NUREG-1937, Vol. 2

Environmental Impact Statement for 

Combined Licenses (COLs) for 

South Texas Project Electric 

Generating Station Units 3 and 4 

Final Report 

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 
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Environmental Impact Statement for 

Combined Licenses (COLs) for 

South Texas Project Electric 

Generating Station Units 3 and 4

Final Report 

Manuscript Completed: February 2011 

Date Published: February 2011 

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, Texas 77553-1229 

 NUREG-1937, Vol. 2 

February 2011 iii NUREG-1937 

Abstract 

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

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

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

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

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

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

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

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

collaboratively on the review team. 

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

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

and mitigation measures available for reducing or avoiding adverse impacts. 

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

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

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

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

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

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

alternatives analysis to determine the Least Environmentally Damaging Practicable Alternative. 

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

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

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

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

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

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

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

February 2011 v NUREG-1937 

Contents 

Abstract ......................................................................................................................................... iii

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

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

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

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

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

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

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

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

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

1.1.4 Concurrent NRC Reviews ............................................................................ 1-7

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

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

1.4 Alternatives to the Proposed Actions ....................................................................... 1-9

1.5 Compliance and Consultations ............................................................................... 1-10

1.6 References ............................................................................................................. 1-10

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

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

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

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

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

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

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

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

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

2.3.1.2 Groundwater Hydrology ............................................................... 2-22

2.3.2 Water Use ................................................................................................... 2-33

2.3.2.1 Surface-Water Use ...................................................................... 2-34

2.3.2.2 Groundwater Use ......................................................................... 2-36

2.3.3 Water Quality .............................................................................................. 2-40

2.3.3.1 Surface-Water Quality ................................................................. 2-40

2.3.3.2 Groundwater Quality .................................................................... 2-42
NUREG-1937 vi February 2011 

2.3.4 Water Monitoring ........................................................................................ 2-44

2.3.4.1 Surface-Water Monitoring ............................................................ 2-44

2.3.4.2 Groundwater Monitoring .............................................................. 2-46

2.4 Ecology ................................................................................................................... 2-48

2.4.1 Terrestrial Ecology ...................................................................................... 2-48

2.4.1.1 Terrestrial Communities of the Site and Vicinity .......................... 2-48

2.4.1.2 Terrestrial Resources – Transmission Lines ................................ 2-56

2.4.1.3 Important Terrestrial Species and Habitats .................................. 2-57

2.4.1.4 Terrestrial Ecology Monitoring ..................................................... 2-67

2.4.2 Aquatic Ecology .......................................................................................... 2-67

2.4.2.1 Aquatic Resources of the Site and Vicinity .................................. 2-67

2.4.2.2 Aquatic Resources – Transmission Lines .................................... 2-88

2.4.2.3 Important Aquatic Species and Habitats ...................................... 2-88

2.4.2.4 Aquatic Monitoring ..................................................................... 2-108

2.5 Socioeconomics ................................................................................................... 2-109

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

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

2.5.1.2 Transient Population .................................................................. 2-115

2.5.1.3 Migrant Labor ............................................................................. 2-116

2.5.2 Community Characteristics ....................................................................... 2-117

2.5.2.1 Economy .................................................................................... 2-118

2.5.2.2 Taxes ......................................................................................... 2-121

2.5.2.3 Transportation ............................................................................ 2-127

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

2.5.2.5 Housing ...................................................................................... 2-132

2.5.2.6 Public Services .......................................................................... 2-134

2.6 Environmental Justice .......................................................................................... 2-146

2.6.1 Methodology ............................................................................................. 2-147

2.6.2 Scoping and Outreach .............................................................................. 2-153

2.6.3 Subsistence and Communities with Unique Characteristics .................... 2-153

2.6.4 Migrant Populations .................................................................................. 2-155

2.6.5 Environmental Justice Summary .............................................................. 2-155

2.7 Historic and Cultural Resources ........................................................................... 2-156

2.7.1 Cultural Background ................................................................................. 2-156

2.7.2 Historic and Cultural Resources at the Site .............................................. 2-157

2.7.3 Consultation .............................................................................................. 2-159
February 2011 vii NUREG-1937 

2.8 Geology ................................................................................................................ 2-160

2.9 Meteorology and Air Quality ................................................................................. 2-161

2.9.1 Climate ..................................................................................................... 2-161

2.9.1.1 Wind ........................................................................................... 2-163

2.9.1.2 Temperature .............................................................................. 2-163

2.9.1.3 Atmospheric Moisture ................................................................ 2-163

2.9.1.4 Severe Weather ......................................................................... 2-164

2.9.1.5 Atmospheric Stability ................................................................. 2-164

2.9.2 Air Quality ................................................................................................. 2-165

2.9.3 Atmospheric Dispersion ............................................................................ 2-165

2.9.3.1 Short-Term Dispersion Estimates .............................................. 2-166

2.9.3.2 Long-Term Dispersion Estimates............................................... 2-167

2.9.4 Meteorological Monitoring ........................................................................ 2-167

2.10 Nonradiological Health ......................................................................................... 2-168

2.10.1 Public and Occupational Health ............................................................... 2-168

2.10.1.1 Air Quality .................................................................................. 2-168

2.10.1.2 Occupational Injuries ................................................................. 2-169

2.10.1.3 Etiological Agents ...................................................................... 2-170

2.10.2 Noise ........................................................................................................ 2-171

2.10.3 Transportation .......................................................................................... 2-172

2.10.4 Electromagnetic Fields ............................................................................. 2-172

2.11 Radiological Environment ..................................................................................... 2-173

2.12 Related Federal Projects and Consultation .......................................................... 2-174

2.13 References ........................................................................................................... 2-174

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

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

3.2 Proposed Plant Structures, Systems, and Components .......................................... 3-2

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

3.2.2 Structures, Systems, and Components with a Major Environmental 

Interface ........................................................................................................ 3-3

3.2.2.1 Landscape and Stormwater Drainage ........................................... 3-6

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

3.2.2.3 Other Permanent Plant-Environment Interfacing Structures, 

Systems, or Components .............................................................. 3-9

3.2.2.4 Other Temporary Plant-Environment Interfacing Structures ........ 3-11

3.2.3 Structures with a Minor Environmental Interface ........................................ 3-11
NUREG-1937 viii February 2011 

3.3 Construction and Preconstruction Activities ........................................................... 3-13

3.3.1 Major Activity Areas .................................................................................... 3-13

3.3.2 Summary of Resource Commitments During Construction and 

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

3.4 Operational Activities .............................................................................................. 3-17

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

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

3.4.2.1 Circulating Water System – Intakes, Discharges, Cooling 

Towers ......................................................................................... 3-19

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

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

3.4.2.4 Emergency Diesel Generators ..................................................... 3-20

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

3.4.3.1 Liquid Radioactive Waste-Management System ......................... 3-21

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

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

3.4.4 Nonradioactive Waste-Management Systems ........................................... 3-23

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

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

3.4.4.3 Gaseous Waste Management ..................................................... 3-25

3.4.4.4 Hazardous and Mixed Waste Management ................................. 3-25

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

3.5 References ............................................................................................................. 3-27

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

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

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

4.1.2 Transmission Line Corridors and Offsite Areas ............................................ 4-5

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

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

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

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

4.2.3.1 Surface-Water Quality Impacts .................................................... 4-12

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

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

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

4.3.1 Terrestrial and Wetland Impacts ................................................................. 4-15
February 2011 ix NUREG-1937 

4.3.1.1 Impacts to Terrestrial Resources – Site and Vicinity ................... 4-15

4.3.1.2 Terrestrial Resources – Transmission Line Corridors .................. 4-18

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

4.3.1.4 Terrestrial Monitoring ................................................................... 4-24

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

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

4.3.2.1 Aquatic Resources – Site and Vicinity ......................................... 4-27

4.3.2.2 Aquatic Resources –Transmission Line Corridors ....................... 4-30

4.3.2.3 Important Aquatic Species and Habitats ...................................... 4-31

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

4.3.2.5 Potential Mitigation Measures for Aquatic Impacts ...................... 4-37

4.3.2.6 Summary of Impacts to Aquatic Resources ................................. 4-37

4.4 Socioeconomic Impacts ......................................................................................... 4-38

4.4.1 Physical Impacts ......................................................................................... 4-38

4.4.1.1 Workers and the Local Public ...................................................... 4-38

4.4.1.2 Buildings ...................................................................................... 4-39

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

4.4.1.4 Aesthetics .................................................................................... 4-40

4.4.1.5 Summary of Physical Impacts ...................................................... 4-40

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

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

4.4.3.1 Economy ...................................................................................... 4-43

4.4.3.2 Taxes ........................................................................................... 4-44

4.4.3.3 Summary of Economic Impacts to the Community ...................... 4-46

4.4.4 Infrastructure and Community Service Impacts .......................................... 4-46

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

4.4.4.2 Recreation ................................................................................... 4-49

4.4.4.3 Housing ........................................................................................ 4-49

4.4.4.4 Public Services ............................................................................ 4-50

4.4.4.5 Education ..................................................................................... 4-53

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

4.4.5 Summary of Socioeconomic Impacts ......................................................... 4-54

4.5 Environmental Justice Impacts ............................................................................... 4-55

4.5.1 Analytical Considerations ........................................................................... 4-55

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

4.5.3 Physical and Environmental Impacts .......................................................... 4-57

4.5.3.1 Soil ............................................................................................... 4-57

4.5.3.2 Water ........................................................................................... 4-57
NUREG-1937 x February 2011 

4.5.3.3 Air ................................................................................................ 4-58

4.5.3.4 Noise ............................................................................................ 4-58

4.5.3.5 Summary of Physical and Environmental Impacts ....................... 4-58

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

4.5.5 Subsistence and Special Conditions .......................................................... 4-59

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

4.5.5.2 High-Density Communities .......................................................... 4-60

4.5.6 Summary of Environmental Justice Impacts .............................................. 4-61

4.6 Historic and Cultural Resources ............................................................................. 4-61

4.7 Meteorological and Air-Quality Impacts .................................................................. 4-63

4.7.1 Construction and Preconstruction Activities ............................................... 4-63

4.7.2 Traffic .......................................................................................................... 4-64

4.7.3 Summary .................................................................................................... 4-66

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

4.8.1 Public and Occupational Health ................................................................. 4-66

4.8.1.1 Public Health ................................................................................ 4-66

4.8.1.2 Construction Worker Health ......................................................... 4-67

4.8.1.3 Summary of Public and Construction Worker Health Impacts ..... 4-68

4.8.2 Noise Impacts ............................................................................................. 4-68

4.8.3 Impacts of Transporting Construction Materials and Construction 

Personnel to the STP Site .......................................................................... 4-69

4.8.4 Summary of Nonradiological Health Impacts ............................................. 4-72

4.9 Radiological Health Impacts ................................................................................... 4-72

4.9.1 Direct Radiation Exposures ........................................................................ 4-72

4.9.2 Radiation Exposures from Gaseous Effluents ............................................ 4-73

4.9.3 Radiation Exposures from Liquid Effluents ................................................. 4-74

4.9.4 Total Dose to Construction Workers ........................................................... 4-74

4.9.5 Summary of Radiological Health Impacts ................................................... 4-74

4.10 Nonradioactive Waste Impacts ............................................................................... 4-75

4.10.1 Impacts to Land .......................................................................................... 4-75

4.10.2 Impacts to Water ........................................................................................ 4-76

4.10.3 Impacts to Air .............................................................................................. 4-76

4.10.4 Summary of Impacts ................................................................................... 4-77
February 2011 xi NUREG-1937 

4.11 Measures and Controls to Limit Adverse Impacts During Construction 

Activities ................................................................................................................. 4-77

4.12 Summary of Preconstruction and Construction Impacts ........................................ 4-78

4.13 References ............................................................................................................. 4-88

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

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

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

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

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

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

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

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

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

5.2.3 Water-Quality Impacts ................................................................................ 5-15

5.2.3.1 Surface-Water Quality Impacts .................................................... 5-15

5.2.3.2 Groundwater-Quality Impacts ...................................................... 5-19

5.2.4 Water Monitoring ........................................................................................ 5-21

5.3 Ecological Impacts ................................................................................................. 5-22

5.3.1 Terrestrial and Wetland Impacts ................................................................. 5-22

5.3.1.1 Terrestrial Resources – Site and Vicinity ..................................... 5-23

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

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

5.3.1.4 Terrestrial Monitoring ................................................................... 5-31

5.3.1.5 Summary of Terrestrial Ecosystems Impacts .............................. 5-31

5.3.2 Aquatic Impacts .......................................................................................... 5-32

5.3.2.1 Aquatic Resources – Site and Vicinity ......................................... 5-32

5.3.2.2 Aquatic Resources – Transmission Lines .................................... 5-44

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

5.3.2.4 Aquatic Monitoring ....................................................................... 5-48

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

5.4 Socioeconomic Impacts ......................................................................................... 5-49

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

5.4.1.1 Workers and the Local Public ...................................................... 5-50

5.4.1.2 Buildings ...................................................................................... 5-51

5.4.1.3 Roads .......................................................................................... 5-51

5.4.1.4 Aesthetics .................................................................................... 5-51

5.4.1.5 Summary of Physical Impacts ...................................................... 5-51
NUREG-1937 xii February 2011 

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

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

5.4.3.1 Economy ...................................................................................... 5-53

5.4.3.2 Taxes ........................................................................................... 5-54

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

5.4.4 Infrastructure and Community Services ..................................................... 5-57

5.4.4.1 Transportation .............................................................................. 5-57

5.4.4.2 Recreation ................................................................................... 5-58

5.4.4.3 Housing ........................................................................................ 5-58

5.4.4.4 Public Services ............................................................................ 5-59

5.4.4.5 Education ..................................................................................... 5-60

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

5.4.5 Summary of Socioeconomic Impacts ......................................................... 5-61

5.5 Environmental Justice ............................................................................................ 5-61

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

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

5.5.2.1 Soil ............................................................................................... 5-63

5.5.2.2 Water ........................................................................................... 5-63

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

5.5.2.4 Summary of Physical and Environmental Impacts ....................... 5-64

5.5.3 Socioeconomic Impacts .............................................................................. 5-64

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

5.5.5 Summary of Environmental Justice Impacts .............................................. 5-65

5.6 Historic and Cultural Resource Impacts ................................................................. 5-65

5.7 Meteorological and Air Quality Impacts .................................................................. 5-66

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

5.7.2 Cooling System Impacts ............................................................................. 5-68

5.7.3 Summary .................................................................................................... 5-70

5.8 Nonradiological Health Impacts .............................................................................. 5-70

5.8.1 Etiological Agents ....................................................................................... 5-71

5.8.2 Noise .......................................................................................................... 5-73

5.8.3 Acute Effects of Electromagnetic Fields ..................................................... 5-74

5.8.4 Chronic Effects of Electromagnetic Fields .................................................. 5-75

5.8.5 Occupational Health ................................................................................... 5-76

5.8.6 Impacts of Transporting Operations Personnel to the Proposed Site ........ 5-77
February 2011 xiii NUREG-1937 

5.8.7 Summary of Nonradiological Health Impacts ............................................. 5-78

5.9 Radiological Impacts of Normal Operations ........................................................... 5-79

5.9.1 Exposure Pathways .................................................................................... 5-79

5.9.2 Radiation Doses to Members of the Public ................................................ 5-83

5.9.2.1 Liquid Effluent Pathway ............................................................... 5-83

5.9.2.2 Gaseous Effluent Pathway .......................................................... 5-84

5.9.3 Impacts to Members of the Public .............................................................. 5-85

5.9.3.1 Maximally Exposed Individual ...................................................... 5-85

5.9.3.2 Population Dose .......................................................................... 5-87

5.9.3.3 Summary of Radiological Impacts to Members of the Public ....... 5-88

5.9.4 Occupational Doses to Workers ................................................................. 5-88

5.9.5 Doses to Biota Other than Humans ............................................................ 5-89

5.9.5.1 Liquid Effluent Pathway ............................................................... 5-89

5.9.5.2 Gaseous Effluent Pathway .......................................................... 5-90

5.9.5.3 Impact of Estimated Non-Human Biota Doses ............................ 5-90

5.9.6 Radiological Monitoring .............................................................................. 5-91

5.10 Nonradioactive Waste Impacts ............................................................................... 5-93

5.10.1 Impacts to Land .......................................................................................... 5-93

5.10.2 Impacts to Water ........................................................................................ 5-94

5.10.3 Impacts to Air .............................................................................................. 5-95

5.10.4 Mixed Waste Impacts ................................................................................. 5-95

5.10.5 Summary of Waste Impacts ....................................................................... 5-95

5.11 Environmental Impacts of Postulated Accidents .................................................... 5-96

5.11.1 Design Basis Accidents .............................................................................. 5-98

5.11.2 Severe Accidents ...................................................................................... 5-100

5.11.2.1 Air Pathway ................................................................................ 5-101

5.11.2.2 Surface-Water Pathways ........................................................... 5-109

5.11.2.3 Groundwater Pathway ............................................................... 5-110

5.11.2.4 Summary ................................................................................... 5-110

5.11.3 Severe Accident Mitigation Alternatives ................................................... 5-111

5.11.4 Summary of Postulated Accident Impacts ................................................ 5-113

5.12 Measures and Controls to Limit Adverse Impacts During Operation ................... 5-113

5.13 Summary of Operational Impacts ......................................................................... 5-118

5.14 References ........................................................................................................... 5-120

6.0 Fuel Cycle, Transportation, and Decommissioning .......................................................... 6-1
NUREG-1937 xiv February 2011 

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

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

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

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

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

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

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

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

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

6.1.9 Conclusion .................................................................................................. 6-15

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

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

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

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

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

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

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

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

6.2.2.3 Nonradiological Impact of Spent Fuel Shipments ........................ 6-35

6.2.3 Transportation of Radioactive Waste ......................................................... 6-36

6.2.4 Conclusions ................................................................................................ 6-38

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

6.4 References ............................................................................................................. 6-40

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

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

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

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

7.2.1.1 Surface Water-Use Impacts ......................................................... 7-10

7.2.1.2 Groundwater-Use Impacts ........................................................... 7-14

7.2.2 Water-Quality Impacts ................................................................................ 7-17

7.2.2.1 Surface-Water Quality Impacts .................................................... 7-17

7.2.2.2 Groundwater-Quality Impacts ...................................................... 7-20

7.3 Ecology ................................................................................................................... 7-22

7.3.1 Terrestrial and Wetland Ecosystem Impacts .............................................. 7-22

7.3.1.1 Wildlife and Plant Communities ................................................... 7-23
February 2011 xv NUREG-1937 

7.3.1.2 Important Species ........................................................................ 7-27

7.3.2 Aquatic Ecosystem Impacts ....................................................................... 7-30

7.4 Socioeconomics and Environmental Justice .......................................................... 7-36

7.4.1 Socioeconomics ......................................................................................... 7-36

7.4.2 Environmental Justice ................................................................................ 7-40

7.5 Historic and Cultural Resources ............................................................................. 7-42

7.6 Air Quality ............................................................................................................... 7-44

7.6.1 Criteria Pollutants ....................................................................................... 7-44

7.6.2 Greenhouse Gas Emissions ....................................................................... 7-45

7.6.3 Summary .................................................................................................... 7-46

7.7 Nonradiological Health ........................................................................................... 7-47

7.8 Radiological Impacts of Normal Operation ............................................................. 7-49

7.9 Postulated Accidents .............................................................................................. 7-51

7.10 Fuel Cycle, Transportation, and Decommissioning ................................................ 7-52

7.10.1 Fuel Cycle ................................................................................................... 7-52

7.10.2 Transportation ............................................................................................ 7-52

7.10.3 Decommissioning ....................................................................................... 7-55

7.11 Conclusions ............................................................................................................ 7-55

7.12 References ............................................................................................................. 7-58

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

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

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

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

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

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

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

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

8.1.3.4 Responsive to Forecasting Uncertainty Test ................................. 8-7

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

8.2 Power Demand ......................................................................................................... 8-8

8.3 Power Supply ......................................................................................................... 8-19

8.4 Assessment of Need for Power .............................................................................. 8-27

8.4.1 Conclusion .................................................................................................. 8-32

8.5 References ............................................................................................................. 8-33
NUREG-1937 xvi February 2011 

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

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

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

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

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

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

9.2.2.2 Natural Gas-Fired Generation...................................................... 9-13

9.2.3 Other Alternatives ....................................................................................... 9-19

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

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

9.2.3.3 Solar Power ................................................................................. 9-23

9.2.3.4 Hydropower ................................................................................. 9-24

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

9.2.3.6 Wood Waste ................................................................................ 9-25

9.2.3.7 Municipal Solid Waste ................................................................. 9-26

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

9.2.3.9 Fuel Cells ..................................................................................... 9-27

9.2.4 Combination of Alternatives ........................................................................ 9-28

9.2.5 Summary Comparison of Alternatives ........................................................ 9-30

9.3 Alternative Sites ..................................................................................................... 9-33

9.3.1 Alternative Sites Selection Process ............................................................ 9-33

9.3.1.1 Selection of Region of Interest ..................................................... 9-34

9.3.1.2 Selection of Candidate Areas. ..................................................... 9-34

9.3.1.3 Selection of Potential Sites .......................................................... 9-36

9.3.1.4 Selection of Primary Sites ............................................................ 9-37

9.3.1.5 Selection of Candidate Sites ........................................................ 9-39

9.3.1.6 Evaluation of STPNOC’s Site Selection Process ......................... 9-43

9.3.2 Red 2 .......................................................................................................... 9-45

9.3.2.1 Land Use ..................................................................................... 9-47

9.3.2.2 Water Use and Quality ................................................................. 9-50

9.3.2.3 Terrestrial and Wetland Resources ............................................. 9-59

9.3.2.4 Aquatic Resources ....................................................................... 9-70

9.3.2.5 Socioeconomics ........................................................................... 9-77

9.3.2.6 Environmental Justice .................................................................. 9-84

9.3.2.7 Historic and Cultural Resources .................................................. 9-87

9.3.2.8 Air Quality .................................................................................... 9-89

9.3.2.9 Nonradiological Health ................................................................. 9-91

9.3.2.10 Radiological Impacts of Normal Operations ................................. 9-93
February 2011 xvii NUREG-1937 

9.3.2.11 Postulated Accidents ................................................................... 9-94

9.3.3 Allens Creek ............................................................................................... 9-95

9.3.3.1 Land Use ..................................................................................... 9-98

9.3.3.2 Water Use and Quality ............................................................... 9-101

9.3.3.3 Terrestrial and Wetland Resources ........................................... 9-108

9.3.3.4 Aquatic Resources ..................................................................... 9-120

9.3.3.5 Socioeconomics ......................................................................... 9-129

9.3.3.6 Environmental Justice ................................................................ 9-135

9.3.3.7 Historic and Cultural Resources ................................................ 9-140

9.3.3.8 Air Quality .................................................................................. 9-143

9.3.3.9 Nonradiological Health ............................................................... 9-144

9.3.3.10 Radiological Impacts of Normal Operations ............................... 9-146

9.3.3.11 Postulated Accidents ................................................................. 9-147

9.3.4 Trinity 2 ..................................................................................................... 9-148

9.3.4.1 Land Use ................................................................................... 9-152

9.3.4.2 Water Use and Quality ............................................................... 9-155

9.3.4.3 Terrestrial and Wetland Resources ........................................... 9-163

9.3.4.4 Aquatic Resources ..................................................................... 9-175

9.3.4.5 Socioeconomics ......................................................................... 9-183

9.3.4.6 Environmental Justice ................................................................ 9-190

9.3.4.7 Historic and Cultural Resources ................................................ 9-194

9.3.4.8 Air Quality .................................................................................. 9-197

9.3.4.9 Nonradiological Health ............................................................... 9-198

9.3.4.10 Radiological Impacts of Normal Operations ............................... 9-200

9.3.4.11 Postulated Accidents ................................................................. 9-201

9.3.5 Comparison of the Impacts of the Proposed Action and Alternative 

Sites .......................................................................................................... 9-202

9.3.5.1 Comparison of Cumulative Impacts at the Proposed and 

Alternative Sites ......................................................................... 9-203

9.3.5.2 Environmentally Preferable Sites ............................................... 9-205

9.3.5.3 Obviously Superior Sites............................................................ 9-207

9.4 System Design Alternatives ................................................................................. 9-208

9.4.1 Heat Dissipation Systems ......................................................................... 9-208

9.4.1.1 Plant Cooling System – Once-Through Operation ..................... 9-208

9.4.1.2 Spray Canals ............................................................................. 9-209

9.4.1.3 Wet Mechanical Draft Cooling Towers....................................... 9-209

9.4.1.4 Wet Natural Draft Cooling Towers ............................................. 9-210

9.4.1.5 Dry Cooling Towers ................................................................... 9-210

9.4.1.6 Combination Wet/Dry Cooling Tower System ............................ 9-211
NUREG-1937 xviii February 2011 

9.4.2 Circulating Water Systems ....................................................................... 9-211

9.4.2.1 Intake Alternatives ..................................................................... 9-211

9.4.2.2 Discharge Alternatives ............................................................... 9-212

9.4.2.3 Water Supplies .......................................................................... 9-213

9.4.2.4 Water Treatment ........................................................................ 9-215

9.4.3 Conclusion ................................................................................................ 9-215

9.5 Corps’ Onsite Alternatives Evaluation .................................................................. 9-215

9.5.1 Onsite Alternative 1 .................................................................................. 9-215

9.5.2 Onsite Alternative 2 .................................................................................. 9-216

9.5.3 Onsite Alternative 3 (STPNOC’s Preferred Alternative) ........................... 9-216

9.6 References ........................................................................................................... 9-216

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

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

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

10.2.1 Unavoidable Adverse Impacts During Construction and 

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

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

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

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

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

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

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

10.4.1.2 Water Use .................................................................................. 10-15

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

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

10.4.1.5 Air and Water ............................................................................. 10-16

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

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

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

10.6.1 Benefits ..................................................................................................... 10-19

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

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

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

10.6.2.1 Internal Costs ............................................................................. 10-25

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

10.6.3 Summary of Benefits and Costs ............................................................... 10-29
February 2011 xix NUREG-1937 

10.7 Staff Conclusions and Recommendations ........................................................... 10-29

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

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

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

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

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

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

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

Appendix G – Supporting Documentation for Socioeconomic and Radiological Dose 

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

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

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

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

Appendix J – U.S. Army Corps of Engineers Cumulative Effect Resource Analysis Table ....... J-1

Appendix K – U.S. Army Corps of Engineers Public Notice Comments ................................... K-1
NUREG-1937 xx February 2011 

Figures 

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

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

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

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

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

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

2-7 Location of the STP Site and the Adjacent Watersheds ................................................ 2-13

2-8 The Colorado River Basin .............................................................................................. 2-14

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

the Gulf of Mexico .......................................................................................................... 2-15

2-10 Daily Mean Colorado River Discharge near Bay City, Texas ........................................ 2-16

2-11 The Six LCRA Dams and the Corresponding Highland Lakes They Impound .............. 2-18

2-12 Current and Previous Locations of the Main Drainage Channel .................................... 2-20

2-13 Kelly Lake and Local Drainages Flowing Into and Out of the Lake ............................... 2-21

2-14 Correlation of USGS and Texas Nomenclature ............................................................. 2-24

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

2-16 Generalized Hydrostratigraphic Section Underlying the STP Site ................................. 2-30

2-17 Hydrological Monitoring Locations for Existing STP Units 1 and 2 ................................ 2-45

2-18 Stormwater Monitoring Locations for Existing STP Units 1 and 2 ................................. 2-47

2-19 Vegetation Cover and Land-Use Cover Types at the STP Site ..................................... 2-50

2-20 Locations of Wildlife Refuges and Critical Habitat Within 50 mi of the STP Site ........... 2-59

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

Aquatic Ecology Sampling Locations ............................................................................. 2-71

2-22 Aquatic Ecology Sampling Locations for 2007-2008, from NMM 5 to 9 ........................ 2-80

2-23 Aquatic Ecology Sampling Locations for 2007-2008, from GIWW to NMM 4 ................ 2-81

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

Proposed Units 3 and 4 ............................................................................................... 2-112

2-25 Road, Highway, and Rail Transportation System ........................................................ 2-128

2-26 Main Routes to STP Site ............................................................................................. 2-129

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

Selection Criteria ......................................................................................................... 2-149

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

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

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

Justice Selection Criteria ............................................................................................. 2-151

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

Criteria ......................................................................................................................... 2-152
February 2011 xxi NUREG-1937 

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

Justice Selection Criteria ............................................................................................. 2-154

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

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

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

4-1 Total Workforce, STP Units 3 and 4 .............................................................................. 4-42

5-1 Exposure Pathways to Man ........................................................................................... 5-81

5-2 Exposure Pathways to Biota Other Than Man ............................................................... 5-82

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

6-2 Illustration of Truck Stop Model ..................................................................................... 6-29

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

Terrestrial Ecological Resources ................................................................................... 7-24

8-1 Map of the ERCOT ISO Service Area ............................................................................. 8-3

8-2 Peak Demand and Average Demand in the ERCOT Region 2010-2019 ....................... 8-9

8-3 ERCOT 2009 Load Duration Curve ............................................................................... 8-10

8-4 ERCOT 2006, 2007, 2008, 2009, and 2010 Peak Load Forecasts ............................... 8-11

8-5 ERCOT 2009 and 2010 Energy Demand Forecasts ..................................................... 8-12

8-6 Population in the ERCOT Region .................................................................................. 8-13

8-7 Total Non-Farm Employment in the ERCOT Region ..................................................... 8-14

8-8 Per Capita Income in the ERCOT Region ..................................................................... 8-14

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

Capacity ......................................................................................................................... 8-21

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

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

9-1 Candidate Areas ............................................................................................................ 9-35 

9-2 Potential Sites ................................................................................................................ 9-38

9-3 Screening Criteria Evaluation Results ........................................................................... 9-39

9-4 Primary Sites ................................................................................................................. 9-40

9-5 Red 2 Alternative Site and 10-mi Radius ....................................................................... 9-48

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

the Red 2 Site in Grayson and Fannin Counties ........................................................... 9-60

9-7 Block Groups with Minority Populations Meeting Environmental Justice Selection 

Critera within 50 mi of the Red 2 Alternative Site .......................................................... 9-85

9-8 Block Groups with Low-Income Populations Meeting Environmental Justice 

Selection Criteria Within 50 mi of the Red 2 Alternative Site ......................................... 9-86

9-9 Allens Creek Alternative Site and 10-mi Radius ............................................................ 9-99

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

Within the Western Gulf Coast Plains Ecoregion in the Lower Brazos and San 

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

Counties ...................................................................................................................... 9-109
NUREG-1937 xxii February 2011 

9-11 Block Groups with Minority Populations Meeting Environmental Justice Selection 

Criteria Within 50 mi of the Allens Creek Alternative Site ............................................ 9-137

9-12 Block Groups with Low-Income Populations Meeting Enviornmental Justice 

Selection Criteria Within 50 mi of the Allens Creek Alternative Site ............................ 9-138

9-13 Trinity 2 Alternative Site and 10-mi Radius .................................................................. 9-154

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

the Trinity 2 Site in Freestone County ......................................................................... 9-165

9-15 Block Groups With Minority Populations Meeting Environmental Justice Selection 

Criteria Within 50 mi of the Trinity 2 Alternative Site ................................................... 9-192

9-16 Block Groups With Low-Income Popualtions Meeting Environmental Justice 

Selection Criteria Within 50 mi of the Trinity 2 Alternative Site .................................... 9-193
February 2011 xxiii NUREG-1937 

Tables 

2-1 Land Use at the STP Site ................................................................................................ 2-7

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

Hydrogeologic Strata ..................................................................................................... 2-31

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

Strata ............................................................................................................................. 2-32

2-4 Groundwater Resource Estimates for Matagorda County ............................................. 2-39

2-5 Maximum Tritium Concentration in Water Bodies Near the STP Site ........................... 2-46

2-6 Approximate Acreages of Habitats and Land Use Found on the STP Site ................... 2-51

2-7 Amphibians Found in Matagorda County, Texas ........................................................... 2-53

2-8 Birds Observed On or Around the STP Project Area for Units 3 and 4 ......................... 2-55

2-9 Federally Listed Terrestrial Species Identified by FWS as Occurring in the Vicinity 

of the STP Site and the STP-to-Hillje Transmission Corridor ........................................ 2-57

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

Site and the STP-to-Hillje Transmission Corridor .......................................................... 2-61

2-11 Fish and Shellfish Collected in the MCR by Gear Type, 2007-2008 ............................. 2-73

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

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

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

Units 1 and 2, 2007-2008 .............................................................................................. 2-75

2-14 Fish and Shellfish Collected in the Colorado River by Gear Type, 2007-2008 .............. 2-83

2-15 Important Aquatic Species that May Occur in the Vicinity of STP Site .......................... 2-89

2-16 Distribution of STP Employees, January 2007 ............................................................ 2-110

2-17 Counties within 50 mi of the STP Site ......................................................................... 2-111

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

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

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

Surrounding the STP Site, 2006 .................................................................................. 2-116

2-21 Minority and Low-Income Populations ......................................................................... 2-118

2-22 Employment by Industry, 2006 .................................................................................... 2-119

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

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

Jackson Counties ........................................................................................................ 2-122

2-25 Matagorda County Property Tax Information, 2000-2005 ........................................... 2-124

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

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

2000-2005 ................................................................................................................... 2-126

2-28 Roadway Use Statistics for Most Likely Routes to the STP Site ................................. 2-130

2-29 Wildlife Management Areas and Parks Within 50 mi of the STP Site .......................... 2-131
NUREG-1937 xxiv February 2011 

2-30 Regional Housing Information by County for the Year 2000 ....................................... 2-133

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

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

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

Systems in Brazoria, Calhoun, Jackson, and Matagorda Counties ............................. 2-137

2-33 Law Enforcement Personnel 2005 ............................................................................... 2-139

2-34 Fire Protection Personnel ............................................................................................ 2-140

2-35 Hospital Data for Brazoria, Calhoun, Jackson and Matagorda Counties ..................... 2-142

2-36 United Way Agencies of Matagorda County ................................................................ 2-144

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

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

2-38 Private School Statistics in the Four-County Socioeconomic Impact Area, 2005-

2006 ............................................................................................................................. 2-146

2-39 Atmospheric Dispersion Factors for Proposed Units 3 and 4 Design Basis 

Accident Calculations .................................................................................................. 2-166

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

Evaluation of Normal Effluents for Receptors of Interest ............................................. 2-167

2-41 Construction Noise Sources and Attenuation with Distance ........................................ 2-171

3-1 Descriptions and Examples of Activities Associated with Building Units 3 and 4 .......... 3-14

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

and 4 .............................................................................................................................. 3-18

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

3-4 Summary of Resource Commitments Associated with Operation of Proposed STP 

Units 3 and 4.................................................................................................................. 3-25

4-1 Drawdown in Feet at the STP Property Line (100 ft) and a Point 2500 ft from a 

Production Well .............................................................................................................. 4-10

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

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

Units 3 and 4, Months 26-35 .......................................................................................... 4-47

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

Site for a Single ABWR.................................................................................................. 4-71

4-5 Direct Radiation Doses to Unit 4 Construction Workers ................................................ 4-73

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

Impacts During Construction of Proposed Units 3 and 4 ............................................... 4-79

4-7 Summary of Construction and Preconstruction Impacts for Proposed Units 3 and 4 .... 4-85

5-1 Summary Statistics of Simulated Colorado River Streamflow Below the RMPF ........... 5-10

5-2 Drawdown at the STP Property Line (100 ft) and a Point 2500 ft from a Production 

Well ................................................................................................................................ 5-13

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

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

5-4 Potential Increase in Resident Population Resulting from Operating Units 3 and 4 ...... 5-52
February 2011 xxv NUREG-1937 

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

Special Districts ............................................................................................................. 5-56

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

3 and 4 ........................................................................................................................... 5-67

5-7 MCR Fog Impact Analysis ............................................................................................. 5-69

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

from the STP Site .......................................................................................................... 5-78

5-9 Annual Doses to the MEI for Liquid Effluent Releases from a New Unit ....................... 5-84

5-10 Annual Doses to MEI for Gaseous Effluent Releases from a New Unit ........................ 5-85

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

Appendix I Design Objectives ........................................................................................ 5-86

5-12 Comparison of MEI Annual Doses with 40 CFR Part 190 Standards – (mrem/yr) ........ 5-87

5-13 Biota Doses for Proposed Units 3 and 4 ........................................................................ 5-90

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

Relevant Guidelines for Biota Protection ....................................................................... 5-91

5-15 Atmospheric Dispersion Factors for STP Site DBA Calculations .................................. 5-99

5-16 Design Basis Accident Doses for an ABWR .................................................................. 5-99

5-17 Mean Environmental Risks from ABWR Reactor Severe Accidents at the STP Site .. 5-103

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

Risks for Current-Generation Reactors at Five Sites Evaluated in NUREG-1150 ....... 5-104

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

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

Events for Current Plants Undergoing Operating License Renewal Review and 

Environmental Risks of the ABWR Reactor at Other Sites .......................................... 5-105

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

Operation ..................................................................................................................... 5-114

5-21 Summary of Operational Impacts at the Proposed Units 3 and 4 Site ........................ 5-118

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

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

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

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

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

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

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

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

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

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

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

Sites to the Proposed Geologic Repository at Yucca Mountain, Nevada ...................... 6-27

6-8 RADTRAN 5.6 Normal (Incident-free) Exposure Parameters ........................................ 6-28
NUREG-1937 xxvi February 2011 

6-9 Normal (Incident-Free) Radiation Doses to Transport Workers and the Public from 

Shipping Spent Fuel from the STP Site and Alternative Sites to the Proposed 

Geologic HLW Repository at Yucca Mountain ............................................................... 6-30

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

ABWR ............................................................................................................................ 6-33

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

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

Generation ..................................................................................................................... 6-35

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

Alternative Sites to the Proposed Geologic HLW Repository at Yucca Mountain, 

Nevada, Normalized to Reference LWR ........................................................................ 6-36

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

Sites ............................................................................................................................... 6-37

6-14 Nonradiological Impacts of Radioactive Waste Shipments from the STP Site .............. 6-38

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

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

7-2 Comparison of Annual Carbon Dioxide Emission Rates ............................................... 7-46

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

Proposed Units 3 and 4 ................................................................................................. 7-56

8-1 ERCOT Peak Demand and Calculated Reserve Margin, 2010-2015 ............................ 8-17

8-2 Calculated ERCOT Reserve Margin, 2009-2025 ........................................................... 8-18

8-3 ERCOT Region Forecasted Summer Resources, 2010-2025 ....................................... 8-22

8-4 STPNOC Forecasted Summer Capacity, Baseload Generation Units Only .................. 8-25

8-5 Review Team Sensitivity Test, ERCOT Region Forecasted Summer Resources, 

2010-2025 ..................................................................................................................... 8-28

8-6 ERCOT/Review Team Forecasted Summer Capacity, Baseload Generation Units 

Only ............................................................................................................................... 8-29

8-7 ERCOT/Review Team Forecasted Unmet Need for Baseload Generation 

Compared with STPNOC Estimated Need for Baseload Power .................................... 8-32

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

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

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

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

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

of Alternatives ................................................................................................................ 9-31

9-5 Comparison of Direct Carbon Dioxide Emissions for Energy Alternatives .................... 9-32

9-6 Criteria for Selection of Candidate Sites ........................................................................ 9-41

9-7 Composite Ratings for the Primary Sites ....................................................................... 9-42

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

Considered in the Cumulative Analysis of the Red 2 Alternative Site ........................... 9-46
February 2011 xxvii NUREG-1937 

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

Site. ............................................................................................................................... 9-61

9-10 Federally and State-listed Threatened and Endangered Species in Fannin County, 

Texas ............................................................................................................................. 9-63

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

Concern for Fannin County............................................................................................ 9-73

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

Considered in the Allens Creek Alternative Site Cumulative Analysis ........................... 9-96

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

800-ac Allens Creek Site. ............................................................................................ 9-110

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

Bend, Colorado, and Wharton Counties, Texas .......................................................... 9-112

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

and Species of Concern for Austin County .................................................................. 9-125

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

Considered in the Cumulative Analysis of the Trinity 2 Alternative Site. ..................... 9-149

9-17 Estimated Land Cover Classes for Approximately 2000 ac of the 2500-ac Trinity 2 

Site. ............................................................................................................................. 9-166

9-18 Federally and State-listed Threatened and Endangered Species in Freestone 

County, Texas.............................................................................................................. 9-168

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

and Species of Concern for Freestone County ............................................................ 9-179

9-20 Comparison of Cumulative Impacts at the Proposed and Alternative Sites ................ 9-204

10-1 Unavoidable Adverse Environmental Impacts from Construction and 

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

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

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

10-4 Summary of Costs of Preconstruction, Construction, and Operation .......................... 10-22

February 2011 xxix NUREG-1937 

Executive Summary 

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

Commission) received an application from STP Nuclear Operating Company (STPNOC) for 

combined construction permits and operating licenses (combined licenses or COLs) for South 

Texas Project Electric Generating Station (STP) Units 3 and 4, located in Matagorda County, 

Texas. The review team’s evaluation is based on the October 2010 revision to the application, 

responses to requests for additional information, and supplemental letters. 

The proposed actions related to the STP Units 3 and 4 application are (1) NRC issuance of 

COLs for construction and operation of two new nuclear units at the STP site, and (2) U.S. Army 

Corps of Engineers (Corps) issuance of a permit pursuant to Section 404 of the Federal Water 

Pollution Control Act (Clean Water Act) and Section 10 of the Rivers and Harbors Act to perform 

certain construction activities on the site. The Corps is participating with the NRC in preparing 

this environmental impact statement (EIS) as a cooperating agency and participates 

collaboratively on the review team. The reactor specified in the application is the certified U.S. 

Advanced Boiling Water Reactor design, as modified by a proposed amendment to the ABWR 

design certification that is being sought by STPNOC to address the requirements of 10 CFR 

50.150 on the ability of the design to withstand the impact of a large commercial aircraft 

(U.S. ABWR, hereafter referred to as ABWR in this EIS). 

Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA) 

(42 USC 4321 et seq.) directs that an EIS be prepared for major Federal actions that 

significantly affect the quality of the human environment. The NRC has implemented 

Section 102 of NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. Further, in 

10 CFR 51.20, the NRC has determined that the issuance of a COL under 10 CFR Part 52 is an 

action that requires an EIS. 

The purpose of STPNOC’s requested NRC action—issuance of the COLs—is to obtain licenses 

to construct and operate two new nuclear units. These licenses are necessary but not sufficient 

for construction and operation of the units. A COL applicant must obtain and maintain the 

necessary permits from other Federal, State, Tribal, and local agencies and permitting 

authorities. Therefore, the purpose of the NRC’s environmental review of the STPNOC 

application is to determine if two new nuclear units of the proposed design can be constructed 

and operated at the STP site without unacceptable adverse impacts on the human environment. 

The purpose of STPNOC’s requested Corps action is to obtain a permit to perform regulated 

activities that would impact waters of the United States. 

Upon acceptance of the STPNOC application, the NRC began the environmental review 

process described in 10 CFR Part 51 by publishing in the Federal Register a Notice of Intent 
NUREG-1937 xxx February 2011 

(72 FR 72774) to prepare an EIS and conduct scoping. On February 5, 2008, the NRC held two 

scoping meetings in Bay City, Texas, to obtain public input on the scope of the environmental 

review. The staff reviewed the comments received during the scoping process and contacted 

Federal, State, Tribal, regional, and local agencies to solicit comments. 

To gather information and to become familiar with the sites and their environs, the NRC and its 

contractor Pacific Northwest National Laboratory (PNNL) visited the STP site in February 2008 

and the Allens Creeks alternative site in March 2008. In August 2009, the NRC and PNNL 

visited the Red 2 and Trinity 2 alternative sites. During the site visits, the NRC staff and its 

contractors met with STPNOC staff, public officials, and the public. 

Included in this EIS are (1) the results of the review team’s analyses, which consider and weigh 

the environmental effects of the proposed actions; (2) potential mitigation measures for reducing 

or avoiding adverse effects; (3) the environmental impacts of alternatives to the proposed 

action; and (4) the NRC staff’s recommendation regarding the proposed action. 

To guide its assessment of the environmental impacts of a proposed action or alternative 

actions, the NRC has established a standard of significance for impacts based on Council on 

Environmental Quality guidance (40 CFR 1508.27). Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B, provides the following definitions of the three significance levels – SMALL, 

MODERATE, and LARGE: 

SMALL – Environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the resource. 

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

destabilize, important attributes of the resource. 

LARGE – Environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource. 

In preparing this EIS, the review team reviewed the application, including the Environmental 

Report (ER) submitted by STPNOC; consulted with Federal, State, Tribal, and local agencies; 

and followed the guidance set forth in NUREG-1555, Environmental Standard Review Plan and 

Staff Memorandum on Addressing Construction and Preconstruction, Greenhouse Gas Issues, 

General Conformity Determinations, Environmental Justice, Need for Power, Cumulative Impact 

Analysis, and Cultural/Historical Resources Analysis Issues in Environmental Impact 

Statements. In addition, the NRC staff considered the public comments related to the 

environmental review received during the scoping process. Comments within the scope of the 

environmental review are included in Appendix D of this EIS. 
February 2011 xxxi NUREG-1937 

A 75-day comment period began on March 26, 2010, when the U.S. Environmental Protection 

Agency (EPA) published a Notice of Availability of the draft EIS to allow members of the public 

and agencies to comment on the results of the environmental review. During this period, the 

NRC and Corps staff conducted two public meetings in Bay City, Texas, to describe the results 

of the environmental review, respond to questions, and accept public comment. All comments 

received on the draft EIS are included in Appendix E. 

The NRC staff’s recommendation to the Commission related to the environmental aspects of the 

proposed action is that the COLs be issued as requested. This recommendation is based on 

(1) the application, including the ER submitted by STPNOC; (2) consultation with other Federal, 

State, Tribal, and local agencies; (3) the staff’s independent review; (4) the staff’s consideration 

of public comments; and (5) the assessments summarized in this EIS, including the potential 

mitigation measures identified in the ER and this EIS. The Corps will issue its Record of 

Decision based, in part, on this EIS. 

The NRC staff’s evaluation of the site safety and emergency preparedness aspects of the 

proposed action will be addressed in the NRC’s Safety Evaluation Report, which is still being 

developed. 

February 2011 xxxiii NUREG-1937 

Abbreviations/Acronyms 

AADT Average Annual Daily Traffic 

ABWR U.S. Advanced Boiling Water Reactor 

ac acre(s) 

ac-ft/yr acre-feet per year 

ACHP Advisory Council on Historic Preservation 

ADAMS Agencywide Documents Access and Management System 

AEC U.S. Atomic Energy Commission 

AEP American Electric Power 

AEP Archaeology and Ethnography Program 

AIA Aircraft Impact Assessment 

APE area of potential effect 

ALARA as low as is reasonably achievable 

ARRA American Recovery and Reinvestment Act of 2009 

ASLB Atomic Safety and Licensing Board 

BACT best available control technology 

BEA Bureau of Economic Analysis 

BEIR Biological Effects of Ionizing Radiation 

BGCD Bluebonnet Groundwater Conservation District 

BGS below ground surface 

BMP best management practice 

Btu British thermal unit(s) 

Bq Becquerel(s) 

BRA Brazos River Authority 

BWR boiling water reactor 

°C degree(s) Celsius 

CAES compressed air energy storage 

CBC Christmas Bird Count 

CCD Census County Division 

CDC Centers for Disease Control and Prevention 

CDF core damage frequency 

CDR Capacity, Demand, and Reserves Report 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

cfs cubic feet per second 

Ci curie(s) 

cm centimeter(s) 
NUREG-1937 xxxiv February 2011 

CMP Coastal Management Program 

CMZ Coastal Management Zone 

CNP CenterPoint Energy 

CO carbon monoxide 

CO2 carbon dioxide 

COL combined license 

CORMIX Cornell Mixing Zone Expert System 

Corps U.S. Army Corps of Engineers 

CPGCD Coastal Plains Groundwater Conservation District 

CPS Energy City Public Service Board of San Antonio, Texas 

CPUE catch per unit effort 

CR County Road (CR 360, CR 392) 

CREZ Competitive Renewable Energy Zones 

CWA Clean Water Act 

CWIS circulating water intake structure 

CWS circulating water system 

CZMA Coastal Zone Management Act 

DBA Design Basis Accident 

dBA decibel(s) (acoustic) 

DC design certification 

DCD Design Control Document 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

DSM demand side management 

D/Q deposition values 

DWS drinking water standards 

EA Environmental Assessment 

EAB Exclusion Area Boundary 

ECP Essential Cooling Pond 

EIA Energy Information Administration 

EIS environmental impact statement 

EFH essential fish habitat 

ELF extremely low frequency 

ELCC effective load carrying capability 

EMF electromagnetic field 

EOF Emergency Operations Facility 

EPA U.S. Environmental Protection Agency 

ER Environmental Report 

ERCOT Electric Reliability Council of Texas 
February 2011 xxxv NUREG-1937 

ESA Endangered Species Act of 1973, as amended 

ESRP Environmental Standard Review Plan 

°F degree(s) Fahrenheit 

FAA Federal Aviation Administration 

FDA final design approval 

FERC Federal Energy Regulatory Commission 

FES Final Environmental Statement 

FM Farm-to-Market 

FMP Fishery Management Plan 

fps feet per second 

FR Federal Register 

FSAR Final Safety Analysis Report 

FSC Federal Species of Concern 

FSER Final Safety Evaluation Report 

ft foot or feet 

ft2 square feet 

ft3

 cubic feet 

FWS U.S. Fish and Wildlife Service 

GBq gigabecquerel 

GCC global climate change 

GCRP U.S. Global Change Research Program 

GE General Electric 

GEIS generic environmental impact statement 

GHG greenhouse gases 

GIT Georgia Institute of Technology 

GIWW Gulf Intracoastal Waterway 

gpd gallon(s) per day 

gpm gallon(s) per minute 

GWMS gaseous waste-management system 

ha hectare(s) 

HAPC habitat areas of particular concern 

hr hour(s) 

Hg mercury 

HLW high-level waste 

Hz hertz 

IAEA International Atomic Energy Agency 

ICRP International Commission on Radiological Protection 
NUREG-1937 xxxvi February 2011 

IGCC integrated gasification combined cycle 

in. inch 

INEEL Idaho National Engineering and Environmental Laboratory 

IOU investor owned utility 

ISD Independent School District 

ISO independent system operator 

I&S interest and sinking fund 

 

km kilometer(s) 

km2

 square kilometer(s) 

kWh kilowatt-hour(s) 

kV kilovolt(s) 

L liter(s) 

lb pound(s) 

LCRA Lower Colorado River Authority 

LCRWPG Lower Colorado Regional Water Planning Group 

LEDPA least environmentally damaging practicable alternative 

LERF large early release frequency 

LLW low-level waste 

LNG liquefied natural gas 

LOS level of service 

LPZ Low Population Zone 

LRF large release frequency 

LST local standard time 

LSWP LCRA-SAWS Water Project 

LTDEF long-term demand energy forecast 

LTSF Long-Term Storage Facility 

LWA Limited Work Authorization 

LWMS liquid waste management system 

LWR light water reactor 

m meter(s) 

m3

 cubic meter(s) 

MACCS2 MELCOR Accident Consequence Code System Version 2 

MBq megabecquerel(s) 

MCEDC Matagorda County Economic Development Corporation 

MCEMO Matagorda County Emergency Management Office 

MCPE market clearing prices of energy 

MCR Main Cooling Reservoir 

MDC Main Drainage Channel 
February 2011 xxxvii NUREG-1937 

MEI maximally exposed individual 

METGCD Mid-East Texas Groundwater Conservation District 

mg milligram(s) 

MGD million gallons per day 

mg/L milligram(s) per liter 

mi mile(s) 

mi2

 square mile(s) 

MIT Massachusetts Institute of Technology 

mL milliliter(s) 

MMS Minerals Management Service 

mo month 

MOU Memorandum of Understanding 

M&O maintenance and operations 

mph mile(s) per hour 

mR milliroentgen 

mrad millirad(s) 

mrem millirem(s) 

μS microsiemens 

MSA Metropolitan Statistical Area 

MSL mean sea level 

mSv millisievert(s) 

MT metric ton(s) (or tonne[s]) 

MTU metric ton(s) of uranium 

MUD municipal utilities district 

MW megawatt(s) 

MWd megawatt-day(s) 

MW(e) megawatt(s) electrical 

MW(t) megawatt(s) thermal 

NCI National Cancer Institute 

NCRP National Council on Radiation Protection & Measurements 

NEI Nuclear Energy Institute 

NEPA National Environmental Policy Act of 1969, as amended 

NERC North American Electric Reliability Corporation 

NESC National Electric Safety Code 

NHPA National Historic Preservation Act of 1966, as amended 

NIEHS National Institute of Environmental Health Sciences 

NINA Nuclear Innovation North America 

NMFS National Marine Fisheries Services 

NMM navigation mile marker 

NOAA National Oceanic and Atmospheric Administration 
NUREG-1937 xxxviii February 2011 

NOx nitrogen oxide 

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service 

NRC U.S. Nuclear Regulatory Commission 

NRG NRG South Texas LP 

NRHP National Register of Historic Places 

NSR new source review 

NTF Nuclear Training Facility 

OCS outer continental shelf 

ODCM offsite dose calculation manual 

OSF Onsite Staging Facility 

OSGSF Old Steam Generator Storage Facility 

OSHA Occupational Safety and Health Administration 

OW observation well 

PAM primary amoebic meningoencephalitis 

pCi picocuries 

pCi/L picocuries per liter 

PGC Power Generation Company 

PIR Public Interest Review 

PM particulate matter 

PM2.5 particulate matter with a diameter of 2.5 microns or less 

PM10 particulate matter with a diameter of 10 microns or less 

PNNL Pacific Northwest National Laboratory 

POSGCD Post Oak Savannah Groundwater Conservation District 

ppt parts per thousand 

PSD prevention of significant deterioration 

PUCT Public Utility Commission of Texas 

PWR pressurized water reactors 

RAI request for additional information 

RCRA Resource Conservation and Recovery Act of 1976, as amended 

RCRWPG Region C Regional Water Planning Group 

RCW Reactor Building Cooling Water 

RE refueling 

rem roentgen equivalent man (a special unit of radiation dose) 

REMP radiological environmental monitoring program 

RIMS Regional Input-Output Model System 

RMPF Reservoir Makeup Pumping Facility 

RMR reliability must run 

ROD Record of Decision 
February 2011 xxxix NUREG-1937 

ROI region of interest 

ROW right of way 

RRGCD Red River Groundwater Conservation District 

RSICC Radiation Safety Information Computational Center 

RSW Reactor Service Water 

RV recreational vehicle 

Ryr reactor-year 

s second(s) 

SACTI Seasonal and Annual Cooling Tower Impacts 

SAMA severe accident mitigation alternatives 

SAMDA severe accident mitigation design alternatives 

SAWS San Antonio Water System 

SCR selective catalytic reduction 

SECPOP 2000 Sector Population, Land Fraction, and Economic Estimation Program 

SER Safety Evaluation Report 

SGIA signed generation interconnection agreement 

SHPO State Historic Preservation Officer 

SO2 sulphur dioxide 

SOx sulphur oxide 

STP South Texas Project Electric Generating Station 

STPEGS STP Electric Generating Station 

STPNOC STP Nuclear Operating Company 

SUV sport utility vehicle 

Sv sievert 

SWMS solid waste management system 

SWPPP Stormwater Pollution Prevention Plan 

TAC Texas Administrative Code 

TAMUG Texas A&M University at Galveston 

TBEG Texas Bureau of Economic Geology 

TBq terabecquerel(s) 

TCC Texas Central Company 

TCEQ Texas Commission on Environmental Quality 

TCMP Texas Coastal Management Plan 

TDCJ Texas Department of Criminal Justice 

TDHCA Texas Department of Housing and Community Affairs 

TDS total dissolved solids 

TDSHS Texas Department of State Health Services 

TEA Texas Education Agency 

TEDE total effective dose equivalent 
NUREG-1937 xl February 2011 

Texas RE Texas Reliability Entity 

THC Texas Historical Commission 

TIS Texas Interconnected System 

TLD thermoluminescent dosimeter 

TMDL total maximum daily load 

TPDES Texas Pollutant Discharge Elimination System 

TPWD Texas Parks and Wildlife Department 

TPWP Texas Prairie Wetlands Project 

TRAGIS Transportation Routing Analysis Geographic Information System 

TRC Texas Railroad Commission 

TSECO Texas State Energy Conservation Office 

TSHA Texas State Historical Association 

TWC Texas Water Code 

TWDB Texas Water Development Board 

TX Texas 

TxDOT Texas Department of Transportation 

U3O8 triuranium octaoxide (“yellowcake”) 

UF6 uranium hexafluoride 

UFSAR Updated Final Safety Analysis Report 

UHS Ultimate Heat Sink 

UMTRI University of Michigan Transportation Research Institute 

UO2 uranium oxide 

USACE U.S. Army Corps of Engineers 

USC United States Code 

USCB U.S. Census Bureau 

USGS U.S. Geological Survey 

VOC volatile organic compound 

WCS Waste Control Specialists, LLC 

WHO World Health Organization 

WMA Wildlife Management Area 

WSEC White Stallion Energy Center 

WSWTS West Sanitary Waste Treatment System 

WCID Water Control and Improvement District 

χ/Q atmospheric dispersion values 

yd yard(s) 

yd3

 cubic yard(s) 

yr year(s) 
Appendix A 

Contributors to the Environmental Impact Statement 

February 2011 A-1 NUREG-1937 

Appendix A 

Contributors to the Environmental Impact Statement 

The overall responsibility for the preparation of this environmental impact statement (EIS) was 

assigned to the Office of New Reactors, U.S. Nuclear Regulatory Commission (NRC). The EIS 

was prepared by members of the Office of New Reactors with assistance from other NRC 

organizations, the U.S. Army Corps of Engineers, Pacific Northwest National Laboratory, and 

Idaho National Laboratory. 

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 

Mohammad Haque Office of New Reactors Hydrology 

Richard Raione Office of New Reactors Branch Chief 

Laurel Bauer Office of New Reactors Geology 

Michael Masnik Office of New Reactors Aquatic Ecology, System Design, Hydrology 

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(a) 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 

NUREG-1937 A-2 February 2011 

Name Affiliation Function or Expertise

Robert Kellner(a) Office of New Reactors Health Physics and Radiation Protection 

(Occupational) 

Stephen Williams Office of New Reactors Health Physics and Radiation Protection 

(Effluent/Public) 

Edward Stutzcage Office of New Reactors Health Physics and Radiation Protection 

(Occupational) 

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(c) Task Leader 

George Last Task Leader 

Beverly Miller Deputy Task Leader 

James Becker Deputy Task Leader 

Terri Miley Comment-Response Support, Interim 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 

Cheegwan Lee Hydrology 

Robert Bryce Alternative System Design 

Janelle Downs Terrestrial Ecology 

Mary Ann Simmons Terrestrial Ecology, Alternative Sites 

Amoret Bunn Aquatic Ecology, Nonradiological Health 

Michael Scott Socioeconomics, Environmental Justice, Need for 

Power, Benefit Cost, Noise 

Michelle Niemeyer Socioeconomics, Environmental Justice 

Dave Anderson Socioeconomics, Environmental Justice, 

Darby Stapp(c) Historic and Cultural Resources 

Tara O’Neil Historic and Cultural Resources 

Ernest Antonio Radiation Protection, Nonradiological Health 

Bruce Napier Health Physics and Radiation Protection 

Van Ramsdell Meteorology and Air Quality, Accidents 

Bruce McDowell Cumulative Impacts 

Phil Daling Transportation 

David Payson Technical Editing 

Denice Carrothers Technical Editing 
Appendix A 

February 2011 A-3 NUREG-1937 

Name Affiliation Function or Expertise

Michael Parker Text Processing 

Christine Ross Text Processing 

Tim Seiple GIS 

Erin Hamilton GIS 

Duane Ward GIS 

Donna Austin-Workman Graphics 

Tomiann Parker Reference Coordinator 

Meredith Willingham References 

IDAHO NATIONAL LABORATORY(d)

Brenda Pace Historic and Cultural Resources 

(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. 

(d) Idaho National Laboratory is operated by Battelle Energy Alliance for the U.S. Department of Energy. 

Appendix B 

Organizations Contacted 

February 2011 B-1 NUREG-1937 

Appendix B 

Organizations Contacted 

The following Federal, State, regional, Tribal, and local organizations were contacted during the 

course of the U.S. Nuclear Regulatory Commission staff’s independent review of potential 

environmental impacts from the construction and operation of two new nuclear units, Units 3 

and 4, at the South Texas Project Electric Generating Station in Matagorda County, Texas: 

Advisory Council on Historic Preservation, Director Office of Federal Agency Programs, 

Washington, D.C. 

Alabama-Coushatta Tribe, Historical Preservation Department, Livingston, Texas 

Angleton Independent School District (ISD), Angleton, Texas 

Bay City Chamber of Commerce, Bay City, Texas 

Bay City Community Development Corporation, Bay City, Texas 

Bay City ISD, Bay City, Texas 

Bay City Ministerial Alliance, Bay City, Texas 

Bay City Salvation Army, Bay City, Texas 

Bell Valuation Services, Bay City, Texas 

Bluebonnet Groundwater Conservation District, Navasota, Texas 

Brazoria County Judge, Angleton, Texas 

Brazos River Authority, Waco, Texas 

Brazos Valley Groundwater Conservation District, Waco, Texas 

Calhoun County Judge, Port Lavaca, Texas 

City of Bay City, Mayor, Bay City, Texas 

City of Corpus Christi, Intergovernmental Relations 
Appendix B 

NUREG-1937 B-2 February 2011 

Coastal Plains Groundwater Conservation District, Bay City, Texas 

Columbia-Brazoria ISD, West Columbia, Texas 

Comanche Nation, Lawton, Oklahoma 

Electric Reliability Council of Texas 

Environmental Protection Agency, Regional Office, Dallas, Texas 

Frankson and Griffith, Certified Public Accountants, Bay City, Texas 

Greater Texoma Utility Authority, Bonham, Texas (now Red River Groundwater Conservation 

District) 

Guadalupe-Blanco River Authority, Seguin, Texas 

Jackson County, Edna, Texas 

Kiowa Tribe of Oklahoma, Carnegie, Oklahoma 

Matagorda County Museum Archives and Collections Department, Bay City, Texas 

Mid-East Texas Groundwater Conservation District, Centerville, Texas 

Lower Colorado River Authority, Austin, Texas 

National Marine Fisheries Service, Galveston Laboratory, Galveston, Texas 

National Marine Fisheries Service, Southeast Regional Office, St. Petersburg, Florida 

NRG Energy, Inc., Limestone Electric Generating Station, Jewett, Texas 

Palacios ISD, Palacios, Texas 

State of Texas, Office of the Governor, Austin, Texas 

St. Anthony of Padua Church, Palacios, Texas 

Tarrant Water District, Fort Worth, Texas 

Texas Commission on Environmental Quality, Austin, Texas 

Texas General Land Office, Coastal Coordination Council, Austin, Texas 
Appendix B 

February 2011 B-3 NUREG-1937 

Texas Historical Commission, Austin, Texas 

Texas Parks and Wildlife Department, Austin, Texas 

Texas State Historic Preservation Officer, Austin, Texas 

Texas State Soil and Water Conservation Board, Temple, Texas 

Texas Water Development Board, Austin, Texas 

Tidehaven ISD, El Maton, Texas 

Tonkawa Tribe of Oklahoma, Tonkawa, Oklahoma 

Trinity River Authority of Texas Southern Region, Huntsville, Texas 

Upper Neches River Municipal Water Authority, Palestine, Texas 

U.S. Army Corps of Engineers Galveston District, Galveston, Texas 

U.S. Army Corps of Engineers, Fort Worth, Texas 

U.S. Congressman Ron Paul’s Office, Galveston, Texas 

U.S. Environmental Protection Agency, Temple, Texas 

U.S. Fish and Wildlife Service, Ecological Services, Houston, Texas 

Van Vleck ISD, Van Vleck, Texas 

Appendix C 

NRC and Corps Environmental Review 

Correspondence 

February 2011 C-1 NUREG-1937 

Appendix C 

NRC and Corps Environmental Review 

Correspondence 

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) or the U.S. Army Corps of Engineers (Corps) and STP Nuclear 

Operating Company (STPNOC). Also included is other correspondence related to the 

environmental review of STPNOC’s application for combined licenses (COLs) and a Corps 

permit at the South Texas Project Electric Generating Station (STP) site in Matagorda County, 

Texas. 

All documents, with the exception of those containing proprietary information, are available 

electronically from the Public Electronic Reading Room found on the Internet at the following 

web address: http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to 

the NRC’s Agencywide Documents Access and Management System (ADAMS), which provides 

text and image files of the NRC's public documents. The ADAMS accession numbers for each 

document are included below. 

October 16, 2007 Letter to Mr. Mark McBurnett, Vice President, STPNOC, from NRC, 

regarding Acknowledgement of Receipt of The Combined License 

Application for South Texas Project, Units 3 and 4, and Associated 

Federal Register Notice. (Accession No. ML072670515) 

November 8, 2007 Letter from Mr. Gregory T. Gibson, Manager, STPNOC, to NRC, 

regarding Environmental Report Acceptance Review: Outstanding 

Issues. (Accession No. ML073190645) 

November 16, 2007 Letter to Mr. Mark McBurnett, Vice President, STPNOC, from NRC, 

regarding Acceptance Review of The Combined License Application for 

South Texas Project (STP), Units 3 and 4. (Accession 

No. ML073200761) 

November 21, 2007 Letter from M.A. McBurnett, STPNOC, to NRC, regarding Supplement 

to Combined License Application. (Accession No. ML073310616) 

November 29, 2007 Letter to Mr. Mark McBurnett, STPNOC, from NRC, regarding the 

Docketing of The Combined License Application (COL) For South 

Texas Project (STP), Units 3 and 4. (Accession No. ML073320290) 
Appendix C 

NUREG-1937 C-2 February 2011 

December 5, 2007 Letter from Mr. Gregory T. Gibson, STPNOC to NRC, Resubmitted 

Aquatic Ecology Monitoring: Six-Month Interim Report. (Accession 

No. ML073410357) 

December 11, 2007 Letter to Mr. Mark McBurnett, STPNOC, from NRC, regarding the 

Notice of Intent to Prepare an Environmental Impact Statement and 

Conduct Scoping Related to Combined Licenses for the South Texas 

Project Sites, Units 3 and 4. (Accession No. ML073400695) 

December 19, 2007 Letter to Mr. Mark McBurnett, STPNOC, from NRC, regarding Federal 

Register Notice Regarding Opportunity to Petition for Leave to Intervene 

- South Texas Project Units 3 and 4. (Accession No. ML073390202) 

December 21, 2007 Letter to Ms. Martha Johnson, Bay City Public Library, from NRC staff, 

regarding the Maintenance of Documents at The Bay City Public Library 

Related to Application by STP Nuclear Operating Company For 

Combined Licenses for The South Texas Project Site, Units 3 and 4. 

(Accession No. ML073480284) 

January 13, 2008 Email from Mr. Paul Kallan, NRC, to Mr. Greg Gibson, STPNOC, Site 

Audit Schedule and Preliminary Needs for Site Audit. (Accession No. 

ML082400729) 

January 18, 2008 Notice of Public Meeting to Discuss Environmental Scoping Process for 

the South Texas Project Site, Units 3 & 4 Combined Licenses (TAC NO. 

RA2764). (Accession No. ML080020250) 

January 25, 2008 Letter to Mr. David Bernhart, Assistant Regional Administrator, National 

Marine Fisheries Service, from NRC staff, regarding Application for The 

South Texas Project Site, Units 3 and 4 Combined Licenses. 

(Accession No. ML080020174) 

January 25, 2008 Letter to Alabama-Coushatta Tribe, Historical Preservation Department, 

from NRC staff, regarding Application for The South Texas Project Site, 

Units 3 and 4 Combined Licenses. (Accession No. ML080090115) 

January 25, 2008 Letter to Mr. Billy Evans Horse, Chairman of the Kiowa Tribe, Kiowa 

Tribe of Oklahoma, from NRC staff, regarding Application for The South 

Texas Project Site, Units 3 and 4 Combined Licenses. (Accession No. 

ML073620378) 
Appendix C 

February 2011 C-3 NUREG-1937 

January 25, 2008 Letter to Ms. Ruth Toahty, NAGPRA Coordinator, Comanche Nation 

NAGPRA and Historic Preservation Program, Comanche National 

Museum, from NRC staff, regarding Application for The South Texas 

Project Site, Units 3 and 4 Combined Licenses. (Accession 

No. ML073620358) 

January 25, 2008 Letter to Mr. Anthony E. Street, Tribal President, Tonkawa Tribe of 

Oklahoma, from NRC staff, regarding Application for The South Texas 

Project Site, Units 3 and 4 Combined Licenses. (Accession 

No. ML080090198) 

January 25, 2008 Letter to Mr. Don Klima, Director Office of Federal Agency Programs, 

Advisory Council on Historic Preservation, from NRC staff, regarding 

Application for The South Texas Project Site, Units 3 and 4 Combined 

Licenses. (Accession No. ML080100669) 

January 25, 2008 Letter to Mr. Lawrence Oaks, Executive Director of the Texas SHPO, 

State Historic Preservation Officer, from NRC staff, regarding 

Application for The South Texas Project Site, Units 3 and 4 Combined 

Licenses. (Accession No. ML080110216) 

January 25, 2008 Letter to Ms. Moni Belton, Fish and Wildlife Biologist, U.S. Fish and 

Wildlife Service Ecological Services, from Mr. William Burton, NRC, 

regarding Application for The South Texas Project Site, Units 3 and 4 

Combined Licenses. (Accession No. ML080090170) 

January 31, 2008 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Submittal of 

Combined License Application Revision 1. (Accession 

No. ML080700399) 

February 28, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC staff, Reponses to 

Environmental Report Site Audit Comments. (Accession 

No. ML080660150) 

February 08, 2008 Site Audit Summary Report. (Accession No. ML081010440) 

February 13, 2008 Notice Withdrawing Hearing Notice Regarding the Application for a 

Combined Operating License for South Texas Project Units 3 and 4. 

(Accession No. ML080450208) 
Appendix C 

NUREG-1937 C-4 February 2011 

April 4, 2008 Letter to Ms. Kathy Boydston, Habitat Assessment Program Manager, 

Texas Parks and Wildlife Department, from NRC staff, regarding 

Application for The South Texas Project Site, Units 3 and 4 Combined 

Licenses. (Accession No. ML080730469) 

April 10, 2008 Summary of Public Scoping Meetings to Support Review of the South 

Texas Plant Combined License Application (TAC NO. MD6691). 

(Accession No. ML081000171) 

May 19, 2008 Letter to Mr. William Burton, NRC, from Mr. Carter Smith, Texas Parks 

and Wildlife, Proposed application for combined licenses for South 

Texas Project, Units 3 and 4, Matagorda County. (Accession 

No. ML090330752) 

May 19, 2008 Letter to Mr. Gregory Gibson, STPNOC, from Mr. Paul Kallan, NRC, 

Request for Additional Information, Letter Number One Related to the 

Environmental Report for the South Texas Combined License 

Application. (Accession No. ML081360531) 

June 04, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Cultural or 

Historical Artifact Discovery During Construction. (Accession 

No. ML081610296) 

June 09, 2008 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Cultural or 

Historical Artifact Discovery During Construction. (Accession 

No. ML081640213) 

June 17, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Final Aquatic 

Ecology Report. (Accession No. ML081750196) 

July 02, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Response to 

Requests for Additional Information. (Accession No. ML081900569) 

July 07, 2008 Letter to Mr. Scott Flanders, NRC, from Mr. Fred Anthamatten, 

U.S. Army Corps of Engineers, Environmental Impact Statement for the 

South Texas Project Nuclear Operating Company’s Combined License 

Application. (Accession No. ML082140640) 

July 15, 2008 Letter from Mr. Greg Gibson, STPNOC, to NRC, Response to Requests 

for Additional Information. (Accession No. ML082040684) 
Appendix C 

February 2011 C-5 NUREG-1937 

July 30, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Response to 

Requests for Additional Information. (Accession No. ML082140629) 

August 27, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Response to 

Requests for Additional Information. (Accession No. ML082420332) 

August 29, 2008 Letter to Mr. Fred Anthamatten, U.S. Army Corps of Engineers, from Mr. 

Scott Flanders, NRC, Request to Cooperate with the Nuclear 

Regulatory Commission on the Environmental Impact Statement for the 

South Texas Project Nuclear Operating Company, Units 3 and 4 

Combined License Application. (Accession No. ML0823106192) 

September 04, 2008 Letter from Mr. Gregory Gibson, STPNOC, to NRC, Completion of NRC 

Commitment. (Accession No. ML082530234) 

September 26, 2008 Letter to Mr. Scott Head, STPNOC, from Mr. William Burton, NRC, 

Scoping Summary Report Related to the Environmental Scoping 

Process for the South Texas Project, Units 3 and 4 Combined License 

Application. (Accession No. ML082260471) 

September 24, 2008 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Submittal of 

Combined License Application Revision 2. (Accession 

No. ML082830938) 

November 18, 2008 Letter to Mr. Scott Head, STPNOC, from Mr. Paul Kallan, NRC, 

Request for Additional Information, Letter Number Two Related to the 

Environmental Report for the South Texas Combined License 

Application. (Accession No. ML083190269) 

January 14, 2009 Memorandum from Ms. Jessie Muir, NRC, to Mr. William Burton, NRC, 

Summary of Teleconferences Held with South Texas Nuclear Operating 

Company Regarding the Draft Requests for Additional Information. 

(Accession No. ML090030003) 

January 21, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Second Re-submittal of 

Response to Request for Additional Information. (Accession 

No. ML090270986) 

January 22, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

for Additional Information. (Accession No. ML090270720) 
Appendix C 

NUREG-1937 C-6 February 2011 

February 03, 2009 Letter from Mr. Scott Head, STPNOC, to Mr. Mark Fisher, TCEQ, 

Request for State Water Quality Certification of Federally Permitted 

Activity. (Accession No. ML ML090360530) 

February 10, 2009 Letter from Mr. George Wunder, NRC, to Mr. Mark McBurnett, 

STPNOC, South Texas Project Units 3 and 4 Combined License 

Application Review Schedule. (Accession No. ML083650198)

February 20, 2009 Federal Register Notice of Order, Hearing, and Opportunity to Petition 

for Leave to Intervene Docket Nos. 52-012 and 52-013. 74 FR 7934. 

(Accession No. ML083570595) 

February 26, 2009 Summary of the Second Site Audit Related to the Environmental 

Review of the Combined Operating License Application for South Texas 

Project Units 3 and 4. (Accession No. ML090350504) 

March 03, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Contracts for 

Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste. 

(Accession No. ML090640920) 

March 16, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Re-Submittal of 

Response to Requests for Additional Information. (Accession 

No. ML090860879) 

March 18, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Update to Aquatic 

Ecology Monitoring Report Data. (Accession No. ML090830503) 

April 07, 2009 Letter from Mr. Kenny Jaynes, U.S. Army Corps of Engineers, to Mr. 

Gregory Gibson, STPNOC, Jurisdictional Determination, 7,000-Acre 

Mass Cooling Reservoir (MCR), Wadsworth, Matagorda County, Texas. 

(Accession No. ML091050501) 

April 22, 2009 Letter to Mr. Scott Head, STPNOC, from Ms. Jessie Muir, NRC, 

Requests for Additional Information, Letter Number Three Related to 

the Environmental Report for the South Texas Combined License 

Application. (Accession No. ML090960303) 

May 13, 2009 U. S. Army Corps of Engineers to NRC, Preliminary Jurisdictional 

Determination Form. (Accession No. ML091390115) 
Appendix C 

February 2011 C-7 NUREG-1937 

May 14, 2009 Letter from Mr. Kenny Jaynes, U.S. Army Corps of Engineers, to 

Mr. Russell Kiesling, STPNOC, Preliminary Jurisdictional Determination, 

Wadsworth, Montgomery County, Texas. (Accession Nos. 

ML091350101; ML091390111) 

May 18, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

for Additional Information. (Accession No. ML091410061) 

June 04, 2009 Letter from Mr. Scott Head, STPNOC, to Mr. Jayson Hudson, U.S. Army 

Corps of Engineers, Permit Determination Request. (Accession No. 

ML092030309) 

June 29, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

for Additional Information. (Accession No. ML091830339) 

July 08, 2009 Letter from Mr. Casey Cutler, U.S. Army Corps of Engineers, to Mr. 

Scott Head, STPNOC. (Accession No. ML092030304) 

July 30, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Response to 

Request for Additional Information. (Accession No. ML092150963) 

August 10, 2009 Letter from Mr. Jayson Hudson, U.S. Army Corps of Engineers to Ms. 

Jessie Muir, NRC, Cooperating Agency Scoping Request for South 

Texas Project Electric Generating Station Units 3 and 4. (Accession 

No. ML092460137) 

August 14, 2009 Letter to Mr. Scott Head, STPNOC, from Ms. Jessie Muir, NRC, 

Request for Additional Information, Letter Number Four Related to the 

Environmental Report for the South Texas Combined License 

Application. (Accession No. ML091620673) 

September 14, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

for Additional Information. (Accession No. ML092580491) 

September 16, 2009 Letter from Mr. Mark McBurnett, STPNOC, to NRC, Submittal of 

Combined License Application Revision 3. (Accession No. 

ML092930393) 

September 22, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Second Re-submittal 

Response to Request for Additional Information. (Accession No. 

ML092710535) 
Appendix C 

NUREG-1937 C-8 February 2011 

September 28, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

for Additional Information. (Accession No. ML092740321) 

October 01, 2009 Letter from Jessie M. Muir, NRC, to Mr. Scott Head, STPNOC, Request 

for Additional Information related to Alternative Sites. (Accession No. 

ML092750384) 

October 15, 2009 Letter to Mrs. Moni Belton, USFWS, from Mr. Ryan Whited, NRC, 

Information Request Regarding Alternative Sites Related to the 

Combined Licenses Application for South Texas Project, Units 3 and 4. 

(Accession No. ML092580516) 

October 15, 2009 Letter to Mr. Carter Smith, Texas Parks and Wildlife Department, from 

Mr. Ryan Whited, NRC, Information Request Regarding Alternative 

Sites Related to the Combined Licenses Application for South Texas 

Project, Units 3 and 4. (Accession No. ML092580421) 

October 27, 2009 Letter from Mr. Scott Head, STPNOC, to NRC, Response to Request 

for Additional Information. (Accession No. ML093060175) 

October 28, 2009 Letter from STPNOC to USACE, Permit Determination Request. 

(Accession No. ML093210232) 

November 09, 2009 Site Audit Summary of South Texas Project Nuclear Operating 

Company’s Revised Alternative Sites Analysis. (Accession No. 

ML092870574) 

November 09, 2009 Forthcoming Teleconference with South Texas Project Nuclear 

Operating Company to Discuss Responses to Request for Additional 

Information Related to Alternative Sites for the South Texas Project 

Units 3 and 4 Environmental Reviews. (Accession No. ML093130330 

November 10, 2009 Letter from Jayson Hudson, US Army Corps, to Scott Head (STPNOC) 

dated November 10, 2009 in response to STPNOC October 28, 2009 

request for a permit determination. (Accession No. ML093210227) 

November 10, 2009 Letter from Scott Head, STPNOC, to NRC, Proposed Revision to 

Environmental Report. (Accession No. ML093170197) 

November 11, 2009 Letter from Scott Head, STPNOC, to NRC, Proposed Revision to 

Environmental Report. (Accession No. ML093200201) 
Appendix C 

February 2011 C-9 NUREG-1937 

November 13, 2009 Letter from Kathy Boydston, Texas Parks and Wildlife Division, to Ryan 

Whited, NRC, Proposed Alternative Sites Related to the Combined 

License Application for South Texas Project, Units 3 and 4. (Accession 

No. ML093210221) 

November 16, 2009 Letter from Mark McBurnett, STPNOC, to NRC, Request for Limited 

Work Authorization. (Accession No. ML093230143) 

November 23, 2009 Letter from Scott Head, STPNOC, to NRC, Response to Request for 

Additional Information. (Accession No. ML093310296) 

November 23, 2009 Letter from Scott Head, STPNOC, to NRC, Supplemental Response to 

Request for Additional Information. (Accession No. ML093310392) 

November 30, 2009 Letter from Scott Head, STPNOC, to NRC, Response to Request for 

Additional Information. (Accession No. ML093370158) 

November 30, 2009 Letter from Scott Head, STPNOC, to NRC, Response to Request for 

Additional Information. (Accession No. ML093380310) 

November 30, 2009 Letter from Scott Head, STPNOC, to NRC, Supplemental Response to 

Request for Additional Information. (Accession No. ML093360350) 

December 14, 2009 Summary of November 17, 2009, Public Teleconference Related to the 

Environmental Review of the South Texas Project Units 3 and 4 

Combined Licenses Application. (Accession No. ML093350861) 

January 08, 2010 Letter from Michael Johnson, NRC, to Mark McBurnett, STPNOC 

regarding South Texas Project Nuclear Power Plan Units 3 and 4 

Request for a Limited Work Authorization for Installation of Crane 

Foundation Retaining Walls. (Accession No. ML093350744) 

January 20, 2010 Letter to Amy Hanna, Texas Parks and Wildlife Division, from Jessie 

Muir, NRC, Comments Regarding Alternative Sites Related to the 

Combined Licenses Application for South Texas Project, Units 3 and 4. 

(Accession No. ML093450914) 

February 2, 2010 Letter from Mark McBurnett, STPNOC, to NRC, Request for Exemption 

to Authorize Installation of Crane Foundation Retaining Walls. 

(Accession No. ML100350219) 
Appendix C 

NUREG-1937 C-10 February 2011 

February 2, 2010 Letter from Charles Maguire, Texas Commission on Environmental 

Quality, to Ryan Whited, NRC, 401 Water Quality Certification of South 

Texas Nuclear Project. (Accession No. ML100500926) 

February 19, 2010 Letter from Casey Cutler, Department of Army, to Ryan Whited, NRC, 

regarding Draft Environmental Impact Statement for the Combined 

Licenses for South Texas Project Generating Station Units 3 and 4. 

(Accession No. ML100660017) 

March 9, 2010 Letter from Scott Head, STPNOC, to the U.S. Army Corps of Engineers 

Galveston District regarding South Texas Project Units 3 and 4 

Application for Department of Army Permit. (Accession No. 

ML102700237) 

March 19, 2010 Letter from NRC, to Moni Belton, FWS, regarding Request for 

Comments on the Draft Environmental Impact Statement for the South 

Texas Project, Units 3 and 4, Combined License Application Review. 

(Accession No. ML100470259) 

March 19, 2010 Letter from NRC, to David Bernhart, NMFS, regarding Draft 

Environmental Impact Statement, Essential Fish Habitat Assessment, 

and Biological Assessment Related to the Review of the Combined 

License Application for the South Texas Project, Units 3 and 4. 

(Accession No. ML100470304) 

March 19, 2010 Letter to EPA, from NRC, regarding Draft Environmental Impact 

Statement for the South Texas Project, Units 3 and 4, Combined 

License Application. (Accession No. ML100470410) 

March 19, 2010 Letter to John Fowler, ACHP, from NRC, regarding Section 106 

Consultation and Notification of the Issuance of the Draft Environmental 

Impact Statement for the South Texas Project, Units 3 and 4, Combined 

License Application Review. (Accession No. ML100490064) 

March 19, 2010 Letter to Billy Evans Horse, Kiowa Tribe, from NRC, regarding Section 

106 Consultation and Notification of the Issuance of the Draft 

Environmental Impact Statement for the South Texas Project, Units 3 

and 4, Combined License Application Review. (Accession No. 

ML100490124) 
Appendix C 

February 2011 C-11 NUREG-1937 

March 19, 2010 Letter to Anthony Street, Tonkawa Tribe of Oklahoma, from NRC, 

regarding Section 106 Consultation and Notification of the Issuance of 

the Draft Environmental Impact Statement for the South Texas Project, 

Units 3 and 4, Combined License Application Review. (Accession No. 

ML100490722) 

March 19, 2010 Letter to Principal Chief Oscola Clayton Sylestine, Alabama-Coushatta 

Tribe, from NRC, regarding Section 106 Consultation and Notification of 

the Issuance of the Draft Environmental Impact Statement for the South 

Texas Project, Units 3 and 4, Combined License Application Review. 

(Accession No. ML100490732) 

March 19, 2010 Letter to Mark Wolfe, Texas Historical Commission, from NRC, 

regarding Section 106 Consultation and Notification of the Issuance of 

the Draft Environmental Impact Statement for the South Texas Project, 

Units 3 and 4, Combined License Application Review. (Accession No. 

ML100490740) 

March 19, 2010 Letter to Ruth Toahty, Comanche Nation, from NRC, regarding Section 

106 Consultation and Notification of the Issuance of the Draft 

Environmental Impact Statement for the South Texas Project, Units 3 

and 4, Combined License Application Review. (Accession No. 

ML100490795) 

March 19, 2010 Letter to Mark McBurnett, STPNOC, from NRC, regarding Notice of 

Availability of the Draft Environmental Impact Statement for the South 

Texas Project, Units 3 and 4, Combined License Application. 

(Accession No. ML100600998) 

March 26, 2010 Federal Register Notice of Availability of the Draft Environmental Impact 

Statement for Combined Licenses for Units 3 and 4 at the South Texas 

Project Site. (Accession No. ML100600982) 

March 23, 2010 Letter from Mark McBurnett, STPNOC, to NRC, regarding Request for 

Exemption to Authorize Installation of Crane Foundations Retaining 

Walls. (Accession No. ML100880055) 

March 30, 2010 Letter from William A. Martin for Mark Wolfe, Texas Historical 

Commission, to Ryan Whited, NRC, regarding Section 106 Consultation 

for the Draft Environmental Impact Statement for the Combined 

Licenses for South Texas Project Generating Station Units 3 and 4. 

(Accession No. ML100990381) 
Appendix C 

NUREG-1937 C-12 February 2011 

April 20, 2010 Letter from Rusty Swafford for Miles M. Croom, National Marine 

Fisheries Service, to NRC, regarding Essential Fish Habitat Biological 

Assessment and the Draft Environmental Impact Statement for the 

Combined Licenses for South Texas Project Generating Station Units 3 

and 4. (Accession No. ML101190379) 

May 6, 2010 Email from Bryant J. Celestine, Alabama-Coushatta Tribe, to NRC, 

regarding South Texas Project COL. (Accession No. ML101300039) 

May 24, 2010 Summary of Public Meetings Conducted for the Draft Environmental 

Impact Statement for South Texas Project Units 3 and 4, Combined 

License Application. (Package Accession No. ML101540288) 

June 2, 2010 Email from Michael Bechdol, US EPA Region 6 Ground Water Center, 

to NRC, regarding Comments on Draft EIS for the COLs for S TX 

Project Electric Generating Station Units 3 and 4. (Accession No. 

ML101540268) 

June 8, 2010 Email from Stephen Spencer, U.S. Department of the Interior, to NRC, 

regarding NUREG-1937, Draft Environmental Impact Statement for 

Combined Licenses at the South Texas Project, Texas. (Accession No. 

ML101600049) 

June 9, 2010 Letter from Cathy Gilmore, U.S. EPA Region 6, to Jessie Muir, NRC, 

regarding Draft EIS for STP Units 3 and 4. (Accession No. 

ML101610346) 

June 9, 2010 Letter from Jayson Hudson, USACE, to Scott Head, STPNOC, 

regarding Permit Determination. (Accession No. ML101660315) 

July 7, 2010 Letter from Scott Head, STPNOC, to NRC, regarding Additional 

Information Regarding Draft Environmental Impact Statement. 

(Accession No. ML101930157) 

July 21, 2010 Letter from Scott Head, STPNOC, to NRC, regarding Revised Request 

for Exemption to Authorize Installation of Crane Foundations Retaining 

Walls. (Accession No. ML102070274) 

August 6, 2010 Notice of Public Teleconference to Discuss Topics Raised in Public 

Comments on the Draft Environmental Impact Statement. (Accession 

No. ML102140545) 
Appendix C 

February 2011 C-13 NUREG-1937 

September 9, 2010 Letter from Mark McBurnett, STPNOC, to NRC, regarding Additional 

Information Regarding Draft Environmental Impact Statement. 

(Accession No. ML102570059) 

September 16, 2010 Letter from Casey Cutler, Corps, to Scott Head, STPNOC, regarding 

Permit Determination. (Accession No. ML103020111) 

September 22, 2010 Memorandum from Jessie Muir, NRC, to Ryan Whited, NRC, Summary 

of August 25, 2010, Public Teleconference with South Texas Project 

Nuclear Operating Company to Discuss Topics Raised in Public 

Comments on the Draft Environmental Impact Statement. (Accession 

No. ML102520341) 

October 5, 2010 Letter from Scott Head, STPNOC, to NRC, Submittal of Combined 

License Application Revision 4. (Accession No. ML102860292) 

October 12, 2010 Letter from Scott Head, STPNOC, to the Corps, Submittal of South 

Texas Project Units 3 and 4 SWG-2007-00786 Mitigation Plan. 

