Draft Environmental Impact 

Statement for Combined Licenses 

(COLs) for South Texas Project 

Electric Generating Station 

Units 3 and 4 

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, Galveston 

Galveston, TX 77553-1229 

NUREG-1937, Vol. 2
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Draft Environmental Impact 

Statement for Combined Licenses 

(COLs) for South Texas Project 

Electric Generating Station 

Units 3 and 4

Draft Report for Comment 

Manuscript Completed: March 2010 

Date Published: March 2010 

Division of Site and Environmental Review 

Office of New Reactors 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Regulatory Branch 

Planning, Environmental and Regulatory Division 

U.S. Army Engineer District, Galveston 

U.S. Army Corps of Engineers 

Galveston, TX 77553-1229 

NUREG-1937, Vol. 2 
COMMENTS ON DRAFT REPORT 

Any party interested 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 draft NUREG-1937 in your comments and send them by the end of the 

75-day comment period specified in the Federal Register notice announcing availability of this 

draft. 

Chief, Rulemaking, Directives, and Editing Branch 

Mail Stop: T6-D59 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

For any questions about the material in this report, please contact: 

Ms. Jessie Muir 

Mail Stop T7-E30 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Phone: (301) 415-0491 

Email: Jessie.Muir@nrc.gov 

or 

Ms. Sarah Lopas 

Mail Stop T7-E18 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Phone: (301) 415-1147 

Email: Sarah.Lopas@nrc.gov 
March 2010 iii Draft NUREG-1937 

1 Abstract 

2 This environmental impact statement (EIS) has been prepared in response to an application 

3 submitted to the U.S. Nuclear Regulatory Commission (NRC) by STP Nuclear Operating 

4 Company (STPNOC) for combined construction permits and operating licenses (combined 

5 licenses or COLs). The proposed actions related to the STPNOC application are (1) NRC 

6 issuance of COLs for two new nuclear power reactor units at the South Texas Project Electric 

7 Generating Station (STP) site in Matagorda County, Texas, and (2) U.S. Army Corps of 

8 Engineers (Corps) issuance of a permit to perform certain construction activities on the site. 

9 The Corps is participating in preparing this EIS as a cooperating agency and participates 

10 collaboratively on the review team. 

11 This EIS includes the review team’s analysis that considers and weighs the environmental 

12 impacts of building and operating two new nuclear units at the STP site and at alternative sites, 

13 and mitigation measures available for reducing or avoiding adverse impacts. 

14 The EIS includes the evaluation of the proposed action’s impacts to waters of the United States 

15 pursuant to Section 404 of the Federal Water Pollution Control Act (Clean Water Act) and 

16 Section 10 of the Rivers and Harbors Appropriation Act of 1899. The Corps will conduct a public 

17 interest review in accordance with the guidelines promulgated by the U.S. Environmental 

18 Protection Agency under authority of Section 404(b) of the Clean Water Act. The public interest 

19 review, which will be addressed in the Corps’ permit decision document, will include an 

20 alternatives analysis to determine the Least Environmentally Damaging Practicable Alternative. 

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

22 recommendation to the Commission is that the COLs be issued as proposed. This 

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

24 submitted by STPNOC; (2) consultation with Federal, State, Tribal, and local agencies; (3) the 

25 review team’s independent review; (4) the consideration of public scoping comments; and (5) 

26 the assessments summarized in this EIS, including the potential mitigation measures identified 

27 in the ER and this EIS. The Corps will issue its Record of Decision based, in part, on this EIS. 

March 2010 v Draft NUREG-1937 

1 Contents 

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

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

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

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

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

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

8 1.1.1.1 NRC COL Application Review .......................................................1-2

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

10 1.1.2 Preconstruction Activities .............................................................................1-5

11 1.1.3 Cooperating Agencies ..................................................................................1-5

12 1.1.4 Concurrent NRC Reviews ............................................................................1-6

13 1.2 The Proposed Federal Actions.................................................................................1-7

14 1.3 The Purpose and Need for the Proposed Actions....................................................1-8

15 1.4 Alternatives to the Proposed Actions .......................................................................1-8

16 1.5 Compliance and Consultations.................................................................................1-9

17 1.6 References...............................................................................................................1-9

18 2.0 Affected Environment .........................................................................................2-1

19 2.1 Site Location.............................................................................................................2-1

20 2.2 Land Use..................................................................................................................2-1

21 2.2.1 The Site and Vicinity.....................................................................................2-1

22 2.2.2 Transmission Lines.......................................................................................2-9

23 2.2.3 The Region...................................................................................................2-9

24 2.3 Water......................................................................................................................2-11

25 2.3.1 Hydrology ...................................................................................................2-11

26 2.3.1.1 Surface-Water Hydrology ............................................................2-11

27 2.3.1.2 Groundwater Hydrology...............................................................2-20

28 2.3.2 Water Use...................................................................................................2-32

29 2.3.2.1 Surface-Water Use ......................................................................2-33

30 2.3.2.2 Groundwater Use.........................................................................2-35

31 2.3.3 Water Quality..............................................................................................2-39

32 2.3.3.1 Surface-Water Quality .................................................................2-39

33 2.3.3.2 Groundwater Quality....................................................................2-41
Draft NUREG-1937 vi March 2010

1 2.3.4 Water Monitoring ........................................................................................2-43 

2 2.3.4.1 Surface-Water Monitoring............................................................2-43

3 2.3.4.2 Groundwater Monitoring ..............................................................2-45

4 2.4 Ecology...................................................................................................................2-47

5 2.4.1 Terrestrial Ecology......................................................................................2-47

6 2.4.1.1 Terrestrial Communities of the Site and Vicinity ..........................2-47

7 2.4.1.2 Terrestrial Resources – Transmission Lines................................2-55

8 2.4.1.3 Important Terrestrial Species and Habitats..................................2-56

9 2.4.1.4 Terrestrial Ecology Monitoring .....................................................2-65

10 2.4.2 Aquatic Ecology..........................................................................................2-66

11 2.4.2.1 Aquatic Resources of the Site and Vicinity ..................................2-66

12 2.4.2.2 Aquatic Resources – Transmission Lines....................................2-87

13 2.4.2.3 Important Aquatic Species and Habitats......................................2-87

14 2.4.2.4 Aquatic Monitoring .....................................................................2-107

15 2.5 Socioeconomics ...................................................................................................2-108

16 2.5.1 Demographics ..........................................................................................2-111

17 2.5.1.1 Resident Population...................................................................2-112

18 2.5.1.2 Transient Population..................................................................2-113

19 2.5.1.3 Migrant Labor.............................................................................2-115

20 2.5.2 Community Characteristics.......................................................................2-116

21 2.5.2.1 Economy....................................................................................2-117

22 2.5.2.2 Taxes .........................................................................................2-119

23 2.5.2.3 Transportation............................................................................2-126

24 2.5.2.4 Aesthetics and Recreation.........................................................2-130

25 2.5.2.5 Housing......................................................................................2-131

26 2.5.2.6 Public Services ..........................................................................2-133

27 2.6 Environmental Justice ..........................................................................................2-145

28 2.6.1 Methodology.............................................................................................2-146

29 2.6.2 Scoping and Outreach..............................................................................2-149

30 2.6.3 Subsistence and Communities with Unique Characteristics ....................2-150

31 2.6.4 Migrant Populations..................................................................................2-151

32 2.6.5 Environmental Justice Summary ..............................................................2-151

33 2.7 Historic and Cultural Resources...........................................................................2-153

34 2.7.1 Cultural Background.................................................................................2-154

35 2.7.2 Historic and Cultural Resources at the Site..............................................2-155

36 2.7.3 Consultation..............................................................................................2-156
March 2010 vii Draft NUREG-1937 

1 2.8 Geology................................................................................................................2-157

2 2.9 Meteorology and Air Quality.................................................................................2-158

3 2.9.1 Climate .....................................................................................................2-159

4 2.9.1.1 Wind...........................................................................................2-160

5 2.9.1.2 Temperature ..............................................................................2-160

6 2.9.1.3 Atmospheric Moisture ................................................................2-160

7 2.9.1.4 Severe Weather.........................................................................2-161

8 2.9.1.5 Atmospheric Stability .................................................................2-161

9 2.9.2 Air Quality.................................................................................................2-162

10 2.9.3 Atmospheric Dispersion............................................................................2-162

11 2.9.3.1 Short-Term Dispersion Estimates..............................................2-163

12 2.9.3.2 Long-Term Dispersion Estimates...............................................2-164

13 2.9.4 Meteorological Monitoring ........................................................................2-164

14 2.10 Nonradiological Health .........................................................................................2-165

15 2.10.1 Public and Occupational Health ...............................................................2-165

16 2.10.1.1 Air Quality ..................................................................................2-165

17 2.10.1.2 Occupational Injuries .................................................................2-166

18 2.10.1.3 Etiological Agents ......................................................................2-167

19 2.10.2 Noise ........................................................................................................2-168

20 2.10.3 Transportation ..........................................................................................2-169

21 2.10.4 Electromagnetic Fields .............................................................................2-169

22 2.11 Radiological Environment.....................................................................................2-170

23 2.12 Related Federal Projects and Consultation..........................................................2-171

24 2.13 References...........................................................................................................2-171

25 3.0 Site Layout and Plant Description ......................................................................3-1

26 3.1 External Appearance and Plant Layout....................................................................3-1

27 3.2 Proposed Plant Structures .......................................................................................3-2

28 3.2.1 Reactor Power Conversion System..............................................................3-2

29 3.2.2 Structures with a Major Environmental Interface..........................................3-3

30 3.2.2.1 Landscape and Stormwater Drainage ...........................................3-4

31 3.2.2.2 Cooling Water System ...................................................................3-6

32 3.2.2.3 Other Permanent Plant-Environment Interfacing Structures, 

33 Systems, or Components ..............................................................3-8

34 3.2.2.4 Other Temporary Plant-Environment Interfacing Structures........3-10

35 3.2.3 Structures with a Minor Environmental Interface........................................3-11

36 3.3 Construction and Preconstruction Activities...........................................................3-12
Draft NUREG-1937 viii March 2010

1 3.3.1 Major Activity Areas....................................................................................3-14

2 3.3.2 Summary of Resource Commitments During Construction and 

3 Preconstruction...........................................................................................3-17

4 3.4 Operational Activities..............................................................................................3-18

5 3.4.1 Description of Operational Modes ..............................................................3-18

6 3.4.2 Plant-Environment Interfaces During Operation.........................................3-18

7 3.4.2.1 Circulating Water System – Intakes, Discharges, Cooling 

8 Towers.........................................................................................3-18

9 3.4.2.2 Landscape and Drainage.............................................................3-19

10 3.4.2.3 Essential Service Water System – Ultimate Heat Sink................3-19

11 3.4.2.4 Emergency Diesel Generators.....................................................3-19

12 3.4.3 Radioactive Waste-Management System ..................................................3-20

13 3.4.3.1 Liquid Radioactive Waste-Management System .........................3-20

14 3.4.3.2 Gaseous Radioactive Waste-Management System ....................3-21

15 3.4.3.3 Solid Radioactive Waste-Management System...........................3-22

16 3.4.4 Nonradioactive Waste Systems..................................................................3-22

17 3.4.4.1 Solid Waste Management............................................................3-23

18 3.4.4.2 Liquid Waste Management ..........................................................3-23

19 3.4.4.3 Gaseous Waste Management .....................................................3-24

20 3.4.4.4 Hazardous and Mixed Waste Management.................................3-24

21 3.4.5 Summary of Resource Parameters During Operation................................3-25

22 3.5 References.............................................................................................................3-26

23 4.0 Construction Impacts at the Proposed Site ........................................................4-1

24 4.1 Land-Use Impacts ....................................................................................................4-3

25 4.1.1 The Site ........................................................................................................4-4

26 4.1.2 Transmission Lines and Offsite Areas..........................................................4-5

27 4.2 Water-Related Impacts.............................................................................................4-6

28 4.2.1 Hydrological Alterations................................................................................4-7

29 4.2.2 Water-Use Impacts.......................................................................................4-8

30 4.2.3 Water-Quality Impacts ................................................................................4-11

31 4.2.3.1 Surface Water-Quality Impacts....................................................4-11

32 4.2.3.2 Groundwater-Quality Impacts ......................................................4-12

33 4.2.4 Water Monitoring ........................................................................................4-14

34 4.3 Ecological Impacts .................................................................................................4-14

35 4.3.1 Terrestrial and Wetland Impacts.................................................................4-14

36 4.3.1.1 Impacts to Terrestrial Resources – Site and Vicinity ...................4-15
March 2010 ix Draft NUREG-1937 

1 4.3.1.2 Terrestrial Resources – Transmission Line Corridors..................4-19

2 4.3.1.3 Important Terrestrial Species and Habitats..................................4-20

3 4.3.1.4 Terrestrial Monitoring...................................................................4-25

4 4.3.1.5 Summary of Impacts to Terrestrial Resources.............................4-25

5 4.3.2 Aquatic Impacts..........................................................................................4-26

6 4.3.2.1 Aquatic Resources – Site and Vicinity .........................................4-26

7 4.3.2.2 Aquatic Resources – Transmission Line Corridors......................4-29

8 4.3.2.3 Important Aquatic Species and Habitats......................................4-30

9 4.3.2.4 Aquatic Monitoring .......................................................................4-36

10 4.3.2.5 Potential Mitigation Measures for Aquatic Impacts......................4-36

11 4.3.2.6 Summary of Impacts to Aquatic Resources.................................4-36

12 4.4 Socioeconomic Impacts .........................................................................................4-37

13 4.4.1 Physical Impacts.........................................................................................4-37

14 4.4.1.1 Workers and the Local Public ......................................................4-37

15 4.4.1.2 Buildings ......................................................................................4-38

16 4.4.1.3 Roads ..........................................................................................4-39

17 4.4.1.4 Aesthetics ....................................................................................4-39

18 4.4.1.5 Summary of Physical Impacts......................................................4-39

19 4.4.2 Demography...............................................................................................4-40

20 4.4.3 Economic Impacts to the Community .........................................................4-42

21 4.4.3.1 Economy......................................................................................4-42

22 4.4.3.2 Taxes ...........................................................................................4-43

23 4.4.3.3 Summary of Economic Impacts to the Community......................4-45

24 4.4.4 Infrastructure and Community Service Impacts..........................................4-45

25 4.4.4.1 Transportation..............................................................................4-46

26 4.4.4.2 Recreation ...................................................................................4-48

27 4.4.4.3 Housing........................................................................................4-48

28 4.4.4.4 Public Services ............................................................................4-49

29 4.4.4.5 Education.....................................................................................4-52

30 4.4.4.6 Summary of Community Service and Infrastructure Impacts.......4-53

31 4.4.5 Summary of Socioeconomic Impacts .........................................................4-53

32 4.5 Environmental Justice Impacts...............................................................................4-54

33 4.5.1 Analytical Considerations ...........................................................................4-54 

34 4.5.2 Health Impacts............................................................................................4-55 

35 4.5.3 Physical and Environmental Impacts..........................................................4-56

36 4.5.3.1 Soil...............................................................................................4-56

37 4.5.3.2 Water ...........................................................................................4-56

38 4.5.3.3 Air ................................................................................................4-57
Draft NUREG-1937 x March 2010

1 4.5.3.4 Noise............................................................................................4-57

2 4.5.3.5 Summary of Physical and Environmental Impacts.......................4-57

3 4.5.4 Socioeconomic Impacts..............................................................................4-58

4 4.5.5 Subsistence and Special Conditions ..........................................................4-58

5 4.5.5.1 Subsistence .................................................................................4-59

6 4.5.5.2 High-Density Communities ..........................................................4-59

7 4.5.6 Summary of Environmental Justice Impacts ..............................................4-60

8 4.6 Historic and Cultural Resources.............................................................................4-60

9 4.7 Meteorological and Air-Quality Impacts..................................................................4-62

10 4.7.1 Construction and Preconstruction Activities ...............................................4-62

11 4.7.2 Traffic..........................................................................................................4-63

12 4.7.3 Summary ....................................................................................................4-64

13 4.8 Nonradiological Health Impacts..............................................................................4-65

14 4.8.1 Public and Occupational Health .................................................................4-65

15 4.8.1.1 Public Health................................................................................4-65

16 4.8.1.2 Construction Worker Health.........................................................4-66

17 4.8.1.3 Summary of Public and Construction Worker Health Impacts.....4-66

18 4.8.2 Noise Impacts.............................................................................................4-67

19 4.8.3 Impacts of Transporting Construction Materials and Construction 

20 Personnel to the STP Site ..........................................................................4-68

21 4.8.4 Summary of Nonradiological Health Impacts .............................................4-71

22 4.9 Radiological Health Impacts...................................................................................4-71

23 4.9.1 Direct Radiation Exposures........................................................................4-71

24 4.9.2 Radiation Exposures from Gaseous Effluents............................................4-72

25 4.9.3 Radiation Exposures from Liquid Effluents.................................................4-73

26 4.9.4 Total Dose to Site-Preparation Workers.....................................................4-73

27 4.9.5 Summary of Radiological Health Impacts...................................................4-73

28 4.10 Nonradioactive Waste Impacts...............................................................................4-74

29 4.10.1 Impacts to Land..........................................................................................4-74

30 4.10.2 Impacts to Water ........................................................................................4-74

31 4.10.3 Impacts to Air..............................................................................................4-75

32 4.10.4 Summary of Impacts...................................................................................4-76

33 4.11 Measures and Controls to Limit Adverse Impacts During Construction 

34 Activities .................................................................................................................4-76
March 2010 xi Draft NUREG-1937 

1 4.12 Summary of Preconstruction and Construction Impacts ........................................4-77

2 4.13 References.............................................................................................................4-86

3 5.0 Operational Impacts at the Proposed Site..........................................................5-1

4 5.1 Land-Use Impacts ....................................................................................................5-1

5 5.1.1 The Site ........................................................................................................5-2

6 5.1.2 Transmission Lines and Offsite Areas..........................................................5-2

7 5.2 Water-Related Impacts.............................................................................................5-3

8 5.2.1 Hydrological Alterations................................................................................5-4

9 5.2.2 Water-Use Impacts.......................................................................................5-5

10 5.2.2.1 Surface Water................................................................................5-6

11 5.2.2.2 Groundwater-Use Impacts...........................................................5-11

12 5.2.3 Water-Quality Impacts ................................................................................5-14

13 5.2.3.1 Surface-Water Quality Impacts....................................................5-14

14 5.2.3.2 Groundwater Quality Impacts ......................................................5-18

15 5.2.4 Water Monitoring ........................................................................................5-20

16 5.3 Ecological Impacts .................................................................................................5-21

17 5.3.1 Terrestrial and Wetland Impacts.................................................................5-21

18 5.3.1.1 Terrestrial Resources – Site and Vicinity.....................................5-22

19 5.3.1.2 Terrestrial Resources – Transmission Lines................................5-25

20 5.3.1.3 Important Terrestrial Species and Habitats..................................5-27

21 5.3.1.4 Important Terrestrial Species and Habitats – Site and Vicinity....5-27

22 5.3.1.5 Important Terrestrial Species – Transmission Lines....................5-29

23 5.3.1.6 Terrestrial Monitoring...................................................................5-31

24 5.3.1.7 Summary of Terrestrial Ecosystems Impacts ..............................5-31

25 5.3.2 Aquatic Impacts..........................................................................................5-31

26 5.3.2.1 Aquatic Resources – Site and Vicinity .........................................5-31

27 5.3.2.2 Aquatic Resources – Transmission Lines....................................5-43

28 5.3.2.3 Important Aquatic Species and Habitats......................................5-44

29 5.3.2.4 Aquatic Monitoring .......................................................................5-47

30 5.3.2.5 Summary of Impacts to Aquatic Resources.................................5-48

31 5.4 Socioeconomic Impacts .........................................................................................5-48

32 5.4.1 Physical Impacts.........................................................................................5-49

33 5.4.1.1 Workers and the Local Public ......................................................5-49

34 5.4.1.2 Buildings ......................................................................................5-50

35 5.4.1.3 Roads ..........................................................................................5-50

36 5.4.1.4 Aesthetics ....................................................................................5-50

37 5.4.1.5 Summary of Physical Impacts......................................................5-51
Draft NUREG-1937 xii March 2010

1 5.4.2 Demography...............................................................................................5-51

2 5.4.3 Economic Impacts to the Community .........................................................5-52

3 5.4.3.1 Economy......................................................................................5-52

4 5.4.3.2 Taxes ...........................................................................................5-53

5 5.4.3.3 Summary of Economic Impacts ...................................................5-56

6 5.4.4 Infrastructure and Community Services .....................................................5-56

7 5.4.4.1 Transportation..............................................................................5-56

8 5.4.4.2 Recreation ...................................................................................5-57

9 5.4.4.3 Housing........................................................................................5-57

10 5.4.4.4 Public Services ............................................................................5-58

11 5.4.4.5 Education.....................................................................................5-59

12 5.4.4.6 Summary of Infrastructure and Community Services ..................5-60

13 5.4.5 Summary of Socioeconomic Impacts .........................................................5-60

14 5.5 Environmental Justice ............................................................................................5-60

15 5.5.1 Health Impacts............................................................................................5-61 

16 5.5.2 Physical and Environmental Impacts..........................................................5-62

17 5.5.2.1 Soil...............................................................................................5-62

18 5.5.2.2 Water ...........................................................................................5-62

19 5.5.2.3 Air ................................................................................................5-63 

20 5.5.2.4 Summary of Physical and Environmental Impacts.......................5-63

21 5.5.3 Socioeconomic Impacts..............................................................................5-63

22 5.5.4 Subsistence and Special Conditions ..........................................................5-64

23 5.5.5 Summary of Environmental Justice Impacts ..............................................5-64

24 5.6 Historic and Cultural Resource Impacts.................................................................5-64

25 5.7 Meteorological and Air Quality Impacts..................................................................5-65

26 5.7.1 Air Quality Impacts .....................................................................................5-66

27 5.7.2 Cooling System Impacts.............................................................................5-67

28 5.7.3 Summary ....................................................................................................5-69

29 5.8 Nonradiological Health Impacts..............................................................................5-69

30 5.8.1 Etiological Agents.......................................................................................5-70

31 5.8.2 Noise ..........................................................................................................5-72

32 5.8.3 Acute Effects of Electromagnetic Fields .....................................................5-73

33 5.8.4 Chronic Effects of Electromagnetic Fields..................................................5-74

34 5.8.5 Occupational Health ...................................................................................5-75

35 5.8.6 Impacts of Transporting Operations Personnel to the Proposed Site ........5-76
March 2010 xiii Draft NUREG-1937 

1 5.8.7 Summary of Nonradiological Health Impacts .............................................5-77

2 5.9 Radiological Impacts of Normal Operations...........................................................5-78

3 5.9.1 Exposure Pathways....................................................................................5-78

4 5.9.2 Radiation Doses to Members of the Public ................................................5-79

5 5.9.2.1 Liquid Effluent Pathway ...............................................................5-79

6 5.9.2.2 Gaseous Effluent Pathway ..........................................................5-83

7 5.9.3 Impacts to Members of the Public ..............................................................5-83

8 5.9.3.1 Maximally Exposed Individual......................................................5-84

9 5.9.3.2 Population Dose ..........................................................................5-85

10 5.9.3.3 Summary of Radiological Impacts to Members of the Public.......5-87

11 5.9.4 Occupational Doses to Workers .................................................................5-87

12 5.9.5 Doses to Biota Other than Humans............................................................5-87

13 5.9.5.1 Liquid Effluent Pathway ...............................................................5-88

14 5.9.5.2 Gaseous Effluent Pathway ..........................................................5-88

15 5.9.5.3 Impact of Estimated Non-Human Biota Doses ............................5-89

16 5.9.6 Radiological Monitoring ..............................................................................5-90

17 5.10 Nonradioactive Waste Impacts...............................................................................5-92

18 5.10.1 Impacts to Land..........................................................................................5-92

19 5.10.2 Impacts to Water ........................................................................................5-93

20 5.10.3 Impacts to Air..............................................................................................5-93

21 5.10.4 Mixed Waste Impacts .................................................................................5-94

22 5.10.5 Summary of Waste Impacts .......................................................................5-94

23 5.11 Environmental Impacts of Postulated Accidents ....................................................5-95

24 5.11.1 Design Basis Accidents ..............................................................................5-96

25 5.11.2 Severe Accidents........................................................................................5-99 

26 5.11.2.1 Air Pathway................................................................................5-100

27 5.11.2.2 Surface-Water Pathway.............................................................5-107

28 5.11.2.3 Groundwater Pathway ...............................................................5-108 

29 5.11.2.4 Summary ...................................................................................5-109 

30 5.11.3 Severe Accident Mitigation Alternatives ...................................................5-109

31 5.11.4 Summary of Postulated Accident Impacts................................................5-111

32 5.12 Measures and Controls to Limit Adverse Impacts During Operation ...................5-111

33 5.13 Summary of Operational Impacts.........................................................................5-115

34 5.14 References...........................................................................................................5-118

35 6.0 Fuel Cycle, Transportation, and Decommissioning ............................................6-1
Draft NUREG-1937 xiv March 2010

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

2 6.1.1 Land Use ......................................................................................................6-8

3 6.1.2 Water Use.....................................................................................................6-8

4 6.1.3 Fossil Fuel Impacts.......................................................................................6-8

5 6.1.4 Chemical Effluents........................................................................................6-9

6 6.1.5 Radiological Effluents.................................................................................6-10

7 6.1.6 Radiological Wastes...................................................................................6-12

8 6.1.7 Occupational Dose .....................................................................................6-15

9 6.1.8 Transportation ............................................................................................6-15

10 6.1.9 Conclusion..................................................................................................6-16

11 6.2 Transportation Impacts...........................................................................................6-16

12 6.2.1 Transportation of Unirradiated Fuel............................................................6-18

13 6.2.1.1 Normal Conditions .......................................................................6-18

14 6.2.1.2 Radiological Impacts of Transportation Accidents.......................6-24

15 6.2.1.3 Nonradiological Impacts of Transportation Accidents..................6-24

16 6.2.2 Transportation of Spent Fuel......................................................................6-25

17 6.2.2.1 Normal Conditions .......................................................................6-26

18 6.2.2.2 Radiological Impacts of Accidents ...............................................6-32

19 6.2.2.3 Nonradiological Impact of Spent Fuel Shipments........................6-36

20 6.2.3 Transportation of Radioactive Waste .........................................................6-37

21 6.2.4 Conclusions................................................................................................6-39

22 6.3 Decommissioning Impacts .....................................................................................6-39

23 6.4 References.............................................................................................................6-41

24 7.0 Cumulative Impacts ............................................................................................7-1

25 7.1 Land Use..................................................................................................................7-6

26 7.2 Water Use and Quality .............................................................................................7-8

27 7.2.1 Water Use Impacts.......................................................................................7-8

28 7.2.1.1 Surface Water-Use Impacts...........................................................7-9

29 7.2.1.2 Groundwater-Use Impacts...........................................................7-13

30 7.2.2 Water-Quality Impacts ................................................................................7-16

31 7.2.2.1 Surface-Water Quality Impacts....................................................7-16

32 7.2.2.2 Groundwater-Quality Impacts ......................................................7-19

33 7.3 Ecology...................................................................................................................7-21

34 7.3.1 Terrestrial and Wetland Ecosystem Impacts ..............................................7-21

35 7.3.1.1 Wildlife and Plant Communities ...................................................7-22
March 2010 xv Draft NUREG-1937 

1 7.3.1.2 Important Species........................................................................7-26

2 7.3.2 Aquatic Ecosystem Impacts .......................................................................7-28

3 7.4 Socioeconomics and Environmental Justice..........................................................7-35

4 7.4.1 Socioeconomics .........................................................................................7-35

5 7.4.2 Environmental Justice ................................................................................7-39

6 7.5 Historic and Cultural Resources.............................................................................7-41

7 7.6 Air Quality...............................................................................................................7-42

8 7.6.1 Criteria Pollutants .......................................................................................7-42

9 7.6.2 Greenhouse Gas Emissions.......................................................................7-43

10 7.6.3 Summary ....................................................................................................7-45

11 7.7 Nonradiological Health ...........................................................................................7-45

12 7.8 Radiological Impacts of Normal Operation.............................................................7-47

13 7.9 Postulated Accidents..............................................................................................7-49

14 7.10 Fuel Cycle, Transportation, and Decommissioning................................................7-50

15 7.10.1 Fuel Cycle...................................................................................................7-50

16 7.10.2 Transportation ............................................................................................7-50

17 7.10.3 Decommissioning .......................................................................................7-53

18 7.11 Conclusions and Recommendations......................................................................7-53

19 7.12 References.............................................................................................................7-56

20 8.0 Need for Power...................................................................................................8-1

21 8.1 Description of Power System ...................................................................................8-1

22 8.1.1 Description of STPNOC................................................................................8-1

23 8.1.2 Description of ERCOT ..................................................................................8-2

24 8.1.3 Description of the ERCOT Analytical Process..............................................8-5 

25 8.1.3.1 Systematic Test .............................................................................8-5

26 8.1.3.2 Comprehensive Test......................................................................8-5 

27 8.1.3.3 Subject to Confirmation Test .........................................................8-6

28 8.1.3.4 Responsive to Forecasting UncertaintyTest ..................................8-7

29 8.1.3.5 Summary of ERCOT Analytical Process........................................8-7

30 8.2 Power Demand.........................................................................................................8-7

31 8.3 Power Supply .........................................................................................................8-16

32 8.4 Assessment of Need for Power..............................................................................8-23

33 8.4.1 Conclusion..................................................................................................8-25

34 8.5 References.............................................................................................................8-26
Draft NUREG-1937 xvi March 2010

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

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

3 9.2 Energy Alternatives ..................................................................................................9-3

4 9.2.1 Alternatives Not Requiring New Generating Capacity..................................9-3

5 9.2.2 Alternatives Requiring New Generating Capacity ........................................9-6

6 9.2.2.1 Coal-Fired Generation ...................................................................9-7

7 9.2.2.2 Natural Gas-Fired Generation......................................................9-15

8 9.2.3 Other Alternatives.......................................................................................9-20

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

10 9.2.3.2 Wind Power .................................................................................9-20

11 9.2.3.3 Solar Power .................................................................................9-22

12 9.2.3.4 Hydropower .................................................................................9-23

13 9.2.3.5 Geothermal Energy......................................................................9-24

14 9.2.3.6 Wood Waste ................................................................................9-24

15 9.2.3.7 Municipal Solid Waste .................................................................9-25

16 9.2.3.8 Other Biomass-Derived Fuels......................................................9-26

17 9.2.3.9 Fuel Cells.....................................................................................9-26

18 9.2.4 Combination of Alternatives........................................................................9-27

19 9.2.5 Summary Comparison of Alternatives ........................................................9-29

20 9.3 Alternative Sites .....................................................................................................9-31

21 9.3.1 Alternative Sites Selection Process............................................................9-31

22 9.3.1.1 Selection of Region of Interest.....................................................9-31

23 9.3.1.2 Selection of Candidate Areas ......................................................9-32

24 9.3.1.3 Selection of Potential Sites ..........................................................9-33

25 9.3.1.4 Selection of Primary Sites............................................................9-34

26 9.3.1.5 Selection of Candidate Sites........................................................9-38

27 9.3.1.6 Evaluation of STPNOC’s Site Selection Process.........................9-40

28 9.3.2 Red 2..........................................................................................................9-42

29 9.3.2.1 Land Use .....................................................................................9-44

30 9.3.2.2 Water Use and Quality.................................................................9-47

31 9.3.2.3 Terrestrial and Wetland Resources .............................................9-56

32 9.3.2.4 Aquatic Resources.......................................................................9-67

33 9.3.2.5 Socioeconomics...........................................................................9-74

34 9.3.2.6 Environmental Justice..................................................................9-81

35 9.3.2.7 Historic and Cultural Resources ..................................................9-84

36 9.3.2.8 Air Quality ....................................................................................9-86

37 9.3.2.9 Nonradiological Health.................................................................9-88

38 9.3.2.10 Radiological Impacts of Normal Operations.................................9-90
March 2010 xvii Draft NUREG-1937 

1 9.3.2.11 Postulated Accidents ...................................................................9-91

2 9.3.3 Allens Creek ...............................................................................................9-92

3 9.3.3.1 Land Use .....................................................................................9-95

4 9.3.3.2 Water Use and Quality.................................................................9-98

5 9.3.3.3 Terrestrial and Wetland Resources ...........................................9-105

6 9.3.3.4 Aquatic Resources.....................................................................9-117

7 9.3.3.5 Socioeconomics.........................................................................9-126

8 9.3.3.6 Environmental Justice................................................................9-132

9 9.3.3.7 Historic and Cultural Resources ................................................9-137

10 9.3.3.8 Air Quality ..................................................................................9-140

11 9.3.3.9 Nonradiological Health...............................................................9-141

12 9.3.3.10 Radiological Impacts of Normal Operations...............................9-143

13 9.3.3.11 Postulated Accidents .................................................................9-144

14 9.3.4 Trinity 2.....................................................................................................9-144

15 9.3.4.1 Land Use ...................................................................................9-148

16 9.3.4.2 Water Use and Quality...............................................................9-151

17 9.3.4.3 Terrestrial and Wetland Resources ...........................................9-159

18 9.3.4.4 Aquatic Resources.....................................................................9-171

19 9.3.4.5 Socioeconomics.........................................................................9-178

20 9.3.4.6 Environmental Justice................................................................9-186

21 9.3.4.7 Historic and Cultural Resources ................................................9-189

22 9.3.4.8 Air Quality ..................................................................................9-192

23 9.3.4.9 Nonradiological Health...............................................................9-193

24 9.3.4.10 Radiological Impacts of Normal Operations...............................9-195

25 9.3.4.11 Postulated Accidents .................................................................9-196

26 9.3.5 Comparison of the Impacts of the Proposed Action and Alternative 

27 Sites..........................................................................................................9-197

28 9.3.5.1 Comparison of Cumulative Impacts at the Proposed and 

29 Alternative Sites.........................................................................9-198

30 9.3.5.2 Environmentally Preferable Sites...............................................9-200

31 9.3.5.3 Obviously Superior Sites............................................................9-202

32 9.4 System Design Alternatives .................................................................................9-202

33 9.4.1 Heat Dissipation Systems.........................................................................9-203

34 9.4.1.1 Plant Cooling System – Once-Through Operation.....................9-203

35 9.4.1.2 Spray Canals .............................................................................9-204

36 9.4.1.3 Wet Mechanical Draft Cooling Towers.......................................9-204

37 9.4.1.4 Wet Natural Draft Cooling Towers .............................................9-205

38 9.4.1.5 Dry Cooling Towers ...................................................................9-205

39 9.4.1.6 Combination Wet/Dry Cooling Tower System............................9-205
Draft NUREG-1937 xviii March 2010

1 9.4.2 Circulating Water Systems .......................................................................9-206

2 9.4.2.1 Intake Alternatives .....................................................................9-206

3 9.4.2.2 Discharge Alternatives...............................................................9-207

4 9.4.2.3 Water Supplies ..........................................................................9-208

5 9.4.2.4 Water Treatment........................................................................9-209

6 9.4.3 Conclusion................................................................................................9-210

7 9.5 Corps' Onsite Alternatives Evaluation ..................................................................9-210 

8 9.5.1 Onsite Alternative 1 ..................................................................................9-210 

9 9.5.2 Onsite Alternative 2 ..................................................................................9-210

10 9.5.3 Onsite Alternative 3 (STPNOC's Preferred Alternative) ...........................9-211

11 9.6 References...........................................................................................................9-211

12 10.0 Conclusions and Recommendations ................................................................10-1

13 10.1 Impacts of the Proposed Action .............................................................................10-3

14 10.2 Unavoidable Adverse Environmental Impacts........................................................10-4

15 10.2.1 Unavoidable Adverse Impacts During Construction and 

16 Preconstruction...........................................................................................10-4

17 10.2.2 Unavoidable Adverse Impacts During Operation .......................................10-7

18 10.3 Relationship Between Short-Term Uses and Long-Term Productivity of 

19 the Human Environment.......................................................................................10-12

20 10.4 Irreversible and Irretrievable Commitments of Resources ...................................10-13

21 10.4.1 Irreversible Commitments of Resources ..................................................10-13

22 10.4.1.1 Land Use ...................................................................................10-14

23 10.4.1.2 Water Use..................................................................................10-14

24 10.4.1.3 Aquatic and Terrestrial Biota......................................................10-14

25 10.4.1.4 Socioeconomic Resources ........................................................10-15

26 10.4.1.5 Air and Water.............................................................................10-15

27 10.4.2 Irretrievable Commitments of Resources .................................................10-15

28 10.5 Alternatives to the Proposed Action .....................................................................10-15

29 10.6 Benefit-Cost Balance............................................................................................10-16

30 10.6.1 Benefits.....................................................................................................10-18

31 10.6.1.1 Societal Benefits ........................................................................10-19

32 10.6.1.2 Regional Benefits.......................................................................10-20

33 10.6.2 Costs ........................................................................................................10-21

34 10.6.2.1 Internal Costs.............................................................................10-23

35 10.6.2.2 External Costs ...........................................................................10-25

36 10.6.3 Summary of Benefits and Costs ...............................................................10-26
March 2010 xix Draft NUREG-1937 

1 10.7 Staff Conclusions and Recommendations ...........................................................10-27

2 10.8 References...........................................................................................................10-27

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

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

5 Appendix C – NRC and Corps Environmental Review Correspondence.................................. C-1

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

7 Appendix E – Draft Environmental Impact Statement Comments and Responses ................. E-1

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

9 Appendix G – Supporting Documentation for Socioeconomic and Radiological Dose 

10 Assessment .......................................................................................................G-1

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

12 Appendix I – Carbon Dioxide Footprint Estimates for a 1000 MW(e) Light Water Reactor 

13 (LWR) ..................................................................................................................I-1 

14 Appendix J – U.S. Army Corps of Engineers Cumulative Effect Resource Analysis Table......J-1 
Draft NUREG-1937 xx March 2010

1 Figures 

2 2-1 STP Site and Proposed Plant Footprint ..........................................................................2-2

3 2-2 STP Site and Vicinity ......................................................................................................2-3

4 2-3 Land-Use Classifications at STP Site..............................................................................2-4

5 2-4 Landscape Features and Habitat Types of the STP Site ................................................2-5

6 2-5 Land-Use Classifications in the Vicinity of the STP Site .................................................2-6

7 2-6 Land-Use Classifications in STP 50-mi Region ............................................................2-10

8 2-7 Location of the STP Site and the Adjacent Watersheds ...............................................2-12

9 2-8 The Colorado River Basin .............................................................................................2-13

10 2-9 Location of the STP Site with Respect to Nearby Cities, the Matogorda Bay, and 

11 the Gulf of Mexico .........................................................................................................2-14

12 2-10 Daily Mean Colorado River Discharge near Bay City, Texas .......................................2-15

13 2-11 The Six LCRA Dams and the Corresponding Highland Lakes They Impound .............2-17

14 2-12 Current and Future Locations of the Main Drainage Channel ......................................2-21

15 2-13 Kelly Lake and Local Drainages Flowing Into and Out of the Lake ...............................2-22

16 2-14 Correlation of USGS and Texas Nomenclature ............................................................2-23

17 2-15 Aquifers of Texas ..........................................................................................................2-25

18 2-16 Generalized Hydrostratigraphic Section Underlying the STP Site ................................2-29

19 2-17 Hydrological Monitoring Locations for Existing STP Units 1 and 2 ...............................2-44

20 2-18 Stormwater Monitoring Locations for Existing STP Units 1 and 2 ................................2-46

21 2-19 Vegetation Cover and Land-Use Cover Types at the STP Site.....................................2-49

22 2-20 Locations of Wildlife Refuges and Critical Habitat within 50 mi of the STP Site............2-58

23 2-21 Location of STP with Respect to Important Aquatic Resources and the 1975-1976 

24 Aquatic Ecology Sampling Locations.............................................................................2-70

25 2-22 Aquatic Ecology Sampling Locations for 2007-2008, from NMM 5 to 9 ........................2-79

26 2-23 Aquatic Ecology Sampling Locations for 2007-2008, from GIWW to NMM 4................2-80

27 2-24 Map of Central Texas Gulf Coast, Showing Counties Potentially Affected by the 

28 Proposed Units 3 and 4 ..............................................................................................2-111

29 2-25 Road, Highway and Rail Transportation System ........................................................2-127

30 2-26 Main Routes to STP Site .............................................................................................2-128

31 2-27 Aggregate Minority Populations in Block Groups Meeting Environmental Justice 

32 Selection Criteria ........................................................................................................2-148

33 2-28 Black or African American Populations in Block Groups Meeting Environmental 

34 Justice Selection Criteria ............................................................................................2-149

35 2-29 Asian or Pacific Islander Populations in Block Groups Meeting Environmental 

36 Justice Selection Criteria ............................................................................................2-150

37 2-30 Hispanic Populations in Block Groups Meeting Environmental Justice Selection 

38 Criteria ........................................................................................................................2-152
March 2010 xxi Draft NUREG-1937 

1 2-31 Aggregate Low Income Populations in Block Groups Meeting Environmental 

2 Justice Selection Criteria ............................................................................................2-153

3 3-1 Representative Ground-Level Photograph of STP Units 1 and 2 ...................................3-2

4 3-2 Simplified Flow Diagram of Reactor Power Conversion System ....................................3-4

5 3-3 STP Site Layout Map.......................................................................................................3-5

6 4-1 Total Workforce, STP Units 3 and 4 .............................................................................4-41

7 5-1 Exposure Pathways to Man ..........................................................................................5-80

8 5-2 Exposure Pathways to Biota Other Than Man ..............................................................5-81

9 6-1 The Uranium Fuel Cycle: No-Recycle Option ................................................................6-6

10 6-2 Illustration of Truck Stop Model .....................................................................................6-30

11 7-1 Geographic Area of Interest Evaluated to Assess Cumulative Impacts to 

12 Terrestrial Ecological Resources...................................................................................7-23

13 8-1 Map of the ERCOT ISO Service Area ............................................................................8-2

14 8-2 Peak Demand and Average Demand in the ERCOT Region 2009-2019 ......................8-9

15 8-3 ERCOT 2007 Load Duration Curve...............................................................................8-10

16 8-4 ERCOT 2006, 2007, 2008, and 2009 Peak Load Forecasts .........................................8-11

17 8-5 ERCOT 2008 and 2009 Energy Demand Forecasts ....................................................8-11

18 8-6 Population in the ERCOT Region .................................................................................8-12

19 8-7 Total Non-Farm Employment in the ERCOT Region ....................................................8-13

20 8-8 Per Capita Income in the ERCOT Region ....................................................................8-13

21 8-9 ERCOT Net Load Duration Curve in 2018 with 18,456 MW of Wind Generation 

22 Capacity ........................................................................................................................8-19

23 8-10 Alternative ERCOT Generation Capacity Reduction Scenarios vs. Projected 

24 Demand ........................................................................................................................8-21

25 9-1 Candidate Areas ...........................................................................................................9-33

26 9-2 Potential Sites ...............................................................................................................9-35

27 9-3 Screening Criteria Evaluation Results ..........................................................................9-36

28 9-4 Primary Sites ................................................................................................................9-37

29 9-5 Red 2 Alternative Site and 10-mi Radius.......................................................................9-45

30 9-6 Geographic Area of Analysis of Cumulative Impacts to Terrestrial Resources for 

31 the Red 2 Site in Grayson and Fannin Counties ...........................................................9-57

32 9-7 Minority Block Groups within 50 mi of the Red 2 Site....................................................9-82

33 9-8 Low-Income Block Groups within 50 mi of the Red 2 Alternative Site...........................9-83

34 9-9 Allens Creek Alternative Site and 10-mi Radius............................................................9-96

35 9-10 Geographic Area for the Analysis of Cumulative Impacts to Terrestrial Resources 

36 within the Western Gulf Coast Plains Ecoregion in the Lower Brazos and San 

37 Bernard watersheds within Austin, Colorado, Wharton, Waller, and Fort Bend 

38 Counties ......................................................................................................................9-106

39 9-11 Minority Block Groups within 50 mi of the Allens Creek Alternative Site.....................9-134

40 9-12 Low-Income Block Groups Near the Allens Creek Alternative Site .............................9-135

41 9-13 Trinity 2 Alternative Site and 10-mi Radius..................................................................9-150
Draft NUREG-1937 xxii March 2010

1 9-14 Geographic Area of Analysis of Cumulative Impacts to Terrestrial Resources for 

2 the Trinity 2 Site in Freestone County .........................................................................9-161

3 9-15 Minority Block Groups within 50 mi of the Trinity 2 Alternative Site.............................9-187

4 9-16 Low-Income Block Groups within 50 mi of the Trinity 2 Alternative Site......................9-188

5 
March 2010 xxiii Draft NUREG-1937 

1 Tables 

2 2-1 Land Use at the STP Site ................................................................................................2-8

3 2-2 Representative Hydrogeologic Properties of Confining Layers in the STP 

4 Hydrogeologic Strata .....................................................................................................2-30

5 2-3 Representative Hydrogeologic Properties of Aquifers in the STP Hydrogeologic 

6 Strata .............................................................................................................................2-31

7 2-4 Groundwater Resource Estimates for Matagorda County.............................................2-37

8 2-5 Maximum Tritium Concentration in Water Bodies Near the STP Site ..........................2-45

9 2-6 Approximate Acreages of Habitats and Land Use Found on the STP Site ...................2-48

10 2-7 Amphibians Found in Matagorda County, Texas...........................................................2-52

11 2-8 Birds Observed On or Around the STP Project Area for Units 3 and 4 .........................2-54

12 2-9 Federally Listed Terrestrial Species Occurring in the Vicinity of the STP Site and 

13 the STP-to-Hillje Transmission Corridor ........................................................................2-56

14 2-10 State-Listed Species Occurring or Potentially Occurring in the Region of the STP 

15 Site and the STP-to-Hillje Transmission Corridor..........................................................2-60

16 2-11 Fish and Shellfish Collected in the MCR by Gear Type, 2007-2008 .............................2-72

17 2-12 Aquatic Species Collected during Impingement Sampling in the MCR’s CWIS for 

18 Units 1 and 2, 2007-2008 ..............................................................................................2-73

19 2-13 Aquatic Species Collected During Entrainment Sampling in the MCR’s CWIS for 

20 Units 1 and 2, 2007-2008 ..............................................................................................2-74

21 2-14 Fish and Shellfish Collected in the Colorado River by Gear Type, 2007-2008..............2-82

22 2-15 Important Aquatic Species that May Occur in the Vicinity of STP Site..........................2-88

23 2-16 Distribution of STP Employees, January 2007 ............................................................2-109

24 2-17 Counties within 50 mi of the STP Site .........................................................................2-110

25 2-18 Historical and Projected Populations for Counties in the STP Region ........................2-114

26 2-19 Municipalities in the 50-mi Region Surrounding the STP Site .....................................2-115

27 2-20 Hotels Nights Available and Sold in Four-County Socioeconomic Impact Area 

28 Surrounding the STP Site, 2006..................................................................................2-115

29 2-21 Minority and Low-Income Populations ........................................................................2-117

30 2-22 Employment by Industry, 2005 ....................................................................................2-119

31 2-23 Major Employers in Matagorda, Brazoria, Calhoun, and Jackson Counties................2-120

32 2-24 Employment and Unemployment Statistics for Matagorda, Brazoria, Calhoun, and 

33 Jackson Counties ........................................................................................................2-121

34 2-25 Matagorda County Property Tax Information, 2000-2005 ..........................................2-123

35 2-26 Property Tax Statistics for Matagorda County and Special Districts 2001-2006 ........2-124

36 2-27 Palacios Independent School District Property Tax Revenues and Disposition 

37 2000-2005 ..................................................................................................................2-125

38 2-28 Roadway Use Statistics for Most Likely Routes to the STP Site .................................2-129

39 2-29 Wildlife Management Areas and Parks within 50 mi of the STP Site ..........................2-130
Draft NUREG-1937 xxiv March 2010

1 2-30 Regional Housing Information by County for the Year 2000 .......................................2-132

2 2-31 Water Supply, Capacity, and Average Daily Consumption by Major Water Supply 

3 Systems in Matagorda and Brazoria Counties ............................................................2-135

4 2-32 Designed Capacity and Maximum Water Treated in Wastewater Treatment 

5 Systems in Brazoria, Calhoun, Jackson, and Matagorda Counties.............................2-136

6 2-33 Law Enforcement Personnel 2005...............................................................................2-138

7 2-34 Fire Protection Personnel ............................................................................................2-139

8 2-35 Hospital Data for Brazoria, Calhoun, Jackson and Matagorda Counties.....................2-141

9 2-36 United Way Agencies of Matagorda County................................................................2-143

10 2-37 Public School Statistics in the Four-County Socioeconomic Impact Area, 

11 2005-2006 ...................................................................................................................2-144

12 2-38 Private School Statistics in the Four-County Socioeconomic Impact Area, 

13 2005-2006 ...................................................................................................................2-145

14 2-39 Atmospheric Dispersion Factors for Proposed Unit 3 and 4 Design Basis Accident 

15 Calculations .................................................................................................................2-163

16 2-40 Maximum Annual Average Atmospheric Dispersion and Deposition Factors for 

17 Evaluation of Normal Effluents for Receptors of Interest.............................................2-164

18 2-41 Construction Noise Sources and Attenuation with Distance........................................2-169

19 3-1 Descriptions and Examples of Activities Associated with Building Units 3 and 4 ..........3-13

20 3-2 Summary of Resource Commitments Associated with Building Proposed Units 3 

21 and 4..............................................................................................................................3-17

22 3-3 Representative Water Treatment Chemicals Used for STP Units 1 and 2....................3-24

23 3-4 Parameters Associated with Operation of Proposed STP Units 3 and 4.......................3-25

24 4-1 Drawdown in Feet at the STP Property Line and a Point 2500 ft from a Production 

25 Well................................................................................................................................4-10

26 4-2 Estimated Acreage Affected by Proposed Activities by Habitat Type and Land Use ....4-15

27 4-3 Calculation of Traffic Impacts on FM 521 from Building Activities at Proposed 

28 Units 3 and 4, Months 26-35..........................................................................................4-46

29 4-4 Estimated Impacts of Transporting Workers and Materials to and from the STP 

30 Site for a Single ABWR..................................................................................................4-70

31 4-5 Direct Radiation Doses to Unit 4 Construction Workers................................................4-72

32 4-6 Summary of Measures and Controls Proposed by STPNOC to Limit Adverse 

33 Impacts During Construction of Proposed Units 3 and 4...............................................4-78

34 4-7 Summary of Construction and Preconstruction Impacts for Proposed Units 3 and 4....4-83

35 5-1 Summary Statistics of Simulated Colorado River Streamflow Below the RMPF .............5-9

36 5-2 Drawdown at the STP Property Line and a Point 2500 ft from a Production Well........5-13

37 5-3 Summary Statistics of Simulated Water Temperature and Total Dissolved Solids 

38 of MCR Discharge .........................................................................................................5-16

39 5-4 Potential Increase in Resident Population Resulting from Operating Units 3 and 4......5-52

40 5-5 Estimated Operations Impacts to Property Taxes for Matagorda County and 

41 Special Districts ............................................................................................................5-55
March 2010 xxv Draft NUREG-1937 

1 5-6 Anticipated Atmospheric Emissions Associated With Operation of Proposed Units 

2 3 and 4...........................................................................................................................5-66

3 5-7 MCR Fog Impact Analysis .............................................................................................5-68

4 5-8 Nonradiological Estimated Impacts of Transporting Operations Workers to and 

5 from the STP Site ..........................................................................................................5-77

6 5-9 Annual Doses to the MEI for Liquid Effluent Releases from a New Unit .......................5-82

7 5-10 Annual Doses to the MEI for Gaseous Effluent Releases from a New Unit ..................5-84

8 5-11 Comparison of Annual MEI Dose Rates for a Single Unit with 10 CFR 50, 

9 Appendix I Criteria .........................................................................................................5-85

10 5-12 Comparison of Maximally Exposed Individual Dose Rates with 40 CFR Part 190 

11 Criteria ...........................................................................................................................5-86

12 5-13 Biota Doses for Proposed Units 3 and 4........................................................................5-89

13 5-14 Comparison of Biota Doses from the Proposed Units 3 and 4 at the STP Site to 

14 Relevant Guidelines for Biota Protection.......................................................................5-90

15 5-15 Atmospheric Dispersion Factors for STP Site DBA Calculations ..................................5-98

16 5-16 Design Basis Accident Doses for an ABWR..................................................................5-98

17 5-17 Mean Environmental Risks from ABWR Reactor Severe Accidents at the STP Site ..5-101

18 5-18 Comparison of Environmental Risks for an ABWR Reactor at the STP Site with 

19 Risks for Current-Generation Reactors at Five Sites Evaluated in NUREG-1150.......5-102

20 5-19 Comparison of Environmental Risks from Severe Accidents Initiated by Internal 

21 Events for an ABWR Reactor at the STP Site with Risks Initiated by Internal 

22 Events for Current Plants Undergoing Operating License Renewal Review and 

23 Environmental Risks of the ABWR Reactor at Other Sites..........................................5-103

24 5-20 Summary of Proposed Measures and Controls to Limit Adverse Impacts During 

25 Operation.....................................................................................................................5-112

26 5-21 Summary of Operational Impacts at the Proposed Units 3 and 4 Site ........................5-116

27 6-1 Table S–3 from 10 CFR 51.51(b), Table of Uranium Fuel Cycle Environmental 

28 Data .................................................................................................................................6-2

29 6-2 Comparison of Annual Average Dose Received by an Individual from All Sources ......6-13

30 6-3 Numbers of Truck Shipments of Unirradiated Fuel for the Reference LWR and the 

31 ABWR............................................................................................................................6-19

32 6-4 RADTRAN 5.6 Input Parameters for Unirradiated Fuel Shipments...............................6-20

33 6-5 Radiological Impacts Under Normal Conditions of Transporting Unirradiated Fuel 

34 to the STP Site or Alternative Sites ...............................................................................6-21

35 6-6 Nonradiological Impacts of Transporting Unirradiated Fuel to the STP Site and 

36 Alternative Sites, Normalized to Reference LWR..........................................................6-25

37 6-7 Transportation Route Information for Shipments from the STP Site and Alternative 

38 Sites to the Proposed Geologic Repository at Yucca Mountain, Nevada......................6-28

39 6-8 RADTRAN 5.6 Normal (Incident-free) Exposure Parameters........................................6-29
Draft NUREG-1937 xxvi March 2010

1 6-9 Normal Radiation Doses to Transport Workers and the Public from Shipping 

2 Spent Fuel from the STP Site and Alternative Sites to the Proposed High-Level 

3 Waste Repository at Yucca Mountain............................................................................6-31

4 6-10 Radionuclide Inventories Used in Transportation Accident Risk Calculations for an 

5 ABWR............................................................................................................................6-34

6 6-11 Annual Spent Fuel Transportation Accident Impacts for an ABWR at the STP Site 

7 and Alternative Sites, Normalized to Reference 1100-MW(e) LWR Net Electrical 

8 Generation.....................................................................................................................6-36

9 6-12 Nonradiological Impacts of Transporting Spent Fuel from the STP Site and 

10 Alternative Sites to Yucca Mountain, Normalized to Reference LWR ...........................6-37

11 6-13 Summary of Radioactive Waste Shipments from the STP Site and Alternative 

12 Sites...............................................................................................................................6-38

13 6-14 Nonradiological Impacts of Radioactive Waste Shipments from the STP Site..............6-39

14 7-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

15 Considered in the STP Cumulative Analysis. ..................................................................7-3

16 7-2 Comparison of Annual Carbon Dioxide Emission Rates ...............................................7-44

17 7-3 Cumulative Impacts on Environmental Resources, Including the Impacts of 

18 Proposed Units 3 and 4 .................................................................................................7-54

19 8-1 ERCOT Peak Demand and Calculated Reserve Margin, 2009-2014............................8-16

20 8-2 ERCOT Calculated Reserve Margin, 2009-2024...........................................................8-16

21 8-3 2009 ERCOT Forecasted Summer Resources 2009-2024 ...........................................8-20

22 8-4 STPNOC Forecasted Summer Capacity, Baseload Generation Units Only..................8-22

23 8-5 ERCOT/Review Team Forecasted Summer Capacity, Baseload Generation Units 

24 Only ..............................................................................................................................8-23

25 8-6 ERCOT/Revoew Team Forecasted Unmet Need for Baseload Generation 

26 Compared with STPNOC Estimated Need for Baseload Power....................................8-25

27 9-1 Summary of Environmental Impacts of Coal-Fired Power Generation..........................9-14

28 9-2 Summary of Environmental Impacts of Natural Gas-Fired Power Generation ..............9-19

29 9-3 Summary of Environmental Impacts of a Combination of Power Sources ....................9-28

30 9-4 Summary of Environmental Impacts of Construction and Operation of New 

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

32 of Alternatives................................................................................................................9-30

33 9-5 Comparison of Carbon Dioxide Emissions for Energy Alternatives...............................9-30

34 9-6 Criteria for Selection of Candidate Sites........................................................................9-39

35 9-7 Composite Ratings for the Primary Sites.......................................................................9-40

36 9-8 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

37 Considered in the Cumulative Analysis of the Red 2 Alternative Site ...........................9-43

38 9-9 Estimated Land Cover Classes for Approximately 2000 ac of the 2500-ac Red 2 

39 Site ................................................................................................................................9-58

40 9-10 Federally and State-Listed Threatened and Endangered Species in Fannin 

41 County, Texas................................................................................................................9-60
March 2010 xxvii Draft NUREG-1937 

1 9-11 State-Listed Aquatic Species that are Endangered, Threatened, and Species of 

2 Concern for Fannin County............................................................................................9-70

3 9-12 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

4 Considered in the Allens Creek Alternative Site Cumulative Analysis...........................9-93

5 9-13 Estimated Acreages by Land Cover Classes for Approximately 300 ac of the 

6 800-ac Allens Creek Site .............................................................................................9-107

7 9-14 List of Federal and State Threatened and Endangered Species in Austin, Fort 

8 Bend, Colorado, and Wharton Counties, Texas ..........................................................9-109

9 9-15 Federally and State-Listed Aquatic Species that are Endangered, Threatened, 

10 and Species of Concern for Austin County..................................................................9-122

11 9-16 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

12 Considered in the Cumulative Analysis of the Trinity 2 Alternative Site. .....................9-145

13 9-17 Estimated Land Cover Classes for an Approximately 2000 ac of the 2500-ac 

14 Trinity 2 Site.................................................................................................................9-162

15 9-18 List of Federal and State Threatened and Endangered Species in Freestone 

16 County, Texas..............................................................................................................9-164

17 9-19 Federally and State-Listed Aquatic Species that are Endangered, Threatened, 

18 and Species of Concern for Freestone County............................................................9-174

19 9-20 Comparison of Cumulative Impacts at the Proposed and Alternative Sites ................9-199

20 10-1 Unavoidable Adverse Environmental Impacts from Construction and 

21 Preconstruction Activities...............................................................................................10-4

22 10-2 Unavoidable Adverse Environmental Impacts from Operation......................................10-8

23 10-3 Summary of Benefits of the Proposed Action..............................................................10-18

24 10-4 Summary of Costs of Preconstruction, Construction, and Operation ..........................10-21

March 2010 xxix Draft NUREG-1937 

1 Executive Summary 

2 By letter dated September 20, 2007, the U.S. Nuclear Regulatory Commission (NRC or the 

3 Commission) received an application from STP Nuclear Operating Company (STPNOC) for 

4 combined construction permits and operating licenses (combined licenses or COLs) for South 

5 Texas Project Electric Generating Station (STP) Units 3 and 4, located in Matagorda County, 

6 Texas. The review team’s evaluation is based on the September 2009 revision to the 

7 application, responses to requests for additional information, and supplemental letters. 

8 The proposed actions related to the STP Units 3 and 4 application are (1) NRC issuance of 

9 COLs for construction and operation of two new nuclear units at the STP site, and (2) U.S. Army 

10 Corps of Engineers (Corps) issuance of a permit pursuant to Section 404 of the Federal Water 

11 Pollution Control Act (Clean Water Act) and Section 10 of the Rivers and Harbors Act to perform 

12 certain construction activities on the site. The Corps is participating with the NRC in preparing 

13 this environmental impact statement (EIS) as a cooperating agency and participates 

14 collaboratively on the review team. The reactor specified in the application is a certified U.S. 

15 Advanced Boiling Water Reactor design (U.S. ABWR, hereafter referred to as ABWR in this 

16 EIS). 

17 Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA) 

18 (42 USC 4321 et seq.) directs that an EIS be prepared for major Federal actions that 

19 significantly affect the quality of the human environment. The NRC has implemented 

20 Section 102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. Further, in 

21 10 CFR 51.20, the NRC has determined that the issuance of a COL under 10 CFR Part 52 is an 

22 action that requires an EIS. 

23 The purpose of STPNOC’s requested NRC action—issuance of the COLs—is to obtain licenses 

24 to construct and operate two new nuclear units. These licenses are necessary but not sufficient 

25 for construction and operation of the units. A COL applicant must obtain and maintain the 

26 necessary permits from other Federal, State, Tribal, and local agencies and permitting 

27 authorities. Therefore, the purpose of the NRC’s environmental review of the STPNOC 

28 application is to determine if two new nuclear units of the proposed design can be constructed 

29 and operated at the STP site without unacceptable adverse impacts on the human environment. 

30 The purpose of STPNOC’s requested Corps action is to obtain a permit to perform regulated 

31 activities that would impact waters of the United States. 

32 Upon acceptance of the STPNOC application, the NRC began the environmental review 

33 process described in 10 CFR Part 51 by publishing in the Federal Register a Notice of Intent 

34 (72 FR 72774) to prepare an EIS and conduct scoping. On February 5, 2008, the NRC held two 

35 scoping meetings in Bay City, Texas, to obtain public input on the scope of the environmental 
Draft NUREG-1937 xxx March 2010

1 review. The staff reviewed the comments received during the scoping process and contacted 

2 Federal, State, Tribal, regional, and local agencies to solicit comments. 

3 To gather information and to become familiar with the sites and their environs, the NRC and its 

4 contractor Pacific Northwest National Laboratory (PNNL) visited the STP site in February 2008 

5 and the Allens Creeks alternative site in March 2008. In August 2009, the NRC and PNNL 

6 visited the Red 2 and Trinity 2 alternative sites. During the site visits, the NRC staff and its 

7 contractors met with STPNOC staff, public officials, and the public. 

8 Included in this EIS are (1) the results of the review team’s analyses, which consider and weigh 

9 the environmental effects of the proposed actions; (2) potential mitigation measures for reducing 

10 or avoiding adverse effects; (3) the environmental impacts of alternatives to the proposed 

11 action; and (4) the NRC staff’s preliminary recommendation regarding the proposed action. 

12 To guide its assessment of the environmental impacts of a proposed action or alternative 

13 actions, the NRC has established a standard of significance for impacts based on Council on 

14 Environmental Quality guidance (40 CFR 1508.27). Table B-1 of 10 CFR Part 51, Subpart A, 

15 Appendix B, provides the following definitions of the three significance levels – SMALL, 

16 MODERATE, and LARGE: 

17 SMALL – Environmental effects are not detectable or are so minor that they will 

18 neither destabilize nor noticeably alter any important attribute of the resource. 

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

20 destabilize, important attributes of the resource. 

21 LARGE – Environmental effects are clearly noticeable and are sufficient to 

22 destabilize important attributes of the resource. 

23 In preparing this EIS, the review team reviewed the application, including the Environmental 

24 Report (ER) submitted by STPNOC; consulted with Federal, State, Tribal, and local agencies; 

25 and followed the guidance set forth in NUREG-1555, Environmental Standard Review Plan. In 

26 addition, the NRC staff considered the public comments related to the environmental review 

27 received during the scoping process. Comments within the scope of the environmental review 

28 are included in Appendix D of this EIS. 

29 The NRC staff’s preliminary recommendation to the Commission related to the environmental 

30 aspects of the proposed action is that the COLs be issued as requested. This recommendation 

31 is based on (1) the application, including the ER submitted by STPNOC; (2) consultation with 

32 other Federal, State, Tribal, and local agencies; (3) the staff’s independent review; (4) the staff’s 

33 consideration of public scoping comments; and (5) the assessments summarized in this EIS, 
March 2010 xxxi Draft NUREG-1937 

1 including the potential mitigation measures identified in the ER and this EIS. The Corps will 

2 issue its Record of Decision based, in part, on this EIS. 

3 A 75-day comment period will begin on the date of publication of the U.S. Environmental 

4 Protection Agency (EPA) Notice of Availability of the filing of the draft EIS to allow members of 

5 the public and agencies to comment on the results of the environmental review. During this 

6 period, the NRC and Corps staff will conduct a public meeting near the STP site to describe the 

7 results of the environmental review, respond to questions, and accept public comment. All 

8 comments received during the comment period will be addressed in the final EIS. 

9 The NRC staff’s evaluation of the site safety and emergency preparedness aspects of the 

10 proposed action will be addressed in the NRC’s Safety Evaluation Report anticipated to be 

11 published in 2011. 

March 2010 xxxiii Draft NUREG-1937 

1 Abbreviations/Acronyms 

2 AADT Average Annual Daily Traffic 

3 ABWR U.S. Advanced Boiling Water Reactor 

4 ac acre(s) 

5 ACHP Advisory Council on Historic Preservation 

6 ADAMS Agencywide Documents Access and Management System 

7 AEP American Electric Power 

8 AEP Archaeology and Ethnography Program 

9 APE area of potential effect 

10 ALARA as low as reasonably achievable 

11 ASLB Atomic Safety and Licensing Board 

12 

13 BEA Bureau of Economic Analysis 

14 BEIR Biological Effects of Ionizing Radiation 

15 BGCD Bluebonnet Groundwater Conservation District 

16 BGS below ground surface 

17 BMP best management practice 

18 Btu British thermal unit(s) 

19 Bq Becquerel(s) 

20 BWR boiling water reactor 

21 

22 °C degree(s) Celsius 

23 CAES compressed air energy storage 

24 CBC Christmas Bird Count 

25 CCD Census County Division 

26 CDC Centers for Disease Control and Prevention 

27 CDF core damage frequency 

28 CDR Capacity, Demand, and Resources Report 

29 CEQ Council on Environmental Quality 

30 CFR Code of Federal Regulations 

31 cfs cubic feet per second (water flow) 

32 Ci curie(s) 

33 cm centimeter(s) 

34 CMP Coastal Management Program 

35 CMZ Coastal Management Zone 

36 CNP CenterPoint Energy 

37 CO carbon monoxide 

38 CO2 carbon dioxide 

39 COL combined license 
Draft NUREG-1937 xxxiv March 2010

1 CORMIX Cornell Mixing Zone Expert System 

2 Corps U.S. Army Corps of Engineers 

3 CPGCD Coastal Plains Groundwater Conservation District 

4 CPS Energy City Public Service Board of San Antonio, Texas 

5 CPUE catch per unit effort 

6 CR County Road (CR 360, CR 392) 

7 CREZ Competitive Renewable Energy Zones 

8 CWA Clean Water Act 

9 CWIS circulating water intake structure 

10 CWS circulating water system 

11 CZMA Coastal Zone Management Act 

12 

13 DBA Design Basis Accident 

14 dBA decibel(s) (acoustic) 

15 DC design certification 

16 DCD Design Control Document 

17 DOE U.S. Department of Energy 

18 DOT U.S. Department of Transportation 

19 DSM demand side management 

20 D/Q deposition values 

21 DWS drinking water standards 

22 

23 EA Environmental Assessment 

24 EAB Exclusion Area Boundary 

25 ECP Essential Cooling Pond 

26 EIS environmental impact statement 

27 EFH essential fish habitat 

28 ELF extremely low frequency 

29 EMF electromagnetic field 

30 EOF Emergency Operations Facility 

31 EPA U.S. Environmental Protection Agency 

32 ER Environmental Report 

33 ERCOT Electric Reliability Council of Texas 

34 ESA U.S. Endangered Species Act of 1973, as amended 

35 ESRP Environmental Standard Review Plan 

36 

37 °F degree(s) Fahrenheit 

38 FAA Federal Aviation Administration 

39 FDA final design approval 

40 FERC Federal Energy Regulatory Commission 

41 FES Final Environmental Statement 
March 2010 xxxv Draft NUREG-1937 

1 FM Farm-to-Market 

2 FMP Fishery Management Plan 

3 fps feet per second 

4 FR Federal Register 

5 FSAR Final Safety Analysis Report 

6 FSER Final Safety Evaluation Report 

7 ft foot or feet 

ft2 8 square feet 

ft3 9 cubic feet 

10 FWS U.S. Fish and Wildlife Service 

11 

12 GBq gigabecquerel 

13 GCC global climate change 

14 GCRP U.S. Global Change Research Program 

15 GE General Electric 

16 GEIS generic environmental impact statement 

17 GHG greenhouse gases 

18 GIT Georgia Institute of Technology 

19 GIWW Gulf Intracoastal Waterway 

20 gpd gallon(s) per day 

21 gpm gallon(s) per minute 

22 GRWMS gaseous radioactive waste-management system 

23 

24 ha hectare(s) 

25 HAPC habitat areas of particular concern 

26 hr hour(s) 

27 Hg mercury 

28 Hz hertz 

29 

30 IAEA International Atomic Energy Agency 

31 ICRP International Commission on Radiological Protection 

32 IGCC integrated gasification combined cycle 

33 in. inch 

34 INEEL Idaho National Engineering and Environmental Laboratory 

35 IOU investor owned utility 

36 ISD Independent School District 

37 ISO independent system operator 

38 I&S interest and sinking fund rate 

39 

40 km kilometer(s) 

km2 41 square kilometer(s) 
Draft NUREG-1937 xxxvi March 2010

1 kWh kilowatt-hour(s) 

2 kV kilovolt(s) 

3 

4 L liter(s) 

5 lb pound(s) 

6 LCRA Lower Colorado River Authority 

7 LCRWPG Lower Colorado Regional Water Planning Group 

8 LEDPA least environmentally damaging practicable alternative 

9 LERF large early release frequency 

10 LLW low-level waste 

11 LNG liquefied natural gas 

12 LOS level of service 

13 LPZ Low Population Zone 

14 LRF large release frequency 

15 LST local standard time 

16 LSWP LCRA-SAWS Water Project 

17 LTSF Long-Term Storage Facility 

18 LWA Limited Work Authorization 

19 LWMS liquid waste management system 

20 LWR light water reactor 

21 

22 m meter(s) 

m3 23 cubic meter(s) 

24 MACCS2 MELCOR Accident Consequence Code System Version 2 

25 MBq megabecquerel(s) 

26 MCEDC Matagorda County Economic Development Corporation 

27 MCEMO Matagorda County Emergency Management Office 

28 MCR Main Cooling Reservoir 

29 MDC Main Drainage Channel 

30 MEI maximally exposed individual 

31 mg milligram(s) 

32 MGD million gallons per day 

33 mg/L milligram(s) per liter 

34 mi mile(s) 

mi2 35 square mile(s) 

36 MIT Massachusetts Institute of Technology 

37 mL milliliter(s) 

38 MMS Minerals Management Service 

39 mo month 

40 MOU Memorandum of Understanding 

41 M&O maintenance and operations 
March 2010 xxxvii Draft NUREG-1937 

1 mph mile(s) per hour 

2 mR milliroentgen 

3 mrad millirad(s) 

4 mrem millirem(s) 

5 μS microsiemens 

6 MSA Metropolitan Statistical Area 

7 MSL mean sea level 

8 mSv millisievert(s) 

9 MT metric ton(s) (or tonne[s]) 

10 MTU metric ton(s) of uranium 

11 MUD municipal utilities district 

12 MW megawatt(s) 

13 MWd megawatt-day(s) 

14 MW(e) megawatt(s) electrical 

15 MW(t) megawatt(s) thermal 

16 

17 NCI National Cancer Institute 

18 NCRP National Council on Radiation Protection & Measurements 

19 NEI Nuclear Energy Institute 

20 NEPA National Environmental Policy Act of 1969, as amended 

21 NERC North American Electric Reliability Corporation 

22 NESC National Electric Safety Code 

23 NHPA National Historic Preservation Act of 1966, as amended 

24 NIEHS National Institute of Environmental Health Sciences 

25 NINA Nuclear Innovation North America 

26 NMFS National Marine Fisheries Services 

27 NMM navigation mile marker 

28 NOAA National Oceanic and Atmospheric Administration 

29 NOx nitrogen oxide 

30 NPDES National Pollutant Discharge Elimination System 

31 NRC U.S. Nuclear Regulatory Commission 

32 NRG NRG South Texas LP 

33 NRHP National Register of Historic Places 

34 NTF Nuclear Training Facility 

35 

36 ODCM offsite dose calculation manual 

37 OSF Onsite Staging Facility 

38 OSGSF Old Steam Generator Storage Facility 

39 OSHA Occupational Safety and Health Administration 

40 OW observation well 

41 
Draft NUREG-1937 xxxviii March 2010

1 PAM primary amoebic meningoencephalitis 

2 pCi picocuries 

3 pCi/L picocuries per liter 

4 PGC Power Generation Company 

5 PIR Public Interest Review 

6 PM particulate matter 

7 PM2.5 particulate matter with a diameter of 2.5 microns or less 

8 PM10 particulate matter with a diameter of 10 microns or less 

9 PNNL Pacific Northwest National Laboratory 

10 ppt parts per thousand 

11 PSD prevention of significant deterioration 

12 PUCT Public Utility Commission of Texas 

13 PWR pressurized water reactors 

14 

15 RAI request for additional information 

16 RCRA Resource Conservation and Recovery Act of 1976, as amended 

17 RCW Reactor Building Cooling Water 

18 rem roentgen equivalent man (a special unit of radiation dose) 

19 REMP radiological environmental monitoring program 

20 RIMS Regional Input-Output Model System 

21 RMPF Reservoir Makeup Pumping Facility 

22 RMR reliability must run 

23 ROD Record of Decision 

24 ROI region of interest 

25 ROW right of way 

26 RSICC Radiation Safety Information Computational Center 

27 RSW Reactor Service Water 

28 Ryr reactor-year 

29 

30 s second(s) 

31 SACTI Seasonal and Annual Cooling Tower Impacts 

32 SAMA severe accident mitigation alternatives 

33 SAMDA severe accident mitigation design alternatives 

34 SAWS San Antonio Water System 

35 SCR selective catalytic reduction 

36 SECPOP 2000 Sector Population, Land Fraction, and Economic Estimation Program 

37 SER Safety Evaluation Report 

38 SHPO State Historic Preservation Officer 

39 SO2 sulphur dioxide 

40 SOx sulphur oxide 

41 STP South Texas Project Electric Generating Station 
March 2010 xxxix Draft NUREG-1937 

1 STPNOC STP Nuclear Operating Company 

2 Sv sievert 

3 SWMS solid waste management system 

4 SWPPP Stormwater Pollution Prevention Plan 

5 

6 TAC Texas Administrative Code 

7 TAMUG Texas A&M University at Galveston 

8 TBEG Texas Bureau of Economic Geology 

9 TBq terabecquerel(s) 

10 TCC Texas Central Company 

11 TCEQ Texas Commission on Environmental Quality 

12 TCMP Texas Coastal Management Plan 

13 TDS total dissolved solids 

14 TDSHS Texas Department of State Health Services 

15 TEDE total effective dose equivalent 

16 THC Texas Historical Commission 

17 TIS Texas Interconnected System 

18 TLD thermoluminescent dosimeter 

19 TMDL total maximum daily load 

20 TPDES Texas Pollutant Discharge Elimination System 

21 TPWD Texas Parks and Wildlife Department 

22 TPWP Texas Prairie Wetlands Project 

23 TRAGIS Transportation Routing Analysis Geographic Information System 

24 TWC Texas Water Code 

25 TWDB Texas Water Development Board 

26 TX Texas 

27 TXDOT Texas Department of Transportation 

28 

29 U3O8 triuranium octaoxide (“yellowcake”) 

30 UF6 uranium hexafluoride 

31 UFSAR Updated Final Safety Analysis Report 

32 UHS Ultimate Heat Sink 

33 UMTRI University of Michigan Transportation Research Institute 

34 UO2 uranium oxide 

35 USACE U.S. Army Corps of Engineers 

36 USC United States Code 

37 USGS U.S. Geological Survey 

38 

39 VOC volatile organic compound 

40 

41 WCS Waste Control Specialists, LLC 
Draft NUREG-1937 xl March 2010

1 WHO World Health Organization 

2 WMA Wildlife Management Area 

3 WSEC White Stallion Energy Center 

4 WSWTS West Sanitary Waste Treatment System 

5 WCID Water Control and Improvement District 

6 

7 χ/Q dispersion values 

8 

9 yd yard(s) 

yd3 10 cubic yard(s) 

11 yr year(s) 

12 
March 2010 8-1 Draft NUREG-1937 

1 8.0 Need for Power 

2 Chapter 8 of the U.S. Nuclear Regulatory Commission’s (NRC) Environmental Standard Review 

3 Plan (ESRP) (NRC 2000) guides the NRC staff’s review and analysis of the need for power from 

4 a proposed nuclear power plant. In addition to the ESRP guidance, the NRC addressed need 

5 for power in a 2003 response to a petition for rulemaking (68 FR 55910). In the 2003 response, 

6 the NRC reviewed whether or not need for power should be considered in NRC environmental 

7 impact statements (EISs) prepared in conjunction with applications that could result in 

8 construction of a new nuclear power plant. The NRC (68 FR 55910) concluded that: 

9 The need for power must be addressed in connection with new power plant 

10 construction so that the NRC may weigh the likely benefits (e.g., electrical power) 

11 against the environmental impacts of constructing and operating a nuclear power 

12 reactor. The Commission emphasizes, however, that such an assessment 

13 should not involve burdensome attempts to precisely identify future conditions. 

14 Rather, it should be sufficient to reasonably characterize the costs and benefits 

15 associated with proposed licensing actions. 

16 While the NRC will perform a need for power analysis in its EIS, the NRC also stated in its 

17 response to the petition that (1) the NRC does not supplant the states, which have traditionally 

18 been responsible for assessing the need for power-generating facilities, for their economic 

19 feasibility and for regulating rates and services; and (2) the NRC has acknowledged the primacy 

20 of state regulatory decisions regarding future energy options (68 FR 55910). 

21 8.1 Description of Power System 

22 8.1.1 Description of STPNOC 

23 The purpose of proposed Units 3 and 4 at the South Texas Plant Electric Generating Station 

24 (STP) site is to provide baseload generation for use by the owners and/or for eventual sale on 

25 the wholesale market. As discussed in Chapter 1, it is planned that Unit 3 would be owned by 

26 Nuclear Innovation North America (NINA) South Texas 3 LLC and the City of San Antonio, 

27 Texas, through the City Public Services Board (CPS Energy), and that Unit 4 would be owned 

28 by NINA South Texas 4 LLC and CPS Energy. Both proposed units would be baseload 

29 merchant generator plants. NINA South Texas 3 LLC and NINA South Texas 4 LLC intend to 

30 sell their share of the power from Units 3 and 4 on the wholesale market. CPS Energy may 

31 either use its share of Units 3 and 4 to supply the needs of its service area and/or sell the power 

32 on the wholesale market (STPNOC 2009). 
Need For Power 

Draft NUREG-1937 8-2 March 2010 

1 The applicant, STP Nuclear Operating Company (STPNOC), stated in its application for 

2 combined licenses (COLs) that proposed Units 3 and 4 at the STP site would be unregulated 

3 entities. The electric utility industry in the State of Texas was deregulated in 2002. One of the 

4 principal owners of proposed Units 3 and 4 (NINA) is a merchant generator that does not have a 

5 specific service area. The other principal owner, CPS Energy, is a municipal utility that sells 

6 capacity in excess of its own retail service needs in the San Antonio area into the Electric 

7 Reliability Council of Texas (ERCOT) wholesale market (STPNOC 2009). Currently, CPS 

8 Energy has several wholesale contracts, for which it is seeking renewal, that amount to firm 

9 power obligations. In addition, CPS Energy’s native retail service area of Bexar County and the 

10 San Antonio vicinity also is growing in population and represents additional potential demand. 

11 However, in estimating the need for power for proposed Units 3 and 4, STPNOC is relying on 

12 ERCOT’s forecast of the overall demand for power in the ERCOT region rather than CPS 

13 Energy’s specific service and contract obligations (STPNOC 2009). 

14 8.1.2 Description of ERCOT 

15 STPNOC has defined the region of interest for evaluating the need for power as the entire area 

16 served by ERCOT, the independent system operator (ISO) for the electric grid for most of the 

17 State of Texas (Figure 8-1). 

18 

19 Figure 8-1. Map of the ERCOT ISO Service Area (STPNOC 2009)
Need For Power 

March 2010 8-3 Draft NUREG-1937 

1 ERCOT is a membership-based nonprofit corporation formed under 26 USC 501(c)(6) of the 

2 Internal Revenue Code. It is governed by a board of directors and subject to oversight by the 

3 Public Utility Commission of Texas (PUCT) and the Texas Legislature. ERCOT’s members 

4 include retail consumers, investor-owned and municipally-owned utilities, rural electric 

5 cooperatives, river authorities, independent generators, power marketers, and retail electric 

6 providers (ERCOT 2008a). The ERCOT board of directors is made up of independent 

7 members, consumers, and representatives from each of ERCOT’s electric market segments. 

8 The board of directors appoints ERCOT’s officers, who direct and manage day-to-day 

9 operations (ERCOT 2008b). ERCOT’s responsibilities include: 

10  managing the flow of electric power to approximately 22 million Texas customers, 

11 representing 85 percent of the State’s electric load, 

12  scheduling power on an electric grid with 40,000 mi of high-voltage transmission lines and 

13 more than 550 generation units, 

14  managing financial settlements for the Texas competitive wholesale bulk-power market, and 

15  administering of customer switching for 6.5 million Texans in competitive choice areas 

16 (ERCOT 2008c). 

17 As explained in STPNOC’s environmental report (ER), the history of the deregulation of the 

18 previously regulated electric supply market in the ERCOT region began in 1995, when the 

19 Texas Legislature passed Senate Bill 373, introducing wholesale competition into Texas’ 

20 intrastate market. PUCT adopted rules requiring all transmission system owners to make their 

21 transmission systems available for use by others at prices and on terms comparable to each 

22 respective owner’s use of its system for its own wholesale transactions. In 1999, by terms of 

23 Senate Bill 7, choice was further broadened by allowing retail customers of investor owned 

24 utilities (IOUs) to choose their electric energy supplier (electric cooperatives and municipally 

25 owned utilities such as CPS Energy had the option not to allow their retail customers to join this 

26 arrangement and CPS Energy has not allowed this). Formerly, vertically integrated IOUs had to 

27 separate their retail energy service activities from regulated utility activities and to unbundle their 

28 generation, transmission/ distribution, and retail electric sales functions into separate units, 

29 which could be sold off or else operated as independent entities at arm’s length from each 

30 other. Transmission and distribution entities (including electric cooperatives and integrated 

31 municipally owned utilities) are fully regulated by the PUCT and must make their facilities 

32 available on an open and non-discriminatory basis. IOUs and independent power producers 

33 owning generation assets must be registered as power generation companies with the PUCT 

34 and must comply with certain rules that are intended to protect consumers, but they are 

35 otherwise unregulated and may sell electricity in private bilateral transactions and at market 

36 prices (STPNOC 2009). 
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Draft NUREG-1937 8-4 March 2010 

1 As explained in the ER and confirmed in the references below, under deregulation in Texas, 

2 utilities no longer perform the comprehensive analysis and planning functions that they once 

3 did. The central planning organization under the new Texas market is the ERCOT ISO. State 

4 law assigns these obligations to ERCOT, under the oversight of the PUCT. The analyses, 

5 reports, system planning processes, and criteria development from ERCOT are the key 

6 measures for determining resource needs in the State [see e.g., Texas Utility Code Ann. §§ 

7 39.155(b) and 39.904(k)] (Texas Utilities Code 2009). STPNOC is relying upon several studies 

8 performed for or by ERCOT on need for power in ERCOT’s capacity as a regional transmission 

9 organization. Regional transmission organizations were created as a result of Order No. 2000 

10 issued by the Federal Energy Regulatory Commission (FERC), which encouraged the voluntary 

11 formation of such organizations to administer the transmission grid on a regional basis 

12 throughout North America (FERC 1999, 2008). 

13 The ERCOT ISO region is also the geographic territory of the Texas Regional Entity (Texas RE) 

14 (ERCOT 2008g). Texas RE is one of the eight approved regional entities in North America 

15 under the North American Electric Reliability Corporation (NERC). NERC’s mission is to ensure 

16 the reliability of the bulk power system in North America. NERC develops and enforces 

17 reliability standards, monitors the bulk power system, assesses and reports on future 

18 transmission and generation adequacy, and offers education and certification programs to utility 

19 industry personnel (NERC 2008a). Texas RE is a functionally independent division of ERCOT 

20 and is independent of all users, owners, and operators of the bulk power system in the State of 

21 Texas. As mandated by the delegation agreement with NERC approved by FERC, Texas RE 

22 performs the regional entity functions described in the Energy Policy Act of 2005 for the ERCOT 

23 region. Texas RE develops, monitors, assesses, and enforces NERC reliability standards within 

24 the ERCOT region. In addition, Texas RE has been authorized by the PUCT and is permitted 

25 by NERC to investigate compliance with the ERCOT protocols and operating guides, working 

26 with PUCT staff regarding any potential protocol violations (ERCOT 2008g). 

27 The ERCOT region is almost entirely isolated from other NERC regions, electrically speaking. 

28 The formation of what is now the ERCOT region dates from the beginning of World War II, when 

29 several Texas utilities banded together and interconnected to support the war effort as the 

30 Texas Interconnected System (STPNOC 2009). Texas Interconnected System formed ERCOT 

31 in 1970 to comply with NERC requirements (ERCOT 2008d). Since the goals of these entities 

32 over the years have been to ensure the reliability of the Texas grid rather than to interconnect 

33 with the rest of the country, importing electric power into, or exporting electric power out of the 

34 ERCOT region effectively is not practicable. As a practical matter this means that electricity 

35 demand in the ERCOT region must be served from generation within ERCOT and that power 

36 generated in excess of demand within ERCOT cannot effectively reach other markets (STPNOC 

37 2009). 
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March 2010 8-5 Draft NUREG-1937 

1 8.1.3 Description of the ERCOT Analytical Process 

2 NRC guidance provides that additional independent review by the NRC may not be needed 

3 when need for power analyses prepared by an independent third party such as an affected 

4 state, NERC reliability council, or regional transmission organization is sufficiently (1) 

5 systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to forecasting 

6 uncertainty (NRC 2000). Taken in aggregate, the staff determined that the studies and reports 

7 summarized in Section 8.4 satisfy the four tests . 

8 8.1.3.1 Systematic Test 

9 The review team determined ERCOT has a systematic and iterative process for load forecasting 

10 and reliability assessment that is updated annually. ERCOT is required by the PUCT to provide 

11 extensive studies, issue reports, make recommendations for transmission system needs and 

12 resource adequacy, and even make legislative recommendations to further those objectives 

13 (STPNOC 2009). The essence of ERCOT is that it is a neutral and independent source of 

14 information on electricity issues for policymakers. The development of these reports is subject 

15 to a vigorous stakeholder input process. 

16 Membership in ERCOT is open to any entity that meets any of the segment definitions as set 

17 forth in the ERCOT bylaws. Members must be in an organization that either operates in the 

18 ERCOT region or represents consumers within the ERCOT region. The members are 

19 organized by the following market segments: consumers, cooperatives, independent 

20 generators, independent power marketers, independent retail electric providers, investor owned 

21 utilities, and municipal utilities (ERCOT 2005b, 2008l). ERCOT uses industry best practices and 

22 methodological approaches to determine future system reliability and the need for new 

23 generating capacity. The forecasts and methods are vetted by ERCOT membership. 

24 Moreover, the analyses and actions of ERCOT based on these analyses are overseen by the 

25 PUCT. 

26 8.1.3.2 Comprehensive Test 

27 The review team finds that, in aggregate, the ERCOT studies and reports discussed in Section 

28 8.4 are comprehensive. ERCOT (ERCOT 2008e) takes account of trends in customer demand 

29 (including the underlying factors of population, income, and employment growth and impacts of 

30 both normal and extreme weather conditions. The electricity supply analysis takes into account 

31 changes in generation profile and potential generation additions; new generating resources 

32 planned for construction in Texas; trends in electric power generation by fuel source; trends in 

33 consumption by class of consumer; forecasts of future electricity sales; transmission congestion 

34 in Texas; demand side management (DSM), demand response, and distributed generation; and 

35 electric reliability assessments. The demand forecasts are fed into the generation and 

36 transmission planning process. ERCOT uses industry best practices and methodological 
Need For Power 

Draft NUREG-1937 8-6 March 2010 

1 approaches to determine system reliability and the need for new generating capacity (ERCOT 

2 2008f, i, j, k). Moreover, the forecasts are subject to a vigorous participatory process. 

3 The model developers recognize that they have not been successful in the past in including 

4 electricity prices as valid predictive variables in the electricity demand model (ERCOT 2008e, 

5 2009a): 

6 In regard to prices, which are considered an important driver for inclusion in a 

7 demand equation, it is not clear as to whether or not the wholesale prices that 

8 ERCOT collects are really the most relevant for a forecasting application, in 

9 terms of being the prices ultimately faced by the consumer. Since the wholesale 

10 prices are collected on an hourly basis, and retail prices are better reflected by 

11 an average over a longer time period, such as a month, wholesale hourly prices 

12 do not capture the correlation with the MWh consumption correctly. Several 

13 attempts to include market clearing prices of energy in the forecasting models 

14 were made but were unsuccessful. The models obtained showed price to be 

15 insignificant or to indicate a nonsensical relationship regarding the direction of 

16 the effect of price (wrong sign on the coefficient) and thus should not be included 

17 in a long-term demand equation. To make matters more challenging in this 

18 respect, an objective and credible forecast of these prices would represent a 

19 major accomplishment in itself. Inclusion of a price variable in the forecasting 

20 models could potentially provide a means to calculate an unbiased and credible 

21 forecast of the price effect on the long-term load response. 

22 However, reportedly, the constraints have been overcome and all future versions of the demand 

23 forecast will include the effects of energy prices (PNNL 2009). 

24 8.1.3.3 Subject to Confirmation Test 

25 The review team finds that, in aggregate, the studies and reports discussed in Section 8.4 are 

26 subject to confirmation. ERCOT’s forecasts are independently prepared. These forecasts are 

27 then independently reviewed, confirmed, and consolidated by PUCT and NERC. Both the 

28 Long-Term Peak Demand study (ERCOT 2008e) and the Capacity, Demand, and Resources 

29 Report (CDR) look at historical information as a check on past forecasting performance and 

30 these results are published. For example, in 2008 to validate the forecast model, an out-of31 sample prediction was performed by estimating the model with data up to December 2005 and a 

32 forecast was produced for January 2006 to December 2006 using the actual temperatures. A 

33 forecast for the summer season only was also produced using the actual temperatures. The 

34 system peak that occurred on August 17, 2006, was forecasted for the year 2006 with a 0.78 

35 percent error and a 0.45 percent error for the summer alone (ERCOT 2008e). Forecast 

36 comparisons for 2008 show a -0.5 percent error for annual energy (with monthly errors from -7.6 
Need For Power 

March 2010 8-7 Draft NUREG-1937 

1 percent to plus 6.0 percent). Maximum hourly demand at the August peak had a -1.0 percent 

2 error and the forecast for annual peak had a -4.2 percent error (ERCOT 2008c) 

3 Over a longer term, from 1999 to 2006, the ERCOT peak demand and energy consumption 

4 forecasts were within ± 5 percent of the actual values (STPNOC 2009). ERCOT publishes its 

5 methodology, key input data, forecast errors, methodological uncertainties and limitations, and 

6 conclusions. 

7 8.1.3.4 Responsive to Forecasting Uncertainty Test 

8 In preparing its load forecasts and reliability assessments, ERCOT takes account of forecasting 

9 uncertainty. It also takes into account of the fact that not all proposed new generating units will 

10 be built and that some existing generating units may be taken off line for various reasons. 

11 8.1.3.5 Summary of ERCOT Analytical Process 

12 Based on its review of ERCOT documents, the review team determined that, in aggregate, the 

13 ERCOT forecasts and documents are sufficiently (1) systematic, (2) comprehensive, (3) subject 

14 to confirmation, and (4) responsive to forecasting uncertainty to serve the needs of the review 

15 team in complying with Section 102 of the National Environmental Policy Act. In keeping with 

16 the ESRP (NRC 2000) and the Commission statements at 68 FR 55910, the review team gave 

17 particular credence to: 

18  ERCOT’s 2009 long-term demand forecast (ERCOT 2009a), 

19  ERCOT’s 2009 CDR (ERCOT 2009b), 

20  ERCOT’s examination of long-term generation issues associated with wind energy in the 

21 2008 Long-Term System Assessment (ERCOT 2008f), and 

22  NERC’s evaluation of long term system adequacy (NERC 2008b). 

23 8.2 Power Demand 

24 The review team initially relied on the 2007 ERCOT Long-Term Peak Demand and Energy 

25 Forecast as its basis for understanding the need for power (ERCOT 2007). Since then, review 

26 team also has reviewed the 2008 and 2009 long-term demand studies (ERCOT 2008e, 2009a), 

27 ERCOT’s 2008 Long Term System Assessment Study (ERCOT 2008f), ERCOT’s latest CDR 

28 (ERCOT 2009b), and the summary of ERCOT findings from the 2008 studies in NERC’s 2008 

29 Long-Term Reliability Assessment as bases for comparison with the STPNOC’s need for power 

30 assessment (NERC 2008b). ERCOT’s demand forecasting model is described in detail in the 

31 2009 demand forecast report and is summarized below (ERCOT 2009a). 
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Draft NUREG-1937 8-8 March 2010 

1 The ERCOT long-term load forecast covers a period from 1 to 15 years using a process and 

2 tools developed internally by ERCOT. The forecast is used for a variety of operating and 

3 planning purposes, the most important of which for the EIS is system planning. The forecasting 

4 model is a set of equations that describes the historical load as a function of independent 

5 variables, where the coefficients are estimated by multiple regression methods. The long-term 

6 forecast was produced with a set of econometric models that use weather and economic and 

7 demographic data to capture and project the long-term trends from the past 5 years of historical 

8 data. Twelve years of weather data were available from 20 ERCOT weather stations. These 

9 weather stations were used to develop weighted hourly weather profiles for each of eight 

10 weather zones in the ERCOT region. These data were used in the load shape models. Monthly 

11 cooling degree days and heating degree days were used in the monthly energy models. 

12 Uncertainty in weather effects (especially that of extreme weather) on load was investigated in a 

13 number of ways, including the running of Monte Carlo simulations, to assess the impact of 

14 extreme temperatures on the peak demands. Economic and demographic changes can affect 

15 the characteristics of electrical demand in the medium- to the long-run. Economic and 

16 demographic data at the county level were obtained on a monthly basis from Moody’s 

17 Economy.com. Three of the key economic and demographic variables that drive the forecast 

18 are per capita income, population, and employment. The growth rates in these variables have 

19 declined during the last three forecasts, but still show largely the same picture for need for 

20 power over the next 10 to 15 years. 

21 Because the proposed Units 3 and 4 at the STP site would be baseload merchant power plants 

22 that are expected to operate more than 90 percent of the time to obtain best cost-effectiveness, 

23 the most important part of the ERCOT forecast for purposes of the this review is the growth in 

24 annual energy demand and the growth in demand at the near-minimum demand hours, since 

25 Units 3 and 4 would address this lowest part of the annual load duration curve. ERCOT, on the 

26 other hand, needs to emphasize peak load demand because of its institutional responsibility for 

27 meeting peak demand and reserve margin. During the period from 1997 to 2007 the compound 

28 growth rates for peak demand and annual energy were 2.3 percent per year and 1.5 percent per 

29 year, respectively (ERCOT 2009a). Assuming normal weather, ERCOT projects that peak 

30 energy demand would increase at a compounded rate of 2.0 percent per year (13,923 MW total) 

31 between 2009 and 2019 and that annual energy (average demand) would grow at a 

32 compounded growth rate of 2.04 percent per year (7965 average MW total) (ERCOT 2009a). 

33 Figure 8-2 shows the ERCOT 2009 peak and annual average load forecasts for the period 

34 2009-2019. 

35 Figure 8-3 shows the 8760-hour load duration curve for the ERCOT region for 2007, the last full 

36 year for which data were available. Ninety percent of the hours in the year equals 7884, 

37 corresponding to a demand of about 26,000 MW. This is approximately the portion of demand 

38 that is addressed by existing nuclear power plants at STP and Comanche Peak (as well as 

39 some hydroelectric, coal, and natural gas combined cycle baseload). If minimum annual hourly 
Need For Power 

March 2010 8-9 Draft NUREG-1937 

1 

2 Figure 8-2. Peak Demand and Average Demand in the ERCOT Region 2009-2019 (ERCOT 

3 2009a) (Note: figures are projected totals, not annual growth.) 

4 demand (equal to 21,817 MW in 2007) and 90th percentile hourly demand both grew at 

5 approximately the rate of annual average hourly demand in the ERCOT region shown in 

6 Figure 8-3, they both would grow by about 27.4 percent by 2019, or by amounts of 5978 MW 

7 and 7124 MW, respectively. These increases exceed the increase of high-availability baseload 

8 capacity represented by proposed Units 3 and 4 at STP. This simple calculation provides an 

9 initial indication that the growth in baseload demand in the ERCOT region would be enough to 

10 support additions of two units at both STP and Comanche Peak. 

11 In the 2008 annual NERC report (NERC 2008b) ”2008 Long-Term Reliability Assessment 2008-

12 2017, October 2008,” it is noted that forecasts of the demand for power declined between the 

13 2007 and 2008 forecasts (after having risen between 2006 and 2007). The decline continued 

14 from 2008 to 2009. Figure 8-4 shows the last four summer peak load forecasts compiled by 

15 ERCOT. Figure 8-5 shows the difference between annual energy forecasts in 2008 and 2009. 

16 The actual 2008 values are below the forecast largely because the peak forecast assumes 

17 normal summer weather, and weather was relatively cool on the peak day in 2007. 

18 The NERC report for ERCOT (NERC 2008b) states that the lower 2008 forecast takes into 

19 account the slowing of the Texas economy: 
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Draft NUREG-1937 8-10 March 2010 

1  The lower peak demands reflect the expected state of the economy as represented by 

2 economic indicators that have been found to drive electricity use in the ERCOT region’s 

3 eight weather zones, including real per-capita personal income, population, gross 

4 domestic product, and various employment measures including non-farm employment 

5 and total employment. 

6  In the long-term, real personal per-capita income is expected to level-off or decline in a 

7 slight to medium fashion due to wage rates experiencing modest growth, only slightly 

8 faster than inflation, due to lower productivity growth. Texas non-farm employment 

9 continues to grow faster than the U.S. rate. The gross domestic product also shows a 

10 lower level and growth rate from 2008 to 2018 when compared to last year’s forecast. 

11  Given the net effects of the economic indicators used in the 2008 Long Term Demand 

12 Forecast, they indicate slowdown of the economy in the long run. The long-run impact 

13 on the forecast due to economic slowdown is projected to start around 2010. Its effects 

14 are projected to translate into a 4.50 percent decline in energy and a 3.31 percent 

15 decline in peak demand by 2018, when compared to last year’s forecast [Note: “last 

16 year” refers to the 2007 forecast]. 

17 

0

10000

20000

30000

40000

50000

60000

70000

1 296 591 886 1181 1476 1771 2066 2361 2656 2951 3246 3541 3836 4131 4426 4721 5016 5311 5606 5901 6196 6491 6786 7081 7376 7671 7966 8261 8556

MW

18 Hours

19 Figure 8-3. ERCOT 2007 Load Duration Curve. (Compiled by review team from ERCOT 

20 2008h)
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March 2010 8-11 Draft NUREG-1937 

60,037 60,210 

62,339 

63,794 

65,135 

66,508 

67,955 

69,456 

70,733 

72,394 

73,998 

75,596 

77,024 

78,694 

80,161 

58,506 

62,188 62,179 

56,086 

63,491 

64,056 

65,494 

67,395 

69,399 

70,837 

72,172 

73,369 

74,871 

76,134 

77,414 

50,000 

55,000 

60,000 

65,000 

70,000 

75,000 

80,000 

85,000 

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

MW

Years

2006 Forecast

2007 Forecast

2008 Forecast

2008 Actual

2009 Forecast

1 

2 Figure 8-4. ERCOT 2006, 2007, 2008, and 2009 Peak Load Forecasts. (Compiled from 2007, 

3 2008, and 2009 ERCOT Long-Term Demand Forecast reports data by review team 

4 from ERCOT 2007; ERCOT 2008e; and ERCOT 2009a) 

5 

281 285 289 299 306 308 312

312 315 322 333 342 349 356 363 370 376 382

319 326 333 339 345 350 356 363 369 375 380

314

0

50

100

150

200

250

300

350

400

450

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Year

TWh

Historical 2009 Forecast 2008 Forecast 6 

7 Figure 8-5. ERCOT 2008 and 2009 Energy Demand Forecasts (ERCOT 2009a)

8 

9 
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Draft NUREG-1937 8-12 March 2010 

1 The review team notes that the ERCOT 2009 forecast features still further reduced economic 

2 growth in the short term as a result of the 2008-2009 economic downturn. However, some of 

3 the decline in underlying long-term economic conditions discussed by NERC between 2007 and 

4 2008 took a more optimistic turn in the ERCOT 2009 forecast. Figure 8-6 through Figure 8-8 

5 show the change in key long-term growth variables used as the primary economic drivers for the 

6 2009 ERCOT forecasts: population, employment, and per-capita income. ERCOT determined 

7 population growth rate would be relatively unchanged due to the economic downturn following 

8 an initial drop in numbers, but that employment and per-capita income would suffer an initial 

9 slump, followed by a faster growth rate than expected in 2008 and which would overtake the 

10 2008 forecasted values by about 2013. 

11 

12 Figure 8-6. Population in the ERCOT Region (ERCOT 2009a)
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March 2010 8-13 Draft NUREG-1937 

1 

2 Figure 8-7. Total Non-Farm Employment in the ERCOT Region (ERCOT 2009a)

3 

4 Figure 8-8. Per Capita Income in the ERCOT Region (ERCOT 2009a)
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Draft NUREG-1937 8-14 March 2010 

1 Because it is involved in meeting the maximum demand conditions in its territory, ERCOT pays 

2 considerable attention to the summer peak demand and the margin of safety in meeting that 

3 peak. The current generation reserve margin requirement for the ERCOT region is 12.5 

4 percent, as approved by the ERCOT Board in August 2002. The following is a brief summary of 

5 the methodology for the reserve margin calculation (ERCOT 2005a). The terms used here are 

6 defined below. 

7 Firm Load equals: 

8  long-term forecast model total summer peak demand 

9  minus loads acting as resources serving as responsive reserve 

10  minus loads acting as resources serving as non-spinning reserve 

11  minus balancing up loads. 

12 Available Resources equals: 

13  installed capacity using the summer net dependable capability pursuant to ERCOT testing 

14 requirements (excluding wind generation) 

15  plus capacity from private networks 

16  plus effective load carrying capability of wind (determined in a study for ERCOT in 2006 by 

17 Global Energy to be 8.7 percent of name plate generation (GED 2007) 

18  plus reliability must run units under contract 

19  plus 50 percent of non-synchronous ties 

20  plus summer net dependable capability of available switchable capacity as reported by the 

21 owners 

22  plus available “mothballed” generation 

23  plus planned generation with a signed generation interconnection agreement (SGIA) and a 

24 Texas Commission on Environmental Quality air permit, if required 

25  plus effective load carrying capability of planned wind generation with SGIA 

26  minus retiring units. 

27 Reserve margin is then defined as (Available Resources - Firm Load Forecast/Firm Load 

28 Forecast). 

29 
Need For Power 

March 2010 8-15 Draft NUREG-1937 

1 In the ERCOT methodology, loads acting as resources are capable of reducing or increasing 

2 the need for electrical energy or providing ancillary services such as responsive reserve service 

3 or non-spinning reserve service. Loads acting as resources must be registered and qualified by 

4 ERCOT, and they will be scheduled by a qualified scheduling entity (STPNOC 2009). 

5 STPNOC discussed the need for power in the context of declining reserve margins in the 

6 ERCOT region (STPNOC 2009). As recently as May 2008, forecasted reserve margin in the 

7 ERCOT Demand and Reserves report was expected to fall below the required reserve margin of 

8 12.5 percent by 2013. However, the May 2009 update to this report now shows a better 

9 capability to meet firm load at least through 2014 (see Table 8-1). ERCOT produces a “top10 down” forecast for its major subareas, but does not include separate demand estimates for 

11 different end-use sectors. Thus, forecasts do not contain separate forecasts for residential, 

12 commercial, and industrial demand. 

13 As shown in Table 8-1, the ERCOT 2009 forecasts take into account DSM programs and 

14 efficiency programs. As stated in the 2008 Texas State Energy Plan, DSM can be divided into 

15 (1) demand-response programs, which are designed to encourage customers to reduce usage 

16 during peak times or to shift that usage to other times; and (2) energy efficiency programs, 

17 which provide a reduction in the overall quantity of electricity consumed over the year, but may 

18 not necessarily reduce the electricity demanded at the hour of system peak (Governor’s 

19 Competitiveness Council 2008). Under Texas House Bill 3693 (signed into law in 2007), 

20 regulated utilities (transmission and distribution utilities [TDUs]) in ERCOT, and the integrated 

21 utilities outside of ERCOT, are required by law to offer DSM programs sufficient to offset 15 

22 percent of the growth in demand by December 31, 2008, and 20 percent of the growth in 

23 demand by December 31, 2009 (Governor’s Competitiveness Council 2008). Although only 

24 regulated utilities are affected inside of ERCOT, success of such programs could affect the 

25 overall demand for electricity in the ERCOT region. 

26 Table 8-2 is a less-detailed extension of Table 8-1 to the year 2024 that shows the ERCOT 

27 2009 forecast of demand, reserve margin (ERCOT calculates long-term required resources to 

28 meet peak demand plus 12.5 percent). Total resources estimates and the need for baseload 

29 power are calculated in Section 8.3. The total resources estimate does not include STP Units 3 

30 and 4 or other units projected for completion after 2014.
March 2010 8-16 Draft NUREG-1937 

1 Table 8-1. ERCOT Peak Demand and Calculated Reserve Margin, 2009-2014

 2009 2010 2011 2012 2013 2014 

Total Summer Peak Demand (MW) 63,491 64,056 65,494 67,394 69,399 70,837 

Less: LAARS Serving as Response 

Reserve and Spinning Reserve, 

Balancing–Up Loads 

1115 1115 1115 1115 1115 1115 

Less Energy Efficiency Program 

(per HB36693) 

110 242 242 242 242 242 

Firm Load Forecast (MW) 62,266 62,699 64,137 66,037 68,042 69,480 

Required Reserve Margin (12.5%) 7783 7837 8017 8255 8505 8685 

Required Resources 70,049 70,536 72,154 74,292 76,547 78,165 

Estimated Total Resources (MW) 

(Table 8-3) 

72,712 75,314 76,215 77,287 79,122 79,123 

Reserve Margin (Resources - Firm 

Load Forecast)/Firm Load Forecast) 

16.8% 20.1% 18.8% 17.0% 16.3% 13.9% 

Source: ERCOT 2009b 

2 

3 Table 8-2. ERCOT Calculated Reserve Margin, 2009-2024

 2009 2010 2014 2019 2024 

Peak Summer Demand, MW 63,491 64,056 70,837 77,414 82,778 

Less: LAAR Spinning and Non Spinning 

reserve and Balancing-up Loads 

1115 1357 1357 1357 1357 

Firm Load, MW 62,266 62,699 69,480 76,057 81,421 

Plus Reserve Requirements (Peak +12.5%) 7936 8007 8855 9677 10,347 

Total Resource Requirements, MW 71,427 72,063 76,692 87,091 93,125 

Total Resources, No Retirements 72,712 75,314 79,122 79,123 79,123 

Reserve Margin Based on Firm Load 16.8% 20.1% 13.9% 4.0% -2.8% 

Source: Calculated by the review team from tables and figures in ERCOT 2009b. 

4 8.3 Power Supply 

5 ERCOT prepares an annual CDR (ERCOT 2009b) on the supply capacity, demand, and 

6 reserves in the ERCOT region. It is developed from data provided by the market participants as 

7 part of the annual load data request, the generation asset registrations, and from data collected 

8 for the annual U.S. Department of Energy Coordinated Bulk Power Supply Program Report. 
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March 2010 8-17 Draft NUREG-1937 

1 The working paper calculates the generation resources reported to be available by market 

2 participants (STPNOC 2009). 

3 The CDR considers all of the generation resources in the ERCOT region meeting the list in the 

4 previous section. There are several constraints on which resources are listed as available in the 

5 CDR. 

6  Only those new generating resources for which the owners have initiated full transmission 

7 interconnection study requests through ERCOT are included as planned generation. 

8  If an air permit is required for a new generating unit, the unit must have received that permit 

9 before it is included as planned generation. 

10  Some mothballed resources may be counted, but the probability of these resources being 

11 able to be returned to service varies by generating technology and declines as the length of 

12 time they are mothballed increases (ERCOT 2005b). 

13  Retiring and retired units are not counted. 

14 Wind Energy in Texas

15 Large amounts of wind energy have or are about to enter the ERCOT region. In the Interim 

16 Order on Reconsideration in Docket 33672 (Interim Order), the PUCT designated five zones as 

17 Competitive Renewable Energy Zones (CREZ), primarily for wind power, in the western and 

18 Panhandle areas of Texas. By Texas law this amount of power would have to be accepted by 

19 the market, if offered to the market, in preference to thermal generation. Installed wind capacity 

20 could grow from around 6900 MW to as much as 24,400 MW over the next few years, with a 

21 planning value of 18,456 MW in 2018. In response, ERCOT performed a CREZ Transmission 

22 Optimization Study (ERCOT 2008j), an extensive study of intrastate transmission bottlenecks 

23 that might arise and solutions that might be needed to absorb this new power source. 

24 The wind generation development scenarios used in the CREZ Transmission Optimization 

25 Study were also used to evaluate resource needs in the ERCOT system in the December, 2008 

26 Long-Term System Assessment (ERCOT 2008f). The Long-Term System Assessment 

27 evaluated the need for other types of generation capacity under the assumption that the 

28 projected 2018 load duration curve would be lowered by the maximum possible use of 

18,456 MW of wind energy. Figure 8-9 shows that at approximately the 80th 29 percentile (a rule30 of-thumb definition of baseload generation) there would still be a demand for up to 30,852 MW 

31 of baseload with 18,456 MW of wind generation installed in the system if natural gas prices 

32 remained at about $7 per million Btu. However, there would be little need for additional 

33 baseload generation beyond current levels (nuclear could still substitute for retiring coal and 

34 natural gas, if needed). 
Need For Power 

Draft NUREG-1937 8-18 March 2010 

1 Current U.S. Energy Information Administration forecasts of natural gas prices favor a natural 

2 gas price to the electricity sector of about $7 per million Btu through much of the next 20 years, 

3 as many new resources come on line, even as economic recovery increases demand (EIA 

2009). This indicates that the demand in 2018 for baseload capacity (80th 4 percentile of the wind5 altered load duration curve) would be close to the 30,852 MW forecast in Figure 8-9. The 

demand for baseload at the 90th 6 percentile of the wind-altered load duration curve would be 

7 about 28,000 MW, an increase of about 2000 MW from current levels. That would not be 

8 enough on its own to fully absorb STP Units 3 and 4, but substitution for retiring coal or natural 

9 gas-fired plants would still be possible. 

10 ERCOT’s 2009 Supply Forecast 

11 Table 8-3 provides ERCOT’s May 2009 projection of the generating resources of various types 

12 that that would be available to serve the ERCOT region between 2009 and 2024. The 2009-

13 2014 ERCOT projections anticipate substantial development of wind resources during the 2009-

14 2014 period, and the review team adopted the view that these resources would be developed 

15 and would meet the State’s goal of 18,564 MW of installed wind capacity by 2018. If the State 

16 falls short of its goal for wind, the demand for STP Units 3 and 4 would be larger than calculated 

17 in this section. 

18 There is uncertainty as to the timing, type, number, and capacity of generating units that may be 

19 retired during the forecast period, which affects the need for replacement generating plants. 

20 The age of the power plant being considered for retirement is a factor in the decision to retire 

21 the plant. Based on ERCOT’s May 2009 CDR, Figure 8-10 shows how the summer capacity of 

22 generating resources may be affected by the need of some participants to retire older, less 

23 efficient, or polluting power plants. Under any retirement scenario, the replacement of such 

24 power plants in the ERCOT region further adds to the need for new generating capacity. 

25 The ERCOT forecast of generating resources shown in Table 8-3 begins with installed capacity 

26 of existing generating stations. To that is added generating capacity of private networks 

27 (connected to the ERCOT grid, but not directly metered by ERCOT), the effective load carrying 

28 capability of existing wind generators (at 8.7 percent of installed capacity), and reliability must29 run (RMR) units that are required for local grid stability. The remaining group of resources 

30 includes (1) 50 percent of so-called “switchable” resources that could either operate in ERCOT 

31 or in the Southwest Power Pool; (2) a protected estimate of mothballed resources that could be 

32 brought back on line in each year (the actual estimate is an expected value based on detailed 

33 computations that involve the age of the unit and the length of time it has been shut down), and 

34 (3) planned resources, whose inclusion depends on the phase that each resource is in the 

35 required interconnection studies (STPNOC 2009). This resulting estimate is then adjusted 

36 downward to account for switchable units known to be unavailable to ERCOT and retiring units. 

37 However, because there is also considerable uncertainty concerning whether existing power 
Need For Power 

March 2010 8-19 Draft NUREG-1937 

1 plants would be retired, the review team calculated available resources both with and without 

2 retirements, as shown in Table 8-3. 

3 

4 Figure 8-9. ERCOT Net Load Duration Curve in 2018 with 18,456 MW of Wind Generation 

5 Capacity (ERCOT 2008f) 

6 
Need For Power 

Draft NUREG-1937 8-20 March 2010 Table 8-3. 2009 ERCOT Forecasted Summer Resources, 2009-2024 1 2009 2010 2011 2012 2013 2014 2019 2024 Installed Capacity, MW 63,492 61,800 61,800 61,800 61,800 61,800 61,800 61,800 Capacity from Private Networks, MW 5313 5318 5318 5318 5318 5318 5318 5318 Effective Load-Carrying Capability (ELCC) of Wind Generation, MW 708 708 708 708 708 708 708 708 RMR Units to be under Contract, MW 115 0 0 0 0 0 0 0 Operational Generation, MW 69,628 67,826 67,826 67,826 67,826 67,826 67,826 67,826 50% of Non-Synchronous Ties, MW 553 553 553 553 553 553 553 553 Switchable Units, MW 2848 2848 2848 2848 2848 2848 2848 2848 Available Mothballed Generation , MW 0 401 479 479 479 479 479 479 Planned Units (not wind) with Signed IA and Air Permit, MW 0 3,769 4389 5414 7206 7206 7206 7206 ELCC of Planned Wind Units with Signed IA, MW 0 76 121 168 211 211 1606 1606 Total Resources, MW 73,029 75,472 76,215 77,287 79,122 79,123 80,518 80,518 less Switchable Units Unavailable to ERCOT, MW 317 158 0 0 0 0 0 0 less Retiring Units, MW (None through 2014, Based on >50 yrs after 2014 0 0 0 0 0 0 0 Retirements in Based of age >50 yrs after 2014 0 0 0 0 0 0 9289 25,274 Resources, MW (no retirements) 72,712 75,314 76,215 77,287 79,122 79,123 80,518 80,518 Reserve Margin Above Firm Load, No retirements 16.8% 20.1% 18.8% 17..0% 16.3% 13.9% 5.86% -1.11% Resources, MW (with retirements) 72,712 75,314 76,215 77,287 79,122 79,122 71,229 55,244 Reserve Margin Above Firm Load, With retirements 16.8% 20.1% 18.8% 17.0% 16.3% 13.9% -6.4% -32.2% Source: ERCOT 2009b and review team calculations based on the expanded wind resource availability of 18,564 installed MW by 2018, and the >50-year old generation retirement scenarios in Figure 8-10. 
Need For Power 

March 2010 8-21 Draft NUREG-1937 

87,091

93,125

100,349

77,414

82,778

89,199

44,491

40,386

28,017

79,692

70,837

44,491

53,849

63,854 68,404

32,053

54,652

26,408

32,053

41,189

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

110,000

120,000

2014 2019 2024 2029

Year

M

W

Total Requirements +12.5% Reserve Margin

Peak Demand

Capacity less units 30 years old or older 

Capacity less units 40 years old or older 

Capacity less units 50 years old or older 

1 

2 Figure 8-10. Alternative ERCOT Generation Capacity Reduction Scenarios vs. Projected 

3 Demand (ERCOT 2009b) 

4 In Table 8-3, the ERCOT forecast shows that by 2014, the amount of summer resources would 

5 be about 79,100 MW and 80,500 MW by 2019. Reserve requirements would be met in 2014, 

6 but not by 2019. The reserve margin would fall from 13.9 percent in 2014 to 5.9 percent in 2019. 

7 With retirements of older power plants after 2014, the demand and supply would be further out 

8 of balance, because the resources needed just to meet firm load would be 76,100 MW. The 

9 resources available, accounting for wind generation and retirements, would be only 71,200 MW 

10 if only power plants older than 50 years old were retired ─ an absolute shortage of 5000 MW 

11 and a shortage of 15,900 MW relative to the amount needed to cover the reserve margin. The 

12 reserve margin would be below zero. If retirements of power plants increase, the prospective 

13 shortage of generation in the 2014-2019 period would grow still larger 

14 STPNOC concluded in its ER (STPNOC 2009), based on the ERCOT 2007 forecasts and 

15 before the 2008-2009 economic recession, which the generation shortage in 2016 could be 

16 between 20,000 and 50,000 MW. The shortage in Table 8-3 is 15,900 MW, still substantial. 
Need For Power 

Draft NUREG-1937 8-22 March 2010 

1 In the ERCOT region, STPNOC estimated about 24.5 percent of current generating capacity is 

2 currently considered to be baseload and that this percentage would rise to 30.1 percent by 2012 

3 (STPNOC 2009) In its ER, STPNOC estimated the combined capacity of baseload generation 

4 that addresses ERCOT through the year 2012 based on the ERCOT criteria (Table 8-4). The 

5 percentage of baseload may be increasing (STPNOC 2009). STP Units 1 and 2 and Comanche 

6 Peak Units 1 and 2 would represent 4892 MW of the 22,178 MW of total summer baseload 

7 generating capacity needed in the ERCOT region in 2012 (STPNOC 2009). The growth in need 

8 for baseload generation in Table 8-4 from 2007 to 2012 is 4557 MW, of which only 2100 MW of 

9 new coal and gas had been added to the ERCOT forecast. In the longer term, plant retirements 

10 and further increases in demand for power allowed STPNOC (STPNOC 2009) to conclude that: 

11 Thus, the need for new capacity in ERCOT in 2015-2016 is substantially greater than the 

12 new capacity to be provided by STP 3 & 4. As a result, not only will there be a need for 

13 power from STP 3 & 4, there will be a need for a substantial amount of other new 

14 generating capacity. 

15 Table 8-4. STPNOC Forecasted Summer Capacity, Baseload Generation Units Only 

 2007 2008 2009 2010 2011 2012 

Resources, MW 71,812 72,048 71,960 72,394 72,939 73,703 

Baseload Generation, MW 17,621 17,621 19,057 19,998 21,378 22,178 

Percent of Resources that 

are Baseload Generation 

24.50% 24.50% 26.50% 27.60% 29.30% 30.10% 

Source: STPNOC 2009 

16 Table 8-5 shows an estimate made by the review team of the need for baseload power in 2009-

17 2024 with and without retirement of older power plants. For purposes of this estimate it was 

18 assumed that baseload power would represent about 27.5 percent of the identified generating 

19 needs in Table 8-3. This percentage is midway between today’s 24.5 percent and the 

20 30.1 percent calculated by STONOC for the year 2102. Without any retirements, Table 8-5 

21 shows that the demand for new baseload is about 1808 MW, a reflection of much higher 

22 planned non-wind resources and wind power penetration into the Texas market than assumed 

23 in 2007, combined with lower load growth than assumed by STPNOC in their forecast. With 

24 only plants greater than 50 yr old retiring, the demand for new baseload plants not currently in 

25 the ERCOT forecast grows to 4362 MW, more than enough for two new nuclear units. 
Need For Power 

March 2010 8-23 Draft NUREG-1937 

1 Table 8-5. ERCOT/Review Team Forecasted Summer Capacity, Baseload Generation Units 

Only(a) 2 

2009 2010 2014 2019 2024 

Power Requirements, 

Including 12.5% 

Reserves (MW) 

71,427 72,063 79,692 87,091 93,125

Current ERCOT Planned New Generation: No Retirements (MW) 

Generating Resources 73,029 75,472 79,123 80,518 80,518

Baseload Needed 

(27.5%) 19,643 19,817 21,915 23,950 25,609 

Baseload Needed 

After 2009 (353) (894) 156 1808 3467 

Current ERCOT Planned New Generation: Retire Only Plants >50 Yr Old (MW) 

Generating Resources 73,029 75,472 79,123 71,229 55,244

Baseload Needed 

(27.5%) 19,643 19,817 21,915 23,950 25,609 

Baseload Needed 

After 2009 (353) (894) 156 4362 10,417 

(a) Excludes proposed STP Units 3 and 4 

3 8.4 Assessment of Need for Power 

4 The review team reviewed reports prepared by ERCOT regional ISO in conjunction with its 

5 assessment of the need for power from STPNOC’s proposed Units 3 and 4 at the STP site. 

6 STPNOC relied on the 2007 versions of these reports, which show a slightly higher need for 

7 power than the 2008 and 2009 reports; however, all versions provide essentially the same 

8 picture. The review team’s key findings from the reports are summarized as follows: 

9  The demand for power at the summer peak and the annual demand for energy in the 

10 ERCOT region are both projected to rise over the period 2009 through 2019 at 

11 approximately 2.0 percent per year compounded. Total demand would be 77,400 MW at 

12 peak in 2019, and including a 12.5 percent reserve requirement, resources would need to 

be about 87,100 MW in that year. If minimum-hour demand and 90th 13 percentile hourly 

14 demand also increases at the 2.0 percent rate, by 2019 the ERCOT region would need an 

15 additional 6000 MW to 7100 MW of baseload generation due to load growth alone. This 

16 estimate, however, does not account for other supply plans. 

17  As noted in Section 8.3, retiring generating units were not counted in the 2009 forecast of 

18 ERCOT region available resources (they are shown as zero in forecasted resources). Thus, 

19 depending on the rate of retirement of older generating units, the ERCOT region may need 

20 substantial additional generating capacity by 2019. The analysis in Table 8-3 shows that if 

21 only the oldest (greater than 50 years old) are retired after 2014, amount of additional 
Need For Power 

Draft NUREG-1937 8-24 March 2010 

1 demand for new generation would be about 9300 MW relative to a case with no retirements. 

2 About 25 to 30 percent of that growth likely would be baseload generation. 

3  The 2009 ERCOT resource forecast contains 8137 MW of current installed capacity in 2009 

4 (with 708 MW of average Effective Load Carrying Capability) plus 2425 MW of planned 

5 installed capacity (average Effective Load Carrying Capability of 211 MW). However, larger 

6 amounts of additional wind generation capacity may be built in the CREZ areas of Texas, 

7 ranging up to 24,000 MW installed (average Effective Load Carrying Capability of 2088 

8 MW). Large amounts of wind generation would require major investments in transmission 

9 resources and improved system controls to manage wind resources, but they could reduce 

10 the demand for power during the off-peak portions of the year and may limit the demand for 

11 additional intermediate and baseload thermal generating resources. More modest market 

12 penetration of wind energy leaves a market for increased baseload generation. The 

13 discussion of the CREZ study in Section 8.3 favors a lower wind penetration rate with up to 

14 18,546 MW installed capacity, given very aggressive wind development, which still leaves 

15 room for 10,000 MW of growth in baseload demand by 2018, and 2000 MW of demand 

growth at the 90th 16 percentile. Because there is uncertainty in the success of very aggressive 

17 wind generation and because nuclear plants can substitute for other potential baseload 

18 generation, the review team believes there is a need for the amount of electrical generation 

19 represented by STP Units 3 and 4. 

20 The State of Texas has funded an ambitious DSM program that is designed to reduce electricity 

21 demand by 15 to 20 percent in the service areas of regulated utilities within ERCOT and 

22 integrated Texas utilities outside of ERCOT (Governor’s Competitiveness Council 2008). This 

23 program is included in the ERCOT forecasts and is part of the 2009 calculation of need for new 

24 generating resources. 

25 If the Texas DSM program were completely successful, a 15 to 20 percent reduction in load 

26 growth in the regulated portion of the ERCOT region would reduce the need for power, but not 

27 eliminate it. 

28 Table 8-6 summarizes the results of the review team’s analysis of the ERCOT electricity 

29 demand and supply forecasts that have occurred since STPNOC used the ERCOT 2007 

30 forecasts to estimate unmet need for power from STP Units 3 and 4. The staff reviewed the 

31 ERCOT 2008 and 2009 demand forecasts, noted the changes since 2007, and decided that 

32 while ERCOT’s short-term forecast of peak summer demand was heavily influenced by the 

33 2008 to 2009 recession, the longer-term estimate of demand is only slightly lower than in the 

34 2007 forecast. A more important issue is that the 2007 supply forecast did not include either the 

35 impact of Texas’s energy conservation plan or the full impact of an ambitious program to 

36 significantly expand the scope of wind power in Texas. The review team added these elements 

37 to the ERCOT 2009 long-term supply forecast. Finally, the review team examined directly the 
Need For Power 

March 2010 8-25 Draft NUREG-1937 

1 impact of power plant retirements, a factor not specifically included in ERCOT’s detailed 

2 forecasts. Based on information available in STPNOC’s need for power analysis, the review 

3 team translated the modified ERCOT 2009 demand and supply forecasts into an estimate of the 

4 unmet need for baseload power in ERCOT in the years 2014-2019, which spans the potential 

5 completion dates for proposed Units 3 and 4. 

6 Table 8-6. ERCOT/Review Team Forecasted Unmet Need for Baseload Generation 

7 Compared with STPNOC Estimated Need for Baseload Power 

Review 

Team/ERCOT 

2009 (2014 and 

2019), MW 

STPNOC/ERCOT 

2007 (2017) MW 

Difference (Review 

Team/STPNOC) 

(Smallest to 

Largest) 

Estimated Baseload Demand 21,900 to 24,000(a) 26,600(b) -4700 to -4500 

Estimated Baseload Supply 21,800 to 19,600(c) 9900 to 20,100(d) -500 to +11,900 

Unmet Net Need for Baseload 

Power 100 to 4400(e) 6500 to 16,700(f) -2100 to -16,600 

Proposed Capacity 2740 2740 0 

(a) Table 8-35, 2014 and 2019 power requirements times 27.5%. 

(b) STPNOC 2009, Figure 8.4-2, 2017 “Total Requirement:, times 30.1%. 

(c) Table 8-3, 2014 and 2019 resources with retirements, times 27.5%. 

(d) STPNOC 2009, Figure 8.4-2, 2017 “Capacity less units 50 years old or older,” “Capacity less units 30 

years old or older,” times 30.1%.. 

(e) Difference between demand and supply. 

(f) Difference between demand and supply. 

8 Table 8-6 shows that although the demand for baseload power in 2016-2017 has not changed 

9 much since the 2007 analysis, the combination of conservation and wind power may have 

10 significantly reduced the need for baseload power. However, even though the potential unmet 

11 need for power in the review team’s alternative estimate is much smaller than STPNOC’s 

12 estimate, it still shows an unmet need large enough to accommodate proposed Units 3 and 4. 

13 In addition, because Units 3 and 4 are merchant plants, they do not need to show an absolute 

14 shortage of power. The marketplace would decide whether Units 3 and 4 would be able to 

15 compete successfully with other potential suppliers of baseload electricity. 

16 8.4.1 Conclusion 

17 The review team concludes that there is an expected future shortage of baseload power in the 

18 ERCOT region that could be at least partially addressed by construction of proposed Units 3 

19 and 4 at the STP site. The review team determined that the STPNOC assessment of its need 

20 for power in its ER is not unreasonable. Building of the two new units could address (1) growth 

21 in demand for baseload power and (2) replacement of retiring baseload generating units 
Need For Power 

Draft NUREG-1937 8-26 March 2010 

1 elsewhere in ERCOT. Based on its analysis, the review team concludes that there is a justified 

2 need for new baseload generating capacity in the ERCOT region in excess of the planned 

3 2740 MW capacity output of proposed Units 3 and 4 at STP. 

4 8.5 References 

5 68 FR 55910. September 29, 2003. “Nuclear Energy Institute; Denial of Petition for 

6 Rulemaking.” Federal Register. U.S. Nuclear Regulatory Commission. 

7 Electric Reliability Council of Texas (ERCOT). 2005a. “Methodology for Reserve Margin 

8 Calculation,” Memorandum from Read Comstock, TAC chair to ERCOT Board of Directors, May 

9 10, 2005. 

10 Electric Reliability Council of Texas (ERCOT). 2005b. Reserve Margin Update - House 

11 Committee on Regulated Industries; PowerPoint Presentation. Electric Reliability Council of 

12 Texas. 

13 Electric Reliability Council of Texas (ERCOT). 2007. 2007 ERCOT Planning Long-Term Hourly 

14 Peak Demand and Energy Forecast, May 8, 2007. Accessed at 

15 http://www.ercot.com/news/presentations/2007/2007_ERCOT_Planning_Long_Term_Hourly_D

16 emand_Energy_Forecast_.pdf. Accession No. ML100600754. 

17 Electric Reliability Council of Texas (ERCOT). 2008a. ERCOT Company Profile. Accessed 

18 May 13, 2009 at http://www.ercot.com/about/profile/index.html. Accession No. ML100600754. 

19 Electric Reliability Council of Texas (ERCOT). 2008b. ERCOT Governance. Accessed May 

20 13, 2009 at http://www.ercot.com/about/governance/index.html. Accession No. ML100600754. 

21 Electric Reliability Council of Texas (ERCOT). 2008c. About ERCOT. Accessed May 13, 2009 

22 at http://www.ercot.com/about/index. Accession No. ML100600754. 

23 Electric Reliability Council of Texas (ERCOT). 2008d. History of ERCOT. Accessed May 13, 

24 2009 at http://www.ercot.com/about/profile/history. Accession No. ML100600754. 

25 Electric Reliability Council of Texas (ERCOT). 2008e. 2008 ERCOT Planning Long-Term 

26 Hourly Peak Demand and Energy Forecast. Accessed June 24, 2009 at 

27 http://www.ercot.com/content/news/presentations/2008/2008%20Planning%20Long28 Term%20Hourly%20Demand%20Energy%20Forecast%20Final.doc. Accession No. 

29 ML100600754. 

30 Electric Reliability Council of Texas (ERCOT). 2008f. ERCOT Long-Term System Assessment 

31 December 2008. Accessed June 24, 2009 at 
Need For Power 

March 2010 8-27 Draft NUREG-1937 

1 http://www.ercot.com/content/news/presentations/2008/ERCOT_Long2 Term_System_Assmt_Dec_2008.pdf. Accession No. ML100600754. 

3 Electric Reliability Council of Texas (ERCOT). 2008g. Texas Regional Entity. Accessed May 

4 14, 2009 at http://www.ercot.com/mktrules/compliance/tre/index. Accession No. ML100600754. 

5 Electric Reliability Council of Texas (ERCOT). 2008h. Hourly Load Data Archives. Accessed 

6 May 14, 2009 at http://www.ercot.com/gridinfo/load/load_hist/. Accession No. ML100600754. 

7 Electric Reliability Council of Texas (ERCOT). 2008i. ERCOT Capacity, Demand, Reserves 

8 Winter Update. Accessed June 24, 2009 at 

9 http://www.ercot.com/content/news/presentations/2009/ERCOT_CDR_update_12-15-

10 08_public.xls. Accession No. ML100600754. 

11 Electric Reliability Council of Texas (ERCOT). 2008j. Competitive Renewable Energy Zones 

12 (CREZ) Transmission Optimization Study, ERCOT System Planning, April 2, 2008. Available at 

13 http://www.ercot.com/news/presentations/2008/index. Accession No. ML100600754. 

14 Electric Reliability Council of Texas (ERCOT). 2008k. Report on the Capacity, Demand, and 

15 Reserves in the ERCOT Region, System Planning, May 2008. Available at 

16 http://www.ercot.com/content/news/presentations/2008/2008_Capacity,_Demand,_Reserves_R

17 eport_FINAL.xls. Accession No. ML100600754. 

18 Electric Reliability Council of Texas (ERCOT). 2008l. ERCOT Membership. Accessed May 14, 

19 2009 at http://www.ercot.com/about/governance/members/. Accession No. ML100600754. 

20 Electric Reliability Council of Texas (ERCOT). 2009a. 2009 ERCOT Planning Long-Term 

21 Hourly Peak Demand and Energy Forecast. Available at 

22 http://www.ercot.com/content/news/presentations/2009/2009_Planning_Long23 Term_Hourly_Demand_Energy_Forecast-av2009.pdf. Accession No. ML100600754. 

24 Electric Reliability Council of Texas (ERCOT). 2009b. Report on the Capacity, Demand, and 

25 Reserves in the ERCOT Region, System Planning. Available at 

26 http://www.ercot.com/content/news/presentations/2009/2009%20ERCOT%20Capacity,%20De

27 mand%20and%20Reserves%20Report.pdf. Accession No. ML100600754. 

28 Energy Information Administration (EIA). 2009. Annual Energy Outlook 2010, Early Release, 

29 Dec 14, 2009. Accessed at http://www.eia.doe.gov/oiaf/aeo/index.html on January 14, 2009. 

30 Accession No. ML100600754. 
Need For Power 

Draft NUREG-1937 8-28 March 2010 

1 Federal Energy Regulatory Commission (FERC). 1999. “89 FERC 61,285. United States of 

2 America Federal Energy Regulatory Commission 18 CFR Part 35 [Docket No. RM99-2-000; 

3 Order No. 2000], Regional Transmission Organizations (Issued December 20, 1999). 

4 Federal Energy Regulatory Commission (FERC). 2008. Regional Transmission Organizations 

5 (RTO)/Independent System Operators (ISO). Accessed May 14, 2009 at 

6 http://www.ferc.gov/industries/electric/indus-act/rto.asp. Accession No. ML100600754. 

7 Global Energy Decisions (GED). 2007. ERCOT Target Reserve Margin Analysis. Prepared for 

8 Electric Reliability Counsel of Texas (ERCOT). Date submitted January 18, 2007. Sacramento, 

9 California. 

10 Governor’s Competitiveness Council. 2008. 2008 Texas State Energy Plan. Governor’s 

11 Competitiveness Council, Austin, Texas. 

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

13 North American Electric Reliability Corporation (NERC). 2008a. North American Electric 

14 Reliability Corporation. Accessed May 14, 2009 at http://www.nerc.com/. Accession No. 

15 ML100600754. 

16 North American Electric Reliability Corporation (NERC) 2008b. 2008 Long-Term Reliability 

17 Assessment 2008-2017. Available at http://www.nerc.com/files/FinalFiled2008LTRA.pdf. 

18 Accession No. ML100600754. 

19 Pacific Northwest National Laboratory (PNNL). 2009. Letter from Dave Anderson (PNNL) to 

20 Paul Hendrickson and Mike Warwick dated April 22, 2009, “Re: ERCOT Meeting.” Accession 

21 No. ML100070666. 

22 South Texas Project Nuclear Operating Company (STPNOC). 2009. South Texas Project Units 

23 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay City, 

24 Texas. Accession No. ML092931600. 

25 Texas Utilities Code. 2009. Texas Statutes: Utilities Code. Accessed May 13, 2009 at 

26 http://tlo2.tlc.state.tx.us/statutes/ut.toc.htm. Accession No. ML100600754. 

27 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan— 

28 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

29 NRC, Washington, D.C. Includes 2007 updates. 
March 2010 9-1 Draft NUREG-1937 

1 9.0 Environmental Impacts of Alternatives 

2 This chapter describes alternatives to the proposed U.S. Nuclear Regulatory Commission 

3 (NRC) action for a combined license (COL) and the U.S. Army Corps of Engineers (Corps) 

4 action for an Individual Permit and discusses the environmental impacts of those alternatives. 

5 Section 9.1 discusses the no-action alternative. Section 9.2 addresses alternative energy 

6 sources. Section 9.3 reviews the STP Nuclear Operating Company’s (STPNOC’s) region of 

7 interest (ROI), its site selection process, and summarizes and compares the environmental 

8 impacts for the proposed and alternative sites. Section 9.4 examines plant design alternatives. 

9 Section 9.5 describes onsite alternatives. Section 9.6 lists the references cited in this chapter. 

10 The need to compare the proposed action with alternatives arises from the requirement in 

11 Section 102(2)(c)(iii) of the National Environmental Policy Act of 1969, as amended (NEPA) 

12 (42 USC 4321) that environmental impact statements (EISs) include an analysis of alternatives 

13 to the proposed action. The NRC implements this comparison through its regulations in Title 10 

14 of the Code of Federal Regulations (CFR) Part 51 and its Environmental Standard Review Plan 

15 (ESRP) (NRC 2000). The environmental impacts of the alternatives are evaluated using the 

16 NRC’s three-level standard of significance – SMALL, MODERATE, or LARGE – developed 

17 using Council on Environmental Quality (CEQ) guidelines (40 CFR 1508.27) and set forth in the 

18 footnotes to Table B-1 of 10 CFR 51, Subpart A, Appendix B. The issues evaluated in this 

19 chapter are the same as those addressed in the Generic Environmental Impact Statement for 

20 License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 

1999)(a) 21 with the additional issue of environmental justice. Although NUREG-1437 was 

22 developed for NRC’s review of renewal of nuclear power plant operating licenses, it provides 

23 useful information for this review and is referenced throughout this chapter. 

24 As part of the evaluation of permit applications subject to Section 404 of the Federal Water 

25 Pollution Control Act (Clean Water Act), the Corps is required by regulation to apply the criteria 

26 set forth in the 404(b)(1) guidelines (33 USC 1344; 40 CFR Part 230). These guidelines 

27 establish criteria that must be met for the proposed activities to be permitted pursuant to 

28 Section 404. 

29 Section 230.10(a) of the Guidelines (40 CFR 230.10(a)) requires that “no discharge of dredged 

30 or fill material shall be permitted if there is a practicable alternative to the proposed discharge 

31 which would have less adverse impact on the aquatic ecosystem, so long as the alternative 

32 does not have other significant adverse environmental consequences.” Section 230.10(a)(2) of 

33 the Guidelines states that “An alternative is practicable if it is available and capable of being 

 

(a) NUREG-1437 was originally issued in 1996. Addendum 1 to NUREG-1437 was issued in 1999 

(NRC 1999). Hereafter, all references to NUREG-1437 include NUREG-1437 and its Addendum 1. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-2 March 2010

1 done after taking into consideration cost, existing technology, and logistics in light of overall 

2 project purposes. If it is otherwise a practicable alternative, an area not presently owned by the 

3 applicant which could reasonably be obtained, used, expanded, or managed in order to fulfill the 

4 basic purpose of the proposed activity may be considered.” Thus, this analysis is necessary to 

5 determine which alternative is the Least Environmentally Damaging Practicable Alternative 

6 (LEDPA) that meets the project purpose and need. 

7 Where the activity associated with a discharge is proposed for a special aquatic site (as defined 

8 in 40 CFR Part 230, Subpart E), and does not require access or proximity to or siting within 

9 these types of areas to fulfill its basic project purpose (i.e., the project is not “water dependent”), 

10 practicable alternatives that avoid special aquatic sites are presumed to be available, unless 

11 clearly demonstrated otherwise (40 CFR 230.10(a)(3)). 

12 9.1 No-Action Alternative 

13 For purposes of an application for a COL, the no-action alternative refers to a scenario in which 

14 the NRC would deny the COL requested by STPNOC which would result in the proposed units 

15 not being built. Likewise, the Corps could also take no action or deny the Individual Permit 

16 request. Upon such a denial by the NRC, the construction and operation of two new nuclear 

17 units at the STP site in accordance with 10 CFR Part 52 would not occur and the predicted 

18 environmental impacts associated with the project would not occur. Preconstruction impacts 

19 associated with activities not within the definition of construction in 10 CFR 50.10(a) and 51.4 

20 may occur nonetheless. If no other power plants were to be built in lieu of the proposed project 

21 or other strategy implemented to take its place, the benefits of the additional electrical capacity 

22 and electricity generation to be provided by the project would not occur. If no additional 

23 measures (e.g., conservation, importing power, restarting retired power plants, and/or extending 

24 the life of existing power plants) were implemented to realize the amount of electrical capacity 

25 that would otherwise be required for power in STPNOC’s ROI (see Section 9.3.1), then the need 

26 for baseload power, discussed in Chapter 8, would not be met. Therefore, the purpose and 

27 need of this project would not be satisfied if the no-action alternative was chosen and the need 

28 for power was not met by other means. 

29 If other generation sources were installed, either at another site or using a different energy 

30 source, the environmental impacts associated with these other sources would eventually occur. 

31 As discussed in Chapter 8, there is a demonstrated need for power. It is reasonable to assume 

32 that other options to meet the need for power would be pursued. This needed power may be 

33 provided and supported through a number of alternatives that are discussed in Section 9.2 and 

34 Section 9.3. Therefore, this section does not include a discussion of other energy alternatives 

35 that could meet the need for power. 
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March 2010 9-3 Draft NUREG-1937 

1 STPNOC’s permit request to the Corps covers the dredging of the barge slip along the Colorado 

2 River and the placement of culverts across six onsite drainages. If the dredging request were 

3 denied, potential alternatives would be constructing a large crane system to offload materials 

4 barged up the Colorado River, use of railroad lines to transport materials to the site instead of 

5 barge transport, and use of truck transport instead of barge transport. Alternatives to the 

6 placement of culverts would be to use current onsite roadways or span the existing drainages 

7 (STPNOC 2009d). In the event the Corps denies the permit requests, STPNOC would need to 

8 decide if the proposed project could continue or if other alternatives should be pursued. 

9 9.2 Energy Alternatives 

10 The purpose and need for the proposed project identified in Section 1.3 is to provide additional 

11 baseload electrical generation capacity for use in the owner’s current markets within the Electric 

12 Reliability Council of Texas (ERCOT) region and/or for potential sale on the wholesale market. 

13 This section examines the potential environmental impacts associated with alternatives to 

14 construction of a new baseload nuclear generating facility. Section 9.2.1 discusses energy 

15 alternatives not requiring new generating capacity. Section 9.2.2 discusses energy alternatives 

16 requiring new generating capacity. Other alternatives are discussed in Section 9.2.3. A 

17 combination of alternatives is discussed in Section 9.2.4. Section 9.2.5 compares the 

18 environmental impacts from new nuclear, coal-fired and natural gas-fired generating units, and a 

19 combination of energy sources at the STP site. 

20 For analysis of energy alternatives, STPNOC assumed a bounding target value of 2700 MW(e) 

21 electrical output (STPNOC 2009a). The staff also used this level of output in analyzing energy 

22 alternatives. 

23 9.2.1 Alternatives Not Requiring New Generating Capacity 

24 Four alternatives to the proposed action that do not require STPNOC to construct new 

25 generating capacity are to: 

26 • purchase the needed electric power from other suppliers 

27 • extend the operating life of existing power plants 

28 • reactivate retired power plants 

29 • implement conservation or demand-side management programs. 

30 Texas produces and consumes more electricity than any other state. Despite large net 

31 interstate electricity imports in some areas, the Texas interconnect power grid is largely isolated 

32 from the integrated power systems serving the eastern and western United States. In addition, 

33 most areas of Texas have little ability to export or import electricity to and from other states 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-4 March 2010

1 (DOE/EIA 2009a). If power to replace the capacity of the proposed new nuclear units was to be 

2 purchased from sources within the United States or from a foreign country, the generating 

3 technology likely would be one of those described in NUREG-1437 (e.g., coal, natural gas, or 

4 nuclear) (NRC 1996). The description of the environmental impacts of other technologies 

5 described in the GEIS for license renewal is representative of the impacts associated with the 

6 construction and operation of new generating units at the STP site. The environmental impacts 

7 of coal-fired and natural gas-fired plants are discussed in Section 9.2.2. 

8 Under the purchased power alternative, the environmental impacts of power production would 

9 still occur but would be located elsewhere within the region, nation, or in another country. If the 

10 purchased power alternative were to be implemented, the most significant environmental 

11 unknown would be whether or not new transmission line corridors would be required. The 

12 construction of new transmission lines could have both environmental and aesthetic 

13 consequences, particularly if new transmission line corridors were needed. The review team 

14 concludes that the local environmental impacts from purchased power would be SMALL when 

15 existing transmission line corridors are used and could range from SMALL to LARGE if 

16 acquisition of new corridors is required. The overall environmental impacts of power generation 

17 would depend on the generation technology and location of the generation site and, therefore, 

18 are unknown. However, as discussed in Section 9.2.5, the review team concluded that from an 

19 environmental perspective, none of the viable energy alternatives would be clearly preferable to 

20 construction of a new baseload nuclear power generation plant located within STPNOC’s ROI. 

21 Nuclear power facilities are initially licensed by the NRC for a period of 40 years. Operating 

22 licenses issued by the NRC can be renewed for up to 20 years; NRC regulations do not 

23 preclude multiple renewals. The operating license for STP Unit 1 expires in 2027, and the 

24 license for STP Unit 2 expires in 2028. STPNOC intends to submit an application to NRC in the 

25 fourth quarter of 2010 to renew the operating licenses of STP Units 1 and 2 (NRC 2009a). 

26 The environmental impacts of continued operation of a nuclear power plant are significantly less 

27 than construction of a new plant. However, continued operation of STP Units 1 and 2 already is 

28 considered in current energy planning. 

29 Older, existing fossil-fueled plants nearing the end of their useful lives, predominately coal-fired 

30 and natural gas-fired plants, are likely to need refurbishing to extend plant life for an extensive 

31 period (the proposed action assumes a minimum operating period of 40 years) and meet 

32 applicable environmental requirements. Given both the costs of refurbishment and the 

33 environmental impacts of operating such facilities, the review team concludes that extending the 

34 life of older, existing generating plants would not be a reasonable alternative to the proposed 

35 action. 

36 Retired generating plants, predominately coal-fired and natural gas-fired plants that potentially 

37 could be reactivated, would ordinarily require extensive refurbishment before reactivation. Such 
 Environmental Impacts of Alternatives 

March 2010 9-5 Draft NUREG-1937 

1 vintage plants typically would require refurbishment to meet current environmental requirements 

2 that would likely be costly. The environmental impacts of a reactivation scenario would be 

3 bounded by the impacts associated with coal-fired and natural gas-fired alternatives (see 

4 Section 9.2.2). Given both these costs and the environmental impacts of operating such 

5 facilities, the review team concludes that reactivating retired generating plants would not be a 

6 reasonable alternative to the proposed action. 

7 Improved energy efficiency and demand management strategies can potentially cost less than 

8 construction of new generation and provide a hedge against market, fuel, and environmental 

9 risks. NRG Energy, the controlling owner of Nuclear Innovation North America (NINA) and the 

10 primary seller of electricity in the ownership group, is a wholesale power generation company 

11 (Toshiba will not sell electricity from Units 3 and 4) (STPNOC 2009f). Consequently, it does not 

12 directly offer demand-side management or conservation programs. 

13 City Public Service Board of San Antonio (CPS Energy) is a retail electricity provider and offers 

14 a variety of energy conservation programs to its customers. It recently introduced a plan to 

15 support energy efficiency by treating it as a new fuel source for electrical generation. The plan 

16 projects how much the demand for electricity will grow over the next four years and seeks to 

17 reduce that amount by 10 percent each year in an effort to reach 40 percent by 2011. Through 

18 its Save for Tomorrow Energy Plan, CPS Energy’s goal is to achieve a cumulative reduction of 

19 approximately 771 MW(e) by 2020 (CPS 2009). To achieve this goal, CPS Energy is 

20 committing millions of dollars to customer incentives and rebates for the installation of high 

21 energy efficiency appliances, lighting, and insulation (CPS 2009). 

22 Among the energy conservation programs currently offered by CPS Energy to its customers are 

23 (STPNOC 2008a): 

24 Commercial Programs: 

25 • lighting retrofit programs 

26 • cool/thermal roof retrofits 

27 • high efficiency chiller and heating, ventilation, and air conditioning retrofits 

28 • efficient electric motors 

29 • window screening and tinting 

30 • incentives for solar water heaters and photovoltaic installations. 

31 Residential Programs: 

32 • rebates for high efficiency heating, ventilation, and air conditioning units 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-6 March 2010

1 • “peak save” programmable thermostats free to customers that allow cycling of air 

2 conditioning compressors in summer months to reduce peak electricity demand 

3 • home efficiency program that offers an array of rebates for attic insulation, duct work, wall 

4 insulation, solar powered attic fans, and window treatments 

5 • incentives for solar water heaters and photovoltaic installations. 

6 The need for power discussion in Chapter 8 takes account of conservation and demand-side 

7 management programs. The review team concluded in Chapter 8 that there is a justified need 

8 for power in the ERCOT region even with the implementation of conservation and demand-side 

9 management programs. 

10 Based on the preceding discussion, the review team concludes that the options of purchasing 

11 electric power from other suppliers, reactivating retired power plants, extending the operating 

12 life of existing power plants, and conservation and demand-side programs are not reasonable 

13 alternatives to providing new baseload power generation capacity. 

14 9.2.2 Alternatives Requiring New Generating Capacity 

15 Consistent with the NRC’s evaluation of alternatives to operating license renewal for nuclear 

16 power plants, a reasonable set of energy alternatives to building and operating one or more new 

17 nuclear units at the STP site should be limited to analysis of discrete power generation sources, 

18 a combination of sources, and those power generation technologies that are technically 

19 reasonable and commercially viable (NRC 1996). The current mix of baseload power 

20 generation options in Texas is one indicator of the feasible choices for power generation 

21 technology within the State. In September 2009, natural gas-fired power plants accounted for 

22 about 51 percent of the electricity produced in Texas, coal-fired plants about 34 percent, nuclear 

23 plants about 10 percent, and renewables (including hydroelectric) about 4 percent (DOE/EIA 

24 2009a). 

25 This section discusses the environmental impacts of energy alternatives to the proposed action 

26 that would require STPNOC to construct new generating capacity. The three primary energy 

27 sources for generating electric power in the United States are coal, natural gas, and nuclear 

28 energy (DOE/EIA 2009b). Coal-fired plants are the primary source of baseload generation in 

29 the United States (DOE/EIA 2009b). Natural gas combined-cycle generation plants are often 

30 used as intermediate generation sources, but they are also used as baseload generation 

31 sources (SSI 2010). 

32 Each year, the Energy Information Administration (EIA), a component of the U.S. Department of 

33 Energy (DOE), issues an annual energy outlook. In its Updated Annual Energy Outlook 2009, 

34 EIA’s reference case projects that total electric generating capacity additions between 2007 and 

35 2030 will use the following fuels in the approximate percentages: natural gas (55 percent), 
 Environmental Impacts of Alternatives 

March 2010 9-7 Draft NUREG-1937 

1 renewables (27 percent), coal (14 percent), and nuclear (5 percent) (DOE/EIA 2009c). The EIA 

2 projection includes baseload, intermittent, and peaking units and is based on the assumption 

3 that providers of new generating capacity would seek to minimize cost while meeting applicable 

4 environmental requirements. 

5 The discussion in Section 9.2.2 is limited to a reasonable range of the individual energy 

6 alternatives that appear to be viable for new baseload generation: coal-fired and natural gas 

7 combined cycle generation. The impacts discussed in Section 9.2.2 are estimates based on 

8 present technology. Section 9.2.3 addresses alternative generation technologies that have 

9 demonstrated commercial acceptance but may be limited in application, total capacity, or 

10 technical feasibility when based on the need to supply reliable, baseload capacity. 

11 The review team assumed that (1) new generation capacity would be located at the STP site for 

12 the coal- and natural gas-fired alternatives, (2) the cooling approach planned for proposed Units 

13 3 and 4 (Section 3.2.2.2) would be used for plant cooling, and (3) the existing transmission line 

14 corridors serving the STP site would be adequate to serve a new coal- or natural gas-fired plant 

15 sited there (Section 3.2.2.3). 

16 9.2.2.1 Coal-Fired Generation 

17 For the coal-fired generation alternative, the review team assumed construction of four 

18 supercritical pulverized coal-fired units, each with a net capacity of 675 MW(e). These 

19 assumptions are consistent with STPNOC’s COL application. Supercritical pulverized coal-fired 

20 plants are similar to conventional pulverized coal-fired plants except they operate at slightly 

21 higher temperatures and higher pressures, which allows for greater thermal efficiency. 

22 Supercritical coal-fired plants are commercially proven and represent an increasing proportion 

23 of new coal-fired power plants. A coal-fired plant is assumed to have a capacity factor of 

24 85 percent. 

25 The review team also considered an integrated gasification combined cycle (IGCC) coal-fired 

26 plant. IGCC is an emerging technology for generating electricity with coal that combines 

27 modern coal gasification technology with both gas turbine and steam turbine power generation. 

28 The technology is cleaner than conventional pulverized coal plants because major pollutants 

29 can be removed from the gas stream before combustion. The IGCC alternative also generates 

30 less solid waste than the pulverized coal-fired alternative. The largest solid waste stream 

31 produced by IGCC installations is slag, a black, glassy, sand-like material that is potentially a 

32 marketable byproduct. The other large-volume byproduct produced by IGCC plants is sulfur, 

33 which is extracted during the gasification process and can be marketed rather than placed in a 

34 landfill. IGCC units do not produce ash or scrubber wastes. In spite of the preceding 

35 advantages, the review team concludes that, at present, a new IGCC plant is not a reasonable 

36 alternative to a 2700 MW(e) nuclear power generation facility for the following reasons: 

37 (1) IGCC plants are more expensive than comparable pulverized coal plants (NETL 2007); 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-8 March 2010

1 (2) the two existing IGCC plants in the United States have considerably smaller capacity, 

2 approximately 250 MW(e) each, than the proposed 2700-MW(e) nuclear plant; (3) system 

3 reliability of existing IGCC plants has been lower than pulverized coal plants; (4) the existing 

4 IGCC plants have had an extended (though ultimately successful) operational testing period 

5 (NPCC 2005); and (5) a lack of overall plant performance warranties for IGCC plants has 

6 hindered commercial financing (NPCC 2005). For these reasons, IGCC plants are not 

7 considered further in this EIS. 

8 The review team assumed that coal and lime (calcium oxide or calcium hydroxide) or limestone 

9 (calcium carbonate) for a supercritical pulverized coal-fired plant would be delivered to the plant 

10 by train. STPNOC estimates that the plant would consume approximately 11 million tons/yr of 

11 pulverized sub-bituminous coal with an ash content of 3.9 percent (STPNOC 2009a). Lime or 

12 limestone, used in the scrubbing process for control of sulfur dioxide (SO2) emissions, is 

13 injected as a slurry into the hot effluent combustion gases to remove entrained SO2. The lime14 based scrubbing solution reacts with SO2 to form calcium sulfite, which precipitates and is 

15 removed from the process as sludge. STPNOC estimates that approximately 105,000 tons/yr of 

16 limestone would be used for flue gas desulfurization (STPNOC 2009a). 

17 Air Quality 

18 The impacts on air quality from coal-fired generation would vary considerably from those of 

19 nuclear generation because of emissions of SO2, nitrogen oxides (NOx), carbon monoxide (CO), 

20 particulate matter (PM), volatile organic compounds (VOCs), and hazardous air pollutants such 

21 as mercury and lead. In its environmental report (ER), STPNOC assumed a coal-fired plant 

22 design that would minimize air emissions through a combination of boiler technology and post23 combustion pollutant removal. STPNOC estimated that annual emissions for a supercritical 

24 pulverized coal-fired generation alternative using sub-bituminous coal would be approximately 

25 as follows (STPNOC 2009a): 

26 • SO2 – 2900 tons/yr 

27 • NOx – 2000 tons/yr 

28 • CO – 2800 tons/yr 

29 • PM10 – 50 tons/yr 

30 • PM2.5 – 13 tons/yr 

31 • Mercury – 0.46 tons/yr. 

