NUREG-1437

Supplement 23

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 23

Regarding

Point Beach Nuclear Plant Units 1 and 2

Final Report

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington, DC 20555-0001
AVAILABILITY OF REFERENCE MATERIALS

IN NRC PUBLICATIONS

NRC Reference Material

As of November 1999, you may electronically access

NUREG-series publications and other NRC records at

NRC's Public Electronic Reading Room at

http:l/www.nrc.oovlreading-rm.html.

Publicly released records include, to name a few,

NUREG-series publications; Federal Register notices;

applicant, licensee, and vendor documents and

correspondence; NRC correspondence and internal

memoranda; bulletins and information notices;

inspection and investigative reports; licensee event

reports; and Commission papers and their attachments.

NRC publications in the NUREG series; NRC

regulations, and Title 10, Energy, in the Code of

Federal Regulations may also be purchased from one

of these two sources.

1. The Superintendent of Documents

U.S. Government Printing Office

Mail Stop SSOP

Washington, DC 20402-0001

Internet: bookstore.gpo.gov

Telephone: 202-512-1800

Fax: 202-512-2250

2. The National Technical Information Service

Springfield, VA 22161-0002

www.ntis.gov

1-800-553-6847 or, locally, 703-605-6000

A single copy of each NRC draft report for comment is

available free, to the extent of supply, upon written

request as follows:

Address: Office of the Chief Information Officer,

Reproduction and Distribution

Services Section

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

E-mail: DISTRIBUTION~nrc.gov

Facsimile: 301-415-2289

Some publications in the NUREG series that are

posted at NRC's Web site address

http://www.nrc.pov/readinp-rm/doc-collections/nureqs

are updated periodically and may differ from the last

printed version. Although references to material found

on a Web site bear the date the material was accessed,

the material available on the date cited may

subsequently be removed from the site.

Non-NRC Reference Material

Documents available from public and special technical

libraries include all open literature items, such as

books, Journal articles, and transactions, Federal

Register notices, Federal and State legislation, and

congressional reports. Such documents as theses,

dissertations, foreign reports and translations, and

non-NRC conference proceedings may be purchased

from their sponsoring organization.

Copies of industry codes and standards used in a

substantive manner in the NRC regulatory process are

maintained atThe NRC Technical Library

Two White Flint North

11545 Rockville Pike

Rockville, MD 20852-2738

These standards are available in the library for

reference use by the public. Codes and standards are

usually copyrighted and may be purchased from the

originating organization or. if they are American

National Standards, fromAmerican National Standards Institute

11 West 424 Street

New York, NY 10036-8002

www.ansi.org

212-642-4900

Legally binding regulatory requirements are stated

only in laws; NRC regulations; licenses, Including

technical specifications; or orders, not in

NUREG-series publications. The views expressed

in contractor-prepared publications in this series are

not necessarily those of the NRC.

The NUREG series comprises (1) technical and

administrative reports and books prepared by the

staff (NUREG-XXXX) or agency contractors

(NUREG/CR-XXXX), (2) proceedings of

conferences (NUREGICP-XXXX), (3) reports

resulting from International agreements

(NUREG/IA-XXXX), (4) brochures

(NUREG(BR-XXXX), and (5) compilations of legal

decisions and orders of the Commission and Atomic

and Safety Licensing Boards and of Directors'

decisions under Section 2.206 of NRC's regulations

(NUREG-0750).

J.
NUREG-1437

Supplement 23

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 23

Regarding

Point Beach Nuclear Plant Units 1 and 2

Final Report

Manuscript Completed: July 2005

Date Published: August 2005

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
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-1 437,

Volumes 1 and 2, and codified the results in Title 10 of the Code of Federal Regulations (CFR)

Part 51. In the GEIS (and its Addendum 1), the 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 the Nuclear Management Company, LLC (NMC), on

behalf of the owner, the Wisconsin Electric Power Company (WEPCO), to renew the OLs for

Point Beach Nuclear Plant Units 1 and 2 (PBNP) 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 staff's recommendation regarding the proposed action.

Regarding the 69 issues for which the GEIS reached generic conclusions, neither NMC nor the

staff has identified information that is both new and significant for any issue that applies to

PBNP. In addition, the staff determined that information provided during the scoping and the

draft SEIS comment processes did not call into question the conclusions in the GEIS.

Therefore, the staff concludes that the impacts of renewing the PBNP OLs would not be greater

than impacts identified for these issues in the GEIS. For each of these issues, the staff's

conclusion in the GEIS is that the impact would be 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 PBNP are addressed in this SEIS. With

the exception of the chronic effects of electromagnetic fields (for which the magnitude of impact

is uncertain"), for each applicable issue, the staff concludes that the significance of the

potential environmental impacts of renewal of the OLs would be SMALL. The staff also

concludes that additional mitigation measures are not likely to be sufficiently beneficial as to be

(a) Environmental impacts are not detectable or are so minor that they would neither destabilize nor

noticeably alter any important attribute of the resource.

August 2005 ... , NUREG-1437, Supplement 23
Abstract

warranted. The staff determined that information provided during the public comment period

I did not identify any new issue that requires site-specific assessment.

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

I environmental impacts of license renewal for PBNP would not be so great that preserving the

option of license renewal for energy-planning decisionmakers would be unreasonable. This

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

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

I staff's own independent review; and (5) the staff's consideration of public comments.

NUREG-1437, Supplement 23 iv August 2005
Contents

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

Executive Summary .......................................

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

1.0 Introduction ..........................................

................. xv

................. xx

................. 1-1

................. 1-2

................. 1-3

1.1

- 1.2

Report Contents ...............................

Background ...................................

. . .

. . .

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

1.2.2 License Renewal Evaluation Process .............. .............. 1-5

1.3

1.4

1.5

1.6

The Proposed Federal Action .....................

The Purpose and Need for the Proposed Action .......

Compliance and Consultations ....................

References ...................................

.................

.................

.................

.................

.. 1-7

.. 1-8

.. 1-9

.. 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 1

2.1.1 External Appearance and Setting ..

2.1.2 Reactor Systems ............................

2.1.3 Cooling and Auxiliary Water Systems ............

2.1.4 Radioactive Waste Management Systems and

Effluent Control Systems.. * ......................

2.1.4.1 Liquid Waste Processing Systems and Effluei

2.1.4.2 Gaseous Waste Processing Systems and Effl

2.1.4.3 Solid-Waste Processing ................

2.1.5 Nonradioactive Waste Systems .................

2.1.6 Plant Operation and Maintenance ...............

2.1.7 Power Transmission System ...................

................

................

................

2-1

2-4

2-4

2-7 

it Controls -....... ; 2-8

uent Controls ..... 2-9

2-10 

2-12 

2-12 

August 2005 v NUREG-1437, Supplement 23
Contents

2.2 Plant Interaction with the Environment ................................ 2-15

2.2.1 Land Use ...................................... 2-16

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

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

2.2.4 Air Quality .............. ........................ 2-19

2.2.5 Aquatic Resources ...................................... 2-22

2.2.6 Terrestrial Resources ...................................... 2-32

2.2.7 Radiological Impacts ...................................... 2-35

2.2.8 Socioeconomic Factors ...................................... 2-36

2.2.8.1 Housing ....................................... 2-36

2.2.8.2 Public Services ...................................... 2-37

2.2.8.3 Offsite Land Use ..................................... 2-39

2.2.8.4 Visual Aesthetics and Noise ............ ................ 2-41

2.2.8.5 Demography ...................................... 2-42

2.2.8.6 Economy ...................................... 2-44

2.2.9 Historic and Archaeological Resources . 2-47

2.2.9.1 Cultural Background .2-47

2.2.9.2 Historic and Archaeological Resources at PBNP Site . 2-53

2.2.10 Related Federal Project Activities and Consultations . .. 2-54

2.3 References .. . 2-55

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

3.1 References .. . 3-4

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

4.1 Cooling System .. 4-2

4.1.1 Entrainment of Fish and Shellfish in Early Life Stages . 4-10

4.1.2 Impingement of Fish and Shellfish . 4-14

4.1.3 Heat Shock . 4-19

NUREG-1 437, Supplement 23 vi August 2005

I r
Contents

4.2 Transmission Lines ................................................ 4-21

4.2.1 Electromagnetic Fields - Acute Effects ....... ................... 4-25

4.2.2 Electromagnetic Fields - Chronic Effects ...... .................. 4-27

4.3 Radiological Impacts of Normal Operations ....... ...................... 4-27

4.4 Socioeconomic Impacts of Plant Operations during the License

Renewal Period ................................................. 4-29

4.4.1

4.4.2

4.4.3

4.4.4

4.4.5

4.4.6

Housing Impacts during Operations .................. . ;... 4-31

Public Services: Public Utility Impacts during Operations ... 4-33

Offsite Land Use during Operations .. . 4-33

Public Services: Transportation Impacts during Operations .4-35

Historic and Archaeological Resources .4-36

Environmental Justice .4-38

4.5 Groundwater Use and Quality ..-

4.6 Threatened or Endangered Species ..................................

4.6.1

4.6.2

4.6.3

Aquatic Species ............................................

Terrestrial Species ..........................................

Conclusions ...............................................

-4-43

4-44

4-44

4-45

4-45

4-46

4-46

4.7 Evaluation of Potential New and Significant Information on

Impacts of Operations during the Renewal Term ........................

4.8 Cumulative Impacts of Operations during the Renewal Term ................

4.8.1 Cumulative Impacts Resulting from Operation of the

Plant Cooling System . ... . 4-47

4.8.2 Cumulative Impacts Resulting from Continued Operation of the

Transmission Lines ......................................... 4-49

4.8.3 Cumulative Radiological Impacts ................................. 4-50

4.8.4 Cumulative Socioeconomic Impacts ........ .................... 4-50

4.8.5 -Cumulative Impacts on Groundwater Use and Quality ..... ........... 4-52

4.8.6 Conclusions Regarding Cumulative Impacts ...... ................ 4-52

4.9 Summary of Impacts of Operations during.the'Renewal Term . 4-52

4.10 References . 4-53

I

I

I

I

I

I

I

August 2005 vii NUREG-1437, Supplement 23
Contents

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 . ................................................ 5-5

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 ...................................................... 5-9

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 . ............................................... 8-1

8.2 Alternative Energy Sources ............. ............................. 8-6

8.2.1 Coal-Fired Generation ........... ............................. 8-8

8.2.1.1 Closed-Cycle Cooling System ............................ 8-9

8.2.1.2 Once-Through Cooling System .......................... 8-23

8.2.2 Natural Gas-Fired Generation ..................... 8-24

NUREG-1437, Supplement 23 viii August 2005

I r
Contents

8.2.2.1 Closed-Cycle Cooling System ........................... 8-24

8.2.2.2 Once-Through Cooling System .............. ............ 8-33

8.2.3 Nuclear Power Generation ................................. 8-34

8.2.3.1 Closed-Cycle Cooling System . 8-35

8.2.3.2 Once-Through Cooling System .8-43

8.2.4 Purchased Electrical Power .8-44

8.2.5 Other Alternatives ...................... 8-45

8.2.5.1 Wind Power .... ....... ........... 8-45

8.2.5.2 Solar Power ...................... 8-46

8.2.5.3 Hydropower ......... .8-47......... 

8.2.5.4 Geothermal Energy .. 8-47

8.2.5.5 Wood Waste .. 8-47

8.2.5.6 Municipal Solid Waste ............................ .. 8-48

8.2.5.7 Other Biomass-Derived Fuels .. 8-49

8.2.5.8 Fuel Cells ......................... 8-49

8.2.5.9 Delayed Retirement ............................ 8-50

8.2.5.10 Utility-Sponsored Conservation . . ............ 8-50

8.2.6 Combination of Alternatives . ............................ 8-51

8.3 Summary of Alternatives Considered . 8-54

8.4 References . 8-54

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 . 9-6

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

9.2 Relative Significance of the Environmental Impacts of

License Renewal and Alternatives . 9-7

9.3 Staff Conclusions and Recommendations . 9-7

9.4 References . 9-9

August 2005 ix NUREG-1437, Supplement 23
Contents

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 Nuclear Management Company, LLC's Application for

License Renewal of Point Beach Nuclear Plant Units 1 and 2 ..... ........ C-1

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

Appendix E - Nuclear Management Company, LLC's Compliance Status

and Consultation Correspondence ............. .................... E-1

Appendix F - GEIS Environmental Issues Not Applicable to Point Beach

Nuclear Plant Units 1 and 2 . ...................................... F-1

Appendix G - NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs)

For Point Beach Nuclear Plant Units 1 and 2, in Support of License

Renewal Application ............................................ G-1

NUREG-1437, Supplement 23 x August 2005

I n
2-1

2-2

2-3

2-4

Figures

Location of PBNP, 80-km (50-mi) Region ............................. ...... 2-2

Location of PBNP, 10-km (6-mi) Region ................................ 2-3 -

PBNP Site Layout .. 2-5

PBNP Transmission Lines .. 2-14

4-1

4-2

4-2

Geographic Distribution of Minority Populations (Shown in Shaded Areas)

within 80 km (50 mi) of PBNP Based on Census Block Group Data .......... ;- 4-41 I

Geographic Distribution of Low-Income Populations (Shown in Shaded Areas) -

within 80 km (50 mi) of the PBNP Site Based on Census Block Group Data. 4-42 1

August 2005 xi NUREG-1437, Supplement 23
Tables

2-1 PBNP Transmission Line Rights-of-Way .2-13

I 2-2 Terrestrial Species Listed by the FWS as Endangered or Threatened

that Could Potentially Occur Within the PBNP Site or the

Associated Transmission Line ROWs .2-33

2-3 Housing Units and Occupied Housing Units for Manitowoc County and

Municipalities during 1990 and 2000 .2-37

2-4 Manitowoc County Public Water Suppliers and Capacities .2-38

2-5 School District Enrollment in Communities near PBNP .2-38

2-6 Traffic Counts for State Route 42 and County Road V .2-39

2-7 Land Use in Manitowoc County, 1999 .2-40

2-8 Population of Manitowoc County and Selected Municipalities .2-43

2-9 Population Projections for Wisconsin and Manitowoc County .2-43

2-10 Occupations in Nearby Municipalities and Manitowoc County . .2-44

2-11 Unemployment Rates for Manitowoc County in 2004 .2-44

2-12 Total Tax Revenues and Shared Revenue Utility Payments for the

Town of Two Creeks .2-46

2-13 Total Tax Revenues and Shared Revenue Utility Payments for Manitowoc County .. 2-47

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

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

4-1 Category 1 Issues Applicable to the Operation of the PBNP Cooling System

during the Renewal Term .4-2

4-2 Category 2 Issues Applicable to the Operation of the PBNP Cooling System

during the Renewal Term .4-10

4-3 Fish Impinged at PBNP during the 1975-1976 Impingement Study .4-15

4-4 Category 1 Issues Applicable to PBNP Transmission Lines during the

Renewal Term .4-22

4-5 Category 2 and Uncategorized Issues Applicable to PBNP Transmission

Lines during the Renewal Term .4-25

4-6 Category 1 Issues Applicable to Radiological Impacts of Normal Operations

during the Renewal Term .4-28

4-7 Category 1 Issues Applicable to Socioeconomics during the Renewal Term .4-29

4-8 Environmental Justice and GEIS Category 2 Issues Applicable to

Socioeconomics during the Renewal Term .4-31

NUREG-1437, Supplement 23 xii August 2005
Tables

4-9 Category 1 Issue Applicable to Groundwater Use and Quality during the -

Renewal Term- .................. .- 4-43

4-10 Category 2 Issue Applicable to Threatened or Endangered Species

during the Renewal Term .4-44

5-1 Category 1 Issue Applicable to Postulated Accidents during the Renewal Term ...... 5-3

5-2 Category 2 Issue Applicable to Postulated Accidents during the Renewal Term .. ..... 5-4

5-3 Core Damage Frequency ............................................... 5-6

5-4 Breakdown of Population Dose by Containment Release Mode ......... 5-7

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

Management. during the Renewal Term . 6-2

7-1 Category 1 Issues Applicable to the Decommissioning of PBNP following

the Renewal Term . 7-2

8-1 Summary of Environmental Impacts of the No-Action Alternative . 8-3

8-2 Summary of Environmental Impacts of Coal-Fired Generation Using Closed-Cycle

Cooling at the PBNP Site and an Alternate Site . 8-10

8-3 Summary of Environmental Impacts of Coal-Fired Generation with a Once-Through

Cooling System at the PBNP Site . 8-23

8-4 Summary of Environmental Impacts of Natural Gas-Fired Generation Using

Closed-Cycle Cooling at the PBNP Site and an Alternate Site . 8-26

8-5 Summary of Environmental Impacts of Natural Gas-Fired Generation with

Once-Through Cooling at the PBNP Site . 8-33

8-6 Summary of Environmental Impacts of New Nuclear Power Generation Using

Closed-Cycle Cooling at the PBNP Site and an Alternate Site . 8-36

8-7 Summary of Environmental Impacts of a New Nuclear Power Plant with

Once-Through Cooling at the PBNP Site . 8-44

8-8 Summary of Environmental Impacts of 646 MW(e) of Natural Gas-Fired

Generation, 200 MW(e) of Purchased Power, and 190 MW(e) from

Demand-Side Management Measures (Combination of Alternatives) . 8-52

9-1 Summary of Environmental Significance of License Renewal, the No-Action

Alternative, and Alternative Methods of Generation (from Chapters 4 and 8) . 9-8

A-1 Individuals Providing Comments during Scoping Comment Period . A-2

A-2 Comments Received on the Draft SEIS .. A-17

August 2005 MUi NUREG-1 437, Supplement 23
Tables

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

E-2 Federal, State, Local, and Regional Licenses, Permits, Consultations, and

Other Approvals for PBNP ............. ................................. E-2

F-1 GEIS Environmental Issues Not Applicable to PBNP .......................... F-1

G-1 PBNP Core Damage Frequency for Internal Events ........................... G-3

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

G-3 Level 1 PRA Summary ............... .................................. G-6

G-4 SAMA Cost/Benefit Screening Analysis ................................... G-21

I G-5 Uncertainty in the Calculated CDF for PBNP ............................... G-31

NUREG-1437, Supplement 23 xiv August 2005

I I
Executive Summary

By letter dated February 25, 2004, the Nuclear Management Company, LLC (NMC), submitted

an application on behalf of the owner, the Wisconsin Electric Power Company (WEPCO), to the

U.S. Nuclear Regulatory Commission (NRC) to renew the operating licenses (OLs) for Point

Beach Nuclear Plant Units 1 and 2 (PBNP) for, an additional 20-year period. If the OLs are

renewed, State regulatory agencies and PBNP's owner, WEPCO, 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 OLs are not renewed, then the

plants must be shut down at or before the expiration dates of the current OLs, which are

October 5, 2010, for Unit 1 and March 8,2013, for Unit 2.

The NRC has implemented Section 102 of the National Environmental Policy Act (N EPA).

(42 United States Code [USC] 4321) in Title 10 of the Code of Federal Regulations (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 NMC 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 staff visited the PBNP site in June 2004 and held public scoping meetings on

June 15, 2004, in Mishicot, Wisconsin. In the preparation of this supplemental environmental

impact statement (SEIS) for PBNP, the staff reviewed the NMC 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,'the Standard

Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating

License Renewatl and considered the public comments received during the scoping process.

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 I, of this SEIS.

A draft SEIS was published in January 2005. iThe staff held two public meetings in Mishicot,

Wisconsin, on March 3, 2005, 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. When the 75-day comment period ended, the staff

considered and dispositioned all of the comments received. These comments are addressed in

Appendix A,;Part II, of this SEIS. --

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

references to the OGEIS" include the GEIS and its Addendum 1.

August 2005 xv . NUREG-1437, Supplement 23
-MExecutive Summary

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 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) decisionmakers.

The evaluation criterion for the 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 decisionmakers 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 would 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).

NUREG-1437, Supplement 23 xvi August 2005

I V
Executive Summary

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 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

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 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 staff relied on conclusions as amplified by supporting information in

the GEIS for issues designated as Category I 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 nmust be addressed in a

August 2005 xvii - NUREG-1 437, Supplement 23
1tL

Executive Summary

plant-specific 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 staff's consideration of all 92 environmental issues identified in the

GEIS. The 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 PBNP OLs) and alternative methods of power generation. Based on projections

made by the U.S. Department of Energy's Energy Information Administration, gas- and

coal-fired generation appear to be the most likely power-generation alternatives if the power

from PBNP is replaced. These alternatives are evaluated assuming that the replacement

power generation plant is located at either the PBNP site or some other unspecified alternate

location.

NMC and the staff have established independent processes for identifying and evaluating the

significance of any new information on the environmental impacts of license renewal. Neither

NMC nor the staff has identified information that is both new and significant related to

Category 1 issues that would call into question the conclusions in the GEIS. Similarly, neither

the scoping process nor the staff has identified any new issue applicable to PBNP that has a

significant environmental impact. These determinations included consideration of public

comments. Therefore, the staff relies upon the conclusions of the GEIS for all of the

Category 1 issues that are applicable to PBNP.

NMC's license renewal application presents an analysis of the applicable Category 2 issues.

The staff has reviewed the NMC analysis for each issue and has conducted an independent

review of each issue. Six Category 2 issues are not applicable, because they are related to

plant design features or site characteristics not found at PBNP. Four Category 2 issues are not

discussed in this SEIS, because they are specifically related to refurbishment. NMC 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 PBNP for the license renewal period. In addition, any replacement of components

or additional inspection activities are within the bounds of normal plant operation and are not

expected to affect the environment outside of the bounds of the plant operations evaluated in

the U.S. Atomic Energy Commission's 1972 Final Environmental Statement Related to

Operation of Point Beach Nuclear Plant Units 1 and 2.