(Accession No. ML103060028) 

November 5, 2010 Letter from George Wunder, NRC, to Mark McBurnett, STPNOC, South 

Texas Project Nuclear Power Plant Units 3 and 4 Exemption from the 

Requirements of Title 10 of The Code of Federal Regulations, Part 50, 

Section 50.10 (TAC No. RG1056). (Accession No. ML102770454) 

November 17, 2010 Letter from Ryan Whited, NRC, to David Bernhart, NMFS, regarding 

Section 7 Consultation Related to the Combined License Application for 

the South Texas Project, Units 3 and 4. (Accession No. ML102880822) 

December 10, 2010 Letter from Mark McBurnett, STPNOC, to NRC, regarding Change in 

Lead Applicant for STP 3 & 4. (Accession No. ML103490483) 

January 18, 2011 Letter from Roy E. Crabtree, National Marine Fisheries Service, to Ryan 

Whited, NRC, regarding Draft Environmental Impact Statement, 

Essential Fish Habitat Assessment and Biological Assessment Related 

to the Review of the Combined License Application for the South Texas 

Project, Units 3 and 4. (Accession No. ML110190723) 

January 19, 2011 Letter from Mark McBurnett, STPNOC, to NRC, regarding Update to 

Change in Lead Applicant for STP 3 & 4. (Accession No. 

ML110250369) 
Appendix C 

NUREG-1937 C-14 February 2011 

January 26, 2011 Letter from Mark McBurnett, NINA, to NRC, regarding Submittal of 

Combined License Application Revision 5. (Accession No. 

ML110340451) 
Appendix D 

Scoping Comments and Responses 

February 2011 D-1 NUREG-1937 

Appendix D 

Scoping Comments and Responses 

On December 21, 2007, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of 

Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process in the 

Federal Register (72 FR 72774). The Notice of Intent notified the public of the staff’s intent to 

prepare an environmental impact statement (EIS) and conduct scoping for the application for 

combined licenses (COLs) received from STP Nuclear Operating Company (STPNOC) for two 

new nuclear units identified as South Texas Project Electric Generating Station (STP) Units 3 

and 4, to be located at the existing STP site, located approximately 12 mi south-southwest of 

Bay City, Texas. NRC invited the applicant; Federal, Tribal, State, and local government 

agencies; local organizations; and individuals to participate in the scoping process by providing 

oral comments at the scheduled public meetings and/or submitting written suggestions and 

comments no later than February 18, 2008. 

D.1 Overview of the Scoping Process 

The scoping process provides an opportunity for public participants to identify issues to be 

addressed in the EIS and highlight public concerns and issues. The Notice of Intent identified 

the following objectives of the scoping process: 

• Define the proposed action which is to be the subject of the EIS. 

• Determine the scope of the EIS and identify significant issues to be analyzed in depth. 

• Identify and eliminate from detailed study those issues that are peripheral or that are not 

significant. 

• Identify any environmental assessments and other EISs that are being prepared or will be 

prepared that are related to, but not part of, the scope of the EIS being considered. 

• Identify other environmental review and consultation requirements related to the proposed 

action. 

• Identify parties consulting with the NRC under the NHPA, as set forth in 36 CFR 

800.8(c)(1)(i). 
Appendix D 

NUREG-1937 D-2 February 2011 

• Indicate the relationship between the timing of the preparation of the environmental 

analyses and the Commission’s tentative planning and decision-making schedule. 

• Identify any cooperating agencies and, as appropriate, allocate assignments for preparation 

and schedules for completing the EIS to the NRC and any cooperating agencies. 

• Describe how the EIS will be prepared and include any contractor assistance to be used. 

Two public scoping meetings were held at the Bay City Civic Center, on Tuesday, February 5, 

2008. The scoping meetings began with NRC staff members providing a brief overview of the 

COL process and the NEPA process. After the NRC’s prepared statements, the meeting was 

open for public comments. Fifty one (51) meeting attendees provided either oral comments or 

written statements that were recorded and transcribed by a certified court reporter. In addition 

to the oral and written statements provided at the public scoping meeting, 11 letters and 7 

emails were received during the scoping period. Preparation of the draft EIS has taken into 

account all of the relevant issues raised during the scoping process. 

Transcripts for both afternoon and evening scoping meeting can be found in the NRC Agency 

Document Access and Management System (ADAMS), under accession numbers 

ML080950499 and ML080950504, respectively. ADAMS is accessible from the NRC Web site 

at http://www.nrc.gov/reading-rm/adams/web-based.html (in the Public Electronic Reading 

Room). (Note: the URL is case-sensitive.) Additional comments received later in letters or 

emails are also available. A meeting summary memorandum (ML081000171) was issued April 

10, 2008. 

At the conclusion of the scoping period, the NRC staff reviewed the scoping meeting transcripts 

and all written material received during the comment period and identified individual comments. 

These comments were organized according to topic within the proposed EIS or according to the 

general topic, if outside the scope of the EIS. Once comments were grouped according to 

subject area, the staff determined the appropriate response for the comment. The staff made a 

determination on each comment that it was one of the following: 

• A comment that was actually a question and introduced no new information. 

• A comment that was either related to support or opposition of combined licensing in general 

(or specifically the STPNOC COLs) or that made a general statement about the COL 

process. In addition, it provided no new information and did not pertain to 10 CFR Part 52. 
Appendix D 

February 2011 D-3 NUREG-1937 

• A comment about an environmental issue that 

– provided new information that would require evaluation during the review 

– provided no new information. 

• A comment that was outside the scope of the COL, which included, but was not limited to 

– a comment on the safety of the existing units. 

Preparation of the EIS has taken into account the relevant issues raised during the scoping 

process. The comments received on the draft EIS will be considered in the preparation of the 

final EIS. The final EIS, along with the staff’s Safety Evaluation Report (SER), will provide much 

of the basis for the NRC’s decision on whether to grant the STPNOC COLs. 

The comments related to this environmental review are included in this appendix. They were 

extracted from the South Texas Project Combined License Scoping Summary Report 

(Accession No. ML082260454), and are provided for the convenience of those interested 

specifically in the scoping comments applicable to this environmental review. The comments 

that are outside the scope of the environmental review for the proposed STP site are not 

included in this Appendix. The out of scope comments include comments related to: 

• Safety 

• Emergency Preparedness 

• NRC Oversight for operating plants 

• Security and Terrorism 

• Support or Opposition to the licensing action, licensing process, nuclear power, hearing 

process or the existing plant 

More detail regarding the disposition of general or out of scope comments can be found in the 

Scoping Summary Report (ML082260454). To maintain consistency with the Scoping Summary 

Report, the comment source ID and comment number along with the name of the commenter 

used in that report is retained in this appendix. Any changes that have occurred since the 

publication of the Scoping Summary Report (e.g., revisions to the EIS outline) are indicated 

within <new information> angle brackets. 

Table D-1 identifies in alphabetical order the individuals providing comments during the scoping 

period, their affiliation, if given, and the ADAMS accession number that can be used to locate 

the correspondence. Although all commenters are listed, the comments presented in this 

appendix are limited to those within the scope of the environmental review. Table D-2 lists the 

comment categories in alphabetical order and commenter names and comment numbers for 

each category. The balance of this appendix presents the comments themselves with NRC 

staff responses organized by topic category. 
Appendix D 

NUREG-1937 D-4 February 2011 

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 

February 2011 D-5 NUREG-1937 

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 

NUREG-1937 D-6 February 2011 

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 

February 2011 D-7 NUREG-1937 

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 

NUREG-1937 D-8 February 2011 

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 

February 2011 D-9 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 

NUREG-1937 D-10 February 2011 

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 

February 2011 D-11 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 

NUREG-1937 D-12 February 2011 

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 

February 2011 D-13 NUREG-1937 

D.2 In-Scope Comments and Responses 

The in-scope comment categories are listed in Table D-3 in the order that they are presented in 

this appendix. In-scope comments and responses are included below the table. Parenthetical 

numbers shown after each comment refer to the Comment Identification (ID) number 

(correspondence number-comment number) and the commenter name. Responses have been 

edited since publication of the Scoping Summary Report to update section references. 

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 

NUREG-1937 D-14 February 2011 

D.2.1 COL Process 

Comment: The entire process involved from start to finish of a nuclear project needs to be 

examined for direct, indirect, secondary, and cumulative impacts, e.g.: Site preparation The 

extraction of materials to build the plant The transportation of the materials to the plant site The 

construction process The extraction of materials to produce the equipment to be installed The 

transportation of that equipment to the site The installation of that equipment The extraction of 

uranium The milling and enriching of uranium The transportation of enriched uranium to the site 

The operation of the plant Potential impacts on endangered species (0002-1 [Sinkin, Lanny])

Response: With respect to environmental impact analysis, the NRC’s COL process is as 

follows: The NRC regulations governing a COL application require that an applicant for a COL 

must provide the NRC with an environmental report that meets the requirements of 10 CFR 

51.45 and 51.50. As described in 10 CFR 52.17, the contents of an application must focus on 

the environmental effects of construction and operation of a reactor or reactors that might be 

built at the proposed site. Additionally, Section 52.18 requires that the NRC prepare an EIS for 

the application that focuses on the same issues. In its EIS, the NRC staff will review the 

impacts of the proposed construction and operation of new nuclear units based on the 

information provided in the application and on information obtained from independent sources. 

The NRC will document the bases for its conclusions in the EIS and in the COL permit, if 

approved. The majority of the impacts noted in the comment are evaluated as part of this COL 

environmental review process. Other issues noted fall outside of the regulatory purveyance of 

the environmental review. 

Comment: We believe that the decision by the NRC to reverse its decision to accept the 

application indicates there are serious problems with the process designed by the NRC, and 

would suggest that until an EIS is completed, the clock on filing for petition to intervene should 

not begin so that the applicant, NRC and potential petitioners can have the benefit of seeing 

what an EIS process finds out. (0003-1 [Reed, Cyrus])

Comment: Since 1992 there has been a consistent effort to constrain citizen input, not to 

expand it. Right now we’ve seen -- and this is all too familiar in Texas -- what we’re seeing is 

fast tracking of these permits, and it’s unacceptable. We’ve gone from what should be four and 

a half years down to three. We’ve gone from shortened input -- and to be honest, this is -- if this 

permit moves forward, it is actually illegal. (0007-36 [Hadden, Karen])

Comment: We have a licensing process moving forward with an EIS not even begun. These 

are both violations of the statutes and regulations that apply to this process, and I would urge 

you to halt all further proceedings on the license application until the environmental impact 

statement is finalized as is required by federal law. (0007-40 [Hadden, Karen])

Response: These comments express general opposition to the NRC licensing process for the 

STP Units 3 and 4 COL, and provide no specific information to the NRC’s associated 

environmental review. These comments also fall outside the scope of 10 CFR 51 and 52 which 

describe in broad outline the NRC’s environmental review process for a COL. Therefore, these 
Appendix D 

February 2011 D-15 NUREG-1937 

comments will not be considered further in regards to the NRC EIS for the STP Units 3 and 4 

COL. 

Comment: I would also ask that you hold scoping meetings in Houston, which is down wind, as 

is Dallas/Ft. Worth, from any potential accident, in Austin and San Antonio, where the cities 

could potentially be partners, and to let more people speak up and be part of this process.

(0007-34 [Hadden, Karen])

Response: Public meetings are generally held in the community geographically located closest 

to the proposed project location. Interested parties that are unable to attend the public meetings 

in person are also afforded the opportunity to submit written comments. This comment 

expresses opposition to NRC’s scoping process, but provides no specific information on the 

NRC’s environmental review of the STP Units 3 and 4 COL application. Therefore, this 

comment will not be considered further in regards to the NRC DEIS for the STP Units 3 and 4 

COL. 

Comment: In the case of a nuclear power plant, the NEPA process is interrelated with the 

licensing, public participation is through filing petitions to intervene. A key document that could 

provide information upon which interveners could build contentions, is the final environmental 

impact statement. Yet the 60 day clock has started on intervention petitions as soon as the NRC 

accepted the application for docketing, so we now have a deadline of February 25, with no date 

even set for a draft environmental impact statement. The EIS will not even begin before the final 

deadline for interveners to file. (0007-38 [Hadden, Karen])

Comment: And the first concern I would raise is one that’s already been mentioned, which is 

the time factor, that there is a feeling among anyone who analyzes the application and analyzes 

the environmental report that 60 days simply is not enough time to have a logical and 

reasonable assessment, particularly when there’s new information coming in. I do take note of 

the issue you raised earlier, which is one can raise contentions later on if new information 

comes in. (0007-42 [Reed, Cyrus])

Comment: I spoke to Mr. Barrs earlier and, again, was informed that the safety review is not 

complete. And even so we as citizens are being asked to have contentions ready in just 20 

days. Something tells me that that safety review will not be done during that time. How can we 

read it, analyze it, get experts, and prepare a case? That is not right. It is not valid. This -- and 

other reports -- the safety review and the final environmental impact statement should be 

finished before the licensee procedure goes forward and before citizens have to raise their 

contentions. (0008-53 [Hadden, Karen])

Response: It is the Commission’s policy that petitions to intervene in the hearing process be 

based on the application itself, not the staff’s review of the application. These comments 

express opposition to the NRC’s timeline for filing intervention petitions, and provide no specific 

information to the NRC’s environmental review of the STP Units 3 and 4 COL application. 

Therefore, these comments will not be considered further in regards to the NRC DEIS for the 

STP Units 3 and 4 COL. 
Appendix D 

NUREG-1937 D-16 February 2011 

Comment: The NEPA law prohibits irreversible or irretrievable commitments of resources prior 

to the completion of the EIS. That involves the work that the NRC does on the permit. So 

basically what’s going on is that we have docketing of a license application for two nuclear 

reactors that is grossly incomplete, forcing potential interveners to decide on whether to pursue 

intervention, and to decide on what issue or issues to pursue without a complete application 

available. (0007-39 [Hadden, Karen])

Response: Section 102(2)(C)(v) of NEPA requires that an EIS include information on any 

irreversible and irretrievable commitments of resources that would occur if the proposed action 

(approval of the COL) is implemented. Irreversible and irretrievable resource commitments are 

relevant to the use of nonrenewable resources and the effects that the loss of use of these 

resources may have on future generations. These issues will be discussed in Chapter 10 of the 

DEIS. The remainder of this comment expresses opposition to the NRC’s timeline for filing 

intervention petitions for the STP Units 3 and 4 COL, and provides no specific information 

regarding the associated environmental review. 

Comment: We really are not looking for secrets. Our letter of intent in June was published on 

the NRC website, was available in the public document room. There were no secrets about our 

announcement of the new units. (0007-142 [Shepherd, Joe])

Response: This comment makes a statement of fact about the Notice of Intent for the STP 

Units 3 and 4 COL application, but provides no specific information on NRC’s associated 

environmental review. Therefore, this comment will not be considered further in regards to the 

NRC EIS for the STP Units 3 and 4 COL. 

Comment: There’s something called the Design Criteria Document, and that’s called the DCD. 

I started looking at this license application online and I found a whole section that said 

incorporated by reference in the DCD. It took a long time to find out what was a DCD. And then 

when I tried to call and get answers I couldn’t get them. Tonight I was informed by Mr. Kallan 

that that document is available. Unfortunately it is available only in Washington, D.C. in the 

reading room of the Nuclear Regulatory Commission. That is a document that we need. That is 

the design criteria for the two advanced boiling water reactors that NRG wants to build here. 

That is a document that we need in our hands to effectively be able to write contentions to 

submit them in a timely manner. (0008-55 [Acevedo, NK])

Comment: Today is February 5. Our contentions have to be submitted in 20 days. I would like 

to officially ask when will the DCD be available. The licensing procedure should be halted 

immediately until that is available. (0008-56 [Hadden, Karen])

Response: These comments express opposition to the limited availability of the Design Criteria 

Document during the period for filing intervention petitions. These comments provide no 

specific information to the NRC’s environmental review of the STP Units 3 and 4 COL 

application, therefore, these comments will not be considered further in regards to the NRC EIS 

for the STP Units 3 and 4 COL. 
Appendix D 

February 2011 D-17 NUREG-1937 

Comment: In section 5.4.1 of the environmental report there is a section of radiological impact 

and exposure pathways. Here is says -- and I will quote -- Radioactive liquids and gasses would 

be discharged to the environment during normal operation of STP 3 and 4. The released 

quantities have been estimated in Tables 12.2-20 for the gasses and Table 12.2-22 for liquids of 

the ABWR DCD. So the documents containing the quantities of radioactive material that would 

be released during normal operations are not yet available to the public. (0008-57 [Hadden, 

Karen])

Response: This comment expresses opposition to the limited availability during the scoping 

period of documents containing the quantities of radioactive material that would be released 

during normal operations. This comment provides no specific information relevant to the 

environmental review of the STP Units 3 and 4 COL application and therefore will not be 

considered further in the EIS. 

Comment: In the old days we used to have a PSAR, a preliminary safety analysis report. Now 

we don’t have that. Now we have an FSAR. How on earth can anybody call that thing final. It’s 

totally incomplete at this time. We don’t have to fib to each other. It’s not done. It’s not even 

close. Okay. We need to extend the comment period because the information is not there.

(0008-81 [Wagner, William])

Comment: The other part of this that’s a real hard spot with me because I am an old reactor 

operator is it is totally inappropriate to license operation on a woefully incomplete safety analysis 

report. I don’t know how the devil you guys ever came to that conclusion, but that needs to be 

looked at seriously. (0008-82 [Wagner, William])

Response: This comment expresses opposition to the length of the NRC’s scoping comment 

period due to a perceived lack of safety information. The safety review is outside the scope of 

the environmental review process and therefore this comment will not be considered further in 

the EIS for STP Units 3 and 4. 

D.2.2 Process - NEPA 

Comment: justifies moving forward - NEPA requirements [The commenter was questioning if 

there should have been a NEPA review prior to accepting the application to justify moving 

forward with the process.] (0020-1 [Hadden, Karen])

Response: A NEPA environmental review could not have been conducted prior to accepting 

the application because the NRC would have had no project-specific information on which to 

base its review. Docketing an application for review is not a major federal action and therefore 

does not require a NEPA review. The comment provides no new information relevant to the 

environmental review process and will not be evaluated further. 

Comment: I’d also like to request additional scoping meetings regarding the environmental 

report. There are many people I know of in Austin who could not make this trip who would like to 

comment in person. There are people in San Antonio and Houston as well. I would urge you to 
Appendix D 

NUREG-1937 D-18 February 2011 

set up scoping meetings in those communities for this environmental report. (0008-52 [Hadden, 

Karen])

Comment: We also deserve and request that the NRC conduct public hearings in San Antonio 

on those [energy] alternatives and the environmental impacts of STP 3 & 4 as part of the 

scoping process. (0018-2 [Cushing, Lara])

Response: Although NEPA does require Federal agencies to initiate a scoping process, the 

decision of how to implement scoping is left to the agencies’ discretion. It is the policy of the 

NRC to involve the public in the Commission’s decision-making process and therefore it elects 

to conduct open public scoping meetings in association with their environmental review process. 

Meetings are generally held in a location to reach the highest population that will experience the 

most direct environmental impact as a result of the proposed action. In the case of STP Units 3 

and 4, this population is located in the area of Bay City, Texas. The NRC will hold additional 

public meetings after the DEIS is published. Separate meetings will be held by the NRC in 

association with the safety review process. Members of the public who are unable to attend the 

public meetings in person may submit written comments during the open comment periods. 

D.2.3 Site Layout and Design 

Comment: So how come we learned today that the design of record is by Toshiba? I think 

there’s a big mess going on here that we don’t know about. (0007-113 [Payne, Cameron])

Response: The applicant experienced unresolvable issues with the vendor originally identified 

in the application. The type and design of the reactor did not change as a result of the change 

in vendors, therefore, the reactor-specific information provided in the application is still valid for 

the analysis. 

Comment: The advance boiling water reactor in Japan, there’s four of them in operation in 

Japan, was developed as a joint venture between General Electric, Hitachi and Toshiba. They 

all jointly own that design in Japan. GE took that design and got it certified in the United States. 

Where did that design come from, you asked about the safety, what is this, what is the safety 

record. We’ve been operating boiling water reactors in the United States since 1960. The boil 

water reactors, through each generation, have evolved into -- further and further involved into a 

more advanced design. When GE and Hitachi and Toshiba went to develop the advanced 

boiling water reactors, they started with the BWR-6, the latest design that’s currently in 

operation in the United States. They took that design and they looked at the rules under Part 

52, what they needed to address, and they looked at the things that were bothering them about 

the BWR-6 that didn’t work as well as they wanted it to, things they could make it safer, things 

that make it more reliable, they addressed those issues and developed the advanced boiling 

water reactor. It’s very similar in operation and design to the BWR-6. We have many, many, 

many years of experience operating those plants. (0007-136 [McBurnett, Mark])

Comment: [The ABWR’s] lineage is over 60 years of operation in the United States and around 

the world. And the plans that we’re looking at are an evolutionary design that’s based upon the 
Appendix D 

February 2011 D-19 NUREG-1937 

best that was in the United States. The design’s certified by the NRC, and meets all U.S. 

standards. (0007-146 [Shepherd, Joe])

Comment: Besides the good operating record that we saw with the advanced boiling water 

reactors in Japan, we choose them also because of their record associated with on-time 

construction, on-budget cost, and on schedule. And that performance, we believe we can 

replicate in the United States. (0007-147 [Shepherd, Joe])

Comment: This technology [ABWR] has a long lineage in the United States. The design that 

has been built in Japan was predicated by 60 years of operations of boiling water reactors in the 

United States as a evolutionary design from our very best in the United States, the BWR6. And 

it’s better. It’s a G.E. design. It’s been certified by the Nuclear Regulatory Commission. And it 

meets all U.S. standards. We [STP] chose the ABWR because of the operating record that it 

has, but we also chose it because of the record that it has for being constructed on time and on 

budget. (0008-128 [Shepherd, Joe])

Response: These comments are general in nature regarding the advanced boiling water 

reactor (ABWR) design chosen for Units 3 and 4. No new information relevant to the 

environmental analysis was provided and therefore the comments will not be evaluated further. 

D.2.4 Land Use - Transmission Lines 

Comment: Actually South Texas has three different power line corridors leaving the site. The 

advanced boiling water reactors will also have cross-ties into the Unit 1 and 2 switch yard.

(0008-121 [McBurnett, Mark])

Response: The power transmission system will be described in Chapter 3 of the DEIS. The 

applicant proposes to upgrade two of the six existing transmission lines and does not intend to 

construct any new transmission lines or corridors. Environmental impacts associated with the 

planned upgrades to the existing transmission lines will be addressed under construction 

impacts in Chapter 4 of the DEIS. 

D.2.5 Meteorology and Air Quality 

Comment: One of the new issues affecting decisions on nuclear power is the global concern 

over Human activity creating global climate change with unpredictable and potentially 

devastating results. While the nuclear industry successfully used this concern to drive their 

lobbying effort for a new generation of nuclear power plants, the premise that nuclear power is a 

positive response to global climate change concerns may not withstand objective examination. 

The EIS should include such an objective examination. (0002-3 [Sinkin, Lanny])

Comment: The context for evaluating emissions of gasses attributable to a nuclear power plant 

should include those gasses emitted during the following: Site preparation The extraction of 

materials to build the plant The transportation of the materials to the plant site The construction 

process The extraction of materials to produce the equipment to be installed The transportation 
Appendix D 

NUREG-1937 D-20 February 2011 

of that equipment to the site The installation of that equipment The extraction of uranium The 

milling and enriching of uranium The transportation of enriched uranium to the site The 

operation of the plant, including the emission of heat and evaporated water. (Water vapor is a 

powerful green house gas. The EIS should provide a conversion of the amount of water vapor 

created by the nuclear plant operating process to the equivalent carbon dioxide emissions.) The 

decommissioning of the plant. The transportation of radioactive waste, including high level, low 

level, and decommissioning waste to final storage. The preparation and operation of sites where 

the radioactive waste is to be stored. (0002-4 [Sinkin, Lanny])

Comment: Water vapor is a powerful green house gas. The EIS should provide a conversion 

of the amount of water vapor created by the nuclear plant operating process to the equivalent 

carbon dioxide emissions. (0002-5 [Sinkin, Lanny])

Comment: Climate change can also be associated with increased air and water temperature 

which could impact the ability of the cooling system and intake to operate sufficiently. Thus, 

temperature change must be assessed more accurately. (0003-32 [Reed, Cyrus])

Comment: While the ER takes credit for the emissions reduction that would be made by 

investing in a nuclear plant as opposed to a coal or natural gas plant (see discussion above), it 

does not discuss the global warming emissions resulting from the mining, processing, 

enrichment and fuel fabrication of uranium needed for the plant. (0003-41 [Reed, Cyrus])

Comment: We feel there are cleaner, safer and quicker ways of achieving global warming 

goals. For example, nuclear power plants take a long time to build, and they’re not going to 

really do anything in terms of the carbon footprint. (0007-105 [Singleton, Robert])

Comment: When you look at the carbon footprint for a nuclear power plant, you also have to 

consider the fact that mining and manufacturing -- mining of uranium and enrichment of uranium 

add carbon to the air, and the lower grade that uranium is, the harder it is to mine, the further 

you have to go to get it, all of those things add to the footprint. Also, transportation and storing 

of nuclear waste have to be added to that. This is not a zero carbon footprint industry. It’s only a 

zero carbon footprint industry is you look just at plant operation. And I’m not even sure that’s 

true. But if you look beyond plant operation to how they get the uranium, and what they do with 

the waste, it’s to a zero carbon footprint industry. (0007-119 [Singleton, Robert])

Comment: We are not against renewables, solar, wind, conservation, efficiency. We teach our 

people to look carefully at decisions, .... I think that the studies that you look at on global 

warming, on greenhouse gases all tell you that you need all of that, including nuclear power, to 

be able to make any kind impact on reducing the emission of greenhouse gases and reversing 

the trends that we see in our global climate. (0007-145 [Shepherd, Joe])

Comment: Also -- it is also a myth that nuclear energy will save us from global warming. We 

hear that a lot and it is not. It is not the truth, it is a myth. A nuclear power plant also creates 

global warming. (0007-81 [Lopez, Diana])
Appendix D 

February 2011 D-21 NUREG-1937 

Comment: So you have uranium in South Texas, so you need to get it enriched, and there are 

only two coal power plants that do that, and they’re not in Texas. So you have to transport the 

uranium to these coal power plants and you have to enrich it, and it causes -- it’s one of the 

primary sources of a potent greenhouse gas that causes global warming. So -- and then you 

have to transport it back to the nuclear reactor, so that causes CO2 emissions, so you have all 

these accumulating effects just for that source of energy. (0007-82 [Lopez, Diana])

Comment: The enrichment takes place at coal-fired facilities that pollute the air and contribute 

to global warming. This is an environmental impact of the South Texas Project. (0007-93

[Cushing, Lara])

Comment: We seem to be given what we at the plant call a sucker’s choice. Either you have 

renewables and efficiency or you have nuclear power. The studies that I have read that are 

done by eminent researchers say that in order to make any kind of significant contribution to the 

reduction of greenhouse gasses being released into the environment, you need it all. You need 

efficiency; you need renewables; and you need nuclear power if you want to make any kind of a 

significant contribution to reducing greenhouse gasses being released into the environment.

(0008-126 [Shepherd, Joe])

Comment: The two nuclear plants that are being proposed here would offset 15.8 million tons 

of carbon dioxide, 38.8 thousand tons of sulfur dioxide, and 10.7 thousand tons of nitrogen 

oxide. (0008-6 [O’Day, Mike])

Response: <The review team characterized the affected environment and the potential 

greenhouse gas impacts of the proposed actions and alternatives in this EIS. The impacts of 

fuel cycle, transportation, and decommissioning on climate change and global warming are 

addressed in Chapter 6. Appendix I provides details of the carbon dioxide footprint estimate for 

a 1000 MW(e) light water reactor. In addition, where it was important to do so, the review team 

considered the potential effects of global climate change during the period of the proposed 

action on other resource assessments.>

D.2.6 Geology 

Comment: We may have a problem with soil subsidence. Not too far away from the existing 

site, on the other side of Highway 60, there is an old Texas Gulf sulphur site at Gulf. Sulphur 

was mined out of there for many, many years. The site was finally abandoned. The company 

moved north out of the county in the area between Highway 60 and Bowling. About five years 

after I moved down here in 1983, that highway fell down into the ground -- a sinkhole. That was 

caused by that sulphur mining that was going on at a place called Newgulf. Is this a possibility 

for the old Gulf site? Would this offer some compromise to the ultimate heat sink or cooling 

pond? (0008-69 [Wagner, William])

Response: Geologic impacts on the proposed facility from off-site actions are in scope of the 

safety analysis and will be addressed in the FSAR issued and maintained by the applicant and 

SER issued by the NRC. The topic of subsidence and sink holes and their potential impact on 
Appendix D 

NUREG-1937 D-22 February 2011 

the proposed facility will be addressed in Section 2.5 of the FSAR. This comment is out of 

scope with regard to the EIS. 

D.2.7 Hydrology - Surface Water 

Comment: Exelon Nuclear decided to move its proposed nuclear plant from Matagorda County 

to Victoria County based on concerns about the costs of preparing for a 20 to 30 foot storm 

surge. How would those same concerns apply to the STNP Units 3 and 4? (0002-11 [Sinkin, 

Lanny])

Comment: If global warming increases sea level rise by 7 meters - will STNP be within the 

storm surge zone? (0010-11 [Public Citizen, Texas Office] [Smith, Tom])

Response: As part of the NRC’s site safety review, the staff will consider whether the site is 

suitable based on storm surge issues. The results of this review will be found in the site Safety 

Evaluation Report. This issue is not within the scope of the environmental review. 

Comment: There are also numerous studies underway regarding the needs of the bays and 

estuaries near STNP. Review of those studies regarding potential fresh water needs of the 

environment and potential effects on the availability of water to STNP should also be part of the 

EIS process. (0002-16 [Sinkin, Lanny])

Comment: [T]he LCRA [Lower Colorado River Authority] still has an ongoing assessment of 

the flow needs of Matagorda Bay. The Inflow Needs Study has yet to be finalized and integrated 

into any management decisions of the LCRA and has yet to be incorporated into any water 

rights requirements. An EIS must assess the inflow needs of the Matagorda Bay and its 

potential impact on the South Texas Project. We would specifically suggest that an EIS examine 

the comments submitted by TPWD on the Matagorda Bay Inflow Criteria Report on January 

22nd, 2008. (0003-26 [Reed, Cyrus])

Comment: [A]ny EIS must address the proposed water rights permit being sought by LCRA for 

the so-called “excess” flows. This proposed water right is presently being contested by the 

Sierra Club in part because of our concern that existing and proposed water use - such as the 

South Texas Project - as well as the proposed permit would impact the flows into Matagorda 

Bay. The permit being sought by LCRA is intimately connected to the so-called LCRA -SAWS 

water project to provide the City of San Antonio with surface water through construction of an 

off-river reservoir not far from the proposed South Texas project. How construction of such a 

reservoir might impact water quality, water availability, water temperature and other parameters 

that could impact the South Texas plant must be considered. (0003-27 [Reed, Cyrus])

Comment: [M]y wife has a place in Egypt, Texas, and that’s probably why I’m here today. She 

couldn’t come today. I’ll talk a little bit on her behalf. She’s a direct competitor for the water 

that’s already allocated to the makeup water I guess for that cooling lake. And so she’s 

concerned on a -- just a on a practical matter. She’s a rice farmer, cattle rancher and a low crop 

farmer in Egypt, Texas. (0007-126 [Conrad, A.C.])
Appendix D 

February 2011 D-23 NUREG-1937 

Comment: My issue here today is water. If we’re going to be taking water from the Colorado 

River, and giving 3,935 gallons per minute to cool a new nuclear reactor, we’re also going to be 

compromising our need for water to San Antonio where humans need water to drink, because 

San Antonio, with the SAWS project, which is San Antonio Water System, the LCRA is going to 

be draining water off the Colorado River to provide for San Antonio. (0007-133 [Schwank, 

Eleanor])

Comment: We have our rice farmers who absolutely need our water. We have out cattlemen 

who absolutely need our water. And let’s not forget our aquaculture, or bays and our estuaries. 

Everybody’s coming to Matagorda because they all love our fishing, but we’re not going to have 

fish, we’re not going to have oysters, we’re not going to have shrimp, we’re not going to have 

anything if we’re not protecting our water. (0007-134 [Schwank, Eleanor])

Comment: There are a number of river studies going on right now, not the least of which by the 

Lower Colorado River Authority, who is in charge of this particular chunk of water. (0008-79

[Wagner, William])

Comment: This new plant will use 4,000 gallons of water per minute. The plant is also 

authorized to use both river and groundwater water. The plant is authorized to use up to 102 

acre feet of river water per year, and use about half of that annually for STNP 1 & 2. If the plant 

uses its full allotment (of water), will there be adequate water for the new reservoir? (0010-4

[Public Citizen, Texas Office] [Smith, Tom])

Comment: The LCRA-SAWS Water Project (LSWP) is based on a Definitive Agreement 

between SAWS and LCRA, signed in 2002, for the purchase of up to 150,000 acre ft/yr of 

surface water from the Lower Colorado River Basin at Bay City. If the plant takes its full 102 

acre feet, will there be enough water for San Antonio to meet its water needs? (0010-5 [Public 

Citizen, Texas Office] [Smith, Tom])

Comment: If it [the new plant] takes its full allotment of 3,935 gallons per minute will there be 

adequate water for rice farmers and others? (0010-6 [Public Citizen, Texas Office] [Smith, Tom])

Response: The impact on current and future water use in the vicinity of the site from the 

additional water withdrawals from the Colorado River needed to operate STP Units 3 and 4 will 

be evaluated and presented in Chapter 5 of the EIS. 

Comment: A similar situation would be the temperature of that water. We’ve had issues -- and 

I say we -- I mean the United States has had issues recently on nuclear plant where because 

the temperatures have gone up, the water temperature has gone up, which has made it difficult 

for those operators to be able to use the water and then discharge the water back in the rivers. 

And I’m speaking about some -- a nuclear plant in Tennessee. And some of the nuclear plants 

in Europe had a similar situation last summer. (0007-48 [Reed, Cyrus])

Response: The comment refers to rising temperatures in the Main Cooling Reservoir and how 

this condition may relate to continued operation of the STP units and to blowdown from the 

reservoir to the Colorado River. The NRC staff’s evaluation of the thermal properties of the 
Appendix D 

NUREG-1937 D-24 February 2011 

blowdown discharge from the reservoir to the Colorado River when all four units are in operation 

will be presented in Chapter 5 of the EIS. 

Comment: My understanding was when you reach certain amounts of -- when the water quality 

is of a certain type, in other words, if there’s a lot of sediment in the water, you do have to 

discharge some back into the river. (0007-49 [Reed, Cyrus])

Response: The comment refers to the blowdown from the Main Cooling Reservoir to the 

Colorado River at the STP site. The NRC staff’s evaluation of the frequency of blowdown and 

its impact on the Colorado River when all four STP units are in operation will be presented in 

Chapter 5 of the EIS. 

Comment: Our cooling reservoir’s a closed cycle system. We do take make-up water out of the 

river to keep that reservoir filled. We take make-up water out of the river most of the times 

during high-flow conditions when it’s, you know, a lot of water flowing through it, to keep it filled. 

The water actually cools in the reservoir, it goes around its little loop and cools to the air, it 

doesn’t -- the hot water does not go back to the river. So it’s closed cycle. We use it for makeup, and just to clarify the operating points, because I think that was confused earlier. (0007-141

[McBurnett, Mark])

Response: This comment provides some information regarding the closed-loop cooling system 

in use for STP Units 1 and 2. No response is needed. 

Comment: Nuclear Power Plants use vast amounts of water. The Union of Concerned 

Scientists, in a document entitled “Got Water? Nuclear power plant cooling water needs,” details 

in a 14-page illustrated summary problems power plants have when the “insatiable cooling 

water needs were not met.” The threat of drought is real in Texas, as is the potential shortage of 

water. (0015-6 [Williams, Mina])

Response: The NRC staff’s assessment of water use requirements for the operation of STP 

Units 3 and 4 including those during drought conditions will be presented in Chapter 5 of the 

EIS. 

Comment: ...of the 12,200 acres containing the current South Texas Nuclear Project, 7,000 of 

these acres (over 57%) comprise the reservoir needed for the cooling water. ... how much of 

this water is lost to evaporation and how much more water might need to be diverted into the 

reservoir if STP expansion is approved. (0017-1 [Scheurich, Venice])

Response: The water withdrawal and consumptive use requirements for the operation of STP 

Units 3 and 4 will be provided in <Chapter 2> of the EIS. 

Comment: As sea levels rise, groundwater can be affected, both in terms of expansion into the 

surrounding soils and in water quality, e.g. salt water intrusion. The effects of such changes 

should be included in the EIS. (0002-12 [Sinkin, Lanny])
Appendix D 

February 2011 D-25 NUREG-1937 

Comment: The combination of reduced precipitation, higher rates of evaporation and 

evapotransporation, and increased number of droughts suggest that relying on the worst 

historical drought may not be a conservative approach. (0002-13 [Sinkin, Lanny])

Comment: A conservative approach to evaluating the adequacy of the water supply available 

to STNP would incorporate the possibility that global warming would produce a drought worse 

than the worst historical drought at a time when available water is already reduced by reduced 

precipitation and increased evaporation and evaportransporation. That evaluation would 

consider: -- the time frame within which the global warming impacts would be expected and the 

projected operating life of the reactors, including renewal of licensing and -- the likelihood of a 

drought worse than the worst historical drought and the potential impact of such a drought on 

the operations of the reactors. (0002-14 [Sinkin, Lanny])

Comment: At the same time, there are credible studies that posit greenhouse warming as a 

precursor to rapid cooling. Schwartz and Randall, An Abrupt Climate Change Scenario and Its 

Implications for United States National Security, October 2003. Any evaluation of potential 

global warming impacts should examine the potential impacts of this alternative scenario for 

climate change, including the impacts on available water. (0002-15 [Sinkin, Lanny])

Comment: A true EIS must examine the relationship between the water needs of the proposed 

plants, its water use, water availability as well as how climate might impact those uses. (0003-25

[Reed, Cyrus])

Comment: The impacts of global warming on the proposed plant must be assessed. Thus, 

when the first STP site was assessed, normal historic drought and water availability were a 

concern, and today, the flow of the Colorado upstream of STP is a real concern during summer 

months, when flows are often lower and evaporation is higher. Nonetheless, the recent IPCC 

Assessments on the impacts of global warming, as well as independent assessments in Texas - 

such as the 1995 Gerald North study - suggest that global warming is likely to affect climate and 

water availability, including in Central Texas. (0003-28 [Reed, Cyrus])

Comment: It would seem any EIS must assess the impacts of global warming and the 

likelihood that droughts in coming decades could be more severe than droughts in the 1940 and 

1950s which are traditionally used as the “drought of record” to determine likely flows. 

Contingencies must be added for flows that are 20 percent or more less than historic drought 

levels. The EIS should rely in part on studies being conducted by the LCRA on the issue of the 

impact of climate change on flows as part of the assessment. (0003-29 [Reed, Cyrus])

Comment: What about water use? With the droughts we’ve been having and with the 

increasing belief that global warming is a significant issue in this part of the country, will there be 

significant decreases in the amount of available water, and what will that mean to the operations 

of this plant? (0007-18 [Smith, Tom])

Comment: One of the issues that’s come up in terms of what scientists are telling us is that 

climate is changing. Yes, it always has changed, but it’s changing more rapidly than in the past. 
Appendix D 

NUREG-1937 D-26 February 2011 

And so, again, I would urge you, in the environmental analysis to look at how climate change 

might impact river flow, because I know that STP has an existing water right, and it appears on 

paper that you’ve got the water to operate your -- you know, the present plants and the plants in 

the future. (0007-45 [Reed, Cyrus])

Comment: Is it really a good investment if in 30 years our flows are going to be that much less, 

will the water really be available and be there? Because if the plant is built and then doesn’t 

operate, it doesn’t make economic sense for anybody. (0007-47 [Reed, Cyrus])

Comment: So I’m here to tell about global warming and how it affects it. With the growth of 

global warming you have to include how will this contribute the nuclear power plants, and how it 

will affect them. So the plant requires water to cool it down, and it requires cold water. So with 

global warming, there’s going to be less water and it’s going to be warmer, so you have to 

consider what the nuclear reactors will be in situations like that. (0007-68 [Lopez, Diana])

Comment: Are there going to be temperature limits? We’re living in a world where 

climatological change is causing warming -- global warming. We know the sea level is rising. It’s 

already bothering the Chinese. It’s not bothering us yet, but it will. Now, what’s causing it isn’t a 

concern here. The mere fact that it’s happening -- and it needs to be analyzed. We’re talking 

about a grand total of about 60 years. We need to look at that. (0008-77 [Wagner, William])

Comment: If global warming is occurring and as severe as we anticipate: If the plant adds 

approximately 14.3°F to the water temperature, and the current intake temperature has been as 

high as 95.6°F, can the plant operate safely with a predicted 3-10°temperature increase due to 

global warming by 2100? (0010-10 [Public Citizen, Texas Office] [Smith, Tom])

Comment: If global warming is occurring and as severe as we anticipate: Will there be enough 

water for cooling decline if a 25% decrease in river flows occurs? (0010-7 [Public Citizen, Texas 

Office] [Smith, Tom])

Comment: If global warming is occurring and as severe as we anticipate: Will the cooling water 

be cool enough to allow the plant to operate? (0010-9 [Public Citizen, Texas Office] [Smith, Tom])

Response: The construction and operation of a nuclear plant involves the consumption of 

water. The staff will independently assess the impact of these consumptive water losses on the 

sustainability of both the local and regional water resources. This assessment will consider both 

current and future conditions, including changes in water demands to serve the needs of the 

future population and changes in water supply resulting from climate variability and climate 

change. While NRC does not regulate or manage water resources, it does have the 

responsibility under NEPA to assess and disclose the impacts of the proposed action on water 

resources. The staff’s assessment of the impacts on the sustainability of water resources will 

be presented in Chapters 4 and 5 of the EIS for construction and operation, respectively. 

Comment: There is substantial evidence to support the prediction that melting the South 

Antactic ice cap and the Greenland glacier will cause a rise in sea level ranging from 6 to 12 

feet (This scenario is presented as a reasonable probability, not a worst case. The sea level rise 
Appendix D 

February 2011 D-27 NUREG-1937 

would probably take place over an extended period of time and probably within the operating life 

of the proposed nuclear power plants). Assuming that sea level were to rise to that extent, what 

would be the impact on: (1) the operations of the plant (2) the access to the plant from off-site, 

particularly by emergency response personnel and equipment (3) the ability to evacuate the 

plant in case of emergency (4) the ability to evacuate surrounding communities in case of 

emergency (0002-6 [Sinkin, Lanny])

Response: Parts (2)-(4) of this comment relate to emergency planning and response and are 

not within the scope of NRC staff’s environmental review. Part (1) of the comment can be 

interpreted to have both a safety and an environmental aspect. As part of the NRC’s site safety 

review, the staff will consider whether the site is suitable based on characteristics of the site 

including long-term variability in flooding levels. The results of this review will be found in the 

site Safety Evaluation Report. This issue is not within the scope of the environmental review 

and will not be discussed in the EIS. As part of the NRC’s environmental review, the staff will 

independently assess the impact of consumptive water losses during operation of the plant on 

the sustainability of water resources including consideration of current and future conditions 

resulting from climate variability and climate change. The staff’s assessment of the operation 

impacts will be presented in Chapter 5 of the EIS.

D.2.8 Hydrology - Groundwater 

Comment: Subsidence, no. What happens if we over-use the ground water in this community, 

and will there be a decrease in the level of the plant? (0007-23 [Smith, Tom])

Response: The NRC is also concerned about subsidence and will be evaluating the potential 

for subsidence at the station. Information on the NRC evaluation of subsidence will appear in 

Chapter 4 on water-use impacts during construction and in Chapter 5 on water-use impacts 

during station operation. The topic of subsidence and sink holes and their potential impact on 

the facility will also be addressed in Section 2.5 of the applicant’s FSAR. 

Comment: If global warming is occurring and as severe as we anticipate: Will groundwater 

decline? (0010-8 [Public Citizen, Texas Office] [Smith, Tom])

Comment: ...in researching in-situ uranium mining, we have discovered that that activity also 

requires enormous amounts of groundwater during the mining process and that there is a high 

likelihood that the mining will contaminate portions of the Gulf Coast Aquifer. For example, the 

company which has applied for a permit to mine in Goliad County, about 100 miles west of here, 

will need 72,000 gallons of water a day during mining and additional vast amounts when 

restoration (which probably won’t be possible) is attempted. (0017-2 [Scheurich, Venice])

Response: Changes in the availability of the water resource by competing demands and longterm variability will be addressed in the cumulative impacts <Section 7.2> on water use and 

quality. 
Appendix D 

NUREG-1937 D-28 February 2011 

D.2.9 Ecology - Terrestrial 

Comment: What about endangered species? There are kemp ridley turtles, whooping cranes, 

and others that are on the threatened and endangered species list in this community. Many of 

them we are beginning to understand how significant they are since they last time this plant was 

permitted in this community. (0007-21 [Smith, Tom])

Comment: There are Kemp Ridley sea turtles and whooping cranes in the vicinity. How will 

construction and operation of the new reactors affect their habitats? What other species will be 

affected? (0010-17 [Public Citizen, Texas Office] [Smith, Tom])

Response: The comments relate to aquatic and terrestrial ecology issues and will be 

considered in the preparation of the DEIS. NRC’s consultations with the National Marine 

Fisheries Service and the U.S. Fish and Wildlife Service regarding threatened and endangered 

species will be discussed in Chapter 4 of the DEIS. 

Comment: [T]he lake that [STP has] -- the 7,000 acre -- also creates some of the best bird 

habitats in the state of Texas. (0008-2 [O’Day, Mike])

Comment: [R]ecently I had the opportunity to go and sit on a pier and watch my brother fish 

and a friend of his. ... So we sat for a time. And as we did, as the conversation waned, I heard 

something. And the longer you listened, the louder it got. And that that I was hearing were frogs: 

frogs that were speaking loudly. And if you know anything about frogs, they’re the most -- or one 

of the most sensitive animals in our environment. And they were not only loud, but they were 

interactive. And I came to understand that as sensitive an issue as this is the creatures of the 

world tell us a lot. And for them to be out in such a large and strong body to be heard at night, 

and them being such a sensitive creature that they through their skins osmose anything the 

environment deals to them, their presence made me understand that we have a very 

environmentally safe -- not just our nuclear facility, but numerous facilities that operate along our 

river -- something I’m very proud of in our county -- something they should be proud of, and I 

think everyone should be well aware of. (0008-23 [Marceaux, Brent])

Comment: Also the alligators -- the nuclear power plant is -- the whole grounds -- in a 

protected wildlife zone. They’ve not only done that, they’ve gone in and put in a -- what’s called 

a wetlands -- their own private wetlands so, you know, to help that. (0008-33 [Head, Bobby])

Comment: In the last 20 years that the nuclear power plant has been here the National 

Audubon Society, year in and year out -- I don’t know if you all know this but Matagorda County 

is the number one birding center in the nation -- more birds -- more species of birds every year. 

They just did the Christmas bird count -- number one in the nation again this year -- more 

species of birds in Matagorda County. (0008-34 [Head, Bobby])

Response: The comments are noted. Terrestrial resources, including all the aforementioned 

species, will be discussed in Chapter 2 of the DEIS. 
Appendix D 

February 2011 D-29 NUREG-1937 

D.2.10 Ecology - Aquatic 

Comment: I had an opportunity one night working nights to go out and work where the pumps 

are out on the reservoir. And I walked out and I looked down and I said, Geez, as a fisherman 

here are these huge catfish and these huge red fish swimming together down there. Now, at -- 

the environment -- if they’re doing something about the environment they’re making the fish 

grow big. I can tell you that. (0008-32 [Head, Bobby])

Response: The DEIS will discuss the aquatic resources at STP in Chapter 2 and will consider 

potential impacts from construction and operation of the two new units in Chapters 4 and 5, 

respectively. 

Comment: As evidenced in the Environmental Report itself, low-flow conditions move the line 

of salinity upstream from Matagorda Bay, leading to more entrainment and entrapments of 

estuarine species, as well as the likely movements of bird species such as pelicans which feed 

on such aquatic species. Thus, the relationship between the salinity line, aquatic species and 

climate must be examined. (0003-30 [Reed, Cyrus])

Response: The DEIS will consider the aquatic biota in the Colorado River, including species 

that move up the river from Matagorda Bay. Recent data collected in the lower Colorado River 

will be used to characterize the aquatic biota, as well as, various water quality indicators 

(including salinity) that will be used to describe the aquatic environment and analyze potential 

impacts from the project. Entrainment, entrapment and impingement of the aquatic biota in the 

river at the vicinity of the plant’s intake structure will be evaluated in Chapter 5 of the DEIS. 

Potential behavioral changes in other non-aquatic species, such as pelicans, resulting from the 

proposed construction and operation of the additional units will also be analyzed. 

Comment: It should be noted that the ER relies heavily on monitoring data of aquatic species 

and water levels from the initial application of 1973 which must be updated to reflect a much 

more saline, lower flow regime which typifies the region today. (0003-31 [Reed, Cyrus])

Comment: In terms of the assessment of water contained in the ER, there are multiple 

sections which continue to rely on dated aquatic monitoring of the Colorado River which must 

be updated and specified as part of an EIS. Thus, as an example, relying on histograms of 

sediment levels in the Colorado River from 1957 to 1973, as is done in Section 2.3.1.1.5 is 

clearly incomplete. (0003-34 [Reed, Cyrus])

Response: The DEIS will include the results of a 12-month monitoring program conducted in 

2007 and 2008 to assess aquatic species and conditions of the lower Colorado River. 

Comment: I know that more than half ( by weight) of the biomass in the earth is in the form of 

microorganisms which live under the surface of the earth and bodies of water. The earth is 

teaming with life to depths below 10,000 feet, especially in coastal plains such as found around 

STP. Some of these organisms have beneficial effects on the biosphere, e.g., producing oxygen 

and absorbing carbon. I am concerned about the effect on these organisms which would result 
Appendix D 

NUREG-1937 D-30 February 2011 

from a massive radioactive effluent leak into the ground, or cooling pond, or the Colorado River. 

An EIS should consider this important effect. (0005-6 [Payne, Cameron])

Response: NRC regulations require strict monitoring of radioactive effluent releases. In 

addition, new plants are commonly required by other State or Federal agencies to perform 

special monitoring of aquatic and terrestrial species for some period of time after a new plant 

commences operation. Ecological impacts related to radioactive effluent releases from the 

proposed facility will be evaluated in the DEIS. 

Comment: We need to figure out whether we’re going to preserve that estuary or whether 

we’re going to let it go to hell. Right now I understand that at the intake for the cooling [pond] 

we’re getting brackish water. The original design was that they were not to remove enough 

water such that there was back-flow to cause saltwater in at the inlet station. It appears it’s 

happening regardless of whether they pump or don’t pump. This says there’s been a change in 

the basic environmental impact statement. That needs to be analyzed for. (0008-78 [Acevedo, 

NK])

Response: The DEIS will describe the function of the intake structure on the Colorado River 

and will discuss the potential impacts to aquatic resources from the operation of that structure. 

The DEIS will also describe changes, unrelated to operation of STP Units 1 and 2, that have 

occurred in the lower Colorado River since publication of NRC’s final environmental statement 

for the two existing units. 

D.2.11 Socioeconomics 

Comment: Units 1 and 2 provide safe, reliable power to millions of Texans. As Mark said, that 

drives that economy of Texas. And it brings millions of dollars of benefits to Matagorda County 

and the surrounding area. (0007-144 [Shepherd, Joe])

Comment: We believe that the benefits to Matagorda County will be significant, not only just 

the jobs that will be created, we’ve talked about the 800 permanent jobs, the 4,000 construction 

jobs, but we believe it’ll have a significant positive affect on the quality of life in Matagorda 

County. (0007-148 [Shepherd, Joe])

Comment: The STP 3 and 4 expansion, as has been mentioned earlier, would bring about 800 

new jobs to the county. It’s been stated that we need jobs, and we do because our high school 

students need opportunities that are not here now, our college-age students are going away 

from the county after they graduate because there’s nothing here to bring them back, what 

limited job we have. Also, we have a number of under-skilled, or under-employed people here 

who are looking for new opportunities to increase the career potential that they have, and that 

they could stay in the county as well. (0007-71 [Bludau, Owen])

Comment: The percentage of new employees living here is important to us. Right now we 

have about 60 percent of the 1200 employees that STP has living in the county, and we would 

like to have an equal percentage or higher of the new hires coming with 3 and 4 that would be 
Appendix D 

February 2011 D-31 NUREG-1937 

here. They would be able to purchase homes and cars here, groceries, retail activities, they 

would use the services of our banks, our medical facilities, insurance, utility service providers. 

And if we could get 600 of those 800 living here, that would generate another 1,000 secondary 

support jobs. Those new employees’ salaries will circulate in the community and that will 

expand it economically. (0007-72 [Bludau, Owen])

Comment: [W]e’re beginning to see the impacts already of the anticipation of Units 3 and 4. 

We saw new retailers open up in Bay City in 2007. We had new retailers who have purchased 

properties in Palacios and in Bay City, and there’s new construction in Palacios and Bay City in 

anticipation of this larger customer base that is going to be here. So these businesses are 

coming, and they’re expanding our tax base and our employee base. (0007-74 [Bludau, Owen])

Comment: STP is looking at about 5,000 construction -- temporary construction workers here 

over a six year period. ... At maximum construction period they’re looking at about 4,000 

workers for two years, but then they would ramp down. ... [T]hose living here are going to spend 

most of their money here. Those commuting in are going to spend some of their money here 

buying gas and refreshments as they go in and out of the county. That’s going to create a strong 

financial benefit to our local businesses and attract some new businesses. (0007-84 [Bludau, 

Owen])

Comment: We are strong supporters of STP. What community would not welcome a $6.4 

billion investment in their community? I mean, this is great. We’re talking about 8,000 

construction jobs during peak, 800 -- I mean 4,000 jobs, 800 permanent jobs. (0007-9 [Knapik, 

Richard])

Comment: I’m indeed pleased to be here tonight and have a chance to talk about bringing new 

reactors to the South Texas Project site and increasing the capacity of the South Texas Project. 

It’s clearly a strong boost for Matagorda County. It’s important for Texans and Texas, for energy 

independence, and having adequate supplies of electricity, which drives our overall economic 

engine that keeps our society going. (0008-113 [McBurnett, Mark])

Comment: Units 1 and 2 provide clean, reliable power to millions of Texans. ... We also 

provide millions of dollars of benefits to Matagorda County. (0008-125 [Shepherd, Joe])

Comment: We think that the benefits associated with Units 3 and 4 will be significant for 

Matagorda County and the surrounding communities. It’s not only the jobs -- the 800 permanent 

jobs and 4,000 construction jobs -- bit the quality of life that we believe the economic impact of 

Units 3 and 4 will bring to this area. (0008-129 [Shepherd, Joe])

Comment: Palacios is going through an economic change. The shrimping industry is on the 

way down and it will never return. The Harris and Galveston County Council of Governments, 

which is 13 counties, including Matagorda County, recently started last year making plans for an 

additional 2.5 million people coming to our area by year 2015. (0008-18 [Morton, Joe])

Comment: As far as the economic impact to Matagorda County ... we’ve got businesses here 

that have ... been here since the early 1900’s. ... Yes, we have new industry coming in. ...But we 
Appendix D 

NUREG-1937 D-32 February 2011 

have these old businesses too. ...down in Palacios ...Blessing and Matagorda and Clemville 

and Bowling ...all these communities around close that are going to have impact by Units 3 and 

4. Also, it’s going to secure future for our children and our children’s children. (0008-38 [Head, 

Bobby])

Comment: The economic impact on the state of Texas will create -- or one nuclear plant would 

create $9.2 billion statewide from one reactor and 5,564 jobs. (0008-4 [O’Day, Mike])

Comment: The focus of the Matagorda County EDC and my job is to bring new economic 

development to Matagorda County. And this ... is a chance of a lifetime that most economic 

developers would dream of. The value of that STP is talking about investing equals the 

combined -- it exceeds the combined value of the eight largest industrial projects in Texas in the 

last four years. It exceeds those. So that is big. That is economic development right big. (0008-

92 [Bludau, Owen])

Comment: We’re after STP 3 and 4 for a number of reasons ... We want to attract their 

employees to live here. If you can get 3 and 4 -- a major percentage of the employees of 3 and 

4 to live here they’re going to buy homes and cars. They’re going to buy their groceries, their 

retail products. They’re going to use the services of our banks, our medical facilities, their 

insurers, utility companies, and our various service providers. That’s going to help all the 

existing businesses in the community. It’s going to attract more businesses to the community. If 

we could get 600 of 800 to live here that would generate an additional 1,000 service sector jobs. 

And that is good economic development. (0008-96 [Bludau, Owen])

Comment: The temporary construction workers that are going to be here will be over a six-year 

period. ... And while they’re living here they’re going to be spending their money here. While 

they are commuting in and out they’re going to be buying gasoline and refreshments and 

spending some of their money here. So that’s going to create additional strong business for our 

local employers, our local businesses, and it’s going to add and attract other businesses. (0008-

97 [Bludau, Owen])

Comment: We saw some of this retail happening already, as was mentioned earlier. We had 

new retailers coming in in 2007. We had more of them buy -- more retailers buy property in 

Palacios and Bay City for new facilities. There are new retail facilities under construction 

because they are anticipating an increased customer base. So this is adding to our employment 

opportunities and it’s adding to the existing tax base, which we all need. (0008-98 [Bludau, Owen])

Comment: The plant location provides jobs on a regional basis without causing development 

problems, such as increased traffic, whlch would occur in a densely industrialized area. (0013-2

[Hearn, Polly])

Response: These comments cite some of the projected favorable socioeconomic impacts on 

the community of plant construction and operation. These comments are covered within the 

existing scope of the DEIS and will be discussed in sections < 4.4 and 5.4 of the EIS.> 
Appendix D 

February 2011 D-33 NUREG-1937 

Comment: I think the first question that you all, in this community, may want to ask is, is this 

going to be a benefit to you, or will your taxes have to go up to pay for the infrastructure to 

support the growth of the plant, the additional hospitals and security systems, roads, schools 

and other issues. (0007-16 [Smith, Tom])

Comment: Tax abatements for NRG will mean the community will bear costs in higher taxes. 

The community will have to come up with funds to build more public infrastructure. The new 

plant will require:1. New roads, new schools, a new hospital, and a paid fire department.2. How 

high will local cities have to raise taxes in order to build this infrastructure? (0010-1 [Public Citizen, 

Texas Office] [Smith, Tom])

Response: These comments briefly identify potential adverse socioeconomic impacts on the 

community of plant construction and operation, including required investments in community 

infrastructure. These topics will be discussed in Chapters 4 and 5 of the DEIS. 

Comment: I think that Matagorda County and Bay City are so much better prepared for two 

more units than we were for the first two units. I happen to have been on the city council at that 

time, and let me tell you, I believe at that time there were 13,000-plus construction workers 

here, which at that time it was the largest construction project in the United States at that time, 

or up to that time, or going on then. (0007-129 [Rice Herreth, Georgia])

Comment: Already ... advanced education has come to the city due to our partnership with the 

local community colleges and with Texas A&M. There’s now a satellite campus at Wharton 

Junior College in Bay City, we’re teaching courses and there are students there today, and that 

did not exist a year ago. And that’s all because of Units 3 and 4. (0007-149 [Shepherd, Joe])

Comment: Ms. Dancer talked about the security of the workforce. I’m sorry if, as we went 

through our deliberations on how we should best manager our costs, that that caused anxiety 

within any of employees. But the truth is, we outsourced not one job. Not one. And we have 

changed our outlook. We’ve gone from an outlook of constriction to one of expansion, and that’s 

the bright future for STP Nuclear Operating Company, and that’s the bright future for Matagorda 

County. We prefer local talent, and the onsite campus in Bay City is part of our commitment to 

try and attract and retain that local talent. And we have many other activities that’ll go forth in 

the future to bring that workforce to Matagorda County. (0007-150 [Acevedo, NK])

Comment: With the announcement of expansion to Units 3 and 4, we have the opportunity to 

bring industry, education, and government together to solve a huge problem, but it was a good 

problem. ... In just a matter of months we came up with a degree program, associate degree 

program called Power Technology, which we have students enrolled in already today, and the 

Mid-Coast Education and Industry Alliance still meets quarterly. We are continuing to address 

the issues to see how we can improve our education systems and make this a great place to 

raise our young adults and have our young adults come back and raise their families for many, 

many years to come, creating another huge strength for our community. (0007-79 [Dunham, D.C.])
Appendix D 

NUREG-1937 D-34 February 2011 

Comment: The city of Bay City is ready to meet the challenges of the growth and expansion of 

Units 3 and 4. The city three years ago passed a $6 million bond issue to repave all the streets 

in the city of Bay City. We’re also actively engaged right now in creating a diversion road around 

our community to help alleviate traffic that we anticipate coming. (0008-14 [Knapik, Richard])

Comment: With this announcement we had the opportunity to bring together industry and 

educators and solve a really huge problem. But it was a good problem, especially for this 

community that has had traditionally double-digit unemployment. Our problem was how are we 

going to meet the demands of our local industries’ needs for all of the jobs that are going to be 

created. ...Within just a matter of months we developed the idea of coming up with power 

technology, which is an associate degree program that’s being taught to our students today.

(0008-47 [Dunham, D.C.])

Comment: STP has made Matagorda County a much strong economic entity by its presence. 

It is our largest private sector employer. Units 3 and 4 would add another 800 jobs. And those 

jobs, as has been mentioned before, are going to be opportunities for our high school 

graduates, our graduates at colleges to come back to school -- come back from school and 

work here and for people who are underemployed to improve their education and have better 

career opportunities. (0008-94 [Bludau, Owen])

Response: These comments discuss community responses designed to take advantage of 

expanding economic opportunities expected as a result of plant construction and operation. 

Such activities are part of the context for economic impact analysis and will be discussed in the 

DEIS. 

Comment: So where initially you had a workforce that by default had to be based in the local 

economy, that paradigm has changed. So as the economy became more global, in part due to 

advances in the internet and electronics communication age, STP began to court workforces 

elsewhere, workforces without roots in Matagorda County. And suddenly, all of those jobs, all of 

those careers that we had been promised, and that had largely come to fruition, suddenly lost 

their stability. (0007-102 [Dancer, Susan])

Comment: If there is any doubt that STP’s ownership didn’t have loyalty to their workforce, or 

their location, pre-announcements of Units 3 and 4, Frank Mallen ended that with a comment 

spoken to a group -- a senior manager, with a comment spoken to a group of recently 

outsourced employees when he said, It’s all about the money. That’s the most poignant and 

honest thing that STP management has presented to this community so far. (0007-103 [Dancer, 

Susan])

Comment: Fortunately for us, we have hindsight and we can see what building two new 

nuclear reactors could bring us. We can see now because we’re 30 years later from the same 

thing happening before. Our unemployment rate is still well above the state average, our school 

districts are still extremely poor, and the owners and operators of the plants still don’t live here 

or show loyalty to our community. (0007-106 [Dancer, Susan])
Appendix D 

February 2011 D-35 NUREG-1937 

Comment: When they started bringing executives in to prepare for 3 and 4, guess where they 

relocated those executives to? Lake Jackson. All the -- and these are the same people who tell 

you they have great love and loyalty for Matagorda County and that we have the infrastructure 

to support the plant growth and to support all the new employees here. (0007-120 [Dancer, 

Susan])

Comment: As far as the concerns I have is the number of STP employees who choose to live 

outside of Matagorda County. I understand. They’ve got beautiful country clubs and stuff like 

that every place else. But I would like to work with both STP, our local officials, and Matagorda 

County to make Matagorda County the preferred residence of not only the construction families 

it will bring, but also the management and employees of STP. (0008-39 [Head, Bobby])

Comment: While the company postulates that it will need between 5000-6000 construction 

workers, how many of them can be found locally or in the region with other major power plants 

being proposed or under construction? There hasn’t been a new reactor ordered in the US for 

decades. The knowledge and skill to build the reactor design is in Japan. 1. Who will NRG hire 

to build and operate the new plant? 2. Will they have to rely on international labor? (0010-2

[Public Citizen, Texas Office] [Smith, Tom])

Response: These comments involve choices by the applicant and their contractors on where 

the construction and operating workforces will come from, and choices by the workforce 

concerning where they will live while working at the proposed plant. These factors affect the 

size of the local resident workforce and the potential socioeconomic impacts and will be 

discussed in the DEIS. 

Comment: [E]mergency planning ... has an aspect to economic development that often is not 

perceived. A lot of the business that I’m talking to -- the industries -- have a concern about the 

Texan fire services -- emergency services. And when we mention the types of planning that are 

undertaken in Matagorda County because of the presence of STP that gives them a good 

comfort level that their needs will be met also and they can participate as a member in this 

emergency planning and response within the county. (0008-100 [Bludau, Owen])

Comment: STP is a major financial supporter to a lot of the activities in the community as has 

been mentioned -- the community events, the organization of the civic activities. Many of these 

events, activities, and so forth could not exist without the financial support of STP. (0008-99

[Bludau, Owen])

Response: These comments discuss past actions of the existing plant management and 

employees for activities that support the community. They provide some context for 

expectations regarding future behavior. Although this type of response is not an inevitable 

socioeconomic consequence of construction and operation, past performance will be used as 

part of the context in the DEIS discussion. 
Appendix D 

NUREG-1937 D-36 February 2011 

Comment: If we can do energy efficiency less expensively than building this plant, and put 

Texans to work as opposed to people in Japan or in Russia or in Africa that will be mining this 

uranium. Wouldn’t it be better to have the jobs and money stay here in the United States? (0007-

29 [Smith, Tom])

Response: This comment expresses the belief that investments in energy efficiency would be 

less expensive and would provide more domestic jobs than an investment in nuclear power. It 

does not ask for an analysis within the EIS of the job and cost consequences of the nuclear fuel 

cycle compared with energy efficiency. Job and cost impacts will be identified and quantified to 

the extent possible in the EIS. 

Comment: I do think that Bay City is being presented with a false choice, either two new 

nuclear reactors, or you’re not going to have any jobs, when, in fact, there are alternatives to 

that, to those two options. (0007-96 [Cushing, Lara])

Response: This comment states that there are alternatives to constructing and operating the 

proposed plant. Chapter 9 of the EIS will discuss the socioeconomic impacts of alternative 

technologies and sites. 

D.2.12 Environmental Justice 

Comment: Environmental justice, what will the net impact be on your taxes and the 

community, the low-income communities of color? (0007-25 [Smith, Tom])

Response: This comment asks what the impact on local taxes and on communities of color will 

be from constructing and operating the proposed plant. Both types of impacts will be 

considered and discussed as part of the socioeconomic and environmental justice impacts, 

respectively. 

D.2.13 Health - Radiological 

Comment: There is a need for measurements on the amount of radioactivity in the water 

currently flowing from the plant into Matagorda Bay to determine whether there is any leakage 

or release of any kind. If there is documentation of such leakage, that potential from two 

additional reactors should also be evaluated. (0002-18 [Sinkin, Lanny])

Response: STP has an ongoing Environmental Monitoring Program which does monitor for 

radionuclides in surface water, groundwater and drinking water on an annual basis. Tritium is 

the only anthropogenic radionuclide that has been measured in onsite water samples for the 

past several years. No radionuclides have been detected in offsite water samples. During 2006 

there were two occurrences of the Total Dissolved Solids discharge line leaking some liquid. 

The water from the leaks was recovered. No radioactive material was released from the site. 

However, the potential for releases will be discussed in EIS Chapter 5. 
Appendix D 

February 2011 D-37 NUREG-1937 

Comment: Prior to STNP Units 1 and 2 going into operation, the public health data for the 

three counties closest to the site showed a cancer death rate 4.5% lower than the statewide 

rate. In the 16 years since the nuclear plants began operating, the cancer death rate in the three 

counties rose to more than 7% higher than the statewide rate. The statewide rate both went up, 

with the three county rate rising four times faster. There is no obvious reason, other than the 

presence of operating nuclear power plants, explaining the data from the three counties. Based 

on this data, an increased cancer death rate would be expected to result from the addition of 

two more operational reactors at the same site. The cumulative impacts analysis for the STNP II 

reactors should address this question. Source: Joseph J. Mangano, MPH, MBA Radiation and 

Public Health Project, January 24, 2008. There is also a recent study indicating that operating 

nuclear power plants adversely affect infant mortality (0002-20 [Sinkin, Lanny])

Comment: There have been numerous cancer studies and infant mortality studies involving 

nuclear plants that should be examined as part of the EIS. While some of these studies have 

been contradictory, a true ER and EIS process must assess the latest studies to estimate the 

actual damages in cancer incidence and death due to the opening of more nuclear power 

plants. (0003-46 [Reed, Cyrus])

Comment: What will the impact of cancer be on this community? And if you look at data you 

see that the cancer rates have gone from below average to above average since this plant’s 

been in operation. (0007-17 [Smith, Tom])

Comment: I do want to go on record and say that I am concerned about increased cancer 

rates (0007-99 [Dancer, Susan])

Comment: ... a large-scale, carefully conducted study concluded: “Our study confirmed that in 

Germany a connection has been observed between the distance of a domicile to the nearest 

nuclear power plant... and the risk of developing cancer, such as leukemia, before the fifth 

birthday.” The study was conducted by the German Register of Child Cancer, an office which is 

funded by the 16 German states and the Federal Health Ministry. Among several alarming and 

unexplained findings was that 37 children living within 3 miles of nuclear power plants had come 

down with leukemia between 1980 and 2003, whereas the statistical average for Germany 

would have predicted just 17 cases In that group. Of course, additional research, which takes 

time, must be done to determine whether proximity to nuclear plants was a factor in causing the 

high number of cases. At this time, scientists can only conclude that this is just “another piece in 

a growing puzzle’” of childhood leukemia’s association with nuclear installations and they 

emphasize the need to keep investigating. We all know that there are risks to almost everything 

we do in life and that there is no escaping some hazards. However, in the case of granting 

nuclear power plant expansion, the risk is too high. (0017-4 [Scheurich, Venice])

Response: As will be discussed in the EIS, the staff accepts the linear, no-threshold doseresponse model. In a recent report entitled “Health Risks from Exposure to Low Levels of 

Ionizing Radiation: BEIR VII - Phase 2 (National Research Council 2006), the BEIR VII 

Committee concluded that the current scientific evidence is consistent with the hypothesis that 

there is a linear, no-threshold dose-response relationship between exposure to ionizing 
Appendix D 

NUREG-1937 D-38 February 2011 

radiation and the development of cancer in humans. Having accepted this model, the staff does 

think that this model is conservative when applied to workers and members of the public who 

are exposed to radiation from nuclear power plants. This is based on the fact that numerous 

epidemiological studies have not shown conclusive evidence of increased incidences of cancer 

at the low dose rates typical of nuclear power plant operations. Further, routine releases from 

operating nuclear power plants are far below the level at which regional excess cancer 

incidences would be expected. These studies include: (1) the National Cancer Institute study 

(1990) of cancer mortality rates around nuclear facilities, including 52 nuclear power plants, (2) 

the University of Pittsburgh study (Talbott et al. 2003) that found no link between radiation 

released during the 1979 accident at the Three-Mile Island nuclear power station and cancer 

deaths among residents, and (3) the Connecticut Academy of Sciences and Engineering study 

(2001) that found no meaningful associations from exposures to radionuclides around the 

Connecticut Yankee nuclear power plant that ceased electricity production in 1996 to the 

cancers studied. Radiological Health Impacts to the public will be addressed in Chapter 5 of the 

EIS. 

Comment: I read a story on the front page of the New York Times two days ago, and ...he 

discovered that his drinking water was contaminated with radioactive tritium. That’s ionizing 

radiation, not the kind of radiation you get from the sun. And he was naturally upset about that, 

and went to Exelon, the largest nuclear reactor manufacturer in the country, and he asked them 

about it, and to make a long story short, they confessed that they knew about this. Exelon 

believed that the tritium found in the drinking water well near the plant in Braidwood, Illinois 

came from millions of gallons of water that had leaked from the plant years earlier, but went 

unreported at the time. That could be happening right here. That concerns me. That bothers 

me. (0007-97 [Payne, Cameron])

Response: STP has an ongoing Environmental Monitoring Program which does monitor for 

radionuclides in surface water, ground water and drinking water on an annual basis. Tritium is 

the only anthropogenic radionuclide that has been measured in onsite water sample for the past 

several years. No radionuclides have been detected in offsite water samples. Drinking water in 

the area is obtained from deep aquifer wells, which is also monitored quarterly and no tritium 

has been detected in this water. 

Comment: There was a comment earlier regarding cancer and radiation in the populations 

living near nuclear facilities. It’s interesting because that question’s been around a long time. In 

the 16 years I’ve been [the site doctor] at STP, the evolution of the answer has been ongoing. 

And I think it’s time, finally, to put that question to bed, because it’s been studied massively, and 

internationally. National Academy of Sciences, National Cancer Institute, long-term big-time 

studies, quality research that have concluded, unequivocally, that living in the shadow of a 

nuclear plant will not give you cancer. So we need to put this to bed. These are American 

studies, British studies, Canadian studies, and, again, it’s good reading. So take it home. 

There’s some real issues to deal with here. This is a non-issue. (0007-115 [Hefner, James])

Comment: As far as locally, less than a year ago, right here in Matagorda County, two Rice 

[University] professors wanted to address his particular question, germane specifically to the 
Appendix D 

February 2011 D-39 NUREG-1937 

county. Can the folks here in Matagorda County -- is there more cancer death rate right here 

than other counties in Texas? The answer is no. Two Rice professors, eminently qualified, 

studied this question and concluded that out of 230 counties studied, Matagorda County ranked 

108 out of 230 counties as far as cancer death rates. And for sure 206 of those counties don’t 

have a nuclear facility. (0007-116 [Hefner, James])

Comment: [W]e’re upstream of the water -- of your water, and we’re downwind of any kind of 

problems. And Wharton County does have a lot of cancer. Now is it because of you all? 

Probably not. But it has a lot of cancer. (0007-127 [Conrad, A.C.])

Comment: Advanced boiling water reactors in Japan have an impressive record on low 

radiation worker exposures. It’s lower than what we typically see in this country in any of our 

plants. They have an impressive record, and we look forward to being able to do this. There’s 

design features in those plants that enable that to happen. (0008-117 [McBurnett, Mark])

Comment: Later there is a comment that 1.9 fatal cancers would occur from the annual fuel 

cycle. Please add information about the day-to-day operations as well. (0008-65 [Hadden, Karen])

Comment: Also going on is what’s known as LCRA-SAWS, or the San Antonio Water System. 

Now, that’s not close. It’s up near Interstate -- or U.S. Highway 59 between Wharton and El 

Campo. But they’re going to build a large reservoir that’s going to feed the city of San Antonio 

from the Colorado River. This is a large open body of potable water that is in a possible patch 

for any radioactive release from the site. It needs to be analyzed as part of the environmental 

report. (0008-80 [Wagner, William])

Comment: The National Academy of Sciences, National Cancer Institute put together multiple 

studies. The NEI has put this fact sheet together ... A whole bunch of long-term studies that 

have concluded unequivocally now that living near a nuclear facility will not increase your 

incidence for cancer. It just won’t happen. (0008-90 [Hefner, James])

Comment: Two Rice [University] professors were asked to analyze the cancer death rate in 

Matagorda County. Statisticians, Ph.D., full professors -- one of them an adjunct professor at 

M.D. Anderson Hospital -- these folks know numbers, they know cancer -- one a Ph.D. 

environmental engineer. They concluded the same as the national and international studies. 

Living in the shadow of a nuclear facility will not increase the cancer death rate. (0008-91 [Hefner, 

James])

Response: Health impacts associated with plant operation will be discussed in Chapter 5 of 

the EIS. 

Comment: [The Environmental Report] discussed the maximally exposed individual. Please, if 

you would, expand this section to include impact on all age groups. It should be women and 

children, young children, pregnant women, not just adult males. In some sections there was 

analysis of children, and that’s good. But the impact should be done for all categories for all 

types of impacts. (0008-58 [Hadden, Karen])
Appendix D 

NUREG-1937 D-40 February 2011 

Response: The software packages that the NRC authorizes for use in calculating the 

maximally exposed individual (MEI) do calculate doses to various age groups, including 

teenagers and children. The concept of the maximally exposed individual is set to maximize the 

dose consequences from all pathways and all age groups. 

Comment: There was data that said water downstream is not used for drinking water or 

irrigation. Please analyze the impacts, however, because there is wildlife in the area and 

breeding grounds in the wetlands. We need to have added explanations of what the data 

means. There is some data provided in here, but no context given to what it means. (0008-59

[Hadden, Karen])

Response: In addition to STP’s ongoing environmental monitoring program that monitors for 

radionuclides in surface water, groundwater, and drinking water, the DEIS will examine 

downstream water uses and impacts from construction and operation of the proposed plant. 

Comment: Gaseous pathways are analyzed in terms of 50 miles, in terms of exposure to 

ground and air, and inhalation. Then there’s a reference to radiation shielding, but no 

explanation. I would like the document to include exactly what is meant by radiation shielding -- 

how does it work, why does it work, what does it mean. (0008-60 [Hadden, Karen])

Response: Shielding is any material or obstruction that absorbs radiation and is designed to 

protect personnel or materials from the effects of ionizing radiation. 

Comment: There’s a conservation estimate of 2.5 milli[rems] per year at the site boundary. 

They come up with a total body exposure to the maximally exposed individual per year of .35 

milli[rems] per unit. So if you double that you’re talking about .70 milli[rems] per year. But we 

need to bear in mind this would now be four units and cumulative impacts need to be addressed 

throughout. (0008-61 [Hadden, Karen])

Response: Cumulative impacts will be discussed in Chapter 7 of the EIS. The National 

Council for Radiation Protection Report 93 (NCRP 1987) estimates that the average American 

citizen receives a natural background, (i.e., terrestrial and cosmic radiation in origin) radiological 

dose of 280 millirem per year, so 0.7 millirem is about 0.25 percent of that background dose 

rate. 

Comment: Several times the study just simply concludes that these exposure limits would be 

small -- in capital letters small. Please give us some context. What is the criteria for small? What 

do you mean? And why are they small? (0008-62 [Hadden, Karen])

Response: The National Council for Radiation Protection in its 1987 Report number 93 

estimated that the average American citizen receives a natural background, (i.e., terrestrial and 

cosmic radiation in origin) radiological dose rate of 280 millirem per year. The radiological 

doses reported in the Environmental Report are considerably less than natural background for 

the average American citizen and are therefore considered ‘small’ as defined in 10 CFR Part 51, 

Appendix B. According to the noted regulation, radiological impacts are considered small if they 

“do not exceed permissible levels in the Commission’s regulations.” 
Appendix D 

February 2011 D-41 NUREG-1937 

Comment: The occupational radiation doses are listed as 197.8 person-rem for the two units 

per year. This is over 200 times, by my calculations, of what the average exposure would be. 

And if you double that, workers at the plant may be getting very high levels of radiation. 

Cumulative impacts must be analyzed. (0008-64 [Hadden, Karen])

Response: The occupational population doses noted in the comment refer to the large work 

force (~5950 workers) that will be building the two new reactors. The average dose rate to that 

work force is about 33 mrem per person. Cumulative impacts will be addressed in Chapter 7 of 

the EIS. 

Comment: More radiation means bigger risk of cancer. The EIS should include an analysis of 

the impact on humans and other living systems of an increase in radiation levels as a result of 4 

operating reactors at STP. ... Will the two new reactors increase the amount of low-level 

radiation exposure to surrounding populations? (0010-3 [Public Citizen, Texas Office] [Smith, Tom])

Response: Radiological impacts from the normal operation of the two new reactors will be 

discussed in Chapter 5 and cumulative impacts will be discussed in Chapter 7 of the EIS. 

Comment: There is a need for a baseline of current animal, bird, fish, reptile, and other nonHuman creature level of radioactive uptake, so that a later comparison can determine health 

effects of reactor operation. (0002-21 [Sinkin, Lanny])

Comment: [The Environmental Report] refers to the fact that gamma and beta emitters are 

typically part of the normally released radionucleids of power plants. Again, the impacts to biota 

are considered small. Please explain. (0008-63 [Hadden, Karen])

Comment: What is the effect of low-level radiation over prolonged periods on wildlife in the 

area? (0010-18 [Public Citizen, Texas Office] [Smith, Tom])

Response: The affected radiological environment will be addressed in Chapter 2 of the DEIS. 

Radiological impacts to biota from operation of the reactors will be discussed in Chapter 5. 

D.2.14 Accidents - Design Basis 

Comment: The last analysis of a credible accident was the CRAC II study done while STNP 

was still under construction. The STNP estimates were: 1. 15,200 early deaths (25 mile radius 

around plant) 2. 8,770 early injuries (35 mile radius) 3. $112 billion (1980 dollars) With nearly 25 

years of sustained population growth in the region, it is certain that these impacts need to be 

updated. The review in the application is inadequate to inform citizens of the threat. (0010-16

[Public Citizen, Texas Office] [Smith, Tom])

Response: The environmental review of the STPNOC application will include analyses of both 

design-basis and severe accidents. The results of these analyses will be included in DEIS 

Chapter 5 that discusses the environmental impacts of reactor operation. 
Appendix D 

NUREG-1937 D-42 February 2011 

D.2.15 Accidents - Severe 

Comment: LCRA is involved in negotiations with San Antonio to establish long term contracts 

for interbasin transfers of water. The storage of that water will be in a large open reservoir. The 

EIS should examine the potential impact on the proposed reservoir of an accident at STNP.

(0002-17 [Sinkin, Lanny])

Comment: The ER analyzes likely dosages to the population and resulting from moderate or 

severe accidents. It predictable finds that all resulting dosages meet NRC requirements and 

guidelines. What is lacking, however, is any analysis of the potential health effect impacts of 

STP 3 and 4 in combination with STP 1 and 2. (0003-45 [Reed, Cyrus])

Comment: While I understand that the proposed ABWR is safer than the Chernobyl reactor, it 

is possible that there could be a meltdown at STP leading to a massive explosion causing a 

similar nuclear catastrophe. I would like the EIS to show what would happen to the people living 

in Houston, as well as those who live even closer. How many would die of severe radiation 

poisoning? A million? How many thousands of square miles of agricultural land would have to 

be abandoned for years to come? Also what about those living in San Antonio, the tenth largest 

city in the U.S. What about Austin,TX? As a U.S. citizen, I think an EIS should make these 

calculations and let the public know. (0005-4 [Payne, Cameron])

Comment: The things I want to see more concern with in the environmental review, in the -- 

and since this is a scoping hearing, let me say this, you have to consider the worst case 

scenario. What if something like Three Mile Island happens? What will the effects on this area of 

Texas be? And that’s not even the worst accident that’s been known to happen. What if 

something like Chernobyl happens? I want to see the environmental review include the worst 

case scenario, the absolute worst that could happen. You’ll not find one word about that in the 

current environmental report. (0007-121 [Singleton, Robert])

Response: The DEIS for the proposed new reactors will include an evaluation of the risks 

associated with potential severe accidents including accidents that involve reactor core melts. 

The evaluation will include estimates of health and economic risks to a distance of 50 mi from 

exposure to the plume and from exposure to contaminated land and water. These risks will be 

compared with risks associated with the existing plants. This evaluation will be in the DEIS 

<Chapter 5> on operational impacts. In addition, the evaluation will include an estimate of the 

cumulative risk of severe accidents for all units at the STP site. <This evaluation will be in 

Chapter 7 of the DEIS.> Consistent with the general NEPA philosophy that environmental 

review under NEPA contain realistic estimates of impacts, the Commission in its Safety Goals 

policy statement (51 FR 30028, 1986) has adopted the use of mean estimates rather than worst 

case estimates of accident risks. 

Comment: I would point out in a boiling water -- a boiling water reactor is a very robust design. 

Loss of that piece of equipment [the cooling tower] does not result in a catastrophic event for a 

boiling water reactor. (0008-123 [McBurnett, Mark])
Appendix D 

February 2011 D-43 NUREG-1937 

Comment: Nuclear power plants are not safe. Regardless of the safety efforts and record of 

specific nuclear powers plants, the fact remains that there need be only one accident to have a 

catastrophic result. Nuclear waste poses a real threat since it is generated throughout all parts 

of the fuel cycle in these power plants. (0015-7 [Williams, Mina])

Response: These comments do not provide new information related to the environmental 

review. They will not be addressed in the environmental impact statement. 

Comment: LCRA is involved in negotiations with San Antonio to establish long term contracts 

for interbasin transfers of water. The storage of that water will be in a large open reservoir. The 

EIS should examine the potential impact on the proposed reservoir of an accident at STNP.

(0002-17 [Sinkin, Lanny])

Response: The environmental impact statement for the proposed new reactors will include an 

evaluation of the risks associated with potential severe accidents including accidents that 

involve reactor core melts. The evaluation will include estimates of health and economic risks to 

a distance of 50 mi from exposure to the plume and from exposure to contaminated land and 

water. These risks will be compared with risks associated with the existing units. This 

evaluation will be in the DEIS <Chapter 5> on operational impacts. In addition, the evaluation 

will include an estimate of the cumulative risk of severe accidents for all units at the STP site. 

<This evaluation will be in Chapter 7 of the DEIS.> Consistent with the general NEPA 

philosophy that environmental review under NEPA contain realistic estimates of impacts, the 

Commission in its Safety Goals policy statement (51 FR 30028, 1986) has adopted the use of 

mean estimates rather than worst case estimates of accident risks. 

Comment: The National Environmental Policy Act (NEPA) require that plausible statements as 

to the prospective environmental impacts be disclosed in advance. Any Environmental Impact 

Statement that did not raise the twin specters of nuclear core meltdown and a meltdown in a 

spent nuclear fuel pool is inadequate, and should be challenged in court. (0005-3 [Payne, 

Cameron])

Comment: Possibly even worse than a reactor core meltdown would be a meltdown in one of 

the spent nuclear fuel pools. Please give us the effects of that. (0005-5 [Payne, Cameron])

Response: The environmental impact statement for the proposed new reactors will include an 

evaluation of the risks associated with potential severe accidents including accidents that 

involve reactor core melts. The probability of simultaneous reactor accident involving a core 

melt and a spent fuel pool accident involving a fire is too low to be plausible. Therefore, the 

environmental impact statement will not address the consequences of simultaneous severe 

reactor accidents and fuel fires in the spent fuel pool. 
Appendix D 

NUREG-1937 D-44 February 2011 

D.2.16 Uranium Fuel Cycle 

Comment: The EIS should examine the likelihood that a solution to the high level waste 

disposal issue will be forthcoming any time in the near future and the consequences for STNP, 

such as indefinite on-site storage, if such a solution is not forthcoming. (0002-22 [Sinkin, Lanny])

Comment: The ER is short on details on how the proposed plant will deal with thousands of 

curies and tons of low-level and high-level waste to be generated by the plant. Radioactive 

waste management in the U.S. has been and continues to be nightmarish and difficult. (0003-35

[Reed, Cyrus])

Comment: There are now only three facilities which are taking low-level waste from nuclear 

plants in the States of South Carolina, Utah and Washington. However, none of the three will 

currently take all types of low-level radioactive waste from Texas power plants. Thus, the [EIS] 

must address how much of which kinds of low-level radioactive waste will go to which facilities 

must be addressed. In addition, because there is the real possibility that no facility will be found 

in the short-term for the most radioactive of low-level rad waste, an EIS must address the 

possibility and impacts of permanent disposal of low-level rad waste on-site. (0003-36 [Reed, 

Cyrus])

Comment: If the ER fails to adequately assess the generation, storage and disposal of lowlevel waste, the oversights in terms of high level radioactive waste are much greater. First of all, 

the ER assesses the transport of spent fuel (high level waste) to a depository, using Yucca 

Mountain as an example. Yet both the NRC and NRG know that even if Yucca Mountain were to 

open sometime in the first years of operation of STP No. 3 and 4, storage of spent fuel would be 

taken up by existing nuclear plants. There has yet to be, and does not appear to be any 

resolution of the question of how to dispose of high level radioactive waste. (0003-37 [Reed, 

Cyrus])

Comment: I think it’s irresponsible to be considering permitting new reactors when we have yet 

to permit or identify a viable site to dispose of the waste. (0007-109 [Cushing, Lara])

Comment: Even assuming that that worst case doesn’t happen, you still have one non -- one 

problem that there is no good solution for. And that is what you’re going to do with nuclear 

waste. I don’t believe the time frame. I think it should be longer. But the federal government 

says we’re going to have to store high-level waste for 10,000 years, that we’re going to have to 

protect for 10,000 years. (0007-124 [Singleton, Robert])

Comment: I assure you we have the capability at South Texas to store nuclear waste. We 

have the capability to store all the waste, the high-level waste out of Units 1 and 2 through 2028. 

We have the capability for 10 years of storage in the new advanced boiling water reactor 

design, and there are technologies to allow us to develop storage that goes much beyond that, 

and basically we can store it as long as we need to, until the federal government fulfills their 

contact and takes possession of that spent fuel and ultimately disposes of it. Ten thousand 

years? Not 10,000 years. That fuel becomes less radioactive than what we dug out of the 

ground originally in a few hundred years. But, yes. (0007-140 [McBurnett, Mark])
Appendix D 

February 2011 D-45 NUREG-1937 

Comment: What about wastes? The whole community of -- the whole question about the plant 

being permitted is dependant upon your ability to dispose of wastes. ... And we do not yet have 

a licensed and operating low-level radioactive waste disposal site, which means that the 

disposal, up until we get those things permitted, if we ever do, is here in this community. (0007-

22 [Smith, Tom])

Comment: With a nuclear power plant, the waste issue has not been solved. Yucca Mountain 

has been cutting back the workers to 15 now. And to bring more of this into the community is 

putting the community at risk. (0007-31 [Hadden, Karen])

Comment: A third issue is radioactive waste. It’s the big bugaboo in the room, nobody likes to 

talk about it. But the fact is, you know, for 50 years we’ve been talking about how we’re going to 

deal with radioactive waste. We still haven’t dealt with it. We still don’t have a final repository for 

radioactive waste. (0007-51 [Reed, Cyrus])

Comment: I saw some discussion about, you know, the transportation of the spent fuel rods to 

a final repository, and about the amount of space you would have at STP 3 and 4 to have these 

spent fuel rods. But I didn’t see the contingency. What happens if we never -- you know, what 

happens if we are never able to locate a place to put all this waste? Does it just sit there 

forever? Do you have the capacity? (0007-52 [Reed, Cyrus])

Comment: Similarly with low-level rad waste, you know, there are currently only three sites that 

are taking it, one of the which, Barnwell, has now said they’re not going to take it. We haven’t 

yet had the Andrews County site open up. Where is the contingency in here for what to do with 

that waste? (0007-54 [Reed, Cyrus])

Comment: [I]n the 50 years of the nuclear industry we have yet to identify a safe way to 

dispose of the waste. And that is an environmental impact of the South Texas Project. Highlevel radioactive waste stays deadly for tens of thousands of years. And it’s a real engineering 

challenge to think of how to contain such a thing on such a geological time scale. So I think that 

the NRC needs to consider all of those impacts in the environmental scope of their review. And 

it’s a real engineering challenge to think of how to contain such a thing on such a geological 

time scale. So I think that the NRC needs to consider all of those impacts in the environmental 

scope of their review. (0007-95 [Acevedo, NK])

Comment: Yes, we [STP] generate high level nuclear waste. We know how to store it. We 

store it safely. We have the capability to store it safely for as long as we need to store it. 