32 PM10 is particulate matter with a diameter equal to or less than 10 microns (40 CFR 50.6). 

33 PM2.5 is particulate matter with a diameter equal to or less than 2.5 microns (40 CFR 50.7). 

34 Based on data from previous NRC EIS documents, the review team determined the preceding 

35 emission estimates are reasonable. A new coal-fired plant at the STP site would also have 
 Environmental Impacts of Alternatives 

March 2010 9-9 Draft NUREG-1937 

1 approximately 27 million tons/yr of unregulated carbon dioxide emissions (STPNOC 2009a) that 

2 could affect climate change. 

3 The acid rain requirements of the Clean Air Act capped the nation’s SO2 emissions from power 

4 plants. STPNOC would need to obtain sufficient pollution credits either from a set-aside pool or 

5 purchases on the open market to cover annual emissions from the plant. 

6 A new coal-fired generation plant at the STP site would likely need a prevention of significant 

7 deterioration (PSD) permit and an operating permit from the Texas Commission on 

8 Environmental Quality (TCEQ). The plant would need to comply with the new source 

9 performance standards for such plants in 40 CFR 60, Subpart Da. The standards establish 

10 emission limits for PM and opacity (40 CFR 60.42Da), SO2 (40 CFR 60.43Da), NOx

11 (40 CFR 60.44Da), and mercury (40 CFR 60.45Da). 

12 Fugitive dust emissions from construction activities would be mitigated using best management 

13 practices (BMPs); such emissions would be temporary (STPNOC 2009a). 

14 The U.S. Environmental Protection Agency(EPA) has various regulatory requirements for 

15 visibility protection in 40 CFR Part 51, Subpart P, including a specific requirement for review of 

16 any new major stationary source in areas designated as in attainment or unclassified under the 

17 Clean Air Act. The STP site is in an area designated as in attainment or unclassified for criteria 

18 pollutants (40 CFR 81.344). 

19 Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing 

20 future impairment of visibility and remedying existing impairment in mandatory Class I Federal 

21 areas when impairment is from air pollution caused by human activities. In addition, the EPA 

22 regulations provide that for each mandatory Class I Federal area located within a State, the 

23 State must establish goals that provide for reasonable progress toward achieving natural 

24 visibility conditions. The reasonable progress goals must provide for an improvement in visibility 

25 for the most impaired days over the period of the implementation plan and confirm no 

26 degradation in visibility for the least-impaired days over the same period [40 CFR 51.308(d)(1)]. 

27 If a new coal-fired power plant were located close to a mandatory Class I area, additional air 

28 pollution control requirements could be imposed. No mandatory Class I Federal areas are 

29 within 50 mi of the STP site. 

30 The GEIS for license renewal considers global warming from unregulated carbon dioxide 

31 emissions and acid rain from sulfur oxides and nitrogen oxide emissions as a potential impact 

32 (NRC 1996). Adverse human health effects, such as cancer and emphysema, have been 

33 associated with the byproducts of coal combustion. Overall, the review team concludes that air 

34 quality impacts from new coal-fired power generation at the STP site would be MODERATE. 

35 The impacts would be clearly noticeable but would not destabilize air quality. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-10 March 2010

1 Waste Management 

2 As the NRC has described in NUREG-1437 (NRC 1996) and verified during its preparation of 

3 the operating license renewal supplemental EIS analyses, coal combustion generates waste in 

4 the form of ash, and equipment for controlling air pollution generates additional ash, spent 

5 selective catalytic reduction (SCR) catalyst, and scrubber sludge. STPNOC estimated that a 

6 coal-fired plant would generate approximately 435,000 tons/yr of ash (STPNOC 2009a). 

7 STPNOC estimated that approximately 50 percent of the ash would be recycled (STPNOC 

8 2008a). The coal plant would also generate approximately 124,000 tons/yr of scrubber sludge. 

9 STPNOC estimated that landfill disposal of the ash and scrubber sludge over a 40-year plant life 

10 would require approximately 141 ac (STPNOC 2009a). 

11 In May 2000, the EPA issued a “Notice of Regulatory Determination on Wastes from the 

12 Combustion of Fossil Fuels” (65 FR 32214). The EPA concluded that some form of national 

13 regulation is warranted to address coal combustion waste products because of health concerns. 

14 Accordingly, the EPA announced its intention to issue regulations for disposal of coal15 combustion waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA). 

16 As of November 2009, the EPA is continuing to study the appropriate form of regulation for coal 

17 combustion waste products. 

18 Waste impacts on groundwater and surface water could extend beyond the operating life of the 

19 plant if leachate and runoff from the waste storage area occurs. Disposal of the waste could 

20 noticeably affect land use (because of the acreage needed for waste) and groundwater quality, 

21 but with appropriate management and monitoring, it would not destabilize any resources. After 

22 closure of the waste site and revegetation, the land could be available for other uses. 

23 Construction-related debris would be generated during plant construction activities, and would 

24 be disposed of in approved landfills. 

25 For the reasons stated above, the review team concludes that the impacts from waste 

26 generated at a coal-fired plant would be MODERATE. The impacts would be clearly noticeable 

27 but would not destabilize any important resource. 

28 Human Health 

29 Coal-fired power generation introduces worker risks from coal and limestone mining, worker and 

30 public risk from coal and lime/limestone transportation, worker and public risk from disposal of 

31 coal-combustion waste, and public risk from inhalation of stack emissions. In addition, the 

32 discharges of uranium and thorium from coal-fired plants can potentially produce radiological 

33 doses in excess of those arising from nuclear power plant operations (Gabbard 1993). 

34 Regulatory agencies, including the EPA and State agencies, base air emission standards and 

35 requirements on human health impacts. These agencies also impose site-specific emission 
 Environmental Impacts of Alternatives 

March 2010 9-11 Draft NUREG-1937 

1 limits as needed to protect human health. Given the regulatory oversight exercised by the EPA 

2 and State agencies, the review team concludes that the human health impacts from radiological 

3 doses and inhaled toxins and particulates generated from coal-fired generation would be 

4 SMALL. 

5 Other Impacts 

6 Approximately 576 ac would need to be converted to industrial use on the STP site for the 

7 powerblock, infrastructure and support facilities, coal and limestone storage and handling, and 

8 landfill disposal of ash and scrubber sludge (STPNOC 2009a). Land-use changes would also 

9 occur offsite in an undetermined coal mining area to supply coal for the plant. In NUREG-1437, 

10 the staff estimated that approximately 22,000 ac would be needed for coal mining and waste 

11 disposal to supply a 1000 MW(e) coal-fired power plant over its operating life (59,400 ac for a 

12 2700 MW(e) plant) (NRC 1996). Based upon the amount of land affected for the site, mining, 

13 and waste disposal, the review team concludes that land-use impacts would be MODERATE. 

14 The amount of water used and the impacts on water use and quality from constructing and 

15 operating a coal-fired plant at the STP site would be comparable to those associated with a new 

16 nuclear plant. All discharges would be regulated by the TCEQ through a Texas Pollutant 

17 Discharge Elimination System (TPDES) permit. Indirectly, water quality could be affected by 

18 acids and mercury from air emissions. However, these emissions are regulated to minimize 

19 impacts. In NUREG-1437, the staff determined that some erosion and sedimentation would 

20 likely occur during construction of new facilities (NRC 1996). These impacts would be similar to 

21 those for a new nuclear plant. Overall, the review team concludes that the water-use and water22 quality impacts would be SMALL. 

23 The coal-fired power generation alternative would introduce ecological impacts from 

24 construction and new incremental impacts from operations. The impacts would be similar to 

25 those of the proposed action at the STP site and along the transmission corridors. The impacts 

26 could include terrestrial and aquatic functional loss, habitat fragmentation and/or loss, reduced 

27 productivity, and a local reduction in biological diversity. The impacts could occur at the STP 

28 site and at the sites used for coal and limestone mining. Some of the impacts would occur in 

29 areas that were previously disturbed during the construction of STP Units 1 and 2, thereby 

30 limiting potential ecological effects. Stack emissions and disposal of waste products could 

31 affect aquatic and terrestrial resources. Additional impacts on threatened and endangered 

32 species could result from ash disposal and mining activities if the locations of such activities 

33 overlap with habitat for such protected species. Overall, the review team concludes that the 

34 ecological impacts would be MODERATE primarily because of potential impacts associated with 

35 disposal of ash and the large area of offiste land affected by mining activities. 

36 Socioeconomic impacts would result from the approximately 2400 workers needed to construct 

37 the plant and 315 workers to operate it, demands on housing and public services during 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-12 March 2010

1 construction, and the loss of jobs after construction (STPNOC 2009a). Overall, because the 

2 scale of activity for coal-fired power generation would be smaller than that for STP 3 and 4 but 

3 still significant in Matagorda County, the review team concludes that these impacts would be 

4 MODERATE and adverse in Matagorda County and SMALL and adverse elsewhere. STPNOC 

5 would pay significant property taxes for the plant to Matagorda County, the Matagorda County 

6 Hospital District, Navigation District #1, Drainage District #3, the Palacios Seawall District, and 

7 the Palacios Independent School District (STPNOC 2009a). The review team estimates that the 

8 taxes would have a LARGE beneficial impact to the tax recipients. 

9 The four coal-fired powerblock units would be up to 200 ft high and visible offsite during daylight 

10 hours. The four exhaust stacks would be up to 600 ft high. The stacks and associated 

11 emissions would likely be visible in daylight hours for distances greater than 10 mi. The 

12 powerblock units and associated stacks would also be visible at night because of outside 

13 lighting. The Federal Aviation Administration (FAA) generally requires that all structures 

14 exceeding an overall height of 200 ft above ground level have markings and/or lighting so as not 

15 to impair aviation safety (FAA 2007). A mitigating factor is that the STP site is currently an 

16 industrial site located in a rural area. The visual impacts of a new coal-fired plant could be 

17 further mitigated by landscaping and color selection for buildings that is consistent with the 

18 environment. Visual impacts at night could be mitigated by reduced use of lighting, enhanced 

19 use of downfacing-lighting provided the lighting meets FAA requirements, and appropriate use 

20 of shielding. Overall, the review team concludes that the aesthetic impacts associated with new 

21 coal-fired power generation at the STP site would be SMALL and adverse. 

22 Coal-fired power generation would introduce mechanical sources of noise that would likely be 

23 audible offsite. Sources contributing to the noise produced by plant operation are classified as 

24 continuous or intermittent. Continuous sources include the mechanical equipment associated 

25 with normal plant operations. Intermittent sources include the equipment related to coal 

26 handling, solid-waste disposal, transportation related to coal and limestone delivery, use of 

27 outside loudspeakers, and the commuting of plant employees. Noise impacts associated with 

28 rail delivery of coal and lime/limestone would be most significant for residents living in the 

29 vicinity of the facility and along the rail route. STPNOC estimated that about 17 unit trains of 

30 coal would be needed per week to supply a coal-fired plant (STPNOC 2009a). Although noise 

31 from passing trains significantly increases noise levels near the rail corridor, the short duration 

32 of the noise reduces the impacts. Nevertheless, given the frequency of train transport and the 

33 fact that many people are likely to be within hearing distance of the rail line, the review team 

34 concludes that the impacts of noise on residents in the vicinity of the facility and of the rail line 

35 would be MODERATE and adverse. 

36 As discussed in Section 2.6, minority and low-income persons are in the population near the 

37 STP site. However, the review team concludes that the socioeconomic-related environmental 

38 justice impacts on minority and low-income populations associated with a new coal-fired plant 

39 located at the STP site would likely be smaller than those associated with proposed Units 3 and 
 Environmental Impacts of Alternatives 

March 2010 9-13 Draft NUREG-1937 

1 4 because the smaller scale of the building and operating effort. The air quality and noise 

2 impacts of a coal-fired power plant in Matagorda County are described above as MODERATE 

3 and adverse. Because at least one Asian-Pacific Islander population block group borders the 

4 STP site to the west and one small, possibly low-income settlement borders the STP site to the 

5 east, there is a potential for a disproportionate and adverse impact on minority and low-income 

6 populations. However, the area in the vicinity of the STP site is not a disproportionately minority 

7 or low-income area, and the air quality impacts likely would affect all nearby populations roughly 

8 equally. Furthermore, as discussed in Section 2.6.3, the review team did not identify any 

9 evidence of unique characteristics or practices in the minority and low-income populations that 

10 may result in different air quality impacts compared to the general population (STPNOC 2009a; 

11 Scott and Niemeyer 2008). Therefore although the review team determined the air quality 

12 impact of a coal-fired plant would be noticeable and adverse, the environmental justice impact 

13 would be SMALL. 

14 Historic and cultural resource impacts for a new coal-fired plant located at the STP site would be 

15 similar to the impacts for a new nuclear plant as discussed in Sections 4.6 and 5.6. A cultural 

16 resources inventory would likely be needed for any onsite property that has not been previously 

17 surveyed. Other lands that would be acquired to support the plant would also likely need an 

18 inventory of field cultural resources, identification and recording of existing historic and 

19 archaeological resources, and possible mitigation of the adverse impact from ground-disturbing 

20 actions. The studies would likely be needed for all areas of potential disturbance at the plant 

21 site; any offsite affected areas, such as mining and waste-disposal sites; and along associated 

22 corridors where new construction would occur, such as roads. The review team concludes that 

23 the historic and cultural resource impacts would likely be SMALL. 

24 The review team’s characterizations of the construction and operation impacts of new coal-fired 

25 power generation at the STP site are summarized in Table 9-1 on the following page. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-14 March 2010

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

Impact Category Impact Comment

Land use MODERATE Uses approximately 576 ac for the powerblock, infrastructure 

and support facilities, coal and limestone storage and handling, 

and landfill disposal of ash and scrubber sludge. Mining 

activities would have additional impacts to tens of thousands of 

ac offsite. 

Air quality MODERATE Emissions would be approximately: 

SO2 – 2900 tons/yr 

NOx – 2000 tons/yr 

CO – 2800 tons/yr 

Hg – 0.46 tons/yr 

PM10 – 50 tons/yr 

PM2.5 – 13 tons/yr 

CO2 – 27 million tons/yr 

Water use and quality SMALL Impacts would be comparable to the impacts for new nuclear 

generating units located at the STP site. 

Ecology MODERATE Impacts could include terrestrial and aquatic functional loss, 

habitat fragmentation and/or loss, reduced productivity, and a 

local reduction in biological diversity. Impacts could occur at 

the STP site and vicinity and at the sites used for coal and 

limestone mining. Disposal of ash could affect the terrestrial 

and aquatic environments. Additional impacts on threatened 

and endangered species could result from ash disposal and 

mining activities. 

Waste management MODERATE Total waste volume would be approximately 435,000 tons/yr of 

ash and an additional 124,000 tons/yr of scrubber sludge. 

Socioeconomics LARGE 

Beneficial to 

MODERATE 

Adverse 

Impacts related to building the facilities would be noticeable. 

Local property tax base would benefit mainly during 

operations. Depending on where the workforce lives, the 

building-related impacts would be noticeable or minor. 

Impacts of coal transportation during operation would be 

noticeable. The plant would have noticeable aesthetic 

impacts. Some offsite noise impacts would occur. 

Human health SMALL Regulatory controls and oversight are assumed to be 

protective of human health. 

Historic and cultural 

resources 

SMALL Any potential impacts could likely be effectively managed. 

Most of the facility and infrastructure would be built on 

previously disturbed ground. 

Environmental justice SMALL 

Adverse 

There are minority and low-income persons in the local 

population; air quality and noise impacts to two populations 

could be noticeable but not disproportionate. 
 Environmental Impacts of Alternatives 

March 2010 9-15 Draft NUREG-1937 

1 9.2.2.2 Natural Gas-Fired Generation 

2 For the natural gas alternative, the review team assumed construction and operation of a 

3 natural gas-fired plant located at the STP site. The review team assumed that the plant would 

4 use combined-cycle combustion turbines, which is consistent with STPNOC’s ER. The review 

5 team used the assumption in the ER of four units with a net capacity of 675 MW(e) per unit 

6 (STPNOC 2009a). The natural gas-fired plant is assumed to have an operating life of 40 years. 

7 STPNOC estimated that the natural gas-fired plant would use approximately 121 billion 

8 standard cubic feet of natural gas per year (STPNOC 2009a). 

9 Air Quality 

10 Natural gas is a relatively clean-burning fuel. When compared to a coal-fired plant, a natural 

11 gas-fired plant would release similar types of emissions but in lower quantities. A new natural 

12 gas-fired power generation plant would likely need a PSD permit and an operating permit from 

13 the TCEQ. A new natural gas-fired combined-cycle plant would also be subject to the new 

14 source performance standards in 40 CFR 60, Subparts Da and GG. These regulations 

15 establish emission limits for particulates, opacity, SO2, and NOX. The EPA has various 

16 regulatory requirements for visibility protection in 40 CFR 51, Subpart P, including a specific 

17 requirement for review of any new major stationary source in areas designated as in attainment 

18 or unclassified under the Clean Air Act. The STP site is in an area designated as in attainment 

19 or unclassified for criteria pollutants (40 CFR 81.344). 

20 Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing 

21 future impairment of visibility and remedying existing impairment in mandatory Class I Federal 

22 areas when impairment is from air pollution caused by human activities. In addition, the EPA 

23 regulations provide that for each mandatory Class I Federal area located within a State, the 

24 State must establish goals that provide for reasonable progress toward achieving natural 

25 visibility conditions. The reasonable progress goals must provide for an improvement in visibility 

26 for the most impaired days over the period of the implementation plan and ensure no 

27 degradation in visibility for the least-impaired days over the same period (40 CFR 51.308(d)(1)). 

28 If a new natural gas-fired power plant were located close to a mandatory Class I area, additional 

29 air pollution control requirements could be imposed. No mandatory Class I Federal areas are 

30 within 50 mi of the STP site. 

31 STPNOC estimated that a natural gas-fired plant equipped with pollution control technology to 

32 meet emission limits would have approximately the following emissions (STPNOC 2009a): 

33 • SO2 – 41 tons/yr 

34 • NOx – 680 tons/yr 

35 • CO – 141 tons/yr 

36 • PM2.5 – 119 tons/yr. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-16 March 2010

1 Based on data from previous NRC EIS documents, the review team determined the preceding 

2 emission estimates are reasonable. A natural gas-fired power plant would also have 

3 approximately 6.9 million tons/yr of unregulated carbon dioxide emissions (STPNOC 2009a) 

4 that could affect climate change. 

5 The combustion turbine portion of the combined-cycle plant would be subject to EPA’s National 

6 Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines 

7 (40 CFR 63) if the site is a major source of hazardous air pollutants. Major sources have the 

8 potential to emit 10 tons/yr or more of any single hazardous air pollutant or 25 tons/yr or more of 

9 any combination of hazardous air pollutants (40 CFR 63.6085(b)). 

10 The review team assumes fugitive dust emissions from construction activities would be 

11 mitigated using BMPs, similar to mitigation discussed in Chapter 4 for proposed Units 3 and 4. 

12 Such emissions would be temporary. 

13 The impacts of emissions from a natural gas-fired power generation plant would be clearly 

14 noticeable, but would not be sufficient to destabilize air resources. Overall, the review team 

15 concludes that air quality impacts resulting from construction and operation of new natural gas16 fired power generation at the STP site would be SMALL to MODERATE. 

17 Waste Management 

18 In NUREG-1437, the NRC staff concluded that waste generation from natural gas-fired 

19 technology would be minimal (NRC 1996). The only significant waste generated at a natural 

20 gas-fired power plant would be spent SCR catalyst, which is used to control NOx emissions. 

21 The spent catalyst would be regenerated or disposed of offsite. Other than spent SCR catalyst, 

22 waste generation at an operating natural gas-fired plant would be limited largely to typical 

23 operations and maintenance waste. Construction-related debris would be generated during 

24 construction activities. Overall, the review team concludes that waste impacts from natural gas25 fired power generation would be SMALL. 

26 Human Health 

27 Natural gas fired power generation introduces public risk from inhalation of gaseous emissions. 

28 The risk may be attributable to NOx emissions that contribute to ozone formation, which in turn 

29 contribute to health risk. Regulatory agencies, including the EPA and state agencies, base air 

30 emission standards and requirements on human health impacts. These agencies also impose 

31 site-specific emission limits as needed to protect human health. Given the regulatory oversight 

32 exercised by the EPA and State agencies, the review team concludes that the human health 

33 impacts from natural gas-fired power generation would be SMALL. 
 Environmental Impacts of Alternatives 

March 2010 9-17 Draft NUREG-1937 

1 Other Impacts 

2 A natural gas-fired generating plant would require approximately 107 ac for the power-block and 

3 support facilities (STPNOC 2009a). Construction of a natural gas pipeline from the STP site to 

4 the closest natural gas distribution line, located approximately 2 mi northwest of the site, would 

5 require approximately 18 ac. Thus, the total land commitment, not including natural gas wells 

6 and collection stations, would be approximately 125 ac. A small amount of additional land 

7 would also be required for natural gas wells and collection stations. Overall, the review team 

8 concludes that the land-use impacts from new natural gas-fired power generation at the STP 

9 site would be SMALL. 

10 The amount of water used and the impacts on water use and quality from constructing and 

11 operating a natural gas-fired plant at the STP site would be less than the impacts associated 

12 with building and operating a new nuclear facility. The impacts on water quality from 

13 sedimentation during construction of a natural gas-fired plant were characterized in 

14 NUREG-1437 as SMALL (NRC 1996). The NRC staff also noted in NUREG-1437 that the 

15 impacts on water quality from operations would be similar to, or less than, the impacts from 

16 other generating technologies (NRC 1996). Overall, the review team concludes that impacts on 

17 water use and quality would be SMALL. 

18 A natural gas-fired plant at the STP site would have less extensive ecological impacts than a 

19 new nuclear facility because less land would be affected. Much of the impact would occur in 

20 areas that were previously disturbed during the construction of STP Units 1 and 2. Constructing 

21 a new underground gas pipeline to the site would result in permanent loss of some terrestrial 

22 and aquatic function and conversion and fragmentation of habitat; however, assuming that the 

23 distance required to connect to natural gas distribution systems would be minimal, no important 

24 ecological attributes would be noticeably altered. Impacts on threatened and endangered 

25 species would be similar to the impacts from a new nuclear facility located at the STP site. 

26 Overall, the review team concludes that ecological impacts from a natural gas-fired plant at the 

27 STP site would be SMALL. 

28 Socioeconomic impacts would result from the approximately 661 workers needed to build the 

29 plant and 91 workers needed to operate it, demands on housing and public services during 

30 construction, and the loss of jobs after construction (STPNOC 2009a). Overall, the review team 

31 concludes these impacts would be SMALL and adverse for demographics, public services, 

32 education, traffic, and housing because of the mitigating influence of the site’s proximity to the 

33 surrounding population area and the relatively small number of workers needed to build and 

34 operate the plant in comparison to nuclear and coal-fired generation alternatives. The plant 

35 owner would pay significant property taxes for the plant to Matagorda County, the Matagorda 

36 County Hospital District, Navigation District #1, Drainage District #3, the Palacios Seawall 

37 District and the Palacios Independent School District (STPNOC 2009a) and would employ a 

38 noticeable but not significant number of workers, especially during the building period. Based 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-18 March 2010

1 on the expected valuation of a natural gas plant, which would be significantly less than for 

2 nuclear or coal, the property taxes would be lower for the natural gas option. Considering the 

3 population and economic condition of the County, the review team concludes that the taxes and 

4 employment would have a MODERATE beneficial impact on the County. 

5 Other socioeconomic impacts related to construction and operation would be SMALL. In most 

6 cases, the impacts would not likely be detectable, and certainly would not destabilize any 

7 important attribute of the resource involved. 

8 The turbine buildings, four exhaust stacks (approximately 200-ft high) and associated 

9 emissions, and the gas pipeline compressors would be visible during daylight hours from offsite. 

10 Noise and light from the plant would be detectable offsite. A mitigating factor is the STP site is 

11 currently an industrial site located in a rural area. Overall, the review team concludes that the 

12 aesthetic impacts associated with new natural gas-fired power generation at the STP site would 

13 be SMALL and adverse. 

14 Historic and cultural resource impacts for a new natural gas-fired plant located at the STP site 

15 would be similar to the impacts for a new nuclear plant as discussed in Sections 4.6 and 5.6. A 

16 cultural resources inventory would likely be needed for any onsite property that has not been 

17 previously surveyed. Other lands that would be acquired to support the plant would also likely 

18 need an inventory of field cultural resources, identification and recording of existing historic and 

19 archaeological resources, and possible mitigation of the adverse impact from ground-disturbing 

20 actions. The studies would likely be needed for all areas of potential disturbance at the plant 

21 site; any offsite affected areas, such as gas wells, collection stations, and waste disposal sites; 

22 and along associated corridors where new construction would occur, such as roads and a new 

23 pipeline. The review team concludes that the historic and cultural resource impacts associated 

24 with new natural gas-fired power generation at the STP site would be SMALL. 

25 As described in Section 2.6, there are minority and low-income persons in the population 

26 around the STP site. However, the review team concludes that the impacts of a natural gas27 fired plant at the STP site on minority or low-income populations would likely be much smaller 

28 than those associated with STP 3 and 4 because of the smaller scale of the building and 

29 operating effort. The air quality impacts of a natural gas-fired power plant in Matagorda County 

30 are described as SMALL to MODERATE and adverse. Similar to the situation with a coal-fired 

31 power plant at the STP site, there is potential for the Asian-Pacific Islander population block 

32 group on the west side of the STP site and the small, possibly low-income settlement on the 

33 east to experience a SMALL to MODERATE adverse impact. However, the area in the vicinity 

34 of the STP site is not a disproportionately minority or low-income area, and the air quality 

35 impacts likely would affect all nearby populations roughly equally. Furthermore, as discussed in 

36 Section 2.6.3, the staff did not identify any evidence of unique characteristics or practices in the 

37 minority and low-income populations that may result in different air quality impacts compared to 

38 the general population (STPNOC 2009a; Scott and Niemeyer 2008). Therefore, although the 
 Environmental Impacts of Alternatives 

March 2010 9-19 Draft NUREG-1937 

1 review team determined the air quality impact of a gas-fired plant could be noticeable and 

2 adverse, the environmental justice impact would be SMALL. The review team’s characterization 

3 of the construction and operational impacts of natural gas-fired power generation at the STP site 

4 are summarized in Table 9-2 below. 

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

Impact Category Impact Comment

Land use SMALL Approximately 125 ac would be needed for the power-block and 

support systems and connection to a natural gas pipeline. 

Air quality SMALL to 

MODERATE 

Emissions would be approximately: 

SO2 – 41 tons/yr 

NOx – 680 tons/yr 

CO – 141 tons/yr 

PM2.5 – 119 tons/yr 

CO2 – 6.9 million tons/yr. 

Water use and 

quality 

SMALL Impacts would be somewhat less than the impacts for new 

nuclear generating units located at the STP site. 

Ecology SMALL Constructing a new underground gas pipeline to the site would 

result in some permanent loss of terrestrial and aquatic function 

and conversion and fragmentation of habitat. Impacts on 

threatened and endangered species would be similar to the 

impacts from new nuclear generating units. In forested areas, 

impacts from pipeline construction would cause conversion of 

forested areas to herbaceous growth, resulting in net loss of 

function. 

Waste 

management 

SMALL The only significant waste would be from spent SCR catalyst 

used for control of NOx emissions. 

Socioeconomics MODERATE 

Beneficial to 

SMALL 

Adverse 

Construction and operations workforces would be relatively 

small. Addition to property tax base, while smaller than for a 

nuclear or coal-fired plant, might still be quite noticeable. 

Construction-related beneficial economic impacts would be 

noticeable, but there likely would not be noticeable adverse 

impacts on community services or infrastructure because of the 

relatively small numbers of in-migrants. Impacts during 

operation would be minor because of the small work-force 

involved. The plant would have only minor aesthetic impacts. 

Human health SMALL Regulatory controls and oversight are assumed to be protective 

of human health. 

Historic and 

cultural 

resources 

SMALL Any potential impacts could likely be effectively managed. Most 

of the facility and infrastructure would be built on previously 

disturbed ground. 

Environmental 

justice 

SMALL There are minority and low-income persons in the local 

population; air quality impacts to two populations could be 

noticeable but not disproportionate. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-20 March 2010

1 9.2.3 Other Alternatives 

2 This section discusses other energy alternatives, the review team’s conclusions about the 

3 feasibility of each alternative, and the review team’s basis for the conclusions. New nuclear 

4 units at the STP site would be baseload generation units. Any feasible alternative to the new 

5 units would need to generate baseload power. In evaluating other energy technologies, 

6 STPNOC used the technologies discussed in the GEIS for license renewal (NRC 1996). The 

7 review team reviewed the information submitted by STPNOC in its ER and also conducted an 

8 independent review. The review team determined that the other energy alternatives are not 

9 reasonable alternatives to two new nuclear units that would provide baseload power. 

10 The review team has not assigned significance levels to the environmental impacts associated 

11 with the alternatives discussed in Section 9.2.3 because, in general, the generation alternatives 

12 would have to be installed at a location other than the STP site. Any attempt to assign 

13 significance levels would require the review team’s speculation about the unknown site. 

14 9.2.3.1 Oil-Fired Generation 

15 EIA’s reference case in its Updated Annual Energy Outlook 2009 projects that oil-fired power 

16 plants will not account for any new electric power generation capacity in the United States 

17 through the year 2030 (DOE/EIA 2009c). Oil-fired generation is more expensive than nuclear, 

18 natural gas-fired, or coal-fired generation options. In addition, future increases in oil prices are 

19 expected to make oil-fired generation increasingly more expensive. The high cost of oil has 

20 resulted in a decline in its use for electricity generation. In Section 8.3.11 of NUREG-1437, 

21 the staff estimated that construction of a 1000-MW(e) oil-fired plant would require about 120 ac 

22 of land (NRC 1996). Operation of an oil-fired powerplant would have environmental impacts 

23 that would be similar to those of a comparably sized coal-fired plant (see Section 9.2.2.1) 

24 (NRC 1996). 

25 For the preceding economic and environmental reasons, the review team concludes that an oil26 fired power plant located would not be a reasonable alternative to construction of a 2700 MW(e) 

27 nuclear power generation facility that would be operated as a baseload plant within STPNOC’s 

28 ROI. 

29 9.2.3.2 Wind Power 

30 Texas has significant wind energy resources and leads the Nation in wind-powered generation 

31 capacity (DOE/EIA 2009a). The installed wind capacity in Texas as of 2008 was approximately 

32 6234 MW(e) (ERCOT 2008). Wind resource areas in the Texas Panhandle, along the Gulf 

33 Coast south of Galveston, and in the mountain passes and ridgetops of the Trans-Pecos region 

34 offer some of the greatest wind power potential in the United States. The Horse Hollow Wind 
 Environmental Impacts of Alternatives 

March 2010 9-21 Draft NUREG-1937 

1 Energy Center in Texas is the largest wind farm in the world with a total capacity of 735 MW(e) 

2 spread across approximately 47,000 ac in Taylor and Nolan Counties near Abilene in west3 central Texas (TSECO 2008b). 

4 Newer wind turbines typically operate at approximately a 36 percent capacity factor (DOE 

5 2008a). In comparison, the average capacity factor for a nuclear generation plant in 2008 in the 

6 United States was 91.5 percent (NEI 2009). Wind turbines generally can serve as an 

7 intermittent power supply (NPCC 2005). Section 8.2 notes that the effective load carrying 

8 capability of wind is assumed by ERCOT to be 8.7 percent of name plate generation. Wind 

9 power, in conjunction with energy storage mechanisms such as pumped hydroelectric or 

10 compressed air energy storage (CAES), or another readily dispatchable power source, e.g., 

11 hydropower, might serve as a means of providing baseload power. 

12 EIA is not projecting any growth in pumped storage capacity through 2030 (DOE/EIA 2009c). In 

13 addition, the review team concludes in Section 9.2.3.4 that the potential for new hydroelectric 

14 development in Texas is limited. Therefore, the review team concludes that the use of pumped 

15 storage in combination with wind turbines to generate 2700 MW(e) is unlikely in Texas. 

16 A CAES plant consists of motor driven air compressors that use low cost off peak electricity to 

17 compress air into an underground storage medium. During high electricity demand periods, the 

18 stored energy is recovered by releasing the compressed air through a combustion turbine to 

19 generate electricity (NPCC 2009). Only two CAES plants are currently in operation. A 290-MW 

20 plant near Bremen, Germany, began operating in 1978, and a 110-MW plant located in 

21 McIntosh, Alabama, has been operating since 1991. Both facilities use salt caverns (Succar 

22 and Williams 2008). A CAES plant requires suitable geology such as an underground cavern 

23 for energy storage. A 268-MW CAES plant coupled to a wind farm, the Iowa Stored Energy 

24 Park, has been proposed for construction near Des Moines, Iowa. The facility would use a 

25 porous rock storage reservoir for the compressed air (Succar and Williams 2008). To date, 

26 nothing approaching the scale of a 2700 MW(e) facility has been contemplated. Therefore, the 

27 review team concludes that the use of CAES in combination with wind turbines to generate 

28 2700 MW(e) in Texas is unlikely. 

29 Aerodynamic and mechanical noise from wind turbines would affect wildlife. Collisions with 

30 wind turbines would increase bird and bat mortality. However, technological advances allow 

31 rotors to turn at lower speeds, reducing the potential for bird and bat strikes. 

32 A significant challenge for new wind power facilities is that wind farms can be built more quickly 

33 than transmission lines. It can take a year to build a wind farm, but five years to build the 

34 transmission lines needed to send power to cities. Moreover, wind power developers are 

35 reluctant to build where transmission lines do not yet exist, and utilities are equally reluctant to 

36 install transmission in areas that do not yet have power generators (TSECO 2008c). 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-22 March 2010

1 Southern Company and the Georgia Institute of Technology (GIT) studied the viability of 

2 offshore wind turbines in the southeast (Southern and GIT 2007). Among the conclusions of the 

3 study authors were the following: (1) the available wind data indicate that a wind farm located 

4 offshore of Georgia would likely have an adequate wind speed to support a project, although 

5 offshore project costs run approximately 50 to 100 percent higher than land-based systems; 

6 (2) based on current prices for wind turbines, the 20-year levelized cost of electricity produced 

7 from an offshore wind farm would be above the current production costs from existing power 

8 generation facilities; and (3) the current commercially available offshore wind turbines are not 

9 built to withstand major hurricanes above a Category 3 or a 1-min sustained wind speed of 

10 124 mph. The review team believes that the preceding conclusions would generally apply to a 

11 wind farm located offshore of Texas. 

12 Although wind power is an important energy resource in Texas, the review team concludes that 

13 a wind energy facility at or in the vicinity of the STP site or elsewhere in STPNOC’s ROI would 

14 not currently be a reasonable alternative to construction of a 2700 MW(e) nuclear power 

15 generation facility within STPNOC’s ROI that would be operated as a baseload plant. 

16 9.2.3.3 Solar Power 

17 Solar technologies use energy and light from the sun to provide heating and cooling, light, hot 

18 water, and electricity for consumers. Solar energy can be converted to electricity using solar 

19 thermal technologies or photovoltaics. Solar thermal technologies employ concentrating 

20 devices to create temperatures suitable for power production. Concentrating thermal 

21 technologies are currently less costly than photovoltaics for bulk power production. They can 

22 also be provided with energy storage or auxiliary boilers to allow operation during periods when 

23 the sun is not shining (NPCC 2006). The largest operational solar thermal plant is the 

24 310 MW(e) Solar Energy Generating System located on approximately 1500 ac in the Mojave 

25 Desert in southern California (NextEra 2009). 

26 Solar radiation is available throughout Texas in sufficient quantity to power distributed solar 

27 systems such as solar water heaters and off-grid photovoltaic panels. Large solar power plants 

28 would be most cost-effective when sited in areas of west Texas that receive high levels of direct 

29 solar radiation (TSECO 2008a). 

30 Solar radiation has a low energy density relative to other common energy sources. 

31 Consequently a large total acreage is needed to gather an appreciable amount of energy. 

32 Typical solar-to-electric power plants require 5 to 10 ac for every MW of generating capacity 

33 (TSECO 2008a). For the target capacity of 2700 MW(e) for proposed Units 3 and 4, land 

34 requirements would thus be approximately 13,500 to 27,000 ac. Solar thermal electric 

35 technologies also typically require considerable water supplies. While the quantity of water 

36 needed per acre of use is similar to or less than that needed for irrigated agriculture, 
 Environmental Impacts of Alternatives 

March 2010 9-23 Draft NUREG-1937 

1 dependability of the water supply is an important issue in the sunny, dry areas of Texas that 

2 would be favored for large-scale solar power plants (TSECO 2008a). 

3 For a large solar plant to be practical as a baseload energy source, a means to store large 

4 quantities of energy for distribution when the plant is producing less than 2700 MW(e) would be 

5 needed. However, the storage possibilities are limited as discussed in Section 9.2.3.2. 

6 Because of the large amount of acreage required for comparable power generation and the 

7 limited energy storage availability, the review team concludes that solar energy facilities at or in 

8 the vicinity of the STP site would not currently be a reasonable alternative to construction of a 

9 2700 MW(e) nuclear power generation facility within STPNOC’s ROI that would be operated as 

10 a baseload plant. 

11 9.2.3.4 Hydropower 

12 Most of Texas does not lend itself to large-scale hydroelectric projects. In 2004, hydropower 

13 accounted for 0.62 percent of the State’s electrical capacity and only 0.34 percent of electricity 

14 actually produced. While Texas has some identified potential for additional hydroelectric 

15 capacity, the likelihood of development is not high. Reservoirs can face opposition from the 

16 public and policy makers, and all new reservoirs being proposed in Texas by water planners are 

17 intended for storing water supplies (Texas Comptroller of Public Accounts 2008a). 

18 EIA’s reference case in its Updated Annual Energy Outlook 2009 projects that U.S. electricity 

19 production from hydropower plants will remain essentially stable through the year 2030 

20 (DOE/EIA 2009c). 

21 In NUREG-1437, the NRC staff estimated that land requirements for hydroelectric power are 

22 0.4 million ha (1 million ac) per 1000 MW(e) (NRC 1996). For the target capacity of 2700 MW(e) 

23 for proposed Units 3 and 4, land requirements would thus be 2.7 million ac. Aquatic organisms 

24 could become stranded temporarily when river levels are lowered. Temperature and nutrient 

25 stratification in the reservoir and reduced levels of dissolved oxygen could result in hypotoxic or 

26 anoxic conditions for aquatic organisms. Aquatic and riparian ecosystems downstream would be 

27 affected by a variety of dam-induced conditions, such as changes in sediment transport and 

28 deposition patterns, and channel erosion or scouring. Hydropower operations could enhance 

29 populations of nonnative aquatic biota and riparian plants. 

30 Because of the relatively low amount of undeveloped hydropower resources in Texas and the 

31 large land use and related environmental and ecological resource impacts associated with siting 

32 hydroelectric facilities large enough to produce 2700 MW(e), the review team concludes that 

33 local hydropower is not a feasible alternative to construction of a new nuclear power generation 

34 facility within STPNOC’s ROI that would be operated as a baseload plant. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-24 March 2010

1 9.2.3.5 Geothermal Energy 

2 Hydrothermal resources, reservoirs of steam or hot water, are available primarily in the western 

3 states, Alaska, and Hawaii. However, earth energy can be tapped almost anywhere with 

4 geothermal heat pumps and direct-use applications. Other geothermal resources (e.g., hot, dry 

5 rock and magma) are awaiting further technology development (DOE 2006). 

6 Texas does not have the sort of readily accessible, high-temperature hydrothermal resource 

7 that can be used to generate electricity (Virtus 2008). The resource in the central part of the 

8 State can, however, have an impact in low-temperature applications such as space heating or 

9 aquaculture. The geopressured-geothermal resource in Texas will become more attractive only 

10 in the context of higher energy prices. The potential of hot dry rock in Texas is presently 

11 unknown (Virtus 2008). 

12 Geothermal energy has an average capacity factor of 90 percent and can be used for baseload 

13 power where available. However, geothermal technology is not widely used as baseload power 

14 generation because of the limited geographic availability of the resource and immature status of 

15 the technology (NRC 1996). Geothermal systems have a relatively small footprint and minimal 

16 emissions (MIT 2006). A study led by the Massachusetts Institute of Technology concluded that 

17 a $300-$400 million investment over 15 years would be needed to make early-generation 

18 enhanced geothermal system power plant installations competitive in the evolving U.S. 

19 electricity supply markets (MIT 2006). 

20 Based on the limited geothermal energy resources currently available in Texas and immature 

21 status of the technology, the review team concludes that one or more geothermal energy 

22 facilities within STPNOC’s ROI would not currently be a reasonable alternative to construction of 

23 a 2700 MW(e) nuclear power generation facility within STPNOC’s ROI that would be operated 

24 as a baseload plant. 

25 9.2.3.6 Wood Waste 

26 In NUREG-1437, the NRC staff determined that a wood-burning facility can provide baseload 

27 power and operate with an average annual capacity factor of around 70 to 80 percent and with 

28 20 to 25 percent efficiency (NRC 1996). The fuels required are variable and site-specific. A 

29 significant impediment to the use of wood waste to generate electricity is the high cost of fuel 

30 delivery and high construction cost per megawatt of generating capacity. The larger wood31 waste power plants are typically only 40 to 50 MW(e) in size. Estimates in NUREG-1437 

32 suggest that the overall level of construction impacts per megawatt of installed capacity would 

33 be approximately the same as that for a coal-fired plant, although facilities using wood waste for 

34 fuel would be built at smaller scales (NRC 1996). Similar to coal-fired plants, wood waste plants 

35 require large areas for fuel storage and processing and involve the same type of combustion 

36 equipment. 
 Environmental Impacts of Alternatives 

March 2010 9-25 Draft NUREG-1937 

1 A 100 MW(e) wood-fired biomass power plant being developed in Sacul, Texas, will use logging 

2 residue as its main fuel source, but also could use urban wood waste (Texas Comptroller of 

3 Public Accounts 2008b). The plant owner, Southern Power, estimates that the plant will require 

4 approximately 1 million tons of biomass per year, which it plans to procure within a 75-mi radius 

5 of the project site (Southern 2009). The plant is scheduled to come online in summer 2012. 

6 Because of uncertainties associated with obtaining sufficient wood and wood waste to fuel a 

7 baseload power plant, the ecological impacts of large-scale timber cutting (for example, soil 

8 erosion and loss of wildlife habitat), and the relatively small size of wood generation plants, the 

9 review team concludes that wood waste would not be a reasonable alternative in STPNOC’s 

10 ROI to a 2700 MW(e) nuclear power generation facility operated as a baseload plant. 

11 9.2.3.7 Municipal Solid Waste 

12 Municipal solid-waste combustors incinerate the waste and can use the resultant heat to 

13 produce steam, hot water, or electricity. The combustion process reduces the volume of waste 

14 and the need for new solid waste landfills. Mass burning technologies are most commonly used 

15 in the United States. This group of technologies processes raw municipal solid waste with little 

16 or no sizing, shredding, or separation before combustion. More than one-fifth of the 

17 U.S. municipal solid waste incinerators use refuse-derived fuel. In contrast to mass burning—

18 where the municipal solid waste is introduced "as is" into the combustion chamber—refuse19 derived fuel facilities are equipped to recover recyclables (e.g., metals, cans, and glass) 

20 followed by shredding the combustible fraction into fluff for incineration (EPA 2008). 

21 In NUREG-1437, the NRC staff determined that the initial capital cost for municipal solid-waste 

22 plants is greater than for comparable steam-turbine technology at wood-waste facilities because 

23 of the need for specialized waste-separation and waste-handling equipment for municipal solid 

24 waste (NRC 1996). 

25 Municipal solid-waste combustors generate SO2 and NOx emissions and an ash residue that is 

26 buried in landfills. The ash residue is composed of bottom ash and fly ash. Bottom ash refers 

27 to that portion of the unburned waste that falls to the bottom of the grate or furnace. Fly ash 

28 represents the small particles that rise from the furnace during the combustion process. Fly ash 

29 is generally removed from flue gases using fabric filters and/or scrubbers (EPA 2009a). 

30 Currently, approximately 87 waste-to-energy plants are operating in the United States (EPA 

31 2009a). No plants are operating in Texas (Texas Comptroller of Public Accounts 2008c). The 

32 87 plants generate approximately 2500 MW(e), or an average of approximately 29 MW(e) per 

33 plant (EPA 2009a). Given the small average output of existing plants, the review team 

34 concludes that generating electricity from municipal solid waste would not be a reasonable 

35 alternative to a 2700 MW(e) nuclear power generation facility operated as a baseload plant 

36 within STPNOC’s ROI. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-26 March 2010

1 9.2.3.8 Other Biomass-Derived Fuels 

2 In addition to wood and municipal solid-waste fuel, several other biomass-derived fuels are 

3 available for fueling electric generators including burning crops, converting crops to a liquid fuel 

4 such as ethanol, and gasifying crops (including wood waste). EIA estimates that wind and 

5 biomass will be the largest source of renewable electricity generation among the 

6 nonhydropower renewable fuels through the year 2030 (DOE/EIA 2009c). However, in 

7 NUREG-1437, the NRC staff determined that none of these technologies has progressed to the 

8 point of being competitive on a large scale or of being reliable enough to replace a large 

9 baseload generating plant (NRC 1996). The major operating waste from biomass plants would 

10 be the fly ash and bottom ash that results from the combustion of the carbonaceous fuels. 

11 Currently, biomass energy accounts for less than 1 percent of electrical power production in 

12 Texas (Texas Comptroller of Public Accounts 2008d). 

13 Co-firing biomass with coal is possible when low-cost biomass resources are available. 

14 Co-firing is the most economic option for the near future to introduce new biomass power 

15 generation. These projects require small capital investments per unit of power generation 

16 capacity. Co-firing systems range in size from 1 to 30 MW(e) of biopower capacity 

17 (DOE 2008b). 

18 The review team concludes that given the relatively small average output of biomass generation 

19 facilities, biomass-derived fuels do not offer a reasonable alternative to a 2700 MW(e) nuclear 

20 power generation facility operated as a baseload plant within STPNOC’s ROI. 

21 9.2.3.9 Fuel Cells 

22 Fuel cells work without combustion and its associated environmental side effects. Power is 

23 produced electrochemically by passing a hydrogen-rich fuel over an anode, air over a cathode, 

24 and then separating the two by an electrolyte. The only byproducts are heat, water, and carbon 

25 dioxide. Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to 

26 steam under pressure. Natural gas is typically used as the source of hydrogen. 

27 Phosphoric acid fuel cells are generally considered first-generation technology. Higher28 temperature, second-generation fuel cells achieve higher fuel-to-electricity and thermal 

29 efficiencies. The higher temperatures contribute to improved efficiencies and give the second30 generation fuel cells the capability to generate steam for cogeneration and combined-cycle 

31 operations. 

32 During the past three decades, significant efforts have been made to develop more practical 

33 and affordable fuel cell designs for stationary power applications, but progress has been slow. 

34 The cost of fuel cell power systems must be reduced before they can be competitive with 

35 conventional technologies (DOE 2008c). 
 Environmental Impacts of Alternatives 

March 2010 9-27 Draft NUREG-1937 

1 The review team concludes that, at the present time, fuel cells are not economically or 

2 technologically competitive with other alternatives for baseload electricity generation. Future 

3 gains in cost competitiveness for fuel cells compared to other fuels are speculative. 

4 For the preceding reasons, the review team concludes that a fuel cell energy facility located in 

5 STPNOC’s ROI would not currently be a reasonable alternative to construction of a 2700 MW(e) 

6 nuclear power generation facility operated as a baseload plant. 

7 9.2.4 Combination of Alternatives 

8 Individual alternatives to the construction of one or more new nuclear units at the STP site might 

9 not be sufficient on their own to generate STPNOC’s target value of 2700 MW(e) because of the 

10 limited availability of the resource or lack of cost-effective opportunities. Nevertheless, it is 

11 conceivable that a combination of alternatives might be cost effective. There are many possible 

12 combinations of alternatives. It would not be reasonable to examine every possible combination 

13 of energy alternatives in an EIS. Doing so would be counter to CEQ guidance that an EIS 

14 should be analytic rather than encyclopedic, shall be kept concise, and shall be no longer than 

15 absolutely necessary to comply with NEPA and CEQ’s regulations [40 CFR 1502.2(a), (b)]. 

16 Given that STPNOC’s objective is for a new baseload generation facility, a fossil energy source, 

17 most likely coal or natural gas, would need to be a significant contributor to any reasonable 

18 alternative energy combination. 

19 Section 9.2.2.2 assumes the construction of four 675 MW(e) natural gas combined-cycle 

20 generating units at the STP site using the existing STP Main Cooling Reservoir (MCR). For a 

21 combined alternatives option, the review team assessed the environmental impacts of an 

22 assumed combination of three 675 MW(e) natural gas combined-cycle generating units at the 

23 STP site, and the following contributions from within STPNOC’s ROI: 50 MW(e) of hydropower 

24 (including a new reservoir), 250 MW(e) from biomass sources including municipal solid waste, 

25 175 MW(e) from additional conservation and demand-side management programs beyond what 

26 is currently planned, and 200 MW(e) from wind power. The demand-side management 

27 programs would be implemented by CPS Energy and/or Reliant Energy, a subsidiary of NRG 

28 Energy. Wind energy would need to be combined with an energy storage mechanism, such as 

29 CAES, to be a base-load resource. The review team believes that the preceding contributions 

30 are reasonable and representative for STPNOC’s ROI. The contributions reflect the review 

31 team’s analysis in Section 9.2. 

32 A summary of the review team’s characterizations of the environmental impacts associated with 

33 the construction and operation of the preceding assumed combination of alternatives is in 

34 Table 9-3 on the following page. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-28 March 2010

1 Table 9-3. Summary of Environmental Impacts of a Combination of Power Sources 

Impact Category Impact Comment

Land use MODERATE A natural gas-fired plant would have land-use impacts for the 

powerblock and connection to a natural gas pipeline. Wind, hydro, 

and biomass facilities and associated transmission lines would 

have land-use impacts in addition to the land-use impact of the 

natural gas-fired plant. Both offshore wind development and 

hydropower plants would potentially impede navigation. 

Air quality SMALL to 

MODERATE 

Emissions from the natural gas-fired plant would be approximately: 

SO2 – 31 tons/yr 

NOx – 510 tons/yr 

CO – 106 tons/yr 

PM2.5 – 89 tons/yr 

CO2 – 5.2 million tons/yr 

Municipal solid waste and biomass generation facilities would also 

have emissions. 

Water use and 

quality 

SMALL Impacts would be somewhat less that the impacts for new nuclear 

generating units located at the STP site. 

Ecology MODERATE Wind energy facilities in the Trans-Gulf migratory route could result 

in increased avian mortality and might also cause increased 

mortality of migratory and resident bats. Offshore wind power 

development would also affect avian and aquatic resources. 

Coastal bird populations could be subject to increased mortality. 

Hydropower facilities would affect terrestrial and aquatic habitat and 

species. 

Waste 

management 

SMALL to 

MODERATE 

The only significant waste would be from spent SCR catalyst used 

for control of NOx emissions and ash from biomass and municipal 

solid waste sources. 

Socioeconomics MODERATE 

Beneficial to 

SMALL 

Adverse 

Construction and operations workforces would be noticeable but 

not significant. Addition to property tax base, while smaller than for 

a nuclear or coal-fired plant, might still be quite noticeable. 

Construction-related beneficial economic impacts would be 

noticeable, but there likely would not be noticeable adverse impacts 

on community services or infrastructure because of the relatively 

small numbers of in-migrants. Impacts during operation would be 

minor because of the small workforce involved. The natural gasfired and biomass plants and wind turbines would have aesthetic 

impacts. 

Human health SMALL Regulatory controls and oversight are assumed to be protective of 

human health. 
 Environmental Impacts of Alternatives 

March 2010 9-29 Draft NUREG-1937 

1 Table 9-3. (contd) 

Impact Category Impact Comment

Historic and 

cultural resources 

SMALL Any potential impacts could likely be effectively managed. Most of 

the facilities and infrastructure at the STP site would likely be built 

on previously disturbed ground. 

Environmental 

justice 

 SMALL 

Adverse 

There are minority and low-income persons in the local population; 

air quality impacts to two populations could be noticeable but not 

disproportionate. 

2 9.2.5 Summary Comparison of Alternatives 

3 Table 9-4 on the following page contains a summary of the review team’s environmental impact 

4 characterizations for constructing and operating new nuclear, coal-fired, and natural gas-fired 

5 combined-cycle generating units at the STP site. The combination of alternatives shown in 

6 Table 9-4 assumes siting of natural gas combined-cycle generating units at the STP site and 

7 siting of other generating units within STPNOC’s ROI. 

8 The review team reviewed the available information on the environmental impacts of power 

9 generation alternatives compared to the building new nuclear units at the STP site. Based on 

10 this review, the review team concludes that, from an environmental perspective, none of the 

11 viable energy alternatives are clearly preferable to building a new baseload nuclear power 

12 generation plant at the STP site. 

13 Because of current concerns related to greenhouse gas emissions, it is appropriate to 

14 specifically discuss the differences among the alternative energy sources regarding carbon 

15 dioxide (CO2) emissions. The CO2 emissions for the proposed action and energy generation 

16 alternatives are discussed in Sections 5.7.1, 9.2.2.1, 9.2.2.2, and 9.2.4. Table 9-5 on the 

17 following page summarizes the CO2 emission estimates for a 40-year period for the alternatives 

18 considered by the review team to be viable for baseload power generation. These estimates 

19 are limited to the emissions from power generation and do not include CO2 emissions for 

20 workforce transportation, building fuel-cycle, or decommissioning. Among the viable energy 

21 generation alternatives, the CO2 emissions for nuclear power are a small fraction of the 

22 emissions of the other viable energy generation alternatives. Even adding in the transportation 

23 emissions for the nuclear plant workforce and fuel cycle emissions would increase the 

24 emissions for plant operation over a 40-year period to about 45,000,000 metric tons. This 

25 number is still significantly lower than the emissions for the other viable alternatives. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-30 March 2010

1 Table 9-4. Summary of Environmental Impacts of Construction and Operation of New Nuclear, 

2 Coal-Fired, and Natural Gas-Fired Generating Units, and a Combination of 

3 Alternatives 

Resource Area Nuclear Coal Natural Gas

Combination of 

Alternatives

Land use SMALL MODERATE SMALL MODERATE 

Air quality (criteria pollutants) SMALL MODERATE SMALL to 

MODERATE 

SMALL to 

MODERATE 

Water use and quality SMALL SMALL SMALL SMALL 

Ecology SMALL MODERATE SMALL MODERATE 

Waste management SMALL MODERATE SMALL SMALL to 

MODERATE 

Socioeconomics LARGE 

Beneficial to 

MODERATE 

Adverse 

LARGE 

Beneficial to 

MODERATE 

Adverse 

MODERATE 

Beneficial to 

SMALL 

Adverse 

MODERATE 

Beneficial to 

SMALL Adverse 

Human health SMALL SMALL SMALL SMALL 

Historic and cultural resources SMALL SMALL SMALL SMALL 

Environmental justice SMALL SMALL SMALL SMALL 

4 Table 9-5. Comparison of Carbon Dioxide Emissions for Energy Alternatives 

Generation Type Years 

CO2 Emission 

(metric tons) 

Nuclear Power(a) 40 20,000 

Coal-Fired Generation(b) 40 980,000,000 

Natural Gas-Fired Generation(c) 40 250,000,000 

Combination of Alternatives(d) 40 190,000,000 

(a) From Appendix I 

(b) From Section 9.2.2.1 

(c) From Section 9.2.2.2 

(d) From Section 9.2.4 (assuming only natural gas generation has significant CO2 emissions) 

5 The CO2 emissions associated with generation alternatives such as wind power, solar power, 

6 and hydropower would be associated with workforce transportation, construction, and 

7 decommissioning of the facilities. Because these generation alternatives do not involve 

8 combustion, the review team considers the emissions to be minor and concludes that the 

9 emissions would have a minimal cumulative impact. Other energy generation alternatives 

10 involving combustion of oil, wood waste, municipal solid waste, or biomass-derived fuels would 

11 have CO2 emissions from combustion as well as from workforce transportation, plant 

12 construction, and plant decommissioning. It is likely that the CO2 emissions from the 

13 combustion process for these alternatives would dominate the other CO2 emissions associated 
 Environmental Impacts of Alternatives 

March 2010 9-31 Draft NUREG-1937 

1 with the generation alternative. It is also likely that the CO2 emissions from these alternatives 

2 would be the same order of magnitude as the emissions for the fossil-fuel alternatives 

3 considered in Sections 9.2.2.1, 9.2.2.2, and 9.2.4. However, because the review team 

4 determined that these alternatives do not meet the need for baseload power generation, the 

5 review team has not evaluated the CO2 emissions quantitatively. 

6 As discussed in Chapter 8, the review team concludes that the need for additional baseload 

7 power generation has been demonstrated. Also, as discussed earlier in this chapter, the review 

8 team concludes that the viable alternatives to the proposed action all would involve the use of 

9 fossil fuels (coal or natural gas). Consequently, the review team concludes that the proposed 

10 action results in the lowest level of emissions of greenhouse gases among the viable 

11 alternatives. 

12 9.3 Alternative Sites 

13 9.3.1 Alternative Sites Selection Process 

14 NRC EISs prepared in conjunction with a COL application are to analyze alternatives to the 

15 proposed action [10 CFR 51.71(d)]. This section discusses STPNOC’s process for selecting its 

16 proposed and alternative sites and the review team’s evaluation of the process. STPNOC’s site 

17 selection process was based on guidance in the following documents (STPNOC 2009a): NRC’s 

18 Environmental Standard Review Plan (ESRP) (NRC 2000), Regulatory Guide 4.7 (NRC 1998), 

19 and the Electric Power Research Institute’s (EPRI) Siting Guide (EPRI 2002). 

20 NRC’s site selection process guidance calls for identification of an ROI followed by successive 

21 screening to candidate areas, potential sites, candidate sites, and the proposed site (NRC 2000, 

22 ESRP 9.3). STPNOC modified this process somewhat by adding an extra step of screening to 

23 primary sites after it had identified potential sites. 

24 The review team raised a number of concerns related to STPNOC’s site selection process and 

25 associated results submitted by STPNOC in the COL application (through revision 2 of the 

26 application) (STPNOC 2009a). The questions were documented in requests for additional 

27 information from the NRC dated May 19, 2008 (NRC 2008a), and November 18, 2008 

28 (NRC 2008b). As a result of these information requests, STPNOC revised its siting process and 

29 submitted it in Revision 3 to the ER (STPNOC 2009a) and in a separate Siting Report 

30 (STPNOC 2009b). The evaluation that follows is based on the revised site selection process 

31 documented in ER Revision 3. 

32 9.3.1.1 Selection of Region of Interest 

33 The ROI is the geographic area considered by an applicant in searching for candidate areas 

34 and potential sites for a new nuclear power plant (NRC 2000). STPNOC selected the land area 

35 included in the ERCOT grid as its ROI (STPNOC 2009a). ERCOT manages the flow of electric 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-32 March 2010

1 power to approximately 20 million Texas customers, which represents approximately 85 percent 

2 of the State’s electric load and 75 percent of the Texas land area (see Figure 8-1) (ERCOT 

3 2009). ERCOT is further discussed in Section 8.1 of this EIS. 

4 9.3.1.2 Selection of Candidate Areas 

5 Candidate areas are one or more areas within an applicant’s ROI that remain after unsuitable 

6 areas for a new nuclear power plant (e.g., due to high population, lack of water, fault lines, or 

7 distance to transmission lines) have been removed (NRC 2000). To screen the ROI for 

8 potential candidate areas, STPNOC used the following screening criteria: geology/seismicity, 

9 water availability, population, dedicated lands, and ecology (STPNOC 2009a). STPNOC 

10 determined that there are no areas within STPNOC’s ROI with predicted peak ground 

11 accelerations greater than 0.3 g. Therefore, the related criteria had no effect on site selection. 

12 The water availability criterion was the most influential criterion STPNOC used in screening the 

13 ROI (STPNOC 2009a). STPNOC looked for rivers where cooling makeup water would not 

14 exceed 10 percent of the average flow rate. STPNOC also assumed that water from the Gulf of 

15 Mexico would be a viable source of cooling water makeup. Urban population areas and special 

16 use lands (e.g., parks) owned by a governmental entity were excluded. Land within a critical 

17 habitat for Federally listed endangered species was also excluded. Using its screening criteria, 

18 STPNOC selected the following nine candidate areas within its ROI (STPNOC 2009a): 

19 1. The Nueces River below Choke Canyon Reservoir – approximately 85 river mi. 

20 2. The Guadalupe River below New Braunfels and the San Antonio River below Goliad – 

21 approximately 320 river mi. 

22 3. The Colorado River below San Saba (just above Lake Buchanan) – approximately 450 river 

23 mi. 

24 4. The Brazos River below South Bend (just above Possum Kingdom Lake) and the Little River 

25 below the town of Little River – approximately 685 river mi. 

26 5. The Trinity River below Dallas – approximately 200 river mi. 

27 6. The Neches River below Lake Palestine and the Angelina River below Alto – approximately 

28 185 river mi. 

29 7. The Sabine River below Mineola – approximately 60 river mi. 

30 8. The Sulphur River below Talco and the Red River below Burkburnett – approximately 435 

31 river mi. 

32 9. The Gulf Coast – approximately 230 coastal mi. 

33 The candidate areas are shown in Figure 9-1 on the following page. 
 Environmental Impacts of Alternatives 

March 2010 9-33 Draft NUREG-1937 

1 

2 Figure 9-1. Candidate Areas (STPNOC 2009a) 

3 9.3.1.3 Selection of Potential Sites 

4 Potential sites are those sites within a candidate area that have been identified by an applicant 

5 for preliminary assessment in establishing candidate sites (NRC 2000). STPNOC applied the 

6 following criteria in selecting potential sites (STPNOC 2009a): 

7 • Distance to existing rail lines: The distance to existing rail lines was minimized to the extent 

8 possible. 

9 • Distance to existing transmission lines: The distance to existing 345-kV transmission lines 

10 was minimized to the extent possible. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-34 March 2010

1 • Distances from towns, villages, and developed areas (commercial and residential) were 

2 maximized. Developed areas were identified from regional screening, satellite imagery, and 

3 county and topographic maps. 

4 • Distance from industrial areas: The distance from industrial areas identifiable from the aerial 

5 photographs and topographic maps (e.g., airports and industrial complexes) was maximized 

6 except when an existing power plant site was being considered. 

7 • Water availability: STPNOC considered the following factors: 

8 – Proximity to cooling water supply: Distance to the potential cooling water source was 

9 minimized to extent possible. 

10 – Existing lakes or reservoirs: Whenever possible, lands around existing lakes and 

11 reservoirs were evaluated as possible potential sites. 

12 – Construction of new reservoirs: If existing lakes or reservoirs were not in areas of 

13 interest, the topography of the land was qualitatively evaluated for the construction of a 

14 new reservoir. 

15 • Topography: The optimal topography was assumed by STPNOC to be: (1) a relatively flat 

16 area, (2) above the 100-year floodplain, and (3) adjacent to streams with surrounding 

17 topography conducive to the construction of a reservoir. Topographic maps and aerial 

18 photographs were qualitatively examined to find areas as close to this ideal as possible. 

19 • Land use: Nominal site areas encompassing a consistent land-use pattern were considered 

20 most suitable, with preference to lands that showed no current development but signs of 

21 previous disturbance (e.g., recently timbered forest or pasture land). Such patterns were 

22 assumed to be associated with fewer landowners (preferred) and less challenges in land 

23 acquisition. Land owned by the applicant and known availability of land were not used as 

24 criteria. 

25 • Transportation: Access to the potential sites was qualitatively evaluated. Areas around 

26 major highways were avoided. Areas within a reasonable distance of state highways were 

27 considered. 

28 STPNOC identified 33 potential sites using professional judgment and the preceding criteria. 

29 The potential sites are shown in Figure 9-2 on the following page. 

30 9.3.1.4 Selection of Primary Sites 

31 STPNOC screened its 33 potential sites to identify a smaller set of primary sites for more 

32 detailed evaluation. Criteria used in the screening included cooling water supply, flooding 

33 potential, population, hazardous land uses, ecology, wetlands, heavy haul access, transmission 

34 access, and land acquisition. The criteria were derived from a larger set of more detailed 

35 criteria in EPRI (2002) (STPNOC 2009a). 
 Environmental Impacts of Alternatives 

March 2010 9-35 Draft NUREG-1937 

1 

2 Figure 9-2. Potential Sites (STPNOC 2009a) 

3 STPNOC developed weighting factors reflecting the relative importance of each of the criteria. 

4 The factors were developed by a multi-disciplinary committee familiar with the subject area of 

5 nuclear power plant site suitability. The committee was comprised of subject matter experts in 

6 water use and availability, engineering and licensing, real estate, ecology and environment, 

7 transmission, land use, health and safety, geotechnical, socioeconomics, and public relations. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-36 March 2010

1 The weighting factors were derived using a methodology consistent with the modified Delphi 

2 process specified in EPRI (2002) (STPNOC 2009a). 

3 STPNOC next assigned a rating of 1 to 5 (1 = least suitable; 5 = most suitable) for each criterion 

4 at each potential site. STPNOC’s information sources for assigning the ratings included publicly 

5 available data, information available from STPNOC files and personnel, and large scale satellite 

6 photographs. Composite suitability ratings reflecting the overall suitability of each potential site 

7 were then developed by multiplying the ratings by the criterion weight factors and summing over 

8 all criteria for each potential site (STPNOC 2009a). STPNOC’s results are shown in Figure 9-3 

9 below (STPNOC 2009a). 

10 

11 

12 Figure 9-3. Screening Criteria Evaluation Results (STPNOC 2009a) 

13 Based on the results, STPNOC selected the nine highest rated sites as its primary sites for 

14 further evaluation. The location of the nine primary sites is shown in Figure 9-4 on the following 

15 page. 
 Environmental Impacts of Alternatives 

March 2010 9-37 Draft NUREG-1937 

1 

2 Figure 9-4. Primary Sites (STPNOC 2009a) 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-38 March 2010

1 9.3.1.5 Selection of Candidate Sites 

2 STPNOC screened its nine primary sites to identify four candidate sites. Candidate sites are 

3 those potential sites within the ROI that are considered in the comparative evaluation of sites to 

4 be among the best that can reasonably be found for the siting of a nuclear power plant (NRC 

5 2000). 

6 In selecting candidate sites, STPNOC followed a similar, but more detailed, process to that used 

7 to identify primary sites. STPNOC derived more than 30 siting criteria from criteria in EPRI 

8 (2002). The criteria are listed in Table 9-6 on the following page (STPNOC 2009b). Weighting 

9 Factors were developed using the same process as STPNOC used for the screening of 

10 potential sites. The siting criteria and weighting factors used by STPNOC to screen primary 

11 sites to candidate sites were not the same as those used to screen potential sites to primary 

12 sites. 

13 Each primary site was assigned a rating of 1 to 5 (1 = least suitable; 5 = most suitable) for each 

14 of the siting criteria. Similar to the screening of potential sites, STPNOC’s information sources 

15 for assigning the ratings included publicly available data, information available from STPNOC 

16 files and personnel, and large scale satellite photographs. Composite suitability ratings 

17 reflecting the overall suitability of each primary site were then developed by multiplying criterion 

18 ratings by the criterion weight factors and summing over all criteria for each site. STPNOC’s 

19 computed composite ratings for the nine primary sites are shown in Table 9-7 (STPNOC 

20 2009a). 

21 To provide additional insights on the environmental preferability of the nine primary sites, two 

22 additional indicators were used by STPNOC. 

23 • Environmental Site Rating – This rating consisted of the Health and Safety Criteria (minus 

24 the Geology/Seismology criterion), the Environmental Criteria, and the Socioeconomic 

25 Criteria. The top sites based on this rating were STP, Red 1, Red 2, Trinity 2, and Allens 

26 Creek/Guadalupe 2, with no significant difference between Allens Creek and Guadalupe 2. 

27 • Expanded Environmental Site Rating – This rating consisted of the Environmental Site 

28 Rating plus the Railroad Access and Transmission Access criteria, which reflect a rough 

29 proxy of environmental impact through measurement of the relative distances required for 

30 these support facilities. The top sites based on this rating were STP, Red 2, Trinity 2, 

31 and Allens Creek, with no significant difference between Allens Creek, Red 1, and 

32 Colorado 3. 
 Environmental Impacts of Alternatives 

March 2010 9-39 Draft NUREG-1937 

1 Table 9-6. Criteria for Selection of Candidate Sites 

Health and Safety Environmental Socioeconomic Engineering and Cost 

Accident cause related 

1. Geology and 

seismology 

2. Cooling system 

requirements 

3. Flooding potential 

4. Nearby hazardous land 

uses 

5. Extreme weather 

conditions 

Construction related 

effects on aquatic 

ecology 

1. Disruption of 

important species 

and habitats 

2. Bottom sediment 

disruption effects 

Construction 

related effects 

Health and Safety Related 

Criteria 

1. Water supply 

2. Pumping distance 

3. Flooding 

4. Civil works 

Accident effects 

1. Population 

2. Emergency planning 

3. Atmospheric dispersion 

Construction related 

effects on terrestrial 

ecology 

1. Disruption of 

wetlands and 

important species 

and habitats 

2. Dewatering effects 

on adjacent lands 

Environmental 

justice 

Transportation and 

transmission access 

1. Railroad 

2. Highway 

3. Barge 

4. Transmission 

Operational effects 

1. Surface water 

radionuclide pathway 

2. Groundwater 

radionuclide pathway 

3. Air radionuclide 

pathway 

4. Air food ingestion 

pathway 

5. Surface water food 

indigestion pathway 

6. Transportation safety 

Operational related 

effects on aquatic 

ecology 

1. Thermal discharge 

effects 

2. Entrainment and 

impingement 

effects 

3. Dredging and 

disposal effects 

Land use Socioeconomic and land 

use 

1. Topography 

2. Land rights 

3. Labor rates 

 Operational related 

effects on terrestrial 

ecology 

1. Drift effects on 

surrounding areas 

 

Source: STPNOC 2009b 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-40 March 2010

1 Table 9-7. Composite Ratings for the Primary Sites 

Site 

Composite 

Rating Score 

STP 735.4 

Red 2 611.8 

Allens Creek 597.5 

Colorado 3 595.8 

Trinity 2 590.1 

Guadalupe 2 586.0 

Malakoff 574.1 

Red 1 573.2 

Sulphur 1 539.9 

Source: STPNOC 2009a 

2 STPNOC’s evaluation showed that while the Colorado 3 site ranked fourth overall in composite 

3 rating, it did not rank as high in the environmentally related criteria ratings. Additionally, the 

4 Guadalupe 2 site, ranked sixth in the composite ratings, but did not rank high in the 

5 environmentally related criteria. These two sites, along with the three lowest ranked sites, were 

6 eliminated by STPNOC from further consideration. Thus, the following sites were identified by 

7 STPNOC as its candidate sites: 

8 • STP 

9 • Red 2 

10 • Allens Creek 

11 • Trinity 2. 

12 STPNOC selected the STP site as its proposed site, relying on ESRP 9.3 (NRC 2000), which 

13 recognizes that there will be special cases in which the proposed site was not selected on the 

14 basis of a systematic site selection process. One example cited in ESRP 9.3 is the siting of a 

15 proposed nuclear plant on the site of an existing nuclear power plant previously found 

16 acceptable on the basis of a NEPA review. The proposed site is then compared to alternative 

17 sites identified through a systematic process. 

18 9.3.1.6 Evaluation of STPNOC’s Site Selection Process 

19 The review team evaluated the methodology used by STPNOC to select its proposed and 

20 alternative sites. The ROI selected by STPNOC covers a largely isolated grid system (ERCOT) 

21 that encompasses a large and ecologically varied area. Use of such an area is consistent with 

22 the guidance in ESRP 9.3 (NRC 2000). STPNOC then established candidate areas based on a 

23 group of exclusionary criteria similar to those described in ESRP 9.3. Next STPNOC identified 

24 potential sites within the candidate areas based on qualitative criteria, and then narrowed the list 

25 of sites using more detailed criteria to identify what it refers to as primary sites. Finally, 

26 STPNOC used more specific criteria to evaluate the primary sites and identify the alternative 
 Environmental Impacts of Alternatives 

March 2010 9-41 Draft NUREG-1937 

1 sites. Based on its review of STPNOC’s site selection process and the guidance in ESRP 9.3 

2 (NRC 2000), the review team concludes that STPNOC’s process for selecting its ROI, candidate 

3 areas, potential sites, primary sites, candidate sites, and the proposed STP site was reasonable 

4 and did not arbitrarily exclude locations that might be suitable choices for siting two new nuclear 

5 generating units to satisfy the need for power identified in Chapter 8. 

6 The three alternative sites examined in detail in Section 9.3 are the Red 2 site in Fannin County, 

7 the Allens Creek site in Austin County, and the Trinity 2 site in Freestone County. The review 

8 team visited each of the three alternative sites, as well as the proposed site. The review team 

9 used information in STPNOC’s ER related to the three alternative sites and also independently 

10 collected and analyzed reconnaissance-level information for each of the alternative sites using 

11 ESRP 9.3 (NRC 2000) as guidance. 

12 In the discussion of the alternative sites that follows, the review team evaluated cumulative 

13 impacts of building and operating two new nuclear units at each site for each resource category, 

14 considering the impacts of other nearby projects on that resource. Included in the cumulative 

15 analysis are past, present, and reasonably foreseeable Federal, non-Federal, and private 

16 actions that could have meaningful cumulative impacts with the proposed action. For purposes 

17 of this analysis, the past is defined as the time period before receipt of the COL application. 

18 The present is defined as the time period from the receipt of the COL application until the start 

19 of building proposed Units 3 and 4. The future is defined as the start of building Units 3 and 4 

20 through operation and eventual decommissioning. 

21 Using Chapter 7 as a guide, the specific resources and components that could be affected by 

22 the incremental effects of the proposed action if implemented at the alternative site and other 

23 actions in the same geographic area were identified. The affected environment that serves as 

24 the baseline for the cumulative impacts analysis is described for each alternative site and 

25 includes a qualitative discussion of the general effects of past actions. For each resource area, 

26 the geographic area over which past, present, and future actions could reasonably contribute to 

27 cumulative impacts is defined and described in later sections. The analysis for each resource 

28 area at each alternative site concludes with a cumulative impact finding (SMALL, MODERATE, 

29 or LARGE). For those cases in which the impact level to a resource was greater than SMALL, 

30 the review team also discussed whether building and operating the nuclear units would be a 

31 significant contributor to the cumulative impact. In the context of this evaluation, “significant” is 

32 defined as a contribution that is important in reaching that impact level determination. 

33 The impacts described in Chapter 6 (e.g., nuclear fuel cycle; decommissioning) would not vary 

34 significantly from one site to another. This is true because all of the alternative sites and the 

35 proposed site are in low-population areas and because the review team assumes the same 

36 reactor design (therefore, the same fuel cycle technology, transportation methods, and 

37 decommissioning methods) for all of the sites. As such, these impacts would not differentiate 

38 between the sites and would not be useful in the determination of whether an alternative site is 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-42 March 2010

1 environmentally preferable to the proposed site. For this reason, these impacts are not 

2 discussed in the evaluation of the alternative sites. 

3 The cumulative impacts are summarized for each resource area at each site in the sections that 

4 follow. The level of detail is commensurate with the significance of the impact for each resource 

5 area. The findings for each resource area at each alternative site then are compared in 

6 Table 9-20 at the end of this section to the cumulative impacts at the proposed site (brought 

7 forward from Chapter 7). The results of this comparison are used to determine if any of the 

8 alternative sites are environmentally preferable to the proposed site. 

9 9.3.2 Red 2 

10 This section covers the review team’s evaluation of the potential environmental impacts of siting 

11 a new two-unit nuclear power plant at the Red 2 site in northeastern Texas near the Oklahoma 

12 border. The site is located in a rural area of Fannin County 3.7 mi north of Savoy and 12.2 mi 

13 southeast of Denison, on the north side of Valley Lake. The Red River, located 3.7 mi to the 

14 north of the site, would be the source for water for plant cooling and other plant uses, and 

15 construction of a new water storage reservoir would be required. Red 2 is a greenfield site not 

16 currently owned by the applicant (STPNOC 2009a). 

17 The following sections include a cumulative impact assessment conducted for each major 

18 resource area. The specific resources and components that could be affected by the 

19 incremental effects of the proposed action if implemented at the Red 2 site and other actions in 

20 the same geographic area were considered. This assessment includes the impacts of NRC21 authorized construction and operations and impacts of preconstruction activities. Also included 

22 in the assessment are past, present and reasonably foreseeable future Federal, non-Federal, 

23 and private actions that could have meaningful cumulative impacts when considered together 

24 with the proposed action if implemented at the Red 2 site. Other actions and projects 

25 considered in this cumulative analysis are described in Table 9-8. 
 Environmental Impacts of Alternatives 

March 2010 9-43 Draft NUREG-1937 

1 Table 9-8. Past, Present, and Reasonably Foreseeable Projects and Other Actions Considered 

2 in the Cumulative Analysis of the Red 2 Alternative Site 

Project Name Summary of Project 

Location 

(relative to Red 2 site) Status 

Energy Projects 

Valley Power Plant Three gas-fired generation units 

with total installed capacity of 1115 

MW 

About 1.8 mi south of 

Red 2 site 

Operational(a)

Pattillo Branch Power 

Plant 

Four new gas-fired turbines with 

total installed capacity of 1400 MW 

Approximately 3 mi 

south of Red 2 site 

Proposed. Air 

Permit issued 

June 17, 2009(b)

Mining Projects 

Trinity Materials 

(Hendrix Mine) 

Construction sand & gravel mine About 12 mi northwest 

of Red 2 site 

Operational(c)

Parks

Caddo-LBJ National 

Grasslands 

National grasslands managed by 

the U.S. Department of Agriculture 

About 14 mi northeast 

of Red 2 site 

Development 

likely limited 

within this 

area(d)

Other 

Actions/Projects:

 

City of Bells Sewage treatment facility About 3 mi southwest 

of Red 2 site 

Operational(e) 

City of Denison – 

Paw Paw wastewater 

treatment plant 

Sewage treatment facility About 11 mi northwest 

of Red 2 site 

Operational(f) 

Lake Ralph Hall Water storage for municipal use 

and for recreation 

About 30 mi southeast 

of Red 2 site 

Proposed(g) 

Lower Bois d'Arc 

Creek Reservoir 

Water storage for municipal use 

and for recreation 

About 20 mi east of 

Red 2 site 

Proposed. 

Construction is 

planned to begin 

in 2015 and take 

three years to 

complete(h) 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-44 March 2010

1 Table 9-8. (contd) 

Project Name Summary of Project 

Location 

(relative to Red 2 site) Status 

Future Urbanization Construction of housing units and 

associated commercial buildings; 

roads (such as the expansion of 

I-75), bridges, and rail; construction 

of water- and/or wastewatertreatment and distribution facilities 

and associated pipelines, as 

described in local land-use 

planning documents. 

Throughout region Construction 

would occur in 

the future, as 

described in 

state and local 

land-use 

planning 

documents 

Various hospitals 

and industrial 

facilities that use 

radioactive 

materials 

Medical and other isotopes Within 50 mi Operational in 

nearby cities 

and towns 

(a) Source: EPA 2009o 

(b) Source: TCEQ 2009e 

(c) Source: EPA 2009i 

(d) Source: USFS 2009 

(e) Source: EPA 2009j 

(f) Source: EPA 2009k 

(g) Source: UTRWD 2010 

(h) Source: North Texas Municipal Water District 2009 2 

3 The STP site is more than 300 mi from the Red 2 site and was therefore not included in this 

4 analysis. The only other nuclear power plant currently operating in Texas is Comanche Peak. 

5 The Comanche Peak plant is more than 120 mi from the Red 2 site and therefore is also not 

6 included in the cumulative impact analysis. The proposed nuclear power plant in Victoria 

7 County is approximately the same distance as the STP site and was not included in the 

8 cumulative impact analysis. 

9 9.3.2.1 Land Use 

10 The following impact analysis includes impacts from building activities and operations. The 

11 analysis also considers other past, present, and reasonably foreseeable future actions that 

12 impact land use, including other Federal and non-Federal projects listed in. For this analysis, 

13 the geographic area of interest for considering cumulative impacts is the 15-mi region 

14 surrounding the Red 2 site. This geographic area of interest was selected to include the primary 

15 communities (e.g., Denison) that would be affected by the proposed project if it were located at 

16 the Red 2 site. Figure 9-5 on the following page shows the location of the Red 2 site and 

17 surrounding communities. 

18 The Red 2 site is located in a rural, mostly cleared agricultural area. There is no current zoning 

19 applicable to the site. There are several residences in the area and a school is located in 
 Environmental Impacts of Alternatives 

March 2010 9-45 Draft NUREG-1937 

1 

2 Figure 9-5. Red 2 Alternative Site and 10-mi Radius
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-46 March 2010

1 Savoy. STPNOC estimates that approximately 47 percent of the site is forested, 51 percent is 

2 in cropland, and 2 percent is water resources (STPNOC 2009a). A rail spur is approximately 

3 4 mi from the site (STPNOC 2009a). The Red 2 site is not owned by the applicants and 

4 acquisition of the site for a new power plant would involve land purchase from more than one 

5 land owner. 

6 The Red 2 site is not in the geographic area covered by the Texas Coastal Management 

7 Program (TCMP 2009); therefore, the Coastal Zone Management Act (CZMA) does not apply to 

8 this site. 

9 The Red 2 site is located 1.8 mi north of the Valley Power Plant owned by Luminant Power 

10 (STPNOC 2009a). The Valley Power Plant is a three-unit, 1115-MW, natural gas-fired plant 

11 (Luminant 2009). Cooling water for Valley Power Plant comes from Valley Lake. Valley Lake 

12 has a surface area of approximately 1180 ac and is on Brushy Creek, a tributary to the Red 

13 River. Construction of Valley Dam, which formed Valley Lake, was completed in 1961 (TSHA 

14 2009a). The Red 2 site is on the north side of Valley Lake. 

15 If new nuclear generating units were built at the Red 2 site, the review team assumes that an 

16 onsite water storage reservoir for plant cooling would be built. Water would be diverted from the 

17 Red River. The land area affected by building two nuclear generating units at the Red 2 site 

18 would be approximately 800 ac for the main power plant site and up to 1700 ac for a new 

19 reservoir (STPNOC 2009a). Land-use impacts would also occur as a result of pipeline building 

20 to divert water to the plant and/or a reservoir and return discharge water to the Red River and 

21 for road and rail access. Most land-use impacts would occur during building, while plant 

22 operations would have minimal land-use impacts. The land-use impacts associated with 

23 building the plant and the reservoir at the Red 2 site would be noticeable, but not destabilizing. 

24 There are no existing transmission corridors connecting directly to the Red 2 site. However, 

25 there are multiple 345-kV transmission lines connecting to the Valley Power Plant (STPNOC 

26 2009a). One or more new transmission corridors would need to be created to connect the Red 

27 2 site to these lines. The corridor(s) would pass through areas that are mostly rural with low 

28 population densities. Farmlands that would become part of a corridor could generally continue 

29 to be farmed. The land-use impacts of building one or more transmission corridors to serve the 

30 Red 2 site would be minimal. 

31 Within the 15-mi geographic area of interest, the reasonably foreseeable future project with the 

32 greatest potential to affect cumulative land use would be the Pattillo Branch Power Plant (see 

33 Table 9-8). If constructed, the Plant would be located approximately 3 mi south of the Red 2 

34 site. If the Pattillo Branch Power Plant is constructed, one or more new transmission corridors 

35 would be needed to connect the plant to the grid. 
 Environmental Impacts of Alternatives 

March 2010 9-47 Draft NUREG-1937 

1 Future urbanization, the continued operation of the Trinity Materials Hendrix Mine, and global 

2 climate change (GCC) (see Table 9-8) could contribute to decreases in open lands, wetlands, 

3 and forested areas. Urbanization in the vicinity of the Red 2 site would alter important attributes 

4 of land use. Urbanization would reduce natural vegetation and open space, resulting in an 

5 overall decline in the extent and connectivity of wetlands, forests, and wildlife habitat. 

6 Continued operation of the Trinity Materials Hendrix Mine could include expansion of the mine 

7 at some point in the future. Potential expansion of the mine would result in a loss of open lands, 

8 forests, and wetlands. GCC could decrease precipitation causing more frequent droughts when 

9 combined with increased evaporation in the geographic area of interest for the Red 2 site (Karl 

10 et al. 2009). Therefore, a reduced water supply combined with increased temperatures could 

11 reduce crop yields and livestock productivity (Karl et al. 2009), which might change portions of 

12 agricultural and ranching land uses in the area of interest. However, existing parks, reserves, 

13 and managed areas would help preserve open lands, wetlands, and forested areas, to the 

14 extent that they are not adversely affected by more droughts. Future urbanization trends and 

15 direct changes resulting from GCC could noticeably alter land uses in the geographic area of 

16 interest. 

17 Based on the information provided by STPNOC and the review team’s independent review, the 

18 review team concludes that the cumulative land-use impacts of constructing and operating two 

19 new nuclear generating units at the Red 2 site would be MODERATE. This conclusion reflects 

20 the substantial amount of land (up to 2500 ac onsite and additional offsite land for roads, a 

21 railroad spur, and pipelines) that would be needed for the proposed project, the land-use 

22 impacts associated with the proposed Pattillo Branch Power Plant, and the land needed to 

23 connect new units at the Red 2 site and the Pattillo Branch Power Plant to the electrical grid, 

24 and land use changes from increased urbanization and GCC. Building and operating two new 

25 nuclear units at the Red 2 site would be a significant contributor to the MODERATE impact. 

26 9.3.2.2 Water Use and Quality 

27 The following impact analysis includes impacts from building activities and operations. The 

28 analysis also considers other past, present, and reasonably foreseeable future actions that 

29 impact water use and quality, including other Federal and non-Federal projects listed in Table 9-

30 8. Geographic areas of interest are (1) for surface water the drainage basin of the Red River 

31 upstream and downstream of the site, and (2) for groundwater the aquifers upgradient and 

32 downgradient of the site. These regions are of interest because they represent the water 

33 resource potentially affected by the proposed project if it were located at the Red 2 site. 

34 The Red 2 site is located in Fannin County in northeastern Texas near the Oklahoma border, 

35 3.7 mi south of the Red River. The Red 2 site is on the north side of Valley Lake; however, the 

36 water of Valley Lake is not available for use. To support operation of the proposed units if they 

37 were to be placed at the Red 2 site, a new water storage reservoir on the site would be 

38 required. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-48 March 2010

1 As stated in Section 2.3.2, water use in Texas is regulated by the Texas Water Code. As 

2 established by Texas Water Code, surface water belongs to the State of Texas (Texas Water 

3 Code, Chapter 11, Section 11.021). The right to use surface waters of the State of Texas may 

4 be acquired in accordance with the provisions of the Texas Water Code, Chapter 11. In Texas, 

5 surface water is a commodity. Since the Red River Basin is currently heavily appropriated, 

6 future water users in this basin would likely only obtain surface water by purchasing or leasing 

7 existing appropriations. Regarding groundwater, Texas law has allowed landowners to pump 

8 the water beneath their property without consideration of impacts to adjacent property owners 

9 (NRC 2009b). However, Chapter 36 of Texas Water Code authorized groundwater 

10 conservation districts to help conserve groundwater supplies and issue groundwater permits. 

11 Chapter 36, Section 36.002, Ownership of Groundwater, states that ownership rights are 

12 recognized and that nothing in the code shall deprive or divest the landowners of their 

13 groundwater ownership rights, except as those rights may be limited or altered by rules 

14 promulgated by a district. Thus, groundwater conservation districts with their local constituency 

15 offer groundwater management options (NRC 2009b). Existing projects in the State have 

16 appropriations to use water for their requirements. The review team expects that future 

17 projects, including the proposed units, if they were to be built and operated at the Red 2 site, 

18 would operate within the limits of these existing surface water and groundwater appropriations. 

19 As stated in Section 7.2.1, the U.S. Global Change Research Program (GCRP), a Federal 

20 Advisory Committee, has compiled the state of knowledge in climate change. This compilation 

21 has been considered in the preparation of this EIS. The projections for changes in temperature, 

22 precipitation, droughts, and increasing reliance on aquifers within the Red River Basin are 

23 similar to those in the Colorado River Basin (Karl et al. 2009). Such changes in climate would 

24 result in adaptations to both surface water and groundwater management practices and policies 

25 that are unknown at this time. 

26 There are currently 249 water rights owners in the Red River Basin, with total water rights of 

27 456,000 ac-ft/yr that are categorized as industrial, irrigation, or mining users (TCEQ 2009a). 

28 According to the TCEQ’s water availability maps, unappropriated flows in the Red River Basin 

29 for a perpetual water rights permit are available 0 to 25 percent of the time (TCEQ 2009b). The 

30 water availability maps do not show the quantity of available water for a new appropriation 

31 (TCEQ 2009b). 

32 The average groundwater use in Fannin County from 1980-1999 is approximately 3168 ac-ft/yr 

33 and the predicted future groundwater use during 2000-2025 is approximately 2622 ac-ft/yr 

34 (Harden and Associates, Inc. 2007). Large water level declines in the Woodbine Aquifer due to 

35 heavy pumping in the past have resulted in suppliers switching to surface water and decreased 
 Environmental Impacts of Alternatives 

March 2010 9-49 Draft NUREG-1937 

future demand (TWDB 2006a). The estimated managed available groundwater(a) 1 for the 

2 Woodbine Aquifer in the Fannin County is 2676 ac-ft/yr (Wade 2008). 

3 Building Impacts

4 The review team assumed that no surface water would be used to build the proposed units at 

5 the Red 2 site so there would be no impact on surface water use. This assumption is consistent 

6 with the analysis done for the STP site and the other alternative sites. 

7 The impacts on surface water quality from building potential units at the Red 2 alternative site 

8 would be limited to stormwater runoff that may enter nearby streams and rivers. Additionally, 

9 treated sanitary wastewater may be discharged to these streams and rivers. Building impacts 

10 would be limited by the duration of these activities, and therefore, would be temporary. The 

11 State of Texas prohibits the unauthorized discharge of waste into or adjacent to water in the 

12 state (Texas Water Code, Chapter 26, Section 26.121). The discharge of waste may be 

13 authorized under a general or individual permit (Texas Water Code, Chapter 26). These 

14 permits may require a stormwater pollution prevention plan (SWPPP) that includes BMPs 

15 appropriate for the site (TCEQ 2003; STPNOC 2009a). Implementation of BMPs should 

16 minimize impacts to wetlands and surface-water bodies near the Red 2 alternative site. 

17 Therefore, the water quality impacts on wetlands and water bodies near the Red 2 alternative 

18 site related to building the proposed units would be temporary and minimal. 

19 The review team assumes that the groundwater use for building activities at the Red 2 site 

20 would be identical to the proposed groundwater use for the STP site (STPNOC 2009b) because 

21 the site would utilize units similar to those proposed for the STP site and the building activities 

22 would also be similar. Monthly normalized groundwater use for the STP site ranges up to 

23 491 gpm (792 ac-ft/yr) (Table 3-4 in Chapter 3). STPNOC stated that groundwater would be 

24 used for potable and sanitary use, concrete batch plant operation, concrete curing, dust 

25 suppression and cleaning, placement of engineered backfill, and piping hydrotests and flushing 

26 (STPNOC 2009a). 

27 The Red 2 alternative site is located in the Texas Groundwater Management Area (GMA) 8 and 

28 the Red River Groundwater Conservation District (RRGCD). The RRGCD started its operations 

29 on September 1, 2009. As of January 2010, the RRGCD has not published any rules or 

30 permitting requirements for groundwater use in the district. GMA 8, however, has established a 

desired future condition(b) 31 for average drawdown in Fannin County to not exceed 186 ft from the 

32 estimated groundwater elevations in 2000 after 50 years of use (TWDB 2009). 

 

(a) Managed available groundwater is the volume of groundwater available for permitting and withdrawal that would 

support the desired future conditions established by a groundwater management authority (GMA). 

(b) A desired future condition is a metric that specifies the future value of the related aquifer characteristic such as 

groundwater elevation, groundwater quality, spring flow, and others that may be deemed suitable by a GMA. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-50 March 2010

1 If the estimated groundwater demand during building of the proposed units at the Red 2 

2 alternative site were to be obtained using a new groundwater permit, this groundwater use 

3 would constitute approximately 30 percent of the managed available groundwater from the 

4 Woodbine Aquifer in Fannin County. However, STPNOC stated (STPNOC 2009b) that 

5 groundwater from the Trinity Aquifer is also available, that access to groundwater production 

6 from existing wells would be sought before requesting new or future groundwater capacity, and 

7 that water could be imported primarily for potable uses and thereby reduce groundwater 

8 demand. 

9 Since the duration of building activities is approximately five years, the review team considers 

10 these impacts to be temporary. A potential plant at the Red 2 alternative site could use a large 

11 fraction of the available groundwater resource during that period. Assuming a new groundwater 

12 permit were issued and based on the magnitude of this use and the potential for substantial 

13 drawdown, the review team concludes that the impact on the groundwater resource associated 

14 with the building of the facilities at the Red 2 alternative site would be noticeable but temporary 

15 and not sufficient to destabilize the groundwater resource. 

16 During the building of a potential plant at the Red 2 alternative site, impacts to groundwater 

17 quality may occur from leaching of spilled effluents into the subsurface and intrusion of lower18 quality water of the Red River into the Woodbine Aquifer. STPNOC stated that BMPs would be 

19 in place during building activities (STPNOC 2009a). Therefore the review team concludes that 

20 any spills would be quickly detected and remediated. The amount of drawdown in the 

21 Woodbine Aquifer from groundwater pumping during building should support established 

22 desired future conditions. The drawdown could be limited by installing multiple, appropriately23 spaced wells. The review team concluded that the drawdown in the Woodbine Aquifer could be 

24 managed during building-related groundwater pumping using an appropriately designed well 

25 system. In addition, building impacts will be limited by the duration of these activities and, 

26 therefore, would be temporary. Because any spills would be quickly remediated, drawdown in 

27 the Woodbine Aquifer would be controlled, and the activities would be temporary, the review 

28 team concludes that the groundwater-quality impacts from building at the Red 2 site would be 

29 minimal. 

30 Operational Impacts

31 STPNOC estimated that a two-unit plant operated at the Red 2 alternative site using a closed32 cycle cooling system that would employ a cooling water reservoir would consume a maximum of 

33 50,000 ac-ft of water per year. STPNOC has proposed the Red River as the source of the 

34 cooling water at the Red 2 alternative site. STPNOC currently does not own the necessary 

35 water rights. STPNOC proposes to acquire existing Texas Red River water rights that are 

36 currently being used for industrial, irrigation, and mining use. Therefore, STPNOC would need 

37 to acquire a minimum of 11 percent of these Texas water rights. 
 Environmental Impacts of Alternatives 

March 2010 9-51 Draft NUREG-1937 

1 According to TCEQ, acquired water rights, as proposed by STPNOC, would have to be 

2 aggregated at a single point of diversion which may lead to concerns regarding instream flow to 

3 maintain water quality and habitat. The TCEQ staff stated that, under current Texas laws, the 

4 acquisition and aggregation process would need to consider the quantity and location of all 

5 water rights and the instream flow needs that may be affected by transfer of these water rights 

6 (NRC 2009b). Additionally, the waters of the Red River are shared by Texas, Oklahoma, 

7 Arkansas, and Louisiana under the Red River Compact (TCEQ 2009c). Because STPNOC has 

8 not identified the particular water rights that may be acquired, it is difficult to determine if any are 

9 suitable for acquisition. However, the review team expects that the TCEQ permitting process 

10 would require STPNOC to acquire water rights in sufficient quantity, at appropriate locations, 

11 and of appropriate type within the Red River Basin such that this reallocation of water rights 

12 would not adversely affect surface water use and quality in the basin. As such, based on the 

13 water rights that would need to be reallocated to accommodate the facility at the Red 2 site, the 

14 review team determines that the operational surface water use impact of potential units at the 

15 Red 2 alternative sites would be noticeable but not destabilizing. 

16 During the operation of a potential plant at the Red 2 alternative site, impacts to surface water 

17 quality could result from stormwater runoff, discharges of treated sanitary and other wastewater, 

18 blowdown from service water cooling towers, and periodic discharges from the cooling water 

19 reservoir into the receiving water body. As mentioned above, the State of Texas may require 

20 STPNOC to obtain a general or individual permit for the discharge of stormwater (Texas Water 

21 Code, Chapter 26). These permits may require an SWPPP that includes BMPs appropriate for 

22 the site (TCEQ 2001; STPNOC 2009a). Any discharges of sanitary and other wastewaters and 

23 blowdown or cooling water reservoir discharges would be controlled by the State of Texas under 

24 a TPDES permit. The State of Texas limits the quantity and quality of discharges to surface 

25 water bodies while accounting for concurrent streamflow and quality conditions within the 

26 surface water body. These permit conditions would also account for designated uses of the 

27 receiving surface water body. The review team expects that the conditions placed on 

28 operations of the proposed units at the Red 2 site would be similar to those currently placed on 

29 the existing facilities at the STP site (Section 5.2.3.1). Therefore, the review team concluded 

30 that the operational impact on surface water quality of the receiving water body would be 

31 minimal because the discharge quantity and quality would be controlled. 

32 The proposed Units 3 and 4 would use approximately 975 gpm (1572 ac-ft/yr) of groundwater 

33 during normal operations and approximately 3434 gpm (5538 ac-ft/yr) during maximum demand 

34 conditions (STPNOC 2009c). STPNOC stated that the expected groundwater use for Units 3 

35 and 4 are assumed to also apply to alternative sites (STPNOC 2009b). However, for maximum 

36 operation demand periods, STPNOC assumes that a temporary increase in the rate of surface 

37 water use would be available (STPNOC 2009b). 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-52 March 2010

1 The review team determined that the proposed groundwater use at the Red 2 alternative site 

2 during operations would not be unreasonable because the alternate site would utilize units 

3 similar to those proposed for the STP site. 

4 As discussed, the managed available groundwater in Fannin County from the Woodbine Aquifer 

5 is 2676 ac-ft/yr. STPNOC estimated normal operational groundwater demand for the two units, 

6 if they were to be operated at the Red 2 alternative site and used a new groundwater permit, 

7 would constitute approximately 59 percent of the managed available groundwater of the 

8 Woodbine Aquifer in Fannin County. However, STPNOC stated (STPNOC 2009b) that 

9 groundwater from the Trinity Aquifer is also available, that access to existing groundwater 

10 production from current wells would be sought before requesting new or future groundwater 

11 capacity, and that water could be imported primarily for potable uses and thereby reduce 

12 groundwater demand. The review team concludes that a potential plant at the Red 2 site could 

13 use a large fraction of the managed available groundwater resource during operations. 

14 If a new groundwater permit were issued, this level of groundwater use and the potential for 

15 substantial drawdown of the Woodbine Aquifer to occur over the operational period of the facility 

16 causes the review team to conclude that the impact of operational groundwater use at the Red 2 

17 site would be noticeable. However, based on available information on the aquifer, and the 

18 authority of groundwater conservation districts to manage and permit groundwater resources 

19 (Texas Water Code, Chapter 36), the impact to the groundwater resource under a groundwater 

20 use permit issued by the applicable groundwater conservation district would not destabilize the 

21 groundwater resource. 

22 During operation of a potential plant at the Red 2 alternative site, impacts to groundwater quality 

23 result from intrusion of lower-quality water of the Red River into the Woodbine Aquifer or from 

24 the requirement to draw groundwater from deeper strata of the Woodbine Aquifer. Groundwater 

25 quality declines with depth in the Woodbine Aquifer. The amount of drawdown in the Woodbine 

26 Aquifer from groundwater pumping during operation should support the established desired 

27 future conditions. Based on standard geohydrologic practice, the review team determined that 

28 the drawdown could be limited by installing multiple, appropriately-spaced wells. The Red 2 site 

29 is located more than 3 mi away from the Red River, and therefore, the review team assumes 

30 wells would be located away from the river. The review team concludes that the drawdown in 

31 the Woodbine Aquifer could be managed during operation-related groundwater pumping using 

32 an appropriately designed well system; however, substantial drawdown would likely occur 

33 locally to the well field. The review team concludes that the impacts to groundwater quality local 

34 to the well field could range from minimal to noticeable, but would not be sufficient to destabilize 

35 the groundwater resource assuming the desired future condition of the aquifer is not violated. 

36 During operation of any potential plant at the Red 2 alternative site, impacts to groundwater 

37 quality may occur from leaching of spilled effluents into the subsurface or intentional discharge 

38 of effluents to groundwater. However, spills that might affect the quality of groundwater would 
 Environmental Impacts of Alternatives 

March 2010 9-53 Draft NUREG-1937 

1 be prevented or detected and mitigated by BMPs and no intentional discharge of effluents to 

2 groundwater should occur. While the implementation of BMPs would preclude or mitigate spills 

3 and there should be no intentional discharges to groundwater, because the drawdown in the 

4 Woodbine Aquifer would be controlled but perhaps result in noticeable changes in groundwater 

5 quality, the review team concludes that the groundwater-quality impacts from operation at the 

6 Red 2 site would be minimal to noticeable but not destabilizing. 

7 Cumulative Impacts

8 In addition to water use and water quality impacts from building and operations activities, 

9 cumulative analysis considers past, present, and reasonably foreseeable future actions that 

10 impact the same environmental resources. For the cumulative analysis of impacts on surface 

11 water, the geographic area of interest for the Red 2 site is considered to be the drainage basin 

12 of the Red River upstream and downstream of the site because this is the resource that would 

13 be affected by the proposed project. Key actions that have past, present, and future potential 

14 impacts to water supply and water quality in the Red River basin include the existing Valley 

15 Power Plant, Trinity Materials Hendrix Mine, and sewage treatment facilities. Key actions that 

16 could have future potential impacts to water supply and water quality include the planned Pattillo 

17 Branch Power Plant, and the Lower Bois d’Arc Creek Reservoir. The Pattillo Branch Power 

18 Plant is to be located approximately 1 mi south of the existing Valley Lake. The project would 

19 host four natural-gas powered units, with a combined output of approximately 1400 MW. 

20 Cumulative Water Use

21 The only surface-water-use impacts of building and operating a nuclear power plant at the Red 

22 2 site are the demands occurring during operation. The projected consumptive surface water 

23 use of the two units is expected to be about 50,000 ac-ft/yr and would require at least 11 

24 percent of the current held water rights of 456,000 ac-ft/yr in the Red River Basin, which would 

25 be a significant fraction of the existing water rights. Past and present water withdrawals, 

26 reflected by the water rights held in the Red River Basin, have used the waters of the river. 

27 Currently, unappropriated flows in the Red River Basin are available for a perpetual water rights 

28 permit only one-quarter of the months during a typical year. 

29 Increases in consumptive use of water in the Red River drainage is anticipated in the future 

30 primarily due to population growth (TWDB 2006b). Because the total rated power output of the 

31 Pattillo Branch Power Plant is smaller than that of the two proposed units, the increase in the 

32 region’s consumptive water use from the Pattillo Branch Power Plant is likely to be smaller than 

33 the consumptive use of the two proposed units, if they were to be located at the Red 2 site. The 

34 region’s water management strategy includes conservation, reuse, and development of new 

35 water supplies, including building the Bois d’Arc reservoir, that would meet and exceed the 

36 region’s 2060 water needs if all strategies are implemented (TWDB 2006b). The impacts of the 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-54 March 2010

1 Pattillo Branch Power Plant on the region’s water use would be noticeable but not destabilizing. 

2 The impacts of the other projects listed in Table 9-8 would have little to no impact on surface 

3 water use. 

4 Groundwater-use impacts of building and operating a nuclear power plant at this site are 

5 characterized by the groundwater demand at the STP site, and those use levels are 491 gpm 

6 (792 ac-ft/yr) during building, a normal operation demand of 975 gpm, and a maximum 

7 operation demand of 3434 gpm (STPNOC 2009c). However, for maximum operation demand 

8 periods, STPNOC assumes that a temporary increase in the rate of surface water use would be 

9 available for the short duration event. During building and normal operation STPNOC would 

10 rely on a balance of (1) a new groundwater permit and associated wells in the Woodbine and 

11 Trinity Aquifers, (2) access to existing groundwater production from wells in the vicinity of the 

12 plant completed in either the Woodbine or Trinity Aquifers, and (3) use of imported water 

13 primarily for potable use onsite that would reduce groundwater demand (STPNOC 2009b). With 

14 regard to the groundwater resource available to all past, present, and future projects, the 

15 managed available groundwater for the Woodbine Aquifer in Fannin County is 2676 ac-ft/yr, and 

16 the predicted future groundwater use through 2025 is 2622 ac-ft/yr. Based on this quantification 

17 of the groundwater resource within Fannin County, the review team concludes that past and 

18 present projects have fully utilized the Woodbine Aquifer resource. 

19 As indicated above, groundwater would be used during the building and operation of two 

20 nuclear units at the Red 2 site. The possibilities exist that STPNOC could (1) use available 

21 groundwater from both the Woodbine and Trinity Aquifers, (2) acquire groundwater sufficient to 

22 build and operate Red 2 plants from existing permitted groundwater wells, and (3) import water 

23 for primarily potable water supplies and thereby reduce groundwater demand (STPNOC 2009e). 

24 Assuming that these strategies are implemented, some but not a substantial impact is 

25 anticipated to other nearby users of groundwater. However, if only new permits are issued to 

26 provide the needed groundwater and new wells are drilled to provide the groundwater, then the 

27 review team expects impacts to nearby users of groundwater would be controlled and limited 

28 through the permitting process and rules of the groundwater conservation district. As such, 

29 impacts to groundwater use would be minimal. 

30 The review team is also aware of the potential for GCC affecting the water resources available 

31 for closed-cycle cooling and the impact of reactor operations on water resources for other users. 

32 The impact of GCC on regional water resources is not precisely known, however it may result in 

33 decreases in precipitation and increases in average temperature (Karl et al. 2009). Such 

34 changes could further stress regional water resources. However, the impacts related to GCC 

35 would be similar for all the alternative sites. 

36 Historically, the waters of the Red River Basin have been used extensively. The region has a 

37 planning, allocation, and development system in place to manage the use of its limited surface 
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March 2010 9-55 Draft NUREG-1937 

1 water supplies (TWDB 2006a, 2006b). As stated above, operation of the proposed units on the 

2 Red 2 site would result in a noticeable but not destabilizing impact to the surface water use in 

3 the region. Future projects in the region would also result in noticeable but not destabilizing 

4 impacts on surface water use in the region. Therefore, the review team concludes that 

5 cumulative impacts to surface water use would be MODERATE. Building and operating the 

6 proposed plant at the Red 2 site would be a significant contributor to surface-water-use impacts 

7 because of the impacts arising from the acquisition and especially the aggregation of surface8 water rights necessary to supply the proposed plant. The review team concludes that 

9 cumulative impacts to groundwater use would be MODERATE. Building and operating the 

10 proposed plant at the Red 2 site would be a significant contributor to this groundwater-use 

11 impact because the implied use of groundwater would exceed the current estimate of managed 

12 available groundwater resource by approximately 30 percent for building and 59 percent for 

13 operating the proposed plant. 

14 Cumulative Water Quality

15 Point and nonpoint sources in the river basin have affected the water quality of the Red River. 

16 Water quality information presented above for the impacts of building and operating the new 

17 units at the Red 2 site would also apply to evaluation of cumulative impacts. The State of Texas 

18 may require an applicant to obtain a general or individual permit for discharge of stormwater 

19 (Texas Water Code, Chapter 26). These permits may require an SWPPP that includes BMPs 

20 appropriate for the site (TCEQ 2001, 2003; STPNOC 2009a). The State of Texas would also 

21 issue TPDES permits for the discharge of sanitary and other wastewaters, including blowdown 

22 from service water cooling towers and cooling water reservoir discharges, before operation of 

23 the proposed units at the Red 2 site. Effluent discharges through a TPDES-permitted outfall, 

24 such as those from Valley Power Station, Trinity Materials Hendrix Mine, and sewage treatment 

25 plants, are required to comply with the Clean Water Act. Such permits are designed to protect 

26 water quality. Therefore, the review team concluded that the cumulative impact on surface 

27 water quality of the receiving water body would be SMALL. The impacts of other projects listed 

28 in Table 9-8 would have little or no impact on surface water quality. 

29 The review team also concludes that with the implementation of BMPs, the impacts of 

30 groundwater quality from building two new nuclear units at the Red 2 site would likely be 

31 minimal. However, during operation, the production of groundwater from wells under a new 

32 permit could result in groundwater-quality impacts ranging from minimal to being altered 

33 noticeably because of the degradation in water quality. The individual impacts from other 

34 projects listed in Table 9-8 would have little or no impact on regional groundwater quality 

35 because of the local nature of groundwater withdrawals and their associated impacts. 

36 Therefore, the cumulative impact on groundwater quality would be SMALL to MODERATE. 

37 Building and operating the proposed plant at the Red 2 site would be a significant contributor to 

38 these water quality impacts. 
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1 9.3.2.3 Terrestrial and Wetland Resources 

2 The following impact analysis includes impacts from building activities and operations. The 

3 analysis also considers other past, present, and reasonably foreseeable future actions that 

4 impact terrestrial and wetland resources, including other Federal and non-Federal projects listed 

5 in Table 9-8. For the analysis of terrestrial ecological impacts, the geographic area of interest is 

6 the intersection of the East Texas Plains and Blackland Prairies ecoregion with the Bois d’Arc 

7 Island watershed in Grayson and Fannin Counties (Figure 9-6). This geographic area of 

8 interest is expected to encompass the ecologically relevant landscape features and species. 

9 The Red 2 site is a greenfield site located on the northern edge of Valley Lake in Fannin 

10 County. The site is in the Blackland Prairies subprovince of the Gulf Coast Plains. The 

11 blacklands have a gentle undulating surface that has been cleared of most natural vegetation 

12 for the cultivation of crops (UT 1996). The soils of the blacklands are chalks and marls that 

13 have weathered to deep, fertile clay soils. Pre-settlement conditions were that of a true prairie 

14 grassland community dominated by a diverse assortment of perennial and annual grasses and 

15 forbs, with sparsely scattered trees or mottes of oaks (Quercus sp.) on the uplands (TPWD 

16 2009a). Forested or wooded areas were restricted to bottomlands along major rivers and 

17 streams, ravines, protected areas, or on certain soil types. Trees such as pecan (Carya 

18 illinoinesis), cedar elm (Ulmus crassifolia), cottonwoods (Populus spp.), various oaks, and 

19 hackberry (Celtis sp.) dotted the landscape (TPWD 2009b). The dominant grass was the little 

20 bluestem (Schizachyrium scoparium). Other grasses included the big bluestem (Andropogon 

21 geradrii), Indian grass (Sorghastrum sp.), eastern gamagrass (Tripsacum dactyloides), 

22 switchgrass (Panicum virgatum), and sideoats grama (Bouteloua curtipendula). 

23 Currently, the region surrounding the Red 2 site is mostly rural, with much of the prairie 

24 converted to cropland and non-native pasture. In August 2009, NRC staff visited the site and 

25 found that the site contained buildings, roads, pastures, and small wooded areas (NRC 2009b). 

26 The total acreage for all temporary and permanent impacts is 800 ac for the plant site and 

27 1700 ac for the reservoir. Permanent impacts associated with building two new nuclear units at 

28 the Red 2 site would include approximately 150 ac for each unit (300 ac total) and a new 

29 1700-ac reservoir for cooling water for the plant (STPNOC 2009a). While specific habitat 

30 acreages have not been determined for the site, Table 9-9 gives approximate acreages by land 

31 cover class for areas experiencing permanent impacts. No assessment was made for land 

32 cover classes receiving temporary impacts. The acreages for land cover classes receiving 

33 permanent impacts are from the ER and were based on evaluation of Google Earth Imagery 

34 (STPNOC 2009a). 
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March 2010 9-57 Draft NUREG-1937 

1 

2 Figure 9-6. Geographic Area of Analysis of Cumulative Impacts to Terrestrial Resources for 

3 the Red 2 Site in Grayson and Fannin Counties 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-58 March 2010

1 Table 9-9. Estimated Land Cover Classes for Approximately 2000 ac of the 2500 ac Red 2 

2 Site. 

Land Cover Class Plant (ac) Reservoir (ac) 

Forested 80 850 

Cleared farmland 220 800 

Water resources/freshwater ponds (no high quality 

forested wetlands identified) 

0 50 

Source: STPNOC 2009a 

3 Water features at the Red 2 site include a portion of Valley Lake, estimated to be 100 ac, 

4 located in the extreme southwestern portion of the site. Numerous freshwater ponds are also 

5 scattered throughout the site with an estimated total acreage of 50 ac. In addition, there are a 

6 few freshwater, emergent wetland areas totaling less than 1 ac. No high quality forested 

7 wetlands have been identified in the immediate site area (STPNOC 2009a). 

8 Ecologically important areas occurring near the Red 2 site include the Caddo-LBJ National 

9 Grasslands approximately 15 mi from the site; the grasslands cover more than 16,000 ac 

10 (TPWD 2009c). TPWD (2009d) has indicated there is potential for native pasture or native 

11 prairie remnants in Fannin County. Additionally two Ecologically Significant River and Stream 

12 Segments occur in Fannin County associated with Bois d’Arc Creek and Coffee Mill Creek 

13 (TPWD 2010). Portions of the Bois d’Arc Creek include Priority 4 Bottomland Hardwood areas 

14 (STPNOC 2009b). The nearby Hagerman National Wildlife Refuge is home to thousands of 

15 geese and waterfowl during the winter (STPNOC 2009b). 

16 Important Species 

17 A range of wildlife species potentially occur at the Red 2 site (STPNOC 2009b), including the 

18 following recreationally valuable species: the eastern turkey (Meleagris gallopavo sylvestris), 

19 mourning dove (Zenaida macroura), white-tailed deer (Odocoileus virginianus), northern 

20 bobwhite quail (Colinus virginianus), and eastern fox squirrel (Sciurus niger) (STPNOC 2009b). 

21 All these species are habitat generalists (NatureServe 2009a). Mourning doves use a variety of 

22 habitats including croplands and pastures, grasslands, and open hardwood forests. The doves 

23 are ground, seed feeders. The eastern fox squirrel is the largest tree squirrel in the western 

24 hemisphere (NatureServe 2009a); it is found in open mixed hardwood forests or mixed pine25 hardwood associations but is well adapted to disturbed areas. Both the eastern turkey and the 

26 bobwhite quail share many of the same habitat characteristics and have been in decline in the 

27 Blackland Prairie areas of Texas (TPWD 2009e). Both species are ground nesters and their 

28 decline has been linked to a lack of nesting and brood rearing habitat (TPWD 2009e). Turkeys 

29 require dense and diverse patches of grasses and forb, with some shrubs and an abundance of 

30 insects (TPWD 2009e). Northern bobwhites build their nests at the bases of native 
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March 2010 9-59 Draft NUREG-1937 

1 bunchgrasses, while brood rearing occurs in areas with enough taller herbaceous cover to 

2 provide overhead concealment with bare ground underneath for easy movement (TPWD 

3 2009e). White-tailed deer occur almost entirely in hardwood woodlands, and forage on a wide4 variety of plants from grasses and forbs, to fruits and nuts (Davis and Schmidly 1994). 

5 Up to seven bat species living in eastern Texas, can occur in Fannin County (Davis and 

6 Schmidly 1994; STPNOC 2009b. Some are mostly year-round residents (i.e., non-migratory), 

7 such as the big brown bat (Eptesicus fuscus), the eastern pipistrelle (Pipistrellus subflavus), and 

8 evening bat (Nycticeius humeralis). Migratory bats that could occur at the site include the hoary 

9 bat (Lasiurus cinereus), the silver-haired bat (Lasionycteris noctivagans), the eastern red bat 

10 (Lasiurus borealis), and the Mexican free-tailed bat (Tadarida brasiliensis). The Mexican free11 tailed bat can be either migratory or non-migratory depending on where it resides; the migratory 

12 status of bats occurring in Fannin County is currently unknown (STPNOC 2009b). 

13 The site lies within the Central Flyway of Texas (STPNOC 2009b) – a major migratory corridor 

14 for neotropical migrants and other birds. Thousands of migrating birds, especially waterfowl, 

15 flying south from cooler regions of the North American continent could potentially rest and feed 

16 in this area. Two areas of potential importance to migratory birds in the vicinity of the Red 2 site 

17 are the Caddo National Grasslands/Wildlife Management Area, approximately 15 mi from the 

18 site, and the Hagerman National Wildlife Refuge located more than 15 mi from the site 

19 (STPNOC 2009b). In addition, portions of Bois D’Arc Creek, east of the Red 2 site, include 

20 Priority 4 Bottomland Hardwood areas that are considered quality habitat for waterfowl. At the 

21 site audit in 2009, the potential for colonial breeding bird rookeries along the pipeline route was 

22 noted (NRC 2009b). 

23 No site specific surveys have been conducted for threatened and endangered species at the 

24 Red 2 site. The following list for Fannin County (Table 9-10 on the following page) was 

25 compiled from the Texas Parks and Wildlife Threatened and Endangered Species by County 

26 website (TPWD 2009f) and the U.S. Fish and Wildlife Service Ecological Service T&E species 

27 for the Southwest region website (FWS 2009a). Three species are listed as Federally28 threatened or endangered in Fannin County (FWS 2009a), and the State lists an additional nine 

29 species as endangered or threatened (TPWD 2009f). No critical or sensitive habitats for 

30 Federally listed species have been identified in the immediate site area (FWS 2009d). 
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Draft NUREG-1937 9-60 March 2010

1 Table 9-10. Federally and State-listed Threatened and Endangered Species in Fannin County, 

2 Texas 

Group Common Name Scientific Name 

Federal 

Status* 

State 

Status* 

Alligator snapping turtle Macrochelys temminckii T 

Texas horned lizard Phrynosoma cornutum T 

Reptiles 

Timber/canebrake rattlesnake Crotalus horridus T 

Birds American peregrine falcon Falco peregrinus anatum T 

 Bald eagle Haliaeetus leucocephalus T 

 Eskimo curlew Numenius borealis E 

 Interior least tern Sterna antillarum athalassos E E 

 Piping plover Charadrius melodus T 

 Whooping crane Grus americana E E 

 Wood stork Mycteria americana T 

Mammals Black bear Ursus americanus T/SA T 

Red wolf Canis rufus E 

Sources: FWS 2009a; TPWD 2009f 

*T-threatened; E-endangered; T/SA-proposed similarity of appearance to a threatened taxon 

3 Alligator snapping turtle

4 The alligator snapping turtle (Macrochelys temminckii) is a State-listed threatened species 

5 (TPWD 2009f). It is found in slow-moving, deep water of rivers, sloughs, oxbows, and canals or 

6 lakes associated with rivers, and also in swamps, ponds near rivers, and shallow creeks that are 

7 tributary to occupied rivers (NatureServe 2009b). It usually occurs in water with mud bottoms 

8 and abundant aquatic vegetation; it may migrate several miles along rivers (TPWD 2009g). 

9 Turtles are rarely found out of the water except when nesting. 

10 Texas horned lizard 

11 The Texas horned lizard (Phrynosoma cornutum) is a State-listed threatened species 

12 (TPWD 2009f). It can be found in arid and semiarid habitats in open areas with sparse plant 

13 cover (TPWD 2009g). They dig for hibernation, nesting, and insulation purposes, and are 

14 commonly associated with loose sand or loamy soils. Populations have declined precipitously 

15 in eastern Texas, and their decline may be related to the spread of fire ants, use of insecticide 

16 to control fire ants, heavy agricultural use of the land, and other habitat alterations 

17 (NatureServe 2009b). Another factor implicated in their decline is over-collecting for the pet and 

18 curio trade. This species is particularly vulnerable to the loss of harvester ants, which make up 

19 nearly 70 percent of their diet. 
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March 2010 9-61 Draft NUREG-1937 

1 Timber/canebrake rattlesnake

2 The timber rattlesnake (Crotalus horridus) is a State-listed threatened species (TPWD 2009f). 

3 It prefers moist lowland forests and hilly woodlands or thickets near permanent water sources 

4 such as rivers, lakes, ponds, streams, and swamps (TPWD 2009g). The range of the 

5 rattlesnake extends from central New England to northern Florida, and west to eastern Texas, 

6 where its distribution is spotty (NatureServe 2009b). 

7 American peregrine falcon 

8 The American peregrine falcon (Falco peregrinus anatum) is a State-listed threatened species 

9 (TPWD 2009f). The bird is a year-round resident and local breeder in west Texas where it nests 

10 in tall cliff eyries (TPWD 2009g). This species also migrates across Texas from breeding areas 

11 in the United States and Canada to winter along the coast and farther south. The American 

12 peregrine falcon occupies a wide range of habitats during migration, including urban areas. 

13 Populations are primarily concentrated along coast and barrier islands. The birds are low14 altitude migrants, with stopovers at leading landscape edges such as lake shores, coastlines, 

15 and barrier islands. 

16 Bald eagle 

17 Although recently delisted from a status of Federally threatened, the bald eagle (Haliaeetus 

18 leucocephalus) is State-listed as threatened in Texas and will remain Federally protected under 

19 the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act (TPWD 2009f). 

20 The species will also continue to be protected under the Endangered Species Act (ESA) 

21 through management guidelines that will be in place for the next five years. Most eagles breed 

22 in Canada and the northern United States and move south for the winter (NatureServe 2009b). 

23 Bald eagles can be year-round residents in areas where water bodies do not freeze. Winter 

24 roost sites can vary with proximity to food resources and eagles commonly roost communally in 

25 large trees, preferably snags. 

26 Eskimo curlew

27 The Eskimo curlew (Numenius borealis) is a State-listed endangered species (TPWD 2009f). 

28 Eskimo curlews historically migrated from breeding grounds in the Arctic tundra through the 

29 North American prairies to wintering grounds on the pampas grasslands of Argentina (TPWD 

30 2009g). Fannin county lies in the historic migration path for this species whose numbers 

31 currently are estimated to be fewer than 50 (NatureServe 2009b). 
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Draft NUREG-1937 9-62 March 2010

1 Interior least tern

2 The interior least tern (Sterna antillarum athalassos) is Federally and State-listed as 

3 endangered (FWS 2009a; TPWD 2009f). The birds breed along inland river systems including 

4 the Red River (TPWD 2009g). Interior least terns nest on bare or sparsely vegetated sand, 

5 shell, and gravel beaches, islands, and salt flats associated with rivers and reservoirs. The 

6 birds prefer open habitat and avoid thick vegetation and narrow beaches. They arrive at 

7 breeding areas in early April to early June after wintering along the Central American coast and 

8 the northern coast of South America. 

9 Piping plover

10 The piping plover (Charadrius melodus) is State-listed as threatened (TPWD 2009f). This 

11 species is Federally listed as threatened in the State of Texas, but is not listed as occurring in 

12 Fannin County by FWS (FWS 2009a). Texas is the wintering home for more than 5000 known 

13 breeding pairs that have migrated from the Great Lakes regions and southern Canada (TPWD 

14 2009g). They live on sandy beaches and lakeshores along the Gulf coast and could migrate 

15 through Fannin County. 

16 Whooping crane 

17 The whooping crane is Federally and State-listed as an endangered species (FWS 2009a; 

18 TPWD 2009f). Whooping cranes breed in Canada during the summer months and migrate to 

19 the Aransas National Wildlife Refuge along the Texas coastal plain, staying there from 

20 November through March (TPWD 2009g). Their winter and migrating habitat includes marshes, 

21 shallow lakes, lagoons, salt flats, and grain and stubble fields (NatureServe 2009b). Migration 

22 habitat includes sites with good horizontal visibility, water depth of 30 cm or less, and a 

23 minimum wetland size of 0.04 ha for roosting. 

24 Wood stork 

25 The wood stork (Mycteria americana) is a State-listed threatened species (TPWD 2009f). 

26 Nesting has been restricted to Florida, Georgia, and South Carolina. However, they may have 

27 formerly bred in Texas (FWS 2009b), but there are no breeding records since 1960 

28 (TPWD 2009g). Wood storks forage in prairie ponds, flooded pastures or fields, ditches, and 

29 other shallow standing water, including saltwater. The birds usually roost communally in tall 

30 snags, sometimes in association with other wading birds (i.e., active rookeries). A distinct, non31 listed population of wood storks breed in Mexico and then move into Gulf states in search of 

32 mud flats and other wetlands, even those associated with forested areas. 
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March 2010 9-63 Draft NUREG-1937 

1 Black bear

2 The black bear (Ursus americanus) is on the State endangered species list (TPWD 2009f) due 

3 to its similarity to the Louisiana black bear (subspecies U. americanus luteolus). The Louisiana 

4 black bear is Federally listed as threatened (FWS 2009a); it is not known to be found in Texas, 

5 although potential habitat exists in the eastern part of the state including Fannin County. 

6 Habitat for the black bear includes bottomland hardwoods and large tracts of inaccessible 

7 forested areas (TPWD 2009g). 

8 Red wolf

9 The red wolf (Canis rufus) is State-listed as endangered (TPWD 2009f). Red wolves inhabited 

10 brush and forested areas, as well as the coastal prairies (Davis and Schmidly 1994). They 

11 formerly ranged throughout eastern Texas, but appear to now be extinct. 

12 Building Impacts 

13 Building impacts would affect up to 2500 ac of land resulting in the permanent loss of terrestrial 

14 habitat. Three-hundred ac would be required for permanent structures and facilities, and up to 

15 1700 ac would be required for a new reservoir. Of the 300 ac that would be permanently 

16 affected at the plant site, approximately 220 ac are previously cleared land and 80 ac are 

17 forested. The reservoir would affect approximately 850 ac of forested land, 800 ac of previously 

18 cleared land, 50 ac of ponds and other water resources, and less than 1 ac of emergent 

19 wetlands (Table 9-8) (STPNOC 2009a). Only one small freshwater emergent wetland (0.9 ac) 

20 was identified within the affected area; this wetland occurs in the area identified for the main 

21 power plant area. (STPNOC 2009a) Additional acreage resulting in permanent losses would be 

22 associated with transmission lines, pipelines, roads, and railroad access (STPNOC 2009a). 

23 New transmission lines would be needed to connect the Red 2 site with existing transmission 

24 lines at the Valley Power Plant, 1.8 mi south. The likely route for new lines would traverse a 

25 distance of 5 mi and require a 200-ft-wide corridor, which would affect approximately 120 ac of 

26 land (STPNOC 2009a). The land along the theoretical corridor is a mixture of cleared land and 

27 forest (STPNOC 2009b). Once at the Valley Power Plant, it is assumed the lines would parallel 

28 the existing corridor (with potential need for expansion). Erection of the transmission towers 

29 and stringing of the lines would be expected to comply with all applicable laws, regulations, 

30 permit requirements, and used of best management practices (STPNOC 2009a). The building 

31 of new transmission line corridors would contribute to fragmentation of habitat. 

32 In addition to the transmission lines, a 3.8-mi-long, 75-ft-wide corridor containing the cooling 

33 water intake and discharge pipelines between the Red River and new reservoir would be built. 

34 A 4.2-mi-long, 50-ft-wide rail corridor and a 2.2-mi-long, 75-ft-wide access road would also be 

35 needed. A total of 81 ac of land would be affected for these new corridors (STPNOC 2009a). 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-64 March 2010

1 The land surrounding the site is predominately cropland and non-native pasture and the review 

2 team assumes a large portion of the acreage needed for the road, pipeline, and rail corridors 

3 would be previously disturbed. 

4 No site-specific reports on Federally or State-listed species were available for the Red 2 site. 

5 As noted above, three Federally-listed and nine State-listed species occur in Fannin County and 

6 may potentially occur at the Red 2 site. 

7 Building two new nuclear reactors at the Red 2 site would result in the permanent loss of 

8 approximately 2000 ac of terrestrial habitat including more than 900 ac of forested habitat and 

9 minimal loss of wetland habitat. However, the reservoir would provide additional waterfowl 

10 habitat. Clearing land for the transmission line corridor would increase habitat fragmentation 

11 along the 5-mi corridor. Other sources of impacts to terrestrial resources such as noise, 

12 increased risk of collision and electrocution, and displacement of wildlife would likely be 

13 temporary and result in minimal impacts to the resource. Building the two new units would 

14 noticeably alter the available terrestrial habitat. 

15 Operational Impacts 

16 Impacts on terrestrial ecological resources from operation of two new nuclear units at the Red 2 

17 site include those associated with transmission system structures, and maintenance of 

18 transmission line corridors. Also, during plant operation, wildlife would be subjected to impacts 

19 from increased traffic. An evaluation of specific impacts resulting from building of transmission 

20 lines and transmission corridor maintenance cannot be conducted in any detail due to the lack 

21 of information, such as the locations of any new corridors that could result from transmission 

22 system upgrades. However, in general, impacts associated with transmission line operation 

23 consist of bird collisions with transmission lines, electromagnetic field (EMF) effects on flora and 

24 fauna, and habitat loss due to corridor maintenance. 

25 Direct mortality resulting from birds colliding with tall structures has been observed (Erickson et 

26 al. 2005). Factors that appear to influence the rate of avian impacts with structures are diverse 

27 and related to bird behavior, structure attributes, and weather. Migratory flight during darkness 

28 by flocking birds has contributed to the largest mortality events. Tower height, location, 

29 configuration, and lighting also appear to play a role in avian mortality. Weather, such as low 

30 cloud ceilings, advancing fronts, and fog also contribute to this phenomenon. Waterfowl may be 

31 particularly vulnerable due to low, fast flight and flocking behavior (Brown 1993). Although 

32 additional transmission lines would be required for two new nuclear units at Red 2, increases in 

33 bird collisions directly attributable to these lines would be minor and would likely not be 

34 expected to cause a measurable reduction in local bird populations. 

35 EMFs are unlike other agents that have an adverse impact (e.g., toxic chemicals and ionizing 

36 radiation) in that dramatic acute effects cannot be demonstrated and long-term effects, if they 
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March 2010 9-65 Draft NUREG-1937 

1 exist, are subtle (NIEHS 2002). A careful review of biological and physical studies of EMFs did 

2 not reveal consistent evidence linking harmful effects with field exposures (NIEHS 2002). The 

3 magnetic fields from many lines, at a distance of 300 ft are similar to typical background levels 

4 in most homes (NIEHS 2002). Thus, impacts of EMFs on terrestrial flora and fauna are of small 

5 significance at operating nuclear power plants, including transmission systems with variable 

6 numbers of power lines (NRC 1996). Since 1997, more than a dozen studies have been 

7 published that looked at cancer in animals that were exposed to EMFs for all or most of their 

8 lives (Moulder 2003). These studies have found no evidence that EMFs cause any specific 

9 types of cancer in rats or mice (Moulder 2003). 

10 The impacts associated with corridor maintenance activities are loss of habitat due to cutting 

11 and herbicide application, and similar impacts where corridors cross floodplains and wetlands. 

12 The maintenance of transmission-line corridors could be beneficial for some species, including 

13 those that inhabit early successional habitat or use edge environments. Thus, corridor 

14 maintenance would not be expected to increase or contribute to cumulative effects. 

15 The potential effects of operating two new nuclear reactors at the Red 2 site would be primarily 

16 associated with maintenance of transmission corridors and increased traffic. Operational 

17 impacts to terrestrial resources would be expected to be minimal. 

18 Cumulative Impacts 

19 The impacts of building and operating two units at Red 2 were evaluated by the review team to 

20 determine the magnitude of their contribution to regional cumulative impacts on terrestrial 

21 ecological resources. The geographic area of interest for cumulative impacts (Figure 9-6) at 

22 Red 2 is the intersection of the East Central Texas Plains and Texas Blackland Prairies 

23 ecoregions and the Bois d’Arc Island watershed in Fannin and Grayson Counties. Activities 

24 related to building include loss of habitat due to clearing for building of the plant, and filling the 

25 reservoir. Past actions that have affected terrestrial resources include the construction of the 

26 Valley Power Plant approximately 2 mi south of the facility, in which about 300 ac were cleared 

27 for the plant; and the construction of the Trinity Materials mine approximately 12 mi from the 

28 Red 2 site (Table 9-8). Both of these actions changed the nature of terrestrial habitat, generally 

29 through grading, removing and covering the previous terrestrial features. 

30 Present actions that affect terrestrial resources include construction related to the expansion of 

31 I-75, 14 mi west of the site (Table 9-8). The project is currently restricted to modifying on and 

32 off ramps, and disturbs relatively little area; however, future activity could involve expansion of 

33 the road to 6 lanes. At the Caddo-LBJ National Grasslands, habitat restoration work would 

34 remove about 200 ac of eastern red cedar (Juniperus virginiana) to allow for restoration of the 

35 traditional open grassland prairie. 
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Draft NUREG-1937 9-66 March 2010

1 There are several proposed future actions near the Red 2 site (Table 9-8). The first is the 

2 proposal to build the Pattillo Branch Power Plant approximately 3 mi south of the Red 2 site. 

3 This proposed facility would affect approximately 300 ac of terrestrial resources through land4 clearing and construction activities, plus road and transmission corridors. The second proposal 

5 is for a reservoir on Bois d’Arc Creek northeast of Bonham Texas, approximately 20 mi east of 

6 the Red 2 site (Corps 2009). In addition to flooding 17,000 ac, two pipelines would be 

7 constructed for water delivery; one pipeline would be 29 mi from the reservoir, the other 14 mi 

8 away. Possible impacts to terrestrial and wetland resources from the power plant and 

9 associated transmission line corridors would be habitat loss through removal of habitat 

10 components (e.g., trees, grassland, access to soil) and habitat fragmentation. The lake would 

11 inundate the Bois d’Arc Creek bottomland hardwoods area, which is designated as a Priority 4 

12 habitat (TWDB 2001). The Bois d’Arc reservoir would convert a large terrestrial habitat to an 

13 aquatic habitat; there would be additional loss of terrestrial habitat through construction of 

14 pipeline corridors. Also, new transmission lines would add to those associated with the Valley 

15 Power Plant and the proposed Pattillo Branch Power Plant (Table 9-8). The increase in the 

16 number of transmission towers would not result in a noticeable increase in bird collisions. The 

17 proposed Lake Ralph Hall Reservoir (Table 9-8) is outside the geographic area of interest for 

18 terrestrial impacts at the Red 2 Site. 

19 The review team is also aware of the potential for GCC affecting the terrestrial resources in the 

20 geographic area of interest. The future impact of GCC on plant and wildlife species and their 

21 habitats in the geographic area of interest is not precisely known. GCC effects near the Red 2 

22 site could result in regional increases in the frequency of severe weather, decreases in annual 

23 precipitation, and increases in average temperature (Karl et al. 2009). The decrease in 

24 precipitation combined with increased temperatures and evaporation could result in more 

25 frequent droughts. Such changes in climate could alter and fragment terrestrial habitats 

26 (grasslands and wetlands, including prairie potholes) and could result in shifts in species 

27 ranges, diversity, and abundance in the geographic area of interest for the Red 2 site (Karl et al. 

28 2009). 

29 The potential cumulative impact to terrestrial resources within the area of interest given the two 

30 new reactors at the Red 2 site, the proposed power plant 3 mi south, and the 17,000-ac 

31 reservoir 20 mi northeast of the site would noticeably alter terrestrial resources. All these 

32 activities would remove or modify terrestrial habitats with the potential to affect important 

33 species living or migrating through the area. For the reasons discussed above in Building 

34 Impacts and Operational Impacts, the incremental contribution of building and operating the two 

35 new reactors at the Red 2 site to the cumulative impacts within the geographic area of interest 

36 would be substantial. 
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1 Summary 

2 Impacts to terrestrial ecology resources and wetland resources were estimated based in the 

3 information provided by STPNOC and the review team’s own independent review. Two future 

4 activities in the region that would noticeably affect wildlife and wildlife habitat, in addition to the 

5 building and operation of two units at the Red 2 site, are the building of the Pattillo Branch 

6 Power Plant and the Lower Bois d’Arc Creek reservoir (Table 9-8). After building at the Red 2 

7 site is complete, terrestrial ecological resources in areas that are temporarily disturbed are 

8 expected to return to predominantly preconstruction conditions. However, the development of a 

9 1700-ac reservoir would permanently shift resources from terrestrial to aquatic. Additional 

10 impacts at the reservoir location and plant site would include the potential for affecting more 

11 than 900 ac of forested land, and the potential habitat loss for any protected species that could 

12 occur in the area. While there is uncertainty concerning the possible routing of a new 

13 transmission corridor, transportation, and pipeline corridors at the Red 2 site, the potential area 

14 affected is estimated to be relatively small (i.e., about 200 ac). Based on the information 

15 provided by STPNOC and the review team’s independent evaluation, the review team 

16 concludes that the cumulative impacts within the area of interest on terrestrial plants and 

17 animals, including threatened or endangered species, and wildlife habitat in the region would be 

18 MODERATE. The creation of the Lower Bois d’Arc Creek reservoir is the primary reason for 

19 this impact level. However, the incremental contribution of building and operating the two new 

20 reactors at the Red 2 site to the cumulative impacts within the geographic area of interest would 

21 be significant. 

22 9.3.2.4 Aquatic Resources 

23 The following impact analysis includes impacts from building activities and operations. The 

24 analysis also considers other past, present, and reasonably foreseeable future actions that 

25 impact aquatic resources, including other Federal and non-Federal projects listed in Table 9-8. 

26 For the analysis of aquatic ecological impacts at the Red 2 site, the geographic area of interest 

27 is considered to be all parts of the Red River drainage between the Denison Dam (below Lake 

28 Texoma Reservoir) and the confluence of the Red River with the Kiamichi River. 

29 At the Red 2 alternative site, aquatic resources are associated with the Red River, Brushy 

30 Creek, and the nearby drainages for Pattillo Branch, Sheep Creek, and Bois d’Arc Creek, as 

31 well as Valley Lake (Figure 9-5). The Red 2 site has been cleared for agriculture, and yet still 

32 supports numerous springs, intermittent streams, and ponds. The Red River flows through 

33 Fannin County downstream of Lake Texoma and is the border between Texas and Oklahoma. 

34 Flows in the Red River are maintained by releases from Lake Texoma Dam. While fishing is 

35 common in the clear waters of Lake Texoma, recreational fishing is popular in the Red River 

36 downstream of the dam (McCord 2009). Texas Water Quality Inventory lists chlorophyll-a

37 concentrations at a level of concern in this portion of the river (TCEQ 2008). The reach of the 

38 river through Fannin County is not navigable for commercial vessels, but is used for recreational 
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1 boating activities. In addition, there are numerous, intermittent streams and creeks that flow into 

2 the river (McCord 2009; STPNOC 2009a). 

3 Valley Lake is a man-made reservoir on Brushy Creek that is owned and operated by Luminant 

4 Power. The lake’s water is used for condenser cooling and other uses associated with the 

5 natural gas-fueled, Valley Power Plant (STPNOC 2009a). The lake is popular for recreational 

6 activities. As stated in Section 9.3.2.2, water from Valley Lake would not be available for 

7 cooling new nuclear units located at the Red 2 site (STPNOC 2009a). 

8 Brushy Creek rises east of Valley Lake and flows north for 4 mi through the Red 2 site before 

9 emptying into the Red River. The creek crosses flat land surfaced by clay and sandy loams with 

10 water-tolerant hardwoods, conifers, and grasses along the banks. The review team could not 

11 find any surveys of aquatic resources in Brushy Creek or the other drainages and ponds in the 

12 area. Flows in the smaller drainages are assumed to be intermittent and the resources would 

13 be dependent on seasonal flows. 

14 Texas Parks and Wildlife Department (TPWD) has designated Bois d’Arc Creek an ecologically 

15 significant stream segment, from its confluence with the Red River through the site and 

16 upstream to its headwaters in east Grayson County. TPWD notes that the creek has significant 

17 habitat value (TPWD 2010). 

18 Within the Red River drainage up and downstream of the Red 2 site there are a number of past, 

19 present and potential projects that could affect the aquatic resources (Table 9-8). Past actions 

20 include building the Valley Power Plant, excavation of the Trinity Materials (Hendrix Mine), and 

21 the wastewater treatment plants for the cities of Belles and Denison. There are two proposed 

22 projects in the region that would also affect aquatic resources in vicinity: the gas-powered 

23 Pattillo Branch Power Plant and the Lower Bois d’Arc Creek Reservoir (16,641 ac). In addition, 

24 the new nuclear units would require building water intake and discharge systems with 

25 associated pipelines from the Red River to the new site, inundation of a reservoir, and 

26 associated transmission corridors to connect with the existing power grid. Without having the 

27 specific plans for locating all facilities at the Red 2 site, the potential for impacts from building 

28 and operation of the new units to aquatic biota are likely to be those inhabiting the Red River, 

29 Valley Lake, Brushy Creek, springs, intermittent streams, ponds, and the nearby drainages for 

30 Bois d’Arc Creek, Sheep Creek, and Pattillo Branch. 

31 Non-Native and Nuisance Species 

32 No non-native or nuisance species have been recorded in the area as a problem. However, 

33 there are numerous nuisance aquatic species that TPWD considers to be ubiquitous across 

34 waterways in Texas. These species include: hydrilla (Hydrilla verticillata), water hyacinth 

35 (Eichhornia crassipes), and giant salvinia (Salvinia molesta). In addition, the Red River basin is 

36 known to have the following non-native fish: common carp (Cyprinus carpio), grass carp 
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March 2010 9-69 Draft NUREG-1937 

1 (Ctenopharyngodon idella), blacktail shiner (Cypinella venusta), bullhead minnow (Pimephales 

2 vigilax), rudd (Scardinius erythrophthalmus), black buffalo (Ictiobus niger), black bullhead 

3 (Ameiurus melas), Western starhead topminnow (Fundulus blairae), redspotted sunfish 

4 (Lepomis miniatus), tadpole madtom (Noturus gyrinus), plains killfish (Fundulus zebrinus), 

5 yellow perch (Perca flavescens), and walleye (Sander vitreum)(Thomas et al. 2007; Hassan6 Williams and Bonner 2009; TPWD 2009h). 

7 Important Species 

8 The Red River is popular for recreational fishing. The recreational fish species in the Red River 

9 and in Valley Lake include: alligator gar (Atractosteus spatula), several bass species (spotted 

10 bass (Micropterus punctulatus), largemouth bass (M. salmoides) and other bass hybrids), 

11 bluegill (Lepomis macrochirus), channel catfish (Ictalurus punctatus), and blue catfish 

12 (I. furcatus), white crappie (Pomoxis annularis), black crappie (P. nigromaculatus), golden 

13 shiners (Notemigonus crysoleucas), emerald shiners (Notropis atherinoides), and warmouth 

14 (L. gulosus). In addition, popular introduced sports fish include: striped bass (Morone saxatilis) 

15 and walleye. Commercial fishing along the reach of the Red River in Fannin County is limited to 

16 collection of bait fish, e.g., the Mississippi silvery minnow (Hybognathus nuchalis) (Thomas et 

17 al. 2007; Hassan-Williams and Bonner 2009). The centrachids (largemouth and spotted bass, 

18 bluegill, crappies, and warmouth) would all be found in lakes, rivers and smaller flowing 

19 tributaries. The bass and warmouth are top carnivores, whereas the bluegill and crappies are 

20 insectivores. Alligator gar and catfish are top carnivores and are found primarily in larger 

21 waterbodies, like rivers and reservoirs. The golden and emerald shiners, cyprinids species, are 

22 found in lakes, rivers and smaller flowing tributaries, feeding on various aquatic insects. The 

23 Mississippi silvery minnow would only be found in rivers and smaller tributaries where it feeds 

24 on soft substrate collecting algae and other organic matter (Thomas et al. 2007; Hassan25 Williams and Bonner 2009). 

26 There are no Federally listed aquatic species or designated critical habitat in the vicinity of the 

27 Red 2 site. However, TPWD has identified numerous rare and protected aquatic species in 

28 Fannin County. The State-listed rare and protected fish species include: Western sand darter 

29 (Ammocrypta clara), orangebelly darter (Etheostoma radiosum), goldeye (Hiodon alosoides), 

30 and taillight shiner (Notropis maculates) (TPWD 2009i). These state rare and protected fish are 

31 thought to be in the Red River and its tributaries and could be found in the vicinity of the Red 2 

32 alternative site (Thomas et al. 2007; Hassan-Williams and Bonner 2009). The State-listed 

33 threatened fish species include: blue sucker (Cycleptus elongates), creek chubsucker 

34 (Erimyzon oblongus), blackside darter (Percilla maculata), paddlefish (Polyodon spathula), and 

35 shovelnose sturgeon (Scaphirhynchus platorynchus) (Table 9-11). Currently, blue suckers and 

36 paddlefish are not known to occur in the Red River above the confluence with the Kiamichi 

37 River, which is below the site (Thomas et al. 2009; Hassan-Williams and Bonner 2009). At one 

38 time, the shovelnose sturgeon was probably found throughout the river systems in Texas, but 
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1 today, its distribution has been reduced to the Red River below Denison Dam (below Lake 

2 Texoma Reservoir). The distribution of the blackside darter is now restricted to the streams and 

3 tributaries of the Red River basin, where it feeds on various aquatic insects and crustaceans. 

4 The darter is known to migrate from feeding areas in small to medium rivers to spawning areas 

5 in small tributaries along riffle areas. The creek chubsucker is found in streams associated with 

6 the Red River, where it feeds on aquatic insects, mollusks and crustaceans. They may spawn 

7 in shallow areas over a variety of substrates (Thomas et al. 2007; Hassan-Williams and Bonner 

8 2009; TPWD 2009i). There are no specific studies for these State-listed species in the vicinity 

9 of the Red 2 alternative site (STPNOC 2009a). 

10 Table 9-11. State-Listed Aquatic Species that are Endangered, Threatened, and Species of 

11 Concern for Fannin County 

Scientific Name Common Name State Status

Fish 

Cycleptus elongates blue sucker T 

Erimyzon oblongus creek chubsucker T 

Percilla maculata Blackside darter T 

Polyodon spathula paddlefish T 

Scaphirhynchus platorynchus shovelnose sturgeon T 

Source: State species information provided by TPWD, (TPWD 2009d; 35 Texas Register 249) 

T = State Listed Threatened. 

12 The State-listed rare and protected, non-fish species include a number of freshwater mussels: 

13 rock pocketbook (Arcidens confragosus), Wabash pigtoe (Fusconaia flava), plain pocketbook 

14 (Lampsilis cardium), White heelsplitter (Lasmigona complanata), common pimpleback 

15 (Quadrula pustulosa), pistolgrip (Tritogonia verrucosa), and fawnsfoot (Truncilla donaciformis). 

16 Not much is known about the distribution of these mussels in Fannin County. However, these 

17 types of freshwater mussels, known as unioid mussels, are found in various water flows, from 

18 fast moving riffles in streams to quiescent ponds. Each species has adapted to a particular flow 

19 regime. These unioid mussels have a larval stage called a glochidium. For glochidia to mature 

20 to juvenile mussels, they must live as a parasite in the gill tissues of a host fish. An important 

21 component to the distribution of freshwater mussels in various water bodies is associated with 

22 the relationship between the mussels and the host fish (Strayer 2008). However, for these 

23 mussel species the host fish species have not been identified. 

24 Building Impacts 

25 Impacts of building a cooling water reservoir may be significant depending on the siting of the 

26 reservoir. At the Red 2 site, the building of a reservoir would flood portions of Brushy Creek 

27 (STPNOC 2009a). Impacts from onsite building activities that have the potential to cause 

28 erosion and sedimentation to the local water bodies would be controlled or minimized by the 

29 implementation of an SWPPP (STPNOC 2009a). During the site visit, observations of the site 
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March 2010 9-71 Draft NUREG-1937 

1 via public roads indicated that there are streams present that are either perennial or intermittent, 

2 and supply water to the major drainages (including Bois d’Arc Creek, Sheep Creek, and Pattillo 

3 Branch)(NRC 2009b). There are no known surveys or studies of the aquatic resources within 

4 these drainages. Inundation of small flowing streams would affect those aquatic resources that 

5 have specific habitat requirements. Fish species that have habitat requirements associated with 

6 lotic systems (flowing water) are often replaced with species more suited to lentic environments 

7 (standing water) (Linam et al. 2002). Habitat for these lotic species would likely be lost when 

8 these water bodies are inundated with the reservoir, including any spawning areas for fish 

9 species that are dependent on flowing water, e.g., the blackside darter. Most freshwater mussel 

10 species are also adapted to a specific flow regime, and the inundation of stream environments 

11 for the reservoir could affect their distribution in the region (STPNOC 2009a; TPWD 2009i). 

12 Assuming that aquatic species are ubiquitous in the Red River drainage, and that the habitat 

13 types provided by the drainages mentioned above are also represented elsewhere in the Red 

14 River drainage, the impacts from the building the cooling water reservoir would not destabilize 

15 the aquatic populations of the region. 

16 New cooling water intake and discharge structures in addition to a cooling water reservoir would 

17 be required at the Red 2 site (STPNOC 2009a). Building of a new intake and discharge 

18 structure in the Red River would likely require dredging, pile driving, and other major alterations 

19 to the shoreline and benthic aquatic habitat. These activities would require permits from the 

20 Corps and the State of Texas. Building of these structures on the Red River would result in the 

21 temporary displacement of aquatic biota within the vicinity of both structures. It is expected that 

22 these biota would return to or recolonize the area after construction is complete. Sedimentation 

23 due to disturbances of the river bank and bottom during building activities could affect local 

24 benthic populations. However, the impacts on aquatic organisms would be temporary and 

25 largely mitigable through implementation of an SWPPP and by use of BMPs (e.g., silt screens) 

26 (STPNOC 2009a). 

27 Building transportation routes (heavy haul road or railroad spur), transmission corridors, and 

28 pipelines for the Red 2 site would also result in the temporary displacement of aquatic biota. 

29 Locations for these systems have not been identified. Expansion of existing corridors is 

30 expected to result in minor environmental impacts, while building in new corridors could result in 

31 more significant impacts. Building these corridors would use BMPs to reduce impacts such that 

32 they would be temporary and localized (STPNOC 2009a). 

33 Building the cooling water reservoir for the two new nuclear reactors at the Red 2 site would 

34 inundate onsite water bodies and flood a portion of Brushy Creek. The habitat for the aquatic 

35 resources would change, and since most species cannot adapt to the reservoir environment, the 

36 species would be lost to the site. Thus, the building of the cooling water reservoir would be 

37 noticeable but not destabilizing to the aquatic resources. Building the intake and discharge 

38 structures on the Red River and in the new reservoir would affect the aquatic communities but 
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Draft NUREG-1937 9-72 March 2010

1 the areas would be recolonized after building of these structures was completed. Building of the 

2 transportation routes, transmission corridors, and pipelines would result in temporary and 

3 localized effects on aquatic communities. 

4 Operation Impacts 

5 To operate two new units at the Red 2 site, water rights for the Red River would have to be 

6 acquired. Currently, there are not sufficient water rights aggregated to a single point of 

7 diversion to support the water needed for the Red 2 site (Section 9.3.2.2). The Red River water 

8 levels and water quality in the vicinity of where an intake structure on the Red River could be 

9 located is influenced by releases from Lake Texoma Reservoir. Instream flow studies 

10 necessary to maintain aquatic resources have not been evaluated for this reach of the river, and 

11 effects on aquatic resources associated with removal of water for the new reservoir are 

12 unknown. 

13 Impingement, entrainment, and entrapment of organisms from the Red River and from a 

14 constructed reservoir would likely be the most significant impacts to the aquatic population that 

15 could occur from operation of two new nuclear units at the Red 2 site. STPNOC states that 

16 using a closed-cycle cooling system with a cooling water reservoir would consume a maximum 

17 of 50,000 ac-ft of water per year (STPNOC 2009a). While the Red River is considered to be 

18 saline and of poor water quality (STPNOC 2009a), the river is known to support populations of 

19 aquatic biota that have acclimated and thrived under those conditions (Thomas et al. 2007; 

20 Hassan-Williams and Bonner 2009; McCord 2009). EPA’s design criteria for 316(b) Phase 1 

21 regulations (66 FR 65256) for intake structures would minimize impacts to aquatic biota in the 

22 Red River. The design criteria include: (1) closed-cycle cooling system that meets the EPA’s 

23 Phase I regulations for new facilities; (2) maximum through-screen velocity of 0.15 m/s (0.5 ft/s) 

24 at the cooling water intake; and (3) intake flow of less than or equal to 5 percent of the mean 

25 annual flow (STPNOC 2009a). Compliance with these regulations would minimize 

26 impingement, entrainment, and entrapment impacts to the aquatic biota. 

27 Operational impacts associated with water quality, physical and thermal characteristics of the 

28 discharge cannot be determined without additional detailed analysis. The water quality of a 

29 cooling water reservoir could be maintained by addition of water from the Red River. A cooling 

30 water reservoir for the Red 2 site would likely evolve in a similar fashion to the MCR at the STP 

31 site, where, with time, the reservoir has developed similar aquatic resources to that in the lower 

32 Colorado River and acclimated to the discharges of the operating reactor units. Impacts to the 

33 Red River would depend on the type of cooling system for the new units, including the volume, 

34 frequency, and water characteristics of the discharge. These types of impacts can be addressed 

35 and minimized through operational procedures and the permitting process with TCEQ. 

36 Operational impacts to aquatic biota from onsite activities and in the transmission line and 

37 pipeline corridors would also be minimal assuming BMPs are used for corridor maintenance. 
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March 2010 9-73 Draft NUREG-1937 

1 SWPPPs would ensure that impacts to biota from erosion and sedimentation would be minimal 

2 through the use of silt screens and controls for managing stormwater. These controls would be 

3 important for habitat quality and survival of benthic biota in the downstream drainages. 

4 Based on operation of the cooling water system (CWS), impacts to aquatic communities in the 

5 Red River and reservoir could result from impingement, entrainment, and entrapment as well as 

6 thermal, chemical, and physical characteristics of the discharge. STPNOC commits to 

7 compliance with State and Federal regulations for operation of intake and discharge structures 

8 that would be protective of aquatic resources. Once a community is established in the new 

9 reservoir, long-term effects from operation of the CWSs are not expected to noticeably alter 

10 aquatic communities in the Red River and reservoir. 

11 Cumulative Impacts 

12 Within all parts of the Red River drainage between the Denison Dam (below Lake Texoma 

13 Reservoir) and the confluence of the Red River with the Kiamichi River, the local aquatic 

14 resources have adapted to the construction of Valley Lake for the Valley Power Plant, but may 

15 be affected by the building of future planned power plants. The aquatic resources of Brushy 

16 Creek and the Red River adapted to the construction of Valley Lake and the water needs for the 

17 Valley Power Plant. Valley Lake is open to the public for recreational fishing. In 2008, the 

18 Pattillo Branch Power Company, LLC, submitted a permit application to TCEQ for construction 

19 of a gas-powered electric-generating plant approximately 3 mi south of the Red 2 site (TCEQ 

20 2009a). The construction of this plant would likely have similar impacts to the aquatic biota as 

21 those discussed for the building of the Red 2 site. If the proposed Pattillo power plant also 

22 includes a reservoir, the cumulative loss of stream and drainage habitat would be greater than 

23 the loss of habitat from the Red 2 reservoir. In addition, these actions may affect water flow to 

24 Bois d’Arc Creek and degrade the biological function of this water body that is designated as an 

25 ecologically significant stream segment. 

26 The Red River below Lake Texoma Reservoir has numerous tributaries, including Brushy Creek 

27 and Valley Lake. It is assumed that the proposed new Pattillo Branch Power Plant would divert 

28 additional water from the Red River. The Corps and TCEQ would evaluate as part of 

29 considering the aggregation of water rights for the proposed Red 2 site if the instream flow in 

30 the Red River for the existing Valley Power Plant, the proposed Pattillo Branch Power Plant, 

31 and the two new units at Red 2 would be sufficient for protection of aquatic life (NRC 2009b). If 

32 instream flows are insufficient for protection of aquatic life, TCEQ could make changes to 

33 available water rights, and that could affect the water availability for future power production 

34 facilities (NRC 2009b). Of particular concern would be the potential to affect the State-listed 

35 species in the area, e.g., the shovelnose sturgeon that now has a distribution limited to the Red 

36 River (Thomas et al. 2007; Hassan-Williams and Bonner 2009; TPWD 2009i). 
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Draft NUREG-1937 9-74 March 2010

1 Continued urbanization and agricultural practices could affect aquatic communities in the Red 2 

2 geographic area of interest in the foreseeable future. Expansion of urban areas in the Red 

3 River drainage could increase water use, decrease available water for aquatic resources, and 

4 increase nonpoint pollution. The effects of continued agricultural practices could result in 

5 additional habitat loss and/or degradation due to irrigation using surface waters and 

6 groundwater withdrawal, point and non-point source pollution, siltation, and bank erosion. 

