Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 33 

Regarding

Shearon Harris Nuclear 

Power Plant, Unit 1 

Final Report

Office of Nuclear Reactor Regulation

NUREG-1437 

Supplement 33

Generic Environmental

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 33 

Regarding

Shearon Harris Nuclear 

Power Plant, Unit 1 

Final Report 

Manuscript Completed: July 2008 

Date Published: August 2008

Office of Nuclear Reactor Regulation

NUREG-1437 

Supplement-33 

August 2008 iii NUREG-1437, Supplement 33 

ABSTRACT

The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of 

renewing nuclear power plant operating licenses (OLs) for a 20-year period in its Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 

Volumes 1 and 2, and codified the results in Part 51 of Title 10 of the Code of Federal 

Regulations (10 CFR Part 51). In the GEIS (and its Addendum 1), the NRC staff identifies 

92 environmental issues and reaches generic conclusions related to environmental impacts for 

69 of these issues that apply to all plants or to plants with specific design or site characteristics. 

Additional plant-specific review is required for the remaining 23 issues. These plant-specific 

reviews are to be included in a supplement to the GEIS. 

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

application submitted to the NRC by Carolina Power & Light Company, doing business as 

Progress Energy Carolinas, Inc. (CP&L), to renew the OL for Shearon Harris Nuclear Power 

Plant, Unit 1 (HNP) for an additional 20 years under 10 CFR Part 54. This SEIS includes the 

NRC staff’s analysis that considers and weighs the environmental impacts of the proposed 

action, the environmental impacts of alternatives to the proposed action, and mitigation 

measures available for reducing or avoiding adverse impacts. It also includes the NRC staff’s 

recommendation regarding the proposed action. 

Regarding the 69 issues for which the GEIS reached generic conclusions, the NRC staff has not 

identified any information that is both new and significant for any issue that applies to HNP. In 

addition, the NRC staff determined that information provided during the scoping process did not 

call into question the conclusions in the GEIS. Therefore, the NRC staff concludes that the 

impacts of renewing the HNP OL would not be greater than impacts identified for these issues in 

the GEIS. For each of these issues, the NRC staff’s conclusion in the GEIS is that the impact is 

of SMALL(a) significance (except for collective offsite radiological impacts from the fuel cycle and 

high-level waste and spent fuel, which were not assigned a single significance level). 

Regarding the remaining 23 issues, those that apply to HNP are addressed in this SEIS. For 

each applicable issue, the NRC staff concludes that the significance of the potential 

environmental impacts of renewal of the OL would be SMALL. The NRC staff determined that 

information provided during the scoping process did not identify any new issue with a significant 

environmental impact. 

 

(a) Environmental effects are not detectable or are so minor that they will neither destabilize nor 

noticeably alter any important attribute of the resource. 
Abstract

NUREG-1437, Supplement 33 iv August 2008 

The NRC staff’s recommendation is that the Commission determine that the adverse 

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

license renewal for energy-planning decision makers would be unreasonable. This 

recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental 

Report submitted by CP&L; (3) consultation with Federal, State, and local agencies; (4) the 

NRC staff’s own independent review; and (5) the NRC staff’s consideration of public comments 

received during the scoping process and on the draft SEIS. 

Paperwork Reduction Act Statement 

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

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved 

by the Office of Management and Budget, approval numbers 3150-0004; 3150-0155; 3150-

0014; 3150-0011; 3150-0021; 3150-0132; 3150-0151. 

Public Protection Notification 

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

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

currently valid OMB control number. 
August 2008 v NUREG-1437, Supplement 33 

Contents

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

Executive Summary ....................................................................................................................xiii 

Abbreviations/Acronyms .............................................................................................................xix 

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

1.1 Report Contents ......................................................................................................1-2 

1.2 Background ..............................................................................................................1-3

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

1.2.2 License Renewal Evaluation Process .........................................................1-4 

1.3 The Proposed Federal Action...................................................................................1-7 

1.4 The Purpose and Need for the Proposed Action......................................................1-8 

1.5 Compliance and Consultations.................................................................................1-8 

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

2.0 Description of Nuclear Power Plant and Site and Plant Interaction 

with the Environment..........................................................................................................2-1

2.1 Plant and Site Description and Proposed Plant Operation During 

the Renewal Term ...................................................................................................2-1 

2.1.1 External Appearance and Setting.................................................................2-1 

2.1.2 Reactor Systems .........................................................................................2-4 

2.1.3 Cooling and Auxiliary Water Systems .........................................................2-6 

2.1.4 Radioactive Waste Management Systems and Effluent 

Control Systems ..........................................................................................2-7 

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls ..............2-8 

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls .........2-9 

2.1.4.3 Solid Waste Processing ...............................................................2-10 

2.1.5 Nonradioactive Waste Systems..................................................................2-11 

2.1.5.1 Nonradioactive Waste Streams ....................................................2-11 

2.1.5.2 Pollution Prevention and Waste Minimization...............................2-13 

2.1.6 Plant Operation and Maintenance..............................................................2-13 

2.1.7 Power Transmission Lines .........................................................................2-14

2.2 Plant Interaction with the Environment...................................................................2-16 

2.2.1 Land Use .................................................................................................. 2-17 

2.2.2 Water Use...................................................................................................2-17 

2.2.2.1 Surface Water Use .......................................................................2-17 
NUREG-1437, Supplement 33 vi August 2008 

2.2.2.2 Groundwater Use..........................................................................2-18 

2.2.3 Water Quality..............................................................................................2-18 

2.2.3.1 Surface Water...............................................................................2-18 

2.2.3.2 Groundwater .................................................................................2-20 

2.2.4 Air Quality...................................................................................................2-22 

2.2.5 Aquatic Resources ....................................................................................2-24 

2.2.5.1 Water Body Characteristics ..........................................................2-25 

2.2.5.2 Threatened or Endangered Aquatic Species................................2-27 

2.2.6 Terrestrial Resources ................................................................................2-30 

2.2.6.1 Terrestrial Resources at the Shearon Harris Site .........................2-30 

2.2.6.2 Threatened and Endangered Terrestrial Species.........................2-33 

2.2.7 Radiological Conditions .............................................................................2-38 

2.2.8 Socioeconomic Factors .............................................................................2-39 

2.2.8.1 Housing.........................................................................................2-40 

2.2.8.2 Public Services ............................................................................ 2-41 

2.2.8.3 Offsite Land Use ..........................................................................2-43 

2.2.8.4 Visual Aesthetics and Noise .........................................................2-45 

2.2.8.5 Demography .................................................................................2-45 

2.2.8.6 Economy ......................................................................................2-48 

2.2.9 Historic and Archaeological Resources......................................................2-51 

2.2.9.1 Cultural Background .....................................................................2-51 

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

2.2.10 Related Federal Project Activities and Consultations.................................2-53 

2.2.10.1 Coastal Zone Management Act ....................................................2-54 

2.3 References ................................................................................................................2-54

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

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

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

4.1 Cooling System ........................................................................................................4-2 

4.2 Transmission Lines ................................................................................................4-12 

4.2.1 Electromagnetic Fields—Acute Effects ......................................................4-15 

4.2.2 Electromagnetic Fields—Chronic Effects ..................................................4-16 

4.3 Radiological Impacts of Normal Operations ..........................................................4-17 

4.4 Socioeconomic Impacts of Plant Operations During the License 

Renewal Term .......................................................................................................4-19 

4.4.1 Housing Impacts.........................................................................................4-21 

4.4.2 Public Services: Public Utility Impacts........................................................4-22 
 

August 2008 vii NUREG-1437, Supplement 33 

4.4.3 Offsite Land Use – License Renewal Period ..............................................4-23 

4.4.3.1 Population-Related Impacts..........................................................4-23 

4.4.3.2 Tax-Revenue-Related Impacts .....................................................4-24 

4.4.4 Public Services: Transportation Impacts During Operations ......................4-24 

4.4.5 Historic and Archaeological Resources......................................................4-25 

4.4.6 Environmental Justice ...............................................................................4-26 

4.4.6.1 Minority Population in 2000 ..........................................................4-27 

4.4.6.2 Low-Income Population in 2000 ...................................................4-28 

4.4.6.3 Analysis of Impacts ......................................................................4-31 

4.5 Groundwater Use and Quality ...............................................................................4-32 

4.6 Threatened or Endangered Species ......................................................................4-33 

4.6.1 Aquatic Species..........................................................................................4-34 

4.6.2 Terrestrial Species......................................................................................4-34 

4.7 Evaluation of New and Potentially Significant Information on 

Impacts of Operations During the Renewal Term ..................................................4-35 

4.8 Cumulative Impacts................................................................................................4-35 

4.8.1 Cumulative Impacts on Aquatic Resources................................................4-36 

4.8.2 Cumulative Impacts on Terrestrial Resources............................................4-38 

4.8.3 Cumulative Impacts on Groundwater Use and Quality...............................4-41 

4.8.4 Cumulative Impacts on Surface Water .......................................................4-41 

4.8.5 Cumulative Radiological Impacts ...............................................................4-42 

4.8.6 Cumulative Socioeconomic Impacts...........................................................4-43 

4.9 Summary of Impacts of Operations During the Renewal Term .............................4-44 

4.10 References.............................................................................................................4-44

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

5.1 Postulated Plant Accidents.......................................................................................5-1 

5.1.1 Design-Basis Accidents................................................................................5-2 

5.1.2 Severe Accidents..........................................................................................5-3 

5.2 Severe Accident Mitigation Alternatives ..................................................................5-4

5.2.1 Introduction...................................................................................................5-4 

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

5.2.3 Potential Plant Improvements.......................................................................5-7 

5.2.4 Evaluation of Risk Reduction and Costs of Improvements...........................5-8 

5.2.5 Cost-Benefit Comparison .............................................................................5-8 

5.2.6 Conclusions..................................................................................................5-9 

5.3 References.............................................................................................................5-10
NUREG-1437, Supplement 33 viii August 2008 

6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid 

Waste Management ..........................................................................................................6-1 

6.1 The Uranium Fuel Cycle...........................................................................................6-2 

6.2 References ..............................................................................................................6-9

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

7.1 Decommissioning.....................................................................................................7-2 

7.2 References...............................................................................................................7-4

8.0 Environmental Impacts of Alternatives to License Renewal .............................................8-1 

8.1 No-Action Alternative................................................................................................8-2 

8.2 Alternative Energy Sources......................................................................................8-7 

8.2.1 Supercritical Conventional Coal-Fired Generation .......................................8-9 

8.2.2 Coal-Fired Integrated Gasification Combined-Cycle (IGCC) Generation ...8-27 

8.2.3 Natural Gas-Fired Combined-Cycle Generation ........................................8-43 

8.2.4 New Nuclear Generation ...........................................................................8-54 

8.2.5 Utility-Sponsored Conservation ..................................................................8-63 

8.2.6 Purchased Electrical Power........................................................................8-69 

8.2.7 Other Alternatives.......................................................................................8-69 

8.2.7.1 Oil-Fired Generation .....................................................................8-69 

8.2.7.2 Wind Power ..................................................................................8-70 

8.2.7.3 Solar Power ..................................................................................8-70 

8.2.7.4 Hydropower ..................................................................................8-71 

8.2.7.5 Geothermal Energy.......................................................................8-71 

8.2.7.6 Wood Waste .................................................................................8-71 

8.2.7.7 Municipal Solid Waste ..................................................................8-72 

8.2.7.8 Other Biomass-Derived Fuels.......................................................8-73 

8.2.7.9 Fuel Cells......................................................................................8-73 

8.2.7.10 Delayed Retirement .....................................................................8-73 

8.2.8 Combination of Alternatives........................................................................8-74 

8.3 Summary of Alternatives Considered ....................................................................8-75 

8.4 References ............................................................................................................8-75

9.0 Summary and Conclusions ................................................................................................9-1

9.1 Environmental Impacts of the Proposed Action-License Renewal...........................9-4 

9.1.1 Unavoidable Adverse Impacts......................................................................9-5 

9.1.2 Irreversible or Irretrievable Resource Commitments ....................................9-5 

9.1.3 Short-Term Use Versus Long-Term Productivity..........................................9-6 
 

August 2008 ix NUREG-1437, Supplement 33 

9.2 Relative Significance of the Environmental Impacts of License 

Renewal and Alternatives.........................................................................................9-6 

9.3 NRC Staff Conclusions and Recommendations.......................................................9-9 

9.4 References ..............................................................................................................9-9

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

Appendix B Contributors to the Supplement....................................................................... B-1 

Appendix C Chronology of NRC Staff Environmental Review Correspondence 

Related to Carolina Power & Light Company Application for the License 

Renewal of Shearon Harris Nuclear Power Plant, Unit 1 ................................ C-1 

Appendix D Organizations Contacted................................................................................. D-1 

Appendix E Carolina Power & Light Company Compliance Status and Consultation 

Correspondence.............................................................................................. E-1 

Appendix F GEIS Environmental Issues Not Applicable to Shearon Harris 

Nuclear Power Plant, Unit 1 .............................................................................F-1 

Appendix G NRC Staff Evaluation of Severe Accident Mitigation Alternatives 

(SAMAs) for Shearon Harris Nuclear Power Plant, Unit 1...............................G-1 

Figures

Figure 2-1. Location of HNP and Surrounding Area within a 80-km (50-mi) Radius ...............2-2 

Figure 2-2. Location of HNP and Surrounding Area within a 10-km (6-mi) Radius .................2-3 

Figure 2-3. HNP Site and Harris Reservoir...............................................................................2-4 

Figure 2-4. Harris Nuclear Power Plant Powerblock Area........................................................2-5 

Figure 2-5. Map of Transmission Lines within 80-km (50-mi) Radius of HNP ........................2-15 

Figure 4-1. Minority Block Groups in 2000 within an 80-km (50-mi) Radius of HNP ..............4-29 

Figure 4-2. Low-Income Block Groups within an 80-km (50-mi) Radius of HNP ...................4-30 

Tables

Table 2-1. HNP Wastewater Discharge Outfalls ...................................................................2-19 

Table 2-2. Storm Water Discharge Outfalls...........................................................................2-20 
NUREG-1437, Supplement 33 x August 2008 

Table 2-3. HNP Permitted Underground Storage Tanks .......................................................2-22 

Table 2-4. Federally and State-Listed Aquatic Species Potentially Occurring in 

Wake or Chatham Counties or in Counties Crossed by Associated 

Transmission Line ROWs.....................................................................................2-28 

Table 2-5. Federally and State-Listed Terrestrial Species Potentially Occurring in 

Wake or Chatham Counties or in Counties Crossed by Associated 

Transmission Line ROWs.....................................................................................2-35 

Table 2-6. HNP Permanent Employee Residence by County in 2006 ..................................2-40 

Table 2-7. Housing in Wake and Lee Counties, North Carolina, in 2000 ..............................2-41 

Table 2-8. Average Annual Daily Traffic (AADT) Counts in the Vicinity of HNP in 2003.......2-43 

Table 2-9. Population and Percent Growth in Wake and Lee Counties, North Carolina, 

from 1970 to 2000 and Projected for 2010 to 2050..............................................2-46 

Table 2-10. Demographic Profile of the Population in the HNP Region of Influence ..............2-47 

Table 2-11. Major Employers in Wake County in 2005 ...........................................................2-49 

Table 2-12. Income Information for the HNP Region of Influence...........................................2-50 

Table 2-13. Wake County Tax Revenues, CP&L Property Tax, and NCEMPA Property 

Tax as a Percentage of Tax Revenues, 2001 to 2005 .........................................2-51 

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

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

Table 4-1. Category 1 Issues Applicable to the Operation of the HNP Cooling 

System During the Renewal Term ........................................................................4-2 

Table 4-2. Category 1 Issues Applicable to the Shearon Harris Nuclear Power Plant 

Transmission Lines During the Renewal Term ...................................................4-12 

Table 4-3. Category 2 and Uncategorized Issues Applicable to the Shearon Harris 

Nuclear Power Plant Transmission Lines During the Renewal Term...................4-15 

Table 4-4. Category 1 Issues Applicable to Radiological Impacts of Normal 

Operations During the Renewal Term .................................................................4-18 

Table 4-5. Category 1 Issues Applicable to Socioeconomics During the 

Renewal Term......................................................................................................4-19 

Table 4-6. Category 2 Issues Applicable to Socioeconomics and Environmental 

Justice During the Renewal Term .......................................................................4-21 

Table 4-7. Category 2 Issue Applicable to Threatened or Endangered Species 

During the Renewal Term ...................................................................................4-33 

Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste 

Management During the Renewal Term ...............................................................6-2 

Table 7-1. Category 1 Issues Applicable to the Decommissioning of HNP Following the 

Renewal Term........................................................................................................7-2 

Table 8-1. Summary of Environmental Impacts of the No-Action Alternative..........................8-6 
 

August 2008 xi NUREG-1437, Supplement 33 

Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation at HNP Site 

and an Alternate Site Using Closed-Cycle Cooling ..............................................8-13 

Table 8-3. Summary of Environmental Impacts of IGCC Coal-Fired Generation at 

HNP Site and an Alternate Site Using Closed-Cycle Cooling ..............................8-30 

Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at 

HNP Site and an Alternate Site Using Closed-Cycle Cooling ..............................8-45 

Table 8-5. Summary of Environmental Impacts of New Nuclear Power Generation at 

the HNP Site and an Alternate Site Using Closed-Cycle Cooling ........................8-56 

Table 8-6. Summary of Environmental Impacts of a Conservation Alternative .....................8-65 

Table 9-1. Summary of Environmental Significance of License Renewal, the 

No-Action Alternative, and Other Alternatives........................................................9-7 

Table A-1. Individuals Providing Comments During Scoping Comment Period ..................... A-3 

Table A-2. Comments Received on the Draft SEIS .............................................................. A-39 

Table E-1. Consultation Correspondence .............................................................................. E-1 

Table E-2. Federal, State, Local, and Regional Licenses, Permits, and Other 

Approvals for the Shearon Harris Nuclear Power Plant (HNP) ............................. E-3 

Table F-1. GEIS Environmental Issues Not Applicable to Shearon Harris Nuclear

Power Plant, Unit 1.................................................................................................F-1 

Table G-1. HNP Core Damage Frequency .............................................................................G-3 

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

Table G-3. HNP PSA Historical Summary ..............................................................................G-5 

Table G-4. Fire Areas and their Contribution to Fire CDF.......................................................G-9 

Table G-5. SAMA Cost/Benefit Screening Analysis for HNP ................................................G-20 

August 2008 xiii NUREG-1437, Supplement 33 

EXECUTIVE SUMMARY 

By letter dated November 14, 2006, Carolina Power and Light Company, doing business as 

Progress Energy Carolinas, Inc., (CP&L) submitted an application to the U.S. Nuclear 

Regulatory Commission (NRC) to renew the operating license (OL) for the Shearon Harris 

Nuclear Power Plant, Unit 1 (HNP) for an additional 20-year period. If the OL is renewed, State 

regulatory agencies and CP&L will ultimately decide whether the plant will continue to operate 

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

the purview of the owners. If the OL is not renewed, then the plant must be shut down on or 

before the expiration date of the current OL, which is October 24, 2026. 

The NRC has implemented Section 102 of the National Environmental Policy Act (NEPA), 

Title 42, Section 4321, of the United States Code (42 USC 4321) in Part 51 of Title 10 of the 

Code of Federal Regulations (10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission 

requires preparation of an Environmental Impact Statement (EIS) or a supplement to an EIS for 

renewal of a reactor OL. In addition, 10 CFR 51.95(c) states that the EIS prepared at the OL 

renewal stage will be a supplement to the Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2.(a)

Upon acceptance of the CP&L application, the NRC began the environmental review process 

described in 10 CFR Part 51 by publishing a Notice of Intent to prepare an EIS and conduct 

scoping. The NRC staff held public scoping meetings on April 18, 2007, in Apex, North 

Carolina, and conducted a site audit at HNP in June 2007. In the preparation of this 

supplemental environmental impact statement (SEIS) for HNP, the NRC staff reviewed the 

CP&L Environmental Report (ER) and compared it to the GEIS, consulted with other agencies, 

conducted an independent review of the issues following the guidance set forth in NUREG1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear Power 

Plants, Supplement 1: Operating License Renewal, and considered the public comments 

received during the scoping process. The public comments received during the scoping 

process are provided in Appendix A, Part 1, of this SEIS. 

The NRC staff held two public meetings in Apex, North Carolina, in January 2008, to describe 

the results of the NRC environmental review, to answer questions, and to provide members of 

the public with information to assist them in formulating comments on this SEIS. When the 

comment period ended, the NRC staff considered and addressed all of the comments received.

These comments are addressed in Appendix A, Part 2, of this final SEIS. 

 

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Executive Summary 

NUREG-1437, Supplement 33 xiv August 2008 

This SEIS includes the NRC staff’s analysis that considers and weighs the environmental 

effects of the proposed action, the environmental impacts of alternatives to the proposed action, 

and mitigation measures for reducing or avoiding adverse effects. It also includes the NRC 

staff’s recommendation regarding the proposed action. 

The Commission has adopted the following statement of purpose and need for license renewal 

from the GEIS: 

The purpose and need for the proposed action (renewal of an operating license) 

is to provide an option that allows for power generation capability beyond the 

term of a current nuclear power plant operating license to meet future system 

generating needs, as such needs may be determined by State, utility, and, where 

authorized, Federal (other than NRC) decision makers. 

The evaluation criterion for the NRC staff’s environmental review, as defined in 10 CFR 

51.95(c)(4) and the GEIS, is to determine 

... whether or not the adverse environmental impacts of license renewal are so 

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

makers would be unreasonable. 

Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 

there are factors, in addition to license renewal, that will ultimately determine whether an 

existing nuclear power plant continues to operate beyond the period of the current OL. 

NRC regulations (10 CFR 51.95[c][2]) contain the following statement regarding the content of 

SEISs prepared at the license renewal stage: 

The supplemental environmental impact statement for license renewal is not 

required to include discussion of need for power or the economic costs and 

economic benefits of the proposed action or of alternatives to the proposed 

action except insofar as such benefits and costs are either essential for a 

determination regarding the inclusion of an alternative in the range of alternatives 

considered or relevant to mitigation. In addition, the supplemental environmental 

impact statement prepared at the license renewal stage need not discuss other 

issues not related to the environmental effects of the proposed action and the 

alternatives, or any aspect of the storage of spent fuel for the facility within the 

scope of the generic determination in § 51.23(a) [“Temporary storage of spent 

fuel after cessation of reactor operation–generic determination of no significant 

environmental impact”] and in accordance with § 51.23(b). 

The GEIS contains the results of a systematic evaluation of the consequences of renewing an OL 

and operating a nuclear power plant for an additional 20 years. It evaluates 92 environmental 

issues using the NRC’s three-level standard of significance—SMALL, MODERATE, or LARGE—
Executive Summary 

August 2008 xv NUREG-1437, Supplement 33 

developed using the Council on Environmental Quality guidelines. The following definitions of the 

three significance levels are set forth in footnotes to Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B: 

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. 

For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS reached the following 

conclusions: 

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

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

specified plant or site characteristics. 

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

impacts (except for collective offsite radiological impacts from the fuel cycle and from highlevel waste and spent fuel disposal). 

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

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

to be sufficiently beneficial to warrant implementation. 

These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 

significant information, the NRC staff relied on conclusions in the GEIS for issues designated as 

Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. 

Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 

issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 

environmental justice and chronic effects of electromagnetic fields, were not categorized. 

Environmental justice was not evaluated on a generic basis and must be addressed in a plantspecific supplement to the GEIS. Information on the chronic effects of electromagnetic fields 

was not conclusive at the time the GEIS was prepared. 

This SEIS documents the NRC staff’s consideration of all 92 environmental issues identified in 

the GEIS. The NRC staff considered the environmental impacts associated with alternatives to 

license renewal and compared the environmental impacts of license renewal and the 

alternatives. The alternatives to license renewal that were considered include the no-action 

alternative (not renewing the OL for HNP), conservation alternative, and alternative methods of 
Executive Summary 

NUREG-1437, Supplement 33 xvi August 2008 

power generation. Based on projections made by the U.S. Department of Energy’s Energy 

Information Administration (DOE/EIA), gas- and coal-fired generation appear to be the most 

likely power-generation alternatives if the power from HNP is replaced. These alternatives are 

evaluated assuming that the replacement power generation plant is located at either the HNP 

site or some other unspecified alternate location. 

The NRC staff has an established process for identifying and evaluating the significance of any 

new information on the environmental impacts of license renewal. No information has been 

identified as being new and significant related to Category 1 issues that would call into question 

the conclusions in the GEIS. Similarly, no new environmental issues applicable to HNP were 

identified by the NRC staff through its review process or the public scoping process. Therefore, 

the NRC staff relies upon the conclusions of the GEIS for all Category 1 issues that are 

applicable to HNP.

CP&L’s ER presents an analysis of the Category 2 issues that are applicable to HNP, plus 

environmental justice. The NRC staff has reviewed the CP&L analysis for each issue and has 

conducted an independent review of each issue plus environmental justice. Nine Category 2 

issues are not applicable because they are related to plant design features or site 

characteristics not found at HNP. Three Category 2 issues are not discussed in this SEIS 

because they are specifically related to refurbishment. CP&L has stated that its evaluation of 

structures and components, as required by 10 CFR 54.21, did not identify any major plant 

refurbishment activities or modifications as necessary to support the continued operation of 

HNP, for the license renewal period. In addition, any replacement of components or additional 

inspection activities are within the bounds of normal plant component replacement and, 

therefore, are not expected to affect the environment outside of the bounds of the plant 

operations evaluated in the Final Environmental Statement Related to Operation of Shearon 

Harris Nuclear Power Plant (NRC 1983). 

Eight Category 2 issues related to operational impacts and postulated accidents during the 

renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are 

discussed in detail in this SEIS. Five of the Category 2 issues and environmental justice apply 

to both refurbishment and to operation during the renewal term and are only discussed in this 

SEIS in relation to operation during the renewal term. For all eight Category 2 issues and 

environmental justice, the NRC staff concludes that the potential environmental effects are of 

SMALL significance in the context of the standards set forth in the GEIS. In addition, the NRC 

staff determined that appropriate Federal health agencies have not reached a consensus on the 

existence of chronic adverse effects from electromagnetic fields. Therefore, no further 

evaluation of this issue is required. For severe accident mitigation alternatives (SAMAs), the 

NRC staff concludes that a reasonable, comprehensive effort was made to identify and evaluate 

SAMAs. Based on its review of the SAMAs for HNP, and the plant improvements already 

made, the NRC staff concludes that several candidate SAMAs are potentially cost-beneficial. 

However, none of these SAMAs relate to adequately managing the effects of aging during the 
Executive Summary 

August 2008 xvii NUREG-1437, Supplement 33 

period of extended operation. Therefore, they need not be implemented as part of license 

renewal pursuant to 10 CFR Part 54. 

Mitigation measures were considered for each Category 2 issue. For most issues, current 

measures to mitigate the environmental impacts of plant operation were found to be adequate. 

Cumulative impacts of past, present, and reasonably foreseeable future actions were 

considered, regardless of what agency (Federal or non-Federal) or person undertakes such 

other actions. For purposes of this analysis, where the HNP license renewal impacts are 

deemed to be SMALL, the NRC staff concluded that these impacts would not result in significant 

cumulative impacts on potentially affected resources. 

If the HNP OL is not renewed and the plant ceases operation on or before the expiration of its 

current OL, then the adverse impacts of likely power generating alternatives would not 

necessarily be smaller than those associated with continued operation of HNP. The impacts 

may be greater in some areas, depending on the alternatives selected. 

The recommendation of the NRC staff is that the Commission determine that the adverse 

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

license renewal for energy planning decision makers would be unreasonable. This 

recommendation is based on (1) the analysis and findings in the GEIS; (2) the ER submitted by 

CP&L; (3) consultation with other Federal, State, and local agencies; (4) the NRC staff’s own 

independent review; and (5) the NRC staff’s consideration of public comments received during 

the scoping process and on the draft SEIS. 

August 2008 xix NUREG-1437, Supplement 33 

ABBREVIATIONS/ACRONYMS 

° degree 

AADT average annual daily traffic 

ac acre(s) 

AEO Annual Energy Outlook 

ALARA as low as reasonably achievable 

AQCR Air Quality Control Region 

AEC Atomic Energy Commission 

BTU British thermal unit(s) 

C Celsius 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

cfs cubic feet per second 

Ci curie(s) 

cm centimeter 

CO carbon monoxide 

COL Combined License 

CP&L Carolina Power and Light Company, doing business as Progress Energy 

Carolinas, Inc. 

CTMU cooling tower make-up (water) 

CVCS Chemical and Volume Control System 

CWA Clean Water Act 

DAW dry active waste 

DOC U.S. Department of Commerce 

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation 

EIA Energy Information Administration 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

EPCRA Emergency Planning and Community Right-to-Know Act 

ER environmental report 

ESA Endangered Species Act 

ESP early site permit 
NUREG-1437, Supplement 33 xx August 2008 

F Fahrenheit 

FES Final Environmental Statement 

FR Federal Register 

ft foot (feet) 

ft3 cubic foot (feet) 

ft/s feet (feet) per second 

FWS U.S. Fish and Wildlife Service 

gal gallon(s) 

GEIS generic environmental impact statement 

gpm gallons per minute 

GWh gigawatt-hour(s) 

GWPS Gaseous Waste Processing System 

ha hectare(s) 

HEEC Harris Energy and Environmental Center 

HLW high-level waste 

HNP Shearon Harris Nuclear Power Plant, Unit 1 

in. inch(es) 

IGCC integrated gasification combined-cycle 

ISFSI Independent Spent Fuel Storage Installation 

IVM Integrated Vegetation Management 

J joule 

km kilometer(s) 

kV kilovolt 

kWh kilowatt-hour 

L liter 

LAER Lowest achievable emissions rate 

lb pound(s) 

LQG large-quantity generator 

LLMW low-level mixed waste 

LWPS Liquid Waste Processing System 

m meter(s) 
August 2008 xxi NUREG-1437, Supplement 33 

m3 cubic meter(s) 

MBq megabecquerel 

MGD million gallons per day 

mGy milligray 

mi mile(s) 

min minute(s) 

MPa megapascal 

mrad millirad 

mrem millirem 

mSv milliSievert 

MT metric ton(s) 

MTHM metric ton of heavy metal 

MWe megawatts-electric 

MWh megawatt hour 

MWt megawatts-thermal 

NAAQS National Ambient Air Quality Standards 

NAS National Academy of Sciences 

NCDENR North Carolina Department of Environmental and Natural Resources 

NCEMPA North Carolina Eastern Municipal Power Agency 

NCNHP North Carolina Natural Heritage Program 

NCOSA North Carolina Office of State Archaeology 

NCWRC North Carolina Wildlife Resources Commission 

NEPA National Environmental Policy Act of 1969 

NESC National Electrical Safety Code 

NHPA National Historic Preservation Act of 1966 

NIEHS National Institute of Environmental Health Sciences 

NOx nitrogen oxides 

NOAA National Oceanic and Atmospheric Administration 

NOV Notice of Violation 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

ODCM Offsite Dose Calculation Manual

OL operating license 

PCB polychlorinated biphenyls 

pCi picocurie(s) 
NUREG-1437, Supplement 33 xxii August 2008 

PDR Public Document Room 

PM10 particulate matter with an aerodynamic diameter less than or equal to 10 microns 

POVR power operated relief valve 

ppm parts per million 

psig pounds per square inch gage 

radwaste radioactive waste 

RCS Reactor Coolant System 

rem roentgen equivalent man 

RCRA Resource Conservation and Recovery Act 

REMP Radiological Environmental Monitoring Program 

ROI region of influence 

ROW right-of-way 

RWST Refueling Water Storage Tank 

SAMA severe accident mitigation alternative 

SCR selective catalytic reduction 

SEIS supplemental environmental impact statement 

SHPO State Historic Preservation Office 

SNHA significant natural heritage areas 

SOx sulfur oxides 

Sv Sievert 

SWPS Solid Waste Processing System 

USC United States Code 

USCB U.S. Census Bureau 

USGS U.S. Geological Survey 

UST underground storage tank 

WPB Waste Processing Building 

WWTP Wastewater Treatment Plant 
August 2008 1-1 NUREG-1437, Supplement 33 

1.0 INTRODUCTION 

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

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

National Environmental Policy Act of 1969 (NEPA), renewal of a nuclear power plant operating 

license (OL) requires the preparation of an environmental impact statement (EIS). In preparing 

the EIS, the NRC staff is required first to issue the statement in draft form for public comment 

and then issue a final statement after considering public comments on the draft. To support the 

preparation of the EIS, the NRC staff has prepared a Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 

1999).(1) The GEIS is intended to (1) provide an understanding of the types and severity of 

environmental impacts that may occur as a result of license renewal of nuclear power plants 

under 10 CFR Part 54, (2) identify and assess the impacts that are expected to be generic to 

license renewal, and (3) support 10 CFR Part 51 to define the number and scope of issues that 

need to be addressed by the applicants in plant-by-plant license renewal proceedings. Use of 

the GEIS guides the preparation of complete plant-specific information related to the OL 

renewal process. 

Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc. (CP&L) 

operates the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) in Wake County, North Carolina 

under OL NPF-63, which was issued by the NRC. This OL will expire on October 24, 2026. On 

November 14, 2006, CP&L submitted an application to the NRC to renew the HNP OL for an 

additional 20 years under 10 CFR Part 54. CP&L is a licensee for the purposes of its current 

OL and an applicant for the renewal of the OL. Pursuant to 10 CFR 54.23 and 51.53(c), CP&L 

submitted an Environmental Report (ER) (Progress Energy 2006b), in which CP&L analyzed the 

environmental impacts associated with the proposed license renewal action, considered 

alternatives to the proposed action, and evaluated mitigation measures for reducing adverse 

environmental effects. 

This report is the plant-specific supplement to the GEIS (the supplemental EIS [SEIS]) for the 

CP&L license renewal application. This SEIS is a supplement to the GEIS because it relies, in 

part, on the findings of the GEIS. The NRC staff will also prepare a separate safety evaluation 

report in accordance with 10 CFR Part 54. 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Introduction 

NUREG-1437, Supplement 33 1-2 August 2008 

1.1 Report Contents

The following sections of this introduction (1) describe the background for the preparation of this 

SEIS, including the development of the GEIS and the process used by the NRC staff to assess 

the environmental impacts associated with plant operations during license renewal; (2) describe 

the proposed Federal action to renew the HNP OL; (3) discuss the purpose and need for the 

proposed action; and (4) present the status of CP&L’s compliance with environmental quality 

standards and requirements that have been imposed by Federal, State, regional, and local 

agencies that are responsible for environmental protection. 

The ensuing chapters of this SEIS closely parallel the contents and organization of the GEIS. 

Chapter 2 describes the site, power plant, and interactions of the plant with the environment. 

Chapters 3 and 4, respectively, discuss the potential environmental impacts of plant 

refurbishment and plant operation during the renewal term. Chapter 5 contains an evaluation of 

potential environmental impacts of plant accidents and includes consideration of severe 

accident mitigation alternatives. Chapter 6 discusses the uranium fuel cycle and solid waste 

management. Chapter 7 discusses decommissioning, and Chapter 8 discusses alternatives to 

license renewal. Finally, Chapter 9 summarizes the findings of the preceding chapters and 

draws conclusions about the adverse impacts that cannot be avoided, the relationship between 

short-term uses of man’s environment and the maintenance and enhancement of long-term 

productivity, and the irreversible or irretrievable commitment of resources. Chapter 9 also 

presents the NRC staff’s recommendation with respect to the proposed license renewal action. 

Additional information is included in appendixes. Appendix A contains public comments related 

to the environmental review for license renewal and NRC staff responses to those comments. 

Appendixes B through G, respectively, list the following: 

• The preparers of the supplement, 

• The chronology of NRC staff’s environmental review correspondence related to this 

SEIS,

• The organizations contacted during the development of this SEIS, 

• CP&L’s compliance status in Table E-1 (this appendix also contains copies of 

consultation correspondence prepared and sent during the evaluation process), 

• GEIS environmental issues that are not applicable to HNP, and 

• Severe accident mitigation alternatives (SAMAs). 
Introduction 

August 2008 1-3 NUREG-1437, Supplement 33 

1.2 Background

Use of the GEIS, which examines the possible environmental impacts that could occur as a 

result of renewing individual nuclear power plant OLs under 10 CFR Part 54, and the 

established license renewal evaluation process support the thorough evaluation of the impacts 

of renewal of OLs. 

1.2.1 Generic Environmental Impact Statement 

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

license renewal term to improve the efficiency of the license renewal process by documenting 

the assessment results and codifying the results in the Commission’s regulations. This 

assessment is provided in the GEIS, which serves as the principal reference for all nuclear 

power plant license renewal EISs. 

The GEIS documents the results of the systematic approach that was taken to evaluate the 

environmental consequences of renewing the licenses of individual nuclear power plants and 

operating them for an additional 20 years. For each potential environmental issue, the GEIS 

(1) describes the activity that affects the environment, (2) identifies the population or resource 

that is affected, (3) assesses the nature and magnitude of the impact on the affected population 

or resource, (4) characterizes the significance of the effect for both beneficial and adverse 

effects, (5) determines whether the results of the analysis apply to all plants, and (6) considers 

whether additional mitigation measures would be warranted for impacts that would have the 

same significance level for all plants. 

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

Environmental Quality (CEQ) terminology for “significantly” (40 CFR 1508.27, which requires 

consideration of both “context” and “intensity”). Using the CEQ terminology, the NRC 

established three significance levels—SMALL, MODERATE, or LARGE. The definitions of the 

three significance levels are set forth in the footnotes to Table B-1 of 10 CFR Part 51, 

Subpart A, Appendix B, as follows: 

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. 

The GEIS assigns a significance level to each environmental issue, assuming that ongoing 

mitigation measures would continue. 
Introduction 

NUREG-1437, Supplement 33 1-4 August 2008 

The GEIS includes a determination of whether the analysis of the environmental issue could be 

applied to all plants and whether additional mitigation measures would be warranted. Issues 

are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 

issues are those that meet all of the following criteria: 

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

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

or other specified plant or site characteristics. 

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

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

high-level waste and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required in this SEIS unless new and significant information is identified. 

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

therefore, additional plant-specific review for these issues is required. 

In the GEIS, the NRC staff assessed 92 environmental issues and determined that 69 qualified 

as Category 1 issues, 21 qualified as Category 2 issues, and 2 issues were not categorized. 

The two uncategorized issues are environmental justice and chronic effects of electromagnetic 

fields. Environmental justice was not evaluated on a generic basis in the GEIS and must be 

addressed in the SEIS. Information on the chronic effects of electromagnetic fields was not 

conclusive at the time the GEIS was prepared. 

Of the 92 issues, 11 are related only to refurbishment, 6 are related only to decommissioning, 

67 apply only to operation during the renewal term, and 8 apply to both refurbishment and 

operation during the renewal term. A summary of the findings for all 92 issues in the GEIS is 

codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. 

1.2.2 License Renewal Evaluation Process 

An applicant seeking to renew its OL is required to submit an ER as part of its application. The 

license renewal evaluation process involves careful review of the applicant’s ER and assurance 

that all new and potentially significant information not already addressed in or available during 

the GEIS evaluation is identified, reviewed, and assessed to verify the environmental impacts of 

the proposed license renewal. 
Introduction 

August 2008 1-5 NUREG-1437, Supplement 33 

In accordance with 10 CFR 51.53(c)(2) and (3), the ER submitted by the applicant must 

• Provide an analysis of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B, in accordance with 10 CFR 51.53(c)(3)(ii), and 

• Discuss actions to mitigate any adverse impacts associated with the proposed action 

and environmental impacts of alternatives to the proposed action. 

In accordance with 10 CFR 51.53(c)(2), the ER does not need to 

• Consider the economic benefits and costs of the proposed action and alternatives to the 

proposed action except insofar as such benefits and costs are either (1) essential for 

making a determination regarding the inclusion of an alternative in the range of 

alternatives considered, or (2) relevant to mitigation. 

• Consider the need for power and other issues not related to the environmental effects of 

the proposed action and the alternatives. 

• Discuss any aspect of the storage of spent fuel within the scope of the generic 

determination in 10 CFR 51.23(a) in accordance with 10 CFR 51.23(b). 

• Contain an analysis of any Category 1 issue unless there is significant new information 

on a specific issue—this is pursuant to 10 CFR 51.23(c)(3)(iii) and (iv). 

New and significant information is (1) information that identifies a significant environmental issue 

not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or 

(2) information that was not considered in the analyses summarized in the GEIS and that leads 

to an impact finding that is different from the finding presented in the GEIS and codified in 

10 CFR Part 51. 

In preparing to submit its application to renew the HNP OL, CP&L developed a process to 

ensure that information not addressed in or available during the GEIS evaluation regarding the 

environmental impacts of license renewal for HNP would be properly reviewed before submitting 

the ER, and to ensure that such new and potentially significant information related to renewal of 

the license would be identified, reviewed, and assessed during the period of NRC review. 

CP&L reviewed the Category 1 issues that appear in Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B, to verify that the conclusions of the GEIS remained valid with respect to HNP. This 

review was performed by personnel from CP&L and its support organizations involved in the 

preparation of a license renewal ER. 

The NRC staff also has a process for identifying new and significant information. That process 

is described in detail in Standard Review Plans for Environmental Reviews for Nuclear Power 

Plants, Supplement 1: Operating License Renewal NUREG-1555, Supplement 1 (NRC 2000).
Introduction 

NUREG-1437, Supplement 33 1-6 August 2008 

The search for new information includes (1) review of an applicant’s ER and the process for 

discovering and evaluating the significance of new information, (2) review of public comments, 

(3) review of environmental quality standards and regulations, (4) coordination with Federal, 

State, and local environmental protection and resource agencies, and (5) review of the technical 

literature. New information discovered by the NRC staff is evaluated for significance using the 

criteria set forth in the GEIS. For Category 1 issues where new and significant information is 

identified, reconsideration of the conclusions for those issues is limited in scope to the 

assessment of the relevant new and significant information; the scope of the assessment does 

not include other facets of the issue that are not affected by the new information. 

Chapters 3 through 7 discuss the environmental issues considered in the GEIS that are 

applicable to HNP. At the beginning of the discussion of each set of issues, a table identifies 

the issues to be addressed and lists the sections in the GEIS where the issue is discussed. 

Category 1 and Category 2 issues are listed in separate tables. For Category 1 issues for which 

there is no new and significant information, the table is followed by a set of short paragraphs 

that state the GEIS conclusion codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, 

followed by the NRC staff’s analysis and conclusion. For Category 2 issues, in addition to the 

list of GEIS sections where the issue is discussed, the tables list the subparagraph of 10 CFR 

51.53(c)(3)(ii) that describes the analysis required and the SEIS sections where the analysis is 

presented. The SEIS sections that discuss the Category 2 issues are presented immediately 

following the table. 

The NRC prepares an independent analysis of the environmental impacts of license renewal 

and compares these impacts with the environmental impacts of alternatives. The evaluation of 

the CP&L license renewal application began with publication of a Notice of Acceptance for 

docketing in the Federal Register (FR; 72 FR 1562 [NRC 2007a]) on January 12, 2007. The 

NRC staff published a Notice of opportunity for Hearing and Intent to prepare an EIS and 

conduct scoping in the Federal Register (72 FR 13139 [NRC 2007b]) on March 20, 2007. Two 

public scoping meetings were held on April 18, 2007, in Apex, North Carolina. Comments 

received during the scoping period were summarized in the Environmental Scoping Summary 

Report Associated with the Staff's Review of the Shearon Harris Nuclear Power Plant License 

Renewal Application (NRC 2007c). Comments that are applicable to this environmental review 

are presented in Appendix A. 

The NRC staff used the review guidance contained in NUREG-1555, Supplement 1 (NRC 

2000). The NRC staff and contractors retained to assist the staff visited the HNP site on June 5 

and 6, 2007, to gather information and to become familiar with the site and its environs. The 

NRC staff also reviewed the comments received during scoping and consulted with Federal, 

State, regional, and local agencies. A list of the organizations consulted is provided in 

Appendix D. Other documents related to HNP were reviewed and are referenced in this SEIS. 

This SEIS presents the NRC staff’s analysis that considers and weighs the environmental 

effects of the proposed renewal of the OL for HNP, the environmental impacts of alternatives to 
Introduction 

August 2008 1-7 NUREG-1437, Supplement 33 

license renewal, and mitigation measures available for reducing or avoiding adverse 

environmental effects. Chapter 9, “Summary and Conclusions,” provides the NRC staff’s 

recommendation to the Commission on whether or not the adverse environmental impacts of 

license renewal are so great that preserving the option of license renewal for energy-planning 

decision makers would be unreasonable. 

On December 19, 2007, the NRC published the Notice of Availability of the draft SEIS in 72 FR 

71973 (NRC 2007d). A 75-day comment period began on the date of publication of the U.S. 

Environmental Protection Agency Notice of Availability (72 FR 72707) of the draft SEIS to allow 

members of the public to comment on the results of the NRC staff's review. In January 2008, 

during this comment period, two public meetings were held in Apex, North Carolina. During 

these meetings, the NRC staff described the preliminary results of the NRC environmental 

review and answered questions to provide members of the public with information to assist them 

in formulating their comments. The comment period for the Shearon Harris draft SEIS ended on 

March 5, 2008. Comments made during the 75-day comment period, including those made at 

the two public meetings, are presented in Part 2 of Appendix A. The NRC responses to those 

comments are also provided. 

This SEIS presents the staff's analysis that considers and weighs the environmental effects of 

the proposed renewal of the OL for HNP, the environmental impacts of alternatives to license 

renewal, and mitigation measures available for avoiding adverse environmental effects. 

Chapter 9 provides the NRC staff's recommendation to the Commission on whether or not the 

adverse environmental impacts of license renewal are so great that preserving the option of 

license renewal for energy-planning decision makers would be unreasonable. 

1.3 The Proposed Federal Action

The proposed Federal action is renewal of the OL for HNP. HNP is located in the southwest 

corner of Wake County, North Carolina, on the northwest shore of the 1680 ha (4150-ac) Harris 

Reservoir, approximately 25.8 km (16 mi) northeast of the city of Raleigh, North Carolina. HNP 

is a single-unit plant with a pressurized light-water reactor designed and manufactured by 

Westinghouse Electric Company, with a rated power level of 2900 megawatts thermal (MWt) 

and a gross power output of 955 megawatts electric (MWe). Plant cooling is provided by a 

closed-cycle system with a cooling tower-based heat dissipation system. The current OL for 

HNP expires on October 24, 2026. By letter dated November 14, 2006, CP&L submitted an 

application to the NRC to renew this OL for an additional 20 years of operation (Progress 

Energy 2006a). 
Introduction 

NUREG-1437, Supplement 33 1-8 August 2008 

1.4 The Purpose and Need for the Proposed Action

Although a licensee must have a renewed license to operate a reactor beyond the term of the 

existing OL, the possession of that license is just one of a number of conditions that must be 

met for the licensee to continue plant operation during the term of the renewed license. Once 

an OL is renewed, State regulatory agencies and the owners of the plant will ultimately decide 

whether the plant will continue to operate based on factors such as the need for power or other 

matters within the State’s jurisdiction or the purview of the owners. 

Thus, for license renewal reviews, the NRC has adopted the following definition of purpose and 

need (GEIS Section 1.3): 

The purpose and need for the proposed action (renewal of an operating license) 

is to provide an option that allows for power generation capability beyond the 

term of a current nuclear power plant operating license to meet future system 

generating needs, as such needs may be determined by State, utility, and where 

authorized, Federal (other than NRC) decision makers. 

This definition of purpose and need reflects the Commission’s recognition that, unless there are 

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

environmental analysis that would lead the NRC to reject a license renewal application, the 

NRC does not have a role in the energy-planning decisions of State regulators and utility 

officials as to whether a particular nuclear power plant should continue to operate. From the 

perspective of the licensee and the State regulatory authority, the purpose of renewing an OL is 

to maintain the availability of the nuclear plant to meet system energy requirements beyond the 

current term of the plant’s license. 

1.5 Compliance and Consultations

CP&L is required to hold certain Federal, State, and local environmental permits, as well as 

meet relevant Federal and State statutory requirements. In its ER, CP&L provided a list of the 

authorizations from Federal, State, and local authorities for current operations as well as 

environmental approvals and consultations associated with HNP license renewal. 

Authorizations and consultations relevant to the proposed OL renewal action are included in 

Appendix E. 

The NRC staff has reviewed the list and consulted with the appropriate Federal, State, and local 

agencies to identify any compliance or permit issues or significant environmental issues of 

concern to the reviewing agencies. These agencies did not identify any new and significant 

environmental issues. The ER states that CP&L is in compliance with applicable environmental 

standards and requirements for HNP. 
Introduction 

August 2008 1-9 NUREG-1437, Supplement 33 

1.6 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

Renewal of Operating Licenses for Nuclear Power Plants.” 

40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment,

Part 1508, “Terminology and Index.” 

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

Progress Energy Carolinas Inc., (Progress Energy). 2006a. Transmittal of Shearon Harris 

Nuclear Power Plant, Application for Renewal of Operating License. Raleigh, North Carolina.

Accessible at ML063350267. 

Progress Energy Carolinas Inc., (Progress Energy). 2006b. Shearon Harris Unit 1, Applicant’s 

Environmental Report, Operating License Renewal Stage. Raleigh, North Carolina. Accessible 

at ML063350276. 

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

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Office of Nuclear 

Regulatory Research, Washington, D.C. 

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

for License Renewal of Nuclear Plants Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.”

NUREG-1437, Volume 1, Addendum 1. Office of Nuclear Regulatory Research, Washington, 

D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555, 

Supplement 1. Office of Nuclear Reactor Regulation, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2007a. “Notice of Acceptance for Docketing of 

the Application for Facility Operating License No. NPF-63 for an Additional 20-Year Period; 

Carolina Power & Light Company, Shearon Harris Nuclear Power Plant, Unit 1.” Federal

Register: Vol. 72, No. 8, pp. 1562-1563. January 12, 2007. Accessible at ML071730450. 
Introduction 

NUREG-1437, Supplement 33 1-10 August 2008 

U.S. Nuclear Regulatory Commission (NRC). 2007b. “Notice of Opportunity for Hearing, and 

Notice of Intent to Prepare an Environmental Impact Statement and Conduct the Scoping 

Process for Facility Operating License No. NPF-63 for an Additional 20-Year Period; Carolina 

Power & Light Company, Shearon Harris Nuclear Power Plant, Unit 1.” Federal Register:

Vol. 72, No. 53, pp. 13139-13142. March 20, 2007. Accessible at ML070790140. 

U.S. Nuclear Regulatory Commission (NRC). 2007c. Environmental Scoping Summary Report 

Associated with the Staff's Review of the Shearon Harris Nuclear Power Plant License Renewal 

Application. Washington, D.C. Accessible at ML071980195. 

U.S. Nuclear Regulatory Commission (NRC). 2007d. “Notice of Availability of the Draft 

Supplement 33 to the Generic Environmental Impact Statement for License Renewal of Nuclear 

Plants, and Public Meeting for the License Renewal of Shearon Harris Nuclear Power Plant, 

Unit 1.” Federal Register. Vol. 72, No. 243, pp. 71973-71974. December 19, 2007. Accessible 

at ML073200701. 
August 2008 2-1 NUREG-1437, Supplement 33 

2.0 DESCRIPTION OF NUCLEAR POWER PLANT AND SITE AND 

PLANT INTERACTION WITH THE ENVIRONMENT 

Shearon Harris Nuclear Power Plant (HNP) is located in Wake County, North Carolina. HNP is 

a single-unit plant with a pressurized light-water reactor that employs a cooling tower-based 

heat dissipation system. HNP is operated by Carolina Power and Light Company, doing 

business as Progress Energy Carolinas, Inc. (CP&L). The plant and its environs are described 

in Section 2.1, and the environment in which the plant is located is presented in Section 2.2. 

2.1 Plant and Site Description and Proposed Plant Operation During the 

Renewal Term

The HNP site is located on approximately 4370 hectares (ha) (10,800 acres [ac]) of land in the 

southwest corner of Wake County, North Carolina, on the northwest shore of the 1680-ha 

(4150-ac) Harris Reservoir, approximately 26 kilometers (km) (16 miles [mi]) northeast of the 

city of Raleigh, North Carolina. Figures 2-1 and 2-2 show the site location and features within 

80 km (50 mi) and 10 km (6 mi), respectively. 

2.1.1 External Appearance and Setting 

The plant is located on a peninsula that extends into Harris Reservoir from the northwest. The 

Tom Jack Creek arm of the reservoir lies to the west; the Thomas Creek arm of the reservoir 

lies to the east. The reactor building and generating facilities lie within a nuclear exclusion area. 

The exclusion area, composed of both high ground and portions of Harris Reservoir, 

encompasses approximately 1430 ha (3535 ac) (Figure 2-3). The HNP site is a much larger 

tract of land that includes the exclusion zone, Harris Reservoir, and some surrounding lands 

totaling approximately 4370 ha (10,800 ac) (Progress Energy 2006b). 

Of the 4370 ha (10,800 ac) that compose the HNP site, approximately 1680 ha (4150 ac) were 

inundated between 1980 and 1983, which created the Harris Reservoir. A second, smaller 

impoundment, the auxiliary reservoir, was created by damming the Tom Jack Creek arm of 

Harris Reservoir. This 130 ha (321 ac) reservoir was created to serve as a second source of 

water for the emergency service water system (Progress Energy 2006b). 

Approximately 400 ha (1000 ac) of vegetation were cleared during development and 

construction of the HNP site. Most borrow areas and laydown yards were planted with pines in 

1981 and 1982. Approximately 180 ha (440 ac) of the site were cleared and graded and are 

now occupied by generating facilities, parking lots, warehouses, equipment storage and 

laydown areas. Most of the remaining acreage, 2000 to 2500 ha (5000 to 6000 ac), is forested 

(Progress Energy 2006b). 


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NUREG-1437, Supplement 33 2-4 August 2008 

Figure 2-3. HNP Site and Harris Reservoir 

2.1.2 Reactor Systems 

HNP is a single-unit plant with a conventional domed concrete containment building. The plant 

includes a pressurized light-water reactor nuclear steam supply system and turbine generator 

designed and manufactured by Westinghouse Electric Company. The plant achieved initial 

criticality on January 3, 1987, and began commercial operation on May 2, 1987. 
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August 2008 2-5 NUREG-1437, Supplement 33 

The reactor containment structure is a steel-lined, reinforced-concrete cylindrical structure 

capped with a hemispheric dome designed to withstand internal pressure of 0.310 MPa 

(45 psig) above atmospheric pressure (AEC 1973). The walls of the containment structure are 

1.4 m (4.5 ft) thick. With its engineered safety features, the reinforced-concrete containment 

structure (reactor building) is designed to withstand severe weather conditions (e.g., tornadoes 

and hurricanes) and to provide radiation protection during both normal operations and designbasis accidents (Progress Energy 2006b). 

Figure 2-4 shows the plant layout, including the location of the reactor building, the turbine 

building, the control building, and the waste processing building. 

Figure 2-4. Harris Nuclear Power Plant Powerblock Area

Originally, HNP was built and operated at the design rating of 2775 megawatts thermal (MWt), 

producing an output of approximately 860 megawatts electric (MWe). On October 16, 2001, 

NRC approved an increase in the licensed maximum core thermal level of HNP from 2775 MWt 

to 2900 MWt, an increase of approximately 4.5 percent (NRC 2001). This, in turn, resulted in 
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NUREG-1437, Supplement 33 2-6 August 2008 

electrical ratings of 955 MWe (gross) and 900 MWe (net) (Progress Energy 2006b). The 

4.5 percent power uprate for HNP was carried out during an extended outage for refueling and 

steam generator replacement that began in late September 2001 and ended in early January 

2002 (Progress Energy 2006a). 

HNP was designed originally for four reactors and four spent fuel storage pools, but only one 

reactor was built. However, the plant’s fuel handling building has four spent fuel pools, as 

originally designed. The NRC operating license for HNP that was issued in 1987 authorized 

CP&L to use two of the four pools for storage of spent fuel from HNP and the company’s other 

nuclear units: Brunswick, Units 1 and 2, and H. B. Robinson. In December 1998, CP&L asked 

the NRC for a license amendment that would allow the other two spent fuel pools to be placed 

in service. The spent fuel pool expansion was approved in December 2000 (NRC 2000). 

Over the next several years, spent fuel from the Brunswick and Robinson plants was shipped to 

HNP in CP&L-owned, NRC-licensed casks on dedicated railroad trains. The shipping routes 

were NRC-approved and CP&L provided notification to appropriate state officials, as required by 

the Code of Federal Regulations. 

CP&L shipped spent fuel from the Robinson Plant to HNP until 2004 when ground was broken 

for an Independent Spent Fuel Storage Installation (ISFSI) at the Robinson Plant. The ISFSI 

was completed in 2005, and the initial load of spent fuel was placed in storage in August of that 

year. Shipments of spent nuclear fuel from the Brunswick Plant to HNP are expected to end in 

2008. The NRC license for the casks was extended from 2005 until 2008. 

2.1.3 Cooling And Auxiliary Water Systems 

HNP uses a closed-cycle heat dissipation system with a natural-draft cooling tower for its single 

unit. Unless otherwise noted, the discussion of the cooling-water system is adapted from the 

Environmental Report (ER) (Progress Energy 2006b), or information was gathered at NRC’s site 

audit.

On the eastern side of HNP, cooling tower makeup (CTMU) water is withdrawn from either the 

Harris Reservoir, or the auxiliary reservoir by way of intake channels, each with its own intake 

structure. The first intake structure houses both CTMU water pumps and non-recirculating 

emergency service water pumps. The second intake structure contains only non-recirculating 

emergency service water pumps. 

Two pumps, each rated at 26,000 gallons per minute (gpm), located within the main intake 

structure, withdraw CTMU water after it passes through trash bars that remove large debris. 

Under normal operation, only one pump is needed to supply makeup water to replace losses to 

evaporation and blowdown. In times of drought, the makeup water pumps can also transfer 

water to the auxiliary reservoir. These pump bays are equipped with traveling screens that have 

a mesh size of 3/8 in. and rotate as needed. The approach velocity for these screens is 9 m/sec 
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August 2008 2-7 NUREG-1437, Supplement 33 

(0.5 ft/sec). Any debris caught on the screens falls into a trough, leading to a bucket, which is 

cleaned out as necessary. 

Within each of the two intake structures, there are two emergency service water pumps. Each 

of these pumps is rated at 20,000 gpm. These pumps are tested at regular intervals to ensure 

reliable operation. These pumps are equipped with traveling screens that have a mesh size of 

7/16 in. When the emergency pumps are in operation for testing, these screens rotate 

continuously. The approach velocity for these screens is 9.1 m/s (0.5 ft/s). 

Three pumps, each rated at 161,000 gpm, circulate water into the main condenser. Chlorine is 

injected three times a day to prevent biofouling in the pipes. In addition, two pumps, each rated 

at 25,000 gpm, supply service water to the power plant. Under normal operating conditions, the 

total rated capacity of the cooling water system is 533,000 gpm. 

After the cooling water passes through the condenser, it is then transferred to a hyperbolic 

natural-draft cooling tower. The 159 m (523 ft) tall cooling tower can remove 6.7 x 109 British 

thermal units per hour (BTU/hr) of excess heat to lower the water temperature by up to 14°C

(25°F). An average 54.5 million L/day (14.4 million gal/day [MGD]) of water in the cooling loop 

are lost due to evaporation from the cooling tower. An additional 15 million L/day (4 MGD) 

(about 10,600 L/min [2800 gpm]) are lost to blowdown. This water is replaced by the makeup 

water from the Harris Reservoir. 

HNP discharges blowdown and wastewater through seven permitted outfalls as described in 

Section 2.2.3.1. All wastewater streams at HNP from outfalls 001 through 005 are combined 

into outfall 006 and discharged through a 91-cm (36-in.) diameter pipe in the southern portion of 

the Harris Reservoir at a depth of 12 m (40 ft). The sewage treatment plant effluent from the 

Harris Energy and Environmental Center is discharged through outfall 007 in the northern neck 

of the reservoir. No discharges are sent to the auxiliary reservoir. 

2.1.4 Radioactive Waste Management Systems and Effluent Control Systems 

HNP radioactive waste (radwaste) systems are designed to collect and treat radioactive 

materials that are produced as a byproduct of plant operations. The design objective for the 

radwaste systems is to provide equipment, instrumentation, and operating procedures such that 

the discharge of radioactivity from the plant will not exceed the limits set forth in 10 CFR 

Part 20. Furthermore, the radwaste systems are designed and operated to meet the dose 

design objectives of 10 CFR Part 50, Appendix I, to meet the criterion of “as low as reasonably 

achievable (ALARA).” Section 3.8.1.1 of the GEIS (NRC 1996) provides a summary of 

regulatory requirements and specific numerical dose limits. 

Liquid, solid, and gaseous waste processing systems are housed in the Waste Processing 

Building (WPB), which is located just southwest of the containment building. The WPB is a 

reinforced-concrete, seismic Category I structure, with cast-in-place, reinforced-concrete 

exterior walls and interior shear walls. 
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NUREG-1437, Supplement 33 2-8 August 2008 

Radioactive waste material results from both the fission of uranium-235 fuel and from neutron 

activation of materials in the reactor systems. Radioactive fission products build up within the 

fuel pellets and migrate into the space that is outside the pellets, but within the sealed fuel rods. 

However, small quantities of fission products migrate from the fuel rods into the reactor coolant. 

Neutron activation of trace concentrations of metals entrained in reactor coolant such as iron 

and cobalt creates radioactive isotopes of these metals. Both fission and activation products in 

liquid and gaseous forms are removed continuously from the reactor coolant by being captured 

on filter media or by demineralization. 

When a certain percentage of the fuel in a fuel rod assembly has been exhausted (i.e., 

fissioned), it is called spent fuel, and the spent fuel rod assembly is removed from the reactor 

core for disposal. Spent fuel assemblies are removed from the reactor core during reactor 

shutdown periods, and they are stored in a spent fuel pool. 

HPN publishes an Annual Radiological Environmental Operating Report that contains data on 

the radiological impact of radioactive effluents on the environment based on the sampling of 

environmental media. In addition, the results from monitoring discharges of radioactive liquid 

and gaseous effluents are contained in an annual report entitled, Shearon Harris Nuclear Power 

Plant, Annual Radioactive Effluent Release Report. The HNP Offsite Dose Calculation Manual

(ODCM) contains the methodology and parameters used in the calculation of off-site doses 

resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid 

effluent monitoring alarm and trip set points, and in the conduct of the Radiological 

Environmental Monitoring Program (REMP). The ODCM also contains the radioactive effluent 

controls and radiological environmental monitoring activities and descriptions of the information 

that should be included in the Radiological Environmental Operating Program reports and in the 

Radioactive Effluent Release reports that are required by 10 CFR Part 50, Appendix I, and 

10 CFR Part 50.36a. 

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls 

Liquid radioactive wastes are collected, monitored, and processed by a combination of 

mechanisms, including holdup (permitting radioactive decay), filtration, demineralization, and 

ion-exchange treatment (removal of insoluble particulates and soluble contaminants), degassing 

(removal of dissolved gases), and evaporation (volume reduction). After processing, most of 

the liquids are recycled back into the primary coolant system or other liquid systems within the 

plant and reused. The remaining wet residues or concentrates are solidified and sent offsite for 

disposal.

Liquid waste from various equipment and floor drains and discharges from the reactor process 

and auxiliary systems is processed through the Liquid Waste Processing System (LWPS) that 

provides for the collection, storing, processing, and controlled release of radioactive and 

potentially radioactive liquids (Progress Energy 2006a). If sampling results show that liquid 

concentrations are sufficiently low, liquid waste may be released to the environment. The 
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August 2008 2-9 NUREG-1437, Supplement 33 

discharge of treated wastes is controlled and monitored to ensure that any discharges are 

ALARA and that they are in conformance with the requirements specified in 10 CFR Part 20 and 

10 CFR Part 50, Appendix I. The LWPS is designed to collect plant radioactive waste water 

and, by processing, reduce the radionuclide concentration to permit its discharge to the environs 

(Progress Energy 2006a). 

The HNP Radioactive Effluent Release Reports for the 5-year period from 2002 through 2006 

were reviewed (Progress Energy 2003a, 2004a, 2005a 2006d, 2007a). No uncontrolled liquid 

releases to the environment were reported. Calculated doses in the HNP Radioactive Effluent 

Release Reports were very small for each year during the 5-year period and were within dose 

limits. Releases of radioactive liquids are expected to continue at approximately the same rate 

during the renewal period. Section 2.2.7 provides more discussion of the calculated doses to 

the maximally exposed individual as a result of radioactive liquid effluent releases. 

Based on the system described above as well as the design and previous performance of the 

HNP plant, liquid effluents would be expected to be released in the similar amounts during the 

renewal period. Therefore, the resulting doses to members of the public would be expected to 

be below the dose design objectives in Appendix I to 10 CRF Part 50. 

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls 

The HNP Gaseous Waste Processing System (GWPS) is designed to collect, process, and 

store gaseous wastes that are generated by plant operations. All GWPS equipment is located 

inside the WPB, and all GWPS equipment is controlled from the WPB Control Room. The ten 

waste gas decay tanks of the gaseous radwaste system provide adequate off-gas holdup time 

to allow significant decay of the short-lived radionuclides (such as nitrogen-16 and oxygen-19), 

as well as the decay of short-lived isotopes of the fission product noble gases (primarily xenon 

and krypton) (Progress Energy 2006a).

The GWPS system is designed to ensure that the calculated dose to members of the public 

from the release of gaseous effluents is in accordance with the dose design objectives of 

Appendix I to 10 CFR Part 50. The GWPS has sufficient capacity and redundancy to control 

releases such that the discharge(s) is within the limits of 10 CFR Part 20 (Progress Energy 

2006a).

The GWPS conforms to the requirements of General Design Criterion 60 of Appendix A to 

10 CFR Part 50 by providing both holdup and storage capacity. This design feature reduces the 

need for releasing radioactive effluents during unfavorable environmental conditions. The 

design features of the GWPS are based on continuous operation of the plant with the 

assumption that one percent of the rated core power is generated by fuel rods containing 

cladding defects and the assumption that this leaky condition exists over the lifetime of the 

plant.
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NUREG-1437, Supplement 33 2-10 August 2008 

The HNP Radioactive Effluent Release Reports for the 5-year period from 2002 through 2006 

were reviewed (Progress Energy 2003a, 2004a, 2005a 2006d, 2007a). No unplanned gaseous 

effluent release occurred during 2002, one during 2003, seven during 2004, eight during 2005, 

and two during 2006. The calculated offsite doses were well below all administrative dose limits 

for each of the five years. Section 2.2.7 provides more discussion of the calculated doses to the 

maximally exposed individual as a result of radioactive gaseous effluent releases. 

All gaseous effluent discharge paths are monitored for radioactivity, in compliance with General 

Design Criterion 64 of Appendix A to 10 CFR Part 50, to ensure that radioactivity concentrations 

do not exceed predetermined limits. If a limit is exceeded, discharge will be terminated 

automatically (Progress Energy 2006a). 

2.1.4.3 Solid Waste Processing 

The Solid Waste Processing System (SWPS) collects, controls, processes, packages, handles, 

and temporarily stores radioactive waste generated as a result of normal operation of the plant, 

including anticipated operational occurrences. Solid wastes include filter sludge, evaporator 

bottoms, spent resins, tools and equipment (that are either radioactive or contaminated with 

radioactive material), and miscellaneous radioactive wastes from plant and laboratory 

operations, maintenance, and cleanup operations. The objective of the Solid Waste Processing 

System is to convert radioactive wastes into packaged forms acceptable for offsite disposal as 

solid waste. In addition, the SWPS is to provide a reliable means for processing the material 

while minimizing radiation exposure to plant personnel and to the general public in compliance 

with the requirements of 10 CFR 20 and 10 CFR 50. The SWPS was designed to perform 

these functions without limiting the operation or availability of the plant. There are also 

provisions for the use of vendor-supplied solidification or dewatering systems. The SWPS 

prepares waste material for transportation to an offsite disposal facility, and solid radioactive 

waste is shipped off-site in vehicles that are equipped with adequate shielding to comply with 

Department of Transportation (DOT) and NRC regulations. Provisions are made for the use of 

a Vendor Mobile Solid Waste Processing System (Progress Energy 2006a). 

The Waste Processing Building (WPB) houses the SWPS, the Liquid Waste Processing System 

(LWPS), and the Gaseous Waste Processing System (GWPS). In addition, the WPB contains 

laboratories and personnel facilities. The WPB provides barriers against fire, flooding, water 

spray, high energy fluid release, and airborne objects. Tanks and processing equipment, which 

contain large quantities of radwaste, are shielded, and ventilation air flows from areas having 

low airborne radioactivity concentrations to areas that may have higher radioactivity 

concentrations (Progress Energy 2006a). Both of these design features are to help effect 

implementation of ALARA for personnel. 

Process wastes originate in the LWPS, the Chemical and Volume Control System (CVCS), the 

Boron Thermal Regeneration System (BRS), and other HNP systems. Wet wastes that are 

generated during normal plant operations are dewatered or solidified. The SWPS is designed to 
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August 2008 2-11 NUREG-1437, Supplement 33 

hold one day of production of evaporator concentrates at normal generation rates before 

solidification is required. The SWPS receives process waste filter sludge, evaporator bottoms, 

and spent resins, and other solid radioactive wastes such as contaminated paper, cloth, 

construction materials, laboratory supplies, and other non-retrievable items such as those that 

are generated by normal operations of the plant (Progress Energy 2006a). 

Dry active waste (DAW) processing is performed by an off-site vendor that uses an effective 

type of volume reduction for the various types of DAW shipped from the HNP. The DAW is 

collected in shipping containers that are retained on site until a sufficient quantity of waste has 

been collected for shipment. This waste is then shipped to an off-site DAW processing facility 

where it is processed, packaged for disposal, and ultimately shipped to the low-level waste 

disposal facility (Progress Energy 2006a). Transportation and disposal of solid radioactive 

wastes are performed in accordance with the applicable requirements of 10 CFR Part 20, 

10 CFR Part 71, and 10 CFR Part 61 as well as applicable state regulations. 

For 2006, HNP reported the volumes and radioactivity shipped offsite in its Annual Radioactive 

Release Report for Year 2006 (Progress Energy 2007a). For Class A waste, a total of 4.59 X 

105 MBq (12.4 Ci) and 59.03 m3 (2084.69 ft3) of spent resins and DAW were shipped offsite. 

For Class B waste, a total of 2.03 X 105 MBq (5.48 Ci) and 0.94 m3 (33.20 ft3) of spent resins 

were shipped offsite. For Class C waste, a total of 2.68 X 106 MBq (72.57 Ci) and 1.66 m3

(58.62 ft3) of spent resins, filter sludges, evaporator bottoms, mechanical filters, and 

contaminated equipment were shipped offsite. The majority of the radioactivity was due to 

cobalt-58, cobalt-60, chromium-51, manganese-54, iron-55, nickel-63, and cesium-137. No 

irradiated components or control rods were disposed of in 2006. Similar quantities of 

radioactive waste are expected during the license renewal term. 

2.1.5 Nonradioactive Waste Systems 

Nonradioactive waste, such as nonhazardous waste, hazardous and universal waste, mixed 

waste, sanitary and industrial wastewater, sanitary sludges, and air emissions is generated at 

HNP from normal operations and plant maintenance. These waste streams are regulated by 

local and State agencies through permitting and compliance activities. 

2.1.5.1 Nonradioactive Waste Streams 

Nonhazardous waste, such as office trash, used oil, and kitchen waste, is generated as part of 

routine daily operations. From 2002 to 2006, approximately 150,000 kg (180 tons) to 

300,000 kg (320 tons) of nonhazardous solid waste was generated and disposed of at the Wake 

County Landfill (Progress Energy 2007d). Two trash compactors are used to decrease the 

volume of trash prior to offsite disposal. 

CP&L operated an unlined industrial landfill onsite until December 2003 for the disposal of 

wood, concrete, paint and paint waste, activated charcoal, industrial greases, and waste ion 

exchange resins. North Carolina Department of Environmental and Natural Resources 
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NUREG-1437, Supplement 33 2-12 August 2008 

(NCDENR) issued a letter of closure for the landfill in May 2005. As a condition of the Stateapproved Closure Plan, CP&L performs groundwater monitoring around the closed landfill. 

Section 2.2.3.2 provides more details on the groundwater monitoring program. 

The Resource Conservation and Recovery Act (RCRA) established regulations regarding the 

treatment, storage, and/or disposal of hazardous waste. RCRA regulations are administered in 

North Carolina by the NCDENR (15A NCAC 13A.0100). HNP is a small-quantity hazardous 

waste generator (NCD 991278284), generating less than 1000 kg (2200 lb) of hazardous waste 

per month. From 2003 to 2006, approximately 500 kg (1100 lbs) of hazardous waste was 

generated annually. In 2002, approximately 2200 kg (5000 lb) of hazardous waste was 

generated.

Universal wastes are hazardous wastes that have been specified as a universal waste by the 

EPA. Universal wastes, including mercury-containing equipment, batteries, lamps, and 

pesticides, have specific regulations to ensure they are properly handled and treated (40 CFR 

Part 273). North Carolina has incorporated, by reference, the EPA’s regulations regarding 

universal wastes (15A NCAC 13A.0119). 

HNP is a small-quantity generator of universal waste, generating waste batteries, waste 

fluorescent lamps, waste mercury-containing equipment, and computer components from 

normal facility operations. The universal wastes are accumulated in satellite areas and then 

stored in a designated storage warehouse. The wastes are disposed of off-site by a contract 

service. 

NCDENR conducts random compliance audits of HNP’s nonradiological waste program. The 

last audit of HNP by NCDENR was in 2005 and no violations were noted. 

The Emergency Planning and Community Right-to-Know Act (EPCRA), requires applicable 

facilities to provide information on hazardous and toxic chemicals to emergency planning 

authorities. HNP is subject to Federal EPCRA and North Carolina Right-to-Know Act reporting 

requirements and, therefore, submits annual Section 312 Tier II reports to local emergency 

agencies for substances such as resins, gases, sealants, antifreeze, and oils (Progress Energy 

2007g).

Low-level mixed wastes (LLMW) are wastes that exhibit hazardous characteristics and contain 

low-levels of radioactivity (40 CFR 266). EPA (or the authorized state agency) regulates the 

hazardous component of the mixed waste through RCRA, and NRC regulates radioactive waste 

subject to the Atomic Energy Act. North Carolina has incorporated by reference federal 

regulations exempting LLMW from RCRA storage and treatment regulations provided the LLMW 

meets specific conditions (15A NCAC 13A.0111). 

HNP accumulates LLMW, such as contaminated used oil or asbestos gaskets, during routine 

facility operation and maintenance. Although a small amount of mixed waste is accumulated at 

HNP, no LLMW has ever been shipped offsite for disposal. When it becomes necessary, a 
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August 2008 2-13 NUREG-1437, Supplement 33 

contract service would remove the LLMW from HNP and dispose of the waste at a permitted 

facility.

There are two State-permitted sewage treatment plants that treat sanitary waste from the HNP 

site and the Harris Environmental and Education Center (HEEC). Sludge is periodically 

removed from the HNP treatment plant, such as during outages, and either sent to the HEEC 

treatment plant or is removed by a contractor that land applies the sludge offsite. Wastewater 

from the HNP treatment is released to the Harris Reservoir through a National Pollutant 

Discharge Elimination System (NPDES) permitted outfall (Outfall No. 002). The HEEC sewage 

treatment plant also sends wastewater through an NPDES-permitted outfall (Outfall No. 007) to 

Harris Reservoir. More information regarding the NPDES permit and associated outfalls is 

provided in Section 2.2.3.1. 

CP&L has procedures in place for the proper handling and disposal of biological waste 

according to Federal (29 CFR 1910.1030) and State (15A NCAC 13B.1200) regulations. 

Nonradioactive biological waste is to be taken to the In-Processing Facility for disposal. If the 

biological waste has a radiological component, it must still be marked as biological waste but 

removed by the radiological waste contractor. 

Nonradioactive air pollutants are released into the atmosphere from the use of oil-fired burners 

and emergency diesel generators. HNP has a Synthetic Minor Air Permit (No. 08455Ro4) from 

the NCDENR, Division of Air Quality. More information about air emissions is provided in 

Section 2.2.4. 

2.1.5.2 Pollution Prevention and Waste Minimization 

CP&L has an active waste minimization program at HNP. Aluminum cans, antifreeze, batteries 

(non-universal waste), cardboard, oil, paper, printer cartridges, scrap metal, wood, pallets, and 

lighting are all recycled, diverting thousands of pounds of waste from the landfill. 

The EPA's Office of Pollution Prevention and Toxics has established a clearinghouse that 

provides information regarding waste management and technical and operational approaches to 

pollution prevention. The EPA’s clearinghouse can be used as a source for additional 

opportunities for waste minimization and pollution prevention at HNP, as appropriate. 

Additionally, the NCDENR Division of Pollution Prevention and Environmental Assistance 

provides compliance resources, technical assistance, and training for industry on pollution 

prevention initiatives. 

2.1.6 Plant Operation and Maintenance 

Maintenance, inspection, testing, and surveillance activities are performed at HNP in order to 

satisfy the current licensing requirements for the facility and to ensure compliance with 

environmental and safety regulations. Some activities can be performed while the reactor is 

operating, but others require that the facility be shut down before they can be performed. Long-
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NUREG-1437, Supplement 33 2-14 August 2008 

term outages are required for refueling and for certain types of repairs or maintenance activities, 

such as replacement of a major reactor system or major support system component. HNP is on 

a nominal 18-month refueling cycle (Progress Energy 2006b). During refueling outages, site 

employment increases above the permanent workforce by as many as 800 workers for 

temporary duty. Progress Energy has stated that no refurbishment is needed (Progress Energy 

2006b); therefore, any employment increment during license renewal depends on the programs 

and activities that are required for managing the effects of aging. 

Numerous maintenance, inspection, testing, and surveillance activities are conducted. Some of 

these are periodic (such as annually), while others are conducted on an as needed basis. 

Some of these activities can only be performed during a refueling outage. Inspections for 

abrasion, abnormal wear, signs of corrosion, material degradation, bent or damaged members, 

loose bolts/components, loose connections, broken welds, component performance, etc. are 

conducted (Progress Energy 2006b). 

2.1.7 Power Transmission Lines 

HNP is currently connected to the regional grid via seven 230-kV transmission lines in the HNP 

switchyard, all of which are owned, operated, and maintained by Progress Energy. The Final 

Environmental Statement (FES) for the construction of the HNP site (AEC 1973) and the FES 

for the operation of the HNP site (NRC 1983) discuss eight transmission lines intended to 

connect the HNP site with the regional transmission grid. Changes have been made to the 

transmission system since the publication of these FESs. Six of the eight lines discussed in the 

FESs were built, and one new line was added later during operation of HNP (Progress Energy 

2006b). Additionally, the Apex-U.S. 1 line, discussed below, has been shortened. 

Transmission lines considered in scope for license renewal are those constructed to connect the 

facility to the transmission system (10 CFR 51.53(c)(3)(ii)(H)); a discussion of the seven inscope transmission lines follows. 

Four transmission lines (Siler City, Cape Fear North, Cape Fear South, and Fort Bragg–

Woodruff Street) originate at the HNP switchyard and share a 110-m (350-ft) wide right-of-way 

(ROW) for 1.6 km (1 mi), located within the HNP site boundary. The Siler City and Fort Bragg–

Woodruff Street transmission lines then split, each having a separate 30-m (100-ft) wide ROW. 

The Cape Fear North and Cape Fear South transmission lines continue sharing a ROW, which 

is 30 m (100 ft) wide after the first mile. The remaining three transmission lines, Apex–U.S. 1, 

Erwin, and Wake, each have 30-m (100-ft) wide ROWs starting at HNP. Figure 2-5 shows the 

location of all seven transmission line ROWs. 
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August 2008 2-15 NUREG-1437, Supplement 33 

Figure 2-5. Map of Transmission Lines within 80-km (50-mi) Radius of HNP 

(Progress Energy 2006b) 
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NUREG-1437, Supplement 33 2-16 August 2008 

Originating at the HNP switchyard, the 50-km (31-mi) long Siler City line runs south from the 

plant, and then west to a substation in Siler City. The 12-km (7.4-mi) long Cape Fear North line 

and 10-km (6.5-mi) long Cape Fear South line both extend from the HNP switchyard to the 

Cape Fear Plant. The Cape Fear Plant transmits electricity to the grid via these lines in the 

plant’s switchyard. The lines also provide a source of power from the Cape Fear Plant to HNP 

for activities such as refueling. Therefore, the sections of the Cape Fear North and Cape Fear 

South lines that run from the Cape Fear Plant switchyard to HNP are considered in scope for 

this SEIS. The 58-km (36-mi) long Fort Bragg–Woodruff Street transmission line runs south 

from the plant to the Woodruff Street substation. A ROW remains along the stretch that 

formerly extended an additional 34 km (21 mi) to Fayetteville, North Carolina, and is considered 

out of scope for this SEIS. The Apex–U.S. 1 line extends 6 km (4 mi) northeast of HNP to a 

substation in Apex. The 48-km (30-mi) long Erwin transmission line, referred to in the FES for 

construction as the “Harris–Fuquay–Erwin North line,” extends east of the HNP site to a 

substation near Erwin (AEC 1974). The 61-km (38-mi) long Wake transmission line runs 

northeast to a substation near Raleigh. 

CP&L owns and operates 227 km (142 mi) of transmission lines and maintains 2747 ha 

(1717 ac) of ROWs associated with the transmission lines (Progress Energy 2006b). The 

transmission lines do not cross any Federal, state, or local parks, though the lines do cross land 

established and set aside for the North Carolina Game Lands program in four locations: 

Chatham Game Lands and Shearon Harris Game Lands to the south and southwest of HNP, 

and Shearon Harris Game Lands to the east and northeast of HNP (Progress Energy 2006b). 

ROW vegetative maintenance practices use an Integrated Vegetation Management (IVM) 

approach that includes both mechanical and chemical control methods. Mechanical methods 

consist primarily of mowing, with supplementary pruning, felling, and hand trimming as needed. 

Mowing is completed on a 3-year cycle. Chemical control methods consist of application of 

EPA-approved herbicides and tree-growth-regulating chemicals (Progress Energy 2006b).

CP&L staff aims spray away from streams and wetlands when applying chemicals to ROWs that 

cross those areas and performs flyover inspections three times each year to identify any 

vegetative interference with transmission lines. Procedures are in place to manage 

environmental incidents that might occur within the ROW, such as a chemical build-up in a 

wetland area. CP&L staff limits erosion around stream crossings and wetlands by using 

appropriate procedures and methods. 

2.2 Plant Interaction with the Environment

Sections 2.2.1 through 2.2.8 provide general descriptions of the environment near HNP as 

background information. They also provide detailed descriptions where needed to support the 

analysis of potential environmental impacts of refurbishment and operation during the renewal 

term, as discussed in Chapters 3 and 4. Section 2.2.9 describes the historic and archaeological 
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August 2008 2-17 NUREG-1437, Supplement 33 

resources in the area, and Section 2.2.10 describes possible impacts associated with other 

Federal project activities. 

2.2.1 Land Use 

HNP is located primarily in the southwest corner of Wake County with a small portion of the site 

extending into southeastern Chatham County, North Carolina (Figure 2-1). The City of Raleigh 

is located approximately 26 km (16 mi) to the northeast of HNP and the City of Sanford is 

located approximately 24 km (15 mi) to the southwest (Figure 2-2). The Cape Fear River flows 

in a northwest-to-southeast direction approximately 11 km (7 mi) south of HNP (Figure 2-1). 

In 1980, the Carolina Power & Light Company (CP&L) constructed a dam on Buckhorn Creek 

about 4 km (2.5 mi) north of its confluence with the Cape Fear River to create the Harris 

Reservoir, which is used for cooling tower makeup water. The HNP power block area, 

consisting of the reactor building, generating facilities, and switchyard, is located on a peninsula 

extending southeast into the Harris Reservoir; about 7 km (4.5 mi) north of the Harris Dam 

(Figure 2-3).

The industrial portion of the HNP site occupies approximately 178 ha (440 ac) and consists of 

generating facilities, warehouses, parking lots, equipment storage, and laydown areas. An 

additional 300 ha (700 ac) of the site have been leased to Wake County for a Fire/Rescue 

Training Facility (8 ha [20 ac]) and for Harris Lake County Park (280 ha [680 ac]). Most of the 

remaining portion of the HNP site (between 2000 and 2500 ha (5000 and 6000 ac]) is forested 

and managed for timber production (Progress Energy 2006b). 

2.2.2 Water Use

HNP uses a closed-cycle cooling system with cooling tower makeup (CTMU) water, emergency 

service water, plant service water, and potable water all supplied from the Harris Reservoir or 

the auxiliary reservoir. The main Harris Reservoir has a full pool elevation of 67 m (220 ft) above 

mean sea level (MSL) and covers an area of 1680 ha (4150 ac). The auxiliary reservoir, which 

serves as the HNP ultimate heat sink, has a surface area of approximately 130 ha (321 ac) and 

an average surface elevation of 77 m (252 ft) above MSL (Progress Energy 2006b). 

2.2.2.1 Surface Water Use 

During normal operation of HNP, an average 54.5 million L/day (14.4 MGD) of water are lost 

through evaporation and an additional 15 million L/day (4 MGD) are lost to blowdown (Progress 

Energy 2006b). CTMU water is withdrawn from Harris Reservoir, which is equipped with an 

intake structure and two CTMU pumps, each rated at 26,000 gpm. In addition, the auxiliary 

reservoir intake structure has two emergency service water pumps, each rated at 20,000 gpm. 

Operations of the HNP water systems are described in Section 2.1.3. 
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NUREG-1437, Supplement 33 2-18 August 2008 

The CTMU pumps are also used to transfer water from the main reservoir to the auxiliary 

reservoir to maintain the volume of water needed for the emergency service water system, 

particularly during drought conditions. The emergency service water system allows water from 

either reservoir to be pumped to the reactor and other critical components during a loss-ofcoolant accident or loss of off-site power. 

Water from the auxiliary reservoir is treated onsite and used as potable water throughout the 

plant. Some of the water is also piped to the HNP demineralized water system where it is 

treated and demineralized for use in a variety of plant components and systems. HNP does not 

utilize water from outside sources and has no plans to do so in the future (Progress Energy 

2006b).

2.2.2.2 Groundwater Use 

HNP is located in the Piedmont physiographic province and is underlain by Triassic age 

sedimentary rocks of the Newark Group. The uppermost aquifer depth ranges from 9 to 27 m 

(30 to 90 ft) below the surface and lies within the bedrock material. The residual soils derived 

from the underlying bedrock are dominated by clay and impede groundwater recharge to the 

bedrock aquifer. Due to the low permeability of the bedrock material, groundwater flow beneath 

the plant and surrounding area primarily occurs in fractures located within the bedrock. This 

results in limited use of groundwater in the area. Average yields from area wells are reported to 

be less than 19 L/min (5 gpm), but yields may range up to 80 L/min (20 gpm). All public water 

supplies within the region obtain water from surface water sources (Progress Energy 2006b). 

HNP does not use groundwater for any of its systems. 

HNP has a NCDENR water withdrawal registration that allows for water withdrawal from the 

Cape Fear River, the average daily withdrawal is 30 MGD. Since 2000 the North Carolina 

Drought Management Council (NCDMC) has been recording drought conditions in the State of 

North Carolina. The data historically collected reflects a cyclic behavior in the drought 

conditions present at the counties where HNP is located and the downstream counties which 

get their water from the Cape Fear River Basin. During a normal year, drought conditions in the 

Cape Fear River Basin would range from “no-drought” conditions to “D-4 Exceptional Drought” 

conditions. While there is uncertainty in what could be the conditions during the extended 

period of operation of HNP, the staff expects that the drought conditions will not vary 

significantly from the historically recorded data. The State of North Carolina would ultimately 

decide how to manage and allocate usage of water resources during drought conditions. 

2.2.3 Water Quality 

2.2.3.1 Surface Water 

Surface water quality is regulated through the EPA NPDES permit program. Section 402 of the 

Clean Water Act specifies that “NPDES prohibits [discharges] of pollutants from any point 
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August 2008 2-19 NUREG-1437, Supplement 33 

source into the nation’s waters except as allowed under an NPDES permit.” Its purpose is to 

regulate the discharge of wastewater to maintain water quality of receiving water bodies. The 

EPA delegated its authority to NCDENR for administration of the NPDES program in North 

Carolina.

The NCDNER issued renewed HNP NPDES Permit No. NC0039586 with an effective date of 

March 1, 2007 (Progress Energy 2007c). There are seven major wastewater discharge points 

(outfalls) at HNP. Outfalls 001 through 005 are each individually monitored and are combined 

at Outfall 006 in a 91 cm (36 in) diameter pipe which discharges to the southern part of Harris 

Reservoir at a depth of 12 m (40 ft). Outfall 006 is sampled on the edge of the HNP power 

block area prior to the combined waste water moving down-gradient to the reservoir. 

Outfall 007 discharges wastewater from the Harris Energy and Environmental Center sewage 

treatment plant located on the north end of Harris Reservoir. The wastewater outfalls are 

further described in Table 2-1.

Within the past 5 years, there have been three exceedances within HNP’s water monitoring 

program.

• 2/18/2004: Sewage overflow in Outfall 007 

• 2/23/2004: Elevated chlorine levels in Outfall 001 due to a stuck pump controller 

• 6/25/2004: Elevated zinc concentrations in Outfall 006 (combined outfall) 

Table 2-1. HNP Wastewater Discharge Outfalls 

Outfall

Number 

Description Flow Rate 

001 Cooling Tower Blowdown 4–6 MGD 

002 Sewage Treatment Facility 0.025 MGD 

003 Metal Cleaning Wastes intermittent 

004 Low-Volume Wastes 0.2 MGD 

005 Radwaste Treatment System 10 gpm 

006 Combined Outfall 4–6 MGD 

007 Harris Energy and Environmental 

Center Wastewater 

0.017 MGD 

Source: Progress Energy 2007c 

The NCDENR was notified of each occurrence and the exceedance was immediately corrected.

There have been no Notices of Violation (NOVs) at HNP with regard to water monitoring 

programs in the past 5 years (since 2002). 
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NUREG-1437, Supplement 33 2-20 August 2008 

In April 2006 HNP received a wastewater pump and haul permit from the NCDNER to remove 

8500 gpd from the waste water treatment plant and have it treated at the Harris Energy and 

Electrical Center sewage treatment plant. The removal was necessary because of the 

increased number of workers on-site during a planned outage. The volume of wastewater 

removed averaged 11,000 L/day (3000 gpd). The work was completed in May 2006, and the 

permit was terminated. 

The 11 HNP storm water outfalls receive precipitation and runoff from the plant area with 

discharge going to either the Harris Reservoir or the auxiliary reservoir. Based on average 

rainfall of 109 cm (43 in.) per year, the discharge through the storm drains is estimated at 

33.3 million liters (8.8 million gallons) per month (Progress Energy 2006b). Water from 

hydrostatic flushing of system piping, equipment and plant wash water, demineralized water, 

potable water, and service water are also discharged from the storm water outfalls. Two of the 

storm water outfalls (SW-003 and SW-006) are sampled as representative of conditions for the 

NPDES permit. No NOVs have been reported for the storm water outfalls. 

Table 2-2. Storm Water Discharge Outfalls 

Outfall Impervious Surface 

Area (acres) 

Total Area Drained 

(acres) 

SW-A 0.27 5.07 

SW-B 1.00 27.94 

SW-001 8.74 66.05 

SW-002 2.06 14.08 

SW-003 6.58 14.74 

SW-004 1.54 33.27 

SW-005 9.77 11.53 

SW-006 7.45 25.84 

SW-007 1.81 45.15 

SW-008 0.48 9.55 

SW-009 1.24 8.72 

Source: Progress Energy 2007c 

2.2.3.2 Groundwater 

During construction of HNP, three landfills were permitted onsite, but only one was used for 

waste disposal. Each of the landfills has been closed with the last being the Industrial Landfill, 

whose closure was effective on May 25, 2005, NC Permit #92-10. Seven monitoring wells were 
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August 2008 2-21 NUREG-1437, Supplement 33 

installed in the vicinity of the industrial landfill in December 1986; two of these were later 

abandoned because they were dry. Initial sampling showed no groundwater contamination. 

The remaining five wells are sampled semiannually for metals and volatile organic compounds 

for a 5-year period ending May 2010. The results are reported to the NCDENR, and no 

evidence of potential contaminants from the landfill has been reported (Progress Energy 

2007b).

HNP also has an Underground Storage Tank (UST) Operating permit for 5 on-site USTs. As 

shown in Table 2-3, contents of the tanks are exclusively petroleum products (Progress Energy 

2007e).
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NUREG-1437, Supplement 33 2-22 August 2008 

Table 2-3. HNP Permitted Underground Storage Tanks 

Tank Number Capacity (gallons) Contents Date Installed 

001 10,000 Diesel/mixture 01/05/1993 

002 10,000 Gasoline/mixture 01/05/1993 

003 1,000 Kerosene/mixture 06/12/1999 

14 175,000 Diesel/mixture 08/05/1984 

15 175,000 Diesel/mixture 08/05/1984 

Source: Progress Energy 2007e 

2.2.4 Air Quality 

HNP is located in the gently rolling central Piedmont region of the state, which rises above the 

Coastal Plain and lies below the mountains to the west. The climate is warm during summer 

when average temperatures tend to be in the 21oC (70oF) range, and cold during winter when 

average temperatures tend to be in the 4.4oC (40oF) range. The warmest month of the year is 

July with an average maximum temperature of 31.6oC (88.9oF), while the coldest month of the 

year is January with an average minimum temperature of –0.33oC (31.4oF). Temperature 

variations between night and day tend to be lower during summer with a difference that can 

reach 10.5oC (19oF), and higher during winter with an average difference of 11.6oC (21oF). 

There are no distinct wet and dry seasons in the area of HNP; average rainfall varies around the 

year. The annual average precipitation is about 111 cm (43.9 in.). The wettest average months 

of the year are July, August, and September with rainfall of about 14.0 cm (5.5 in.) per month. 

The driest average months of the year are October, November, and December with rainfall of 

about 7.4 cm (2.9 in.) per month. Representative weather data was found at the nearby 

Raleigh-Durham Airport weather station (SCONC 2007).

The prevailing winds are generally from the southwest for 10 months of the year, and from the 

northeast during September and October. The average annual wind speed is about 3.3 meter 

per second (7.4 miles per hour), with a maximum annual wind speed of 4.1 meters per second 

(9.2 miles per hour). The highest wind gusts are in the range of 113 kilometers per hour 

(70 miles per hour). Areas suitable for wind turbine applications have a wind power class rating 

of 3 or higher. The wind power class for the HNP site is a relatively low Class 1 (Ramsdell 

2007a; Elliott et al. 1987). 

Tropical hurricanes or cyclones impact the coast of the state approximately one to two times per 

year, most often in the late summer and early fall. Ocean temperatures are warmest during this 

time of the year in the North Atlantic Basin. Since HNP is located well inland, the main impact 

of hurricanes is increased precipitation. Economic losses can also result from hail and wind 

from summer thunderstorms. Such storms tend to impact only limited areas. North Carolina is 

outside the principal tornado area of the United States, but still averages two to three per year. 
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August 2008 2-23 NUREG-1437, Supplement 33 

They occur mostly east of the Appalachian Mountains during early spring. The tornado strike 

probability for HNP is about 6.7 × 10-4 (Ramsdell 2007b). 

Nonradioactive air emissions from the HNP site are regulated by the NCDENR, Division of Air 

Quality. HNP is located in Wake County, North Carolina, which is part of the Eastern Piedmont 

Intrastate Air Quality Control Region (AQCR). The EPA has established National Ambient Air 

Quality Standards (NAAQS) for six common pollutants: nitrogen dioxide, sulfur dioxide, carbon 

monoxide, lead, ozone, and particulate matter with aerodynamic diameters of 10 microns or less 

(PM10). The EPA has designated all areas of the United States as having air quality better 

(“attainment”) or worse (“nonattainment”) than the NAAQS. 

All counties in the Raleigh–Durham–Chapel Hill Metropolitan Statistical Area, including Wake 

County, are in nonattainment with respect to the new 8-hour ozone standard (EPA 2007). Wake

County is in attainment for all other air quality standards, except that it continues to be a 

maintenance area for carbon monoxide (CO) (NCDENR 2007a). 

In 1997, the EPA revised the national standard for ground-level ozone from a 0.12 ppm 1-hour 

“peak” standard to a 0.08 ppm 8-hour “average” standard. This new standard is commonly 

referred to as the 8-hour ozone standard. In April 2004, EPA published the 8-hour ozone nonattainment designations, and announced that the 1-hour “peak” ozone standard will be phased 

out.

The closest designated Class I Federal area is located 160 km from the HNP site. Class 1 

Federal areas include places such as national parks, national wilderness areas, and national 

monuments. These areas are granted special air quality protections under the Clean Air Act 

aimed at protecting visibility. Any modification to a major stationary source occurring within 

100 km of a Class 1 Federal area must comply with established requirements. HNP is not a 

major stationary source. 

Diesel engines, diesel compressors, oil-fired boilers, and other sources associated with the HNP 

site emit various nonradioactive air pollutants to the atmosphere, such as NOx, SO2 and CO. 