Ultimately the federal -- we have a contract with the federal government to take possession of 

that material and dispose of it. Until they do so, we’ll store it and continue to do so in a safe 

manner. I want point out our waste is not in a tin building; it is a concrete building. (0008-114

[McBurnett, Mark])

Comment: And right now we’ve got a crisis because the scientific process that we’re looking to 

manage the nuclear waste South Texas 1 and 2, 3 and 4, the 104 operating reactors around the 

country -- right now there’s only one site that’s being looked at. And that’s in Yucca Mountain, 

Nevada. And the issue is is that if this were a scientific process you would be looking at least 
Appendix D 

NUREG-1937 D-46 February 2011 

three sites. And you would be looking -- likely you would be looking at Deaf Smith County, 

Texas, as one of those other sites. And it wasn’t until 1987 that Deaf Smith County, Texas, was 

taken off of the list and Yucca Mountain, Nevada, was the only one that was left. (0008-43

[Gunter, Paul])

Comment: Now, the issue is is that we believe and -- that you should be able to raise this issue 

of nuclear waste within the context of building more reactors. But currently -- the current NRC 

process says that we are not allowed to raise that because of what they call the nuclear waste 

confidence decision. And that decision was made by rule-making with the U.S. Nuclear 

Regulatory Commission that said someday somewhere somebody somehow is going to figure 

out what to do with, you know, right now 55,000 metric tons. You add more reactors -- it’s going 

to be up to 100,000 metric tons, 120,000 metric tons. And right now the only place we’re looking 

at is to send it off to a seismologically and volcanically active area. And it’s not for sure that it’s 

going to happen. Right now the Yucca Mountain process is alling apart. And, in fact, there is no 

confidence. (0008-44 [Acevedo, NK])

Comment: How can the generation of waste which we still do not know how to safely store be 

justified? (0009-4 [Lindsey, Joy])

Comment: No high or low level site has yet been permitted Recognizing that generating 

nuclear energy produces tons of high and low-level radioactive waste that remains dangerous to 

living systems for tens of thousands of years, and radioactive and toxic waste is produced at 

every stage of the fuel cycle, including plant operations, the EIS should address waste issues 

thoroughly. (0010-19 [Public Citizen, Texas Office] [Smith, Tom])

Comment: There is still no ways to safely store nuclear waste for the millions of years during 

which it will remain radioactive. (0012-5 [Edwards, Nancy])

Comment: Nuclear power plants are not a clean energy source and they are not long-lived. 

Radioactive waste remains dangerous to human health for thousands of years, and no country 

in the world has found a solution for disposing of it. (Public Citizen April 2006). These plants 

have a life span of only 30-40 years, after which they must be upgraded at huge costs or 

decommissioned, leaving the site contaminated for thousands ofyears. (Southwest Workers’ 

Union October 25, 2007). (0015-2 [Williams, Mina])

Comment: It has also long been common knowledge that there are health and safety concerns 

associated with the production of nuclear power. We all know there are huge quantities of 

nuclear waste produced for which there is no satisfactory storage solution, and there are 

documented accidents resulting in contamination due to leakages. (0017-3 [Scheurich, Venice])

Response: Onsite storage and offsite disposal of spent nuclear fuel are Category 1 issues. 

The safety and environmental effects of long-term storage of spent fuel on site has been 

evaluated by the NRC and, as set forth in the Waste Confidence Rule at 10 CFR 51.23, the 

NRC generically determined that “if necessary, spent fuel generated in any reactor can be 

stored safely and without significant environmental impacts for at least 30 years beyond the 
Appendix D 

February 2011 D-47 NUREG-1937 

licensed life for operation . . . of that reactor at its spent fuel storage basin or at either onsite of 

offsite independent spent fuel installations. Further, the Commission believes there is 

reasonable assurance that at least one mined geologic repository will be available within the 

first quarter of the twenty-first century and sufficient repository capacity will be available within 

30 years beyond the licensed life for operation of any reactor to dispose of the commercial highlevel waste and spent fuel originating in any such reactor and generated up to that time.” The 

comment provides no new significant information, and, therefore, will not be evaluated further. 

Comment: The low level waste analysis should examine the likelihood of off-site storage being 

available for such waste. (0002-24 [Sinkin, Lanny])

Response: Radiological wastes will be addressed in Chapter 6 of the EIS. 

Comment: Waste produced from uranium mining, including tailings, is another waste which 

should be included in the analysis. (0002-27 [Sinkin, Lanny])

Comment: Chapter 10 of the Environmental Report does not discuss the land that will likely be 

used to mine, process, enrich and fabricate uranium fuels, and the waste and air emissions that 

are generated in that process, nor does it discuss the long-term implications of the low-level and 

high-level waste generated by the operations of the plants, including their potential impact on 

water resources and human health. (0003-23 [Reed, Cyrus])

Comment: [T]here is no discussion of where uranium is likely to be mined as a result of the 

potential additional nuclear plants. Thus, while the ER suggests that uranium is a resource that 

is mainly imported and that the uranium mining industry in the U.S. has been depressed in 

recent years, the Sierra Club notes in Texas, there are currently 19 exploratory permits for 

uranium mining that have been granted or are being processed by the Railroad Commission of 

Texas since mid-2006, that four uranium mines are currently operating in Kleberg and Duval 

Counties, and that two new applications are being processed by the Texas Commission on 

Environmental Quality for mines in Duval and Goliad Counties. The EIS should assess different 

scenarios and the likely impacts, including in South Texas on water resources and health 

impacts. (0003-42 [Reed, Cyrus])

Comment: If NRC is to license a new nuclear plant, it must be based on the impacts from the 

whole uranium cycle that will result. For 50 years, nuclear power has been presented as a clean 

energy source, even as communities at Three Mile Island, Pennsylvania in West Valley, New 

York, in Sheffield, Illinois, Hanford, Washington, Barnwell and a myriad of other locations were 

impacted from the generation and waste disposal, in some cases leading to deaths. Any EIS 

must address the full impacts so more communities do not suffer. (0003-43 [Reed, Cyrus])

Comment: And then the source of uranium. We all think that the uranium will probably come 

from someplace else, and most of it will, but here in Texas we have a number of communities, 

particularly those around Karnes City and Kingsville where we have significant impact already to 

ground water as a result of uranium mining. We’re about ready to get into another round of 
Appendix D 

NUREG-1937 D-48 February 2011 

uranium mining in Goliad and Duval Counties. And the impact of the uranium extraction on 

those communities typically means that ground water is no longer safe. (0007-26 [Smith, Tom])

Comment: And then also you have ... high-grade and low-grade uranium, so once you finish 

with the high-grade, when you enrich it you have to use energy to do that. So when you use low 

...the low-level one, you have to use more energy just to get it so it could be used at the nuclear 

reactor plants. (0007-83 [Lopez, Diana])

Comment: While it’s true that nuclear power plants don’t emit carbon dioxide, one of the 

principle ingredients fueling global warming, the mining of uranium to fuel these plants is 

anything but clean. I’d ask all of you to consider the indirect costs associated with uranium 

mining. It’s a nasty business that can pollute aquifers, and taint drinking water and irrigation for 

nearby residents. (0007-86 [Castro, Geoffrey])

Comment: Mining and enriching uranium results in radioactive contamination of the 

environment and risks to public health. Exposure to radon has been shown to cause kidney 

failure, chronic lung disease, and tumors for the brain, bone, lung, and nasal passage. The EIS 

needs to assess the impact of uranium mining in the regions from where STP 3 and 4 will derive 

its fuel. (0010-23 [Public Citizen, Texas Office] [Smith, Tom])

Response: Impacts from the uranium fuel cycle have been tabulated in 10 CFR 51.51 Table S3, which is used as the basis for evaluating the contribution of the environmental effects of 

uranium mining and milling to the environmental costs of licensing the nuclear power reactor. 

Associated effects also discussed in the noted CFR include the production of uranium 

hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 

of radioactive materials and management of low-level wastes and high-level wastes related to 

uranium fuel-cycle activities. Health effects from normal plant operation will be addressed in 

Chapter 5. 

Comment: An EIS must assess the much more likely scenario that radioactive waste will be 

stored on-site well.... Forever. That assessment must include an assessment of any potential 

leaks, accidents or gases escaping from the containment zone. (0003-38 [Reed, Cyrus])

Response: Radiological waste will be discussed in Chapter 6 and accidents will be discussed 

in Chapter 7 of the EIS. 

Comment: In the economics analysis, the EIS should consider the burden on the public 

treasury potentially created by Units 3 and 4. For example, the Federal Government is already 

ten years behind in its promise to establish a long term repository for high level nuclear waste 

and remove such wastes from existing nuclear power sites. Based on that failure to perform, the 

Federal Government is having to pay for on site storage, amounting to billions of dollars. This 

expense is discussed in “As Nuclear Waste Languishes, Expense to U.S. Rises,” New York 

Times, February 17, 2008. (0004-2 [Sinkin, Lanny])
Appendix D 

February 2011 D-49 NUREG-1937 

Response: NRC regulation (10 CFR 50.75) requires the establishment of a decommissioning 

trust fund. Sufficient funds are required to be collected and placed in a secure trust that would 

assure decommissioning, including the disposal of low-level waste. Funds are also collected 

from licensees annually to defray costs associated with the ultimate disposal of high-level 

waste. 

Comment: It’s mentioned in the application that you currently send it (low-level waste) to 

several locations. It seems like more detail would be needed so that we, the public, can be sure 

that this rad waste, both low-level and high waste, is taken care of. (0007-55 [Reed, Cyrus])

Comment: I am concerned about the waste issues, and I am concerned about Matagorda 

County being essentially set up as a permanent radioactive waste site because there doesn’t 

seem to be a solution for that one. (0007-91 [Dancer, Susan])

Response: Radiological wastes will be addressed in Chapter 6 of the EIS. 

Comment: [W]here is that uranium going to come from? We have at the Railroad Commission 

now 19 new exploratory permits for a uranium mine. To make the nuclear power plant you need 

uranium, uranium mining can have some environmental impacts here in Texas. So how are we 

going to make that if -- where that uranium’s coming from, and what the total fuel cycle impacts 

are going to be. (0007-57 [Reed, Cyrus])

Response: The NRC staff evaluated the environmental impacts of the uranium fuel cycle 

including the impacts of fuel manufacturing, transportation, and the onsite storage and eventual 

disposal of spent fuel. The staff’s evaluation accounts for the Commission’s “Waste 

Confidence” decision embodied in 10 CFR 51.23 to the extent that decision applies to such 

impacts. The comment does not provide new information and will not be evaluated further. 

Comment: If you’re looking at the enriching of uranium, you have to do -- and you have to do 

that at coal burning power plants as well. You know, so, one, maybe when it gets to the nuclear 

reactor here the pollution is not being produced, but every step of that process there’s pollution 

that’s impacting people, and once it arrives here at the South Texas Nuclear Project, then 

there’s a huge question of radioactive waste which we have nowhere to put. (0007-67 [Rendon, 

Genaro])

Response: Impacts from the uranium fuel cycle have been tabulated in 10 CFR 51.51 Table S3, which is used as the basis for evaluating the contribution of the environmental effects of 

uranium mining and milling to the environmental costs of licensing the nuclear power reactor. 

Associated effects also discussed in the noted CFR include the production of uranium 

hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 

of radioactive materials and management of low-level wastes and high-level wastes related to 

uranium fuel cycle activities. Radiological wastes will be addressed in Chapter 6 of the EIS. 
Appendix D 

NUREG-1937 D-50 February 2011 

Comment: I’m not going to presume to tell you what’s best for your community, I am going to 

talk in solidarity with the communities that are facing the impacts of uranium mining. Eighty 

percent comes from overseas. Most of those places don’t even have environmental or worker 

protections. (0007-107 [Cushing, Lara])

Comment: The most radical nuclear people will admit that something is going to come along 

that’s going to be cleaner and safer and better, and that eventually -- well, we’re still going to be 

storing the waste from this 50 years or 100 years of nuclear power and have to safeguard it. 

What language are we going to put on the warnings to people from the nuclear waste and have 

any guarantee that it’s going to be spoken 10,000 years from now? (0007-125 [Singleton, Robert])

Comment: Interestingly enough, nuclear reactors remove radiation from the environment. This 

is probably going to come as a startling little fact for you, but think about this. The isotopes that 

you put in the reactor are long-lived isotopes -- radioactive isotopes. Reactors convert them to 

short-lived radioactive isotopes that die off much more quickly. When you’re through at the end 

of the day, there is a lower radiation load on the environment because of the presence of 

nuclear reactors. (0008-103 [Dykes, Ed])

Comment: In terms of going forward in the years to come, obviously we have much to do in the 

area of disposing of the high level nuclear waste. ... but it’s not something we should delay 

going forward with new construction and wait 20 or 25 years till the technology is developed. 

We should do it in parallel. (0008-111 [McCormick, Mr.])

Response: These comments do not provide new information relevant to the environmental 

impact analysis and therefore will not be evaluated further. 

D.2.17 Transportation 

Comment: Transportation, how will the materials and the waste come in and out of this 

community? (0007-24 [Smith, Tom])

Comment: [F]or us in San Antonio, this also raises other dangers. In 2004 we had 21 

derailments in our city, 21 derailments that killed five people; one of them spilling chlorine gas in 

the community killing four people instantly. So how is this [uranium] being transported? Is it 

going to be coming through our backyards, of which -- you know, we want to make a clear 

statement that we would not, and do not, want this type of deadly waste passing through 

people’s backyards. And it’s literally passing through people’s backyards when you look at the 

train system in the City of San Antonio. (0007-65 [Rendon, Genaro])

Comment: [H]ow is the fuel going to be transported into this community? How is waste -- if 

they ever find a place to put the waste, how is going to be transported out of this community? 

What we found out in San Antonio after 21 derailments, major derailments, occurred in 2004 is 

that you can’t get any of that information. You can’t find out the routes that they’re taking. They 
Appendix D 

February 2011 D-51 NUREG-1937 

won’t tell you what’s on those trains, and there’s no way to know that. So how can we possibly 

evaluation the risk to our communities when we don’t even know where this stuff is going to be 

transported through, and how to protect it? (0007-94 [Cushing, Lara])

Response: The environmental impacts of transporting fuel and waste to and from the STP site 

will be evaluated, and the results of the analysis will be presented in Chapter 6 of the EIS. The 

transportation of radioactive material to and from the STP site, including unirradiated fuel, spent 

fuel, and radioactive waste, will be conducted in accordance with Federal regulations. The U.S. 

Nuclear Regulatory Commission (NRC) and Department of Transportation (DOT) are the lead 

Federal agencies in charge regulating the safety of shipments of radioactive materials. The 

NRC establishes requirements for the design and manufacture of packages for radioactive 

materials (10 CFR 71, Packaging and Transportation of Radioactive Materials). The 

Department of Transportation regulates the shipments while they are in transit, and sets 

standards for labeling and smaller quantity packages (Title 49, Transportation, U.S. Code of 

Federal Regulations). 

D.2.18 Decommissioning 

Comment: Additional radioactive waste is produced in terms of the irradiated structures and 

equipment in the nuclear plant. A comprehensive examination of the likely method of 

decommissioning should also be part of the EIS. (0002-26 [Sinkin, Lanny])

Response: Decommissioning will be discussed in Chapter 5. The environmental impact from 

decommissioning a permanently shutdown commercial nuclear power reactor is discussed in 

Supplement 1 to NUREG-0586, Generic Environmental Impact Statement on Decommissioning 

of Nuclear Facilities, which was published in 2002. For most environmental issues, the impact 

from decommissioning activities is considered small. 

D.2.19 Cumulative Impacts 

Comment: And very important when we’re looking and talking about the environmental impact 

statement, is that we also take into effect, into consideration, the cumulative impacts that folks 

have to deal with when we talk about pollution, when we talk about environmental 

contamination. ...And if you look at the Gulf Coast of Texas, it’s littered with chemical plants, it’s 

littered as well with refineries and ports, and huge inland ports as well that are situated for ships 

to be able to come in. So if we’re looking at ourselves here and in San Antonio, what is the 

whole of the impact that we’ve being exposed to? (0007-62 [Rendon, Genaro])

Comment: [I]f we look at the State of Texas, we rank number seven amongst countries in 

pollution. As one state, we’re surpassing what countries are producing in pollution. So we have 

to be looking at reducing that amount of pollution here within the State of Texas, reducing the 

impacts that communities are feeling by living around these polluting industries. (0007-63

[Rendon, Genaro])
Appendix D 

NUREG-1937 D-52 February 2011 

Response: NEPA requires the analysis of cumulative impacts in an environmental impact 

statement. The cumulative impacts associated with the construction and operation of the 

proposed Units 3 and 4 will be evaluated and the results of this analysis will be presented in 

Chapter 7 of the EIS. 

Comment: [T]he analysis of the Matagorda [STP] site never acknowledges or assesses the 

degree to which siting a new nuclear plant next to an existing plant might present potential 

problems. Thus, what might the impact of a leak or problem at the existing STP No. 1 and 2 

present during the construction or operation of No. [3] and 4? Could a problem at the new plant 

lead to a shut down or problem with the existing plants? (0003-21 [Reed, Cyrus])

Comment: Is there an environmental impact by placing so much power, and so much waste in 

the same physical location, subject to an increased likelihood that a natural, operational or 

terrorist attack could have an even larger impact than if a nuclear plant were to be located, for 

example, at the site in Limestone County? Is it safer, in other words, to separate an aging and 

new plant? (0003-22 [Reed, Cyrus])

Comment: When you consider that this plant would be -- if it goes through -- having 

construction right next door to an operating nuclear plant, you’re introducing circumstances that 

haven’t been seen before. (0007-32 [Hadden, Karen])

Comment: I think that FEMA should be present for a safety hearing and the Department of 

Homeland Security. And I would like to hear how all of those agencies are, in fact, working 

together to assure safety. This is no small thing to have a construction site next to an operating 

nuclear plant. It deserves close scrutiny. (0008-54 [Hadden, Karen])

Comment: We did not see anything that had to do with coincidental unit problems. If we have a 

problem on Unit 1 and 2 during construction on 3 and 4 what’s going to happen about that? If 

we have a problem on 3 and 4 during the operation of Unit 1 and 2 and it affects Unit 1 and 2, 

what will happen with that? This works very strongly in things like low-pressure turbines coming 

apart. They just rebuilt the low-pressure turbines. Why? They obviously weren’t really happy 

with its performance at that point, and that was done as a preventive measure. (0008-67 [Wagner, 

William])

Response: These comments address issues related to co-location of two or more nuclear 

power plants. Several aspects of these issues will be addressed in the DEIS. The DEIS will 

address the doses to construction workers from the existing units, and from Unit 3 after it starts 

operation. The DEIS will also address cumulative radiological impacts of normal operation and 

cumulative risks of severe accidents. Other aspects of these issues, which are addressed in the 

emergency plan that has been submitted as part of the application, are out of the scope of the 

environmental review and will not be addressed in the DEIS. 
Appendix D 

February 2011 D-53 NUREG-1937 

D.2.20 Need for Power 

Comment: Chapter 8 - the need for power - analyzes Texas-based information about the need 

for additional power in ERCOT, which covers the majority of Texas. While Sierra Club does not 

object to the use of ERCOT reports cited on 8.4-6 or 8.4-7, we would note the list is incomplete 

because it does not list reports which discuss other scenarios for the growth in overall and peak 

summer demand. Because we believe that ERCOT’s evaluation of power needs in Texas in 

itself is incomplete, we would suggest that the EIS conduct a much more balanced full-scale 

independent analysis. Specifically, the ERCOT evaluations cited by the applicant do not take 

into account significant regulatory and statutory changes which will increase the use of load 

demand management and energy efficiency as a result of legislative action taken in 2007 [i.e. 

HB3693]. [I]t is quite likely that the future of peak and load demand will look quite differently 

then that presented by the applicant. (0003-9 [Reed, Cyrus])

Response: The determination for the need for power within a given area is not under the 

NRC’s regulatory purview. When another agency has the regulatory authority over an issue, 

NRC defers to that agency’s decision. The NRC staff reviews the need for power analysis to 

determine if it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and 

(4) responsive to forecasting uncertainty. If the need for power evaluation is found to be 

acceptable, no additional independent review by the NRC is needed. 

Comment: In addition to these legislative and regulatory changes that will affect the need for 

power, several studies have come out over the last 18 months which should be assessed, as 

they present alternative demand scenarios based on the use of increased renewable energy, 

increased efficiency and increased demand response programs. (0003-10 [Reed, Cyrus])

Comment: NRG and CPS base their need for the plant on forecasts from ERCOT that may 

overstate the need for power, and therefore the need for STP 3 and 4. Indeed, it should be 

remembered at the end of 2006, ERCOT was stating that generation capacity would fall below 

the required reserve capacity of 12.5 percent potentially by 2008, only to later reassess this 

projection based on a smaller demand as well as the opening of several gas plants. The ER 

states that by 2016 ERCOT projects there will be a need for between 20,000 and 50,000 MWe, 

and that the capacity of STP 3 and 4 - as well as many other generation sources - are therefore 

needed. (0003-13 [Reed, Cyrus])

Comment: ER Chapter 9 states “NRG anticipates it would not be able to provide competitively 

priced power if it had to retain an extensive conservation and load modification incentive 

program” and further implies that demand management is not a form of baseload power. 

Nevertheless, this two paragraph analysis is not a true analysis of the potential for baseload 

demand management to provide power or make up for the need for additional power. The 

analysis of the ability of peak demand plants to replace baseload plants is superficial and does 

not incorporate the ability of different plants to be used in combination to provide power, such as 

the conjunctive use of solar, wind and natural gas as a way to provide power through peaking 

plants operating at different times of the day. (0003-17 [Reed, Cyrus])
Appendix D 

NUREG-1937 D-54 February 2011 

Comment: NRG has to prove there is a need for new energy. Their assessment of need is 

based on ERCOT projections of future energy demand in Texas. But, 1. The application ignores 

the effect energy efficiency and renewable energy will have in the future on demand. 2. Recent 

studies have shown that we could meet between 75-100% of Texas’s growth in demand using 

efficiency and renewable energy (“Role of Energy Efficiency and Onsite Renewables in Meeting 

Energy and Environmental Needs in the Dallas/Fort Worth and Houston/Galveston Metro 

Areas”. R. Neal Elliott and Maggie Eldridge. American Council for an Energy-Efficient Economy, 

September 2007 Report Number E078; (0010-20 [Public Citizen, Texas Office] [Smith, Tom])

Comment: Federal and state-mandated energy efficiency and renewable energy goals do not 

appear to be factored into the energy needs assessment. The EPACT of 2007 mandated a ban 

on incandescent bulbs, increased air conditioning efficiency standards and standards of other 

appliances, and other efficiency reductions that are not counted in NRG’s analysis of need. Nor 

are the provisions of HB 3693, passed by the Texas Legislature in 2007, factored into the 

energy needs assessment. The bill doubled the goal of the state of reducing by 10% per year 

the growth in demand for electricity to a minimum of 20%. A study completed during licensing 

period showed efficiency may result in as much as 50% of the growth in demand. (0010-21

[Public Citizen, Texas Office] [Smith, Tom])

Comment: As to CPS’s need for power the analysis contains an interesting logical flaw. It 

claims that an analysis of need is required for traditional utilities, such as CPS, but not for 

merchant companies such as NRG. It then further claims that since CPS has sold power at 

wholesale, and will continue to do so in the future, it does not have to do a needs analysis. This 

logic is imperfect. CPS is a municipal utility, and has not opted into competition, and is limited to 

incidental sales to customers beyond its traditional service area, so it should have completed a 

need for power analysis. CPS ignores the study done by KEMA in 2004 for CPS San Antonio 

that shows that over 1220 MW of baseload savings could be obtained at costs less than 2 cents 

per kilowatt hour (pg 3.1) or far less than the 6.5 cents per kilowatt than the cost of building and 

operating the plant. (0010-22 [Public Citizen, Texas Office] [Smith, Tom])

Response: Affected states or regions may prepare a need for power evaluation and 

assessment of the regional power system for planning or regulatory purposes. A need for 

power analysis may also be prepared by a regulated utility and submitted to a regulatory 

authority, such as a state public utility commission. However, the data may be supplemented by 

information from other sources. The determination for the need for power is not under NRC’s 

regulatory purview. When another agency has the regulatory authority over an issue, NRC 

defers to that agency’s decision. The NRC staff will review the need for power and determine if 

it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to 

forecasting uncertainty. If the need for power evaluation is found to be acceptable, no additional 

independent review by the NRC is needed. The information provided in this comment will be 

considered to determine whether it significantly affects the forecast on which the applicant relied 

for its need for power analysis. 
Appendix D 

February 2011 D-55 NUREG-1937 

Comment: Sierra Club believes that an EIS must more independently assess these claims 

[need for power], and also assess other projects currently being planned in Texas, including 

new wind generation, plans for solar plants, energy efficiency and demand response program, 

coal plants and new natural gas plants. (0003-14 [Reed, Cyrus])

Comment: Our assessment, and along with the Energy Reliability Council of Texas basically 

says we need power, we need generation, we need new generation on line and we need to 

retire old units that are in operation, we need new power generation in Texas, we need new 

base load generation in Texas. (0007-138 [McBurnett, Mark])

Comment: But the fundamental question is, do we need this plant, and will it be completed on 

time? And this history of this has not been clear. The last time we tried to build a plant in this 

community, it took eight years longer than necessary. And what we’re seeing here in this 

particular analysis that has been presented to you all, is that the applicant says we need the 

plant for baseload. And it’s impossible to really utilize other resources like energy efficiency and 

renewable energy as base load. (0007-27 [Smith, Tom])

Comment: I wanted to make sure that the NRC is aware that legislation was passed last 

legislative session... that expands the amount of energy that investor-owned utilities, like NRG, 

are required to get from energy efficiency programs that all of us, frankly, pay for. And so I 

wanted to make sure that when you do the analysis of whether this power is needed, that we 

look at those new requirements on energy efficiency, because I think everyone agrees we can 

save money for our consumers, and generate more power simply by saving energy. (0007-43

[Reed, Cyrus])

Comment: The Harris and Galveston County Council of Governments, which is 13 counties, 

including Matagorda County, recently started last year making plans for an additional 2.5 million 

people coming to our area by year 2015. That’s a footprint of Los Angeles, California, coming 

on a 13-county area. Matagorda County is going to get its share of those people. We’re having 

to plan for it now. But the main thing is the power that’s needed for our state in this area is 

something we’ve got to work on. (0008-19 [Morton, Joe])

Comment: I want to congratulate CPS Energy for their forward-looking windtricity and 

conservation programs. We’ve heard this afternoon people talk that we need a mix of 

conservation, energy saving, renewal resources, and CPS Energy is providing that to us in the 

San Antonio area. ...But even with this, even with the rest of the citizens doing this in San 

Antonio, I don’t think this is surely enough to meet the future needs of electricity in San Antonio 

and south Texas. (0008-25 [Kale, Stephen])

Comment: Secondly, the governments of San Antonio and Bexar County are on record that 

they desire -- strongly desire continued economic growth in the city -- in Bexar County and in 

the city. CPS Energy has determined that timely additional electrical generation capacity is 

required for this growth in south Texas. So I submit that the proposed action and alternatives 

must be able to meet these requirements. (0008-27 [Kale, Stephen])
Appendix D 

NUREG-1937 D-56 February 2011 

Comment: It has not been shown that there is a need for this expansion. (0009-3 [Lindsey, Joy])

Comment: The governments of San Antonio and Bexar County are on record that they desire 

continued economic growth for the City and the County. CPS Energy has determined that timely 

additional electricity generation capacity ls required for economic growth in South Texas. The 

proposed action and alternatives must be able to meet these requirements. (0014-2 [Kale, 

Stephen])

Response: Affected states or regions may prepare a Need for Power evaluation and 

assessment of the regional power system for planning or regulatory purposes. A Need for 

Power analysis may also be prepared by a regulated utility and submitted to a regulatory 

authority, such as a State Public Utility Commission. However, the data may be supplemented 

by information from other sources. The determination for the need for power is not under NRC’s 

regulatory purview. When another agency has the regulatory authority over an issue, NRC 

defers to that agency’s decision. The NRC staff will review the Need for Power and determine if 

it is (1) systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to 

forecasting uncertainty. If the Need for Power evaluation is found to be acceptable, no 

additional independent review by the NRC is needed. 

D.2.21 Alternatives - Energy 

Comment: The global climate change question discussed above obviously calls into question 

using any fossil fuel central generators as an alternative. There are numerous other alternatives, 

however, that are safe and far more benign environmentally. (0002-29 [Sinkin, Lanny])

Response: The EIS will be prepared in accordance with 10 CFR 51.75(c). Alternative energy 

sources will be considered in the EIS and the potential global climate change impacts of fossil 

fuel generation stations will also be addressed. 

Comment: One of the applicants, CPSEnergy, has reclassified energy conservation as power 

generation. This essentially treats energy conservation approaches the same as baseload.

(0002-30 [Sinkin, Lanny])

Comment: The alternatives analysis should examine at least the following: 1. Energy efficiency 

and conservation, such as a. changing building codes that are leading to more energy efficient 

buildings, b. retrofitting of existing buildings that is lowering their energy consumption c. the 

redesign of appliances that is leading to replacing older units with more energy efficient units d. 

the “small is beautiful” alternatives, such as solar powered attic fans e. existing studies by 

utilities in the service area regarding possible reduction of energy demand through conservation 

and efficiency. (0002-33 [Sinkin, Lanny])

Comment: [B]ecause CPS is an applicant, their own study, which shows the potential to 

economically obtain 1,220 MW of Demand Savings and Technically 1,935 MWs by 2014 alone 

through a suite of energy efficiency measures - approximately the energy output of one of the 

units and approximately 40 % of the total capacity of both plants - this ability to obtain the power 
Appendix D 

February 2011 D-57 NUREG-1937 

they say they need through a cheaper and more alternative must be assessed as part of the 

EIS. (0003-11 [Reed, Cyrus])

Comment: A CPS commissioned study, this was mentioned before, the CIMA report, 

concluded that 1200 megawatts of energy could be saved through stronger building codes and 

retrofitting programs. That’s 80 percent of the half of STP reactors 3 and 4 energy that we are 

going to be supposedly getting. And that report is nowhere mentioned in this environmental 

report. So this STP application needs to include a real analysis of alternatives, and all the 

alternatives for meeting San Antonio’s energy needs. (0007-100 [Cushing, Lara])

Comment: In trying to look through the thousands of pages of this permit application, I realize 

that the entire scope of the environmental review was based on, and this is a quote, “that the 

purpose of the project is to sell base-load power on the wholesale market.” And the only 

alternatives to this project that were looked at were alternatives for meeting that mission. But the 

fact is that that is not CPS Energy’s mission. CPS Energy’s mission, as a public utility, is to 

provide for the energy needs of San Antonio, and the other small areas that it covers and 

serves. (0007-89 [Acevedo, NK])

Comment: CPS has classified efficiency and conservation measures as a source of generating 

power. And since it’s done that, those need to be given over best analysis in the environmental 

report. (0007-90 [Cushing, Lara])

Comment: I believe CPS should be smarter than nuclear power plants, and they believe that 

we should be the green generation that think about the future and our health, but also the future 

generations to come. That is why CPS should invest in solar and wind energy. (0007-98 [Garcia, 

Sandra])

Comment: CPS’s mandate is to serve the energy needs of the greater San Antonio area, and 

its Strategic Energy Plan identifies energy efficiency as one of its four main tenets. According to 

its publications, CPS Energy is “so committed to this goal that energy efficiency is treated as a 

new resource for electrical generation.” As such, energy efficiency programs are a directly 

comparable alternative to the electricity that will be generated from STP 3 & 4 and need to be 

given full consideration in the EIS. (0018-3 [Cushing, Lara])

Comment: A 2004 CPS-commissioned study by KEMA Inc. concluded that it was cost effective 

for CPS to save 1,200 mW through stronger building codes and retrofitting programs, nearly as 

much as CPS’s 1,350 mW share of STP 3 &4’s generating capacity, on a comparable if not 

shorter time scale. Neither this report nor a more recent analysis of efficiency is presented in the 

permit application. With houses that waste more energy than any other large city in Texas, San 

Antonio has a huge potential for energy savings from weatherization programs that would 

contribute to the local economy by lowering family’s energy bills and creating “green collar” jobs 

in San Antonio. (0018-4 [Cushing, Lara])
Appendix D 

NUREG-1937 D-58 February 2011 

Response: The DEIS will be prepared in accordance with 10 CFR 51.75(c) and will include a 

discussion of energy alternatives. Energy conservation and efficiency will be discussed as an 

energy alternative not requiring new generating capacity. Existing conservation programs will 

also be considered as part of the need for power analysis in Chapter 8 of the DEIS. 

Comment: The alternatives analysis should look at the rate at which alternatives are coming 

into use and project both what is likely and what is possible. A secondary question to be 

anwered is: Taking the same funds as will likely be spent on the nuclear plant and investing 

those funds in direct or subsidized implementation of alternative strategies, could the same 

amount of energy be saved and/or generated with far less environmental impact? A related 

question is: Would investment in the alternative technologies buy additional time before new 

generating capacity would be needed, allowing for still further innovative alternatives and 

improvements in existing alternatives? (0002-31 [Sinkin, Lanny])

Comment: Alternative energy, such as a. major breakthroughs in solar energy that are 

lowering the per watt cost to a level competitive with other sources b. new developments in 

storage which would permit solar and wind energy to be included as base load plants c. 

scenarios in which solar, wind, biomass and other sources provide most of the baseload with 

the available natural gas plants filling in as needed. d. wind energy potential, acknowledging 

that some environmental impacts, such as the impact on birds, must be addressed e. wave 

energy f. temperature differential energy extraction (ocean) g. biomass as baseload h. 

previously suppressed technology, such as Tesla coils This list is far from comprehensive.

(0002-34 [Sinkin, Lanny])

Comment: The most obvious irreversible and irretrievable commitment of resources is the 

money that will be spent on building the nuclear plants that will not be available for 

implementation of alternative energy strategies. Once begun, nuclear power plants will demand 

continuing investment and can be expected to absorb a far higher level than presented when 

the project is being sold to the utility and public. The analysis of this irreversible and irretrievable 

commitment of financial resources should evaluate the impact of that commitment on the ability 

to pursue implementation of alternative energy strategies, such as conservation, efficiency, 

solar, wind, and biomass. (0002-36 [Sinkin, Lanny])

Comment: [A]n EIS should not only assess the “no action”, “building nuclear plant at Bay City” 

or “building it somewhere else,” but assess other projects that NRG and CPS could be pursuing 

to meet their need to sell wholesale power in the first case, and meet the energy demands of its 

residents in the second. [T]he 2004 KEMA study commissioned by CPS sets out an alternative 

path for meeting the 40 percent of the plant that CPS has announced they are seeking a COL 

for. This should be assessed as part of an EIS. (0003-15 [Reed, Cyrus])

Comment: If CPS Energy could achieve a better, more cost-effective and environmentallymore-friendly alternative to the proposed nuclear plant, then the EIS should examine that 

possibility. (0003-5 [Reed, Cyrus])
Appendix D 

February 2011 D-59 NUREG-1937 

Comment: A coal fire power plant spits out more than four times as much radiation as the 

average nuclear plant does because of contaminants in the coal. In fact, you could generate 

more power from coal by removing uranium from it and thorium and burning it in nuclear power 

plants. There’s less environmental damage. The EPA estimates that 30,000 Americans die 

prematurely every year from the effluent from coal-fired power plants. (0008-104 [Dykes, Ed])

Response: The no-action alternative, as well as, alternative energy sources will be considered 

in the EIS. The analysis of alternatives in the EIS will be conducted in accordance with 

Section 102 of the National Environmental Policy Act and 10 CFR 51.75(c). 

Comment: [E]ach application must be carefully reviewed, and all alternatives to the siting of 

the plants and indeed to nuclear power itself must be considered as part of the EIS process.

(0003-2 [Reed, Cyrus])

Response: NRC staff carefully reviews each application it receives by utilizing an acceptance 

review process to ensure all required components are provided by the applicant. Each 

application then receives additional scrutiny during the safety and environmental review 

processes. Examining alternative energy sources and alternative sites is a function of the 

environmental review process and these topics will be discussed in the EIS. 

Comment: In the case of NRG, nuclear power is not the only option it has as an energy 

provider. They could - and are - pursuing development of coal plants, but could also be 

examining demand response and energy efficiency - which because of incentives can earn a 

provider a profit, on-site and off-site solar, wind, geothermal, biomass and other ways to 

generate a similar amount of power. (0003-16 [Reed, Cyrus])

Comment: There is no analysis of energy efficiency programs, and the solar analysis is based 

upon 2003 estimates of a cost of 0.108 and 0.187 per kilowatt hour, which are well above 

recently developed solar projects in California and Nevada. Indeed, the City of Austin has been 

receiving bids for proposed solar off-site plants that are on the low-end of this range, and recent 

technological improvements forecast lower solar energy costs over the next five years. An EIS 

must provide a much more extensive analysis of these alternatives than that provided in the ER.

(0003-18 [Reed, Cyrus])

Comment: While Chapter Nine does provide some analysis of coal-fired and natural gas 

plants, and concludes that they are not preferable to nuclear power because largely of the air 

quality impacts, such a conclusion does not take into account how that compares with the longterm impacts of uranium mining and radioactive waste. Indeed, there is no real comparison 

between the three choices other than the conclusion that air quality impacts mean nuclear 

power is preferable. For example, coal, gas - and the alternatives that are never really 

considered such as energy efficiency, biomass, solar and wind - or some combination of all - 

are never assessed for the fact that they do not produce radioactive waste in large quantities.

(0003-19 [Reed, Cyrus])
Appendix D 

NUREG-1937 D-60 February 2011 

Comment: In the areas of alternative energy, the EIS should also consider major commitments 

being made to accelerate the development of alternative, renewable energy. For example, the 

commitment of Silicon Valley to solar cells is discussed in “Silicon Valley Turns its Face to the 

Sun” in the New York Times on February 17, 2008. Google intends to spend hundreds of 

millions of dollars to hire engineers and other experts to develop solar, wind, geothermal, and 

other renewable resources. Austin Chronicle, February 8, 2008 at 31. (0004-1 [Sinkin, Lanny])

Comment: Well, let me just say it once again, so it’s absolutely clear what we’re in favor of. 

Conservation, renewables and energy efficiency. (0007-118 [Singleton, Robert])

Comment: I moved to Matagorda County in 1997 and I have lived very peacefully with STP 

down the road, and I have felt very safe. But my problem is, is that I do have a concern about 

building more nuclear power plants, as opposed to looking for alternative choices, other green 

choices. Of course, we have this huge yellow ball in the sky that burns us to death every 

summer, actually from March until like November, which is an endless source of power. (0007-

132 [Schwank, Eleanor])

Comment: As a matter of fact, yes, we need solar, we need wind, we need conservation, we 

need nuclear, and we need clean coal. We need all of those to meet our energy demands. 

Energy is what drives the economy of Texas, it’s what drives the economy of the world. It’s 

important, we need to plan for that energy. If we don’t, we’ll go, as an economy, down the hill.

(0007-139 [McBurnett, Mark])

Comment: Yet there are three studies not referenced in this most recent submission by NRG 

to you all that have been done in the last several years. One on San Antonio in particular that 

said we could save more than 1200 megawatts, far more than CPS’s share of this plant, if we 

did energy efficiency at costs less than building this plant. Another by Optimal Energy that said 

that the state could save 80 percent of the energy -- the growth in demand for energy that this 

plant is designed to meet. And yet another most recently by AC Triple E indicating that we could 

save between 75 percent of the growth in demand for energy, and 101 percent of the growth in 

demand for energy in either the Houston or Dallas areas respectively, by using energy efficiency 

as our first resource, along with other resources like combined heating and power, and 

renewable energies. (0007-28 [Smith, Tom])

Comment: And I also think that if we’re going to really analyze the power demands of -- that 

may be needed by these new plants, we’ve also got to look at the cities like San Antonio, like 

Austin, that may be investing in the plant and see -- look at how they meet their energy 

demands and whether they could be getting their energy in a cheaper, cleaner and faster 

manner. (0007-44 [Reed, Cyrus])

Comment: -- let’s make sure we look at all the choices. If the choice is this new nuclear plant, 

or concentrated solar power and efficiency, which really makes the most sense. And I hope, 

frankly, that NRG and the other investors are looking at all the options that are out there on the 

table, some of which I think could be used in Matagorda County. (0007-58 [Reed, Cyrus])
Appendix D 

February 2011 D-61 NUREG-1937 

Comment: Now I understand that our energy needs here in Texas are growing. However, there 

are alternatives to nuclear power here in Texas, which are cleaner, more affordable, and more 

sustainable ways of powering our needs for the future. Alternatives include energy efficiency, 

solar power, wind, combined heat and power, and more. In addition, just not too long ago 

Optimal Energy discovered that 80 percent of our energy needs could be met by these 

technologies. (0007-87 [Castro, Geoffrey])

Comment: We can also talk about alternative power and how there’s no disposal plant for solar 

collectors. It might surprise a lot of you to understand that the incredible chemical mix that’s in 

solar panels, including arsenic. The burden on the environment with arsenic, which, by the way, 

has an infinite half-time -- not a 100,000 years, but infinite. (0008-105 [Dykes, Ed])

Comment: If you look at the carbon footprint of the life cycle of the nuclear power’s life cycle 

from the mining of the uranium all the way through the disposal of the waste that carbon 

footprint is the equivalent and the same footprint for solar and for wind and for hydro. (0008-127

[Shepherd, Joe])

Comment: [T]he land for these reactors [units 3 and 4] exists. Installation of the equivalent 

capacity [of solar and/or wind alternatives] -- and, again, I think when these alternatives and 

proposed actions are evaluated they’ve got to be done on an equivalent basis. So I think that 

installation of alternatives has got to be the equivocal capacity to what the proposed action for 

the nuclear plants will be. (0008-29 [Kale, Stephen])

Comment: I’m thinking primarily of wind and solar [energy alternatives], which would I think 

require large areas of land -- primarily the agrarian areas -- out in west Texas. I think the EIS 

needs to determine whether installation of these alternatives -- and I’m thinking about Fort 

Stockton -- the wind farms out there -- of Big Spring just off of I-20, and if you go up to 

Sweetwater and over across I-20 to Spider there are hundreds of windmills up there. So the 

EIS I think needs to evaluate installation of either wind, solar, whatever, and determine if there 

are any impacts -- primarily impacts on land usage, ecology, wildlife, other natural resources.

(0008-30 [Kale, Stephen])

Comment: And as a third generation Matagorda County resident I understand the concerns 

and -- that we have about nuclear power. But I also understand the huge drawbacks that we’re 

having today with our continued overuse of fossil energy. We as a county, of course, a state and 

nation need to look at solar, wind, bio, and, of course, nuclear energy for our future. (0008-31

[Head, Bobby])

Comment: This area has offshore wind, and there is a small town mayor in west Texas named 

Sherry Phillips. I heard her say the same things -- that when wind energy came to their 

community for the first time their kids could come home. They could live and work in the 

community. They could run cattle underneath the wind turbines. That’s a possibility for this 

community as well. And I urge NRG to seriously consider that path. (0008-50)
Appendix D 

NUREG-1937 D-62 February 2011 

Comment: Why do we consider such a costly, potentially destructive, and unnecessary project 

instead of employing more benign solutions such as conservation, wind, and solar? (0009-7

[Lindsey, Joy])

Comment: I am writing to express my concern about the proposed expansion of the South 

Texas Nuclear Power plant (Federal Register Vol.72, No. 245/ Friday, December 21, 

2007/Notices Page 72775). As a resident of Houston, just to the north of this plant, I would like 

to know why this expansion has been proposed rather than expansion of our state’s enormous 

potential for wind energy. (0011-1 [Russell, Nancy])

Comment: Texas needs more non-polluting sources of electricity such as wind and solar. 

Utilities also should promote energy conservation as a way to avoid new construction of power 

plants. (0012-6 [Edwards, Nancy])

Comment: The land for the proposed reactors exists. Installation of the equivalent capacity of 

solar and/or wind alternatives will require immense areas of agrarian lands in West Texas. The 

EIS should evaluate whether installation of equivalent capacity of these alternatives would 

negatively impact land use, ecology. wild life, or other natural resources. (0014-4 [Kale, Stephen])

Comment: The clear alternative to coal and nuclear power plants is renewables: wind, sun, 

water, and geothermal. These technologies are on the horizon. Venture capitalists are presently 

investing in the development of the necessary technology to make these renewable sources of 

energy practical on a nationwide basis. According to a recent analysis by The National 

Renewable Energy Laboratory (NREL) - the country’s primary research and development facility 

for renewable technology - “the entire U.S. electricity demand could technically be met by 

renewable energy resources by 2020. In the longer term, the potential of domestic renewable 

resources is more than 85 times current U.S. energy use.” (0015-8 [Williams, Mina])

Comment: [A]ccording to the November 5, 2007, U.S. News and World Report cover story, 

“Power Revolution,” one of the most promising renewable energy sources is geothermal, which 

taps into Earth’s steady, reliable warmth. According to this article, recent studies show that 

techniques developed in the oil industry can be used to release geothermal energy three or 

more miles underground. (0015-9 [Williams, Mina])

Comment: We are concerned by the inadequate inclusion of the public in the decision by our 

public utility CPS Energy to construct two new nuclear reactors at the South Texas project 

(STP) and the total lack of an assessment of alternative ways to meet San Antonio’s energy 

needs in the Environmental Impact Statement (EIS) as required under the National 

Environmental Policy Act. As the ratepayers that will finance this project, we have a right to a full 

and transparent assessment of alternatives. (0018-1 [Cushing, Lara])

Comment: The EIS needs to include a thorough analysis of alternatives specific to meeting 

San Antonio’s energy needs that includes proactive weatherization and retrofitting programs, 

stronger building codes, combined heat and power or cogeneration strategies, renewable 

energy production, and combinations thereof. This analysis needs to receive as much 
Appendix D 

February 2011 D-63 NUREG-1937 

consideration in terms of technical expertise, time and financial investment as the proposed new 

nuclear reactors have received. (0018-5 [Cushing, Lara])

Comment: STP 3 & 4 would be a huge financial investment for San Antonio ratepayers and will 

with all likelihood greatly overrun initial cost and time projections, preventing CPS from making 

large scale investments in efficiency and a renewable energy future. We deserve a full analysis 

of those different futures, free of radioactive waste, the pollution associated with uranium mining 

and enrichment, weapons proliferation, and the danger to public health and the environment 

from leaks and accidents at STP, before this project progresses any further. (0018-6 [Cushing, 

Lara])

Response: The EIS will be prepared in accordance with 10 CFR 51.75(c). Alternative energy 

sources, including energy conservation and renewable energy sources, will be considered in 

<Chapter 9 of> the EIS. 

D.2.22 Alternatives - System Design 

Comment: [T]he large cooling pond you see at South Texas, that 7,000-acre reservoir, is used 

for cooling the main turbine. It’s the main heat sink for the plant as the plant is in operation. 

Provided in Unit 1 and 2 is a pond for providing for emergency cooling should that be required. 

Unit 3 and 4 will actually have a cooling tower for emergency cooling for what we call the 

ultimate heat sink. ... it’s not one of these monster hyperbolic towers like you see in all the 

pictures that one associates with a nuclear plant. These are small towers, more akin to what 

you see out behind a large commercial building that provided for air conditioning. (0008-122

[McBurnett, Mark])

Response: This comment provides some information regarding the cooling system in use for 

STP Units 1 and 2 and the Ultimate Heat Sink cooling towers proposed for STP Units 3 and 4. 

No response is needed. 

Comment: They have a giant cooling pond out there. Depending on which part of that COLA 

you read, they’re either going to use cooling towers -- four-strap cooling towers on Units 3 and 4 

or they’re going to use the cooling pond itself. I’m not sure which one it is. (0008-73 [Wagner, 

William])

Comment: Speaking about the cooling link, what part of makeup requirements are going to be 

for both instances or decide which one you’re going to use and tell us that one. (0008-76

[Wagner, William])

Response: The Main Cooling Reservoir serves as the heat sink during normal operation of 

STP Units 1 and 2 and would operate similarly for STP Units 3 and 4. The make-up water for 

the reservoir is obtained from the Colorado River. The cooling towers for STP Units 3 and 4 

would be part of the Ultimate Heat Sink that would provide cooling for safety-related systems 

and components during normal and accidental conditions. The cooling water required for the 

Ultimate Heat Sink cooling towers would be stored in basins beneath the towers and make-up 

water to these basins would be provided by on-site water storage basins that contain 30-day 
Appendix D 

NUREG-1937 D-64 February 2011 

supply of make-up water. Make-up water to the on-site water storage basins would be provided 

by groundwater. A detailed description of the cooling system for STP Units 3 and 4 will be 

presented in Chapter 3 of the DEIS. 

D.2.23 Alternatives - Sites 

Comment: The analysis of choosing an alternative site - such as NRG’s land owned in 

Limestone County - concludes that the existing Matagorda County [STP] site is preferable but is 

based largely on the possibility that additional transmission lines would be needed at the 

Limestone County site. The analysis seems too simplistic. (0003-20 [Reed, Cyrus])

Response: The DEIS <Chapter 9> will include a more detailed analysis of siting the proposed 

nuclear generating units at alternative sites located within the applicant’s region of interest. 

D.2.24 Benefit-Cost Balance 

Comment: [B]ecause the City of Austin hired a consultant to study the NRG and CPS proposal 

and found that the risk of investing in the application process outweighed the benefit because of 

the potential for the cost of the construction and licensing to exceed the estimates provided by 

the applicant by $1 billion, this analysis must be included as part of the discussion of 

alternatives. (0003-12 [Reed, Cyrus])

Comment: Failure to provide financial information needed for true alternative analysis: the 

applicant has asked for and the NRC has granted an exemption to disclosing basic financial 

information about the proposal. Thus, in Chapter 1 of the COL application, tables [1.3-1 through 

1.3-9] have been declared proprietary and thus unavailable for public review. The reason that 

project cost, construction funds, O & M costs and plant performance are an environmental issue 

is because NEPA requires an analysis of alternatives to the proposed action, and without cost 

figures and analysis of the construction and O & M costs, it is impossible to know if the energy 

demand needed could be more cost-effectively be achieved through other means, or with 

construction of a nuclear plant at another site. (0003-4 [Reed, Cyrus])

Comment: It is also difficult to assess whether the plant would generate the monies needed for 

ongoing repairs, the ability to respond to emergency situations, and the ability to provide 

decommissioning costs without a financial analysis. Even assuming that EPA and NRC have 

the needed financial information provided by the applicants to assess these issues, it will be 

difficult as a member of the public to add to the discussion through the draft EIS process without 

making at least basic financial information disclosed. (0003-6 [Reed, Cyrus])

Comment: The lack of financial information - at least publicly available - also makes it difficult 

to assess Chapters 8, 9 and 10 of the applicants Environmental Report. (0003-8 [Reed, Cyrus])

Comment: [The EIS] also needs to incorporate the true costs of nuclear power. And if it did, 

there’s no way that nuclear power would come out on top. There’s reasons why no nuclear 

reactors -- the construction of nuclear reactors has not been permitted in 29 years, despite that 
Appendix D 

February 2011 D-65 NUREG-1937 

fact that it’s the most government subsidized energy source of all. And one of the reasons why 

the true costs of nuclear are never evaluated is because NRC only looks at a small price. The 

fact is that the construction of new generators is -- and the speculation about the construction of 

new generators, is already driving up the price of uranium, which means communities are 

fighting tooth and nail right now to prevent new uranium mining permits from being issued in 

South Texas. That is an environmental impact of the South Texas Project. (0007-92 [Cushing, 

Lara])

Comment: We get no cost figures out of that COLA -- none. Everything is proprietary. That’s 

nonsense. I can get cost figures on ones that they haven’t even put applications in on. And in 

some cases they’ve already decided it costs too much. The one thing that would kill this -- and it 

won’t be guys like me -- is money. And if we don’t know what’s going on we’ll never know, will 

we? (0008-86 [Wagner, William])

Comment: Nuclear power is not competitive with other forms of power generation and requires 

taxpayer dollars to subsidize. (0009-2 [Lindsey, Joy])

Comment: Nuclear power still requires Federal subsidies to make it competitive with other 

forms of power generation. (0012-3 [Edwards, Nancy])

Comment: As one leading advocate for green technology puts it: “Any state that allows the 

construction of new nuclear power plants in the face of today’s global industrial competition and 

financial turmoil will be committing economic suicide.- (Harvey Wasserman, Testimony to the 

Public Utilities Commission of the Ohio House, January 30, 2008). (0015-11 [Williams, Mina])

Comment: Nuclear power plants are not cost effective. Nuclear power plants have required 

exorbitant cost overruns, are dependent on massive federal subsidies, and need continual 

expensive maintenance. Cost to taxpayers is extreme. (Southwest Workers’ Union April 25, 

2007). (0015-4 [Williams, Mina])

Response: The applicant is authorized by 10 CFR 2.390 that trade secrets and commercial 

and financial information be held by NRC as privileged or confidential, subject to certain 

procedural controls allowing access to the information. The Commission also determines 

whether the right of the public to be fully apprised as to whether the bases for and effects of the 

proposed action outweighs the demonstrated concern for protection of a competitive position, 

and whether the information should be withheld from public disclosure. The NRC has 

determined that the requested financial information shall be held as confidential. The 

comparison of alternatives in the DEIS is an environmental comparison, not a financial one. 

Comment: The intergenerational aspect of producing high level waste for every generation 

coming after us so that we can have supposedly cheaper electricity should be a part of the 

analysis of unavoidable impacts of pursuing the project. (0002-25 [Sinkin, Lanny])

Comment: You know, as a young person I wonder why we are putting so many money and 

energy into this when in the last 50 years the nuclear problems have not even been solved.

(0007-73 [Lopez, Diana])
Appendix D 

NUREG-1937 D-66 February 2011 

Response: The DEIS will discuss the provisions for the long-term storage of spent fuel. The 

NRC’s Waste Confidence Rule, found in 10 CFR 51.23, states: The Commission has made a 

generic determination that, if necessary, spent fuel generated in any reactor can be stored 

safely and without significant environmental impacts for at least 30 years beyond the licensed 

life for operation (which may include the term of a revised or renewed license) of that reactor at 

its spent fuel storage basin or at either onsite or offsite independent spent fuel storage 

installations. The rule covers new reactors and applies to the staff’s review of an early site 

permit or a combined license application. The Atomic Safety and Licensing Board presiding 

over the proceeding on the Grand Gulf early site permit application affirmed that the Waste 

Confidence Rule and its subsequent amendments clearly include waste produced by a new 

generation of reactors. 

Comment: Given that the applicant in the application makes it clear they will rely on the federal 

Department of Energy guarantees to peak interest in capital investment markets, the financing 

of the project would seem a reasonable area to be investigated as part of the EIS. If the 

financing for the project does not work, there is the potential to have the project stalled, which 

could have environmental impacts. (0003-7 [Reed, Cyrus])

Response: The benefit-cost balance for the project will rely on the best available estimate of 

project timing and duration and will note any uncertainties in the analysis. 

Comment: CPS provides my residential electricity at a cost much lower than the national 

average. My suspicion is that that’s due in a large part to the operation of the nuclear plants. My 

own residence bill is about $35 a month lower than this national average. 35 bucks a month 

doesn’t sound like much, but over the course of a year I think that’s a pretty good piece of 

change. So I think that the proposed action and the alternatives need to consider this and be 

able to meet this type of a requirement. If they can’t then the EIS should go into the impacts -- 

the negative impacts – socio-economic impacts on the residents and the businesses in San 

Antonio. (0008-28 [Kale, Stephen])

Comment: CPS Energy provides residential electricity at a cost much lower than the national 

average. My own residence bill is about $35 a month less than the national average. The EIS 

should evaluate whether the proposed action and alternatives will improve or retain this low 

cost, and if not evaluate negative socioeconomic impacts. (0014-3 [Kale, Stephen])

Response: The purpose of the environmental impact statement is to disclose potential 

environmental impacts of building and operating of the proposed nuclear power plant. The 

determination for the impact of building and operating a nuclear power plant on retail power 

rates is not under NRC’s regulatory authority. 
Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

February 2011 E-1 NUREG-1937 

Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

As part of the U.S. Nuclear Regulatory Commission (NRC) review of STP Nuclear Operating 

Company (STPNOC) application for combined licenses (COLs) for proposed Units 3 and 4 at 

the South Texas Project Electric Generating Station (STP), the NRC and the U.S. Army Corps 

of Engineers (Corps) (together referred to as the “review team”) solicited comments from the 

public on the draft environmental impact statement (EIS). The draft EIS was issued in March of 

2010. A 75-day comment period began on March 26, 2010, when the U.S. Environmental 

Protection Agency (EPA) issued a Federal Register Notice of Availability (75 FR 14594) of the 

draft EIS to allow members of the public to comment on the results of the environmental review. 

As part of the process to solicit public comments on the draft EIS, the review team: 

• Placed a copy of the draft EIS at the Bay City Public Library, 

• Made the draft EIS available in the NRC’s Public Document Room in Rockville, Maryland, 

• Placed a copy of the draft EIS on the NRC website at www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1937/, 

• Provided a copy of the draft EIS to any member of the public who requested one, 

• Sent copies of the draft EIS to certain Federal, State, Tribal, and local agencies, 

• Published a notice of availability of the draft EIS in the Federal Register on March 25, 2010 

(75 FR 14474), 

• Filed the draft EIS with the U.S. Environmental Protection Agency, and 

• Held two public meetings on May 6, 2010, in Bay City, Texas. 

Approximately 175 people attended the public meetings and numerous attendees provided oral 

comments. A certified court reporter recorded these oral comments and prepared written 

transcripts of the meeting. The transcripts of the public meetings were published on May 24, 

2010, as part of the public meeting summary (Agencywide Documents Access and 

Management System [ADAMS] Accession Number ML101540288). In addition to the 

comments received at the public meeting, the NRC received letters and e-mail messages with 

comments. 
Appendix E 

NUREG-1937 E- 2 February 2011 

The comment letters, e-mail messages, and transcripts of the public meeting are available in 

ADAMS. ADAMS is accessible at http://www.nrc.gov/reading-rm.html. Persons who do not 

have access to ADAMS or who encounter problems in accessing the documents located in 

ADAMS should contact the NRC’s Public Document Room reference staff at 1-800-397-4209 or 

301-415-4737. The ADAMS accession numbers for the letters, e-mail messages, and 

transcripts are provided in Table E-1. 

E.1 Disposition of Comments 

Each set of comments from a given commenter was given a unique correspondence identifier, 

allowing each set of comments from a commenter to be traced back to the transcript, letter, or 

e-mail in which the comments were submitted. 

After the comment period concluded, the review team considered and dispositioned all 

comments received. To identify each individual comment, the team reviewed the transcript of 

the public meeting and each letter and e-mail received related to the draft EIS. As part of the 

review, the review team identified statements that it believed were related to the proposed 

action and recorded the statements as comments. Each comment was assigned to a specific 

subject area, and similar comments were grouped together. Finally, responses were prepared 

for each comment or group of comments. 

Some comments addressed topics and issues that are not part of the environmental review for 

this proposed action. These comments included questions about NRC’s safety review, general 

statements of support or opposition to nuclear power, and comments on the NRC regulatory 

process in general. These comments are included, but detailed responses to such comments 

are not provided because they addressed issues that do not directly relate to the environmental 

effects of this proposed action and are, thus, outside the scope of the National Environmental 

Policy Act (NEPA) review of this proposed action. Many comments, however, specifically 

addressed the scope of the environmental review, analyses, and issues contained in the draft 

EIS. 

Table E-1 provides a list of commenters identified by name, affiliation (if given), comment 

number, and the source of the comment. 
Appendix E 

February 2011 E-3 NUREG-1937 

Table E-1. Individuals Providing Comments

Commenter Affiliation (if stated) 

Comment Source and ADAMS 

Accession # 

Correspondence 

ID

Arnold, James Meeting Transcript (ML101450282) 0004-2 

Bechdol, Michael EPA Region 6, Groundwater Email (ML101540268) 0006 

Bludau, Owen Matagorda County Economic 

Development Corporation 

Meeting Transcript (ML101450282) 0004-1 

Bradish, Michael Meeting Transcript (ML101450282) 0004-2 

Celestine, Bryant Alabama-Coushatta Tribe of Texas Email (ML101300039) 0001 

Chavez, Chance Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101450284) 0003 

Corder, John Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101450284) 0003 

Croft, Roy Meeting Transcript (ML101450282) 0004-2 

Dancer, Susan Matagorda County Coalition for 

Nuclear Industry Accountability 

Email (ML101610154) 0013 

Meeting Transcript (ML101450282) 0004-2 

Dunham, D.C. Bay City Community Development 

Corporation 

Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101450284) 0003 

Fuson, David Independent inventor Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101470110) 0007 

Gilmore, Cathy EPA Office of Planning and 

Coordination 

Email (ML101610346) 0016 

Grebe, Lynn Meeting Transcript (ML101450284) 0003 

Green, Julie Fit for Life Meeting Transcript (ML101450284) 0003 

Griffin, Mark International Brotherhood of Electrical 

Workers Local 66 

Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101450284) 0003 

Griffith, Mike Meeting Transcript (ML101450282) 0004-1 

Hadden, Karen Sustainable Energy and Economic 

Development (SEED) Coalition 

Meeting Transcript (ML101450282) 0004-1 

Halpin, Ed STP Nuclear Operating Company 

(STPNOC) 

Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101450284) 0003 

Head, Bobby Meeting Transcript (ML101450284) 0003 

Head, Scott STP Project Units 3 & 4 Letter (ML101580094) 0010 

Hegar, Glenn Senator, Texas Meeting Transcript (ML101450282) 0004-1 

Holt, Ben Heritage Homes Meeting Transcript (ML101450282) 0004-2 

Humphries, Jim Meeting Transcript (ML101450284) 0003 

Hutto, Veronica Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101450284) 0003 
Appendix E 

NUREG-1937 E- 4 February 2011 

Table E-1. (contd)

Commenter Affiliation (if stated) 

Comment Source and ADAMS 

Accession # 

Correspondence 

ID

Johnson, Ken City of Palacios Economic 

Development Corp. 

Meeting Transcript (ML101470110) 0007 

Johnson, Matthew Public Citizen-Texas Office Email (ML101610062) 0015 

Knapik, Richard Mayor, Bay City Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101450284) 0003 

Kumar, Vatsu Meeting Transcript (ML101450284) 0003 

Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101470110) 0007 

Lucero, Greg International Brotherhood of Electrical 

Workers (IBEW) Local 66 

Meeting Transcript (ML101450282) 0004-2 

Mann, Billy Meeting Transcript (ML101450284) 0003 

Marceaux, Brent Meeting Transcript (ML101450284) 0003 

McBurnett, Mark STPNOC Meeting Transcript (ML101450282) 0004-2 

McDonald, Nate Matagorda County Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101450284) 0003 

Meeting Transcript (ML101470110) 0007 

O’Day, Mike Lower Colorado River Authority 

(LCRA) Advisory Board 

Meeting Transcript (ML101450282) 0004-2 

Opella, Ernest Meeting Transcript (ML101450282) 0004-2 

Paul, Ron U.S. Congress, Texas Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101470110) 0007 

Purvis, Gail The Trull Foundation Email (ML101540218) 0005 

Reed, Cyrus Sierra Club, Lone Star Chapter Letter (ML101670460) 0017 

Roberts, Kaley Hampton Inn & Suites and Titan 

Hotels Group 

Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101450284) 0003 

Scurlock, Betty Matagorda Regional Medical Center 

Board of Managers 

Letter (ML101530429) 0012 

Segovia, Valerie Nuclear Power Institute at Texas A&M Meeting Transcript (ML101450282) 0004-2 

Silva, Allison Bay City School District Meeting Transcript (ML101450282) 0004-2 

Smith, Steve Matagorda Regional Medical Center 

Board of Managers 

Meeting Transcript (ML101450282) 0004-1 

Smith, Tom Public Citizen, Texas Office Meeting Transcript (ML101450282) 0004-1 

Spencer, Stephen U.S. Department of the Interior Email (ML101600049) 0011 

Stanley, Rikki Meeting Transcript (ML101450282) 0004-2 

Thames, Carolyn Workforce Solutions Meeting Transcript (ML101450282) 0004-1 
Appendix E 

February 2011 E-5 NUREG-1937 

Table E-1. Individuals Providing Comments

Commenter Affiliation (if stated) 

Comment Source and ADAMS 

Accession # 

Correspondence 

ID

Thames, Mitch Bay City Chamber of Commerce Meeting Transcript (ML101450282) 0004-1 

Meeting Transcript (ML101450284) 0003 

Weber, Randy Meeting Transcript (ML101450282) 0004-1 

Wolf, Clayton Texas Parks and Wildlife Department 

(TPWD), Wildlife Division 

Email (ML101610057) 0019 

Yeamans, Joe Meeting Transcript (ML101450282) 0004-2 

Meeting Transcript (ML101450284) 0003 

E.2 Comments and Responses 

This appendix presents the comments and responses to them grouped by similar issues as 

follows: 

• Comments Concerning Process – COL 

• Comments Concerning Process – NEPA 

• Comments Concerning Site Layout and Design 

• Comments Concerning Land Use – Site and Vicinity 

• Comments Concerning Land Use – Transmission Lines 

• Comments Concerning Meteorology and Air Quality 

• Comments Concerning Geology 

• Comments Concerning Hydrology – Surface Water 

• Comments Concerning Hydrology – Groundwater 

• Comments Concerning Ecology – Terrestrial 

• Comments Concerning Ecology – Aquatic 

• Comments Concerning Socioeconomics 

• Comments Concerning Environmental Justice 

• Comments Concerning Historic and Cultural Resources 

• Comments Concerning Nonradiological Waste 

• Comments Concerning Nonradiological Health 

• Comments Concerning Radiological Health 

• Comments Concerning Severe Accidents 

• Comments Concerning the Uranium Fuel Cycle 

• Comments Concerning Transportation 

• Comments Concerning Decommissioning 

• Comments Concerning the Need for Power 
Appendix E 

NUREG-1937 E- 6 February 2011 

• Comments Concerning the No-Action Alternative 

• Comments Concerning Energy Alternatives 

• Comments Concerning Benefit-Cost Balance 

• General Comments in Support of the Licensing Action 

• General Comments in Support of the Licensing Process 

• General Comments of Support of Nuclear Power 

• General Comments in Support of the Existing Plant 

• General Comments in Opposition to Nuclear Power 

• Comments Concerning Issues Outside Scope – Safety 

• Comments Concerning Issues Outside Scope – Security and Terrorism 

• General Editorial Comments 

When the comments resulted in a change in the text of the draft EIS, the corresponding 

response refers the reader to the appropriate section of the EIS where the change was made. 

Throughout this final EIS, with the exception of new appendices such as this appendix and 

Appendix K, substantive revisions to the text from the draft EIS are indicated by change bars 

(vertical lines) beside the text. 

E.2.1 Comments Concerning Process – COL 

Comment: The U.S. Department of the Interior has reviewed the subject DEIS. In this regard, 

we have no comment. (0011-1 [Spencer, Stephen] 

Comment: EPA rates the DEIS as LO, i.e., EPA has a Lack of Objections to the proposed 

action described in the DEIS. (0016-2 [Gilmore, Cathy]) 

Response: These comments reflect reviews of the U.S. Department of Interior and EPA of the 

draft EIS. No changes were made to the EIS as a result of these comments. 

E.2.2 Comments Concerning Process – NEPA 

Comment: DEIS Section 03.01. External Appearance and Plant Layout. Page 3-1, Line 5: The 

DEIS states, “In addition to the COL application, STPNOC will need to apply for a permit from 

the U.S. Army Corps of Engineers (Corps) to conduct activities that result in alteration of waters 

of the United States.” STPNOC has applied for the required permit; therefore, the sentence 

should read that “STPNOC has applied for a permit.” (Ref. STPNOC Letter U7-C-STP-ACE100001, dated March 9, 2010 from Scott Head, STPNOC, to U.S. Army Corps of Engineers - 

Galveston District, Subject: Application for Department of Army Permit.) 

(0010-1-35 [Head, Scott]) 
Appendix E 

February 2011 E-7 NUREG-1937 

Response: STPNOC’s permit application was submitted to the Corps after the draft EIS went 

into production. Sections 1.0 and 3.0 of the EIS were modified to reflect that the application has 

now been submitted to the Corps. 

Comment: I received [the STP draft EIS], read thoroughly. The breadth, I was impressed with. 

The depth is absolutely impressive, the coverage of protagonists and antagonists in their 

mailing, the coverage of topics in detail. One particularly near to my heart was Native American 

Indians. Their intimate and effective communication to those groups is something we should all 

be very proud of. (0003-5 [Marceaux, Brent]) 

Comment: Public involvement in this process called licensing of new nuclear power plants, is 

essential. What it does is it, in the end, helps to bring a better product. And, frankly, it adds a 

lot of transparency to the process, and also builds public confidence and trust, which is 

essential. (0004-1-15 [Halpin, Ed]) 

Response: These comments express general support for the NEPA process. No changes 

were made to the EIS as a result of these comments. 

Comment: The Draft Environmental Impact Statement is not adequate. It does not have 

adequate scientific analysis on many fronts, and it paints a glossy picture, while minimizing 

risks. I have come to call it the Don’t Worry Be Happy Report. (0004-1-30 [Hadden, Karen]) 

Comment: NEPA requires agencies to consider and give effect to the environmental objectives 

in the act and “not just to file detailed impact studies which will fill governmental archives.” 

Environmental Defense Fund, Inc. v. Corps of Engineers of U. S. Army, 470 F.2d 289 (8th Cir. 

1972) application denied 93 S.Ct. 675, 409 U.S. 1072, 34 L.Ed.2d 661, certiorari denied 93 

S.Ct. 2749, 412 U.S. 931, 37 L.Ed.2d 160. The DEIS related to this adjudication falls short of 

this requirement as related to the need for power, water impacts, comparisons of alternative 

generation modes and climate change. (0015-1 [Johnson, Matthew]) 

Response: These comments express opposition to the draft EIS that is general in nature; 

therefore, no changes were made to the EIS as a result of these comments. 

Comment: The Environmental Impact Statement uses the categories of small, medium, and 

large. These are not scientific terms. These are not numbers, and, yet, they are used throughout 

the EIS without giving corresponding numerical parameters. This is not scientifically valid. This 

is a judgment call. (0004-1-39 [Hadden, Karen]) 

Response: The SMALL, MODERATE and LARGE significance levels are used by the review 

team after completing its analyses to communicate the results of its assessment of the 

environmental impacts of the proposed action and alternatives to the action. The structure for 

the significance levels was based on Council on Environmental Quality (CEQ) guidance (40 
Appendix E 

NUREG-1937 E- 8 February 2011 

CFR 1508.27) and on discussions with the CEQ and the EPA when it was first implemented for 

nuclear power plant licensing actions. Definitions of the three significance levels are provided in 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, and are provided in Section 1.1.1.1 of the 

EIS. 

When determining significance levels for environmental impacts, the review team considers two 

variables: context and intensity. Context is the geographic, biophysical, and social setting in 

which the impacts would occur. For the STP Units 3 and 4 environmental review, the context 

varies according to the resource being evaluated. For example, the context for the 

environmental justice review is the 50-mile region surrounding the STP site. Intensity refers to 

the severity of the impact, in whatever context it occurs. 

CEQ’s regulations that implement NEPA (40 CFR 1500-1508) require that EISs be concise, 

clear, to the point, and supported by evidence that agencies have made the necessary 

environmental analyses. The NRC uses SMALL, MODERATE, or LARGE to concisely 

communicate the results of our environmental analyses. Our analyses in the EIS, which follow 

the environmental review requirements contained in NUREG-1555, Standard Review Plans for 

Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan, are 

contained in the paragraphs preceding the significance determination of SMALL, MODERATE, 

or LARGE. In compliance with CEQ regulations, the STP Units 3 and 4 EIS identifies the 

methodologies used in the environmental analyses, and explicitly references sources relied 

upon for conclusions. For some analyses, a separate appendix is included that contains 

additional detailed calculations and numerical data. 

The significance levels of SMALL, MODERATE, and LARGE are used to concisely summarize 

the analyses completed by the review team, and as such, are scientifically valid descriptions of 

potential environmental impacts. No change was made to the EIS as a result of this comment. 

E.2.3 Comments Concerning Site Layout and Design 

Comment: DEIS Section 03.02. Proposed Plant Structures. Page 3-6, Line 31: The DEIS 

states, “The RMPF consists of 18 traveling screens.” The statement should be revised to state 

that the RMPF consists of “24” traveling screens. STPNOC plans to revise the Environmental 

Report Figure 3.4-5 to indicate the correct number of traveling screens. 

(0010-1-36 [Head, Scott]) 

Comment: DEIS Section 03.02. Proposed Plant Structures. Page 3-7, Lines 1-2: The DEIS 

states, the “surface area of the 18 traveling screens is 2430 ft2

.” This statement should be 

revised to state indicate that the number of traveling screens is 24 (see comment on Page 3-6, 

Line 31, above) and the surface area should be shown as 2400 ft2

 (24 screens x 10 ft wide x 10 

ft deep = 2400 ft2

). (0010-1-37 [Head, Scott]) 
Appendix E 

February 2011 E-9 NUREG-1937 

Comment: DEIS Section 03.02. Proposed Plant Structures. Page 3-8, Lines 30-31: The DEIS 

indicates that the combustion turbine generators are safety related. Combustion turbine 

generators are used during off normal conditions as an Alternate AC power source for Station 

Blackout events and are non-safety-related. (Reference Part 2 Tier 1 Section 2.12.11, and Part 

2 Tier 2 Sections 9.5.11.3 and 9.5.13.21). (0010-1-38 [Head, Scott]) 

Comment: DEIS Section 03.02. Proposed Plant Structures. Page 3-9, Line 26: The DEIS 

states, “the existing MDC would need to be relocated.” This should read, “the existing MDC has 

been relocated.” (0010-1-39 [Head, Scott]) 

Response: Section 3.2 of the EIS was updated to correct the statements regarding the number 

of traveling screens, to clarify that the combustion turbine generators are not safety related, and 

to reflect the correct location of the Main Drainage Channel (MDC).

Comment: DEIS Section 03.04. Operational Activities. Page 3-23, Line 2: The DEIS states, 

“activated sludge from existing Units 1 and 2 is currently disposed by land application at a rate 

of 30,000 to 40,000 gallons per year.” The phrase “is currently” in the sentence should be 

changed to “has previously been.” (0010-1-48 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-23, Line 5: The DEIS states, 

“The sludge from the new West Sanitary Waste Treatment System (WSWTS) and Nuclear 

Training Facility (NTF) systems for the existing Units 1 and 2 and proposed Units 3 and 4 would 

be disposed of by land application.” The phrase “by land application” at the end of the sentence 

should be changed to “off-site.” (0010-1-49 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-24, Line 5: The DEIS states, 

“Both systems would be replaced by newer systems to accommodate the expansion of the 

facilities by the addition of Units 3 and 4.” The phrase “replaced by newer systems” should read 

“replaced, or upgraded”. (0010-1-52 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-24, Lines 6-8: The DEIS states: 

“The new WSWTS will be designed to treat sanitary waste at a rate of 300,000 gallons per day, 

and the new NTF system will be designed to treat sanitary waste at a rate of 100,000 gallons 

per day.” STPNOC recommends deleting the word “new” preceding ”WSWTS” and preceding 

“NTF” in this sentence consistent with the comment noted on Line 5 of this page. 

(0010-1-53 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-26, Table 3-4: The DEIS states, 

in Table 3-4 that 23,190 gpm is the ”full heat load.” “Full heat load” should be revised to read 

“for 100% load factor.” (0010-1-55 [Head, Scott])
Appendix E 

NUREG-1937 E- 10 February 2011 

Comment: DEIS Section 03.04. Operational Activities. Page 3-26, Table 3-4: The DEIS states, 

in Table 3-4, “21,600 gpm long-term average basis for 93% heat load.” This should read, 

“21,600 gpm long term average basis for 93% load factor.” (0010-1-56 [Head, Scott]) 

Response: Section 3.4 and Table 3-4 of the EIS were changed to reflect these comments. 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-6, Line 37: The 

DEIS states that “The RMPF contains 18 traveling screens, each of 13.5-ft width.” The sentence 

should be corrected to state that “The RMPF contains 24 traveling screens, each of 10.0-ft 

width.” (0010-2-6 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-7, Line 12: The 

DEIS states that ”... the area of 18 screens would be 2430 ft2

....” The sentence should be 

corrected to state that “...the area of 24 screens would be 2400 ft2

....” (0010-2-7 [Head, Scott]) 

Comment: DEIS Appendix F. Key Consultation Correspondence. Page F-47, Line 16: The 

DEIS states: “The area of the 18 screens would be 2430 ft2

.” As previously discussed, the 

Reservoir Makeup Pumping Facility is currently configured for 24 rotating screens. The surface 

area should be 2400 ft2

. (0010-2-85 [Head, Scott]) 

Response: Section 5.2 was updated to reflect that the Reservoir Makeup Pumping Facility 

(RMPF) contains 24 traveling screens with a total surface area of 2400 ft2. Appendix F contains 

copies of the Biological Assessment and the Essential Fish Habitat Assessment submitted to 

the National Marine Fisheries Service as part of consultation requirements under the 

Endangered Species Act and the Magnuson-Stevens Fishery Conservation and Management 

Act, respectively. These are standalone documents that will not be edited in the EIS. 

E.2.4 Comments Concerning Land Use – Site and Vicinity 

Comment: DEIS Section 02.02. Land Use. Page 2-7, Lines 20-22: The DEIS states, “There are 

no mineral resources of known commercial value within the STP site boundary or in the 6-mi 

vicinity of the site (STPNOC 2009a).” The Environmental Report (Rev. 3) Section 2.2.1.1 

indicates the following: “The co-owners of STP also own or control all of the mineral interests 

within the site boundary and have the power to acquire such outstanding mineral interests in the 

subsurface estate as may be required for operation of the facility. “The co-owners control the 

surface minerals and any drilling used to recover minerals. However, the co-owners of STP 

have agreed to not exercise their right to use any area within the EAB for explorations or 

recovery of minerals, or convey or lease mineral rights to any third party without proper approval 

of STP Nuclear Operating Company. There are mineral resources (e.g., sand and gravel, coal, 

oil, natural gas, and ores) adjacent to (within the 6-mile vicinity) and within the site boundary 

presently being exploited or of known commercial value. According to the Railroad Commission 

(RRC) of Texas, there are two petroleum wells within the site property that have been plugged 
Appendix E 

February 2011 E-11 NUREG-1937 

and abandoned and there are seven petroleum wells within the 6-mile vicinity. There are 26 

gas wells and nine oil/gas wells within the 6-mile vicinity (Reference 2.2-1). Reference: Railroad 

Commission of Texas, 2007. Wells. (0010-1-2 [Head, Scott]) 

Response: Section 2.2.1 of the EIS was revised to reflect the information provided by this 

comment. 

Comment: DEIS Section 04.01. Land Use Impacts - Construction. Page 4-4, lines 11-15: The 

DEIS states, “An additional approximately 240 ac would be disturbed for temporary facilities 

including a concrete batch plant, materials storage areas, laydown areas, heavy haul road, 

parking areas, borrow areas, and spoils storage (STPNOC 2009a). These activities would 

result in a temporary land-use change; as STPNOC is committed to restore temporarily 

disturbed areas after construction completion.” However, as stated in DEIS 4.1.1, Page 4-4, 

Lines 20, 21 and 22, consistent with Rev 3 of the ER, “The heavy haul road would be 

approximately 2.5 mi long and 50 ft wide (STPNOC 2009a) and would result in a permanent 

land use change from open space.” Lines 11-15 should be revised to indicate that the heavy 

haul road would be a permanent disturbance. (0010-1-58 [Head, Scott]) 

Comment: DEIS Section 04.01. Land Use Impacts - Construction. Page 4-4, Line 15: The 

DEIS states, “STPNOC is committed to restore temporarily disturbed areas after construction 

completion.” STPNOC believes that “is committed” is not appropriate and that the words should 

be changed to “plans.” This change is important given that parking and other areas could be 

used after construction. (0010-1-59 [Head, Scott]) 

Comment: DEIS Section 04.01. Land Use Impacts - Construction. Page 4-4, Line 24: Replace 

“committed” with ”plans”. (0010-1-60 [Head, Scott]) 

Comment: DEIS Section 04.01. Land Use Impacts - Construction. Page 4-5, Line 10: Replace 

“committed” with “plans”. (0010-1-61 [Head, Scott]) 

Response: Section 4.1.1 of the EIS was changed to reflect these comments. 

Comment: DEIS Section 07.01. Land Use - Cumulative. Page 7-6, Line 15: The DEIS states, 

“The review team determined that a 15-mi radius would represent the smallest area that would 

be directly affected because it includes the primary communities (the largest being Bay City) 

that would be affected by the proposed project.” Based on the context of the statement, 

smallest area should be revised to largest area. (0010-2-43 [Head, Scott]) 

Response: Section 7.1 of the EIS was revised to reflect this comment. 

Comment: DEIS Section 09.03. Alternative Sites, Page 9-150, lines 1-2: The DEIS names 

Figure 9-13 as “Trinity 2 Alternative Site and 10-mi Radius.” STPNOC believes Figure 9-13 is 
Appendix E 

NUREG-1937 E- 12 February 2011 

the incorrect figure as the figure content does not conform to the figure title. This figure is the 

same as Figure 9-15 and appears to depict a 50-mile radius rather than the 10-mile radius 

identified in the figure title. Additionally, the figure is not similar to Figures 9-5 and 9-9 which 

also depict a 10-mile radius around an alternative site. (0010-2-66 [Head, Scott]) 

Response: Figure 9-13 has been replaced in the EIS with the correct figure showing the 

location of the Trinity 2 Alternative Site and the 10-mi radius. 

Comment: DEIS Section 10.03. Relationship Between Short Term Uses and Long Term 

Productivity of the Human Environment. Page 10-13, Line 1: The DEIS only lists the 

consumption of depletable resources as a result of plant construction and operation as a longterm use. The Environmental Report (Rev. 3.0) also lists the land committed for waste burial as 

a long-term use (Section 10.3.2). (0010-2-73 [Head, Scott]) 

Response: The land committed for waste disposal is discussed in Section 10.4.1.1 of the EIS; 

therefore, no change was made to Section 10.3 as a result of this comment. 

Comment: DEIS Section 10.04. Irreversible and Irretrievable Commitments of Resources. 

Page 10-14; Lines 2-3: The DEIS states that once land is committed to the disposal of 

radioactive and non-radioactive waste, it cannot be used for other purposes. The 

Environmental Report (Rev. 3.0) indicates that land used for the disposal of radioactive and 

non-radioactive waste, while not available for other uses while in use, is not considered 

irreversible since it could be remediated for future use (Section 10.2.1.1). (0010-2-74 [Head, 

Scott]) 

Response: An irreversible commitment of a resource refers to primary or secondary impacts 

which limit future options for that resource. It is the review team’s position that the disposal of 

radioactive and nonradioactive wastes would require an irreversible commitment of land. The 

treatment, storage, and disposal of spent nuclear fuel, low level waste, hazardous waste, and to 

a lesser extent, nonhazardous waste, would require the long-term or permanent, irretrievable 

commitment of land. As an irreversible action, the disposal of such wastes could potentially 

adversely impact the surrounding ecosystem, rendering it unfit for remediation and future use. 

Section 10.4.1.1 of the EIS was modified to clarify that waste disposal would require either a 

long-term or permanent commitment of land. 

E.2.5 Comments Concerning Land Use – Transmission Lines 

Comment: DEIS Section 03.02. Proposed Plant Structures. Page 3-10, Line 9: The DEIS 

states, “Except for upgrading the transition lines from the STP site to Hillje Substation, STPNOC 

has determined that no additional offsite transmission line corridors or expansion of existing 

corridors would be required to support Units 3 and 4.” The phrase “Except for” in this sentence 

may be read to imply the need for additional corridors or expansion of corridors. STPNOC 
Appendix E 

February 2011 E-13 NUREG-1937 

recommends this statement be split into two sentences to clarify that upgrading will be within an 

existing corridor: “The existing transmission lines from the STP site to the Hillje Substation will 

be upgraded. STPNOC has determined that no additional offsite transmission line corridors or 

expansion of existing corridors will be required to support Units 3 and 4.” 

(0010-1-40 [Head, Scott]) 

Response: In response to this comment, Section 3.2.2.3 of the EIS was revised to delete the 

following words: “... except for upgrading the transmission lines from the STP site to Hillje 10 

Substation.” 

E.2.6 Comments Concerning Meteorology and Air Quality 

Comment: DEIS Section 5.07. Meteorological and Air Quality Impacts - Operation. Page 5-66, 

Line 19: The DEIS states in “Table 5-6 (Anticipated Atmospheric Emissions Associated With 

Operation of Proposed Units 3 and 4)...: 

Particulates 2500 44 44,700 

Sulfur Oxides 5200 3800 ---- 

Carbon Monoxide 5200 1800 ---- 

Hydrocarbons 6100 120 ---- 

Nitrogen Oxides 57,900 2000 ---- 

emissions (lb/yr) from diesel generators, combustion turbine, and UHS cooling towers, 

respectively. Environmental Report Rev. 3.0 and supporting documents indicate that these 

emissions should be: 

Particulates 2500 44 22,700 

[cooling tower particulate release based on RAI Response 5.3.3.1 (9/14/09), Attachment 7, p. 3 

of 32 which gives effluent for two towers = 43101 gal/min * 3.79 l/gal * 525600 min/yr * .005/100 

drift rate * 3 cycles of concentration * 800 mg-salt/l * 1/1000 g/mg * 1/454 lb/g = 22,700 lb/yr] 

Sulfur Oxides 9200 3800 --- 

Carbon Monoxide 9200 1800 --- 

Hydrocarbons 6100 120 --- 

Nitrogen Oxides 57,900 4000 --- 

[sulfur oxide, carbon monoxide and nitrogen oxide corrections based on ER Rev 3.0, 

Section3.6, Table 3.6-3, Page 3.6-8, which gives diesel generator and combustion turbine 

emissions(lb/yr) per unit]. (0010-2-22 [Head, Scott]) 
Appendix E 

NUREG-1937 E- 14 February 2011 

Response: The review team determined that the comment is only partially correct. The 

request for additional information (RAI) response referenced in the comment clearly states that 

the 43,100 gal/min flow is for each cooling tower. Consequently, the total salt drift for the two 

cooling towers is about 45,000 lbs/yr, not the 22,700 lbs/yr stated in the comment. Table 5-6 of 

the EIS was revised as appropriate. The salt drift values in Section 5.3.3.1 of ER Revision 4 are 

consistent with the values listed above. 

Comment: Since the DEIS was released, at least two significant events have occurred: 

The US EPA released a new report on April 27th 2010 entitled “Climate Change Indicators in 

the United States,” which details many ways in which the climate is being disrupted by 

emissions of greenhouse gasses. (0015-15 [Johnson, Matthew]) 

Response: The EPA report referenced in the comment was released after the draft EIS was 

published. NRC reviewed the April 2010 report and determined that information contained in 

the EPA report would not alter any conclusions in the EIS regarding the cumulative impacts of 

climate change.

Comment: The DEIS understates the effect of global warming on the cumulative impacts of the 

operation of STP 3 & 4. 

A. The DEIS conclusion that cumulative effects of greenhouse gas emissions are projected to 

be “noticeable but not destabilizing” is contradicted by the EPA’s April 27, 2010 report “Climate 

Change Indicators in the United States”. Inter alia, the EPA report finds compelling evidence 

that composition of the atmosphere and many fundamental measures of climate are changing. 

By understating the effects of climate change the DEIS effectively minimizes the contributions to 

the GHG inventory attributable to operation of STP Units 3&4. This has the further effect of 

minimizing the importance of selecting the lowest GHG alternatives to generate electricity. A full 

accounting for all stages of the UFC shows that nuclear power has significantly greater GHG 

burdens than wind, solar power or geothermal. The DEIS did not make any such comparison, 

however. (0015-3 [Johnson, Matthew]) 

Comment: The DEIS fails to compare the CO2 emissions of the UFC to the CO2 emissions of 

wind and solar power. 