7 As mentioned above in the terrestrial section, GCC could result in regional increases in the 

8 frequency of severe weather, decreases in annual precipitation, and increases in average 

9 temperature (Karl et al. 2009). The decrease in precipitation combined with elevated water 

10 temperatures and evaporation could result in more frequent droughts, which could reduce 

11 aquatic habitat. Loss of habitat could cause shifts in species ranges, diversity, and abundance 

12 in the geographic area of interest for the Red 2 site (Karl et al. 2009). Specific predictions on 

13 potential impacts to aquatic species and their habitat in this region resulting from GCC are 

14 inconclusive at this time. Because of the regional nature of climate change, the impacts related 

15 to GCC would be similar for all the alternative sites, as they are all in the Great Plains Region. 

16 Based on building and operation of two new nuclear units at the Red 2 alternative site and other 

17 projects and influences in the region of influence for aquatic resources, the cumulative impacts 

18 would be noticeable but not destabilizing. All these activities would alter the aquatic habitats 

19 and potentially change the species composition and diversity in the affected water bodies. The 

20 incremental contribution of building and operating the two new reactors at the Red 2 site to the 

21 cumulative impacts within the geographic area of interest would be substantial. 

22 Summary 

23 STPNOC has indicated that building of a cooling water reservoir at the Red 2 site would 

24 inundate existing water bodies and destroy habitat for aquatic resources that are dependent on 

25 flowing water. The review team concludes that the impacts from building two new nuclear units 

26 at the Red 2 site would be noticeable but not destabilizing to the aquatic resources. The review 

27 team also concludes that the impacts from operation of two new units would be minimal. Based 

28 on the information provided by STPNOC and the review team’s independent evaluation, the 

29 review team concludes that the cumulative impacts of building and operating two new reactors 

30 on the Red 2 site combined with other past, present, and future activities on most aquatic 

31 resources in the Red River drainage would be MODERATE. The incremental contribution of 

32 building and operating the two new reactors at the Red 2 site to the cumulative impacts within 

33 the geographic area of interest would be significant. 

34 9.3.2.5 Socioeconomics 

35 The following impact analysis includes impacts from building activities and operations. The 

36 analysis also considers other past, present, and reasonably foreseeable future actions that 
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March 2010 9-75 Draft NUREG-1937 

1 impact socioeconomics, including other Federal and non-Federal projects listed in Table 9-8. 

2 For the analysis of socioeconomic impacts at the Red 2 site, the geographic area of interest is 

3 considered to be the 50 mi region centered on the Red 2 site with special consideration of 

4 Fannin and Grayson Counties as that is where the review team expects socioeconomic impacts 

5 to be the greatest. In evaluating the socioeconomic impacts of site development and operation 

6 at the Red 2 site near Savoy in Fannin County, the review team undertook a reconnaissance 

7 survey of the site using readily obtainable data from the Internet or published sources. 

8 Physical Impacts 

9 Many of the physical impacts of building and operation would be similar regardless of the site. 

10 Building activities can cause temporary and localized physical impacts such as noise, odor, 

11 vehicle exhaust, vibration, shock from blasting (if used), and dust emissions. The use of public 

12 roadways, railways, and waterways would be necessary to transport construction materials and 

13 equipment. Offsite areas that would support building activities (e.g., borrow pits, quarries, and 

14 disposal sites) would be expected to be already permitted and operational. 

15 Potential impacts from station operation include noise, odors, exhausts, thermal emissions, and 

16 visual intrusions (the latter are discussed under aesthetics and recreation). New units would 

17 produce noise from the operation of pumps, cooling towers, transformers, turbines, generators, 

18 and switchyard equipment. Traffic at the site also would be a source of noise. Any noise 

19 coming from the proposed STP site would be controlled in accordance with standard noise 

20 protection and abatement procedures. This practice also would be expected to apply to all 

21 alternative sites, including the Red 2 site. Commuter traffic would be controlled by speed limits. 

22 Good road conditions and appropriate speed limits would minimize the noise level generated by 

23 the workforce commuting to the alternative site. 

24 The new units at the Red 2 site would likely have standby diesel generators and auxiliary power 

25 systems. Permits obtained for these generators would ensure that air emissions comply with 

26 applicable regulations. In addition, the generators would be operated on a limited, short-term 

27 basis. During normal plant operation, new units would not use a significant quantity of 

28 chemicals that could generate odors that exceed odor threshold values. Good access roads 

29 and appropriate speed limits would minimize the dust generated by the commuting workforce. 

30 Based on the information provided by STPNOC and the review team’s independent evaluation, 

31 the review team concludes that the physical impacts of building and operating two nuclear units 

32 at the Red 2 site would be minimal. 

33 Demography 

34 The Red 2 site is located in Fannin County, 3.7 mi north of the city of Savoy (2008 population 

35 895) and 12.2 mi southeast of Denison (2008 population 24,001), approximately 20 mi east of 

36 Sherman (2008 population 38,077) and within 50 mi of the outer edges of the Dallas-Fort Worth 
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1 (DFW) Metroplex (2008 population 6,300,006) (USCB 2009a). The Sherman-Denison 

2 metropolitan area (located in Grayson County) has an estimated 2008 population of 118,804 

3 (USCB 2009b). After World War II, Fannin County’s population declined up until the 1970s 

4 when it slowly began to rise again to its current 2008 population of 33,229 (TSHA 2009c). 

5 STPNOC estimated the peak number of building workers would be 5950. Approximately 900 

6 operations workers would also be onsite during the final phase of building activities (STPNOC 

7 2008c). Based on assumptions in Section 4.4 concerning in-migration for Units 3 and 4 in 

8 Matagorda County, the review team assumed that 50 percent or 2975 construction workers 

9 would in-migrate, with half of these assumed to move to Fannin County and the other half to 

10 Grayson County. Collin County and other counties nearer Dallas-Fort Worth would likely see an 

11 in-migration of workers as well, but considering the large populations of these counties and the 

12 relatively small number of in-migrants they would be easily absorbed with no measurable 

13 impact. Eighty percent of in-migrating construction workers would bring a family. All operations 

14 workers would in-migrate and all would bring a family. A family size of 3.25 was used for 

15 construction workers for a total peak site development related population increase of 8330 

16 (7735 in-migrating workers and family members and 595 workers without family). The average 

17 family size of 2.74 for the operating workforce (see Section 5.4) would result in a total in18 migrating operations-related population of 2466 (900 operations workers plus family). 

19 Therefore, the total expected in-migrating population (site development and operations) at peak 

20 building would be 10,796. 

21 Since the assumed in-migrating population during the building period would be less than 5 

22 percent of the total population for Grayson County and 16 percent for Fannin County, the 

23 demographic impacts of site development are expected to be much less for Grayson County 

24 than for the smaller Fannin County. If the facility is constructed and commences operations, the 

25 operational workforce would number about 959 workers, 900 of whom would already be at the 

26 site during peak site development and are included in the above analysis, meaning that there 

27 would be very little demographic impact during operations in either county. Based on the 

28 information provided by STPNOC and the review team’s independent evaluation, the review 

29 team concludes that the demographic impacts of building and operating two nuclear units at the 

30 Red 2 site would be noticeable mainly in Fannin County during the building period, because of 

31 the relatively significant ratio of in-migrating to resident population. 

32 Taxes and Economy 

33 Tax revenues to the local economies and the State would come in several different forms, as 

34 discussed in Sections 4.4 and 5.4. As described in Section 5.4.3.2, STPNOC estimates it would 

35 spend $60 million on annual expenditures for goods and services related to the new units of 

36 which about 20 percent ($12 million) would be spent locally (STPNOC 2008b). STPNOC 

37 estimated if the units were 100 percent taxable, annual franchise taxes for Units 3 would be 
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March 2010 9-77 Draft NUREG-1937 

1 $4.7 to $5.4 million and Unit 4 would have payments of $3.9 to $4.7 million per year, which 

2 would represent less than 1 percent of the State’s annual franchise tax revenues. 

3 Based on the assumptions and methodology detailed in Section 5.4.3.2, the review team 

4 estimated that annual property taxes would range from $6.10 million to $13.86 million, which 

5 would represent a 73 to 165 percent increase over the 2008 Fannin County taxes levied of 

6 $8.4 million. Savoy Independent School District (ISD) may also receive tax benefits from the 

7 hypothetical new reactors (STPNOC 2009a). 

8 Economic impacts would be spread across the 50-mi region but would be greatest in Fannin 

9 County and to a lesser extent Grayson County. Fannin County per capita income for 2007 was 

10 $25,258 and $28,901 for Grayson County. The 2008 unemployment rate for Fannin County and 

11 Grayson County was 5.9 percent and 5.3 percent, respectively (Texas Association of Counties 

12 2009a, b) The wages and salaries of the building and operations workforce would stimulate the 

13 economy and could result in increases in business activity, particularly in the retail and service 

14 sectors. This would have a positive impact on the business community and could provide 

15 opportunities for new businesses and increased job opportunities for local residents. Based on 

16 the information provided by STPNOC and the review team’s independent evaluation, the review 

17 team concludes that the tax and economic impacts of building and operating two nuclear units 

18 at the Red 2 site would be significant. 

19 Transportation and Housing 

20 Primary access to the site is from the south on U.S. Route 82 which runs between Sherman and 

21 Bonham. U.S. 82 is four-lanes in Grayson County but narrows to two-lanes before entering 

22 Fannin County. Commuters from Denison would use U.S. 69 to its intersection with U.S. 82. 

23 Other secondary roads serving the site are Farm-to-Market (FM) 1897, FM 1753 and FM 1752 

24 (provides access to Valley Plant). All three of these roads are two-lanes and in good condition 

25 (STPNOC 2009b). The Red 2 site is accessed by a one lane unimproved road not maintained 

26 by Texas Department of Transportation (TXDOT) that would need major upgrades and a portion 

27 of FM 1752 that would need widening (STPNOC 2009a). The most likely pinch points would be 

28 the intersection of U.S. 69 and U.S. 82 and also at FM 1897 and FM 1752. Approximately 

29 4.2 mi of rail would need to be constructed (STPNOC 2009a). The review team expects the 

30 transportation impacts from site development of a plant at the Red 2 site could be noticeable 

31 and may change traveler behavior, depending on commuter patterns of the workers at the Red 

32 2 site and those at the Valley Power Plant and would warrant mitigation. Operation impacts 

33 would be significantly lower than the building phase impacts of traffic due to the much smaller 

34 workforce and because roads would have been improved during the building phase. 

35 The U.S. Census Housing Profile for Fannin County estimated a total housing stock of 13,571 

36 units with a rental vacancy rate of 8.5 percent. Approximately 2146 housing units were 

37 unoccupied at the time of the survey (USCB 2009b). The U.S. Census Housing Profile for 
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1 Grayson County estimated a total housing stock of 51,733 units with a rental vacancy rate of 7.6 

2 percent. Approximately 7103 housing units were unoccupied at the time of the survey (USCB 

3 2009c). The review team expects that the in-migrating workforce could be absorbed into the 

4 existing housing stock in Grayson County and the region without a measureable impact, but the 

5 impacts to Fannin County could be more significant, given the small number of vacant housing 

6 units. Based on the information provided by STPNOC and the review team’s independent 

7 evaluation, the review team concludes that the transportation and housing impacts of building 

8 and operating two nuclear units at the Red 2 site would be noticeable. 

9 Public Services and Education 

10 In-migrating construction workers and plant operations staff would likely impact local municipal 

11 water, wastewater treatment facilities, and other public services in the region. These impacts 

12 would likely be in proportion with the demographic impacts experienced in the region, unless 

13 these resources have excess capacity or are particularly strained during building, which would 

14 decrease or increase the impact, respectively. For example, the largest water treatment 

15 facilities in both Fannin County and Grayson County have water capacity available that is 

16 roughly two to five times current average daily consumption (EPA 2009b; TCEQ 2010a), so 

17 while Fannin County in particular may have to build considerable distribution infrastructure, 

18 neither county is likely to be water capacity limited. The in-migrating workers represent a small 

19 portion of the total population of Grayson County and would likely not have a noticeable impact 

20 on their public services. In the smaller Fannin County impacts could place a strain on some 

21 public services, based on the county’s proportionally larger in-migrating workforce population. 

22 During operations the impact on public services would likely be minimal. 

23 Fannin County has nine independent school districts with 25 schools, and Grayson County has 

24 13 independent school districts with 69 schools. The 2007-2008 student enrollments for Fannin 

25 and Grayson Counties are 5620 students and 21,081 students, respectively (NCES 2009). The 

26 review team expects a peak building-related increase of about 2537 students (1269 in each 

27 county). The in-migrating students would likely represent a noticeable but not significant impact 

28 to schools in Grayson County due to the 6 percent increase in overall students. However, the 

29 increase would be a 23 percent increase in the student population in Fannin County, where the 

30 review team expects the impact to be significant and potentially destabilizing to this school 

31 system. During operation, this impact on schools would be significantly less due to the lower 

32 number of in-migrating students. Based on the information provided by STPNOC and the 

33 review team’s independent evaluation, the review team concludes that the public service and 

34 education impacts of building and operating two nuclear units at the Red 2 site would be 

35 significant. 
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1 Aesthetics and Recreation 

2 Recreation in the area includes historic Texas Lakes Trail, Lake Davy Crockett Recreational 

3 Area, Caddo Wildlife Management Area (WMA) and Ray Roberts Lake State Park and WMA. 

4 These areas offer boat access, picnicking and camping. The Red 2 site is located near Valley 

5 Lake which supports the Valley Power Plant. Any recreation that occurs on Valley Lake is 

6 private but would be affected by building the nuclear plant (STPNOC 2009a). The building and 

7 operation of transmission lines to support the site also would have an aesthetic impact on the 

8 region. The NRC review team concludes that the visual impact associated with site 

9 development and operation of two tall, relatively isolated nuclear units on this site would have a 

10 noticeable impact on the visual aesthetic resources in the area. Impacts on aesthetic resources 

11 would not be destabilizing because these resources are already significantly affected by the 

12 presence of the nearby Valley Power Plant. The nuclear plant would not adversely affect 

13 boating access or access to picnicking or camping sites, therefore, it is expected that there 

14 would be minimal impacts on recreation. Based on the information provided by STPNOC and 

15 the review team’s independent evaluation, the review team concludes that the aesthetic and 

16 recreation impacts of building and operating two nuclear units at the Red 2 site would be 

17 noticeable. 

18 Summary of Project-Related Socioeconomic Impacts 

19 Physical impacts on workers and the general public include impacts on existing buildings, 

20 transportation, aesthetics, noise levels, and air quality. Social and economic impacts span 

21 issues of demographics, economy, taxes, infrastructure, and community services. In summary, 

22 on the basis of information provided by STPNOC and the review team’s independent evaluation, 

23 the review team concludes that the impacts of the building and operation of two nuclear units at 

24 the Red 2 site on socioeconomics would be minimal and adverse for Grayson County and most 

25 of the region but could be noticeable but not destabilizing for Fannin County in terms of 

26 transportation, housing, and public services and significant and potentially destabilizing for 

27 education impacts during the building phase. During operation, these impacts are expected to 

28 be minimal. The impacts on aesthetics are expected to be noticeable but not destabilizing. The 

29 impacts on the Fannin County economy and tax base during plant development and operation 

30 likely would be significant and beneficial. 

31 Cumulative Impacts 

32 For the analysis of socioeconomic impacts at the Red 2 site, the geographic area of interest is 

33 considered to be the 50-mi region centered on the Red 2 site with special consideration of 

34 Fannin and Grayson Counties as that is where the review team expects socioeconomic impacts 

35 to be the greatest. Fannin County has historically had an agricultural based economy centered 

36 mainly on cotton but during the late 20th century wheat was the only major crop to increase 

37 production as did several other small crops. Stock farming moved from milk cattle to beef cattle 
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1 and Fannin County also saw an increase in banking and service businesses after World War II. 

2 With the opening of the first oilfield in Grayson County in the 1930s the local economy was 

3 changed. By 1970, the County was producing 120 million barrels of oil a day and became a 

4 manufacturing and trade center in the 1970’s and 1980’s with 50 percent of the labor force 

5 employed in these two sectors (THSA 2009c, d). After World War II Fannin County’s population 

6 declined up until the 1970s when it slowly began to rise again to its current 2008 population of 

7 33,229 (Handbook of Texas Online 2009). 

8 In addition to assessing the marginal socioeconomic impacts from the building and operations of 

9 two additional nuclear units on the Red 2 site, the cumulative impact is also considered. The 

10 cumulative analysis considers other past, present, and reasonably foreseeable future actions 

11 that could contribute to the cumulative socioeconomic impacts on a given region, including other 

12 Federal and non-Federal projects and those projects listed in Table 9-8. For the analysis of 

13 socioeconomic impacts at the Red 2 site, the geographic area of interest is considered to be the 

14 50-mi region centered on the Red 2 site. 

15 The projects identified in Table 9-8 have or would contribute to the demographics, economic 

16 climate, and community infrastructure of the region and generally result in increased 

17 urbanization and industrialization. However, many impacts such as those on housing or public 

18 services are able to adjust over time, particularly with increased tax revenues. Furthermore, 

19 state and county plans along with modeled demographic projections include forecasts of future 

20 development and population increases. Because the other projects described in Table 9-8 do 

21 not include any significant reasonably foreseeable changes in socioeconomic impacts within 

22 50 mi of the Red 2 site, the review team determined there would not be any significant 

23 additional cumulative socioeconomic impacts in the region from those activities. Any economic 

24 impacts associated with activities listed in Table 9-8 would have been considered as part of the 

25 socioeconomic baseline, except for the Pattillo Branch Power Company natural gas fired power 

26 plant near Savoy. The project reportedly would create “100s” of construction jobs and 25 to 30 

27 operations jobs. The project would be completed in 2012. For that reason, Pattillo site 

28 employment would be declining just as site employment at Red 2 would be beginning. Because 

29 of this timing and Pattillo’s relatively small size, the review team does not believe that the Pattillo 

30 plant would significantly exacerbate any socioeconomic impacts from the Red 2 site. The Lake 

31 Ralph Hall project represents another reasonably foreseeable activity in Fannin County and 

32 within 30 mi of the Red 2 site, as is Bois d’Arc Creek Reservoir, located within 20 mi of the Red 

33 2 site. While these projects could impose additional socioeconomic impacts, the planned 

34 starting and completion dates and the level of activity for these projects are uncertain. 

35 Therefore, the review team concluded that for purposes of this alternative site analysis, the 

36 socioeconomic impacts of these projects could not be quantitatively evaluated. However, 

37 although the timing of the impacts is not known, the review team expects that the following 

38 effects may occur. The review team would expect temporary increases in economic activity, 

39 population and traffic during the building period; decreases in existing property tax base which 
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March 2010 9-81 Draft NUREG-1937 

1 may or may not be offset by values of recreational development and other improvements related 

2 to the reservoir. In addition, during reservoir operations, depending on the level of development 

3 (and population), there may be increases in the demand for infrastructure and community 

4 services. There is a possibility that recreational opportunities would increase. 

5 The review team concludes that the physical impacts of the building and operation of a nuclear 

6 plant at the Red 2 site would be SMALL for the entire 50 mi region. Socioeconomic impacts 

7 would be SMALL and adverse for Grayson County and most of the region but could be 

8 MODERATE and adverse for Fannin County in terms of demographic, transportation, housing, 

9 public services, and aesthetics; and LARGE and adverse for education during the building 

10 phase. The impacts on the economy and tax base during plant building and operation likely 

11 would be beneficial and LARGE in Fannin County but SMALL for the rest of the 50-mi region. 

12 Building and operating a new plant at the Red 2 site would make a significant, incremental 

13 contribution to these impact levels. 

14 9.3.2.6 Environmental Justice 

15 The following impact analysis includes impacts from building activities and operations. The 

16 analysis also considers other past, present, and reasonably foreseeable future actions that 

17 impact environmental justice, including other Federal and non-Federal projects listed in Table 9-

18 8. The cumulative environmental justice impacts were assessed for the 50-mi region centered 

19 on the Red 2 site. In 2000, the 50-mi region around the Red 2 site was characterized as 

20 5.7 percent Black, 1.7 percent American Indian and Alaskan Native, 3.6 percent Asian, 

21 0.04 percent Hawaiian and Other Pacific Islander, 4.1 percent all other races, and 2.3 percent 

22 two or more races, 9.2 percent Hispanic or Latino and 6.5 percent low-income (STPNOC 2009a). 

23 The review team identified a total of 631 census block groups within the 50-mi region (which 

24 included portions of Oklahoma), 41 of which were classified as minority populations, with one of 

25 them in Fannin County and seven of them in Grayson County. None of these populations are 

26 within 10 mi of the Red 2 alternative site. The review team also found 19 census block groups 

27 classified as low income in the 50-mi region, with none in Fannin County and 2 in Grayson 

28 County. None of these populations are within 10 mi of the Red 2 alternative site. See 

29 Figure 9-7 and Figure 9-8 for the location of minority or low-income populations within the 50-mi 

30 region. Almost all of the potential physical impacts of building and operation would occur within 

31 the vicinity of the Red 2 site and Figure 9-7 and Figure 9-8 show no minority or low-income 

32 block groups within 10 mi of the Red 2 site. The review team did not locate any minority or low33 income populations downstream of the Red 2 site on Brushy Creek or the Red River within 

34 50 mi of the Red 2 site. The review team’s analysis did not find any information suggesting that 

35 minority or low-income populations in the area were dependent on natural resources that would 

36 be adversely affected by a nuclear power plant at the Red 2 site. Finally, the review team did 

37 not identify any potential pathways by which any building or operations activity could affect any 
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Draft NUREG-1937 9-82 March 2010

1 

2 Figure 9-7. Minority Block Groups within 50 mi of the Red 2 Alternative Site
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March 2010 9-83 Draft NUREG-1937 

1 

2 Figure 9-8. Low-Income Block Groups within 50 mi of the Red 2 Alternative Site
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Draft NUREG-1937 9-84 March 2010

1 minority and low-income populations outside of Fannin and Grayson Counties. The review team 

2 determined that for the Red 2 site there would be no disproportionate and adverse impacts on 

3 minority or low-income populations from building and operating two nuclear units and therefore 

4 the environmental justice impacts can be characterized as minimal and adverse. 

5 The projects identified in Table 9-8 likely did not or will not contribute to environmental justice 

6 impacts of the region. Based on information provided by STPNOC and the review team’s 

7 independent evaluation, the review team concludes that there would likely not be any 

8 disproportionate and adverse environmental justice cumulative impacts from building and 

9 operating two nuclear units at the Red 2 site and therefore any environmental justice-related 

10 impacts would be SMALL and adverse. 

11 9.3.2.7 Historic and Cultural Resources 

12 The following impact analysis includes impacts from building activities and operations. The 

13 analysis also considers other past, present, and reasonably foreseeable future actions that 

14 impact historic and cultural resources, including other Federal and non-Federal projects listed in 

15 Table 9-8. For the analysis of cultural impacts at the Red 2 site, the geographic area of interest 

16 is considered to be the APE that would be defined for this site. This includes the physical APE, 

17 defined as the area directly affected by the site development and operation activities at the site 

18 and transmission lines, and the visual APE. The visual APE is defined as an additional 1-mi 

19 radius around the physical APE consistent with the discussion in Section 2.7 about the 

20 maximum distance from which the structures can be seen.Reconnaissance activities in a 

21 cultural resource review have particular meaning. Typically, for example, it includes preliminary 

22 field investigations to confirm the presence or absence of cultural resources. However, in 

23 developing its EISs, the review team relies upon reconnaissance-level information to perform its 

24 alternative site evaluation. Reconnaissance-level information is data that are readily available 

25 from agencies and other public sources. It can also include information obtained through visits 

26 to the site area. To identify the historic and cultural resources at the Red 2 site, the following 

27 information was used: 

28 • STPNOC ER (STPNOC 2009a) - including the Texas Historical Commission’s Texas 

29 Archeological Sites Atlas 

30 • NRC Alternative Sites Visit August 2009 

31 The Red 2 site is a greenfield site located 1.8 mi north of the existing Valley power plant. 

32 Historically, the site and vicinity were largely undisturbed and likely contained intact 

33 archaeological sites associated with the past 10,000 years of human settlement. Over time, the 

34 area has been disturbed by rural development and cleared for agricultural purposes. The 

35 physical and visual APEs if the proposed plant were to be sited at the Red 2 site do not appear 

36 to have any historic properties likely to be affected by building or operating new units. No 

37 archaeological and/or architectural surveys have been conducted at the Red 2 site. 
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March 2010 9-85 Draft NUREG-1937 

1 Nine historic properties listed on the National Register of Historic Places are found in Fannin 

2 County, Texas, but all are located more than 10 mi away from the site in towns within a 

3 protected area (Caddo National Grasslands). Six archaeological sites have been recorded 

4 along Valley Lake, within 2 mi of the Red 2 site. In addition, the Virginia Point Cemetery, which 

5 is still active, is located 0.75 mi west of the site. Near the cemetery is a Texas Historic 

6 Landmark, the Virginia Point Methodist Church, the oldest church in Fannin County (STPNOC 

7 2009a). Neither the cemetery nor the church is listed on the National Register. The project has 

8 the potential to affect resources through visual impacts from buildings and transmission lines. 

9 Should these two properties be subsequently listed on the National Register, then these impacts 

10 may result in significant alterations to the visual landscape within the geographic area of 

11 interest. 

12 To accommodate building two new nuclear generating units on the Red 2 site, STPNOC would 

13 need to clear approximately 800 ac for the main power plant site and up to 1700 ac for a new 

14 reservoir (STPNOC 2009a). In the event that the Red 2 site was chosen for the proposed 

15 project, identification of cultural resources would be accomplished through cultural resource 

16 surveys and consultation with the State Historic Preservation Officer (SHPO), tribes and 

17 interested parties. The results would be used in the site planning process to avoid cultural 

18 resources impacts. In the event significant cultural resources were identified by these surveys, 

19 the review team assumes that STPNOC would develop protective measures in a manner similar 

20 to those for the STP site. These procedures are detailed in STPNOC’s Addendum #5 to 

21 procedure No OPGP03-ZO-0025 Rev. 12 (Unanticipated Discovery of Cultural Resources) 

22 (STPNOC 2008e); the procedure includes notification of Texas Historical Commission. 

23 Section 9.3.2.1 describes the transmission line corridors. There are no existing transmission 

24 corridors connecting directly to the Red 2 site. However, there are multiple 345-kV transmission 

25 lines connecting to the Valley power plant (STPNOC 2009a). A new transmission corridor 

26 would need to be created to connect the Red 2 site to these lines. In the event that the Red 2 

27 site were chosen for the proposed project, the review team assumes that STPNOC would 

28 conduct its transmission line-related cultural resource surveys and procedures in a manner 

29 similar to that for the STP site described in Section 4.6. 

30 Past actions in the geographic area of interest that have similarly affected historic and cultural 

31 resources include rural development and agricultural development and activities associated with 

32 these land disturbing activities such as road development. No current or planned projects were 

33 identified in Table 9-8 that may contribute to cumulative impacts on historic and cultural 

34 resources in the geographic area of interest. 

35 Activities associated with building two nuclear units and supporting facilities that can potentially 

36 destabilize important attributes of historic and cultural resources include land clearing, 

37 excavation, and grading activities. Given STPNOC’s site planning process and no known 
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Draft NUREG-1937 9-86 March 2010

1 cultural resources at the Red 2 site based on reconnaissance-level information, the impacts to 

2 cultural resources due to site development activities would be negligible. 

3 Additionally, visual impacts from transmission lines may result in significant alterations to the 

4 visual landscape within the geographic area of interest. Given that there are no known cultural 

5 resources where the historic setting and character of the resources are important, the visual 

6 impacts would be negligible. The review team assumes that STPNOC would develop 

7 procedures and consult with the SHPO similar to the process developed for cultural resource 

8 management at the STP site. 

9 Impacts on historic and cultural resources from operation of two new nuclear generating units at 

10 the Red 2 site include those associated with the operation of new units and maintenance of 

11 transmission lines. The review team assumes that the same procedures currently used by 

12 STPNOC would be used for onsite and offsite maintenance activities. Consequently, the 

13 incremental effects of the maintenance of transmission-line corridors and operation of the two 

14 new units and associated impacts on the cultural resources would be negligible for the physical 

15 and visual APEs. 

16 No other activities in Table 9-8 in the geographic area of interest were identified that would 

17 significantly affect historic and cultural resources in a manner similar to those associated with 

18 the operation of two new units. 

19 Cultural resources are non-renewable; therefore, the impact of destruction of cultural resources 

20 is cumulative. Based on the information provided by the applicant and the review team’s 

21 independent evaluation, the review team concludes that the cumulative impacts from building 

22 and operating two new nuclear generating units on the Red 2 site (because there are no other 

23 projects) would be SMALL. This impact level determination reflects no known cultural resources 

24 that could be affected; however, if the Red 2 site was to be developed, then cultural resource 

25 surveys may reveal important historic properties that could result in greater cumulative impacts. 

26 9.3.2.8 Air Quality 

27 The following impact analysis includes impacts from building activities and operations. The 

28 analysis also considers other past, present, and reasonably foreseeable future actions that 

29 impact air quality, including other Federal and non-Federal projects listed in Table 9-8. The 

30 geographic area of interest for the Red 2 site is Fannin County, which is in the Metropolitan 

31 Dallas-Fort Worth Intrastate Air Quality Control Region (40 CFR 81.39). 

32 The emissions related to building and operating a nuclear power plant at the Red 2 alternative 

33 site would be similar to those at the STP site. The air quality attainment status for Fannin 
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March 2010 9-87 Draft NUREG-1937 

1 County as set forth in 40 CFR 81.344 reflects the effects of past and present emissions from all 

2 pollutant sources in the region. Fannin County is not out of attainment of any National Ambient 

3 Air Quality Standard. 

4 The atmospheric emissions related to building and operating a nuclear power plant at the STP 

5 site in Matagorda County, Texas, are described in Chapters 4 and 5. The criteria pollutants 

6 were found to have a SMALL impact. In Chapter 7, the cumulative impacts of the criteria 

7 pollutants at the STP site were evaluated and also determined to be MODERATE principally 

8 because of a nearby major source; absent that source, the cumulative impacts would be 

9 SMALL. 

10 Reflecting on the projects listed in Table 9-8, the most significant are the Valley Power Plant 

11 and the Pattillo Branch Power Plant. Effluents from power plants such these are typically 

12 released through stacks and with significant vertical velocity. Other industrial projects listed in 

13 Table 9-8 would have de minimis impacts. Given that these projects would be subject to 

14 institutional controls, it is unlikely that the air quality in the region would degrade to the extent 

15 that the region is in nonattainment of National Ambient Air Quality Standards. 

16 The air quality impact of Red 2 site development would be local and temporary. The distance 

17 from building activities to the site boundary would be sufficient to generally avoid significant air 

18 quality impacts. There are no land uses or projects, including the aforementioned sources, that 

19 would have emissions during site development that would, in combination with emissions from 

20 the Red 2 site, result in degradation of air quality in the region. 

21 Releases from operation of two units at the Red 2 site would be intermittent and made at low 

22 levels with little or no vertical velocity. The air quality impacts of the Valley Power Plant are 

23 included in the baseline air quality status. The air quality impacts of the Pattillo Branch Power 

24 Plant would be similar to the air quality impacts discussed in Section 9.2.2.2, which could be 

25 noticeable but not destabilizing. The cumulative impacts from emissions of effluents from the 

26 Red 2 site and the aforementioned sources could be noticeable but not destabilizing. 

27 The cumulative impacts of greenhouse gas emissions related to nuclear power are discussed in 

28 Section 7.5. The impacts of the emissions are not sensitive to location of the source. 

29 Consequently, the discussion in Section 7.5 is applicable to a nuclear power plant located at the 

30 Red 2 site. The review team concludes that the national and worldwide cumulative impacts of 

31 greenhouse gas emissions are noticeable but not destabilizing. The review team further 

32 concludes that the cumulative impacts would be noticeable but not destabilizing, with or without 

33 the greenhouse gas emissions of the project at the Red 2 site. 

34 Cumulative impacts to air quality resources are estimated based in the information provided by 

35 STPNOC and the review team’s independent evaluation. Other past, present and reasonably 
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1 foreseeable future activities exist in the geographic areas of interest (local for criteria pollutants 

2 and global for greenhouse gas emissions) that could affect air quality resources. The 

3 cumulative impacts on criteria pollutants from emissions of effluents from the Red 2 site, other 

4 projects, and the Valley Power Plant and the Pattillo Branch Power Plant could be noticeable 

5 but not destabilizing, principally as a result of the contribution of these two sources. The 

6 national and worldwide cumulative impacts of greenhouse gas emissions are noticeable but not 

7 destabilizing. The review team concludes that the cumulative impacts would be noticeable but 

8 not destabilizing, with or without the greenhouse gas emissions from the Red 2 site. The review 

9 team concludes that cumulative impacts from other past, present, and reasonably foreseeable 

10 future actions on air quality resources in the geographic areas of interest would be SMALL to 

11 MODERATE for criteria pollutants and MODERATE for greenhouse gas emissions. The 

12 incremental contribution of impacts on air quality resources from building and operating two 

13 units at the Red 2 site would be insignificant for both criteria pollutants and greenhouse gas 

14 emissions. 

15 9.3.2.9 Nonradiological Health 

16 The following impact analysis includes impacts from building activities and operations. 

17 The analysis also considers other past, present, and reasonably foreseeable future actions 

18 that impact nonradiological health, including other Federal and non-Federal projects listed in 

19 Table 9-8. For the analysis of nonradiological health impacts at the Red 2 alternative site, the 

20 geographic area of interest is considered to include projects within a 5-mi radius from the site’s 

21 center based on the localized nature of the impacts. For impacts associated with transmission 

22 lines, the geographic area of interest is the transmission line corridor. 

23 The building activities that have the potential to impact the health of members of the public and 

24 workers include exposure to dust and vehicle exhaust, occupational injuries, noise, and the 

25 transport of construction materials and personnel to and from the site. The operation-related 

26 activities that have the potential to impact the health of members of the public and workers 

27 includes exposure to etiological agents, noise, EMFs, and impacts from the transport of workers 

28 to and from the site. 

29 Building Impacts 

30 Nonradiological health impacts to construction workers and members of the public from building 

31 two new nuclear units at the Red 2 site would be similar to those evaluated in Section 4.8 for the 

32 STP site. The impacts include noise, vehicle exhaust, dust, occupational injuries, and 

33 transportation accidents, injuries, and fatalities. Applicable Federal and State regulations on air 

34 quality and noise would be complied with during the site preparation and building phase. The 

35 incidence of construction worker accidents would not be expected to be different from the 
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March 2010 9-89 Draft NUREG-1937 

1 incidence of accidents estimated for the STP site. The Red 2 site is located in a rural area and 

2 nonradiological health impacts from building would likely be negligible on the surrounding 

3 populations. 

4 The ER (STPNOC 2009a) indicated that there may be significant impacts on the transportation 

5 network in the vicinity of the Red 2 site and mitigation would be warranted. The impacts in the 

6 vicinity of the Red 2 site include traffic associated with the existing Valley Power Plant. 

7 Interactions between the traffic destined for the Red 2 site nuclear power plant project and the 

8 Valley Power Plant are likely to increase the nonradiological health effects from traffic accidents 

9 in the vicinity of the Red 2 site. The additional injuries and fatalities from traffic accidents 

10 involving transportation of materials and personnel for building of a new nuclear power plant at 

11 the Red 2 site would be similar to those evaluated in Section 4.8.3 for the STP site and would 

12 represent a small fraction (less than 5 percent) of the total traffic fatalities in Fannin County. 

13 Past actions in the geographic area of interest that have similarly affected the public and 

14 workers from nonradiological resources include the construction of the Valley Power Plant and a 

15 wastewater treatment facility for the City of Bells. There are no major current construction 

16 projects in the geographic area of interest that would cumulatively impact nonradiological health. 

17 Proposed future actions that would impact nonradiological health in a similar way to 

18 development at the Red 2 site would include the proposed Pattillo Branch Power Plant, 

19 transmission line development and/or upgrading throughout the designated geographic area of 

20 interest, and future urbanization. 

21 Operational Impacts 

22 Nonradiological health impacts from operation of two new nuclear units on occupational health 

23 and members of the public at the Red 2 site would be similar to those evaluated in Section 5.8 

24 for the STP site. Occupational health impacts to workers (e.g., falls, electric shock or exposure 

25 to other hazards) at the Red 2 site would likely be the same as those evaluated for workers at 

26 two new units at the STP site. Exposure to the public from water-borne etiological agents at the 

27 Red 2 site would be similar to the types of exposures evaluated in Section 5.8.1, and the 

28 operation of the new units at the alternative sites would not likely lead to an increase in water29 borne diseases in the vicinity. Noise and EMF exposure would be monitored and controlled in 

30 accordance with applicable Occupational Safety and Health Administration (OSHA) regulations. 

31 Effects of EMF on human health would be controlled and minimized by conformance with 

32 National Electrical Safety Code (NESC) criteria and adherence to the standards for transmission 

33 systems regulated by the Public Utility Commission of Texas (PUCT). Nonradiological impacts 

34 of traffic associated with the operations workforce would be less than the impacts during 

35 building. Mitigation measures taken during building to improve traffic flow would also minimize 

36 impacts during operation of a new unit. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-90 March 2010

1 The past and present activities in the geographic areas of interest that would have 

2 nonradiological impacts to the public or workers similar to those discussed for the Red 2 site 

3 include the Valley Power Plant and the wastewater treatment facility for the City of Bells. In the 

4 future, these facilities, the proposed Pattillo Branch Power Plant, transmission line systems, and 

5 future urbanization would have nonradiological impacts to the public and workers, and these 

6 impacts would be similar to those described for the proposed two new units at the Red 2 site. 

7 The review team is also aware of the potential climate changes that could affect human health; 

8 a recent compilation of the state of the knowledge in this area (Karl et al. 2009) has been 

9 considered in the preparation of this EIS. Projected changes in the climate for the region 

10 include an increase in average temperature and a decrease in precipitation, which may alter the 

11 presence of microorganisms and parasites in any reservoir that would be used. The review 

12 team did not identify anything that would alter its conclusion regarding the presence of 

13 etiological agents or change in the incidence of water-borne diseases. 

14 Summary 

15 Based on the information provided by STPNOC and the review team’s independent evaluation, 

16 the review team expects that nonradiological health impacts from building and operation of two 

17 new units at the Red 2 alternative site would be similar to the impacts evaluated for the STP 

18 site. While there are other past, present and future activities in the geographic area of interest 

19 that could affect nonradiological health in ways similar to the building and operation of two units 

20 at the Red 2 site, the impacts would be localized and managed through adherence to existing 

21 regulatory requirements. The review team concludes, therefore, that cumulative impacts would 

22 be SMALL. 

23 9.3.2.10 Radiological Impacts of Normal Operations 

24 The following impact analysis includes impacts from building activities and operations for two 

25 nuclear units at the Red 2 alternative site. The analysis also considers other past, present, and 

26 reasonably foreseeable future actions that impact radiological health, including other Federal 

27 and non-Federal projects listed in Table 9-8. As described in Section 9.3.2, Red 2 is a 

28 greenfield site; there are currently no nuclear facilities on the site. The geographic area of 

29 interest is the area within a 50-mi radius of the Red 2 site. There are no major facilities that 

30 result in regulated exposures to the public or biota within the 50-mi radius of the Red 2 site. 

31 However, there are likely to be hospitals and industrial facilities within 50 mi of the Red 2 site 

32 that use radioactive materials. 

33 The radiological impacts of building and operating the proposed two advanced boiling water 

34 reactor (ABWR) units at the Red 2 site include doses from direct radiation and liquid and 

35 gaseous radioactive effluents. These pathways would result in low doses to people and biota 

36 offsite that would be well below regulatory limits. These impacts are expected to be similar to 
Environmental Impacts of Alternatives 

March 2010 9-91 Draft NUREG-1937 

1 those estimated for the STP site. The NRC staff concludes that the dose from direct radiation 

2 and effluents from hospitals and industrial facilities that use radioactive material would be an 

3 insignificant contribution to the cumulative impact around the Red 2 site. This conclusion is 

4 based on data from the radiological environmental monitoring programs conducted around 

5 currently operating nuclear power plants. 

6 Based on the information provided by STPNOC and the NRC staff's independent analysis, the 

7 NRC staff concludes that the cumulative radiological impacts from building and operating the 

8 two proposed ABWRs and other existing and planned projects and actions in the geographic 

9 area of interest around the Red 2 site would be SMALL. 

10 9.3.2.11 Postulated Accidents 

11 The following impact analysis includes radiological impacts from postulated accidents from 

12 operations for two nuclear units at the Red 2 alternative site. The analysis also considers other 

13 past, present, and reasonably foreseeable future actions that impact radiological health from 

14 postulated accidents, including other Federal and non-Federal projects and those projects listed 

15 in Table 9-8. As described in Section 9.3.2, the Red 2 site is a greenfield site; there are 

16 currently no nuclear facilities on the site. The geographic area of interest considers all existing 

17 and proposed nuclear power plants that have the potential to increase the probability-weighted 

18 consequences (i.e., risks) from a severe accident at any location within 50 mi of the Red 2 site. 

19 There are no existing or proposed reactors that have the potential to increase the probability20 weighted consequences (i.e., risks) from a severe accident at any location within 50 mi of the 

21 Red 2 Site. 

22 As described in Section 5.11.1, the NRC staff concludes that the environmental consequences 

23 of DBAs at the STP site would be minimal for ABWRs. DBAs are addressed specifically to 

24 demonstrate that a reactor design is robust enough to meet NRC safety criteria. The ABWR 

25 design is independent of site conditions, and the meteorology of the Red 2 and STP sites are 

26 similar; therefore, the NRC staff concludes that the environmental consequences of DBAs at the 

27 Red 2 site would be minimal. 

28 Because the meteorology, population distribution, and land use for the Red 2 alternative site are 

29 expected to be similar to the proposed STP site, risks from a severe accident for an ABWR 

30 reactor located at the Red 2 alternative site are expected to be similar to those analyzed for the 

31 proposed STP site. These risks for the proposed STP site are presented in Tables 5-18 and 

32 5-19 and are well below the median value for current-generation reactors. In addition, estimates 

33 of average individual early fatality and latent cancer fatality risks are well below the 

34 Commission’s safety goals (51 FR 30028). On this basis, the NRC staff concludes that the 

35 cumulative risks of severe accidents at any location within 50 mi of the Red 2 alternative site 

36 would be SMALL. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-92 March 2010

1 9.3.3 Allens Creek 

2 This section covers the review team’s evaluation of the potential environmental impacts of siting 

3 a new two-unit nuclear power plant at the Allens Creek site in southeastern Texas. The site is 

4 located within a rural area of Austin County approximately 4 mi north of Wallis and 7 mi 

5 southeast of Sealy. Allens Creek is a greenfield site that was set aside for a nuclear power 

6 plant and cooling reservoir in the early 1970s in a proposal by the Houston Power and Lighting 

7 Company. Although the project was subsequently cancelled, a Final Environmental Statement 

8 for the proposed nuclear power plant was issued by the United States Atomic Energy 

9 Commission (AEC 1974). When appropriate, this report is used as a resource in the evaluation 

10 of Allens Creek as an alternative site. The majority of the site is currently owned by the City of 

11 Houston and the Brazos River Authority (BRA). NRG Energy Inc. still owns 1722 ac of the site 

12 which would encompass the location of the power block, related facilities, and switchyard for 

13 siting new nuclear units (STPNOC 2009a). 

14 The following sections include a cumulative impact assessment conducted for each major 

15 resource area. The specific resources and components that could be affected by the 

16 incremental effects of the proposed action if implemented at the Allens Creek site and other 

17 actions in the same geographic area were considered. This assessment includes the impacts of 

18 NRC-authorized construction and operations and impacts of preconstruction activities. Also 

19 included in the assessment are other past, present, and reasonably foreseeable future Federal, 

20 non-Federal, and private actions that could have meaningful cumulative impacts when 

21 considered together with the proposed action if implemented at the Allens Creek site. Other 

22 actions and projects considered in this cumulative impact analysis are described in Table 9-12. 

23 Water for cooling and other plant uses would be from the Allens Creek Reservoir as currently 

24 proposed by the BRA. If the BRA reservoir is not constructed, a smaller reservoir at the same 

25 location would be constructed as part of the nuclear power plant project. The analysis of 

26 cumulative impacts for the Allens Creek site discussed below assumes the Allens Creek 

27 Reservoir is constructed by the BRA. Impacts associated with a smaller reservoir would be less 

28 than those anticipated for the proposed reservoir and are therefore not considered separately. 

29 Because the STP site is approximately 60 mi from Allens Creek, it is beyond the geographic 

30 area of interest for all resource areas with the exception of accidents. The only other nuclear 

31 power plant currently operating in Texas is Comanche Peak. The Comanche Peak plant is 

32 more than 200 mi from Allens Creek and therefore is also not included in the cumulative impact 

33 analysis. The proposed nuclear power plant in Victoria County is approximately 95 mi from 

34 Allens Creek and therefore was only considered in the accident analysis. 
 Environmental Impacts of Alternatives 

March 2010 9-93 Draft NUREG-1937 

1 Table 9-12. Past, Present, and Reasonably Foreseeable Projects and Other Actions 

2 Considered in the Allens Creek Alternative Site Cumulative Analysis 

Project Name Summary of Project Location Status 

Energy Projects 

WA Parish Electric 

Generating Station 

Nine-unit, 3653-MW coal- and 

gas-fired plant 

About 30 mi 

southeast of 

Allens Creek 

site 

Operational(a)

South Texas Project Two 1265 MW(e) Westinghouse 

pressurized water reactors 

About 60 mi 

south of Allens 

Creek site 

Operational(b) STP plans 

to submit an application 

for renewal of the 

operating licenses for 

Units 1 and 2 in late 

2010. If granted, the 

operating licenses would 

be extended for 20 

years, or until 2047 for 

Unit 1 and 2048 for Unit 

2.(c)

Victoria County 

Nuclear Station 

One or more large-scale power 

reactors 

About 95 mi 

southwest of 

Allens Creek 

site 

Proposed. Exelon 

Generation intends to 

submit an application to 

NRC for an Early Site 

Permit in March 2010.(d)

Transportation Projects 

Highway construction Construction of a 11.9-mi new 

location, four-lane, controlled 

access toll road from United 

States Highway (US) 290 to State 

Highway (SH) 249 in 

Harris County, Texas 

Approx 40 mi 

from Allens 

Creek site 

Proposed. Final EIS 

issued June 2009.(e)

Parks and Nature Preserve Facilities 

Texas Independence 

Trail 

Driving route within the Texas 

Independence Trail region 

Throughout the 

region near site 

Development likely 

limited at specific points 

along the trail(f)

Stephen F. Austin 

State Historical Park 

Activities include picnicking, 

camping, fishing, hiking, and 

nature and historical tours 

About 10 mi 

north of Allens 

Creek site 

Development likely 

limited within this park(g)

Attwater Prairie 

Chicken National 

Wildlife Refuge 

Home to one of the last 

populations of the critically 

endangered Attwater's prairiechicken 

Closest parcel 

of land is 5 mi 

west of Allens 

Creek site 

Development likely 

limited within this 

refuge(h)

3 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-94 March 2010

Table 9-12. (contd)

Project Name Summary of Project Location Status 

Brazos Bend State 

Park 

Activities include camping, 

picnicking, hiking, biking, 

equestrian, and fishing at six lakes 

About 20 mi 

southeast of 

Allens Creek 

site 

Development likely 

limited within this park(i)

Other Actions/Projects 

Allens Creek 

Reservoir 

9500-ac municipal water supply 

reservoir on Allens Creek 

proposed by Brazos River 

Authority 

At the Allens 

Creek site 

Proposed. Construction 

is expected to begin by 

2018.(j)

US Steel Tubular 

Products Inc. – 

Bellville Operations 

Division 

Line pipe and tubular goods 

manufacture 

About 20 mi 

northwest of 

Allens Creek 

site 

Operational(k)

Hudson Products 

Corporation 

Design and manufacture aircooled heat exchanger equipment 

to serve the oil, gas and 

petrochemical processing 

industries 

About 10 mi 

southeast of 

Allens Creek 

site 

Operational(l)

Frito Lay – Rosenberg 

Facility 

Food manufacturer About 20 mi 

southeast of 

Allens Creek 

site 

Operational(m)

Acme Brick, San 

Felipe Plant, Sealy 

Brick and structural clay tile 

manufacture 

About 10 mi 

north-northwest 

of Allens Creek 

site 

Operational(n)

Waste Water 

Treatment Plants 

Numerous plants Within 30 mi 

radius of site 

Operational 

Future Urbanization Construction of housing units and 

associated commercial buildings; 

roads (such as the I-69 TransTexas Corridor project), bridges, 

and rail; construction of waterand/or wastewater- treatment and 

distribution facilities and 

associated pipelines, as described 

in local land-use planning 

documents. 

Throughout 

region 

Construction would 

occur in the future, as 

described in state and 

local land-use planning 

documents(o)
 Environmental Impacts of Alternatives 

March 2010 9-95 Draft NUREG-1937 

1 Table 9-12. (contd) 

Project Name Summary of Project Location Status 

Various hospitals and 

industrial facilities that 

use radioactive 

materials 

Medical and other isotopes Within 50 mi Operational in nearby 

cities and towns 

(a) Source: EPA 2009l 

(b) Source: NRC 2009a 

(c) Source: NRC 2009a 

(d) Source: Exelon 2009 

(e) Source: USDOT 2009 

(f) Source: STPNOC 2009b 

(g) Source: TPWD 2009n 

(h) Source: STPNOC 2009b 

(i) Source: TPWD 2009o 

(j) Source: Brazos River Authority 2010 

(k) Source: USS 2009 

(l) Source: Hudson 2009 

(m) Source: EPA 2009m 

(n) Source: EPA 2009n 

(o) Source: TxDOT 2009b 

2 9.3.3.1 Land Use 

3 The following impact analysis includes impacts from building activities and operations. The 

4 analysis also considers other past, present, and reasonably foreseeable future actions that 

5 impact land use, including other Federal and non-Federal projects and those projects listed in 

6 Table 9-12. For this analysis, the geographic area of interest for considering cumulative 

7 impacts is the 10-mi region surrounding the Allens Creek site. This area of interest was 

8 selected to include the primary communities (e.g., Sealy) that would be affected by the 

9 proposed project if it were located at the Allens Creek site. Figure 9-9 shows the location of the 

10 Allens Creek site and surrounding communities. 

11 The Allens Creek site is a greenfield site located in an unincorporated area of Austin County, 

12 Texas, 4.4 mi north of Wallis and 7.3 mi southeast of Sealy (STPNOC 2009a). There is no 

13 current zoning applicable to the site. 

14 In 1973, Houston Lighting and Power applied to the NRC for construction permits for a new, 

15 two-unit nuclear power plant at the site. The application was ultimately withdrawn in 1982 

16 (HMRC 2009). The City of Houston and the Brazos River Authority later acquired the land for a 

17 water storage reservoir to be built on Allens Creek, a tributary of the Brazos River. Currently, 

18 the Brazos River Authority plans to construct a 9500-ac reservoir at the site to serve the future 

19 water needs of the City of Houston and surrounding communities. Construction is expected to 

20 begin in 2018 (Brazos 2009). This analysis assumes the reservoir would be a source of cooling 

21 water for new nuclear units sited at Allens Creek. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-96 March 2010

1 

2 Figure 9-9. Allens Creek Alternative Site and 10-mi Radius
 Environmental Impacts of Alternatives 

March 2010 9-97 Draft NUREG-1937 

1 If the Brazos River Authority does not construct the planned reservoir, an alternative reservoir 

2 would be needed for plant cooling. Alternatively, water could potentially be withdrawn directly 

3 from the Brazos River. 

4 The land area affected by building two nuclear generating units at the Allens Creek site would 

5 be approximately 800 ac for the main power plant site and up to 9500 ac for the new, multi-use 

6 reservoir (STPNOC 2009a). Land-use impacts would also occur to divert water to the plant and 

7 return discharge water to Allens Creek and for road and rail access. 

8 In 1973, the majority of the Allens Creek site was cleared of the native hardwood vegetation, 

9 and an extensive system of drainage ditches was constructed which allowed much of the area 

10 to be used to farm row crops. Much of the Allens Creek site is open cropland and pasture, but 

11 hardwood riparian areas and bluff forests exist along the Brazos River and Allens Creek. Major 

12 crops grown in the area include corn, cotton, sorghum, and hay. Uncleared and partially 

13 cleared land is used to graze cattle (STPNOC 2009a). 

14 The Allens Creek site is not in the geographic area covered by the TCMP (TCMP 2009); 

15 therefore, the CZMA does not apply to this site. 

16 Three new transmission line corridors would likely be needed to connect the Allens Creek site to 

17 the three closest 345-kV lines in the area. The Allens Creek site is approximately 20 mi west of 

18 the 345-kV connection at the O’Brien Substation, 30 mi northwest of the 345kV line between 

19 W.A. Parish power plant and the Hill Substation, and 35 mi northeast of the 345kV line between 

20 Holman and Hill substations. The total combined distance for new corridors would be 

21 approximately 85 mi. Farmlands that would become part of a corridor could generally continue 

22 to be farmed. Based on 85 mi of corridor and a 200-ft corridor width, installation of new 

23 transmission corridors would impact approximately 2000 ac (STPNOC 2009a). 

24 Future urbanization in the geographic area of interest and GCC could contribute to decreases in 

25 open lands, wetlands, and forested areas. . Urbanization in the vicinity of the Allens Creek site 

26 would alter important attributes of land use. Urbanization would reduce natural vegetation and 

27 open space, resulting in an overall decline in the extent and connectivity of wetlands, forests, 

28 and wildlife habitat. GCC could decrease precipitation, causing more frequent droughts when 

29 combined with increased evaporation in the geographic area of interest for the Allens Creek site 

30 (Karl et al. 2009). Reduced water supply and increased temperatures could reduce crop yields 

31 and livestock productivity (Karl et al. 2009), which might change portions of agricultural and 

32 ranching land uses in the area of interest. However, existing parks, reserves, and managed 

33 areas would help preserve open lands, wetlands, and forested areas to the extent that they are 

34 not adversely affected by droughts. Future urbanization trends and direct changes resulting 

35 from GCC could noticeably alter land uses in the geographic area of interest. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-98 March 2010

1 Based on the information provided by STPNOC and the review team’s independent review, the 

2 review team concludes that the cumulative land-use impacts of constructing and operating two 

3 new nuclear generating units at the Allens Creek site would be MODERATE. This conclusion 

4 reflects the substantial amount of land (800 ac for the main power plant site; up to 9500 ac for 

5 the new, multi-use reservoir; and approximately 2000 ac for transmission corridors) that would 

6 be needed if the proposed reservoir is built and two new nuclear units were sited at the Allens 

7 Creek site, and land use changes from increased urbanization and potential effects of GCC. 

8 Building and operating two new nuclear units at the Allens Creek site would be a significant 

9 contributor to the MODERATE impact. 

10 9.3.3.2 Water Use and Quality 

11 The following impact analysis includes impacts from building activities and operations. 

12 The analysis also considers other past, present, and reasonably foreseeable future actions 

13 that impact water use and quality including other Federal and non-Federal projects listed in 

14 Table 9-12. The Allens Creek site is located in rural Austin County in southeastern Texas. 

15 Development of this site for two nuclear units would require the building of a water reservoir on 

16 the Allens Creek site supplied with water from the Brazos River. 

17 Geographic areas of interest are the surface water in the drainage basin of the Brazos River 

18 upstream and downstream of the proposed intake and outfall structures and the Allens Creek 

19 drainage, and for groundwater the aquifers upgradient and downgradient of the site. These 

20 regions are of interest because they represent the water resource potentially affected by the 

21 proposed project if it were located at the Allens Creek site. 

22 As stated in Section 2.3.2, water use in Texas is regulated by the Texas Water Code. As 

23 established by Texas Water Code, surface water belongs to the State of Texas (Texas Water 

24 Code, Chapter 11, Section 11.021). The right to use surface waters of the State of Texas can 

25 be acquired in accordance with the provisions of the Texas Water Code, Chapter 11. In Texas, 

26 surface water is a commodity. Since the Brazos River Basin is currently heavily appropriated, 

27 future water users in this basin would likely only obtain surface water by purchasing or leasing 

28 existing appropriations. Regarding groundwater, Texas law has allowed landowners to pump 

29 the water beneath their property without consideration of impacts to adjacent property owners 

30 (NRC 2009b). However, Chapter 36 of Texas Water Code authorized groundwater 

31 conservation districts to help conserve groundwater supplies. Chapter 36, Section 36.002, 

32 Ownership of Groundwater, states that ownership rights are recognized and that nothing in the 

33 code shall deprive or divest the landowners of their groundwater ownership rights, except as 

34 those rights may be limited or altered by rules promulgated by a district. Thus, groundwater 

35 conservation districts with their local constituency offer groundwater management options (NRC 

36 2009b). Existing projects in the State have appropriations to use water for their requirements. 

37 The review team expects that future projects, including the proposed units, if they were to be 
 Environmental Impacts of Alternatives 

March 2010 9-99 Draft NUREG-1937 

1 built and operated at the Allens Creek site, would operate within the limits of these existing 

2 surface water and groundwater appropriations. 

3 As stated in Section 7.2.1, the GCRP has compiled the state of knowledge in climate change. 

4 This compilation has been considered in the preparation of this EIS. The projections for 

5 changes in temperature, precipitation, droughts, and increasing reliance on aquifers within the 

6 Brazos River Basin are similar to those in the Colorado River Basin (Karl et al. 2009). Such 

7 changes in climate would result in adaptations to both surface water and groundwater 

8 management practices and policies that are unknown at this time. 

9 There are currently 1368 water rights owners in the Brazos River Basin, with total water rights of 

10 4,350,000 ac-ft/yr that are categorized as industrial, irrigation, or mining users (TCEQ 2009a). 

11 According to TCEQ’s water availability maps, unappropriated flows in the Lower Brazos River 

12 Basin for a perpetual water rights permit are available 0 to 50 percent of the time in Austin 

13 County (TCEQ 2009b). The water availability maps do not show the quantity of available water 

14 for a new appropriation (TCEQ 2009b). 

15 The Texas Water Development Board, in the 2007 State Water Plan, has estimated that 

16 groundwater supplies of more than 1.6 million ac-ft per year would be available from 2010-2060 

17 in the Gulf Coast Aquifer that is shared by 54 counties and approximately 100,000 ac-ft per year 

18 in the Brazos River Alluvium Aquifer that is shared by 13 counties (TWDB 2006a). The 

19 Bluebonnet Groundwater Conservation District (BGCD) has estimated the amount of usable 

20 groundwater in the district as approximately 107,289 ac-ft per year based on 2001 Region H 

21 and Region G Water Plans (BGCD 2004). The estimated groundwater availability of the Gulf 

22 Coast and Brazos River Alluvium aquifers within the district are approximately 53,259 and 

23 10,307 ac-ft per year (BGCD 2004). The TWDB reported that wells in the Gulf Coast Aquifer 

24 support pumping rates from less than 100 to more than 3000 gpm and those in the Brazos River 

25 Alluvium Aquifer support pumping rates of 250 to 500 gpm. The estimated groundwater use 

26 within the district is approximately 23,214 ac-ft per year (BGCD 2004). 

27 Building Impacts

28 The review team assumed that no surface water would be used to build the proposed units at 

29 the Allens Creek site so there would be no impact on surface water use. This assumption is 

30 consistent with the analysis done for the STP site and the other alternative sites. 

31 The impacts on surface water quality from building potential units at the Allens Creek alternative 

32 site would be limited to stormwater runoff that may enter nearby streams and rivers. 

33 Additionally, treated sanitary wastewater may be discharged to these streams and rivers. 

34 Building impacts would be limited by the duration of these activities, and therefore, would be 

35 temporary. The State of Texas prohibits the unauthorized discharge of waste into or adjacent to 

36 water in the state (Texas Water Code, Chapter 26, Section 26.121). The discharge of waste 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-100 March 2010

1 may be authorized under a general or individual permit (Texas Water Code, Chapter 26). 

2 These permits may require an SWPPP that includes BMPs appropriate for the site (TCEQ 2003; 

3 STPNOC 2009a). Implementation of BMPs should minimize impacts to wetlands and surface4 water bodies near the Allens Creek alternative site. Therefore, the water quality impacts on 

5 wetlands and water bodies near the Allens Creek alternative site related to building the 

6 proposed new units would be temporary and minimal. 

7 The review team assumes that the groundwater use for building activities at the Allens Creek 

8 site would be identical to the proposed groundwater use for the STP site (STPNOC 2009b) 

9 because the site would utilize units similar to those proposed for the STP site and the building 

10 activities would also be similar. Monthly normalized groundwater use for the STP site ranges up 

11 to 491 gpm (792 ac-ft/yr) (see Table 3-4). STPNOC stated that groundwater would be used for 

12 potable and sanitary use, concrete batch plant operation, concrete curing, dust suppression and 

13 cleaning, placement of engineered backfill, and piping hydrotests and flushing (STPNOC 

14 2009a). 

15 The Allens Creek alternative site is located in Texas GMA 14 and the BGCD. As of January 

16 2010 GMA 14 has not adopted desired future conditions for the Carrizo-Wilcox, Gulf Coast, 

17 Brazos River Alluvium, Queen City, Sparta, and Yegua-Jackson aquifers (TWDB 2010c) located 

18 within its area. STPNOC has suggested the Gulf Coast and the Brazos River Alluvium aquifers 

19 as the potential sources of groundwater. Based on the available information, the review team 

20 determined that the groundwater that would be used to build proposed units at the Allens Creek 

21 alternative site would be less than 2 percent of the available groundwater from the Gulf Coast 

22 and the Brazos River Alluvium aquifers within the BGCD. Based on standard practice, the 

23 review team concluded that the drawdown from pumping the aquifers could be minimized during 

24 building-related groundwater pumping using an appropriately designed well system. The review 

25 team concluded, based on available information, that the impact of groundwater use for building 

26 related activities at the Allens Creek site would be minimal. 

27 The review team found that groundwater in the Gulf Coast Aquifer system is reported to be of 

28 good quality underlying Austin County (TWDB 2006a). Levels of total dissolved solids (TDS) in 

29 the Chicot, Evangeline, and Jasper Aquifers of the Gulf Coast Aquifer system are all shown as 

30 less than 1000 mg/L. The review team concludes that wells completed in the Gulf Coast Aquifer 

31 system should produce good quality groundwater. During building of any potential units at the 

32 Allens Creek alternative site, impacts to groundwater quality may occur from leaching of spilled 

33 effluents into the subsurface. BMPs would be in place during building activities and therefore 

34 the review team concluded that any spills would be quickly detected and remediated. In 

35 addition, impacts would be limited by the duration of these activities, and therefore, would be 

36 temporary. Because any spills would be quickly detected and remediated and the activities 

37 causing the spill would be temporary, the review team concluded that the groundwater-quality 

38 impacts from building at the Allens Creek site would be minimal. 
 Environmental Impacts of Alternatives 

March 2010 9-101 Draft NUREG-1937 

1 Operational Impacts

2 STPNOC estimated that a two-unit plant, operated at the Allens Creek alternative site using a 

3 closed-cycle cooling system that would employ a cooling water reservoir would consume a 

4 maximum of 50,000 ac-ft of water per year. STPNOC identified the Brazos River as the likely 

5 source of cooling water at the Allens Creek alternative site. STPNOC currently does not own 

6 the necessary water rights. STPNOC would acquire existing Brazos River water rights that are 

7 currently being used for industrial, irrigation, and mining use. Based on the total water rights 

8 currently issued for the Brazos River Basin, STPNOC would need to acquire a minimum of 

9 1.1 percent of these water rights (STPNOC 2009a). 

10 At the Allens Creek site, the Brazos River Authority (BRA) has plans to create a 9500-ac water 

11 supply reservoir. The proposed reservoir would supply water to the City of Houston and a 

12 portion of the water would be owned by the BRA. Currently, the building of the reservoir is 

13 scheduled to begin in 2018 and to be completed by 2030. STPNOC would need to acquire 

14 sufficient water rights in the proposed reservoir and would need the building of the reservoir to 

15 begin earlier to support operation of potential units at the Allens Creek alternative site 

16 (STPNOC 2009a). 

17 According to TCEQ staff, the water rights for the proposed reservoir at Allens Creek have 

18 already been permitted (NRC 2009b). Therefore, the aggregation of these water rights that 

19 STPNOC would need to acquire at the potential plant site would not be of concern. However, 

20 the review team determined that the reservoir’s water rights are currently allocated for municipal 

21 use. The acquisition of these water rights for potential plants at the Allens Creek alternative site 

22 could displace municipal users. The Allens Creek site is located in Austin County, which is part 

23 of Region H. The projected water demand for municipal users in Region H for 2010 is 

24 897,600 ac-ft and is estimated to grow to 1,480,300 ac-ft in 2060 (TWDB 2006a). The needed 

25 water supply for municipal users in Region H for 2010 is 69,700 ac-ft and projected to grow to 

26 518,600 ac-ft in 2060. The proposed reservoir at Allens Creek is estimated to supply 

27 97,400 ac-ft. The cooling water demand of approximately 50,000 ac-ft per year for potential 

28 units at the Allens Creek alternate site would result in an increased need for municipal uses in 

29 Region H. The review team determined, therefore, that the surface water use impacts of 

30 operations at the Allens Creek site would be noticeable but not destabilizing. 

31 During the operation of a potential plant at the Allens Creek alternative site, impacts to surface 

32 water quality could result from stormwater runoff, discharges of treated sanitary and other 

33 wastewater, blowdown from service water cooling towers, and periodic discharges from the 

34 cooling water reservoir into the Brazos River. As mentioned above, the State of Texas may 

35 require STPNOC to obtain a general or individual permit for the discharge of stormwater (Texas 

36 Water Code, Chapter 26). These permits may require an SWPPP that includes BMPs 

37 appropriate for the site (TCEQ 2001; STPNOC 2009a). Any discharges of sanitary and other 

38 wastewaters and cooling water reservoir discharges would be controlled by the State of Texas 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-102 March 2010

1 under a TPDES permit. The State of Texas limits the quantity and quality of discharges to 

2 surface water bodies while accounting for concurrent discharge and quality conditions within the 

3 surface water body. These permit conditions would also account for designated uses of the 

4 receiving surface water body. The review team expects that the conditions placed on 

5 operations of any potential plants at the Allens Creek site would be similar to those currently 

6 placed on the existing facilities at the STP site (see Section 5.2.3.1). Therefore, the review 

7 team concluded that the operational impact on surface water quality of the Brazos River would 

8 be minimal because the discharge quantity and quality would be controlled. 

9 The proposed Units 3 and 4 would use approximately 975 gpm (1572 ac-ft/yr) of groundwater 

10 during normal operations and approximately 3434 gpm (5538 ac-ft/yr) during maximum demand 

11 conditions (STPNOC 2009c). STPNOC stated that the expected groundwater use for Units 3 

12 and 4 are assumed to also apply to alternative sites (STPNOC 2009b). However, for maximum 

13 operation demand periods, STPNOC assumes that a temporary increase in the rate of surface 

14 water use would be available. 

15 The review team determined that the proposed groundwater use at the Allens Creek alternative 

16 site during operations would not be unreasonable because the alternative site would utilize units 

17 similar to those proposed for the STP site. 

18 As stated above, GMA 14 has not yet adopted desired future conditions for the Carrizo-Wilcox, 

19 Gulf Coast, Brazos River Alluvium, Queen City, Sparta, and Yegua-Jackson aquifers (TWDB 

20 2010c). The BGCD has estimated the amount of usable groundwater in the district as 

21 approximately 107,289 ac-ft per year based on 2001 Region H and Region G Water Plans 

22 (BGCD, 2004). The estimated groundwater availability of the Gulf Coast and Brazos River 

23 Alluvium aquifers within the district are approximately 53,259 and 10,307 ac-ft per year (BGCD, 

24 2004). Based on the available information, the review team determined that the groundwater 

25 use for the operation of proposed units at the Allens Creek alternative site would be 2.5 percent 

26 of the available groundwater from the Gulf Coast and the Brazos River Alluvium aquifers within 

27 the BGCD. During operation of any potential plant at the Allens Creek alternative site, some 

28 drawdown of the Brazos River Alluvium and the Gulf Coast Aquifers could be expected. Based 

29 on standard hydrogeologic practice, the amount of drawdown in the aquifers from groundwater 

30 pumping during operation could be limited by installing multiple, appropriately-spaced wells 

31 because groundwater would be withdrawn from a large area resulting in smaller drawdown. 

32 Therefore, because groundwater use would be a relatively small fraction of the available 

33 groundwater, there is available capacity (BGCD 2004), and drawdown could be controlled, the 

34 review team concluded that the impact of operational groundwater use at the Allens Creek site 

35 would be minimal. 

36 During the operation of a potential plant at the Allens Creek alternative site, impacts to 

37 groundwater quality could result from potential spills. Spills that might affect the quality of 

38 groundwater would be prevented and mitigated by BMPs. As noted above, groundwater in the 
 Environmental Impacts of Alternatives 

March 2010 9-103 Draft NUREG-1937 

1 Gulf Coast Aquifer system underlying Austin County is of good quality (TWDB 2006a). Because 

2 spills would be mitigated through BMPs and no intentional discharge to groundwater should 

3 occur, the review team concludes that the groundwater-quality impacts from operations at the 

4 Allens Creek site would be minimal. 

5 Cumulative Impacts

6 In addition to water use and water quality impacts from building and operations activities, 

7 cumulative analysis considers past, present, and reasonably foreseeable future actions that 

8 impact the same environmental resources. For the cumulative analysis of impacts on surface 

9 water, the geographic area of interest for the Allens Creek site is considered to be the drainage 

10 basin of the Brazos River upstream and downstream of the intake and outfall structures 

11 including the Allens Creek drainage because this is the surface water resource that would be 

12 affected by the proposed project if it were located at the Allens Creek site. Key actions that 

13 have past, present and future potential impacts to water supply and water quality in the Brazos 

14 River Basin include the existing WA Parish Electric Generating Station and numerous sewage 

15 treatment facilities. 

16 Cumulative Water Use

17 The only surface-water-use impacts of building and operating a nuclear power plant at this site 

18 are the demands occurring during operation. The projected consumptive surface water use of 

19 the two units is expected to be about 50,000 ac-ft/yr or less than 1.1 percent of the total water 

20 rights of 4,350,000 ac-ft/yr currently held by 1368 water rights owners in the Brazos River Basin. 

21 Past and present water withdrawals, reflected by the water rights held in the Brazos River 

22 Basin, have used the waters of the river. Currently, unappropriated flows in the Lower Brazos 

23 River Basin are available for a perpetual water rights permit less than half of the time during a 

24 typical year. The surface water use for the proposed units, if they were to be built at the Allens 

25 Creek site, is already granted by TCEQ and held by the City of Houston and the Brazos River 

26 Authority. Reasonably foreseeable future actions in the Brazos River Basin, primarily the 

27 predicted estimated population growth of 77 percent between 2010 and 2060 (TWDB 2006a), 

28 could noticeably alter, but due to water management strategies, not destabilize, the surface 

29 water resource. Water management strategies could include conservation, wastewater reuse, 

30 system operation of the Brazos River Authority reservoirs, desalination, reservoir augmentation, 

31 and new reservoirs, among other strategies (TWDB 2006c). The impacts of other projects listed 

32 in Table 9-2 would have little or no impact on surface water use. 

33 Groundwater-use impacts of building and operating a nuclear power plant at this site are 

34 characterized by the groundwater demand at the STP site, and those use levels are 491 gpm 

35 (792 ac-ft/yr) during building activities, a normal operation demand of 975 gpm (1572 ac-ft/yr), 

36 and a maximum operation demand of 3434 gpm (5538 ac-ft/yr) (STPNOC 2009c). However, for 

37 maximum operation demand periods, STPNOC assumes that a temporary increase in the rate 

38 of surface water use would be available. During building and normal operation of two nuclear 
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Draft NUREG-1937 9-104 March 2010

1 units at the Allens Creek site, the possibilities exist that STPNOC could (1) a new groundwater 

2 permit and associated wells, (2) access to existing groundwater production from wells in the 

3 vicinity of the plant, and (3) use of imported water primarily for potable use onsite (STPNOC 

4 2009b). With regard to the groundwater resource available to all past, present, and future 

5 projects, the BGCD (2004) estimates groundwater availability of 63,566 ac-ft/yr and 

6 groundwater use of 23,214 ac-ft/yr within the BGCD for the Gulf Coast and Brazos River 

7 Alluvium aquifers. The review team concludes there is a net surplus of groundwater available 

8 within the BGCD. 

9 The review team is also aware of the potential for GCC affecting the water resources available 

10 for closed-cycle cooling and the impact of reactor operations on water resources for other users. 

11 The impact of GCC on regional water resources is not precisely known, however it may result in 

12 decreases in precipitation and increases in average temperature (Karl et al. 2009). Such 

13 changes could further stress regional water resources. However, the impacts related to GCC 

14 would be similar for all the alternative sites. 

15 Historically, the waters of the Brazos River Basin have been used extensively. The region has a 

16 planning, allocation, and development system in place to manage the use its limited surface 

17 water supplies. These efforts are described in the Regional and State Water Plans (TWDB 

18 2006a, 2006b, 2006c). The operation of the proposed units at the Allens Creek site would result 

19 in noticeable but not destabilizing impact on surface water use in the region. Future growth 

20 would also result in noticeable but not destabilizing impact on surface water use in the region. 

21 Therefore, the review team concludes that cumulative impacts to surface water use would be 

22 MODERATE. However, building and operating the proposed plant at the Allens Creek site 

23 would not be a significant contributor to these water-use impacts because the water rights are 

24 already held by the City of Houston and the Brazos River Authority. 

25 As indicated above, groundwater would be used during the building and operation of two 

26 nuclear units at the Allens Creek site. Because alternatives are available to supplying the 

27 needed groundwater (i.e., new groundwater wells, acquired groundwater permits, and import of 

28 potable water), a potential reduction in new groundwater demand, and the available 

29 groundwater resource, the review team concludes there would not be a substantial impact to 

30 other nearby users of groundwater. As such, the review team concludes that cumulative 

31 impacts to groundwater use would be SMALL. The impacts of other projects listed in Table 

32 9-12 would have little or no impact on surface water and groundwater use. 

33 Cumulative Water Quality

34 Point and nonpoint sources in the river basin have affected the water quality of the Brazos 

35 River. Water quality information presented above for the impacts of building and operating the 

36 new units at the Allens Creek site would also apply to evaluation of cumulative impacts. The 

37 State of Texas may require an applicant to obtain a general or individual permit for discharge of 

38 stormwater (Texas Water Code, Chapter 26). These permits may require an SWPPP that 
 Environmental Impacts of Alternatives 

March 2010 9-105 Draft NUREG-1937 

1 includes BMPs appropriate for the site (TCEQ 2001, 2003; STPNOC 2009a). The State of 

2 Texas would also issue TPDES permits for the discharge of sanitary and other wastewaters, 

3 including blowdown from service water cooling towers and cooling water reservoir discharges, 

4 before operation of the units at the Allens Creek site. Effluent discharges through TPDES5 permitted outfalls, such as those from the WA Parish Electric Generating Station and sewage 

6 treatment plants, are required to comply with the Clean Water Act. Such permits are designed 

7 to protect water quality. Therefore, the review team concluded that the cumulative impact on 

8 surface water quality of the receiving water body would be SMALL. The impacts of other 

9 projects listed in Table 9-12 would have little or no impact on surface water quality. 

10 The review team also concludes that with the implementation of BMPs, the impacts of 

11 groundwater quality from building and operating two new nuclear units at the Allens Creek site 

12 would likely be minimal. The individual impacts from other projects listed in Table 9-8 would 

13 have little or no impact on regional groundwater quality because of the local nature of 

14 groundwater withdrawals and their associated impacts. Therefore, the cumulative impact on 

15 groundwater quality would be SMALL. 

16 9.3.3.3 Terrestrial and Wetland Resources 

17 The following impact analysis includes impacts from building activities and operations. The 

18 analysis also considers other past, present, and reasonably foreseeable future actions that 

19 impact terrestrial and wetland resources, including other Federal and non-Federal projects listed 

20 in Table 9-12. For the analysis of terrestrial ecological impacts, the geographic area of interest 

21 is considered to be intersection of the Western Gulf Coastal Plains ecoregion with the Lower 

22 Brazos and San Bernard watersheds within Austin, Colorado, Wharton, Waller and Fort Bend 

23 Counties (Figure 9-10). This area is expected to encompass the ecologically relevant 

24 landscape features and species. 

25 Austin County is in the Coastal Prairie subprovince of the Gulf Coastal Plains ecoregion (UT 

26 1996). The Coastal Prairie of Texas is a tallgrass prairie similar to the tallgrass prairie of the 

27 Great Plains (TPWD 2009a). Trees are uncommon except along streams and in oak mottes 

28 (i.e., groves) (UT 1996). Nearly 1000 plant species have been identified in the Coastal Prairie 

29 and it provides habitat for wintering waterfowl and spring neotropical migratory birds (TPWD 

30 2009b). It is home to the Federally endangered Attwater’s prairie chicken (Tympanuchus 

31 cupido attwateri) and is the exclusive wintering ground of the whooping crane (Grus americana). 

32 Plants in this ecoregion include trees such as oak (Quercus spp.), elm (Ulmus spp.), mulberry 

33 (Morus sp.), cedar (Juniperus sp.) and pine (Pinus spp.); grasses such as bluestem 

34 (Andropogon sp.) and cordgrass (Spartina sp.). Almost all of the coastal prairies have been 

35 converted to cropland, rangeland, pasture, or urban uses. 
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Draft NUREG-1937 9-106 March 2010

1 

2 Figure 9-10. Geographic Area for the Analysis of Cumulative Impacts to Terrestrial Resources 

3 within the Western Gulf Coast Plains Ecoregion in the Lower Brazos and San 

4 Bernard watersheds within Austin, Colorado, Wharton, Waller, and Fort Bend 

5 Counties 
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March 2010 9-107 Draft NUREG-1937 

1 The terrain at the Allens Creek site varies from rolling hills in the northern, western, and central 

2 sections to a nearly level coastal prairie in the south where site is located (STPNOC 2009b). 

3 Currently, the site is mostly flat, agricultural land used to farm row crops (primarily cotton, 

4 sorghum, corn, and soybeans) and graze cattle. Although much of the site has been disturbed 

5 for agriculture, the coastal prairie around the site exhibits wide expanses of open grassland 

6 fringed by stands of oak and elm. In 1973, the majority of the site was cleared of native 

7 hardwood vegetation, and an extensive system of drainage ditches was constructed to allow the 

8 area to be used for farming row crops. Uncleared and partially cleared land was used to graze 

9 cattle. The area is prone to flooding and is not considered appropriate for urban development. 

10 The total acreage for all temporary and permanent impacts is 800 ac for the plant site, with 

11 300 ac permanently affected (STPNOC 2009a). The proposed Allens Creek reservoir would be 

12 used for cooling water. The City of Houston and the Brazos River Authority acquired part of this 

13 site for a proposed 9500-ac reservoir (STPNOC 2009a). For the purposes of this analysis, the 

14 review team assumes that the proposed reservoir would be built and functional before the two 

15 new nuclear power reactors would be built. General land uses and acreage estimates for areas 

16 permanently affected by building are presented in Table 9-13 (STPNOC 2009a). The plant site 

17 would be located on the bluff on the western side of the reservoir. No wetlands were identified 

18 within the footprint of the Allens Creek alternative site. 

19 Table 9-13. Estimated Acreages by Land Cover Classes for Approximately 300 ac of the 

20 800-ac Allens Creek Site. 

Land Cover Class Plant (ac)(a)

Bluff forest 75 

Grass 225 

Total 300 

Source: STPNOC 2009a. 

(a) Acreages are for areas permanently affected by 

building at the site. 

21 Ecologically important areas occurring near the Allens Creek site include the Attwater Prairie 

22 Chicken National Wildlife Refuge (NWR) (FWS 2009c) and two Ecologically Significant River 

23 and Stream Segments: the Brazos River and Mill Creek (TPWD 2010). The Attwater Prairie 

24 Chicken NWR contains one of the largest remnants of coastal prairie habitat in southeast Texas 

25 and provides habitat to the critically imperiled prairie chicken (in 1996 there were fewer than 

26 50 birds in the wild) (TPWD 2009g). The ecologically significant segment of the Brazos River 

27 extends from the confluence with the Gulf of Mexico upstream to Austin/Waller County and 

28 includes riparian conservation areas and rare live oak-water oak-pecan bottomlands 

29 (TPWD 2010). Special habitat features associated with Mill Creek include the rare 

30 gammagrass-switchgrass (Tripsacum dactyloides – Panicum virgatum) bottomland tallgrass 

31 prairie (TPWD 2010). 
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Draft NUREG-1937 9-108 March 2010

1 Important Species 

2 Because of changing land-use practices over the years that have reduced upland game species 

3 habitat in the Texas Parks and Wildlife Oak-Prairie Wildlife District, the occurrence of game 

4 species has been reduced (STPNOC 2009b). This district emcompasses 26 counties in 

5 southeastern Texas; Austin County is in the northcentral section (TPWD 2009h). The demise of 

6 the small farmer, whose farms in the northern district provided excellent habitat for doves and 

7 quail, and the conversion of native pastures to improved grasses to enhance cattle production 

8 have combined to greatly reduce the quail population. Dove hunting is still popular in many 

9 parts of the Oak-Prairie Wildlife District, although the number of available birds is tied to food 

10 supply. There is a hunting season for white-tailed deer and quail in Austin County. Finally, the 

11 Oak-Prairie Wildlife District has two species of turkeys: the eastern turkey (stocked in the 

12 eastern tier of counties) and the Rio Grand turkey (Meleagris gallopavo intermedia), which is 

13 found in many western counties. Turkeys are usually found along the major creek and river 

14 drainages. Most counties do not support a large number of birds (STPNOC 2009b). 

15 The Allens Creek site is within the Central Flyway of Texas (STPNOC 2009b) and would 

16 provide habitat for rest and forage opportunities during migration. There are two birding areas 

17 in the vicinity of the Allens Creek site that support migratory birds: 

18 • The Washington-on-the-Brazos State Historic Park (within the southern portion of the 

19 Prairies and Pineywoods Wildlife Trail West; more than 20 mi north of Allens Creek in 

20 Washington county), where migratory birds have been observed along the Brazos River 

21 (vireos, warblers, tanagers, orioles and neotropical migrants including warblers); and 

22 • Chapel Hill/Brazos River Valley Trail (east of SH 36 near Hempstead, between 10 and 15 mi 

23 north of the Allens Creek site) (STPNOC 2009b), where “[s]pring and fall migrations release 

24 a river of neotropical birds through this area.” 

25 Up to 10 bat species living in eastern Texas, can occur in Austin County (Davis and Schmidly, 

26 1994; STPNOC 2009b). Some are mostly year-round residents (i.e., non-migratory), such as the 

27 big brown bat (Eptesicus fuscus), the eastern pipistrelle (Pipistrellus subflavus), evening bat 

28 (Nycticeius humeralis), and Seminole bat (Lasiurus seminolus). Migratory bats that could occur 

29 at the site include the hoary bat (L. cinereus), the silver-haired bat (Lasionycteris noctivagans), 

30 the eastern red bat (Lasiurus borealis), the big free-tailed bat (Nyctinomops macrotis), the 

31 northern yellow bat (L. intermedius), and the Mexican free-tailed bat (Tadarida brasiliensis). The 

32 Mexican free-tailed bat can be either migratory or non-migratory depending on where it resides; 

33 the migratory status of bats occurring in Austin County is currently unknown (STPNOC 2009b). 

34 No site specific surveys have been conducted for threatened and endangered species at the 

35 Allens Creek site or along likely transmission line corridors. The likely transmission line 

36 corridors could potentially cross into three adjacent counties: Fort Bend, Colorado, and 

37 Wharton. Table 9-14 lists the Federally and State T&E species (FWS 2009a; TPWD 2009f). No 
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March 2010 9-109 Draft NUREG-1937 

1 areas designated as critical habitat for Federally-listed species exist in Austin County or in the 

2 three counties (i.e., Fort Bend, Colorado, and Wharton) where transmission lines may be routed 

3 (STPNOC 2009b). 

4 Table 9-14. List of Federal and State Threatened and Endangered Species in Austin, Fort 

5 Bend, Colorado, and Wharton Counties, Texas 

Group Common Name Scientific Name 

Federal 

Status 

State 

Status County 

Plants Texas prairie dawn-flower Hymenoxys texana E E Fort Bend 

Amphibians Houston toad Bufo houstonensis E E Austin, Fort Bend, 

Colorado 

Alligator snapping turtle Macrochelys temminckii T Austin, Fort Bend 

Smooth green snake Liochlorophis vernalis T Austin 

Texas horned lizard Phrynosoma cornutum T Austin, Fort Bend, 

Wharton, Colorado

Reptiles 

Timber/Canebrake 

rattlesnake 

Crotalus horridus T Austin, Fort Bend, 

Wharton, Colorado

American Peregrine 

Falcon 

Falco peregrinus 

anatum 

 T Austin, Fort Bend, 

Wharton, Colorado

Attwater's Greater PrairieChicken 

Tympanuchus cupido 

attwateri 

E E Austin, Fort Bend, 

Wharton, Colorado

Bald Eagle Haliaeetus 

leucocephalus 

 T Austin, Fort Bend, 

Wharton, Colorado

Interior Least Tern Sterna antillarum 

athalassos 

 E Austin, Fort Bend, 

Wharton, Colorado

White-faced ibis Plegadis chihi T Austin, Fort Bend, 

Wharton, Colorado

White-tailed hawk Buteo albicaudatus T Austin, Fort Bend, 

Wharton, Colorado

Whooping crane Grus americana E E Austin, Fort Bend, 

Wharton, Colorado

Birds 

Wood Stork Mycteria americana T Austin, Fort Bend, 

Wharton, Colorado

Louisiana black bear Ursus americanus 

luteolus 

T/SA T Austin, Fort Bend, 

Wharton, Colorado

Mammals 

Red wolf Canis rufus E Austin, Fort Bend, 

Wharton, Colorado

Sources: FWS 2009a and TPWD 2009f 

T = threatened; E = endangered; T/SA = proposed similarity of appearance to a threatened taxon 

6 Texas prairie dawn-flower

7 The Texas prairie dawn-flower (Hymenoxys texana) is a Federally and State-listed endangered 

8 species and is found in Fort Bend County (FWS 2009a; TPWD 2009f). The plant is a delicate 

9 annual forb found in poorly drained, sparsely vegetated areas at the bases of small mounds in 
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Draft NUREG-1937 9-110 March 2010

1 open grassland or in almost barren areas (NatureServe 2009b). They are found in slightly 

2 saline soils and are sometimes associated with other Texas Gulf Coast Plain endemics such as 

3 Texas windmill-grass (Chloris texensis) and Houston machaeranthera (Machaeranthera aurea). 

4 Houston toad

5 The Houston toad (Bufo houstonensis) is a Federally and State-listed endangered species and 

6 is found in Austin, Fort Bend, and Colorado Counties (FWS 2009a; TPWD 2009f). It lives 

7 primarily on land and burrows into sand for protection from cold weather in the winter and from 

8 hot, dry conditions in the summer. The toads are found in areas with loose, deep sand 

9 supporting woodland savannah and in proximity to still or flowing waters for breeding (TPWD 

10 2009g). The toads have been recorded in Austin County and in the lower Brazos River 

11 watershed (NatureServe 2009b). 

12 Alligator snapping turtle

13 The alligator snapping turtle (Macrochelys temminckii) is a State-listed threatened species and 

14 is found in Austin and Fort Bend Counties (TPWD 2009f). It is found in slow-moving, deep 

15 water of rivers, sloughs, oxbows, and canals or lakes associated with rivers; and also in 

16 swamps, ponds near rivers, and shallow creeks that are tributary to occupied rivers 

17 (NatureServe 2009b). It usually occurs in water with mud bottoms and abundant aquatic 

18 vegetation; it may migrate several miles along rivers (TPWD 2009g). Turtles are rarely found 

19 out of the water except when nesting. 

20 Smooth green snake

21 The smooth green snake (Liochlorophis vernalis) is a State-listed threatened species (TPWD 

22 2009f) and is found in Austin County. Habitats include meadows, grassy marshes, moist grassy 

23 fields at forest edges, mountain shrublands, stream borders, bogs, open moist woodland, 

24 abandoned farmland, and vacant lots (NatureServe 2009b). They have also been found 

25 hibernating in abandoned ant mounds. The snake may be extirpated in Austin County, but has 

26 recently been recorded in the Lower Brazos River watershed. 

27 Texas horned lizard 

28 The Texas horned lizard (Phrynosoma cornutum) is a State-listed threatened species and is 

29 found in Austin, Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). It can be found in 

30 arid and semiarid habitats in open areas with sparse plant cover (TPWD 2009g). They dig for 

31 hibernation, nesting, and insulation purposes, and are commonly associated with loose sand or 

32 loamy soils. Populations have declined precipitously in eastern Texas and their decline may be 

33 related to the spread of fire ants, use of insecticide to control fire ants, heavy agricultural use of 

34 the land and other habitat alterations (NatureServe 2009b). Another factor implicated in their 
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March 2010 9-111 Draft NUREG-1937 

1 decline is over-collecting for the pet and curio trade. This species is particularly vulnerable to 

2 the loss of harvester ants which make up nearly 70 percent of their diet. 

3 Timber/canebrake rattlesnake

4 The timber rattlesnake (Crotalus horridus) is a State-listed threatened species and is found in 

5 Austin, Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). It prefers moist lowland 

6 forests and hilly woodlands or thickets near permanent water sources such as rivers, lakes, 

7 ponds, stream and swamps (TPWD 2009g). Their range extends from central New England to 

8 northern Florida, and west to eastern Texas, where its distribution is spotty 

9 (NatureServe 2009b). 

10 American peregrine falcon 

11 The American peregrine falcon (Falco peregrinus anatum) is a State-listed threatened species 

12 and is found in Austin, Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). The bird is 

13 a year-round resident and local breeder in west Texas where it nests in tall cliff eyries 

14 (TPWD 2009g). The bird also migrates across Texas from breeding areas in United States and 

15 Canada to winter along the coast and farther south. The American peregrine falcon occupies a 

16 wide range of habitats during migration, including urban areas. Populations are primarily 

17 concentrated along coast and barrier islands. The birds are low-altitude migrants, with 

18 stopovers at leading landscape edges such as lake shores, coastlines, and barrier islands. 

19 Attwater’s Greater Prairie Chicken

20 The Attwater’s greater prairie-chicken (Tympanuchus cupido attwateri) is a Federally and State21 listed endangered species and is found in Austin, Fort Bend, Colorado, and Wharton Counties 

22 (FWS 2009a; TPWD 2009f). The prairie chicken lives in the coastal prairie grasslands with tall 

23 grasses such as little bluestem, Indian grass, and switchgrass. The birds like a variety of tall 

24 and short grasses (TPWD 2009g). About 25 percent of the remaining population of the birds is 

25 found on the Attwater Prairie Chicken National Wildlife Refuge (NWR) (NatureServe 2009b) 

26 which is approximately 5 mi west of the Allens Creek site (STPNOC 2009b). No information 

27 was found on the distance the birds can travel, but they can have home ranges in excess of 

28 2000 ac (NatureServe 2009b) (the refuge covers more than 10,500 ac). 

29 Bald eagle 

30 Although recently delisted from a status of Federally-threatened species, the bald eagle 

31 (Haliaeetus leucocephalus) is State-listed as threatened in Texas and will remain Federally 

32 protected under the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act 

33 (TPWD 2009f). The species will also continue to be protected under the ESA through 

34 management guildelines that will be in place for the next five years. Most eagles breed in 
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Draft NUREG-1937 9-112 March 2010

1 Canada and the northern United States and move south for the winter (NatureServe 2009b). 

2 Bald eagles can be year-round residents in areas where water bodies do not freeze. Winter 

3 roost sites can vary with proximity to food resources and eagles commonly roost communally in 

4 large trees, preferably snags. The bald eagle is found in Austin, Fort Bend, Colorado, and 

5 Wharton Counties. 

6 Interior least tern

7 The interior least tern (Sterna antillarum athalassos) is a State-listed endangered species and is 

8 found in Austin, Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). The birds breed 

9 along major inland river systems, but it appears restricted to less altered and more natural river 

10 segments (TPWD 2009g). Interior least terns nest on bare or sparsely vegetated sand, shell, 

11 and gravel beaches, islands, and salt flats associated with rivers and reservoirs. The birds 

12 prefer open habitat and avoid thick vegetation and narrow beaches. They arrive at breeding 

13 areas in early April to early June after wintering along the Central American coast and the 

14 northern coast of South America. 

15 White-faced ibis 

16 The white-faced ibis (Plegadis chihi) is a State-listed threatened species and is found in Austin, 

17 Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). The white-faced ibis prefers 

18 freshwater marshes where they roost on low platforms of dead reed stems or on mud banks 

19 (TPWD 2009g). In Texas, they breed and winter along the Gulf coast and may occur as 

20 migrants in other parts of the State. 

21 White-tailed hawk

22 The white-tailed hawk (Buteo albicaudatus) is a State-listed threatened species and is found in 

23 Austin, Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). In Texas, the white-tailed 

24 hawk is found near the coast in coastal prairies, cordgrass flats, and scrub-live oak 

25 (NatureServe 2009b). The hawk is resident from coastal Texas to southern South America 

26 (Benson and Arnold 2001). 

27 Whooping crane 

28 The whooping crane (Grus americana) is a Federally and State-listed endangered species and 

29 is found in Austin, Fort Bend, Colorado, and Wharton Counties (FWS 2009a; TPWD 2009f). 

30 They breed in Canada during the summer months and migrate to the Aransas National Wildlife 

31 Refuge along the Texas coastal plain, staying there from November through March (TPWD 

32 2009g). Their winter and migrating habitat includes marshes, shallow lakes, lagoons, salt flats, 
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March 2010 9-113 Draft NUREG-1937 

1 and grain and stubble fields (NatureServe 2009b). Migration habitat includes sites with good 

2 horizontal visibility, water depth of 30 cm or less, and a minimum wetland size of 0.1 ac for 

3 roosting. 

4 Wood stork 

5 The wood stork (Mycteria americana) is a State-listed threatened species and is found in Austin, 

6 Fort Bend, Colorado, and Wharton Counties (TPWD 2009f). Nesting appears to be limited to 

7 Florida, Georgia, and South Carolina. However, they may have formerly bred in Texas (FWS 

8 2009b), but there are no breeding records since 1960 (TPWD 2009g). Wood storks forage in 

9 prairie ponds, flooded pastures or fields, ditches, and other shallow standing water, including 

10 salt-water. The birds usually roost communally in tall snags, sometimes in association with 

11 other wading birds (i.e., active rookeries). A distinct, non-listed population of wood storks breed 

12 in Mexico and birds then move into Gulf States in search of mud flats and other wetlands, even 

13 those associated with forested areas. 

14 Louisiana black bear

15 The black bear (Ursus americanus) is on the state endangered species list (TPWD 2009f) due 

16 to its similarity to the Louisiana black bear (subspecies U. a. luteolus). The Louisiana black 

17 bear is a Federally and State-listed threatened species; it is not known to be found in Texas, 

18 although potential habitat exists in the eastern part of the state. Habitat for the Louisiana black 

19 bear is primarily bottomland hardwoods and floodplain forests; it is also found in upland 

20 hardwoods, mixed pine/hardwoods, coastal flatwoods, and marshes (TPWD 2009g). 

21 Red wolf

22 The red wolf (Canis rufus) is a State-listed endangered species (TPWD 2009f). Red wolves 

23 inhabited brush and forested areas, as well as the coastal prairies (Davis and Schmidly 1994). 

24 They formerly ranged throughout eastern Texas, but appear to now be extinct. 

25 Building Impacts 

26 Building two nuclear power units at Allens Creek would affect up to 800 ac of land resulting in 

27 the permanent loss of 300 ac of terrestrial habitat. For the purpose of this assessment, the 

28 review team assumes that the proposed 9500-ac, multiple-use reservoir would be in place 

29 before the two new nuclear power units would be built. To accommodate the building and 

30 operation of two nuclear units on the Allens Creek site, STPNOC would need to clear 

31 undisturbed terrestrial habitats to tie new power lines with existing lines (STPNOC 2009a). 

32 Three new corridors would be required to connect to the three closest 345-kV lines in the area 

33 (STPNOC 2009a). The site is approximately 20 mi west of the 345-kV connection at the 
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1 O’Brien Substation, which connects to multiple double-circuit lines (in Fort Bend County). The 

2 site is 30 mi northwest of a 345-kV line between W.A. Parish power plant and the Hill 

3 Substation, which is a triple-circuit line (in Fort Bend County). The site is also 35 mi northeast of 

4 a 345-kV line between the Holman and Hill substations (connection could be in either Wharton 

5 or Colorado Counties). The total combined distance is 85 mi; based on a 200-ft-width corridor, 

6 installation of new lines would affect 2060 ac. Although the most direct route would be used, 

7 efforts would be made to avoid natural or man-made areas where important environmental 

8 resources are located. This applies particularly to the third potential corridor (i.e., between the 

9 Holman and Hill substations) which would run close to the Attwater Prairie Chicken NWR; the 

10 corridor would be routed south of FM 3013 to avoid potential conflicts (STPNOC 2009b). 

11 Erection of the transmission towers and stringing of the lines would be expected to comply with 

12 all applicable laws, regulations, permit requirements, and use of BMPs (STPNOC 2009a). 

13 In addition to transmission corridors, there would be possible impacts associated with the 

14 building of pipelines to deliver makeup water from the river to the reservoir. Transportation 

15 routes (both road and rail) would also be needed at Allens Creek. Acreage estimates for these 

16 activities are: 5 ac for 0.7 mi of rail (50-ft width), 36 ac for 4 mi of pipeline for the cooling water 

17 intake and discharge between the plant and new reservoir (75-ft width), and 11 ac for a 1.2-mi 

18 access road (75-ft width) (STPNOC 2009a). 

19 No site-specific reports or surveys on Federally or State-listed species were available for the 

20 Allens Creek site or for counties affected by transmission line corridors (i.e., Fort Bend, 

21 Colorado and Wharton Counties). Federally and State-listed species for Austin, Fort Bend, 

22 Wharton, and Colorado Counties are discussed above. At the site visit in 2009, the presence of 

23 numerous wetlands and forested areas in the northwest portion of the site was noted; some of 

24 these areas contained large, old live oaks (NRC 2009b). In addition, one parcel of the Attwater 

25 Prairie Chicken NWR is approximately 5 mi west of the site, while a second parcel is 10 mi west 

26 of the site (STPNOC 2009b). The refuge contains one of the largest remnants of coastal prairie 

27 habitat and is home to one of the last populations of the critically endangered prairie chicken 

28 (FWS 2009c). 

29 Loss of terrestrial habitat and habitat fragmentation associated with building the two new 

30 nuclear reactors and the associated new transmission corridors would noticeably alter terrestrial 

31 resources. Other sources of impacts to terrestrial resources such as increased traffic, noise, 

32 risk of collision and electrocution, and displacement of wildlife would likely be temporary and/or 

33 result in minimal impact to the resource. The disturbance footprint for the two new units would 

34 be small relative to the disturbance footprint for new transmission corridors. 

35 Operational Impacts 

36 Impacts on terrestrial ecological resources from operation of two new nuclear units at the Allens 

37 Creek site include those associated with transmission system structures, and maintenance of 
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1 transmission line corridors. Also, during plant operation, wildlife would be subjected to impacts 

2 from increased traffic. An evaluation of specific impacts resulting from transmission corridor

3 maintenance cannot be conducted in any detail due to the lack of information, such as the 

4 locations of any new rights-of-way that could result from transmission system upgrades. 

5 However, in general, impacts associated with transmission line operation consist of bird 

6 collisions with the lines, EMF effects on flora and fauna, and habitat loss due to corridor 

7 maintenance. 

8 Direct mortality resulting from birds colliding with tall structures has been observed (Erickson et 

9 al. 2005). Factors that appear to influence the rate of avian impacts with structures are diverse 

10 and related to bird behavior, structure attributes, and weather. Migratory flight during darkness 

11 by flocking birds has contributed to the largest mortality events. Tower height, location, 

12 configuration, and lighting also appear to play a role in avian mortality. Weather, such as low 

13 cloud ceilings, advancing fronts, and fog, also contribute to this phenomenon. Waterfowl may 

14 be particularly vulnerable due to low, fast flight and flocking behavior (Brown 1993). Although 

15 additional transmission lines would be required for the two new nuclear units at Allens Creek, 

16 increases in bird collisions directly attributable to these lines would be minor and would likely not 

17 be expected to cause a measurable reduction in local bird populations. 

18 EMFs are unlike other agents that have an adverse impact (e.g., toxic chemicals and ionizing 

19 radiation) in that dramatic acute effects cannot be demonstrated and long-term effects, if they 

20 exist, are subtle (NIEHS 2002). A careful review of biological and physical studies of EMFs did 

21 not reveal consistent evidence linking harmful effects with field exposures (NIEHS 2002). The 

22 magnetic fields from many lines, at a distance of 300 ft are similar to typical background levels 

23 in most homes (NIEHS 2002). Thus, impacts of EMFs on terrestrial flora and fauna are of small 

24 significance at operating nuclear power plants, including transmission systems with variable 

25 numbers of power lines (NRC 1996). Since 1997, more than a dozen studies have been 

26 published that looked at cancer in animals that were exposed to EMFs for all or most of their 

27 lives (Moulder 2003). These studies have found no evidence that EMFs cause any specific 

28 types of cancer in rats or mice (Moulder 2003). 

29 The impacts associated with corridor maintenance activities are loss of habitat due to cutting 

30 and herbicide application and similar impacts where corridors cross floodplains and wetlands. 

31 The maintenance of transmission-line corridors could be beneficial for some species, including 

32 those that inhabit early successional habitat or use edge environments. Thus, corridor 

33 maintenance would not be expected to increase and contribute to cumulative effects. 

34 The potential effects of operating two new nuclear reactors at the Allens Creek site would be 

35 primarily associated with maintenance of transmission corridors and increased traffic. 

36 Operational impacts to terrestrial resources would be expected to be minimal. 
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1 Cumulative Impacts

2 The impacts of building and operating two units at the Allens Creek site were evaluated to 

3 determine the magnitude of their contribution to regional cumulative impacts on terrestrial 

4 ecological resources. Activities related to building and operating at Allens Creek include loss of 

5 habitat at the plant site and along the transmission line corridors. The geographic area of 

6 interest for cumulative impacts at Allens Creek is the intersection of the Western Gulf Coastal 

7 Plains ecoregion with the Brazos and San Bernard watershed within Austin Colorado, Wharton, 

8 Waller, and Fort Bend Counties (Figure 9-10). There are a number of past and potential 

9 projects that could affect the terrestrial and wetland resources at Allens Creek (Table 9-12). 

10 Past actions included building the W.A. Parish Electric Generating Station approximately 30 mi 

11 southeast of the site. The generating station occupies about 4650 ac with two multiple-unit 

12 stations on the site. 

13 Future activities that potentially could affect terrestrial and wetland resources include road 

14 expansion and the development of the Allens Creek reservoir. A four-lane toll road with 

15 frontage roads and a 400-ft corridor is proposed to be developed approximately 40 mi from the 

16 site. Road expansion and future industrial and urban development would contribute to loss of 

17 habitat and fragmentation of existing habitats in the area of interest. 

18 The other future project is building the 9500-ac Allens Creek reservoir for municipal water 

19 supplies; the timeline for the reservoir indicates construction would begin in 2018 (Brazos 2010). 

20 The reservoir would have a substantial impact to wetland and forest resources. Acreages for 

21 the reservoir indicate it would inundate 460 ac of bluff forest, 27 ac of parks, more than 3900 ac 

22 of grassland, and more than 2600 ac of bottomland forest, including more than 1700 ac of 

23 wetland (STPNOC 2009e). Most of the wetlands were mapped as Brazoria depressional soils 

24 with the deepest depressions having a meander pattern, and are probably the remnants of 

25 former cutoff channels or oxbow lakes. These depressions are in bottomland forests. The 

26 dominant tree in the depressions is weedy hackberry (Celtis sp.), with green ash (Fraxinus 

27 pennsylvanica) in the wetter areas. 

28 The review team is also aware of the potential for GCC affecting the terrestrial resources in the 

29 geographic area of interest. The impact of GCC on plant and wildlife species and their habitat in 

30 the geographic area of interest is not precisely known. GCC could result in sea level rise and 

31 may result in regional increases in the frequency of severe weather, decreases in annual 

32 precipitation and increases in average temperature (Karl et al. 2009). Such changes in climate 

33 could alter and fragment key terrestrial habitats (grasslands, forests, and wetlands), and could 

34 result in shifts in species ranges, diversity, and abundance in the geographic area of interest for 

35 the Allens Creek site. 

36 The potential cumulative impact to terrestrial resources within the area of interest given the two 

37 new reactors at the Allens Creek site and associated new transmission corridors and the 
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1 proposed reservoir at the site would noticeably alter terrestrial resources. All these activities 

2 would remove or modify terrestrial habitats with the potential to affect important species living or 

3 migrating through the area. For the reasons discussed above in Building Impacts and 

4 Operational Impacts, the incremental contribution of building and operating the two new reactors 

5 at the Allens Creek site and the associated transmission corridors to the cumulative impacts 

6 within the geographic area of interest would be significant. 

7 Summary 

8 Impacts to terrestrial and wetland resources were estimated based on information provided by 

9 STPNOC and the review teams own independent review. There would be major localized 

10 impacts at the reservoir location based on the potential for affecting 3060 ac of forested land, 

11 including loss of high quality bottomland hardwood habitat and possible impacts to a number of 

12 protected species that could potentially occur in the area. In addition, there is the uncertainty in 

13 the possible routing of new transmission line corridors that could affect more than 2000 ac, 

14 possibly resulting in substantial impacts to terrestrial resources. Based on the information 

15 provided by STPNOC and the review team’s assessment, the review team concludes that the 

16 cumulative impacts within the area of interest on terrestrial plants and animals, including 

17 threatened or endangered species, and wildlife habitat in the region would be MODERATE. 

18 The incremental contribution of impacts on terrestrial resources from the building footprint and 

19 associated transmission lines would be significant. 

20 9.3.3.4 Aquatic Resources 

21 The following impact analysis includes impacts from building activities and operations. The 

22 analysis also considers other past, present, and reasonably foreseeable future actions that 

23 impact aquatic resources, including other Federal and non-Federal projects listed in Table 9-12. 

24 For the analysis of aquatic ecological impacts at the Allens Creek site, the geographic area of 

25 interest is considered to be Allens Creek and the Brazos River drainage, upstream and 

26 downstream to the next major tributaries from the confluence of Allens Creek, because this is 

27 the area that the aquatic resources could be affected by new nuclear units. 

28 Aquatic resources at the Allens Creek alternative site are associated primarily with the Brazos 

29 River and Allens Creek, as well as onsite ponds and drainages (Figure 9-10). The Brazos River 

30 would be the major source of water for the proposed 9500-ac, off-channel reservoir at the site. 

31 Allens Creek originates southeast of the town of Sealy, and flows south through mostly open 

32 country for 9.9 mi before making a strong turn to the east, emptying into the Brazos River after 

33 another 3.7 mi (Linam et el. 1994; STPNOC 2009a). The onsite ponds and drainages are 

34 mostly associated with wetlands. 

35 The reach of the Brazos River through the Allens Creek site has been designated by TPWD as 

36 an ecologically significant stream segment. The characteristics of the reach that are 
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1 ecologically significant include hydrological functions, riparian conservation and the presence of 

2 unique communities within the vicinity of the Allens Creek site (TPWD 2010). 

3 A reservoir at Allens Creek has been part of Texas Water Development Board’s plans for some 

4 time. In preparation for the reservoir’s development, several assessments have been 

5 conducted to characterize the fish and macroinvertebrates as well as to evaluate instream flow 

6 for the support of aquatic life. Linam et al. (1994) inventoried and assessed the fish in Allens 

7 Creek above and through the area proposed to be inundated for construction of a reservoir as 

8 well as at and below the confluence of the creek with the Brazos River. Wood et al. (1994) 

9 assessed macroinvertebrates at the same sampling stations as Linam et al. (1994) in Allens 

10 Creek and the Brazos River. Gelwick and Li (2002) evaluated the mesohabitat use and 

11 community structure of the Brazos River for 10 km above and below the confluence with Allens 

12 Creek. Osting et al. (2004) prepared an instream flow study for the lower Brazos River using 

13 the aforementioned studies as well as others to evaluate impacts to the hydrology and aquatic 

14 life from the proposed Allens Creek Reservoir. 

15 Linam et al. (1994) collected fish, habitat characteristics, and physiochemical measurements to 

16 characterize the Index of Biotic Integrity (IBI) of the fish community in the region of the Allens 

17 Creek alternative site. Forty-four fish species were collected in September and November 

18 1993, from six sites, including four sites in Allens Creek, one at the confluence of Allens Creek 

19 with the Brazos River, and another downstream of the confluence. Western mosquitofish was 

20 the most abundant fish species at all but two sampling stations in Allens Creek. At the first 

21 sampling location within the proposed inundation area for the reservoir, pirate perch 

22 (Aphredoderus sayanus) slightly outnumbered the mosquitofish in September, whereas longear 

23 sunfish (Lepomis megalotis) outnumbered the mosquitofish in November. Red shiner 

24 (Cyprinella lutrensis) was the most abundant species at the confluence of Allens Creek and the 

25 Brazos River in November, and dominated both collections at sites within the Brazos River. 

26 Bullhead minnow were more numerous than red shiners at the last sampling location within 

27 Allens Creek. No one cyprinid species dominated the three upstream stations in Allens Creek, 

28 but blacktail shiner was the most numerous cyprinid in most upstream collections. This shift in 

29 cyprinid abundance between the lower collection locations on Allens Creek may be related to 

30 factors including conductivity, turbidity, and siltation, and perhaps the influence of wastewater 

31 discharged from the City of Wallis treatment plant. Linam et al. (1994) speculated that red 

32 shiners and bullhead minnows appear better suited than many freshwater fishes (including 

33 blacktail shiners) to such physicochemical conditions, providing them an advantage over other 

34 cyprinids in the lower reach of Allens Creek and the Brazos River. Biotic integrity of the 

35 sampling locations varied over time. The sampling location furthest upstream in Allens Creek 

36 was consistently scored as good biotic integrity, while the next sampling station downstream 

37 was fair to good integrity class. The lower two sampling locations in Allens Creek had a biotic 

38 integrity ranging from excellent to good over the sampling period. At the confluence of Allens 

39 Creek and the Brazos River the biotic integrity ranged from good to fair. The Brazos River 
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1 sampling location ranged from good/excellent to good in biotic integrity. The authors concluded 

2 that the species richness in the vicinity of study was comparable to minimally disturbed streams 

3 in Texas. They also concluded that the creation of a reservoir and inundation of Allens Creek 

4 would likely shift the fish community towards species more suited for lentic rather than lotic 

5 habitats. 

6 Wood et al. (1994) sampled at the same locations as Linam et al. (1994) during September and 

7 October 1993. Overall, 32 macroinvertebrate taxa were identified from benthic and snag 

8 habitats. The most common taxa were insects (78 percent), with the remaining number of 

9 organisms divided among Amphipoda (4 percent), Annelida (7 percent), Bivalvia (4 percent), 

10 Decapoda (7 percent) and other minor taxa. Benthic habitats were dominated by Annelida 

11 (11 percent), Chironomidae (Diptera) (50 percent), Baetis spp. (Ephemeroptera) (8 percent), 

12 and Popenaias sp. (unioid mussel) (6 percent). The dominant taxa for snag habitats were 

13 Chironomidae (73 percent), Hydropsyche spp. (Tricoptera) (10 percent), Leptohyphes spp. 

14 (Ephemeroptera) (5 percent), and Argia spp. (Odonata) (3 percent). Chironomids were the 

15 most numerous organisms collected in both snag and benthic habitats with densities ranging 

16 from 9 to more than 1000 organisms per square meter. Snag habitats had the greatest density 

17 of macroinvertebrates, with more than 2000 organisms per square meter. Snags and large 

18 woody debris in the stream beds created important structural components for 

19 macroinvertebrates by increasing the surface area for their food source, and in turn create 

20 essential food resources for the fish community. The authors characterized the region as 

21 relatively high stress environments for macroinvertebrates due to the rapid fluctuations in water 

22 level, temperature, and substrate movement. The results of the macroinvertebrate community 

23 assessment indicated a slightly impaired to moderately impaired system and that some level of 

24 impact was occurring from the wastewater effluents entering Allens Creek from the Cities of 

25 Sealy and Wallis, as well as from agricultural and ranching activity in the watershed. 

26 Interestingly, the only bivalve mollusk collected was identified as the unioid mussel genus, 

27 Popenaias. The only species in Texas of this genus is P. popeii, the Texas hornshell. TPWD 

28 did not identify this species of freshwater mussel in Austin County. The FWS lists the Texas 

29 hornshell as a candidate species, and it is considered a proposed threatened species by TPWD. 

30 From 74 to 153 specimens of this species were collected from the upper reach sampled in 

31 Allens Creek, and the number of specimens declined in the lower sampling locations along the 

32 creek. Additional specimens were collected in the Brazos River sampling location (Wood et al. 

33 1994). 

34 Gelwick and Li (2002) analyzed fish habitat utilization on the basis of visually delineated 

35 mesohabitats in the Brazos River above and below its confluence with Allens Creek, and 

36 included information about fish habitat at different flow conditions. From September 2001 

37 through August 2002, six collections were completed over a range of river discharges, and 43 

38 species representing 14 families of fish species were collected. Red shiners and bullhead 

39 minnows accounted for 67.4 percent and 16.9 percent of the collections, respectively. Other 
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1 common species (abundances exceeding 1 percent of overall collections) were ghost shiner 

2 (Notropis buchanani), silverband shiner (N. shumardi), striped mullet, and mosquitofish. 

3 Notably, three individuals of sharpnose shiner (Notropis oxyrhynchus), a candidate species for 

4 Federal listing by FWS, were collected in the confluence of Allens Creek and the Brazos River. 

5 As did Linam et al. (1994), the authors calculated the IBI for the mesohabitats that were 

6 evaluated. Based on seined samples, all the sites in the reach of the Brazos River that was 

7 included in the study had IBI metrics of excellent across all six collections over a range of flows, 

8 except for a good rating in September 2001. The authors noted that their study reach also 

9 scored consistently higher than the scores for seine and electrofishing collections calculated 

10 previously in the Brazos River, where that study sampled smaller areas of the river than their 

11 study. Overall, the authors found that no significant fish habitat utilization variation in the Brazos 

12 River in the vicinity of the Allens Creek alternative site could be explained by visually-classified 

13 mesohabitat and that the fish communities were habitat generalists. 

14 Osting et al. (2004) used the available assessments of aquatic communities in Allens Creek and 

15 the Brazos River to identify potential impacts from the construction of a reservoir at the Allens 

16 Creek site. The analyses focused on hydrology, fish habitat, and the potential for salinity 

17 migration in the lower Brazos River. The authors used three different methods to investigate the 

18 distribution of fish species within aquatic habitats in the vicinity of the alternative site, and found 

19 that two of the analyses indicated fish communities were made up of habitat generalists, and 

20 one analysis indicated some degree of habitat specialization. This indicated that fish species 

21 relationships related to specialized habitat conditions was strong for some species, and 

22 identified fish indicators for habitat evaluations. The resulting hydrodynamic model predicted 

23 that Allens Creek Reservoir would not be anticipated to have significant effect on salinity 

24 migration in the lower Brazos River estuary. 

25 Within Allens Creek and the Brazos River drainage, upstream and downstream to the next 

26 major tributaries from the confluence of Allens Creek, there are a number of past, present and 

27 potential projects that could affect the aquatic resources (Table 9-12). Past actions included 

28 building and operating the coal- and gas-powered W.A. Parish Electric Generating Station and 

29 the wastewater treatment systems for the Cities of Sealy and Wallis. TCEQ, Brazos River 

30 Authority and other state agencies have been planning on construction of a reservoir at the 

31 Allens Creek site and the water would be available for multiple uses, including power 

32 production. The building of new nuclear units, include a water intake and discharge systems 

33 with associated pipelines from the Brazos River to the new site, inundation of Allens Creek for 

34 development of a reservoir, and associated transmission corridors to connect with the existing 

35 power grid. Without having the specific plans for locating all facilities at the Allens Creek site, 

36 the potential for impacts from building and operation of the new units to aquatic biota are 

37 assumed to be primarily to the organisms inhabiting the Allens Creek and the Brazos River. 
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1 Non-Native and Nuisance Species 

2 No non-native or nuisance species have been recorded in the area as a problem. However, 

3 there are numerous nuisance aquatic species that TPWD considers to be ubiquitous across 

4 waterways in Texas. TPWD works to educate recreational boaters to remove nuisance aquatic 

5 plant species across the state and in the area of the Allens Creek site. These species include: 

6 hydrilla, waterhyacinth, and giant salvinia. In addition, the Brazos River basin is known to have 

7 the following non-native fish introduced to its waters: common carp, grass carp, blacktail shiner, 

8 bullhead minnow, rudd, black buffalo, black bullhead, western starhead topminnow, redspotted 

9 sunfish, tadpole madtom, plains killfish, yellow perch, and walleye (Thomas et al 2007; Hassan10 Williams and Bonner 2009; TPWD 2009h). The introduced bullhead minnow and blacktail 

11 shiner have become some of the most abundant species in Allens Creek and at the confluence 

12 with the Brazos River (Linam et al. 1994; Gelwick and Li 2002). 

13 Important Species 

14 Osting et al. (2004) reported that TPWD observed very little recreational fishing during creel 

15 assessments by TPWD on the Brazos River. Catfish were the most sought after fish in the 

16 area, including channel, blue, and flathead catfish. The greatest catch per unit effort (CPUE) in 

17 the Brazos River at Simonton (downstream of confluence with Allens Creek) was for channel 

18 catfish, followed by flathead catfish and blue catfish. In the vicinity of the Allens Creek site on 

19 the Brazos River, recreational boating is limited because steep banks make access difficult and 

20 state parks and wildlife management areas that support recreational boating are far away. 

21 There are no Federally listed species in Austin County. However, the FWS considers the 

22 sharpnose shiner a candidate for listing (Table 9-15) (TPWD 2009d; FWS 2009a). Gelwick and 

23 Li (2002) reported finding three sharpnose shiners at their sampling location in the confluence of 

24 Allens Creek and the Brazos River; Linam et al. (1994) did not collect this species almost a 

25 decade earlier. TPWD has identified several rare and protected species in Austin County: a 

26 mayfly species (Pseudocentroptiloides morihari) as well as the freshwater mussels rock 

27 pocketbook (Arcidens confragosus) and pistolgrip (Tritogonia verrucosa). The rare and 

28 protected mayfly is a benthic macroinvertebrate, which lives on the bottom of streams until it 

29 emerges from the water as a flying adult (TPWD 2009i). In addition, TPDW lists as threatened 

30 three species of freshwater, unioid mussels that are found in Austin County: smooth 

31 pimpleback (Quadrula houstonensis), false spike mussel (Quincuncina mitchelli), and Texas 

32 fawnsfoot (Truncilla macrodon) (Table 9-15) (TPWD 2009i; 35 Texas Register 249). Not much 

33 is known about the distribution of these mussels in Austin County, and the only known survey 

34 for benthic macroinvertebrates did not collect these species (Wood et al. 1994). However, 

35 these types of mussels, known as unioid mussels, are found in various water flows, from fast 

36 moving riffles in streams to quiescent ponds. Each species has adapted to a particular flow 

37 regime. These unioid mussels have a larval stage called a glochidium. For glochidia to mature 

38 to juvenile mussels, they must live as a parasite in the gill tissues of a host fish. An important 
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1 component to the distribution of freshwater mussels in various water bodies is associated with 

2 the relationship between the mussels and the host fish (Strayer 2008). 

3 Table 9-15. Federally and State-Listed Aquatic Species that are Endangered, Threatened, and 

4 Species of Concern for Austin County 

Scientific Name Common Name Federal Status(a) State Status(b)

Fish 

Notropis oxyrhynchus sharpnose shiner FSC 

Mussel 

Quadrula houstonensis smooth pimpleback T 

Quincuncina mitchelli false spike mussel T 

Truncilla macrodon Texas fawnsfoot T 

(a) Federal status rankings determined by the FWS under the Endangered Species Act, FSC = Federal Species of 

Concern (FWS 2009a). 

(b) State species information provided by TPWD, T = State Listed Threatened (TPWD 2009d; 35 Texas Register 

249).

5 Building Impacts 

6 For the purpose of this assessment, the review team assumes that the proposed 9500-ac, 

7 multiple-use reservoir would be in place before the two new nuclear power units would be built. 

8 Impacts associated with the building of the reservoir are considered below in the cumulative 

9 impacts discussion. 

10 Water intake and discharge structures along the shoreline of the Brazos River would be 

11 required for the Allens Creek reservoir at the Allens Creek site (STPNOC 2009a). Building a 

12 new intake and discharge in the Brazos River would likely require dredging and other significant 

13 alterations to the shoreline aquatic habitat. These activities, which would be unrelated to the 

14 building and operating of two nuclear units at the Allens Creek site, would be permitted by the 

15 Corps and the construction activities would have to meet all State water quality requirements. 

16 Building these structures on the Brazos River would result in the temporary displacement of 

17 aquatic biota within the vicinity of both structures. It is expected that the motile aquatic 

18 organisms would be displaced temporarily during building, including such fish species as the 

19 sharpnose shiner. However, the sessile aquatic biota (e.g., mussels) would be lost during 

20 building activities if the river substrate was removed or sedimentation covered the bottom of the 

21 river burying the organisms. Organisms like the mussels could possibly recolonize the 

22 disturbed river substrate with time. If required by TPWD, State-listed threatened mussels could 

23 be surveyed and removed before building activities as a mitigation action. For the most part, 

24 the impacts on aquatic organisms would be temporary and largely mitigable through the use of 

25 BMPs, e.g., silt screens. 
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1 Building transportation routes (heavy haul road and railroad spur), pipelines and transmission 

2 lines for the Allens Creek site would result in the temporary displacement of some aquatic biota. 

3 Locations for these systems have not been identified. Building new transmission line corridors 

4 could result in noticeable impacts; however, effects to the aquatic resources could be minimized 

5 by routing the corridor away from water bodies or spanning the water bodies without placement 

6 of transmission tower footings in aquatic resource habitats. BMPs would be used while building 

7 these corridors to reduce impacts such that they would be temporary and localized (STPNOC 

8 2009a). Depending on whether or not the intake and discharge structure are built in the 

9 reservoir before or after filling of the reservoir, some adverse impacts to aquatic biota could 

10 occur. Such impacts would be confined in their extent and temporary, and would affect similar 

11 species and habitats that would be affected during construction of the intake structure on the 

12 Brazos River. 

13 Building the intake and discharge structures on the Brazos River and in the new reservoir would 

14 affect the aquatic communities but the areas would be recolonized after building these 

15 structures was completed. Building of the transportation routes, transmission corridors, and 

16 pipelines would result in temporary and localized effects on aquatic communities. 

17 Operation Impacts 

18 The Brazos River instream flow study determined that the aquatic resources could be 

19 maintained with diversion of water to the proposed Allens Creek reservoir (Osting et al. 2004). 

20 Water withdrawal and water return to the Brazos River could be managed in such a way that 

21 impacts to this ecologically significant stream section could be maintained with minimal impacts 

22 to the aquatic resources and associated riparian habitat (STPNOC 2009a). 

23 Impingement, entrainment, and entrapment of organisms from the Brazos River and from the 

24 reservoir would likely be the most significant impacts to the aquatic population that could occur 

25 from operation of two new nuclear units at the Allens Creek site. EPA’s design criteria for 

26 316(b) Phase 1 regulations (66 FR 65256) for intake structures would minimize impacts to 

27 aquatic biota in the reservoir. The design criteria include: (1) closed-cycle cooling system that 

28 meets the EPA’s Phase I regulations for new facilities; (2) maximum through-screen velocity of 

29 0.15 m/s (0.5 ft/s) at the cooling water intake; and (3) intake flow of less than or equal to 5 

30 percent of the mean annual flow (STPNOC 2009a). Compliance with these regulations would 

31 minimize impingement, entrainment, and entrapment impacts to the aquatic biota in the 

32 reservoir. 

33 Operational impacts associated with water quality, physical, and thermal characteristics of the 

34 discharge cannot be determined without additional detailed analysis. The proposed reservoir 

35 for the Allens Creek site would likely evolve in a similar fashion to the MCR at the STP site, 

36 where, with time, the reservoir has developed similar aquatic resources to that in the lower 

37 Colorado River and acclimated to the discharges of the operating reactor units. Impacts to the 
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1 Brazos River would depend on the type of cooling system for the new units as well as the 

2 volume, frequency, and water characteristics of the discharge. These types of impacts can be 

3 addressed and minimized through operational procedures and the permitting process with 

4 TCEQ. 

5 Operational impacts to aquatic biota from onsite activities and in the transmission corridors 

6 would also be minimal assuming BMPs are used for maintenance of these areas and corridors. 

7 SWPPPs would ensure that impacts to biota from erosion and sedimentation would be minimal 

8 through the use of silt screens and controls for managing stormwater. These controls would be 

9 important for habitat quality and survival of benthic biota in the downstream drainages. 

10 Based on operation of the CWS, impacts to aquatic communities in the Brazos River and 

11 reservoir could result from impingement, entrainment, and entrapment as well as thermal, 

12 chemical, and physical characteristics of the discharge. STPNOC commits to compliance with 

13 State and Federal regulations for operation of intake and discharge structures associated with 

14 the nuclear units that would be protective of aquatic resources. Once a community is 

15 established in the new reservoir, long-term effects from operation of the CWSs are not expected 

16 to noticeably alter aquatic communities in the Brazos River and reservoir. 

17 Cumulative Impacts 

18 Within Allens Creek and the Brazos River drainage, upstream and downstream to the next 

19 major tributaries from the confluence of Allens Creek, current and future plans for water usage 

20 by municipalities and industries have influenced the aquatic ecology of the region. Included in 

21 such plans is the Allens Creek Reservoir to supply water to the City of Houston. 

22 Impacts of building the reservoir at Allens Creek may be significant depending on the siting of 

23 the reservoir. The proposed plans are for inundating approximately 7 to 9 mi of Allens Creek to 

24 the confluence with the Brazos River. Impacts from onsite building activities that have the 

25 potential to cause erosion and sedimentation to the local water bodies would be controlled or 

26 minimized by the implementation of an SWPPP (STPNOC 2009a). Habitat for aquatic species, 

27 including any spawning areas for fish species that are dependent on flowing water, that are 

28 found in Allens Creek and the associated wetlands and drainages would be lost when these 

29 water bodies are inundated to create the reservoir. In addition, the snags and large woody 

30 debris in the lower reaches of Allens Creek would be less likely to accumulate after building the 

31 reservoir, and this habitat was thought to contribute to the high abundance of 

32 macroinvertebrates in the creek (Wood et al. 1994). Most freshwater mussel species are 

33 adapted to a specific flow regime, and the inundation of Allens Creek could affect the 

34 distribution of the organisms in the region (STPNOC 2009a; TPWD 2009i). If habitat for the 

35 sharpnose shiner or any of the State-listed mussels is found in the area to be inundated for the 

36 creation of the reservoir, the FWS and/or TPWD might require mitigation activities. 
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1 Other uses of the reservoir would include cooling for power production and recreation, 

2 e.g., fishing and boating. Allens Creek and possibly the proposed reservoir would be influenced 

3 mostly by discharges from the wastewater treatment plants for the Cities of Sealy and Wallis as 

4 well as agricultural development and ranching activities along the riparian areas (Linam et al. 

5 1994; Wood et al. 1994). The coal- and gas-powered W.A. Parish Electric Generating Station is 

6 approximately 40 mi downstream of the Allens Creek site, and uses water from the Brazos River 

7 stored in Smithers Lake. Building in and along the shoreline of the Brazos River for the Allens 

8 Creek site is not likely to influence the sediment transport and aquatic ecology beyond the 

9 geographic area of interest because the activities would be relatively short in duration and 

10 BMPs would minimize impacts. In addition, Osting et al. (2004) found that salinity intrusion up 

11 the Brazos River is unlikely based on its instream modeling of a reservoir at Allens Creek. 

12 Continued urbanization and agricultural practices could affect aquatic communities in the Allens 

13 Creek geographic area of interest in the foreseeable future. Expansion of urban areas in the 

14 Brazos River drainage could increase water use, decrease available water for aquatic 

15 resources, and increase nonpoint pollution. The effects of continued agricultural practices could 

16 result in additional habitat loss and/or degradation due to irrigation using surface waters and 

17 groundwater withdrawal, nonpoint source pollution, siltation, and bank erosion. 

18 As mentioned above in the terrestrial section, GCC could result in regional increases in the 

19 frequency of severe weather, decreases in annual precipitation, and increases in average 

20 temperature (Karl et al. 2009). The decrease in precipitation combined with elevated water 

21 temperatures and evaporation could result in more frequent droughts, which could reduce 

22 aquatic habitat. Loss of habitat could cause shifts in species ranges, diversity, and abundance 

23 in the geographic area of interest for the Allens Creek site (Karl et al. 2009). Specific 

24 predictions on aquatic habitat changes and impacts to aquatic species in this region resulting 

25 from GCC are inconclusive at this time. Because of the regional nature of climate change, the 

26 impacts related to GCC would be similar for all the alternative sites, as they are all in the Great 

27 Plains region. 

28 Based on building and operation of two new nuclear units at the Allens Creek alternative site 

29 and other projects and influences in the region of influence for aquatic resources, the 

30 cumulative impacts would be noticeable but not destabilizing. All these activities would alter the 

31 aquatic habitats and potentially change the species composition and diversity in the affected 

32 water bodies. 

33 Summary 

34 The review team concludes that the impacts from building and operating two new nuclear units 

35 at the Allens Creek site would be minimal. Building of a multi-use reservoir at Allens Creek 

36 would inundate existing water bodies and destroy habitat for aquatic resources that are 

37 dependent on flowing water. Based on the information provided by STPNOC and the review 
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Draft NUREG-1937 9-126 March 2010

1 team’s independent evaluation, the review team concludes that the cumulative impacts of 

2 building and operating two new reactors on the Allens Creek site combined with other past, 

3 present, and future activities on most aquatic resources in the Brazos River drainage would be 

4 MODERATE. The incremental contribution of building and operating the two new reactors at 

5 the Allens Creek site to the cumulative impacts within the geographic area of interest would not 

6 be significant. 

7 9.3.3.5 Socioeconomics 

8 The following impact analysis includes impacts from building activities and operations. The 

9 analysis also considers other past, present, and reasonably foreseeable future actions that 

10 impact socioeconomics, including other Federal and non-Federal projects listed in Table 9-12. 

11 For the analysis of socioeconomic impacts at the Allens Creek site, the geographic area of 

12 interest is considered to be the 50-mi region centered on the Allens Creek site with special 

13 consideration of Austin and Fort Bend Counties as that is where the review team expects 

14 socioeconomic impacts to be the greatest. In evaluating the socioeconomic impacts of site 

15 development and operation at the Allens Creek site near Wallis and Sealy, in Austin County, the 

16 review team undertook a reconnaissance survey of the site using readily obtainable data from 

17 the Internet or published sources. Impacts from both site development and station operation 

18 are discussed. 

19 Physical Impacts 

20 Many of the physical impacts of building and operation would be similar regardless of the site. 

21 Building activities can cause temporary and localized physical impacts such as noise, odor, 

22 vehicle exhaust, vibration, shock from blasting (if used), and dust emissions. The use of public 

23 roadways, railways, and waterways would be necessary to transport construction materials and 

24 equipment. Offsite areas that would support building activities (for example, borrow pits, 

25 quarries, and disposal sites) would be expected to be already permitted and operational. 

26 Potential impacts from station operation include noise, odors, exhausts, thermal emissions, and 

27 visual intrusions (the latter are covered under aesthetics and recreation). New units would 

28 produce noise from the operation of pumps, cooling towers, transformers, turbines, generators, 

29 and switchyard equipment. Traffic at the site also would be a source of noise. Any noise 

30 coming from the proposed STP site would be controlled in accordance with standard noise 

31 protection and abatement procedures. This practice also would be expected to apply to all 

32 alternative sites, including the Allens Creek site. Commuter traffic would be controlled by speed 

33 limits. Good road conditions and appropriate speed limits would minimize the noise level 

34 generated by the workforce commuting to the alternative site. 

35 The new units at the Allens Creek site would likely have standby diesel generators and auxiliary 

36 power systems. Permits obtained for these generators would ensure that air emissions comply 
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March 2010 9-127 Draft NUREG-1937 

1 with applicable regulations. In addition, the generators would be operated on a limited, short2 term basis. During normal plant operation, new units would not use a significant quantity of 

3 chemicals that could generate odors that exceed odor threshold values. Good access roads 

4 and appropriate speed limits would minimize the dust generated by the commuting workforce. 

5 Based on the information provided by STPNOC and the review team’s independent evaluation, 

6 the review team concludes that the physical impacts of building and operating two nuclear units 

7 at the Allens Creek site would be minimal. 

8 Demography 

9 The Allens Creek site is located in Austin County (2008 population 26,851), 4.4 mi north of the 

10 city of Wallis (2007 population 1287) and 7.3 mi southeast of Sealy (2008 population 6190), and 

11 within 50 mi of the outer edges of the Houston Metropolitan area (2008 population 5.7 million) 

12 (USCB 2009e). Fort Bend County (2008 population 532,141) was one of the fastest growing 

13 counties in the United States during recent decades as Houston suburbs have expanded 

14 westward into the county. 

15 STPNOC estimated the peak number of construction workers would be 5950. Approximately 

16 900 operations workers would also be onsite during the final phase of building activities 

17 (STPNOC 2008c). Based on assumptions in Section 4.4 concerning in-migration for Units 3 

18 and 4 in Matagorda County, the review team assumed that 50 percent or 2975 construction 

19 workers would in-migrate, with half of these moving to Austin County and the other half to Fort 

20 Bend County. Eighty percent of in-migrating construction workers would bring a family. Harris 

21 County, which includes Houston, would likely see an in-migration of workers as well, but 

22 considering the large populations of this county and the relatively small number of in-migrants 

23 they would be easily absorbed without noticeable impacts. All operations workers would in24 migrate and all would bring a family. A family size of 3.25 was used for construction workers for 

25 a total peak site development related population increase of 8330 (7735 in-migrating workers 

26 and family members and 595 workers without family). An average family size of 2.74 for the 

27 operating workforce (see Section 5.4) would result in a total in-migrating operations-related 

28 population of 2466 (900 operations workers plus family). Therefore, the total expected in29 migrating population (site development and operations) at peak building would be 10,796. 

30 Because the assumed in-migrating population would be about 1 percent of the total population 

31 for Fort Bend County, the demographic impacts of building activities are expected to be minimal 

32 for this county. However, the impacts would likely be noticeable and significant in the smaller 

33 Austin County, where the in-migrating population represents 20 percent of the current 

34 population. If the facility is completed and commences operations, the operational workforce 

35 would number about 959 workers, 900 of whom would be at the site during building activities 

36 and are included in the above analysis. The review team expects that the demographic impact 

37 during operation would be minimal for all counties in the region. Based on the information 
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1 provided by STPNOC and the review team’s independent evaluation, the review team 

2 concludes that the demographic impacts of building and operating two nuclear units at the 

3 Allens Creek site would be significant. 

4 Taxes and Economy 

5 As described in Section 5.4.3.2, STPNOC estimates it would spend $60 million annually for 

6 goods and services related to the new units, of which about 20 percent ($12 million) would be 

7 spent locally (STPNOC 2008b). STPNOC estimated if the units were 100 percent taxable, 

8 annual franchise taxes for Unit 3 would be $4.7 to $5.4 million and Unit 4 would have payments 

9 of $3.9 to $4.7 million which would represent less than 1 percent of the State’s annual franchise 

10 tax revenues. 

11 The largest tax impacts would come from property taxes related to the building and operations 

12 activities of the two units. The owners of STPNOC would pay taxes to the county, any 

13 applicable special districts that exist within the county and the local school district in which the 

14 land sits. During the building process, county property tax payments would be based on the 

15 cost of building the units and determined in accordance with state law using mutually agreed on 

16 appraisal formulas (STPNOC 2009a). During operations property taxes would range from $6.10 

17 million to $13.86 million. Taxes from the nuclear plant would represent a 58 to 131 percent 

18 increase over the 2008 Austin County taxes levied of $10.6 million. Development of the Allens 

19 Creek site for a nuclear power plant also would require a cooling water source. STPNOC 

20 believes that proposed 9500-ac reservoir to the east of the power plant footprint could perform 

21 that function. Such a reservoir, if built, could remove approximately 9500 ac from the property 

22 tax rolls, with a resulting significant tax loss to Austin County. 

23 Increased property values in the district would increase the tax payments made to Brazos 

24 independent school district (ISD), which is a Texas Education Code Chapter 42 “poor district” 

25 (TEA 2009) This means the Brazos ISD could keep most if not all of the additional tax revenues 

26 generated by the development of a nuclear plant within the district lines. Although the exact 

27 amount currently is unknown, the tax payments are likely to represent a substantial beneficial 

28 impact for both the small, rural county of Austin County and for Brazos ISD. Brazos ISD’s total 

29 tax revenue in 2008 was $9.2 million (Global Scholar 2008). 

30 Economic impacts would be spread across the 50-mi region but would be greatest in Austin 

31 County. Austin County per capita income for 2007 is $35,580 and $41,779 for Fort Bend 

32 County (Texas Association of Counties 2009c, d). The 2008 unemployment rate for Austin 

33 County and Fort Bend County was 4.3 percent and 4.5 percent, respectively (Texas Association 

34 of Counties 2009c, d). The wages and salaries of the building- and operations-related 

35 workforces would stimulate local economies and increase business activity, particularly in the 

36 retail and service sectors. This would have a positive and noticeable impact on the business 
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March 2010 9-129 Draft NUREG-1937 

1 community and could provide opportunities for new businesses and increased job opportunities 

2 for local residents. Based on the information provided by STPNOC and the review team’s 

3 independent evaluation, the review team concludes that the tax and economic impacts of 

4 building and operating two nuclear units at the Allens Creek site would be significant and 

5 beneficial. 

6 Transportation and Housing 

7 Both Austin and Fort Bend Counties have well developed road networks. The local 

8 transportation network near the site includes Interstate 10 (I-10), US-90, SH-36, and several FM 

9 roads. Primary access to the site is from I-10 which is approximately 6 mi south of the site. 

10 Commuters would likely take I-10 to SH 36, a two lane road in good condition, which provides 

11 direct access to the site. A new access road would need to be constructed to provide access 

12 inside the site. I-10 east and west of Sealy has an annual average daily traffic count (AADT) of 

13 46,000 and 38,000, respectively. The I-10 SH 36 intersection has an AADT of 22,000 but the 

14 part of SH 36 between Sealy and Wallis, where direct access to the site would be, is only 5900. 

15 The most likely pinch points would be at several intersections on SH 36 between Sealy and 

16 Wallis. Provision would have to be made to cross the rail line that closely parallels SH 36 

17 between the highway and the site. Rail traffic is heavy enough on this corridor to possibly 

18 require coordination between rail and site vehicular traffic. Less than a mile of rail would need 

19 to be constructed (STPNOC 2009a). The review team expects the transportation impacts from 

20 building a plant at the Allens Creek site would be significant but not destabilizing on SH 36 and 

21 would warrant mitigation. Operation impacts would be minimal due to the much smaller 

22 workforce and because roads would have been improved during the site development phase. 

23 Approximately 3875 construction and operations workers could migrate into the region during 

24 peak site development. During operations the workforce is expected to be about 959 workers of 

25 which 900 are included in the 3875 workers needing housing during peak building activity. 

26 U.S. Census Housing Profile for Austin County estimated a total housing stock of 10,822 units 

27 with a rental vacancy rate of 11.4 percent. Approximately 1487 housing units were unoccupied 

28 at the time of the survey (USCB 2009e). The U.S. Census Housing Profile for Fort Bend County 

29 estimated a total housing stock of 148,484 units with a rental vacancy rate of 8.7 percent. 

30 Approximately 9209 housing units were unoccupied at the time of the survey (USCB 2009f). 

31 Some workers may choose to find other housing such as an apartment while others may in32 migrate with their own housing in the form of a travel trailer. The review team expects that the 

33 in-migrating workforce would be absorbed easily into the existing housing stock in Fort Bend 

34 County and the region without a measurable impact, but if workers concentrate closer to the 

35 plant, the impacts could be noticeable but not destabilizing due to the smaller number of 

36 housing units available. Based on the information provided by STPNOC and the review team’s 

37 independent evaluation, the review team concludes that the transportation and housing impacts 

38 of building and operating two nuclear units at the Allens Creek site would be noticeable. 
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1 Public Services and Education 

2 The influx of construction workers and plant operations staff settling in the region could impact 

3 local municipal water and water treatment facilities and other public services in the region. 

4 These impacts would likely be in proportion with the demographic impacts experienced in the 

5 region, unless these resources have excess capacity or are particularly strained during building, 

6 which would decrease or increase the impact, respectively. For example, the largest water 

7 treatment facilities in Austin County and Fort Bend County have water capacity available that is 

8 roughly three to ten times current average daily consumption (EPA 2009b), so while they may 

9 have to build considerable distribution infrastructure they are unlikely to be water capacity 

10 limited. 

11 The in-migrating workers represent a small portion of the total population of Fort Bend County 

12 and would likely have a minimal impact on their public services. In the smaller Austin County 

13 the impacts during building could be more noticeable due to a strain on public services from a 

14 relatively larger population increase in this county. During operations the impact on public 

15 services would diminish to minimal levels throughout the region. 

16 Austin County has 3 independent school districts with 13 schools and Fort Bend County has 6 

17 independent school districts with 174 schools. The 2007-2008 student enrollments for Austin 

18 and Fort Bend County are 5641 students and 149,952 students, respectively (NCES 2009). 

19 The review team expects a peak building-related increase of about 2537 students (1269 in each 

20 county). The in-migrating students would be less than 1 percent of the current student 

21 population and would have a minimal impact to schools in Fort Bend County. However, the 

22 increase would be a 23 percent increase in the student population in Austin County, where the 

23 review team expects the impact would be significant and potentially destabilizing to this school 

24 system. The impact from operations-related new students would decline to minimal levels 

25 everywhere. Based on the information provided by STPNOC and the review team’s 

26 independent evaluation, the review team concludes that the public service and education 

27 impacts of building and operating two nuclear units at the Allens Creek site would be significant. 

28 Aesthetics and Recreation 

29 Recreation in the area includes the historic Texas Independence Trail, the Stephen F. Austin 

30 Historical Park, and the Attwater Prairie Chicken National Wildlife Refuge (STPNOC 2009a). 

31 Building of the reservoir would impact a 7-mi stretch of the Texas Independence Trail. During 

32 building activities, drivers along the Texas Independence Trail would experience modest 

33 inconvenience from building activities or by the occasional closure of the road. During 

34 operations, drivers would receive minimal impacts from additional cars on the road commuting 

35 to the site. The building and operation of the plant itself and transmission lines to support the 

36 site would have a noticeable aesthetic impact on the region. Based on the information provided 
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March 2010 9-131 Draft NUREG-1937 

1 by STPNOC and the review team’s independent evaluation, the review team concludes that the 

2 aesthetic and recreation impacts of building and operating two nuclear units at the Allens Creek 

3 site would be noticeable. 

4 Summary of Socioeconomics 

5 Physical impacts on workers and the general public include impacts on existing buildings, 

6 transportation, aesthetics, noise levels, and air quality. Social and economic impacts span 

7 issues of demographics, economy, taxes, infrastructure, and community services. In summary, 

8 on the basis of information provided by STPNOC and the review team’s independent evaluation, 

9 the review team concludes that the socioeconomic impacts of the building and operation of a 

10 new nuclear plant at the Allens Creek site would be minimal and adverse for Fort Bend County 

11 and the region but could be noticeable and adverse in terms of transportation, housing, public 

12 services, and significant and adverse for demographics and education impacts in Austin County 

13 during the building phase. Aesthetic and recreational impacts would be noticeable and adverse. 

14 The impacts on the Austin County economy and tax base during plant building and operation 

15 likely would be beneficial and significant. 

16 Cumulative Impacts 

17 For the analysis of socioeconomic impacts at the Allens Creek site, the geographic area of 

18 interest is the 50-mi region centered on the Allens Creek site with special consideration of 

19 Austin and Fort Bend Counties as that is where the review team expects socioeconomic 

20 impacts to be the greatest. After World War II and the introduction of irrigation, agriculture 

21 supported the local economy in Austin County. Much of the land used for cotton farming was 

22 converted to ranchland and livestock production became the chief industry after World War II. 

23 Manufacturing in Austin County also increased after World War II due in part to the heavy 

24 industry coming out of Houston (TSHA 2009e). Traditionally, Fort Bend County’s economy was 

25 based on farming and ranching but that has declined over the last several decades. Cotton, 

26 sorghum and rice are all still important crops in Fort Bend County however farms produce more 

27 cattle than any other commodity. The county also produces numerous minerals and the first 

28 oilfields were drilled in the 1920s. The petroleum industry was the most important industry in 

29 Fort Bend County in terms of taxes generated until the mid 1970’s oil crisis. Due to Houston’s 

30 westward expansion into Fort Bend County the economy has become much more diverse 

31 recently (TSHA 2009f). 

32 In addition to assessing the incremental socioeconomic impacts from the building and 

33 operations of two additional nuclear units on the Allens Creek site, the cumulative impacts 

34 analysis also considers other past, present, and reasonably foreseeable future actions that 

35 could contribute to the cumulative socioeconomic impacts on a given region, including other 

36 Federal and non-Federal projects and those projects listed in Table 9-12. For the analysis of 
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1 socioeconomic impacts at the Allens Creek site, the geographic area of interest is considered to 

2 be the 50-mi region centered on the Allens Creek site. 

3 The projects identified in Table 9-12 have or would contribute to the demographics, economic 

4 climate, and community infrastructure of the region and generally result in increased 

5 urbanization and industrialization. However, many impacts such as those on housing or public 

6 services are able to adjust over time, particularly with increased tax revenues. Furthermore, 

7 state and county plans along with modeled demographic projections include forecasts of future 

8 development and population increases. Because the projects within the review area identified 

9 in Table 9-12 would be consistent with applicable land-use plans and control policies, the review 

10 team considers the cumulative socioeconomic impacts from the projects to be manageable with 

11 the exception of the Trans-Texas Corridor (TTC). Although the review team was not able to 

12 locate information regarding either the timing of the project or the level of employment in the 

13 immediate area of Austin County, it is the teams understanding that during construction there 

14 would be a large construction population working immediately west of the Allens Creek site. 

15 Another branch of the TTC would go through the central part of Fort Bend County (DOT and 

16 TxDOT 2007). The highway itself would take a wide swath of land that would be removed from 

17 predominately agriculture use in both counties but may attract commercial and industrial 

18 development. This is expected to have very significant beneficial consequences for the Austin 

19 County economy and tax base but may create short-term burdens on public services. The 

20 impacts would be similar in Fort Bend County, but smaller in relative impact because of Fort 

21 Bend County’s larger population. It is not known whether the long-term balance of 

22 socioeconomic effects would be beneficial or adverse. The short- and long-term aesthetic 

23 affects would be significant and adverse. 

24 The review team concludes that the cumulative socioeconomic impacts of the building and 

25 operation of a new nuclear plant at the Allens Creek site would be MODERATE and adverse for 

26 Fort Bend County and the region but could be MODERATE to LARGE and adverse in in Austin 

27 County in terms of demographics, transportation, housing, public services, education in Austin 

28 County during the building phase. Physical, aesthetic and recreation impacts would be LARGE 

29 and adverse. The building and operating the new plants at Allens Creek would make a 

30 significant contribution to the aesthetics and recreation impacts. The impacts on the economy 

31 and tax base during plant development and operation likely would be beneficial and 

32 MODERATE to LARGE in Austin County and MODERATE in Fort Bend County. Building and 

33 operating a new plant at the Allens Creek site would make a significant, incremental contribution 

34 to these impact levels in Austin County. 

35 9.3.3.6 Environmental Justice 

36 The following impact analysis includes impacts from building activities and operations. The 

37 analysis also considers other past, present, and reasonably foreseeable future actions that 

38 impact environmental justice, including other Federal and non-Federal projects listed in Table 9-
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March 2010 9-133 Draft NUREG-1937 

1 12. The cumulative environmental justice impacts were assessed for the 50-mi region centered 

2 on the Allens Creek site. In 2000, the 50-mi region around the Allens Creek site was 

3 characterized as 20 percent Black, 0.4 percent American Indian and Alaskan Native, 5.9 

4 percent Asian, 0.05 percent Hawaiian and Other Pacific Islander, 13 percent all other races, and 

5 2.8 percent two or more races, 30.2 percent Hispanic or Latino and 11.6 percent low-income 

6 (STPNOC 2009a). 

7 For this analysis of cumulative environmental justice impacts, the geographic area of interest is 

8 considered to be the 50-mi region surrounding the Allens Creek site and Freeport area in 

9 Brazoria County, which has a minority population and potentially could be affected if the flow 

10 regime at the mouth of the Brazos River were to be changed as a result of withdrawing water 

11 from the river to supply water for the reservoir at the Allens Creek site. The review team 

12 identified 1946 census blocks groups within the 50 mi region, 1065 of which were classified as 

13 minority populations (two of them in Austin County and 99 in Fort Bend County). One of these 

14 block groups in Austin County (near Sealy) and one block group in Waller County are within 

15 10 mi of the Allens Creek alternative site. The review team identified 164 census block groups 

16 classified as low income in the 50-mi region, of which none are in Austin County and one in Fort 

17 Bend County. None of these populations are within 10 mi of the Allens Creek alternative site. 

18 See Figure 9-11 and Figure 9-12 on the following pages for the location of minority or low19 income populations within the 50-mi region. The review team did not locate any minority or low20 income populations that were located along Allens Creek. Nor did the review team find any 

21 minority or low-income populations in the first 50 miles of the Brazos River downstream from the 

22 Allens Creek site or that were engaged in subsistence activity along this river. The review 

23 team’s analysis did not find any information suggesting that minority or low-income populations 

24 in the area were dependent on natural resources that would be adversely affected by a nuclear 

25 power plant at the Allens Creek site. 

26 There are significant minority populations in Austin, Wharton, Ft. Bend and Harris Counties. 

27 However, physical impacts of building (noise, fugitive dust, air emissions, and air and water 

28 emissions) would not disproportionately and adversely affect minority populations because of 

29 their distance from the Allens Creek site (at least 5 mi even for the closest minority populations 

30 in Waller County just east of Austin County and in the vicinity of Sealy, several miles to the north 

31 of the site). The TTC preferred route cuts through Austin County to the immediate west of the 

32 Allens Creek site. Another branch of the TTC passes through the central part of Fort Bend 

33 County on the general alignment passing just south of East Bernard and Beasley, and just north 

34 of Kendleton. The TTC does not appear to pass through minority and low-income census block 

35 groups in Austin County but does appear to do so in Fort Bend County (DOT and TxDOT 2007). 

36 Much of the TTC corridor in Fort Bend County passes directly through many minority census 

37 block groups and because of the preemptive nature of large highways on land use, this branch 

38 of the TTC has a strong chance of disproportionately disrupting neighborhood continuity, 
March 2010 9-134 Draft NUREG-1937 

1 

2 Figure 9-11. Minority Block Groups within 50 mi of the Allens Creek Alternative Site
 Environmental Impacts of Alternatives 

March 2010 9-135 Draft NUREG-1937 

1 

2 Figure 9-12. Low Income Block Groups Near the Allens Creek Alternative Site 
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Draft NUREG-1937 9-136 March 2010

1 displacing existing local services, and interrupting community interactions in minority 

2 communities within the TTC highway corridor. The review team took into account the U.S. 

3 Department of Transportation and TxDOT’s draft EIS for the Tier 1 I-69 Trans-Texas Corridor 

4 Study (DOT and TxDOT 2007). The review team recognizes that a more detailed Tier 2 study 

5 will be taking place in the future, that initial estimations of environmental justice impacts could 

6 change, and that re-routing and other mitigation would be taken to minimize impacts on minority 

7 and low income populations. The impacts of the highway would be significant and potentially 

8 destabilizing to affected individuals and communities, but the corridor is broad enough that 

9 appropriate routing might avoid or mitigate any disproportionate impact to minority and low10 income populations. Depending on the exact routing eventually taken by the TTC highway link 

11 through Fort Bend County within the Tier 1 study corridor, disproportionate adverse impacts 

12 associated with the TTC to the noted minority census block groups in Fort Bend County could 

13 range from minimal to significant and potentially destabilizing. It would noticeably impact the 

14 economy, tax base, and public services of both counties and the impact may be quite significant 

15 in both counties. Because there are minority populations in the Sealy area, they likely would be 

16 adversely affected if crowding in schools and housing occurs in Austin County. However, the 

17 review team does not expect that minority and low-income populations in Austin County would 

18 be disproportionately affected. 

19 The 9500 ac reservoir for Allens Creek does not appear to infringe on lands occupied by 

20 minority populations. There are scattered low income populations in Waller, Ft. Bend, and 

21 Warren Counties beyond 15 mi from the Allens Creek alternative site and a somewhat greater 

22 concentration in western Harris County more than 30 mi away. There are no identified low 

23 income populations in Austin County. Because they are a greater distance from the Allens 

24 Creek alternative site than the minority populations, low-income populations are even less likely 

25 to experience disproportionate, adverse environmental impacts from the Allens Creek 

26 alternative site. 

27 The city of Freeport is at the mouth of the Brazos River, 60 mi downstream from the Allens 

28 Creek Site and has a population that is more than 50 percent Hispanic or Latino. Its proportion 

29 of low-income persons is about 5 percentage points above the Texas state average. However, 

30 any impacts on the Brazos River at Freeport would be short in duration during the building 

31 period and negligible during operations. The building and operation of the proposed project at 

32 the Allens Creek site is unlikely to have any disproportionate adverse impact on any minority or 

33 low-income populations. See Sections 4.5 and 5.5 for more information about environmental 

34 justice criteria and impacts. The environmental justice impacts from building and operating two 

35 nuclear units at the Allens Creek site would be minimal and adverse. 

36 The cumulative environmental justice impacts in the Allens Creek site area would be SMALL to 

37 LARGE and adverse in Fort Bend County and SMALL and adverse elsewhere within the 50-mi 
 Environmental Impacts of Alternatives 

March 2010 9-137 Draft NUREG-1937 

1 region. However, this cumulative rating is based entirely on the impact of the TTC project. 

2 Building and operating two nuclear units at the Allens Creek site would not be a significant 

3 contributor to these impacts. 

4 9.3.3.7 Historic and Cultural Resources 

5 The following cumulative impact analysis includes building and operating two new nuclear 

6 generating units at the Allens Creek site. The analysis also considers other past, present, and 

7 reasonably foreseeable future actions that could impact cultural resources, including other 

8 Federal and non-Federal projects and those projects listed in Table 9-12. For the analysis of 

9 cultural impacts at the Allens Creek site, the geographic area of interest is considered to be the 

10 APE that would be defined for this site. This includes the physical APE, defined as the area 

11 directly affected by the site development and operation activities at the site and transmission 

12 lines, and the visual APE. The visual APE is defined as an additional 1-mi radius around the 

13 physical APE consistent with the discussion in Section 2.7 about the maximum distance from 

14 which the structures can be seen. 

15 Reconnaissance activities in a cultural resource review have particular meaning. Typically, for 

16 example, it includes preliminary field investigations to confirm the presence or absence of 

17 cultural resources. However, in developing its EISs, the review team relies upon 

18 reconnaissance-level information to perform its alternative site evaluation. Reconnaissance19 level information is data that are readily available from agencies and other public sources. It 

20 can also include information obtained through visits to the site area. To identify the historic and 

21 cultural resources at the Allens Creek site, the following information was used: 

22 • STPNOC ER (STPNOC 2009a) - including the Texas Historical Commission’s Texas 

23 Archeological Sites Atlas; 

24 • NRC Alternative Sites Visit March 2008; and 

25 • Final Environmental Statement – Allens Creek Nuclear Generating Station Units 1 and 2 

26 (AEC 1974). 

27 The Allens Creek site is located in Austin County, Texas. The Allens Creek site is a greenfield 

28 site. Historically, the site and vicinity was largely undisturbed and likely contained intact 

29 archaeological sites associated with the past 10,000 years of human settlement. Over time, the 

30 area has been disturbed by rural development and cleared for agricultural purposes. The 

31 majority of the land was cleared of native hardwood vegetation in the 1970’s for agricultural 

32 purposes. Today, much of the site is farmed and current uses include cropland and pasture 

33 land (STPNOC 2009a). 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-138 March 2010

1 Archaeological and/or architectural surveys conducted at the Allens Creek site were discussed 

2 in the 1974 final environmental statement (AEC 1974) for the proposed Allens Creek Nuclear 

3 Generating Station. The 1974 environmental statement identified four cemeteries, historic 

4 areas, and several significant archaeological sites in the Allens Creek area. Additionally, in that 

5 report, the AEC required that the applicant complete an investigation of selected archaeological 

6 sites in the vicinity of the plant and cooling reservoir before the start of construction activities 

7 that could impact the sites. Subsequently, applicant-sponsored investigations indicate that 

8 several mounds with human remains exist in the area. Should the site be developed, then 

9 consultation with the THC and Native American tribes would help determine the significance of 

10 the mounds and any potential impacts the project would have on cultural resources. 