Air emissions from these sources are subject to the terms and conditions of a Synthetic Minor 

air permit issued by the North Carolina Environmental Management Commission Department of 

Environment and Natural Resources, Division of Air Quality (Air Permit No. 08455R04). This 

permit is effective from March 21, 2007, until February 29, 2012 (NCDENR 2007b). The permit 

is based on the Synthetic Minor Air Permit Renewal Application submitted by Progress Energy 

on December 20, 2006 (Progress Energy 2006c). In general terms, a Synthetic Minor air permit 

is used for sources that have the potential to emit pollutants in excess of “Major Source” 

thresholds, but have permit conditions restricting emissions to “Minor Source” levels. The HNP 

plant must comply with the associated conditions of the permit, including emissions controls, 

emissions reporting and notifications requirements. Compliance with the air permit conditions 

has been excellent, with no reported violations related to air emissions (Lane 2007a). Permitted 

equipment with nonradioactive air emissions at the facility includes: 
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NUREG-1437, Supplement 33 2-24 August 2008 

Compressor 1 – Fuel oil fired emergency compressor (475 horsepower) 

Compressor 2 – Fuel oil fired emergency compressor (475 horsepower) 

Compressor 3 – Fuel oil fired emergency compressor (475 horsepower) 

Compressor 4 – Fuel oil fired emergency compressor (475 horsepower) 

Generator A – Fuel oil-fired emergency generator (9074 horsepower) 

Generator B – Fuel oil-fired emergency generator (9074 horsepower) 

Generator C – Fuel oil-fired emergency generator (650 kilowatt) 

Boiler B – Fuel oil-fired boiler (87.4 million Btu per hour) 

Temporary Boiler – Fuel oil-fired boiler (86 million Btu per hour) 

Temporary Firewater Pump – Fuel oil-fired firewater pump (600 horsepower) 

Temporary Generator – Fuel oil-fired emergency generator (1300 kilowatt) 

Some of the permitted sources are procured on a rental contract basis, and are not always 

physically on site, specifically, the compressors, temporary boiler, and temporary generator. 

In calendar year 2005, the total annual NOx emission was 11.03 metric tons (12.16 tons) and 

the total annual CO emission was 2.88 metric tons (3.17 tons), while all other emission 

constituents were less than one metric ton (ton) (Lane 2007b). There are no significant 

changes proposed for nonradioactive air emissions from HNP, and there are no significant 

changes proposed to the limits and conditions of the Air Permit. 

2.2.5 Aquatic Resources 

HNP is located on a peninsula stretching from the northwest into the Harris Reservoir, with the 

Tom Jack Creek arm of the reservoir located on the western side and the Thomas Creek arm 

located on the eastern side. In late 1980, CP&L created the reservoir by impounding Buckhorn 

Creek, a tributary of the Cape Fear River, within the Cape Fear River Basin. Eight tributaries 

(Tom Jack Creek, Thomas Creek, Little White Oak Creek, White Oak Creek, Utley Creek, Cary 

Branch, Jim Branch, and Buckhorn Creek) feed into the Harris Reservoir. The reservoir 

supplies makeup water for HNP’s cooling tower. CP&L created an auxiliary reservoir, by 

impounding a 130 ha (321 ac) portion of the Tom Jack Creek arm of the Harris Reservoir 

(Figure 2-3) to serve as the ultimate heat sink for the plant. 
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August 2008 2-25 NUREG-1437, Supplement 33 

All seven transmission lines associated with HNP cross streams. The 50-km (31-mi) long Siler 

City transmission line crosses about 20 streams, including Deep River and the Cape Fear River. 

The 12-km (7.4-mi) long Cape Fear North transmission line crosses about 6 streams. The 

10-km (6.5-mi) long Cape Fear South transmission line has only 1 stream crossing. The 58-km 

(36-mi) long Fort Bragg–Woodruff Street transmission line crosses about 25 streams, including 

the Cape Fear River. These four transmission lines also cross the Tom Jack Creek arm of the 

reservoir and a finger of the Thomas Creek arm. The 6-km (4-mi) long Apex–U.S. 1 

transmission line crosses about 8 streams and also crosses the Thomas Creek arm of the 

reservoir. The 48-km (30-mi) long Erwin transmission line crosses about 25 streams. It also 

crosses the White Oak Creek arm, the Little White Oak Creek arm, and the Thomas Creek arm 

of the reservoir. The 61-km (38-mi) long Wake transmission line crosses about 24 streams, 

including Little Oak Creek. It also crosses the Thomas Creek arm of the reservoir. 

2.2.5.1 Water Body Characteristics 

Reservoir level is controlled by a spillway in the Harris Dam, keeping the elevation at or below 

67 m (220 ft). The dam regulates the streamflow of Buckhorn Creek, which continues 

downstream of the dam until it joins the Cape Fear River. From 1981 to 2003, the annual mean 

streamflow of Buckhorn Creek, measured 1.6 km (1 mi) downstream of the dam, ranged from 

0.07 to 9 m3/sec (2.47 to 137 cubic feet per second [cfs]). The spillway is not controlled by 

CP&L, but water spills over naturally due to rainfall for an estimated 6 months out of the year, 

with an annual average rate of 0.3 m3/sec (10 cfs) (4500 gpm or less than 2.5 million gallons 

per year). The surface area of the reservoir is 1680 ha (4151 ac), with a maximum depth of 

17 m (56 ft), a mean depth of 6.1 m (20 ft), a volume of 82,000 ac-ft (2.7 x 1010 gal), and an 

average residence time of 28 months (NCDENR 2004). Under normal operations, only one of 

the two makeup pumps takes up water, at a rate of 26,000 gpm. In addition to the receiving 

discharge from HNP, the reservoir receives discharges from the Harris Energy and 

Environmental Center and a wastewater treatment plant in Holly Springs via Utley Creek (a 

tributary of White Oak Creek). 

The shoreline and immediate watershed are wooded, and the drainage area consists of rolling 

hills used for silviculture and agriculture. The bottom of Harris Reservoir is mostly clay, with 

organic materials and some sand. 

Harris Reservoir waters tend to be stratified in summer months and mixed in winter months 

(Progress Energy 2001, 2003b). From data collected in 1992 and 2000, water temperatures 

near the surface of the reservoir range from 7°C (50°F) in the winter to 32°C (90°F) in the 

summer (CP&L 1994; Progress Energy 2001). Based on calculated North Carolina Trophic 

State Index, Harris Reservoir is classified as eutrophic (NCDENR 2004). Although 

concentrations of phosphorous and nitrogen rose rapidly in the late 1980s and early 1990s, 

monitoring by CP&L in recent years has shown that nutrient levels are now stable, and are 

typical of a productive, southeastern reservoir. Subsurface waters are seasonally oxygendeficient. Other water quality parameters, such as total dissolved solids, turbidity, total organic 
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NUREG-1437, Supplement 33 2-26 August 2008 

carbon, ions, total alkalinity, hardness, and copper, exhibit no significant spatial trends, and 

none are at harmful levels for the local aquatic environment (Progress Energy 2003b). Mean 

chlorophyll a concentrations, which are indicators of algal blooms, reflect moderate to high 

productivity. In 1997 and 1998, concentrations of chlorophyll a exceeded the 40 microgram per 

liter (μg/L) North Carolina water quality standard, but as of 2002, this has not recurred (Progress 

Energy 2001, 2003b). 

The dominant species of aquatic plants are hydrilla (Hydrilla verticillata) and creeping water 

primrose (Ludwigia grandiflora), both invasive species. In 1994, 1996, and 1997, CP&L stocked 

the auxiliary reservoir with grass carp (Ctenopharyngodon idella) to control for hydrilla, and 

according to the 2002 Environmental Monitoring Report (Progress Energy 2003b), no hydrilla 

has been observed in the auxiliary reservoir. While these invasive species of aquatic vegetation 

can be a nuisance for power plants, anglers perceive the plants as desirable fish habitat (Jones 

et al. 2000; Kibler 2007). In 2002, water hyacinth (Eichhornia crassipes) and water lettuce 

(Pistia stratiotes) were both observed in the Harris Reservoir. CP&L removed both species, and 

neither invasive plant has been observed since then (Progress Energy 2003b). 

On the shorelines of both the main and auxiliary reservoir, vegetation includes common cattail 

(Typha latifolia), common rush (Juncus effusus) and woolgrass (Scirpus cyperinus). Water 

shield (Brasenia schreberi) and fragrant water lily (Nymphaea odorata) grow throughout the 

reservoir’s littoral zone. Brittle naiad (Najas minor) has been found in the auxiliary reservoir. In 

the White Oak Creek arm of Harris Reservoir, American lotus (Nelumbo lutea) grows (CP&L 

1994).

Asiatic clam (Corbicula fluminea), an invasive freshwater mollusk, has been present in Harris 

Reservoir for over a decade and continues to spread, based on qualitative observations made 

by CP&L (CP&L 1994). As of 2002, the zebra mussel (Dreissena polymorpha), another 

invasive freshwater mollusk, has not been found in Harris Reservoir (Progress Energy 2003b). 

Harris Reservoir is dominated by bluegill (Lepomis macrochirus), redear sunfish (L.

microlophus), and largemouth bass (Micropterus salmoides). Together with black crappie 

(Pomoxis nigromaculatus), these four members of the centrarchid family accounted for 

80 percent of the mean number of fish per hour collected in Harris Reservoir in 2002 by 

electrofishing sampling (Progress Energy 2003b), when the mean number of total fish per hour 

collected was 322, which exceeded the reservoir averages from the previous 12 years. By 

weight, the dominant species are bluegill, redear sunfish, largemouth bass, and gizzard shad 

(Dorosoma cepedianum) (Progress Energy 2001, 2003b). 

Other common fish species in the Harris Reservoir include bluespotted sunfish (Enneacanthus 

gloriosus), bowfin (Amia calva), brown bullhead (Ameiurus nebulosus), chain pickerel (Esox

niger), channel catfish (Ictalurus punctatus), coastal shiner (Notropis petersoni), flat bullhead 

(Ameiurus platycephalus), golden shiner (Notemigonus crysoleucas), pumpkinseed (Lepomis

gibbosus), redbreast sunfish (L. auritus), threadfin shad (D. petenense), warmouth (L. gulosus),
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August 2008 2-27 NUREG-1437, Supplement 33 

white catfish (Ameiurus catus), white crappie (Pomoxis annularis), and white perch (Morone

americana) (Progress Energy 2003b). 

Several species were introduced to the reservoir. The non-native grass carp is an herbivore 

that was introduced to the auxiliary reservoir to control the spread of nuisance vegetation. 

Common carp (Cyprinus carpio), native to Asia, was collected for the first time in 2000 in the 

reservoir, although it had been previously known to exist in the Cape Fear River before the 

impoundment of the reservoir (Progress Energy 2003b). Threadfin shad were stocked in the 

Harris Reservoir once in 1987 by the North Carolina Wildlife Resources Commission to provide 

prey for largemouth bass (Progress Energy 2006b). Channel catfish were stocked in the 

reservoir in 1985, but as of 1997, a reproducing channel catfish population has not been 

established (Jones et al. 2000). 

Harris Reservoir has become popular in recent years for largemouth bass fishing. Based on a 

creel survey conducted July 1997 through June 1998 (Jones et al. 2000), the estimated fishing 

effort during that time was 188,948 hours, or 118 hours/hectare (48 hours/ac). Sixty-seven 

percent of the effort was directed at largemouth bass, with crappie fishing only 17 percent of 

effort (Jones et al. 2000). In response to the fishing pressure on Harris bass, in 2002 the North 

Carolina Wildlife Resources Commission imposed a daily limit for largemouth bass of five in 

aggregate, of which only two may be less than 14 in. and none may be between 16 and 20 in. 

(NCWRC 2007). 

American beavers (Castor canadensis) build lodges on Harris Reservoir, but their presence has 

not created a problem for the operation for the plant. 

2.2.5.2 Threatened or Endangered Aquatic Species 

Aquatic species that are listed as threatened or endangered by the U.S. Fish and Wildlife 

Service (FWS) or the State of North Carolina and have the potential to occur in Wake or 

Chatham counties or in counties crossed by HNP-associated transmission lines are presented 

in Table 2-4. 

Within Wake and Chatham counties and the counties (Cumberland, Harnett, Lee, and 

Randolph) crossed by HNP-associated transmission lines, two aquatic species are Federally 

listed as endangered: the Cape Fear shiner (Notropis mekistocholas) and the dwarf 

wedgemussel (Alasmidonta heterodon) (NCNHP 2007). 

The Cape Fear shiner is a small minnow, approximately 5 cm (2 in.) long. Associated with 

gravel, cobble, and boulder substrates, the Cape Fear shiner is endemic to the upper Cape 

Fear River Basin in the Central Piedmont of North Carolina and has been found in the tributaries 

and mainstreams of the Deep, Haw, and Rocky rivers. Of the five populations remaining, two 

are very small and unstable. The other three populations are estimated to have a total effective 

population size (defined by the number of available breeding individuals) between 1500 and 

3000 individuals. Three critical habitats were designated under the Endangered Species Act of 
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NUREG-1437, Supplement 33 2-28 August 2008 

1973, as amended (ESA): in Chatham County, 6.6 km (4.1 mi) of the Rocky River; in Chatham 

and Lee counties, 0.8 km (0.5 mi) of Bear Creek, 6.8 km (4.2 mi) of Rocky River, and 4 km 

(2.6 mi) of Deep River; and in Randolph and Moore Counties, 2.4 km (1.5 mi) of Fork Creek and 

6.6 km (4.1 mi) of Deep River (FWS 2007c). In 1972 CP&L reported the species as rare in 

Buckhorn Creek and not present in the other creeks (AEC 1974). One specimen was collected 

in the Cape Fear River, downstream of the reservoir during pre-operational surveys in 1972 

through 1980 (NRC 1983). In 1998, CP&L conducted a self-assessment of HNP for threatened 

and endangered species, and reported that the nearest recorded Cape Fear shiner was from 

Parkers Creek, a tributary of Jordan Lake (CP&L 1998). There are no details for when this 

specimen was found. The Cape Fear shiner is not currently known to inhabit Buckhorn Creek 

or Harris Reservoir, and these waters have not been designated as one of the three critical 

habitat areas. 

Found in large rivers and small streams, including certain creeks within the Neuse River and Tar 

River basins, the dwarf wedgemussel is small, with a shell that rarely exceeds 45 mm (1.8 in.) in 

length. The dwarf wedgemussel has not been found in the Cape Fear River Basin (NCWRC 

2007b). Individuals often burrow into clay banks near root systems of trees, in mixed substrates 

of cobble, gravel, and sand, or occasionally in soft silt. Like all freshwater mussels, this species 

uses fish hosts, including the tessellated darter (Etheostoma olmstedi), Johnny darter (E.

nigrum), and mottled sculpin (Cottus bairdi), as part of their maturation process (FWS 2007a). 

There are no known populations of these fish species in the Harris Reservoir (Progress Energy 

2001, 2003b). 

The Sandhills chub (Semotilus lumbee), a Federal and State species of special concern, is 

known to occur in a stream that crosses the Harris-Fayetteville transmission line ROW 

(Progress Energy 2006b). No other aquatic threatened or endangered species or species of 

special concern are known to occur at HNP or in its transmission line ROWs. 

Table 2-4. Federally and State-Listed Aquatic Species Potentially Occurring in Wake or 

Chatham Counties or in Counties Crossed by Associated Transmission Line ROWs 

Scientific Name Common Name 

Federal

Status(a)

State

Status(a)

Fish 

Ambloplites cavifrons Roanoke bass SC SR

Cyprinella zanema pop 2 Santee chub - Coastal Plain population — SC 

Etheostoma collis pop 2 Carolina darter - eastern Piedmont population SC SC 

Lampetra aepyptera least brook lamprey — T 

Lythrurus matutinus Pinewoods shiner SC SR 

Moxostoma sp 3(b) Carolina redhorse SC SR (PE) 
Plant and the Environment 

August 2008 2-29 NUREG-1437, Supplement 33 

Scientific Name Common Name 

Federal

Status(a)

State

Status(a)

Notropis mekistocholas Cape Fear shiner E E 

Noturus furiosus Carolina madtom SC SC (PT) 

Noturus sp 2(b) broadtail madtom — SC 

Semotilus lumbee Sandhills chub SC SC 

Mollusks 

Alasmidonta heterodon dwarf wedgemussel E E 

Alasmidonta undulata triangle floater — T 

Alasmidonta varicosa brook floater SC E 

Elliptio folliculata pod lance — SC 

Elliptio lanceolata yellow lance SC E 

Elliptio marsupiobesa Cape Fear spike — SC 

Elliptio roanokensis Roanoke slabshell — T 

Fusconaia masoni Atlantic pigtoe SC E 

Lampsilis cariosa yellow lampmussel SC E 

Lampsilis radiata conspicua Carolina fatmucket — T 

Lampsilis radiata radiata eastern lampmussel — T 

Lasmigona subviridis green floater SC E 

Strophitus undulatus creeper — T 

Toxolasma pullus Savannah lilliput SC E 

Villosa constricta notched rainbow — SC 

Villosa delumbis eastern creekshell — SR 

Villosa vaughaniana Carolina creekshell SC E 

Crustaceans 

Cambarus catagius Greensboro burrowing crayfish — SC 

Cambarus davidi Carolina ladle crayfish — SR 

Orconectes carolinensis North Carolina spiny crayfish — SC 

Sources: NCNHP 2007. 

(a) E = Endangered, T = Threatened, — = not listed, SC = Special Concern, SR = Significantly Rare, 

P = Proposed 

(b) sp 2 and sp 3 denote that species are currently undescribed. 
Plant and the Environment 

NUREG-1437, Supplement 33 2-30 August 2008 

2.2.6 Terrestrial Resources 

2.2.6.1 Terrestrial Resources at the Shearon Harris Site 

The HNP site and associated transmission lines span across Wake, Chatham, and Harnett 

counties, which are primarily in the Piedmont Province and coastal plain (NCNHP 2003). The 

overall terrain is gently rolling with some steep areas along the creeks and rivers where banks 

can rise over 30 m (100 ft) above the stream channel (NCNHP 2003). The HNP site has a total 

area of approximately 4370 ha (10,800 ac). The reservoir, formed from a dam on Buckhorn 

Creek, covers approximately 1680 ha (4150 ac) of the total HNP site. Of the remaining 

acreage, 180 ha (440 ac) is used for industrial purposes, 283 ha (700 ac) is leased to Wake 

County for a county park and a fire-and-rescue training facility, and 2000 to 2500 ha (5000 to 

6000 ac) are forested land (Progress Energy 2006b). 

CP&L has enrolled 5700 ha (14,090 ac) of land around the Harris Reservoir, known collectively 

as the Shearon Harris Game Lands, in the North Carolina Game Lands Program. The Game 

Lands are separate from the HNP site, but still owned and operated by CP&L (Progress Energy 

2006b). Transmission line ROWs cross the Game Lands in four locations. The Shearon Harris 

Game Lands are used for recreation, education, development, associated transmission lines, 

and hunting (Progress Energy 2006b). The North Carolina Wildlife Resources Commission 

issues hunting permits for bear, deer, wild boar, wild turkeys, small game, and waterfowl. 

Pre-settlement vegetation at the HNP site consisted of forested land with isolated marshes and 

wetlands; however, as Wake County has become more populated in the past 20 years, forested 

areas and agricultural lands have developed into commercial and residential areas. This 

change has occurred primarily within the last decade, as the commercial development has been 

fueled by the growing concentration of biotechnology, biomedical, and computer and software 

companies in Wake County. Presently only 17 percent of the land in Wake County is used for 

agricultural production (NCNHP 2003). 

Eighty-five percent of Wake County lies within the Neuse River Basin, and the remaining 

southwest corner of the county, including the HNP site, lies within the Cape Fear River Basin 

(NCNHP 2003). The majority of waterways that enter the county flow southeast towards the 

Atlantic Ocean. No natural lakes occur in the county, but several large reservoirs exist, most 

notably Harris Reservoir (NCNHP 2003). Other smaller, artificially created lakes and ponds 

exist throughout the county. The Buckhorn Creek, Tom Jack Creek, Thomas Creek, Little White 

Oak Creek, White Oak Creek, Utley Creek, Cary Branch, and Jim Branch watersheds are all 

within the Cape Fear River Basin. Terrestrial vertebrates, including birds (both migratory and 

non-migratory species), mammals, reptiles, and amphibians, all inhabit the Cape Fear River 

watershed.

Vegetative plant communities at the HNP site consist of upland forest, lowland forest, and 

wetlands. The upland forest areas can be subdivided into pine forest, hardwood forest, and 
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August 2008 2-31 NUREG-1437, Supplement 33 

pine-hardwood mixtures (Progress Energy 2006b). Most of the upland forest is managed for 

timber production. The lowland forests on the HNP site are generally closer to water and are 

composed of a mixture of maples (Acer spp.), birches (Betula spp.), elms (Ulmus spp.), and 

shrubs. The open marsh areas are primarily composed of grasses and aquatic vegetation and 

are without woody vegetation. 

The upland pine forests at the HNP site primarily consist of loblolly pine (Pinus taeda), shortleaf 

pine (P. echinata), Virginia pine (P. virginiana), and longleaf pine (P. palustris). The upland 

hardwood forests at the HNP site primarily consist of oaks (Quercus spp.), hickories (Carya

spp.), and some maples. Virginia spiderwort (Tradescantia virginiana), which is rare in Wake 

County, can be found on the sloping areas of the upland hardwood forest (Progress Energy 

2006b). Pine-hardwood mixture forests contain species characteristic of both the upland 

hardwood and upland pine forests. 

Plant species found in the lowland forest at the HNP site include sweet gum (Liquidambar 

styraciflua), red maple (A. rubrum), American sycamore (Platanus occidentalis), American elm 

(U. americana), and river birch (Betula nigra) (Progress Energy 2006b). Vegetation 

characteristic of the wetland areas include cattail (Typha spp.), cordgrass (Spartina spp.), 

rushes (Juncus spp.), and rice cutgrass (Leersia oryzoides). The FWS National Wetlands 

Inventory database indicates that wetlands, some of which are classified as significant habitats, 

exist on and in the vicinity of the HNP site along many of the waterways feeding into Harris 

Reservoir and along the banks of the Harris Reservoir. Several of the transmission line ROWs 

cross wetland habitats. 

CP&L has not found that invasive terrestrial species interfere with plant operation thus far; 

however, several invasive plant species exist that are potentially within the vicinity of the HNP 

site. These include garlic mustard (Alliaria petiolata), tree-of-heaven (Ailanthus altissima), and 

bull thistle (Cirsium vulgare), all of which have the ability to displace native species and reduce 

species diversity (NCNPS 2006). During a site audit NRC staff conducted in June 2007, the 

NRC staff observed a population of Japanese beetles (Popillia japonica), which is invasive to 

most areas of the eastern United States. CP&L is not required to keep and does not keep 

records of known invasive species and does not have any programs or procedures in place to 

control terrestrial plant or animal invasive populations on the HNP site. 

Two of the three significant natural heritage areas (SNHA), which are managed by the North 

Carolina Natural Heritage Program (NCNHP), are located on the HNP site. The first SNHA is a 

field located within the Harris Research Tract, which is historically a nesting site for the 

Federally endangered red-cockaded woodpecker (Picoides borealis). The nesting site was 

confirmed to be abandoned in 1987 (Progress Energy 2006b). The second SNHA is a great 

blue heron (Ardea herodias) rookery, located on the southern end of the Harris Reservoir along 

Jim Branch. The NCDENR reported that 32 nests were counted on a site visit in 2002, which 

makes the rookery one of the largest known colonies of great blue herons in the eastern 

Piedmont region (NCDENR 2006). 
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NUREG-1437, Supplement 33 2-32 August 2008 

The Shearon Harris Longleaf Pine Forest, a remnant of the natural Piedmont longleaf pine 

savannah community, is the third SNHA and is located northeast of Harris Reservoir within the 

HNP site (NCDENR 2006; NCNHP 2003). The longleaf pine savannah is characterized by 

longleaf pines, which form an open canopy, and shrubs and herbs, which create a dense 

ground cover. North Carolina State University (NC State) manages the Shearon Harris 

Longleaf Pine Forest as part of the Harris Research Tract, which is discussed below. NC State 

is managing the Shearon Harris Longleaf Pine Forest in order to facilitate the continued survival 

of the longleaf pine savannah community, which has become a rare habitat in the State of North 

Carolina (Progress Energy 2006b). 

The Harris Research Tract encompasses a 513 ha (1267 ac) plot of land, which CP&L leases to 

the NC State Department of Forestry for research purposes (Progress Energy 2006b). NC 

State uses the land to research forestry management practices, such as prescribed burns and 

selective cutting, on a long-term basis. NC State also focuses on regional pine species, 

especially the longleaf pine discussed above, and threatened and endangered plant species 

(Progress Energy 2006b). 

Timber harvesting occurs at the HNP site in the upland forests. Best management practices 

(BMPs) are implemented by CP&L using the guidance of the NCDENR and the North Carolina 

Division of Forest Resources. BMPs include guidelines for responsible management of forested 

areas, riparian zones, buffer strips, and wetlands, as well as overall management of water 

bodies such as Harris Reservoir (Progress Energy 2006b). 

CP&L maintains the following public access areas at the HNP site: an environmental center and 

associated hiking trails, and a portion of the Harris Research Tract. Additionally, the following 

limited public access areas are maintained on the HNP site: a fire-and-rescue training facility, 

hunting areas, boat ramps on the Harris Reservoir, and limited access parks (Progress Energy 

2006b).

Wake County and the State of North Carolina maintain and operate several parks and open 

spaces for recreation in the vicinity of the HNP site. Harris Lake County Park, a 260 ha (640 ac) 

park located on the Harris Reservoir and adjacent to the HNP site is leased to Wake County by 

CP&L (Progress Energy 2006b). Harris Lake County Park contains managed longleaf pine 

habitat. Located about 16 km (10 mi) from the HNP site, Jordan Lake State Recreation Area in 

Apex, North Carolina, is a large summertime habitat for the bald eagle (Haliaeetus

leucocephalus), and has a public observation deck for bird watching (NCDPR 2006). The 

Jordon Lake State Recreation Area is leased to the State of North Carolina by the U.S. Federal 

Government. 

CP&L maintains wildlife management plans for the HNP site, which include checklists for 

qualified biologists to complete in order to ensure that all appropriate procedures and BMPs are 

followed where applicable to minimize the effects of plant operation on wildlife. A variety of 

wildlife species are found at the HNP site and in the surrounding area. Forested areas support 
Plant and the Environment 

August 2008 2-33 NUREG-1437, Supplement 33 

many species of birds, snakes, frogs, lizards, toads, as well as whitetail deer (Odocoileus

virginianus), Virginia opossums (Didelphis virginiana), northern raccoons (Procyon lotor),

eastern gray squirrels (Sciurus carolinensis), eastern cottontails (Sylvilagus floridanus), striped 

skunks (Mephitis mephitis), bobcats (Lynx rufus), and American black bears (Ursus

americanus). Additionally, migratory songbirds and waterfowl commonly pass through the HNP 

site, which is part of the Atlantic flyway. Harris Reservoir supports species such as the great 

blue heron, great white egret (Ardea alba), osprey (Pandion haliaetus), and double-crested 

cormorant (Phalacrocorax auritus), as well as numerous goose and duck species. Wood duck 

(Aix sponsa) boxes are maintained throughout the Harris Reservoir to promote nesting of this 

species. 

2.2.6.2 Threatened and Endangered Terrestrial Species 

Two Federally listed threatened or endangered terrestrial species: the red-cockaded 

woodpecker (Picoides borealis) and Michaux’s sumac (Rhus michauxii) have been found in the 

vicinity of HNP. Four State-listed threatened or endangered species have been confirmed in the 

vicinity of HNP: the Carolina grass-of-Parnassus (Parnassia caroliniana), the eastern tiger 

salamander (Ambystoma tigrinum), the bald eagle (Haliaeetus leucocephalus), and the fourtoed salamander (Hemidactylium scutatum) (Progress Energy 2006b). Protected and rare 

terrestrial species known to occur in Wake or Chatham counties or in counties crossed by HNPassociated transmission lines ROWs can be found in Table 2-5. 

Federally Protected Species 

On July 9, 2007, the FWS issued a Federal Register notice announcing the removal of the bald 

eagle species from the Federal List of Endangered and Threatened Wildlife (72FR37346). Bald 

eagles, formerly listed as threatened, are sighted occasionally at the Harris Reservoir (Progress 

Energy 2006b). However, the bald eagle remains threatened at the state level. The bald eagle 

is a large bird, even among raptor species, and can reach a weight of more than 6 kg (13 lb). 

Bald eagle adults have a white head and tail and brown body feathers, while juveniles are 

entirely brown and remain so until 5 to 6 years of age. Bald eagle habitat consists of forested 

areas throughout North America. The species feeds primarily on fish, as well as other small 

animals and occasionally carrion (NCWRC 2005). In the 2004–2005 nesting season, one active 

bald eagle nest was discovered near the Harris Reservoir (Progress Energy 2006b). 

Potential habitat for the endangered red-cockaded woodpecker, a small and slender 

woodpecker species, is located within the HNP site (FWS 2007d). The red-cockaded 

woodpecker prefers to nest in mature pine forests, especially areas containing longleaf pines 

and loblolly pines, which are abundant on the HNP site (U.S. Audubon Society 2002; Progress 

Energy 2006b). The bird’s diet is composed mainly of insects, which include ants, beetles, 

wood-boring insects, caterpillars, and worms. The red-cockaded woodpecker may also 

supplement 15 to 20 percent of its overall diet with seasonal wild fruit. Egg laying occurs 

between April and June (FWS 2007d). The bird’s range is closely tied to the distribution of 

southern pines. The species is known to currently inhabit 11 states, of which the most abundant 
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NUREG-1437, Supplement 33 2-34 August 2008 

populations occur in North Carolina and South Carolina (U.S. Audubon Society 2002; FWS 

2007d). A red-cockaded woodpecker nest with known activity was located in the proximity of 

the HNP site during the 1980s; however, the nest was confirmed to be abandoned in 1987. No 

activity has since been observed, and the pair is believed to have vacated the site (Progress 

Energy 2006b). 

Michaux’s sumac, listed as endangered, is found within the land set aside for research at NC 

State. The entire population of Michaux’s sumac occurring on the HNP site is designed for 

research as an experimental population, which was originally transplanted in 2001 by NC State 

(Progress Energy 2006b). Michaux's sumac, a plant in the cashew family, is a rhizomatous, 

densely hairy shrub, with erect stems 0.3 to 0.9 m (1 to 3 ft) in height. The compound leaves 

contain evenly serrated, oblong to lanceolate, acuminate leaflets. The flowers are small, borne 

in a terminal, erect, dense cluster, and colored greenish yellow to white with flowering usually 

occurring from June to July. The fruit, a red drupe, is produced through the months of August to 

October. The species inhabits sunny areas, and is generally not considered shade-tolerant 

(FWS 2007b). Michaux’s sumac occurs in the southeastern United States, with habitat 

spanning from North Carolina southward to Georgia. 

State-Protected Species 

The endangered Carolina grass-of-Parnassus occurs in wet savannahs in the Harris–

Fayetteville transmission line ROW (Progress Energy 2006b). The species inhabits the Coastal 

Plain and Sandhills of the southeastern U.S. and grows in fire-maintained, wet savannahs as 

well as ecotonal areas between pine uplands and seepage slopes or streamhead pocosins. 

The Carolina grass-of-Parnassus has basal leaves that are rounded with long leafstalks as well 

as a single, stalkless rounded leaf on the flower stalk. Timber production and changes in 

hydrology have diminished the range of the plant and continue to pose a significant threat to its 

habitat (CPC 2007). 

The threatened eastern tiger salamander occurs near the Harris–Wake transmission line ROW 

(Progress Energy 2006b). The salamander has an average length of 18 to 20 cm (7 to 8 in.), a 

stocky body, strong limbs, and a long tail. The salamander is dark brown, with yellow and olive 

irregular blotches marking the body. The eastern tiger salamander lives most of its life 

underground, requiring contaminent-free soils as its habitat. The species’ range is along the 

east coast from Florida to New York, but also occurs in parts of the Midwest (NYDEC 2007). 

The salamander feeds on insects, worms, minnows, and occasionally other small amphibians 

(CRACM 2007a). 

The four-toed salamander (Hemidactylium scutatum), a State-listed species of special concern, 

has recorded breeding areas in vernal pools outside of the property boundaries of CP&L 

(Progress Energy 2006b). Four-toed salamanders are easily identified by three distinctive 

characteristics: four toes on the hind feet, a distinct basal constriction on the tail, and a bright 

white underbelly with black speckles. Four-toed salamanders most commonly inhabit wet moss. 
Plant and the Environment 

August 2008 2-35 NUREG-1437, Supplement 33 

The species subsists primarily on ticks, beetles, ants, snails, midges, and fly larvae (CRACM 

2007b).

Table 2-5. Federally and State-Listed Terrestrial Species Potentially Occurring in Wake or 

Chatham Counties or in Counties Crossed by Associated Transmission Line ROWs 

Scientific Name Common Name 

Federal

Status(a)

State

Status(a) Habitat 

Reptiles and Amphibians

Alligator 

mississippiensis 

American alligator(b) T T Swampy areas, rivers, lakes, streams, 

and ponds 

Ambystoma tigrinum eastern tiger 

salamander 

— T Sandy, gravelly, or barren forested 

areas with pools for breeding 

Crotalus adamanteus eastern diamondback 

rattlesnake 

— E Pine flatwoods, abandoned farmland, 

or sandy woodlands 

Crotalus horridus timber rattlesnake — SC Deciduous forests with rugged terrain 

Heterodon simus southern hognose 

snake

SC SC Upland forests with sandy soils 

Hemidactylium 

scutatum 

four-toed salamander — SC Swamps; boggy streams; near ponds 

or mossy pools 

Necturus lewisi Neuse River waterdog — SC Wide, fast-flowing streams with high 

oxygen and hard substrate 

Pituophis 

melanoleucus 

northern pine snake — SC Sandhills and pine flatwoods 

Rana heckscheri river frog — SC Forest streams 

Sistrurus miliarius pigmy rattlesnake — SC Sandhills with oak and pine flatwoods 

Micrurus fulvius eastern coral snake — E Well drained pine woods near ponds or 

streams

Birds

Aimophila aestivalis Bachman’s sparrow SC SC Scattered, shrubby vegetation with 

dense herbaceous understudy 

Egretta caerulea little blue heron — SC Freshwater ponds, lakes, rivers, 

streams, swamps, marshes and 

lagoons 

Haliaeetus 

leucocephalus 

bald eagle — T Large open bodies of water with 

adjacent riparian areas 

Lanius ludovicianus loggerhead shrike — SC Forest habitat with preference for tree 

species with thorns 
Plant and the Environment 

NUREG-1437, Supplement 33 2-36 August 2008 

Scientific Name Common Name 

Federal

Status(a)

State

Status(a) Habitat 

Picoides borealis red-cockaded 

woodpecker 

E E Mature pine forests with preference of 

loblolly and longleaf pines 

Mammals

Condylura cristata 

pop. 1

star-nosed mole, 

coastal plain population 

— SC Forests, clearings, marshes, wet 

meadows, and peat bogs with nearby 

stream banks and moist soils 

Myotis austroriparius southeastern myotis — SC Forest habitats with caves or tree 

hollows and nearby waterways 

Plants

Amorpha georgiana 

georgiana 

Georgia indigo-bush — E Brushy and weedy habitats along the 

edges of farmland, forests, roads, and 

transmission line ROWs 

Astragalus michauxii Sandhills milkvetch — T Herb-dominated sandhills 

Carex barrattii Barratt’s sedge — E Wetlands and occasional stream banks 

Carex exilis coastal sedge — T Marshes and other wetlands 

Chrysoma 

pauciflosculosa 

woody goldenrod — E Dunes, salt flats, and sandy woodlands 

Eupatorium resinosum pine barren boneset — T, SC Sandhills and coastal plains 

Helenium brevifolium littleleaf sneezeweed — E Sandhills and coastal plains 

Helianthus schweinitzii Schweinitz’s sunflower E E Roadsides, pastures, ROWs, forest 

clearings, and other open sunny areas 

Isoetes piedmontana Piedmont quillwort — T Rough, hilly terrain and rolling hills 

Lilium pyrophilum Sandhills lily — E, SC Sandy ridges in pine forest 

understories and clearings 

Lindera melissifolia pondberry E E Poorly drained, swampy depressions 

and sand dunes 

Lindera subcoriacea bog spicebush SC T Forest understories and forest 

clearings 

Lobelia boykinii Boykin’s lobelia — T Swamps and cypress ponds 

Lysimachia 

asperulifolia 

rough-leaved loosestrife E E Ecotones between pine uplands 

Macbridea caroliniana Carolina bogmint — T Forested flatlands with poor drainage 

Muhlenbergia 

torreyana

pinebarren smokegrass — E Ecotones between pine uplands 
Plant and the Environment 

August 2008 2-37 NUREG-1437, Supplement 33 

Scientific Name Common Name 

Federal

Status(a)

State

Status(a) Habitat 

Myriophyllum laxum loose watermilfoil — T Streams, rivers, pond, bogs, and 

swamps 

Parnassia caroliniana Carolina grass-ofParnassus — E Bogs, swamps, moist woods, and other 

wet areas 

Portulaca smallii Small’s portulaca — T Forest edges 

Pteroglossaspis 

ecristata

spiked medusa — E Open areas with sandy soil 

Ptilimnium nodosum harperella E E Rocky or gravelly shoals of stream 

bottoms or pond edges 

Pyxidanthera barbulata 

var. brevifolia 

Sandhills pixie-moss — E Pine forests and sandhills 

Rhexia aristosa awned meadow-beauty — T Wet, sandy soils with fluctuating water 

levels and occasional inundation 

Rhus michauxii Michaux’s sumac E E, SC Sandy or rocky open woods 

Rhynchospora macra southern white 

beaksedge 

— E Marshes, swamps, and bogs 

Rudbeckia heliopsidis sun-facing coneflower — E Grasslands around forest edges 

Ruellia humilis low wild petunia — T Grasslands around forest edges 

Schwalbea americana American chaffseed E E Sandy soils in flatwoods, savannahs, 

forest edges, and other open areas 

Solidago verna spring flowering 

goldenrod 

— T Wetlands and stream banks 

Stylisma pickeringii 

var. pickeringii 

Pickering’s dawnflower — E Dry, barren, sandy areas 

Symphyotrichum 

georgianum 

Georgia aster C T Dry, high light areas, in savannah or 

prairies 

Trillium pusillum Virginia least trillium SC E Forested, freshwater, and riparian 

areas

Utricularia olivacea dwarf bladderwort — T Forested wetlands with poorly drained 

soils

Sources: NCNHP 2007; Progress Energy 2006b 

(a) C = Candidate, E = Endangered, SC = Special Concern, T = Threatened, — = No listing 

(b) The alligator is Federally and State listed for protection of the similar, endangered American crocodile (Crocodylus 

acutus).
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NUREG-1437, Supplement 33 2-38 August 2008 

2.2.7 Radiological Impacts 

HNP does not discharge unprocessed radioactive liquid wastes directly into a river, lake, or 

ocean; all radioactive liquid wastes are processed by the LWPS. Sludges and evaporator 

bottoms that are associated with liquid wastes are dewatered, solidified, and then shipped to an 

offsite disposal facility. Radioactive gaseous effluents are controlled by holdup in a series of 

storage tanks until very significant radioactive decay has occurred before the gases are 

released into the environment. HNP publishes an Annual Radioactive Effluent Release Report 

which provides detailed information on the types and quantities of radioactive material released 

into the environment. Through the sampling and analysis of various types of environmental 

media the REMP assesses the radiological impact to employees, the public, and the 

environment. The results of the environmental monitoring are documented and compared to the 

appropriate regulatory standards. HNP publishes the results of its environmental monitoring 

program in an Annual Radiological Environmental Operating Report (Progress Energy 2003a, 

2004a, 2005a, 2006d, 2007a). The objectives of the REMP are as follows: 

• Provide representative measurements of radiation levels and concentrations of 

radioactive materials in pertinent exposure pathways for the radionuclides that have the 

highest potential for radiation exposures to members of the public; and 

• Supplement the radiological effluent monitoring program by verifying that the 

measurable concentrations of radioactive materials and levels of radiation are not higher 

than expected on the basis of effluent measurements and modeling of the environmental 

exposure pathways. 

The ODCM contains the methodology for calculating the radiation dose that may be received by 

the maximally exposed member of the public from all radiation exposure pathways associated 

with HNP. The limits for all radiological releases are specified in the HNP ODCM, also. These 

release limits are used to help ensure compliance with regulatory requirements. The REMP 

includes monitoring of the waterborne environment (ground, water, and shoreline sediment); 

airborne environment (airborne radioiodine, gross beta, and gamma); ingestion pathways (milk, 

fish and invertebrates, and food products); and direct radiation. The REMP reports that were 

reviewed found no indication of significant radiological effects of HNP on the environment. 

In addition to the REMP, in response to NRC and industry initiatives HNP established a 

groundwater protection program in 2006. The program contains requirements for monitoring of 

four onsite groundwater monitoring wells. In addition to the onsite wells, HNP also performs 

periodic surveillance and monitoring of selected plant buildings, systems, and components 

containing liquids with radioactive material, for indication of leaks. The program includes criteria 

to notify the Control Room and Environmental and Chemistry personnel for follow-up 

assessment and cleanup, as necessary (Progress Energy 2006). At the time of the audit, there 

were no indications of radioactive leaks into the groundwater. During the periodic NRC 

inspection of the REMP, the groundwater protection program will be reviewed for information on 

indications of leaks into the groundwater and the actions taken by the applicant. 
Plant and the Environment 

August 2008 2-39 NUREG-1437, Supplement 33 

A historical review of radioactive release data from HNP, together with the resultant dose 

calculations, demonstrated that the calculated doses to maximally exposed individuals in the 

vicinity of HNP were a small fraction of the limiting values specified in the HNP ODCM to meet 

10 CFR Part 50, Appendix I dose design objectives, the 10 CFR Part 20 dose limits, and the 

EPA radiation standards in 40 CFR Part 190. For 2006, dose estimates were calculated based 

on actual liquid and gaseous effluent release data and conservative models for simulation of the 

transport mechanisms. The results are presented in the Shearon Harris Nuclear Power Plant, 

Annual Radioactive Effluent Release Report for 2006. The calculated maximum dose to an 

individual located at the HNP boundary from liquid effluents that were released is summarized 

as follows: 

• The maximum whole-body dose to an offsite member of the general public from liquid 

effluents was 8.20 × 10–3 mSv/y (0.820 mrem/y), well below the 0.03 mSv/y (3 mrem/y) 

dose design objective in 10 CFR Part 50, Appendix I. 

• The maximum whole-body dose to an offsite member of the general public averaged 

over the last 5 years and based on actual monitoring data from the REMP was 8.34 ×

10–5 mSv/y (8.34 × 10–3 mrem/y), well below the 0.03 mSv/y (3 mrem/y) dose design 

objective in 10 CFR Part 50, Appendix I. 

Each reported annual dose from gaseous effluents is calculated based on the highest 12-year 

annual average relative concentration and deposition factor for particulates at the most 

restrictive location at the site boundary. Therefore, the doses reported for 2006 were based on 

meteorological data for 1976 through 1987. 

During the last five years, releases of tritium, iodine-131, iodine-133, and particulates with 

greater than an 8-day half life resulted in a calculated average annual dose of 2.28 × 10–3

mSv/y (0.228 mrem/y) with the lungs being the critical organ of the maximally exposed member 

of the general public. This calculated average annual dose is well below the 0.15 mSv/y 

(15 mrem/y) design guidance objective specified in 10 CFR Part 50, Appendix I. 

2.2.8 Socioeconomic Factors 

This section describes current socioeconomic factors that have the potential to be directly or 

indirectly affected by changes in operations at HNP. HNP and the communities that support it 

can be described as a dynamic socioeconomic system. The communities provide the people, 

goods, and services required by HNP operations. HNP operations, in turn, create the demand 

and pay for the people, goods, and services in the form of wages, salaries, and benefits for jobs 

and dollar expenditures for goods and services. The measure of the communities’ ability to 

support the demands of HNP depends on their ability to respond to changing environmental, 

social, economic, and demographic conditions. 

The socioeconomics region of influence (ROI) is defined by the areas where HNP employees 

and their families reside, spend their income, and use their benefits, thereby affecting the 
Plant and the Environment 

NUREG-1437, Supplement 33 2-40 August 2008 

economic conditions of the region. The ROI consists of a two-county area (Wake and Lee 

counties), which is where approximately 82 percent of HNP employees reside. The following 

sections describe the housing, public services, offsite land use, visual aesthetics and noise, 

population demography, and the economy in the ROI surrounding the HNP site. 

HNP employs a permanent workforce of around 470 permanent employees and up to 250 longterm contract employees (Progress Energy 2006f). Approximately 94 percent live in Chatham, 

Harnett, Johnston, Lee, and Wake counties, North Carolina (Table 2–6). The remaining 

6 percent are divided among 11 other counties in North Carolina. Given the residential 

locations of HNP employees, the most significant impacts of plant operations are likely to occur 

in Wake and Lee counties where approximately 82 percent of the HNP employees reside. The 

focus of the analysis in this SEIS is therefore on the impacts of HNP in these two counties. 

HNP schedules refueling outages at nominal 18-month intervals. During refueling outages, site 

employment increases by 800 workers for temporary duty. Most of these workers are assumed 

to be located in the same geographic areas as the permanent HNP staff. 

Table 2–6. HNP Permanent Employee Residence 

by County in 2006 

County 

Number of HNP 

Personnel 

Percentage 

of Total 

Chatham 21 4 

Harnett 18 4 

Johnston 17 4 

Lee 75 16 

Wake 311 66 

Other 28 6 

Total 470 100 

Source: Progress Energy 2007f 

2.2.8.1 Housing 

Table 2–7 lists the total number of occupied housing units, vacancy rates, and median value in 

the region of influence. According to the 2000 census, there were approximately 279,000 

housing units in the ROI, of which approximately 261,000 were occupied. The median value of 

owner-occupied units was $162,900 in Wake County, which was higher than Lee County. The 

vacancy rate was also lower in Wake County (6.5 percent) and higher in Lee County 

(7.2 percent). 
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August 2008 2-41 NUREG-1437, Supplement 33 

By 2005, the total number of housing units in Wake County grew by more than 55,000 units to 

more than 314,000 units. As a result, the number of available vacant housing units increased 

by more than 9,000 units to approximately 26,000 units or 8.3 percent of the available units 

(USCB 2007). 

Table 2–7. Housing in Wake and Lee Counties, North Carolina, in 2000 

Wake Lee ROI 

Total 258,953 19,909 278,862 

Occupied housing units 242,040 18,466 260,506 

Vacant units 16,913 1,443 18,356 

Vacancy rate (percent) 6.5 7.2 6.6 

Median value (dollars) 162,900 95,100 129,000 

Source: USCB 2007 

2.2.8.2 Public Services 

This section presents a discussion of the public services of water supply, education, and 

transportation. 

Water Supply 

HNP does not use public water and is registered with the State of North Carolina as a user of 

water from Harris Reservoir for process, service, and domestic use, and provides onsite 

treatment for sanitary and process water and discharges effluent to Harris Reservoir under 

NPDES permit requirements.

Most HNP employees live in and around the communities of Raleigh, Cary, Apex, Holly Springs, 

Fuquay-Varina, and Sanford. The city of Raleigh’s water treatment and distribution system 

serves more than 125,000 metered customers and 345,000 individuals (City of Raleigh 2004). 

The source of Raleigh’s drinking water is Falls Lake, a 5018 ha (12,400 ac) impoundment 

northwest of the city that can provide up to 380 million liters (100 million gallons) of raw water a 

day to the city’s E.M Johnson Water Plant (Raleigh Public Utilities 2006). 

The towns of Cary and Apex use B. Everett Jordan Lake, located northwest of the town of Apex, 

as their source of drinking water (Town of Apex 2006; Town of Cary 2006). The towns of Cary 

and Apex co-own a water treatment facility that can treat up to 150 million liters (40 million 

gallons) per day. A study prepared in 2000 for the Town of Cary predicted that water demand 

would increase from 32.5 million liters (8.6 million gallons) per day (1998 value) to 101 million 

liters (26.7 million gallons) per day in 2028 (Town of Cary 2000). 
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NUREG-1437, Supplement 33 2-42 August 2008 

The town of Holly Springs purchases water from the city of Raleigh and from Harnett County 

(Town of Holly Springs 2006). The town is presently allocated 4.5 million liters (1.2 million 

gallons) of water per day from the City of Raleigh and 7.6 million liters (2 million gallons) per day 

from Harnett County. Harnett County uses the Cape Fear River as its source of drinking water 

(Harnett County 2006). Holly Springs’ water supply system is currently producing around 

5.7 million liters (1.5 million gallons) per day and is capable of treating its entire allocation of 

12.1 million liters (3.2 million gallons) of water per day. The town has a planned future capacity 

of 5.4 million liters (12 million gallons) per day using existing supply lines and a current storage 

capacity of 8.7 million liters (2.3 million gallons). 

The town of Fuquay-Varina purchases its drinking water from the city of Raleigh and Harnett 

and Johnston counties which use the Cape Fear River (Raleigh, Harnett County) and Neuse 

River (Johnston County) as their sources of drinking water (Fuquay-Varina 2006). Current 

treatment capacity for the town is 10.4 million liters (2.75 million gallons) per day. 

The city of Sanford uses the Cape Fear River system as its source for drinking water (City of 

Sanford 2005). The city’s single water treatment plant is capable of producing 45.4 million liters 

(12 million gallons) of clean drinking water per day, and typically provides around 7.6 billion 

liters (2 billion gallons) of drinking water (20.8 million liters [5.5 million gallons] per day) to city 

residents annually. 

Education

HNP is located in the Wake County Public School System, which is the second largest school 

system in North Carolina and had an enrollment of approximately 120,300 students in 2005. 

The Wake County Public School System, which includes the City of Raleigh, is composed of 

9 school districts with 138 public schools (WCPSS 2007). In 2000, there were approximately 

98,950 students enrolled in Wake County public schools (NCES 2007). 

Transportation

Access to HNP is via U.S. 1 approximately 3.2 km (2 mi) south-southwest of the center of the 

town of New Hill and 1.6 km (1 mi) southeast of the town of Bonsal near the Chatham CountyWake County line (Figure 2-3). The plant’s address is in New Hill. 

Most HNP employees live in Sanford, Holly Springs, Apex, Cary, and Raleigh, and FuquayVarina (Progress Energy 2006b). Employees generally use state secondary and county roads 

to get to U.S. 1 and then to the HNP site (Figure 2-3). Travel in the vicinity of the HNP is limited 

to county roads by the presence of Harris Reservoir and B. Everett Jordan Lake. U.S. 1 

provides the major highway link through the area and the only readily accessible access to the 

plant.

Traffic count data for roads in the vicinity of HNP is shown in Table 2-8. None of the roads 

listed have level-of-service determinations. 
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August 2008 2-43 NUREG-1437, Supplement 33 

Table 2-8. Average Annual Daily Traffic (AADT) Counts in the 

Vicinity of HNP in 2003

Roadway and Location 

Annual Average Daily 

Traffic (AADT)(a)

U.S. 1 – Entrance to HNP South of old US 1 17,000

U.S. 1 – near Apex 16,000

Old U.S. 1 – south of New Hill 1,800

Old U.S. 1 – just north of intersection with US 1 1,700

Old U.S. 1 – just north of Merry Oaks 2,300

Source: Progress Energy 2006b. 

(a) All AADTs represent traffic volume during the average 24-hour day during 2003. 

2.2.8.3 Offsite Land Use 

North Carolina has experienced significant population and economic growth since the early 

1990s. The state has been one of the fastest growing states in the nation, primarily as a result 

of in-migration (Brookings Institution 2000). This section describes Wake County current land 

use conditions because more than 99 percent of HNP’s annual property taxes go to Wake 

County.

Wake County 

Wake County is one of the fastest-growing counties in North Carolina. From 1990 to 2000, 

Wake County’s population grew by approximately 204,500 persons, which is an increase of 

approximately 48 percent, while during the same 10-year period the population in the state of 

North Carolina increased by 21 percent (USCB 2001). At the same time, the number of housing 

units in Wake County increased by 46 percent, while the total number of units in the state 

increased by 25 percent (USCB 2007). 

Wake County’s comprehensive land use plan focuses on growth-related issues and the 

implementation of conservation efforts to protect natural resources. The plan reflects public 

involvement in the planning process and the desire to encourage growth while controlling 

patterns of development. Land use planning tools, such as zoning and population density limits, 

are used to control development. Wake County encourages growth in areas where public 

facilities, such as water and sewer systems, exist or are scheduled to be built in the future. 

Wake County has no growth control measures in the traditional sense. However, the County 

has created a Growth Management Task Force dedicated to the development of a 
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NUREG-1437, Supplement 33 2-44 August 2008 

comprehensive growth management strategy that will retain the quality of life experienced by 

residents within the region thus far. 

Portions of Wake County lie within the Research Triangle, an area located between Duke 

University in Durham, North Carolina State University in Raleigh, and the University of North 

Carolina at Chapel Hill. Wake County occupies roughly 2155 km2 (832 mi2) of land area (USCB 

2006). Currently, the county is 35 to 40 percent developed. The land use breakdown 

percentages for Wake County are as follows: 32.8 percent residential, 4.0 percent 

business/commercial, 2.0 percent industrial, 17.2 percent parks and public lands, 42.8 percent 

agricultural/undeveloped, and 2.2 percent ”other” (Progress Energy 2006b). A report drafted by 

the Wake County Growth Management Task Force in 2002 noted that the county had 

experienced “rapid, exponential” growth in the 1990s and had a population of 678,751 in July 

2002 (Wake County 2002). The report predicted that the county’s population would increase by 

one-third over the ensuing 20 years, bringing the population “close” to one million. In 2006, 

however, the North Carolina State Demographer projected that the population of Wake County 

would exceed one million by 2015 and would be 1,133,110 by the year 2020 (NCOSBM 2006). 

Initially, as rapid regional growth occurred, the county and its 12 municipalities continued a 

traditional approach of working independently to deliver services, to plan for futures, and to 

address growth-related impacts within their own borders. The county and municipalities each 

adopted their own land use plans, zoning and subdivision ordinances, and capital improvement 

programs (Wake County 2002). 

By the late 1990s, the county was encountering significant growth-related changes resulting 

from rapid growth, including traffic jams, overcrowded schools, and loss of open space and 

natural areas. County and municipal officials identified the need for a more comprehensive 

effort to address growth concerns in Wake County. As a result, the Wake County Board of 

Commissioners formed the Wake County Growth Management Task Force to develop a countywide plan for growth management. 

Wake County has developed a county-wide land use plan, which also includes a special section 

devoted to the Harris Lake (Reservoir) Watershed. In the Wake County Land Use Plan (Wake 

County Planning Department 2003), the county has indicated that all land use planning should 

be based on the following broad goals: 

• To guide quality growth throughout the County in conjunction with affected local 

governments. 

• To encourage growth close to municipalities, to take advantage of existing and planned 

infrastructure, such as transportation, water and sewer facilities. 

• To encourage the development of communities that provide adequate land for 

anticipated demands, in a pattern which allows a mixture of uses. 
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August 2008 2-45 NUREG-1437, Supplement 33 

• To encourage maintenance of: open space, scenic aspects of rural areas, entrance 

ways to urban areas, and transition areas between urban areas. 

• To encourage the conservation of environmentally significant areas and important 

natural and cultural resources. 

• To allow owners of significant farmlands and forest lands the opportunity to maintain the 

productivity of their land. 

• To ensure that the land use plan and transportation plan mutually support each other. 

• To ensure that the County always protects the property rights of landowners. 

• To maintain the quality and develop the capacity of surface water resources, using them 

for recreation sites, where appropriate. 

• To prevent contamination of and maintain the capacity of groundwater resources. 

• To ensure that local governments provide adequate, properly located land for 

recreational and leisure opportunities. 

2.2.8.4 Visual Aesthetics and Noise 

The site of the HNP is in a sparsely populated rural area of North Carolina characterized by 

gently rolling timbered hills. The HNP reactor is on a rolling plateau above Harris Reservoir. 

The major visible structures are the reactor building, the turbine building, the radiological waste 

building, the service and administration building, and the cooling tower. The HNP buildings are 

only visible in the immediate vicinity of the station due to the rolling terrain. The top of the 

cooling tower during both day and night are visible for a greater distance because they protrude 

above the hilltops. 

Sources of noise from station operation include HNP’s cooling tower, turbines, and large pumps 

and cooling water system motors. The turbines, pump, and motor noise have not exceeded 

ambient (baseline) levels in offsite areas and the noise is audible (exceeding ambient levels) for 

no more than a mile from the plant. Noise emissions during operations do not cause other than 

minor nuisance problems. However, noise levels in the vicinity of the plant may sometimes 

exceed the 55 dBA level that the EPA uses as a threshold level to protect against excess noise 

during outdoor activities. However, according to the EPA this threshold does “not constitute a 

standard, specification, or regulation,” but was intended to provide a basis for state and local 

governments establishing noise standards. 

2.2.8.5 Demography 

According to the 2000 census, approximately 438,969 people lived within 32 km (20 mi) of HNP, 

which equates to a population density of (349 persons/mi2) (Progress Energy 2006b). This 
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NUREG-1437, Supplement 33 2-46 August 2008 

density translates to the least sparse Category 4 (greater than or equal to 120 persons per 

square mile within 20 miles) using the GEIS measure of sparseness. Approximately 

2,035,797 people live within 80 km (50 mi) of HNP (Progress Energy 2006b). This equates to a 

population density of (259 persons/mi2). Applying the GEIS proximity measures, HNP is 

classified as proximity Category 4 (greater than or equal to 190 persons per square mile within 

50 miles). Therefore, according to the sparseness and proximity matrix presented in the GEIS, 

the HNP ranks of sparseness Category 4 and proximity Category 4 result in the conclusion that 

HNP is located in a high population area. 

Table 2-9 shows population projections and growth rates from 1970 to 2050 in Wake and Lee 

counties. According to the 2000 census, between 1990 and 2000, Wake County was the fastest 

growing county in North Carolina. It was ranked first out of 100 counties in the state and 22nd 

among 3,141 counties nationwide by the total number of residents added. Beyond 2000, the 

population in Wake County is projected to continue to grow steadily. In Lee County, the 

population also grew steadily between 1970 and 2000 and is projected to continue to grow but 

at a relatively lower rate compared to Wake County through 2050. 

Table 2-9. Population and Percent Growth in Wake and Lee Counties, 

North Carolina, from 1970 to 2000 and Projected for 2010 to 2050 

Wake County Lee County 

Year Population

Percent 

Growth(a) Population

Percent 

Growth(a)

1970 228,453 — 30,467 — 

1980 301,327 31.9 36,718 20.5 

1990 423,380 40.5 41,374 12.7 

2000 627,846 48.3 49,040 18.5 

2010 882,373 40.5 58,382 19.0 

2020 1,133,110 28.4 67,180 15.1 

2030 1,404,751 24.0 76,573 14.0 

2040 1,521,813 8.3 82,283 7.5 

2050 1,723,651 13.3 90,007 9.4 

Sources: USCB 2007; NCSD 2007 

— = No data available.

(a) Percent growth rate is calculated over the previous decade. 
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August 2008 2-47 NUREG-1437, Supplement 33 

The 2000 demographic profile of the region of influence population is included in Table 2-10. 

Persons self-designated as minority individuals comprise 30.3 percent of the combined total 

population of these two counties. This minority population is composed largely of Black or 

African American and Hispanic and Latino residents. 

Table 2-10. Demographic Profile of the Population in the HNP Region of Influence 

 Wake County Lee County Region of Influence 

Total Population 627,846 49,040 676,886 

Race (2000) (percent of total population, Non-Hispanic or Latino) 

White 69.9 66.2 69.7 

Black or African 

American

19.5 20.4 19.6 

American Indian and 

Alaska Native 

0.3 0.4 0.3 

Asian 3.4 0.7 3.2 

Native Hawaiian and 

Other Pacific 

Islander 

0.0 0.0 0.0 

Some other race 0.1 0.1 0.1 

Two or more races 1.3 0.6 1.2 

Ethnicity 

Hispanic or Latino 33,985 5,715 39,700 

Percent of total 

population 

5.4 11.7 5.9 

Minority Population (including Hispanic or Latino ethnicity) 

Total minority 

population 

188,686 16,573 205,259 

Percent minority 30.1 33.8 30.3 

Source: USCB 2007 

Transient Population 

Within 80 km (50 mi) of HNP, colleges and recreational opportunities attract daily and seasonal 

visitors who create demand for temporary housing and services. In 2000 in Wake County, 

0.4 percent of all housing units are considered temporary housing for seasonal, recreational, or 

occasional use. By comparison, temporary housing accounts for only 0.7 percent and 

3.8 percent of total housing units in Lee County and North Carolina, respectively (USCB 2007).
Plant and the Environment 

NUREG-1437, Supplement 33 2-48 August 2008 

In 2004, there were approximately 112,000 students attending colleges and universities within 

80 kilometers (50 miles) of HNP (IES 2007). 

Migrant Farm Worker 

Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

crops. These workers may or may not have a permanent residence. Some migrant workers 

may follow the harvesting of crops, particularly fruit, throughout the northeastern U.S. rural 

areas. Others may be permanent residents near HNP who travel from farm to farm harvesting 

crops.

Migrant workers may be members of minority or low-income populations. Because they travel 

and can spend a significant amount of time in an area without being actual residents, migrant 

workers may be unavailable for counting by census takers. If uncounted, these workers would 

be “underrepresented” in USCB minority and low-income population counts. 

Wake and Lee counties host relatively small numbers of migrant workers. According to 2002 

Census of Agriculture estimates, 882 temporary farm laborers (those working fewer than 

150 days per year) were employed on 106 farms in Wake County, and 115 were employed on 

26 farms in Lee County (USDA 2002). 

2.2.8.6 Economy 

This section contains a discussion of the economy, including employment and income, 

unemployment, and taxes. 

Employment and Income 

Between 2000 and 2005, the civilian labor force in the Wake County area increased 

14.4 percent to the 2005 level of 408,977. The civilian labor force in the Lee County area grew 

7.0 percent to the 2005 level of 25,825 (USCB 2007). 

In 2005, employment in the services industry represented the largest sector of employment in 

both counties combined followed closely by construction and retail trade industries (Employment 

Security Commission of North Carolina 2007). The largest employer in Wake County in 2005 

was the State of North Carolina with approximately 37,700 employees (see Table 2-11). The 

majority of employment in Wake County is located in the city of Raleigh. 
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August 2008 2-49 NUREG-1437, Supplement 33 

Table 2-11. Major Employers in Wake County in 2005 

Employer 

Number of 

Employees Employer 

Number of 

Employees 

State of North Carolina 37,671 City of Raleigh 3,000 

Wake County Public School 

System 

15,000 Research Triangle Institute 2,600 

International Business 

Machines (IBM) 

13,000 Cisco Systems 2,500 

North Carolina State University 7,787 RTI International 2,260 

WakeMed Health & Hospitals 6,500 US Environmental Protection 

Agency

2,000

GlaxoSmithKline, Inc. 4,800 Waste Industries, Inc. 2,000 

Pinkerton & Burns 4,500 Verizon Wireless 1,600 

SAS Institute, Inc. 4,300 First Citizens Bank & Trust 

Company 

1,574

WakeMed Faculty Physician’s 

Internal Medicine 

4,000 Eaton Division/Headquarters 1,500 

Rex Healthcare 3,800 Food Lion Stores 1,500 

Progress Energy 3,400 Longistics International 1,500 

Wake County 3,300 Misys Healthcare Systems 1,500 

Nortel 3,150 

Source: Wake County 2007 

Income information for Wake and Lee counties is presented in Table 2-12. According to the 

2000 census, the median household and per capita income in Wake County was well above Lee 

County and the North Carolina average. Income levels in Lee County were slightly below but 

were very close to the state average. In 2000, only 7.8 percent of the population in Wake 

County was living below the official poverty level, while in Lee County, 12.8 percent of the 

population was living below the poverty level (USCB 2007). 
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NUREG-1437, Supplement 33 2-50 August 2008 

Table 2-12. Income Information for the HNP Region of Influence 

 Wake County Lee County North Carolina 

Median household income 1999 (dollars) 54,988 38,900 39,184 

Per capita income 1999 (dollars) 27,004 19,147 20,307 

Percent of persons below the poverty line 

(2000) 

7.8 12.8 12.3 

Source: USCB 2007 

Unemployment

In 2005, the annual unemployment average in the Wake and Lee counties were 5.1 and 

5.5 percent, respectively, which were well below the annual unemployment average of 

7.1 percent for North Carolina (USCB 2007). 

Taxes

CP&L and North Carolina Eastern Municipal Power Agency (NCEMPA), the owners of HNP, 

pay property taxes to both Wake County and Chatham County, but the amounts paid to 

Chatham County are relatively small. From 2001 to 2004, the amount paid to Chatham County 

by CP&L ranged between $50,000 and $60,000 annually. For the same years, the NCEMPA 

amount ranged between $40,000 and $50,000 annually. 

From 2001 through 2005, CP&L paid between $7.1 million and $8.4 million annually in property 

taxes to Wake County (see Table 2-13). Over the same period, the NCEMPA’s property tax 

payments have represented less than one percent of Wake County’s total real and personal 

property tax revenues (see Table 2-13). These payments represented between 1.9 and 

2.6 percent of the county’s total annual property tax revenue. Each year, Wake County collects 

these taxes, retains a portion for county operations, and disburses the remainder to the county’s 

12 cities or municipalities to fund their respective operating budgets (Progress Energy 2006b). 

Real and personal property tax revenues go into the county’s General Fund. The property tax 

payments from CP&L and NCEMPA are primarily used by Wake County to pay for education 

and human services, as well as general administration, community, and environmental services, 

and public safety (Wake County 2004). 

At present, the State of North Carolina General Assembly has taken no action on deregulation, 

which could, if enacted, affect tax payments to Wake County (Progress Energy 2006b). The 

Study Commission on the Future of Electric Service in North Carolina, which studied electric 

service choice for more than four years, decided in February 2002 to delay any action for the 

foreseeable future. Therefore, the potential effects of deregulation are not yet fully known. 

However, any changes to HNP property tax rates due to deregulation would be independent of 

license renewal (Progress Energy 2006b). 
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August 2008 2-51 NUREG-1437, Supplement 33 

The continued availability of HNP and the associated tax base is an important feature in the 

ability of the Wake County and county municipalities to continue to invest in infrastructure and to 

draw industry and new residents. 

Table 2-13. Wake County Tax Revenues, CP&L Property Tax, and NCEMPA Property Tax as 

a Percentage of Tax Revenues, 2001 to 2005 

Year

Wake County Tax 

Revenues 

(in millions of 

dollars)

Property Tax 

Paid by 

Progress

Energy (in 

millions of 

dollars)

Progress

Energy 

Property Tax as 

Percentage of 

Tax Revenues 

Property Tax 

Paid by 

NCEMPA (in 

millions of 

dollars)

NCEMPA 

Property Tax as 

Percentage of 

Tax Revenues 

2001 323.5 7.1 2.2 2.1 Less than 1.0 

2002 317.0 8.4 2.6 2.1 Less than 1.0 

2003 354.1 7.4 2.1 2.0 Less than 1.0 

2004 368.4 7.1 1.9 1.9 Less than 1.0 

2005 389.3 8.4 2.2 1.8 Less than 1.0 

Source: Progress Energy 2006b 

2.2.9 Historic and Archaeological Resources 

This section discusses the cultural background and the known historic and archaeological 

resources at the HNP site and in the surrounding area. 

2.2.9.1 Cultural Background 

The region around HNP contains prehistoric and historic Native American and Euro American 

cultural resources. The HNP ER mentions 29 properties listed in the National Register of 

Historic Places within approximately 9.6 km (6 mi) of HNP boundary (Progress Energy 2006b). 

These registered properties are primarily historic architectural resources but they also include 

archaeological resources. Five other locations within the 6 mile area are determined eligible for 

inclusion but are not yet listed in the Register. These locations are all historic architectural 

resources. Recorded archaeological sites in the area are predominantly the remains of 

prehistoric occupations but they also include remains of historic activities. 

Paleo-Indians occupied North America from 10,000 to 12,000 years ago, living off the land and 

subsisting on large game, such as mammoths, that have since become extinct. In the North 
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NUREG-1437, Supplement 33 2-52 August 2008 

Carolina area, people lived in an environment that was wetter and cooler than today’s. 

Paleo-Indians are typically considered to have been big game hunters. However, evidence from 

archaeological work in the state suggests that small game and plants played a significant role in 

the lifeways of the populations living in Paleo-Indian times. Stone tool styles show little 

variability over wide areas of North and South America, nevertheless raw material for these 

tools often have sources far from where the tools are found. 

During the Archaic Period, from approximately 10,000 years ago until about 2,500 years ago, 

subsistence strategies underwent local changes to adapt to available resources. By the end of 

the Archaic Period, at a time when the climate reached its modern condition, archaeologists find 

more evidence of occupation suggesting an increased population density after the Paleo-Indian 

Period. Archaeologists interpret the settlement patterns they find as suggestive of an increase 

in the breadth of resources sought by prehistoric people as they lived in smaller territories. 

Archaic people collected, hunted, and gathered most of what they needed for survival in their 

home territory.

The Woodland Period, from approximately 3500 years ago to about 400 years ago, is viewed by 

North Carolina archaeologists as representative of a continuum of change in adaptation by 

prehistoric peoples. In the Woodland culture, Native Americans became regionally distinct 

cultural entities. Woodland people ultimately became dependent on maize agriculture, lived in 

villages, used the bow and arrow in hunting, and began to regularly make and use pottery. 

Archaeologists have gained no precise understanding of the transition from the Archaic to 

Woodland periods. The change seems to have been gradual and the remains for these 

occupations are often mixed in deposits that overlap each other. In the Woodland culture semipermanent villages were most often located along stream valleys where conditions are best for 

agriculture (Claggett 1996). 

Files maintained by the North Carolina Office of State Archaeology document 52 archaeological 

sites within lands owned by the applicant. All but one of the sites are found to date to the 

prehistoric time periods associated with the Archaic and Woodland periods (Patch 2006). 

Beginning in the early seventeenth century contacts between Native American groups and new 

immigrants from the Old World were frequent and by the early eighteenth century immigrants 

began to flow into the area from European colonies in Virginia, Maryland, Pennsylvania, and 

North Carolina (Patch 2006). The Native Americans were displaced; either to join tribes outside 

the geographic area, move to small reservations (Claggett 1996), or they assimilated into the 

new settler’s European-American or African-American cultures. 

The North Carolina Legislature established Wake County in 1771 (Corbett 1987). Agriculture 

remained the principal activity for colonists and their descendents through the eighteenth and 

nineteenth centuries. Upland as well as river and stream bottoms were farmed in this period 

though evidence of this is obscured by reforestation. At first the farming was for subsistence but 

as roads and railroads penetrated the area the importance of market agriculture increased. 
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August 2008 2-53 NUREG-1437, Supplement 33 

After the Civil War the agricultural emphasis changed from corn, dairy, hogs, and truck farming 

to crops such as tobacco and cotton that produced cash but exhausted the land (Patch 2006). 

Depleted and eroded soils led to a reduction in farming and a shift in population to more urban 

environments in the late nineteenth and early twentieth centuries. 

2.2.9.2 Historic and Archaeological Resources 

The HNP ER states “there are a number of cultural resources within or near the HNP 

boundaries” and that none of these are “listed on the National Register of Historic Places” 

(Progress Energy 2006b). NRC staff has confirmed historic and archaeological sites have been 

recorded at HNP (Patch 2006). In January 2006, the North Carolina State Historic Preservation 

Office (SHPO) wrote a letter to the applicant concerning HNP license renewal. The letter 

confirmed that they had “conducted a review of the project and are aware of no historic 

resources that would be affected” by the proposal to extend the operating license for HNP 

(NCDCR 2006). 

A search of the archaeological site record files indicates that 51 prehistoric and one historic 

archaeological sites have been recorded on lands at HNP owned by the applicant. Most of 

these consist of low-density scatters of stone debris and tools in upland settings. The majority 

of the archaeological sites are small and badly disturbed. Additional historic and prehistoric 

archaeological sites remain undiscovered and unevaluated on the applicant’s lands. 

The SHPO, in letters concerned with the original construction of HNP and dated March 1978 

and December 1979, acknowledges the location of archaeological sites on affected lands but 

comments that none of the recorded sites are “considered to be significant...due to damage and 

destruction caused by erosional processes” (NCDCR 1978). 

2.2.10 Related Federal Project Activities and Consultations 

The NRC staff reviewed the possibility that activities of other Federal agencies might impact the 

renewal of the operating license for HNP. Any such activity could result in cumulative 

environmental impacts and the possible need for a Federal agency to become a cooperating 

agency in the preparation of the HNP SEIS. 

The NRC staff has determined that there are no Federal project activities that could result in 

cumulative impacts or would make it desirable for another Federal agency to become a 

cooperating agency for preparing this SEIS. 

NRC is required under Section 102 of the National Environmental Policy Act of 1969 (NEPA) to 

consult with and obtain the comments of any Federal agency that has jurisdiction by law or 

special expertise with respect to any environmental impact involved. Federal agency comment 

correspondence is included in Appendix E. 
Plant and the Environment 

NUREG-1437, Supplement 33 2-54 August 2008 

2.2.10.1 Coastal Zone Management Act 

In the United States, coastal areas are managed through the Coastal Zone Management Act of 

1972 (CZMA). The Act, administered by the National Oceanic and Atmospheric Administration 

(NOAA) Office of Ocean and Coastal Resource Management, provides for management of the 

nation's coastal resources, including the Great Lakes, and balances economic development 

with environmental conservation. The Federal Consistency Regulations implemented by NOAA 

are contained in 15 CFR Part 930. 

This law authorizes individual states to develop plans that incorporate the strategies and 

policies they will employ to manage development and use of coastal land and water areas. 

Each plan must be approved by NOAA. One of the components of an approved plan is 

“enforceable polices,” by which a state exerts control over coastal uses and resources. 

The North Carolina Coastal Management Program was approved by NOAA in 1981. The lead 

agency is the Division of Coastal Management within the Department of Environment and 

Natural Resources which implements and supervises all the various Coastal Zone Management 

programs in the state. North Carolina's coastal zone includes 20 coastal counties that in whole 

or in part are adjacent to, adjoining, intersected or bounded by the Atlantic Ocean or any coastal 

sound (NOAA 2007). 

Federal Consistency requires “federal actions, occurring inside a state’s coastal zone, that have 

a reasonable potential to affect the coastal resources or uses of that state’s coastal zone, to be 

consistent with that state’s enforceable coastal policies, to the maximum extent practicable”.

HNP is located in Wake County, North Carolina. Wake County is not included in the list of North 

Carolina coastal counties which are subject to the rules and policies of the Division of Coastal 

Management, which administers the CZMA (NCDENR 2007c). License renewal of HNP does 

not require a State coastal consistency certification. 

2.3 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 

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, National Environmental Policy Act – 

Regulations Implementing Section 102(2), Part 51, “Postconstruction Environmental Reports: 

Operating License Renewal Stage.” 
Plant and the Environment 

August 2008 2-55 NUREG-1437, Supplement 33 

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

Requirements for Land Disposal of Radioactive Waste.” 

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

Transportation of Radioactive Material.” 

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

“Designation of Areas for Air Quality Planning Purposes.” 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental Radiation Protection Standards for Nuclear Power Operations.” 

40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260 

“Hazardous Waste Management System: General.” 

40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 

“Identification and Listing of Hazardous Waste.” 

40 CFR Part 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273, 

“Standards for Universal Waste Management.” 

72 FR 37346, U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 

removing the Bald Eagle in the lower 48 states from the list of endangered and threatened 

wildlife. July 9, 2007. 

Brookhaven National Laboratory (BNL). 2007. BNL Table of Isotopes, NuDat 2.3 Decay 

Radiation Search. Available URL: http://www.nndc.bnl.gov/nudat2/indx_dec.jsp. 

Brookings Institution 2000. Adding It Up: Growth Trends and Policies in North Carolina. 

Center on Urban and Metropolitan Policy. Available online at 

http://www.brookings.edu/es/urban/ncreport.pdf. 

Carolina Power and Light Company (CP&L). 1994. Harris Nuclear Power Plant 1992 

Environmental Monitoring Report. Environmental Services Section, New Hill, NC. July 1994. 

Accessible at ML072290476, Pages 173-249. 

Carolina Power and Light Company (CP&L). 1998. Threatened and Endangered Species SelfAssessment Report. Memo. August 12, 1998. Accessible at ML072290476, Pages 67-115. 

Center for Plant Conservation (CPC). 2007. “Carolina Grass-of-Parnassas.” Available URL: 

http://www.centerforplantconservation.org/ASP/CPC_ViewProfile.asp?CPCNum=3099. 

Accessible at ML072920082 Page 29. 
Plant and the Environment 

NUREG-1437, Supplement 33 2-56 August 2008 

Center for Reptile and Amphibian Conservation (CRACM). 2007a. “Eastern Tiger Salamander.” 

Available URL: http://herpcenter.ipfw.edu/index.htm?http://herpcenter.ipfw.edu/outreach/ 

accounts/amphibians/salamanders/E_Tiger_Salamander/index.htm&2. Accessible at 

ML072920082 Page 33. 

Center for Reptile and Amphibian Conservation (CRACM). 2007b. “Four-toed Salamander.” 

Available URL: http://herpcenter.ipfw.edu/index.htm?http://herpcenter.ipfw.edu/outreach/ 

accounts/amphibians/salamanders/Four-toed_salamander/index.htm&2. Accessible at 

ML072920082 Page 34. 

City of Raleigh. 2004. 2003 Annual Drinking Water Quality Report. Available URL: 

http://www.raleighnc.gov/publications/Public_Utilities/Consumer_Confidence_Report-2003.pdf. 

Accessible at ML072920082 Page 3. 

City of Sanford. 2005. “Where does my water come from?” Available URL: 

http://www.sanfordnc.net/Public_Works/water_from.htm. Accessible at ML072920082 Page 9. 

Claggett, S. R. 1996. North Carolina’s First Colonists: 12,000 Years Before Roanoke. Available 

URL: http://www.arch.dcr.state.nc.us/ncarch/articles/1stcolo.htm. Accessible at ML072920082 

Page 10.

Clean Water Act of 1977. Federal Water Pollution Control Act of 1977, 33 USC 1251, et seq. 

Coastal Zone Management Act of 1972. 16 USC 1456(c)(3)(A). 

Corbett, D.L. 1987. The Formation of North Carolina Counties 1663-1943. Division of Archives 

and History, North Carolina Department of Cultural Resources, Raleigh. 

Elliott, D. L., C. G. Holladay, W. R. Barchet, H. P. Foote, and W. F. Sandusky. 1987. Wind 

Energy Resource Atlas of the United States. DOE/CH 10093-4, U. S. Department of Energy, 

Washington, D. C. Available URL: http:// http://rredc.nrel.gov/wind/pubs/atlas/. 

Employment Security Commission of North Carolina. 2007. Wake and Lee County 

Employment and Wages by North American Industry Classification System (NAICS) for 2005. 

Available URL: http://eslmi23.esc.state.nc.us/ew/. Accessible at ML072920082 Page 43. 

Endangered Species Act of 1973. 16 USC 1531, et seq. 

Fuquay-Varina. 2006. “Public Utilities Department (Water and Sewer). Available URL: 

http://www.fuquay-varina.org/utilities/. Accessible at ML072920082 Page 64. 

Harnett County. 2006. “Public Utilities.” Available URL: http://www.harnett.org/utilities. 

Accessible at ML072920082 Page 88. 
Plant and the Environment 

August 2008 2-57 NUREG-1437, Supplement 33 

Institute of Educational Science (IES). 2007. U.S. Department of Education. National Center 

for Educational Statistics. “College Opportunities Online Locator”. Available URL: 

http://nces.ed.gov/ipeds/cool.refinesearch.aspx. 

Jones, T.W., W.J. Collart, D. Hinshaw, S. Van Horn. 2000. Harris Lake Creel Survey, 1997-

1998. North Carolina Wildlife Resources Commission Division of Inland Fisheries, Raleigh, 

North Carolina. Accessible at ML072920082 Page 189. 

Kibler, D. 2007. Shearon Harris: Carolina’s Best Bassin’. North Carolina Game & Fish. 

Available URL: http://www.ncgameandfish.com/fishing/bass-fishing/NC_0407_01/index.html. 

Accessible at ML072920082 Page 116. 

Lane, S. 2007a. Response to requests for additional information regarding the environmental 

review for Shearon Harris nuclear power plant license renewal application. Request number 2, 

Harris Nuclear plant air emissions. August 8, 2007. Accessible at ML072290474. 

Lane, S. 2007b. Request for additional information regarding the environmental review for 

Shearon Harris nuclear power plan license renewal application, Harris Nuclear Plant FacilityCriteria Pollutant Actual Emissions. August 8, 2007. Accessible at ML072290481 Page 470. 

National Center for Education Statistics (NCES). 2007. U.S. Department of Education, National 

Center for Education Statistics, Common Core of Data, “Public Elementary/Secondary School 

Universe Survey,” 2000-01, and “Local Education Agency Universe Survey,” 2000-01. Available 

URL: http://nces.ed.gov/pubs2002/100_largest/table_app_a_1.asp. Accessible at 

ML072920082 Page 136. 

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

National Oceanic & Atmospheric Administration (NOAA). 2007. U.S. Department of 

Commerce, National Oceanic and Atmospheric Administration, Office of Coastal Resource 

Management, “Ocean and Coastal Management in North Carolina” Available URL: 

http://coastalmanagement.noaa.gov/mystate/nc.html. Washington, D.C. Accessible at 

ML072920082 Page 177. 

New York Department of Environmental Conservation (NYDEC). 2007. “Eastern Tiger 

Salamander Fact Sheet.” Available URL: http://www.dec.ny.gov/animals/7143.html. Accessible 

at ML072920082 Page 179. 

North Carolina Department of Cultural Resources (NCDCR). 1978. Letter from North Carolina 

State Historic Preservation Officer, L. E. Tise, to Manager Environmental Technology-Carolina 

Power and Light Company, R. L. Sanders. Subject: Shearon Harris Nuclear Plant, Wake and 

Chatham Counties—Inquiry. March 9, 1978. 
Plant and the Environment 

NUREG-1437, Supplement 33 2-58 August 2008 

North Carolina Department of Cultural Resources (NCDCR). 2006. Letter from Renee GledhillEarly to Dave Corlett, Subject: License Renewal, Shearon Harris Nuclear Power Plant, Wake 

County, ER 05-2747. January 26, 2006. Appendix D, Page D-8 of Shearon Harris Nuclear Plant 

– License Renewal Application, Appendix E: Applicant’s Environmental Report, Operating 

License Renewal Stage. Accessible at ML063350276.

North Carolina Department of Environment and Natural Resources (NCDENR). 2004.

Basinwide Assessment Report – Cape Fear River Basin. Division of Water Quality, 

Environmental Sciences Section. August 2004. Accessible at ML072530536. 

North Carolina Department of the Environment and Natural Resources (NCDENR). 2006. 

Letter from H. LeGrand, Zoologist, Natural Heritage Program. Subject: License Renewal for 

the Harris Nuclear Plant (HNP); Wake and Chatham Counties. Appendix C of Shearon Harris 

Nuclear Plant – License Renewal Application, Appendix E: Applicant’s Environmental Report, 

Operating License Renewal Stage. Accessible at ML063350276. 

North Carolina Department of Environment and Natural Resources (NCDENR). 2007a.

Available URL: http://www.daq.state.nc.us/planning/attainment.shtml. Accessible at 

ML072920082 Page 133. 

North Carolina Department of Environment and Natural Resources (NCDENR). 2007b. Air 

Permit No. 08455R04, March 21, 2007. Accessible at ML072290474, Page 6.

North Carolina Department of Environment and Natural Resources (NCDENR). 2007c. State of 

North Carolina, Division of Coastal Management, “North Carolina CAMA Counties”. Available 

URL: http://www.nccoastalmanagement.net/cama_counties.htm. Accessible at ML072920082 

Page 134. 

North Carolina Division of Parks and Recreation (NCDPR). 2006. “Jordan Lake State 

Recreation Area: Ecological Information.” Available URL: 

http://ils.unc.edu/parkproject/visit/jord/info.html Accessible at ML072920082 Page 135. 

North Carolina Native Plant Society (NCNPS). 2006. “Invasive Exotic Plants in NC.” Available 

URL: http://www.ncwildflower.org/invasives/invasives.htm Accessible at ML072920082 Page 

150.

North Carolina Natural Heritage Program (NCNHP). 2003. “Executive Summary: An Inventory 

of Significant Natural Heritage Areas in Wake County, North Carolina.” Available URL: 

http://www.ncnhp.org/Images/Wake12-12-2005.pdf Accessible at ML072920082 Page 139. 

North Carolina Natural Heritage Program (NCNHP). 2007. Heritage Database. Available at 

URL: http://www.ncnhp.org/Pages/heritagedata.html. Accessible at ML072920082 Page 145. 
Plant and the Environment 

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North Carolina Office of State Budget and Management (NCOSBM). 2006. Population 

Overview: 2000-2030. Available URL: http://demog.state.nc.us/demog/pop0030.html 

Accessible at ML072920082 Page 157. 

North Carolina State Demographics (NCSD). 2007. North Carolina projected population data 

for 2010, 2020, and 2030. Available URL: http://demog.state.nc.us/demog/home.html. 

Accessible at ML072920082 Page 161. 

North Carolina Wildlife Resources Commission (NCWRC). 2005. “Bald Eagle Fact Sheet.” 

Available URL: http://www.ncwildlife.org/pg07_wildlifespeciescon/nongame_baldeagle_hires.pdf

Accessible at ML072920082 Page 173. 

North Carolina Wildlife Resources Commission (NCWRC). 2007. Inland Fishing, Hunting, and 

Trapping Regulations Digest, July 1, 2007 to June 30, 2008. Accessible at ML072530593. 

North Carolina Wildlife Resources Commission (NCWRC). 2007b. Dwarf wedgemussel. 

Available URL: http://www.ncwildlife.org/pg07_WildlifeSpeciesCon/pg7b1a1_1.htm Accessible 

at ML072920082 Page 175. 

Patch, S. 2006. An Archaeological Survey of Portions of the Shearon Harris Nuclear Plant 

Wake and Chatham Counties, North Carolina. New South Associates Technical Report # 1372. 

July 17, 2006. Accessible at ML072290481, Pages 430-468. 

Progress Energy Carolinas Inc., (Progress Energy). 2001. Harris Nuclear Plant 2000 

Environmental Monitoring Report. Environmental Services Section, New Hill, North Carolina. 

September. Accessible at ML072290476, Pages 117-149. 

Progress Energy Carolinas Inc., (Progress Energy). 2003a. Harris Nuclear Plant 2002 

Radiological Environmental Operating Report. January 2002–December 2002. Raleigh, North 

Carolina. Accessible at ML031200120.

Progress Energy Carolinas Inc., (Progress Energy). 2003b. Harris Nuclear Plant 2002 

Environmental Monitoring Report. Environmental Services Section, New Hill, North Carolina. 

Accessible at ML072290476, Pages 151-171. 

Progress Energy Carolinas Inc., (Progress Energy). 2004a. 2003 Radiological Environmental 

Operating Report. January 2003–December 2003. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML041210098. 

Progress Energy Carolinas Inc., (Progress Energy). 2005a. 2004 Radiological Environmental 

Operating Report. January 2004–December 2004. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML051220229. 
Plant and the Environment 

NUREG-1437, Supplement 33 2-60 August 2008 

Progress Energy Carolinas Inc., (Progress Energy). 2006. Shearon Harris Nuclear Plant 

License Renewal Application. Raleigh, North Carolina. Accessible at ML062280593. 

Progress Energy Carolinas Inc., (Progress Energy). 2006a. Shearon Harris Nuclear Plant 

License Renewal Application. Raleigh, North Carolina. Accessible at ML063350270. 

Progress Energy Carolinas Inc., (Progress Energy). 2006b. Shearon Harris Unit 1, Applicant’s 

Environmental Report, Operating License Renewal Stage. Raleigh, North Carolina. Accessible 

at ML063350276. 

Progress Energy Carolinas Inc., (Progress Energy). 2006c. Synthetic Minor Air Permit Renewal 

Application dated December 20, 2006. Accessible at ML072290481 Pages 1-16. 

Progress Energy Carolinas Inc., (Progress Energy). 2006d. 2005 Radiological Environmental 

Operating Report. January 2005-December 2005. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML061160214. 

Progress Energy Carolinas Inc., (Progress Energy). 2007a. 2006 Radiological Environmental 

Operating Report. January 2006–December 2006. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML071140335. 

Progress Energy Carolinas Inc., (Progress Energy). 2007b. Letter from B.C. Waldrep, HNP to 

NCDENR, Subject: Industrial Landfill Closure. April 19, 2005. Accessible at ML072290481, 

Pages 191-203. 

Progress Energy Carolinas Inc., (Progress Energy). 2007c. Letter from David H. Corlett, HNP 

Licensing Regulatory Programs to USNRC, Washington, D.C. Subject: Shearon Harris Nuclear 

Power Plant, Docket No. 50-400/License No. NPF-63, Notification of NPDES Permit Renewal, 

New Hill, North Carolina. March 7, 2007. Accessible at ML070740432. 

Progress Energy Carolinas Inc., (Progress Energy). 2007d. Harris Nuclear Plant Response to 

Requests for Additional Information Part II, Solid Waste Generation at the Harris Plant. Raleigh, 

North Carolina. Accessible at ML072290481 Page 483. 

Progress Energy Carolinas Inc., (Progress Energy). 2007e. Harris Nuclear Plant Response to 

Requests for Additional Information Part II, Underground Storage Tank Operating Permit 

Application. Raleigh, North Carolina. Accessible at ML072290481 Pages 239-240. 

Progress Energy Carolinas Inc., (Progress Energy). 2007f. Harris Nuclear Plant Response to 

Requests for Additional Information Part II, HNP Employee residence data. Raleigh, North 

Carolina. Accessible at ML072290481 Pages 218-228. 
Plant and the Environment 

August 2008 2-61 NUREG-1437, Supplement 33 

Progress Energy Carolinas Inc., (Progress Energy). 2007g. Harris Nuclear Plant Response to 

Requests for Additional Information Part II, HNP Employee residence data. Raleigh, North 

Carolina. Accessible at ML072290481 Pages 76-111. 

Raleigh Public Utilities. 2006. “Public Utilities.” Available URL: http://www.raleigh-nc.org/portal/ 

server.pt/gateway/PTARGS_0_2_306_204_0_43/http%3B/pt03/DIG_Web_Content/dept/public/

Dept-AboutUs-PubUtil.html. Accessible at ML072920082 Page 183. 

Ramsdell, J.V. Jr. 2007a. E-mail to Dave Armstrong, Lawrence Livermore National Laboratory, 

dated May 29, 2007. Accessible at ML072920082 Page 186. 

Ramsdell, J. V. Jr. 2007b. Tornado Climatology of the Contiguous United States. 

NUREG/CR-4461, Rev. 2, U.S. Nuclear Regulatory Commission, Washington, D.C. Accessible 

at ML070810400. 

State Climate Office of North Carolina (SCONC). 2007. Available URL: http://www.nc-climate 

.ncsu.edu/cronos/summaries.php?station=KRDU Accessible at ML072920082 Page 187. 

Town of Apex. 2006. Annual Drinking Water Quality Report, Calendar Year 2005, Public Water 

System No. NC0392045. Available URL: http://www.apexnc.org/docs/pw/water_qual.pdf 

Accessible at ML072920082 Page 203. 

Town of Cary. 2000. Water Conservation and Peak Demand Management Plan (Executive 

Summary). Available URL: http://www.townofcary.org/depts/pwdept/water/waterconservation/ 

wcplanexecsumm.pdf Accessible at ML072920082 Page 207. 

Town of Cary. 2006. Annual Water Quality Report: water testing performed in 2005. Available 

URL: http://www.townofcary.org/depts/pwdept/water/ccr.pdf Accessible at ML072920082 

Page 215. 

Town of Holly Springs. 2006. Water Quality Department. Available URL: 

http://www.hollyspringsnc.us/dept/water/index.htm Accessible at ML072920082 Page 220. 

U.S. Atomic Energy Commission (AEC). 1973. Final Environmental Statement related to 

construction of Shearon Harris Nuclear Power Plant Units 1, 2, 3, and 4. Carolina Power and 

Light Company. May 1973. Accessible at ML070800129. 

U.S. Atomic Energy Commission (AEC). 1974. Revised Final Environmental Statement 

Related to the Construction of Shearon Harris Units 1, 2, 3, and 4. Docket No. 50-400.

Directorate of Licensing. Washington, D.C. Accessible at ML063330486. 

U.S. Audubon Society. 2002. “Audubon WatchList: Red-cockaded Woodpecker.” Available 

URL: http://audubon2.org/webapp/watchlist/viewSpecies.jsp?id=171 Accessible at 

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Plant and the Environment 

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U.S. Census Bureau (USCB). 2001. Ranking Tables for States: Population in 2000 and 

Population change from 1990 to 2000 (PHC-T-2). Available URL: 

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U.S. Census Bureau (USCB). 2006. “Wake County, North Carolina.” Available URL: 

http://quickfacts.census.gov/qfd/states/37/37183.html. 

U.S. Census Bureau (USCB). 2007. North Carolina Data. DP-1. Profile of General 

Demographic Characteristics: 2000 for Wake and Lee Counties, North Carolina. Data Set: 

Census 2000 Summary File 1 (SF-1) – 100-Percent Data. Available URL: 

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U.S. Department of Agriculture (USDA). 2002. Census of Agriculture. Available URL: 

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U.S. Environmental Protection Agency (EPA). 2007. “8-Hour Ground-level Ozone 

Designations.” Available URL: http://www.epa.gov/ozonedesignations/regions/region4desig.htm 

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U.S. Fish and Wildlife Service (FWS). 2007a. Dwarf wedgemussel in North Carolina. Available 

URL: http://www.fws.gov/nc-es/mussel/dwmussel.html Accessible at ML072920082 Page 66. 

U.S. Fish and Wildlife Service (FWS). 2007b. “Michaux's Sumac in North Carolina.” Available 

URL: http://www.fws.gov/nc-es/plant/michsumac.html Accessible at ML072920082 Page 68. 

U.S. Fish and Wildlife Service (FWS). 2007c. North Carolina Ecological Services, Cape Fear 

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U.S. Fish and Wildlife Service (FWS). 2007d. “Red-cockaded Woodpecker.” Available URL: 

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U.S. Nuclear Regulatory Commission (NRC). 1983. Final Environmental Statement Related to 

the Operation of Shearon Harris Units 1 and 2. Docket No. 50-400. Washington, D.C. 

Accessible at ML071340292. 

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

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

U.S. Nuclear Regulatory Commission (NRC). 2000. “Shearon Harris Nuclear Power Station, 

Unit 1, Issuance of Amendment Re: Expansion of Spent Fuel Storage Capacity” December 21, 

2000. Accessible at ML003779362. 
Plant and the Environment 

August 2008 2-63 NUREG-1437, Supplement 33 

U.S. Nuclear Regulatory Commission (NRC). 2001. “Shearon Harris Nuclear Power Station, 

Unit 1, Notice of Issuance of Amendment to Facility Operating License” October 12, 2001. 

Accessible at ML012890247. 

Wake County. 2002. Wake County Growth Management Strategy: Executive Summary and 

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Wake County, North Carolina. Available URL: 

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Wake County Planning Department. 2003. Wake County Land Use Plan. Available URL: 

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Wake County. 2004. Wake County Tax Information. Available URL: 

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Wake County. 2007. Wake County Economic Development “Mayor Employers”. Available 

URL: http://www.raleigh-wake.org/files/Major.Employers.Summary.pdf. Accessible at 

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Wake County Public School System (WCPSS). 2007. Demographic Resource Center. Actual 

2005 Student Population, Number of Schools and School Districts Information. Available URL: 

http://www.wcpss.net/demographics/. Accessible at ML072920082 Page 268. 

August 2008 3-1 NUREG-1437, Supplement 33 

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 

Environmental issues associated with refurbishment activities are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 

Volumes 1 and 2 (NRC 1996; 1999).(1) The GEIS includes a determination of whether the 

analysis of the environmental issues could be applied to all plants and whether additional 

mitigation measures would be warranted. Issues are then assigned a Category 1 or a 

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 

the following criteria: 

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

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

or other specified plant or site characteristics. 

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

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

high-level waste and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required in this supplemental environmental impact statement (SEIS) unless new and significant 

information is identified. 

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

therefore, additional plant-specific review of these issues is required. 

License renewal actions may require refurbishment activities for the extended plant life. These 

actions may have an impact on the environment that requires evaluation, depending on the type 

of action and the plant-specific design. Environmental issues associated with refurbishment, 

which were determined to be Category 1 issues, are listed in Table 3-1. 

Environmental issues related to refurbishment considered in the GEIS for which these 

conclusions could not be reached for all plants, or for specific classes of plants, are Category 2 

issues. These are listed in Table 3-2. 

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 33 3-2 August 2008 

Table 3-1. Category 1 Issues for Refurbishment Evaluation

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Impacts of refurbishment on surface water quality 3.4.1 

Impacts of refurbishment on surface water use 3.4.1 

AQUATIC ECOLOGY (FOR ALL PLANTS)

Impacts of refurbishment on aquatic biota 3.5 

GROUND-WATER USE AND QUALITY

Impacts of refurbishment on ground-water use and quality 3.4.2 

LAND USE

Impacts of refurbishment on Onsite land use 3.2 

HUMAN HEALTH

Radiation exposures to the public during refurbishment 3.8.1 

Occupational radiation exposures during refurbishment 3.8.2 

SOCIOECONOMICS

Public services: public safety, social services, and tourism and 

recreation 

3.7.4; 3.7.4.3;

3.7.4.4; 3.7.4.6 

Aesthetic impacts (refurbishment) 3.7.8 

Category 1 and Category 2 issues related to refurbishment that are not applicable to Shearon 

Harris Nuclear Power Plant, Unit 1 (HNP) because they are related to plant design features or 

site characteristics not found at the HPN site are listed in Appendix F. 