Appendix I of the DEIS discusses the CO2 footprint of a LWR. However, this discussion omits 

any direct comparison to similar emissions related to alternatives such as wind, solar, 

geothermal, etc. The only reference to a comparison is the study by B.K. Sovacool. This study 

consists of a survey of relevant literature and concludes that alternatives such as wind, solar 

and geothermal have much smaller CO2 footprints than nuclear powered generation. However, 

the DEIS otherwise makes no attempt to compare the CO2 footprints of alternative generation 

modes. Additionally, comparisons of CO2 emissions related to alternatives are not covered in 
Appendix E 

February 2011 E-15 NUREG-1937 

other contexts of the DEIS. The closest that the DEIS comes to a meaningful discussion of a 

comparison of CO2 impacts is an attenuated reference in the environmental impacts of 

alternatives where it is conceded that wind, solar and hydropower have minor CO2 impacts. But 

this reference does not quantify any comparisons and erroneously concludes that the nuclear 

option has the lowest emission of GHG of viable alternatives. ...The failure of the DEIS to 

discuss CO2 impacts related to alternative generation modes is particularly noteworthy 

considering the DEIS’s recognition that GHG increases and effects of climate change have 

profound environmental impacts. Moreover, the omission of any discussion of the lower GHG 

profiles for renewable generating sources compared to the UFC has the effect of distorting the 

putative advantages of nuclear powered generation. (0015-8 [Johnson, Matthew]) 

Comment: After reviewing the draft, it is my professional judgment that the NRC Staff has 

committed numerous errors of omission in their analysis of global climate change including: 

• The significance of climate change on the environment, 

• the methods of calculating the global climate change emissions from the proposed nuclear 

generating facility, 

• the significance of the emissions from this plant compared to alternatives, 

• the impact of climate change on the operations of this plant (0015-13 [Johnson, Matthew]) 

Comment: The DEIS is flawed because it failed to do a thorough analysis of the significance of 

climate change. In their summary the NRC Staff concludes: 7.6.2 Greenhouse Gas Emissions - 

The review team concludes that the cumulative impacts of greenhouse emissions around the 

world as presented in the report are the appropriate basis for it’s evaluation of cumulative 

impacts. Based on the impacts set forth in the GCRP report, the review team concludes that 

the national and worldwide cumulative impacts of greenhouse gas emissions are noticeable but 

not destabilizing. (p. 7-43, 44) This conclusion is contradicted by the newest EPA study entitled 

“Climate Change Indicators in the United States” released April 27, 2010 which concludes: The 

indicators in this report present compelling evidence that the composition of the atmosphere and 

many fundamental measures of climate in the United States are changing. These changes 

include rising air and water temperatures, more heavy precipitation, and, over the last several 

decades, more frequent heat waves and intense Atlantic hurricanes. Assessment reports from 

the Intergovernmental Panel on Climate Change and the U.S. Global Change Research 

Program have linked many of these changes to increasing greenhouse gas emissions from 

human activities, which are also documented in this report. Analysis of the indicators presented 

here suggests that these climate changes are affecting the environment in ways that are 

important for society and ecosystems. Sea levels are rising, snow cover is decreasing, glaciers 

are melting, and planting zones are shifting (see Summary of Key Findings on p. 4). Although 

the indicators in this report were developed from some of the most complete data sets currently 

available, they represent just a small sample of the growing portfolio of potential indicators. 

Considering that future warming projected for the 21st century is very likely to be greater than 

observed warming over the past century,1 indicators of climate change should only become 
Appendix E 

NUREG-1937 E- 16 February 2011 

more clear, numerous, and compelling. It also notes that: Temperature is a fundamental 

component of climate, and it can have wide-ranging effects on human life and ecosystems, as 

many of the other indicators in this report demonstrate. For example, increases in air 

temperature can lead to more intense heat waves, which can cause illness and death in 

vulnerable populations. Temperature patterns also determine what types of animals and plants 

can survive in a particular place. Changes in temperature can disrupt a wide range of natural 

processes, particularly if these changes occur abruptly and plant and animal species do not 

have time to adapt. Its hard to conclude that changes in temperature that “can disrupt a wide 

range of natural processes and “cause illness and death in vulnerable populations” are not 

destabilizing. (0015-25 [Johnson, Matthew]) 

Response: On December 15, 2009, the Administrator of EPA issued 74 FR 66496, her 

determination under her authority under the Clean Air Act that: 

... greenhouse gases in the atmosphere may reasonably be anticipated both to 

endanger public health and to endanger public welfare.... The Administrator reached 

her determination by considering both observed and projected effects of greenhouse 

gases in the atmosphere, their effect on climate, and the public health and welfare risks 

and impacts associated with such climate change. 

In addition to the finding, the bases for the finding provide insights on the extensive efforts within 

the Federal government to weigh and balance science and public policy issues when 

considering greenhouse gas (GHG) emissions and the effects of climate change; GHG 

emissions is treated as a surrogate for the potential effects on climate. In the following, the 

excerpted text from EPA’s determination was considered by the NRC staff in shaping its 

consideration of GHG emissions and the effects of climate change as part of its NEPA reviews 

of new reactor applications and its preparation of EISs: 

The Administrator recognizes that human-induced climate change has the potential to be 

far-reaching and multidimensional, and in light of existing knowledge, that not all risks 

and potential impacts can be quantified or characterized with uniform metrics. 

The Administrator has considered how elevated concentrations of the well-mixed 

greenhouse gases and associated climate change affect public health by evaluating the 

risks associated with changes in air quality, increases in temperatures, changes in 

extreme weather events, increases in food- and water-borne pathogens, and changes in 

aeroallergens. 

The Administrator has considered how elevated concentrations of the well-mixed 

greenhouse gases and associated climate change affect public welfare by evaluating 

numerous and far-ranging risks to food production and agriculture, forestry, water 
Appendix E 

February 2011 E-17 NUREG-1937 

resources, sea level rise and coastal areas, energy, infrastructure, and settlements, and 

ecosystems and wildlife. 

The Administrator is defining the air pollutant that contributes to climate change as the 

aggregate group of the well-mixed greenhouse gases. The definition of air pollutant used 

by the Administrator is based on the similar attributes of these substances. These 

attributes include the fact that they are sufficiently long-lived to be well mixed globally in 

the atmosphere, that they are directly emitted, and that they exert a climate warming 

effect by trapping outgoing, infrared heat that would otherwise escape to space, and that 

they are the focus of climate change science and policy. 

The release of the U.S. Global Climate Research Program (GCRP) [formerly the Climate 

Change Science Program (CCSP)] report on impacts of climate change in the United 

States in June 2009 ... synthesized information contained in prior CCSP reports and 

other synthesis reports, many of which had already been published ... [and undergo a 

rigorous and exacting standard of peer review by the expert community, as well as 

rigorous levels of U.S. government review and acceptance.... The review processes ... 

provide EPA with strong assurance that this material has been well vetted by both the 

climate change research community and by the U.S. government.]. These assessments 

therefore essentially represent the U.S. government’s view of the state of knowledge on 

greenhouse gases and climate change. For example, with regard to government 

acceptance and approval of IPCC [Intergovernmental Panel on Climate Change] 

assessment reports, the GCRP Web site states that: ‘‘When governments accept the 

IPCC reports and approve their Summary for Policymakers, they acknowledge the 

legitimacy of their scientific content.’’ It is the Administrator’s view that such review and 

acceptance by the U.S. Government lends further support for placing primary weight on 

these major assessments. 

EPA has no reason to believe that the assessment reports do not represent the best 

source material to determine the state of science and the consensus view of the world’s 

scientific experts on the issues central to making an endangerment decision with respect 

to greenhouse gases. EPA also has no reason to believe that putting this significant 

body of work aside and attempting to develop a new and separate assessment would 

provide any better basis for making the endangerment decision, especially because any 

such new assessment by EPA would still have to give proper weight to these same 

consensus assessment reports. 

The latter represents an endorsement by the EPA of the GCRP. The review team’s assessment 

of the current affected environment (either in Chapter 2 for the site region or in Chapter 9 for the 

alternative sites) reflects conditions entirely consistent with the EPA Administrator’s finding. If 

the Administrator determined that an immediate action was necessary to improve public health 
Appendix E 

NUREG-1937 E- 18 February 2011 

conditions in the affected environment (e.g., the closure of GHG-emitting facilities), then the 

review team may have considered an impact more reflective of a destabilized environment. 

With regard to the EPA report referenced in the comment, the report was released after the draft 

EIS was issued. The review team finds that it corroborates and aligns well with the material 

provided in the draft EIS and provides useful data to inform decision-makers taking Federal 

actions. The sources of data used in the EPA report are similar to, and in many respects 

identical to, the sources of data that were used by the GCRP. More current data have not 

changed the trends that were considered in the GCRP; that report was considered for the 

important resources areas, including health effects, ecology, air and water issues, that could be 

affected by GHG emissions and this proposed action. 

The proposed action involves the generation of baseload electrical power in the amount of 2700 

MW(e). Insofar as certain energy alternatives do not reasonably meet the purpose and need for 

the action (i.e., they are not reasonable alternatives for generating 2700 MW(e) of baseload 

power), they are not reasonable alternatives to the proposed action. NEPA requires that the 

environmental impacts of the proposed action be compared to reasonable alternatives and does 

not require a comparison with alternatives not considered to be reasonable. The long-term 

effects of GHG emissions among the reasonable energy alternatives are focused on the 

operational impacts discussed in Section 9.2.5. To avoid even the appearance of efforts to 

“minimize” the GHG effects of producing electrical energy from nuclear power, the review team 

also considered the environmental air quality effects from the fuel cycle and GHG emissions 

from worker transportation over the operating life of the facility. The review team did not 

consider analogous fuel cycle and worker GHG emissions from the other viable baseload 

energy alternatives because it would not alter the review team’s conclusions. 

Appendix I presents the review team’s estimate solely of the carbon dioxide (CO2) footprint of 

the nuclear power generation alternative; a discussion of other energy alternatives in Appendix I 

would not be consistent with the purpose of the appendix. The comparison of CO2 footprints of 

nuclear power and reasonable alternatives is presented in Section 9.2.5. Expanding the 

comparison of the CO2 footprint of nuclear power and renewable generation alternatives 

individually would be an academic exercise that does not serve the purpose of NEPA because 

the review team determined that the renewable generation alternatives would not reasonably 

meet the need for baseload power generation in the required amount. During preparation of the 

final EIS, the review team did update the Table I-3 estimate from the Uranium Fuel Cycle (UFC) 

to be 1.7 x 107

 MT and the total to be 1.8 x 107 MT consistent with NRC staff guidance on the 

evaluation of GHG emissions; this update was also reflected in Sections 4.7.1, 6.1.3 and 9.2.5. 

Comment: The DEIS analysis of STP 3 & 4 construction impacts related to GHG emissions 

assumes appropriate mitigation measures would be adopted but fails to discuss what mitigation 

measures would be available to minimize GHG emissions during construction. 
Appendix E 

February 2011 E-19 NUREG-1937 

The DEIS acknowledges that construction activities include those with GHG impacts. And then 

the DEIS dismisses any need to analyze such because it assumes appropriate mitigation would 

be implemented. But the DEIS makes no attempt to determine what mitigation 

measures/alternatives are available let alone what actual effects on GHG emissions would be 

realized by such. The DEIS suggests no specific alternatives or GHG mitigation measures 

related to earthmoving, concrete batch plant operations or any other construction related 

activity. This assumption/ leap of faith is contrary to 10 CFR 51.70(b) that requires the DEIS to 

be analytic in its discussion of impacts. (0015-9 [Johnson, Matthew]) 

Response: Consistent with 10 CFR Part 51, Appendix A, data and analyses in an EIS are to 

be commensurate with the importance of the impact, with less important material summarized, 

consolidated, or simply referenced. Applying this principle to the draft EIS, the review team 

concluded that because of the relatively small carbon footprint from construction and 

preconstruction activities as compared to the total U.S. annual CO2 emission rate, “atmospheric 

impacts of greenhouse gases from construction and preconstruction activities would not be 

noticeable and additional mitigation would not be warranted.” The review team reaches this 

same conclusion in the final EIS. However, Section 4.7 of the EIS was revised to highlight that 

measures to mitigate the impacts of construction activities on air quality will also reduce GHG 

emissions. 

E.2.7 Comments Concerning Geology 

Comment: DEIS Section 02.08. Geology. Page 2-157, Lines 35-37 and Page 2-158, Lines 1-2: 

The DEIS states: “For the purposes of considering the hydrogeological setting in the vicinity of 

the STP intake structure on the Colorado River, an apparent feature is the incision in the 

sediments by the river to an elevation of approximately 14 ft below MSL (STPNOC 2009a). At 

the nearby STP site, this would imply direct communication between the Colorado River and the 

Upper Shallow Aquifer (STPNOC 2009a).” The DEIS statements should be clarified to 

reference Environmental Report (Rev. 3.0) Subsection 2.3.1.2.5.2 and Table 2.3.1-23, which 

presents the estimates of travel time to various receptors, including the Colorado River, to avoid 

any misunderstanding that a release at the site would immediately be observed in the river. 

(0010-1-33 [Head, Scott]) 

Response: These topics are addressed in Sections 4.2 and 5.2 of the EIS, where spills during 

building and operating the proposed Units 3 and 4 are postulated, and pathways and travel 

times are presented for groundwater. Therefore, no change was made to Section 2.8 as a 

result of this comment. 

E.2.8 Comments Concerning Hydrology – Surface Water 

Comment: But I guess one of the main -- one of the things that I really like about STP is they 

are a good steward of their water. Being a rice farmer, that’s important to me. They only pump 
Appendix E 

NUREG-1937 E- 20 February 2011 

their water during floods. That’s great. There is no loss. When the river is low, when the lakes 

are low, STP is not pulling it out. They have already got their water. They have already thought 

about that. (0003-34 [Mann, Billy]) 

Comment: I’m on the LCRA Advisory Board. I know how the plant takes their water. Mark did 

a very good job of explaining it. They take their water when the river is high. They also take 

their water from below the fresh water barrier, so the water they’re taking is more brackish than 

we would use for any of the other issues that we use, especially for public consumption. 

(0004-2-16 [O’Day, Mike]) 

Comment: The main cooling reservoir in South Texas, as our source of cooling, that reservoir, 

basically, is a storage facility. We pump water out of the Colorado, store it in that reservoir, and 

use it for cooling. Over time, it evaporates, and we have to add more water to it. We pump 

water out of the Colorado River when the river is flowing. In fact, this last year the reservoir was 

at a low level towards the latter part of last year due to the dry conditions, so we hadn’t pumped 

water in a long time. Just when the rain started, we basically had filled that reservoir back to full 

capacity now. We fill it, basically, off the run of the river. The rain that’s sent between, 

basically, Columbus and Bay City, has provided sufficient water to refill that reservoir. And 

that’s been our normal practice. That’s really how that reservoir is kept full. So, we store it for 

times. If we have sufficient storage quantity in there for times of drought, such that we don’t 

have to draw from the river during times of drought. And then there’s provisions to deal with 

those circumstances, as well. (0004-2-2 [McBurnett, Mark]) 

Response: These comments provide general information in support of STPNOC’s application 

for COLs. No changes were made to the EIS as a result of these comments. 

Comment: We have concerns with ... the consumption of vast quantities of water. (0004-1-35

[Hadden, Karen]) 

Comment: Water use, again, is of a great concern. The Draft EIS points out that in 26 of 60 

recent years, the Colorado had lowered river flow. It was 75 percent of the average flow during 

those years. The lowest the river has gotten down to is 20 percent of the average flow, so while 

STP may be allowed to use up to 100,000 acre feet per year, there is no guarantee that that 

water will be there. Last September, the water in the main cooling reservoir got quite low, and 

extensive pumping was needed to refill it in a time of serious drought. The proposed reactors, 

Units 3 and 4, would use over 23,000 gallons per minute, per minute. That is filling 1,440 

swimming pools in one day, backyard swimming pools. So, this vast consumption of water 

raises the question of how will other users get water if there is a drought, the water needed for 

rice farming and ranching, the water needed for recreation. Together with all four reactors, the 

site would use 42,604 gallons per minute. (0004-1-41 [Hadden, Karen]) 

Comment: I’m also concerned about water usage. (0004-2-9 [Dancer, Susan]) 
Appendix E 

February 2011 E-21 NUREG-1937 

Response: The review team analyzed the proposed water use of STP Units 3 and 4 in 

Section 5.2.2.1 of the EIS. During an average year, existing STP Units 1 and 2 use 

approximately 2 percent and all four STP units would use 4 percent of the Colorado River 

discharge. The Main Cooling Reservoir (MCR) is used to store cooling water withdrawn from 

the Colorado River during periods of relatively high discharge. The MCR has a sufficient 

storage capacity so that it can supply necessary cooling water to all four units without makeup 

water for an extended duration. STPNOC stated that the projected firm water demands for 

stored water in the upstream Colorado River currently is still less than the total firm water 

available; therefore, it is an extremely remote possibility that firm water rights would be reduced 

even under extreme drought conditions and that, if the conditions are worse than the drought of 

record, backup water would be released from firm stored water or any other sources of water 

originating upstream of the Bay City Dam (ER Section 5.2.1). Safe plant shutdown will not 

depend on the ability to pump river water to the MCR because engineered ultimate heat sink 

water storage tanks provide water for safe shutdown. If and when the MCR water level drops 

below its lowest operating level, STPNOC would shut down Units 3 and 4 (ER 3.4.1.3.3). No 

changes were made to the EIS as a result of these comments. 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-16, Lines 22-24: The DEIS 

indicates that Lake Buchanan has a storage capacity of 875,566 ac-ft and that Lake Travis has 

a storage capacity of 1,131,650 ac-ft. Since storage volumes vary with water depths, it is 

therefore suggested that the two statements be revised to “Lake Buchanan has a storage 

capacity of 875,566 ac-ft at normal operating level and ....”, and “Lake Travis has a storage 

capacity of 1,131,650 ac-ft at normal operating level and ....” (0010-1-3 [Head, Scott]) 

Response: Section 2.3.1.1 of the EIS was changed in response to this comment to more 

clearly convey the storage capacities of the highland lakes. 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-18, Lines 25-26: The DEIS 

states: “Water is pumped into the MCR from the Colorado River to maintain the water quality 

below 3000 μS/cm for specific conductivity (STPNOC 2009a).” The DEIS statement is not 

completely accurate based on Environmental Report Reference 5.2-4, the Amended and 

Restated Contract by and between the Lower Colorado River Authority and STP Nuclear 

Operating Company, effective January 1, 2006. To eliminate any misunderstanding the 

statement should be simplified to read, “Water is pumped into the MCR from the Colorado River 

(STPNOC 2009a).” (0010-1-4 [Head, Scott]) 

Response: The LCRA and STPNOC water contract (LCRA-STPNOC 2006) states that “... 

reservoir blowdown will commence as necessary to maintain MCR water at an average of 3000 

μS/cm” (see Note 2 below Water Delivery Plan, page 26). The review team clarified Section 

2.3.1 of the EIS to state that the MCR will likely have periodic discharges to the Colorado River, 

as well as withdrawals from the river. 
Appendix E 

NUREG-1937 E- 22 February 2011 

Lower Colorado River Authority and STP Nuclear Operating Company (LCRA-STPNOC). 2006. 

Amended and Restated Contract By and Between The Lower Colorado River Authority and STP 

Nuclear Operating Company. Effective as of January 1, 2006. 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-19, Lines 3-5: The DEIS states: 

“The powerblock area of the existing Units 1 and 2 is drained by gravity toward the northwest to 

a point west of the existing switchyard where the existing Main Drainage Channel (MDC) starts 

(Figure 2-12).” The power block for existing Units 1 and 2 drains by gravity to the east via the 

Plant Area Drainage Ditch or via drainage around the Essential Cooling Pond. Environmental 

Report (Rev. 3.0) Section 6.3.1.3 addresses storm water outfalls and Figure 6.3-3 shows these 

outfalls. The STP Units 1 and 2 powerblock area drains to Outfall A to the southeast. (0010-1-5

[Head, Scott]) 

Response: Section 2.3.1 of the EIS was updated to indicate the correct drainage paths from 

the power-block area of existing Units 1 and 2. The description of the MDC was updated also. 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-19, Line 32: The DEIS states: 

“The RMPF contains 18 traveling screens, each 13.5 ft in width (STPNOC 2009a).” 

Environmental Report (Rev. 3.0) Figure 3.4-5 shows 18 screens. The correct number of 

traveling screens is 24, with each 10 ft in width, as shown in the Unit 1 and 2 Operating License 

Environmental Report, Figures 3.4-2 and 3.4-4. A revised figure will be included in the next 

revision of the COLA. (0010-1-6 [Head, Scott]) 

Response: Section 2.3.1 of the EIS was updated to state that the RMPF contains 24 traveling 

screens each 10 ft in width. 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-21, Figure 2-12: The Main 

Drainage Channel has been relocated as part of pre-construction activities. In DEIS Figure 2-

12, “Current Location of MDC” should read “Previous Location of MDC” and “Main Drainage 

Channel (MDC)” should read “Relocated Main Drainage Channel (MDC)”. The title of DEIS 

Figure 2-12 should be reworded to read, “Current and Previous Locations of the Main Drainage 

Channel (STPNOC 2009b).” (0010-1-7 [Head, Scott]) 

Response: Figure 2-12 of the EIS was updated to reflect the current location of the MDC. 

Comment: DEIS Section 02.03.02. Water - Water Use. Page 2-34, Lines 11-13: The DEIS 

states: The STPNOC currently holds a water right for 102,000 ac-ft of water per year 

(determined as a 5-year rolling average) from the Colorado River and is authorized to divert 

water at a maximum rate of 1200 cfs. Although there is a provision in the existing STPNOCLCRA water contract that the river permit can be amended to allow diversion of 102,000 ac-ft of 

water per year on average over any five consecutive years, this provision is not currently in 

effect. Therefore, the DEIS statement should be clarified to delete the text (determined as a 5-
Appendix E 

February 2011 E-23 NUREG-1937 

year rolling average), to be consistent with the Environmental Report (Rev. 3.0) Table 2.3.2-3, 

which identifies 102,000 ac-ft of water per year as the STPNOC-LCRA permit limit without any 

discussion on rolling averages. (0010-1-13 [Head, Scott]) 

Response: The review team interpreted Amendment 1(b) on page 18 of the LCRA and 

STPNOC water contract (LCRA-STPNOC 2006), to mean that the maximum withdrawal of 

102,000 ac-ft of water per year on a five-year rolling average basis is currently in effect and may 

be modified at a later date by mutual agreement and amendment of the contract. Following this 

STPNOC comment, the review team confirmed, using the LCRA-STPNOC water contract that 

the subject amendment is not currently in effect. Section 2.3.2 of the EIS was updated in 

response to the comment. 

Comment: DEIS Section 02.03.02. Water - Water Use. Page 2-34, Lines 15-17: The DEIS 

states that STPNOC also has access to a maximum of 20,000 acre-feet of water for operation of 

Units 1 and 2. Although the DEIS is not inconsistent with STPNOC’s Lower Colorado River 

Authority (LCRA) Water Contract, which states that the LCRA will make available firm water 

totaling no more than 20,000 acre-feet/year (rolling five-year average) for 2-unit operation or 

40,000 acre-feet/year (rolling five-year average) for any additional generation capacity, using 

the 40,000 acre-feet per year value provided in ER Rev. 3 (Section 2.3.1.1.2) would be more 

applicable to STP Units 3 and 4. (0010-1-14 [Head, Scott]) 

Response: The review team disagreed with this comment. 20,000 ac-ft/yr of firm water for 

Units 1 and 2 is available to STPNOC at the STP site as described in Section 2.3.2.1 of the EIS. 

Water use for STP Units 3 and 4, including their firm water supply, is discussed in Section 

5.2.2.1. Reporting 40,000 ac-ft/yr as a value applicable to Units 3 and 4, as suggested by the 

commenter above, would be overstating the firm water available to Units 3 and 4 per the LCRASTPNOC water contract. Therefore, no changes were made to the EIS as a result of this 

comment. 

Comment: DEIS Section 02.03.02. Water - Water Use. Page 2-35, Lines 10-13: The DEIS 

states that STPNOC reported that the existing consumptive water use from the Colorado River 

is approximately 37,100 acre-feet per year. ER Rev. 3 Table 2.3.2-8 states that the 

consumptive water use is 34,821 acre-feet per year. The 37,100 acre-feet per year value is an 

average of the amount of water diverted from the Colorado River from 2001 to 2006. (0010-1-15

[Head, Scott]) 

Response: Section 2.3.2.1 of the EIS was updated to show a consumptive water use of 

34,821 ac-ft/yr. 

Comment: DEIS Section 02.03.03. Water - Water Quality. Page 2-45, Line 2: The DEIS states, 

“Stormwater runoff discharge from the STP site is monitored at eight outfalls....” This is 

incorrect. Only those outfalls associated with industrial activity require monitoring. Only 3 of the 
Appendix E 

NUREG-1937 E- 24 February 2011 

eight outfalls are associated with industrial activity and thus are the only ones monitored. 

(0010-1-17 [Head, Scott]) 

Response: The statement referred to by the commenter occurs in Section 2.3.4 of the EIS. 

Based on Section 6.3.1.3 of STPNOC’s environmental report (ER) Revision 4, EIS Section 

2.3.4.2 was updated to state that stormwater runoff discharge from the STP site is monitored at 

four outfalls. 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-4, Lines 26-27: 

The DEIS states that “... the MCR normal maximum water surface elevation would be raised 

from 47 to 49 ft mean sea....” The DEIS should also state that the 49 MSL is the original design 

maximum operating level (STPNOC is not changing the design). (0010-2-2 [Head, Scott]) 

Response: Section 5.2.1 of the EIS was modified to add the following explanatory sentence, 

“The normal maximum operating elevation for the original MCR design is 49 ft above MSL.” 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-6, Lines 2-3: The 

DEIS states that “STPNOC would have access to 20,000 acre-feet of firm water for operation of 

Units 3 and 4”. Although the DEIS is not inconsistent with STPNOC’s Lower Colorado River 

Authority (LCRA) Water Contract, which states that STPNOC also has rights to an additional 

20,000 acre-feet per year of rolling water rights for a two unit operation, and 40,000 acre-feet 

per year for a four-unit operation any additional generation capacity. STPNOC recommends 

using the 40,000 acre-feet per year value provided in ER Rev. 3 (Section 2.3.1.1.2). 

(0010-2-3 [Head, Scott]) 

Response: Firm water availability for STP Units 1 and 2 is described in Section 2.3.2.1, and 

the sentence referred to in Section 5.2.2.1 mentions additional firm water that would be 

available for the proposed Units 3 and 4. There is no inconsistency, and addressing firm water 

availability for all four units would be confusing because in Section 5.2.2 incremental impacts of 

Units 3 and 4 water use is described. No changes were made to the EIS as a result of this 

comment. 

Comment: DEIS Section 05.02 Water-Related Impacts - Operation. Page 5-6, Lines 21-23: 

The DEIS states that, “... the current STP water use for Units 1 and 2 during normal operations 

is 2 percent (37,100 ac-ft/yr of use with 1,903,000 ac-ft/yr)....” According to the Table 2.9S-1 of 

Environmental Report (Rev. 3.0), the value of 37,100 ac-ft/yr is the average withdrawal from the 

Colorado River for the calendar years 2004 to 2006. Lines 23-25 of the DEIS states that, “... the 

proposed STP water use for the existing and proposed units during normal operations would be 

4 percent (37,100 plus 34,405 ac-ft/yr of use with 1,903,000 ac-ft/yr)....” The 34,405 ac-ft water 

use for Units 3 & 4 should be corrected as 37,405 ac-ft, which is consistent with value shown on 

Line 7 of the DEIS. The 37,405 ac-ft is the projected long-term average MCR evaporation loss 

from Units 3 & 4 at full load condition (STPNOC 2009f). Because the water use values provided 
Appendix E 

February 2011 E-25 NUREG-1937 

in the DEIS for the existing units and the proposed units were derived on different basis, it is 

suggested that the DEIS statement in Lines 23-25 be revised as follows to include the 

definitions of the two values: ”... (37,100 ac-ft/yr, based on a 3-year average (STPNOC 2009a), 

plus 37,405 ac-ft/yr, based on the projected long-term average MCR evaporation at full load 

operating condition (STPNOC 2009f) of use with 1,903,000 ac-ft/yr) of available surface water 

resource.” (0010-2-5 [Head, Scott]) 

Response: Section 5.2.2.1 of the EIS was updated in response to this comment. 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-15, Lines 22-23: 

The DEIS states that STPNOC would discharge when the specific conductivity of the water in 

the MCR exceeds 3000 μS/cm. Based on response to RAI 02.0306 (Reference STPNOC 

2009d - STPNOC Letter U7-C-STP-NRC-090006, dated January 22, 2009), there are other 

concurrent requirements identified in RAI 02.03-06 as stipulated in the STPNOC-LCRA water 

contract for blowdown to be performed. This is MCR Blowdown Rule # 4 from RAI 02.03-06. 

(0010-2-13 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-15, Lines 24-27: 

The DEIS states that “The MCR discharge would cease when the conductivity of the water in 

the MCR falls to 2100 μS/cm. Discharge from the MCR could also occur during large rainfall 

events when the MCR water surface elevation exceeds the spillway crest elevation.” Based on 

response to RAI 02.03-06 (Reference STPNOC 2009d - STPNOC Letter U7-C-STP-NRC090006, dated January 22, 2009), there are also other rules as specified in the STPNOC-LCRA 

water contract for blowdown to cease. The DEIS should be clarified to include these other 

blowdown rules. (0010-2-14 [Head, Scott]) 

Response: Section 5.2.3.1 of the EIS was updated to clarify that there are other concurrent 

requirements for discharge from the MCR. 

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-10, Lines 13-15: 

The DEIS states that: “The expected consumptive surface-water use of proposed Units 3 and 4 

would be 37,373 ac-ft per year (23,170 gallons per minute [gpm] during normal operations and 

37,788 ac-ft per year (23,427 gpm) during maximum demand conditions.” Per response to RAI 

05.02-08, please revise the statement accordingly: “The expected consumptive surface-water 

use of proposed Units 3 and 4 would be 37,430 ac-ft per year (23,190 gallons per minute [gpm]) 

during normal operations and 38,050 ac-ft per year (23,570 gpm) during maximum demand 

conditions”. (0010-2-44 [Head, Scott]) 

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-10, Line 18: The 

DEIS states that: “...under normal operations and 69,004 act-ft per year....” Although not stated 

in this paragraph, the maximum annual value for Units 1 & 2 is stated in the response to RAI 
Appendix E 

NUREG-1937 E- 26 February 2011 

05.02-07 as 37,200 ac-ft per year. Thus, this would be 38,050 + 37,200 = 75,250 ac-ft per year. 

(0010-2-48 [Head, Scott]) 

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-10, Lines 18-19: 

The DEIS states that: ”... per year (42,780 pgm)....” Although not stated in this paragraph, the 

maximum annual value for Units 1 & 2 is stated in the response to RAI 05.02-07 as 37,200 ac-ft 

per year, which equates to 23,063 gpm. Thus, this would be 23,570 + 23,063 = 46,633 gpm.) 

(0010-2-49 [Head, Scott]) 

Response: Section 7.2.1.1 of the EIS was updated in response to these comments. 

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-10, Lines 16-17: 

The DEIS states that: ”... from the Colorado River from 2001 through 2006 (STPNOC 2009a).” 

Please revise the statement accordingly: ”... from the Colorado River from 2001 through 2004 

(STPNOC 2009c).” As corrected in the response to RAI 05.02-07 with markups in response to 

RAI 05.10-4, the Units 1 & 2 average consumptive use value used here is not a 6-year average, 

but rather is a computed 3-year (2004, 2005, and 2006) average value cited in COL 3 & 4 ER 

Table 2.9S-1. An average long term consumptive use was calculated to be 33,200 acre-ft per 

year for Units 1 and 2 per the response to RAI 05.02-07. (0010-2-45 [Head, Scott]) 

Response: In ER Revision 4, Table 2.3.2-8, STPNOC states that the average amount of water 

diverted from the Colorado River is 37,804 ac-ft/yr. The sentence on draft EIS page 7-10, lines 

16-17, described the water diverted from the Colorado River during 2001 to 2006. The final EIS 

was updated to correct the typographical error. 

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-10, Lines 17-18: 

The DEIS states that: “Together, all four STP units would consume approximately 68,714 ac-ft 

per year...”. The 3-yr average for all four units would be 74,513 ac-ft/yr. (0010-2-46 [Head, 

Scott]) 

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-10, Line 18: The 

DEIS states that: “...per year (42,600 gpm)...”. The 3-yr average for all four units would be 

46,180 gpm. (0010-2-47 [Head, Scott]) 

Response: The review team is not using three-year average values on draft EIS page 7-10, 

lines 17-18. For the cumulative impact assessment, the long-term average water use is being 

used. Section 7.2.1.1 of the final EIS was updated to clarify the review team’s assessment. 

Comment: DEIS Section 09.04. System Design Alternatives. Page 9-208, Line 23: The DEIS 

states that UHS system discharges account for approximately 500 gpm of groundwater 

discharged to the MCR. The UHS discharge is estimated at 283 gpm (see stream 5 in ER 

Table 3.3-1, Figure 3.3-1) under normal operations. The total discharge to the MCR (stream 10) 
Appendix E 

February 2011 E-27 NUREG-1937 

is 530 gpm, or approximately 500 gpm as stated in the DEIS, but that estimate includes sanitary 

waste, liquid radwaste, and wastewater retention basin effluents in addition to the UHS system 

discharges. Clarify that the discharge of 500 gpm to the MCR is not solely a result of UHS 

system discharges. (0010-2-68 [Head, Scott]) 

Response: Section 9.4 of the EIS was revised to update the description of the ultimate heat 

sink (UHS) discharge in response to this comment. 

Comment: The EIS is deficient in its evaluation of surface water issues which are especially 

important in Matagorda County as keeping sufficient freshwater inflow to our delicate bay and 

estuary system assures the success of not only the commercial and recreational fishing 

industries, but also overall health of the Gulf which are all dependent on the aquatic 

reproduction based at or near Matagorda County. The LCRA-SAWS (Lower Colorado River 

Authority-San Antonio Water System) is touted as being one solution to the shortage of river 

water; desalinization is another. The LCRA-SAWS project was officially canceled long before 

the draft EIS was released and should not, therefore, be considered part of the solution for the 

water shortage (http://www.lcra.org/water/facts.html). The predicted rise in sea level due to 

climate change will push brackish water even further inland, exacerbating the effects of loss of 

freshwater inflow (Draft NUREG-1937, 2-15). (0013-2 [Dancer, Susan]) 

Response: The review team evaluated the impact of proposed STP Units 3 and 4 water use in 

Section 5.2.2.1 of the EIS. The review team considered the cumulative impacts of the 

LCRA-SAWS project and global climate change (GCC) in Section 7.2.1.1. The review team 

considered the LCRA-SAWS water project to export water out of the Lower Colorado River 

Basin as a possible future cumulative impact and not as a solution to water shortage. Although 

the LCRA-SAWS water project is currently on hold because of ongoing legal proceedings, no 

announcement of project cancellation has been made. The review team used available 

instream flow requirements for bays and estuaries in its assessment. No changes were made 

to the EIS as a result of this comment. 

Comment: In the case of ... surface water issues, the EIS asserts that because Texas has 

rights of ownership which STP has already purchased, the issues are resolved. This is not a 

thorough or sufficient visitation or resolution of these issues. To claim that STP has purchased 

water that, by its own admission doesn’t exist (Draft NUREG-1937, 2-33, 2-133) is 

preposterous. Secondly, no sense of social justice can be preserved when a community is 

being told that it can rely on a defunct inter-municipal agreement (LCRA-SAWS) combined with 

undeveloped, super expensive futuristic technology (desalinization) to meet its most base needs 

such as drinking water. (0013-5 [Dancer, Susan]) 

Response: The review team considered the effect of increased water use by the proposed 

STP Units 3 and 4 on the available water resource of the Colorado River in Chapter 5 of the 

EIS. The review team considered the effects of water use for all four units and the water use for 
Appendix E 

NUREG-1937 E- 28 February 2011 

other existing, proposed, and reasonably foreseeable future actions in Chapter 7 of the EIS. 

The review team considered the LCRA-SAWS water project to export water out of the Lower 

Colorado River Basin as a possible future cumulative impact and not as a solution to water 

shortage. Section 7.2.1.1 describes that after accounting for known and reasonably foreseeable 

future water usage, Region K would have surplus water supply with implementation of all water 

management strategies described in the 2007 State Water Plan by 2060. Therefore, the review 

team concluded that the impact of the water usage by known and reasonably foreseeable future 

projects on surface water resources of Region K would be noticeable, but not destabilizing. No 

changes were made to the EIS as a result of this comment. 

Comment: The DEIS acknowledges that a rising sea level caused by climate change could 

cause salt water to flow farther up the Colorado River towards the Reservoir Makeup Pumping 

Facility but does not consider the increased salinity of the water on plant operations. Increased 

salinity of water from the Colorado River could have adverse effects on plant operations. 

(0015-4 [Johnson, Matthew]) 

Response: The review team considered the impact from construction and operation on the 

environment in the EIS. Any adverse effects on the new units caused by events in the 

environment are evaluated in the NRC’s Safety Evaluation Report. This comment is beyond the 

scope of the environmental review and therefore no changes were made to the EIS as a result 

of this comment. 

Comment: The review team failed to analyze the impact of increased ambient air and cooling 

water temperatures on operations. Nor did it analyze the impact of the increase thermal loading 

resulting from the discharge. Both of these impacts were raised during public comments on 

these plants. The failure of the NRC’s staff to analyze these impacts is a serious omission. 

(0015-30 [Johnson, Matthew]) 

Comment: The DEIS fails to consider the effect of global warming on operations of STP Units 

3 & 4 related to 1) water availability and 2) increased ambient temperatures of air and the effect 

of higher cooling water temperatures. The failure to consider these adverse impacts has the 

effect of omitting material information concerning water usage and temperature thereof and 

effects on plant operations. This omission has the effect of overstating relative advantages of 

nuclear power and understating environmental impacts. (0015-6 [Johnson, Matthew]) 

Response: The review team considered effects related to GCC in Section 7.2 of the EIS. 

Based on available information, the review team concluded that GCC could result in decreased 

precipitation and increased temperatures in the lower Colorado River basin. These forecasted 

changes have the potential to reduce surface runoff and increase evapotranspiration and may 

result in reduction in the surface water resource in the region. To the extent that these 

comments are focused on adverse effects on the new units caused by events in the 

environment rather than effects on the environment from construction and operation of the new 
Appendix E 

February 2011 E-29 NUREG-1937 

units, the comments are beyond the scope of the environmental review. The concluding 

statements in Sections 7.2.1.2 and 7.2.2.2 now draw the distinction between global and local 

effects of climate change. The review team stated in Section 7.2 that while the changes from 

GCC may not be insignificant nationally or globally, the review team has not identified anything 

that would alter the conclusions presented regarding surface water use and quality in the 

geographical area of interest. 

Comment: The DEIS analysis of surface water availability fails to account for the sale of 

19,356 acre ft/yr from the Colorado River to the Las Brisas coal-fired power plant. 

The David Power Report notes that the water resources for Units 3 & 4 operations has been 

diminished by the recent sale of 19,356 acre ft/yr from the Colorado River for use by the Las 

Brisas coal-fired power plant. The DEIS does not discuss this transaction nor the effects thereof 

on the assumed volume of water available from the Colorado River for Units 3&4 operations. 

This is a material omission from the DEIS discussion of surface water impacts and is significant, 

particularly in low-flow periods, when STP units will be competing for scarce water resources 

with other power plants. (0015-12 [Johnson, Matthew]) 

Comment: Since the DEIS was released, at least two significant events have occurred: 

The Corpus Christi, Texas, City Council has approved the sale of water to the proposed Las 

Brisas coal plant. The City will be piping water from the Colorado River to the serve the needs 

of this plant. This new plant will could withdraw as much as 19,356 acre feet a year from the 

Colorado, thus decreasing water flow to STP Units 3 and 4. (0015-16 [Johnson, Matthew]) 

Comment: Additional Water Demands Not Addressed in the DEIS: Two new proposed coal 

plants will use significantly more water than is currently withdrawn from the Colorado River. 

Since the DEIS was written, the Corpus Christi City Council has authorized the City Manger to 

negotiate a contract to sell water from the Colorado River to the Las Brisas Energy Center. 

That means a total of nearly 39,000 acre feet of Colorado water will consumed before it reaches 

the STP water intake, thus reducing the availability of make-up water. 

(0015-29 [Johnson, Matthew]) 

Response: The last of the three proceeding comments (0015-29) mentions two coal plants but 

names only the Las Brisas Energy Center. The review team assumed that the commenter 

meant the second one of these to be the White Stallion Energy Center near Bay City, Texas. 

The impact of White Stallion Energy Center’s 22,000 ac-ft/yr water use was described in Draft 

EIS Section 7.2.1.1. 

According to the minutes of the May 11, 2010 (City of Corpus Christi 2010), meeting of the City 

Council of the City of Corpus Christi, the water that it has agreed to provide to the Las Brisas 

Energy Center will be supplied from its current water supplies and not from the Colorado River. 
Appendix E 

NUREG-1937 E- 30 February 2011 

This assessment is consistent with the fact that the City has no water supply pipeline from the 

Lower Colorado River and no plans to have one by the time Las Brisas Energy Center is 

expected to begin operations in 2013. Based on this information (which contradicts much of the 

information in the comments), the review team concluded that the Las Brisas Energy Center 

would not contribute to the cumulative impacts of the proposed action to build two new nuclear 

units at the STP site and therefore Las Brisas Energy Center is not discussed in the body of this 

EIS. However, the review team notes that the City of Corpus Christi does own water rights 

amounting to 35,000 ac-ft/yr in the Lower Colorado River and that it retains the option to use 

this water via the construction of Phase II of the Mary Rhodes pipeline (City of Corpus Christi 

2009). According to the City, the water would be used to meet growing demand when needed, 

with an operational date currently estimated in the 2020 to 2030 timeframe (City of Corpus 

Christi 2009). 

In response to the comments, Sections 2.3 and 7.2 of the EIS were updated to include a 

description and an evaluation of the impact of the City’s use of its 35,000 ac-ft/yr Colorado River 

water rights. 

City of Corpus Christi. 2009. Garwood Pipeline Project, Project Update 2009. October 2, 

2009. Water Department, Corpus Christi, Texas. Available at 

http://www.cctexas.com/files/g17/GarwoodCouncilPresentation100209.pdf. 

City of Corpus Christi. 2010. Minutes: City of Corpus Christi, Texas, Regular Council Meeting, 

May 11, 2010 – 12:00 p.m. May 11, 2010. City of Corpus Christi, Texas. Available at 

http://www.cctexas.com/files/g40/051110min5.pdf. 

Comment: The review team also found: “the projected change in precipitation from the “recent 

past” (1961-1979) to the period 2080 to 2099 is a decrease of between 10 to 30 percent (Karl et 

al. 2009).” (page 125 note 117). An additional recent study for the Texas Water Development 

board found: “The recent drought in the Southeastern U.S. during 2007 has drawn attention to 

the vulnerability of electric power production to low stream flows. In the Fall of 2007, the 

governor of Alabama wrote a letter to President Bush regarding a proposed Georgia water 

conservation strategy that threatened to shut down the Farley Nuclear Plant in Alabama due to 

a limited supply of cooling water [Riley, 2007]. As water consumption in other sectors increases 

over the next 50 years, the power sector, Central and West Texas in particular, will become 

increasingly vulnerable to drought. Drought can threaten the ability to cool a steam-electric 

power plant if insufficient water is available for diversion and/or withdrawal.” (0015-28 [Johnson, 

Matthew]) 

Response: The review team described the current operation of STP Units 1 and 2 in Chapter 2 

of the EIS and that of the proposed STP Units 3 and 4 in Chapter 5. The MCR stores cooling 

water and is filled during relatively high flows in the Colorado River. During an extended 
Appendix E 

February 2011 E-31 NUREG-1937 

drought, if all water rights available to STPNOC have been used and if the water stored in the 

MCR is not sufficient to support plant operations and to comply with all permit requirements, the 

units would not be expected to remain in operation; provisions may exist to allow the plant to 

continue to operate in energy emergency situations. The review team considered the effects of 

prolonged droughts, including the most severe historical droughts, in its analysis in Chapters 5 

and 7. Section 7.2.1.1 describes that after accounting for known and reasonably foreseeable 

future water usage, Region K would have surplus water supply with implementation of all water 

management strategies described in the 2007 State Water Plan by 2060. Therefore, the review 

team concluded that the impact of the water usage by known and reasonably foreseeable future 

projects on surface water resources of Region K would be noticeable, but not destabilizing. No 

changes were made to the EIS as a result of this comment. 

Comment: DEIS Section 10.02. Unavoidable Adverse Environmental Impacts. Page 10-8, 

Lines 7-8 and Table 10-2: The DEIS states that water use and quality would be affected during 

operations due to potential increases in sedimentation to surface waters and potential surface 

and groundwater contamination from spills. The Environmental Report (Rev. 3.0) makes no 

mention of sedimentation issues to surface water during operation. The Environmental Report 

(Rev. 3.0) indicates that groundwater quality could be affected by radioactive spills during a 

severe accident (Section 7.2.2.3). The consequences of a radioactive spill were evaluated in 

COLA Part 2, FSAR Subsection 2.4S.13 and the results show that if radioactive liquids were 

released directly to groundwater, the isotopic concentrations would be below 10 CFR 20 effluent 

limits before they reached a drinking water receptor. This does not seem to be the issue being 

addressed in Chapter 10 of the DEIS; therefore, it is unknown what drives this statement. 

Inadvertent spills are not listed as a water use or quality impact from operations in the ER. 

(0010-2-72 [Head, Scott]) 

Response: Any active industrial site could result in sedimentation from stormwater runoff. 

These effects are controlled and managed by best management practices and permitted under 

Texas Pollutant Discharge Elimination System (TPDES). Any nonradioactive spills that occur at 

the site also would be addressed by the TPDES permit and required to be cleaned up as soon 

as possible. No changes were made to the EIS as a result of this comment. 

Comment: The DEIS also failed to analyze the impact of increased ambient air and cooling 

water temperatures on operations. Nor did it analyze the impact of the increase thermal loading 

resulting from the discharge. 

In its review the NRC staff found: The review team determined that the forecasted changes 

could affect water supply and water quality in the Colorado River Basin during operation of the 

proposed STP Units 3 and 4. For the water use and water quality assessments discussed 

below, the review team considered forecasted changes to temperature and precipitation for the 

entire Colorado River watershed. The projected change in temperature from “present day” 
Appendix E 

NUREG-1937 E- 32 February 2011 

(1993-2008) to the period encompassing the licensing action (i.e., the period of 2040 to 2059 in 

the GCRP report) for the Colorado River watershed is an increase of between 0 to 5[degrees]F. 

GCC could result in decreased precipitation and increased temperatures in the lower Colorado 

River basin. These forecasted changes have the potential to reduce surface runoff and 

increase evapotranspiration. The changes may result in reduction in the surface water resource 

in the region. (p.7-13) The review team failed to examine the impact of increased ambient 

temperature on the temperature of the cooling water reservoir. Large coal and nuclear plants 

have been limited in their operations by reduced river levels caused by higher temperatures and 

thermal limits on water discharge. (0015-27 [Johnson, Matthew]) 

Response: In Section 7.2.1.1 of the EIS, the review team determined, based on its 

independent review of the recent compilation of the state of knowledge by the GCRP that GCC 

could result in decreased precipitation and increased temperatures in the lower Colorado River 

Basin. These forecasted changes have the potential to reduce surface runoff and increase 

evapotranspiration. The changes may result in reduction in the surface water resource in the 

region. While these changes from GCC may not be insignificant nationally or globally, the 

review team has not identified anything that would alter its conclusions that the cumulative 

impact on surface water use in the geographical area of interest is noticeable. Furthermore, 

volume and temperature of discharges from the STP units are and would be controlled under a 

TPDES permit. Based on the review team’s assessment described in Chapters 5 and 7 of the 

EIS, there is sufficient available operational flexibility in the MCR-Colorado River system to 

accommodate discharges from the MCR with all four STP units operating. No changes were 

made to the EIS as a result of this comment. 

E.2.9 Comments Concerning Hydrology – Groundwater 

Comment: They [STPNOC] are a good steward of their underground water also. (0003-35

[Mann, Billy]) 

Response: This comment expresses general support for STPNOC, specifically their use of 

groundwater; therefore, no changes were made to the EIS as a result of this comment.

Comment: The U.S. Environmental Protection Agency Region 6 Ground Water Center has 

reviewed the Draft Environmental Impact Statement for Combined Licenses for South Texas 

Project Electric Generating Station Units 3 and 4. The document was reviewed mainly from the 

perspective of how the project will affect ground water. It appears that, based on the 

information contained in the report, the project should not have a significant impact on the 

regional ground water resources. ... Recent trends show a decline in use of ground water the 

area. Using the permitted 3000 ac/ft/yr average withdrawal rate analysis demonstrated that the 

drawdown would be substantially less than the confining pressure in the Deep Aquifer and have 

a minimal regional affect to the ground water resource. The EPA Region 6 Ground Water 
Appendix E 

February 2011 E-33 NUREG-1937 

Center agrees with the project review team’s conclusion that impacts to the ground water 

resource will be small. (0006-1 [Bechdol, Michael]) 

Comment: The report indicates the South Texas Plant Electric Generating Station (STP) site 

already has 3000 ac/ft/yr of ground water allocated to it, while none of the other alternative 

nuclear locations or other types of energy plants are as efficient in the use of water resources. 

(0006-2 [Bechdol, Michael]) 

Response: These comments reflect EPA Region 6 Ground Water Center’s review of the draft 

EIS, specifically groundwater. No changes were made to the EIS as a result of these 

comments. 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-26, Lines 24-26: The DEIS 

states: “The bottom of the MCR is unlined and acts as a local recharge source for the Upper 

Shallow Aquifer, and it appears to cause some mounding in the Upper Shallow Aquifer and 

possibly the Lower Shallow Aquifer (STPNOC 2008c, 2009c).” Although the cited reference 

STPNOC 2008c, dated December 18, 2008 (response to ER RAI 02.03-07), did indicate that 

“...postulated mounding in the aquifer is plausible due to the influence of the MCR,” the results 

of subsequent analyses as discussed in the response to FSAR RAI 02.04.12-28 (STPNOC 

2009c, dated September 21, 2009) determined that there are “...no obvious mounding impacts 

to the Lower Shallow aquifer from the MCR.” Thus, the DEIS statement should be clarified to 

delete the following portion of the sentence “...and possibly the Lower Shallow Aquifer”. 

(0010-1-8 [Head, Scott]) 

Response: Section 2.3.1.2 of the EIS was revised to include reference to Updated Final Safety 

Analysis Report (UFSAR) Figures 2.4.13-17 and 2.4.13-17A (UFSAR STP Units 1 and 2). The 

influence of the MCR on the Lower Shallow Aquifer cannot be ruled out based solely on the 

STPNOC responses to RAIs 02.04.12-20 (December 30, 2008) and 02.04.12-28 (September 

21, 2009) because of the apparent change in the piezometric contours within the Lower Shallow 

Aquifer since pre-site conditions. STPNOC stated in response to RAI 02.04.12-30 (September 

21, 2009) that observed tritium concentrations in the Upper and Lower Shallow Aquifers support 

a downward vertical gradient. STPNOC concluded in the above-mentioned RAI response that 

“... due to the pervasive downward vertical hydraulic gradient, releases to the Upper Shallow 

aquifer will flow downward to the Lower Shallow aquifer where the hydraulic conductivity of the 

material separating the aquifers is conducive to downward flow” and that the finding supports 

the site conceptual model. Because of the presence of downward vertical gradient at the STP 

site, water seeping out of the unlined bottom of the MCR would pass through the Upper Shallow 

Aquifer and may eventually migrate to the Lower Shallow Aquifer. Therefore, STPNOC’s data 

and assessment based on this data support the EIS conclusion that some mounding in the 

Lower Shallow Aquifer is possible. 
Appendix E 

NUREG-1937 E- 34 February 2011 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-27, Lines 10-12: The DEIS 

states: “In the vicinity of the proposed and existing STP units, where the confining unit has been 

removed, the hydraulic gradient between Upper and Lower Shallow aquifers is downward, and 

groundwater movement is known to occur between them (see ER Section 2.3.1.2.5.1).” The 

cited Environmental Report (Rev. 3.0) subsection, does not make explicit statements that 

“groundwater movement is known to occur” between the two aquifers. Thus, without direct 

evidence, such as might be obtained from a tracer test, groundwater movement between the 

Upper and Lower Shallow aquifers can only be interpreted (or hypothesized) to occur. To 

eliminate any misunderstanding, the DEIS statement should be clarified to read, “In the vicinity 

of the proposed and existing STP units, where the confining unit has been removed, the 

hydraulic gradient between Upper and Lower Shallow aquifers is downward, and groundwater 

movement is interpreted to occur between them (see ER Section 2.3.1.2.5.1).” 

(0010-1-9 [Head, Scott]) 

Response: Section 2.3.1.2 of the EIS was revised to include reference to STPNOC’s response 

to RAI 02.04.12-30 (September 21, 2009), which describes monitoring of a tritium leak in the 

vicinity of STP Units 1 and 2. This leak is essentially a tracer test and direct evidence of 

downward groundwater movement between the Upper and Lower Shallow aquifers. 

Comment: DEIS Section 02.03.01. Water- Hydrology, Page 2-27, Lines 13-15: The DEIS 

states: “Potentiometric measurements completed in September 2008 in the vicinity of Kelly Lake 

indicate an upward groundwater gradient between Lower and Upper Shallow aquifers, and a 

hydraulic equilibrium between the Upper Shallow Aquifer and Kelly Lake (STPNOC 2008g).” 

The response to FSAR RAI 02.04.12-20 (STPNOC 2008g) states: “September 2008 

groundwater levels measured in new observation wells near the lake indicate an upward flow 

potential from the Lower to Upper Shallow aquifer and a piezometric surface in the Upper 

Shallow Aquifer essentially equal to the water level in the lake. These findings suggest that 

groundwater from the nearby Shallow Aquifer discharges to Kelly Lake.” The following text in 

the DEIS statement “...a hydraulic equilibrium....” suggests that neither discharge from nor 

recharge to the groundwater system from the lake is occurring, which is distinctly different from 

the statements provided in the RAI response. (0010-1-10 [Head, Scott]) 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-27, Lines 33-34: The DEIS 

states: “Groundwater production wells located along the northern perimeter of the MCR 

withdraw....” Environmental Report (Rev. 3.0) Figure 2.3.2-4, shows Production Well No. 8 

located on the east side of the existing plant site, which is not directly located along the northern 

perimeter of the MCR. The DEIS statement could better state, “Groundwater production wells 

located north of the MCR withdraw....” (0010-1-11 [Head, Scott]) 

Comment: DEIS Section 02.03.01. Water - Hydrology, Page 2-28, Lines 7-8: The DEIS states: 

“Groundwater reversal is occurring locally to the STP production wells with groundwater being 

drawn to the wells from the northwest and southeast.” Environmental Report (Rev. 3.0) 
Appendix E 

February 2011 E-35 NUREG-1937 

Subsection 2.3.1.2.3.4 states: “The onsite Deep Aquifer potentiometric surface suggests a 

reversal of the regional flow direction in the southern portion of the map, where flow is north 

toward the site pumping wells, rather than toward the southeast.” As indicated in the ER, 

groundwater is being drawn to the production wells in approximately a radial pattern, not just 

from the northwest and southeast. Thus, the DEIS statement should be clarified to eliminate 

any misunderstanding. (0010-1-12 [Head, Scott]) 

Response: Section 2.3.1 of the EIS was revised based on information provided in these 

comments.

Comment: DEIS Section 03.02. Proposed Plant Structures. Page 3-11, Line 3: The DEIS 

states, “Groundwater wells are planned to dewater deep excavations in the power block region.” 

For clarity, STPNOC recommends the phrase “Groundwater wells” be replaced with 

“Dewatering wells.” (0010-1-41 [Head, Scott]) 

Comment: DEIS Section 03.03. Construction and Preconstruction Activities. Page 3-15, Line 2: 

The DEIS states, “The slurry wall would be installed into the Upper Aquifer in the power block 

area.” To be consistent with terminology in Environmental Report (Rev. 3.0) Subsection 

2.3.1.2.3.1, STPNOC recommends this statement be revised to state: “The slurry wall would be 

installed into the Shallow Aquifer in the power block area.” (0010-1-42 [Head, Scott]) 

Comment: DEIS Section 03.03. Construction and Preconstruction Activities. Page 3-15, Line 

17: The DEIS states, “Wells would be drilled using standard drilling practices into the Upper 

Aquifer.” To be consistent with terminology in Environmental Report (Rev. 3.0) Subsection 

2.3.1.2.3.1, the statement should be clarified to state: “Wells would be drilled using standard 

drilling practices into the Shallow Aquifer.” (0010-1-44 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-19, Line 3-4: The DEIS states, 

“STP estimates that the two proposed units would require approximately 1242 gpm of 

groundwater during normal operation and 4108 gpm during shorter-term peak demand periods.” 

STPNOC’s response to NRC Request for Additional Information (RAI) 05.10-4, identifies the 

correct number during normal operation of 975 gpm, and the correct number during shorter-term 

peak demand periods of 3434 gpm. STPNOC recommends that the DEIS be revised to reflect 

the current estimates provided in STPNOC’s response to RAI 05.10-4 (STPNOC Letter U7-CSTP-NRC-090164 dated September 28, 2009). (0010-1-47 [Head, Scott]) 

Response: Sections 3.2, 3.3, and 3.4 of the EIS were revised based on information in these 

comments. 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-8, Line 21: The 

DEIS states that there is no permit limit on short-term groundwater demands. The term permit 
Appendix E 

NUREG-1937 E- 36 February 2011 

limit should be replaced with available groundwater withdrawal capacity. (0010-1-62 [Head, 

Scott]) 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-8, Line 30: The 

DEIS states that “... the distance allowed by CPGCD between groundwater production wells.” 

Please insert the text “unless the wells are owned by the same person(s)” at the end of the 

sentence above. (0010-1-63 [Head, Scott]) 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-8, Lines 35-36: 

The DEIS states that existing STPNOC production wells are pumped at 500 gpm and extend 

down to approximately 700 ft bgs. ER Rev. 3 Section 2.3.2.2.1 and Table 2.3.2-17 indicates 

that the production wells range in depth from 600 to 700 ft bgs with design pumping capacities 

ranging from 200 to 500 gpm. However, the wells are pumped at much less than their design 

capacity: As summarized in ER Rev. 3 Section 2.3.2.2.1 and Table 2.3.2-18, the average 

pumping rate of the wells collectively between 2001 and 2006 ranged from 745 to 863 gpm 

(note: only several of the five wells are pumped simultaneously). (0010-1-64 [Head, Scott]) 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-9, Line 11: The 

DEIS states that “At a distance of 2500 ft from the production well, the nearest allowed well 

location per CPGCD rules...”. STPNOC recommends that the sentence be modified 

accordingly: “At a distance of 2500 ft from the production well, the nearest allowed well location 

per CPGCD rules for wells that are not owned by the same person(s)....” (0010-1-65 [Head, 

Scott]) 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-10, Lines 3-4: 

The DEIS states that “ ... and 2 operations, and may install and operate one or more additional 

well to decrease pumping rates...” STPNOC recommends that the sentence be modified as 

follows: “ ... and 2 operations, and may install and operate one or more additional wells to 

decrease pumping rates to ensure sufficient withdrawal capacity to serve the total site water use 

under the existing groundwater permit (STPNOC 2009c).” (0010-1-66 [Head, Scott]) 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-10, Line 7: The 

DEIS states that “ ... CPGCD requires that wells be no closer than 2500 ft apart.” STPNOC 

recommends that the sentence be modified as follows: “ ... CPGCD requires that wells be no 

closer than 2500 ft apart, unless the wells are owned by the same owner(s).” 

(0010-1-67 [Head, Scott]) 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-10, Line 12: 

The DEIS states that “Since building the proposed new units would use an estimated 1062 gpm 

....” STPNOC recommends that the sentence be modified as follows: “Since building and 

operating the proposed new units would use an estimated maximum of 1062 gpm ....” 

(0010-1-68 [Head, Scott]) 
Appendix E 

February 2011 E-37 NUREG-1937 

Comment: DEIS Section 04.02. Water-Related Impacts - Construction. Page 4-10, Line 15: 

The DEIS states that “ ... one impact of developing the proposed units is a reduction of 1062 

gpm ....” STPNOC recommends that the sentence be modified as follows: “ ... one impact of 

developing the proposed units is a reduction of up to 1062 gpm.....” (0010-1-69 [Head, Scott]) 

Response: Section 4.2 of the EIS was revised based on information provided in these 

comments. 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-12, Lines 7-8: The 

DEIS states that “Drawdown is evaluated at the property line and at a point 2500 ft from the well 

because that is the minimum distance allowed by the CPGCD between groundwater production 

wells (CPGCD 2009).” The statement is not true for wells owned by the same owners. 

STPNOC suggests that the sentence be changed accordingly: “Drawdown is evaluated at the 

property line and at a point 2500 ft from the well because that is the minimum distance allowed 

by the CPGCD between groundwater production wells not owned by the same owner. (CPGCD 

2009).” (0010-2-10 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts 1 Operation. Page 5-12, Line 25: The 

DEIS states that “At a distance 2500 ft from the production well, the nearest allowed well 

location per CPGCD rule....” The statement is not true for wells owned by the same owners. 

STPNOC suggests that the sentence be changed accordingly: “At a distance 2500 ft from the 

production well, the nearest allowed well location per CPGCD rule for groundwater production 

wells that are not owned by the same person(s) ....” (0010-2-11 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-12, Line 28: The 

DEIS states that “...the location 2500 ft from an STP production well is the ....” STPNOC 

suggests that the sentence be modified accordingly: “...the location 2500 ft from an STP 

production well is assumed to be the ...” (0010-2-12 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-18, Lines 36-38: 

The DEIS states that the bottom of the existing STPNOC production wells are at 700 ft bgs with 

pumping capacities of 500 gpm. ER Rev. 3 Section 2.3.2.2.1 and Table 2.3.2-17 indicates that 

the production wells range in depth from 600 to 700 ft bgs with design pumping capacities 

ranging from 200 to 500 gpm. (0010-2-15 [Head, Scott]) 

Response: Section 5.2 of the EIS was revised based on information provided in these 

comments.

Comment: DEIS Section 07.02. Water Use and Quality - Cumulative. Page 7-15, Lines 5-6: 

The DEIS states that: “... annual average normal operation of groundwater requirement of 1860 

gpm (3000 ac-ft/yr), which is the maximum usage allowed under the groundwater use....” 

Please modify the statement accordingly: “... normal operation of groundwater requirement of 
Appendix E 

NUREG-1937 E- 38 February 2011 

9000 ac-ft over the approximately 3-year term of the groundwater use permit, which is the 

maximum usage allowed under the groundwater use....” (0010-2-50 [Head, Scott]) 

Response: Section 7.2 of the EIS was revised based on information in this comment.

Comment: DEIS Section 09.04. System Design Alternatives. Page 9-208, Line 28: The DEIS 

states that groundwater wells at the STP site must be separated by 2500 ft from neighboring 

Deep Aquifer wells. The Coastal Plains Groundwater Conservation District rules do not specify 

a minimum well spacing for wells owned by the same owner. Add text “owned by different 

owners” after “...neighboring Deep Aquifer wells.” (0010-2-69 [Head, Scott]) 

Comment: DEIS Section 09.04. System Design Alternatives. Page 9-208, Lines 31-33: The 

DEIS concludes it would not be possible to locate the required number of wells on the STP site. 

This conclusion is not supported since the analysis in the DEIS is based on a minimum well 

spacing of 2500 ft. The Coastal Plains Groundwater Conservation District rules do not impose 

minimum well spacing requirements for wells owned by the same owner. 

(0010-2-70 [Head, Scott]) 

Response: Section 9.4 of the EIS was revised based on information provided in these 

comments.

Comment: DEIS Section 10.02. Unavoidable Adverse Environmental Impacts. Page 10-4, 

Table 10-1: The DEIS states that an Unavoidable Adverse Impact to Water Quality would be 

“inadvertent spills that seep into aquifers and saltwater intrusion”. The Environmental Report 

(Rev. 3.0) indicates that only shallow aquifers would be affected (Section 4.2.3.2). Additionally, 

the wording could be misunderstood as if the spills would be caused by carelessness with no 

attempt to prevent or remediate. It should be re-worded to say “Seepage into aquifers from 

spills that are unable to be contained or remediated ...” Saltwater intrusion is not listed as a 

water quality impact in the ER. (0010-2-71 [Head, Scott]) 

Response: Section 10.2 of the EIS was revised based on information provided in this 

comment. 

Comment: DEIS Section 03.03. Construction and Preconstruction Activities. Page 3-17, Table 

3-2: The DEIS states, the “Value” of the “Hydrology-Groundwater” is “95 ft below grade.” This 

value should be changed to 100 ft, for consistency with the STP Units 3 and 4 Final Safety 

Analysis Report. (0010-1-45 [Head, Scott]) 

Response: In Revision 3 of the Final Safety Analysis Report (FSAR), Section 2.5S.4.5.2.1, 

the deepest excavation is identified as 94 ft below the proposed rough grade, and in FSAR 

Revision 3, Section 2.5S.4.5.4.1, dewatering is identified as 3 ft below the excavation and 5 ft 
Appendix E 

February 2011 E-39 NUREG-1937 

below slope faces. Table 3-2 of the EIS was clarified to show “... 94 ft below plant grade” and 

“... Excavation depth for which dewatering would be required.” 

Comment: The EIS is deficient in addressing ground water issues as well. Much rhetoric is 

available in the document about Texas’ ground water ownership and STP’s having already 

purchased enough to supply their needs, but it is also clear that more future water rights have 

been sold than will be physically available. (0013-3 [Dancer, Susan]) 

Comment: In the case of ... ground water ... issues, the EIS asserts that because Texas has 

rights of ownership which STP has already purchased, the issues are resolved. This is not a 

thorough or sufficient visitation or resolution of these issues. To claim that STP has purchased 

water that, by its own admission doesn’t exist (Draft NUREG-1937, 2-33, 2-133) is 

preposterous. (0013-4 [Dancer, Susan]) 

Response: The review team also is concerned with use of the groundwater resource during 

building and operation of the proposed units. These comments on Chapter 2 of the EIS, 

subsections on water use and public services, are interpreted to apply to Section 2.3.2.2 

Groundwater Use. Section 2.3.2.2 does make it clear that permits issued by the Coastal Plains 

Groundwater Conservation District (CPGCD) for the period 2008 through 2010 exceed the 

amount of groundwater available in the county (see Table 2-4). Note, groundwater rights are 

not purchased in Texas; rather the groundwater conservation district allocates the groundwater 

resource through its permits according to its published rules. Note also that the allocated 

quantity has not been produced in Matagorda County. Production is governed by the 

infrastructure that is in place to produce groundwater. The CPGCD-estimated quantity of 

groundwater produced is well below both the managed available groundwater quantity and the 

allocated quantity (see Table 2-4). Therefore, while over-allocated, the groundwater resource is 

not over-produced. Because the full STPNOC permit is included in both the allocation total and 

the estimate of groundwater that can be produced, the groundwater needed to supply the 

proposed units represents a future demand that can be produced within the estimated quantity 

of the groundwater resource available in the county. The thorough discussion of potential 

impacts on groundwater use and quality with regard to building and operation of the proposed 

units can be found in Sections 4.2 and 5.2, respectively. To clarify the groundwater resource 

availability and use issue, Section 2.3.2.2 of the EIS, Groundwater Use, has been revised in 

response to these comments to provide a more complete statement of the groundwater 

available, allocated, and produced within the CPGCD. No changes were made to Section 

2.5.2.6 of the EIS, Public Services, because the evaluation of issues related to groundwater use 

and quality during building and operation of the proposed Units 3 and 4 appear in Sections 4.2 

and 5.2. 

Comment: The DEIS conclusion that impacts caused by changes in global climate change 

“may not be insignificant” fails to meet the requirements of 10 CFR 51.70(b) to be “clear and 

analytic”. 
Appendix E 

NUREG-1937 E- 40 February 2011 

The DEIS describes climate change impacts related to groundwater as “not insignificant”. 

Despite this somewhat ambiguous conclusion, the DEIS determined no alterations to its 

conclusions regarding groundwater ... were warranted. As a result of this conclusion, the 

cumulative impacts on groundwater ... were characterized as “small”. The DEIS findings that 

certain impacts are “not insignificant” is inconsistent with conclusions that are considered 

“small”. In effect, the DEIS concedes the impacts are significant but then reaches an 

inconsistent conclusion that the effects thereof are “small”. In this regard, the DEIS fails to 

satisfy 10 CFR 51.70(b) that requires the document to be, inter alia, clear and analytic. This 

requirement is not satisfied because the DEIS makes no attempt to reconcile its findings of 

significant impacts with conclusions that such have only minimal effects. Instead the DEIS 

makes the unsupported and contradictory analytic leap that significant impacts yield only small 

effects. One court has described the EIS adequacy criteria as follows: (1) whether the agency in 

good faith objectively has taken a hard look at the environmental consequences of a proposed 

action and alternatives; (2) whether the EIS provides detail sufficient to allow those who did not 

participate in its preparation to understand and consider the pertinent environmental influences 

involved; and (3) whether the EIS explanation of alternatives is sufficient to permit a reasoned 

choice among different courses of action. The DEIS has failed to take a “hard look” at impacts it 

determines are “not insignificant” and instead merely concludes such have small effects. This 

failure does not provide sufficient detail to understand how the conclusions were reached. As a 

result, the public and decision makers are unable to make reasoned choices among competing 

alternatives. (0015-10 [Johnson, Matthew]) 

Response: Climate change is a global phenomenon. The global atmospheric concentration of 

GHGs, which drives the climate change discussed in the EIS, will not be detectably altered by 

the building or the operation of the proposed units. The change to groundwater resources 

mentioned in the EIS (i.e., not insignificant) are those associated with climate change and not 

the incremental changes expected with the withdrawal of groundwater for the building and 

operation of the proposed units. Water resource managers are accustomed to adapting to 

historical climate variability. The review team considers the groundwater resource broadly to 

reflect the ability of the resource to meet multiple water demands and historical variability. The 

review team acknowledges that the global and local baseline of groundwater resources may 

change in a manner that is “not insignificant.” However, the review team did not identify a 

reasonably foreseeable baseline condition of the groundwater resources after the climate has 

changed that would alter the team’s conclusion regarding the impact of the proposed units. The 

review team recognized that climate change has the potential to affect groundwater in the 

region of interest, but the team’s overall conclusions on cumulative impacts were not altered. 

Regarding the commenter’s claim that the EIS “... does not provide sufficient detail to 

understand how the conclusions were reached,” the EIS does explain the review team’s 

conclusions regarding the impacts of climate change in the region of interest. The review team 

analyzed data in the EIS in a level of detail that was commensurate with the importance of the 

impact, with some less important material summarized, consolidated, or simply referenced. The 
Appendix E 

February 2011 E-41 NUREG-1937 

concluding statements in Sections 7.2.1.2 and 7.2.2.2 now draw the distinction between global 

and local effects of climate change. 

Comment: The DEIS is flawed because it failed to do a thorough analysis of the impact of 

climate change on the operation of STP Units 3 and 4. In its review the NRC staff found: 7.3.2 

Aquatic Ecosystem Impacts, GCC could lead to decreased precipitation, increased sea levels, 

varying freshwater inflow, increased temperatures, increased storm surges, greater intensity of 

coastal storms, and increased nonpoint source pollution from runoff during these storms, in the 

water bodies in the geographic area of interest (Nielsen-Gammon 1995; Montagna et al. 1995; 

Karl et al. 2009). Such changes could alter salinity, change freshwater inflow, and reduce 

dissolved oxygen, which could directly affect aquatic habitat. Rising sea water due to global 

climate change could affect water levels in the lower Colorado River and Matagorda Bay and 

subsequently change the water quality associated with the mixing of freshwater and estuarine 

waters (Montagna et al. 1995; Karl et al. 2009). (p.7-33,4) The staff further noted: While the 

GCRP has not incrementally forecasted the change in precipitation by decade to align with the 

licensing action, the projected change in precipitation from the “recent past” (1961-1979) to the 

period 2080 to 2099 is a decrease of between 10 to 30 percent (Karl et al. 2009). ( page 125 

note 117) The NRC staff also notes that: As stated in Section 2.3.1.1, it is reasonably 

foreseeable that sea level rise may exceed 3 ft by the end of the century due to GCC (Karl et al. 

2009). Actual changes in shorelines would also be influenced by geological changes in 

shoreline regions (such as sinking due to subsidence). The increase in sea level relative to the 

Colorado River bed, coupled with reduced streamflow (also due to GCC), could result in the salt 

water front in the Colorado River moving up towards the Reservoir Makeup Pumping Facility 

(RMPF). p.7-18 The Karl study the NRC selectively cited notes, “Sea level rise is expected to 

increase saltwater incursion into coastal freshwater aquifers, making some unusable without 

desalinization,” (Karl page 47-note 146) However, even with these concerns being explicitly 

stated, no analysis has been conducted in the DEIS on the impact of the salt water incursion 

into the Reservoir Makeup Pumping Facility or the increased salinity of the groundwater used 

for makeup. If the salinity increases the current fresh water based cooling system will be 

subject to corrosion and may become inoperable or need to be replaced by a desalinization 

facility. (0015-26 [Johnson, Matthew]) 

Response: The review team focused on the remarks related to saltwater effects on the cooling 

system. Even under the commenter’s postulated scenario, wherein the cooling system would 

temporarily become inoperable while repairs took place to mitigate corrosion impacts, the local 

environmental impacts from not operating the units would be less than operating the units. 

Although increased saltwater in the Colorado River is likely, the need for or use of a 

desalinization facility at STP is speculative and not currently proposed by the applicant, 

therefore the review team does not believe it necessary to evaluate the impacts of a 

desalinization facility. No changes were made to the EIS as a result of this comment. 
Appendix E 

NUREG-1937 E- 42 February 2011 

E.2.10 Comments Concerning Ecology – Terrestrial 

Comment: STP also provides a protected habitat for several threatened species, including bald 

eagles, white-tailed hawks, and alligators. (0003-28 [Chavez, Chance]; 0004-2-24 [Chavez, 

Chance]) 

Response: These comments provide general information related to STPNOC’s application for 

COLs. No changes to the EIS were necessary as a result of these comments. 

Comment: You will hear STP officials pledge their concern for the physical environment, and 

they do have responsibility for a huge chunk of our county, about 12,000 acres, I think. But who 

is this land’s husbandry entrusted to, the lowest bidder. Things like toxic herbicide and pesticide 

applications, and wildlife management are handled by some of the lowest paid, least welltrained contractors on site, not inhouse employees. Our state’s wildlife and fur bearing animals 

laws are regularly broken as underpaid, inexperienced staff kill protected species, relocate 

infectious disease specimens, and kill off honeybee swarms necessary for pollination of our 

food crops. I have personally spoken with some of the contractors, and the STP personnel in 

charge of them on multiple occasions. I’m a state-licensed wildlife rehabilitator, and regularly 

teach classes on peaceful and safe coexistence with our native species. When I offered to 

teach, or provide other instructors or free resources during the last wildlife crisis at STP, I was 

told, and I quote, “We’re not ready to take it to that level.” What does that say to you about 

STP’s real commitment to the environment where the rubber meets the road? (0004-2-7

[Dancer, Susan]) 

Response: Management and protection of wildlife in Matagorda County is under the 

jurisdiction of the Texas Parks and Wildlife Department (TPWD). This comment expresses 

opposition to STPNOC but does not identify any new issues to be addressed in the EIS. The 

NRC and Corps carefully reviewed the application according to their regulations that are 

intended to protect the environment. Enforcement of state laws is the sole responsibility of the 

State. No changes were made to the EIS as a result of this comment. 

Comment: DEIS Section 04.03. Ecological Impacts. Page 4-17, Line 10: To make this 

statement more precise, replace “the new roadway” with “construction of the new sections of the 

heavy haul road and for upgrade of existing site roadways.” (0010-1-70 [Head, Scott]) 

Response: Section 4.3.1 of the EIS was modified to include the proposed text. 

Comment: Three of the proposed road crossings have existing culverts that would be 

replaced, three additional culverts would be needed to span existing drainages, and one culvert 

would be added as part of preparing a new drainage area. This section of the DEIS does not 

clarify if the proposed haul road and associated wetland impacts from the barge-slip to the 

construction site is a new road or an expansion of the existing road. (0019-3 [Wolf, Clayton]) 
Appendix E 

February 2011 E-43 NUREG-1937 

Response: Section 4.3.1 of the EIS was amended to clarify that construction of the heavy haul 

road includes upgrades to the existing roadway and new road sections. 

Comment: Regarding potential wetland impacts, EPA suggests that all wetland sites be clearly 

marked, posted, flagged and/or fenced prior to construction. Such actions should prevent 

accidental or operator error impacts during construction. Once the project is completed, EPA 

recommends that a post construction review be held to ensure wetland impacts were avoided. 

(0016-1 [Gilmore, Cathy]) 

Response: Section 4.3.1 of the EIS was amended to include STPNOC’s description of 

installation and use of exclusion fencing around wetland boundaries to avoid potential impacts 

and the potential for post-construction review as part of the conditions of the Section 404 permit 

from the Corps. 

Comment: The acreage identified above is less than 300 acres of permanent impacts. 

According to the DEIS, an additional 56 acres of unidentified habitat type will be disturbed. 

Request: TPWD requests that the Nuclear Regulatory Commission and STPNOC provide a 

description of the habitat type of the approximately 56 acres of permanent impacts that are not 

outlined in the DEIS. In addition, TPWD requests that the category “Other” be defined as a 

specific habitat type(s). (0019-1 [Wolf, Clayton]) 

Response: Section 4.3.1 and Table 4-2 of the EIS were amended to provide updated 

information clarifying the type and amount of terrestrial habitat that would be affected by 

construction. 

Comment: According to the DEIS, STPNOC has committed to the restoration of areas 

temporarily disturbed by construction activities through grading, landscaping and replanting of 

these areas. Recommendation: TPWD recommends that all temporary construction impacts be 

restored to preconstruction contours and conditions and that STPNOC prepare a restoration 

plan and provide this plan to TPWD for review and comment. (0019-2 [Wolf, Clayton]) 

Response: This comment by TPWD is directed to STPNOC, NRC does not have the statutory 

authority to require submission of a restoration plan to a state agency for its review. However, 

Sections 4.3.1.5 and 4.3.2.5 were revised to reflect TPWD’s recommendations for mitigation 

and that the review team’s impact determination is SMALL, with or without the implementation 

of TPWD’s recommendation. 

Comment: DEIS Section 09.03. Alternative Sites, Page 9-63, lines 13-15: The DEIS states: 

“Building impacts would affect up to 2500 ac of land resulting in the permanent loss of terrestrial 

habitat. Three-hundred ac would be required for permanent structures and facilities, and up to 

1700 ac would be required for a new reservoir.” STPNOC believes that the value of 2500 ac of 

permanent loss of habitat is in error, and the correct value should be 2000 ac of permanent loss 
Appendix E 

NUREG-1937 E- 44 February 2011 

of habitat consistent with the breakout of impacts between permanent structures and a reservoir 

in the second sentence. (0010-2-64 [Head, Scott]) 

Response: Section 9.3.2.3 of the EIS was amended to indicate that 2000 ac would be 

permanently lost of the 2500 ac of terrestrial habitat impacted by construction and operation. 

Comment: DEIS Section 09.03. Alternative Sites, Page 9-163, lines 15-22: The DEIS states: 

“Up to seven bat species living in eastern Texas, can occur in Freestone County (Davis and 

Schmidly 1994; STPNOC 2009b). Some are mostly year-round residents (i.e., non-migratory), 

such as the big brown bat (Eptesicus fuscus), the eastern pipistrelle (Pipistrellus subflavus), and 

evening bat (Nycticeius humeralis). Migratory bats that could occur at the site include the hoary 

bat (Lasiurus cinereus), the silver-haired bat (Lasionycteris noctivagans), the eastern red bat 

(Lasiurus borealis), and the Mexican free-tailed bat (Tadarida brasiliensis). The Mexican free 

tailed bat is either migratory or non-migratory depending on where it resides; the migratory 

status of bats occurring in Freestone County is currently unknown (STPNOC 2009b).” The 

DEIS does not mention the southeastern myotis bat, which also may be found in the vicinity of 

the Trinity 2 site (ER Section 9.3.3.4.4). (0010-2-67 [Head, Scott]) 

Response: With regard to the potential occurrence of the southeastern myotis bat (Myotis 

austroriparius) in Freestone County, the review team found a single record noting occurrence of 

this species in Freestone County in the U.S. Geological Survey (USGS) Bat Population 

Database (USGS 2010). Information from Mammals of Texas (Davis and Schmidly 1994) 

indicate this bat species typically is found to the east of the Trinity 2 site; however, TPWD lists 

the southeastern myotis bat as potentially occurring in the area (TPWD 2010). Section 9.3.4.3 

of the EIS was modified to indicate that the southeastern myotis bat may potentially occur in the 

region. 

Davis, W.B. and D.J. Schmidly. 1994. The Mammals of Texas – Online Edition. Texas Parks 

and Wildlife Department, Austin, Texas. Accessed October 15, 2009 at 

http://www.nsrl.ttu.edu/tmot1/Default.htm. 

Texas Parks and Wildlife Department (TPWD). 2010. TPWD Endangered Species: 

Southeastern myotis bat. Accessed July 15, 2010 at 

http://gis.tpwd.state.tx.us/TpwEndangeredSpecies/DesktopDefault.aspx?tabindex=0&tabid=9&t

ype=map&cname=Southeastern%20myotis%20bat&desc=roosts%20in%20cavity%20trees%20

of%20bottomland%20hardwoods,%20concrete%20culverts,%20and%20abandoned%20manmade%20structures&parm=AMACC01030&sname=Myotis%20austroriparius&usesa=&sprot= 

[tpwd_southeastern_myotis_distribution.pdf].

U.S. Geological Survey (USGS). 2010. USGS Bat Population Database for the United States 

and Trust Territories. Accessed July 15, 2010 at http://www.fort.usgs.gov/BPD/ . 
Appendix E 

February 2011 E-45 NUREG-1937 

Comment: DEIS Appendix H. Authorizations, Permits, and Certifications. Page H-4: Table H-1 

lists the status of the USACE Section 404 (first permit on the page) as “Permit Determination 

Request submitted 06/04/2009, Second Permit Determination Request Submitted 10/28/2009” 

The following should be added at the end of these status items “Individual Permit Application 

Submitted 03/09/2010”. (0010-2-94 [Head, Scott]) 

Response: Table H-1 was updated to reflect the current status of authorizations, permits, and 

certifications. 

E.2.11 Comments Concerning Ecology – Aquatic 

Comment: DEIS Section 02.04. Ecology. Page 2-76, Line 13-14: The DEIS states, “However, 

they also noted that the high numbers of cyanobacteria and crytomonads were probably due to 

the water quality changes associated with the heavy rainfall that year (STPNOC 2009a).” 

Environmental Report (Rev. 3.0) indicates that the correct term is “cryptomonads” and does not 

mention rainfall (Section 2.4.2). The ER states the following: “The 1974 ER also observes that 

stressful conditions (i.e., high-water temperatures) appeared to produce increases in numbers 

of “opportunistic” groups such as Cryptomonads and blue-green algae (cyanobacteria). Bluegreen algae, in particular, are often associated with degraded water quality, specifically with 

nutrient enrichment and eutrophication.” (0010-1-18 [Head, Scott]) 

Response: The sentence, “However, they also noted that the high numbers of cyanobacteria 

and crytomonads were probably due to the water quality changes associated with the heavy 

rainfall that year (STPNOC 2009a).” was deleted from Section 2.4.2.1 of the EIS based on 

information provided in this comment. 

Comment: DEIS Section 02.04. Ecology. Page 2-91, Line 20: The DEIS states, “There are no 

bag or possession limits for harvesting black drum; however they must be from 14 to 30 in. in 

length (TPWD 2009o).” Please revise as follows: “There are no bag or possession limits for the 

commercial harvest of black drum; however they must be from 14 to 30 in. in length. The 

recreational bag limit for black drum is 5 fish per day between 14 and 30 in. in length. However, 

one fish over 52 in. may be retained per day as part of the bag limit (TPWD 2009o)” (0010-1-20

[Head, Scott]) 

Comment: DEIS Section 02.04. Ecology. Page 2-95, Lines 20-21: The DEIS states “However, 

mating females and those brooding eggs are only common outside of the bay.” The 

Environmental Report (Rev. 3.0) states that mating blue crabs are common in the tidal fresh 

portions of the bay (Table 2.4-3). Patillo et al. (1997) confirms this. (0010-1-21 [Head, Scott]) 

Response: Section 2.4.2.3 of the EIS was revised to reflect the information provided by the 

comments. 
Appendix E 

NUREG-1937 E- 46 February 2011 

Comment: DEIS Section 04.03. Ecological Impacts. Page 4-27, Line 9: To make this statement 

more precise, replace “roadway” with “portions of the heavy haul road and upgrades to existing 

site roadways.” (0010-1-71 [Head, Scott]) 

Response: Section 4.3.2.1 of the EIS was revised to reflect the information provided by this 

comment. 

Comment: DEIS Section 04.03. Ecological Impacts. Page 4-31, Line 31: The DEIS states, 

“Taxa such as Corbicula, giant salvinia (Salvinia moesta), and Hydrilla were not reported in the 

onsite water bodies and have not been found in high densities in the Colorado River in the 

vicinity of STP (STPNOC 2009a).” The Environmental Report (Rev. 3.0) states, “As of 2003, no 

rooted Hydrilla had been found in the Colorado River downstream of the Austin-area 

impoundments.” (ER Section 2.4.2.3.1.2) The Environmental Report (Rev. 3.0) states, “It (the 

Asiatic clam) was first documented in the Colorado River in the 1970s. A number of specimens 

were discovered in the MCR in 1981 (Reference 2.4-26). Routine biofouling inspections 

conducted since initial operation have not identified any corbicula in STP 1 & 2 plant systems. 

Additional specimens were collected in the Colorado River drainage between the STP site and 

Bay City in the mid-1980s (Reference 2.4-57). By 2005, Corbicula had been reported from 162 

lotic and 174 lentic water bodies in Texas.” (ER Section 2.4.2.3.1.2) The DEIS should be 

revised as follows: “Taxa such as Corbicula, giant salvinia (Salvinia molesta), and Hydrilla were 

not reported in the onsite water bodies. Corbicula was collected from the MCR in 1981, and is 

known to occur in the Colorado River (STPNOC 2009a).” (0010-1-72 [Head, Scott]) 

Response: Section 4.3.2.3 of the EIS was revised to reflect the information provided by this 

comment. 

Comment: DEIS Section 05.03. Ecological Impacts - Operation. Page 5-41, Lines 31-38 and 

Page 5-42, Lines 1-2: The DEIS states “Taxa such as Corbicula, giant salvinia (Savinia 

moesta), and Hydrilla have not been found in high densities in the Colorado River in the vicinity 

of STP (STPNOC 2009a). In 2008, the review team observed Corbicula shells on the shoreline 

of the river above the site but did not see any nuisance organisms at the RMPF in the screen 

racks or in the fish bypass system. The 2007-2008 survey of the MCR did not report any 

nuisance organisms in the reservoir or during impingement and entrainment studies at the CWS 

for existing Units 1 and 2 (ENSR 2008a). It is unlikely that the MCR discharge would become a 

contributor of nuisance organisms in the Colorado River because these species have not been 

reported in surveys of the MCR (ENSR 2008a), and the MCR discharge is likely to be 

infrequent.” The Environmental Report (Rev. 3.0) states, “As of 2003, no rooted Hydrilla had 

been found in the Colorado River downstream of the Austin-area impoundments.” (ER Section 

2.4.2.3.1.2) “The Asiatic clam, Corbicula fluminea, is a problematic invasive mollusk from 

southeastern Asia. It is a small bivalve that is typically found at high densities and has a 

relatively high growth rate (Reference 2.4-55). Because of its tolerance of a wide variety of 

aquatic conditions and its high reproductive rate, it has developed into a pest that clogs ditches 
Appendix E 

February 2011 E-47 NUREG-1937 

and interferes with pipes and heat exchangers of power plants. The first reported collection of 

Corbicula in Texas occurred in the Neches River in 1958 (Reference 2.4-56). Corbicula were 

next discovered near El Paso, in 1964, suggesting that the species was invading Texas from 

both east and west. It was first documented in the Colorado River in the 1970s. A number of 

specimens were discovered in the MCR in 1981 (Reference 2.4-26). Routine biofouling 

inspections conducted since initial operation have not identified any Corbicula in STP 1 & 2 

plant systems. Additional specimens were collected in the Colorado River drainage between 

the STP site and Bay City in the mid-1980s (Reference 2.4-57). By 2005, Corbicula had been 

reported from 162 lotic and 174 lentic water bodies in Texas.” (ER Section 2.4.2.3.1.2) The ER 

did not mention giant salvinia. Please note that the correct scientific name of this plant is 

Salvinia molesta. The DEIS should be revised as follows: “Taxa such as Corbicula, giant 

salvinia (Salvinia molesta), and Hydrilla have not been found in high densities in the Colorado 

River in the vicinity of STP (STPNOC 2009a). In 2008, the review team observed Corbicula

shells on the shoreline of the river above the site but did not see any nuisance organisms at the 

RMPF in the screen racks or in the fish bypass system. The 2007-2008 survey of the MCR did 

not report any nuisance organisms in the reservoir or during impingement and entrainment 

studies at the CWS for existing Units 1 and 2 (ENSR 2008a), although Corbicula were collected 

from the MCR in 1981. It is unlikely that the MCR discharge would become a contributor of 

nuisance organisms in the Colorado River because these species have not been reported in 

surveys of the MCR (ENSR 2008a).” (0010-2-18 [Head, Scott]) 

Response: Section 5.3.2.1 of the EIS was revised to reflect the information provided by this 

comment. 