11 Seven historic properties listed on the National Register of Historic Places are found in Austin 

12 County. The closest listed properties to the Allens Creek site are the Church of the Guardian 

13 Angel, located in Wallis about 4 mi from the site and an ossuary located in the vicinity of Wallis. 

14 A Texas Historic Landmark, the Martin Allen Public House foundation and associated Allen15 Johnston cemetery, is about 1 mi from the Allens Creek site (STPNOC 2009a). Neither the 

16 Public House nor the cemetery is listed on the National Register. The project has the potential 

17 to affect resources through visual impacts from buildings and transmission lines. These impacts 

18 may result in significant alterations to the visual landscape within the geographic area of 

19 interest. 

20 In the event that the Allens Creek site was chosen for the proposed project, identification of 

21 cultural resources would be accomplished through cultural resource surveys and consultation 

22 with the SHPO, tribes and interested parties. The results would be used in the site planning 

23 process to avoid cultural resources impacts. Because of the known and significant cultural 

24 resources that exist in the site area, the review team assumes that STPNOC would develop 

25 protective measures in a manner similar to those for the STP site. These procedures are 

26 detailed in STPNOC’s Addendum #5 to Procedure No. OPGP03-ZO-0025 Rev. 12 

27 (Unanticipated Discovery of Cultural Resources) (STPNOC 2008e); the procedure includes 

28 notification of the THC. 

29 Section 9.3.3.1 describes the transmission line corridors. Three new transmission lines would 

30 likely be needed to connect to the three closest 345-kV lines in the area (STPNOC 2009a). In 

31 the event that the Allens Creek site was chosen for the proposed project, the review team 

32 assumes that STPNOC would conduct its transmission line-related cultural resource surveys 

33 and procedures in a manner similar to that for the STP site described in Section 4.6. 

34 Past actions in the geographic area of interest that have similarly impacted historic and cultural 

35 resources include rural development and agricultural development and activities associated with 

36 these land disturbing activities such as road development. Two current or planned projects, the 

37 Texas Independence Trail and the Allens Creek Reservoir, were identified in Table 9-12 that 
 Environmental Impacts of Alternatives 

March 2010 9-139 Draft NUREG-1937 

1 may contribute to cumulative impacts on historic and cultural resources in the geographic area 

2 of interest. 

3 Activities associated with building two nuclear units and supporting facilities that can potentially 

4 destabilize important attributes of historic and cultural resources include land clearing, 

5 excavation, and grading activities. Given STPNOC’s site planning process and known cultural 

6 resources at the Allens Creek site, there would be unavoidable impacts to cultural resources 

7 due to site development activities. 

8 In addition, visual impacts from transmission lines may result in significant alterations to the 

9 visual landscape within the geographic area of interest. Given that there are significant cultural 

10 resources where the historic setting and character of the resources are important, the visual 

11 impacts would be unavoidable. The review team assumes that STPNOC would develop 

12 procedures and consult with the SHPO similar to the process developed for cultural resource 

13 management at the STP site. 

14 Impacts on historic and cultural resources from operation of two new nuclear generating units at 

15 the Allens Creek site include those associated with the operation of new units and maintenance 

16 of transmission lines. The review team assumes that the same procedures currently used by 

17 STPNOC would be used for onsite and offsite maintenance activities. Consequently, the 

18 incremental effects of the maintenance of transmission-line corridors and operation of the two 

19 new units and associated impacts on the cultural resources would be negligible for the physical 

20 APE and detectable but not destabilizing for the visual APE. 

21 The two projects that were identified in Table 9-12 that could contribute to the cumulative 

22 impacts on cultural resources are the Texas Independence Trail and the Allens Creek 

23 Reservoir, a municipal water supply reservoir. The Texas Independent Trail would not 

24 significantly affect historic and cultural resources in the geographic area of interest; the impacts 

25 would be limited to the visual APE and would be similar to those associated with the operation 

26 of two new units. Given the known cultural resources at the Allens Creek site, there would be 

27 significant adverse impacts to cultural resources due to site development activities with regard 

28 to the Allens Creek Reservoir project. 

29 Cultural resources are non-renewable; therefore, the impact of destruction of cultural resources 

30 is cumulative. Based on the information provided by the applicant and the review team’s 

31 independent evaluation, the review team concludes that the cumulative impacts from building 

32 and operating two new nuclear generating units on the Allens Creek site and from other 

33 projects, particularly the planned co-located Allens Creek Reservoir, would be LARGE. The 

34 incremental contribution of building and operating the two new units would be a significant 

35 contributor to the cumulative impacts determination for the cultural resources known to exist 

36 within the geographic area of interest. 
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Draft NUREG-1937 9-140 March 2010

1 9.3.3.8 Air Quality 

2 The following impact analysis includes impacts from building activities and operations. The 

3 analysis also considers other past, present, and reasonably foreseeable future actions that 

4 impact air quality, including other Federal and non-Federal projects listed in Table 9-12. The 

5 atmospheric emissions related to building and operating a nuclear power plant at the STP site in 

6 Matagorda County, Texas, are described in Chapters 4 and 5. The criteria pollutants were 

7 found to have a SMALL impact. In Chapter 7, the cumulative impacts of the criteria pollutants at 

8 the STP site were evaluated and also determined to be MODERATE principally because of a 

9 nearby major source; absent that source, the cumulative impacts would be SMALL. The 

10 geographic area of interest for the Allens Creek site is Austin County, which is in the 

11 Metropolitan Houston-Galveston Intrastate Air Quality Control Region (40 CFR 81.38). The 

12 emissions related to building and operating a nuclear power plant at the Allens Creek site would 

13 be similar to those at the STP site. The air quality attainment status for Austin County as set 

14 forth in 40 CFR 81.344 reflects the effects of past and present emissions from all pollutant 

15 sources in the region. Austin County is not out of attainment of any National Ambient Air Quality 

16 Standard. 

17 Reflecting on the projects listed in Table 9-12, the most significant is the W.A. Parish Electric 

18 Generating Station. Effluents from power plants such as this are typically released through 

19 stacks and with significant vertical velocity. Other industrial projects listed in Table 9-12 would 

20 have de minimis impacts. Given that these projects would be subject to institutional controls, it 

21 is unlikely that the air quality in the region would degrade to the extent that the region is in 

22 nonattainment of National Ambient Air Quality Standards. 

23 The air quality impact of Allens Creek site development would be local and temporary. The 

24 distance from building activities to the site boundary would be sufficient to generally avoid 

25 significant air quality impacts. There are no land uses or projects, including the aforementioned 

26 source, that would have emissions during site development that would, in combination with 

27 emissions from the Allens Creek site, result in degradation of air quality in the region. 

28 Releases from operation of two units at the Allens Creek site would be intermittent and made at 

29 low levels with little or no vertical velocity. The air quality impacts of the aforementioned source 

30 are included in the baseline air quality status. The cumulative impacts from emissions of 

31 effluents from the Allens Creek site and the aforementioned source would not be noticeable. 

32 The cumulative impacts of greenhouse gas emissions related to nuclear power are discussed in 

33 Section 7.5. The impacts of the emissions are not sensitive to location of the source. 

34 Consequently, the discussion in Section 7.5 is applicable to a nuclear power plant located at the 

35 Allens Creek site. The review team concludes that the national and worldwide cumulative 

36 impacts of greenhouse gas emissions are noticeable but not destabilizing. The review team 
 Environmental Impacts of Alternatives 

March 2010 9-141 Draft NUREG-1937 

1 further concludes that the cumulative impacts would be noticeable but not destabilizing, with or 

2 without the greenhouse gas emissions of the project at the Allens Creek site. 

3 Cumulative impacts to air quality resources are estimated based in the information provided by 

4 STPNOC and the review team’s independent evaluation. Other past, present and reasonably 

5 foreseeable future activities exist in the geographic areas of interest (local for criteria pollutants 

6 and global for greenhouse gas emissions) that could affect air quality resources. The 

7 cumulative impacts on criteria pollutants from emissions of effluents from the Allens Creek site, 

8 other projects, and the W.A. Parish Electric Generating Station would not be noticeable. The 

9 national and worldwide cumulative impacts of greenhouse gas emissions are noticeable but not 

10 destabilizing. The review team concludes that the cumulative impacts would be noticeable but 

11 not destabilizing, with or without the greenhouse gas emissions from the Allens Creek site. The 

12 review team concludes that cumulative impacts from other past, present, and reasonably 

13 foreseeable future actions on air quality resources in the geographic areas of interest would be 

14 SMALL for criteria pollutants and MODERATE for greenhouse gas emissions. The incremental 

15 contribution of impacts on air quality resources from building and operating two units at the 

16 Allens Creek site would be insignificant for both criteria pollutants and greenhouse gas 

17 emissions. 

18 9.3.3.9 Nonradiological Health 

19 The following impact analysis includes impacts from building activities and operations. The 

20 analysis also considers other past, present, and reasonably foreseeable future actions that 

21 impact nonradiological health, including other Federal and non-Federal projects listed in 

22 Table 9-12. The building-related activities that have the potential to impact the health of 

23 members of the public and workers include exposure to dust and vehicle exhaust, occupational 

24 injuries, noise, and the transport of construction materials and personnel to and from the site. 

25 The operation-related activities that have the potential to impact the health of members of the 

26 public and workers includes exposure to etiological agents, noise, EMFs, and impacts from the 

27 transport of workers to and from the site. For the analysis of nonradiological health impacts at 

28 the Allens Creek alternative site, the geographic area of interest is considered to include 

29 projects within a 5-mi radius from the site’s center based on the localized nature of the impacts. 

30 For impacts associated with transmission lines, the geographic area of interest is the 

31 transmission line corridor. 

32 Building Impacts 

33 Nonradiological health impacts to construction workers and members of the public from building 

34 two new nuclear units at the Allens Creek site would be similar to those evaluated in Section 4.8 

35 for the STP site. The impacts include noise, vehicle exhaust, dust, occupational injuries, and 

36 transportation accidents, injuries, and fatalities. Applicable Federal and State regulations on air 

37 quality and noise would be complied with during the site preparation and building phase. The 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-142 March 2010

1 incidence of construction worker accidents would not be expected to be different from the 

2 incidence of accidents estimated for STP. The Allens Creek site is located in a rural area and 

3 nonradiological health impacts from building would likely be negligible on the surrounding 

4 populations. The ER (STPNOC 2009a) indicated that transportation impacts could potentially 

5 be significant because the Allens Creek site is located in a rural area. Mitigation would be 

6 warranted, including constructing a new access road, and potentially widening existing 

7 roadways, installing traffic controls, and other measures designed to reduce traffic congestion. 

8 The additional injuries and fatalities from traffic accidents involving transportation of materials 

9 and personnel for building a new nuclear power plant at the Allens Creek site would be similar 

10 to those evaluated in Section 4.8.3 for the STP site and would represent a small fraction (less 

11 than 5 percent) of the total traffic fatalities in Austin County. 

12 There are no past or present actions in the geographic area of interest that would cumulatively 

13 impact nonradiological health in a similar way to those discussed for Allens Creek. Proposed 

14 future actions would include transmission line development and/or upgrading throughout the 

15 designated geographic area of interest, highway improvement projects, and future urbanization. 

16 These actions would likely result in nonradiological health impacts similar to those discussed 

17 above for the building of the Allens Creek site. 

18 Operational Impacts 

19 Nonradiological health impacts from operation of two new nuclear units on occupational health 

20 and members of the public at the Allens Creek site would be similar to those evaluated in 

21 Section 5.8 for the STP site. Occupational health impacts to workers (e.g., falls, electric shock 

22 or exposure to other hazards) at the Allens Creek site would likely be the same as those 

23 evaluated for workers at two new units at the STP site. Exposure to the public from water-borne 

24 etiological agents at the Allens Creek site would be similar to the types of exposures evaluated 

25 in Section 5.8.1, and the operation of the new units at the Allens Creek site would not likely lead 

26 to an increase in water-borne diseases in the vicinity. Noise and EMF exposure would be 

27 monitored and controlled in accordance with applicable OSHA regulations. Effects of EMF on 

28 human health would be controlled and minimized by conformance with NESC criteria and 

29 adherence to the standards for transmission systems regulated by the PUCT. Nonradiological 

30 impacts of traffic associated with the operations workforce would be less than the impacts 

31 during building. Mitigation measures taken during building to improve traffic flow would also 

32 minimize impacts during operation of a new unit. 

33 There are no past or present activities in the geographic areas of interest that would have 

34 nonradiological impacts to the public or workers similar to those discussed for the Allens Creek 

35 site. Proposed future actions that would impact nonradiological health in a similar way to 

36 operation activities at the Allens Creek site would include transmission line systems and future 

37 urbanization, which would both occur throughout the designated geographic areas of interest. 
 Environmental Impacts of Alternatives 

March 2010 9-143 Draft NUREG-1937 

1 The review team is also aware of the potential climate changes that could affect human health; 

2 a recent compilation of the state of the knowledge in this area (Karl et al. 2009) has been 

3 considered in the preparation of this EIS. Projected changes in the climate for the region 

4 include an increase in average temperature and decrease in precipitation, which may alter the 

5 presence of microorganisms and parasites in any reservoir that would be used. The review 

6 team did not identify anything that would alter its conclusion regarding the presence of 

7 etiological agents or change in the incidence of water-borne diseases. 

8 Summary 

9 Based on the information provided by STPNOC and the review team’s independent evaluation, 

10 the review team expects that nonradiological health impacts from building and operating two 

11 new units at the Allens Creek alternative site would be similar to the impacts evaluated for the 

12 STP site. While there are other past, present and future activities in the geographic area of 

13 interest that could affect nonradiological health in ways similar to the building and operation of 

14 two units at the Allens Creek site, those impacts would be localized and managed through 

15 adherence to existing regulatory requirements. The review team concludes, therefore, that the 

16 cumulative impacts would be SMALL. 

17 9.3.3.10 Radiological Impacts of Normal Operations 

18 The following impact analysis includes impacts from building activities and operations for two 

19 nuclear units at the Allens Creek alternative site. The analysis also considers other past, 

20 present, and reasonably foreseeable future actions associated with radiological impacts, 

21 including other Federal and non-Federal projects listed in Table 9-12. As described in Section 

22 9.3.3, Allens Creek is a greenfield site; there are currently no nuclear facilities on the site. The 

23 geographic area of interest is the area within a 50-mi radius of the Allens Creek site. There are 

24 no major facilities that result in regulated exposures to the public or biota within the 50-mi radius 

25 of the Allens Creek site. However, there are likely to be hospitals and industrial facilities within 

26 50 mi of the Allens Creek site that use radioactive materials. 

27 The radiological impacts of building and operating the proposed two ABWR units at the Allens 

28 Creek site include doses from direct radiation and liquid and gaseous radioactive effluents. 

29 These pathways would result in low doses to people and biota offsite that would be well below 

30 regulatory limits. These impacts are expected to be similar to those estimated for the STP site. 

31 The NRC staff concludes that the dose from direct radiation and effluents from hospitals and 

32 industrial facilities that use radioactive material would be an insignificant contribution to the 

33 cumulative impact around the Allens Creek site. This conclusion is based on data from the 

34 radiological environmental monitoring programs conducted around currently operating nuclear 

35 power plants. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-144 March 2010

1 The cumulative radiological impacts from building and operating the two proposed ABWRs and 

2 other existing and planned projects and actions in the geographic area of interest around the 

3 Allens Creek site would be SMALL. 

4 9.3.3.11 Postulated Accidents 

5 The following impact analysis includes radiological impacts from postulated accidents from 

6 operations for two nuclear units at the Allens Creek alternative site. The analysis also considers 

7 other past, present, and reasonably foreseeable future actions that impact radiological health 

8 from postulated accidents, including other Federal and non-Federal projects and those projects 

9 listed in Table 9-12. As described in Section 9.3.3, Allens Creek is a greenfield site; there are 

10 currently no nuclear facilities on the site. The geographic area of interest considers all existing 

11 and proposed nuclear power plants that have the potential to increase the probability-weighted 

12 consequences (i.e., risks) from a severe accident at any location within 50 mi of the Allens 

13 Creek site. This includes the reactors at the STP Site. A site near Victoria has been identified 

14 as a potential reactor location. 

15 As described in Section 5.11.1, the staff concludes that the environmental consequences of 

16 DBAs at the STP site would be minimal for ABWRs. DBAs are addressed specifically to 

17 demonstrate that a reactor design is robust enough to meet NRC safety criteria. The ABWR 

18 design is independent of site conditions, and the meteorology of the Allens Creek and STP sites 

19 are similar; therefore, the NRC staff concludes that the environmental consequences of DBAs at 

20 the Allens Creek site would be minimal. 

21 Because the meteorology, population distribution, and land use for the Allens Creek alternative 

22 site are expected to be similar to the proposed STP site, risks from a severe accident for an 

23 ABWR reactor located at the Allens Creek alternative site are expected to be similar to those 

24 analyzed for the proposed STP site. These risks for the proposed STP site are presented in 

25 Tables 5-18 and 5-19 and are well below the median value for current-generation reactors. In 

26 addition, estimates of average individual early fatality and latent cancer fatality risks are well 

27 below the Commission’s safety goals (51 FR 30028). For the existing plants within the 

28 geographic area of interest, STP Units 1 and 2, the Commission has determined that the 

29 probability-weighted consequences of severe accidents are small (10 CFR 51, Appendix B, 

30 Table B-1). It is expected that risks for any new reactors at the Victoria site would be well below 

31 risks for current-generation reactors and meet the Commission’s safety goals. On this basis, 

32 the NRC staff concludes that the cumulative risks of severe accidents at any location within 

33 50 mi of the Allens Creek alternative site would be SMALL. 

34 9.3.4 Trinity 2 

35 This section covers the review team’s evaluation of the potential environmental impacts of siting 

36 a new two-unit nuclear power plant at the Trinity 2 site in eastern Texas near the Trinity River. 
 Environmental Impacts of Alternatives 

March 2010 9-145 Draft NUREG-1937 

1 The site is located in a rural area of Freestone County approximately 10 mi northeast of Fairfield 

2 and 2.6 mi east of the existing Big Brown Power Plant. The water source for plant cooling and 

3 other plant uses would be the Trinity River and a new reservoir would be constructed. Trinity 2 

4 is a greenfield site not currently owned by the applicant (STPNOC 2009a). 

5 The following sections include a cumulative impact assessment conducted for each major 

6 resource area. The specific resources and components that could be affected by the 

7 incremental effects of the proposed action if implemented at the Trinity 2 site and other actions 

8 in the same geographic area were considered. This assessment includes the impacts of NRC9 authorized construction and operations and impacts of preconstruction activities. Also included 

10 in the assessment are past, present and reasonably foreseeable future Federal, non-Federal, 

11 and private actions that could have meaningful cumulative impacts when considered together 

12 with the proposed action if implemented at the Trinity 2 site. Other actions and projects 

13 considered in this cumulative analysis are described in Table 9-16. 

14 The STP site is more than 200 mi from Trinity 2 and was therefore not included in this analysis. 

15 The only other nuclear power plant currently operating in Texas is Comanche Peak. The 

16 Comanche Peak plant is approximately 100 mi from Trinity 2 and therefore is also not included 

17 in the cumulative analysis. The proposed nuclear power plant in Victoria County is 

18 approximately the same distance as the STP site and was not included in the following analysis. 

19 Table 9-16. Past, Present, and Reasonably Foreseeable Projects and Other Actions 

20 Considered in the Cumulative Analysis of the Trinity 2 Alternative Site. 

Project Name Summary of Project 

Location 

(relative to Trinity 2 

site) Status 

Energy Projects 

Big Brown Power 

Plant (BBPP) 

Two 575 MW units. Burns 

lignite coal from local mines, 

supplemented by subbituminous coal delivered by 

train. Uses water from Lake 

Fairfield. 

Approximately 2.6 mi 

west of Trinity 2 

Operational(a)

Freestone Energy 

Center 

1035 MW natural gas plant on 

506 ac 

Approx 7 mi northwest 

of Trinity 2 

Operational(b)

Lakeside Energy 

Center 

Proposed 640 MW natural gas 

plant 

Approx12 mi northwest 

of Trinity 2 near 

Richland-Chambers 

Reservoir 

Proposed(c)
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-146 March 2010

1 Table 9-16. (contd) 

Project Name Summary of Project 

Location 

(relative to Trinity 2 

site) Status 

Limestone Electric 

Generating Station 

Currently comprised of two 

lignite/coal-fueled steam units, 

with a combined 1700 MW 

capacity. The proposed 

expansion project would add a 

third 744 MW unit. 

Approx 30 mi southsouthwest of Trinity 2 

near Jewett, Texas 

Units 1 and 2 

operational. Unit 3 

expected to begin 

operating in 2012(d)

2 

Mining Projects 

Big Brown Lignite 

Coal Mine and 

Expansion 

Current mining consists of more 

than 20,000 ac of land mined in 

Freestone County. The owner 

of the Big Brown Mine, 

Luminant, plans to open the 

Turlington mine (10,397 ac) 

adjacent to and south of the 

existing Big Brown Mine. 

Approx 4 mi northwest 

of Trinity 2 

Operational. (e)

Turlington mine 

expected to begin 

operating in 2011(f)

Streetman Expanded 

Shale and Clay Plant 

Lightweight aggregate 

production facility 

Approx 21 mi west of 

Trinity 2 

Operational.(g)

Transportation Projects 

Highway expansion Widening of US 79 About 18 mi southeast 

of Trinity 2 

Proposed but 

currently 

unfunded(h)

Highway expansion Widening of US 287 About 10 mi northeast 

of Trinity 2 

Proposed but 

currently 

unfunded(i)

Parks and Aquaculture Facilities 

Fairfield Lake State 

Park 

1460 ac outdoor recreation Approx 4 mi southwest 

of Trinity 2 

Operational(j)

Richland Creek 

Wildlife Management 

Area 

13,700 ac, created to 

compensate for habitat losses 

associated with the construction 

of Richland-Chambers 

Reservoir 

Approx 10 mi north of 

Trinity 2 

Operational(k)

Big Lake Bottom 

Wildlife Management 

Area 

2870 ac of the area are 

accessible and open for public 

use 

Approx 11 mi eastsoutheast of Trinity 2 Development likely 

limited within this 

park(l)
 Environmental Impacts of Alternatives 

March 2010 9-147 Draft NUREG-1937 

1 Table 9-16. (contd) 

Project Name Summary of Project 

Location 

(relative to Trinity 2 

site) Status 

Gus Engeling Wildlife 

Management Area 

10,958 ac for wildlife 

management, research, and 

demonstration area for the Post 

Oak Savannah Ecoregion. Also 

used for hunting & other outdoor 

recreation. 

Approx16 mi northeast 

of Trinity 2 

Development likely 

limited within this 

park(m)

Other Actions/Projects: 

Tehuacana Reservoir 14,900-ac water supply 

reservoir 

Approx 10 mi westnorthwest of Trinity 2 Proposed (n)

Tennessee Colony 

Reservoir 

85,000-ac water supply and 

flood control reservoir 

Adjacent to Trinity 2 Proposed (o)

Coffield Correctional 

Institution 

Prison in operation since 1965, 

wastewater treatment plant 

Approx 8 mi eastsoutheast of Trinity 2 Operational(p)

Boyd Correctional 

Institution 

Prison in operation since 1992, 

wastewater treatment plant 

Approx. 15 mi westsouthwest of Trinity 2 Operational(q)

Nucor Steel Primary Metal Industries Approx 34 mi southsouthwest of Trinity 2 Operational(r)

Cayuga Independent 

School District 

Waste Water Treatment Plant Approx 9 mi northeast 

of Trinity 2 

Operational(s)

Future Urbanization Construction of housing units 

and associated commercial 

buildings; roads, bridges, and 

rail; construction of waterand/or wastewater- treatment 

and distribution facilities and 

associated pipelines, as 

described in local land-use 

planning documents. 

Throughout region. Construction would 

occur in the future, 

as described in 

state and local 

land-use planning 

documents 

Various hospitals and 

industrial facilities 

that use radioactive 

materials 

Medical and other isotopes Within 50 mi Operational in 

nearby cities and 

towns 

(a) Source: EPA 2009c 

(b) Source: Calpine 2009 

(c) Source: TCEQ 2009d 

(d) Source: NRG 2009 

(e) Source: EPA 2009d 

(f) Source: TRC 2010 

(g) Source: EPA 2009e 

(h) Source: TxDOT 2009a 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-148 March 2010

Table 9-16. (contd) 

(i) Source: TxDOT 2009a 

(j) Source: TPWD 2009j 

(k) Source: TPWD 2009k 

(l) Source: TPWD 2009l 

(m) Source: TPWD 2009m 

(n) Source: TWDB 2010a 

(o) Source: TWDB 2006b 

(p) Source: EPA 2009f 

(q) Source: TDCJ 2009 

(r) Source: EPA 2009g 

(s) Source: EPA 2009h 

1 9.3.4.1 Land Use 

2 The following impact analysis includes impacts from building activities and operations. The 

3 analysis also considers past, present, and reasonably foreseeable future actions that impact 

4 land use, including other Federal and non-Federal projects and those projects listed in 

5 Table 9-16. For this analysis, the geographic area of interest for considering cumulative 

6 impacts is the 15-mi region surrounding the Trinity 2 site. This geographic area of interest 

7 includes the primary communities (e.g., Fairfield) that would be affected by the proposed project 

8 The Trinity 2 site is a greenfield site located in an unincorporated area of Freestone County, 

9 Texas, 10.4 mi northeast of Fairfield. STPNOC estimates that approximately 18 percent of the 

10 Trinity 2 site is forested, 80 percent is in open land or grass lands, 1 percent is developed, and 1 

11 percent is water resources (STPNOC 2009a). There is no current zoning applicable to the site. 

12 The Trinity 2 site is not owned by the applicants. Acquisition of the site for a new power plant 

13 would involve land purchase from more than one land owner (STPNOC 2009a). 

14 The Trinity 2 site is not in the geographic area covered by the TCMP (TCMP 2009); therefore, 

15 the CZMA does not apply to this site. 

16 The Trinity 2 site is 2.6 mi east of the Big Brown Power Plant owned by Luminant Power 

17 (STPNOC 2009a). The Big Brown plant is a two-unit, 1150-MW, coal-fired plant (Luminant 

18 2009). The plant uses lignite coal mined near the plant (see Table 9-16) and also coal from the 

19 Powder River Basin in Wyoming. Continued mining operations would be expected to increase 

20 the amount of affected land near the Trinity 2 site. Cooling water for the Luminant plant comes 

21 from Fairfield Lake. Fairfield Lake has a surface area of approximately 2400 ac and was formed 

22 by a dam on Big Brown Creek (TSHA 2009b). Fairfield Lake State Park is located on the 

23 southern and southwestern shores of Fairfield Lake. 

24 If new nuclear generating units were built at the Trinity 2 site, the review team assumes that an 

25 onsite water storage reservoir for plant cooling would be built and that water would be diverted 

26 from the Trinity River. The land area affected by building two nuclear generating units at the 
 Environmental Impacts of Alternatives 

March 2010 9-149 Draft NUREG-1937 

1 Trinity 2 site would be approximately 800 ac for the main power plant site and up to 1700 ac for 

2 a new reservoir to be used for plant cooling (STPNOC 2009a). Land-use impacts would also 

3 occur to divert water to the plant and/or a reservoir and return discharge water to the Trinity 

4 River and for road and rail access. Most land-use impacts would occur during building, while 

5 plant operations would have minimal land-use impacts. The land-use impacts associated with 

6 building the plant and the reservoir at the Trinity 2 site would be noticeable, but not 

7 destabilizing. 

8 Figure 9-13 shows the location of the Trinity 2 site and surrounding communities. There are no 

9 existing transmission corridors connecting directly to the Trinity 2 site. However, there are 

10 multiple 345-kV transmission lines connecting to the Big Brown Power Plant (STPNOC 2009a). 

11 One or more new transmission corridors would need to be created to connect the Trinity 2 site 

12 to these lines. The corridor(s) would pass through areas that are mostly rural with low 

13 population densities. Farmlands that would become part of a corridor could generally continue 

14 to be farmed. The land-use impacts of building one or more transmission corridors to serve the 

15 Trinity 2 site would be minimal. 

16 Within the 15-mi geographic area of interest, four reasonably foreseeable future projects 

17 (included in Table 9-16) have the potential to significantly affect cumulative land use. The first 

18 project would be the proposed Lakeside Energy Center. The Lakeside Energy Center would be 

19 a 640 MW(e) natural gas-fired power plant located on a 35 ac tract of land approximately 12 mi 

20 northwest of the Trinity 2 site. Construction and operations workers would likely be drawn from a 

21 wide area. If the proposed Lakeside Energy Center is constructed, one or more new 

22 transmission corridors would be needed to connect the plant to the grid. The second project 

23 would be the proposed Tehuacana Reservoir which would affect approximately 14,900 ac. The 

24 third project would be the proposed Tennessee Colony Reservoir which would impact 

25 approximately 85,000 ac adjacent to the Trinity 2 site. The fourth project would be the opening 

26 of the Turlington Mine to support the Big Brown Power Plant. The planned mine would affect 

27 approximately 10,400 ac. 

28 Future urbanization in the geographic area of interest, the continued operation of the Big Brown 

29 coal mine, the four proposed projects (see Table 9-16), and GCC could contribute to decreases 

30 in open lands, wetlands, and forested areas. Urbanization in the vicinity of the Trinity 2 site 

31 would alter important attributes of land use. Urbanization would reduce natural vegetation and 

32 open space, resulting in an overall decline in the extent and connectivity of wetlands, forests, 

33 and wildlife habitat. Continued operation of the Big Brown coal mine could include expansion of 

34 the mine at some point in the future. Potential expansion of the mine would result in a loss of 

35 open lands, forests, and wetlands. Construction of the four proposed projects (Lakeside Energy 

36 Center and associated transmission lines, the Tehuacana and Tennessee Colony reservoirs, 

37 and the Turlington Mine) would all also contribute to loss of open lands, forests, and wetlands. 

38 GCC could decrease precipitation, causing more frequent droughts when combined with 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-150 March 2010

1 

2 Figure 9-13. Trinity 2 Alternative Site and 10-mi Radius
 Environmental Impacts of Alternatives 

March 2010 9-151 Draft NUREG-1937 

1 increased evaporation in the geographic area of interest for the Trinity 2 site (Karl et al. 2009). 

2 Reduced water supply and increased temperatures could reduce crop yields and livestock 

3 productivity (Karl et al. 2009), which might change portions of agricultural and ranching land 

4 uses in the area of interest. However, existing parks, reserves, and managed areas would help 

5 preserve open lands, wetlands, and forested areas to the extent that they are not adversely 

6 affected by droughts. The proposed two reservoirs (Tehuacana and Tennessee Colony) may 

7 help ameliorate some adverse effects of droughts if the reservoirs are in operation soon 

8 enough. But these reservoirs would simultaneously cause land-use changes by inundating 

9 large tracts of land. Urbanization trends, ongoing and proposed projects, and changes resulting 

10 from potential GCC could cause a shift in land use and, therefore, noticeably alter land uses in 

11 the geographic area of interest. 

12 Based on the information provided by STPNOC and the review team’s independent review, the 

13 review team concludes that the cumulative land-use impacts of constructing and operating two 

14 new nuclear generating units at the Trinity 2 site would be MODERATE. This conclusion 

15 reflects the substantial amount of land (up to 2500 ac onsite and additional offsite land for 

16 roads, a railroad spur, and pipelines) that would be needed for the proposed project if it were 

17 located at the Trinity 2 site, and the land-use impacts associated with the (1) proposed Lakeside 

18 Energy Center, (2) Tehuacana and Tennessee Colony Reservoirs, (3) Turlington Mine, and (4) 

19 transmission corridors that would be needed to serve the Trinity 2 and Lakeside Energy Center 

20 sites. Increased urbanization and potential effects of GCC could also noticeably contribute to 

21 this impact determination. Building and operating two new nuclear units at the Trinity 2 site 

22 would be a significant contributor to the MODERATE impact. 

23 9.3.4.2 Water Use and Quality 

24 The following impact analysis includes impacts from building activities and operations. The 

25 analysis also considers other past, present, and reasonably foreseeable future actions that 

26 impact water use and quality, including other Federal and non-Federal projects listed in 

27 Table 9-16. The Trinity 2 site is located in rural Freestone County in eastern Texas. Onsite 

28 drainages include Tehuacana Creek, Big Brown Creek, and Rock Springs Branch (see Fig 9-13) 

29 which all ultimately drain to the Trinity River. Development of this site for two nuclear units 

30 would require water from the Trinity River, and the building of a water storage reservoir on the 

31 Trinity 2 site. 

32 Geographic areas of interest are (1) for surface water the drainage basin of the Trinity River 

33 upstream and downstream of the intake and outfall structures, and the drainage basin of 

34 Tehuacana Creek upstream and downstream of the facility, and (2) for groundwater the aquifers 

35 upgradient and downgradient of the site. These regions are of interest because they represent 

36 the water resource potentially affected by siting the proposed project at the Trinity 2 site. 
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Draft NUREG-1937 9-152 March 2010

1 As stated in Section 2.3.2, water use in Texas is regulated by the Texas Water Code. As 

2 established by Texas Water Code, surface water belongs to the State of Texas (Texas Water 

3 Code, Chapter 11, Section 11.021). The right to use surface waters of the State of Texas can 

4 be acquired in accordance with the provisions of the Texas Water Code, Chapter 11. In Texas, 

5 surface water is a commodity. Since the Trinity River Basin is currently heavily appropriated, 

6 future water users in this basin would likely only obtain surface water by purchasing or leasing 

7 existing appropriations. Regarding groundwater, Texas law has allowed landowners to pump 

8 the water beneath their property without consideration of impacts to adjacent property owners 

9 (NRC 2009b). However, Chapter 36 of Texas Water Code authorized groundwater 

10 conservation districts to help conserve groundwater supplies and issue groundwater use 

11 permits. Chapter 36, Section 36.002, Ownership of Groundwater, states that ownership rights 

12 are recognized and that nothing in the code shall deprive or divest the landowners of their 

13 groundwater ownership rights, except as those rights may be limited or altered by rules 

14 promulgated by a district. Thus, groundwater conservation districts with their local constituency 

15 offer groundwater management options (NRC 2009b). Existing projects in the State have 

16 appropriations to use water for their requirements. The review team expects that future 

17 projects, including the proposed units, if they were to be built and operated at the Trinity 2 site, 

18 would operate within the limits of these existing surface water and groundwater appropriations. 

19 As stated in Section 7.2.1, the GCRP has compiled the state of knowledge in climate change. 

20 This compilation has been considered in the preparation of this EIS. The projections for 

21 changes in temperature, precipitation, droughts, and increasing reliance on aquifers within the 

22 Trinity River Basin are similar to those in the Colorado River Basin (Karl et al. 2009). Such 

23 changes in climate would result in adaptations to both surface water and groundwater 

24 management practices and policies that are unknown at this time. 

25 There are currently 475 water rights owners in the Trinity River Basin, with total water rights of 

26 1,169,000 ac-ft/yr that are categorized as industrial, irrigation, or mining users (TCEQ 2009a). 

27 According to the TCEQ’s water availability maps, unappropriated flows in the Trinity River Basin 

28 for a perpetual water rights permit are available 25 to 50 percent of the time (TCEQ 2009b). 

29 The water availability maps do not show the quantity of available water for a new appropriation 

30 (TCEQ 2009b). The segment of the Trinity River near the Trinity 2 site appears on the State’s 

31 303(d) list as an impaired waterbody (TCEQ 2010b). 

32 The Texas Water Development Board, in the 2007 State Water Plan, has estimated that more 

33 than 1 million ac-ft of groundwater supplies would be available during 2010-2060 in the Carrizo34 Wilcox Aquifer that is shared by 66 counties (TWDB 2006a). The Mid-East Texas Groundwater 

35 Conservation District (METGCD) in which Trinity 2 resides, has estimated an average historical 

36 use of approximately 2784 ac-ft per year within Freestone County during 1980-2003 (METGCD 

37 2009). The TWDB reported that wells in the Carrizo-Wilcox Aquifer support pumping rates from 

38 500 to 3000 gpm. 
 Environmental Impacts of Alternatives 

March 2010 9-153 Draft NUREG-1937 

1 Building Impacts

2 The review team assumed that no surface water would be used to build the units at the Trinity 2 

3 site so there would be no impact on surface water use. This assumption is consistent with the 

4 analysis done for the STP site and other alternative sites. 

5 The impacts on surface water quality from building potential units at the Trinity 2 alternative site 

6 would be limited to stormwater runoff that may enter nearby streams and rivers. Additionally, 

7 treated sanitary wastewater may be discharged to these streams and rivers. Building impacts 

8 would be limited by the duration of these activities, and therefore, would be temporary. The 

9 State of Texas prohibits the unauthorized discharge of waste into or adjacent to water in the 

10 state (Texas Water Code, Chapter 26, Section 26.121). The discharge of waste may be 

11 authorized under a general or individual permit (Texas Water Code, Chapter 26). These 

12 permits may require an SWPPP that includes BMPs appropriate for the site (TCEQ 2003; 

13 STPNOC 2009a). Implementation of BMPs should minimize impacts to wetlands and surface14 water bodies near the Trinity 2 alternative site. Therefore, the water quality impacts on wetlands 

15 and water bodies related to building the proposed units near the Trinity 2 alternative site would 

16 be temporary and minimal. 

17 The review team assumes that the groundwater use for building activities at the Trinity 2 site 

18 would be identical to the proposed groundwater use for the STP site (STPNOC 2009b). 

19 Monthly normalized groundwater use for the STP site ranges up to 491 gpm (792 ac-ft/yr) (see 

20 Table 3-4). STPNOC stated that groundwater would be used for potable and sanitary use, 

21 concrete batch plant operation, concrete curing, dust suppression and cleaning, placement of 

22 engineered backfill, and piping hydrotests and flushing (STPNOC 2009a). 

23 The review team concludes that the potential groundwater use at the Trinity 2 alternative site 

24 during building activities would not be unreasonable because the site would utilize units similar 

25 to those proposed for the STP site and the building activities would also be similar. 

26 The Trinity 2 alternative site is located in Region C, GMA 12, and the METGCD. As of January 

27 2010, GMA 12 has not adopted desired future conditions for the Carrizo-Wilcox Aquifer (TWDB 

28 2010b) which is the source of groundwater that would be used by STPNOC. The Carrizo29 Wilcox Aquifer outcrops in much of Freestone County and therefore receives recharge in the 

30 area. Based on the available information, the review team determined that the groundwater that 

31 would be used for building the proposed units at the Trinity 2 alternative site would be 

32 approximately 28 percent of the average historical groundwater use from the Carrizo-Wilcox 

33 Aquifer in Freestone County. While 28 percent appears substantial, it represents 28 percent of 

34 prior average annual groundwater use and not of the managed available groundwater resource 

35 in the vicinity of the Trinity 2 site. The managed available groundwater resource level will be 

36 determined at a future time by the METGCD in cooperation with the TWDB (METGCD 2009). 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-154 March 2010

1 The METGCD has proposed to develop the Carrizo-Wilcox Aquifer to meet demands within the 

2 Freestone County during 2010-2060 (METGCD 2009). 

3 The review team determined, based on available information and groundwater source options 

4 that it is possible that there is sufficient groundwater available in the Carrizo-Wilcox aquifer to 

5 provide the groundwater needed to build the potential plants at the Trinity 2 alternative site. For 

6 example, the METGCD is developing an estimate of the managed available groundwater in the 

7 district and may find sufficient groundwater resource to allow expanded use of the aquifer. 

8 Based on standard geohydrologic practice, the review team concludes that the drawdown in the 

9 Carrizo-Wilcox Aquifer could be managed for groundwater pumping during building activities 

10 using an appropriately designed well system. Accordingly, the review team concludes that the 

11 impact of groundwater use for building the potential plants at the Trinity 2 site could be minimal. 

12 However, if a new groundwater use permit is issued, and the managed available groundwater 

13 resource is not sufficient, then the impact would be noticeable but not destabilizing because 

14 pumping from the aquifer would be temporary and limited to the building period. 

15 While building the potential plants at the Trinity 2 alternative site, impacts to groundwater quality 

16 may occur from leaching of spilled effluents into the subsurface. Within Freestone County, wells 

17 completed within the Carrizo-Wilcox Aquifer yield groundwater with TDS levels of less than 500 

18 mg/L (TWDB 2006a). STPNOC stated that BMPs would be in place during building activities 

19 and therefore the review team concludes that any spills would be quickly detected and 

20 remediated. In addition groundwater impacts would be limited to the duration of these activities, 

21 and therefore, would be temporary. Because any spills related to building activities would be 

22 quickly remediated under BMPs, and the activities would be temporary, the review team 

23 concludes that the groundwater-quality impacts from building at the Trinity 2 site would be 

24 minimal. 

25 Operational Impacts

26 STPNOC estimated that a two-unit plant, operated at the Trinity 2 alternative site using a 

27 closed-cycle cooling system that would employ a cooling water reservoir, would consume a 

28 maximum of 50,000 ac-ft of water per year. STPNOC has identified the Trinity River as the 

29 source of the cooling water at the Trinity 2 alternative site. STPNOC currently does not own the 

30 necessary water rights. STPNOC would need to acquire existing Trinity River water rights that 

31 are currently being used for industrial, irrigation, and mining use. Therefore, based on the 

32 1,169,000 ac-ft/yr of water rights held on the Trinity River by 475 water right owners, STPNOC 

33 would need to acquire a minimum of 4.3 percent of these water rights. 

34 According to TCEQ staff, acquired water rights would have to be aggregated at a single point of 

35 diversion which may lead to concerns regarding instream flow to maintain water quality and 

36 habitat (NRC 2009b). The TCEQ staff stated that, under current Texas laws, the acquisition 

37 and aggregation process would need to consider the quantity and location of all water rights and 
 Environmental Impacts of Alternatives 

March 2010 9-155 Draft NUREG-1937 

1 the instream flow needs that may be affected by transfer of these water rights. Because 

2 STPNOC has not identified the particular water rights that may be acquired, it is difficult to 

3 determine if any are suitable for acquisition. However, the review team concluded that the 

4 TCEQ permitting process would require STPNOC to acquire water rights in sufficient quantity, at 

5 appropriate locations, and of appropriate type within the Trinity River Basin such that this 

6 reallocation of water rights does not adversely affect surface water use and quality in the basin. 

7 As such, based upon the water rights that would need to be reallocated to accommodate the 

8 facility at the Trinity 2 site, the review team determined that the operational surface water use 

9 impact of the proposed units at the Trinity 2 alternative site would be noticeable but not 

10 destabilizing. 

11 During the operation of the proposed plants at the Trinity 2 alternative site, impacts to surface 

12 water quality could result from stormwater runoff, discharges of treated sanitary and other 

13 wastewater, blowdown from service water cooling towers, and periodic discharges from the 

14 cooling water reservoir into the Trinity River. As mentioned above, the State of Texas may 

15 require STPNOC to obtain a general or individual permit for the discharge of stormwater (Texas 

16 Water Code, Chapter 26). These permits may require an SWPPP that includes BMPs 

17 appropriate for the site (TCEQ 2001; STPNOC 2009a). Any discharges of sanitary and other 

18 wastewaters or cooling water reservoir discharges would be controlled by the State of Texas 

19 under a TPDES permit. The State of Texas limits the quantity and quality of discharges to 

20 surface water bodies while accounting for concurrent discharge and quality conditions within the 

21 surface water body. These permit conditions would also account for designated uses of the 

22 receiving surface water body and comply with the Clean Water Act. Such permits are designed 

23 to protect water quality. The review team expects that the conditions placed on operations of 

24 the proposed plants at the Trinity 2 site would be similar to those currently placed on the 

25 existing facilities at the STP site (Section 5.2.3.1). Therefore, the review team concluded that 

26 the operational impact on surface water quality of the receiving water body would be minimal 

27 because the discharge quantity and quality would be controlled. 

28 The proposed Units 3 and 4 would use approximately 975 gpm (1572 ac-ft/yr) of groundwater 

29 during normal operations and approximately 3434 gpm (5538 ac-ft/yr) during maximum demand 

30 conditions (STPNOC 2009c). STPNOC stated that the expected groundwater use for Units 3 

31 and 4 are assumed to also apply to alternative sites. However, for maximum operation demand 

32 periods, STPNOC assumes that a temporary increase in the rate of surface water use would be 

33 available (STPNOC 2009b). 

34 The review team concludes that the potential groundwater use at the Trinity 2 alternative site 

35 during operations would not be unreasonable because the alternative site would utilize units 

36 similar to those proposed for the STP site. 

37 As stated above, the desired future conditions for the Carrizo-Wilcox Aquifer have not yet been 

38 adopted (TWDB 2010b) and the managed available groundwater resource has not yet been 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-156 March 2010

1 determined. However, the Texas Water Development Board, in the 2007 State Water Plan, has 

2 estimated that more than 1 million ac-ft/yr of groundwater supplies would be available during 

3 2010-2060 in the Carrizo-Wilcox Aquifer that is shared by 66 counties (TWDB 2006a). The 

4 TWDB also reported that wells in the Carrizo-Wilcox Aquifer support pumping rates from 500 to 

5 3000 gpm. The METGCD has determined that average historical use of groundwater in 

6 Freestone County between 1984 and 2003 has been approximately 2784 ac-ft per year. The 

7 normal operation groundwater use of 975 gpm (1572 ac-ft/yr) represents 56 percent of the 

8 county’s historical usage. 

9 STPNOC stated that access to groundwater production from existing wells would be sought 

10 before requesting new or future groundwater capacity, and that water could be imported 

11 primarily for potable water use and thereby reduce groundwater demand (STPNOC 2009b). 

12 Thus, less new groundwater may be needed for operations at the Trinity 2 site. However, it is 

13 possible that plants operating at the Trinity 2 site would use a large fraction of the available 

14 groundwater resource for operations. Based on standard hydrogeologic practice, the review 

15 team determined that the amount of drawdown in the Carrizo-Wilcox Aquifer from groundwater 

16 pumping during operation could be limited by installing multiple, appropriately-spaced wells 

17 because groundwater could be withdrawn from a large area resulting in smaller drawdown. 

18 Because of the level of groundwater resource use and the potential for drawdown to occur over 

19 the operational period of the facility, the review team concludes that the impact of operational 

20 groundwater use at the Trinity 2 site would be noticeable. However, based on available 

21 information on the aquifer, and the authority of groundwater conservation districts to manage 

22 and permit groundwater resources (Texas Water Code, Chapter 36), the review team expects 

23 that the impact to the groundwater resource under a groundwater use permit issued by the 

24 applicable groundwater conservation district would not destabilize the groundwater resource. 

25 During the operation of a potential plant at the Trinity 2 alternative site, impacts to groundwater 

26 quality could result from potential spills. Spills that might affect the quality of groundwater would 

27 be prevented and mitigated by BMPs. During operation of the potential plants at the Trinity 2 

28 alternative site, some drawdown of the Carrizo-Wilcox Aquifer would be expected; however, the 

29 aquifer yields fresh groundwater with TDS levels of less than 500 mg/L (TWDB 2003). Because 

30 BMPs would be used to mitigate spills and no intentional discharge to groundwater should 

31 occur, the review team concludes that the groundwater-quality impacts from operation of two 

32 nuclear units at the Trinity 2 site would be minimal. 

33 Cumulative Impacts

34 In addition to water use and water quality impacts from building and operations activities, 

35 cumulative analysis considers past, present, and reasonably foreseeable future actions that 

36 impact the same environmental resources. For the cumulative analysis of impacts on surface 

37 water, the geographic area of interest for the Trinity 2 site is considered to be the drainage basin 

38 of the Trinity River upstream and downstream of intake and discharge structures, and the 
 Environmental Impacts of Alternatives 

March 2010 9-157 Draft NUREG-1937 

1 drainage basin of Tehuacana Creek upstream and downstream of the Trinity 2 site because this 

2 is the resource that would be affected by the Trinity 2 project. For groundwater, the geographic 

3 areas of interest for cumulative analysis of the Trinity 2 site are aquifers underlying the site 

4 upgradient and downgradient of the site. 

5 Water supply in the Trinity River Basin could change with implementation of potential water 

6 management strategies (e.g., Lake Tehuacana and Tennessee Colony Lake; Table 9-16). Key 

7 actions that have past, present and future potential impacts to water supply and water quality in 

8 the Trinity River basin include the existing Big Brown Power Plant, Freestone Energy Center, 

9 and Big Brown Lignite Coal Mine and Expansion (Table 9-16). Key actions that would have 

10 future potential impacts to water supply and water quality include the planned Lakeside Energy 

11 Center, Limestone 3 Coal Plant Expansion Project (Table 9-16), and the cooling water reservoir 

12 and/or water storage reservoir required for operation of the Trinity 2 site. The Lakeside Energy 

13 Center would use a new 640-MW gas-fired unit that may use water for cooling purposes. Unit 3 

14 at the Limestone site would generate 744 MW and would use dry cooling, which would 

15 substantially reduce water consumption. 

16 Cumulative Water Use

17 The only surface-water-use impacts of building and operating a nuclear power plant at this site 

18 are the water demands occurring during operation. The projected consumptive surface water 

19 use of the two potential units at the Trinity 2 site is expected to be about 50,000 ac-ft/yr or 4.3 

20 percent of the total basin water rights (i.e., 1,169,000 ac-ft/yr), held by 475 water right owners in 

21 the Trinity River Basin. Future potential water use by other actions in the Trinity River Basin 

22 (e.g., Lakeside Energy Center and Limestone 3 Coal Plant Expansion Project) would also 

23 increase consumptive demand. Because the total rated power output of these power plants is 

24 smaller than that of the two proposed units, the review team concludes that the potential water 

25 use of these projects would likely be smaller than that for the two proposed nuclear units if they 

26 were to be operated at the Trinity 2 site; therefore the combined future water use would likely 

27 still be a relatively small fraction of the current water rights in the basin. Therefore, the review 

28 team concludes that the impact of these projects on the region’s surface water use would be 

29 noticeable but not destabilizing. 

30 Increases in consumptive use of water in the Trinity River drainage is anticipated in the future, 

31 however, the impacts of the other projects listed in Table 9-16 would have little or no impact on 

32 surface water use. 

33 The review team is also aware of the potential for GCC affecting the water resources available 

34 for closed-cycle cooling and the impact of reactor operations on water resources for other users. 

35 The impact of GCC on regional water resources is not precisely known, however it may result in 

36 decreases in precipitation and increases in average temperature (Karl et al. 2009). Such 
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Draft NUREG-1937 9-158 March 2010

1 changes could further stress regional water resources. However, the impacts related to GCC 

2 would be similar for all the alternative sites 

3 Historically, the waters of the Trinity River Basin have been used extensively. The region has a 

4 planning, allocation, and development system in place to manage its limited surface water 

5 supplies. These efforts are described in the Regional and State Water Plans (Region C 

6 Regional Water Planning Group (RCRWPG) (TWDB 2006a, 2006b). As stated above, 

7 operation of the proposed units on the Trinity 2 site would result in a noticeable but not 

8 destabilizing impact to the surface water use in the region. Future projects in the region would 

9 also result in noticeable but not destabilizing impacts on surface water use in the region. 

10 Therefore, the review team concludes that cumulative impacts to surface water use would be 

11 MODERATE. Building and operating the proposed plant at the Trinity 2 site would be a 

12 significant contributor to these water-use impacts. 

13 Groundwater-use impacts at this site are characterized by the groundwater demand at the STP 

14 site, and those use levels are 491 gpm (792 ac-ft/yr) during building, a normal operation 

15 demand of 975 gpm (1572 ac-ft/yr), and a maximum operation demand of 3434 gpm (5538 ac16 ft/yr) (STPNOC 2009c). However, for maximum operation demand periods, STPNOC assumes 

17 that a temporary increase in the rate of surface water use would be available (STPNOC 2009b). 

18 During building and normal operation, the possibilities exist that STPNOC could (1) use a new 

19 groundwater permit and associated wells in the Carrizo-Wilcox aquifer, (2) acquire existing 

20 groundwater production from wells in the vicinity of the plant, and (3) use of imported water 

21 primarily for potable use onsite to reduce groundwater-use requirements (STPNOC 2009b). 

22 With regard to the groundwater resource used by all other past and present projects, the 

23 average use of the Carrizo-Wilcox aquifer in Freestone County is approximately 2784 ac-ft/yr. 

24 Normal operation demand for the proposed units, if they were placed at the Trinity 2 site, would 

25 represent a 56 percent increase in groundwater use within the Carrizo-Wilcox aquifer in 

26 Freestone County. The review team concludes this is a significant increase in use of the 

27 groundwater resource for future projects. 

28 As indicated above, groundwater would be used during the building and operation of two 

29 nuclear units at the Trinity 2 site. Because of the alternatives available to supply groundwater, 

30 (i.e., new, acquired, imported), it is possible that new groundwater demand would be reduced. 

31 However, the METGCD is now working with the TWDB to establish the managed available 

32 groundwater quantity for the Carrizo-Wilcox aquifer. Accordingly, the review team concludes 

33 that based on available information on the aquifer, and the authority of groundwater 

34 conservation districts to manage and permit groundwater resources (Texas Water Code, 

35 Chapter 36), the impact to the groundwater resource under a groundwater use permit issued by 

36 the applicable groundwater conservation district would not destabilize the groundwater 

37 resource. Therefore, the review team concludes that cumulative impacts to groundwater use 

38 would be MODERATE. Building and operating the proposed units at the Trinity 2 site would be 

39 a significant contributor to this groundwater-use impact because the implied use of groundwater 
 Environmental Impacts of Alternatives 

March 2010 9-159 Draft NUREG-1937 

1 would exceed the current estimate of historical groundwater use from the Carrizo-Wilcox Aquifer 

2 in Freestone County by approximately 28 percent for building and 56 percent for operating the 

3 proposed units. The impacts of other projects listed in Table 9-16 would have little or no impact 

4 on groundwater use. 

5 Cumulative Water Quality

6 Point and nonpoint sources in the river basin have affected the water quality of the Trinity River. 

7 The segment of the Trinity River to which the proposed units, if they were to be operated at the 

8 Trinity 2 site, would discharge effluent, appears on the State’s 303(d) list as an impaired 

9 waterbody (TCEQ 2010b). Water quality information presented above for the impacts of 

10 building and operating the new units at the Trinity 2 site would also apply to evaluation of 

11 cumulative impacts. The State of Texas may require an applicant to obtain a general or 

12 individual permit for discharge of stormwater (Texas Water Code, Chapter 26). These permits 

13 may require an SWPPP that includes BMPs appropriate for the site (TCEQ 2001, 2003; 

14 STPNOC 2009a). The State of Texas would also issue TPDES permits for the discharge of 

15 sanitary and other wastewaters including blowdown from service water cooling towers and 

16 cooling water reservoir discharges before operation of the units at the Trinity 2 site. Effluent 

17 discharges through a TPDES-permitted outfall, such as those from the Big Brown Power Plant, 

18 Freestone Energy Center, amd Limestone Electric Generating Station, are required to comply 

19 with the Clean Water Act. Such permits are designed to protect water quality. Because 

20 historical discharges to the Trinity River have resulted in impairment of the segment near the 

21 Trinity 2 site, the review team concludes that the cumulative impact on surface water quality of 

22 the receiving water body would be MODERATE. Building and operating the proposed units at 

23 the Trinity 2 site would not be a significant contributor to these surface water quality impacts, 

24 because industrial and wastewater discharges from the proposed units would comply with 

25 TPDES permit limitations. The impacts of other projects listed in Table 9-16 would have little or 

26 no impact on surface water quality. 

27 The review team also concludes that with the implementation of BMPs, the impacts to 

28 groundwater quality from building and operating two new nuclear units at the Trinity 2 site would 

29 likely be minimal. The individual impacts from other projects listed in Table 9-8 would have little 

30 or no impact on regional groundwater quality because of the local nature of groundwater 

31 withdrawals and their associated impacts. Therefore, the cumulative impact on groundwater 

32 quality would be SMALL. 

33 9.3.4.3 Terrestrial and Wetland Resources 

34 The following impact analysis includes impacts from building activities and operations. The 

35 analysis also considers other past, present, and reasonably foreseeable future actions that 

36 impact terrestrial and wetland resources, including other Federal and non-Federal projects listed 

37 in Table 9-16. For the analysis of terrestrial ecological impacts at the Trinity 2 site, the 
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Draft NUREG-1937 9-160 March 2010

1 geographic area of interest is the intersection of the East Central Plains ecoregion and the 

2 Trinity-Lower Tehuacana watershed (Figure 9-14 on the following page). This region is 

3 expected to encompass the ecologically relevant landscape features and species. 

4 The Trinity 2 site is a greenfield site located 2.5 mi west and 5 mi south of the Trinity River. The 

5 site is in the Blackland Prairies subprovince of the Gulf Coast Plains. The blacklands have a 

6 gentle undulating surface that has been cleared of most natural vegetation for the cultivation of 

7 crops (UT 1996). The soils of the blacklands are chalks and marls that have weathered to 

8 deep, fertile clay soils. Pre-settlement conditions were that of a true prairie grassland 

9 community dominated by a diverse assortment of perennial and annual grasses and forbs, with 

10 sparsely scattered trees or mottes of oaks (Quercus sp.) on the uplands (TPWD 2009a). 

11 Forested or wooded areas were restricted to bottomlands along major rivers and streams, 

12 ravines, protected areas, or on certain soil types. Trees such as pecan (Carya illinoinesis), 

13 cedar elm (Ulmus crassifolia), cottonwoods (Populus sp.), various oaks, and hackberry (Celtis

14 sp.) dotted the landscape (TPWD 2009b). The dominant grass was the little bluestem 

15 (Schizachyrium scoparium); other grasses included the big bluestem (Andropogon geradrii), 

16 Indian grass (Sorghastrum sp.), eastern gamagrass (Tripsacum dactyloides), switchgrass 

17 (Panicum virgatum), and sideoats grama (Bouteloua curtipendula). 

18 Currently in the region surrounding the Trinity 2 site, there is a mixture of post oak woods, 

19 improved pasture, and rangeland (STPNOC 2009b). There is also a surface lignite mining 

20 operation to the west. Onsite drainages include Tehuacana Creek, Big Brown Creek, and Rock 

21 Springs Branch. Big Brown Creek is dammed in its middle reaches to form Fairfield Lake; it 

22 flows into Tehucana Creek. Big Brown Creek crosses rolling prairie with local shallow 

23 depressions, surfaced by clay and sandy loams that support hardwoods, mesquite, conifers, 

24 and grasses. The area is used primarily for dryland farming. Tehuacana Creek flows into the 

25 Trinity River and passes through terrain similar to Big Brown Creek. The area supports water26 tolerant hardwoods, conifers, and grasses (STPNOC 2009a). 

27 The total acreage for all temporary and permanent impacts at the Trinity 2 site is 800 ac for the 

28 plant site and 1700 ac for the reservoir. Permanent impacts associated with building two new 

29 nuclear units would include approximately 150 ac for each unit (300 ac total) and a new 1700-ac 

30 reservoir for cooling water for the plant (STPNOC 2009a). While specific habitat acreages have 

31 not been determined for the site, Table 9-17 gives approximate acreages by land cover class for 

32 areas expected to receive permanent impacts. No assessment was made for land cover 

33 classes expected to receive temporary impacts (STPNOC 2009a). 
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1 

2 Figure 9-14. Geographic Area of Analysis of Cumulative Impacts to Terrestrial Resources for 

3 the Trinity 2 Site in Freestone County
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1 Table 9-17. Estimated Land Cover Classes for Approximately 2000 ac of the 2500-ac Trinity 2 

2 Site. 

Land Cover Class Plant (ac) Reservoir (ac) 

Forested (includes 80 ac of high-quality forested wetlands) 160 190 

Open land/grasslands 140 1460 

Developed areas (roads, drill pads) 30 

Water resources/freshwater ponds 20 

Source: STPNOC 2009a 

Note: Estimates are for areas receiving permanent impacts and are based on Google Earth Imagery 

3 No digitized wetland maps are available for the site area, so wetland acreage was estimated 

4 using United States Geological Survey (USGS) quadrangle maps that encompass the site 

5 (i.e., Young (1988) and Yard (1980)) (STPNOC 2009a). Within the 2000- ac area for the Trinity 

6 2 site receiving permanent impacts, wetlands appear to be limited to the northern portion. 

7 These wetlands include several high-quality forested wetlands (80 ac total) with several small 

8 freshwater ponds (20 ac total). Approximately 15 of the 100 ac appear to be located in the area 

9 where the plant would be located; 10 ac of the 15 ac are high quality forested wetlands. The 

10 remaining wetland areas fall within the footprint of the reservoir. 

11 There are numerous wildlife areas located near the Trinity 2 site (STPNOC 2009b) including the 

12 Fairfield Lake State Park, 4-mi southwest of the site, the Richland Creek WMA approximately 

13 10 mi north of the site, the Gus Engeling WMA, approximately 16 mi northeast of the site, and 

14 the Big Lake Bottom WMA 11 mi east-southeast of the site. The woods at the Fairfield Lake 

15 State Park include oak, hickory, cedar elm, dogwood, and redbud, and mark the transition zone 

16 between pine forests to the east and the prairie grasslands to the north and west (TPWD 

17 2009c). Wildlife found at the park include osprey, bald eagles (November through February), 

18 white-tailed deer, raccoons, foxes, beaver, squirrels, and armadillos. The Richland Creek WMA 

19 supports a wide variety of bottomland and wetland dependent wildlife and vegetation 

20 communities which serves as nesting and brood rearing habitat for many species of neotropical 

21 birds (TPWD 2009c). In addition, the area has numerous marshes and sloughs which provide 

22 habitat for migrating and wintering waterfowl, wading and shore birds. The Gus Engeling WMA 

23 is comprised of 2000 ac of hardwood bottomland floodplain and almost 500 ac of natural 

24 watercourse, 350 ac of wetlands, and nearly 300 ac of sphagnum moss bogs (TPWD 2009c). 

25 There are two Ecologically Significant River and Stream Segments near the Trinity 2 site: the 

26 Trinity River from the Freestone/Anderson/Leon County line upstream to the 

27 Anderson/Henderson County line, and Buffalo Creek, from the confluence with Alligator Creek 

28 in Freestone County upstream to State Route 164 in Freestone County (TPWD 2010). In 

29 addition, drainage in the area feeds Catfish Creek, a tributary of the Trinity River. Eight mi of 

30 the creek have been designated as a “Natural National Landmark” by the U.S. Department of 

31 Interior (NPS 2009). Currently wildlife in the Gus Engeling WMA comprises nearly 40 species of 

32 mammals, 156 species of birds, 54 species of reptiles and amphibians, and 900 plant species. 
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1 More than 90 percent of the Big Lake Bottom WMA is bottomland habitat of mature hardwood 

2 timber with more than 450 plant species (TPWD 2009c). Wildlife species include white-tailed 

3 deer, feral hog, ducks, mourning dove, fox squirrel, gray squirrel, raccoon, skunk, armadillo, 

4 coyote, grey fox, plus numerous species of reptiles and migratory birds. 

5 Important Species 

6 A range of recreationally important wildlife species occur at the site (STPNOC 2009b) including 

7 white-tailed deer (Odocoileus virginianus), mourning dove (Zenaida macroura), and northern 

8 bobwhite (Colinus virginianus) on the uplands, and eastern fox squirrel (Sciurus niger) along 

9 stream bottoms (STPNOC 2009a). The Tehuacana Creek area, north of the Trinity 2 site, 

10 contains excellent deer and wild turkey habitat (STPNOC 2009b). Generally these species are 

11 habitat generalists (NatureServe 2009a), although lack of nesting and brood rearing habitats for 

12 the turkey and northern bobwhite have led to their decline (TPWD 2009e). The site lies within 

13 the Central Flyway of Texas (STPNOC 2009b) and provides habitat for rest and forage 

14 opportunities during migration. 

15 Up to seven bat species living in eastern Texas, can occur in Freestone County (Davis and 

16 Schmidly 1994; STPNOC 2009b). Some are mostly year-round residents (i.e., non-migratory), 

17 such as the big brown bat (Eptesicus fuscus), the eastern pipistrelle (Pipistrellus subflavus), and 

18 evening bat (Nycticeius humeralis). Migratory bats that could occur at the site include the hoary 

19 bat (Lasiurus cinereus), the silver-haired bat (Lasionycteris noctivagans), the eastern red bat 

20 (Lasiurus borealis), and the Mexican free-tailed bat (Tadarida brasiliensis). The Mexican free21 tailed bat is either migratory or non-migratory depending on where it resides; the migratory 

22 status of bats occurring in Freestone County is currently unknown (STPNOC 2009b). 

23 No site-specific surveys have been conducted for threatened and endangered species at the 

24 Trinity 2 site. The following list for Freestone County (Table 9-18 on the following page) is from 

25 the Texas Parks and Wildlife Threatened and Endangered Species by County website (TPWD 

26 2009c) and the U.S. Fish & Wildlife Service Ecological Service T&E species for the Southwest 

27 region website (FWS 2009a). The list includes four species on the Federal-endangered list 

28 (FWS 2009a), and an additional ten species on the State-endangered and threatened species 

29 list (TPWD 2009f). 
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1 Table 9-18. Federally and State-listed Threatened and Endangered Species in Freestone 

2 County, Texas 

Group Common Name Scientific Name 

Federal 

Status 

State 

Status 

Plants Large-fruited sand-verbena Abronia macrocarpa E E 

Navasota ladies'-tresses Spiranthes parksii E E 

Amphibians Houston toad Bufo houstonensis E 

Alligator snapping turtle Macrochelys temminckii T 

Texas horned lizard Phrynosoma cornutum T 

Reptiles 

Timber/canebrake rattlesnake Crotalus horridus T 

American peregrine falcon Falco peregrinus anatum T 

Bachman's sparrow Aimophila aestivalis T 

Bald eagle Haliaeetus leucocephalus T 

Interior least tern Sterna antillarum athalassos E E 

Piping plover Charadrius melodus T 

Whooping crane Grus americana E E 

Birds 

Wood stork Mycteria americana T 

Mammals Red wolf Canis rufus E 

Sources: FWS 2009a and TPWD 2009f 

T = threatened; E = endangered 

3 Large-fruited sand-verbena

4 Large-fruited sand-verbena (Abronia macrocarpa) is a Federally and State-listed endangered 

5 species (FWS 2009a; TPWD 2009f). This plant lives in sandy openings in post oak-grassland 

6 mosaic vegetation type (NatureServe 2009b). It is sometimes found on actively blowing sand 

7 dunes. The species can temporarily dominate bare sand areas during the spring. This plant is 

8 distributed in Freestone and two other counties in Texas (TPWD 2009g). 

9 Navasota ladies’-tresses

10 The orchid, Navasota ladies’-tresses (Spiranthes parksii), is a Federally and State-listed 

11 endangered species (FWS 2009a; TPWD 2009f). This plant is endemic to the Oak Woodlands 

12 and Prairies region of east-central Texas (TPWD 2009g). It occurs primarily in seasonally moist 

13 soils along open wooded margins of creeks, drainages, and intermittent tributaries of the Brazos 

14 and Navasota rivers. Once thought to be extremely rare, it is now known to be locally common 

15 in parts of its range which includes Freestone County. 

16 Houston toad

17 The Houston toad (Bufo houstonensis) is a State-listed endangered species (TPWD 2009f). It 

18 lives primarily on land and burrows into sand for protection from cold weather in the winter and 
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1 from hot, dry conditions in the summer. The toads are found in areas with loose, deep sand 

2 supporting woodland savannah and in proximity to still or flowing waters for breeding (TPWD 

3 2009g). The toads have been recorded in Freestone County and in the Trinity River watershed 

4 (NatureServe 2009b). 

5 Alligator snapping turtle

6 The alligator snapping turtle (Macrochelys temminckii) is a State-listed threatened species 

7 (TPWD 2009f). It is found in slow-moving, deep water of rivers, sloughs, oxbows, and canals or 

8 lakes associated with rivers; also swamps, and ponds near rivers, and shallow creeks that are 

9 tributary to occupied rivers (NatureServe 2009b). It usually occurs in water with mud bottoms 

10 and abundant aquatic vegetation; it may migrate several miles along rivers (TPWD 2009g). 

11 Turtles are rarely found out of the water except when nesting. The turtles have been recorded 

12 in the Upper and Lower Trinity watersheds (NatureServe 2009b). 

13 Texas horned lizard 

14 The Texas horned lizard (Phrynosoma cornutum) is a State-listed threatened species (TPWD 

15 2009f). It can be found in arid and semiarid habitats in open areas with sparse plant cover 

16 (TPWD 2009g). They dig for hibernation, nesting, and insulation purposes, and are commonly 

17 associated with loose sand or loamy soils. Populations have declined precipitously in eastern 

18 Texas and their decline may be related to the spread of fire ants, use of insecticide to control 

19 fire ants, heavy agricultural use of the land and other habitat alterations (NatureServe 2009b). 

20 Another factor implicated in their decline is over-collecting for pet and curio trade. This species 

21 is particularly vulnerable to the loss of harvester ants which make up nearly 70 percent of their 

22 diet. 

23 Timber/canebrake rattlesnake

24 The timber rattlesnake (Crotalus horridus) is a State-listed threatened species (TPWD 2009f). It 

25 prefers moist lowland forests and hilly woodlands or thickets near permanent water sources 

26 such as rivers, lakes, ponds, stream and swamps (TPWD 2009g). Their range extends from 

27 central New England to northern Florida, and west to eastern Texas, where their distribution is 

28 spotty (NatureServe 2009b). 

29 American peregrine falcon 

30 The American peregrine falcon (Falco peregrines anatum) is a State-listed threatened species 

31 (TPWD 2009f). The bird is a year-round resident and local breeder in west Texas where it nests 

32 in tall cliff eyries (TPWD 2009g). The bird also migrates across Texas from breeding areas in 

33 the United States and Canada to winter along the coast and farther south. The American 

34 peregrine falcon occupies a wide range of habitats during migration, including urban areas. 
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1 Populations are primarily concentrated along coast and barrier islands. The birds are low2 altitude migrants, with stopovers at leading landscape edges such as lake shores, coastlines, 

3 and barrier islands. 

4 Bachman’s sparrow

5 Bachman’s sparrow (Aimophila aestivalis) is a State-listed threatened species (TPWD 2009f). 

6 The sparrow is a permanent resident that occurs only in the far eastern portion of the state 

7 (Benson and Arnold 2001). It prefers areas with a high density of herbaceous cover and an 

8 open overstory. It historically was found in pineywoods with mature, open pine forests and 

9 savannah maintained by frequent fires. Today, with the dramatic decline in this forest type, the 

10 sparrow seems to tolerate treeless, grassy areas, abandoned fields or early stages of 

11 regenerating clearcuts. 

12 Bald eagle 

13 Although recently delisted as a Federally endangered species, the bald eagle (Haliaeetus 

14 leucocephalus) is listed as threatened in Texas and will remain Federally protected under the 

15 Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act (TPWD 2009f). The 

16 species will also continue to be protected under the ESA through management guidelines that 

17 will be in place for the next five years. Most eagles breed in Canada and the northern United 

18 States and move south for the winter (NatureServe 2009b). Bald eagles can be year-round 

19 residents in areas where water bodies do not freeze. Winter roost sites can vary with proximity 

20 to food resources, and eagles commonly roost communally in large trees, preferably snags. 

21 Interior least tern

22 The interior least tern (Sterna antillarum athalassos) is a Federally and State-listed endangered 

23 species (FWS 2009a; TPWD 2009f). The birds breed along major inland river systems but 

24 appear to be restricted to less altered and more natural river segments (TPWD 2009g). Interior 

25 least terns nest on bare or sparsely vegetated sand, shell, and gravel beaches, islands, and salt 

26 flats associated with rivers and reservoirs. The birds prefer open habitat and avoid thick 

27 vegetation and narrow beaches. They arrive at breeding areas in early April to early June after 

28 wintering along the Central American coast and the northern coast of South America. 

29 Piping plover

30 The piping plover (Charadrius melodus) is a State-listed threatened species (TPWD 2009f). 

31 This species is Federally-listed as threatened in the state of Texas, but is not listed as occurring 

32 in Freestone County by FWS (FWS 2009a). Texas is the wintering home for more than 5000 

33 known breeding pairs which have migrated from the Great Lakes regions and southern Canada 
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1 (TPWD 2009g). They live on sandy beaches and lakeshores along the Gulf coast and could 

2 migrate through Freestone County. 

3 Whooping crane 

4 The whooping crane (Grus americana) is a Federally and State-listed endangered species 

5 (FWS 2009a; TPWD 2009f). They breed in Canada during the summer months and migrate in 

6 the fall to the Aransas National Wildlife Refuge along the Texas coastal plain, staying there from 

7 November through March (TPWD 2009g). Their winter and migrating habitat includes marshes, 

8 shallow lakes, lagoons, salt flats, grain and stubble fields (NatureServe 2009b). Migration 

9 habitat includes sites with good horizontal visibility, water depth of 30-cm or less, and a 

10 minimum wetland size of 0.04-ha for roosting. 

11 Wood stork 

12 The wood stork (Mycteria americana) is a State-listed threatened species (TPWD 2009f). 

13 Nesting appears to be restricted to Florida, Georgia, and South Carolina, however they may 

14 have formerly bred in Texas (FWS 2009b), but there are no breeding records since 1960 

15 (TPWD 2009g). Wood storks forage in prairie ponds, flooded pastures or fields, ditches, and 

16 other shallow standing water, including salt-water. The birds usually roost communally in tall 

17 snags, sometimes in association with other wading birds (i.e., active rookeries). A distinct, non18 listed population of wood storks breed in Mexico and birds then move into Gulf States in search 

19 of mud flats and other wetlands, even those associated with forested areas. 

20 Red wolf

21 The red wolf (Canis rufus) is a State-listed endangered species (TPWD 2009f). Red wolves 

22 inhabited brush and forested areas, as well as the coastal prairies (Davis and Schmidly 1994). 

23 They formerly ranged throughout eastern Texas, but appear to now be extinct. 

24 Building Impacts 

25 Building two nuclear power units and a reservoir at Trinity 2 would affect up to 2500 ac of land 

26 resulting in the permanent loss of 2000 ac of terrestrial habitat. Three-hundred ac would be 

27 required for permanent structures, and facilities, and up to 1700 ac would be for a new 

28 reservoir. Of the acreage that would be permanently affected, 350 ac would be forested 

29 including 80 ac of high quality forested wetlands (Table 9-17) and 1600 ac of open grasslands. 

30 In addition, the land required for transmission corridors, water pipelines, road, or rail access is 

31 estimated to impact an additional 303 ac. The water storage reservoir would be created off of 

32 Tehuacana Creek (STPNOC 2009a), and would flood portions of Tehuacana Creek, Big Brown 

33 Creek, and other smaller tributaries in the area (STPNOC 2009a). The project could result in 

34 localized, direct, and adverse impacts to wetlands. 
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1 To accommodate the building and operation of two nuclear units on the Trinity 2 site, STPNOC 

2 would need to clear undisturbed terrestrial habitats to connect existing power lines with new 

3 lines (STPNOC 2009a). The terrain along the likely transmission corridor is similar to that of the 

4 Trinity 2 site (STPNOC 2009b). The Trinity 2 site is 2.6 mi east of the Big Brown Power Plant 

5 and new lines would traverse a distance of 5 mi to connect to multiple 345kV lines. A new 

6 corridor would be needed to access these lines. Based on 5 mi and a 200-ft width corridor, 

7 installation of new lines would impact 120 ac in Freestone County. Although the most direct 

8 route would be used, efforts would be made to avoid natural or man-made areas where 

9 important environmental resources are located. No areas designated by the FWS as critical 

10 habitat for endangered species exist on the Trinity 2 site or adjacent to associated transmission 

11 lines (FWS 2009d). Erection of transmission towers and stringing of new lines would be 

12 expected to comply with all applicable laws, regulations, permit requirements, and use of best 

13 management practices. (STPNOC 2009a) 

14 In addition to transmission lines, there would be possible impacts associated with the building of 

15 pipelines to deliver cooling water to the reservoir/plant site. Transportation corridors (both road 

16 and rail) would also be needed at the Trinity 2 site. Acreage estimates for these activities are: 

17 120 ac for 19.5 mi of rail (50-ft width), 36 ac for 4 mi of pipeline for the cooling water intake/ 

18 discharge between the Trinity River and new reservoir (75-ft width), and 27 ac for a 3.0-mi 

19 access road (75-ft width) (STPNOC 2009a). 

20 There are no published records of Federal or state-listed species were available from the Trinity 

21 2 site (STPNOC 2009a). Federally and State-listed species for Freestone County were 

22 discussed above. No critical or sensitive habitats have been identified in the site area although 

23 portions of the Trinity River and Tehuacana Creek include Priority Bottomland Hardwood habitat 

24 which have high habitat resource value, particularly for waterfowl. The site area, particularly 

25 along Tehuacana Creek heading towards Richland-Chambers Reservoir contains excellent 

26 deer, wild turkey, and grey squirrel habitat. The Richland Creek WMA is within 7 mi of the site. 

27 The WMA was created to compensate for habitat loss associated with the construction of the 

28 Richland-Chambers Reservoir; it was developed to provide habitat for indigenous and migratory 

29 wildlife species (TPWD 2009c). 

30 Building two new nuclear units at the Trinity 2 site would result in the permanent loss of 

31 approximately 2000 ac of terrestrial habitat including 350 ac of forested habitat and 80 ac of 

32 wetlands. However, the new reservoir would provide habitat for waterfowl. Clearing land for the 

33 transmission line corridor would increase habitat fragmentation along the 5-mi corridor. Other 

34 sources of impacts to terrestrial resources such as noise, increased risk of collision and 

35 electrocution, and displacement of wildlife would likely be temporary and result in minimal 

36 impacts to the resource. Building the two new units would noticeably alter the available 

37 terrestrial habitat. 
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March 2010 9-169 Draft NUREG-1937 

1 Operational Impacts 

2 Impacts on terrestrial ecological resources from operation of two new nuclear units at the 

3 Trinity 2 site would include those associated with transmission system structures, and 

4 maintenance of transmission line corridors. Also, during plant operation, wildlife would be 

5 subjected to impacts from increased traffic. An evaluation of specific impacts resulting from 

6 presence of transmission lines and transmission line corridor maintenance cannot be conducted 

7 in any detail due to the lack of information, such as the locations of any new corridors that could 

8 result from transmission system upgrades. However, in general, impacts associated with 

9 transmission line operation consist of bird collisions with transmission lines, EMF effects on flora 

10 and fauna, and habitat loss due to corridor maintenance. 

11 Direct mortality resulting from birds colliding with tall structures has been observed (Erickson et 

12 al. 2005). Factors that appear to influence the rate of avian impacts with structures are diverse 

13 and related to bird behavior, structure attributes, and weather. Migratory flight during darkness 

14 by flocking birds has contributed to the largest mortality events. Tower height, location, 

15 configuration, and lighting also appear to play a role in avian mortality. Weather, such as low 

16 cloud ceilings, advancing fronts, and fog also contribute to this phenomenon. Waterfowl may be 

17 particularly vulnerable due to low, fast flight and flocking behavior (Brown 1993). Although 

18 additional transmission lines would be required for two new nuclear units at Trinity 2, increases 

19 in bird collisions directly attributable to these lines would be minor and these would likely not be 

20 expected to cause a measurable reduction in local bird populations. Consequently, the 

21 incremental direct mortality posed by the addition of new transmission lines for two new nuclear 

22 units would be negligible at Trinity 2. 

23 EMFs are unlike other agents that have an adverse impact (e.g., toxic chemicals and ionizing 

24 radiation) in that dramatic acute effects cannot be demonstrated and long-term effects, if they 

25 exist, are subtle (NIEHS 2002). A careful review of biological and physical studies of EMFs did 

26 not reveal consistent evidence linking harmful effects with field exposures (NIEHS 2002). The 

27 magnetic fields from many lines, at a distance of 300 ft are similar to typical background levels 

28 in most homes (NIEHS 2002). Thus, impacts of EMFs on terrestrial flora and fauna are of small 

29 significance at operating nuclear power plants, including transmission systems with variable 

30 numbers of power lines (NRC 1996). Since 1997, more than a dozen studies have been 

31 published that looked at cancer in animals that were exposed to EMFs for all or most of their 

32 lives (Moulder 2003). These studies have found no evidence that EMFs cause any specific 

33 types of cancer in rats or mice (Moulder 2003). 

34 The impacts associated with corridor maintenance activities are loss of habitat due to cutting 

35 and herbicide application. The maintenance of transmission-line corridors could be beneficial 

36 for some species, including those that inhabit early successional habitat or use edge 

37 environments. Thus, corridor maintenance would not be expected to increase and contribute to 

38 cumulative effects. 
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1 The potential effects of operating two new nuclear reactors at the Trinity 2 site would be 

2 primarily associated with maintenance of transmission corridors and increased traffic. 

3 Operational impacts to terrestrial resources would be expected to be minimal. 

4 Cumulative Impacts 

5 The impacts of building and operating two units at Trinity 2 were evaluated to determine the 

6 magnitude of their contribution to regional cumulative impacts on terrestrial ecological 

7 resources. The geographic area of interest for cumulative impacts is the intersection of the East 

8 Central Texas Plains ecoregion with the Lower Trinity-Tehucana watershed (Figure 9-14). 

9 There are a number of past, present, and potential future projects that could affect the terrestrial 

10 and wetland resources (Table 9-16). Past actions that have affected terrestrial resources 

11 include building the Big Brown Power Plant, approximately 3 mi west of the Trinity 2 site, and 

12 the Freestone Energy Center, approximately 7 mi northwest of the site. A third project is the Big 

13 Brown Mine, 4 mi northwest of the site. Luminant Mining, LLC, owner of the Big Brown Mine, 

14 has mined, leveled, and reclaimed 11,499 ac at the mine site (Gentry 1997). 

15 Projects or actions listed in Table 9-16 that could have future impacts on terrestrial resources 

16 include the Lakeside Energy Center, a 640-MW natural gas plant, planned for construction 

17 approximately 12 mi northwest of the Trinity 2 site. About 35 ac of terrestrial habitat would be 

18 needed for the site (Fairfield 2009). Luminant Mining, LLC is proposing to open the Turlington 

19 Mine next to the Big Brown Mine to mine an additional 10,000 ac at their facility 4 mi northwest 

20 of Trinity 2 site. There are several planned but currently unfunded highway widening projects 

21 within the geographic area of interest. In addition, two reservoirs are planned for the region: the 

22 Tehuacana Reservoir (approximately 15,000 ac) and the Tennessee Colony Lake 

23 (approximately 85,000 ac); both would inundate substantial areas of terrestrial habitat. 

24 The review team is also aware of the potential for GCC affecting the terrestrial resources in the 

25 geographic area of interest. The future impact of GCC on plant and wildlife species and their 

26 habitat in the geographic area of interest is not precisely known. GCC effects near the Trinity 2 

27 site could result in regional increases in the frequency of severe weather, decreases in annual 

28 precipitation, and increases in average temperature (Karl et al. 2009). The decrease in 

29 precipitation combined with increased temperatures and evaporation could result in more 

30 frequent droughts. Such changes in climate could alter and fragment terrestrial habitats 

31 (grasslands, forests, and wetlands) and result in shifts in species ranges, diversity, and 

32 abundance in the geographic area of interest for the Trinity 2 site (Karl et al. 2009). Because of 

33 the regional nature of climate change, the impacts related to GCC would be similar for all the 

34 alternative sites, as they are all in the Great Plains Region. 

35 The potential cumulative impact to terrestrial resources within the area of interest given the two 

36 new reactors and cooling reservoir at the Trinity 2 site, the proposed Turlington Mine, the 

37 building of a new power plant, and the potential construction of two additional reservoirs would 
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March 2010 9-171 Draft NUREG-1937 

1 noticeably alter terrestrial resources. All these activities would remove or modify terrestrial 

2 habitats with the potential to affect important species living or migrating through the area. The 

3 incremental contribution of building and operating the two reactors at the Trinity 2 site to the 

4 cumulative impacts within the geographic area of interest would be significant. 

5 Summary 

6 Impacts to terrestrial ecology and wetland resources were estimated based on information 

7 provided by STPNOC and the review team’s own independent review. The review team 

8 concludes that there would be a loss of about 10 ac of high-quality forested wetlands associated 

9 with building two new nuclear units at the Trinity 2 site. Additional impacts to terrestrial 

10 resources would occur at the reservoir location based on the potential for affecting 350 ac of 

11 forested land, including high quality bottomland hardwood habitat, wetlands, and to a number of 

12 protected species that could potentially occur in the area. Although there is uncertainty 

13 concerning the possible routing of a new transmission line corridor, building impacts would 

14 probably be minimal given the small distance to existing transmission lines. There are several 

15 future activities in the region that would noticeably affect wildlife and wildlife habitat. These 

16 activities include the opening of the Turlington Mine, building the Lakeside Energy Center, and 

17 development of two large reservoirs (Tennessee Colony and Tehuacana). Based on the 

18 information provided by STPNOC and the review team’s independent evaluation, the review 

19 team concludes that the cumulative impacts within the area of interest on terrestrial plants and 

20 animals, including threatened or endangered species, and wildlife habitat in the region would be 

21 MODERATE. For the reasons discussed above in Building Impacts and Operational Impacts, 

22 the incremental contribution of building and operating two units at Trinity 2 and its associated 

23 reservoir to cumulative impacts within the geographic area of interest would be significant. 

24 9.3.4.4 Aquatic Resources 

25 The following impact analysis includes impacts from building activities and operations. The 

26 analysis also considers other past, present, and reasonably foreseeable future actions that 

27 impact aquatic resources, including other Federal and non-Federal projects listed in Table 9-16. 

28 For the analysis of aquatic ecological impacts at the Trinity 2 site, the geographic area of 

29 interest is considered to be the Trinity River drainage basin, from the upstream reaches of the 

30 Richland Chambers Reservoir to the proposed Tennessee Colony dam site (Region C 2010) 

31 because this is the area that the aquatic resources could be affected by new nuclear units. 

32 Aquatic resources of the Trinity 2 site are associated with the Trinity River, Lake Fairfield, and 

33 local drainages (Tehuacana Creek, Big Brown Creek, and Rock Springs Branch). (The Trinity 

34 River has been significantly influenced by urbanization and growth both upstream (Dallas-Fort 

35 Worth) and downstream (Houston). Water conditions in the Trinity River deteriorated to the 

36 point where numerous fish kills were common, even as recently as 1985 (USGS 2005). 

37 Through efforts to address wastewater discharge and manage water withdrawal, the Trinity 
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1 River’s aquatic ecology has rebounded in recent years. Surveys of fish in the river have shown 

2 the improvement over time. From 1972-74, six surveys for fish were conducted and only four 

3 species of fish were identified (smallmouth buffalo [Ictiobus bubalus], gizzard shad [Dorosoma 

4 cepedianum], common carp [Cyprinus carpio], and yellow bass [Morone mississippiensis]), and 

5 no fish were collected in four of the six surveys. TPWD conducted additional surveys in 1987 

6 that indicated species richness was still low but the identification of 11 fish species was an 

7 indication of improvements to the aquatic resources. The most recent studies, performed by the 

8 USGS from 1993 to 1995, found a cumulative total of 25 fish species, including several game 

9 indigenous species. The presence of two darter species (bigscale logperch [Percina 

10 macrolepida] and slough darter [Etheostoma gracile]) suggests that the Trinity River is starting 

11 to recover and return to more natural conditions (USGS 2005). Today, the Trinity River in the 

12 vicinity of the Trinity 2 site is considered an ecologically significant stream segment based on its 

13 biological function, riparian conservation area, and the presence of protected aquatic species 

14 (TPWD 2010). 

15 Lake Fairfield supports the Big Brown Power Plant. The lake is an off-channel reservoir, and 

16 was formed by the damming of Big Brown Creek. Recreational fishing is popular in the lake and 

17 several fishing tournaments take place there every year. 

18 The area for a new reservoir to support the Trinity 2 site is located in the vicinity of Tehuacana 

19 Creek, Big Brown Creek, and Rock Springs Branch. No stream surveys for aquatic resources 

20 have been identified for Tehuacana Creek, Big Brown Creek, and Rock Springs Branch. Big 

21 Brown Creek begins three mi southwest of Fairfield in central Freestone County., and runs 

22 northeast 13 mi to the confluence with Tehuacana Creek, which is 4 mi east of Lake Fairfield. 

23 Tehuacana Creek flows from outside the town of Tehuacana for 42 mi to the confluence with the 

24 Trinity River. Tehuacana Creek and its major tributaries have been reported as having 

25 intermittent flow conditions; yet small potholes remain full of water during the drier periods of the 

26 year. 

27 Within the Trinity River drainage basin, from the upstream reaches of the Richland Chambers 

28 Reservoir to the proposed Tennessee Colony Dam site, there are a number of past, present, 

29 and potential projects that could affect the aquatic resources (Table 9-16). Past actions 

30 included building the lignite coal-powered Big Brown Power Plant, natural gas-powered 

31 Freestone Energy Center, Big Brown Lignite Coal Mine, and the Streetman Expanded Shale 

32 and Clay Plant. The Big Brown Lignite Coal Mine has plans to begin expanding its mining 

33 activities (Turlington mine). The natural gas-powered Lakeside Energy Center is another 

34 proposed power-related project in the region. The Trinity River Authority has proposed 

35 additional reservoirs to be constructed off the Trinity River: Tennessee Colony and Tehuacana 

36 Reservoirs. In addition, the new nuclear units at the Trinity 2 alternative site would require 

37 building water intake and discharge systems with associated pipelines from the Trinity River to 

38 the new cooling water reservoir, inundation of existing water features at the Trinity 2 site, and 
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March 2010 9-173 Draft NUREG-1937 

1 establishing and operation of associated transmission corridors to connect with the existing 

2 power grid. Without having the specific plans for locating all facilities at the Trinity 2 site, the 

3 potential for impacts from building and operation of the new units to aquatic biota are assumed 

4 to be primarily to the organisms inhabiting the Trinity River, Tehuacana Creek, Big Brown 

5 Creek, and Rock Springs Branch. 

6 Non-Native and Nuisance Species 

7 No non-native or nuisance species have been recorded in the area as a problem. However, 

8 there are numerous nuisance aquatic species that TPWD considers to be ubiquitous across 

9 waterways in Texas. TPWD works to educate recreational boaters to remove nuisance aquatic 

10 plant species across the state and in the area of the Trinity 2 site. These species include: 

11 hydrilla, waterhyacinth, and giant salvinia. In addition, the Trinity River basin is known to have 

12 the following non-native fish introduced to its waters: common carp, grass carp, blacktail shiner, 

13 bullhead minnow, rudd, black buffalo, black bullhead, Western starhead topminnow, redspotted 

14 sunfish, tadpole madtom, plains killfish, yellow perch, red drum (Sciaenops ocellatus), tilapia 

15 (Oreochromis aureus) and walleye (Thomas et al 2007; Hassan-Williams and Bonner 2009; 

16 TPWD 2009h). 

17 Important Species 

18 Recreational fishing is popular in the region of the Trinity 2 alternative site, particularly in Lake 

19 Fairfield. Access for recreational fishing in the Trinity River in the vicinity is limited because boat 

20 access is difficult. In Lake Fairfield, fishing for the following species is popular: alligator gar, 

21 largemouth bass, catfish (blue, channel, and flathead), and sunfish (longear [Lepomis 

22 megalotis], redear [L. microlophus], and hybrids) (TPWD 2007; STPNOC 2009a). Recreational 

23 and commercially important species for the Trinity River basin include the bluegill, blue catfish, 

24 channel catfish, flathead catfish, white crappie, black crappie, striped mullet (Mugil cephalus), 

25 white mullet (M. curema), and warmouth (Thomas et al. 2007; TPWD 2007; Hassan-Williams 

26 and Bonner 2009). The centrachids (largemouth bass, bluegill, crappies, sunfishes, and 

27 warmouth) typically inhabit lakes, rivers, and smaller flowing tributaries. The bass and 

28 warmouth are top carnivores, whereas the bluegill and crappies are insectivores. Alligator gar 

29 and catfish are top carnivores and are found primarily in larger waterbodies, like rivers and 

30 reservoirs. The striped and white mullet are more commonly found on the coast, and it is 

31 unclear if they travel and forage above Lake Livingston, which is below the Trinity 2 site 

32 (Thomas et al. 2007; Hassan-Williams and Bonner 2009). 

33 There are no Federally listed aquatic species protected under the ESA in Freestone County. 

34 TPWD has identified numerous rare and protected aquatic species in Freestone County. These 

35 include several benthic macroinvertebrates that have been determined to be rare and located in 

36 the Trinity River basin: Morse's net-spinning caddisfly (Cheumatopsyche morsei), Holzenthal's 

37 philopotamid caddisfly (Chimarra holzenthali), purse casemaker caddisfly (Hydroptila ouachita), 
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Draft NUREG-1937 9-174 March 2010

1 and another caddisfly (Phylocentropus harrisi). These invertebrates live on the bottom of 

2 streams (lotic systems) until they emerge from the water as a flying adult. One of the interesting 

3 characteristics of caddisflies is that the larvae produce and live inside cases, constructed of 

4 material gathered from the stream and held together by silk. Various families of caddisfly have 

5 unique cases. As larvae, they eat plants and periphyton. They are important in the food web 

6 for streams at all life stages as food for fish and birds. These organisms are not likely to thrive 

7 in slow or standing water, such as in a reservoir (Cushing and Allan 2001). 

8 TPWD has also identified a number of rare and protected freshwater mussels in the Trinity River 

9 basin: rock pocketbook (Arcidens confragosus), Wabash pigtoe (Fusconaia flava), creeper (or 

10 squawfoot) (Strophitus undulatus), pistolgrip (Tritogonia verrucosa), fawnsfoot (Truncilla 

11 donaciformis), and little spectaclecase (Villosa Iienosa). Not much is known about the 

12 distribution of these mussels in the area. However, these types of mussels, known as unioid 

13 mussels, are found in various water flows, from fast moving riffles in streams to quiescent 

14 ponds. Each species has adapted to a particular flow regime. These unioid mussels have a 

15 larval stage called a glochidium. For glochidia to mature to juvenile mussels, they must live as a 

16 parasite in the gill tissues of a host fish. An important component to the distribution of 

17 freshwater mussels in various water bodies is associated with the relationship between the 

18 mussels and the host fish (TPWD 2009d, 2009i). 

19 In addition, TPDW has proposed to list as threatened four species of freshwater, unioid mussels 

20 that are found in Freestone County: Texas pigtoe (Fusconaia askewi), sandbank pocketbook 

21 (Lampsilis satura), Louisiana pigtoe (Pleurobema riddellii), and Texas heelsplitter (Potamilus 

22 amphichaenus) ( 

23 Table 9-19 on the following page) (TPWD 2009i; 35 Texas Register 249). These unioid 

24 mussels have similar life histories to those mentioned above. The Trinity River has one of the 

25 two largest populations of the Texas heelsplitter in the State, and has been noted as part of the 

26 designation for this reach of the river as an ecologically significant stream segment. The Texas 

27 pigtoe and the sandbank pocketbook mussels are being considered for protective status by the 

28 FWS (TPWD 2009i). 

29 Table 9-19. Federally and State-Listed Aquatic Species that are Endangered, Threatened, 

30 and Species of Concern for Freestone County

Scientific Name Common Name State Status

Mussels 

Fusconaia askewi Texas pigtoe T 

Lampsilis satura sandbank pocketbook T 

Pleurobema riddellii Louisiana pigtoe T 

Potamilus amphichaenus Texas heelsplitter T 

Source: State species information provided by TPWD (TPWD 2009; 35 Texas Register 249). 

T = State Listed Threatened 
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1 Building Impacts 

2 Impacts of building a cooling water reservoir may be significant depending on the siting of the 

3 reservoir. The plans are for inundating portions of Tehuacana and Big Brown Creeks as well as 

4 other smaller tributaries in the area. Impacts from onsite building activities that have the 

5 potential to cause erosion and sedimentation in the local water bodies would be controlled or 

6 minimized by the implementation of an SWPPP (STPNOC 2009a). Inundation of small flowing 

7 streams would affect those aquatic resources that have specific habitat requirements. Fish 

8 species that have habitat requirements associated with lotic systems (flowing water) are often 

9 replaced with species more suited to lentic environments (standing water) (Linam et al. 1994). 

10 Habitat for these lotic species found in Tehuacana and Big Brown Creeks, associated wetlands, 

11 and drainages would be lost when these water bodies are inundated to create the reservoir, 

12 including any spawning areas for fish species that are dependent on flowing water. Most 

13 freshwater mussel species are adapted to a specific flow regime, and the inundation of this area 

14 could affect the distribution of the organisms in the region (STPNOC 2009a; TPWD 2009i). If 

15 habitat for the any of the State-listed mussels is found in the area to be inundated for the 

16 creation of the reservoir, TPWD might require mitigation activities (e.g., mussels could be 

17 collected and relocated). 

18 Water intake and discharge structures along the shoreline of the Trinity River would be required 

19 for the new reservoir at the Trinity 2 site (STPNOC 2009a). Building of a new intake and 

20 discharge in the Trinity River would likely require dredging and other significant alterations to the 

21 shoreline aquatic habitat. These activities would be permitted by the Corps and would be 

22 required to meet all State water quality requirements. Building of these structures on the Trinity 

23 River would result in the temporary displacement of aquatic biota within the vicinity of both 

24 structures. It is expected that the motile aquatic organisms would be displaced temporarily 

25 during building. However, the sessile aquatic biota (e.g., mussels) would be lost during building 

26 activities if the river substrate was removed or sedimentation covered the bottom of the river 

27 burying the organisms. Organisms like the mussel could possibly recolonize the disturbed river 

28 substrate with time. For the most part, the impacts on aquatic organisms would be temporary 

29 and largely mitigable through the use of BMPs (e.g., silt screens). If required by TPWD, State30 listed mussels could be surveyed and removed before building activities as a mitigation action. 

31 Building transportation routes (heavy haul road and railroad spur), pipeline and transmission 

32 lines for the Trinity 2 site would result in the temporary displacement of some aquatic biota. 

33 Locations for these systems have not been identified. Expansion of existing corridors is 

34 expected to result in small environmental impacts while building new corridors could result in 

35 moderate impacts. Development of these corridors would employ BMPs to reduce impacts 

36 such that they would be temporary and localized (STPNOC 2009a). 

37 Building the cooling water reservoir for the two new nuclear reactors at the Trinity 2 site would 

38 inundate onsite water bodies. The habitat for the aquatic resources would change, and since 
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Draft NUREG-1937 9-176 March 2010

1 most species cannot adapt to the reservoir environment, the species would be lost to the site. 

2 Thus, the building of the cooling water reservoir would be noticeable but not destabilizing to the 

3 aquatic resources. Building the intake and discharge structures on the Trinity River and in the 

4 new reservoir would affect the aquatic communities but the areas would be recolonized after 

5 building these structures was completed. Building of the transportation routes, transmission 

6 corridors, and pipelines would result in temporary and localized effects on aquatic communities. 

7 Operation Impacts 

8 To operate the two new units at Trinity 2, water rights for the Trinity River would have to be 

9 acquired. Currently, there are not sufficient water rights aggregated to a single point of 

10 diversion (50,000 ac-ft/yr). Instream flow studies necessary to maintain aquatic resources have 

11 not been evaluated for this reach of the river, and impacts associated with removal of water for 

12 the new reservoir are unknown. 

13 Impingement, entrainment, and entrapment of organisms from the Trinity River and from a 

14 constructed reservoir would likely be the most significant impacts to the aquatic population that 

15 could occur from operation of two new nuclear units at the Trinity 2 site. STPNOC states that 

16 using a closed-cycle cooling system with a cooling water reservoir would consume a maximum 

17 of 50,000 ac-ft of water per year (STPNOC 2009a). EPA’s design criteria for 316(b) Phase 1 

18 regulations (66 FR 65256) for intake structures would minimize impacts to aquatic biota in the 

19 Trinity River. The design criteria include: (1) closed-cycle cooling system that meets the EPA’s 

20 Phase I regulations for new facilities; (2) maximum through-screen velocity of 0.15 m/s (0.5 ft/s) 

21 at the cooling water intake; and (3) intake flow of less than or equal to 5 percent of the mean 

22 annual flow. Compliance with these regulations would minimize impingement, entrainment, and 

23 entrapment impacts to the aquatic biota. 

24 Operational impacts to aquatic resources associated with water quality, physical and thermal 

25 characteristics of the discharge cannot be determined without additional detailed analysis. A 

26 cooling water reservoir for the Trinity 2 site would likely evolve in a similar fashion to the MCR at 

27 STP, where, with time, the reservoir has developed similar aquatic resources to that in the lower 

28 Colorado River and acclimated to the discharges of the operating reactor units. Effects on the 

29 aquatic resources in the Trinity River would depend on the type of cooling system as well as 

30 volume, frequency, and water characteristics of the discharge. These types of impacts can be 

31 addressed and minimized through operational procedures and the permitting process with 

32 TCEQ. 

33 Operational impacts to aquatic biota from onsite activities and in the transmission corridors 

34 would also be minimal assuming BMPs are used for maintenance of these areas and corridors. 

35 SWPPPs would ensure that impacts to biota from erosion and sedimentation would be minimal 

36 through the use of silt screens and controls for managing stormwater. These controls would be 

37 important for habitat quality and survival of benthic biota in the downstream drainages. 
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March 2010 9-177 Draft NUREG-1937 

1 Based on operation of the CWS, impacts to aquatic communities in the Trinity River and 

2 reservoir could result from impingement, entrainment, and entrapment as well as thermal, 

3 chemical, and physical characteristics of the discharge. STPNOC commits to compliance with 

4 State and Federal regulations for operation of intake and discharge structures that would be 

5 protective of aquatic resources. Once a community is established in the new reservoir, long6 term effects from operation of the CWSs are not expected to noticeably alter aquatic 

7 communities in the Trinity River and reservoir. 

8 Cumulative Impacts 

9 In the Trinity River drainage basin, from the upstream reaches of the Richland Chambers 

10 Reservoir to the proposed Tennessee Colony Dam site, the aquatic resources have been 

11 heavily influenced over the years by urbanization, municipal water use, wastewater treatment, 

12 industrial use, and impoundments. Water use and discharge of wastewater from Dallas-Fort 

13 Worth area and other municipalities led to significant decline of the water quality as well as fish 

14 kills as recently as 1985 (USGS 2005; STPNOC 2009a). Construction of the off-channel 

15 Richland Chambers Reservoir and Lake Fairfield (for the Big Brown Power Plant) affected the 

16 local aquatic resources during inundation of the areas, and now the aquatic ecology of the local 

17 water ways and the reservoir have adapted to the changes in the water flows. Efforts by TCEQ 

18 and the municipalities have restored much of the aquatic life to the Trinity River (USGS 2005). 

19 Without careful water management of the Trinity River, aquatic resources could be degraded 

20 again. Future proposed projects, (e.g., the proposed Turlington Mine next to the existing Big 

21 Brown Lignite Coal Mine and the proposed Lakeside Energy Center) would increase water use 

22 in the area of interest and affect the aquatic resources in a similar manner to ongoing mining 

23 and power production facilities. The Texas Water Development Board and the Trinity River 

24 Authority have plans for the construction of additional reservoirs in the Trinity River near the 

25 Trinity 2 site. The proposed Tennessee Colony Reservoir would dam the Trinity River 

26 downstream of the Trinity 2 site and connect to the existing Richland Chambers Reservoir, the 

27 proposed Tehuacana Reservoir, and the existing Lake Fairfield (NRC 2009b). Further 

28 evaluations would be needed to determine if the operation of the dam for the Tennessee Colony 

29 Reservoir might affect the sharpnose shiner distribution. Building of these reservoirs would 

30 have a cumulative loss of stream and drainage habitat that would be substantially greater than 

31 the loss of habitat from the building of the cooling reservoir at the Trinity 2 site. 

32 Continued urbanization and agricultural practices could affect aquatic communities in the Trinity 

33 2 geographic area of interest in the foreseeable future. Expansion of urban areas in the Trinity 

34 River drainage could increase water use, decrease available water for aquatic resources, and 

35 increase nonpoint pollution. The effects of continued agricultural practices could result in 

36 additional habitat loss and/or degradation due to irrigation using surface waters and 

37 groundwater withdrawal, point and non-point source pollution, siltation, and bank erosion. 
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1 As mentioned above in the terrestrial section, GCC could result in regional increases in the 

2 frequency of severe weather, decreases in annual precipitation, and increases in average 

3 temperature (Karl et al. 2009). The decrease in precipitation combined with elevated water 

4 temperatures and evaporation could result in more frequent droughts, which could reduce 

5 aquatic habitat. Loss of habitat could cause shifts in species ranges, diversity, and abundance 

6 in the geographic area of interest for the Trinity 2 site (Karl et al. 2009). Specific predictions on 

7 aquatic habitat changes in this region resulting from GCC are inconclusive at this time. 

8 However, because of the regional nature of climate change, the impacts related to GCC would 

9 be similar for all the alternative sites. 

10 Based on building and operation of two new nuclear units at the Trinity 2 alternative site and 

11 other projects and influences in the region of influence for aquatic resources, the cumulative 

12 impacts would be noticeable and possibly destabilizing. All these activities would alter the 

13 aquatic habitats and potentially change the species composition and diversity in the affected 

14 water bodies. The incremental contribution of building and operating the two new reactors, 

15 including building of a cooling water reservoir, at the Trinity 2 site to the cumulative impacts 

16 within the geographic area of interest would be significant. 

17 Summary 

18 STPNOC has indicated that building of the cooling water reservoir at the Trinity 2 site would 

19 inundate existing water bodies and destroy habitat for aquatic resources that are dependent on 

20 flowing water. The review team concludes that the impacts from building two new nuclear units, 

21 including the new cooling water reservoir, at the Trinity 2 site would be noticeable but not 

22 destabilizing to the aquatic resources. The review team also concludes that the impacts from 

23 operation of two new units would be minimal. In the Trinity River drainage basin, from the 

24 upstream reaches of the Richland Chambers Reservoir to the proposed Tennessee Colony 

25 Dam site, the aquatic resources have been heavily influenced over the years by urbanization, 

26 municipal water use, wastewater treatment, industrial use, and impoundments. Based on the 

27 information provided by STPNOC and the review team’s independent evaluation, the review 

28 team concludes that the cumulative impacts of building and operating two new reactors on the 

29 Trinity 2 site combined with other past, present, and future activities on most aquatic resources 

30 in the Trinity River drainage would be MODERATE to LARGE. For the reasons discussed in 

31 Building Impacts and Operational Impacts, the incremental contribution of building and 

32 operating the two new reactors at the Red 2 site to the cumulative impacts within the geographic 

33 area of interest would be significant. 

34 9.3.4.5 Socioeconomics 

35 The following impact analysis includes impacts from building activities and operations. The 

36 analysis also considers other past, present, and reasonably foreseeable future actions that 

37 impact socioeconomics, including other Federal and non-Federal projects listed in Table 9-16. 
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March 2010 9-179 Draft NUREG-1937 

1 For the analysis of socioeconomic impacts at the Trinity 2 site, the geographic area of interest is 

2 considered to be the 50-mi region centered on the Trinity 2 site with special consideration of 

3 Freestone and Anderson Counties as that is where the review team expects socioeconomic 

4 impacts to be the greatest. In evaluating the socioeconomic impacts of site development and 

5 operation at the Trinity 2 site near Fairfield, in Freestone County, the NRC review team 

6 undertook a reconnaissance survey of the site using readily obtainable data from the Internet or 

7 published sources. Impacts from both site development and station operation are discussed. 

8 Physical Impacts 

9 Many of the physical impacts of building and operation would be similar regardless of the site. 

10 Building activities can cause temporary and localized physical impacts such as noise, odor, 

11 vehicle exhaust, vibration, shock from blasting (if used), and dust emissions. The use of public 

12 roadways, railways, and waterways would be necessary to transport construction materials and 

13 equipment. Offsite areas that would support building activities (for example, borrow pits, 

14 quarries, and disposal sites) would be expected to be already permitted and operational. 

15 Potential impacts from station operation include noise, odors, exhausts, thermal emissions, and 

16 visual intrusions (the latter of which are treated under aesthetics and recreation below). New 

17 units would produce noise from the operation of pumps, cooling towers, transformers, turbines, 

18 generators, and switchyard equipment. Traffic at the site also would be a source of noise in 

19 Freestone County. Highway maps show that practical access to the site from the south, west, 

20 and northwest is I-45, then through the town of Fairfield (2000 Census population of 3094) 

21 While practical access from the east and northeast may avoid Fairfield, the patterns of access 

22 routes likely mean that during the building period several thousand additional cars per day may 

23 pass through Fairfield and its eastern outskirts at construction work shift changes, and would 

24 have very noticeable impacts on traffic and traffic noise. Any noise coming from the STP site 

25 would be controlled in accordance with standard noise protection and abatement procedures. 

26 This practice also would be expected to apply to all alternative sites, including the Trinity 2 site. 

27 Commuter traffic would be controlled by speed limits. Good road conditions and appropriate 

28 speed limits would reduce the noise level generated by the workforce commuting to the 

29 alternative site, but there still would likely be very noticeable traffic noise increases in and near 

30 Fairfield. 

31 The new units at the Trinity 2 site would likely have standby diesel generators and auxiliary 

32 power systems. Permits obtained for these generators would ensure that air emissions comply 

33 with applicable regulations. In addition, the generators would be operated on a limited, short34 term basis. During normal plant operation, new units would not use a significant quantity of 

35 chemicals that could generate odors that exceed odor threshold values. Good access roads 

36 and appropriate speed limits would minimize the dust generated by the commuting workforce. 
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Draft NUREG-1937 9-180 March 2010

1 Based on the information provided by STPNOC and the review team’s independent evaluation, 

2 the review team concludes that the physical impacts of building and operating two nuclear units 

3 at the Trinity 2 site would be minimal, except in Freestone County (Fairfield and vicinity), where 

4 increases in traffic noise would be very noticeable during the building period. 

5 Demography 

6 The Trinity 2 site is located in Freestone County 10.4 mi northeast of the city of Fairfield (2008 

7 population 3567) and approximately 20 mi west of Palestine (2008 population 18,129), 

8 Anderson County (2008 population 56,838 [Texas Association of Counties 2009e, f]). After 

9 World War II Freestone County’s population declined up until the 1970’s when it slowly begin to 

10 rise again to its 2008 population of 18,923 (TSHA 2009g). 

11 STPNOC estimated the peak number of construction workers would be 5950. Approximately 

12 900 operations workers would also be onsite during the final phase (i.e., final 10 months) of 

13 building activities (STPNOC 2008c). Based on assumptions in Section 4.4 concerning in14 migration for Units 3 and 4 in Matagorda County, the review team assumed that 50 percent or 

15 2975 construction workers would in-migrate, with half of these moving to Freestone County and 

16 the other half to Anderson County. Eighty percent of in-migrating construction workers would 

17 bring a family. Other counties such as Navarro County would likely see an in-migration of 

18 workers as well, but considering the larger population of this county and the relatively small 

19 number of in-migrants they would be easily absorbed. All operations workers would in-migrate 

20 and all would bring a family. A family size of 3.25 was used for construction workers for a total 

21 peak site development related population increase of 8330 (7735 in-migrating workers and 

22 family members and 595 workers without family). The review team also assumed an average 

23 family size of 2.74 for the operating workforce (see Section 5.4), resulting in a total in-migrating 

24 operations-related population of 2466 (900 operations workers plus family) at the peak of 

25 building activities. Therefore, the total expected in-migrating population at peak building would 

26 be 10,796. 

27 Considering that the maximum estimation of in-migrating population would be almost 30 percent 

28 of Freestone County’s total population and 9 percent of the total population in Anderson County, 

29 the demographic impacts of building activities are expected to be significant in both counties 

30 and potentially destabilizing for Freestone County. If the facility is constructed and commences 

31 operations, the operational workforce would number about 959 workers, 900 of whom would be 

32 at the site during peak site development and are included in the above analysis. The review 

33 team expects that the demographic impact during operation would be minimal. Based on the 

34 information provided by STPNOC and the review team’s independent evaluation, the review 

35 team concludes that the demographic impacts of building would be significant and potentially 

36 destabilizing. The demographic impacts of operating two nuclear units at the Trinity 2 site would 

37 be minimal. 
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March 2010 9-181 Draft NUREG-1937 

1 Taxes and Economy 

2 As discussed in Sections 4.4 and 5.4, in-migrating workers who buy property within the region 

3 would pay property taxes to the respective county, workers would also pay both the state and 

4 county sales and use tax on all eligible purchases as would STPNOC on all eligible purchases 

5 related to the two units. As described in Section 5.4.3.2, STPNOC estimates it would spend 

6 $60 million on annual expenditures for goods and services related to the new units of which 

7 about 20 percent ($12 million) would be spent locally (STPNOC 2008b). STPNOC estimated if 

8 the units were 100 percent taxable, annual franchise taxes for Unit 3 would be $4.7 to $5.4 

9 million and Unit 4 would have payments of $3.9 to $4.7 million, which would represent less than 

10 1 percent of the State’s annual franchise tax revenues. 

11 The largest tax impacts would come from property taxes related to the development and 

12 operation of the two units. The owners of STPNOC would pay taxes to the county, any 

13 applicable special districts that exist within the county and the local school district in which the 

14 land sits in. During the building process, county property tax payments would be based on the 

15 cost of building the units and determined in accordance with state law using mutually agreed on 

16 appraisal formulas (STPNOC 2009a). During operations property taxes would range from $6.10 

17 million to $13.86 million. Taxes from the nuclear plant would represent a 56 to 127 percent 

18 increase over the 2008 Freestone County taxes levied of $10.9 million. 

19 An increased appraised value in the district would increase the tax payments made to Fairfield 

20 ISD. However, Fairfield ISD is a Chapter 41 “wealthy district,” and by State law would have to 

21 pass most, if not all, plant-related property taxes to the State of Texas for redistribution 

22 (TEA 2009). 

23 Under new legislation, Fairfield ISD and Fairfield County would be allowed to enter into an 

24 agreement with the plant owner which would reduce owner’s taxes and allow the ISD and 

25 County to share in the tax savings. The money the district may receive would not be subject to 

26 the state’s equalization laws and would not have to be sent back to the State. If such an 

27 agreement were reached, the tax payments are likely to represent a significant beneficial impact 

28 for both a small, rural county such as Freestone County and for Fairfield ISD. 

29 Economic impacts would be spread across the 50-mi region, but would be greatest in Freestone 

30 and Anderson Counties. Per capita income for Freestone County in 2007 is $26,107 and 

31 $23,399 for Anderson County. The 2008 unemployment rate for Freestone County and 

32 Anderson County was 4.1 percent and 5.7 percent, respectively (Texas Association of Counties 

33 2009e, f). The wages and salaries of the site development and operating workforce would 

34 stimulate the local economies and could provide noticeable and significant impacts for new 

35 businesses to get started and for increased job opportunities for local residents. Based on the 

36 information provided by STPNOC and the review team’s independent evaluation, the review 
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Draft NUREG-1937 9-182 March 2010

1 team concludes that the tax and economic impacts of building and operating two nuclear units 

2 at the Trinity 2 site would be significant and beneficial. 

3 Transportation and Housing 

4 The transportation network in the area includes Interstate 45 (I45), US-84, SH-75 and several 

5 FM roads. Primary commuter access from the south would be from US-84, I-45, and the west 

6 on SH 75 and FM27. Commuters from Palestine and Corsicana could also use US 287 and 

7 FM 488. As discussed under physical impacts, the most practical commuting routes to the 

8 Trinity 2 site from the north, west, and south converge on the city of Fairfield, resulting in a 

9 traffic increase of several thousand cars per day. It is likely that the city of Fairfield would 

10 experience a very noticeable increase in traffic as a result. In addition, Freestone County 

11 population is projected to grow enough to significantly impact traffic, with lower but noticeable 

12 impacts in Anderson County. There are numerous secondary roads near the site, several that 

13 lead to the Big Brown Plant. The only roads that lead to the nearby Trinity 2 site are one lane 

14 unimproved roads. A new access road would need to be built which would likely be from the 

15 west off FM 2570 (STPNOC 2009a). Other major road upgrades would be needed to support 

16 site development. The building of a nuclear plant on the Trinity 2 site would have noticeable 

17 and significant impacts on the local transportation network. 

18 Approximately 3875 construction and operations workers could migrate into the region during 

19 peak building activities. During operations the workforce is expected to be about 959 workers of 

20 which 900 are included in the 3875 workers needing housing during peak building activities. 

21 The most recent data for Freestone County estimated a total housing stock of 8138 units (USCB 

22 2009g) and 19, 243 for Anderson County, with a rental vacancy rate of 5.6 percent. 

23 Approximately 3690 housing units were unoccupied at the time of the survey (USCB 2009h). 

24 Some workers may choose to find other housing such as an apartment while others may in25 migrate with their own housing in the form of a travel trailer. Given Freestone County’s rural 

26 nature and small number of overall housing units, the review team expects that the in-migrating 

27 workforce of 3875 would cause a noticeable and potentially destabilizing impact on the housing 

28 market within the two county socioeconomic impact area and mitigation may be warranted. 

29 Based on the information provided by STPNOC and the review team’s independent evaluation, 

30 the review team concludes that the transportation and housing impacts of building and operating 

31 two nuclear units at the Trinity 2 site would be noticeable and potentially significant. 

32 Public Services and Education 

33 The influx of construction workers and plant operations staff settling in the region could impact 

34 local municipal water and water treatment facilities and other public services in the region. 

35 These impacts would likely be in proportion with the demographic impacts experienced in the 

36 region, unless these resources have excess capacity or are particularly strained during building, 

37 which would decrease or increase the impact, respectively. For example, the largest water 
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March 2010 9-183 Draft NUREG-1937 

1 treatment facilities in Freestone County and Anderson County have water capacity available 

2 that is roughly three to four-and-a-half times current average daily consumption (EPA 2009b, 

3 TCEQ 2010a), so while they may have to build considerable distribution infrastructure they are 

4 unlikely to be water capacity limited. 

5 The in-migrating workers would likely put a temporary strain on public services during peak site 

6 development due to the significant population increases in each county. Therefore, the review 

7 team expects site development-related impacts on public services would be noticeable and 

8 potentially destabilizing, at least in Freestone County. During operations the impact on public 

9 services would be minimal. 

10 Freestone County has 4 independent school districts with 15 schools and Anderson County has 

11 7 independent school districts with 23 schools. The 2007-2008 student enrollments for 

12 Freestone and Anderson County are 3667 students and 8539 students, respectively (NCES 

13 2009). The review team expects a peak site development-related increase of about 2537 

14 students (1269 in each county). The in-migrating students would represent a significant 

15 increase in students in both counties (35 percent in Freestone County and 15 percent in 

16 Anderson County) therefore; the review team expects impacts to educational services would be 

17 significant and potentially destabilizing during peak building activities in at least Freestone 

18 County and possibly in Anderson County. During operations, this impact would reduce to 

19 minimal levels. Based on the information provided by STPNOC and the review team’s 

20 independent evaluation, the review team concludes that the public service and education 

21 impacts of building and operating two nuclear units at the Trinity 2 site would be significant. 

22 Aesthetics and Recreation 

23 Recreation in the area includes the Catfish Creek, Gus Engeling WMA, Big Lake Bottom WMA, 

24 Richland Creek WMA, Richland Chambers Reservoir and Fairfield Lake State Park. Fairfield 

25 Lake State Park is located 2.5 mi southwest of the site and has the most recreational 

26 opportunities. During the winter months fishing tournaments are held every weekend. Other 

27 activities include picnicking, boat ramps, playgrounds, an amphitheater, hiking, biking, 

28 equestrian and bird watching (STPNOC 2009a). The development of transmission lines to 

29 support the site would likely follow the Big Brown corridor, and the aesthetics of the site vicinity 

30 are already degraded by the existence of the Big Brown plant. The review team concludes that 

31 the visual impact associated with building and operating two nuclear units on this site would 

32 have a minimal impact on the aesthetics resources in the area. Increased building-related traffic 

33 to and from the plant could significantly impact recreation at Fairfield Lake State Park during the 

34 building period and would be noticeable in Freestone County; however, the overall impact to 

35 recreation elsewhere would be minimal. Based on the information provided by STPNOC and 

36 the review team’s independent evaluation, the review team concludes that the aesthetic and 

37 recreation impacts of building and operating two nuclear units at the Trinity 2 site would be 

38 minimal. 
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1 Summary of Socioeconomics 

2 Physical impacts on workers and the general public include impacts on existing buildings, 

3 transportation, aesthetics, noise levels, and air quality. Social and economic impacts span 

4 issues of demographics, economy, taxes, infrastructure, and community services. In summary, 

5 on the basis of information provided by STPNOC and the review team’s independent evaluation, 

6 the review team concludes that the socioeconomic impacts of the building of a new nuclear 

7 plant at the Trinity 2 site would be significant and adverse for Anderson County and potentially 

8 destabilizing in Freestone County in terms of demographics, transportation, housing, public 

9 services, and education. Housing impacts during building would be significant and adverse in 

10 Anderson County and probably destabilizing and adverse in Freestone County. These impacts 

11 would be minimal and adverse during operations. Physical impacts (with the exception of 

12 traffic-related noise in Freestone County) and impacts on aesthetics would be minimal in both 

13 counties, but recreation could be noticeably affected during the building period in Freestone 

14 County due to access issues at Fairfield State Park. The impacts on the economy and tax base 

15 during building and operations likely would be beneficial and significant for Freestone County 

16 and beneficial and noticeable in Anderson County. The review team expects all physical and 

17 socioeconomic impacts on other areas within the region would be minimal, except in Freestone 

18 County where the impacts to recreation could be noticeable during building. 

19 Cumulative Impacts 

20 In addition to assessing the incremental socioeconomic impacts from the building and 

21 operations of two additional nuclear units on the Trinity 2 site, the cumulative impact is also 

22 considered. The cumulative analysis considers other past, present, and reasonably foreseeable 

23 future actions that could contribute to the cumulative socioeconomic impacts on a given region, 

24 including other Federal and non-Federal projects and those projects listed in Table 9-16. For 

25 the analysis of socioeconomic impacts at the Trinity 2 site, the geographic area of interest is 

26 considered to be the 50-mi region centered on the Trinity 2 site. 

27 Economic impacts would be spread across the 50-mi region but would be greatest in Freestone 

28 and Anderson Counties. After World War II Freestone County’s population declined up until the 

29 1970’s when it slowly begin to rise again to its current 2008 population of 18,923 (Texas 

30 Association of Counties 2009e). Farming began declining before World War II and continued 

31 for several decades afterwards. During the 1970s and 1980s farming increased as new 

32 businesses also moved into the area. Mining became very important to the area by the late 

33 1980’s. Anderson County’s economy has been based on manufacturing. Oil and gas 

34 discoveries, iron ore deposits, timber regions, and good ranchlands kept the price of farmland 

35 high. Another contributor to the local economy has been the three prison units located near 

36 Fairfield (TSHS 2009g, h). 
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March 2010 9-185 Draft NUREG-1937 

1 Most of the projects identified in Table 9-16 have or would contribute to the impacts on 

2 demographics, economic climate, and community infrastructure of the region and generally 

3 result in increased urbanization and industrialization. However, many impacts such as those on 

4 housing or public services are able to adjust over time, particularly with increased tax revenues. 

5 Furthermore, state and county plans along with modeled demographic projections include 

6 forecasts of future development and population increases. But several of the proposed energy 

7 and mining facilities (for example, the existing Big Brown Mine and the proposed Turlington 

8 Mine, which is expected to be operational in 2011) are close to the Trinity 2 site and have 

9 substantial workforces. Depending on the timing of these proposed activities, the coincidence 

10 of several projects is a potential socioeconomic concern for Freestone County, which could 

11 have to deal with significant impacts from building at the Trinity 2 site while also dealing with 

12 workers from these other projects. Although the projects identified in Table 9-16 would be 

13 consistent with applicable land-use plans and control policies, the review team considers that 

14 managing the cumulative socioeconomic impacts from the projects would be possible but could 

15 be challenging. Tehuacana Reservoir and Tennessee Colony Reservoir projects represent two 

16 reasonably foreseeable activities within close proximity to the Trinity 2 site. While each of those 

17 projects could impose additional socioeconomic impacts, the planned starting and completion 

18 dates and the level of activity for these projects are all uncertain. Therefore, the review team 

19 concluded that for the purposes of this alternative site analysis the socioeconomic impacts of 

20 those two projects could not be quantitatively evaluated. However, although the timing of the 

21 impacts is not known, the review team expects that the following effects may occur should either 

22 reservoir be developed. The review team would expect temporary increases in economic 

23 activity, population, and traffic during the construction period; and decreases in the existing 

24 property tax base, which may or may not be offset by values of recreational development, and 

25 other improvements related to reservoirs. In addition, during reservoir operations, depending on 

26 the level of development (and population), there may be increases in the demand for 

27 infrastructure and community services. There is a possibility that recreational opportunities 

28 would increase. 

29 In summary, on the basis of information provided by STPNOC and the review team’s 

30 independent evaluation, the review team concludes that the cumulative socioeconomic impacts 

31 during the building of a new nuclear plant at the Trinity 2 site would be MODERATE and 

32 adverse for Anderson County and LARGE and adverse for Freestone County in terms of 

33 demographics, transportation, housing, public services, and education. These impacts would 

34 be SMALL and adverse during operations. Cumulative impacts on aesthetics and recreation 

35 and physical impacts in Freestone County would be MODERATE and adverse during the 

36 building period and SMALL and adverse elsewhere. Impacts on aesthetics would be SMALL. 

37 These impacts would all be SMALL and adverse during operations. The cumulative impacts on 

38 economy and tax base during building and operations likely would be beneficial and LARGE in 

39 Freestone County and beneficial and SMALL to MODERATE in Anderson County. The review 

40 team expects all cumulative physical 
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Draft NUREG-1937 9-186 March 2010

1 and socioeconomic impacts on other areas within the region would be SMALL. Building and 

2 operating a new plant at the Trinity 2 site would make a significant, incremental contribution to 

3 these impact levels. 

4 9.3.4.6 Environmental Justice 

5 The following impact analysis includes impacts from building activities and operations. The 

6 analysis also considers other past, present, and reasonably foreseeable future actions that 

7 impact environmental justice, including other Federal and non-Federal projects listed in Table 9-

8 16. The cumulative environmental justice impacts were assessed for the 50-mi region centered 

9 on the Trinity 2 site, with allowance made for counties downstream in case offsite surface water10 related impacts were identified for any human population. In 2000, the 50 mi region around the 

11 Trinity 2 site was characterized as 14.2 percent Black, 0.5 percent American Indian and Alaskan 

12 Native, 0.4 percent Asian, 0.07 percent Hawaiian and Other Pacific Islander, 5.6 percent all 

13 other races, and 1.3 percent two or more races, 10.2 percent Hispanic or Latino and 12.3 

14 percent low-income (STPNOC 2009a). 

15 The 2000 Census block groups were used for ascertaining minority and low-income populations 

16 in the region. There were a total of 282 census blocks groups within the 50-mi region, 41 of 

17 which were classified as minority populations (2 of them in Freestone County and 8 of them in 

18 Anderson County). One of these populations in Anderson County is within 10 mi of the Trinity 2 

19 alternative site. There are 14 census block groups classified as low income in the 50-mi region, 

20 none of which are in Freestone County and 2 in Anderson County. None of these populations is 

21 within 10 mi of the Trinity 2 alternative site, but there are minority populations on both sides of 

22 the Trinity River downstream from the Trinity 2 site. The review team does not know if they are 

23 dependent on the river for water supply or if they are engaged in subsistence activity. See 

24 Figure 9-15 and Figure 9-16 for the location of minority or low-income populations within the 50-

25 mi region. 

26 The review team’s analysis did not find any information suggesting that minority or low income 

27 populations in the area were dependent on natural resources that would be adversely affected 

28 by a nuclear power plant at the Trinity 2 alternative site. 

29 Physical impacts during building (noise, fugitive dust, air emissions, traffic) would not 

30 disproportionately adversely affect minority populations because of their distance from the 

31 Trinity 2 site. However, the operation of the proposed project at the Trinity 2 site may have a 

32 disproportionate adverse impact on minority or low-income populations due to impacts on 

33 surface water supplies. Surface water-related impacts during operations were described in 

34 Section 9.3.4.2 as at least noticeable and adverse because of ambiguity concerning available 

35 water rights on the Trinity River and concerns about the water available to downstream users. 

36 See Sections 4.5 and 5.5 for more information about environmental justice criteria and impacts. 
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March 2010 9-187 Draft NUREG-1937 

1 

2 Figure 9-15. Minority Block Groups within 50 mi of the Trinity 2 Alternative Site
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1 

2 Figure 9-16. Low-Income Block Groups within 50 mi of the Trinity 2 Alternative Site 
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March 2010 9-189 Draft NUREG-1937 

1 With the possible exception of the Big Brown Power Plant, 2.6 mi west of the Trinity 2 site, the 

2 existing projects identified in Table 9-16 are not likely to have disproportionately and adversely 

3 affected minority and low-income populations of the region. Neither Big Brown nor its 

4 associated mining operations are close to minority or low income populations, but they are 

5 significant employers. If additional major construction projects such as the proposed 

6 Tehuacana Reservoir and Tennessee Colony reservoir projects commence at the same time as 

7 building new nuclear units at the Trinity 2 site, that could cause a greater general rise in rental 

8 rates than that due to one project alone, but it is not clear whether any general rent increase 

9 would have a disproportionate and adverse impact on rental prices experienced by low-income 

10 populations or whether these populations would be uniquely impacted due to their lower 

11 household budgets. 

12 Based on information provided on water use by STPNOC and the review team’s independent 

13 reconnaissance evaluation, MODERATE impacts to surface water resources and aquatic 

14 resources are expected in the region of the Trinity 2 site downstream from the site. However, 

15 the review team did not find any information suggesting that the minority populations located 

16 downstream near the Trinity 2 site had any disproportionate dependence on the Trinity River for 

17 water supply and subsistence activities. Accordingly, the review team concludes that the 

18 environmental justice impacts from locating the proposed project at the Trinity 2 site would be 

19 SMALL and adverse. 

20 9.3.4.7 Historic and Cultural Resources 

21 The following impact analysis includes impacts from building activities and operations. The 

22 analysis also considers other past, present, and reasonably foreseeable future actions that 

23 impact historic and cultural resources, including other Federal and non-Federal projects listed in 

24 Table 9-16. For the analysis of cultural impacts at the Trinity 2 site, the geographic area of 

25 interest is considered to be the APE that would be defined for this site. This includes the 

26 physical APE, defined as the area directly affected by the site development and operation 

27 activities at the site and transmission lines, and the visual APE. The visual APE is defined as 

28 an additional 1-mi radius around the physical APE consistent with the discussion in Section 2.7 

29 about the maximum distance from which the structures can be seen. 

30 Reconnaissance activities in a cultural resource review have particular meaning. Typically, for 

31 example, it includes preliminary field investigations to confirm the presence or absence of 

32 cultural resources. However, in developing its EISs, the review team relies upon 

33 reconnaissance-level information to perform its alternative site evaluation. Reconnaissance34 level information is data that are readily available from agencies and other public sources. It 

35 can also include information obtained through visits to the site area. To identify the historic and 

36 cultural resources at the Trinity 2 site, the following information was used: 
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Draft NUREG-1937 9-190 March 2010

1 • STPNOC ER (STPNOC 2009a) - including the Texas Historical Commission’s Texas 

2 Archeological Sites Atlas; and 

3 • NRC Alternative Sites Visit August 2009. 

4 The Trinity 2 site is located in Freestone County, Texas, and is a greenfield site. Historically, 

5 the site and vicinity were largely undisturbed and likely contained intact archaeological sites 

6 associated with the past 10,000 years of human settlement. Over time, the area has been 

7 disturbed by rural development and cleared for agricultural purposes. The physical and 

8 visual APEs if the proposed plant were to be sited at the Trinity 2 site do not appear to have any 

9 historic properties likely to be affected by building or operating new units (STPNOC 2009a). No 

10 archaeological and/or architectural surveys have been conducted at the Trinity 2 site. 

11 One historic structure, a railroad depot and office building, listed on the National Register of 

12 Historic Places is found in Freestone County. It is located approximately 10 mi away from the 

13 site. Eleven archaeological sites have been recorded within a 2-mi radius of the Trinity 2 site, 

14 the closest of which is within 0.5 mi, and several cemeteries are located nearby (STPNOC 

15 2009a). None of the cemeteries are listed on the National Register. The project has the 

16 potential to affect resources through visual impacts from buildings and transmission lines. 

17 Should such properties be subsequently listed on the National Register, then these impacts may 

18 result in significant alterations to the visual landscape within the geographic area of interest. 

19 To accommodate building two new nuclear generating units on the Trinity 2 site, STPNOC 

20 would need to clear approximately 800 ac for the main power plant site and up to 1700 ac for a 

21 new reservoir (STPNOC 2009a). In the event that the Trinity 2 site was chosen for the 

22 proposed project, identification of cultural resources would be accomplished through cultural 

23 resource surveys and consultation with the SHPO, tribes and interested parties. The results 

24 would be used in the site planning process to avoid cultural resources impacts. In the event 

25 significant cultural resources were identified by these surveys, the review team assumes that 

26 STPNOC would develop protective measures in a manner similar to those for the STP site. 

27 These procedures are detailed in STPNOC’s Addendum #5 to procedure No. OPGP03-ZO28 0025 Rev. 12 (Unanticipated Discovery of Cultural Resources) (STPNOC 2008e); the procedure 

29 includes notification of THC. 

30 Section 9.3.4.1 describes the transmission line corridors. There are no existing transmission 

31 corridors connecting directly to the Trinity 2 site. However, there are multiple 345-kV 

32 transmission lines connecting to the Big Brown Power Plant (STPNOC 2009a). A new 

33 transmission corridor would need to be created to connect the Trinity 2 site to these lines. In the 

34 event that the Trinity 2 site was chosen for the proposed project, the review team assumes that 

35 STPNOC would conduct its transmission line-related cultural resource surveys and procedures 

36 in a manner similar to that for the STP site described in Section 4.6. 
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1 Past actions in the geographic area of interest that have similarly impacted historic and cultural 

2 resources include rural development and agricultural development and activities associated 

3 with these land disturbing activities such as road development. Two planned projects, the 

4 Tehuacana Reservoir and the Tennessee Colony Reservoir, were identified in Table 9-16 that 

5 may contribute to cumulative impacts on historic and cultural resources in the geographic area 

6 of interest. Activities associated with building two nuclear units and supporting facilities that can 

7 potentially destabilize important attributes of historic and cultural resources include land 

8 clearing, excavation, and grading activities. Given STPNOC’s site planning process and no 

9 known cultural resources at the Trinity 2 site based on reconnaissance-level information, the 

10 impacts to cultural resources due to site development activities would be negligible. 

11 In addition, visual impacts from transmission lines may result in significant alterations to the 

12 visual landscape within the geographic area of interest. Given that there are no known 

13 cultural resources where the historic setting and character of the resources are important, 

14 the visual impacts would be negligible. The review team assumes that STPNOC would 

15 develop procedures and consult with the SHPO similar to the process developed for 

16 cultural resource management at the STP site. 

17 Impacts on historic and cultural resources from operation of two new nuclear generating units at 

18 the Trinity 2 site include those associated with the operation of new units and maintenance of 

19 transmission lines. The review team assumes that the same procedures currently used by 

20 STPNOC would be used for onsite and offsite maintenance activities. Consequently, the 

21 incremental effects of the maintenance of transmission-line corridors and operation of the two 

22 new units and associated impacts on the cultural resources would be negligible for the physical 

23 and visual APEs. 

24 No past, present, or future actions in the geographic area of interest were identified that would 

25 significantly affect historic and cultural resources in a manner similar to those associated with 

26 the operation of two new units. 

27 The two projects that were identified in Table 9-16 that could contribute to the cumulative 

28 impacts on cultural resources are the Tehuacana Reservoir and the Tennessee Colony 

29 Reservoir. Neither reservoir would significantly affect historic and cultural resources since there 

30 are no known resources in the geographic area of interest; the impacts would be limited to the 

31 visual APE and would be similar to those associated with the operation of two new units. 

32 Cultural resources are non-renewable; therefore, the impact of destruction of cultural resources 

33 is cumulative. Based on the information provided by the applicant and the review team’s 

34 independent evaluation, the review team concludes that the cumulative impacts from building 

35 and operating two new nuclear generating units on the Trinity 2 site and from other projects 

36 particularly the planned adjacent Tennessee Colony Reservoir, would be SMALL. This impact 

37 level determination reflects no known cultural resources that could be affected; however, if the 
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Draft NUREG-1937 9-192 March 2010

1 Tennessee Colony Reservoir or the Trinity 2 site were to be developed, then cultural resource 

2 surveys may reveal important historic properties that could result in greater cumulative impacts. 

3 9.3.4.8 Air Quality 

4 The following impact analysis includes impacts from building activities and operations. The 

5 analysis also considers other past, present, and reasonably foreseeable future actions that 

6 impact air quality, including other Federal and non-Federal projects listed in Table 9-16. The 

7 atmospheric emissions related to building and operating a nuclear power plant at the STP site in 

8 Matagorda County, Texas, are described in Chapters 4 and 5. The criteria pollutants were 

9 found to have a SMALL impact. In Chapter 7, the cumulative impacts of the criteria pollutants at 

10 the STP site were evaluated and determined to be MODERATE principally because of a nearby 

11 major source; absent that source, the cumulative impacts would be SMALL. The geographic 

12 area of interest for the Trinity 2 site is Freestone County, which is in the Austin-Waco Intrastate 

13 Air Quality Control Region (40 CFR 81.134). The emissions related to building and operating a 

14 nuclear power plant at the Trinity 2 site would be similar to those at the STP site. The air quality 

15 attainment status for Freestone County as set forth in 40 CFR 81.344 reflects the effects of past 

16 and present emissions from all pollutant sources in the region. Freestone County is not out of 

17 attainment of any National Ambient Air Quality Standard. 

18 Reflecting on the projects listed in Table 9-16, the most significant are the Big Brown Power 

19 Plant, Freestone Energy Center, Lakeside Energy Center, and the Limestone Electric 

20 Generating Station. Effluents from power plants such these are typically released through 

21 stacks and with significant vertical velocity. Other industrial projects listed in Table 9-16 would 

22 have de minimis impacts. Given that these projects would be subject to institutional controls, it 

23 is unlikely that the air quality in the region would degrade to the extent that the region would be 

24 in nonattainment of National Ambient Air Quality Standards. 

25 The air quality impact of Trinity 2 site development would be local and temporary. The distance 

26 from building activities to the site boundary would be sufficient to generally avoid significant air 

27 quality impacts. There are no land uses or projects, including the aforementioned source, that 

28 would have emissions during site development that would, in combination with emissions from 

29 the Trinity 2 site, result in degradation of air quality in the region. 

30 Releases from operation of two units at the Trinity 2 site would be intermittent and made at low 

31 levels with little or no vertical velocity. The air quality impacts of the Big Brown Power Plant, 

32 Freestone Energy Center, and Units 1 and 2 of the Limestone Electric Generating Station are 

33 included in the baseline air quality status. The air quality impacts of the Lakeside Energy 

34 Center would be similar to the air quality impacts discussed in Section 9.2.2.2, and the air 

35 quality impacts of Unit 3 of the Limestone Electric Generating Station would be similar to the air 

36 quality impacts discussed in Section 9.2.2.1, which could be noticeable but not destabilizing. 
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March 2010 9-193 Draft NUREG-1937 

1 The cumulative impacts from emissions of effluents from the Trinity 2 site and the 

2 aforementioned sources could be noticeable but not destabilizing. 

3 The cumulative impacts of greenhouse gas emissions related to nuclear power are discussed in 

4 Section 7.5. The impacts of the emissions are not sensitive to location of the source. 

5 Consequently, the discussion in Section 7.5 is applicable to a nuclear power plant located at the 

6 Trinity 2 site. The review team concludes that the national and worldwide cumulative impacts of 

7 greenhouse gas emissions are noticeable but not destabilizing. The review team further 

8 concludes that the cumulative impacts would be noticeable but not destabilizing, with or without 

9 the greenhouse gas emissions of the project at the Trinity 2 site. 

10 Cumulative impacts to air quality resources are estimated based in the information provided by 

11 STPNOC and the review team’s independent evaluation. Other past, present and reasonably 

12 foreseeable future activities exist in the geographic areas of interest (local for criteria pollutants 

13 and global for greenhouse gas emissions) that could affect air quality resources. The 

14 cumulative impacts on criteria pollutants from emissions of effluents from the Trinity 2 site, other 

15 projects, the Big Brown Power Plant, Freestone Energy Center, Lakeside Energy Center, and 

16 the Limestone Electric Generating Station would be noticeable but not destabilizing, principally 

17 as a result of the contribution of Unit 3 of the Limestone Electric Generating Station. The 

18 national and worldwide cumulative impacts of greenhouse gas emissions are noticeable but not 

19 destabilizing. The review team concludes that the cumulative impacts would be noticeable but 

20 not destabilizing, with or without the greenhouse gas emissions from the Trinity 2 site. The 

21 review team concludes that cumulative impacts from other past, present, and reasonably 

22 foreseeable future actions on air quality resources in the geographic areas of interest would be 

23 MODERATE for criteria pollutants and MODERATE for greenhouse gas emissions. The 

24 incremental contribution of impacts on air quality resources from building and operating two 

25 units at the Trinity 2 site would be insignificant for both criteria pollutants and greenhouse gas 

26 emissions. 

27 9.3.4.9 Nonradiological Health 

28 The following impact analysis includes impacts from building activities and operations. The 

29 analysis also considers other past, present, and reasonably foreseeable future actions that 

30 impact nonradiological health, including other Federal and non-Federal projects listed in 

31 Table 9-16. The building-related activities that have the potential to impact the health of 

32 members of the public and workers include exposure to dust and vehicle exhaust, occupational 

33 injuries, noise, and the transport of construction materials and personnel to and from the site. 

34 The operation-related activities that have the potential to impact the health of members of the 

35 public and workers includes exposure to etiological agents, noise, EMFs, and impacts from the 

36 transport of workers to and from the site. For the analysis of nonradiological health impacts at 

37 the Trinity 2 alternative site, the geographic area of interest is considered to include projects 

38 within a 5 mi radius from the site’s center based on the localized nature of the impacts. For 
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Draft NUREG-1937 9-194 March 2010

1 impacts associated with transmission lines, the geographic area of interest is the transmission 

2 line corridor. 

3 Building Impacts 

4 Nonradiological health impacts to construction workers and members of the public from building 

5 two new nuclear units at the Trinity 2 site would be similar to those evaluated in Section 4.8 for 

6 the STP site. The impacts include noise, vehicle exhaust, dust, occupational injuries, and 

7 transportation accidents, injuries, and fatalities. Applicable Federal and State regulations on air 

8 quality and noise would be complied with during the site preparation and building phase. The 

9 incidence of construction worker accidents would not be expected to be different from the 

10 incidence of accidents estimated for STP. The Trinity 2 site is located in a rural area and 

11 building impacts would likely be negligible on the surrounding populations. The ER (STPNOC 

12 2009a) indicated that there may be significant impacts on the transportation network in the 

13 vicinity of the Trinity 2 site and mitigation would be warranted. The impacts in the vicinity of the 

14 Trinity 2 site include traffic associated with the Big Brown Power Plant and lignite mine and the 

15 Fairfield Lake State Park. Interactions between the traffic destined for the Trinity 2 site during 

16 building and these other projects are likely to increase the nonradiological health effects from 

17 traffic accidents in the vicinity. The additional injuries and fatalities from traffic accidents 

18 involving transportation of materials and personnel for building of a new nuclear power plant at 

19 the Trinity 2 site would be similar to those evaluated in Section 4.8.3 for the STP site and would 

20 represent a small fraction (less than 5 percent) of the total traffic fatalities in Freestone County. 

21 Past and present actions in the geographic areas of interest that have similarly affected 

22 nonradiological resources include the construction and operation of the Big Brown Power Plant 

23 and the Big Brown Lignite Coal Mine. Proposed future actions would include transmission line 

24 development and/or upgrading throughout the designated geographic area of interest, and 

25 future urbanization. These actions would likely result in nonradiological health impacts similar to 

26 those discussed above for the building of the Trinity 2 site. 

27 Operational Impacts 

28 Nonradiological health impacts from operation of two new nuclear units on occupational health 

29 and members of the public at the Trinity 2 site would be similar to those evaluated in Section 5.8 

30 for the STP site. Occupational health impacts to workers (e.g., falls, electric shock or exposure 

31 to other hazards) at the Trinity 2 site would likely be the same as those evaluated for workers at 

32 two new units at the STP site. Exposure to the public from water-borne etiological agents at the 

33 Trinity site would be similar to the types of exposures evaluated in Section 5.8.1, and the 

34 operation of the new units at the Trinity 2 site would not likely lead to an increase in water-borne 

35 diseases in the vicinity. Noise and EMF exposure would be monitored and controlled in 

36 accordance with applicable OSHA regulations. Effects of EMF on human health would be 

37 controlled and minimized by conformance with NESC criteria and adherence to the standards for 
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March 2010 9-195 Draft NUREG-1937 

1 transmission systems regulated by the PUCT. Nonradiological impacts of traffic associated with 

2 the operations workforce would be less than the impacts during building. Mitigation measures 

3 taken during building to improve traffic flow would also minimize impacts during operation, 

4 The past and present activities in the geographic areas of interest that would have 

5 nonradiological impacts to the public or workers similar to those discussed for the Trinity 2 site 

6 include the Big Brown Power Plant and the Big Brown Lignite Coal Mine. Noise from the 

7 operation of the Trinity 2 site would not likely be discernable to the public at the Fairfield Lake 

8 State Park, which is closest to the Big Brown Power Plant. Proposed future actions that would 

9 impact nonradiological health in a similar way to operation activities at the Trinity 2 site would 

10 include transmission line systems and future urbanization, which would both occur throughout 

11 the designated geographic areas of interest. 

12 The review team is also aware of the potential climate changes that could affect human health; 

13 a recent compilation of the state of the knowledge in this area (Karl et al. 2009) has been 

14 considered in the preparation of this EIS. Projected changes in the climate for the region 

15 include an increase in average temperature and a decrease in precipitation, which may alter the 

16 presence of microorganisms and parasites in any reservoir that would be used. The review 

17 team did not identify anything that would alter its conclusion regarding the presence of 

18 etiological agents or change in the incidence of water-borne diseases. 

19 Summary 

20 Based on the information provided by STPNOC and the review team’s independent evaluation, 

21 the review team expects that nonradiological health impacts from building and operating two 

22 new units at the Trinity 2 alternative site would be similar to the impacts evaluated for the STP 

23 site. While there are past, present and future activities in the geographic area of interest that 

24 could affect nonradiological health in ways similar to the building and operation of two units at 

25 the Trinity 2 site, those impacts would be localized and managed through adherence to existing 

26 regulatory requirements. The review team concludes, therefore, that the cumulative impacts 

27 would be SMALL. 

28 9.3.4.10 Radiological Impacts of Normal Operations 

29 The following impact analysis includes radiological impacts to the public and workers from 

30 building activities and operations for two nuclear units at the Trinity 2 alternative site. The 

31 analysis also considers other past, present, and reasonably foreseeable future actions that 

32 impact radiological health, including other Federal and non-Federal projects and those projects 

33 listed in Table 9-16. As described in Section 9.3.4, the Trinity 2 site is a greenfield site; there 

34 are currently no nuclear facilities on the site. The geographic area of interest is the area within 

35 a 50-mi radius of the Trinity 2 site. There are no major facilities that result in regulated 

36 exposures to the public or biota within the 50-mi radius of the Trinity 2 site. However, there are 
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1 likely to be hospitals and industrial facilities within 50 mi of the Trinity 2 site that use radioactive 

2 materials. 

3 The radiological impacts of building and operating the proposed two ABWR units at the Trinity 2 

4 site include doses from direct radiation and liquid and gaseous radioactive effluents. These 

5 pathways would result in low doses to people and biota offsite that would be well below 

6 regulatory limits. These impacts are expected to be similar to those estimated for the STP site. 

7 The NRC staff concludes that the dose from direct radiation and effluents from hospitals and 

8 industrial facilities that use radioactive material would be an insignificant contribution to the 

9 cumulative impact around the Trinity 2 site. This conclusion is based on data from the 

10 radiological environmental monitoring programs conducted around currently operating nuclear 

11 power plants. 

12 Based on the information provided by STPNOC and the NRC staff's independent analysis, the 

13 NRC staff concludes that the cumulative radiological impacts from building and operating the 

14 two proposed ABWRs and other existing and planned projects and actions in the geographic 

15 area of interest around the Trinity 2 site would be SMALL. 

16 9.3.4.11 Postulated Accidents 

17 The following impact analysis includes radiological impacts from postulated accidents from 

18 operations for two nuclear units at the Trinity 2 alternative site. The analysis also considers 

19 other past, present, and reasonably foreseeable future actions that impact radiological health 

20 from postulated accidents, including other Federal and non-Federal projects and those projects 

21 listed in Table 9-16. As described in Section 9.3.4, Trinity 2 is a greenfield site; there are 

22 currently no nuclear facilities on the site. The geographic area of interest considers all existing 

23 and proposed nuclear power plants that have the potential to increase the probability-weighted 

24 consequences (i.e., risks) from a severe accident at any location within 50 mi of the Trinity 2 

25 site. There are no existing or proposed reactors that have the potential to increase the 

26 probability-weighted consequences (i.e., risks) from a severe accident at any location within 50 

27 mi of the Trinity 2 site. 

28 As described in Section 5.11.1, the NRC staff concludes that the environmental consequences 

29 of DBAs at the STP site would be minimal for ABWRs. DBAs are addressed specifically to 

30 demonstrate that a reactor design is robust enough to meet NRC safety criteria. The ABWR 

31 design is independent of site conditions, and the meteorology of the Trinity 2 and STP sites are 

32 similar; therefore, the NRC staff concludes that the environmental consequences of DBAs at the 

33 Trinity 2 site would be minimal. 

34 Because the meteorology, population distribution, and land use for the Trinity 2 alternative site 

35 are expected to be similar to the proposed STP site, risks from a severe accident for an ABWR 

36 reactor located at the Trinity 2 alternative site are expected to be similar to those analyzed for 
 Environmental Impacts of Alternatives 

March 2010 9-197 Draft NUREG-1937 

1 the proposed STP site. These risks for the proposed STP site are presented in Tables 5-18 and 

2 5-19 and are well below the median value for current-generation reactors. In addition, estimates 

3 of average individual early fatality and latent cancer fatality risks are well below the 

4 Commission’s safety goals (51 FR 30028). On this basis, the NRC staff concludes that the 

5 cumulative risks of severe accidents at any location within 50 mi of the Trinity 2 alternative site 

6 would be SMALL. 

7 9.3.5 Comparison of the Impacts of the Proposed Action and Alternative Sites 

8 This section summarizes the review team’s characterization of the cumulative impacts related to 

9 locating a two-unit ABWR nuclear power facility at the proposed STP site and at each 

10 alternative site. The three sites selected for detailed review as part of the alternative sites 

11 environmental analysis are the Red 2, Allens Creek, and Trinity 2 sites in Texas. Comparisons 

12 are made between the proposed and alternative sites to evaluate if one of the alternative sites 

13 would be environmentally preferable to the proposed site. The NRC’s determination is 

14 independent of the Corps’ determination of a Least Environmentally Damaging Practicable 

15 Alternative pursuant to the Clean Water Act Section 404(b)(1) Guidelines at 40 CFR Part 230. 

16 The Corps will conclude its analysis of both off-site and on-site alternatives in its Record of 

17 Decision. The Corps onsite alternatives evaluation is discussed in Section 9.5. 

18 The need to compare the proposed site with alternative sites arises from the requirement in 

19 Section 102(2)(c)(iii) of NEPA (42 USC 4332) that environmental impact statements include an 

20 analysis of alternatives to the proposed action. The NRC criteria to be employed in assessing 

21 whether a proposed site is to be rejected in favor of an alternative site is based on whether the 

22 alternative site is “obviously superior” or “environmentally preferable” to the site proposed by the 

23 applicant (Public Service Company of New Hampshire 1977). An alternative site is “obviously 

24 superior” to the proposed site if it is “clearly and substantially” superior to the proposed site 

25 (Rochester Gas & Electric Corp. 1978). The standard of obviously superior “...is designed to 

26 guarantee that a proposed site will not be rejected in favor of an alternate unless, on the basis 

27 of appropriate study, the Commission can be confident that such action is called for (New 

28 England Coalition on Nuclear Pollution 1978).” 

29 The “obviously superior” test is appropriate for two reasons. First, the analysis performed by the 

30 NRC in evaluating alternative sites is necessarily imprecise. Key factors considered in the 

31 alternative site analysis, such as population distribution and density, hydrology, air quality, 

32 aquatic and terrestrial ecological resources, aesthetics, land use, and socioeconomics are 

33 difficult to quantify in common metrics. Given this difficulty, any evaluation of a particular site 

34 must have a wide range of uncertainty. Second, the applicant’s proposed site has been 

35 analyzed in detail, with the expectation that most adverse environmental impacts associated 

36 with the site have been identified. The alternative sites have not undergone a comparable level 

37 of detailed study. For these reasons, a proposed site may not be rejected in favor of an 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-198 March 2010

1 alternative site when the alternative site is marginally better than the proposed site, but only 

2 when it is obviously superior (Rochester Gas & Electric Corp. 1978). NEPA does not require 

3 that a nuclear plant be constructed on the single best site for environmental purposes. Rather, 

4 “...all that NEPA requires is that alternative sites be considered and that the effects on the 

5 environment of building the plant at the alternative sites be carefully studied and factored into 

6 the ultimate decision (New England Coalition on Nuclear Pollution 1978).” 

7 Section 9.3.5.1 reviews the cumulative environmental impacts of building and operating a two8 unit nuclear power plant at the proposed STP site. Cumulative impact levels from Chapter 7 (for 

9 the proposed STP site), and the three alternative sites (from Sections 9.3.2 through 9.3.4) are 

10 listed in Table 9-20. Sections 9.3.5.2 and 9.3.5.3 discuss the cumulative impacts of the 

11 proposed project located at the STP site and at the alternative sites as they relate to a 

12 determination of environmental preference or obvious superiority. 

13 9.3.5.1 Comparison of Cumulative Impacts at the Proposed and Alternative Sites 

14 The following section summarizes the review team’s independent assessment of the proposed 

15 and alternative sites. The team characterized the expected cumulative environmental impacts 

16 of building and operating new units at the STP site and alternative sites; these impacts are 

17 summarized by resource area in Table 9-20 on the following page. 

18 The environmental resource areas listed in the following table have been evaluated using the 

19 NRC’s three-level standard of impact significance: SMALL, MODERATE, or LARGE. These 

20 levels were developed using the CEQ guidelines and set forth in the footnotes to Table B-1 of 

21 10 CFR Part 51, Subpart A, Appendix B: 

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

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

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

25 destabilize, important attributes of the resource. 

26 LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

27 important attributes of the resource. 