The potential environmental effects of refurbishment actions would be identified, and the 

analysis would be summarized within this section, if such actions were planned. Carolina 

Power and Light Company (CP&L) indicated that it has performed an evaluation of systems, 

structures, and components pursuant to Section 54.21 of Title 10 of the Code of Federal 

Regulations (10 CFR 54.21) to identify the need to undertake any major refurbishment activities 

that are necessary to support continued operation of HNP during the requested 20-year period 

of extended operation. Items that are subject to aging and might require refurbishment to 

support continued operation during the renewal period are listed in Table B.2 of the GEIS. 
 Environmental Impacts of Refurbishment 

August 2008 3-3 NUREG-1437, Supplement 33 

Table 3-2. Category 2 Issues for Refurbishment Evaluation

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 

GEIS

Sections

10 CFR 51.53

(c)(3)(ii)

Subparagraph

TERRESTRIAL RESOURCES

Impacts of refurbishment on terrestrial ecology 3.6 E 

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 3.9 E 

AIR QUALITY

Air quality during refurbishment (nonattainment and 

maintenance areas) 

3.3 F 

SOCIOECONOMICS

Housing impacts 3.7.2 I 

Public services: public utilities 3.7.4.5 I 

Public services: education (refurbishment) 3.7.4.1 I 

Offsite land use (refurbishment) 3.7.5 I 

Public services, transportation 3.7.4.2 J 

Historic and archaeological resources 3.7.7 K 

ENVIRONMENTAL JUSTICE

Environmental justice Not addressed(a) Not addressed(a)

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated 

revision to 10 CFR Part 51 were prepared. If an applicant plans to undertake refurbishment activities for 

license renewal, environmental justice must be addressed in the applicant’s environmental report and the 

NRC staff’s environmental impact statement. 

CP&L’s evaluation of systems, structures, and components as required by 10 CFR 54.21 did not 

identified the need to undertake any major refurbishment or replacement actions associated 

with license renewal to support the continued operation of HNP beyond the end of the existing 

operating license. Therefore, refurbishment is not considered in this SEIS. 

3.1 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 33 3-4 August 2008 

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

Renewal of Operating Licenses for Nuclear Power Plants.” 

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Office of Nuclear 

Regulatory Research, Washington, D.C. 

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

for License Renewal of Nuclear Plant. NUREG-1437, Volume 1, Addendum 1. Office of 

Nuclear Reactor Regulation, Washington, D.C. 
August 2008 4-1 NUREG-1437, Supplement 33 

4.0 ENVIRONMENTAL IMPACTS OF OPERATION 

Environmental issues associated with operation of a nuclear power plant during the renewal 

term are discussed in the Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(1) The GEIS 

includes a determination of whether the analysis of the environmental issues could be applied to 

all plants and whether additional mitigation measures would be warranted. Issues are then 

assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues 

are those that meet all of the following criteria: 

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

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

or other specified plant or site characteristics. 

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

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

high-level waste and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required unless new and significant information is identified. 

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

therefore, additional plant-specific review of these issues is required. 

This chapter addresses the issues related to operation during the renewal term that are listed in 

Table B-1 of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51), Subpart A, 

Appendix B and are applicable to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP). 

Section 4.1 addresses issues applicable to the HNP cooling system. Section 4.2 addresses 

issues related to transmission lines and onsite land use. Section 4.3 addresses the radiological 

impacts of normal operation, and Section 4.4 addresses issues related to the socioeconomic 

impacts of normal operation during the renewal term. Section 4.5 addresses issues related to 

groundwater use and quality, while Section 4.6 discusses the impacts of renewal-term operations 

on threatened and endangered species. Section 4.7 addresses potential new information that 

was raised during the scoping period, and Section 4.8 discusses cumulative impacts. The results 

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-2 August 2008 

of the evaluation of environmental issues related to operation during the renewal term are 

summarized in Section 4.9. Finally, Section 4.10 lists the references for Chapter 4. Category 1 

and Category 2 issues that are not applicable to HNP because they are related to plant-design 

features or site characteristics not found at HNP are listed in Appendix F. 

4.1 Cooling System

Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B that are applicable to 

the HNP cooling system operation during the renewal term are listed in Table 4-1. Progress 

Energy stated in its Environmental Report (ER) that it is not aware of any new and significant 

information associated with the license renewal of HNP. The U.S. Nuclear Regulatory 

Commission (NRC) staff has not identified any new and significant information during its 

independent review of the Progress Energy ER (Progress Energy 2006b), the site audit, the 

scoping process and its evaluation of other available information and public comments on the 

draft SEIS. Therefore, the NRC staff concludes that there would be no impacts related to these 

issues beyond those discussed in the GEIS. For all of the issues, the NRC staff concluded in 

the GEIS that the impacts would be SMALL, and additional plant-specific mitigation measures 

are not likely to be sufficiently beneficial to be warranted. 

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1, 

for each of these issues follows: 

Table 4-1. Category 1 Issues Applicable to the Operation of the HNP Cooling 

System During the Renewal Term 

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 

SURFACE-WATER QUALITY, HYDROLOGY, AND USE

Altered current patterns at intake and discharge structures 4.2.1.2.1 

Altered thermal stratification of lakes 4.2.1.2.3 

Temperature effects on sediment transport capacity 4.2.1.2.3 

Scouring caused by discharged cooling water 4.2.1.2.3 

Eutrophication 4.2.1.2.3 

Discharge of chlorine or other biocides 4.2.1.2.4 

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 

Discharge of other metals in wastewater 4.2.1.2.4 
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August 2008 4-3 NUREG-1437, Supplement 33 

AQUATIC ECOLOGY

Accumulation of contaminants in sediments or biota 4.2.1.2.4 

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 

Cold shock 4.2.2.1.5

Thermal plume barrier to migrating fish 4.2.2.1.6 

Distribution of aquatic organisms 4.2.2.1.6 

Premature emergence of aquatic insects 4.2.2.1.7 

Gas supersaturation (gas bubble disease) 4.2.2.1.8 

Low dissolved oxygen in the discharge 4.2.2.1.9 

Losses from predation, parasitism, and disease among organisms exposed to 

sublethal stresses 

4.2.2.1.10

Stimulation of nuisance organisms 4.2.2.1.11 

AQUATIC ECOLOGY (PLANTS WITH COOLING-TOWER-BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life stages 4.3.3 

Impingement of fish and shellfish 4.3.3 

Heat shock 4.3.3

TERRESTRIAL RESOURCES

Cooling-tower impacts on crops and ornamental vegetation 4.3.4 

Cooling-tower impacts on native plants 4.3.5.1 

Bird collisions with cooling towers 4.3.5.2 

HUMAN HEALTH

Microbiological organisms (occupational health) 4.3.6 

Noise 4.3.7

• Altered current patterns at intake and discharge structures. Based on information in the 

GEIS, the Commission found that 

Altered current patterns have not been found to be a problem at operating 

nuclear power plants and are not expected to be a problem during the license 

renewal term. 

The NRC staff has not identified any new and significant information during its review of the

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-4 August 2008 

there would be no impacts of altered current patterns at intake and discharge structures 

during the renewal term beyond those discussed in the GEIS. 

• Altered thermal stratification of lakes. Based on information in the GEIS, the Commission 

found that 

Generally, lake stratification has not been found to be a problem at operating 

nuclear power plants and is not expected to be a problem during the license 

renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of altered thermal stratification of lakes during the renewal term 

beyond those discussed in the GEIS. 

• Temperature effects on sediment transport capacity. Based on information in the GEIS, the 

Commission found that 

These effects have not been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of temperature effects on sediment transport capacity during the 

renewal term beyond those discussed in the GEIS. 

• Scouring caused by discharged cooling water. Based on information in the GEIS, the 

Commission found that 

Scouring has not been found to be a problem at most operating nuclear power 

plants and has caused only localized effects at a few plants. It is not expected to 

be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of scouring caused by discharged cooling water during the 

renewal term beyond those discussed in the GEIS. 
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August 2008 4-5 NUREG-1437, Supplement 33 

• Eutrophication. Based on information in the GEIS, the Commission found that 

Eutrophication has not been found to be a problem at operating nuclear power 

plants and is not expected to be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information including plant monitoring data and technical reports and public comments on 

the draft SEIS. Therefore, the NRC staff concludes there would be no impacts of 

eutrophication during the renewal term beyond those discussed in the GEIS. 

• Discharge of chlorine or other biocides. Based on information in the GEIS, the Commission 

found that 

Effects are not a concern among regulatory and resource agencies, and are not 

expected to be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of discharge of chlorine or other biocides during the renewal term 

beyond those discussed in the GEIS. 

• Discharge of sanitary wastes and minor chemical spills. Based on information in the GEIS, 

the Commission found that 

Effects are readily controlled through [National Pollutant Discharge Elimination 

System] NPDES permit and periodic modifications, if needed, and are not 

expected to be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of discharges of sanitary wastes and minor chemical spills during 

the renewal term beyond those discussed in the GEIS. 

• Discharge of other metals in wastewater. Based on information in the GEIS, the 

Commission found that 

These discharges have not been found to be a problem at operating nuclear 

power plants with cooling-tower-based heat dissipation systems and have been 

satisfactorily mitigated at other plants. They are not expected to be a problem 

during the license renewal term. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-6 August 2008 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of discharges of other metals in wastewater during the renewal 

term beyond those discussed in the GEIS. 

• Accumulation of contaminants in sediments or biota. Based on information in the GEIS, the 

Commission found that 

Accumulation of contaminants has been a concern at a few nuclear power plants 

but has been satisfactorily mitigated by replacing copper alloy condenser tubes 

with those of another metal. It is not expected to be a problem during the license 

renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of available information and 

public comments on the draft SEIS. Therefore, the NRC staff concludes there would be no 

impacts of accumulation of contaminants in sediments or biota during the renewal term 

beyond those discussed in the GEIS. 

• Entrainment of phytoplankton and zooplankton. Based on information in the GEIS, the 

Commission found that 

Entrainment of phytoplankton and zooplankton has not been found to be a 

problem at operating nuclear power plants and is not expected to be a problem 

during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, the review of monitoring programs, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes there would be no impacts of entrainment of phytoplankton and 

zooplankton during the renewal term beyond those discussed in the GEIS. 

• Cold shock. Based on information in the GEIS, the Commission found that 

Cold shock has been satisfactorily mitigated at operating nuclear plants with 

once-through cooling systems, has not endangered fish populations or been 

found to be a problem at operating nuclear power plants with cooling towers or 

cooling ponds, and is not expected to be a problem during the license renewal 

term.

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 
 Environmental Impacts of Operation 

August 2008 4-7 NUREG-1437, Supplement 33 

there would be no impacts of cold shock during the renewal term beyond those discussed in 

the GEIS. 

• Thermal plume barrier to migrating fish. Based on information in the GEIS, the Commission 

found that 

Thermal plumes have not been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of thermal plume barriers on migrating fish during the renewal 

term beyond those discussed in the GEIS. 

• Distribution of aquatic organisms. Based on information in the GEIS, the Commission found 

that

Thermal discharge may have localized effects but is not expected to affect the 

larger geographical distribution of aquatic organisms. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, the review of monitoring programs, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes there would be no impacts on distribution of aquatic organisms 

during the renewal term beyond those discussed in the GEIS. 

• Premature emergence of aquatic insects. Based on information in the GEIS, the 

Commission found that 

Premature emergence has been found to be a localized effect at some operating 

nuclear power plants but has not been a problem and is not expected to be a 

problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of premature emergence of aquatic insects during the renewal 

term beyond those discussed in the GEIS. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-8 August 2008 

• Gas supersaturation (gas bubble disease). Based on information in the GEIS, the 

Commission found that 

Gas supersaturation was a concern at a small number of operating nuclear 

power plants with once-through cooling systems but has been satisfactorily 

mitigated. It has not been found to be a problem at operating nuclear power 

plants with cooling towers or cooling ponds and is not expected to be a problem 

during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of gas supersaturation during the renewal term beyond those 

discussed in the GEIS. 

• Low dissolved oxygen in the discharge. Based on information in the GEIS, the Commission 

found that 

Low dissolved oxygen has been a concern at one nuclear power plant with a 

once-through cooling system but has been effectively mitigated. It has not been 

found to be a problem at operating nuclear power plants with cooling towers or 

cooling ponds and is not expected to be a problem during the license renewal 

term.

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, the review of monitoring programs, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes there would be no impacts of low dissolved oxygen during the 

renewal term beyond those discussed in the GEIS. 

• Losses from predation, parasitism, and disease among organisms exposed to sublethal 

stresses. Based on information in the GEIS, the Commission found that 

These types of losses have not been found to be a problem at operating nuclear 

power plants and are not expected to be a problem during the license renewal 

term.

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of losses from predation, parasitism, and disease among 

organisms exposed to sublethal stresses during the renewal term beyond those discussed 

in the GEIS. 
 Environmental Impacts of Operation 

August 2008 4-9 NUREG-1437, Supplement 33 

• Stimulation of nuisance organisms. Based on information in the GEIS, the Commission 

found that 

Stimulation of nuisance organisms has been satisfactorily mitigated at the single 

nuclear power plant with a once-through cooling system where previously it was 

a problem. It has not been found to be a problem at operating nuclear power 

plants with cooling towers or cooling ponds and is not expected to be a problem 

during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of stimulation of nuisance organisms during the renewal term 

beyond those discussed in the GEIS. 

• Entrainment of fish and shellfish in early life stages (cooling-tower-based heat dissipation).

Based on information in the GEIS, the Commission found that 

Entrainment of fish has not been found to be a problem at operating nuclear 

power plants with this type of cooling system and is not expected to be a problem 

during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of entrainment of fish and shellfish in early life stages for coolingtower-based systems during the renewal term beyond those discussed in the GEIS. 

• Impingement of fish and shellfish (cooling-tower-based heat dissipation). Based on 

information in the GEIS, the Commission found that 

The impingement has not been found to be a problem at operating nuclear power 

plants with this type of cooling system and is not expected to be a problem during 

the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of impingement of fish and shellfish for cooling-tower-based 

systems during the renewal term beyond those discussed in the GEIS. 
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NUREG-1437, Supplement 33 4-10 August 2008 

• Heat shock (cooling-tower-based heat dissipation). Based on information in the GEIS, the 

Commission found that 

Heat shock has not been found to be a problem at operating nuclear power 

plants with this type of cooling system and is not expected to be a problem during 

the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of heat shock for cooling-tower-based systems during the 

renewal term beyond those discussed in the GEIS. 

• Cooling-tower impacts on crops and ornamental vegetation. Based on information in the 

GEIS, the Commission found that 

Impacts from salt drift, icing, fogging, or increased humidity associated with 

cooling-tower operation have not been found to be a problem at operating 

nuclear power plants and are not expected to be a problem during the renewal 

term.

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no cooling-tower impacts on crops and ornamental vegetation during the 

renewal term beyond those discussed in the GEIS. 

• Cooling-tower impacts on native vegetation. Based on information in the GEIS, the 

Commission found that 

Impacts from salt drift, icing, fogging, or increased humidity associated with 

cooling-tower operation have not been found to be a problem at operating 

nuclear power plants and are not expected to be a problem during the renewal 

term.

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no cooling-tower impacts on native vegetation during the renewal term 

beyond those discussed in the GEIS. 
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August 2008 4-11 NUREG-1437, Supplement 33 

• Bird collisions with cooling towers. Based on information in the GEIS, the Commission 

found that 

These collisions have not been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of bird collisions with cooling towers during the renewal term 

beyond those discussed in the GEIS. 

• Microbiological organisms (occupational health). Based on information in the GEIS, the 

Commission found that 

Occupational health impacts are expected to be controlled by continued 

application of accepted industrial hygiene practices to minimize worker 

exposures.

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of microbiological organisms during the renewal term beyond 

those discussed in the GEIS. 

• Noise. Based on information in the GEIS, the Commission found that 

Noise has not been found to be a problem at operating plants and is not 

expected to be a problem at any plant during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of noise during the renewal term beyond those discussed in the 

GEIS.

There are no Category 2 issues related to cooling system operation during the renewal term 

that are applicable to HNP. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-12 August 2008 

4.2 Transmission Lines

The transmission lines and right-of-way (ROW) maintenance are described in Section 2.1.7 of 

this supplemental environmental impact statement (SEIS). The transmission lines connect to 

five substations: Siler City, Erwin, Wake, Apex, and Fort Bragg-Woodruff Street and to one 

power plant, the Cape Fear Plant. The seven transmission lines total 229 km (142 mi) in length 

and their ROW occupy 695 ha (1717 ac) (Progress Energy 2006b).

Progress Energy controls vegetation in transmission line ROWs using an Integrated Vegetation 

Management approach, which includes both mechanical and chemical maintenance methods. 

Procedures are in place to ensure protection of terrestrial and aquatic resources, as well as 

protection against human exposure to herbicides and pesticides. 

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 

the HNP transmission lines are listed in Table 4-2. Progress Energy stated in its Environmental 

Report (ER) that it is not aware of any new and significant information associated with the 

renewal of the HNP operating license (Progress Energy 2006b). The NRC staff has not 

identified any new and significant information during its independent review of the Progress 

Energy ER, the site audit, the scoping process, and its evaluation of other information and 

public comments on the draft SEIS. Therefore, the NRC staff concludes that there would be no 

impacts related to these issues beyond those discussed in the GEIS (NRC 1996). For all those 

issues, the NRC staff concluded in the GEIS that the impacts would be SMALL, and additional 

plant-specific mitigation measures are not likely to be sufficiently beneficial to warrant 

implementation.

Table 4-2. Category 1 Issues Applicable to the Shearon Harris Nuclear Power Plant 

Transmission Lines During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

TERRESTRIAL RESOURCES

Power line right-of-way management (cutting and herbicide application) 4.5.6.1 

Bird collisions with power lines 4.5.6.2 

Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, 

honeybees, wildlife, livestock) 

4.5.6.3

Floodplains and wetland on power line right of way 4.5.7 

AIR QUALITY

Air quality effects of transmission lines 4.5.2 

LAND USE

Onsite land use 4.5.3

Power line right-of-way 4.5.3 
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August 2008 4-13 NUREG-1437, Supplement 33 

A brief description of the staff's review and GEIS conclusions, as codified in Table B-1, for each 

of these issues follows: 

• Power line right-of-way management (cutting and herbicide application). Based on 

information in the GEIS, the Commission found that 

The impacts of right-of-way maintenance on wildlife are expected to be of small 

significance at all sites. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of power line ROW maintenance during the renewal term beyond 

those discussed in the GEIS. 

• Bird collisions with power lines. Based on information in the GEIS, the Commission found 

that

Impacts are expected to be of small significance at all sites. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of bird collisions with power lines during the renewal term beyond 

those discussed in the GEIS. 

• Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, 

wildlife, livestock). Based on information in the GEIS, the Commission found that 

No significant impacts of electromagnetic fields on terrestrial flora and fauna 

have been identified. Such effects are not expected to be a problem during the 

license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of electromagnetic fields on flora and fauna during the renewal 

term beyond those discussed in the GEIS. 

• Floodplains and wetland on power line right-of-way. Based on information in the GEIS, the 

Commission found that 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-14 August 2008 

Periodic vegetation control is necessary in forested wetlands underneath power 

lines and can be achieved with minimal damage to the wetland. No significant 

impact is expected at any nuclear power plant during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of power line ROW on floodplains and wetlands during the 

renewal term beyond those discussed in the GEIS. 

• Air quality effects of transmission lines. Based on the information in the GEIS, the 

Commission found that 

Production of ozone and oxides of nitrogen is insignificant and does not 

contribute measurably to ambient levels of these gases. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of air quality effects of transmission lines during the renewal term 

beyond those discussed in the GEIS. 

• Onsite land use. Based on the information in the GEIS, the Commission found that 

Projected onsite land use changes required during ... the renewal period would 

be a small fraction of any nuclear power plant site and would involve land that is 

controlled by the applicant. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of onsite land use during the renewal term beyond those 

discussed in the GEIS. 

• Power line right-of-way. Based on information in the GEIS, the Commission found that 

Ongoing use of power line right-of-ways would continue with no change in 

restrictions. The effects of these restrictions are of small significance. 

The NRC staff has not identified any new and significant information during its review of the 

Progress Energy ER, the site audit, the scoping process, and its evaluation of other 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there would be no impacts of power line ROWs during the renewal term beyond those 

discussed in the GEIS. 
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August 2008 4-15 NUREG-1437, Supplement 33 

The NRC staff has identified one Category 2 issue and one uncategorized issue related to 

transmission lines. These issues are listed in Table 4-3 and are discussed in Sections 4.2.1 

and 4.2.2. 

Table 4-3. Category 2 and Uncategorized Issues Applicable to the Shearon Harris Nuclear 

Power Plant Transmission Lines During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 

GEIS

Section

10 CFR 

51.53(c)(3)(ii) 

Subparagraph 

SEIS

Section

HUMAN HEALTH

Electromagnetic fields, acute effects 

(electric shock) 

4.5.4.1 H 4.2.1 

Electromagnetic fields, chronic effects 4.5.4.2 NA 4.2.2 

4.2.1 Electromagnetic Fields – Acute Effects 

Based on the GEIS, the Commission found that electric shock resulting from direct access to 

energized conductors or from induced charges in metallic structures has not been found to be a 

problem at most operating plants and generally is not expected to be a problem during the 

license renewal term. However, site-specific review is required to determine the significance of 

the electric shock potential along the portions of the transmission lines that are within the scope 

of this SEIS. 

In the GEIS (NRC 1999), the NRC staff found that without a review of the conformance of each 

nuclear plant transmission line with National Electrical Safety Code (NESC; IEEE 1997) criteria, 

it was not possible to determine the significance of the electric shock potential. Evaluation of 

individual plant transmission lines is necessary because the issue of electric shock safety was 

not addressed in the licensing process for some plants. For other plants, land use in the vicinity 

of transmission lines may have changed, or power distribution companies may have chosen to 

upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an 

assessment of the potential shock hazard if the transmission lines that were constructed for the 

specific purpose of connecting the plant to the transmission system do not meet the 

recommendations of the NESC for preventing electric shock from induced currents. 

CP&L designed and constructed all HNP transmission lines in accordance with industry 

guidance that was current when the lines were built. Ongoing surveillance and maintenance of 

HNP-related transmission facilities ensure continued conformance to design standards 

(Progress Energy 2006b). In the current configuration of the transmission system, seven 

230-kV transmission lines connect HNP to the regional grid. All lines emanating from HNP were 

designed, constructed, and are operated in compliance with the applicable sections of the 

NESC, including the most recent edition. These lines generally run through 100-foot-wide 
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NUREG-1437, Supplement 33 4-16 August 2008 

corridors, but in some areas, such as the area immediately south of HNP, corridors are as wide 

as 350 feet (Progress Energy 2006b). These lines meet the requirements that have been in 

effect since 1977 when the NESC adopted a provision that became part of the NESC Code for 

lines exceeding 98 kV alternating current to ground; this provision limits "the steady state 

current due to electrostatic effects to 5 mA if the largest anticipated truck, vehicle or equipment 

under the line were short-circuited to ground" (Progress Energy 2006b). This current is induced 

in vehicles by the transmission line electric field and is proportional to the voltage of the line and 

inversely proportional to the distance from the line. 

By using a computer code called ACDCLINE (Rev. 3.0) that was produced by the Electric 

Power Research Institute (Progress Energy 2006b), Progress Energy calculated electric field 

strength and induced current that is produced by its transmission lines. The results of this 

computer program have been field-verified through electrostatic field measurements by several 

utilities. Input parameters included the design features of the limiting-case scenario, the NESC 

requirement that line sag be determined at 120oF conductor temperature, and the maximum 

vehicle size under the lines as a tractor-trailer. 

The analysis determined that none of the transmission lines has the capacity to induce as much 

as 5 mA in a vehicle parked beneath the lines. The calculated induced currents ranged from 1.1 

to 3.1 mA (Progress Energy 2006b), but in reality, the induced currents would be lower because 

the calculations were performed with the conservative assumption that the line sag was 

determined at 212oF conductor temperature, instead of at the required 120oF. 

In the GEIS (NRC 1999), the NRC staff found that electrical shock is of SMALL significance for 

transmission lines that are operated in adherence with the NESC criteria for limiting hazards. 

The NRC staff identified potential mitigation measures, including installing road signs at road 

crossings and increased clearances. Based on a review of the available information, including 

that provided in the ER (Progress Energy 2006b), the NRC staff’s site audit, the scoping 

process, and its evaluation of other information and public comments on the draft SEIS, the staff 

concludes that the potential impacts for electric shock during the renewal term are SMALL. 

4.2.2 Electromagnetic Fields – Chronic Effects 

In the GEIS, the chronic effects of 60-Hz electromagnetic fields from power lines were not 

designated as Category 1 or 2, and will not be until a scientific consensus is reached on the 

health implications of these fields. 

The potential for chronic effects from these fields continues to be studied and is not known at 

this time. The National Institute of Environmental Health Sciences (NIEHS) directs related 

research through the U.S. Department of Energy (DOE). A NIEHS report (NIEHS 1999) 

contains the following conclusion: 
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August 2008 4-17 NUREG-1437, Supplement 33 

The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic 

field] exposure cannot be recognized as entirely safe because of weak scientific 

evidence that exposure may pose a leukemia hazard. In our opinion, this finding 

is insufficient to warrant aggressive regulatory concern. However, because 

virtually everyone in the United States uses electricity and therefore is routinely 

exposed to ELF-EMF, passive regulatory action is warranted such as a continued 

emphasis on educating both the public and the regulated community on means 

aimed at reducing exposures. The NIEHS does not believe that other cancers or 

non-cancer health outcomes provide sufficient evidence of a risk to currently 

warrant concern. 

This statement is not sufficient to cause the NRC staff to change its position with respect to the 

chronic effects of electromagnetic fields. Footnote 4 to Table B-1 states: 

If in the future, the Commission finds that, contrary to current indications, a 

consensus has been reached by appropriate Federal health agencies that there 

are adverse health effects from electromagnetic fields, the Commission will 

require applicants to submit plant-specific reviews of those health effects as part 

of their license renewal applications. Until such time, applicants for license 

renewal are not required to submit information on this issue. 

The staff considers the GEIS finding of “Uncertain” still appropriate and will continue to follow 

developments on this issue. 

4.3 Radiological Impacts of Normal Operations

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to 

HNP in regard to radiological impacts are listed in Table 4-4. Progress Energy stated in its ER 

that it is not aware of any new and significant information associated with the license renewal of 

HNP. The NRC staff has not identified any new and significant information during its review of 

the HNP ER (Progress Energy 2006b), the site audit, the scoping process, and its evaluation of 

other available information and public comments on the draft SEIS. Therefore, the NRC staff 

concludes there are no impacts related to these issues beyond those discussed in the GEIS. 

For these issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and 

additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be 

warranted.
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NUREG-1437, Supplement 33 4-18 August 2008 

Table 4-4. Category 1 Issues Applicable to Radiological Impacts of Normal 

Operations During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

HUMAN HEALTH

Radiation exposures to public (license renewal term) 4.6.2 

Occupational radiation exposures (license renewal term) 4.6.3 

A brief description of the staff’s review and the GEIS conclusions, as codified in Table B-1, for 

each of these issues follows: 

• Radiation exposures to public (license renewal term). Based on information in the GEIS, the 

Commission found that 

Radiation doses to the public will continue at current levels associated with 

normal operations. 

The NRC staff has not identified any new and significant information during its review of the

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there are no impacts of radiation exposures to the public during the renewal term beyond 

those discussed in the GEIS. 

• Occupational radiation exposures (license renewal term). Based on information in the 

GEIS, the Commission found that 

Projected maximum occupational doses during the license renewal term are 

within the range of doses experienced during normal operations and normal 

maintenance outages, and would be well below regulatory limits. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there are no impacts of occupational radiation exposures during the renewal term beyond 

those discussed in the GEIS. 

There are no Category 2 issues related to radiological impacts of routine operations. 
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August 2008 4-19 NUREG-1437, Supplement 33 

4.4 Socioeconomic Impacts of Plant Operations During the License Renewal 

Term

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B–1 that are applicable to 

socioeconomic impacts during the renewal term are listed in Table 4–5. As stated in the GEIS, 

the impacts associated with these Category 1 issues were determined to be SMALL, and plantspecific mitigation measures would not be sufficiently beneficial to be warranted. 

The NRC staff reviewed and evaluated the HNP ER (Progress Energy 2006b), scoping 

comments, other available information, and visited the HNP site in search of new and significant 

information that would change the conclusions presented in the GEIS. No new and significant 

information was identified during this review. Therefore, it is expected that there would be no 

impacts related to these Category 1 issues during the renewal term beyond those discussed in 

the GEIS. 

Table 4–5. Category 1 Issues Applicable to Socioeconomics During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

SOCIOECONOMICS

Public services: public safety, social services, and tourism and 

recreation 

4.7.3; 4.7.3.3; 

4.7.3.4; 4.7.3.6 

Public services: education (license renewal term) 4.7.3.1 

Aesthetic impacts (license renewal term) 4.7.6 

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1, 

for each of these issues follows: 

• Public services: public safety, social services, and tourism and recreation. Based on 

information in the GEIS, the Commission found that 

Impacts to public safety, social services, and tourism and recreation are 

expected to be of small significance at all sites. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there are no impacts on public safety, social services, and tourism and recreation during the 

renewal term beyond those discussed in the GEIS. 
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NUREG-1437, Supplement 33 4-20 August 2008 

• Public services: education (license renewal term). Based on information in the GEIS, the 

Commission found that 

Only impacts of small significance are expected. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there are no impacts on education during the renewal term beyond those discussed in the 

GEIS.

• Aesthetic impacts (license renewal term). Based on information in the GEIS, the 

Commission found that 

No significant impacts are expected during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there are no aesthetic impacts during the renewal term beyond those discussed in the GEIS. 

• Aesthetic impacts of transmission lines (license renewal term). Based on information in the 

GEIS, the Commission found that 

No significant impacts are expected during the license renewal term. 

The NRC staff has not identified any new and significant information during its review of the 

HNP ER, the site audit, the scoping process, and its evaluation of other available 

information and public comments on the draft SEIS. Therefore, the NRC staff concludes 

there are no aesthetic impacts of transmission lines during the renewal term beyond those 

discussed in the GEIS. 

Table 4–6 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and 

environmental justice, which was not addressed in the GEIS. 
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August 2008 4-21 NUREG-1437, Supplement 33 

Table 4–6. Category 2 Issues Applicable to Socioeconomics 

and Environmental Justice During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 GEIS Section 

10 CFR 

51.53(c)(3)(ii) 

Subparagraph 

SEIS

Section

SOCIOECONOMICS

Housing impacts 4.7.1 I 4.4.1 

Public services: public utilities 4.7.3.5 I 4.4.2 

Offsite land use (license renewal term) 4.7.4 I 4.4.3 

Public services: transportation 4.7.3.2 J 4.4.4 

Historic and archaeological resources 4.7.7 K 4.4.5 

Environmental justice Not addressed(a) Not addressed(a) 4.4.6 

(a) Guidance related to environmental justice was not in place at the time the GEIS and the 

associated revision to 10 CFR Part 51 were prepared. Therefore, environmental justice must be 

addressed in plant-specific reviews. 

4.4.1 Housing Impacts 

Appendix C of the GEIS presents a population characterization method based on two factors, 

sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 

within 32 km (20 mi) of the site, and proximity measures population density and city size within 

80 km (50 mi). Each factor has categories of density and size (GEIS, Table C.1). A matrix is 

used to rank the population category as low, medium, or high (GEIS, Figure C.1). 

According to the 2000 census, approximately 438,969 people lived within 32 km (20 mi) of HNP, 

which equates to a population density of 349 persons per square mile (Progress Energy 2006b). 

This density translates to the least sparse Category 4 (greater than or equal to 120 persons per 

square mile within 20 miles). Approximately 2,035,797 people live within 80 km (50 mi) of HNP 

(Progress Energy 2006b). This equates to a population density of 259 persons per square mile. 

Applying the GEIS proximity measures, HNP is classified as proximity Category 4 (greater than 

or equal to 190 persons per square mile within 50 miles). Therefore, according to the 

sparseness and proximity matrix presented in the GEIS, the HNP ranks of sparseness 

Category 4 and proximity Category 4 result in the conclusion that HNP is located in a high 

population area. 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 

are expected to be of small significance in medium or high-density population areas where 

growth-control measures are not in effect. Since HNP is located in a high population area and 

Wake and Lee counties are not subject to growth-control measures that would limit housing 
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NUREG-1437, Supplement 33 4-22 August 2008 

development, any HNP employment-related impact on housing availability would likely be small. 

Since CP&L has indicated that there would be no major plant refurbishment and no non-outage 

employees would be added to support HNP operations during the license renewal term, 

employment levels at HNP would remain relatively constant with no additional demand for 

housing during the license renewal term. In addition, the number of available housing units has 

kept pace with or exceeded the low growth in the area population. Based on this information, 

there would be no impact on housing during the license renewal term and mitigation measures 

need not be considered. 

4.4.2 Public Services: Public Utility Impacts 

Impacts on public utility services are considered SMALL if there is little or no change in the 

ability of the system to respond to demand and thus there is no need to add capital facilities. 

Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak 

demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially 

degraded and additional capacity is needed to meet ongoing demand. The GEIS indicated that, 

in the absence of new and significant information to the contrary, the only impacts on public 

utilities that could be significant are impacts on public water supplies. 

Analysis of impacts on the public water and sewer systems considered both plant demand and 

plant-related population growth. Section 2.2.2 of this SEIS describes the HNP permitted 

withdrawal rate and actual use of water. 

As discussed in Section 2.2.8.2, HNP does not use water provided by any outside public water 

source. HNP is registered with the State of North Carolina as a user of water from Harris 

Reservoir for process, service, and domestic use, and provides onsite treatment for sanitary and 

process water and discharges effluent to Harris Reservoir under National Pollutant Discharge 

Elimination System (NPDES) permit requirements. CP&L has identified no operational changes 

during the HNP license renewal term that would alter the plant water use source. Water usage 

by HNP has not stressed system capacity and is not currently an issue. CP&L also has no 

plans to increase HNP staffing due to refurbishment or plant aging management activities, and 

has identified no operational changes during the license renewal term that would increase plant 

water use. 

HNP operations during the license renewal term would not increase plant-related population 

demand for public water and sewer services. Since CP&L has indicated that there would be no 

major plant refurbishment, overall employment levels at HNP would remain relatively constant 

during this period with no additional demand for public services. In addition, both public and 

private water systems in the region would be adequate to provide the capacity and to meet the 

demand of residential and industrial customers in the area. Because HNP has no groundwater 

production wells and obtains no drinking water from public water suppliers, it has no effect on 

local or regional public drinking water supply capacities. Similarly, HNP treats its own sanitary 

and process wastes and has no effect on the capacities or availability of local or regional 
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August 2008 4-23 NUREG-1437, Supplement 33 

sewage treatment facilities. Therefore, there would be no impact to public water and sewer 

services during the license renewal term, and mitigation measures need not be considered. 

4.4.3 Offsite Land Use – License Renewal Period 

Offsite land use during the license renewal term is a Category 2 issue (10 CFR 51, Subpart A, 

Appendix B, Table B-1). Table B-1 of 10 CFR 51 Subpart A, Appendix B notes that "significant 

changes in land use may be associated with population and tax revenue changes resulting from 

license renewal." 

Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 

operation during the license renewal term as follows: 

SMALL - Little new development and minimal changes to an area's land-use pattern. 

MODERATE - Considerable new development and some changes to the land-use pattern. 

LARGE - Large-scale new development and major changes in the land-use pattern. 

Tax revenue can affect land use because it enables local jurisdictions to provide the public 

services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 

the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 

term should consider (1) the size of the plant’s payments relative to the community’s total 

revenues, (2) the nature of the community’s existing land-use pattern, and (3) the extent to 

which the community already has public services in place to support and guide development. If 

the plant’s tax payments are projected to be small relative to the community’s total revenue, taxdriven land-use changes during the plant’s license renewal term would be SMALL, especially 

where the community has pre-established patterns of development and has provided adequate 

public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax 

payments by the plant owner are less than 10 percent of the taxing jurisdiction’s revenue, the 

significance level would be SMALL. If the plant’s tax payments are projected to be medium to 

large relative to the community’s total revenue, new tax-driven land-use changes would be 

MODERATE. If the plant’s tax payments are projected to be a dominant source of the 

community’s total revenue, new tax-driven land-use changes would be LARGE. This would be 

especially true where the community has no pre-established pattern of development or has not 

provided adequate public services to support and guide development. 

4.4.3.1 Population-Related Impacts 

Since CP&L has no plans to add non-outage employees during the license renewal period, 

there would be no noticeable change in land use conditions in the vicinity of the HNP site. 

Therefore, there would be no land use impacts during the license renewal term and mitigation 

measures need not be considered. 
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NUREG-1437, Supplement 33 4-24 August 2008 

4.4.3.2 Tax-Revenue-Related Impacts 

CP&L and North Carolina Eastern Municipal Power Agency (NCEMPA) pay annual real estate 

taxes to both Wake and Chatham counties. From 2001 through 2005, CP&L and NCEMPA 

annually paid between $7.1 and $8.4 million and $1.8 and $2.1 million, respectively, in property 

taxes to Wake County. This represented between 1.9 and 2.6 percent and less than 1 percent, 

respectively, of the county’s annual total real and personal property tax revenues. Real and 

personal property tax revenues go into the county’s General Fund. The amount paid to 

Chatham County during this time period by CP&L ranged between $50,000 and $60,000 

annually, and NCEMPA paid between $40,000 and $50,000 annually. 

At present, the State of North Carolina has taken no action on deregulation, which could, if 

enacted, affect tax payments to both Wake and Chatham counties. However, any changes to 

HNP property tax rates due to deregulation would be independent of license renewal. 

Discontinuing the current level of tax revenues would have a significant negative economic 

impact on the county. 

CP&L has indicated that there would be no major plant refurbishment or license renewal-related 

construction activities necessary to support the continued operation of the HNP beyond the end 

of the existing operating license term during the license renewal period. Accordingly, there 

would be no increase in the assessed value of HNP and annual property taxes to Wake and 

Chatham counties would remain relatively constant throughout the license renewal period. 

Based on this information, there would be no tax revenue-related land-use impacts during the 

license-renewal term and mitigation measures need not be considered. 

4.4.4 Public Services: Transportation Impacts During Operations 

Table B-1, 10 CFR Part 51 states: 

Transportation impacts (level of service) of highway traffic generated... during the 

term of the renewed license are generally expected to be of small significance. 

However, the increase in traffic associated with additional workers and the local 

road and traffic control conditions may lead to impacts of moderate or large 

significance at some sites. 

All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic 

generated by the proposed project on the level of service of local highways during the term of 

the renewed license. 

Since CP&L has no plans to add non-outage employees during the license renewal period, 

there would be no noticeable change in traffic volume and levels of service on roadways in the 

vicinity of the HNP site. Therefore, there would be no transportation impacts during the license 

renewal term and mitigation measures need not be considered. 
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August 2008 4-25 NUREG-1437, Supplement 33 

4.4.5 Historic and Archaeological Resources 

The National Historic Preservation Act (NHPA) requires Federal agencies to take into account 

the potential effects of their undertakings on historic properties. The historic preservation review 

process mandated by Section 106 of the NHPA is outlined in regulations issued by the Advisory 

Council on Historic Preservation in 36 CFR Part 800. Renewal of an operating license for a 

nuclear power plant is an undertaking that could possibly affect either known or potential historic 

properties that may be located at the plant. Therefore, in accordance with the provisions of the 

NHPA, the NRC is required to make a reasonable effort to identify historic properties in the 

areas of potential effects. If no historic properties are present or affected, the NRC is required 

to notify the State Historic Preservation Office before proceeding. If it is determined that historic 

properties are present, the NRC is required to assess and resolve possible adverse effects of 

the undertaking. 

Archaeological sites, both historic and prehistoric in age, are recorded on lands associated with 

the HNP. In the 1970s, archaeologists conducted a survey of logging roads, farm trails, and 

other eroded locations in the area of the present day reservoir for the HNP (Ward 1978). That 

investigation documented 36 prehistoric and 1 historic site. The report concluded that the 

prehistoric sites were small and badly disturbed by plowing and erosion, and therefore, not 

significant. The one historic site was a twentieth century mill complex that was virtually 

destroyed. Physical traces of the mill site remain, and the report concluded that the site was not 

significant. By letters dated March 1978 and December 1979, the North Carolina Department of 

Cultural Resources concurred with the recommendations of the survey (NCDCR 1978, 1979). 

The files of the North Carolina Office of State Archaeology (NCOSA) document that in the 

1980s, as the reservoir was filling, avocational archaeologists recorded 13 additional sites 

around the reservoir. More recently, archaeologists completed a survey of approximately 70 ha 

(180 ac) of land where CP&L plans new construction that NRC will consider separately from the 

application to renew the HNP license (Patch 2006). The majority of the 70 ha (180 ac) survey 

area was disturbed by construction of the HNP in the 1970s; nevertheless investigators found 

two archaeological sites and three isolated finds. It was recommended that the sites did not 

meet the criteria for nomination to the National Register for Historic Places (Patch 2006). 

CP&L initiated communication with the North Carolina State Historic Preservation Office 

(SHPO) about the re-licensing in a letter dated November 2005 (HNP 2005). The letter 

requested comments on the proposed relicensing and stated CP&L’s conclusion that operation 

of HNP over the license renewal term would have no effect on any historic or archaeological 

properties. CP&L’s letter described the HNP site itself and seven transmission corridors as 

within the purview of the undertaking. A response by the SHPO in January 2006 stated, “We 

have conducted a review of the project and are aware of no historic resource that would be 

affected by the project...we have no comment on the project as proposed” (NCDCR 2006). 

In accordance with 36 CFR 800.8(c), the NRC contacted the North Carolina SHPO (NRC 

2007c), the Advisory Council on Historic Preservation (NRC 2007d), and the appropriate 
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NUREG-1437, Supplement 33 4-26 August 2008 

Federally recognized Native American Tribes with current and historic ties to the region. These 

letters are presented in Appendix E. No comments were received from the North Carolina 

SHPO or from Federally recognized tribes. 

The conditions at HNP require plans to protect archaeological sites from inadvertent disturbance 

or destruction. To avoid such adverse impacts, environmental review procedures have been 

put in place at HNP regarding undertakings that involve land disturbing construction or 

operational activities in undisturbed areas. CP&L has no plans to construct new facilities at 

HNP during the renewal term related to support license renewal (Progress Energy 2006b). 

However, because there is a strong potential for cultural resources to be present at the site, the 

applicant should take care during normal operations and maintenance activities to ensure 

consideration of cultural resources. 

Based on the NRC staff’s review of NCOSA files, archaeological reviews, surveys, 

assessments, and other information, the NRC staff concludes that the potential impacts of 

license renewal on historic and archaeological resources at HNP would be SMALL. This 

conclusion is based upon (1) no new ground disturbance or refurbishment activities would occur 

during the renewal period, and (2) the applicant understands that archaeological, historical, and 

other cultural resources could be present at the HNP site. Mitigation measures in the form of 

administrative controls are in place to ensure that, if cultural resources are found at HNP, they 

will be protected. The NRC staff determines that the impact of license renewal on cultural 

resources is SMALL. Current measures to mitigate potential impacts of plant operation on 

cultural resources are found to be adequate. 

4.4.6 Environmental Justice 

Under Executive Order 12898 (59 FR 7629), Federal agencies are responsible for identifying 

and addressing potential disproportionately high and adverse human health and environmental 

impacts on minority and low-income populations. Although the Executive Order is not 

mandatory for independent agencies such as the NRC, the NRC has voluntarily committed to 

undertake environmental justice reviews. In 2004, the Commission issued a Policy Statement 

on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions

(69 FR 52040), which states “The Commission is committed to the general goals set forth in 

E.O. 12898, and strives to meet those goals as part of its NEPA review process.” (NRC 2004c) 

The Council of Environmental Quality (CEQ) provides the following information in Environmental 

Justice: Guidance Under the National Environmental Policy Act (1997): 

Disproportionately High and Adverse Human Health Effects. Adverse health effects are 

measured in risks and rates that could result in latent cancer fatalities, as well as other fatal 

or nonfatal adverse impacts on human health. Adverse health effects may include bodily 

impairment, infirmity, illness, or death. Disproportionately high and adverse human health 

effects occur when the risk or rate of exposure to an environmental hazard for a minority or 
 Environmental Impacts of Operation 

August 2008 4-27 NUREG-1437, Supplement 33 

low-income population is significant (as defined by NEPA [National Environmental Policy 

Act]) and appreciably exceeds the risk or exposure rate for the general population or for 

another appropriate comparison group (CEQ 1997). 

Disproportionately High and Adverse Environmental Effects. A disproportionately high 

environmental impact that is significant (as defined by NEPA) refers to an impact or risk of 

an impact on the natural or physical environment in a low-income or minority community that 

appreciably exceeds the environmental impact on the larger community. Such effects may 

include ecological, cultural, human health, economic, or social impacts. An adverse 

environmental impact is an impact that is determined to be both harmful and significant (as 

defined by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that 

uniquely affect geographically dislocated or dispersed minority or low-income populations or 

American Indian tribes are considered (CEQ 1997). 

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority and low-income populations that 

could result from the operation of HNP during the renewal term. In assessing the impacts, the 

following CEQ (1997) definitions of minority individuals and populations and low-income 

population were used: 

• Minority individuals. Individuals who identify themselves as members of the following 

population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or 

African American, Native Hawaiian or Other Pacific Islander, or two or more races meaning 

individuals who identified themselves on a Census form as being a member of two or more 

races, for example, Hispanic and Asian. 

• Minority populations. Minority populations are identified when (1) the minority population of 

an affected area exceeds 50 percent or (2) the minority population percentage of the 

affected area is meaningfully greater than the minority population percentage in the general 

population or other appropriate unit of geographic analysis. 

• Low-income population. Low-income populations in an affected area are identified with the 

annual statistical poverty thresholds from the Census Bureau’s Current Population Reports, 

Series PB60, on Income and Poverty. 

4.4.6.1 Minority Population in 2000 

According to 2000 census data, 34 percent of the population (approximately 690,000 

individuals) residing within a 50-mi radius of HNP were minority individuals. The largest minority 

group was Black or African American (474,000 individuals or 23 percent), followed by Hispanic 

or Latino (131,600 individuals or about 7 percent). About 30 percent of the Wake County 

population are minorities, with Black or African American the largest minority group 

(19.5 percent) followed by Hispanic or Latino (5.4 percent). Black or African American block 
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NUREG-1437, Supplement 33 4-28 August 2008 

groups are concentrated in urban areas (Burlington, Cary, Durham, Fayetteville, and Raleigh) 

and the Fort Bragg area 24 km (15 mi) from HNP. Members of the Lumbee and Tuscarora 

tribes are found in Hoke and Robeson counties south of the plant (Progress Energy 2006b). 

Census block groups with minority populations exceeding 50 percent were considered minority 

block groups. Based on 2000 census data, Figure 4–1 shows minority block groups within a 

50-mi radius of HNP in which more than 50 percent of the block group population is minority. 

4.4.6.2 Low-Income Population in 2000 

According to 2000 census data, approximately 216,000 individuals (approximately 10 percent) 

residing within a 50-mi radius of HNP were identified as living below the Federal poverty 

threshold. The 1999 Federal poverty threshold was $17,029 for a family of four. According to 

2000 census data, the median household income for North Carolina in 1999 was $39,184, while 

12.3 percent of the state population was determined to be living below the 1999 Federal poverty 

threshold (USCB 2007). 

Wake County had a higher median household income ($54,988) and a lower percentage 

(7.8 percent) of individuals living below the poverty level when compared to the state. Lee 

County had the lowest median household incomes ($38,900) and the highest percentage 

(12.8 percent) of individuals living below the poverty level when compared to Coffey County and 

the state (USCB 2007). 

Census block groups were considered low-income block groups if the percentage of the 

population living below the Federal poverty threshold exceeded the state percentage of 

12.3 percent. Based on 2000 Census data, Figure 4–2 shows low-income block groups within a 

50-mi radius of HNP.
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August 2008 4-29 NUREG-1437, Supplement 33 

Figure 4–1. Minority block groups in 2000 within an 80-km (50-mi) radius of HNP. 
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NUREG-1437, Supplement 33 4-30 August 2008 

Figure 4–2. Low-income block groups with an 80-km (50-mi) radius of HNP. 
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August 2008 4-31 NUREG-1437, Supplement 33 

4.4.6.3 Analysis of Impacts 

Consistent with the impact analysis for the public and occupational health and safety, the 

affected populations are defined as minority and low-income populations who reside within a 

50-mi radius of HNP. Based on the analysis of impacts for all resource areas presented in this 

SEIS, there would be no disproportionately high and adverse impacts from the operation of HNP 

during the license renewal period. 

NRC also analyzed the risk of radiological exposure through the consumption patterns of 

special pathway receptors, including subsistence consumption of fish, native vegetation, surface 

waters, sediments, and local produce; absorption of contaminants in sediments through the 

skin; and inhalation of plant materials. The special pathway receptors analysis is important to 

the environmental justice analysis because consumption patterns may reflect the traditional or 

cultural practices of minority and low-income populations in the area. 

Subsistence Consumption of Fish and Wildlife 

Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

appropriate, to collect and analyze information on the consumption patterns of populations who 

rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 

consumption patterns to the public. In this SEIS, NRC considered whether there were any 

means for minority or low-income populations to be disproportionately affected by examining 

impacts to American Indian, Hispanic, and other traditional lifestyle special pathway receptors. 

Special pathways that took into account the levels of contaminants in native vegetation, crops, 

soils and sediments, surface water, fish, and game animals on or near the HNP site were 

considered. 

CP&L has a comprehensive Radiological Environmental Monitoring Program (REMP) at HNP to 

assess the impact of site operations on the environment. Samples are collected from the aquatic 

and terrestrial pathways applicable to the site. The aquatic pathways include fish, surface waters 

and sediment. The terrestrial pathways include airborne particulates and radioiodine, milk, food 

products and direct radiation. 

Most of the land within an 8 km (5 mi) radius of HNP is wooded with few residences and limited 

agricultural activity. The land in this area is primarily used for timber production. The land within a 

16 km (10 mi) radius is mostly rural with significant populations centers located in the towns of Apex, 

Holly Springs, and Fuquay-Varina. These communities are currently experiencing significant 

growth. Much of the land within an 80 km (50 mi) radius is also used for agricultural crop and 

livestock production. Agricultural production in this region primarily consists of corn, soybeans, 

tobacco, cattle, hogs, poultry, and dairy (Progress Energy 2006b). 

During 2005, analyses were performed on 1148 collected samples of environmental media as part 

of the required REMP and showed no significant or measurable radiological impact from HNP 

operations. Cesium-137, cobalt-58, and colbalt-60 activity was detected in samples obtained from 
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NUREG-1437, Supplement 33 4-32 August 2008 

bottom sediment and cobalt-60 activity was detected in one of three samples obtained from aquatic 

vegetation at Harris Reservoir. Activity due to plant operation was not evident in any shoreline 

sediment samples taken during 2005 and no unusual trends were noted. Tritium attributable to 

HNP operation was also detected in surface water samples collected from Harris Reservoir during 

2005. Tritium was the only activity detected in surface water samples, except for one control 

sample taken upstream of the plant, and no unusual trends were noted. In the 2005 REMP, fish 

samples taken from Harris Reservoir were assumed to have the same amount of tritium activity as 

reservoir surface water (5940 pCi/liter annual average). Based on this assumption, an adult 

consuming 21 kg (46 lb) of fish could receive a total body and organ dose equivalent of 

0.00013 mSv (0.013 mrem). No other radionuclides were detected in fish during the year. With the 

exception of the average tritium concentration in Harris Reservoir being higher than the 2004 annual 

average, the results for all samples in 2005 were consistent with the previous five-year historical 

results and exhibited no adverse trends (Progress Energy 2006b). 

The results of the 2005 REMP demonstrate that the routine operation at the HNP site had no 

significant or measurable radiological impact on the environment. No elevated radiation levels 

were detected in the offsite environment as a result of plant operations and the storage of 

radioactive waste. The continued operation of the HNP has not contributed measurable 

radiation, with the exception of Harris Reservoir bottom sediment and aquatic vegetation, in the 

environmental monitoring program (Progress Energy 2006b). REMP continues to demonstrate 

that the dose to a member of the public from the operation of HNP remains significantly below 

the federally required dose limits specified in 10 CFR Part 20 and 40 CFR Part 190. 

Based on recent monitoring results, concentrations of contaminants in native vegetation, crops, 

soils and sediments, surface water, fish, and game animals in areas surrounding HNP have 

been quite low (at or near the threshold of detection) and seldom above background levels. 

Consequently, no disproportionately high and adverse human health impacts would be 

expected in special pathway receptor populations in the region as a result of subsistence 

consumption of fish and wildlife. 

4.5 Groundwater Use and Quality

No Category 1 or Category 2 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, are 

potentially applicable to HNP groundwater use and quality during the renewal term. The NRC 

staff has not identified any new and significant information during its independent review of the 

HNP ER (Progress Energy 2006b), the site audit, the scoping process, and its evaluation of 

other available information and public comments on the draft SEIS. HNP does not use 

groundwater for any purpose, and there is no evidence operation of the plant is contaminating 

groundwater in the area. While the plans have not been finalized, HNP is developing a 

voluntary groundwater monitoring program and plans to install more monitoring wells in the 

power block area to monitor for radionuclides and other parameters. However, there are no 

known local users of groundwater within the influence of HNP because the local geology inhibits 
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August 2008 4-33 NUREG-1437, Supplement 33 

the development of functioning wells. Even the presence of contaminants in the HNP property 

would have no effect on local water supplies. Because continued operation of HNP would have 

no impacts on groundwater use and quality, mitigation measures need not be considered. 

Therefore, the NRC staff concludes that there are no impacts related to these issues beyond 

those discussed in the GEIS. 

4.6 Threatened or Endangered Species

Threatened or endangered species are listed as a Category 2 issue in 10 CFR Part 51, 

Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-7. 

Table 4-7. Category 2 Issue Applicable to Threatened 

or Endangered Species During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 

GEIS

Section

10 CFR 51.53(c)(3)(ii) 

Subparagraph 

SEIS

Section

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 4.1 E 4.6 

This issue requires consultation with appropriate agencies to determine whether threatened or 

endangered species are present and whether they would be adversely affected by continued 

operation of the HNP during the license renewal term. The characteristics and habitats of 

threatened or endangered species in the vicinity of the HNP site are discussed in Sections 2.2.5 

and 2.2.6. 

CP&L contacted the FWS on November 16, 2005, regarding threatened and endangered 

species at the HNP site and its transmission lines ROWs (Progress Energy 2006b). In its 

response to CP&L, on February 16, 2006, the United States Fish and Wildlife Service (FWS) 

indicated that the proposed project would not likely adversely affect any Federally listed 

endangered or threatened species, formally designated critical habitat or any proposed species 

for listing under the Endangered Species Act of 1973 (Progress Energy 2006b).

On March 27, 2007, the NRC contacted the FWS and the North Carolina Natural Heritage 

Program to request information on Federally and State listed threatened and endangered 

species and critical habitats in the vicinity of HNP. The NRC staff also requested information 

that could assist in its assessment of the environmental impacts associated with license renewal 

(NRC 2007a, 2007b). In response, on April 26, 2007, the North Carolina Natural Heritage 

Program indicated that, “although many rare plants and animals are know to occur in North 

Carolina within power line ROWs apparently no such species are know to occur on the HNP 
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NUREG-1437, Supplement 33 4-34 August 2008 

power line ROWs” (NCDENR 2007b). The FWS did not provided any comments in response to 

the March 27, 2007, NRC letter. 

On June 6, 2007, NRC staff met with North Carolina Wildlife Resources Commission (NCWRC) 

staff to discuss potential impacts of continued operation on State-listed species. The NCWRC 

indicated that no habitat has been identified near the HNP site or any of its transmission line 

corridors. The NCWRC staff has not identified any significant foreseeable impacts on State 

protected species or areas that would result from continued operation or maintenance activities 

during the renewal term. The NRC staff contacted FWS on June 25, 2007, and concluded that 

the proposed project would not adversely affect Federally listed species under the FWS’s 

jurisdiction (FWS 2007). 

4.6.1 Aquatic Species 

The NRC staff has reviewed information provided by the applicant, information publicly 

available, and has contacted the FWS and the North Carolina Department of Environment and 

Natural Resources (NCDENR). No Federally listed threatened or endangered aquatic species 

or critical habitat occurs in the Harris Reservoir, in the vicinity of the HNP site, or in the streams 

crossed by the transmission line ROWs. Therefore, license renewal of HNP would have no 

effect on any Federally listed aquatic species, therefore mitigation measures need not be 

considered. 

4.6.2 Terrestrial Species 

Two Federally listed endangered terrestrial species have been identified as occurring or 

historically occurring at or near the HNP site or within the associated transmission line ROWs. 

These are the endangered red-cockaded woodpecker (Picoides borealis) and the endangered 

Michaux’s sumac (Rhus michauxii). These species are described in greater detail in 

Section 2.2.6.2. 

Operation of HNP and its associated transmission lines are not expected to adversely affect any 

threatened or endangered terrestrial species during the license renewal term. Therefore, the 

NRC staff concludes that adverse impacts to threatened or endangered species during the 

license renewal term would be SMALL. 

However, maintenance of forested areas around the HNP site likely provides habitat that could 

be inhabited by a threatened or endangered species during the license renewal term. Mitigation 

measures in the form of wildlife management plans, administrative procedures and best 

management practices are in place to minimize the effects of plant operation on terrestrial 

species. Current measures to mitigate potential impacts of plant operation on endangered 

terrestrial species are found to be adequate. 
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August 2008 4-35 NUREG-1437, Supplement 33 

4.7 Evaluation of New and Potentially Significant Information on Impacts of 

Operations During the Renewal Term

The NRC staff has not identified new and significant information on environmental issues listed 

in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, related to station operation during the 

renewal term. The NRC staff also determined that information provided during the public 

comment period did not identify any new issue that requires site-specific assessment. The NRC 

staff reviewed the discussion of environmental impacts associated with operation during the 

renewal term in the GEIS and has conducted its own independent review, including public 

scoping meetings, to identify issues with new and significant information. Processes for 

identification and evaluation of new information are described in Section 1.2.2. 

4.8 Cumulative Impacts

The NRC staff considered potential cumulative impacts on the environment resulting from the 

incremental impact of license renewal when added to other past, present, and reasonably 

foreseeable future actions. For the purposes of this analysis, past actions are related to the 

resources when HNP was licensed and constructed, present actions are related to the 

resources during current operations, and future actions are those that are reasonably 

foreseeable through the end of station operations including the license renewal term. The 

geographic area over which past, present, and future actions are assessed is dependent on the 

affected resource. 

The impacts of the proposed action, license renewal, as described in this chapter of the SEIS, 

are combined with other past, present, and reasonably foreseeable future actions regardless of 

which agency (Federal or non-Federal) or entity is undertaking the actions. The combined 

impacts are defined as “cumulative” in 40 CFR 1508.7 and include individually minor but 

collectively significant actions taking place over a period of time. It is possible that an impact 

that may be SMALL by itself could result in a MODERATE or LARGE impact when considered 

in combination with the impacts of other actions on the affected resource. Likewise, if a 

resource is regionally declining or imperiled, even a SMALL individual impact could be important 

if it contributes to or accelerates the overall resource decline.

The NRC staff has identified reasonably foreseeable actions occurring in the future that are 

considered in this review for its cumulative impacts on the environment. Among the identified 

actions, a significant one involves the submittal of an application to build two new nuclear units 

at the HNP site. 
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NUREG-1437, Supplement 33 4-36 August 2008 

A letter of intent to submit a Combined License (COL) application was sent to the NRC by 

CP&L, in February 1, 2006(2), as amended on May 31, 2007(3). The letter states that a COL 

application for the Harris site could be submitted to the NRC during the first quarter of 2008; it 

further indicated that the proposal calls for two Westinghouse AP 1000 units to be built at the 

site.

Submitting the COL application does not commit CP&L to build new nuclear units, and does not 

constitute approval of the proposal by the NRC. If such application is submitted, it will be 

evaluated on its merits and after considering and evaluating the environmental and safety 

implications of the proposal, the NRC will decide whether to approve or deny a license. 

Should CP&L submit the application, receive approval by the NRC, and decide to construct one 

or two new nuclear power plant units at the HNP site the cumulative short-term construction 

impacts of this action could range from SMALL to LARGE in the immediate vicinity of the HNP. 

The cumulative long-term impacts related to the operation of the units could range from SMALL 

to MODERATE. 

The specific cumulative impacts of the COL action will depend on the actual design, 

characteristics, and construction practices that could be proposed by the applicant. Such 

details are not available at this time, but if such application is submitted to the NRC the detailed 

environmental impacts of the COL action at the HNP site would be analyzed and addressed in a 

separate NEPA document that would be prepared by the NRC staff. 

The following sections contain a description of the cumulative impacts in the vicinity of HNP. 

While the description might be limited due to the unavailability of specific information, the NRC 

staff based its assessment on scientific principles and professional judgment. 

4.8.1 Cumulative Impacts on Aquatic Resources 

For the purposes of this analysis, the geographic area considered for cumulative impacts on 

aquatic resources at HNP is the Harris Reservoir, the eight tributaries that feed into the reservoir 

upstream of the Harris Dam (Tom Jack Creek, Thomas Creek, Little White Oak Creek, White 

Oak Creek, Utley Creek, Cary Branch, Jim Branch, and Buckhorn Creek), and the section of 

Buckhorn Creek downstream of the Harris Dam. 

As discussed in Section 4.1, the NRC staff found no new and significant information that would 

indicate that the conclusions regarding any of the Category 1 issues related to HNP’s closedcycle cooling system are inconsistent with the conclusions in the GEIS (NRC 1996). Because 

the GEIS concludes that the impacts from Category 2 issues, such as entrainment, 

 

2 Publicly available in ADAMS under accession number ML060460250. 

3 Publicly available in ADAMS under accession number ML071550412. 
 Environmental Impacts of Operation 

August 2008 4-37 NUREG-1437, Supplement 33 

impingement, and heat shock are small for closed-cycle cooling systems, operation of the HNP 

cooling system would not contribute significantly to the cumulative impacts for surface water 

quality and aquatic resources of Harris Reservoir and its tributaries. 

The current and future conditions of local aquatic resources water quality are influenced by the 

cumulative effects of past actions. Section 2.2.5 discusses the major changes and 

modifications within Harris Reservoir and its immediate drainage area that have had the 

greatest impacts on aquatic resources. These changes include the damming of Buckhorn 

Creek to create Harris Reservoir and fluctuations in nutrient levels due to discharges from HNP, 

the Harris Energy & Environment Center, and Holly Spring’s Utley Creek Wastewater Treatment 

Plant (WWTP). Since the mid-1990s, nutrient levels in the Harris Reservoir have stabilized to 

eutrophic condition. Additionally, recreational fishing pressure, as well as the introduction of 

species by the North Carolina Wildlife Resources Commission in 1987, have likely altered the 

ecosystem of the Harris Reservoir. Threadfin shad (Dorosoma petenense) was introduced to 

provide prey for largemouth bass (Micropterus salmoides), a relationship that led to a productive 

recreational fishery. Common carp (Cyprinus carpio) was introduced to the auxiliary reservoir to 

control the spread of nuisance vegetation. 

Recreational fishing pressure is likely to continue to affect aquatic resources in the Harris 

Reservoir and associated waterways. Despite the slot limit for largemouth bass instituted by 

North Carolina Wildlife Resources Commission, fishing pressure is high, and creel surveys 

reveal that the reservoir is often crowded with bass fishermen (Jones et al. 2000), especially 

during tournaments. Boating, waterskiing, and other related activities on the reservoir can 

introduce pollutants to the water system, as can runoff from US Route 1 (from Apex to New Hill). 

Water activities can also lead to increased rates of shoreline erosion. 

The construction of the Harris Dam flooded the creeks that now feed into the reservoir, 

changing the immediate area. However, streamflow for the downstream sections of Buckhorn 

Creek did not change dramatically. CP&L is currently assessing if any bathymetric changes 

have occurred due to sedimentation in the reservoir, but they currently have no plans to dredge 

Harris Reservoir.

The Utley Creek WWTP discharges into Utley Creek, a tributary of White Oak Creek, which 

flows into the Harris Reservoir. The town of Holly Spring plans to expand the WWTP and to 

send treated effluent to the Western Wake Water Reclamation Facility when it becomes 

operational. The new water reclamation facility would discharge into the Cape Fear River below 

the Buckhorn Dam (at the intersection of the Cape Fear River and Buckhorn Creek). According 

to NCDENR, this plan would improve water quality in Utley Creek and downstream waters. 

(NCDENR 2007a). 

Several brick companies, including Triangle Brick and Cherokee Brick, which are located in the 

area of HNP, consume water from the surrounding area in their production of brick. 
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NUREG-1437, Supplement 33 4-38 August 2008 

Additionally, local agriculture can have impacts on both the consumption and pollution of the 

area’s aquatic resources. 

Hydrilla (Hydrilla verticillata) and creeping water primrose (Ludwigia grandiflora), two invasive 

aquatic plants, have been growing in Harris Reservoir and are likely to continue to affect the 

area. With the exception of the introduction of common carp to the auxiliary reservoir, nothing 

has been done to check the spread of these species, in part because they provide habitat for 

largemouth bass and other fish. CP&L discovered the presence of the invasive plant species 

water hyacinth (Eichohornia crassipes) and water lettuce (Pistia stratiotes) and removed the two 

species in 2002. Although these species have not been rediscovered, they, or other invasive 

species, could establish populations in the future. 

The largest change that is reasonably foreseeable for the area is the possible creation and 

operation of two additional nuclear units at HNP by CP&L, as indicated in the letter of intent to 

NRC (Progress Energy 2005b, 2007c). If the units are built, HNP would require additional water 

for the two new cooling towers. This would require the reservoir level to be raised an estimated 

6 m (20 ft), which would approximately double the acreage of the reservoir. Additionally, HNP 

would withdraw makeup water from the Cape Fear River, potentially affecting that resource, 

which currently serves as the water source for the Cape Fear Plant, also owned by CP&L. 

Evaporation and blowdown levels would increase, and the increased footprint of the new units 

could lead to additional runoff to the reservoir and streams. A decrease in distance from 

agricultural areas could increase agricultural runoff, which could affect aquatic species. As an 

example of how runoff can affect aquatic resources, after Hurricane Fran in September 1996, 

the large-scale flooding caused excess runoff that carried plant nutrients and organic material 

into the upper Thomas Creek area of Harris Reservoir, resulting in low dissolved oxygen 

concentrations that killed an estimated 10,000 fish (CP&L 1996, 1997). If the reservoir is indeed 

raised by 6 m (20 ft), transmission line towers located in or near the reservoir would likely be 

rebuilt. The associated construction would affect aquatic resources. A complete review of the 

impacts from two new units would be included in future environmental impact statements (EISs) 

if CP&L proceeds with its application. 

The NRC staff concludes that the minimal aquatic impacts of the continued HNP operations 

would not contribute to an overall decline in the condition of aquatic resources. However, the 

impacts of other current and future actions, by CP&L or other entities, could have significant 

impacts to the aquatic resources, and therefore, the potential cumulative impacts on the Harris 

Reservoir and associated waterways would be MODERATE to LARGE. Mitigative measures for 

the potential future actions by CP&L would be addressed in future EISs, if applicable. 

4.8.2 Cumulative Impacts on Terrestrial Resources 

This section addresses past, present, and future actions that could result in adverse cumulative 

impacts on terrestrial resources, including wildlife populations, upland habitats, wetlands, 

riparian zones, invasive species, protected species, and land use. For purposes of this 
 Environmental Impacts of Operation 

August 2008 4-39 NUREG-1437, Supplement 33 

analysis, the geographic area considered in the evaluation includes the HNP site, the Harris 

Research Tract, the Shearon Harris Game Lands, the Harris Lake State Park, all forested land 

owned by CP&L and managed for timber production, the ROWs of the seven in-scope 

transmission lines identified in Section 2.1.7, the wetlands on and in the vicinity of the HNP site, 

and the significant natural heritage areas of Wake County discussed in Section 2.2.6.1. 

Initial construction of the HNP site converted approximately 400 ha (1000 ac) of forested land 

owned by CP&L into cleared land used for industrial purposes, though the majority of the 2000 

to 2500 ha (5000 to 6000 ac) was left undeveloped and is now managed to ensure forest growth 

continues (Progress Energy 2006b). During construction, the Harris Reservoir was formed from 

the creation of a dam on Buckhorn Creek for the purpose of creating a water supply for HNP. 

Creation of the Harris Reservoir submerged many acres of forested land. Leveling of the land 

surrounding Harris Reservoir created suitable land for wetland vegetation, and allowed lowland 

forest vegetation to develop. 

Construction of the seven transmission lines maintained by CP&L for HNP resulted in 

subsequent changes to the wildlife and plant species present within the vicinity of HNP. Due to 

the fragmentation of previously contiguous forested areas, edge effects such as changes in 

light, wind, and temperature, changes in abundance and distribution of interior species, reduced 

habitat ranges for certain species, and an increased susceptibility to invasive species have likely 

occurred in these areas. ROW maintenance has likely had past impacts and is likely to have 

present and future impacts on the terrestrial habitat, which may include bioaccumulation of 

chemicals, prevention of the natural successional stages of the surrounding vegetative 

community due to mowing and cutting, an increase in abundance of edge species, a decrease 

in abundance of interior species, and an increase in invasive species populations. 

Invasive terrestrial species are not managed by CP&L on their land holdings; therefore, a 

potential exists for invasive species to be introduced on or in the vicinity of the HNP site from 

present and future actions. Introduction may contribute to the establishment of an invasive 

species population, which could compete with native populations for resources and degrade 

areas of terrestrial habitat. 

Protected species within the vicinity of HNP, which are discussed in Section 2.2.6, are expected 

to continue to inhabit the area. Management of the Harris Research Tract would ensure the 

existence of the longleaf pine as well as any threatened and endangered species contained 

within this area of land. Hunting is permitted on the Shearon Harris Game Lands; however, the 

FWS, in conjunction with other Federal and State agencies, prohibits hunting of all protected 

species and species of special concern. Population depletion does not pose a foreseeable 

threat to any terrestrial species within the Shearon Harris Game Lands. 

The Cape Fear Plant near Moncure, North Carolina, is located within 16 km (10 mi) of the HNP 

site and has two coal-fired units, four oil-fired units, and two combined-cycle generating units 

(Progress Energy 2007b). Fossil plants release carbon dioxide, mercury, nitrous oxides, and 
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NUREG-1437, Supplement 33 4-40 August 2008 

sulfur dioxide, among other air emissions. Nitrous oxides and sulfur dioxides can combine with 

water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury can 

deposit on soils and surface water, and may then be taken up by both terrestrial and aquatic 

plant or animal species, and poses the risk of bioaccumulation. For these reasons, the Cape 

Fear Plant is likely to have current and future impacts to the environment on the HNP site and 

surrounding area. 

Utley Creek Wastewater Treatment Plant is located on Utley Creek, a creek that flows into the 

Harris Reservoir (NCDENR 2007a). Chemical discharges from this wastewater treatment plant 

that enter Utley Creek and then flow into Harris Reservoir may have current and future impacts 

on the surrounding vegetation, wetlands, and wildlife. Bioaccumulation of chemicals throughout 

the terrestrial environment also poses a threat to these habitats, as well as to riparian zones and 

wildlife species. 

Prior and continued development of Wake County for residential and industrial purposes may 

affect the terrestrial habitat within in the vicinity of the HNP site. Significant increases in both 

commercial and residential development have occurred in Wake County over the past 20 years. 

With future development, additional runoff from roads and impervious surfaces, development 

adjacent to wetlands and riparian zones, and an increase in waste releases could have future 

impacts on the terrestrial habitat. 

CP&L intends to apply for combined licenses for two new reactor units in 2008, which would be 

located on previously disturbed land adjacent to the current unit (Progress Energy 2005b; 

2007c). The operation of the new units would require CP&L to raise the level of Harris 

Reservoir by 6 m (20 ft). The increase in the depth of the reservoir would submerge many 

acres of terrestrial habitat, including wetlands, riparian zones, and lowland forest areas; 

however, CP&L would likely mitigate the loss of these habitats by creating new areas of wetland 

vegetation. Other lowland terrestrial habitat would be lost. The Harris Lake County Park may 

need to be relocated due the rise of Harris Reservoir, and two boat ramps would need to be 

moved. Additionally, the rise in Harris Reservoir would necessitate the relocation of a highway 

and the raising of a road and bridge. Therefore, the increase in depth of Harris Reservoir would 

have future effects on the terrestrial environment. 

Though new transmission lines may need to be added to HNP, CP&L does not anticipate the 

need for additional ROWs with the addition of two new units. However, some transmission line 

towers in or near Harris Reservoir would need to be elevated due to the increase in depth of the 

reservoir. No additional impacts are likely from transmission lines than those discussed above 

concerning ROW maintenance. 

The NRC staff believes that the cumulative impacts during the term of license renewal on 

terrestrial habitat and associated species, when added to past, present, and reasonably 

foreseeable future actions, would be MODERATE to LARGE. Mitigative measures for the 

potential future actions by CP&L would be addressed in future EISs, if applicable. 
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August 2008 4-41 NUREG-1437, Supplement 33 

4.8.3 Cumulative Impacts on Groundwater Use and Quality 

HNP does not use groundwater for any purpose. All of the water supply comes from either 

Harris Reservoir or the auxiliary reservoir. In addition, there are no local wells down-gradient of 

HNP that would be affected by plant operations, and no local public water supply uses 

groundwater as a source. Future planned groundwater monitoring should determine if 

radionuclides are present in the groundwater in the power block area. Because the general 

direction of groundwater flow is toward the reservoir and water from the site does not reach any 

known aquifer, no groundwater contamination, if it exists, would reach beyond the HNP 

property.

The two reservoirs were created to serve as the entire water source for HNP and had a 

measurable impact on local hydrologic conditions when built. Small perennial and intermittent 

streams were converted to limnological conditions with the resulting increase in groundwater 

bank storage and area groundwater levels. The effect on groundwater use was negligible 

because the local aquifer is not capable of producing more than 3 to 76 liters per minute (1 to 20 

gallons per minute). The increase in water levels may have improved the prospect of 

developing local wells.

There are future plans to build two new power reactor units at HNP. Both of these would likely 

use closed-cycle cooling towers and would use the Harris Reservoir and auxiliary reservoir as 

water supplies. The initial planning indicates the reservoirs would be raised about 6 m (20 ft) 

from current maintained elevations to provide the needed water supply. This would have an 

impact on groundwater levels near the reservoir, but the impact has not been evaluated. It is 

likely local groundwater recharge would increase with enlargement of the reservoirs. Continued 

use of the Harris Reservoir and auxiliary reservoir at HNP, even at higher volumes, would result 

in SMALL adverse cumulative impacts to groundwater use and quality. Mitigative measures for 

the potential future actions by CP&L would be addressed in future EISs, if applicable. 

4.8.4 Cumulative Impacts on Surface Water 

Because HNP uses a cooling tower and does not discharge into a small river, CP&L is not 

required to monitor the thermal discharge for potential impacts to public health from thermophilic 

microorganisms. However, in the future and under certain conditions, localized areas of Harris 

Reservoir at the discharge could potentially increase in temperature, creating an environment 

suitable for the growth of thermophilic microorganisms such as the enteric pathogens 

Salmonella spp. and Shigella spp., the bacterium Pseudomonas aeruginos, thermophilic fungi, 

bacteria Legionella spp., and pathogenic strains of the free-living amoebae Naegleria spp. and 

Acanthamoeba spp. 

The development of the reservoirs during construction of HNP changed the local surface water 

regime from small perennial and intermittent streams to limnological conditions. This was a 

significant change in local hydrologic conditions, but there is no evidence the impact was 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-42 August 2008 

adverse. The reservoirs have value as recreational venues, wildlife habitat, and limited floodcontrol structures. 

Another significant change to the newly established hydrologic regime would likely be caused by 

the proposed future increase in reservoir water levels by 6 m (20 ft). This change has not been 

evaluated, but water quality may deteriorate at first flooding as increased sediment load and 

bioacculmulation at the reservoir bottom could occur. Erosion control measures could be used 

to mitigate increased turbidity and sedimentation and clear-cutting of potentially flooded 

vegetation may be considered. Studies have not been initiated, but the impact to surface water 

in the area from a 6 m (20 ft) increase in water levels would likely be MODERATE. Mitigative 

measures for the potential future actions by CP&L would be addressed in future EISs, if 

applicable.

4.8.5 Cumulative Radiological Impacts 

Operation of HNP results in the release of radioactive material into the environment, which 

results in a very small increase in radiation dose to the local population from that received from 

background radiation. Continued operation of HNP for the license renewal term would result in 

irreversible and irretrievable resource commitments, including the following: 

• nuclear fuel, which is used in the reactor and is converted to radioactive waste; 

• land required to dispose of spent nuclear fuel and low-level radioactive wastes generated as 

a result of plant operations, and sanitary wastes generated from industrial operations; 

• elemental materials that become radioactive; and 

• materials used for the industrial operations of the plant that cannot be recovered or recycled 

or that are consumed or reduced to unrecoverable forms. 

Radiation protections standards for protection of the public and workers have been developed 

by the EPA and NRC to minimize the cumulative impact of acute and long-term exposure to 

radiation and radioactive material. These radiation standards are codified in 40 CFR Part 190 

and 10 CFR Part 20, and contain the upper limits of allowable radiation exposure from the 

existing two reactors at HNP, as well as the proposed two additional reactors. For the purpose 

of this analysis, the area within a 50-mi radius of the HNP site was included. The REMP 

conducted by CP&L in the vicinity of the HNP site measures radiation and radioactive material 

from all sources, including HNP; therefore, the monitoring program is appropriate to measure 

cumulative radiological impacts. There are four other nuclear power reactors in North Carolina: 

two at the Brunswick plant and two at the McGuire plant. However, none of those plants are 

within a 50-mi radius of HNP. Out-of-state nuclear power plants are located beyond 50 miles 

from HNP. The annual radiological environmental monitoring operating reports for the 5-year 

period from 2002 to 2006 were reviewed as part of the cumulative impacts assessment 
 Environmental Impacts of Operation 

August 2008 4-43 NUREG-1437, Supplement 33 

(Progress Energy 2003a, 2004a; 2005a; 2006d; 2007a). No radiation levels in excess of 

regulatory standards were reported. Additionally, in Sections 2.2.7 and 4.3, the NRC staff 

presented information which supports that the radiological impacts to the public and workers 

from operation of HNP during the renewal term as SMALL. The NRC and the State of North 

Carolina would regulate any future activities in the vicinity of the HNP site that could contribute 

to cumulative radiological impacts. 

Therefore, the staff concludes that cumulative radiological impacts of continued operation of 

HNP are SMALL. NRC and the State of North Carolina will continue to regulate future activities 

of the HNP for radiological impacts. 

4.8.6 Cumulative Socioeconomic Impacts 

As discussed in Section 4.4, the continued operation of HNP during the license renewal term 

would have no impact on socioeconomic conditions in the region beyond those already being 

experienced. Since CP&L has indicated that there would be no major plant refurbishment, 

overall expenditures and employment levels at HNP would remain relatively constant with no 

additional demand for housing, public utilities, and public services. In addition, since 

employment levels and the value of HNP would not change, there would be no population- and 

tax revenue-related land use impacts. There would also be no disproportionately high or 

adverse health or environmental impacts on minority and low-income populations in the region. 

Based on this and other information presented in the SEIS, there would be no cumulative 

socioeconomic impacts from HNP operations during the license renewal term and mitigation 

measures need not be considered. 

If CP&L decides to construct one or two new nuclear power plant units at the HNP site, the 

cumulative short-term construction impacts of this action would be MODERATE to LARGE in 

the immediate vicinity of HNP. These impacts would be caused by the short-term increased 

demand for rental housing and other commercial and public services by construction workers 

during the years of plant construction. During peak construction periods there would be a 

noticeable increase in the number and volume of construction vehicles on roads in the 

immediate vicinity of the HNP site. 

The cumulative long-term operations impacts of this action during the operation of the new 

power plant unit(s) would be SMALL to MODERATE. These impacts would be caused by the 

increased demand for permanent housing and other commercial and public services, such as 

schools, police and fire, and public water and electric services by operations workers during the 

years of plant operations. During shift changes there would be a noticeable increase in the 

number of commuter vehicles on roads in the immediate vicinity of the HNP site. 

Because Wake County is one of the fastest growing counties in the nation, the cumulative 

socioeconomic construction and operations impacts are likely to be SMALL when combined with 

all of the other ongoing public and commercial development projects in the county and region. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-44 August 2008 

For the reasonably foreseeable future, members of the public would continue to experience the 

cumulative socioeconomic impacts from the rapid development of Wake County. If CP&L 

constructs these new nuclear power plant units at the HNP site, the cumulative impacts of this 

action would likely be SMALL. 

The specific impact of this action will depend on the actual design, characteristics, and 

construction practices that could be proposed by the applicant. Such details are not available at 

this time, but if such application is submitted to NRC the detailed socioeconomic impacts of this 

action at the HNP site would be analyzed and addressed in a separate NEPA document that 

would be prepared by NRC. 

4.9 Summary of Impacts of Operations During the Renewal Term

The NRC staff has not identified any information that is both new and significant related to any 

of the applicable Category 1 issues associated with the HNP operation during the renewal term. 

Consequently, the NRC staff concludes that environmental impacts associated with these 

issues are bounded by the impacts described in the GEIS. For each of these issues, the GEIS 

concluded that the impacts would be SMALL and that additional plant-specific mitigation 

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

Plant-specific environmental evaluations were conducted for eight Category 2 issues applicable 

to HNP operation during the renewal term and for environmental justice and chronic effects of 

electromagnetic fields. For four issues (Housing, Public Utilities, Offsite Land Use, 

Transportation), the NRC staff concludes that there are no environmental impacts during the 

license renewal term. For the remaining four issues (Acute Effects-Electromagnetic Fields, 

Historic and Archaeological Resources, Threatened or Endangered Species, Severe Accidents), 

the NRC staff concluded that the potential environmental impacts of renewal term operations of 

HNP would be of SMALL significance in the context of the standards set forth in the GEIS. 

For the issue of environmental justice the NRC staff determined that no disproportionately high 

and adverse impacts would be expected on minority and low income populations. In addition, 

the NRC staff determined that a consensus has not been reached by appropriate Federal health 

agencies regarding chronic adverse effects from electromagnetic fields. Therefore, the NRC 

staff did not conduct an evaluation of this issue. 

4.10 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

Protection Against Radiation.” 
 Environmental Impacts of Operation 

August 2008 4-45 NUREG-1437, Supplement 33 

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 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

Waste, and Reactor-Related Greater Than Class C Waste.” 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,

Part 800, “Protection of Historic Properties.” 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental Radiation Protection Requirements for Normal Operations of Activities in the 

Uranium Fuel Cycle.” 

40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment, Part 

1508, “Terminology and Index.” 

Carolina Power & Light (CP&L). 1996. Report of fish kill in Harris Lake. October 23, 1996. 

Accessible at ML072920082 Page 15. 

Carolina Power & Light (CP&L). 1997. Shearon Harris Nuclear Power Plant Unit 1, Annual 

Environmental (Nonradiological) Operating Report, Appendix B, for January 1-December 31, 

1996. Accessible at ML072920082 Page 21. 

Council on Environmental Quality (CEQ). 1997. Environmental Justice: Guidance Under the 

National Environmental Policy Act. Executive Office of the President, Washington, D.C. 

Executive Order 12898. 1994. “Federal Actions to Address Environmental Justice in Minority 

and Low-Income Populations.” Federal Register, Vol. 59, No. 32. 

HNP 2005. Letter from Dave Corlett HNP, to Jeffrey Crow, NC SHPO. Subject: Shearon Harris 

Nuclear Power Plant License Renewal—Request for Information Historic and Archaeological 

Resources. November 16, 2005. Appendix D, Page D-2 of Shearon Harris Nuclear Plant – 

License Renewal Application, Appendix E: Applicant’s Environmental Report, Operating License 

Renewal Stage. Accessible at ML063350276. 

Institute of Electrical and Electric Engineers (IEEE). 1997. National Electrical Safety Code 

(NESC). New York. 

Jones, T.W., W.J. Collart, D. Hinshaw, S. Van Horn. 2000. Harris Lake Creel Survey, 1997-

1998. North Carolina Wildlife Resources Commission Division of Inland Fisheries, Raleigh, 

North Carolina. Accessible at ML072920082 Page 189. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-46 August 2008 

Lumbee Tribe. 2006. “Who are the Lumbee?” Available URL: 

http://www.lumbeetribe.com/lumbee/index.htm. Accessible at ML072920082 Page 119. 

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

National Historic Preservation Act (NHPA) of 1966. 16 USC 470, et seq. 

National Institute of Environmental Health Sciences (NIEHS). 1999. NIEHS Report on Health 

Effects from Exposure to Power Line Frequency and Electrical and Magnetic Fields. Publication 

No. 99-4493, Research Triangle Park, North Carolina. 

North Carolina Department of Cultural Resources (NCDCR). 1978. Letter from North Carolina 

State Historic Preservation Officer, L. E. Tise, to Manager Environmental Technology-Carolina 

Power and Light Company, R. L. Sanders. Subject: Shearon Harris Nuclear Plant, Wake and 

Chatham Counties—Inquiry. March 9, 1978. 

North Carolina Department of Cultural Resources (NCDCR). 1979. Letter from North Carolina 

State Historic Preservation Officer, L. E. Tise, to Manager Environmental Technology-Carolina 

Power and Light Company, W. T. Hogarth. Subject: Archaeological Survey, Shearon Harris 

Makeup Water System, Wake and Chatham Counties. December 27, 1979. 

North Carolina Department of Cultural Resources (NCDCR). 2006. Letter from Renee GledhillEarly to Dave Corlett, Subject: License Renewal, Shearon Harris Nuclear Power Plant, Wake 

County, ER 05-2747. January 26, 2006. Appendix D, Page D-8 of Shearon Harris Nuclear Plant 

– License Renewal Application, Appendix E: Applicant’s Environmental Report, Operating 

License Renewal Stage. Accessible at ML063350276. 

North Carolina Department of Environment and Natural Resources (NCDENR). 2007a. Finding 

of No Significant Impact and Environmental Assessment. Town of Holly Springs Expansion of 

the Utley Creek Wastewater Treatment Plant. February 16, 2007. Accessible at ML072920082 

Page 120. 

North Carolina Department of Environment and Natural Resources (NCDENR). 2007b. Letter 

from H. LeGrand, Jr., Natural Heritage Program, to R. Franovich, NRC. Subject: Renewal of 

operating license for the Shearon Harris Nuclear Power Plant; Wake and Chatham counties, NC. 

Accessible at ML071280403. 

Patch, S. 2006. An Archaeological Survey of Portions of the Shearon Harris Nuclear Plant 

Wake and Chatham Counties, North Carolina. New South Associates Technical Report # 1372. 

July 17, 2006. Accessible at ML072290481, Pages 430-468. 

Progress Energy Carolinas Inc., (Progress Energy). 2003a. Harris Nuclear Plant 2002 

Radiological Environmental Operating Report. January 2002–December 2002. Raleigh, North 

Carolina. Accessible at ML031200120. 
 Environmental Impacts of Operation 

August 2008 4-47 NUREG-1437, Supplement 33 

Progress Energy Carolinas Inc., (Progress Energy). 2004a. 2003 Radiological Environmental 

Operating Report. January 2003–December 2003. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML041210098. 

Progress Energy Carolinas Inc., (Progress Energy). 2005a. 2004 Radiological Environmental 

Operating Report. January 2004–December 2004. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML051220229. 

Progress Energy Carolinas Inc., (Progress Energy). 2005b. Letter from C. Hinnant, Senior Vice 

President and Chief Nuclear Officer. Subject: Letter of Intent to Submit an Application for a 

COL. Accessible at ML052440369. 

Progress Energy Carolinas Inc., (Progress Energy). 2006b. Shearon Harris Unit 1, Applicant’s 

Environmental Report, Operating License Renewal Stage. Raleigh, North Carolina. Accessible 

at ML063350276. 

Progress Energy Carolinas Inc., (Progress Energy). 2006d. 2005 Radiological Environmental 

Operating Report. January 2005-December 2005. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML061160214. 

Progress Energy Carolinas Inc., (Progress Energy). 2007a. 2006 Radiological Environmental 

Operating Report. January 2006–December 2006. Docket Number 50-400, New Hill, North 

Carolina. Accessible at ML071140335. 

Progress Energy Carolinas Inc., (Progress Energy). 2007b. “Cape Fear Plant.” Available URL: 

http://www.progress-energy.com/environment/programs/airquality/capefear.asp. Accessible at 

ML072920082 Page 182. 

Progress Energy Carolinas Inc., (Progress Energy). 2007c. Letter from C. Hinnant, Senior Vice 

President and Chief Nuclear Officer. Subject: Progress Energy COL Projects – NRC Numbers 

738 and 756. Accessible at ML071550412. 

U.S. Census Bureau (USCB). 2007. North Carolina Data. DP-1. Profile of General 

Demographic Characteristics: 2000 for Wake and Lee Counties, North Carolina. Data Set: 

Census 2000 Summary File 1 (SF-1) – 100-Percent Data. Available URL: 

http://factfinder.census.gov.

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

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

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

License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 33 4-48 August 2008 

U.S. Nuclear Regulatory Commission (NRC). 2004c. Policy Statement on the Treatment of 

Environmental Justice Matters in NRC Regulatory and Licensing Actions. Federal Register,

Vol. 69, pp. 52040–52048. Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2007a. Letter from U.S. Nuclear Regulatory 

Commission to S. Hamilton, U.S. Fish and Wildlife Service Southeast Regional Office, Request 

for List of Protected Species Within the Area Under Evaluation for the Shearon Harris Nuclear 

Power Plant License Renewal Application Review. Accessible at ML070220281. 

U.S. Nuclear Regulatory Commission (NRC). 2007b. Letter from U.S. Nuclear Regulatory 

Commission to L. Pearsall, North Carolina Natural Heritage Program, Request for List of State 

Protected Species Within the Area Under Evaluation for the Shearon Harris Nuclear Power 

Plant License Renewal Application Review. Accessible at ML070220337. 

U.S. Nuclear Regulatory Commission (NRC). 2007c. Letter from U.S. Nuclear Regulatory 

Commission to J. Crow, North Carolina State Historic Preservation Officer, Request for 

Comments Concerning the Shearon Harris Nuclear Power Plant License Renewal Application 

Review. Accessible at ML063600188. 

U.S. Nuclear Regulatory Commission (NRC). 2007d. Letter from U.S. Nuclear Regulatory 

Commission to D. L. Kilma, Advisory Council on Historic Preservation Concerning the Shearon 

Harris Nuclear Power Plant License Renewal Application Review. Accessible at ML070220273. 

Ward, T. 1978. Archaeological Survey and Evaluation of the Shearon Harris Nuclear Power 

Plant Cooling Lake Reservoir. Research Laboratories of Anthropology, the University of North 

Carolina at Chapel Hill. January 1978. 
August 2008 5-1 NUREG-1437, Supplement 33 

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 

Environmental issues associated with postulated accidents are discussed in the Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 

Volumes 1 and 2 (NRC 1996, 1999).(1) The GEIS includes a determination of whether the 

analysis of the environmental issue could be applied to all plants and whether additional 

mitigation measures would be warranted. Issues are then assigned a Category 1 or a 

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 

the following criteria: 

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

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

or other specified plant or site characteristics. 

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

the impacts (except for collective off-site radiological impacts from the fuel cycle and 

from high-level waste [HLW] and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required unless new and significant information is identified. 

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

therefore, additional plant-specific review of these issues is required. 

This chapter describes the environmental impacts from postulated accidents that might occur 

during the license renewal term. 

5.1 Postulated Plant Accidents

Two classes of accidents are evaluated in the GEIS. These are design-basis accidents (DBAs) 

and severe accidents, as discussed below. 

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and Addendum 1. 
Postulated Accidents 

NUREG-1437, Supplement 33 5-2 August 2008 

5.1.1 Design-Basis Accidents 

In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 

power facility, an applicant for an initial operating license (OL) must submit a Safety Analysis 

Report (SAR) as part of its application. The SAR presents the design criteria and design 

information for the proposed reactor and comprehensive data on the proposed site. The SAR 

also discusses various hypothetical accident situations and the safety features that are provided 

to prevent and mitigate accidents. The NRC staff reviews the application to determine whether 

the plant design meets the Commission’s regulations and requirements and includes, in part, 

the nuclear plant design and its anticipated response to an accident. 

Design-basis accidents (DBAs) are those accidents that both the licensee and the NRC staff 

evaluate to ensure that the plant can withstand normal and abnormal transients, and a broad 

spectrum of postulated accidents, without undue hazard to the health and safety of the public. 

A number of these postulated accidents are not expected to occur during the life of the plant, 

but are evaluated to establish the design basis for the preventive and mitigative safety systems 

of the facility. The acceptance criteria for DBAs are described in Title 10, Part 50 and Part 100, 

of the Code of Federal Regulations (10 CFR Part 50 and 10 CFR Part 100). 

The environmental impacts of DBAs are evaluated during the initial licensing process, and the 

ability of the plant to withstand these accidents is demonstrated to be acceptable before 

issuance of the OL. The results of these evaluations are found in license documentation such 

as the applicant’s Final Safety Analysis Report (FSAR), the NRC staff’s Safety Evaluation 

Report (SER), the Final Environmental Statement (FES), and Section 5.1 of this Supplemental 

Environmental Impact Statement (SEIS). A licensee is required to maintain the acceptable 

design and performance criteria throughout the life of the plant, including any extended-life 

operation. The consequences for these events are evaluated for the hypothetical maximally 

exposed individual; as such, changes in the plant environment will not affect these evaluations. 

Because of the requirements that continuous acceptability of the consequences and aging 

management programs be in effect for license renewal, the environmental impacts as calculated 

for DBAs should not differ significantly from initial licensing assessments over the life of the 

plant, including the license renewal period. Accordingly, the design of the plant relative to DBAs 

during the extended period is considered to remain acceptable, and the environmental impacts 

of those accidents were not examined further in the GEIS. 

The Commission has determined that the environmental impacts of DBAs are of SMALL 

significance for all plants because the plants were designed to successfully withstand these 

accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 

Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The early resolution of 

the DBAs makes them a part of the current licensing basis of the plant; the current licensing 

basis of the plant is to be maintained by the licensee under its current license and, therefore, 

under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This 

issue, applicable to Shearon Harris Nuclear Power Plant, Unit 1 (HNP), is listed in Table 5-1. 
Postulated Accidents 

August 2008 5-3 NUREG-1437, Supplement 33 

Table 5-1. Category 1 Issues Applicable to Postulated Accidents During the Renewal Term 

ISSUE—10 CFR PART 51, SUBPART A, APPENDIX B,

TABLE B-1

GEIS SECTION

POSTULATED ACCIDENTS

Design basis accidents 5.3.2; 5.5.1 

Based on information in the GEIS, the Commission found that 

The NRC staff has concluded that the environmental impacts of design-basis 

accidents are of small significance for all plants. 

Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc. (CP&L), 

stated in its Environmental Report (ER) (Progress Energy 2006) that it is not aware of any new 

and significant information associated with the renewal of the HNP OL. The NRC staff has not 

identified any new and significant information during its independent review of the CP&L ER, the 

site visit, the scoping process, or the evaluation of other available information. Therefore, the 

NRC staff concludes that there are no impacts related to DBAs beyond those discussed in the 

GEIS.

5.1.2 Severe Accidents 

Severe nuclear accidents are those that are more severe than DBAs because they could result 

in substantial damage to the reactor core, regardless of offsite consequences. In the GEIS, the 

NRC staff assessed the impacts of severe accidents using the results of existing analyses and 

site-specific information to conservatively predict the environmental impacts of severe accidents 

for each plant during the renewal period. 

Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes, 

fires, and sabotage, traditionally have not been discussed in quantitative terms in FESs and 

were not specifically considered for the HNP site in the GEIS (NRC 1996). However, in the 

GEIS, the NRC staff did evaluate existing impact assessments performed by the NRC and by 

the industry at 44 nuclear plants in the United States and concluded that the risk from beyonddesign-basis earthquakes at existing nuclear power plants is SMALL. Additionally, compliance 

with the NRC regulatory requirements under 10 CFR Part 73 provide reasonable assurance that 

the risk from sabotage is SMALL. Even if such events were to occur, the Commission would 

expect that resultant core damage and radiological releases would be no worse than those 

expected from internally initiated events. Based on the above, the Commission concludes that 

the risk from sabotage and beyond design-basis earthquakes at existing nuclear power plants is 

small and additionally, that the risks from other external events, are adequately addressed by a 

generic consideration of internally initiated severe accidents. 
Postulated Accidents 

NUREG-1437, Supplement 33 5-4 August 2008 

Based on information in the GEIS, the Commission found that 

The probability weighted consequences of atmospheric releases, fallout onto open 

bodies of water, releases to groundwater, and societal and economic impacts from 

severe accidents are small for all plants. However, alternatives to mitigate severe 

accidents must be considered for all plants that have not considered such alternatives. 

Therefore, the Commission has designated mitigation of severe accidents as a Category 2 issue 

in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to HNP, is listed in 

Table 5-2. 

Table 5-2. Category 1 Issues Applicable to Postulated Accidents During the Renewal Term 

ISSUE—10 CFR PART 51, SUBPART A,

APPENDIX B, TABLE B-1

GEIS SECTION 10 CFR 51.53(C)(3)(III)

SUBPARAGRAPH

SEIS SECTION

POSTULATED ACCIDENTS

Severe Accidents 5.3.3; 5.3.3.2; 

5.3.3.3; 5.3.3.4; 

5.3.3.5; 5.4; 5.5.2 

L 5.2 

5.2 Severe Accident Mitigation Alternatives

Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to 

mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's 

plant in an environmental impact statement (EIS) or related supplement or in an environmental 

assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware, 

procedures, and training) with the potential for improving severe accident safety performance 

are identified and evaluated. SAMAs have not been previously considered for Shearon Harris 

Nuclear Plant (HNP); therefore, the remainder of Chapter 5 addresses those alternatives. 