Comment: The review team’s determination of the impact category levels is based on the 

assumption that the mitigation measures identified in the Environmental Report (ER) or activities 

planned by various state and county governments, such as infrastructures upgrades (discussed 

throughout this chapter), are implemented. Failure to implement these upgrades might result in 

a change in the impact category. Possible mitigation measures of adverse impacts, where 

appropriate, are presented in Section 4.11. However, none of the mitigation measures and 

controls includes compensatory mitigation for the project’s proposed impacts to fish and wildlife 

habitat including waters of the United States. 

Recommendation: TPWD recommends that STPNOC formulate a compensatory mitigation plan 

for all impacts to fish and wildlife habitat, including wetlands and shallow water habitat for the 

proposed project. This would include impacts to species and habitats covered under federal law 

and state resource habitat types not covered by state or federal law. At a minimum, TPWD 

recommends a replacement ratio of 1: 1 for state resource habitat types. TPWD requests the 

opportunity to review and comment on the compensation plan. (0019-4 [Wolf, Clayton]) 

Response: The comment is directed to STPNOC, and NRC does not have the statutory 

authority to require submission of a compensation plan to a state agency for its review. 
Appendix E 

NUREG-1937 E- 48 February 2011 

However, Sections 4.3.1.5 and 4.3.2.5 were updated to reflect TPWD’s recommendations for 

mitigation and state that the review team’s impact determination is SMALL with or without 

implementation of TPWD’s recommendations.

Comment: DEIS Section 05.03. Ecological Impacts - Operation. Page 5-45, Lines 6-22: The 

DEIS states “As described in the EFH assessment in Appendix F, operation of the proposed 

Units 3 and 4 could affect EFH for juvenile king mackerel; all life stages of Spanish mackerel, 

gray snapper, red drum, and Gulf stone crab; and larvae and juveniles of brown, pink, and white 

shrimp.... Operation of Units 3 and 4 would likely affect Spanish mackerel, gray snapper, and 

red drum similarly. The eggs and larvae of Spanish mackerel, gray snapper, and red drum 

could be entrained during pumping at the RMPF, and the organisms would be lost from the river 

environment. Discharge of MCR water could create thermal and chemical characteristics of the 

river water and affect the viability of the eggs and larvae of these species.... The juvenile and 

adult Spanish mackerel, gray snapper, and red drum and their prey could avoid the affected 

areas of the Colorado River during operation of the RMPF and discharge structure as well as 

during maintenance dredging.” The Environmental Report (Rev. 3.0) states that the red drum 

spawns offshore. No red drum eggs occur near the STP RMPF (ER Table 2.4.3). The ER did 

not include Spanish mackerel or gray snapper as important species because they rarely occur 

in the area. The only life stage of the Spanish mackerel that occurs in the Matagorda Bay is the 

juvenile, and it is listed as rarely occurring (Patillo et al. 1997). It is highly unlikely that juvenile 

Spanish mackerel would occur at the RMPF. Likewise, only adult and juvenile gray snapper 

occur in Matagorda Bay, and only rarely. Eggs and larvae of the gray snapper do not occur 

near the STP site (Patillo et al. 1997). The DEIS should be revised as follows: “As described in 

the EFH assessment in Appendix F, operation of the proposed Units 3 and could affect EFH for 

juvenile king mackerel; all life stages of red drum, and Gulf stone crab; and larvae and juveniles 

of brown, pink, and white shrimp.... Operation of Units 3 and would likely affect red drum 

similarly. The eggs and larvae of red drum could be entrained during pumping at the RMPF, 

and the organisms would be lost from the river environment. Discharge of MCR water could 

create thermal and chemical characteristics of the river water and affect the viability of the eggs 

and larvae of the red drum .... The Spanish mackerel, gray snapper, and red drum and their 

prey could avoid the affected areas of the Colorado River during operation of the RMPF and 

discharge structure as well as during maintenance dredging.” (0010-2-19 [Head, Scott]) 

Comment: DEIS Section 10.04. Irreversible and Irretrievable Commitments of Resources. 

Page 10-14, Line 25: The DEIS states that designated essential fish habitat (EFH) in the 

Colorado River would be adversely affected. The Environmental Report (Rev. 3.0) only lists 

categories of essential fish habitat in the lower Colorado River and Matagorda Bay that could be 

impacted. The ER further states that the lower Colorado River is not a unique nursery area for 

estuarine-marine organisms and species most affected by operations at STP were ubiquitous 

and abundant along the Texas and Gulf coasts (Section 2.4.2.4). (0010-2-75 [Head, Scott]) 
Appendix E 

February 2011 E-49 NUREG-1937 

Response: The EIS summarizes the consultation with NMFS in accordance with the 1996 

amendments to the Magnuson-Stevens Fishery Conservation and Management Act. Appendix 

F includes the EFH assessment. The review team followed NMFS guidance in writing the EFH 

assessment in support of the consultation; all designated EFHs in the area were considered. 

The habitat for the species and their life stages that are summarized in the EIS are consistent 

with the description in the EFH assessment. In a letter dated April 20, 2010, the NMFS 

concurred with the review team’s EFH assessment. No changes were made in the EIS as a 

result of this comment. 

Comment: DEIS Section 07.03. Ecology – Cumulative. Page 7-31, Lines 1-3 and Page 7-33, 

Lines 28-32: The DEIS states on page 7-31 “STPNOC plans on moving and constructing 

additional drainages and culverts to manage the flows after precipitation events, which could 

increase due to GCC.” DEIS states on page 7-33 “GCC could lead to decreased precipitation, 

increased sea levels, varying freshwater inflow, increased temperatures, increased storm 

surges, greater intensity of coastal storms, and increased nonpoint source pollution from runoff 

during these storms, in the water bodies in the geographic area of interest (Nielsen-Gammon 32 

1995; Montagna et al. 1995; Karl et al. 2009).” These two statements make contradictory 

predictions about the effect of global climate change (GCC) on precipitation at the site. 

(0010-2-51 [Head, Scott]) 

Response: While overall precipitation is expected to decrease, the frequency and intensity of 

coastal storms is predicted to increase. The precipitation events that are mentioned in the draft 

EIS on page 7-31, lines 1-3, refer to these events and could include coastal storms that could 

be of greater intensity because of GCC. If that were the case, then STPNOC’s plans to address 

stormwater management during those coastal storm events would be important to minimizing 

any impacts from the storms. Section 7.3 of the EIS was revised based on this comment. 

E.2.12 Comments Concerning Socioeconomics 

Comment: It is important we really take advantage of these opportunities that have been 

described in this review, and, first of all, to capture the great job opportunities. ... Next is to 

capture the new employees coming into our community. We have been working very hard to 

bring in developers, to bring in new subdivisions, and housing, as well as apartments. Earlier 

today you did hear about some of the developers building subdivisions and housing. Apartments 

are soon to follow. (0003-16 [Dunham, D.C.]) 

Comment: I think that not only will it help my own business, but other small businesses in the 

area. And a lot of that revenue that comes in through the local businesses that are not 

franchises stays within the community. And that leads to more taxes and more programs that 

we can offer the public. So those benefits are going to be huge in terms of all parts of our 

population. (0003-18 [Green, Julie]) 
Appendix E 

NUREG-1937 E- 50 February 2011 

Comment: STP’s Units 3 and 4 will produce approximately 4- to 6,000 construction jobs, which 

will be staffed by the AFL-CIO, Building and Construction Trades Department, who currently 

represent over two million skilled crafts professionals in both the United States and Canada. 

The construction phase of this project will also impact several billions of dollars into our local 

economy. Once these units are completed, they will also create an additional 800 well-being 

jobs, full-time, many of which will be again skilled union craftsmen and craftswomen, which I will 

help represent. In addition, the potential for as many as 12- to 1,300 new hires exist between 

2011 and 2017 to compensate for the loss of retirees at our current units. ... This project would 

produce well-paying jobs with solid benefit packages and stability to the local area for decades 

to come. (0003-20 [Griffin, Mark]) 

Comment: This expansion will be great for our community in that it will provide even more jobs 

for our citizens we currently have, as well as bring more people into our community. (0003-25

[Hutto, Veronica]) 

Comment: I will say that having 800 jobs and many more that ancillary businesses would 

bring, and many more that the ancillary retail and quality of life provisions and businesses would 

provide. (0003-8 [Marceaux, Brent]) 

Comment: With our unemployment rate higher than the national rate, and the Texas State 

rate, we need these jobs, we need these people to come to our community. 

(0004-1-12 [Thames, Carolyn]) 

Comment: [W]e create jobs, as was mentioned. Thousands of construction jobs will be 

created with Units 3 and 4, an additional 800 or so permanent in-house jobs at the station. 

(0004-1-17 [Halpin, Ed]) 

Comment: STP is the largest employer in Matagorda County, with more than 1,200 

employees. The new units will add an additional 800 permanent jobs to the local economy. 

(0004-1-44 [Smith, Steve]) 

Comment: STP Units 3 and 4 will produce approximately 4-6,000 construction jobs, which will 

be staffed, primarily, by the AFL-CIO, the Building and Construction Trades Department, who 

currently represent over 2 million skilled crafts persons in both America and Canada. The 

construction phase will also inject several billion dollars into this local community. Once these 

units are complete, they will create an additional 800 well-paying full-time jobs, many of which, 

again, will be filled by skilled union craftsmen. In addition, the potential for as many as 12-1300 

jobs will be created between 2011 and 2017 to compensate for the loss of retirees at the current 

units. ... This project will produce well-paying jobs, with solid benefit packages, and stability to 

the local area for decades to come. (0004-1-49 [Griffin, Mark]) 
Appendix E 

February 2011 E-51 NUREG-1937 

Comment: The expansion of STP will create hundreds of well-paid permanent positions, as 

well as thousands of contractor jobs during plant construction, and will add several billion dollars 

to the local and state economies, several billion dollars. STP is already Matagorda County’s 

largest employer with more than 1,200 employees. The company will need an additional 800 

well-trained and highly-skilled technicians, engineers, operators, and other personnel to staff its 

planned new units. ... STP has committed to attracting and training that workforce locally. (0004-

1-5 [Hegar, Glenn]) 

Comment: [I]t’s important that we take advantage of the [economic] opportunities that are put 

before us, and that are actually explained in this review in this document, ... First, is to capture 

the great job opportunities that are going to be coming. ... And then next we’ve got to capture 

the new employees coming in. ...We are developing subdivisions. We do have new housing 

going in. (0004-2-20 [Dunham, D.C.]) 

Comment: This expansion will be great for our community in that it will provide even more jobs 

for our citizens we currently have, as well as bring more people into our community. (0004-2-28

[Hutto, Veronica]) 

Comment: These employees are all well paid employees, and I do believe that a majority of 

my employees do live in Matagorda County. So I do believe that the majority of them that would 

be hired are going to live in Matagorda County. ... The jobs and the wages that they do make, 

like I said, are a fair wage. ... But it does help -- not just the good pay, but also the health and 

welfare. These employees all get insurance. They all have a retirement. Not necessarily do 

they have to leave and go elsewhere when they do finish working at that plant. They can stay 

right here and spend that money right back at home. It is a trickle-down from the lower class, I 

guess you would say. It’s where these employees do make the money, right here, and they 

spend it right here. (0004-2-32 [Lucero, Greg]) 

Comment: I am excited that new units 3 & 4 will provide new permanent jobs and temporary 

construction jobs for citizens in our area! ... The additional tax base support that will come with 

the creation of units 3 & 4 will provide a critical infusion of support to every aspect of life in the 

county. (0005-2 [Purvis, Gail]) 

Comment: STP is the largest employer in Matagorda County with more than 1,200 employees. 

The new units will add an additional 800 permanent jobs to the local economy. 

(0012-2 [Scurlock, Betty]) 

Response: These comments generally express support for the proposed STP Units 3 and 4, 

based on the potential positive socioeconomic impacts they would be expected to bring to the 

region. Socioeconomic impacts of construction and operation are discussed in Chapters 4 and 

5 of the EIS. No changes were made to the EIS as a result of these comments. 
Appendix E 

NUREG-1937 E- 52 February 2011 

Comment: Socioeconomically, STP proponents say that the expansion is good for our area, 

yet 30 percent of the children in the districts closest to STP live below the poverty level, and 

Matagorda County’s unemployment is the highest in the state. Is that STP’s fault? No, of 

course not, but they do play a role. The only way for us to get out of our economic slump is to 

acknowledge how we got here, and in that STP does have a role. Here’s how it works. You get 

a big construction project going on. You get an influx of people from around the country, and in 

this case even from around the world. And each professional who comes seeking job brings 

with him an un- or under-skilled spouse, 2.3 children, and encourages others to come with him, 

as well. Each of these others come into the scenario and compete with locals, who are already 

here, for the menial jobs they already have. Unemployment here skyrockets. ... Meanwhile, 

infrastructure costs are borne mostly by existing locals for classrooms, hospitals, roadways, law 

enforcement efforts go through the roof, so people already established here get a double 

whammy. ... the truth is that a very large percentage of the current 1,200 employees, and likely 

800 to come live elsewhere. A huge chunk of STP’s upper managers live in neighboring 

Brazoria County, leaving Matagorda County the risk, the infrastructure burden, and the 

economic backlash that worsens the very issues it proposes to remedy. 

Another undeniable factor in STP’s inability to be the answer to our economic woes is that 

STP’s upper management positions appear to be only open to white males. ... The fact of the 

matter is that STP 1 and 2 did not bring prosperity to our community by any economic indicator 

one may use, child poverty, unemployment, et cetera. The fact of the matter is the local people 

look realistically at indicators via the EIS process, expanding the nuclear plant seems to only 

worsen our situation. (0004-2-8 [Dancer, Susan]) 

Response: This comment does not dispute that economic opportunities would increase with 

the building and operation of STP Units 3 and 4, and does not specifically recommend a change 

in the analysis or conclusions. The commenter is concerned about the distribution of local 

impacts. The actual level and distribution of local socioeconomic impacts will depend to a 

significant degree on a number of factors, including the number of imported workers needed for 

the project, where they choose to live, the number of dependents accompanying the workers, 

and mitigation strategies developed by local and higher governments and project developments. 

These matters are discussed in EIS Sections 4.4 and 5.4. Based in part on estimates from 

STPNOC, on known plans by local government and private sector entities for job training and 

infrastructure, and on patterns of settlement related to the existing STP facility, the review team 

believes that a number of STP jobs would be open to local residents and that they would be 

qualified to compete for them. For example, Section 2.5.2.6 briefly discusses the local 

education program to train new nuclear energy workers. Local government and private 

economic development groups in Matagorda County are actively planning for the infrastructure 

requirements presented by the construction and permanent operational workforces for Units 3 

and 4. STPNOC and local government bodies also are working on the proposed construction 

schedule and related issues, and they plan to continue these communications. See, for 
Appendix E 

February 2011 E-53 NUREG-1937 

example, Section 4.4.4.3. Because this comment did not provide any new information, no 

changes were made to the EIS as a result of this comment. 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-113, Lines 14-16: The DEIS provides 

a list of the types of people that are considered transients in this analysis, but does not identify 

three of them: those residing in schools, hospitals and nursing homes, and correctional facilities. 

Nor, does the DEIS provide an explanation for their omission. The Environmental Report (Rev. 

3.0) provides a list of all of the types of transients and provides an explanation for the omission 

of some of them. This information should be included in the DEIS for completeness. 

(0010-1-24 [Head, Scott]) 

Response: Section 2.5 of the EIS was revised in response to this comment to include an 

updated list and abbreviated explanation. 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-119, Table 2-22: The DEIS Table 2-

22 data do not match the data in Table 2.5-7 of the Environmental Report (Rev. 3.0). The Table 

2-22 data are not for 2005. The reference listed at the bottom of the table says “BEA 2008”. The 

table title should be changed to that later year. (0010-1-26 [Head, Scott]) 

Response: The citation is to a 2008 version of the U.S. Bureau of Economic Analysis (BEA) 

website shown in the references to the chapter. The correct year for the title is 2006. The title 

of Table 2-22 of the EIS was changed to reflect this fact. 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-121, Table 2-24: DEIS Table 2-24 

and ER (Rev. 3) Table 2.5-9 both purport to report the same data. However, there are some 

discrepancies between the two tables, even though they report the data for the same years. It is 

unclear whether 1) the years listed for the data are incorrect, or 2) the data have been revised. 

The ER table reference is BLS 2007 while the DEIS reference is BLS 2008. The data in Table 

2-24 may need to be reconciled or the dates of the data may need to be changed. 

(0010-1-27 [Head, Scott]) 

Response: The local data for 2005 were revised in BLS 2008. The table is correct as it stands. 

No changes were made to the EIS as a result of this comment. 

Comment: DEIS Section 04.04. Socioeconomic Impacts – Construction. Page 4-50, Line 7: 

The DEIS states STPNOC estimated the total daily groundwater usage at the STP site during 

building.... This sentence should be revised to state STPNOC estimated the total maximum 

groundwater usage at the STP site during construction, initial testing, and operation of Units 3 

and 4.... (0010-1-73 [Head, Scott]) 

Comment: DEIS Section 04.04. Socioeconomic Impacts – Construction. Page 4-50, Line 7: 

The DEIS references 1.7 MGD for groundwater use. This value was deleted in response to RAI 
Appendix E 

NUREG-1937 E- 54 February 2011 

05.10-04. Language should be inserted that states groundwater use will remain below the 

existing site groundwater permit limit. (0010-1-74 [Head, Scott]) 

Comment: DEIS Section 04.04. Socioeconomic Impacts – Construction. Page 4-50, Lines 8-9: 

The DEIS states “During peak development, water usage by STPNOC could exceed its annual 

permitted amount.” STPNOC will operate within established groundwater-use permit limits. 

The current groundwater permit does not have an annual permitted amount; instead it 

establishes maximum usage for the permit term which is approximately three years. 

(0010-1-75 [Head, Scott]) 

Response: Section 4.4.4.4 of the EIS was revised based on these comments to reflect the 

updated water balance for STP Units 3 and 4.

Comment: DEIS Section 04.04. Socioeconomic Impacts – Construction. Page 4-50, Lines 29-

31: The building-related population increase, 10,445, and the estimated water treatment 

increase, 940,050, are inconsistent with DEIS Section 4.4.2, lines 24 and 25. In order to be 

consistent with DEIS Section 4.4.2, lines 24 and 25, the building-related population increase 

should be 10,338. The estimated water treatment increase should be 930,458. 

(0010-1-76 [Head, Scott]) 

Response: The suggested change has been made to Section 4.4.4.4 of the EIS. Estimates for 

the population increase and the increased wastewater treatment capacity are 10,338 people 

and 930,458 gpd, respectively. 

Comment: DEIS Section 05.04. Socioeconomic Impacts – Operation. Page 5-58, Line 27-29: 

This paragraph should be replaced with the following text: “The STP site has two private 

wastewater treatment facilities for the existing units. As part of the new units’ development 

project, these would be replaced or expanded to support the additional units. Therefore, 

operations would not impact the existing wastewater treatment facility.” STPNOC will provide 

this clarification in the ER in Revision 4.0 of the COLA (0010-2-21 [Head, Scott]) 

Response: The proposed rewording provides additional clarification. Section 5.4.4.4 of the 

EIS was modified to reflect this comment. 

Comment: DEIS Section 07.04. Socioeconomic and Environmental Justice – Cumulative. 

Page 7-37, Lines 3-4: The DEIS states, “Exelon has since stated its intent to submit an Early 

Site Permit (ESP) application”. It should be noted that Exelon submitted an ESP application to 

the Nuclear Regulatory Commission in March 2010. (0010-2-52 [Head, Scott]) 

Comment: DEIS Section 07.04. Socioeconomic and Environmental Justice – Cumulative. 

Page 7-37, Lines 4-7: This section should be redrafted in light of Exelon’s withdrawal of the 

Combined License Application (COLA) and submission of an ESP application. The anticipated 
Appendix E 

February 2011 E-55 NUREG-1937 

schedule associated with an ESP renders the construction impacts immaterial since they may 

be deferred up to 20 years. (0010-2-53 [Head, Scott]) 

Response: Section 7.4.1 of the EIS was revised to reflect these comments. The discussion of 

the overlapping impacts with STP Units 3 and 4 has been revised to note that Exelon has no 

plans for onsite activity at the Victoria County Station (VCS) site after issuance of an early site 

permit, and that VCS could be delayed as much as 20 years, resulting in no construction period 

impact and much delayed impact of any kind in Matagorda or Brazoria Counties.

Comment: The Draft EIS is deficient in its evaluation of socioeconomic impacts regarding 

employment rates, poverty, and benefits for the local community. The construction of units 1 

and 2 did not have the positive effects on our community alleged in the EIS in Section 4. There 

is no consideration or acknowledgment of the additional social stressors associated with a 

large-scale construction project in a small community such as increased crime rates, insufficient 

jail space, increased need for law enforcement personnel, classroom space, and hospital beds 

and increased demand on social services such as housing assistance and other welfare 

programs necessary to accommodate a large transient worker population. Each of these 

negative impacts were experienced during construction of units 1 and 2 and the influx of 

unemployed persons, largely spouses and family of new employees, caused Matagorda 

County’s unemployment rate to skyrocket throughout the construction period and should be 

anticipated for the construction period of units 3 and 4 as well. (0013-1 [Dancer, Susan]) 

Response: Acknowledging that the size of transitory impacts on community services will 

depend on the extent of population growth during the construction and operations periods, 

Sections 4.4.4.4 and 5.4.4.4 of the EIS discuss the potential impacts on Matagorda County, in 

particular during construction, and say that impacts on police and fire staffing and education 

facilities could be noticeable. The comment did not provide information on the historical period 

to demonstrate that overall impacts of the existing STP Units 1 and 2 were not favorable 

because of crime increases and lack of education and medical facilities. No changes were 

made to the EIS as a result of this comment. 

E.2.13 Comments Concerning Environmental Justice 

Comment: DEIS Section 02.06. Environmental Justice. Page 2-148, Lines 5-6: The DEIS is 

missing a figure for the six block groups that have significant “some other race” populations. 

(0010-1-30 [Head, Scott]) 

Response: The “some other race” figure was omitted on purpose from the EIS for the sake of 

brevity. The information contained in the figure was not considered to be critical to the 

discussion because the six block groups with “some other race” populations were already 

encompassed by total minorities or one of the other racial and ethnic minorities. No change 

was made to the EIS as a result of this comment. 
Appendix E 

NUREG-1937 E- 56 February 2011 

Comment: DEIS Section 02.06. Environmental Justice. Page 2-151, Line 34: This sentence is 

missing “some other race” populations. (0010-1-31 [Head, Scott]) 

Response: The phrase “some other race” has been added to the list in this sentence. 

Comment: DEIS Section 02.06. Environmental Justice. Page 2-148, Figure 2-27: Figure 2-27 

of the DEIS is incorrect. The correct figure is attached to this review document. (0010-1-32

[Head, Scott]) 

Response: Figure 2-27 has been replaced with a corrected figure created by the review team, 

instead of the revised Figure 2-27 provided by STPNOC. 

E.2.14 Comments Concerning Historic and Cultural Resources 

Comment: Our review did not identify any known impacts to religious, cultural, or historical 

assets of the Alabama-Coushatta Tribe of Texas in conjunction with the preferred option. 

However, in the event of inadvertent discovery of human remains and/or archaeological 

artifacts, activity in proximity to the location must cease and appropriate authorities, including 

our office, notified without delay. If an alternative site take precedence, further consultation with 

our office may be necessary. (0001-1 [Celestine, Bryant]) 

Response: STPNOC has developed a procedure for addressing unanticipated discoveries of 

cultural resources or human skeletal remains that includes provisions for halting work activities 

and notifying appropriate agencies, including the State Historic Preservation Office at the Texas 

Historical Commission as well as affected tribe(s) or other parties, to determine the steps to be 

taken prior to resuming work. In the event that an alternative site is chosen for the proposed 

project, NRC and the Corps would continue to consult with the Alabama-Coushatta Tribe of 

Texas in accordance with Section 106 of the National Historic Preservation Act of 1966 and 

NEPA. Sections 2.7, 4.6, 5.6, 7.5, and 9.3 of the EIS were revised as a result of this comment 

to indicate that consultation in the event of an inadvertent discovery could include affected 

tribe(s).

E.2.15 Comments Concerning Nonradiological Waste 

Comment: STP ships a variety of materials to be reprocessed for reuse, including oil, lead, 

acid batteries, and more than a dozen tons of paper annually. With this being said, it is clear 

that STP takes pride in being an ecofriendly plant, protecting threatened species, and recycling 

a variety of material -- all positive characteristics that make STP the world class plant that it is. 

(0004-2-25 [Chavez, Chance]) 

Response: This comment expresses general support for STPNOC’s recycling program. No 

changes were made to the EIS as a result of this comment. 
Appendix E 

February 2011 E-57 NUREG-1937 

Comment: DEIS Section 04.10. Nonradiological Waste Impacts - Construction. Page 4-75, 

Lines 3-4: The DEIS states that two wastewater treatment facilities would be replaced to 

accommodate increased waste generation during project activities. However, the West Sanitary 

Waste Treatment System will be replaced; the Nuclear Training Facility Sanitary Waste 

Treatment System will be upgraded to increase its capacity. STPNOC suggests modifying the 

wording to “ ... facilities would be replaced or upgraded to ....” (0010-1-81 [Head, Scott]) 

Response: Section 4.10.2 of the EIS was changed to reflect the information in this comment. 

Comment: DEIS Section 05.10. Nonradiological Waste Impacts - Operation. Page 5-92, Lines 

34-35: The DEIS states that activated sludge from onsite wastewater treatment facilities is 

currently disposed of at both onsite and offsite locations. The onsite land disposal permit was 

allowed to expire. There are no plans to reactivate it. The statement should be revised to state 

that the activated sludge from the onsite sanitary waste treatment facilities is disposed of at an 

offsite location. (0010-2-28 [Head, Scott]) 

Comment: DEIS Section 05.10. Nonradiological Waste Impacts - Operation. Page 5-93, Lines 

1-2: The DEIS states that the increased activated sludge from the operation of two additional 

units would require a new or revised permit from the TCEQ. The onsite land disposal permit 

was allowed to expire and there are no plans to reactivate it. This statement should be revised 

to exclude any reference to such a permit. (0010-2-29 [Head, Scott]) 

Comment: DEIS Section 05.10. Nonradiological Waste Impacts - Operation. Page 5-93, Lines 

9-10: The DEIS states that effluents containing chemicals or biocides would be discharged to 

the MCR and the Colorado River. No biocides are discharged to the Colorado River. Total 

Residual Chlorine per the TPDES permit must be <0.05 mg/l to discharge to the Colorado River. 

STPNOC recommends deleting and the Colorado River from this sentence. (0010-2-30 [Head, 

Scott]) 

Comment: DEIS Section 05.10. Nonradiological Waste Impacts - Operation. Page 5-93, Line 

14: The DEIS states that the existing facilities would be replaced with two new wastewater 

treatment facilities. However, the West Sanitary Waste Treatment System will be replaced; the 

Nuclear Training Facility Sanitary Waste Treatment System will be upgraded to increase its 

capacity. This sentence should be revised to state that existing wastewater treatment facilities 

would be replaced or upgraded to serve all four units. (0010-2-31 [Head, Scott]) 

Response: Section 5.10 of the EIS was revised based on the information provided by these 

comments. 
Appendix E 

NUREG-1937 E- 58 February 2011 

E.2.16 Comments Concerning Nonradiological Health 

Comment: DEIS Section 04.08. Nonradiological Health Impacts - Construction. Page 4-65, 

Line 13: The DEIS states that the population within a 10-mile radius is approximately 6400, 

citing the ER as a source. Table 2.5-2 of Rev 3 of the ER states the 2000 population to be 6314 

(including transients) and the 2010 population to be 6692. Although the DEIS is not inconsistent 

with the table, using a value from the ER (e.g., the 2010 value) would improve traceability. 

(0010-1-78 [Head, Scott]) 

Comment: DEIS Section 04.08. Nonradiological Health Impacts - Construction. Page 4-66, 

Lines 17-18: The DEIS states that the average construction workforce for Units 3 and 4 would 

be approximately 3300 during a 67-month period. The data in Table 3.10S-2 indicate that the 

67-month average is 4038. If one averages from month minus 24 through plus 67, the average 

is 3281 - in agreement with the DEIS. The DEIS should be changed to either 1) indicate that 

the average is over the 91-month period or 2) change the 67-month average to 4038. (0010-1-

79 [Head, Scott]) 

Response: Section 4.8.1.2 of the EIS was revised to reflect the information provided by these 

comments. 

Comment: The DEIS describes climate change impacts related to ... nonradiological as “not 

insignificant”. Despite this somewhat ambiguous conclusion, the DEIS determined no 

alterations to its conclusions regarding ... nonradiological health were warranted. As a result of 

this conclusion, the cumulative impacts on ... nonradiological health were characterized as 

“small”. The DEIS findings that certain impacts are “not insignificant” is inconsistent with 

conclusions that are considered “small”. In effect, the DEIS concedes the impacts are 

significant but then reaches an inconsistent conclusion that the effects thereof are “small”‘. In 

this regard, the DEIS fails to satisfy 10 CFR 51.70(b) that requires the document to be, inter 

alia, clear and analytic. This requirement is not satisfied because the DEIS makes no attempt to 

reconcile its findings of significant impacts with conclusions that such have only minimal effects. 

Instead the DEIS makes the unsupported and contradictory analytic leap that significant impacts 

yield only small effects. One court has described the EIS adequacy criteria as follows: (1) 

whether the agency in good faith objectively has taken a hard look at the environmental 

consequences of a proposed action and alternatives; (2) whether the EIS provides detail 

sufficient to allow those who did not participate in its preparation to understand and consider the 

pertinent environmental influences involved; and (3) whether the EIS explanation of alternatives 

is sufficient to permit a reasoned choice among different courses of action. The DEIS has failed 

to take a “hard look” at impacts it determines are “not insignificant” and instead merely 

concludes such have small effects. This failure does not provide sufficient detail to understand 

how the conclusions were reached. As a result, the public and decision makers are unable to 

make reasoned choices among competing alternatives. (0015-11 [Johnson, Matthew]) 
Appendix E 

February 2011 E-59 NUREG-1937 

Response: Climate change is a global phenomenon. The global atmospheric concentration of 

greenhouse gases, which drives the climate change discussed in the EIS, will not be detectably 

altered by the building or the operation of the proposed plants. The change to nonradiological 

health resources mentioned in the EIS (i.e., not insignificant) are those associated with climate 

change and not the incremental changes expected with the release of waste heat during the 

operation of the proposed plants. Federal and State regulators authorizing discharges into the 

aquatic environment are accustomed to adapting to historical climate variability. The review 

team considers the institutional controls to be protective of water resources in a manner that 

would not, for example, increase the presence of thermophilic organisms that could adversely 

affect human health. The review team acknowledges that the global and local baseline 

environment that could increase the presence of etiological agents may change in a manner 

that is “not insignificant.” However, the review team did not identify a reasonably foreseeable 

baseline condition after the climate has changed − for example, as a result of an increase in 

rainfall and temperature − that would alter the review team’s conclusion regarding the impact of 

the proposed plants. The review team recognized that climate change has the potential to 

affect the presence of etiological agents in the region of interest, but the review team’s overall 

conclusions on cumulative impacts were not altered. Regarding the commenter’s claim that the 

EIS “.... does not provide sufficient detail to understand how the conclusions were reached....,” 

the EIS does explain the review team’s conclusions regarding the impacts of climate change in 

the region of interest. The review team analyzed data in the EIS in a level of detail that was 

commensurate with the importance of the impact, with some less important material 

summarized, consolidated, or simply referenced. The concluding statement in Section 7.7 now 

draws the distinction between global and local effects of climate change. 

E.2.17 Comments Concerning Radiological Health 

Comment: We have concerns with ... radiation risks for the general population, and for 

workers. (0004-1-33 [Hadden, Karen]) 

Comment: I’m also concerned about ... tritium, other radionuclide contamination. (0004-2-10

[Dancer, Susan]) 

Response: Chapter 5 of the EIS addresses radiation risks to the general public and 

occupational doses to plant workers. These comments are general in nature and required no 

change to the EIS. 

Comment: [T]here would be ground water use of 1,860 gallons per minute, and I would 

recommend, and I don’t see it in the EIS, that the water be tested to make sure that there’s no 

radioactivity, since that will be drinking water. The aquatic organisms have been identified in 

the Environmental Impact Statement, which is great. .. What they did not do was take any of 

these organisms into a laboratory and find out, is there radioactivity already here? Is there 

tritium already here? And they should. ... Why were these organisms not tested, fish, snakes, 
Appendix E 

NUREG-1937 E- 60 February 2011 

invertebrates, birds, shell fish, blue crabs, oysters, and even the larger aquatic mammals. No 

testing, and we recommended this from day one. In terms of that, the EIS acknowledges the 

shortcoming in data, and they simply say STPNOC does not conduct any routine monitoring of 

aquatic resources of the site. Regulatory agencies have not required ecological monitoring of 

the STP site, and it hasn’t been done, even with this Draft Environmental Impact Statement 

looking to build two more reactors. According to the Environmental Impact Statement, there 

were over 122,000 people living within 50 miles of the South Texas Project site. They could, 

according to the document, be exposed to 2.5 millirem per year from the two proposed units. 

No mention was made at the same time of exposure from the existing units, and what the 

cumulative impact is, nor any kind of real estimate of what the health risks are from this level of 

exposure. (0004-1-42 [Hadden, Karen]) 

Response: As discussed in Section 5.2.2.2, groundwater use at the STP site is planned for 

makeup to UHS basins, fire protection systems, potable water supply, sanitary uses, and 

service water needs; it is not all intended for drinking. Drinking water for the site is obtained 

from deep aquifer wells, which are monitored quarterly, and no tritium has been detected in this 

water. As discussed in Sections 2.11 and 5.9.6, surface water, fish, invertebrates, and 

sediments are routinely monitored in the Radiological Environmental Monitoring Program 

(REMP). The results of the REMP are presented in the Annual Environmental Operating 

Report. Cumulative doses to the maximally exposed individual from Units 1 and 2 plus the 

proposed Units 3 and 4 are discussed in Section 5.9.3 and Appendix G. No changes were 

made to the EIS as a result of this comment. 

Comment: DEIS Section 05.09. Radiological Impacts of Normal Operations. Page 5-82, Line 

13: The DEIS states, “STPNOC calculated liquid pathway doses to the MEI as shown in ER 

Table 5.4-4” STPNOC’s liquid pathway doses to the MEI are shown in Table 5.4-5 of 

Environmental Report Rev. 3.0 (Section 5.4, p. 5.4-11). (0010-2-23 [Head, Scott]) 

Comment: DEIS Section 05.09. Radiological Impacts of Normal Operations. Page 5-89 Line 3 

(Table 5-13): The DEIS states, “STPNOC’s dose estimates to the surrogate species from the 

liquid and gaseous pathways are shown in Table 5-13” 

 Invertebrate 5.30 0 5.85 

 Algae 0.54 0 0.68....” 

Liquid, gaseous and total dose, respectively, from Units 3 & 4. Environmental Report RAI 

05.09.05-01(Letter U7-C-STP-NRC-090137, Attachment 8, page 2 of 3, 9/14/09) indicate that 

these doses are: 

 Invertebrate 5.30 0 5.30 

 Algae 0.54 0 0.54.... 
Appendix E 

February 2011 E-61 NUREG-1937 

The doses given in the DEIS for these two species are the sum of the doses from the MCR (RAI 

05.09.05-01) and Little Robbins Slough (Environmental Report Rev. 3.0, Section 5.4, Table 5.4-

10, page 5.4-15). The DEIS correctly reports these doses in DEIS Appendix G, Table G-7, p. 

G-22. (0010-2-24 [Head, Scott]) 

Comment: DEIS Section 05.09. Radiological Impacts of Normal Operations. Page 5-90 Line 2 

(Table 5-14): The DEIS states, “Table 5-14 compares STPNOC’s estimated total body dose to 

the biota from the proposed Units 3 and 4 to the IAEA chronic dose rate values for aquatic and 

terrestrial biota” 

 Fish 6.8 x 10-4 1000 

 Invertebrate 1.6 x 10-2 1000 

 Algae 1.9 x 10-4 1000 

 Muskrat 3.0 x 10-2 100 

 Raccoon 3.1 x 10-2 100 

 Heron 3.0 x 10-2 100 

 Duck 3.1 x 10-2 100”, 

total dose in mrad per day from Units 3 & 4. These values should be (DEIS Table 5-13, as 

corrected in the previous comment, total dose in mrad per year divided by 365 to get mrad per 

day): 

 Fish 6.8 x 10-3 1000 

 Invertebrate 1.5 x 10-2 1000 

 Algae 1.5 x 10-3 1000 

 Muskrat 3.0 x 10-2 100 

 Raccoon 3.1 x 10-2 100 

 Heron 3.0 x 10-2 100 

 Duck 3.6 x 10-2 100 (0010-2-25 [Head, Scott]) 

Comment: DEIS Section 05.09. Radiological Impacts of Normal Operations. Page 5-91, Lines 

15-20: The DEIS states, “and lower values before and since (STPEGS 2008). During 2005, the 

REMP sampled six onsite wells and found one above tritium detection limits (260 pCi/L). A 

tritium concentration of 1200 pCi/L was observed (STPNOC 2009a). During 2006, 16 shallow 

aquifer, STPNOC-controlled wells surrounding the MCR (and located outside the Protected 

Area of existing STP Units 1 and 2) were sampled (STPNOC 2009a; STPEGS 2007).” This 

should be edited to, “and lower values before and since (STPEGS 2008). During 2005, the 

REMP collected six samples from an onsite well all of which exceeded the tritium detection limit 

(260 pCi/L). A tritium concentration of 1200 pCi/L was observed (STPNOC 2009a). During 

2006, a special study of 16 shallow aquifer STPNOC-controlled wells surrounding the MCR and 
Appendix E 

NUREG-1937 E- 62 February 2011 

located outside the Protected Area of existing STP Units 1 and 2 was conducted (STPNOC 

2009a; STPEGS 2007). Review of the Annual Radiological Environmental Operating Report 

showed the tritium concentrations ranged from less than 260 pCi/L to a little over 5000 pCi/L 

(STPEGS 2007).” (0010-2-26 [Head, Scott]) 

Comment: DEIS Section 05.09. Radiological Impacts of Normal Operations. Page 5-91, Line 

29: The units “Ci/L” should be changed to “Ci/yr”. (0010-2-27 [Head, Scott]) 

Comment: In the case of tritium ... The important thing here is we know what’s there, we 

measure, we monitor it. And, by the way, it is not in the drinking water, not in the deep aquifer. 

It is also -- what we have in our reservoir is actually below the Environmental Protection Agency 

limit, significantly below the Environmental Protection Agency limits for drinking water. 

(0004-2-1 [McBurnett, Mark]) 

Response: The level of tritium in the MCR is discussed in Section 5.9.6 of the EIS. This 

comment presented information consistent with that discussion and therefore required no 

change to the EIS.

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-21, Lines 25-26: The DEIS states, “staff’s dose analysis confirmed 

the liquid pathway doses to biota shown in Table 5-13 and Table G-7.” Note that Table 5-13 

(DEIS p.5-89) contains two table entry errors (invertebrate total dose and algae total dose); 

those entries are correct in Table G-7 (DEIS p.G-22). STPNOC also comments on this in DEIS 

Section 5.09. (0010-2-93 [Head, Scott]) 

Response: These dose estimates have been revised in Section 5.9 and Appendix G. These 

revisions did not affect conclusions reached in the EIS. 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-20 Line 4 (Table G-5): 

The DEIS states 

 ”Total Body 0.0042 0.0072 0.011 ... 

 Thyroid 0.0041 0.0099 0.14 ... 

 Bone 0.00077 0.00079 0.0016 ...” 

for STP Units 1 and 2, liquid, gaseous and total dose, respectively. Rev. 3.0 of the 

Environmental Report (Section 5.4, Table 5.4-8, p. 5.4-14) indicates that these doses are: 

 Total Body 0.0042 0.0080 0.012 ... 

 Thyroid 0.0041 0.0097 0.014 ... 

 Bone 0.00077 0.0011 0.0019 ...” (0010-2-90 [Head, Scott]) 
Appendix E 

February 2011 E-63 NUREG-1937 

Response: Table G-5 in Appendix G of the EIS was updated with the values indicated. The 

revisions do not affect the conclusions reached in the EIS. 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-20, Line 9: The DEIS states, “Table G-5 is the same table as ER 

Table 5-12.” Table G-5 is the same table as DEIS Table 5-12. The analogous table in Rev. 3.0 

of the Environmental Report (Section 5.4, Table 5.4-8, page 5.4-14) indicates differences as 

noted in the previous comment (re Page G-20, Line 4). (0010-2-91 [Head, Scott]) 

Response: Table G-5 in the EIS was updated with the values indicated; the change is also 

reflected in parallel Table 5-12. The revisions do not affect the conclusions reached in the EIS. 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-18, next to last line of Table G-4: The DEIS states, “Doses from the 

milk pathway were not calculated because there are no dairies within 50 mi of the STP site.” 

Rev. 3.0 of the Environmental Report (Section 5.4, Table 5.4-2, page 5.4-10) indicates that STP 

includes doses from the milk pathway, based on the presence of milk cows in four counties at 

least partially within 50-miles of STP (including Matagorda County which is wholly within 50-

miles of STP). The milk pathway makes up < 2% of the total body dose calculated for the ER. 

(0010-2-89 [Head, Scott]) 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-20, Lines 15-16: The DEIS states, “Doses from the milk pathway 

were not calculated because there are no dairies within 50 mi of the STP site.” However, Table 

G-4 on page G-18 has an entry, ”Milk Production within 50 mi of STP site,” which states that 

milk production is 2,130,000 liters per year. STPNOC calculated milk doses and reported them 

in Table 5.4-6 of Rev 3 of the ER. Also, DEIS page G-16, lines 10-11 state, “Milk consumption 

was not considered because there are no milk animals within 5 mi of the site.” While, the ER 

Section 5.4.2.2 states that there are no dairies within 5 miles of the STP site, we believe that 

NRC may have intended 50 miles instead of 5 miles. (0010-2-92 [Head, Scott]) 

Response: The sentence, “Doses from the milk pathway were not calculated because there 

are no dairies within 50 mi of the STP site.” was deleted from Section G.2.3 in Appendix G of 

the EIS. Doses calculated for the maximum individual do not include the milk pathway because 

there are no milk cows within 5 mi of the STP site, but the collective doses do include milk as 

indicated in Table G-4. This correction does not change the conclusions of the EIS. 

E.2.18 Comments Concerning Severe Accidents 

Comment: If there was a serious accident at South Texas Project, hopefully, there never will 

be, it could impact the whole State of Texas, not just Bay City. A 1982 report that was done for 

the NRC by Sandia Labs found that there could be 18,000 early deaths if there was a meltdown. 
Appendix E 

NUREG-1937 E- 64 February 2011 

That would be followed by thousands of cancers, and they would not be limited to Bay City. 

These are risks that Texans don’t need, risks that we don’t need to take. (0004-1-37 [Hadden, 

Karen]) 

Response: As discussed in Section 5.11 of the EIS, the NRC staff estimated the probabilityweighted risks associated with severe accidents at the proposed new units, and concluded that 

risks are low. No changes were made to the EIS as a result of this comment. 

E.2.19 Comments Concerning the Uranium Fuel Cycle 

Comment: DEIS Section 06.01. Fuel Cycle Impacts and Solid Waste Management. Page 6-12, 

Line 3. The DEIS states that the estimated whole body population doses from gaseous 

effluents, liquid effluents, radon-222, and technetium-99 total approximately 4300 person-rem 

per year. Values for gaseous releases (1280 person-rem per year), liquid releases (640 personrem per year) radon-222 (1900 + 36 = 1936 person rem per year) and technetium99 (320 

person-rem per year) presented in Section 6.1.5 of the DEIS total to 4176 or approximately 

4200 person-rem per year. The calculation of total detrimental health effects (TDHEs) is also 

affected by this difference. On line 4 of this page, the DEIS reports a value of 2.5 TDHEs 

annually. The calculation results in 2.4 TDHEs annually (4200 person-rem per year × 570 

TDHEs per million person-rem = 2.4 TDHEs per year). (0010-2-37 [Head, Scott]) 

Response: In Section 6.1.5 of the EIS, the NRC staff re-evaluated and revised the dose 

estimates for radon-222. The new total population dose is approximately 5300 person-rem, and 

the estimate of the associated detrimental health effects is approximately 3 fatal cancers, 

nonfatal cancers, and severe hereditary effects annually. The revisions do not affect the 

conclusions reached in the EIS.

Comment: DEIS Section 07.10. Fuel Cycle, Transportation, and Decommissioning - 

Cumulative. Page 7-50, Lines 20-24: The DEIS states that the combination of Units 3 and 4 and 

Units 1 and 2 would result in a scaling factor of not more than five. The two ABWR units would 

have an electrical output of 1350 MWe and capacity factor of 95%, result in a scaling factor of 

3.2 ((1350 x 95% ) x 2) ÷ 800) = 3.2). Units 1 and 2 have an electrical output of 1265 MWe 

(Table 7-1). Using a capacity factor of 80%, Units 1 and 2 would result in a scaling factor of 2.5 

((1265 x 80% ) x 2) ÷ 800) = 2.5). The capacity factor for Units 1 and 2 is likely to be greater 

than 80%, yielding a higher scaling factor. The combination of all four units would result in a 

scaling factor of 5.7 (3.2 + 2.5) or greater. The DEIS should be revised to indicate that the 

combination of the four units results in a scaling factor of not more than six. (0010-2-54 [Head, 

Scott]) 

Response: Section 7.10 of the EIS was revised to show that the combination of the four units 

results in a scaling factor of no more than six. These revisions do not affect the conclusions 

reached in the EIS. 
Appendix E 

February 2011 E-65 NUREG-1937 

Comment: We have concerns with ... radioactive waste problems that still have no solution. 

(0004-1-34 [Hadden, Karen]) 

Comment: I’m also concerned about ... waste storage. (0004-2-12 [Dancer, Susan]) 

Response: Section 6.1.6 of the EIS evaluates the impacts of storage and disposal of 

radiological wastes based on the generic impacts of the fuel cycle codified in 10 CFR 51.51(b), 

Table S−3, Table of Uranium Fuel Cycle Environmental Data. Section 6.1.6 presents Yucca 

Mountain as an example of a possible high-level waste repository; the conclusions in Section 

6.1.6 do not depend on whether Yucca Mountain, or another site, is ultimately the destination for 

spent fuel and high-level radioactive waste. Moreover, as indicated at 10 CFR 51.23(a), “The 

Commission has made a generic determination that, if necessary, spent fuel generated in any 

reactor can be stored safely and without significant environmental impacts for at least 60 years 

beyond the licensed life for operation (which may include the term of a revised or renewed 

license) of that reactor in a combination of storage in its spent fuel storage basin and at either 

onsite or offsite independent spent fuel storage installations. Further, the Commission believes 

there is reasonable assurance that sufficient mined geologic repository capacity will be available 

to dispose of the commercial high-level radioactive waste and spent fuel generated in any 

reactor when necessary.” In addition, 10 CFR 51.23(b) applies the generic determination in 

section 51.23(a) to provide that “no discussion of any environmental impact of spent fuel 

storage in reactor facility storage pools or independent spent fuel storage installations (ISFSI) 

for the period following the term of the . . . reactor combined license or amendment . . .is 

required in any . . . environmental impact statement . . . prepared in connection with . . . the 

issuance or amendment of a combined license for a nuclear power reactors under parts 52 or 

54 of this chapter.” Section 6.1.6 of the EIS has been revised to address this issue. 

E.2.20 Comments Concerning Transportation 

Comment: DEIS Section 06.02. Transportation Impacts. Page 6-24, Line 2: The DEIS states 

that the dose to a person at a truck service station exposed for 49 minutes at a distance of 52 

feet from the loaded shipping container would be 0.34 mrem per shipment. Previous NRC 

analyses (NUREGs 1881, 1815, 1817, 1872) indicated a dose of 0.07 mrem per shipment for 

this exposure scenario. (0010-2-38 [Head, Scott]) 

Response: After the issuance of NUREGs 1881, 1815, 1817, and 1872, the NRC staff reexamined the basis of the analysis of the dose to an employee at a truck service station

described in the Yucca Mountain EIS (DOE/EIS-0250; DOE 2002) and concluded that the dose 

per shipment should be five times the dose per shipment expressed in the earlier EISs. No 

changes were made to the EIS as a result of this comment.
Appendix E 

NUREG-1937 E- 66 February 2011 

Comment: DEIS Section 06.02. Transportation Impacts. Page 6-35, Line 23: The DEIS omits a 

phrase following line 23. The phrase “likely result in no excess health effects” should appear 

there as it does in a similar discussion on page 6-32, line 23 of the DEIS. (0010-2-41 [Head, 

Scott]) 

Response: Section 6.2 of the EIS was revised as suggested in the comment. 

Comment: DEIS Section 06.02. Transportation Impacts. Page 6-34, Table 6-10: The DEIS 

states that spent fuel inventory is obtained from Table 7.4-3 of the STPNOC ER. There is no 

Table 7.4-3 in the ER. Spent fuel inventory data is obtained from Table 7.4-1 of the ER with the 

exception noted in footnote (b). The DEIS table also presents the inventory for gaseous Kr-85. 

That radionuclide is not included in Table 7.4-1 of the ER. Table notes should be revised to 

identify the source of the information presented in Table 6-10. (0010-2-40 [Head, Scott]) 

Response: The Kr-85 entry in Table 6-10 was deleted for consistency with the ER. It was 

determined that the Kr-85 contribution to the radiation doses from transportation accidents was 

negligible, so removing Kr-85 from the accident risk calculations had no effect on the reported 

results. The footnote in Table 6-10 cited an incorrect table number from the ER. Table 6-10 of 

the EIS was updated to reflect this comment. These revisions do not affect the conclusions 

reached in the EIS. 

E.2.21 Comments Concerning Decommissioning 

Comment: DEIS Section 06.03. Decommissioning Impacts. Page 6-39, Lines 29-30: The DEIS 

states: “The regulations governing decommissioning of power reactors are found in 10 CFR 

50.75.” The decommissioning regulations in 10 CFR 50.75 are for decommissioning funding not 

decommissioning power reactors. The sentence should be clarified to also reference 10 CFR 

50.82, which provides the regulations on license termination for decommissioning power 

reactors. (0010-2-42 [Head, Scott]) 

Response: Section 6.3 of the EIS was revised to reference 10 CFR 50.82 and the radiological 

criteria for termination of the NRC license in 10 CFR Part 20, Subpart E. These revisions do not 

affect the conclusion reached in the EIS. 

E.2.22 Comments Concerning the Need for Power 

Comment: I don’t think the NRC has done an adequate job in analyzing the need for the plant. 

And if the plant is not needed, then we, as tax payers, and you, as residents of Matagorda 

County, may end up with a plant that is never completed. (0004-1-20 [Smith, Tom]) 

Comment: The Electric Reliability Council says we need 30,000 megawatts of new energy. 

We don’t think we need anywhere near that ...the folks who are in charge of determining 
Appendix E 

February 2011 E-67 NUREG-1937 

whether we need power, the Electric Reliability Council of Texas, haven’t done their homework. 

(0004-1-23 [Smith, Tom]) 

Comment: The DEIS has also failed in the need for power discussion to adequately consider 

reductions in demand for power and additional capacity from renewable and energy storage. 

(0015-14 [Johnson, Matthew]) 

Comment: We believe that the demand analysis contained in the DEIS seriously 

underestimates the reduction in demands and additional resources that will be arriving from 

energy efficiency, demand response, advanced meters, onsite solar and large-scale renewables 

resources like wind and solar. In fact, we believe the need for a large 2700 MW baseload plant 

for hire is questionable at best. Instead, Texas is more likely to need flexible, smaller plants to 

meet energy needs at peak times, as well as a combination of energy storage and renewable 

energy and existing plants to meet baseload. (0017-1 [Reed, Cyrus]) 

Comment: DEIS ... overestimates energy demand  Based upon our comments, it should be 

clear that the DEIS fails to consider a number of new developments in the Texas market, 

including building code adoptions, a new energy efficiency rule, federal stimulus monies, new 

solar investments, new wind investments, new clean energy, plans from San Antonio and Austin 

municipal utilities, and PACE financing districts. All of these developments will lessen the need 

for additional power from the expansion of the South Texas Nuclear Power Plant. 

(0017-13 [Reed, Cyrus]) 

Response: These comments express general opinions concerning the need for power, but do 

not make specific recommendations or offer alternative analyses. The final comment makes a 

general point about developments in the Texas electricity market that may reduce the need for 

power. All of the suggested sources of savings were considered, and where appropriate, the 

forecast in Chapter 8 was revised. Even with these revisions, the review team continues to 

conclude that there is sufficient baseload demand for power in the 2015 to 2020 time period to 

accommodate STP Units 3 and 4. 

Comment: The Electric Reliability Council of Texas, or ERCOT, projects that the state’s 

demand for electricity will increase more than 30 percent in the next two decades. 

(0004-1-3 [Hegar, Glenn]) 

Comment: For the last 30 years, STP has called Matagorda County home, and supplies 2 

million Texas homes with power, 2 million Texas homes with power. That’ll double, if we get the 

other two units, they’ll be able to supply 4 million Texas homes. And with 50 million people 

slated to be in Texas by the year 2040, 2050 at the latest, we’re going to need some power. 

(0004-1-7 [Weber, Randy]) 
Appendix E 

NUREG-1937 E- 68 February 2011 

Response: These comments generally support the idea that there is a need for the power to 

be produced by the proposed STP Units 3 and 4; therefore no changes were made to Chapter 8 

as a result of these comments. 

Comment: A number of studies done for the PUC and others indicate that we can meet 101 

percent of our demand for electricity in the I-35 corridor, and about 76 percent of the growing 

demand over that same period of time through energy efficiency. We will need some new 

power plants in the industrial belt along the coast, but not nearly as many as the Electric 

Reliability Council of Texas has indicated we will. (0004-1-26 [Smith, Tom]) 

Response: This comment did not provide documentation for the two numerical estimates given 

in the comment. While the rest of the comment goes on to provide specific estimates for the 

potential impacts of some of the energy efficiency programs in Texas, which are addressed 

individually elsewhere in this section, the review team was not able to determine what studies 

were used and what assumptions the commenter was relying on to account for the level of 

energy savings cited in the comment. More generally, based on the review team’s evaluation, 

the overall savings are likely to be far lower than anticipated in this comment. The review 

team’s reviews of the latest Public Utility Commission of Texas (PUCT) analyses and Electric 

Reliability Council of Texas (ERCOT) forecasts can be found in Chapter 8. 

Comment: They haven’t really looked at the amount of wind we’ve got, potentially, or amount 

of energy efficiency, haven’t added in all the coal plants that have been permitted, or are close 

to being permitted. For example, they assume that wind only blows 8.7 percent of the time. I’ve 

been to your coast. I know it’s a hell of a lot stronger than that. The numbers on the coast 

seem to be around 40 percent of the time, high 30s in the evenings and night out in the West 

Texas wind areas. (0004-1-25 [Smith, Tom]) 

Response: This comment appears to assume that the 8.7 percent effective load carrying 

capacity (ELCC) is based purely on the percent of the time that the wind blows. The 2007 

ERCOT-ordered study that resulted in this figure was far more sophisticated because it takes 

into account not only the wind resource but all reasons for potential loss of generation when 

needed to meet firm demand. A new ERCOT study has since been completed of the loss of 

load expectations and reserve margin and was considered by the ERCOT Board of Directors at 

their November 16, 2010 meeting. As a result of their review of the new study the ERCOT 

Board of Directors explicitly voted to continue to use 8.7 percent for ELCC and to increase the 

target reserve margin to 13.75 percent. These values were explicitly used in ERCOT’s 

December 2010 update to the May 2010 Capacity, Demand, and Reserves report and in the 

review team’s sensitivity test of the 2010 ERCOT forecast in Chapter 8. 

Comment: We think we can save 1,100 megawatts with the new building codes that are now 

required in Texas, 154 megawatts with better appliances, 3,300 megawatts with the programs 

that the Public Utilities Commission is putting in there. There are 1,900 megawatts of new 
Appendix E 

February 2011 E-69 NUREG-1937 

permitted coal that aren’t in the NRC report that you saw up here, and we think there’s another 

2,400 likely to get permitted within the next six months. We think that there is about another 

3,500 megawatts of geothermal that’s likely, and other non-wind resources that could be put on 

line in the same period of time at a fraction of the cost. And that the real number is probably 

about 8,000 megawatts of wind on peak, off peak, serving as baseload with storage. And 

15,000 megawatts of combined heating and power that could economically be put into place. 

The bottom line is, that entire capacity hole under the worst case scenario of 30,000 megawatts 

and leaves another 5,000 on the table leftover, spare. There’s not a market for this power plant. 

There’s no real need for the power plant. And we don’t think the NRC did a good enough job at 

looking at the need for the power plant. ... and we believe that the NRC needs to go back and 

take a good hard look at the basis of the assessment for the analysis of need. 

(0004-1-28 [Smith, Tom]) 

Response: The energy savings discussed in this comment are speculative and depend on the 

success of a number of market factors, public policies and incentives that are not or may not be 

accurate in the current Texas electricity marketplace. For example, the savings suggested 

above depend to a significant extent on the implementation of public policies that are not in 

current Texas law (including state appliance standards), assumed extensive deployment of 

technologies such as smart thermostatic controls and (so far, unproven) commercial success of 

low-cost energy storage methods currently announced at the pilot stage that would significantly 

“firm up” wind generation. It further assumes factors about the marketplace such as the 

assumed rate of construction of new housing and commercial space after 2010 (to which new 

statewide building codes established for 2011 would apply) that are not or may not be 

applicable in the current depressed economic environment. 

Based on the PUCT’s actual established goals of 25 percent in 2011 and 30 percent for the 

public utility programs, these programs potentially could produce additional savings beyond 

those already incorporated in the ERCOT forecast of 5 percent in 2012 and 10 percent in 2013 

and after. The ERCOT 2010 forecast for electricity load growth and this increment would yield a 

maximum of about 650 MW savings by 2015 and about 1050 MW savings per year by 2020. 

However, based on discussions with ERCOT and examination of the PUCT order, there are a 

number of considerations to keep in mind that may significantly reduce the impact on actual 

electricity consumption. 1) The PUCT program goals are based on “deemed” or assumed 

savings for specific funded activities, and do not represent measured savings. They do not, for 

example, count the take-back effects on electricity consumption when more efficient equipment 

is used more as a result of lowered operating costs. 2) The utilities are encouraged and 

compensated through customer rates for funding activities deemed to save energy, but are not 

penalized if they fall short. 3) Because the programs are operating costs of the utilities that are 

ultimately funded by customer utility bills, PUCT imposed cost caps on the programs to keep 

cost recovery from having too large an impact on customer rates. This constraint may limit the 

size of the program, if the cost of deemed savings escalates as the easiest savings are 
Appendix E 

NUREG-1937 E- 70 February 2011 

achieved and more costly savings are addressed. PUCT strongly constrained the program for 

this reason. For all of these reasons the review team does not believe that 3300 MW will 

actually be achieved by the PUCT program and that a far lower estimate is appropriate. See 

Chapter 8 for details. 

The ERCOT 2010 forecast includes all permitted conventional thermal power plants and wind 

and non-wind renewable portfolio standard (RPS) resources that meet the requirements for 

inclusion as resources in the ERCOT market area, so these are not missing from the forecast. 

The review team has updated the need for power analysis in Chapter 8 to include the 2010 

ERCOT forecast and has conducted sensitivity tests of that forecast to include factors such as 

significant increases in energy efficiency and greatly expanded penetration of RPS resources. 

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 1) The much lower cost of energy 

efficiency. 

As an example, recent reports by Nexant in a study of the San Antonio demand side 

management program show that their energy efficiency program has significant energy savings 

at very low cost. They stated in their report to San Antonio, “As programs expand, CPS Energy 

should continue planning for the resources necessary to support large-scale deployment of 

DSM program portfolio and to achieve both short-term and long-term goals.” The overall cost of 

the program as defined for the energy efficiency programs only is: “Cost of Saved Energy = 

$0.032/kWh.” This does not take into account the additional reduction in peak costs that their 

load management programs achieved. The combined programs were determined to have 

achieved a reduction of 44.7 MW of peak energy with an expected energy savings of 

86,712,978 KWh. 

The Texas Public Utility Commission has been considering modifying the state’s energy 

efficiency incentive program and has released a Strawman rule that will change the goal of the 

program. The proposed rule will increase the annual reduction from the current standard of 

20% of new growth in demand to 50% of new growth in demand or 1% of peak demand, 

whichever is greater. Using the published ERCOT consumption data this would reduce energy 

consumption in the regulated areas of the state by 635 MW annually using the published 2009 

actual value and 705 Mw annually using the 2015 ERCOT estimated peak demand forecast, 

this would reduce the need for additional generation by at least 3200 MW by 2020 and if the 

ERCOT forecast is accurate, would be over 3500MW. 

ERCOT does not currently use energy efficiency other than those based on Texas HB3693 in its 

projections and is currently shown to be calculated at only 242 MW annually. 

(0015-17 [Johnson, Matthew]) 
Appendix E 

February 2011 E-71 NUREG-1937 

Response: Because the San Antonio savings discussed in the first paragraph of the comment 

are historical savings, the 44.7 MW already is included in the ERCOT forecast. ERCOT 

describes the 242 MW estimate as only efficiency gains not otherwise accounted for by its more 

general econometric analysis of load growth. In other words, the existing level of demand and 

econometric forecast plus the 242 additional MW already accounts for 20 percent savings from 

the PUCT program. The PUCT amended rule as adopted in late 2010 increased the 

percentage savings goal for 2012 to 25 percent and to 30 percent for 2013 and all later years 

(not 50 percent as assumed in the strawman rule). That change increases the 2012 goal by 5 

percentage points and the 2013 goal by 10 percentage points. In the review team’s test of the 

ERCOT assumptions in Chapter 8, these amounts have been multiplied by all increases in 

power demand in the ERCOT region (not just PUCT-regulated utilities) and subtracted from the 

2010 ERCOT forecast. Applying the new percentages to all of ERCOT allows for savings that 

would be achieved by non-regulated utilities within ERCOT.

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 2) ERCOT/PUC energy forecast 

(DEIS page 8-20, Need for Power): 

ERCOT recently revised their load forecast, as released in their May 2010 load forecast and 

reserve margin update prepared for the ERCOT board of directors, dated May 18, 2010. 

According to this report ERCOT has reduced its estimate of forecasted demand from 72,172 

MW to 70,517 MW for a reduction of 1655 MW or a 2.2% peak reduction in 2015. ERCOT has 

also increased their estimate of wind carrying capacity reported in their March 2010 report from 

708 MW to 793 MW or a 12% increase in just 2 months and an additional increase of 115 MW 

by 2015. This does not take into account any increases in effective load carrying capacity 

(ELCC) factor that coastal or off shore wind developments might add or the addition of large 

scale storage in the market to time shift the energy provided by wind or solar generation assets. 

New additional generation of 2,073 MW in the ERCOT generation portfolio was also reported. 

Additionally 26,182 MW of planned units in the Full Interconnection Study Phase are also 

reported, providing an ERCOT total estimate of 31,757 MW of additional generation available in 

2015. By ERCOT’s estimates the reserve capacity will exceed 51% under these conditions. 

(0015-18 [Johnson, Matthew]) 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

E. The DEIS does not account for 31,757 MW of additional capacity through interconnections in 

the ERCOT region by 2015. The addition of this capacity will create a reserve capacity of 51% 

in the ERCOT region. The failure of the DEIS to account for this increase has the effect of 

understating the total capacity available in the ERCOT region without the addition of STP Units 

3 & 4. (0015-33 [Johnson, Matthew]) 
Appendix E 

NUREG-1937 E- 72 February 2011 

Response: The need for power estimate in Chapter 8 has been revised to incorporate the 2010 

ERCOT forecast. ERCOT does not include planned units in the process of full interconnection 

studies because these plants are still considered not to be available to produce power for 

transmission during the time period under consideration, and may in fact be cancelled before 

they have an interconnection agreement. After due consideration of the most recent Loss of 

Load Expectation study, ERCOT’s Board of Directors adopted a 13.75 percent target reserve 

margin, but has elected to maintain the ELCC at 8.7 percent of nameplate capacity. These 

values are taken into account in the review team’s analysis and sensitivity test of the 2010 

ERCOT forecast in Chapter 8 of the EIS. Chapter 8 already had taken into account over 18,500 

MW of installed wind energy (with an ELCC of 1060 MW) by 2020. 

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 3) Texas Non-wind RPS - 

The PUC is considering adding an additional renewable energy mandate to the state’s existing 

Renewable Portfolio Standard. This has been assigned a project #35792 and a strawman has 

been issued. This would provide an additional 500 MW of generating capacity in the ERCOT 

market. (0015-19 [Johnson, Matthew]) 

Comment: 500 MW Rule  During the 2009 Legislative Session, there were several attempts 

to create a non-wind Renewable Portfolio Standard, with proposals ranging from 1,000 to 4,000 

MWs of solar, geothermal and biomass requirements by 2020. While none of these legislative 

attempts were ultimately successful and it would be very difficult to predict what will happen in 

the 2011 Legislative Session, the PUC has now published a “strawman” which would implement 

a provision of existing law which says the state should set a target of at least 500 MWs of nonwind renewables by 2015. More recently, the PUC Commissioners discussed the potential to 

hold an open meeting on the non-wind renewable proposed rule this summer, with an aim of 

publishing a final rule for comment in early Fall and implementing the rule by the end of the 

year. In practice, such a rule would require Retail Electric Providers within ERCOT to either 

contract with non-wind renewables, purchase RECs from other entities or pay a fine. Thus, we 

would assume this would increase renewable energy sources within ERCOT in the competitive 

market, again offering a direct competition for power compared to the proposed nuclear plant. 

The impact of this proposed rule is not covered in the DEIS. (0017-9 [Reed, Cyrus]) 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

F. The DEIS does not account for a non-wind renewable capacity mandate under consideration 

by the Texas PUC. Adoption of this renewable portfolio standard would add 500 MW of 

capacity in the ERCOT region. The failure of the DEIS to account for this increase has the 

effect of understating the total capacity available in the ERCOT region. (0015-34 [Johnson, 

Matthew]) 
Appendix E 

February 2011 E-73 NUREG-1937 

Response: The PUCT was directed by the Texas legislature to establish a target of having at 

least 500 MW of capacity from a renewable energy technology other than 

a source using wind energy, and this goal is already reflected in an existing regulation, 16 Texas 

Admin. Code 25.173(a). The PUCT has issued a strawman rule for non-wind RPS that would 

amend section 25.173(a), but it is not a final rule and as of late 2010 both the final text of the 

rule and any result are still in PUCT staff draft and are speculative. In addition, it is not clear 

how much net generation capacity would actually be provided to the ERCOT market as a result 

of this rule even if it is adopted in its current form. The strawman rule does not increase the 

overall goal for renewable energy installed capacity beyond 5880 MW in 2015 and 10,000 MW 

in 2025, both of which have been exceeded thanks to the substantial increase of wind energy in 

Texas. Also, the overall 500 MW capacity target for non-wind renewable is the same in the 

existing regulation and the strawman rule. To the extent that the strawman rule would have an 

effect, it may simply trade non-wind renewables for wind. Nor is it clear to what extent non-wind 

RPS generation could function as baseload capacity. Solar, for example, could not do so 

without significant investment in storage. Finally, the December 2010 update to the 2010 

ERCOT forecast shows 4800 MW of newly planned non-wind generating capacity by 2015 that 

will meet its standards as a generating resource, of which 145 MW is biomass and most of the 

rest is natural gas. This forecast already is included in the need for power analysis in Chapter 8 

of the EIS. No changes were made to the forecasts in the EIS as a result of these comments 

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 6) Additional Federal Incentives. 

In addition to the $218 million in funding from the American Recovery and Reinvestment Act, 

additional Federal incentives for energy efficiency programs recently passed in the House of 

Representatives in HB5019 and would provide over $6 billion in energy efficiency retrofit 

incentives further reducing the need for new generation. (0015-22 [Johnson, Matthew]) 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

A. The DEIS analysis of the need for power is incomplete because it accounts only for decline in 

demand attributable to demand side management from the requirements of Texas House Bill 

3693. The DEIS does not account for reduced demand caused by funds for energy efficiency 

programs under the American Recovery and Reinvestment Act nor additional funds for the 

same purpose as proposed in the recently passed U.S House of Representatives HB 5019. 

Additionally, the DEIS does not address the recent energy efficiency experiences of the San 

Antonio municipal utility that yielded a peak reduction of 44.7 MW and anticipated energy 

savings of 86,712,978 KWh at a cost of $0.032/KWh. The DEIS’s attenuated consideration of 

the effects of energy efficiency/demand side management programs has the effect of 

overstating the Applicant’s need for power. (0015-31 [Johnson, Matthew]) 

Response: The energy efficiency programs funded under the American Recovery and 

Reinvestment Act (ARRA) are included implicitly in the 2010 ERCOT forecast because the 2010 
Appendix E 

NUREG-1937 E- 74 February 2011 

electricity demand is affected by the recent history of electricity demand savings. This recent 

history implicitly includes the past impact of ARRA as well as other recent subsidies for energy 

efficiency and past successes in San Antonio and Austin. The past rate of success is carried 

forward in the econometric forecast. Similarly, recent history of energy savings for all utilities is 

reflected in the historical data for 2009 used to estimate future demand relationships. Based on 

discussions with ERCOT, the review team has learned that documentation of the actual energy 

savings of these activities is difficult to obtain, but so far has not shown any significant impact on 

the forecast, partly for reasons outlined in the answer to comment 0017-8, shown below. No 

changes were made to the forecasts in Chapter 8 as a result of this comment. 

HB 5019 only passed the U.S. House of Representatives and is not law. It is not appropriate to 

base a need for power forecast on speculation that a proposed bill might become law; therefore, 

no changes were made the EIS as a result of these comments. 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

B. The DEIS analysis of the need for power is flawed because it does not consider the most 

recent energy forecast from ERCOT. The DEIS assumes that peak demand in 2015 will be 

72,172 MW. However, the most recent ERCOT forecast actually projects peak demand in 2015 

at 70,517 MW or a 1655 MW/ 2.2% reduction in peak demand. The failure to consider this more 

recent energy forecast has the effect of overstating the Applicant’s need for power. 

(0015-32 [Johnson, Matthew]) 

Response: Chapter 8 of the EIS has been revised to take the 2010 ERCOT forecast into 

account. 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

C. The DEIS analysis does not account for increases in wind carrying capacity. The most 

recent ERCOT analysis indicates that wind carrying capacity has increased has increased from 

708 MW to 793 MW so far this year and is expected to increase another 115 MW by 2015. The 

failure of the DEIS to account for this increase has the effect of understating the total generation 

capacity available in the ERCOT region. 

D. The DEIS fails to account for the addition of 2,073 MW of non-nuclear capacity to the 

ERCOT generation portfolio. This additional capacity was not accounted for in the need for 

power discussion in the DEIS. The failure of the DEIS to account for this increase has the effect 

of understating the total generation capacity available in the ERCOT region. (0015-2 [Johnson, 

Matthew]) 

Response: This comment appears to refer to values contained in the 2010 ERCOT forecast. 

That forecast has been included in the revised need for power analysis in Chapter 8. 
Appendix E 

February 2011 E-75 NUREG-1937 

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 4) New Building codes. 

The State Energy Conservation Office (SECO) has announced that the state will be adopting 

the IECC 2009 building code. The International Energy Conservation Code (IECC) is a 

national, consensus-based, model code. The 2009 IECC is expected to result in significant 

energy savings and related emissions reductions, estimated at 12 to 15% annual improvement 

for average homes. In a report examining the potential for energy efficiency in Texas, the 

American Council for an Energy Efficient Economy estimates that with this new code, Texas 

could save 10,533 kilowatt hours of electricity annually and 2,362 megawatts annually of peak 

summer demand by 2023. These new standards have significant increases in the requirements 

for energy savings that are required for all new construction. According to the Building Code’s 

Assistance Project (BCAP) if Texas began implementing the 2009 IECC and Standard 90.1-

2007 statewide in 2011, businesses and homeowners would save an estimated $785 million 

annually by 2020 and $1,605 million annually by 2030 in energy costs (assuming 2006 prices). 

Additionally, implementing the latest model codes would help avoid about 213.9 trillion Btu of 

primary annual energy use by 2030 and annual emissions of more than 15.6 million metric tons 

of CO2 by 2030. (0015-20 [Johnson, Matthew]) 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

G. The DEIS does not account for reduced demand caused by the adoption of the International 

Energy Conservation Code. The IECC building code has the potential to reduce peak demand 

by 2,362 MW annually by 2023 in the ERCOT region. The failure of the DEIS to account for this 

reduction in peak demand has the effect of understating the total capacity available in the 

ERCOT region. (0015-35 [Johnson, Matthew]) 

Comment: Building Codes  On June, 2010, the State Energy Conservation Office approved 

rules that will require all areas of Texas to meet or adopt new energy codes for new 

construction. Thus, all commercial, industrial and multi-family homes must meet IECC 2009 

Energy Codes by April 1, 2011, while single-family homes must meet 2009 IRC energy codes 

(Chapter 11) by January 1, 2012. What this means is that new commercial and residential 

homes will use less energy - about 15 percent less according to the Energy Systems 

Laboratory. In fact, several major metropolitan areas have already acted before SECO even 

passed the new rules. Thus, the City of Austin adopted 2009 IECC codes for all new 

construction in April of 2010 with local amendments meaning buildings in Austin will be even 

more energy efficient. San Antonio adopted the 2009 IECC codes on May 1, 2009, while the 

City of Waco did in early 2010. Thus within the next few years, all new construction in Texas 

will help reduce the growth in energy demand. This is not reflected in the DEIS discussion of 

energy demand and alternatives. We believe this could reduce baseload and peak energy 

demand in Texas by hundreds and perhaps thousands of megawatts over the next five years. 

(0017-6 [Reed, Cyrus]) 
Appendix E 

NUREG-1937 E- 76 February 2011 

Response: Although not directly cited in this comment, many if not all of the figures cited in the 

first comment appeared to come from a 2007 report of the American Council for an EnergyEfficient Economy (ACEEE) by R. Neal Elliott et al. “Potential for Energy Efficiency, Demand 

Response, and Onsite Renewable Energy to Meet Texas’s Growing Electricity Needs (ACEE, 

Report No. E073). In the report being relied upon in the first comment, the reduction in peak 

electricity demand in the state would be 1054 MW in 2015 and 1754 MW in 2020. The 2007 

report does not refer to the 2009 IRC energy or IECC energy codes but does contemplate 

increasing the stringency of energy codes in Texas to save 15 percent relative to the thencurrent code beginning in 2009 and by 30 percent in 2020. The review team notes that if 

sensitivity testing were performed on the 2010 ERCOT forecast in Chapter 8 to account for the 

new building codes, adjustments would have to be made to account for the facts that ERCOT 

serves only about 85 percent of the Texas electricity market, and that both later program 

implementation than assumed by ACEEE and lower projected building construction than was 

assumed by ACEEE would reduce the impact of new building codes. 

Over the very long term (20 to 30 years), a new building code could be effective in reducing 

electricity consumption due to heating, cooling, and to some extent, lighting. Some of the 

potential savings would be in end uses such as lighting that are also being targeted by utility 

programs and municipal programs, so it is important not to double count. There are additional 

reasons to consider ACEEE projection speculative. The first is that in Texas, code adoption and 

enforcement occurs at a local level, and as noted by the commenter, many jurisdictions do so 

before the state updates its statewide standard. Many of the large metropolitan code-enforcing 

jurisdictions in Texas already had adopted the 2003, 2004, 2006, or 2009 model standards even 

though the statewide standard was the 2000 version (Energy Systems Laboratory 2010). Thus, 

the trend in energy savings from early adoption would have been embodied in the historical 

energy consumption data used to produce the ERCOT forecasts. The impact of imposing the 

2009 standards would be significantly less than might otherwise be supposed, based on an 

engineering comparison of buildings with the new codes with the old codes. Second, because 

the codes would apply only to new structures, its effect depends on how many new structures 

are built under the new codes. Third, new codes would not address additional growth and 

electrification of household services (e.g., additional plug loads) in either new or existing homes. 

Finally, the codes must be enforced as well as adopted. Not all jurisdictions do this equally well, 

although the major metropolitan areas in Texas reportedly do a good job. In addition, the 15 

percent savings figure discussed in the second comment must hold up in the field (there would 

have to be no take-back or rebound effects on energy use from lowered cost of household 

services due to the more efficient buildings). ERCOT did not publish the underlying economic 

data for their 2010 forecast and the review team was not able to locate either good estimates of 

future construction in Texas or estimates of building-code-sensitive electricity use in new 

buildings so it was not possible to perform a quantitative estimate of the near-term impact of the 

new building code It is likely that many of the contemplated savings would be covered in the 
Appendix E 

February 2011 E-77 NUREG-1937 

lower demand growth in the 2010 ERCOT forecast and in the sensitivity tests the review team 

conducted on the ERCOT forecast in Chapter 8. 

Texas A&M University Energy Systems Laboratory (Energy Systems Laboratory). 2010. 2010 

Texas Jurisdiction Energy Code Adoption Survey. ESL-TR-10-06-01. Accessed on February 4, 

2011 at http://www-esl.tamu.edu/terp/reports/2010. 

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 5) In the new study on Energy 

Efficiency in the South they found that fewer new power plants would be needed with a 

commitment to energy efficiency. 

Our analysis of nine illustrative policies shows the ability to retire almost 25 GW of older power 

plants - approximately 10 GW more than in the reference case. The nine policies would also 

avoid over the next twenty years the need to construct 49 GW of new plants to meet a growing 

electricity demand from the RCI sectors. Further, the industry sector offers the greatest energy 

efficiency potential in Texas. In 2020, savings from all three sectors is about 10% (1,180 TBtu) 

of the total energy consumed by the State in 2007. Electricity savings constitute 668 TBtu of 

this amount. With these policies, the generation of electricity from the equivalent of 17 power 

plants of 500-MW each could be avoided in the year 2020. (0015-21 [Johnson, Matthew]) 

Response: This comment suggests the need for power analysis in the EIS is deficient because 

it does not incorporate a series of policies that could potentially reduce the need for new power 

plants, such as energy saving building code changes. Not all of those programs have been 

implemented. For those programs that have been implemented, the reduction in energy 

demand they will produce is uncertain, and either was contained in the ERCOT forecast or to 

the extent that it was not, was addressed in the analysis in Chapter 8 and are likely to have a 

small impact. As for the policies not implemented yet, they are too speculative to be included in 

the analyses. Finally, the review team relied upon the analyses, assumptions, and 

methodologies employed by ERCOT in their assessment of the need for power. This comment 

did not result in a change to the EIS. 

Comment: The NRC Staff’s DEIS is flawed because it failed to do a thorough analysis of the 

need for power. NRC Staff failed to adequately consider: 7) Compressed Air Energy Storage - 

Significant advances in energy storage technologies are being made. This will provide 

additional firming or increase in the capacity factor of wind generation. New projects have been 

announced similar to one by ConocoPhillips with General Compression announced on April 14, 

2010. General Compression, Inc. (GC), a Massachusetts company developing an innovative 

compressed air energy storage system, today announced it has signed an agreement with 

ConocoPhillips (NYSE: COP) of Houston, Texas, to develop compressed air energy storage 

projects, beginning with a pilot project in Texas, using General Compression’s Advanced 
Appendix E 

NUREG-1937 E- 78 February 2011 

Energy Storage (“GCAES”) technology. GC and ConocoPhillips are evaluating a multiple-phase 

pilot project in Texas that would incorporate GCAES technology with wind energy, underground 

air storage and power sales. GC’s near-isothermal compressor/expander module is used to 

create 2 MW to 1,000 MW, 8 to 300 hour discharge, compressed air energy storage (CAES) 

projects. According to the engineering designs, “The projects shape power from the wind farm 

so that it arrives to the customer 5 days a week for 8 hours (Peaking), 5-7 days a week for 16 

hours (Intermediate) or 7 days a week for 24 hours (Baseload), or any other demand curve that 

a customer provides. Projects are designed to bid into firm power contracts, and to have 

enough storage duration, from 20-300 hours, to meet contracted delivery commitments.” In 

addition “Shell and Luminant will also explore the use of compressed air storage, in which 

excess power could be used to pump air underground for later use in generating electricity. 

This technology will further improve reliability and grid usage and becomes more economical 

with large-scale projects, such as proposed for Briscoe County.” As discussed in the 

“Comments Regarding Luminant’s Revision to the Comanche Peak Nuclear Power Plant” by 

Raymond H. Dean, Ph.D, there has been considerable additional information on the conclusions 

of combining new generation power sources with storage that would also apply in this instance. 

Natural gas, wind, solar; and energy storage either individually or in combination, are viable 

alternatives that could both produce baseload power and be environmentally preferable to 

nuclear generation. What really matters is whether grid managers understand, know how to deal 

with, and have experience dealing with them in the dynamic electrical-grid environment. For 

example, there are several decades of experience using CAES to absorb power from the grid 

when customer demand is weak and supply power to the grid when customer demand is strong. 

This is not significantly different from using CAES to absorb power from the grid when wind 

power is strong and supply power to the grid when wind power is weak. 

(0015-23 [Johnson, Matthew]) 

Comment: The DEIS analysis of the need for power is flawed and incomplete. 

H. The DEIS does not account for a compressed air energy storage (CAES) project planned for 

Texas by ConocoPhillips/General Compression that will be available for baseload capacity. 

This recently announced project is proof that the combination of wind capacity and CAES is a 

viable means of generating baseload power. The failure of the DEIS to account for this source 

of baseload capacity has the effect of understating the future total generating capacity in the 

ERCOT region. (0015-36 [Johnson, Matthew]) 

Response: These comments suggest that technology is commercially available that will in 

effect turn intermittent wind power into reliable baseload power. The projects discussed are still 

in the pilot stage and are subject to evaluation before full commercial deployment. Among the 

considerations would be technical performance, scalability, and cost. The comment provides no 

estimate of the effect on the overall demand for baseload power. The review team regards the 

comments as speculative and therefore no changes were made to Chapter 8 as a result of 

these comments. 
Appendix E 

February 2011 E-79 NUREG-1937 

Comment: When considering all reductions in demand, due to efficiencies and DSM programs 

that are implemented by municipally owned utilities, the forecast reflects a likely decrease in the 

total need for energy of 35,877 MW by 2020. This reduction in demand, combined with the 

anticipated additional non-nuclear generation, including increased capacity for wind, solar, 

geothermal and other renewables, makes the addition of STP Units 3&4 unnecessary to meet 

baseload needs. Then, if the industrial customers follow the recommended guidelines, an 

additional 8,500 MW of reduction could be achieved for a total of 44,377 MW. Any need for 

additional generation to serve the market at this time would have to be in doubt. The following 

chart summarizes the combination of increased efficiencies and generation capacity. 

(0015-24 [Johnson, Matthew]) 

Response: This comment is based on the adding together of several potential sources of 

increased energy efficiency, some of which are accounted for in the 2010 ERCOT forecast, 

some of which were added to the 2010 ERCOT forecast based on events that have occurred 

since the forecast was published, and some of which are still speculative. The review team 

believes the reliable potential savings are significantly smaller than indicated in the comment 

and has based its assessment on the 2010 ERCOT forecast, plus the impacts of several actions 

taken by ERCOT and PUCT since the forecast that would modify that forecast. With respect to 

industrial energy, the Texas industrial sector has been active historically in saving energy and 

adopting combined heat and power where economically attractive. This trend is included 

implicitly in the ERCOT forecasts. The 2010 ERCOT forecast and review team sensitivity test of 

the forecast continue to show a need for baseload power in the 2015-2020 period. The 

modified forecast can be found in Chapter 8.

Comment: More Wind - CREZ goes forward - While we believe the DEIS does address the 

likely impact of some 18,000 MWs of total wind coming into ERCOT, an update on the 

successful resolution of several major CREZ lines would make the DEIS more complete. A 

review of recent hearings before the PUC Commissioners show that three major lines by 

ONCOR and LCRA have been approved, while one major LCRA line was rejected, but will be 

resubmitted in the coming months. In addition, there is insufficient discussion of the potential for 

onshore and offshore wind in East Texas to provide power to Texans during the day. In fact, in 

addition to two existing wind projects in Kenedy County, several developers are looking all along 

the Texas coast for additional opportunities to provide power. We believe that this wind - more 

prevalent during the times when power is needed most - is likely to increase in coming years 

and is not analyzed in the DEIS. (0017-12 [Reed, Cyrus]) 

Response: The comment acknowledges that the draft EIS included a substantial amount of 

installed wind generation (18,456 MW) of which approximately 9500 MW was already installed 

in late 2010. Only part of the remainder was included in the ERCOT forecast because ERCOT 

counts only those planned units with a signed interconnection agreement, The review team 

included all of 18,456 MW in its sensitivity test of the ERCOT forecast in the DEIS. The 18,456 
Appendix E 

NUREG-1937 E- 80 February 2011 

MW was a middle planning figure used for the Competitive Renewable Energy Zones (CREZ) 

program. The 18,456 MW estimate assumed a successful completion of the CREZ 

transmission projects. The comment notes that successful resolution of the several major 

CREZ lines is underway. 

The review team believes that the emphasis on serving peak power needs in this comment is 

misplaced, since the STP Unit 3 and 4 plants are intended to address baseload power needs. 

The CREZ lines and coastal power are discussed briefly in the Chapter 8 need for power 

assessment. 

Comment: Energy Efficiency Portfolio Standard  First of all, the demand forecast and review 

fail to take into account new programs within ERCOT designed to reduce both peak demand 

and overall energy use. Thus, the Texas Legislature passed HB 3693 in 2007, which mandated 

that the major investor-owned utilities both in ERCOT, and outside of ERCOT reduce their peak 

demand by 20 percent of load growth in 2010, while: achieving an energy savings target of 

percent capacity of that peak demand reduction. While a relatively small amount on a yearly 

basis, reduction of approximately 20 MW of baseload power per year would lower the need for 

additional baseload resources. In addition, this year, in 2010, the Public Utility Council has 

published a draft rule that would require the nine investor-owned utilities to meet much higher 

goals. Just this week, the PUC has released the latest version of the rule, and an open meeting 

to consider it is expected later this summer. Thus, under the latest version of the proposed rule, 

investor-owned utilities would need to meet 50 percent of load growth while also meeting a 

capacity factor of 25 percent for energy savings by 2014. Thus, these goals would triple the 

amount of energy efficiency that investor-owned utilities are required to meet, reducing both 

peak and baseload demand. While the DEIS makes the case in its Alternative Section that 

demand reduction and conservation is already incorporated in ERCOT forecasts, the Sierra 

Club believes that in fact it is not and in particular the impacts of this proposed rule likely to be 

adopted soon are definitely not. But it will be adopted by August or September of this year. 

Thus, there has been no attempt to show how the new PUC requirements published as a draft 

rule would impact the projections of future demand. We estimate that the new requirements 

would reduce peak demand by 560 MWs in 2014, and baseload demand by some 150 MWs by 

2014. Cumulatively, the impact would be much greater. (0017-2 [Reed, Cyrus]) 

Response: The final version of the rule discussed in this comment, as adopted, took effect 

December 1, 2010 and requires significantly less energy savings than contemplated by the 

comment. The rule’s goals are 25 percent savings in 2012 and 30 percent in the year 2013 and 

after, which adds 5 percentage points and 10 percentage points to the previous savings goals. 

However, these goals may be strongly constrained by cost caps that limit the impacts on 

customer bills to 0.12 cents per kWh for residential customers and 0.75 cents per kWh for 

commercial customers. The review team’s estimates of the effects of the rule are discussed in 

Chapter 8. 
Appendix E 

February 2011 E-81 NUREG-1937 

Comment: San Antonio Plan  In addition, while the alternative section discusses CPS Energy 

laudatory plan to reduce peak demand by 771 MWs by 2020, there is no attempt to assess how 

this would impact overall demand or the need for baseload power in the state as a whole. Thus, 

CPS Energy itself recently discovered that the combination of reduced demand, energy 

efficiency goals and increasing investments in renewable energy had made its initial plan to buy 

1,200 MWs of power, from nuclear plants unnecessary. Indeed, in the space of two years, CPS 

Energy found that there “need” for power was reduced from 1,200 MWs to 600 MWs to some 

200 MWs simply by emphasizing other alternatives like efficiency, conservation and 

renewables. (0017-3 [Reed, Cyrus]) 

Comment: Austin Energy Clean Energy Plan Similarly, the DEIS fails to consider the impacts 

of the Austin Energy 2020 Plan, recently approved on April 22, 2010 by the Austin City Council. 