28 Full explanations for the specific cumulative impact characterizations are provided in Chapter 7 

29 for the proposed site and in Sections 9.3.2, 9.3.3, and 9.3.4 for the alternative sites. The review 

30 team’s impact category levels are based on professional judgment, experience, and 

31 consideration of controls likely to be imposed under required Federal, State, or local permits that 

32 would not be acquired until an application for a COL is underway. The considerations and 

33 assumptions were similarly applied at each of the alternative sites to provide a common basis 

34 for comparison. In the following discussion, the review team compares the impact levels 

35 between the proposed site, and each alternative site. 
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March 2010 9-199 Draft NUREG-1937 

1 

2 Table 9-20. Comparison of Cumulative Impacts at the Proposed and Alternative Sites

Resource Area STP Red 2 Allens Creek Trinity 2 

Land-Use MODERATE MODERATE MODERATE MODERATE 

Water-Related 

 Surface Water Use MODERATE MODERATE MODERATE MODERATE 

 Surface Water Quality MODERATE SMALL SMALL MODERATE 

Groundwater Use SMALL MODERATE SMALL MODERATE 

Groundwater Quality SMALL SMALL to 

MODERATE 

SMALL SMALL 

Ecology 

 Terrestrial Ecosystems MODERATE MODERATE MODERATE MODERATE 

 Aquatic Ecosystems MODERATE MODERATE MODERATE MODERATE 

to LARGE 

Socioeconomic* 

 Physical SMALL SMALL LARGE SMALL to 

MODERATE 

 Demography SMALL to 

MODERATE 

SMALL to 

MODERATE 

MODERATE 

to LARGE 

MODERATE 

to LARGE 

 Taxes and Economy SMALL to 

LARGE 

BENEFICIAL 

 SMALL to 

LARGE 

BENEFICIAL 

SMALL to 

LARGE 

BENEFICIAL 

SMALL to 

LARGE 

BENEFICIAL 

 Housing and Transportation SMALL to 

MODERATE 

SMALL to 

MODERATE 

 MODERATE 

to LARGE 

 MODERATE 

to LARGE 

 Public Services and Education SMALL to 

MODERATE 

SMALL to 

LARGE 

MODERATE 

to LARGE 

MODERATE 

to LARGE 

 Aesthetics and Recreation SMALL to 

MODERATE 

SMALL to 

MODERATE 

LARGE SMALL to 

MODERATE 

Environmental Justice SMALL SMALL SMALL to 

LARGE 

SMALL 

Historic and Cultural Resources SMALL SMALL LARGE SMALL 

Air Quality MODERATE SMALL to 

MODERATE 

SMALL to 

MODERATE 

 MODERATE 

Nonradiological Health SMALL SMALL SMALL SMALL 

Radiological Health SMALL SMALL SMALL SMALL 

Postulated Accidents SMALL SMALL SMALL SMALL 

*ranges indicate differences in counties 
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Draft NUREG-1937 9-200 March 2010

1 9.3.5.2 Environmentally Preferable Sites 

2 As shown in Table 9-20, the cumulative impacts of building and operating two new units at the 

3 proposed site and the alternative sites vary across the impact categories. The resource 

4 categories for which the impact level at an alternative site is the same as that for the proposed 

5 site does not contribute to the alternative site being judged to be environmentally preferable to 

6 the proposed site. Therefore, these categories are not discussed further in determining whether 

7 an alternate site is environmentally preferable to the proposed site. The categories for which an 

8 alternative site has a different impact level than the proposed site are discussed further to 

9 determine if an alternative site is environmentally preferable to the proposed site. Where there 

10 is a range of impacts for a resource, the upper value of the impacts is used for the comparison. 

11 In addition, for those cases in which the cumulative impacts for a resource are greater than 

12 SMALL, consideration is given to those cases in which the impacts of the project at the specific 

13 site do not make any significant contribution to the cumulative impact level. As shown in 

14 Table 9-20, there are some differences in impacts among the sites. 

15 Red 2 Site

16 The STP site is characterized more favorably than the Red 2 site in Table 9-20 for the following 

17 resource areas: groundwater use and quality and public services and education. The Red 2 

18 site is characterized more favorably than the STP site for surface water quality and air quality. 

19 For the resource areas for which the STP site is characterized more favorably, building and 

20 operating two new nuclear units at the Red 2 site would be a significant contributor to the higher 

21 impact level. Therefore, the differences in impacts for these two resource areas are meaningful 

22 to the comparison of the sites. For surface water quality, the MODERATE impact at the STP 

23 site is based on pre-existing conditions. Building and operating two new nuclear units at the 

24 STP would not contribute significantly to surface water quality impacts. For air quality at both 

25 sites, the MODERATE impacts are based on the effects of projects other than the nuclear units. 

26 Nuclear plants don’t contribute significantly to air quality impacts. So the apparent differences in 

27 impacts for these resources are not meaningful in terms of the proposed action. 

28 For land use, surface water use, and terrestrial and aquatic ecosystems, although the two sites 

29 have essentially the same cumulative impact levels, the two new nuclear units would not be a 

30 significant contributor to the impact level at the STP site. This is because a reservoir already 

31 exists at the STP site, and there would be little in-water construction in the Colorado River. The 

32 project would be a significant contributor to the MODERATE cumulative impacts to these 

33 resources at the Red 2 site because it is a greenfield site with no existing facilities to be shared 

34 with new units. A similar situation exists for aesthetics and recreation – the project would not be 

35 a significant contributor to the SMALL to MODERATE impacts at the STP site, but it would be at 

36 the Red 2 site. Again, these differences favor the STP site. 
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March 2010 9-201 Draft NUREG-1937 

1 Based on the results and comparison of the impact characterizations, the review team 

2 concludes that the Red 2 site would not be environmentally preferable to the STP site for two 

3 new nuclear generating units. 

4 Allens Creek Site

5 The STP site is characterized more favorably than the Allens Creek site in Table 9-20 for the 

6 following resource areas: physical impacts, demography, housing and transportation, public 

7 services and education, aesthetics and recreation, environmental justice, and historic and 

8 cultural resources. Conversely, the Allens Creek site is characterized by the review team as 

9 more favorable than the STP site in Table 9-20 for surface water quality and air quality. For 

10 physical and environmental justice impacts, the primary reason for the higher impacts at the 

11 Allens Creek site is the proposed Trans-Texas Corridor. Building and operating two new 

12 nuclear units at the Allens Creek site would not contribute significantly to the impact levels. For 

13 the remainder of the impact areas for which the STP is characterized more favorably, building 

14 and operating two new nuclear units at the Allens Creek site is a significant contributor to the 

15 higher impact levels, and so the differences in impact levels are meaningful to the comparison 

16 of the sites. For surface water quality, the MODERATE impact at the STP site is based on pre17 existing conditions. Building and operating two new nuclear units at the STP would not 

18 contribute significantly to surface water quality impacts. For air quality at both sites, the 

19 MODERATE impacts are based on the effects of projects other than the nuclear units. Nuclear 

20 plants don’t contribute significantly to air quality impacts. So the apparent differences in impacts 

21 for these resources are not meaningful in terms of the proposed action. 

22 For land use and terrestrial ecosystems, although the two sites have essentially the same 

23 cumulative impact levels, the two new nuclear units would not be a significant contributor to the 

24 impact level at the STP site (i.e., the MODERATE impacts are based on the effects of other 

25 projects). This is because a reservoir already exists at the STP site and there would be little in26 water construction in the Colorado River. But the project would be a significant contributor to 

27 the MODERATE cumulative impacts for these resources at the Allens Creek site because it is a 

28 greenfield site with no existing facilties to be shared with new units. 

29 Based on comparison of the impact characterizations in Table 9-20, the review team concludes 

30 that the Allens Creek site would not be environmentally preferable to the STP site for two new 

31 nuclear generating units. 

32 Trinity 2 Site

33 The STP site is characterized more favorably than the Trinity 2 site in Table 9-20 for the 

34 following resource areas: groundwater use, aquatic ecosystems, physical impacts, demography, 

35 housing and transportation, and public services and education. Conversely, the Trinity 2 site is 

36 not characterized by the review team as more favorable than the STP site in Table 9-20 for any 
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Draft NUREG-1937 9-202 March 2010

1 resource area. For physical impacts, the higher impacts at the Trinity 2 site relate to other 

2 projects in the area and the project at the Trinity 2 site would not contribute significantly to the 

3 impact level. For all of the other impact areas for which the STP site is characterized more 

4 favorably, the differences relate directly to the impacts of the proposed project at the two sites. 

5 For land use, surface water use, and terrestrial ecosystems, although the two sites have 

6 essentially the same cumulative impact levels, the two new nuclear units would not be a 

7 significant contributor to the impact level at the STP site. This is because a reservoir already 

8 exists at the STP site and there would be little in-water construction in the Colorado River. But 

9 the project would be a significant contributor to the MODERATE cumulative impacts for these 

10 resources at the Trinity 2 site because it is a greenfield site with no existing facilities to be 

11 shared with new units. 

12 Based on comparison of the impact characterizations in Table 9-20, the review team concludes 

13 that the Trinity 2 site would not be environmentally preferable to the STP site for two new 

14 nuclear generating units. 

15 Although there are differences and distinctions between the cumulative environmental impacts 

16 of building and operating two new nuclear generating units at the proposed STP site and the 

17 alternative sites, the review team concludes that none of these differences is sufficient to 

18 determine that any of the alternative sites would be environmentally preferable to the proposed 

19 site for building of two new nuclear generating units. 

20 9.3.5.3 Obviously Superior Sites 

21 None of the alternative sites were determined to be environmentally preferable to the proposed 

22 STP site. Therefore, the NRC staff concludes that none of the alternative sites would be 

23 obviously superior to the STP site. The Corps will conclude its analysis of both offsite and 

24 onsite alternatives in its Record of Decision. 

25 9.4 System Design Alternatives 

26 The NRC staff considered a variety of heat dissipation systems and circulating water systems 

27 alternatives. While other heat dissipation systems and water systems exist, by far the largest 

28 and the most likely to dominate the environmental consequences of operation is the CWS that 

29 cools and condenses the steam for the turbine-generator. Other water systems, such as 

30 service water system, are much smaller than the CWS. As a result, the review team only 

31 considers alternative heat dissipation and water treatment systems for the CWS. The proposed 

32 CWS is a closed loop system that uses the existing MCR for heat dissipation (STPNOC 2009a). 

33 The proposed system is discussed in detail in Chapter 3. 
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March 2010 9-203 Draft NUREG-1937 

1 9.4.1 Heat Dissipation Systems 

2 About two-thirds of the heat from a commercial nuclear reactor is rejected as heat to the 

3 environment. The remaining one-third of the reactor’s generated heat is converted into 

4 electricity. Normal heat sink cooling systems transfer the rejected heat load into the 

5 atmosphere and/or nearby water bodies, primarily as latent heat exchange (evaporating water) 

6 or sensible heat exchange (warmer air or water). Different heat-dissipation systems rely on 

7 different exchange processes. The following sections describe alternative heat dissipation 

8 systems considered by the NRC staff for proposed Units 3 and 4 at the STP site. 

9 The impacts associated with the proposed heat dissipation system, a cooling pond or reservoir, 

10 are discussed in Sections 4.2, 4.3, 5.2, and 5.3. STPNOC proposes to use the existing MCR as 

11 the heat dissipation system for the proposed units. The NRC staff determined in Chapter 4 that 

12 the impacts of building the proposed heat dissipation system would be SMALL for both 

13 hydrologic and ecological resources. The NRC staff also determined in Chapter 5 that the 

14 impacts of operating the proposed heat dissipation system would be SMALL for both hydrologic 

15 and ecological resources. 

16 STPNOC considered a range of heat dissipation systems in its ER including a once-through 

17 cooling system and several closed-cycle cooling systems. In addition to the closed-cycle MCR 

18 selected, STPNOC also considered spray canals, mechanical draft wet cooling towers, natural 

19 draft wet cooling towers, a combination wet/dry cooling tower system, fan-assisted natural draft 

20 cooling towers and dry cooling towers (STPNOC 2009a). The NRC staff considered these 

21 options as well as once-through cooling with a helper tower cooling system that would be used 

22 under high receiving water body temperature conditions. 

23 9.4.1.1 Plant Cooling System – Once-Through Operation 

24 Once-through cooling systems withdraw water from the source water body and return virtually 

25 the same volume of water to the receiving water body at an elevated temperature. Typically the 

26 source water body and the receiving water body are the same body, and the intake and 

27 discharge structures are separated to limit recirculation. While there is essentially no 

28 consumptive use of water in a once-through heat-dissipation system, the elevated temperature 

29 of the receiving water body would result in some induced evaporative loss that decreases the 

30 net water supply. The large intake and discharge flows associated with once-through cooling 

31 systems require large intake and discharge structures; the high flow rates may result in 

32 hydrological alterations in the source/receiving water bodies. In addition, the high flow rates 

33 result in higher levels of impingement and entrainment of aquatic organisms. Based on U.S. 

34 EPA 316(b) Phase I regulations (66 FR 65255), the NRC staff has determined that once35 through cooling systems for new nuclear reactors are unlikely to be permitted in the future, 

36 except in rare and unique situations. 
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Draft NUREG-1937 9-204 March 2010

1 The STP site is approximately 10 mi from the Matagorda Bay on the Gulf of Mexico (STPNOC 

2 2009a), the closest body of water that potentially could support once-through cooling. The NRC 

3 staff determined that once-through cooling would not be an environmentally preferable 

4 alternative because of the magnitude of the impacts of building large intake and discharge 

5 structures and associated piping linking these structures with the plant. Furthermore, once6 through cooling would require a significant volume of makeup water and could potentially have 

7 significant impacts on sensitive aquatic biota of Matagorda Bay. 

8 9.4.1.2 Spray Canals 

9 Spray canal cooling systems circulate water in man-made canals and enhance evaporative 

10 cooling by spraying water into the atmosphere. In addition to evaporation, heat transfer from 

11 the spray canals to the atmosphere also occurs through black-body radiation and conduction. A 

12 spray canal system alternative was evaluated by STPNOC for cooling STP Units 1 and 2 and 

13 was found to require an effective canal length of 20,250 ft and a width of 200 ft which would 

14 require 150 ac. An additional 680 acres would be required for the intake canal corridor 

15 (STPNOC 2009a). The NRC staff independently evaluated the system design requirements 

16 and determined that the size and dimensions were calculated consistent with the heat rejection 

17 requirements. Since the evaporation from a new spray canal would be greater than the induced 

18 evaporation of the existing MCR, the consumptive water use of a spray canal would be greater 

19 than the proposed alternative. Because no additional land would need to be disturbed for the 

20 proposed alternative and because of increased consumptive use of water in a spray canal the 

21 NRC staff concluded that use of a spray canal would not be an environmentally preferable 

22 alternative for the STP site. 

23 9.4.1.3 Wet Mechanical Draft Cooling Towers 

24 A wet mechanical draft cooling tower transfers heat to the environment via evaporation and 

25 conduction. These towers can be relatively low profile compared to natural draft towers, and 

26 rely on large fans to force air through walls of falling water. Drift abatement features in the 

27 design limit the amount of water suspended as droplets in the air, which may be deposited on 

28 the ground outside the tower. Wet mechanical draft towers often generate visible plumes when 

29 the moisture in air from the cooling tower exhaust cools and the moisture condenses. 

30 This alternative would require six towers to be built (three towers for each unit), each containing 

31 12 cells. STPNOC indicates that approximately 70 ac would be required for the towers and an 

32 additional 630 ac would be required for the intake canal corridor (STPNOC 2009a). The NRC 

33 staff independently evaluated the system design requirements and determined that the size and 

34 dimensions were calculated consistent with the heat rejection requirements. Since the 

35 evaporation of a wet mechanical draft cooling tower is greater than the induced evaporation of a 

36 cooling pond, the consumptive water use of a wet mechanical draft cooling tower is greater than 

37 the proposed alternative. Therefore, based on consideration of the land area that would be 
 Environmental Impacts of Alternatives 

March 2010 9-205 Draft NUREG-1937 

1 disturbed and the increase in consumptive water use, the NRC staff concluded that building and 

2 operating wet mechanical draft cooling towers would not be an environmentally preferable 

3 alternative for the STP site. 

4 9.4.1.4 Wet Natural Draft Cooling Towers 

5 Wet natural draft cooling towers induce airflow up through large (500 ft tall and 400 ft in 

6 diameter) towers by cascading warm water downward in the lower portion of the cooling tower. 

7 As heat transfers from the water to the air in the tower, the air becomes more buoyant and rises. 

8 This buoyant circulation induces more air to enter the tower through its open base. The size of 

9 the cooling towers results both in a large visual and land-use footprint. STPNOC indicates that 

10 approximately 80 ac would be required for the towers and an additional 630 ac would be 

11 required for the intake canal corridor (STPNOC 2009a). The NRC staff independently evaluated 

12 the system design requirements and determined that the size and dimensions were calculated 

13 consistent with the heat rejection requirements. Since the evaporation of a wet natural draft 

14 cooling tower is greater than the induced evaporation of a cooling pond, the consumptive water 

15 use of a wet natural draft cooling tower is greater than the proposed alternative. Therefore, 

16 based on consideration of the land area that would be disturbed for the tower footprints, the 

17 increase in consumptive water use, and the available cooling capacity of the existing cooling 

18 reservoir to dissipate heat for two additional units, the NRC staff concluded that building and 

19 operating wet natural draft cooling towers would not be an environmentally preferable 

20 alternative for the STP site. 

21 9.4.1.5 Dry Cooling Towers 

22 Dry cooling towers would eliminate all water-related impacts from the cooling system operation. 

23 No makeup water would be needed, and no blowdown water would be generated. However, 

24 dry cooling systems require much larger cooling systems, and result in both a loss in electrical 

25 generation efficiency (because the theoretical approach temperature is limited to the dry-bulb 

26 temperature and not the lower wet-bulb temperature) and greater parasitic energy losses for the 

27 large array of fans involved. This loss in generation efficiency translates into increased fuel 

28 cycle impacts. Because the impacts associated with aquatic ecology, water use, and water 

29 quality for the proposed cooling system were found to be SMALL (see Chapters 4 and 5), the 

30 NRC staff determined that, although dry cooling eliminates water-related impacts, it is not 

31 environmentally preferred to the proposed alternative. 

32 9.4.1.6 Combination Wet/Dry Cooling Tower System 

33 A combination mechanical draft wet/dry cooling tower system uses both wet and dry cooling 

34 cells to limit consumption of cooling water, often with the added benefit of reducing plume 

35 visibility. Water used to cool the turbine generators generally passes first through the dry 

36 portion of the cooling tower where heat is removed by drawing air at ambient temperature over 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-206 March 2010

1 tubes through which the water is moving. Cooling water leaving the dry portion of the tower 

2 then passes through the wet tower where the water is sprayed into a moving air stream and 

3 additional heat is removed through evaporation and sensible heat transfer. When ambient air 

4 temperatures are low, the dry portion of these cooling towers may be sufficient to meet cooling 

5 needs. The use of the dry portion of the system would result in a loss in generating efficiency 

6 that would translate into increased fuel cycle impacts. Although a combination mechanical draft 

7 wet/dry cooling tower system could reduce water-related impacts, the NRC staff determined that 

8 the impacts associated with aquatic ecology, water use, and water quality for the building and 

9 operating the proposed cooling system were SMALL. The NRC staff concluded that building 

10 and operating a combination wet/dry cooling tower system would not be an environmentally 

11 preferable alternative for the STP site. 

12 9.4.2 Circulating Water Systems 

13 The NRC staff evaluated alternatives to the proposed intakes and discharges for the normal 

14 heat sink cooling system, based on the proposed heat dissipation system water requirements. 

15 The capacity requirements of the intake and discharge system are defined by the recommended 

16 heat dissipation system. For Units 3 and 4, the proposed heat dissipation system is a closed17 loop system that uses the existing MCR for heat dissipation. 

18 9.4.2.1 Intake Alternatives 

19 The impacts associated with the proposed intake system, the RMPF, are discussed in Sections 

20 4.2, 4.3, 5.2, and 5.3. STPNOC proposes to use the existing RMPF as the intake system for the 

21 proposed units. The review team determined in Chapter 4 that the impacts of building the 

22 proposed intake system would be SMALL for both hydrologic and ecological resources. The 

23 review team determined in Chapter 5 that the impacts of operating the proposed intake system 

24 would be SMALL for both hydrologic and ecological resources. 

25 The existing intake structure, the RMPF, for the STP site was originally designed to support four 

26 units. As a result, no additional excavation and building is required to meet the needs of the two 

27 proposed units. The existing intake structure would be refurbished with new pumps and 

28 traveling screens in the existing structure (STPNOC 2009a). A redesigned intake structure that 

29 extends into the river or radial collector wells are alternatives to the current structure for 

30 obtaining makeup water for the MCR. 

31 An intake structure that extends into the river has an advantage if other structures on the 

32 shoreline would conflict with a shoreline intake or if bathymetry or vegetation considerations 

33 make a shoreline intake less desirable. At the STP site, the conditions that would make an 

34 offshore intake advantageous do not occur. Offshore intakes with submerged passive screens 

35 are also more difficult to maintain. The shoreline option is preferable to an offshore intake 

36 because the intake structure is already in place. 
 Environmental Impacts of Alternatives 

March 2010 9-207 Draft NUREG-1937 

1 A radial collector-well system was considered by the NRC staff because in many cases it 

2 reduces the impact on aquatic resources and, when water is being withdrawn from turbid 

3 environments can reduce the water treatment needed before its introduction into the cooling 

4 system. A radial collector-well system consists of an excavated central concrete caisson with 

5 well screens projected laterally outward in a radial pattern (Riegert 2006). Radial collector wells 

6 slowly draw surface water through the subsurface layer and, thereby, filter out some sediment 

7 that might have required treatment if the water had been directly withdrawn from the surface 

8 water body. In general, collecting surface water in this way eliminates most of the direct 

9 operational impacts on aquatic ecosystems (e.g., entrainment and impingement) associated 

10 with water withdrawal. The NRC staff determined that radial collector wells, which would induce 

11 flow through the sediments of the Colorado River into lateral subterranean pipes extending from 

12 the shoreline out beneath the reservoir, would require multiple large structures near the 

13 shoreline. STPNOC did not consider this alternative water source, but the NRC staff 

14 independently determined that a radial collector-well system is not environmentally preferable to 

15 the proposed direct withdrawal from the river due to the environmental impacts associated with 

16 excavating the caissons, drilling the laterals and building the multiple new shoreline structures, 

17 and because the impacts associated with aquatic ecology for the proposed intake have been 

18 determined to be SMALL in Chapters 4 and 5. 

19 Because the RMPF already exists, the NRC staff concludes that there would be no alternative 

20 intake designs that would be environmentally preferable to the proposed intake design for the 

21 STP site. 

22 9.4.2.2 Discharge Alternatives 

23 The impacts associated with the proposed discharge system are discussed in Sections 4.2, 4.3, 

24 5.2, and 5.3. STPNOC proposes to use the existing discharge system as the discharge system 

25 for the proposed units. The review team determined in Chapter 4 that the impacts of building 

26 the proposed discharge system would be SMALL for both hydrologic and ecological resources. 

27 The review team determined in Chapter 5 that the impacts of operating the proposed discharge 

28 system would be SMALL for both hydrologic and ecological resources. 

29 The MCR discharges to the Colorado River through the existing discharge structure. This 

30 system includes a 1.1-mi-long discharge line that extends downstream along the river bank. 

31 Releases to the river would occur through one or more of seven discharge ports (STPNOC 

32 2009a). The review team determined that the impacts of operation of this system would be 

33 SMALL and that any other alternative would result in land disturbing and in-water activities. 

34 Therefore, the NRC staff concluded that there were no alternative discharge designs that would 

35 be environmentally preferable to the proposed discharge design at the STP site. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-208 March 2010

1 9.4.2.3 Water Supplies 

2 The impacts associated with the proposed water supply, the Colorado River, are discussed in 

3 Sections 4.2, 4.3, 5.2, and 5.3. Since the applicant does not propose to use surface water for 

4 building the proposed units, the review team determined in Chapter 4 that the impacts of 

5 building the proposed units would be SMALL for both hydrologic and ecological resources. The 

6 review team determined in Chapter 5 that the impacts of withdrawing water to operate the 

7 proposed units would be SMALL for both hydrologic and ecological resources. 

8 The NRC staff considered alternative sources for the circulating water system including water 

9 reuse, groundwater, and surface water, including both freshwater and saltwater. 

10 Water Reuse 

11 Sources of water for reuse can either come from the plant itself or from other local water users. 

12 Sanitary waste water treatment plants generally used by communities with modest sized 

13 populations are the most ubiquitous source of water for reuse. Agricultural processing, 

14 industrial processing, and oilfield production can also provide significant supplies of water for 

15 reuse. Additional treatment (e.g., tertiary treatment, chlorination) may be required to provide 

16 water of appropriate quality for the specific plant need. Population is very low and there is little 

17 industry around the STP site. Consequently, the NRC staff determined that sufficient sources of 

18 water for reuse do not exist near the STP site. Therefore, the NRC staff concluded that water 

19 reuse would not be a feasible alternative for water supply at the STP site. 

20 Groundwater 

21 STPNOC proposes to use groundwater for the Ultimate Heat Sink (UHS) system during 

22 operation, but not the circulating water system. The UHS system discharges to the MCR 

23 resulting in approximately 500 gpm of groundwater being made available to make up for 

24 evaporative losses from the MCR. The NRC staff did consider groundwater as an alternative 

25 water source for the remainder of the makeup water for the circulating water system. Existing 

26 groundwater wells at the STP site are limited to a pumping rate of 500 gpm under the Coast 

27 Plains Groundwater Conservation District Operating Permit and must be separated by 2500 ft 

28 from neighboring Deep Aquifer wells. The review team estimated that withdrawal of the 

29 quantities of water needed to supply makeup water to the circulating water system (22,799 gpm 

30 for normal operating conditions, 47,489 gpm maximum) would require 95 wells for the maximum 

31 demand case. Based on the size of the existing STP site the review team concluded that it is 

32 not possible to locate this number of wells on the existing STP site under the rules of the 

33 groundwater well operating permit. The review team estimates that if 100 wells were placed in 

34 a square grid separated by 2500 ft, it would require more than 18 square mi. 
 Environmental Impacts of Alternatives 

March 2010 9-209 Draft NUREG-1937 

1 The STPNOC states (STPNOC 2008b) that the Lower Colorado Regional Water Planning 

2 Group (LCRWPG) is currently making plans for the conjunctive use of groundwater and surface 

3 water to effectively use and preserve available water resources. The planning group advocates 

4 the combined use of these two resources in ways that would minimize the use of groundwater 

5 when surface water is available and that would manage aquifers for sustainable yield (LCRWPG 

6 2006). The water management plans document an interest in minimizing the use of 

7 groundwater rather than utilization. Because it would take an additional 95 wells to meet the 

8 maximum demand for makeup water for cooling and water management plans for this region 

9 call for minimizing the use of groundwater, the NRC staff determined that groundwater use for 

10 CWS makeup water would not be an environmentally preferable alternative for water supply at 

11 the STP site. 

12 Surface water 

13 Surface water supplies at the STP site are saltwater from Matagorda Bay, brackish water from 

14 the estuarine portion of the Colorado River or fresh water from the Colorado River upstream of 

15 the dam at Bay City. 

16 Use of salt water from the Matagorda Bay would require a new intake structure to be built and 

17 an 18-mi pipeline to transport the water from the Bay to the STP site to be installed (STPNOC 

18 2009a). To obtain fresh water from the Colorado River upstream of the Fabridam near Bay City 

19 would also require a new intake structure and a pipeline to transport the water between the 

20 intake and the STP site to be built. The NRC staff determined that, while there is an abundant 

21 supply of water from Matagorda Bay and from the Colorado River upstream of the Fabridam, 

22 selection of either of these two alternatives would result in environmental impacts in many 

23 resource areas due to the construction of intake structures and the associated pipelines. 

24 Therefore, the NRC staff concluded that none of the surface water supply alternatives is 

25 environmentally preferable for the proposed water source for STP site. 

26 9.4.2.4 Water Treatment 

27 Both inflow and effluent water may require treatment to ensure that it meets plant water needs 

28 and effluent water standards. STPNOC proposes to add chemicals to plant water to meet 

29 appropriate water quality process needs. The effluent water chemistry is regulated by the 

30 TCEQ through the TPDES permitting process. Mechanical treatment may be a viable option for 

31 scale and biofilm removal. Other alternatives to manage biofouling, such as UV treatment, are 

32 also feasible. These alternatives, while feasible, would not eliminate the need for some 

33 chemical treatment. Chemical treatment is a reliable and well-established engineering practice 

34 that has been shown to provide minimal impacts in a variety of settings. The NRC staff 

35 identified no environmentally preferable alternative to STPNOC’s proposed chemical water 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-210 March 2010

1 treatment. The effluents from cooling tower blowdown are specifically regulated in 40 CFR 423 

2 by the EPA to protect the environment. In the State of Texas, this regulatory authority is 

3 administered by the TCEQ. 

4 9.4.3 Conclusion 

5 The NRC staff considered alternative systems designs including seven alternative heat 

6 dissipation systems and alternative intake, discharge, and water supply systems. As discussed 

7 in the above sections, the NRC staff identified no alternative that was environmentally 

8 preferable to the proposed plant systems design. 

9 9.5 Corps’ Onsite Alternatives Evaluation 

10 A key provision of the 404(b)(1) guidelines is the “practicable alternative test” that requires that 

11 “no discharge of fill material shall be permitted if there is a practicable alternative to the 

12 proposed fill which would have a less adverse impact on the aquatic ecosystem” [40CFR 

13 230.10(a)]. This is especially true when the proposed project is not water-dependent. The 

14 applicant must demonstrate that there are no less-damaging alternatives available and that all 

15 onsite impacts to waters of the United States have been avoided to the maximum practicable 

16 extent possible. For an alternative to be considered “practicable,” it must be available and 

17 capable of being done after taking into consideration cost, existing technology, and logistics in 

18 light of the overall project purpose. STPNOC proposes to construct an off-loading facility and 

19 heavy haul roads for oversized equipment associated with the construction and operation of the 

20 proposed nuclear power generation facility. 

21 9.5.1 Onsite Alternative 1

22 Onsite alternative 1 uses a railway system as ingress for large equipment and use of existing 

23 roads within the STP facility to offload and transport heavy materials. This alternative would 

24 require the construction of 12 mi of rail line, which may cost between $10 and $15 million. 

25 Construction of the railway may require up to a 100-ft right-of-way, or 145 ac, which may include 

26 impacts to waters, uplands, and public infrastructure such as overhead utility lines, potable 

27 water, and sewer lines. Use of existing roads to transport materials after offloading from the 

28 railcars would be strictly limited due to safety concerns to human health and risk. 

29 9.5.2 Onsite Alternative 2

30 Onsite alternative 2 includes barging material up the existing Colorado River Navigation 

31 Channel, but not dredging the existing barge terminal. In this alternative, a large crane would 

32 be used to offload material from the barges, which could be located within the Colorado River. 
 Environmental Impacts of Alternatives 

March 2010 9-211 Draft NUREG-1937 

1 The cost of the crane is estimated to be $12 million. Barge traffic staged in the river for 

2 offloading may impede commercial and recreational navigation in the river during staging and 

3 offloading. Use of upgraded roads to transport materials after offloading from the barge would 

4 be strictly limited due to safety concerns to human health and risk. Limited impacts to waters, 

5 uplands, or public infrastructure are anticipated by this alternative. 

6 9.5.3 Onsite Alternative 3 (STPNOC’s Preferred Alternative)

7 Onsite alternative 3 uses a combination of barging material up the existing Colorado River 

8 Navigation Channel, upgrading existing barge slips to unload heavy equipment and construction 

9 of a heavy haul road within the STP facility. The existing barge slips are silted-in and would 

10 require dredging and rehabilitation before use. STPNOC has proposed to increase the capacity 

11 of the barge slips to accommodate larger barges. Excavation and dredging of material would be 

12 conducted utilizing mechanical dredge methods and all materials would be placed in an existing 

13 upland dredge material placement area located onsite. Offloading of material would occur 

14 within the barge slip, and no impacts to navigation are expected during staging and offloading. 

15 A heavy haul road would be constructed from the barge slip to the construction site. The heavy 

16 haul road would require six culverted crossings within channelized streams. Properly sized and 

17 placed culverts may result in both positive and negative stream impacts. Culverts may disrupt 

18 the geomorphology of the stream, but also provide shade for aquatic species. The streams 

19 proposed for crossing are channelized and devoid of riparian buffer. The estimated cost of 

20 excavation and expansion of the existing barge slip and construction of the heavy haul road is 

21 $1 million. 

22 9.6 References 

23 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 

24 Production and Utilization Facilities." 

25 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 

26 Protection Regulations for Domestic Licensing and Related Regulatory Functions." 

27 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 

28 Certifications, and Approvals for Nuclear Power Plants." 

29 35 Tex. Reg. 249. January 8, 2010. “Threatened and Endangered Nongame Species.” Texas 

30 Register. Texas Parks and Wildlife Department. 

31 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

32 "National Primary and Secondary Ambient Air Quality Standards." 
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Draft NUREG-1937 9-212 March 2010

1 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 

2 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans." 

3 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 

4 "Standards of Performance for New Stationary Sources." 

5 40 CFR Part 63. Code of Federal Regulations, Title 40, Protection of Environment, Part 63, 

6 "National Emission Standards for Hazardous Air Pollutants for Source Categories." 

7 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

8 "Designation of Areas for Air Quality Planning Purposes." 

9 40 CFR Part 230. Code of Federal Regulations, Title 40, Protection of Environment, "Section 

10 404(B)(1)Guidelines for Specification of Disposal Sites for Dredged or Fill Materials." 

11 40 CFR Part 423. Code of Federal Regulations, Title 40, Protection of the Environment, Part 

12 423, "Steam Electric Power Generating Point Source Category." 

13 40 CFR Parts 1500 - 1518. Code of Federal Regulations, Title 40, Protection of Environment, 

14 Parts 1500- 1518 "National Environmental Policy Act.” 

15 51 FR 30028. August 21, 1986. “Safety Goals for the Operations of Nuclear Power Plants; 

16 Policy Statement.” Federal Register. U.S. Nuclear Regulatory Commission. 

17 65 FR 32214. May 22, 2000. “Notice of Regulatory Determination on Wastes from the 

18 Combustion of Fossil Fuels.” Federal Register. U.S. Environmental Protection Agency. 

19 66 FR 65255. December 18, 2001. “National Pollutant Discharge Elimination System: 

20 Regulations Addressing Cooling Water Intake Structures for New Facilities. Federal Register. 

21 U.S. Environmental Protection Agency. 

22 Benson, K.L.P. and K.A. Arnold. 2001. The Texas Breeding Bird Atlas. Texas A&M University 

23 System, College Station and Corpus Christi, Texas. Accessed October 23, 2009 at 

24 http://tbba.cbi.tamucc.edu. Accession No. ML100640755. 

25 Bluebonnet Groundwater Conservation District.(BGCD). 2004. Groundwater Management Plan 

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27 Navasota, Texas. 

28 Brazos River Authority (Brazos). 2009. Allens Creek Reservoir. Accessed November 12, 2009 

29 at http://www.brazos.org/acrHome.asp. Accession No. ML100640755. 
 Environmental Impacts of Alternatives 

March 2010 9-213 Draft NUREG-1937 

1 Brazos River Authority (Brazos). 2010. Allens Creek Reservoir Timeline. Accessed January 22, 

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3 Brown, WM. 1993. Avian Collisions with Utility Structures: Biological Perspectives. In 

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8 Clean Air Act. 42 USC 7401, et seq. 

9 Coastal Zone Management Act (CZMA). 16 USC 1451, et seq. 

10 CPS Energy (CPS). 2009. “CPS Energy Outlines Its Commitment to Sustainability.” Accessed 

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13 Cushing, C.E., and J.D. Allen. 2001. Streams: Their Ecology and Life. Academic Press, San 

14 Diego, California. Accession No. ML100640755. 

15 Davis, W.B. and D.J. Schmidly. 1994. The Mammals of Texas. Accessed October 15, 2009 at 

16 http://www.nsrl.ttu.edu/tmot1/Default.htm. Accession No. ML100640755. 

17 Electric Reliability Council of Texas (ERCOT). 2008. An Update on the ERCOT Market. 

18 Accessed February 19, 2009 at 

19 http://www.ercot.com/content/news/presentations/2009/KahnBizComm11-18-08.pdf. Accession 

20 No. ML100640755. 

21 Electric Reliability Council of Texas (ERCOT). 2009. “Company Profile.” Accessed November 

22 5, 2009, at http://www.ercot.com/about/profile/index.html. Accession No. ML100640755. 

23 Electric Power Research Institute (EPRI). 2002. Siting Guide: Site Selection and Evaluation 

24 Criteria for an Early Site Permit Application. Product ID: 1006878, EPRI, Palo Alto, California. 

25 Endangered Species Act (ESA). 16 USC 1531, et seq. 

26 Erickson, WP, GD Johnson, and DP Young, Jr. 2005. A Summary and Comparison of Bird 

27 Mortality from Anthropogenic Causes with an Emphasis on Collisions. USDA Forest Service 

28 General Technical Report, PSW-GTR-191. 

29 Exelon Generation (Exelon). 2009. Letter from Marilyn C. Kray (Exelon Generation Vice 

30 President, Project Development) to U.S. Nuclear Regulatory Commission, "Subject: Exelon 
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1 Nuclear Texas Holdings, LLC, Victoria County Station, Early Site Permit Application Expected 

2 Submission Date, NRC Project Number 0781." October 13, 2009. Accession No. 

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4 Fairfield Recorder (Fairfield). 2009. New Gas Power Plant Planned Near Richland-Chambers. 

5 Accessed December 18, 2009 at http://www.thefairfieldrecorder.net/news/2009-02-

6 05/front_page/001.html. Accession No. ML100640755. 

7 Federal Water Pollution Control Act (Clean Water Act). 33 USC 1251, et seq. 

8 Gabbard A. 1993. “Coal Combustion: Nuclear Resource or Danger,” Oak Ridge National 

9 Laboratory Review. Summer/Fall 1993. Oak Ridge National Laboratory, Oak Ridge, 

10 Tennessee. Accessed February 23, 2009 at http://www.ornl.gov/ORNLReview/rev26-

11 34/text/colmain.html. Accession No. ML100640755. 

12 Gelwick, F.P., and R.Y. Li. 2002. Mesohabitat Use and Community Structure of Brazos River 

13 Fishes in the Vicinity of the Proposed Allens Creek Reservoir. Texas Water Development 

14 Board Interagency Contract Number 2001-483-376. Texas Parks and Wildlife Department, 

15 Austin, Texas. 

16 Gentry, RR. 1997. An Overview of the Reclamation Program at the Big Brown Lignite Mine. 

17 Presented at the 1997 National Meeting of the American Society for Surface Mining and 

18 Reclamation, Austin Texas. Accessed November 20, 2009 at 

19 http://www.docstoc.com/docs/15730949/An-Overview-of-the-Reclamation-Program-at-the-Big. 

20 Accession No. ML100640755. 

21 Global Scholar. 2008. Schoolfinder - Brazos ISD : Overview & Information. Accessed on 

22 January 12, 2009 at http://www.globalscholar.com/schoolfinder/district/16530-brazos23 isd/overview-information.aspx. Accession No. ML100640755. 

24 R.W. Harden & Associates, Inc., 2007. Northern Trinity/Woodbine GAM Assessment of 

25 Groundwater Use in the Northern Trinity Aquifer due to Urban Growth and Barnett Shale 

26 Development. Prepared for the Texas Water Development Board. Austin, Texas. January 

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28 Hassan-Williams, C., and T.H. Bonner. 2009. Texas Freshwater Fishes. Texas State 

29 University-San Marcos, Biology Department, Aquatic Station, San Marcos, Texas. Accessed 

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32 Houston Metropolitan Research Center (HMRC). 2009. Allens Creek Nuclear Generating Plant 

33 Collection: An Inventory of Records at the Houston Metropolitan Research Center, Houston 
 Environmental Impacts of Alternatives 

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1 Public Library. Accessed November 12, 2009 at 

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3 ML100640755. 

4 Hudson Products. 2009. Company Profile. Accessed March 4, 2010 at 

5 http://www.hudsonproducts.com. Accession No. ML100640755. 

6 Linam, G.W., L.J. Kleinsasser, and K.B. Mayes. 2002. Regionalization of the Index of Biotic 

7 Integrity for Texas Streams. River Studies Report No. 17, Texas Parks & Wildlife Department, 

8 Resource Protection Division. 

9 Lower Colorado Regional Water Planning Group (LCRWPG). 2006. Region “K” Water Plan for 

10 the Lower Colorado Regional Water Planning Group. Accessed June 22, 2009 at 

11 http://www.twdb.state.tx.us/rwpg/2006_RWP/RegionK. Accession No. ML100640755. 

12 Luminant. 2009. Power Plants. Accessed November 12, 2009 at 

13 http://www.luminant.com/plants/default.aspx. Accession No. ML100640755. 

14 Massachusetts Institute of Technology (MIT). 2006. The Future of Geothermal Energy. 

15 Accessed February 25, 2009 at 

16 http://geothermal.inel.gov/publications/future_of_geothermal_energy.pdf. Accession No. 

17 ML100640755. 

18 McCord, M.W. 2009. Southwest Paddler: Outdoor Recreation Guide for Texas, Oklahoma, 

19 Arkansas, Missouri, New Mexico, Arizona, Colorado and Utah: Red River, Denison Dam to SH 

20 78. Accessed November 17, 2009 at http://southwestpaddler.com/docs/red3.html. 

21 Mid-East Texas Groundwater Conservation District (METGCD). 2009. Management Plan: Mid22 East Texas Groundwater Conservation District; adopted August 13, 2009. METGCD, 

23 Centerville, Texas. Accessed at March 4, 2010 at 

24 http://mideasttexasgcd/management%20plan.pdf. Accession No. ML100640755. 

25 National Center for Education Statistics (NCES). 2009. Search for Public School Districts. 

26 Accessed on November 20, 2009 at http://nces.ed.gov/ccd/districtsearch/index.asp. Accession 

27 No. ML100640755. 

28 National Energy Technology Laboratory (NETL). 2007. Cost and Performance Baseline for 

29 Fossil Energy Plants. Volume 1: Bituminous Coal and Natural Gas to Electricity. DOE/NETL30 2007/1281. Accessed February 20, 2009 at http://www.netl.doe.gov/energy31 analyses/pubs/Bituminous%20Baseline_Final%20Report.pdf. Accession No. ML100640755. 

32 National Environmental Policy Act of 1969, as amended (NEPA). 42 USC 4321, et seq. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-216 March 2010

1 National Park Service (NPS). 2009. Catfish Creek National Natural Landmark. Accessed 

2 November 20, 2009 

3 http://www.nature.nps.gov/nnl/Registry/USA_Map/States/Texas/NNL/CC/index.cfm. Accession 

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5 Moulder, J.E.M. 2003. Powerlines & Cancer FAQS. Accessed March 8, 2010 at 

6 http://www.faqs.org/faqs/medicine/powerlines-cancer-faq/. Accession No. ML100670532. 

7 National Institute of Environmental Health Sciences (NIEHS). 2002. Electric and Magnetic 

8 Fields Associated with the use of Electric Power. Questions and Answers. Accessed March 5, 

9 2010 at http://www.niehs.nih.gov/health/docs/emf-02.pdf. Accession No. ML100640755. 

10 NRG. 2009. Repowering NRG. Limestone 3 Expansion. Accessed February 4, 2010 at 

11 http://www.nrgenergy.com/about/repowering/repowering_tx_ls.htm. Accession No. 

12 ML100640755. 

13 NatureServe. 2009a. Species Descriptions for Important Species at Alternative Sites. 

14 Accessed December 21, 2009 at 

15 http://www.natureserve.org/explorer/servlet/NatureServe?post_processes=PostReset&loadTem

16 plate=nameSearchSpecies.wmt&Type=Reset. Accession No. ML100640755. 

17 NatureServe. 2009b. Species Descriptions for Threatened and Endangered Species at 

18 Alternative Sites. Accessed October 26, 2009 at 

19 http://www.natureserve.org/explorer/servlet/NatureServe?post_processes=PostReset&loadTem

20 plate=nameSearchSpecies.wmt&Type=Reset. Accession No. ML100640755. 

21 New England Coalition on Nuclear Pollution. 1978. New England Coalition on Nuclear 

22 Pollution v. NRC. 582 F.2d 87 (1st Circuit 1978). 

23 NextEra Energy Resources (NextEra). 2009. Solar Electric Generating Systems. Accessed 

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27 Nielsen-Gammon, JW. 1995. “The Changing Climate of Texas” In The Impact of Global 

28 Warming on Texas, North, G., J. Schmandt, and J. Clarkson (eds). University of Texas Press, 

29 Austin, Texas. 

30 Northwest Power and Conservation Council (NPCC). 2005. The Fifth Northwest Electric Power 

31 and Conservation Plan, Vol. 3. Accessed February 20, 2009 at 

32 http://www.nwcouncil.org/energy/powerplan/5/Volume3.pdf. Accession No. ML100640755. 
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Northwest Power and Conservation Council (NPCC). 2009. Draft Northwest 6th 5 Power Plan. 

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8 North Texas Municipal Water District (NTMWD). 2009. The Lower Bois d’Arc Creek Reservoir.

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11 Nuclear Energy Institute (NEI). 2009. U.S. Nuclear Industry Capacity Factors (1971 – 2008). 

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15 Osting, T., R. Mathews, and B. Austin. 2004. Analysis of Instream Flows for the Lower Brazos 

16 River - Hydrology, Hydraulics, and Fish Habitat Utilization. Final Report, Volume I – Main 

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18 Public Service Company of New Hampshire. (Seabrook Station, Units 1 and 2) CLI-77-8, 5 NRC 

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24 Resource Conservation and Recovery Act (RCRA). 42 USC 6901, et seq. 

25 Rochester Gas & Electric Corp. 1978. (Sterling Power Project Nuclear Unit No. 1), ALAB-502, 8 

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1 South Texas Project Nuclear Operating Company (STPNOC). 2008a. Letter from Greg 

2 Gibson, STPNOC, to NRC, dated February 28, 2008, “Responses to Environmental Report Site 

3 Audit Comments." Accession No. ML080660150. 

4 South Texas Project Nuclear Operating Company (STPNOC). 2008b. Letter from Greg 

5 Gibson, STPNOC, to NRC, dated July 15, 2008, ”Response to Requests for Additional 

6 Information.” Accession No. ML082040684. 

7 South Texas Project Nuclear Operating Company (STPNOC). 2008c. Letter from Greg Gibson, 

8 STPNOC, to NRC, dated July 30, 2008, “Response to Requests for Additional Information." 

9 Accession No. ML082140629. 

10 South Texas Project Nuclear Operating Company (STPNOC). 2008d. Letter from Mark 

11 McBurnett, STPNOC, to NRC, dated June 9, 2008, “Cultural or Historical Artifact Discovery 

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13 South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

14 Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

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16 South Texas Project Nuclear Operating Company (STPNOC). 2009b. Letter from Scott Head, 

17 STPNOC, to NRC, dated October 27, 2009, “Response to Request for Additional Information.” 

18 Accession No. ML093060175. 

19 South Texas Project Nuclear Operating Company (STPNOC). 2009c. Letter from Scott Head, 

20 STPNOC, to NRC, dated November 30, 2009, "Supplemental Response to Request for 

21 Additional Information. " Accession No. ML093360350. 

22 South Texas Project Nuclear Operating Company (STPNOC). 2009d. Letter from Scott Head, 

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25 South Texas Project Nuclear Operating Company (STPNOC). 2009e. Letter from Scott Head, 

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28 South Texas Project Nuclear Operating Company (STPNOC). 2009f. South Texas Project 

29 Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

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31 Southern Company and Georgia Institute of Technology (Southern and GIT). 2007. Southern 

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1 Georgia Coast. Accessed March 5, 2010 at http://www.energy.gatech.edu/research/Summary2 Southern-Winds.pdf. Accession No. ML100640755. 

3 Southern Company. 2009. “Southern Company Breaks Ground on Biomass Plant. Accessed 

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6 Strayer, D.L. 2008. Freshwater Mussel Ecology: A Multifactor Approach to Distribution and 

7 Abundance. Freshwater Ecology Series, Vol. 1. University of California Press, Berkley, 

8 California. 

9 Succar, S. and R. H. Williams. 2008. “Compressed Air Energy Storage: Theory, Resources, 

10 and Applications for Wind Power.” Princeton University Energy Systems Analysis Group. 

11 Accessed September 30, 2009 at http://www.princeton.edu/~ssuccar/caesReport.html. 

12 Accession No. ML100640755. 

13 Texas Association of Counties. 2009a. Fannin County Profile. Accessed November 21, 2009 

14 at http://www.txcip.org/tac/census/profile.php?FIPS=48147. Accession No. ML100640755. 

15 Texas Association of Counties. 2009b. Grayson County Profile. Accessed November 20, 2009 

16 at http://www.txcip.org/tac/census/profile.php?FIPS=48181. Accession No. ML100640755. 

17 Texas Association of Counties. 2009c. Austin County Profile. Accessed November 21, 2009 at 

18 http://www.txcip.org/tac/census/profile.php?FIPS=48015. Accession No. ML100640755. 

19 Texas Association of Counties. 2009d. Fort Bend County Profile. Accessed November 21, 

20 2009 at http://www.txcip.org/tac/census/profile.php?FIPS=48157. Accession No. 

21 ML100640755. 

22 Texas Association of Counties. 2009e Freestone County Profile. Accessed November 21, 

23 2009 at http://www.txcip.org/tac/census/profile.php?FIPS=48161. Accession No. 

24 ML100640755. 

25 Texas Association of Counties. 2009f Anderson County Profile. Accessed November 21, 2009 

26 at: http://www.txcip.org/tac/census/profile.php?FIPS=48001. Accession No. ML100640755. 

27 Texas Coastal Management Program (TCMP) 2009. Texas Coastal Management Program. 

28 Accessed November 13, 2009 at http://www.glo.state.tx.us/coastal/cmp.html#mapsdata. 

29 Accession No. ML100640755. 

30 Texas Commission on Environmental Quality (TCEQ). 2001. Multi-Sector Permit – Permit No. 

31 TXR050000. Austin, Texas. August 20, 2001. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-220 March 2010

1 Texas Commission on Environmental Quality (TCEQ). 2003. TPDES General Permit No. 

2 TXR150000. Austin, Texas. March 5, 2003. 

3 Texas Commission on Environmental Quality (TCEQ). 2008. Texas Water Quality Inventory: 

4 Water bodies with concerns for use for use attainment and screening levels (March 19, 2008). 

5 Red River. Accessed November 18, 2009 at 

6 http://www.tceq.state.tx.us/assets/public/compliance/monops/water/08twqi/2008_concerns.pdf. 

7 Accession No. ML100640755. 

8 Texas Commission on Environmental Quality (TCEQ). 2009a. Water Rights Database and 

9 Related Files. Accessed April 13, 2009 at 

10 http://www.tceq.state.tx.us/permitting/water_supply/water_rights/wr_databases.html. Accession 

11 No. ML100640755. 

12 Texas Commission on Environmental Quality (TCEQ). 2009b. Water Availability Models. 

13 Accessed November 15, 2009 at 

14 http://www.tceq.state.tx.us/permitting/water_supply/water_rights/wam.html. Accession No. 

15 ML100640755. 

16 Texas Commission on Environmental Quality. (TCEQ). 2009c. Red River Compact 

17 Commission. Accessed November 15, 2009 at 

18 http://www.tceq.state.tx.us/permitting/water_supply/water_rights/redriver.html. Accession No. 

19 ML100640755. 

20 Texas Commission on Environmental Quality. (TCEQ). 2009d. Lakeside Operating Permit. 

21 Accessed February 4, 2010 at 

22 http://www5.tceq.state.tx.us/airperm/index.cfm?fuseaction=airpermits.project_report&proj_id=14

23 3623&addn_num_txt=PSDTX1200. Accession No. ML100640755. 

24 Texas Commission on Environmental Quality. (TCEQ). 2009e. New Source Review Permits 

25 and Authorizations for Calendar Year 2009. Accessed February 4, 2010 at 

26 http://www.tceq.state.tx.us/assets/public/permitting/air/NewSourceReview/Agendas/nsryear200

27 9.htm. Accession No. ML100640755. 

28 Texas Commission on Environmental Quality (TCEQ). 2010a. List of Texas Utilities (Water or 

29 Sewer). Accessed on January 15, 2010 at 

30 http://www10.tceq.state.tx.us/iwud/util/index.cfm?fuseaction=ListUtilities&COMMAND=LIST. 

31 Accession No. ML100640755. 

32 Texas Commission on Environmental Quality (TCEQ). 2010b. Draft 2010 Texas 303(d) List. 

33 February 5, 2010. Accessed March 2, 2010 at 
 Environmental Impacts of Alternatives 

March 2010 9-221 Draft NUREG-1937 

1 http://www.tceq.state.tx.us/assets/public/compliance/monops/water/10twqi/2010_303d.pdf. 

2 Accession No. ML100630153. 

3 Texas Comptroller of Public Accounts. 2008a. The Energy Report 2008 - Hydropower. 

4 Accessed March 5, 2010 at 

5 http://www.window.state.tx.us/specialrpt/energy/renewable/hydro.php. Accession No. 

6 ML100640755. 

7 Texas Comptroller of Public Accounts. 2008b. The Energy Report 2008 - Wood. Accessed 

8 February 25, 2009 at http://www.window.state.tx.us/specialrpt/energy/renewable/wood.php. 

9 Accession No. ML100640755. 

10 Texas Comptroller of Public Accounts. 2008c. The Energy Report 2008 – Municipal Waste 

11 Combustion. Accessed February 25, 2009 at 

12 http://www.window.state.tx.us/specialrpt/energy/renewable/municipal.php. Accession No. 

13 ML100640755. 

14 Texas Comptroller of Public Accounts. 2008d. The Energy Report 2008 – Biomass Overview. 

15 Accessed February 25, 2009 at 

16 http://www.window.state.tx.us/specialrpt/energy/renewable/biomass.php. Accession No. 

17 ML100640755. 

18 Texas Department of Criminal Justice (TDCJ). 2009. Correctional Institutions Division – Prison; 

19 Boyd. Accessed February 11, 2010 at http://www.tdcj.state.tx.us/stat/unitdirectory/by.htm. 

20 Accession No. ML100640755. 

21 Texas Department of Transportation (TxDOT). 2009a. TxDOT 2009 Highway Projects. 

22 Accessed March 5, 2010 at 

23 http://apps.dot.state.tx.us/apps/project_tracker/projects.htm?view=cnty&dist=Tyler&cnty=Anders

24 on. Accession No. ML100640755. 

25 Texas Department of Transportation (TxDOT). 2009b. Project Overview Keep Texas Moving. 

26 Accessed March 5, 2010 at http://www.keeptexasmoving.com/index.php/i-69-ttc. Accession No. 

27 ML100640755. 

28 Texas Education Agency (TEA). 2009. TEA School Finance Website. Accessed January 22, 

29 2010 at http://ritter.tea.state.tx.us/school.finance/index.html#chapter. Accession No. 

30 ML100640755. 

31 Texas Parks and Wildlife Department (TPWD). 2007. Fairfield Lake. Accessed January 10, 

32 2010 at http://www.tpwd.state.tx.us/fishboat/fish/recreational/lakes/fairfield/. Accession No. 

33 ML100640755. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-222 March 2010

1 Texas Parks and Wildlife Department (TPWD). 2009a. Wildlife Management by District: Post 

2 Oak Savannah and Oak Prairie. Accessed October 21, 2009 at 

3 http://www.tpwd.state.tx.us/landwater/land/habitats. Accession No. ML100640755. 

4 Texas Parks and Wildlife Department (TPWD). 2009b. Plant Guidance by Ecoregions. 

5 Accessed October 21, 2009 at 

6 http://www.tpwd.state.tx.us/huntwild/wild/wildscapes/guidance/plants/ecoregions. Accession 

7 No. ML100640755. 

8 Texas Parks and Wildlife Department (TPWD). 2009c. TPWD Parks and WMA at Alternative 

9 Sites. Accessed November 19, 2009 at http://www.tpwd.state.tx.us/huntwild/hunt/wma/. 

10 Accession No. ML100640755. 

11 Texas Parks and Wildlife Department (TPWD). 2009d. Letter from Ross Melinchuk (Deputy 

12 Executive Director, Texas Parks and Wildlife Department) to Ray Whited (Chief, U.S. Nuclear 

13 Regulatory Commission) dated November 13, 2009, “Proposed alternative sites related to the 

14 combined license application for South Texas Project, Units 3 and 4.” Accession No. 

15 ML093210221. 

16 Texas Parks and Wildlife Department (TPWD). 2009e. Game Species at Alternative Sites. 

17 Accessed December 21, 2009 at http://www.tpwd.state.tx.us/huntwild/hunt/wma/. Accession 

18 No. ML100640755. 

19 Texas Parks and Wildlife Department (TPWD). 2009f. Endangered and Threatened Species 

20 List for Austin, Fannin, Freestone, and Fort Bend Counties. Accessed October 26, 2009 at 

21 http://www.tpwd.state.tx.us/landwater/land/maps/gis/ris/endangered_species/. Accession No. 

22 ML100640755. 

23 Texas Parks and Wildlife Department (TPWD). 2009g. Profiles of Endangered and Threatened 

24 Species for Austin, Fannin, Freestone, and Fort Bend Counties. Accessed October 26, 2009 at 

25 http://www.tpwd.state.tx.us/huntwild/wild/species/. Accession No. ML100640755. 

26 Texas Parks and Wildlife Department (TPWD). 2009h. Invasive, Prohibited and Exotic 

27 Species. Accessed November 19, 2009 at: 

28 http://www.tpwd.state.tx.us/huntwild/wild/species/exotic/. Accession No. ML100640755. 

29 Texas Parks and Wildlife Department (TPWD). 2009i. Rare, Threatened, and Endangered 

30 Species of Texas, Fannin, Austin, and Freestone Counties. Texas Parks and Wildlife 

31 Department, Austin, Texas. Accessed January 25, 2010 at 

32 http://gis.tpwd.state.tx.us/TpwEndangeredSpecies/DesktopDefault.aspx. Accession No. 

33 ML100640755. 
 Environmental Impacts of Alternatives 

March 2010 9-223 Draft NUREG-1937 

1 Texas Parks and Wildlife Department (TPWD). 2009j. Fairfield Lake State Park. Accessed 

2 February 4, 2010 at www.tpwd.state.tx.us/spdest/findadest/parks/fairfield_lake/. Accession No. 

3 ML100640755. 

4 Texas Parks and Wildlife Department (TPWD). 2009k. Richland Creek WMA. Accessed 

5 February 4, 2010 at http://www.tpwd.state.tx.us/huntwild/hunt/wma/find_a_wma/list/?id=23. 

6 Accession No. ML100640755. 

7 Texas Parks and Wildlife Department (TPWD). 2009l. Big Lake Bottom WMA. Accessed 

8 February 4, 2010 at hhtp://www.tpwd.state.tx.us/huntwild/hunt/wma/find_a_wma/list/?id=1. 

9 Accession No. ML100640755. 

10 Texas Parks and Wildlife Department (TPWD). 2009m. Gus Engeling WMA (GEWMA).

11 Accessed February 4, 2010 at 

12 http://www.tpwd.state.tx.us/huntwild/hunt/wma/find_a_wma/list/?id=10. Accession No. 

13 ML100640755. 

14 Texas Parks and Wildlife Department (TPWD). 2009n. Stephen F. Austin State Park.

15 Accessed February 4, 2010 at 

16 http://www.tpwd.state.tx.us/spdest/findadest/parks/stephen_f_austin_and_san_felipe. 

17 Accession No. ML100640755. 

18 Texas Parks and Wildlife Department (TPWD). 2009o. Brazos Bend State Park. Accessed 

19 February 4, 2010 at http://www.tpwd.state.tx.us/spdest/findadest/parks/brazos_bend. 

20 Accession No. ML100640755. 

21 Texas Parks and Wildlife Department (TPWD). 2010. Ecologically Significant River and Stream 

22 Segments – Regions C and H. Accessed January 21, 2010 at 

23 http://www.tpwd.state.tx.us/landwater/water/environconcerns/water_quality/sigsegs/. Accession 

24 No. ML100640755. 

25 Texas Railroad Commission (TRC). 2010. Surface Mining & Reclamation. Accessed February 

26 4, 2010 at http://www.rrc.state.tx.us/programs/mining/projects/TurlingtonMine.php. Accession 

27 No. ML100640755. 

28 Texas State Energy Conservation Office (TSECO). 2008a. Texas Solar Energy. Accessed 

29 February 24, 2009 at http://www.seco.cpa.state.tx.us/re_solar.htm. 

30 Texas State Energy Conservation Office (TSECO). 2008b. Texas Wind Energy. Accessed 

31 February 24, 2009 at http://www.seco.cpa.state.tx.us/re_wind.htm. Accession No. 

32 ML100640755. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-224 March 2010

1 Texas State Energy Conservation Office (TSECO). 2008c. Wind Energy Transmission. 

2 Accessed February 24, 2009 at http://www.seco.cpa.state.tx.us/re_wind-transmission.htm. 

3 Accession No. ML100640755. 

4 Texas State Historical Association (TSHA). 2009a. Valley Lake. Accessed November 12, 

5 2009 at: http://www.tshaonline.org/handbook/online/articles/VV/rovnr.html. Accession No. 

6 ML100640755. 

7 Texas State Historical Association (TSHA). 2009b. Fairfield Lake. Accessed November 13, 

8 2009 at http://www.tshaonline.org/handbook/online/articles/FF/rof8.html. Accession No. 

9 ML100640755. 

10 Texas State Historical Association (TSHA). 2009c. Handbook of Texas Online - Fannin County. 

11 Accessed on November 18, 2009 at 

12 http://www.tshaonline.org/handbook/online/articles/FF/hcf2.html. Accession No. ML100640755. 

13 Texas State Historical Association (TSHA). 2009d. Handbook of Texas Online - Grayson 

14 County. Accessed on November 18, 2009 at 

15 http://www.tshaonline.org/handbook/online/articles/GG/hcg9.html. Accession No. 

16 ML100640755. 

17 Texas State Historical Association (TSHA). 2009e. Handbook of Texas Online - Austin County. 

18 Accessed on November 18, 2009 at 

19 http://www.tshaonline.org/handbook/online/articles/AA/hca8.html. Accession No. 

20 ML100640755. 

21 Texas State Historical Association (TSHA). 2009f. Handbook of Texas Online –Fort Bend

22 County. Accessed on November 18, 2009 at 

23 http://www.tshaonline.org/handbook/online/articles/FF/hcf7.html. Accession No. ML100640755. 

24 Texas State Historical Association (TSHA). 2009g. Handbook of Texas Online –Freestone 

25 County. Accessed on November 18, 2009 at 

26 http://www.tshaonline.org/handbook/online/articles/AA/hca8.html. Accession No. 

27 ML100640755. 

28 Texas State Historical Association (TSHA). 2009h. Handbook of Texas Online –Anderson 

29 County. Accessed on November 18, 2009 at 

30 http://www.tshaonline.org/handbook/online/articles/AA/hca8.html. Accession No. 

31 ML100640755. 

32 Thomas, C., T.H. Bonner, and B.G. Whiteside. 2007. Freshwater Fishes of Texas: A Field 

33 Guide. Texas A&M University Press, College Station, Texas. 
 Environmental Impacts of Alternatives 

March 2010 9-225 Draft NUREG-1937 

1 Texas Water Development Board (TWDB) 2001. Region C Water Plan. Accessed January 13, 

2 2010 at 

3 http://www.regioncwater.org/Documents/index.cfm?PageNum_d=1&Category=Water+Plan. 

4 Accession No. ML100640755. 

5 Texas Water Development Board (TWDB). 2003. Groundwater Availability Model for the 

6 Central Part of the Carrizo-Wilcox Aquifer in Texas. TWDB, Austin, Texas. 

7 Texas Water Development Board (TWDB). 2006a. Water For Texas 2007. Accessed January 

8 14, 2010 at: http://www.twdb.state.tx.us/wrpi/swp/swp.htm. Accession No. ML100640755. 

9 Texas Water Development Board (TWDB). 2006b. 2006 Region C Water Plan. Accessed 

10 March 1, 2010 at http://www.twdb.state.tx.us/rwpg/2006_RWP/RegionC/. Accession No. 

11 ML100640755. 

12 Texas Water Development Board (TWDB). 2006c. Regional Water Plan. Accessed March 1, 

13 2010 at http://www.twdb.state.tx.us/rwpg/2006_RWP/RegionG/. Accession No. ML100640755. 

14 Texas Water Development Board (TWDB). 2009. Groundwater Management Area 8. 

15 Accessed March 5, 2010 at http://www.twdb.state.tx.us/GwRD/GMA/gma8/gma8home.htm. 

16 Accession No. ML100640755. 

17 Texas Water Development Board (TWDB). 2010a. Potential New Reservoirs for Region C 

18 Water Supply. Accessed March 5, 2010 at 

19 http://www.twdb.state.tx.us/rwp/c/PDFs/Regional%20Plan%20Main%20Text/Table_5-3.pdf. 

20 Accession No. ML100640755. 

21 Texas Water Development Board (TWDB). 2010b. Groundwater Management Area 12. 

22 Accessed March 5, 2010 at http://www.state.tx.us/GwRD/GMA/gma12/gma12home.htm. 

23 Accession No. ML100640755. 

24 Texas Water Development Board (TWDB). 2010c. Groundwater Management Area 14. 

25 Accessed March 5, 2010 at http://www.twdb.state.tx.us/GWRD/GMA/gma14/gma14home.htm. 

26 Accession No. ML100640755. 

27 Texas Water Code, Title 2, Water Administration. Chapter 11, “Water Rights.” 

28 Texas Water Code, Title 2. Water Administration. Chapter 26, “Water Quality Control.” 

29 Texas Water Code, Title 2. Water Administration. Chapter 36, “Groundwater Conservation 

30 Districts.” 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-226 March 2010

1 United States Steel (USS). 2009. Bellville Operations Division. Accessed March 5, 2010 at 

2 http://www.ussteel.com/corp/facilities/Bellville.asp. Accession No. ML100640755. 

3 U.S. Army Corps of Engineers (Corps). 2009. Proposed Lower Bois d’Arc Creek Reservoir 

4 Scoping Meeting Public Notice Announcement. Application No. SWT-0-14659. U.S. Army Corps 

5 of Engineers. 

6 U.S. Atomic Energy Commission (AEC). 1974. Final Environmental Statement Related to the 

7 Proposed Allens Creek Nuclear Generating Station, Units 1 and 2. Houston Lighting and Power 

8 Company. Docket Nos. 50-466 and 50-467. 

9 U.S. Census Bureau (USCB). 2009a. Population Finder - American FactFinder. Accessed 

10 September 24, 2009 at 

11 http://factfinder.census.gov/servlet/SAFFPopulation?_event=Search&geo_id=01000US&_. 

12 (Select City). Accession No. ML100640755. 

13 U.S. Census Bureau (USCB). 2009b.Sherman-Denison, TX Metropolitan Statistical Area. Data 

14 Profiles. Selected Social Characteristics in the United States: 2008. Accessed November 21, 

15 2009 at http://factfinder.census.gov. Data Set: 2008 American Community Survey 1-Year 

16 Estimates. Survey: American Community Survey. 

17 U.S. Census Bureau (USCB). 2009c. Fannin County Texas - Selected Housing Characteristics 

18 2006-2008 American Community Survey 3-Year Estimates Accessed November 21, 2009 at 

19 http://factfinder.census.gov Search: 2006-2008 American Community Survey, Data Profiles, 

20 Fannin County, Texas. 

21 U.S. Census Bureau (USCB). 2009d. Grayson County Texas - Selected Housing 

22 Characteristics 2006-2008 American Community Survey 3-Year Estimates Accessed 

23 November 21, 2009 at http://factfinder.census.gov Search: 2006-2008 American Community 

24 Survey, Data Profiles, Grayson County, Texas. 

25 U.S. Census Bureau (USCB). 2009e. Austin County Texas - Selected Housing Characteristics 

26 2006-2008 American Community Survey 3-Year Estimates Accessed November 21, 2009 at 

27 http://factfinder.census.gov Search: 2006-2008 American Community Survey, Data Profiles, 

28 Austin County, Texas. 

29 U.S. Census Bureau (USCB). 2009f. Fort Bend County Texas - Selected Housing 

30 Characteristics 2006-2008 American Community Survey 3-Year Estimates Accessed 

31 November 21, 2009 at http://factfinder.census.gov Search: 2006-2008 American Community 

32 Survey, Data Profiles, Fort Bend County, Texas. 
 Environmental Impacts of Alternatives 

March 2010 9-227 Draft NUREG-1937 

1 U.S. Census Bureau (USCB). 2009g. Freestone County Texas - Selected Housing 

2 Characteristics 2006-2008 American Community Survey 3-Year Estimates Accessed 

3 November 21, 2009 at http://factfinder.census.gov Search: 2006-2008 American Community 

4 Survey, Data Profiles, Freestone County, Texas. 

5 U.S. Census Bureau (USCB). 2009h. Anderson County Texas - Selected Housing 

6 Characteristics 2006-2008 American Community Survey 3-Year Estimates Accessed 

7 November 21, 2009 at http://factfinder.census.gov Search: 2006-2008 American Community 

8 Survey, Data Profiles, Anderson County, Texas. 

9 U.S. Census Bureau (USCB). 2009i. Population Estimates Data Sets. Accessed September 24, 

10 2009 at http://www.census.gov/popest/datasets.html. Accession No. ML100640755. 

11 U.S. Department of Energy (DOE). 2006. Geothermal FAQs. Accessed February 25, 2009 at 

12 http://www1.eere.energy.gov/geothermal/faqs.html. Accession No. ML100640755. 

13 U.S. Department of Energy (DOE). 2008a. 20% Wind Energy by 2030. DOE/GO-102008-

14 2567. Accessed February 24, 2009 at http://www1.eere.energy.gov/windandhydro/. Accession 

15 No. ML100640755. 

16 U.S. Department of Energy (DOE). 2008b. State Energy Alternatives: Biomass Energy. 

17 Accessed February 25, 2009 at http://www.eere.energy.gov/states/alternatives/biomass.cfm. 

18 U.S. Department of Energy (DOE). 2008c. Fuel Cell Technology Challenges. Accessed 

19 February 25, 2009 at 

20 http://www1.eere.energy.gov/hydrogenandfuelcells/fuelcells/fc_challenges.html. Accession No. 

21 ML100640755. 

22 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2009a. Texas 

23 Quick Facts. Accessed January 7, 2010 at 

24 http://tonto.eia.doe.gov/state/state_energy_profiles.cfm?sid=TX. Accession No. ML100640755. 

25 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2009b. Electric 

26 Power Industry 2007: Year in Review. Accessed February 19 2009 at 

27 http://www.eia.doe.gov/cneaf/electricity/epa/epa_sum.html. Accession No. ML100640755. 

28 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2009c. An Updated 

29 Annual Energy Outlook 2009 Reference Case Reflecting Provisions of the American Recovery 

30 and Reinvestment Act and Recent Changes in the Economic Outlook. SR/OIAF/2009-03. 

31 Accessed July 22, 2009 at http://www.eia.doe.gov/oiaf/servicerpt/stimulus/index.html. 

32 Accession No. ML100640755. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-228 March 2010

1 U.S. Department of Transportation (USDOT). 2009. Re-evaluation of the Final Environmental 

2 Impact Statement for State Highway 99 Grand Parkway. Accessed March 5, 2010 at 

3 http://www.grandpky.com/downloads/segment_f1/20090605_F-1_FEIS%20Draft_ReEval.pdf. 

4 Accession No. ML100640755. 

5 U.S. Department of Transportation and Texas Department of Transportation (DOT and TxDOT). 

6 2007. I-69/Trans-Texas Corridor Tier One Draft Environmental Impact Statement. FHWA-TX7 EIS-07-02-D. Austin, Texas. 

8 U.S. Environmental Protection Agency (EPA). 2008. Municipal Solid Waste - Combustion. 

9 Accessed February 25, 2009 at http://www.epa.gov/osw/nonhaz/municipal/combustion.htm. 

10 Accession No. ML100640755. 

11 U.S. Environmental Protection Agency (EPA). 2009a. Municipal Solid Waste. Accessed 

12 February 25, 2009 at http://www.epa.gov/cleanenergy/energy-and-you/affect/municipal-sw.html. 

13 Accession No. ML100640755. 

14 U.S. Environmental Protection Agency (EPA). 2009b. U.S. Environmental Protection Agency 

15 (EPA). 2009. Safe Drinking Water Information System (SDWIS). Accessed January 15,2010 

16 at http://oaspub.epa.gov/enviro/sdw_form_v2.create_page?state_abbr=TX. Accession No. 

17 ML100640755. 

18 U.S. Environmental Protection Agency. (EPA). 2009c. Big Brown Steam Electric Station.

19 Accessed March 5, 2010 at 

20 http://iaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110000598988. 

21 Accession No. ML100640755. 

22 U.S. Environmental Protection Agency. (EPA). 2009d. Big Brown Lignite Mining Area. 

23 Accessed March 5, 2010 at 

24 http://iaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110033229897. 

25 Accession No. ML100640755. 

26 U.S. Environmental Protection Agency. (EPA) 2009e. TXI Operations LP. Accessed March 5, 

27 2010 at 

28 http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=75859TXPSL2

29 MILE&pgm_sys_acrnm_in=TRIS. Accession No. ML100640755. 

30 U.S. Environmental Protection Agency. (EPA). 2009f. Coffield Prison Water Discharge Permit. 

31 Accessed February 4, 2010 at 

32 http://oaspub.epa.gov/enviro/pcs_det_reports.pcs_tst?npdesid=TX0031577&npvalue=1&npvalu

33 e=2&npvalue=3&npvalue=4&npvalue=5&npvalue=6&rvalue=13&npvalue=7&npvalue=8&npvalu

34 e=10&npvalue=11&npvalue=12. Accession No. ML100640755. 
 Environmental Impacts of Alternatives 

March 2010 9-229 Draft NUREG-1937 

1 U.S. Environmental Protection Agency. (EPA). 2009g. Nucor Steel – Texas. Accessed 

2 February 4, 2010 at 

3 http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=TXD07137858

4 2&pgm_sys_acrnm_in=RCRAINFO. Accession No. ML100640755. 

5 U.S. Environmental Protection Agency. (EPA). 2009h. EPA 2009 Cayuga. 

6 U.S. Environmental Protection Agency. (EPA). 2009i. Trinity Materials Water Discharge Permits. 

7 Accessed February 4, 2010 at 

8 http://oaspub.epa.gov/enviro/pcs_web.report?PGM_SYS_ID=OK0044172. Accession No. 

9 ML100640755. 

10 U.S. Environmental Protection Agency. (EPA). 2009j. City of Bells Water Discharge Permit. 

11 Accessed February 4, 2010 at 

12 http://oaspub.epa.gov/enviro/pcs_web.report?PGM_SYS_ID=TX0053368. Accession No. 

13 ML100640755. 

14 U.S. Environmental Protection Agency. (EPA). 2009k. EPA 2009 City of Denison Water 

15 Discharge Permit. Accessed February 4, 2010 at 

16 http://oaspub.epa.gov/enviro/pcs_web.report?PGM_SYS_ID=TX0053368. Accession No. 

17 ML100640755. 

18 U.S. Environmental Protection Agency. (EPA). 2009l WA Parish Electric Generating Station 

19 Detail Report. Accessed February 4, 2010 at 

20 http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=TXD09731184

21 9&pgm_sys_acrnm_in=RCRAINFO. Accession No. ML100640755. 

22 U.S. Environmental Protection Agency. (EPA). 2009m. Frito Lay Rosenberg Facility. Accessed 

23 February 4, 2010 at 

24 http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=77471FRTLY3

25 310H&pgm_sys_acrnm_in=TRIS. Accession No. ML100640755. 

26 U.S. Environmental Protection Agency. (EPA). 2009n. Sealy PLT. Accessed February 4, 2010 

27 at 

28 http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?pgm_sys_id_in=TXR00001734

29 3&pgm_sys_acrnm_in=RCRAINFO. Accession No. ML100640755. 

30 U.S. Environmental Protection Agency. (EPA). 2009o. EPA 2009 Valley Facility Emissions. 

31 Accessed February 10, 2010 at 

32 http://oaspub.epa.gov/enviro/airs_web.report?PGM_SYS_ID=4814700001. Accession No. 

33 ML100640755. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-230 March 2010

1 U.S. Federal Aviation Administration (FAA). 2007. Obstruction Marking and Lighting. Advisory 

2 Circular AC 70/7460-1K. Accessed February 23, 2009 at 

3 https://oeaaa.faa.gov/oeaaa/external/content/AC70_7460_1K.pdf. Accession No. 

4 ML100640755. 

5 U.S. Fish and Wildlife Service (FWS). 2009a. Endangered and Threatened Species List for 

6 Austin, Fannin, Freestone, and Fort Bend Counties. Accessed October 26, 2009 at 

7 http://www.fws.gov/southwest/es/EndangeredSpecies/lists/. Accession No. ML100640755. 

8 U.S. Fish and Wildlife Service (FWS). 2009b. Profiles of Endangered and Threatened Species 

9 for Austin, Fannin, Freestone, and Fort Bend Counties. Accessed October 22, 2009 at 

10 http://ecos.fws.gov/tess_public/. Accession No. ML100640755. 

11 U.S. Fish and Wildlife Service (FWS). 2009c. Attwater Prairie Chicken National Wildlife Refuge. 

12 Accessed October 21, 2009 at http://fws.gov/southwest/refuges/texas/attwater/index.html. 

13 Accession No. ML100640755. 

14 U.S. Fish and Wildlife Service (FWS). 2009d. Ecological Services; Southwest County-by15 County. Accessed October 26, 2090 at 

16 http://www.fws.gov/southwest/es/EndangeredSpecies/lists/default.cfm. Accession No. 

17 ML100640755. 

18 U.S. Forest Service. (USFS). 2009. Caddo-LBJ National Grasslands. Accessed February 4, 

19 2010 at http://www.fs.fed.us/r8/texas/recreation/caddo_lbj/caddo-lbj_gen_info.shtml. 

20 Accession No. ML100640755. 

21 U.S. Geologic Survey (USGS). 2005. Fish-Community Changes Reflect Water-Quality 

22 Improvements in the Trinity River Downstream From Dallas. Accessed November 18, 2009 at 

23 http://pubs.usgs.gov/circ/circ1171/html/fishcom.htm. Accession No. ML100640755. 

24 Karl, Thomas R., Jerry M. Melillo, and Thomas C. Peterson (eds.). 2009. Global Climate 

25 Change Impacts in the United States. Cambridge University Press, New York. Accessed 

26 February 27, 2010 at http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts27 report.pdf. Accession No. ML100580077. 

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

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

30 U.S. Nuclear Regulatory Commission. 1998. General Site Suitability Criteria for Nuclear Power 

31 Stations. Regulatory Guide 4.7, Rev. 2. 
 Environmental Impacts of Alternatives 

March 2010 9-231 Draft NUREG-1937 

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

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

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

4 NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

5 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan—

6 Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

7 Washington, D.C. Includes 2007 updates. 

8 U.S. Nuclear Regulatory Commission (NRC). 2008a. Letter from Paul Kallan, NRC, to Gregory 

9 Gibson, STPNOC, dated May 19, 2008, “Request for Additional Information, Letter Number One 

10 Related to the Environmental Report for the South Texas Combined License Application.” 

11 Accession No. ML081360531. 

12 U.S. Nuclear Regulatory Commission (NRC). 2008b. Letter from Paul Kallan, NRC, to Scott 

13 Head, STPNOC, dated November 18, 2008, “Request for Additional Information, Letter Number 

14 Two Related to the Environmental Report for the South Texas Combined License Application.” 

15 Accession No. ML083190269. 

16 U.S. Nuclear Regulatory Commission (NRC). 2009a. Status of License Renewal Applications 

17 and Industry Activities. Accessed February 8, 2010 at 

18 http://www.nrc.gov/reactors/operating/licensing/renewal/applications.html#future. Accession 

19 No. ML100640755. 

20 U.S. Nuclear Regulatory Commission (NRC). 2009b. Site Audit Summary of South Texas 

21 Project Nuclear Operating Company’s Revised Alternative Sites Analysis. November 9, 2009. 

22 Accession No. ML092870574. 

23 University of Texas (UT). 1996. Physiography of Texas. Accessed October 21, 2009 at 

24 http://www.lib.utexas.edu/geo/physiography.html. Accession No. ML100640755. 

25 Upper Trinity Regional Water District’s Diversified Water Portfolio. (UTRWD). 2010. Lake 

26 Ralph Hall. Accessed March 5, 2010 at http://www.lakeralphhallinfo.com. Accession No. 

27 ML100640755. 

28 Virtus Energy (Virtus). 2008. Texas Renewable Energy Assessment: Geothermal. Accessed 

29 February 25, 2009 at http://www.vera.com/re_b_psdoc_07.htm. Accession No. ML100640755. 

30 Wade, S.C., 2008. GAM Run 08-14mag. Texas Water Development Board, Groundwater 

31 Availability Modeling Section. May 6, 2008. Accessed November 15, 2009 at 

32 http://www.twdb.state.tx.us/GwRD/GMA/MAG/GMA8_GR08-14mag.pdf. Accession No. 

33 ML100640755. 
Environmental Impacts of Alternatives 

Draft NUREG-1937 9-232 March 2010

1 Wood, C.R., T.L. Arsuffi and M.K. Cauble. 1994. Macroinvertebrate assessment of Allens Creek 

2 and the Brazos River, Austin County, Texas. River Studies Report No. 11, Texas Water 

3 Develoment Board Interagency Contract Number 93-483-364. Texas Parks and Wildlife 

4 Department, Austin, Texas. 
March 2010 10-1 Draft NUREG-1937 

1 10.0 Conclusions and Recommendations 

2 The U.S. Nuclear Regulatory Commission (NRC or the Commission) received an application 

3 from STP Nuclear Operating Company (STPNOC) for combined construction permits and 

4 operating licenses (combined licenses or COLs) for South Texas Project Electric Generating 

5 Station (STP) Units 3 and 4. The location of the proposed Units 3 and 4 is approximately 2000 

6 ft northwest of the existing STP Units 1 and 2. The STP site and existing facilities are owned by

7 NRG South Texas LP (NRG); City Public Service Board of San Antonio, Texas (CPS Energy); 

8 and the City of Austin, Texas. It is planned that STP Unit 3 would be owned by Nuclear 

9 Innovation North America (NINA) Texas 3 LLC and CPS Energy, and STP Unit 4 would be 

10 owned by NINA Texas 4 LLC and CPS Energy (STPNOC 2009a). STPNOC would be the 

11 licensed operator for the proposed Units 3 and 4, as it currently is for the existing Units 1 and 2. 

12 In its application, STPNOC specified the certified U.S. Advanced Boiling Water Reactor (ABWR) 

13 as the proposed reactor design for Units 3 and 4. 

14 On June 4, 2009, with a subsequent submittal on October 28, 2009, STPNOC submitted a 

15 Permit Determination Request to the U.S. Army Corps of Engineers (Corps) Galveston District 

16 for activities associated with constructing and operating proposed Units 3 and 4 (STPNOC 

17 2009b). On November 10, 2009, the Corps notified STPNOC that the proposed project would 

18 require a U.S. Department of the Army permit pursuant to Section 404 of the Federal Water 

19 Pollution Control Act (Clean Water Act) and Section 10 of the Rivers and Harbors Act. The 

20 Corps is participating with the NRC in preparing this environmental impact statement (EIS) as a 

21 cooperating agency (Corps 2009). 

22 Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA) (42 USC 

23 4321 et seq.), directs that an EIS is required for major Federal actions that significantly affect 

24 the quality of the human environment. Section 102(2)(C) of NEPA requires that an EIS include 

25 information about the following: 

26  the environmental impacts of the proposed action; 

27  any adverse environmental effects that cannot be avoided should the proposal be 

28 implemented; 

29  alternatives to the proposed action; 

30  the relationship between local short-term uses of the environment and the maintenance and 

31 enhancement of long-term productivity; and 

32  any irreversible and irretrievable commitments of resources that would be involved if the 

33 proposed action is implemented. 
Conclusions and Recommendations 

Draft NUREG-1937 10-2 March 2010 

1 The NRC has implemented NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. 

2 In 10 CFR 51.20, the NRC requires preparation of an EIS for issuance of COLs. Subpart C of 

3 10 CFR Part 52 contains the NRC regulations related to COLs. 

4 The proposed actions related to the Units 3 and 4 application are (1) the NRC issuance of COLs 

5 for construction and operation of two new nuclear units at the STP site in Matagorda County, 

6 Texas; and (2) the Corps issuance of a permit pursuant to Section 404 of the Clean Water Act 

7 and Section 10 of the Rivers and Harbors Appropriation Act. The permit application requests 

8 authorization to expand an existing barge slip on the Colorado River and to culvert and fill 

9 waters of the United States for the purpose of constructing a heavy haul road on the site. 

10 The environmental review described in this EIS was conducted by a team consisting of NRC 

11 staff, its contractor’s staff, and staff from the Corps. During the course of preparing this EIS, the 

12 review team reviewed the Environmental Report (ER) submitted by STPNOC (2009c and 

13 supplemental documentation; consulted with Federal, State, Tribal, and local agencies; and 

14 followed the guidance set forth in NUREG-1555, Environmental Standard Review Plans (NRC 

15 2000). In addition, the NRC considered the public comments related to the environmental 

16 review received during the scoping process. These comments are provided in Appendix D. 

17 Included in this EIS are (1) the results of the review team’s preliminary analyses, which consider 

18 and weigh the environmental effects of the proposed actions; (2) mitigation measures for 

19 reducing or avoiding adverse effects; (3) the environmental impacts of alternatives to the 

20 proposed action; and (4) the NRC staff’s preliminary recommendation regarding the proposed 

21 action based on its environmental review. The COL application references a certified reactor 

22 design. Where appropriate, this EIS adopts results of the environmental review conducted in 

23 support of the design certification application and incorporates those results by reference. 

24 As a cooperating agency, the Corps has participated in the environmental review and EIS 

25 preparation. The proposed action includes impacts on waters of the United States. For 

26 proposed actions requiring a Section 404 Clean Water Act permit for the discharge of dredged 

27 and/or fill material into waters of the United States, regulations promulgated by the U.S. 

28 Environmental Protection Agency (EPA) require the Corps to limit its authorization to the least 

29 environmentally damaging practicable alternative. The Corps will document its conclusion of 

30 the review process, including the requirement for compensatory mitigation, in accordance with 

31 33 CFR Part 332, Compensatory Mitigation for Losses of Aquatic Resources, in its permit32 decision document. 

33 Environmental issues are evaluated using the three-level standard of significance – SMALL, 

34 MODERATE, or LARGE – developed by the NRC using guidelines from the Council on 

35 Environmental Quality (CEQ) (40 CFR 1508.27). Table B-1 of 10 CFR Part 51, Subpart A, 

36 Appendix B, provides the following definitions of the three significance levels: 
 Conclusions and Recommendations 

March 2010 10-3 Draft NUREG-1937 

1 SMALL – Environmental effects are not detectable or are so minor that they would neither 

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

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

4 important attributes of the resource. 

5 LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

6 important attributes of the resource. 

7 Mitigation measures were considered for each environmental issue and are discussed in the 

8 appropriate sections. During its environmental review, the NRC and Corps review team 

9 considered planned activities and actions that STPNOC indicates it and others would likely take 

10 should STPNOC receive the COLs. In addition, STPNOC provided estimates of the 

11 environmental impacts resulting from the building and operation of two new nuclear units on the 

12 proposed site. 

13 10.1 Impacts of the Proposed Action 

14 In a final rule dated October 9, 2007 (72 FR 57416), the Commission limited the definition of 

15 “construction” to those activities that fall within its regulatory authority (10 CFR 51.4). Many of 

16 the activities required to build a nuclear power plant are not part of the NRC action to license the 

17 plant. Activities associated with building the plant that are not within the purview of the NRC 

18 action are grouped under the term “preconstruction.” Preconstruction activities include clearing 

19 and grading, excavating, erection of support buildings and transmission lines, and other 

20 associated activities. Because the “preconstruction” activities are not part of the NRC action, 

21 their impacts are not reviewed as a direct effect of the NRC action. Rather, the impacts of the 

22 preconstruction activities are considered in the context of cumulative impacts. Although the 

23 preconstruction activities are not part of the NRC action, they support or are requisite to the 

24 NRC action. In addition, certain preconstruction activities require permits from the Corps, as 

25 well as other Federal, State, and local agencies. 

26 Chapter 4 describes the relative magnitude of impacts related to preconstruction and 

27 construction activities with a summary of impacts in Table 4-7. Impacts associated with 

28 operation of the proposed facilities are discussed in Chapter 5 and are summarized in 

29 Table 5-21. Chapter 6 describes the impacts associated with the fuel cycle, transportation, and 

30 decommissioning. Chapter 7 describes the impacts associated with preconstruction and 

31 construction activities and operation of Units 3 and 4 when considered along with the cumulative 

32 impacts of other past, present, and reasonably foreseeable future projects in the geographic 

33 region around the STP site. 
Conclusions and Recommendations 

Draft NUREG-1937 10-4 March 2010 

1 10.2 Unavoidable Adverse Environmental Impacts 

2 Section 102(2)(C)(ii) of NEPA requires that an EIS include information on any adverse 

3 environmental effects that cannot be avoided should the proposal be implemented. 

4 Unavoidable adverse environmental impacts are those potential impacts of the NRC action and 

5 the Corps action that cannot be avoided and for which no practical means of mitigation are 

6 available. 

7 10.2.1 Unavoidable Adverse Impacts During Construction and Preconstruction 

8 Chapter 4 discusses in detail the potential impacts from construction and preconstruction of the 

9 proposed Units 3 and 4 at the STP site and presents mitigation and controls intended to lessen 

10 the adverse impacts. Table 10-1 presents the adverse impacts associated with construction 

11 and preconstruction activities to each of the resource areas evaluated in this EIS, and the 

12 mitigation measures that would reduce the impacts. Those impacts remaining after mitigation is 

13 applied are identified in the table as the unavoidable adverse impacts. Unavoidable adverse 

14 impacts are the result of both construction and preconstruction activities, unless otherwise 

15 noted. The impact determinations in Table 10-1 are for the combined impacts of construction 

16 and preconstruction, but the impact determinations for NRC-regulated construction are the 

17 same for each resource area. 

18 Table 10-1. Unavoidable Adverse Environmental Impacts from Construction and 

19 Preconstruction Activities 

Resource Area Impacts Mitigation Measures Unavoidable Adverse Impacts

Land Use SMALL Comply with requirements of 

applicable Federal, State, and 

local permits. 

Approximately 300 ac committed 

on a long-term basis and 240 ac 

disturbed on a temporary basis. 

Water Use SMALL Comply with the requirements 

of Coastal Plains Groundwater 

Conservation District (CPGCD) 

permitting rules. 

New groundwater wells would be 

installed in the Deep Aquifer to 

supply water for building needs. 

Water Quality SMALL Implement best management 

practices (BMPs) and a sitespecific Stormwater Pollution 

Prevention Plan (SWPPP). 

Onsite and offsite water bodies 

would receive stormwater runoff 

during building phase. 

 Comply with Federal and State 

permits and implementation of 

BMPs. 

Dredging in the Colorado River 

near the Reservoir Makeup 

Pumping Facility (RMPF) and 

barge slip. 20 
 Conclusions and Recommendations 

March 2010 10-5 Draft NUREG-1937 

Table 10-1. (contd) 

Resource Area Impacts Mitigation Measures Unavoidable Adverse Impacts

 Compliance with CPGCD 

permitting rules and 

implementation of BMPs. 

Inadvertent spills that seep into 

aquifers and saltwater intrusion. 

Ecological 

(Terrestrial) 

SMALL Implement BMPs and Avian 

Protection Plans. 

Habitat loss and increased risk of 

collision and direct mortality; 

temporary wildlife displacement 

and avoidance due to noise and 

increased activities. 

 Implement BMPs and 

avoidance. 

No temporary or permanent losses 

of wetlands are expected. 

Ecological 

(Aquatic) 

SMALL Implement BMPs and a sitespecific SWPPP. Habitat loss from dredging and 

barge slip expansion. 

Socioeconomic 

Physical 

Impacts 

SMALL to 

MODERATE 

Alert local governmental 

agencies concerning needed 

road repairs. 

Minor temporary impacts during 

building phase. 

 Develop and implement a 

construction traffic management 

plan during building phase. 

Noticeable impacts to traffic in 

Matagorda County during building 

phase. 

Demography SMALL to 

MODERATE 

None. Noticeable demographic impacts in 

Matagorda County during building 

phase. 

Economic 

Impacts 

SMALL to 

MODERATE 

(beneficial) 

None. None. 

Community 

Services and 

Infrastructure 

SMALL TO 

MODERATE 

Add infrastructure and 

personnel as necessary. 

Some temporary shortages of 

facilities may occur during the 

building period 

 Maintain communication with 

local government and planning 

officials so that ample time is 

given to plan for the influx of 

population during the building 

phase. Add modular 

classrooms, infrastructure, and 

personnel as necessary, during 

building phase. 

Some temporary infrastructure 

shortages and crowding in housing 

and in education facilities during 

the building period. 

Environmental 

Justice 

SMALL None. None. 
Conclusions and Recommendations 

Draft NUREG-1937 10-6 March 2010 

Table 10-1. (contd) 

Resource Area Impacts Mitigation Measures Unavoidable Adverse Impacts

Historic and 

Cultural 

SMALL Formal inadvertent discovery 

procedures are in place to 

minimize impacts to potential 

onsite historic and cultural 

resources 

None. 

Air Quality SMALL Compliance with Federal, State, 

and local regulations governing 

construction activities and 

construction vehicle emissions. 

Implementation of a dust control 

program. 

Increased equipment, vehicular, 

and fugitive dust emissions, but 

impacts would be temporary. 

Nonradiological 

Health 

SMALL Adherence to permits and 

authorizations issued by State 

and local agencies 

Temporary public health impacts 

from exposure to fugitive dust and 

vehicular emissions, noise, and 

increased occupational injuries 

and traffic fatalities during the 

building phase. 

Radiological SMALL Doses to construction workers 

would be maintained below 

NRC public dose limits. 

Small radiological dose to 

construction workers from 

operating units that would be less 

than NRC public dose limits. 

1 The primary unavoidable adverse environmental impacts during building activities would be 

2 related to land use and terrestrial habitat loss, as approximately 300 ac would be permanently 

3 disturbed and approximately 240 ac would be temporarily disturbed. All building activities for 

4 Units 3 and 4, including ground-disturbing activities, would occur within the existing STP site 

5 boundary. 

6 No surface water use is proposed during building activities. Several surface-water bodies 

7 including the Little Robbins Slough, the Main Cooling Reservoir (MCR), existing Main Drainage 

8 Channel, and proposed site drainage channels that flow to the Colorado River and the West 

9 Branch of the Colorado River would be affected during building activities. Replacement and 

10 placing of new culverts on the site would also affect some onsite sloughs. BMPs would be 

11 employed to control runoff to onsite water bodies under a Stormwater Pollution Prevention Plan 

12 (SWPPP). The impacts on surface water quality of onsite and offsite water bodies would be 

13 temporary. Dredging activities in the Colorado River near the Reservoir Makeup Pumping 

14 Facility (RMPF) and the barge slip may result in disturbance of sediments and increased 

15 turbidity. The increased turbidity would be localized and temporary. 

16 Groundwater aquifers that would potentially be affected include the Upper and Lower Shallow 

17 Aquifers into which the slurry wall, excavation, and fill would penetrate, and the Deep Aquifer in 
 Conclusions and Recommendations 

March 2010 10-7 Draft NUREG-1937 

1 which one or more additional production wells would be installed. Dewatering systems 

2 employed during excavation within the powerblock area would depress the water table in the 

3 general vicinity; however, the impacts would be localized and temporary. 

4 Ecological impacts from building the proposed units would include loss of terrestrial and aquatic 

5 habitats. Terrestrial ecological impacts would include habitat loss during clearing and grading of 

6 the proposed site, risk of avian and bat collisions with construction equipment, and direct 

7 mortality of species from onsite preconstruction and construction activities. BMPs and 

8 avoidance would be used to minimize adverse impacts to wetlands. Aquatic ecological impacts 

9 would include habitat loss from activities in the Colorado River and onsite waterbodies. 

10 SWPPPs include best management practices to manage loss of aquatic habitat during 

11 construction and preconstruction activities. 

12 Socioeconomic impacts of building the proposed units would include an increase in traffic from 

13 construction workers, and possible demand pressure on the local housing market and some 

14 other public services if workers concentrate in Matagorda County. No unusual resource 

15 dependencies on minority and low-income populations in the region were identified. 

16 Atmospheric and meteorological impacts include fugitive dust from land disturbing and building 

17 activities that can be mitigated by the dust-control plan. 

18 The review team did not identify any cultural resources that would be affected by building the 

19 proposed units. STPNOC has agreed to follow procedures if historic or cultural resources are 

20 discovered during ground-disturbing activities associated with building the proposed Units 3 and 

21 4. These procedures are detailed in STPNOC’s Addendum #5 to Procedures No. OPGP03-ZO22 0025 Rev. 12 “Unanticipated Discovery of Cultural Resources” (STPNOC 2008). 

23 Nonradiological health impacts to members of the public from construction, including public and 

24 occupational health, noise and transportation of materials, equipment and personal, would be 

25 minimal through controls and measures by STPNOC associated with compliance to Federal, 

26 State and local regulations, permits and authorizations. 

27 Radiological doses to construction workers at Units 3 and 4 from the adjacent operating units 

28 are expected to be well below regulatory limits. 

29 10.2.2 Unavoidable Adverse Impacts During Operation 

30 Chapter 5 provides a detailed discussion of the potential impacts from operation of the proposed 

31 Units 3 and 4 at the STP site and presents mitigation and controls intended to lessen the 

32 adverse impacts. Table 10-2 presents the adverse impacts associated with operation of the two 

33 proposed units to each of the resource areas evaluated in this EIS, and the mitigation measures 

34 that would reduce the impacts. Those impacts remaining after mitigation is applied are 

35 identified in the table as the unavoidable adverse impacts. 
Conclusions and Recommendations 

Draft NUREG-1937 10-8 March 2010 

1 The unavoidable adverse impacts from operation for land use would be minimal and are 

2 associated with making land unavailable for other uses until after decommissioning of the two 

3 existing and two proposed units. 

4 Water-related impacts during operation would be mitigated through STPNOC’s adherence to 

5 State permits for water withdrawal and discharge. Remaining adverse impacts to hydrological 

6 water-use and water-quality impacts during operation would be minimal and limited to increased 

7 water use, potential increases in sedimentation to surface water bodies, potential surface and 

8 groundwater contamination from inadvertent spills. 

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

Resource Area Impact Mitigation Measures

Unavoidable Adverse 

Impacts

Land Use SMALL Adherence to local land 

management plans. 

Land would not be available 

for other use until after 

decommissioning of the 

entire STP site, including 

the proposed two new units. 

Water Use SMALL Compliance with STPNOC’s 

Texas Commission for Water 

Quality (TCEQ) water rights 

permit limits and STPNOC’s 

water delivery contract with 

Lower Colorado River 

Authority (LCRA). 

Increased surface water 

use from the Colorado River 

because of the addition of 

Units 3 and 4. 

 Compliance with CPGCD 

groundwater permit limits. 

Increased groundwater use 

from the Deep Aquifer 

because of addition of Units 

3 and 4. 

Water Quality SMALL Implement BMPs and 

Stormwater Management 

Plan. 

Increased sediment load in 

stormwater and potential to 

contaminate surface and 

groundwater through 

inadvertent spills. 

 Compliance with STPNOC’s 

Texas Pollutant Discharge 

Elimination System (TPDES) 

permit 

Increased frequency of 

discharge of MCR waters to 

the Colorado River 

10 
 Conclusions and Recommendations 

March 2010 10-9 Draft NUREG-1937 

Table 10-2. (contd)

Resource Area Impact Mitigation Measures

Unavoidable Adverse 

Impacts

Ecological 

(Terrestrial) 

SMALL Implement BMPs to limit 

potential impacts from 

vegetation control, road 

maintenance, and other 

corridor activities. Follow 

Avian Protection Plan. 

Transmission line 

maintenance would prevent 

forest succession and 

maintain habitat 

fragmentation. New 

structures would represent 

an incremental increase in 

the risk of collision for birds 

and bats. Noise and 

activities during operation 

would cause wildlife to 

avoid certain areas. 

Ecological 

(Aquatic) 

SMALL RMPF already includes 

design features to mitigate 

adverse impacts. Use 

screens at circulating water 

intake structure. 

Cooling water withdrawal 

would result in 

impingement, entrainment, 

and entrapment of some 

Colorado River species. 

 Meet all applicable State and 

Federal regulatory 

requirements regarding the 

discharge of heat. 

MCR discharge thermal 

plume in the Colorado River 

may affect habitat, 

behavior, migration, 

abundance and distribution 

of some species.

 Meet all applicable State and 

Federal Clean Water Act and 

TPDES permit regulations 

and limitations. 

Nonradiological wastewater 

discharge (e.g., bio-fouling 

and other process control 

chemicals) would increase 

and this may affect aquatic 

species. 

 MCR discharge system 

design includes features to 

minimize physical impacts. 

MCR discharge into 

Colorado River may cause 

physical scouring that would 

affect aquatic species and 

habitat in the area. 

 Implement BMPs for 

maintenance and operation 

activities (e.g., approved 

herbicide usage and 

SWPPP). 

Maintenance and operation 

activities (e.g., application 

of chemicals for vegetation 

management) along 

transmission corridor could 

harm aquatic species. 

1 
Conclusions and Recommendations 

Draft NUREG-1937 10-10 March 2010 

1 

Table 10-2. (contd)

Resource Area Impact Mitigation Measures

Unavoidable Adverse 

Impacts

Socioeconomic 

Physical SMALL Continue to implement 

strategies from the building 

period with consideration of 

smaller but more permanent 

impacts 

Very minor levels of 

increased traffic; increased 

use of schools services, 

shortages of facilities and 

personnel for some public 

services in Matagorda 

County (but less than during 

the building period). 

Demography SMALL None. Matagorda County’s 

population would grow by 3 

to 4% over a few years. 

Economic Impacts SMALL to 

LARGE 

(beneficial) 

None. None. 

Community 

Services and 

Infrastructure 

SMALL Minor impact on traffic from 

additional workers. Impact 

would be minimal on 

housing demand and 

prices. 

Environmental 

Justice 

SMALL None. None. 

Historic and Cultural SMALL Formal inadvertent discovery 

procedures are in place to 

minimize impacts to potential 

onsite historic and cultural 

resources. 

None. 

Air Quality SMALL Compliance with Federal, 

State, and local air quality 

permits and regulations. 

Slight increase in certain 

criteria pollutants and CO2

due to plant auxiliary 

combustion equipment 

(e.g., diesel engines, 

combustion turbines); 

plumes and drift deposition 

from cooling towers; 

increase fogging from the 

MCR. 

Nonradiological 

Health 

SMALL State water quality 

monitoring for bacteria and 

compliance with TPDES 

permit for thermal 

discharges. 

MCR discharge thermal 

plume could encourage 

growth of etiological agents 

in Colorado River. 
 Conclusions and Recommendations 

March 2010 10-11 Draft NUREG-1937 

1 Table 10-2. (contd) 

Resource Area Impact Mitigation Measures

Unavoidable Adverse 

Impacts

 

 None. Noise from onsite systems 

(cooling towers,

transformers, loud 

speakers) would be 

<65dBA at 400 ft. 

 Conformance with Federal 

codes. 

Electrical shock from 

transmission lines. 

 Implementation of existing 

STP industrial safety 

program. 

Occupational injuries and 

illnesses. 

 Stagger arrival/departure 

times as well as outage 

schedule to minimize 

impacts to transportation 

routes. 

Accidents associated with 

transportation of operation 

and outage workers. 

Radiological SMALL Doses to members of the 

public would be maintained 

below NRC and EPA 

standards; workers’ doses 

would be maintained below 

NRC limits and As Low As 

Reasonably Achievable 

(ALARA); and mitigative 

actions instituted for 

members of the public would 

also ensure doses to biota 

other than humans would be 

well below National Council 

on Radiation and 

Measurements (NCRP) and 

International Atomic Energy 

Agency (IAEA) guidelines. 

Small radiation doses to 

members of the public 

below NRC and EPA 

standards; ALARA doses to 

workers; and biota doses 

less than NCRP and IAEA 

guidelines. 

2 Unavoidable adverse impacts to terrestrial resources would include increased risks of bird and 

3 bat collisions with structures, wildlife avoidance due to noise, and minimal impacts of salt 

4 deposition on vegetation within 660 ft of the mechanical draft cooling towers. Assuming that 

5 BMPs are followed, terrestrial impacts during operation would be minor. Aquatic impacts would 

6 be minimal during operation because the design of the intake structure on the Colorado River 

7 would have minimal effects to aquatic organisms from impingement, entrainment, and 

8 entrapment. Aquatic impacts from MCR discharge into the Colorado River would have minimal 

9 effects to aquatic organisms; however, as discussed in Section 5.3.2, under certain flow 

10 conditions the thermal plume in combination with the water quality of the Colorado River, could 
Conclusions and Recommendations 

Draft NUREG-1937 10-12 March 2010 

1 create conditions that would have noticeable affects but would not destabilize the on the aquatic 

2 community. 

3 Adverse socioeconomic impacts likely would be similar in character to those during the building 

4 phase but much smaller due to the smaller project-related population and the fact that much of 

5 the mitigation of housing and infrastructure shortages would have occurred in response to the 

6 larger impacts during the building period. Socioeconomic impacts would primarily be increased 

7 traffic, some damage to roads, an increase in the demand for housing and public services, 

8 along with increased employment opportunities and an increase in tax revenue to support the 

9 increase in service-demand. 

10 The review team did not identify any cultural resources that would be affected by operation of 

11 the proposed units. STPNOC has agreed to follow procedures if historic or cultural resources 

12 are discovered during operation activities associated with the proposed Units 3 and 4. These 

13 procedures are detailed in STPNOC’s Addendum #5 to procedures No. OPGP03-ZO-0025 Rev. 

14 12 “Unanticipated Discovery of Cultural Resources” (STPNOC 2008). 

15 It is expected that air-quality impacts would be negligible and that pollutants emitted during 

16 operations would be insignificant. Nonradiological and radiological health impacts would be 

17 minimal. Nonradiological health impacts to members of the public from operation, including 

18 etiological agents, noise, electromagnetic fields, occupational health and transportation of 

19 materials and personal, would be minimal through controls and measures by STPNOC 

20 associated with compliance to Federal and State regulations. 

21 Radiological doses to members of the public from operation of proposed Units 3 and 4 would be 

22 below NRC and EPA standards. Doses to workers from operation of proposed Units 3 and 4 

23 would also be below NRC limits and would be maintained ALARA. The radiation protection 

24 measures designed to maintain doses to members of the public below NRC and EPA standards 

25 would also ensure that doses to biota other than humans would be well below NCRP and IAEA 

26 guidelines. 

27 10.3 Relationship Between Short-Term Uses and Long-Term 

28 Productivity of the Human Environment 

29 Section 102(2)(C)(iv) of NEPA requires that an EIS include information on the relationship 

30 between local short-term uses of the environment and the maintenance and enhancement of 

31 long-term productivity. 

32 The local use of the human environment by the proposed project can be summarized in terms of 

33 the unavoidable adverse environmental impacts of construction and operation and the 

34 irreversible and irretrievable commitments of resources. With the exception of the consumption 
 Conclusions and Recommendations 

March 2010 10-13 Draft NUREG-1937 

1 of depletable resources as a result of plant construction and operation, these uses may be 

2 classed as short term. The principal short-term benefit of the plant is represented by the 

3 production of electrical energy; and the economic productivity of the site, when used for this 

4 purpose, would be extremely large compared to the productivity from agriculture or from other 

5 probable uses for the site. 

6 The maximum long-term impact to productivity would result when the plant is not immediately 

7 dismantled at the end of the period of plant operation, and consequently the land occupied by 

8 the plant structures would not be available for any other use. However, the enhancement of 

9 regional productivity resulting from the electrical energy produced by the plant is expected to 

10 result in a correspondingly large increase in regional long-term productivity that would not be 

11 equaled by any other long-term use of the site. In addition, most long-term impacts resulting 

12 from land-use preemption by plant structures can be eliminated by removing these structures or 

13 by converting them to other productive uses. Once the plants are shut down, they would be 

14 decommissioned according to NRC regulations. Once decommissioning is complete and the 

15 NRC license is terminated, the site would be available for other uses. 

16 The review team concludes that the negative aspects of plant construction and operation as 

17 they affect the human environment would be outweighed by the positive long-term 

18 enhancement of regional productivity through the generation of electrical energy. 

19 10.4 Irreversible and Irretrievable Commitments of 

20 Resources 

21 Section 102(2)(C)(v) of NEPA requires that an EIS include information on any irreversible and 

22 irretrievable commitments of resources that would occur if the proposed actions are 

23 implemented. The term “irreversible commitments of resources” refers to environmental 

24 resources that would be irreparably changed by the new units and that could not be restored at 

25 some later time to the resource’s state before the relevant activities. “Irretrievable commitments 

26 of resources” refers to materials that would be used for or consumed by the new units in such a 

27 way that they could not, by practical means, be recycled or restored for other uses. The 

28 resources discussed in this section are the environmental resources discussed in Chapters 4, 5, 

29 and 6. 

30 10.4.1 Irreversible Commitments of Resources 

31 Irreversible commitments of environmental resources resulting from Units 3 and 4, in addition to 

32 the materials used for the nuclear fuel, include: 
Conclusions and Recommendations 

Draft NUREG-1937 10-14 March 2010 

1 10.4.1.1 Land Use 

2 Land committed to the disposal of radioactive and nonradioactive wastes is committed to that 

3 use and cannot be used for other purposes. The land used for Units 3 and 4 is not irreversibly 

4 committed because once Units 3 and 4 cease operations and the plant is decommissioned in 

5 accordance with NRC requirements, the land supporting the facilities could be returned to other 

6 industrial or nonindustrial uses. 

7 10.4.1.2 Water Use 

8 Approximately 21,600 gpm of cooling water from the MCR would be lost through consumptive 

9 use (i.e., evaporation) during operation. 

10 10.4.1.3 Aquatic and Terrestrial Biota 

11 Construction, preconstruction, and operation activities would cause temporary and long-term 

12 changes to both the aquatic and terrestrial biota at the plant site and facilities. These activities 

13 would change the abundance and distribution of local terrestrial flora and fauna on the STP site; 

14 however, enough suitable habitat exists elsewhere in the area that such changes would not 

15 result in adverse impacts on the regional populations despite localized permanent loss of habitat 

16 associated with the construction footprint for Units 3 and 4. Terrestrial habitats could be 

17 restored after decommissioning of the proposed reactors and thus no irretrievable loss of 

18 terrestrial habitats would be expected. STPNOC has indicated that no wetlands would be filled 

19 or affected, thus no irretrievable loss of wetland habitats would be expected to occur. In 

20 addition, no irretrievable loss of resources detectable at the population level would be expected 

21 as a result of operations. The review team expects that no irretrievable commitment of 

22 resources affecting terrestrial habitats or species would be expected to occur associated with 

23 upgrades to the transmission corridor. 

24 Construction, preconstruction, and operation activities would adversely affect the abundance 

25 and distribution of the aquatic community, including designated essential fish habitat (EFH), in 

26 the Colorado River in the vicinity of the RMPF, barge slip, and discharge structure. The review 

27 team expects that these activities would likely have more than minimal, but less than substantial 

28 adverse effect on EFH within the Colorado River by loss of forage and/or shelter habitat as well 

29 as early life stages of some species (see EFH assessment in Appendix F). The review team 

30 expects that no irretrievable commitment of resources affecting habitat or individual species is 

31 expected to occur associated with the new transmission corridors. The aquatic habitat and 

32 aquatic populations would recover once Units 3 and 4 cease operations and the plant is 

33 decommissioned in accordance with NRC requirements. 
 Conclusions and Recommendations 

March 2010 10-15 Draft NUREG-1937 

1 10.4.1.4 Socioeconomic Resources 

2 The review team expects that no irreversible socioeconomic commitments would be made to 

3 socioeconomic resources since they would be reallocated for other purposes once the plant is 

4 decommissioned. 

5 10.4.1.5 Air and Water 

6 Dust and other emissions such as vehicle exhaust would be released to the air during 

7 construction and preconstruction. During operations, vehicle exhaust emissions would continue 

8 and other air pollutants and chemicals including very low concentrations of radioactive gases 

9 and particulates would be released from the facility to the air and surface water. Because these 

10 releases would conform to applicable Federal and State regulations, their impact to the public 

11 health and the environment would be limited. The review team expects no irreversible 

12 commitment to air or water resources because all Unit 3 and 4 releases would be made in 

13 accordance with duly issued permits. 

14 10.4.2 Irretrievable Commitments of Resources 

15 A study by the U.S. Department of Energy (DOE/EIA 2006) on new reactor construction 

estimated the following quantities of materials would be required for a single reactor: 12,239 yd3 16 

17 of concrete, 3107 tons of rebar, 13,000,000 ft of cable, and 275,000 ft of piping. Therefore, 

18 about twice these amounts would be needed for proposed Units 3 and 4 at STP, and 

19 considerably more would be required for all the other site structures. 

20 The review team expects that the use of construction materials in the quantities associated with 

21 those expected for Units 3 and 4 at the STP site, while irretrievable, would be of small 

22 consequence with respect to the availability of such resources. 

23 The main resource that would be irretrievably committed during operation of the new nuclear 

24 units would be uranium. The availability of uranium ore and existing stockpiles of highly 

25 enriched uranium in the United States and Russia that could be processed into fuel is sufficient 

26 (OECD NEA and IAEA 2008), so that the irreversible and irretrievable commitment would be 

27 negligible. 

28 10.5 Alternatives to the Proposed Action 

29 Alternatives to the proposed actions are discussed in Chapter 9. Alternatives considered are 

30 the no-action alternative, energy production alternatives, system design alternatives, and 

31 alternative sites. For the purposes of the Corps’ evaluation, onsite alternatives are also 

32 addressed in Section 9.5. 
Conclusions and Recommendations 

Draft NUREG-1937 10-16 March 2010 

1 The NRC no-action alternative, described in Section 9.1, refers to a scenario in which the NRC 

2 would deny the STPNOC’s request for the COLs. Upon such a denial by the NRC, the 

3 construction and operation of two new nuclear units at the STP site in accordance with 10 CFR 

4 Part 52 would not occur and the predicted environmental impacts associated with the project 

5 would not occur. If no other power plant were built or electrical power supply strategy 

6 implemented to take its place, the electrical capacity to be provided by the project would not 

7 become available, and the benefits (electricity generation) associated with the proposed action 

8 would not occur and the need for power would not be met. 

9 Alternative energy sources are described in Section 9.2. Alternatives that would not require 

10 additional generating capacity are described in Section 9.2.1. Detailed analyses of coal- and 

11 natural-gas-fired alternatives are provided in Section 9.2.2. Other energy sources are 

12 discussed in Section 9.2.3. A combination of energy alternatives is discussed in Section 9.2.4. 

13 The NRC staff concluded that none of the alternative energy options were both (1) consistent 

14 with STPNOC’s objective of building baseload generation units, and (2) environmentally 

15 preferable to the proposed action. 

16 Alternative sites are discussed in Section 9.3. The cumulative impacts of building and operating 

17 the proposed facilities at the alternative sites are compared to the impacts at the proposed STP 

18 site in Section 9.3.5. Table 9-20 contains the review team’s characterization of cumulative 

19 impacts at the proposed and alternative sites. Based on this review, the NRC staff concludes 

20 that while there are differences in cumulative impacts at the proposed and alternative sites, 

21 none of the alternative sites would be environmentally preferable or obviously superior to the 

22 proposed STP site. The NRC’s determination is independent of the Corps’ determination of a 

23 Least Environmentally Damaging Practicable Alternative pursuant to Clean Water Act Section 

24 404(b)(1) guidelines. The Corps will conclude its analysis of both offsite and onsite alternatives 

25 in its Record of Decisions. 

26 Alternative heat dissipation and circulating water system designs are discussed in Section 9.4. 

27 The NRC staff concluded that none of the alternatives considered would be environmentally 

28 preferable to the proposed system designs.

29 10.6 Benefit-Cost Balance 

30 NEPA requires that all agencies of the Federal Government prepare detailed environmental 

31 statements on proposed major Federal actions that can significantly affect the quality of the 

32 human environment. A principal objective of NEPA is to require each Federal agency to 

33 consider, in its decision making process, the environmental impacts of each proposed major 

34 action and the available alternative actions. In particular, Section 102 of NEPA requires all 

35 Federal agencies to the fullest extent possible: 
 Conclusions and Recommendations 

March 2010 10-17 Draft NUREG-1937 

1 “(B) identify and develop methods and procedures, in consultation with the 

2 Council on Environmental Quality established by title II of this Act, which will 

3 insure that presently unquantified environmental amenities and values may be 

4 given appropriate consideration in decisionmaking along with economic and 

5 technical considerations.” (42 USC 4321) 

6 However, neither NEPA nor CEQ requires the costs and benefits of a proposed action be 

7 quantified in dollars or any other common metric. 

8 The intent of this section is not to identify and quantify all of the potential societal benefits of the 

9 proposed actions and compare these to the potential costs of the proposed actions. Instead, 

10 this section will focus on only those benefits and costs of such magnitude or importance that 

11 their inclusion in this analysis can inform the decision-making process. This section compiles 

12 and compares the pertinent analytical conclusions reached in earlier chapters of this EIS. It 

13 gathers all of the expected impacts from building and operations of the proposed Units 3 and 4 

14 and aggregates them into two final categories: the expected costs and the expected benefits. 

15 The benefit-cost balancing for the NRC action will be based on a balancing of the benefits and 

16 costs of construction and operation. 

17 Although the analysis in this section is conceptually similar to a purely economic benefit-cost 

18 analysis, which determines the net present dollar value of a given project, the intent of this 

19 section is to identify all potential societal benefits of the proposed actions and compare these to 

20 the potential internal (i.e., private) and external (i.e., societal) costs of the proposed actions. 

21 The purpose is to generally inform the COL process by gathering and reviewing information that 

22 demonstrates the likelihood that the benefits of the proposed actions outweigh the aggregate 

23 costs. 

24 General issues related to STPNOC’s financial viability and those of its parent organizations are 

25 outside NRC’s mission and authority and, thus, would not be considered in this EIS. Issues 

26 related to the financial qualifications of STPNOC will be addressed in the NRC staff’s safety 

27 evaluation report. It is not possible to quantify and assign a value to all benefits and costs 

28 associated with the proposed action. This analysis, however, attempts to identify, quantify, and 

29 provide monetary values for benefits and costs when reasonable estimates are available. 

30 Section 10.6.1 discusses the benefits associated with the proposed action. Section 10.6.2 

31 discusses the costs associated with the proposed action. A summary of benefits is shown in 

32 Table 10-3. Section 10.6.3 provides a summary of the impact assessments, bringing previous 

33 sections together to establish a general impression of the relative magnitude of the proposed 

34 actions’ costs and benefits. 
Conclusions and Recommendations 

Draft NUREG-1937 10-18 March 2010 

1 10.6.1 Benefits

2 The most apparent benefit from a power plant is that it generates power and provides 

3 thousands of residential, commercial, and industrial consumers with electricity. Maintaining an 

4 adequate supply of electricity in any given region has social and economic importance because 

5 adequate electricity is the foundation for economic stability and growth and fundamental to 

6 maintaining our current standard of living. Because the focus of this EIS is on the proposed 

7 expansion of the STP site generating capacity, this section focuses primarily on the relative 

8 benefits of the STP option rather than the broader, more generic benefits of electricity supply. 

9 Table 10-3. Summary of Benefits of the Proposed Action 

Benefit 

Category Description

Monetized Value or 

Impact Assessment

Benefits

Electricity 

generated 

20,000,000 to 22,000,000 MWh (Megawatt hour) per year for 

the 40-year life of the plant (assuming capacity factors in the 

range of 85-93 percent). 

Generating 

capacity 

2700 MW (two units at 1350 MW each). 

Fuel diversity 

and energy 

security 

Nuclear option provides diversity to coal- and natural-gas-fired 

baseload generation. Reduces exposure to supply and price 

risk associated with reliance on any single fuel source. 

Tax revenues Tax payments and service fees in In-lieu-of-taxes increase as 

STPNOC’s investment in building grows and as Units 3 and 4 

start generating electricity (see Sections 4.4.3.2 and 5.4.3.2). 

Franchise tax amount shown is based on STPNOC’s estimate 

of gross margin at 100 percent taxability. Under the proposed 

settlement between NINA and CPS (NINA 2010, CPS 2010), 

both units are projected to be about 8 percent owned by nontaxable entities. Property taxes based on STPNOC’s estimate 

of capital cost and a range of 44 percent to 100 percent 

taxability. Capital cost may be higher, as described in Section 

10.6.2.1. 

Operations, between $4.7 

and $5.4 million (2015) and 

$8.6-$10.0 million per year 

(later years) in franchise 

taxes. $9.5 - $21.5 million 

per year in property taxes 

Local economy Increased jobs would benefit the area economically and 

increase the economic diversity of region (see 

Sections 4.4.3.1 and 5.4.3.1) 

1620 total regional 

employment; $73 million 

per year regional income 

Price Volatility Would dampen potential for fuel price volatility. 

Electrical 

Reliability 

Would enhance reliability of electricity supply. 
 Conclusions and Recommendations 

March 2010 10-19 Draft NUREG-1937 

1 10.6.1.1 Societal Benefits 

2 For the production of electricity to be beneficial to a society, there must be a corresponding 

3 demand, or “need for power,” in the region. Chapter 8 defines and discusses the need for 

4 power in more detail. From a societal perspective, nuclear power offers two primary benefits 

5 relative to most other generating systems: long-term price stability and energy security through 

6 fuel diversity. These benefits are described in this subsection. 

7 Long-term Price Stability 

8 Because of its relatively low and non-volatile fuel costs, nuclear energy is a dependable 

9 generator of electricity that can provide electricity to the consumer at relatively stable prices 

10 over a long period of time. Unlike some other energy sources, nuclear energy is generally not 

11 subject to unreliable weather or climate conditions, unpredictable cost fluctuations, and is less 

12 dependent on foreign suppliers than other energy sources. Nuclear power plants are generally 

13 not subject to fuel price volatility like natural gas and oil power plants. In addition, uranium fuel 

14 constitutes only 3 percent to 5 percent of the cost of a kilowatt-hour of nuclear-generated 

15 electricity. Doubling the price of uranium increases the cost of electricity by about 9 percent; 

16 while doubling the price of gas would add about 66 percent to the price of electricity, and 

17 doubling the cost of coal would add about 31 percent to the price of electricity (WNA 2010). 

18 Energy Security through Fuel Diversity

19 Currently, more than 70 percent of the electricity generated in the United States is generated 

20 with fossil-based technologies; thus, non-fossil-based generation, such as nuclear generation, is 

21 essential to maintaining diversity in the aggregate power-generation fuel mix (DOE/EIA 2006). 

22 Nuclear power contributes to the diverse U.S. energy mix, hedging the risk of shortages and 

23 price fluctuations for any one power-generation system and reducing the nation’s dependence 

24 on imported fossil fuels. 

25 A diverse fuel mix helps to protect consumers from contingencies such as fuel shortages or 

26 disruptions, price fluctuations, and changes in regulatory practices. ERCOT’s 2007 fuel mix for 

27 annual generation was made up of approximately 46 percent natural gas, 37 percent coal, 

28 13 percent nuclear, and 4 percent hydroelectric and renewables (ERCOT 2008). Summer 

29 capacity is more concentrated in natural-gas fired plants due to the need to address summer 

30 peak. Summer capacity percentages are natural gas, 72 percent; coal, 18 percent; nuclear, 

31 7 percent; and hydroelectric and renewables, about 3 percent. Efficiency programs and loads 

32 serving as reserves meet about 2 percent of summer peak demand (ERCOT 2009). The 

33 effective load–carrying capacity of wind generation is rated by ERCOT at 8.7 percent of 

34 nameplate, or about 708 MW total in 2009 (ERCOT 2009). ERCOT is planning a capacity mix 

35 that provides the region with a hedge against the risks of future shortages and price fluctuations. 

36 The building of STP Units 3 and 4 fits with ERCOT’s strategy to continue generating power with 

37 a diverse fuel mix. 
Conclusions and Recommendations 

Draft NUREG-1937 10-20 March 2010 

1 10.6.1.2 Regional Benefits 

2 Regional benefits of the proposed construction and operation of Units 3 and 4 include enhanced 

3 tax revenues, regional productivity, and community impacts. 

4 Tax Revenue Benefits 

5 NINA South Texas 3 LLC and NINA South Texas 4 LLC, STPNOC’s taxable entities, would 

6 make tax payments and in-lieu-of tax payments to the State of Texas, Matagorda County, 

7 Palacios School District, and to other special taxing districts within Matagorda County. Tax 

8 payments on existing units are shown in Section 2.5.2.2, and taxes for the proposed Units 3 and 

9 4 are identified in Sections 4.4.3.2 and 5.4.3.2 

10 As the owners of Units 3 and 4 invest in building the power plant, the growing book value of the 

11 plant can increase the proportion of STPNOC’s property tax payments that the local taxing 

12 districts receive. This is on a construction work in progress basis, as power property is 

13 amortized, the proportion of tax equivalent payments may decline. The amount of property tax 

14 payments received by Matagorda County, some special service districts and the Palacios 

15 Independent School District would significantly increase with the construction and operation of 

16 STP Units 3 and 4 (see Sections 4.4.3.2 and 5.4.3.2). These impacts are discussed in Sections 

17 4.4 and 5.4 of this document. 

18 In addition to in-lieu-of-tax payments by STPNOC, a variety of taxes would be paid on the 

19 wages, earnings, and expenditures that result from the owners of STPNOC’s investment in the 

20 construction of proposed Units 3 and 4. These various taxes are also described in Sections 4.4 

21 and 5.4 of this document. 

22 Regional Productivity and Community Impacts 

23 The new units would require a net increase in the operating workforce of 656 people who would 

24 stimulate the creation of 964 additional indirect jobs (Section 4.5 and 5.5) within the 50-mi region 

25 of STP influence, or a total of approximately 1620 new jobs within the region that would be 

26 maintained throughout the life of the plant. The economic multiplier effect of the increased 

27 spending by the direct and indirect workforce created as a result of two new units would 

28 increase the economic activity in the region, most noticeably in Matagorda County (STPNOC 

29 2009a). Sections 4.5.3.1 and 5.5.3.1 provide additional information on the economic impacts of 

30 constructing and operating proposed Units 3 and 4 on the STP site. 

31 The NRC staff’s interviews in communities surrounding the STP site revealed high perceived 

32 benefit to having the jobs, income, and people associated with the nuclear plant in their area 

33 (Scott and Niemeyer 2008). 
 Conclusions and Recommendations 

March 2010 10-21 Draft NUREG-1937 

1 10.6.2 Costs

2 Internal costs to the proposed owners of Units 3 and 4 as well as external costs to the 

3 surrounding region and environment would be incurred during the construction, preconstruction, 

4 and operation of two new units at the STP site. A summary of the costs is shown in Table 10-4. 

5 Internal costs include all of the costs included in a total capital cost assessment—the direct and 

6 indirect cost to physically build the power plant (capital costs), plus the annual costs of operation 

7 and maintenance, fuel costs, waste disposal, and decommissioning costs. In accordance with 

8 the NRC staff’s guidance in NUREG-1555 (NRC 2000), internal costs of the proposed project 

9 are presented in monetary terms. External costs include all costs imposed on the environment 

10 and region surrounding the plant that are not internalized by the company and may include such 

11 things as a loss of regional productivity, environmental degradation, or loss of wildlife habitat. 

12 The external costs listed below in Table 10-4 summarize environmental impacts to resources 

13 that could result from preconstruction, construction, and operation of the proposed Units 3 and 

14 4. Because Table 10-4 includes costs from preconstruction activities, it overestimates the costs 

15 for the proposed NRC action. 

16 Table 10-4. Summary of Costs of Preconstruction, Construction, and Operation 

Cost Category Description

Impact 

Assessment(a)

Internal Costs(b)

Construction cost $6.2-$11.1 billion for the two STP units (overnight capital cost 

– 2008$)(c)

Operating cost 3.8–8.6 cents per kWh (levelized cost of electricity – 2008$) 

Fuel cost is about 0.7 cents per kWh(d)

Spent fuel 

management(e)

Approximately 0.1 cents per kWh 

Decommissioning(f) Approximately 0.1 to 0.2 cents per kWh 

Material and 

resources(g)

480,000 yds3

 concrete (2 units) 

26,000 tons structural steel 

18 million linear ft of cable 

110,000 linear ft of large bore piping having diameter >2.5 in. 

34,000 metric tons of uranium 

Land use Already utilized plant site of approximately 12,200 ac of which 

about 300 ac are occupied on a long-term basis by the two 

new nuclear reactors and associated infrastructure. Rights-ofway maintained for transmission lines (see Sections 4.1 and 

5.1). 

External Costs 

Land use No new land acquired for new transmission line rights-of-way 

would be taken out of other productive or beneficial use (see 

Sections 4.1 and 5.1). 

SMALL 
Conclusions and Recommendations 

Draft NUREG-1937 10-22 March 2010 

1 

2 Table 10-4. (contd.)

Cost Category Description 

Impact 

Assessment(a)

Air quality impacts Negligible impacts associated with sulfur dioxide, nitrogen 

oxide, carbon monoxide, carbon dioxide, and particulate 

emissions (Sections 4.7 and 5.7). 

SMALL 

Ecological impacts Terrestrial habitat loss (approximately 300 ac). STPNOC’s 

adherence to the NPDES permit would likely result in 

balanced aquatic populations. No threatened or endangered 

terrestrial or aquatic species likely to be adversely affected 

(see Sections 4.3 and 5.3). EFH for some species would be 

adversely affected (more than minimal but less than 

substantial). 

SMALL 

Physical Impacts Traffic noise impacts limited primarily to boundaries of the site 

and immediate neighborhood. Temporary stress on road/local 

road network because of congestion during building and 

potential degradation from building and operation activities 

(see Sections 4.4.1 and 5.4.1). 

SMALL 

 Because a two unit operating plant already exists onsite, very 

little marginal impact on aesthetic and recreation from 

additional reactors (see Sections 4.4.1.4, 4.5.3.4, 5.4.1.4, and 

5.4.3.4). 

Community 

Services and 

Infrastructure 

Potential short-term strain on some community services and 

short-term strain on housing in Matagorda County during early 

stages of 7-year construction period (see Sections 4.5.4.3 and 

4.5.4.4). 

MODERATE 

Health Impacts 

(Nonradiological 

and Radiological) 

Minor estimated temperature increases would not significantly 

increase the abundance of thermophilic microorganisms. 

Radiological doses and nonradiological health hazards to the 

public and occupational workers would be monitored and 

controlled in accordance with regulatory limits (see Sections 

4.8, 4.9, 5.8, and 5.9). 

SMALL 

(a) Impact assessments are listed for all impacts evaluated in detail as part of this EIS. The details on impact assessments are 

found in the indicated sections of this EIS. 

(b) Internal costs are those incurred by STPNOC to implement proposed building and operation of the STP site. Note that no 

impact assessments are provided for these private financial impacts. 

(c) $5.4 billion is based on $2000/kW(e) in 2003$ used in STPNOC 2009a, escalated to 2008$. $11.1 billion is based on 

$4000/kW(e) in 2007$, estimated in MIT 2009, escalated to 2008$, 

(d) Review team calculation of price per kWh based on MIT (2009). 

(e) U.S. used fuel program is funded by a 0.1 cent/kWh levy. 

(f) USA experience (WNA 2010). 

(g) From STPNOC 2009a and based on referenced plant design, which could change if the plant design is modified. 
 Conclusions and Recommendations 

March 2010 10-23 Draft NUREG-1937 

1 10.6.2.1 Internal Costs 

2 The most substantial monetary cost associated with nuclear energy is the cost of capital 

3 construction. Nuclear power plants have relatively high capital costs for building the plant but 

4 low fuel costs relative to alternative power-generation systems. The real prices of key heavy 

5 construction commodities, such as cement, steel, and copper, have increased substantially in 

6 recent years, which would have a significant impact on nuclear plant capital costs (although it 

7 should be noted that these price increases would increase construction costs for non-nuclear 

power plants as well).(a) 8 Because of the large capital costs for nuclear power, and the relatively 

9 long construction period before revenue is returned, servicing the capital costs of a nuclear 

10 power plant is a key factor in determining the economic competitiveness of nuclear energy. 

11 Construction delays can add significantly to the cost of a plant. Because a power plant does not 

12 yield profits during construction, longer construction times mean a longer time before any costs 

13 can be offset by revenues. Furthermore the longer it takes to build the plant, the higher would 

14 be the interest expenses on borrowed construction funds. In general, because no new nuclear 

15 plants have been built in the United States in many years, there is a great deal of uncertainty 

16 about the true costs of a new unit, which can affect the cost of capital, further increasing the 

17 cost of the proposed project. 

18 Construction Costs 

19 In evaluating monetary costs related to constructing proposed Units 3 and 4, the review team 

20 reviewed recent published literature, vendor information, internally generated financial 

21 information, and internally generated, site-specific information. The review team also compared 

22 recent cost estimates with STPNOC’s. The cost estimates reviewed were not based on nuclear 

23 plant construction experience in the United States, which is more than 20 years old, but rather 

24 on more recent studies and more recent plant construction costs overseas. 

25 Capital costs are costs incurred during construction, including preconstruction, when the actual 

26 outlays for equipment and construction and engineering are made. “Overnight capital costs” 

27 include engineering, procurement, and construction costs; however, it is presumed that the plant 

28 is constructed overnight; thus, interest is not included. STPNOC based its estimates of 

29 overnight capital costs for construction and preconstruction on analysis of four comprehensive 

30 studies of nuclear plant costs (University of Chicago 2004; MIT 2003; DOE 2004; OECD 2005), 

31 in which estimates ranged from $1100 per kW to $2500 per kW (in 2002 dollars). STPNOC 

32 estimates that the top end of the overnight cost range increased to around $2000 per kW in 

33 2003 dollars (equivalent to about $2200 per KW in 2008 dollars). On this basis, STPNOC 

 

(a) Although in real terms, the construction costs for large projects remained relatively flat from 1998 to 2002, 

various construction cost indices from such sources as the Electric Power Research Institute and McGraw Hill 

estimate real cost escalation for large power plant construction projects to be approximately 4 percent per year 

since 2002 (through 2007). This is based on actual field data as well as data on commodity costs, labor cost 

information, and other equipment (USDI/Reclamation 2008). 
Conclusions and Recommendations 

Draft NUREG-1937 10-24 March 2010 

1 estimates an overnight capital cost for the two STP units of $5.4 billion in 2003 dollars ($6.1 

2 billion in 2008 dollars) (STPNOC 2009a). In addition to the studies STPNOC used, the review 

3 team also considered three other more recent studies: two estimates of construction costs from 

4 other applicants and a 2009 update to the 2003 MIT study on the cost of nuclear power (MIT 

5 2009). 

6  Tennessee Valley Authority estimated its per kW cost of construction for two new proposed 

7 AP1000 units at its Bellefonte site in Alabama between $2850 and $3200 per kW (TVA 

8 2008), which if applied to proposed Units 3 and 4 at STP (installed capacity of 2700 MWe), 

9 would yield an overnight capital cost of $7.7 to $8.7 billion. 

10  Southern Nuclear Operating Company estimated the overnight cost of construction for two 

11 AP1000 units at its Vogtle site in Georgia between $3200 and $3500 kW (Southern 2008), 

12 which if applied to proposed Units 3 and 4 at STP would yield an overnight capital cost of 

13 $8.7 billion to $9.5 billion. 

14  The MIT Update (MIT 2009) estimated the overnight construction cost at $4000 per kW in 

15 2007$ (about $4100 per kW in 2008$) or about $11.1 billion for 2700 MWe in 2008$. 

16 All of these estimates include the cost of both preconstruction and construction activities. 

17 Thus, they overestimate the costs of the proposed NRC action and provide a conservative 

18 estimate of the costs for the benefit-cost analysis. 

19 Operation Costs 

20 Operation costs are frequently expressed as levelized cost of electricity, which is the lowest 

21 price per kilowatt-hour of producing electricity that covers operating costs, annualized capital 

22 costs, and a reasonable profit. For nuclear power plants, overnight capital costs typically 

23 account for a third of the levelized cost, and interest costs on the overnight costs account for 

24 another 25 percent (University of Chicago 2004). STPNOC estimated that the levelized cost for 

25 STP would be in the range of $36 to $65 per MWh (3.6 to 6.5 cents per kWh), which is the 

26 range estimated by the four studies mentioned above (STPNOC 2009; University of Chicago 

27 2004; MIT 2003; DOE 2004; OECD 2005). In addition, the review team examined the update to 

28 the MIT study (MIT 2009) which re-evaluated the overnight levelized cost of electricity at 8.4 

29 cents per kWh (2007$). In 2008 dollars, this yields an overall range of 3.8 to 8.6 cents per kWh. 

30 Factors affecting the range include choices for discount rate, construction duration, plant life 

31 span, capacity factor, cost of debt and equity, and split between debt and equity financing, 

32 depreciation time, tax rates, and premium for uncertainty. Estimates include decommissioning 

33 but, because of the effect of discounting a cost that would occur as much as 40 years or more in 

34 the future, decommissioning costs have relatively little effect on the levelized cost. 
 Conclusions and Recommendations 

March 2010 10-25 Draft NUREG-1937 

1 Fuel Costs 

2 STPNOC calculated nuclear fuel cost and decommissioning cost separately using information 

3 from a study published jointly by the University of Chicago (2004). In the report, the University 

4 of Chicago estimated the average fuel cost for a nuclear generating plant to be $4.35 per MWh, 

5 or 0.4 cents per kWh. Based on the recent World Nuclear Association’s study (WNA 2010), the 

6 review team estimated nuclear fuel costs to be $0.449 cents per kWh (WNA 2010). 

7 Waste Disposal 

8 The back-end costs of nuclear power contribute a very small share of total cost because of both 

9 the long lifetime of a nuclear reactor and the fact that provisions for waste-related costs can be 

10 accumulated over that time. Spent fuel management costs are estimated to be 0.1 cents per 

11 kWh (WNA 2010; DOE 2008). It should be recognized, however, that radioactive nuclear waste 

12 poses unique disposal challenges for long-term management. While spent fuel and radioactive 

13 nuclear waste are being stored successfully in on-site facilities, the United States has yet to 

14 implement final disposition of spent fuel or high-level radioactive waste streams created at 

15 various stages of the nuclear fuel cycle. 

16 Decommissioning 

17 NRC has requirements for licensees at 10 CFR 50.75 to provide reasonable assurance that 

18 funds would be available for the decommissioning process. Because of the effect of discounting 

19 a cost that would occur as much as 40 years in the future, decommissioning costs have 

20 relatively little effect on the levelized cost of electricity generated by a nuclear power plant. 

21 Decommissioning costs are about 9 to 15 percent of the initial capital cost of a nuclear power 

22 plant. However, when discounted, they contribute only a few percent to the investment cost and 

23 even less to generation cost. In the United States, they account for 0.1 to 0.2 cents per kWh 

24 (WNA 2010). 

25 10.6.2.2 External Costs 

26 External costs are social and/or environmental effects that would be caused by the construction 

27 of and generation of power by two new reactors at the STP site. This EIS includes the review 

28 team’s analysis that considers and weighs the environmental impacts of building and operating 

29 new nuclear units at the STP site or at alternative sites and mitigation measures available for 

30 reducing or avoiding these adverse impacts. It also includes the NRC staff’s recommendation 

31 to the Commission regarding the proposed action. 

32 Environmental and Social Costs 

33 Chapter 4 describes the impacts of constructing the proposed Units 3 and 4 on the environment 

34 with respect to the land, water, ecology, socioeconomics, radiation exposure to construction 
Conclusions and Recommendations 

Draft NUREG-1937 10-26 March 2010 

1 workers, and measures and controls to limit adverse impacts during building of the proposed 

2 new units at the STP site. Chapter 5 examines environmental issues associated with operation 

3 of the proposed new nuclear Units 3 and 4 for an initial 40-year period. Potential operational 

4 impacts on land use, air quality, water, terrestrial and aquatic ecosystems, socioeconomics, 

5 historic and cultural resources, environmental justice, nonradiological and radiological health 

6 effects, postulated accidents, and applicable measures and controls that would limit the adverse 

7 impacts of station operation during the 40-year operating period are considered. In accordance 

8 with 10 CFR Part 51, all impacts identified in Chapters 4 and 5 have been analyzed, and a 

9 significance level of potential adverse impacts (i.e., SMALL, MODERATE, or LARGE) has been 

10 assigned. 

11 Chapter 6 addresses the environmental impacts from: (1) the uranium fuel cycle and solid 

12 waste management, (2) the transportation of radioactive material, and (3) the decommissioning 

13 of nuclear units at the STP site. Chapter 9 includes the review team's review of alternative sites 

14 and alternative power generation systems. 

15 Unlike generation of electricity from coal and natural gas, normal operation of a nuclear power 

16 plant does not result in any emissions of criteria (e.g., oxides of nitrogen or sulfur dioxide,), 

17 methyl mercury, or greenhouse gases associated with global warming and climate change. 

18 Whereas combustion-based power plants are responsible for at least 70 percent of the sulfur 

19 dioxide, at least 21 percent of nitrogen oxides, and 51 percent of the mercury emissions from 

20 industrial sources in the United States (EPA 2009), and 40 percent of the carbon dioxide 

21 (DOE/EIA 2008). Eighty-two percent of the electric power industry’s emissions are from coal22 fired plants (DOE/EIA 2008). Chapter 9 analyzes coal- and natural-gas-fired alternatives to the 

23 building and operation of proposed STP Units 3 and 4. Air emissions from these alternatives 

24 and nuclear power are summarized in Chapters 4, 5 and 9. 

25 As mentioned previously, Table 10-4 summarizes the external costs (i.e., environmental 

26 impacts) associated with the preconstruction, construction, and operation of the proposed STP 

27 Units 3 and 4. Impacts to land use, air quality, aquatic and terrestrial ecology, housing, 

28 transportation, public services, aesthetics and recreation, cultural resources, and radiological 

29 and nonradiological health would all be SMALL. Because the overall impact to these resources 

30 from the proposed project in its entirety would be SMALL, the NRC portion of the project 

31 (i.e., construction as defined in 10 CFR 51.4, and operation of the proposed new units) 

32 accordingly would also be SMALL. 

33 10.6.3 Summary of Benefits and Costs

34 The internal costs to construct additional units appear to be substantial; however, STPNOC’s 

35 decision to pursue this expansion implies that it has concluded that the internal benefits of the 

36 proposed facility (production of 20,000,000 to 22,000,000 MWh per year for the 40-year life of 

37 the plant and 2700 MW of baseload capacity) outweigh the internal costs. Although no specific 
 Conclusions and Recommendations 

March 2010 10-27 Draft NUREG-1937 

1 monetary values could reasonably be assigned to the identified societal benefits, it would 

2 appear that the potential societal benefits of the proposed Units 3 and 4, including the primary 

3 benefit of the generated power and baseload capacity, are substantial. In comparison, the 

4 external socio-environmental costs imposed on the region appear to be relatively small. 

5 Table 10-3 includes a summary of both internal and external costs of the proposed activities at 

6 the STP site for Units 3 and 4, as well as the identified benefits. The table includes a reference 

7 to other sections of this EIS where more detailed analyses and impact assessments are 

8 available for specific topics. These assessments are included in the table. 

9 On the basis of the assessments summarized in this EIS, building and operating the proposed 

10 Units 3 and 4, with mitigation measures identified by the review team, would have accrued 

11 benefits that most likely would outweigh the economic, environmental, and social costs. For the 

12 NRC-proposed action (NRC-authorized construction and operation) the accrued benefits would 

13 also outweigh the costs of construction and operation of Units 3 and 4. 

14 10.7 Staff Conclusions and Recommendations 

15 The NRC staff’s preliminary recommendation to the Commission related to the environmental 

16 aspects of the proposed action is that the COLs should be issued. The NRC staff’s evaluation 

17 of the safety and emergency preparedness aspects of the proposed action will be addressed in 

18 the staff’s safety evaluation report that is anticipated to be published in 2011. 

19 The staff’s preliminary recommendation is based on (1) the ER submitted by STPNOC 

20 (STPNOC 2009a), (2) consultation with Federal, State, Tribal, and local agencies, (3) the review 

21 team’s own independent review, (4) the staff’s consideration of public scoping comments, and 

22 (5) the assessments summarized in this EIS, including the potential mitigation measures 

23 identified in the ER and in the EIS. In addition, in making its preliminary recommendation, the 

24 staff determined that none of the alternative sites assessed is obviously superior to the STP 

25 site. 

26 The NRC’s determination is independent of the Corps’ determination of a Least Environmentally 

27 Damaging Practicable Alternative pursuant to Clean Water Act Section 404(b)(1) Guidelines. 

28 The Corps will conclude its analysis of both offsite and onsite alternatives in its Record of 

29 Decision. 

30 10.8 References 

31 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 

32 Production and Utilization Facilities." 
Conclusions and Recommendations 

Draft NUREG-1937 10-28 March 2010 

1 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 

2 Protection Regulations for Domestic Licensing and Related Regulatory Functions." 

3 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 

4 Certifications, and Approvals for Nuclear Power Plants." 

5 33 CFR Part 332. Code of Federal Regulations, Title 10, Navigation and Navigable Waters, Part 

6 332, “Compensatory Mitigation for Losses of Aquatic Resources.” 

7 40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment, Part 

8 1508, "Terminology and Index." 

9 72 FR 57416. October 9, 2007. "Limited Work Authorizations for Nuclear Power Plants." 

10 Federal Register. U.S. Nuclear Regulatory Commission. 

11 CPS Energy (CPS). 2010. February 17, 2010, News Release, “CPS Energy, NINA Reach 

12 Agreement.” Accession No. ML100670377. 

13 Electric Reliability Council of Texas (ERCOT). 2008. Report on Existing and Potential Electric 

14 System Constraints and Needs December, 2008. Accessed April 9, 2009 at 

15 http://www.ercot.com/news/presentations/2008/index. Accession No. ML100670568 

16 Electric Reliability Council of Texas (ERCOT). 2009. Report on the Capacity, Demand, and 

17 Reserves in the ERCOT Region, System Planning. Accessed June 24, 2009 at 

18 http://www.ercot.com/content/news/presentations/2009/2009%20ERCOT%20Capacity,%20De

19 mand%20and%20Reserves%20Report.pdf. Accession No. ML100600754. 

20 Federal Water Pollution Control Act (Clean Water Act). 33 USC 1251, et seq. 

21 Massachusetts Institute of Technology (MIT). 2003. The Future of Nuclear Power: An 

22 Interdisciplinary MIT Study. Accessed February 4, 2008 at http://web.mit.edu/nuclearpower/. 

23 Accession No. ML100600694. 

24 Massachusetts Institute of Technology (MIT). 2009. Update of The Future of Nuclear Power: 

25 An Interdisciplinary MIT Study. Accessed July 23, 2009 at 

26 http://web.mit.edu/nuclearpower/pdf/nuclearpower-update2009.pdf. Accession No. 

27 ML100600695. 

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

29 Nuclear Energy Agency, International Energy Agency, and Organization for Economic Co30 operation and Development and (NEA/IEA/OECD). 2005. Projected Costs of Generating 

31 Electricity – 2005 Update. International Energy Agency, Paris, France. 
 Conclusions and Recommendations 

March 2010 10-29 Draft NUREG-1937 

1 Nuclear Innovation North America (NINA). 2010. February 17, 2010, News Release, “Nuclear 

2 Innovation North American (NINA) Moving Forward with South Texas Project (STP) Expansion.” 

3 Accession No. ML100670379. 

4 Organization for Economic Co-operation and Development (OECD). 2005. Nuclear Energy 

5 Agency, Organization for Economic Co-operation and Development, and International Energy 

6 Agency, Projected Costs of Generating Electricity; 2005 Update. Access March 7, 2010 at 

7 http://www.oecdbookshop.org/oecd/display.asp?K=5LH1VDKBQCTB&tag=XNJB98XX4X48891

8 8XKCJS5&lang=EN&sort=sort_date/d&sf1=Title&st1=electricity&sf3=SubjectCode&st3=34&st4

9 =not+E4+or+E5+or+5&sf4=SubVersionCode&ds=electricity%3B+Energy%3B+&m=17&dc=58&

10 plang=en. Accession No. ML100600699. 

11 Organization for Economic Co-operation and Development Nuclear Energy Agency and 

International Atomic Energy Agency (OECD NEA and IAEA). 2008. Uranium 2007. 22nd 12 ed., 

13 Paris. 

14 Rivers and Harbors Appropriation Act of 1899, as amended. 33 USC 403, et seq. 

15 Scott, M., and M. Niemeyer. 2008. South Texas Project -- Interviews with the Public; 

16 Socioeconomic and Environmental Justice. Pacific Northwest National Laboratory. Accession 

17 No. ML092100141. 

18 South Texas Project Nuclear Operating Company (STPNOC). 2008. Letter from Mark 

19 McBurnett, STPNOC, to NRC, dated June 9, 2008, “Cultural or Historical Artifact Discovery 

20 During Construction." Accession No. ML081640213. 

21 South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

22 Units 3 and 4 Combined License Application, Part 1, General Financials. Revision 3, Bay City, 

23 Texas. Accession No. ML092931178. 

24 South Texas Project Nuclear Operating Company (STPNOC). 2009b. Letter from S. Head, 

25 STPNOC, to U.S. Army Corps of Engineers, dated October 28, 2009, “South Texas Project 

26 Units 3 and 4 Permit Determination Request.” Accession No. ML093210232. 

27 South Texas Project Nuclear Operating Company (STPNOC). 2009c. South Texas Project 

28 Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

29 City, Texas. Accession No. ML092931600. 

30 Southern Nuclear Operating Company, Inc. (Southern). 2008. Southern Nuclear Operating 

31 Company, Vogtle Early Site Permit Application, Response to NRC Questions from April 23, 

32 2008 Environmental Conference Call. Letter report from Southern Nuclear Operating Company 
Conclusions and Recommendations 

Draft NUREG-1937 10-30 March 2010 

1 (Birmingham, Alabama) to the U. S. Nuclear Regulatory Commission (Washington, D.C.), June 

2 26, 2008. Southern Company, Birmingham, Alabama. Accession No. ML081790598. 

3 Tennessee Valley Authority (TVA). 2008. Bellefonte Nuclear Plant, Units 3 & 4 COL 

4 Application, Part 3, Environmental Report. Revision 1. Knoxville, TN. Accession No. 

5 ML083100558. 

6 U.S. Army Corps of Engineers (Corps). 2009. Letter from Jayson Hudson (Corps) to Scott 

7 Head, STPNOC, dated November 10, 2009 in response to STPNOC October 28, 2009 request 

8 for a Permit Determination. Accession No. ML093210227. 

9 University of Chicago. 2004. The Economic Future of Nuclear Power. University of Chicago, 

10 Chicago, Illinois. Accessed June 20, 2009 at 

11 http://www.ne.doe.gov/np2010/reports/NuclIndustryStudy-Summary.pdf. Accession No. 

12 ML100600700. 

13 U.S. Department of Interior, Bureau of Reclamation (USDI/Reclamation). 2008. Construction 

14 Cost Trends. U.S. Department of Interior, Washington, D.C. Accessed July 7, 2009 at 

15 http://www.usbr.gov/pmts/estimate/cost_trend.html. Accession No. ML100600715. 

16 U.S. Department of U.S. Department of Energy (DOE). 2004. Study of Construction 

17 Technologies and Schedules, O&M Staffing and Cost, Decommissioning Costs and Funding 

18 Requirements for Advanced Reactor Designs. Vol. 2 - MPR-2610, prepared by Dominion 

19 Energy, Inc., Bechtel Power Corporation, TLG, Inc., and MPR Associates under Contract DE20 AT01-020NE23476, May 27. 

21 Energy (DOE) 2008. Yucca Mountain Repository. Accessed May 2008 at 

22 http://www.ocrwm.doe.gov/ym_repository/index.shtml#4. Accession No. ML100600704. 

23 U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2006. Energy 

24 Power Annual. Energy Information Administration, Washington, D.C. Accessed February 4, 

25 2008 at http://www.eia.doe.gov/cneaf/electricity/epa/epa_sum.html. Accession No. 

26 ML100600709. 

27 U.S. Department of Energy/Energy Information Administration (DOE/EIA). 2008. Emissions of 

28 Greenhouse Gases in the United States. DOE/EIA-0573(2008). Accessed February 3, 2010 at 

29 http://www.eia.doe.gov/oiaf/1605/ggrpt/gwp_gases.html. Accession No. ML100580032. 

30 U.S. Environmental Protection Agency (EPA). 2009. Report on the Environment. A-Z 

31 Indicators List. Accessed on February 3, 2010 at 

32 http://cfpub.epa.gov/eroe/index.cfm?fuseaction=list.listByAlpha#E. Accession No. 

33 ML100580033. 
 Conclusions and Recommendations 

March 2010 10-31 Draft NUREG-1937 

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 Vol. 1, Washington, D.C. Includes 2007 updates. 

4 World Nuclear Association (WNA). 2010. The Economics of Nuclear Power. Accessed 

5 January 27, 2010 at http://www.world-nuclear.org/info/default.aspx?id=410&terms=price. 

6 Accession No. ML100600712. 

7 

Appendix A 

Contributors to the Environmental Impact Statement 

March 2010 A-1 Draft NUREG-1937 

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 statement was prepared by members of the Office of New Reactors with assistance from other 

4 NRC organizations, the U.S. Army Corps of Engineers, and Pacific Northwest National 

5 Laboratory. 

6 

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Jessie Muir Office of New Reactors Project Manager 

Sarah Lopas Office of New Reactors Assistant Project Manager, Nonradiological 

Health 

Paul Kallan(a) Office of New Reactors Project Manager 

Cristina Guerrero(a) Office of New Reactors Assistant Project Manager 

Ryan Whited Office of New Reactors Branch Chief 

William Burton(a) Office of New Reactors Branch Chief 

Hosung Ahn Office of New Reactors Hydrology, Alternative Systems 

Nebiyu Tiruneh Office of New Reactors Hydrology 

Richard Raione Office of New Reactors Branch Chief 

Laurel Bauer Office of New Reactors Geology 

Harriet Nash Office of New Reactors Aquatic Ecology, Land Use, Terrestrial Ecology 

Daniel Mussatti Office of New Reactors Socioeconomics, Environmental Justice, Need 

for Power, Benefit Cost 

Richard Emch Office of New Reactors Radiological Impacts, Accidents 

Michelle Moser Office of New Reactors Cumulative Effects 

Jessica Glenny Office of Nuclear Material Safety and 

Safeguards 

Transportation of Radioactive Materials 

Andrew Kugler Office of New Reactors Alternatives 

Stan Echols Office of Nuclear Material Safety and 

Safeguards 

Fuel Cycle 

Brad Harvey Office of New Reactors Meteorology 

Bruce Watson Office of Federal and State Materials and 

Environmental Management Programs 

Decommissioning 

James Shepard Office of Federal and State Materials and 

Environmental Management Programs 

Decommissioning 

Jay Lee Office of New Reactors Accidents 
Appendix A 

Draft NUREG-1937 A-2 March 2010 

Name Affiliation Function or Expertise

Robert Kellner Office of New Reactors Health Physics and Radiation Protection 

(Occupational) 

Stephen Williams Office of New Reactors Health Physics and Radiation Protection 

(Effluent/Public) 

Ed Fuller Office of New Reactors Severe Accidents 

Seshagiri Rao 

Tammara 

Office of New Reactors Demography 

Barry Zalcman Office of New Reactors Cultural Resources, Air Quality, Climate Change

U.S. ARMY CORPS OF ENGINEERS

Jayson Hudson Galveston District Regulatory Project Manager 

PACIFIC NORTHWEST NATIONAL LABORATORY(b)

Nona Diediker Task Leader 

Beverly Miller Deputy Task Leader 

James Becker Deputy Task Leader 

Paul Hendrickson Land Use, Transmission Lines, Alternatives (No 

Action, Energy and Sites) 

Charles Kincaid Hydrology - Groundwater, Geology 

Rajiv Prasad Hydrology - Surface Water 

Lance Vail Hydrology 

Robert Bryce Alternative System Design 

Janelle Downs Terrestrial Ecology 

Mary Ann Simmons Terrestrial Ecology – Alternative Sites 

Amoret Bunn Aquatic Ecology 

Michael Scott Socioeconomics, Environmental Justice, Need 

for Power, Benefit Cost, Noise 

Michelle Neimeyer Socioeconomics, Environmental Justice 

Darby Stapp(c) Historic and Cultural Resources 

Tara O’Neil Historic and Cultural Resources 

Ernest Antonio Radiation Protection, Nonradiological Health 

Van Ramsdell Meteorology and Air Quality, Accidents 

Bruce McDowell Cumulative Impacts 

Phil Daling Transportation 

David Payson Technical Editing 

Denice Carrothers Technical Editing 

Michael Parker Text Processing 

Meredith Willingham References 

Christine Ross Text Processing 

(a) Staff member is no longer with the NRC, Office of New Reactors, or the Division of Siting and Environmental Reviews. 

(b) Pacific Northwest National Laboratory is operated by Battelle for the U.S. Department of Energy. 