5.2.1 Introduction 

This section presents a summary of the SAMA evaluation for HNP conducted by Carolina 

Power and Light (CP&L) and the NRC staff's review of that evaluation. The NRC staff 

performed its review with contract assistance from Information Systems Laboratories, Inc. The 

NRC staff’s review is available in full in Appendix G; the SAMA evaluation is available in full in 

CP&L’s ER. 

The SAMA evaluation for HNP was conducted with a four-step approach. In the first step CP&L 

quantified the level of risk associated with potential reactor accidents using the plant-specific 

probabilistic safety assessment (PSA) and other risk models. 
Postulated Accidents 

August 2008 5-5 NUREG-1437, Supplement 33 

In the second step CP&L examined the major risk contributors and identified possible ways 

(SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 

systems, procedures, and training. CP&L initially identified 22 potential SAMAs for HNP. CP&L 

screened out two SAMAs from further consideration because they were determined to not be 

applicable to the HNP design or to have estimated costs that would exceed the dollar value 

associated with completely eliminating all severe accident risk at HNP. The remaining 

20 SAMAs were subjected to further evaluation. 

In the third step CP&L estimated the benefits and the costs associated with each of the 

remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 

estimates were developed in terms of dollars in accordance with NRC guidance for performing 

regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs was also 

estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 

compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the 

SAMA were greater than the cost (a positive cost-benefit). CP&L found one SAMA to be 

potentially cost-beneficial in the baseline analysis, and two additional SAMAs to be potentially 

cost-beneficial when analysis uncertainties are considered (Progress Energy 2006). 

The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging 

during the period of extended operation; therefore, they need not be implemented as part of 

license renewal pursuant to 10 CFR Part 54. CP&L's SAMA analyses and the NRC's review are 

discussed in more detail below. 

5.2.2 Estimate of Risk 

CP&L submitted an assessment of SAMAs for HNP as part of the ER (Progress Energy 2006). 

This assessment was based on the most recent HNP PSA available at that time, a plant-specific 

offsite consequence analysis performed using the MELCOR Accident Consequence Code 

System 2 (MACCS2) computer program, and insights from the HNP Individual Plant 

Examination (IPE) (CP&L 1993) and Individual Plant Examination of External Events (IPEEE) 

(CP&L 1995). 

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is 

approximately 9.2 x 10-6 per year. This CDF is based on the risk assessment for internallyinitiated events. CP&L did not include the contribution to risk from external events within the 

HNP risk estimates; however, it did account for the potential risk reduction benefits associated 

with external events by increasing the estimated benefits for internal events by a factor of two. 

The breakdown of CDF by initiating event is provided in Table 5-3. 
Postulated Accidents 

NUREG-1437, Supplement 33 5-6 August 2008 

Table 5-3. HNP Core Damage Frequency

Initiating Event CDF(Per Year) 

Percent

Contribution to 

CDF

Loss of Offsite Power 2.8 x 10-6 30

Internal Floods 1.6 x 10-6 17

LOCA 1.3 x 10-6 14

Loss of AC Bus 9.2 x 10-7 10

Steam Generator Tube Rupture 8.3 x 10-7 9

Reactor Trip 4.6 x 10-7 5

Loss of Feedwater 4.6 x 10-7 5

Loss of Instrument Air 3.7 x 10-7 4

Spurious ESFAS 2.8 x 10-7 3

Interfacing System LOCA 1.9 x 10-7 2

Other 9.2 x 10-8 1

Total CDF (internal events) 9.24 x 10-6 100

As shown in Table 5-3, events initiated by loss of offsite power (LOOP) and internal flooding are 

the dominant contributors to CDF. Although not separately reported, station blackout (SBO) 

sequences contribute roughly 2.2 x 10-6 per year (24 percent of the total internal events CDF), 

while anticipated transient without scram (ATWS) sequences contribute 2.3 x 10-7 per year 

(about 2 percent of the total internal events CDF). 

CP&L estimated the dose to the population within 80 km (50 mi) of the HNP site to be 

approximately 0.29 person-Sv (29 person-rem) per year. The breakdown of the total population 

dose by containment release mode is summarized in Table 5-4. Containment bypass failures 

such as a steam generator tube rupture (SGTR) accident with a stuck open safety relief valve 

(SRV) on the ruptured steam generator or an unmitigated interfacing-systems loss of coolant 

accident (ISLOCA) dominate the contributions to the population dose risk at HNP. 
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August 2008 5-7 NUREG-1437, Supplement 33 

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

Containment Release Mode 

Population Dose 

(Person-Rem1

Per Year) 

Percent

Contribution 

Containment Intact 0 0 

Late Containment Failure without scrubbing 0.9 3 

Large Early Containment Failure without scrubbing 0.1 0 

Small Containment Bypass (SGTR or mitigated intersystem LOCA) with scrubbing 0.4 1 

Large Containment Bypass (SGTR with stuck open 

SRV, ruptured SG or unmitigated ISLOCA) with 

scrubbing

5.4 19 

Large Containment Bypass (SGTR with stuck open 

SRV, ruptured SG or unmitigated ISLOCA) without 

scrubbing

19.9 69 

Very Late Containment Failure (basemat melt 

through)

0.2 1 

Very Late Containment Failure (over pressurization) 1.9 7 

Total 29 100 

1

 One person-Rem = 0.01 person-Sv 

The NRC staff has reviewed CP&L's data and evaluation methods and concludes that the 

quality of the risk analyses is adequate to support an assessment of the risk reduction potential 

for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs 

and offsite doses reported by CP&L. 

5.2.3 Potential Plant improvements 

Once the dominant contributors to plant risk were identified, CP&L searched for ways to reduce 

that risk. In identifying and evaluating potential SAMAs, CP&L considered insights from the 

plant-specific PSA, and SAMA analyses performed for other operating plants that have 

submitted license renewal applications. CP&L identified 22 potential risk-reducing 

improvements (SAMAs) to plant components, systems, procedures and training. 
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NUREG-1437, Supplement 33 5-8 August 2008 

CP&L removed two SAMAs from further consideration because they were determined to not be 

applicable to the HNP design or to have estimated costs that would exceed the dollar value 

associated with completely eliminating all severe accident risk at HNP. A detailed cost-benefit 

analysis was performed for each of the 20 remaining SAMAs. 

The staff concludes that CP&L used a systematic and comprehensive process for identifying 

potential plant improvements for HNP, and that the set of potential plant improvements identified 

by CP&L is reasonably comprehensive and, therefore, acceptable. 

5.2.4 Evaluation of Risk Reduction and Costs of Improvements 

CP&L evaluated the risk-reduction potential of the remaining 20 SAMAs. The SAMA 

evaluations were performed using realistic assumptions with some conservatism. 

CP&L estimated the costs of implementing the 20 candidate SAMAs through the application of 

engineering judgment, and use of other licensees’ estimates for similar improvements. The cost 

estimates conservatively did not include the cost of replacement power during extended 

outages required to implement the modifications, nor did they include contingency costs 

associated with unforeseen implementation obstacles. 

The staff reviewed CP&L’s bases for calculating the risk reduction for the various plant 

improvements and concludes that the rationale and assumptions for estimating risk reduction 

are reasonable and generally conservative (i.e., the estimated risk reduction is similar to or 

somewhat higher than what would actually be realized). Accordingly, the staff based its 

estimates of averted risk for the various SAMAs on CP&L’s risk reduction estimates. 

The staff reviewed the bases for the applicant’s cost estimates. For certain improvements, the 

staff also compared the cost estimates to estimates developed elsewhere for similar 

improvements, including estimates developed as part of other licensees’ analyses of SAMAs for 

operating reactors and advanced light-water reactors. The staff found the cost estimates to be 

consistent with estimates provided in support of other plants’ analyses. 

The staff concludes that the risk reduction and the cost estimates provided by CP&L are 

sufficient and appropriate for use in the SAMA evaluation. 

5.2.5 Cost-Benefit Comparison 

The cost-benefit analysis performed by CP&L was based primarily on NUREG/BR-0184 (NRC 

1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently been 

revised to reflect the agency’s revised policy on discount rates. Revision 4 of NUREG/BR-0058 

states that two sets of estimates should be developed – one at three percent and one at seven 

percent (NRC 2004). CP&L provided both sets of estimates (Progress Energy 2006). 
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August 2008 5-9 NUREG-1437, Supplement 33 

CP&L identified one potentially cost-beneficial SAMA in the baseline analysis contained in the 

ER (using a three percent discount rate). The potentially cost-beneficial SAMAs is: 

SAMA 9 - Proceduralize actions to open emergency diesel generator (EDG) room doors 

and implement portable fans on loss of heating ventilation and air-conditioning (HVAC). 

CP&L performed additional analyses to evaluate the impact of parameter choices and 

uncertainties on the results of the SAMA assessment (Progress Energy 2006). If the benefits 

are increased by a factor of 1.5 to account for uncertainties, two additional SAMA candidates 

were determined to be potentially cost-beneficial: 

SAMA 6 - Waterproof motor operators for valves 1SW-274 and 1SW-275 to mitigate 

floods caused by service water line breaks 

SAMA 8 - Provide the capability to align a direct feed to the 1B3-SB transformer to 

preclude battery depletion, and to align the “C” charging/safety injection pump (CSIP) for 

seal injection 

The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 

above, the costs of the SAMAs evaluated would be higher than the associated benefits. 

5.2.6 Conclusions 

The staff reviewed CP&L’s analysis and concluded that the methods used and the 

implementation of those methods were sound. The treatment of SAMA benefits and costs 

support the general conclusion that the SAMA evaluations performed by CP&L are reasonable 

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 

events was somewhat limited by the unavailability of an external event PSA, the likelihood of 

there being cost-beneficial enhancements in this area was minimized by improvements that 

have been realized as a result of the IPEEE process, and increasing the estimated SAMA 

benefits for internal events by a factor of two to account for potential benefits in external events. 

Based on its review of the SAMA analysis, the staff concurs with CP&L’s identification of areas 

in which risk can be further reduced in a cost-beneficial manner through the implementation of 

all or a subset of potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk 

reduction, the staff considers that further evaluation of these SAMAs by CP&L is warranted. 

However, none of the potentially cost-beneficial SAMAs relate to adequately managing the 

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

implemented as part of the license renewal pursuant to 10 CFR Part 54. 
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NUREG-1437, Supplement 33 5-10 August 2008 

5.3 References

Carolina Power & Light (CP&L). 1993. Letter from W. R. Robinson, HNP to U.S. Nuclear 

Regulatory Commission Document Control Desk. Subject: Shearon Harris Nuclear Power Plant 

Docket No. 50-400/License No. NPF-63 Submittal of Individual Plant Examination (IPE). 

August 20, 1993. 

Carolina Power & Light (CP&L). 1995. Letter from W. R. Robinson, HNP to NRC Document 

Control Desk. Subject: Shearon Harris Nuclear Power Plant Docket No. 50-400/License No. 

NPF-63 Response to Generic Letter 88-20. Supplement 4 - Individual Plant Examination of 

External Events (IPEEE). June 30, 1995. 

Progress Energy Carolinas, Inc. (Progress Energy). 2006 Licensee’s Environmental Report–

Operating License Renewal Stage, Shearon Harris Nuclear Plant. November, 2006. 

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

Handbook. NUREG/BR-0184, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C. 
August 2008 6-1 NUREG-1437, Supplement 33 

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE 

AND SOLID WASTE MANAGEMENT 

Environmental issues associated with the uranium fuel cycle and solid waste management are 

discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear 

Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999.)(1) The GEIS includes a 

determination of whether the analysis of the environmental issue could be applied to all plants 

and whether additional mitigation measures would be warranted. Issues are then assigned a 

Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those 

that meet all of the following criteria: 

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

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

or other specified plant or site characteristics. 

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

the impacts (except for collective off-site radiological impacts from the fuel cycle and 

from high-level waste [HLW] and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required unless new and significant information is identified. 

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

therefore, additional plant-specific review of these issues is required. There are no Category 2 

issues for the uranium fuel cycle and solid waste management. 

This chapter addresses the issues that are related to the uranium fuel cycle and solid waste 

management during the license renewal term that are listed in Table B-1 of 10 CFR Part 51, 

Subpart A, Appendix B, and are applicable to Shearon Harris Nuclear Power Plant, Unit 1 

(HNP). The generic potential impacts of the radiological and nonradiological environmental 

impacts of the uranium fuel cycle and transportation of nuclear fuel and wastes are described in 

detail in the GEIS based, in part, on the generic impacts provided in 10 CFR 51.51(b), 

Table S-3, “Table of Uranium Fuel Cycle Environmental Data,” and in 10 CFR 51.52, Table S-4, 

“Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1 
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NUREG-1437, Supplement 33 6-2 August 2008 

Cooled Nuclear Power Reactor.” The U.S. Nuclear Regulatory Commission (NRC) staff also 

addresses the impacts from radon-222 and technetium-99 in the GEIS. 

6.1 The Uranium Fuel Cycle

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to 

HNP from the uranium fuel cycle and solid waste management are listed in Table 6-1. 

Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste 

Management During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

URANIUM FUEL CYCLE AND WASTE MANAGEMENT

Offsite radiological impacts (individual effects from other than the 

disposal of spent fuel and high level waste) 

6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 

6.2.4; 6.6 

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 

Offsite radiological impacts (spent fuel and high level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 

Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 

6.2.2.9; 6.2.3; 6.2.4; 6.6 

Low-level waste storage and disposal 6.1; 6.2.2.2;6.4.2; 6.4.3; 6.4.3.1; 

6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1; 

6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; 

6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 

6.4.4.5.4; 6.4.4.6;6.6 

Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 

6.4.5.5; 6.4.5.6; 6.4.5.6.1; 

6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 

On-site spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 

6.4.6.4; 6.4.6.5; 6.4.6.6; 6.4.6.7; 

6.6

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, 

Addendum 1 

Progress Energy stated in its Environmental Report (ER) for HNP (Progress Energy 2006) that it 

is not aware of any new and significant information associated with the renewal of the HNP 

operating licenses. The NRC staff has not identified any new and significant information during 

its independent review of the HNP ER (Progress Energy 2006), the site audit, the scoping 

process, and its evaluation of other available information and public comments on the draft 
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August 2008 6-3 NUREG-1437, Supplement 33 

SEIS. Therefore, the NRC staff concludes that there are no impacts related to these issues 

beyond those discussed in the GEIS. For these issues, the NRC staff concluded in the GEIS 

that the impacts are SMALL except for the collective offsite radiological impacts from the fuel 

cycle and from high level waste (HLW) and spent fuel disposal, as discussed below, and that 

additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be 

warranted.

A brief description of the staff review and the GEIS conclusions, as codified in Table B-1, 

10 CFR 51, for each of these issues follows: 

• Offsite radiological impacts (individual effects from other than the disposal of spent fuel and 

high level waste). Based on information in the GEIS, the Commission found that 

Off-site impacts of the uranium fuel cycle have been considered by the 

Commission in Table S-3 of this part [10 CFR 51.51(b)]. Based on information in 

the GEIS, impacts on individuals from radioactive gaseous and liquid releases 

including radon-222 and technetium-99 are small. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no offsite radiological impacts of the uranium fuel 

cycle during the renewal term beyond those discussed in the GEIS. 

• Offsite radiological impacts (collective effects). Based on information in the GEIS, the 

Commission found that 

The 100 year environmental dose commitment to the U.S. population from the 

fuel cycle, high level waste and spent fuel disposal excepted, is calculated to be 

about 14,800 person-rem, or 12 cancer fatalities, for each additional 20-year 

power reactor operating term. Much of this, especially the contribution of radon 

releases from mines and tailing piles, consists of tiny doses summed over large 

populations. This same dose calculation can theoretically be extended to include 

many tiny doses over additional thousands of years as well as doses outside the 

U.S. The result of such a calculation would be thousands of cancer fatalities from 

the fuel cycle, but this result assumes that even tiny doses have some statistical 

adverse health effect which will not ever be mitigated (for example no cancer 

cure in the next thousand years), and that these doses projected over thousands 

of years are meaningful. However, these assumptions are questionable. In 

particular, science cannot rule out the possibility that there will be no cancer 

fatalities from these tiny doses. For perspective, the doses are very small 

fractions of regulatory limits and even smaller fractions of natural background 

exposure to the same populations. 
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NUREG-1437, Supplement 33 6-4 August 2008 

Nevertheless, despite all the uncertainty, some judgment as to the regulatory 

NEPA [National Environmental Policy Act] implications of these matters should 

be made and it makes no sense to repeat the same judgment in every case. 

Even taking the uncertainties into account, the Commission concludes that these 

impacts are acceptable in that these impacts would not be sufficiently large to 

require the NEPA conclusion, for any plant, that the option of extended operation 

under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission 

has not assigned a single level of significance for the collective effects of the fuel 

cycle, this issue is considered Category 1. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no offsite radiological impacts (collective effects) 

from the uranium fuel cycle during the renewal term beyond those discussed in the GEIS. 

• Offsite radiological impacts (spent fuel and high level waste disposal). Based on information 

in the GEIS, the Commission found that 

For the high level waste and spent fuel disposal component of the fuel cycle, 

there are no current regulatory limits for offsite releases of radionuclides for the 

current candidate repository site. However, if we assume that limits are 

developed along the lines of the 1995 National Academy of Sciences (NAS) 

report, “Technical Bases for Yucca Mountain Standards,” and that in accordance 

with the Commission’s Waste Confidence Decision, 10 CFR 51.23, a repository 

can and likely will be developed at some site which will comply with such limits, 

peak doses to virtually all individuals will be 1 mSv (100 millirem) per year or 

less. However, while the Commission has reasonable confidence that these 

assumptions will prove correct, there is considerable uncertainty since the limits 

are yet to be developed, no repository application has been completed or 

reviewed, and uncertainty is inherent in the models used to evaluate possible 

pathways to the human environment. The NAS report indicated that 1 mSv 

[100 millirem] per year should be considered as a starting point for limits for 

individual doses, but notes that some measure of consensus exists among 

national and international bodies that the limits should be a fraction of the 1 mSv 

[100 millirem] per year. The lifetime individual risk from 1 mSv [100 millirem] 

annual dose limit is about 3 × 10-3.

Estimating cumulative doses to populations over thousands of years is more 

problematic. The likelihood and consequences of events that could seriously 

compromise the integrity of a deep geologic repository were evaluated by the 

Department of Energy in the “Final Environmental Impact Statement: 

Management of Commercially Generated Radioactive Waste,” October 1980 
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August 2008 6-5 NUREG-1437, Supplement 33 

[DOE 1980]. The evaluation estimated the 70-year whole-body dose 

commitment to the maximum individual and to the regional population resulting 

from several modes of breaching a reference repository in the year of closure, 

after 1,000 years, after 100,000 years, and after 100,000,000 years. 

Subsequently, the NRC and other federal agencies have expended considerable 

effort to develop models for the design and for the licensing of a high level waste 

repository, especially for the candidate repository at Yucca Mountain. More 

meaningful estimates of doses to population may be possible in the future as 

more is understood about the performance of the proposed Yucca Mountain 

repository. Such estimates would involve very great uncertainty, especially with 

respect to cumulative population doses over thousands of years. The standard 

proposed by the NAS is a limit on maximum individual dose. The relationship of 

potential new regulatory requirements, based on the NAS report, and cumulative 

population impacts has not been determined, although the report articulates the 

view that protection of individuals will adequately protect the population for a 

repository at Yucca Mountain. However, U.S. Environmental Protection 

Agency’s (EPA’s) generic repository standards in 40 CFR Part 191 generally 

provide an indication of the order of magnitude of cumulative risk to population 

that could result from the licensing of a Yucca Mountain repository, assuming the 

ultimate standards will be within the range of standards now under consideration. 

The standards in 40 CFR Part 191 protect the population by imposing 

“containment requirements” that limit the cumulative amount of radioactive 

material released over 10,000 years. Reporting performance standards that will 

be required by EPA are expected to result in releases and associated health 

consequences in the range between 10 and 100 premature cancer deaths with 

an upper limit of 1,000 premature cancer deaths world-wide for a 100,000 metric 

tonne (MTHM) repository. 

Nevertheless, despite all the uncertainty, some judgment as to the regulatory 

NEPA implications of these matters should be made and it makes no sense to 

repeat the same judgment in every case. Even taking the uncertainties into 

account, the Commission concludes that these impacts are acceptable in that 

these impacts would not be sufficiently large to require the NEPA conclusion, for 

any plant, that the option of extended operation under 10 CFR Part 54 should be 

eliminated. Accordingly, while the Commission has not assigned a single level of 

significance for the impacts of spent fuel and high level waste disposal, this issue 

is considered Category 1. 

On February 15, 2002, based on a recommendation by the Secretary of the Department of 

Energy, the President recommended the Yucca Mountain site for the development of a 

repository for the geologic disposal of spent nuclear fuel and high-level nuclear waste. The 

U.S. Congress approved this recommendation on July 9, 2002, in House Joint 

Resolution 87, which designated Yucca Mountain as the repository for spent nuclear waste. 
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NUREG-1437, Supplement 33 6-6 August 2008 

On July 23, 2002, the President signed House Joint Resolution 87 into law; Public Law 107-

200, 116 Stat. 735 (2002) designates Yucca Mountain as the repository for spent nuclear 

waste. This development does not represent new and significant information with respect to 

the offsite radiological impacts from license renewal related to disposal of spent nuclear fuel 

and high-level nuclear waste. 

EPA developed Yucca Mountain-specific repository standards, which were subsequently 

adopted by the NRC in 10 CFR Part 63. In an opinion, issued July 9, 2004, the U.S. Court 

of Appeals for the District of Columbia Circuit (the Court) vacated EPA’s radiation protection 

standards for the candidate repository, which required compliance with certain dose limits 

over a 10,000-year period. The Court’s decision also vacated the compliance period in 

NRC’s licensing criteria for the candidate repository in 10 CFR Part 63. In response to the 

Court’s decision, EPA issued its proposed revised standards on August 22, 2005 

(70 Federal Register [FR] 49014). In order to be consistent with EPA’s revised standards, 

NRC proposed revisions to 10 CFR Part 63 on September 8, 2005 (70 FR 53313). 

Therefore, for the high-level waste and spent fuel disposal component of the fuel cycle, 

there is some uncertainty with respect to regulatory limits for offsite releases of radioactive 

nuclides for the current candidate repository site. However, prior to promulgation of the 

affected provisions of the Commission’s regulations, we assumed that limits would be 

developed along the lines of the 1995 NAS report, Technical Bases for Yucca Mountain 

Standards (NAS 1995), and that in accordance with the Commission’s Waste Confidence 

Decision, 10 CFR 51.23, a repository that would comply with such limits could and likely 

would be developed at some site. Peak doses to virtually all individuals would be 1 mSv 

(100 mrem) or less. 

Despite the current uncertainty with respect to these rules, some judgment as to the 

regulatory NEPA implications of offsite radiological impacts of spent fuel and high-level 

waste disposal should be made. The NRC staff concludes that these impacts are 

acceptable in that the impacts would not be sufficiently large to require the NEPA conclusion 

that the option of extended operation under 10 CFR Part 54 should be eliminated.

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no offsite radiological impacts related to spent fuel 

and HLW disposal during the renewal term beyond those discussed in the GEIS. 

• Nonradiological impacts of the uranium fuel cycle. Based on information in the GEIS, the 

Commission found that 

The nonradiological impacts of the uranium fuel cycle resulting from the renewal 

of an operating license for any plant are found to be small. 
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August 2008 6-7 NUREG-1437, Supplement 33 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no nonradiological impacts of the uranium fuel cycle 

during the renewal term beyond those discussed in the GEIS. 

• Low-level waste storage and disposal. Based on information in the GEIS, the Commission 

found that 

The comprehensive regulatory controls that are in place and the low public doses 

being achieved at reactors ensure that the radiological impacts to the 

environment will remain small during the term of a renewed license. The 

maximum additional on-site land that may be required for low-level waste storage 

during the term of a renewed license and associated impacts will be small. 

Non-radiological impacts on air and water will be negligible. The radiological and 

non-radiological environmental impacts of long-term disposal of low-level waste 

from any individual plant at licensed sites are small. In addition, the Commission 

concludes that there is reasonable assurance that sufficient low-level waste 

disposal capacity will be made available when needed for facilities to be 

decommissioned consistent with NRC decommissioning requirements. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts of low-level waste storage and disposal 

associated with the renewal term beyond those discussed in the GEIS. 

• Mixed waste storage and disposal. Based on information in the GEIS, the Commission 

found that 

The comprehensive regulatory controls and the facilities and procedures that are 

in place ensure proper handling and storage, as well as negligible doses and 

exposure to toxic materials for the public and the environment at all plants. 

License renewal will not increase the small, continuing risk to human health and 

the environment posed by mixed waste at all plants. The radiological and nonradiological environmental impacts of long-term disposal of mixed waste from 

any individual plant at licensed sites are small. In addition, the Commission 

concludes that there is reasonable assurance that sufficient mixed waste 

disposal capacity will be made available when needed for facilities to be 

decommissioned consistent with NRC decommissioning requirements. 
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NUREG-1437, Supplement 33 6-8 August 2008 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts of mixed waste storage and disposal 

associated with the renewal term beyond those discussed in the GEIS. 

• On-site spent fuel. Based on information in the GEIS, the Commission found that 

The expected increase in the volume of spent fuel from an additional 20 years of 

operation can be safely accommodated on site with small environmental effects 

through dry or pool storage at all plants if a permanent repository or monitored 

retrievable storage is not available. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts of onsite spent fuel associated with 

license renewal beyond those discussed in the GEIS. 

• Nonradiological waste. Based on information in the GEIS, the Commission found that 

No changes to generating systems are anticipated for license renewal. Facilities 

and procedures are in place to ensure continued proper handling and disposal at 

all plants. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no nonradiological waste impacts during the renewal 

term beyond those discussed in the GEIS. 

• Transportation. Based on information contained in the GEIS, the Commission found that 

The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with 

average burnup for the peak rod to current levels approved by NRC up to 

62,000 MWd/MTU and the cumulative impacts of transporting high-level waste to 

a single repository, such as Yucca Mountain, Nevada are found to be consistent 

with the impact values contained in 10 CFR 51.52, Summary Table S-4—

Environmental Impact of Transportation of Fuel and Waste to and from One 

Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or burnup 

conditions are not met, the applicant must submit an assessment of the 

implications for the environmental impact values reported in § 51.52. 
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August 2008 6-9 NUREG-1437, Supplement 33 

HNP meets the fuel-enrichment and burnup conditions set forth in Addendum 1 to the GEIS. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts of transportation associated with license 

renewal beyond those discussed in the GEIS. 

6.2 References

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

Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for Renewal 

of Operating Licenses for Nuclear Power Plants.” 

10 CFR 63. Code of Federal Regulations, Title 10, Energy, Part 63, “Disposal of High-Level 

Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada.” 

40 CFR 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

“Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 

Fuel, High-Level and Transuranic Radioactive Waste.” 

Carolina Power & Light Company, Progress Energy Carolinas Inc., (Progress Energy). 2006. 

Shearon Harris Unit 1, Applicant’s Environmental Report, Operating License Renewal Stage.

Raleigh, North Carolina. Accessible at ML063350276. 

National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards. 

Washington, D.C. 

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

U.S. Department of Energy (DOE). 1980. Final Environmental Impact Statement: Management 

of Commercially Generated Radioactive Waste. DOE/EIS-0046F, Washington, D.C. 

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

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

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

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.”

NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

August 2008 7-1 NUREG-1437, Supplement 33 

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 

Environmental impacts from the activities associated with the decommissioning of any reactor 

before or at the end of an initial or renewed license are evaluated in the Generic Environmental 

Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 

Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC 2002). The 

U.S. Nuclear Regulatory Commission (NRC) staff’s evaluation of the environmental impacts of 

decommissioning presented in NUREG-0586, Supplement 1, identifies a range of impacts for 

each environmental issue. 

The incremental environmental impacts associated with decommissioning activities resulting 

from continued plant operation during the renewal term are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, 

Volumes 1 and 2 (NRC 1996; 1999).(1) The GEIS includes a determination of whether the 

analysis of the environmental issue could be applied to all plants and whether additional 

mitigation measures would be warranted. Issues were then assigned a Category 1 or a 

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of 

the following criteria: 

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

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

or other specified plant or site characteristics. 

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

the impacts (except for collective off-site radiological impacts from the fuel cycle and 

from high level waste and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required unless new and significant information is identified. 

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

therefore, additional plant-specific review of these issues is required. There are no Category 2 

issues related to decommissioning. 

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Environmental Impacts of Decommissioning 

NUREG-1437, Supplement 33 7-2 August 2008 

7.1 Decommissioning

Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B that are applicable to 

Shearon Harris Nuclear Power Plant, Unit 1 (HNP) decommissioning following the renewal term 

are listed in Table 7-1. Carolina Power and Light Company (CP&L) stated in its Environmental 

Report (ER) (Progress Energy 2006) that it is aware of no new and significant information 

regarding the environmental impacts of HNP license renewal. The NRC staff has not identified 

any new and significant information during its independent review of the HNP, the site audit, the 

scoping process, and its evaluation of other available information and public comments on the 

draft SEIS. Therefore, the NRC staff concludes that there are no impacts related to these 

issues beyond those discussed in the GEIS. For all of these issues, the NRC staff concluded in 

the GEIS that the impacts are SMALL, and additional plant-specific mitigation measures are not 

likely to be sufficiently beneficial to be warranted. 

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

Following the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

DECOMMISSIONING

Radiation Doses 7.3.1; 7.4 

Waste Management 7.3.2; 7.4 

Air Quality 7.3.3; 7.4 

Water Quality 7.3.4; 7.4 

Ecological Resources 7.3.5; 7.4 

Socioeconomic Impacts 7.3.7; 7.4 

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1, 

for each of the issues follows: 

• Radiation doses. Based on information in the GEIS, the Commission found that 

Doses to the public will be well below applicable regulatory standards regardless 

of which decommissioning method is used. Occupational doses would increase 

no more than 1 man-rem caused by buildup of long-lived radionuclides during the 

license renewal term. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 
 Environmental Impacts of Decommissioning 

August 2008 7-3 NUREG-1437, Supplement 33 

the NRC staff concludes that there are no radiation dose impacts associated with 

decommissioning following the license renewal term beyond those discussed in the GEIS. 

• Waste management. Based on information in the GEIS, the Commission found that 

Decommissioning at the end of a 20-year license renewal period would generate 

no more solid wastes than at the end of the current license term. No increase in 

the quantities of Class C or greater than Class C wastes would be expected. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts from solid waste associated with 

decommissioning following the license renewal term beyond those discussed in the GEIS. 

• Air quality. Based on information in the GEIS, the Commission found that 

Air quality impacts of decommissioning are expected to be negligible either at the 

end of the current operating term or at the end of the license renewal term. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts on air quality associated with 

decommissioning following the license renewal term beyond those discussed in the GEIS. 

• Water quality. Based on information in the GEIS, the Commission found that 

The potential for significant water quality impacts from erosion or spills is no 

greater whether decommissioning occurs after a 20-year license renewal period 

or after the original 40-year operation period, and measures are readily available 

to avoid such impacts. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts on water quality associated with 

decommissioning following the license renewal term beyond those discussed in the GEIS. 

• Ecological resources. Based on information in the GEIS, the Commission found that 

Decommissioning after either the initial operating period or after a 20-year 

license renewal period is not expected to have any direct ecological impacts. 
Environmental Impacts of Decommissioning 

NUREG-1437, Supplement 33 7-4 August 2008 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no impacts on ecological resources associated with 

decommissioning following the license renewal term beyond those discussed in the GEIS. 

• Socioeconomic Impacts. Based on information in the GEIS, the Commission found that 

Decommissioning would have some short-term socioeconomic impacts. The 

impacts would not be increased by delaying decommissioning until the end of a 

20-year relicense period, but they might be decreased by population and 

economic growth. 

The NRC staff has not identified any new and significant information during its independent 

review of the HNP ER (Progress Energy 2006), the site audit, the scoping process, and its 

evaluation of other available information and public comments on the draft SEIS. Therefore, 

the NRC staff concludes that there are no socioeconomic impacts associated with 

decommissioning following the license renewal term beyond those discussed in the GEIS. 

7.2 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Carolina Power & Light Company, Progress Energy Carolinas Inc., (Progress Energy). 2006. 

Shearon Harris Unit 1, Applicant’s Environmental Report, Operating License Renewal Stage.

Raleigh, North Carolina. Accessible at ML063350276. 

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Office of Nuclear 

Regulatory Research, Washington, D.C. 

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

for License Renewal of Nuclear Plants, Main Report. NUREG-1437, Volume 1, Addendum 1.

Office of Nuclear Regulatory Research, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, D.C. 
August 2008 8-1 NUREG-1437, Supplement 33 

8 .0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

TO LICENSE RENEWAL

In this chapter, U.S. Nuclear Regulatory Commission (NRC) staff examines the potential 

environmental impacts associated with alternatives to renewing the Shearon Harris Nuclear 

Power Plant, Unit 1 (HNP) operating license. NRC staff considers the following alternatives: 

1) denying the renewal of an operating license (i.e., the no-action alternative); 2) implementing 

electric generating sources other than HNP; 3) relying on conservation to offset an amount of 

electric demand equal to HNP’s capacity; 4) purchasing electric power from other sources; and 

5) implementing a combination of generation and conservation measures. In addition, NRC 

staff briefly discusses other generation alternatives that they deemed incapable of individually 

replacing the power generated by HNP. As NRC staff determined in the Generic Environmental 

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

2 (NRC 1996; 1999)(1), NRC staff will assume that Progress Energy requires power generation 

capability to meet system generating needs beyond the end of the current HNP operating 

license.

Since the GEIS assumes that CP&L needs the power currently generated by HNP, NRC staff 

assumes that CP&L would resort to other forms of power supply or demand reduction (i.e., 

conservation) if NRC elects the no-action alternative. NRC staff discusses the impacts of these 

alternatives in Section 8.2. The alternatives considered in Section 8.2 represent other, distinct 

alternatives to license renewal that allow CP&L to meet future system needs. Though the 

environmental impacts of these alternatives may also be considered potential consequences of 

the no-action alternative, they provide options that CP&L may elect to pursue regardless of 

whether NRC renews the HNP license.

The NRC staff evaluated environmental impacts across 11 categories (land use, ecology, water 

use and quality, air quality, waste, human health, socioeconomics, transportation, aesthetics, 

historical and archaeological resources, and environmental justice) using the NRC’s three-level 

standard of significance—SMALL, MODERATE, or LARGE. NRC staff outlines these standards 

in the footnotes to Table B-1 of Title 10, Part 51, of the Code of Federal Regulations (10 CFR 

Part 51), Subpart A, Appendix B: 

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. 

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
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NUREG-1437, Supplement 33 8-2 August 2008 

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

important attributes of the resource. 

The impact categories NRC staff used in this chapter are the same categories NRC staff used in 

the GEIS, with the additional impact category of environmental justice. 

8.1 No-Action Alternative

NRC regulations implementing the National Environmental Policy Act (NEPA) of 1969 require 

NRC staff to discuss the no-action alternative in any NRC environmental impact statement (EIS, 

see 10 CFR Part 51, Subpart A, Appendix A(4)). For license renewal, the no-action alternative 

means that NRC does not renew the HNP operating license. The HNP operating license would 

then expire in 2026, causing CP&L to cease plant operations.

If, after performing safety and environmental reviews of HNP’s license renewal application, NRC 

acts to renew HNP’s operating license, then CP&L may choose to continue operating HNP 

throughout the renewal term. If this occurs, then shutdown of the unit and decommissioning 

activities would be postponed for up to an additional 20 years. NRC staff expects that the 

impacts of decommissioning after 60 years of operation would not differ significantly from those 

that would occur after 40 years of operation. 

NRC staff addresses the environmental impacts of decommissioning in several documents, 

including the Final Generic Environmental Impact Statement on Decommissioning of Nuclear 

Facilities, NUREG-0586, Supplement 1 (NRC 2002); the license renewal GEIS (chapter 7; 

NRC 1996); and Chapter 7 of this supplemental environmental impact statement (SEIS). These 

analyses either directly address or bound the environmental impacts of decommissioning 

whenever CP&L ceases operating HNP.

These documents do not, however, address environmental impacts that occur after plant 

shutdown and before the actual decommissioning process begins. In the following section, 

NRC staff considers the immediate impacts from plant shutdown. The impacts are summarized 

in Table 8-1.

• Land Use 

Onsite land use would not be affected immediately by the cessation of operations. Plant 

structures and other facilities would likely remain in place until decommissioning. CP&L 

plans to keep transmission lines associated with the project in service after the plant stops 

operating. As a result, maintenance of the rights-of-way would continue as before. Since 

the NRC staff concluded in Chapter 4 that continued operations would have no impact on 

land use, and as plant shutdown would have little or no immediate effect on land use 
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August 2008 8-3 NUREG-1437, Supplement 33 

practices, the NRC staff concludes that the impacts to land use from plant shutdown would 

be SMALL. 

• Ecology

Ecology would be minimally affected by plant shutdown. HNP utilizes a cooling tower rather 

than once-through cooling, which makes aquatic ecology impacts from operations SMALL.

CP&L would continue to maintain Harris Reservoir after shutdown. CP&L staff may allow 

access to the auxiliary reservoir following shutdown, which would increase fishing pressure 

on this impoundment and may introduce invasive species. Impacts to ecology in the 

auxiliary reservoir, though, would probably not be noticeable. Decreased withdrawals from 

Harris Reservoir may increase flows to Buckhorn Creek and the Cape Fear River. These 

effects would be positive, though also likely SMALL. CP&L would continue to use HNP’s 

transmission lines and maintain right-of-way corridors. CP&L would generally continue to 

maintain the site until decommissioning. Since NRC staff determined that continued 

operation of HNP into the license renewal term would have SMALL impacts to ecology, and 

since few changes would occur to ecological resources following shutdown, the NRC staff 

concludes that ecological impacts from shutdown of the plant would be SMALL. 

• Water Use and Quality—Surface Water 

When the plant stops operating, consumptive water use for cooling tower makeup would 

immediately decrease and HNP would discharge much less blow-down water to Harris 

Reservoir. As CP&L would maintain Harris Reservoir even in the event of plant shutdown, 

this net reduction in consumptive water use would increase the amount of water flowing out 

of Harris Reservoir and into Buckhorn Creek, as well as to the Cape Fear River. This would 

have a positive impact to surface water use and quality. Since NRC staff determined in 

Chapter 4 that continued operation would have a SMALL impact on surface water quality 

and use, cessation of a portion of these impacts would also be SMALL. 

• Water Use and Quality—Groundwater 

HNP currently relies on surface water from Harris Reservoir for all domestic, process, and 

makeup water. Though construction crews developed 20 wells between 1973 and 1981, 

none of the wells remain in use. If CP&L shuts the plant down, it is possible that water flows 

out of Harris Reservoir and into Buckhorn Creek would increase, and groundwater recharge 

from the stream may also increase. It is unlikely, however, that this effect would be 

noticeable. Since NRC staff determined in Chapter 4 that continued operation of HNP 

would have no impact on groundwater resources, a small, positive impact from plant 

shutdown would result in a SMALL overall impact to groundwater use and quality from plant 

shutdown.
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NUREG-1437, Supplement 33 8-4 August 2008 

• Air Quality 

When the plant stops operating, there would be a reduction in emissions from activities 

related to plant operation such as use of diesel generators and workers’ vehicles. In 

Chapter 4, NRC staff determined that these emissions would have a SMALL impact on air 

quality during the renewal term. Therefore, if the emissions decrease, the impact to air 

quality would also decrease and would be SMALL. 

• Waste

When the plant stops operating, it would stop generating high-level waste, and it would 

generate fewer low-level and mixed waste from plant operation and maintenance. Since the 

NRC staff determined in Chapter 6 that continued low-level and mixed waste generation 

would have a SMALL impact, a reduction in waste generation would have an even smaller 

impact. Therefore, the NRC staff concludes that waste impacts from plant shutdown would 

be SMALL, and less than during operation. 

• Human Health 

After shutdown the plant would release smaller amount of radioactive gaseous and liquid 

materials to the environment than it did while operating. In addition, the variety of potential 

accidents at the plant would decline to a limited set associated with shutdown events and 

fuel handling. Since NRC staff determined in Chapter 4 that continued plant operations 

would have a SMALL impact on human health, and since NRC staff also determined in 

Chapter 5 that potential accidents during the renewal term would have a SMALL impact, 

then reducing the amounts of gaseous and liquid releases while simplifying and limiting the 

types of potential accidents the plant may experience would further reduce impacts to 

human health. Impacts to human health from plant shutdown, then, are SMALL.

• Socioeconomics

There would be immediate socioeconomic impacts associated with the shutdown of the 

plant due to the elimination of jobs at the plant. These effects would likely not be noticeable, 

however, given the region’s rapid growth rate and variety of economic activities.

Decommissioning activities or construction and operation of an alternative at the current site 

would offset these impacts. There also may be a relatively small reduction in property tax 

revenues for Wake County, which could also be offset by an alternative. In Chapter 4, the 

NRC staff determined that continued plant operations would have no effect on 

socioeconomic conditions in the vicinity of HNP. Since the socioeconomic effects of plant 

shutdown would likely not be noticeable, plant shutdown would have a SMALL impact. See 
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August 2008 8-5 NUREG-1437, Supplement 33 

Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of the 

potential socioeconomic impacts of plant decommissioning.

• Transportation

Cessation of operations would be accompanied by reduced traffic in the vicinity of the plant. 

This reduction would occur largely because the post-shutdown workforce would be smaller 

than the operating workforce. Shipments of materials to and from the plant would also 

decrease. As the NRC staff determined in Chapter 4 that continued operational 

transportation impacts would have no additional impact, a reduction in traffic means that 

impacts would remain SMALL if the plant shuts down. 

• Aesthetics

Plant structures and other facilities are likely to remain in place until decommissioning.

Plumes from the cooling tower would cease or greatly decrease after shutdown. Therefore, 

the NRC staff concludes that the aesthetic impacts of plant closure would be SMALL. 

• Historic and Archaeological Resources 

Onsite lands and underlying archaeological resources would not be affected immediately by 

shutdown, as plant structures and other facilities are likely to remain in place until 

decommissioning. CP&L would continue to operate the plant’s transmission lines and 

maintain Harris Reservoir. Transmission line right-of-way maintenance would continue. As 

NRC staff determined in Chapter 4 that these practices would have a SMALL impact on 

historic and archaeological resources, then continuation of these practices after plant 

shutdown would also have SMALL impacts.

• Environmental Justice 

Impacts on minority and low-income populations due to the shutdown of HNP would depend 

on the number of jobs and the amount of tax revenue lost to the communities surrounding 

the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue 

generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it 

is likely that these losses would be replaced by the development of new businesses and 

new sources of tax revenue in the region. Since CP&L’s tax payments represent a small 

percentage of Wake County’s total annual property tax revenue, it is unlikely that social 

services would be seriously affected. Therefore, minority and low-income populations in the 
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NUREG-1437, Supplement 33 8-6 August 2008 

vicinity of HNP would not likely experience any disproportionately high and adverse 

socioeconomic impacts from the shutdown of HNP. 

The environmental effect of plan shutdown would reduce the amount of operational impacts 

on the environment. Therefore, minority and low-income populations in the vicinity of HNP 

would not likely experience any disproportionately high and adverse environmental impacts 

from the shutdown of HNP.

Table 8-1. Summary of Environmental Impacts of the No-Action Alternative 

Impact Category Impact Comment 

Land Use SMALL Impacts are expected to be SMALL because plant 

shutdown is not expected to result in changes to onsite 

or offsite land use. 

Ecology SMALL Impacts from shutdown are expected to be SMALL 

because aquatic impacts are generally reduced and 

terrestrial impacts are not expected because there 

would not be any land use or maintenance changes.

Water Use and Quality— 

Surface Water 

SMALL Impacts are expected to be SMALL because surface 

water intake and discharges would decrease.

Water Use and Quality— 

Groundwater

No Change The current plant uses no groundwater and no more 

would be extracted if CP&L shuts the plant down. 

Air Quality SMALL Impacts are expected to be SMALL because emissions 

related to plant operation and worker transportation 

would decrease.

Waste SMALL Impacts are expected to be SMALL because generation 

of high-level waste would stop, and generation of lowlevel and mixed waste would decrease. 

Human Health SMALL Impacts are expected to be SMALL because 

radiological doses to workers and members of the 

public, which are currently within regulatory limits, 

would be reduced. 

Socioeconomics SMALL Impacts are expected to be SMALL because of small 

relative decreases in employment and tax revenues.

Regional growth would likely offset most, if not all, 

impacts.

Socioeconomics

(Transportation)

SMALL Impacts are expected to be SMALL because of the 

decrease in commuter traffic to the plant.

Aesthetics SMALL Impacts are expected to be SMALL because plant 

structures would remain in place.

Historic and Archaeological 

Resources

SMALL Impacts are expected to be SMALL because shutdown 

of the plant would not change land use or disturbance. 
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August 2008 8-7 NUREG-1437, Supplement 33 

Impact Category Impact Comment 

Environmental Justice SMALL Impacts are expected to be SMALL because plant 

shutdown is unlikely to disproportionately affect minority 

or low-income populations. 

8.2 Alternative Energy Sources

In this section, NRC staff discusses the environmental impacts of alternatives to license renewal 

that would meet system energy needs after the expiration of HNP’s current license or whenever 

CP&L elects to cease operating HNP. These alternatives include alternate sources of electric 

power (generation alternatives and purchased power), as well as an equivalent amount of 

conservation. If NRC renews the HNP operating license, the decision of whether to continue 

operating HNP or whether to rely on an alternative is left to Progress Energy and state-level 

energy decision makers.

The NRC staff considers the following generation alternatives in detail:

• Supercritical coal-fired generation at the HNP site and at an alternate site (Section 8.2.1) 

• Integrated gasification combined-cycle coal-fired generation at the HNP site and at an 

alternate site (Section 8.2.2) 

• Natural gas combined-cycle generation at the HNP site and at an alternate site 

(Section 8.2.3) 

• New nuclear generation at the HNP site and at an alternate site (Section 8.2.4) 

The NRC staff considers the following non-generation alternatives to license renewal in detail: 

• Utility-sponsored conservation programs (Section 8.2.5) 

• Purchased power (Section 8.2.6) 

The order of alternatives does not imply which alternatives the NRC staff considers most likely 

or most environmentally benign. 

The NRC staff addresses other alternatives considered and found not to be reasonable 

replacements for HNP in Section 8.2.7. Section 8.2.8 presents the environmental impacts of a 

combination of generation and conservation alternatives. This combination includes several 

alternatives that the NRC staff determined to be insufficient as stand-alone alternatives to HNP 

license renewal. 

Each year the Energy Information Administration (EIA), a branch of the U.S. Department of 

Energy (DOE), issues the updated Annual Energy Outlook (AEO). The AEO is a forecasting 

document that analyzes trends and issues in energy production, supply, and consumption in 
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NUREG-1437, Supplement 33 8-8 August 2008 

order to project future energy developments. The projections in the AEO vary from year to year 

based on current events. Its comprehensiveness and policy-neutrality is unique among 

forecasting documents. In the Annual Energy Outlook 2007 with Projections to 2030, EIA 

projects a continued nationwide increase in energy consumption and generating capacity 

(DOE/EIA 2007). Early in this period, through 2010, EIA projects that gas-fired combined-cycle 

or combustion turbine technology will account for most generating capacity additions. As 

natural gas prices increase, coal-fired generation begins to account for the largest share of 

capacity additions. EIA projects that coal will account for the majority (54%) of new capacity 

through 2030. EIA also projects that advanced coal technologies, like coal-fueled integrated 

gasification combined-cycle generation, will decline in cost relative to improved natural-gas-fired 

combined-cycle technologies. EIA projections indicate that U.S. generators will increase total 

nuclear and renewable generation capacity throughout the forecast term, due partly to tax 

credits and other incentives. As a proportion of installed capacity, however, nuclear generation 

will decrease slightly through 2030, while renewables’ share will remain relatively constant 

(DOE/EIA 2007). EIA indicates that changes in electricity generation costs, which are highly 

dependent on emissions-control costs, will drive utilities’ choices in generating technologies.

EIA asserts that oil-fired plants will account for virtually no new generation capacity in the U.S. 

through 2030, and furthermore projects a 0.6% annual decrease in electric sector oil 

consumption because of higher fuel costs and lower efficiencies relative to other technologies 

(DOE/EIA 2007). Given EIA’s analysis, NRC staff will not consider an oil-fired alternative for 

HNP.

HNP has a net rating of 900 megawatts electric output (MWe) net. To simplify alternatives 

analysis in the HNP ER, CP&L developed a set of fossil-fueled alternatives that would 

approximately, but not exactly, replace this capacity (Progress Energy 2006b). CP&L selected 

alternative capacity based on the commercially available combined-cycle gas generators that 

would best approximate HNP’s capacity. After reviewing several manufacturers’ product lines 

(e.g., Siemens and General Electric), NRC staff determined that CP&L’s approximation of 879 

MWe provides an adequate estimate of potential environmental impacts and also noted that this 

approximation may understate impacts by approximately 2.4% in cases where plant output and 

environmental impact correlate directly and linearly. NRC staff also employed this capacity as a 

suitable approximation of both supercritical and integrated gasification combined-cycle coalfired alternatives.(2)

 

(2) While supercritical coal-fired plants rely on conventional boiler technology operated at higher pressures 

and temperatures, integrated gasification combined-cycle (IGCC) plants use coal (or other solid or 

liquid feedstocks) to produce syngas that burns in a combined-cycle plant similar to that used for 

natural gas. Thus, an approximation of this sort is also necessary for the IGCC alternative. Boilerbased coal plants of this size are typically built-to-specifications.
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August 2008 8-9 NUREG-1437, Supplement 33 

In the HNP ER, CP&L identified several possible alternatives, all of which would be constructed 

at the current HNP site. Given that the current site includes approximately 4370 ha (10,800 ac), 

of which 1680 ha (4150 ac) is Harris Reservoir, (Progress Energy 2006b) as well as cooling 

water, plant auxiliary buildings and infrastructure, and transmission lines, NRC staff believes 

that the HNP site allows adequate area for construction of all proposed alternatives. CP&L also 

owns additional land around the HNP site that it does not consider part of the site. NRC staff 

notes that CP&L’s potential plans for two additional nuclear units at the site would raise the 

reservoir level to flood an additional 1540 ha (3800 ac). Even if CP&L raises the Harris 

Reservoir level to support two potential new nuclear plants onsite, NRC staff believes sufficient 

land would exist to construct an alternative to the existing unit, though it may be necessary to 

convert nearby CP&L-owned land to plant use to support some of the more land-intensive 

alternatives. In addition to considering impacts from alternatives at the HNP site, the NRC staff 

will also generally characterize impacts for alternate sites. 

8.2.1 Supercritical Conventional Coal-Fired Generation

In this section, NRC staff analyzes a new supercritical coal-fired boiler, the first of two coal-fired 

alternatives. Supercritical coal-fired plants are similar to conventional coal boilers, except they 

operate at slightly higher temperatures and higher pressures, which allows for greater thermal 

efficiency. Supercritical coal-fired boilers are commercially proven and represent an increasing 

proportion of new coal-fired power plants. In Section 8.2.2, NRC staff presents the second coalfired alternative, a new integrated gasification combined-cycle (IGCC) coal-fired plant. 

NRC staff considers constructing a supercritical coal-fired power plant at both the HNP site and 

at an alternate site. Construction of a coal-fired plant at an alternate site may necessitate the 

construction of new transmission lines to transmit power to CP&L’s system. Transmission line 

length would vary with distance to suitable existing lines. In addition, construction at an 

alternate site would necessitate the construction of an appropriate railroad spur (or other 

transportation infrastructure) for coal and lime deliveries. 

NRC staff has re-evaluated CP&L’s analysis assuming a better plant efficiency or heat rate of 

8844 British thermal units (BTU) of heat per kilowatt-hour (kWh), the value EIA reports as the 

heat rate for new, scrubbed coal plants in 2005, the most recent year for which NRC staff 

identified data (DOE/EIA 2006b). This would reduce by approximately 13.3% the level of 

emissions CP&L calculated in the HNP ER for some impact areas. NRC staff accepts CP&L’s 

proposed coal-fired alternative configuration, which consists of two 439.5 MWe net coal-fired 

units (approximately 468 MW gross electric power each, assuming 6% onsite power 

consumption). NRC staff notes that this may understate some impacts, like air emissions, by 

2.4% versus a plant equal in output to HNP. The NRC staff compared this information to 

environmental impact information in the GEIS, as well as to reference information available from 

EIA, the Environmental Protection Agency (EPA), and electric industry sources. 
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NUREG-1437, Supplement 33 8-10 August 2008 

Although the operating license renewal period is only 20 years, NRC staff analyzed the impact 

of operating the coal-fired alternative for 40 years, as this is a reasonable projection of the 

operating life of a coal-fired plant. This means that only half of certain impacts (land use for 

waste disposal and coal mining, for example) are directly attributable to the 20 year license 

renewal period.

The supercritical coal-fired plant, with a gross output of slightly more than 935 MWe would 

consume approximately 2.27 million metric tons (MT) (2.50 million tons) per year of pulverized 

bituminous coal with an ash content of approximately 11.6 percent (based on averages for 

North Carolina coal consumption) (EIA/DOE 2006c) and sulfur content of 0.88 percent. As in 

Progress Energy’s analysis, NRC staff assumed a capacity factor(3) of 0.85 for the supercritical 

coal-fired alternative (Progress Energy 2006b).

At the HNP site, a coal-fired alternative would likely receive coal and lime (used to scrub sulfur 

oxides from flue gases) by rail. The coal-fired option would require approximately 5 coal unit 

trains per week (assuming each train has 100 cars with 100 tons of coal per car). CP&L would 

have to improve HNP’s existing rail spur to allow for these deliveries. Impacts from improving 

the rail spur would be SMALL, as the area is already disturbed and used for industrial purposes. 

In evaluating the supercritical coal-fired alternative, the NRC staff assumed that a new plant 

located at either the HNP site or an alternate site would use a closed-cycle cooling system, like 

the current HNP unit does. NRC staff discusses the overall impacts of the supercritical coalfired generating alternative in the following sections and summarizes these impacts in 

Table 8-2. The extent of impacts at an alternate site would depend on the location and 

characteristics of the particular site selected. 

• Land Use 

A supercritical coal-fired alternative would use the existing facilities and infrastructure at the 

HNP site to the extent practicable, limiting the amount of new construction. This alternative 

may be able to use the existing cooling tower system, switchyard, offices, and transmission 

line rights-of-way. Much of the land the new plant may use has been previously disturbed.

In the GEIS (NRC 1996), NRC staff noted that workers would need to convert roughly 

700 ha (1700 ac) of land to industrial uses to support a 1000 MWe coal-fired plant. Since 

some of this area includes space for offices, parking lots, and other auxiliary structures that 

would be reused from the existing plant, a coal-fired power plant on the HNP site would 

require much less land than at a previously undeveloped site. A coal-fired alternative at the 

 

(3) The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy 

that could have been generated at continuous full-power operation during the same period. 
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August 2008 8-11 NUREG-1437, Supplement 33 

HNP site would likely require several hundred acres for new structures, rather than the 655 

ha (1590 ac) calculated from the GEIS. CP&L, for example, estimated 102 ha (250 ac) in 

the HNP ER.

Mining operators would create additional land-use changes offsite in an undetermined coalmining area to supply coal for the plant. Assuming a mix of coal supply similar to North 

Carolina’s current coal supply, this land disturbance would occur mostly in West Virginia 

(EIA/DOE 2006c). In the GEIS, the NRC staff estimated that supplying coal to a 1000 MWe 

plant would disturb approximately 8900 ha (22,000 ac) of land for mining the coal and 

disposing of the wastes during the 40-year operational life. A coal-fired alternative to 

replace HNP would thus require approximately 8321 ha (20,600 ac) of land, 59.9 ha 

(148 ac) of which the plant would use for onsite waste disposal over the 40 year life(4). Coal 

mining would likely take place in existing coal-mining regions and in accordance with 

applicable mining regulations. Partially offsetting this offsite land use would be the 

elimination of the need for uranium mining to supply fuel for HNP. In the GEIS, the NRC 

staff estimated that approximately 400 ha (1000 ac) would be affected for mining the 

uranium and processing it during the operating life of a 1000 MW nuclear power plant.

Depending on when this land area would be needed, it would be possible that some would 

include areas previously disturbed by nuclear plant structures removed after shutdown or 

decommissioning, thus minimizing the extent to which any additional land would be 

required. Should CP&L move ahead with potential plans to construct new nuclear units on 

the HNP site, a coal-fired alternative may disturb areas that CP&L may not have previously 

disturbed because the nuclear units would be built first and use the area the coal plant 

otherwise may have used. Impacts from converting several hundred acres onsite, as well 

as up to 8321 ha (20,600 ac) for coal and limestone mining and disposal of coal waste,

would occur mostly in previously disturbed areas or in existing mining land. NRC staff 

estimates that these impacts would be LARGE. Improving the rail spur to allow frequent 

coal and lime deliveries would incur short-lived impacts along the existing rail corridor.

These impacts would be SMALL. The overall impact on land use of a coal-fired generating 

unit at the existing HNP site would be best characterized as LARGE, and would be greater 

than the operating license renewal alternative. 

Construction of the coal-fired generation alternative at an alternate site would impact up to 

655 ha (1617 ac) for plant structures (NRC 1996) and 8321 ha (20,600 ac) for mining and 

waste disposal (59.9 ha [148 ac] of which would occur onsite for waste disposal), and 

impacts would be LARGE due not only to plant structures, but also construction of a rail 

spur, transmission lines, and their respective rights-of-way.

 

(4) Only half of the land area needed for mining and by-product disposal is directly attributable to providing 

an alternative to renewing HNP’s operating license for 20 years. 
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NUREG-1437, Supplement 33 8-12 August 2008 

• Ecology

Locating a coal-fired plant at the HNP site would affect ecological resources, but existing 

site maintenance practices and the site’s industrial nature would minimize additional impacts 

from a new supercritical coal-fired plant. Plant structures, coal storage, and waste disposal 

would create SMALL to MODERATE impacts. At an alternate site, constructing 

transmission lines and a rail spur would incur additional impacts, which would be 

MODERATE to LARGE, depending on the length of corridors required. 

Aquatic impacts of a supercritical coal-fired alternative would likely be similar to the impacts 

of the existing HNP, as the on-site option would make use of the existing plant’s cooling, 

intake, and outflow structures. The lower heat rate of the coal-fired alternative compared to 

the existing nuclear unit means that less water would be consumed for cooling and 

blowdown than in the license renewal alternative. Since continued operation of the existing 

HNP unit would result in SMALL impacts to aquatic ecology, the supercritical coal-fired 

option would also result in a SMALL impact.

A coal plant at an alternate site would likely also make use of cooling towers, and would 

incur similar aquatic impacts, which would range from SMALL to MODERATE, depending on 

characteristics of the water body used for cooling makeup.
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August 2008 8-13 NUREG-1437, Supplement 33 

Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation at HNP Site and an 

Alternate Site Using Closed-Cycle Cooling 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Land Use MODERATE Uses several hundred acres 

for plant and waste disposal, 

though much of this would 

have been previously 

disturbed; additional offsite 

land impacts for coal and 

limestone mining affects 

thousands of acres. 

MODERATE to 

LARGE

Uses nearly 2000 acres for 

plant and waste disposal. 

There would be additional 

land use impacts from 

transmission line, and rail 

spur, as well as coal and 

limestone mining. 

Ecology SMALL to 

MODERATE 

Uses undeveloped areas at 

current HNP site, plus existing 

rail and transmission corridors; 

impacts also dependent on 

land used for coal and 

limestone mining.

MODERATE to 

LARGE

Impact depends on location 

and ecology of the site, 

surface water body used for 

intake and discharge, and 

transmission line and rail 

routes; may cause habitat 

loss and fragmentation, as 

well as reduced productivity 

and biological diversity; 

impact also dependent on 

coal and limestone mining. 

Water Use and 

Quality—Surface 

Water 

SMALL Uses existing cooling tower 

system, while reduced heat 

rate means the supercritical 

coal-fired alternative requires 

less water than the existing 

plant.

SMALL to 

MODERATE 

With closed-cycle cooling, 

the impact would likely be 

SMALL, though it would 

depend on the volume of 

water withdrawn and 

discharged and the 

characteristics of the 

surface water body; impacts 

would be MODERATE. 

Water Use and 

Quality—

Groundwater 

SMALL A new plant onsite would likely 

continue to rely on Harris 

Reservoir for all water. 

SMALL to 

MODERATE 

Impacts would depend on 

the volume of water 

withdrawn and discharged 

and the characteristics of 

the aquifers, though 

groundwater would not likely 

be used for cooling tower 

makeup purposes. 
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NUREG-1437, Supplement 33 8-14 August 2008 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Air Quality MODERATE • Sulfur oxides 

1900 MT/yr 

(2090 tons/yr) 

• Nitrogen oxides 

567 MT/yr 

(625 tons/yr) 

• Total suspended 

particulates

132 MT/yr 

(145 tons/yr) 

• PM10

30.3 MT/yr 

(33.4 tons/yr) 

• Carbon monoxide 

567 MT/yr 

(625 tons/yr) 

• Small amounts of 

mercury and other 

hazardous air 

pollutants.

MODERATE Potentially the same impacts 

as the Harris site, although 

pollution-control standards 

may vary. 

Waste MODERATE Total waste production would 

be approximately 

249,000 MT/yr 

(274,000 tons/yr) of ash (after 

some is recycled) and 

scrubber sludge requiring 

approximately 59.9 ha 

(148 ac) for disposal during 

the 40-year life of the plant. 

The plant would also generate 

relatively small amounts of 

conventional, hazardous, and 

universal wastes during 

operation.

MODERATE Same impacts as at HNP 

site; waste disposal 

constraints may vary. 

Human Health SMALL Impacts are uncertain, but 

considered SMALL as the 

plant would comply with 

health-informed standards in 

the Clean Air Act and other 

relevant emissions regulations.

SMALL Similar impacts to those at 

the HNP site. 
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August 2008 8-15 NUREG-1437, Supplement 33 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Socioeconomics SMALL to 

MODERATE 

During construction, impacts 

would be SMALL to 

MODERATE. Up to 2340 

workers would be onsite 

during the peak period of the 

4-year construction period, 

followed by a reduction from 

the current HNP work force of 

720 to 234. Tax base would 

generally be preserved in 

Wake County. Impacts during 

operation would be SMALL. 

SMALL to 

LARGE

Construction impacts 

depend on location, but 

would be LARGE if the plant 

is located in an area that is 

rural or is growing less 

quickly than areas near the 

HNP site. Wake and 

surrounding counties may 

lose tax revenue and 

employment, though 

economic growth would 

likely offset much of this 

loss. Impacts at a site near 

to an urban area may be 

SMALL.

Socioeconomics

(Transportation) 

SMALL to 

MODERATE 

Transportation impacts would 

likely be SMALL to 

MODERATE, primarily with 

construction activities. 

For rail transportation of coal 

and lime, the impact would 

likely be SMALL, depending 

on the routing of coal trains.

SMALL to 

LARGE

Transportation impacts 

could be SMALL to LARGE, 

primarily during 

construction.

For rail transportation of 

coal and lime, the impact is 

likely to be SMALL, but 

dependent on the routing of 

coal trains.

Aesthetics SMALL to 

MODERATE 

Aesthetic impact due to plant 

units and stacks would be 

SMALL to MODERATE given 

current site usage and 

structures.

Rail transportation of coal and 

lime would likely have SMALL 

to MODERATE aesthetic 

impacts, depending on rail 

traffic routing and noise 

effects.

Plant noise impact would be 

SMALL given the size and 

usage of the HNP site. 

MODERATE to 

LARGE

The greatest impacts would 

be from new transmission 

lines, plant stacks, and rail 

lines to transport coal and 

lime. Impacts range from 

MODERATE to LARGE 

depending on the nature of 

the site.
Alternatives

NUREG-1437, Supplement 33 8-16 August 2008 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Historic and 

Archeological

Resources

SMALL Most construction would affect 

previously developed parts of 

the HNP site; a cultural 

resource inventory and 

mitigation measures would 

minimize any impacts on 

previously undeveloped lands. 

SMALL to 

MODERATE 

An alternate location would 

necessitate cultural resource 

studies; construction would 

likely avoid highly sensitive 

areas. Impacts likely would 

be managed or mitigated. 

Environmental

Justice

SMALL Impacts on minority and lowincome communities would be 

similar to those experienced 

by the population as a whole, 

which are SMALL. Some 

additional impacts on rental 

housing may occur during 

construction, though these 

likely would not be noticeable. 

SMALL to 

MODERATE 

Impacts would vary 

depending on population 

distribution and location of 

the site. 

• Water Use and Quality 

Surface Water. NRC staff assumes that the coal-fired generation alternative at the HNP 

site would use the existing cooling tower system and rely on Harris Reservoir for all its water 

needs. Given the supercritical coal-fired alternative’s heat rate, it would use less cooling 

makeup water than the existing HNP unit, and discharge smaller volumes of tower 

blowdown to Harris Reservoir. Surface-water impacts would be SMALL, and slightly smaller 

than the proposed action.

The supercritical coal-fired alternative at an alternate site would likely use a closed-cycle 

cooling system with cooling towers. For alternate sites, impacts on the surface water would 

depend on the volume of water needed for makeup volume discharge and the 

characteristics of the water body. Intake from and discharge to any surface body of water 

would be regulated by the North Carolina Department of Environment and Natural 

Resources (NCDENR), Division of Water Quality. These impacts would range from SMALL 

to MODERATE. 

Groundwater. HNP currently uses no groundwater. A coal-fired alternative on the Harris 

site would likely continue to rely on Harris Reservoir for all water needs. Disposal of coal 

wastes, however, could have an impact on groundwater resources, especially if onsite 

disposal results in any leakage to groundwater. NRC staff expects, however, that the 

wastes would be handled in accordance with state and Federal law. This would keep 

impacts SMALL. 
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August 2008 8-17 NUREG-1437, Supplement 33 

At an alternate site, impacts to groundwater would depend on the extent to which the plant 

would utilize groundwater, though NRC finds it unlikely that a coal-fired plant would depend 

on groundwater for cooling purposes. Given that a plant would likely use groundwater only 

for domestic and some service purposes, the impact could be SMALL to MODERATE, 

depending on the nature of the aquifers used. 

• Air Quality 

The air-quality impacts of coal-fired generation can be substantial and include emissions of 

sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon monoxide, hazardous air 

pollutants such as mercury, and naturally occurring radioactive materials. Many of these 

pollutants, however, can be effectively controlled by various technologies. 

Currently, Wake County and the neighboring counties of Johnston, Chatham, Durham, 

Franklin and Nash exceed Federal ozone standards, as so are nonattainment areas for 

ozone under the Clean Air Act (EPA 2007b). These counties are either in attainment or 

unclassified for other criteria pollutants(5) (EPA 2007b). A new supercritical coal-fired plant 

located in an ozone nonattainment area would need to purchase emissions credits from 

existing emitters of ozone-causing chemicals, including NOx.

A new supercritical coal-fired generating plant located at the HNP site would need a NonAttainment Area permit and a Title V operating permit under the Clean Air Act. A new coalfired generating plant would also need to comply with the new source performance 

standards for coal-fired plants set forth in 40 CFR 60 Subpart D(a). The standards establish 

limits for particulate matter and opacity (40 CFR 60.42(a)), SO2 (40 CFR 60.43(a)), and NOx

(40 CFR 60.44(a)). A coal-fired power plant constructed elsewhere in North Carolina or 

CP&L’s territory would need to comply with applicable provisions of the Clean Air Act, as 

well, based on those areas attainment statuses.

Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing 

future and remedying existing impairment of visibility in mandatory Class I Federal areas 

when impairment results from man-made air pollution. EPA issued a new regional haze rule 

in 1999 (64 FR 35714) (EPA 1999). The rule specifies that for each mandatory Class I 

Federal area located within a state, the State must establish goals that provide for 

reasonable progress towards achieving natural visibility conditions. The reasonable 

progress goals must provide for an improvement in visibility for the most-impaired days over 

the period of the implementation plan and ensure no degradation in visibility for the leastimpaired days over the same period (40 CFR 51.308(d)(1)). If a coal-fired plant were 

 

(5) Listed criteria pollutants are particulate matter, ground-level ozone, carbon monoxide, sulfur oxides, 

nitrogen oxides, and lead. 
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NUREG-1437, Supplement 33 8-18 August 2008 

located close to a mandatory Class I area, additional air pollution control requirements 

would be imposed. North Carolina contains five Class I areas, one of which, Swanquarter 

Wilderness Area, is potentially downwind of a coal-fired alternative at HNP (EPA 2007a).

Swanquarter, however, is approximately 298 km (185 mi) from the HNP site, and thus is 

unlikely to be affected by a coal-fired alternative. A coal-fired alternative located near 

Swanquarter or any of North Carolina’s other Class 1 Areas may need to install additional 

emissions controls. EPA more generally protects visibility with regulations in 40 CFR 51, 

Subpart P. 

In addition to Clean Air Act regulations, North Carolina restricts utilities’ aggregate emissions 

of NOx and SOx from coal-fired power plants (NC General Statutes 143-215.107D; known 

as the “Clean Smokestacks Act”). To date, CP&L has met the aims of the legislation by 

installing emissions controls technologies at older coal-fired plants (NCDENR and NCUC 

2006). Constructing a new coal-fired power plant may result in emissions levels that require 

CP&L to install emissions controls on older coal-fired power plants in order to remain in 

compliance with the law.

The supercritical coal-fired alternative would produce the following quantities of air 

pollutants:

Sulfur oxides emissions. This coal-fired alternative at the HNP site would likely use wet, 

lime-based scrubbers to remove SOx. EPA indicates that this technology can remove up to 

95% of SOx from flue gases (EPA 1998a). NRC staff projects total SOx emissions would be 

1900 MT (2090 tons) per year.

SOx emissions from a new coal-fired power plant would be subject to the requirements in 

Title IV of the Clean Air Act. Title IV was enacted to reduce emissions of SO2 and NOx, the 

two principal precursors of acid rain, by restricting emissions of these pollutants from power 

plants. Title IV caps aggregate annual power plant SO2 emissions and imposes controls on 

SO2 emissions through a system of marketable allowances. EPA issues one allowance for 

each ton of SO2 that a unit is allowed to emit. New units do not receive allowances, but are 

required to have allowances to cover their SO2 emissions. Owners of new units must 

therefore purchase allowances from owners of other power plants or reduce SO2 emissions 

at other power plants they own. Allowances can be banked for use in future years. Thus, 

provided a new coal-fired power plant is able to purchase sufficient allowances to operate, it 

would not add to net regional SO2 emissions, although it might do so locally.

North Carolina’s Clean Smokestacks Act restricts utility-level aggregate emissions of SOx

from coal-fired power plants. A new coal-fired power plant in North Carolina may result in 

emissions levels that require CP&L to reduce emissions from other, older power plants.

Nitrogen oxides emissions. This new coal-fired plant would likely use a variety of NOxcontrol technologies, including low-NOx burners, overfire air, and selective catalytic 
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August 2008 8-19 NUREG-1437, Supplement 33 

reduction. EPA notes that when these emissions controls are used in concert, they can 

reduce NOx emissions by up to 95% (EPA 1998a), for total annual emissions of 577 MT 

(625 tons).

Section 407 of the Clean Air Act establishes technology-based emission limitations for NOx

emissions. A new coal-fired power plant would be subject to the new source performance 

standards for such plants as indicated in 40 CFR 60.44a(d)(1). This regulation, issued on 

September 16, 1998 (63 FR 49453) (EPA 1998b), limits the discharge of any gases that 

contain nitrogen oxides (expressed as NO2) in excess of 200 nanograms (ng) per joule (J) of 

gross energy output (equivalent to 1.6 lb/MWh), based on a 30-day rolling average. 

NRC staff estimates that the total annual NOx emissions for a new coal-fired power plant 

would be approximately 11.2 percent of the new source performance standard emission 

rate. As HNP is located in an ozone non-attainment area, the plant operator would need to 

purchase emissions allowances to offset this amount of emissions. 

EPA further restricts the total amount of NOx that can be emitted on a State level basis. In 

the 2007 ozone season (May 1–September 30) North Carolina may emit 150,000 MT 

(165,306 tons) of NOx. A new coal-fired power plant would need to offset emissions 

through credit purchases or from a set-aside pool. 

North Carolina’s Clean Smokestacks Law restricts utility-level aggregate emissions of NOx

from coal-fired power plants. A new coal-fired power plant in North Carolina may result in 

emissions levels that require CP&L to reduce emissions from other coal-fired power plants. 

Particulate emissions. This new coal-fired power plant would use fabric filters or 

electrostatic precipitators to remove particulates from flue gases. CP&L indicates that these 

technologies, in concert with emissions controls, would remove 99.9% of particulate matter 

(Progress Energy 2006b). EPA notes that filters or precipitators are each capable of 

removing in excess of 99% of particulate matter, and that SO2 scrubbers further reduce 

particulate matter emissions (EPA 1998a). As such, NRC staff believes CP&L’s removal 

factor is appropriate. Based on this, the new supercritical coal-fired plant would emit 

132 MT (145 tons) of total suspended particulates and approximately 30.3 MT (33.4 tons) of 

particulate matter having an aerodynamic diameter less than or equal to 10 microns (PM10)

(40 CFR 50.6) annually. In addition, coal-handling equipment would introduce fugitive 

particulate emissions. 

During the construction of a coal-fired plant, on-site activities would generate fugitive dust.

In addition, vehicles and motorized equipment would create exhaust emissions during the 

construction process. These impacts would be intermittent and short-lived, however. In 

addition, to minimize dust generation, construction crews would use applicable dust-control 

measures.
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NUREG-1437, Supplement 33 8-20 August 2008 

Carbon monoxide emissions. Based on EPA emission factors (EPA 1998a), NRC staff 

estimates that the total carbon monoxide emissions would be approximately 567 MT 

(625 tons) per year.

Hazardous air pollutants including mercury. In December 2000, EPA issued regulatory 

findings on emissions of hazardous air pollutants from electric utility steam-generating units 

(EPA 2000b). EPA determined that coal- and oil-fired electric utility steam-generating units 

are significant emitters of hazardous air pollutants. Coal-fired power plants were found by 

EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen 

fluoride, lead, manganese, and mercury (EPA 2000). EPA concluded that mercury is the 

hazardous air pollutant of greatest concern. EPA found that (1) there is a link between coal 

consumption and mercury emissions; (2) electric utility steam-generating units are the 

largest domestic source of mercury emissions; and (3) certain segments of the 

U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are 

believed to be at potential risk of adverse health effects due to mercury exposures resulting 

from consumption of contaminated fish (EPA 2000). Accordingly, on March 15, 2005, EPA 

issued the Clean Air Mercury Rule to permanently cap and reduce mercury emissions from 

coal-fired power plants (EPA 2007c). A new coal-fired power plant would need to comply 

with performance standards contained in 40 CFR 60.45(a), requiring that the plant emit no 

more than 0.0025 nanograms per Joule output (20 x 10-6 lbs. per MWh). In addition, to the 

extent the plant would emit any mercury, the plant owners would need to purchase mercury 

allowances or reduce emissions to ensure that North Carolina emits no more than 1.133 

tons of mercury containing gases in 2010, and 0.447 tons of mercury containing gases in 

2018 (EPA 2006). 

Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring 

elements. Alex Gabbard, a researcher at Oak Ridge National Laboratory, indicates that 

uranium concentrations are generally in the range of 1 to 10 parts per million (ppm) and 

thorium concentrations are generally about 2.5 times this level (Gabbard 1993). The U.S. 

Geological Survey (USGS) indicates that Western and Illinois Basin coals contain uranium 

and thorium at roughly equal concentrations, mostly between 1 and 4 ppm, but also 

indicates that some coals may contain concentrations as high as 20 ppm of both elements 

(USGS 1997). Gabbard indicates that a 1000 MWe coal-fired plant would release roughly 

4.7 MT (5.2 tons) of uranium and 11.6 MT (12.8 tons) of thorium annually (Gabbard 1993).

Both USGS and Gabbard indicate that almost all of the uranium, thorium, and most decay 

products remain in solid coal wastes, especially in the fine glass spheres that constitute 

much of coal’s fly ash. Modern emissions controls, such as those included for this coal-fired 

alternative, allow for recovery of greater than 99% of these solid wastes (EPA 1998a), thus 

retaining most of coal’s radioactive elements in solid form rather than releasing it to the 

atmosphere. Even after concentration in coal waste, the level of radioactive elements 

remains relatively low (typically 10 to 100 ppm) and consistent with levels found in naturally 

occurring granites, shales, and phosphate rocks (USGS 1997). The level of uranium and 
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August 2008 8-21 NUREG-1437, Supplement 33 

thorium contained in coal wastes and disposed of in the environment exceed the levels of 

uranium and thorium released to the environment by the existing nuclear power plant. 

Carbon dioxide. A coal-fired plant would also have unregulated carbon dioxide emissions 

during operations as well as during coal mining and processing, and coal and lime 

transportation. Burning bituminous coal in the U.S. emits roughly 205.3 lbs CO2 per million 

Btu (Hong and Slatick 1994). The supercritical coal-fired plant would emit approximately 

6,320,000 tons of CO2 per year (5,730,000 MT).

Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but 

implied that air impacts would be substantial. The GEIS also mentioned global warming 

from unregulated carbon dioxide emissions and acid rain from SOx and NOx emissions as 

potential impacts (NRC 1996). The above analysis shows that emissions of air pollutants, 

including SOx, NOx, carbon monoxide, and particulates, exceed those produced by the 

existing nuclear power plant, as well as those of the other alternatives considered in this 

section. Operational emissions of carbon dioxide are also much greater under the coal-fired 

alternative.(6)

Adverse human health effects such as cancer and emphysema have also been associated 

with air emissions from coal combustion. NRC analysis for a coal-fired alternative at the 

HNP site and an alternative site indicates that impacts from the coal-fired alternative would 

have clearly noticeable effects, but given existing regulatory regimes, permit requirements, 

and emissions controls, the coal-fired alternative would not destabilize air quality. Thus, the 

appropriate characterization of air impacts from coal-fired generation would be MODERATE.

Siting a coal-fired generation plant at a site other than HNP would not significantly change 

air-quality impacts, although it would result in installing more- or less-stringent pollutioncontrol equipment to meet applicable local requirements, or cause the plant’s owner to 

more- or less-actively participate in various emissions trading schemes. Impacts to air 

quality at an alternate site would be MODERATE. 

• Waste

Coal combustion generates waste in the form of ash, and emissions controls collect 

additional ash while converting gaseous pollutants to liquid or semisolid sludge. Two 

439.5-MWe, net, coal-fired units would generate approximately 357,000 MT (393,000 tons) 

of this waste annually for 40 years. Of this waste, approximately 108,000 MT (119,000 tons) 

(41% of the ash content) would be recycled, according to CP&L, leaving a total of 

 

(6) Table S-3 in 10 CFR 51.51 indicates that electrical energy consumed during the uranium fuel cycle to 

supply a 1000 MWe is equivalent to the electricity produced by a 45 MWe coal-fired power plant.
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NUREG-1437, Supplement 33 8-22 August 2008 

approximately 249,000 MT (274,000 tons) that would be landfilled onsite. This waste would 

require approximately 59.9 ha (148 ac) of land area over the 40-year plant life (assuming a 

waste pile 9.15 m [30.0 ft] high). As mentioned in the air quality section, this waste would 

also contain levels of uranium and thorium in concentrations similar to those found in 

naturally occurring granites, shales, and phosphate rocks (USGS 1997). In addition to coal 

combustion wastes, a supercritical coal-fired alternative would also produce small amounts 

of domestic and hazardous wastes.

Waste impacts to groundwater and surface water would extend beyond the operating life of 

the plant if leaching and runoff from the waste storage area makes way into groundwater or 

surface water. Disposal of the waste would noticeably affect land use and groundwater 

quality if not properly managed, but with appropriate management and monitoring, effects 

on groundwater water resources would be prevented. After closure of the waste site and 

revegetation, the land would be available for other uses. Waste impacts from operating this 

coal-fired alternative, then, are MODERATE, as waste impacts would be noticeable, but 

they would not destabilize any resources.

Debris would be generated during construction activities. These would likely be disposed 

onsite, when possible. Overall, this amount of waste would be small compared to 

operational waste generated, and many construction wastes can be recycled. As such, 

construction-stage waste impacts would be SMALL. 

For all of the preceding reasons, the appropriate characterization of impacts from waste 

generated by the supercritical coal-fired alternative would be MODERATE; the impacts 

would be clearly noticeable, but would not destabilize any important resource. 

Siting the facility at a site other than HNPS would not alter waste generation, although other 

sites might have more constraints on disposal locations. If a coal facility was sited on a 

previously developed location, then there may also be fewer constraints on waste disposal, 

but the overall impact level would not likely change. Therefore, the impacts would remain 

MODERATE.

• Human Health 

Coal-fired power generation introduces worker risks from coal and limestone mining, from 

coal and lime transportation, and from disposal of coal combustion waste. In addition there 

are public risks from inhalation of stack emissions. Emission impacts can be widespread 

and health risks difficult to quantify. The coal-fired alternative also introduces the risk of 

coal-pile fires and attendant inhalation risks. 

Regulatory agencies, including EPA and State agencies, set air emission standards and 

requirements based on human health impacts. These agencies also impose site-specific 

emission limits as needed to protect human health. As discussed previously, EPA has 
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August 2008 8-23 NUREG-1437, Supplement 33 

concluded that certain segments of the U.S. population (e.g., the developing fetus and 

subsistence fish-eating populations) are believed to be at potential risk of adverse health 

effects due to mercury exposures from sources such as coal-fired power plants and has 

taken action to address mercury emissions from coal-fired power plants. In the absence of 

more quantitative data, human health impacts from radiological doses and inhaling toxins 

and particulates generated by burning coal would be characterized as SMALL. 

• Socioeconomics

Construction of the supercritical coal-fired alternative would take approximately 4 years 

(DOE/EIA 2006b). The NRC staff assumed that construction would take place while HNP 

continues operation and would be completed by the time it permanently ceases operations 

in 2026. The construction work force would be expected to include up to 2340 workers 

(NRC 1996). These workers would be in addition to the approximately 720 workers 

currently employed at HNP. During construction, the surrounding communities would 

experience an increased demand for rental housing and public services, though this would 

be moderated by the proximity of the site to urban areas. After construction, the 

communities may be affected by the loss of construction jobs, though this would likely be 

offset by the area’s rapid growth. 

If the coal-fired replacement plant were constructed at the HNP site and HNP were to be 

decommissioned, the area would experience a loss of approximately 486 permanent highpaying jobs (from 720 employees for HNP to 234 for the coal-fired plant), with a 

commensurate, relatively minor reduction in demands on socioeconomic resources and tax 

contributions to the regional economy. The coal-fired plant would provide a new tax base to 

offset the loss of tax base associated with decommissioning of the HNP unit in Wake 

County. Other counties would likely experience little impact, as HNP pays 90% of its local 

taxes to Wake County. Since the region’s growing economy effectively mitigates most 

socioeconomic impacts of both construction and operation, the appropriate characterization 

of non-transportation socioeconomic impacts for a coal-fired plant constructed at the HNP 

site would be SMALL to MODERATE. 

Construction of a supercritical coal-fired power plant at an alternate site would relocate 

some socioeconomic impacts, but would not eliminate them. The communities around HNP 

would experience relatively minor impacts of HNP operational job loss, and the communities 

around the new site would have to absorb the impacts of a large, temporary work force (up 

to 2340 workers at the peak of construction) and a permanent work force of approximately 

234 workers. In the GEIS, the NRC staff stated that socioeconomic impacts at a rural site 

would be larger than at an urban site, because more of the peak construction work force 

would need to move to the area to work. The HNP site is in the Raleigh-Durham-Chapel Hill 

metropolitan area and is therefore not considered a rural site. Alternate sites would need to 

be analyzed on a case-by-case basis. Alternate industrial sites, however, tend to be close 
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NUREG-1437, Supplement 33 8-24 August 2008 

to metropolitan areas, and may still have remaining transportation infrastructure nearby.

Socioeconomic impacts at a rural site would be LARGE, while impacts at previously 

developed industrial site would be SMALL to MODERATE. 

• Transportation

During the 4-year construction period of replacement coal-fired units, up to 2340 

construction workers would be commuting to the site in addition to the current 720 workers 

at HNP. The addition of these workers would increase traffic loads on existing highways, 

particularly on surface roads in and around the plant. Given that the area has good access 

to highways, however, these impacts would be SMALL to MODERATE. Transportationrelated impacts associated with commuting construction workers at an alternate site are site 

dependent, but would be SMALL to LARGE. Transportation impacts related to commuting 

of plant operating personnel would also be site dependent, but would be characterized as 

SMALL to MODERATE.

For transportation related to commuting of plant operating personnel, the impacts would be 

considered SMALL. The maximum number of plant operating personnel would be 

approximately 234 compared to the current HNP work force of 720. Therefore, traffic 

impacts associated with plant personnel commuting to a coal-fired plant would be expected 

to be SMALL, and smaller than the impacts of HNP license renewal. 

For rail transportation related to coal and lime delivery to the HNP site, the impacts would be 

SMALL, depending on coal train routes. Approximately 250 coal unit trains per year (each 

with 100 cars carrying 100 tons of coal each) would be needed to deliver the coal and lime 

for the two coal-fired units. A total of 10 train trips would be expected per week, or nearly 

2 trips per day on the spur leading to the plant, because for each full train delivery there 

would be an empty train returning from the plant. At an alternate site, coal and lime would 

likely be delivered by rail as well. Transportation impacts would depend upon the site 

location. Socioeconomic impacts associated with rail transportation would be SMALL.

Socioeconomic impacts associated with rail transportation on a previously developed site 

would be SMALL.

• Aesthetics

If sited at the current HNP location, the coal-fired power plant units would be as much as 

60 m (200 ft) tall and would likely not be visible offsite due to extensive forestation. The two 

exhaust stacks would be somewhere in the range of 120 to 185 m (400 to 600 ft) high and 

would be visible offsite for many miles. Given the current presence of a cooling tower and 

its plumes, as well as other plant structures on-site, the addition of plant stacks would not 

drastically increase visual impacts. These would be noticeable, but would not likely 

destabilize the resource. The units and associated stacks would also be visible at night 
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August 2008 8-25 NUREG-1437, Supplement 33 

because of outside lighting. Visual impacts of a new coal-fired plant could be mitigated by 

landscaping and color selection for buildings that is consistent with the environment. Visual 

impact at night could be mitigated by reduced lighting where possible and appropriate 

shielding. Overall, the addition of a coal-fired unit and the associated stack at the HNP site

would likely have a SMALL to MODERATE aesthetic impact. 

Coal-fired generation would introduce mechanical sources of noise that would be audible 

offsite, although given the low population near the plant’s property, offsite noise is unlikely to 

be obtrusive. Sources contributing to total noise produced by plant operation would be 

classified as continuous or intermittent. Continuous sources include the mechanical 

equipment associated with normal plant operations. Intermittent sources include the 

equipment related to coal handling, solid-waste disposal, transportation related to coal and 

lime delivery, use of outside loudspeakers, and the commuting of plant employees. The 

incremental noise impacts of a coal-fired plant compared to existing HNP operations would 

be SMALL.

Noise impacts associated with rail delivery of coal and lime to a plant at the HNP site would 

be most significant for residents living in the vicinity of the facility and along the rail route.

Although noise from passing trains significantly raises noise levels near the rail corridor, the 

short duration of the noise reduces the impact. Given the frequency of train transport and 

the potential for many residents within hearing distance of the rail route, the impacts of noise 

would be SMALL to MODERATE, depending on train routes. 

At an alternate site, plant buildings, exhaust stacks, cooling towers, and cooling tower 

plumes would create aesthetic impacts. There would also be an aesthetic impact 

associated with construction of a new transmission line to connect to other lines to enable 

delivery of electricity. Noise and light from the plant would be detectable offsite. Aesthetic 

impacts at the plant site would be mitigated if the plant were located in an industrial area 

adjacent to other power plants or industrial facilities. Noise impacts from a rail spur, if 

required, would be similar to the impacts at the existing site. Overall the aesthetic impacts 

associated with locating at an alternate site would be categorized as MODERATE to 

LARGE. Some of these issues would be rectified if the coal plant was sited at a previously 

developed site, as many contain some level of rail infrastructure, and would be in areas 

previously developed for industrial uses. Impacts at a previously developed site would be 

SMALL to MODERATE.

• Historic and Archaeological Resources 

At the HNP site or an alternate site, a cultural resource inventory would be needed for any 

onsite property that has not been previously surveyed. Other lands, if any, that are acquired 

to support the plant would also need an inventory of field cultural resources, identification 

and recording of existing historic and archaeological resources, and possible mitigation of 
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NUREG-1437, Supplement 33 8-26 August 2008 

adverse effects from subsequent ground-disturbing actions related to physical expansion of 

the plant site. 

Before beginning construction at an alternate site, surveys would likely be needed to 

identify, evaluate, and address mitigation of the potential impacts of new plant construction 

on cultural resources. The studies would likely be needed for all areas of potential 

disturbance at the proposed plant site and along associated corridors where new 

construction would occur (e.g., roads, transmission corridors, rail lines, or other rights-ofway).

Historic and archaeological resource impacts can generally be effectively managed and as 

such would be considered SMALL for the existing site and likely SMALL to MODERATE at a 

new site. For a previously developed site, most of which have already been intensively 

developed, impact on cultural and historic resources would also be SMALL. Previous 

development would likely have either removed or surveyed items of archaeological interest. 

• Environmental Justice 

No environmental impacts were identified that would result in disproportionately high and 

adverse environmental impacts on minority and low-income populations if a replacement 

coal-fired plant were built at the HNP site. Some impacts on rental and other temporary 

housing availability and lease prices during construction might occur, and this could 

disproportionately affect the minority and low-income populations.

Impacts on minority and low-income populations due to the shutdown of HNP would depend 

on the number of jobs and the amount of tax revenue lost to the communities surrounding 

the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue 

generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it 

is likely that these losses would be replaced by the development of new businesses and 

new sources of tax revenue in the region. Since CP&L’s tax payments represent a small 

percentage of Wake County’s total annual property tax revenue, it is unlikely that social 

services would be seriously affected. Therefore, minority and low-income populations in the 

vicinity of HNP would not likely experience any disproportionately high and adverse 

socioeconomic impacts from the shutdown of HNP. 

The environmental effect of plant shutdown would reduce the amount of operational impacts 

on the environment. Therefore, minority and low-income populations in the vicinity of HNP 

would not likely experience any disproportionately high and adverse environmental impacts 

from the shutdown of HNP. 

Impacts at other sites would depend upon the site chosen and the nearby population 

distribution, but would be SMALL to MODERATE for alternate sites. For previously 
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August 2008 8-27 NUREG-1437, Supplement 33 

developed industrial sites, impacts would be slightly larger, depending on where low-income 

populations are located. 

8.2.2 Coal-Fired Integrated Gasification Combined-Cycle (IGCC) Generation 

The second coal-fired option considered by NRC as an alternative to HNP license renewal is an 

integrated gasification combined-cycle (IGCC) plant. IGCC plants operate very differently from 

conventional coal plants, and were not considered by NRC staff in the GEIS. An IGCC coalfired plant first heats coal in a gasifier with carefully controlled amounts of water and oxygen.

The resulting gas stream (called synthesis gas, or syngas) contains primarily carbon monoxide 

and hydrogen. Most coal impurities remain in gasifier waste material, called slag, while 

gasifiers convert sulfur-containing compounds to either elemental sulfur or sulfuric acid, both of 

which can be marketed as commodities. Gaseous pollutants, mercury among them, can be 

removed from the syngas stream prior to combustion. Following gasification and pollutant 

removal, the gas stream travels to a conventional combined-cycle power plant, similar in 

construction to a natural-gas-fired combined-cycle power plant. First, the gas stream burns in a 

combustion turbine. Then, the still-hot gas mixture gives up most of the remaining heat to water 

in a heat recovery steam generator. While IGCC plants can theoretically achieve thermal 

efficiencies approaching 50% (DOE/EIA 2006a), the technology is still relatively young from a 

utility-scale commercial perspective. No IGCC plant with a capacity as large as HNP has yet 

been constructed in the U.S., though NRC staff notes considerable utility interest in this 

technology for the ability to effectively reduce emissions of many air pollutants as well as to 

potentially produce a separate carbon dioxide stream for eventual sequestration. Given IGCC’s 

limited commercial implementation in the U.S., EPA has not yet developed detailed emissions 

factors for the technology. In general, NRC staff has adopted emissions factors from DOE 

(DOE 1999) as cited in the HNP ER in order to characterize emissions from the IGCC coal-fired 

alternative.

In the HNP ER, CP&L adopts a heat rate of 6870 BTU/kWh for an IGCC coal-fired alternative.

NRC staff notes that this heat rate is significantly lower than the 8309 Btu/kWh reported by EIA 

for forecasting purposes (DOE/EIA 2006a). NRC staff will adopt EIA’s assumed heat rate for 

this analysis, as it more-closely approximates existing IGCC plants (e.g., Tampa Electric 

Company’s Polk Plant and the Wabash River Coal Gasification Repowering Project; see DOE 

2004 and DOE 2000). CP&L’s analysis assumed three gas turbine units each with net outputs 

of 293 MWe each (nearly 326 MWe gross output assuming 10% onsite power consumption; this 

level of onsite consumption is consistent with experience at the Wabash River site) (DOE 2000). 

Although the operating license renewal period is only 20 years, NRC staff analyzed the impact 

of operating the IGCC coal-fired alternative for 40 years, as this may be a reasonable projection 

of the operating life of an IGCC coal-fired plant and is consistent with the analysis NRC staff 

conducted for the supercritical coal-fired alternative. 
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NUREG-1437, Supplement 33 8-28 August 2008 

The IGCC coal-fired plant, with a gross output of 977 MWe, would consume approximately 

2.23 million MT (2.45 million tons) per year of pulverized bituminous coal with an ash content of 

approximately 11.6 percent based on averages for North Carolina coal consumption (EIA/DOE 

2006c). In an IGCC coal-fired-plant, the gasifier consolidates solid waste in vitrified slag, 

instead of producing ash as in a coal-fired boiler. For HNP, the IGCC coal-fired alternative 

would produce approximately 258,000 MT (285,000 tons) of slag and 19,200 MT (21,200 tons) 

of elemental sulfur in a year. CP&L indicated that the elemental sulfur as well as 90% of slag 

would be marketed. Based on IGCC’s ability to remove wastes prior to syngas combustion, 

CP&L also indicated that no additional scrubbing of exhaust streams would be necessary 

(Progress Energy 2006b).

At the HNP site, coal would likely be delivered by rail, while slag and sulfur for reuse would likely 

be removed by rail or by truck. The IGCC coal fired option would likely require approximately 

245 100-car unit trains per year, or roughly 5 trains or 10 trips per week. As such, the existing 

rail spur would need to be improved to allow for these deliveries. Impacts from improving the 

rail spur would be SMALL, as the spur already exists and is currently used for industrial 

purposes.

For purposes of this section, the NRC staff assumed that an IGCC coal-fired plant located at 

either the HNP site or an alternate site would use a closed-cycle cooling system, as the current 

HNP unit does. CP&L did not analyze an alternate site for an IGCC coal-fired plant in the ER.

The NRC staff discusses the overall impacts of the IGCC coal-fired generating system in the 

following sections and summarizes the analysis in Table 8-3. The extent of impacts at an 

alternate site would depend on the location of the particular site selected. 

• Land Use 

The existing facilities and infrastructure at the HNP site would be used to the extent 

practicable, limiting the amount of new construction necessary. A new IGCC coal-fired plant 

may be able to use the existing cooling tower system, switchyard, offices, and transmission 

line rights-of-way. Much of the land that would be used has been previously disturbed. As 

noted above, a coal-fired plant on-site would require improvements to the existing rail line in 

order to support coal and lime deliveries.

NRC noted in the GEIS (NRC 1996) that a 1000 MW coal-fired alternative would necessitate 

converting approximately 700 ha (1700 ac) of land to industrial uses. NRC staff recognizes 

that, as IGCC plants tend to be more mechanically similar to gas-fired power plants than to 

coal-fired power plants. Therefore, the amount of land conversion required by a 

conventional coal plant is likely greater than the IGCC alternative would require. In addition, 

NRC staff recognizes that some amount of existing HNP auxiliary structures, like offices and 

parking lots, as well as intake and cooling tower systems, would also be used by the IGCC 
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August 2008 8-29 NUREG-1437, Supplement 33 

alternative. NRC staff thus indicates that the IGCC alternative would likely require several 

hundred acres, but fewer than the supercritical coal-fired alternative (Progress Energy 

indicated that the IGCC option would require 80.9 ha [200 ac], which is 20.2 ha [50 ac] fewer 

than the conventional coal alternative) (Progress Energy 2006b).

Additional land-use changes would occur offsite in an undetermined coal-mining area to 

supply coal for the plant. Assuming a mix of coal supply similar to North Carolina’s current 

coal supply, this land disturbance would likely occur mostly in West Virginia (EIA/DOE 

2006c). In the GEIS, the NRC staff estimated that approximately 8900 ha (22,000 ac) would 

be affected for mining the coal and disposing of the waste to support a 1000 MWe coal plant 

during the operational life. An IGCC coal-fired alternative to replace HNP would thus require 

approximately 8700 ha (21,500 ac) of land, 4.37 ha (10.8 ac) of which the plant would use 

for onsite slag disposal over the 40-year life. Coal mining would likely take place in existing 

coal-mining regions and in accordance with applicable mining regulations. Partially 

offsetting this offsite land use would be the elimination of the need for uranium mining to 

supply fuel for HNP. In the GEIS, the NRC staff estimated that approximately 400 ha 

(1000 ac) would be affected for mining the uranium and processing it during the operating 

life of a 900 MW nuclear power plant.