Eleven 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 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 11 Category 2 issues and

NUREG-1437, Supplement 23 xviii August 2005

I I.
Executive Summary

environmental justice, the staff concludes that the potential environmental impacts would be of

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

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

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

made, the staff concludes that none of the candidate SAMAs is cost-beneficial. Although none

of the SAMAs appear cost-beneficial in the baseline analysis, the staff concluded that one

SAMA could be cost-beneficial when uncertainties or alternative discount rates are taken into.-

account. However, this SAMA does not relate to adequately managing the effects of aging

during the period of extended operation. Therefore, it need not be implemented as part of the

license renewal pursuant to 10 CFR Part 54.

Mitigation measures were considered for each Category 2 issue. Current measures to mitigate

the environmental impacts of plant operation were found to be adequate, and no additional

mitigation measures were deemed sufficiently beneficial to be warranted.

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 PBNP license renewal impacts are deemed

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

impacts on potentially affected resources.

If the PBNP OLs are not renewed and the units cease operation on or before the expiration of

their current operating licenses, then the adverse impacts of likely alternatives would not be

smaller than those associated with continued operation of PBNP. The impacts may, in fact, be

greater in some areas. ---

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

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

of license renewal for energy planning decisionmakers would be unreasonable. This

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

NMC; (3) consultation with other Federal, State, and local agencies; (4) the staff's own

independent review; and (5) the staff's consideration of public comments.'

August 2005 Axi NUREG-1 437, Supplement 23
Abbreviations/Acronyms

° .degree(s)

pm micrometer(s)

ac acre(s)

AC alternating current

ACC averted cleanup and decontamination costs

ADAMS Agencywide Document Access and Management System

AEC U.S. Atomic Energy Commission

AFW auxiliary feedwater

AOC averted offsite property damage costs

AOE averted occupational exposure costs

AOSC averted onsite costs

APE averted public exposure

AQCR Air Quality Control Region

ATC American Transmission Company

ATWS anticipated transient without scram

AVD AVD Archaeological Services, Inc.

Bq becquerel(s)

BTU British thermal unit(s)

C Celsius

CAA Clean Air Act

CCW component cooling water

CDF core damage frequency

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic feet per second (same as ft3/sec)

Ci curie(s)

cm centimeter(s)

l cm2 square centimeter(s)

COE cost of enhancement

CST condensate storage tank

cu cubic

CWA Clean Water Act of 1977

d day(s)

dB decibel(s)

DBA design-basis accident

NUREG-1 437, Supplement 23 xx August 2005

I I
Abbreviations/Acronyms

DC direct current

DOE U.S. Department of Energy

DOI U.S. Department of Interior

DSM demand-side management

ECCS emergency core cooling system -

EIA Energy Information Administration (of DOE)

EIS environmental impact statement

ELF-EMF extremely low frequency-electromagnetic field

EOP emergency operating procedure

ESA Endangered Species Act of 1973

EPA U.S. Environmental Protection Agency

ER Environmental Report

ESRP Standard Review Plans for Nuclear Power Plants, Supplement 1: Operating

License Renewal

F Fahrenheit

FES Final Environmental Statement

FR Federal Register

FSAR final safety analysis report

ft foot (feet)

ft2 square feet

ft3 cubic feet

ftW/s cubic feet per second (same as cfs)

FWS U.S. Fish and Wildlife Service

GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

NUREG-1437

GEn&SIS Geographical, Environmental, and Siting Information System -

GLARC Great Lakes Archaeological Research Center, Inc.

gpd gallon(s) per day

gpm gallon(s) per minute

h hour(s)

ha hectare(s)

HEP Human Error Probability

HLW high-level waste

HRA human reliability analysis

Hz hertz

IGCC integrated coal gasification combined cycle

August 2005 xxi NUREG-1437, Supplement 23
Abbreviations/Acronyms

in.

I in.2

IPE

I IPEEE

ISFSI

ISLOCA

inch(es)

square inches

Individual Plant Examination

Individual Plant Examination of External Events

independent spent fuel storage installation

interfacing systems loss-of-coolant accident

J joule(s)

kg

KNPP

km

km 2

kV

kW

I kWh

kilogram(s)

Kewaunee Nuclear Power Plant

kilometer(s)

square kilometer(s)

kilovolt(s)

kilowatt(s)

kilowatt-hour(s)

L

lb

LOCA

LOOP

liter(s)

pound(s)

loss-of-coolant accident

loss of offsite power

m

l m3

mA

MAAP

MACCS2

MCPPC

I MFW

i mGy

mi

min

mph

mrad

MRCC

mrem

MSIV

mSv

MT

I MTHM

MW

meter(s)

cubic meter(s)

milliampere(s)

Modular Accident Analysis Program

MELCOR Accident Consequence Code System 2

Manitowoc County Planning and Park Commission

main feedwater

milligray

mile(s)

minute(s)

mile(s) per hour

millirad(s)

Midwestern Regional Climate Center

millirem(s)

main steam isolation valve

millisievert(s)

metric ton(s) (tonne[s])

metric ton(s) heavy metal

megawatt(s)

NUREG-1437, Supplement 23 xxii August 2005

I l;
Abbreviations/Acronyms

MWd/MTU megawatt day(s) per metric ton of uranium

MW(e) megawatt(s) electric

MWh megawatt hour(s)

MW(t) megawatt(s) thermal

NAS National Academy of Sciences

NEPA National Environmental Policy Act of 1969

NESC National Electrical Safety Code

ng nanogram(s)

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMC Nuclear Management Company, LLC

NOAA National Oceanographic and Atmospheric Administration

NOX nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System

NRC U.S. Nuclear Regulatory Commission

NRHP National Register of Historic Places

ODCM Offsite Dose Calculation Manual

OL operating license

PBNP Point Beach Nuclear Plant Units 1 and 2

pCi picocurie(s)

PCBs polychlorinated biphenyls

PCS power conversion system

PM10 particulate matter, 10 micrometers or less in diameter

ppb parts per billion

ppm parts per million

PRA probabilistic risk assessment

PWR pressurized-water reactor -- - -

RAI request for additional information

RCP reactor cooling pump

RCS reactor coolant system

rem roentgen equivalent man

RHR residual heat removal

ROW right-of-way

RPC replacement power costs

RWST refueling water storage tank

s second(s)

August 2005 xxiii NUREG-1 437, Supplement 23
I I I

Abbreviations/Acronyms

SAMA Severe Accident Mitigation Alternative

SAR safety analysis report

SBO station blackout

SEIS Supplemental Environmental Impact Statement

SER safety evaluation report

SGTR steam generator tube rupture

SHPO State Historic Preservation Office

Si safety injection

S02 sulfur dioxide

SOx sulfur oxide(s)

sp. species (singular)

spp. species (plural)

SRV safety relief valve

Sv sievert(s)

SW service water

U.S. United States

USC United States Code

USCB U.S. Census Bureau

USGS U.S. Geological Survey

USDOT U.S. Department of Transportation

WDA Wisconsin Department of Administration

WDNR Wisconsin Department of Natural Resources

WDOT Wisconsin Department of Transportation

WDR Wisconsin Department of Revenue

WDWD Wisconsin Department of Workforce Development

WEPCO Wisconsin Electric Power Company

WHS Wisconsin Historical Society

WPDES Wisconsin Pollutant Discharge Elimination System

yd yard(s)

yr year(s)

NUREG-1437, Supplement 23 xxiv August 2005

I lie
1.0 Introduction

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

in Title 10 of the Code of Federal Regulations (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 staff has prepared a Generic Environmental Impact Statement for

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

1999).(a) 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

must be addressed by the applicants in plant-by-plant renewal proceedings. Use of the GEIS

guides the preparation of complete plant-specific information in support of the OL renewal

process.

The Nuclear Management Company, LLC (NMC) operates Point Beach Nuclear Plant

Units 1 and 2 (PBNP) in Wisconsin on behalf of the owner, the Wisconsin Electric Power

Company (WEPCO), under OLs DPR-24 and DPR-27, which were issued by the NRC. 'These '

OLs will expire on October 5,2010, for Unit land March 8, 2013, for Unit 2. On February 25,

2004, NMC submitted an application to the NRC for renewal of the PBNP OLs for an additional'-

20 years under the procedures in 10 CFR Part 54. NMC is a licensee for the purposes of its

current OLs and an applicant for the renewal of the OLs. Pursuant'to 10 CFR 54.23 and -

51.53(c), NMC submitted an Environmental Report (ER) (NMC 2004a)'in which NMC analyzed

the environmental impacts associated with the proposed license renewal action, considered

alternatives to the proposed license renewal action, and evaluated mitigation measures for

reducing adverse environmental impacts.

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

NMC license renewal application. This SEIS is a supplement to the GEIS because it relies, in'

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

in accordance with 10 CFR Part 54. -

(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.

August 2005 1 -1 NUREG-1437, Supplement 23
1

Introduction

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 staff to assess

the environmental impacts associated with license renewal, (2) describe the proposed Federal

action to renew the PBNP OLs, (3) discuss the purpose and need for the proposed action, and

(4) present the status of NMC'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 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 (SAMAs). 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 the human environment and the maintenance and enhancement of

| long-term productivity, and the irreversible or irretrievable commitment of resources. Chapter 9

also presents the staff's recommendation with respect to the proposed license renewal action.

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

received on the environmental review for license renewal and staff responses. Appendixes B

through G, respectively, list the following:

* The preparers of the supplement

* The chronology of the NRC staff's environmental review correspondence related to this

SEIS

* The organizations contacted during the development of this SEIS

* NMC'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 PBNP

* SAMAs.

NUREG-1437, Supplement 23 1-2 August2005

l I
Introduction

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 ElSs.

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

impacts, (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 l6vel for all plants.

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

Environmental Quality (CEQ) teriminology for "significantly" (40 'CFR 1508.27, which requires

consideration of both "context" and uintensity").- Using the CEO 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 after 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.

August 2005 1 -3 NUREG-1437, Supplement 23
. . - - _ _ _ - - - - - _ _ _ _ _ _ _ -- _ __ -L L L _

Introduction

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

mitigation measures would continue.

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 (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 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 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 issues not categorized were environmental justice and chronic effects of electromagnetic

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

plant-specific supplement to the GEIS. 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.

NUREG-1437, Supplement 23 1-4 August 2005

I I
Introduction

1.2.2 License Renewal Evaluation Process

An applicant seeking to renew its OLs is required to submit an ER as part of its application

(10 CFR 54.23).' 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.

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 CPR Part 51,

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

* 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 .53(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-l'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 PBNP OLs, NMC developed a process to

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

Auaust 2005 1-5 NUREG-1437. * _ .Supplement F r 23
I vr -

Introduction

environmental impacts of license renewal for PBNP would be properly reviewed before

submitting the ER and to ensure that such new and potentially significant information related to

renewal of the licenses would be identified, reviewed, and assessed during the period of NRC

review. NMC 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

PBNP. This review was performed by personnel from NMC and its support organization who

were familiar with NEPA issues and the scientific disciplines 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 (ESRP), NUREG-1 555, Supplement 1

(NRC 2000). The search for new information includes (1) a review of an applicant's ER and the

process for discovering and evaluating the significance of new information; (2) a review of

records of public comments; (3) a 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 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 PBNP. At the beginning of the discussion of each set of issues, there is a table

that 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 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 NMC license renewal application began with publication of a notice of acceptance for

docketing and opportunity for a hearing in the Federal Register (69 FR 19559-19561

(NRC 2004a]) on April 13, 2004. The staff published a notice of intent to prepare an EIS and

conduct scoping in the Federal Register (69 FR 26624-26626 [NRC 2004b]) on May 13, 2004.

NUREG-1 437, Supplement 23 1-6 August 2005

I I
Introduction

Two public scoping meetings were held on June 15, 2004, in Mishicot, Wisconsin. Comments

received during the scoping period were summarized in the Environmental Impact Statement

Scoping Process: Summary Report - Point Beach Nuclear Plant Units 1 and 2, Manitowoc

County, Wisconsin (NRC 2004c) dated September 3, 2004. Comments applicable to this

environmental review are presented in Part I of Appendix A.

The staff followed the review guidance contained in NUREG-1 555 (NRC 2000). The staff and

contractors retained to assist the staff visited the PBNP site on June 16 and 17, 2004, to gather

information and to become familiar with the site and its environs. The 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 PBNP were reviewed and are referenced in this report.

On January 26, 2005, the NRC published a Notice of Availability of the draft SEIS in

70 FR 3744-3745 (NRC 2005a).- A 75-day comment period began on the date of publication of

the U.S. Environmental Protection Agency Notice of Filing of the draft SEIS to allow members,

of the public to comment on the preliminary results of the NRC staff's review. During this

comment period, two public meetings were held in Mishicot, Wisconsin, on March 3, 2005.

During these meetings, the 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 PBNP draft SEIS ended on

April 13,2005. Comments made during the 75-day public comment period are presented in

Part II of Appendix A of this SEIS. The NRC responses to these comments are also provided.

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

the proposed renewal of the PBNP OLs, the environmental impacts of alternatives to license

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

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 decisionmakers would

be unreasonable.

1.3 The Proposed Federal Action

The proposed Federal action is renewal of the PBNP OLs. The PBNP site is located on the

western shore of Lake Michigan in Manitowoc County, Wisconsin, approximately 48 km (30 mi)

southeast of Green Bay and 24 km (15 mi) north-northeast of Manitowoc (NMC 2004a, 2004b).

PBNP has two Westinghouse pressurized water reactors. Each reactor was originally designed

to produce a reactor thermal output of 1518.5 megawatts thermal (MW[tI) and to generate,

August - 2005 1-7 NUREG-1437, Supplement 23
I I

Introduction

523.8 megawatts electric (MW[e]) of gross electrical power (NMC 2004a). Each unit underwent

a low-pressure turbine retrofit modification that increased the unit design output to

537.96 MW(e). In 2003, PBNP underwent a 1.4 percent uprate, which increased the rated

thermal output to 1540 MW(t) and increased the gross electrical power to 545 MW(e)

(518 MW[e] net). Plant cooling is provided by a once-through cooling water system that

withdraws water from Lake Michigan and dissipates heat by discharge back into Lake Michigan.

PBNP produces approximately 25 percent of the electricity that WEPCO provides to

approximately 1.08 million customers (NMC 2004a).

The current OL for Unit 1 expires on October 5, 2010, and for Unit 2 on March 8, 2013. By

letter dated February 25, 2004, NMC submitted an application to the NRC (NMC 2004b) to

renew these OLs for an additional 20 years of operation (i.e., until October 5, 2030, for Unit 1

and March 8, 2033, for Unit 2).

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 plant owner (WEPCO) will ultimately

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

or other matters within the jurisdiction of the State or the purview of the owners.

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

need from the GEIS, Section 1.3 (NRC 1996):

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) decisionmakers.

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 (Title 42 United States

Code [USC] 2011) 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.

NUREG-1437, Supplement 23 1-8 August 2005

I I
Introduction

1.5 Compliance and Consultations

NMC and/or WEPCO are required to hold certain Federal, State, and local environmental

permits in order to operate PBNP, as well as meet relevant Federal and State statutory

requirements. In the PBNP ER (NMC 2004a), NMC provided a list of the authorizations from

Federal, State, and local authorities for current operations as well as environmental approvals

and consultations associated with renewal of the PBNP OLs. Authorizations and consultations'

relevant to the proposed OL renewal action are included in Appendix E.

The 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 (NMC 2004a) states that NMC is in compliance with applicable

environmental standards and requirements for PBNP. The staff also has not identified any

environmental issues that are both new and significant.

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, as amended. 42 USC 2011 et seq.

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

Nuclear Management Company, LLC. (NMC). 2004a. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

Nuclear Management Company, LLC. (NMC). 2004b. Application for Renewed Operating

Licenses, Point Beach Nuclear Plant Units 1 and 2. Two Rivers, Wisconsin.

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

for License Renewal of Nuclear Plants. NUREG-1 437, Volumes 1 and 2, Washington, D.C.

August 2005 1 -9 NUREG-1437, Supplement 23
_ _ _ _ _ _ -- _ _ ~_ I. .LL

Introduction

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). 2000. Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1 555,

Supplement 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004a. "Notice of Acceptance for Docketing of

the Application and Notice of Opportunity for a Hearing Regarding Renewal of License

Nos. DPR-24 and DPR-27 for an Additional Twenty-Year Period." Federal Register, Vol. 69,

No. 71, pp. 19559-19561, Washington, D.C. April 13, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004b. "Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process." Federal Register, Vol. 69,

No. 93, pp. 26624-26626, Washington, D.C. May 13, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004c. Environmental Impact Statement

Scoping Process: Summary Report - Point Beach Nuclear Plant Units 1 and 2, Manitowoc

County, Wisconsin. Washington, D.C. September 3, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2005. "Nuclear Management Company, LLC

Point Beach Nuclear Plant, Units 1 and 2; Notice of Availability of the Draft Supplement 23 to

the Generic Environmental Impact Statement and Public Meeting for the License Renewal of

Point Beach Nuclear Plant, Units 1 and 2." Federal Register, Vol. 70, pp. 3744-3745,

Washington, D.C. January 26, 2005.

NUREG-1 437, Supplement 23 1-10 August 2005

I III
2.0 Description of Nuclear Power Plant and Site

and Plant Interaction with the Environment

Point Beach Nuclear Plant Units 1 and 2 (PBNP) are located in Manitowoc County, Wisconsin,

on the western shore of Lake Michigan. The plant consists of two units. Each unit is a

pressurized-water reactor with steam generators producing steam that turns turbines to

generate electricity. -Plant cooling is provided by a once-through system using water from Lake

Michigan. The plant and its environs are described in Section 2.1, and the plant's interaction

with the environment is presented in Section 2.2.

2.1 Plant and Site Description and Proposed Plant Operation

during the Renewal Term

PBNP is located on the western shore of Lake Michigan, approximately 48 km (30 mi)

southeast of Green Bay and 24 km (15 mi) north-northeast of Manitowoc (Nuclear Management

Company, LLC [NMCj 2004a). The area within 10 km (6 mi) of PBNP includes portions of

Manitowoc and Kewaunee counties and is largely rural, characterized by farmland, woods, and

small residential communities. The nearest town is Two Creeks, approximately 2 km (1 mi)

north-northwest of the site. PBNP is approximately 10 km (6 mi) east-northeast of Mishicot,

13 km (8 mi) north of Two Rivers, and 18 km (11 mi) south of Kewaunee. The Oneida Indian

Reservation is located on the western edge of Green Bay, approximately 56 km (35 mi)

northwest of the plant. The PBNP property covers approximately 510 ha (1260 ac). Structures

and parking lots occupy about 28 ha (70 ac). Figures 2-1 and 2-2 show the site location and

features within 80 km (50 mi) and 10 km (6 mi), respectively (NMC 2004a).

2.1.1 External Appearance and Setting

PBNP is owned by Wisconsin Electric Power Company (WEPCO) and operated by NMC. Site

structures include two reactor containments, auxiliary and service buildings, turbine building,

office building, switchyard, pump house, cooling water intake and discharge structures, and an

independent spent fuel storage installation (ISFSI) (NMC 2004a). Approximately 425 ha

(1050 ac) are used for agriculture. The remaining area is a mixture of woods, wetlands, and

open areas. The site includes approximately 3 km (2 mi) of continuous frontage on the western

shore of Lake Michigan.

The local terrain is gently rolling to flat, with elevations varying from 1.5 to 18 m (5 to 60 ft)

above the normal level of Lake Michigan. The land surface slopes gradually toward the lake

from higher glacial moraine areas west of the site. Low bluffs face the Lake Michigan shore,

August 2005 2-1 NUREG-1437, Supplement 23
I I. . _

Plant and the Environment

5 0 5 ID i 5 2D

6 0 6 12 18 24 30O.OW

'[ 50-MN.e Vicinity Map

Figure 2-1. Location of PBNP, 80-km (50-mi) Region

NUREG-1437, Supplement 23 2-2 August 2005

I I
Plant and the Environment

APoint Beac

I .Pe 1...-

L*eaw1\m I Ii .- -. i ; 050 ;-- - '' 33 " '' u 

i\twy Keaue |at [ Mapeg : I.s 

Figuret 2-2. Locto of 10-k :, '(6-mi Region, .- \

August 25 2 Cks3 ' 43' S 23

_> J- . t~~~~~~~~~~~Burie Faret t'. -,! <.'S ;\........................._*...

'' .Si.'s 'i ; .................................. .^...... . J I§ =. . X:. _. , ..C _

S | 1 '1- ';-: . - . I .u _0, ;-;oit Bea*

{ 1 : CeE * ;. - X-. j .l, !,W' .

.Mani l ...Towo Cs .t....... ,. ,:f,,......

| | ~~~ 9\ li4JT~Scadk Fores <; ,, .t...

. ae ., --an Won -5 0 05 I 13 2 3 3S 4 K.. . .

Coit Ro a-- t antwo 

Augus 200 2 . NUE-47 Suchffen 235t*
_ _,

Plant and the Environment

with evidence of marked erosion near the center of the PBNP site. At this point, the beach is

narrow (ranging in width from 6 m to 15 m [20 ft to 50 ft]), with bare mud slopes showing active

erosion due to Lake storms. Historically, shoreline recession has ranged from 0.8 m to 1.5 m

(2.5 ft to 5 ft) per year in this area. WEPCO has provided riprap to control further recession of

the shoreline at the site (NMC 2004a).

2.1.2 Reactor Systems

PBNP has two Westinghouse reactors moderated and cooled by pressurized light water. Each

unit was originally designed to produce a reactor thermal output of 1518.5 megawatts thermal

(MW[t]). All steam and power conversion equipment, including each turbine generator, was

originally designed to permit generation of 523.8 megawatts of gross electrical power (MW[e)).

Unit 1 achieved commercial operation in December 1970, and Unit 2 achieved commercial

operation in October 1972. Since being placed into commercial operation, each unit underwent

a low-pressure turbine retrofit modification that increased the unit design output to 538 MW(e).