(c) Staff member is no longer with Pacific Northwest National Laboratory 

1 
Appendix B 

Organizations Contacted 

March 2010 B-1 Draft NUREG-1937 

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 staff’s independent review of potential 

3 environmental impacts from the construction and operation of two new nuclear units, Units 3 

4 and 4, at the South Texas Project Electric Generating Station in Matagorda County, Texas: 

5 Advisory Council on Historic Preservation, Director Office of Federal Agency Programs, 

6 Washington, D.C. 

7 Alabama-Coushatta Tribe, Historical Preservation Department, Livingston, Texas 

8 Angleton Independent School District (ISD), Angleton, Texas 

9 Bay City Chamber of Commerce, Bay City, Texas 

10 Bay City Community Development Corporation, Bay City, Texas 

11 Bay City ISD, Bay City, Texas 

12 Bay City Ministerial Alliance, Bay City, Texas 

13 Bay City Salvation Army, Bay City, Texas 

14 Bell Valuation Services, Bay City, Texas 

15 Bluebonnet Groundwater Conservation District, Navasota, Texas 

16 Brazoria County Judge, Angleton, Texas 

17 Brazos River Authority, Waco, Texas 

18 Brazos Valley Groundwater Conservation District, Waco, Texas 

19 Calhoun County Judge, Port Lavaca, Texas 

20 City of Bay City, Mayor, Bay City, Texas 

21 Coastal Plains Groundwater Conservation District, Bay City, Texas 
Appendix B 

Draft NUREG-1937 B-2 March 2010 

1 Columbia-Brazoria ISD, West Columbia, Texas 

2 Comanche Nation, Lawton, Oklahoma 

3 Environmental Protection Agency, Regional Office, Dallas, Texas 

4 Frankson and Griffith, Certified Public Accountants, Bay City, Texas 

5 Greater Texoma Utility Authority, Bonham, Texas (now Red River Groundwater Conservation 

6 District) 

7 Guadalupe-Blanco River Authority, Seguin, Texas 

8 Jackson County, Edna, Texas 

9 Kiowa Tribe of Oklahoma, Carnegie, Oklahoma 

10 Matagorda County Museum Archives and Collections Department, Bay City, Texas 

11 Mid-East Texas Groundwater Conservation District, Centerville, Texas 

12 Lower Colorado River Authority, Austin, Texas 

13 National Marine Fisheries Service, Galveston Laboratory, Galveston, Texas 

14 National Marine Fisheries Service, Southeast Regional Office, St. Petersburg, Florida 

15 NRG Energy, Inc., Limestone Electric Generating Station, Jewett, Texas 

16 Palacios ISD, Palacios, Texas 

17 State of Texas, Office of the Governor, Austin, Texas 

18 St. Anthony of Padua Church, Palacios, Texas 

19 Tarrant Water District, Fort Worth, Texas 

20 Texas Commission on Environmental Quality, Austin, Texas 

21 Texas General Land Office, Coastal Coordination Council, Austin, Texas 

22 Texas Historical Commission, Austin, Texas 

23 Texas Parks and Wildlife Department, Austin, Texas 
Appendix B 

March 2010 B-3 Draft NUREG-1937 

1 Texas State Historic Preservation Officer, Austin, Texas 

2 Texas State Soil and Water Conservation Board, Temple, Texas 

3 Texas Water Development Board, Austin, Texas 

4 Tidehaven ISD, El Maton, Texas 

5 Tonkawa Tribe of Oklahoma, Tonkawa, Oklahoma 

6 Trinity River Authority of Texas Southern Region, Huntsville, Texas 

7 Upper Neches River Municipal Water Authority, Palestine, Texas 

8 U.S. Army Corps of Engineers Galveston District, Galveston, Texas 

9 U.S. Army Corps of Engineers, Fort Worth, Texas 

10 U.S. Congressman Ron Paul’s Office, Galveston, Texas 

11 U.S. Environmental Protection Agency, Temple, Texas 

12 U.S. Fish and Wildlife Service, Ecological Services, Houston, Texas 

13 Van Vleck ISD, Van Vleck, Texas 

Appendix C 

NRC and Corps Environmental Review 

Correspondence 

March 2010 C-1 Draft NUREG-1937 

Appendix C 

NRC and Corps Environmental Review 

Correspondence 

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

2 Regulatory Commission (NRC) or the U.S. Army Corps of Engineers (Corps) and STP Nuclear 

3 Operating Company (STPNOC). Also included is other correspondence related to the 

4 environmental review of STPNOC’s application for combined licenses (COLs) and a Corps 

5 permit at the South Texas Project Electric Generating Station (STP) site in Matagorda County, 

6 Texas. 

7 All documents, with the exception of those containing proprietary information, are available 

8 electronically from the Public Electronic Reading Room found on the Internet at the following 

9 web address: http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to 

10 the NRC’s Agencywide Documents Access and Management System (ADAMS), which provides 

11 text and image files of the NRC's public documents. The ADAMS accession numbers for each 

12 document are included below. 

13 October 16, 2007 Letter to Mr. Mark McBurnett, Vice President, STPNOC, from NRC, 

14 regarding Acknowledgement of Receipt of The Combined License 

15 Application for South Texas Project, Units 3 and 4, and Associated 

16 Federal Register Notice. (Accession No. ML072670515) 

17 November 8, 2007 Letter from Mr. Gregory T. Gibson, Manager, STPNOC, to NRC, 

18 regarding Environmental Report Acceptance Review: Outstanding 

19 Issues. (Accession No. ML073190645) 

20 November 16, 2007 Letter to Mr. Mark McBurnett, Vice President, STPNOC, from NRC, 

21 regarding Acceptance Review of The Combined License Application for 

22 South Texas Project (STP), Units 3 and 4. (Accession 

23 No. ML073200761) 

24 November 21, 2007 Letter from M.A. McBurnett, STPNOC, to NRC, regarding Supplement 

25 to Combined License Application. (Accession No. ML073310616) 

26 November 29, 2007 Letter to Mr. Mark McBurnett, STPNOC, from NRC, regarding the 

27 Docketing of The Combined License Application (COL) For South 

28 Texas Project (STP), Units 3 and 4. (Accession No. ML073320290) 
Appendix C 

Draft NUREG-1937 C-2 March 2010 

1 December 5, 2007 Letter from Mr. Gregory T. Gibson, STPNOC to NRC, Resubmitted 

2 Aquatic Ecology Monitoring: Six-Month Interim Report. (Accession 

3 No. ML073410357) 

4 December 11, 2007 Letter to Mr. Mark McBurnett, STPNOC, from NRC, regarding the 

5 Notice of Intent to Prepare an Environmental Impact Statement and 

6 Conduct Scoping Related to Combined Licenses for the South Texas 

7 Project Sites, Units 3 and 4. (Accession No. ML073400695) 

8 December 19, 2007 Letter to Mr. Mark McBurnett, STPNOC, from NRC, regarding Federal 

9 Register Notice Regarding Opportunity to Petition for Leave to Intervene 

10 - South Texas Project Units 3 and 4. (Accession No. ML073390202) 

11 December 21, 2007 Letter to Ms. Martha Johnson, Bay City Public Library, from NRC staff, 

12 regarding the Maintenance of Documents at The Bay City Public Library 

13 Related to Application by STP Nuclear Operating Company For 

14 Combined Licenses for The South Texas Project Site, Units 3 and 4. 

15 (Accession No. ML073480284) 

16 January 13, 2008 Email from Mr. Paul Kallan, NRC, to Mr. Greg Gibson, STPNOC, Site 

17 Audit Schedule and Preliminary Needs for Site Audit. (Accession No. 

18 ML082400729) 

19 January 18, 2008 Notice of Public Meeting to Discuss Environmental Scoping Process for 

20 the South Texas Project Site, Units 3 & 4 Combined Licenses (TAC NO. 

21 RA2764). (Accession No. ML080020250) 

22 January 25, 2008 Letter to Mr. David Bernhart, Assistant Regional Administrator, National 

23 Marine Fisheries Service, from NRC staff, regarding Application for The 

24 South Texas Project Site, Units 3 and 4 Combined Licenses. 

25 (Accession No. ML080020174) 

26 January 25, 2008 Letter to Alabama-Coushatta Tribe, Historical Preservation Department, 

27 from NRC staff, regarding Application for The South Texas Project Site, 

28 Units 3 and 4 Combined Licenses. (Accession No. ML080090115) 

29 January 25, 2008 Letter to Mr. Billy Evans Horse, Chairman of the Kiowa Tribe, Kiowa 

30 Tribe of Oklahoma, from NRC staff, regarding Application for The South 

31 Texas Project Site, Units 3 and 4 Combined Licenses. (Accession No. 

32 ML073620378) 
Appendix C 

March 2010 C-3 Draft NUREG-1937 

1 January 25, 2008 Letter to Ms. Ruth Toahty, NAGPRA Coordinator, Comanche Nation 

2 NAGPRA and Historic Preservation Program, Comanche National 

3 Museum, from NRC staff, regarding Application for The South Texas 

4 Project Site, Units 3 and 4 Combined Licenses. (Accession 

5 No. ML073620358) 

6 January 25, 2008 Letter to Mr. Anthony E. Street, Tribal President, Tonkawa Tribe of 

7 Oklahoma, from NRC staff, regarding Application for The South Texas 

8 Project Site, Units 3 and 4 Combined Licenses. (Accession 

9 No. ML080090198) 

10 January 25, 2008 Letter to Mr. Don Klima, Director Office of Federal Agency Programs, 

11 Advisory Council on Historic Preservation, from NRC staff, regarding 

12 Application for The South Texas Project Site, Units 3 and 4 Combined 

13 Licenses. (Accession No. ML080100669) 

14 January 25, 2008 Letter to Mr. Lawrence Oaks, Executive Director of the Texas SHPO, 

15 State Historic Preservation Officer, from NRC staff, regarding 

16 Application for The South Texas Project Site, Units 3 and 4 Combined 

17 Licenses. (Accession No. ML080110216) 

18 January 25, 2008 Letter to Ms. Moni Belton, Fish and Wildlife Biologist, U.S. Fish and 

19 Wildlife Service Ecological Services, from Mr. William Burton, NRC, 

20 regarding Application for The South Texas Project Site, Units 3 and 4 

21 Combined Licenses. (Accession No. ML080090170) 

22 January 31, 2008 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Submittal of 

23 Combined License Application Revision 1. (Accession 

24 No. ML080700399) 

25 February 28, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC staff, Reponses to 

26 Environmental Report Site Audit Comments. (Accession 

27 No. ML080660150) 

28 February 08, 2008 Site Audit Summary Report. (Accession No. ML081010440) 

29 February 13, 2008 Notice Withdrawing Hearing Notice Regarding the Application for a 

30 Combined Operating License for South Texas Project Units 3 and 4. 

31 (Accession No. ML080450208) 
Appendix C 

Draft NUREG-1937 C-4 March 2010 

1 April 4, 2008 Letter to Ms. Kathy Boydston, Habitat Assessment Program Manager, 

2 Texas Parks and Wildlife Department, from NRC staff, regarding 

3 Application for The South Texas Project Site, Units 3 and 4 Combined 

4 Licenses. (Accession No. ML080730469) 

5 April 10, 2008 Summary of Public Scoping Meetings to Support Review of the South 

6 Texas Plant Combined License Application (TAC NO. MD6691). 

7 (Accession No. ML081000171) 

8 May 19, 2008 Letter to Mr. William Burton, NRC, from Mr. Carter Smith, Texas Parks 

9 and Wildlife, Proposed application for combined licenses for South 

10 Texas Project, Units 3 and 4, Matagorda County. (Accession 

11 No. ML090330752) 

12 May 19, 2008 Letter to Mr. Gregory Gibson, STPNOC, from Mr. Paul Kallan, NRC, 

13 Request for Additional Information, Letter Number One Related to the 

14 Environmental Report for the South Texas Combined License 

15 Application. (Accession No. ML081360531) 

16 June 04, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Cultural or 

17 Historical Artifact Discovery During Construction. (Accession 

18 No. ML081610296) 

19 June 09, 2008 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Cultural or 

20 Historical Artifact Discovery During Construction. (Accession 

21 No. ML081640213) 

22 June 17, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Final Aquatic 

23 Ecology Report. (Accession No. ML081750196) 

24 July 02, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Response to 

25 Requests for Additional Information. (Accession No. ML081900569) 

26 July 07, 2008 Letter to Mr. Scott Flanders, NRC, from Mr. Fred Anthamatten, 

27 U.S. Army Corps of Engineers, Environmental Impact Statement for the 

28 South Texas Project Nuclear Operating Company’s Combined License 

29 Application. (Accession No. ML082140640) 

30 July 15, 2008 Letter from Mr. Greg Gibson, STPNOC, to NRC, Response to Requests 

31 for Additional Information. (Accession No. ML082040684) 
Appendix C 

March 2010 C-5 Draft NUREG-1937 

1 July 30, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Response to 

2 Requests for Additional Information. (Accession No. ML082140629) 

3 August 27, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Response to 

4 Requests for Additional Information. (Accession No. ML082420332) 

5 August 29, 2008 Letter to Mr. Fred Anthamatten, U.S. Army Corps of Engineers, from Mr. 

6 Scott Flanders, NRC, Request to Cooperate with the Nuclear 

7 Regulatory Commission on the Environmental Impact Statement for the 

8 South Texas Project Nuclear Operating Company, Units 3 and 4 

9 Combined License Application. (Accession No. ML0823106192) 

10 September 04, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Completion of NRC 

11 Commitment. (Accession No. ML082530234) 

12 September 26, 2008 Letter to Mr. Scott Head, STPNOC, from Mr. William Burton, NRC, 

13 Scoping Summary Report Related to the Environmental Scoping 

14 Process for the South Texas Project, Units 3 and 4 Combined License 

15 Application. (Accession No. ML082260471) 

16 September 24, 2008 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Submittal of 

17 Combined License Application Revision 2. (Accession 

18 No. ML082830938) 

19 November 18, 2008 Letter to Mr. Scott Head, STPNOC, from Mr. Paul Kallan, NRC, 

20 Request for Additional Information, Letter Number Two Related to the 

21 Environmental Report for the South Texas Combined License 

22 Application. (Accession No. ML083190269) 

23 January 14, 2009 Memorandum from Ms. Jessie Muir, NRC, to Mr. William Burton, NRC, 

24 Summary of Teleconferences Held with South Texas Nuclear Operating 

25 Company Regarding the Draft Requests for Additional Information. 

26 (Accession No. ML090030003) 

27 January 21, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Second Re-submittal of 

28 Response to Request for Additional Information. (Accession 

29 No. ML090270986) 

30 January 22, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

31 for Additional Information. (Accession No. ML090270720) 
Appendix C 

Draft NUREG-1937 C-6 March 2010 

1 February 03, 2009 Letter from Mr. Scott Head, STPNOC, to Mr. Mark Fisher, TCEQ, 

2 Request for State Water Quality Certification of Federally Permitted 

3 Activity. (Accession No. ML ML090360530) 

4 February 10, 2009 Letter from Mr. George Wunder, NRC, to Mr. Mark McBurnett, 

5 STPNOC, South Texas Project Units 3 and 4 Combined License 

6 Application Review Schedule. (Accession No. ML083650198)

7 February 20, 2009 Federal Register Notice of Order, Hearing, and Opportunity to Petition 

8 for Leave to Intervene Docket Nos. 52-012 and 52-013. 74 FR 7934. 

9 (Accession No. ML083570595) 

10 February 26, 2009 Summary of the Second Site Audit Related to the Environmental 

11 Review of the Combined Operating License Application for South Texas 

12 Project Units 3 and 4. (Accession No. ML090350504) 

13 March 03, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Contracts for 

14 Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste. 

15 (Accession No. ML090640920) 

16 March 16, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Re-Submittal of 

17 Response to Requests for Additional Information. (Accession 

18 No. ML090860879) 

19 March 18, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Update to Aquatic 

20 Ecology Monitoring Report Data. (Accession No. ML090830503) 

21 April 07, 2009 Letter from Mr. Kenny Jaynes, U.S. Army Corps of Engineers, to Mr. 

22 Gregory Gibson, STPNOC, Jurisdictional Determination, 7,000-Acre 

23 Mass Cooling Reservoir (MCR), Wadsworth, Matagorda County, Texas. 

24 (Accession No. ML091050501) 

25 April 22, 2009 Letter to Mr. Scott Head, STPNOC, from Ms. Jessie Muir, NRC, 

26 Requests for Additional Information, Letter Number Three Related to 

27 the Environmental Report for the South Texas Combined License 

28 Application. (Accession No. ML090960303) 

29 May 13, 2009 U. S. Army Corps of Engineers to NRC, Preliminary Jurisdictional 

30 Determination Form. (Accession No. ML091390115) 
Appendix C 

March 2010 C-7 Draft NUREG-1937 

1 May 14, 2009 Letter from Mr. Kenny Jaynes, U.S. Army Corps of Engineers, to 

2 Mr. Russell Kiesling, STPNOC, Preliminary Jurisdictional Determination, 

3 Wadsworth, Montgomery County, Texas. (Accession Nos. 

4 ML091350101; ML091390111) 

5 May 18, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

6 for Additional Information. (Accession No. ML091410061) 

7 June 04, 2009 Letter from Mr. Scott Head, STPNOC, to Mr. Jayson Hudson, U.S. Army 

8 Corps of Engineers, Permit Determination Request. (Accession No. 

9 ML092030309) 

10 June 29, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

11 for Additional Information. (Accession No. ML091830339) 

12 July 08, 2009 Letter from Mr. Casey Cutler, U.S. Army Corps of Engineers, to Mr. 

13 Scott Head, STPNOC. (Accession No. ML092030304) 

14 July 30, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Response to 

15 Request for Additional Information. (Accession No. ML092150963) 

16 August 10, 2009 Letter from Mr. Jayson Hudson, U.S. Army Corps of Engineers to Ms. 

17 Jessie Muir, NRC, Cooperating Agency Scoping Request for South 

18 Texas Project Electric Generating Station Units 3 and 4. (Accession 

19 No. ML092460137) 

20 August 14, 2009 Letter to Mr. Scott Head, STPNOC, from Ms. Jessie Muir, NRC, 

21 Request for Additional Information, Letter Number Four Related to the 

22 Environmental Report for the South Texas Combined License 

23 Application. (Accession No. ML091620673) 

24 September 14, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

25 for Additional Information. (Accession No. ML092580491) 

26 September 16, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Submittal of 

27 Combined License Application Revision 3. (Accession No. 

28 ML092930393) 

29 September 22, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Second Re-submittal 

30 Response to Request for Additional Information. (Accession No. 

31 ML092710535) 
Appendix C 

Draft NUREG-1937 C-8 March 2010 

1 September 28, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

2 for Additional Information. (Accession No. ML092740321) 

3 October 01, 2009 Letter from Jessie M. Muir, NRC, to Mr. Scott Head, STPNOC, Request 

4 for Additional Information related to Alternative Sites. (Accession No. 

5 ML092750384) 

6 October 15, 2009 Letter to Mrs. Moni Belton, USFWS, from Mr. Ryan Whited, NRC, 

7 Information Request Regarding Alternative Sites Related to the 

8 Combined Licenses Application for South Texas Project, Units 3 and 4. 

9 (Accession No. ML092580516) 

10 October 15, 2009 Letter to Mr. Carter Smith, Texas Parks and Wildlife Department, from 

11 Mr. Ryan Whited, NRC, Information Request Regarding Alternative 

12 Sites Related to the Combined Licenses Application for South Texas 

13 Project, Units 3 and 4. (Accession No. ML092580421) 

14 October 27, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

15 for Additional Information. (Accession No. ML093060175) 

16 October 28, 2009 Letter from STPNOC to USACE, Permit Determination Request. 

17 (Accession No. ML093210232) 

18 November 09, 2009 Site Audit Summary of South Texas Project Nuclear Operating 

19 Company’s Revised Alternative Sites Analysis. (Accession No. 

20 ML092870574) 

21 November 09, 2009 Forthcoming Teleconference with South Texas Project Nuclear 

22 Operating Company to Discuss Responses to Request for Additional 

23 Information Related to Alternative Sites for the South Texas Project 

24 Units 3 and 4 Environmental Reviews. (Accession No. ML093130330 

25 November 10, 2009 Letter from Jayson Hudson, US Army Corps, to Scott Head (STPNOC) 

26 dated November 10, 2009 in response to STPNOC October 28, 2009 

27 request for a permit determination. (Accession No. ML093210227) 

28 November 10, 2009 Letter from Scott Head, STPNOC, to NRC, Proposed Revision to 

29 Environmental Report. (Accession No. ML093170197) 

30 November 11, 2009 Letter from Scott Head, STPNOC, to NRC, Proposed Revision to 

31 Environmental Report. (Accession No. ML093200201) 
Appendix C 

March 2010 C-9 Draft NUREG-1937 

1 November 13, 2009 Letter from Kathy Boydston, Texas Parks and Wildlife Division, to Ryan 

2 Whited, NRC, Proposed Alternative Sites Related to the Combined 

3 License Application for South Texas Project, Units 3 and 4. (Accession 

4 No. ML093210221) 

5 November 16, 2009 Letter from Mark McBurnett, STPNOC, to NRC, Request for Limited 

6 Work Authorization. (Accession No. ML093230143) 

7 November 23, 2009 Letter from Scott Head, STPNOC, to NRC, Response to Request for 

8 Additional Information. (Accession No. ML093310296) 

9 November 23, 2009 Letter from Scott Head, STPNOC, to NRC, Supplemental Response to 

10 Request for Additional Information. (Accession No. ML093310392) 

11 November 30, 2009 Letter from Scott Head, STPNOC, to NRC, Response to Request for 

12 Additional Information. (Accession No. ML093370158) 

13 November 30, 2009 Letter from Scott Head, STPNOC, to NRC, Response to Request for 

14 Additional Information. (Accession No. ML093380310) 

15 November 30, 2009 Letter from Scott Head, STPNOC, to NRC, Supplemental Response to 

16 Request for Additional Information. (Accession No. ML093360350) 

17 December 14, 2009 Summary of November 17, 2009, Public Teleconference Related to the 

18 Environmental Review of the South Texas Project Units 3 and 4 

19 Combined Licenses Application. (Accession No. ML093350861) 

20 January 08, 2010 Letter from Michael Johnson, NRC, to Mark McBurnett, STPNOC 

21 regarding South Texas Project Nuclear Power Plan Units 3 and 4 

22 Request for a Limited Work Authorization for Installation of Crane 

23 Foundation Retaining Walls. (Accession No. ML093350744) 

24 January 20, 2010 Letter to Amy Hanna, Texas Parks and Wildlife Division, from Jessie 

25 Muir, NRC, Comments Regarding Alternative Sites Related to the 

26 Combined Licenses Application for South Texas Project, Units 3 and 4. 

27 (Accession No. ML093450914) 

28 February 2, 2010 Letter from Mark McBurnett, STPNOC, to NRC, Request for Exemption 

29 to Authorize Installation of Crane Foundation Retaining Walls. 

30 (Accession No. ML100350219) 
Appendix C 

Draft NUREG-1937 C-10 March 2010 

1 February 2, 2010 Letter from Charles Maguire, Texas Commission on Environmental 

2 Quality, to Ryan Whited, NRC, 401 Water Quality Certification of South 

3 Texas Nuclear Project. (Accession No. ML100500926) 

4 February 19, 2010 Letter from Casey Cutler, Department of Army, to Ryan Whited, NRC, 

5 regarding Draft Environmental Impact Statement for the Combined 

6 Licenses for South Texas Project Generating Station Units 3 and 4. 

7 (Accession No. ML100660017). 
Appendix D 

Scoping Comments and Responses 

March 2010 D-1 Draft NUREG-1937 

Appendix D 

Scoping Comments and Responses 

1 On December 21, 2007, 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 (72 FR 72774). The Notice of Intent notified the public of the staff’s intent to 

4 prepare an environmental impact statement (EIS) and conduct scoping for the application for 

5 combined licenses (COLs) received from STP Nuclear Operating Company (STPNOC) for two 

6 new nuclear units identified as South Texas Project Electric Generating Station (STP) Units 3 

7 and 4, to be located at the existing STP site, located approximately 12 mi south-southwest of 

8 Bay City, Texas. NRC invited the applicant; Federal, Tribal, State, and local government 

9 agencies; local organizations; and individuals to participate in the scoping process by providing 

10 oral comments at the scheduled public meetings and/or submitting written suggestions and 

11 comments no later than February 18, 2008. 

12 D.1 Overview of the Scoping Process 

13 The scoping process provides an opportunity for public participants to identify issues to be 

14 addressed in the EIS and highlight public concerns and issues. The Notice of Intent identified 

15 the following objectives of the scoping process: 

16 • Define the proposed action which is to be the subject of the EIS. 

17 • Determine the scope of the EIS and identify significant issues to be analyzed in depth. 

18 • Identify and eliminate from detailed study those issues that are peripheral or that are not 

19 significant. 

20 • Identify any environmental assessments and other EISs that are being prepared or will be 

21 prepared that are related to, but not part of, the scope of the EIS being considered. 

22 • Identify other environmental review and consultation requirements related to the proposed 

23 action. 

24 • Identify parties consulting with the NRC under the NHPA, as set forth in 36 CFR 

25 800.8(c)(1)(i). 
Appendix D 

Draft NUREG-1937 D-2 March 2010 

1 • Indicate the relationship between the timing of the preparation of the environmental 

2 analyses and the Commission’s tentative planning and decision-making schedule. 

3 • Identify any cooperating agencies and, as appropriate, allocate assignments for preparation 

4 and schedules for completing the EIS to the NRC and any cooperating agencies. 

5 • Describe how the EIS will be prepared and include any contractor assistance to be used. 

6 Two public scoping meetings were held at the Bay City Civic Center, on Tuesday, February 5, 

7 2008. The scoping meetings began with NRC staff members providing a brief overview of the 

8 COL process and the NEPA process. After the NRC’s prepared statements, the meeting was 

9 open for public comments. Fifty one (51) meeting attendees provided either oral comments or 

10 written statements that were recorded and transcribed by a certified court reporter. In addition 

11 to the oral and written statements provided at the public scoping meeting, 11 letters and 7 

12 emails were received during the scoping period. Preparation of the draft EIS has taken into 

13 account all of the relevant issues raised during the scoping process. 

14 Transcripts for both afternoon and evening scoping meeting can be found in the NRC Agency 

15 Document Access and Management System (ADAMS), under accession numbers 

16 ML080950499 and ML080950504, respectively. ADAMS is accessible from the NRC Web site 

17 at http://www.nrc.gov/reading-rm/adams/web-based.html (in the Public Electronic Reading 

18 Room). (Note: the URL is case-sensitive.) Additional comments received later in letters or 

19 emails are also available. A meeting summary memorandum (ML081000171) was issued April 

20 10, 2008. 

21 At the conclusion of the scoping period, the NRC staff reviewed the scoping meeting transcripts 

22 and all written material received during the comment period and identified individual comments. 

23 These comments were organized according to topic within the proposed EIS or according to the 

24 general topic, if outside the scope of the EIS. Once comments were grouped according to 

25 subject area, the staff determined the appropriate response for the comment. The staff made a 

26 determination on each comment that it was one of the following: 

27 • A comment that was actually a question and introduced no new information. 

28 • A comment that was either related to support or opposition of combined licensing in general 

29 (or specifically the STPNOC COLs) or that made a general statement about the COL 

30 process. In addition, it provided no new information and did not pertain to 10 CFR Part 52. 
Appendix D 

March 2010 D-3 Draft NUREG-1937 

1 • A comment about an environmental issue that 

2 – provided new information that would require evaluation during the review 

3 – provided no new information. 

4 • A comment that was outside the scope of the COL, which included, but was not limited to 

5 – a comment on the safety of the existing units. 

6 Preparation of the EIS has taken into account the relevant issues raised during the scoping 

7 process. The comments received on the draft EIS will be considered in the preparation of the 

8 final EIS. The final EIS, along with the staff’s Safety Evaluation Report (SER), will provide much 

9 of the basis for the NRC’s decision on whether to grant the STPNOC COLs. 

10 The comments related to this environmental review are included in this appendix. They were 

11 extracted from the South Texas Project Combined License Scoping Summary Report 

12 (Accession No. ML082260454), and are provided for the convenience of those interested 

13 specifically in the scoping comments applicable to this environmental review. The comments 

14 that are outside the scope of the environmental review for the proposed STP site are not 

15 included in this Appendix. The out of scope comments include comments related to: 

16 • Safety 

17 • Emergency Preparedness 

18 • NRC Oversight for operating plants 

19 • Security and Terrorism 

20 • Support or Opposition to the licensing action, licensing process, nuclear power, hearing 

21 process or the existing plant 

22 More detail regarding the disposition of general or out of scope comments can be found in the 

23 Scoping Summary Report (ML082260454). To maintain consistency with the Scoping Summary 

24 Report, the comment source ID and comment number along with the name of the commenter 

25 used in that report is retained in this appendix. Any changes that have occurred since the 

26 publication of the Scoping Summary Report (e.g., revisions to the EIS outline) are indicated 

27 within <new information> angle brackets. 

28 Table D-1 identifies in alphabetical order the individuals providing comments during the scoping 

29 period, their affiliation, if given, and the ADAMS accession number that can be used to locate 

30 the correspondence. Although all commenters are listed, the comments presented in this 

31 appendix are limited to those within the scope of the environmental review. Table D-2 lists the 

32 comment categories in alphabetical order and commenter names and comment numbers for 

33 each category. The balance of this appendix presents the comments themselves with NRC 

34 staff responses organized by topic category. 
Appendix D 

Draft NUREG-1937 D-4 March 2010 

1 Table D-1. Individuals Providing Comments During Scoping Comment Period 

Commenter Affiliation (if stated)

Comment Source and ADAMS 

Accession #

Acevedo, NK Self Meeting Transcript (ML080950499) 

Acevedo, NK Self Meeting Transcript (ML080950504) 

Alvarado, Robert Self Meeting Transcript (ML080950499) 

Alvarado, Robert Self Meeting Transcript (ML080950504) 

Bludau, Owen Matagorda County Economic 

Development Corporation 

Meeting Transcript (ML080950499) 

Bludau, Owen Matagorda County Economic 

Development Corporation 

Meeting Transcript (ML080950504) 

Castro, Geoffrey Citizens League for Environmental 

Action Now 

Meeting Transcript (ML080950499) 

Conrad, A.C. Self Meeting Transcript (ML080950499) 

Corder, John Self Meeting Transcript (ML080950504) 

Cushing, Lara Self Email (ML081140370) 

Cushing, Lara Self Meeting Transcript (ML080950499) 

Dancer, Susan Matagorda County Coalition for 

Nuclear Industry Accountability 

Meeting Transcript (ML080950499) 

Dunham, D.C. Bay City Community Development 

Corporation 

Meeting Transcript (ML080950499) 

Dunham, D.C. Bay City Community Development 

Corporation 

Meeting Transcript (ML080950504) 

Dykes, Ed Self Meeting Transcript (ML080950504) 

Edwards, Nancy Self Letter (ML08064019) 

Garcia, Sandra Self Meeting Transcript (ML080950499) 

Griffith, Mike Self Letter (ML080840434) 

Gunter, Paul Beyond Nuclear Meeting Transcript (ML080950504) 

Hadden, Karen SEED Coalition Letter (ML080840435) 

Hadden, Karen SEED Coalition Meeting Transcript (ML080950499) 

Hadden, Karen SEED Coalition Meeting Transcript (ML080950504) 

Head, Bobby Self Meeting Transcript (ML080950504) 

Hearn, Polly Self Letter (ML080840439) 

Hefner, James STP Meeting Transcript (ML080950499) 

Hefner, James STP Meeting Transcript (ML080950504) 
Appendix D 

March 2010 D-5 Draft NUREG-1937 

1 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and ADAMS 

Accession #

Johnson, Matthew Public Citizen-Texas Office Email (ML081140369) 

Kale, Stephen Self Letter (ML080840438) 

Kale, Stephen Self Meeting Transcript (ML080950504) 

Knapik, Richard Bay City Meeting Transcript (ML080950499) 

Knapik, Richard Bay City Meeting Transcript (ML080950504) 

Lindsey, Joy Self Letter (ML080460530) 

Lopez, Diana Self Meeting Transcript (ML080950499) 

Marceaux, Brent Self Meeting Transcript (ML080950504) 

Martin, Bruce Self Meeting Transcript (ML080950504) 

McBurnett, Mark STPNOC Meeting Transcript (ML080950499) 

McBurnett, Mark STPNOC Meeting Transcript (ML080950504) 

McCauley, Jimmy Self Meeting Transcript (ML080950504) 

McCormick, Mr. Self Meeting Transcript (ML080950504) 

McDonald, Nate Matagorda County Letter (ML080840425) 

Mitchell, James Matagora County Meeting Transcript (ML080950499) 

Mitchell, James Matagora County Meeting Transcript (ML080950504) 

Morton, Joe Palacios, TX Meeting Transcript (ML080950499) 

Morton, Joe Palacios, TX Meeting Transcript (ML080950504) 

O’Day, Mike Self Meeting Transcript (ML080950499) 

O’Day, Mike Self Meeting Transcript (ML080950504) 

Opella, Ernest Self Meeting Transcript (ML080950504) 

Payne, Cameron Self Email (ML081420662) 

Payne, Cameron Self Meeting Transcript (ML080950499) 

Public Citizen, 

Texas Office 

Public Citizen, Texas Office Letter (ML080640543) 

Reed, Cyrus Sierra Club, Lone Star Chapter Email (ML081140366) 

Reed, Cyrus Sierra Club, Lone Star Chapter Meeting Transcript (ML080950499) 

Rendon, Genaro Self Meeting Transcript (ML080950499) 
Appendix D 

Draft NUREG-1937 D-6 March 2010 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and ADAMS 

Accession #

Rice Herreth, 

Georgia 

Self Meeting Transcript (ML080950499) 

Russell, Nancy Self Letter (ML080640196) 

Ryan, Timothy Self Email (ML081140368) 

Scheurich, Venice Self Letter (ML080840437) 

Schwank, Eleanor Self Meeting Transcript (ML080950499) 

Shepherd, Joe STP, Nuclear Operating Company Meeting Transcript (ML080950499) 

Shepherd, Joe STP, Nuclear Operating Company Meeting Transcript (ML080950504) 

Singleton, Robert Self Meeting Transcript (ML080950499) 

Singleton, Robert Self Meeting Transcript (ML080950504) 

Sinkin, Lanny Self Email (ML081140364) 

Sinkin, Lanny Self Email (ML081140367) 

Smith, Tom Public Citizen, Texas Office Letter (ML080640543) 

Smith, Tom Public Citizen, Texas Office Meeting Transcript (ML080950499) 

Thames, Mitch Bay City Chamber of Commerce Meeting Transcript (ML080950499) 

Thames, Mitch Bay City Chamber of Commerce Meeting Transcript (ML080950504) 

Wagner, William Self Meeting Transcript (ML080950504) 

Williams, Mina Coastal Bend Sierra Club Letter (ML080840436) 
Appendix D 

March 2010 D-7 Draft NUREG-1937 

1 Table D-2. Comment Categories with Associated Commenters and Comment IDs 

Comment Category Commenter (Comment ID)

Accidents-Design 

Basis 

• Public Citizen, Texas Office (0010-16) 

• Smith, Tom (0010-16) 

Accidents-Severe • McBurnett, Mark (0008-123) 

• Payne, Cameron (0005-3) (0005-4) (0005-5) 

• Reed, Cyrus (0003-45) 

• Singleton, Robert (0007-121) 

• Sinkin, Lanny (0002-17) 

• Williams, Mina (0015-7) 

Alternatives-Energy • Acevedo, NK (0007-89) 

• Castro, Geoffrey (0007-87) 

• Cushing, Lara (0007-90) (0007-100) (0018-1) (0018-3) (0018-4) (0018-5) 

(0018-6) 

• Dykes, Ed (0008-104) (0008-105) 

• Edwards, Nancy (0012-6) 

• Garcia, Sandra (0007-98) 

• Head, Bobby (0008-31) 

• Kale, Stephen (0008-29) (0008-30) (0014-4) 

• Lindsey, Joy (0009-7) 

• McBurnett, Mark (0007-139) 

• Reed, Cyrus (0003-2) (0003-5) (0003-11) (0003-15) (0003-16) (0003-18) 

(0003-19) (0007-44) (0007-58) 

• Russell, Nancy (0011-1) 

• Schwank, Eleanor (0007-132) 

• Shepherd, Joe (0008-127) 

• Singleton, Robert (0007-118) 

• Sinkin, Lanny (0002-29) (0002-30) (0002-31) (0002-33) (0002-34) 

(0002-36) (0004-1) 

• Smith, Tom (0007-28) 

• Williams, Mina (0015-8) (0015-9) 

Alternatives-Sites • Reed, Cyrus (0003-20) 

Alternatives-System 

Design 

• McBurnett, Mark (0008-122) 

• Wagner, William (0008-73) (0008-76) 

Benefit-Cost Balance • Cushing, Lara (0007-92) 

• Edwards, Nancy (0012-3) 

• Kale, Stephen (0008-28) (0014-3) 

• Lindsey, Joy (0009-2) 

• Lopez, Diana (0007-73) 

• Reed, Cyrus (0003-4) (0003-6) (0003-7) (0003-8) (0003-12) 

• Sinkin, Lanny (0002-25) 

• Wagner, William (0008-86) 

• Williams, Mina (0015-4) (0015-11) 
Appendix D 

Draft NUREG-1937 D-8 March 2010 

1 

Table D-2. (contd)

Comment Category Commenter (Comment ID)

Cumulative Impacts • Hadden, Karen (0007-32) (0008-54) 

• Reed, Cyrus (0003-21) (0003-22) 

• Rendon, Genaro (0007-62) (0007-63) 

• Wagner, William (0008-67) 

Decommissioning • Sinkin, Lanny (0002-26) 

Ecology-Aquatic • Acevedo, NK (0008-78) 

• Head, Bobby (0008-32) 

• Payne, Cameron (0005-6) 

• Reed, Cyrus (0003-30) (0003-31) (0003-34) 

Ecology-Terrestrial • Head, Bobby (0008-33) (0008-34) 

• Marceaux, Brent (0008-23) 

• O’Day, Mike (0008-2) 

• Public Citizen, Texas Office (0010-17) 

• Smith, Tom (0007-21) (0010-17) 

Environmental 

Justice 

• Smith, Tom (0007-25) 

Geology • Wagner, William (0008-69) 

Health-Radiological • Conrad, A.C. (0007-127) 

• Dancer, Susan (0007-99) 

• Hadden, Karen (0008-58) (0008-59) (0008-60) (0008-61) (0008-62) 

(0008-63) (0008-64) (0008-65) 

• Hefner, James (0007-115) (0007-116) (0008-90) (0008-91) 

• McBurnett, Mark (0008-117) 

• Payne, Cameron (0007-97) 

• Public Citizen, Texas Office (0010-3) (0010-18) 

• Reed, Cyrus (0003-46) 

• Scheurich, Venice (0017-4) 

• Sinkin, Lanny (0002-18) (0002-20) (0002-21) 

• Smith, Tom (0007-17) (0010-3) (0010-18) 

• Wagner, William (0008-80) 

HydrologyGroundwater 

• Public Citizen, Texas Office (0010-8) 

• Scheurich, Venice (0017-2) 

• Smith, Tom (0007-23) (0010-8) 

Hydrology-Surface 

Water 

• Conrad, A.C. (0007-126) 

• Lopez, Diana (0007-68) 

• McBurnett, Mark (0007-141) 

• Public Citizen, Texas Office (0010-4) (0010-5) (0010-6) (0010-7) (0010-9) 

(0010-10) (0010-11) 

• Reed, Cyrus (0003-25) (0003-26) (0003-27) (0003-28) (0003-29) (0007-45) 

(0007-47) (0007-48) (0007-49) 

• Scheurich, Venice (0017-1) 

• Schwank, Eleanor (0007-133) (0007-134) 
Appendix D 

March 2010 D-9 Draft NUREG-1937 

Table D-2. (contd)

Comment Category Commenter (Comment ID)

• Sinkin, Lanny (0002-6) (0002-11) (0002-12) (0002-13) (0002-14) (0002-15) 

(0002-16) 

• Smith, Tom (0007-18) (0010-4) (0010-5) (0010-6) (0010-7) (0010-9) 

(0010-10) (0010-11) 

• Wagner, William (0008-77) (0008-79) 

• Williams, Mina (0015-6) 

Land UseTransmission Lines 

• McBurnett, Mark (0008-121) 

Meteorology and Air 

Quality 

• Cushing, Lara (0007-93) 

• Lopez, Diana (0007-81) (0007-82) 

• O’Day, Mike (0008-6) 

• Reed, Cyrus (0003-32) (0003-41) 

• Shepherd, Joe (0007-145) (0008-126) 

• Singleton, Robert (0007-105) (0007-119) 

• Sinkin, Lanny (0002-3) (0002-4) (0002-5) 

Need for Power • Kale, Stephen (0008-25) (0008-27) (0014-2) 

• Lindsey, Joy (0009-3) 

• McBurnett, Mark (0007-138) 

• Morton, Joe (0008-19) 

• Public Citizen, Texas Office (0010-20) (0010-21) (0010-22) 

• Reed, Cyrus (0003-9) (0003-10) (0003-13) (0003-14) (0003-17) (0007-43) 

• Smith, Tom (0007-27) (0010-20) (0010-21) (0010-22) 

• Alvarado, Robert (0007-60) 

• Conrad, A.C. (0007-128) 

• Edwards, Nancy (0012-1) 

• Lindsey, Joy (0009-1) 

• Lopez, Diana (0007-78) 

• Ryan, Timothy (0001-1) 

• Scheurich, Venice (0017-5) 

• Schwank, Eleanor (0007-135) 

• Williams, Mina (0015-1) 

• Hadden, Karen (0008-51) 

• Reed, Cyrus (0003-3) 

• Castro, Geoffrey (0007-85) (0007-88) 

• Edwards, Nancy (0012-2) (0012-4) (0012-7) 

• Hadden, Karen (0007-30) 

• Reed, Cyrus (0007-59) 

• Rendon, Genaro (0007-66) 

• Singleton, Robert (0007-117) 

• Sinkin, Lanny (0002-28) 

• Williams, Mina (0015-3) (0015-10) 

• Singleton, Robert (0008-106) 

• Bludau, Owen (0007-76) (0008-101) 
Appendix D 

Draft NUREG-1937 D-10 March 2010 

Table D-2. (contd)

Comment Category Commenter (Comment ID)

• McDonald, Nate (0016-2) 

• Mitchell, James (0008-12) 

• Morton, Joe (0008-21) 

• Public Citizen, Texas Office (0010-12) (0010-13) (0010-14) (0010-15) 

• Singleton, Robert (0007-122) 

• Sinkin, Lanny (0002-7) (0002-8) 

• Smith, Tom (0010-12) (0010-13) (0010-14) (0010-15) 

• Hadden, Karen (0007-35) 

• Johnson, Matthew (0006-1) 

• Kale, Stephen (0008-26) (0014-1) 

• Reed, Cyrus (0003-24) 

• Rendon, Genaro (0007-61) 

• Sinkin, Lanny (0002-32) 

• Wagner, William (0008-85) 

• Dancer, Susan (0007-108) 

• Morton, Joe (0007-15) (0008-22) 

• Sinkin, Lanny (0002-37) (0002-38) 

• Corder, John (0008-40) 

• Dancer, Susan (0007-101) 

• Hadden, Karen (0007-37) 

• Lindsey, Joy (0009-5) (0009-6) 

• Lopez, Diana (0007-80) 

• McBurnett, Mark (0007-137) (0008-118) (0008-119) (0008-120) 

• McCauley, Jimmy (0008-87) 

• McCormick, Mr. (0008-110) 

• Payne, Cameron (0005-1) (0005-2) (0007-110) (0007-111) (0007-112) 

(0007-114) 

• Reed, Cyrus (0003-33) (0003-39) (0003-40) (0007-46) (0007-50) 

• Rice Herreth, Georgia (0007-130) 

• Shepherd, Joe (0007-143) (0008-124) 

• Singleton, Robert (0008-107) (0008-108) 

• Sinkin, Lanny (0002-2) (0002-9) (0002-10) (0002-19) 

• Smith, Tom (0007-19) (0007-20) 

• Wagner, William (0008-66) (0008-68) (0008-70) 

• Acevedo, NK (0008-71) (0008-83) 

• Alvarado, Robert (0008-74) 

• Dancer, Susan (0007-104) 

• Gunter, Paul (0008-45) (0008-46) 

• Hadden, Karen (0007-33) 

• Head, Bobby (0008-36) 

• McBurnett, Mark (0008-115) (0008-116) 

• McCormick, Mr. (0008-109) 

• Mitchell, James (0007-6) (0008-8) (0008-9) (0008-10) (0008-11) 

• Morton, Joe (0007-13) 
Appendix D 

March 2010 D-11 Draft NUREG-1937 

Table D-2. (contd)

Comment Category Commenter (Comment ID)

• Reed, Cyrus (0003-44) (0007-53) (0007-56) 

• Singleton, Robert (0007-123) 

• Sinkin, Lanny (0002-23) (0002-35) 

• Wagner, William (0008-72) (0008-75) (0008-84) 

• Williams, Mina (0015-5) 

Process-ESP-COL • Acevedo, NK (0008-55) 

• Hadden, Karen (0007-34) (0007-36) (0007-38) (0007-39) (0007-40) 

(0008-53) (0008-56) (0008-57) 

• Reed, Cyrus (0003-1) (0007-42) 

• Shepherd, Joe (0007-142) 

• Sinkin, Lanny (0002-1) 

• Wagner, William (0008-81) (0008-82) 

Process-NEPA • Cushing, Lara (0018-2) 

• Hadden, Karen (0008-52) (0020-1) 

Site Layout and 

Design 

• McBurnett, Mark (0007-136) 

• Payne, Cameron (0007-113) 

• Shepherd, Joe (0007-146) (0007-147) (0008-128) 

Socioeconomics • Acevedo, NK (0007-150) 

• Bludau, Owen (0007-71) (0007-72) (0007-74) (0007-84) (0008-92) 

(0008-94) (0008-96) (0008-97) (0008-98) (0008-99) (0008-100) 

• Cushing, Lara (0007-96) 

• Dancer, Susan (0007-102) (0007-103) (0007-106) (0007-120) 

• Dunham, D.C. (0007-79) (0008-47) 

• Head, Bobby (0008-38) (0008-39) 

• Hearn, Polly (0013-2) 

• Knapik, Richard (0007-9) (0008-14) 

• McBurnett, Mark (0008-113) 

• Morton, Joe (0008-18) 

• O’Day, Mike (0008-4) 

• Public Citizen, Texas Office (0010-1) (0010-2) 

• Rice Herreth, Georgia (0007-129) 

• Shepherd, Joe (0007-144) (0007-148) (0007-149) (0008-125) (0008-129) 

• Smith, Tom (0007-16) (0007-29) (0010-1) (0010-2) 

• Bludau, Owen (0007-69) (0007-77) (0008-93) (0008-102) 

• Dunham, D.C. (0007-64) (0008-48) 

• Griffith, Mike (0019-2) 

• Head, Bobby (0008-35) 

• Hearn, Polly (0013-3) (0013-4) (0013-5) 

• Knapik, Richard (0007-8) (0007-11) (0008-15) 

• Marceaux, Brent (0008-24) 

• Martin, Bruce (0008-41) 

• McCormick, Mr. (0008-112) 

• Mitchell, James (0007-7) (0008-13) 
Appendix D 

Draft NUREG-1937 D-12 March 2010 

Table D-2. (contd)

Comment Category Commenter (Comment ID)

• Morton, Joe (0007-14) 

• Opella, Ernest (0008-88) 

• Rice Herreth, Georgia (0007-131) 

• Thames, Mitch (0007-41) (0008-49) 

• Morton, Joe (0008-17) 

• Bludau, Owen (0008-95) 

• O’Day, Mike (0007-2) (0007-3) (0007-4) (0008-1) (0008-3) (0008-5) 

(0008-7) 

• Bludau, Owen (0007-70) (0007-75) 

• Griffith, Mike (0019-1) (0019-3) 

• Head, Bobby (0008-37) 

• Hearn, Polly (0013-1) 

• Knapik, Richard (0007-10) (0008-16) 

• Martin, Bruce (0008-42) 

• McDonald, Nate (0016-1) (0016-3) 

• Morton, Joe (0007-12) (0008-20) 

• O’Day, Mike (0007-1) (0007-5) 

• Opella, Ernest (0008-89) 

Transportation • Cushing, Lara (0007-94) 

• Rendon, Genaro (0007-65) 

• Smith, Tom (0007-24) 

Uranium Fuel Cycle • Acevedo, NK (0007-95) (0008-44) 

• Castro, Geoffrey (0007-86) 

• Cushing, Lara (0007-107) (0007-109) 

• Dancer, Susan (0007-91) 

• Dykes, Ed (0008-103) 

• Edwards, Nancy (0012-5) 

• Gunter, Paul (0008-43) 

• Hadden, Karen (0007-31) 

• Lindsey, Joy (0009-4) 

• Lopez, Diana (0007-83) 

• McBurnett, Mark (0007-140) (0008-114) 

• McCormick, Mr. (0008-111) 

• Public Citizen, Texas Office (0010-19) (0010-23) 

• Reed, Cyrus (0003-23) (0003-35) (0003-36) (0003-37) (0003-38) (0003-42) 

(0003-43) (0007-51) (0007-52) (0007-54) (0007-55) (0007-57) 

• Rendon, Genaro (0007-67) 

• Scheurich, Venice (0017-3) 

• Singleton, Robert (0007-124) (0007-125) 

• Sinkin, Lanny (0002-22) (0002-24) (0002-27) (0004-2) 

• Smith, Tom (0007-22) (0007-26) (0010-19) (0010-23) 

• Williams, Mina (0015-2) 
Appendix D 

March 2010 D-13 Draft NUREG-1937 

1 D.2 In-Scope Comments and Responses 

2 The in-scope comment categories are listed in Table D-3 in the order that they are presented in 

3 this appendix. In-scope comments and responses are included below the table. Parenthetical 

4 numbers shown after each comment refer to the Comment Identification (ID) number 

5 (correspondence number-comment number) and the commenter name. Responses have been 

6 edited since publication of the Scoping Summary Report to update section references. 

7 Table D-3. Comment Categories in Order as Presented in this Report

Category 

Number Category Name 

D.2.1 COL Process 

D.2.2 Process - NEPA 

D.2.3 Site Layout and Design 

D.2.4 Land Use - Transmission Lines 

D.2.5 Meteorology and Air Quality 

D.2.6 Geology 

D.2.7 Hydrology - Surface Water 

D.2.8 Hydrology - Groundwater 

D.2.9 Ecology - Terrestrial 

D.2.10 Ecology - Aquatic 

D.2.11 Socioeconomics 

D.2.12 Environmental Justice 

D.2.13 Health - Radiological 

D.2.14 Accidents - Design Basis 

D.2.15 Accidents - Severe 

D.2.16 Uranium Fuel Cycle 

D.2.17 Transportation 

D.2.18 Decommissioning 

D.2.19 Cumulative Impacts 

D.2.20 Need for Power 

D.2.21 Alternatives - Energy 

D.2.22 Alternatives - System Design 

D.2.23 Alternatives - Sites 

D.2.24 Benefit-Cost Balance 
Appendix D 

Draft NUREG-1937 D-14 March 2010 

1 D.2.1 COL Process 

2 Comment: The entire process involved from start to finish of a nuclear project needs to be 

3 examined for direct, indirect, secondary, and cumulative impacts, e.g.: Site preparation The 

4 extraction of materials to build the plant The transportation of the materials to the plant site The 

5 construction process The extraction of materials to produce the equipment to be installed The 

6 transportation of that equipment to the site The installation of that equipment The extraction of 

7 uranium The milling and enriching of uranium The transportation of enriched uranium to the site 

8 The operation of the plant Potential impacts on endangered species (0002-1 [Sinkin, Lanny])

9 Response: With respect to environmental impact analysis, the NRC’s COL process is as 

10 follows: The NRC regulations governing a COL application require that an applicant for a COL 

11 must provide the NRC with an environmental report that meets the requirements of 10 CFR 

12 51.45 and 51.50. As described in 10 CFR 52.17, the contents of an application must focus on 

13 the environmental effects of construction and operation of a reactor or reactors that might be 

14 built at the proposed site. Additionally, Section 52.18 requires that the NRC prepare an EIS for 

15 the application that focuses on the same issues. In its EIS, the NRC staff will review the 

16 impacts of the proposed construction and operation of new nuclear units based on the 

17 information provided in the application and on information obtained from independent sources. 

18 The NRC will document the bases for its conclusions in the EIS and in the COL permit, if 

19 approved. The majority of the impacts noted in the comment are evaluated as part of this COL 

20 environmental review process. Other issues noted fall outside of the regulatory purveyance of 

21 the environmental review. 

22 Comment: We believe that the decision by the NRC to reverse its decision to accept the 

23 application indicates there are serious problems with the process designed by the NRC, and 

24 would suggest that until an EIS is completed, the clock on filing for petition to intervene should 

25 not begin so that the applicant, NRC and potential petitioners can have the benefit of seeing 

26 what an EIS process finds out. (0003-1 [Reed, Cyrus])

27 Comment: Since 1992 there has been a consistent effort to constrain citizen input, not to 

28 expand it. Right now we’ve seen -- and this is all too familiar in Texas -- what we’re seeing is 

29 fast tracking of these permits, and it’s unacceptable. We’ve gone from what should be four and 

30 a half years down to three. We’ve gone from shortened input -- and to be honest, this is -- if this 

31 permit moves forward, it is actually illegal. (0007-36 [Hadden, Karen])

32 Comment: We have a licensing process moving forward with an EIS not even begun. These 

33 are both violations of the statutes and regulations that apply to this process, and I would urge 

34 you to halt all further proceedings on the license application until the environmental impact 

35 statement is finalized as is required by federal law. (0007-40 [Hadden, Karen])

36 Response: These comments express general opposition to the NRC licensing process for the 

37 STP Units 3 and 4 COL, and provide no specific information to the NRC’s associated 

38 environmental review. These comments also fall outside the scope of 10 CFR 51 and 52 which 

39 describe in broad outline the NRC’s environmental review process for a COL. Therefore, these 
Appendix D 

March 2010 D-15 Draft NUREG-1937 

1 comments will not be considered further in regards to the NRC EIS for the STP Units 3 and 4 

2 COL. 

3 Comment: I would also ask that you hold scoping meetings in Houston, which is down wind, as 

4 is Dallas/Ft. Worth, from any potential accident, in Austin and San Antonio, where the cities 

5 could potentially be partners, and to let more people speak up and be part of this process.

6 (0007-34 [Hadden, Karen])

7 Response: Public meetings are generally held in the community geographically located closest 

8 to the proposed project location. Interested parties that are unable to attend the public meetings 

9 in person are also afforded the opportunity to submit written comments. This comment 

10 expresses opposition to NRC’s scoping process, but provides no specific information on the 

11 NRC’s environmental review of the STP Units 3 and 4 COL application. Therefore, this 

12 comment will not be considered further in regards to the NRC DEIS for the STP Units 3 and 4 

13 COL. 

14 Comment: In the case of a nuclear power plant, the NEPA process is interrelated with the 

15 licensing, public participation is through filing petitions to intervene. A key document that could 

16 provide information upon which interveners could build contentions, is the final environmental 

17 impact statement. Yet the 60 day clock has started on intervention petitions as soon as the NRC 

18 accepted the application for docketing, so we now have a deadline of February 25, with no date 

19 even set for a draft environmental impact statement. The EIS will not even begin before the final 

20 deadline for interveners to file. (0007-38 [Hadden, Karen])

21 Comment: And the first concern I would raise is one that’s already been mentioned, which is 

22 the time factor, that there is a feeling among anyone who analyzes the application and analyzes 

23 the environmental report that 60 days simply is not enough time to have a logical and 

24 reasonable assessment, particularly when there’s new information coming in. I do take note of 

25 the issue you raised earlier, which is one can raise contentions later on if new information 

26 comes in. (0007-42 [Reed, Cyrus])

27 Comment: I spoke to Mr. Barrs earlier and, again, was informed that the safety review is not 

28 complete. And even so we as citizens are being asked to have contentions ready in just 20 

29 days. Something tells me that that safety review will not be done during that time. How can we 

30 read it, analyze it, get experts, and prepare a case? That is not right. It is not valid. This -- and 

31 other reports -- the safety review and the final environmental impact statement should be 

32 finished before the licensee procedure goes forward and before citizens have to raise their 

33 contentions. (0008-53 [Hadden, Karen])

34 Response: It is the Commission’s policy that petitions to intervene in the hearing process be 

35 based on the application itself, not the staff’s review of the application. These comments 

36 express opposition to the NRC’s timeline for filing intervention petitions, and provide no specific 

37 information to the NRC’s environmental review of the STP Units 3 and 4 COL application. 

38 Therefore, these comments will not be considered further in regards to the NRC DEIS for the 

39 STP Units 3 and 4 COL. 
Appendix D 

Draft NUREG-1937 D-16 March 2010 

1 Comment: The NEPA law prohibits irreversible or irretrievable commitments of resources prior 

2 to the completion of the EIS. That involves the work that the NRC does on the permit. So 

3 basically what’s going on is that we have docketing of a license application for two nuclear 

4 reactors that is grossly incomplete, forcing potential interveners to decide on whether to pursue 

5 intervention, and to decide on what issue or issues to pursue without a complete application 

6 available. (0007-39 [Hadden, Karen])

7 Response: Section 102(2)(C)(v) of NEPA requires that an EIS include information on any 

8 irreversible and irretrievable commitments of resources that would occur if the proposed action 

9 (approval of the COL) is implemented. Irreversible and irretrievable resource commitments are 

10 relevant to the use of nonrenewable resources and the effects that the loss of use of these 

11 resources may have on future generations. These issues will be discussed in Chapter 10 of the 

12 DEIS. The remainder of this comment expresses opposition to the NRC’s timeline for filing 

13 intervention petitions for the STP Units 3 and 4 COL, and provides no specific information 

14 regarding the associated environmental review. 

15 Comment: We really are not looking for secrets. Our letter of intent in June was published on 

16 the NRC website, was available in the public document room. There were no secrets about our 

17 announcement of the new units. (0007-142 [Shepherd, Joe])

18 Response: This comment makes a statement of fact about the Notice of Intent for the STP 

19 Units 3 and 4 COL application, but provides no specific information on NRC’s associated 

20 environmental review. Therefore, this comment will not be considered further in regards to the 

21 NRC EIS for the STP Units 3 and 4 COL. 

22 Comment: There’s something called the Design Criteria Document, and that’s called the DCD. 

23 I started looking at this license application online and I found a whole section that said 

24 incorporated by reference in the DCD. It took a long time to find out what was a DCD. And then 

25 when I tried to call and get answers I couldn’t get them. Tonight I was informed by Mr. Kallan 

26 that that document is available. Unfortunately it is available only in Washington, D.C. in the 

27 reading room of the Nuclear Regulatory Commission. That is a document that we need. That is 

28 the design criteria for the two advanced boiling water reactors that NRG wants to build here. 

29 That is a document that we need in our hands to effectively be able to write contentions to 

30 submit them in a timely manner. (0008-55 [Acevedo, NK])

31 Comment: Today is February 5. Our contentions have to be submitted in 20 days. I would like 

32 to officially ask when will the DCD be available. The licensing procedure should be halted 

33 immediately until that is available. (0008-56 [Hadden, Karen])

34 Response: These comments express opposition to the limited availability of the Design Criteria 

35 Document during the period for filing intervention petitions. These comments provide no 

36 specific information to the NRC’s environmental review of the STP Units 3 and 4 COL 

37 application, therefore, these comments will not be considered further in regards to the NRC EIS 

38 for the STP Units 3 and 4 COL. 
Appendix D 

March 2010 D-17 Draft NUREG-1937 

1 Comment: In section 5.4.1 of the environmental report there is a section of radiological impact 

2 and exposure pathways. Here is says -- and I will quote -- Radioactive liquids and gasses would 

3 be discharged to the environment during normal operation of STP 3 and 4. The released 

4 quantities have been estimated in Tables 12.2-20 for the gasses and Table 12.2-22 for liquids of 

5 the ABWR DCD. So the documents containing the quantities of radioactive material that would 

6 be released during normal operations are not yet available to the public. (0008-57 [Hadden, 

7 Karen])

8 Response: This comment expresses opposition to the limited availability during the scoping 

9 period of documents containing the quantities of radioactive material that would be released 

10 during normal operations. This comment provides no specific information relevant to the 

11 environmental review of the STP Units 3 and 4 COL application and therefore will not be 

12 considered further in the EIS. 

13 Comment: In the old days we used to have a PSAR, a preliminary safety analysis report. Now 

14 we don’t have that. Now we have an FSAR. How on earth can anybody call that thing final. It’s 

15 totally incomplete at this time. We don’t have to fib to each other. It’s not done. It’s not even 

16 close. Okay. We need to extend the comment period because the information is not there.

17 (0008-81 [Wagner, William])

18 Comment: The other part of this that’s a real hard spot with me because I am an old reactor 

19 operator is it is totally inappropriate to license operation on a woefully incomplete safety analysis 

20 report. I don’t know how the devil you guys ever came to that conclusion, but that needs to be 

21 looked at seriously. (0008-82 [Wagner, William])

22 Response: This comment expresses opposition to the length of the NRC’s scoping comment 

23 period due to a perceived lack of safety information. The safety review is outside the scope of 

24 the environmental review process and therefore this comment will not be considered further in 

25 the EIS for STP Units 3 and 4. 

26 D.2.2 Process - NEPA 

27 Comment: justifies moving forward - NEPA requirements [The commenter was questioning if 

28 there should have been a NEPA review prior to accepting the application to justify moving 

29 forward with the process.] (0020-1 [Hadden, Karen])

30 Response: A NEPA environmental review could not have been conducted prior to accepting 

31 the application because the NRC would have had no project-specific information on which to 

32 base its review. Docketing an application for review is not a major federal action and therefore 

33 does not require a NEPA review. The comment provides no new information relevant to the 

34 environmental review process and will not be evaluated further. 

35 Comment: I’d also like to request additional scoping meetings regarding the environmental 

36 report. There are many people I know of in Austin who could not make this trip who would like to 

37 comment in person. There are people in San Antonio and Houston as well. I would urge you to 
Appendix D 

Draft NUREG-1937 D-18 March 2010 

1 set up scoping meetings in those communities for this environmental report. (0008-52 [Hadden, 

2 Karen])

3 Comment: We also deserve and request that the NRC conduct public hearings in San Antonio 

4 on those [energy] alternatives and the environmental impacts of STP 3 & 4 as part of the 

5 scoping process. (0018-2 [Cushing, Lara])

6 Response: Although NEPA does require Federal agencies to initiate a scoping process, the 

7 decision of how to implement scoping is left to the agencies’ discretion. It is the policy of the 

8 NRC to involve the public in the Commission’s decision-making process and therefore it elects 

9 to conduct open public scoping meetings in association with their environmental review process. 

10 Meetings are generally held in a location to reach the highest population that will experience the 

11 most direct environmental impact as a result of the proposed action. In the case of STP Units 3 

12 and 4, this population is located in the area of Bay City, Texas. The NRC will hold additional 

13 public meetings after the DEIS is published. Separate meetings will be held by the NRC in 

14 association with the safety review process. Members of the public who are unable to attend the 

15 public meetings in person may submit written comments during the open comment periods. 

16 D.2.3 Site Layout and Design 

17 Comment: So how come we learned today that the design of record is by Toshiba? I think 

18 there’s a big mess going on here that we don’t know about. (0007-113 [Payne, Cameron])

19 Response: The applicant experienced unresolvable issues with the vendor originally identified 

20 in the application. The type and design of the reactor did not change as a result of the change 

21 in vendors, therefore, the reactor-specific information provided in the application is still valid for 

22 the analysis. 

23 Comment: The advance boiling water reactor in Japan, there’s four of them in operation in 

24 Japan, was developed as a joint venture between General Electric, Hitachi and Toshiba. They 

25 all jointly own that design in Japan. GE took that design and got it certified in the United States. 

26 Where did that design come from, you asked about the safety, what is this, what is the safety 

27 record. We’ve been operating boiling water reactors in the United States since 1960. The boil 

28 water reactors, through each generation, have evolved into -- further and further involved into a 

29 more advanced design. When GE and Hitachi and Toshiba went to develop the advanced 

30 boiling water reactors, they started with the BWR-6, the latest design that’s currently in 

31 operation in the United States. They took that design and they looked at the rules under Part 

32 52, what they needed to address, and they looked at the things that were bothering them about 

33 the BWR-6 that didn’t work as well as they wanted it to, things they could make it safer, things 

34 that make it more reliable, they addressed those issues and developed the advanced boiling 

35 water reactor. It’s very similar in operation and design to the BWR-6. We have many, many, 

36 many years of experience operating those plants. (0007-136 [McBurnett, Mark])

37 Comment: [The ABWR’s] lineage is over 60 years of operation in the United States and around 

38 the world. And the plans that we’re looking at are an evolutionary design that’s based upon the 
Appendix D 

March 2010 D-19 Draft NUREG-1937 

1 best that was in the United States. The design’s certified by the NRC, and meets all U.S. 

2 standards. (0007-146 [Shepherd, Joe])

3 Comment: Besides the good operating record that we saw with the advanced boiling water 

4 reactors in Japan, we choose them also because of their record associated with on-time 

5 construction, on-budget cost, and on schedule. And that performance, we believe we can 

6 replicate in the United States. (0007-147 [Shepherd, Joe])

7 Comment: This technology [ABWR] has a long lineage in the United States. The design that 

8 has been built in Japan was predicated by 60 years of operations of boiling water reactors in the 

9 United States as a evolutionary design from our very best in the United States, the BWR6. And 

10 it’s better. It’s a G.E. design. It’s been certified by the Nuclear Regulatory Commission. And it 

11 meets all U.S. standards. We [STP] chose the ABWR because of the operating record that it 

12 has, but we also chose it because of the record that it has for being constructed on time and on 

13 budget. (0008-128 [Shepherd, Joe])

14 Response: These comments are general in nature regarding the advanced boiling water 

15 reactor (ABWR) design chosen for Units 3 and 4. No new information relevant to the 

16 environmental analysis was provided and therefore the comments will not be evaluated further. 

17 D.2.4 Land Use - Transmission Lines 

18 Comment: Actually South Texas has three different power line corridors leaving the site. The 

19 advanced boiling water reactors will also have cross-ties into the Unit 1 and 2 switch yard.

20 (0008-121 [McBurnett, Mark])

21 Response: The power transmission system will be described in Chapter 3 of the DEIS. The 

22 applicant proposes to upgrade two of the six existing transmission lines and does not intend to 

23 construct any new transmission lines or corridors. Environmental impacts associated with the 

24 planned upgrades to the existing transmission lines will be addressed under construction 

25 impacts in Chapter 4 of the DEIS. 

26 D.2.5 Meteorology and Air Quality 

27 Comment: One of the new issues affecting decisions on nuclear power is the global concern 

28 over Human activity creating global climate change with unpredictable and potentially 

29 devastating results. While the nuclear industry successfully used this concern to drive their 

30 lobbying effort for a new generation of nuclear power plants, the premise that nuclear power is a 

31 positive response to global climate change concerns may not withstand objective examination. 

32 The EIS should include such an objective examination. (0002-3 [Sinkin, Lanny])

33 Comment: The context for evaluating emissions of gasses attributable to a nuclear power plant 

34 should include those gasses emitted during the following: Site preparation The extraction of 

35 materials to build the plant The transportation of the materials to the plant site The construction 

36 process The extraction of materials to produce the equipment to be installed The transportation 
Appendix D 

Draft NUREG-1937 D-20 March 2010 

1 of that equipment to the site The installation of that equipment The extraction of uranium The 

2 milling and enriching of uranium The transportation of enriched uranium to the site The 

3 operation of the plant, including the emission of heat and evaporated water. (Water vapor is a 

4 powerful green house gas. The EIS should provide a conversion of the amount of water vapor 

5 created by the nuclear plant operating process to the equivalent carbon dioxide emissions.) The 

6 decommissioning of the plant. The transportation of radioactive waste, including high level, low 

7 level, and decommissioning waste to final storage. The preparation and operation of sites where 

8 the radioactive waste is to be stored. (0002-4 [Sinkin, Lanny])

9 Comment: Water vapor is a powerful green house gas. The EIS should provide a conversion 

10 of the amount of water vapor created by the nuclear plant operating process to the equivalent 

11 carbon dioxide emissions. (0002-5 [Sinkin, Lanny])

12 Comment: Climate change can also be associated with increased air and water temperature 

13 which could impact the ability of the cooling system and intake to operate sufficiently. Thus, 

14 temperature change must be assessed more accurately. (0003-32 [Reed, Cyrus])

15 Comment: While the ER takes credit for the emissions reduction that would be made by 

16 investing in a nuclear plant as opposed to a coal or natural gas plant (see discussion above), it 

17 does not discuss the global warming emissions resulting from the mining, processing, 

18 enrichment and fuel fabrication of uranium needed for the plant. (0003-41 [Reed, Cyrus])

19 Comment: We feel there are cleaner, safer and quicker ways of achieving global warming 

20 goals. For example, nuclear power plants take a long time to build, and they’re not going to 

21 really do anything in terms of the carbon footprint. (0007-105 [Singleton, Robert])

22 Comment: When you look at the carbon footprint for a nuclear power plant, you also have to 

23 consider the fact that mining and manufacturing -- mining of uranium and enrichment of uranium 

24 add carbon to the air, and the lower grade that uranium is, the harder it is to mine, the further 

25 you have to go to get it, all of those things add to the footprint. Also, transportation and storing 

26 of nuclear waste have to be added to that. This is not a zero carbon footprint industry. It’s only a 

27 zero carbon footprint industry is you look just at plant operation. And I’m not even sure that’s 

28 true. But if you look beyond plant operation to how they get the uranium, and what they do with 

29 the waste, it’s to a zero carbon footprint industry. (0007-119 [Singleton, Robert])

30 Comment: We are not against renewables, solar, wind, conservation, efficiency. We teach our 

31 people to look carefully at decisions, .... I think that the studies that you look at on global 

32 warming, on greenhouse gases all tell you that you need all of that, including nuclear power, to 

33 be able to make any kind impact on reducing the emission of greenhouse gases and reversing 

34 the trends that we see in our global climate. (0007-145 [Shepherd, Joe])

35 Comment: Also -- it is also a myth that nuclear energy will save us from global warming. We 

36 hear that a lot and it is not. It is not the truth, it is a myth. A nuclear power plant also creates 

37 global warming. (0007-81 [Lopez, Diana])
Appendix D 

March 2010 D-21 Draft NUREG-1937 

1 Comment: So you have uranium in South Texas, so you need to get it enriched, and there are 

2 only two coal power plants that do that, and they’re not in Texas. So you have to transport the 

3 uranium to these coal power plants and you have to enrich it, and it causes -- it’s one of the 

4 primary sources of a potent greenhouse gas that causes global warming. So -- and then you 

5 have to transport it back to the nuclear reactor, so that causes CO2 emissions, so you have all 

6 these accumulating effects just for that source of energy. (0007-82 [Lopez, Diana])

7 Comment: The enrichment takes place at coal-fired facilities that pollute the air and contribute 

8 to global warming. This is an environmental impact of the South Texas Project. (0007-93

9 [Cushing, Lara])

10 Comment: We seem to be given what we at the plant call a sucker’s choice. Either you have 

11 renewables and efficiency or you have nuclear power. The studies that I have read that are 

12 done by eminent researchers say that in order to make any kind of significant contribution to the 

13 reduction of greenhouse gasses being released into the environment, you need it all. You need 

14 efficiency; you need renewables; and you need nuclear power if you want to make any kind of a 

15 significant contribution to reducing greenhouse gasses being released into the environment.

16 (0008-126 [Shepherd, Joe])

17 Comment: The two nuclear plants that are being proposed here would offset 15.8 million tons 

18 of carbon dioxide, 38.8 thousand tons of sulfur dioxide, and 10.7 thousand tons of nitrogen 

19 oxide. (0008-6 [O’Day, Mike])

20 Response: <The review team characterized the affected environment and the potential 

21 greenhouse gas impacts of the proposed actions and alternatives in this EIS. The impacts of 

22 fuel cycle, transportation, and decommissioning on climate change and global warming are 

23 addressed in Chapter 6. Appendix I provides details of the carbon dioxide footprint estimate for 

24 a 1000 MW(e) light water reactor. In addition, where it was important to do so, the review team 

25 considered the potential effects of global climate change during the period of the proposed 

26 action on other resource assessments.>

27 D.2.6 Geology 

28 Comment: We may have a problem with soil subsidence. Not too far away from the existing 

29 site, on the other side of Highway 60, there is an old Texas Gulf sulphur site at Gulf. Sulphur 

30 was mined out of there for many, many years. The site was finally abandoned. The company 

31 moved north out of the county in the area between Highway 60 and Bowling. About five years 

32 after I moved down here in 1983, that highway fell down into the ground -- a sinkhole. That was 

33 caused by that sulphur mining that was going on at a place called Newgulf. Is this a possibility 

34 for the old Gulf site? Would this offer some compromise to the ultimate heat sink or cooling 

35 pond? (0008-69 [Wagner, William])

36 Response: Geologic impacts on the proposed facility from off-site actions are in scope of the 

37 safety analysis and will be addressed in the FSAR issued and maintained by the applicant and 

38 SER issued by the NRC. The topic of subsidence and sink holes and their potential impact on 
Appendix D 

Draft NUREG-1937 D-22 March 2010 

1 the proposed facility will be addressed in Section 2.5 of the FSAR. This comment is out of 

2 scope with regard to the EIS. 

3 D.2.7 Hydrology - Surface Water 

4 Comment: Exelon Nuclear decided to move its proposed nuclear plant from Matagorda County 

5 to Victoria County based on concerns about the costs of preparing for a 20 to 30 foot storm 

6 surge. How would those same concerns apply to the STNP Units 3 and 4? (0002-11 [Sinkin, 

7 Lanny])

8 Comment: If global warming increases sea level rise by 7 meters - will STNP be within the 

9 storm surge zone? (0010-11 [Public Citizen, Texas Office] [Smith, Tom])

10 Response: As part of the NRC’s site safety review, the staff will consider whether the site is 

11 suitable based on storm surge issues. The results of this review will be found in the site Safety 

12 Evaluation Report. This issue is not within the scope of the environmental review. 

13 Comment: There are also numerous studies underway regarding the needs of the bays and 

14 estuaries near STNP. Review of those studies regarding potential fresh water needs of the 

15 environment and potential effects on the availability of water to STNP should also be part of the 

16 EIS process. (0002-16 [Sinkin, Lanny])

17 Comment: [T]he LCRA [Lower Colorado River Authority] still has an ongoing assessment of 

18 the flow needs of Matagorda Bay. The Inflow Needs Study has yet to be finalized and integrated 

19 into any management decisions of the LCRA and has yet to be incorporated into any water 

20 rights requirements. An EIS must assess the inflow needs of the Matagorda Bay and its 

21 potential impact on the South Texas Project. We would specifically suggest that an EIS examine 

22 the comments submitted by TPWD on the Matagorda Bay Inflow Criteria Report on January 

23 22nd, 2008. (0003-26 [Reed, Cyrus])

24 Comment: [A]ny EIS must address the proposed water rights permit being sought by LCRA for 

25 the so-called “excess” flows. This proposed water right is presently being contested by the 

26 Sierra Club in part because of our concern that existing and proposed water use - such as the 

27 South Texas Project - as well as the proposed permit would impact the flows into Matagorda 

28 Bay. The permit being sought by LCRA is intimately connected to the so-called LCRA -SAWS 

29 water project to provide the City of San Antonio with surface water through construction of an 

30 off-river reservoir not far from the proposed South Texas project. How construction of such a 

31 reservoir might impact water quality, water availability, water temperature and other parameters 

32 that could impact the South Texas plant must be considered. (0003-27 [Reed, Cyrus])

33 Comment: [M]y wife has a place in Egypt, Texas, and that’s probably why I’m here today. She 

34 couldn’t come today. I’ll talk a little bit on her behalf. She’s a direct competitor for the water 

35 that’s already allocated to the makeup water I guess for that cooling lake. And so she’s 

36 concerned on a -- just a on a practical matter. She’s a rice farmer, cattle rancher and a low crop 

37 farmer in Egypt, Texas. (0007-126 [Conrad, A.C.])
Appendix D 

March 2010 D-23 Draft NUREG-1937 

1 Comment: My issue here today is water. If we’re going to be taking water from the Colorado 

2 River, and giving 3,935 gallons per minute to cool a new nuclear reactor, we’re also going to be 

3 compromising our need for water to San Antonio where humans need water to drink, because 

4 San Antonio, with the SAWS project, which is San Antonio Water System, the LCRA is going to 

5 be draining water off the Colorado River to provide for San Antonio. (0007-133 [Schwank, 

6 Eleanor])

7 Comment: We have our rice farmers who absolutely need our water. We have out cattlemen 

8 who absolutely need our water. And let’s not forget our aquaculture, or bays and our estuaries. 

9 Everybody’s coming to Matagorda because they all love our fishing, but we’re not going to have 

10 fish, we’re not going to have oysters, we’re not going to have shrimp, we’re not going to have 

11 anything if we’re not protecting our water. (0007-134 [Schwank, Eleanor])

12 Comment: There are a number of river studies going on right now, not the least of which by the 

13 Lower Colorado River Authority, who is in charge of this particular chunk of water. (0008-79

14 [Wagner, William])

15 Comment: This new plant will use 4,000 gallons of water per minute. The plant is also 

16 authorized to use both river and groundwater water. The plant is authorized to use up to 102 

17 acre feet of river water per year, and use about half of that annually for STNP 1 & 2. If the plant 

18 uses its full allotment (of water), will there be adequate water for the new reservoir? (0010-4

19 [Public Citizen, Texas Office] [Smith, Tom])

20 Comment: The LCRA-SAWS Water Project (LSWP) is based on a Definitive Agreement 

21 between SAWS and LCRA, signed in 2002, for the purchase of up to 150,000 acre ft/yr of 

22 surface water from the Lower Colorado River Basin at Bay City. If the plant takes its full 102 

23 acre feet, will there be enough water for San Antonio to meet its water needs? (0010-5 [Public 

24 Citizen, Texas Office] [Smith, Tom])

25 Comment: If it [the new plant] takes its full allotment of 3,935 gallons per minute will there be 

26 adequate water for rice farmers and others? (0010-6 [Public Citizen, Texas Office] [Smith, Tom])

27 Response: The impact on current and future water use in the vicinity of the site from the 

28 additional water withdrawals from the Colorado River needed to operate STP Units 3 and 4 will 

29 be evaluated and presented in Chapter 5 of the EIS. 

30 Comment: A similar situation would be the temperature of that water. We’ve had issues -- and 

31 I say we -- I mean the United States has had issues recently on nuclear plant where because 

32 the temperatures have gone up, the water temperature has gone up, which has made it difficult 

33 for those operators to be able to use the water and then discharge the water back in the rivers. 

34 And I’m speaking about some -- a nuclear plant in Tennessee. And some of the nuclear plants 

35 in Europe had a similar situation last summer. (0007-48 [Reed, Cyrus])

36 Response: The comment refers to rising temperatures in the Main Cooling Reservoir and how 

37 this condition may relate to continued operation of the STP units and to blowdown from the 

38 reservoir to the Colorado River. The NRC staff’s evaluation of the thermal properties of the 
Appendix D 

Draft NUREG-1937 D-24 March 2010 

1 blowdown discharge from the reservoir to the Colorado River when all four units are in operation 

2 will be presented in Chapter 5 of the EIS. 

3 Comment: My understanding was when you reach certain amounts of -- when the water quality 

4 is of a certain type, in other words, if there’s a lot of sediment in the water, you do have to 

5 discharge some back into the river. (0007-49 [Reed, Cyrus])

6 Response: The comment refers to the blowdown from the Main Cooling Reservoir to the 

7 Colorado River at the STP site. The NRC staff’s evaluation of the frequency of blowdown and 

8 its impact on the Colorado River when all four STP units are in operation will be presented in 

9 Chapter 5 of the EIS. 

10 Comment: Our cooling reservoir’s a closed cycle system. We do take make-up water out of the 

11 river to keep that reservoir filled. We take make-up water out of the river most of the times 

12 during high-flow conditions when it’s, you know, a lot of water flowing through it, to keep it filled. 

13 The water actually cools in the reservoir, it goes around its little loop and cools to the air, it 

14 doesn’t -- the hot water does not go back to the river. So it’s closed cycle. We use it for make15 up, and just to clarify the operating points, because I think that was confused earlier. (0007-141

16 [McBurnett, Mark])

17 Response: This comment provides some information regarding the closed-loop cooling system 

18 in use for STP Units 1 and 2. No response is needed. 

19 Comment: Nuclear Power Plants use vast amounts of water. The Union of Concerned 

20 Scientists, in a document entitled “Got Water? Nuclear power plant cooling water needs,” details 

21 in a 14-page illustrated summary problems power plants have when the “insatiable cooling 

22 water needs were not met.” The threat of drought is real in Texas, as is the potential shortage of 

23 water. (0015-6 [Williams, Mina])

24 Response: The NRC staff’s assessment of water use requirements for the operation of STP 

25 Units 3 and 4 including those during drought conditions will be presented in Chapter 5 of the 

26 EIS. 

27 Comment: ...of the 12,200 acres containing the current South Texas Nuclear Project, 7,000 of 

28 these acres (over 57%) comprise the reservoir needed for the cooling water. ... how much of 

29 this water is lost to evaporation and how much more water might need to be diverted into the 

30 reservoir if STP expansion is approved. (0017-1 [Scheurich, Venice])

31 Response: The water withdrawal and consumptive use requirements for the operation of STP 

32 Units 3 and 4 will be provided in <Chapter 2> of the EIS. 

33 Comment: As sea levels rise, groundwater can be affected, both in terms of expansion into the 

34 surrounding soils and in water quality, e.g. salt water intrusion. The effects of such changes 

35 should be included in the EIS. (0002-12 [Sinkin, Lanny])
Appendix D 

March 2010 D-25 Draft NUREG-1937 

1 Comment: The combination of reduced precipitation, higher rates of evaporation and 

2 evapotransporation, and increased number of droughts suggest that relying on the worst 

3 historical drought may not be a conservative approach. (0002-13 [Sinkin, Lanny])

4 Comment: A conservative approach to evaluating the adequacy of the water supply available 

5 to STNP would incorporate the possibility that global warming would produce a drought worse 

6 than the worst historical drought at a time when available water is already reduced by reduced 

7 precipitation and increased evaporation and evaportransporation. That evaluation would 

8 consider: -- the time frame within which the global warming impacts would be expected and the 

9 projected operating life of the reactors, including renewal of licensing and -- the likelihood of a 

10 drought worse than the worst historical drought and the potential impact of such a drought on 

11 the operations of the reactors. (0002-14 [Sinkin, Lanny])

12 Comment: At the same time, there are credible studies that posit greenhouse warming as a 

13 precursor to rapid cooling. Schwartz and Randall, An Abrupt Climate Change Scenario and Its 

14 Implications for United States National Security, October 2003. Any evaluation of potential 

15 global warming impacts should examine the potential impacts of this alternative scenario for 

16 climate change, including the impacts on available water. (0002-15 [Sinkin, Lanny])

17 Comment: A true EIS must examine the relationship between the water needs of the proposed 

18 plants, its water use, water availability as well as how climate might impact those uses. (0003-25

19 [Reed, Cyrus])

20 Comment: The impacts of global warming on the proposed plant must be assessed. Thus, 

21 when the first STP site was assessed, normal historic drought and water availability were a 

22 concern, and today, the flow of the Colorado upstream of STP is a real concern during summer 

23 months, when flows are often lower and evaporation is higher. Nonetheless, the recent IPCC 

24 Assessments on the impacts of global warming, as well as independent assessments in Texas - 

25 such as the 1995 Gerald North study - suggest that global warming is likely to affect climate and 

26 water availability, including in Central Texas. (0003-28 [Reed, Cyrus])

27 Comment: It would seem any EIS must assess the impacts of global warming and the 

28 likelihood that droughts in coming decades could be more severe than droughts in the 1940 and 

29 1950s which are traditionally used as the “drought of record” to determine likely flows. 

30 Contingencies must be added for flows that are 20 percent or more less than historic drought 

31 levels. The EIS should rely in part on studies being conducted by the LCRA on the issue of the 

32 impact of climate change on flows as part of the assessment. (0003-29 [Reed, Cyrus])

33 Comment: What about water use? With the droughts we’ve been having and with the 

34 increasing belief that global warming is a significant issue in this part of the country, will there be 

35 significant decreases in the amount of available water, and what will that mean to the operations 

36 of this plant? (0007-18 [Smith, Tom])

37 Comment: One of the issues that’s come up in terms of what scientists are telling us is that 

38 climate is changing. Yes, it always has changed, but it’s changing more rapidly than in the past. 
Appendix D 

Draft NUREG-1937 D-26 March 2010 

1 And so, again, I would urge you, in the environmental analysis to look at how climate change 

2 might impact river flow, because I know that STP has an existing water right, and it appears on 

3 paper that you’ve got the water to operate your -- you know, the present plants and the plants in 

4 the future. (0007-45 [Reed, Cyrus])

5 Comment: Is it really a good investment if in 30 years our flows are going to be that much less, 

6 will the water really be available and be there? Because if the plant is built and then doesn’t 

7 operate, it doesn’t make economic sense for anybody. (0007-47 [Reed, Cyrus])

8 Comment: So I’m here to tell about global warming and how it affects it. With the growth of 

9 global warming you have to include how will this contribute the nuclear power plants, and how it 

10 will affect them. So the plant requires water to cool it down, and it requires cold water. So with 

11 global warming, there’s going to be less water and it’s going to be warmer, so you have to 

12 consider what the nuclear reactors will be in situations like that. (0007-68 [Lopez, Diana])

13 Comment: Are there going to be temperature limits? We’re living in a world where 

14 climatological change is causing warming -- global warming. We know the sea level is rising. It’s 

15 already bothering the Chinese. It’s not bothering us yet, but it will. Now, what’s causing it isn’t a 

16 concern here. The mere fact that it’s happening -- and it needs to be analyzed. We’re talking 

17 about a grand total of about 60 years. We need to look at that. (0008-77 [Wagner, William])

18 Comment: If global warming is occurring and as severe as we anticipate: If the plant adds 

19 approximately 14.3°F to the water temperature, and the current intake temperature has been as 

20 high as 95.6°F, can the plant operate safely with a predicted 3-10°temperature increase due to 

21 global warming by 2100? (0010-10 [Public Citizen, Texas Office] [Smith, Tom])

22 Comment: If global warming is occurring and as severe as we anticipate: Will there be enough 

23 water for cooling decline if a 25% decrease in river flows occurs? (0010-7 [Public Citizen, Texas 

24 Office] [Smith, Tom])

25 Comment: If global warming is occurring and as severe as we anticipate: Will the cooling water 

26 be cool enough to allow the plant to operate? (0010-9 [Public Citizen, Texas Office] [Smith, Tom])

27 Response: The construction and operation of a nuclear plant involves the consumption of 

28 water. The staff will independently assess the impact of these consumptive water losses on the 

29 sustainability of both the local and regional water resources. This assessment will consider both 

30 current and future conditions, including changes in water demands to serve the needs of the 

31 future population and changes in water supply resulting from climate variability and climate 

32 change. While NRC does not regulate or manage water resources, it does have the 

33 responsibility under NEPA to assess and disclose the impacts of the proposed action on water 

34 resources. The staff’s assessment of the impacts on the sustainability of water resources will 

35 be presented in Chapters 4 and 5 of the EIS for construction and operation, respectively. 

36 Comment: There is substantial evidence to support the prediction that melting the South 

37 Antactic ice cap and the Greenland glacier will cause a rise in sea level ranging from 6 to 12 

38 feet (This scenario is presented as a reasonable probability, not a worst case. The sea level rise 
Appendix D 

March 2010 D-27 Draft NUREG-1937 

1 would probably take place over an extended period of time and probably within the operating life 

2 of the proposed nuclear power plants). Assuming that sea level were to rise to that extent, what 

3 would be the impact on: (1) the operations of the plant (2) the access to the plant from off-site, 

4 particularly by emergency response personnel and equipment (3) the ability to evacuate the 

5 plant in case of emergency (4) the ability to evacuate surrounding communities in case of 

6 emergency (0002-6 [Sinkin, Lanny])

7 Response: Parts (2)-(4) of this comment relate to emergency planning and response and are 

8 not within the scope of NRC staff’s environmental review. Part (1) of the comment can be 

9 interpreted to have both a safety and an environmental aspect. As part of the NRC’s site safety 

10 review, the staff will consider whether the site is suitable based on characteristics of the site 

11 including long-term variability in flooding levels. The results of this review will be found in the 

12 site Safety Evaluation Report. This issue is not within the scope of the environmental review 

13 and will not be discussed in the EIS. As part of the NRC’s environmental review, the staff will 

14 independently assess the impact of consumptive water losses during operation of the plant on 

15 the sustainability of water resources including consideration of current and future conditions 

16 resulting from climate variability and climate change. The staff’s assessment of the operation 

17 impacts will be presented in Chapter 5 of the EIS.

18 D.2.8 Hydrology - Groundwater 

19 Comment: Subsidence, no. What happens if we over-use the ground water in this community, 

20 and will there be a decrease in the level of the plant? (0007-23 [Smith, Tom])

21 Response: The NRC is also concerned about subsidence and will be evaluating the potential 

22 for subsidence at the station. Information on the NRC evaluation of subsidence will appear in 

23 Chapter 4 on water-use impacts during construction and in Chapter 5 on water-use impacts 

24 during station operation. The topic of subsidence and sink holes and their potential impact on 

25 the facility will also be addressed in Section 2.5 of the applicant’s FSAR. 

26 Comment: If global warming is occurring and as severe as we anticipate: Will groundwater 

27 decline? (0010-8 [Public Citizen, Texas Office] [Smith, Tom])

28 Comment: ...in researching in-situ uranium mining, we have discovered that that activity also 

29 requires enormous amounts of groundwater during the mining process and that there is a high 

30 likelihood that the mining will contaminate portions of the Gulf Coast Aquifer. For example, the 

31 company which has applied for a permit to mine in Goliad County, about 100 miles west of here, 

32 will need 72,000 gallons of water a day during mining and additional vast amounts when 

33 restoration (which probably won’t be possible) is attempted. (0017-2 [Scheurich, Venice])

34 Response: Changes in the availability of the water resource by competing demands and long35 term variability will be addressed in the cumulative impacts <Section 7.2> on water use and 

36 quality. 
Appendix D 

Draft NUREG-1937 D-28 March 2010 

1 D.2.9 Ecology - Terrestrial 

2 Comment: What about endangered species? There are kemp ridley turtles, whooping cranes, 

3 and others that are on the threatened and endangered species list in this community. Many of 

4 them we are beginning to understand how significant they are since they last time this plant was 

5 permitted in this community. (0007-21 [Smith, Tom])

6 Comment: There are Kemp Ridley sea turtles and whooping cranes in the vicinity. How will 

7 construction and operation of the new reactors affect their habitats? What other species will be 

8 affected? (0010-17 [Public Citizen, Texas Office] [Smith, Tom])

9 Response: The comments relate to aquatic and terrestrial ecology issues and will be 

10 considered in the preparation of the DEIS. NRC’s consultations with the National Marine 

11 Fisheries Service and the U.S. Fish and Wildlife Service regarding threatened and endangered 

12 species will be discussed in Chapter 4 of the DEIS. 

13 Comment: [T]he lake that [STP has] -- the 7,000 acre -- also creates some of the best bird 

14 habitats in the state of Texas. (0008-2 [O’Day, Mike])

15 Comment: [R]ecently I had the opportunity to go and sit on a pier and watch my brother fish 

16 and a friend of his. ... So we sat for a time. And as we did, as the conversation waned, I heard 

17 something. And the longer you listened, the louder it got. And that that I was hearing were frogs: 

18 frogs that were speaking loudly. And if you know anything about frogs, they’re the most -- or one 

19 of the most sensitive animals in our environment. And they were not only loud, but they were 

20 interactive. And I came to understand that as sensitive an issue as this is the creatures of the 

21 world tell us a lot. And for them to be out in such a large and strong body to be heard at night, 

22 and them being such a sensitive creature that they through their skins osmose anything the 

23 environment deals to them, their presence made me understand that we have a very 

24 environmentally safe -- not just our nuclear facility, but numerous facilities that operate along our 

25 river -- something I’m very proud of in our county -- something they should be proud of, and I 

26 think everyone should be well aware of. (0008-23 [Marceaux, Brent])

27 Comment: Also the alligators -- the nuclear power plant is -- the whole grounds -- in a 

28 protected wildlife zone. They’ve not only done that, they’ve gone in and put in a -- what’s called 

29 a wetlands -- their own private wetlands so, you know, to help that. (0008-33 [Head, Bobby])

30 Comment: In the last 20 years that the nuclear power plant has been here the National 

31 Audubon Society, year in and year out -- I don’t know if you all know this but Matagorda County 

32 is the number one birding center in the nation -- more birds -- more species of birds every year. 

33 They just did the Christmas bird count -- number one in the nation again this year -- more 

34 species of birds in Matagorda County. (0008-34 [Head, Bobby])

35 Response: The comments are noted. Terrestrial resources, including all the aforementioned 

36 species, will be discussed in Chapter 2 of the DEIS. 
Appendix D 

March 2010 D-29 Draft NUREG-1937 

1 D.2.10 Ecology - Aquatic 

2 Comment: I had an opportunity one night working nights to go out and work where the pumps 

3 are out on the reservoir. And I walked out and I looked down and I said, Geez, as a fisherman 

4 here are these huge catfish and these huge red fish swimming together down there. Now, at -- 

5 the environment -- if they’re doing something about the environment they’re making the fish 

6 grow big. I can tell you that. (0008-32 [Head, Bobby])

7 Response: The DEIS will discuss the aquatic resources at STP in Chapter 2 and will consider 

8 potential impacts from construction and operation of the two new units in Chapters 4 and 5, 

9 respectively. 

10 Comment: As evidenced in the Environmental Report itself, low-flow conditions move the line 

11 of salinity upstream from Matagorda Bay, leading to more entrainment and entrapments of 

12 estuarine species, as well as the likely movements of bird species such as pelicans which feed 

13 on such aquatic species. Thus, the relationship between the salinity line, aquatic species and 

14 climate must be examined. (0003-30 [Reed, Cyrus])

15 Response: The DEIS will consider the aquatic biota in the Colorado River, including species 

16 that move up the river from Matagorda Bay. Recent data collected in the lower Colorado River 

17 will be used to characterize the aquatic biota, as well as, various water quality indicators 

18 (including salinity) that will be used to describe the aquatic environment and analyze potential 

19 impacts from the project. Entrainment, entrapment and impingement of the aquatic biota in the 

20 river at the vicinity of the plant’s intake structure will be evaluated in Chapter 5 of the DEIS. 

21 Potential behavioral changes in other non-aquatic species, such as pelicans, resulting from the 

22 proposed construction and operation of the additional units will also be analyzed. 

23 Comment: It should be noted that the ER relies heavily on monitoring data of aquatic species 

24 and water levels from the initial application of 1973 which must be updated to reflect a much 

25 more saline, lower flow regime which typifies the region today. (0003-31 [Reed, Cyrus])

26 Comment: In terms of the assessment of water contained in the ER, there are multiple 

27 sections which continue to rely on dated aquatic monitoring of the Colorado River which must 

28 be updated and specified as part of an EIS. Thus, as an example, relying on histograms of 

29 sediment levels in the Colorado River from 1957 to 1973, as is done in Section 2.3.1.1.5 is 

30 clearly incomplete. (0003-34 [Reed, Cyrus])

31 Response: The DEIS will include the results of a 12-month monitoring program conducted in 

32 2007 and 2008 to assess aquatic species and conditions of the lower Colorado River. 

33 Comment: I know that more than half ( by weight) of the biomass in the earth is in the form of 

34 microorganisms which live under the surface of the earth and bodies of water. The earth is 

35 teaming with life to depths below 10,000 feet, especially in coastal plains such as found around 

36 STP. Some of these organisms have beneficial effects on the biosphere, e.g., producing oxygen 

37 and absorbing carbon. I am concerned about the effect on these organisms which would result 
Appendix D 

Draft NUREG-1937 D-30 March 2010 

1 from a massive radioactive effluent leak into the ground, or cooling pond, or the Colorado River. 

2 An EIS should consider this important effect. (0005-6 [Payne, Cameron])

3 Response: NRC regulations require strict monitoring of radioactive effluent releases. In 

4 addition, new plants are commonly required by other State or Federal agencies to perform 

5 special monitoring of aquatic and terrestrial species for some period of time after a new plant 

6 commences operation. Ecological impacts related to radioactive effluent releases from the 

7 proposed facility will be evaluated in the DEIS. 

8 Comment: We need to figure out whether we’re going to preserve that estuary or whether 

9 we’re going to let it go to hell. Right now I understand that at the intake for the cooling [pond] 

10 we’re getting brackish water. The original design was that they were not to remove enough 

11 water such that there was back-flow to cause saltwater in at the inlet station. It appears it’s 

12 happening regardless of whether they pump or don’t pump. This says there’s been a change in 

13 the basic environmental impact statement. That needs to be analyzed for. (0008-78 [Acevedo, 

14 NK])

15 Response: The DEIS will describe the function of the intake structure on the Colorado River 

16 and will discuss the potential impacts to aquatic resources from the operation of that structure. 

17 The DEIS will also describe changes, unrelated to operation of STP Units 1 and 2, that have 

18 occurred in the lower Colorado River since publication of NRC’s final environmental statement 

19 for the two existing units. 

20 D.2.11 Socioeconomics 

21 Comment: Units 1 and 2 provide safe, reliable power to millions of Texans. As Mark said, that 

22 drives that economy of Texas. And it brings millions of dollars of benefits to Matagorda County 

23 and the surrounding area. (0007-144 [Shepherd, Joe])

24 Comment: We believe that the benefits to Matagorda County will be significant, not only just 

25 the jobs that will be created, we’ve talked about the 800 permanent jobs, the 4,000 construction 

26 jobs, but we believe it’ll have a significant positive affect on the quality of life in Matagorda 

27 County. (0007-148 [Shepherd, Joe])

28 Comment: The STP 3 and 4 expansion, as has been mentioned earlier, would bring about 800 

29 new jobs to the county. It’s been stated that we need jobs, and we do because our high school 

30 students need opportunities that are not here now, our college-age students are going away 

31 from the county after they graduate because there’s nothing here to bring them back, what 

32 limited job we have. Also, we have a number of under-skilled, or under-employed people here 

33 who are looking for new opportunities to increase the career potential that they have, and that 

34 they could stay in the county as well. (0007-71 [Bludau, Owen])

35 Comment: The percentage of new employees living here is important to us. Right now we 

36 have about 60 percent of the 1200 employees that STP has living in the county, and we would 

37 like to have an equal percentage or higher of the new hires coming with 3 and 4 that would be 
Appendix D 

March 2010 D-31 Draft NUREG-1937 

1 here. They would be able to purchase homes and cars here, groceries, retail activities, they 

2 would use the services of our banks, our medical facilities, insurance, utility service providers. 

3 And if we could get 600 of those 800 living here, that would generate another 1,000 secondary 

4 support jobs. Those new employees’ salaries will circulate in the community and that will 

5 expand it economically. (0007-72 [Bludau, Owen])

6 Comment: [W]e’re beginning to see the impacts already of the anticipation of Units 3 and 4. 

7 We saw new retailers open up in Bay City in 2007. We had new retailers who have purchased 

8 properties in Palacios and in Bay City, and there’s new construction in Palacios and Bay City in 

9 anticipation of this larger customer base that is going to be here. So these businesses are 

10 coming, and they’re expanding our tax base and our employee base. (0007-74 [Bludau, Owen])

11 Comment: STP is looking at about 5,000 construction -- temporary construction workers here 

12 over a six year period. ... At maximum construction period they’re looking at about 4,000 

13 workers for two years, but then they would ramp down. ... [T]hose living here are going to spend 

14 most of their money here. Those commuting in are going to spend some of their money here 

15 buying gas and refreshments as they go in and out of the county. That’s going to create a strong 

16 financial benefit to our local businesses and attract some new businesses. (0007-84 [Bludau, 

17 Owen])

18 Comment: We are strong supporters of STP. What community would not welcome a $6.4 

19 billion investment in their community? I mean, this is great. We’re talking about 8,000 

20 construction jobs during peak, 800 -- I mean 4,000 jobs, 800 permanent jobs. (0007-9 [Knapik, 

21 Richard])

22 Comment: I’m indeed pleased to be here tonight and have a chance to talk about bringing new 

23 reactors to the South Texas Project site and increasing the capacity of the South Texas Project. 

24 It’s clearly a strong boost for Matagorda County. It’s important for Texans and Texas, for energy 

25 independence, and having adequate supplies of electricity, which drives our overall economic 

26 engine that keeps our society going. (0008-113 [McBurnett, Mark])

27 Comment: Units 1 and 2 provide clean, reliable power to millions of Texans. ... We also 

28 provide millions of dollars of benefits to Matagorda County. (0008-125 [Shepherd, Joe])

29 Comment: We think that the benefits associated with Units 3 and 4 will be significant for 

30 Matagorda County and the surrounding communities. It’s not only the jobs -- the 800 permanent 

31 jobs and 4,000 construction jobs -- bit the quality of life that we believe the economic impact of 

32 Units 3 and 4 will bring to this area. (0008-129 [Shepherd, Joe])

33 Comment: Palacios is going through an economic change. The shrimping industry is on the 

34 way down and it will never return. The Harris and Galveston County Council of Governments, 

35 which is 13 counties, including Matagorda County, recently started last year making plans for an 

36 additional 2.5 million people coming to our area by year 2015. (0008-18 [Morton, Joe])

37 Comment: As far as the economic impact to Matagorda County ... we’ve got businesses here 

38 that have ... been here since the early 1900’s. ... Yes, we have new industry coming in. ...But we 
Appendix D 

Draft NUREG-1937 D-32 March 2010 

1 have these old businesses too. ...down in Palacios ...Blessing and Matagorda and Clemville 

2 and Bowling ...all these communities around close that are going to have impact by Units 3 and 

3 4. Also, it’s going to secure future for our children and our children’s children. (0008-38 [Head, 

4 Bobby])

5 Comment: The economic impact on the state of Texas will create -- or one nuclear plant would 

6 create $9.2 billion statewide from one reactor and 5,564 jobs. (0008-4 [O’Day, Mike])

7 Comment: The focus of the Matagorda County EDC and my job is to bring new economic 

8 development to Matagorda County. And this ... is a chance of a lifetime that most economic 

9 developers would dream of. The value of that STP is talking about investing equals the 

10 combined -- it exceeds the combined value of the eight largest industrial projects in Texas in the 

11 last four years. It exceeds those. So that is big. That is economic development right big. (0008-

12 92 [Bludau, Owen])

13 Comment: We’re after STP 3 and 4 for a number of reasons ... We want to attract their 

14 employees to live here. If you can get 3 and 4 -- a major percentage of the employees of 3 and 

15 4 to live here they’re going to buy homes and cars. They’re going to buy their groceries, their 

16 retail products. They’re going to use the services of our banks, our medical facilities, their 

17 insurers, utility companies, and our various service providers. That’s going to help all the 

18 existing businesses in the community. It’s going to attract more businesses to the community. If 

19 we could get 600 of 800 to live here that would generate an additional 1,000 service sector jobs. 

20 And that is good economic development. (0008-96 [Bludau, Owen])

21 Comment: The temporary construction workers that are going to be here will be over a six-year 

22 period. ... And while they’re living here they’re going to be spending their money here. While 

23 they are commuting in and out they’re going to be buying gasoline and refreshments and 

24 spending some of their money here. So that’s going to create additional strong business for our 

25 local employers, our local businesses, and it’s going to add and attract other businesses. (0008-

26 97 [Bludau, Owen])

27 Comment: We saw some of this retail happening already, as was mentioned earlier. We had 

28 new retailers coming in in 2007. We had more of them buy -- more retailers buy property in 

29 Palacios and Bay City for new facilities. There are new retail facilities under construction 

30 because they are anticipating an increased customer base. So this is adding to our employment 

31 opportunities and it’s adding to the existing tax base, which we all need. (0008-98 [Bludau, Owen])

32 Comment: The plant location provides jobs on a regional basis without causing development 

33 problems, such as increased traffic, whlch would occur in a densely industrialized area. (0013-2

34 [Hearn, Polly])

35 Response: These comments cite some of the projected favorable socioeconomic impacts on 

36 the community of plant construction and operation. These comments are covered within the 

37 existing scope of the DEIS and will be discussed in sections < 4.4 and 5.4 of the EIS.> 
Appendix D 

March 2010 D-33 Draft NUREG-1937 

1 Comment: I think the first question that you all, in this community, may want to ask is, is this 

2 going to be a benefit to you, or will your taxes have to go up to pay for the infrastructure to 

3 support the growth of the plant, the additional hospitals and security systems, roads, schools 

4 and other issues. (0007-16 [Smith, Tom])

5 Comment: Tax abatements for NRG will mean the community will bear costs in higher taxes. 

6 The community will have to come up with funds to build more public infrastructure. The new 

7 plant will require:1. New roads, new schools, a new hospital, and a paid fire department.2. How 

8 high will local cities have to raise taxes in order to build this infrastructure? (0010-1 [Public Citizen, 

9 Texas Office] [Smith, Tom])

10 Response: These comments briefly identify potential adverse socioeconomic impacts on the 

11 community of plant construction and operation, including required investments in community 

12 infrastructure. These topics will be discussed in Chapters 4 and 5 of the DEIS. 

13 Comment: I think that Matagorda County and Bay City are so much better prepared for two 

14 more units than we were for the first two units. I happen to have been on the city council at that 

15 time, and let me tell you, I believe at that time there were 13,000-plus construction workers 

16 here, which at that time it was the largest construction project in the United States at that time, 

17 or up to that time, or going on then. (0007-129 [Rice Herreth, Georgia])

18 Comment: Already ... advanced education has come to the city due to our partnership with the 

19 local community colleges and with Texas A&M. There’s now a satellite campus at Wharton 

20 Junior College in Bay City, we’re teaching courses and there are students there today, and that 

21 did not exist a year ago. And that’s all because of Units 3 and 4. (0007-149 [Shepherd, Joe])

22 Comment: Ms. Dancer talked about the security of the workforce. I’m sorry if, as we went 

23 through our deliberations on how we should best manager our costs, that that caused anxiety 

24 within any of employees. But the truth is, we outsourced not one job. Not one. And we have 

25 changed our outlook. We’ve gone from an outlook of constriction to one of expansion, and that’s 

26 the bright future for STP Nuclear Operating Company, and that’s the bright future for Matagorda 

27 County. We prefer local talent, and the onsite campus in Bay City is part of our commitment to 

28 try and attract and retain that local talent. And we have many other activities that’ll go forth in 

29 the future to bring that workforce to Matagorda County. (0007-150 [Acevedo, NK])

30 Comment: With the announcement of expansion to Units 3 and 4, we have the opportunity to 

31 bring industry, education, and government together to solve a huge problem, but it was a good 

32 problem. ... In just a matter of months we came up with a degree program, associate degree 

33 program called Power Technology, which we have students enrolled in already today, and the 

34 Mid-Coast Education and Industry Alliance still meets quarterly. We are continuing to address 

35 the issues to see how we can improve our education systems and make this a great place to 

36 raise our young adults and have our young adults come back and raise their families for many, 

37 many years to come, creating another huge strength for our community. (0007-79 [Dunham, D.C.])
Appendix D 

Draft NUREG-1937 D-34 March 2010 

1 Comment: The city of Bay City is ready to meet the challenges of the growth and expansion of 

2 Units 3 and 4. The city three years ago passed a $6 million bond issue to repave all the streets 

3 in the city of Bay City. We’re also actively engaged right now in creating a diversion road around 

4 our community to help alleviate traffic that we anticipate coming. (0008-14 [Knapik, Richard])

5 Comment: With this announcement we had the opportunity to bring together industry and 

6 educators and solve a really huge problem. But it was a good problem, especially for this 

7 community that has had traditionally double-digit unemployment. Our problem was how are we 

8 going to meet the demands of our local industries’ needs for all of the jobs that are going to be 

9 created. ...Within just a matter of months we developed the idea of coming up with power 

10 technology, which is an associate degree program that’s being taught to our students today.

11 (0008-47 [Dunham, D.C.])

12 Comment: STP has made Matagorda County a much strong economic entity by its presence. 

13 It is our largest private sector employer. Units 3 and 4 would add another 800 jobs. And those 

14 jobs, as has been mentioned before, are going to be opportunities for our high school 

15 graduates, our graduates at colleges to come back to school -- come back from school and 

16 work here and for people who are underemployed to improve their education and have better 

17 career opportunities. (0008-94 [Bludau, Owen])

18 Response: These comments discuss community responses designed to take advantage of 

19 expanding economic opportunities expected as a result of plant construction and operation. 

20 Such activities are part of the context for economic impact analysis and will be discussed in the 

21 DEIS. 

22 Comment: So where initially you had a workforce that by default had to be based in the local 

23 economy, that paradigm has changed. So as the economy became more global, in part due to 

24 advances in the internet and electronics communication age, STP began to court workforces 

25 elsewhere, workforces without roots in Matagorda County. And suddenly, all of those jobs, all of 

26 those careers that we had been promised, and that had largely come to fruition, suddenly lost 

27 their stability. (0007-102 [Dancer, Susan])

28 Comment: If there is any doubt that STP’s ownership didn’t have loyalty to their workforce, or 

29 their location, pre-announcements of Units 3 and 4, Frank Mallen ended that with a comment 

30 spoken to a group -- a senior manager, with a comment spoken to a group of recently 

31 outsourced employees when he said, It’s all about the money. That’s the most poignant and 

32 honest thing that STP management has presented to this community so far. (0007-103 [Dancer, 

33 Susan])

34 Comment: Fortunately for us, we have hindsight and we can see what building two new 

35 nuclear reactors could bring us. We can see now because we’re 30 years later from the same 

36 thing happening before. Our unemployment rate is still well above the state average, our school 

37 districts are still extremely poor, and the owners and operators of the plants still don’t live here 

38 or show loyalty to our community. (0007-106 [Dancer, Susan])
Appendix D 

March 2010 D-35 Draft NUREG-1937 

1 Comment: When they started bringing executives in to prepare for 3 and 4, guess where they 

2 relocated those executives to? Lake Jackson. All the -- and these are the same people who tell 

3 you they have great love and loyalty for Matagorda County and that we have the infrastructure 

4 to support the plant growth and to support all the new employees here. (0007-120 [Dancer, 

5 Susan])

6 Comment: As far as the concerns I have is the number of STP employees who choose to live 

7 outside of Matagorda County. I understand. They’ve got beautiful country clubs and stuff like 

8 that every place else. But I would like to work with both STP, our local officials, and Matagorda 

9 County to make Matagorda County the preferred residence of not only the construction families 

10 it will bring, but also the management and employees of STP. (0008-39 [Head, Bobby])

11 Comment: While the company postulates that it will need between 5000-6000 construction 

12 workers, how many of them can be found locally or in the region with other major power plants 

13 being proposed or under construction? There hasn’t been a new reactor ordered in the US for 

14 decades. The knowledge and skill to build the reactor design is in Japan. 1. Who will NRG hire 

15 to build and operate the new plant? 2. Will they have to rely on international labor? (0010-2

16 [Public Citizen, Texas Office] [Smith, Tom])

17 Response: These comments involve choices by the applicant and their contractors on where 

18 the construction and operating workforces will come from, and choices by the workforce 

19 concerning where they will live while working at the proposed plant. These factors affect the 

20 size of the local resident workforce and the potential socioeconomic impacts and will be 

21 discussed in the DEIS. 

22 Comment: [E]mergency planning ... has an aspect to economic development that often is not 

23 perceived. A lot of the business that I’m talking to -- the industries -- have a concern about the 

24 Texan fire services -- emergency services. And when we mention the types of planning that are 

25 undertaken in Matagorda County because of the presence of STP that gives them a good 

26 comfort level that their needs will be met also and they can participate as a member in this 

27 emergency planning and response within the county. (0008-100 [Bludau, Owen])

28 Comment: STP is a major financial supporter to a lot of the activities in the community as has 

29 been mentioned -- the community events, the organization of the civic activities. Many of these 

30 events, activities, and so forth could not exist without the financial support of STP. (0008-99

31 [Bludau, Owen])

32 Response: These comments discuss past actions of the existing plant management and 

33 employees for activities that support the community. They provide some context for 

34 expectations regarding future behavior. Although this type of response is not an inevitable 

35 socioeconomic consequence of construction and operation, past performance will be used as 

36 part of the context in the DEIS discussion. 
Appendix D 

Draft NUREG-1937 D-36 March 2010 

1 Comment: If we can do energy efficiency less expensively than building this plant, and put 

2 Texans to work as opposed to people in Japan or in Russia or in Africa that will be mining this 

3 uranium. Wouldn’t it be better to have the jobs and money stay here in the United States? (0007-

4 29 [Smith, Tom])

5 Response: This comment expresses the belief that investments in energy efficiency would be 

6 less expensive and would provide more domestic jobs than an investment in nuclear power. It 

7 does not ask for an analysis within the EIS of the job and cost consequences of the nuclear fuel 

8 cycle compared with energy efficiency. Job and cost impacts will be identified and quantified to 

9 the extent possible in the EIS. 

10 Comment: I do think that Bay City is being presented with a false choice, either two new 

11 nuclear reactors, or you’re not going to have any jobs, when, in fact, there are alternatives to 

12 that, to those two options. (0007-96 [Cushing, Lara])

13 Response: This comment states that there are alternatives to constructing and operating the 

14 proposed plant. Chapter 9 of the EIS will discuss the socioeconomic impacts of alternative 

15 technologies and sites. 

16 D.2.12 Environmental Justice 

17 Comment: Environmental justice, what will the net impact be on your taxes and the 

18 community, the low-income communities of color? (0007-25 [Smith, Tom])

19 Response: This comment asks what the impact on local taxes and on communities of color will 

20 be from constructing and operating the proposed plant. Both types of impacts will be 

21 considered and discussed as part of the socioeconomic and environmental justice impacts, 

22 respectively. 

23 D.2.13 Health - Radiological 

24 Comment: There is a need for measurements on the amount of radioactivity in the water 

25 currently flowing from the plant into Matagorda Bay to determine whether there is any leakage 

26 or release of any kind. If there is documentation of such leakage, that potential from two 

27 additional reactors should also be evaluated. (0002-18 [Sinkin, Lanny])

28 Response: STP has an ongoing Environmental Monitoring Program which does monitor for 

29 radionuclides in surface water, groundwater and drinking water on an annual basis. Tritium is 

30 the only anthropogenic radionuclide that has been measured in onsite water samples for the 

31 past several years. No radionuclides have been detected in offsite water samples. During 2006 

32 there were two occurrences of the Total Dissolved Solids discharge line leaking some liquid. 

33 The water from the leaks was recovered. No radioactive material was released from the site. 

34 However, the potential for releases will be discussed in EIS Chapter 5. 
Appendix D 

March 2010 D-37 Draft NUREG-1937 

1 Comment: Prior to STNP Units 1 and 2 going into operation, the public health data for the 

2 three counties closest to the site showed a cancer death rate 4.5% lower than the statewide 

3 rate. In the 16 years since the nuclear plants began operating, the cancer death rate in the three 

4 counties rose to more than 7% higher than the statewide rate. The statewide rate both went up, 

5 with the three county rate rising four times faster. There is no obvious reason, other than the 

6 presence of operating nuclear power plants, explaining the data from the three counties. Based 

7 on this data, an increased cancer death rate would be expected to result from the addition of 

8 two more operational reactors at the same site. The cumulative impacts analysis for the STNP II 

9 reactors should address this question. Source: Joseph J. Mangano, MPH, MBA Radiation and 

10 Public Health Project, January 24, 2008. There is also a recent study indicating that operating 

11 nuclear power plants adversely affect infant mortality (0002-20 [Sinkin, Lanny])

12 Comment: There have been numerous cancer studies and infant mortality studies involving 

13 nuclear plants that should be examined as part of the EIS. While some of these studies have 

14 been contradictory, a true ER and EIS process must assess the latest studies to estimate the 

15 actual damages in cancer incidence and death due to the opening of more nuclear power 

16 plants. (0003-46 [Reed, Cyrus])

17 Comment: What will the impact of cancer be on this community? And if you look at data you 

18 see that the cancer rates have gone from below average to above average since this plant’s 

19 been in operation. (0007-17 [Smith, Tom])

20 Comment: I do want to go on record and say that I am concerned about increased cancer 

21 rates (0007-99 [Dancer, Susan])

22 Comment: ... a large-scale, carefully conducted study concluded: “Our study confirmed that in 

23 Germany a connection has been observed between the distance of a domicile to the nearest 

24 nuclear power plant... and the risk of developing cancer, such as leukemia, before the fifth 

25 birthday.” The study was conducted by the German Register of Child Cancer, an office which is 

26 funded by the 16 German states and the Federal Health Ministry. Among several alarming and 

27 unexplained findings was that 37 children living within 3 miles of nuclear power plants had come 

28 down with leukemia between 1980 and 2003, whereas the statistical average for Germany 

29 would have predicted just 17 cases In that group. Of course, additional research, which takes 

30 time, must be done to determine whether proximity to nuclear plants was a factor in causing the 

31 high number of cases. At this time, scientists can only conclude that this is just “another piece in 

32 a growing puzzle’” of childhood leukemia’s association with nuclear installations and they 

33 emphasize the need to keep investigating. We all know that there are risks to almost everything 

34 we do in life and that there is no escaping some hazards. However, in the case of granting 

35 nuclear power plant expansion, the risk is too high. (0017-4 [Scheurich, Venice])

36 Response: As will be discussed in the EIS, the staff accepts the linear, no-threshold dose37 response model. In a recent report entitled “Health Risks from Exposure to Low Levels of 

38 Ionizing Radiation: BEIR VII - Phase 2 (National Research Council 2006), the BEIR VII 

39 Committee concluded that the current scientific evidence is consistent with the hypothesis that 

40 there is a linear, no-threshold dose-response relationship between exposure to ionizing 
Appendix D 

Draft NUREG-1937 D-38 March 2010 

1 radiation and the development of cancer in humans. Having accepted this model, the staff does 

2 think that this model is conservative when applied to workers and members of the public who 

3 are exposed to radiation from nuclear power plants. This is based on the fact that numerous 

4 epidemiological studies have not shown conclusive evidence of increased incidences of cancer 

5 at the low dose rates typical of nuclear power plant operations. Further, routine releases from 

6 operating nuclear power plants are far below the level at which regional excess cancer 

7 incidences would be expected. These studies include: (1) the National Cancer Institute study 

8 (1990) of cancer mortality rates around nuclear facilities, including 52 nuclear power plants, (2) 

9 the University of Pittsburgh study (Talbott et al. 2003) that found no link between radiation 

10 released during the 1979 accident at the Three-Mile Island nuclear power station and cancer 

11 deaths among residents, and (3) the Connecticut Academy of Sciences and Engineering study 

12 (2001) that found no meaningful associations from exposures to radionuclides around the 

13 Connecticut Yankee nuclear power plant that ceased electricity production in 1996 to the 

14 cancers studied. Radiological Health Impacts to the public will be addressed in Chapter 5 of the 

15 EIS. 

16 Comment: I read a story on the front page of the New York Times two days ago, and ...he 

17 discovered that his drinking water was contaminated with radioactive tritium. That’s ionizing 

18 radiation, not the kind of radiation you get from the sun. And he was naturally upset about that, 

19 and went to Exelon, the largest nuclear reactor manufacturer in the country, and he asked them 

20 about it, and to make a long story short, they confessed that they knew about this. Exelon 

21 believed that the tritium found in the drinking water well near the plant in Braidwood, Illinois 

22 came from millions of gallons of water that had leaked from the plant years earlier, but went 

23 unreported at the time. That could be happening right here. That concerns me. That bothers 

24 me. (0007-97 [Payne, Cameron])

25 Response: STP has an ongoing Environmental Monitoring Program which does monitor for 

26 radionuclides in surface water, ground water and drinking water on an annual basis. Tritium is 

27 the only anthropogenic radionuclide that has been measured in onsite water sample for the past 

28 several years. No radionuclides have been detected in offsite water samples. Drinking water in 

29 the area is obtained from deep aquifer wells, which is also monitored quarterly and no tritium 

30 has been detected in this water. 

31 Comment: There was a comment earlier regarding cancer and radiation in the populations 

32 living near nuclear facilities. It’s interesting because that question’s been around a long time. In 

33 the 16 years I’ve been [the site doctor] at STP, the evolution of the answer has been ongoing. 

34 And I think it’s time, finally, to put that question to bed, because it’s been studied massively, and 

35 internationally. National Academy of Sciences, National Cancer Institute, long-term big-time 

36 studies, quality research that have concluded, unequivocally, that living in the shadow of a 

37 nuclear plant will not give you cancer. So we need to put this to bed. These are American 

38 studies, British studies, Canadian studies, and, again, it’s good reading. So take it home. 

39 There’s some real issues to deal with here. This is a non-issue. (0007-115 [Hefner, James])

40 Comment: As far as locally, less than a year ago, right here in Matagorda County, two Rice 

41 [University] professors wanted to address his particular question, germane specifically to the 
Appendix D 

March 2010 D-39 Draft NUREG-1937 

1 county. Can the folks here in Matagorda County -- is there more cancer death rate right here 

2 than other counties in Texas? The answer is no. Two Rice professors, eminently qualified, 

3 studied this question and concluded that out of 230 counties studied, Matagorda County ranked 

4 108 out of 230 counties as far as cancer death rates. And for sure 206 of those counties don’t 

5 have a nuclear facility. (0007-116 [Hefner, James])

6 Comment: [W]e’re upstream of the water -- of your water, and we’re downwind of any kind of 

7 problems. And Wharton County does have a lot of cancer. Now is it because of you all? 

8 Probably not. But it has a lot of cancer. (0007-127 [Conrad, A.C.])

9 Comment: Advanced boiling water reactors in Japan have an impressive record on low 

10 radiation worker exposures. It’s lower than what we typically see in this country in any of our 

11 plants. They have an impressive record, and we look forward to being able to do this. There’s 

12 design features in those plants that enable that to happen. (0008-117 [McBurnett, Mark])

13 Comment: Later there is a comment that 1.9 fatal cancers would occur from the annual fuel 

14 cycle. Please add information about the day-to-day operations as well. (0008-65 [Hadden, Karen])

15 Comment: Also going on is what’s known as LCRA-SAWS, or the San Antonio Water System. 

16 Now, that’s not close. It’s up near Interstate -- or U.S. Highway 59 between Wharton and El 

17 Campo. But they’re going to build a large reservoir that’s going to feed the city of San Antonio 

18 from the Colorado River. This is a large open body of potable water that is in a possible patch 

19 for any radioactive release from the site. It needs to be analyzed as part of the environmental 

20 report. (0008-80 [Wagner, William])

21 Comment: The National Academy of Sciences, National Cancer Institute put together multiple 

22 studies. The NEI has put this fact sheet together ... A whole bunch of long-term studies that 

23 have concluded unequivocally now that living near a nuclear facility will not increase your 

24 incidence for cancer. It just won’t happen. (0008-90 [Hefner, James])

25 Comment: Two Rice [University] professors were asked to analyze the cancer death rate in 

26 Matagorda County. Statisticians, Ph.D., full professors -- one of them an adjunct professor at 

27 M.D. Anderson Hospital -- these folks know numbers, they know cancer -- one a Ph.D. 

28 environmental engineer. They concluded the same as the national and international studies. 

29 Living in the shadow of a nuclear facility will not increase the cancer death rate. (0008-91 [Hefner, 

30 James])

31 Response: Health impacts associated with plant operation will be discussed in Chapter 5 of 

32 the EIS. 

33 Comment: [The Environmental Report] discussed the maximally exposed individual. Please, if 

34 you would, expand this section to include impact on all age groups. It should be women and 

35 children, young children, pregnant women, not just adult males. In some sections there was 

36 analysis of children, and that’s good. But the impact should be done for all categories for all 

37 types of impacts. (0008-58 [Hadden, Karen])
Appendix D 

Draft NUREG-1937 D-40 March 2010 

1 Response: The software packages that the NRC authorizes for use in calculating the 

2 maximally exposed individual (MEI) do calculate doses to various age groups, including 

3 teenagers and children. The concept of the maximally exposed individual is set to maximize the 

4 dose consequences from all pathways and all age groups. 

5 Comment: There was data that said water downstream is not used for drinking water or 

6 irrigation. Please analyze the impacts, however, because there is wildlife in the area and 

7 breeding grounds in the wetlands. We need to have added explanations of what the data 

8 means. There is some data provided in here, but no context given to what it means. (0008-59

9 [Hadden, Karen])

10 Response: In addition to STP’s ongoing environmental monitoring program that monitors for 

11 radionuclides in surface water, groundwater, and drinking water, the DEIS will examine 

12 downstream water uses and impacts from construction and operation of the proposed plant. 

13 Comment: Gaseous pathways are analyzed in terms of 50 miles, in terms of exposure to 

14 ground and air, and inhalation. Then there’s a reference to radiation shielding, but no 

15 explanation. I would like the document to include exactly what is meant by radiation shielding -- 

16 how does it work, why does it work, what does it mean. (0008-60 [Hadden, Karen])

17 Response: Shielding is any material or obstruction that absorbs radiation and is designed to 

18 protect personnel or materials from the effects of ionizing radiation. 

19 Comment: There’s a conservation estimate of 2.5 milli[rems] per year at the site boundary. 

20 They come up with a total body exposure to the maximally exposed individual per year of .35 

21 milli[rems] per unit. So if you double that you’re talking about .70 milli[rems] per year. But we 

22 need to bear in mind this would now be four units and cumulative impacts need to be addressed 

23 throughout. (0008-61 [Hadden, Karen])

24 Response: Cumulative impacts will be discussed in Chapter 7 of the EIS. The National 

25 Council for Radiation Protection Report 93 (NCRP 1987) estimates that the average American 

26 citizen receives a natural background, (i.e., terrestrial and cosmic radiation in origin) radiological 

27 dose of 280 millirem per year, so 0.7 millirem is about 0.25 percent of that background dose 

28 rate. 

29 Comment: Several times the study just simply concludes that these exposure limits would be 

30 small -- in capital letters small. Please give us some context. What is the criteria for small? What 

31 do you mean? And why are they small? (0008-62 [Hadden, Karen])

32 Response: The National Council for Radiation Protection in its 1987 Report number 93 

33 estimated that the average American citizen receives a natural background, (i.e., terrestrial and 

34 cosmic radiation in origin) radiological dose rate of 280 millirem per year. The radiological 

35 doses reported in the Environmental Report are considerably less than natural background for 

36 the average American citizen and are therefore considered ‘small’ as defined in 10 CFR Part 51, 

37 Appendix B. According to the noted regulation, radiological impacts are considered small if they 

38 “do not exceed permissible levels in the Commission’s regulations.” 
Appendix D 

March 2010 D-41 Draft NUREG-1937 

1 Comment: The occupational radiation doses are listed as 197.8 person-rem for the two units 

2 per year. This is over 200 times, by my calculations, of what the average exposure would be. 

3 And if you double that, workers at the plant may be getting very high levels of radiation. 

4 Cumulative impacts must be analyzed. (0008-64 [Hadden, Karen])

5 Response: The occupational population doses noted in the comment refer to the large work 

6 force (~5950 workers) that will be building the two new reactors. The average dose rate to that 

7 work force is about 33 mrem per person. Cumulative impacts will be addressed in Chapter 7 of 

8 the EIS. 

9 Comment: More radiation means bigger risk of cancer. The EIS should include an analysis of 

10 the impact on humans and other living systems of an increase in radiation levels as a result of 4 

11 operating reactors at STP. ... Will the two new reactors increase the amount of low-level 

12 radiation exposure to surrounding populations? (0010-3 [Public Citizen, Texas Office] [Smith, Tom])

13 Response: Radiological impacts from the normal operation of the two new reactors will be 

14 discussed in Chapter 5 and cumulative impacts will be discussed in Chapter 7 of the EIS. 

15 Comment: There is a need for a baseline of current animal, bird, fish, reptile, and other non16 Human creature level of radioactive uptake, so that a later comparison can determine health 

17 effects of reactor operation. (0002-21 [Sinkin, Lanny])

18 Comment: [The Environmental Report] refers to the fact that gamma and beta emitters are 

19 typically part of the normally released radionucleids of power plants. Again, the impacts to biota 

20 are considered small. Please explain. (0008-63 [Hadden, Karen])

21 Comment: What is the effect of low-level radiation over prolonged periods on wildlife in the 

22 area? (0010-18 [Public Citizen, Texas Office] [Smith, Tom])

23 Response: The affected radiological environment will be addressed in Chapter 2 of the DEIS. 

24 Radiological impacts to biota from operation of the reactors will be discussed in Chapter 5. 

25 D.2.14 Accidents - Design Basis 

26 Comment: The last analysis of a credible accident was the CRAC II study done while STNP 

27 was still under construction. The STNP estimates were: 1. 15,200 early deaths (25 mile radius 

28 around plant) 2. 8,770 early injuries (35 mile radius) 3. $112 billion (1980 dollars) With nearly 25 

29 years of sustained population growth in the region, it is certain that these impacts need to be 

30 updated. The review in the application is inadequate to inform citizens of the threat. (0010-16

31 [Public Citizen, Texas Office] [Smith, Tom])

32 Response: The environmental review of the STPNOC application will include analyses of both 

33 design-basis and severe accidents. The results of these analyses will be included in DEIS 

34 Chapter 5 that discusses the environmental impacts of reactor operation. 
Appendix D 

Draft NUREG-1937 D-42 March 2010 

1 D.2.15 Accidents - Severe 

2 Comment: LCRA is involved in negotiations with San Antonio to establish long term contracts 

3 for interbasin transfers of water. The storage of that water will be in a large open reservoir. The 

4 EIS should examine the potential impact on the proposed reservoir of an accident at STNP.

5 (0002-17 [Sinkin, Lanny])

6 Comment: The ER analyzes likely dosages to the population and resulting from moderate or 

7 severe accidents. It predictable finds that all resulting dosages meet NRC requirements and 

8 guidelines. What is lacking, however, is any analysis of the potential health effect impacts of 

9 STP 3 and 4 in combination with STP 1 and 2. (0003-45 [Reed, Cyrus])

10 Comment: While I understand that the proposed ABWR is safer than the Chernobyl reactor, it 

11 is possible that there could be a meltdown at STP leading to a massive explosion causing a 

12 similar nuclear catastrophe. I would like the EIS to show what would happen to the people living 

13 in Houston, as well as those who live even closer. How many would die of severe radiation 

14 poisoning? A million? How many thousands of square miles of agricultural land would have to 

15 be abandoned for years to come? Also what about those living in San Antonio, the tenth largest 

16 city in the U.S. What about Austin,TX? As a U.S. citizen, I think an EIS should make these 

17 calculations and let the public know. (0005-4 [Payne, Cameron])

18 Comment: The things I want to see more concern with in the environmental review, in the -- 

19 and since this is a scoping hearing, let me say this, you have to consider the worst case 

20 scenario. What if something like Three Mile Island happens? What will the effects on this area of 

21 Texas be? And that’s not even the worst accident that’s been known to happen. What if 

22 something like Chernobyl happens? I want to see the environmental review include the worst 

23 case scenario, the absolute worst that could happen. You’ll not find one word about that in the 

24 current environmental report. (0007-121 [Singleton, Robert])

25 Response: The DEIS for the proposed new reactors will include an evaluation of the risks 

26 associated with potential severe accidents including accidents that involve reactor core melts. 

27 The evaluation will include estimates of health and economic risks to a distance of 50 mi from 

28 exposure to the plume and from exposure to contaminated land and water. These risks will be 

29 compared with risks associated with the existing plants. This evaluation will be in the DEIS 

30 <Chapter 5> on operational impacts. In addition, the evaluation will include an estimate of the 

31 cumulative risk of severe accidents for all units at the STP site. <This evaluation will be in 

32 Chapter 7 of the DEIS.> Consistent with the general NEPA philosophy that environmental 

33 review under NEPA contain realistic estimates of impacts, the Commission in its Safety Goals 

34 policy statement (51 FR 30028, 1986) has adopted the use of mean estimates rather than worst 

35 case estimates of accident risks. 

36 Comment: I would point out in a boiling water -- a boiling water reactor is a very robust design. 

37 Loss of that piece of equipment [the cooling tower] does not result in a catastrophic event for a 

38 boiling water reactor. (0008-123 [McBurnett, Mark])
Appendix D 

March 2010 D-43 Draft NUREG-1937 

1 Comment: Nuclear power plants are not safe. Regardless of the safety efforts and record of 

2 specific nuclear powers plants, the fact remains that there need be only one accident to have a 

3 catastrophic result. Nuclear waste poses a real threat since it is generated throughout all parts 

4 of the fuel cycle in these power plants. (0015-7 [Williams, Mina])

5 Response: These comments do not provide new information related to the environmental 

6 review. They will not be addressed in the environmental impact statement. 

7 

8 Comment: LCRA is involved in negotiations with San Antonio to establish long term contracts 

9 for interbasin transfers of water. The storage of that water will be in a large open reservoir. The 

10 EIS should examine the potential impact on the proposed reservoir of an accident at STNP.

11 (0002-17 [Sinkin, Lanny])

12 Response: The environmental impact statement for the proposed new reactors will include an 

13 evaluation of the risks associated with potential severe accidents including accidents that 

14 involve reactor core melts. The evaluation will include estimates of health and economic risks to 

15 a distance of 50 mi from exposure to the plume and from exposure to contaminated land and 

16 water. These risks will be compared with risks associated with the existing units. This 

17 evaluation will be in the DEIS <Chapter 5> on operational impacts. In addition, the evaluation 

18 will include an estimate of the cumulative risk of severe accidents for all units at the STP site. 

19 <This evaluation will be in Chapter 7 of the DEIS.> Consistent with the general NEPA 

20 philosophy that environmental review under NEPA contain realistic estimates of impacts, the 

21 Commission in its Safety Goals policy statement (51 FR 30028, 1986) has adopted the use of 

22 mean estimates rather than worst case estimates of accident risks. 

23 Comment: The National Environmental Policy Act (NEPA) require that plausible statements as 

24 to the prospective environmental impacts be disclosed in advance. Any Environmental Impact 

25 Statement that did not raise the twin specters of nuclear core meltdown and a meltdown in a 

26 spent nuclear fuel pool is inadequate, and should be challenged in court. (0005-3 [Payne, 

27 Cameron])

28 Comment: Possibly even worse than a reactor core meltdown would be a meltdown in one of 

29 the spent nuclear fuel pools. Please give us the effects of that. (0005-5 [Payne, Cameron])

30 Response: The environmental impact statement for the proposed new reactors will include an 

31 evaluation of the risks associated with potential severe accidents including accidents that 

32 involve reactor core melts. The probability of simultaneous reactor accident involving a core 

33 melt and a spent fuel pool accident involving a fire is too low to be plausible. Therefore, the 

34 environmental impact statement will not address the consequences of simultaneous severe 

35 reactor accidents and fuel fires in the spent fuel pool. 
Appendix D 

Draft NUREG-1937 D-44 March 2010 

1 D.2.16 Uranium Fuel Cycle 

2 Comment: The EIS should examine the likelihood that a solution to the high level waste 

3 disposal issue will be forthcoming any time in the near future and the consequences for STNP, 

4 such as indefinite on-site storage, if such a solution is not forthcoming. (0002-22 [Sinkin, Lanny])

5 Comment: The ER is short on details on how the proposed plant will deal with thousands of 

6 curies and tons of low-level and high-level waste to be generated by the plant. Radioactive 

7 waste management in the U.S. has been and continues to be nightmarish and difficult. (0003-35

8 [Reed, Cyrus])

9 Comment: There are now only three facilities which are taking low-level waste from nuclear 

10 plants in the States of South Carolina, Utah and Washington. However, none of the three will 

11 currently take all types of low-level radioactive waste from Texas power plants. Thus, the [EIS] 

12 must address how much of which kinds of low-level radioactive waste will go to which facilities 

13 must be addressed. In addition, because there is the real possibility that no facility will be found 

14 in the short-term for the most radioactive of low-level rad waste, an EIS must address the 

15 possibility and impacts of permanent disposal of low-level rad waste on-site. (0003-36 [Reed, 

16 Cyrus])

17 Comment: If the ER fails to adequately assess the generation, storage and disposal of low18 level waste, the oversights in terms of high level radioactive waste are much greater. First of all, 

19 the ER assesses the transport of spent fuel (high level waste) to a depository, using Yucca 

20 Mountain as an example. Yet both the NRC and NRG know that even if Yucca Mountain were to 

21 open sometime in the first years of operation of STP No. 3 and 4, storage of spent fuel would be 

22 taken up by existing nuclear plants. There has yet to be, and does not appear to be any 

23 resolution of the question of how to dispose of high level radioactive waste. (0003-37 [Reed, 

24 Cyrus])

25 Comment: I think it’s irresponsible to be considering permitting new reactors when we have yet 

26 to permit or identify a viable site to dispose of the waste. (0007-109 [Cushing, Lara])

27 Comment: Even assuming that that worst case doesn’t happen, you still have one non -- one 

28 problem that there is no good solution for. And that is what you’re going to do with nuclear 

29 waste. I don’t believe the time frame. I think it should be longer. But the federal government 

30 says we’re going to have to store high-level waste for 10,000 years, that we’re going to have to 

31 protect for 10,000 years. (0007-124 [Singleton, Robert])

32 Comment: I assure you we have the capability at South Texas to store nuclear waste. We 

33 have the capability to store all the waste, the high-level waste out of Units 1 and 2 through 2028. 

34 We have the capability for 10 years of storage in the new advanced boiling water reactor 

35 design, and there are technologies to allow us to develop storage that goes much beyond that, 

36 and basically we can store it as long as we need to, until the federal government fulfills their 

37 contact and takes possession of that spent fuel and ultimately disposes of it. Ten thousand 

38 years? Not 10,000 years. That fuel becomes less radioactive than what we dug out of the 

39 ground originally in a few hundred years. But, yes. (0007-140 [McBurnett, Mark])
Appendix D 

March 2010 D-45 Draft NUREG-1937 

1 Comment: What about wastes? The whole community of -- the whole question about the plant 

2 being permitted is dependant upon your ability to dispose of wastes. ... And we do not yet have 

3 a licensed and operating low-level radioactive waste disposal site, which means that the 

4 disposal, up until we get those things permitted, if we ever do, is here in this community. (0007-

5 22 [Smith, Tom])

6 Comment: With a nuclear power plant, the waste issue has not been solved. Yucca Mountain 

7 has been cutting back the workers to 15 now. And to bring more of this into the community is 

8 putting the community at risk. (0007-31 [Hadden, Karen])

9 Comment: A third issue is radioactive waste. It’s the big bugaboo in the room, nobody likes to 

10 talk about it. But the fact is, you know, for 50 years we’ve been talking about how we’re going to 

11 deal with radioactive waste. We still haven’t dealt with it. We still don’t have a final repository for 

12 radioactive waste. (0007-51 [Reed, Cyrus])

13 Comment: I saw some discussion about, you know, the transportation of the spent fuel rods to 

14 a final repository, and about the amount of space you would have at STP 3 and 4 to have these 

15 spent fuel rods. But I didn’t see the contingency. What happens if we never -- you know, what 

16 happens if we are never able to locate a place to put all this waste? Does it just sit there 

17 forever? Do you have the capacity? (0007-52 [Reed, Cyrus])

18 Comment: Similarly with low-level rad waste, you know, there are currently only three sites that 

19 are taking it, one of the which, Barnwell, has now said they’re not going to take it. We haven’t 

20 yet had the Andrews County site open up. Where is the contingency in here for what to do with 

21 that waste? (0007-54 [Reed, Cyrus])

22 Comment: [I]n the 50 years of the nuclear industry we have yet to identify a safe way to 

23 dispose of the waste. And that is an environmental impact of the South Texas Project. High24 level radioactive waste stays deadly for tens of thousands of years. And it’s a real engineering 

25 challenge to think of how to contain such a thing on such a geological time scale. So I think that 

26 the NRC needs to consider all of those impacts in the environmental scope of their review. And 

27 it’s a real engineering challenge to think of how to contain such a thing on such a geological 

28 time scale. So I think that the NRC needs to consider all of those impacts in the environmental 

29 scope of their review. (0007-95 [Acevedo, NK])

30 Comment: Yes, we [STP] generate high level nuclear waste. We know how to store it. We 

31 store it safely. We have the capability to store it safely for as long as we need to store it. 

32 Ultimately the federal -- we have a contract with the federal government to take possession of 

33 that material and dispose of it. Until they do so, we’ll store it and continue to do so in a safe 

34 manner. I want point out our waste is not in a tin building; it is a concrete building. (0008-114

35 [McBurnett, Mark])

36 Comment: And right now we’ve got a crisis because the scientific process that we’re looking to 

37 manage the nuclear waste South Texas 1 and 2, 3 and 4, the 104 operating reactors around the 

38 country -- right now there’s only one site that’s being looked at. And that’s in Yucca Mountain, 

39 Nevada. And the issue is is that if this were a scientific process you would be looking at least 
Appendix D 

Draft NUREG-1937 D-46 March 2010 

1 three sites. And you would be looking -- likely you would be looking at Deaf Smith County, 

2 Texas, as one of those other sites. And it wasn’t until 1987 that Deaf Smith County, Texas, was 

3 taken off of the list and Yucca Mountain, Nevada, was the only one that was left. (0008-43

4 [Gunter, Paul])

5 Comment: Now, the issue is is that we believe and -- that you should be able to raise this issue 

6 of nuclear waste within the context of building more reactors. But currently -- the current NRC 

7 process says that we are not allowed to raise that because of what they call the nuclear waste 

8 confidence decision. And that decision was made by rule-making with the U.S. Nuclear 

9 Regulatory Commission that said someday somewhere somebody somehow is going to figure 

10 out what to do with, you know, right now 55,000 metric tons. You add more reactors -- it’s going 

11 to be up to 100,000 metric tons, 120,000 metric tons. And right now the only place we’re looking 

12 at is to send it off to a seismologically and volcanically active area. And it’s not for sure that it’s 

13 going to happen. Right now the Yucca Mountain process is alling apart. And, in fact, there is no 

14 confidence. (0008-44 [Acevedo, NK])

15 Comment: How can the generation of waste which we still do not know how to safely store be 

16 justified? (0009-4 [Lindsey, Joy])

17 Comment: No high or low level site has yet been permitted Recognizing that generating 

18 nuclear energy produces tons of high and low-level radioactive waste that remains dangerous to 

19 living systems for tens of thousands of years, and radioactive and toxic waste is produced at 

20 every stage of the fuel cycle, including plant operations, the EIS should address waste issues 

21 thoroughly. (0010-19 [Public Citizen, Texas Office] [Smith, Tom])

22 Comment: There is still no ways to safely store nuclear waste for the millions of years during 

23 which it will remain radioactive. (0012-5 [Edwards, Nancy])

24 Comment: Nuclear power plants are not a clean energy source and they are not long-lived. 

25 Radioactive waste remains dangerous to human health for thousands of years, and no country 

26 in the world has found a solution for disposing of it. (Public Citizen April 2006). These plants 

27 have a life span of only 30-40 years, after which they must be upgraded at huge costs or 

28 decommissioned, leaving the site contaminated for thousands ofyears. (Southwest Workers’ 

29 Union October 25, 2007). (0015-2 [Williams, Mina])

30 Comment: It has also long been common knowledge that there are health and safety concerns 

31 associated with the production of nuclear power. We all know there are huge quantities of 

32 nuclear waste produced for which there is no satisfactory storage solution, and there are 

33 documented accidents resulting in contamination due to leakages. (0017-3 [Scheurich, Venice])

34 Response: Onsite storage and offsite disposal of spent nuclear fuel are Category 1 issues. 

35 The safety and environmental effects of long-term storage of spent fuel on site has been 

36 evaluated by the NRC and, as set forth in the Waste Confidence Rule at 10 CFR 51.23, the 

37 NRC generically determined that “if necessary, spent fuel generated in any reactor can be 

38 stored safely and without significant environmental impacts for at least 30 years beyond the 
Appendix D 

March 2010 D-47 Draft NUREG-1937 

1 licensed life for operation . . . of that reactor at its spent fuel storage basin or at either onsite of 

2 offsite independent spent fuel installations. Further, the Commission believes there is 

3 reasonable assurance that at least one mined geologic repository will be available within the 

4 first quarter of the twenty-first century and sufficient repository capacity will be available within 

5 30 years beyond the licensed life for operation of any reactor to dispose of the commercial high6 level waste and spent fuel originating in any such reactor and generated up to that time.” The 

7 comment provides no new significant information, and, therefore, will not be evaluated further. 

8 Comment: The low level waste analysis should examine the likelihood of off-site storage being 

9 available for such waste. (0002-24 [Sinkin, Lanny])

10 Response: Radiological wastes will be addressed in Chapter 6 of the EIS. 

11 Comment: Waste produced from uranium mining, including tailings, is another waste which 

12 should be included in the analysis. (0002-27 [Sinkin, Lanny])

13 Comment: Chapter 10 of the Environmental Report does not discuss the land that will likely be 

14 used to mine, process, enrich and fabricate uranium fuels, and the waste and air emissions that 

15 are generated in that process, nor does it discuss the long-term implications of the low-level and 

16 high-level waste generated by the operations of the plants, including their potential impact on 

17 water resources and human health. (0003-23 [Reed, Cyrus])

18 Comment: [T]here is no discussion of where uranium is likely to be mined as a result of the 

19 potential additional nuclear plants. Thus, while the ER suggests that uranium is a resource that 

20 is mainly imported and that the uranium mining industry in the U.S. has been depressed in 

21 recent years, the Sierra Club notes in Texas, there are currently 19 exploratory permits for 

22 uranium mining that have been granted or are being processed by the Railroad Commission of 

23 Texas since mid-2006, that four uranium mines are currently operating in Kleberg and Duval 

24 Counties, and that two new applications are being processed by the Texas Commission on 

25 Environmental Quality for mines in Duval and Goliad Counties. The EIS should assess different 

26 scenarios and the likely impacts, including in South Texas on water resources and health 

27 impacts. (0003-42 [Reed, Cyrus])

28 Comment: If NRC is to license a new nuclear plant, it must be based on the impacts from the 

29 whole uranium cycle that will result. For 50 years, nuclear power has been presented as a clean 

30 energy source, even as communities at Three Mile Island, Pennsylvania in West Valley, New 

31 York, in Sheffield, Illinois, Hanford, Washington, Barnwell and a myriad of other locations were 

32 impacted from the generation and waste disposal, in some cases leading to deaths. Any EIS 

33 must address the full impacts so more communities do not suffer. (0003-43 [Reed, Cyrus])

34 Comment: And then the source of uranium. We all think that the uranium will probably come 

35 from someplace else, and most of it will, but here in Texas we have a number of communities, 

36 particularly those around Karnes City and Kingsville where we have significant impact already to 

37 ground water as a result of uranium mining. We’re about ready to get into another round of 
Appendix D 

Draft NUREG-1937 D-48 March 2010 

1 uranium mining in Goliad and Duval Counties. And the impact of the uranium extraction on 

2 those communities typically means that ground water is no longer safe. (0007-26 [Smith, Tom])

3 Comment: And then also you have ... high-grade and low-grade uranium, so once you finish 

4 with the high-grade, when you enrich it you have to use energy to do that. So when you use low 

5 ...the low-level one, you have to use more energy just to get it so it could be used at the nuclear 

6 reactor plants. (0007-83 [Lopez, Diana])

7 Comment: While it’s true that nuclear power plants don’t emit carbon dioxide, one of the 

8 principle ingredients fueling global warming, the mining of uranium to fuel these plants is 

9 anything but clean. I’d ask all of you to consider the indirect costs associated with uranium 

10 mining. It’s a nasty business that can pollute aquifers, and taint drinking water and irrigation for 

11 nearby residents. (0007-86 [Castro, Geoffrey])

12 Comment: Mining and enriching uranium results in radioactive contamination of the 

13 environment and risks to public health. Exposure to radon has been shown to cause kidney 

14 failure, chronic lung disease, and tumors for the brain, bone, lung, and nasal passage. The EIS 

15 needs to assess the impact of uranium mining in the regions from where STP 3 and 4 will derive 

16 its fuel. (0010-23 [Public Citizen, Texas Office] [Smith, Tom])

17 Response: Impacts from the uranium fuel cycle have been tabulated in 10 CFR 51.51 Table S18 3, which is used as the basis for evaluating the contribution of the environmental effects of 

19 uranium mining and milling to the environmental costs of licensing the nuclear power reactor. 

20 Associated effects also discussed in the noted CFR include the production of uranium 

21 hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 

22 of radioactive materials and management of low-level wastes and high-level wastes related to 

23 uranium fuel-cycle activities. Health effects from normal plant operation will be addressed in 

24 Chapter 5. 

25 Comment: An EIS must assess the much more likely scenario that radioactive waste will be 

26 stored on-site well.... Forever. That assessment must include an assessment of any potential 

27 leaks, accidents or gases escaping from the containment zone. (0003-38 [Reed, Cyrus])

28 Response: Radiological waste will be discussed in Chapter 6 and accidents will be discussed 

29 in Chapter 7 of the EIS. 

30 Comment: In the economics analysis, the EIS should consider the burden on the public 

31 treasury potentially created by Units 3 and 4. For example, the Federal Government is already 

32 ten years behind in its promise to establish a long term repository for high level nuclear waste 

33 and remove such wastes from existing nuclear power sites. Based on that failure to perform, the 

34 Federal Government is having to pay for on site storage, amounting to billions of dollars. This 

35 expense is discussed in “As Nuclear Waste Languishes, Expense to U.S. Rises,” New York 

36 Times, February 17, 2008. (0004-2 [Sinkin, Lanny])
Appendix D 

March 2010 D-49 Draft NUREG-1937 

1 Response: NRC regulation (10 CFR 50.75) requires the establishment of a decommissioning 

2 trust fund. Sufficient funds are required to be collected and placed in a secure trust that would 

3 assure decommissioning, including the disposal of low-level waste. Funds are also collected 

4 from licensees annually to defray costs associated with the ultimate disposal of high-level 

5 waste. 

6 Comment: It’s mentioned in the application that you currently send it (low-level waste) to 

7 several locations. It seems like more detail would be needed so that we, the public, can be sure 

8 that this rad waste, both low-level and high waste, is taken care of. (0007-55 [Reed, Cyrus])

9 Comment: I am concerned about the waste issues, and I am concerned about Matagorda 

10 County being essentially set up as a permanent radioactive waste site because there doesn’t 

11 seem to be a solution for that one. (0007-91 [Dancer, Susan])

12 Response: Radiological wastes will be addressed in Chapter 6 of the EIS. 

13 Comment: [W]here is that uranium going to come from? We have at the Railroad Commission 

14 now 19 new exploratory permits for a uranium mine. To make the nuclear power plant you need 

15 uranium, uranium mining can have some environmental impacts here in Texas. So how are we 

16 going to make that if -- where that uranium’s coming from, and what the total fuel cycle impacts 

17 are going to be. (0007-57 [Reed, Cyrus])

18 Response: The NRC staff evaluated the environmental impacts of the uranium fuel cycle 

19 including the impacts of fuel manufacturing, transportation, and the onsite storage and eventual 

20 disposal of spent fuel. The staff’s evaluation accounts for the Commission’s “Waste 

21 Confidence” decision embodied in 10 CFR 51.23 to the extent that decision applies to such 

22 impacts. The comment does not provide new information and will not be evaluated further. 

23 Comment: If you’re looking at the enriching of uranium, you have to do -- and you have to do 

24 that at coal burning power plants as well. You know, so, one, maybe when it gets to the nuclear 

25 reactor here the pollution is not being produced, but every step of that process there’s pollution 

26 that’s impacting people, and once it arrives here at the South Texas Nuclear Project, then 

27 there’s a huge question of radioactive waste which we have nowhere to put. (0007-67 [Rendon, 

28 Genaro])

29 Response: Impacts from the uranium fuel cycle have been tabulated in 10 CFR 51.51 Table S30 3, which is used as the basis for evaluating the contribution of the environmental effects of 

31 uranium mining and milling to the environmental costs of licensing the nuclear power reactor. 

32 Associated effects also discussed in the noted CFR include the production of uranium 

33 hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 

34 of radioactive materials and management of low-level wastes and high-level wastes related to 

35 uranium fuel cycle activities. Radiological wastes will be addressed in Chapter 6 of the EIS. 
Appendix D 

Draft NUREG-1937 D-50 March 2010 

1 Comment: I’m not going to presume to tell you what’s best for your community, I am going to 

2 talk in solidarity with the communities that are facing the impacts of uranium mining. Eighty 

3 percent comes from overseas. Most of those places don’t even have environmental or worker 

4 protections. (0007-107 [Cushing, Lara])

5 Comment: The most radical nuclear people will admit that something is going to come along 

6 that’s going to be cleaner and safer and better, and that eventually -- well, we’re still going to be 

7 storing the waste from this 50 years or 100 years of nuclear power and have to safeguard it. 

8 What language are we going to put on the warnings to people from the nuclear waste and have 

9 any guarantee that it’s going to be spoken 10,000 years from now? (0007-125 [Singleton, Robert])

10 Comment: Interestingly enough, nuclear reactors remove radiation from the environment. This 

11 is probably going to come as a startling little fact for you, but think about this. The isotopes that 

12 you put in the reactor are long-lived isotopes -- radioactive isotopes. Reactors convert them to 

13 short-lived radioactive isotopes that die off much more quickly. When you’re through at the end 

14 of the day, there is a lower radiation load on the environment because of the presence of 

15 nuclear reactors. (0008-103 [Dykes, Ed])

16 Comment: In terms of going forward in the years to come, obviously we have much to do in the 

17 area of disposing of the high level nuclear waste. ... but it’s not something we should delay 

18 going forward with new construction and wait 20 or 25 years till the technology is developed. 

19 We should do it in parallel. (0008-111 [McCormick, Mr.])

20 Response: These comments do not provide new information relevant to the environmental 

21 impact analysis and therefore will not be evaluated further. 

22 D.2.17 Transportation 

23 Comment: Transportation, how will the materials and the waste come in and out of this 

24 community? (0007-24 [Smith, Tom])

25 Comment: [F]or us in San Antonio, this also raises other dangers. In 2004 we had 21 

26 derailments in our city, 21 derailments that killed five people; one of them spilling chlorine gas in 

27 the community killing four people instantly. So how is this [uranium] being transported? Is it 

28 going to be coming through our backyards, of which -- you know, we want to make a clear 

29 statement that we would not, and do not, want this type of deadly waste passing through 

30 people’s backyards. And it’s literally passing through people’s backyards when you look at the 

31 train system in the City of San Antonio. (0007-65 [Rendon, Genaro])

32 Comment: [H]ow is the fuel going to be transported into this community? How is waste -- if 

33 they ever find a place to put the waste, how is going to be transported out of this community? 

34 What we found out in San Antonio after 21 derailments, major derailments, occurred in 2004 is 

35 that you can’t get any of that information. You can’t find out the routes that they’re taking. They 
Appendix D 

March 2010 D-51 Draft NUREG-1937 

1 won’t tell you what’s on those trains, and there’s no way to know that. So how can we possibly 

2 evaluation the risk to our communities when we don’t even know where this stuff is going to be 

3 transported through, and how to protect it? (0007-94 [Cushing, Lara])

4 Response: The environmental impacts of transporting fuel and waste to and from the STP site 

5 will be evaluated, and the results of the analysis will be presented in Chapter 6 of the EIS. The 

6 transportation of radioactive material to and from the STP site, including unirradiated fuel, spent 

7 fuel, and radioactive waste, will be conducted in accordance with Federal regulations. The U.S. 

8 Nuclear Regulatory Commission (NRC) and Department of Transportation (DOT) are the lead 

9 Federal agencies in charge regulating the safety of shipments of radioactive materials. The 

10 NRC establishes requirements for the design and manufacture of packages for radioactive 

11 materials (10 CFR 71, Packaging and Transportation of Radioactive Materials). The 

12 Department of Transportation regulates the shipments while they are in transit, and sets 

13 standards for labeling and smaller quantity packages (Title 49, Transportation, U.S. Code of 

14 Federal Regulations). 

15 D.2.18 Decommissioning 

16 Comment: Additional radioactive waste is produced in terms of the irradiated structures and 

17 equipment in the nuclear plant. A comprehensive examination of the likely method of 

18 decommissioning should also be part of the EIS. (0002-26 [Sinkin, Lanny])

19 Response: Decommissioning will be discussed in Chapter 5. The environmental impact from 

20 decommissioning a permanently shutdown commercial nuclear power reactor is discussed in 

21 Supplement 1 to NUREG-0586, Generic Environmental Impact Statement on Decommissioning 

22 of Nuclear Facilities, which was published in 2002. For most environmental issues, the impact 

23 from decommissioning activities is considered small. 