As mentioned earlier, while the existing rail spur could be used to deliver coal to the site, it 

would be likely that the spur would require improvements to support the significant increase 

in traffic involved in servicing the IGCC.

The impact of an IGCC coal-fired generating unit on land use located at the existing HNP 

site would be best characterized as MODERATE, and would be greater than the proposed 

action.

Construction of the IGCC coal-fired generation alternative at an alternate site would impact 

significantly more than 80.9 ha (200 ac) for plant and auxiliary structures, as well as tens to 

thousands of acres for transmission lines and a rail spur. Waste disposal would require 

4.37 ha (10.8 ac). An IGCC alternative at a different site would also require approximately 

8700 ha (21,500 ac) for coal mining. Thus, impacts would range from MODERATE to 

LARGE, depending on length of transmission line corridors and the rail spur.

• Ecology

Locating an IGCC coal-fired plant at the HNP site would affect ecological resources, but 

existing site maintenance practices and the site’s industrial nature would minimize additional 

impacts from the new plant. Given the IGCC plant’s easily-marketed waste streams, 

impacts from onsite waste disposal are smaller than for the supercritical coal-fired plant.

Impacts to terrestrial ecology would be SMALL to MODERATE. At an alternate site, 

constructing transmission lines and a rail spur would incur additional impacts, along with the 
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NUREG-1437, Supplement 33 8-30 August 2008 

land used to construct plant facilities and infrastructure. These impacts would be 

MODERATE to LARGE. 

Aquatic ecology impacts would be smaller than the impacts of the HNP unit, as the lower 

heat rate of the IGCC coal-fired option means less water would be consumed for cooling.

The on-site option would make use of the existing plant’s cooling, intake, and outflow 

structures. Since the existing HNP unit already has a SMALL impact on aquatic ecology, 

and the IGCC alternative has a smaller impact, the impact level remains SMALL. An IGCC 

coal-fired plant at an alternate site would likely also make use of cooling towers, and would 

incur similar aquatic impacts, which would range from SMALL to MODERATE, depending on 

the characteristics of the water body used for cooling.

Table 8-3. Summary of Environmental Impacts of IGCC Coal-Fired Generation at HNP Site and 

an Alternate Site Using Closed-Cycle Cooling 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Land Use MODERATE May use 80.9 ha (200 ac) for 

plant structures and 4.37 ha 

(10.8 ac) for waste disposal; 

impact would be less than the 

supercritical coal-fired 

alternative; additional offsite 

land impacts for coal mining. 

MODERATE 

to LARGE 

Uses several hundred 

acres for plant, offices, 

parking, and plant facilities. 

 Transmission line, rail 

spur, and coal mining 

require additional land. 

Ecology SMALL to 

MODERATE 

Uses undeveloped areas at 

current HNP site, plus existing 

rail and transmission corridors.

MODERATE 

to LARGE 

Impacts depend on the 

location and ecology of the 

site, characteristics of the 

surface water body used 

for intake and discharge, 

and transmission line and 

rail routes. Construction 

may result in habitat loss 

and fragmentation; reduced 

productivity and biological 

diversity. 

Water Use and 

Quality—Surface 

Water 

SMALL Uses existing cooling tower 

system, and uses less water 

than the existing HNP. 

SMALL to 

MODERATE 

With closed-cycle cooling, 

impact likely to be SMALL, 

though it would depend on 

the volume of water 

withdrawn and discharged, 

as well as the 

characteristics of the 

surface water body. 
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August 2008 8-31 NUREG-1437, Supplement 33 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Water Use and 

Quality—

Groundwater 

SMALL A new plant onsite would likely 

continue to rely on Harris 

Reservoir for all water. NRC 

staff expects groundwater 

impacts only if coal slag 

contaminates groundwater. 

SMALL to 

MODERATE 

Impact would depend on 

the volume of water 

withdrawn and discharged 

and the characteristics of 

the aquifers, though NRC 

staff assumes groundwater 

would not be used for 

cooling makeup water. 

Air Quality MODERATE • Sulfur oxides 

466 MT/yr (514 tons/yr) 

• Nitrogen oxides 

658 MT/yr (725 tons/yr) 

• Total suspended 

particulates

52.1 MT/yr (57 tons/yr) 

• PM10

52.1 MT/yr (57 tons/yr) 

• Carbon monoxide 

822 MT/yr (906 tons/yr) 

• Mercury removed by 

syngas-stage controls 

MODERATE Potentially the same 

impacts as at the HNP site, 

although pollution-control 

standards may vary. 

Waste SMALL Total slag disposed onsite 

would be approximately 

25,800 MT (28,500 tons) per 

year, since most slag, 

232,000 MT/yr (256,000 

tons/yr), would be reused. Over 

the plant’s lifespan, 4.37 ha 

(10.8 ac) would be required for 

waste disposal. 

SMALL to 

MODERATE 

Same impacts as at the 

HNP site; waste disposal 

constraints may vary. 

Human Health SMALL Impacts are uncertain, but 

considered SMALL as the plant 

would comply with healthinformed standards in the Clean 

Air Act and other relevant 

emissions regulations. 

SMALL Similar impacts as at the 

HNP site. 
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NUREG-1437, Supplement 33 8-32 August 2008 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Socioeconomics SMALL to 

MODERATE 

During construction, impacts 

would be MODERATE. 

Between 1170 and 2440 

workers during the peak period 

of the 4-year construction 

period, followed by reduction 

from current HNP work force of 

720 to between 147 and 244 

workers. Tax base would 

generally be preserved in Wake 

County. Impacts during 

operation would be SMALL. 

SMALL to 

LARGE

Construction impacts 

depend on location, but 

would be LARGE if the 

plant is located in an area 

that is rural or is growing 

less quickly than areas 

near the HNP site. Wake 

and surrounding counties 

may lose tax revenue and 

employment, though 

economic growth would 

likely offset much of this 

loss. Impacts at a site near 

to an urban area may be 

SMALL.

Socioeconomics

(Transportation) 

SMALL to 

MODERATE 

Transportation impacts would 

be SMALL to MODERATE, 

primarily due to construction 

activities.

For rail transportation of coal 

and lime, the impact would 

likely be SMALL, depending on 

the routing of coal trains.

SMALL to 

LARGE

Transportation impacts 

would be SMALL to 

LARGE, primarily due to 

construction activities. 

For rail transportation of 

coal, the impact would be 

SMALL, but dependent on 

the routing of coal trains.

Aesthetics SMALL to 

MODERATE 

Aesthetic impact due to plant 

units and stacks would be 

SMALL.

Rail transportation of coal would 

have a SMALL to MODERATE 

aesthetic impact. 

Noise impact would be SMALL 

given the size of the site. 

SMALL to 

LARGE

Overall impacts could vary 

widely, with the greatest 

impacts from new 

transmission lines, rail lines 

to transport coal, and 

cooling towers. 

Historic and 

Archeological

Resources

SMALL Some construction would affect 

previously developed parts of 

the HNP site; cultural resource 

inventory would minimize any 

impacts on undeveloped lands. 

SMALL to 

MODERATE 

Alternate location would 

necessitate cultural 

resource studies; 

construction would likely 

avoid highly sensitive 

areas. Impacts would be 

managed.
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August 2008 8-33 NUREG-1437, Supplement 33 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Environmental

Justice

SMALL Impacts on minority and lowincome communities would be 

similar to those experienced by 

the population as a whole. 

Some impacts on rental 

housing may occur during 

construction; loss of 476 to 573 

operating jobs could reduce 

employment prospects for 

minority and low-income 

populations, though this would 

likely be offset by economic 

growth. 

SMALL to 

MODERATE 

Impacts would vary 

depending on population 

distribution and location of 

the site.

• Water Use and Quality 

Surface Water. The IGCC coal-fired generation alternative at the HNP site is assumed to 

use the existing cooling tower system, which would minimize incremental water-use and 

quality impacts. Given the IGCC coal plant’s heat rate, it would likely use less water than 

the existing HNP unit. As such, impacts to surface water use and quality would be SMALL.

Alternate sites would likely use a closed-cycle cooling system with cooling towers. For 

alternate sites, the impact on the surface water would depend on the volume of water 

needed for makeup water, the discharge volume, and the characteristics of the water body 

used for intake and discharge. Intake from and discharge to any surface body of water 

would be regulated by NCDENR. The impacts would be SMALL to MODERATE. 

Groundwater. HNP uses no groundwater. An IGCC coal-fired alternative on the HNP site 

would likely continue to rely on Harris Reservoir for all water needs and not use any 

groundwater. Provided operators properly landfill leftover slag, the impact to groundwater 

would be SMALL.

At an alternate site, impacts to groundwater would depend on the extent to which the plant 

utilizes groundwater, though NRC finds it unlikely that a coal-fired IGCC plant would depend 

on groundwater for cooling purposes. Given that a plant would likely use groundwater only 

for domestic and some service purposes, the impact could be SMALL to MODERATE, 

depending on the nature of the aquifers used. 
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• Air Quality 

The air-quality impacts of IGCC coal-fired generation can be substantial, though markedly 

less than conventional coal technologies in several important areas. These include lower 

emissions of mercury as well as particulate matter. Pre-scrubbed levels of sulfur oxides 

(SOx) and nitrogen oxides (NOx) are also typically much lower than conventional coal 

technologies. In addition, naturally occurring radioactive materials would likely remain in 

slag much as they remain in solid ash products in conventional coal plants.

Currently, Wake County and the neighboring counties of Johnston, Chatham, Durham, 

Franklin and Nash are ozone nonattainment areas under the Clean Air Act (EPA 2007b).

These counties are either in attainment or unclassified for other criteria pollutants (EPA 

2007b). A new IGCC coal-fired plant located in an ozone non-attainment area would need 

to purchase emissions credits from existing emitters of ozone-causing chemicals, including 

NOx.

A new IGCC coal-fired generating plant located at the HNP site would also need a 

Nonattainment Area permit and a Title V operating permit under the Clean Air Act. A new 

coal-fired generating plant located at an alternate site would also need to comply with the 

new source performance standards for coal-fired plants set forth in 40 CFR 60 Subpart D(a). 

The standards establish limits for particulate matter and opacity (40 CFR 60.42(a)), SO2 (40 

CFR 60.43(a)), and NOx (40 CFR 60.44(a)). A coal-fired power plant constructed elsewhere 

in North Carolina or CP&L’s territory would need to comply with applicable provisions of the 

Clean Air Act, as well, based on those areas attainment statuses.

Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing 

future and remedying existing impairment of visibility in mandatory Class I Federal areas 

when impairment results from man-made air pollution. EPA issued a new regional haze rule 

in 1999 (64 FR 35714) (EPA 1999). The rule specifies that for each mandatory Class I 

Federal area located within a state, the State must establish goals that provide for 

reasonable progress towards achieving natural visibility conditions. The reasonable 

progress goals must provide for an improvement in visibility for the most-impaired days over 

the period of the implementation plan and ensure no degradation in visibility for the leastimpaired days over the same period (40 CFR 51.308(d)(1)). If a coal-fired plant were 

located close to a mandatory Class I area, additional air pollution control requirements 

would be imposed. North Carolina contains five Class I areas, one of which, Swanquarter 

Wilderness Area, is potentially downwind of a coal-fired alternative at HNP (EPA 2007a).

Swanquarter, however, is approximately 298 km (185 mi) from the HNP site, and thus is 

unlikely to be affected by a coal-fired alternative. A coal-fired alternative located near 

Swanquarter or any of North Carolina’s other Class 1 Areas may need to install additional 

emissions controls. EPA more generally protects visibility with regulations in 40 CFR 51, 

Subpart P. 
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August 2008 8-35 NUREG-1437, Supplement 33 

In addition to Clean Air Act regulations, North Carolina restricts utilities’ aggregate emissions 

of NOx and SOx from coal-fired power plants (NC General Statutes 143-215.107D; 

commonly known as the Clean Smokestacks Act). To date, Progress Energy has met the 

aims of the legislation by installing emissions controls technologies at older coal-fired plants 

(NCDENR and NCUC 2006). Constructing a new IGCC coal-fired power plant may result in 

emissions levels that require CP&L to install emissions controls on older coal-fired power 

plants in order to remain in compliance with the law.

The IGCC coal-fired alternative would produce the following quantities of air pollutants: 

Sulfur oxides emissions. DOE indicated that a coal-fired IGCC plant would emit 0.0077 

kg (0.017 lb) of SOx per million BTU of thermal input (DOE 1999). Based on this emissions 

rate, NRC staff projects total SO2 emissions are of 466 MT (514 tons) per year without any 

additional emissions control technology. 

A new coal-fired power plant would be subject to the requirements in Title IV of the Clean Air 

Act. Title IV was enacted to reduce emissions of SO2 and NOx, the two principal precursors 

of acid rain, by restricting emissions of these pollutants from power plants. Title IV caps 

aggregate annual power plant SO2 emissions and imposes controls on SO2 emissions 

through a system of marketable allowances. EPA issues one allowance for each ton of SO2

that a unit is allowed to emit. New units do not receive allowances, but are required to have 

allowances to cover their SO2 emissions. Owners of new units must therefore purchase 

allowances from owners of other power plants or reduce SO2 emissions at other power 

plants they own. Allowances can be banked for use in future years. Thus, a new coal-fired 

power plant would not add to net regional SO2 emissions, although it might do so locally.

North Carolina’s Clean Smokestacks Law restricts utility-level aggregate emissions of SOx

from coal-fired power plants. A new coal-fired power plant in North Carolina may result in 

emissions levels that require CP&L to reduce emissions from other, older power plants.

Nitrogen oxides emissions. In the absence of additional control technologies, the IGCC 

alternative would produce 658 MT (725 tons) of NOx per year, based on DOE emissions 

projections (DOE 1999).

Section 407 of the Clean Air Act establishes technology-based emission limitations for NOx

emissions. The market-based allowance system used for SO2 emissions is not used for 

NOx emissions. A new coal-fired power plant would be subject to the new source 

performance standards for such plants as indicated in 40 CFR 60.44a(d)(1). This 

regulation, issued on September 16, 1998 (63 FR 49453) (EPA 1998b), limits the discharge 

of any gases that contain nitrogen oxides (expressed as NO2) in excess of 200 ng/J of gross 

energy output (1.6 lb/MWh), based on a 30-day rolling average. 
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NUREG-1437, Supplement 33 8-36 August 2008 

Even without additional control technologies, NRC staff estimates that the total annual NOx

emissions for a new coal-fired power plant would be approximately 658 MT/yr (725 tons/yr) 

or approximately 12.4 percent of the new source performance standard emission rate. This 

level of NOx emissions would be greater, however, than the operating license renewal 

alternative.

EPA further restricts the total amount of NOx that can be emitted on a State level basis. In 

the 2007 ozone season (May 1–September 30) North Carolina may emit 150,000 MT 

(165,306 tons) of NOx. A new IGCC coal-fired power plant would need to offset emissions 

through credit purchases or from a set-aside pool.

North Carolina’s Clean Smokestacks Law restricts utility-level aggregate emissions of NOx

from coal-fired power plants. A new IGCC power plant in North Carolina may result in 

emissions levels that require CP&L to reduce emissions from other coal-fired power plants. 

Particulate emissions. NRC staff estimates that the total annual stack emissions would 

include approximately 52.1 MT (57 tons) of filterable total suspended particulates, all of 

which have an aerodynamic diameter less than or equal to 10 ȝm (PM10) (40 CFR 50.6). In 

addition, coal-handling equipment would introduce fugitive particulate emissions.

Particulate emissions would be greater under the coal alternative than the operating license 

renewal alternative. 

During the construction of an IGCC coal-fired plant, fugitive dust would be generated. In 

addition, exhaust emissions would come from vehicles and motorized equipment used 

during the construction process. These impacts are intermittent and short-lived. To 

minimize dust generation, construction crews would use applicable dust-control measures.. 

Carbon monoxide emissions. In the absence of DOE or EPA emissions data, NRC staff 

adopts CP&L’s emissions rate, which indicates that the total carbon monoxide emissions 

would be approximately 822 MT (906 tons) per year. This level of emissions would be 

greater than the operating license renewal alternative. 

Hazardous air pollutants including mercury. In December 2000, EPA issued regulatory 

findings on emissions of hazardous air pollutants from electric utility steam-generating units 

(EPA 2000b). EPA determined that coal- and oil-fired electric utility steam-generating units 

are significant emitters of hazardous air pollutants. Coal-fired power plants were found by 

EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen 

fluoride, lead, manganese, and mercury (EPA 2000b). EPA concluded that mercury is the 

hazardous air pollutant of greatest concern. EPA found that (1) there is a link between coal 

consumption and mercury emissions; (2) electric utility steam-generating units are the 

largest domestic source of mercury emissions; and (3) certain segments of the 

U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are 

believed to be at potential risk of adverse health effects due to mercury exposures resulting 
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from consumption of contaminated fish (EPA 2000b). Accordingly, EPA added coal- and oilfired electric utility steam-generating units to the list of source categories under Section 

112(c) of the Clean Air Act for which emission standards for hazardous air pollutants will be 

issued (EPA 2000b). Accordingly, on March 15, 2005, EPA issued the Clean Air Mercury 

Rule to permanently cap and reduce mercury emissions from coal-fired power plants (EPA 

2007c). A new IGCC coal-fired power plant would need to comply with performance 

standards contained in 40 CFR 60.45(a), requiring that the plant emit no more than 0.0025 

nanograms per Joule output (20 x 10-6 lbs. per MWh). In addition, to the extent the plant 

would emit any mercury, the plant owners would need to purchase mercury allowances or 

reduce emissions to ensure that North Carolina emits no more than 1.133 tons of mercury 

containing gases in 2010, and 0.447 tons of mercury containing gases in 2018 (EPA 2006). 

IGCC units minimize mercury emissions by allowing control technologies to extract mercury 

from syngas prior to combustion in the combined-cycle power plant.

Uranium and thorium. Coal contains uranium and thorium, among other naturally occurring 

elements. Alex Gabbard, a researcher at Oak Ridge National laboratory, indicates that 

uranium concentrations are generally in the range of 1 to 10 parts per million (ppm) and 

thorium concentrations are generally about 2.5 times this level (Gabbard 1993). The USGS 

indicates that Western and Illinois Basin coals contain uranium and thorium at roughly equal 

concentrations, mostly between 1 and 4 ppm, but also indicates that some coals may 

contain concentrations as high as 20 ppm of both elements (USGS 1997). Gabbard 

indicates that a 1000 MWe coal-fired plant would release roughly 4.7 MT (5.2 tons) of 

uranium and 11.6 MT (12.8 tons) of thorium annually (Gabbard 1993). Both USGS and 

Gabbard indicate that almost all of the uranium, thorium, and most decay products remain in 

solid coal wastes, especially in the fine glass spheres that constitute much of coal’s fly ash.

Modern emissions controls allow for recovery of greater than 99% of these solid wastes 

(EPA 1998a), thus retaining most of coal’s radioactive elements in solid form rather than 

releasing it to the atmosphere. In an IGCC plant, uranium and thorium would remain in slag 

material. Even after concentration in coal slag, the level of radioactive elements remains 

relatively low (typically 10 to 100 ppm) and consistent with levels found in naturally occurring 

granites, shales, and phosphate rocks (USGS 1997). The level of uranium and thorium 

contained in coal wastes and disposed of in the environment exceed the levels of uranium 

and thorium released to the environment by the existing nuclear power plant.

Carbon dioxide. A coal-fired IGCC plant would also have unregulated carbon dioxide 

emissions during operations of the plant itself as well as during coal mining and processing, 

as well as coal transportation. Burning bituminous coal in the U.S. emits roughly 205.3 lbs 

CO2 per million Btu (Hong and Slatick 1994). The IGCC plant would emit approximately 

6,200,000 tons of CO2 per year (5,630,000 MT)

Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but 

did imply that air impacts would be substantial. The GEIS also mentioned global warming 
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NUREG-1437, Supplement 33 8-38 August 2008 

from unregulated carbon dioxide emissions and acid rain from SOx and NOx emissions as 

potential impacts (NRC 1996). Adverse human health effects such as cancer and 

emphysema have been associated with the products of coal combustion. NRC staff 

analysis for an IGCC coal-fired alternative at the HNP site and an alternative site indicates 

that impacts from the coal-fired alternative would have clearly noticeable effects, but would 

not destabilize air quality. Thus, the appropriate characterization of air impacts from coalfired generation would be MODERATE.

Siting an IGCC coal-fired generation plant at a site other than HNP would not significantly 

change air-quality impacts, although it would result in installing more or less stringent 

pollution-control equipment to meet applicable local requirements. Therefore, the impacts 

would be MODERATE. 

• Waste

IGCC combustion of coal generates waste in slag, a vitreous, sand-like material. The IGCC 

alternative would generate 258,000 MT (285,000 tons) of slag annually for 40 years. Of this 

waste, approximately 232,000 MT (256,000 tons) (90%) would be recycled, according to 

CP&L, leaving a total of approximately 25,800 MT (28,500) tons that would be landfilled 

onsite. Slag disposal would require 4.37 ha (10.8 ac) of land area over the 40-year plant 

life. Waste impacts to groundwater and surface water would extend beyond the operating 

life of the plant if leachate and runoff from the waste storage area occurs, though proper 

management can prevent this pollution. In addition, the small size of the waste disposal 

area makes other waste impacts less likely. IGCC slag would need to be handled in 

accordance with state and national regulations. After closure of the waste site and 

revegetation, the land would be available for other uses 

Debris would be generated during construction activities. This would likely be disposed 

onsite, when possible. Overall, this amount of waste would be small compared to 

operational waste generated, and many construction wastes can be recycled. As such, 

construction-stage waste impacts would be SMALL. 

For all of the preceding reasons, the appropriate characterization of impacts from waste 

generated by a coal-fired IGCC plant located at the HNP site would be SMALL. 

Siting the facility at a site other than HNP would not alter waste generation, although other 

sites might have more constraints on disposal locations. If a coal facility was sited on a 

previously developed location, then there may also be fewer constraints on waste disposal.

Therefore, the impacts would likely be SMALL to MODERATE. 
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August 2008 8-39 NUREG-1437, Supplement 33 

• Human Health 

IGCC coal-fired power generation introduces worker risks from coal mining, from coal 

transportation, and from disposal of slag as well as transportation of reusable byproducts.

In addition there are public risks from inhalation of stack emissions. Emission impacts can 

be widespread and health risks difficult to quantify. The coal-fired IGCC alternative also 

introduces the risk of coal-pile fires and attendant inhalation risks. 

In the GEIS, the NRC staff stated that there would be human health impacts (cancer and 

emphysema) from inhalation of toxins and particulates, but it did not identify the significance 

of these impacts (NRC 1996).

Regulatory agencies, including EPA and State agencies, set air emission standards and 

requirements based on human health impacts. These agencies also impose site-specific 

emission limits as needed to protect human health. As discussed previously, EPA has 

recently concluded that certain segments of the U.S. population (e.g., the developing fetus 

and subsistence fish-eating populations) are believed to be at potential risk of adverse 

health effects due to mercury exposures from sources such as coal-fired power plants, 

though these emissions are likely to be smaller from IGCC plants than from conventional 

coal-fired plants. In the absence of more quantitative data, human health impacts from 

radiological doses and inhaling toxins and particulates generated by burning coal would be 

characterized as SMALL. 

• Socioeconomics

Construction of the IGCC coal-fired alternative would take approximately 4 years (DOE/EIA 

2006b). The NRC staff assumed that construction would take place while HNP continues 

operation and would be completed by the time it permanently ceases operations in 2026.

The work force would be expected to include between 1170 and 2440 workers (based on 

estimates for natural gas and coal-fired power plants in NRC 1996). These workers would 

be in addition to the approximately 720 workers currently employed at HNP. During 

construction, the surrounding communities would experience an increased demand for 

rental housing and public services, though this would be moderated by the proximity of the 

site to urban areas. After construction, the communities would be impacted by the loss of 

the construction jobs, though rapid economic growth in the area would mitigate these 

impacts.

If the coal-fired IGCC plant were constructed at the HNP site and HNP were 

decommissioned, there would be a loss of approximately 473 to 576 permanent high-paying 

jobs (720 for HNP to between 147 and 244 for the IGCC coal-fired plant), with a 

commensurate reduction in demand on socioeconomic resources and tax contribution to the 

regional economy. The coal-fired IGCC plant would provide a new tax base to offset the 

loss of tax base associated with decommissioning of the HNP unit in Wake County. Other 
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NUREG-1437, Supplement 33 8-40 August 2008 

counties would likely experience little impact, as HNP pays 90% of its local taxes to Wake 

County. Since the region’s growing economy effectively mitigates most socioeconomic 

impacts of both construction and operation, the appropriate characterization of nontransportation socioeconomic impacts for an IGCC coal-fired plant constructed at the HNP 

site would be SMALL to MODERATE 

During the 4-year construction period of the IGCC coal-fired units, between 1172 and 

2440 construction workers would be commuting to the site in addition to the 720 workers at 

HNP. The addition of these workers would increase traffic loads on existing highways, 

particularly on surface roads in and around the plant. These transportation impacts would 

be SMALL to MODERATE. 

Construction of a replacement coal-fired IGCC power plant at an alternate site would 

relocate some socioeconomic impacts. The communities around HNP would experience the 

relatively minor impact of HNP operational job loss, and the communities around the new 

site would have to absorb the impacts of a large, temporary work force (up to 2440 workers 

at the peak of construction) and a permanent work force ranging from 147 to 244 workers.

In the GEIS, the NRC staff stated that socioeconomic impacts at a rural site would be larger 

than at an urban site, because more of the peak construction work force would need to 

move to the area to work. The HNP site is in the Raleigh-Durham-Chapel Hill metropolitan 

area and is therefore not considered a rural site. Alternate sites would need to be analyzed 

on a case-by-case basis. Alternate industrial sites, however, tend to be close to 

metropolitan areas, and may still have remaining transportation infrastructure nearby.

Socioeconomic impacts at a rural site would be LARGE, while impacts at previously 

developed industrial site would be SMALL to MODERATE. 

• Transportation

For transportation related to commuting of plant operating personnel, the impacts would be 

considered SMALL. The maximum number of plant operating personnel would be 

approximately 244. The current HNP work force is approximately 720. Therefore, traffic 

impacts associated with plant personnel commuting to an IGCC coal-fired plant would be 

expected to be SMALL, and smaller than the impacts of renewing the license for HNP. 

For rail transportation related to coal delivery to the HNP site, the impacts would be 

considered SMALL. NRC staff estimates that approximately 245 unit trains per year would 

deliver coal for IGCC alternative, while trains or trucks would remove sulfur and slag for 

marketing. Approximately 5 unit trains would deliver coal each week, or more than one trip 

per day on the spur leading to the plant, because for each full train delivery there would be 

an empty train.
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Transportation-related impacts associated with commuting construction workers at an 

alternate site are site dependent, but could be SMALL to LARGE. Transportation impacts 

related to commuting of plant operating personnel would also be site dependent, but would 

be best characterized as SMALL.

At an alternate site, coal would also likely be delivered by rail. Transportation impacts would 

depend upon the site location. Socioeconomic impacts associated with rail transportation 

would likely be SMALL, though dependent on coal train routing. Socioeconomic impacts 

associated with rail transportation on a previously developed industrial site would likely be 

SMALL.

• Aesthetics

If sited at the current HNP location, the IGCC coal-fired power plant units would be as much 

as 60 m (200 ft) tall. Given the site’s heavy forestation, these units would likely not be 

visible offsite. The two exhaust stacks would be similar in height to those of a natural gasfired combined cycle plant, and shorter than the 122 to 183 m (400 to 600 ft) estimated for a 

supercritical coal-fired plant. Given the current presence of a cooling tower and its plume, 

as well as other plant structures on-site, the addition of plant stacks would not drastically 

increase visual impacts. The units and associated stacks would also be visible at night 

because of outside lighting. Visual impacts of a new coal-fired plant could be mitigated by 

landscaping and color selection for buildings that is consistent with the environment. Visual 

impact at night could be mitigated by reduced lighting and appropriate shielding. The visual 

impacts at the HNP site would be SMALL. 

Coal-fired IGCC generation would introduce mechanical sources of noise at the site. Given 

the low population offsite of the plant’s property and the screening effect of trees onsite, 

offsite noise would be unlikely to be obtrusive. Sources contributing to total noise produced 

by plant operation are classified as continuous or intermittent. Continuous sources include 

the mechanical equipment associated with normal plant operations. Intermittent sources 

include the equipment related to coal handling, solid-waste disposal, transportation related 

to coal and lime delivery, use of outside loudspeakers, and the commuting of plant 

employees. The incremental noise impacts of a coal-fired plant compared to existing HNP 

operations would be considered SMALL.

Noise impacts associated with rail delivery of coal to a plant at the HNP site would be most 

significant for residents living in the vicinity of the facility and along the rail route. Although 

noise from passing trains significantly raises noise levels near the rail corridor, the short 

duration of the noise reduces the impact. The number of people affected by transportation 

would depend on the rail route. As such, the impacts of train noise on residents in the 

vicinity of the facility and the rail line would be SMALL to MODERATE. 
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NUREG-1437, Supplement 33 8-42 August 2008 

At an alternate site, there would be an aesthetic impact from the buildings, exhaust stacks, 

cooling towers, and the plume associated with the cooling towers. There would be a 

significant aesthetic impact associated with construction of a new transmission line to 

connect to other lines to enable delivery of electricity. Noise and light from the plant may be 

detectable offsite, depending on plant characteristics. Aesthetic impacts at the plant site 

would be mitigated if the plant were located in an industrial area adjacent to other power 

plants. Noise impacts from a rail spur, if required, would be similar to the impacts at the 

existing site. Overall the aesthetic impacts associated with locating at an alternate site 

could range from SMALL to LARGE, depending on site characteristics. Some of these 

issues would be rectified if the IGCC coal plant were sited at a previously developed site, as 

many contain some level of rail or transmission infrastructure, and would be in areas 

accustomed to industrial uses. Impacts at a previously developed site would be SMALL to 

MODERATE.

• Historic and Archaeological Resources 

At the HNP site, a cultural resource inventory would likely be needed for any onsite property 

that has not been previously surveyed. Other lands, if any, that are acquired to support the 

plant would also likely need an inventory of field cultural resources, identification and 

recording of existing historic and archaeological resources, and possible mitigation of 

adverse effects from subsequent ground-disturbing actions related to physical expansion of 

the plant site. 

Before construction at an alternate, undeveloped site, studies would be needed to identify, 

evaluate, and develop mitigation measures for the potential impacts of new plant 

construction on cultural resources. The studies would be needed for all areas of potential 

disturbance at the proposed plant site and along associated corridors where new 

construction would occur (e.g., roads, transmission corridors, rail lines, or other rights-ofway). Historic and archaeological resource impacts can generally be effectively managed 

and as such would be considered SMALL for the existing site and would be SMALL to 

MODERATE at a new site. For a previously developed site, impacts on cultural and historic 

resources would be SMALL, as the area has previously been developed, and previous 

development either removed or surveyed items of archaeological interest. 

• Environmental Justice 

No environmental impacts were identified that would result in disproportionately high and 

adverse environmental impacts to minority and low-income populations if a replacement 

IGCC coal-fired plant were built at the HNP site. Some impacts on housing availability and 

lease prices during construction would occur, and this could disproportionately affect the 

minority and low-income populations.
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August 2008 8-43 NUREG-1437, Supplement 33 

Impacts on minority and low-income populations due to the shutdown of HNP would depend 

on the number of jobs and the amount of tax revenue lost to the communities surrounding 

the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue 

generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it 

is likely that these losses would be replaced by the development of new businesses and 

new sources of tax revenue in the region. Since CP&L’s tax payments represent a small 

percentage of Wake County’s total annual property tax revenue, it is unlikely that social 

services would be seriously affected. Therefore, minority and low-income populations in the 

vicinity of HNP would not likely experience any disproportionately high and adverse 

socioeconomic impacts from the shutdown of HNP. 

The environmental effect of plan shutdown would reduce the amount of operational impacts 

on the environment. Therefore, minority and low-income populations in the vicinity of HNP 

would not likely experience any disproportionately high and adverse environmental impacts 

from the shutdown of HNP. 

Impacts at other sites would depend upon the site chosen and the nearby population 

distribution, but would be SMALL to MODERATE for alternate sites. For previously 

developed industrial sites, impacts would be larger, depending on the locations of lowincome populations. 

8.2.3 Natural Gas-Fired Combined-Cycle Generation 

In this section, NRC staff examines the environmental impacts of the natural gas-fired 

alternative at both the HNP site and at an alternate site. The NRC staff assumed that a natural 

gas-fired plant would use a closed-cycle cooling system. At the HNP site, the NRC staff 

assumed that the new plant would make use of the existing cooling system, including cooling 

tower, intake, and outlet.

If a new natural gas-fired plant were built on the existing property to replace HNP, approximately 

3.2 km (2 mi) of new, 20-cm (8-in.) gas pipeline would be necessary to connect the plant to 

existing gas pipelines north of the plant (Progress Energy 2006b). This would require a 15-m 

(50-ft) wide corridor, resulting in disturbance to as much as 4.9 ha (12 ac) of land. CP&L 

indicates that this new pipeline may necessitate additional improvements to the statewide 

pipeline system. 

NRC staff assumed that a replacement natural gas-fired plant would use combined-cycle 

technology. Compared to simple-cycle combustion turbines, combined cycle plants are 

significantly more efficient, and thus provide electricity at lower levelized costs. Typically, they 

support intermediate loads, but they are capable of supporting a baseload duty cycle and thus 

provide an alternative to the renewed operating license.
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In a combined-cycle unit, hot combustion gases in a combustion turbine rotate the turbine to 

generate electricity. Waste combustion heat from the combustion turbine is routed through a 

heat-recovery steam generator, which then powers a steam turbine electrical generator. 

In the HNP ER, CP&L asserts that three units based on existing Siemens combined cycle 

systems would be constructed to replace HNP (Progress Energy 2006b). After reviewing 

commercially available combined cycle power plant, the NRC staff assumed that these units 

would be Siemens SCC6-5000F units with heat rates of 5990 Btu/kWh. NRC staff believes 

these units appropriately reflect modern combined-cycle power plant technology, and also note 

that examining these units for the purpose of environmental impact analysis does not mean that 

they are the units most likely to be chosen by CP&L or other relevant authorities should they 

choose to implement a gas-fired alternative. 

The NRC staff reviewed this information and compared it to environmental impact information in 

the GEIS. Although the operating license renewal period is only 20 years, the impact of 

operating the natural gas-fired alternative for 40 years is considered (though this may modestly 

exceed the expected lifetime of a combined-cycle plant, it is consistent with impacts for the 

other fossil-fueled alternatives). 

NRC staff discusses the overall impacts of the natural gas-fired generating system in the 

following sections and summarizes them in Table 8-4. The extent of impacts at an alternate site 

would depend on the location of the site selected. 

• Land Use 

For siting at HNP, existing facilities and infrastructure would be used to the extent 

practicable, limiting the amount of new construction that would be required. Specifically, the 

NRC staff assumed that the natural gas-fired replacement plant alternative would use the 

cooling tower system, switchyard, offices, and transmission line rights-of-way. Much of the 

land that would be used has been previously disturbed. NRC staff in the GEIS asserted that 

a 1000 MWe gas-fired plant would require 45 ha (110 ac). As such, a plant of the size 

proposed for replacing HNP’s capacity would require 40 ha (100 ac). NRC staff notes that 

by using structures from the existing HNP unit, land use impacts would be minimized. CP&L 

estimated a land-use impact of 24 ha (60 ac) for a gas-fired alternative constructed on the 

HNP site (Progress Energy 2006b). There would be an additional impact of up to 

approximately 4.9 ha (12 ac) for construction of a gas pipeline.

For construction at an alternate site, the NRC staff assumed that 40 ha (100 ac) would be 

needed for the plant and associated infrastructure. In addition, anywhere from tens to 

thousands of acres would be disturbed by installing gas pipelines and electric transmission 

lines. NRC staff expects that this area would be reduced if a gas-fired alternative was 

constructed on a previously-developed industrial site. Many former industrial sites have 

easier access to pipelines and transmission capacity than undeveloped sites. 
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Regardless of where a gas-fired alternative is built, additional land would be required for 

natural gas wells and collection stations. According to the GEIS, a 1000 MWe gas-fired 

plant requires approximately 1500 ha (3600 ac) for wells, collection stations, and pipelines 

(NRC 1996). Much of the land area necessary for the gas-fired alternative would be in 

existing gas-extraction areas. Partially offsetting these offsite land requirements would be 

the elimination of the need for uranium mining to supply fuel for HNP. In the GEIS (NRC 

1996), the NRC staff estimated that approximately 400 ha (1000 ac) would be affected for 

mining the uranium and processing it during the operating life of a 1000 MWe nuclear power 

plant. Overall, land-use impacts would be SMALL to MODERATE for an alternative at the 

HNP site. Impacts would generally be similar at an undeveloped site, as the primary driver 

for these impacts would be the large area of land necessary for natural gas infrastructure.

At an alternate site, additional pipelines or transmission lines may also be necessary. As 

such, impacts would be SMALL to LARGE. 

Table 8-4. Summary of Environmental Impacts of Natural Gas-Fired Generation at HNP Site 

and an Alternate site Using Closed-Cycle Cooling 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Land Use SMALL to 

MODERATE 

Less than 40 ha (100 ac) for 

powerblock, offices, roads, and 

parking areas, some of which 

would be reused from the 

existing HNP site. Additional 

impact of up to approximately 

4.9 ha (12 ac) for construction 

of an underground gas pipeline. 

SMALL to 

LARGE

Approximately 40 ha 

(100 ac) for power block, 

offices, roads, and parking 

areas. Power line and gas 

pipeline impacts may vary 

widely, from tens of acres 

to thousands of acres.

Previously developed sites 

would experience lower 

impacts than undeveloped 

sites.

Ecology SMALL As the alternative would use 

undeveloped areas at the 

current HNP site, terrestrial 

impacts would be minimal. 

Relatively little land would be 

disturbed for a pipeline, though 

actual land characteristics 

would drive pipeline impacts. 

Aquatic ecology actually 

benefits from gas-fired 

alternative, as the combinedcycle plant requires significantly 

less makeup water and 

SMALL to 

MODERATE 

Impact depends on location 

and ecology of the site, 

surface water body used 

for intake and discharge, 

and transmission and 

pipeline routes; potential 

habitat loss and 

fragmentation; reduced 

productivity and biological 

diversity. These issues 

would be much smaller on 

a previously developed 

site.
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HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

discharges less blowdown than 

HNP.

Water Use and 

Quality—Surface 

Water 

SMALL Uses a closed-cycle cooling 

system with natural gas-fired 

combined-cycle units. This 

would result in a significant 

reduction in water use due to 

lower levels of heat rejection. 

SMALL to 

MODERATE 

Impact depends on volume 

of water withdrawn and 

discharged, as well as 

characteristics of the 

surface water body. 

Water Use and 

Quality—

Groundwater 

SMALL HNP uses no groundwater. A 

combined-cycle alternative 

would continue to use Harris 

Reservoir for all water needs 

rather than use groundwater. 

SMALL to 

MODERATE 

Impact depends on volume 

of water withdrawal, though 

it is not likely to be used for 

cooling makeup. 

Air Quality SMALL to 

MODERATE 

Emissions:

• Sulfur oxides 

62.3 MT (69 tons/yr) 

• Nitrogen oxides 

200 MT (220 tons/yr) 

• Carbon monoxide 

41.5 MT (46 tons/yr) 

• PM10 particulates 

34.8 MT (38 tons/yr) 

• Small amounts of 

hazardous air pollutants 

SMALL to 

MODERATE 

Same emissions as at HNP 

site.

Waste SMALL Solid waste primarily due to 

emission controls and plant 

operations.

SMALL Same waste produced as 

at the HNP site. 

Human Health SMALL Impacts are uncertain, but 

considered SMALL as the plant 

would comply with healthinformed standards in the Clean 

Air Act and other relevant 

emissions regulations. 

SMALL Similar impacts to those at 

the HNP site. 
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August 2008 8-47 NUREG-1437, Supplement 33 

HNP Site Alternate Site Impact 

Category Impact Comments Impact Comments 

Socioeconomics SMALL During construction, impacts 

would be SMALL. Up to 1090 

additional workers during the 

peak of the 3-year construction 

period, followed by reduction 

from current HNP work force of 

720 to 136; tax base preserved. 

Impacts during operation would 

be SMALL.

SMALL to 

MODERATE 

During construction, 

impacts would be SMALL 

to MODERATE, depending 

on site. Up to 1090 additional workers during the 

peak of the 3-year 

construction period. Wake 

county would lose jobs and 

tax base, while other 

counties would lose jobs. 

Impacts during operation 

would be SMALL. 

Socioeconomics

(Transportation) 

SMALL to 

MODERATE 

Transportation impacts would 

likely be SMALL to 

MODERATE, primarily with 

construction activities. 

SMALL to 

MODERATE 

Transportation impacts 

could be SMALL to 

MODERATE, primarily with 

construction activities. 

Aesthetics SMALL Aesthetic impact due to plant 

units and stacks would be minor 

compared to exiting HNP 

structures.

SMALL to 

MODERATE 

Greatest impact would be 

from the new transmission 

line and pipeline right-ofway that would be needed. 

Overall impact would be 

SMALL for previously 

developed sites and 

SMALL to MODERATE for 

undeveloped sites. 

Historic and 

Archeological

Resources

SMALL Any potential impacts could be 

effectively managed given the 

plant’s small footprint.

SMALL to 

MODERATE 

Any potential impacts 

would be effectively 

managed, though pipeline 

and transmission line may 

have SMALL to

MODERATE impacts. 

Environmental

Justice

SMALL Impacts on minority and lowincome communities would be 

similar to those experienced by 

the population as a whole, 

which are SMALL. Some 

additional impacts on rental 

housing may occur during 

construction, though these 

would not be noticeable. 

SMALL to 

MODERATE 

Impacts would vary 

depending on population 

distribution and location of 

the site. 
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NUREG-1437, Supplement 33 8-48 August 2008 

• Ecology

At the HNP site, there would be ecological impacts to land use for siting of the gas-fired 

plant, though these are likely to be small since the disturbed area of the plant would likely 

accommodate a new combined-cycle gas plant. There would also be some ecological 

impacts associated with bringing a new underground gas pipeline to the HNP site, though 

this is dependent upon habitat disturbed during construction, which is, in turn, dependent on 

pipeline routing. Since CP&L estimates this pipeline would require only 4.9 ha (12 ac) to 

reach the plant, this impact is unlikely to noticeably affect important ecological features. 

Aquatic ecology actually benefits from gas-fired alternative, as the combined-cycle plant 

requires significantly less makeup water and discharges less blowdown than HNP.

Ecological impacts at an alternate site would depend on the nature of the land converted for 

the plant and the possible need for a new gas pipeline and/or transmission line.

Construction of the transmission line and construction and/or upgrading of the gas pipeline 

to serve a plant at an alternate site would have temporary ecological impacts, though these 

would be substantial. Ecological impacts to the plant site and utility rights of way would 

include impacts on threatened or endangered species, wildlife habitat loss and reduced 

productivity, habitat fragmentation, and a local reduction in biological diversity. At an 

alternate site, the cooling makeup water intake and discharge would have aquatic resource 

impacts. These impacts would be smaller at a previously developed site, owing to generally 

closer access to pipelines and transmission lines than at greenfield sites. Overall, the 

ecological impacts would be considered SMALL at the HNP site and SMALL to MODERATE 

at a different location. 

• Water Use and Quality 

Surface Water. Combined-cycle gas-fired plants are highly efficient and require less 

cooling water than other generation alternatives, including the existing plant. Plant 

discharge would consist mostly of cooling tower blowdown, with the discharge having a 

slightly higher temperature and increased concentration of dissolved solids relative to the 

receiving body of water, as well as intermittent low concentrations of biocides (e.g., 

chlorine). In addition to the cooling tower blowdown, process waste streams and sanitary 

waste water would also be discharged, though these discharges would be much smaller 

than at the existing plant since a gas-fired alternative would employ many fewer people. All 

discharges would be regulated through a NPDES permit, which is administered by 

NCDENR. Finally, some erosion and sedimentation would probably occur during 

construction (NRC 1996), though the GEIS indicates this would be SMALL. Overall, the 

impacts to water use and quality at the HNP site from a gas-fired alternative would be 

considered SMALL, and would be less than the proposed action.

A natural gas-fired plant at an alternate site is assumed to use a closed-cycle cooling 

system with cooling towers. The NRC staff assumed that surface water would be used for 

cooling makeup water and discharge. Intake and discharge would involve relatively small 
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August 2008 8-49 NUREG-1437, Supplement 33 

quantities of water compared to once-through cooling. The impact on the surface water 

would depend on the volume of water needed for makeup water, the discharge volume, and 

the characteristics of the receiving body of water. Intake from and discharge to any surface 

body of water would be regulated by the NCDENR. The impacts would be SMALL to 

MODERATE.

Groundwater. HNP currently uses no groundwater. It is likely that a gas-fired alternative 

would also not use groundwater. Impacts at the HNP site would thus be SMALL.

Groundwater impacts at an alternate site may vary widely depending on whether the plant 

uses groundwater for any of its water needs, though it would be unlikely that a plant on an 

alternate site would use groundwater for cooling system makeup water. Impacts at an 

alternate site would be SMALL to MODERATE.

• Air Quality 

Natural gas is a relatively clean-burning fuel. The gas-fired alternative would release similar 

types of emissions, but in lesser quantities, than the coal-fired alternative. 

Currently, Wake County and the neighboring counties of Johnston, Chatham, Durham, 

Franklin and Nash are non-attainment areas for ozone under the Clean Air Act (EPA 

2007b). These counties are either in attainment or unclassified for other criteria pollutants 

(EPA 2007b). A new gas-fired plant located in an ozone non-attainment area would need to 

purchase emissions credits from existing emitters of ozone-causing chemicals, including 

NOx.

A gas-fired alternative at the HNP site or another non-attainment area site would require 

Non-Attainment Area permit and a Title V operating permit under the Clean Air Act. A new 

combined-cycle natural gas power plant would also be subject to the new source 

performance standards for such units at 40 CFR 60, Subparts Da and GG. These 

regulations establish emission limits for particulates, opacity, SO2, and NOx.

EPA has various regulatory requirements for visibility protection in 40 CFR 51, Subpart P, 

including a specific requirement for review of any new major stationary source in an area 

designated attainment or unclassified under the Clean Air Act.

Section 169A of the Clean Air Act (42 USC 7491) establishes a national goal of preventing 

future and remedying existing impairment of visibility in mandatory Class I Federal areas 

when impairment results from man-made air pollution. EPA issued a new regional haze rule 

in 1999 (64 FR 35714) (EPA 1999). The rule specifies that for each mandatory Class I 

Federal area located within a State, the State must establish goals that provide for 

reasonable progress towards achieving natural visibility conditions. The reasonable 

progress goals must provide for an improvement in visibility for the most impaired days over 

the period of the implementation plan and ensure no degradation in visibility for the least-
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NUREG-1437, Supplement 33 8-50 August 2008 

impaired days over the same period (40 CFR 51.308(d)(1)). If a natural gas-fired plant were 

located close to a mandatory Class I area, additional air pollution control requirements 

would be imposed. North Carolina contains five Class I areas, one of which, Swanquarter 

Wilderness Area, is potentially downwind of a coal-fired alternative at HNP (EPA 2007a).

Swanquarter is approximately 298 km (185 mi) east of the HNP site. A gas-fired alternative 

at HNP may need additional pollution controls to keep from impairing visibility in this area.

Additionally, a gas-fired plant at an alternate site nearer to a Class I area may require even 

more stringent controls. 

NRC staff projects the following emissions for a gas-fired alternative based on EPA 

emissions factors (EPA 2000a): 

o Sulfur oxides – 62.3 tons/yr 

o Nitrogen oxides – 200 tons/yr 

o Carbon monoxide – 41.5 tons/yr 

o PM10 particulates – 34.8 tons/yr 

The total amount of nitrogen oxides which can be emitted by North Carolina in the 2007 

ozone season (May 1–September 30) is set out at 40 CFR 51.121(e). For North Carolina, 

the amount is 150,000 MT (165,306 tons). A new gas-fired power plant would need to buy 

credits if it was likely to cause North Carolina to exceed this amount.

A natural gas-fired plant would also have unregulated carbon dioxide emissions. An IGCC 

plant would emit approximately 2,330,000 tons of CO2 per year (2,110,000 MT) (DOE/EIA 

2007a).

In December 2000, EPA issued regulatory findings on emissions of hazardous air pollutants 

from electric utility steam-generating units (EPA 2000b). Natural gas-fired power plants 

were found by EPA to emit arsenic, formaldehyde, and nickel (EPA 2000b). Unlike coal and 

oil-fired plants, EPA did not determine that emissions of hazardous air pollutants from 

natural gas-fired power plants should be regulated under Section 112 of the Clean Air Act. 

Construction activities would also result in some air effects, including those from temporary 

fugitive dust, though construction crews would employ dust-control practices to limit this 

impact. Exhaust emissions would also come from vehicles and motorized equipment used 

during the construction process, though these emissions are likely to be intermittent in 

nature and will occur over a limited period of time. As such, construction stage impacts 

would be SMALL. 

The overall air-quality impact for a new natural gas-fired plant sited at HNP or at an alternate 

site would be SMALL to MODERATE, depending on control technology employed during the 

operating stage. 
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August 2008 8-51 NUREG-1437, Supplement 33 

• Waste

Burning natural gas fuel generates small amounts of waste, though a plant using selective 

catalytic reduction (SCR) to control NOx will generate spent SCR catalyst from NOx

emissions control and small amounts of solid-waste products (i.e., ash). In the GEIS, the 

NRC staff concluded that waste generation from gas-fired technology would be minimal 

(NRC 1996). Waste-generation impacts would be so minor that they would not noticeably 

alter any important resource attribute. 

Constructing a gas-fired alternative would generate small amounts of waste, though many 

construction wastes can be recycled, and land-clearing debris would be disposed of onsite.

Overall, the waste impacts would be SMALL for a natural gas-fired plant sited at HNP or at 

an alternate site. 

• Human Health 

In Table 8-2 of the GEIS, the NRC staff identifies cancer and emphysema as potential 

health risks from gas-fired plants (NRC 1996). The risk may be attributable to NOx

emissions that contribute to ozone formation, which in turn contribute to health risks. NOx

emissions from any gas-fired plant would be regulated as mentioned in the Air Quality 

section. Human health effects would not be detectable or would be sufficiently minor that 

they would neither destabilize nor noticeably alter any important attribute of the resource.

Overall, the impacts on human health of the natural gas-fired alternative sited at HNP or at 

an alternate site would be considered SMALL. 

• Socioeconomics

Construction of a natural gas-fired plant would take approximately 3 years (DOE/EIA 

2006b). Peak employment would be approximately 1090 workers (NRC 1996). NRC staff 

assumed that construction would take place while HNP continues operation and would be 

completed by the time it permanently ceases operations. During construction, the 

communities surrounding the HNP site would experience an increased demand for rental 

housing and public services that would have SMALL impacts given the area’s population.

These impacts could be reduced by construction workers commuting to the site from other 

parts of the Raleigh-Durham-Chapel Hill area. The natural gas-fired plant would provide a 

new tax base to offset the loss of tax base associated with decommissioning of the HNP unit 

in Wake County. Other counties would likely experience little impact, as HNP pays 90% of 

its local taxes to Wake County. Since the region’s growing economy effectively mitigates 

most socioeconomic impacts of both construction and operation, the appropriate 

characterization of non-transportation socioeconomic impacts for a natural gas-fired plant 
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NUREG-1437, Supplement 33 8-52 August 2008 

constructed at the HNP site would be SMALL to MODERATE. For siting at an alternate site, 

impacts in Wake County would be SMALL from loss of tax base.

Compared to the coal-fired and nuclear alternatives, the smaller size of the construction 

work force, the shorter construction time frame, and the smaller size of the operations work 

force would mitigate socioeconomic impacts. In addition, the communities around HNP 

would experience relatively minor impacts of HNP operational job loss and loss of tax 

revenue. For these reasons, socioeconomic impacts associated with construction and 

operation of a natural gas-fired power plant would be SMALL for siting at HNP, and SMALL 

to MODERATE at an alternate site.

• Transportation

Transportation impacts associated with construction and operating personnel commuting to 

the plant site would depend on the population density and transportation infrastructure in the 

vicinity of the site. The impacts would be SMALL to MODERATE for siting at either HNP or 

an alternate site. 

• Aesthetics

At the HNP site, the two turbine buildings (100 ft tall) and four exhaust stacks (approximately 

150 ft tall) would not be visible during daylight hours from offsite due to extensive site 

forestation. The gas pipeline compressors may be visible if they are located near roads, 

though they are relatively small. Noise and light from the plant may be detectable offsite, 

but would also be screened by the site’s trees. The visual impact, then from a new 

combined-cycle plant on the current HNP site, would be SMALL. 

At an alternate site, the buildings, cooling towers, cooling tower plumes, and the associated 

transmission line and gas pipeline compressors may be visible offsite. Visual impacts from 

new transmission lines or a pipeline right-of-way would also be significant, though these 

may be minimized by building near transmission or on previously-developed land.

Additionally, aesthetic impacts would be mitigated if the plant were located in an industrial 

area adjacent to other power plants. Unlike the coal-fired alternatives, the gas-fired plant 

lacks a coal pile, rail spur, and frequent coal deliveries. Overall, the aesthetic impacts 

associated with an alternate site would be SMALL to MODERATE. 

• Historic and Archaeological Resources 

At HNP, a cultural resource inventory would likely be needed for any onsite property that 

has not been previously surveyed. Other lands, if any, that are acquired to support the plant 

would also need an inventory of cultural resources, identification and recording of existing 
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August 2008 8-53 NUREG-1437, Supplement 33 

historic and archaeological resources, and possible mitigation of adverse effects from 

subsequent ground-disturbing actions related to physical expansion of the plant site. Since 

the gas-fired alternative uses little land, and most of it would have been previously 

disturbed, the impact of the gas-fired alternative at the HNP site would be SMALL.

Before construction at an alternate site, studies would likely be needed to identify, evaluate, 

and address mitigation of the potential impacts of new plant construction on cultural 

resources. The studies would be needed for all areas of potential disturbance at the 

proposed plant site and along associated corridors where new construction would occur 

(e.g., roads, transmission and pipeline corridors, or other rights-of-way). Building on a 

previously developed site would minimize the likelihood of affecting historical or 

archaeological resources, as previous development either removed these resources or 

previous studies identified their locations. At an alternate, undeveloped site, the impact 

would be SMALL to MODERATE. 

• Environmental Justice 

No environmental impacts were identified that would result in disproportionately high and 

adverse environmental impacts on minority and low-income populations if a replacement 

natural gas-fired plant were built at the HNP site. Some impacts on housing availability and 

lease prices during construction might occur, and this could affect minority and low-income 

populations.

Impacts on minority and low-income populations due to the shutdown of HNP would depend 

on the number of jobs and the amount of tax revenue lost to the communities surrounding 

the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue 

generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it 

is likely that these losses would be replaced by the development of new businesses and 

new sources of tax revenue in the region. Since CP&L’s tax payments represent a small 

percentage of Wake County’s total annual property tax revenue, it is unlikely that social 

services would be seriously affected. Therefore, minority and low-income populations in the 

vicinity of HNP would not likely experience any disproportionately high and adverse 

socioeconomic impacts from the shutdown of HNP. 

The environmental effect of plan shutdown would reduce the amount of operational impacts 

on the environment. Therefore, minority and low-income populations in the vicinity of HNP 

would not likely experience any disproportionately high and adverse environmental impacts 

from the shutdown of HNP. 
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NUREG-1437, Supplement 33 8-54 August 2008 

Impacts at an alternate site would depend upon the site chosen, nearby population 

characteristics, and economic opportunity. These impacts would range from SMALL to 

MODERATE, depending on the distribution of low-income and minority population. 

8.2.4 New Nuclear Generation 

Since 1997 the NRC has certified four new standard designs for nuclear power plants under 

10 CFR 52, Subpart B. These designs are the 1300 MWe U.S. Advanced Boiling Water 

Reactor (10 CFR 52, Appendix A), the 1300 MWe System 80+ Design (10 CFR 52, 

Appendix B), the 600 MWe AP600 Design (10 CFR 52, Appendix C), and the 1100 MWe 

AP1000 Design (10 CFR 52, Appendix C). One additional design is awaiting certification, and 

five others are undergoing pre-application reviews. All of the designs currently certified or 

awaiting certification are light-water reactors. Several designs in pre-application review are not 

light water reactors; these include the helium-cooled Pebble Bed Modular Reactor and the 

heavy water moderated and cooled Advanced Candu Reactor, ACR-700. Although NRC has 

received no applications for a construction permit or a combined license based on certified 

designs, NRC has received several early site permit (ESP) applications, and has approved the 

first ESPs at the Clinton site near Clinton, Illinois (ESP issued on March 15, 2007), and the 

Grand Gulf site, in Claiborne County, Mississippi (ESP issued on March 27, 2007). These ESP 

applications and design certification applications indicate continuing interest in the possibility of 

licensing new nuclear power plants. In addition, recent escalation in natural gas and electricity 

prices have made new nuclear power plant construction more attractive from a cost standpoint, 

though academic and investment communities remain uncertain as to what new nuclear plants 

will actually cost. Given current uncertainty and expressed industry interest in new nuclear 

construction, NRC staff will evaluate the new nuclear generation option in depth for both the 

HNP site and an alternate site. CP&L did not consider a new nuclear reactor at an alternate site 

in the HNP ER. 

The NRC staff assumed that the new nuclear plant would have a 40-year lifetime. This allows 

for comparisons between a new nuclear plant and other alternatives, and also coincides with 

the initial licensing period for a new nuclear plant. 

NRC has summarized environmental data associated with the uranium fuel cycle in Table S-3 of 

10 CFR 51.51. The impacts shown in Table S-3 are representative of the impacts that would be 

associated with a replacement nuclear power plant built to one of the certified designs, sited at 

HNP or an alternate site. The impacts shown in Table S-3 are for a 1000-MWe reactor and 
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August 2008 8-55 NUREG-1437, Supplement 33 

would need to be adjusted to reflect impacts of 900 MW of new nuclear power.(7) The 

environmental impacts associated with transporting fuel and waste to and from a light-water 

cooled nuclear power reactor are summarized in Table S-4 of 10 CFR 51.52. NRC staff 

summarize findings on National Environmental Policy Act (NEPA) issues for license renewal of 

nuclear power plants in Table B-1 of 10 CFR 51 Subpart A, Appendix B.

NRC staff notes that this analysis addresses the potential impacts of a reactor constructed at 

the current HNP site for the purposes of replacing the existing HNP unit. This analysis is not 

meant to be indicative of the impacts one would expect from the two units that CP&L has 

indicated they may possibly construct at the HNP site should they file a combined construction 

and operating license (COL) application and receive approval from NRC. NRC staff would 

initiate a separate, detailed environmental impact statement to address the design-specific and 

site-specific impacts from those units if and when CP&L submits a COL.

NRC staff discusses the overall impacts of a new nuclear generating alternative in the following 

sections, and summarizes impacts in Table 8-5. The extent of impacts at an alternate site 

would depend on the location of the particular site selected. 

• Land Use 

The existing facilities and infrastructure at the HNP site would be used to the extent 

practicable, limiting the amount of new construction that would be required. Specifically, the 

NRC staff assumed that a replacement nuclear power plant would use the existing cooling 

tower system, switchyard, offices, and transmission line rights-of-way. Much of the land that 

would be used has been previously disturbed. 

A replacement nuclear power plant at the HNP site would alter approximately 200 to 400 ha 

(500 to 1000 ac) of land to plant use (NRC 1996). Some of this land may already have been 

converted into parking lots or other auxiliary structures and can be modified to support the 

new plant. There would be little net change in land needed for uranium mining because 

land needed for the new nuclear plant would offset land needed to supply uranium for fuel 

HNP, though the GEIS indicates that new reactor designs may require more uranium than 

existing plants. 

The impact of a replacement nuclear generating plant on land use at the existing HNP site 

would be best characterized as MODERATE. This impact would be greater than the 

 

(7) NRC staff notes that while Table S-3 does not estimate impacts from unregulated CO2 emissions 

during the nuclear fuel cycle, Table S-3 does indicate that energy consumed during the cycle is roughly 

equal to that generated by a 45 MWe conventional coal-fired plant, and thus provides a means of 

approximating unregulated CO2 emissions.
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NUREG-1437, Supplement 33 8-56 August 2008 

operating license renewal alternative, as well as greater than the gas-fired alternative and 

likely similar to that of the coal-fired alternatives. 

Land-use impacts at an alternate site would be similar to siting at HNP except for the land 

needed for transmission lines necessary to connect to existing lines, and a rail spur to allow 

deliver of major components and fuel. Depending on the site, anywhere from tens to 

thousands of acres may be necessary. The need to construct transmission and rail capacity 

would likely be reduced at a previously developed industrial site, though it would not 

necessarily be eliminated. Depending particularly on transmission line routing and rail spur 

siting, siting a new nuclear plant at an alternate site would result in MODERATE to LARGE 

land-use impacts. 

• Ecology

Locating a new nuclear unit at the HNP site would affect ecological resources, but existing 

site maintenance practices and the site’s industrial nature would minimize additional impacts 

from the new plant on terrestrial ecology.

Siting at HNP would have a SMALL to MODERATE ecological impact that would be greater 

than renewal of the HNP operating license. Impacts become greater if more undeveloped 

land is converted to industrial uses.

At an alternate site, there would be construction impacts and new incremental operational 

impacts. Even assuming siting at a previously disturbed area, the impacts may include 

wildlife habitat loss, reduced productivity, habitat fragmentation, and a local reduction in 

biological diversity, depending on the degree to which the site was previously disturbed and 

how much remediation has taken place. A new nuclear plant at an alternate site would likely 

also make use of cooling towers, and would incur similar aquatic impacts to the existing 

HNP unit. At a new site, these impacts would likely be MODERATE, due primarily to 

terrestrial impacts, but also depending on the characteristics of the water body used for 

cooling.

Table 8-5. Summary of Environmental Impacts of New Nuclear Power Generation at the HNP 

Site and an Alternate Site Using Closed-Cycle Cooling 

HNP Site Alternate Site Impact

Category Impact Comments Impact Comments 

Land Use MODERATE Requires approximately 200 to 

400 ha (500 to 1000 ac) for the 

plant. Fuel cycle effects are 

similar to the current plant. 

MODERATE 

to LARGE 

Same as HNP site plus 

land for transmission line 

and rail spur. 

Ecology SMALL to Uses undeveloped areas at 

current HNP site and may use 

MODERATE Impact depends on location 

and ecology of the site, 
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August 2008 8-57 NUREG-1437, Supplement 33 

HNP Site Alternate Site Impact

Category Impact Comments Impact Comments 

MODERATE offsite Progress Energy-owned 

areas. Aquatic ecology impacts 

would be similar to existing 

plant.

surface water body used 

for intake and discharge, 

and transmission line route; 

potential habitat loss and 

fragmentation; reduced 

productivity and biological 

diversity. 

Water Use and 

Quality—Surface 

water 

SMALL Uses existing cooling tower 

system. 

SMALL to 

MODERATE 

Impact would depend on 

the volume of water 

withdrawn and discharged 

and the characteristics of 

the surface water body. 

Water Use and 

Quality—

Groundwater 

SMALL Would likely use Harris 

Reservoir for all onsite water. 

A new nuclear plant would also 

use the existing cooling system.

SMALL to 

MODERATE 

Impact would depend on 

the volume of water 

withdrawn, as well as 

characteristics of the 

aquifer. Groundwater 

would not be used for 

cooling system makeup 

water. 

Air Quality SMALL Fugitive emissions and 

emissions from vehicles and 

equipment during construction; 

small amount of emissions from 

diesel generators and possibly 

other sources during operation. 

SMALL Same impacts as HNP site.

Waste SMALL Waste impacts for an operating 

nuclear power plant are set out 

in 10 CFR 51, Appendix B, 

Table B-1. Debris would be 

generated and removed during 

construction.

SMALL Same impacts as HNP site.

Human Health SMALL Human health impacts for an 

operating nuclear power plant 

are set out in 10 CFR 51, 

Appendix B, Table B-1. 

SMALL Same impacts as HNP site.
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NUREG-1437, Supplement 33 8-58 August 2008 

HNP Site Alternate Site Impact

Category Impact Comments Impact Comments 

Socioeconomics SMALL to 

MODERATE 

During construction, impacts 

would be MODERATE, with up 

to 2250 workers during peak 

period of the 6-year construction period. The operating work 

force assumed to be similar to 

HNP; tax base preserved in 

Wake County, but may change 

in surrounding counties if 

workers don’t transfer from one 

plant to another. Impacts 

during operation would be 

SMALL.

SMALL to 

LARGE

Construction impacts 

depend on location.

Impacts at a rural location 

would be LARGE. Wake 

County would experience a 

loss of tax revenue while 

surrounding counties would 

lose employment, though 

rapid growth in the region 

would offset these impacts. 

 Impacts during operation 

would be SMALL to 

MODERATE. 

Socioeconomics

(Transportation) 

MODERATE Transportation impacts would 

be MODERATE, due primarily 

to construction activities.

Transportation impacts of 

commuting plant personnel 

would be SMALL even if their 

commuting patterns differ from 

current plant employees. 

SMALL to 

LARGE

Transportation impacts 

would be MODERATE to 

LARGE, primarily with 

construction activities.

Transportation impacts of 

commuting plant personnel 

would be SMALL to 

MODERATE. 

Aesthetics SMALL No new exhaust stacks or 

cooling towers would be 

needed. New containment and 

turbine buildings would be 

visible in the immediate vicinity 

of the plant. Visual impact at 

night would be mitigated by 

reduced use of lighting and 

appropriate shielding. Noise 

impacts would be relatively 

small and would be mitigated. 

MODERATE 

to LARGE 

Greatest impact is likely 

from new cooling towers. 

Also, transmission lines or 

a rail spur would also have 

significant impacts.

Impacts from containment 

and other buildings would 

also be noticeable. 

Historic and 

Archeological

Resources

SMALL Any potential impacts can likely 

be effectively managed. Any 

offsite land acquired would 

need to be surveyed. 

SMALL to 

MODERATE 

Any potential impacts can 

likely be effectively 

managed. Land would 

need to be surveyed. 

Impact likely smaller at 

previously developed site. 

Environmental

Justice

SMALL Impacts on minority and lowincome communities would be 

similar to those experienced by 

the population as a whole. 

Some impacts on rental 

SMALL to 

MODERATE 

Impacts would vary 

depending on population 

distribution and location of 

the site. Impacts to 

minority and low-income 
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August 2008 8-59 NUREG-1437, Supplement 33 

HNP Site Alternate Site Impact

Category Impact Comments Impact Comments 

housing may occur during 

construction, though most 

personnel are expected to 

travel from nearby urban areas. 

populations from the 

closure of HNP would likely 

to be offset by the area’s 

economic growth. 

• Water Use and Quality 

Surface Water. The replacement nuclear plant alternative at the HNP site is assumed to 

use the existing closed-cycle cooling tower system, which would minimize incremental 

water-use and quality impacts. Harris Reservoir would likely remain the source of other 

water required by the plant. Surface-water impacts are expected to remain SMALL. 

Cooling towers would likely be used at alternate sites. For alternate sites, the impact on the 

surface water would depend on the volume of water needed for makeup water, the 

discharge volume, and the characteristics of the water body. Intake from and discharge to 

any surface body of water would be regulated by the DENR. The impacts would be SMALL 

to MODERATE. 

Groundwater. The NRC staff assumed that a new nuclear power plant located at HNP 

would continue to obtain all water from Harris Reservoir.

Use of groundwater for a nuclear power plant located at an alternate site is a possibility.

Any groundwater withdrawal would require a permit from the local permitting authority. A 

new plant is unlikely to use groundwater for cooling makeup water, however, given the 

volume of water necessary. 

Overall, groundwater impacts at the current site would be SMALL, and at an alternate site 

would be SMALL to MODERATE. 

• Air Quality 

Construction of a new nuclear plant sited at HNP or an alternate site would result in fugitive 

dust emissions during the construction process. These impacts are intermittent and shortlived. To minimize dust generation, construction crews would use applicable dust-control 

measures. Exhaust emissions would also come from vehicles and motorized equipment 

used during the construction process, but these would also be of limited duration. An 

operating nuclear plant would have minor air emissions associated with diesel generators 

and other small-scale intermittent sources. Overall, air emissions and associated impacts 

would be SMALL. 
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• Waste

The waste impacts associated with operation of a nuclear power plant are set out in 

Table B-1 of 10 CFR 51, Subpart A, Appendix B. Construction-related debris would be 

generated during construction activities and removed to an appropriate disposal site.

Overall, waste impacts would be SMALL. 

Siting the replacement nuclear power plant at a site other than HNP would not alter waste 

generation. Therefore, the impacts would be SMALL. 

• Human Health 

Human health impacts for an operating nuclear power plant are set out in 10 CFR Part 51 

Subpart A, Appendix B, Table B-1. Overall, human health impacts would be SMALL. 

Siting the replacement nuclear power plant at a site other than HNP would not alter human 

health impacts. Therefore, the impacts would also be SMALL. 

• Socioeconomics

The construction period and the peak work force associated with construction of a new 

nuclear power plant are currently unquantified (NRC 1996). In the absence of quantitative 

data, NRC staff assumed a construction period of 6 years (based on DOE/EIA 2006b) and a 

peak work force of 2250 (based on peak workforce for a 1000 MWe coal-fired plant and 

extrapolated to the current plant size). The NRC staff assumed that construction would take 

place while the existing nuclear unit continues operation and would be completed by the 

time HNP permanently ceases operations. During construction, the communities 

surrounding the HNP site would experience an increase demand for rental housing and 

public services that would have SMALL to MODERATE impacts. These impacts could be 

reduced by construction workers commuting to the site from other parts of the RaleighDurham-Chapel Hill area or from other counties. After construction, the communities would 

be impacted by the loss of the construction jobs. An alternative site would experience 

SMALL to LARGE impacts, depending on characteristics of the surrounding community and 

local economy. 

The replacement nuclear unit is assumed to have an operating work force comparable to the 

720 workers currently working at HNPS. The replacement nuclear unit would provide new 

tax revenue to offset the loss of revenue associated with the decommissioning of HNP.

New employment, as well as the area’s economic growth, would also likely offset loss of 

HNP jobs. For all of these reasons, the appropriate characterization of non-transportation 

socioeconomic impacts for a replacement nuclear unit constructed at HNP would be 
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SMALL; the socioeconomic impacts would be noticeable, but would be unlikely to 

destabilize the area. 

Construction of a replacement nuclear power plant at an alternate site would relocate some 

socioeconomic impacts, but would not eliminate them. The communities around the HNP 

site would still experience the impact of operational job loss, though this would be offset by 

economic growth. The communities around the new site would have to absorb the impacts 

of a large, temporary work force (up to 2250 workers at the peak of construction) and a 

permanent work force of approximately 720 workers. In the GEIS (NRC 1996), the NRC 

staff indicated that socioeconomic impacts at a rural site would be larger than at an urban 

site because more of the peak construction work force would need to move to the area to 

work. The HNP site is within commuting distance of the Raleigh-Durham-Chapel Hill urban 

area and is therefore not considered a rural site. Alternate sites would need to be analyzed 

on a case-by-case basis. Non-transportation socioeconomic impacts at a rural site would be 

LARGE.

• Transportation

During the 6-year construction period, up to 2250 construction workers would commute to 

the HNP site in addition to the 720 workers at HNP. The addition of the construction 

workers, equipment, and material would increase traffic loads on existing roads around the 

plant. Such impacts would be MODERATE. Transportation impacts related to commuting 

of plant operating personnel would be similar to current impacts associated with operation of 

HNP and would be SMALL. 

Transportation-related impacts associated with commuting construction workers at an 

alternate site are site dependent, but would be MODERATE to LARGE. These may be 

mitigated somewhat if built on a previously developed site nearer to population.

Transportation impacts related to commuting of plant operating personnel at an alternate 

site would also be site dependent, but would be characterized as SMALL to MODERATE. 

• Aesthetics

The containment building for a replacement nuclear power plant sited at HNP, existing 

cooling tower, and as other associated buildings would be visible in daylight hours over 

many miles, though extensive forestation on site may help screen these structures. The 

replacement nuclear unit may be visible at night because of outside lighting. Visual impacts 

could be mitigated by landscaping and selecting a color for buildings that is consistent with 

the environment. Visual impact at night could be mitigated by reduced use of lighting and 

appropriate use of shielding. No exhaust stacks would be needed. Visual impacts would 

likely be SMALL. 
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Noise impacts from a new nuclear plant would be similar to those from the existing HNP 

unit. Given the land area available around the plant, and potential noise mitigation 

measures, such as reduced use of outside loudspeakers, the impact of noise would be 

SMALL.

At an alternate site, there would be an aesthetic impact from the buildings, cooling towers, 

and the plume associated with the cooling tower. There would also be a significant 

aesthetic impact associated with construction of a new transmission line to connect to other 

lines to enable delivery of electricity to Progress Energy’s transmission system. Noise and 

light from the plant would be detectable offsite. The impact of noise and light would be 

mitigated if the plant is located in an industrial area adjacent to other power plants or 

industrial land uses. Overall the aesthetic impacts associated with locating at an alternative 

site would be categorized as MODERATE to LARGE, depending on the site’s 

characteristics. The greatest contributor to this categorization would be the aesthetic impact 

of the cooling towers and transmission lines.

• Historic and Archaeological Resources 

At the HNP site, a cultural resource inventory would likely be needed for any onsite property 

that has not been previously surveyed. Other lands, if any, that are acquired to support the 

plant would also need an inventory of field cultural resources, identification and recording of 

existing historic and archaeological resources, and possible mitigation of adverse effects 

from subsequent ground-disturbing actions related to physical expansion of the plant site. 

Before beginning construction at an alternate site, studies would be needed to identify, 

evaluate, and address mitigation of the potential impacts of new plant construction on 

cultural resources over the 200 to 400 ha (500 to 1000 ac) necessary for plant construction. 

The studies would be needed for all areas of potential disturbance at the proposed plant site 

and along associated corridors where new construction would occur (e.g., roads, 

transmission corridors, rail lines, or other rights-of-way). Historic and archaeological 

resource impacts can generally be effectively managed and as such would be. Effects at an 

undeveloped site would be SMALL to MODERATE. 

• Environmental Justice 

No environmental impacts were identified that would result in disproportionately high and 

adverse environmental impacts on minority and low-income populations if a replacement 

nuclear plant were built at the HNP site. Some impacts on housing availability and lease 

prices during construction might occur, and this could disproportionately affect the minority 

and low-income populations. 
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Impacts on minority and low-income populations due to the shutdown of HNP would depend 

on the number of jobs and the amount of tax revenue lost to the communities surrounding 

the power plant. Closure of HNP would reduce the overall number of jobs and tax revenue 

generated in the region that was directly and indirectly attributed to plant operations.

However, given the rapid economic growth of Wake County and the Raleigh-Durham area, it 

is likely that these losses would be replaced by the development of new businesses and 

new sources of tax revenue in the region. Since CP&L’s tax payments represent a small 

percentage of Wake County’s total annual property tax revenue, it is unlikely that social 

services would be seriously affected. Therefore, minority and low-income populations in the 

vicinity of HNP would not likely experience any disproportionately high and adverse 

socioeconomic impacts from the shutdown of HNP. 

The environmental effect of plant shutdown would reduce the amount of operational impacts 

on the environment. Therefore, minority and low-income populations in the vicinity of HNP 

would not likely experience any disproportionately high and adverse environmental impacts 

from the shutdown of HNP. 

Impacts at other sites would depend upon the site chosen and the nearby population 

distribution, but would be SMALL to MODERATE. 

8.2.5 Utility-sponsored Conservation 

In the following section, NRC staff will evaluate the environmental impacts of a conservation(8)

alternative to license renewal. Though CP&L currently employs a variety of conservation, 

energy efficiency, and other demand-side management measures, the NRC staff finds it 

reasonable to consider a conservation-based alternative to HNP license renewal based on 

several recent developments. First, in May 2007, CP&L announced plans to institute utilitybased energy efficiency programs aimed at eliminating the need for 2000 MW of electrical 

generating capacity in the North and South Carolina service territories (Murawski 2007, Beattie 

2007). Second, earlier in the same month, North Carolina’s largest utility, Duke Energy 

Carolinas, indicated that an energy efficiency program would allow it to retire 800 MW of coal 

capacity, and would allow it to offset up to 1700 MW of capacity over four years (Fordney 2007). 

Duke also indicated that the cost of the program would be less than the cost of constructing new 

generation capacity. Third, the North Carolina Utilities Commission released a report in 

December 2006 indicating that North Carolina has a statewide potential to reduce projected 

energy consumption by 32.7% of total projected utility sales per year by 2017. The report 

deemed approximately 25,132 gigawatt-hours (GWh) of this savings (13.9% of statewide 

 

(8) NRC staff notes that conservation typically refers to all programs that reduce energy consumption, 

while energy efficiency refers to programs that reduce consumption without reducing services. For this 

section, NRC staff will use the terms interchangeably. 
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electricity sales) to be cost-effectively achievable(9) (GDS Associates 2006). Though much of 

this savings potential likely exists during peak demand times, the magnitude of potential savings 

significantly exceeds HNP’s capacity, and several major efficiency measures identified in the 

GDS Associates report would affect baseload generation needs. These announcements all 

indicate robust opportunities for energy efficiency or conservation in North Carolina, as well as 

costs consistent with other alternatives. As such, NRC staff will evaluate utility-sponsored 

conservation as a feasible and commercially-available alternative to HNP license renewal.

Given the terminology used in the GDS Associates report, in announcements from CP&L, and in 

the GEIS, NRC staff will use “conservation” and “energy efficiency” interchangeably. 

The GEIS notes that a conservation alternative would have mostly SMALL or negligible 

environmental impacts. NRC staff, in the GEIS, established that resource extraction and 

material disposal would be the most visible lifecycle impacts, and that some conservation 

measures may also affect indoor air quality. The GEIS noted, however, that studies had not 

identified direct impacts from conservation measures to indoor air quality, and that pre-existing 

contamination is a major determinant in determining post-weatherization pollution levels. The 

GEIS also noted that production of conservation measures would not require large amounts of 

materials, and those it does require are common to many manufacturing processes. In addition, 

the GEIS established that disposal involves normal procedures with sufficiently effective 

disposal methods and small enough amounts of hazardous compounds that no adverse health 

effects would result (NRC 1996). 

According to the GDS Associates in their A Study of the Feasibility of Energy Efficiency as an 

Eligible Resource as Part of a Renewable Portfolio Standard for the State of North Carolina,

conducted for the North Carolina Utilities Commission, energy efficiency potential varies across 

residential, commercial, and industrial building sectors (GDS Associates 2006). In each sector, 

GDS provided technical potential (an indication of complete and total implementation of all 

possible efficiency measures); achievable potential (an implementation level achieved by an 

aggressively funded and sustained campaign); and achievable cost-effective potential (an 

implementation level achieved by targeting aggressive and sustained implementation 

campaigns toward efficiency measures with a lifetime cost of $.05 per kWh or less).

In the residential sector, GDS Associates determined that most achievable cost-effective 

potential energy savings result from a combination of building insulation and weatherization, 

Energy Star windows, Energy Star programmable thermostats, and compact fluorescent light 

installation. Other energy reductions come from low-flow shower heads, water heater blankets, 

and insulation and weatherization programs targeted toward low-income populations. In the 

commercial sector, improved HVAC controls and motors, higher efficiency lighting and lighting 

controls, improved refrigeration, better compressed air systems, and upgraded transformers 

 

(9) GDS Associates determined $.05 per lifetime kWh produced to be the cost-effectiveness threshold. 
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reduce energy consumption. In the industrial sector, improved lighting, motors, pumps, 

lubricants, controls, and system designs, as well as system optimization and upgraded 

transformers contribute to increased efficiency (GDS Associates 2006).

GDS Associates’ analysis assumed that program administrators would have ten years to 

implement the programs, reaching full effect by 2017. NRC staff notes that HNP’s operating 

license expires in 2026, and thus would allow for sufficient time to develop a suitable energy 

efficiency program.

NRC staff discusses the overall impacts of a new nuclear generating alternative in the following 

sections, and summarizes impacts in Table 8-6.

• Land Use 

Since CP&L would continue to use the existing transmission lines, and would continue to 

maintain Harris Reservoir, land use impacts of an energy efficiency alternative would be 

SMALL. It would be possible that equipment replacements would increase waste 

generation and increased resulting landfill disposal, but given a ten-year timeline for 

program development and implementation, it would be likely that some proportion of 

replacements would occur at the end of the existing equipment’s life (especially in the case 

of frequently replaced items, like lightbulbs). Many replaced items (like home appliances or 

industrial equipment) have substantial recycling value and would likely not be landfilled.

• Ecology

Ecological impacts would be SMALL, but positive, as withdrawals from and discharges to 

Harris Reservoir would cease. As no power generation alternative would take the plant’s 

place, water levels in Harris Reservoir may rise and contribute additional water to Buckhorn 

Creek, which currently is nearly dry for part of the year, and to the Cape Fear River 

downstream of Harris Reservoir. These impacts would be SMALL, however. Also, there 

would be SMALL, but positive effects if plant staff stops controlling vegetation at the plant 

site. If CP&L allowed boat access to the auxiliary reservoir after plant shutdown, aquatic 

ecology may be affected by potential introduction of invasive species and increased boat 

traffic as well as fishing access, though this effect would be SMALL, as well. 

Table 8-6. Summary of Environmental Impacts of a Conservation Alternative 

Impact Category Impact Comments 

Land Use SMALL Existing reservoir, transmission lines remain in use; possible minor, 

speculative effects on landfill area. 

Ecology SMALL Withdrawal from and discharge to reservoir ceases; some land may 
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Impact Category Impact Comments 

revert to other habitats; fishing may increase in former auxiliary 

reservoir and invasive species may be introduced, though this would 

have SMALL effects.

Water Use and 

Quality—Surface

Water

SMALL Water withdrawal and discharge would cease; additional water may 

flow into Buckhorn Creek downstream of Harris Reservoir, perhaps 

reducing stream intermittency.

Water Use and 

Quality—

Groundwater

SMALL Plant currently uses no groundwater; increased flow may affect 

groundwater around Buckhorn Creek, but aquifers are not currently 

used for water supply. 

Air Quality SMALL Commuter vehicle emissions and diesel emissions would decrease, 

positively affecting air quality. This effect would be SMALL. 

Waste SMALL Waste volumes generated by conservation programs would be 

mitigated by lengthening the program implementation timeline and 

through recycling. In addition, significance of other waste streams 

would likely swamp waste generated by an energy efficiency 

program.

Human Health SMALL Changes may occur to indoor air quality, but these are not wellestablished, and usually stem from pre-existing air quality issues. 

Socioeconomics SMALL Loss of jobs offset by economic growth in area; speculative potential 

for additional contractor employment across North Carolina. 

Socioeconomics

(Transportation)

SMALL Commuter traffic to the plant would decrease; additional traffic 

associated with efficiency programs would be widely distributed and 

would likely not be noticeable. 

Aesthetics SMALL The existing plant would be decommissioned and an alternative 

structure would replace it; no noticeable impacts from energy 

efficiency improvements. 

Historic and 

Archeological

Resources

SMALL No known effects. 

Environmental

Justice

SMALL Depending on program design and enrollment, minority and lowincome populations could benefit from energy efficiency programs. 

• Water Use and Quality 

Impacts to water use and quality from an energy efficiency program would be SMALL but 

positive, as withdrawals from Harris Reservoir would cease. Additional water may be 

available downstream from HNP in both Buckhorn Creek and the Cape Fear River as the 

plant would no longer evaporate water for cooling. As the plant uses no groundwater, a 

conservation alternative would not directly affect groundwater, though increased flow to 

Buckhorn Creek may affect groundwater in the immediate vicinity. As no one uses this 

groundwater, the effect would not be noticeable. 
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August 2008 8-67 NUREG-1437, Supplement 33 

• Air Quality 

Air quality impacts from a utility-sponsored energy efficiency program would be SMALL and 

positive. Emissions from commuter vehicles and diesel generators would decrease. The 

GEIS noted that indoor air quality may suffer from weatherization programs that fail to 

balance air quality concerns. The GEIS also noted that indoor air quality after 

weatherization is most strongly affected by pre-existing air quality issues.

• Waste

Waste impacts from energy efficiency programs would likely be SMALL, but somewhat 

dependent on the nature of the program. Improvements to heating and cooling systems 

would generate construction wastes, while appliance replacements may also generate 

wastes. Some of these replacements may occur in the course of normal retirement over the 

10-year implementation period and thus constitute no change to normal waste streams.

This would be particularly the case for frequently replaced items like light bulbs.

While projections of waste amounts from a conservation program are speculative, statewide 

equipment replacements and upgrades spread over 10 or more years, many of which would 

generate several pounds of waste per resident (e.g., lightbulbs, new shower heads, new 

thermostats), along with some which would generate hundreds to thousands of pounds of 

waste spread over many residents (replacing commercial ventilation systems or industrial 

motors), would keep impacts SMALL when compared to the 1.23 MT (1.36 tons) of waste 

disposed per resident in fiscal year 2005-2006 (NCDENR/DWM 2006). Furthermore, many 

replacements or upgrades generate waste materials with substantial recycling value (such 

as metal scrap from appliances, ductwork, and motors) and would thus not increase the 

burden on landfills. Some wastes, like fluorescent light bulbs, would need to be recycled as 

they contain hazardous compounds, though they generally operate much longer than their 

incandescent counterparts. The GEIS noted that amounts of hazardous compounds are 

small, and disposal methods are effective. Also, facilities to recycle these items currently 

exist in North Carolina. Waste impacts from the conservation alternative, then, would be 

SMALL.

• Human Health 

An energy efficiency program is unlikely to have a significant effect on human health.

Changes to most building appliances would not affect health, though upgrades to HVAC 

systems, insulation, and weatherization (including windows) may affect indoor air quality.

The GEIS noted that this issue has not been sufficiently studied, but that mitigation 

measures would be available to correct problems. The GEIS also noted that hazardous 

chemicals in the waste stream would not affect human health. As such, NRC staff 

determines that these effects would be SMALL. 
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• Socioeconomics

Socioeconomic effects of an energy efficiency program would be SMALL. As in the noaction alternative, loss of jobs at HNP would be offset by economic growth in the area.

Additionally, a conservation program would likely employ additional workers, as noted in the 

GEIS. Low-income populations could benefit from weatherization and insulation programs. 

This effect would be greater than the effect for the general population because low-income 

households experience home energy burdens more than four times larger than the average 

household (OMB 2007).

• Transportation

Transportation impacts would also be SMALL as fewer employees commute to the plant 

site. Any transportation effects from the energy efficiency alternative would be widely 

distributed across the state, and would not be noticeable. 

• Aesthetics

Impacts from energy efficiency programs would be positive, though small, as the plant is 

decommissioned and no alternative would replace it. The transmission lines and Harris 

Reservoir would remain after plant decommissioning. Traffic to the plant would decrease, 

however, as would the attendant noise and emissions. Noise impacts would occur in 

instances of upgrades to major building systems, though this impact would be highly 

intermittent and short-lived.

• Historic and Archaeological Resources 

Impacts to archaeological resources from energy efficiency programs would be SMALL, if 

any, as a conservation alternative would not affect land use or the historical or cultural 

resources contained onsite or elsewhere in the state.

• Environmental Justice 

GDS Associates identified weatherization programs targeting low-income residents as a 

cost-effective energy efficiency option (GDS 2006). Since low-income populations tend to 

spend a larger proportion of their incomes paying utility bills (according to the Office of 

Management and Budget, low income populations experience energy burdens more than 

four times as large as those of average households [OMB 2007]). Impacts to environmental 

justice from energy efficiency programs would be SMALL, depending on program design 

and enrollment. 
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8.2.6 Purchased Electrical Power 

CP&L currently relies on purchased power from a variety of generators. In the summer of 2007, 

CP&L indicated a net purchased power capacity of 1442 MW. Through 2016, CP&L anticipates 

at least 1147 MW of purchased capacity (Progress Energy 2006a). Thus, NRC staff believes 

purchased power represents a reasonable alternative to license renewal. In the HNP ER, CP&L 

indicated that purchased power capacity would likely be available within the Carolinas. Impacts 

would likely be similar to those of the above generating options; if CP&L’s purchased power 

causes currently existing capacity to operate at higher capacity factors, rather than triggering 

new construction, then construction stage impacts would be eliminated. It is possible, however, 

that purchased power would then come from older, less efficient plants, plants with once 

through cooling, or plants without modern emissions controls. In addition, if power purchased to 

replace HNP’s capacity came from plants built specifically to supply CP&L’s needs, the impacts 

would be the same as for the alternatives already discussed and constructed at alternate sites.

As such, impacts are difficult to quantify, though likely similar to other alternatives considered in 

Sections 8.2.1 through 8.2.5 in this SEIS, as well as in the GEIS. 

Given the location of HNP, it would be unlikely that CP&L would be able to purchase power from 

Canada or Mexico to replace HNP’s capacity, regardless of whether either country has sufficient 

existing export capacity. 

Since purchased power may come from a variety of generating resources, including coal, 

natural gas, nuclear, hydroelectric, and perhaps oil-fired installations, NRC staff believes 

impacts from the purchased power alternative would be generally greater than the impacts of 

license renewal, and similar to impacts of the other generation alternatives staff considered in 

this section. 

8.2.7 Other Alternatives 

Other generation technologies NRC staff considered but determined to be individually 

inadequate to serve as alternatives to HNP are discussed in the following paragraphs. 

8.2.7.1 Oil-Fired Generation 

EIA projects that oil-fired plants will account for very little of the new generation capacity in the 

United States during the 2007 to 2030 time period, and overall oil consumption for electricity 

generation will decrease because of higher fuel costs and lower efficiencies (DOE/EIA 2007).

Oil-fired generation is more expensive to operate than nuclear or coal-fired plants, though it is 

less expensive than either to construct. Future increases in oil prices are expected to make oilfired generation increasingly more expensive than coal-fired generation. The high cost of oil 
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has prompted a steady decline for use in electricity generation. For these reasons, oil-fired 

generation will not be evaluated at an alternative to HNP license renewal. 

8.2.7.2 Wind Power 

Wind power, by itself, is not suitable for large base-load capacity. As discussed in Section 8.3.1 

of the GEIS, wind has a high degree of intermittency, and average annual capacity factors for 

wind plants are relatively low (of the order of 30 to 40 percent). Wind power, in conjunction with 

energy storage mechanisms or another, readily dispatchable power source, like hydropower, 

might serve as a means of providing base-load power. However, current energy storage 

technologies are too expensive for wind power to serve as a large base-load generator, and 

opportunities to pair a sufficient volume of wind with hydropower do not exist in North Carolina 

(INEEL 1997). 

The State of North Carolina is mostly a wind power Class 1 region, though some areas, 

particularly along ridgelines in the western part of the state, contain wind resources in Classes 4 

through 7. Offshore areas in the east also offer wind power potential, and some areas provide 

wind classes ranging from 4 to 6 (DOE/NREL 2007a). While wind turbines tend to be 

economical in wind resources Class 4 and above, both ridgeline and coastal areas of the state 

are protected by state law, under the Mountain Ridge Protection Act (MRPA) and the Coastal 

Area Management Act, respectively (Bell 2006). La Capra Associates, in its 2006 report to the 

North Carolina Utilities Commission, indicated 500 MW of practical wind potential in North 

Carolina if one excludes prohibited western wind resources (La Capra 2006). Should 

interpretation of the MRPA change in the future, 1000 MW of additional practical wind potential 

is available in western North Carolina. 

Given limitations on potential wind power sites, as well as relatively low capacity factors, NRC 

staff does not consider wind power to be a suitable stand-alone alternative to HNP license 

renewal. NRC staff does, however, recognize that North Carolina likely has utility-scale wind 

resources, and will include wind power in a combination alternative addressed in Section 8.2.8. 

8.2.7.3 Solar Power 

Solar technologies use the sun's energy to produce electricity. Currently, the HNP site receives 

an average of 4.5 to 5 kWh of solar radiation per square meter per day, as does much of the 

state of North Carolina (DOE 2007). Since photovoltaic cells, the most likely alternative given 

North Carolina’s potential, tend to be roughly 15% efficient, a solar-powered alternative would 

require approximately at least 2390 ha (5910 ac) to provide an equivalent amount of electricity 

to that generated by gas- and coal-fired alternatives (DOE/NREL 2006). In the GEIS, the NRC 

staff noted that solar power is intermittent; therefore, additional collectors would be necessary to 

account for shading. In addition, a solar powered alternative would require energy storage or a 

backup power supply to provide electric power at night. Solar power is currently significantly 
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more costly than most other alternatives for a given amount of capacity, and as adding energy 

storage technologies only increases the cost of solar power, NRC staff will not evaluate solar 

power in-depth as a feasible alternative to license renewal of HNP. 

8.2.7.4 Hydropower 

The Idaho National Energy and Environmental Laboratory (INEEL) estimates that North 

Carolina has 508 MW of technically available, undeveloped hydroelectric resources (INEEL 

1997). This amount occurs entirely in installations of 100 MW or less. This potential is 44% 

less than HNP’s capacity, and thus is insufficient to serve as an alternative to license renewal.

As such, hydropower would not be considered as a feasible alternative to HNP license renewal. 

8.2.7.5 Geothermal Energy 

Geothermal plants are most likely to be sited in the western continental United States, Alaska, 

and Hawaii where hydrothermal reservoirs are prevalent (NRC 1998). There is no feasible 

eastern location for geothermal capacity to serve as an alternative to HNP. As such, NRC staff 

concludes that geothermal energy would not be a feasible alternative to renewal of the HNP 

operating license. 

8.2.7.6 Wood Waste 

DOE notes that North Carolina has good biomass resource potential (DOE 2007). Pulp, paper, 

and paperboard industries in North Carolina consume wood and wood waste for energy 

production.

In 1999, DOE researchers estimated that North Carolina has biomass fuel resources consisting 

of urban, mill, agricultural and forest residues, as well as speculative potential for energy crops. 

Excluding potential energy crops, DOE projected that North Carolina had 8,367,600 MT 

(9,223,700 tons) of plant-based biomass at $50 a ton delivered (Walsh et al. 1999; costs are in 

1995 dollars). The National Renewable Energy Laboratory estimates that each dry ton of wood 

residue produces approximately 1100 kWh of electricity (DOE/NREL 2004). Assuming this 

conversion efficiency, using all biomass available in North Carolina at $50 per ton would 

generate roughly 10 TWh of electricity. This is greater than the output of HNP (operating at a 

0.9 capacity factor) by roughly 43%. Walsh notes, however, that these estimates of biomass 

capacity contain substantial uncertainty, and that potential availability does not mean they would 

actually be available at the prices indicated or that resources would be free of contamination.

Some of these plant wastes already have reuse value, and would likely be more costly to 

deliver. Others, such as forest residues, may prove unsafe and unsustainable to harvest on a 

regular basis.
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While the GEIS notes that wood-waste plants are able to operate in a baseload duty cycle, the 

larger wood-waste power plants are currently only 40 to 50 MWe in size. Thus, up to 23 wood 

waste plants may be necessary to replace the capacity of HNP. Estimates in the GEIS suggest 

that the overall level of construction impact per MW of installed capacity would be approximately 

the same as that for a coal-fired plant, although facilities using wood waste for fuel would be 

built at smaller scales. Like coal-fired plants, wood-waste plants require large areas for fuel 

storage and processing and involve the same type of combustion equipment. 

NRC staff believes North Carolina has utility-scale wood waste resources, but given 

uncertainties in supply estimates, as well as the small size and high number of installed facilities 

necessary to replace HNP, NRC staff does not believe wood biomass is a suitable alternative to 

HNP license renewal. NRC staff will include wood waste facilities in a combination alternative 

addressed in Section 8.2.8. 

8.2.7.7 Municipal Solid Waste 

Currently there are approximately 89 waste-to-energy plants operating in the United States.

These plants generate approximately 2700 MWe, or an average of approximately 30 MWe per 

plant (Integrated Waste Services Association 2007). Assuming average size waste 

incinerators, approximately 30 plants would be necessary to replace HNP.

Estimates in the GEIS suggest that the overall level of construction impact from a waste-fired 

plant would be approximately the same as that for a coal-fired plant. Additionally, waste-fired 

plants have the same or greater operational impacts than coal-fired technologies (including 

impacts on the aquatic environment, air, and waste disposal). The initial capital costs for 

municipal solid waste plants are greater than for comparable steam turbine technology at coal 

facilities or at wood waste facilities, due to the need for specialized waste separation and 

handling equipment (NRC 1996).

The decision to burn municipal waste to generate energy is usually driven by the need for an 

alternative to landfills rather than by energy considerations. The use of landfills as a waste 

disposal option is likely to increase in the near term; with energy prices increasing, however, it is 

possible that municipal waste combustion facilities may become attractive again.

Regulatory structures that once supported municipal solid waste incineration no longer exist.

For example, the Tax Reform Act of 1986 made capital-intensive projects such as municipal 

waste combustion facilities more expensive relative to less capital-intensive waste disposal 

alternative such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v. 

Town of Clarkstown struck down local flow control ordinances that required waste to be 

delivered to specific municipal waste combustion facilities rather than landfills that may have 

had lower fees. In addition, increasingly stringent environmental regulations have increased the 
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capital cost necessary to construct and maintain municipal waste combustion facilities 

(DOE/EIA 2001). 

Given the small average installed size of municipal solid waste plants and unfavorable 

regulatory environment, NRC staff does not consider municipal solid waste combustion to be a 

feasible alternative to license renewal. 

8.2.7.8 Other Biomass Derived Fuels 

In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling 

electric generators, including burning crops, converting crops to a liquid fuel such as ethanol, 

and gasifying crops (including wood waste). In the GEIS, the NRC staff points out that none of 

these technologies has progressed to the point of being competitive on a large scale or of being 

reliable enough to replace a baseload plant such as HNP. For these reasons, such fuels do not 

offer a feasible alternative to renewal of the HNP operating license. 