In 2003, PBNP underwent a 1.4 percent power uprate, which increased the rated thermal

output to 1540 MW(t) and increased the gross electrical power to 545 MW(e) (518 MW[e] net).

New PBNP fuel is slightly enriched to contain a nominal 5.0 weight percent of uranium-235, with

an average burnup for the peak rod of 45,000 megawatt-days per metric ton uranium

(NMC 2004a).

The PBNP facility is depicted in Figure 2-3. Each reactor is housed in its own containment

structure (labeled "Reactor Structures" in Figure 2-3), together with its primary cooling system,

associated steam generators, and circulation system. Each reactor containment structure is a

steel-lined, reinforced-concrete cylinder with a hemispheric dome and a flat reinforced-concrete

foundation mat. A common gallery containing the principal radioactive waste systems and the

control room is located between the two reactor units, which lie north and south of the common

gallery in a single structure. The containment structures are encased in vinyl coated steel

buildings that are colored to blend in with the green and brown Wisconsin countryside

(U.S. Atomic Energy Commission [AEC] 1972).

2.1.3 Cooling and Auxiliary Water Systems

Lake Michigan is the source of water for the cooling and auxiliary water systems at PBNP,

which operates as a once-through cooling plant. Water from Lake Michigan reaches PBNP

through a submerged offshore intake. Water returns to Lake Michigan through a surface

shoreline discharge. The system removes waste heat from the condensers as well as other

plant equipment and discharges water through separate flumes for each unit. At peak capacity,

water is circulated at a maximum rate of 22 m3/s (777 ft3/s) through each condenser and then

NUREG-1 437, Supplement 23 2-4 August 2005

I I
Plant and the Environment

Figure 2-3. PBNP Site Layout

August 2005- 2-5- NUREG-1437, Supplement 23
-

I L:L

Plant and the Environment

returned to the Lake. The maximum total intake of water by PBNP is approximately 44 m3/s

(1554 ft3/s) when both units are at full power operation. The consumptive net loss within the

plant is minimal (less than 0.1 percent of the total intake) (WEPCO 2003, NMC 2004a). Thus,

with both units operating at full power, a maximum outflow of approximately 44 m3/s (1554 Ifts)

would be returned to the Lake. The water withdrawn for these systems flows first through the

offshore intake structure to the forebay, then to the condensers and other equipment. Auxiliary

water systems include the service water system and the fire protection system.

Lake water is provided to the forebay through two 4.3-m (14-ft) diameter pipes buried beneath

the lakebed. Water enters these pipes at the offshore intake structure. The offshore intake

structure is an annulus of steel pilings with limestone blocks between the steel pilings. The

cylinder stands upright on the lakebed 533 m (1750 ft) offshore in 6.7 m (22 ft) of water. As

originally designed, the offshore intake structure had a top elevation of 2.4 in (8 ft) above water

level. However, the original structure attracted a large number of birds during the spring and

fall migration and contributed to a number of bird mortalities. In May 2001, the offshore intake

structure was reconfigured to address the bird mortality issue. As modified, the offshore intake

structure stands approximately 3.4 m (11 ft) tall above the lake floor, has an outside diameter of

34 in (110 ft), and an inside chamber with a diameter of 18 m (60 ft); the offshore intake

structure is now completely submerged. The top is covered with a steel superstructure

supporting a trash rack made of high-density polyethylene having approximately 18 x 46 cm

(7 x 18 in.) openings. In addition, in 2002, WEPCO installed a permanent fish deterrent system

around the intake structure under a compliance agreement with the U.S. Fish and Wildlife

Service (FWS). This system makes use of high-frequency sound (125 kilohertz) to minimize

the influx of fish into the intake structure.

Water enters the chamber through the trash rack as well as through void spaces around the

limestone blocks and through 76 cm (30 in.) diameter pipes that penetrate the blocks in a ring

1.5 m (5 ft) above the lakebed. The pipes are covered with 3 x 5 cm (1.2 x 2 in.) bar grating to

prevent debris and large fish from entering the intake system. In 1980, the original intake

structure was modified to reduce problems with ice formation. Modifications consisted of the

installation of four 2 x 2 m (6.5 x 6.5 ft) concrete pipes near the lake bottom in the south half of

the intake crib. The pipes are covered with a grating that is hinged for lowering in the winter

months (usually December 1 to March 1) to prevent the formation of frazzle ice on the grate

and the subsequent restriction of water flow. The modification was also designed to lower the

velocity of water approaching the offshore intake structure. Three of the four pipes were

retained during the May 2001 modification. A trash rack, bar grates, and traveling screens are

located in the forebay, where small debris and trapped fish are collected in baskets and

removed before they can enter the circulating water system.

Water circulated through the condensers is discharged to the Lake through two steel piling

troughs at the lake surface extending in opposite directions (at 30-degree angles from the plant

NUREG-1437, Supplement 23 2-6 August 2005

I I
Plant and the Environment

centerline) approximately 61 rri (200 ft) out into Lake Michigan. The hormal temperature

increase over the ambient water temperature at the point of discharge is about 13 0C (23 OF).

The momentum of the discharge velocity is sufficient to create a high degree of mixing with the

Lake water in the immediate vicinity.

The system is designed to control the formation of needle ice within the intake structure during

the winter months by using warm water feedback. The recirculation of heated effluent back

through the pump house forebay reduces the net rate of water withdrawal from the Lake to

10 m3/s (353 ft3/s) for each unit (NMC 2004a).

Sodium hypochlorite and various biocides are injected into the cooling water at the pump house

forebay to control aquatic nuisances and algal growth. In addition, an electrolytic system

continuously adds copper to the service water at a rate of 5 to 10 parts per billion to control

biological fouling of the service water.

2.1.4 Radioactive Waste Management Systems and Effluent Control Systems

PBNP uses liquid, gaseous, and solid radioactive waste management systems to collect and

treat the radioactive materials that are a by-product of PBNP operations. These systems

process radioactive liquid, gaseous, and solid effluents to maintain releases within regulatory

limits and to maintain levels as low as reasonably achievable before they are~ released to the

environment. The PBNP waste processing systems meet the design objectives of Title 10 of

the Code of Federal Regulations (CFR), Part 50, Appendix 1, uNumerical Guides for Design

Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low as is

Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor

Effluents."

Radioactive material in the reactor coolant is the primary source of gaseous, liquid, and solid

radioactive wastes in light-water reactors. Radioactive fission products build up within the fuel

as a consequence of the fission process; These fission products are contained in the sealed

fuel rods, but small quantities escape from the fuel rods and contaminate the reactor coolant.

Neutron activation of the primary coolant system is also responsible for coolant contamination.

Nonfuel solid waste results from treating and separating radionuclides from gases and liquids

and from removing contaminated material from various reactor areas.- Solid waste also consists' -

of reactor components, equipment, and tools removed from service, as well as contaminated

protective clothing, paper, rags, and other trash generated from plant design modifications,

operations, and routine maintenance activities. Solid waste is shipped to a waste processor for '

volume reduction before disposal or is sent directly to the licensed disposal facility. Spent

resins and filters are -dewatered and packaged for shipment to licensed offsite processing or

disposal facilities (NMC 2003a). -

August 2005 2-7 NUREG-1 437, Supplement 23
__ ___ _LLL

Plant and the Environment

Fuel assemblies that have exhausted a certain percentage of their fuel and have been removed

from the reactor core for disposal contain spent fuel. PBNP currently operates on a nominal

18-month refueling cycle. The spent fuel is currently stored on site in the spent fuel pool in the

auxiliary building adjacent to the containment building or in dry cask storage at the onsite ISFSI.

The Offsite Dose Calculation Manual (ODCM) for PBNP describes the methods used for

calculating the concentration of radioactive material in the environment and the estimated

potential offsite doses associated with liquid and gaseous effluents from PBNP (NMC 2003b).

The ODCM also specifies controls for release of liquid and gaseous effluents to ensure

compliance with the NRC regulations.

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls

Radioactive fluids entering the waste disposal system are collected in tanks for analysis prior to

discharge and/or further treatment. Each unit has a steam generator blowdown tank and one

reactor coolant drain tank inside each containment. Units 1 and 2 share one laundry and hot

shower tank, one chemical tank, one waste holdup tank, two waste condensate tanks, and one

waste distillate tank. As the primary means for processing all radioactive liquid waste effluents,

the blowdown evaporator system is designed to remove radioactive particulates and gases from

radioactive liquid waste and from steam generator blowdown water in the event of primary to

secondary leakage. Evaporator bottoms and ion exchange resins are pumped to the primary

auxiliary building truck bay for dewatering prior to shipment for disposal. All piping, pumps, and

valves carrying the liquid wastes are stainless steel and have provisions to minimize leakage,

prevent over-pressurization, and isolate equipment as required for operation and maintenance

(NMC 2003a).

All liquid waste components except the reactor coolant drain tank are located in the auxiliary

building and any leakage from the tank or piping would be collected in the building sump to be

pumped back into the liquid waste system. The building sump and basement volume are

sufficient to hold the full volume of a liquid holdup tank without overflowing to areas outside the

building. The full volume of either the volume control tank or the waste holdup tank would be

contained in the auxiliary building (NMC 2003a).

All liquid wastes are monitored prior to release. The radiation monitoring system monitors the

effluent, closing the discharge valve if the amount of radioactive material in the effluent exceeds

preset values. These values are established using the methodology described in the ODCM

(NMC 2003b).

During 2003, there was a total amount of radioactive material (fission and activation products)

of 5 x 1 O0 Bq (0.16 Ci) and a total amount of tritium of 2.77 x 1 io Bq (748 Ci) released from

NUREG-1437, Supplement 23 2-8 August 2005

I I
Plant and the Environment

PBNP. These levels are typical of past years and are within regulatory limits (NMC 2000, 2001,

2002). See Section 2.2.7 for a discussion of the calculated doses to the maximally exposed

individual as a result of these releases. Absent a change in licensed power levels, NMC does

not anticipate any increase in liquid waste releases during the license renewal period.

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls

PBNP ventilation is designed to maintain gaseous effluents to levels as low as reasonably

achievable.' -This is done by a combination of holdups for decay of short-lived radioactive

material, filtration, and monitoring. Gases from the primary containment system are held in

decay tanks for up to 45 days prior to release .through the auxiliary building ventilation stack.

Gases from other areas of the plant, such as the spent fuel pool, radioactive waste handling

area, auxiliary building, service building, and chemistry laboratory are filtered and monitored

prior to release. The primary release points at PBNP are the auxiliary building vent stack, the

Unit 1 and 2 containment purge stacks, and the drumming areas vent stack. These four - -

release points are equipped with shutoff valves that close if the activity levels exceed the alarm,

set point of the monitor. The basis for the value of the alarm set point is discussed in the

ODCM.- The unmonitored release point is the exhaust from the turbine building, where airborne

radioactive material is not expected. Areas of the plant that could contain low levels of

radioactive contaminants in the event of primary to secondary leakage, such as the turbine

building, are not provided with high-efficiency particulate air filters or carbon absorber

equipment, because releases from these areas are insignificant.

During 2003, the total amount of radioactive material released from PBNP (NMC 2004c)

occurred in the following forms:

* Fission and activation gas of 3.3 x 1 010 Bq (0.89 Ci)

* Iodine of 5.5 x 1 06 Bq (1.5 x 104 Ci)

* Total particulate of 3.2 x 1 O6 Bq (8.7 x 1 0 Ci)

* Total tritium of 2.3 x 1012 Bq (61.5 Ci).

These releases are typical of past years (NMC 2000, 2001, 2002). See Section 2.2.7 for a

discussion of the calculated doses to the maximally exposed individual as a result of these

releases. Absent a change in licensed power levels, NMC does not anticipate any increase in

gaseous waste releases during the license renewal period. -

August 2005 , 2-9 NUREG-1437, Supplement 23
____ _____ _LL

Plant and the Environment

2.1.4.3 Solid-Waste Processing

The solid-waste system at PBNP is designed to package and/or solidify radioactive waste for

shipment to an approved offsite burial facility. Solid waste consists of chemical laboratory

samples, spent resins, used filter cartridges, radioactively contaminated hardware, and

compacted wastes such as rags, paper, and clothing.

Spent resins from the demineralizers, filter cartridges, and the concentrates from the

evaporators are packaged and stored on site until shipment for offsite disposal. Miscellaneous

materials such as paper, plastic, wood, and metal are collected and shipped off site for vendor

supplied volume reduction (i.e., incineration, supercompaction, metal melt, decontamination,

etc.) followed by disposal.

Spent resins from the chemical and volume control system and other system demineralizers are

flushed to a shielded, lined, stainless steel storage tank located in the auxiliary building

basement. When the tank is full, the resin is dewatered and liquids from the dewatering

operation are sent to the waste holdup tank. Following resin dewatering, the tank and its shield

are transferred by the seismically qualified auxiliary building crane to the truck access area or to

the new-fuel storage area where the resin is sluiced to a disposable cask liner. When the

disposable liner is full, the liner is dewatered to meet disposal site criteria. The disposable liner

is then shipped off site for disposal at a suitable burial site or stored until shipment for offsite

burial.

Dry active waste is stored in SeaLand containers in designated locations in the outside yard

portion of the radiation control area before shipment. Also, boxes loaded with dry active waste

are stored in the outside yard area of the radiation control area before shipment. Routine

surveys and inspections are performed to verify container integrity (NMC 2003a).

Spent fuel is currently stored on site in the spent fuel pool in the auxiliary building adjacent to

the containment building or in dry cask storage at the onsite ISFSI (NMC 2004b).

Disposal and transportation of solid waste are performed in accordance with the applicable

requirements of 10 CFR Parts 61 and 71, respectively. There have been no releases to the

environment from radioactive solid wastes generated at PBNP (State of Wisconsin 2003,

2004a).

The total amount of radioactive material shipped for disposal in 2003 was 6.5 x 1012 Bq

(175.3 Ci) (NMC 2004c). These shipments are representative of the shipments made in the

past several years (NMC 2000, 2001, 2002). Absent a change in licensed power levels, NMC

does not anticipate any increase in radioactive waste shipments during the license renewal

period.

NUREG-1437, Supplement 23 2-10 August 2005

I
Plant and the Environment

2.1.5 -Nonradioactive Waste Systems

Various nonradioactive wastewater management and disposal activities are conducted at

PBNP. They include collection, treatment, and disposal of the following principal effluents:

sanitary waste, demineralizer regeneration neutralization tank discharge, steam generator

blowdown, reverse osmosis reject wastewater, microfiltration unit backwash, water treatment

plant backwash, potable water treatment system filter backwash, heating system condensate,

and wastewater from various sumps and floor drains. '

After the appropriate treatment processes, the wastewater streams are discharged to Lake

Michigan and monitored and regulated according'to Wisconsin Pollutant Discharge Elimination

System (WPDES) permit number WI-0000957-07-0 administered by the Wisconsin Department

of Natural Resources (WDNR) (WDNR 2004a).

Sanitary wastewater is treated in an onsite treatment system. The effluent is commingled with

other wastewater and subsequently discharged with the cooling-water discharges. Waste liquid

sludge is hauled off site for disposal. Land application of sludge is considered as an alternative

disposal method. However,' no land application has occurred in the last 6 years. The sludge is

taken to the Green Bay or Manitowoc wastewater treatment plants for disposal.

A wastewater retention pond previously used for low-volume process wastewater and treated

sanitary waste effluent was abandoned in 2002. The site was restored to' its pre-excavation

grades arid'planted with native plant species (GeoSyntec Consultants 2002). A vacuum fabric

filter system is now used for treating the wastewater. The vacuum fabric filter system removes

suspended solids to provide final clarification prior to discharge.

All nonradioactive solid waste is disposed of using licensed disposal methods appropriate for

the waste types. Hazardous, nonradioactive waste generated by PBNP is regulated under the

Resource Conservation and Recovery Act (42 United States Code [USC] 6901 et seq.), which

is administered by the WDNR. Hazardous waste activity is registered with the U.S.

Environmental Protection Agency (EPA) under Identification No. WID093422657. Hazardous

wastes generated on the PBNP site, such as contaminated soil and other materials, paints, oils,

solvent wastes, outdated chemical products, and corrosive reagents, are managed and

disposed of by shipping off site in accordance with applicable rules and regulations. In 2003,

approximately 32.2 MT (35.5 tons) of hazardous waste were generated at PBNP

(We Energies 2004a).

Nonradioactive and nonhazardous waste materials such as excess dirt and debris from past

construction activities, including clean soil, broken pavement, and building materials, have been

collected at an onsite spoil pile at the PBNP site. The spoil pile is established and maintained in

August 2005 2-11 NUREG-1 437, Supplement 23
Plant and the Environment

conformance with the applicable requirements of the WDNR. The pile is stabilized by years of

natural vegetative growth. A visual inspection of the pile is conducted annually to check for

erosion as part of the Storm Water Pollution Prevention Plan.

2.1.6 Plant Operation and Maintenance

Maintenance activities conducted at PBNP include inspection, testing, and surveillance to

maintain the current licensing basis of the plant and ensure compliance with environmental and

safety requirements. Certain activities can be performed while the reactor is operating, but

some activities require that the plant be shut down. Long-term outages are scheduled for

refueling and for certain types of repairs or maintenance, such as replacement of a major

component. NMC refuels PBNP on a nominal 18-month, staggered schedule. During refueling

outages, which last from 30 to 40 days, site employment increases above the 740 permanent

workforce by 300 temporary workers (NMC 2004a).

The final safety analysis report (NMC 2003a) regarding the effects of aging on systems,

structures, and components was included as part of the PBNP application for renewal of its

operating license (OL), in accordance with 10 CFR Part 54. Chapter 3 and Appendix B of the

PBNP license renewal application (NMC 2004b) describe the programs and activities that would

manage the effects of aging during the license renewal period. NMC expects to conduct

activities related to the management of aging effects during normal plant operation, or refueling

and other outages, but plans no outages specifically for the purpose of refurbishment. NMC

does not plan to add significant additional full-time staff (non-outage workers) at PBNP during

the period of the renewed license.

2.1.7 Power Transmission System

In its Environmental Report (ER), the applicant identified three 345-kilovolt (kV) transmission

lines that connect PBNP to the power grid (NMC 2004a). A fourth 345-kV line connects the

Kewaunee Nuclear Power Plant (KNPP) to the substation at PBNP. Currently the four lines are

owned and maintained by the American Transmission Company (ATC). The transmission lines

are described below and the characteristics of each right-of-way (ROW) are shown in

Table 2-1.

NUREG-1437, Supplement 23 2-12 August 2005

I I.
Plant and the Environment

Table 2-1. PBNP Transmission Line Rights-of-Way'

Approximate Approximate Approximate

Length . Width Area

Rights- Number

Substation of-Way of Lines kV km (mi) m (ft) ha (ac)

Granville L-111 1 345 32.0 20.0 67 220 210 530

Arcadian L-121 1 345 29.0 18.0 67 220 190 480

North Appleton L-1 51 1 345 47.5 - 29.7 67 220 320 790

PBNP 0-303 1 345 9.0 5.6 67 220 61 150

Source: NMC 2004a --

Line L-l 11 connects to the Granville substation via a previously existing line. The tie point is in

the southwest quadrant of Section 16, Franklin Township. The length of the line is 32 km

(20 mi) (NMC 2004a).

Line L-121 connects to the Arcadian substation via a previously existing line. The tie point is in

the southwest quadrant of Section 9, Franklin Township. The length of the line is 29 km (18 mi)

(NMC 2004a).

Line L-1 51 connects to the North Appleton substation'via a previously existing line. The tie

point is in the northwestern quadrant of Section 7, Wrightstown Township. The length of the

line is 47.5 km (29.7 mi) (NMC 2004a).

Line 0-303 runs 9.0 km (5.6 mi) north to the substation at KNPP (NMC 2004a).

Each ROW is 67 m (220 ft) wide. Figure 2-4 shows the transmission system for PBNP. For the

specific purpose of connecting PBNP to the power grid, ATC has a total of 118 km (73.3 mi) of

transmission lines occupying approximately 791 ha (1955 ac) of easement (NMC 2004a). The

ROWs pass through land that is primarily rolling hills covered in forest and farmland.' These

ROWs pass through rural areas with low population densities. The lines cross numerous State

and Federal highways,-including Wisconsin Highways 42 and 147 and Interstate 43. ROWs

that pass through farmland generally continue to be managed as such. ATC plans to maintain

these lines indefinitely as they are an integral part of the larger transmission system. These

transmission lines are expected to remain a permanent part of the regional transmission system

after decommissioning of PBNP.

August 2005 2-13 NUREG-1437, Supplement 23
l-- LLPlant and the Environment

LEGEND

P ie potlo aexis"g line

/1VTrnscr~in Lines

Mqar Roads

aV PawY road wilM ed acss

,Prpury road

?-'__;Corty Boundanes

Lakes and Rvens

3 53V3 Indlan Reservatons

UrbanAreas

Wsconsin

Pontatch Nuckw~ Flawt

5 0 5 10 I5 20WMk

6 0 6 12 IS 24 30 Ooweks

Transmission Line Map

Figure 2-4. PBNP Transmission Lines

NUREG-1437, Supplement 23 2-14 August 2005
Plant and the Environment

The transmission lines were designed and constructed in the late 1 960s and early 1 970s in

accordance with then existing Wisconsin Electrical Code and industry standards. ATC

implements a ROW inspection and maintenance program to ensure that the transmission

facilities continue to conform to design standards. ATC manages transmission line ROWs

using a wire zone/border zone concept. The wire zone is directly below the transmission lines,

where the vegetation is primarily low-growing forbs and grasses. The border zone extends

from the wire zone to the edge of the ROW, where woody species less than 5 m (15 ft) tall

provide a transition to the surrounding habitats (ATC 2004).