24 D.2.19 Cumulative Impacts 

25 Comment: And very important when we’re looking and talking about the environmental impact 

26 statement, is that we also take into effect, into consideration, the cumulative impacts that folks 

27 have to deal with when we talk about pollution, when we talk about environmental 

28 contamination. ...And if you look at the Gulf Coast of Texas, it’s littered with chemical plants, it’s 

29 littered as well with refineries and ports, and huge inland ports as well that are situated for ships 

30 to be able to come in. So if we’re looking at ourselves here and in San Antonio, what is the 

31 whole of the impact that we’ve being exposed to? (0007-62 [Rendon, Genaro])

32 Comment: [I]f we look at the State of Texas, we rank number seven amongst countries in 

33 pollution. As one state, we’re surpassing what countries are producing in pollution. So we have 

34 to be looking at reducing that amount of pollution here within the State of Texas, reducing the 

35 impacts that communities are feeling by living around these polluting industries. (0007-63

36 [Rendon, Genaro])
Appendix D 

Draft NUREG-1937 D-52 March 2010 

1 Response: NEPA requires the analysis of cumulative impacts in an environmental impact 

2 statement. The cumulative impacts associated with the construction and operation of the 

3 proposed Units 3 and 4 will be evaluated and the results of this analysis will be presented in 

4 Chapter 7 of the EIS. 

5 Comment: [T]he analysis of the Matagorda [STP] site never acknowledges or assesses the 

6 degree to which siting a new nuclear plant next to an existing plant might present potential 

7 problems. Thus, what might the impact of a leak or problem at the existing STP No. 1 and 2 

8 present during the construction or operation of No. [3] and 4? Could a problem at the new plant 

9 lead to a shut down or problem with the existing plants? (0003-21 [Reed, Cyrus])

10 Comment: Is there an environmental impact by placing so much power, and so much waste in 

11 the same physical location, subject to an increased likelihood that a natural, operational or 

12 terrorist attack could have an even larger impact than if a nuclear plant were to be located, for 

13 example, at the site in Limestone County? Is it safer, in other words, to separate an aging and 

14 new plant? (0003-22 [Reed, Cyrus])

15 Comment: When you consider that this plant would be -- if it goes through -- having 

16 construction right next door to an operating nuclear plant, you’re introducing circumstances that 

17 haven’t been seen before. (0007-32 [Hadden, Karen])

18 Comment: I think that FEMA should be present for a safety hearing and the Department of 

19 Homeland Security. And I would like to hear how all of those agencies are, in fact, working 

20 together to assure safety. This is no small thing to have a construction site next to an operating 

21 nuclear plant. It deserves close scrutiny. (0008-54 [Hadden, Karen])

22 Comment: We did not see anything that had to do with coincidental unit problems. If we have a 

23 problem on Unit 1 and 2 during construction on 3 and 4 what’s going to happen about that? If 

24 we have a problem on 3 and 4 during the operation of Unit 1 and 2 and it affects Unit 1 and 2, 

25 what will happen with that? This works very strongly in things like low-pressure turbines coming 

26 apart. They just rebuilt the low-pressure turbines. Why? They obviously weren’t really happy 

27 with its performance at that point, and that was done as a preventive measure. (0008-67 [Wagner, 

28 William])

29 Response: These comments address issues related to co-location of two or more nuclear 

30 power plants. Several aspects of these issues will be addressed in the DEIS. The DEIS will 

31 address the doses to construction workers from the existing units, and from Unit 3 after it starts 

32 operation. The DEIS will also address cumulative radiological impacts of normal operation and 

33 cumulative risks of severe accidents. Other aspects of these issues, which are addressed in the 

34 emergency plan that has been submitted as part of the application, are out of the scope of the 

35 environmental review and will not be addressed in the DEIS. 
Appendix D 

March 2010 D-53 Draft NUREG-1937 

1 D.2.20 Need for Power 

2 Comment: Chapter 8 - the need for power - analyzes Texas-based information about the need 

3 for additional power in ERCOT, which covers the majority of Texas. While Sierra Club does not 

4 object to the use of ERCOT reports cited on 8.4-6 or 8.4-7, we would note the list is incomplete 

5 because it does not list reports which discuss other scenarios for the growth in overall and peak 

6 summer demand. Because we believe that ERCOT’s evaluation of power needs in Texas in 

7 itself is incomplete, we would suggest that the EIS conduct a much more balanced full-scale 

8 independent analysis. Specifically, the ERCOT evaluations cited by the applicant do not take 

9 into account significant regulatory and statutory changes which will increase the use of load 

10 demand management and energy efficiency as a result of legislative action taken in 2007 [i.e. 

11 HB3693]. [I]t is quite likely that the future of peak and load demand will look quite differently 

12 then that presented by the applicant. (0003-9 [Reed, Cyrus])

13 Response: The determination for the need for power within a given area is not under the 

14 NRC’s regulatory purview. When another agency has the regulatory authority over an issue, 

15 NRC defers to that agency’s decision. The NRC staff reviews the need for power analysis to 

16 determine if it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and 

17 (4) responsive to forecasting uncertainty. If the need for power evaluation is found to be 

18 acceptable, no additional independent review by the NRC is needed. 

19 Comment: In addition to these legislative and regulatory changes that will affect the need for 

20 power, several studies have come out over the last 18 months which should be assessed, as 

21 they present alternative demand scenarios based on the use of increased renewable energy, 

22 increased efficiency and increased demand response programs. (0003-10 [Reed, Cyrus])

23 Comment: NRG and CPS base their need for the plant on forecasts from ERCOT that may 

24 overstate the need for power, and therefore the need for STP 3 and 4. Indeed, it should be 

25 remembered at the end of 2006, ERCOT was stating that generation capacity would fall below 

26 the required reserve capacity of 12.5 percent potentially by 2008, only to later reassess this 

27 projection based on a smaller demand as well as the opening of several gas plants. The ER 

28 states that by 2016 ERCOT projects there will be a need for between 20,000 and 50,000 MWe, 

29 and that the capacity of STP 3 and 4 - as well as many other generation sources - are therefore 

30 needed. (0003-13 [Reed, Cyrus])

31 Comment: ER Chapter 9 states “NRG anticipates it would not be able to provide competitively 

32 priced power if it had to retain an extensive conservation and load modification incentive 

33 program” and further implies that demand management is not a form of baseload power. 

34 Nevertheless, this two paragraph analysis is not a true analysis of the potential for baseload 

35 demand management to provide power or make up for the need for additional power. The 

36 analysis of the ability of peak demand plants to replace baseload plants is superficial and does 

37 not incorporate the ability of different plants to be used in combination to provide power, such as 

38 the conjunctive use of solar, wind and natural gas as a way to provide power through peaking 

39 plants operating at different times of the day. (0003-17 [Reed, Cyrus])
Appendix D 

Draft NUREG-1937 D-54 March 2010 

1 Comment: NRG has to prove there is a need for new energy. Their assessment of need is 

2 based on ERCOT projections of future energy demand in Texas. But, 1. The application ignores 

3 the effect energy efficiency and renewable energy will have in the future on demand. 2. Recent 

4 studies have shown that we could meet between 75-100% of Texas’s growth in demand using 

5 efficiency and renewable energy (“Role of Energy Efficiency and Onsite Renewables in Meeting 

6 Energy and Environmental Needs in the Dallas/Fort Worth and Houston/Galveston Metro 

7 Areas”. R. Neal Elliott and Maggie Eldridge. American Council for an Energy-Efficient Economy, 

8 September 2007 Report Number E078; (0010-20 [Public Citizen, Texas Office] [Smith, Tom])

9 Comment: Federal and state-mandated energy efficiency and renewable energy goals do not 

10 appear to be factored into the energy needs assessment. The EPACT of 2007 mandated a ban 

11 on incandescent bulbs, increased air conditioning efficiency standards and standards of other 

12 appliances, and other efficiency reductions that are not counted in NRG’s analysis of need. Nor 

13 are the provisions of HB 3693, passed by the Texas Legislature in 2007, factored into the 

14 energy needs assessment. The bill doubled the goal of the state of reducing by 10% per year 

15 the growth in demand for electricity to a minimum of 20%. A study completed during licensing 

16 period showed efficiency may result in as much as 50% of the growth in demand. (0010-21

17 [Public Citizen, Texas Office] [Smith, Tom])

18 Comment: As to CPS’s need for power the analysis contains an interesting logical flaw. It 

19 claims that an analysis of need is required for traditional utilities, such as CPS, but not for 

20 merchant companies such as NRG. It then further claims that since CPS has sold power at 

21 wholesale, and will continue to do so in the future, it does not have to do a needs analysis. This 

22 logic is imperfect. CPS is a municipal utility, and has not opted into competition, and is limited to 

23 incidental sales to customers beyond its traditional service area, so it should have completed a 

24 need for power analysis. CPS ignores the study done by KEMA in 2004 for CPS San Antonio 

25 that shows that over 1220 MW of baseload savings could be obtained at costs less than 2 cents 

26 per kilowatt hour (pg 3.1) or far less than the 6.5 cents per kilowatt than the cost of building and 

27 operating the plant. (0010-22 [Public Citizen, Texas Office] [Smith, Tom])

28 Response: Affected states or regions may prepare a need for power evaluation and 

29 assessment of the regional power system for planning or regulatory purposes. A need for 

30 power analysis may also be prepared by a regulated utility and submitted to a regulatory 

31 authority, such as a state public utility commission. However, the data may be supplemented by 

32 information from other sources. The determination for the need for power is not under NRC’s 

33 regulatory purview. When another agency has the regulatory authority over an issue, NRC 

34 defers to that agency’s decision. The NRC staff will review the need for power and determine if 

35 it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to 

36 forecasting uncertainty. If the need for power evaluation is found to be acceptable, no additional 

37 independent review by the NRC is needed. The information provided in this comment will be 

38 considered to determine whether it significantly affects the forecast on which the applicant relied 

39 for its need for power analysis. 
Appendix D 

March 2010 D-55 Draft NUREG-1937 

1 Comment: Sierra Club believes that an EIS must more independently assess these claims 

2 [need for power], and also assess other projects currently being planned in Texas, including 

3 new wind generation, plans for solar plants, energy efficiency and demand response program, 

4 coal plants and new natural gas plants. (0003-14 [Reed, Cyrus])

5 Comment: Our assessment, and along with the Energy Reliability Council of Texas basically 

6 says we need power, we need generation, we need new generation on line and we need to 

7 retire old units that are in operation, we need new power generation in Texas, we need new 

8 base load generation in Texas. (0007-138 [McBurnett, Mark])

9 Comment: But the fundamental question is, do we need this plant, and will it be completed on 

10 time? And this history of this has not been clear. The last time we tried to build a plant in this 

11 community, it took eight years longer than necessary. And what we’re seeing here in this 

12 particular analysis that has been presented to you all, is that the applicant says we need the 

13 plant for baseload. And it’s impossible to really utilize other resources like energy efficiency and 

14 renewable energy as base load. (0007-27 [Smith, Tom])

15 Comment: I wanted to make sure that the NRC is aware that legislation was passed last 

16 legislative session... that expands the amount of energy that investor-owned utilities, like NRG, 

17 are required to get from energy efficiency programs that all of us, frankly, pay for. And so I 

18 wanted to make sure that when you do the analysis of whether this power is needed, that we 

19 look at those new requirements on energy efficiency, because I think everyone agrees we can 

20 save money for our consumers, and generate more power simply by saving energy. (0007-43

21 [Reed, Cyrus])

22 Comment: The Harris and Galveston County Council of Governments, which is 13 counties, 

23 including Matagorda County, recently started last year making plans for an additional 2.5 million 

24 people coming to our area by year 2015. That’s a footprint of Los Angeles, California, coming 

25 on a 13-county area. Matagorda County is going to get its share of those people. We’re having 

26 to plan for it now. But the main thing is the power that’s needed for our state in this area is 

27 something we’ve got to work on. (0008-19 [Morton, Joe])

28 Comment: I want to congratulate CPS Energy for their forward-looking windtricity and 

29 conservation programs. We’ve heard this afternoon people talk that we need a mix of 

30 conservation, energy saving, renewal resources, and CPS Energy is providing that to us in the 

31 San Antonio area. ...But even with this, even with the rest of the citizens doing this in San 

32 Antonio, I don’t think this is surely enough to meet the future needs of electricity in San Antonio 

33 and south Texas. (0008-25 [Kale, Stephen])

34 Comment: Secondly, the governments of San Antonio and Bexar County are on record that 

35 they desire -- strongly desire continued economic growth in the city -- in Bexar County and in 

36 the city. CPS Energy has determined that timely additional electrical generation capacity is 

37 required for this growth in south Texas. So I submit that the proposed action and alternatives 

38 must be able to meet these requirements. (0008-27 [Kale, Stephen])
Appendix D 

Draft NUREG-1937 D-56 March 2010 

1 Comment: It has not been shown that there is a need for this expansion. (0009-3 [Lindsey, Joy])

2 Comment: The governments of San Antonio and Bexar County are on record that they desire 

3 continued economic growth for the City and the County. CPS Energy has determined that timely 

4 additional electricity generation capacity ls required for economic growth in South Texas. The 

5 proposed action and alternatives must be able to meet these requirements. (0014-2 [Kale, 

6 Stephen])

7 Response: Affected states or regions may prepare a Need for Power evaluation and 

8 assessment of the regional power system for planning or regulatory purposes. A Need for 

9 Power analysis may also be prepared by a regulated utility and submitted to a regulatory 

10 authority, such as a State Public Utility Commission. However, the data may be supplemented 

11 by information from other sources. The determination for the need for power is not under NRC’s 

12 regulatory purview. When another agency has the regulatory authority over an issue, NRC 

13 defers to that agency’s decision. The NRC staff will review the Need for Power and determine if 

14 it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to 

15 forecasting uncertainty. If the Need for Power evaluation is found to be acceptable, no 

16 additional independent review by the NRC is needed. 

17 D.2.21 Alternatives - Energy 

18 Comment: The global climate change question discussed above obviously calls into question 

19 using any fossil fuel central generators as an alternative. There are numerous other alternatives, 

20 however, that are safe and far more benign environmentally. (0002-29 [Sinkin, Lanny])

21 Response: The EIS will be prepared in accordance with 10 CFR 51.75(c). Alternative energy 

22 sources will be considered in the EIS and the potential global climate change impacts of fossil 

23 fuel generation stations will also be addressed. 

24 Comment: One of the applicants, CPSEnergy, has reclassified energy conservation as power 

25 generation. This essentially treats energy conservation approaches the same as baseload.

26 (0002-30 [Sinkin, Lanny])

27 Comment: The alternatives analysis should examine at least the following: 1. Energy efficiency 

28 and conservation, such as a. changing building codes that are leading to more energy efficient 

29 buildings, b. retrofitting of existing buildings that is lowering their energy consumption c. the 

30 redesign of appliances that is leading to replacing older units with more energy efficient units d. 

31 the “small is beautiful” alternatives, such as solar powered attic fans e. existing studies by 

32 utilities in the service area regarding possible reduction of energy demand through conservation 

33 and efficiency. (0002-33 [Sinkin, Lanny])

34 Comment: [B]ecause CPS is an applicant, their own study, which shows the potential to 

35 economically obtain 1,220 MW of Demand Savings and Technically 1,935 MWs by 2014 alone 

36 through a suite of energy efficiency measures - approximately the energy output of one of the 

37 units and approximately 40 % of the total capacity of both plants - this ability to obtain the power 
Appendix D 

March 2010 D-57 Draft NUREG-1937 

1 they say they need through a cheaper and more alternative must be assessed as part of the 

2 EIS. (0003-11 [Reed, Cyrus])

3 Comment: A CPS commissioned study, this was mentioned before, the CIMA report, 

4 concluded that 1200 megawatts of energy could be saved through stronger building codes and 

5 retrofitting programs. That’s 80 percent of the half of STP reactors 3 and 4 energy that we are 

6 going to be supposedly getting. And that report is nowhere mentioned in this environmental 

7 report. So this STP application needs to include a real analysis of alternatives, and all the 

8 alternatives for meeting San Antonio’s energy needs. (0007-100 [Cushing, Lara])

9 Comment: In trying to look through the thousands of pages of this permit application, I realize 

10 that the entire scope of the environmental review was based on, and this is a quote, “that the 

11 purpose of the project is to sell base-load power on the wholesale market.” And the only 

12 alternatives to this project that were looked at were alternatives for meeting that mission. But the 

13 fact is that that is not CPS Energy’s mission. CPS Energy’s mission, as a public utility, is to 

14 provide for the energy needs of San Antonio, and the other small areas that it covers and 

15 serves. (0007-89 [Acevedo, NK])

16 Comment: CPS has classified efficiency and conservation measures as a source of generating 

17 power. And since it’s done that, those need to be given over best analysis in the environmental 

18 report. (0007-90 [Cushing, Lara])

19 Comment: I believe CPS should be smarter than nuclear power plants, and they believe that 

20 we should be the green generation that think about the future and our health, but also the future 

21 generations to come. That is why CPS should invest in solar and wind energy. (0007-98 [Garcia, 

22 Sandra])

23 Comment: CPS’s mandate is to serve the energy needs of the greater San Antonio area, and 

24 its Strategic Energy Plan identifies energy efficiency as one of its four main tenets. According to 

25 its publications, CPS Energy is “so committed to this goal that energy efficiency is treated as a 

26 new resource for electrical generation.” As such, energy efficiency programs are a directly 

27 comparable alternative to the electricity that will be generated from STP 3 & 4 and need to be 

28 given full consideration in the EIS. (0018-3 [Cushing, Lara])

29 Comment: A 2004 CPS-commissioned study by KEMA Inc. concluded that it was cost effective 

30 for CPS to save 1,200 mW through stronger building codes and retrofitting programs, nearly as 

31 much as CPS’s 1,350 mW share of STP 3 &4’s generating capacity, on a comparable if not 

32 shorter time scale. Neither this report nor a more recent analysis of efficiency is presented in the 

33 permit application. With houses that waste more energy than any other large city in Texas, San 

34 Antonio has a huge potential for energy savings from weatherization programs that would 

35 contribute to the local economy by lowering family’s energy bills and creating “green collar” jobs 

36 in San Antonio. (0018-4 [Cushing, Lara])
Appendix D 

Draft NUREG-1937 D-58 March 2010 

1 Response: The DEIS will be prepared in accordance with 10 CFR 51.75(c) and will include a 

2 discussion of energy alternatives. Energy conservation and efficiency will be discussed as an 

3 energy alternative not requiring new generating capacity. Existing conservation programs will 

4 also be considered as part of the need for power analysis in Chapter 8 of the DEIS. 

5 Comment: The alternatives analysis should look at the rate at which alternatives are coming 

6 into use and project both what is likely and what is possible. A secondary question to be 

7 anwered is: Taking the same funds as will likely be spent on the nuclear plant and investing 

8 those funds in direct or subsidized implementation of alternative strategies, could the same 

9 amount of energy be saved and/or generated with far less environmental impact? A related 

10 question is: Would investment in the alternative technologies buy additional time before new 

11 generating capacity would be needed, allowing for still further innovative alternatives and 

12 improvements in existing alternatives? (0002-31 [Sinkin, Lanny])

13 Comment: Alternative energy, such as a. major breakthroughs in solar energy that are 

14 lowering the per watt cost to a level competitive with other sources b. new developments in 

15 storage which would permit solar and wind energy to be included as base load plants c. 

16 scenarios in which solar, wind, biomass and other sources provide most of the baseload with 

17 the available natural gas plants filling in as needed. d. wind energy potential, acknowledging 

18 that some environmental impacts, such as the impact on birds, must be addressed e. wave 

19 energy f. temperature differential energy extraction (ocean) g. biomass as baseload h. 

20 previously suppressed technology, such as Tesla coils This list is far from comprehensive.

21 (0002-34 [Sinkin, Lanny])

22 Comment: The most obvious irreversible and irretrievable commitment of resources is the 

23 money that will be spent on building the nuclear plants that will not be available for 

24 implementation of alternative energy strategies. Once begun, nuclear power plants will demand 

25 continuing investment and can be expected to absorb a far higher level than presented when 

26 the project is being sold to the utility and public. The analysis of this irreversible and irretrievable 

27 commitment of financial resources should evaluate the impact of that commitment on the ability 

28 to pursue implementation of alternative energy strategies, such as conservation, efficiency, 

29 solar, wind, and biomass. (0002-36 [Sinkin, Lanny])

30 Comment: [A]n EIS should not only assess the “no action”, “building nuclear plant at Bay City” 

31 or “building it somewhere else,” but assess other projects that NRG and CPS could be pursuing 

32 to meet their need to sell wholesale power in the first case, and meet the energy demands of its 

33 residents in the second. [T]he 2004 KEMA study commissioned by CPS sets out an alternative 

34 path for meeting the 40 percent of the plant that CPS has announced they are seeking a COL 

35 for. This should be assessed as part of an EIS. (0003-15 [Reed, Cyrus])

36 Comment: If CPS Energy could achieve a better, more cost-effective and environmentally37 more-friendly alternative to the proposed nuclear plant, then the EIS should examine that 

38 possibility. (0003-5 [Reed, Cyrus])
Appendix D 

March 2010 D-59 Draft NUREG-1937 

1 Comment: A coal fire power plant spits out more than four times as much radiation as the 

2 average nuclear plant does because of contaminants in the coal. In fact, you could generate 

3 more power from coal by removing uranium from it and thorium and burning it in nuclear power 

4 plants. There’s less environmental damage. The EPA estimates that 30,000 Americans die 

5 prematurely every year from the effluent from coal-fired power plants. (0008-104 [Dykes, Ed])

6 Response: The no-action alternative, as well as, alternative energy sources will be considered 

7 in the EIS. The analysis of alternatives in the EIS will be conducted in accordance with 

8 Section 102 of the National Environmental Policy Act and 10 CFR 51.75(c). 

9 Comment: [E]ach application must be carefully reviewed, and all alternatives to the siting of 

10 the plants and indeed to nuclear power itself must be considered as part of the EIS process.

11 (0003-2 [Reed, Cyrus])

12 Response: NRC staff carefully reviews each application it receives by utilizing an acceptance 

13 review process to ensure all required components are provided by the applicant. Each 

14 application then receives additional scrutiny during the safety and environmental review 

15 processes. Examining alternative energy sources and alternative sites is a function of the 

16 environmental review process and these topics will be discussed in the EIS. 

17 Comment: In the case of NRG, nuclear power is not the only option it has as an energy 

18 provider. They could - and are - pursuing development of coal plants, but could also be 

19 examining demand response and energy efficiency - which because of incentives can earn a 

20 provider a profit, on-site and off-site solar, wind, geothermal, biomass and other ways to 

21 generate a similar amount of power. (0003-16 [Reed, Cyrus])

22 Comment: There is no analysis of energy efficiency programs, and the solar analysis is based 

23 upon 2003 estimates of a cost of 0.108 and 0.187 per kilowatt hour, which are well above 

24 recently developed solar projects in California and Nevada. Indeed, the City of Austin has been 

25 receiving bids for proposed solar off-site plants that are on the low-end of this range, and recent 

26 technological improvements forecast lower solar energy costs over the next five years. An EIS 

27 must provide a much more extensive analysis of these alternatives than that provided in the ER.

28 (0003-18 [Reed, Cyrus])

29 Comment: While Chapter Nine does provide some analysis of coal-fired and natural gas 

30 plants, and concludes that they are not preferable to nuclear power because largely of the air 

31 quality impacts, such a conclusion does not take into account how that compares with the long32 term impacts of uranium mining and radioactive waste. Indeed, there is no real comparison 

33 between the three choices other than the conclusion that air quality impacts mean nuclear 

34 power is preferable. For example, coal, gas - and the alternatives that are never really 

35 considered such as energy efficiency, biomass, solar and wind - or some combination of all - 

36 are never assessed for the fact that they do not produce radioactive waste in large quantities.

37 (0003-19 [Reed, Cyrus])
Appendix D 

Draft NUREG-1937 D-60 March 2010 

1 Comment: In the areas of alternative energy, the EIS should also consider major commitments 

2 being made to accelerate the development of alternative, renewable energy. For example, the 

3 commitment of Silicon Valley to solar cells is discussed in “Silicon Valley Turns its Face to the 

4 Sun” in the New York Times on February 17, 2008. Google intends to spend hundreds of 

5 millions of dollars to hire engineers and other experts to develop solar, wind, geothermal, and 

6 other renewable resources. Austin Chronicle, February 8, 2008 at 31. (0004-1 [Sinkin, Lanny])

7 Comment: Well, let me just say it once again, so it’s absolutely clear what we’re in favor of. 

8 Conservation, renewables and energy efficiency. (0007-118 [Singleton, Robert])

9 Comment: I moved to Matagorda County in 1997 and I have lived very peacefully with STP 

10 down the road, and I have felt very safe. But my problem is, is that I do have a concern about 

11 building more nuclear power plants, as opposed to looking for alternative choices, other green 

12 choices. Of course, we have this huge yellow ball in the sky that burns us to death every 

13 summer, actually from March until like November, which is an endless source of power. (0007-

14 132 [Schwank, Eleanor])

15 Comment: As a matter of fact, yes, we need solar, we need wind, we need conservation, we 

16 need nuclear, and we need clean coal. We need all of those to meet our energy demands. 

17 Energy is what drives the economy of Texas, it’s what drives the economy of the world. It’s 

18 important, we need to plan for that energy. If we don’t, we’ll go, as an economy, down the hill.

19 (0007-139 [McBurnett, Mark])

20 Comment: Yet there are three studies not referenced in this most recent submission by NRG 

21 to you all that have been done in the last several years. One on San Antonio in particular that 

22 said we could save more than 1200 megawatts, far more than CPS’s share of this plant, if we 

23 did energy efficiency at costs less than building this plant. Another by Optimal Energy that said 

24 that the state could save 80 percent of the energy -- the growth in demand for energy that this 

25 plant is designed to meet. And yet another most recently by AC Triple E indicating that we could 

26 save between 75 percent of the growth in demand for energy, and 101 percent of the growth in 

27 demand for energy in either the Houston or Dallas areas respectively, by using energy efficiency 

28 as our first resource, along with other resources like combined heating and power, and 

29 renewable energies. (0007-28 [Smith, Tom])

30 Comment: And I also think that if we’re going to really analyze the power demands of -- that 

31 may be needed by these new plants, we’ve also got to look at the cities like San Antonio, like 

32 Austin, that may be investing in the plant and see -- look at how they meet their energy 

33 demands and whether they could be getting their energy in a cheaper, cleaner and faster 

34 manner. (0007-44 [Reed, Cyrus])

35 Comment: -- let’s make sure we look at all the choices. If the choice is this new nuclear plant, 

36 or concentrated solar power and efficiency, which really makes the most sense. And I hope, 

37 frankly, that NRG and the other investors are looking at all the options that are out there on the 

38 table, some of which I think could be used in Matagorda County. (0007-58 [Reed, Cyrus])
Appendix D 

March 2010 D-61 Draft NUREG-1937 

1 Comment: Now I understand that our energy needs here in Texas are growing. However, there 

2 are alternatives to nuclear power here in Texas, which are cleaner, more affordable, and more 

3 sustainable ways of powering our needs for the future. Alternatives include energy efficiency, 

4 solar power, wind, combined heat and power, and more. In addition, just not too long ago 

5 Optimal Energy discovered that 80 percent of our energy needs could be met by these 

6 technologies. (0007-87 [Castro, Geoffrey])

7 Comment: We can also talk about alternative power and how there’s no disposal plant for solar 

8 collectors. It might surprise a lot of you to understand that the incredible chemical mix that’s in 

9 solar panels, including arsenic. The burden on the environment with arsenic, which, by the way, 

10 has an infinite half-time -- not a 100,000 years, but infinite. (0008-105 [Dykes, Ed])

11 Comment: If you look at the carbon footprint of the life cycle of the nuclear power’s life cycle 

12 from the mining of the uranium all the way through the disposal of the waste that carbon 

13 footprint is the equivalent and the same footprint for solar and for wind and for hydro. (0008-127

14 [Shepherd, Joe])

15 Comment: [T]he land for these reactors [units 3 and 4] exists. Installation of the equivalent 

16 capacity [of solar and/or wind alternatives] -- and, again, I think when these alternatives and 

17 proposed actions are evaluated they’ve got to be done on an equivalent basis. So I think that 

18 installation of alternatives has got to be the equivocal capacity to what the proposed action for 

19 the nuclear plants will be. (0008-29 [Kale, Stephen])

20 Comment: I’m thinking primarily of wind and solar [energy alternatives], which would I think 

21 require large areas of land -- primarily the agrarian areas -- out in west Texas. I think the EIS 

22 needs to determine whether installation of these alternatives -- and I’m thinking about Fort 

23 Stockton -- the wind farms out there -- of Big Spring just off of I-20, and if you go up to 

24 Sweetwater and over across I-20 to Spider there are hundreds of windmills up there. So the 

25 EIS I think needs to evaluate installation of either wind, solar, whatever, and determine if there 

26 are any impacts -- primarily impacts on land usage, ecology, wildlife, other natural resources.

27 (0008-30 [Kale, Stephen])

28 Comment: And as a third generation Matagorda County resident I understand the concerns 

29 and -- that we have about nuclear power. But I also understand the huge drawbacks that we’re 

30 having today with our continued overuse of fossil energy. We as a county, of course, a state and 

31 nation need to look at solar, wind, bio, and, of course, nuclear energy for our future. (0008-31

32 [Head, Bobby])

33 Comment: This area has offshore wind, and there is a small town mayor in west Texas named 

34 Sherry Phillips. I heard her say the same things -- that when wind energy came to their 

35 community for the first time their kids could come home. They could live and work in the 

36 community. They could run cattle underneath the wind turbines. That’s a possibility for this 

37 community as well. And I urge NRG to seriously consider that path. (0008-50)
Appendix D 

Draft NUREG-1937 D-62 March 2010 

1 Comment: Why do we consider such a costly, potentially destructive, and unnecessary project 

2 instead of employing more benign solutions such as conservation, wind, and solar? (0009-7

3 [Lindsey, Joy])

4 Comment: I am writing to express my concern about the proposed expansion of the South 

5 Texas Nuclear Power plant (Federal Register Vol.72, No. 245/ Friday, December 21, 

6 2007/Notices Page 72775). As a resident of Houston, just to the north of this plant, I would like 

7 to know why this expansion has been proposed rather than expansion of our state’s enormous 

8 potential for wind energy. (0011-1 [Russell, Nancy])

9 Comment: Texas needs more non-polluting sources of electricity such as wind and solar. 

10 Utilities also should promote energy conservation as a way to avoid new construction of power 

11 plants. (0012-6 [Edwards, Nancy])

12 Comment: The land for the proposed reactors exists. Installation of the equivalent capacity of 

13 solar and/or wind alternatives will require immense areas of agrarian lands in West Texas. The 

14 EIS should evaluate whether installation of equivalent capacity of these alternatives would 

15 negatively impact land use, ecology. wild life, or other natural resources. (0014-4 [Kale, Stephen])

16 Comment: The clear alternative to coal and nuclear power plants is renewables: wind, sun, 

17 water, and geothermal. These technologies are on the horizon. Venture capitalists are presently 

18 investing in the development of the necessary technology to make these renewable sources of 

19 energy practical on a nationwide basis. According to a recent analysis by The National 

20 Renewable Energy Laboratory (NREL) - the country’s primary research and development facility 

21 for renewable technology - “the entire U.S. electricity demand could technically be met by 

22 renewable energy resources by 2020. In the longer term, the potential of domestic renewable 

23 resources is more than 85 times current U.S. energy use.” (0015-8 [Williams, Mina])

24 Comment: [A]ccording to the November 5, 2007, U.S. News and World Report cover story, 

25 “Power Revolution,” one of the most promising renewable energy sources is geothermal, which 

26 taps into Earth’s steady, reliable warmth. According to this article, recent studies show that 

27 techniques developed in the oil industry can be used to release geothermal energy three or 

28 more miles underground. (0015-9 [Williams, Mina])

29 Comment: We are concerned by the inadequate inclusion of the public in the decision by our 

30 public utility CPS Energy to construct two new nuclear reactors at the South Texas project 

31 (STP) and the total lack of an assessment of alternative ways to meet San Antonio’s energy 

32 needs in the Environmental Impact Statement (EIS) as required under the National 

33 Environmental Policy Act. As the ratepayers that will finance this project, we have a right to a full 

34 and transparent assessment of alternatives. (0018-1 [Cushing, Lara])

35 Comment: The EIS needs to include a thorough analysis of alternatives specific to meeting 

36 San Antonio’s energy needs that includes proactive weatherization and retrofitting programs, 

37 stronger building codes, combined heat and power or cogeneration strategies, renewable 

38 energy production, and combinations thereof. This analysis needs to receive as much 
Appendix D 

March 2010 D-63 Draft NUREG-1937 

1 consideration in terms of technical expertise, time and financial investment as the proposed new 

2 nuclear reactors have received. (0018-5 [Cushing, Lara])

3 Comment: STP 3 & 4 would be a huge financial investment for San Antonio ratepayers and will 

4 with all likelihood greatly overrun initial cost and time projections, preventing CPS from making 

5 large scale investments in efficiency and a renewable energy future. We deserve a full analysis 

6 of those different futures, free of radioactive waste, the pollution associated with uranium mining 

7 and enrichment, weapons proliferation, and the danger to public health and the environment 

8 from leaks and accidents at STP, before this project progresses any further. (0018-6 [Cushing, 

9 Lara])

10 Response: The EIS will be prepared in accordance with 10 CFR 51.75(c). Alternative energy 

11 sources, including energy conservation and renewable energy sources, will be considered in 

12 <Chapter 9 of> the EIS. 

13 D.2.22 Alternatives - System Design 

14 Comment: [T]he large cooling pond you see at South Texas, that 7,000-acre reservoir, is used 

15 for cooling the main turbine. It’s the main heat sink for the plant as the plant is in operation. 

16 Provided in Unit 1 and 2 is a pond for providing for emergency cooling should that be required. 

17 Unit 3 and 4 will actually have a cooling tower for emergency cooling for what we call the 

18 ultimate heat sink. ... it’s not one of these monster hyperbolic towers like you see in all the 

19 pictures that one associates with a nuclear plant. These are small towers, more akin to what 

20 you see out behind a large commercial building that provided for air conditioning. (0008-122

21 [McBurnett, Mark])

22 Response: This comment provides some information regarding the cooling system in use for 

23 STP Units 1 and 2 and the Ultimate Heat Sink cooling towers proposed for STP Units 3 and 4. 

24 No response is needed. 

25 Comment: They have a giant cooling pond out there. Depending on which part of that COLA 

26 you read, they’re either going to use cooling towers -- four-strap cooling towers on Units 3 and 4 

27 or they’re going to use the cooling pond itself. I’m not sure which one it is. (0008-73 [Wagner, 

28 William])

29 Comment: Speaking about the cooling link, what part of makeup requirements are going to be 

30 for both instances or decide which one you’re going to use and tell us that one. (0008-76

31 [Wagner, William])

32 Response: The Main Cooling Reservoir serves as the heat sink during normal operation of 

33 STP Units 1 and 2 and would operate similarly for STP Units 3 and 4. The make-up water for 

34 the reservoir is obtained from the Colorado River. The cooling towers for STP Units 3 and 4 

35 would be part of the Ultimate Heat Sink that would provide cooling for safety-related systems 

36 and components during normal and accidental conditions. The cooling water required for the 

37 Ultimate Heat Sink cooling towers would be stored in basins beneath the towers and make-up 

38 water to these basins would be provided by on-site water storage basins that contain 30-day 
Appendix D 

Draft NUREG-1937 D-64 March 2010 

1 supply of make-up water. Make-up water to the on-site water storage basins would be provided 

2 by groundwater. A detailed description of the cooling system for STP Units 3 and 4 will be 

3 presented in Chapter 3 of the DEIS. 

4 D.2.23 Alternatives - Sites 

5 Comment: The analysis of choosing an alternative site - such as NRG’s land owned in 

6 Limestone County - concludes that the existing Matagorda County [STP] site is preferable but is 

7 based largely on the possibility that additional transmission lines would be needed at the 

8 Limestone County site. The analysis seems too simplistic. (0003-20 [Reed, Cyrus])

9 Response: The DEIS <Chapter 9> will include a more detailed analysis of siting the proposed 

10 nuclear generating units at alternative sites located within the applicant’s region of interest. 

11 D.2.24 Benefit-Cost Balance 

12 Comment: [B]ecause the City of Austin hired a consultant to study the NRG and CPS proposal 

13 and found that the risk of investing in the application process outweighed the benefit because of 

14 the potential for the cost of the construction and licensing to exceed the estimates provided by 

15 the applicant by $1 billion, this analysis must be included as part of the discussion of 

16 alternatives. (0003-12 [Reed, Cyrus])

17 Comment: Failure to provide financial information needed for true alternative analysis: the 

18 applicant has asked for and the NRC has granted an exemption to disclosing basic financial 

19 information about the proposal. Thus, in Chapter 1 of the COL application, tables [1.3-1 through 

20 1.3-9] have been declared proprietary and thus unavailable for public review. The reason that 

21 project cost, construction funds, O & M costs and plant performance are an environmental issue 

22 is because NEPA requires an analysis of alternatives to the proposed action, and without cost 

23 figures and analysis of the construction and O & M costs, it is impossible to know if the energy 

24 demand needed could be more cost-effectively be achieved through other means, or with 

25 construction of a nuclear plant at another site. (0003-4 [Reed, Cyrus])

26 Comment: It is also difficult to assess whether the plant would generate the monies needed for 

27 ongoing repairs, the ability to respond to emergency situations, and the ability to provide 

28 decommissioning costs without a financial analysis. Even assuming that EPA and NRC have 

29 the needed financial information provided by the applicants to assess these issues, it will be 

30 difficult as a member of the public to add to the discussion through the draft EIS process without 

31 making at least basic financial information disclosed. (0003-6 [Reed, Cyrus])

32 Comment: The lack of financial information - at least publicly available - also makes it difficult 

33 to assess Chapters 8, 9 and 10 of the applicants Environmental Report. (0003-8 [Reed, Cyrus])

34 Comment: [The EIS] also needs to incorporate the true costs of nuclear power. And if it did, 

35 there’s no way that nuclear power would come out on top. There’s reasons why no nuclear 

36 reactors -- the construction of nuclear reactors has not been permitted in 29 years, despite that 
Appendix D 

March 2010 D-65 Draft NUREG-1937 

1 fact that it’s the most government subsidized energy source of all. And one of the reasons why 

2 the true costs of nuclear are never evaluated is because NRC only looks at a small price. The 

3 fact is that the construction of new generators is -- and the speculation about the construction of 

4 new generators, is already driving up the price of uranium, which means communities are 

5 fighting tooth and nail right now to prevent new uranium mining permits from being issued in 

6 South Texas. That is an environmental impact of the South Texas Project. (0007-92 [Cushing, 

7 Lara])

8 Comment: We get no cost figures out of that COLA -- none. Everything is proprietary. That’s 

9 nonsense. I can get cost figures on ones that they haven’t even put applications in on. And in 

10 some cases they’ve already decided it costs too much. The one thing that would kill this -- and it 

11 won’t be guys like me -- is money. And if we don’t know what’s going on we’ll never know, will 

12 we? (0008-86 [Wagner, William])

13 Comment: Nuclear power is not competitive with other forms of power generation and requires 

14 taxpayer dollars to subsidize. (0009-2 [Lindsey, Joy])

15 Comment: Nuclear power still requires Federal subsidies to make it competitive with other 

16 forms of power generation. (0012-3 [Edwards, Nancy])

17 Comment: As one leading advocate for green technology puts it: “Any state that allows the 

18 construction of new nuclear power plants in the face of today’s global industrial competition and 

19 financial turmoil will be committing economic suicide.- (Harvey Wasserman, Testimony to the 

20 Public Utilities Commission of the Ohio House, January 30, 2008). (0015-11 [Williams, Mina])

21 Comment: Nuclear power plants are not cost effective. Nuclear power plants have required 

22 exorbitant cost overruns, are dependent on massive federal subsidies, and need continual 

23 expensive maintenance. Cost to taxpayers is extreme. (Southwest Workers’ Union April 25, 

24 2007). (0015-4 [Williams, Mina])

25 Response: The applicant is authorized by 10 CFR 2.390 that trade secrets and commercial 

26 and financial information be held by NRC as privileged or confidential, subject to certain 

27 procedural controls allowing access to the information. The Commission also determines 

28 whether the right of the public to be fully apprised as to whether the bases for and effects of the 

29 proposed action outweighs the demonstrated concern for protection of a competitive position, 

30 and whether the information should be withheld from public disclosure. The NRC has 

31 determined that the requested financial information shall be held as confidential. The 

32 comparison of alternatives in the DEIS is an environmental comparison, not a financial one. 

33 Comment: The intergenerational aspect of producing high level waste for every generation 

34 coming after us so that we can have supposedly cheaper electricity should be a part of the 

35 analysis of unavoidable impacts of pursuing the project. (0002-25 [Sinkin, Lanny])

36 Comment: You know, as a young person I wonder why we are putting so many money and 

37 energy into this when in the last 50 years the nuclear problems have not even been solved.

38 (0007-73 [Lopez, Diana])
Appendix D 

Draft NUREG-1937 D-66 March 2010 

1 Response: The DEIS will discuss the provisions for the long-term storage of spent fuel. The 

2 NRC’s Waste Confidence Rule, found in 10 CFR 51.23, states: The Commission has made a 

3 generic determination that, if necessary, spent fuel generated in any reactor can be stored 

4 safely and without significant environmental impacts for at least 30 years beyond the licensed 

5 life for operation (which may include the term of a revised or renewed license) of that reactor at 

6 its spent fuel storage basin or at either onsite or offsite independent spent fuel storage 

7 installations. The rule covers new reactors and applies to the staff’s review of an early site 

8 permit or a combined license application. The Atomic Safety and Licensing Board presiding 

9 over the proceeding on the Grand Gulf early site permit application affirmed that the Waste 

10 Confidence Rule and its subsequent amendments clearly include waste produced by a new 

11 generation of reactors. 

12 Comment: Given that the applicant in the application makes it clear they will rely on the federal 

13 Department of Energy guarantees to peak interest in capital investment markets, the financing 

14 of the project would seem a reasonable area to be investigated as part of the EIS. If the 

15 financing for the project does not work, there is the potential to have the project stalled, which 

16 could have environmental impacts. (0003-7 [Reed, Cyrus])

17 Response: The benefit-cost balance for the project will rely on the best available estimate of 

18 project timing and duration and will note any uncertainties in the analysis. 

19 Comment: CPS provides my residential electricity at a cost much lower than the national 

20 average. My suspicion is that that’s due in a large part to the operation of the nuclear plants. My 

21 own residence bill is about $35 a month lower than this national average. 35 bucks a month 

22 doesn’t sound like much, but over the course of a year I think that’s a pretty good piece of 

23 change. So I think that the proposed action and the alternatives need to consider this and be 

24 able to meet this type of a requirement. If they can’t then the EIS should go into the impacts -- 

25 the negative impacts – socio-economic impacts on the residents and the businesses in San 

26 Antonio. (0008-28 [Kale, Stephen])

27 Comment: CPS Energy provides residential electricity at a cost much lower than the national 

28 average. My own residence bill is about $35 a month less than the national average. The EIS 

29 should evaluate whether the proposed action and alternatives will improve or retain this low 

30 cost, and if not evaluate negative socioeconomic impacts. (0014-3 [Kale, Stephen])

31 Response: The purpose of the environmental impact statement is to disclose potential 

32 environmental impacts of building and operating of the proposed nuclear power plant. The 

33 determination for the impact of building and operating a nuclear power plant on retail power 

34 rates is not under NRC’s regulatory authority. 
Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

March 2010 E-1 Draft NUREG-1937 

Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

1 This appendix is intentionally left blank. In the final Environmental Impact Statement (EIS), this 

2 appendix will include comments and responses received on the draft EIS. 

Appendix F 

Key Consultation Correspondence 

March 2010 F-1 Draft NUREG-1937 

Appendix F 

Key Consultation Correspondence 

1 Correspondence received during the evaluation process for the combined license application for 

2 the siting of two new nuclear units, Units 3 and 4, at the South Texas Project Electric 

3 Generating Station (STP) site in Matagorda County, Texas, is identified in Table F-1. In 

4 addition, full copies of the Biological Assessment and Essential Fish Habitat documents are 

5 included in this appendix.

6 Table F-1. Key Consultation Correspondence 

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission 

(William Burton) 

National Marine Fisheries Service 

(Mr. David Bernhart) 

January 25, 2008 

ML080020174 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Alabama-Coushatta Tribe, Historical 

Preservation Department 

January 25, 2008 

ML080090115 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Kiowa Tribe of Oklahoma 

(Mr. Billy Evans Horse) 

January 25, 2008 

ML073620378 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Comanche Nation NAGPRA and 

Historic Preservation Program 

(Ms. Ruth Toahty) 

January 25, 2008 

ML0703620358 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Tonkawa Tribe of Oklahoma 

(Mr. Anthony E. Street) 

January 25, 2008 

ML080090198 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Advisory Council on Historic 

Preservation (Mr. Don Klima) 

January 25, 2008 

ML080100669 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Texas State Historic Preservation 

Officer (Mr. Lawerence Oaks) 

January 25, 2008 

ML080110216 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Fish and Wildlife Service 

(Ms. Moni Belton) 

January 25, 2008 

ML080090170 

U.S. Nuclear Regulatory Commission 

(William Burton) 

Texas Parks and Wildlife Department 

(Ms. Kathy Boydston) 

April 4, 2008 

ML080730469 

STP Nuclear Operating Company 

(Mr. Gregory Gibson) 

Texas General Land Office 

(Mr. Benjamin Rhame) 

April 22, 2008 

ML091760272 

Texas Parks and Wildlife 

(Mr. Carter Smith) 

U.S. Nuclear Regulatory Commission 

(William Burton) 

May 19, 2008 

ML090330752 
Appendix F 

Draft NUREG-1937 F-2 March 2010 

1 Table F-1. (contd) 

Source Recipient Date of Letter

Texas General Land Office 

(Mrs. Tammy Brooks) 

STP Nuclear Operating Company 

(Mr. Gregory Gibson) 

June 09, 2008 

ML091590374 

U.S. Army Corps of Engineers 

(Mr. Fred Anthamatten) 

U.S. Nuclear Regulatory Commission 

(Mr. Scott Flanders) 

July 7, 2008 

ML082140640 

U.S. Nuclear Regulatory Commission 

(Mr. Scott Flanders) 

U.S. Army Corps of Engineers 

(Mr. Fred Anthamatten) 

August 29, 2008 

ML082310619 

STP Nuclear Operating Company 

(Mr. Scott Head) 

Texas Commission on Environmental 

Quality (Mr. Mark Fisher) 

February 03, 2009 

ML090360530 

U.S. Army Corps of Engineers 

(Mr. Kenny Jaynes) 

STP Nuclear Operating Company 

(Mr. Russell Kiesling) 

April 07, 2009 

ML091050501

U.S. Army Corps of Engineers 

(Mr. Kenny Jaynes) 

STP Nuclear Operating Company 

(Mr. Russell Kiesling) 

May 14, 2009 letter 

ML091350101 

Memo ML091390111 

STP Nuclear Operating Company 

(Mr. Scott Head)

U.S. Army Corps of Engineers 

(Mr. Jayson Hudson) 

June 04, 2009 

ML092030309 

U.S. Army Corps of Engineers 

(Mr. Casey Cutler) 

STP Nuclear Operating Company 

(Mr. Scott Head) 

July 08, 2009 

ML092030304 

U.S. Army Corps of Engineers 

(Mr. Jayson Hudson) 

U.S. Nuclear Regulatory Commission 

(Ms Jessie Muir) 

August 10, 2009 

ML092460137

U.S. Nuclear Regulatory Commission 

(Ms Jessie Muir) 

Fish and Wildlife Service 

(Ms. Moni Belton) 

October 15, 2009 

ML092580516 

U.S. Nuclear Regulatory Commission 

(Ms Jessie Muir) 

Texas Parks and Wildlife Department 

(Mr. Carter Smith) 

October 15, 2009 

ML092580421 

STP Nuclear Operating Company 

(Mr. Scott Head) 

U.S. Army Corps of Engineers 

(Mr. Jayson Hudson) 

October 29, 2009 

ML093210232 

U.S. Army Corps of Engineers 

(Mr. Jayson Hudson)

STP Nuclear Operating Company 

(Mr. Scott Head) 

November 10, 2009 

ML093210227 

Texas Parks and Wildlife 

(Mr. Ross Melinchuk) 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

November 13, 2009 

ML093210221 

U.S. Nuclear Regulatory Commission 

(Ms. Jessie Muir) 

Texas Parks and Wildlife 

(Ms. Amy Hanna) 

January 20, 2010 

ML093450914 
Appendix F 

March 2010 F-3 Draft NUREG-1937 

1 Table F-1. (contd) 

Source Recipient Date of Letter

Texas Commission on Environmental 

Quality (Mr. Charles Maguire) 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

February 2, 2010 

ML100500926 

U.S. Army Corps of Engineers 

(Mr. Casey Cutler) 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

February 19, 2010 

ML100660017 

2 
Appendix F 

Draft NUREG-1937 F-4 March 2010 

1 Biological Assessment 

2 

3 National Marine Fisheries Service

4 

5 

6 South Texas Project Electric Generating Station Units 3 and 4 

7 

8 

9 U.S. Nuclear Regulatory Commission Combined License Application 

10 Docket Nos. 52-012 and 52-013 

11 

12 U.S. Army Corps of Engineers Permit Application 

13 

14 

15 

16 Matagorda County, Texas 

17 

18 

19 March 2010

20 

21 

22 U.S. Nuclear Regulatory Commission 

23 Rockville, Maryland 

24 

25 U.S. Army Corps of Engineers 

26 Galveston District 
 Appendix F 

March 2010 F-5 Draft NUREG-1937 

1 1.0 Introduction 

2 The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from STP Nuclear 

3 Operating Company (STPNOC) for two combined construction permit and operating licenses 

4 (combined licenses or COLs) for two new reactors at the South Texas Project Electric 

5 Generating Station (STP) site in Matagorda County, approximately 12 mi south-southwest of 

6 Bay City, Texas (Figure 1). STPNOC submitted the COL application to the NRC on September 

7 20, 2007. The STP site and existing facilities are owned by NRG South Texas LP (NRG), City 

8 Public Service Board of San Antonio, Texas (CPS Energy), and the City of Austin, Texas. It is 

9 planned that proposed Unit 3 would be owned by Nuclear Innovation North America (NINA) 

10 South Texas 3 LLC and CPS Energy, and proposed Unit 4 would be owned by NINA South 

11 Texas 4 LLC and CPS Energy (STPNOC 2009a). Concurrent with the NRC’s review, the U.S. 

12 Army Corps of Engineers (Corps) is reviewing STPNOC’s application for a Department of the 

13 Army (DA) Permit to build the proposed reactors on the STP site. The NRC and the Corps are 

14 cooperating agencies with the NRC serving as the lead agency. This biological assessment 

15 (BA) supports a joint consultation with the National Oceanic and Atmospheric Administration’s 

16 (NOAA) National Marine Fisheries Service (NMFS) pursuant to Section 7(c) of the Endangered 

17 Species Act of 1973, as amended (ESA). 

18 The NRC and the Corps are preparing an environmental impact statement (EIS) as part of the 

19 agencies’ review of the COL and DA permit applications pursuant to the National Environmental 

20 Policy Act (NEPA). As required by Title 10 of the Code of Federal Regulations (CFR) Part 

21 51.26, the NRC has published a Notice of Intent (72 FR 72774) in the Federal Register to 

22 prepare an EIS, conduct scoping, and publish a draft EIS for public comment. The final EIS 

23 would be issued after considering public comments on the draft. The impact analysis in the EIS 

24 includes an assessment of the potential environmental impacts of the construction and 

25 operation of two new nuclear power units at the STP site and along the associated transmission 

26 line corridors, including potential impacts to threatened and endangered species. If approved, 

27 the COLs and DA permit would authorize STPNOC to construct and operate the new units. 

28 This BA examines the potential impacts on threatened or endangered species due to 

29 construction of the proposed Units 3 and 4 at the STP site. As discussed in the STP EIS, 

30 operation of the proposed two new nuclear power units at the STP site would not affect critical 

31 habitat or Federally listed species within the jurisdiction of NMFS. Therefore, this BA focuses 

32 on the species that may be affected by construction activities, specifically barging of heavy 

33 equipment and materials to the site. These species include loggerhead sea turtle 

34 (Caretta caretta), green sea turtle (Chelonia mydas), leatherback sea turtle (Dermochelys 

35 coriacea), hawksbill sea turtle (Eretmochelys imbricata), and Kemp’s ridley sea turtle 

36 (Lepidochelys kempii) (Table 1). 
Appendix F 

Draft NUREG-1937 F-6 March 2010 

1 

2 Figure 1. Location of the STP Site and Major Important Aquatic Resources 
 Appendix F 

March 2010 F-7 Draft NUREG-1937 

1 Table 1. Federally Listed Marine Species Occurring in the Vicinity of Transportation Routes to 

2 the STP Site (NMFS 2009a) 

Scientific Name Common Name Federal Status 

Caretta caretta loggerhead sea turtle Threatened 

Chelonia mydas green sea turtle Threatened 

Dermochelys coriacea leatherback sea turtle Endangered 

Eretmochelys imbricata hawksbill sea turtle Endangered 

Lepidochelys kempii Kemp’s ridley sea turtle Endangered 

3 2.0 South Texas Project Site Description 

4 The STP site is located in a rural area of Matagorda County, Texas. STPNOC currently 

5 operates two nuclear generating units (existing STP Units 1 and 2) on the site. The site is 

6 located approximately 10 mi north of Matagorda Bay, 70 mi south-southwest of Houston, and 

7 12 mi south-southwest of Bay City, Texas. The site is along the west bank of the Colorado 

8 River, approximately 6 navigable miles from the confluence with the Gulf Intracoastal Waterway 

9 (GIWW). This section provides a description of the existing and proposed facilities and the 

10 ecological resources found at the site of the proposed project and in the vicinity. 

11 2.1 Existing and Proposed Facilities on the STP Site 

12 The 12,220-ac STP site currently contains two pressurized water reactors and their associated 

13 facilities, which occupy approximately 300 ac. The main condenser heat sink for the existing 

14 two units is a 7000-ac reservoir called the Main Cooling Reservoir (MCR). The 7000-ac MCR is 

15 a constructed impoundment enclosed by an engineered embankment with a maximum normal 

16 operating pool of 49 ft mean sea level. The existing units also have a much smaller 46-ac 

17 Essential Cooling Pond (ECP) for their Ultimate Heat Sink (UHS). Makeup water for the MCR is 

18 withdrawn from the Colorado River at the Reservoir Makeup Pumping Facility (RMPF) to 

19 maintain the reservoir volume and control the concentration of total dissolved solids in its 

20 waters. The RMPF is located on the west bank of the river, approximately 8 navigable miles 

21 upstream of the confluence of the Colorado River and the GIWW. Near the southeast corner of 

22 the MCR is a spillway and blowdown discharge pipeline, which releases water to the Colorado 

23 River downstream from the RMPF. The spillway allows release of excess water from the MCR 

24 to the Colorado River during heavy precipitation events. The blowdown discharge pipeline 

25 allows for controlled releases of water from the MCR into the Colorado River through seven 

26 valve boxes along the river shoreline. Next to and downstream of the RMPF is a barge slip that 

27 was used for delivery of major equipment during the construction of Units 1 and 2. STPNOC’s 

28 proposed location for proposed Units 3 and 4 is wholly within the STP site, approximately 1500 
Appendix F 

Draft NUREG-1937 F-8 March 2010 

1 

2 Figure 2. STP Site and Proposed Plant Footprint (STPNOC 2009a) 
 Appendix F 

March 2010 F-9 Draft NUREG-1937 

1 Many of the existing facilities already were designed to support four nuclear reactor units, and 

2 the proposed Units 3 and 4 would rely on these facilities. The main condenser heat sink for the 

3 proposed units would be the MCR. The proposed new units would not rely on the ECP as an 

4 UHS in the event of an emergency, but rather would rely on two 119-ft-tall mechanical draft 

5 cooling towers that would be located north of the MCR (STPNOC 2009a). Modifications to the 

6 RMPF associated with the two new units would be limited and include refurbishing or replacing 

7 intake screens for currently unused bays and the addition of two new pumps. Maintenance 

8 dredging in front of the intake screens and the RMPF’s forebay would continue during 

9 construction and operation of the new units. No changes or upgrades are planned for the 

10 spillway and blowdown discharge pipeline from the MCR to the Colorado River to support the 

11 new units. The barge slip would be refurbished to allow delivery of material for constructing 

12 Units 3 and 4. In the event of an emergency, the proposed Units 3 and 4 would not rely on the 

13 ECP as a UHS. Instead, they will rely on two mechanical draft cooling towers as mentioned 

14 above (STPNOC 2009a). In addition, the Corps would periodically dredge the Colorado River to 

15 maintain the navigation channel from the GIWW to a point upstream of the STP site. 

16 2.2 Aquatic Ecological Resources 

17 The aquatic resources associated with the STP site include onsite water resources (sloughs, 

18 drainage areas, wetlands, Kelly Lake, and the MCR) and offsite water resources, particularly the 

19 Colorado River. The species of concern for this BA are associated with the offsite water 

20 resources. This section will discuss the offsite water resources likely to be affected by the 

21 barging activities for the construction and operation of the proposed STP Units 3 and 4. 

22 The Colorado River is one of the largest river systems within the State of Texas. The river is 

23 approximately 862 mi, extending from the high plains to the coastal marshes in Matagorda 

24 County. The section of the river near the STP site, between Bay City and the GIWW, is a 

25 diverse, fluvial system that meanders through the coastal plain providing freshwater, sediments, 

26 and nutrients to Matagorda Bay (ENSR 2008a). The lower Colorado River has been studied on 

27 a limited basis with specific studies conducted in 1974, 1976, 1983, and 1984 associated with 

28 the licensing of existing STP Units 1 and 2 (NRC 1975, 1986) and in 2007-2008 associated with 

29 the licensing of the proposed STP Units 3 and 4 (ENSR 2008a). 

30 Changes in the aquatic community in the Colorado River over time were evaluated using the 

31 results of the 1974, 1983, 1984, and 2007-2008 studies. These studies span the time of 

32 construction and operation of the existing STP Units 1 and 2, as well as the Corps’ Mouth of 

33 Colorado River project that completed the diversion of the Colorado River into Matagorda Bay in 

34 July 1992. The sampling locations and gear types varied with each study, making some 

35 comparisons more difficult. Trawl samples collected from the GIWW to the STP site in 1974 

36 showed a moderately diverse species community for the lower river based on measures for 

37 species richness, diversity, and evenness. All three measures were slightly lower than those in 
Appendix F 

Draft NUREG-1937 F-10 March 2010 

1 similar segments of the river compared to the 2007-2008 study, suggesting that the diversity of 

2 aquatic species is greater now than in the past. Data collected during 1974 examining specific 

3 segments also indicated a diverse species community for all three segments. The 1983-1984 

4 trawl and seine data indicated overall lower species richness, diversity, and evenness relative to 

5 the present data (ENSR 2008a). Rerouting of the lower Colorado River has likely contributed to 

6 these changes in diversity of aquatic species. 

7 The number and assortment of organisms collected during this study indicate that this portion of 

8 the lower Colorado River supports a diverse assemblage of fauna. The regular occurrence of 

9 both freshwater and saltwater species, the range of macroinvertebrate and finfish fauna, and the 

10 sheer number of species captured among various sampling gears and river reaches provide 

11 evidence of a dynamic ecosystem. There was a low to moderate level of similarity between the 

12 current 2007-2008 faunal communities and the historic communities (1974 and 1983-84) (ENSR 

13 2008a). 

Matagorda Bay is 300 mi2 14 formed by a 45-mi-long barrier island parallel to the coast and is 

15 located to the southeast of STP. The Bay is connected naturally to the waters on the site 

16 through the discharges of Little Robbins Slough into the marshes next to the GIWW, which then 

17 flow into Matagorda Bay. As mentioned, the Colorado River flows past STP, across the GIWW, 

18 and into a diversion channel, which flows into the Bay. The Bay is described as the Matagorda 

19 Bay system, and it is the third largest estuary on the Texas coast. The Bay system includes 

20 Lavaca, East Matagorda, Keller, Carancahua, and Tres Palacios Bays (Corps 2007). 

21 The aquatic community of the Matagorda Bay system includes organisms in open water areas, 

22 as well as organisms over hard substrates (including oyster reefs and offshore sands). In the 

23 open water areas of the Bay, phytoplankton (e.g., algae) are the major primary producers 

24 providing the main food source for zooplankton (e.g., small crustaceans), fish, and benthic 

25 organisms (e.g., mollusks). A study of Lavaca Bay found that phytoplankton species 

26 composition changes based on the season, with maximum abundance occurring in the winter 

27 and minimum in the summer, and the most dominant organisms were diatoms (Corps 2007). 

28 Zooplankton composition also changed seasonally, with the greatest abundance during the 

29 spring and minimum in the fall. The same composition of phytoplankton and zooplankton are 

30 thought to be found throughout the Matagorda Bay estuary (Corps 2007). 

31 The Matagorda Bay system supports a diverse population of aquatic organisms that are found 

32 in the open water column (nekton), including fish, shrimp, and crabs. The nekton assemblages 

33 consist mainly of secondary consumers feeding on zooplankton or juvenile and smaller 

34 organisms in the water column. Some of these species are resident species, spending their 

35 entire life in the Bay, whereas other species may spend only a portion of their life cycle in the 

36 Bay. According to a summary of studies on the nekton species in the Matagorda Bay estuary, 

37 the dominant nekton species include the bay anchovy (Anchoa mitchilli), Atlantic croaker 

38 (Micropogonias undulatus), white shrimp (Litopenaeus setiferus), brown shrimp 
 Appendix F 

March 2010 F-11 Draft NUREG-1937 

1 (Farfantepenaeus aztecus), hardhead catfish (Ariopsis felis), sand seatrout (Cynoscion 

2 arenarius), blue crab (Callinectes sapidus), and Gulf menhaden (Brevoortia patronus). All of 

3 these species are ubiquitous along the Texas coast, and they are unaffected by seasonal or 

4 other short-term changes (e.g., salinity). The abundance of these species changes with the 

5 season, with biomass and number usually being the smallest in the fall after Gulfward 

6 migrations. In the winter and early spring, newly spawned fish and shellfish begin migrating into 

7 the Bay, with the maximum biomass observed during the summer months (Corps 2007). Many 

8 of these species have been collected in the Colorado River and some in the MCR at the STP 

9 site (NRC 1975, 1986; ENSR 2008a, 2008b; STPNOC 2009a). 

10 Areas of the Matagorda Bay estuary that are not considered open water include oyster reefs 

11 (Eastern oyster, Crassostrea virginica) and offshore sands. The oyster reefs of Matagorda Bay 

12 are formed in areas where the substrate is hard and the current is strong enough to provide 

13 phytoplankton and nutrients to the oysters and carry sediment away from the organisms. The 

14 reefs are subtidal or intertidal and found near passes, cuts, and along the edges of marshes. 

15 The oyster reefs provide an ecologically important function to the Bay system by supplying 

16 habitat to other benthic organisms and influencing water clarity and quality (oysters can filter 

17 water 1500 times the volume of their body per hour). While oysters can survive in salinities 

18 ranging from 5 to more than 40 ppt, they thrive within a range of 10 to 25 ppt. The current 

19 distributions of oyster reefs in Matagorda Bay are not mapped, but the prominent locations 

20 (including commercial harvests) are in the vicinity of Lavaca Bay (Corps 2007). Primary goals 

21 of the diversion of the Colorado River into the Bay are to increase mixture of freshwater in the 

22 estuary and to enhance locations of the Bay for further reef development (Wilbur and Bass 

23 1998; Corps 2005). 

24 The offshore sands of the Matagorda Bay system include areas of open sandy substrate, as 

25 well as regions where seagrass or attached algae grow. Much of the faunal diversity in these 

26 areas is buried in the sand, and the organisms rely on the phytoplankton for food. Sand dollars 

27 (Mellita quinquiesperforata) and several species of brittle stars (Hemipholis elongata, Ophiolepis 

28 elegans, and Ophiothrix angulata) are some of the most common species found in the shallow 

29 offshore sands. The bivalves in offshore sands include the blood ark (Anadara ovalis), 

30 incongruous ark (Anadara brasiliana), southern quahog (Mercenaria campechiensis), giant 

31 cockle (Dinocardium robustum), disk dosinia (Dosinia discus), pen shells (Atrina serrata), 

32 common egg cockle (Laevicardium laevigatum), crossbarred venus (Chione cancellata), tellins 

33 (Tellina spp.), and the tusk shell (Dentalium texasianum). The most common gastropods are 

34 moon snail (Polinices duplicatus), ear snail (Sinum perspectivum), Texas olive (Oliva sayana), 

35 Atlantic auger (Terebra dislocata), Sallé’s auger (Terebra salleana), Scotch bonnet (Phalium 

36 granulatum), distorted triton (Distorsio clathrata), wentletraps (Epitonium spp.), and whelks 

37 (Busycon spp.). Crustaceans also inhabit the open sand areas, including white and brown 

38 shrimp, rock shrimp (Sicyonia brevirostris), blue crabs, mole crabs (Albunea spp.), speckled 

39 crab (Arenaeus cribrarius), box crab (Calappa sulcata), calico crab (Hepatus epheliticus), and 
Appendix F 

Draft NUREG-1937 F-12 March 2010 

1 pea crab (Pinnotheres maculatus). With respect to the number of individuals found in the open 

2 sands, the most abundant infaunal organisms are the polychaetes (Capitellidae, Orbiniidae, 

3 Magelonidae, and Paraonidae) (Corps 2007). 

4 Aquatic resources of the GIWW in the vicinity of Matagorda Bay up to Port Freeport are not well 

5 described. The aquatic ecology is thought to be similar to that found in Matagorda Bay. GIWW 

6 is used extensively for commercial traffic and recreational use. The locks in the GIWW at the 

7 confluence of the Colorado River probably disrupt some aquatic organisms from moving through 

8 the area. Maintenance dredging of the GIWW occurs at such a frequency that the typical 

9 benthic community found in Matagorda Bay does not fully recover (Corps 2007). 

10 3.0 Proposed Federal Actions 

11 This section provides information on the potential aquatic impacts of construction activities 

12 related to the proposed Units 3 and 4 at the STP site. The proposed Federal actions are NRC’s 

13 issuance of two COLs for construction and operation of two new nuclear reactors at the STP 

14 site pursuant to 10 CFR Part 52 and the Corps’ issuance of a DA permit pursuant to Section 

15 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Appropriation Act of 1899. 

16 The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

17 “construction” to activities that fall within its regulatory authority in 10 CFR 51.4. Many of the 

18 activities required to build a nuclear power plant are not part of the NRC action to license the 

19 plant. Activities associated with building the plant that are not within the purview of the NRC 

20 action are grouped under the term “preconstruction.” Preconstruction activities include clearing 

21 and grading, excavating, erection of support buildings and transmission lines, and other 

22 associated activities. These preconstruction activities may take place before the application for 

23 a COL is submitted, during the staff’s review of a COL application, or after a COL is granted. 

24 Although preconstruction activities are outside the NRC’s regulatory authority, many of them are 

25 within the regulatory authority of local, State, or other Federal agencies. The distinction 

26 between construction and preconstruction is not carried forward in this BA, and they are being 

27 discussed together as construction activities for this Section 7 consultation. 

28 This BA addresses the potential impacts posed by the construction activities that have the 

29 potential to interact with aquatic threatened and endangered species under the jurisdiction of 

30 NMFS. Primarily, these activities are associated with transport of materials and equipment 

31 using barges, which is not part of the NRC action. Operations of Units 3 and 4 would not 

32 interact with Federally listed aquatic threatened and endangered species or critical habitat. 

33 Delivery of major equipment for proposed Units 3 and 4 would be by barging the material to the 

34 site. The cargo that would be barged to the site includes heavy equipment (prefabricated 
 Appendix F 

March 2010 F-13 Draft NUREG-1937 

1 modules and large components fabricated overseas) and bulk commodities (e.g., aggregate or 

2 structural fill materials). STPNOC has stated that no firm shipping contracts have been 

3 developed for transportation of the materials to the STP site. However, STPNOC has indicated 

4 the current plans call for the heavy equipment to be shipped to the Port of Freeport (or points 

5 north) where they would be transferred from ocean-going ships to inland barges. The inland 

6 barges would then enter the GIWW, move south to the confluence of the Colorado River, and 

7 proceed upstream to the site. Currently, the ports in Matagorda Bay to the south of the site do 

8 not have adequate facilities for the transfer of heavy cargo from ocean-going vessels to inland 

9 barges. Therefore, transport of these materials would not involve the Matagorda Shipping 

10 Channel or the diversion canal in Matagorda Bay (STPNOC 2009b). 

11 STPNOC plans to ship bulk commodities (e.g., aggregate or structural fill materials) via inland 

12 barges. Access to the Colorado River by the barges would depend on the source of the 

13 materials and could be transported either from the north or south along the GIWW. However, 

14 no bulk commodity traffic is expected to traverse the diversion canal in Matagorda Bay or the 

15 Matagorda Shipping Channel (STPNOC 2009b). 

16 4.0 Protected Estuarine and Marine Species Descriptions 

17 NMFS lists 11 threatened and endangered species in Texas (Table 2). Of these species, only 

18 the sea turtles are expected to be associated with the construction of proposed STP Units 3 and 

19 4. The other species listed by NMFS for Texas are either too far away from the site (e.g., 

20 whales) or have not been found in the vicinity of the Colorado River or Matagorda Bay for 

21 numerous years (e.g., smalltooth sawfish [Pristis pectinata] [TPWD 2009a]). This section 

22 describes the life history and habitat use for the Federally listed sea turtles along the routes for 

23 ocean-going ships and inland barges that would transport materials to the STP site. 

24 

25 There are two families and six genera of living sea turtles containing eight species (Pritchard 

26 1996). All but one of the species are in the family Cheloniidae. The leatherback sea turtle is the 

27 only living member of the family Dermochelyidae. Five of the eight living species of sea turtles 

28 occur in the Gulf of Mexico. These species are the loggerhead sea turtle, the green sea turtle, 

29 the leatherback sea turtle, the hawksbill sea turtle, and the Kemp's ridley sea turtle. Although 

30 each of these species have nested along the Texas coast, no critical habitat has been 

31 designated in the State for any of these sea turtle species (Pritchard 1996; NMFS 2009a; 

32 NPS 2009). 

33 
Appendix F 

Draft NUREG-1937 F-14 March 2010 

1 Table 2. Federally Listed Estuarine and Marine Species Occurring in Texas (NMFS 2009a) 

Listed Species Scientific Name Status Date Listed 

Fish 

smalltooth sawfish Pristis pectinata Endangered 04/01/2003 

Marine Mammals 

sei whale Balaenoptera borealis Endangered 12/02/1970 

blue whale Balaenoptera musculus Endangered 12/02/1970 

fin whale Balaenoptera physalus Endangered 12/02/1970 

humpback whale Megaptera novaeangliae Endangered 12/02/1970 

sperm whale Physeter macrocephalus Endangered 12/02/1970 

Turtles 

loggerhead turtle Caretta caretta Threatened 07/28/1978 

green sea turtle Chelonia mydas Threatened 07/28/1978 

leatherback sea turtle Dermochelys coriacea Endangered 06/02/1970 

hawksbill sea turtle Eretmochelys imbricata Endangered 06/02/1970 

Kemp's ridley sea turtle Lepidochelys kempii Endangered 12/02/1970 

2 4.1 Loggerhead Turtle (Caretta caretta) 

3 The loggerhead turtle was named for its relatively large head and has powerful jaws used to 

4 feed on hard-shelled prey, such as whelks and conchs. Its carapace is slightly heart-shaped 

5 and reddish-brown, while the plastron is generally a pale yellowish color. Adult turtles weigh 

6 170 to 400 lb and have a carapace up to 41 in. long. Females nest on beaches in subtropical 

7 and temperate areas and may nest several times during a breeding season (April to 

8 September), laying as many as 110 eggs per clutch. The hatchings vary in color from light to 

9 dark brown to dark gray, and they lack the reddish-brown coloration of the adults and juveniles. 

10 When loggerheads hatch, they are about 1.7 in. long and weigh approximately 0.04 lb (Prichard 

11 and Mortimer 1999; NMFS 2009b; TPWD 2009b). 

12 4.1.1 Reasons for Status 

13 The loggerhead turtle was listed as a threatened species throughout its range on July 28, 1978 

14 (43 FR 32808). Until the 1970s, these turtles were commonly harvested commercially for their 

15 meat, eggs, leather, and fat. While the loggerhead is the most common and abundant turtle on 

16 the inshore coastal waters of the Gulf of Mexico, its population has been declining as a result of 

17 overexploitation by man, fishing and trawling activities inadvertently killing individuals, and 

18 natural predation. The most significant threats to the loggerhead are development, commercial 

19 fisheries, and pollution (NMFS 2009b; Corps 2007; TPWD 2009b). 
 Appendix F 

March 2010 F-15 Draft NUREG-1937 

1 4.1.2 Habitat and Life History 

2 Loggerhead turtles are mainly found over the continental shelf and in bays, estuaries, lagoons, 

3 creeks, and mouths of rivers, but they can also occur in the open seas as far as 500 mi from 

4 shore. Loggerheads prefer warm temperate and subtropical regions not far from shorelines. 

5 Adult loggerheads occupy various habitats, from turbid bays to clear waters of reefs, while 

6 subadults occur mainly in nearshore and estuarine waters. Hatchlings move directly from their 

7 nest into the sea, and then often float in masses of sargassum (Sargassum sp.). Juvenile 

8 loggerheads may remain associated with sargassum for perhaps three to five years (NMFS and 

9 FWS 2008; Corps 2007). 

10 Loggerheads consume a wide variety of both benthic and pelagic food items. Their prey has 

11 been found to include conches, shellfish, horseshoe crabs, prawns, other crustacea, squid, 

12 sponges, jellyfish, basket starts, fish (carrion or slow-moving species), and even hatchling 

13 loggerhead turtles (Corps 2007). Adults forage primarily on the bottom but will also take jellyfish 

14 from the surface. The young feed primarily on the surface, grazing on gastropods and 

15 fragments of crustaceans as well as sargassum. 

16 Nesting usually occurs on open sandy beaches above the high-tide mark and seaward of well17 developed dunes. Loggerheads prefer steeply sloped beaches with gradually sloped offshore 

18 approaches on high-energy beaches on barrier islands adjacent to continental land masses 

19 (Corps 2007). 

20 4.1.3 Range 

21 The loggerhead is widely distributed in tropical and subtropical seas, being found in the Atlantic 

22 Ocean from Nova Scotia to Argentina; the Gulf, Indian, and Pacific Oceans (although it is rare in 

23 the eastern and central Pacific); and the Mediterranean Sea. In the continental U.S., 

24 loggerheads nest along the Atlantic coast from Florida to as far north as New Jersey and 

25 sporadically along the Gulf Coast. In recent years, a few have nested on barrier islands along 

26 the Texas coast (Corps 2007). The loggerhead is the most abundant sea turtle species in U.S. 

27 coastal waters (NMFS and FWS 2007a). 

28 4.1.4 Distribution in Texas and Presence in the Study Area 

29 The most abundant sea turtle in the Texas coastal region is the loggerhead. The species 

30 prefers the shallow inner continental shelf waters and only infrequently does it move into the 

31 bays. The turtles are often found near offshore oil rig platforms, reefs, and jetties. They are 

32 likely present off the coast year-round. However, they are most often observed in the spring 

33 when their favorite food, the Portuguese man-of-war (Physalia physalis), is abundant. The 

34 loggerhead turtles are the most common species of sea turtles found washed ashore, either 
Appendix F 

Draft NUREG-1937 F-16 March 2010 

1 dead or moribund (stranded), on the Texas coast each year (Sea Turtle Stranding and Salvage 

2 Network [STSSN] 2009). The greatest proportion of these deaths appears to be the result of 

3 accidental capture by shrimp trawlers, when caught turtles drown. There was no positive 

4 documentation of loggerheads nesting along the Texas shoreline before 1977 (Hildebrand 

5 1982). Nesting sites in Texas have been confirmed since 1999 when two loggerhead nests 

6 were verified and again in 2000 when five loggerhead nests were confirmed. Between 2001 

7 and 2005, up to five loggerhead nests per year have been recorded on the Texas coast (Corps 

8 2007). In 2006, one nest each was observed on Padre Island National Seashore and on South 

9 Padre Island (NPS 2009). Loggerhead populations have declined in Texas as they have 

10 worldwide. In the early 1900s, the species was taken in Texas for local consumption, and a few 

11 were marketed (Hildebrand 1982; Corps 2007). 

12 The loggerhead turtle has been found in the vicinity of Matagorda Bay. Within the study area, a 

13 loggerhead was killed in 1996 during dredging operations in the entrance channel of the 

14 Matagorda Shipping Channel. In 2006, two loggerheads were taken at the entrance channel of 

15 the shipping channel during dredging operations (Corps 2007). 

16 4.2 Green Turtle (Chelonia mydas) 

17 The green turtle has a smooth shell and is the largest of the hard-shelled sea turtles. Adult 

18 turtles can grow to be more than 3 ft long and can weigh 300 to 350 lb. They have a smooth 

19 carapace that can be shades of black, gray, green, and brown in starburst or irregular patterns. 

20 The adults are unique in that they are herbivorous, feeding on primarily seagrasses and algae. 

21 The nesting season for green turtles varies based on location, but, typically, nesting occurs from 

22 June through September. The females choose a variety of locations for nesting, from large 

23 open beaches to small cove beaches, and can lay from 110 to 130 eggs per clutch (NMFS and 

24 FWS 1991; Prichard and Mortimer 1999; Corps 2007; NMFS 2009c; TPWD 2009b). 

25 4.2.1 Reasons for Status 

26 On July 28, 1978, the green turtle was listed throughout its range as a threatened species 

27 except for Florida and the Pacific Coast of Mexico where it was listed as endangered 

28 (43 FR 32808). Green turtles have declined primarily due to their commercial harvest, where 

29 the eggs and adults are used for food and other body parts for leather and jewelry. The 

30 recovery of the species has been hindered by mortality of juveniles and adults caught 

31 incidentally by commercial shrimp trawling. Various other fishing operations have also affected 

32 recovery of the species (NMFS 2009c). Another threat to the survival of the species is epidemic 

33 outbreaks of fibropapillomatosis, or “tumor” infections, in green turtle populations, especially in 

34 Hawaii and Florida. The cause of these outbreaks is largely unknown, but the disease is 

35 thought to be caused by a viral infection (Barrett 1996; Corps 2007). 
 Appendix F 

March 2010 F-17 Draft NUREG-1937 

1 4.2.2 Habitat and Life History 

2 Adult green turtles are found primarily in shallow habitats such as lagoons, bays, inlets, shoals, 

3 estuaries, and other areas where they can find an abundance of marine algae and seagrasses. 

4 They often use coral reefs and rocky outcrops near where they feed as resting areas. Individual 

5 adults passing through open ocean are thought to be migrating to feeding grounds or nesting 

6 beaches (Meylan 1982). Hatchlings often can be found floating in rafts of sargassum (sea 

7 plants) in convergence zones. The adults are primarily herbivorous, while the juveniles 

8 consume more invertebrates. Green turtles consume primarily seagrasses, macroalgae, and 

9 other marine plants. Juveniles, and sometimes adults, also feed on mollusks, sponges, 

10 crustaceans, and jellyfish (Mortimer 1982; Corps 2007). 

11 Green turtles typically come to shore only for nesting activities. However, they sometimes can 

12 be seen basking on beaches in areas such as Hawaii and the Galápagos Islands. They prefer 

13 to enter high-energy beaches with an open offshore approach and deep sand, which may be 

14 coarse to fine with little organic content. Generally, green turtles nest at the same beach each 

15 year, which is apparently their natal beach (Balazs 1980; Prichard and Mortimer 1999; Corps 

16 2007; NMFS and FWS 2007b). 

17 4.2.3 Range 

18 The green turtle is a circumglobal species in tropical and subtropical waters. They are found in 

19 U.S. Atlantic waters around the U.S. Virgin Islands and Puerto Rico and the continental U.S. 

20 from Massachusetts to Texas. Major nesting activity occurs on Ascension Island, Aves Island 

21 (Venezuela), Costa Rica, and in Surinam. Relatively small numbers nest in Florida, with even 

22 smaller numbers in Georgia, North Carolina, and Texas (NMFS and FWS 1991; Hirth 1997; 

23 Corps 2007). 

24 4.2.4 Distribution in Texas and Presence in the Study Area 

25 The green turtle in Texas generally inhabit shallow bays and estuaries around seagrass beds. 

26 Small juvenile turtles have been observed in bays that are devoid of seagrasses and are 

27 thought to be feeding on benthic invertebrates and jellyfish. The worldwide decline in green 

28 turtles has also been seen in the population off of the Texas coast. During the mid- to late-19th 

29 century, there was a green turtle fishery in Matagorda Bay, Aransas Bay, and the lower Laguna 

30 Madre, although a few also came from Galveston Bay. By 1900, however, the fishery had 

31 collapsed. Still, some turtles continued to be collected commercially until 1935 (Hildebrand 

32 1982; Corps 2007). 

33 Green turtle nests are rare in Texas. Padre Island National Seashore has recorded from one to 

34 five nests per year since 1987, except in 1999 when no nests were found (NPS 2009). Florida 
Appendix F 

Draft NUREG-1937 F-18 March 2010 

1 and Mexico are more common areas for green turtle nests. Adult green turtles found in Texas 

2 waters are thought to be in transit to distant feeding grounds or nesting beaches. Juvenile 

3 turtles found in Texas bays are thought to be using those waters as they move to other feeding 

4 grounds (Corps 2007). 

5 A study by Williams and Renaud (1998) in 1996-1997 found that four of the green turtles fitted 

6 with radio transmitters spent time in Lavaca Bay, western Matagorda Bay, and Powderhorn 

7 Bayou. A green turtle was recorded swimming in the Matagorda Ship Channel, and one was 

8 taken during dredging operations at the same location in 2004 (Corps 2007). In 2006, two 

9 green turtles were killed during maintenance dredging of the entrance and jetty channels of the 

10 Freeport Harbor Project. No green turtle nests have been recorded in the vicinity of the STP 

11 site (Corps 2007, 2008; NPS 2009). 

12 4.3 Leatherback Turtle (Dermochelys coriacea) 

13 Leatherback turtles are the largest and most distinctive of the living sea turtles. They reach a 

14 length of 78 in. and weigh more than 2000 lbs. Large, outstretched front flippers of the adult 

15 turtles may span 106 in. Lacking a keratinized shell, they are covered instead with a tough hide. 

16 Because they have physiological adaptations for heat conservation, leatherback turtles are 

17 more widely distributed as adults than other sea turtles in temperate and boreal waters 

18 throughout the world. However, all leatherbacks return to subtropical and tropical shores to nest 

19 (NMFS 2009d). 

20 4.3.1 Reasons for Status 

21 On June 2, 1970, the leatherback sea turtle was listed as endangered throughout its range 

22 (35 FR 8495). Critical habitat was designated for leatherbacks in the U.S. Virgin Islands 

23 (43 FR 43688 and 44 FR 17710). Estimating the world population of leatherbacks is based on 

24 nesting populations. Spotila et al. (1996) estimated the 1995 worldwide population of nesting 

25 female leatherbacks at 26,000 to 42,000. The decline of leatherbacks is attributable to 

26 overexploitation of the turtles for various uses, as well as incidental mortality from commercial 

27 shrimping and fishing activities. Leatherbacks have been known to be killed from complications 

28 after consuming litter, particularly plastics that are thought to be mistaken for jellyfish by the 

29 turtles. Other reasons for the decline of the turtles include collection of eggs for food and 

30 destruction or degradation of nesting habitat. Leatherbacks are probably more susceptible than 

31 other turtles to drowning in shrimp trawlers equipped with turtle excluder devices (TEDs) 

32 because the adults are too large to pass through the TED exit opening. To address this, NMFS 

33 established a leatherback conservation zone extending from Cape Canaveral to the Virginia34 North Carolina border, and commercial shrimping activities can be closed when there is an 

35 abundance of leatherbacks in those vicinities (NMFS and FWS 1992a; Corps 2007). 
 Appendix F 

March 2010 F-19 Draft NUREG-1937 

1 4.3.2 Habitat and Life History 

2 The leatherback sea turtle is mainly pelagic, found in the open ocean, and seldom approaches 

3 land except for nesting. Leatherbacks are most often found in coastal waters only when nesting 

4 or when following populations of jellyfish. The turtles dive almost continuously, often to great 

5 depths. Their diet consists largely of jellyfish and sea squirts, but they are also known to 

6 consume sea urchins, squid, crustaceans, fish, blue-green algae, and floating seaweed 

7 (FWS 1980). Leatherback turtles typically nest on wide, long beaches with steep slope, deep, 

8 rock-free sand and an unobstructed deep water or mud-bottom approach (Prichard and 

9 Mortimer 1999; Corps 2007; TPWD 2009b). 

10 4.3.3 Range 

11 Leatherback turtles probably have the greatest range of all the sea turtle species. They are 

12 found in the Atlantic, Pacific and Indian Oceans; as far north as British Columbia, 

13 Newfoundland, Great Britain, and Norway; as far south as Australia, the Cape of Good Hope, 

14 and Argentina; and in other water bodies such as the Mediterranean Sea. Leatherbacks are 

15 known to migrate further and venture into colder water than any other marine reptile. Adult 

16 turtles appear to engage in routine migrations between boreal, temperate, and tropical waters, 

17 presumably to optimize both foraging and nesting opportunities. During the summer, 

18 leatherbacks tend to occur off the coast of the Atlantic states, from the Gulf of Maine south to 

19 the middle of Florida (Corps 2007; NMFS and FWS 2007c). 

20 Nesting areas are primarily in the tropical regions, including Malaysia, Mexico, French Guiana, 

21 Surinam, Costa Rica, and Trinidad. The turtles nest infrequently on the Atlantic and Gulf of 

22 Mexico coasts. The largest nesting assemblages occur in the U.S. Virgin Islands, Puerto Rico, 

23 and Florida (Corps 2007; NMFS and FWS 2007c). 

24 4.3.4 Distribution in Texas and Presence in the Study Area 

25 There have been no recorded leatherback nests in Texas since the 1930s when one was found 

26 on Padre Island. There have been occasional reports of leatherbacks feeding on jellyfish off 

27 Port Aransas and in the Brownsville area. No leatherback turtles have been taken by dredging 

28 activities in Texas. One leatherback was caught in 2003 by a relocation trawler in a shipping 

29 channel approximately 1.5 mi north of Aransas Pass (NMFS and FWS 1992a, 2007c; TPWD 

30 2007; Corps 2007, 2008). This species is unlikely to occur in the vicinity of the STP site. 

31 4.4 Hawksbill Turtle (Eretmochelys imbricata) 

32 The hawksbill turtle is a medium-sized tropical and subtropical species that inhabits the warm 

33 waters of the Atlantic, Pacific, and Indian Oceans (NMFS and FWS 1993). It is the most tropical 
Appendix F 

Draft NUREG-1937 F-20 March 2010 

1 of the sea turtles and is restricted primarily to warmer waters more than the other four sea 

2 turtles found in the Gulf of Mexico. In U.S. territorial waters, hawksbills occur along the U.S. 

3 coast of south Texas and along the Gulf and Atlantic coasts of Florida. Adult nesting females 

4 have a carapace length of about 34 in. and weigh about 176 lbs. The largest hawksbill on 

5 record weighed 276 lbs. Hatchlings are about 1.7 in. long and weigh 0.5 to 0.7 oz (NMFS and 

6 FWS 1993). In the U.S. Caribbean and Florida Keys, overexploitation severely depleted 

7 hawksbills during the 20th century. Since banning sales of turtle shell products, hawksbills may 

8 no longer be in decline at present. However, data are not available to indicate that numbers are 

9 increasing (NMFS and FWS 1993, 2007d; NMFS 2009e). 

10 4.4.1 Reasons for Status 

11 On June 2, 1970, the hawksbill turtle was Federally listed as endangered throughout its range 

12 (35 FR 8495). Critical habitat for the species was designated in Puerto Rico (43 FR 22224 and 

13 63 FR 46693). The greatest threat to this species is commercial harvest of the turtle for its 

14 highly valued shell and as stuffed turtle curios. The hawksbill is also used in the manufacture of 

15 leather, oil, perfume, and cosmetics. Other threats to hawksbill turtles include destruction of 

16 breeding locations by beach development, incidental take in lobster and Caribbean reef fish 

17 fisheries, pollution by petroleum products (especially oil tanker discharges), entanglement in 

18 persistent marine debris, and predation on eggs and hatchlings (Corps 2007; NMFS 2009e). 

19 4.4.2 Habitat and Life History 

20 Hawksbills generally are found in coastal waters less than 70 ft deep, including coastal reefs, 

21 bays, rocky areas, passes, estuaries, and lagoons. Like loggerhead and green turtles, 

22 hatchlings are often found around sargassum rafts in the open ocean. Hawksbills reenter 

23 coastal waters as juveniles. Coral reefs are widely used for foraging on sponges by juveniles, 

24 subadults, and adults. In Texas, juvenile hawksbills are associated with stone jetties (FWS 

25 1980; Corps 2007; NMFS 2009e). 

26 Hawksbills are considered omnivorous, but they prefer invertebrates, especially encrusting 

27 organisms such as sponges, tunicates, bryozoans, mollusks, corals, barnacles, and sea 

28 urchins. Along the coast, they also consume algae, sea grasses, and mangroves. In open 

29 waters, the turtles consume jellyfish and fish. The young turtles appear to be more herbivorous 

30 than adults (Corps 2007; NMFS 2009e). 

31 Nesting typically is the only time hawksbills are found on shore. Hawksbills almost exclusively 

32 nest in the tropics on islands or the mainland. They are typically solitary nesters and prefer 

33 nesting on narrow beaches with reefs obstructing offshore approach (Prichard and Mortimer 

34 1999; Corps 2007). 
 Appendix F 

March 2010 F-21 Draft NUREG-1937 

1 4.4.3 Range 

2 Although it does occur in many temperate regions, the hawksbill turtle is probably the most 

3 tropical of all the marine turtles. Its range is circumtropical, occurring in tropical and subtropical 

4 seas of the Atlantic, Pacific, and Indian Oceans. The hawksbill turtle is widely distributed in the 

5 Caribbean Sea and western Atlantic Ocean, with representatives of at least some life history 

6 stages regularly occurring in southern Florida and the northern Gulf (especially Texas) and 

7 south to Brazil. In the continental U.S., the hawksbill sporadically nests in Florida. However, a 

8 major nesting beach exists on Mona Island, Puerto Rico. Small numbers of nests have been 

9 observed elsewhere in the western Atlantic, along the Gulf Coast of Mexico, the West Indies, 

10 and along the Caribbean coasts of Central and South America (NFMS and FWS 1993; Corps 

11 2007). 

12 4.4.4 Distribution in Texas and Presence in the Study Area 

13 Outside of Florida, Texas is the only state where hawksbills are encountered with any regularity. 

14 Most of these sightings are of post-hatchling and juvenile turtles around stone jetties. These 

15 small turtles probably traveled north from nesting beaches in Mexico. The first and only 

16 hawksbill nest recorded in Texas was in 1998 at Padre Island National Seashore (NMFS and 

17 FWS 1993, 2007d; Corps 2007, 2008; TPWD 2009b). This species may potentially occur in the 

18 vicinity of the STP site. 

19 4.5 Kemp’s Ridley Turtle (Lepidochelys kempii) 

20 The Kemp’s ridley turtle is one of the smallest living sea turtles. Adult females have shell 

21 lengths of 24 to 28 in., and they weigh 77 to 99 lb (NMFS and FWS 1992b). Pelagic-phase 

22 juvenile Kemp’s ridleys range in size from 2 to 8 in. in carapace length. Subadults are 8 to 24 

23 in. long, and mature adults generally are longer than 24 in. in carapace length (Marquez 1994). 

24 Kemp’s ridley turtles are distributed throughout the Gulf of Mexico and into the Atlantic Ocean. 

25 The center of their distribution is in the Gulf of Mexico. The Kemp’s ridley turtle is the most 

26 endangered sea turtle in the world (NMFS and FWS 1992b) and is listed as endangered 

27 throughout its range. From 1947 to 1985, the number of females nesting at the only significant 

28 Kemp’s ridley nesting beach dropped from more than 40,000 to as low as 702 (NMFS and FWS 

29 2007e). This is the most severe population decline documented for any species of sea turtles. 

30 Since the mid 1980s, there has been a noticeable increase in the number of nests. In 2003, an 

31 estimated 3,600 turtles produced over 8,000 nests (NMFS 2009f). While this trend is positive, 

32 the criteria for downlisting the status for Kemp’s ridley sea turtles under the ESA put forth in the 

33 recovery plan have not yet been met (NMFS and FWS 2007e). 
Appendix F 

Draft NUREG-1937 F-22 March 2010 

1 4.5.1 Reasons for Status 

2 On December 2, 1970, the Kemp’s ridley turtle was listed as endangered throughout its range 

3 (35 FR 18320). Primarily, the decline of this species has been the result of human activities, 

4 including collection of eggs, fishing for juveniles and adults, killing adults for meat and other 

5 products, and direct take for indigenous use. Another major factor in the loss of the species is 

6 the high level of incidental takes by shrimp trawlers (NMFS and FWS 1992b; NMFS 2009f; 

7 Corps 2007). 

8 Campbell (1995) documented the loss of Kemp’s ridley turtles due to the consumption of debris 

9 on the Texas coast. Postmortem examinations of Kemp’s ridleys found stranded from 1986 

10 through 1988 revealed 54 percent (60 of the 111 turtles examined) had eaten some type of 

11 marine debris. The most commonly ingested debris included pieces of plastic bags, Styrofoam, 

12 plastic pellets, balloons, rope, and fishing line. Other debris was also found, such as glass, tar, 

13 and aluminum foil. Campbell speculated that the source of the debris was from offshore oil rigs, 

14 cargo ships, commercial and recreational fishing boats, research vessels, naval ships, and other 

15 vessels operating in the Gulf. 

16 Further threats to this species include collisions with boats, explosives used to remove oil rigs, 

17 and entrapment in coastal power plant intake pipes (Campbell 1995). Incidental takes of 

18 Kemp’s ridley turtles have happened in association with dredging operations, particularly with 

19 hopper dredges. Placement of dredged materials, degraded water quality/clarity, and altered 

20 current flow associated with dredging activities can also affect turtles through channelization of 

21 the inshore and nearshore areas degrading foraging and migratory zones (NMFS and FWS 

22 1992b). 

23 4.5.2 Habitat and Life History 

24 Kemp’s ridleys inhabit shallow coastal and estuarine waters, usually over sand or mud bottoms. 

25 Adult turtles are primarily shallow-water benthic feeders, where they forage on crabs, while 

26 juveniles feed on sargassum and other organisms found in the mass of plants (NMFS and FWS 

27 1992b). In some regions, juvenile and adult Kemp’s ridleys almost exclusively eat blue crabs. 

28 Other food items in the Kemp’s ridleys diet include shrimp, snails, bivalves, sea urchins, 

29 jellyfish, sea stars, fish, and occasional marine plants (Campbell 1995; Corps 2007). 

30 Nesting occurs in a highly synchronized manner with large numbers of females (called an 

31 “arribada”) coming ashore within a period of a few hours during daylight (Marquez 1994). 

32 Hatchlings migrate rapidly down the beach and out to sea, where they spend a period of 

33 perhaps two years in the pelagic zone. They are about 8 in. long at the end of the pelagic 

34 period. Little is known about the feeding behavior and food preferences of hatchling Kemp’s 

35 ridley turtles during their pelagic stage. During this period, they presumably feed on 
 Appendix F 

March 2010 F-23 Draft NUREG-1937 

1 zooplankton and floating matter, including sargassum weed and the associated biotic 

2 community. Following a pelagic feeding stage shortly after hatching and lasting for several 

3 months, the juvenile Kemp’s ridleys move into shallow coastal waters to feed and grow. The 

4 young subadults often forage in water less than 3 ft deep, but they tend to move into deeper 

5 water as they grow. Because of their preference for crabs and other primarily shallow-water 

6 demersal prey, juvenile and adult Kemp’s ridley turtles concentrate in coastal waters less than 

7 30 ft deep throughout their range. They make long dives to the bottom and may feed on the 

8 bottom for an hour or more at a time (Turtle Expert Working Group 1998). 

9 4.5.3 Range 

10 Nearly all reproduction of Kemp’s ridleys takes place along a single 9.3-mi stretch of beach near 

11 Rancho Nuevo, Tamaulipas, Mexico, about 200 mi south of Brownsville, Texas (Marquez 1994). 

12 A small number of nests have been found in Texas and along the Mexican coast of the Gulf of 

13 Mexico between Playa Lauro Villar, Tamaulipas, Mexico and Isla Aguada, Campeche, Mexico, 

14 but nothing that reaches the level of nests at Rancho Nuevo. 

15 4.5.4 Distribution in Texas and Presence in the Study Area 

16 Kemp’s ridley turtles occur in Texas in small numbers and, when observed, are probably in 

17 transit between crustacean-rich feeding areas in the northern Gulf and breeding grounds in 

18 Mexico. As mentioned earlier, the number of nesting Kemp’s ridley turtles has been increasing, 

19 which may be a sign of the earliest stages of recovery for the species. The species has nested 

20 sporadically in Texas in the last 50 years with reports increasing over the last 12 years from four 

21 nests in 1995 to 102 nests in 2006 (a majority of the nests are located at Padre Island National 

22 Seashore). There was one nest recorded on Matagorda Peninsula in 2002 and four on 

23 Matagorda Island in 2004. The increase in nests is related to the success of breeding programs 

24 in Texas. A study by Williams and Renaud (1998) in 1996 found that seven of the Kemp’s ridley 

25 turtles fitted with radio transmitters spent most of their time within 4 mi of the western shoreline 

26 of Matagorda Bay, but they also swam to Lavaca Bay, Carancahua Bay, Tres Palacios Bay, and 

27 Powderhorn Bayou. Two Kemp’s ridleys were taken at the entrance of the Matagorda Ship 

28 Channel in 2006 during dredging operations (NMFS and FWS 1992b, 2007e; Corps 2007, 2008; 

29 TPWD 2009b). Of all the turtles, Kemp’s ridleys are likely to be the most common in the vicinity 

30 of the STP site. 

31 5.0 Potential Environmental Effects of the 

32 Proposed Actions 

33 This section describes potential impacts from construction of the proposed Units 3 and 4 at the 

34 STP site to the sea turtle species found in the Gulf of Mexico and on the coast of Texas. As 
Appendix F 

Draft NUREG-1937 F-24 March 2010 

1 stated above, impacts from operation of the proposed new units are highly unlikely to affect sea 

2 turtles as they do not swim upstream in the Colorado River to STP site. 

3 The potential impacts to Federally threatened and endangered sea turtle species resulting from 

4 the barging of heavy equipment and bulk commodities to the STP site are associated with 

5 collisions between the vessels and the turtles, capture in the turbine washes of the vessels, and 

6 potential disorientation from lights on the vessels. Sea turtles may be present at certain times of 

7 the year when barging traffic is moving through the Port of Freeport, Matagorda Ship Channel, 

8 and the GIWW. The five species of sea turtles discussed above would all be exposed to these 

9 potential impacts to degrees relative to their occurrence in Texas waters. There are no areas 

10 designated as critical habitat near the STP site (Corps 2007, 2008; NMFS and FWS 2007a, b, c, 

11 d, e; NMFS 2009a). 

12 Loggerhead, green and Kemp’s ridley turtles have all been recorded in the area where barging 

13 traffic for STP equipment and material would be expected to travel. Kemp’s ridley turtles have 

14 nested in the vicinity, and all the other sea turtle species are known to have nested to the south 

15 of the study area. An estimate of the species of sea turtles in the study area can be obtained 

16 from the STSSN, which tracks, collects, and documents standing of marine turtles in the Gulf of 

17 Mexico. STSSN divides the Gulf into zones, and the study area is included in zone 19, which 

18 extends from Freeport to Port Aransas, Texas. From 1986 through 2007, STSSN reported a 

19 total of 1051 strandings in zone 19: 523 loggerhead, 285 Kemp’s ridley, 105 green, 29 

20 leatherback, 15 hawksbill, and 94 unknown species (STSSN 2009). 

21 Increased vessel activity could affect sea turtles in the area. The most common effect from 

22 vessel activity on sea turtles is from propeller and boat strikes on the turtles. Direct strikes on 

23 the turtles can kill or maim the animals. The wash from the propellers of the barges is also 

24 known to entrain turtles and either temporarily disorient the organisms or potentially drown 

25 them. Lights from the vessels are thought to disorient turtles, particularly hatchlings. However, 

26 barging traffic to STP is not likely to happen in the dark (Corps 2007, 2008; STPNOC 2009b). 

27 The wash from moving barges could create flows that would disrupt food sources for the sea 

28 turtles. Organisms in the open water would be disrupted as the barge moved through the area, 

29 but the effects would be temporary. Increased vessel movements in narrow channels could 

30 erode shorelines and increase turbidity that could settle on benthic organisms, which could 

31 result in diminished food supply for the turtles. Barge traffic would be restricted to channels 

32 where traffic is common, and these areas are limited in comparison to the overall area of the 

33 bays and waterways where turtles can forage. While turtles can forage elsewhere, sea turtles 

34 that are swimming in vessel channels would be adversely affected if they interact with barges 

35 transporting materials and equipment to the STP site. 
 Appendix F 

March 2010 F-25 Draft NUREG-1937 

1 6.0 Cumulative Impacts to Federally Protected Species 

2 Barging of heavy equipment and bulk commodities would add to the vessel traffic through the 

3 Port of Freeport, Matagorda Ship Channel, and the GIWW in the study area. STPNOC has not 

4 finalized the plans for shipping equipment and material to the STP site. While traffic in these 

5 navigation areas would increase during the building of proposed Units 3 and 4, the number of 

6 trips for the barges carrying both heavy equipment and construction materials would not add 

7 significantly to the existing traffic in the area (STPNOC 2009b). 

8 Barging traffic may add cumulatively to the impacts on sea turtles from other activities within the 

9 study area. Sea turtles are affected by numerous activities that are common in the study area, 

10 including dredging, commercial fishing, vessel traffic, development along nesting beaches, 

11 pollution, and poaching. The Corps is responsible for maintaining over 12,000 mi of waterways 

12 throughout the United States for commercial and recreational vessel traffic, water supply, 

13 regional development, and national security. The three primary types of dredges used for 

14 maintaining navigational waters are cutterhead pipeline, mechanical, and hopper dredges. Sea 

15 turtles are most likely to be harmed or killed by hopper dredges. Based on the Corps’ Sea 

16 Turtle Data Warehouse, there have been 85 incidental takes of sea turtles since 1995 within the 

17 Galveston District from dredging activities, primarily loggerhead, green and Kemp’s ridley sea 

18 turtles. The Corps and the dredging industry continue to work on protocols, operational 

19 methods, and modifying dredging equipment to reduce impacts to sea turtles (Corps 2010). 

20 Some of these improvements include a plow-like deflector designed to move the turtles away 

21 from the suction of the draghead (NMFS and FWS 2007e). 

22 Along the proposed barging routes for transporting heavy equipment and bulk commodities for 

23 the construction of proposed Units 3 and 4, there are plans for dredging and changing the 

24 shipping channels at the Port of Freeport and Matagorda Bay. The Corps has prepared BAs for 

25 both of these activities and evaluated the effects on sea turtles from the use of pipeline and 

26 hopper dredges, sedimentation, loss of benthic habitat, and disorientation from lights on 

27 vessels. The Corps concluded these activities may affect the species, and hopper dredging 

28 would adversely affect the sea turtles. The Corps and NMFS have identified “reasonable and 

29 prudent measures” to reduce the potential for affecting sea turtles from the proposed activities 

30 at the Port of Freeport (Corps 2008) and will likely agree to similar measures for the Matagorda 

31 Ship Channel (Corps 2007). These measures include the implementation of a sea turtle 

32 avoidance plan. For more than a decade, these measures have been incorporated in the 

33 Corps’ regulatory and civil works projects throughout the Gulf of Mexico. Barging traffic to STP 

34 during the dredging activities planned by the Corps may create more distractions for the sea 

35 turtles in the area. 
Appendix F 

Draft NUREG-1937 F-26 March 2010 

1 Commercial fishermen in the bay systems of Texas must use approved TEDs to minimize 

2 collection of turtles in their trawl equipment (TPWD 2009c). Kemp’s ridley sea turtles are 

3 particularly susceptible to being caught in trawl nets because they inhabit shallow waters. In the 

4 past, shrimp trawls were known to kill thousands of Kemp’s ridley sea turtles each year before 

5 the implementation of TEDs, which occurred in 1990 for the Texas commercial fishing industry 

6 (TPWD 2009d). In addition, in 2000 Texas Parks and Wildlife Commission established 

7 seasonal closure for shrimping from the beach out to five nautical mi from December 1 through 

8 July 15, which is the season when adult Kemp ridleys use those waters for mating, nesting, 

9 foraging and migrating (NMFS and FWS 2007e). Other sea turtle species also benefit from the 

10 implementation of TEDs and seasonal closure of the fishing industry when they are prevalent. 

11 Vessel traffic in the area includes commercial and recreational vessels. NMFS has identified 

12 that these activities have an adverse impact on sea turtles from propeller and boat strike 

13 damage (Singel et al. 2003; NMFS and FWS 2007e). However, the magnitude of these events 

14 in the study area is not known (Corps 2008). 

15 Development in the study area can lead to loss of nesting habitat, increased pollution, increased 

16 recreational activities, etc. As mentioned above, there have been few sea turtles nesting in the 

17 Matagorda Bay area. Increased development of Matagorda Peninsula could remove 

18 appropriate habitat for future nesting activity. Lighting of homes and on roadways can disorient 

19 adult females as well as hatchlings and diminish the success of future nesting opportunities. 

20 Turtles can be harmed through ingestion and entanglement with debris washed into waters from 

21 developed areas or dropped overboard. Coastal runoff can contribute to poor water quality that 

22 affects the food for turtles as well as potentially harming them. Organochlorine compounds, 

23 heavy metals, and petroleum products are all known to be detrimental to turtles either directly or 

24 indirectly through bioaccumulation of the toxins in the food web (NMFS and FWS 2007e). 

25 Power plants and other large industrial systems in coastal waters also have the potential to 

26 affect sea turtles. The intake systems for cooling water at power plants have attracted and 

27 impinged turtles. Most of these power plants are located along the coastal area where turtles 

28 are foraging and nesting. It is unlikely that the operation of the nuclear units at the STP site 

29 would harm sea turtles because the intake system is located upstream in the Colorado River 

30 and turtles have not been reported in that area. Other industrial ports can attract turtles and 

31 they can be harmed by vessels approaching the port. 

32 7.0 Conclusions 

33 The potential impacts of barging heavy equipment and material for proposed Units 3 and 4 to 

34 the STP site on Federally protected sea turtle species in the vicinity of the site have been 

35 evaluated. The known distributions and records of those species and the potential ecological 

36 impacts of barging to the species, their habitats, and their prey have been considered in this BA. 
 Appendix F 

March 2010 F-27 Draft NUREG-1937 

1 Based on this review, the NRC and the Corps conclude that the overall effects of barging heavy 

2 equipment and material to the STP site for construction of the proposed Units 3 and 4, may 

3 affect but would not be likely to adversely affect or jeopardize the continued existence of the 

4 loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and Kemp’s 

5 ridley sea turtle in the Gulf of Mexico and on the coast of Texas. 

6 8.0 References 

7 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

8 Production and Utilization Facilities.” 

9 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

11 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

12 Certifications, and Approvals for Nuclear Power Plants.” 

13 35 FR 8495. “Endangered Species Conservation Act of 1969.” Federal Register. U.S. 

14 Department of the Interior. 

15 35 FR 18320. December 2, 1970. “Endangered Species Conservation Act of 1969.” Federal 

16 Register. U.S. Department of the Interior. 

17 43 FR 22224. May 24, 1978. “Proposed Determination of Critical Habitat for the Hawksbill Sea 

18 Turtle.” Federal Register. U.S. Department of the Interior.

19 43 FR 32808. July 28, 1978. “Listing and Protecting Loggerhead Sea Turtles as ‘Threatened 

20 Species’ and Populations of Green and Olive Ridley Sea Turtles as ‘Threatened Species or 

21 Endangered Species’.” Federal Register. U.S. Department of the Interior. 

22 43 FR 43688. September 26, 1978. “Determination of Critical Habitat for the Leatherback Sea 

23 Turtle.” Federal Register. U.S. Department of the Interior. 

24 44 FR 17710. March 23, 1979. “Determination of Critical Habitat for the Leatherback Sea 

25 Turtle.” Federal Register. U.S. Department of the Interior. 

26 63 FR 46693. September 2, 1998. “Designated Critical Habitat; Green and Hawksbill Sea 

27 Turtles.” Federal Register. U.S. Department of the Interior. 

28 72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

29 Federal Register. U.S. Nuclear Regulatory Commission. 
Appendix F 

Draft NUREG-1937 F-28 March 2010 

1 

2 72 FR 72774. December 21, 2007. “South Texas Project Nuclear Operating Company South 

3 Texas Project Site, Units 3 & 4; Notice of Intent To Prepare an Environmental Impact Statement 

4 and Conduct Scoping Process.” Federal Register. U.S. Nuclear Regulatory Agency. 

5 Balazs, G. 1980. Synopsis of biological data on the green turtle in the Hawaiian Islands. 

6 NOAA Technical Memorandum. NMFS-SWFC-7, U.S. Department of Commerce, Miami, 

7 Florida. 

8 Barrett, S. 1996. Disease threatens green sea turtles. Endangered Species Bulletin 21(2):8–9. 

9 Campbell, L. 1995. Endangered and threatened animals of Texas, their life history and 

10 management. Texas Parks and Wildlife Department, Resource Protection Division, 

11 Endangered Resources Branch, Austin, Texas. 

12 Clean Water Act. 33 USC 1251, et seq. 

13 Endangered Species Act of 1973, as amended (ESA). 16 USC 1531, et seq. 

14 ENSR Corporation (ENSR). 2008a. Aquatic Ecology – Colorado River Monitoring Report, Unit 

15 3 and 4 Licensing Project. Houston, Texas. 

16 ENSR Corporation (ENSR). 2008b. Aquatic Ecology – Main Cooling Reservoir and Circulating 

17 Water Intake Structure Study, Unit 3 and 4 Licensing Project. Houston, Texas. 

18 Hildebrand, H. 1982. “A historical review of the status of sea turtle populations in the western 

19 Gulf of Mexico.” In: K. Bjorndal, ed., Biology and conservation of sea turtles. Smithsonian 

20 Institution Press, Washington, D.C. 

21 Hirth, H.F. 1997. “Synopsis of the biological data on the green turtle Chelonia mydas (Linnaeus 

22 1758).” Biological Report 97 (1). U.S. Fish and Wildlife Service, Washington, D.C. 

23 Marquez, M.R. 1994. “Synopsis of Biological Data on the Kemp’s Ridley Turtle, Lepidochelys 

24 kempi (Garman, 1880).” NOAA Technical Memorandum NMFS-SEFSC-343, U.S. Department 

25 of Commerce, Miami, Florida. 

26 Meylan, A. 1982. “Sea turtle migration – evidence from tag returns.” In: K. Bjorndal, ed., 

27 Biology and Conservation of Sea Turtles. Smithsonian Institution Press, Washington, D.C. 

28 Mortimer, J.A. 1982. “Feeding ecology of sea turtles.” In: K. Bjorndal, ed., Biology and 

29 conservation of sea turtles. Smithsonian Institution Press, Washington, D.C. 
 Appendix F 

March 2010 F-29 Draft NUREG-1937 

1 National Marine Fisheries Service (NMFS). 2009a. “Endangered and Threatened Species and 

2 Critical Habitats under the Jurisdiction of the NOAA Fisheries Service: Texas.” NOAA Fisheries 

3 Service, Southeast Regional Office, Saint Petersburg, Florida. Accessed March 13, 2009 at 

4 http://sero.nmfs.noaa.gov/pr/esa/specieslst.htm. 

5 National Marine Fisheries Service (NMFS). 2009b. “Loggerhead Turtle (Caretta caretta).” 

6 Accessed November 2, 2009 at http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm. 

7 Accession No. ML100650007. 

8 National Marine Fisheries Service (NMFS). 2009c. “Green Turtle (Chelonia mydas).” 

9 Accessed November 2, 2009 at http://www.nmfs.noaa.gov/pr/species/turtles/green.htm. 

10 Accession No. ML100650007. 

11 National Marine Fisheries Service (NMFS). 2009d. “Leatherback Turtle (Dermochelys 

12 coriacea).” Accessed November 2, 2009 at 

13 http://www.nmfs.noaa.gov/pr/species/turtles/leatherback.htm. Accession No. ML100650007. 

14 National Marine Fisheries Service (NMFS). 2009e. “Hawksbill Turtle (Eretmochelys imbricata).” 

15 Accessed November 2, 2009 at http://www.nmfs.noaa.gov/pr/species/turtles/hawksbill.htm. 

16 Accession No. ML100650007. 

17 National Marine Fisheries Service (NMFS). 2009f. “Kemp’s Ridley Turtle (Lepidochelys 

18 kempii).” Accessed November 2, 2009 at 

19 http://www.nmfs.noaa.gov/pr/species/turtles/kempsridley.htm. Accession No. ML100650007. 

20 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1991. 

21 “Recovery Plan for U.S. Population of Atlantic Green Turtle.” National Marine Fisheries Service, 

22 Washington, D.C. 

23 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1992a. 

24 “Recovery Plan for Leatherback Turtles in the U.S. Caribbean, Atlantic and Gulf of Mexico.” 

25 National Marine Fisheries Service, Washington, D.C. 

26 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1992b. 

27 “Recovery Plan for the Kemp’s Ridley Sea Turtle (Lepidochelys kempii).” National Marine 

28 Fisheries Service, St. Petersburg, Florida. 

29 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1993. 

30 “Recovery Plan for Hawksbill Turtles in the U.S. Caribbean Sea, Atlantic Ocean, and Gulf of 

31 Mexico.” National Marine Fisheries Service, St. Petersburg, Florida. 
Appendix F 

Draft NUREG-1937 F-30 March 2010 

1 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007a. 

2 Loggerhead Sea Turtle (Caretta caretta), 5-Year Review: Summary and Evaluation. National 

3 Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

4 Jacksonville, Florida. 

5 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007b. 

6 Green Sea Turtle (Chelonia mydas) 5-Year Review: Summary and Evaluation. National Marine 

7 Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, Jacksonville, 

8 Florida. 

9 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007c. 

10 Leatherback Sea Turtle (Dermochelys coriacea) 5-Year Review: Summary and Evaluation. 

11 National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

12 Jacksonville, Florida. 

13 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007d. 

14 Hawksbill Sea Turtle (Eretmochelys imbricata) 5-Year Review: Summary and Evaluation. 

15 National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

16 Albuquerque, New Mexico. 

17 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007e. 

18 Kemp's Ridley Sea Turtle (Lepidochelys kempii) 5-Year Review: Summary and Evaluation. 

19 National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

20 Albuquerque, New Mexico. 

21 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2008. 

22 “Recovery Plan for the Northwest Atlantic Population of the Loggerhead Sea Turtle (Caretta 

23 caretta).” Second Revision. National Marine Fisheries Service, Silver Spring, Maryland. 

24 Pritchard, P.C.H. 1996. “Evolution, phylogeny and current status.” In: Lutz, P.L., Musick, J.A. 

25 (Eds.), The Biology of Sea Turtles. CRC Press, Florida. 

26 Pritchard, P.C.H., and J.A. Mortimer. 1999. Taxonomy, External Morphology, and Species 

27 Identification. In: Eckert, K.L., K.A. Bjorndal, F.A. Abreu-Grobois, and M. Donnelly (Editors), 

28 Research and Management Techniques for the Conservation of Sea Turtles. IUCN/SSC Marine 

29 Turtle Specialist Group Publication No. 4. Consolidated Graphic Communications, Blanchard, 

30 Pennsylvania. 

31 Rivers and Harbors Appropriation Act of 1899, as amended. 33 USC 403, et seq. 
 Appendix F 

March 2010 F-31 Draft NUREG-1937 

1 Sea Turtle Stranding and Salvage Network (STSSN). 2009. “Monthly turtle stranding by year, 

2 species, and state.” Accessed January 28, 2010 at 

3 http://www.sefsc.noaa.gov/seaturtleSTSSN.jsp. Accession No. ML100650007. 

4 Singel, K., T. Redlow, and A. Foley. 2003. “Twenty-two years of data on sea turtle mortality in 

5 Florida: Trends and factors.” In: J.A. Seminoff, compiler, Proceedings of the Twenty-Second 

6 Annual Symposium on Sea Turtle Biology and Conservation. NOAA Technical Memorandum 

7 NMFS-SEFSC-503, U.S. Department of Commerce, Miami, Florida. 

8 South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

9 Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

10 City, Texas. Accession No. ML092931600. 

11 South Texas Project Nuclear Operating Company (STPNOC). 2009b. Letter from Scott Head 

12 (STPNOC, Manager, Regulatory Affairs, South Texas Project, Units 3 and 4) to U.S. Nuclear 

13 Regulatory Commission dated September 14, 2009 in response to NRC letter dated August 14, 

14 2009, "South Texas Project Units 3 and 4, Docket Nos. 52-012 and 52-013, Response to 

15 Requests for Additional Information.” Accession No. ML092580491. 

16 Spotila, J.R., A.E. Dunham, A.J. Leslie, A.C. Steyermark, P.T. Plotkin, and F.V. Paladino. 1996. 

17 Worldwide population decline of Dermochelys coriacea: Are leatherback turtles going extinct? 

18 Chelonian Conservation and Biology 2(2):209–222. 

19 Texas Parks and Wildlife Department (TPWD). 2007. “Leatherback Sea Turtle (Dermochelys 

20 coriacea).” Texas Parks and Wildlife Department, Austin, Texas. Accessed November 8, 2009 

21 at 

22 http://www.tpwd.state.tx.us/huntwild/wild/species/endang/animals/reptiles_amphibians/lethback.

23 phtml. Accession No. ML100650007. 

24 Texas Parks and Wildlife Department (TPWD). 2009a. Telephone call to Tonya Wiley (Texas 

25 Parks and Wildlife Department, Fisheries Outreach Specialist, Coastal Fisheries Division) from 

26 Christa Woodley (Pacific Northwest National Laboratory, Research Scientist), “Smalltooth 

27 sawfish in southern Texas”, March 18, 2009. 

28 Texas Parks and Wildlife Department (TPWD). 2009b. “Wildlife Fact Sheets.” Texas Parks 

29 and Wildlife Department, Austin, Texas. Accessed January 22, 2010 at 

30 http://www.tpwd.state.tx.us/huntwild/wild/species. Accession No. ML100650007. 

31 Texas Parks and Wildlife Department (TPWD). 2009c. “2009-2010 Texas Commercial Fishing 

32 Guide.” Texas Parks and Wildlife Department, Austin, Texas. 
Appendix F 

Draft NUREG-1937 F-32 March 2010 

1 Texas Parks and Wildlife Department (TPWD). 2009d. “Kemp’s Ridley Sea Turtle.” Texas 

2 Parks and Wildlife Department, Austin, Texas. Accessed December 1, 2009 at 

3 http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_bk_w7000_0013_kemps_ridley_s

4 ea_turtle.pdf. Accession No. ML100650007. 

5 Turtle Expert Working Group. 1998. “An Assessment of the Kemp’s Ridley (Lepidochelys 

6 kempii) and Loggerhead (Caretta caretta) Sea Turtle Populations in the Western North Atlantic.” 

7 NOAA Technical Memorandum NMFS-SEFSC-406, U.S. Department of Commerce, Miami, 

8 Florida. 

9 U.S. Army Corps of Engineers (Corps). 2005. Galveston District Projects: Mouth of the 

10 Colorado River. U.S. Army Corps of Engineers, Galveston District, Galveston, Texas. 

11 Accessed December 16, 2009 at 

12 http://www.swg.usace.army.mil/items/coloradoriver/default.asp. Accession No. ML100650007. 

13 U.S. Army Corps of Engineers (Corps). 2007. Draft Environmental Impact Statement for 

14 Calhoun County Navigation District’s Proposed Matagorda Ship Channel Improvement Project 

15 Calhoun and Matagorda Counties, Texas. Document No. 060146, U.S. Army Corps of 

16 Engineers, Galveston District, Galveston, Texas. 

17 U.S. Army Corps of Engineers (Corps). 2008. Final Environmental Impact Statement for the 

18 Proposed Port Freeport Channel Widening, Brazoria County, Texas. U.S. Army Corps of 

19 Engineers, Galveston District, Galveston, Texas. 

20 U.S. Army Corps of Engineers (Corps). 2010. “USACE Sea Turtle Data Warehouse.” U.S. 

21 Army Corps of Engineers, Galveston District, Galveston, Texas. Accessed January 29, 2010 at 

22 http://el.erdc.usace.army.mil/seaturtles. Accession No. ML100650007. 

23 U.S. Fish and Wildlife Service (FWS). 1980. “Selected vertebrate endangered species of the 

24 seacoast of the United States.” FWS/OBS-80/01. U.S. Fish and Wildlife Service, Biological 

25 Services Program, Washington, D.C. 

26 U.S. National Park Service (NPS). 2009. “Padre Island National Seashore: Current Sea Turtle 

27 Nesting Season.” National Park Service, U.S. Department of Interior. Accessed November 8, 

28 2009 at http://www.nps.gov/pais/naturescience/current-season.htm. Accession No. 

29 ML100650007. 

30 U.S. Nuclear Regulatory Commission (NRC). 1975. Final Environmental Statement Related to 

31 the Proposed South Texas Project Units 1 & 2. NUREG-75/019, Washington, D.C. 

32 U.S. Nuclear Regulatory Commission (NRC). 1986. Final Environmental Statement Related to 

33 the Operation of South Texas Project, Units 1 and 2. NUREG-1171, Washington, D.C. 
 Appendix F 

March 2010 F-33 Draft NUREG-1937 

1 Wilber, D.H. and R. Bass. 1998. “Effect of the Colorado River Diversion on Matagorda Bay 

2 Epifauna.” Coastal and Shelf Science 47:309-318. 

3 Williams, J.A., and M.L. Renaud. 1998. “Tracking of Kemp’s ridley (Lepidochelys kempii) and 

4 green (Chelonia mydas) sea turtles in the Matagorda Bay System, Texas.” In: S. Epperly and J. 

5 Braun (compilers), Proceedings of the 17th Annual Sea Turtle Symposium. NOAA Technical 

6 Memorandum NMFS SEFSC-415, U.S. Department of Commerce, Miami, Florida. 
Appendix F 

Draft NUREG-1937 F-34 March 2010 

1 Essential Fish Habitat 

2 Assessment 

3 

4 

5 National Marine Fisheries Service

6 

7 South Texas Project Electric Generating Station Units 3 and 4 

8 

9 

10 U.S. Nuclear Regulatory Commission Combined License Application 

11 Docket Nos. 52-012 and 52-013 

12 

13 

14 U.S. Army Corps of Engineers Permit Application 

15 

16 

17 

18 Matagorda County, Texas 

19 

20 

21 March 2010

22 

23 

24 U.S. Nuclear Regulatory Commission 

25 Rockville, Maryland 

26 

27 U.S. Army Corps of Engineers 

28 Galveston District 
Appendix F 

March 2010 F-35 Draft NUREG-1937 

1 1.0 Introduction 

2 The 1996 amendments to the Magnuson-Stevens Fishery Conservation and Management Act 

3 (MSA) (16 USC 1801 et seq.) and amendments by the Sustainable Fisheries Act of 1996 

4 (Public Law 104-297) recognized that habitat is important for the protection of healthy fisheries 

5 and established procedures to identify, conserve, and enhance essential fish habitat (EFH) for 

6 Federally managed fish and shellfish species (GMFMC 2004). EFH is defined as “those waters 

7 and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity” (16 USC 

8 1801 et seq.; NMFS 2004). Federal agencies must consult with the Secretary of Commerce on 

9 all actions or proposed actions that are authorized, funded, or undertaken by the agency that 

10 may adversely affect EFH (NMFS 2004). Identifying EFH is an essential component in the 

11 development of fishery management plans (FMPs) to evaluate the effects of habitat loss or 

12 degradation on fishery stocks and to take actions to mitigate such damage. This responsibility 

13 was expanded by the National Marine Fisheries Service (NMFS) to ensure additional habitat 

14 protection (NMFS 1999). The consultation requirements of Section 305(b) of the MSA provide 

15 that Federal agencies consult with the Secretary of Commerce on all actions, or proposed 

16 actions, authorized, funded, or undertaken by the agency, that may adversely affect EFH. 

17 The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from STP Nuclear 

18 Operating Company (STPNOC) for two combined construction permits and operating licenses 

19 (combined licenses or COLs) to construct and operate two new nuclear reactors at the South 

20 Texas Project Electric Generating Station (STP) site in Matagorda County, Texas, 

21 approximately 12 mi south-southwest of Bay City, Texas (Figure 1). The STP site is located 

22 adjacent to the Colorado River, upstream of its confluence with the Gulf Intracoastal Waterway 

23 (GIWW). STPNOC submitted the COL application to the NRC on September 20, 2007. The 

24 STP site and existing facilities (Units 1 and 2) are owned by NRG South Texas LP (NRG), City 

25 Public Service Board of San Antonio, Texas (CPS Energy), and the City of Austin, Texas. 

26 STPNOC plans for the proposed STP Unit 3 to be owned by Nuclear Innovation North America 

27 (NINA) South Texas 3 LLC and CPS Energy, and the proposed STP Unit 4 to be owned by 

28 NINA South Texas 4 LLC and CPS Energy (STPNOC 2009a). Concurrent with the NRC’s 

29 review, the U.S. Army Corps of Engineers (Corps) is reviewing STPNOC’s application for a 

30 Department of the Army (DA) Permit pursuant to Section 10 of the Rivers and Harbors 

31 Appropriation Act of 1899 (33 USC Sec. 403) and Section 404 of the Clean Water Act (CWA) 

32 (33 USC 1344) to perform site preparation activities and construct supporting facilities for two 

33 proposed new nuclear reactors at the STP site (Units 3 and 4). The Corps is a cooperating 

34 agency with the NRC to ensure that the information presented in the environmental impact 

35 statement (EIS) is adequate to fulfill the requirements of Corps regulations; the CWA Section 

36 404(b)(1) Guidelines, which contain the substantive environmental criteria used by the Corps in 

37 evaluating discharges of dredged or fill material into waters of the United States; and the Corps 

38 public interest review process. The NRC and the Corps have formed a combined review team 
Appendix F 

Draft NUREG-1937 F-36 March 2010

1 

2 Figure 1. Location of the STP Site and General Land Use Classification for the Region 

3 and prepared this EFH assessment to support their joint consultation with the NMFS in 

4 accordance with the MSA. The Corps permit decision will be made following issuance of the 

5 final EIS for building the two new reactors at the STP site. 

6 The proposed project has the potential to cause temporary and permanent adverse impacts to 

7 spawning, nursery, forage, and shelter activities and habitats. The review team has evaluated 

8 potential impacts on the designated EFH and Federally-managed fish and shellfish species in 

9 the vicinity of STP based on information from communications with the NMFS (Southeast 

10 Regional Office, Habitat Conservation Division, Gulf Branch) and review of information on the 

11 Gulf of Mexico Fishery Management Council’s final EIS on the generic EFH amendments 

12 (GMFMC 2004). In addition, the EFH mapper tool was used to visualize the extent of potential 

13 designated EFH in the vicinity of the STP site, with an understanding that the area may be 

14 within known areas of spatial data quality issues (NMFS 2009). Matagorda Bay, the GIWW, 

15 and the Colorado River extending up to the bridge at FM 521 (at approximately navigable mile 
Appendix F 

March 2010 F-37 Draft NUREG-1937 

1 marker [NMM] 10, upstream of the confluence of the Colorado River and the GIWW) are within 

2 Ecoregion 5 of the designated EFH by the Gulf of Mexico Fishery Management Council’s FMP 

3 (GMFMC 2004; NMFS 2009). Ecoregion 5 extends from Freeport, Texas to the Mexico border. 

4 FMPs for coastal migratory pelagics, reef fish, red drum, shrimp, and stone crab fisheries 

5 include the Colorado River, the GIWW and Matagorda Bay within the vicinity of STP include 

6 coastal migratory pelagic, reef fish, red drum, shrimp, and stone crab (GMFMC 2004). This 

7 EFH assessment examines the potential impacts of the proposed actions on eight species: king 

8 mackerel (Scomberomorus cavalla), Spanish mackerel (S. maculates), gray snapper (Lutjanus 

9 griseus), red drum (Sciaenops ocellatus), brown shrimp (Farfantepenaeus aztecus), pink shrimp 

10 (F. duorarum), white shrimp (Litopenaeus setiferus), and Gulf stone crab (Menippe adina). 

11 These species are described in Section 4.0, and the impacts to them and their EFH, including 

12 their prey, are discussed in Section 5.0. 

13 2.0 STP Site Description 

14 The 12,220-ac STP site currently contains two pressurized water reactors (Units 1 and 2) and 

15 their associated facilities, which occupy approximately 300 ac (Figure 2). Existing Units 1 and 2 

16 share a 7000-ac Main Cooling Reservoir (MCR). Approximately 58 percent of the 12,220-ac 

17 STP site is covered in water (STPNOC 2009a). The MCR is an engineered cooling reservoir 

18 originally sized for four nuclear units and currently dissipates heat as part of a closed-cycled 

19 cooling system for the existing Units 1 and 2. Water loss from the MCR through evaporation, 

20 seepage, and discharge is made up from the Colorado River. Colorado River water is pumped 

21 from the Reservoir Makeup Pumping Facility (RMPF) into the MCR. Operation of the RMPF 

22 requires periodic maintenance dredging of the river in the immediate vicinity. When the total 

23 dissolved solids concentration in the MCR exceeds operating criteria, water is released through 

24 a discharge structure on the Colorado River downstream from the RMPF. However, STPNOC 

25 has only discharged water from the MCR into the Colorado River once during operation of Units 

26 1 and 2 (STPNOC 2009a). There is a barge slip near the downstream shoreline of the RMPF 

27 that was used for the construction of Units 1 and 2 and could be required in the future for 

28 continued operation of Units 1 and 2. Both existing units would continue to operate during the 

29 site preparation activities, construction, and operation of the proposed Units 3 and 4, and the 

30 proposed two new units would share many of the same systems for cooling, including the use of 

31 the existing RMPF, MCR, and discharge structure, and transmission of power. 
Appendix F 

Draft NUREG-1937 F-38 March 2010

1 A diverse aquatic community has developed over time since the construction of the MCR. The 

2 organisms are likely survivors of entrainment at the RMPF from the Colorado River, but it is 

3 unclear if these organisms are reproducing in the MCR. The organisms are not available for 

4 harvest as there is no public access to the MCR and STPNOC has only evaluated the aquatic 

5 community in the MCR twice (during an employee fishing tournament in 1994 and during an 

6 aquatic community survey during 2007-2008) (ENSR 2008a; STPNOC 2009a). For the purpose 

7 of this assessment and consultation, the entrained aquatic community will be considered lost to 

8 the environment and, therefore not evaluated further. Within the vicinity of the STP site, the 

9 major aquatic communities occur in the Colorado River, Matagorda Bay and the associated 

10 GIWW (Figure 3). The segment of the Colorado River adjacent to the STP site is used for 

11 recreational boating and fishing, as well as shipping to upstream ports. Matagorda Bay is used 

12 for commercial fishing and shipping as well as for recreational activities. The GIWW is used for 

13 shipping as well as for some recreational activities. Designated EFH occurs in the lower 

14 Colorado River, Matagorda Bay, and the GIWW, but there are no habitat areas of particular 

15 concern in any of those water bodies (GMFMC 2004). 

16 2.1 Colorado River 

17 The Colorado River is one of the largest river systems in Texas. The river is approximately 

18 862 mi long, extending from the high plains to the coastal marshes in Matagorda County. The 

19 segment of the river near the STP site, between Bay City and the GIWW, is a diverse, tidal, 

20 fluvial system that meanders through the coastal plain providing freshwater, sediments, and 

21 nutrients to Matagorda Bay (ENSR 2008a). The substrate and bathymetry of the Colorado 

22 River from the RMPF to the confluence with the GIWW is not well characterized. The Corps’ 

23 Galveston District reported in December 2009 that the Colorado River Channel from navigable 

24 mile 0 (GIWW) to the turning Basin near Bay City had a minimum width of 100 ft, minimum 

25 depth of 9 ft. In the vicinity of the STP site, the left quarter, middle half and right quarter channel 

26 had average depths of 2.1 ft, 3.8 ft, and 4.5 ft, respectively (all measurements were provided at 

27 the mean low tide datum) (Corps 2009a). The width of the river near the RMPF is 

28 approximately 900 ft. The west bank of the river channel drops off quickly to a shelf that 

29 extends approximately 400 ft, then drops again to the thalweg (lowest point in the river channel) 

30 approximately 600 ft from the west bank. The east bank of the river channel drops to the 

31 thalweg within 300 ft from the east bank. The bathymetry of the river at the discharge structure 

32 is not known, but the width is approximately 300 ft (STPNOC 2009a). The river’s bottom habitat 

33 in the vicinity of the STP site is described as un-vegetated, estuarine benthic habitats with mud 

34 and sand substrate (STPNOC 2009a). 
Appendix F 

March 2010 F-39 Draft NUREG-1937 

1 

2 Figure 2. STP Site and Proposed Plant Footprint (STPNOC 2009a) 
Appendix F 

Draft NUREG-1937 F-40 March 2010

1 

2 Figure 3. Location of the STP Site and Major Important Aquatic Resources 
Appendix F 

March 2010 F-41 Draft NUREG-1937 

1 Today, there is no natural direct connection between the Gulf of Mexico and the Colorado River. 

2 Aquatic resources associated with the Gulf of Mexico can move into and out of the Colorado 

3 River through the navigation channel (that connects the Gulf to the GIWW), and through the 

4 GIWW or a diversion channel into Matagorda Bay. The major shipping channels connect to the 

5 GIWW in the northeast through the Freeport Harbor Channel (Corps 2008) and in the southwest 

6 through the Matagorda Ship Channel (Corps 2007). 

7 The lower Colorado River has been studied on a very limited basis with specific studies 

8 conducted in 1974, 1976, 1983, and 1984 associated with the licensing of existing STP Units 1 

9 and 2 (NRC 1975, 1986) and in 2007-2008 associated with the licensing of the proposed Units 3 

10 and 4 (ENSR 2008a). The flow of the Colorado River and the Gulf of Mexico has changed with 

11 development of the area since the 1920s. The course of the river prior to the 1920s flowed 

12 directly into Matagorda Bay. In the 1930s, a delta began to form in the mouth of the river, and a 

13 channel was constructed through the Matagorda Peninsula, shunting the river flows away from 

14 the bay directly into the Gulf of Mexico. Then, in the 1950s, the Tiger Island Channel was 

15 constructed through the west side of the delta, re-establishing flow between the river and the 

16 bay. The Corps constructed a deeper river diversion channel northwest of the Tiger Island 

17 Channel in 1990. In 1991, two dams were constructed to divert the river flow, including one 

18 across the Tiger Island Channel (called the Tiger Island Cut dam) and a diversion dam across 

19 the river channel on Matagorda Peninsula. By July 1992, all of the Colorado River flow was 

20 diverted into Matagorda Bay through the GIWW and the newly constructed diversion channel. 

21 The changes in freshwater inflow to Matagorda Bay over time, and the changes to flow from the 

22 Gulf of Mexico into the Colorado River have likely influenced the aquatic communities 

23 historically in the river and bay (Wilber and Bass 1998). 

24 Changes in the aquatic community over time in the Colorado River were evaluated using the 

25 results of the 1974, 1983, 1984, and 2007-2008 studies (NRC 1975, 1986; ENSR 2008a). The 

26 sampling locations and gear types varied with each study, making some comparisons more 

27 difficult. Trawl samples collected from the GIWW to the STP site in 1974 showed a moderately 

28 diverse species community for the lower river based on measures for species richness, 

29 diversity, and evenness. All three measures were slightly lower than those in similar segments 

30 of the river compared to the 2007-2008 study, suggesting that the diversity of aquatic species is 

31 greater now than in the past. Data collected during 1974 examining specific segments also 

32 indicated a diverse species community for all three segments. The 1983-1984 trawl and seine 

33 data indicated overall lower species richness, diversity, and evenness relative to the present 

34 data (ENSR 2008a). Rerouting of the lower Colorado River has likely contributed to these 

35 changes in diversity of aquatic species. 

36 The number and assortment of organisms collected during the 2007-2008 study indicate that 

37 this portion of the lower Colorado River supports a diverse assemblage of fauna, many of which 

38 would be prey for species with designated EFH in the area (Table 1 on the following page). The 
Appendix F 

Draft NUREG-1937 F-42 March 2010

1 regular occurrence of both freshwater and saltwater species, the range of macroinvertebrate 

2 and finfish fauna, and the sheer number of species captured among various sampling gears and 

3 river reaches provide evidence of a dynamic ecosystem. There was a low to moderate level of 

4 similarity between the current 2007-2008 faunal communities and the historic communities 

5 (1974 and 1983-1984) (ENSR 2008a). 

6 The 2007-2008 survey of the Colorado River did not include sampling for younger life stages 

7 (e.g., ichthyoplankton). In addition, there were no reports during the 1974, 1983, 1984, and 

8 2007-2008 studies of any submerged aquatic vegetation (SAV) in the Colorado River from the 

9 GIWW to the bridge with FM 521 (NRC 1975, 1986; ENSR 2008a). 

10 

11 Table 1. Fish and Shellfish Collected in the Colorado River by Gear Type, 2007-2008 

12 (ENSR 2008b) 

Common Name Scientific Name 

Bag 

Seine

Gill 

Net 

Hoop 

Net Trawl Total 

alligator gar Atractosteus spatula 2 2 13 17 

Atlantic brief squid Lolliguncula brevis 1 30 31 

Atlantic croaker Micropogonias undulatus 562 1 482 1045 

Atlantic cutlassfish Trichiurus lepturus 6 6 

Atlantic seabob Xiphopenaeus kroyeri 127 127 

Atlantic spadefish Chaetodipterus faber 3 3 

Atlantic threadfin Polydactylus octonemus 6 6 

bay anchovy Anchoa mitchilli 24 264 288 

bay whiff Citharichthys spilopterus 15 2 17 

bayou killifish Fundulus pulvereus 3 3 

black drum Pogonias cromis 1 1 1 1360 1363 

blackcheek tonguefish Symphurus plagiusa 3 3 

blue catfish Ictalurus furcatus 51 22 3 677 753 

blue crab Callinectes sapidus 190 2 3 77 272 

bluegill Lepomis macrochirus 3 3 

brown shrimp Farfantepenaeus aztecus 264 192 456 

bull shark Carcharhinus leucas 6 6 

channel catfish Ictalurus punctatus 22 2 6 30 

cichlid Cichlasoma spp. 16 16 

crayfish Procambarus sp. 1 1 

crevalle jack Caranx hippos 2 2 

cyprinid sp. Cyprinidae 1 1 
Appendix F 

March 2010 F-43 Draft NUREG-1937 

Table 1. (contd)

Common Name Scientific Name 

Bag 

Seine

Gill 

Net 

Hoop 

Net Trawl Total 

diamond killifish Adinia xenica 11 11 

flathead catfish Pylodictis olivaris 2 2 

freshwater goby Ctenogobius shufeldti 9 9 

gafftopsail catfish Bagre marinus 9 183 192 

gizzard shad Dorosoma cepedianum 8 2 52 62 

grass carp Ctenopharyngodon idella 2 1 3 

grass shrimp Palaemonetes pugio 1762 1762 

gray (mangrove) snapper Lutjanus griseus 1 1 

Gulf killifish Fundulus grandis 15 15 

Gulf menhaden Brevoortia patronus 2960 5 2 1076 4043 

hardhead catfish Ariopsis felis 1 1 252 254 

Harris mud crab Rhithropanopeus harrisii 1 1 

inland silverside Menidia beryllina 6 6 

killifish sp. Fundulus sp. 5 5 1 

ladyfish Elops saurus 2 1 3 

lesser blue crab Callinectes similis 1 5 6 

lined sole Achirus lineatus 3 3 

longnose gar Lepisosteus osseus 1 1 

mosquitofish Gambusia affinis 1 1 

naked goby Gobiosoma bosc 3 3 

pigfish Orthopristis chrysoptera 1 1 

pinfish Lagodon rhomboides 11 11 

rainwater killifish Lucania parva 2 2 

red drum Sciaenops ocellatus 8 8 38 25 79 

red eared slider Trachemys scripta elegans 1 1 

river shrimp Macrobrachium ohione 10 5 15 

rough silverside Membras martinica 17 17 

sailfin molly Poecilia latipinna 150 150 

sand seatrout Cynoscion arenarius 22 5 294 321 

sharptail goby Oligolepis acutipennis 39 39 

sheepshead Archosargus probatocephalus 14 1 6 48 69 

sheepshead minnow Cyprinodon variegatus 79 7 86 

shiner Notropsis spp. 2 2 
Appendix F 

Draft NUREG-1937 F-44 March 2010

Table 1. (contd)

Common Name Scientific Name 

Bag 

Seine

Gill 

Net 

Hoop 

Net Trawl Total 

silver jenny Eucinostomus gula 2 2 

silver perch Bairdiella chrysoura 350 350 

smallmouth buffalo Ictiobus bubalus 32 5 37 

Southern flounder Paralichthys lethostigma 2 2 3 12 19 

southern stingray Dasyatis americana 1 1 

spot croaker Leiostomus xanthurus 88 1 156 245 

spotfin mojarra Eucinostomus argenteus 3 5 8 

spotted gar Lepisosteus oculatus 1 1 10 1 13 

spotted seatrout Cynoscion nebulosus 4 53 57 

star drum Stellifer lanceolatus 86 86 

striped mullet Mugil cephalus 1676 1 1 1678 

threadfin shad Dorosoma petenense 4 7 11 

violet goby Gobioides broussonnetii 2 2 

white mullet Mugil curema 181 2 183 

white shrimp Litopenaeus setiferus 584 2870 3454 

Total 8806 106 99 8760 17771 

1 2.2 Matagorda Bay 

Matagorda Bay is 300 mi2 2 formed by a 45-mi-long barrier island-peninsula complex that is 

3 parallel to the Gulf of Mexico and is located to the southeast of the STP site (STPNOC 2009a). 

4 The Matagorda Bay system is considered the second largest of the seven major bay systems in 

5 Texas (LCRA 2006). The bay is connected to the waters on the site as it receives water 

6 discharged from the site through drainage ditches and channels into Little Robbins Slough and 

7 downstream marshes and also through the discharge facility into the Colorado River; water in 

8 the slough, marshes, and river flows into the bay. As mentioned above, the Colorado River 

9 flows by STP then across the GIWW into a diversion channel into the bay. The bay is described 

10 as the Matagorda Bay system, and it is the third largest estuary on the Texas coast. The bay 

11 system includes Lavaca, East Matagorda, Keller, Carancahua, and Tres Palacios bays (Corps 

12 2007). 

13 The Colorado River and associated discharge basin is a major contributor of freshwater to 

14 Matagorda Bay (LCRA 2006). Salinity in the bay system depends on the tidal exchange and 

15 freshwater inflow. There is little vertical stratification since the bay is relatively shallow and 

16 mixing occurs from consistent winds (LCRA 2006). Salinity at the Matagorda Ship Channel is 
Appendix F 

March 2010 F-45 Draft NUREG-1937 

1 higher than in the northeastern end of the bay, closest to the diversion channel with the 

2 Colorado River, decreasing from 27 to 18 parts per trillion (ppt) (Kim and Montagna 2009). 

3 The aquatic community of Matagorda Bay system includes organisms in the open water areas 

4 as well as organisms over hard substrates (including oyster reefs and offshore sands). In the 

5 open water areas of the bay, phytoplankton (e.g., algae) are the major primary producers that 

6 are the main food source for zooplankton (e.g., small crustaceans), fish and benthic organisms 

7 (e.g., mollusks). 

8 3.0 Proposed Federal Actions 

9 The proposed Federal actions are (1) NRC’s issuance of two COLs for the construction and 

10 operation of two new nuclear reactors at the proposed STP site pursuant to Title 10 of the Code 

11 of Federal Regulations (CFR) 52.97, and (2) the Corps’ issuance of a DA permit pursuant to 

12 Section 404 of the CWA and Section 10 of the Rivers and Harbors Act of 1899. 

13 The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

14 “construction” in 10 CFR 50.10 and 51.4 to activities that fall within its regulatory authority. 

15 Many of the activities required to build a nuclear power plant are not part of the NRC action to 

16 license the plant. Activities associated with building the plant that are not within the purview of 

17 the NRC action are grouped under the term “preconstruction.” Preconstruction activities include 

18 clearing and grading, excavating, erecting of support buildings and transmission lines, and other 

19 associated activities. These preconstruction activities may take place before the application for 

20 a COL is submitted, during the staff’s review of a COL application, or after a COL is granted. 

21 Although preconstruction activities are outside the NRC’s regulatory authority, many of them are 

22 within the regulatory authority of local, State, or other Federal agencies. The distinction 

23 between construction and preconstruction is not carried forward in this EFH assessment, and 

24 both are being discussed together as construction for the purposes of the NRC/Corps joint EFH 

25 consultation. 

26 The Corps action is the decision whether to issue a permit pursuant to Section 404 of the Clean 

27 Water Act and Section 10 of the Rivers and Harbors Appropriation Act of 1899 for proposed 

28 structures in and under navigable waters and the discharge of dredged, excavated, and/or fill 

29 material into waters of the United States, including jurisdictional wetlands.

30 Prerequisites to certain construction activities include, but are not limited to, documentation of 

31 existing site conditions within the STP site and acquisition of the necessary permits (e.g., COLs, 

32 local building permits, CWA Section 402(p) Texas Pollutant Discharge Elimination System 

33 (TPDES) permit, Construction and Industrial Stormwater Permits, a DA permit, Coastal 

34 Consistency Determination per the Coastal Zone Management Act [16 USC 1451, et seq.], and 
Appendix F 

Draft NUREG-1937 F-46 March 2010

1 a CWA Section 401 Certification). After these prerequisites are completed, planned 

2 construction activities could proceed and would include all or some or all the activities pursuant 

3 to 10 CFR 50.10(e)(1). Following construction, planned operation of the new reactors would be 

4 authorized if the Commission finds, under 10 CFR 52.103(g), that all acceptance criteria in the 

5 COLS are met. 

6 Briefly, the construction and operation activities that could affect Federally-managed fish and 

7 shellfish species based on habitat affinities, life-history characteristics, and the nature and 

8 spatial and temporal considerations of the proposed actions are as follows: 

9 Construction 

10  Refurbishment of the existing RMPF at the Colorado River 

11  Expansion of the barge slip on the Colorado River 

12  Barging heavy equipment and materials to STP site 

13 Operation

14  Operation of RMPF on Colorado River 

15  Operation of discharge structure on Colorado River 

16  Maintenance dredging of RMPF and barge slip 

17 The footprint for proposed Units 3 and 4 would be approximately 2000 ft northwest of existing 

18 Units 1 and 2 (STPNOC 2009a). The cooling system would be the largest interface from the 

19 plant to the environment. The proposed new units cooling system would include the same 

20 systems currently in use for Units 1 and 2: RMFP, MCR, and discharge structure on the 

21 Colorado River. With the addition of the two proposed new units, additional makeup water 

22 would be provided to the MCR through refurbished intakes from the Colorado River at the 

23 RMPF. A portion of this makeup water would be returned to the environment via the discharge 

24 structure. The remaining portion of the water would be available for release into the 

25 atmosphere via evaporative cooling of the MCR. Groundwater is planned as the source for 

26 makeup water for the proposed Units 3 and 4 ultimate heat sink (UHS), service water for the 

27 power plants, and water for sanitary and potable water systems. The power transmission 

28 system for proposed Units 3 and 4 would not require new transmission lines or corridors, but it 

29 would use five of the nine 345-kV transmission lines that currently connect to existing STP Units 

30 1 and 2, and involve upgrading a 20-mi section of the existing 345-kV Hillje transmission line 

31 (STPNOC 2009a). Below is further description of the major features of the proposed site. 
Appendix F 

March 2010 F-47 Draft NUREG-1937 

1 3.1 Circulating Water Intake System 

2 The circulating water intake system for the proposed new units consists of two parts. The 

3 RMPF pumps water from the Colorado River into the MCR. A new circulating water intake 

4 system (CWIS) would be constructed within the MCR for use by the proposed new units for 

5 cooling purposes. 

6 Reservoir Makeup Pumping Facility. The RMPF is located along the west bank of the Colorado 

7 River and is an existing facility that would be modified solely within its existing footprint to supply 

8 makeup water to the MCR for operating all four nuclear units. The facility is located near NMM 

9 8 on the Colorado River upstream from the confluence with the GIWW, and the structure is 

10 “flush” to the river bank with no projecting structures into the river. The RMPF withdraws water 

11 through a 406-ft-long intake along the shoreline. Water from the river flows through trash racks 

12 (with 4-in. spacing between the bars), then through traveling screens, and then over a weir into 

13 an embayment before entering the pumps into a pipeline delivering water to the MCR. There 

14 are 18 travelling screens, each of 13.5 ft width, with the bottom of the screens situated at 10 ft 

15 below mean sea level (MSL) in the Colorado River (water surface elevation in the Colorado 

River at 0 ft MSL). The area of the 18 screens would be 2430 ft2 16 . The existing traveling 

17 screens have a 3/8-in. mesh, and operate intermittently to coincide with the intermittent 

18 withdrawal of river water. For the purposes of this assessment, the review team is assuming 

19 that modifications to the RMPF would result in trash bars and travelling screens with identical 

20 characteristics to those that exist currently at the RMPF. 

21 Fish collected on the traveling screens can be returned to the river via the existing sluice and 

22 fish bypass pipe. The fish return outfall is at the downstream end of the intake structure, 

23 approximately 2 ft below normal water elevation (STPNOC 2009a). During high-flow conditions, 

24 the accumulation of debris on the traveling screens is too high to open the fish bypass system, 

25 and screenwash discharge is directed to the sluice trench catch baskets rather than back to the 

26 river. Generally, the fish bypass system is closed when river flows are greater than 4000 cubic 

27 feet per second (cfs), and the system is occasionally closed when flows are greater than 

28 2000 cfs (which has occurred from 2001-2006 only 7 percent of the time) (STPNOC 2009a, 

29 2008b). Impingement mortality can be reduced based on the procedures for operating the 

30 RMPF. Operators at the RMPF are required to monitor for increased impingement rates on the 

31 traveling screens, and factors like river flow, salinity, and observations of impingement are used 

32 to determine if pumping should continue (STPNOC 2009a, 2008a, 2008b). 

33 STPNOC has stated that periodic dredging in the future would be conducted in front of the 

34 RMPF (STPNOC 2009a). These activities are currently covered by existing permits with the 

35 Corps for the operation of Units 1 and 2. In addition, the Corps would be conducting 

36 maintenance dredging of the navigation channel in the river in the vicinity of the discharge 

37 structure and RMPF (Corps 2009a). Based on past dredging events, the substrate that would 
Appendix F 

Draft NUREG-1937 F-48 March 2010

1 be dredged is predominantly silty-clay soils with approximately 6 in. of “detritus and silt soils” on 

2 the surface. Dredged material would be placed in the designated onsite location that is 

3 currently used for storage of material removed during maintenance activities with the RMPF 

4 (STPNOC 2009b). The area to be dredged would be approximately one ac. 

5 Main Cooling Reservoir. The MCR is a 7000-ac engineered impoundment enclosed by an 

6 engineered embankment. STPNOC has indicated that, at the maximum normal operating pool 

7 of 49 ft MSL, the reservoir contains approximately 202,700 ac-ft of water. The CWIS for Units 3 

8 and 4 would be located within the MCR. This CWIS would be a 131-ft by 392-ft concrete 

9 structure and would house eight pumps for the two proposed units. The structure would include 

10 trash racks and traveling screens (again, the review team assumes characteristics would be 

11 identical to those described above for RMPF trash racks and screens). Pipes carrying water 

12 from the plant would run to the turbine building. As for existing Units 1 and 2, the circulating 

13 water discharge structure for Units 3 and 4 would also be located within the MCR. The water 

14 return from Units 3 and 4 turbine buildings would enter the MCR through a new discharge 

15 structure within the MCR. The simple discharge structure would include a weir and a stilling 

16 basin to dissipate the velocity of the returning water before it enters the MCR. Dikes within the 

17 MCR increase the travel time that cooling water from the circulating water system would 

18 experience. The reject heat from the existing and proposed units would enter the MCR in the 

19 form of sensible heat in circulating water in the MCR. As the heated water circulates in the 

20 MCR, the heat is gradually dissipated to the environment through evaporation, conduction, and 

21 long-wave radiative cooling. 

22 A diverse aquatic community exists in the MCR, but the organisms are not available for harvest. 

23 No public access or use of the MCR exists. In addition, the Corps has determined that the MCR 

24 is not considered waters of the United States (Corps 2009b), and the Texas Commission on 

25 Environmental Quality (TCEQ) has stated that the MCR is not considered waters of the State 

26 (TCEQ 2007; STPNOC 2008a). 

27 The aquatic community in the MCR was evaluated in 2007-2008 (ENSR 2008b). A total of 

28 11,605 finfish and invertebrates were collected over the duration of the sampling program for 

29 the MCR. The most common fish species collected were with seines, and included threadfin 

30 shad (Dorosoma petenense, 62 percent), inland silverside (Menidia beryllina, 18 percent), rough 

31 silverside (Membras martinica, 12 percent), and blue catfish (Ictalurus furcatus, three percent). 

32 The macroinvertebrates were characterized using plankton tows, and a total of 5362 organisms 

33 were collected in the MCR. The most common species (84 percent of all samples) collected 

34 were Harris mud crab larvae (Rhithropanopeus harrisii), and more than 99 percent of all 

35 sampled organisms were crustaceans (ENSR 2008b). 

36 The same study also evaluated the impinged and entrained aquatic resources by the CWIS in 

37 the MCR for Units 1 and 2 (ENSR 2008b). Overall, very few fish species were impinged (less 

38 than 50 percent) or entrained (less than one percent). A total of 3982 organisms representing 
Appendix F 

March 2010 F-49 Draft NUREG-1937 

1 25 fish species, seven invertebrate species, and one reptile species were collected during 

2 impingement sampling. Impingement rates were highest during the winter and early spring 

3 months. The dominant species collected in the impingement samples were threadfin shad 

4 (42 percent), Harris mud crab (24 percent), blue crab (Callinectes sapidus, 24 percent), Atlantic 

5 croaker (Micropogonias undulates, 5 percent), and white shrimp (Litopenaeus setiferus, 

6 3 percent). A total of 207,696 organisms representing nine different fish families and 

7 12 different invertebrate classes were collected during entrainment sampling. Entrainment rates 

8 were highest during the spring months. The dominant species collected in the entrainment 

9 samples were Harris mud crab (68 percent), unidentified decapods (15 percent), and 

10 harpacticoid copepods (6 percent). Less than one percent of the total composition of entrained 

11 organisms was fish eggs (ichthyoplankton) (ENSR 2008a). 

12 Water quality sampling in the MCR showed that there were seasonal and spatial changes within 

13 the reservoir. Water temperature was the highest at the cooling water discharge area and 

14 gradually decreased by approximately 10°F as the water traveled through the internal levee 

15 system to the CWIS. The temperature through the water column did not vary much: 65.3°F to 

16 96.1°F for surface measurements, and 65.1°F to 95°F for bottom measurements. Through the 

17 year, the temperature did vary. Temperature data from trawl samples increased from an 

18 average 86.4°F in May to 93.4°F in August and then decreased in October to 76.8°F and then to 

19 70.5°F in February. Salinity remained constant throughout the reservoir and the water column 

20 at approximately 1.6 ppt. 

21 3.2 Cooling Water Discharge System 

22 Discharge from the MCR enters the Colorado River through a series of seven 36-in.-diameter 

23 pipes directed 45 degrees from the downstream western shore. The discharge structure is 

24 located about 2 mi downstream of the RMPF, located at NMM 6 on the Colorado River 

25 upstream from the confluence with the GIWW. The pipes entering the river are spaced 250 ft 

26 apart. Discharge that is released from the MCR approaches the diffusers through a 78-in.-

27 diameter pipeline. As mentioned above, STPNOC has only released water through the 

28 discharge system once during the operation of Units 1 and 2. No change to the existing 

29 discharge structure is proposed for the new nuclear units (STPNOC 2009a). 