8.2.7.9 Fuel Cells 

Fuel cells work without combustion and the accompanying environmental side effects. Power is 

produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 

over a cathode and separating the two by an electrolyte. The only by-products are heat, water, 

and carbon dioxide. Hydrogen fuel can come from a variety of hydrocarbon resources by 

subjecting them to steam under pressure. Natural gas is typically used as the source of 

hydrogen.

At the present time, fuel cells are not economically or technologically competitive with other 

alternatives for baseload electricity generation. EIA projects that by 2008, fuel cells will cost 

$3,787 per installed kW, and projects a 10 MWe unit size (DOE/EIA 2006b). While it may be 

possible to use a distributed array of fuel cells to provide an alternative to HNP, it would be 

extremely costly to do so.

8.2.7.10 Delayed Retirement 

CP&L has no plans to retire any generating units at this time (Progress Energy 2006a), and thus 

delayed retirement would not be a feasible alternative to license renewal. 
Alternatives

NUREG-1437, Supplement 33 8-74 August 2008 

8.2.8 Combination of Alternatives 

Even though individual alternatives to license renewal might not be sufficient on their own to 

replace the capacity of HNP due to the small size of the resource or lack of cost-effective 

opportunities, it is conceivable that a combination of alternatives might be cost-effective.

There are many possible combinations of alternatives. NRC staff believes a combination that 

includes, for example, 293 MWe of combined-cycle natural gas-fired capacity, six 50-MW 

biomass-fired plants, a 100 MWe wind park, and 250 MW of conservation programs would 

provide an alternative that roughly approximates the amount of power produced by HNP with 

some degree of overcapacity to compensate for wind capacity factors. The biomass-fired plants 

would operate on wood residues and would exist throughout the state, while the natural gas 

combined-cycle plant would operate at the HNP site or at an alternate site.

The GEIS indicates that wood-fired plants would serve baseload capacity, but that they tend to 

operate at low efficiencies and are economic only when feedstocks are very inexpensive. In 

addition, the GEIS notes that gathering fuel for wood-fired plants can have significant 

environmental impacts. NRC staff believes it is likely that 300 MWe of wood-fired generation 

would have SMALL to MODERATE impacts, depending on the fuel source. If the plants were 

widely distributed and feedstocks were primarily pre-existing waste streams, operational 

impacts would be SMALL. Construction impacts of six wood-fired plants would be SMALL to 

MODERATE depending on plant cooling configurations and plant locations. These impacts 

would be mitigated by locating plants on previously disturbed land near other industrial 

applications, including paper/pulp mills or other forest-products operations. 

Siting a single, 293 MWe gas-fired unit at the HNP site would likely have SMALL impacts, 

similar to, but smaller than those of the gas-fired alternative NRC staff considered in 

Section 8.2.3. Initiating 250 MW of conservation programs would have overall SMALL impacts, 

as determined for a larger amount of conservation capacity in Section 8.2.5.

NRC staff notes that it may be difficult to site 100 MW of wind capacity in North Carolina (Bell 

2006), but such a project may be possible in unrestricted areas, such as land on the western 

sides of North Carolina’s sounds. A 100 MW wind park using 1.5 MW turbines (a common 

commercially available size) would require roughly 6.9 to 14 ha (17 to 35 ac) of land for turbine 

footprints based on DOE’s Wind Farm Area Calculator (DOE/NREL 2007b), with some 

additional land use for infrastructure. The total area for the park would be larger, but land 

between turbines would continue to be used for agricultural purposes. Construction impacts for 

the 67 turbines required would be SMALL to MODERATE, depending on the amount of land 

disturbance required for installation.

The impacts of this alternative would be mostly SMALL, though potential exists for several 

MODERATE impacts. Therefore, the impact of this combination alternative would be greater 

than impacts of continued HNP operation or of the conservation alternative.
Alternatives

August 2008 8-75 NUREG-1437, Supplement 33 

8.3 Summary of Alternatives Considered

NRC staff considered alternative actions including the no-action alternative (discussed in 

Section 8.1), new generation or conservation alternatives (coal-fired supercritical and IGCC 

generation, natural gas, nuclear, and conservation alternatives discussed in Sections 8.2.1 

through 8.2.5, respectively), purchased electrical power (discussed in Section 8.2.6), alternative 

technologies NRC staff considered inadequate to serve as alternatives (discussed in 

Section 8.2.7), and a combination of alternatives (discussed in Section 8.2.8). 

As established in the GEIS, the need for power from HNP is assumed by NRC in the license 

renewal process. Should NRC not renew HNP’s license, this amount of generating capacity or 

load reduction would have to come from an alternative to license renewal. In addition, even if 

NRC renews the HNP operating license, CP&L could elect to meet this need with an alternative 

other than continued HNP operation. Decisions about which alternative to implement, 

regardless of whether NRC renews the HNP operating license, are left to utility and state-level 

decisionmakers (or non-NRC Federal level decisionmakers) where applicable. 

The environmental impacts from most alternatives to license renewal that NRC staff considered 

would be greater than the impacts of continued HNP operation under a renewed license, which 

would have all SMALL impacts except for collective offsite radiological impacts from the fuel 

cycle and from high-level waste (HLW) and spent fuel disposal. The conservation alternative to 

HNP renewal, however, also has all SMALL impacts, and some of these impacts are likely to be 

smaller than the impacts of HNP license renewal.

The NRC staff concludes, then, that conservation has the lowest levels of environmental impact 

among all alternatives considered. Thus, conservation is the environmentally preferred 

alternative to the proposed federal action of renewing the HNP operating license. 

8.4 References

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

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

Regulations for Domestic Licensing and Related Functions.” 

10 CFR 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Early Site Permits; 

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.” 

40 CFR 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

“National Primary and Secondary Ambient Air Quality Standards.” 
Alternatives

NUREG-1437, Supplement 33 8-76 August 2008 

40 CFR 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 

“Requirements for Preparation, Adoption, and Submittal of Implementation Plans.” 

40 CFR 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 

“Standards of Performance for New Stationary Sources.” 

Beattie, Jeff. 2007. “Progress Push on Conservation to Delay New Nuke.” The Energy Daily.

June 1, 2007. 

Bell, Steven G. 2006. “The Way the Winds are Blowing These Days: The Rapid Growth of 

Wind Energy and Legal Hurdles of North Carolina’s General Statutes.” North Carolina Journal 

of Law and Technology. 8 N.C. J.L. & Tech. 117 (2006). Available URL:

http://www.ncjolt.org/images/stories/issues/8_1/8_nc_jl_tech_117.pdf.

C&A Carbone, Inc. v. Town of Clarkstown, New York, 511 U.S. 383, (U.S. Supreme Court 

1994).

Clean Air Act (CAA). 42 USC 7401, et seq. 

Fordney, Jason. 2007. “Duke Efficiency Charge to Cover Lost Power Sales.” The Energy 

Daily. May 8, 2007. 

Gabbard, Alex. 1993. “Coal Combustion: Nuclear Resource or Danger,” Oak Ridge National 

Laboratory Review. Oak Ridge National Laboratory: Oak Ridge, Tennessee. Summer/Fall 

1993. Available URL: http://www.ornl.gov/ORNLReview/rev26-34/text/colmain.html.

Accessible at ML072920082 Page 76. 

GDS Associates. 2006. A Study of the Feasibility of Energy Efficiency as an Eligible Resource 

as Part of a Renewable Portfolio Standard for the State of North Carolina: Report for the North 

Carolina Utilities Commission. December 2006. Raleigh, NC.

Hong, B.D., and E.R. Slatick (Hong and Slatick). 1994. Energy Information Administration, 

Quarterly Coal Report, January-April 1994, DOE/EIA-0121. Available URL:

http://www.eia.doe.gov/cneaf/coal/quarterly/co2_article/co2.html. Accessible at ML072920082 

Page 89.

Idaho National Engineering and Environmental Laboratory (INEEL). 1997. U.S. Hydropower 

Resource Assessment for North Carolina. DOE/ID-10430(NC). Idaho Falls, Idaho. October 

1997. Available URL: http://hydropower.inl.gov/resourceassessment/pdfs/states/nc.pdf.

Accessible at ML072920082 Page 103. 

Integrated Waste Services Association. 2007. “Waste to Energy and the Production Tax Credit.” 

Fact Sheet. Washington, DC. Available URL: http://www.wte.org/docs/factsheetptc.pdf.

Accessible at ML072920082 Page 115. 
Alternatives

August 2008 8-77 NUREG-1437, Supplement 33 

La Capra Associates, Inc. 2006. Analysis of a Renewable Portfolio Standard for the State of 

North Carolina. Boston, MA. Available URL:

http://www.ncuc.commerce.state.nc.us/rps/NC%20RPS%20Report%2012-06.pdf.

Murawski, John. 2007. “Nuclear Reactor Plan on Hold.” Raleigh News and Observer.

May 31, 2007. 

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

North Carolina Department of Environment and Natural Resources, Division of Waste 

Management (NCDENR/DWM). 2006. “North Carolina Solid Waste Management Annual Report: 

July 1, 2005–June 30, 2006.” Available URL: http://www.wastenotnc.org/swhome/AR05-06.pdf.

North Carolina Department of Environment and Natural Resources and North Carolina Utilities 

Commission (NCDENR and NCUC). 2006. “Implementation of the ‘Clean Smokestacks Act’.”

Available URL: http://www.ncuc.net/reports/csa2006.pdf.

North Carolina General Statutes. Chapter 143: State Departments, Institutions and 

Commissions. Section 215.107D. “Emissions of oxides of nitrogen (NOx) and sulfur dioxide 

(SO2) from certain coal-fired generating units.” Available URL: http://www.ncga.state.nc.us/ 

EnactedLegislation/Statutes/pdf/BySection/Chapter_143/GS_143-215.107D.pdf.

Progress Energy Carolinas. 2006a. “Progress Energy Carolinas Resource Plan.” Prepared for 

North Carolina Utilities Commission Docket No. E-100, Sub 109. September, 2006. Available 

URL: http://ncuc.commerce.state.nc.us/cgi-bin/webview/senddoc.pgm?dispfmt=&itype 

=Q&authorization=&parm2=BAAAAA94260B&parm3=000125616.

Progress Energy Carolinas Inc., (Progress Energy). 2006b. Shearon Harris Unit 1, Applicant’s 

Environmental Report, Operating License Renewal Stage. Raleigh, North Carolina. Accessible 

at ML063350276. 

U.S. Department of Energy (DOE). 1999. “Market-Based Advanced Coal Power Systems Final 

Report.” DOE/FE-0400. May. Available URL:

http://www.netl.doe.gov/technologies/coalpower/refshelf/marketbased_systems_report.pdf.

U.S. Department of Energy (DOE). 2000. “The Wabash River Coal Gasification Repowering 

Project: An Update.” Available URL: http://www.fossil.energy.gov/programs/powersystems/

publications/Clean_Coal_Topical_Reports/topical20.pdf.

U.S. Department of Energy (DOE). 2004. “Tampa Electric Integrated Gasification Combined 

Cycle Project: Project Performance Summary.” Available URL:

http://www.netl.doe.gov/technologies/coalpower/cctc/resources/pdfs/tampa/Tampa_PPS.pdf.
Alternatives

NUREG-1437, Supplement 33 8-78 August 2008 

U.S. Department of Energy (DOE). 2007. “State Energy Alternatives: Alternative Energy 

Resources in North Carolina.” Available URL:

http://www.eere.energy.gov/states/alternatives/resources_nc.cfm Accessible at ML072920082 

Page 39. 

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2001. Renewable 

Energy 2000: Issues and Trends. DOE/EIA-0628(2000). Washington, D.C. Available URL: 

http://www.eia.doe.gov/cneaf/solar.renewables/rea_issues/contents.html.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2006a. Annual 

Energy Review 2005. DOE/EIA-0384(2006). Washington, D.C. Available URL:

http://tonto.eia.doe.gov/FTPROOT/multifuel/038405.pdf.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2006b.

Assumptions to the Annual Energy Outlook 2006 With Projections to 2030.

DOE/EIA-0554(2006). Washington, D.C. Available URL:

http://tonto.eia.doe.gov/FTPROOT/forecasting/0554(2006).pdf.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2006c. “Cost and 

Quality of Fuel for Electric Plants.” DOE/EIA-0191(2006). Washington, D.C. Available URL: 

http://www.eia.doe.gov/cneaf/electricity/cq/cqa2005.pdf.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2007. Annual

Energy Outlook 2007 With Projections to 2030. DOE/EIA-0383(2007). Washington, D.C.

Available URL: http://tonto.eia.doe.gov/FTPROOT/forecasting/0383(2007).pdf. 

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2007a. “Voluntary 

Reporting of Greenhouse Gases Program Fuel and Energy Source codes and Emission 

Coefficients.” Available URL: http://www.eia.doe.gov/oiaf/1605/coefficients.html. Accessible at 

ML072920082 Page 41. 

U.S. Department of Energy, National Renewable Energy Laboratory (DOE/NREL). 2004. 

“Biomass and Biofuels.” Available URL: http://www.nrel.gov/gis/il_biomass.html (accessed 

May 23, 2007). 

U.S. Department of Energy, National Renewable Energy Laboratory (DOE/NREL). 2006.

“Power Technologies Energy Data Book. NREL/TP-620-36729. Available URL: 

http://www.nrel.gov/analysis/power_databook/docs/pdf/39728_complete.pdf.

U.S. Department of Energy, National Renewable Energy Laboratory (DOE/NREL). 2007a.

“United States Atlas of Renewable Resources.” GIS mapping software. Available URL: 

http://www.nrel.gov/gis/maps.html#resource_atlas (accessed March 19, 2007). 
Alternatives

August 2008 8-79 NUREG-1437, Supplement 33 

U.S. Department of Energy, National Renewable Energy Laboratory (DOE/NREL). 2007b.

“Wind Farm Area Calculator.” Available URL: 

http://www.nrel.gov/analysis/power_databook/calc_wind.php (accessed July 11, 2007). 

U.S. Environmental Protection Agency (EPA). 1998a. Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. “Section 1.1: 

Bituminous and Subbituminous Coal Combustion: Final Section Supplement E.” Available URL: 

http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s01.pdf.

U.S. Environmental Protection Agency (EPA). 1998b. "Revision of Standards of Performance 

for Nitrogen Oxide Emissions From New Fossil-Fuel Fired Steam Generating Units; Revisions to 

Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam 

Generating Units, Final Rule. Federal Register Vol. 63, No. 179, pp. 49442-49455.

Washington, D.C. (September 16, 1998.) 

U.S. Environmental Protection Agency (EPA). 1999. "Regional Haze Regulations, Final Rule" 

Federal Register Vol. 64, No. 126, pp. 35714-3577. Washington, D.C. (July 1, 1999). 

U.S. Environmental Protection Agency (EPA). 2000a. Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. “Section 3.1: 

Stationary Gas Turbines: Final Section Supplement F.” Available URL: 

http://www.epa.gov/ttn/chief/ap42/ch03/final/c03s01.pdf.

U.S. Environmental Protection Agency (EPA). 2000b. “Regulatory Finding on the Emissions of 

Hazardous Air Pollutants from Electric Utility Steam Generating Units.” Federal Register.

Vol. 65, No. 245, pp. 79825-79831. Washington, D.C. (December 20, 2000.) 

U.S. Environmental Protection Agency (EPA). 2006. “Revision of December 2000 Clean Air 

Act Section 112(n), Finding Regarding electric Utility Steam Generating Units; and standards of 

Performance for New and Existing Electric Utility Steam Generating Units.” Available URL:

http://www.epa.gov/camr/pdfs/camr_recon_fr_final_053106.pdf.

U.S. Environmental Protection Agency (EPA). 2007a. “List of 156 Mandatory Class I Federal 

Areas.” Available URL: http://www.epa.gov/visibility/class1.html. Accessible at ML072920082 

Page 53. 

U.S. Environmental Protection Agency (EPA). 2007b. “Nonattainment Areas Map – Criteria Air 

Pollutants.” Available URL: http://www.epa.gov/air/data/nonat.html?us~USA~United%20States 

 (accessed June 27, 2007). 

U.S. Environmental Protection Agency (EPA). 2007c. “Clean Air Mercury Rule.” Available 

URL: http://www.epa.gov/camr (accessed July 9, 2007). 
Alternatives

NUREG-1437, Supplement 33 8-80 August 2008 

U.S. Geological Survey (USGS). 1997. “Radioactive Elements in Coal and Fly Ash:

Abundance, Forms, and Environmental Significance; USGS Fact Sheet FS-163-97.” Available 

URL: http://greenwood.cr.usgs.gov/energy/factshts/163-97/FS-163-97.pdf. Accessible at 

ML072920082 Page 237. 

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

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

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

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

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report. 

NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2002. Final Generic Impact Statement on 

Decommissioning of Nuclear Facilities, Supplement 1. NUREG-0586, Washington, D.C.

U.S. Office of Management and Budget (OMB). 2007. ExpectMore.gov. “Detailed Information 

on the Low Income Home Energy Assistance Program Assessment.” Available URL: 

http://www.whitehouse.gov/omb/expectmore/detail/10001059.2003.html (accessed

July 10, 2007).

Walsh, Marie E., Robert L. Perlack, Anthony Turhollow, Daniel de la Torre Ugarte,

Denny A. Becker, Robin L. Graham, Stephen A. Slinsky, and Daryll E. Ray. 1999. “Biomass 

Feedstock Availability in the United States: 1999 State Level Analysis.” Available URL: 

http://bioenergy.ornl.gov/resourcedata/index.html. Accessible at ML072920082 Page 245.
August 2008 9-1 NUREG-1437, Supplement 33 

9.0 SUMMARY AND CONCLUSIONS 

By letter dated November 14, 2006, Carolina Power and Light Company, doing business as 

Progress Energy Carolinas, Inc., (CP&L) submitted an application to the U.S. Nuclear 

Regulatory Commission (NRC) to renew the operating license (OL) for the Shearon Harris 

Nuclear Power Plant, Unit 1 (HNP) for an additional 20-year period. If the OL is renewed, State 

regulatory agencies and CP&L will ultimately decide whether the plant will continue to operate 

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

the purview of the owners. If the OL is not renewed, then the plant must be shut down on or 

before the expiration date of the current OL, which is October 24, 2026. 

Section 102 of the National Environmental Policy Act (NEPA) (42 USC 4321) directs that an 

environmental impact statement (EIS) is required for major Federal actions that significantly 

affect the quality of the human environment. The NRC has implemented Section 102 of NEPA 

in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51). Part 51 identifies 

licensing and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the Commission 

requires preparation of an EIS or a supplement to an EIS for renewal of a reactor OL; 10 CFR 

51.95(c) states that the EIS prepared at the OL renewal stage will be a supplement to the 

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

NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999).(1)

Upon acceptance of the CP&L application, the NRC began the environmental review process 

described in 10 CFR Part 51 by publishing on March 20, 2007, a Notice of Intent to prepare an 

EIS and conduct scoping (NRC 2007b). The NRC staff held public scoping meetings on 

April 18, 2007, in Apex, North Carolina (NRC 2007c), and conducted a site audit at HNP in 

June 2007 (NRC 2007d). In the preparation of this supplemental environmental impact 

statement (SEIS) for HNP, the NRC staff reviewed the CP&L Environmental Report (ER) and 

compared it to the GEIS, consulted with other agencies, conducted an independent review of 

the issues following the guidance set forth in NUREG-1555, Supplement 1, Standard Review 

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

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

process. The NRC staff also considered the public comments received during the scoping 

process for preparation of this SEIS for HNP (NRC 2007a). The public comments received 

during the scoping process that were considered to be within the scope of the environmental 

review are provided in Appendix A, Part 1, of this SEIS. 

The NRC staff held two public meetings in Apex, North Carolina, in January 2008, to describe 

the preliminary results of the NRC environmental review, to answer questions, and to provide 

members of the public with information to assist them in formulating comments on this SEIS 

 

(1) The GEIS was issued in 1996, and Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to GEIS include Addendum 1. 
Summary and Conclusions 

NUREG-1437, Supplement 33 9-2 August 2008 

(NRC 2008). When the comment period ended, the NRC staff considered and addressed all of 

the comments received. These comments were addressed in Appendix A, Part 2, of the final 

SEIS.

This SEIS includes the NRC staff’s analysis that considers and weighs the environmental 

effects of the proposed action, including cumulative impacts, the environmental impacts of 

alternatives to the proposed action, and mitigation measures available for reducing or avoiding 

adverse effects. This SEIS also includes the NRC staff’s recommendation regarding the 

proposed action. 

The NRC has adopted the following statement of purpose and need for license renewal from the 

GEIS:

The purpose and need for the proposed action (renewal of an operating license) is to 

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

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

needs may be determined by State, utility, and, where authorized, Federal (other than NRC) 

decision makers. 

The evaluation criterion for the NRC staff’s environmental review, as defined in 10 CFR 

51.95(c)(4) and the GEIS, is to determine 

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

preserving the option of license renewal for energy planning decision makers would be 

unreasonable.

Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that 

there are factors, in addition to license renewal, that will ultimately determine whether an 

existing nuclear power plant continues to operate beyond the period of the current OL. 

NRC regulations (10 CFR 51.95(c)(2)) contain the following statement regarding the content of 

SEISs prepared at the license renewal stage: 

The supplemental environmental impact statement for license renewal is not required to 

include discussion of need for power or the economic costs and economic benefits of the 

proposed action or of alternatives to the proposed action except insofar as such benefits 

and costs are either essential for a determination regarding the inclusion of an alternative in 

the range of alternatives considered or relevant to mitigation. In addition, the supplemental 

environmental impact statement prepared at the license renewal stage need not discuss 

other issues not related to the environmental effects of the proposed action and the 

alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the 

generic determination in § 51.23(a) and in accordance with § 51.23(b). 
Summary and Conclusions 

August 2008 9-3 NUREG-1437, Supplement 33 

The GEIS contains the results of a systematic evaluation of the consequences of renewing an 

OL and operating a nuclear power plant for an additional 20 years. It evaluates 

92 environmental issues using the NRC’s three-level standard of significance—SMALL, 

MODERATE, or LARGE—developed using the Council on Environmental Quality guidelines. 

The following definitions of the three significance levels are set forth in the footnotes to 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B: 

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. 

For 69 of the 92 issues considered in the GEIS, the NRC staff analysis in the GEIS shows the 

following:

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

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

or other specified plant or site characteristics. 

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

the impacts (except for collective off-site radiological impacts from the fuel cycle and 

from high-level waste [HLW] and spent fuel disposal). 

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

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

are likely not to be sufficiently beneficial to warrant implementation. 

These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and 

significant information, the NRC staff relied on conclusions in the GEIS for issues designated 

Category 1 in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. The NRC staff also 

determined that information provided during the public comment period did not identify any new 

issue that requires site-specific assessment. 

Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2 

issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues, 

environmental justice and chronic effects of electromagnetic fields, were not categorized. 

Environmental justice was not evaluated on a generic basis in the GEIS and must be addressed 

in the SEIS. Information on the chronic effects of electromagnetic fields was not conclusive at 

the time the GEIS was prepared. 
Summary and Conclusions 

NUREG-1437, Supplement 33 9-4 August 2008 

This SEIS documents the NRC staff’s consideration of all 92 environmental issues identified in 

the GEIS. The NRC staff considered the environmental impacts associated with alternatives to 

license renewal and compared the environmental impacts of license renewal and the 

alternatives. The alternatives to license renewal that were considered include the no-action 

alternative (not renewing the OL for HNP) and alternative methods of power generation. These 

alternatives were evaluated assuming that the replacement power generation plant is located at 

either the HNP site or some other unspecified location. 

9.1 Environmental Impacts of the Proposed Action-License Renewal

The NRC staff has an established process for identifying and evaluating the significance of any 

new information on the environmental impacts of license renewal. No information has been 

identified as being new and significant related to Category 1 issues that would call into question 

the conclusions in the GEIS. Similarly, no new environmental issues applicable to HNP were 

identified by the NRC staff through its review process or the public scoping process. Therefore, 

the NRC staff relies upon the conclusions of the GEIS for all Category 1 issues that are 

applicable to HNP.

CP&L’s ER presents an analysis of the Category 2 issues that are applicable to HNP, plus 

environmental justice. The NRC staff has reviewed the CP&L analysis for each issue and has 

conducted an independent review of each issue plus environmental justice. Nine Category 2 

issues are not applicable because they are related to plant design features or site 

characteristics not found at HNP. Three Category 2 issues are not discussed in this SEIS 

because they are specifically related to refurbishment. CP&L has stated that its evaluation of 

structures and components, as required by 10 CFR 54.21, did not identify any major plant 

refurbishment activities or modifications as necessary to support the continued operation of 

HNP, for the license renewal period. In addition, any replacement of components or additional 

inspection activities are within the bounds of normal plant component replacement and, 

therefore, are not expected to affect the environment outside of the bounds of the plant 

operations evaluated in the Final Environmental Statement Related to Operation of Shearon 

Harris Nuclear Power Plant (NRC 1983). 

Eight Category 2 issues related to operational impacts and postulated accidents during the 

renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are 

discussed in detail in this SEIS. Five of the Category 2 issues and environmental justice apply 

to both refurbishment and to operation during the renewal term and are only discussed in this 

SEIS in relation to operation during the renewal term. For all eight Category 2 issues and 

environmental justice, the NRC staff concludes that the potential environmental effects are of 

SMALL significance in the context of the standards set forth in the GEIS. In addition, the NRC 

staff determined that appropriate Federal health agencies have not reached a consensus on the 

existence of chronic adverse effects from electromagnetic fields. Therefore, no further 

evaluation of this issue is required. For severe accident mitigation alternatives (SAMAs), the 
Summary and Conclusions 

August 2008 9-5 NUREG-1437, Supplement 33 

NRC staff concludes that a reasonable, comprehensive effort was made to identify and evaluate 

SAMAs. Based on its review of the SAMAs for HNP, and the plant improvements already 

made, the NRC staff concludes that several candidate SAMAs are potentially cost-beneficial. 

However, none of these SAMAs relate to adequately managing the effects of aging during the 

period of extended operation. Therefore, they need not be implemented as part of license 

renewal pursuant to 10 CFR Part 54. 

Mitigation measures were considered for each Category 2 issue. For most issues, current 

measures to mitigate the environmental impacts of plant operation were found to be adequate. 

Cumulative impacts of past, present, and reasonably foreseeable future actions were 

considered, regardless of what agency (Federal or non-Federal) or person undertakes such 

other actions. For purposes of this analysis, where HNP license renewal impacts are deemed 

to be SMALL, the NRC staff concluded that these impacts would not result in significant 

cumulative impacts on potentially affected resources. 

The following sections discuss unavoidable adverse impacts, irreversible or irretrievable 

commitments of resources, and the relationship between local short-term use of the 

environment and long-term productivity. 

9.1.1 Unavoidable Adverse Impacts 

An environmental review conducted at the license renewal stage differs from the review 

conducted in support of a construction permit because the plant is in existence at the license 

renewal stage and has operated for a number of years. As a result, adverse impacts associated 

with the initial construction have been avoided, have been mitigated, or have already occurred. 

The environmental impacts to be evaluated for license renewal are those associated with 

refurbishment and continued operation during the renewal term. 

The adverse impacts of continued operation identified are considered to be of SMALL 

significance. The adverse impacts of likely power-generation alternatives if HNP ceases 

operation at or before the expiration of the current OL will not be smaller than those associated 

with continued operation of this unit, and they may be greater for some impact categories in 

some locations. 

9.1.2 Irreversible or Irretrievable Resource Commitments 

The commitment of resources related to construction and operation of the HNP during the 

current license period was made when the plant was built. The resource commitments to be 

considered in this SEIS are associated with continued operation of the plant for an additional 

20 years. These resources include materials and equipment required for plant maintenance 

and operation, the nuclear fuel used by the reactors, and ultimately, permanent offsite storage 

space for the spent fuel assemblies. 
Summary and Conclusions 

NUREG-1437, Supplement 33 9-6 August 2008 

The likely power-generation alternatives if HNP ceases operation on or before the expiration of 

the current OL will require a commitment of resources for construction of the replacement plants 

as well as for fuel to run the plants. 

9.1.3 Short-Term Use Versus Long-Term Productivity 

An initial balance between short-term use and long-term productivity of the environment at the 

HNP site was set when the plant was approved and construction began. That balance is now 

well established. Renewal of the OL for HNP and continued operation of the plant will not alter 

the existing balance but may postpone the availability of the site for other uses. Denial of the 

application to renew the OL will lead to shutdown of the plant and will alter the balance in a 

manner that depends on subsequent uses of the site. For example, the environmental 

consequences of turning the HNP site into a park or an industrial facility are quite different. 

9.2 Relative Significance of the Environmental Impacts of License Renewal 

and Alternatives

The proposed action is renewal of the OL for HNP. Chapter 2 describes the site, power plant, 

and interactions of the plant with the environment. As noted in Chapter 3, no refurbishment and 

no refurbishment impacts are expected at HNP. Chapters 4 through 7 discuss environmental 

issues associated with renewal of the OL. Environmental issues associated with the no-action 

alternative and alternatives involving power generation and conservation are discussed in 

Chapter 8.

The significance of the environmental impacts from the proposed action (approval of the 

application for renewal of the OL), the no-action alternative (denial of the application), 

alternatives involving nuclear, gas-fired or coal-fired generation of power at the HNP site and an 

unspecified “alternate site,” and a combination of alternatives are compared in Table 9-1. 

Continued use of a closed-cycle cooling system at the HNP site is assumed for Table 9-1. 

Table 9-1 shows that the significance of the environmental effects of the proposed action is 

SMALL for all impact categories (except for collective offsite radiological impacts from the fuel 

cycle and from high-level waste and spent fuel disposal, for which a single significance level 

was not assigned [see Chapter 6]). Similarly, the environmental effects of the no-action and 

conservation alternatives are SMALL for all impact categories. Other considered powergenerating alternative actions may have environmental effects in at least some impact 

categories that reach MODERATE or LARGE significance. 
Summary and Conclusions 

August 2008 9-7 NUREG-1437, Supplement 33 Alternate Site SMALL to MODERATE SMALL to MODERATE SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL SMALL to MODERATE MODERATE SMALL to MODERATE SMALL to MODERATE MODERATE to LARGE MODERATE to LARGE IGCC Coal-Fired Generation HNP Site SMALL SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL SMALL MODERATE SMALL SMALL SMALL to MODERATE MODERATE Alternate Site SMALL to MODERATE SMALL to MODERATE MODERATE to LARGE SMALL to LARGE SMALL to LARGE SMALL MODERATE MODERATE SMALL to MODERATE SMALL to MODERATE MODERATE to LARGE MODERATE to LARGE Coal-Fired Generation HNP Site SMALL SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL MODERATE MODERATE SMALL SMALL SMALL to MODERATE MODERATE No-Action Alternative Denial of Renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL Proposed Action License Renewal SMALL SMALL SMALL SMALL SMALL SMALL(a) SMALL SMALL SMALL SMALL SMALL SMALL Table 9-1. Summary of Environmental Significance of License Renewal, the No Action Alternative, and Other Alternatives Impact Category Land Use Ecology Water Use and Quality – Surface Water Water Use and Quality– Groundwater Air Quality Waste Human Health Socioeconomics Transportation Aesthetics Historic & archaeological Resources Environmental Justice (a) Except for collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal, for which a significance level was 

not assigned. See Chapter 6 for details
Summary and Conclusions 

NUREG-1437, Supplement 33 9-8 August 2008 Alternate Site MODERATE to LARGE MODERATE SMALL to MODERATE SMALL to MODERATE SMALL SMALL SMALL SMALL to LARGE SMALL to LARGE MODERATE to LARGE SMALL to MODERATE SMALL to MODERATE New Nuclear Power Generation HNP Site MODERATE SMALL to MODERATE SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE MODERATE SMALL SMALL SMALL Alternative Site SMALL to LARGE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE Natural Gas-Fired Generation HNP Site SMALL to MODERATE SMALL SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL Conservation SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL Combination of Alternatives SMALL to MODERATE SMALL SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL Table 9-1. Summary of Environmental Significance of License Renewal, the No Action Alternative, and Other Alternatives Impact Category Land Use Ecology Water Use and Quality – Surface Water Water Use and Quality– Groundwater Air Quality Waste Human Health Socioeconomics Transportation Aesthetics Historic & archaeological Resources Environmental Justice (a) Except for collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal, for which a significance level was not assigned. See Chapter 6 for details.
Summary and Conclusions 

August 2008 9-9 NUREG-1437, Supplement 33 

9.3 NRC Staff Conclusions and Recommendations

Based on (1) the analysis and findings in the GEIS, (2) the ER submitted by CP&L, 

(3) consultation with Federal, State, and local agencies, (4) the NRC staff’s own independent 

review, and (5) the NRC staff’s consideration of public comments received, the recommendation 

of the NRC staff is that the Commission determine that the adverse environmental impacts of 

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

energy planning decision makers would be unreasonable. 

9.4 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

Renewal of Operating Licenses for Nuclear Power Plants.” 

Progress Energy Carolinas Inc., (Progress Energy). 2006. Shearon Harris Unit 1, Applicant’s 

Environmental Report, Operating License Renewal Stage. Raleigh, North Carolina. Accessible 

at ML063350276. 

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

U.S. Nuclear Regulatory Commission (NRC). 1983. Final Environmental Statement Related to 

the Operation of Shearon Harris Nuclear Power Plant. NUREG-0972. Office of Nuclear 

Reactor Regulation, Washington, D.C. Accessible at ML071340292. 

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

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

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

for License Renewal of Nuclear Plants Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.”

NUREG-1437, Volume 1, Addendum 1. Office of Nuclear Regulatory Research, Washington, 

D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555, 

Supplement 1, Washington, D.C. 
Summary and Conclusions 

NUREG-1437, Supplement 33 9-10 August 2008 

U.S. Nuclear Regulatory Commission (NRC). 2007a. “Environmental Scoping Summary 

Report Associated with the Staff's Review of the Shearon Harris Nuclear Power Plant License 

Renewal Application”. Accessible at ML071980195. 

U.S. Nuclear Regulatory Commission (NRC). 2007b. “Notice of Opportunity for Hearing and 

Notice of Intent to prepare an Environmental Impact Statement and Conduct Scoping Process 

of Facility Operating License No. NPF-63 for an Additional 20-year Period, Carolina Power and 

Light Company, Shearon Harris Nuclear Power Plant.” Federal Register: Vol. 72, No. 53, pp. 

13139-13142. Washington, D.C. Accessible at ML070790140. 

U.S. Nuclear Regulatory Commission (NRC). 2007c. “Summary of public meetings related to 

the review of the Shearon Harris nuclear power plant license renewal application.” Accessible 

at ML071200434.

U.S. Nuclear Regulatory Commission (NRC). 2007d. “Summary of site audit related to the 

review of the license renewal application for Shearon Harris nuclear power plant, Unit 1.” 

Accessible at ML071700428. 

U.S. Nuclear Regulatory Commission (NRC). 2008. “Public meetings on the draft Supplemental 

Environmental Impact Statement regarding the Shearon Harris Nuclear Power Plant, license 

renewal review.” Accessible at ML080460469. 
Appendix A 

Comments Received on the Environmental Review 

August 2008 A-1 NUREG-1437, Supplement 33 

Appendix A: 

Comments Received on the Environmental Review 

Part I – Comments Received During Scoping 

On March 20, 2007, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of 

Intent in the Federal Register (72 FR 13139) to notify the public of the NRC staff’s intent to 

prepare a plant-specific supplement to the Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996; 1999),(a)

related to the renewal application for the Shearon Harris Nuclear Power Plant (HNP) operating 

license and to conduct scoping. This plant-specific supplement to the GEIS has been prepared 

in accordance with the National Environmental Policy Act (NEPA), Council on Environmental 

Quality (CEQ) guidance, and Title 10 of the Code of Federal Regulations, Part 51 (10 CFR 

Part 51). As outlined by NEPA, the NRC initiated the scoping process with the issuance of the 

Federal Register Notice. The NRC invited the applicant; Federal, State, and local government 

agencies; Native American tribal organizations; local organizations; and individuals to 

participate in the scoping process by providing oral comments at the scheduled public meetings 

and/or submitting comments by May 19, 2007. 

The scoping process included two public scoping meetings, which were held at the New 

Horizons Fellowship in Apex, North Carolina, on April 18, 2007. The NRC issued press 

releases and announced the meetings in local newspapers. Approximately 180 members of the 

public attended the meetings. Both sessions began with NRC staff members providing a brief 

overview of the license renewal process. Following the NRC’s prepared statements, the 

meetings were open for public comments. Thirty-four attendees provided either oral comments 

or written statements that were recorded and transcribed by a certified court reporter. The 

meetings transcripts can be found as an attachment to the meeting summary, which was issued 

on May 14, 2007 (meeting transcripts, ML071300371 and ML071300377; meeting summary, 

ML071200434). The documents are publicly available and can be found at the Agencywide 

Documents Access and Management System (ADAMS) at 

http://adamswebsearch.nrc.gov/dologin.html or through the NRC’s Electronic Reading Room 

link at http://www.nrc.gov. 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 staff at 1-800-397-4209, or 301-415-4737, or by e-mail at pdr@nrc.gov. 

At the conclusion of the scoping period, the NRC staff reviewed the transcripts and all written 

material received and identified individual comments. Each set of comments from a given 

 

(1) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Appendix A 

NUREG-1437, Supplement 33 A-2 August 2008 

commenter was given a unique alpha identifier (Commenter ID letter), allowing each set of 

comments from a commenter to be traced back to the transcript, letter, or email in which the 

comments were submitted. Specific comments were numbered sequentially within each 

comment set. All of the comments received and the NRC staff responses are included in the 

HNP Scoping Summary Report dated August 9, 2007 (ML071980195). 

Comments were consolidated and categorized according to the topic within the proposed 

supplement to the GEIS or according to the general topic if outside the scope of the GEIS. 

Comments with similar specific objectives were combined to capture the common essential 

issues that had been raised in the source comments. Once comments were grouped according 

to subject area, the NRC staff determined the appropriate action for the comment. 

Table A-1 identifies the individuals who provided comments applicable to the environmental 

review and the Commenter ID associated with each person's set(s) of comments. The 

individuals are listed in the order in which they spoke at the public meeting, and in the 

alphabetical order for the comments received by letter. To maintain consistency with the 

Scoping Summary Report, the unique identifier used in that report for each set of comments is 

retained in this appendix. The Commenter ID is preceded by HNP, which stands for Shearon 

Harris Nuclear Power Plant. Accession numbers indicate the location of the written comments 

in ADAMS. 

The comments fall into one of the following general groups: 

• Specific comments that address environmental issues within the purview of the NRC 

environmental regulations related to license renewal. These comments address 

Category 1 or Category 2 issues or issues that were not addressed in the GEIS. They 

also address alternatives and related Federal actions. 

• General comments (1) in support of or opposed to nuclear power or license renewal or 

(2) on the renewal process, the NRC’s regulations, and the regulatory process. These 

comments may or may not be specifically related to the HNP license renewal 

application. 

• Questions that do not provide new information. 

• Specific comments that address issues that do not fall within or are specifically excluded 

from the purview of NRC environmental regulations related to license renewal. These 

comments typically address issues such as the need for power, emergency 

preparedness, security, current operational safety issues, and safety issues related to 

operation during the renewal period. 

Comments applicable to this environmental review and the NRC staff’s responses are 

summarized in this appendix. The parenthetical alpha-numeric identifier after each comment 

refers to the comment set (Commenter ID) and the comment number. This information, which 
Appendix A 

August 2008 A-3 NUREG-1437, Supplement 33 

was extracted from the HNP Scoping Summary Report, is provided for the convenience of those 

interested in the scoping comments applicable to this environmental review. The ADAMS 

accession number for the Scoping Summary Report is ML071980195. 

Comments in this section are grouped into the following categories: 

A.1.1 Request for Information 

A.1.2 Opposition to Nuclear Power 

A.1.3 Support for Nuclear Power 

A.1.4 License Renewal and Its Processes 

A.1.5 Opposition to License Renewal at Shearon Harris Nuclear Power Plant, Unit 1 

A.1.6 Support for License Renewal at Shearon Harris Nuclear Power Plant, Unit 1 

A.1.7 Water Quality and Use Issues 

A.1.8 Human Health Issues 

A.1.9 Socioeconomic Issues 

A.1.10 Uranium Fuel Cycle and Waste Management Issues 

A.1.11 Alternatives 

A.1.12 Environmental Justice 

A.1.13 Global Warming 

A.1.14 Issues Outside the Scope of License Renewal: Operational Safety, Security, & 

Emergency Preparedness; Safeguards and Security; Need for Power; and Cost of 

Power

Table A-1. Individuals Providing Comments During Scoping Comment Period 

Commenters ID Commenter Affiliation (If Stated) 

Comment Source and ADAMS 

Accession Number(a)

HNP-A John Rukavina Director of Public Safety, Wake County Afternoon Scoping Meeting 

HNP-B Lynn Bauchkey Local Citizen Afternoon Scoping Meeting 

HNP-C Herman Jaffe Local Citizen Afternoon Scoping Meeting 

HNP-D David McNellis Research Professor, University of North 

Carolina, Chapel Hill 

Afternoon Scoping Meeting 

HNP-E John Byrne Mayor, Fuquay-Varina Afternoon Scoping Meeting 

HNP-F Paul Fisher Alderman, City of Southport; Chairman, 

North Carolina Municipal Power Agency

Afternoon Scoping Meeting 
Appendix A 

NUREG-1437, Supplement 33 A-4 August 2008 

Commenters ID Commenter Affiliation (If Stated) 

Comment Source and ADAMS 

Accession Number(a)

HNP-G Robert J. Ahlert Mayor pro tem, Town of Clayton Afternoon Scoping Meeting 

HNP-H David Finger Chairman, Cary Chamber of Commerce 

Board of Directors 

Afternoon Scoping Meeting 

HNP-I Scoop Green Executive Director, Holly Springs 

Chamber of Commerce 

Afternoon Scoping Meeting 

HNP-J Harvey Schmitt President, Greater Raleigh Chamber of 

Commerce 

Afternoon Scoping Meeting 

HNP-K Liz Cullington Local Citizen Afternoon Scoping Meeting 

HNP-L Michael Leach Raleigh-Apex branch of the National 

Association for the Advancement of 

Colored People (NAACP) 

Afternoon Scoping Meeting 

HNP-M Robert Duncan Site Vice President, HNP Afternoon Scoping Meeting 

HNP-N Keith Sutton President, Triangle Urban League Afternoon Scoping Meeting 

HNP-O Tom Oxholm Chief Financial Officer, Wake Stone 

Corporation 

Afternoon Scoping Meeting 

HNP-P Carl Wilkins Past President, North Carolina Chapter 

of the American Association of Blacks 

in Energy 

Afternoon Scoping Meeting 

HNP-Q Nelle Hotchkiss Senior Vice President of Corporate 

Relations, North Carolina Electric 

Membership Corporation 

Afternoon Scoping Meeting 

HNP-R Ken Atkins Executive Director, Wake County 

Economic Development 

Afternoon Scoping Meeting 

HNP-S Hilda PinnixRagland 

Vice President, Progress Energy’s 

Northern Region 

Afternoon Scoping Meeting 

HNP-T Dick Sears Mayor, Holly Springs Evening Scoping Meeting 

HNP-U Gina Dean State Advisor, NAACP Evening Scoping Meeting 
Appendix A 

August 2008 A-5 NUREG-1437, Supplement 33 

Commenters ID Commenter Affiliation (If Stated) 

Comment Source and ADAMS 

Accession Number(a)

HNP-V Ann Turnbill Local Citizen Evening Scoping Meeting 

HNP-W Lee Craig Professor of Economics, North Carolina 

State University 

Evening Scoping Meeting 

HNP-X Lou Ebert President, North Carolina State 

Chamber of Commerce 

Evening Scoping Meeting 

HNP-Y John Rukavina Director of Public Safety, Wake County Evening Scoping Meeting 

HNP-Z Marvin Furman Local Citizen Evening Scoping Meeting 

HNP-AA Sandy Jordan Vice President of Economic 

Development, Cary Chamber of 

Commerce 

Evening Scoping Meeting 

HNP-BB Bernie Hodges President, Wade Manufacturing 

Company 

Evening Scoping Meeting 

HNP-CC Elizabeth Rooks Executive Vice President, Research 

Triangle Foundation 

Evening Scoping Meeting 

HNP-DD William D. 

Lynch

People’s Channel Evening Scoping Meeting 

HNP-EE Ed Bonner Member, Board of Directors of the 

Raleigh Chamber of Commerce 

Evening Scoping Meeting 

HNP-FF Scott Lasell Chairman, Eastern Carolina Section of 

the American Nuclear Society 

Evening Scoping Meeting 

HNP-GG Tony Gurley Chairman, Wake County Board of 

Commissioners 

Evening Scoping Meeting 

HNP-HH Donna 

Alexander 

Employee, Progress Energy Evening Scoping Meeting 

HNP-II Herman Jaffe Local Citizen Evening Scoping Meeting 

HNP-JJ Jackie Clements Retired Employee, Progress Energy Evening Scoping Meeting 

HNP-KK Town of Clayton Resolution (ML071300371) 
Appendix A 

NUREG-1437, Supplement 33 A-6 August 2008 

Commenters ID Commenter Affiliation (If Stated) 

Comment Source and ADAMS 

Accession Number(a)

HNP-LL Holly Springs Chamber of Commerce Resolution (ML071300371) 

HNP-MM Cary Chamber of Commerce Resolution (ML071300371) 

HNP-NN Fuquay-Varina Chamber of Commerce Resolution (ML071300371) 

HNP-OO Wake County Mayor’s Association Resolution (ML071300371) 

HNP-PP Greater Raleigh Chamber of Commerce Resolution (ML071300371) 

HNP-QQ Wake County Economic Development 

Commission 

Resolution (ML071300371) 

HNP-RR Board of Commissioners of the North 

Carolina Eastern Municipal Power 

Agency

Resolution (ML071300371) 

HNP-SS Raleigh-Apex NAACP Resolution (ML071300024) 

HNP-TT Wendell-Wake Br. NAACP Resolution (ML071300024) 

HNP-UU American Association of Blacks in 

Energy North Carolina Chapter 

Resolution (ML071300024) 

HNP-VV Keith Sutton President and CEO, Triangle Urban 

League 

Letter (ML071300024) 

HNP-WW Liz Cullington Local Citizen Letter (ML071150313) 

HNP-XX Rudolph 

Williams 

Local Citizen Letter (ML071210160) 

(a) The afternoon and evening transcripts can be found under accession numbers ML071300371 and ML071300377, respectively. 

Part 1 — Comments Received During Scoping 

A.1.1 Request for Information 

Comment: I'm asking the NRC to provide a copy of the generic environmental impact statement 

to the Cary library. I also request that the NRC allow another 60 days to allow for adequate 

comment. (HNP-K-15)
Appendix A 

August 2008 A-7 NUREG-1437, Supplement 33 

Comment: The NRC is urged to allow another 60 days to allow for adequate comment. We 

also request that the GEIS be provided to the Cary Library and Eva Perry Library. Without 

these documents it is impossible for interested members of the public to know what 

environmental impacts are supposed to be considered in which process, the adequacy of 

current scoping plans, or how the process affects the future of their environment. (HNP-WW-7)

Response: The NRC staff believes that 60 days is an appropriate time frame to conduct the 

environmental scoping process for License Renewal. A scoping period extension of 60 

additional days in this case was not warranted. In the past the NRC staff has accepted late 

comments on the scope of the environmental review to the extent that it was practicable to do 

so. In response to this comment received during the scoping meeting, the NRC staff placed a 

copy of the GEIS in the local libraries and also provided a copy of the GEIS to the commenter.

A.1.2 Opposition to Nuclear Power 

Comment: I like to put the onus, the responsibility on the public, on us, to figure an issue. I 

worked for ABC News for many years. That doesn't mean a thing. I have the benefit of their 

library, and when Three Mile Island happened, and when the arms build-up in the '80s 

happened, I got involved in the anti-nuclear movement, and the anti-weapons movement. 

But I realized, when somebody said to me, on the street, handing out a leaflet, you don't know 

what you are talking about. All the literature out there is a lot to read, isn't it? But to study the 

beast, or the benefit, is something we must do, right? That is why we are here. It is really 

serious. People joke. Like I was talking with one of the engineers from the NRC about the 

Simpsons being something that jokes about glowing reactors, and all this. 

This is true. Why is this? Because are we scared of our ignorance of the issue, are we scared 

of the potential? When I drive across 64, and I see the cooling tower steaming away, and think 

of all the people boating, and having fun in the lake, and just the risk that exists, that is a gut 

fear. Apex had the chemical fire, Three Mile Island had their thing, Love Canal had their thing, 

Virginia Tech had their thing. The unexpected can happen. And that is why I'm actually more in 

the side of the military running plants than commercial ventures, because of the risk of profit 

overriding safety. (HNP-DD-2) 

Response: The comment is noted. The comment opposes nuclear power and does not provide 

any new information. This comment is not within the scope of 10 CFR Part 51 for the 

environmental review associated with the application for license renewal at Shearon Harris 

Nuclear Power Plant, Unit 1. Therefore, this comment will not be considered further in this 

SEIS.
Appendix A 

NUREG-1437, Supplement 33 A-8 August 2008 

A.1.3 Support for Nuclear Power 

Comment: And I agree with DOE assistant secretary Dennis Bergen, who recently said, any 

serious efforts to stabilize greenhouse gases in the atmosphere, while providing the increasing 

amount of energy for economic development and growth must include expanded use of nuclear 

energy. That, obviously, includes the retention of current capabilities through the license 

renewal process. (HNP-M-2)

Comment: In a broader context, nuclear energy is essential to a balanced portfolio for any 

energy company operating in North Carolina. North Carolina Electric Membership Corporation 

has interest in a nuclear plant as well, and supports the continuation and development of 

nuclear resources in our state. (HNP-Q-2)

Comment: I entered my profession because I believe that nuclear technology provides many 

benefits to our society, and improves our quality of life. I also believe, from many years of 

interactions with nuclear professionals, from Progress Energy and the NRC, that nuclear 

technology is being used safely for the generation of power here in North Carolina. (HNP-FF-1)

Comment: In my 12 years of experience, working at three different nuclear research reactor 

facilities, I have been continually impressed with the dedication and commitment of the nuclear 

professionals with whom I have come in contact. This includes the scientists and staff 

responsible for the operation and utilization of the facilities, and the NRC inspectors, and 

examiners, that regularly visit the facility, to assure the safe operation, and regulatory 

compliance. (HNP-FF-3) 

Response: The comments are noted. The comments are in favor of nuclear power and do not 

provide any new information. The comments are not within the scope of 10 CFR Part 51 for the 

environmental review associated with the application for license renewal at Shearon Harris 

Nuclear Power Plant, Unit 1. Therefore, these comments will not be considered further in this 

SEIS.

A.1.4 License Renewal and Its Processes 

Comment: The generic environmental impact statement is not adequate to address future 

environmental impacts 40 years into the future, since it was only prepared in the 1990s. 

Significant new mechanisms have been discovered since that time, which have drastically 

altered both projected impacts and timeliness of climate change effects. 

Any issue that was covered inadequately in the GEIS, or not covered at all, but which involves 

future environmental impacts, in this case, should be allowed into the scope of the plant specific 

environmental impact statement. (HNP-K-14)

Response: The NRC staff will base its analysis of environmental impacts of license renewal on 

the GEIS which was issued in 1996 as amended in 1999. As part of its review the NRC staff will 
Appendix A 

August 2008 A-9 NUREG-1437, Supplement 33 

look for any new and additional information that might call into question the conclusions reached 

in the GEIS for Category 1 issues. The review for Category 2 issues will take into account 

available site specific data and analysis to base its conclusions. While the commenter argues 

that the GEIS is outdated and should not be used as a base for the assessment, the NRC staff 

believes that the current process assures that any new information that comes to light will be 

used to make the final assessment of the environmental impacts of the proposed action.

Comment: Scoping issues that ought to be included in the supplemental plant specific EIS, 

specific environmental and public health impacts that are supposed to be analyzed in the EIS 

seem very hard to predict in the future, but I tried to come up with a list of things that should be 

analyzed, and what is wrong with the current analysis. (HNP-K-4)

Comment: The vast majority of the public only had a few days notice from Sunday's April the 

17th News and Observer, or possibly a week from one or more of the local papers. That is a 

certain amount of information, but probably not full or adequate. Without these documents it is 

impossible for interested members of the public to know what environmental impacts are 

supposed to be considered, and which process the adequacy of current scoping plans, or how 

the process affects the future of their environment. The entire relicensing process is a 

premature action which is unwise and unnecessary. What is the hurry? The Harris plant 

operating license is good for another 20 years, and does not need to be renewed at this time. 

To rule on aging and safety issues, 20 years in the future, is both risky and absurd. The 

licensee has not even attempted to frame these issues in the required future years of 2026 to 

2046. Instead they have prepared a report that could be quickly adapted for other purposes, 

such as to support a combined operating and siting license, construction license, for one or two 

new reactors at the Harris site, since it covers conditions in the year 2006, not 2026, let alone 

2046. (HNP-K-16)

Comment: Why are you all here? Are your heads tired, a lot of science, politics, economics? It 

may be because I'm a new resident to Chatham County, who is anti-nuclear, but is also curious 

about the whole issue, which isn't just are you against or for the plant, the renewal, another 

plant. Are you scared of the plant, are you wanting the plant? Or maybe because this 

opportunity to come to a meeting, to speak with the NRC, to speak with and listen to other 

community members who are very well versed in what their agenda is, to present to the public. 

What I have seen of the public's discussion of the issue is impassioned, desperate perhaps, 

fearful, and unfortunately not as informed as we could be. (HNP-DD-1)

Comment: But thank God the NRC is there, and that there are people who oversight, and that 

there is oversight, and there is review. But as we know, from Katrina, as we know from so many 

things, it is not enough. The responsibility is on us. As Progress Energy rate payers, as future 

rate payers if there is a new plant, as parents, citizens, Americans, taxpayers. (HNP-DD-3)

Response: The comments are noted. These comments oppose license renewal and speak to 

NRC’s license renewal review process in general, but do not provide new and significant 

information. The comments do not raise any issues within the scope of this license renewal 

review. Therefore, the comments will not be evaluated further.
Appendix A 

NUREG-1437, Supplement 33 A-10 August 2008 

A.1.5 Opposition to License Renewal at HNP 

Comment: It is their future, for our sins. And I'm just asking you to please consider it. People 

don't want alternative. I lived in Wales for a year and a half. Actually I thought the windmills 

looked pretty good. I would rather look at a windmill than look at nothing, or know that I lived 

and gave these sins of us, to our children. And that is about all I have to say, thank you. 

(HNP-B-2)

Comment: Shearon Harris has stalled on replacing known unsafe firewalls, and wiring, and 

does not really qualify as a responsible operator. The corrections must be made before you, the 

NRC, consider a license extension that Shearon Harris has asked for. (HNP-C-3)

Comment: For this reason alone it is dangerous and unnecessary for the NRC to proceed with 

considering extending the Harris plant license at this time. (HNP-K-7)

Comment: Because it is that important. The fire safety issues, the bizarre potential of an 

evacuation being jammed up, and any kind of a reaction to get away from an accident to me is 

crazy. But I have a lot more to learn about it. It is easy to say stuff. People talk a lot, there is 

not much real dialogue. American Idol is what people watch, isn't it? But do they watch the 

news, do they stay with an issue? I hope that everybody leaves here, tonight, with a different 

perspective. It is not about who is sitting here, or sitting there, or talking. It is what do we do at 

this point in our history about our energy use, and the safe development of it. Because this 

place is developing, North Carolina, the country, at an incredible rate. And is nuclear going to 

be one of the answers? (HNP-DD-4) 

Comment: There are several other reasons, I said, that let's us want to consider not the 

extension at this time, but to wait ten years. We may be, by that time, considering shutting 

Shearon Harris down, and that is a fact of life. I know I heard about 11 people praising 

Progress Energy to the hilt, and I can appreciate why. But, you know, the world changes, things 

change, and it is time that you guys got out there and looked a little bit beyond your rose colored 

lenses. (HNP-II-2)

Comment: Progress Energy's Environmental Report is an arrogant insult to the public that pays 

their bills, drinks their radioactive water, and has to put up with their legitimate concerns being 

routinely dismissed as scaremongering, attacks on the workers, or sheer ignorance. It is clear 

that Progress Energy assumes that no one will read the report, a pretty fair assumption, but also 

that no one at the NRC will either. That is how low an opinion they have of the NRC. They 

apparently believe that they can submit any sort of document, as long as it is of suitable 

thickness, to support any new decision they are asking for. (HNP-WW-8)

Response: The comments are noted. The comments oppose license renewal at Shearon 

Harris Nuclear Power Plant, Unit 1 and do not provide new and significant information. These 

comments are not within the scope of 10 CFR Part 51 for the environmental review associated 

with the license renewal application for HNP. Therefore, these comments will not be evaluated 

further in this SEIS.
Appendix A 

August 2008 A-11 NUREG-1437, Supplement 33 

A.1.6 Support for License Renewal at HNP

Comment: I'm here to speak in favor of extending the license for the Shearon Harris nuclear 

power plant. (HNP-D-1)

Comment: I have toured the facility and, periodically, talked with some of the plant's staff and 

employees. They have earned my confidence, over the years, and I'm pleased to speak in 

support of this application to extend the license, for the Harris facility, for an additional 20 years. 

(HNP-D-7)

Comment: Many of the employees who work at the Shearon Harris plant live in, and are a part 

of, our community. I am confident that their commitment to safe operation of the plant, and their 

strong commitment to the environment, are there. There are numerous activities that the lake, 

and the Harris park, offers, to citizens, including hiking, and nature trails. (HNP-E-2)

Comment: While we face challenges in meeting the demands of growth, certainly our region 

has, and will continue, to meet those challenges while we work together. In that spirit of team 

work, cooperation, the Wake County Mayors Association has unanimously, there are 12 

municipalities in Wake County, and they support this renewal, unanimously, with a resolution.

I'm also a member of the Board of Directors of the Fuquay Chamber of Commerce, and its 

support was unanimous. I truly believe that we will have a continued safe and reliable operation 

at the Harris plant, with the 20 year license renewal. (HNP-E-4)

Comment: Progress Energy has an outstanding track record and is recognized, world-wide, as 

an industry leader in safe and reliable nuclear operations. The North Carolina Municipal Power 

Agency supports the continued safe and secure operations of the Harris plant, and encourages 

favorable considerations of the license renewal extension. I have left a copy, with your 

receptionist, of my remarks, plus the Resolution of the 32 cities in support of this license 

renewal favorably. I thank you for the opportunity to speak to you this afternoon. (HNP-F-2)

Comment: In closing, the town of Clayton, and the Eastern Municipal Power Agency, endorse 

the application of Progress Energy to renew the operating license for Shearon Harris nuclear 

generating plant. Premature closing of the plant would have a negative impact for the more 

than 425,000 citizens in the agency municipalities, and the more than 250,000 electric 

customers they serve. We encourage you to give favorable consideration to a safe and secure 

operating license renewal of the Shearon Harris plant for the economic and environmental 

reasons previously stated. (HNP-G-3)

Comment: The Cary Chamber fully supports the continued safe and secure operation of the 

Harris plant, and encourages the NRC to extend the Harris plant's operating license an 

additional 20 years. (HNP-H-1)

Comment: To the NRC we ask that you take whatever steps are necessary to facilitate the 

operating license extension, and thank you for allowing us to participate in this hearing today. 

And I would also like to leave, with you, a resolution that was unanimously approved by our 

Board of Directors and our Executive Board. (HNP-H-5)
Appendix A 

NUREG-1437, Supplement 33 A-12 August 2008 

Comment: On January 24th, 2007, with one hundred percent support, the Holly Springs 

Chamber of Commerce Board of Directors passed a resolution in support of the continued safe 

and secure operations of the Shearon Harris nuclear plant. Besides Progress Energy's proven 

track record and safety, we also recognize their tremendous economic impact, and the 

environmental resources that Progress Energy has in Holly Springs, as well as within Wake 

County. Please support the necessary steps to facilitate the operating license extension. 

(HNP-I-1)

Comment: Obviously it has a big impact. Greater Raleigh Chamber of Commerce would 

support this relicensing request, and would ask that the agency consider the fact that this 

growth has taken place in the market, and will have an impact on the need for electricity in our 

community for some time to come. (HNP-J-2)

Comment: And I have submitted a resolution in support of the Harris license renewal. I work 

with Progress Energy on various projects over the years. And I'm familiar with its Harris plant.

(HNP-L-1)

Comment: Therefore I support to ensure the Harris plant continues to operate in the future, 

providing safe, reliable, and affordable energy. (HNP-L-3)

Comment: It is important to clarify that if our application is approved, that doesn't give us carte 

blanche to operate for another 20 years. We have to earn that license every minute, of every 

day, through our performance. We are a good neighbor, and a capable corporate citizen. And 

we intend to preserve what has been entrusted to us, and that is our commitment. (HNP-M-5)

Comment: Like other community leaders I have worked closely with Progress Energy since 

2000, and I know first hand the commitment this company has to the community that it serves. 

As that community continues to grow, with these accolades and others, so will the demand for 

electricity. Therefore I advocate for safe, affordable, and reliable electricity. And in my 

observation Progress Energy is capable of providing such and, therefore, I support moving 

forward with the license renewal of the Harris plant. (HNP-N-1)

Comment: With demand for our products growing in Wake county, and eastern North Carolina, 

failure to renew the license of the Harris plant would threaten the reliability of our needed power 

source, and affordability of our products. (HNP-O-4)

Comment: Thank you for the opportunity to speak, and to ask you to please renew the Harris 

plant license. (HNP-O-7) 

Comment: We have lived with the Shearon Harris nuclear power plant in our region since 1987 

and have observed that it is operated without a major incident. We also know that it operates at 

a low cost of production, which helps keep our local electric rates low. In addition we have 

observed that it has operated reliably and safely. Therefore it is the opinion of the North 

Carolina Chapter of the American Association of Blacks in Energy, that Progress Energy's 
Appendix A 

August 2008 A-13 NUREG-1437, Supplement 33 

application to extend this operating license for Shearon Harris nuclear power plant be granted 

by the Nuclear Regulatory Commission. (HNP-P-3)

Comment: North Carolina Electric Membership Corporation is a wholesale customer of 

Progress Energy Carolinas. The Harris plant is an important part of Progress Energy's 

resources. Extending the life of a well run, existing plant, in today's global environment of rising 

energy costs, and environmental sensitivity, provides for the continuation of emission free, 

reliable power, at the lowest possible cost to the citizens of North Carolina, including our electric 

cooperative membership. (HNP-Q-1) 

Comment: We strongly support the relicensing of the Harris plant and encourage the Nuclear 

Regulatory Commission to do so as well. (HNP-Q-3)

Comment: I'm here to support the extension of the license for Progress Energy. North Carolina 

and Research Triangle Region is recognized as one of the most dynamic economies in the 

U.S., we heard some of the earlier accolades. (HNP-R-1)

Comment: It is for that reasons, and many of the others that you heard today, that Wake 

County Economic Development strongly supports the extension of the license. We feel it is a 

critical part of our vibrant economy and must be in place for us to move forward. (HNP-R-3)

Comment: Now, as I close, I'm extremely pleased to announce that we have support from 13 

different entities. These are resolutions. Some of them have been mentioned already. I will 

mention just the 13. The Raleigh Apex branch of the NAACP, the American Association of 

Blacks in Energy; the Wendell Wake branch of the NAACP, the Triangle Urban League, the 

Holly Springs Chamber of Commerce, the Fuquay-Varina Area Chamber of Commerce, Wake 

County Economic Development, Town of Clayton, the Greater Raleigh Chamber of Commerce, 

the North Carolina Economic Developers Association, the North Carolina Eastern Municipal 

Power Agency, and the Wake County Mayors Association. 

Again, I thank you for allowing me this opportunity, and I definitely endorse the renewal of the 

plant. (HNP-S-4)

Comment: And I'm pleased to support, pleased to support, Progress Energy's request for 

license renewal. Briefly, which is difficult for mayors, the reasons behind that would include I 

met with both of these gentlemen, several months ago, and we talked about this in detail. The 

plant has been part of our area, now, for almost 20 years. And, in my opinion, they have 

supplied safe, reliable, efficient, and clean electricity to our town, region, and state. (HNP-T-1)

Comment: We have just been impressed with the diversity initiatives that Progress Energy has 

shown us, as well as their relationships with the community. And so it is with great pleasure that 

I lend our support, and the NAACP, and to the Harris plant, but in short, we have the confidence 

that will tend to the growth, and everything else, as they always have, and will continue to do. 

(HNP-U-1)
Appendix A 

NUREG-1437, Supplement 33 A-14 August 2008 

Comment: And we are just very fortunate that we live in Wake County, in experiencing the 

growth, and the prosperity here. And having said that, I would like to tell you that I hope that 

you grant the renewal for the license for the Shearon Harris nuclear plant so we can continue to 

grow and prosper in Wake County. (HNP-V-2)

Comment: I'm pleased to stand here tonight in support of Progress Energy's application for 

reauthorizing the Shearon Harris plant. The State Chamber, the North Carolina Chamber, and 

its 25,000 members across the state, support a growing and competitive economy, which 

creates opportunities for all North Carolina citizens. (HNP-X-1)

Comment: We expect that that relationship will continue, and we look forward to working with 

Progress Energy in maintaining those emergency response plans, and exercising them so that if 

something were to occur we would be ready to respond appropriately in the interest of the 

community. (HNP-Y-1)

Comment: For 20 years the Shearon Harris nuclear plant has helped provide the region with 

reliable electrical energy. It is a facility that has operated safely, and efficiently, during those 20 

years, and is extremely important, as our region looks to its future prosperity. Accordingly I 

would ask the Commission to positively act on the license renewal request requested by 

Progress Energy. (HNP-AA-2)

Comment: I am not aware of any environmental or safety issues caused by the Shearon Harris 

plant. I believe the past record, and rules and regulations that the plant operates under, are 

evidence of a well run and properly regulated facility. I simply believe the word nuclear has bad 

connotations. I wish we could change the word. I certainly believe the majority of homeowners 

and industrial customers want the lowest rate for electricity. I further believe that all North 

Carolinians want to do our best to save manufacturing jobs in our state. 

For these reasons I support and strongly encourage the office of Nuclear Reactor Regulation, to 

fully investigate and extend the requested operating license for the Shearon Harris plant. 

(HNP-BB-3)

Comment: The Research Triangle Foundation is the developer of the Research Triangle Park, 

a 7,000 acre science park, which houses 157 companies, and over 20 million square feet of 

buildings, and employs more than 39,000 people. RTF has been a major economic engine for 

the Triangle area, and for North Carolina as a whole. Provision of adequate, clean, costeffective, reliable electricity is crucial to the maintenance, and future expansion, of companies in 

RTP. For these reasons we support the license renewal of the Harris plant. (HNP-CC-1)

Comment: And I would like to respectfully submit, for the record, a resolution passed 

unanimously, by the general membership of the Raleigh Chamber, supporting the extension of 

Progress Energy's license to operate the Shearon Harris nuclear plant. (HNP-EE-1)

Comment: And, finally, Progress Energy's commitment to our community. The membership of 

our chamber recognizes that extending the operating license of the Harris plant is an important 
Appendix A 

August 2008 A-15 NUREG-1437, Supplement 33 

part of meeting our community's growing electricity needs, and asks this Commission to extend 

the license of the Shearon Harris nuclear plant. (HNP-EE-4)

Comment: I would, therefore, like to go on record as supporting the relicensing of the Shearon 

Harris plant, by the NRC, because I believe that nuclear energy is a reliable and 

environmentally sound, and above all else, a safe form of power generation. (HNP-FF-2)

Comment: So, to summarize, my professional experience has given me an appreciation of the 

clear benefits of nuclear technology. And, as importantly, trust and respect for the people that 

are responsible for ensuring its safe deployment and utilization here in North Carolina. In 

closing I simply ask the NRC to carefully and thoughtfully execute your responsibilities as 

related to the renewal of the Harris plant license, and support the ongoing generation of 

electricity with nuclear power. (HNP-FF-5)

Comment: I would like to express my personal support for the license renewal for Progress 

Energy's Shearon Harris facility. My responsibility as a county commissioner is to prepare for 

the growth in our county, while improving the quality of life for all citizens. I have found 

Progress Energy to be a willing and capable partner in my efforts, over the past five years. 

Progress Energy, through its capable employees, have contributed in a very positive manner, as 

a responsible corporate citizen. Most importantly the services and the energy produced by 

Progress Energy are needed and are essential to the continued growth of this area. I'm proud 

to offer my support and gladly offer my thanks for the many contributions from Progress Energy 

to the citizens of Wake County. (HNP-GG-1)

Comment: I am -- I can personally attest to the company's commitment to the environmental 

protection, both from a radiological and non-radiological programs. I am proud to work with a 

dedicated team of individuals at the plant. Many long time employees that provide the essential 

energy for the area. And I can say that decisions made at the plant safety is considered first 

and foremost in all decisions that are made, both personal safety and nuclear safety. And I'm 

excited to be a part of the extended operating license for the Harris plant. (HNP-HH-1)

Comment: And I'm here to personally attest to my complete confidence and trust in the ability of 

Progress Energy to continue to operate the Shearon Harris plant, which we need, in the most 

safe, reliable, efficient operation. I have worked with the management teams, and employees of 

the Shearon Harris plant, during the construction of the plant, as well as after it went into 

commercial operation. (HNP-JJ-1)

Comment: I appreciate the opportunity to speak tonight, to you. And, again, I'm in favor the 

license renewal. We need the plant to meet customer growth. It is clean power. The 

management team at Progress Energy, as well as the employees, have a culture of acting with 

integrity, and the commitment to nuclear power is there on a daily basis, 24/7. (HNP-JJ-3)

Comment: NOW, THEREFORE, BE IT RESOLVED that the Town of Clayton supports the 

continued safe and secure operation of the Harris Plant and encourages the Nuclear Regulatory 
Appendix A 

NUREG-1437, Supplement 33 A-16 August 2008 

Commission to extend the Harris Nuclear Plant's operating license an additional 20 years. 

(HNP-KK-5)

Comment: Now, Therefore, Be It Resolved that the Holly Springs Chamber of Commerce 

supports the continued safe and secure operation of the Harris Plant and encourages the 

Nuclear Regulatory Commission to extend the Harris Nuclear Plant's operating license an 

additional 20 years. (HNP-LL-5) 

Comment: Now, Therefore, Be It Resolved that the Cary Chamber of Commerce supports the 

continued safe and secure operation of the Harris Plant and encourages the Nuclear Regulatory 

Commission to extend the Harris Nuclear Plant's operating license an additional 20 years. 

(HNP-MM-5) 

Comment: Now, Therefore, Be It Resolved that the Fuquay-Varina Area Chamber of 

Commerce supports the continued safe and secure operation of the Harris Plant and 

encourages the Nuclear Regulatory Commission to extend the Harris Nuclear Plant's operating 

license an additional 20 years. (HNP-NN-5)

Comment: Now, Therefore, Be It Resolved that the Wake County Mayor's Association supports 

the continued safe and secure operation of the Harris Plant and encourages the Nuclear 

Regulatory Commission to extend the Harris Nuclear Plant's operating license an additional 20 

years. (HNP-OO-5)

Comment: Now, Therefore, Be It Resolved that the Greater Raleigh Chamber of Commerce 

supports the continued safe and secure operation of the Harris Plant and encourages the 

Nuclear Regulatory Commission to extend the Harris Nuclear Plant's operating license an 

additional 20 years. (HNP-PP-7)

Comment: Now, Therefore, Be It Resolved that the Wake County Economic Development 

Commission supports the continued safe and secure operation of the Harris Plant and 

encourages the Nuclear Regulatory Commission to extend the Harris Nuclear Plant's operating 

license an additional 20 years. (HNP-QQ-7)

Comment: Now, therefore, be it resolved that the Board of Commissioners of the North 

Carolina Eastern Municipal Power Agency supports the continued safe and secure operation of 

the Harris Plant and encourages the Nuclear Regulatory Commission to extend the Harris 

Plant's operating license an additional 20 years. (HNP-RR-6) 

Comment: Now, Therefore, Be It Resolved that the Raleigh-Apex NAACP supports the 

continued safe and secure operation of the Harris Plant and encourages the Nuclear Regulatory 

Commission to extend the Harris Nuclear Plant's operating license an additional 20 years. 

(HNP-SS-5)

Comment: Now, Therefore, Be It Resolved that the Wendell-Wake Br. NAACP supports the 

continued safe and secure operation of the Harris Plant and encourages the Nuclear Regulatory 
Appendix A 

August 2008 A-17 NUREG-1437, Supplement 33 

Commission to extend the Harris Nuclear Plant's operating license an additional 20 years. 

(HNP-TT-5)

Comment: Now, Therefore, Be It Resolved that the American Association of Blacks in Energy 

North Carolina Chapter supports the continued safe and secure operation of the Harris Plant 

and encourages the Nuclear Regulatory Commission to extend the Harris Nuclear Plant's 

operating license an additional 20 years. (HNP-UU-5)

Comment: We support the continued safe and secure operation of the Harris Nuclear Plant and 

encourage the Nuclear Regulatory Commission to extend the plant's operating license an 

additional 20 years. (HNP-VV-3)

Response: The comments are noted. The comments support license renewal at Shearon 

Harris Nuclear Power Plant, Unit 1 and do not provide new and significant information. These 

comments are not within the scope of 10 CFR Part 51 for the environmental review associated 

with the license renewal application for HNP. Therefore, these comments will not be evaluated 

further in this SEIS.

A.1.7 Water Quality and Use Issues 

Comment: I urge the NRC to reject Progress Energy's application for license extension at this 

time. If the NRC insists on proceeding along this relicensing track, then I urge the NRC to reject 

the company's draft EIS and require them to attempt to meet their legal requirements for the 

future period in question. Secondly, the NRC must not begin consideration of an application for 

one or two new reactors at the Harris site, until the relicensing process for the first reactor is 

finalized, and all the water supply, and other issues, described above, are resolved. The NRC 

must not allow a separate track process under which the company could allocate the same 

resource to several different safety and environmental impact analysis without the left hand 

counting what the right hand is doing. (HNP-K-17) 
Appendix A 

NUREG-1437, Supplement 33 A-18 August 2008 

Comment: The first one is water supply for reactor cooling. There are significant water supply 

issues with the plant now, with water having to be pumped from the lower Harris lake reservoir, 

to the upper lake reservoir, during dry months. The source for this information is Progress 

Energy's application for renewal of its North Carolina NPDES permit in 2006. Harris lake, 

compared to some other lakes in our state, has a relatively small and poor cachement area. It 

is not fed by a single major river. To what extent is Progress Energy double dipping in regards 

to the possibility of raising the water level in the lower reservoir of Harris Lake? The company 

has said that this could be done to serve two additional reactors. That water supply, if that is 

done, that water supply would not be available for additional reactors if it turns out that it is 

needed for the current reactor, and vice versa. (HNP-K-5)

Comment: In addition to actual water volume use of the lake for makeup water for a nuclear 

reactor, raises its temperature. And so a usable water body can be temperature limited, and 

affected by increasingly hot summers. The availability of Harris lake as a heat sink not just for 

routine cooling for the period of 2026 to 2046 would need to be evaluated in light of this water 

supply factors, and may need to be evaluated for the current term of the operating license. 

(HNP-K-6)

Response: The comments are noted. Water use conflicts and Cumulative Impacts are 

discussed in Chapter 4 of this SEIS. 

Comment: The high level waste storage, i.e., the fuel pools and the water supply, a separate 

analysis would need to be done for future scenarios of climate change on the fuel pools, 

including the possibility of no repository. This analysis must include the availability of the lake to 

provide cooling, and the heat sink, to the fuel pools, and the reactor, simultaneously, under the 

most severe drought conditions, and the most catastrophic accident conditions. (HNP-K-8)

Comment: Issue number 4, water impacts and water pathways to humans and other species. 

An environmental impact statement for an additional 20 years of operation beyond 2026, would 

have to be able to adequately predict, under uncertain climate change scenarios, all the water 

pollution aspects of all those activities just discussed above. (HNP-K-10) 

Response: While climate change is a legitimate concern, the specific impacts of climate change 

within a particular region or watershed are still highly speculative, and are, therefore, beyond the 

scope of a NEPA review for reactor license renewal. Furthermore, any changes in watershed 

characteristics would likely be gradual, allowing water-use conflicts to be resolved as needed. 

The comment does not provide new and significant information; therefore, it will not be 

evaluated further.

A.1.8 Human Health Issues

Comment: Tritium is currently released at the Harris lake, and thus into the Cape Fear river 

downstream, which is used as a drinking water source by a number of counties and 

municipalities. Harnett county is merely the first intake downstream. And water from that intake 
Appendix A 

August 2008 A-19 NUREG-1437, Supplement 33 

is currently sold to other water needy counties and municipalities. Tritium cannot be filtered out 

of water, and is incorporated into the body of humans and other animals. Analysis would have 

to include increased emissions of tritium, under aging and accident scenarios, and include 

higher concentration under drought conditions, and the concentration and consequent 

exposures during simultaneous catastrophic accident and severe drought conditions. 

(HNP-K-11)

Comment: Anyway, I want to talk about the safety issue. And I'm not talking about nuclear 

meltdowns, and we can forget about the adverse environmental factors, and we also can forget 

about the terrorist factor here. What I'm talking about is that if you have parents who live in this 

area, and you have children, your children are in danger of getting leukemia. There is a better 

chance they will get leukemia because there is a nuclear power plant here. And I have pulled 

evidence off the internet to show this here, and I will just point out that there is so much 

evidence on this here, and I'm only going to point out two things to you. First I'm going to tell 

you that Canada, France, Germany, and the Soviet Union, there were high incidence of 

leukemia in the proximity of nuclear power plant among children. And another example of 

evidence that I'm going to give you, is that SEER, that is surveillance and epidemiology and end 

result program, of the United States Center for Disease Control and Prevention, came out with 

figures that from 1975, to 2000, cancer rates in children, near nuclear power plants, went up 40 

percent. If you are a parent, but more important Mayor are you here? Do you have 

grandchildren? Are you concerned about your grandchildren? Okay, think about that, look it 

up. Those children are in danger, I'm telling you. Wake up. (HNP-Z-1)

Comment: All exposure analyses to humans would have to be able to predict demographic 

patterns 20-40 years into the future (currently predicted to be increasing sharply.) (HNP-WW-2)

Comment: (v) Additional operational exposures: An EIS would have to predict accurately the 

range of the additional future radiation exposures through all pathways from an additional 20 

years of plant operation forty years into the future to: 

(A) nuclear plant workers including contract workers 

(B) the public near the nuclear plant 

(C) uranium miners 

(D) the public near or downstream of uranium mining 

(E) fuel fabrication workers 

(F) the public near fuel fabrication facilities 

(G) spent fuel handling workers 

(H) the public along spent fuel transportation routes 
Appendix A 

NUREG-1437, Supplement 33 A-20 August 2008 

(I) low-level waste transport workers 

(J) the public along low-level transport routes 

(K) low-level waste incineration and compaction workers 

(L) the public near low-level waste incineration and compaction facilities 

(M) low-level waste disposal workers 

(N) the public near low-level waste disposal facilities 

(HNP-WW-3) 

Comment: (vi) Air, ingestion, direct and other pathways: An EIS for an additional 20 years of 

operation during the period 2026-2046 would also have to consider all other exposure pathways 

to humans. All pathways of radioactive emissions/releases/pollution through food animals and 

fish to humans would have to be analyzed. Progress Energy's annual or periodic environmental 

reports state that there are no food animals impacted by the Harris Plant, but in fact there are 

deer and ducks that can migrate from Harris Lake to adjacent game land and Jordan Lake and 

which are seasonally hunted for food. Harris Lake is open to fishing and fish caught in the lake 

are consumed as food. The EIS should also consider future conditions under various fuel 

constraint and economic downturn scenarios under which there is an increase in the utilization 

of these food sources. (HNP-WW-4)

Response: The comments are noted. The GEIS evaluated radiation exposures to the public for 

all plants including HNP, and concluded that the impact was small. During the plant-specific 

environmental review, the NRC search’s for new and significant information that causes the 

NRC to question this generic conclusion for HNP. The information provided by the comments 

will be reviewed as part of that search. If significant new information regarding the issue of 

radiation exposure is found during the conduct of the environmental review of HNP, the NRC 

staff will document any information and analysis in Chapter 4 of this SEIS. 

In addition, evaluation of new studies and analyses of the health effects of radiation exposure, 

such as BEIR VII, is an ongoing effort at the NRC. Any updates to the NRC’s exposure limits 

would be reflected in resulting rulemaking. 

A.1.9 Socioeconomic Issues

Comment: Shearon Harris is also a member of the local community. Its management 

communicates with, and advises, local and state officials, on matters related to its operation. It 

communicates with the public through its visitor centers, and outreach programs, and 

participates with local and state organizations, in safety related drills and exercises. (HNP-D-6)
Appendix A 

August 2008 A-21 NUREG-1437, Supplement 33 

Comment: Aside from benefiting from the plant's safe and productive operation, our community 

realizes a tremendous positive and economic impact from Progress Energy and the Harris plant 

by virtue of the tax revenues generated, salaries generated, and the company's strong 

philanthropic contributions to Cary and Wake County. (HNP-H-4)

Comment: We are a 37 year customer of Progress Energy, spending close to a million dollars 

per year for power to crush our products to state specifications. We count on them to always 

provide our stone crushing plants with a reliable power. A power outage in our business means 

equipment that locks up, full of thousands of tons of raw material. A lockup might take us a full 

day to unclog. When we do have a power problem they get right on it, helping us get back in 

business as quickly as possible. The Harris plant is an important part of Progress Energy plan 

to ensure reliable power at the lowest possible cost to us, and to other business customers. 

(HNP-O-1)

Comment: I would also like to add that I'm a former member of the Wake county Board of 

Education, serving from 1999 to 2003. And there is no better partner for public education than 

Progress Energy. School children's safety is always their top priority. And Wake County public 

schools confidently depend on their reliability record. (HNP-O-5)

Comment: I will leave the complete list with you, but I think you are getting a feel for what we 

are saying. These new companies, and the others that came in, represent 29,759 net new jobs 

for the citizens of Wake County. We must continue to grow our jobs, and investment, for us to 

continue having a dynamic economy. My staff and I were involved in every one of the projects I 

just mentioned. And I can tell you a key factor in their decision to come here was the availability 

of reasonably priced reliable energy. And it is extremely important to us that this license be 

renewed, because many of these companies, particularly Novardas [Novartis], the vaccine 

producer, it will take them five to six years even to get their facility up and operating. They are 

very concerned that there is a long term plan in place to continue having a good steady supply 

of electricity, and a very vibrant market. (HNP-R-2)

Comment: Now, we are also mindful of making an impact in our communities. In fact, there are 

two great examples. Our employees, and our customers, since 1982, have contributed more 

than 16 million dollars to our energy neighbor fund. Now, that fund was created by us to make 

sure those customers who can't afford to pay their bills, have that opportunity. And they can do 

so by applying for this Energy Neighbor Fund dollars. Furthermore, in 2006, Progress Energy 

contributed more than 12 million dollars to support our community, to enhance education, to 

protect the environment, to promote economic development. And, of course, we are supportive 

of our communities, because we have more than 10,000 employees, out and about in our 

communities. Now, we have a major tax impact on this community. I think someone mentioned 

it earlier. In Wake County the tax revenue is about 15.1 million dollars, of which 7.4 million is 

directly attributable to the Harris plant. (HNP-S-3)

Comment: We also need roads, which is another subject that we will talk about at a different 

time, for the traffic that all these people bring to our area. (HNP-T-4)
Appendix A 

NUREG-1437, Supplement 33 A-22 August 2008 

Comment: Whether we realize it or not, Progress Energy touches all of our lives. Not just when 

we flip on the light switch, or drive down the street at night, but they are a member of our 

community, and an excellent corporate citizen. If you are not aware, Progress Energy supports 

this community in many, many ways. And I know this because I do some volunteer work with 

my PTA, through my son's school, and through other educational programs and organizations. 

They are a generous supporter of public education, and they demonstrate a true, true 

commitment to the high quality that we experience here in Wake County. (HNP-V-1)

Comment: As I just mentioned, my report tonight summarizes an economic impact study. 

There are two ways in which one can interpret an economic impact study of this type. One way 

is to interpret it in a way that would let us view and answer the following question. Holding all 

other economic variables constant, what does the plant in question contribute to the local 

economy? Another way to interpret a study like this would be to see it as an answer to a slightly 

different, but related, question. Which is, if this plant had never been constructed, or if it were to 

be closed, or otherwise go missing, then how would that impact the local economy? (HNP-W-1)

Comment: The economic impact report that I'm summarizing contains at least five key 

economic indicators. These are: One, the value of economic output; two, employment; three, 

personal income, which is to say primarily wages and salaries; four, all other income; and five, 

tax revenues. As of calendar year 2005 Dr. Erickson estimates that the Shearon Harris plant 

generates the following economic impacts for these five categories. The plant generates 

roughly 700 million dollars in economic output. The plant supports more than 2,100 jobs in the 

Triangle region. The plant generates 86 million dollars in personal income, and nearly 40 million 

dollars in other income. And the report estimates that the plant generates roughly ten million 

dollars in indirect business taxes, which in North Carolina are largely sale taxes, and 20 million 

dollars in property taxes. In concluding this summary I offer one additional and final impact, 

which was estimated in the report. At current property tax rates, in the Triangle Region, the 

property value required to generate 20 million dollars in property taxes is approximately 

2.8 billion dollars, which is greater than one percent of the value of the assessed property in the 

Triangle, at the time of the study. (HNP-W-2)

Comment: WHEREAS, the Harris Plant provides approximately $10 million dollars in taxes to 

Wake County each year. (HNP-PP-6 through RR-5) 

Comment: The Harris Plant has been a part of the local community for two decades and has 

proved to be an outstanding corporate citizen, providing significant economic benefits to the 

surrounding community. Since 1987, the plant has been generating safe and efficient electricity 

to more than 550,000 homes and businesses. More than 600 people work at the Harris Plant 

and live in the surrounding communities in Wake, Chatham, Harnett and Lee counties. 

(HNP-VV-1)

Response: The comments are noted. Socioeconomic issues are Category 2 issues which are 

addressed in Chapter 2 and 4 of this SEIS.
Appendix A 

August 2008 A-23 NUREG-1437, Supplement 33 

A.1.10 Uranium Fuel Cycle and Waste Management Issues 

Comment: Let me start by saying that I'm not here saying I know everything, I know nothing. 

I'm just a mom, I'm a grandmother, I'm a wife. I'm very concerned about what we are going to 

do with the spent rods, before we do any renewal of license. I have been here for two years. 

Previous to that I lived in a small town called Bayville, New Jersey. We were right outside 

Oyster Creek. You guys renewed their license, I cried that day. If you could renew Oyster 

Creek license, you could renew your license. But anyone that opposes it, I feel for you, I truly 

do feel for you. And what I'm doing is I'm begging that you do look into disposing of these used 

rods. When we first started nuclear energy we never expected to keep them on the facilities, 

and we have. They don't want them out there in the desert, in Nevada. They are very, very 

dangerous in our backyards. (HNP-B-1)

Comment: The Progress Energy staff has demonstrated, over the past 20 plus years, that it is 

fully capable of safely operating the facility, and storing the spent assemblies in pools, and in 

dry casks. I am convinced that they are fully capable of also preparing the assemblies for 

shipment, when the repository, or an interim storage facility is available. (HNP-D-2)

Comment: The global nuclear power industry has now, according to my estimates, over 12,000 

reactor years of operation, or operational experience. The storage pools at Shearon Harris was 

originally built to store the assemblies, from the four reactors for which the site was originally 

designed. There is, of course, only one reactor in operation at the site, and the pool holds, of its 

own fuel, again according to my estimates, less than 25 percent of its capacity of 8,400 rods, or 

assemblies. And with its own fuel will only be approximately at 75 percent of capacity, at the 

end of the relicense period. (HNP-D-3)

Comment: Uranium supply, analysis of remaining global uranium supply does not support the 

feasibility of operating the Harris plant for an additional 20 years under current assumptions 

regarding fuel availability, or price. Uranium prices are projected, by industry analysts, to 

continue to rise with global scarcity, and increasing global demand for uranium, for both fuel 

fabrication and nuclear feed stock, until they reach 500 dollars a pound, and then conceivably 

people would just stop paying. The price advantage cited by Progress Energy and the nuclear 

industry, generally, over other alternatives, often relies on old uranium prices, such as when 

several years it was 8 dollars a pound, now it is 113 dollars a pound, and shows no sign of 

slowing down. It has risen 57 percent since the start of 2007. Uranium mining is dependent on 

a supply of water very nearby. The environmental impact statement would have to consider the 

effects of uranium mining using alternative water supply methods because, basically, that water 

supply future is not assured. (HNP-K-13)

Comment: The EIS would have to project the environmental effects of alternative methods of 

uranium mining, in the 2026-2046 period, and its effects on price of uranium mining/operational 

cost factors of HNP compared to alternative sources under futuristic pricing scenarios. 

(HNP-WW-6) 
Appendix A 

NUREG-1437, Supplement 33 A-24 August 2008 

Response: The comments are noted. All of the environmental impacts associated with the 

uranium fuel cycle are addressed in the GEIS. Chapter 6 of the GEIS concluded that all 

impacts including the offsite radiological impact of storage, transportation, water usage and 

disposal of spent fuel and other radioactive waste are Category 1 issues. The impact of all 

these Category 1 issues was judged to be small in the GEIS. During the plant-specific 

environmental review of HNP, the NRC will search for new and significant information that 

causes the NRC to question the generic conclusion for HNP. If significant new information is 

found, the NRC will perform a plant-specific analysis of these environmental impacts. These 

issues are addressed in Chapter 6.0 of this SEIS. 

In addition the issue of costs of uranium is not within the scope of the review of the 

environmental impacts of continued operation considered by the staff in this SEIS.

A.1.11 Comments Concerning Alternatives

Comment: An environmental scoping process is not a popularity contest. The environmental 

impact statement is supposed to analyze the effect of a no-action alternative, which would mean 

an NRC denial to extend the operating license beyond 2026 to 2046, or deciding not to do so at 

this time. It also has to consider alternative sources for power. We are talking about a very 

early extension of the license. The license doesn't expire for 20 years. We won't have the 

same staff, we won't have the same environmental conditions, we won't have the same 

population. (HNP-K-1)

Response: Chapter 8 of the HNP SEIS will contain the analysis related to alternatives to the 

proposed action. The National Environmental Policy Act (NEPA) requires the consideration of 

alternatives to the proposed action in an environmental impact statement (EIS). NEPA also 

requires the alternatives analysis in the EIS to include the alternative of no action. In the case 

of license renewal not renewing the operating license.

Comment: Seeking other sources, without the Shearon Harris plant, would undoubtedly direct 

the agency to other higher costs, fossil fuel generating plants, in the southeastern, part of the 

United States. That is, of course, assuming there is transmission capacity in order to get that 

power to our member cities. In addition to economic impact, consideration should be given to 

the negative impact of replacing clean nuclear power with fossil fuel power, that generates 

greenhouse gases, carbon monoxide, sulfur dioxide, mercury, and nitrogen oxide. Likewise, 

conservation measures would not be sufficient to offset the loss output from the Harris plant. 

(HNP-G-2) 

Comment: The alternative energy sources that Progress Energy has considered, in its report, 

are limited to those that are available now, in terms of electricity demand now, not in 2026. And 

on their claim that energy demand is simply going to increase for the foreseeable future. They 

only consider, in their report, power generation sources that they consider viable now, a new 
Appendix A 

August 2008 A-25 NUREG-1437, Supplement 33 

nuclear or new fossil fuel plant, or purchase power from such dirty sources, rather than what 

might be available, and viable, in 2026. (HNP-K-2)

Comment: Alternatives, any discussion of available alternative energy generation must be done 

for a period beginning 20 years into the future, and not based on currently available 

technologies or prices. Reasonable assumptions, which are not found in Progress Energy's 

report, include wind, solar, and current clean renewable alternatives will be cheaper than at 

present, and possibly have lower impacts than at present. Additional renewable energy options 

will be developed in the future, beyond what is considered in Progress Energy's report, or 

basically in any of our minds right now. Thirdly, coal fired power plants may not be an available 

or viable option in 2026, and natural gas supplies via pipeline may not be available either. If the 

environmental impact statement is still to include alternatives such as new nuclear, coal or 

natural gas generation, then their environmental impacts would have to be evaluated, 

thoroughly, for the period 2026 to 2046, for their entire fuel cycle, not just utility operation. From 

exploration and mining, through transportation, and up to disposal of wastes, it would also have 

to include all the resources committed and used, those would be impacted in the full range of 

water and air emissions, resulting in deep stage. (HNP-K-12)

Comment: The newspaper article stated that Shearon Harris supplies 12 percent of Progress 

Energy's capacity now. That is a small amount when I look at the study done for the North 

Carolina State Utility Commission, as directed by the State. The study states that we can get 

ten percent of our electric needs from solar and wind if we develop them. The associate, Mr. 

Jonathan Winter, also agreed with me that the new environmentally sound compact fluorescent 

light bulbs, now on the market, will reduce demand by at least 25 percent over the next few 

years. Progress, two years ago, reported capacity on hand to us through 2016, with no 

increase in capacity needed. Now you take these numbers, and they tell us that we really don't 

need Shearon Harris, or any other nuclear or coal plants at this time. By 2016 California's 

public gas and electric, which is one of the largest, if not the largest in the United States, is 

instituting a program, right now, to boost electric car power for the grid, on demand, and will be 

in operation within the next four or five years. They are planning on using something like the 

new Honda electric car that is due for sale to the public in 2009. You can read about this in this 

article here, in the newspaper, but you folks don't get this kind of newspaper, it is a weekly that 

goes out world-wide, it is called the Epic Times. That is why this is not the time to consider a 

license extension, as I said earlier. Progress should be spending time studying places like 

Wakeland, Florida's utility plant, where they have leasing solar hot water heaters to their rate 

payers. (HNP-II-1)

Comment: Progress Energy's Environmental Report (Draft EIS). The Environmental Impact 

Statement is supposed to analyze the effect of the "no action alternative" which means the NRC 

denying to extend the operating license for the period of 2026 to 2046, or deciding not to do so 

at this time. Progress energy has not provided any evidence or compelling argument that the 

operating license needs to be renewed, or more accurately, extended, now, 20 years in 

advance of when that action might be needed. 
Appendix A 

NUREG-1437, Supplement 33 A-26 August 2008 

Progress Energy has rounded up a number of resolutions in favor of license extension from 

local chambers of commerce, and their glossy brochure might lead you to think that this action 

is needed now to allow the plant to operate for the next twenty years. However, the company 

makes it clear in their 476 page "Environmental Report" that, in the unlikely event of the NRC 

not renewing the operating license, the plant could still operate until 2026. 

In addition that brochure uses an old technique illustrated in that old but still relevant book "How 

to Lie with Statistics" in comparing nuclear energy to other sources. Leaving aside for the 

moment the misleading nature of only considering the fuel component, the figure used to 

illustrate these costs adds in two misleading features. One is the reference to a processed 

uranium pellet rather than the many pounds of raw uranium ore, but the other is that as the 

height of the little picture grows, so does the width. So you might take away the idea that other 

sources of large centralized power are seven times as costly, rather than merely slightly higher, 

were these figures actually total costs, which they are not. 

Worse, Progress Energy claims in the material that they are not handing out, but burying within 

hundreds of pages in the Apex Library, that since the impacts of decommissioning the plant in 

2026 would be the same as decommissioning it in 2046 there is no difference, conveniently 

leaving out the significant and varied additional public health and environmental impacts of 

20 years of additional uranium mining, plant releases, and 20 years more worth of high and lowlevel radioactive waste. 

The alternative energy sources that Progress considers are limited to those that "meet system 

needs" based on electricity demand now, not in 2026-2046, saying that energy demand is going 

to increase "for the forseeable [sic] future." They only consider power generation sources that 

they consider viable now, a new nuclear or fossil fuel plant, or purchased power from such 

sources, rather than what might be available and viable in 2026. 

Progress Energy describes "incentive programs that encourage customers to replace old, 

inefficient appliances or equipment with new high-efficiency appliances or equipment" as if it 

were a current program, but there is no such program in the company's NC service area, and 

there has never been one. If there's one just started in Florida, that's outside this analysis. 

Progress Energy actually projects DECREASING impacts of conservation, in spite of national 

trends favoring more efficiency. And those trends are used as an argument that there's nothing 

left to do: "...The adoption of increasingly stringent national appliance standards for most major 

energy-using equipment and the adoption of energy efficiency requirements in state building 

codes. These mandates have further reduced the potential for cost-effective utility-sponsored 

measures."