The maintenance and inspection program uses aerial patrols to check for encroachments,

broken conductors, broken or leaning structures, and signs of tree burning. Any of these

conditions could be evidence of clearance problems. Additionally, ground inspections are

performed to further examine clearance at questionable locations, observe the integrity of

structures, and identify dead or diseased trees that might fall on the lines. Problems that are

found are brought to the attention of the appropriate organization for corrective action. 'ATC

has a vegetation management program for trimming and clearing tall trees that may impinge

upon the conductors (ATC 2004b). The program also involves removing invasive plants from

the ROW. The specific clearing activities implemented are dependent upon the type and --

amount of vegetation in a given area and are modified as needed for sensitive habitats and

stream crossings. Vegetation management activities may include tractor mowing, manual 'I

chainsaw clearing, and application of herbicides by a State-licensed, commercial applicator.

Trimming is usually performed every 5 to 7 years, depending on the growth rates of vegetation

in a given area.

ATC recognizes that transmission line ROWs provide ancillary compatible uses including

wildlife habitat, biodiversity corridors, recreation, and aesthetics. ATC practices a vegetation

management program that utilizes physical, chemical, and biological treatments to promote

stable, diverse, low-growing plant communities in a way that promotes wildlife habitat and -

reduces environmental impacts.

2.2 Plant Interaction with the Environment

Sections 2.2.1 through 2.2.8 provide general descriptions of the environment near PBNP as

background information. They also provide detailed descriptions when 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

resources in the area,' and Section 2.2.10 describes possible impacts associated with'other

Federal project activities.

August 2005 2-15 NUREG-1437, Supplement 23
_ __ .LL

Plant and the Environment

2.2.1 Land Use

PBNP is situated on the western shore of Lake Michigan in Manitowoc County, Wisconsin,

approximately 48 km (30 mi) southeast of Green Bay and 24 km (15 mi) north-northeast of the

City of Manitowoc. Lake Michigan is the second largest of the Great Lakes by volume at

4900 km3 (nearly 4 billion acre-feet) and third largest by area, covering approximately

57,800 km2 (22,300 mi2) (Environment Canada 1995). Major tributaries of Lake Michigan

include the Fox-Wolf, Grand, and Kalamazoo rivers. Two small creeks are located within the

PBNP site boundaries and drain to the north and south. One of the creeks discharges into the

Lake about 457 m (1500 ft) north of the site, while the other discharges near the center of the

site. During the spring, water often ponds in shallow depressions because of the poor drainage

characteristics of the soil, due largely to a high clay content.

The PBNP site boundary includes 3.2 km (2 mi) of continuous frontage on Lake Michigan. Low

bluffs face the shoreline with evidence of marked erosion near the center of the site. At this

point, the beach is narrow, ranging in width from 6 m to 15 m (20 ft to 50 ft). The bluff faces are

bare mud slopes and show active erosion during storm events. It is estimated that the

shoreline is receding at a rate of approximately 0.8 m to 1.5 m (2.5 ft to 5 ft) per year. To

counter this erosion, WEPCO has placed riprap along the most sensitive stretches

(NMC 2004a).

The plant site boundary encompasses approximately 510 ha (1260 ac) (NMC 2004a), all owned

by WEPCO. Within the plant site boundary, there are nine leases totaling approximately

425 ha (1050 ac) issued to local farmers. The land subject to the leases is used primarily for

grain crops, but some is allowed to remain uncultivated or stand fallow. The balance of land

within the site boundary is a combination of open space, woods, and wetlands. The developed

portion of the site resides primarily along the shoreline, but there are some ancillary structures,

notably the ISFSI. The zoning of the PBNP site is exclusively agricultural (Manitowoc County

Planning and Park Commission [MCPPC] 2004).

Originally, there were several residences on the land that is now occupied by the PBNP site.

Only one of these former residences still stands, but it is unoccupied. It is occasionally used for

training purposes by the plant's security forces. There are no other residential structures on the

plant site itself.

The area within 10 km (6 mi) of PBNP includes portions of Manitowoc and Kewaunee counties

and is largely rural, characterized by farmland, woods, and small residential communities.

Zoning of the land adjacent to the plant site is agricultural with the exception of the Town of

Two Creeks, which has a small area zoned for both residential and business. The nearest

residential community to PBNP is the Town of Two Creeks, approximately 1.6 km (1 mi)

north-northwest of the site (Figure 2-2). Other nearby communities include the Village of

NUREG-1437, Supplement 23 2-16 August 2005

Il
Plant and the Environment

Mishicot (approximately 10 km [6 mg] west-southwest of the plant), the City of Two Rivers |

(13 km [8 ml] to the south) and Kewaunee (18 km [11 mi] to the north). The largest

metropolitan area within 80 km (50 mi) is the City of Green Bay, located 48 km (30 mi) to the

northwest. Approximately 81 percent of the plant's workforce resides in Manitowoc County,

with the majority living in the cities of Manitowoc and Two Rivers.

Section 307(c)(3)(A) of the Coastal Zone Management Act [16 USC .1456(c)(3)(A)] requires that

applicants for Federal licenses to conduct an activity in a coastal zone certify that the proposed |

activity is consistent with the enforceable policies of the-State's coastal management program.. |

A copy of the certification is also to be provided to the Federal agency. The State is to notify

the applicant and the Federal agency whether the State concurs with or objects to the -

applicant's certification. According to 15 CFR Part 930, this notification is to occur within 6

months of the State's receipt of the certification. PBNP is within Wisconsin's coastal zone for

purposes of this Act.- NMC submitted a consistency certification to the Wisconsin Department I

of Administration (WDA) on March 2, 2004 (NMC 2004d). According to WDA procedures, -

concurrence by the Coastal Management Council's staff can be presumed in the absence of its

objection within six months of the commencement of its review (WDA 2005). WDA did not

notify the applicant or the NRC of any objection to the consistency certification within the

specified time frame; thus, the Coastal Management Council's concurrence can be presumed. -

Theref ore, renewal of the operating licenses for PBNP. Units 1 and 2 can be presumed to be |

consistent with Wisconsin's Coastal Management Program. - -

2.2.2 Water Use

Lake Michigan is the source of water for cooling and auxiliary water systems at PBNP. PBNP

uses a once-through condenser cooling system with a submerged offshore intake and a surface

shoreline discharge. 1The withdrawal rate from the Lake through each condenser is 22 rn3/s-

(777 ft3/s), or approximately 1.33 x 106 Llmin (350,000 gpm). Water is then returned to the -

Lake with minimal net loss. - - -

Groundwater supplies in the vicinity of PBNP are obtained primarily from the Silurian aquifer. . |

This aquifer is in the uppermost bedrock, which consists of Silurian-age Niagara Dolomite. It

lies below approximately 33 m (110 ft) of unconsolidated glacial material primarily consisting of

clay with some sand,- silt, and gravel. Underlying the Silurian-age deposits are relatively uniform -

layers of Ordovician-age formations composed of shale, dolomite, and limestone. -

Domestic-quality water for drinking and sanitary purposes is withdrawn from groundwater by

five active domestic supply wells at PBNP having an average flow rate of about 24 Umin -

(6.5 gpm), or 35,000 L/day (9300 gpd). The main well at PBNP is drilled to a depth of 78 m

(257 ft). The normal water level in this well is at 3.5 m (12 ft) below grade, which indicates an

artesian condition in the Silurian aquifer (NMC 2004a). PBNP is not connected to a municipal

water system. - - - -

August 2005 2-17 - NUREG-1437, Supplement 23
_____- - LL

Plant and the Environment

2.2.3 Water Quality

Lake Michigan provides safe drinking water for 10 million people, wildlife habitat, food

production and processing, an active sport and sustenance fishery, and other valuable

commercial and recreational activities (EPA 2000). However, threats to the Lake Michigan

ecosystem still exist that result in fish consumption advisories, beach closures, and impairment

of aquatic organisms and wildlife.

The water quality of Lake Michigan has been degraded by industrial, municipal, agricultural,

navigational, and recreational water users for more than 150 years. Although major point

sources of pollutants have been curtailed since the enactment of the Federal Water Pollution

Control Act (also known as the Clean Water Act of 1977 (CWA]) (33 USC 1326 et seq.), the

lake continues to receive pollutants such as polychlorinated biphenyls (PCBs) and mercury from

the atmosphere. The United States and Canada, in consultation with State and provincial

governments, are working to restore and maintain the chemical, physical, and biological

integrity of the water of the Great Lakes Basin ecosystem under the provisions of the Great

Lakes Water Quality Agreement, signed in 1972 and amended in 1987 (EPA 2005).

As part of this effort, the Lake Michigan Technical Committee developed a Lake Michigan

Lakewide Management Plan (EPA 2000) that describes the current state of Lake habitats (open

waters, wetlands, tributary streams), identifies areas of concern, and recommends future steps

that should be taken to protect and restore Lake Michigan ecosystems. These

recommendations range from controls on ballast water to remediation of contaminated

(sediment) sites and the implementation of total maximum daily load strategies for tributary

streams. The Lake Michigan Lakewide Management Plan lists a number of areas in which

improvements have been made (e.g., reduction of point source pollutants entering the basin

and protection and restoration of wetlands) but notes that other areas still need improvement

(e.g., deposition of toxic air pollutants in the watershed and nonpoint source pollutants). The

Lake Michigan Lakewide Management Plan is one of the most comprehensive sources of

information available on the current state of health of the Lake Michigan ecosystem

(EPA 2000).

In accordance with the CWA, the water quality of plant effluent discharges is regulated through

the National Pollutant Discharge Elimination System (NPDES). WDNR is the agency delegated

by the EPA to issue discharge permits in Wisconsin. PBNP wastewater discharges to Lake

Michigan are regulated and monitored under WPDES permit number WI-0000957-07-0

administered by the WDNR (WDNR 2004a). The current permit was issued July 1, 2004, and

is due to expire June 30, 2009.

The permit contains effluent limitations necessary to ensure that the water-quality standards for

Lake Michigan are met. The current permit requires monitoring of discharge streams from the

NUREG-1437, Supplement 23 2-18 August 2005

Il
Plant and the Environment

condenser cooling water, deicing line for the water intake crib (during winter), demineralization

regeneration neutralization tank, steam generator blowdown, sewage treatment plant effluent,

liquid sludge line from sanitary wastewater treatment system, low-volume wastewater (from

sumps, drains, and backwash), plant process wastewater, and microfiltration unit backwash -

from the plant. Monitoring requirements and discharge limitations exist for flow, pH, suspended

solids, oil and grease, biochemical oxygen demand, total residual chlorine, and whole effluent

toxicity for the discharge streams as applicable. The current permit requires monitoring and

reporting of PBNP discharges to Lake Michigan, but the permit does not have any thermal

water-quality standards for compliance. The permit also requires a study of the cooling-water -

intake to assess any potential adverse impacts and notes that, where applicable, the best -- I

technology available must be implemented to prevent the impingement and entrainment of fish

and aquatic life. Any new regulations promulgated by the EPA or the State would be reflected

in future permits (WDNR 2004a).

From 1968 to 2002,-PBNP used a wastewater retention pond to collect process wastewater and |

sewage treatment plant effluent, and settle out the suspended solids. Originally pond water

was discharged to a small, onsite creek, which discharged to Lake Michigan. However, in the

mid-1 970s, the pond, creek, and adjacent soils were found to be slightly contaminated with low |

levels of radionuclides. Soils in a nearby wetland outside the pond basin were found to be.

contaminated with low levels of cesium and cobalt-60. In response, the wastewater retention I

pond discharges were rerouted into the facility, monitored, and released to Lake Michigan with

the cooling water discharges (NMC 2004a). -

Active wastewater treatment in the pond ended in 2002, and WEPCO subsequently closed the

wastewater retention pond as prescribed by WDNR regulations. The pond was dewatered, and

the sediments were either removed or stabilized in place and covered with layers of soil. Soils |

in the nearby wetland contaminated in excess of the NRC decommissioning guidelines were

removed and disposed of at a licensed offsite facility. The site was restored to its |

pre-excavation grades and planted with native plant species (NMC 2004a). The abandonment |

plan for the wastewater retention pond (GeoSyntec Consultants 2002) was reviewed for .

compliance and approved by WDNR, who verified that currently there are no |

groundwater-related issues of concern to WDNR at PBNP (WDNR 2002, 2005). There are

currently no discharges to groundwater from PBNP requiring permits by regulatory agencies I

(WDNR 2005). |

2.2.4 Air Quality

PBNP is located near the Town of Two Creeks on the-western shore of Lake Michigan in

Manitowoc County,-Wisconsin. Overall, the-ground surface at the PBNP site is gently rolling to

flat with elevations varying from 1.5 m to 18 m (5 ft to 60 ft) above the level of Lake Michigan.

The climate of the region is influenced by the west-to-east flow of storms along the northern

August 2005 2-19 NUREG-1 437, Supplement 23
- - -_ _LLL

Plant and the Environment

portion of the country and from the southwest to the Great Lakes. Lake Michigan influences the

wind and temperature regimes in the vicinity of PBNP. The site is well ventilated with infrequent

calms. Prevailing winds during spring and summer are onshore lake breezes. Beginning in the

summer, a flow from the south-southwest appears that is reinforced in the fall by offshore flows

from west-southwest and west-northwest. During winter, the flow is from the northwest through

south-southwest (NMC 2003a).

The average annual temperature is 7.2 OC (45 OF), with an average daytime winter temperature

of -1.7 0C (29 OF) and an average daytime summer temperature of 25 0C (77 OF). The

maximum monthly average daily temperature is 26.4 0C (79.6 OF) (July) and the minimum

monthly average daily temperature is -11.8 0C (10.8 OF) (January) (Midwestern Regional

Climate Center [MRCC] 2003).

Average total annual precipitation is about 71 cm (28 in.) per year with 55 percent falling in the

months of May through September. For the period of 1971 to 2000, rainfall ranged from a

monthly average high of 9.47 cm (3.73 in.) in August, to a monthly average low of 3.15 cm

(1.24 in.) in February (MRCC 2003). Average annual snowfall is about 114cm (45 in.) per year

with a maximum of 38 cm (15 in.) in 24 hours occurring in January 1947. Ice storms are

infrequent in this region of Wisconsin (MRCC 2003).

Tornadoes occur in the state, but the only one that caused major property damage and injury to

people within an 80-km (50-mi) radius of PBNP occurred in 1959 in Green Bay, 48 km (30 mi)

northwest of the site. Based on statistics for the 30 years from 1954 through 1983 (Ramsdell

and Andrews 1986), the probability of a tornado striking the site is expected to be about

4.0 x 10-4 per year.

Average wind speeds at the site are approximately 16 km/h (10 mph). Wind power potential is

generally rated on a scale of 1 through 7. Areas suitable for wind turbine applications have a

rating of 3 or higher. The western shore of Lake Michigan, which forms the eastern edge of

Wisconsin, has an annual average wind power rating of class 3. This rating is due primarily to

the prevailing westerly winds. Eastward moving storm systems are responsible for the easterly

winds that flow off the lake during the winter and late autumn. Thus, on the annual average,

the wind power potential on the western shore is less than on the eastern shore but still reflects

the influence of Lake Michigan. Lake breezes, which are maximized in the spring, also

contribute to the wind power potential along this shoreline (Elliot et al. 1987).

The PBNP site is located within the Lake Michigan Intrastate Air Quality Control Region

(AQCR), formerly known as the Menominee-Escanaba (Michigan)-Marinette (Wisconsin)

Interstate Air Quality Control Region (40 CFR 81.67). This AQCR comprises the territorial

NUREG-1437, Supplement 23 2-20 August 2005

I I
Plant and the Environment

areas encompassed by the following Wisconsin counties: Brown, Calumet, Door, Fond du Lac, -

Green Lake, Kewaunee, Manitowoc, Marinette, Marquette, Menominee, Oconto, Outagamie,

Shawano, Sheboygan, Waupaca, Waushara, and Winnebago.

The Lake Michigan Intrastate AQCR is in attainment for all air-quality criteria pollutants, with the

exception of ozone. The AQCR was previously in attainment with the 1-hour ozone standard.'

In 1997, the EPA revised the national standard for ground-level ozone from a 1-hour 'peak"

standard of 0.12 ppm to an 8-hour "average" standard of 0.08 ppm. This new standard is --

commonly referred to as the 8-hour standard and was upheld by the U.S. Supreme Court in

February 2001 (Whitman, Administrator of EPA, etaL. v. American Trucking Associations, Inc.,

et al.). In April 2004, the EPA-published the 8-hour ozone nonattainment designations and -

announced that the 1-hour standard will be phased out. The EPA designated Manitowoc

County as a "basic" nonattainment area, with attainment to be achieved no later than June 2009

(EPA 2004a). The EPA indicated that areas designated as "basic" must comply with the more

general nonattainment requirements of the Clean Air Act of 1970 (CM) (42 USC 7401 et seq.)

(EPA 2004b). This change in attainment status for Manitowoc County will not significantly - -

affect the ongoing operations of PBNP. Over time, continued nonattainment may increase the

likelihood that additional emission controls will be required for stationary sources: Any such

new controls would employ demonstrated cost-effective technologies and would only minimally

impact plant operations. Kewaunee County, immediately north of Manitowoc County, is also

designated as a "basic" nonattainment area for ozone, whereas the Sheboygan and

Milwaukee-Racine areas to the south are "moderate" nonattainment areas with respect to the

8-hour ozone standard. There are no Class I Federal areas, in which visibility is an important

value designated in 40 CFR Part 81, within 160 km (100 mi) of the PBNP site.

Diesel engines, boilers, a gas turbine, and other activities and facilities associated with the

PBNP site emit various nonradioactive air pollutants to the atmosphere. Air emissions from

these sources are subject to the terms and conditions of a CM Title V air pollution control

operation permit issued by the WDNR Air Management Program (Permit Number

436034500-P1 0).

The air permit includes limits on emissions of particulate matter and opacity for all of the

permitted sources of nonradioactive'air emissions. The combustion turbine may not be

operated more than 228.83 hours per month, as determined by the average over any

12 consecutive months. There are no significant changes proposed for nonradioactive air

emissions from the PBNP site during the license renewal period, and there are no significant

changes proposed to the limits and conditions of the air permit.

August 2005 , - 2-21- NUREG-1437, Supplement 23
L LL

Plant and the Environment

2.2.5 Aquatic Resources

The principal aquatic resource in the vicinity of PBNP is Lake Michigan, which is the source and

receiving body for the PBNP Units 1 and 2 cooling systems. The PBNP site lies on the western

shore of Lake Michigan and occupies approximately 3 km (2 mi) of Lake Michigan shoreline

(NMC 2004a). At the site, low bluffs face the Lake Michigan shore with evidence of marked

erosion near the center of the PBNP site. At this point the beach is narrow (ranging in width

from 6 to 15 m [20 to 50 ft]) with bare mud slopes showing active erosion. Historically, shore

recession has ranged from 0.8 to 1.5 m (2.5 to 5 ft) per year in this area. WEPCO has provided

riprap to control further recession of the shoreline at the site (NMC 2004a). The transmission

lines associated with PBNP cross several streams and rivers including Kriwanek Creek, Devils

River, Branch River, Neshota River, West Twin River, and East Twin River (AEC 1972).

Transmission line ROW maintenance activities in the vicinity of stream and river crossings

include procedures to avoid impacts to existing waterway channels and shorelines (including

maintaining buffer zones at stream and river crossings and, as appropriate, using hand cutting

at sensitive habitats and wetlands, using established waterway crossings, and not using

herbicides unless approved for aquatic use) (ATC 2004a, ATC 2004b, NRC 2004). This is also

discussed in Section 2.1.7.

Lake Michigan is used for a variety of purposes, including commercial and recreational boating,

sport and commercial fishing, and tourism. The major changes and modifications that have had

the greatest effect on aquatic resources of Lake Michigan include: (1) lakefront industrial,

urban, and residential developments; (2) water quality impairment from industrial, municipal,

agricultural, navigational, and recreational water uses; (3) overfishing; and (4) invasion of exotic

species (EPA 2002). The Lake Michigan ecosystem continues to experience profound changes

because of development, impacts of invasive species, and pollution. Overall, the status of Lake

Michigan habitats, including open water, wetlands, coastal shore, and tributaries, is mixed to

deteriorating (EPA 2002). The WDNR has prepared an integrated plan to guide the

management of sport and commercial fisheries in the Wisconsin waters of Lake Michigan

(WDNR 2004b).

Some fish cannot be sold commercially because of high levels of PCBs, mercury, or other

substances (Fuller et al. 1995). Mercury is a growing concern in fish in Lake Michigan and its

tributary streams (EPA 2002). Wisconsin has published health advisories governing the

consumption of fish, including those from Lake Michigan waters. Mercury and PCBs are the

two main contaminants that account for the fish advisories in Wisconsin. PCBs are the only

contaminants for which advisories apply within Lake Michigan (WDNR 2004c). For the

Wisconsin waters of Lake Michigan, advisories are provided for rainbow smelt (Osmerus

mordax), Chinook salmon (Oncorhynchus tshawytscha), coho salmon (0. kisutch), rainbow

trout (0. mykiss), brown trout (Salmo trutta), lake trout (Salvelinus namaycush), lake whitefish

(Coregonus clupeaformis), bloater (C. hoyi), and yellow perch (Perca flavescens). Depending

NUREG-1437, Supplement 23 2-22 August 2005

I
Plant and the Environment

on fish species and size, the advisories range from no more than one meal a week (e.g.;

rainbow trout) to do not eat (e.g., lake trout over 69 cm [27 in.]). Women of childbearing years,

nursing mothers, and children under age 15 are cautioned to space their fish meals according'--

to the advisories. Additional advisories are provided for other fish species for Wisconsin's

inland waters, the Mississippi River, Green Bay, and Lake Superior (WDNR 2004c).

Despite the multiple competing uses of Lake Michigan, the overall fish biodiversity is fairly high.