30 3.3 Barging 

31 The existing barge slip that was built for Units 1 and 2 would be re-excavated and expanded for 

32 use with the proposed Units 3 and 4 (STPNOC 2009c). Delivery of major equipment for Units 3 

33 and 4 would be accomplished by barging the material to the site and would include heavy 

34 equipment (prefabricated modules, large components fabricated overseas) and bulk 

35 commodities (e.g., aggregate or structural fill materials). STPNOC has stated that no firm 
Appendix F 

Draft NUREG-1937 F-50 March 2010

1 shipping contracts have been developed for transportation of the materials to the STP site. 

2 However, STPNOC has indicated that the current plans call for prefabricated modules and 

3 components fabricated overseas to be shipped to the Port of Freeport (or points north) where 

4 they would be transferred from ocean-going ships to inland barges. The inland barges would 

5 then enter the GIWW and move south to the confluence of the Colorado River and proceed 

6 upstream to the site. The ports in Matagorda Bay to the south of the site currently do not have 

7 adequate facilities for the transfer of heavy cargo from ocean-going vessels to inland barges. 

8 Therefore, transport of these materials would not involve the Matagorda Ship Channel or the 

9 diversion canal in Matagorda Bay (STPNOC 2009b). 

10 STPNOC plans to ship bulk commodities via inland barge. Access to the Colorado River by the 

11 barges would depend on the source of the materials, and could be transported either from the 

12 north or south along the GIWW. However, no bulk commodity traffic is expected to traverse the 

13 diversion canal in Matagorda Bay or the Matagorda Ship Channel (STPNOC 2009b). 

14 4.0 Essential Fish Habitat Species Descriptions 

15 The proposed Units 3 and 4 at the STP site are located in an area that is designated as EFH in 

16 Ecoregion 5 by the Gulf of Mexico Fishery Management Council (GMFMC 2004). The NRC and 

17 the Corps conducted an evaluation by identifying and considering all designated EFH that 

18 occurs near the STP site (GMFMC 2004; NMFS 2009). Table 2 lists the species with 

19 designated EFH in Matagorda Bay, GIWW, and the Colorado River extending up to the bridge 

20 at FM 521 (located at NMM 10 on the Colorado River upstream from the confluence with the 

21 GIWW). With the exception of a few species that do not occur in the region of interest, or 

22 occupy EFH that would not be affected by the proposed actions, these species and their life 

23 stages that rely on habitats essential for species propagation are detailed below with regard to 

24 the impact of the proposed Federal actions on EFH. 

25 During the initial review of life history and EFH requirements, some life stages were eliminated 

26 from further consideration based on depth requirements, or life history information that 

27 suggested specific life stages are unlikely in the Colorado River extending up to the bridge at 

28 FM 521, GIWW, and Matagorda Bay (Table 3). Table lists the species and life stages 

29 evaluated in this EFH assessment. 
Appendix F 

March 2010 F-51 Draft NUREG-1937 

1 Table 2. Designated Essential Fish Habitat with Ecoregion 5 

Fishery Management Plan Species Common Name Life Stage 

Coastal Migratory Pelagic Scomberomorus cavalla king mackerel eggs, larvae, 

juveniles, adults 

Coastal Migratory Pelagic Scomberomorus maculatus Spanish mackerel eggs, larvae, 

juveniles, adults 

Reef Fish Lutjanus griseus gray (mangrove) 

snapper 

eggs, larvae, 

juveniles, adults 

Red Drum Sciaenops ocellatus red drum eggs, larvae, 

juveniles, adults 

Shrimp Farfantepenaeus aztecus(a) brown shrimp eggs, larvae, 

juveniles, adults 

Shrimp Farfantepenaeus duorarum(b) pink shrimp eggs, larvae, 

juveniles, adults 

Shrimp Litopenaeus setiferus(c) white shrimp eggs, larvae, 

juveniles, adults 

Stone Crab Menippe adina(d) Gulf stone crab eggs, larvae, 

juveniles, adults 

Sources: Guillory et al. 1995; GSMFC 1995; Cascorbi 2004; NMFS 2009. 

(a) This species was formerly known as Penaeus aztecus. 

(b) This species was formerly known as Penaeus duorarum. 

(c) This species was formerly known as Penaeus setiferus. 

(d) Menippe adina has been recognized as a new species, distinct from M. mercenaria, and is the species most 

common in the Gulf along the Texas coastline. 

2 Table 3. Species and Life Stages Excluded from Essential Fish Habitat Assessment 

Common Name Life Stages Excluded Rationale for Exclusion 

King mackerel eggs, larvae, adults 

(juveniles retained)

depth requirements not present 

in Colorado River, GIWW, or 

Matagorda Bay(a)

Brown shrimp eggs, adults (larvae, 

juveniles retained)

depth requirements not present 

in Colorado River, GIWW, or 

Matagorda Bay(a)

Pink shrimp eggs, adults (larvae, 

juveniles retained) 

depth requirements not present 

in Colorado River, GIWW, or 

Matagorda Bay(a)

White shrimp eggs, adults (larvae, 

juveniles retained) 

depth requirements not present 

in Colorado River, GIWW, or 

Matagorda Bay(a)

(a) GMFMC 2004 
Appendix F 

Draft NUREG-1937 F-52 March 2010

1 Table 4. Essential Fish Habitat Included in Evaluation 

Fishery Management Plan Species Common Name Life Stage 

Coastal Migratory Pelagic Scomberomorus cavalla king mackerel juveniles 

Coastal Migratory Pelagic Scomberomorus maculatus Spanish mackerel eggs, larvae, 

juveniles, adults 

Reef Fish Lutjanus griseus gray (mangrove) 

snapper 

eggs, larvae, 

juveniles, adults 

Red Drum Sciaenops ocellatus red drum eggs, larvae, 

juveniles, adults 

Shrimp Farfantepenaeus aztecus brown shrimp larvae, juveniles 

Shrimp Farfantepenaeus duorarum pink shrimp larvae, juveniles 

Shrimp Litopenaeus setiferus white shrimp larvae, juveniles 

Stone Crab Menippe adina Gulf stone crab eggs, larvae, 

juveniles, adults 

2 4.1 King Mackerel 

3 King mackerel (Scomberomorus cavalla) are highly migratory and are aggressive predators that 

4 prefer feeding on schooling fish. Occasionally they eat penaeid shrimp and squid. Adult king 

5 mackerels consume mainly fish around 4 to 6 in. Juveniles eat smaller fish and invertebrates, 

6 particularly bay anchovy (Anchoa mitchilli). King mackerel can live to at least 14 years, 

7 although most die earlier. Females grow larger than males and spawn in their third or fourth 

8 year of life, with spawning occurring in the summer months (TSFGW 2005; FMNH 2009; TPWD 

9 2009). Adults are primarily found offshore, but juveniles occasionally frequent estuarine waters 

10 for foraging (GMFMC 2004). Although no king mackerel have been observed during sampling 

11 studies, juvenile king mackerel are likely to occur in Matagorda Bay, GIWW, and the Colorado 

12 River. 

13 4.2 Spanish Mackerel 

14 Adult Spanish mackerel (Scomberomorus maculates) forage in estuarine and marine nearshore 

15 pelagic waters, and eggs and juveniles also occur nearshore marine surface (eggs) and pelagic 

16 (juveniles) waters (GMFMC 2004). The species is often found in large schools near the water 

17 surface. Juvenile and adult Spanish mackerel are fast-moving, voracious predators that feed on 

18 other smaller schooling fish. Spawning takes place from late spring to late summer at depths of 

19 less than 50 m along the Texas inner continental shelf (DeVries et al. 1990; Patillo et al. 1997). 

20 According to an EFH assessment in Matagorda Bay by the Corps (2007), adult and juvenile 

21 Spanish mackerel are found in the Gulf and Matagorda Bay throughout the year. The surveys 

22 of the Colorado River did not report any Spanish mackerel (NRC 1986; ENSR 2008a; STPNOC 

23 2009a). 
Appendix F 

March 2010 F-53 Draft NUREG-1937 

1 4.3 Gray Snapper 

2 Larval, juvenile, and adult life stages of gray snapper (Lutjanus griseus) are considered because 

3 these life stages primarily occupy inshore habitats, such as those in the Colorado River, GIWW, 

4 and Matagorda Bay (GMFMC 2004). Eggs are neritic and demersal, and are found primarily in 

5 marine waters. Larvae are marine, neritic, and planktonic, and are known to be in the Gulf from 

6 April through November. As they mature, gray snapper move into estuarine habitats and 

7 occupy inshore grassy areas. Juveniles and adults are found in inshore marine and estuarine 

8 habitats with SAV or near mangroves, where they forage on small fish and crustaceans (Croker 

9 1962; Patillo et al. 1997). The Corps (2007) reported that gray snapper are found in Matagorda 

10 Bay. Patillo et al. (1997) indicated that gray snapper are rare as adults and juveniles, but other 

11 life stages were not present in Matagorda Bay. Gray snapper were collected within the first 3 mi 

12 of the Colorado River from the confluence with the GIWW during the 2007-2008 sampling 

13 events (ENSR 2008a). 

14 4.4 Red Drum 

15 Red drum (Sciaenops ocellatus) larvae and juveniles spend most of their time in estuarine soft 

16 bottom, sand/shell, and SAV habitats actively feeding on copepods, mysid shrimp (Mysidopsis 

17 bahia), amphipods, decapods, and small fish. All free swimming life stages of the red drum are 

18 carnivorous. Adults spend some time near inshore SAV, sandy or hard-bottom foraging habitats 

19 but are predominantly found offshore where spawning activities occur (Patillo et al. 1997; 

20 GMFMC 2004). Red drum move to deep offshore waters to spawn in the fall and then return to 

21 nearshore coastal and estuarine habitats where they spend most of their life cycle (FFWCC 

22 2007). Tidal currents move larvae to nearshore habitats, where they grow rapidly as juveniles 

23 during the first two years, and associate with seagrass habitats, with little wave action (Buckley 

24 1984). The Corps (2007) reported that juvenile red drum are present in Matagorda Bay 

25 throughout the year. Patillo et al. (1997) indicated that all life stages of red drum were common 

26 in Matagorda Bay. Red drum were collected in along the Colorado River in 2007-2008 with all 

27 types of sampling gear, indicating that the species was well distributed in the river (ENSR 

28 2008a). 

29 4.5 Shrimp 

30 Adult brown shrimp migrate (Farfantepenaeus aztecus) from offshore pelagic environment as 

31 larvae to inhabit grassy, estuarine habitats as juveniles (GMFMC 2004). They spawn in 

32 offshore waters between spring and early summer. The eggs are demersal and deposited 

33 offshore. Larvae migrate into estuarine waters through passes during flood tides. Juveniles 

34 inhabit a variety of areas where they can burrow in shallow estuarine waters, ranging from areas 

35 with vegetative cover to open silty sand, nonvegetated mud substrate. Postlarvae and juveniles 
Appendix F 

Draft NUREG-1937 F-54 March 2010

1 can tolerate a range of salinities, from 0 to 70 ppt. Juveniles and subadults prefer soft, muddy 

2 areas. Subadult brown shrimp migrate from estuaries into the Gulf (Patillo et al. 1997; GMFMC 

3 2004; Corps 2007). Juvenile and adult shrimp are omnivorous with diets that vary between 

4 available food sources within the occupied habitat, which is preferably soft bottom, shallow 

5 estuarine areas (FWS 1983). According to an EFH assessment in Matagorda Bay by the Corps 

6 (2007), juvenile brown shrimp are common to highly abundant in Matagorda Bay year-round, 

7 while adults are common to highly abundant from April to July and are rare from August through 

8 March. Brown shrimp were collected in sampling studies all along the Colorado River in 1983-

9 1984 and 2007-2008 (NRC 1986; ENSR 2008a; STPNOC 2009a). 

10 Pink shrimp (Litopenaeus duorarum) in the Texas coastal waters are often difficult to distinguish 

11 from brown shrimp, and pink and brown shrimp are usually reported together in information 

12 about the shrimping fishery in Texas coastal waters (Patillo et al. 1997). Adults occur offshore 

13 and migrate into estuaries in the spring and fall. Postlarvae and juvenile pink shrimp select 

14 habitats with seagrass and shoalgrass, where they burrow by day and emerge and are active at 

15 night (Patillo et al. 1997; Corps 2007). Like brown shrimp, juvenile and adult shrimp are 

16 omnivorous (Patillo et al. 1997). According to an EFH assessment in Matagorda Bay by the 

17 Corps (2007), juvenile pink shrimp are common in Matagorda Bay year-round, while adults are 

18 common from November through June. Pink shrimp were not reported in surveys of the 

19 Colorado River in 2007-2008 (ENSR 2008a). 

20 Adult white shrimp (Litopenaeus setiferus) also migrate from offshore pelagic environment as 

21 larvae to inhabit grassy, estuarine habitats as juveniles (GMFMC 2004). They spawn in 

22 offshore waters from spring to fall (FWS 1983). The eggs are demersal and deposited offshore 

23 (Patillo et al. 1997). White shrimp larvae may be found in the nearshore marine water column, 

24 but they prefer estuarine habitats and migrate further upstream in estuarine waters than brown 

25 shrimp (GMFMC 2004). Juvenile and adult shrimp are omnivorous with diets that vary between 

26 available food sources within the occupied habitat, which is preferably soft-bottom, shallow 

27 estuarine areas (FWS 1983). According to an EFH assessment in Matagorda Bay by the Corps 

28 (2007), adult and juvenile white shrimp are common to abundant in Matagorda Bay throughout 

29 the year, except in July when adult white shrimp are absent. White shrimp were collected in 

30 sampling studies all along the Colorado River in 1983-1984 and 2007-2008 (NRC 1986; ENSR 

31 2008a; STPNOC 2009a). 

32 4.6 Gulf Stone Crab 

33 The Gulf stone crab (Menippe adina) occupies estuarine and marine SAV, sand/shell, and hard34 bottom habitats as eggs, larvae, and juveniles (GMFMC 2004). Adults are both intertidal and 

35 subtidal and are typically found near oyster reefs or other hard-bottom substrate, and prefer a 

36 diet of oysters (Wilber 1989). Juveniles feed on small mollusks, worms, and crustaceans. 

37 Females maintain eggs on their abdomen until they hatch and become planktonic. As they 
Appendix F 

March 2010 F-55 Draft NUREG-1937 

1 metamorphose to larvae, they become epibenthic, settling to areas providing cover (e.g., rubble 

2 and seagrass beds). The stone crab FMP allows harvest only of individuals with claws greater 

3 than 2.75 in. long. Florida stone crabs (M. mercenaria) require high salinities for juvenile 

4 growth, but the Gulf stone crab tolerates estuarine waters (GMFMC 2004). All life stages of 

5 Gulf stone crab are considered common throughout the year in Matagorda Bay (Patillo et al. 

6 1997; Corps 2007). Gulf stone crabs were not reported in surveys of the Colorado River in 

7 1983-1984 and 2007-2008 (NRC 1986; ENSR 2008a; STPNOC 2009a). 

8 5.0 Potential Environmental Effects of the Proposed 

9 Federal Actions 

10 This section describes the potential impacts from the construction and operation of proposed 

11 Units 3 and 4 at the STP site to Federally-managed estuarine and marine fish and shellfish and 

12 their habitats. Most of the construction and operation impacts to EFH would be limited to the 

13 Colorado River. Barging traffic during construction of Units 3 and 4 would be associated with 

14 Matagorda Bay, GIWW and the Colorado River. 

15 5.1 General Construction Impacts 

16 Construction activities in the Colorado River for the proposed Units 3 and 4 are limited to the 

17 RMPF, the barge slip and barging traffic to the STP site. Activities within the MCR are not part 

18 of this assessment because the aquatic organisms in the MCR are considered removed from 

19 the ecological system of the Colorado River, and the MCR is not included as designated EFH. 

20 Half of the intake screens on the RMPF have not been used during the operation of STP Units 1 

21 and 2, and they would be removed from the water and either refurbished or replaced. New 

22 pumps for proposed Units 3 and 4 would be installed behind the embayment located behind the 

23 traveling screens. These activities would involve little underwater disturbance, which would be 

24 limited to the front of the intake structure. EFH in the Colorado River would likely not be 

25 adversely affected during construction because of the minimal activity in the river that would be 

26 required by the refurbishment of the RMPF. 

27 When the barge slip for existing STP Units 1 and 2 was built, a sheet pile wall was installed in 

28 the river to control sedimentation and limit downstream increases in turbidity and siltation. At 

29 that time, an estimated area of less than one ac of benthic habitat was destroyed during the 

30 building of the barge slip (STPNOC 2009a). The areal extent and types of disturbances to the 

31 shoreline and in the river for the re-excavation and expansion of the slip for transporting the 

32 barged materials for proposed Units 3 and 4 is anticipated to be similar to or less than the 

33 disturbances during the building of Units 1 and 2 (STPNOC 2009c). The loss of soft-bottom 
Appendix F 

Draft NUREG-1937 F-56 March 2010

1 habitat would likely reduce the potential forage area for the penaeid shrimp and some benthic2 feeding EFH fish species. However, the area is not one of high benthic productivity, and the 

3 area that would be lost is relatively small. 

4 STPNOC has indicated the current plans call for heavy equipment (prefabricated modules and 

5 components fabricated overseas) to be shipped to the Port of Freeport (or points north) where 

6 they would be transferred from ocean-going ships to inland barges. The inland barges would 

7 enter the GIWW, move south to the confluence of the Colorado River, and proceed upstream to 

8 the site. Bulk commodities (e.g., aggregate or structural fill material) could be barged to the 

9 STP site from ports to the north or south along the GIWW. There is no estimate for the number 

10 of barges that would deliver to the STP site (STPNOC 2009b). Based on the minimum depths 

11 and narrow channels that the barges would have to travel in the Colorado River, the barges are 

12 likely to be slow moving, and would have minimal wave disturbances along shoreline habitat. 

13 Habitat for aquatic organisms in the vicinity of the barge slip would be disturbed while barges 

14 continue to use the area. While there would be an increase in turbidity and silt in the water 

15 column associated with docking and the potential for discharge of small amounts of gas, oil, and 

16 grease from motors, the overall impact would be short in duration (STPNOC 2009b). 

17 Erosion and sedimentation controls, are expected to minimize quantities of sediment or silt. 

18 Increase in turbidity would increase suspended sediments in the water column, but it is not likely 

19 that such sediments would be transported far down the river. Dredging would remove habitat 

20 (probably less than three ac) for organisms in the area of the barge slip, and could take 

21 individuals that cannot avoid the area. Based on the short duration and limited area of the river 

22 that would be affected, the impacts from construction activities for proposed Units 3 and 4 at 

23 STP are likely to be minor for aquatic resources in the Colorado River, the GIWW and 

24 Matagorda Bay. 

25 5.2 General Operational Impacts 

26 Operational activities in the Colorado River are limited to pumping water at the RMPF, 

27 discharge of the MCR water into the river, and maintenance dredging of the RMPF. Removal of 

28 water from the Colorado River at the RMPF affects aquatic organisms by impingement on 

29 screens, entrainment into the cooling system, and entrapment in the MCR. Discharging from 

30 the MCR into the Colorado River has the potential to affect the aquatic organisms because of 

31 the thermal, chemical, and physical characteristics of the discharge plume. Maintenance 

32 dredging around the RMPF and barge slip has the potential to remove habitat. 

33 Impingement, Entrainment, and Entrapment. The RMPF has a number of design elements that 

34 are expected to minimize impingement, entrainment and entrapment of aquatic organisms 

35 during operation of all the STP units. For aquatic resources, the primary concerns related to 

36 water intake and consumption are the impacts related to the relative amount of water drawn 
Appendix F 

March 2010 F-57 Draft NUREG-1937 

1 from the cooling water source (Colorado River and MCR) and the potential for organisms to be 

2 impinged on the intake screens entrained into the cooling water system, or entrapped in the 

3 MCR. Impingement occurs when organisms are trapped against the intake screens by the force 

4 of the water passing through the screens at the RMPF on the Colorado River and the CWIS on 

5 the MCR. Impingement can result in starvation and exhaustion, asphyxiation (water velocity 

6 forces may prevent proper gill movement or organisms may be removed from the water for 

7 prolonged periods of time), and descaling. Entrainment occurs when organisms are drawn 

8 through the RMPF from the Colorado River into the MCR, or through the CWIS from the MCR 

9 into the proposed Units 3 and 4 cooling system. Organisms that become entrained are normally 

10 relatively small benthic, planktonic, and nektonic (organisms in the water column) forms, 

11 including early life stages of fish and shellfish, which often serve as prey for larger organisms 

12 (69 FR 41576). Entrained organisms from the Colorado River have survived the stresses of the 

13 intake system and colonized the MCR, creating a rather diverse aquatic community that is 

14 removed from the rest of the ecosystem in the region. The survey of the MCR in 2007 and 2008 

15 indicates that many individuals of numerous species have survived entrainment at the RMPF 

16 and are living in the MCR. While these entrapped organisms have survived entrainment of the 

17 pumps at the RMPF, overall the entrainment and entrapment have led to a loss of the 

18 organisms in the Colorado River, and these organisms no longer contribute to the richness of 

19 the river community as they are effectively isolated. Organisms in the MCR that pass through 

20 the CWIS into the plant’s cooling system are subject to mechanical, thermal, and toxic stresses, 

21 and survival of CWIS entrainment is unlikely and assumed to be zero for the purposes of this 

22 assessment. 

23 A number of factors, such as the type of cooling system, the design and location of the intake 

24 structure, and the amount of water withdrawn from the source water body greatly influences the 

25 degree to which impingement and entrainment affect the aquatic biota. The 7000-ac MCR is 

26 considered a closed-cycle cooling system since the water in the reservoir continues to circulate 

27 from the MCR, into the plant, and back again. Water loss from the MCR through evaporation, 

28 seepage, and discharge is made up from the Colorado River. 

29 The RMPF is located on the Colorado River, which is designated as a tidal stream (TCEQ 2008) 

30 and includes EFH for Federally managed fish and shellfish species (GMFMC 2004). Locating 

31 intake systems in such areas with sensitive biological communities is generally considered a 

32 negative factor in protection of aquatic life (69 FR 41576). However, the segment of the river 

33 where the RMPF is situated (Segment C) has fewer organisms and less species richness than 

34 the downstream segment of the river, closer to the GIWW (Segment A)(ENSR 2008b). During 

35 2007-2008, 18 percent of the total number of individuals collected were from Segment C as 

36 compared to 44 percent from Segment A; and 42 species were collected from Segment C as 

37 compared to 62 species from Segment A (Figures 4 and 5). 
Appendix F 

Draft NUREG-1937 F-58 March 2010

1 Operation of the RMPF is based on the need for makeup water in the MCR, and Section 5.2.2.1 

2 of the EIS discusses the conditions when STPNOC would pump water from the Colorado River 

3 into the MCR. One of these conditions is pumping makeup water during periods of high flows in 

4 the Colorado River. Pumping at high-flow conditions minimizes impacts to aquatic organisms in 

5 the water column because the organisms are likely to remain in the river flow and not likely to be 

6 caught in the influence of the water being pumped into the RMPF located on the shoreline 

7 (STPNOC 2008b, 2008c, 2009a). During the 2007-2008 aquatic ecology studies in the 

8 Colorado River, there was an inverse relationship between high-flow conditions and low 

9 densities of fish (as expressed in the catch per unit effort) (ENSR 2008a; STPNOC 2008b, 

10 2008c). Salinity can be an indicator of an influx of estuarine species moving up the river from 

11 the GIWW. STPNOC has stated that the salinity of the water being pumped would be 

12 monitored, and when the pumped water exceeds 3 ppt, the traveling screens would be 

13 monitored for increased impingement. The operation of the fish-return system at the RMPF is a 

14 function of river flow and the amount of debris and organisms removed in the screen wash 

15 discharge (STPNOC 2008a). 

16 Location of the RMPF and the intake screens on the shoreline of the Colorado River can 

17 minimize entrainment and entrapment (as a function of minimized entrainment). The RMPF 

18 was designed to maintain the traveling intake screens on the facility parallel with the flow in the 

19 river (69 FR 41576), or “flush” to the river bank with no projecting structures that create eddies 

20 and countercurrents that would cause entrapment (NRC 1986; STPNOC 2009a). Most 

21 organisms likely to be entrained or entrapped would be present in higher densities in the main 

22 river channel and less likely to be removed from the river by an intake facility sited on the 

23 shoreline. Entrapment of aquatic organisms in a restricted area (e.g., in the sedimentation 

24 basin between the RMPF intake screens and the pumps and in the MCR) can lead to 

25 congregation of the organisms, and if environmental conditions change, the organisms may be 

26 harmed. Under such conditions, entrapment can increase impingement of aquatic organisms. 

27 Another important factor that influences the rate of impingement, entrainment, and entrapment 

28 of organisms at a facility is the intake design through-screen velocity. The higher the through29 screen velocity, the greater the number of fish impinged, entrained, and entrapped. The 

30 Environmental Protection Agency defines the through-screen velocity as the water velocity 

31 immediately in front of the screen, and the maximum design, through-screen velocity is no more 

32 than 0.5 feet per second (fps) (69 FR 41576). STPNOC has determined that the RMPF has a 

33 maximum design approach velocity at the traveling screens of 0.5 fps based on a maximum 

34 pumping rate of approximately 538,000 gpm (STPNOC 2008b, 2009a). The review team 

35 independently calculated that the velocity directly in front of the screens was dependent on the 

36 withdrawal rate of the RMPF: for withdrawals of 60 and 1200 cfs, the average velocity in front of 

37 the screen would be 0.025 and 0.49 fps. The resulting low through-screen velocity reduces the 

38 probability of impingement because most fish can swim against such low flows to avoid or swim 

39 off of intake streams. 
Appendix F 

March 2010 F-59 Draft NUREG-1937 

1 Other design features at the RMPF would also help to reduce impingement mortality 

2 (69 FR 41576). In front of the traveling water screens are coarse trash racks and stop-log 

3 guides that allow fish that approach the RMPF to have free passage, reducing entrapment and 

4 impingement. The traveling screens have a 3/8-in. mesh, and operate intermittently to coincide 

5 with the intermittent withdrawal of river water. Fish collected on the traveling screens can be 

6 returned to the river via the sluice and a fish bypass pipe. The discharge point of the fish 

7 bypass system is at the downstream end of the intake structure, approximately two ft below 

8 normal water elevation (STPNOC 2009a). During high-flow conditions, the accumulation of 

9 debris on the traveling screens is too high to open the fish bypass system, and screenwash 

10 discharge is directed to the sluice trench catch baskets rather than back to the river. Generally, 

11 the fish bypass system is closed when river flows are greater than 4000 cfs, and the system is 

12 occasionally closed when flows are greater than 2000 cfs (which has occurred from 2001-2006 

13 seven percent of the time) (STPNOC 2008b, 2009a). Impingement mortality can be reduced 

14 based on the procedures for operating the RMPF. Operators at the RMPF are required to 

15 monitor for increased impingement rates on the traveling screens, and factors like river flow, 

16 salinity, and observations of impingement are used to determine whether pumping should 

17 continue (STPNOC 2008b, c, 2009a). 

18 Entrainment and impingement studies were conducted as part of the licensing process for STP 

19 Units 1 and 2, and were discussed in the Final Environmental Statement (FES) for operation 

20 (NRC 1986). Studies conducted in 1975-1976, prior to construction of the RMPF, estimated 

21 entrainment of the larvae of the most common fish and crustacean species during an 8-month 

period at Station 2 on the Colorado River (Figure 3): 3.37 x 106

 Atlantic croaker, 1.35 x 106 22 Gulf 

menhaden (Brevoortia patronus), 1.32 x 106

 blue crab, 5.44 x 105 bay anchovy and 1.1 x 104 23 

24 shrimp (undetermined species) larvae. There was a seasonal fluctuation of the species 

25 collected monthly during the study. Atlantic croaker larvae were entrained mainly from 

26 November through January. From January through April 1976, Gulf menhaden larvae were the 

27 predominant species. Anchovy eggs and larvae occurred sporadically throughout the sampling 

28 year. Highest numbers of juvenile and megalops of blue crab were collected in October, but 

29 there were increased numbers taken in September and April (NRC 1986). 

30 The entrainment studies in 1983-1984 were conducted during the filling of the MCR (NRC 

31 1986). Different species of fish and crustaceans were collected compared to the studies in 

32 1975-1976. The primary fish species collected in the vicinity of the plant intake were bay 

33 anchovies, followed by darter goby (Ctenogobius boleosoma) and naked goby (Gobiosoma 

34 bosc). The most common crustacean collected were the zoea larval stage of the Harris mud 

35 crab, followed by the zoea and postlarval stages of the ghost shrimp (Callianassa spp.). 

36 Postlarval stages of the brown shrimp and white shrimp and the juvenile stages of the blue crab 

37 were collected only sporadically in river samples. The variety of species collected illustrates 

38 that the lower Colorado River is used as a nursery area by estuarine-marine organisms (NRC 

39 1986). The seasonal variations in species and numbers of individuals found in these studies 
Appendix F 

Draft NUREG-1937 F-60 March 2010

1 

2 Figure 4. Aquatic Ecology Sampling Locations for 2007-2008 on the Colorado River from 

3 Navigation Mile Marker 5 to 9 
Appendix F 

March 2010 F-61 Draft NUREG-1937 

1 

2 Figure 5. Aquatic Ecology Sampling Locations for 2007-2008 on the Colorado River from Gulf 

3 Intracoastal Waterway to Navigation Mile Marker 4 
Appendix F 

Draft NUREG-1937 F-62 March 2010

1 emphasize the complexity of the aquatic environment in the Colorado River and in the vicinity of 

2 the RMPF. These variations are a function of the species’ reproductive periods, changes in the 

3 flow of the river, the mixture of freshwater coming down the river, and tidal influence of the Gulf. 

4 The FES for operation (NRC 1986) concluded that entrainment losses for the species that were 

5 collected during the two studies would not constitute a significant impact to their respective 

6 populations for several reasons. They estimated that the actual entrainment losses would 

7 probably be near a median value of about 10 percent of the organisms passing the RMPF. This 

8 value represents the loss of organisms in the influence of the tidal flow in the river and does not 

9 represent the entire populations of those species in the Colorado River. The organisms that use 

10 the lower Colorado River as a nursery also use many other tidal river systems along the Texas 

11 and Gulf coast, and the area influenced by the RMPF is not unique. The most common species 

12 collected in the entrainment studies were bay anchovy, Gulf menhaden, Atlantic croaker and 

13 blue crab; the species are ubiquitous and abundant along the Texas and Gulf coast. The 

14 reproductive potential (fecundity) for the species collected during the entrainment studies is high 

15 (e.g., one female blue crab can produce over her lifetime at least as many larvae as were 

16 projected to be entrained by the studies). And finally, the most makeup water withdrawal would 

17 occur during high river flow conditions when tidal flows are low at the RMPF, which is when the 

18 concentrations of estuarine and marine organisms would be lowest (NRC 1986). 

19 Impingement studies were conducted during 1983-1984, while river water was being pumped 

20 into the MCR. The study reported that the highest numbers of organisms impinged over a 

21 30-minute collection period for two intake screens at the RMPF were 64 organisms in July and 

22 13 organisms in September. The number of organisms that could be impinged for all 

23 24 screens at the RMPF and for two pumping velocities (85 cfs and 260 cfs) was extrapolated to 

24 be from 156 to 768 individuals over a 30-minute period. Gulf menhaden was the most common 

25 species impinged, which relates to their small size (and thus, relatively low swim speed), dense 

26 schooling nature and high relative abundance at the site. The report estimated that Gulf 

27 menhaden could constitute about 65 percent of the total number of all individuals impinged at 

28 the RMPF. The other major species that could be impinged include: Atlantic croaker 

29 (16 percent), bay anchovy (10 percent) and mullet (eight percent, undetermined species). The 

30 remaining species that were collected during the impingement study were expected to make up 

31 less than one percent of all the individuals impinged. 

32 The FES for operation concluded that impingement losses would have only a minor effect on 

33 the biota of the Colorado River. The reasons cited for the minor impacts due to impingement 

34 included those mentioned above for perspective on entrainment losses (e.g., the species are 

35 ubiquitous and the number of similar habitat areas along the Texas Gulf coast). Additional 

36 reasons cited included design elements of the RMPF that should reduce impingement losses. 

37 For example, the mounting of the intake screens on the RMPF flush with the shoreline and 

38 without protruding sidewalls into the flow of the river would reduce entrapment and 
Appendix F 

March 2010 F-63 Draft NUREG-1937 

1 concentration of organisms ahead of the screens. Also, the location of the screens would 

2 decrease eddy currents downstream and allow free passage of the organisms into the main 

3 channel. Trash racks and the fish handling and bypass system were other features cited that 

4 would reduce impingement losses. Finally, the location of the intake structure was designed to 

5 use the upper stratum of the river water that is primarily freshwater flowing downstream in the 

6 river and not the lower portion of the river in the salt wedge where the estuarine organisms are 

7 most common (NRC 1986). 

8 Since the impingement and entrainment studies for the RMPF were conducted, the Corps 

9 completed the Mouth of the Colorado River Project, diverting the Colorado River flow from the 

10 Gulf into Matagorda Bay (Wilbur and Bass 1998; Corps 2005). The diversity of aquatic species 

11 has increased since the diversion of the river. Of the most common species impinged during 

12 the 1983-1984 studies (NRC 1986), Gulf menhaden, striped mullet (Mugil cephalus) and Atlantic 

13 croaker continue to be the most common species of fish collected around the RMPF, and 

14 probably are the most common species impinged today for the same reasons speculated 

15 above. The lack of studies over time in the lower Colorado River makes it difficult to conclude if 

16 the aquatic communities are stable based on the changes in the river system and the 

17 relationship of the species distributed in the region to the flow of freshwater and tidal changes. 

18 However, the results and conclusions of the earlier impingement and entrainment studies 

19 mentioned above are still applicable because the design features of the RMPF that would 

20 minimize losses of organisms would not change with the addition of proposed Units 3 and 4 at 

21 the STP site. 

22 The survey of fish and shellfish in the Colorado River in 2007-2008 indicates that the river has a 

23 large population of fresh- and saltwater species, with high species richness and a strong 

24 dynamic ecosystem. Impingement, entrainment, and entrapment from current operations of the 

25 RMPF have removed individuals from the river environment. A survey of only one year provides 

26 limited information about the robustness of the populations of aquatic organisms in the river. 

27 However, based on the limited information from the latest survey and what is known about the 

28 design of the RMPF, the operation of the RMPF does not appear to have changed the 

29 populations of the species currently found in the river. 

30 Entrapment and entrainment of the smaller organisms and early life stages would be removed 

31 from the Colorado River ecosystem. Some of these organisms may survive and thrive in the 

32 MCR. There would be indirect effects for those EFH species that forage on the organisms that 

33 are lost through entrapment and entrainment. Impingement is likely to affect the EFH species 

34 that have life stages that could not swim away from the intake screens. 

35 Thermal, Chemical, and Physical Impacts. The operation of the discharge system into the 

36 Colorado River would likely have impacts on the aquatic resources from heated effluents, 

37 chemical impacts, and physical impacts. There is a current TPDES permit for the discharge of 

38 the MCR water into the Colorado River that would be applicable for the proposed new units as 
Appendix F 

Draft NUREG-1937 F-64 March 2010

1 well as the existing units (TCEQ 2005). During the operation of the existing units, no discharge 

2 from the MCR to the Colorado River has been needed to maintain the dilute solutes present in 

3 MCR water quality at acceptable levels for the circulating water systems. The current TPDES 

4 permit allows an average daily MCR discharge of 144 million gallons per day (MGD) with a daily 

5 maximum of 200 MGD. The average daily MCR discharge temperature is limited to 95°F with a 

6 daily maximum of 97°F. Total residual chlorine in the MCR discharge is limited to a daily 

7 maximum of 0.05 mg/L. The pH of the MCR discharge is limited to between 6.0 and 9.0 

8 standard units. The TPDES permit specifies that MCR discharge must not exceed 12.5 percent 

9 of the flow of the Colorado River at the discharge point. The permit also restricts the MCR 

10 discharges to periods when the flow of the Colorado River adjacent to the site is 800 cfs or 

11 greater. Whole effluent toxicity testing (i.e., biomonitoring) of the MCR water is also required 

12 prior to discharging water into the river (TCEQ 2005). The MCR discharge facility consists of 

13 seven submerged ports located on the west bank of the Colorado River approximately 2 mi 

14 downstream of the RMPF. Each port can discharge at a maximum rate of 44 cfs, for a total 

15 maximum MCR discharge of 308 cfs (STPNOC 2009a). 

16 STPNOC stated that, as part of their operating policy, they would discharge water from the MCR 

17 into the Colorado River when they are concurrently pumping water at the RMPF (STPNOC 

18 2009d). STPNOC would discharge water from the MCR when the specific conductivity of the 

19 water in the MCR exceeds 3000 microsiemens per centimeter (μS/cm). STPNOC would pump 

20 makeup water from the Colorado River under conditions specified by the Lower Colorado River 

21 Authority (LCRA) contract. The conditions that STPNOC would consider when planning to 

22 discharge from the MCR include: when the MCR water level is between 40 and 49 ft MSL; 

23 when the river water conductivity is less than 2100 μS/cm; and when the river flow at the 

24 discharge facility is greater than or equal to 2500 cfs. STPNOC revised these conditions and 

25 indicated that they might discharge MCR water when the river flow is as low as 800 cfs, as 

26 permitted by their TPDES permit (TCEQ 2005; STPNOC 2009e). If all these conditions are met, 

27 STPNOC would then only discharge when the MCR water had a conductivity greater than or 

28 equal to 3000 μS/cm. STPNOC would cease discharging when any of those conditions 

29 changed or when the MCR water had a conductivity less than or equal to 2100 μS/cm 

30 (STPNOC 2009d). STPNOC estimated that the need for discharging would likely be as frequent 

31 as once every 11 days and could be continuous for as nearly much as 75 days. No information 

32 was provided on the most likely time of year for discharging water (STPNOC 2009d). 

33 STPNOC (STPNOC 2009a) as well as the NRC and Corps review team evaluated the 

34 maximum thermal plume from the discharge of the MCR water into the Colorado River using the 

35 Cornell Mixing Zone Expert System (CORMIX). The maximum thermal plume dimensions 

36 would occur when there was the greatest difference in temperatures between the MCR water 

37 and the water in the river (20.4°F) and a discharge rate from the MCR was the greatest (308 

38 cfs). Under these discharge conditions, the minimum streamflow of the Colorado River would 
Appendix F 

March 2010 F-65 Draft NUREG-1937 

1 be 2464 cfs based on the specifications of the TPDES permit where the discharge volume 

2 cannot be less than 12.5 percent of the streamflow in the Colorado River. 

3 Based on the results of the CORMIX modeling of the maximum expected thermal plume 

4 dimensions, the thermal plume that is 5°F above ambient conditions would be attached to the 

5 bottom of the river from the discharge pipe to 120 ft downstream, and the plume would extend 

6 approximately 25 percent across the width of the river. Approximately 100 ft downstream of the 

7 last discharge port, the plume becomes buoyant rises to the surface of the river. The surface of 

8 the river is predicted to have an elevated temperature from approximately 1060 ft downstream 

9 of the last discharge port to about 4400 ft downstream from the discharge ports. Under these 

10 conditions, there would be a portion of the water column that would remain at ambient river 

11 temperatures as the plume rises to the surface and extends from bank to bank that would allow 

12 foraging fish (e.g., Gulf menhaden, black drum [Pogonias cromis], striped mullet) to move up 

13 and downstream. Also, the invertebrate species (e.g., grass [Palaemonetes pugio], white and 

14 brown shrimp) and other bottom dwellers would be able to pass along the bottom of the river on 

15 the far side of the discharge structure without passing through the elevated temperature plume. 

16 The review team evaluated the possibility that the thermal plume generated by discharging the 

17 MCR water into the Colorado River could coincide with poor water quality for aquatic organisms 

18 in the river at the discharge structure. ENSR (2008a) measured water quality, e.g., salinity and 

19 dissolved oxygen, at various levels in the water column while collecting fish and shellfish. There 

20 are times of the year that ENSR reported the water at the bottom of the river was anoxic or low 

21 in dissolved oxygen (hypoxic, or with dissolved oxygen less than 2 mg/L) when the salinity was 

22 high. The conditions were most often observed at or below the mid point of the water column. 

23 The combination of the maximal thermal plume and poor river water conditions (e.g., high 

24 salinity and low dissolved oxygen) would force aquatic species to avoid the area completely. 

25 STPNOC compared the results reported by ENSR (2008a) and the flow in the river at the 

26 nearest gaging station at the time of the water sampling, and determined that the salinity at the 

27 bottom of the river during flows greater than 800 cfs had salinities ranging from 0 to 18.7 ppt 

28 (STPNOC 2008a). The review team further evaluated the river flows greater than 800 cfs and 

29 dissolved oxygen at the bottom of the river and found that there was only one occurrence during 

30 2007-2008 when the flow was greater than 800 cfs and the dissolved oxygen was less than or 

31 equal to 2 mg/L. In addition, the salinity at this sampling time was 17.5 ppt (ENSR 2008b). 

32 Although there is limited information available on river flow and water quality, the operating 

33 policy that STPNOC has established for discharging MCR water into the river in compliance with 

34 requirements in their TPDES permit would likely result in infrequent opportunities for discharging 

35 when the combined effect of the thermal plume with river conditions would cause harm to the 

36 aquatic community. The adult and juvenile life stages of the EFH species would likely avoid the 

37 thermal plume, but there could be some impacts to the earlier life stages that would not be able 

38 to avoid the plume. Depending on the frequency and duration of the discharge, the early life 

39 stages could be lost from the effects of the thermal plume. 
Appendix F 

Draft NUREG-1937 F-66 March 2010

1 Chemical effects on the aquatic community from future discharges from the MCR into the 

2 Colorado River can be evaluated in terms of compliance with the STPNOC’s TPDES permit. 

3 Inputs to the MCR include makeup water from the river, precipitation, dissolved solids from the 

4 operation of the condensers and UHSs for all units, and permitted chemical discharges from 

5 other operations (e.g., treated sanitary sewage, biocides, algaecides, corrosion inhibitors, pH 

6 buffering, scale inhibitors, and dispersants). The most significant chemical changes in the MCR 

7 would be the concentration of total dissolved solids from the operation of the condensers and 

8 UHSs. STPNOC does not currently evaluate the water quality of the MCR in relation to the 

9 TPDES permit conditions for chemical standards for the protection of aquatic life because it is 

10 not currently discharging to the Colorado River. The permit conditions also require evaluating 

11 acute and chronic effects on aquatic organisms from the MCR discharge prior to commencing 

12 discharge into the river. 

13 Physical effects from the operation of the discharge system in the Colorado River could affect 

14 aquatic resources, particularly through scouring of aquatic habitat. The NRC evaluated 

15 discharge-induced scouring of the seven-port diffuser and concluded that scouring would be 

16 limited to a few feet downstream of each port and would have “no adverse impacts” on the 

17 aquatic biota in the vicinity (NRC 1975). Since the discharge pipes have not been operated 

18 except for a test in 1997 (STPNOC 2009a) and the Colorado River in the vicinity of the pipes 

19 has not been dredged recently, the initial discharge of water would disturb the sediments in the 

20 area. Because the small predicted size of the potential scour area and relative impoverishment 

21 of the benthic community that would be replaced with time, the physical effects from the 

22 operation of the would have a minor effect on the regional benthic populations or their 

23 predators. 

24 Maintenance Dredging. STPNOC has stated that periodic dredging in the future would be 

25 conducted in front of the RMPF and barge slip. These activities are currently covered by 

26 existing permits with the Corps for the operation of existing Units 1 and 2. Dredging would 

27 remove benthic habitat and the organisms that are not highly mobile (e.g., mollusks). The area 

28 to be dredged in front of the RMPF and at the barge slip would likely be no more than 3 ac total, 

29 and would not cover the entire width of the river channel. Highly mobile organisms would likely 

30 avoid the area during dredging activities. After dredging activities, these areas would be 

31 recolonized by the aquatic community. Impacts from dredging on aquatic organisms would be 

32 minor. 

33 5.3 Potential Effects of the Proposed Federal Actions on 

34 EFH Species 

35 The species and life stages by the Gulf of Mexico Fishery Management Council for Ecoregion 5 

36 rely on habitats essential for species propagation. Below, each species is discussed with 

37 regard to the impact of the proposed Federal action on EFHs. The potential impacts of the 
Appendix F 

March 2010 F-67 Draft NUREG-1937 

1 construction and operation of the proposed STP Units 3 and 4 on Federally managed fish and 

2 shellfish species and their designated EFH, including their prey, near the site have been 

3 evaluated. Six categories of impacts related to STP construction and operation that could 

4 influence EFH are (1) siltation or turbidity during construction; (2) barge traffic creating turbidity 

5 or sedimentation; (3) impingement of juveniles or adults; (4) entrainment and entrapment of 

6 eggs, larvae, and zooplankton in the water column; (5) release of heated cooling water 

7 containing biocides or other chemicals; and (6) maintenance dredging at the RMPF and at the 

8 barge slip. 

9 5.3.1 King Mackerel 

10 Disruption of habitat for foraging in the Colorado River is expected to be minor, temporary, and 

11 largely mitigable. Construction activities around the RMPF and barge slip would involve a 

12 minimal area where juvenile king mackerel might be foraging. Barges moving heavy equipment 

13 and bulk commodities are likely to be moving slowly and prop wash and wave action from the 

14 vessel’s movement would not affect juvenile mackerel in the vicinity. Therefore, construction 

15 would likely have a minimal adverse effect on juvenile king mackerel EFH. Operation of the 

16 RMPF is not expected to have an impact on the juveniles directly or indirectly since they and 

17 their prey should be able to swim away from the low approach velocities at the RMPF intake 

18 screens. Juvenile king mackerel and their pray are expected to avoid areas affected by 

19 thermal, chemical and physical changes in the Colorado River from the discharge of the MCR 

20 water and maintenance dredging at the RMPF. Their prey should be able to avoid the adverse 

21 effects from the discharge system as well. Operations of the RMPF and discharge system are 

22 not continuous, and their adverse effects would be relatively short in duration. Therefore, the 

23 construction and operation of the proposed Units 3 and 4 at the STP site are likely to have a 

24 minimal adverse effect on EFH for the king mackerel juveniles. 

25 5.3.2 Spanish Mackerel 

26 Construction activities would occur in a small proportion of available Spanish mackerel foraging 

27 habitat within the Colorado River at the site of intake and barge slip modifications. Barges 

28 moving heavy equipment and bulk commodities are likely to be moving slowly and prop wash 

29 and wave action from the vessel’s movement would not affect any of the life stages of Spanish 

30 mackerel in the vicinity. Disruption of habitat for foraging in these areas of the Colorado River 

31 from construction and operation are expected to be minor and temporary. Juvenile and adult 

32 Spanish mackerel and their pray are expected to avoid areas affected by thermal, chemical and 

33 physical changes in the Colorado River from the discharge of the MCR water. Spanish 

34 mackerel eggs and larvae could be affected by the thermal or chemical characteristics of the 

35 discharge plume depending on the river conditions, frequency, and duration of the discharge. 

36 Eggs and larvae passing through the intake screens at RMPF would be lost. However, 

37 operations of the RMPF and discharge system are not continuous, and their effects would be 
Appendix F 

Draft NUREG-1937 F-68 March 2010

1 relatively short in duration. Maintenance dredging at the RMPF could be easily avoided by 

2 juvenile and adult Spanish mackerel, but some eggs and larvae would be lost. Because no 

3 Spanish mackerel were collected in recent surveys near the STP site, it is unlikely that the small 

4 loss (from operation of the RMPF, discharge structure, and dredges) of eggs and larvae would 

5 be detectable. Therefore, the construction and operation of the proposed Units 3 and 4 at the 

6 STP site are likely to have a minimal adverse effect on EFH for Spanish mackerel eggs, larvae, 

7 juveniles, and adults. 

8 5.3.3 Gray Snapper 

9 Disruption of gray snapper foraging habitat in the Colorado River is expected to be minor, 

10 temporary, and largely mitigable from construction activities. Juvenile and adult gray snapper 

11 may move into estuarine habitats, like the downstream portion of the Colorado River. Eggs and 

12 larvae are unlikely to be in the areas of the discharge structure, barge slip and RMPF. 

13 Construction activities at the barge slip and RMPF would occur in a small proportion of available 

14 potential foraging habitat within the Colorado River. Barges moving heavy equipment and bulk 

15 commodities are likely to be moving slowly and prop wash and wave action from the vessel’s 

16 movement would not affect any of the life stages of gray snapper in the vicinity. Any larvae that 

17 move up the Colorado River may become entrained in the cooling water intake system; 

18 however, juveniles and adults would likely swim away from the low approach velocity at the 

19 intake screens. Juvenile and adult gray snapper and their prey are expected to avoid areas 

20 affected by thermal, chemical and physical changes in the Colorado River from the discharge of 

21 the MCR water. Eggs and larvae passing through the intake screens at RMPF would be lost. 

22 However, operations of the RMPF and discharge system are not continuous, and their effects 

23 would be relatively short in duration. Maintenance dredging at the RMPF could be easily 

24 avoided by the juvenile and adult gray snapper. Therefore, the construction and operation of 

25 the proposed Units 3 and 4 at the STP site are likely to have a minimal adverse effect on EFH 

26 for eggs, larvae, juvenile and adult life stages of the gray snapper. 

27 5.3.4 Red Drum 

28 Construction activities would occur in a small proportion of available potential foraging habitat 

29 within the Colorado River at the site of RMPF and barge slip modifications. There is no SAV in 

30 the Colorado River in the vicinity of the barge slip and RMPF for the younger life stages of red 

31 drum. Disruption of habitat for foraging in these areas of the Colorado River is expected to be 

32 minor and temporary. Therefore, construction activities upstream in the Colorado River are 

33 likely to have a minimal adverse effect on the red drum. Barges moving heavy equipment and 

34 bulk commodities are likely to be moving slow and prop wash and wave action from the vessel’s 

35 movement would not affect any of the life stages of red drum in the vicinity. Operation of the 

36 RMPF and discharge structure are not likely to affect the juvenile and adult red drum because 

37 they are capable of swimming out of the current created by the RMPF and can avoid the 
Appendix F 

March 2010 F-69 Draft NUREG-1937 

1 thermal, chemical and physical changes of the river water from the discharge of the MCR. 

2 However, eggs and larvae could become entrained at the RMPF and could be affected by the 

3 thermal, chemical and physical characteristics of the discharge plume, if they are transported up 

4 the Colorado River to the vicinity of the STP site. Maintenance dredging at the RMPF could be 

5 easily avoided by the juvenile and adult red drum, but some eggs and larvae would be lost. It is 

6 unlikely that the small loss (from operation of the RMPF, discharge structure, and dredges) of 

7 eggs and larvae would be detectable given the high fecundity of the red drum. Therefore, 

8 construction and operation of proposed STP Units 3 and 4 would likely have minimal adverse 

9 impact on red drum juvenile and adult EFH. STP operations would likely have a minimal 

10 adverse effect on EFH for red drum eggs, larvae, juveniles, and adults. 

11 5.3.5 Shrimp 

12 Juvenile and adult brown, pink, and white shrimp may forage within the Colorado River at or 

13 near the RMPF and barge slip. Disruption of habitat for foraging in these areas of the Colorado 

14 River is expected to be minor, temporary, and largely mitigable. Brown, pink, and white shrimp 

15 have been collected in the MCR and all along the Colorado River during the 1983-1984 and 

16 2007-2008 sampling studies (ENSR 2008a, b). Construction activities at the RMPF and barge 

17 slip could remove habitat through turbidity and sedimentation resulting in siltation on the river 

18 bottom. The sheet pile wall that could be erected during barge slip modification would 

19 temporarily remove habitat for the shrimp. Barges moving heavy equipment and bulk 

20 commodities are likely to be moving slow and prop wash and wave action from the vessel’s 

21 movement would not affect any of the life stages of shrimp as they are benthic. Larvae and 

22 juvenile brown, pink, and white shrimp would be lost if entrained at the RMPF. Operation of the 

23 RMPF is not likely to entrain appreciable numbers of shrimp larvae, as brown and white shrimp 

24 were more abundant at the confluence of the river and the GIWW than further up the river 

25 (ENSR 2008a), and only four pink shrimp were reported in impingement studies (NRC 1986). 

26 Maintenance dredging would remove habitat at the point where substrate is dredged and could 

27 also temporarily remove habitat from turbidity and sedimentation. Therefore, construction and 

28 operation of the proposed Units 3 and 4 at the STP site are likely to have a greater than 

29 minimal, but less than substantial, adverse effect on EFH for the brown, pink, and white shrimp 

30 larvae and juveniles EFH. 

31 5.3.6 Gulf Stone Crab 

32 It is possible that construction activities in the Colorado River associated with intake structure 

33 placement and barge slip modifications may disrupt foraging in these areas of the Colorado 

34 River, but the disruption is expected to be minor, temporary, and largely mitigable. Gulf stone 

35 crab eggs and larvae may drift into the upper portion of the Colorado River, and become 

36 entrained in the cooling water intake system at the RMPF. However, it is unlikely that 

37 appreciable numbers of eggs or larvae would be entrained as no Gulf stone crabs were 
Appendix F 

Draft NUREG-1937 F-70 March 2010

1 collected in the Colorado River during the 1983-1984 or 2007-2008 studies (NRC 1986; ENSR 

2 2008a, b). Operation of the discharge structure would likely have minimal effect on the mobile 

3 adult and juvenile life stages. While eggs and larvae could be harmed by the thermal and 

4 chemical plume, it is unlikely that these life stages are present in the vicinity of the discharge 

5 structure. Therefore, construction and operation of the proposed STP Units 3 and 4 would likely 

6 have a minimal adverse effect on stone crab EFH for eggs, larvae, juveniles, and adults. 

7 6.0 Mitigation Measures 

8 Potential mitigation measures regarding water withdrawal at the RMPF, chemical and thermal 

9 reductions within the discharge to the Colorado River, frequency and conditions of discharge, 

10 and dredging techniques could reduce adverse effects on EFH and Federally-managed fish and 

11 shellfish species. Because the proposed cooling system would be closed-cycle and use the 

12 best technology available, the review team could not identify any potential mitigation measures 

13 to further reduce entrainment and entrapment. However, a potential mitigation measure that 

14 might increase impingement survival would be to alter the fish-return operational procedure 

15 such that the fish return always functions when the RMPF is withdrawing water. The review 

16 team also identified that the discharge operational procedure could be modified to reduce 

17 potential impacts on aquatic biota; such modifications could include mixing ambient river water 

18 with the discharge water before discharging it to the river to reduce the discharge temperature. 

19 Although the NRC lacks the statutory authority to require any of the above potential mitigation 

20 measures, the staff recognizes that such potential mitigation could further reduce adverse 

21 impacts on designated EFH and on Federally-managed fish and shellfish species in the 

22 Colorado River, the GIWW, and Matagorda Bay. 

23 The Corps permit, if issued, could include special conditions such as time-of-year restrictions or 

24 specific methods of work to ameliorate potential impacts to EFH for the authorized construction 

25 and maintenance dredging activities. EFH Conservation Recommendations necessary to 

26 protect EFH may also be included as conditions in the Corps permit, if issued. Mitigation may 

27 only be employed after all appropriate and practical steps to avoid and minimize adverse 

28 impacts to aquatic resources have been taken. All remaining unavoidable impacts must be 

29 compensated to the extent appropriate and practicable. 

30 7.0 Conclusions 

31 The potential impacts of the construction and operation of the proposed Units 3 and 4 at the 

32 STP site on Federally-managed fish and shellfish species and their EFH near the site have 

33 been evaluated. Based on the project design, the minimal short-term impacts associated with 
Appendix F 

March 2010 F-71 Draft NUREG-1937 

1 the construction activities, barging, operation of the RMPF and discharge structure, and 

2 maintenance dredging at the RMPF, and the mitigation measures planned for proposed Units 3 

3 and 4, the review team concludes that construction and operation of STP would likely have 

4 more than minimal, but less than substantial, adverse effects on EFH within the Colorado River 

5 by loss of forage and/or shelter habitat for three of the eight species considered, brown, pink, 

6 and white shrimp, specifically larvae and juveniles (Table 5). Construction and operation 

7 activities would likely have minimal adverse effect on the remaining species considered. The 

8 NRC lacks the statutory authority to require any mitigation measures that would minimize 

9 adverse effects on EFH. The Corps does not recommend any mitigative measures to minimize 

10 adverse effects on EFH at this time. This determination may be modified if additional 

11 information indicates otherwise and would change the preliminary determination. 

Table 1. Effects on EFH from Proposed Actions 

Common Name Life Stage Expected Impact 

king mackerel juveniles Minimal Adverse Effect 

Spanish mackerel eggs Minimal Adverse Effect 

Release of MCR water could temporarily change water 

column and have short-term effects. Entrained eggs 

would be removed, and therefore lost, from the river. 

 larvae Minimal Adverse Effect 

Release of MCR water could temporarily change water 

column and have short-term effects. Entrained larvae 

would be removed, and therefore lost, from the river. 

 juveniles Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 

 adults Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 

gray (mangrove) snapper eggs Minimal Adverse Effect 

Entrained eggs would be removed, and therefore lost, 

from the river. 

 larvae Minimal Adverse Effect 

Release of MCR water could temporarily change water 

column and have short-term effects. Entrained larvae 

would be removed, and therefore lost, from the river. 

 juveniles Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 

 adults Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 
Appendix F 

Draft NUREG-1937 F-72 March 2010

Table 1. Effects on EFH from Proposed Actions 

Common Name Life Stage Expected Impact 

foraging habitat temporarily. 

red drum eggs Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. Release of MCR water 

could temporarily change water column and have shortterm affects. Entrained eggs would be removed, and 

therefore lost, from the river. 

 larvae Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. Release of MCR water 

could temporarily change water column and have shortterm affects. Entrained eggs would be removed, and 

therefore lost, from the river. 

 juveniles Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 

 adults Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 

brown shrimp larvae Greater than Minimal but Less than Substantial, 

Adverse Effect 

Construction activities in Colorado River could remove 

habitat over the short-term. Maintenance dredging 

would remove habitat and could temporarily remove 

habitat due to turbidity and sedimentation. 

 juveniles Greater than Minimal but Less than Substantial, 

Adverse Effect 

Construction activities in Colorado River could remove 

habitat over the short-term. Maintenance dredging 

would remove habitat and could temporarily remove 

habitat due to turbidity and sedimentation. 

pink shrimp larvae Greater Than Minimal but Less Than Substantial, 

Adverse Effect 

Construction activities in Colorado River could remove 

habitat over the short-term. Maintenance dredging 

would remove habitat and could temporarily remove 

habitat due to turbidity and sedimentation. 

 juveniles Greater than Minimal but Less than Substantial, 

Adverse Effect 

Construction activities in Colorado River could remove 

habitat over the short-term. Maintenance dredging 
Appendix F 

March 2010 F-73 Draft NUREG-1937 

Table 1. Effects on EFH from Proposed Actions 

Common Name Life Stage Expected Impact 

would remove habitat and could temporarily remove 

habitat due to turbidity and sedimentation. 

white shrimp larvae Greater Than Minimal but Less Than Substantial, 

Adverse Effect 

Construction activities in Colorado River could remove 

habitat over the short-term. Maintenance dredging 

would remove habitat and could temporarily remove 

habitat due to turbidity and sedimentation. 

 juveniles Greater Than Minimal but Less Than Substantial,, 

Adverse Effect 

Construction activities in Colorado River could remove 

habitat over the short-term. Maintenance dredging 

would remove habitat and could temporarily remove 

habitat due to turbidity and sedimentation. 

Gulf stone crab eggs Minimal Adverse Effect 

Release of MCR water could temporarily change water 

column and have short-term affectseffects. Entrained 

eggs would be removed, and therefore lost, from the 

river. 

 larvae Minimal Adverse Effect 

Release of MCR water could temporarily change water 

column and have short-term affectseffects. Entrained 

larvae would be removed, and therefore lost, from the 

river. 

 juveniles Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 

 adults Minimal Adverse Effect 

Construction activities in Colorado River could disrupt 

foraging habitat temporarily. 
Appendix F 

Draft NUREG-1937 F-74 March 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 69 FR 41576. July 9, 2004. “National Pollutant Discharge Elimination System—Final 

9 Regulations to Establish Requirements for Cooling Water Intake Structures at Phase II Existing 

10 Facilities.” Federal Register. U.S. Environmental Protection Agency, Washington, D.C. 

11 72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

12 Federal Register. U.S. Nuclear Regulatory Commission, Washington, D.C. 

13 Buckley, J. 1984. Habitat Suitability Index Models: Larval and Juvenile Red Drum. 

14 FWS/OBS-82-10.74, U.S. Fish and Wildlife Service, Washington, D.C. 

15 Cascorbi, A. 2004. “Wild-Caught Warmwater Shrimp (Infraorder Penaeus – the Penaid 

16 Shrimps).” Seafood Watch, Seafood Report. Monterey Bay Aquarium, Monterey, California. 

17 Coastal Zone Management Act of 1972, as amended. 16 USC 1451, et seq. 

18 Croker, R. 1962. “Growth and Food of the Gray Snapper, Lutjanus Griseus, in the Everglades 

19 National Park.” Transactions of the American Fisheries Society 91(4):379-383. 

20 DeVries, D., CB Grimes, KL Lang, and DB White. 1990. “Age and Growth of King and Spanish 

21 Mackerel Larvae and Juveniles from the Gulf of Mexico and U.S. South Atlantic Bight.” 

22 Environmental Biology of Fishes 29(1990):135-143. 

23 ENSR Corporation (ENSR). 2008a. Aquatic Ecology – Main Cooling Reservoir and Circulating 

24 Water Intake Structure Study, Unit 3 and 4 Licensing Project. Houston, Texas. 

25 ENSR Corporation (ENSR). 2008b. Aquatic Ecology – Colorado River Monitoring Report, 

26 Unit 3 and 4 Licensing Project. Houston, Texas. 

27 Federal Water Pollution Control Act (Clean Water Act). 33 USC 1251, et seq. 
Appendix F 

March 2010 F-75 Draft NUREG-1937 

1 Florida Fish and Wildlife Conservation Commission (FFWCC). 2007. “Red Drum, Sciaenops 

2 Ocellatus.” Florida Fish and Wildlife Conservation Commission. 

3 Florida Museum of Natural History (FMNH). 2009. “Ichthyology at the Florida Museum of 

4 Natural History, Education, Biological Profiles: King Mackerel.” Accessed January 29, 2010 at 

5 http://www.flmnh.ufl.edu/fish/gallery/descript/kingmackerel/kingmackerel.html. Accession No. 

6 ML100600370. 

7 Guillory, V., H.M. Perry, and R.L. Leard. 1995. “A Profile of the Western Gulf Stone Crab, 

8 Menippe adina.” Number 31, Gulf States Marine Fisheries Commission, Ocean Springs, 

9 Mississippi. 

10 Gulf of Mexico Fishery Management Council (GMFMC). 2004. Final Environmental Impact 

11 Statement for the Generic Essential Fish Habitat Amendment to the Following Fishery 

12 Management Plans of the Gulf of Mexico (GOM): Shrimp Fishery of the Gulf of Mexico, Red 

13 Drum Fishery of the Gulf of Mexico, Reef Fish Fishery of the Gulf of Mexico, Stone Crab Fishery 

14 of the Gulf of Mexico, Coral and Coral Reef Fishery of the Gulf of Mexico, Spiny Lobster Fishery 

15 of the Gulf of Mexico and South Atlantic Coastal Migratory Pelagic Resources of the Gulf of 

16 Mexico and South Atlantic. National Oceanic and Atmospheric Administration, Tampa, Florida. 

17 Gulf States Marine Fisheries Commission (GSMFC). 1995. A Profile of the Western Gulf Stone 

18 Crab, Menippe Adina. Number 31, National Oceanic and Atmospheric Administration, Ocean 

19 Springs, Mississippi. 

20 Kim, H.C., and P.A. Montagna. 2009. “Implications of Colorado River (Texas, USA) Freshwater 

21 Inflow to Benthic Ecosystem Dynamics: A Modeling Study.” Estuarine, Coastal and Shelf 

22 Science 83:491–504. 

23 Lower Colorado River Authority (LCRA). 2006. Matagorda Bay Freshwater Inflow Needs 

24 Study. Lower Colorado River Authority, Texas Commission on Environmental Quality, Texas 

25 Parks and Wildlife, and Texas Water Development Board, Austin, Texas. Available at 

26 http://www.lcra.org/library/media/public/docs/fins_2006.pdf. Accession No. ML100600370. 

27 Magnuson-Stevens Fishery Conservation and Management Act, as amended. 16 USC 1801 et 

28 seq. 

29 National Marine Fisheries Service (NMFS). 1999. Essential Fish Habitat: New Marine Fish 

30 Habitat Conservation Mandate for Federal Agencies. National Marine Fisheries Service, Habitat 

31 Conservation Division, Southeast Regional Office, St. Petersburg, Florida. 
Appendix F 

Draft NUREG-1937 F-76 March 2010

1 National Marine Fisheries Service (NMFS). 2004. Essential Fish Habitat Consultation 

2 Guidance Version 1.1. National Marine Fisheries Service, Office of Habitat Conservation, 

3 Silver Spring, Maryland. 

4 National Marine Fisheries Service (NMFS). 2009. “Essential Fish Habitat EFH Mapper.” 

5 NOAA Fisheries Services, Office of Habitat Conservation, Habitat Protection Division. 

6 Accessed May 20, 2009 at http://sharpfin.nmfs.noaa.gov/website/EFH_Mapper/map.aspx. 

7 Accession No. ML100600370. 

8 Patillo, M.E., T.E. Czapla, D.M. Nelson, and M.E. Monaco. 1997. Distribution and Abundance 

9 of Fishes and Invertebrates in Gulf of Mexico Estuaries, Volume II: Species Life History 

10 Summaries. ELMR Rep. No. 11. NOAA/NOS Strategic Environmental Assessments Division, 

11 Silver Spring, Maryland. 

12 Permits for Dredged or Fill Material. 33 USC 1344. 

13 Rivers and Harbors Appropriation Act of 1899, as amended. 33 USC 403, et seq. 

14 South Texas Project Nuclear Operating Company (STPNOC). 2008a. Letter from Greg 

15 Gibson, STPNOC, to NRC, dated July 2, 2008 in response to NRC letter dated May 19, 2008, 

16 "South Texas Project Units 3 and 4, Docket Nos. 52-012 and 52-013, Response to Requests for 

17 Additional Information.” Accession No. ML081970465. 

18 South Texas Project Nuclear Operating Company (STPNOC). 2008b. Letter from Greg 

19 Gibson, STPNOC, to NRC, dated July 15, 2008, Response to Requests for Additional 

20 Information.” Accession No. ML082040684. 

21 South Texas Project Nuclear Operating Company (STPNOC). 2008c. Letter from Scott Head 

22 STPNOC, to NRC, dated December 18, 2008, Responses to Requests for Additional 

23 Information.” Accession No. ML090860873. 

24 South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

25 Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

26 City, Texas. Accession No. ML092931600. 

27 South Texas Project Nuclear Operating Company (STPNOC). 2009b. Letter from Scott Head, 

28 STPNOC, to NRC, dated September 14, 2009, “Responses to Request for Additional 

29 Information.” Accession No. ML092580491. 

30 South Texas Project Nuclear Operating Company (STPNOC). 2009c. Letter from Scott Head, 

31 STPNOC, to US Army Corps, dated October 28, 2009, “Subject: South Texas Project, Permit 
Appendix F 

March 2010 F-77 Draft NUREG-1937 

1 Determination Request, Construction Activities in Association with STP Units 3 & 4.” Accession 

2 No. ML093210232. 

3 South Texas Project Nuclear Operating Company (STPNOC). 2009d. Letter from Scott Head, 

4 STPNOC, to NRC, dated July 30, 2009, “Subject: South Texas Project, NRC Docket No. 52-

5 012 and 52-013, Submittal of Requests for Additional Information (RAI), Pertaining COLA Part 3 

6 Environmental Report.” Accession No. ML092150963. 

7 Texas Commission on Environmental Quality (TCEQ). 2005. TPDES Permit 

8 No. WQ0001908000. TCEQ, Austin, Texas. 

9 Texas Commission on Environmental Quality (TCEQ). 2007. Cooling Water Intake Structures 

10 Phase II Rules; South Texas Project Electric Generating Station; TPDES Permit No. WQOOO 

11 1908000. Letter from Mr. Kelly Holligan, TCEQ to Mr. R. A. Gangluff, STPNOC. June 27. 

12 Texas Commission on Environmental Quality (TCEQ). 2008. General Permit to Discharge 

13 Wastes under provisions of Section 402 of the Clean Water Act and Chapter 26 of the Texas 

14 Water Code. TCEQ Docket No. 2007-1588-WQ, TPDES General Permit No. TXR150000, 

15 Issues February 15, 2008. Austin, Texas. 

16 Texas Parks and Wildlife Department (TPWD). 2009. “Saltwater Fishing.” Texas Parks and 

17 Wildlife Department, Austin, Texas. Accessed January 27, 2010 at 

18 http://www.tpwd.state.tx.us/publications/annual/fish/limits_saltwater/index.phtml#limits. 

19 Accession No. ML100600370. 

20 Texas Saltwater and Fishing Guides Web (TSFGW). 2005. “King Mackerel (Kingfish).” 

21 Accessed November 24, 2009 at 

22 http://www.txsaltwaterfishingguides.com/FishFacts/kingfish.htm. Accession No. ML100600370. 

23 U.S. Army Corps of Engineers (Corps). 2005. “Galveston District Projects, Mouth of the 

24 Colorado River.” U.S. Army Corps of Engineers, Galveston District, Galveston, Texas. 

25 Accessed December 16, 2009 at http://www.swg.usace.army.mil/items/coloradoriver/MOC.asp. 

26 Accession No. ML100600370. 

27 U.S. Army Corps of Engineers (Corps). 2007. Draft Environmental Impact Statement for 

28 Calhoun County Navigation District’s Proposed Matagorda Ship Channel Improvement Project 

29 Calhoun and Matagorda Counties, Texas. Document No. 060146, U.S. Army Corps of 

30 Engineers, Galveston District, Galveston, Texas. 

31 U.S. Army Corps of Engineers (Corps). 2008. Final Environmental Impact Statement for the 

32 Proposed Port Freeport Channel Widening, Brazoria County, Texas. U.S. Army Corps of 

33 Engineers, Galveston District, Galveston, Texas. 
Appendix F 

Draft NUREG-1937 F-78 March 2010

1 U.S. Army Corps of Engineers (Corps). 2009a. “December 2009 Hydrographic Bulletin: 

2 Channels with Project Depths Under 25 Feet.” U.S. Army Corps of Engineers, Galveston 

3 District, Galveston, Texas. 

4 U.S. Army Corps of Engineers (Corps). 2009b. Letter from K. Jaynes, Chief, Compliance 

5 Section, U.S. Army Corps of Engineers Galveston District to G. Gibson, South Texas Project 

6 Operating Company dated April 7, 2009, “Subject: SWG-2008-1351, South Texas Project 

7 Operating Company, Jurisdictional Determination, 7,000-Acre Mass Cooling Reservoir (MCR), 

8 Wadsworth, Matagorda County, Texas.” Accession No. ML091050501. 

9 U.S. Fish and Wildlife Service (FWS). 1983. Habitat Suitability Index Models: Northern Gulf of 

10 Mexico Brown Shrimp and White Shrimp. FWS/OBS-82/10.54, Slidell, Louisiana. 

11 U.S. Nuclear Regulatory Commission (NRC). 1975. South Texas Project, Units 1 and 2: Final 

12 Environmental Statement. NUREG-75/019, Houston Lighting & Power Company, City Public 

13 Service Board of San Antonio, Central Power and Light Company, City of Austin. 

14 U.S. Nuclear Regulatory Commission (NRC). 1986. Final Environmental Statement Related to 

15 the Operation of South Texas Project, Units 1 and 2. NUREG-1171, Washington, D.C. 

16 Wilber, D. 1989. “Reproductive Biology and Distribution of Stone Crabs (Xanthidae, Menippe) 

17 in the Hybrid Zone on the Northeastern Gulf of Mexico.” Marine Ecology Progress Series

18 52(1989):235-244. 

19 Wilber, D.H. and R. Bass. 1998. “Effect of the Colorado River Diversion on Matagorda Bay 

20 Epifauna.” Coastal and Shelf Science 47:309-318. 
Appendix G 

Supporting Documentation for Socioeconomic and 

Radiological Dose Assessment 

March 2010 G-1 Draft NUREG-1937 

Appendix G 

Supporting Documentation for Socioeconomics and 

Radiological Dose Assessment 

1 This appendix contains supporting documentation for review team determinations described in 

2 this environmental impact statement (EIS) for the socioeconomic and radiological dose 

3 assessments. 

4 G.1 Socioeconomic Data Tables 

5 This section contains two data tables (Table G-1 and Table G-2) related to socioeconomics as 

6 discussed in Section 2.5. 

7 
Draft NUREG-1937 G-2 March 2010 

Appendix G Table G-1. Current Populations by Distance and Direction and Projections to 2080 (STPNOC 2009a) 1 Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 

N 2000 0 0 15 0 0 32 47 1237 536 14097 5445 21362 2010 0 0 16 0 0 34 50 1311 563 14899 6121 22944 2020 0 0 17 0 0 36 53 1397 596 15866 6946 24858 2030 0 0 18 0 0 38 56 1484 629 16867 7914 26950 2040 0 0 19 0 0 41 60 1583 667 18048 9103 29461 2050 0 0 20 0 0 44 64 1681 706 19276 10482 32209 2060 0 0 22 0 0 46 68 1792 744 20573 12145 35322 2070 0 0 23 0 0 49 72 1903 783 21939 14094 38791 2080 0 0 25 0 0 52 77 2026 828 23543 16500 42974NNE 2000 0 0 0 0 205 542 747 21441 1120 2540 10968 36816 2010 0 0 0 0 217 575 792 22727 1207 2917 13351 40994 2020 0 0 0 0 232 613 845 24228 1310 3374 16273 46030 2030 0 0 0 0 246 650 896 25729 1420 3912 19841 51798 2040 0 0 0 0 262 694 956 27444 1545 4548 24265 58758 2050 0 0 0 0 279 737 1016 29160 1677 5277 29545 66675 2060 0 0 0 0 297 786 1083 31089 1829 6155 36110 76266 2070 0 0 0 0 316 835 1151 33019 1993 7181 43962 87306 2080 0 0 0 0 336 889 1225 35163 2177 8397 53732 100694NE 2000 0 0 0 0 31 99 130 931 6687 11447 24758 43953 2010 0 0 0 0 33 105 138 987 7527 13164 28556 50372 2020 0 0 0 0 35 112 147 1052 8531 15225 33122 58077 2030 0 0 0 0 37 119 156 1117 9682 17628 38466 67049 2040 0 0 0 0 40 127 167 1192 10997 20376 44614 77346 2050 0 0 0 0 42 135 177 1266 12458 23466 51565 88932

2 
Appendix G 

March 2010 G-3 Draft NUREG-1937 Table G-1. (contd) Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 2060 0 0 0 0 45 144 189 1350 14181 27129 59839 102688 2070 0 0 0 0 48 152 200 1434 16148 31365 69435 118582 2080 0 0 0 0 51 162 213 1527 18377 36173 80426 136716 ENE 2000 0 0 0 0 0 472 472 271 2480 16635 62994 82852 2010 0 0 0 0 0 500 500 287 2732 19130 72443 95092 2020 0 0 0 0 0 533 533 306 3032 22125 83782 109778 2030 0 0 0 0 0 566 566 325 3366 25618 97011 126886 2040 0 0 0 0 0 604 604 347 3748 29610 112129 146438 2050 0 0 0 0 0 642 642 369 4164 34102 129138 168415 2060 0 0 0 0 0 684 684 393 4651 39425 149296 194449 2070 0 0 0 0 0 727 727 417 5195 45580 172604 224523 2080 0 0 0 0 0 774 774 444 5810 52567 199061 258656 E 2000 0 0 0 15 3 245 263 83 1243 87 46 1722 2010 0 0 0 16 3 260 279 88 1322 99 53 1841 2020 0 0 0 17 3 277 297 94 1415 114 61 1981 2030 0 0 0 18 4 294 316 100 1510 132 71 2129 2040 0 0 0 19 4 314 337 106 1618 151 82 2294 2050 0 0 0 20 4 333 357 113 1728 174 94 2466 2060 0 0 0 22 4 355 381 120 1852 200 109 2662 2070 0 0 0 23 5 377 405 128 1979 230 126 2868 2080 0 0 0 25 5 402 432 136 2120 264 145 3097 ESE 2000 0 0 0 99 164 146 409 2 0 0 0 411 2010 0 0 0 105 174 155 434 2 0 0 0 436 2020 0 0 0 112 185 165 462 2 0 0 0 464
Draft NUREG-1937 G-4 March 2010 

Appendix G Table G-1. (contd) Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 

 2030 0 0 0 119 197 175 491 2 0 0 0 493 2040 0 0 0 127 210 187 524 3 0 0 0 527 2050 0 0 0 135 223 199 557 3 0 0 0 560 2060 0 0 0 144 238 212 594 3 0 0 0 597 2070 0 0 0 153 253 225 631 3 0 0 0 634 2080 0 0 0 162 269 239 670 3 0 0 0 673 SE 2000 0 0 0 3 248 2055 2306 13 0 0 0 2319 2010 0 0 0 3 263 2178 2444 14 0 0 0 2458 2020 0 0 0 3 280 2322 2605 15 0 0 0 2620 2030 0 0 0 4 298 2466 2768 16 0 0 0 2784 2040 0 0 0 4 317 2630 2951 17 0 0 0 2968 2050 0 0 0 4 338 2795 3137 18 0 0 0 3155 2060 0 0 0 4 360 2680 3044 19 0 0 0 3063 2070 0 0 0 5 382 3165 3552 20 0 0 0 3572 2080 0 0 0 5 407 3370 3782 21 0 0 0 3803SSE 2000 0 0 0 0 0 204 204 117 0 0 0 321 2010 0 0 0 0 0 216 216 124 0 0 0 340 2020 0 0 0 0 0 231 231 132 0 0 0 363 2030 0 0 0 0 0 245 245 140 0 0 0 385 2040 0 0 0 0 0 261 261 150 0 0 0 411 2050 0 0 0 0 0 277 277 159 0 0 0 436 2060 0 0 0 0 0 296 296 170 0 0 0 466 2070 0 0 0 0 0 314 314 180 0 0 0 494 2080 0 0 0 0 0 335 335 192 0 0 0 527
Appendix G 

March 2010 G-5 Draft NUREG-1937 Table G-1. (contd) Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 S 2000 0 0 0 0 0 40 40 0 0 0 0 40 2010 0 0 0 0 0 42 42 0 0 0 0 42 2020 0 0 0 0 0 45 45 0 0 0 0 45 2030 0 0 0 0 0 48 48 0 0 0 0 48 2040 0 0 0 0 0 51 51 0 0 0 0 51 2050 0 0 0 0 0 54 54 0 0 0 0 54 2060 0 0 0 0 0 58 58 0 0 0 0 58 2070 0 0 0 0 0 62 62 0 0 0 0 62 2080 0 0 0 0 0 66 66 0 0 0 0 66 SSW SW 2000 0 0 0 0 0 0 0 1 0 0 0 1 2010 0 0 0 0 0 0 0 1 0 0 0 1 2020 0 0 0 0 0 0 0 1 0 0 0 1 2030 0 0 0 0 0 0 0 1 0 0 0 1 2040 0 0 0 0 0 0 0 1 0 0 0 1 2050 0 0 0 0 0 0 0 1 0 0 0 1 2060 0 0 0 0 0 0 0 1 0 0 0 1 2070 0 0 0 0 0 0 0 2 0 0 0 2 2080 0 0 0 0 0 0 0 2 0 0 0 2 SW 2000 0 0 1 0 0 118 119 345 0 1111 628 2203 2010 0 0 1 0 0 125 126 366 0 1189 672 2353 2020 0 0 1 0 0 133 134 390 0 1255 710 2489 2030 0 0 1 0 0 142 143 414 0 1344 760 2661 2040 0 0 1 0 0 151 152 442 0 1433 810 2837 2050 0 0 1 0 0 161 162 469 0 1522 860 3013
Draft NUREG-1937 G-6 March 2010 

Appendix G Table G-1. (contd) Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 

 2060 0 0 1 0 0 171 172 500 0 1622 917 3211 2070 0 0 2 0 0 182 184 531 0 1722 973 3410 2080 0 0 2 0 0 194 196 566 0 1844 1042 3648WSW 2000 0 0 0 4 6 240 250 5671 1074 14758 3240 24993 2010 0 0 0 4 6 254 264 5999 1142 15784 3474 26663 2020 0 0 0 5 7 271 283 6378 1206 16676 3683 28226 2030 0 0 0 5 7 288 300 6762 1285 17852 3953 30152 2040 0 0 0 5 8 307 320 7186 1364 19029 4226 32125 2050 0 0 0 5 8 326 339 7624 1446 20212 4503 34124 2060 0 0 0 6 9 348 363 8105 1535 21538 4813 36354 2070 0 0 0 6 9 370 385 8585 1624 22866 5126 38586 2080 0 0 0 7 10 394 411 9124 1732 24484 5504 41255 W 2000 0 0 0 5 0 130 135 261 829 1302 3614 6141 2010 0 0 0 5 0 138 143 275 870 1373 3925 6586 2020 0 0 0 6 0 147 153 292 920 1457 4272 7094 2030 0 0 0 6 0 156 162 310 970 1542 4652 7636 2040 0 0 0 6 0 166 172 328 1020 1629 5064 8213 2050 0 0 0 7 0 177 184 348 1078 1729 5512 8851 2060 0 0 0 7 0 189 196 369 1136 1830 5993 9524 2070 0 0 0 8 0 200 208 390 1194 1933 6507 10232 2080 0 0 0 8 0 213 221 413 1260 2051 7089 11034WNW 2000 0 0 0 0 4 878 882 1181 492 9669 1259 13483 2010 0 0 0 0 4 931 935 1248 517 10152 1325 14177 2020 0 0 0 0 5 992 997 1327 546 10733 1403 15006
Appendix G 

March 2010 G-7 Draft NUREG-1937 Table G-1. (contd) Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 2030 0 0 0 0 5 1054 1059 1406 576 11313 1482 15836 2040 0 0 0 0 5 1124 1129 1492 605 11893 1562 16681 2050 0 0 0 0 5 1194 1199 1583 640 12570 1654 17646 2060 0 0 0 0 6 1273 1279 1681 674 13247 1747 18628 2070 0 0 0 0 6 1352 1358 1780 708 13923 1841 19610 2080 0 0 0 0 7 1440 1447 1890 748 14697 1948 20730 NNW 2000 0 0 0 19 30 227 276 477 787 1455 222 3217 2010 0 0 0 20 32 241 293 505 826 1528 230 3382 2020 0 0 0 21 34 257 312 537 874 1615 240 3578 2030 0 0 0 23 36 272 331 569 921 1702 250 3773 2040 0 0 0 24 38 291 353 606 975 1801 261 3996 2050 0 0 0 26 41 309 376 644 1030 1903 272 4225 2060 0 0 0 28 44 329 401 685 1085 2005 283 4459 2070 0 0 0 29 46 350 425 725 1140 2107 295 4692 2080 0 0 0 31 49 372 452 771 1203 2223 308 4957 NNW 2000 0 0 0 0 0 34 34 484 4469 11928 2211 19126 2010 0 0 0 0 0 36 36 512 4692 12524 2305 20069 2020 0 0 0 0 0 38 38 545 4961 13240 2415 21199 2030 0 0 0 0 0 41 41 577 5229 13956 2526 22329 2040 0 0 0 0 0 44 44 615 5542 14791 2653 23645 2050 0 0 0 0 0 46 46 653 5854 15626 2780 24959 2060 0 0 0 0 0 49 49 694 6167 16461 2907 26278 2070 0 0 0 0 0 52 52 735 6480 17296 3040 27603 2080 0 0 0 0 0 56 56 781 6838 18250 3183 29108
Draft NUREG-1937 G-8 March 2010 

Appendix G Table G-1. (contd) Radii/Distances (miles) Sectors 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50 

TOTAL 2000 0 0 16 145 691 5462 6314 32515 19717 85029 115385 258960 2010 0 0 17 153 732 5790 6692 34446 21398 92759 132455 287750 2020 0 0 18 164 781 6172 7135 36696 23391 101680 152907 321809 2030 0 0 19 175 830 6554 7578 38952 25588 111866 176926 360910 2040 0 0 20 185 884 6992 8081 41512 28081 123309 204769 405752 2050 0 0 21 197 940 7429 8587 44091 30781 135857 236405 455721 2060 0 0 23 211 1003 7620 8857 46971 33854 150185 274159 514026 2070 0 0 25 224 1065 8412 9726 49852 37244 166142 318003 580967 2080 0 0 27 238 1134 8958 10357 53059 41093 184493 368938 657940Source: STPNOC (2009a) 

1 
Appendix G 

March 2010 G-9 Draft NUREG-1937 

1 Table G-2. Total STP Workforce During Construction Period for Proposed Units 3 and 4, and 

2 18 Months Beyond 

Event(a) Month 

Unit 1 and 2 

Staffing(b)

Unit 3 and 4 

Staffing(c)

Construction 

Workforce(d)

Outage 

Workforce(e)

Total 

Workforce 

Site 

Preparation 

Starts 

-24 1350 99 100 1549 

-23 1353 107 200 1660 

-22 1356 116 300 1772 

-21 1359 124 400 1883 

-20 1362 133 500 45 2040 

-19 1364 142 600 310 2416 

-18 1367 150 700 1080 3297 

1RE15 -17 1367 159 800 1350 3676 

-16 1368 167 900 60 2495 

-15 1368 176 1000 2544 

-14 1368 184 1100 45 2698 

-13 1369 193 1200 310 3072 

-12 1369 202 1300 1080 3951 

2RE14 -11 1369 212 1400 1350 4331 

-10 1370 221 1500 60 3151 

-9 1370 230 1600 3200 

[2] -8 1370 240 1700 3310 

-7 1371 249 1800 3420 

-6 1371 258 1900 3529 

-5 1368 268 2000 3636 

-4 1365 277 2100 3742 

-3 1362 286 2200 3848 

-2 1358 296 2300 35 3989 

-1 1355 305 2400 170 4230 

COL Issued/ 

Start Constr 

1 1352 314 2500 850 5016 

1RE16 2 1349 322 2650 1100 5421 

3 1346 331 2800 60 4536 

4 1343 339 2950 4632 

5 1339 348 3100 35 4822 

6 1336 356 3250 170 5112 

7 1333 365 3400 850 5948 

3 
Appendix G 

Draft NUREG-1937 G-10 March 2010 

1 

Table G-2. (contd)

Event(a) Month 

Unit 1 and 2 

Staffing(b)

Unit 3 and 4 

Staffing(c)

Construction 

Workforce(d)

Outage 

Workforce(e)

Total 

Workforce 

2RE15 8 1328 373 3550 1100 6351 

9 1324 382 3700 60 5465 

10 1319 390 3830 5539 

11 1315 399 3960 5673 

12 1310 407 4090 5807 

13 1306 431 4220 5957 

14 1301 455 4350 6106 

15 1296 479 4480 6256 

16 1292 503 4610 6405 

17 1287 527 4740 35 6590 

18 1283 552 4870 170 6874 

19 1278 576 5000 850 7704 

1RE17 20 1272 600 5130 1100 8102 

21 1267 624 5260 60 7210 

22 1261 648 5390 7299 

23 1255 672 5520 35 7482 

24 1250 696 5650 170 7766 

25 1244 715 5800 850 8609 

2RE16 26 1238 733 5950 1100 9021 

27 1233 752 5950 60 7994 

28 1227 770 5950 7947 

29 1221 789 5950 7960 

30 1216 807 5950 7973 

31 1210 826 5950 7986 

32 1204 844 5950 7998 

33 1199 863 5950 8011 

34 1193 881 5950 8024 

35 1187 900 5950 35 8072 

36 1181 918 5850 170 8119 

37 1176 921 5750 850 8697 

1RE18 38 1170 925 5650 1100 8845 

39 1164 928 5450 60 7602 

40 1158 932 5250 7340 

41 1153 935 5050 35 7173 

42 1147 939 4850 170 7105 

43 1141 942 4650 850 7583 
Appendix G 

March 2010 G-11 Draft NUREG-1937 

1 

Table G-2. (contd)

Event(a) Month 

Unit 1 and 2 

Staffing(b)

Unit 3 and 4 

Staffing(c)

Construction 

Workforce(d)

Outage 

Workforce(e)

Total 

Workforce 

2RE17 44 1135 945 4450 1100 7630 

U3 Fuel Load 45 1128 949 4250 60 6387 

46 1122 952 4050 6124 

47 1115 956 3900 5971 

48 1109 959 3800 5868 

49 1102 959 3700 5761 

50 1096 959 3600 5655 

51 1089 959 3500 5548 

52 1083 959 3400 5442 

53 1076 959 3300 35 5370 

CO U3 54 1070 959 3200 170 5399 

55 1063 959 3000 850 5872 

1RE19 56 1063 959 2800 1100 5922 

57 1063 959 2600 60 4682 

U4 Fuel Load 58 1063 959 2400 4422 

59 1063 959 2200 35 4257 

60 1063 959 2000 170 4192 

61 1062 959 1800 850 4671 

2RE18 62 1062 959 1600 1100 4721 

63 1062 959 1400 60 3481 

64 1062 959 1200 3221 

65 1062 959 1100 3121 

U4 CO 66 1062 959 525 2546 

67 1062 959 0 2021 

68 1062 959 0 2021 

69 1062 959 0 35 2056 

70 1062 959 0 170 2191 

71 1062 959 0 885 2906 

3REO1 72 1062 959 0 1270 3291 

73 1062 959 0 910 2931 

1RE20 74 1062 959 0 1100 3121 

75 1062 959 0 60 2081 

76 1062 959 0 2021 

77 1062 959 0 35 2056 

78 1062 959 0 170 2191 

79 1062 959 0 850 2871 
Appendix G 

Draft NUREG-1937 G-12 March 2010 

1 

Table G-2. (contd)

Event(a) Month 

Unit 1 and 2 

Staffing(b)

Unit 3 and 4 

Staffing(c)

Construction 

Workforce(d)

Outage 

Workforce(e)

Total 

Workforce 

2RE19 80 1062 959 0 1135 3156 

81 1062 959 0 230 2251 

82 1062 959 0 850 2871 

4REO1 83 1062 959 0 1100 3121 

84 1062 959 0 60 2081 

85 1062 959 0 2021 

Source: STPNOC (2009a).

(a) Events at indicated months are from Table 3.10S-2, Environmental Report Rev 3, and South Texas Project Long 

Range Outage Plan, Rev 4b, 10/15/07. Outages numbering convention: for example, for 1RE15, 1 = Unit 1 (or 

2, 3 or 4); RE = refueling; 15 = this is the 15th refueling for Unit 1. 

(b) Units 1/2 estimates are from STP Staffing Plan, June 2007 

(c) Units 3/4 estimates are from Owner's Estimate, 10/25/07 

(d) Construction Workforce estimates are from Table 3.10S-2, ER, Rev 3 

(e) Outage Supplemental Workforce estimates are based on South Texas Project 1RE14 Outage Report, 2008 

2 G.2 Supporting Documentation on Radiological Dose 

3 Assessment 

4 The U.S. Nuclear Regulatory Commission (NRC) staff reviewed and performed an independent 

5 dose assessment of the radiological impacts from normal operations of the new and existing 

6 nuclear units at and near the South Texas Project Electric Generating Station (STP). The 

7 results of the assessment are presented in this appendix and are compared to the results from 

8 STP Nuclear Operating Company (STPNOC) found in the Environmental Report (ER) 

9 (STPNOC 2009a), Sections 4.5, Radiation Exposure to Construction Workers, and 5.4, 

10 Radiological Impacts of Normal Operation. This appendix is divided into five sections: (1) dose 

11 estimates to the public from liquid effluents; (2) dose estimates to the public from gaseous 

12 effluents; (3) cumulative dose estimates; (4) dose estimates to biota from gaseous and liquid 

13 effluents, and (5) dose to construction workers. 

14 G.2.1 Dose Estimate from Liquid Effluents 

15 The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 

16 1977) and the LADTAP II computer code (Strenge et al. 1986) to estimate doses to the 

17 maximally exposed individual (MEI) and the population from the liquid effluent pathway of 

18 proposed Units 3 and 4. The NRC staff used the projected radioactive effluents release values 

19 from the Final Safety Analysis Report. 
Appendix G 

March 2010 G-13 Draft NUREG-1937 

1 G.2.1.1 Scope 

2 Doses from each new unit to the MEI were calculated and compared to the regulatory criteria for 

3 the following: 

4 Total Body – Dose was the total for the ingestion of aquatic organisms as food and cow 

5 meat and external exposure to contaminated sediments deposited along the shoreline 

6 (shoreline exposure). Water downstream from the STP site is used for neither drinking 

7 water nor irrigation. 

8 Organ – Dose was the total for each organ for ingestion of aquatic food and cow meat and 

9 shoreline exposure with the highest value for adult, teen, child, or infant. 

10 The NRC staff reviewed the assumed exposure pathways and input parameters and values 

11 used by STP for appropriateness. Default values from Regulatory Guide 1.109 (NRC 1977)

12 were used when site-specific input parameters were not available. The NRC staff concluded 

13 that the assumed exposure pathways were appropriate – ingestion of aquatic organisms and 

14 shoreline exposure only – because water downstream of the site is not used for drinking or 

15 irrigation. In addition, the input parameters and values used by STPNOC were appropriate. 

16 G.2.1.2 Resources Used 

17 To calculate doses to the public from liquid effluents the NRC staff used a personal computer 

18 version of the LADTAP II code entitled NRCDOSE, version 2.3.10 (Chesapeake Nuclear Services, 

19 Inc. 2006) obtained through the Oak Ridge Radiation Safety Information Computational Center 

20 (RSICC). 

21 G.2.1.3 Input Parameters 

22 Table G-3 lists the major parameters used in calculating dose to the public from liquid effluent 

23 releases during normal operation. It should be noted that the 50-mi population was assumed to 

24 be for the year 2060, which is an overestimate of the population and is considered to be 

25 conservative. Section 5.4.1 of the Environmental Standard Review Plan (ESRP) (NRC 2000) 

26 guidance suggests that populations be projected only five years out from the date of the licensing 

27 action under consideration. 

28 G.2.1.4 Comparison of Results 

29 NRC staff’s dose calculations confirmed the doses estimated by STPNOC. 

30 
Appendix G 

Draft NUREG-1937 G-14 March 2010 

1 Table G-3. Single Unit Source Term for Liquid Effluent Pathways 

Parameter Staff Value Comments

 

Fraction 

Reaching 

Colorado 

River 

Fraction 

Reaching 

Matagorda 

Bay 

Fraction 

Reaching 

Little 

Robbins 

Slough 

Single new unit liquid 

effluent source term 

(Ci/yr) 

I-131 

I-132 

I-133 

I-134 

I-135 

H-3 

Na-24 

P-32 

Cr-51 

Mn-54 

Mn-56 

Co-58 

Co-60 

Fe-55 

Fe-59 

Ni-63 

Cu-64 

Zn-65 

Sr-89 

Sr-90 

Y-90 

Sr-91 

Y-91 

Sr-92 

Y-92 

Y-93 

Zr-95 

Nb-95 

Mo-99 

Tc-99M 

Ru-103 

9.05 x 10-3

1.93 x 10-3

3.73 x 10-2

1.14 x 10-4

1.09 x 10-2

8.00 

5.05 x 10-3

5.68 x 10-4

1.70 x 10-2

3.97 x 10-3

2.04 x 10-3

8.38 x 10-3

1.54 x 10-2

9.46 x 10-3

2.23 x 10-3

1.70 x 10-3

1.26 x 10-2

4.41 x 10-4

3.14 x 10-4

2.68 x 10-5

0.00 

1.25 x 10-3

2.35 x 10-4

4.43 x 10-4

1.69 x 10-3

1.36 x 10-3

1.11 x 10-3

3.14 x 10-4

2.61 x 10-3

5.68 x 10-3

3.27 x 10-4

1.40 x 10-5

0.00 

6.99 x 10-11

0.00 

7.64 x 10-22

7.87 x 10-2

6.61 x 10-13

4.22 x 10-5

1.13 x 10-4

1.64 x 10-3

0.00 

3.54 x 10-4

7.64 x 10-3

4.60 x 10-3

2.07 x 10-4

2.17 x 10-2

3.33 x 10-14

1.30 x 10-3

2.41 x 10-4

1.74 x 10-2

4.14 x 10-7

5.14 x 10-17

2.85 x 10-4

0.00 

0.00 

2.40 x 10-16

3.16 x 10-4

1.54 x 10-4

4.71 x 10-7

2.42 x 10-23

1.78 x 10-4

2.31 x 10-5

0.00 

1.15 x 10-10

0.00 

1.26 x 10-21

1.30 x 10-1

1.09 x 10-12

6.96 x 10-5

1.87 x 10-4

2.71 x 10-3

0.00 

5.84 x 10-4

1.26 x 10-2

7.60 x 10-3

3.42 x 10-4

3.59 x 10-2

5.49 x 10-14

2.14 x 10-3

3.97 x 10-4

2.86 x 10-2

6.83 x 10-7

8.48 x 10-17

4.70 x 10-4

0.00 

0.00 

3.96 x 10-16

5.22 x 10-4

2.54 x 10-4

7.77 x 10-7

4.00 x 10-23

2.93 x 10-4

8.56 x 10-6

0.00 

4.27 x 10-11

0.00 

4.67 x 10-22

4.81 x 10-2

4.04 x 10-13

2.57 x 10-5

6.93 x 10-5

1.00 x 10-3

0.00 

2.16 x 10-4

4.67 x 10-3

2.81 x 10-3

1.27 x 10-4

1.33 x 10-2

2.03 x 10-14

7.92 x 10-4

1.47 x 10-4

1.06 x 10-2

2.53 x 10-7

3.14 x 10-17

1.74 x 10-4

0.00 

0.00 

1.46 x 10-16

1.93 x 10-4

9.42 x 10-5

2.88 x 10-7

1.48 x 10-23

1.09 x 10-4

(STPNOC 2009b) 

Ru-106 

Ag-110M 

Sb-124 

Te-129M 

Te-131M 

Te-132 

Cs-134 

Cs-136 

Cs-137 

Cs-138 

Ba-140 

Ce-141 

Ce-144 

Pr-143 

Nd-147 

W-187 

Np-239 

8.89 x 10-3

1.20 x 10-3

0.00 

8.43 x 10-5

8.38 x 10-5

1.35 x 10-5

1.13 x 10-2

7.51 x 10-4

1.78 x 10-2

8.00 x 10-7

1.68 x 10-3

2.97 x 10-4

3.89 x 10-3

8.11 x 10-5

2.00 x 10-6

2.23 x 10-4

9.49 x 10-3

1.92 x 10-3

1.33 x 10-3

2.95 x 10-4

1.46 x 10-4

3.10 x 10-9

9.68 x 10-7

3.67 x 10-3

3.64 x 10-5

1.76 x 10-2

0.00 

3.48 x 10-5

1.39 x 10-4

1.49 x 10-3

3.85 x 10-5

3.41 x 10-10

2.20 x 10-7

2.56 x 10-4

3.17 x 10-3

2.19 x 10-3

4.86 x 10-4

2.40 x 10-4

5.12 x 10-9

1.60 x 10-6

3.67 x 10-3

3.64 x 10-5

1.76 x 10-2

0.00 

5.74 x 10-5

2.30 x 10-4

2.47 x 10-3

6.36 x 10-5

5.62 x 10-10

3.62 x 10-7

4.23 x 10-4

1.17 x 10-3

8.12 x 10-4

1.80 x 10-4

8.89 x 10-5

1.90 x 10-9

5.91 x 10-7

0.00 

0.00 

0.00 

0.00 

2.12 x 10-5

8.52 x 10-5

9.13 x 10-4

2.35 x 10-5

2.08 x 10-10

1.34 x 10-7

1.57 x 10-4
Appendix G 

March 2010 G-15 Draft NUREG-1937 

1 

2 

Table G-3. (contd) 

Parameter Staff Value Comments

Discharge Flow Rate 18.3 cfs 

16.5 cfs 

10700 cfs 

From MCR to Little Robbins Slough 

Blowdown 

Four Unit discharge flow into MCR 

Evaporation Rate 146.35 cfs MCR evaporation rate – used for tritium 

calculations only 

Source Term multiplier 2 x 2.7027 x10-5 = 5.41 x 10-5 Converts from MBq/yr to Ci/yr and adjusts 

for two ABWR units. 

Site Type Fresh water MCR to Little Robbins Slough 

Reconcentration Model None Site-specific from Table 5.4-1 of ER 

(STPNOC 2009a) 

Impoundment Volume 0; 7.35 x 109

 ft3 Set to “0” for no impoundment at Little 

Robbins slough, Second value is MCR 

volume. 

Shore width factor 0.2 and 0.3 Little Robbins slough and MCR, 

respectively. 

Dilution factors for aquatic food 

and boating, shoreline and 

swimming 

1 Liquid discharge assumed fully mixed with 

annual average dilution flows at Little 

Robbins slough. For MCR calculations 

Partially Mixed 

Transit time to nearest drinking 

water 

Not considered for Little 

Robbins slough calculations 

0.1 h for MCR calculations 

No drinking water downstream from STP 

0.1 h to simulate doses to biota exposed 

to MCR concentrations. 

Consumption and usage factors 

for adults, teens, child, and infant 

Shoreline usage (hr/yr) 

12 Adult 

67 Teen 

14 Child 

0 Infant 

Fish Consumption (kg/yr) 

21 Adult 

16 Teen 

6.9 Child 

0 Infant 

50-mi population(a) 5.14 x 105 

Fractions: 

Adult 0.71, Teen 0.11, 

Child 0.18 

Assumes 2060 population 

50-mi sport fishing 4.5 x 104

 kg/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2009a) 

50-mi invertebrate catch 1.8 x 106

 kg/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2009a) 

50-mi shoreline usage 7.84 x 106

 person-hr/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2009a) 

50-mi swimming, boating usage 3.92 x 106 person-hr/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2009a) 
Appendix G 

Draft NUREG-1937 G-16 March 2010 

1 G.2.2 Dose Estimates to the Public from Gaseous Effluents 

2 The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 

3 1977) and the GASPAR II computer code (Strenge et al. 1987) to estimate doses to the MEI 

4 and to the public within 50 mi of the STP site from the gaseous effluent pathway for the 

5 proposed units. The NRC staff used the projected radioactive gaseous effluents release values 

6 from the Final Safety Analysis Report (STPNOC 2009b). 

7 G.2.2.1 Scope 

8 The NRC staff and STPNOC calculated the MEI dose at 2.19 mi west-southwest of the new 

9 units. Pathways included were plume, ground, inhalation, and ingestion of locally grown meat 

10 and vegetables. Milk consumption was not considered because there are no milk animals 

11 within 5 mi of the plant. 

12 The NRC staff reviewed the parameters and values used by STPNOC (2009a), for 

13 appropriateness. Default values from Regulatory Guide 1.109 were used when site or design 

14 specific input parameters were not available. The NRC staff concluded that the assumed 

15 exposure pathways and input parameters were appropriate. These pathways and parameters 

16 were used by the NRC staff in its independent calculations using GASPAR II. 

17 Joint frequency distribution data of wind speed and wind direction by atmospheric stability class 

18 for the STP site provided in ER Table 2.7-10 (STPNOC 2009a) were used as input to the 

19 XOQDOQ code (Sagendorf et al. 1982) to calculate the average X/Q and D/Q values for routine 

20 releases. XOQDOQ output from the applicant were examined and determined to be 

21 appropriate. 

22 Population doses were calculated for all types of releases (i.e., noble gases, particulates, 

23 iodines H-3 and C-14) using the GASPAR II code for the following: plume immersion, direct 

24 radiation from radionuclides deposited on the ground, inhalation, ingestion of vegetables, milk, 

25 and meat. 

26 G.2.2.2 Resources Used 

27 To calculate doses to the public from gaseous effluents, the NRC staff used a personal 

28 computer version of the XOQDOQ and GASPAR II computer codes entitled NRCDOSE version 

29 2.3.10 (Chesapeake Nuclear Services, Inc. 2006) obtained through the Oak Ridge RSICC. 

30 G.2.2.3 Input parameters 

31 Table G-4 lists the major parameters used in calculating doses to the public from gaseous 

32 effluents during normal operation. It should be noted that the 50-mi population was assumed to 

33 be for the year 2060, which is an overestimate of the population and is considered to be 

34 conservative. ESRP guidance suggests that populations be projected only five years out from 

35 the date of the licensing action under consideration. 
Appendix G 

March 2010 G-17 Draft NUREG-1937 

1 Table G-4. Parameters Used in Calculating Dose to Public from Gaseous Effluent Releases 

Parameter Staff Value Comments

Single new unit gaseous effluent 

source term (Ci/yr) 

Kr-83m 

Kr-85m 

Kr-85 

Kr-87 

Kr-88 

Kr-89 

Kr-90 

Xe-131m 

Xe-133m 

Xe-133 

Xe-135m 

Xe-135 

Xe-137 

Xe-138 

Xe-139 

I-131 

I-132 

I-133 

I-134 

I-135 

H-3 

C-14 

Na-24 

P-32 

Ar-41 

Cr-51 

Mn-54 

Mn-56 

Fe-55 

Fe-59 

Co-58 

Co-60 

Ni-63 

Cu-64 

Zn-65 

Rb-89 

Sr-89 

Sr-90 

Y-90 

Sr-91 

Sr-92 

Y-91 

8.37 x 10-4

2.11 x 101

5.67 x 102

2.51 x 101

3.78 x 101

2.40 x 102

3.24 x 10-4

5.13 x 101

8.64 x 10-2

2.40 x 103

4.05 x 102

4.59 x 102

5.13 x 102

4.32 x 102

4.05 x 10-4

2.59 x 10-1

2.19 

1.70 

3.78 

2.40 

7.29 x 101

9.18 

4.05 x 10-3

9.18 x 10-4

6.75 

3.51 x 10-2

5.40 x 10-3

3.51 x 10-3

6.48 x 10-3

8.10 x 10-4

2.40 x 10-3

1.30 x 10-2

6.48 x 10-6

9.99 x 10-3

1.11 x 10-2

4.32 x 10-5

5.67 x 10-3

7.02 x 10-5

4.59 x 10-5

9.99 x 10-4

7.83 x 10-4

2.40 x 10-4

STPNOC (2009a) references these 

values in Table 3.5-2 of the ER for 

single new unit. These values are 

converted from the original SI units in 

MBq/yr to Ci/yr 

2 
Appendix G 

Draft NUREG-1937 G-18 March 2010 

Table G-4. (contd)

Parameter Staff Value Comments

 Y-92 

Y-93 

Zr-95 

Nb-95 

Mo-99 

Tc-99m 

Ru-103 

Rh-103m 

Ru-106 

Rh-106 

Ag-110m 

Sb-124 

Te-129m 

Te-131m 

Te-132 

Cs-134 

Cs-136 

Cs-137 

Cs-138 

Ba-140 

La-140 

Ce-141 

Ce-144 

Pr-144 

W-187 

Np-239 

6.21 x 10-4

1.11 x 10-3

1.59 x 10-3

8.37 x 10-3

5.94 x 10-2

2.97 x 10-4

3.51 x 10-3

1.11 x 10-4

1.89 x 10-5

1.89 x 10-5

2.00 x 10-6

1.81 x 10-4

2.19 x 10-4

7.56 x 10-5

1.89 x 10-5

6.21 x 10-3

5.94 x 10-4

9.45 x 10-3

1.70 x 10-4

2.70 x 10-2

1.81 x 10-3

9.18 x 10-3

1.89 x 10-5

1.89 x 10-5

1.89 x 10-4

1.19 x 10-2

Population distribution Table 2.5-2 of the ER 

(STPNOC 2009a) 

Population distribution used by STP and 

the staff was for year 2060. 

Wind Speed and Direction Table 2.7-7 of the ER 

(STPNOC 2009a) 

Site-specific data for 1997, 1999, and 

2000. 

Joint Frequency distribution of 

wind speed and direction by 

stability class 

Table 2.7-10 of the ER 

(STPNOC 2009a) 

Site specific data for 1997, 1999, and 

2000. 

Atmospheric Dispersion factors 

(sec/m3

) 

Tables 2.7-15 and 2.7-16 of 

the ER (STPNOC 2009a) 

Ground Deposition factors Table 2.7-15 of the ER 

(STPNOC 2009a) 

Table to be updated with July 20, 2009 

response to RAI 5.4.2 (U7-C-STP-NRC090075) 

Vegetable Production rate within 

50 mi of STP site 

9,640,000 kg/yr Site-specific data provided by STPNOC 

in Table 5.4-2 of the ER (STPNOC 

2009a) 

Meat Production Rate within 

50 mi of STP site 

40,500,000 kg/yr Site-specific data provided by STPNOC 

in Table 5.4-2 of the ER (STPNOC 

2009a) 

Milk Production rate within 50 mi 

of STP site 

2,130,000 L/yr Site-specific data provided by STPNOC 

in Table 5.4-2 of the ER (STPNOC 

2009a) 

Pathway receptor locations Table 5.4-4 of the ER 
Appendix G 

March 2010 G-19 Draft NUREG-1937 

Table G-4. (contd)

Parameter Staff Value Comments

(direction, and distance,) – 

nearest site boundary, MEI 

location 

(STPNOC 2009a) 

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 Vegetable (kg/yr) 

64 Adult 

42 Teen 

26 Child 

0 Infant 

Vegetable (kg/yr) 

520 Adult 

630 Teen 

520 Child 

0 Infant 

Table 5.4-3 of the ER (STPNOC 2009a) 

Section 5.9.2 of the EIS states that there 

are no milk cows within 5 mi of the STP 

site. 

Fraction of leafy vegetables 

grown 

0.917 Table 5.4-3 of the ER (STPNOC 2009a) 

Fraction of year that milk cows 

are on pasture 

0.917 Table 5.4-3 of the ER (STPNOC 2009a) 

Fraction of MEI vegetable intake 

from own garden 

0.76 Table 5.4-3 of the ER (STPNOC 2009a) 

Fraction of year beef cattle are on 

pasture 

0.917 Table 5.4-3 of the ER (STPNOC 2009a) 

Fraction of year beef cattle intake 

is from pasture while on pasture 

1 Default value of GASPAR II code 

(Strenge et al. 1987). 

RAI = Request for Additional Information 
Appendix G 

Draft NUREG-1937 G-20 March 2010 

1 G.2.2.4 Comparison of Doses to the MEI from Gaseous Effluents 

2 NRC staff’s dose calculations confirmed the doses estimated by STPNOC. 

3 Table G-5. Comparison of Cumulative Doses to the MEI with 40 CFR Part 190 Criteria 

4 (mrem per year) 

STP Units 1 and 2(a) STP Units 3 and 4 

DOSE Liquid Gaseous Total 

Direct(b)

Radiation Liquid(c) Gaseous Total 

Site 

Total 

40 CFR Part 

190 Criteria

Total Body 0.0042 0.0072 0.011 5 0.000525 0.70(d) 5.7 5.71 25 

Thyroid 0.0041 0.0099 0.14 NA 0.000406 4.54(e) 4.54 4.55 75 

Bone 0.00077 0.00079 0.0016 NA 0.00230 1.94(d) 1.94 1.94 25 

(a) Doses from liquid and gaseous effluent releases for two existing units are taken from ER Table 5.4-8 (STPNOC 2009a). 

(b) Doses from direct radiation are based on plant shielding design acceptance criteria for the ABWR that specify a maximum 

dose rate from direct and scattered radiation of 2.5 mrem/y at the Exclusion Area Boundary (STPNOC 2009a). 

(c) Liquid pathway MEI is a combination of teen (total body and thyroid) and child (bone) 

(d) Gaseous pathway MEI dose for bone and total body is a child located at 2.18 mi WSW of new units with meat animal and 

vegetable garden. 

(e) Gaseous pathway MEI dose for thyroid is a child located 3.03 mi NNW of new units with meat animal and vegetable garden.

5 G.2.3 Cumulative and Population Dose Estimates 

6 Based on parameters shown for the liquid pathway and the gaseous pathway, Table G-3 and 

7 Table G-4, respectively, doses from the two proposed units were calculated using LADTAP and 

8 GASPAR to the MEI. Doses from the existing units are taken from ER Table 5.4-8 (for the MEI) 

9 and Table 5.4-9 (for the population) (STPNOC 2009a). Table G-5 is the same table as ER 

10 Table 5-12 and compares cumulative dose estimates to the MEI with EPA’s dose criteria in 40 

11 CFR Part 190. Table G-5 includes doses from all pathways (i.e., external, liquid effluent and 

12 gaseous effluent) summed for existing Units 1 and 2 and proposed Units 3 and 4. 

13 Based on parameters shown for the liquid pathway and gaseous pathway (Table G-3 and 

14 Table G-4, respectively), doses were calculated using LADTAP and GASPAR to the population 

15 within 50 mi of the STP site (as discussed in Section G.2.1.3 and G.2.2.3). Doses from the 

16 milk pathway were not calculated because there are no dairies within 50 mi of the STP site. 

17 Table G-6 shows dose estimates to the population within 50-mi of the STP site from operation of 

18 proposed Units 3 and 4. It should be noted that the 50-mi population was assumed to be for the 

19 year 2060, which is an overestimate of the population and is considered to be conservative. 

20 ESRP guidance suggests that populations be projected only five years out from the date of the 

21 licensing action under consideration. For comparison, the collective background dose to the 

22 regional population is estimated to be approximately 159,000 person-rem. This estimate is the 

23 product of the annual average dose rate to individuals from natural sources of 311 mrem/yr, as 

stated in NCRP Report 160 (NCRP 2009), and the estimated 2060 population of 5.14×105 24 . 
Appendix G 

March 2010 G-21 Draft NUREG-1937 

1 Table G-6. Doses to Population Within 50-mi Radius of the STP Site (Person-Rem) 

STP Units 3 and 4 

Liquid Gaseous Total 

Noble gases 0 0.11 0.11 

Iodines and particulates 0.0030 0.14 0.14 

Tritium and C-14 0.0000056 0.32 0.32 

Total(a) 0.0030 0.58 0.58 

(a) Differences between sum of components and totals are due to rounding. 

2 G.2.4 Dose Estimates to the Biota from Liquid and Gaseous Effluents 

3 To estimate doses to the biota from the liquid and gaseous effluent pathways, the STPNOC 

4 staff used the LADTAP II computer code (Strenge et al. 1986), the GASPAR II computer code 

5 (Strenge et al. 1987), and input parameters supplied by STPNOC in response to RAIs 

6 (STPNOC 2008). 

7 G.2.4.1 Scope 

8 It is acceptable to NRC staff to estimate radiation doses to representative biota species. Fish, 

9 invertebrates, and algae are used as reference aquatic biota species. Muskrats, raccoons, 

10 herons, and ducks are used as reference terrestrial biota species. The NRC staff recognizes 

11 the LADTAP II computer program as an appropriate method for calculating dose to the aquatic 

12 biota and for calculating the liquid-pathway contribution to terrestrial biota. The LADTAP II code 

13 calculates an internal dose component and an external dose component and sums them for a 

14 total body dose. Default values from Regulatory Guide 1.109 (NRC 1977) are used when site15 specific input parameters are not available. The NRC staff concluded that all of the input 

16 parameters used by STPNOC were appropriate. 

17 G.2.4.2 Resources Used 

18 To calculate doses to the biota from liquid effluents, the NRC staff used a personal computer 

19 version of the LADTAP II entitled NRCDOSE Version 2.3.10 (Chesapeake Nuclear Services, 

20 Inc. 2006). NRCDOSE was obtained through the Oak Ridge RSICC. 

21 Most of the LADTAP II input parameters are specified in Section G.2.1.3 to include the source 

22 term, the discharge flow rate to the receiving freshwater system, the shore-width factor, and 

23 fractions of radionuclides in the Main Cooling Reservoir (MCR) reaching offsite bodies of water. 

24 These parameter values are appropriate to use in calculating biota dose in the MCR. The NRC 

25 staff’s dose analysis confirmed the liquid pathway doses to biota shown in Table 5-13 and Table 

26 G-7. 
Appendix G 

Draft NUREG-1937 G-22 March 2010 

1 Table G-7. Dose Estimates to Biota from Liquid and Gaseous Effluents

 Liquid 

(mrad/yr) 

Gaseous 

(mrad/yr) 

Combined 

(mrad/yr) 

Fish 2.50 0.00 2.50 

Invertebrate 5.30 0.00 5.30 

Algae 0.54 0.00 0.54 

Muskrat 2.4 14 16 

Raccoon 1.3 17 18 

Heron 2.4 14 16 

Duck 3.2 17 20 

2 NRC staff assessed dose to terrestrial biota from the gaseous effluent pathway using GASPAR 

3 by assuming doses for raccoons and ducks were equivalent to adult human doses for 

4 inhalation, vegetation ingestion, plume and twice the ground pathways at the exclusion area 

5 boundary (EAB) at 0.52 mi northwest. STPNOC estimated the gaseous pathway doses to biota 

6 at the site boundary in the direction that resulted in the largest doses (maximum site boundary). 

7 The NRC staff concluded that terrestrial biota could live on the STP site and receive higher 

8 doses from the gaseous effluents. Therefore, the NRC staff estimated the doses at the 

9 exclusion area boundary (0.5 mi NW) to achieve a more reasonable estimate of doses to 

10 terrestrial biota that might live on the STP site (Table G-7). The doubling of doses from ground 

11 deposition reflects the closer proximity of these organisms to the ground. Muskrats and herons 

12 do not consume terrestrial vegetation, so that pathway was not included for those organisms. 

13 G.2.5 Dose to Construction Workers 

14 STPNOC used fenceline thermoluminescent dosimeters (TLDs) and environmental TLDs to 

15 measure direct radiation levels at locations in and around the STP protected area (STPNOC 

16 2009a). Sixteen TLDs are located along the protected area fence around existing Units 1 and 2 

17 (Figure G-1). All TLDs are read quarterly and measure the contribution to dose from any 

18 source, either natural or anthropogenic, including the current reactor buildings and Onsite 

19 Staging Facility (OSF) (Figure G-2). Data from 2002 through 2006 are provided in Table G-8 

20 through Table G-12. Data from this five-year period provide information indicative of plant 

21 conditions. Table G-12 also contains data collected from around the Old Steam Generator 

22 Storage Facility (OSGSF) see Figure G-2. These tables show the maximum measured dose 

23 rate at monitoring stations 9 to 16 over the five years was 18.9 mR/quarter. 

24 The difference between the maximum protected area fence reading (18.9 mR/quarter) and the 

25 average background reading yields a net maximum dose rate of 6.4 mR/quarter, as shown in 

26 Table G-13. 

27 A primary source of direct radiation exposure to the workers on STP Unit 4 will be the gamma 

28 radiation from nitrogen-16 in the STP Unit 3 steam lines and steam-bearing components such 
Appendix G 

March 2010 G-23 Draft NUREG-1937 

1 as turbines, moisture separators, and re-heaters (STPNOC 2009a). The plant shielding design 

2 acceptance criteria for the ABWR specify a maximum dose rate due to direct and scattered 

3 radiation of 2.5 mrem/yr at the EAB. The distances from STP Unit 3 to the EAB and to the STP 

4 Unit 4 reactor are 0.52 and 0.17 mi, respectively. The ABWR DCD does not describe the 

5 outside condensate storage tank that STPNOC proposes (STPNOC 2009c). The dose rate 

6 from this tank was evaluated by NRC staff using the Microshield computer code and was 

7 encompassed by the 2.5 mrem/yr acceptance criteria. 

8 In 1986, prior to operation of STP Units 1 and 2, the background exposure rate was measured 

9 at the site boundary was 15.4 mR/quarter. However, some of the current protected area fence 

10 line direct radiation measurements are lower than the 1986 site boundary measurements 

11 because the protected area was excavated and backfilled with sand and gravel that contained 

12 less naturally occurring radioactive material than exists in the native clay found near the site 

13 boundary. Between 2002 and 2006, the exposure rate along the protected area fence averaged 

14 12.5 mR/quarter and will be used as the reference background exposure rate, see Table G-14. 

15 Data presented in Table G-14 were determined as follows: 

16 • STP Units 1 and 2 – The dose rate from the waste monitor tanks at the construction area 

17 was calculated in the ER by multiplying the net quarterly dose rate by a factor of four, to 

18 convert to an annual dose rate then, it was doubled for conservatism, yielding 51.2 

19 mrem/yr at the TLD on the protected area fence. Figures 4.5-1 and 4.5-2 in the ER 

20 show the distance from Unit 2 waste monitor tanks to the protected area fence to be 

21 about 600 ft and the distance to the center of STP Unit 3 construction area is about 2300 

22 ft. Setting DTLD = 51.2 mrem/yr, RTLD = 600 ft, and Rloc = 2300 ft, gives a dose rate of 

23 13.4 mrem/yr at the center of the construction area of Unit 3, for 100 percent occupancy. 

24 This can be reduced by the ratio of 2080 hr (worked)/8766 hr (per yr), yielding 3.2 

25 mrem/yr to a worker (Table G-14). 

26 • OSGSF – The dose rate from the OSGSF was calculated by multiplying the net quarterly 

27 dose by four to get an annual dose rate, then it is doubled for conservatism, yielding 

28 33.6 mrem/yr at the TLD. The distance from the exterior wall of the OSGSF is about 93 

29 ft and the distance from the OSGSF to the center of STP Unit 4 construction area is 

30 about 700 ft. Setting DTLD = 33.6 mrem/yr, RTLD = 93 ft, and Rloc = 700 ft gives a dose 

31 rate of 4.5 mrem/yr at the center of the construction area of Unit 4, for 100 percent 

32 occupancy. This can be reduced by the ratio of 2080 h (worked) / 8766 h (per yr), 

33 yielding 1.07 mrem/yr to a worker (Table G-14). 
Appendix G 

Draft NUREG-1937 G-24 March 2010 

1 

2 Figure G-1. Protected Area Monitoring Stations (STPNOC 2009a) 
Appendix G 

March 2010 G-25 Draft NUREG-1937 

1 

2 Figure G-2. Locations of TLD Monitoring Stations at OSGSF (STPNOC 2009a) 
Appendix G 

Draft NUREG-1937 G-26 March 2010 

1 Table G-8. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2002 

Station Average Dose by Quarter (mR) 

Number 1 2 3 4 

9 12.9 11.8 18.9 12.2 

10 12.4 11.1 14.1 13.2 

11 11.5 11 12 11.4 

12 12.5 11.3 13.3 11.9 

13 12.3 11.1 13.1 11.7 

14 12.2 11.4 13.3 11.3 

15 13 12.1 13.9 11.9 

16 12.7 11.1 13 12.1 

Source: STPNOC 2009a 

2 Table G-9. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2003 

Station Average Dose by Quarter (mR) 

Number 1 2 3 4 

9 12.9 13.1 12.7 13 

10 12.5 13 12.5 12.6 

11 11.7 11.4 12 11.8 

12 12.7 12.5 12.6 11.8 

13 12.6 12.5 12.1 12.2 

14 12.6 12.6 12.4 12.3 

15 13.2 12.8 13.2 12.9 

16 12.5 12.5 13 12.7 

Source: STPNOC 2009a 

3 Table G-10. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2004 

Average Dose by Quarter (mR) 

Station 

Number 1 2 3 4 

9 13.1 13.1 13.4 12.9 

10 12.5 12.6 13.5 12.1 

11 11.5 11.5 12.3 11.2 

12 12.1 12.3 12.9 12.5 

13 12 12.3 13.1 12.8 

14 12.3 12.1 13.2 12.3 

15 13.5 12.9 13.5 13.3 

16 13.2 12.4 13.4 12.8 

Source: STPNOC 2009a 
Appendix G 

March 2010 G-27 Draft NUREG-1937 

1 Table G-11. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2005 

Average Dose by Quarter (mR) 

Station 

Number 1 2 3 4 

9 14.7 13.7 11.5 11.6 

10 14.6 12.9 11.2 11.4 

11 13.8 12.6 10.5 10.7 

12 13.9 13.7 11.2 11.3 

13 14.5 13.6 11.8 12.1 

14 14.2 13.6 11.1 11.6 

15 15 14.6 11.7 12.3 

16 14.7 13.1 10.9 12.1 

Source: STPNOC 2009a 

2 Table G-12. TLD Measurements at STP Units 1 and 2 and Old Steam Generator Storage 

3 Facility Monitoring Stations in 2006 

Average Dose by Quarter (mR) 

Station 

Number 1 2 3 4 

9 12.8 12.2 12.4 13.4 

10 11.9 11.5 12.1 12.2 

11 11.4 11.5 11.7 13.3 

12 12.3 13.1 12.2 13 

13 12.9 12.7 12.3 13.1 

14 12.3 11.6 12.1 12.4 

15 12.8 12.5 13.6 14 

16 12 12.1 12.7 13 

OSGSF 25 13.8 12.6 12.5 12.6 

OSGSF 26 16.7 15.1 15.9 15.3 

OSGSF 27 15.6 13.6 14.1 14.7 

OSGSF 28 14.1 12.1 12.1 13.8 

Source: STPNOC 2009a 

4 Table G-13. Maximum Quarterly Measured Dose Rates at STP Units 1 and 2 and OSGSF 

Dose Rate (mrem/quarter) 

Location Maximum Measured Background Net 

STP Units 1 and 2 Protected Area Fence 18.9 12.5 6.4 

OSGSF 16.7 12.5 4.2 

Note: The maximum measured dose rates are from Tables 4.5-3 to 4.5-7 in the ER (STPNOC 2009a). 

The net dose rate is calculated by subtracting the background dose rate from the maximum dose rate. 
Appendix G 

Draft NUREG-1937 G-28 March 2010 

1 Table G-14. Direct Radiation Doses to Unit 4 Construction Workers

Distance from Source (ft) Dose Rate (mrem/yr) 

Source 

To TLD 

Location 

To 

Construction 

Location 

TLD 

Location 

Construction 

Location 

Annual 

Dose to 

Worker 

(mrem) 

STP Units 1 and 2 600 2300 51.2 13.4 3.18 

OSGSF 92.6 700 33.6 4.5 1.07 

LTSF - 700 1 0.24 

OSF - -* 1 0.24 

STP Unit 3 - 900 23 5.5 

Total for STP Units 1 

and 2 

- - 

19.9 4.72 

Total for STP Units1, 

2, and 3 

- - 

42.9 10.2 

Location of the Onsite Storage Facility has not been specified; therefore, dose rate to construction workers is 

only an estimate. 

2 • LTSF – The Long Term Storage Facility is not yet built yet but plans are to build it 

3 adjacent to the OSGSF. It is therefore assumed that the distance from the LTSF to the 

4 center of the construction area of STP Unit 4 is also 700 ft. Contamination smears and 

5 exposure measurements taken from the reactor vessel heads that will be stored in the 

6 LTSF and using MicroShield and MicroShine software yielded an exposure rate of 

8×10-6 7 mR/hr at 700 ft away. With fulltime occupancy, this results in a dose rate of 0.07 

8 mrem/yr. This is conservatively rounded up to 1 mrem/yr for the construction location, 

9 and the annual dose to the construction worker of 0.24 mrem was obtained by 

10 multiplying by the ratio of 2080 hours worked/ 8766 hours per year (Table G-14). 

11 • OSF – As indicated above, the OSF will be relocated and have additional shielding 

12 provided such that the dose rate from this source will be negligible at the STP Units 3 

13 and 4 construction location. However, the dose rate from the OSF is conservatively 

14 assumed to be 1 mrem/yr at the construction location, and the annual dose to the 

15 construction worker of 0.24 mrem was obtained by multiplying by the ratio of 2080 hours 

16 worked/ 8766 hours per year (Table G-14). 

17 • STP Unit 3 – STP Unit 3, including the CST, must be considered as a source of direct 

18 radiation to construction workers at STP Unit 4 during the timeframe between STP Unit 3 

19 becoming operational and STP Unit 4 becoming operational. The plant shielding design 

20 acceptance criteria for the ABWR specify a maximum dose rate due to direct and 

21 scattered radiation of 2.5 mrem/yr at the EAB. Distances from STP Unit 3 to the EAB 

22 and to the STP Unit 4 reactor are 0.52 and 0.17 mi, respectively. Assuming the 
Appendix G 

March 2010 G-29 Draft NUREG-1937 

1 distances were great enough to consider the source a point source, the dose rate at the 

2 construction site was estimated at 23 mrem/yr. Adjusting the calculated dose rate at 

3 STP Unit 4 from operations of STP Unit 3 for worker occupancy (2080 hours 

4 worked/8766 hours per year) yields a worker dose rate of 5.5 mrem/yr. Adding the total 

5 direct radiation dose rate from STP Units 1 and 2 (4.72 mrem/yr) to the Unit 3 direct 

6 radiation dose yields a total of 10.2 mrem/yr for the Unit 4 construction worker (Table 

7 G-14). 

8 G.3 References 

9 40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

10 “Environmental Radiation Protection Standards for Nuclear Power Operations.” 

11 Chesapeake Nuclear Services, Inc. 2006. NRCDOSE for Windows. Radiation Safety 

12 Information Computational Center, Oak Ridge, Tennessee. 

13 National Council on Radiation Protection and Measurements (NCRP). 2009. Ionizing Radiation 

14 Exposure of the Population of the United States. NCRP Report No. 160, Bethesda, Maryland. 

15 Sagendorf, J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the 

16 Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations. 

17 NUREG/CR-2919, Pacific Northwest National Laboratory, Richland, Washington. 

18 South Texas Project Nuclear Operating Company (STPNOC). 2008. Letter from Greg Gibson, 

19 STPNOC, to NRC dated July 30, 2008,, “Response to Requests for Additional Information.” 

20 Accession No. ML082140629. 

21 South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

22 Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

23 City, Texas. Accession No. ML092931600. 

24 South Texas Project Nuclear Operating Company (STPNOC). 2009b. South Texas Project 

25 Units 3 and 4 Combined License Application, Part 2, Final Safety Analysis Report. Revision 3, 

26 Bay City, Texas. Accession No. ML092931524. 

27 South Texas Project Nuclear Operating Company (STPNOC). 2009c. Letter from Scott Head, 

28 STPNOC, to NRC, dated September 14, 2009 "Response to Request for Additional 

29 Information." Accession No. ML092580491. 

30 Strenge, D.L., R.A. Peloquin, and G. Whelan. 1986. LADTAP II – Technical Reference and 

31 User Guide. NUREG/CR-4013, Pacific Northwest Laboratory, Richland, Washington. 
Appendix G 

Draft NUREG-1937 G-30 March 2010 

1 Strenge, D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR II – Technical Reference and User 

2 Guide. NUREG/CR-4653, Pacific Northwest Laboratory, Richland, Washington. 

3 U.S. Nuclear Regulatory Commission (NRC). 1977. Calculation of Annual Doses to Man from 

4 Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

5 10 CFR Part 50, Appendix I. Regulatory Guide 1.109, Washington, D.C. Accession 

6 No ML003740384. 

7 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan —

8 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

9 Vol. 1, Washington, D.C. Includes 2007 updates. 
Appendix H 

 

Authorizations, Permits, and Certifications 

March 2010 H-1 Draft NUREG-1937 

Appendix H 

Authorizations, Permits, and Certifications 

1 This appendix contains a list of the environmental-related authorizations, permits, and 

2 certifications potentially required by STP Nuclear Operating Company (STPNOC) from Federal, 

3 State, regional, and local agencies related to the combined licenses for the two proposed new 

4 nuclear units, Units 3 and 4, at South Texas Project (STP) site. The table is reproduced from 

5 Tables 1.2-1 through 1.2-4 of the Environmental Report submitted to the U.S. Nuclear 

6 Regulatory Commission (NRC). 
Draft NUREG-1937 H-2 March 2010

Appendix H Table H-1. Other Authorizations, Permits, and Certifications Potentially Required by STPNOC Agency Authority Requirement Activity Covered Status

NRC 10 Code of Federal 

Register (CFR) 30 

Byproduct license Approval to possess special 

nuclear material (SNM). 

01/2012 

NRC 10 CFR Part 52, Subpart C Combined Licenses Construction and operation of 

two new nuclear units. 

Application submitted 09/20/07 

NRC 10 CFR 70 Special Nuclear 

Materials License 

Approval to possess fuel. 01/2012 

NRC 10 CFR 61 Licensing 

Requirements for Land Disposal of Radioactive Wastes 

Procedures, criteria, and terms and conditions for the licensing of land disposal facilities intended to contain byproduct source, and SNM. 

If required 

NRC 10 CFR 71 Packaging and 

Transportation of Radioactive Material 

The regulations in this part provide requirements, procedures, and standards for packaging, preparation for shipment, and transportation of licensed material. 

If required 

NRC 10 CFR 72 Licensing 

Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste 

The issuance of licenses to receive, transfer, and possess power reactor spent fuel and other associated radioactive materials in an independent spent fuel storage installation and the terms under which the Commission will issue such a license. 

If required 
March 2010 H-3 Draft NUREG-1937

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered Status

NOAA Fisheries 

Endangered Species Act of 1973 

Consultation regarding potential to adversely impact protected marine species 

Concurrence with no adverse impact or consultation on appropriate mitigation measures. 

Complete 

US Fish and Wildlife Service (FWS) 

Endangered Species Act of 1973 

Consultation regarding potential to adversely impact protected species (non-marine species) 

Concurrence with no adverse impact or consultation on appropriate mitigation measures. Triggering Activity: Cannot modify habitat of endangered or threatened species without authorization from FWS, including clearing of vegetation or earth-moving activities. 

Complete 

FWS Migratory Bird Treaty Act, 

50 CFR 21 

Compliance with requirements of Act 

Adverse impacts on protected species and/or their nests. 

Complete 

Department of Energy (DOE) 

Nuclear Waste Policy Act (42 United States Code (U.S.C) 10101 et seq.) and 10 CFR Part 961 

Spent Fuel Contract The DOE Standard Contract for 

disposal of spent nuclear fuel contained in 10 CFR Part 961 is being modified by the DOE. 

2008 DE-CR01-09RW09007 (Unit 3) DE-CR01-09RW09008 (Unit 4) 
Draft NUREG-1937 H-4 March 2010

Appendix H Table H-1. (contd) Agency Authority Requirement Activity Covered Status

US Army Corps of Engineers (Corps) 

Federal Clean Water Act (FCWA), Section 404, 33 CFR 323 

Section 404 Permit Disturbance or crossing wetland 

areas or navigable waters. 

Permit Determination Request submitted 06/04/2009 Second Permit Determination Request submitted 10/28/2009 

Corps FCWA, Section 404, 33 

CFR 323 

Dredge and Fill Discharge Permit 

Maintenance dredging of intake structure on Colorado River. 

Covered under Permit No. SWG1992-02707 Exp. Date: 12/31/2019 

 Corps Rivers and Harbors Act Section 10 Permit Maintenance dredging of barge 

slip. 

Covered under Permit No. 10570 Exp. Date: 12/31/2014 

United States Department of Transportation 

49 CFR 107, Subpart G Registration for Hazardous Materials Transportation 

Certificate of Registration 

Renew existing two-year registration for transportation of hazardous materials. 

Covered under Permit No. 061506 551 0960P 

Federal Aviation Administration 

14 CFR 77 Construction Notice Notice of erection of structures 

(>200 feet high) potentially impacting air navigation. 

12/2011 
March 2010 H-5 Draft NUREG-1937

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered Status

 Texas Commission on Environmental Quality (TCEQ) 

Federal Clean Air Act (FCAA), General Air Quality Rules (Texas Administrative Code (T.A.C.) Title 30, Part 1, Chapter 101, 111, 116) 

Air Quality Construction Permit 

Construction of air emission sources – diesel combustion generator, diesel generators, vents and other air sources regulated by TCEQ. Triggering Activity: Permit must be obtained before excavation for or construction of foundation or footings supporting air emitting facilities. 

Complete 

TCEQ FCAA, General Air Quality 

Rules (T.A.C. Title 30, Part 1, Chapter 101, 111, 116) 

Air Quality Construction Permit 

Construction air emission sources: Concrete batch plant (CBP) Sand blast facility and surfacing coating facility. Triggering Activity: Authorization must be obtained before excavation for or construction of foundation or footings supporting air emitting facilities. 

12/2010 (Obtained by Constructor) 

TCEQ Federal Clean Water Act 

(FCWA) (33 U.S.C. 1251 et seq.); T.A.C. Title 30, Part 1, Chapter 307, 308 

Section 401 Certification 

Certify that issuance of the COL will not result in a violation of state water quality standards. 

Waiver received on Feb 2, 2010. 
Draft NUREG-1937 H-6 March 2010

Appendix H Table H-1. (contd) Agency Authority Requirement Activity Covered Status

TCEQ FCWA, Texas Water Code 

(TWC) Chapter 26; T.A.C. Title 30, Part 1, Chapter 205, 279, 307, 308 

Renewal of or amendment to existing Texas Pollutant Discharge Elimination System (TPDES) Permit 

Regulates discharge of pollutants to surface water. Triggering Activity: Amended TPDES permit must be issued prior to excavation for or construction of foundation or footings to support wastewater treatment plant components for expanded capacity. 

12/2009 

TCEQ FCWA, TWC Chapter 26 General Permit for 

Stormwater Discharges Associated With Construction Activity 

Discharge stormwater from site during construction. Triggering Activity: Authorization must be obtained prior to exposure of soils from activities such as clearing, grading and excavating. 

10/2009 (Obtained by Constructor) 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 290 

TCEQ approval of modification of public water system 

Modify treatment, storage, distribution of potable water system as needed for expansion Approval of plans and specifications or TCEQ determination that approval is not required must occur before construction commences on any new or expanded component of water system, including water well, storage, treatment or distribution lines. 

As required 
March 2010 H-7 Draft NUREG-1937

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered Status

TCEQ FCWA, TWC, Ch. 26 TPDES General 

Permit 

Discharge of uncontaminated groundwater encountered during construction will be included in TPDES General Permit for construction activities. 

12/2009 (Obtained by Constructor) 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 334 

Certificate of Annual Tank Registration 

All underground storage tanks that are in use or capable of being used for petroleum products and certain chemicals. 

As required 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 335 

Notice of Registration 

Onsite disposal of Class III industrial solid waste consisting of earth and earth-like products, concrete, rock, bricks, and land clearing debris. 

Registration No. 30651 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 335 

Notice of Registration 

Offsite disposal of industrial solid wastes. 

Registration No. 30651 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 295, 297 

Water Rights Use of additional makeup water 

from Colorado River. 

Covered under existing water rights.Registration No. 14-5437 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 321; FCWA; TWC, Chapter 26 

Notice of Registration 

Relocation of existing pond related to car wash and vehicle washdown. 

12/2010 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 290 

Revision or new permit to operate a public water system - Notice of Termination 

Operate a public noncommunity water system. 

As required 
Draft NUREG-1937 H-8 March 2010

Appendix H Table H-1. (contd) Agency Authority Requirement Activity Covered Status

TCEQ RCRA, T.A.C. Title 30, Part 

1, Chapter 334 

Certificate of Annual Tank Registration -Notice of Termination 

All underground storage and aboveground storage tanks that are in use or capable of being used for petroleum products and certain chemicals. Tank removal/abandonment 

As required 

TCEQ FCWA, T.A.C. Title 30, 

Part 1, Chapter 307, 308, 309, and 317 

Amendment to existing TPDES Permit 

Regulates limits of pollutants in liquid discharge to surface water TPDES Permit No. 01908. Expiration date: 12/1/09. 

Renewal review in process by TCEQ 

TCEQ Revision of existing Title V 

Operating Permit 

Operation of air emission sources 

Update existing permit as necessary. 

Permit No. 0801 Expiration Date: 1/25/2011 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 335 

Revision/new permit for Industrial/ Hazardous Waste 

Industrial/Hazardous waste generation, storage, and disposal activities. 

As required 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 327 

Spill Prevention and Control 

Procedures for reporting spills of hazardous materials onsite (Covered in the STPEGS Integrated Spill Contingency Plan) 

As required 

TCEQ T.A.C. Title 30, Part 1, 

Chapter 328 

Waste Minimization and Recycling 

Program for waste reduction (Covered in the STPEGS Source Reduction and Waste minimization Program) 

As required 
March 2010 H-9 Draft NUREG-1937

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered Status

TCEQ Multi-sector stormwater 

Permit 

Revision of Stormwater Pollution Prevention Plan 

Areas meeting the definition of industrial activity to be added to current program. 

As required 

Texas Historical Commission (THC) 

National Historic Preservation Act, (36 Code of Federal Regulations (CFR) 800), Texas Historical Commission T.A.C. Title 13, Part 2 

Consultation regarding potential to adversely affect historic resources 

Confirm site construction or operation would not affect protected historic resources. Triggering Activity: Authorization must be obtained before excavation or soil disturbance in area where historic resources are located. 

Complete 

NOAA, Texas Coastal Coordination Council (CCC) 

Coastal Zone Management Act, Texas Coastal Management Plan implemented through CCC 

Consistency review NRC license, any individual 

Section 404 permit. 

Complete Consistency Determination received 06/09/08 

Texas Parks and Wildlife Division 

Resource Protection 

(T.A.C. Title 31, Part 2, Chapter 69) Wildlife (T.A.C. Title 31, Part 2, Chapter 65) 

Consultation regarding potential to adversely impact State-listed protected species 

Adverse impacts on state-listed protected species and/or their habitat. 

Complete 
Draft NUREG-1937 H-10 March 2010

Appendix H Table H-1. (contd) Agency Authority Requirement Activity Covered Status

Texas Department of State Health Services 

FCAA, 40 CFR Part 61, Subpart M, Texas Asbestos Health Protection (T.A.C. Title 25, Part 1, Chapter 295, Subchapter C) 

Notice of intent for asbestos renovation, encapsulation, or demolition 

Building demolition or renovation activities and asbestos abatement projects. 

As required 

State of Tennessee Department of Environment and Conservation Division of Radiological Health 

Tennessee Department of Environment and Conservation Rule 1200-2-10.32 

Revision of existing Tennessee Radioactive Waste License-for-Delivery 

Transportation of radioactive waste into the State of Tennessee. 

If required 

State of Utah Department of Environmental Quality Division of Radiation Control 

R313-26 of the Utah Radiation Control Rules 

Revision of existing General Site Access Permit 

Transportation of radioactive materials into the State of Utah. 

If required 

Coastal Plains Groundwater Conservation District (CPGCD) 

Rules of the CPGCD, Chapter 3, Subchapter A 

Groundwater Well Permit 

New groundwater well installation and operation. 

Issued 02/07/2008 Expires 02/28/2011 
March 2010 H-11 Draft NUREG-1937

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered Status

CPGCD Rules of the CPGCD, 

Chapter 8 

Capping and plugging of groundwater wells 

Capping and plugging of monitoring wells at completion of subsurface investigation. 

As required 

Matagorda County 

Flood Plain Management Plan C Zone Requirements 

Land Disturbing Activity and Construction Permit 

Land disturbing activities within the boundaries of Matagorda County including new construction and renovation of buildings. 

As required 

Appendix I 

Carbon Dioxide Footprint Estimates for a 1000 MW(e) 

Light Water Reactor (LWR) 

March 2010 I-1 Draft NUREG-1937 

1 Appendix I 

2 

3 Carbon Dioxide Footprint Estimates for a 1000 MW(e) 

4 Light Water Reactor (LWR) 

5 The review team has estimated the carbon dioxide (CO2) footprint of various activities 

6 associated with nuclear power plants. These activities include building, operating, and 

7 decommissioning the plant. The estimates include direct emissions from the nuclear facility and 

8 indirect emissions from workforce transportation and the uranium fuel cycle. 

9 Construction equipment estimates listed in Table I-1 are based on hours of equipment use 

10 estimated for a single nuclear power plant at a site requiring a moderate amount of terrain 

11 modification. Equipment usage for a multiple unit facility would be larger, but it is likely that it 

12 would not be a factor of 2 larger. A reasonable set of emissions factors used to convert the 

13 hours of equipment use to CO2 emissions are based on carbon monoxide emissions (UniStar 

14 2007) scaled to CO2 using a scaling factor of 165 tons of CO2 per ton of CO. This scaling factor 

15 is based on emissions factors in Table 3.3-1 of AP-42 (EPA 1995). Equipment emissions 

16 estimated for decommissioning are one half of those for construction. 

17 Table I-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. 

18 Workforce estimates are typical workforce numbers for new plant construction and operation 

19 based on estimates in various COL applications, and decommissioning workforce emissions 

20 estimates are based on decommissioning workforce estimates in NUREG-0586 S1, Generic 

21 Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1 
Appendix I 

Draft NUREG-1937 I-2 March 2010 

1 Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). A typical 

2 construction workforce averages about 2500 for a 7-year period with a peak work force of about 

3 4000. A typical operations workforce for the 40-year life of the plant is assumed to be about 

4 400, and the decommissioning workforce during a decontamination and dismantling period of 10 

5 years is assumed to be 200 to 400. In all cases, the daily commute is assumed to involve a 

6 100-mi roundtrip with 2 individuals per vehicle. Considering shifts, holidays, and vacations,1250 

7 roundtrips per day are assumed each day of the year during construction; 200 roundtrips per 

8 day are assumed each day during operations; and 150 roundtrips per day are assumed 250 

9 days per year for the decontamination and dismantling portion of decommissioning. If the 

10 SAFSTOR decommissioning option is included in decommissioning, 20 roundtrips each day of 

11 the year are assumed for the caretaker workforce. 

12 Table I-2 lists the review team’s estimates of the carbon dioxide equivalent emissions associated 

13 with workforce transport. The table lists the assumptions used to estimate total miles traveled by 

14 each workforce and the factors used to convert total miles to metric tons CO2 equivalent. CO2

15 equivalent accounts for other greenhouse gases, such as methane and nitrous oxide, that are 

16 emitted by internal combustion engines. The workers are assumed to travel in gasoline powered 

17 passenger vehicles (cars, trucks, vans, and SUVs) that get an average of 19.7 mi per gallon of 

18 gas (FHWA 2006). Conversion from gallons of gasoline burned to CO2 equivalent is based on 

19 Environmental Protection Agency emissions factors (EPA 2007a; 2007b). 

20 Table I-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
Appendix I 

March 2010 I-3 Draft NUREG-1937 

1 Published estimates of uranium fuel cycle CO2 emissions required to support a nuclear power 

2 plant range from about 1 percent to about 5 percent of the CO2 emissions from a comparably 

3 sized coal-fired plant (Sovacool 2008). A coal-fired power plant emits about 1 metric ton of CO2

4 for each megawatt hour generated (Miller and Van Atten 2004). Therefore, for consistency with 

5 Table S-3 of 10 CFR 51.51, the NRC staff estimated the uranium fuel cycle CO2 emissions as 

6 0.05 metric tons of CO2 per MWh generated and assumed an 80 percent capacity factor. 

7 Finally, the review team estimated the CO2 emissions directly related to plant operations from 

8 the typical usage of various diesel generators onsite using EPA emissions factors (EPA 1995). 

9 The review team assumed an average of 600 hrs of emergency diesel generator operation per 

10 year (total for 4 generators) and 200 hrs of station blackout diesel generator operation per year 

11 (total for 2 generators). 

12 Given the various sources of CO2 emissions discussed above, the review team estimates the 

13 total life CO2 footprint for a reference 1000 MW(e) nuclear power plant to be about 18 million 

14 metric tons. The components of the footprint are summarized in Table I-3. The uranium fuel 

15 cycle component of the footprint dominates all other components. It is directly related to power 

16 generated. As a result, it is reasonable to use reactor power to scale the footprint to larger 

17 reactors. 

18 Table I-3. 1000 MW(e) LWR 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 1.4 × 107

Decommissioning Equipment 10 1.8 × 104

Decommissioning Workforce 10 1.7 × 104

SAFSTOR Workforce 40 1.3 × 104

TOTAL 1.5 × 107

19 In closing, the review team considers the footprint estimated in Table I-3 to be appropriately 

20 conservative. The CO2 emissions estimates for the dominant component (uranium fuel cycle) 

21 are based on 30 year old enrichment technology assuming that the energy required for 

22 enrichment is provided by coal-fired generation. Different assumptions related to the source of 

23 energy used for enrichment or the enrichment technology that would be just as reasonable 

24 could lead to a significantly reduced footprint. 
Appendix I 

Draft NUREG-1937 I-4 March 2010 

1 Emissions estimates presented in the body of this EIS have been scaled to values that are 

2 appropriate for the proposed project. The uranium fuel cycle emissions have been scaled by 

3 reactor power using the scaling factor determined in Chapter 6 and by the number of reactors to 

4 be built. Plant operations emissions have been adjusted to represent the number of large CO2

5 emissions sources (diesel generators, boilers, etc.) associated with the project. The workforce 

6 emissions estimates have been scaled to account for differences in workforce numbers and 

7 commuting distance. Finally, equipment emissions estimates have been scaled by estimated 

8 equipment usage. As can be seen in Table I-3, only the scaling of the uranium fuel cycle 

9 emissions estimates makes a significant difference in the total carbon footprint of the project. 

10 I.1 References 

11 Federal Highway Administration (FHWA). 2006. Highway Statistics 2005 (Table VM-1). Office 

12 of Highway Policy Information. Washington, D.C. 

13 Miller, P. J., and C. Van Atten. 2004. North American Power Plant Air Emissions. Commission 

14 for Environmental Cooperation of North America, Montreal. 

15 Sovacool, B. K. 2008. “Valuing the greenhouse gas emissions from nuclear power: A critical 

16 survey. Energy Policy 36:2940-2953. Elsevier Ltd. 

17 UniStar Nuclear Energy, LLC (UniStar). 2007. Technical Report in Support of Application of 

18 UniStar Nuclear Operating Services, LLC for Certificate of Public Convenience and Necessity 

19 Before the Maryland Public Service Commission for Authorization to Construct Unit 3 at Calvert 

20 Cliffs Nuclear Power Plant and Associated Transmission Lines. Prepared for the Public Service 

21 Commission of Maryland, dated 6 November 2007. Accession No. ML090680065. 

22 U.S. Environmental Protection Agency. 1995. Compilation of Air Pollutant Emission Factors 

Volume 1: Stationary and Point and Area Sources. AP-42, 5th 23 Edition. Office of Air and 

24 Radiation, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. 

25 U.S. Environmental Protection Agency. 2007a. Inventory of U. S. Greenhouse Gas Emissions 

26 and Sinks: 1990-2005 (Table 3-7). U.S. Environmental Protection Agency. Washington, D.C. 

27 U.S. Environmental Protection Agency. 2007b. “Conversion Factors to Energy Units (Heat 

28 Equivalents) Heat Contents and Carbon Content Coefficients of Various Fuel Types.” Inventory 

29 of U. S. Greenhouse Gas Emissions and Sinks: Fast Facts 1990-2005. EPA-430-R-07-002. 

30 U.S. Environmental Protection Agency. Washington, D.C. 

31 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

32 on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the Decommissioning of 

33 Nuclear Power Reactors. NUREG-0586 S1, Vol. 1, Washington, D.C. 
Appendix J 

U.S. Army Corps of Engineers Cumulative Effect 

Resource Analysis Table 

Draft NUREG-1937 J-1 March 2010

Appendix J Table J-1. U.S. Army Corps of Engineers (Corps) Cumulative Effect Resource Analysis Table 1 

Corps Resource/Issue 

Summary of Direct Impacts 

of the Proposed Action 

Included 

in 

Analysis Explanation of Impact 

Considered in South Texas 

Project (STP) DEIS 

Land Use Resources 

Local Land Plans and Policies 

Compatible with all local Land Use plans and policies. 

No Documentation, not a resource NA 

Local and Regional Area Land Use 

About 540 acres within the existing STP site would be cleared and excavated. 

Yes Area was previously disturbed 

by construction on Units 1 and 2. No new transmission lines are planned. 

Section 7.1 

Social and Economic Resources 

Environmental Justice Disproportionate adverse 

effects to health or welfare of minority or low income groups 

Yes No disproportionate adverse 

effects of the proposed project. 

Section 7.4.2 

Community Cohesion The proposed location is 

entirely within the existing STP site. 

No Not a pertinent resource NA 

ROW Requirements, Relocations, Displacements 

A new heavy haul road would be installed for access to the barge slip. However, the activity is all onsite and there are no new ROW associated with the haul road. 

No All impacts from heavy haul 

road would be entirely within the existing STP site 

NA 

Public Facilities and Services Hard and soft infrastructure Yes Moderate adverse impact to 

Matagorda Co in housing, schools and possibly emergency services. 

Section 7.4.1 

2 
March 2010 J-2 Draft NUREG-1937

Appendix J

Table J-1. (contd)

Corps Resource/Issue 

Summary of Direct Impacts 

of the Proposed Action 

Included 

in 

Analysis Explanation of Impact 

Considered in South Texas 

Project (STP) DEIS 

Visual Resources Addition of structures and 

cooling towers. 

Yes Minimal impact due to proximity 

to existing facility. 

Section 7.4.1 

Existing Circulation Patterns All current circulation 

patterns would remain after construction 

No Not a pertinent resource 

Traffic Will generate additional 

traffic on roadways. 

Yes Peak traffic would result in 

congestion. 

Section 7.4.1 

Noise Project will result in noise 

that could impact sensitive receptors 

Yes Workers, residents and 

recreational uses would not experience elevated noise levels. 

Section 7.4.1 

Recreational Boating Project will include delivery 

of large components by barge 

Yes Construction and maintenancedredging related impact. Section 7.4.1 

Marine Navigation Project will include delivery 

of large components by barge 

Yes Construction and maintenancedredging related impact. Section 7.4.1 

Natural Resources 

Prairie Uplands No Direct Impacts No Not a pertinent resource, no 

coastal prairie as defined by USFWS identified within the project area 

NA 

Riparian Habitat No Direct Impacts No Not a pertinent resource NA Wildlife Habitat Areas that may have 

formerly been used for habitat would be permanently or temporarily 

Yes Incremental contribution of 

impacts to terrestrial resources from building and operating proposed Units 3 and 4 would 

Section 7.3.1 
Draft NUREG-1937 J-3 March 2010

Appendix J Table J-1. (contd)

Corps Resource/Issue 

Summary of Direct Impacts 

of the Proposed Action 

Included 

in 

Analysis Explanation of Impact 

Considered in South Texas 

Project (STP) DEIS 

displaced, and migration routes may be temporarily or permanently blocked by construction and/or construction practices. 

be SMALL. 

Threatened and Endangered Species 

Construction disturbs existing habitats. 

Yes Impacts on terrestrial State and 

Federally listed threatened and endangered species from building activities on the STP site would be negligible. 

Section 7.3.1 

Migratory and Resident Birds New structures create 

collision hazards. 

Yes Largest structure (cooling 

tower) is similar in height to other existing structures. 

Section 7.3.1 

Farmland No Direct Impacts No Not a pertinent resource NA Water Quality Water discharges to the 

Colorado River, minor stormwater runoff. 

Yes Construction and operations 

impacts would be SMALL 

Section 7.2.2 

Hazardous Materials Radioactive and 

nonradioactive materials. 

Yes Radiological and 

nonradiological health impacts would be SMALL 

Sections 7.7 and 7.8 

Air Quality Matagorda County is in 

attainment of all criteria pollutants. 

Yes Construction and operations 

impacts would be SMALL 

Section 7.6 

Wetlands: Estuarine No Direct Impacts No Not a pertinent resource NA Wetlands: Dune Swale No Direct Impacts No Not a pertinent resource NA Wetlands: Sand Flat No Direct Impacts No Not a pertinent resource NA Floodplains No Direct Impacts No Not a pertinent resource NA 
March 2010 J-4 Draft NUREG-1937

Appendix J

Table J-1. (contd)

Corps Resource/Issue 

Summary of Direct Impacts 

of the Proposed Action 

Included 

in 

Analysis Explanation of Impact 

Considered in South Texas 

Project (STP) DEIS 

Bay Bottom No Direct Impacts No Discharge to Colorado River. 

Not a pertinent resource 

NA 

Coastal Hazards No Direct Impacts No Discharge in to Colorado River. 

Not a pertinent resource 

NA 

Cultural Resources 

Archeology No known resources 

anticipated to be impacted. 

Yes Section 7.5 

Historical Resources No known resources 

anticipated to be impacted. 

Yes 

STPNOC has agreed to follow procedures to be taken if cultural or historic resources are discovered during grounddisturbing activities associated with building Units 3 and 4. These procedures are detailed in STPNOC’s Addendum #5 to procedure No. OPGP03-ZO0025 Rev. 12 (Unanticipated Discovery of Cultural Resources) (STPNOC 2008g); the procedure includes notification of Texas Historic Commission 

Section 7.5 

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