Under the plan, Austin Energy will attempt to reduce energy demand by at least 800 MWs by 

2020, while purchasing close to 1,000 MWs of additional resources, including solar (200 MWs), 

wind (700 MWs) and natural gas (200 MWs). Thus, the DEIS fails to examine how these new 

resources - which will help the growing City of Austin meet its power needs - will impact the 

need for STP. It should be noted that when the City of Austin and Austin Energy examined the 

option to contract for additional power from a proposed expansion of STP they specifically 

declined to do so, refusing to enter into contract with NRG and the other promoters of the 

project. Instead, they will reduce energy demand and look to natural gas and renewables to fill 

their energy needs. (0017-4 [Reed, Cyrus]) 

Comment: Other Utilities  Several electric cooperatives - who in theory might be interested in 

contracting for power from a new nuclear plant - have also adopted long-term goals to reduce 

energy demand. These include the State’s largest electric cooperatives, such as Bluebonnet 

and Pedernales. Again, the DEIS makes no attempt to incorporate these additional demand 

savings which would reduce the need for the proposed power plants. (0017-5 [Reed, Cyrus]) 

Response: Program-based energy savings in municipal utilities and coops are accounted for in 

two ways in the forecasts. First, the 2010 ERCOT forecast shows low growth in electricity 

demand based in part on the recent reduction in the historical trend of electricity demand per 

capita measured econometrically. This accounts both for success in past energy efficiency 

programs and the ongoing success of such programs in reducing the future trend in 

consumption. Second, in the review team’s sensitivity tests of the ERCOT forecasts, municipal 

utilities are assumed to save additional energy through new programs at the same rate as the 

investor-owned utilities regulated by PUCT under their new rule. There appears to be little or no 

quantitative information available on the plans of the electric cooperatives. In the sensitivity test 

of the 2010 ERCOT forecast in Chapter 8, they also were assumed to be as successful at 

cutting energy consumption as the public utilities regulated by the PUCT. The effects of the 

PUCT rule and energy efficiency programs are discussed in Chapter 8. The review team 

considers that the Austin plan’s emphasis on purchase of alternative renewable resources is 
Appendix E 

NUREG-1937 E- 82 February 2011 

included in the overall projection of RPS resources available for power generation in the 

ERCOT region, so it is not addressed separately in Chapter 8. 

Comment: HB 1937  During the 2009 Legislative Session, the Legislature passed and the 

Governor signed legislation that allows municipalities to begin loan programs for retrofits of 

existing buildings to make them more energy efficient and add onsite renewable energy devices 

to save and produce electricity. While no city has yet adopted a program under the terms of HB 

1937, several major cities - including El Paso, Austin and San Antonio - are seeking or have 

obtained funding to begin pilot programs aimed at reducing energy use. We expect that in 2011 

there will be an attempt to clarify some of the issues surrounding HB 1937 and that by 2012 

Texas will have a robust “Property Assessed Clean Energy” Financing Districts loaning out 

money to individual homeowners and businesses. This new program is not reflected in the 

DEIS, even though both Austin and San Antonio have received some $10 million apiece in 

ARRA funds to implement pilot programs. (0017-7 [Reed, Cyrus]) 

Response: Based on this comment, Property-Assessed Clean Energy (PACE) programs in 

Texas appear to be not yet settled in structure and are being implemented only at the pilot 

stage. Also, they address many of the end uses also addressed by building codes, ARRA, 

block grants and PUCT utility programs. Their potential effect on load growth is therefore highly 

speculative; therefore no changes were made to the EIS as a result of this comment. 

Comment: ARRA monies  There appears to be no attempt to consider the impact of the 

spending of some $1 billion on energy efficiency and solar programs in Texas as a result of 

ARRA monies. The majority of these monies will be implemented within the ERCOT market 

where South Texas is planning to sell its power. Thus, the $326 million being spent on lowincome weatherization - some 40,000 to 50,000 homes - is not considered, nor is the expansion 

of SECO’s LoneSTAR program for municipal buildings by some $150 million. Large cities in 

Texas also received hundreds of millions of dollars in direct and competitive Energy Efficiency 

and Conservation Block Grants. We would suggest that the DEIS obtain information from the 

State Energy Conservation Office, Texas Department of Housing and Community Affairs and 

the individual cities that obtained monies from the federal stimulus about how this will impact 

local demand. (0017-8 [Reed, Cyrus]) 

Response: Along with other recent programs, at least a portion of the energy efficiency 

programs funded under the ARRA is included implicitly in the 2010 ERCOT forecast because 

the 2009-2010 electricity demand is affected by the recent history of electricity demand savings. 

This recent history implicitly includes the past impact of ARRA as well as other recent subsidies 

for energy efficiency and successes in San Antonio and Austin are carried forward in the 

forecast. Similarly, the recent history of energy savings for all utilities is reflected in the 

historical data for 2009 used to estimate future demand relationships. Historically, ERCOT 

forecasts have shown rates of growth in peak demand of over 2 percent per year; the most 

recent forecast shows an average rate of closer to 1.5 percent for the period 2009-2020 before 
Appendix E 

February 2011 E-83 NUREG-1937 

special adjustments ERCOT made for program-related energy efficiency not otherwise 

accounted for. These adjustments further reduce the growth rate to about 1.4 percent. 

Based on discussions with ERCOT, the review team has learned that information documenting 

the actual energy savings of ARRA activities is difficult to obtain, but that ARRA and the other 

new programs so far have not shown any significant impact on the forecast. In the case of 

weatherization programs, some 40,000 to 50,000 units were weatherized, but this did not 

always result in overall electricity savings. In some cases, new equipment (e.g. air conditioning 

equipment) replaced equipment that was not operational, or was too expensive to operate. 

After replacement, the household benefitted from cooler indoor temperatures, but used more 

electricity because the customer actually ran the air conditioner. In other cases, it was 

necessary to repair the house in order to carry out the weatherization retrofit. For example, for 

increased insulation to be effective, in some cases it was necessary to fix or replace a leaking 

roof, greatly increasing the cost of the retrofit and improving the lives of the residents, but not 

saving much electricity. 

Regarding SECO’s LoanStar Program, the amount of funding is known, but no estimates of 

impact appear to be available. Regarding Energy Efficiency Block Grants, the amount of 

funding is known, but no estimates of impact appear to be available. 

No changes were made to the forecasts in Chapter 8 as a result of this comment. 

Comment: [W]e are deregulated market. We’re a merchant power producer. Our owners are 

a merchant power producer. If this plant is going to be built, it’s got to satisfy their economic 

model to show that it will make money. It’s got to satisfy their economic model, such that they 

can satisfy their investors. So, basically, it won’t start construction unless it passes that hurdle 

first, because they won’t finance it. (0004-2-37 [McBurnett, Mark]) 

Response: This general comment is about the requirement that the owners of a merchant 

nuclear plant have a business model that will allow it to be financed in the marketplace. If the 

marketplace participants do not have the assurance that the owners can sell the power at a 

profit, they will not finance the plant. The EIS makes the same point in Section 8.4; therefore no 

changes were made to the EIS as a result of this comment. 

E.2.23 Comments Concerning Alternatives – No-Action 

Comment: DEIS Section 09.01. No-Action Alternative. Page 9-2, Lines 17-18: The DEIS states 

that if the NRC denies the COL, the predicted environmental impacts would not occur. 

However, not all impacts from the construction and operation of STP 3 & 4 are negative and this 

also means that the positive impacts would not occur. Aside from the lost opportunity for 

additional electrical capacity, positive impacts that would be lost in the no-action alternative are 

not addressed in the DEIS. The Environmental Report (Rev. 3.0) describes the benefits such 
Appendix E 

NUREG-1937 E- 84 February 2011 

as additional jobs, additional revenue injected into the regional economy, and the increased 

electrical capacity generated which supports national and international goals to reduce the 

generation of greenhouse gases as outlined in the Energy Policy Act of 2005. 

(0010-2-55 [Head, Scott]) 

Response: Section 9.1 of the EIS was revised in response to this comment to include a 

reference to the benefits of the proposed project identified in Section 10.6.1. 

Comment: DEIS Section 09.01. No-Action Alternative. Page 9-2, Line 26: The DEIS does not 

address that the no-action alternative would cause ERCOT to be unable to maintain the 

minimum 12.5% target level of reserve margin necessary to mitigate uncertainties in load 

requirements. (0010-2-56 [Head, Scott]) 

Response: The review team believes that the first two paragraphs of Section 9.1 of the EIS 

adequately cover the concern expressed by the comment. No change to the EIS was made as 

a result of the comment. 

Comment: DEIS Section 09.01. No-Action Alternative. Page 9-2, Lines 29-35: The DEIS states 

that other generation sources would be pursued which would have environmental impacts as 

well and would meet the need for power. Although it is stated that this is discussed in later 

sections, this is not part of the No-Action Alternative and could be misleading. 

(0010-2-57 [Head, Scott]) 

Response: The review team believes that the existing text in Section 9.1 of the EIS is not 

misleading to the reader. No change to the EIS was made as a result of the comment. 

E.2.24 Comments Concerning Alternatives - Energy 

Comment: I don’t think the NRC has done an adequate job in looking at the efficiency 

potential, and the potential for renewables, combined heating and power, geothermal, the 

impact of what we call nodal transmission, or nodal dispatch, and demand side management. ... 

Industry studies indicate that energy efficiency, wind, coal with carbon sequestration are all 

lower cost than nuclear power. (0004-1-22 [Smith, Tom]) 

Response: The review team’s evaluation of alternative energy sources, including renewable 

sources, is in Section 9.2 of the EIS. The staff concluded in Section 9.2.3 of the EIS that energy 

alternatives other than coal and natural gas would not be reasonable alternatives to two new 

nuclear units that would provide baseload power. The review team concluded in Section 9.2.1 

of the EIS that demand-side management would not be a reasonable alternative to providing 

new baseload power generating capacity. The review team did not include an evaluation of coal 

with carbon sequestration because the technology is not yet mature enough to allow for 

anything other than a purely speculative evaluation. The staff concluded in Sections 9.2.5 and 
Appendix E 

February 2011 E-85 NUREG-1937 

10.5 of the EIS that none of the alternative energy options were both (1) consistent with 

STPNOC’s objective of building baseload generation units to meet the need for 2700 MW(e) of 

baseload power and (2) environmentally preferable to the proposed action. The cost of energy 

alternatives was not considered in the EIS because the two preceding conditions were not met. 

No change was made to the EIS as a result of this comment. 

Comment: You all know about cogen. There’s about another 15,000 megawatts of cogen out 

there that have never been plugged in that could be utilized. And there’s a great untapped 

resource called geothermal energy that’s underground. And anybody who has ever drilled for 

oil and gas knows one of your problems is you’ve got to deal with the hot stuff, the hot water, 

the hot brines that come out from underground. That can be turned into electricity and sold to 

the grid. ... Energy storage is right on the horizon. And we know how to do it, we’ve been doing 

it for over 50 years with compressed natural gas. We can do it with wind, and other kinds of 

renewable energies. ... we believe that the NRC needs to go back and take a good hard look at 

the basis of the assessment for ... alternatives. (0004-1-27 [Smith, Tom]) 

Response: The review team’s evaluation of alternative energy sources, including renewable 

sources, is in Section 9.2 of the EIS. The commenter mentioned cogeneration as an option that 

needed to be considered. (Cogeneration refers to the production of electricity and useful 

thermal energy simultaneously from a common fuel source.) Because the purpose and need for 

this proposed action is the generation of baseload electricity and cogeneration is for other 

purposes, it was not considered by the review team in the EIS. The review team concluded in 

Section 9.2.3 of the EIS that energy alternatives other than coal and natural gas would not be 

reasonable alternatives to two new nuclear units that would provide baseload power. The 

feasibility of energy storage is discussed in Section 9.2.3.2, and geothermal energy is discussed 

in Section 9.2.3.5. The review team concluded in Section 10.5 of the EIS that none of the 

alternative energy options were both (1) consistent with STPNOC’s objective of building 

baseload generation units and (2) environmentally preferable to the proposed action. No 

change to the EIS was made as a result of this comment. 

Comment: There is also a need for decentralized power generation as shown by the many 

alternatives available commercially for power generation, including solar cells, generators, 

windmills, and other so-called alternative energy sources. It is an object of the present invention 

to provide such an alternative electrical power source. (0007-7 [Fuson, David]) 

Comment: The DEIS describes STP 3 & 4 cumulative impacts on surface water and 

groundwater quality but fails to compare cumulative impacts to surface water quality from 

alternatives such as wind and solar. The failure to compare water quality impacts from 

alternatives including wind, solar, geothermal, etc. has the effect of distorting the relative 

advantages of nuclear power. (0015-5 [Johnson, Matthew]) 
Appendix E 

NUREG-1937 E- 86 February 2011 

Comment: Solar announcements - Much is made in the discussion of alternatives about the 

high cost, large land needs and water needs of utility-scale solar plants. The DEIS seems to 

suggest it is just not reasonable to talk about solar replacing the need for a nuclear plant. In fact, 

the main point seems to be that while Matagorda County is a great place to build an additional 

nuclear plant it would not be a good place to build a utility-scale solar plant. And we agree. But 

there is no reason that NRG could not build a solar plant somewhere else. Indeed, NRG has 

been looking at building solar plants, such as the 10 MW project for the City of Houston. While 

that agreement appears to have broken down, the fact remains that NRG does have the desire 

and capability to explore meeting Texas’s energy needs with utility scale solar power. Indeed, 

we now have three announced utility-scale solar plants announced in Texas, including Tesara in 

Presidio County, and the Austin Energy Webberville project. While these projects are relatively 

small - 30 or 14 MWs as opposed to 2,740 MWs - they point to the potential to replace a large 

project with several smaller-scale flexible projects throughout Texas. As mentioned, both Austin 

Energy and CPS Energy have made long term commitments to obtain hundreds of Megawatts 

of electricity from solar over the next 10 years. In addition to the utility-scale announcements, 

Texas; has begun to install onsite photovoltaic solar production. Thus, while still a tiny part of 

the market -perhaps 5 to 10 MWs currently - a series of announcements in San Antonio, Austin 

and especially the Oncor Service territory suggest that onsite solar will lead to further reduction 

in demand for power from the proposed plant. Thus, earlier this year, SolarCity, a California 

company, announced a partnership in the Oncor Service Territory. Under this partnership, 

SolarCity will build solar installations on homes in return for the ONCOR solar rebate and then 

charge homes only $35 per month. SolarCity is considering expanding their operations to other 

parts of the state, contingent upon the existence of solar rebates. AEP has begun a small solar 

rebate program as well. In the meantime, CPS Energy has announced a new feed-in tariff for 

larger commercial systems, while Austin Energy is currently reviewing its solar rebate and 

incentive program. The Sierra Club believes that while small in the short-term, these and similar 

programs could lead to large-scale deployment of solar PV in Texas, particularly if the 

Legislature takes action to get rid of some barriers. (0017-11 [Reed, Cyrus]) 

Comment: DEIS undercounts alternatives to nuclear plant ...  In fact, the Lone Star Chapter 

believes given its high cost, inflexibility and lengthy implementation schedule, Texas would be 

better served by developing smaller, more flexible, cheaper alternatives like on and off-site 

solar, additional natural gas plants, energy efficiency, coastal wind, energy storage and 

geothermal resources. (0017-14 [Reed, Cyrus]) 

Response: The review team’s evaluation of alternative energy sources, including renewable 

sources such as solar and wind, is in Section 9.2 of the EIS. The review team concluded in 

Section 9.2.3 of the EIS that energy alternatives other than coal and natural gas would not be 

reasonable alternatives to two new nuclear units that would provide baseload power, and these 

comments do not provide information that would change these conclusions. There is no need to 

compare the environmental impacts of the proposed action with alternatives that do not meet 
Appendix E 

February 2011 E-87 NUREG-1937 

the purpose and need of the action. The review team concluded in Sections 9.2.5 and 10.5 of 

the EIS that none of the alternative energy options were both (1) consistent with STPNOC’s 

objective of building baseload generation units to meet the need for 2700 MW(e) of baseload 

power and (2) environmentally preferable to the proposed action. No changes were made to 

the EIS as a result of these comments. 

Comment: DEIS Section 09.02. Energy Alternatives. Page 9-3, Lines 30-33: Consistent with 

the ER, NRC identified the Region of Interest (ROI) for the alternatives analysis as the ERCOT 

region (See page 9-3, lines 11-12), which represents about 85 percent of the electric load and 

75 percent of the land area in Texas. However, this paragraph implicitly considers the entire 

State of Texas as the ROI. The discussion in the ER is limited to the ERCOT region. Other 

locations that may need additional clarity on the Texas/ERCOT distinction are Page 9-6, Lines 

19-24, Page 9-20, Lines 32-34, Page 9-22, Lines 18-20, Page 9-23, Lines 12-14, Page 9-24, 

Lines 6-11. (0010-2-58 [Head, Scott]) 

Response: Section 9.2.2 of the EIS was changed to reflect the energy mix within ERCOT. No 

other changes to the EIS were made as a result of this comment. 

Comment: DEIS Section 09.02. Energy Alternatives. Page 9-6, Lines 15-18: The DEIS states 

“Consistent with NRC’s evaluation of alternatives to operating license renewal for nuclear power 

plants, a reasonable set of energy alternatives ... should be limited to analysis of discrete power 

generation sources, a combination of sources, and those power generation technologies that 

are technically reasonable and commercially viable (NRC 1996).” This statement is incorrect. 

Combinations of power generation technologies were specifically excluded from NRC’s 

evaluation of alternatives to operating license renewal for nuclear power plants (NRC 1996). 

Section 8.1 of NRC 1996 states “While many methods are available for generating electricity, 

and a huge number of combinations or mixes can be assimilated to meet a defined generating 

requirement, such expansive consideration would be too unwieldy to perform given the 

purposes of this analysis. Therefore, NRC has determined that a reasonable set of alternatives 

should be limited to analysis of single, discrete electric generation sources and only electric 

generation sources that are technically feasible and commercially viable.” 

(0010-2-59 [Head, Scott]) 

Response: NRC’s supplemental EISs for license renewal do include an analysis of a 

combination of energy alternatives. In response to this comment, the citation to “NRC 1996” 

was removed from the first paragraph of Section 9.2.2 of the EIS. 

Comment: DEIS Section 09.02. Energy Alternatives. Page 9-12, Lines 4-8: The DEIS states 

“STPNOC would pay significant property taxes for the plant to Matagorda County, the 

Matagorda County Hospital District, Navigation District #1, Drainage District #3, the Palacios 

Seawall District, and the Palacios Independent School District (STPNOC 2009a). The review 

team estimates that the taxes would have a LARGE beneficial impact to the tax recipients.” The 
Appendix E 

NUREG-1937 E- 88 February 2011 

reference to the ER is incorrect. While the beneficial impacts from taxes on STP Units 3 & 4 are 

addressed in the ER, the ER does not address the potential impacts from taxes for the coal-fired 

alternative. Also, STPNOC is the operator of the nuclear facilities at the STP site and would not 

own any plant that is constructed at the site. The owners of the coal-fired plant would pay the 

property taxes. (0010-2-60 [Head, Scott]) 

Response: Based on this comment, the reference to the ER in Section 9.2.2.1 of the EIS was 

deleted. In addition, the EIS was changed to indicate that the owners would pay the property 

tax. 

Comment: DEIS Section 09.02. Energy Alternatives. Page 9-17, Lines 28-38 and Page 9-18, 

Lines 1-4: The DEIS states “The plant owner would pay significant property taxes for the plant to 

Matagorda County, the Matagorda County Hospital District, Navigation District #1, Drainage 

District #3, the Palacios Seawall District, and the Palacios Independent School District 

(STPNOC 2009a) and would employ a noticeable but not significant number of workers, 

especially during the building period. Based on the expected valuation of a natural gas plant, 

which would be significantly less than for nuclear or coal, the property taxes would be lower for 

the natural gas option. Considering the population and economic condition of the County, the 

review team concludes that the taxes and employment would have a MODERATE beneficial 

impact on the County.” The reference to the ER is incorrect. While the beneficial impacts from 

taxes on STP Units 3 & 4 are addressed in the ER, the ER does not provide an assessment of 

the potential impacts from taxes for the gas-fired alternative. Also, the ER (Section 9.2.3.2.3) 

concluded that impacts from employment would be SMALL due to the influence of the nearby 

metropolitan area. (0010-2-61 [Head, Scott]) 

Response: Based on this comment, the reference to the ER in Section 9.2.2.2 of the EIS was 

deleted. The MODERATE beneficial socioeconomic impact characterization in the EIS is based 

on the tax and employment impact of a hypothetical alternative natural gas-fired plant. 

Comment: DEIS Section 09.02. Energy Alternatives. Page 9-24, Lines 15-16: The DEIS states 

“Geothermal systems have a relatively small footprint.” The ER (Section 9.2.2.3.4) indicates 

that a geothermal power plant requires between 1 and 8 acres per MWe, and estimates that a 

2700 MWe geothermal plant with a 93% capacity factor would require between 2900 acres and 

23,200 acres. (0010-2-62 [Head, Scott]) 

Response: Section 1.8 of the report published by the Massachusetts Institute of Technology 

(MIT 2006) cited in the EIS states that “... a geothermal energy source is contained 

underground, and the surface energy conversion equipment is relatively compact, making the 

overall footprint of the entire system small.” No changes were made to the EIS as a result of 

this comment. 
Appendix E 

February 2011 E-89 NUREG-1937 

Comment: DEIS Section 09.02. Energy Alternatives. Page 9-27, Lines 27-28: The DEIS states 

“The demand-side management programs would be implemented by CPS Energy and/or 

Reliant Energy, a subsidiary of NRG Energy.” This statement contradicts the information 

provided on DEIS page 9-5, lines 9-12 which states “NRG Energy ... is a wholesale power 

generation company ... it does not directly offer demand-side management or conservation 

programs.” (0010-2-63 [Head, Scott]) 

Response: The review team considers the text as written in Section 9.2.4 to be accurate. 

NRG Energy doesn’t directly offer demand side management programs, as stated in the EIS. 

However, the review team assumes that Reliant Energy, a subsidiary of NRG Energy, will 

continue to offer demand side management programs.

Comment: Energy Storage announcements  In the last several years, several large 

companies - such as Luminant, Shell and Chevron have announced plans to invest in largescale energy storage technology in Texas. Those announcements are not incorporated or 

analyzed in the DEIS. (0017-10 [Reed, Cyrus]) 

Response: The feasibility of energy storage is discussed in Section 9.2.3.2 of the EIS. The 

review team’s evaluation is based on current experience with energy storage and not on the 

speculation of possible future projects that might or might not come to fruition. This comment 

provides no new specific information that would merit a change to Section 9.2.3.2; therefore, no 

change was made to the EIS. 

Comment: This DEIS conclusion mistakenly assumes that alternatives such as wind, solar and 

geothermal (or combinations thereof) are not viable baseload alternatives. This conclusion is 

contradicted by, inter alia, the recent announcement of ConocoPhillips and General 

Compression of a CAES facility planned for Texas that would be suitable for baseload 

generation. The announcement of this project coupled with the National Renewable Energy 

Laboratory’s conclusion that wind generation combined with CAES is a viable baseload source 

makes exclusion of this alternative in the DEIS unreasonable. Additionally, the DEIS omits any 

discussion of combinations of wind and solar power to provide baseload generation. 

(0015-7 [Johnson, Matthew]) 

Response: The feasibility of energy storage is discussed in Section 9.2.3.2 of the EIS. Section 

9.2.3.2 points out that only two CAES plants are currently in operation and that nothing 

approaching the scale of a 2700 MW(e) facility has been proposed. Whether a plant this size 

could be constructed and operated in the ERCOT region is speculative. Wind and solar power 

would both require energy storage to serve as a baseload power source as discussed in 

Sections 9.2.3.2 and 9.2.3.3. No changes were made to the EIS as a result of this comment. 
Appendix E 

NUREG-1937 E- 90 February 2011 

E.2.25 Comments Concerning Benefit-Cost Balance 

Comment: [This] may end being an economic albatross, both through having to pay out on the 

loan guarantees, but with you having a plant that’s never completed (0004-1-21 [Smith, Tom]) 

Comment: I’m also concerned about ... financial burden of nuclear energy, generally speaking, 

on the tax payer as far as loan guarantees. (0004-2-11 [Dancer, Susan]) 

Response: These comments express a concern that Units 3 and 4 will not be completed once 

begun, leaving the U.S. taxpayer with an obligation to pay for the plants’ Federal loan 

guarantees, without a corresponding benefit of electricity generated. The cost of the loan 

guarantees only would be borne if the owners default on the loans that they take out to build the 

plant. From a national benefit-cost perspective, the cost of Units 3 and 4 would be roughly the 

same whether the taxpayers or ratepayers provide the financing; the difference would be that 

power generation benefits would not occur if Units 3 and 4 were not finished. The NRC is not 

involved in establishing national energy policy, and issues related to the guaranteeing of loans 

to nuclear power are outside the scope of the NRC’s mission and authority. No changes were 

made to the EIS as a result of these comments. 

Comment: [A] study we had a consultant do last April by a former expert for the Office of 

Public Utility Council in Texas, came to the same conclusion. But what he showed in his study, 

which I think is important, is that it’s 20 years before this plant starts to make a profit. And, at 

some point, the investor community is going to get wise to this, and say why would we invest in 

a plant like this, if there are a bunch of cheaper ways to end up making money, and to 

generating electricity? ... If load guarantees are granted, if this plant is started, somewhere 

along the line the market is going to do what markets do, and say this power is too expensive to 

use, and this plant will never be completed. (0004-1-24 [Smith, Tom]) 

Response: Whether STP Units 3 and 4 make a profit for their owners is outside the scope of 

authority and responsibility of either NRC or the Corps . No changes were made to the EIS as a 

result of this comment. 

Comment: The STP proposed reactors are incredibly expensive. They could be as much as 

$22 billion, according to one study. Federal loan guarantees, if granted, and if there were to be 

a default, would cost billions of dollars, and all U.S. tax payers would be left with that bill. 

(0004-1-36 [Hadden, Karen]) 

Response: There are a number of studies estimating the cost of new nuclear plants including 

STP Units 3 and 4. The study cited by the commenter includes projected escalation of costs 

and includes financing costs. The capital costs reported in Chapter 10 are overnight or cashequivalent costs of building the plant, based on publicly available studies. They are the true 

national resource costs of building Units 3 and 4 and ignore the economic transfers associated 
Appendix E 

February 2011 E-91 NUREG-1937 

with financing the facilities. There is as yet no publicly-available specific cost estimate for STP 

Units 3 and 4. No changes were made to the EIS as a result of this comment. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-21, Table 10-4: The DEIS 

states that 300 acres will be occupied on a long term basis for the 2 new reactors and 

associated infrastructure (which is the acreage for the existing STP Units 1 & 2). The 

Environmental Report (Rev. 3.0) states that 90 acres will be occupied on long term basis for the 

2 new reactors and infrastructure (Sections 4.3, 5.10, and 10.1). (0010-2-79 [Head, Scott]) 

Response: Table 10-4 of the EIS was corrected to show that 90 ac will be occupied on a longterm basis rather than 300 ac. 

Comment: One last item I’d like to talk about is cost. Nuclear power plants are very large 

capital investments, no denying that. They’re also long-term investments. This plant will run for 

upwards of 60 plus years generating reliable power. It’s a long-term investment. ... It’s true the 

new units are going to be expensive. (0004-2-3 [McBurnett, Mark]) 

Response: The comment qualitatively addresses the cost of nuclear power plants, but does 

not provide any specific information about cost. The license period for a combined license is 

40 years. A licensee can request renewal for an additional 20 years. The cost-benefit analysis 

is done for the license period of 40 years. It would not be appropriate to assume additional cost 

or benefit for an additional 20 years of operation under a renewed license when that action has 

not been requested or approved. No changes were made to the EIS as a result of this 

comment. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-27, Lines 5-6: The DEIS states 

that “Table 10-3 includes a summary of both internal and external costs of the proposed 

activities at the STP site for Units 3 and 4, as well as the identified benefits”. This sentence is 

incorrect. Table 10-3 only includes a summary of the benefits of the project. Table 10-4 

includes a summary of the costs. (0010-2-84 [Head, Scott]) 

Response: The EIS has been corrected to state that Table 10-3 summarizes benefits while 

Table 10-4 summarizes costs. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-21, Table 10-4: The DEIS 

states in the table under “Land Use” that the already utilized plant site is approximately 12,200 

acres. The Environmental Report (Rev. 3.0), as does other sections of the DEIS, states that the 

STP site is approximately 12,220 acres. Additionally, the wording “already utilized plant site” 

could be misleading that all 12,220 acres is being used for plant operations. Section 2.2.1.1 of 

the ER states that “The 12,220-acre STP site includes land developed for industrial use, 

farmland, and undeveloped natural and man-made wetlands. The existing plant and plant 

facilities, including the NTF, operations area, support facilities, and transmission right-of-ways 
Appendix E 

NUREG-1937 E- 92 February 2011 

occupy approximately 65 acres, while the MCR makes up an additional 7000 acres. Another 

approximate 1700 acres remain as natural lowland habitat. The remaining portion of the STP 

site is undeveloped land, some of which, located to the east of the MCR, is leased for cattle 

grazing”. (0010-2-82 [Head, Scott]) 

Response: The reference to “already-utilized” land was removed from Table 10-4 of the EIS. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-21, Table 10-4: The DEIS 

does not list land use for fuel cycle support. The Environmental Report (Rev. 3.0) states that the 

total annual land requirements for fuel cycle support committed would be 21 permanently 

committed acres and 160 temporarily committed acres per unit (Table 10.4-2). (0010-2-80

[Head, Scott]) 

Response: Table 10-4 of the EIS has been updated to include land committed to fuel cycle 

support. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-19, Line 19-31: The DEIS 

gives an estimated ERCOT fuel mix from a 2008 source. The citation is incorrect for this 

information. The call-out is dated 2006, the document is dated 2008, and the ADAMS 

accession number is for a 2007 document. Additionally, this does not agree with Chapter 9 of 

the DEIS, which addresses the fuel mix for the entire State of Texas instead of the ERCOT 

region of interest. The Environmental Report (Rev. 3.0) cites a fuel mix from actual ERCOT 

energy production values from June 2005 to May 2006 (Section 10.4.1.2). 

(0010-2-77 [Head, Scott]) 

Response: The value for ERCOT’s 2007 energy mix is a figure on page 20 of the cited 

reference (ERCOT 2008). The summer capacity fuel mix is the 2009 estimated available 

summer capacity from page 13 of the May 2009 cited report (ERCOT 2009). The 2006 callout 

is for the national mix, not ERCOT. ERCOT data should not necessarily be the same as that for 

Texas. However, Sections 9.2.2 and 10.6.1 of the EIS were revised to use 2008 annual energy 

production data. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-21, Table 10-4: The DEIS 

does not list hydrology as a cost category. The Environmental Report (Rev. 3.0) includes both 

groundwater and surface water in the benefit-cost summary table (Table 10.4-2). (0010-2-81

[Head, Scott]) 

Response: Table 10-4 of the EIS was revised to include information about groundwater and 

surface water use. 

Comment: DEIS Section 10.06. Benefit-Cost Balance. Page 10-20, Lines 23-26: The DEIS 

states that operations would yield 656 additional operations workforce and 964 additional 
Appendix E 

February 2011 E-93 NUREG-1937 

indirect jobs within 50-mile radius. The Environmental Report (Rev. 3.0) states that operations 

would yield 444 additional operations workforce and 653 additional indirect jobs within 50 mile 

radius (Section 5.8.2.1 and 10.4.1.7). (0010-2-78 [Head, Scott]) 

Response: The 444 workers cited in the comment are STPNOC’s number of new workers who 

would move to the 50-mi region, not the number of operations jobs at Units 3 and 4 (estimated 

by STPNOC as 888 jobs in Section 5.8.2.1 of the ER, but as 959 jobs in Table 3.10.S-3, which 

was the figure the review team used). The review team also accounted for a net decrease in 

employment at the existing STP Units 1 and 2, yielding a net increase of operations jobs at the 

STP site of 656 jobs. The 964 additional indirect jobs came from applying the same operations 

job multiplier of 1.47 as used in the ER to the 656 net jobs increase. No changes were made to 

the EIS as a result of this comment. 

E.2.26 General Comments in Support of the Licensing Action 

Comment: I want to thank you all again for giving me the opportunity to speak tonight in 

support, you know, of Units 3 and 4 at STP. ... And we look forward to you being back soon to 

continue this expansion. (0003-12 [Humphries, Jim]) 

Comment: Titan Hotels Group and Hampton Inn and Suites have chosen to put their roots 

down in Bay City, and, therefore, we are here to support STP and we ask that you do the same. 

(0003-13 [Roberts, Kaley]) 

Comment: I am excited to speak here today in support of the expansion of Units 3 and 4. 

(0003-14 [Yeamans, Joe]) 

Comment: [I] hope for that expansion at STP, so I can continue to offer services there. 

(0003-17 [Green, Julie]) 

Comment: So as both a union member and a union officer, I would just like to express my 

support for this expansion project. (0003-19 [Griffin, Mark]) 

Comment: I challenge anyone to find anything environmentally sensitive about what we are 

doing here. This is truly a wonderful outfit to do business with. Coupling it with NRC’s expertise 

and guiding hand, this truly is something that we can move America and Texas forward with, 

and certainly Matagorda County, if and when this new Units 3 and 4 build occurs. 

(0003-2 [McDonald, Nate]) 

Comment: I would like to tell the NRC that we love our power plant. ... and we want Units 3 

and 4. (0003-21 [Head, Bobby]) 
Appendix E 

NUREG-1937 E- 94 February 2011 

Comment: I am excited that we are going to build Units 3 and 4. I think it is a great thing. ... 

So my only comment to the NRC would be, hey, hurry up and approve this thing, and let’s get 

this thing built. (0003-22 [Grebe, Lynn]) 

Comment: I am speaking today in support of the expansion of STP to include two new units, 

Reactors Number 3 and 4. (0003-24 [Hutto, Veronica]) 

Comment: I am very excited about STP’s expansion with Units 3 and 4, and I am highly 

confident that the new advanced boiling water reactors will be a huge success, complementing 

Units 1 and 2 well into the future. (0003-26 [Chavez, Chance]) 

Comment: I strongly support STP’s request to get their operating licenses, and I would 

recommend that NRC should help them with it. (0003-32 [Kumar, Vatsu]) 

Comment: So I don’t know why it took so long for the good news to get out about Units 1 and 

2, so that we are finally building 3 and 4. It’s going to happen, you know that. ... and I’ll just be 

glad when it’s up and running. (0003-36 [Mann, Billy]) 

Comment: Two years ago I stood at this podium and I said, PIMBY -- for those of you who 

have forgotten what PIMBY is, let me remind you. It is Please In My Backyard. 

(0003-4 [Knapik, Richard]) 

Comment: We are hopefully on the crux of greatness here in many aspects -- one, becoming a 

mini power-generating mecca of South Texas, doing it in a relationship with STP. 

(0003-6 [Marceaux, Brent]) 

Comment: [T]he reason we can fill this room up tonight at 7:00 with hardworking people with 

families to look after, when we can fill this room up this afternoon, is because we as a 

community know what [Units] 3 and 4 means. (0003-9 [Thames, Mitch]) 

Comment: I am writing in support of the South Texas Project Units 3 and 4 Combined License 

application. This project will provide much needed energy, generation capacity in the area, and 

will have a significant positive impact for economic development in Matagorda County 

(0004-1-1 [Paul, Ron]) 

Comment: I strongly urge the NRC to grant the license. (0004-1-11 [Knapik, Richard]) 

Comment: This project, 3 and 4, will not only help the State of Texas with power needs, it’ll 

help this community, as well. (0004-1-14 [Thames, Mitch]) 

Comment: The Matagorda County Economic Development Corporation submits this letter in 

support of the findings of the Draft Environmental Impact Statement, that there are no significant 

environmental reasons for denying the construction, and operating license for Units 3 and 4. 
Appendix E 

February 2011 E-95 NUREG-1937 

...on behalf of the Matagorda County Economic Development Corporation, and the City of 

Palacios Economic Development Corporation, we urge approval of the Draft EIS into a Final 

EIS, and quickly proceed to issue the operating license in early 2012 with the construction of 

Units 3 and 4. (0004-1-19 [Bludau, Owen]) 

Comment: [A]s the Texas State Senator whose district includes Matagorda County, and the 

South Texas Project, I am pleased to endorse the proposed expansion of the facility. 

(0004-1-2 [Hegar, Glenn]) 

Comment: We’re the local sponsor for the federal project, which is Colorado River Navigation 

Channel. We’ve been affiliated with the nuclear plant in some of their activities, and they’ve 

been a great partner. And the Port fully supports the expansion of Units 3 and 4. 

(0004-1-29 [Griffith, Mike]) 

Comment: Matagorda Regional Medical Center Board of Managers supports the expansion of 

South Texas Project’s proposed Units 3 and 4. ... The Matagorda Regional Medical Center 

Board of Managers supports STP’s expansion. The new units will benefit not only our local 

communities, but our entire state for decades to come. (0004-1-43 [Smith, Steve]) 

Comment: Titan Hotels Group and Hampton Inn & Suites have chosen to put roots down in 

Bay City, and, therefore, we’re here to show our support for STP, and we ask that you do the 

same. (0004-1-47 [Roberts, Kaley]) 

Comment: As both a union member, and a union officer, I would just like to express my 

support for this expansion project. (0004-1-48 [Griffin, Mark]) 

Comment: I want to go on record as being in support of this project, and to reiterate that 

Matagorda County has a quality of life that’s more than a slogan, it’s an experience worth living. 

(0004-1-8 [Weber, Randy]) 

Comment: [P]lease accept this as my endorsement of Units 3 and 4, and my endorsement of 

the Draft Environmental Impact Statement that we’re hearing today. 

(0004-1-9 [McDonald, Nate]) 

Comment: [W]e urge for the certificate to be granted. (0004-2-14 [Holt, Ben]) 

Comment: I do want to support the implementation of the [STP] expansion. 

(0004-2-15 [Croft, Roy]) 

Comment: I am very excited about STP’s expansion of 3 and 4, and I am highly confident that 

the new advanced boiling water reactors will be a huge success, complementing Units 1 and 2 

well into the future. (0004-2-22 [Chavez, Chance]) 
Appendix E 

NUREG-1937 E- 96 February 2011 

Comment: I am speaking today in support of the expansion of STP to include two new 

reactors, Units 3 and 4. (0004-2-27 [Hutto, Veronica]) 

Comment: I am excited to speak here today in support of expansion of Units 3 and 4. 

(0004-2-30 [Yeamans, Joe]) 

Comment: I want to support -- please, hurry this up, and let’s get some people working. 

(0004-2-33 [Lucero, Greg]) 

Comment: I fully support the expansion of the project. (0004-2-35 [Arnold, James]) 

Comment: I think it [building of STP 3 and 4] is a great thing for Matagorda, and I look forward 

to you all getting started. (0004-2-36 [Bradish, Michael]) 

Comment: I very strongly recommend to NRC that they should have no hesitation to approve 

and issue a license, operating license to STP, and STP will do a fine job. 

(0004-2-6 [Kumar, Vatsu]) 

Comment: I am proud that STP, located in Matagorda County, will be providing a greater 

amount of electric energy needed to support the needs of families and businesses throughout 

our great State of Texas! (0005-4 [Purvis, Gail]) 

Comment: I am writing in support of the South Texas Project Units 3 and 4 Combined License 

Application. This project will provide much needed energy generation capacity in the area and 

will have a significant positive impact for economic development in Matagorda County. 

(0007-1 [Paul, Ron]) 

Comment: I strongly urge NRC to issue the Construction and Operating Licenses to STP. 

(0007-4 [Kumar, Vatsu]) 

Comment: The Matagorda County Economic Development Corporation (MCEDC) fully 

supports the granting of a Combined Operating License for STP Units 3 and 4. ...The 

Matagorda County Economic Development Corporation submits this letter in support of the 

findings of the STP Draft Environmental Impact Statement that there are no significant 

environmental reasons for denying a Construction and Operating License for STP Units 3 and 4. 

... The Matagorda County Economic Development Corporation urges the NRC to approve the 

Draft EIS and to proceed with the remainder of the review process in order to issue the 

Construction and Operating License in early 2012 for Units 3 and 4 to begin construction. 

(0007-5 [McDonald, Nate]) 

Comment: The City of Palacios Economic Development Corporation wishes to go on record as 

supporting the findings of the STP Draft Environmental Impact Statement that there will be no 
Appendix E 

February 2011 E-97 NUREG-1937 

significant environmental reasons for denying a construction and operations permit for STP 

Units 3 and 4. ... The City of Palacios Economic Development Corporation urges the NRC to 

approve the Draft EIS and to proceed with the remainder of the review process in order to issue 

the construction and operating license in early 2012 for Units 3 and 4 to begin construction. 

(0007-6 [Johnson, Ken]) 

Comment: The Matagorda Regional Medical Center Board of Managers supports the 

expansion of the South Texas Project’s proposed Units 3 & 4. ... The Matagorda Regional 

Medical Center Board of Managers supports STP’s expansion. The new units will benefit not 

only our local communities but our entire state for decades to come. (0012-1 [Scurlock, Betty]) 

Response: These comments provide general support of STPNOC’s application for COLs. The 

comments do not provide any new information that would require changes to the EIS. 

E.2.27 General Comments in Support of the Licensing Process 

Comment: I also appreciate that the NRC here tonight has two sessions, one for those that are 

not able to be here earlier today. (0003-23 [Corder, John]) 

Comment: [W]e have the freedom of speech, and I am exercising that tonight, and I appreciate 

it. (0004-2-13 [Corder, John]) 

Response: These comments express general support for the NRC COL process. No changes 

were made to the EIS as a result of these comments. 

E.2.28 General Comments in Support of Nuclear Power 

Comment: You have experienced nuclear power for the last 30 years. Let that experience 

speak for itself. (0003-10 [Halpin, Ed]) 

Comment: [W]e are able to produce electricity without polluting the air and producing 

greenhouse gases, which would damage the atmosphere and cause harm to plants and 

animals. We are an ecofriendly plant and offset the equivalent of 35 million barrels or oil and 

nine million tons of coal each and every year. (0003-27 [Chavez, Chance]) 

Comment: With nuclear power on the rise, the NRC overseeing reactor safety, and with 

nuclear plants producing energy without pollution, it is apparent that nuclear power is a clear-cut 

choice in producing electricity. (0003-29 [Chavez, Chance]) 

Comment: Why nuclear energy, when people are looking at coal, natural gas, geothermal, 

wind, so many things? Because there is a wonderful technology available for plant design, the 

most recent and the most advanced plant design in this industry. Large amount of power that 

can be produced economically and reliably from one location -- at one location. It is a clean 
Appendix E 

NUREG-1937 E- 98 February 2011 

environment. There is no fly ash, no sulphur dioxide emission, no sludge to be removed, and 

no need to store an enormous quantity of raw materials and fuels. No raw materials -- know 

that raw materials also need to be handled in or outside of the facilities. 

(0003-30 [Kumar, Vatsu]) 

Comment: [W]e think nuclear is very good for all of us, for the environment, avoiding across 

the United States some 700 tons per year of carbon dioxide going into the environment 

(0004-1-16 [Halpin, Ed]) 

Comment: We need the energy to happen. It should happen through nuclear. Nuclear is safe 

and clean. (0004-1-18 [Halpin, Ed]) 

Comment: [N]uclear energy must play a larger role in our state’s energy future. Nuclear 

energy has the lowest fuel and production costs of all major power sources together, averaging 

less than 2 cents per kilowatt hour. It also is the most reliable source, because nuclear power 

plants operate around the clock, and throughout the year. Nuclear energy is also carbon-free, 

and produces no greenhouse gases. Increased nuclear generation will help secure our state’s 

energy future. It will also stabilize our energy costs, produce a cleaner environment, and reduce 

our dependence on fossil fuels. (0004-1-4 [Hegar, Glenn]) 

Comment: We believe nuclear energy must play a larger role in our state’s long-term energy 

future. There is a growing recognition of nuclear energy’s environmental benefits, and its role in 

providing much needed generating capacity in Texas for the decades ahead. 

(0004-1-46 [Smith, Steve]) 

Comment: With STP being a nuclear power plant, we are able to produce electricity without 

polluting the air or producing greenhouse gases, which damage the atmosphere and cause 

harm to plants and animals. We are an ecofriendly plant and offset the equivalent of 35 million 

barrels of oil or nine million tons of coal each and every year. (0004-2-23 [Chavez, Chance]) 

Comment: With nuclear power on the rise, the NRC overseeing nuclear reactor safety, and 

with nuclear plants producing energy without air pollution, it is apparent that nuclear power is a 

clear-cut choice in producing electricity. (0004-2-26 [Chavez, Chance]) 

Comment: [W]hy nuclear energy? ... The answer to this question, first of all, nuclear energy, 

availability of advanced technology in the area of plant design that’s provided by nuclear energy 

industry. Large amount of power that is reliable, economical, that will be available for a long 

period of time, like 60 years or longer with the same facility. Clean environment, not fly ash, no 

sulfur dioxide emission, no sludge removal, no need to store enormous quantities of raw fuel, 

either carting them in, or carting them out, no raw materials, no unnecessary raw materials 

needed on the site. The nuclear industry has continuously done engineering, monitors the plant 
Appendix E 

February 2011 E-99 NUREG-1937 

performances, looks for ways and means of continuously improving the plant efficiency. 

(0004-2-4 [Kumar, Vatsu]) 

Comment: As the Director of The Trull Foundation, I am a member of the Texas Environmental 

Grantmakers Group. I have learned to appreciate the clean, energy producing aspects of 

nuclear power. Again, I am proud that Matagorda County has STP as a neighbor, producing 

clean energy. Energy produced in a way that is not a threat to the County’s precious assets of 

water, air, bay critters, birds in flight and citizens of our County. (0005-3 [Purvis, Gail]) 

Comment: 1. Availability of advanced technology in the areas of plant design. 2. Large 

amount of power that is reliable and economical. 3. Clean environment, no fly ash, no sulphur 

dioxide emission, no sludge removal, no need to store enormous quantities of fuel. 4. No raw 

materials to be handled to or from the site in large volumes. (0007-3 [Kumar, Vatsu]) 

Comment: We believe nuclear energy must play a larger role in our state’s long-term energy 

future. There is a growing recognition of nuclear energy’s environmental benefits and its role in 

providing much needed generating capacity in Texas for the decades ahead. (0012-4 [Scurlock, 

Betty]) 

Response: These comments provide general support of nuclear power. No changes were 

made to the EIS as a result of these comments. 

E.2.29 General Comments in Support of the Existing Plant 

Comment: [I]ts heartening for me, and quite gratifying, to be able to witness firsthand the 

commitment to the culture of excellence that has been promulgated and brought forth out at 

STP. It permeates everything we do at the STP here in Matagorda County. It permeates their 

operations, it permeates their maintenance, it permeates their emergency management, and it 

certainly permeates their commitment to the environment. (0003-1 [McDonald, Nate]) 

Comment: [E]ven more important, is the relationship that we have with the community. It is 

one that has been forged over the last 30 years like a piece of steel. It is a relationship, a 

partnership, a friendship, and people are envious of that relationship, which is why it’s great to 

build at STP. (0003-11 [Halpin, Ed]) 

Comment: In my opinion, STP and the Center for Energy Development is the best thing that 

has ever happened to Matagorda County. ... in all my life I have never experienced anything 

that meets or exceeds the culture of STP. Their strong commitment to safety and exemplary 

work ethics are a model for any industry. (0003-15 [Yeamans, Joe]) 

Comment: [O]n the north side of the plant, along FM-521, many years ago a lot of migrating 

birds would stay there for the winter. And a lot of birders in the area -- and not only our area, 
Appendix E 

NUREG-1937 E- 100 February 2011 

but from all over, came to, you know, watch the birds. Well, this became a problem, because it 

was a traffic hazard. It was along FM-521, a small, narrow, two-lane road. STP, without any 

prodding, but because they are a great corporate citizen and are partners in our community, 

took it upon themselves to add a parking area and a viewing area to enable the safety of the 

birders, so they can watch in enjoyment all the birds that came there during the winter. I mean, 

if that’s the kind of corporate citizens they are, I will take 800 more of them any day, any time. I 

mean, they are great to live with here. (0003-3 [Knapik, Richard]) 

Comment: Now, specifically about STP, engineering continuously monitors the plant 

performance, looking for ways and means to continuously improve the plant efficiency. Cost of 

generation has gone down continuously for over a decade, due to improved plant performance, 

training of personnel, and the positive attitude that exists at STP. (0003-31 [Kumar, Vatsu]) 

Comment: Would we have that hospital that we have right now without a nuclear plant? Would 

we have the emergency response that we have, teams? How about our high school over here? 

I’m proud of our new high school. Would we have that? They encourage their employees to be 

active in the community, and they are. They get involved in different clubs. ... But they are very 

supportive. They work in the community, and that’s good, because that’s what it’s all about. 

(0003-33 [Mann, Billy]) 

Comment: [N]o other city can be more proud of the way they [STP] operate, the way they 

respond to the necessities of charitable institutions, the unending door open and access to all of 

their staff, all of their directors. It is a rare and wonderful thing to have in our community. 

(0003-7 [Marceaux, Brent]) 

Comment: Thanks to STP’s leadership, and corporate citizenry, they built a road, and a 

parking lot that allowed citizens and bird watchers to pull in there and safely observe the birds 

during the winter months. That, to me, is corporate citizenship above and beyond the call of 

duty. (0004-1-10 [Knapik, Richard]) 

Comment: As a City Council person, we want STP as a partner. We love STP as a partner. 

(0004-1-13 [Thames, Carolyn]) 

Comment: For 20 years, STP’s existing units have provided safe, clean, reliable energy to 2 

million Texas homes. The facility is a recognized industry leader in production, reliability, and 

safety. Earlier this year, STP surpassed 10 million man hours, nearly three years, without a loss 

time or restricted duty injury. The facility is focused and committed to the safety of its 

employees, and the surrounding communities. (0004-1-45 [Smith, Steve]) 

Comment: STP, in my opinion, epitomizes that focus, and that commitment to quality of life. 

STP, in my estimation, is a good corporate citizen. (0004-1-6 [Weber, Randy]) 
Appendix E 

February 2011 E-101 NUREG-1937 

Comment: I believe that STP has been a great steward. I’ve enjoyed all my relationships with 

them. I’ve been in the plant. I like the way they do their business. I think it’s a very safe facility, 

and I’m here in support. (0004-2-17 [O’Day, Mike]) 

Comment: I can just tell you as a child, and as a young adult, and as an older adult, always 

appreciated everything that the plant has done for the community, wonderful stewards of the 

community of all the events, of the environment. So, I appreciate that very much as a young 

person, and as an older person, but especially as a parent now. I have three children of my 

own, and just the support, not only in what they do for the environment, but also for the 

educational system, and how they support those programs. (0004-2-18 [Segovia, Valerie]) 

Comment: They [STP employees] come into our schools, and they teach skills. They’ve got a 

welding program going in ACIC giving our students some much needed real job, real life skills 

that they will be able to get jobs with. They do a lot of environmental awareness programs in our 

schools. ... they are very, very generous to our school district, ... And I really appreciate that. 

(0004-2-19 [Silva, Allison]) 

Comment: Several years ago, about 30, I was Mayor of Bay City. ... And as Mayor, I 

represented the City of Bay City, the City Council, and the majority of the citizens. We gave our 

full support to the permitting, construction, and operation at STP. And I certainly haven’t 

changed my mind, as a citizen, for that. (0004-2-21 [Opella, Ernest]) 

Comment: STP has done an excellent job of performing the tasks that they have when they 

moved into town. They provide a valuable product to this region of the country. They provide 

employment opportunities for people, and they do it in a very, very good and neighborly way. 

They support all county and civic organizations tenfold. They go way beyond the call of duty, 

and they do their business in a safety manner. And because of that, I am for them. 

(0004-2-29 [Stanley, Rikki]) 

Comment: In my opinion, STP and the Center for Energy Development is the best thing that 

has ever happened to Matagorda County. ... in all my life I have never experienced anything 

that meets or exceeds the culture of STP. Their strong commitment to safety and exemplary 

work ethics are a model for any industry. (0004-2-31 [Yeamans, Joe]) 

Comment: I think that STP is doing a wonderful job in the community ... They are so good in 

the community, with no problems, no one even knows you’re here beyond the boundaries of this 

local area. ... I know that you are good for the community, and you are doing really well. 

(0004-2-34 [Fuson, David]) 

Comment: Why STP? ... STP provides super, super training that I have not seen anywhere 

else. The emphasis on quality of work, there are multiple points of checks and balances, so 

there’s nothing that can fall in the crack. Reviews, updates, new designs are done in a very 
Appendix E 

NUREG-1937 E- 102 February 2011 

timely manner. Cost of generation has gone down continuously due to improvement of plant 

performance, training of personnel, and a very positive attitude that can be seen and 

experienced at the STP. (0004-2-5 [Kumar, Vatsu]) 

Comment: As a resident of Palacios and Matagorda County, I am proud that STP is a good 

neighbor and a productive, tax paying organization. STP’s safety record and emergency 

response methods have been a models for other nuclear power plants throughout the nation. ... 

As a member of the Palacios Hospital board, I appreciate STP and NINA’s commitment of 

support for our Critical Access Hospital, a non-taxing 501c3 organization. (0005-1 [Purvis, Gail]) 

Comment: Safety of plant personnel and plant equipment is number 1 priority at STP. Trained 

personnel perform far more better than those that are not. Emphasis on quality of work, multiple 

points of checks and balances at STP. Design reviews, updates and new designs in a timely 

manner at STP. ... Engineering continuously monitors the plant performance, looking for ways 

and means to continuously improve plant efficiency. Cost of generation has gone down 

continuously since 1996 due to improved plant performance, training of personnel and a positive 

attitude. (0007-2 [Kumar, Vatsu]) 

Comment: For 20 years, STP’s existing units have provided safe, clean, reliable energy to two 

million Texas homes. The facility is a recognized industry leader in production, reliability, and 

safety. Earlier this year, STP surpassed 10 million man-hours --nearly three years -without a 

lost -time or restricted duty injury. The facility is focused and committed to the safety of its 

employees and the surrounding communities. (0012-3 [Scurlock, Betty]) 

Response: These comments express support of the existing Units 1 and 2 at the site. No 

changes were made to the EIS as a result of the comments. 

E.2.30 General Comments in Opposition to Nuclear Power 

Comment: There are ways to generate electricity. There are safe, affordable, less risky 

options to do so, and plenty of ways to have economic vitality in the community without building 

nuclear reactors. (0004-1-38 [Hadden, Karen]) 

Response: This comment expresses general opposition to nuclear power and does not provide 

any specific information relating to the environmental effects of the proposed action. No 

changes were made to the EIS as a result of this comment. 

E.2.31 Comments Concerning Issues Outside Scope - Safety 

Comment: We have concerns with safety. (0004-1-31 [Hadden, Karen]) 
Appendix E 

February 2011 E-103 NUREG-1937 

Comment: The EIS is deficient because it fails to consider the combined effects of ongoing 

subsidence, frequent flooding due to tropical weather and rising sea levels. For both the units 

and the community, the cumulative effect of these could mean both would eventually be below 

mean sea level. (0013-6 [Dancer, Susan]) 

Response: Safety issues are outside the scope of the environmental review and were not 

addressed in the EIS. However, the NRC is developing a Safety Evaluation Report that 

analyzes all aspects of reactor and operational safety. 

E.2.32 Comments Concerning Issues Outside Scope - Security and Terrorism 

Comment: We have concerns with ... security. (0004-1-32 [Hadden, Karen]) 

Response: Comments related to security and terrorism are safety issues that are not within the 

scope of the environmental review. The NRC is devoting substantial time and attention to 

terrorism-related matters, including coordination with the U.S. Department of Homeland 

Security. As part of its mission to protect public health and safety and the common defense and 

security pursuant to the Atomic Energy Act, the NRC staff is conducting vulnerability 

assessments for the domestic utilization of radioactive material. In the time since September 

2001, the NRC has identified the need for license holders to implement compensatory 

measures and has issued several orders to license holders imposing enhanced security 

requirements. The NRC has also imposed enhanced security requirements on both license 

holders and applicants by rule. Finally, the NRC has taken actions to ensure that applicants 

and license holders maintain vigilance and a high degree of security awareness. Consequently, 

the NRC will continue to consider measures to prevent and mitigate the consequences of acts 

of terrorism in fulfilling its safety mission. Additional information about the NRC staff’s actions 

regarding physical security since September 11, 2001, can be found on the NRC’s website at 

www.nrc.gov/reading-rm/doc-collections/fact-sheets/security-enhancements.html. 

E.2.33 General Editorial Comments 

Comment: DEIS Section 01.01. Background. Page 1-2, Line 33: The DEIS states “... two 

ABWR reactors each with thermal power ratings of 3853 MW(t).” The correct value for Units 3 

& 4 is 3926 MW(t) (RAI Response 07.02-07). (0010-1-1 [Head, Scott]) 

Comment: DEIS Section 02.03.02. Water - Water Use. Page 2-37, Line 17, Table 2-4, “Annual 

Permitted” line: The DEIS Table 2-4 states in the last row of the References column “CBGCD 

2009”. Please change “CBGCD” to “CPGCD”. (0010-1-16 [Head, Scott]) 

Comment: DEIS Section 02.04. Ecology. Page 2-91, Lines 4-6: The DEIS states “This species 

was collected in the Columbia River during the 1975-1976 nekton samples (NRC 1986), the 

1983-1984 ichthyplankton samples (NRC 1986), and in the 2007-2008 bag seine and trawl 
Appendix E 

NUREG-1937 E- 104 February 2011 

samples (ENSR 2008c).” The data refer to the Colorado River, not the Columbia River. Please 

note that ichthyoplankton is misspelled. (0010-1-19 [Head, Scott]) 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-112, Line 27: The DEIS text 

references Figure 2-17. Instead, it should reference Table 2-18. (0010-1-22 [Head, Scott]) 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-112, Line 28: The DEIS text 

references Figure 2-17. Instead, it should reference Table 2-18. (0010-1-23 [Head, Scott]) 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-118, Line 13: The DEIS states 

“Table 2-23 shows where the STP site’s employees lived”. This should be “Table 2-16 shows....” 

(0010-1-25 [Head, Scott]) 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-127, Line 6: The DEIS contains an 

incomplete reference to a table. The correct reference should be Table 2-28. (0010-1-28 [Head, 

Scott]) 

Comment: DEIS Section 02.05. Socioeconomics. Page 2-131, Line 29: The DEIS contains an 

incomplete reference to a table. The correct reference should be Table 2-16. (0010-1-29 [Head, 

Scott]) 

Comment: DEIS Section 02.13. References. Page 2-183, lines 26-28: The DEIS states: “South 

Texas Project Nuclear Operating Company (STPNOC). 2009e. Letter from Scott Head, 

STPNOC, to NRC, dated November 23, 2009, Response to Request for Additional Information 

Accession No. ML093310296.” Accession No. ML093310296 is related to ER Section 5.4, 

instead of ER Section 2.3. The correct document for the STPNOC 2009e Reference should be 

another STPNOC letter to the NRC, also dated November 23, 2009 (Accession No. 

ML093310392), that provided COLA markups for ER Section 2.3.1. (0010-1-34 [Head, Scott]) 

Comment: DEIS Section 03.03. Construction and Preconstruction Activities. Page 3-15, Line 

10: The DEIS states, “The MDC from the site would be relocated via shallow excavation of the 

new course.” The phrase “would be” in the sentence should be changed to “has been.” (0010-

1-43 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-18, Lines 29-30: The DEIS 

states, During normal plant operation, the CWS would dissipate approximately 8.656 x 109

Btu/hr for each unit, or 1.732 x 109

 Btu/hr for both units, of waste heat. The correct value is 

1.732 x 1010 Btu/hr for both units consistent with DEIS Table 3-4. (0010-1-46 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-23, Line 31: The DEIS states, 

“Water from the MCR may be discharged to the Colorado River subject to the limitations of the 

STP site’s existing National Pollutant Discharge Elimination System (NPDES) permit (STPNOC 
Appendix E 

February 2011 E-105 NUREG-1937 

2009a).” The phrase “National Pollutant Discharge Elimination System (NPDES)” should be 

changed to “Texas Pollutant Discharge Elimination System (TPDES).” (0010-1-50 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-24, Table 3-3: The DEIS states, 

two of the chemicals in Table 3-3, Representative Water Treatment Chemicals Used for STP 

Units 1 and 2, as “Sodium hyperchlorite and Sodium bisulfate.” This should be corrected to 

read “Sodium hypochlorite and Sodium bisulfite.” (0010-1-51 [Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-25, Line 6: The DEIS contains 

an incomplete reference to a table. The correct reference should be Table 3-2. (0010-1-54

[Head, Scott]) 

Comment: DEIS Section 03.04. Operational Activities. Page 3-26, Table 3-4: The DEIS cites a 

value of “1.732 x 1010” under both the Normal Operating Condition and Maximum Condition 

columns for the Meteorology/Air Quality Resource Area.” The value should be corrected to 

show the proper exponential notation as “1.732 x 1010.” (0010-1-57 [Head, Scott]) 

Comment: DEIS Section 04.10. Nonradiological Waste Impacts - Construction. Page 4-76, 

Line 18: The DEIS states that cumulative impacts to water are discussed in Section 7.2.2.1 and 

cumulative air impacts from nonradioactive emissions are discussed in Section 7.5. Cumulative 

water impacts are discussed in both 7.2.2.1 and 7.2.2.2 while air impacts are discussed in 

Section 7.6 of the DEIS. (0010-1-80 [Head, Scott]) 

Comment: DEIS Section 04.10. Nonradiological Waste Impacts - Construction. Page 4-75, 

Lines 32-33: The DEIS states a conclusion that “no further mitigation would not be warranted.” 

STPNOC recommends correcting this double negative statement to “further mitigation would not 

be warranted”. (0010-1-82 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-3, Line 32: The 

DEIS states that ”...make-up to the Main Cooling Reactor....” Main Cooling Reactor should be 

changed to Main Cooling Reservoir. (0010-2-1 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-6, Lines 8-9: The 

DEIS states that, “The normal and maximum conditions refer to 93 and 100 percent load 

factors, respectively (STPNOC 2008a).” The correct reference is STPNOC 2009a (STPNOC 

Letter U7-C-STP-NRC-090130, dated September 16, 2009), which includes this information in 

Environmental Report (Rev. 3.0), Section 3.3.1. (0010-2-4 [Head, Scott]) 

Comment: DEIS Section 05.02 Water-Related Impacts - Operation. Page 5-7, Lines 27-28: 

The DEIS states that, “As described in Section 2.3.1.1, STPNOC currently diverts water from 

the Colorado River following a set of rules specified by the STPNOC-LCRA water contract 

(STPNOC 2009c).” This reference should be corrected to STPNOC 2009d (STPNOC Letter U7-
Appendix E 

NUREG-1937 E- 106 February 2011 

C-STP-NRC-090006, dated January 22, 2009) which includes RAI 02.03-06 stating these rules. 

(0010-2-8 [Head, Scott]) 

Comment: DEIS Section 05.02. Water-Related Impacts - Operation. Page 5-7, Lines 30-31: 

The DEIS states that “... maintain the MCR water level at or above 25 ft above MSL.” Based on 

Supplemental Response to RAI 02.03-06 (STPNOC 2009d Reference STPNOC Letter U7-CSTP-NRC-090006, dated January 22, 2009) and the ‘Amended and Restated Contract by and 

between the Lower Colorado River Authority and STP Nuclear Operating Company’, page 26, 

Note 4, effective January 1, 2006, the MCR water level is maintained at or above 27 ft MSL. The 

MCR water level of 27 ft MSL is correctly stated in DEIS Section 2.3.2, Page 2-34, Line 17. 

(0010-2-9 [Head, Scott]) 

Comment: DEIS Section 05.03. Ecological Impacts - Operation. Page 5-22, Line 29: The DEIS 

states that the maximum drift rate reported by STPNOC is 45 gpm. However, per response to 

RAI 05.10-4, US Tower Drift is a maximum of 10 gpm, not 45 gpm. (0010-2-16 [Head, Scott]) 

Comment: DEIS Section 05.03. Ecological Impacts - Operation. Page 5-32, Line 18-20: The 

DEIS states, “Water quality monitoring during the 2007-2008 aquatic ecology studies in the 

MCR showed that the salinity (a surrogate for dissolved solids) was on average 1.6 parts per 

trillion (ppt) (ENSR 2008a).” The Environmental Report (Rev. 3) defines ppt as follows: 

“Salinities less than 0.5 parts per thousand (ppt) are generally regarded as limnetic or “fresh,” 

while salinities greater than 0.5 ppt are generally regarded as indicative of brackish water.” 

(Section 2.4.2.1.2 in the ER). “Parts per trillion” should be changed to “parts per thousand”. 

(0010-2-17 [Head, Scott]) 

Comment: DEIS Section 05.04. Socioeconomic Impacts – Operation. Page 5-49, Line 23: The 

DEIS references Section 2.5.1. The appropriate reference should be Section 4.4.1.1. 

(0010-2-20 [Head, Scott]) 

Comment: DEIS Section 05.10. Nonradiological Waste Impacts - Operation. Page 5-95, Line 

3: The DEIS states that cumulative impacts to air from nonradioactive emissions are discussed 

in Section 7.5. Cumulative air impacts are discussed in Section 7.6 of the DEIS. (0010-2-32

[Head, Scott]) 

Comment: DEIS Section 05.11. Environmental Impacts of Postulated Accidents, Page 5-97, 

Line 32-34: The DEIS states: “The doses in Table 5-16 were calculated by the NRC staff from 

the DBA doses in the design control document using the ratio of the staff’s site-specific 

atmospheric dispersion factors in Table 5-16 to the atmospheric dispersion factors assumed for 

the design certification.” The staff’s site-specific atmospheric dispersion factors are provided in 

Table 5-15 on DEIS Page 5-98, Line 1, not Table 5-16. (0010-2-33 [Head, Scott]) 
Appendix E 

February 2011 E-107 NUREG-1937 

Comment: DEIS Section 05.11. Environmental Impacts of Postulated Accidents, Page 5-98, 

Line 2: The DEIS Table 5-16 states that the EAB thyroid dose for a Loss-of-Coolant Accident is 

51 rem. This dose appears to be a typographical error with a factor of 10 too high. DEIS 

Section 05.11, Page 5-97, Lines 32-34 states, “The doses in Table 5-16 were calculated by the 

NRC staff from the DBA doses in the design control document using the ratio of the staff’s sitespecific atmospheric dispersion factors in Table 5-16 to the atmospheric dispersion factors 

assumed for the design certification.” Use of this approach results in an EAB thyroid dose for 

the Loss-of-Coolant Accident of 5.1 rem, instead of 51 rem. (0010-2-34 [Head, Scott]) 

Comment: DEIS Section 06.01. Fuel Cycle Impacts and Solid Waste Management. Page 6-2, 

Table 6-1: The DEIS includes format differences in Table 6-1 that make it inconsistent with 

Table S-3 of 10 CFR 51.51(b). Under the “Natural Resource Use” heading, “Disturbed area” 

should be a subcategory under “Temporarily committed” land similar to “Undisturbed area.” 

“Natural gas” should be a subcategory under “Fossil fuel.” (0010-2-35 [Head, Scott]) 

Comment: DEIS Section 06.01. Fuel Cycle Impacts and Solid Waste Management. Page 6-5, 

Line 14: The DEIS states that UO2 is converted to uranium hexafluoride at a conversion facility. 

The type of uranium oxide that is converted to uranium hexafluoride is U3O8, commonly known 

as yellowcake, not UO2. (Reference DEIS Table 6-1). (0010-2-36 [Head, Scott]) 

 Comment: DEIS Section 06.02. Transportation Impacts. Page 6-23, Line 5: Text was omitted 

from the DEIS. The sentence should be revised to add “they” after “Air passengers are less of a 

concern because...” (0010-2-39 [Head, Scott]) 

Comment: DEIS Section 09.03. Alternative Sites, Page 9-92, lines 5-7: The DEIS states: 

“Allens Creek is a greenfield site that was set aside for a nuclear power plant and cooling 

reservoir in the early 1970s in a proposal by the Houston Power and Lighting Company.” The 

correct company name is “Houston Lighting & Power Company.” (0010-2-65 [Head, Scott]) 

Comment: EIS Section 10.06. Benefit-Cost Balance. Page 10-26, Line 16: The DEIS states 

that “normal operation of a nuclear power plant does not result in any emissions of criteria (e.g., 

oxides of nitrogen or sulfur dioxide)”. The word pollutants should be added after criteria for 

clarification. (0010-2-83 [Head, Scott]) 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-5, Table G-1 (contd): In the Sectors column change “SSW SW” 

to ”SSW”. (0010-2-86 [Head, Scott]) 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-7, Table G-1 (contd): In the Sectors column change the first and 

topmost ”NNW” to ”NW”. (0010-2-87 [Head, Scott]) 
Appendix E 

NUREG-1937 E- 108 February 2011 

Response: These comments are editorial in nature. The EIS was changed to reflect these 

comments. 

Comment: DEIS Section 04.07. Meteorological and Air-Quality Impacts. Page 4-64, Line 10: 

The DEIS states, “STPNOC (2009a) has stated that a construction management traffic plan 

would be developed before building activities begin.” STPNOC suggests that the phrase 

“building activities” be changed to “construction activities.” (0010-1-77 [Head, Scott]) 

Response: The NRC has defined “construction” according to the bounds of its regulatory 

authority, but many of the activities required to build a nuclear power plant do not fall within the 

NRC’s regulatory authority. Those non-NRC authorized activities are referred to as 

“preconstruction” activities. The review team used the term “building activities” to capture both 

preconstruction and NRC-authorized construction activities, and believe the STPNOC’s 

construction management traffic plan would cover “building activities;” therefore, no change was 

made to the EIS. 

Comment: DEIS Section 10.04. Irreversible and Irretrievable Commitments of Resources. 

Page 10-15, Line 17: The DEIS gives specific quantities of building materials required for the 

construction of a single reactor based on the following reference: “U.S. Department of EnergyEnergy Information Administration (DOE/EIA). 2006. Energy Power Annual. Energy 

Information Administration, Washington, D.C. Accessed February 4, 2008 at 

http://www.eia.doe.gov/cneaf/electricity/epa/epa_sum.html. Accession No. ML100600709.” 

This reference is a review of electric industry activities that occur annually and does not provide 

information on construction materials. Additionally, the citation is incorrect for this information. 

The call-out is dated 2006, the document is dated 2008, and the ADAMS accession number is 

for a 2007 document. (0010-2-76 [Head, Scott]) 

Response: The reference callout in Section 10.4 was revised based on this comment. This 

information is from the following document: 

U.S. Department of Energy. 2004. “Application of Advanced Construction Technologies to New 

Nuclear Power Plants.” In NP2010 Improved Construction Technologies, O&M Staffing and 

Cost, Decommissioning Costs, and Funding Requirements Study. MPR-2610. Washington, 

D.C. Accession No. ML093160836. 

Comment: DEIS Appendix G. Supporting Documentation for Socioeconomic and Radiological 

Dose Assessment. Page G-16, Line 8: The DEIS states, “The NRC staff and STPNOC 

calculated the dose at 2.19 mi west-southwest of the new units.” Rev. 3.0 of the Environmental 

Report (Section 5.4, Table 5.4-4, p. 5.4-11) indicates that the distance was revised to 2.18 

miles. (0010-2-88 [Head, Scott]) 

Response: Appendix G of the EIS was revised to correct the distance for the dose to the 

maximally exposed individual. The revision is editorial in nature and does not affect the 

conclusions of the EIS. The appropriate value of 2.18 mi was used in EIS Section 5.9.2.2. 
Appendix F 

Key Consultation Correspondence 

February 2011 F-1 NUREG-1937 

Appendix F 

Key Consultation Correspondence 

Correspondence received during the evaluation process for the combined license application for 

the siting of two new nuclear units, Units 3 and 4, at the South Texas Project Electric 

Generating Station (STP) site in Matagorda County, Texas, is identified in Table F-1. In 

addition, full copies of the Biological Assessment (BA), consultation correspondence with the 

National Marine Fisheries Service concerning the BA, and the Essential Fish Habitat 

Assessment are included in this appendix.

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 

Texas General Land Office 

(Mrs. Tammy Brooks) 

STP Nuclear Operating Company 

(Mr. Gregory Gibson) 

June 09, 2008 

ML091590374 
Appendix F 

NUREG-1937 F-2 February 2011 

Table F-1. (contd)

Source Recipient Date of Letter

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 

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 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

U.S. Fish and Wildlife Service 

(Mrs. Moni Belton) 

March 19, 2010 

ML100470259 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

National Marine Fisheries Service 

(Mr. David Bernhart) 

March 19, 2010 

ML100470304 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

Advisory Council on Historic 

Preservation (Mr. John Fowler) 

March 19, 2010 

ML100490064 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

Kiowa Tribe 

(Mr. Billy Evans Horse) 

March 19, 2010 

ML100490124 
Appendix F 

February 2011 F-3 NUREG-1937 

Table F-1. (contd)

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

Tonkawa Tribe of Oklahoma 

(Mr. Anthony E. Street) 

March 19, 2010 

ML100490722 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

Alabama-Coushatta Tribe (Principal 

Chief Oscola Clayton Sylestine) 

March 19, 2010 

ML100490732 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

Comanche Nation NAGPRA and 

Historic Preservation Program 

(Ms. Ruth Toahty) 

March 19, 2010 

ML100490795 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

Texas Historical Commission 

(Mr. Mark Wolfe) 

March 19, 2010 

ML100490740 

Texas Historical Commission 

(Mr. William A. Martin for Mark Wolfe) 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

March 30, 2010 

ML100990381 

National Marine Fisheries Service 

(Mr. Rusty Swafford) 

U. S. Nuclear Regulatory Commission April 20, 2010 

ML1011903791 

Alabama-Coushatta Tribe 

(Mr. Bryant J. Celestine) 

U.S. Nuclear Regulatory Commission May 6, 2010 

ML101300039 

U.S. Environmental Protection 

Agency Region Ground Water Center 

(Mr. Michael Bechdol) 

U.S. Nuclear Regulatory Commission 

(Ms. Jessie Muir) 

June 2, 2010 

ML101540268 

U.S. Department of Interior 

(Mr. Stephen Spencer) 

U.S. Nuclear Regulatory Commission June 8, 2010 

ML101600049 

U.S. Environmental Protection 

Agency Region 6 

(Mrs. Cathy Gilmore) 

U.S. Nuclear Regulatory Commission 

(Ms. Jessie Muir) 

June 9, 2010 

ML101610346 

U.S. Army Corps of Engineers 

(Mr. Jayson Hudson) 

STP Nuclear Operating Company 

(Mr. Scott Head) 

June 9, 2010 

ML101660315 

U.S. Army Corps of Engineers 

(Mr. Casey Cutler) 

STP Nuclear Operating Company 

(Mr. Scott Head) 

September 16, 2010 

ML103020111 

STP Nuclear Operating Company 

(Mr. Scott Head) 

U.S. Army Corps of Engineers 

(Mr. Jayson Hudson) 

October 12, 2010 

ML103060028 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

National Marine Fisheries Service 

(Mr. David Bernhart) 

November 17, 2010 

ML102880822 

National Marine Fisheries Service 

(Mr. Roy E. Crabtree) 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

January 18, 2011 

ML110190723 
Appendix F 

NUREG-1937 F-4 February 2011 

Biological Assessment 

National Marine Fisheries Service

South Texas Project Electric Generating Station Units 3 and 4 

U.S. Nuclear Regulatory Commission Combined License Application 

Docket Nos. 52-012 and 52-013 

U.S. Army Corps of Engineers Permit Application 

Matagorda County, Texas 

March 2010

U.S. Nuclear Regulatory Commission 

Rockville, Maryland 

U.S. Army Corps of Engineers 

Galveston District 
Appendix F 

February 2011 F-5 NUREG-1937 

1.0 Introduction 

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from STP Nuclear 

Operating Company (STPNOC) for two combined construction permit and operating licenses 

(combined licenses or COLs) for two new reactors at the South Texas Project Electric 

Generating Station (STP) site in Matagorda County, approximately 12 mi south-southwest of 

Bay City, Texas (Figure 1). STPNOC submitted the COL application to the NRC on September 

20, 2007. The STP site and existing facilities are owned by NRG South Texas LP (NRG), City 

Public Service Board of San Antonio, Texas (CPS Energy), and the City of Austin, Texas. It is 

planned that proposed Unit 3 would be owned by Nuclear Innovation North America (NINA) 

South Texas 3 LLC and CPS Energy, and proposed Unit 4 would be owned by NINA South 

Texas 4 LLC and CPS Energy (STPNOC 2009a). Concurrent with the NRC’s review, the U.S. 

Army Corps of Engineers (Corps) is reviewing STPNOC’s application for a Department of the 

Army (DA) Permit to build the proposed reactors on the STP site. The NRC and the Corps are 

cooperating agencies with the NRC serving as the lead agency. This biological assessment 

(BA) supports a joint consultation with the National Oceanic and Atmospheric Administration’s 

(NOAA) National Marine Fisheries Service (NMFS) pursuant to Section 7(c) of the Endangered 

Species Act of 1973, as amended (ESA). 

The NRC and the Corps are preparing an environmental impact statement (EIS) as part of the 

agencies’ review of the COL and DA permit applications pursuant to the National Environmental 

Policy Act (NEPA). As required by Title 10 of the Code of Federal Regulations (CFR) Part 

51.26, the NRC has published a Notice of Intent (72 FR 72774) in the Federal Register to 

prepare an EIS, conduct scoping, and publish a draft EIS for public comment. The final EIS 

would be issued after considering public comments on the draft. The impact analysis in the EIS 

includes an assessment of the potential environmental impacts of the construction and 

operation of two new nuclear power units at the STP site and along the associated transmission 

line corridors, including potential impacts to threatened and endangered species. If approved, 

the COLs and DA permit would authorize STPNOC to construct and operate the new units. 

This BA examines the potential impacts on threatened or endangered species due to 

construction of the proposed Units 3 and 4 at the STP site. As discussed in the STP EIS, 

operation of the proposed two new nuclear power units at the STP site would not affect critical 

habitat or Federally listed species within the jurisdiction of NMFS. Therefore, this BA focuses 

on the species that may be affected by construction activities, specifically barging of heavy 

equipment and materials to the site. These species include loggerhead sea turtle 

(Caretta caretta), green sea turtle (Chelonia mydas), leatherback sea turtle (Dermochelys 

coriacea), hawksbill sea turtle (Eretmochelys imbricata), and Kemp’s ridley sea turtle 

(Lepidochelys kempii) (Table 1). 
Appendix F 

NUREG-1937 F-6 February 2011 

Figure 1. Location of the STP Site and Major Important Aquatic Resources 
Appendix F 

February 2011 F-7 NUREG-1937 

Table 1. Federally Listed Marine Species Occurring in the Vicinity of Transportation Routes to 

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 

2.0 South Texas Project Site Description 

The STP site is located in a rural area of Matagorda County, Texas. STPNOC currently 

operates two nuclear generating units (existing STP Units 1 and 2) on the site. The site is 

located approximately 10 mi north of Matagorda Bay, 70 mi south-southwest of Houston, and 

12 mi south-southwest of Bay City, Texas. The site is along the west bank of the Colorado 

River, approximately 6 navigable miles from the confluence with the Gulf Intracoastal Waterway 

(GIWW). This section provides a description of the existing and proposed facilities and the 

ecological resources found at the site of the proposed project and in the vicinity. 

2.1 Existing and Proposed Facilities on the STP Site 

The 12,220-ac STP site currently contains two pressurized water reactors and their associated 

facilities, which occupy approximately 300 ac. The main condenser heat sink for the existing 

two units is a 7000-ac reservoir called the Main Cooling Reservoir (MCR). The 7000-ac MCR is 

a constructed impoundment enclosed by an engineered embankment with a maximum normal 

operating pool of 49 ft mean sea level. The existing units also have a much smaller 46-ac 

Essential Cooling Pond (ECP) for their Ultimate Heat Sink (UHS). Makeup water for the MCR is 

withdrawn from the Colorado River at the Reservoir Makeup Pumping Facility (RMPF) to 

maintain the reservoir volume and control the concentration of total dissolved solids in its 

waters. The RMPF is located on the west bank of the river, approximately 8 navigable miles 

upstream of the confluence of the Colorado River and the GIWW. Near the southeast corner of 

the MCR is a spillway and blowdown discharge pipeline, which releases water to the Colorado 

River downstream from the RMPF. The spillway allows release of excess water from the MCR 

to the Colorado River during heavy precipitation events. The blowdown discharge pipeline 

allows for controlled releases of water from the MCR into the Colorado River through seven 

valve boxes along the river shoreline. Next to and downstream of the RMPF is a barge slip that 

was used for delivery of major equipment during the construction of Units 1 and 2. STPNOC’s 

proposed location for proposed Units 3 and 4 is wholly within the STP site, approximately 1500 

north and 2150 ft west of the center of the existing Units 1 and 2 containment buildings on the 

north side of the MCR, as shown in Figure 2 (STPNOC 2009a). 
Appendix F 

NUREG-1937 F-8 February 2011 

Figure 2. STP Site and Proposed Plant Footprint (STPNOC 2009a) 
Appendix F 

February 2011 F-9 NUREG-1937 

Many of the existing facilities already were designed to support four nuclear reactor units, and 

the proposed Units 3 and 4 would rely on these facilities. The main condenser heat sink for the 

proposed units would be the MCR. The proposed new units would not rely on the ECP as an 

UHS in the event of an emergency, but rather would rely on two 119-ft-tall mechanical draft 

cooling towers that would be located north of the MCR (STPNOC 2009a). Modifications to the 

RMPF associated with the two new units would be limited and include refurbishing or replacing 

intake screens for currently unused bays and the addition of two new pumps. Maintenance 

dredging in front of the intake screens and the RMPF’s forebay would continue during 

construction and operation of the new units. No changes or upgrades are planned for the 

spillway and blowdown discharge pipeline from the MCR to the Colorado River to support the 

new units. The barge slip would be refurbished to allow delivery of material for constructing 

Units 3 and 4. In the event of an emergency, the proposed Units 3 and 4 would not rely on the 

ECP as a UHS. Instead, they will rely on two mechanical draft cooling towers as mentioned 

above (STPNOC 2009a). In addition, the Corps would periodically dredge the Colorado River to 

maintain the navigation channel from the GIWW to a point upstream of the STP site. 

2.2 Aquatic Ecological Resources 

The aquatic resources associated with the STP site include onsite water resources (sloughs, 

drainage areas, wetlands, Kelly Lake, and the MCR) and offsite water resources, particularly the 

Colorado River. The species of concern for this BA are associated with the offsite water 

resources. This section will discuss the offsite water resources likely to be affected by the 

barging activities for the construction and operation of the proposed STP Units 3 and 4. 

The Colorado River is one of the largest river systems within the State of Texas. The river is 

approximately 862 mi, extending from the high plains to the coastal marshes in Matagorda 

County. The section of the river near the STP site, between Bay City and the GIWW, is a 

diverse, fluvial system that meanders through the coastal plain providing freshwater, sediments, 

and nutrients to Matagorda Bay (ENSR 2008a). The lower Colorado River has been studied on 

a limited basis with specific studies conducted in 1974, 1976, 1983, and 1984 associated with 

the licensing of existing STP Units 1 and 2 (NRC 1975, 1986) and in 2007-2008 associated with 

the licensing of the proposed STP Units 3 and 4 (ENSR 2008a). 

Changes in the aquatic community in the Colorado River over time were evaluated using the 

results of the 1974, 1983, 1984, and 2007-2008 studies. These studies span the time of 

construction and operation of the existing STP Units 1 and 2, as well as the Corps’ Mouth of 

Colorado River project that completed the diversion of the Colorado River into Matagorda Bay in 

July 1992. The sampling locations and gear types varied with each study, making some 

comparisons more difficult. Trawl samples collected from the GIWW to the STP site in 1974 

showed a moderately diverse species community for the lower river based on measures for 

species richness, diversity, and evenness. All three measures were slightly lower than those in 
Appendix F 

NUREG-1937 F-10 February 2011 

similar segments of the river compared to the 2007-2008 study, suggesting that the diversity of 

aquatic species is greater now than in the past. Data collected during 1974 examining specific 

segments also indicated a diverse species community for all three segments. The 1983-1984 

trawl and seine data indicated overall lower species richness, diversity, and evenness relative to 

the present data (ENSR 2008a). Rerouting of the lower Colorado River has likely contributed to 

these changes in diversity of aquatic species. 

The number and assortment of organisms collected during this study indicate that this portion of 

the lower Colorado River supports a diverse assemblage of fauna. The regular occurrence of 

both freshwater and saltwater species, the range of macroinvertebrate and finfish fauna, and the 

sheer number of species captured among various sampling gears and river reaches provide 

evidence of a dynamic ecosystem. There was a low to moderate level of similarity between the 

current 2007-2008 faunal communities and the historic communities (1974 and 1983-84) (ENSR 

2008a). 

Matagorda Bay is 300 mi2

 formed by a 45-mi-long barrier island parallel to the coast and is 

located to the southeast of STP. The Bay is connected naturally to the waters on the site 

through the discharges of Little Robbins Slough into the marshes next to the GIWW, which then 

flow into Matagorda Bay. As mentioned, the Colorado River flows past STP, across the GIWW, 

and into a diversion channel, which flows into the Bay. The Bay is described as the Matagorda 

Bay system, and it is the third largest estuary on the Texas coast. The Bay system includes 

Lavaca, East Matagorda, Keller, Carancahua, and Tres Palacios Bays (Corps 2007). 

The aquatic community of the Matagorda Bay system includes organisms in open water areas, 

as well as organisms over hard substrates (including oyster reefs and offshore sands). In the 

open water areas of the Bay, phytoplankton (e.g., algae) are the major primary producers 

providing the main food source for zooplankton (e.g., small crustaceans), fish, and benthic 

organisms (e.g., mollusks). A study of Lavaca Bay found that phytoplankton species 

composition changes based on the season, with maximum abundance occurring in the winter 

and minimum in the summer, and the most dominant organisms were diatoms (Corps 2007). 

Zooplankton composition also changed seasonally, with the greatest abundance during the 

spring and minimum in the fall. The same composition of phytoplankton and zooplankton are 

thought to be found throughout the Matagorda Bay estuary (Corps 2007). 

The Matagorda Bay system supports a diverse population of aquatic organisms that are found 

in the open water column (nekton), including fish, shrimp, and crabs. The nekton assemblages 

consist mainly of secondary consumers feeding on zooplankton or juvenile and smaller 

organisms in the water column. Some of these species are resident species, spending their 

entire life in the Bay, whereas other species may spend only a portion of their life cycle in the 

Bay. According to a summary of studies on the nekton species in the Matagorda Bay estuary, 

the dominant nekton species include the bay anchovy (Anchoa mitchilli), Atlantic croaker 

(Micropogonias undulatus), white shrimp (Litopenaeus setiferus), brown shrimp 
Appendix F 

February 2011 F-11 NUREG-1937 

(Farfantepenaeus aztecus), hardhead catfish (Ariopsis felis), sand seatrout (Cynoscion 

arenarius), blue crab (Callinectes sapidus), and Gulf menhaden (Brevoortia patronus). All of 

these species are ubiquitous along the Texas coast, and they are unaffected by seasonal or 

other short-term changes (e.g., salinity). The abundance of these species changes with the 

season, with biomass and number usually being the smallest in the fall after Gulfward 

migrations. In the winter and early spring, newly spawned fish and shellfish begin migrating into 

the Bay, with the maximum biomass observed during the summer months (Corps 2007). Many 

of these species have been collected in the Colorado River and some in the MCR at the STP 

site (NRC 1975, 1986; ENSR 2008a, 2008b; STPNOC 2009a). 

Areas of the Matagorda Bay estuary that are not considered open water include oyster reefs 

(Eastern oyster, Crassostrea virginica) and offshore sands. The oyster reefs of Matagorda Bay 

are formed in areas where the substrate is hard and the current is strong enough to provide 

phytoplankton and nutrients to the oysters and carry sediment away from the organisms. The 

reefs are subtidal or intertidal and found near passes, cuts, and along the edges of marshes. 

The oyster reefs provide an ecologically important function to the Bay system by supplying 

habitat to other benthic organisms and influencing water clarity and quality (oysters can filter 

water 1500 times the volume of their body per hour). While oysters can survive in salinities 

ranging from 5 to more than 40 ppt, they thrive within a range of 10 to 25 ppt. The current 

distributions of oyster reefs in Matagorda Bay are not mapped, but the prominent locations 

(including commercial harvests) are in the vicinity of Lavaca Bay (Corps 2007). Primary goals 

of the diversion of the Colorado River into the Bay are to increase mixture of freshwater in the 

estuary and to enhance locations of the Bay for further reef development (Wilbur and Bass 

1998; Corps 2005). 

The offshore sands of the Matagorda Bay system include areas of open sandy substrate, as 

well as regions where seagrass or attached algae grow. Much of the faunal diversity in these 

areas is buried in the sand, and the organisms rely on the phytoplankton for food. Sand dollars 

(Mellita quinquiesperforata) and several species of brittle stars (Hemipholis elongata, Ophiolepis 

elegans, and Ophiothrix angulata) are some of the most common species found in the shallow 

offshore sands. The bivalves in offshore sands include the blood ark (Anadara ovalis), 

incongruous ark (Anadara brasiliana), southern quahog (Mercenaria campechiensis), giant 

cockle (Dinocardium robustum), disk dosinia (Dosinia discus), pen shells (Atrina serrata), 

common egg cockle (Laevicardium laevigatum), crossbarred venus (Chione cancellata), tellins 

(Tellina spp.), and the tusk shell (Dentalium texasianum). The most common gastropods are 

moon snail (Polinices duplicatus), ear snail (Sinum perspectivum), Texas olive (Oliva sayana), 

Atlantic auger (Terebra dislocata), Sallé’s auger (Terebra salleana), Scotch bonnet (Phalium 

granulatum), distorted triton (Distorsio clathrata), wentletraps (Epitonium spp.), and whelks 

(Busycon spp.). Crustaceans also inhabit the open sand areas, including white and brown 

shrimp, rock shrimp (Sicyonia brevirostris), blue crabs, mole crabs (Albunea spp.), speckled 

crab (Arenaeus cribrarius), box crab (Calappa sulcata), calico crab (Hepatus epheliticus), and 
Appendix F 

NUREG-1937 F-12 February 2011 

pea crab (Pinnotheres maculatus). With respect to the number of individuals found in the open 

sands, the most abundant infaunal organisms are the polychaetes (Capitellidae, Orbiniidae, 

Magelonidae, and Paraonidae) (Corps 2007). 