Almost 100 species of fish occur in Lake'Michigan (UWSGI 2001a). Lake Michigan'supports

commercial, recreational, and tribal fishing. Commercial and tribal fishing totals over

6.6 million kg (14.6 million lb) annually (EPA 2002).' Lake whitefish is the primary commercial

species. Lake whitefish and lake trout constitute the tribal fisheries (Stein et al.2003). Some

commercial fishing is also done for bloater, rainbow smelt, and yellow perch (Madenjian et al.

2004; Hasz 2004).- The 2003 commercial 'catches for the Wisconsin waters of Lake Michigan

were lake whitefish - 600,104 kg (1,323,002 Ib); bloater - 571,086 kg (1,259,029 lb) (includes

marketable and unmarketable bloaters caught incidental to targeted rainbow smelt harvests);

rainbow smelt - 46,075 kg (101,578 Ib); and yellow perch - 8669 kg (19,111 lb) (for the -

2002/2003 harvest year in Green Bay, commercial harvest of yellow perch in the rest of Lake

Michigan has been closed since September, 1996) (Kroeff 2004; Peeters 2004; Hogler and

Surendonk 2004; Hasz 2004; Hirenthota 2004). The yellow perch population density in Lake

Michigan has declined dramatically since the early 1990s, with its age structure shifting towards

older fish due to limited recruitment (WDNR 2004b). The commercial fishery for the introduced

alewife (Alosa pseudoharengus) was closed in 1991 and has not reopened (Madenjian et al.

2002).

The number of fish caught by sport fishing within the Wisconsin waters of Lake Michigan

(including Green Bay) in 2003 were lake trout - 23,881; rainbow trout -'48,548; brown;

trout - 23,654; coho salmon - 50,625; Chinook salmon - 317,619,-northern pike (Esox

lucius) - 3344; smallmouth bass (Micropterus dolomieu) - 19,253; yellow perch - 156,321; -and - -'

walleye (Stizostedion vitreum) - 22,806 (Eggold 2004).

The top-level predators of Lake Michigan are currently dominated by introduced species' of trout

and salmon. The native burbot (Lota Iota) and lake trout (the original top predators in - - '; --

Lake Michigan) have been recovering due to sea lamprey (Petromyzon marinus) control

(Madenjian et al. 2004). Burbot abundance increased throughout the 1980s and 1990s,

peaking in 1997, but numbers have declined in recent years (Madenjian et al. 2004). Lake trout'

have also increased in abundance,' but -numbers are maintained by stocking programs rather

than by natural reproduction. About 2.4 million yearling lake trout are annually stocked into

Lake Michigan (Bronte and Schuette 2002). Reasons that self-sustaining populations of lake

trout have yet to be reestablished in Lake Michigan may include loss of suitable spawning -

habitat, environmental contamination, predation on larval lake trout by alewife, thiamine

August 2005 2-23 NUREG-1437, Supplement 23
- 1___ _LL

Plant and the Environment

deficiency from a diet of alewife, and a loss of genetically distinct strains (EPA 2002). Current

efforts to restore the lake trout to Lake Michigan focus on stocking a variety of lake trout strains

in offshore refuges that offer protection from fishing (NMC 2004a).

Alewife, rainbow smelt, bloater, deepwater sculpin (Myoxocephalus thompsom), and slimy

sculpin (Cottus cognatus) constitute the bulk of the forage biomass in Lake Michigan

(Eshenroder et al. 1995; Madenjian et al. 2004). In 2003, the alewife was the most important

prey fish in Lake Michigan, with an estimated lake-wide biomass of 42,876 metric tons

(47,262 tons), which is equivalent to about 16.5 billion adult alewives (Madenjian et al. 2004).

There is now a major effort to manage the non-native alewife population because of its

importance as the major prey for introduced salmonids. The 2003 lake-wide biomass of

bloater, rainbow smelt, deepwater sculpin, and slimy sculpin were estimated at 20,682 metric

tons (22,798 tons), 1386 metric tons (1528 tons), 32,787 metric tons (36,141 tons), and

2385 metric tons (2629 tons), respectively (Madenjian et al. 2004). The biomass of Lake

Michigan forage fish, taken as a group, increased from the 1970s to the late 1980s, peaked in

1989, and appears to have declined steadily since 1989. The overall decline in forage fish

biomass over the 1990s is due primarily to the decline in the bloater (Madenjian et al. 2004).

Fish species reported from the PBNP site area include rainbow trout, brook trout

(Salvelinus fontinalis), lake trout, coho salmon, Chinook salmon, round whitefish (Prosopium

cylindraceum), lake whitefish, bloater, lake herring or cisco (Coregonus artedi), alewife, gizzard

shad (Dorosoma cepedianum), rainbow smelt, trout-perch (Percopsis omiscomaycus), fathead

minnow (Pimephales promelas), spottail shiner (Notropis hudsonius), black bullhead (Ameiurus

melas), longnose sucker (Catostomus catostomus), white sucker (C. commersonf), ninespine

stickleback (Pungitius pungitius), bluegill (Lepomis macrochirus), yellow perch, and slimy

sculpin (AEC 1972; WEPCO 1976). The habitats most suitable for reproduction by the Great

Lakes fish community (i.e., coastal wetlands, bedrock, sandy beach-dunes, and bluffs;

Wei et al. 2004) do not occur in the immediate vicinity of PBNP.

At least 160 species of plants, plankton, macroinvertebrates, and fish have been introduced into

the Great Lakes since the early 1800s through the canal system interconnection with the

Atlantic Ocean (e.g., sea lamprey, alewife, and white perch [Morone americana]), ship ballast

(e.g., Asiatic clam [Corbicula fluminea], zebra mussel [Dreissena polymorpha], spiny water flea

[Bythotrephes longimanus, formerly known as B. cederstroemi], and round goby

[Neogobius melanostomus]), or as intentionally introduced species (e.g., common carp

[Cyprinus carpio], rainbow smelt, and various salmonids) (EPA 2002; Peeters 1998). Bait and

pet releases have also contributed to the introduction of invasive species. About 10 percent of

the invasive species have resulted in significant economic costs and/or ecological harm

(WDNR 2003a). The presence of invasive species, coupled with increased loss of nearshore

wetlands and tributary habitats, precludes the possibility for full restoration of the original fish

NUREG-1437, Supplement 23 2-24 August 2005

I
Plant and the Environment

community of Lake Michigan (WDNR 2004b). The WDNR (2003a) has developed a

comprehensive management plan'to prevent further introductions of invasive species and to

control existing populations of aquatic nuisance species.

In the mid-1960s, American and Canadian fish and game agencies began stocking trout and

salmon species into the Great Lakes to control alewife and rainbow smelt numbers'and to

improve the sport fishery. The non-native salmonids that have been introduced to the Great

Lakes between 1870 and 1960 include Atlantic species (Atlantic salmon [Salmo salad] and

brown trout); Pacific species (Chinook salmon, coho salmon, rainbow trout, sockeye salmon

[Oncorhynchus nerka], chum salmon [0. keta], cutthroat trout [0. clarkih], cherry salmon'- '

[0. masou], and pink salmon [0. gorbuscha]); and Arctic species (Arctic charr [Salvelinus

alpinus]) (Crawford 2001). -

Many of the' introduced trout and salmon flourished,' and by the 1970s,' Lake"Michigan

fishermen were landing many large trout and salmon. Catch rates peaked in the mid-to-late

1980s, and then leveled off, as alewife numbers declined (Crawford 2001). Since the- ' '

mid-1 970s, salmonid stocking in Lake Michigan has involved the brook trout, brown trout, lake

trout, rainbow trout/steelhead, Chinook salmon, coho salmon, and splake (hybrid between lake

trout and brook trout). Among these species, only the lake trout was released to reestablish a

reproducing population. The other species were stocked to provide a put-grow-take sport

fishery and to control alewives. However, sustainable reproduction of lake trout has not

occurred and natural reproduction of brown trout has been limited. -Significant reproduction

does occur for rainbow trout, Chinook salmon, and coho salmon (Eshenroder et al. 1995).

Nearly 14.5 million trout and salmon are stocked annually in Lake Michigan

(Eshenroder'et al. 1995). About 70 percent of the Great Lakes trout and salmon fishery is

dependent upon fish stocking (MDNR 2004). - Atlantic salmon have not been stocked in the

Lake since 1989 (Bronte and Schuette 2002). Tiger trout (hybrid between brook trout and,

brown trout) were stocked in the Wisconsin waters of Lake-Michigan from 1974 through 1977.

Their stocking was discontinued due to poor returns (WDNR 2003b).

Currently, the only major objective for salmonid stocking is the development and maintenance

of recreational fisheries (Crawford 2001).- Salmonid spawning in a number of streams on the

Wisconsin shoreline'of Lake Michigari is not conducive to natural reproduction because the

stream temperatures are too high for survival of trout fingerlings, and heavy sediment loads

smother eggs (WDNR 2003b). The stocking of salmonids may'have resulted in the introduction

of some non-native fish diseases and parasites to the Great Lakes and caused genetic

alteration of native salmonids through hybridization and introgression and/or through declines in

the abundance of native salmonids (brook trout and lake trout). Also, stocked salmonids may

August 2005 2-25 NUREG-1437, Supplement 23
-___1_LL

Plant and the Environment

present a direct threat to native and non-native forage fish and invertebrates, while placing

competitive pressure upon native fish species for food and habitat resources (Crawford 2001).

Nevertheless, the lake whitefish has made a recovery in the northern waters of Lake Michigan

since salmonid stocking began (Eshenroder et al. 1995).

Because of concern that alewife and rainbow smelt populations in Lake Michigan were not

adequate to support the booming populations of trout and salmon, fisheries managers in states

bordering Lake Michigan began to reduce the stocking rates of Chinook salmon in 1999. This

appears to have allowed alewife and rainbow smelt populations to stabilize, while improving the

growth and overall health of trout and salmon.

In 2003, salmonid stockings into the Wisconsin waters of Lake Michigan (including its tributary

streams) were brook trout - 23,877; brown trout - 1,080,538; Chinook salmon - 1,614,700;

coho salmon - 540,145; lake trout - 724,774; steelhead - 758,275; and splake - 22,086. The

numbers stocked in the area of Manitowoc and Kewaunee counties were brook trout - none;

brown trout - 216,672; Chinook salmon - 488,718; coho salmon - 229,621; lake trout - 119,950;

steelhead - 402,927; and splake - none (Burzynski 2004).

The native fish species of Lake Michigan have been affected by the introduced aquatic species,

most notably the sea lamprey and alewife. The sea lamprey, first discovered in Lake Michigan

in 1936, contributed to the collapse of top predator populations (e.g., lake trout and burbot) by

the late 1940s (Eshenroder et al. 1995). Combined with overfishing, the sea lamprey

contributed to the extirpation of the longjaw cisco (Coregonus alpanae), deepwater cisco

(C. johannae), and blackfin cisco (C. nigripinnis) from Lake Michigan (Fuller et al. 2004). Sea

lamprey abundance remains higher than desired in Lake Michigan. This limits rehabilitation

efforts for lake trout, despite the stocking program previously mentioned (Stein et al. 2003).

Other impediments to sustainable reproduction of lake trout in Lake Michigan relate to the

following: (1) the lake-wide population is too low, (2) spawning aggregations are too diffuse and

in inappropriate locations, and (3) there is poor survival of early-life stages (Bronte et al. 2003).

Declines in predator species allowed the alewife, which invaded Lake Michigan in 1949, to

proliferate and further disrupt native aquatic food webs (Eshenroder et al. 1995). By 1967, the

alewife made up about 85 percent of the fish biomass of the Lake (Peeters 1998). The

population explosion of alewives contributed to the decline of native fishes such as the bloater,

emerald shiner (Notropis atherinoides), lake whitefish, lake herring, deepwater sculpin,

spoonhead sculpin (Cottus ricei), and yellow perch (Eshenroder et al. 1995; Peeters 1998;

Madenjian et al. 2002; Fuller et al. 2004).

Alewives are easily stressed and, during peak population levels, can be subject to large die-offs

in the spring. They are affected by both osmotic stress associated with life in fresh water and

exposure to fluctuating water temperatures when they move to inshore waters (e.g., exposure

NUREG-1437, Supplement 23 2-26 August 2005
Plant and the Environment

to colder waters during an upwelling event can cause the fish to die [UWSGI 2002]).

Susceptibility to cold is related to inadequate lipid reserves in the spring (Eshenroder et al.

1995). In the spring, alewives are also in a weakened condition due to a lack of forage in the

winter and by stress related to spawning (UWSGI 2001 b). Adult alewives feed little, if at all,

during their spawning migration (DFO 2004). Large numbers of spawning alewives can occur

in nearshore waters as a result of strong year classes produced in the previous three or more

years. Fish that become weak or die during rapid temperature change can be blown into

windrows close to shore or can wash onto beaches (UWSGI 2002). Adult mortality following -

spawning may be as high as 40 to 60 percent (DFO 2004). Therefore, potentially large

numbers of both moribund and dead alewives can be found in the nearshore waters during the

spawning season. The alewife spawning season generally occurs from late May to early

August, peaking in June and July (Jude 1995).

Native to the Atlantic coastal region, the white perch invaded the Great Lakes in 1950

(WDNR 2004d). It preys on eggs of walleye and other species (including its own), zooplankton, -

macroinvertebrates, and minnows. The white perch may compete with yellow perch, emerald

shiner, and spottail shiner for food resources (Fuller 2003).

The round goby first began appearing in southern Lake Michigan in 1994 (Fuller and

Benson 2003). It feeds on the eggs and young of other bottom-dwelling fish species, zebra

mussels, snails, soft-shelled crayfish, aquatic insects, and zooplankton. The round goby

inhabits a wide variety of habitats, but prefers rock, cobble, or riprap (Manz 1998). It has a long

spawning season (e.g., it may spawn up to six times during the breeding season) and

aggressively defends its spawning area. It displaces native sculpins and darters, and impacts

recreationally important centrarchids (sunfish and bass) and lake trout (Great Lakes Science.

Center 2003; Marsden and Chotkowski 1995; Manz 1998; Ray and Corkum 1997). -However,- to

date, no lake-wide changes in the abundance of any Lake Michigan biota has been ascribed to

the round goby invasion (Madenjian et al. 2002). The ruffe (Gymnocephalus cemuus) has also

made its way into Lake Michigan. This species also has the potential to disrupt the fish

community structure within the Lake through competition or modification of plankton and -

macroinvertebrate populations (Jude 1995). - - . - --

Changes in the phytoplankton and zooplankton communities of Lake Michigan may be

occurring as a result of contaminants, nutrients, and invasive species such as the spiny water

flea and zebra mussel (EPA 2002). For. example, phytoplankton abundance and production in

nearshore waters of Lake Michigan have been decreasing since 1970, probably due to

reduction in phosphorus loadings (Madenjian et al. 2002). -Makarewicz et al. (1994) examined

trends in phytoplankton abundance in Lake Michigan from 1983 to 1992 (and, to a limited

extent, historical trends) and related them to "top-down mediated changes" observed in the fish

and zooplankton communities. Bacillariophyta (diatoms) dominated spring samples in all years

but one (1989), making up 69 percent to 95 percent of total algal biomass. Depending on the

August 2005 2-27 -- NUREG-1437, Supplement 23
_ I LL

Plant and the Environment

composition of the zooplankton community, summer phytoplankton samples were dominated by

diatoms, Chlorophyta (green algae), Chrysophyta (yellow-green or yellow-brown algae), and

Pyrrhophyta (dinoflagellates). The presence of the large-bodied zooplankton

(e.g., Daphnia spp.) resulted in increasing abundance of colonial and filamentous algae; while

low numbers of Daphnia spp. were associated with an increasing abundance of small,

unicellular phytoplankton. Makarewicz et al. (1994) also noted that large zooplankton

(e.g., large cladocerans, calanoid copepods, and cyclopoid copepods) became more abundant

in 1983 through 1985 after a sharp decline in the abundance of the planktivorous alewife in

1982 and 1983.

The introduction of the spiny water flea caused a significant decline in three native species of

Daphnia (Lehman 1991). Another non-native cladoceran, the fishhook water flea (Cercopagis

pengoi), has also invaded the Great Lakes (WDNR 2004e). These species compete with

planktivorous larval fish for food and have been implicated as a factor in the decline of alewives

in the following Great Lakes: Erie, Huron, Michigan, and Ontario (Liebig and Benson 2004).

Their spiny tails make it difficult for them to be eaten by young fishes (WDNR 2004e).

However, they are a food source for larger yellow perch, white perch, walleye, white bass

(Morone chrysops), alewife, bloater, Chinook salmon, emerald shiner, spottail shiner, rainbow

smelt, lake herring, lake whitefish, and deepwater sculpin (Liebig and Benson 2004). Another

invasive water flea, Daphnia lumholtzi, also has head and tail spines that make it difficult for

young fish to consume. This protection can allow it to potentially replace native species of

Daphnia (WDNR 2003a).

The Lake Michigan substrate in the area of the PBNP site is characterized by coarse, shifting

sand and gravel overlying hard clay. The substrate is not favorable for the growth of rooted

vegetation (AEC 1972).

The macroinvertebrate community in the PBNP site area was described as "depauperate" due

to the substrates being characterized by coarse, shifting sand and gravel overlying hard clay,

which limits its suitability for macroinvertebrate colonization. Amphipods (e.g., Diporeia spp.),

opossum shrimps (i.e., Mysis relicta), oligochaetes (aquatic worms), sphaeriids (fingernail

clams), and chironomids (midge larvae) dominated the macroinvertebrate community near the

PBNP site (AEC 1972; WEPCO 1976). Since the early 1970s, nearshore benthic communities

in Lake Michigan have undergone dramatic changes as a result of reductions in nutrient loads

(phosphorus) and the establishment of the zebra mussel. Higher nutrient loads in the 1950s

and 1960s were associated with higher productivity and densities of amphipods, oligochaetes,

and sphaeriids (Nalepa et al. 1998). Lower nutrient loads, the result of changes mandated by

the CWA and NPDES programs that reduced point and nonpoint source pollutants in the 1970s

and 1980s, produced declines in oligochaetes and sphaeriids throughout southern Lake

Michigan.

NUREG-1437, Supplement 23 2-28 August 2005
Plant and the Environment

The zebra mussel, a non-native and invasive species, has had an important effect on Lake -

Michigan's aquatic communities by consuming zooplankton and phytoplankton, fundamentally

altering food webs and displacing native mussels. The first zebra mussel was discovered in

Lake Michigan in May 1988, in Indiana Harbor at Gary, Indiana. By 1990, adult zebra mussels

had been found at multiple sites in southern Lake Michigan, and by 1992 ranged along the

eastern and western shoreline in the southern two-thirds of the Lake, as'well as in Green Bay

and Grand Traverse Bay (Fleischer et al. 2001). Zebra mussels appeared in the immediate

vicinity of PBNP by 1991 (Lee 1991).

Because they are capable of filtering up to 1 Uday (0.3 gpd) per adult (Lei 1993), and are

present in high densities (up to several thousand per square meter), zebra mussels remove

large numbers of phytoplankton and zooplankton from the water column. As a consequence,

water clarity increases, and plankton populations tend to decline precipitously. Secondary

impacts can be positive (increased water clarity and increased light transmissivity allow

submerged aquatic vegetation to become established in deeper waters) or negative (some

species of fish and waterfowl feed heavily on zebra mussels, which bioconcentrate

contaminants) (Schloesser et al. '1996). -

Zebra mussels displace native clams and mussels by interfering with their feeding, growth,

reproduction, and respiration, often directly by attaching to the clam or mussel. Hundreds of

zebra mussels may attach to a single large unionid. Because zebra mussels also have a high

reproductive potential,'they often move (or are carried) into an area and can eliminate native

unionid mussels within two to four years (Schloesser et al. 1996). Zebra mussels can also

exclude gastropods (snails) and net-spinning caddisf lies from hard substrates through

competition for food and space (Stewart et al. 1998a). However, they consistently cause

increases in the total macroinvertebrate biomass and densities of hydrozoans, flatworms and

amphipods on hard benthic substrates because their shells enhance surface area, substrate

heterogeneity,-and accumulation of benthic organic matter (Horvath et al. 1999;

Stewart et al. 1998a).

It is suspected that lakewide population declines of Diporeia spp. are linked to the introduction

of the zebra mussel, which has severely limited the food available to Diporeia spp. (EPA 2002).

Declines of Diporeia spp. might be the cause of decline in the abundance of lake whitefish and

slimy sculpin (Madenjian et al. 2004; Stein et al.' 2003) and in the decline in alewife condition

(Madenjian et al. 2002). Reduced biomass of phytoplankton, zooplankton, and Diporeia spp.

caused by zebra mussels may adversely affect rainbow smelt and young salmonids, which in

turn would affect predators of these fishes. However, freshwater drum (Aplodinotus grunniens),

rock bass (Ambloplites rupestris), yellow perch, and other benthivorous fish species consume

large numbers of gammarid amphipods, crayfish,'zebra mussels, and other benthic

macroinvertebrates (Stewart et al. 1998a, 1998b).

August 2005 2-29 NUREG-1 437, Supplement 23
-

Plant and the Environment

The zebra mussel presents a potential serious biofouling problem at power plants. They can

accumulate on the inside of intake tunnels; intake cribs; and screenhouse walls, floors, trash

racks, and out-of-service traveling screens. Zebra mussels are controlled at PBNP by a

number of methods: chlorination (e.g., sodium hypochlorite) of the condensers; continuous

copper ion injection; and a formulation of the aquatic herbicide endothall (a registered

molluscicide known as EVAC). Limitations on these biocides are provided in the WPDES

permit (WDNR 2004a). The cooling water system is described in Section 2.1.3.

The amphipod Echinogammarus ischnus and the quagga mussel Dreissena bugensis (a

species similar to the zebra mussel) have recently been reported in Lake Michigan. Both

species will likely contribute to further food-web modifications in the Lake. The quagga mussel

may further decrease the abundance of Diporeia spp. in offshore areas through competition for

food resources, while Echinogammarus ischnus may become an important food item for many

fish species (Nalepa et al. 2001).