What is this supposed to mean? That governments and states have done so much there's 

nothing left for a poor utility to do in this area? On the contrary, what remains is the gigantic gap 

between the brand new appliances and systems and actually getting them into customer's 

homes, thus reducing their demand, or getting the customers into more energy efficient homes, 

or upgrading their homes to these new codes. 
Appendix A 

August 2008 A-27 NUREG-1437, Supplement 33 

The past, present or future creation of new codes for building and/or appliances create 

increasing gaps between current use and future use of electricity. Without some incentive to 

increase the rate of adoption these standards and requirements don't have a large immediate 

impact on overall demand. However, they may well have a significant impact by 2026-2046 

which is the period this report is supposed to cover. (HNP-WW-1)

Comment: Conservation: Conservation options should consider what might be feasible 20 

years from now, and not based on what is available today, under various adoption rate 

scenarios, including with incentives, and what could be developed in future. (HNP-WW-5) 

Comment: I have been doing my best to get in touch with you. But I do believe that some 

companys [sic] have done their best to hide me from you. Right down to N.C. News & 

Observer, I have written them (N&O) 5 straight times trying to get them to put me in touch with 

the right people. I have invented a power source that is inexpensive and 95% safe to the 

consumer & the world. It is a fully self sustaining electrical power/generator, this invention will 

power anything & everything electrical that we have created thus far. But I believe for the sake 

of the companys [sic] losing out on millions of dollars they have made up their minds to try and 

hide this discovery from you & the rest of the world. So I have been fighting against all odds to 

get national attention to what I have named I AM COIL. This engine/generator will change the 

way we suppy [sic] power to our homes, offices & business. Because instead of wires running 

for miles & miles, we will be able to place one small I Am Coil (3 feet wide x 4 feet high x 7 feet 

long) on the building or home lot of land in which it sits on. And I need not tell you how great a 

benefit that will be in storms, floods & summer. This is a great invention and it should be put 

into full production starting now. If you truely [sic] do care about our safety & making the world a 

great place to live for our kids, then I will see you at this prison no later than 3 days after you 

have received this letter. Then I will take you through the whole system of the I Am Coil, and 

explain to you how it works from top to bottom. And when I finish you will know for yourself that 

it truely [sic] works and works good, forget about me being in prison & look at what I have 

invented, that is the most important subject here. I stay off to myself & I don't let to [sic] many 

people know what I have created in here, because it is a multi billion dollar invention. And like 

my Grandfather use to say talk is cheap, action is more, so come & see this invention for 

yourself. I will be waiting for you to show up. (HNP-XX-1)

Response: The comment is noted. Impacts from reasonable alternatives for the Shearon 

Harris Nuclear Power Plant, Unit 1, will be evaluated in Chapter 8 of the SEIS.

A.1.12 Environmental Justice Issues

Comment: We learned that African-Americans, and other minorities, pay a disproportionate 

share of their income for energy, and these groups to be more acutely affected by air emissions 

from our transportation and energy sectors. We also learned that our communities tend to live 

in older housing stock, which isn't energy efficient, and usually has older, less efficient 

appliances, and heating and cooling systems. With these observations, as a back drop, we 
Appendix A 

NUREG-1437, Supplement 33 A-28 August 2008 

have determined that our constituents, and our communities, would be greatly served from 

measures that would ensure low cost, clean and reliable energy sources. (HNP-P-1)

Response: In order to perform a review of environmental justice in the vicinity of a nuclear 

power plant, the NRC staff examines the geographic distribution of minority and low-income 

populations within 80 kilometers (50 miles) of the site. The NRC staff uses the most recent 

census data available. The NRC staff also supplements its analysis by field inquiries to such 

groups as county planning departments, social service agencies, agricultural extension 

personnel, and private social service agencies. Once the locations of minority and low-income 

populations are identified, the staff evaluates whether any of the environmental impacts of the 

proposed action could affect these populations in a disproportionately high and adverse 

manner.

The comments relate to environmental justice issues and will be considered in the preparation 

of the SEIS. The NRC conducts an independent analysis of the impacts of license renewal with 

regard to environmental justice; potential impacts which are discussed in Chapter 4 of this SEIS.

A.1.13 Global Warming Issues

Comment: ...its operation is not contributing to the tropospheric loading of green house gases. 

(HNP-D-5)

Comment: Third issue, greenhouse gas emissions from the entire fuel cycle, from an additional 

20 years of operation. Progress Energy, in its report said if we decommission the plant in 2026, 

or if we decommission the plant in 2046, oh what is the difference? Well, the difference is, 

among other things, significant quantities of various greenhouse gases are released during the 

entire fuel cycle, uranium fuel cycle, some of which are many times more damaging than carbon 

dioxide, such as those emitted during fuel fabrication. The plant specific environmental impact 

statement should consider all the greenhouse gas emissions, not just carbon dioxide, 

associated with extended operation for 20 years, beyond 2026, such as uranium mining, fuel 

fabrication, fuel transport, repair, replacement, manufacture and transport, to maintain the 

reactor, spent fuel transport, low level radioactive waste transport, low level radioactive waste 

incineration, and so on. (HNP-K-9)

Comment: The Harris plant is essential to meeting the needs of our customers and we meet 

those needs with zero greenhouse gas emissions. With very real concerns about global 

warming it is good for our customers and good for the environment to take steps now to ensure 

that the Harris plant continues to be that clean air energy source well into the future. Renewing 

the plant's license will allow us to do exactly that. A recent Bisconti research national survey 

determined that 85 percent of the public believe that the U.S. should take advantage of all low 

carbon energy opportunities in the future, including nuclear power. (HNP-M-1)

Comment: In addition, it is my belief that there is less environmental pollution from nuclear 

generation than a coal fired, or natural gas fired electricity generation source. There are no air 
Appendix A 

August 2008 A-29 NUREG-1437, Supplement 33 

pollutants being emitted. In an age where global warming appears a real issue, certainly 

nuclear power is the correct means of electricity generation for the future. (HNP-BB-2) 

Comment: WHEREAS, nuclear energy produces no greenhouse gas emissions that contribute 

to global climate change; (HNP-KK-3)

Comment: WHEREAS, nuclear energy produces no greenhouse gas emissions that contribute 

to global climate change; (HNP-LL-3 through OO-3; SS-3 through UU-3) 

Comment: WHEREAS, nuclear energy produces no greenhouse gas emissions that can lead to 

ozone formation or acid rain; (HNP-PP-3; QQ-3)

Comment: WHEREAS, nuclear energy produces no greenhouse gas emissions; (HNP-RR-3)

Response: While climate change is a legitimate concern, the specific impacts of climate change 

within a particular region is still highly speculative, and is, therefore, beyond the scope of a 

NEPA review for reactor license renewal. The comments do not provide new and significant 

information; therefore, they will not be evaluated further.

A.1.14 Issues Outside the Scope of License Renewal 

Operational Safety, Security, & Emergency Preparedness 

Comment: Since the initial licensing efforts, for the plant, Wake County and, at the time, CP&L, 

and subsequently Progress Energy, have had a continuing relationship. And that relationship 

includes financial planning, and work support, in development and maintenance of our 

emergency response plans, and other preparedness activities. And, as a result of that 

continuing collaborative effort, when we've ted our emergency response activities, it has been 

determined that we meet NRC and FEMA standards for emergency response external to the 

plant. In Wake County we actually conduct annual tests of that plan. In alternating years we 

either test the activation of the EOC only, or we activate the EOC and the field activities 

response for exercise purposes. And what I wanted to establish, for the record, was that current 

relationship with Progress Energy, in emergency planning and testing, and managing the 

emergency plan for Shearon Harris. (HNP-A-1)

Comment: I have had a chance to visit the plant and interface with Bob Duncan, and his 

management team. I have seen, first-hand, the security measures in place, and the dedication, 

and the commitment, of the entire Progress Energy team. (HNP-E-1)

Comment: This is a very safe plant, it has proven that it has stood the test of time, and it meets 

a very, very important part of our community and region's needs. (HNP-E-5)

Comment: Progress Energy has a proven 35 year track record of operating nuclear plants 

safely and securely. (HNP-H-2)
Appendix A 

NUREG-1437, Supplement 33 A-30 August 2008 

Comment: I'm here today representing 650 employees who work at the Harris plant, many of 

who are in the audience today to show their support. These are highly skilled, extensively 

trained professionals, who are dedicated and committed to their work. Understandably these 

employees, including me, are held to very high expectations. We are responsible for safely 

operating a nuclear reactor, and that is a huge responsibility. We come to work every day with 

our first priority not simply to generate electricity, but to make sure that we are generating 

electricity in a sustainable way, that ensures the health and safety of the public, and the 

environment. It is my responsibility to ensure that safety for our employees, and for our public. 

Safety has, and always will be, a top priority for the Harris plant. (HNP-M-3)

Comment: We do need to be environmentally responsible to concerns about global warming, 

and we need to be safe. One of our plants is about ten miles from the Harris plant. We are very 

pleased with Progress Energy's outstanding safety record, and are very confident in their ability 

to keep our employees safe. (HNP-O-3)

Comment: I have toured the plant at least four to five times, the total plant, inside, out, the 

whole nine yards. And I, personally, am very pleased and comfortable with their safety 

precautions. I would also encourage any elected officials who might be here, or others, to do 

the same thing that I have done, take a look at the plant, go through the whole thing, you will be 

impressed. (HNP-T-2)

Comment: The Harris plant has been operating for 18 years and, over that time, has 

consistently been ranked, by its peers, as among the top nuclear plants in the country, in terms 

of safety, production, and cost. Progress Energy has a 35 year track record of operating 

nuclear plants safely, and securely. The Harris plant continuously updates equipment, and 

undergoes constant oversight and scrutiny by the Nuclear Regulatory Commission. (HNP-EE-3)

Comment: In the past three years I have had the opportunity to become involved with the local 

section of the American Nuclear Society. In the numerous society functions and meetings I 

have attended, I have interacted extensively with personnel from Progress Energy, both from 

the corporate offices, and the Harris plant. Without exception I have found these professional 

men and women to be of the highest caliber, possessing a good questioning attitude, and 

ensuring understanding of the technical concepts presented at section meetings. Their strong 

commitment to their profession, and to excellence and safety in nuclear plant operations, is 

evident. (HNP-FF-4)

Comment: As Ms. Alexander spoke to, I can also attest to being a part of seeing, first-hand the 

conservative decisionmaking that is used in our nuclear safety programs to ensure the highest 

degree of safety to employees, the plant, and the public. My husband and I, after having 

different assignments in other states, moved back to North Carolina, and chose to locate in 

Apex, North Carolina. I currently volunteer in the emergency department in a local hospital. 

And when nuclear power is brought up I have the opportunity to talk with residents, and I tell 

them, and I'm genuine in saying this, if there were a natural disaster, the first place I would want 

to be would be inside the containment building at the Shearon Harris nuclear power plant. 

(HNP-JJ-2)
Appendix A 

August 2008 A-31 NUREG-1437, Supplement 33 

Comment: WHEREAS, the Harris Plant has been consistently ranked by its peers among the 

top nuclear plants in the country in terms of safety, production and cost; and WHEREAS, 

Progress Energy has a 35-year track record of operating nuclear plants safely and securely, and 

the plant features multiple backup systems to ensure safety; and WHEREAS, the Harris Plant is 

closely monitored by on-site inspectors from the Nuclear Regulatory Commission; and 

WHEREAS, the 650 professionals who work at the plant and live in the community are 

committed to the safety and security of the site; (HNP-KK-2 through OO-2; RR-2 through UU-2) 

Comment: WHEREAS, the Harris Plant has been consistently ranked by its peers as among 

the top nuclear plants in the country in terms of safety, production, and cost; and WHEREAS, 

Progress Energy has a 35-year track record of operating nuclear plants safely and securely; 

(HNP-PP-2; QQ-2) 

Comment: WHEREAS, the 650 professionals who work at the plant and live in the community 

are committed to the safety and security of the site; (HNP-PP-5; QQ-5) 

Response: The comments are noted. Operational safety, security, and emergency 

preparedness is outside the scope of this review. An NRC safety review for the license renewal 

period is conducted separately. Although a topic may not be within the scope of review for 

license renewal, the NRC is always concerned with protecting health and safety. Any matter 

potentially affecting safety can be addressed under processes currently available for an existing 

operating license absent a license renewal application. 

Emergency preparedness is an ongoing process at all plants, including HNP. Each nuclear 

plant must have an approved emergency plan, as required by 10 CFR Part 50, that is revised 

periodically and required to be updated. Licensees are required to frequently test the 

effectiveness of the plans by conducting emergency response exercises. Emergency planning 

is part of the current operating license and is outside the scope of the environmental analysis for 

license renewal. The comments did not provide any new and significant information and do not 

fall within the scope of license renewal as set forth in 10 CFR Parts 51 and 54; therefore, the 

comments will not be evaluated further.

Security

Comment: I have been around for over 80 years. And as far as the Nuclear Regulatory 

Commission, I have been around from the get-go. And I supervised security offices back in the 

'70s. And all the blab, and all the blurb from Progress Energy, I can sum up in one little 

statement from every security officer I supervised in five different atomic energy plants, in the 

northeast. Anything happens here, bud, I'm the first one out the gate. And this is all security 

officers I'm referring to, who I supervised. You have no real security if a major accident occurs. 

And we have just been going along hoping that they spot a fire, like they did back in '93, before 

it becomes a major conflagration. (HNP-C-4)
Appendix A 

NUREG-1437, Supplement 33 A-32 August 2008 

Response: The issue of security at nuclear power plants is not unique to facilities that have 

requested a renewal to their license. As part of its oversight process the NRC constantly 

ensures that licensees meet appropriate security levels. 

Security is not within the scope of license renewal as set forth in 10 CFR Parts 51 and 54. The 

comments; therefore, will not be evaluated further. 

Aging Management 

Comment: Now, there are several reasons not to extend the license of Shearon Harris nuclear 

plant. The most important is that Shearon Harris has been stalling, for 15 years, and now asks 

for another ten years to correct the wiring of firewalls. This is material installed, originally, by the 

builders of Shearon Harris and approved by you, the NRC. Shearon Harris is spending 500,000 

dollars a year on a fire watch system, again, approved by the NRC, hoping to prevent a major 

fire. (HNP-C-1)

Comment: The next reason not to extend the license is that it was built to last 40 years, only, 

and it is wearing out, much as a car that was built to last 100,000 miles, and has run over 

550,000 miles. There are parts of the plant that cannot be measured for durability, and us life, 

just as an old car engine and drive train can only be estimated. When a piece of equipment is 

designed for 40 years of use, there are hidden weaknesses to consider. It ages. Let's wait ten 

more years before we consider a license renewal. (HNP-C-2)

Comment: In terms of plant aging issues and those affects on the public health and the 

environment, aging of plant systems is the only area, other than environmental issues, that the 

NRC is supposed to consider in relicensing a plant or not. But this is the one area that is very 

impossible to predict so far in advance. During the first 20 to 30 years of U.S. power reactor 

operation numerous systems and components have turned out to age and deteriorate more 

rapidly than expected, and to be missed by routine inspections. It seems extremely likely that 

additional generic aging issues will emerge in the next 5, 10, and 20 years if U.S. power 

reactors continue to operate. It simply is not credible that either Progress Energy, or the NRC, 

can predict additional aging effects 40 years into the future. Two dangerous examples of such 

unforeseen issues that have emerged in recent years are reactor head corrosion, and the 

pressurized water reactor problem with butt welds. These appear to be -- there are likely to be 

many more as reactors age. A responsible regulator would not tie its hands so far in advance, 

but would retain the authority to shut down nuclear reactors that can no longer be operated 

safely. (HNP-K-3)

Comment: WHEREAS, the Harris Plant is continually updating equipment and undergoes 

constant oversight and scrutiny by the Nuclear Regulatory Commission; (HNP-PP-4; QQ-4) 

Response: The comments are noted. The NRC’s environmental review is confined to 

environmental matters relevant to the extended period of operation requested by the applicant. 

Safety matters related to aging are outside the scope of this environmental review. An NRC 

safety review for the license renewal period is conducted separately. The comments provide no 
Appendix A 

August 2008 A-33 NUREG-1437, Supplement 33 

new information and will not be evaluated further in the context of the environmental review. 

However, the comments were forwarded to the project manager for the license renewal safety 

review for consideration.

Need for Power 

Comment: Shearon Harris is contributing to the provision of the base load of electricity that we, 

the consumers, are demanding. It is contributing to our national goal of energy independence 

(HNP-D-4)

Comment: I have lived in Fuquay for over 30 years, and continue to count on Progress Energy 

to provide the electricity needed for our community, and the region, and recognize that the 

Shearon Harris plant has been a part of providing infrastructure, and meeting the tremendous 

growth that has taken place in our area. I'm satisfied, in fact, that we could not have had this 

type of growth if we hadn't had the type of energy needed for this region. And the Harris plant 

has met those demands. (HNP-E-3)

Comment: The agency [North Carolina Eastern Municipal Power Agency], the power agency, 

owns 16.17 percent of the Harris nuclear plant. The Harris nuclear plant provides safe and 

reliable power to more than 250,000 power agency customers. The Harris plant is important to 

Progress Energy to ensure reliable power to both and all of its customers. The plant does not 

depend on imported fuel and is environmentally responsive to concerns of global warming. 

(HNP-F-1)

Comment: And, lastly, the agency [North Carolina Eastern Municipal Power Agency] owns 

16.17 percent of the Shearon Harris nuclear generating plant, located in southwest Wake 

County, in North Carolina. And that is the subject of this operating license renewal hearing 

today. The rated capacity of this plant is 900 megawatts. The agency's share of the Shearon 

Harris plant's output is 146 megawatts. This represents about 10 percent of the capacity that is 

owned by the agency's generating capacity, and 12 percent of the energy requirements. The 

Harris plant has provided safe, secure, economical power to the agency, its members, and 

customers, for almost 20 years. Should the NRC not grant an operating license renewal for the 

Harris plant, beginning in 2027, the agency, including the town of Clayton, would have to 

purchase power from other sources to meet the requirements of its customers. (HNP-G-1)

Comment: The Harris plant supplies power to more than 550,000 businesses and residences, 

or about 12 percent of the total electricity generated by PE Carolinas. Continued operation of 

the Harris plant will result in no greenhouse gas emissions, and reduce dependence upon 

unstable foreign energy supplies. (HNP-H-3)

Comment: Over the past 12 months our area has received many high rankings and accolades; 

number one place for business, and careers, by Forbes, number eight fastest growing metro in 

the nation by the U.S. Census Bureau; number one best U.S. city for job, Forbes; top 50 hottest 

cities for expanding and relocating companies; top ten tech town; Wake County number one 

school district, and the Wake County's schools gold rating from Expansion Management 
Appendix A 

NUREG-1437, Supplement 33 A-34 August 2008 

magazine. What those ratings suggest is that dynamic growth that has taken place in this 

market is likely to continue. And that kind of growth requires energy to meet new demand. The 

Shearon Harris plant currently supplies more than a half million residences and businesses, and 

provides 12 percent of the total energy generated by Progress Energy of the Carolinas. And the 

plant generates more than 7.9 million megawatt hours of electricity, and approximately ten 

million dollars in taxes to Wake County, annually. (HNP-J-1)

Comment: I'm also a customer of Progress Energy. I count on them to provide me, and the 

members I represent, with reliable power. The Harris plant is an important part of Progress 

Energy's plan to ensure reliable power at the least expensive cost to me, and other customers. 

(HNP-L-2)

Comment: I'm also currently the finance chair of the Board of Directors of Wake Med Health 

and hospitals. The hospital system cannot operate without safe dependable power. Progress 

Energy has an unwavering commitment to all of Wake Med's hospitals and patients, that Wake 

County citizens depend on, every minute of every day. (HNP-O-6)

Comment: I have the opportunity to serve 16 counties in central and northern North Carolina for 

Progress Energy. And I also have this opportunity to ensure that our commercial, our industrial, 

and our residential customers receive the power to their homes, and their businesses. We must 

make sure that reliable, 24/7 flow of power, is there to meet their needs each and every day. 

And, especially, for those hospitals, the fire and police departments, and for our industrial 

customers, often who can't even tolerate a flick within their power flow. So continuous power is 

needed. The Harris plant is an important, no it is essential, it is an essential part to a balanced 

solution, to meeting all of our customers needs. So we are applying to renew the Harris plant's 

operating license because we have responsibility to serve our customers, to ensure they have 

power today, and for tomorrow. (HNP-S-1)

Comment: And, in summary, due to the rapid growth in our area, in particular Holly Springs, we 

are moving in 2.7 families every day. We need Shearon Harris and we need the electricity. 

(HNP-T-3)

Comment: As the fourth fastest growing state in America, and the tenth largest state in the 

country, business needs reliable, affordable, and clean energy, to compete, to create jobs, and 

drive the continued economic growth of our state. There are many reasons that make our state 

the envy of most in the country. Maintaining and improving our competitive position, as a state, 

is the primary mission of the North Carolina Chamber. And the competition to grow jobs, and 

expand, costs matter. Energy drives North Carolina business, it drives our economy, and 

creates opportunities for all of us. (HNP-X-2)

Comment: We have experienced quality sustainable growth that is the envy of many other 

communities. The local investment by companies, that are moving here, and the jobs that they 

are creating for our growing population, have done much to enhance the quality of life that all of 

us appreciate and enjoy. Key to that past growth, and to its sustainability, as we move forward, 

has been, and will continue to be, an adequate supply of quality power. The ability to meet our 
Appendix A 

August 2008 A-35 NUREG-1437, Supplement 33 

electrical demands is critical. If we cannot say, with certainty, that an adequate supply of 

electrical power is available, we will no longer be able to attract these investments, and new 

jobs to our area. (HNP-AA-1)

Comment: Without reading the entire resolution we support the license extension based on 

renewing the Harris plant's license will ensure Progress Energy can continue to meet the 

growing Triangle area's need for electricity in a safe, efficient, and affordable manner. The 

Harris plant provides electricity to more than 55,000 residents, and businesses, in the Triangle. 

(HNP-EE-2)

Comment: WHEREAS, renewing the Harris Plant's operating license will help ensure that 

Progress Energy can continue to provide the electricity needed for the growing Triangle region; 

and WHEREAS, the Harris Plant supplies power to more than 550,000 residencies and 

businesses, and provides 12 percent of the total electricity generated by PE Carolinas; and 

WHEREAS, in 2005, the Harris Plant generated more than 7.9 million megawatt-hours of 

electricity, the largest volume in its 18 years of operation; (HNP-KK-1 through OO-1; RR-1 

through UU-1) 

Comment: WHEREAS, nuclear power helps the United States reduce dependence on unstable 

foreign energy supplies; (HNP-KK-4 through OO-4; RR-4 through UU-4) 

Comment: WHEREAS, renewing the Harris Plant's operating license will ensure that Progress 

Energy can continue to provide the electricity needed for the growing Triangle region; and 

WHEREAS, the Harris Plant supplies power to more than 550,000 residences and businesses, 

and provides 12 percent of the total electricity generated by PE Carolinas; and WHEREAS, In 

2005, the Harris Plant generated more than 7.9 million megawatt-hours of electricity, the largest 

volume in its 18 years of operation; (HNP-PP-1; QQ-1) 

Comment: Renewing the Harris Plant's operating license will ensure that Progress Energy can 

continue to provide the electricity needed to fuel the growing Triangle region far into the future. 

As an organization that is committed to improving the quality of life of residents in the Triangle, 

the Urban League recognizes that renewing the license at the Harris Plant is also a key part of 

Progress Energy's balanced solution to meeting the growing energy needs of our region.

(HNP-VV-2)

Response: The need for power is considered to be outside the scope of license renewal 

(10 CFR 51.95 (c)(2)). The purpose and need for the proposed action (renewal of an operating 

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

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

needs may be determined by State, utility, and where authorized, Federal (other than NRC) 

decision makers. The comments are outside the scope of the license renewal review; therefore, 

will not be evaluated further. 

Cost of Power
Appendix A 

NUREG-1437, Supplement 33 A-36 August 2008 

Comment: We also have an obligation to produce power in a cost effective way. The Harris 

plant helps Progress Energy do that. We consistently rank high in the industry in this category. 

And in 2002 and 2005 the Harris plant was the lowest cost energy provided, in dollars per 

megawatt generated, of any nuclear plant in the country. (HNP-M-4)

Comment: Nuclear power helps Progress Energy protects customers from price volatility, 

ensures a reliable supply of energy. We do not need to depend on imported fuels. (HNP-O-2)

Comment: With the current volatility in the fossil fuels market, we believe that the stable cost of 

nuclear power has had a positive effect on our local rates with respect to fuel adjustment. Our 

members and constituents want continued access to low cost energy, as we see it as necessary 

to having a growing economy, and the quality of life which we have grown accustomed to. 

(HNP-P-2)

Comment: The nuclear power generated at Harris is the lowest cost option, and it produces no 

greenhouse gases that contribute to global climate change. (HNP-S-2)

Comment: My company is being asked to compete in a large international market and 

environment. The game has changed rapidly in the last few years. The cost of electricity is one 

of the few areas we have an advantage over foreign competition. Electricity is cheaper, and 

more dependable, in the United States than in overseas locations. We certainly want to retain 

that cost advantage. Our plants are in rural North Carolina, all manufacturing jobs are 

meaningful in those areas. For an electrical utility nuclear power is the lowest cost source of 

generating electricity on a large scale. I wish Progress Energy had more nuclear generated 

electricity. Without the cost of nuclear generated electricity averaged into the overall cost of all 

electricity generated by Progress Energy, the cost would force some industrial manufacturing 

companies to shut their doors, or relocate to areas with competitive electricity costs. 

(HNP-BB-1)

Response: The comments are noted. The economic costs and benefits of renewing an 

operating license are specifically directed to be outside the scope of license renewal in 

10 CFR 51.95(c)(2). The comments provide no new and significant information and, therefore, 

will not be evaluated further. 

Part II – Comments Received on the Draft SEIS

Pursuant to 10 CFR Part 51, the staff transmitted the Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants Regarding Shearon Harris Nuclear Power Plant, Unit 1, 

Draft Report for Comment (NUREG-1437, Supplement 33, referred to as the draft Supplemental 

Environmental Impact Statement [SEIS]) to Federal, State, and local government agencies; 

certain Indian tribes; and interested members of the public. As part of the process to solicit 

public comments on the draft SEIS, the staff: 
Appendix A 

August 2008 A-37 NUREG-1437, Supplement 33 

• placed a copy of the draft SEIS into the NRC’s Public Electronic Reading Room, on its 

license renewal website, at the West Regional Library in Cary, North Carolina, and at the 

Eva H. Perry Library in Apex, North Carolina; 

• sent copies of the draft SEIS to the applicant, members of the public who requested 

copies, representatives of certain Indian tribes, and certain Federal, State, and local 

agencies;

• published a notice of availability of the draft SEIS in the Federal Register on 

December 19, 2007 (72 FR 71973); 

• issued public announcements, such as advertisements in local newspapers and postings 

in public places, of the availability of the draft SEIS; 

• announced and held two public meetings in Apex, North Carolina, on January 30, 2008, 

to describe the results of the environmental review and answer related questions; 

• issued public service announcements and press releases announcing the issuance of 

the draft SEIS, the public meetings, and instructions on how to comment on the draft 

SEIS; and 

• established an email address to receive comments on the draft SEIS through the 

Internet.

During the comment period, the staff received a total of thirteen comment letters and emails in 

addition to the comments received during the public meetings. 

The staff has reviewed the public meeting transcripts and the comment letters that are part of 

the docket file for the application, all of which are available in the NRC’s Public Document 

Room. Appendix A, Part II, Section A.2 contains a summary of the comments and the staff’s 

responses. Related issues are grouped together. The public meeting transcripts and comment 

letters have been incorporated by reference and are available online in ADAMS. 

Each comment identified by the staff was assigned a specific alpha-numeric identifier (marker). 

A cross-reference of the alpha-numeric identifiers, the speaker or author of the comment, the 

page where the comment can be found, and the section(s) of this report in which the comment 

is addressed is provided in Table A-2. Public testimony and written comments are identified by 

a specific letter representing the commenter, followed by a number that identifies each comment 

in approximate chronological order in which the comments were made. 

The staff made a determination on each comment that it was one of the following: 

• A comment that was actually a question and introduces no new information. 
Appendix A 

NUREG-1437, Supplement 33 A-38 August 2008 

• A comment that was either related to support or opposition of license renewal in general 

(or specifically, Shearon Harris Nuclear Power Plant, Unit 1) or that makes a general 

statement about the licensing renewal process. It may make only a general statement 

regarding Category 1 and/or Category 2 issues. In addition, it provides no new 

information and does not pertain to 10 CFR Part 54. 

• A comment about a Category 1 issue that provided new information that required 

evaluation during the review, or provided no new information. 

• A comment about a Category 2 issue that provided information that required evaluation 

during the review, or provided no such information. 

• A comment regarding Alternatives to the proposed action. 

• A comment that raised an environmental issue that was not addressed in the GEIS or 

the draft SEIS. 

• A comment outside the scope of license renewal (not related to 10 CFR Parts 51 or 54), 

which includes comments regarding the Need for Power. 

• A comment on Safety issues pertaining to 10 CFR Part 54. 

• A comment that was editorial in nature. 

There was no significant new information provided on Category 1 issues or information that 

required further evaluation on Category 2 issues. Therefore, the conclusions in the GEIS and 

draft SEIS remained valid and bounding, and no further evaluation was performed. 

Comments without a supporting technical basis or without any new information are discussed in 

this appendix, and not in other sections of this report. Relevant references that address the 

issues within the regulatory authority of the NRC are provided where appropriate. Many of 

these references can be obtained from the NRC Public Document Room. 

Within each section of Part II of this appendix (A.2.1 through A.2.17), similar comments are 

grouped together for ease of reference, and a summary description of the comments is given, 

followed by the staff’s response. Where the comment or question resulted in a change in the 

text of the draft report, the corresponding response refers the reader to the appropriate section 

of this report where the change was made. Revisions to the text in the draft report are 

designated by vertical lines beside the text. 
Appendix A 

August 2008 A-39 NUREG-1437, Supplement 33 

Table A-2. Comments Received on the Draft SEIS 

Comment ID Commenter

Comment Source and 

ADAMS Accession Number 

Section Where 

Addressed 

A-1 Runkle Afternoon Transcript, ML080500331 2.1

A-2 Runkle Afternoon Transcript, ML080500331 2.15

A-3 Runkle Afternoon Transcript, ML080500331 2.15

A-4 Runkle Afternoon Transcript, ML080500331 2.2

A-5 Runkle Afternoon Transcript, ML080500331 2.15

A-6 Runkle Afternoon Transcript, ML080500331 2.8

A-7 Runkle Afternoon Transcript, ML080500331 2.13

A-8 Runkle Afternoon Transcript, ML080500331 2.4

A-9 Runkle Afternoon Transcript, ML080500331 2.2

A-10 Runkle Afternoon Transcript, ML080500331 2.12

A-11 Runkle Afternoon Transcript, ML080500331 2.8

A-12 Runkle Afternoon Transcript, ML080500331 2.2

B-1 Wilberg Email Letter, ML080640201 2.3

C-1 Kocher Email Letter, ML080640200 2.3

D-1 Tiffany Email Letter, ML080640202 2.11

E-1 Williams Letter, ML080370395 2.2

E-2 Williams Letter, ML080370395 2.8

E-3 Williams Letter, ML080370395 2.12

E-4 Williams Letter, ML080370395 2.12

E-5 Williams Letter, ML080640203 2.2

E-6 Williams Letter, ML080640203 2.8

F-1 Chatham Co. Letter, ML080720335 2.2

F-2 Chatham Co. Letter, ML080720335 2.11

F-3 Chatham Co. Letter, ML080720335 2.15

F-4 Chatham Co. Letter, ML080720335 2.10
Appendix A 

NUREG-1437, Supplement 33 A-40 August 2008 

Comment ID Commenter

Comment Source and 

ADAMS Accession Number 

Section Where 

Addressed 

F-5 Chatham Co. Letter, ML080720335 2.5

G-1 Mueller Letter, ML080720334 2.11

G-2 Mueller Letter, ML080720334 2.6

G-3 Mueller Letter, ML080720334 2.5

H-1 Goudreau Letter, ML080840431 2.14

H-2 Goudreau Letter, ML080840431 2.5

H-3 Goudreau Letter, ML080840431 2.7

H-4 Goudreau Letter, ML080840431 2.6

I-1 Stallings Letter, ML080840431 2.9

J-1 LeGrand Letter, ML080840431 2.1

K-1 McRight Letter, ML080840431 2.5

L-1 Cullington Letter, ML080950186 2.12

L-2 Cullington Letter, ML080950186 2.12

L-3 Cullington Letter, ML080950186 2.14

L-4 Cullington Letter, ML080950186 2.8

L-5 Cullington Letter, ML080950186 2.14

L-6 Cullington Letter, ML080950186 2.5

L-7 Cullington Letter, ML080950186 2.5

L-8 Cullington Letter, ML080950186 2.8

L-9 Cullington Letter, ML080950186 2.12

L-10 Cullington Letter, ML080950186 2.12

L-11 Cullington Letter, ML080950186 2.12

L-12 Cullington Letter, ML080950186 2.12

L-13 Cullington Letter, ML080950186 2.10

L-14 Cullington Letter, ML080950186 2.12

L-15 Cullington Letter, ML080950186 2.12

L-16 Cullington Letter, ML080950186 2.12
Appendix A 

August 2008 A-41 NUREG-1437, Supplement 33 

Comment ID Commenter

Comment Source and 

ADAMS Accession Number 

Section Where 

Addressed 

L-17 Cullington Letter, ML080950186 2.14

L-18 Cullington Letter, ML080950186 2.8

L-19 Cullington Letter, ML080950186 2.5

L-20 Cullington Letter, ML080950186 2.12

M Gledhill-Earley Letter, ML080840431 --

N Hogue Letter, ML060130040 --

O-1 Progress

Energy

Email Letter, ML08090104 2.14

O-2 Progress

Energy

Email Letter, ML08090104 2.14

O-3 Progress

Energy

Email Letter, ML08090104 2.14

O-4 Progress

Energy

Email Letter, ML08090104 2.14

O-5 Progress

Energy

Email Letter, ML08090104 2.14

O-6 Progress

Energy

Email Letter, ML08090104 2.14

O-7 Progress

Energy

Email Letter, ML08090104 2.14

O-8 Progress

Energy

Email Letter, ML08090104 2.14

O-9 Progress

Energy

Email Letter, ML08090104 2.14

A.2 Comments and Responses 

Comments in this section are grouped in the following categories: 

A.2.1 General Comments Concerning License Renewal and Its Processes 

A.2.2 General Comments in Opposition to License Renewal at Shearon Harris Nuclear 

Power Plant, Unit 1 

A.2.3 General Comments in Support of License Renewal at Shearon Harris Nuclear Power 

Plant, Unit 1 

A.2.4 Comments Concerning Land Use 
Appendix A 

NUREG-1437, Supplement 33 A-42 August 2008 

A.2.5 Comments Concerning Water Use and Quality 

A.2.6 Comments Concerning Aquatic Resources 

A.2.7 Comments Concerning Terrestrial Resources 

A.2.8 Comments Concerning Radiological Impacts 

A.2.9 Comments Concerning Related Federal Project Activities and Consultations 

A.2.10 Comments Concerning Environmental Justice 

A.2.11 Comments Concerning Uranium Fuel Cycle and Waste Management 

A.2.12 Comments Concerning Alternatives 

A.2.13 Comments Concerning Global Warming 

A.2.14 Editorial and General Comments 

A.2.15 Comments Concerning Issues Outside the Scope of License Renewal: Operational 

Safety, Emergency Preparedness, Security 

A.2.1 General Comments Concerning License Renewal and Its Processes 

Comment: I appreciate the opportunity to speak here and give some comments on the draft 

EIS. I was kind of surprised how poorly advertised this meeting was, and that I'm not surprised 

that there aren't a lot of people here that actually have read the draft environmental impact 

statement and offer comments on it. It seems to be something that people have understood this 

process, and understood the limitations of it, and it is a done deal, and there is really no 

question about it. (A-1)

Response: The NRC staff published the Draft EIS for Shearon Harris on December 11, 2007; 

that same day a copy of the Draft EIS as well as a letter notifying of the issuance of the 

document and the opportunity for comment and details about the public meeting were sent to 

everyone listed in the HNP license renewal distribution list. The HNP license renewal 

distribution list includes anyone who requests to be included as well as anyone who participated 

during the scoping process. 

On December 26, 2007, the NRC issued a press release, which was covered by several local 

North Carolina news media on December 26, 2007, and December 27, 2007. The press 

release had information regarding the public meeting date, time, and location, and a contact 

number for additional information. 

On January 14, 2008, the NRC issued a meeting notice which was posted on the NRC public 

website announcing the meeting; additionally the meeting date had been posted in the NRC 

public website for several months. Lastly, the NRC arranged for several advertisements 

announcing the meeting to be posted in local NC newspapers during the week before the 

meeting and during the week of the meeting. 
Appendix A 

August 2008 A-43 NUREG-1437, Supplement 33 

Comment: The Natural Heritage Program is unable to review this project for failure to obtain a 

suitable map or maps of the project area. No maps are provided with the Project Review, and a 

perusal of the website listed on the Project Review Form does not provide easy access to maps 

or other pertinent material for our agency's review. For example, we are aware of a proposal by 

Progress Energy Carolinas, Inc., to raise the water level of Harris Lake, which would impact 

several significant natural areas identified by our Program. It is not clear after some review of 

documents on the website whether this license renewal involves the raising of the water level of 

Harris Lake. Without such information made available to us, we are unable to comment on the 

project at the present time. (J-1) 

Response: During the scoping process, the Natural Heritage program provided maps to the 

NRC staff showing locations and names of rare plant species within the vicinity of the Shearon 

Harris site (see Appendix E pp. E-21). The License Renewal action under consideration by the 

NRC does not involve raising the level of the Harris Reservoir. There is a separate action 

involving the construction of New Nuclear units which might require raising the level of the 

Harris reservoir, and a separate NEPA document will be prepared by the NRC to address all 

significant issues associated with the construction and operation of new nuclear units. 

A.2.2 General Comments in Opposition to License Renewal at Shearon Harris Nuclear 

Power Plant, Unit 1 

Comment: Looking at the draft environmental impact statement, there are really two fatal flaws 

to it. One is that it is complete with these fairly bald assertions that there is not going to be any 

problem, or not be any impacts. 

But there is no supporting documentation for a lot of those statements. There are a couple of 

references back to the environmental assessment that Progress Energy put in, but there is very 

little things to back out the statement that, you know, that there is not going to be an impact on 

different kinds of environmental thing. (A-4) 

Comment: So the two fatal flaws are, you know, these sort of bald assertions without the 

supporting documentation, and not taking a realistic look at the area around the plant, from the 

2026 to 2046. 

This is specially galling, because when we raised issues on the safety side of these 

proceedings, we could only look at differences in the plant from 2026 to 2046. Yet in the 

environmental impact statement that is, that is glossed over.

And to say that, I mean, the basic assumption is that there won't be any change in land use, and 

population, and water use in this plant, water use in this area from the time period. (A-9) 
Appendix A 

NUREG-1437, Supplement 33 A-44 August 2008 

Comment: So, in conclusion, there are fatal flaws in the draft environmental impact statement 

that the NRC should not be able to base any kind of decision whether to grant this license 

extension or not, based on what this is worth. 

This is -- I don't even think it is a fair start. So there is a lot of work to be done, and I see that 

there is a deadline for some time that you are going to issue a final environmental impact 

statement.

The studies that need to be done, to get a realistic look, I don't think you all can finish in that 

time. And if you issue something just because you have a deadline, that it is still flawed and is 

still insufficient, that is even less of a reason why to rely on it. (A-12) 

Response: The commenter makes a broad statement about the draft environmental impact 

statement relying on “bald assertions” not backed by “supporting documentation.” Changes in 

Land Use, Population and Water Use associated with the continued operation of the Shearon 

Harris Nuclear Power Plant are covered in Chapter 2 and Chapter 4. Section 2.2.8 specifically 

provides a projection of population growth during the period of extended operation, and what 

socioeconomic impacts would result from the continued operation of Shearon Harris. 

Additionally Land Use and Water Use issues deal with the environmental impacts which could 

be associated with relicensing the facility; these issues are covered in Chapter 2 and Chapter 4. 

The commenter fails to provide any substantive data or information that could call into question 

the preliminary conclusions or analysis made in the draft environmental impact statement. 

As part of the environmental review process, the NRC evaluates site-specific data provided by 

the applicant, other Federal agencies, State agencies, tribal and local governments, as well as 

information from members of the public. In addition, the NRC performs independent reviews of 

the plant-specific environmental impacts of license renewal in accordance with the National 

Environmental Policy Act (NEPA) and the NRC's requirements in 10 CFR Part 51 and following 

the guidance set forth in NUREG -1555 Supplement 1. The comments provide no additional 

information; therefore, there were no changes made to the supplement.

Comment: It is a waste of valuable time, to keep argueing [sic] about, who is at fault, when it 

comes down, to the electric companys [sic], because it can’t, just be, pend [sic] on one 

company. Every single power company, is doing its part, to add to “global warming”, and while 

you (NRC) are trying to figure out, whether to give certain companys [sic], another license to 

operate. The problem of hazardous emissions, into our atmosphere, is growing at a steady 

pace, while we are focusing, our attention on unnecessary things at this point and time. 

Our focus, should not be side track, by an electric companys [sic], applying for another license, 

when its first license, haven’t even expired. The electric companys [sic] legal team, has found a 

loop hole, in getting you (NRC) to move on, to another subject. (E-1) 
Appendix A 

August 2008 A-45 NUREG-1437, Supplement 33 

Comment: These are my feelings towards the lisensce [sic] renewal of the Shearon Harris 

Nuclear Power Plant Unit 1. Frist [sic], their frist [sic] license hasn’t even come close to 

expirating [sic], so what is the true purpose of getting this second license renewed now. Well let 

me tell you (NRC) companys [sic] have study the rules and regulations that you (NRC) have set 

forth. These same companys [sic] don’t want to have you tell them whey they can produce 

energy and when they can’t. So if I, was a big time power company, who is making Billions of 

dollars a year, then by all means I am going to ensure that I keep making that amount or more 

“Every Year” regardless of who it hurts or kills. (E-5) 

Comment: The timing of this request for an extension of the operating license is inappropriate. 

Major changes in the condition of the plant and its safety systems, availability of sufficient water 

to operate the plant safely, the size and vulnerability of the human population surrounding the 

plant, and the presence of Federally- and State-listed threatened and endangered species near 

the plant and in transmission line rights-of-ways, could occur before the expiration of the current 

license in 2026. During the next 18 years the area sewed by the Harris Plant could implement 

substantial energy conservation measures, bringing the area more in line with energy use 

patterns in other industrialized nations. For example, if light sources for new construction and 

replacement bulbs were compact florescent lights (CLF), two-thirds of the energy requirement 

currently needed from regular florescent bulbs would be eliminated, resulting in a 67% energy 

savings. Furthermore, renewable power generation technologies could be developed. The 

license extension should not be considered until at least 2018, by which time the future need for 

the Harris Plant and its potential impact on environmental health could be more realistically 

evaluated. At that time further changes in these parameters during the renewal period, 2026-

2046, could be more adequately projected and assessed. (F-1) 

Response: According to the regulations a nuclear power plant licensee may apply to the NRC 

to renew a license as early as 20 years before expiration of the current license. The NRC staff 

has determined that 20 years of operating experience is sufficient to assess aging and 

environmental issues at the site. A major consideration for seeking license renewal so far in 

advance of the expiration date of the current license is that it takes about 10 years to design and 

construct major new generating facilities and long lead times are required by energy-planning 

decision-makers. License renewal applicants are expected to apply at least 5 years before their 

license expires. Typically it takes 22 to 30 months for the NRC to determine whether or not to 

grant the renewed license. 

Additionally, Section 8.2.5 addresses the environmental impacts associated with the energy 

Conservation alternative and also provides an analysis of the viability for implementation of 

energy conservation measures in the State of North Carolina. No changes to the supplement 

were made in response to these comments.
Appendix A 

NUREG-1437, Supplement 33 A-46 August 2008 

A.2.3 General Comments in Support of License Renewal at Shearon Harris Nuclear 

Power Plant, Unit 1 

Comment: Memories of the former Torry Canyon and Exxon Valdez oil supertankers cannot 

fade from my mind. And they should not. They were some of the greatest ecological and 

economic diasters [sic] of mankind. Millions of fish, birds, and mammals died in the black ooz 

spilled from these vessels. More recent oil spills have happened off the coast of South Korea. 

If mankind depends upon oil for energy this tragically will not stop. Oil must be replaced by 

alternative energy sources. Yes so far our automobiles and other ground transport still depend 

upon this source but our power generating stations do not! 

From internet information I understand that the USA has about 104 nuclear power plants with 

the Shearon Harris plant being one. Our future depends upon reliable energy without being 

held hostage by those nations such as in the far east for this essential oil. 

How many of our young generation will die and spill their blood on a foreign land in this 

relentless quest for oil? Wars are being fought for this resource and America is going into debt 

that will never be paid off to do this? Are our future generations (assuming there may be a 

future) going to be doomed due to our reluctance to use nuclear technology? Who knows? The 

jury is still out. 

For one electricity consumer served by the Harris nuke plant I would without reservation say to 

renew the license for the additional 20 years. 

Our life as a people and a nation depend upon energy that is cheap, plentiful, and obtainable, 

The risks compared to wars being fought for oil and past oil spill disasters are just plain not 

worth it. Yes in my opinion not worth it..... (B-1) 

Comment: I urge the commission to renew the license for Shearon Harris. This has been an 

excellent facility with an outstanding safety record. I'm anxious for the additional reactor to be 

built. This is the safest, cleanest source of electrical power and our nation should proceed 

quickly with more facilities that will aid in reducing, in part, our dependence on foreign oil. (C-1) 

Response: The comments are noted. The comments are supportive of license renewal at 

Shearon Harris Nuclear Power Plant, Unit 1, and are general in nature. The comments provide 

no additional information; therefore, there were no changes made to the supplement.

A.2.4 Comments Concerning Land Use 

Comment: And the changes with the increasing population will have a complete change in land 

use. And this is not addressed. To be able to say that to look at impacts, cumulative impacts 

and say, well we don't expect that there would be any difference in plant operation, but knowing 

that surrounding the plant will be considerably more people that we are using the land different, 
Appendix A 

August 2008 A-47 NUREG-1437, Supplement 33 

and more aged population, a lot more traffic potentially, a whole lot of different kinds of things. 

So that is, I think, a fatal flaw. (A-8) 

Response: The purpose of the environmental impact statement is to look at the environmental 

impacts associated with relicensing the facility and the impacts of plant operation for an 

additional 20 years. Environmental impacts that could occur in the vicinity of the plant 

associated with other actions not related to license renewal over the 20 year period of extended 

operation are not considered in the environmental impact statement. 

Land use, transportation and socioeconomic issues are discussed in Chapters 4 and 8 of the 

SEIS. The comment provides no additional information; therefore, there were no changes made 

to the supplement. 

A.2.5. Comments Concerning Water Use and Quality 

Comment: Finally, with regards to environmental impacts of operation, many of the issues 

considered applicable to all plants should be subject to more site-specific review. In Chatham 

County, we are especially concerned with the impacts of transmission lines on water quality, 

and aquatic and terrestrial resources, all of which require site-specific analysis. (F-5) 

Response: Transmission line right of way maintenance impacts on water quality and aquatic 

and terrestrial species are Category 1 issues. On these issues the Commission determined in 

the GEIS that the impact on wildlife is expected to be small. During its site specific review the 

NRC staff did not identified any new and significant information which could call into question 

the conclusions reached on the GEIS. The comment provides no additional information; 

therefore, there were no changes made to the supplement. 

Comment: Potential impacts resulting from water withdrawals during drought conditions are 

also a concern, and should be addressed in the Final Generic Supplemental Environmental 

Impact Statement (FGSEIS). We note that the North Carolina Drought Management Advisory 

Council currently lists Wake County and surrounding counties as D4 Exceptional Drought areas. 

(G-3)

Comment: The EIS scoping process included comments regarding the severe impacts of 

drought periods on Harris Lake and cooling water supply to the plant, owing to the relatively 

small watershed for the Lake. This included documentation of current impacts, and the need to 

actively pump water from the lower reservoir up to the higher reservoir during dry months. NRC 

was reminded to project environmental impacts into the 2026-2046 period and to include the 

range of potential impacts with increased global warming and weather variation, temperature 

and rainfall. 

The NRC's response to this significant issue is to state that localized impacts of global warming 

are speculative and don't have to be dealt with. The EIS needs to be amended to include a 
Appendix A 

NUREG-1437, Supplement 33 A-48 August 2008 

range of possible impacts that include more severe droughts and more significant rainfall 

events. There are enough variations in current and historical data for this to be within the 

reasonable scope of the EIS. 

What is the construction method for the Harris Lake dams (upper and lower)? What would be 

the impact of a stalled hurricane event like Hurricane Floyd and/or the effect on the dams of 24-

36" of rain in 24 hours? (L-6) 

Comment: The EIS finds that shutting down the Harris plant in 2026 would have a beneficial 

effect on water resources. Without water being withdrawn from Harris Lake and some of that 

water evaporated by the cooling tower, the NRC says that flow might be better maintained in 

Buckhorn Creek downstream of the dam, which is currently dry during several months of year.

(Section 8.2.5, p.8-66) 

Yet this is not reflected in the overall analysis. Firstly (as discussed above), favorable impacts 

are not identified as distinct from negative ones. Secondly, in spite of comments made during 

the scoping process, the NRC has failed to include the magnification of this beneficial effect 

during the 2026-2046 period when a changing climate or natural variations should be 

considered to include more severe droughts. In some years this could be at least a "moderate" 

or even large impact for downstream water users. (L-7) 

Comment: The EIS states in Section 9.1 (Page 9-4) that no new environmental issues were 

identified, however, comments during the scoping period identified an extremely significant 

environmental issue, the inadequacy of the plants cooling water supply/upper reservoir/ which 

sometimes has to be maintained by pumping from the lower reservoir. This was not reflected in 

the environmental assessment provided by the licensee (Progress Energy) nor in this EIS. If 

this is already happening now this cannot be dismissed as some future global warming problem 

that can't be quantified yet. (L-19) 

Response: Section 2.2.2 has been modified to reflect additional information with respect to 

drought conditions in the State of North Carolina. While the staff recognizes that there have 

been temporary drought conditions in counties surrounding the HNP site and downstream 

counties located in the Cape Fear River Basin, the continued operation of HNP does not have a 

significant impact on surface water use. These findings fall within the conclusions reached for 

water use issues on the GEIS. 

The staff discusses environmental impacts of severe accidents such as hurricane events in 

Chapter 5 of the SEIS, and has determined that such impacts are SMALL based on a Category 

1 finding in the GEIS. To the extent that the comments address construction of the Harris Lake 

dams and their performance during severe accident events, those are operational safety issues 

outside the scope of an environmental review, and would be addressed under the purview of the 

NRC’s regulatory oversight process, as appropriately. 
Appendix A 

August 2008 A-49 NUREG-1437, Supplement 33 

Comment: The gross and net (consumptive) amount of water used by Unit 1 is not clear. 

Section 2.1.3 states that "900 L/min (240 gpm) of water in the cooling loop are lost due to 

evaporation from the cooling tower. An additional 15 million L/day (4 million gal/day) (about 

10,600 L/min [2800 gpm]) are lost to blowdown." Using these numbers we calculate that the 

total consumptive loss of water is 6.7 cfs (blowdown loss of 4 mgd = 6.2 cfs; cooling loss of 280 

gpm = 0.5 cfs). However, Section 2.2.2.1 of the DSEIS states that "During normal operation of 

1-NP, an average 54.5 million L/day (14.4 million gal/day [MGD]) of water are lost through 

evaporation and an additional 15 million L/day (4 MGD) are lost to blowdown (Progress Energy 

2006b)." These values result in an estimated consumptive loss is of 28.4 cfs (1.8.4 MGD). 

There is a vast discrepancy in the estimates for the cooling water portion. Please reconcile the 

differences between these two Sections and clearly state the gross amount of water used by 

Unit 1 and the net amount of water lost to Harris Reservoir and the Buckhorn Creek system via 

evaporation and other means. (H-2)

Response: Text in Section 2.1.3 has been modified to reflect the correct amount for water 

usage [54.5 million L/day (14.4 million gal/day)] this correction is editorial, the correct value was 

used in Section 2.2.2.1, this revision not affect the conclusions reached in the Supplement.

Comment: If renewal of license requires any modifications to the water supply system, PWS 

(Public Water Supply) approval is required. (K-1) 

Response: There are no water supply system modifications needed for the continued operation 

of the Shearon Harris facility during the period of extended operation.

A.2.6 Comments Concerning Aquatic Resources 

Comment: Based on EPA’s review of the DGSEIS, the project received an “EC-1” rating, 

meaning that environmental concerns exist. Specifically, protecting the environment involves 

the continuing need for appropriate storage and ultimate disposition of radioactive wastes 

generated on-site, as well as continuing measures to limit bioentrainment and other impacts to 

aquatic species from surface water withdrawals and discharges, and compliance with the 

NPDES Permit. (G-2) 

Response: Safe storage of spent fuel is achieved through the use of the Shearon Harris spent 

fuel pool, which meets all the necessary requirements imposed by the NRC. Onsite storage of 

spent nuclear fuel is a Category 1 issue. The safety and environmental effects of long-term 

storage of spent fuel onsite have been evaluated by the NRC, and, as set forth in the Waste 

Confidence Rule at 10 CFR 51.23 (available at http://www.nrc.gov/reading-rm/doccollections/cfr/part051/part051-0023.html), 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 licensed life for 

operation (which may include the term of a revised or renewed license) of that reactor at 
Appendix A 

NUREG-1437, Supplement 33 A-50 August 2008 

its spent fuel storage basin or at either onsite or offsite independent spent fuel storage 

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 twentyfirst 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 high-level 

waste and spent fuel originating in any such reactor and generated up to that time.” 

The comments provide no new and significant information; therefore, no changes were made to 

the SEIS in response to these comments.

Comment: Conditions for salamanders could be improved by protecting seeps and vernal 

pools, and restoring or maintaining their natural hydrology. Active management (either fire or 

mechanical removal) should be considered to reduce tree cover in and immediately adjacent to 

vernal pools. (H-4) 

Response: Section 2.2.6 of this SEIS outlines best management practices employed by 

Progress Energy under the guidance of the North Carolina Division of Forest Resources, for the 

responsible management of forested areas, riparian zones, buffer strips and wetlands.

A.2.7 Comments Concerning Terrestrial Resources 

Comment: We recommend that transmission line right-of-way maintenance be adjusted to 

improve wildlife habitat. They should not be mowed all at once during the same year. Rotate 

mowed zones on individual right of ways (some are miles long) and "feather" the edges. 

Mowing should be done in late fall as much as possible and should be avoided between April 

and July. (H-3) 

Response: Section 2.2.6 of this SEIS outlines best management practices employed by 

Progress Energy under the guidance of the North Carolina Division of Forest Resources, for the 

responsible management of forested areas, riparian zones, buffer strips and wetland. 

A.2.8 Comments Concerning Radiological Impacts 

Comment: The design person, as I understand it, is still a fairly young, healthy adult male, 

instead of an elderly person, or even a young person, or somebody that has chronic illnesses. 

So to be able to make the assertion, without any kind of documentation, of these changing 

circumstances, that are going to happen in this area from 2026 to 2046, I think is a fatal flaw. 

(A-6)

Comment: Lastly I always look at these kinds of things to look for tritium. Tritium is a major, I 

think, radioactive pollutant that comes out of a nuclear power plant, part of the source term. 
Appendix A 

August 2008 A-51 NUREG-1437, Supplement 33 

But it certainly is -- that cycle needs to be, I think, specifically looked at, and analyzed, at the 

nuclear power plant; how much tritium is getting into the Harris Lake, into the groundwater, into 

the atmosphere, and what are those impacts on the environment, including the human 

environment. 

And, again, that goes back to if we are looking at the time period from 2026 to 2046, we have to 

look at the potential increase in the number of people, in the area, and what will be the effect of 

tritium.

I'm just using that for an example, but looking through this to follow-up, you know, any kind of 

these pathways of radioactivity to people. (A-11) 

Comment: By applying for another operator license, for an additional 20 years it makes you 

think about down the road, but we are dying from cancer now. Don’t you see (NRC), by the 

electric companys [sic] applying, for all of these new licenses, they can keep you (NRC) so busy 

with technical details of rules and regulations for filing, for another operator license, until no one 

will even have enough time to focus on the here and now, and what we can do about our 

problem at this present moment. Companys [sic] that make billions of dollars a year will also 

pay billions of dollars out, to get people to help them, keep doing what they are doing. (E-2) 

Comment: So your quick decision about granting license to Companys [sic] that are killing 

people by the thousand, really need to be thought all over again. Because guess that “You” 

(NRC) are one of those thousands that are posined [sic] every year, just like me. The only 

difference is you may have a little bit more money to keep yourself alive longer than me and the 

rest of the public. What good does it do you to live longer and suffer having parts of your body 

“cut off” to try and stop the spread of cancer. (E-6) 

Response: As part of the NRC’s radiological evaluation process for license renewal, we 

reviewed several years of radiological data contained in the Harris nuclear power plant’s annual 

radiological effluent (which includes tritium) and environmental monitoring reports and 

performed an on-site audit of the facility. We found that the information in those reports and the 

information obtained during the site audit met NRC radiation protection requirements for 

protection of the public and plant workers. The applicant’s radiological effluent and 

environmental reports are publicly available in ADAMS. The ADAMS Public Electronic Reading 

Room is accessible at http://adamswebsearch.nrc.gov/dologin.htm. 

The NRC's primary mission is to protect the public health and safety from the effects of radiation 

from nuclear reactors, materials, and waste facilities by conducting its licensing functions in a 

manner which is receptive to environmental concerns. The NRC's regulatory limits for 

radiological protection are set to protect workers and the public from the harmful health effects 

of radiation on humans. The limits are based on the recommendations of standards-setting 

organizations. Radiation standards reflect extensive scientific study by national and 

international organizations and incorporate conservative assumptions and models to account for 
Appendix A 

NUREG-1437, Supplement 33 A-52 August 2008 

differences in gender and age so as to ensure that workers and all members of the public are 

adequately protected from radiation. 

The amount of radioactive material released from nuclear power facilities is well measured, well 

monitored, and known to be very small. The doses of radiation that are received by members of 

the public as a result of exposure to nuclear power facilities are very low (i.e., less than a few 

millirem). To put this in perspective, each person in this country receives a total annual dose of 

about 360 millirems from natural sources of radiation. Radiation from natural and man-made 

sources is not different in its properties or effect. 

To ensure that the nuclear power plants are operated safely within radiation protection 

requirements, the NRC licenses the plants to operate, licenses the plant operators, and 

establishes license conditions for the safe operation of each plant. The NRC provides 

continuous oversight of plants through its Reactor Oversight Process to verify that they are 

being operated in accordance with NRC rules and regulations. The NRC has full authority to 

take whatever action is necessary to protect public health and safety and may demand 

immediate licensee actions, up to and including a plant shutdown. 

The NRC regulations requirements for license renewal are designed to ensure safe plant 

operation for extended plant life (codified in 10 CFR Part 54). An applicant must provide the 

NRC with an evaluation that addresses the technical aspects of plant aging and describes the 

ways those effects will be managed. The applicant must also prepare an evaluation of the 

potential impact on the environment if the plant operates for up to an additional 20 years. 

During the review of the application for license renewal the NRC staff verifies the safety 

evaluations through inspections and reviews environmental issues associated with license 

renewal.

The NRC's primary mission to protect the public health and safety continues to be met. The 

comments provided no additional information; therefore, there were no changes made to the 

supplement. 

Comment: In addition this EIS has failed to quantify additional radiation doses from another 

20 years of operation, so these cannot be offset as specific negative impacts that would be 

incurred by license renewal or avoided by all other alternatives (except coal alternatives). (L-4) 

Comment: In addition, there is no mention at all in Section 8.0 of the "large" potential negative 

or positive impact to downstream water users if the Harris plant license is renewed or not 

renewed in terms of tritiated water used as a drinking water source downstream of the Harris 

plant.

Tritium cannot be filtered out of water by any known means. Increased withdrawal demand and 

decreased supply in the downstream watershed during droughts like the summer of 2007 mean 

that tritium levels would be elevated. (L-8) 
Appendix A 

August 2008 A-53 NUREG-1437, Supplement 33 

Comment: In addition, the EIS fails to quantify increased radiation doses from 50% more 

operational years and so this greater impact is not reflected in the summary (chart or text). 

(L-18)

Response: All nuclear plants were licensed with the expectation that they would release 

radioisotopes to both the air and water during normal operation. Tritium is one of the 

radionuclides routinely released to the atmosphere from nuclear power plants, including 

Shearon Harris. Releases of radionuclides from nuclear power plants must meet radiation 

dose-based limits specified in 40 CFR Part 190, 10 CFR Part 20, and 10 CFR Part 50, 

Appendix I. The regulations specify that the dose to individual members of the public from all 

exposure pathways, including both internal and external exposure, due to nuclear fuel cycle 

facilities be less than 25 mrem to the whole body, 75 mrem to the thyroid, and 25 mrem to any 

other organ (40 CFR Part 190 and 10 CFR Part 20 Section 1301). In 10 CFR Part 50, dose 

design objectives are specified for both air and liquid effluents consistent with the requirements 

of 40 CFR Part 190 and 10 CFR Part 20. Licensees are required to report liquid, gaseous, and 

solid effluent releases annually to the NRC. As part of the preparation of the draft SEIS, the 

NRC staff visited the site and reviewed the effluent releases reported in the HNP Annual 

Radioactive Effluent Release Reports for the years 2002 through 2006. Average gaseous 

emissions from HNP are discussed in Section 2.1.4.2 of the SEIS. The releases and radiation 

doses to members of the public from all airborne radioactive emissions from HNP are within the 

regulatory limits specified above and are expected to continue to meet the regulatory criteria 

during the extended period of operation. The comments provide no new and significant 

information; therefore, no changes were made to the SEIS in response to these comments.

A.2.9 Comments Concerning Related Federal Project Activities and Consultations 

Comment: The Submittal of an application to build two new nuclear units at the HNP site is 

mentioned at several locations. It should be noted that the Division's response to this Generic 

Environmental Impact Statement for license renewal is provided with the understanding that a 

detailed Environmental Impact Statement for building the two new nuclear units will be required 

and will be addressed in a separate, independent NEPA document. (I-1) 

Response: The North Carolina Division of Water Quality understanding is correct. The specific 

impacts of building one or more new nuclear units at the HNP site will depend on the actual 

design, characteristics, and construction practices that could be proposed by the applicant. The 

detailed environmental impacts of building two new nuclear units at the HNP site would be 

analyzed and addressed in a separate NEPA document that would be prepared by the NRC 

staff and which would be circulated to the appropriate North Carolina state agencies for review 

and comment.
Appendix A 

NUREG-1437, Supplement 33 A-54 August 2008 

A.2.10 Comments Concerning Environmental Justice 

Comment: Environmental justice analyses in this report use an inappropriate criterion of 50% 

people of color or Hispanic people to evaluate impact. Environmental injustice can occur when 

these populations are below 50% but still disproportionately located near a hazardous site. The 

Supplement does not cite the substantial literature on assessments of environmental injustice in 

North Carolina based on continuous measures of population characteristics rather than an 

arbitrary 50% value. (F-4) 

Response: The Commission’s Policy Statement on the Treatment of Environmental Justice 

Matters in NRC Regulatory and Licensing Actions, outlines the process in which minority 

populations are identified for the purposes of the environmental review (69 FR 52040). 

A 50 mile radius was used to identify environmental justice populations meeting the low-income 

or minority criteria. A minority or low-income community is identified by comparing the 

percentage of the minority or low-income population in the impacted area to the percentage of 

the minority or low-income population in the county and the state. If the percentage in the 

impacted area significantly exceeds that of the state or the county percentage for either the 

minority or low-income population then environmental justice will be considered in greater detail. 

‘‘Significantly’’ is defined by staff guidance to be 20 percentage points. Alternatively, if either the 

minority or low-income population percentage in the impacted area exceeds 50 percent, 

environmental justice matters are considered in greater detail. 

For HNP the staff used the criterion which was more conservative. In this specific case using 

the criteria of minority population exceeding 50% was more conservative because the minority 

population in the county is 34%, and applying the other method for identifying minority 

populations would yield 54%. 

The comments provide no new and significant information; therefore, no changes were made to 

the SEIS in response to these comments. 

Comment: In addition, the "environmental justice" impacts of the conservation alternative are 

listed as SMALL (positive) whereas they could be argued to be MODERATE to LARGE in terms 

of economic impact. The EIS text notes in this section that low-income and minority groups as 

an average spend a larger portion of income on utility bills, and these financial constraints can 

affect a wide range of health issues, housed versus homeless, food availability and quality, 

access to medical care and prescriptions, and -- with rising oil/gasoline prices -- ability to get to 

jobs.

The high cost of utilities in cheaper rental housing in the Harris Plant/Progress Energy service 

area also means that the effect of conservation measures on all housing (not just a few new 

Energy Star homes) would decrease many deaths from fire experienced in the area every year 

caused by improvised heating measures. (L-13) 
Appendix A 

August 2008 A-55 NUREG-1437, Supplement 33 

Response: Comment is noted. The socioeconomic data used by the staff to reach its 

conclusion is available in Chapter 2 of this SEIS and support a qualitative finding of SMALL. A 

further quantitative analysis to support a different severity (positive) would not further 

benefit/change the SEIS conclusions. No changes were made to the SEIS in response to this 

comment.

A.2.11 Comments Concerning Uranium Fuel Cycle and Waste Management 

Comment: Licensing should be contingent on FAIL-SAFE Dry Cask Containment of RadWaste.

Fuel rods are designed to produce temperatures above the boiling point of water, so putting 

them in water is inherently hazardous, and requires human & automated monitoring for as long 

they are stored in water.

At Shearon-Harris, the hazardous waste storage is more hazardous that anywhere else in the 

country due to the ever-more high-mass/high-density, high-temperature storage in water of 

high-level hazardous rad-waste generating temperatures above the boiling point of water, 

necessitating complex automated systems dependent on impossible perfection for decades, 

with the obvious potential for human error and moving-parts failure (both as natural as the 

boiling point of water). 

On the other hand, well-designed, well-made, properly implemented Dry-Cask storage, is 

inherently less dangerous because there is no water to boil, and the argon atmosphere within 

the sealed containers is inert and does not require monitoring, and maintenance, and constant 

replenishment (in a drought-prone area that may shut down the plant, diverting attention and 

extra available staff from fuel-pool emergencies). 

There is far better containment, no moving parts to fail, and no water to boil away, and no 

inherent necessity for constant, error-free automated and human-error-prone monitoring and 

intervention, with well-designed, well-made, properly implemented dry-cask containment, a 

method which is inherently FAIL-SAFE, rather than the storage of high-volume, high-mass, 

high-density, high-temperature hazardous rad-waste (above the boiling point of water), which is 

inherently NOT fail-safe. 

Licensing should be contingent on moving hazardous rad-waste to well-designed, well-made, 

properly-implemented inherently FAIL-SAFE Dry Cask Containment A.S.A.P. (D-1) 

Comment: Spent fuel storage at the Harris Plant is a particular long-range concern. 

Commercial reactors were licensed under the assumption that the federal government would 

provide a permanent storage site for spent fuel, which remains hazardous for hundreds of 

thousands of years. Such a site has not yet been provided. Harris is providing temporary 

storage for its own spent fuel in addition to fuel from other reactors. Storage of massive 
Appendix A 

NUREG-1437, Supplement 33 A-56 August 2008 

quantities of fuel under water presents serious safety concerns, as noted in federal reports and 

the work of independent scientists. Granting a license extension for a facility that produces 

materials that will remain highly dangerous for far longer than the entire span of recorded 

human history in the absence of a long-range plan to protect the environment and human health 

raises serious concerns. (F-2) 

Response: Onsite storage of spent nuclear fuel is a Category 1 issue. The safety and 

environmental effects of long-term storage of spent fuel onsite has been evaluated by the NRC, 

and, as set forth in the Waste Confidence Rule. 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. 

These comments provide no new and significant information. Therefore, no changes have been

made to the SEIS.

A.2.12 Comments Concerning Alternatives 

Comment: Now, looking at the alternatives, just very quickly, I think that the analysis is 

extremely limited in looking at the conservation side, to only look at utility sponsored 

conservation. 

And that was probably the easiest for you all to look at because several studies conducted in 

the last year, part of the General Assembly, or the North Carolina Utilities Commission, looked 

at a substantial reduction of energy use in this area, and our Senate Bill 3 from the session 

mandated reductions, mandated the change of different alternative sources of energy. 

But to only limit the review to utility sponsored conservation ignores the real potential for 

conservation that people will do. I mean, looking at what builders are doing, and they are 

bringing house movements, looking at the changes in office spaces, in schools, and commercial 

and institutional buildings, there is a real potential for conservation that will not be utility 

sponsored.

And to say that the only conservation that is an alternative to extending the nuclear power plant, 

is just utility sponsored, I think is something that needs to be corrected when you issue the final 

environmental impact statement. (A-10) 

Response: NRC staff acknowledges that activities taken by citizens in their private or business 

lives may contribute to energy conservation or efficiency. Many of the efficiency practices and 
Appendix A 

August 2008 A-57 NUREG-1437, Supplement 33 

measures identified in A Study of the Feasibility of Energy Efficiency as an Eligible Resource as 

Part of a Renewable Portfolio Standard for the State of North Carolina (GDS Associates 2006) 

commissioned by the North Carolina Utilities Commission and referenced by NRC staff in 

developing the conservation-based alternative could be taken by non-utility actors. The NRC 

staff believes, however, that the measures identified in the GDS report are more likely to 

achieve their indicated effectiveness if a specific entity pays for them, rather than relying on 

private citizens or businesses to fund the actions themselves. In this case, “utility-sponsored” is 

meant to indicate only that the utility would pay for the efficiency measures, much as the utility 

would likely pay for the other alternatives to license renewal (new generation sources or 

purchased power). NRC staff purposely did not indicate a specific mechanism by which the 

utility would sponsor conservation. This could include direct payments to citizens, contracts with 

third-party installers, dedicated charges paid to independent program administrators, or other 

approaches, all of which are outside of NRC’s regulatory purview. In addition, the NRC staff 

purposely did not indicate which actors would implement the measures, which could include 

private citizens. NRC staff did not intend to limit the range of possible actions by indicating that 

the conservation alternative was “utility sponsored.” 

Comment: You (NRC) have to take a bigger step, but with less effort. I have told you 3 times 

about the “I am coil power engine”, you (NRC) have the power to make sure that a prototype is 

made, which you can do, by sending out a letter to each and every electric company, that you 

are suppose to have power over. About my engine, I am 100% sure that my engine “is the 

solution to the problem right now” and it will clear up a lot of things later on too. (E-3) 

Comment: Please, remember, that all of the electric companys [sic] are crying out, that they 

haven’t found any new way to produce the same amount of electricity or more for its customers, 

without it costing them more money, than, what they are already spending. So, they need all 

the information that they can get, if the companys [sic] are really searching, for new ways, 

“cheaper ways”, to supply their customers with electricity without killing the very people that you 

are trying to provide a service to. (E-4) 

Response: The commenter is proposing a power engine as a substitute for all existing power 

generating plants. No specific information about the attributes and functioning of this “Coil 

Power Engine” are provided, therefore the NRC staff is unable to make a detailed assessment 

of the proposed alternative. The comments do not provide new information to support the 

environmental review; therefore it will not be evaluated further.

Comment: Many significant findings of the Harris EIS supplement are not reflected in the 

executive summary, such as the fact that utility sponsored conservation programs could 

adequately and cost-effectively replace the output of the Harris plant, and be fully implemented 

by a decade prior to the expiration of the current license. (L-1) 

Comment: "The NRC staff concludes, then, that conservation has the lowest level of 

environmental impact among all alternatives considered. Thus, conservation is the 
Appendix A 

NUREG-1437, Supplement 33 A-58 August 2008 

environmentally preferred alternative to the proposed federal action of renewing the HNP 

license." (Section 8.3 p. 8-76) 

Instead the executive summary talks only about "the likely adverse impacts of likely power 

generating alternatives" and goes further by not clarifying that some sources would have less 

negative impact than continued operation of the Harris Plant, and could actually have a positive 

impact, saying instead, "The impacts may be greater in some areas, depending on the 

alternatives selected." (p. xvii) 

This summary is a misleading interpretation of the EIS, which finds several alternatives to 

continued operation to have a lesser impact, and for some to have positive impacts in a wide 

range of categories, especially the conservation alternative. (L-2) 

Response: The EIS executive summary is meant to provide a brief overview of the conclusions 

reached in the EIS. The executive summary for the Shearon Harris EIS accurately describes 

the conclusions and recommendations reached by the staff. Furthermore the detailed 

environmental analysis, recommendations and conclusions are captured in the corresponding 

sections of the Shearon Harris EIS and it is unreasonable to suggest that all the specific details 

of every single technical aspect of the environmental analyses be captured “verbatim” in the 

executive summary. These comments provide no new and significant information. Therefore, 

no changes have been made to the SEIS. 

Comment: Section 8.1 (p.8-2) "NRC staff expects that the impacts of decommissioning after 

60 years of operation would not differ significantly from those that would occur after 40 years of 

operation." This statement ignores the more highly irradiated components of the plant. 

In the following discussion of the impacts of shutdown in 2026 versus continued operation, the 

effects of continued operation are minimized as small, yet 20 years of continued operation after 

40 years could be predicted to result in a 50% increased cumulative operational impact. 

This once again shows up the logical fallacy as identifying impacts as "small" etc. rather than 

quantifying them, particularly for risks and impacts that the NRC has already calculated 

precisely in terms of extra deaths and cancer cases etc., or mathematical likelihood. 

Twenty more years of a supposedly small negative impact (compared to what?) is not 

equivalent to a one-time in one year small impact.

In mathematical terms a "small" impact or risk multiplied by a 50% longer period of operation 

could well be "moderate" or even "large." However "small" multiplied by anything is "small" 

because it is not a mathematical term. (L-9) 

Response: The impacts of license renewal on radiation doses, waste management, air quality, 

water quality, ecological resources, and socioeconomics impacts from decommissioning are 

Category 1 issues, and are covered extensively in chapter 7 of the GEIS. 
Appendix A 

August 2008 A-59 NUREG-1437, Supplement 33 

The decommissioning chapter of the GEIS analyzes the impact that an additional 20 years of 

plant operation would have on ultimate plant decommissioning. An analysis of the expected 

impacts from plant decommissioning is provided in NUREG–0586, ‘‘Final Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities’’ (August 1988). The 

analysis in the GEIS for license renewal examines the physical requirements and attendant 

effects of decommissioning after a 20-year license renewal period compared with 

decommissioning at the end of 40 years of operation, and finds little difference in effects. 

The physical requirements and attendant effects of decommissioning nuclear power plants after 

a 20-year license renewal are not expected to differ from those of decommissioning at the end 

of 40 years of operation. Decommissioning after a 20-year license renewal would increase the 

occupational dose no more than 0.1 person-rem and the public dose by a negligible amount 

(GEIS Section 7.3.1). License renewal would not increase to any appreciable extent the quantity 

or classification of LLW generated by decommissioning (GEIS Section 7.3.2). Air quality, water 

quality, and ecological impacts of decommissioning would not change as a result of license 

renewal (GEIS Sections 7.3.3, 7.3.4, and 7.3.5). Incremental radiation doses, waste 

management, air quality, water quality, ecological, and socioeconomic impacts of 

decommissioning due to operations during a 20-year license renewal term would be of small 

significance.

Comment: The NRC is also abdicating its responsibility to protect the health and safety of the 

public by continuing to use incorrect time frames throughout the EIS, including the feasibility or 

pricing of alternatives to be considered. It is 2026-2046 that should be projected, not 2006 

assumptions. Comments during the scoping period pointing out this draft error were filed away 

as "not providing new information"!!! (L-3) 

Comment: In the scoping period the NRC was specifically advised that considerations of 

alternative power sources needed to be projected into the 2026 time period, not the present 

day, in terms of availability, feasibility and cost. The NRC has completely ignored this needed 

correction in Section 8.2 Alternative Energy Sources. New generation sources starting 

construction ten years from now to replace Harris Unit 1 in 2026 would have higher construction 

costs or probably not be allowed (e.g. coal, to which many pages are dedicated, whereas wind 

gets at most a few lines). 

Thus the consideration of alternatives is limited to two types of coal generation, natural gas 

generation, new nuclear plants, utility sponsored conservation or purchased power, or a 

combination of alternatives. No photovoltaics are included. No solar hot water heating is 

included.

These last two alternatives are significant omissions for the Harris plant because the Progress 

Energy system experiences its highest peaks in summer (4-6 pm period) on the hottest days, 

with peaking demand particularly from residential, commercial, office-institutional customers. 
Appendix A 

NUREG-1437, Supplement 33 A-60 August 2008 

There is NO attempt to frame the consideration of alternatives in future terms, specifically what 

megawattage available, feasible technology in the future, future lower costs etc. 

Since there is also no consideration of higher uranium prices in future, in spite of scoping 

comments on increasing demand and diminishing supply, the consideration of alternatives is 

fatally rooted in the past instead of being projected into the future. (L-10) 

Comment: The purchased power discussion in Section 8.2.6, page 8-70, assumes that 

purchased power is from "dirty" sources like other coal or natural gas plants. However this 

discussion is supposed to consider what might be available in the 2026-2046 period, not 2006. 

Even today there is wind power coming on line, with Texas showing the fastest increase in 

available megawattage at present.

In the 2026-2046 period any reasonable person would assume not only greater wind resources 

but a considerably enhanced national grid to wheel power around so that power becomes as 

fungible as currency, which to energy traders it already is. Progress Energy has its own energy 

trading department. (L-15) 

Response: The NRC staff made a reasonable effort to put into a clear comparative context the 

available power generating technologies that could be used to replace the electric power 

currently generated by Shearon Harris, including wind power among others. To support that 

effort a baseline needed to be established in order to make sound descriptions of the 

environmental impacts that could be related to the implementation of alternative power 

generation alternatives. The NRC staff cannot speculate about what could be the available 

technologies that could be available 20 years from now, but the NRC staff did used the most 

current information available on the power generating technologies that are technologically 

feasible and proven to replace the electric power generated by Shearon Harris. Chapter 8 of 

this SEIS contains the analysis environmental impacts associated with alternatives available to 

replace the electric power generated by Shearon Harris. 

Comment: Secondly, NRC has failed to determine how much power generated by the Harris 

plant is sold outside the service area. The plant is connected to the east coast portion of the 

national grid by a high voltage line to Richmond. The company has stated that power from the 

plant is sold outside the region. It is only the power from the plant that will be needed locally in 

the 2026- 2046 period that should be considered in any consideration of alternatives. (L-11) 

Response: NRC regulations that outline the purpose and need for the proposed action indicate 

that alternatives should meet the needs currently served by the plant beyond the period of 

plant’s current license period, and do not limit this purpose to replacing “local” demand. Thus, 

analyzing which end users ultimately consume power generated by HNP (which may vary 

based on CP&L system needs and based on whether CP&L’s bulk power obligations are served 

by electricity produced at HNP or elsehwere) is not necessary. Further, under 10 CFR 

51.95(c)(2), “the supplemental environmental impact statement is not required to include 
Appendix A 

August 2008 A-61 NUREG-1437, Supplement 33 

discussion of need for power. . .” though the commenter indicates that NRC staff should 

determine the local need for power, and analyze alternatives to replace only that share of the 

plant’s output. The comment will not be evaluated further.

Comment: Overall the NRC has elected not to implement the findings of its own EIS -- that 

conservation would be less harmful to the environment and public health than operation of the 

Harris plant beyond 2026, and that it is both economically and practically feasible. 

Instead the NRC has punted this decision to imaginary others, "preserving the option of license 

renewal for energy planning decision makers." (p.9-9) However, as the NRC well knows, North 

Carolina's only "energy planning decision makers" for the Harris Plant are (a) Progress Energy 

executives and (b) the North Carolina Utilities Commission (NCUC). 

Under North Carolina's current laws Progress Energy is not required to substitute any 

alternative to extended operation of the Harris plant merely because it is less environmental 

harmful. That is solely the purview of the NRC. Secondly, under North Carolina's laws the 

executives of the company are beholden to shareholders to maximize profit for the corporation, 

which, in turn, stands to make more profit per kwh sold from continued operation of the plant 

through return on investment.

Thirdly, I don't believe the NCUC currently has the power to shut down the Harris plant in 2026 

as being too old, or unsafe, or more expensive than alternatives, if the NRC renews the license. 

(L-20)

Response: The action in front of the NRC is whether or not to renew the operating license for 

Shearon Harris. As part of the NRC’s obligations under NEPA an Environmental Impact 

Statement has been prepared to inform decision makers about the whole range of 

environmental impacts associated with the action and alternatives to the proposed action. The 

NRC will make its decision on the renewal based on the results of the nuclear safety review and 

the recommendations of the environmental review. It is up to energy planning decision makers 

(utility owners, state and federal agencies other than NRC) to decide whether or not they wish to 

keep Shearon Harris in operation for economic or other relevant reasons.

A.2.13 Comments Concerning Global Warming 

Comment: We know what some of those impacts are going to be. This year there has been 

severe drought in this area, water use has been severely restricted. Looking at Harris Lake as 

an example, it certainly is at the margin of how much water can be used. 

Luckily there was a shutdown during the summer, for other reasons. And if it hadn't been 

shutdown, levels could have been at an extreme criticality at the plant. 
Appendix A 

NUREG-1437, Supplement 33 A-62 August 2008 

And we are looking from 2026 to 2046. The draft environmental impact statement does not 

address, at all, any changes of climate, climate change. It does not look at whether those 

droughts are going to be more severe, whether the weather patterns are going to change; 

whether there will be any differences in the environment. 

I think that is reasonably foreseeable, of water use in that time period. By 2046, and if we are 

going to extend, if the NRC is going to extend the operating license for this plant, from 2026 to 

2046, you have to address those foreseeable changes. And you are going to have to address 

climate change in it. 

And you have to be able to document that, in the environmental impact statement. (A-7) 

Response: The comment addresses the impacts of climate change on plant operation. 

Operational safety issues are not within the scope of an environmental review. However, they 

are under the purview of the regulatory oversight process and would be addressed there as 

appropriate.

A.2.14 Editorial and General Comments 

Comment: The entire EIS relies on a ranking of impacts as being SMALL, MODERATE, or 

LARGE (sic). Yet these are not merely "small" "moderate" or "large" negative impacts but 

include findings of "small" "moderate" or "large" positive impacts, but they are not properly 

differentiated as such, especially when summarizing or in the tables. 

Thus tables can be extrapolated from the EIS that would make it appear that the impacts of 

license renewal are equivalent to shutting down the plant and meeting system needs in other 

ways. This is not true according to the detailed text, yet it handily supports the executive 

summary's false assertion that anything else would be either just as bad or worse. 

The entire text of the EIS needs to be revised to ensure that all postulated impacts are identified 

as negative or positive. 

The tables also need to be redone to create clearly identified separate POSITIVE IMPACT, 

NEGATIVE IMPACT (or ADVERSE IMPACT) columns, which would be preferable to keeping 

the tables as they are and amending so that all entries read (for example) 'SMALL POS" 

'SMALL NEG". It would clearly be unacceptable to solve this problem by abbreviating to POS 

and ADV because this creates the greatest possibility for misinterpretation. Up and down 

arrows are equally unacceptable because they can mean either of two opposites (down = bad 

effects or down = less of (current) bad effect. (L-5) 

Comment: Table 9-1 (page 9-7 to 9.8) is misleading/false (as noted above) because the 

SMALL impacts of conservation are positives not negatives but are made to appear the same 

as the supposedly only SMALL negative impacts of continued operation of the plant. (L-17) 
Appendix A 

August 2008 A-63 NUREG-1437, Supplement 33 

Comment: Thirdly, it is this section that we find an even worse perversion and misuse of the 

"small/medium/large" framing of impacts. In the charting of impacts from conservation (Table 8-

6, p. 8-67) the beneficial impacts of energy conservation over power generation is shown as 

having "SMALL" impacts for all categories, yet these are POSITIVE impacts, not negative ones 

(per the text). Yet this makes them equivalent to the negative impacts of the other alternatives, 

such as continued operation of the Harris plant, new nuclear plants or a coal plant. 

This is worse than misleading, particularly when these contrary values are charted as if 

equivalent, in a very long document that many decision-makers don't have time to read, and 

when the advantages of the conservation alternative are not reflected in the executive summary. 

(L-12)

Response: The Shearon Harris EIS has been prepared following the guidance and 

requirements provided in 10 CFR Part 51. A standard of significance was established for 

assessing environmental issues and, because significance and severity of an impact can vary 

with the setting of a proposed action, both "context" and "intensity" were considered. With these 

standards as a basis, each impact was assigned to one of three significance levels as defined in 

10 CFR Part 51, Subpart A, Appendix B, Table B-1: 

Small: For the issue, environmental effects are not detectable or are so minor that they will 

neither destabilize nor noticeably alter any important attribute of the resource. For the purposes 

of assessing radiological impacts, the Commission has concluded that those impacts that do not 

exceed permissible levels in the Commission's regulations are considered small. 

Moderate: For the issue, environmental effects are sufficient to alter noticeably but not to 

destabilize important attributes of the resource. 

Large: For the issue, environmental effects are clearly noticeable and are sufficient to 

destabilize important attributes of the resource. 

The NRC staff has chosen not to make a distinction between what would be considered a 

positive impact or a negative impact in a resource area, but rather explicitly state when an 

impact could have a noticeable effect on the environment. The text of the EIS in its 

corresponding sections specifically describes all the impact areas all the corresponding 

significance levels for all areas. 

Comment: Page 2-28, second paragraph. Given that a full paragraph is devoted to the dwarf 

wedgemussel, a species that also appears in Table 2-4, it should be made clear early in the 

paragraph that this species occurs in the (adjoining) Neuse River drainage (in Wake County) 

rather than the Cape Fear River drainage. This critical bit of information appears too late in the 

paragraph. (O-1) 

Comment: In two places in Section 2.1.3 of the DSEIS the approach velocity of water to the 

debris screens is reported as "9 m/sec (0.5 ft/sec) and 9.1 m/sec (0.5 ft/sec)." These values are 
Appendix A 

NUREG-1437, Supplement 33 A-64 August 2008 

not equivalent. We assume that the approach velocity is 0.5 ft/sec, which equals 0.15 m/sec. 

Please provide the correct velocity values. (H-1) 

Comment: Section 4.8.4, Cumulative Impacts on Surface Water. Given that blowdown 

temperatures are only slightly higher than ambient in the warmer months, it seems unlikely that 

“localized areas of Harris Reservoir...could potentially increase in temperature, creating an 

environment optimal for the growth of thermophilic microorganisms...” Even with three closedcycle units operating, temperatures would not approach those optimal for thermophilic 

pathogens. Recommend that “optimal’ be replaced with “suitable.” As is, the text suggests that 

these pathogenic organisms will flourish. Thermophilic organisms haven’t been a problem at 

once-through power plants in the southeastern U.S. with discharge temperatures greater than 

110°F in summer. They certainly won’t be a problem at Harris, whether one, two, or three 

closed-cycle units are operating. (O-2) 

Comment: Page 2-30, lines 12-14. Should be re-worded as follows: “CP&L has enrolled 5700 

ha (14,090 ac) of land around the Harris Reservoir, known collectively as the Shearon Harris 

Game Lands, in the North Carolina Game Lands program.” Misleading as is. (O-3) 

Comment: Page 2-31, line 29. Species name is Liquidambar styraciflua. (O-4)

Comment: Page 2-33, lines 7-8. Not sure what meaning is intended. “Harris Lake County Park 

holds the only longleaf pine habitat [in the area? in the county?] outside the Harris Research 

Tract.” As written, it’s incorrect. Clearly, there are hundreds of thousands of acres of longleaf 

pine habitat outside the Harris Research Tract, an estimated 80,000 acres on the Fort Bragg 

installation alone. (O-5)

Comment: Page 2-35/Table 2-5. The American alligator is threatened due to similarity of 

appearance to the American crocodile. This is an important distinction, and could be handled 

with a footnote. (O-6) 

Comment:

Item Topic Comment

Table 2-4 Ambloplites cavifrons Federal status should be “SC.”

Table 2-4 Moxostoma sp. 2 Should be revised to “Moxostoma sp. 3.” Revise 

footnote b accordingly.

Table 2-4 Noturus furiosus Federal status is “SC.”

Table 2-4 Noturus sp. 1 Should be revised to “Noturus sp. 2;” Federal status is 

“SC.” Revise footnote b accordingly.

Table 2-5 Hemidactylium scatatum Should be revised to “Hemidactylium scutatum.”

Table 2-5 Haliaeetus leucocephalus State status should be “T.”
Appendix A 

August 2008 A-65 NUREG-1437, Supplement 33 

Table 2-5 Condylura cristata Should be revised to “Condylura cristata pop. 1.”

Table 2-5 Star-nosed mole Should be revised to “Star-nosed mole - Coastal Plain 

Population.”

Table 2-5 Eupatorium resinosum State status is “T-SC.”

Table 2-5 Lilium pyrophilum State status is “E-SC.”

Table 2-5 Lysimachia asperulaefolia Should be revised to “Lysimachia asperulifolia.”

Table 2-5 Pyxidanthera brevifolia Should be revised to “Pyxidanthera barbulata var. 

brevifolia.”

Table 2-5 Rhus michauxii State status is “E-SC.”

Table 2-5 Trillium pusillum Should be revised to “Trillium pusillum var. 

virginianum.”

Table 2-5 Carolina Least Trillium Should be revised to “Virginia Least Trillium.”

Table 2-5 Pteroglossaspsis ecristata Should be revised to “Pteroglossaspis ecristata.”

Table 2-5 Stylisma pickeringii Should be revised to “Stylisma pickeringii var. 

pickeringii.”

Note that while the bald eagle has been de-listed at the federal level, it maintains “Threatened” 

status at the state level. Lines 30 through 33 on page 2-33 should be revised to reflect this 

status. Also, on page 2-34 line 2 we suggest adding a sentence similar to “This bird is still on 

the state list as threatened” after “Energy 2006b).” 

It is noted that Table 2-4 includes recognition of Federal species of Special Concern, while 

Table 2-5 does not. Table 2-5 contains numerous species that have a Federal status of Special 

Concern, but are indicated as “_.” (O-7) 

Comment: "It is conceivable that a combination of alternatives might be cost-effective." Section 

8.2.8, p.8-75 

However, the combined alternatives option that is discussed in Section 8 is not included in 

Table 9-1 in the Summary and Conclusions section, even thought the text (page 9-6) says that it 

is. (L-16) 

Response: Comments are noted. Necessary revisions to the text have been made to the 

corresponding sections of the SEIS, the revisions are editorial in nature and do not affect the 

conclusions reached in the Supplement.

Comment: Page 2-33, lines 37 and 38, page 2-34, lines 1-8. Given that Table 2-5 indicates 

that the bald eagle has no state or federal special status, this discussion appears unwarranted. 
Appendix A 

NUREG-1437, Supplement 33 A-66 August 2008 

Recommend that it be deleted or that the species’ special status under the Bald and Golden 

Eagle Protection Act be discussed. (O-8) 

Comment: Section 4.8.1, Cumulative Impacts on Aquatic Resources. The conclusion seems 

based on flimsy evidence and pure speculation. For example, it does not follow logically that 

doubling the acreage of the reservoir “could lead to an increase in eutrophy in the reservoir.” 

Recommend that, at a minimum, that the next-to-last sentence be changed from “would” to 

“could” be MODERATE to LARGE. (O-9) 

Comment: Economic impacts overall would be more than small. In addition to the benefits to 

low-income customers, the benefits to industrial and other customers in reducing bills and 

stabilizing energy prices would have huge economic impact. As some studies have indicated, 

this type of economic impact (such as enable a business or industry to remain competitive and 

not go under) spread throughout the local economy with a magnifier effect. 

In addition nowhere does the EIS consider the economic impact of not renewing the Harris plant 

license in rate base terms. Rates for all customers would need to be adjusted downwards in 

order to remove the guaranteed rate of return on the allowed costs of the Harris plant, which is a 

very significant dollar fraction of Progress Energy Carolina's (CP&L's) entire generation system. 

(L-14)

Response: Comments are noted, but based on the facts and findings of the review the staff 

does not agree with the revisions proposed by the commenters. Specifically, (1) the discussion 

regarding bald eagles was included as part of the SEIS when the specie was still listed as a 

federal species of concern, (2) cumulative impacts encompasses all reasonable and 

foreseeable actions that would have potential impacts on the environment. The comments 

provide no new information to alter the staff’s finding in the SEIS; therefore, no changes were 

made to the SEIS in response to these comments.

A.2.15 Comments Concerning Issues Outside the Scope of License Renewal: Operational 

Safety, Emergency Preparedness, Security 

Operational Safety 

Comment: I have a document that I would like to put into the record. It is the Office of Inspector 

General's Special Inquiry Report that came out last week, looking at the HEMYC fire barriers. 

And it is relevant to both the environmental side and the safety side. It is, most of you here 

have probably seen it. It says that for at least 15 years that the NRC and the various nuclear 

utilities have known that the HEMYC fire barriers are likely to fail, they don't meet the standards. 

And that six out of the 15 that are of special concern are Progress Energy's and Duke Power's. 

And that this is something that we raised in the issue of challenging on the safety permit. 
Appendix A 

August 2008 A-67 NUREG-1437, Supplement 33 

And I think there is, it continues to be of major concern, and I think you ought to address that, is 

looking at the different access, and the various SAMAs. 

This is something that, fire safety is a problem, it is one of the greatest risks to safe shutdown of 

a nuclear power plant, and you are all not doing anything about it. So we can put that in the 

record. (A-2) 

Response: The commenter makes reference to an Office of the Inspector General special 

inquiry pertaining to Hemyc fire barriers. Hemyc is a fire barrier that has been installed at a 

number of nuclear power plants (including Shearon Harris). The concerns focused on the failure 

of Hemyc to provide the level of protection expected for a 1-hour rated fire barrier during 

confirmatory testing sponsored by the NRC in 2005. 

The NRC has taken appropriate actions commensurate with the significance of the safety 

concern represented by the reduced Hemyc fire barrier resistance. Operating reactors with 

Hemyc fire barriers have been safe throughout this period of time and remain safe today. The 

safety significance of the Hemyc issue is low at Shearon Harris because the other components 

of fire protection, prevention and detection and suppression, remain intact. 

The NRC’s Reactor Oversight Process (ROP) continues to ensure that Shearon Harris is 

operating safely and in accordance with applicable regulations. Fire protection experts conduct 

comprehensive fire protection design inspections every 3 years, and Resident Inspectors 

inspect fire protection controls and equipment quarterly and fire brigade training annually. 

Inspectors review fire protection equipment design, operational safety programs, and the control 

of transient combustibles and ignition sources. Therefore, the NRC continues to rely on the 

ROP to provide oversight of fire protection requirements. 

Comments regarding operational safety issues are outside the scope of license renewal; 

therefore, no changes were made to the supplement in response to this comment.

Emergency Preparedness 

Comment: Looking at this time period, from 2026 to 2046, the population of this area is going to 

increase dramatically. You know, the population within the ten mile emergency planning zone is 

12 to 15,000 now, it easily could go up to 100,000. 

Certainly with the extension of the outer beltway around Raleigh, the 540 coming to the 

southwest Wake County, if anything there is going to be more and more people moving into this. 

So there will be a considerable more impact from anything that happens at the power plant. 

With the increasing population, increasing aging population, we cannot say that the impacts 

from the source term, or the likely accidents, is not going to impact people. (A-5) 
Appendix A 

NUREG-1437, Supplement 33 A-68 August 2008 

Comment: The sections of the report that address socioeconomic characteristics and 

environmental justice are based on data from the year 2000. They are already out of date.

Rapid growth of the Chatham County population, and issuance of permits for additional housing 

that has not yet been built or occupied, are not taken into account in this Supplement. The 

Triangle J Council of Governments projects that the population of Eastern Chatham will more 

than triple by 2035. Changes in population size could drastically affect the ability to evacuate 

people in the event of radiation releases. The Supplement does not assess the impact of 

evacuation on infants and toddlers, school children, the elderly, or institutionalized populations. 

These deficiencies must be addressed. (F-3) 

Response: Changes in Population and the socioeconomic characteristics in the vicinity of the 

Shearon Harris Nuclear Power Plant are covered in Chapter 2. Section 2.2.8 specifically 

provides a projection of population growth during the period of extended operation, and what 

socioeconomic impacts would result from the continued operation of Shearon Harris. 

Additionally the NRC staff based its environmental justice analysis on the 2000 U.S. Census 

data. The 2000 U.S. Census data is the most current U.S. government sanctioned population 

data available. 

The Commission considered the need for a review of emergency planning issues in the context 

of license renewal during its rulemaking proceedings on 10 CFR Part 54, which included public 

notice and comment. As discussed in the Statement of Consideration for rulemaking (56 FR 

64966), the programs for emergency preparedness at nuclear power facilities apply to all 

nuclear power facility licensees and require the specified levels of protection from each licensee 

regardless of plant design, construction, or license date. Requirements related to emergency 

planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part 50. These 

requirements apply to all operating licenses and will continue to apply to facilities with renewed 

licenses. Through its standards and required exercises, the Commission reviews existing 

emergency preparedness plans throughout the life of any facility, keeping up with changing 

demographics and other site-related factors. Therefore, the Commission has determined that 

there is no need for a special review of emergency planning issues in the context of an 

environmental review for license renewal. 

The comments are outside the scope of the license renewal review; therefore, they will not be 

evaluated further. 

Offsite entities such as State and local governments and the U.S. Federal Emergency 

Management Agency have responsibility for offsite emergency planning. Perceived deficiencies 

in the offsite emergency plans should be directed to the government entities that have 

responsibility for the specific portions of the plan judged to be deficient. 
Appendix A 

August 2008 A-69 NUREG-1437, Supplement 33 

Security 

Comment: And looking at the various accidents, and SAMAs, one thing in the design basis 

accidents that hasn't been addressed is the aircraft threats. I understand that the NRC is going 

through the process of looking at that again, and coming up with some rules. 

But certainly you can't say that that issue hasn't been known to both Progress Energy and the 

NRC for 20 years. And that looking at it there is no plan in the next 20 years to correct that 

problem, there is no plan to correct the fire problem. 

And it is hard for us to understand how you can say from the year 2026 to 2046, that there won't 

be any additional potential for accidents. We know that there is going to be an accident 

somewhere in this country, from the fire protection, and we are pretty sure that with the way that 

the world is these days, that there will be an aircraft threat. 