Aquatic resources of the GIWW in the vicinity of Matagorda Bay up to Port Freeport are not well 

described. The aquatic ecology is thought to be similar to that found in Matagorda Bay. GIWW 

is used extensively for commercial traffic and recreational use. The locks in the GIWW at the 

confluence of the Colorado River probably disrupt some aquatic organisms from moving through 

the area. Maintenance dredging of the GIWW occurs at such a frequency that the typical 

benthic community found in Matagorda Bay does not fully recover (Corps 2007). 

3.0 Proposed Federal Actions 

This section provides information on the potential aquatic impacts of construction activities 

related to the proposed Units 3 and 4 at the STP site. The proposed Federal actions are NRC’s 

issuance of two COLs for construction and operation of two new nuclear reactors at the STP 

site pursuant to 10 CFR Part 52 and the Corps’ issuance of a DA permit pursuant to Section 

404 of the Clean Water Act and Section 10 of the Rivers and Harbors Appropriation Act of 1899. 

The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

“construction” to activities that fall within its regulatory authority in 10 CFR 51.4. Many of the 

activities required to build a nuclear power plant are not part of the NRC action to license the 

plant. Activities associated with building the plant that are not within the purview of the NRC 

action are grouped under the term “preconstruction.” Preconstruction activities include clearing 

and grading, excavating, erection of support buildings and transmission lines, and other 

associated activities. These preconstruction activities may take place before the application for 

a COL is submitted, during the staff’s review of a COL application, or after a COL is granted. 

Although preconstruction activities are outside the NRC’s regulatory authority, many of them are 

within the regulatory authority of local, State, or other Federal agencies. The distinction 

between construction and preconstruction is not carried forward in this BA, and they are being 

discussed together as construction activities for this Section 7 consultation. 

This BA addresses the potential impacts posed by the construction activities that have the 

potential to interact with aquatic threatened and endangered species under the jurisdiction of 

NMFS. Primarily, these activities are associated with transport of materials and equipment 

using barges, which is not part of the NRC action. Operations of Units 3 and 4 would not 

interact with Federally listed aquatic threatened and endangered species or critical habitat. 

Delivery of major equipment for proposed Units 3 and 4 would be by barging the material to the 

site. The cargo that would be barged to the site includes heavy equipment (prefabricated 

modules and large components fabricated overseas) and bulk commodities (e.g., aggregate or 
Appendix F 

February 2011 F-13 NUREG-1937 

structural fill materials). STPNOC has stated that no firm shipping contracts have been 

developed for transportation of the materials to the STP site. However, STPNOC has indicated 

the current plans call for the heavy equipment to be shipped to the Port of Freeport (or points 

north) where they would be transferred from ocean-going ships to inland barges. The inland 

barges would then enter the GIWW, move south to the confluence of the Colorado River, and 

proceed upstream to the site. Currently, the ports in Matagorda Bay to the south of the site do 

not have adequate facilities for the transfer of heavy cargo from ocean-going vessels to inland 

barges. Therefore, transport of these materials would not involve the Matagorda Shipping 

Channel or the diversion canal in Matagorda Bay (STPNOC 2009b). 

STPNOC plans to ship bulk commodities (e.g., aggregate or structural fill materials) via inland 

barges. Access to the Colorado River by the barges would depend on the source of the 

materials and could be transported either from the north or south along the GIWW. However, 

no bulk commodity traffic is expected to traverse the diversion canal in Matagorda Bay or the 

Matagorda Shipping Channel (STPNOC 2009b). 

4.0 Protected Estuarine and Marine Species Descriptions 

NMFS lists 11 threatened and endangered species in Texas (Table 2). Of these species, only 

the sea turtles are expected to be associated with the construction of proposed STP Units 3 and 

4. The other species listed by NMFS for Texas are either too far away from the site (e.g., 

whales) or have not been found in the vicinity of the Colorado River or Matagorda Bay for 

numerous years (e.g., smalltooth sawfish [Pristis pectinata] [TPWD 2009a]). This section 

describes the life history and habitat use for the Federally listed sea turtles along the routes for 

ocean-going ships and inland barges that would transport materials to the STP site. 

There are two families and six genera of living sea turtles containing eight species (Pritchard 

1996). All but one of the species are in the family Cheloniidae. The leatherback sea turtle is the 

only living member of the family Dermochelyidae. Five of the eight living species of sea turtles 

occur in the Gulf of Mexico. These species are the loggerhead sea turtle, the green sea turtle, 

the leatherback sea turtle, the hawksbill sea turtle, and the Kemp's ridley sea turtle. Although 

each of these species have nested along the Texas coast, no critical habitat has been 

designated in the State for any of these sea turtle species (Pritchard 1996; NMFS 2009a; 

NPS 2009). 
Appendix F 

NUREG-1937 F-14 February 2011 

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 

4.1 Loggerhead Turtle (Caretta caretta) 

The loggerhead turtle was named for its relatively large head and has powerful jaws used to 

feed on hard-shelled prey, such as whelks and conchs. Its carapace is slightly heart-shaped 

and reddish-brown, while the plastron is generally a pale yellowish color. Adult turtles weigh 

170 to 400 lb and have a carapace up to 41 in. long. Females nest on beaches in subtropical 

and temperate areas and may nest several times during a breeding season (April to 

September), laying as many as 110 eggs per clutch. The hatchings vary in color from light to 

dark brown to dark gray, and they lack the reddish-brown coloration of the adults and juveniles. 

When loggerheads hatch, they are about 1.7 in. long and weigh approximately 0.04 lb (Prichard 

and Mortimer 1999; NMFS 2009b; TPWD 2009b). 

4.1.1 Reasons for Status 

The loggerhead turtle was listed as a threatened species throughout its range on July 28, 1978 

(43 FR 32808). Until the 1970s, these turtles were commonly harvested commercially for their 

meat, eggs, leather, and fat. While the loggerhead is the most common and abundant turtle on 

the inshore coastal waters of the Gulf of Mexico, its population has been declining as a result of 

overexploitation by man, fishing and trawling activities inadvertently killing individuals, and 

natural predation. The most significant threats to the loggerhead are development, commercial 

fisheries, and pollution (NMFS 2009b; Corps 2007; TPWD 2009b). 
Appendix F 

February 2011 F-15 NUREG-1937 

4.1.2 Habitat and Life History 

Loggerhead turtles are mainly found over the continental shelf and in bays, estuaries, lagoons, 

creeks, and mouths of rivers, but they can also occur in the open seas as far as 500 mi from 

shore. Loggerheads prefer warm temperate and subtropical regions not far from shorelines. 

Adult loggerheads occupy various habitats, from turbid bays to clear waters of reefs, while 

subadults occur mainly in nearshore and estuarine waters. Hatchlings move directly from their 

nest into the sea, and then often float in masses of sargassum (Sargassum sp.). Juvenile 

loggerheads may remain associated with sargassum for perhaps three to five years (NMFS and 

FWS 2008; Corps 2007). 

Loggerheads consume a wide variety of both benthic and pelagic food items. Their prey has 

been found to include conches, shellfish, horseshoe crabs, prawns, other crustacea, squid, 

sponges, jellyfish, basket starts, fish (carrion or slow-moving species), and even hatchling 

loggerhead turtles (Corps 2007). Adults forage primarily on the bottom but will also take jellyfish 

from the surface. The young feed primarily on the surface, grazing on gastropods and 

fragments of crustaceans as well as sargassum. 

Nesting usually occurs on open sandy beaches above the high-tide mark and seaward of welldeveloped dunes. Loggerheads prefer steeply sloped beaches with gradually sloped offshore 

approaches on high-energy beaches on barrier islands adjacent to continental land masses 

(Corps 2007). 

4.1.3 Range 

The loggerhead is widely distributed in tropical and subtropical seas, being found in the Atlantic 

Ocean from Nova Scotia to Argentina; the Gulf, Indian, and Pacific Oceans (although it is rare in 

the eastern and central Pacific); and the Mediterranean Sea. In the continental U.S., 

loggerheads nest along the Atlantic coast from Florida to as far north as New Jersey and 

sporadically along the Gulf Coast. In recent years, a few have nested on barrier islands along 

the Texas coast (Corps 2007). The loggerhead is the most abundant sea turtle species in U.S. 

coastal waters (NMFS and FWS 2007a). 

4.1.4 Distribution in Texas and Presence in the Study Area 

The most abundant sea turtle in the Texas coastal region is the loggerhead. The species 

prefers the shallow inner continental shelf waters and only infrequently does it move into the 

bays. The turtles are often found near offshore oil rig platforms, reefs, and jetties. They are 

likely present off the coast year-round. However, they are most often observed in the spring 

when their favorite food, the Portuguese man-of-war (Physalia physalis), is abundant. The 

loggerhead turtles are the most common species of sea turtles found washed ashore, either 
Appendix F 

NUREG-1937 F-16 February 2011 

dead or moribund (stranded), on the Texas coast each year (Sea Turtle Stranding and Salvage 

Network [STSSN] 2009). The greatest proportion of these deaths appears to be the result of 

accidental capture by shrimp trawlers, when caught turtles drown. There was no positive 

documentation of loggerheads nesting along the Texas shoreline before 1977 (Hildebrand 

1982). Nesting sites in Texas have been confirmed since 1999 when two loggerhead nests 

were verified and again in 2000 when five loggerhead nests were confirmed. Between 2001 

and 2005, up to five loggerhead nests per year have been recorded on the Texas coast (Corps 

2007). In 2006, one nest each was observed on Padre Island National Seashore and on South 

Padre Island (NPS 2009). Loggerhead populations have declined in Texas as they have 

worldwide. In the early 1900s, the species was taken in Texas for local consumption, and a few 

were marketed (Hildebrand 1982; Corps 2007). 

The loggerhead turtle has been found in the vicinity of Matagorda Bay. Within the study area, a 

loggerhead was killed in 1996 during dredging operations in the entrance channel of the 

Matagorda Shipping Channel. In 2006, two loggerheads were taken at the entrance channel of 

the shipping channel during dredging operations (Corps 2007). 

4.2 Green Turtle (Chelonia mydas) 

The green turtle has a smooth shell and is the largest of the hard-shelled sea turtles. Adult 

turtles can grow to be more than 3 ft long and can weigh 300 to 350 lb. They have a smooth 

carapace that can be shades of black, gray, green, and brown in starburst or irregular patterns. 

The adults are unique in that they are herbivorous, feeding on primarily seagrasses and algae. 

The nesting season for green turtles varies based on location, but, typically, nesting occurs from 

June through September. The females choose a variety of locations for nesting, from large 

open beaches to small cove beaches, and can lay from 110 to 130 eggs per clutch (NMFS and 

FWS 1991; Prichard and Mortimer 1999; Corps 2007; NMFS 2009c; TPWD 2009b). 

4.2.1 Reasons for Status 

On July 28, 1978, the green turtle was listed throughout its range as a threatened species 

except for Florida and the Pacific Coast of Mexico where it was listed as endangered 

(43 FR 32808). Green turtles have declined primarily due to their commercial harvest, where 

the eggs and adults are used for food and other body parts for leather and jewelry. The 

recovery of the species has been hindered by mortality of juveniles and adults caught 

incidentally by commercial shrimp trawling. Various other fishing operations have also affected 

recovery of the species (NMFS 2009c). Another threat to the survival of the species is epidemic 

outbreaks of fibropapillomatosis, or “tumor” infections, in green turtle populations, especially in 

Hawaii and Florida. The cause of these outbreaks is largely unknown, but the disease is 

thought to be caused by a viral infection (Barrett 1996; Corps 2007). 
Appendix F 

February 2011 F-17 NUREG-1937 

4.2.2 Habitat and Life History 

Adult green turtles are found primarily in shallow habitats such as lagoons, bays, inlets, shoals, 

estuaries, and other areas where they can find an abundance of marine algae and seagrasses. 

They often use coral reefs and rocky outcrops near where they feed as resting areas. Individual 

adults passing through open ocean are thought to be migrating to feeding grounds or nesting 

beaches (Meylan 1982). Hatchlings often can be found floating in rafts of sargassum (sea 

plants) in convergence zones. The adults are primarily herbivorous, while the juveniles 

consume more invertebrates. Green turtles consume primarily seagrasses, macroalgae, and 

other marine plants. Juveniles, and sometimes adults, also feed on mollusks, sponges, 

crustaceans, and jellyfish (Mortimer 1982; Corps 2007). 

Green turtles typically come to shore only for nesting activities. However, they sometimes can 

be seen basking on beaches in areas such as Hawaii and the Galápagos Islands. They prefer 

to enter high-energy beaches with an open offshore approach and deep sand, which may be 

coarse to fine with little organic content. Generally, green turtles nest at the same beach each 

year, which is apparently their natal beach (Balazs 1980; Prichard and Mortimer 1999; Corps 

2007; NMFS and FWS 2007b). 

4.2.3 Range 

The green turtle is a circumglobal species in tropical and subtropical waters. They are found in 

U.S. Atlantic waters around the U.S. Virgin Islands and Puerto Rico and the continental U.S. 

from Massachusetts to Texas. Major nesting activity occurs on Ascension Island, Aves Island 

(Venezuela), Costa Rica, and in Surinam. Relatively small numbers nest in Florida, with even 

smaller numbers in Georgia, North Carolina, and Texas (NMFS and FWS 1991; Hirth 1997; 

Corps 2007). 

4.2.4 Distribution in Texas and Presence in the Study Area 

The green turtle in Texas generally inhabit shallow bays and estuaries around seagrass beds. 

Small juvenile turtles have been observed in bays that are devoid of seagrasses and are 

thought to be feeding on benthic invertebrates and jellyfish. The worldwide decline in green 

turtles has also been seen in the population off of the Texas coast. During the mid- to late-19th 

century, there was a green turtle fishery in Matagorda Bay, Aransas Bay, and the lower Laguna 

Madre, although a few also came from Galveston Bay. By 1900, however, the fishery had 

collapsed. Still, some turtles continued to be collected commercially until 1935 (Hildebrand 

1982; Corps 2007). 

Green turtle nests are rare in Texas. Padre Island National Seashore has recorded from one to 

five nests per year since 1987, except in 1999 when no nests were found (NPS 2009). Florida 
Appendix F 

NUREG-1937 F-18 February 2011 

and Mexico are more common areas for green turtle nests. Adult green turtles found in Texas 

waters are thought to be in transit to distant feeding grounds or nesting beaches. Juvenile 

turtles found in Texas bays are thought to be using those waters as they move to other feeding 

grounds (Corps 2007). 

A study by Williams and Renaud (1998) in 1996-1997 found that four of the green turtles fitted 

with radio transmitters spent time in Lavaca Bay, western Matagorda Bay, and Powderhorn 

Bayou. A green turtle was recorded swimming in the Matagorda Ship Channel, and one was 

taken during dredging operations at the same location in 2004 (Corps 2007). In 2006, two 

green turtles were killed during maintenance dredging of the entrance and jetty channels of the 

Freeport Harbor Project. No green turtle nests have been recorded in the vicinity of the STP 

site (Corps 2007, 2008; NPS 2009). 

4.3 Leatherback Turtle (Dermochelys coriacea) 

Leatherback turtles are the largest and most distinctive of the living sea turtles. They reach a 

length of 78 in. and weigh more than 2000 lbs. Large, outstretched front flippers of the adult 

turtles may span 106 in. Lacking a keratinized shell, they are covered instead with a tough hide. 

Because they have physiological adaptations for heat conservation, leatherback turtles are 

more widely distributed as adults than other sea turtles in temperate and boreal waters 

throughout the world. However, all leatherbacks return to subtropical and tropical shores to nest 

(NMFS 2009d). 

4.3.1 Reasons for Status 

On June 2, 1970, the leatherback sea turtle was listed as endangered throughout its range 

(35 FR 8495). Critical habitat was designated for leatherbacks in the U.S. Virgin Islands 

(43 FR 43688 and 44 FR 17710). Estimating the world population of leatherbacks is based on 

nesting populations. Spotila et al. (1996) estimated the 1995 worldwide population of nesting 

female leatherbacks at 26,000 to 42,000. The decline of leatherbacks is attributable to 

overexploitation of the turtles for various uses, as well as incidental mortality from commercial 

shrimping and fishing activities. Leatherbacks have been known to be killed from complications 

after consuming litter, particularly plastics that are thought to be mistaken for jellyfish by the 

turtles. Other reasons for the decline of the turtles include collection of eggs for food and 

destruction or degradation of nesting habitat. Leatherbacks are probably more susceptible than 

other turtles to drowning in shrimp trawlers equipped with turtle excluder devices (TEDs) 

because the adults are too large to pass through the TED exit opening. To address this, NMFS 

established a leatherback conservation zone extending from Cape Canaveral to the VirginiaNorth Carolina border, and commercial shrimping activities can be closed when there is an 

abundance of leatherbacks in those vicinities (NMFS and FWS 1992a; Corps 2007). 
Appendix F 

February 2011 F-19 NUREG-1937 

4.3.2 Habitat and Life History 

The leatherback sea turtle is mainly pelagic, found in the open ocean, and seldom approaches 

land except for nesting. Leatherbacks are most often found in coastal waters only when nesting 

or when following populations of jellyfish. The turtles dive almost continuously, often to great 

depths. Their diet consists largely of jellyfish and sea squirts, but they are also known to 

consume sea urchins, squid, crustaceans, fish, blue-green algae, and floating seaweed 

(FWS 1980). Leatherback turtles typically nest on wide, long beaches with steep slope, deep, 

rock-free sand and an unobstructed deep water or mud-bottom approach (Prichard and 

Mortimer 1999; Corps 2007; TPWD 2009b). 

4.3.3 Range 

Leatherback turtles probably have the greatest range of all the sea turtle species. They are 

found in the Atlantic, Pacific and Indian Oceans; as far north as British Columbia, 

Newfoundland, Great Britain, and Norway; as far south as Australia, the Cape of Good Hope, 

and Argentina; and in other water bodies such as the Mediterranean Sea. Leatherbacks are 

known to migrate further and venture into colder water than any other marine reptile. Adult 

turtles appear to engage in routine migrations between boreal, temperate, and tropical waters, 

presumably to optimize both foraging and nesting opportunities. During the summer, 

leatherbacks tend to occur off the coast of the Atlantic states, from the Gulf of Maine south to 

the middle of Florida (Corps 2007; NMFS and FWS 2007c). 

Nesting areas are primarily in the tropical regions, including Malaysia, Mexico, French Guiana, 

Surinam, Costa Rica, and Trinidad. The turtles nest infrequently on the Atlantic and Gulf of 

Mexico coasts. The largest nesting assemblages occur in the U.S. Virgin Islands, Puerto Rico, 

and Florida (Corps 2007; NMFS and FWS 2007c). 

4.3.4 Distribution in Texas and Presence in the Study Area 

There have been no recorded leatherback nests in Texas since the 1930s when one was found 

on Padre Island. There have been occasional reports of leatherbacks feeding on jellyfish off 

Port Aransas and in the Brownsville area. No leatherback turtles have been taken by dredging 

activities in Texas. One leatherback was caught in 2003 by a relocation trawler in a shipping 

channel approximately 1.5 mi north of Aransas Pass (NMFS and FWS 1992a, 2007c; TPWD 

2007; Corps 2007, 2008). This species is unlikely to occur in the vicinity of the STP site. 

4.4 Hawksbill Turtle (Eretmochelys imbricata) 

The hawksbill turtle is a medium-sized tropical and subtropical species that inhabits the warm 

waters of the Atlantic, Pacific, and Indian Oceans (NMFS and FWS 1993). It is the most tropical 
Appendix F 

NUREG-1937 F-20 February 2011 

of the sea turtles and is restricted primarily to warmer waters more than the other four sea 

turtles found in the Gulf of Mexico. In U.S. territorial waters, hawksbills occur along the U.S. 

coast of south Texas and along the Gulf and Atlantic coasts of Florida. Adult nesting females 

have a carapace length of about 34 in. and weigh about 176 lbs. The largest hawksbill on 

record weighed 276 lbs. Hatchlings are about 1.7 in. long and weigh 0.5 to 0.7 oz (NMFS and 

FWS 1993). In the U.S. Caribbean and Florida Keys, overexploitation severely depleted 

hawksbills during the 20th century. Since banning sales of turtle shell products, hawksbills may 

no longer be in decline at present. However, data are not available to indicate that numbers are 

increasing (NMFS and FWS 1993, 2007d; NMFS 2009e). 

4.4.1 Reasons for Status 

On June 2, 1970, the hawksbill turtle was Federally listed as endangered throughout its range 

(35 FR 8495). Critical habitat for the species was designated in Puerto Rico (43 FR 22224 and 

63 FR 46693). The greatest threat to this species is commercial harvest of the turtle for its 

highly valued shell and as stuffed turtle curios. The hawksbill is also used in the manufacture of 

leather, oil, perfume, and cosmetics. Other threats to hawksbill turtles include destruction of 

breeding locations by beach development, incidental take in lobster and Caribbean reef fish 

fisheries, pollution by petroleum products (especially oil tanker discharges), entanglement in 

persistent marine debris, and predation on eggs and hatchlings (Corps 2007; NMFS 2009e). 

4.4.2 Habitat and Life History 

Hawksbills generally are found in coastal waters less than 70 ft deep, including coastal reefs, 

bays, rocky areas, passes, estuaries, and lagoons. Like loggerhead and green turtles, 

hatchlings are often found around sargassum rafts in the open ocean. Hawksbills reenter 

coastal waters as juveniles. Coral reefs are widely used for foraging on sponges by juveniles, 

subadults, and adults. In Texas, juvenile hawksbills are associated with stone jetties (FWS 

1980; Corps 2007; NMFS 2009e). 

Hawksbills are considered omnivorous, but they prefer invertebrates, especially encrusting 

organisms such as sponges, tunicates, bryozoans, mollusks, corals, barnacles, and sea 

urchins. Along the coast, they also consume algae, sea grasses, and mangroves. In open 

waters, the turtles consume jellyfish and fish. The young turtles appear to be more herbivorous 

than adults (Corps 2007; NMFS 2009e). 

Nesting typically is the only time hawksbills are found on shore. Hawksbills almost exclusively 

nest in the tropics on islands or the mainland. They are typically solitary nesters and prefer 

nesting on narrow beaches with reefs obstructing offshore approach (Prichard and Mortimer 

1999; Corps 2007). 
Appendix F 

February 2011 F-21 NUREG-1937 

4.4.3 Range 

Although it does occur in many temperate regions, the hawksbill turtle is probably the most 

tropical of all the marine turtles. Its range is circumtropical, occurring in tropical and subtropical 

seas of the Atlantic, Pacific, and Indian Oceans. The hawksbill turtle is widely distributed in the 

Caribbean Sea and western Atlantic Ocean, with representatives of at least some life history 

stages regularly occurring in southern Florida and the northern Gulf (especially Texas) and 

south to Brazil. In the continental U.S., the hawksbill sporadically nests in Florida. However, a 

major nesting beach exists on Mona Island, Puerto Rico. Small numbers of nests have been 

observed elsewhere in the western Atlantic, along the Gulf Coast of Mexico, the West Indies, 

and along the Caribbean coasts of Central and South America (NFMS and FWS 1993; Corps 

2007). 

4.4.4 Distribution in Texas and Presence in the Study Area 

Outside of Florida, Texas is the only state where hawksbills are encountered with any regularity. 

Most of these sightings are of post-hatchling and juvenile turtles around stone jetties. These 

small turtles probably traveled north from nesting beaches in Mexico. The first and only 

hawksbill nest recorded in Texas was in 1998 at Padre Island National Seashore (NMFS and 

FWS 1993, 2007d; Corps 2007, 2008; TPWD 2009b). This species may potentially occur in the 

vicinity of the STP site. 

4.5 Kemp’s Ridley Turtle (Lepidochelys kempii) 

The Kemp’s ridley turtle is one of the smallest living sea turtles. Adult females have shell 

lengths of 24 to 28 in., and they weigh 77 to 99 lb (NMFS and FWS 1992b). Pelagic-phase 

juvenile Kemp’s ridleys range in size from 2 to 8 in. in carapace length. Subadults are 8 to 24 

in. long, and mature adults generally are longer than 24 in. in carapace length (Marquez 1994). 

Kemp’s ridley turtles are distributed throughout the Gulf of Mexico and into the Atlantic Ocean. 

The center of their distribution is in the Gulf of Mexico. The Kemp’s ridley turtle is the most 

endangered sea turtle in the world (NMFS and FWS 1992b) and is listed as endangered 

throughout its range. From 1947 to 1985, the number of females nesting at the only significant 

Kemp’s ridley nesting beach dropped from more than 40,000 to as low as 702 (NMFS and FWS 

2007e). This is the most severe population decline documented for any species of sea turtles. 

Since the mid 1980s, there has been a noticeable increase in the number of nests. In 2003, an 

estimated 3,600 turtles produced over 8,000 nests (NMFS 2009f). While this trend is positive, 

the criteria for downlisting the status for Kemp’s ridley sea turtles under the ESA put forth in the 

recovery plan have not yet been met (NMFS and FWS 2007e). 
Appendix F 

NUREG-1937 F-22 February 2011 

4.5.1 Reasons for Status 

On December 2, 1970, the Kemp’s ridley turtle was listed as endangered throughout its range 

(35 FR 18320). Primarily, the decline of this species has been the result of human activities, 

including collection of eggs, fishing for juveniles and adults, killing adults for meat and other 

products, and direct take for indigenous use. Another major factor in the loss of the species is 

the high level of incidental takes by shrimp trawlers (NMFS and FWS 1992b; NMFS 2009f; 

Corps 2007). 

Campbell (1995) documented the loss of Kemp’s ridley turtles due to the consumption of debris 

on the Texas coast. Postmortem examinations of Kemp’s ridleys found stranded from 1986 

through 1988 revealed 54 percent (60 of the 111 turtles examined) had eaten some type of 

marine debris. The most commonly ingested debris included pieces of plastic bags, Styrofoam, 

plastic pellets, balloons, rope, and fishing line. Other debris was also found, such as glass, tar, 

and aluminum foil. Campbell speculated that the source of the debris was from offshore oil rigs, 

cargo ships, commercial and recreational fishing boats, research vessels, naval ships, and other 

vessels operating in the Gulf. 

Further threats to this species include collisions with boats, explosives used to remove oil rigs, 

and entrapment in coastal power plant intake pipes (Campbell 1995). Incidental takes of 

Kemp’s ridley turtles have happened in association with dredging operations, particularly with 

hopper dredges. Placement of dredged materials, degraded water quality/clarity, and altered 

current flow associated with dredging activities can also affect turtles through channelization of 

the inshore and nearshore areas degrading foraging and migratory zones (NMFS and FWS 

1992b). 

4.5.2 Habitat and Life History 

Kemp’s ridleys inhabit shallow coastal and estuarine waters, usually over sand or mud bottoms. 

Adult turtles are primarily shallow-water benthic feeders, where they forage on crabs, while 

juveniles feed on sargassum and other organisms found in the mass of plants (NMFS and FWS 

1992b). In some regions, juvenile and adult Kemp’s ridleys almost exclusively eat blue crabs. 

Other food items in the Kemp’s ridleys diet include shrimp, snails, bivalves, sea urchins, 

jellyfish, sea stars, fish, and occasional marine plants (Campbell 1995; Corps 2007). 

Nesting occurs in a highly synchronized manner with large numbers of females (called an 

“arribada”) coming ashore within a period of a few hours during daylight (Marquez 1994). 

Hatchlings migrate rapidly down the beach and out to sea, where they spend a period of 

perhaps two years in the pelagic zone. They are about 8 in. long at the end of the pelagic 

period. Little is known about the feeding behavior and food preferences of hatchling Kemp’s 

ridley turtles during their pelagic stage. During this period, they presumably feed on 
Appendix F 

February 2011 F-23 NUREG-1937 

zooplankton and floating matter, including sargassum weed and the associated biotic 

community. Following a pelagic feeding stage shortly after hatching and lasting for several 

months, the juvenile Kemp’s ridleys move into shallow coastal waters to feed and grow. The 

young subadults often forage in water less than 3 ft deep, but they tend to move into deeper 

water as they grow. Because of their preference for crabs and other primarily shallow-water 

demersal prey, juvenile and adult Kemp’s ridley turtles concentrate in coastal waters less than 

30 ft deep throughout their range. They make long dives to the bottom and may feed on the 

bottom for an hour or more at a time (Turtle Expert Working Group 1998). 

4.5.3 Range 

Nearly all reproduction of Kemp’s ridleys takes place along a single 9.3-mi stretch of beach near 

Rancho Nuevo, Tamaulipas, Mexico, about 200 mi south of Brownsville, Texas (Marquez 1994). 

A small number of nests have been found in Texas and along the Mexican coast of the Gulf of 

Mexico between Playa Lauro Villar, Tamaulipas, Mexico and Isla Aguada, Campeche, Mexico, 

but nothing that reaches the level of nests at Rancho Nuevo. 

4.5.4 Distribution in Texas and Presence in the Study Area 

Kemp’s ridley turtles occur in Texas in small numbers and, when observed, are probably in 

transit between crustacean-rich feeding areas in the northern Gulf and breeding grounds in 

Mexico. As mentioned earlier, the number of nesting Kemp’s ridley turtles has been increasing, 

which may be a sign of the earliest stages of recovery for the species. The species has nested 

sporadically in Texas in the last 50 years with reports increasing over the last 12 years from four 

nests in 1995 to 102 nests in 2006 (a majority of the nests are located at Padre Island National 

Seashore). There was one nest recorded on Matagorda Peninsula in 2002 and four on 

Matagorda Island in 2004. The increase in nests is related to the success of breeding programs 

in Texas. A study by Williams and Renaud (1998) in 1996 found that seven of the Kemp’s ridley 

turtles fitted with radio transmitters spent most of their time within 4 mi of the western shoreline 

of Matagorda Bay, but they also swam to Lavaca Bay, Carancahua Bay, Tres Palacios Bay, and 

Powderhorn Bayou. Two Kemp’s ridleys were taken at the entrance of the Matagorda Ship 

Channel in 2006 during dredging operations (NMFS and FWS 1992b, 2007e; Corps 2007, 2008; 

TPWD 2009b). Of all the turtles, Kemp’s ridleys are likely to be the most common in the vicinity 

of the STP site. 

5.0 Potential Environmental Effects of the 

Proposed Actions 

This section describes potential impacts from construction of the proposed Units 3 and 4 at the 

STP site to the sea turtle species found in the Gulf of Mexico and on the coast of Texas. As 
Appendix F 

NUREG-1937 F-24 February 2011 

stated above, impacts from operation of the proposed new units are highly unlikely to affect sea 

turtles as they do not swim upstream in the Colorado River to STP site. 

The potential impacts to Federally threatened and endangered sea turtle species resulting from 

the barging of heavy equipment and bulk commodities to the STP site are associated with 

collisions between the vessels and the turtles, capture in the turbine washes of the vessels, and 

potential disorientation from lights on the vessels. Sea turtles may be present at certain times of 

the year when barging traffic is moving through the Port of Freeport, Matagorda Ship Channel, 

and the GIWW. The five species of sea turtles discussed above would all be exposed to these 

potential impacts to degrees relative to their occurrence in Texas waters. There are no areas 

designated as critical habitat near the STP site (Corps 2007, 2008; NMFS and FWS 2007a, b, c, 

d, e; NMFS 2009a). 

Loggerhead, green and Kemp’s ridley turtles have all been recorded in the area where barging 

traffic for STP equipment and material would be expected to travel. Kemp’s ridley turtles have 

nested in the vicinity, and all the other sea turtle species are known to have nested to the south 

of the study area. An estimate of the species of sea turtles in the study area can be obtained 

from the STSSN, which tracks, collects, and documents standing of marine turtles in the Gulf of 

Mexico. STSSN divides the Gulf into zones, and the study area is included in zone 19, which 

extends from Freeport to Port Aransas, Texas. From 1986 through 2007, STSSN reported a 

total of 1051 strandings in zone 19: 523 loggerhead, 285 Kemp’s ridley, 105 green, 29 

leatherback, 15 hawksbill, and 94 unknown species (STSSN 2009). 

Increased vessel activity could affect sea turtles in the area. The most common effect from 

vessel activity on sea turtles is from propeller and boat strikes on the turtles. Direct strikes on 

the turtles can kill or maim the animals. The wash from the propellers of the barges is also 

known to entrain turtles and either temporarily disorient the organisms or potentially drown 

them. Lights from the vessels are thought to disorient turtles, particularly hatchlings. However, 

barging traffic to STP is not likely to happen in the dark (Corps 2007, 2008; STPNOC 2009b). 

The wash from moving barges could create flows that would disrupt food sources for the sea 

turtles. Organisms in the open water would be disrupted as the barge moved through the area, 

but the effects would be temporary. Increased vessel movements in narrow channels could 

erode shorelines and increase turbidity that could settle on benthic organisms, which could 

result in diminished food supply for the turtles. Barge traffic would be restricted to channels 

where traffic is common, and these areas are limited in comparison to the overall area of the 

bays and waterways where turtles can forage. While turtles can forage elsewhere, sea turtles 

that are swimming in vessel channels would be adversely affected if they interact with barges 

transporting materials and equipment to the STP site. 
Appendix F 

February 2011 F-25 NUREG-1937 

6.0 Cumulative Impacts to Federally Protected Species 

Barging of heavy equipment and bulk commodities would add to the vessel traffic through the 

Port of Freeport, Matagorda Ship Channel, and the GIWW in the study area. STPNOC has not 

finalized the plans for shipping equipment and material to the STP site. While traffic in these 

navigation areas would increase during the building of proposed Units 3 and 4, the number of 

trips for the barges carrying both heavy equipment and construction materials would not add 

significantly to the existing traffic in the area (STPNOC 2009b). 

Barging traffic may add cumulatively to the impacts on sea turtles from other activities within the 

study area. Sea turtles are affected by numerous activities that are common in the study area, 

including dredging, commercial fishing, vessel traffic, development along nesting beaches, 

pollution, and poaching. The Corps is responsible for maintaining over 12,000 mi of waterways 

throughout the United States for commercial and recreational vessel traffic, water supply, 

regional development, and national security. The three primary types of dredges used for 

maintaining navigational waters are cutterhead pipeline, mechanical, and hopper dredges. Sea 

turtles are most likely to be harmed or killed by hopper dredges. Based on the Corps’ Sea 

Turtle Data Warehouse, there have been 85 incidental takes of sea turtles since 1995 within the 

Galveston District from dredging activities, primarily loggerhead, green and Kemp’s ridley sea 

turtles. The Corps and the dredging industry continue to work on protocols, operational 

methods, and modifying dredging equipment to reduce impacts to sea turtles (Corps 2010). 

Some of these improvements include a plow-like deflector designed to move the turtles away 

from the suction of the draghead (NMFS and FWS 2007e). 

Along the proposed barging routes for transporting heavy equipment and bulk commodities for 

the construction of proposed Units 3 and 4, there are plans for dredging and changing the 

shipping channels at the Port of Freeport and Matagorda Bay. The Corps has prepared BAs for 

both of these activities and evaluated the effects on sea turtles from the use of pipeline and 

hopper dredges, sedimentation, loss of benthic habitat, and disorientation from lights on 

vessels. The Corps concluded these activities may affect the species, and hopper dredging 

would adversely affect the sea turtles. The Corps and NMFS have identified “reasonable and 

prudent measures” to reduce the potential for affecting sea turtles from the proposed activities 

at the Port of Freeport (Corps 2008) and will likely agree to similar measures for the Matagorda 

Ship Channel (Corps 2007). These measures include the implementation of a sea turtle 

avoidance plan. For more than a decade, these measures have been incorporated in the 

Corps’ regulatory and civil works projects throughout the Gulf of Mexico. Barging traffic to STP 

during the dredging activities planned by the Corps may create more distractions for the sea 

turtles in the area. 

Commercial fishermen in the bay systems of Texas must use approved TEDs to minimize 

collection of turtles in their trawl equipment (TPWD 2009c). Kemp’s ridley sea turtles are 
Appendix F 

NUREG-1937 F-26 February 2011 

particularly susceptible to being caught in trawl nets because they inhabit shallow waters. In the 

past, shrimp trawls were known to kill thousands of Kemp’s ridley sea turtles each year before 

the implementation of TEDs, which occurred in 1990 for the Texas commercial fishing industry 

(TPWD 2009d). In addition, in 2000 Texas Parks and Wildlife Commission established 

seasonal closure for shrimping from the beach out to five nautical mi from December 1 through 

July 15, which is the season when adult Kemp ridleys use those waters for mating, nesting, 

foraging and migrating (NMFS and FWS 2007e). Other sea turtle species also benefit from the 

implementation of TEDs and seasonal closure of the fishing industry when they are prevalent. 

Vessel traffic in the area includes commercial and recreational vessels. NMFS has identified 

that these activities have an adverse impact on sea turtles from propeller and boat strike 

damage (Singel et al. 2003; NMFS and FWS 2007e). However, the magnitude of these events 

in the study area is not known (Corps 2008). 

Development in the study area can lead to loss of nesting habitat, increased pollution, increased 

recreational activities, etc. As mentioned above, there have been few sea turtles nesting in the 

Matagorda Bay area. Increased development of Matagorda Peninsula could remove 

appropriate habitat for future nesting activity. Lighting of homes and on roadways can disorient 

adult females as well as hatchlings and diminish the success of future nesting opportunities. 

Turtles can be harmed through ingestion and entanglement with debris washed into waters from 

developed areas or dropped overboard. Coastal runoff can contribute to poor water quality that 

affects the food for turtles as well as potentially harming them. Organochlorine compounds, 

heavy metals, and petroleum products are all known to be detrimental to turtles either directly or 

indirectly through bioaccumulation of the toxins in the food web (NMFS and FWS 2007e). 

Power plants and other large industrial systems in coastal waters also have the potential to 

affect sea turtles. The intake systems for cooling water at power plants have attracted and 

impinged turtles. Most of these power plants are located along the coastal area where turtles 

are foraging and nesting. It is unlikely that the operation of the nuclear units at the STP site 

would harm sea turtles because the intake system is located upstream in the Colorado River 

and turtles have not been reported in that area. Other industrial ports can attract turtles and 

they can be harmed by vessels approaching the port. 

7.0 Conclusions 

The potential impacts of barging heavy equipment and material for proposed Units 3 and 4 to 

the STP site on Federally protected sea turtle species in the vicinity of the site have been 

evaluated. The known distributions and records of those species and the potential ecological 

impacts of barging to the species, their habitats, and their prey have been considered in this BA. 
Appendix F 

February 2011 F-27 NUREG-1937 

Based on this review, the NRC and the Corps conclude that the overall effects of barging heavy 

equipment and material to the STP site for construction of the proposed Units 3 and 4, may 

affect but would not be likely to adversely affect or jeopardize the continued existence of the 

loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and Kemp’s 

ridley sea turtle in the Gulf of Mexico and on the coast of Texas. 

8.0 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” 

35 FR 8495. “Endangered Species Conservation Act of 1969.” Federal Register. U.S. 

Department of the Interior. 

35 FR 18320. December 2, 1970. “Endangered Species Conservation Act of 1969.” Federal 

Register. U.S. Department of the Interior. 

43 FR 22224. May 24, 1978. “Proposed Determination of Critical Habitat for the Hawksbill Sea 

Turtle.” Federal Register. U.S. Department of the Interior.

43 FR 32808. July 28, 1978. “Listing and Protecting Loggerhead Sea Turtles as ‘Threatened 

Species’ and Populations of Green and Olive Ridley Sea Turtles as ‘Threatened Species or 

Endangered Species’.” Federal Register. U.S. Department of the Interior. 

43 FR 43688. September 26, 1978. “Determination of Critical Habitat for the Leatherback Sea 

Turtle.” Federal Register. U.S. Department of the Interior. 

44 FR 17710. March 23, 1979. “Determination of Critical Habitat for the Leatherback Sea 

Turtle.” Federal Register. U.S. Department of the Interior. 

63 FR 46693. September 2, 1998. “Designated Critical Habitat; Green and Hawksbill Sea 

Turtles.” Federal Register. U.S. Department of the Interior. 

72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

Federal Register. U.S. Nuclear Regulatory Commission. 
Appendix F 

NUREG-1937 F-28 February 2011 

72 FR 72774. December 21, 2007. “South Texas Project Nuclear Operating Company South 

Texas Project Site, Units 3 & 4; Notice of Intent To Prepare an Environmental Impact Statement 

and Conduct Scoping Process.” Federal Register. U.S. Nuclear Regulatory Agency. 

Balazs, G. 1980. Synopsis of biological data on the green turtle in the Hawaiian Islands. 

NOAA Technical Memorandum. NMFS-SWFC-7, U.S. Department of Commerce, Miami, 

Florida. 

Barrett, S. 1996. Disease threatens green sea turtles. Endangered Species Bulletin 21(2):8–9. 

Campbell, L. 1995. Endangered and threatened animals of Texas, their life history and 

management. Texas Parks and Wildlife Department, Resource Protection Division, 

Endangered Resources Branch, Austin, Texas. 

Clean Water Act. 33 USC 1251, et seq. 

Endangered Species Act of 1973, as amended (ESA). 16 USC 1531, et seq. 

ENSR Corporation (ENSR). 2008a. Aquatic Ecology – Colorado River Monitoring Report, Unit 

3 and 4 Licensing Project. Houston, Texas. 

ENSR Corporation (ENSR). 2008b. Aquatic Ecology – Main Cooling Reservoir and Circulating 

Water Intake Structure Study, Unit 3 and 4 Licensing Project. Houston, Texas. 

Hildebrand, H. 1982. “A historical review of the status of sea turtle populations in the western 

Gulf of Mexico.” In: K. Bjorndal, ed., Biology and conservation of sea turtles. Smithsonian 

Institution Press, Washington, D.C. 

Hirth, H.F. 1997. “Synopsis of the biological data on the green turtle Chelonia mydas (Linnaeus 

1758).” Biological Report 97 (1). U.S. Fish and Wildlife Service, Washington, D.C. 

Marquez, M.R. 1994. “Synopsis of Biological Data on the Kemp’s Ridley Turtle, Lepidochelys 

kempi (Garman, 1880).” NOAA Technical Memorandum NMFS-SEFSC-343, U.S. Department 

of Commerce, Miami, Florida. 

Meylan, A. 1982. “Sea turtle migration – evidence from tag returns.” In: K. Bjorndal, ed., 

Biology and Conservation of Sea Turtles. Smithsonian Institution Press, Washington, D.C. 

Mortimer, J.A. 1982. “Feeding ecology of sea turtles.” In: K. Bjorndal, ed., Biology and 

conservation of sea turtles. Smithsonian Institution Press, Washington, D.C. 

National Marine Fisheries Service (NMFS). 2009a. “Endangered and Threatened Species and 

Critical Habitats under the Jurisdiction of the NOAA Fisheries Service: Texas.” NOAA Fisheries 
Appendix F 

February 2011 F-29 NUREG-1937 

Service, Southeast Regional Office, Saint Petersburg, Florida. Accessed March 13, 2009 at 

http://sero.nmfs.noaa.gov/pr/esa/specieslst.htm. 

National Marine Fisheries Service (NMFS). 2009b. “Loggerhead Turtle (Caretta caretta).” 

Accessed November 2, 2009 at http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm. 

Accession No. ML100650007. 

National Marine Fisheries Service (NMFS). 2009c. “Green Turtle (Chelonia mydas).” 

Accessed November 2, 2009 at http://www.nmfs.noaa.gov/pr/species/turtles/green.htm. 

Accession No. ML100650007. 

National Marine Fisheries Service (NMFS). 2009d. “Leatherback Turtle (Dermochelys 

coriacea).” Accessed November 2, 2009 at 

http://www.nmfs.noaa.gov/pr/species/turtles/leatherback.htm. Accession No. ML100650007. 

National Marine Fisheries Service (NMFS). 2009e. “Hawksbill Turtle (Eretmochelys imbricata).” 

Accessed November 2, 2009 at http://www.nmfs.noaa.gov/pr/species/turtles/hawksbill.htm. 

Accession No. ML100650007. 

National Marine Fisheries Service (NMFS). 2009f. “Kemp’s Ridley Turtle (Lepidochelys 

kempii).” Accessed November 2, 2009 at 

http://www.nmfs.noaa.gov/pr/species/turtles/kempsridley.htm. Accession No. ML100650007. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1991. 

“Recovery Plan for U.S. Population of Atlantic Green Turtle.” National Marine Fisheries Service, 

Washington, D.C. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1992a. 

“Recovery Plan for Leatherback Turtles in the U.S. Caribbean, Atlantic and Gulf of Mexico.” 

National Marine Fisheries Service, Washington, D.C. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1992b. 

“Recovery Plan for the Kemp’s Ridley Sea Turtle (Lepidochelys kempii).” National Marine 

Fisheries Service, St. Petersburg, Florida. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1993. 

“Recovery Plan for Hawksbill Turtles in the U.S. Caribbean Sea, Atlantic Ocean, and Gulf of 

Mexico.” National Marine Fisheries Service, St. Petersburg, Florida. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007a. 

Loggerhead Sea Turtle (Caretta caretta), 5-Year Review: Summary and Evaluation. National 
Appendix F 

NUREG-1937 F-30 February 2011 

Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

Jacksonville, Florida. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007b. 

Green Sea Turtle (Chelonia mydas) 5-Year Review: Summary and Evaluation. National Marine 

Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, Jacksonville, 

Florida. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007c. 

Leatherback Sea Turtle (Dermochelys coriacea) 5-Year Review: Summary and Evaluation. 

National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

Jacksonville, Florida. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007d. 

Hawksbill Sea Turtle (Eretmochelys imbricata) 5-Year Review: Summary and Evaluation. 

National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

Albuquerque, New Mexico. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007e. 

Kemp's Ridley Sea Turtle (Lepidochelys kempii) 5-Year Review: Summary and Evaluation. 

National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

Albuquerque, New Mexico. 

National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2008. 

“Recovery Plan for the Northwest Atlantic Population of the Loggerhead Sea Turtle (Caretta 

caretta).” Second Revision. National Marine Fisheries Service, Silver Spring, Maryland. 

Pritchard, P.C.H. 1996. “Evolution, phylogeny and current status.” In: Lutz, P.L., Musick, J.A. 

(Eds.), The Biology of Sea Turtles. CRC Press, Florida. 

Pritchard, P.C.H., and J.A. Mortimer. 1999. Taxonomy, External Morphology, and Species 

Identification. In: Eckert, K.L., K.A. Bjorndal, F.A. Abreu-Grobois, and M. Donnelly (Editors), 

Research and Management Techniques for the Conservation of Sea Turtles. IUCN/SSC Marine 

Turtle Specialist Group Publication No. 4. Consolidated Graphic Communications, Blanchard, 

Pennsylvania. 

Rivers and Harbors Appropriation Act of 1899, as amended. 33 USC 403, et seq. 

Sea Turtle Stranding and Salvage Network (STSSN). 2009. “Monthly turtle stranding by year, 

species, and state.” Accessed January 28, 2010 at 

http://www.sefsc.noaa.gov/seaturtleSTSSN.jsp. Accession No. ML100650007. 
Appendix F 

February 2011 F-31 NUREG-1937 

Singel, K., T. Redlow, and A. Foley. 2003. “Twenty-two years of data on sea turtle mortality in 

Florida: Trends and factors.” In: J.A. Seminoff, compiler, Proceedings of the Twenty-Second 

Annual Symposium on Sea Turtle Biology and Conservation. NOAA Technical Memorandum 

NMFS-SEFSC-503, U.S. Department of Commerce, Miami, Florida. 

South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

City, Texas. Accession No. ML092931600. 

South Texas Project Nuclear Operating Company (STPNOC). 2009b. Letter from Scott Head 

(STPNOC, Manager, Regulatory Affairs, South Texas Project, Units 3 and 4) to U.S. Nuclear 

Regulatory Commission dated September 14, 2009 in response to NRC letter dated August 14, 

2009, "South Texas Project Units 3 and 4, Docket Nos. 52-012 and 52-013, Response to 

Requests for Additional Information.” Accession No. ML092580491. 

Spotila, J.R., A.E. Dunham, A.J. Leslie, A.C. Steyermark, P.T. Plotkin, and F.V. Paladino. 1996. 

Worldwide population decline of Dermochelys coriacea: Are leatherback turtles going extinct? 

Chelonian Conservation and Biology 2(2):209–222. 

Texas Parks and Wildlife Department (TPWD). 2007. “Leatherback Sea Turtle (Dermochelys 

coriacea).” Texas Parks and Wildlife Department, Austin, Texas. Accessed November 8, 2009 

at 

http://www.tpwd.state.tx.us/huntwild/wild/species/endang/animals/reptiles_amphibians/lethback.

phtml. Accession No. ML100650007. 

Texas Parks and Wildlife Department (TPWD). 2009a. Telephone call to Tonya Wiley (Texas 

Parks and Wildlife Department, Fisheries Outreach Specialist, Coastal Fisheries Division) from 

Christa Woodley (Pacific Northwest National Laboratory, Research Scientist), “Smalltooth 

sawfish in southern Texas”, March 18, 2009. 

Texas Parks and Wildlife Department (TPWD). 2009b. “Wildlife Fact Sheets.” Texas Parks 

and Wildlife Department, Austin, Texas. Accessed January 22, 2010 at 

http://www.tpwd.state.tx.us/huntwild/wild/species. Accession No. ML100650007. 

Texas Parks and Wildlife Department (TPWD). 2009c. “2009-2010 Texas Commercial Fishing 

Guide.” Texas Parks and Wildlife Department, Austin, Texas. 

Texas Parks and Wildlife Department (TPWD). 2009d. “Kemp’s Ridley Sea Turtle.” Texas 

Parks and Wildlife Department, Austin, Texas. Accessed December 1, 2009 at 

http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_bk_w7000_0013_kemps_ridley_s

ea_turtle.pdf. Accession No. ML100650007. 
Appendix F 

NUREG-1937 F-32 February 2011 

Turtle Expert Working Group. 1998. “An Assessment of the Kemp’s Ridley (Lepidochelys 

kempii) and Loggerhead (Caretta caretta) Sea Turtle Populations in the Western North Atlantic.” 

NOAA Technical Memorandum NMFS-SEFSC-406, U.S. Department of Commerce, Miami, 

Florida. 

U.S. Army Corps of Engineers (Corps). 2005. Galveston District Projects: Mouth of the 

Colorado River. U.S. Army Corps of Engineers, Galveston District, Galveston, Texas. 

Accessed December 16, 2009 at 

http://www.swg.usace.army.mil/items/coloradoriver/default.asp. Accession No. ML100650007. 

U.S. Army Corps of Engineers (Corps). 2007. Draft Environmental Impact Statement for 

Calhoun County Navigation District’s Proposed Matagorda Ship Channel Improvement Project 

Calhoun and Matagorda Counties, Texas. Document No. 060146, U.S. Army Corps of 

Engineers, Galveston District, Galveston, Texas. 

U.S. Army Corps of Engineers (Corps). 2008. Final Environmental Impact Statement for the 

Proposed Port Freeport Channel Widening, Brazoria County, Texas. U.S. Army Corps of 

Engineers, Galveston District, Galveston, Texas. 

U.S. Army Corps of Engineers (Corps). 2010. “USACE Sea Turtle Data Warehouse.” U.S. 

Army Corps of Engineers, Galveston District, Galveston, Texas. Accessed January 29, 2010 at 

http://el.erdc.usace.army.mil/seaturtles. Accession No. ML100650007. 

U.S. Fish and Wildlife Service (FWS). 1980. “Selected vertebrate endangered species of the 

seacoast of the United States.” FWS/OBS-80/01. U.S. Fish and Wildlife Service, Biological 

Services Program, Washington, D.C. 

U.S. National Park Service (NPS). 2009. “Padre Island National Seashore: Current Sea Turtle 

Nesting Season.” National Park Service, U.S. Department of Interior. Accessed November 8, 

2009 at http://www.nps.gov/pais/naturescience/current-season.htm. Accession No. 

ML100650007. 

U.S. Nuclear Regulatory Commission (NRC). 1975. Final Environmental Statement Related to 

the Proposed South Texas Project Units 1 & 2. NUREG-75/019, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1986. Final Environmental Statement Related to 

the Operation of South Texas Project, Units 1 and 2. NUREG-1171, Washington, D.C. 

Wilber, D.H. and R. Bass. 1998. “Effect of the Colorado River Diversion on Matagorda Bay 

Epifauna.” Coastal and Shelf Science 47:309-318. 
Appendix F 

February 2011 F-33 NUREG-1937 

Williams, J.A., and M.L. Renaud. 1998. “Tracking of Kemp’s ridley (Lepidochelys kempii) and 

green (Chelonia mydas) sea turtles in the Matagorda Bay System, Texas.” In: S. Epperly and J. 

Braun (compilers), Proceedings of the 17th Annual Sea Turtle Symposium. NOAA Technical 

Memorandum NMFS SEFSC-415, U.S. Department of Commerce, Miami, Florida. 
Appendix F 

NUREG-1937 F-34 February 2011 
Appendix F 

February 2011 F-35 NUREG-1937 
Appendix F 

NUREG-1937 F-36 February 2011 
Appendix F 

February 2011 F-37 NUREG-1937 
Appendix F 

NUREG-1937 F-38 February 2011 
Appendix F 

February 2011 F-39 NUREG-1937 

Essential Fish Habitat 

Assessment 

National Marine Fisheries Service

South Texas Project Electric Generating Station Units 3 and 4 

U.S. Nuclear Regulatory Commission Combined License Application 

Docket Nos. 52-012 and 52-013 

U.S. Army Corps of Engineers Permit Application 

Matagorda County, Texas 

March 2010

U.S. Nuclear Regulatory Commission 

Rockville, Maryland 

U.S. Army Corps of Engineers 

Galveston District 
Appendix F 

NUREG-1937 F-40 February 2011

1.0 Introduction 

The 1996 amendments to the Magnuson-Stevens Fishery Conservation and Management Act 

(MSA) (16 USC 1801 et seq.) and amendments by the Sustainable Fisheries Act of 1996 

(Public Law 104-297) recognized that habitat is important for the protection of healthy fisheries 

and established procedures to identify, conserve, and enhance essential fish habitat (EFH) for 

Federally managed fish and shellfish species (GMFMC 2004). EFH is defined as “those waters 

and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity” (16 USC 

1801 et seq.; NMFS 2004). Federal agencies must consult with the Secretary of Commerce on 

all actions or proposed actions that are authorized, funded, or undertaken by the agency that 

may adversely affect EFH (NMFS 2004). Identifying EFH is an essential component in the 

development of fishery management plans (FMPs) to evaluate the effects of habitat loss or 

degradation on fishery stocks and to take actions to mitigate such damage. This responsibility 

was expanded by the National Marine Fisheries Service (NMFS) to ensure additional habitat 

protection (NMFS 1999). The consultation requirements of Section 305(b) of the MSA provide 

that Federal agencies consult with the Secretary of Commerce on all actions, or proposed 

actions, authorized, funded, or undertaken by the agency, that may adversely affect EFH. 

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from STP Nuclear 

Operating Company (STPNOC) for two combined construction permits and operating licenses 

(combined licenses or COLs) to construct and operate two new nuclear reactors at the South 

Texas Project Electric Generating Station (STP) site in Matagorda County, Texas, 

approximately 12 mi south-southwest of Bay City, Texas (Figure 1). The STP site is located 

adjacent to the Colorado River, upstream of its confluence with the Gulf Intracoastal Waterway 

(GIWW). STPNOC submitted the COL application to the NRC on September 20, 2007. The 

STP site and existing facilities (Units 1 and 2) are owned by NRG South Texas LP (NRG), City 

Public Service Board of San Antonio, Texas (CPS Energy), and the City of Austin, Texas. 

STPNOC plans for the proposed STP Unit 3 to be owned by Nuclear Innovation North America 

(NINA) South Texas 3 LLC and CPS Energy, and the proposed STP Unit 4 to be owned by 

NINA South Texas 4 LLC and CPS Energy (STPNOC 2009a). Concurrent with the NRC’s 

review, the U.S. Army Corps of Engineers (Corps) is reviewing STPNOC’s application for a 

Department of the Army (DA) Permit pursuant to Section 10 of the Rivers and Harbors 

Appropriation Act of 1899 (33 USC Sec. 403) and Section 404 of the Clean Water Act (CWA) 

(33 USC 1344) to perform site preparation activities and construct supporting facilities for two 

proposed new nuclear reactors at the STP site (Units 3 and 4). The Corps is a cooperating 

agency with the NRC to ensure that the information presented in the environmental impact 

statement (EIS) is adequate to fulfill the requirements of Corps regulations; the CWA Section 

404(b)(1) Guidelines, which contain the substantive environmental criteria used by the Corps in 

evaluating discharges of dredged or fill material into waters of the United States; and the Corps 

public interest review process. The NRC and the Corps have formed a combined review team 
Appendix F 

February 2011 F-41 NUREG-1937 

Figure 1. Location of the STP Site and General Land Use Classification for the Region 

and prepared this EFH assessment to support their joint consultation with the NMFS in 

accordance with the MSA. The Corps permit decision will be made following issuance of the 

final EIS for building the two new reactors at the STP site. 

The proposed project has the potential to cause temporary and permanent adverse impacts to 

spawning, nursery, forage, and shelter activities and habitats. The review team has evaluated 

potential impacts on the designated EFH and Federally-managed fish and shellfish species in 

the vicinity of STP based on information from communications with the NMFS (Southeast 

Regional Office, Habitat Conservation Division, Gulf Branch) and review of information on the 

Gulf of Mexico Fishery Management Council’s final EIS on the generic EFH amendments 

(GMFMC 2004). In addition, the EFH mapper tool was used to visualize the extent of potential 

designated EFH in the vicinity of the STP site, with an understanding that the area may be 

within known areas of spatial data quality issues (NMFS 2009). Matagorda Bay, the GIWW, 

and the Colorado River extending up to the bridge at FM 521 (at approximately navigable mile 

marker [NMM] 10, upstream of the confluence of the Colorado River and the GIWW) are within 
Appendix F 

NUREG-1937 F-42 February 2011

Ecoregion 5 of the designated EFH by the Gulf of Mexico Fishery Management Council’s FMP 

(GMFMC 2004; NMFS 2009). Ecoregion 5 extends from Freeport, Texas to the Mexico border. 

FMPs for coastal migratory pelagics, reef fish, red drum, shrimp, and stone crab fisheries 

include the Colorado River, the GIWW and Matagorda Bay within the vicinity of STP include 

coastal migratory pelagic, reef fish, red drum, shrimp, and stone crab (GMFMC 2004). This 

EFH assessment examines the potential impacts of the proposed actions on eight species: king 

mackerel (Scomberomorus cavalla), Spanish mackerel (S. maculates), gray snapper (Lutjanus 

griseus), red drum (Sciaenops ocellatus), brown shrimp (Farfantepenaeus aztecus), pink shrimp 

(F. duorarum), white shrimp (Litopenaeus setiferus), and Gulf stone crab (Menippe adina). 

These species are described in Section 4.0, and the impacts to them and their EFH, including 

their prey, are discussed in Section 5.0. 

2.0 STP Site Description 

The 12,220-ac STP site currently contains two pressurized water reactors (Units 1 and 2) and 

their associated facilities, which occupy approximately 300 ac (Figure 2). Existing Units 1 and 2 

share a 7000-ac Main Cooling Reservoir (MCR). Approximately 58 percent of the 12,220-ac 

STP site is covered in water (STPNOC 2009a). The MCR is an engineered cooling reservoir 

originally sized for four nuclear units and currently dissipates heat as part of a closed-cycled 

cooling system for the existing Units 1 and 2. Water loss from the MCR through evaporation, 

seepage, and discharge is made up from the Colorado River. Colorado River water is pumped 

from the Reservoir Makeup Pumping Facility (RMPF) into the MCR. Operation of the RMPF 

requires periodic maintenance dredging of the river in the immediate vicinity. When the total 

dissolved solids concentration in the MCR exceeds operating criteria, water is released through 

a discharge structure on the Colorado River downstream from the RMPF. However, STPNOC 

has only discharged water from the MCR into the Colorado River once during operation of Units 

1 and 2 (STPNOC 2009a). There is a barge slip near the downstream shoreline of the RMPF 

that was used for the construction of Units 1 and 2 and could be required in the future for 

continued operation of Units 1 and 2. Both existing units would continue to operate during the 

site preparation activities, construction, and operation of the proposed Units 3 and 4, and the 

proposed two new units would share many of the same systems for cooling, including the use of 

the existing RMPF, MCR, and discharge structure, and transmission of power. 
Appendix F 

February 2011 F-43 NUREG-1937 

A diverse aquatic community has developed over time since the construction of the MCR. The 

organisms are likely survivors of entrainment at the RMPF from the Colorado River, but it is 

unclear if these organisms are reproducing in the MCR. The organisms are not available for 

harvest as there is no public access to the MCR and STPNOC has only evaluated the aquatic 

community in the MCR twice (during an employee fishing tournament in 1994 and during an 

aquatic community survey during 2007-2008) (ENSR 2008a; STPNOC 2009a). For the purpose 

of this assessment and consultation, the entrained aquatic community will be considered lost to 

the environment and, therefore not evaluated further. Within the vicinity of the STP site, the 

major aquatic communities occur in the Colorado River, Matagorda Bay and the associated 

GIWW (Figure 3). The segment of the Colorado River adjacent to the STP site is used for 

recreational boating and fishing, as well as shipping to upstream ports. Matagorda Bay is used 

for commercial fishing and shipping as well as for recreational activities. The GIWW is used for 

shipping as well as for some recreational activities. Designated EFH occurs in the lower 

Colorado River, Matagorda Bay, and the GIWW, but there are no habitat areas of particular 

concern in any of those water bodies (GMFMC 2004). 

2.1 Colorado River 

The Colorado River is one of the largest river systems in Texas. The river is approximately 

862 mi long, extending from the high plains to the coastal marshes in Matagorda County. The 

segment of the river near the STP site, between Bay City and the GIWW, is a diverse, tidal, 

fluvial system that meanders through the coastal plain providing freshwater, sediments, and 

nutrients to Matagorda Bay (ENSR 2008a). The substrate and bathymetry of the Colorado 

River from the RMPF to the confluence with the GIWW is not well characterized. The Corps’ 

Galveston District reported in December 2009 that the Colorado River Channel from navigable 

mile 0 (GIWW) to the turning Basin near Bay City had a minimum width of 100 ft, minimum 

depth of 9 ft. In the vicinity of the STP site, the left quarter, middle half and right quarter channel 

had average depths of 2.1 ft, 3.8 ft, and 4.5 ft, respectively (all measurements were provided at 

the mean low tide datum) (Corps 2009a). The width of the river near the RMPF is 

approximately 900 ft. The west bank of the river channel drops off quickly to a shelf that 

extends approximately 400 ft, then drops again to the thalweg (lowest point in the river channel) 

approximately 600 ft from the west bank. The east bank of the river channel drops to the 

thalweg within 300 ft from the east bank. The bathymetry of the river at the discharge structure 

is not known, but the width is approximately 300 ft (STPNOC 2009a). The river’s bottom habitat 

in the vicinity of the STP site is described as un-vegetated, estuarine benthic habitats with mud 

and sand substrate (STPNOC 2009a). 
Appendix F 

NUREG-1937 F-44 February 2011

Figure 2. STP Site and Proposed Plant Footprint (STPNOC 2009a) 
Appendix F 

February 2011 F-45 NUREG-1937 

Figure 3. Location of the STP Site and Major Important Aquatic Resources 
Appendix F 

NUREG-1937 F-46 February 2011

Today, there is no natural direct connection between the Gulf of Mexico and the Colorado River. 

Aquatic resources associated with the Gulf of Mexico can move into and out of the Colorado 

River through the navigation channel (that connects the Gulf to the GIWW), and through the 

GIWW or a diversion channel into Matagorda Bay. The major shipping channels connect to the 

GIWW in the northeast through the Freeport Harbor Channel (Corps 2008) and in the southwest 

through the Matagorda Ship Channel (Corps 2007). 

The lower Colorado River has been studied on a very limited basis with specific studies 

conducted in 1974, 1976, 1983, and 1984 associated with the licensing of existing STP Units 1 

and 2 (NRC 1975, 1986) and in 2007-2008 associated with the licensing of the proposed Units 3 

and 4 (ENSR 2008a). The flow of the Colorado River and the Gulf of Mexico has changed with 

development of the area since the 1920s. The course of the river prior to the 1920s flowed 

directly into Matagorda Bay. In the 1930s, a delta began to form in the mouth of the river, and a 

channel was constructed through the Matagorda Peninsula, shunting the river flows away from 

the bay directly into the Gulf of Mexico. Then, in the 1950s, the Tiger Island Channel was 

constructed through the west side of the delta, re-establishing flow between the river and the 

bay. The Corps constructed a deeper river diversion channel northwest of the Tiger Island 

Channel in 1990. In 1991, two dams were constructed to divert the river flow, including one 

across the Tiger Island Channel (called the Tiger Island Cut dam) and a diversion dam across 

the river channel on Matagorda Peninsula. By July 1992, all of the Colorado River flow was 

diverted into Matagorda Bay through the GIWW and the newly constructed diversion channel. 

The changes in freshwater inflow to Matagorda Bay over time, and the changes to flow from the 

Gulf of Mexico into the Colorado River have likely influenced the aquatic communities 

historically in the river and bay (Wilber and Bass 1998). 

Changes in the aquatic community over time in the Colorado River were evaluated using the 

results of the 1974, 1983, 1984, and 2007-2008 studies (NRC 1975, 1986; ENSR 2008a). The 

sampling locations and gear types varied with each study, making some comparisons more 

difficult. Trawl samples collected from the GIWW to the STP site in 1974 showed a moderately 

diverse species community for the lower river based on measures for species richness, 

diversity, and evenness. All three measures were slightly lower than those in similar segments 

of the river compared to the 2007-2008 study, suggesting that the diversity of aquatic species is 

greater now than in the past. Data collected during 1974 examining specific segments also 

indicated a diverse species community for all three segments. The 1983-1984 trawl and seine 

data indicated overall lower species richness, diversity, and evenness relative to the present 

data (ENSR 2008a). Rerouting of the lower Colorado River has likely contributed to these 

changes in diversity of aquatic species. 

The number and assortment of organisms collected during the 2007-2008 study indicate that 

this portion of the lower Colorado River supports a diverse assemblage of fauna, many of which 

would be prey for species with designated EFH in the area (Table 1 on the following page). The 
Appendix F 

February 2011 F-47 NUREG-1937 

regular occurrence of both freshwater and saltwater species, the range of macroinvertebrate 

and finfish fauna, and the sheer number of species captured among various sampling gears and 

river reaches provide evidence of a dynamic ecosystem. There was a low to moderate level of 

similarity between the current 2007-2008 faunal communities and the historic communities 

(1974 and 1983-1984) (ENSR 2008a). 

The 2007-2008 survey of the Colorado River did not include sampling for younger life stages 

(e.g., ichthyoplankton). In addition, there were no reports during the 1974, 1983, 1984, and 

2007-2008 studies of any submerged aquatic vegetation (SAV) in the Colorado River from the 

GIWW to the bridge with FM 521 (NRC 1975, 1986; ENSR 2008a). 

Table 1. Fish and Shellfish Collected in the Colorado River by Gear Type, 2007-2008 

(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 

NUREG-1937 F-48 February 2011

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 

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 

February 2011 F-49 NUREG-1937 

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 

2.2 Matagorda Bay 

Matagorda Bay is 300 mi2 formed by a 45-mi-long barrier island-peninsula complex that is 

parallel to the Gulf of Mexico and is located to the southeast of the STP site (STPNOC 2009a). 

The Matagorda Bay system is considered the second largest of the seven major bay systems in 

Texas (LCRA 2006). The bay is connected to the waters on the site as it receives water 

discharged from the site through drainage ditches and channels into Little Robbins Slough and 

downstream marshes and also through the discharge facility into the Colorado River; water in 

the slough, marshes, and river flows into the bay. As mentioned above, the Colorado River 

flows by STP then across the GIWW into a diversion channel into the bay. The bay is described 

as the Matagorda Bay system, and it is the third largest estuary on the Texas coast. The bay 

system includes Lavaca, East Matagorda, Keller, Carancahua, and Tres Palacios bays (Corps 

2007). 

The Colorado River and associated discharge basin is a major contributor of freshwater to 

Matagorda Bay (LCRA 2006). Salinity in the bay system depends on the tidal exchange and 

freshwater inflow. There is little vertical stratification since the bay is relatively shallow and 

mixing occurs from consistent winds (LCRA 2006). Salinity at the Matagorda Ship Channel is 
Appendix F 

NUREG-1937 F-50 February 2011

higher than in the northeastern end of the bay, closest to the diversion channel with the 

Colorado River, decreasing from 27 to 18 parts per trillion (ppt) (Kim and Montagna 2009). 

The aquatic community of Matagorda Bay system includes organisms in the open water areas 

as well as organisms over hard substrates (including oyster reefs and offshore sands). In the 

open water areas of the bay, phytoplankton (e.g., algae) are the major primary producers that 

are the main food source for zooplankton (e.g., small crustaceans), fish and benthic organisms 

(e.g., mollusks). 

3.0 Proposed Federal Actions 

The proposed Federal actions are (1) NRC’s issuance of two COLs for the construction and 

operation of two new nuclear reactors at the proposed STP site pursuant to Title 10 of the Code 

of Federal Regulations (CFR) 52.97, and (2) the Corps’ issuance of a DA permit pursuant to 

Section 404 of the CWA and Section 10 of the Rivers and Harbors Act of 1899. 

The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

“construction” in 10 CFR 50.10 and 51.4 to activities that fall within its regulatory authority. 

Many of the activities required to build a nuclear power plant are not part of the NRC action to 

license the plant. Activities associated with building the plant that are not within the purview of 

the NRC action are grouped under the term “preconstruction.” Preconstruction activities include 

clearing and grading, excavating, erecting of support buildings and transmission lines, and other 

associated activities. These preconstruction activities may take place before the application for 

a COL is submitted, during the staff’s review of a COL application, or after a COL is granted. 

Although preconstruction activities are outside the NRC’s regulatory authority, many of them are 

within the regulatory authority of local, State, or other Federal agencies. The distinction 

between construction and preconstruction is not carried forward in this EFH assessment, and 

both are being discussed together as construction for the purposes of the NRC/Corps joint EFH 

consultation. 

The Corps action is the decision whether to issue a permit pursuant to Section 404 of the Clean 

Water Act and Section 10 of the Rivers and Harbors Appropriation Act of 1899 for proposed 

structures in and under navigable waters and the discharge of dredged, excavated, and/or fill 

material into waters of the United States, including jurisdictional wetlands.

Prerequisites to certain construction activities include, but are not limited to, documentation of 

existing site conditions within the STP site and acquisition of the necessary permits (e.g., COLs, 

local building permits, CWA Section 402(p) Texas Pollutant Discharge Elimination System 

(TPDES) permit, Construction and Industrial Stormwater Permits, a DA permit, Coastal 

Consistency Determination per the Coastal Zone Management Act [16 USC 1451, et seq.], and 

a CWA Section 401 Certification). After these prerequisites are completed, planned 
Appendix F 

February 2011 F-51 NUREG-1937 

construction activities could proceed and would include all or some or all the activities pursuant 

to 10 CFR 50.10(e)(1). Following construction, planned operation of the new reactors would be 

authorized if the Commission finds, under 10 CFR 52.103(g), that all acceptance criteria in the 

COLS are met. 

Briefly, the construction and operation activities that could affect Federally-managed fish and 

shellfish species based on habitat affinities, life-history characteristics, and the nature and 

spatial and temporal considerations of the proposed actions are as follows: 

Construction 

 Refurbishment of the existing RMPF at the Colorado River 

 Expansion of the barge slip on the Colorado River 

 Barging heavy equipment and materials to STP site 

Operation

 Operation of RMPF on Colorado River 

 Operation of discharge structure on Colorado River 

 Maintenance dredging of RMPF and barge slip 

The footprint for proposed Units 3 and 4 would be approximately 2000 ft northwest of existing 

Units 1 and 2 (STPNOC 2009a). The cooling system would be the largest interface from the 

plant to the environment. The proposed new units cooling system would include the same 

systems currently in use for Units 1 and 2: RMFP, MCR, and discharge structure on the 

Colorado River. With the addition of the two proposed new units, additional makeup water 

would be provided to the MCR through refurbished intakes from the Colorado River at the 

RMPF. A portion of this makeup water would be returned to the environment via the discharge 

structure. The remaining portion of the water would be available for release into the 

atmosphere via evaporative cooling of the MCR. Groundwater is planned as the source for 

makeup water for the proposed Units 3 and 4 ultimate heat sink (UHS), service water for the 

power plants, and water for sanitary and potable water systems. The power transmission 

system for proposed Units 3 and 4 would not require new transmission lines or corridors, but it 

would use five of the nine 345-kV transmission lines that currently connect to existing STP Units 

1 and 2, and involve upgrading a 20-mi section of the existing 345-kV Hillje transmission line 

(STPNOC 2009a). Below is further description of the major features of the proposed site. 
Appendix F 

NUREG-1937 F-52 February 2011

3.1 Circulating Water Intake System 

The circulating water intake system for the proposed new units consists of two parts. The 

RMPF pumps water from the Colorado River into the MCR. A new circulating water intake 

system (CWIS) would be constructed within the MCR for use by the proposed new units for 

cooling purposes. 

Reservoir Makeup Pumping Facility. The RMPF is located along the west bank of the Colorado 

River and is an existing facility that would be modified solely within its existing footprint to supply 

makeup water to the MCR for operating all four nuclear units. The facility is located near NMM 

8 on the Colorado River upstream from the confluence with the GIWW, and the structure is 

“flush” to the river bank with no projecting structures into the river. The RMPF withdraws water 

through a 406-ft-long intake along the shoreline. Water from the river flows through trash racks 

(with 4-in. spacing between the bars), then through traveling screens, and then over a weir into 

an embayment before entering the pumps into a pipeline delivering water to the MCR. There 

are 18 travelling screens, each of 13.5 ft width, with the bottom of the screens situated at 10 ft 

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

. The existing traveling 

screens have a 3/8-in. mesh, and operate intermittently to coincide with the intermittent 

withdrawal of river water. For the purposes of this assessment, the review team is assuming 

that modifications to the RMPF would result in trash bars and travelling screens with identical 

characteristics to those that exist currently at the RMPF. 

Fish collected on the traveling screens can be returned to the river via the existing sluice and 

fish bypass pipe. The fish return outfall is at the downstream end of the intake structure, 

approximately 2 ft below normal water elevation (STPNOC 2009a). During high-flow conditions, 

the accumulation of debris on the traveling screens is too high to open the fish bypass system, 

and screenwash discharge is directed to the sluice trench catch baskets rather than back to the 

river. Generally, the fish bypass system is closed when river flows are greater than 4000 cubic 

feet per second (cfs), and the system is occasionally closed when flows are greater than 

2000 cfs (which has occurred from 2001-2006 only 7 percent of the time) (STPNOC 2009a, 

2008b). Impingement mortality can be reduced based on the procedures for operating the 

RMPF. Operators at the RMPF are required to monitor for increased impingement rates on the 

traveling screens, and factors like river flow, salinity, and observations of impingement are used 

to determine if pumping should continue (STPNOC 2009a, 2008a, 2008b). 

STPNOC has stated that periodic dredging in the future would be conducted in front of the 

RMPF (STPNOC 2009a). These activities are currently covered by existing permits with the 

Corps for the operation of Units 1 and 2. In addition, the Corps would be conducting 

maintenance dredging of the navigation channel in the river in the vicinity of the discharge 

structure and RMPF (Corps 2009a). Based on past dredging events, the substrate that would 
Appendix F 

February 2011 F-53 NUREG-1937 

be dredged is predominantly silty-clay soils with approximately 6 in. of “detritus and silt soils” on 

the surface. Dredged material would be placed in the designated onsite location that is 

currently used for storage of material removed during maintenance activities with the RMPF 

(STPNOC 2009b). The area to be dredged would be approximately one ac. 

Main Cooling Reservoir. The MCR is a 7000-ac engineered impoundment enclosed by an 

engineered embankment. STPNOC has indicated that, at the maximum normal operating pool 

of 49 ft MSL, the reservoir contains approximately 202,700 ac-ft of water. The CWIS for Units 3 

and 4 would be located within the MCR. This CWIS would be a 131-ft by 392-ft concrete 

structure and would house eight pumps for the two proposed units. The structure would include 

trash racks and traveling screens (again, the review team assumes characteristics would be 

identical to those described above for RMPF trash racks and screens). Pipes carrying water 

from the plant would run to the turbine building. As for existing Units 1 and 2, the circulating 

water discharge structure for Units 3 and 4 would also be located within the MCR. The water 

return from Units 3 and 4 turbine buildings would enter the MCR through a new discharge 

structure within the MCR. The simple discharge structure would include a weir and a stilling 

basin to dissipate the velocity of the returning water before it enters the MCR. Dikes within the 

MCR increase the travel time that cooling water from the circulating water system would 

experience. The reject heat from the existing and proposed units would enter the MCR in the 

form of sensible heat in circulating water in the MCR. As the heated water circulates in the 

MCR, the heat is gradually dissipated to the environment through evaporation, conduction, and 

long-wave radiative cooling. 

A diverse aquatic community exists in the MCR, but the organisms are not available for harvest. 

No public access or use of the MCR exists. In addition, the Corps has determined that the MCR 

is not considered waters of the United States (Corps 2009b), and the Texas Commission on 

Environmental Quality (TCEQ) has stated that the MCR is not considered waters of the State 

(TCEQ 2007; STPNOC 2008a). 

The aquatic community in the MCR was evaluated in 2007-2008 (ENSR 2008b). A total of 

11,605 finfish and invertebrates were collected over the duration of the sampling program for 

the MCR. The most common fish species collected were with seines, and included threadfin 

shad (Dorosoma petenense, 62 percent), inland silverside (Menidia beryllina, 18 percent), rough 

silverside (Membras martinica, 12 percent), and blue catfish (Ictalurus furcatus, three percent). 

The macroinvertebrates were characterized using plankton tows, and a total of 5362 organisms 

were collected in the MCR. The most common species (84 percent of all samples) collected 

were Harris mud crab larvae (Rhithropanopeus harrisii), and more than 99 percent of all 

sampled organisms were crustaceans (ENSR 2008b). 

The same study also evaluated the impinged and entrained aquatic resources by the CWIS in 

the MCR for Units 1 and 2 (ENSR 2008b). Overall, very few fish species were impinged (less 

than 50 percent) or entrained (less than one percent). A total of 3982 organisms representing 
Appendix F 

NUREG-1937 F-54 February 2011

25 fish species, seven invertebrate species, and one reptile species were collected during 

impingement sampling. Impingement rates were highest during the winter and early spring 

months. The dominant species collected in the impingement samples were threadfin shad 

(42 percent), Harris mud crab (24 percent), blue crab (Callinectes sapidus, 24 percent), Atlantic 

croaker (Micropogonias undulates, 5 percent), and white shrimp (Litopenaeus setiferus, 

3 percent). A total of 207,696 organisms representing nine different fish families and 

12 different invertebrate classes were collected during entrainment sampling. Entrainment rates 

were highest during the spring months. The dominant species collected in the entrainment 

samples were Harris mud crab (68 percent), unidentified decapods (15 percent), and 

harpacticoid copepods (6 percent). Less than one percent of the total composition of entrained 

organisms was fish eggs (ichthyoplankton) (ENSR 2008a). 

Water quality sampling in the MCR showed that there were seasonal and spatial changes within 

the reservoir. Water temperature was the highest at the cooling water discharge area and 

gradually decreased by approximately 10°F as the water traveled through the internal levee 

system to the CWIS. The temperature through the water column did not vary much: 65.3°F to 

96.1°F for surface measurements, and 65.1°F to 95°F for bottom measurements. Through the 

year, the temperature did vary. Temperature data from trawl samples increased from an 

average 86.4°F in May to 93.4°F in August and then decreased in October to 76.8°F and then to 

70.5°F in February. Salinity remained constant throughout the reservoir and the water column 

at approximately 1.6 ppt. 

3.2 Cooling Water Discharge System 

Discharge from the MCR enters the Colorado River through a series of seven 36-in.-diameter 

pipes directed 45 degrees from the downstream western shore. The discharge structure is 

located about 2 mi downstream of the RMPF, located at NMM 6 on the Colorado River 

upstream from the confluence with the GIWW. The pipes entering the river are spaced 250 ft 

apart. Discharge that is released from the MCR approaches the diffusers through a 78-in.-

diameter pipeline. As mentioned above, STPNOC has only released water through the 

discharge system once during the operation of Units 1 and 2. No change to the existing 

discharge structure is proposed for the new nuclear units (STPNOC 2009a). 

3.3 Barging 

The existing barge slip that was built for Units 1 and 2 would be re-excavated and expanded for 

use with the proposed Units 3 and 4 (STPNOC 2009c). Delivery of major equipment for Units 3 

and 4 would be accomplished by barging the material to the site and would include heavy 

equipment (prefabricated modules, large components fabricated overseas) and bulk 

commodities (e.g., aggregate or structural fill materials). STPNOC has stated that no firm 
Appendix F 

February 2011 F-55 NUREG-1937 

shipping contracts have been developed for transportation of the materials to the STP site. 

However, STPNOC has indicated that the current plans call for prefabricated modules and 

components fabricated overseas to be shipped to the Port of Freeport (or points north) where 

they would be transferred from ocean-going ships to inland barges. The inland barges would 

then enter the GIWW and move south to the confluence of the Colorado River and proceed 

upstream to the site. The ports in Matagorda Bay to the south of the site currently do not have 

adequate facilities for the transfer of heavy cargo from ocean-going vessels to inland barges. 

Therefore, transport of these materials would not involve the Matagorda Ship Channel or the 

diversion canal in Matagorda Bay (STPNOC 2009b). 

STPNOC plans to ship bulk commodities via inland barge. Access to the Colorado River by the 

barges would depend on the source of the materials, and could be transported either from the 

north or south along the GIWW. However, no bulk commodity traffic is expected to traverse the 

diversion canal in Matagorda Bay or the Matagorda Ship Channel (STPNOC 2009b). 

4.0 Essential Fish Habitat Species Descriptions 

The proposed Units 3 and 4 at the STP site are located in an area that is designated as EFH in 

Ecoregion 5 by the Gulf of Mexico Fishery Management Council (GMFMC 2004). The NRC and 

the Corps conducted an evaluation by identifying and considering all designated EFH that 

occurs near the STP site (GMFMC 2004; NMFS 2009). Table 2 lists the species with 

designated EFH in Matagorda Bay, GIWW, and the Colorado River extending up to the bridge 

at FM 521 (located at NMM 10 on the Colorado River upstream from the confluence with the 

GIWW). With the exception of a few species that do not occur in the region of interest, or 

occupy EFH that would not be affected by the proposed actions, these species and their life 

stages that rely on habitats essential for species propagation are detailed below with regard to 

the impact of the proposed Federal actions on EFH. 

During the initial review of life history and EFH requirements, some life stages were eliminated 

from further consideration based on depth requirements, or life history information that 

suggested specific life stages are unlikely in the Colorado River extending up to the bridge at 

FM 521, GIWW, and Matagorda Bay (Table 3). Table lists the species and life stages 

evaluated in this EFH assessment. 
Appendix F 

NUREG-1937 F-56 February 2011

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. 

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 

February 2011 F-57 NUREG-1937 

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 

4.1 King Mackerel 

King mackerel (Scomberomorus cavalla) are highly migratory and are aggressive predators that 

prefer feeding on schooling fish. Occasionally they eat penaeid shrimp and squid. Adult king 

mackerels consume mainly fish around 4 to 6 in. Juveniles eat smaller fish and invertebrates, 

particularly bay anchovy (Anchoa mitchilli). King mackerel can live to at least 14 years, 

although most die earlier. Females grow larger than males and spawn in their third or fourth 

year of life, with spawning occurring in the summer months (TSFGW 2005; FMNH 2009; TPWD 

2009). Adults are primarily found offshore, but juveniles occasionally frequent estuarine waters 

for foraging (GMFMC 2004). Although no king mackerel have been observed during sampling 

studies, juvenile king mackerel are likely to occur in Matagorda Bay, GIWW, and the Colorado 

River. 

4.2 Spanish Mackerel 

Adult Spanish mackerel (Scomberomorus maculates) forage in estuarine and marine nearshore 

pelagic waters, and eggs and juveniles also occur nearshore marine surface (eggs) and pelagic 

(juveniles) waters (GMFMC 2004). The species is often found in large schools near the water 

surface. Juvenile and adult Spanish mackerel are fast-moving, voracious predators that feed on 

other smaller schooling fish. Spawning takes place from late spring to late summer at depths of 

less than 50 m along the Texas inner continental shelf (DeVries et al. 1990; Patillo et al. 1997). 

According to an EFH assessment in Matagorda Bay by the Corps (2007), adult and juvenile 

Spanish mackerel are found in the Gulf and Matagorda Bay throughout the year. The surveys 

of the Colorado River did not report any Spanish mackerel (NRC 1986; ENSR 2008a; STPNOC 

2009a). 
Appendix F 

NUREG-1937 F-58 February 2011

4.3 Gray Snapper 

Larval, juvenile, and adult life stages of gray snapper (Lutjanus griseus) are considered because 

these life stages primarily occupy inshore habitats, such as those in the Colorado River, GIWW, 

and Matagorda Bay (GMFMC 2004). Eggs are neritic and demersal, and are found primarily in 

marine waters. Larvae are marine, neritic, and planktonic, and are known to be in the Gulf from 

April through November. As they mature, gray snapper move into estuarine habitats and 

occupy inshore grassy areas. Juveniles and adults are found in inshore marine and estuarine 

habitats with SAV or near mangroves, where they forage on small fish and crustaceans (Croker 

1962; Patillo et al. 1997). The Corps (2007) reported that gray snapper are found in Matagorda 

Bay. Patillo et al. (1997) indicated that gray snapper are rare as adults and juveniles, but other 

life stages were not present in Matagorda Bay. Gray snapper were collected within the first 3 mi 

of the Colorado River from the confluence with the GIWW during the 2007-2008 sampling 

events (ENSR 2008a). 

4.4 Red Drum 

Red drum (Sciaenops ocellatus) larvae and juveniles spend most of their time in estuarine soft 

bottom, sand/shell, and SAV habitats actively feeding on copepods, mysid shrimp (Mysidopsis 

bahia), amphipods, decapods, and small fish. All free swimming life stages of the red drum are 

carnivorous. Adults spend some time near inshore SAV, sandy or hard-bottom foraging habitats 

but are predominantly found offshore where spawning activities occur (Patillo et al. 1997; 

GMFMC 2004). Red drum move to deep offshore waters to spawn in the fall and then return to 

nearshore coastal and estuarine habitats where they spend most of their life cycle (FFWCC 

2007). Tidal currents move larvae to nearshore habitats, where they grow rapidly as juveniles 

during the first two years, and associate with seagrass habitats, with little wave action (Buckley 

1984). The Corps (2007) reported that juvenile red drum are present in Matagorda Bay 

throughout the year. Patillo et al. (1997) indicated that all life stages of red drum were common 

in Matagorda Bay. Red drum were collected in along the Colorado River in 2007-2008 with all 

types of sampling gear, indicating that the species was well distributed in the river (ENSR 

2008a). 

4.5 Shrimp 

Adult brown shrimp migrate (Farfantepenaeus aztecus) from offshore pelagic environment as 

larvae to inhabit grassy, estuarine habitats as juveniles (GMFMC 2004). They spawn in 

offshore waters between spring and early summer. The eggs are demersal and deposited 

offshore. Larvae migrate into estuarine waters through passes during flood tides. Juveniles 

inhabit a variety of areas where they can burrow in shallow estuarine waters, ranging from areas 

with vegetative cover to open silty sand, nonvegetated mud substrate. Postlarvae and juveniles 
Appendix F 

February 2011 F-59 NUREG-1937 

can tolerate a range of salinities, from 0 to 70 ppt. Juveniles and subadults prefer soft, muddy 

areas. Subadult brown shrimp migrate from estuaries into the Gulf (Patillo et al. 1997; GMFMC 

2004; Corps 2007). Juvenile and adult shrimp are omnivorous with diets that vary between 

available food sources within the occupied habitat, which is preferably soft bottom, shallow 

estuarine areas (FWS 1983). According to an EFH assessment in Matagorda Bay by the Corps 

(2007), juvenile brown shrimp are common to highly abundant in Matagorda Bay year-round, 

while adults are common to highly abundant from April to July and are rare from August through 

March. Brown shrimp were collected in sampling studies all along the Colorado River in 1983-

1984 and 2007-2008 (NRC 1986; ENSR 2008a; STPNOC 2009a). 

Pink shrimp (Litopenaeus duorarum) in the Texas coastal waters are often difficult to distinguish 

from brown shrimp, and pink and brown shrimp are usually reported together in information 

about the shrimping fishery in Texas coastal waters (Patillo et al. 1997). Adults occur offshore 

and migrate into estuaries in the spring and fall. Postlarvae and juvenile pink shrimp select 

habitats with seagrass and shoalgrass, where they burrow by day and emerge and are active at 

night (Patillo et al. 1997; Corps 2007). Like brown shrimp, juvenile and adult shrimp are 

omnivorous (Patillo et al. 1997). According to an EFH assessment in Matagorda Bay by the 

Corps (2007), juvenile pink shrimp are common in Matagorda Bay year-round, while adults are 

common from November through June. Pink shrimp were not reported in surveys of the 

Colorado River in 2007-2008 (ENSR 2008a). 

Adult white shrimp (Litopenaeus setiferus) also migrate from offshore pelagic environment as 

larvae to inhabit grassy, estuarine habitats as juveniles (GMFMC 2004). They spawn in 

offshore waters from spring to fall (FWS 1983). The eggs are demersal and deposited offshore 

(Patillo et al. 1997). White shrimp larvae may be found in the nearshore marine water column, 

but they prefer estuarine habitats and migrate further upstream in estuarine waters than brown 

shrimp (GMFMC 2004). Juvenile and adult shrimp are omnivorous with diets that vary between 

available food sources within the occupied habitat, which is preferably soft-bottom, shallow 

estuarine areas (FWS 1983). According to an EFH assessment in Matagorda Bay by the Corps 

(2007), adult and juvenile white shrimp are common to abundant in Matagorda Bay throughout 

the year, except in July when adult white shrimp are absent. White shrimp were collected in 

sampling studies all along the Colorado River in 1983-1984 and 2007-2008 (NRC 1986; ENSR 

2008a; STPNOC 2009a). 