Although not technically aquatic organisms, waterfowl are often found in the vicinity of PBNP,

especially during their seasonal migrations. During September 1990, carcasses of

double-crested cormorants (Phalacrocorax auritus) were discovered in the screenwash from the

traveling water screens and in the forebay of the plant. The intake structure originally extended

2.4 m (8 ft) above the water surface. Double-crested cormorants are abundant in the area

during spring and fall migrations and are attracted to schools of fish in the vicinity of, and within,

the intake structure. They would enter the interior of the intake structure to feed, and because

they must run along the surface for a substantial distance to become airborne, they were

unable to fly out of the intake structure (NMC 2004a). After several failed attempts to reduce or

eliminate mortality of cormorants, the intake structure was redesigned in May 2001, and placed

below the water surface to eliminate any further mortality (NMC 2004a).

No Federally listed threatened or endangered aquatic species occur in Lake Michigan in the

vicinity of PBNP (We Energies 2004b; NMC 2004a). Four state-listed aquatic species

potentially occur in Lake Michigan within the PBNP site area or within some of the waterbodies

crossed by the transmission lines associated with PBNP. The following provides a discussion

of these state-listed aquatic species.

The monkeyface (Quadrula metanevra), a freshwater mussel species, is listed as threatened in

Wisconsin. It inhabits medium-to-large rivers in gravel or mixed sand and gravel substrates

(WDNR 2003c). It has declined due to habitat destruction and water pollution. Locks and

dams may have also limited access of host species to the mussel's habitat (WDNR 2003c).

Reported hosts include the green sunfish (Lepomis cyanellus), bluegill, and sauger

(Stizostedion canadense) (NatureServe 2004). The monkeyface is known from the Branch

River, which is crossed by one of the transmission lines associated with PBNP.

NUREG-1 437, Supplement 23 2-30 August 2005

I I
Plant and the Environment

The lake sturgeon (Acipenser fulvescens) is listed as a species of special concern in

Wisconsin. Wisconsin has one of the largest self-sustaining lake sturgeon populations in the

world (WDNR 2003d), with the largest concentration occurring in Green Bay (WDNR 2004b).

Two Lake Michigan tributaries, the Manitowoc and Milwaukee rivers, do not currently support

remnant lake sturgeon populations, but offer suitable habitat for reproduction. In 2003, stocking

of early life stages of lake sturgeon were conducted in these rivers (WDNR 2004b). Since the

mid-nineteenth century, exploitation, pollution, habitat degradation, and habitat loss have

resulted in substantial declines in the lake sturgeon (Hay-Chmielewski and Whelan 1997;

Lake Michigan Technical Committee 2002). The lake sturgeon inhabits low- and

moderate-gradient big rivers and lakes. Preferred substrates include firm sand, gravel, or rock.

In the Great Lakes, lake sturgeon lives in shoal water (NatureServe 2004). The lake sturgeon

may migrate as far as 125 to 400 km (78 to 250 mi) between non-spawning and spawning

habitats (NatureServe 2004). Once mature, females spawn only once every four to six years.

However, a female can produce 50,000 to 700,000 eggs per spawn and can live to be 80 years

old or more. Eggs of lake sturgeon are preyed upon by common carp, suckers, catfish, and,

other sturgeons (NatureServe 2004). The lake sturgeon preys upon invertebrates such as

leeches, snails, small clams, and aquatic insects (NatureServe 2004). In the Wisconsin portion

of the Lake Michigan basin, the lake sturgeon occurs in Green Bay, Lake Michigan, the -

Menominee River upstream to White Rapids Dam, the Fox River upstream to Lake Puckaway,

and the Wolf River upstream to Shawano. It is uncommon to rare in the Wisconsin portion of

Lake Michigan (WDNR 2003d). A lake sturgeon management plan has been developed for

Wisconsin (WDNR 2003d). -

The redfin shiner (Lythrurus umbratilis) is listed as threatened in Wisconsin. It usually occurs in

turbid waters at depths of 10 to. 152 cm (4 to 60 in.) over silt, gravel, and rubble substrates in

pool areas of low-gradient, medium-sized streams. However, it requires clear water during -

spawning, which may account for its limited occurrence. They spawn in nests and nesting

territories of sunfish species (WDNR 2003e). The redfin shiner schools near the surface and

feeds on filamentous algae, macrophytes, and aquatic and terrestrial invertebrates -

(WDNR 2003e). The redfin shiner is known from the West Twin River watershed, which is

crossed by the transmission lines associated with PBNP.

The greater redhorse (Moxostoma valenciennes,) is listed as threatened in Wisconsin. It

inhabits medium- to large-sized rivers, reservoirs, and large lakes at depths <1 m (3 ft)

(WDNR 2003f). The greater redhorse prefers clear water with substrates of clean sand, gravel,

or boulders. Spawning beds consist of gravel with mixtures of sand and rubble in moderate to

swift currents. The range and abundance of the greater redhorse have declined due to

siltation, pollution, and other habitat degradation (NatureServe 2004). The eggs of the greater

redhorse are preyed upon by yellow perch and American eels (Anguilla rostrata)

(NatureServe 2004). Molluscs, aquatic insects, and crustaceans are its main diet, although it

also consumes some plant material (NatureServe 2004). However, its presence is now known

August 2005 - 2-31 NUREG-1 437, Supplement 23
-__ L LL

Plant and the Environment

to be more common than previously thought in Wisconsin, accounting for its change in status

from state-endangered to state-threatened (WDNR 2003f). The greater redhorse occurs in

some of the streams and rivers crossed by the PBNP transmission lines (e.g., Branch River,

Neshota River, East Twin River, and West Twin River; NMC 2004a).

2.2.6 Terrestrial Resources

The PBNP site is located on 510 ha (1260 ac) on the western shore of Lake Michigan

(NMC 2004a). The site and surrounding area consist primarily of agricultural land and forest.

Approximately 42 ha (104 ac) of the property are devoted to industrial use. The site consists of

land leased for farming and woodlots up to 19 ha (47 ac) in size. The woodlots occupy a total

of about 40 ha (100 ac), making up about 9 percent of the PBNP property. The plant

communities forming the overstory include a variety of trees such as quaking aspen (Populus

tremuloides), American beech (Fagus grandifolia), Canadian hemlock (Tsuga canadensis), and

maple (Acerspp.) (AEC 1972). The woodlots are maintained in a natural state and provide

food, cover, and nesting sites for a variety of wildlife.

The terrestrial wildlife that occurs at PBNP and surrounding areas is typical of that found in

similar habitats throughout Wisconsin (AEC 1972). Common mammals include white-tailed

deer (Odocoileus virginianus), eastern cottontail rabbit (Sylvilagus floridanus), northern raccoon

(Procyon lotor), gray fox (Urocyon cinereoargenteus), eastern gray squirrel (Sciurus

carolinensis), eastern chipmunk (Tamias striatus), and masked shrew (Sorex cinereus). Upland

birds that occur on the property include ring-necked pheasant (Phasianus colchicus), wild

turkey (Meleagris gallopavo), American goldfinch (Carduelis tristis), eastern bluebird

(Sialia sialia), blue jay (Cyanocitta cristata), and eastern meadowlark (Stumella magna).

Several waterfowl also occur there, including the Canada goose (Branta canadensis), the wood

duck (Aix sponsa), and the double-crested cormorant (Phalacrocorax auritus). Additionally, the

site is occupied by several common amphibians and reptiles such as the tiger salamander

(Ambystoma tigrinum), northern leopard frog (Rana pipiens), American toad (Bufo americanus),

and the painted turtle (Chrysemys picta).

The PBNP property contains about 3 km (2 mi) of Lake Michigan shoreline. The shoreline

consists of mostly narrow, bare beaches ranging from 6 to 15 m (20 to 50 ft) wide that extend

from the water's edge to low bluffs created by years of erosion. Riprap has been placed along

the edges of the bluffs to reduce erosion, which had been occurring at the rate of 0.8 m to

1.5 m (2.5 ft to 5 ft) per year (AEC 1972). The shoreline on the PBNP property does not

contain any sand dunes. NMC protects species that require beach habitat by restricting

unauthorized public access to the Lake Michigan beach area of the PBNP site with a line of

boulders at the north and south boundaries, buoy markers off the shoreline to mark restricted

NUREG-1 437, Supplement 23 2-32 August 2005

I I
Plant and the Environment

waters, and 24-hour surveillance by security personnel (We Energies 2004b). Additional

protections have been implemented for the Federally endangered piping plover (Charadrius

melodus) (We Energies 2004d).

No Federally or State-listed threatened or endangered species of terrestrial wildlife are known

to occur at the PBNP site or associated transmission line ROWs (NMC 2004a; We Energies

2004b). Three Federally listed threatened or endangered species have been recorded in

Manitowoc County: the bald eagle (Haliaeetus leucocephalus), piping plover, and dune (or

Pitcher's) thistle (Cirsium pitchen) (WDNR 2004f). The dwarf lake iris (iris lacustris), also a

Federally listed species, has been recorded in Brown County, through which a portion of the

L-151 transmission line ROW traverses. Table 2-2 presents those Federally and State-listed

species that have been recorded in Brown and Manitowoc counties and could potentially occur

on the PBNP site or transmission line ROWs if suitable habitat were available.

Table 2-2. Terrestrial Species Listed by the FWS as Endangered or Threatened that Could

Potentially Occur within the PBNP Site or the Associated Transmission Line ROWs

Federal

Scientific Name Common Name Status" - State Status(a)

Birds

Haliaeetus leucocephalus bald eagle T S

Charadrus melodus piping plover E E

Plants

Cirsium pitchen dune (or Pitcher's) thistle - T T

Iris lacustris dwarf lake iris T T

(a) E = endangered, T = threatened, S = Wisconsin species of special concern.

Sources: WDNR 2004f, 2004g, 2004h, 2004i, 2004j

The bald eagle is Federally listed as threatened in the lower 48 states (FWS 2004b). This

species is a large raptor that is found along the coastline around lakes and rivers. Eagles

generally nest in tall trees or on cliff faces near water and away from human disturbance. No

bald eagle nesting occurs on the PBNP site, and no bald eagles have been observed to forage

in the vicinity of the plant (We Energies 2004b). The transmission lines associated with PBNP

extend for the most part to the west, away from Lake Michigan and bald eagle foraging habitat.

The piping plover is Federally listed as endangered in the Great Lakes region. Great Lakes

piping plovers breed along sparsely vegetated beaches, cobble pans, and sand spits along the

shoreline. The FWS defines their essential breeding habitat as greater than 7 m (23 ft) wide

beach, greater than 0.4 km (0.25 mi) of shoreline length, dune area of 1.95 ha (4.82 ac),

August2OO5 - 2-33- NUREG-1437, Supplement 23
____I CL

Plant and the Environment

patches of cobble or debris cover, and areas of beach with up to 50 percent of vegetation cover

(FWS 2003). The nearest stretch of shoreline that is designated as critical breeding habitat is

at Point Beach State Forest, approximately 5 km (3 mi) to the south, where about 13 km (8 mi)

of shoreline have been designated as suitable, although no records of breeding at that location

exist (FWS 2001). Portions of the shoreline managed by PBNP also appear to be suitable

nesting habitat (We Energies 2004d). In October 2004, We Energies commissioned a habitat

study of the shoreline. The study showed that the habitat, although not optimal, could support

piping plover nesting (We Energies 2004d). The only breeding plovers known within Wisconsin

in recent years have been along the shores of Lake Superior (WDNR 2004g).

The dune (or Pitcher's) thistle is Federally listed as threatened over its entire range

(FWS 2004b). The preferred site for the dune (or Pitcher's) thistle is an area between a sandy

beach and a fully vegetated dune next to the shorelines of the Great Lakes (WDNR 2004b).

The primary threats to the species are disturbance through recreational activities (all terrain

vehicle use, trampling, etc.) and overstory encroachment (NatureServe 2004). No suitable

habitat for this species has been identified at the PBNP site or along associated transmission

line ROWs.

The dwarf lake iris is Federally listed as threatened over its entire range (FWS 2004b). The

dwarf lake iris is endemic to the northern shores of Lake Michigan and Lake Huron. This

species is found in association with the Niagara Escarpment, a limestone formation that

extends from the Door Peninsula to the north of PBNP through Michigan and Ontario to New

York. In Wisconsin, the dwarf lake iris is found on the northwestern shore of Lake Michigan

and the eastern shore of Green Bay in Brown and Door counties (WDNR 2004b). The primary

threat to this species is habitat degradation due to overstory encroachment

(NatureServe 2004). This species apparently thrives with frequent natural disturbance, does

not appear to be detrimentally impacted by human disturbance, and is reported to do well in old

field conditions (NatureServe 2004). The dwarf lake iris has not been recorded at the PBNP

site or along associated transmission line ROWs.

The only terrestrial State-listed threatened or endangered species believed to occur in the

vicinity of PBNP transmission lines is the snow trillium (Trillium nivale) (WDNR 2004j, 2004k).

Populations are known to occur in mesic forests in the Kriwanek Creek drainage, which is

crossed by line L-121, and the Devil's Creek drainage, which is crossed by line L-151.

However, this species is not recorded as occurring in these transmission line ROWs.

NUREG-1437, Supplement 23 2-34 August 2005

I I
Plant and the Environment

2.2.7 Radiological Impacts

NMC conducts a radiological environmental monitoring program in and around the PBNP site.

An environmental monitoring program was initiated before plant operations began in 1970.

Through this program, radiological impacts to employees, the public, and the environment are

monitored, documented, and compared to the appropriate standards. Results are published

annually. The objectives of the radiological environmental monitoring program are the

following:

* Provide representative measurements of radiation and radioactive materials in the

exposure pathways and of the radionuclides that have the highest potential for radiation

exposures to members of the public.'

* Supplement the radiological effluent monitoring program by verifying that measurable

concentrations of radioactive materials and levels of radiation are not higher than

expected on the basis of effluent measurements and the modeling of the environmental

exposure pathways.

Radiological releases are summarized in the Annual Monitoring Reports (e.g., NMC 2004c).

The limits for all radiological releases are specified in the PBNP ODCM (NMC 2003b); theses

limits are designed to meet Federal standards and requirements.'

Because land in the area is used primarily for farming and dairy operations, environmental - -

components, such as soil and vegetation, are sampled to detect changes in radiological

conditions at the base of the terrestrial food chain for animals. Because dairy farming is a:

major industry in the area, milk produced in the area is also sampled. Air particulate samples

and thermoluminescent dosimeters at various locations provide the means to detect significant

changes in environmental radioactivity that would result from plant releases to the atmosphere.

Locations for terrestrial radiological sampling emphasize monitoring around the site boundary

and at various other points out to a distance of approximately 8 km (5 mi). A single sampling

location well beyond a distance of approximately 16 km (10 mi) is used to provide an estimate

of background levels.'

Aquatic samples, such as lakewater, algae, and shoreline sediment, are collected from LakeMichigan locations both north and south of the wastewater discharge point and analyzed for

radioactivity. -

For 2003, NMC assessed doses to the maximally exposed individual from gaseous and liquid

effluents at several locations based on actual liquid and gaseous effluent release data. In all

cases, doses were well below the 25 mrem/yr limit as defined in the ODCM and the EPA

August 2005 2-35 NUREG-1437, Supplement 23
I IJ1

Plant and the Environment

radiation standards in 40 CFR Part 190 (NMC 2003b). A breakdown of the calculated

maximum dose to an individual located at the site boundary from liquid and gaseous effluents

released during 2003 is summarized as follows:

• The total body dose from liquid effluents at the site discharge was 8 x 1o-5 mSv

(0.008 mrem), which is about 0.14 percent of the 0.06 mSv (6 mrem) dose design

objective specified in 10 CFR Part 50, Appendix I. The critical organ dose due to the

liquid effluents at the site discharge was 8 x 110- mSv (0.008 mrem). This dose was

about 0.04 percent of the 0.20 mSv (20 mrem) dose design objective (NMC 2004c).

* The air dose from noble gases in gaseous effluents was 3.45 x 10-6 mGy

(3.45 x 10-4 mrad) gamma, which is 0.002 percent of the 0.2 mGy (20 mrad) gamma

dose design objective, and 1.27 x 10-6 mGy (1.27 x 10-4 mrad) beta, which is

0.03 percent of the 0.4 mGy (40 mrad) beta dose design objective (NMC 2004c).

* The critical organ dose from gaseous effluents due to iodine-131, iodine-133, tritium,

and particulates with half-lives greater than 8 days was 3.12 x 10-4 mSv (0.03 mrem),

which is 0.1 percent of the 0.3 mSv (30 mrem) dose design objective (NMC 2004c).

Absent a change in licensed power levels, NMC does not anticipate any increase in radiological

impacts during the license renewal period.

2.2.8 Socioeconomic Factors

The staff reviewed the ER (NMC 2004a) and information obtained from county, city, school

district, and local economic development staff. The following sections describe the housing

market, public services, offsite land use, visual aesthetics and noise, demography, and

economy in the region surrounding the PBNP site.

2.2.8.1 Housing

NMC employs a nuclear related permanent workforce of approximately 740 employees and an

additional 231 contract employees at PBNP. Approximately 81 percent of the employees live in

Manitowoc County. The remaining 19 percent are distributed across 12 counties, with numbers

ranging from 1 to 73 employees per county (NMC 2004a). Given the predominance of

employees living in Manitowoc County, and the absence of the likelihood of significant

socioeconomic effects in other counties, the focus of this analysis is Manitowoc County,

particularly the City of Manitowoc, the City of Two Rivers, the Town of Two Creeks, and the

Village of Mishicot (79 percent of the PBNP employees live in these municipalities).

NUREG-1437, Supplement 23 2-36 August 2005

I I
Plant and the Environment

The PBNP reactors are each on a nominal 18-month refueling cycle. During refueling outages,

nuclear related site employment increases above the 740 permanent workforce by

approximately 300 workers for temporary duty (30 to 40 days) (NMC 2004a). Most of these

temporary contractor employees are assumed to be located in the same geographic areas as

the permanent PBNP staff. These workforce numbers are w'ithin the GEIS estimated range of

200 to 900 additional workers per reactor outage.

Table 2-3 shows an overview of occupied and unoccupied housing units available in Mishicot,

Two Creeks; Manitowoc, Two Rivers, and Manitowoc County for 1990 and 2000, the last year

for which data are available. The County as a whole had a vacancy rate slightly greater than

5 percent. The vacancy rates in specific communities varied from 5 to 9 percent and showed

similar trends from 1990 to 2000.

Table 2-3. Housing Units and Occupied Housing Units for Manitowoc County and

Municipalities during 1990 and 2000

Percent of Units

Total Units Occupied Units Occupied

1990 2000 -1990 2000 .1990 - 2000

Mishicot 503 614 488 582 ----- 97.02 94.79

Two Creeks 164 202 148 i84 90.24 .91.09

Manitowoc (City) 13,729 15,007 13,145 14,235 95.75 94.86

Two Rivers 5414 5547 5164 5221 95.38 94.12

Manitowoc County 31,843. 34,651- 30,112 32,721 -94.56 - 94.43

Source: Wisconsin Department of Administration (WDA) 2004a

2.2.8.2 Public Services

* Water Supply

Within Manitowoc County, municipal water is largely supplied by municipal or village water

utilities. 'PBNP is not connected to a local utility and pumps groundwater for its own use. The

primary municipal water suppliers in Manitowoc County are listed in Table 2-4 along with their.

average daily output and maximum capacities.

The total daily use shown here is 10.6 million gpd forlthe entire County. This closely agrees |

with U.S.-Geological Survey (USGS) estimates of 10.44 million gpd of surface-water use and

1.05 million gpd groundwater use for Manitowoc County (USGS 2002).

August 2005 2-37 NUREG-1437, Supplement 23
___LLL_

Plant and the Environment

Table 2-4. Manitowoc County Public Water Suppliers and Capacities

Maximum Daily Capacity Water Supplier

Cleveland Waterworks

Kellnersville Waterworks

Kiel Waterworks

Manitowoc Waterworks

Maribel Waterworks

Mishicot Waterworks

Reedsville Waterworks

St. Nazianz Waterworks

Two Rivers Waterworks

Valders Waterworks

Whitelaw Waterworks

Total

Source: NMC 2004a

Average Daily Use

(gpd)

120,000

320,000

415,000

8,000,000

25,000

150,000

45,000

60,000

1,300,000

120,000

55,000

10,610,000

Maximum Daily Capacity

(gpd)

1,150,000

500,000

2,660,000

11,000,000

720,000

1,200,000

1,000,000

1,000,000

4,000,000

1,440,000

720,000

25,390,000 - _

* Education

In 2000, approximately 14,369 students attended schools in the districts located near the PBNP

site. The region's school districts do not track the number of PBNP employees' children

enrolled. Table 2-5 shows the total enrollment for students in the PBNP vicinity.

I Table 2-5. School District Enrollment in Communities near PBNP

District Pre-Kindergarten Grades K-6 Grades 7-12

Manitowoc 2285 3670 3695

Mishicot 360 705 69

Two Rivers 755 1470 1360

* Transportation

The region within an 80-km (50-mi) radius of PBNP is served by Interstate 43, which runs

north-south near the lake front in southern Manitowoc County. At the City of Manitowoc,

Interstate 43 turns inland to Green Bay. The region is also served by Canadian National rail

NUREG-1437, Supplement 23 2-38 August 2005

Il
Plant and the Environment

lines connecting to Neenah to the'west and Milwaukee to the south.' A rail line runs part of the

way from Manitowoc to Green Bay. The Manitowoc County airport is located on the northern

edge of the City of Manitowoc. -

State Route 42 runs north-south from Two Rivers to Kewaunee and passes about 1.6 km (1 mi)

to the west of PBNP. It is used by most employees coming from Two Rivers, Manitowoc, or,

Mishicot to access the plant. From Mishicot, employees reach State Route 42'via County

Road V. Employees access the plant by turning east off State Route 42 onto Nuclear Road and

traveling approximately 2.4 km (1.5 mi) to the plant entrance (Figure 2-2).