And neither the safety report, or the environmental impact statement, I think squarely addresses 

those kinds of impacts. And to say that we are not looking at them because they are in the 

generic environmental impact statement, we know that the aircraft threats are not part of the 

generic environmental impact statement. (A-3) 

Response: The issue of security and risk from malevolent acts at nuclear power plants is 

beyond the scope of license renewal. These matters will continue to be addressed through the 

ongoing regulatory oversight process as current and generic regulatory issues that affect all 

nuclear facilities. Appropriate safeguards and security measures have been incorporated into 

the site security and emergency preparedness plans. Any required changes to emergency and 

safeguards contingency plans related to terrorist events will be incorporated and reviewed under 

the operating license.

Appendix B 

Contributors to the Supplement 

August 2008 B-1 NUREG-1437, Supplement 33 

Appendix B: 

Contributors to the Supplement 

The overall responsibility for the preparation of this supplement was assigned to the Office of 

Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The supplement 

was prepared by members of the Office of Nuclear Reactor Regulation with assistance from 

other NRC organizations and Lawrence Livermore National Laboratory. 

Name Affiliation Function or Expertise 

NUCLEAR REGULATORY COMMISSION

Rani L. Franovich Nuclear Reactor Regulation Branch Chief 

Samuel Hernandez Nuclear Reactor Regulation Project Manager 

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics, Environmental Justice, Land Use 

Dennis Beissel Nuclear Reactor Regulation Hydrology, Water Use and Quality 

Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection 

Jennifer A. Davis Nuclear Reactor Regulation Cultural Resources 

Scott Werts Nuclear Reactor Regulation Meteorology, Air Quality 

Jessie Muir Nuclear Reactor Regulation Backup Project Manager, Nonradiological Waste 

Andrew Stuyvenberg Nuclear Reactor Regulation Alternatives 

Harriet Nash Nuclear Reactor Regulation Aquatic and Terrestrial Ecology 

Elizabeth Wexler Nuclear Reactor Regulation Aquatic Ecology, Threatened and Endangered Species 

Nathan Goodman Nuclear Reactor Regulation Terrestrial Ecology, Threatened and Endangered Species

Briana Balsam Nuclear Reactor Regulation Terrestrial Ecology 

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation Alternatives 

LAWRENCE LIVERMORE NATIONAL LABORATORY(a)

Crystal Quinly Environmental Evaluations Team Leader 

Paul Webb Environmental Evaluations Health Physics 

Paul McGuff Environmental Evaluations Cultural Resources 

David Armstrong Environmental Evaluations Meteorology, Air Quality 

Nancy Woods Environmental Evaluations Lead Editor 
Appendix B 

NUREG-1437, Supplement 33 B-2 August 2008 

Name Affiliation Function or Expertise 

INFORMATION SYSTEMS LABORATORIES

Bruce Mrowca Severe Accident Mitigation Alternatives 

Joshua Reinert Severe Accident Mitigation Alternatives 

(a) Lawrence Livermore National Laboratory is operated for the U.S. Department of Energy by Lawrence Livermore 

National Security, LLC. 
Appendix C 

Chronology of NRC Staff Environmental Review Correspondence 

Related to Carolina Power & Light Company Application for the 

License Renewal of Shearon Harris Nuclear Power Plant, Unit 1 

August 2008 C-1 NUREG-1437, Supplement 33 

Appendix C: 

Chronology of NRC Staff Environmental Review Correspondence 

Related to Carolina Power & Light Company Application for the 

License Renewal of Shearon Harris Nuclear Power Plant, Unit 1 

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and Carolina Power & Light Company, doing business as 

Progress Energy Carolinas, Inc. (CP&L) and other correspondence related to the NRC staff’s 

environmental review, under Title 10 of the Code of Federal Regulations, Part 51 (10 CFR 

Part 51), of the CP&L application for renewal of the Shearon Harris Nuclear Power Plant, Unit 1 

(HNP) operating license. All documents, with the exception of those containing proprietary 

information, are publicly available at the NRC Public Document Room (PDR), located at One 

White Flint North, 11555 Rockville Pike, Rockville, Maryland, 20852, or from the NRC’s 

Agencywide Documents Access and Management System (ADAMS). The ADAMS Public 

Electronic Reading Room is accessible at http://adamswebsearch.nrc.gov/dologin.htm. The 

ADAMS accession numbers for each document are included below. Persons who do not have 

access to ADAMS, or who encounter problems in accessing the documents located in ADAMS, 

should contact the NRC’s PDR reference staff by telephone at 1-800-397-4209 or

301-415-4737, or by e-mail at pdr@nrc.gov.

November 14, 2006 Letter from C. Gannon, CP&L, submitting the application for renewal of 

the operating license for the HNP. (Accession No. ML063350267) 

November 14, 2006 Shearon Harris Nuclear Power Plant, Unit 1 — License Renewal 

Application, Applicant’s Environmental Report. (Accession No. 

ML063350276)

December 8, 2006 NRC press release announcing the availability of the license renewal 

application for Shearon Harris Nuclear Power Plant. (Accession 

No. ML063420172) 

December 5, 2006 Letter to C. Gannon, CP&L, Receipt and Availability of the License 

Renewal Application for Shearon Harris Nuclear Power Plant.

(Accession No. ML063210237) 

December 11, 2006 Federal Register Notice of Receipt and Availability of Application for 

Renewal of Shearon Harris Nuclear Power Plant Facility Operating 

License No. NPF-63 for an Additional 20-Year Period (71 FR 71586).

(Accession No. ML071770522) 
Appendix C 

NUREG-1437, Supplement 33 C-2 August 2008 

January 8, 2007 Determination of Acceptability and Sufficiency for Docketing the 

Application from Carolina Power and Light Company, for the renewal 

of the operating license for the Shearon Harris Nuclear Power Plant, 

Unit 1. (Accession No. ML063520336) 

January 12, 2007 Federal Register Notice of Acceptance for Docketing of the Application 

for Facility Operating License No. NPF-63 for an Additional 20-Year 

Period; Carolina Power and Light Company, Shearon Harris Nuclear 

Power Plant, Unit 1 (72 FR 1562). (Accession No. ML071730450) 

March 1, 2007 Letter to S. Cropps, Eva H. Perry Library, regarding the maintenance 

of reference material at the Eva H. Perry Library, related to the 

Shearon Harris Nuclear Power Plant license renewal application.

(Accession No. ML063600236) 

March 7, 2007 Letter from D. Corlett (CP&L) to U.S. NRC staff, regarding notification 

of NPDES permit renewal for HNP. (Accession No. ML070740432) 

March 14, 2007 Proposed review schedule, intent to prepare an environmental impact 

statement and opportunity for a hearing regarding the application from 

Carolina Power & Light Company, for Renewal of the operating license 

for the Shearon Harris Nuclear Power Plant. (Accession No. 

ML070230076)

March 20, 2007 Federal Register Notice of Opportunity for Hearing, and Notice of 

Intent to Prepare an Environmental Impact Statement and Conduct the 

Scoping Process for Facility Operating License No. NPF-63 for an 

Additional 20-Year Period; Carolina Power & Light Company, Shearon 

Harris Nuclear Power Plant, Unit 1 (72 FR 13139). (Accession No. 

ML070790140)

March 20, 2007 Letter to D. L. Kilma, Advisory Council on Historic Preservation 

Concerning the Shearon Harris Nuclear Power Plant License Renewal 

Application Review. (Accession No. ML070220273) 

March 20, 2007 Letter to J. Crow, North Carolina State Historic Preservation Officer, 

Request for Comments Concerning the Shearon Harris Nuclear Power 

Plant License Renewal Application Review. (Accession No. 

ML063600188)
Appendix C 

August 2008 C-3 NUREG-1437, Supplement 33 

March 20, 2007 Letter to T. Lewis, Meherrin Indian Tribe, Request for Comments 

Concerning the Shearon Harris Nuclear Power Plant License Renewal 

Application Review. (Accession No. ML070220278) 

March 20, 2007 Letter to R. Richardson, Haliwa Saponi Tribe, Request for Comments 

Concerning the Shearon Harris Nuclear Power Plant License Renewal 

Application Review. (Accession No. ML070230098) 

March 20, 2007 Letter to M. Hicks, Eastern Band of Cherokee, Request for Comments 

Concerning the Shearon Harris Nuclear Power Plant License Renewal 

Application Review. (Accession No. ML070230127) 

March 20, 2007 Letter to J. Goins, Lumbee Tribe of North Carolina, Request for 

Comments Concerning the Shearon Harris Nuclear Power Plant 

License Renewal Application Review. (Accession No. ML070230142) 

March 20, 2007 Letter to G. Faircloth, Coharie Tribe, Request for Comments 

Concerning the Shearon Harris Nuclear Power Plant License Renewal 

Application Review. (Accession No. ML070230167) 

March 21, 2007 NRC press release announcing the Hearing Opportunity and Intent to 

Develop Environmental Report on Harris Nuclear Plant License 

Renewal. (Accession No. ML070800277) 

March 27, 2007 Letter to S. Hamilton, U.S. Fish and Wildlife Service Southeast 

Regional Office, Request for List of Protected Species Within the Area 

Under Evaluation for the Shearon Harris Nuclear Power Plant License 

Renewal Application Review. (Accession No. ML070220281) 

March 27, 2007 Letter to L. Pearsall, North Carolina Natural Heritage Program, 

Request for List of State Protected Species Within the Area Under 

Evaluation for the Shearon Harris Nuclear Power Plant License 

Renewal Application Review. (Accession No. ML070220337) 

March 27, 2007 Letter to R. Duncan, CP&L, Request for Additional Information 

Regarding Severe Accident Mitigation Alternatives for Shearon Harris 

Nuclear Power Plant. (Accession No. ML070740160) 
Appendix C 

NUREG-1437, Supplement 33 C-4 August 2008 

March 28, 2007 Letter to R. Duncan, CP&L, Notice of Intent to Prepare an 

Environmental Impact Statement and Conduct Scoping Process for 

License Renewal for the Shearon Harris Nuclear Power Plant.

(Accession No. ML063600250) 

April 11, 2007 NRC press release announcing public meetings to discuss the license 

renewal review process for and to solicit public comments on the 

scope of the environmental review for Shearon Harris (Accession 

No. ML071010055) 

April 12, 2007 Summary of telephone conference call held on March 27, 2007, 

between NRC and CP&L, concerning draft request for additional 

information pertaining to Shearon Harris Nuclear Power Plant.

(Accession No. ML070930289) 

April 15, 2007 Letter from R. Williams, concerning the Shearon Harris Nuclear Power 

Plant license renewal application. (Accession No. ML071210160) 

April 18, 2007 Letter from L. Cullington, Comments on Shearon Harris License 

Renewal Environmental Scoping. (Accession No. ML071150313) 

April 18, 2007 Letter from B. Duncan, Comment concerning the Shearon Harris 

Nuclear Power Plant license renewal application. (Accession No. 

ML071210163)

April 18, 2007 Meeting Transcript for Shearon Harris, Unit 1, License Renewal Public 

Meeting Afternoon Session (Accession Nos. ML071300371) 

April 18, 2007 Meeting Transcript for Shearon Harris, Unit 1, License Renewal Public 

Meeting Evening Session (Accession Nos. ML071300377) 

April 26, 2007 Letter from H. LeGrand, North Carolina State Natural Heritage 

Program, Renewal of Operating License for the Shearon Harris 

Nuclear Power Plant, Wake and Chatham Counties. (Accession Nos. 

ML071280403)

April 27, 2007 Letter to K. O’Daly, West Regional Library, regarding the maintenance 

of reference material at the West Regional Library, related to the 

review of the Shearon Harris Nuclear Power Plant license renewal 

application. (Accession No. ML071140313) 
Appendix C 

August 2008 C-5 NUREG-1437, Supplement 33 

May 2, 2007 Letter from C.D. Vaughn, Advisory Council on Historic Preservation, 

Notification pursuant to 36 CFR 800.8(c), Proposed Shearon Harris 

Nuclear Power Plant License Renewal Wake County, North Carolina.

(Accession Nos. ML071300272) 

May 10, 2007 Letter from T. Natale, CP&L, Response to Request for Additional 

Information Regarding Severe Accident Mitigation Alternatives for 

Shearon Harris Nuclear Power Plant. (Accession Nos. ML071410135) 

May 14, 2007 Summary of Public Meetings Related to the Review of the Shearon 

Harris Nuclear Power Plant License Renewal Application. (Accession 

No. ML071200434) 

May 21, 2007 Letter to R. Duncan, CP&L, Environmental Site Audit Regarding 

Shearon Harris Nuclear Power Plant License Renewal Application.

(Accession No. ML071360138) 

June 25, 2007 Summary of Telephone Conference Call 6-13-2007, Between NRC 

and CP&L, Concerning SAMA Analysis of the Shearon Harris Nuclear 

Power Plant License Renewal Application. (Accession No. 

ML071690054)

July 06, 2007 Summary of Site Audit Related to the Review of the License Renewal 

Application for Shearon Harris Nuclear Power Plant, Unit 1.

(Accession No. ML071700428) 

July 12, 2007 Letter to R. Duncan, CP&L, Request for Additional Information 

Regarding the Environmental Review for Shearon Harris Nuclear 

Power Plant License Renewal Application. (Accession No. 

ML071660322)

August 08, 2007 Letter from C. Burton, CP&L, Response to Request for Additional 

Information Regarding the Environmental Review for Shearon Harris 

Nuclear Power Plant License Renewal Application. (Accession No. 

ML072290474)

August 09, 2007 Letter to R. Duncan, CP&L, Environmental Scoping Summary Report 

Associated with the Staff’s Review of the Shearon Harris Nuclear 

Power Plant License Renewal Application. (Accession No. 

ML071980184 and ML071980195) 
Appendix C 

NUREG-1437, Supplement 33 C-6 August 2008 

August 27, 2007 Letter from T. Natale, CP&L, Documentation of Changes to Severe 

Accident Mitigation Analysis for Shearon Harris Nuclear Power Plant 

License Renewal Application. (Accession No. ML072490033) 

October 05, 2007 Letter from C. Burton, CP&L, Discussion of the Impact of Errors in the 

SECPOP2000 Computer Code on the Severe Accident Mitigation 

Alternatives Analysis for Shearon Harris Nuclear Power Plant License 

Renewal. (Accession No. ML072840455) 

October 31, 2007 Docketing of Email Communication Between USNRC and Progress 

Energy Staff, Related to the Environmental Review of the Shearon 

Harris Nuclear Power Plant License Renewal Application. (Accession 

No. ML072960078) 

December 10, 2007 Letter to R. Duncan, CP&L, Notice of Availability of the Draft PlantSpecific Supplement 33 to the Generic Environmental Impact 

Statement regarding Shearon Harris Nuclear Power Plant. (Accession 

No. ML073200665) 

December 10, 2007 Letter to US EPA, Official SEIS filing with the U.S. Environmental 

Protection Agency, regarding Shearon Harris Nuclear Power Plant.

(Accession No. ML073300494) 

December 26, 2007 NRC press release announcing availability of Draft Environmental 

Impact Statement for Shearon Harris Nuclear Power Plant

(Accession No. ML073600361) 

January 14, 2008 NRC Notice, announcing meeting to discuss the draft supplemental 

environmental impact statement for the license renewal of Shearon 

Harris Nuclear Power Plant (Accession No. ML073601005) 

February 27, 2008 Summary of public meetings on the Draft Supplemental Environmental 

Impact Statement regarding the Shearon Harris Nuclear Power Plant 

License Renewal Review (Accession No. ML080460480) 
Appendix D 

Organizations Contacted 

August 2008 D-1 NUREG-1437, Supplement 33 

Appendix D: Organizations Contacted 

During the course of the U.S. Nuclear Regulatory Commission staff’s independent review of 

environmental impacts from operations during the renewal term, the following Federal, State 

and local agencies, and Native American Tribal agencies were contacted: 

Advisory Council on Historic Preservation, Washington, DC 

Coharie Tribe, Clinton, NC 

Eastern Band of Cherokee, Cherokee, NC 

Haliwa Saponi Tribe, Hollister, NC 

Lumbee Tribe of North Carolina, Red Spring, NC 

Meherrin Indian Tribe, Ahoskie, NC 

North Carolina Department of Environment and Natural Resources, Raleigh, NC 

North Carolina Natural Heritage Program, Raleigh NC 

North Carolina State Historic Preservation Office, Raleigh, NC 

North Carolina Wildlife Resources Commission, Raleigh NC 

Town of Apex, NC 

Town of Fuquay Varina, NC 

Town of Holly Springs, NC 

U.S. Fish and Wildlife Service, Southeast Regional Office, Atlanta, GA 

Appendix E 

Compliance Status and Consultation Correspondence 

August 2008 E-1 NUREG-1437, Supplement 33 

Appendix E: 

 Compliance Status and Consultation Correspondence

Consultation correspondence related to the evaluation of the application for renewal of the 

operating license for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) is identified in 

Table E-1. Copies of the consultation correspondence are included at the end of this appendix. 

The licenses, permits, and other approvals obtained from Federal, State, regional, and local 

authorities for HNP, are listed in Table E-2. 

Table E-1. Consultation Correspondence 

Source Recipient Date of Letter 

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

Advisory Council on Historic 

Preservation (D.L. Kilma) 

March 20, 2007 

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

North Carolina State Historic 

Preservation Office (J. Crow) 

March 20, 2007 

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

Meherrin Indian Tribe (T. Lewis) March 20, 2007(a)

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

Haliwa Saponi Tribe (R. Richardson) March 20, 2007(a)

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

Eastern Band of Cherokee 

(M. Hicks) 

March 20, 2007(a)

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

Lumbee Tribe of North Carolina 

(J. Goins) 

March 20, 2007(a)

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

Coharie Tribe (G. Faircloth) March 20, 2007(a)

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

U.S. Fish and Wildlife Service 

Southeast Regional Office 

(S. Hamilton) 

March 27, 2007 

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

North Carolina Natural Heritage 

Program (L. Pearsall) 

March 27, 2007 

North Carolina Natural Heritage 

Program (H. LeGrand) 

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

April 26, 2007 

Advisory Council on Historic 

Preservation (C.D. Vaughn) 

U.S. Nuclear Regulatory 

Commission (R. Franovich) 

May 2, 2007 

North Carolina Department of 

Administration (C. Baggett) 

U.S. Nuclear Regulatory 

Commission (S. Hernandez) 

December 18, 2007 

U.S. Department of Commerce 

(M.M. Croom) 

U.S. Nuclear Regulatory 

Commission (S. Hernandez) 

February 27, 2008 
NUREG-1437, Supplement 33 E-2 August 2008 

Source Recipient Date of Letter 

U.S. Environmental Protection 

Agency (H.J. Mueller) 

U.S. Nuclear Regulatory 

Commission 

March 3, 2008 

U.S. Department of the Interior 

(G. Hogue) 

U.S. Nuclear Regulatory 

Commission 

March 5, 2008 

North Carolina Department of 

Administration (C. Baggett) 

U.S. Nuclear Regulatory 

Commission (S. Hernandez) 

March 7, 2008 

(a) Similar letters were sent to listed Indian Nations. 
Appendix E 

August 2008 E-3 NUREG-1437, Supplement 33 

Table E-2. Federal, State, Local, and Regional Licenses, Permits, and 

Other Approvals for the Shearon Harris Nuclear Power Plant (HNP) 

Agency Authority Requirement Number Expiration Date Authorized Activity U.S. Nuclear Regulatory Commission

Atomic Energy Act, 10 CFR 50 

License to operate NPF-63 October 24, 2026 Authorization to operate HNP. 

U.S. Department of Transportation 

49 CFR 5108 Hazardous Materials 

Shipment Certificate of Registration 

060707 551 070P June 30, 2008 Authorization to ship hazardous 

materials.

U.S. Fish and Wildlife Service 

16 USC 703-712 Federal Fish and Wildlife 

Permit, Depredation 

MB789112-0 March 31, 2008 Removal and recollection of 

migratory bird nests. 

NC Department of Environment and Natural Resources

NC General Statute 143-215.1 

National pollutant Discharge Elimination System Permit 

NC0039586 July 31, 2011 Permit to discharge 

wastewaters to waters of the State.

NC Department of Environment and Natural Resources

NC General Statute Article 21B Chapter 143

Air Permit 08455R04 February 29, 2012 Air emissions for boilers and 

emergency generators source operations. 

NC Department of Environment and Natural Resources

NC General Statute Title 15A Subchapter 2N, Section 0300 

Underground Storage Tank Operating Permit 

0-006715 December 31, 2007 Authorization to operate 

underground storage tank. 

NC Wildlife ResourcesCommission

NC General Statute 113-274(c)(1)(a) Title 15A Subchapter 10B.0106 

Special Migratory Bird Permit

 December 31, 2007 Removal and relocation of 

migratory bird nests. 
Appendix E 

Agency Authority Requirement Number ExNUREG-1437, Supplement 33 E-4 August 2008 

piration Date Authorized Activity 

South Carolina Department of Health and Environmental Control 

South Carolina Radioactive Waste Transportation and Disposal Act (Act No. 429) 

South Carolina Radioactive Waste Transport Permit 

0324-32-07-X December 31, 2007 Transportation of radioactive 

materials into the State of South Carolina. 

Tennessee Department of Environment and Conservation 

Tennessee Department of Environment and Conservation Rule 1200-2-10.32 

Tennessee Radioactive Waste License for Delivery 

T-NC002-L07 December 31, 2007 Transportation of radioactive 

materials into the State of Tennessee 
 Appendix E

August 2008 E-5 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-6 August 2008 
 Appendix E

August 2008 E-7 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-8 August 2008 
 Appendix E

August 2008 E-9 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-10 August 2008 
 Appendix E

August 2008 E-11 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-12 August 2008 
 Appendix E

August 2008 E-13 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-14 August 2008 
 Appendix E

August 2008 E-15 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-16 August 2008 
 Appendix E

August 2008 E-17 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-18 August 2008 
 Appendix E

August 2008 E-19 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-20 August 2008 
 Appendix E

August 2008 E-21 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-22 August 2008 
 Appendix E

August 2008 E-23 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-24 August 2008 
 Appendix E

August 2008 E-25 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-26 August 2008 
 Appendix E

August 2008 E-27 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-28 August 2008 
 Appendix E

August 2008 E-29 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-30 August 2008 
 Appendix E

August 2008 E-31 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-32 August 2008 
 Appendix E

August 2008 E-33 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-34 August 2008 
 Appendix E

August 2008 E-35 NUREG-1437, Supplement 33 
Appendix E 

NUREG-1437, Supplement 33 E-36 August 2008 
 Appendix E

August 2008 E-37 NUREG-1437, Supplement 33 

Appendix F 

GEIS Environmental Issues Not Applicable

to Shearon Harris Nuclear Power Plant, Unit 1 

August 2008 F-1 NUREG-1437, Supplement 33 

Appendix F: GEIS Environmental Issues Not Applicable 

to Shearon Harris Nuclear Power Plant, Unit 1 

Table F-1 lists those environmental issues identified in the Generic Environmental Impact 

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

(NRC 1996; 1999),(a) and Title 10 of the Code of Federal Regulations, Part 51 (10 CFR 

Part 51), Subpart A, Appendix B, Table B-1, that are not applicable to Shearon Harris Nuclear 

Power Plant, Unit 1 (HNP) because of plant or site characteristics. 

Table F-1. GEIS Environmental Issues Not Applicable 

to Shearon Harris Nuclear Power Plant, Unit 1 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 Category

GEIS

Sections Comment 

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered salinity gradients 1 4.2.1.2.2 The HNP heat-dissipation system 

does not discharge to an estuary. 

Water-use conflicts (plants with oncethrough cooling systems) 

1 4.2.1.3 Once-through cooling system is a 

feature not applicable at the HNP. 

Water-use conflicts (plants with cooling 

ponds or cooling towers using make-up 

water from a small river with low flow) 

2 4.3.2.1;

4.4.2.1

The HNP cooling system does not 

use make-up water from a small river 

with low flow, and the cooling pond 

heat-dissipation system is not 

applicable at the HNP. 

AQUATIC ECOLOGY (FOR PLANTS WITH ONCE-THROUGH AND COOLING POND HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life 

stages for plants with once-through and 

cooling pond heat dissipation systems 

2 4.2.2.1.2 Once-through heat-dissipation 

systems is a feature not applicable at 

the HNP. 

Impingement of fish and shellfish 2 4.2.2.1.3 Once-through heat-dissipation 

systems is a feature not applicable at 

the HNP. 

Heat shock 2 4.2.2.1.4 Once-through heat-dissipation 

systems is a feature not applicable at 

the HNP. 

 

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all 

references to the “GEIS” include the GEIS and its Addendum 1. 
Appendix F 

NUREG-1437, Supplement 33 F-2 August 2008 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 Category

GEIS

Sections Comment 

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and 

service water, and dewatering; plants that 

use > 100 gpm) 

2 4.8.1.1;

4.8.1.2

HNP does not use more than 100 

gallons per minute of groundwater. 

Groundwater use conflicts (plants using 

cooling towers withdrawing make-up water 

from a small river) 

2 4.8.1.3 HNP does not withdraw cooling tower 

make-up water from a small river. 

Groundwater-use conflicts (Ranney wells) 2 4.8.1.4 HNP does not have or use Ranney 

wells. 

Groundwater quality degradation (Ranney 

wells) 

1 4.8.2.2 HNP does not have or use Ranney 

wells. 

Groundwater quality degradation (saltwater 

intrusion) 

1 4.8.2.1 The HNP cooling system does not 

withdraw groundwater from an 

estuary or an oceanic area. 

Groundwater quality degradation (cooling 

ponds in salt marshes) 

1 4.8.3 This issue is related to cooling pond 

heat-dissipation system which is not 

applicable at HNP. 

Groundwater quality degradation (cooling 

ponds at inland sites) 

2 4.8.3 This issue is related to cooling pond 

heat-dissipation system which is not 

applicable at HNP. 

TERRESTRIAL RESOURCES

Cooling pond impacts on terrestrial 

resources 

1 4.4.4 This issue is related to cooling pond 

heat-dissipation system which is not 

applicable at HNP. 

HUMAN HEALTH

Microbial organisms (public health) (plants 

using lakes or canals, or cooling towers or 

cooling ponds that discharge to a small 

river). 

2 4.3.6 The HNP heat-dissipation system 

does not discharge to a small river. 

F.1 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

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

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

August 2008 F-3 NUREG-1437, Supplement 33 

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

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

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.

NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

Appendix G 

NRC Staff Evaluation of Severe Accident Mitigation Alternatives 

(SAMAs) for Shearon Harris Nuclear Power Plant, Unit 1 

August 2008 G-1 NUREG-1437, Supplement 33

Appendix G 

U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for Shearon Harris Nuclear Plant in Support of the License Renewal Application Review

G.1 Introduction 

Carolina Power and Light Company (CP&L), now doing business as Progress Energy Carolinas, 

Inc., submitted an assessment of severe accident mitigation alternatives (SAMAs) for Shearon 

Harris Nuclear Plant (HNP) as part of the environmental report (ER) (Progress Energy 2006). 

This assessment was based on the most recent HNP probabilistic safety assessment (PSA) 

available at that time, a plant-specific offsite consequence analysis performed using the 

MELCOR Accident Consequence Code System 2 (MACCS2) computer code, and insights from 

the HNP individual plant examination (IPE) (CP&L 1993) and the individual plant examination of 

external events (IPEEE) (CP&L 1995). In identifying and evaluating potential SAMAs, HNP 

considered SAMAs that addressed the major contributors to core damage frequency (CDF) and 

population dose at HNP, as well as SAMA candidates for other operating plants which have 

submitted license renewal applications. CP&L identified 22 potential SAMA candidates. This 

list was reduced to 20 unique SAMAs by eliminating SAMAs that are not applicable to the HNP 

design, or have estimated costs that would exceed the dollar value associated with completely 

eliminating all severe accident risk at HNP. CP&L assessed the costs and benefits associated 

with each of the potential SAMAs and concluded in the ER that several of the candidate SAMAs 

evaluated are potentially cost-beneficial. 

Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 

issued a request for additional information (RAI) to CP&L by letter dated March 27, 2007 (NRC 

2007). Key questions concerned: additional details regarding the plant-specific probabilistic 

safety assessment (PSA) model and changes to the model since the IPE; justification for the 

multiplier used for external events; the plant-specific reactor core inventory and meteorology 

data used in the offsite consequence analysis; and further information on several specific 

candidate SAMAs and low cost alternatives. CP&L submitted additional information by letter 

dated May 10, 2007 (Progress Energy 2007a). In response to the RAIs, CP&L provided: 

information regarding PSA models and recent changes; additional justification for the treatment 

of external events; clarification regarding the reactor core inventory and meteorological data; 

and additional information regarding several specific SAMAs. CP&L’s responses addressed the 

NRC staff’s concerns. 

An assessment of SAMAs for HNP is presented below. 
Appendix G 

NUREG-1437, Supplement 33 G-2 August 2008 

G.2 Estimate of Risk for Shearon Harris Nuclear Plant 

CP&L's estimates of offsite risk at the HNP are summarized in Section G.2.1. The summary is 

followed by the NRC staff's review of CP&L’s risk estimates in Section G.2.2. 

G.2.1 CP&L’s Risk Estimates 

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 

analysis: (1) the HNP Level 1 and 2 PSA model, which is an updated version of the IPE (CP&L 

1993), and (2) a supplemental analysis of offsite consequences and economic impacts 

(essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA 

analysis is based on the most recent HNP Level 1 and 2 PSA model available at the time of the 

ER, referred to as the Model of Record 2005 (i.e., the MOR2005 model). The scope of the HNP 

PSA does not include external events. 

The baseline CDF for the purpose of the SAMA evaluation is approximately 9.24 x 10-6 per year.

The CDF is based on the risk assessment for internally-initiated events, which includes internal 

flooding. CP&L did not include the contribution from external events within the HNP risk 

estimates; however, it did account for the potential risk reduction benefits associated with 

external events by doubling the estimated benefits for internal events. This is discussed further 

in Sections G.2.2 and G.6.2. 

The breakdown of CDF by initiating event is provided in Table G-1. As shown in this table, 

events initiated by loss of offsite power (LOOP) and internal flooding are the dominant 

contributors to CDF. Although not separately reported, station blackout (SBO) sequences 

contribute roughly 2.2 x 10-6 per year (24 percent of the total internal events CDF), while 

anticipated transient without scram (ATWS) sequences contribute 2.3 x 10-7 per year (about 

2 percent of the total internal events CDF). 

The current Level 2 HNP PSA is based on the IPE model with updates to reflect changes to the 

plant due to a 4.5 percent power uprate and steam generator replacement, and minor changes 

to some inputs. The model utilizes a Containment Safeguards Event Tree (CSET) and a 

Containment Event Tree (CET) that address both systemic and phenomenological events. The 

significant Level 1 core damage sequences were processed using the CSET to determine the 

applicable endstates and their frequencies. The CSET derived endstates were used as input 

into the CET in order to determine the containment response. The CET has 14 possible 

endstates which provide information about accident sequence progression, containment status, 

and source term release. The frequency of each release category was obtained by summing 

the frequency of the individual accident progression CET endpoints into the release category. 

The release characteristics for the release categories are based on updated Modular Accident 
Appendix G 

August 2008 G-3 NUREG-1437, Supplement 33 

Analysis Program (MAAP) analyses that reflect the revised HNP configuration (Progress Energy 

2007a).

Table G-1. HNP Core Damage Frequency 

Initiating Event CDF

(Per Year) 

% Contribution 

to CDF 

Loss of Offsite Power 2.8 x 10-6 30 

Internal Floods 1.6 x 10-6 17 

LOCA 1.3 x 10-6 14 

Loss of AC Bus 9.2 x 10-7 10 

Steam Generator Tube Rupture 8.3 x 10-7 9 

Reactor Trip 4.6 x 10-7 5 

Loss of Feedwater 4.6 x 10-7 5 

Loss of Instrument Air 3.7 x 10-7 4 

Spurious ESFAS 2.8 x 10-7 3 

Interfacing System LOCA 1.9 x 10-7 2 

Other 9.2 x 10-8 1 

Total CDF (internal events) 9.24 x 10-6 100 

The offsite consequences and economic impact analyses use the MACCS2 code to determine 

the offsite risk impacts on the surrounding environment and public. Inputs for these analyses 

include plant-specific and site-specific input values for core radionuclide inventory, source term 

and release characteristics, site meteorological data, projected population distribution (within an 

80-kilometer (50-mile) radius) for the year 2040, emergency response evacuation modeling, and 

economic data. The magnitude of the onsite impacts (in terms of clean-up and decontamination 

costs and occupational dose) is based on information provided in NUREG/BR-0184 (NRC 

1997a).

In the ER, CP&L estimated the dose to the population within 80 kilometers (50 miles) of the 

HNP site to be approximately 0.290 person-sievert (Sv) (29.0 person-rem) per year. The 

breakdown of the total population dose by containment release mode is summarized in 

Table G-2. Containment bypass failures such as a steam generator tube rupture (SGTR) 

accident with a stuck open safety relief valve (SRV) on the ruptured steam generator or an 

unmitigated interfacing-systems loss of coolant accident (ISLOCA) dominate the contributions to 

the population dose risk at HNP. 
Appendix G 

NUREG-1437, Supplement 33 G-4 August 2008 

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

Containment Release Mode 

Population Dose 

(Person-Rem1 Per Year) 

%

Contribution 

Containment Intact 0 0 

Late Containment Failure without scrubbing 0.9 3 

Large Early Containment Failure without scrubbing 0.1 0 

Small Containment Bypass (SGTR or mitigated 

inter-system LOCA) with scrubbing 

0.4 1 

Large Containment Bypass (SGTR with stuck open 

SRV, ruptured SG or unmitigated ISLOCA) with 

scrubbing 

5.4 19 

Large Containment Bypass (SGTR with stuck open 

SRV, ruptured SG or unmitigated ISLOCA) without 

scrubbing 

19.9 69 

Very Late Containment Failure (basemat melt 

through) 

0.2 1 

Very Late Containment Failure (over pressurization) 1.9 7 

Total 29 100 

1

One person-Rem = 0.01 person-Sv 

G.2.2 Review of CP&L’s Risk Estimates 

CP&L’s determination of offsite risk at HNP is based on the following three major elements of 

analysis:

• The Level 1 and Level 2 risk models that form the bases for the 1993 IPE submittal 

(CP&L 1993), and the external events analyses of the 1995 IPEEE submittal (CP&L 

1995),

• The major modifications to the IPE model that have been incorporated in the HNP 2005 

PSA Update, and 

• The MACCS2 analyses performed to translate fission product source terms and release 

frequencies from the Level 2 PSA model into offsite consequence measures. 

Each of these analyses was reviewed to determine the acceptability of CP&L’s risk estimates for 

the SAMA analysis, as summarized below. 
Appendix G 

August 2008 G-5 NUREG-1437, Supplement 33 

The NRC staff's review of the HNP IPE is described in an NRC report dated January 26, 1996 

(NRC 1996). Based on a review of the IPE submittal and responses to RAIs, the NRC staff 

concluded that the IPE submittal met the intent of Generic Letter (GL) 88-20; that is, the 

licensee’s IPE process is capable of identifying the most likely severe accidents and severe 

accident vulnerabilities. The IPE did not identify any severe accident vulnerabilities associated 

with either core damage or poor containment performance. 

Although no vulnerabilities were identified in the IPE, several improvements to the plant or 

procedures were identified. These improvements have been either implemented at the site, or 

addressed by a SAMA in the current evaluation (Progress Energy 2006). 

There have been six revisions to the IPE model since the 1993 IPE submittal. A comparison of 

the internal events CDF between the 1993 IPE submittal and the current PSA model 

(MOR2005) indicates a decrease of approximately 87 percent (from 7 x 10-5 per year to 9.24 x 

10-6 per year), with most of the reduction occurring in the 2003 and 2005 updates. A description 

of those changes that resulted in the greatest impact on the internal events CDF was provided 

in Section E.2 of the ER, and is summarized in Table G-3. 

Table G-3. HNP PSA Historical Summary 

PSA

Version Summary of Changes from Prior Model 

CDF

(per year) 

1993 IPE Submittal (Internal Flooding Contribution 5 x 10-6) 7.0 x 10-5

MOR1995 1995 PSA Update 

- Added CSIP pump alternate minimum flow lines 

- Installed rotary instrument air compressor 

- Installed isolation valves in the RHR pump recirculation lines to the 

RWST

- Added the requirement for the operation of one-of-three pressurizer 

PORVs for the bleed function of feed and bleed cooling for small 

LOCAs, seal LOCAs and unisolated SGTR 

- Added several system and initiating event fault tree models 

- Updated initiating event frequencies, LOOP recovery probabilities, 

and plant specific reliability and availability data 

- Re-assessed operator actions to provide more realistic human error 

probabilitieis (HEPs), improve consistency, and remove 

conservatisms 

6.2 x 10-5
Appendix G 

NUREG-1437, Supplement 33 G-6 August 2008 

PSA

Version Summary of Changes from Prior Model 

CDF

(per year) 

MOR1998 1998 PSA Update 

- Removed credit for refilling the RWST following a failure of 

recirculation for S1 LOCAs and transient induced LOCAs 

- Added credit to TQ LOCA and S1 LOCA event tree logic to take credit 

for rapid cooldown and depressurization 

- Updated the S1 LOCA and TQ LOCA event trees with a new gate that 

allowed for RHR operation without CCW cooling 

- Implemented rule based recovery of offsite power 

- Added turbine trip initiating as input to the loss of condenser cooling 

- Updated transient initiating event categories without plant-specific 

initiating event system models 

5.0 x 10-5

MOR2000 2000 PSA Update 

- Revised the instrument air fault tree model and support systems to 

reflect the replacement of the four reciprocating instrument air 

compressors with two rotary air compressors 

- Added a new Loss of Instrument Air initiating event fault tree to 

replace the single point estimate basic event 

- Revised the demineralized water system model to capture procedural 

changes requiring the normal position of the RWST supply valve to 

be normally closed 

- Revised operator actions as part of the procedure reviews to improve 

overall consistency and documentation quality 

5.0 x 10-5

MOR2001 2001 PSA Update 

- Incorporated changes to reflect the SG replacement and power 

uprate modifications 

- Removed credit for RWST makeup from SGTR sequences that 

included a loss of secondary side heat removal 

- Revised plant specific ISLOCA initiating event tree to include operator 

intervention for smaller break sizes 

- Expanded common-cause failure analysis in the CCW initiating event 

tree to include the swing pump credit 

- Updated transient and SGTR initiating event frequencies, LOOP 

recovery probabilities, and plant specific reliability and availability 

data

4.9 x 10-5
Appendix G 

August 2008 G-7 NUREG-1437, Supplement 33 

PSA

Version Summary of Changes from Prior Model 

CDF

(per year) 

MOR2003 2003 PSA Update 

- Implemented the Rhodes seal LOCA model to replace the 

NUREG/CR-4550 model 

- Incorporated the most recent Westinghouse guidance on modeling 

SGTR and ATWS sequences 

- Added the potential for containment sump clogging 

- Updated common-cause analysis 

- Updated ISLOCA analysis 

- Added credit for local operation of TDAFW pump when B Train DC 

power is unavailable based on plant procedures 

- Updated transient initiating event frequencies, LOOP recovery 

probabilities, and plant specific reliability and availability data 

2.5 x 10-5

MOR2005 2005 PSA Update 

- Updated human reliability analysis 

- Updated the LOSP recovery analysis to reflect the change to the 

WOG2000 Seal LOCA model 

- Updated the internal flooding analysis 

- Removed credit for cool-down/depressurization with secondary side 

heat removal going on shutdown cooling with no LPI/HHSI 

- Updated common-cause failure events in accordance with 

NUREG/CR-5497

- Updated data for several valves to reflect demand failure rates 

9.2 x 10-6

The CDF value from the 1993 HNP IPE submittal (7.0 x 10-5 per year) is at the low end of the 

range of the CDF values reported in the IPEs for Westinghouse three-loop plants. Figure 11.6 

of NUREG-1560 shows that the IPE-based total internal events CDF for three-loop 

Westinghouse plants ranges from 7 x 10-5 per year to 4 x 10-4 per year (NRC 1997b). It is 

recognized that other plants have updated the values for CDF subsequent to the IPE submittals 

to reflect modeling and hardware changes. The current internal events CDF result for HNP 

(9.24 x 10-6 per year) is lower than that for other plants of similar vintage and characteristics. 

The NRC staff considered the peer reviews performed for the HNP PSA, and the potential 

impact of the review findings on the SAMA evaluation. In the ER and in response to an NRC 

staff RAI (Progress Energy 2007a), CP&L described the peer review by the Westinghouse 

Owner’s Group (WOG) of the 2001 PSA Model conducted in June 2002. The peer review 

identified two Level A and 27 Level B Facts & Observations (F&Os) (Progress Energy 2007). 
Appendix G 

NUREG-1437, Supplement 33 G-8 August 2008 

CP&L states that all Level A F&Os (important and necessary to address before the next regular 

PSA update) and Level B F&Os (important and necessary to address but disposition may be 

deferred until the next PSA update) have been dispositioned, and that those requiring model 

and/or documentation changes have been addressed with the issuance of MOR2005 (Progress 

Energy 2006 and 2007a). 

Given that the HNP internal events PSA model has been peer-reviewed and the peer review 

findings were all addressed, and that CP&L has satisfactorily addressed NRC staff questions 

regarding the PSA, the NRC staff concludes that the internal events Level 1 PSA model is of 

sufficient quality to support the SAMA evaluation. 

As indicated above, the current HNP PSA does not include external events. In the absence of 

such an analysis, CP&L used the HNP IPEEE to identify the highest risk accident sequences 

and the potential means of reducing the risk posed by those sequences, as discussed below. 

The HNP IPEEE was submitted in June 1995 (CP&L 1995), in response to Supplement 4 of 

Generic Letter 88-20 (NRC 1991). This submittal included a seismic margins analysis, a fire 

PSA, and a screening analysis for other external events. While no fundamental weaknesses or 

vulnerabilities to severe accident risk in regard to the external events were identified, several 

opportunities for seismic and fire risk reduction were identified as discussed below. In a letter 

dated January 14, 2000, the NRC staff concluded that the submittal met the intent of 

Supplement 4 to Generic Letter 88-20, and that the licensee’s IPEEE process is capable of 

identifying the most likely severe accidents and severe accident vulnerabilities (NRC 2000). 

The HNP IPEEE used a focused scope Electric Power Research Institute (EPRI) seismic 

margins analysis. This method is qualitative and does not provide numerical estimates of the 

CDF contributions from seismic initiators (EPRI 1991). For this assessment, a detailed 

walkdown was performed in which components were screened using an overall high confidence 

of low probability of failure (HCLPF) capacity of 0.3g, the review level earthquake (RLE) value 

for the plant, and the screening level that would be used for a focused-scope plant. The ER 

states that not all of the Safe Shutdown Equipment in the plant was initially determined to meet 

the HCLPF requirements for the 0.30g peak ground acceleration (pga) RLE. Following 

additional evaluation by CP&L, most of the remaining equipment was found to meet the HCLPF 

capacity of 0.3g and the few remaining components are addressed by a candidate SAMA that 

evaluates increasing their seismic capacity. 

The HNP IPEEE fire analysis employed a combination of probabilistic risk analysis with Electric 

Power Research Institute’s fire-induced vulnerability evaluation (FIVE) methodology. The 

evaluation was performed in four phases: (1) qualitative screening, (2) quantitative screening, 

(3) fire damage evaluation screening, and (4) fire scenario evaluation and quantification. Each 

phase focused on those fire areas that did not screen out in the prior phases. The final phase 

involved using the IPE model for internal events to quantify the CDF resulting from a fireinitiating event. The CDF for each area was obtained by multiplying the frequency of a fire in a 
Appendix G 

August 2008 G-9 NUREG-1437, Supplement 33 

given fire area by the conditional core damage probability associated with that fire area 

including, where appropriate, the impact of fire suppression and fire propagation. In most 

cases, it was assumed that all equipment in the area was damaged by the fire. The potential 

impact on containment performance and isolation was evaluated following the core damage 

evaluation. In response to an RAI on some potential weaknesses noted in the staff’s evaluation 

of the IPEEE fire analysis, CP&L provided supporting documentation that addressed concerns 

associated with the screening of fire areas, and the control room and cable spreading room fire 

ignition frequencies (Progress Energy 2007a). 

The total fire CDF from the IPEEE was estimated to be 1.1 x 10-5 per year (CP&L 1995). The 

dominant fire areas and their contributions to the fire CDF are listed in Table G-4. 

Table G-4. Fire Areas and their Contribution to Fire CDF 

Fire Area Major Equipment Failed 

CDF

(per year) 

1-A-SWGRB/1 1B-SB AC Emergency Bus (plus other minor 

contributors) 

1.1 x 10-6

1A-SWGRB/2 Entire “B“ division safe shutdown path, offsite power 

to 1ASA without successful operator action. 

2.8 x 10-6

1-A-SWGRA/FDS ASG1 1A-SA AC Emergency Bus (plus other minor 

contributors) 

4.4 x 10-7

1-A-SWGRA/FDS ASG2 Entire “A“ division safe shutdown path 2.6 x 10-6

1-A-SWGRA/FDS ASG3 1A-SA AC Emergency Bus (plus other minor 

contributors), fire induced spurious open PORV 

7.6 x 10-8

12-A-CR/1D1 AFW SA/SB, CWS SA, EDG SB, ESW SA/SB, 

HCRC SB, HCRM SB, HDGB SB, RCSPC SB 

1.3 x 10-6

12-A-CR/6B No SSE damaged, but main control room evacuation 

and shutdown from the alternate control panel (ACP) 

are required. 

3.0 x 10-6

Total Fire CDF 1.1 x 10-5

In the ER, CP&L states that the use of the fire analysis results as a reflection of CDF may be 

inappropriate and that while the fire PSA is generally self-consistent within its calculational 

framework, the fire analysis does not compare well with internal events PSAs because of the 

number of conservative assumptions that have been included in the fire analysis process. The 
Appendix G 

NUREG-1437, Supplement 33 G-10 August 2008 

ER provides a list of fire analysis topics (involving technical inputs, data and modeling) that 

prevent the effective comparison of the CDF between the internal events PSA and the fire 

analysis. In response to an RAI requesting the applicability of the general topics to the HNP fire 

analysis (NRC 2007), CP&L provided several HNP-specific examples of conservatisms in the 

fire analysis, including: a factor of 6.5 reduction in the internal events CDF since the IPE that 

has not been incorporated into the fire CDF, potential reduction in fire ignition frequencies, 

conservative target fire damage assumptions, and conservative application of generic 

COMPBRN results (Progress Energy 2007a). Although arguments regarding the conservatisms 

in the fire analysis are presented in the ER and RAI responses, CP&L used the baseline fire 

CDF of 1.1 x 10-5 per year in the SAMA analysis rather than some reduced value. 

The IPEEE analysis of high winds, floods, and other external events followed the screening and 

evaluation approaches specified in NUREG/CR-4839 (NRC 1992) and did not identify any 

significant sequences or vulnerabilities (CP&L 1995). Based on this result, CP&L concluded 

that these other external hazards would not be expected to impact the conclusions of the SAMA 

analysis and did not consider specific SAMAs for these events. It is noted that the risks from 

deliberate aircraft impacts were explicitly excluded since this was being considered in other 

forums along with other sources of sabotage. 

Based on the aforementioned results, the external events CDF is approximately 1.4 times the 

internal events CDF (based on a fire CDF of 1.1 x 10-5 per year, a combined CDF from seismic, 

high wind, external flood, and transportation events CDF of 2 x 10-6 per year, and an internal 

events CDF of 9.24 x 10-6 per year). Accordingly, the total CDF from internal and external 

events would be approximately 2.4 times the internal events CDF. In the SAMA analysis 

submitted in the ER, CP&L doubled the benefit that was derived from the internal events model 

to account for the combined contribution from internal and external events. This doubling was 

not applied to the SAMA that specifically addresses seismic risk or to the fire risk portion of the 

two SAMAs where the impact on fire risk is determined separately. For the seismic SAMA, only 

the seismic benefit is estimated. For fire risk portion of the two fire related SAMAs, the fire 

benefit was explicitly calculated using an estimate derived from the IPEEE and a correlation 

between internal and external events. Doubling the benefit for these SAMAs is not appropriate 

since these SAMAs are specific to external events or, as in the case for the two fire-related 

SAMAs, have a targeted external event impact and would be underestimated if calculated using 

the doubling approach. In response to an RAI requesting justification for increasing the internal 

events CDF by only a factor of 2, CP&L provided arguments related to the conservative bias 

and modeling limitations of the fire analysis, and results of a sensitivity analysis that showed the 

outcome of the SAMA analysis is unchanged when the multiplier is increased from 2.0 to 2.4 

(Progress Energy 2007a). The NRC staff agrees with the licensee’s overall conclusion 

concerning the impact of external events and concludes that the licensee’s use of a multiplier of 

2.0 to account for external events is reasonable for the purposes of the SAMA evaluation. 

The NRC staff reviewed the general process used by CP&L to translate the results of the Level 

1 PSA into containment releases, as well as the results of the Level 2 analysis, as described in 
Appendix G 

August 2008 G-11 NUREG-1437, Supplement 33 

the ER and in response to NRC staff requests for additional information (Progress Energy 

2007a). The current Level 2 HNP PSA is based on the IPE model with updates to reflect 

changes to the plant due to a 4.5 percent power uprate and steam generator replacement, and 

minor changes to some inputs. The model utilizes a Containment Safeguards Event Tree 

(CSET) and a Containment Event Tree (CET) that address both systemic and 

phenomenological events. The significant Level 1 core damage sequences were processed 

using the CSET to determine the applicable endstates and their frequencies. The CSET 

derived endstates were used as input into the CET in order to determine the containment 

response. CP&L characterized the releases for the spectrum of possible radionuclide release 

scenarios using a set of 14 release categories, defined based on the timing and magnitude of 

the release and whether the containment remains intact or is bypassed. The frequency of each 

release category was obtained by summing the frequency of the individual accident progression 

CET endpoints into the release category. Source term release characteristics were developed 

for each release category based on results of plant-specific calculations using the Modular 

Accident Analysis Program (MAAP 3.0B) computer program. The release categories and their 

frequencies and release characteristics are presented in Table E.3-2 of the ER. All releases 

were modeled as occurring at ground level with an assumed thermal content of 1.0E+07 watts. 

CP&L assessed the impact of alternatively assuming an elevated release at a release height of 

66 meters (top of the plant stack). The results of these sensitivity studies showed that the 

elevated release produces about a 16 percent and 12 percent increase in population dose and 

the offsite economic cost risk, respectively (Progress Energy 2006). CP&L stated in the ER that 

using a ground level release is more realistic, given that the largest contributors to the release 

consequences are SGTR and ISLOCA events, which do not release through the plant stack. 

The NRC staff’s review of the Level 2 IPE concluded that it addressed the most important 

severe accident phenomena normally associated with large, dry containments, and identified no 

significant problems or errors (NRC 1996). In response to an RAI on the changes to the Level 2 

analysis since the IPE, CP&L stated that the MAAP input deck was updated to reflect the power 

uprate and steam generator replacement, and confirmatory analyses were made to ensure that 

existing Level 2 analyses were consistent with the revised plant configuration. However, the 

methodology and approach used in the Level 2 PSA continues to be based on the IPE model. 

Based on the NRC staff’s review of the Level 2 methodology and the fact that the Level 2 model 

was reviewed in more detail as part of the WOG peer review, the NRC staff concludes that the 

Level 2 PSA provides an acceptable basis for evaluating the benefits associated with various 

SAMAs.

As indicated in the ER, the reactor core radionuclide inventory used in the consequence 

analysis was derived from the plant’s safety analysis Table 15.0.9-1. In response to a request 

for additional information, the licensee indicated that the current HNP Capital Long Range Plan 

does not contain any projects that would substantially impact the plant-specific fuel burnup / 

management as the plant is expected to be operated during the renewal period (including power 

uprate). However, an Appendix K power uprate is planned that would cause only a 2 percent 

increase in core fission product inventory. 
Appendix G 

NUREG-1437, Supplement 33 G-12 August 2008 

The NRC staff reviewed the process used by CP&L to extend the containment performance 

(Level 2) portion of the PSA to an assessment of offsite consequences (essentially a Level 3 

PSA). This included consideration of the source terms used to characterize fission product 

releases for the applicable containment release categories and the major input assumptions 

used in the offsite consequence analyses. The MACCS2 code was utilized to estimate offsite 

consequences. Plant-specific input to the code includes the source terms for each release 

category and the reactor core radionuclide inventory (both discussed above), site-specific 

meteorological data, projected population distribution within an 80-kilometer (50-mile) radius for 

the year 2040, emergency evacuation modeling, and economic data. This information is 

provided in Attachment E of the ER. 

CP&L used site-specific meteorological data for the 2003 calendar year as input to the MACCS2 

code. The development of the meteorological data is discussed in Section E.3.5 of the ER and 

in response to an RAI (Progress Energy 2007a). The data were collected from the 

meteorological tower located 1.1 miles northeast of the reactor complex, with the base of the 

tower at approximately the plant grade level of 260 ft above main sea level. Data from 2001 

through 2005 were also considered, but the 2003 data was chosen because results of a 

MACCS2 sensitivity case indicated that the 2003 data produced more conservative results, i.e., 

about a 5 percent increase in economic cost risk over the 2005 data (Progress Energy 2007c). 

For instances where data were missing for brief periods or were invalid, the data were 

developed based on either interpolation or substitution using other onsite instruments or data 

from a nearby National Weather Service (NWS) or Federal Aviation Administration (FAA) 

observation location, or from the Raleigh-Durham airport (RDU) data. For longer stability data 

loss periods, RDU wind direction, cloud cover and ceiling height are used in conjunction with the 

time of day and time of year to derive a stability class. Hourly radar-derived precipitation 

estimates were used to confirm that hourly values from RDU are consistent at HNP or were 

adjusted according to the radar results (Progress Energy 2007a). The NRC staff concludes that 

the use of the 2003 meteorological data in the SAMA analysis is reasonable. 

The population distribution the licensee used as input to the MACCS2 analysis was estimated 

for the year 2040, based on the U.S. Census Bureau population data for 2000, as provided by 

the SECPOP 2000 program (NRC 2003), the 2000 county-level census data (USCB 2000) and 

state projections for the year 2030 (State of North Carolina 2005). The 2040 population was 

adjusted to account for transient population. The 2000 and 2030 census data were used to 

estimate the annual population growth rate. It was assumed that the growth rate would remain 

the same as the average rate projected between 2000 and 2030. The growth rate was derived 

assuming an exponential growth. Using sector-specific population growth rates, projections 

were made by extrapolating the 2030 sector population data to year 2040. A population 

sensitivity case was performed by using a 30 percent uniform increase in population for all 

sectors. The 30 percent population case showed about a 33 percent change in both population 

dose and offsite economic cost risk. The NRC staff considers the methods and assumptions for 

estimating population reasonable and acceptable for purposes of the SAMA evaluation. 
Appendix G 

August 2008 G-13 NUREG-1437, Supplement 33 

The emergency evacuation model was modeled as a single evacuation zone extending out 

16 kilometers (10 miles) from the plant. It was assumed that 95 percent of the population would 

move at an average speed of approximately 1.2 meters per second with a delayed start time of 

15 minutes (Progress Energy 2006). This assumption is conservative relative to the NUREG1150 study (NRC 1990), which assumed evacuation of 99.5 percent of the population within the 

emergency planning zone. A sensitivity analysis was performed in which the evacuation speed 

was decreased by 50 percent. The result was a 24 percent increase in the total population dose 

(Progress Energy 2007c). The NRC staff concludes that the evacuation assumptions and 

analysis are reasonable and acceptable for the purposes of the SAMA evaluation. 

Much of the site-specific economic data was provided from SECPOP2000 (NRC 2003) by 

specifying the data for each of the counties surrounding the plant to a distance of 50 miles. 

SECPOP2000 utilizes economic data from the 1997 Census of Agriculture (USDA 1998). In 

addition, generic economic data that applied to the region as a whole were revised from the 

MACCS2 sample problem input when better information was available. Some of this data was 

adjusted using the consumer price index of 1.68. These revised parameters included the value 

of farm and non-farm wealth. 

Subsequent to the ER, several input/output problems related to use of the SECPOP2000 code 

were identified. CP&L performed a re-analysis of the benefit estimates using corrected 

input/output, and found that the overall results of the SAMA assessment were not affected. This 

is discussed further in Section G.6.1. 

The NRC staff concludes that the methodology used by CP&L to estimate the offsite 

consequences for HNP provides an acceptable basis from which to proceed with an 

assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based 

its assessment of offsite risk on the CDF and offsite doses reported by CP&L. 

G.3 Potential Plant Improvements 

The process for identifying potential plant improvements, an evaluation of that process, and the 

improvements evaluated in detail by CP&L are discussed in this section. 

G.3.1 Process for Identifying Potential Plant Improvements 

CP&L's process for identifying potential plant improvements (SAMAs) consisted of the following 

elements:

• Review of the most significant basic events from the current plant-specific PSA, 

• Review of potential plant improvements identified in the HNP IPE and IPEEE, 
Appendix G 

NUREG-1437, Supplement 33 G-14 August 2008 

• Review of dominant fire areas from the fire analysis that could potentially reduce the 

associated fire risk, 

• Review of Phase II SAMAs from license renewal applications for six other U.S. nuclear 

sites, and 

• Review of other industry documentation discussing potential plant improvements. 

Based on this process, an initial set of 22 potential SAMA candidates, referred to as Phase I 

SAMAs, was identified. In Phase I of the evaluation, CP&L performed a qualitative screening of 

the initial list of SAMAs and eliminated SAMAs from further consideration using the following 

criteria:

• The SAMA is not applicable at HNP due to design differences, or 

• The SAMA has estimated costs that would exceed the dollar value associated with 

completely eliminating all severe accident risk at HNP. 

Based on this screening, 2 SAMAs were eliminated leaving 20 unique SAMAs for further 

evaluation. The remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.5-4 of 

the ER (Progress Energy 2006). In Phase II, a detailed evaluation was performed for each of 

the 20 remaining SAMA candidates, as discussed in Sections G.4 and G.6 below. To account 

for the potential impact of external events, the estimated benefits based on internal events were 

multiplied by a factor of 2 except for those SAMAs specific to external events, since those 

SAMAs address specific portions of the fire and seismic fire risk (in these cases, a separate 

evaluation is used). 

G.3.2 Review of CP&L’s Process 

CP&L’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

initiating events, but also included explicit consideration of potential SAMAs for fire and seismic 

events. The initial list of SAMAs generally addressed the accident sequences considered to be 

important to CDF from functional, initiating event, and risk reduction worth perspectives at HNP, 

and included selected SAMAs from prior SAMA analyses for other plants. 

CP&L provided a tabular listing of the PSA basic events sorted according to their risk reduction 

worth (RRW) (Progress Energy 2006). SAMAs impacting these basic events would have the 

greatest potential for reducing risk. CP&L used a RRW cutoff of 1.014, which corresponds to 

about a 1.4-percent change in CDF given 100-percent reliability of the SAMA. This equates to a 

benefit of approximately $48,500 (after the benefits have been multiplied to account for external 

events). In response to an RAI, CP&L indicated that they had misinterpreted the function of the 

PSA human action failure event “OPER-66 - Failure to locally operate the turbine-driven pump 

after power failure” in the ER and that risk reduction opportunities related to OPER-66 could 
Appendix G 

August 2008 G-15 NUREG-1437, Supplement 33 

have been missed in the SAMA identification process (Progress Energy 2007b). In their 

response, CP&L demonstrated that the majority of OPER-66 risk is addressed by cost-beneficial 

SAMA 8, therefore minimizing the impact of this error. 

CP&L also provided and reviewed the LERF-based RRW events down to an RRW of 1.014.

CP&L correlated the basic events with highest risk importance in the Level 1 and 2 PSA with the 

SAMAs evaluated in Phase I or Phase II, and showed that, with a few exceptions, all of the 

significant basic events are addressed by one or more SAMAs (Progress Energy 2006). Of the 

basic events of high risk importance that are not addressed by SAMAs, each is closely tied to 

other basic events that had been addressed by one or more SAMAs. 

For a number of the Phase II SAMAs listed in the ER, the information provided did not 

sufficiently describe the proposed modification. Therefore, the NRC staff asked the licensee to 

provide more detailed descriptions of the modifications for several of the Phase II SAMA 

candidates (NRC 2007). In response to the RAI (Progress Energy 2007b), CP&L provided more 

detailed information on the modifications for SAMAs 2, 4 and 8. 

The NRC staff questioned CP&L about lower cost alternatives to some of the SAMAs evaluated 

(NRC 2007), including: 

• Changes to procedures to re-open 1SW-274 and 1SW-275 in order to re-establish an 

emergency service water (ESW) discharge pathway (a low cost alternative to SAMA 15, 

which involves logic changes) 

• Use of portable generator to provide DC power to turbine-driven auxiliary feedwater 

(TDAFW) pump and selected instrumentation to extend the coping time in loss of 

alternating current power events (to power battery chargers only, and not the hydrostatic 

test pump as assumed in SAMA 1) 

In response to the RAIs, CP&L addressed the suggested lower cost alternatives, some of which 

are covered by an existing procedure or are addressed by other SAMAs (Progress Energy 

2007a). This is discussed further in Section G.6.2. 

Although the IPE did not identify any vulnerabilities, three potential enhancements to the plant, 

procedures, and training at HNP were identified as part of the IPE process. These 

enhancements included: (1) revision of operating procedures to provide explicit instructions for 

locally aligning offsite AC power if the breakers fail to automatically actuate and cannot be 

controlled from the main control room, (2) installation of instrumentation for improved battery 

monitoring capability for detection of open circuits during battery charging, and (3) verification of 

testing and maintenance procedures for the non-vital 125 VDC battery to ensure practices are 

equivalent to the practices for the safety related batteries. CP&L noted that the first of these 

enhancements had been implemented, and that the last had been verified to have already been 

the plant practice, therefore requiring no plant changes. 
Appendix G 

NUREG-1437, Supplement 33 G-16 August 2008 

The enhancement that has not been implemented at HNP is to install instrumentation for 

improved battery monitoring capability. SAMA 2 is proposed as an alternative to this IPE 

enhancement, which would change the emergency bus power supply from the unit auxiliary 

transformers (UATs) to the startup transformers (SUTs). CP&L stated that this would eliminate 

the dependence on non-vital DC to swap power supplies after a trip. The NRC staff requested 

CP&L to further evaluate the costs and benefits associated with the installation of 

instrumentation for improved battery monitoring capability (NRC 2007). The result of this 

assessment are addressed in Section G.6.2. 

Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 

together with those identified in response to NRC staff RAIs, addresses the major contributors 

to internal event CDF. 

CP&L identified HNP-specific candidate SAMAs for external events using the HNP IPEEE. This 

included reconsideration of any previously rejected or incompleted plant changes identified in 

the IPEEE. A total of 3 SAMAs (one seismic- and two fire-related SAMAs) were identified to 

address external events. As a result of the seismic portion of the IPEEE, thirteen items were 

found to have minor interaction, housekeeping, or maintenance issues, mostly related to 

missing or broken anchorage parts. Six additional items were found to be improperly secured 

requiring alternate means of anchoring. CP&L indicates that all of these items have been 

addressed (Progress Energy 2006). Some equipment was not able to be screened from further 

review using only the information obtained from the plant walkdown and a review of design 

documentation. Sixteen such items were identified and further evaluated to determine if the 

equipment had HCLPF capacities of 0.30g or higher. The HNP seismic IPEEE showed that the 

high confidence low probability of failure (HCLPF) values for all SSCs were greater than the 

0.3g review level earthquake except for the RHR heat exchangers, which had a HCLPF value of 

0.29g. Although CP&L considers it likely that the RHR heat exchangers could be shown to have 

a HCLPF value sufficient for the RLE, given the importance of loss of RHR events, CP&L 

included a candidate SAMA to increase the seismic capacity of these components, i.e., SAMA 

22 - install upper lateral restraints on the RHR heat exchangers. CP&L noted that some 

electrical relays could not be assigned a HCLPF value of 0.3g during the IPEEE seismic 

equipment analysis but that a subsequent seismic qualification test showed that the relays 

exceeded the RLE requirements by a factor of 2.4 (Progress Energy 2006). Based on the 

licensee’s efforts to identify and address seismic outliers and the expected cost associated with 

further seismic risk analysis and potential plant modifications, the NRC staff concludes that the 

opportunity for seismic-related SAMAs has been adequately explored and that it is unlikely that 

there are any cost-beneficial, seismic-related SAMA candidates. 
August 2008 G-17 NUREG-1437, Supplement 33

The HNP fire IPEEE identified one opportunity for improvement related to fire events that was 

subsequently implemented. This enhancement was to incorporate procedure changes that 

require the operators to check the status of the power operated relief valves (PORVs) after 

transfer to the alternate control panel, and to close the associated block valve if a PORV is 

stuck open in fire-induced Main Control Room evacuation scenarios. CP&L stated that this 

enhancement has been implemented, but has not been credited in the IPEEE fire CDF. 

Nevertheless, the licensee further considered potential SAMAs for fire and identified two 

opportunities for additional reduction of fire risk, specifically, SAMA 1 - Install a permanent 

hydrostatic test pump and a 480V AC generator such that the pump can be rapidly aligned to 

provide seal injection in an SBO and provide power to the “B“ battery chargers to eliminate the 

need to manually operate the turbine-driven AFW pump after battery depletion, and SAMA 8 - 

Provide the capability to align a direct feed to the B3-SB transformer and to align the “C“ 

charging/safety injection pump (CSIP) for seal injection. The NRC staff concludes that the 

opportunity for fire-related SAMAs has been adequately explored and that it is unlikely that there 

are additional potentially cost-beneficial, fire-related SAMA candidates. 

The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional, 

possibly even less expensive, design alternatives can always be postulated. However, the NRC 

staff concludes that the benefits of any additional modifications are unlikely to exceed the 

benefits of the modifications evaluated and that the alternative improvements would not likely 

cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 

with maintenance, procedures, and training are considered. 

The NRC staff concludes that CP&L used a systematic and comprehensive process for 

identifying potential plant improvements for HNP, and that the set of potential plant 

improvements identified by CP&L is reasonably comprehensive and therefore acceptable. This 

search included reviewing insights from the plant-specific risk studies and reviewing plant 

improvements considered in previous SAMA analyses. While explicit treatment of external 

events in the SAMA identification process was limited, it is recognized that the prior 

implementation of plant modifications for seismic and fire events and the absence of external 

event vulnerabilities reasonably justifies examining primarily the internal events risk results for 

this purpose. 

G.4 Risk Reduction Potential of Plant Improvements 

CP&L evaluated the risk-reduction potential of the 20 remaining SAMAs that were applicable to 

HNP. The SAMA evaluations were performed using realistic assumptions with some 

conservatism. On balance, such calculations overestimate the benefit and are conservative. 

For most of the SAMAs, CP&L used model re-quantification to determine the potential benefits. 

The CDF and population dose reductions were estimated using the 2005 version of the HNP 
Appendix G 

NUREG-1437, Supplement 33 G-18 August 2008 

PSA model (MOR2005). The changes made to the model to quantify the impact of the SAMAs 

are detailed in Section E.6 of Attachment E to the ER. Table G-5 lists the assumptions 

considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk 

reduction in terms of percent reduction in CDF and population dose, and the estimated total 

benefit (present value) of the averted risk. The estimated benefits reported in Table G-5 reflect 

the combined benefit in both internal and external events. The determination of the benefits for 

the various SAMAs is further discussed in Section G.6. 

The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction 

estimates of certain SAMAs provided in the ER (NRC 2007). For example, for SAMA 6, 

Waterproof motor operators for valves 1SW-274 and 1SW-275 to mitigate floods caused by 

service water line breaks, the NRC staff requested the bases of the assumption that failure to 

mitigate specific flood scenarios has a failure probability of 0.01 following SAMA 

implementation. In response, CP&L showed that the averted cost risk for SAMA 6 varies by 

only a small amount over the range of failure probabilities from 0.0 to 0.1. In order to show that 

the results of this SAMA evaluation are not sensitive to the human error probability used in the 

modeling process, CP&L re-performed the cost benefit analysis assuming no credit for isolation 

maximum flow breaks and a failure probability of 0.1 for non-maximum flow breaks. SAMA 6 is 

not cost-beneficial even when uncertainties are considered. The NRC staff considers the 

assumptions, as clarified, to be reasonable and acceptable for purposes of the SAMA 

evaluation.

For those SAMAs that address both fire events and internal events (i.e., SAMAs 1 and 8), the 

internal events risk reduction was directly assessed and combined with the estimated risk 

reduction in fire events. For the fire events portion, CP&L reduced the total external events 

benefit used in the SAMA 1 and 8 calculations by excluding the risk contribution of SGTR and 

interfacing-systems LOCA. The IPEEE fire analysis was then used to identify the fraction of the 

fire risk that could be eliminated by potential enhancements in various fire areas. The product 

of the reduced external events benefit, the fraction of the fire risk eliminated and the estimated 

reliability of each proposed SAMA was used to determine the cost-risk of these SAMAs. In 

response to an RAI on excluding the contribution of SGTR and interfacing-systems LOCA, 

CP&L demonstrated that if the method of multiplying the internal events averted cost-risk by a 

factor of 2 is used, then SAMA 1 (which was not cost-beneficial in the ER) remains not costbeneficial, and SAMA 8 (which was cost-beneficial in the ER) is no longer cost-beneficial. 

CP&L stated that the original conclusions of the ER submittal are believed to be the most 

appropriate for these SAMAs. 

For the internal events portion of SAMAs 1 and 8, one of the elements of the PSA that was 

adjusted to evaluate the benefit of these SAMAs was the human action failure basic event 

OPER-66. As previously discussed, CP&L discovered that they had misinterpreted the function 

of OPER-66 in the ER. In CP&L’s response to an RAI, they demonstrated that the 

misinterpretation of OPER-66 resulted in an optimistic representation of SAMA 1 and had no 

impact on the conclusions regarding SAMA 8 (Progress 2007b). 
Appendix G 

August 2008 G-19 NUREG-1437, Supplement 33 

For the SAMA that specifically addresses seismic events (i.e., SAMA 22 - Installation of upper 

lateral restraints on the RHR heat exchangers), CP&L assumed that 100 percent of the non-fire 

external events contributions are due to seismic events, 25 percent of the total seismic risk is 

attributable to the RHR heat exchangers, and the lateral restraints are 100 percent effective at 

preventing seismically induced failure. This SAMA was assumed to have no additional benefits 

in internal events. 

The NRC staff has reviewed CP&L’s bases for calculating the risk reduction for the various plant 

improvements and concludes that the rationale and assumptions for estimating risk reduction 

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for 

the various SAMAs on CP&L’s risk reduction estimates. 

G.5 Cost Impacts of Candidate Plant Improvements 

CP&L estimated the costs of implementing the 20 candidate SAMAs through the application of 

engineering judgement and use of other licensees‘ estimates for similar improvements. The 

cost estimates conservatively did not include the cost of replacement power during extended 

outages required to implement the modifications, nor did they include contingency costs 

associated with unforeseen implementation obstacles. In response to a request for additional 

information, the licensee indicated that the cost estimates provided in the ER also did not 

account for inflation, which is considered another conservatism (Progress Energy 2007a). 

The NRC staff reviewed the bases for the licensee’s cost estimates (presented in Section E.6 of 

Attachment E to the ER). For certain improvements, the NRC staff also compared the cost 

estimates to estimates developed elsewhere for similar improvements, including estimates 

developed as part of other licensees‘ analyses of SAMAs for operating reactors and advanced 

light-water reactors. In response to an RAI requesting a more detailed description of the 

changes associated with SAMA 2,4 and 8, CP&L provided additional information detailing the 

analysis, procedure changes and modifications included in the cost estimate of each 

improvement (Progress 2007b). The NRC staff reviewed the costs and found them to be 

reasonable, and generally consistent with estimates provided in support of other plants‘ 

analyses.

The NRC staff concludes that the cost estimates provided by CP&L are sufficient and 

appropriate for use in the SAMA evaluation.
Appendix G 

NUREG-1437, Supplement 33 G-20 August 2008 Cost ($) 1,000,000 200,000 565,000 150,000 Total Benefit Using 3% Discount Rate(b) ($) 235,000 155,000 390,000 59,000 34,000 62,000 Population Dose 

6

4 [based on 

39.4x.9x3.2

5/28.97]

1

<1 

1

% Risk Reduction 

CDF

33

32 [based on 

39.4x.9x8.26

e-6/9.24e-6 

277

Assumptions 

Internal Events: Set a new basic event for failure of alternate seal injection to 0.1, and reduce operator failure to align 480V AC generator to the battery charger by 50 percent 

Fire Events: Eliminate 90 percent of the CDF for all applicable fire scenarios, not including SGTR and ISLOCA Combined Eliminate loss of non-vital 125V DC power as contributors to failures of buses 1D and 1E, and to failure of providing power to emergency buses 1A-SA and 1BS

Include credit for injection and RHR heat removal, add event (with failure probability of 1E-2) for new sump suction line and booster pump for CSIPs Include credit for makeup in SGTR events by charging the corresponding sequence flag of the relevant contributions to 1E-1 

Table G-5. SAMA Cost Benefit Screening Analysis for HNP(a)

SAMA

1 - Install a permanent, hydrostatic test pump (or alternate pump) with 480V AC generator for seal injection and to provide power to the “B” battery chargers(c)

2 – Change 1D and 1E Buses to be normally aligned to an off-site power source 3 – Increase capacity of containment fan coolers for heat removal when RHR cooling unavailable and provide sump suction for HPSI 4 – Develop procedures for RWST makeup using firewater and boric acid addition [see response to RAI 6.a.i]
Appendix G 

August 2008 G-21 NUREG-1437, Supplement 33 Cost ($) 150,000 1,700,000 300,000 70,000 50,000 Total Benefit Using 3% Discount Rate(b) ($) 110,000 82,000 22,000 280,000 300,000 94,000 11,000 Population Dose 

21

<1 

7

[based on 

(63.4x3.25) 

/ 28.97 ] 

1

<1 

% Risk Reduction 

CDF

8

14

5

57 [based on (63.4 x 

8.26e-6) / 

9.24e-6 ] 

72

Assumptions 

Reduce the flooding initiating event frequency by two orders of magnitude Create event with failure probability of 1E-2 to represent operation of passive secondary side heat removal system Internal Events: Create event with failure probability of 0.1 for operator error when diagnosing and aligning the alternate seal cooling Fire Events: Eliminate all of the CDF for all applicable fire scenarios, not including SGTR and ISLOCA CombinedChanged probability of events representing the major contributors to loss of EDG HVAC to 0 

Reduced probability for event representing the conditions under which the control room trip action is not possible by two orders of magnitude 

Table G-5. SAMA Cost Benefit Screening Analysis for HNP(a)

SAMA

6 – Waterproof motor operators for valves 1SW-274 and 1SW2757 – Passive secondary side cooling system 8 – Provide the capability to align a direct feed to the 1B3-SB transformer to preclude battery depletion and to provide alternate seal cooling by aligning the “C“ CSIP for seal injection(c) 

9 – Proceduralize actions to open EDG room doors and implement portable fans on loss of HVAC 10 – Install a main control room power interrupt switch for alternate SCRAM capability 
Appendix G 

NUREG-1437, Supplement 33 G-22 August 2008 Cost ($) 500,000 175,000 50,000 3,400,000 Total Benefit Using 3% Discount Rate(b) ($) 60,000 40,000 9,000 410,000 Population Dose 

11

<1 

6

% Risk Reduction 

CDF

222

31

Assumptions 

Eliminate the risk contribution from common cause failure involving valves 1SI107 and 1SI-3 Create new event with failure probability of 1E-1 to represent operator action governing the alignment if the unisolated suction path and assume that alignment can be performed in time to prevent seal damage given failure of the normally Changed logic such that either the A or B (as opposed to both A and B) air compressor could carry the balance of plant loads to maintain the plant on-line and avoid a plant trip Eliminate the risk contribution from failures that could be mitigated by availability of a swing EDG (all LOOP contributors, loss of bus contributors and failure combinations including EDG start and run failures) 

Table G-5. SAMA Cost Benefit Screening Analysis for HNP(a)

SAMA

17 – Replace 2 of the 5 high pressure injection valves with an alternate type of valve 18 – Proceduralize alignment of HHSI to the RHR heat exchangers during injection phase 19 – Replace “A” and “B” instrument air compressors with 100 percent capacity compressors 21 – Swing 6.9kV AC EDG
Appendix G 

August 2008 G-23 NUREG-1437, Supplement 33 Cost ($) 350,000 Total Benefit Using 3% Discount Rate(b) ($) 75,000 Population Dose 

4

% Risk Reduction 

CDF

4

Assumptions 

Eliminate all seismically-induced failures of RHR heat exchangers 

Table G-5. SAMA Cost Benefit Screening Analysis for HNP(a)

SAMA

22 – Install upper lateral restraints on the RHR heat exchangers(c)

(a) SAMAs in bold are potentially cost beneficial (b) Estimated benefits reflect revised values provided after correction of SECPOP2000 economic data file errors (Progress Energy 2007d) (c) Estimated benefits are derived from information provided in the ER (Progress Energy 2006) and are stated as a percentage reduction of 

risk from external events.
Appendix G 

NUREG-1437, Supplement 33 G-24 August 2008 

G.6 Cost-Benefit Comparison 

CP&L's cost-benefit analysis and the NRC staff’s review are described in the following sections. 

G.6.1 CP&L’s Evaluation 

The methodology used by CP&L was based primarily on NRC’s guidance for performing costbenefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook

(NRC 1997a). The guidance involves determining the net value for each SAMA according to 

the following formula: 

Net Value = (APE + AOC + AOE + AOSC) - COE, where 

APE = present value of averted public exposure ($) 

AOC = present value of averted offsite property damage costs ($) 

AOE = present value of averted occupational exposure costs ($) 

AOSC = present value of averted onsite costs ($) 

COE = cost of enhancement ($) 

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 

benefit associated with the SAMA and it is not considered cost-beneficial. CP&L’s derivation of 

each of the associated costs is summarized below. 

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed: one at 

3 percent and one at 7 percent (NRC 2004). CP&L provided both sets of estimates (Progress 

Energy 2006). 

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula: 

APE = Annual reduction in public exposure (ǻperson-rem per year) 

x monetary equivalent of unit dose ($2000 per person-rem) 

x present value conversion factor (15.04 based on a 20-year period with a 

3-percent discount rate). 
Appendix G 

August 2008 G-25 NUREG-1437, Supplement 33 

As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of 

the public health risk after discounting does not represent the expected reduction in public 

health risk due to a single accident. Rather, it is the present value of a stream of potential 

losses extending over the remaining lifetime (in this case, the renewal period) of the facility. 

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an 

accident could occur at any time over the renewal period, and the effect of discounting these 

potential future losses to present value. For the purposes of initial screening, which assumes 

elimination of all severe accidents due to internal events, CP&L calculated an APE of 

approximately $871,000 for the 20-year license renewal period.

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula: 

AOC = Annual CDF reduction 

x offsite economic costs associated with a severe accident (on a per-event basis) 

x present value conversion factor. 

For the purposes of initial screening which assumes all severe accidents due to internal events 

are eliminated, CP&L calculated an annual offsite economic risk of about $43,000 based on the 

Level 3 risk analysis. This results in a discounted value of approximately $647,000 for the 

20-year license renewal period. 

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula: 

AOE = Annual CDF reduction 

x occupational exposure per core damage event 

x monetary equivalent of unit dose 

x present value conversion factor. 

CP&L derived the values for averted occupational exposure from information provided in 

Section 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values provided 

for immediate occupational dose (3300 person-rem) and long-term occupational dose 

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these 

doses was calculated using the equations provided in the handbook in conjunction with a 

monetary equivalent of unit dose of $2000 per person-rem, a real discount rate of 3 percent, 

and a time period of 20 years to represent the license renewal period. For the purposes of initial 
Appendix G 

NUREG-1437, Supplement 33 G-26 August 2008 

screening, which assumes all severe accidents due to internal events are eliminated, CP&L 

calculated an AOE of approximately $5,700 for the 20-year license renewal period. 

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted 

power replacement costs. Repair and refurbishment costs are considered for recoverable 

accidents only and not for severe accidents. CP&L derived the values for AOSC based on 

information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook 

(NRC 1997a). 

CP&L divided this cost element into two parts B the onsite cleanup and decontamination cost, 

also commonly referred to as averted cleanup and decontamination costs, and the replacement 

power cost. 

Averted cleanup and decontamination costs (ACC) were calculated using the following formula: 

ACC = Annual CDF reduction 

x present value of cleanup costs per core damage event 

x present value conversion factor. 

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 

NUREG/BR-0184 to be $1.3 x 109

 (discounted over a 10-year cleanup period). This value is 

integrated over the term of the proposed license extension. For the purposes of initial 

screening, which assumes all severe accidents due to internal events are eliminated, CP&L 

calculated an ACC of approximately $180,000 for the 20-year license renewal period. 

Long-term replacement power costs (RPC) were calculated using the following formula: 

RPC = Annual CDF reduction 

x present value of replacement power for a single event 

x factor to account for remaining service years for which replacement power is required 

x reactor power scaling factor 

CP&L based its calculations on the EPU value of 900 megawatt electric (MWe), which is the 

current electrical output for HNP. Therefore, CP&L applied a power scaling factor of 900/910 to 

determine the replacement power costs. For the purposes of initial screening, which assumes 

all severe accidents due to internal events are eliminated, CP&L calculated an RPC of 
Appendix G 

August 2008 G-27 NUREG-1437, Supplement 33 

approximately $50,000 and an AOSC of approximately $230,000 for the 20-year license 

renewal period. 

Using the above equations, CP&L estimated the total present dollar value equivalent associated 

with completely eliminating severe accidents due to internal events at HNP to be about $1.75M. 

Use of a multiplier of two to account for external events increases the value to $3.5M and 

represents the dollar value associated with completely eliminating all internal and external event 

severe accident risk at HNP, also referred to as the Modified Maximum Averted Cost Risk 

(MMACR).

CP&L’s Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

was considered not to be cost-beneficial. In the baseline analysis contained in the ER, (using a 

3 percent discount rate), CP&L identified one potentially cost-beneficial SAMAs. The potentially 

cost-beneficial SAMA is: 

• SAMA 9 - Proceduralize actions to open emergency diesel generator (EDG) room doors 

and implement portable fans on loss of heating ventilation and air-conditioning (HVAC). 

CP&L performed additional analyses to evaluate the impact of parameter choices and 

uncertainties on the results of the SAMA assessment (Progress Energy 2006). Using a 

7 percent discount rate, SAMA 9 would not be cost-beneficial. If the benefits (based on a 

3 percent discount rate) are increased by a factor of 1.5 to account for uncertainties, SAMA 9 

plus two additional SAMA candidates were determined to be potentially cost-beneficial: 

• SAMA 6 - Waterproof motor operators for valves 1SW-274 and 1SW-275 to mitigate 

floods caused by service water line breaks 

• SAMA 8 - Provide the capability to align a direct feed to the 1B3-SB transformer to 

preclude battery depletion, and to align the “C“ charging/safety injection pump (CSIP) for 

seal injection 

Subsequent to the ER, three problems related to use of the SECPOP2000 code were identified. 

These deal with: (1) a formatting error in the regional economic data block text file generated by 

SECPOP2000 for input to MACCS2 which results in MACCS2 mis-reading the data, (2) an error 

associated with the formatting of the COUNTY97.DAT economic database file used by 

SECPOP2000 which results in SECPOP2000 processing incorrect economic and land use data, 

and (3) gaps in the numbered entries in the COUNTY97.DAT economic database file which 

result in any county beyond county number 955 being handled incorrectly in SECPOP2000. 

CP&L provided revised benefit estimates using corrected input to MACCS2 (Progress Energy 

2007d). The correction of the identified problems resulted in an increase in the maximum 

averted cost risk of about 14 percent, and a change in the estimated benefits for the various 

SAMAs ranging from a 10 percent reduction in benefits to a 14 percent increase in benefits. 
Appendix G 

NUREG-1437, Supplement 33 G-28 August 2008 

This correction resulted in no change to the Phase I screening results, and resulted in no 

additional SAMAs becoming potentially cost-beneficial in either the baseline analysis or the 

uncertainty analysis. Thus, the overall results of the SAMA assessment were not affected. 

The potentially cost-beneficial SAMAs and CP&L’s plans for further evaluation of these SAMAs 

are discussed in more detail in Section G.6.2. 

G.6.2 Review of CP&L’s Cost-Benefit Evaluation 

The cost-benefit analysis performed by CP&L was based primarily on NUREG/BR-0184 (NRC 

1997a) and was implemented consistent with this guidance. 

To account for external events, CP&L multiplied the internal event benefits by a factor of 2, and 

for each SAMA, except those SAMAs that specifically address external events (i.e., SAMAs 1, 

8, and 22). Doubling the benefit for these SAMAs is not appropriate since these SAMAs are 

specific to external events or, as in the case for the two fire-related SAMAs, have a targeted 

external event impact and would be underestimated if calculated using the doubling approach. 

Although the CDF from external events is a factor of 1.4 greater than the CDF for internal 

events, given the licensee’s demonstration of conservatism in the external events CDF, and the 

licensee’s demonstration that use of a higher multiplier would not affect the SAMA screening, 

the NRC staff agrees that the factor of 2 multiplier for external events is reasonable. 

CP&L considered the impact that possible increases in benefits from analysis uncertainties 

would have on the results of the SAMA assessment. In the ER, CP&L presents the results of an 

uncertainty analysis of the internal events CDF which indicates that the 95th percentile value is 

a factor of 1.5 times the mean CDF. CP&L reexamined the initial set of SAMAs to determine if 

any additional Phase I SAMAs would be retained for further analysis if the benefits (and 

Modified Maximum Averted Cost-Risk) were increased by a factor of 1.5. One such Phase I 

SAMA was identified: SAMA 20 - Install alternative high pressure system. However, based on 

further consideration of the limited benefit of eliminating the events addressed by this SAMA, 

CP&L concluded that this SAMA would not be cost-beneficial even if it were completely reliable. 

The specific rationale is provided in Section E.7.2.1 of the ER. 

CP&L also considered the impact on the Phase II screening if the estimated benefits were 

increased by a factor of 1.5 (in addition to the factor of 2 multiplier for external events). Two 

additional SAMAs became cost-beneficial in CP&L’s analysis (SAMAs 6 and 8, as described 

above). Although not cost-beneficial in the baseline analysis, CP&L included these two SAMAs 

within the set of potentially cost-beneficial SAMAs that they intend to examine further for 

implementation.

CP&L did not develop a cost-risk analysis for the Phase II SAMA 14 - Alternate Auxiliary 

Feedwater (AFW) suction. In the ER, CP&L noted that the costs and benefits were not 

quantified for SAMA-14 because once existing procedures and equipment for the Emergency 
Appendix G 

August 2008 G-29 NUREG-1437, Supplement 33 

Service Water (ESW) to AFW suction line were credited, most condensate storage tank flow 

path failures were eliminated. Any flow path failure which remained had RRW values of 1.0. 

Therefore, the benefits and costs of this SAMA was not evaluated. 

The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 

that could achieve much of the risk reduction at a lower cost. The NRC staff asked the licensee 

to evaluate several lower cost alternatives to the SAMAs considered in the ER, including 

SAMAs that had been found to be potentially cost-beneficial at other PWR plants. These 

alternatives were: (1) changes to procedures to re-open 1SW-274 and 1SW-275 in order to reestablish an ESW discharge pathway, (2) the use of a portable generator to provide DC power 

to the TDAFW pump and selected instrumentation to extend the coping time in loss of AC power 

events, and (3) installation of instrumentation for improved battery monitoring capability (NRC 

2007). CP&L provided a further evaluation of these alternatives, as summarized below. 

• Changes to procedures to re-open 1SW-274 and 1SW-275 (a low cost alternative to 

SAMA 15, which involves logic changes) - No credit can be given for this proposed 

SAMA due to the limited time window. The cooling requirements of the EDG necessitate 

that the valves be re-opened very quickly. Clearing or bypassing the safety injection 

signal would be required before the valves could be re-opened. The cooling flow would 

be further delayed by the time required to operate the valves and the time for the valves 

to stroke. These time constraints would prevent cooling flow to the EDG before damage 

would occur. 

• Use of portable generator to provide DC power to TDAFW pump and selected 

instrumentation to extend the coping time (a low cost alternative to SAMA 1, which 

involves also powering a hydrostatic test pump) - Based on a bounding analysis in which 

the human error probability for TDAFW control was set to zero, this proposed SAMA 

provides limited benefit and is not cost-beneficial even when considering uncertainties. 

One of the elements of the PSA that was adjusted to evaluate the benefit of this 

proposed improvement was the human action failure basic event OPER-66 (Progress 

2007a). As previously discussed, CP&L discovered that it had misinterpreted the 

function of OPER-66. In CP&L’s response to an RAI, they stated that the 

misinterpretation of OPER-66 had a significant impact on the estimated benefit 

associated with this improvement. As a result, CP&L provided a revised assessment of 

this improvement which resulted in an averted cost-risk of $48,000 and a cost of 

implementation of $100,000. If the 95th percentile results are used, the averted cost-risk 

increases to $72,000. These results demonstrate that the enhancement is still not costbeneficial (Progress 2007b).

• Installation of instrumentation for improved battery monitoring capability, especially for 

detection of open circuit faults while the bus is carried by the battery charger - This 

improvement provides minimum benefit as there is a connection between the non-vital 

125 VDC battery and the bus, precluding an “open circuit fault“. In addition, there are 
Appendix G 

NUREG-1437, Supplement 33 G-30 August 2008 

periodic proceduralized checks, and main control room alarms related to the non-vital 

battery charger, which would identify a loss of charge on the battery. As a bounding 

analysis shows that elimination of all non-vital DC system failures would achieve a 

smaller benefit than the minimum cost of SAMAs requiring a hardware change, this 

proposed SAMA is not cost-beneficial. 

The NRC staff notes that the three potentially cost-beneficial SAMAs 6, 8, and 9 identified in 

either CP&L’s baseline analysis, or uncertainty analysis, are included within the set of SAMAs 

that CP&L will consider for implementation. 

The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs 

discussed above, the costs of the SAMAs evaluated would be higher than the associated 

benefits.

G.7 Conclusions 

CP&L compiled a list of 22 SAMAs based on a review of the most significant basic events from 

the current plant-specific PSA, insights from the plant-specific IPE and IPEEE, Phase II SAMAs 

from license renewal applications for other plants, and review of other industry documentation. 

An initial screening removed SAMA candidates that (1) were determined not applicable to the 

HNP design, or (2) had estimated costs that would exceed the dollar value associated with 

completely eliminating all severe accident risk at HNP. Based on this screening, 2 SAMAs were 

eliminated leaving 20 candidate SAMAs for evaluation. 

For the remaining SAMA candidates, more detailed evaluation was performed as shown in 

Table G-5. The cost-benefit analyses in the ER showed that one SAMA candidate was 

potentially cost-beneficial in the baseline analysis (SAMA 9). CP&L performed additional 

analyses to evaluate the impact of parameter choices and uncertainties on the results of the 

SAMA assessment. As a result, two additional SAMAs (SAMAs 6 and 8) were identified as 

potentially cost-beneficial. CP&L has indicated that all three potentially cost-beneficial SAMAs 

(6, 8, and 9) will be considered for implementation at HNP.

The NRC staff reviewed the CP&L analysis and concludes that the methods used and the 

implementation of those methods were sound. The treatment of SAMA benefits and costs 

support the general conclusion that the SAMA evaluations performed by CP&L are reasonable 

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 

events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 

area was minimized by improvements that have been realized as a result of the IPEEE process, 

and inclusion of a multiplier to account for external events. 
Appendix G 

August 2008 G-31 NUREG-1437, Supplement 33 

The NRC staff agrees with CP&L’s identification of areas in which risk can be further reduced in 

a cost-beneficial manner through the implementation of the identified, potentially cost-beneficial 

SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees that further 

evaluation of these SAMAs by CP&L is warranted. However, these SAMAs do not relate to 

adequately managing the effects of aging during the period of extended operation. Therefore, 

they need not be implemented as part of license renewal pursuant to Title 10 of the Code of 

Federal Regulations, Part 54. 

G.8 References 

Carolina Power & Light (CP&L). 1993. Letter from W. R. Robinson, HNP to U.S. Nuclear 

Regulatory Commission Document Control Desk. Subject: Shearon Harris Nuclear Power Plant 

Docket No. 50-400/License No. NPF-63 Submittal of Individual Plant Examination (IPE). 

August 20, 1993. 

Carolina Power & Light (CP&L). 1995. Letter from W. R. Robinson, HNP to NRC Document 

Control Desk. Subject: Shearon Harris Nuclear Power Plant Docket No. 50-400/License 

No. NPF-63 Response to Generic Letter 88-20. Supplement 4 - Individual Plant Examination of 

External Events (IPEEE). June 30, 1995. 

Electric Power Research Institute (EPRI). 1991. A Methodology for Assessment of Nuclear 

Power Plant Seismic Margins, Revision 1. EPRI Report NP-6041-SL. 

Progress Energy Carolinas, Inc. (Progress Energy). 2006 Licensee’s Environmental 

ReportBOperating License Renewal Stage, Shearon Harris Nuclear Plant. November 2006. 

Progress Energy Carolinas, Inc. (Progress Energy). 2007a. Response to Request Additional 

Information Regarding Severe Accident Mitigation Alternative for Shearon Harris Nuclear Power 

Plant. May 10, 2007. 

Progress Energy Carolinas, Inc. (Progress Energy). 2007b. Documentation of Changes to 

Severe Accident Mitigation Analysis for Shearon Harris Nuclear Power Plant License Renewal 

Application. August 27, 2007. 

Progress Energy Carolinas, Inc. (Progress Energy). 2007c. E-mail from J. Kozyra to 

S. Hernandez-Quinones, Subject: SAMA Sensitivity Analysis Regarding Shearon Harris 

Relicensing, October 2, 2007. 

Progress Energy Carolinas, Inc. (Progress Energy). 2007d. Impact of Errors in the 

SECPOP2000 Computer Code on the Severe Accident Mitigation Alternatives Analysis for 

Shearon Harris Nuclear Power Plant License Renewal. October 5, 2007. 
Appendix G 

NUREG-1437, Supplement 33 G-32 August 2008 

State of North Carolina. 2005. “Population Overview: 2000-2030.” State Demographics Unit. 

<http://demog.state.nc.us/demog/pop0030.xls>. May 25, 2006 

U.S. Census Bureau (USCB). 2000. Census 2000 Redistricting Data (P.L. 94-171) Summary 

File and 1990 Census. Table 1 B Counties in Alphabetical Sort within State, 1990 and 2000 

Population, Numeric and Percent Change: 1990 to 2000. April 2, 2001. Available online at: 

<http://www.census.gov/population/cen2000/phc-t4/tab01.xls> 

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National 

Agriculture Statistics Service, 1998. Available online at: 

<http://www.nass.usda.gov/census/census97/volume1/vol1pubs.htm>. 

U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment 

for Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1991. Generic Letter No. 88-20, Supplement 4, 

“Individual Plant Examination of External Events for Severe Accident Vulnerabilities,” NUREG1407, Washington, D.D., June 28, 1991. 

U.S. Nuclear Regulatory Commission (NRC). 1992. “Methods for External Event Screening 

Quantification: Risk Methods Integration and Evaluation Program (RMIEP) Methods 

Development,” NUREG/CR-4839, Washington, D.C 

U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from Ngoc B. Le, U.S. NRC, to 

W. R. Robinson, CP&L. Subject: NRC Staff’s Evaluation of the Shearon Harris Nuclear Plant 

Individual Plant Examination (IPE Submittal), (Serial: HNP-93-835) (TAC No. M74418), 

January 26, 1996. 

U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 

Handbook. NUREG/BR-0184, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program: 

Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2000. Letter from Richard J. Laufer, U.S. NRC to 

James Scarola, CP&L. Subject: NRC Staff's Evaluation of the Shearon Harris Nuclear Power 

Plant, Unit 1, Individual Plant Examination of External Events (IPEEE) Submittal (TAC No. 

M83627), January 14, 2000. 

U.S. Nuclear Regulatory Commission (NRC). 2003. SECPOP 2000: Sector Population, Land 

Fraction, and Economic Estimation Program. NUREG/CR-6525 Revision 1, Washington, D.C., 

August 2003. 
Appendix G 

August 2008 G-33 NUREG-1437, Supplement 33 

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

Nuclear Regulatory Commission. NUREG/BR-0058, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 2007. Letter from Samuel Hernandez, U.S. NRC, 

to Robert J. Duncan II, Progress. Subject: Request for Additional Information Regarding 

Severe Accident Mitigation Alternatives for the Shearon Harris Nuclear Plant (TAC No. 

MD3611), March 27, 2007. 

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1437, Supplement 33

3. DATE REPORT PUBLISHED

MONTH

August

YEAR

2008

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS)

Supplement 33 

Regarding Shearon Harris Nuclear Power Plant, Unit 1

Final Report

5. AUTHOR(S)

See Appendix B of report

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of License Renewal

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8 above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket Number 50-400

11. ABSTRACT (200 words or less)

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

Carolina Power and Light Company, doing business as Progress Energy Carolinas, Inc. (CP&L) to the Nuclear Regulatory

Commission (NRC) to renew the Operating License for Shearon Harris Nuclear Power Plant, Unit 1 (HNP) for an additional 20

years under 10 CFR Part 54. The SEIS includes the NRC staff's analysis that considers and weighs the environmental impacts

of the proposed action, the environmental impacts of alternatives to the proposed action, and mitigation measures available for

reducing or avoiding adverse impacts. It also includes the staff's recommendation regarding the proposed action.

The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for HNP are not so great that preserving the option of license renewal for energy-planning decision makers would be

unreasonable. The recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental Report

submitted by CP&L; (3) consultation with Federal, State, and local agencies; (4) the staff's own independent review; and (5) the

staff's consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Shearon Harris Nuclear Power Plant, Unit 1 

HNP

Shearon Harris

Supplement to the Generic Environmental Impact Statement

FSEIS

National Environmental Policy Act

NEPA

License Renewal

GEIS

NUREG 1437, Supplement 33

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001