4.6 Gulf Stone Crab 

The Gulf stone crab (Menippe adina) occupies estuarine and marine SAV, sand/shell, and hardbottom habitats as eggs, larvae, and juveniles (GMFMC 2004). Adults are both intertidal and 

subtidal and are typically found near oyster reefs or other hard-bottom substrate, and prefer a 

diet of oysters (Wilber 1989). Juveniles feed on small mollusks, worms, and crustaceans. 

Females maintain eggs on their abdomen until they hatch and become planktonic. As they 
Appendix F 

NUREG-1937 F-60 February 2011

metamorphose to larvae, they become epibenthic, settling to areas providing cover (e.g., rubble 

and seagrass beds). The stone crab FMP allows harvest only of individuals with claws greater 

than 2.75 in. long. Florida stone crabs (M. mercenaria) require high salinities for juvenile 

growth, but the Gulf stone crab tolerates estuarine waters (GMFMC 2004). All life stages of 

Gulf stone crab are considered common throughout the year in Matagorda Bay (Patillo et al. 

1997; Corps 2007). Gulf stone crabs were not reported in surveys of the Colorado River in 

1983-1984 and 2007-2008 (NRC 1986; ENSR 2008a; STPNOC 2009a). 

5.0 Potential Environmental Effects of the Proposed 

Federal Actions 

This section describes the potential impacts from the construction and operation of proposed 

Units 3 and 4 at the STP site to Federally-managed estuarine and marine fish and shellfish and 

their habitats. Most of the construction and operation impacts to EFH would be limited to the 

Colorado River. Barging traffic during construction of Units 3 and 4 would be associated with 

Matagorda Bay, GIWW and the Colorado River. 

5.1 General Construction Impacts 

Construction activities in the Colorado River for the proposed Units 3 and 4 are limited to the 

RMPF, the barge slip and barging traffic to the STP site. Activities within the MCR are not part 

of this assessment because the aquatic organisms in the MCR are considered removed from 

the ecological system of the Colorado River, and the MCR is not included as designated EFH. 

Half of the intake screens on the RMPF have not been used during the operation of STP Units 1 

and 2, and they would be removed from the water and either refurbished or replaced. New 

pumps for proposed Units 3 and 4 would be installed behind the embayment located behind the 

traveling screens. These activities would involve little underwater disturbance, which would be 

limited to the front of the intake structure. EFH in the Colorado River would likely not be 

adversely affected during construction because of the minimal activity in the river that would be 

required by the refurbishment of the RMPF. 

When the barge slip for existing STP Units 1 and 2 was built, a sheet pile wall was installed in 

the river to control sedimentation and limit downstream increases in turbidity and siltation. At 

that time, an estimated area of less than one ac of benthic habitat was destroyed during the 

building of the barge slip (STPNOC 2009a). The areal extent and types of disturbances to the 

shoreline and in the river for the re-excavation and expansion of the slip for transporting the 

barged materials for proposed Units 3 and 4 is anticipated to be similar to or less than the 

disturbances during the building of Units 1 and 2 (STPNOC 2009c). The loss of soft-bottom 

habitat would likely reduce the potential forage area for the penaeid shrimp and some benthic-
Appendix F 

February 2011 F-61 NUREG-1937 

feeding EFH fish species. However, the area is not one of high benthic productivity, and the 

area that would be lost is relatively small. 

STPNOC has indicated the current plans call for heavy equipment (prefabricated modules and 

components fabricated overseas) to be shipped to the Port of Freeport (or points north) where 

they would be transferred from ocean-going ships to inland barges. The inland barges would 

enter the GIWW, move south to the confluence of the Colorado River, and proceed upstream to 

the site. Bulk commodities (e.g., aggregate or structural fill material) could be barged to the 

STP site from ports to the north or south along the GIWW. There is no estimate for the number 

of barges that would deliver to the STP site (STPNOC 2009b). Based on the minimum depths 

and narrow channels that the barges would have to travel in the Colorado River, the barges are 

likely to be slow moving, and would have minimal wave disturbances along shoreline habitat. 

Habitat for aquatic organisms in the vicinity of the barge slip would be disturbed while barges 

continue to use the area. While there would be an increase in turbidity and silt in the water 

column associated with docking and the potential for discharge of small amounts of gas, oil, and 

grease from motors, the overall impact would be short in duration (STPNOC 2009b). 

Erosion and sedimentation controls, are expected to minimize quantities of sediment or silt. 

Increase in turbidity would increase suspended sediments in the water column, but it is not likely 

that such sediments would be transported far down the river. Dredging would remove habitat 

(probably less than three ac) for organisms in the area of the barge slip, and could take 

individuals that cannot avoid the area. Based on the short duration and limited area of the river 

that would be affected, the impacts from construction activities for proposed Units 3 and 4 at 

STP are likely to be minor for aquatic resources in the Colorado River, the GIWW and 

Matagorda Bay. 

5.2 General Operational Impacts 

Operational activities in the Colorado River are limited to pumping water at the RMPF, 

discharge of the MCR water into the river, and maintenance dredging of the RMPF. Removal of 

water from the Colorado River at the RMPF affects aquatic organisms by impingement on 

screens, entrainment into the cooling system, and entrapment in the MCR. Discharging from 

the MCR into the Colorado River has the potential to affect the aquatic organisms because of 

the thermal, chemical, and physical characteristics of the discharge plume. Maintenance 

dredging around the RMPF and barge slip has the potential to remove habitat. 

Impingement, Entrainment, and Entrapment. The RMPF has a number of design elements that 

are expected to minimize impingement, entrainment and entrapment of aquatic organisms 

during operation of all the STP units. For aquatic resources, the primary concerns related to 

water intake and consumption are the impacts related to the relative amount of water drawn 

from the cooling water source (Colorado River and MCR) and the potential for organisms to be 
Appendix F 

NUREG-1937 F-62 February 2011

impinged on the intake screens entrained into the cooling water system, or entrapped in the 

MCR. Impingement occurs when organisms are trapped against the intake screens by the force 

of the water passing through the screens at the RMPF on the Colorado River and the CWIS on 

the MCR. Impingement can result in starvation and exhaustion, asphyxiation (water velocity 

forces may prevent proper gill movement or organisms may be removed from the water for 

prolonged periods of time), and descaling. Entrainment occurs when organisms are drawn 

through the RMPF from the Colorado River into the MCR, or through the CWIS from the MCR 

into the proposed Units 3 and 4 cooling system. Organisms that become entrained are normally 

relatively small benthic, planktonic, and nektonic (organisms in the water column) forms, 

including early life stages of fish and shellfish, which often serve as prey for larger organisms 

(69 FR 41576). Entrained organisms from the Colorado River have survived the stresses of the 

intake system and colonized the MCR, creating a rather diverse aquatic community that is 

removed from the rest of the ecosystem in the region. The survey of the MCR in 2007 and 2008 

indicates that many individuals of numerous species have survived entrainment at the RMPF 

and are living in the MCR. While these entrapped organisms have survived entrainment of the 

pumps at the RMPF, overall the entrainment and entrapment have led to a loss of the 

organisms in the Colorado River, and these organisms no longer contribute to the richness of 

the river community as they are effectively isolated. Organisms in the MCR that pass through 

the CWIS into the plant’s cooling system are subject to mechanical, thermal, and toxic stresses, 

and survival of CWIS entrainment is unlikely and assumed to be zero for the purposes of this 

assessment. 

A number of factors, such as the type of cooling system, the design and location of the intake 

structure, and the amount of water withdrawn from the source water body greatly influences the 

degree to which impingement and entrainment affect the aquatic biota. The 7000-ac MCR is 

considered a closed-cycle cooling system since the water in the reservoir continues to circulate 

from the MCR, into the plant, and back again. Water loss from the MCR through evaporation, 

seepage, and discharge is made up from the Colorado River. 

The RMPF is located on the Colorado River, which is designated as a tidal stream (TCEQ 2008) 

and includes EFH for Federally managed fish and shellfish species (GMFMC 2004). Locating 

intake systems in such areas with sensitive biological communities is generally considered a 

negative factor in protection of aquatic life (69 FR 41576). However, the segment of the river 

where the RMPF is situated (Segment C) has fewer organisms and less species richness than 

the downstream segment of the river, closer to the GIWW (Segment A)(ENSR 2008b). During 

2007-2008, 18 percent of the total number of individuals collected were from Segment C as 

compared to 44 percent from Segment A; and 42 species were collected from Segment C as 

compared to 62 species from Segment A (Figures 4 and 5). 

Operation of the RMPF is based on the need for makeup water in the MCR, and Section 5.2.2.1 

of the EIS discusses the conditions when STPNOC would pump water from the Colorado River 
Appendix F 

February 2011 F-63 NUREG-1937 

into the MCR. One of these conditions is pumping makeup water during periods of high flows in 

the Colorado River. Pumping at high-flow conditions minimizes impacts to aquatic organisms in 

the water column because the organisms are likely to remain in the river flow and not likely to be 

caught in the influence of the water being pumped into the RMPF located on the shoreline 

(STPNOC 2008b, 2008c, 2009a). During the 2007-2008 aquatic ecology studies in the 

Colorado River, there was an inverse relationship between high-flow conditions and low 

densities of fish (as expressed in the catch per unit effort) (ENSR 2008a; STPNOC 2008b, 

2008c). Salinity can be an indicator of an influx of estuarine species moving up the river from 

the GIWW. STPNOC has stated that the salinity of the water being pumped would be 

monitored, and when the pumped water exceeds 3 ppt, the traveling screens would be 

monitored for increased impingement. The operation of the fish-return system at the RMPF is a 

function of river flow and the amount of debris and organisms removed in the screen wash 

discharge (STPNOC 2008a). 

Location of the RMPF and the intake screens on the shoreline of the Colorado River can 

minimize entrainment and entrapment (as a function of minimized entrainment). The RMPF 

was designed to maintain the traveling intake screens on the facility parallel with the flow in the 

river (69 FR 41576), or “flush” to the river bank with no projecting structures that create eddies 

and countercurrents that would cause entrapment (NRC 1986; STPNOC 2009a). Most 

organisms likely to be entrained or entrapped would be present in higher densities in the main 

river channel and less likely to be removed from the river by an intake facility sited on the 

shoreline. Entrapment of aquatic organisms in a restricted area (e.g., in the sedimentation 

basin between the RMPF intake screens and the pumps and in the MCR) can lead to 

congregation of the organisms, and if environmental conditions change, the organisms may be 

harmed. Under such conditions, entrapment can increase impingement of aquatic organisms. 

Another important factor that influences the rate of impingement, entrainment, and entrapment 

of organisms at a facility is the intake design through-screen velocity. The higher the throughscreen velocity, the greater the number of fish impinged, entrained, and entrapped. The 

Environmental Protection Agency defines the through-screen velocity as the water velocity 

immediately in front of the screen, and the maximum design, through-screen velocity is no more 

than 0.5 feet per second (fps) (69 FR 41576). STPNOC has determined that the RMPF has a 

maximum design approach velocity at the traveling screens of 0.5 fps based on a maximum 

pumping rate of approximately 538,000 gpm (STPNOC 2008b, 2009a). The review team 

independently calculated that the velocity directly in front of the screens was dependent on the 

withdrawal rate of the RMPF: for withdrawals of 60 and 1200 cfs, the average velocity in front of 

the screen would be 0.025 and 0.49 fps. The resulting low through-screen velocity reduces the 

probability of impingement because most fish can swim against such low flows to avoid or swim 

off of intake streams. 
Appendix F 

NUREG-1937 F-64 February 2011

Other design features at the RMPF would also help to reduce impingement mortality 

(69 FR 41576). In front of the traveling water screens are coarse trash racks and stop-log 

guides that allow fish that approach the RMPF to have free passage, reducing entrapment and 

impingement. The traveling screens have a 3/8-in. mesh, and operate intermittently to coincide 

with the intermittent withdrawal of river water. Fish collected on the traveling screens can be 

returned to the river via the sluice and a fish bypass pipe. The discharge point of the fish 

bypass system is at the downstream end of the intake structure, approximately two ft below 

normal water elevation (STPNOC 2009a). During high-flow conditions, the accumulation of 

debris on the traveling screens is too high to open the fish bypass system, and screenwash 

discharge is directed to the sluice trench catch baskets rather than back to the river. Generally, 

the fish bypass system is closed when river flows are greater than 4000 cfs, and the system is 

occasionally closed when flows are greater than 2000 cfs (which has occurred from 2001-2006 

seven percent of the time) (STPNOC 2008b, 2009a). Impingement mortality can be reduced 

based on the procedures for operating the RMPF. Operators at the RMPF are required to 

monitor for increased impingement rates on the traveling screens, and factors like river flow, 

salinity, and observations of impingement are used to determine whether pumping should 

continue (STPNOC 2008b, c, 2009a). 

Entrainment and impingement studies were conducted as part of the licensing process for STP 

Units 1 and 2, and were discussed in the Final Environmental Statement (FES) for operation 

(NRC 1986). Studies conducted in 1975-1976, prior to construction of the RMPF, estimated 

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 Gulf 

menhaden (Brevoortia patronus), 1.32 x 106

 blue crab, 5.44 x 105 bay anchovy and 1.1 x 104

shrimp (undetermined species) larvae. There was a seasonal fluctuation of the species 

collected monthly during the study. Atlantic croaker larvae were entrained mainly from 

November through January. From January through April 1976, Gulf menhaden larvae were the 

predominant species. Anchovy eggs and larvae occurred sporadically throughout the sampling 

year. Highest numbers of juvenile and megalops of blue crab were collected in October, but 

there were increased numbers taken in September and April (NRC 1986). 

The entrainment studies in 1983-1984 were conducted during the filling of the MCR (NRC 

1986). Different species of fish and crustaceans were collected compared to the studies in 

1975-1976. The primary fish species collected in the vicinity of the plant intake were bay 

anchovies, followed by darter goby (Ctenogobius boleosoma) and naked goby (Gobiosoma 

bosc). The most common crustacean collected were the zoea larval stage of the Harris mud 

crab, followed by the zoea and postlarval stages of the ghost shrimp (Callianassa spp.). 

Postlarval stages of the brown shrimp and white shrimp and the juvenile stages of the blue crab 

were collected only sporadically in river samples. The variety of species collected illustrates 

that the lower Colorado River is used as a nursery area by estuarine-marine organisms (NRC 

1986). The seasonal variations in species and numbers of individuals found in these studies 
Appendix F 

February 2011 F-65 NUREG-1937 

Figure 4. Aquatic Ecology Sampling Locations for 2007-2008 on the Colorado River from 

Navigation Mile Marker 5 to 9 
Appendix F 

NUREG-1937 F-66 February 2011

Figure 5. Aquatic Ecology Sampling Locations for 2007-2008 on the Colorado River from Gulf 

Intracoastal Waterway to Navigation Mile Marker 4 
Appendix F 

February 2011 F-67 NUREG-1937 

emphasize the complexity of the aquatic environment in the Colorado River and in the vicinity of 

the RMPF. These variations are a function of the species’ reproductive periods, changes in the 

flow of the river, the mixture of freshwater coming down the river, and tidal influence of the Gulf. 

The FES for operation (NRC 1986) concluded that entrainment losses for the species that were 

collected during the two studies would not constitute a significant impact to their respective 

populations for several reasons. They estimated that the actual entrainment losses would 

probably be near a median value of about 10 percent of the organisms passing the RMPF. This 

value represents the loss of organisms in the influence of the tidal flow in the river and does not 

represent the entire populations of those species in the Colorado River. The organisms that use 

the lower Colorado River as a nursery also use many other tidal river systems along the Texas 

and Gulf coast, and the area influenced by the RMPF is not unique. The most common species 

collected in the entrainment studies were bay anchovy, Gulf menhaden, Atlantic croaker and 

blue crab; the species are ubiquitous and abundant along the Texas and Gulf coast. The 

reproductive potential (fecundity) for the species collected during the entrainment studies is high 

(e.g., one female blue crab can produce over her lifetime at least as many larvae as were 

projected to be entrained by the studies). And finally, the most makeup water withdrawal would 

occur during high river flow conditions when tidal flows are low at the RMPF, which is when the 

concentrations of estuarine and marine organisms would be lowest (NRC 1986). 

Impingement studies were conducted during 1983-1984, while river water was being pumped 

into the MCR. The study reported that the highest numbers of organisms impinged over a 

30-minute collection period for two intake screens at the RMPF were 64 organisms in July and 

13 organisms in September. The number of organisms that could be impinged for all 

24 screens at the RMPF and for two pumping velocities (85 cfs and 260 cfs) was extrapolated to 

be from 156 to 768 individuals over a 30-minute period. Gulf menhaden was the most common 

species impinged, which relates to their small size (and thus, relatively low swim speed), dense 

schooling nature and high relative abundance at the site. The report estimated that Gulf 

menhaden could constitute about 65 percent of the total number of all individuals impinged at 

the RMPF. The other major species that could be impinged include: Atlantic croaker 

(16 percent), bay anchovy (10 percent) and mullet (eight percent, undetermined species). The 

remaining species that were collected during the impingement study were expected to make up 

less than one percent of all the individuals impinged. 

The FES for operation concluded that impingement losses would have only a minor effect on 

the biota of the Colorado River. The reasons cited for the minor impacts due to impingement 

included those mentioned above for perspective on entrainment losses (e.g., the species are 

ubiquitous and the number of similar habitat areas along the Texas Gulf coast). Additional 

reasons cited included design elements of the RMPF that should reduce impingement losses. 

For example, the mounting of the intake screens on the RMPF flush with the shoreline and 

without protruding sidewalls into the flow of the river would reduce entrapment and 
Appendix F 

NUREG-1937 F-68 February 2011

concentration of organisms ahead of the screens. Also, the location of the screens would 

decrease eddy currents downstream and allow free passage of the organisms into the main 

channel. Trash racks and the fish handling and bypass system were other features cited that 

would reduce impingement losses. Finally, the location of the intake structure was designed to 

use the upper stratum of the river water that is primarily freshwater flowing downstream in the 

river and not the lower portion of the river in the salt wedge where the estuarine organisms are 

most common (NRC 1986). 

Since the impingement and entrainment studies for the RMPF were conducted, the Corps 

completed the Mouth of the Colorado River Project, diverting the Colorado River flow from the 

Gulf into Matagorda Bay (Wilbur and Bass 1998; Corps 2005). The diversity of aquatic species 

has increased since the diversion of the river. Of the most common species impinged during 

the 1983-1984 studies (NRC 1986), Gulf menhaden, striped mullet (Mugil cephalus) and Atlantic 

croaker continue to be the most common species of fish collected around the RMPF, and 

probably are the most common species impinged today for the same reasons speculated 

above. The lack of studies over time in the lower Colorado River makes it difficult to conclude if 

the aquatic communities are stable based on the changes in the river system and the 

relationship of the species distributed in the region to the flow of freshwater and tidal changes. 

However, the results and conclusions of the earlier impingement and entrainment studies 

mentioned above are still applicable because the design features of the RMPF that would 

minimize losses of organisms would not change with the addition of proposed Units 3 and 4 at 

the STP site. 

The survey of fish and shellfish in the Colorado River in 2007-2008 indicates that the river has a 

large population of fresh- and saltwater species, with high species richness and a strong 

dynamic ecosystem. Impingement, entrainment, and entrapment from current operations of the 

RMPF have removed individuals from the river environment. A survey of only one year provides 

limited information about the robustness of the populations of aquatic organisms in the river. 

However, based on the limited information from the latest survey and what is known about the 

design of the RMPF, the operation of the RMPF does not appear to have changed the 

populations of the species currently found in the river. 

Entrapment and entrainment of the smaller organisms and early life stages would be removed 

from the Colorado River ecosystem. Some of these organisms may survive and thrive in the 

MCR. There would be indirect effects for those EFH species that forage on the organisms that 

are lost through entrapment and entrainment. Impingement is likely to affect the EFH species 

that have life stages that could not swim away from the intake screens. 

Thermal, Chemical, and Physical Impacts. The operation of the discharge system into the 

Colorado River would likely have impacts on the aquatic resources from heated effluents, 

chemical impacts, and physical impacts. There is a current TPDES permit for the discharge of 

the MCR water into the Colorado River that would be applicable for the proposed new units as 
Appendix F 

February 2011 F-69 NUREG-1937 

well as the existing units (TCEQ 2005). During the operation of the existing units, no discharge 

from the MCR to the Colorado River has been needed to maintain the dilute solutes present in 

MCR water quality at acceptable levels for the circulating water systems. The current TPDES 

permit allows an average daily MCR discharge of 144 million gallons per day (MGD) with a daily 

maximum of 200 MGD. The average daily MCR discharge temperature is limited to 95°F with a 

daily maximum of 97°F. Total residual chlorine in the MCR discharge is limited to a daily 

maximum of 0.05 mg/L. The pH of the MCR discharge is limited to between 6.0 and 9.0 

standard units. The TPDES permit specifies that MCR discharge must not exceed 12.5 percent 

of the flow of the Colorado River at the discharge point. The permit also restricts the MCR 

discharges to periods when the flow of the Colorado River adjacent to the site is 800 cfs or 

greater. Whole effluent toxicity testing (i.e., biomonitoring) of the MCR water is also required 

prior to discharging water into the river (TCEQ 2005). The MCR discharge facility consists of 

seven submerged ports located on the west bank of the Colorado River approximately 2 mi 

downstream of the RMPF. Each port can discharge at a maximum rate of 44 cfs, for a total 

maximum MCR discharge of 308 cfs (STPNOC 2009a). 

STPNOC stated that, as part of their operating policy, they would discharge water from the MCR 

into the Colorado River when they are concurrently pumping water at the RMPF (STPNOC 

2009d). STPNOC would discharge water from the MCR when the specific conductivity of the 

water in the MCR exceeds 3000 microsiemens per centimeter (μS/cm). STPNOC would pump 

makeup water from the Colorado River under conditions specified by the Lower Colorado River 

Authority (LCRA) contract. The conditions that STPNOC would consider when planning to 

discharge from the MCR include: when the MCR water level is between 40 and 49 ft MSL; 

when the river water conductivity is less than 2100 μS/cm; and when the river flow at the 

discharge facility is greater than or equal to 2500 cfs. STPNOC revised these conditions and 

indicated that they might discharge MCR water when the river flow is as low as 800 cfs, as 

permitted by their TPDES permit (TCEQ 2005; STPNOC 2009e). If all these conditions are met, 

STPNOC would then only discharge when the MCR water had a conductivity greater than or 

equal to 3000 μS/cm. STPNOC would cease discharging when any of those conditions 

changed or when the MCR water had a conductivity less than or equal to 2100 μS/cm 

(STPNOC 2009d). STPNOC estimated that the need for discharging would likely be as frequent 

as once every 11 days and could be continuous for as nearly much as 75 days. No information 

was provided on the most likely time of year for discharging water (STPNOC 2009d). 

STPNOC (STPNOC 2009a) as well as the NRC and Corps review team evaluated the 

maximum thermal plume from the discharge of the MCR water into the Colorado River using the 

Cornell Mixing Zone Expert System (CORMIX). The maximum thermal plume dimensions 

would occur when there was the greatest difference in temperatures between the MCR water 

and the water in the river (20.4°F) and a discharge rate from the MCR was the greatest (308 

cfs). Under these discharge conditions, the minimum streamflow of the Colorado River would 
Appendix F 

NUREG-1937 F-70 February 2011

be 2464 cfs based on the specifications of the TPDES permit where the discharge volume 

cannot be less than 12.5 percent of the streamflow in the Colorado River. 

Based on the results of the CORMIX modeling of the maximum expected thermal plume 

dimensions, the thermal plume that is 5°F above ambient conditions would be attached to the 

bottom of the river from the discharge pipe to 120 ft downstream, and the plume would extend 

approximately 25 percent across the width of the river. Approximately 100 ft downstream of the 

last discharge port, the plume becomes buoyant rises to the surface of the river. The surface of 

the river is predicted to have an elevated temperature from approximately 1060 ft downstream 

of the last discharge port to about 4400 ft downstream from the discharge ports. Under these 

conditions, there would be a portion of the water column that would remain at ambient river 

temperatures as the plume rises to the surface and extends from bank to bank that would allow 

foraging fish (e.g., Gulf menhaden, black drum [Pogonias cromis], striped mullet) to move up 

and downstream. Also, the invertebrate species (e.g., grass [Palaemonetes pugio], white and 

brown shrimp) and other bottom dwellers would be able to pass along the bottom of the river on 

the far side of the discharge structure without passing through the elevated temperature plume. 

The review team evaluated the possibility that the thermal plume generated by discharging the 

MCR water into the Colorado River could coincide with poor water quality for aquatic organisms 

in the river at the discharge structure. ENSR (2008a) measured water quality, e.g., salinity and 

dissolved oxygen, at various levels in the water column while collecting fish and shellfish. There 

are times of the year that ENSR reported the water at the bottom of the river was anoxic or low 

in dissolved oxygen (hypoxic, or with dissolved oxygen less than 2 mg/L) when the salinity was 

high. The conditions were most often observed at or below the mid point of the water column. 

The combination of the maximal thermal plume and poor river water conditions (e.g., high 

salinity and low dissolved oxygen) would force aquatic species to avoid the area completely. 

STPNOC compared the results reported by ENSR (2008a) and the flow in the river at the 

nearest gaging station at the time of the water sampling, and determined that the salinity at the 

bottom of the river during flows greater than 800 cfs had salinities ranging from 0 to 18.7 ppt 

(STPNOC 2008a). The review team further evaluated the river flows greater than 800 cfs and 

dissolved oxygen at the bottom of the river and found that there was only one occurrence during 

2007-2008 when the flow was greater than 800 cfs and the dissolved oxygen was less than or 

equal to 2 mg/L. In addition, the salinity at this sampling time was 17.5 ppt (ENSR 2008b). 

Although there is limited information available on river flow and water quality, the operating 

policy that STPNOC has established for discharging MCR water into the river in compliance with 

requirements in their TPDES permit would likely result in infrequent opportunities for discharging 

when the combined effect of the thermal plume with river conditions would cause harm to the 

aquatic community. The adult and juvenile life stages of the EFH species would likely avoid the 

thermal plume, but there could be some impacts to the earlier life stages that would not be able 

to avoid the plume. Depending on the frequency and duration of the discharge, the early life 

stages could be lost from the effects of the thermal plume. 
Appendix F 

February 2011 F-71 NUREG-1937 

Chemical effects on the aquatic community from future discharges from the MCR into the 

Colorado River can be evaluated in terms of compliance with the STPNOC’s TPDES permit. 

Inputs to the MCR include makeup water from the river, precipitation, dissolved solids from the 

operation of the condensers and UHSs for all units, and permitted chemical discharges from 

other operations (e.g., treated sanitary sewage, biocides, algaecides, corrosion inhibitors, pH 

buffering, scale inhibitors, and dispersants). The most significant chemical changes in the MCR 

would be the concentration of total dissolved solids from the operation of the condensers and 

UHSs. STPNOC does not currently evaluate the water quality of the MCR in relation to the 

TPDES permit conditions for chemical standards for the protection of aquatic life because it is 

not currently discharging to the Colorado River. The permit conditions also require evaluating 

acute and chronic effects on aquatic organisms from the MCR discharge prior to commencing 

discharge into the river. 

Physical effects from the operation of the discharge system in the Colorado River could affect 

aquatic resources, particularly through scouring of aquatic habitat. The NRC evaluated 

discharge-induced scouring of the seven-port diffuser and concluded that scouring would be 

limited to a few feet downstream of each port and would have “no adverse impacts” on the 

aquatic biota in the vicinity (NRC 1975). Since the discharge pipes have not been operated 

except for a test in 1997 (STPNOC 2009a) and the Colorado River in the vicinity of the pipes 

has not been dredged recently, the initial discharge of water would disturb the sediments in the 

area. Because the small predicted size of the potential scour area and relative impoverishment 

of the benthic community that would be replaced with time, the physical effects from the 

operation of the would have a minor effect on the regional benthic populations or their 

predators. 

Maintenance Dredging. STPNOC has stated that periodic dredging in the future would be 

conducted in front of the RMPF and barge slip. These activities are currently covered by 

existing permits with the Corps for the operation of existing Units 1 and 2. Dredging would 

remove benthic habitat and the organisms that are not highly mobile (e.g., mollusks). The area 

to be dredged in front of the RMPF and at the barge slip would likely be no more than 3 ac total, 

and would not cover the entire width of the river channel. Highly mobile organisms would likely 

avoid the area during dredging activities. After dredging activities, these areas would be 

recolonized by the aquatic community. Impacts from dredging on aquatic organisms would be 

minor. 

5.3 Potential Effects of the Proposed Federal Actions on 

EFH Species 

The species and life stages by the Gulf of Mexico Fishery Management Council for Ecoregion 5 

rely on habitats essential for species propagation. Below, each species is discussed with 

regard to the impact of the proposed Federal action on EFHs. The potential impacts of the 
Appendix F 

NUREG-1937 F-72 February 2011

construction and operation of the proposed STP Units 3 and 4 on Federally managed fish and 

shellfish species and their designated EFH, including their prey, near the site have been 

evaluated. Six categories of impacts related to STP construction and operation that could 

influence EFH are (1) siltation or turbidity during construction; (2) barge traffic creating turbidity 

or sedimentation; (3) impingement of juveniles or adults; (4) entrainment and entrapment of 

eggs, larvae, and zooplankton in the water column; (5) release of heated cooling water 

containing biocides or other chemicals; and (6) maintenance dredging at the RMPF and at the 

barge slip. 

5.3.1 King Mackerel 

Disruption of habitat for foraging in the Colorado River is expected to be minor, temporary, and 

largely mitigable. Construction activities around the RMPF and barge slip would involve a 

minimal area where juvenile king mackerel might be foraging. Barges moving heavy equipment 

and bulk commodities are likely to be moving slowly and prop wash and wave action from the 

vessel’s movement would not affect juvenile mackerel in the vicinity. Therefore, construction 

would likely have a minimal adverse effect on juvenile king mackerel EFH. Operation of the 

RMPF is not expected to have an impact on the juveniles directly or indirectly since they and 

their prey should be able to swim away from the low approach velocities at the RMPF intake 

screens. Juvenile king mackerel and their pray are expected to avoid areas affected by 

thermal, chemical and physical changes in the Colorado River from the discharge of the MCR 

water and maintenance dredging at the RMPF. Their prey should be able to avoid the adverse 

effects from the discharge system as well. Operations of the RMPF and discharge system are 

not continuous, and their adverse effects would be relatively short in duration. Therefore, the 

construction and operation of the proposed Units 3 and 4 at the STP site are likely to have a 

minimal adverse effect on EFH for the king mackerel juveniles. 

5.3.2 Spanish Mackerel 

Construction activities would occur in a small proportion of available Spanish mackerel foraging 

habitat within the Colorado River at the site of intake and barge slip modifications. Barges 

moving heavy equipment and bulk commodities are likely to be moving slowly and prop wash 

and wave action from the vessel’s movement would not affect any of the life stages of Spanish 

mackerel in the vicinity. Disruption of habitat for foraging in these areas of the Colorado River 

from construction and operation are expected to be minor and temporary. Juvenile and adult 

Spanish mackerel and their pray are expected to avoid areas affected by thermal, chemical and 

physical changes in the Colorado River from the discharge of the MCR water. Spanish 

mackerel eggs and larvae could be affected by the thermal or chemical characteristics of the 

discharge plume depending on the river conditions, frequency, and duration of the discharge. 

Eggs and larvae passing through the intake screens at RMPF would be lost. However, 

operations of the RMPF and discharge system are not continuous, and their effects would be 
Appendix F 

February 2011 F-73 NUREG-1937 

relatively short in duration. Maintenance dredging at the RMPF could be easily avoided by 

juvenile and adult Spanish mackerel, but some eggs and larvae would be lost. Because no 

Spanish mackerel were collected in recent surveys near the STP site, it is unlikely that the small 

loss (from operation of the RMPF, discharge structure, and dredges) of eggs and larvae would 

be detectable. Therefore, the construction and operation of the proposed Units 3 and 4 at the 

STP site are likely to have a minimal adverse effect on EFH for Spanish mackerel eggs, larvae, 

juveniles, and adults. 

5.3.3 Gray Snapper 

Disruption of gray snapper foraging habitat in the Colorado River is expected to be minor, 

temporary, and largely mitigable from construction activities. Juvenile and adult gray snapper 

may move into estuarine habitats, like the downstream portion of the Colorado River. Eggs and 

larvae are unlikely to be in the areas of the discharge structure, barge slip and RMPF. 

Construction activities at the barge slip and RMPF would occur in a small proportion of available 

potential foraging habitat within the Colorado River. Barges moving heavy equipment and bulk 

commodities are likely to be moving slowly and prop wash and wave action from the vessel’s 

movement would not affect any of the life stages of gray snapper in the vicinity. Any larvae that 

move up the Colorado River may become entrained in the cooling water intake system; 

however, juveniles and adults would likely swim away from the low approach velocity at the 

intake screens. Juvenile and adult gray snapper and their prey are expected to avoid areas 

affected by thermal, chemical and physical changes in the Colorado River from the discharge of 

the MCR water. Eggs and larvae passing through the intake screens at RMPF would be lost. 

However, operations of the RMPF and discharge system are not continuous, and their effects 

would be relatively short in duration. Maintenance dredging at the RMPF could be easily 

avoided by the juvenile and adult gray snapper. Therefore, the construction and operation of 

the proposed Units 3 and 4 at the STP site are likely to have a minimal adverse effect on EFH 

for eggs, larvae, juvenile and adult life stages of the gray snapper. 

5.3.4 Red Drum 

Construction activities would occur in a small proportion of available potential foraging habitat 

within the Colorado River at the site of RMPF and barge slip modifications. There is no SAV in 

the Colorado River in the vicinity of the barge slip and RMPF for the younger life stages of red 

drum. Disruption of habitat for foraging in these areas of the Colorado River is expected to be 

minor and temporary. Therefore, construction activities upstream in the Colorado River are 

likely to have a minimal adverse effect on the red drum. Barges moving heavy equipment and 

bulk commodities are likely to be moving slow and prop wash and wave action from the vessel’s 

movement would not affect any of the life stages of red drum in the vicinity. Operation of the 

RMPF and discharge structure are not likely to affect the juvenile and adult red drum because 

they are capable of swimming out of the current created by the RMPF and can avoid the 
Appendix F 

NUREG-1937 F-74 February 2011

thermal, chemical and physical changes of the river water from the discharge of the MCR. 

However, eggs and larvae could become entrained at the RMPF and could be affected by the 

thermal, chemical and physical characteristics of the discharge plume, if they are transported up 

the Colorado River to the vicinity of the STP site. Maintenance dredging at the RMPF could be 

easily avoided by the juvenile and adult red drum, but some eggs and larvae would be lost. It is 

unlikely that the small loss (from operation of the RMPF, discharge structure, and dredges) of 

eggs and larvae would be detectable given the high fecundity of the red drum. Therefore, 

construction and operation of proposed STP Units 3 and 4 would likely have minimal adverse 

impact on red drum juvenile and adult EFH. STP operations would likely have a minimal 

adverse effect on EFH for red drum eggs, larvae, juveniles, and adults. 

5.3.5 Shrimp 

Juvenile and adult brown, pink, and white shrimp may forage within the Colorado River at or 

near the RMPF and barge slip. Disruption of habitat for foraging in these areas of the Colorado 

River is expected to be minor, temporary, and largely mitigable. Brown, pink, and white shrimp 

have been collected in the MCR and all along the Colorado River during the 1983-1984 and 

2007-2008 sampling studies (ENSR 2008a, b). Construction activities at the RMPF and barge 

slip could remove habitat through turbidity and sedimentation resulting in siltation on the river 

bottom. The sheet pile wall that could be erected during barge slip modification would 

temporarily remove habitat for the shrimp. Barges moving heavy equipment and bulk 

commodities are likely to be moving slow and prop wash and wave action from the vessel’s 

movement would not affect any of the life stages of shrimp as they are benthic. Larvae and 

juvenile brown, pink, and white shrimp would be lost if entrained at the RMPF. Operation of the 

RMPF is not likely to entrain appreciable numbers of shrimp larvae, as brown and white shrimp 

were more abundant at the confluence of the river and the GIWW than further up the river 

(ENSR 2008a), and only four pink shrimp were reported in impingement studies (NRC 1986). 

Maintenance dredging would remove habitat at the point where substrate is dredged and could 

also temporarily remove habitat from turbidity and sedimentation. Therefore, construction and 

operation of the proposed Units 3 and 4 at the STP site are likely to have a greater than 

minimal, but less than substantial, adverse effect on EFH for the brown, pink, and white shrimp 

larvae and juveniles EFH. 

5.3.6 Gulf Stone Crab 

It is possible that construction activities in the Colorado River associated with intake structure 

placement and barge slip modifications may disrupt foraging in these areas of the Colorado 

River, but the disruption is expected to be minor, temporary, and largely mitigable. Gulf stone 

crab eggs and larvae may drift into the upper portion of the Colorado River, and become 

entrained in the cooling water intake system at the RMPF. However, it is unlikely that 

appreciable numbers of eggs or larvae would be entrained as no Gulf stone crabs were 
Appendix F 

February 2011 F-75 NUREG-1937 

collected in the Colorado River during the 1983-1984 or 2007-2008 studies (NRC 1986; ENSR 

2008a, b). Operation of the discharge structure would likely have minimal effect on the mobile 

adult and juvenile life stages. While eggs and larvae could be harmed by the thermal and 

chemical plume, it is unlikely that these life stages are present in the vicinity of the discharge 

structure. Therefore, construction and operation of the proposed STP Units 3 and 4 would likely 

have a minimal adverse effect on stone crab EFH for eggs, larvae, juveniles, and adults. 

6.0 Mitigation Measures 

Potential mitigation measures regarding water withdrawal at the RMPF, chemical and thermal 

reductions within the discharge to the Colorado River, frequency and conditions of discharge, 

and dredging techniques could reduce adverse effects on EFH and Federally-managed fish and 

shellfish species. Because the proposed cooling system would be closed-cycle and use the 

best technology available, the review team could not identify any potential mitigation measures 

to further reduce entrainment and entrapment. However, a potential mitigation measure that 

might increase impingement survival would be to alter the fish-return operational procedure 

such that the fish return always functions when the RMPF is withdrawing water. The review 

team also identified that the discharge operational procedure could be modified to reduce 

potential impacts on aquatic biota; such modifications could include mixing ambient river water 

with the discharge water before discharging it to the river to reduce the discharge temperature. 

Although the NRC lacks the statutory authority to require any of the above potential mitigation 

measures, the staff recognizes that such potential mitigation could further reduce adverse 

impacts on designated EFH and on Federally-managed fish and shellfish species in the 

Colorado River, the GIWW, and Matagorda Bay. 

The Corps permit, if issued, could include special conditions such as time-of-year restrictions or 

specific methods of work to ameliorate potential impacts to EFH for the authorized construction 

and maintenance dredging activities. EFH Conservation Recommendations necessary to 

protect EFH may also be included as conditions in the Corps permit, if issued. Mitigation may 

only be employed after all appropriate and practical steps to avoid and minimize adverse 

impacts to aquatic resources have been taken. All remaining unavoidable impacts must be 

compensated to the extent appropriate and practicable. 

7.0 Conclusions 

The potential impacts of the construction and operation of the proposed Units 3 and 4 at the 

STP site on Federally-managed fish and shellfish species and their EFH near the site have 

been evaluated. Based on the project design, the minimal short-term impacts associated with 

the construction activities, barging, operation of the RMPF and discharge structure, and 

maintenance dredging at the RMPF, and the mitigation measures planned for proposed Units 3 
Appendix F 

NUREG-1937 F-76 February 2011

and 4, the review team concludes that construction and operation of STP would likely have 

more than minimal, but less than substantial, adverse effects on EFH within the Colorado River 

by loss of forage and/or shelter habitat for three of the eight species considered, brown, pink, 

and white shrimp, specifically larvae and juveniles (Table 5). Construction and operation 

activities would likely have minimal adverse effect on the remaining species considered. The 

NRC lacks the statutory authority to require any mitigation measures that would minimize 

adverse effects on EFH. The Corps does not recommend any mitigative measures to minimize 

adverse effects on EFH at this time. This determination may be modified if additional 

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 

foraging habitat temporarily. 
Appendix F 

February 2011 F-77 NUREG-1937 

Table 1. Effects on EFH from Proposed Actions 

Common Name Life Stage Expected Impact 

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 

would remove habitat and could temporarily remove 
Appendix F 

NUREG-1937 F-78 February 2011

Table 1. Effects on EFH from Proposed Actions 

Common Name Life Stage Expected Impact 

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. 

8.0 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 
Appendix F 

February 2011 F-79 NUREG-1937 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52. “Licenses, 

Certifications, and Approvals for Nuclear Power Plants.” 

69 FR 41576. July 9, 2004. “National Pollutant Discharge Elimination System—Final 

Regulations to Establish Requirements for Cooling Water Intake Structures at Phase II Existing 

Facilities.” Federal Register. U.S. Environmental Protection Agency, Washington, D.C. 

72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

Federal Register. U.S. Nuclear Regulatory Commission, Washington, D.C. 

Buckley, J. 1984. Habitat Suitability Index Models: Larval and Juvenile Red Drum. 

FWS/OBS-82-10.74, U.S. Fish and Wildlife Service, Washington, D.C. 

Cascorbi, A. 2004. “Wild-Caught Warmwater Shrimp (Infraorder Penaeus – the Penaid 

Shrimps).” Seafood Watch, Seafood Report. Monterey Bay Aquarium, Monterey, California. 

Coastal Zone Management Act of 1972, as amended. 16 USC 1451, et seq. 

Croker, R. 1962. “Growth and Food of the Gray Snapper, Lutjanus Griseus, in the Everglades 

National Park.” Transactions of the American Fisheries Society 91(4):379-383. 

DeVries, D., CB Grimes, KL Lang, and DB White. 1990. “Age and Growth of King and Spanish 

Mackerel Larvae and Juveniles from the Gulf of Mexico and U.S. South Atlantic Bight.” 

Environmental Biology of Fishes 29(1990):135-143. 

ENSR Corporation (ENSR). 2008a. Aquatic Ecology – Main Cooling Reservoir and Circulating 

Water Intake Structure Study, Unit 3 and 4 Licensing Project. Houston, Texas. 

ENSR Corporation (ENSR). 2008b. Aquatic Ecology – Colorado River Monitoring Report, 

Unit 3 and 4 Licensing Project. Houston, Texas. 

Federal Water Pollution Control Act (Clean Water Act). 33 USC 1251, et seq. 

Florida Fish and Wildlife Conservation Commission (FFWCC). 2007. “Red Drum, Sciaenops 

Ocellatus.” Florida Fish and Wildlife Conservation Commission. 

Florida Museum of Natural History (FMNH). 2009. “Ichthyology at the Florida Museum of 

Natural History, Education, Biological Profiles: King Mackerel.” Accessed January 29, 2010 at 

http://www.flmnh.ufl.edu/fish/gallery/descript/kingmackerel/kingmackerel.html. Accession No. 

ML100600370. 
Appendix F 

NUREG-1937 F-80 February 2011

Guillory, V., H.M. Perry, and R.L. Leard. 1995. “A Profile of the Western Gulf Stone Crab, 

Menippe adina.” Number 31, Gulf States Marine Fisheries Commission, Ocean Springs, 

Mississippi. 

Gulf of Mexico Fishery Management Council (GMFMC). 2004. Final Environmental Impact 

Statement for the Generic Essential Fish Habitat Amendment to the Following Fishery 

Management Plans of the Gulf of Mexico (GOM): Shrimp Fishery of the Gulf of Mexico, Red 

Drum Fishery of the Gulf of Mexico, Reef Fish Fishery of the Gulf of Mexico, Stone Crab Fishery 

of the Gulf of Mexico, Coral and Coral Reef Fishery of the Gulf of Mexico, Spiny Lobster Fishery 

of the Gulf of Mexico and South Atlantic Coastal Migratory Pelagic Resources of the Gulf of 

Mexico and South Atlantic. National Oceanic and Atmospheric Administration, Tampa, Florida. 

Gulf States Marine Fisheries Commission (GSMFC). 1995. A Profile of the Western Gulf Stone 

Crab, Menippe Adina. Number 31, National Oceanic and Atmospheric Administration, Ocean 

Springs, Mississippi. 

Kim, H.C., and P.A. Montagna. 2009. “Implications of Colorado River (Texas, USA) Freshwater 

Inflow to Benthic Ecosystem Dynamics: A Modeling Study.” Estuarine, Coastal and Shelf 

Science 83:491–504. 

Lower Colorado River Authority (LCRA). 2006. Matagorda Bay Freshwater Inflow Needs 

Study. Lower Colorado River Authority, Texas Commission on Environmental Quality, Texas 

Parks and Wildlife, and Texas Water Development Board, Austin, Texas. Available at 

http://www.lcra.org/library/media/public/docs/fins_2006.pdf. Accession No. ML100600370. 

Magnuson-Stevens Fishery Conservation and Management Act, as amended. 16 USC 1801 et 

seq. 

National Marine Fisheries Service (NMFS). 1999. Essential Fish Habitat: New Marine Fish 

Habitat Conservation Mandate for Federal Agencies. National Marine Fisheries Service, Habitat 

Conservation Division, Southeast Regional Office, St. Petersburg, Florida. 

National Marine Fisheries Service (NMFS). 2004. Essential Fish Habitat Consultation 

Guidance Version 1.1. National Marine Fisheries Service, Office of Habitat Conservation, 

Silver Spring, Maryland. 

National Marine Fisheries Service (NMFS). 2009. “Essential Fish Habitat EFH Mapper.” 

NOAA Fisheries Services, Office of Habitat Conservation, Habitat Protection Division. 

Accessed May 20, 2009 at http://sharpfin.nmfs.noaa.gov/website/EFH_Mapper/map.aspx. 

Accession No. ML100600370. 
Appendix F 

February 2011 F-81 NUREG-1937 

Patillo, M.E., T.E. Czapla, D.M. Nelson, and M.E. Monaco. 1997. Distribution and Abundance 

of Fishes and Invertebrates in Gulf of Mexico Estuaries, Volume II: Species Life History 

Summaries. ELMR Rep. No. 11. NOAA/NOS Strategic Environmental Assessments Division, 

Silver Spring, Maryland. 

Permits for Dredged or Fill Material. 33 USC 1344. 

Rivers and Harbors Appropriation Act of 1899, as amended. 33 USC 403, et seq. 

South Texas Project Nuclear Operating Company (STPNOC). 2008a. Letter from Greg 

Gibson, STPNOC, to NRC, dated July 2, 2008 in response to NRC letter dated May 19, 2008, 

"South Texas Project Units 3 and 4, Docket Nos. 52-012 and 52-013, Response to Requests for 

Additional Information.” Accession No. ML081970465. 

South Texas Project Nuclear Operating Company (STPNOC). 2008b. Letter from Greg 

Gibson, STPNOC, to NRC, dated July 15, 2008, Response to Requests for Additional 

Information.” Accession No. ML082040684. 

South Texas Project Nuclear Operating Company (STPNOC). 2008c. Letter from Scott Head 

STPNOC, to NRC, dated December 18, 2008, Responses to Requests for Additional 

Information.” Accession No. ML090860873. 

South Texas Project Nuclear Operating Company (STPNOC). 2009a. South Texas Project 

Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 3, Bay 

City, Texas. Accession No. ML092931600. 

South Texas Project Nuclear Operating Company (STPNOC). 2009b. Letter from Scott Head, 

STPNOC, to NRC, dated September 14, 2009, “Responses to Request for Additional 

Information.” Accession No. ML092580491. 

South Texas Project Nuclear Operating Company (STPNOC). 2009c. Letter from Scott Head, 

STPNOC, to US Army Corps, dated October 28, 2009, “Subject: South Texas Project, Permit 

Determination Request, Construction Activities in Association with STP Units 3 & 4.” Accession 

No. ML093210232. 

South Texas Project Nuclear Operating Company (STPNOC). 2009d. Letter from Scott Head, 

STPNOC, to NRC, dated July 30, 2009, “Subject: South Texas Project, NRC Docket No. 52-

012 and 52-013, Submittal of Requests for Additional Information (RAI), Pertaining COLA Part 3 

Environmental Report.” Accession No. ML092150963. 

Texas Commission on Environmental Quality (TCEQ). 2005. TPDES Permit 

No. WQ0001908000. TCEQ, Austin, Texas. 
Appendix F 

NUREG-1937 F-82 February 2011

Texas Commission on Environmental Quality (TCEQ). 2007. Cooling Water Intake Structures 

Phase II Rules; South Texas Project Electric Generating Station; TPDES Permit No. WQOOO 

1908000. Letter from Mr. Kelly Holligan, TCEQ to Mr. R. A. Gangluff, STPNOC. June 27. 

Texas Commission on Environmental Quality (TCEQ). 2008. General Permit to Discharge 

Wastes under provisions of Section 402 of the Clean Water Act and Chapter 26 of the Texas 

Water Code. TCEQ Docket No. 2007-1588-WQ, TPDES General Permit No. TXR150000, 

Issues February 15, 2008. Austin, Texas. 

Texas Parks and Wildlife Department (TPWD). 2009. “Saltwater Fishing.” Texas Parks and 

Wildlife Department, Austin, Texas. Accessed January 27, 2010 at 

http://www.tpwd.state.tx.us/publications/annual/fish/limits_saltwater/index.phtml#limits. 

Accession No. ML100600370. 

Texas Saltwater and Fishing Guides Web (TSFGW). 2005. “King Mackerel (Kingfish).” 

Accessed November 24, 2009 at 

http://www.txsaltwaterfishingguides.com/FishFacts/kingfish.htm. Accession No. ML100600370. 

U.S. Army Corps of Engineers (Corps). 2005. “Galveston District Projects, Mouth of the 

Colorado River.” U.S. Army Corps of Engineers, Galveston District, Galveston, Texas. 

Accessed December 16, 2009 at http://www.swg.usace.army.mil/items/coloradoriver/MOC.asp. 

Accession No. ML100600370. 

U.S. Army Corps of Engineers (Corps). 2007. Draft Environmental Impact Statement for 

Calhoun County Navigation District’s Proposed Matagorda Ship Channel Improvement Project 

Calhoun and Matagorda Counties, Texas. Document No. 060146, U.S. Army Corps of 

Engineers, Galveston District, Galveston, Texas. 

U.S. Army Corps of Engineers (Corps). 2008. Final Environmental Impact Statement for the 

Proposed Port Freeport Channel Widening, Brazoria County, Texas. U.S. Army Corps of 

Engineers, Galveston District, Galveston, Texas. 

U.S. Army Corps of Engineers (Corps). 2009a. “December 2009 Hydrographic Bulletin: 

Channels with Project Depths Under 25 Feet.” U.S. Army Corps of Engineers, Galveston 

District, Galveston, Texas. 

U.S. Army Corps of Engineers (Corps). 2009b. Letter from K. Jaynes, Chief, Compliance 

Section, U.S. Army Corps of Engineers Galveston District to G. Gibson, South Texas Project 

Operating Company dated April 7, 2009, “Subject: SWG-2008-1351, South Texas Project 

Operating Company, Jurisdictional Determination, 7,000-Acre Mass Cooling Reservoir (MCR), 

Wadsworth, Matagorda County, Texas.” Accession No. ML091050501. 
Appendix F 

February 2011 F-83 NUREG-1937 

U.S. Fish and Wildlife Service (FWS). 1983. Habitat Suitability Index Models: Northern Gulf of 

Mexico Brown Shrimp and White Shrimp. FWS/OBS-82/10.54, Slidell, Louisiana. 

U.S. Nuclear Regulatory Commission (NRC). 1975. South Texas Project, Units 1 and 2: Final 

Environmental Statement. NUREG-75/019, Houston Lighting & Power Company, City Public 

Service Board of San Antonio, Central Power and Light Company, City of Austin. 

U.S. Nuclear Regulatory Commission (NRC). 1986. Final Environmental Statement Related to 

the Operation of South Texas Project, Units 1 and 2. NUREG-1171, Washington, D.C. 

Wilber, D. 1989. “Reproductive Biology and Distribution of Stone Crabs (Xanthidae, Menippe) 

in the Hybrid Zone on the Northeastern Gulf of Mexico.” Marine Ecology Progress Series

52(1989):235-244. 

Wilber, D.H. and R. Bass. 1998. “Effect of the Colorado River Diversion on Matagorda Bay 

Epifauna.” Coastal and Shelf Science 47:309-318. 

Appendix G 

Supporting Documentation for Socioeconomic and 

Radiological Dose Assessment 

February 2011 G-1 NUREG-1937 

Appendix G 

Supporting Documentation for Socioeconomics and 

Radiological Dose Assessment 

This appendix contains supporting documentation for review team determinations described in 

this environmental impact statement (EIS) for the socioeconomic and radiological dose 

assessments. 

G.1 Socioeconomic Data Tables 

This section contains two data tables (Table G-1 and Table G-2) related to socioeconomics as 

discussed in Section 2.5. 
NUREG-1937 G-2 February 2011 

Appendix G Table G-1. Current Populations by Distance and Direction and Projections to 2080 (STPNOC 2010a) 

Sectors 

Radii/Distances (miles) 

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
Appendix G 

February 2011 G-3 NUREG-1937 Table G-1. (contd) Sectors Radii/Distances (miles) 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
NUREG-1937 G-4 February 2011 

Appendix G Table G-1. (contd) 

Sectors 

Radii/Distances (miles) 

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 

February 2011 G-5 NUREG-1937 Table G-1. (contd) Sectors Radii/Distances (miles) 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 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
NUREG-1937 G-6 February 2011 

Appendix G Table G-1. (contd) 

Sectors 

Radii/Distances (miles) 

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 

February 2011 G-7 NUREG-1937 Table G-1. (contd) Sectors Radii/Distances (miles) 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 NW 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
NUREG-1937 G-8 February 2011 

Appendix G Table G-1. (contd) 

Sectors 

Radii/Distances (miles) 

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 2010a 
Appendix G 

February 2011 G-9 NUREG-1937 

Table G-2. Total STP Workforce During Construction Period for Proposed Units 3 and 4, and 

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 
Appendix G 

NUREG-1937 G-10 February 2011 

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 

February 2011 G-11 NUREG-1937 

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 

NUREG-1937 G-12 February 2011 

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 2010a

(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 

G.2 Supporting Documentation on Radiological Dose 

Assessment 

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed and performed an independent 

dose assessment of the radiological impacts from normal operations of the new and existing 

nuclear units at the South Texas Project Electric Generating Station (STP). The results of the 

assessment are presented in this appendix and are compared to the results from STP Nuclear 

Operating Company’s (STPNOC’s) assessment found in the Environmental Report (ER) 

(STPNOC 2010a), Sections 4.5, Radiation Exposure to Construction Workers, and 5.4, 

Radiological Impacts of Normal Operation. This appendix is divided into five sections: (1) dose 

estimates to the public from liquid effluents; (2) dose estimates to the public from gaseous 

effluents; (3) cumulative dose estimates; (4) dose estimates to biota from gaseous and liquid 

effluents, and (5) dose to construction workers. 

G.2.1 Dose Estimate to the Public from Liquid Effluents 

The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 

(NRC 1977) and the LADTAP II computer code (Strenge et al. 1986) to estimate doses to the 

maximally exposed individual (MEI) and the population from the liquid effluent pathway of 

proposed Units 3 and 4. The NRC staff used the projected radioactive effluents release values 

from the Final Safety Analysis Report (STPNOC 2010b). 
Appendix G 

February 2011 G-13 NUREG-1937 

G.2.1.1 Scope 

Doses from each new unit to the MEI were calculated and compared to the regulatory criteria for 

the following: 

• Total Body – Dose was the total for the ingestion of aquatic organisms and cow meat and 

external exposure to contaminated sediments deposited along the shoreline (shoreline 

exposure). Water downstream from the STP site is used for neither drinking water nor 

irrigation. 

• Organ – Dose was the total for each organ for ingestion of aquatic food and cow meat and 

shoreline exposure with the highest value for adult, teen, child, or infant. 

The NRC staff reviewed the assumed exposure pathways and input parameters and values 

used by STP for appropriateness. Default values from Regulatory Guide 1.109 (NRC 1977)

were used when site-specific input parameters were not available. The NRC staff concluded 

that the assumed exposure pathways were appropriate – ingestion of aquatic organisms and 

shoreline exposure only – because water downstream of the site is not used for drinking or 

irrigation. In addition, the input parameters and values used by STPNOC were appropriate. 

NRC staff assessment added the meat cow pathway from livestock drinking water from 

groundwater wells. 

G.2.1.2 Resources Used 

To calculate doses to the public from liquid effluents the NRC staff used a personal computer 

version of the LADTAP II code entitled NRCDOSE, version 2.3.10 (Chesapeake Nuclear Services, 

Inc. 2006) obtained through the Oak Ridge Radiation Safety Information Computational Center 

(RSICC). The meat cow dose was estimated using LADTAP parameters. 

G.2.1.3 Input Parameters 

Table G-3 lists the major parameters used in calculating dose to the public from liquid effluent 

releases during normal operation. It should be noted that the 50-mi population was assumed to 

be for the year 2060, which is an overestimate of the population and is considered to be 

conservative. Section 5.4.1 of the Environmental Standard Review Plan (ESRP) (NRC 2000) 

guidance suggests that populations be projected only five years out from the date of the licensing 

action under consideration. Groundwater concentration at the livestock well was assumed to be 

that predicted for the nearest offsite well, 1600 pCi/L (STPNOC 2010a). 

G.2.1.4 Comparison of Results 

NRC staff’s dose calculations confirmed the doses estimated by STPNOC. Dose from 

consumption of meat from cows consuming groundwater contaminated with tritium was 

estimated to be 0.0037, 0.0022, and 0.0026 mrem/yr for adults, teens, and children, respectively. 
Appendix G 

NUREG-1937 G-14 February 2011 

Table G-3. Single Unit Source Term for Liquid Effluent Pathways 

Parameter Staff Value Comments

Single new unit liquid 

effluent source term 

(Ci/yr) 

Fraction 

Reaching 

Colorado 

River

Fraction 

Reaching 

Matagorda 

Bay

Fraction 

Reaching 

Little 

Robbins 

Slough 

(STPNOC 2010b)

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 

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 

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

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

1.40 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

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

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

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

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

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 

February 2011 G-15 NUREG-1937 

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 2010a) 

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 2010a) 

50-mi invertebrate catch 1.8 x 106 kg/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2010a) 

50-mi shoreline usage 7.84 x 106 person-hr/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2010a) 

50-mi swimming, boating usage 3.92 x 106 person-hr/yr Site Specific from Table 5.4-1 of ER 

(STPNOC 2010a) 
Appendix G 

NUREG-1937 G-16 February 2011 

G.2.2 Dose Estimates to the Public from Gaseous Effluents 

The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 

1977) and the GASPAR II computer code (Strenge et al. 1987) to estimate doses to the MEI 

and to the public within 50 mi of the STP site from the gaseous effluent pathway for the 

proposed units. The NRC staff used the projected radioactive gaseous effluents release values 

from the Final Safety Analysis Report (STPNOC 2010b). 

G.2.2.1 Scope 

The NRC staff and STPNOC calculated the MEI dose at 2.18 mi west-southwest of the new 

units. Pathways included were plume, ground, inhalation, and ingestion of locally grown meat 

and vegetables. Milk consumption was not considered because there are no milk animals 

within 5 mi of the plant. 

The NRC staff reviewed the parameters and values used by STPNOC (2010a), for 

appropriateness. Default values from Regulatory Guide 1.109 were used when site or design 

specific input parameters were not available. The NRC staff concluded that the assumed 

exposure pathways and input parameters were appropriate. These pathways and parameters 

were used by the NRC staff in its independent calculations using GASPAR II. 

Joint frequency distribution data of wind speed and wind direction by atmospheric stability class 

for the STP site provided in ER Table 2.7-10 (STPNOC 2010a) were used as input to the 

XOQDOQ code (Sagendorf et al. 1982) to calculate the average X/Q and D/Q values for routine 

releases. XOQDOQ output from the applicant were examined and determined to be 

appropriate. 

Population doses were calculated for all types of releases (i.e., noble gases, particulates, 

iodines H-3 and C-14) using the GASPAR II code for the following: plume immersion, direct 

radiation from radionuclides deposited on the ground, inhalation, ingestion of vegetables, milk, 

and meat. 

G.2.2.2 Resources Used 

To calculate doses to the public from gaseous effluents, the NRC staff used a personal 

computer version of the XOQDOQ and GASPAR II computer codes entitled NRCDOSE version 

2.3.10 (Chesapeake Nuclear Services, Inc. 2006) obtained through the Oak Ridge RSICC. 

G.2.2.3 Input parameters 

Table G-4 lists the major parameters used in calculating doses to the public from gaseous 

effluents during normal operation. It should be noted that the 50-mi population was assumed to 

be for the year 2060, which is an overestimate of the population and is considered to be 

conservative. ESRP guidance suggests that populations be projected only five years out from 

the date of the licensing action under consideration (NRC 2000). 
Appendix G 

February 2011 G-17 NUREG-1937 

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 (2010a) references these 

values in Table 3.5-2 of the ER for a 

single new unit. These values are 

converted from the original SI units in 

MBq/yr to Ci/yr 
Appendix G 

NUREG-1937 G-18 February 2011 

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 2010a) 

Population distribution used by STP and 

the staff was for year 2060. 

Wind Speed and Direction Table 2.7-7 of the ER 

(STPNOC 2010a) 

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 2010a) 

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 2010a) 

Ground Deposition factors Tables 2.7-15 and 2.7-16 of 

the ER (STPNOC 2010a) 

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 

2010a) 

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 

2010a) 

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 

2010a) 

Pathway receptor locations 

(direction, and distance) – nearest 

Table 5.4-4 of the ER 

(STPNOC 2010a) 
Appendix G 

February 2011 G-19 NUREG-1937 

Table G-4. (contd)

Parameter Staff Value Comments

site boundary, MEI location 

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 2010a) 

Section 5.4.2.2of the ER 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 2010a) 

Fraction of year that milk cows 

are on pasture 

0.917 Table 5.4-3 of the ER (STPNOC 2010a) 

Fraction of MEI vegetable intake 

from own garden 

0.76 Table 5.4-3 of the ER (STPNOC 2010a) 

Fraction of year beef cattle are on 

pasture 

0.917 Table 5.4-3 of the ER (STPNOC 2010a) 

Fraction of year beef cattle intake 

is from pasture while on pasture 

1 Default value of GASPAR II code 

(Strenge et al. 1987). 

G.2.2.4 Comparison of Doses to the MEI from Gaseous Effluents 

NRC staff’s dose calculations confirmed the doses estimated by STPNOC, replicating the 

values shown in Table G-5. 
Appendix G 

NUREG-1937 G-20 February 2011 

Table G-5. Comparison of Cumulative Doses to the MEI with 40 CFR Part 190 Criteria 

(mrem per year) 

DOSE 

STP Units 1 and 2(a) STP Units 3 and 4

Site 

Total 

40 CFR Part 

Liquid Gaseous Total 190 Criteria

Direct(b)

Radiation Liquid(c) Gaseous Total 

Total Body 0.0042 0.0080 0.012 5 0.000525 0.70(d) 5.7 5.71 25 

Thyroid 0.0041 0.0097 0.014 NA 0.000406 4.54(e) 4.54 4.55 75 

Bone 0.00077 0.0011 0.0019 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 2010a). 

(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 2010a). 

(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.

G.2.3 Cumulative and Population Dose Estimates 

Based on parameters shown for the liquid pathway and the gaseous pathway, Table G-3 and 

Table G-4, respectively, doses from the two proposed units were calculated using LADTAP and 

GASPAR to the MEI. Doses from the existing units are taken from ER Table 5.4-8 (for the MEI) 

and Table 5.4-9 (for the population) (STPNOC 2010a). Table G-5 is the same table as ER 

Table 5-12 and compares cumulative dose estimates to the MEI with EPA’s dose criteria in 40 

CFR Part 190. Table G-5 includes doses from all pathways (i.e., external, liquid effluent and 

gaseous effluent) summed for existing Units 1 and 2 and proposed Units 3 and 4. 

Based on parameters shown for the liquid pathway and gaseous pathway (Table G-3 and 

Table G-4, respectively), doses were calculated using LADTAP and GASPAR to the population 

within 50 mi of the STP site (as discussed in Section G.2.1.3 and G.2.2.3). Table G-6 shows 

dose estimates to the population within 50-mi of the STP site from operation of proposed Units 3 

and 4. It should be noted that the 50-mi population was assumed to be for the year 2060, which 

is an overestimate of the population and is considered to be conservative. ESRP guidance 

suggests that populations be projected only five years out from the date of the licensing action 

under consideration. For comparison, the collective background dose to the regional population 

is estimated to be approximately 159,000 person-rem. This estimate is the 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

. 
Appendix G 

February 2011 G-21 NUREG-1937 

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. 

G.2.4 Dose Estimates to the Biota from Liquid and Gaseous Effluents 

To estimate doses to the biota from the liquid and gaseous effluent pathways, the NRC staff 

used the LADTAP II computer code (Strenge et al. 1986), the GASPAR II computer code 

(Strenge et al. 1987), and input parameters supplied by STPNOC in response to RAIs 

(STPNOC 2009). 

G.2.4.1 Scope 

It is acceptable to NRC staff to estimate radiation doses to representative biota species. Fish, 

invertebrates, and algae are used as reference aquatic biota species. Muskrats, raccoons, 

herons, and ducks are used as reference terrestrial biota species. The NRC staff recognizes 

the LADTAP II computer program as an appropriate method for calculating dose to the aquatic 

biota and for calculating the liquid-pathway contribution to terrestrial biota. The LADTAP II code 

calculates an internal dose component and an external dose component and sums them for a 

total body dose. Default values from Regulatory Guide 1.109 (NRC 1977) are used when sitespecific input parameters are not available. The NRC staff concluded that all of the input 

parameters used by STPNOC were appropriate. 

G.2.4.2 Resources Used 

To calculate doses to the biota from liquid effluents, the NRC staff used a personal computer 

version of the LADTAP II entitled NRCDOSE Version 2.3.10 (Chesapeake Nuclear Services, 

Inc. 2006). NRCDOSE was obtained through the Oak Ridge RSICC. 

Most of the LADTAP II input parameters are specified in Section G.2.1.3 to include the source 

term, the discharge flow rate to the receiving freshwater system, the shore-width factor, and 

fractions of radionuclides in the Main Cooling Reservoir (MCR) reaching offsite bodies of water. 

These parameter values are appropriate to use in calculating biota dose in the MCR. The NRC 

staff’s dose analysis confirmed the liquid pathway doses to biota shown in Table 5-13 and 

Table G-7. 
Appendix G 

NUREG-1937 G-22 February 2011 

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 

NRC staff assessed dose to terrestrial biota from the gaseous effluent pathway using GASPAR 

by assuming doses for raccoons and ducks were equivalent to adult human doses for 

inhalation, vegetation ingestion, plume and twice the ground pathways at the exclusion area 

boundary (EAB) at 0.52 mi northwest. STPNOC estimated the gaseous pathway doses to biota 

at the site boundary in the direction that resulted in the largest doses (maximum site boundary). 

The NRC staff concluded that terrestrial biota could live on the STP site and receive higher 

doses from the gaseous effluents. Therefore, the NRC staff estimated the doses at the 

exclusion area boundary (0.52 mi NW) to achieve a more reasonable estimate of doses to 

terrestrial biota that might live on the STP site (Table G-7). The doubling of doses from ground 

deposition reflects the closer proximity of these organisms to the ground. Muskrats and herons 

do not consume terrestrial vegetation, so that pathway was not included for those organisms. 

G.2.5 Dose to Construction Workers 

STPNOC used fenceline thermoluminescent dosimeters (TLDs) and environmental TLDs to 

measure direct radiation levels at locations in and around the STP Units 1 and 2 protected area 

(STPNOC 2010a). Sixteen TLDs are located along the protected area fence around existing 

Units 1 and 2 (Figure G-1). All TLDs are read quarterly and measure the contribution to dose 

from any source, either natural or anthropogenic, including the current reactor buildings and 

Onsite Staging Facility (OSF) (Figure G-2). Data from 2002 through 2006 are provided in 

Table G-8 through Table G-12. Data from this five-year period provide information indicative of 

plant conditions. Table G-12also contains data collected from around the Old Steam Generator 

Storage Facility (OSGSF) see Figure G-2. These tables show the maximum measured dose 

rate at monitoring stations 9 to 16 over the five years was 18.9 mR/quarter. 

The difference between the maximum protected area fence reading (18.9 mR/quarter) and the 

average background reading yields a net maximum dose rate of 6.4 mR/quarter, as shown in 

Table G-13. 
Appendix G 

February 2011 G-23 NUREG-1937 

Figure G-1. STP Units 1 and 2 Protected Area Monitoring Stations (STPNOC 2010a) 
Appendix G 

NUREG-1937 G-24 February 2011 

Table G-8. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2002 

Station 

Number 

Average Dose by Quarter (mR) 

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 2010a 

Table G-9. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2003 

Station 

Number 

Average Dose by Quarter (mR) 

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 2010a 

Table G-10. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2004 

Station 

Number 

Average Dose by Quarter (mR) 

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 2010a 
Appendix G 

February 2011 G-25 NUREG-1937 

Table G-11. TLD Measurements at STP Units 1 and 2 Monitoring Stations in 2005 

Station 

Number 

Average Dose by Quarter (mR) 

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 2010a 

Table G-12. TLD Measurements at STP Units 1 and 2 and Old Steam Generator Storage 

Facility Monitoring Stations in 2006 

Station 

Number 

Average Dose by Quarter (mR) 

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 2010a 
Appendix G 

NUREG-1937 G-26 February 2011 

Figure G-2. Locations of TLD Monitoring Stations at OSGSF (STPNOC 2010a) 
Appendix G 

February 2011 G-27 NUREG-1937 

Table G-13. Maximum Quarterly Measured Dose Rates at STP Units 1 and 2 and OSGSF 

Location 

Dose Rate (mrem/quarter) 

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 2010a). 

The net dose rate is calculated by subtracting the background dose rate from the maximum dose rate. 

A primary source of direct radiation exposure to the workers on STP Unit 4 will be the gamma 

radiation from nitrogen-16 in the STP Unit 3 steam lines and steam-bearing components such 

as turbines, moisture separators, and re-heaters (STPNOC 2010a). The plant shielding design 

acceptance criteria for the ABWR specify a maximum dose rate due to direct and scattered 

radiation of 2.5 mrem/yr at the EAB. The distances from STP Unit 3 to the EAB and to the STP 

Unit 4 reactor are 0.52 and 0.17 mi, respectively. The ABWR DCD does not describe the 

outside condensate storage tank that STPNOC proposes (STPNOC 2009). The dose rate from 

this tank was evaluated by NRC staff using the Microshield computer code and was 

encompassed by the 2.5 mrem/yr acceptance criteria. 

In 1986, prior to operation of STP Units 1 and 2, the background exposure rate measured at the 

site boundary was 15.4 mR/quarter. However, some of the current protected area fence line 

direct radiation measurements are lower than the 1986 site boundary measurements because 

the protected area was excavated and backfilled with sand and gravel that contained less 

naturally occurring radioactive material than exists in the native clay found near the site 

boundary. Between 2002 and 2006, the exposure rate along the protected area fence averaged 

12.5 mR/quarter; this will be used as the reference background exposure rate, see Table G-14. 

Worker dose rates presented in Table G-14 were estimated by the NRC staff in a manner 

similar to that used by STPNOC (2010a), except the NRC used the revised background rates as 

follows: 

• STP Units 1 and 2 – The dose rate from the waste monitor tanks at the construction area 

was calculated in the ER by multiplying the net quarterly dose rate by a factor of four, to 

convert to an annual dose rate, and then it was doubled for conservatism, yielding 

51.2 mrem/yr at the TLD on the protected area fence. Figures 4.5-1 and 4.5-2 in the ER 

show the distance from Unit 2 waste monitor tanks to the protected area fence to be about 

600 ft and the distance to the center of STP Unit 3 construction area is about 2300 ft. 

Setting DTLD = 51.2 mrem/yr, RTLD = 600 ft, and Rloc = 2300 ft, gives a dose rate of 

13.4 mrem/yr at the center of the construction area of Unit 3, for 100 percent occupancy. 

This can be reduced by the ratio of 2080 hr (worked)/8766 hr (per yr), yielding 3.2 mrem/yr 

to a worker (Table G-14). 
Appendix G 

NUREG-1937 G-28 February 2011 

Table G-14. Direct Radiation Doses to Unit 4 Construction Workers

Source 

Distance from Source (ft) Dose Rate (mrem/yr) Annual 

Dose to 

Worker 

(mrem) 

To TLD 

Location 

To Construction 

Location 

TLD 

Location 

Construction 

Location 

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. 

• OSGSF – The dose rate from the OSGSF was calculated by multiplying the net quarterly 

dose by four to get an annual dose rate, and then it was doubled for conservatism, yielding 

33.6 mrem/yr at the TLD. The distance from the exterior wall of the OSGSF is about 93 ft 

and the distance from the OSGSF to the center of STP Unit 4 construction area is about 

700 ft. Setting DTLD = 33.6 mrem/yr, RTLD = 93 ft, and Rloc = 700 ft gives a dose rate of 

4.5 mrem/yr at the center of the construction area of Unit 4, for 100 percent occupancy. 

This can be reduced by the ratio of 2080 hr (worked) / 8766 hr (per yr), yielding 1.07 

mrem/yr to a worker (Table G-14). 

• LTSF – The Long Term Storage Facility is not yet built yet but plans are to build it adjacent 

to the OSGSF. It is therefore assumed that the distance from the LTSF to the center of the 

construction area of STP Unit 4 is also 700 ft. Contamination smears and exposure 

measurements taken from the reactor vessel heads that will be stored in the LTSF and 

using MicroShield and MicroShine software yielded an exposure rate of 8×10-6 mR/hr at 

700 ft away. With fulltime occupancy, this results in a dose rate of 0.07 mrem/yr. This is 

conservatively rounded up to 1 mrem/yr for the construction location, and the annual dose to 

the construction worker of 0.24 mrem was obtained by multiplying by the ratio of 2080 hr 

(worked) / 8766 hr (per yr) (Table G-14). 

• OSF – As indicated above, the OSF will be relocated and have additional shielding provided 

such that the dose rate from this source will be negligible at the STP Units 3 and 4 

construction location. However, the dose rate from the OSF is conservatively assumed to 

be 1 mrem/yr at the construction location, and the annual dose to the construction worker of 

0.24 mrem was obtained by multiplying by the ratio of 2080 hr (worked) / 8766 hr (per yr) 

(Table G-14). 

• STP Unit 3 – STP Unit 3, including the CST, must be considered as a source of direct 

radiation to construction workers at STP Unit 4 during the timeframe between STP Unit 3 
Appendix G 

February 2011 G-29 NUREG-1937 

becoming operational and STP Unit 4 becoming operational. The plant shielding design 

acceptance criteria for the ABWR specify a maximum dose rate due to direct and scattered 

radiation of 2.5 mrem/yr at the EAB. Distances from STP Unit 3 to the EAB and to the STP 

Unit 4 reactor are 0.52 and 0.17 mi, respectively. Assuming the distances were great 

enough to consider the source a point source, the dose rate at the construction site was 

estimated at 23 mrem/yr. Adjusting the calculated dose rate at STP Unit 4 from operations 

of STP Unit 3 for worker occupancy (2080 hr worked / 8766 hr per yr) yields a worker dose 

rate of 5.5 mrem/yr. Adding the total direct radiation dose rate from STP Units 1 and 2 

(4.72 mrem/yr) to the Unit 3 direct radiation dose yields a total of 10.2 mrem/yr for the Unit 4 

construction worker (Table G-14). 

G.3 References 

40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental Radiation Protection Standards for Nuclear Power Operations.” 

Chesapeake Nuclear Services, Inc. 2006. NRCDOSE for Windows. Radiation Safety 

Information Computational Center, Oak Ridge, Tennessee. 

National Council on Radiation Protection and Measurements (NCRP). 2009. Ionizing Radiation 

Exposure of the Population of the United States. NCRP Report No. 160, Bethesda, Maryland. 

Sagendorf, J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the 

Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations. 

NUREG/CR-2919, Pacific Northwest National Laboratory, Richland, Washington. 

South Texas Project Nuclear Operating Company (STPNOC). 2009. Letter from Scott Head, 

STPNOC, to NRC, dated September 14, 2009, "Response to Request for Additional 

Information." Accession No. ML092580491. 

South Texas Project Nuclear Operating Company (STPNOC). 2010a. South Texas Project 

Units 3 and 4 Combined License Application, Part 3, Environmental Report. Revision 4, Bay 

City, Texas. Accession No. ML 102860592. 

South Texas Project Nuclear Operating Company (STPNOC). 2010b. South Texas Project 

Units 3 and 4 Combined License Application, Part 2, Final Safety Analysis Report. Revision 4, 

Bay City, Texas. Accession No. ML102860517. 

Strenge, D.L., R.A. Peloquin, and G. Whelan. 1986. LADTAP II – Technical Reference and 

User Guide. NUREG/CR-4013, Pacific Northwest Laboratory, Richland, Washington. 

Strenge, D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR II – Technical Reference and User 

Guide. NUREG/CR-4653, Pacific Northwest Laboratory, Richland, Washington. 
Appendix G 

NUREG-1937 G-30 February 2011 

U.S. Nuclear Regulatory Commission (NRC). 1977. Calculation of Annual Doses to Man from 

Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

10 CFR Part 50, Appendix I. Regulatory Guide 1.109, Washington, D.C. Accession 

No ML003740384. 

U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan —

Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

Vol. 1, Washington, D.C. Includes 2007 updates. 
Appendix H 

 

Authorizations, Permits, and Certifications 

February 2011 H-1 NUREG-1937 

Appendix H 

Authorizations, Permits, and Certifications 

This appendix contains a list of the environmental-related authorizations, permits, and 

certifications potentially required by STP Nuclear Operating Company (STPNOC) from Federal, 

State, regional, and local agencies related to the combined licenses for the two proposed new 

nuclear units, Units 3 and 4, at the South Texas Project (STP) site. The table is derived from 

Tables 1.2-1 through 1.2-4 of the Environmental Report submitted to the U.S. Nuclear 

Regulatory Commission (NRC). 
NUREG-1937 H-2 February 2011

Appendix H Table H-1. Other Authorizations, Permits, and Certifications Potentially Required by STPNOC 

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

NRC 10 Code of Federal 

Register (CFR) Part 30 

Byproduct License Approval to receive, possess, 

and use byproduct material. 

To be issued as part of COLs 

NRC 10 CFR Part 40 Source 

Materials 

License 

Approval to receive, possess, and use source material. 

To be issued as part of COLs 

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 receive, possess, 

and use special nuclear material. 

To be issued as part of COLs 

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 
February 2011 H-3 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) 
NUREG-1937 H-4 February 2011

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 

Individual Permit Application submitted 03/09/2010 

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 
February 2011 H-5 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. 
NUREG-1937 H-6 February 2011

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 
February 2011 H-7 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 
NUREG-1937 H-8 February 2011

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 
February 2011 H-9 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 
NUREG-1937 H-10 February 2011

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 
February 2011 H-11 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) 

February 2011 I-1 NUREG-1937 

Appendix I 

Carbon Dioxide Footprint Estimates for a 1000 MW(e) 

Light Water Reactor (LWR) 

The review team has estimated the carbon dioxide (CO2) footprint of various activities 

associated with nuclear power plants. These activities include building, operating, and 

decommissioning the plant. The estimates include direct emissions from the nuclear facility and 

indirect emissions from workforce transportation and the uranium fuel cycle. 

Construction equipment estimates listed in Table I-1 are based on hours of equipment use 

estimated for a single nuclear power plant at a site requiring a moderate amount of terrain 

modification. Equipment usage for a multiple unit facility would be larger, but it is likely that it 

would not be a factor of 2 larger. A reasonable set of emissions factors used to convert the 

hours of equipment use to CO2 emissions are based on carbon monoxide emissions 

(UniStar 2007) scaled to CO2 using a scaling factor of 165 tons of CO2 per ton of CO. This 

scaling factor is based on emissions factors in Table 3.3-1 of AP-42 (EPA 1995). Equipment 

emissions estimated for decommissioning are one half of those for construction. 

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. 

Workforce estimates are typical workforce numbers for new plant construction and operation 

based on estimates in various COL applications, and decommissioning workforce emissions 

estimates are based on decommissioning workforce estimates in NUREG-0586 S1, Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1 
Appendix I 

NUREG-1937 I-2 February 2011 

Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). A typical 

construction workforce averages about 2500 for a 7-year period with a peak work force of about 

4000. A typical operations workforce for the 40-year life of the plant is assumed to be about 

400, and the decommissioning workforce during a decontamination and dismantling period of 10 

years is assumed to be 200 to 400. In all cases, the daily commute is assumed to involve a 

100-mi round trip with 2 individuals per vehicle. Considering shifts, holidays, and 

vacations,1250 roundtrips per day are assumed each day of the year during construction; 200 

round trips per day are assumed each day during operations; and 150 round trips per day are 

assumed 250 days per year for the decontamination and dismantling portion of 

decommissioning. If the SAFSTOR decommissioning option is included in decommissioning, 20 

round trips each day of the year are assumed for the caretaker workforce. 

Table I-2 lists the review team’s estimates of the CO2 equivalent emissions associated with 

workforce transport. The table lists the assumptions used to estimate total miles traveled by 

each workforce and the factors used to convert total miles to metric tons CO2 equivalent. CO2

equivalent accounts for other greenhouse gases, such as methane and nitrous oxide, that are 

emitted by internal combustion engines. The workers are assumed to travel in gasoline powered 

passenger vehicles (cars, trucks, vans, and SUVs) that get an average of 19.7 mi per gallon of 

gas (FHWA 2006). Conversion from gallons of gasoline burned to CO2 equivalent is based on 

Environmental Protection Agency emissions factors (EPA 2007a; 2007b). 

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 

February 2011 I-3 NUREG-1937 

Published estimates of uranium fuel cycle CO2 emissions required to support a nuclear power 

plant range from about 1 percent to about 5 percent of the CO2 emissions from a comparably 

sized coal-fired plant (Sovacool 2008). A coal-fired power plant emits about 1 metric ton of CO2

for each megawatt hour generated (Miller and Van Atten 2004). Therefore, for consistency with 

Table S-3 of Title10 of the Code of Federal Regulations (CFR) Part 51.51, the review team 

estimated the uranium fuel cycle CO2 emissions as 0.05 metric tons of CO2 per MWh generated. 

Finally, the review team estimated the CO2 emissions directly related to plant operations from 

the typical usage of various diesel generators onsite using EPA emissions factors (EPA 1995). 

The review team assumed an average of 600 hrs of emergency diesel generator operation per 

year (total for 4 generators) and 200 hrs of station blackout diesel generator operation per year 

(total for 2 generators). 

Given the various sources of CO2 emissions discussed above, the review team estimates the 

total life CO2 footprint for a reference 1000 MW(e) nuclear power plant with an 80 percent 

capacity factor to be about 18 million metric tons. The components of the footprint are 

summarized in Table I-3. The uranium fuel cycle component of the footprint dominates all other 

components. It is directly related to power generated. As a result, it is reasonable to use 

reactor power to scale the footprint to larger reactors. 

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 1.7 × 107

Decommissioning Equipment 10 1.8 × 104

Decommissioning Workforce 10 1.7 × 104

SAFSTOR Workforce 40 1.3 × 104

TOTAL 1.8 × 107

In closing, the review team considers the footprint estimated in Table I-3 to be appropriately 

conservative. The CO2 emissions estimates for the dominant component (uranium fuel cycle) 

are based on 30 year old enrichment technology assuming that the energy required for 

enrichment is provided by coal-fired generation. Different assumptions related to the source of 

energy used for enrichment or the enrichment technology that would be just as reasonable 

could lead to a significantly reduced footprint. 
Appendix I 

NUREG-1937 I-4 February 2011 

Emissions estimates presented in the body of this EIS have been scaled to values that are 

appropriate for the proposed project. The uranium fuel cycle emissions have been scaled by 

reactor power using the scaling factor determined in Chapter 6 and by the number of reactors to 

be built. Plant operations emissions have been adjusted to represent the number of large CO2

emissions sources (diesel generators, boilers, etc.) associated with the project. The workforce 

emissions estimates have been scaled to account for differences in workforce numbers and 

commuting distance. Finally, equipment emissions estimates have been scaled by estimated 

equipment usage. As can be seen in Table I-3, only the scaling of the uranium fuel cycle 

emissions estimates makes a significant difference in the total carbon footprint of the project. 

I.1 References 

Federal Highway Administration (FHWA). 2006. Highway Statistics 2005 (Table VM-1). Office 

of Highway Policy Information. Washington, D.C. 

Miller, P. J., and C. Van Atten. 2004. North American Power Plant Air Emissions. Commission 

for Environmental Cooperation of North America, Montreal, Canada. 

Sovacool, B. K. 2008. “Valuing the greenhouse gas emissions from nuclear power: A critical 

survey. Energy Policy 36:2940-2953. Elsevier Ltd. 

UniStar Nuclear Energy, LLC (UniStar). 2007. Technical Report in Support of Application of 

UniStar Nuclear Operating Services, LLC for Certificate of Public Convenience and Necessity 

Before the Maryland Public Service Commission for Authorization to Construct Unit 3 at Calvert 

Cliffs Nuclear Power Plant and Associated Transmission Lines. Prepared for the Public Service 

Commission of Maryland, dated 6 November 2007. Accession No. ML090680065. 

U.S. Environmental Protection Agency (EPA). 1995. Compilation of Air Pollutant Emission 

Factors Volume 1: Stationary and Point and Area Sources. AP-42, 5th Edition. Office of Air and 

Radiation, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. 

U.S. Environmental Protection Agency (EPA). 2007a. Inventory of U. S. Greenhouse Gas 

Emissions and Sinks: 1990-2005 (Table 3-7). U.S. Environmental Protection Agency. 

Washington, D.C. 

U.S. Environmental Protection Agency (EPA). 2007b. “Conversion Factors to Energy Units 

(Heat Equivalents) Heat Contents and Carbon Content Coefficients of Various Fuel Types.”

Inventory of U. S. Greenhouse Gas Emissions and Sinks: Fast Facts 1990-2005. EPA-430-R07-002. U.S. Environmental Protection Agency. Washington, D.C. 
Appendix I 

February 2011 I-5 NUREG-1937 

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the Decommissioning of 

Nuclear Power Reactors. NUREG-0586 Supplement 1, Vols. 1 and 2, Washington, D.C. 

Appendix J 

U.S. Army Corps of Engineers Cumulative Effect 

Resource Analysis Table 

February 2011 J-1 NUREG-1937 

Appendix J 

Table J-1. U.S. Army Corps of Engineers (Corps) Cumulative Effect Resource Analysis Table 

Corps Resource/Issue 

Summary of Direct Impacts 

of the Proposed Action 

Included 

in 

Analysis Explanation of Impact 

Considered in South Texas 

Project (STP) EIS 

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 offsite transmission 

corridors 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 County in housing, schools and possibly emergency services. 

Section 7.4.1 
NUREG-1937 J-2 February 2011 

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) EIS 

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 would 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 would include 

delivery of large components by barge 

Yes Construction and maintenancedredging related impact. Section 7.4.1 

Marine Navigation Project would 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 FWS 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 
February 2011 J-3 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) EIS 

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 
NUREG-1937 J-4 February 2011 

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) EIS 

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 STPNOC has agreed to follow 

SHPO-approved procedures 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); the procedures include notification of the SHPO at the Texas Historic Commission 

Section 7.5 

Historical Resources No known resources 

anticipated to be impacted. 

Yes Section 7.5 
Appendix K 

U.S. Army Corps of Engineers 

Public Notice Comments 

February 2011 K-1 NUREG-1937 

Appendix K 

U.S. Army Corps of Engineers 

Public Notice Comments 

On March 25, 2010, the U.S. Army Corps of Engineers (Corps) published a public notice 

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

Section 10 of the Rivers and Harbors Appropriation Act of 1899. The purpose of the public 

notice was to solicit comments from the public on STP Nuclear Operating Company’s proposal 

to perform site preparation activities and construct supporting facilities at the South Texas 

Project Electric Generating Station site. Comments received on the public notice are listed in 

Table K-1. In addition, full copies of the comments (ML103130352) are provided in this 

appendix. 

Table K-1. Corps Public Notice Comments 

Source Date of Comment

Texas Commission on Environmental Quality 

(Charles Maguire) 

April 14, 2010 

U.S. Fish and Wildlife Service 

(Catherine Yeargan) 

April 26, 2010 

U.S. Environmental Protection Agency 

(Sharon Fancy Parrish) 

April 26, 2010 

Texas Parks and Wildlife 

(Rebecca Hensley) 

April 26, 2010 
Appendix K 

NUREG-1937 K-2 February 2011 
Appendix K 

February 2011 K-3 NUREG-1937 
Appendix K 

NUREG-1937 K-4 February 2011 
Appendix K 

February 2011 K-5 NUREG-1937 
Appendix K 

NUREG-1937 K-6 February 2011 
Appendix K 

February 2011 K-7 NUREG-1937 
Appendix K 

NUREG-1937 K-8 February 2011 

 
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 	



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--------------------

OFFICIAL BUSINESS
NUREG

-1937, Vol. 2

Final 

Environmental Impact Statement for Combined Licenses (COLs) for

South Texas Project Electric Generating Station Units 3 and 4