Traffic counts for State Route 42 and County Road V are shown in Table 2-6. The State does

not make level of service determinations in rural nonmetropolitan areas unless it has been

deemed necessary. The Wisconsin Department of Transportation (WDOT) has not calculated

level of service determinations for either of the roads listed (WDOT 2002).

Table 2-6. Traffic Counts for State Route 42 and County Road V

Route No. Location AADT

State Route 42 North of County Road V 3800

South of County Road V 3700

County Road V East of State Route 42 330

West of State Route 42 1200

AADT Annual average daily traffic volumes for 2002.

-:Source: WDOT 2002

2.2.8.3 Offsite Land Use

PBNP is situated in northern Manitowoc County close to the Kewaunee County line. Both of

these counties are on the western shore of Lake Michigan, and both are largely rural with a: -

heavy dependence upon agriculture. Manitowoc County maintains information on land use,

which is derived from aerial photographs and periodically updated.'

Land use in Manitowoc County is predominantly agricultural; approximately 58 percent of its

land area is devoted to agriculture. Of the remainder, much'of the land is undeveloped

woodland, wetland, or land not used for crops; only 7 percent is classified as urban or

developed (Table 2-7).' The approximately 1400 farms within the'County cover a total of '

1.05 x 105 ha-(2.6 x 105 ac), averaging 75'ha (186 ac) per farm. Of the 1400 farms,';'

approximately 375 are dairy farms with 45,300 cows. Manitowoc County ranks 5th'in Wisconsin

and 27th in the United States in milk production. 'Other crops in the County include alfalfa'

August 2005 2-39 - NUREG-1 437, Supplement 23 -
-

Plant and the Environment

(26,000 ha (64,200 acd), corn (24,700 ha [61,000 acd), oats (3035 ha [7500 ac]), barley

(4450 ha [11,000 ac]), soybeans (8500 ha [21,000 ac]), and snap beans (1950 ha [4800 ac]).

Total farm and farm-related employment accounts for approximately 20 percent of the total

County employment (University of Wisconsin 2004a).

Table 2-7. Land Use in Manitowoc County, 1999

Land Use Hectares Acres Percent of Total

Agriculture 89,416 220,953 58.0

Buildings 10,617 26,235 6.9

Non-Cropland 15,088 37,284 9.8

Non-Metallic Mining 684 1690 0.4

Roads 3412 8432 2.2

Surface Water 1750 4326 1.1

Wetlands 376 930 0.3

Woodlands 32,921 81,352 21.3

Total 154,264 381,202 100.0

Source: Yanda 2004

Kewaunee County is also heavily dependent on agriculture. Of the approximately $88 million

generated from agriculture sales in Kewaunee County in 2002, approximately $67 million was

generated from dairy farms (University of Wisconsin 2004b). There are around 970 farms in

Manitowoc County, of which 318 are dairy farms. The average size of a farm is approximately

73 ha (181 ac). Other agricultural crops include corn, alfalfa, soybeans, small grains, and

vegetables. Approximately 2300 jobs are related to agriculture, which represents approximately

20 percent of the Manitowoc County total (University of Wisconsin 2004a).

A few industrial areas are located south of the PBNP site in the towns of Two Rivers and

Manitowoc and to the west in the Fox River Valley. KNPP is the nearest industrial site, located

approximately 8 km (5 mi) north of PBNP. KNPP is a single unit 535-MW(e) pressurized water

reactor located on approximately 367 ha (908 ac).

The Point Beach State Forest is located approximately 4.8 km (3 mi) south of the PBNP site

and offers fishing, boating, hiking, camping, and picnicking. The Rahr Memorial School Forest

is located 1.6 km (1 mi) south of the plant and offers a wide range of educational and outdoor

activities. Two Creeks Town Park is located north of the PBNP site and also provides some

NUREG-1437, Supplement 23 2-40 August 2005

I I
Plant and the Environment

lakeside recreation. The Two Creeks Buried Forest unit of the Ice Age National Scientific

Reserve is located approximately 3.2 km (2 mi) north of the plant. This reserve is affiliated with

the National Park Service and provides public access to remnants of a buried forest.

In an effort to decrease urban sprawl, the State established a statute outlining the development

of farmland prservation areas. The MCPPC prepared the Manitowoc County Farmland

Preservation Plan in 1981 (currently undergoing revision) to provide guidance to the -

communities 'within the County in their efforts to guide future growth and protect valuable

farmlands (MCPPC 1981). This plan qualifies lands designated as "restrictive agriculture" for

tax credits and makes it difficult to change the zoning of the land from agriculture to another

designation.

There are 18 towns in Manitowoc County. Land-use planning and city growth are managed at

the town or city level and not at the regional or county level. Many of the communities use

zoning to direct the'extent and nature of growth. Zoning has remained relatively unchanged

since the preparation of the Manitowoc County Farmland Preservation Plan. The area around

the PBNP site has remained zoned for agriculture, and no significant industrial, business, or

residential development has occurred near the site boundaries.

2.2.8.4 Visual Aesthetics and Noise

PBNP is located in Manitowoc County on the western shore of Lake Michigan. The local terrain

is gently rolling to flat, with elevations varying from 1.5 to 18 m (5 to 60 ft) above the normal

level of Lake Michigan. The land surface slopes gradually toward the Lake from higher glacial

moraine areas west of the site. However, higher ground adjacent to the Lake diverts the

drainage to the north and south.

The site occupies an area of approximately 510 ha (1260 ac), all owned by WEPCO.

Structures and parking lots occupy approximately 28 ha (70 ac). Of the balance, approximately:

425 ha (1050 ac) are divided among nine leases and used for agriculture. The crops grown on

the leased land are primarily grain crops and include corn, soybeans, and wheat. The

remainder of the site consists of woods, wetlands, and open space. The site includes

approximately 3.2 km (2 mi) of shoreline on Lake Michigan (NMC 2004a).

Structures at PBNP include two reactor containment buildings; associated auxiliary, service,

turbine, and office buildings; a switchyard; a pump house; and cooling-water intake and

discharge structures. The largest of the structures (the reactor containment buildings) are

approximately 19 m (63 ft) high. The plant is visible from State Highway 42 for several miles in

either direction but is not a prominent feature to the residents of the Town of Two Creeks.

August 2005 2-41 NUREG-1437, Supplement 23
- - . - LL

Plant and the Environment

From the Lake, the plant is visible for many miles to the north and south, as is KNPP located

8 km (5 mi) to the north. The PBNP reactor containment structures are encased in vinyl coated

steel buildings that are colored to blend with the green and brown Wisconsin countryside

(AEC 1972).

The PBNP transmission line ROWs occupy approximately 1344 ha (3321 ac) (NRC 1996) and

run through rural, agricultural land. From PBNP, three of the transmission lines run east-west

and connect the plant to the existing State power grid. The fourth line connects PBNP to KNPP

8 km (5 mi) to the north. While the transmission line towers are typically at or slightly above the

level of the wooded areas, which helps obscure them from populated areas, they are very

visible in open and agricultural areas. In a few locations, the towers are visible to the residents

of Two Creeks. The transmission lines in open areas are visible for several miles from

roadways and for a much shorter distance when the ROWs run through wooded areas.

Noise from operations at the PBNP site is barely noticeable, except very close to the reactor

containment buildings. While some noise may reach the leased lands which are located within

the site boundary, no noise from normal plant operations reaches the residential areas around

the Town of Two Creeks.

2.2.8.5 Demography

In 2000, the population of Wisconsin was approximately 5.36 million (U.S. Census Bureau

[USCB] 2004). Table 2-8 shows the population for Manitowoc County and selected

municipalities. From 1990 to 2000, Wisconsin had an average annual growth rate of

approximately 1.0 percent. The average annual growth rate of Manitowoc County during the

same period was 0.3 percent (USCB 2004). Wisconsin and Manitowoc County are both

projected to grow relatively slowly over the next 30 years. (As shown in Table 2-9, a projected

average annual growth rate for Wisconsin as a whole of 0.6 percent, versus 0.3 percent for

Manitowoc County.)

NUREG-1437, Supplement 23 2-42 August 2005

I III
Plant and the Environment

Table 2-8. Population of Manitowoc County and Selected Municipalities

Total Population

Municipality or County 1970 1980 1990 2000

Two Creeks

Mishicot

Manitowoc (City)

Two Rivers

Manitowoc County

580

938

33,430

13,732

82,294

489 466

1503 1296

- 32,547 - 32,521

13,354 13,030

82,918 80,421 -

551

1422 - -:

34,053 -

12,639

- 82,887

Source: WDA 2004b

Table 2-9. Population Projections for Wisconsin and Manitowoc County

Year Wisconsin (a) Manitowoc County (

2000 5,363,715 82,893

2005 5,563,896 84,574

2010 5,751,470 86,307

2015 5,931,386 88,055

2020 6,110,878 89,860

2025 - 6,274,867 90,821

2030 6,415,923 91,327-,

(a) Based on 0.6 percent annual growth (WDA 2004c)

(b) Based on 0.3 percent annual growth (WDA 2004d)

* Transient Population

There is little transient population for agriculture in the vicinity of PBNP. Almost all of the

laborers on farms in the area are believed to be residents in the area. Seasonal migrant labor

plays little or no role in field agriculture in the PBNP region.

* Agricultural Labor r

Although this is an agricultural region, agriculture employs a relatively small fraction of the

workforce in the communities near PBNP and within Manitowoc County, as shown in

Table 2-10. . -

August 2005- 2-43 NUREG-1437, Supplement 23
-

Plant and the Environment

2.2.8.6 Economy

Although much of the land use in the region is agricultural, only a very small portion of the

population is actually employed in agricultural occupations, as shown in Table 2-1 0. The

majority of the population is employed in production, managerial, and office occupations.

Table 2-10. Occupations in Nearby Municipalities and Manitowoc County

Occupations Mishicot

Manitowoc

(City)

4011

Two Rivers

1357

Manitowoc

County

Management, Professional, and 10,448

Related Occupations

Service Occupations

Sales and Office Occupations

Farming, Fishing, and Forestry

Occupations

Construction, Extraction, and

Maintenance Occupations

Production, Transportation, and

Material Moving Occupations

182

133

146

10

80

191

2639

3866

96

1450

4640

862

1194

36

549

2271

5793

8880

820

4264

12,748

Source: WDA 2004e

Within Manitowoc County, the median household income is $43,286 per year (USCB 2000).

During the first six months of 2004, the unemployment rate ranged between 6.7 and 9.8 percent

(Table 2-11). For comparison, the unemployment rate for Wisconsin ranged from 4.8 to

6.5 percent during the same period (Wisconsin Department of Workforce Development

[WDWD] 2004).

Table 2-11. Unemployment Rates for Manitowoc County in 2004

Employed Unemployed Unemployment Rate

January 43,955 4000 9.1

February 44,051 4302 9.8

March 43,969 4093 9.3

April 43,568 3206 7.4

May 43,723 2936 6.7

June 44,680 3065 6.9

Source: WDWD 2004

NUREG-1437, Supplement 23 2-44 August 2005

I
Plant and the Environment

In Wisconsin, public utilities are exempt from local property taxation and, instead, -are taxed by

the State. Public utilities pay gross revenue taxes to the State in lieu of property taxes. Gross

revenue taxes paid by utilities become part of the State's general purpose revenue, which goes

to fund the Wisconsin Shared Revenue Program, which provides the largest aid payment for

municipalities and is an important source of revenue for counties.

The shared revenue program has several separate payment types, including a utility payment.

Only shared revenue utility payments are distributed to counties and municipalities based on

the presence of an electric utility facility. The other payments are distributed based on a

formula that is independent of utility valuation or location (Wisconsin Department of Revenue

[WDR] 2003a). The utility payment consists of three components: :net book value, spent:

nuclear fuel storage, and the minimum payment (WDR 2003a). The minimum payment

component does not apply to PBNP. The formulas and rules controlling the net book value and

spent nuclear fuel storage components are slightly different for counties and municipalities.

The rules for counties are the following:

Utility. The utility payment consists of three components: (a) A payment based on the net

book value of qualifying property of electric and gas utilities. For property in towns, the

county received 6 mills on the net book value. For property in villages or cities, the county

received 3 mills. The total value of qualifying property for payment purposes in a

municipality (the basis on which county payments are calculated) may not exceed

$125 million per utility company or for a jointly owned power plant. Payments could also not

exceed $100 per capita. (b) A payment of $50,000 to counties in which spent nuclear fuel

was stored. (c) If a county had a generating plant having a rated capacity of 200 megawatts

or more, the payment could not be less than $75,000 (WDR 2003a).

The rules for municipalities are the following:

Utility. The utility payment consisted of three components: (a) A payment based on the net

book value (original cost less depreciation) of qualifying property (production plants,

substations, and general structures, excluding land) of electric and gas utilities. For

property in towns, the town received 3 mills on the net book value. For property in villages

or cities, the village or city received 6 mills. The total value of qualifying property for

payment purposes in a municipality could not exceed $125 million per utility company or for

a jointly owned power plant. Payments could also not exceed $300 per capita. (b) A

payment of $50,000 to municipalities in which spent nuclear fuel was stored. If the nuclear

fuel storage facility was located within one mile of another municipality, the municipality

where the fuel was stored received $40,000 and the nearby municipality received $1 0,000.

(c) If a municipality had a generating plant having a rated capacity of 200 megawatts or

more, the payment could not be less than $75,000.

August 2005- 2-45 NUREG-1 437, Supplement 23
_-_ -IELL

Plant and the Environment

Note that the shared revenue formula changed to a megawatt based payment for plants put into

operation or repowered after January 1, 2004. However, this does not apply to PBNP.

The Town of Two Creeks and Manitowoc County are the recipients of the shared revenue utility

payments attributable to PBNP. Tables 2-12 and 2-13 list the total tax revenues of the Town of

Two Creeks and Manitowoc County and the shared revenue utility payments from the State. As

is presented in the tables, the shared revenue utility payments attributable to PBNP represent

approximately 14 to 20 percent (excluding the 1999 payment) of the tax revenues of Two

Creeks. The shared revenue utility payments attributable to PBNP represent approximately

1.4 to 2.0 percent of the total tax revenues of Manitowoc County.

Table 2-12. Total Tax Revenues and Shared Revenue Utility Payments for the Town of

Two Creeks

Total Tax Shared Revenue Utility Payment Percent of Total Tax

Year Revenues('c b. c) on behalf of PBNP(d) Revenues

1996 $982,600(a) $190,100 19.3

1997 $1,026,300 $191,900 18.7

1998 $937,200 $193,400 20.1

1999 $270,500(e) $194,600 72.0

2000 $1,420,800 $194,600 13.7

2001 $881,800 $216,500 24.5

2002 $933,100 $217,100 23.3

(a) Data for 1996 through 2000 from NMC 2004a

(b) Data for 2001 from WDR 2003b

(c) Data for 2002 from WDR 2004

(d) Calculated based on WDR 2003a

(e) The Town of Two Creeks' 1999 interest income was negative due to market fluctuations.

NUREG-1437, Supplement 23 2-46 August 2005

I l
Plant and the Environment

Table 2-13. Total Tax Revenues and Shared Revenue Utility Payments for Manitowoc

County

Total Tax Shared Revenue Utility Payment Percent of Total Tax

Year Revenues (ba,) - -on behalf of PBNP(d) Revenues

1996 $40,129,000 - $800,000 2.0

1997 $41,556,900 $800,000 1.9

1998 $47,112,400 $800,000 1.7

1999 $51,694,700 $800,000 1.5

2000 $55,931,600 $800,000 1.4

2001 $67,044,000 $800,000 1.2

2002. - $57,966,000 - - $800,000 1.4-

In}1 lnnt fnr I OOf thrnt inh 9nnn from .NM 2flon A- -. - - - . - - - ' -

(b) Data fr0 from WDR - -v - --- (b) Data for 2001 from WDR 2003b

(c) Data for 2002 from WDR 2004

(d) Calculated based on WDR 2003a

; . I - . I I . - . . i

2.2.9 Historic and Archaeological Resources -

This section discusses the cultural background and the known historic and archaeological

resources at the PBNP site and the surrounding area.

2.2.9.1 Cultural Background '

Wisconsin was last glaciated beginning about 25,000 years ago. The glaciers reached their

greatest extent 14,000 to 16,000 years ago, and the last glacial advance (the Two Rivers, or

Valderan) dates to about 12,400 years ago. The topography of Wisconsin is strongly -

influenced by glacial and postglacial geological deposits. These landforms affected the pattern'

of human'use and settlement. Until about 12,000 to 14,000 years ago, all of northern and

eastern Wisconsin was buried by ice sheets. By about 12,000 years ago, the glaciers had

retreated and exposed most of the current area of Wisiconsin. The western shore of postglacial

Lake Michigan,' however, 'continued to expand and retreat for the next several thousand years

(Illinois State Museum 2004) in a complex manner dictated by impoundment of water against

the retreating ice, new outlets opening up as the ice retreated, and a rebounding of the land

surface (isostatic uplift) as the weight of the glacial ice was removed. -

August 2005 2-47 --: NUREG-1437, Supplemient 23
- -- tLi L 

Plant and the Environment

* Native American Prehistory

The distribution of Paleo-lndian remains, the earliest known prehistoric tradition, in Wisconsin

correlates with the last stages of glacial activity and the fluctuating lake levels (R. Mason 1997).

Paleo-lndians are believed to have exploited newly opened postglacial environments and to

have been organized in small mobile hunting societies (R. Mason 1997). In general, early

Paleo-lndian groups appear to have been more numerous in southern Wisconsin than in the

north where glacial conditions persisted longer (R. Mason 1997). Paleo-lndian groups hunted

large, now extinct megafauna, such as mastodon, mammoth, and caribou, that lived on the lush

vegetation that colonized postglacial soils (R. Mason 1997). By the later Paleo-lndian period,

the levels of the Great Lakes may have been significantly lower than present. Paleo-lndian

sites of this period may now be submerged several hundred feet below the current surface

(R. Mason 1997). The later Paleo-lndian sites, while retaining a basic hunting orientation, used

woodworking tools that reflect the increasing forestation of the previously glaciated land. Late

Paleo-lndian sites are widespread and continue to reflect small mobile populations. Instead of

megafauna, the species hunted during the later period included deer, caribou, bison, turtle,

beaver, and other small mammals (R. Mason 1997).

With the onset of warmer climatic conditions, a further shift in subsistence patterns becomes

obvious. Beginning sometime between 10,000 and 7500 years ago, Archaic Tradition

populations consisting of small groups of hunters and gatherers living in caves, rock shelters,

along rivers, and around lakes and wetlands, replaced the older Paleo-lndian Tradition. Archaic

peoples may have been direct descendants of Paleo-lndians or may represent a migration of

people from the south (Stoltman 1997). These hunter-gatherers subsisted on fish, wild plants,

nuts, acorns, and modern game animals such as elk and deer (Stoltman 1997). Settlement

appears to have been sparse; small mobile groups, relying on diverse hunting and gathering

subsistence, seem to have been the typical pattern (Stoltman 1997). At least one extensive

Archaic local Wisconsin quarry site is known; however, stone tool materials from neighboring

Illinois are also found at Archaic sites (Stoltman 1997). By about 4000 to 6000 B.C., Archaic

sites were more widely distributed throughout Wisconsin. Drier, warmer conditions with a rise

in herbaceous species characterize this period. Archaic tool assemblages expand to include

fishing gear, ground stone plant processing tools, axes, and copper tools (Stoltman 1997).

Copper artifacts (such as harpoons, axes, adzes, chisels, knives, and drills) are widely found in

eastern Wisconsin and in Manitowoc County (Stoltman 1997). Beginning about 2500 years

ago, the Woodland Tradition replaced the Archaic Tradition across most of Wisconsin

(Stoltman 1997).

The Red Ochre Complex, an elaborate ceremonial burial complex distributed widely across the

Midwest and the Great Lakes areas, serves as a marker of the transition between the

preceding Archaic Tradition and the subsequent Woodland Tradition. Because information

about the complex is largely limited to burial sites, its connections to the Archaic and Woodland

NUREG-1437, Supplement 23 2-48 August 2005
Plant and the Environment

Traditions remains uncertain (Stevenson et al. 1997). Use of copper for ornaments increased;

evidence of fishing and wild rice harvesting exists. Toward the end of the Red Ochre period,

mounds and Woodland pottery are found in association with the sites (Stevenson et al. 1997).

By about 2500 years ago, the presence of pottery marks the beginning of early Woodland

Tradition in Wisconsin. Typically, the Woodland Tradition is characterized by a transition from

subsistence based on hunting and gathering to one based more heavily on horticulture.- Use of

bows and arrows and pottery and construction of effigy mounds, many of which were in the

form of animals and humans, are hallmarks of the Woodland Tradition. As the Woodland

Tradition developed, cultivation became more prominent in the economy, and increasingly!

settled village sites became more common (Stevenson et al. 1997).- -

The middle Woodland occupation (roughly 1500 to 2200 years ago) has distinctive

characteristics that include construction of conical burial mounds and evidence of widespread-'

interaction throughout central and eastern North America. The characteristics of this network,

called the Hopewell Interaction Sphere, include elaborate ceremonialism, extensive trade of

exotic manufactured items and raw -materials, and large mound construction'. The Hope-well

influence in Wisconsin appears to consist of a veneer of ceremonialism on a traditional way of

life that was otherwise largely unchanged (Stevenson et al. 1997).

Late Woodland sites (occupied 700 to 1600 years ago) show a decline in Hopewellian

ceremonialism but continue the tradition of mound construction, primarily in form of animal and

human shapes, in the southern half of Wisconsin. Burials are associated with some, but not all,

mounds (Stevenson et al. 1997). Cultivation of corn became increasingly prominent, and

villages became more permanent (Stevenson et al: 1997).

An exception to the typical Woodland Tradition is the intrusion of a few Middle Mississippian

sites in Wisconsin about 1000 years ago. These sites are related to the development of

planned permanent towns and ceremonial sites in Iowa, Minnesota, Missouri, and Illinois,

particularly the site of Cahokia. Hierarchical structure, extensive trade networks, and intensive

agriculture characterized these societies. 'Several sites in south-central Wisconsin represent a

northern extension of Mississippian culture. Aztalan, a palisaded village containing four

platform mounds and a series of dwellings, is the best known of these sites in Wisconsin

(Goldstein and Freeman 1997). The relationship of such sites'with the surrounding Woodland

Tradition is unclear, and the influence of the Mississippian culture on Woodland culture in

Wisconsin appears to have been transitory (Green 1997).

The transition from Woodland Tradition to later cultures is poorly understood. About

1000 years ago, overlapping the late Woodland and Mississippian traditions, sites referred to as

the Oneota culture, recognized by distinctive pottery styles, appear in the archaeological record.

Permanent villages, some fortified; were established; subsistence was based on corn, beans, '

August 2005 2-49 NUREG-1437, Supplement 23
_ I LL

Plant and the Environment

squash, aquatic resources, and a variety of wild plants and game. Hunting and gathering,

probably on a seasonal basis, supplemented the basic agricultural economy (Overstreet 1997).

Differences between Oneota and existing Woodland cultures may have been one of degree,

rather than kind. The origin of Oneota groups is a subject of debate. They may have migrated

into Wisconsin from the south or developed out of an interaction of late Woodland Tradition with

Mississippian culture at such sites as Aztalan (Overstreet 1997). Late Woodland and Oneota

communities may have coexisted in several areas of Wisconsin for a period of time. Expanding

Mississippian culture in Wisconsin may have forced Oneota populations out of areas of eastern

Wisconsin. Following the collapse of Mississippian influence, Oneota communities returned to

the abandoned areas, and by about 700 years ago, they were the predominant culture in most

of southern Wisconsin (Overstreet 1997).

During the later period of Oneota culture, villages were concentrated in several areas, such as

the Fox River valley in eastern Wisconsin. Subsistence patterns appear to have remained

relatively constant throughout Oneota history until the onset of European contact (circa 1600 to

1650). Oneota settlements in eastern Wisconsin were abandoned by the time of French

contact. The causes for this rapid depopulation may include disease, warfare, or out-migration

(Overstreet 1997). The Ho-Chunk (formerly Winnebago) Indians are commonly believed to be

descendants of Oneota populations, but the archaeological evidence is weak.

At the time of the first European contact (1600 to 1650), eastern Wisconsin was occupied by

several Native American groups (Ho-Chunk, Potawatomi, Menominee, and Chippewa).

Disruption of Native American communities in eastern North America by ecological shifts

(Cronon 1983), societal collapse, disease, and dislocation by European settlers created waves

of population shifts as these tribal groups pushed north and westward (Bragdon 2001).

Wisconsin tribal groups, responding to these pressures, shifted their areas of use around

Wisconsin, Michigan, and other areas of the Midwest.

- Historic Period

During the first half of the 17th century, Iroquoian Huron Indians controlled trade across the

northern Great Lakes and restricted French incursions into the western Great Lakes area.

Between 1648 and 1650, other Iroquoian groups, under pressure because of declining reserves

of fur bearing animals, attacked the Huron villages causing a mass exodus of Hurons to the

north and west. Huron camps between the Door Peninsula and southern Lake Michigan are

evidence of this migration. With the collapse of the Huron control of Great Lakes trade,

northern Wisconsin was opened to European intrusion, Iroquois raids, and large-scale

migrations of refugees.

"Some places were literally emptied of people, and areas receiving them experienced crowding,

confusion, and disruption of old ways. Villages were established with mixed populations as

NUREG-1437, Supplement 23 2-50 August 2005

I l
Plant and the Environment

older patterns of interrelationship were abandoned....The wars of the Iroquois additionally drove

many refugees into Wisconsin from the southern end of Lake Michigan, and people whose

former homes were as far east as Ohio'sought refuge here, most before any reliable historic

records were kept of their movements" (C. Mason 1997).

The first European'known to have visited the area was Jean Nicolet, a French explorer, who

reached Green Bay in 1634. Green Bay was subsequently established as the first French fur

trading settlement, and a number of other trading posts were established during the late 1600s

and 1700s. Between 1665 and 1728, French Jesuits established missions in conjunction with

the trading posts and in various parts of the Green Bay/Fox River area (C. Mason 1997).

French influence continued until the end of the French and Indian War. As the French withdrew -

from the western Great Lakes, items of British manufacture replaced French trade goods in

Native American communities (C. Mason 1997). Throughout the historic period, Wisconsin

Native American societal structures and ecological conditions were disrupted. Native

economies were supplanted or supplemented by an emphasis on hunting for the fur trade.

European trade goods increasingly replaced traditional tools and utensils.

The United States acquired ownership of the northern Midwest at the close of the American

Revolution, but de facto control remained with the British until the War of 1812. By 1825, the

United States had confirmed the rights of three Native American groups (Menominee,

Potawatomi, and Ho-Chunk) to land in eastern Michigan (Wisconsin Historical Society [WHS]

2000). However, as a result of later treaties that ceded land to the United States, some tribal

groups with ancestral interests in Wisconsin were forced to move to Iowa, Michigan, Kansas,

and Oklahoma or were resettled in much smaller reservations (Great Lakes Inter-Tribal Council

2003). During the 1820s and 1830s, the Oneida and Mohican Indians of New York negotiated

various treaties with Menominee and Ho:Chunk tribes and with the Federal government for land

on the western shore of Lake Michigan. Groups of Oneida and Mohicans began to relocate to -

that area and were eventually settled on small reservations south of Green Bay. -

Wisconsin was sparsely settled by Europeans prior to becoming a U.S. territory. Lead mining

drew the first wave of Euro-American immigrants to southwestern Wisconsin in the 1820s. In

1834,-Wisconsin was surveyed and opened to Euro-American settlers. The fur trade, which '

had been a lucrative enterprise from the time of French influence, declined rapidly in the 1830s,

and by the time of the Civil War, logging, especially in the heavily forested northern areas, had

become the primary industry. Initially, loggers floated white pine logs down the rivers to sawmill

towns. As the supply of pines was exhausted, railroads were constructed to haul the next most;

desirable species (maple and other hardwoods that would sink when waterlogged) to the mills

(Birmingham et al. 1997). Wood product industries developed to exploit Wisconsin's forests. In

eastern Wisconsin, a substantial tanning industry developed based on the availability of

"tanbark" derived from large stands of hemlock that grew in that area. A number of tanneries

were located in the area of Two Rivers. The Village of Two Creeks, located directly north of

August 2005 2-51 NUREG-1437, Supplement 23
Plant and the Environment

PBNP, was founded by Guido Pfister who established the Pfister (later Pfister and Vogel)

Leather Company there in 1861 (Wojta 1945). Pfister acquired rights to about 607 ha

(1500 ac) of hemlock forest along the shores of Lake Michigan between Two Creeks and the

current location of PBNP. The Two Creeks tanning industry flourished for about 20 years, but

was finally abandoned and moved to Milwaukee in 1882 (Spevacek 1985). The primary factor

in the decline of the tanning industry was the massive loss of local hemlock and tanbark as a

result of the Peshtigo fires of 1871 (Vogl 1986).

The Village of Two Creeks (variously named Rowley, Nero, or East Two Creeks) was the

largest community in the immediate vicinity of PBNP from 1861 to 1920. Initially established for

the Pfister Leather Company, the town developed a substantial shipping industry. Tanned

hides and leather goods, farm products, and wood products were shipped from Two Creeks to

other Great Lakes ports (Spevacek 1985). This commercial activity persisted after the closure

of the Pfister and Vogel Leather Company. In 1918, under severe drought conditions, a fire

destroyed nine buildings in the village. As a result of the extensive destruction, East Two

Creeks was abandoned, and what remained of the community relocated west of the original

lakeshore location.

Although the tanning industry was short lived, eastern Wisconsin developed an extensive

fishing and shipbuilding industry, with a major center in the City of Manitowoc during the 1800s

and 1900s. Dairy farming also became a significant enterprise. Logging continued to be a

significant industry through the 1920s. Drawn by its natural resources and economic

opportunities, immigrants from many areas of Europe (Scandinavia, northern and eastern

Europe, and the British Isles) and the eastern United States settled in Wisconsin. The rich

ethnic diversity of its people is reflected in the architecture and industries of its farms

(WHS 1996), churches, and villages. Between 1836 and 1850 (2 years after statehood), the

population of Wisconsin increased from less than 12,000 people to 305,000 (State of

Wisconsin 2004b).

* Native American Tribes

There are 11 Federally recognized Native American tribes resident in Wisconsin. There are six

groups of Chippewa (Bad River Band of the Lake Superior Chippewa, Lac Courte Oreilles Band

of Lake Superior Chippewa Indians, Lac du Flambeau Band of Lake Superior Chippewa

Indians, St. Croix Chippewa Indians, Sakaogon Chippewa Community, and the Red Cliff Band

of Lake Superior Chippewa Indians); the Ho-Chunk (formerly Winnebago) Nation; the Forest

County Potawatomi Community; the Oneida Tribe of Indians; the Menominee Indian Tribe; and

the Stockbridge Munsee Community (formerly Stockbridge Munsee Community of Mohican

Indians) (Bureau of Indian Affairs 2002). In addition to Native American groups resident in

NUREG-1437, Supplement 23 2-52 August 2005
Plant and the Environment

Wisconsin, three other groups of Potawatomi (Hannahville Indian Community, Michigan; Citizen

Potawatomi Nation, Oklahoma; Prairie Band of Potawatomi Nation, Kansas) have cultural

interests in Manitowoc and Kewaunee counties (National Park Service 2004).

2.2.9.2 Historic and Archaeological Resources at PBNP Site

During the development of the final environmental statement (FES) (AEC 1972), archaeological

site file searches were conducted at the WHS to -identify cultural resources that might be

present at PBNP. The FES reported that an "Indian burial site" was located north of the plant

but was not disturbed by construction. A number of farm buildings of unknown history were

reported to have been razed.

In 1993, the Great Lakes Archaeological Research Center, Inc. (GLARC) conducted a field

inventory of approximately 16 ha (40 ac) that was proposed for use as 'an ISFSI facility. They:

also examined the sites files, archives, and maps maintained by the WHS. No prehistoric or

historic sites were located during the field inventory. GLARC also noted three prehistoric

campsites and one historic Euro-American site within 3.2 km (2 mi) of the project area

(GLARC 1993).

In the course of preparing this SEIS, the WHS records of historic properties were examined.

As of August 2004, a number of historic properties within Manitowoc and Kewaunee counties

have been listed on the National Register of Historic Places (NRHP), 10 in Kewaunee County'

(WHS 2004a) and 19 in Manitowoc County (WHS 2004b). The nearest, the Rawley Point Light

Station, falls within a 10-km (6-mi) radius of PBNP. In addition to sites listed on the NRHP, the

WHS records list more than 170 additional historic buildings in Manitowoc County that are of

historical interest. None of these are in the immediate vicinity of PBNP. '

Local histories indicate that the first houses built in Two Creeks township were located within

the PBNP site boundaries. The first house was built in 1842, and the second in 1847

(Wojta 1945). County plat maps of Two Creeks township show the presence of structures and

a north-south road within the PBNP site boundaries as early as 1872 to 1878. -A pier at the

northern boundary of the PBNP site is also shown on County maps from the 1870s -

(Snyder et al. 1878). A standing fisherman's shed built about 1948 is also located within the

PBNP site boundaries. The fishing shed was evaluated for significance under the National

Historic Preservation Act (16 USC 470 et seq.) (We Energies 2004c). -On October 21,2004,

the WHS issued a determination that the fishing shed is not eligible for inclusion on the NRHP

(WHS 2004c).

Records at the WHS identify a number of prehistoric and historic sites in the vicinity of the

PBNP site and three sites located within the PBNP site boundary. A cultural resources field

investigation of the leased farmlands within the PBNP site has recently been completed

August 2005 2-53 ' NUREG-1437, Supplement 23
___ LL

Plant and the Environment

(AVD Archaeological Services, Inc. [AVD] 2004). In addition to the sites identified in the WHS

records, this investigation found prehistoric and historic artifacts at 19 locations: 15 isolated

artifacts, one prehistoric lithic artifact scatter, and three historic artifact scatters. One of the

historic scatters is associated with a nearby residence. Another historic scatter is probably

associated with a nearby foundation and possible grave site, and the third historic scatter is

also associated with a foundation. AVD recommended that the four artifact scatters be avoided

during any future land disturbance (AVD 2004). Alternatively, additional evaluations could be

conducted to determine if these sites were eligible for the NRHP. Unless construction is

planned at the isolated artifact locations, no further investigation was recommended

(AVD 2004).

In addition to the known sites within the PBNP site boundaries, the surrounding areas (within

approximately 10 km [6 mi] of the plant site) are known to contain 25 archaeological sites. The

majority of these are prehistoric campsites and villages, most of them of unknown cultural

affiliation. Other campsites and villages in this area have been attributed to the Woodland

Tradition. Other sites within this area include one prehistoric Native American and two

Euro-American cemeteries, a shipwreck (the Pathfinder), and a French trading post/landing site

dating to the 1700s. The landing site, reported to be that of Jean (variously Jacques) Vieau is

located north of the plant site. The historic village of Two Creeks, although not listed in the

WHS site records, also lies due north of the PBNP site.

In addition to cultural resources, a portion of the Two Creeks Buried Forest unit of the Ice Age

National Scientific Reserve, a paleontological resource, is exposed near the plant site. Its

extent within and beneath the plant site has not been documented. The buried forest contains

preserved remains of a periglacial forest that was buried by the last glacial advance over

Wisconsin. Cultural resources are not likely to be associated with the buried forest unit.

2.2.10 Related Federal Project Activities and Consultations

The staff reviewed the possibility that activities of other Federal agencies might impact the

renewal of the PBNP OLs. Any such activities could result in cumulative environmental impacts

and the possible need for the Federal agency to become a cooperating agency for preparation

of the SEIS.

As discussed in the NMC ER (NMC 2004a), KNPP is located on the western shore of Lake

Michigan in Kewaunee County, approximately 8 km (5 mi) north of the PBNP site. KNPP is a

single unit, 535-MW(e) pressurized-water reactor with a thermal power rating of 1650 MW. The

KNPP site consists of approximately 367 ha (908 ac), jointly owned by Wisconsin Public

Service Corporation and Alliant Energy. Under an arrangement similar to that of PBNP, NMC

NUREG-1 437, Supplement 23 2-54 August 2005

I I
Plant and the Environment

holds the OL for KNPP and is responsible for plant operation and maintenance. At KNPP, a

maximum of 1.6 million Uimin (4.2 x 1 O0 gpm) of cooling water and up to 95,000 Urmin

(25,000 gpm) of water for in-plant use are drawn from and discharged to Lake Michigan as a

once-through system. Groundwater from an onsite well is used for potable and sanitary water.

Studies conducted of the hydrologic characteristics of this portion of Lake Michigan indicate that

the discharge heat of KNPP does not interact with the discharge heat of PBNP (Wisconsin

Public Service Corporation 1972).

NMC conducts a radiological environmental monitoring program on and in the vicinity of KNPP.

A total of 17 parameters are measured, including four air samples (e.g., airborne particulates),

nine terrestrial samples (e.g., well water), and four aquatic samples (e.g., fish). Radionuclide

concentrations from the surveillance program are compared to levels measured at control

locations and in preoperational studies. These comparisons indicated only~background level

radioactivity in all samples collected in the year 2000.

PBNP has a 20-MW(e), oil-fired combustion turbine used for spinning reserve, alternate power

supply during plant blackouts, and peaking purposes. The combustion turbine is fully capable -

of operating independent of the remainder of the plant. PBNP operates the combustion turbine

pursuant to Chapter 285 of the Wisconsin Statutes and the plant's air pollution control operation

permit issued under the CM by the WDNR.

The NRC is required under Section 102(c) of the National Environmental Policy Act of 1969 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. The NRC consulted with

the FWS; the consultation is described in Section 4.6, and correspondence, including the

Biological Assessment, is included in Appendix E..

2.3 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing

of Production and Utilization Facilities."

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

Renewal of Operating Licenses for Nuclear Power Plants."

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."

August 2005 2-55 NUREG-1437, Supplement 23
Plant and the Environment

15 CFR Part 930. Code of Federal Regulations, Title 15, "Federal Consistency with Approved

Coastal Management Programs."

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of the 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."

American Transmission Company (ATC). 2004a. Transmission Line Right-of-Way Forestry

Specification. ATC Operating Instruction. May 1, 2004.

American Transmission Company (ATC). 2004b. Vegetation Management Philosophy and

Standards. ATC Operating Instruction No. 02-04. May 1, 2004.

AVD Archaeological Services Inc. (AVD). 2004. A Phase I Archaeological Sunrey at the Point

Beach Nuclear Power Plant in Manitowoc County, Wisconsin. Report No. 104284. Union

Grove, Wisconsin. September 2004.

Birmingham, R. A., J. H. Broihahn, and D. J. Cooper. 1997. "Historic Period, Euro-Americans."

The Wisconsin Archaeologist, Vol. 78, Numbers 1 and 2, pp. 320-349.

Bragdon, K. J. 2001. The Columbia Guide to American Indians of the Northeast. Columbia

University Press, New York.

Bronte, C.R., and P.A. Schuette. 2002. Summary of Trout and Salmon Stocking in Lake

Michigan 1976-2001. Great Lakes Fishery Commission, Lake Michigan Committee Meeting,

Duluth, Minnesota. March 21-22, 2002.

Bronte, C.R., J. Jonas, M.E. Holey, R.L. Eshenroder, M.L. Toneys, P. McKee, B. Breidert, R.M.

Claramunt, M.P. Ebener, C.C. Krueger, G. Wright, and R. Hess. 2003. Possible Impediments

to Lake Trout Restoration in Lake Michigan. Great Lakes Fishery Commission, Ann Arbor,

Michigan. http://www.glfc.org/lakecom/lmc/ltrestore.pdf (Accessed January 12, 2004).

Burzynski, T. 2004. Wisconsin's Lake Michigan Salmonid Stocking Program. PUB-FH-828

2004. Wisconsin Department of Natural Resources, Milwaukee, Wisconsin.

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Stocking%2Osummary%202003.pdf

(Accessed November 12, 2004).

NUREG-1437, Supplement 23 2-56 August 2005
Plant and the Environment

Bureau of Indian Affairs. 2002. Indian Entities Recognized and Eligible To Receive Services

From the United States Bureau of Indian Affairs." Federal Register, Vol. 67, No. 134,

pp. 46328-46333. Washington, D.C. July 12,2002. -

Clean Air Act of 1970 (CM). 42 USC 7401 et seq.

Clean Water Act of 1977 (CWA). 33 USC 1326 et seq. (common name of the Federal Water

Pollution Control Act of 1977). --

Coastal Zone Management Act of 1972 (CZMA). 16 USC 1451 et seq.

Crawford, S.S. 2001. Salmonine Introductions to the Laurentian Great Lakes: An Historical

Review and Evaluation of Ecological Effects. Executive Summary. Canadian Special

Publication of Fisheries and Aquatic Sciences.

http://www.uoguelph .cal-scrawfor/research/research-greatlakes/researchgreatlakes_fisheries

/research-greatlakes-fisheriesissues_/researchgreatlakesfisheries*_issueas_salmon_mono

graph.shtml (Accessed February 24, 2004) (ADAMS Accession Number ML041960305).

Cronon, W. 1983. Changes in the Land: Indians, Colonists, and the Ecology of New England.

Hill and Wang, New York.

Department of Fisheries and Oceans Canada (DFO). 2004. "The Alewife." Department of

Fisheries and Oceans Canada, Ottawa, Ontario, Canada.

http://www.dfo-mpo-gc.ca/zone/underwater sous-marin/gasparea/alewife-gaspareau-e.htm

(Accessed July 14, 2004).

Eggold, B. 2004. Sportfishing Effort and Harvest. Lake Michigan Management Reports.

Wisconsin Department of Natural Resources, Milwaukee, Wisconsin.

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Great%20Lakes%Fishery%20Commissio

n%2OReport%/202004.pdf (Accessed November 11, 2004).

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.

Environment Canada. 1995. The Great Lakes: An Environmental Atlas and Resource Book

(Third Edition). Factsheet 1. Jointly produced by the Government of Canada and the U.S.

Environmental Protection Department. http://www.on.ec.gc.calgreat-lakes-atlas.html (Accessed

December 4, 2003) (ADAMS Accession Number ML041970161).

August 2005 2-57 NUREG-1437, Supplement 23
- __ I - ELL

Plant and the Environment

Eshenroder, R.L., M.E. Holey, T.K. Gorenflo, and R.D. Clark, Jr. 1995. "Fish-Community

Objectives for Lake Michigan." Great Lakes Fishery Commission Spec. Pub 95-3.

http://www.glfc.org/pubs/SpecialPubs/Sp95-3.pdf (Accessed January 25, 2004).

Fleischer, G.W., T.J. DeSorcie, and J.D. Holuszko. 2001. "Lake-wide Distribution of Dreissena

in Lake Michigan, 1999." Journal of Great Lakes Research, Vol 72, pp. 252-257.

Fuller, P. 2003. Morone americana (Gmelin 1789). U.S. Geological Survey (USGS), Center

for Aquatic Resource Studies, Gainesville, Florida.

http:llnas.er.usgs.gov/queries/SpFactSheet.asp?specieslD=777 (Accessed February 25, 2004).

Fuller, P., and A. Benson. 2003. Neogobius melanostomus (Pallas 1814). U.S. Geological

Survey (USGS), Center for Aquatic Resource Studies, Gainesville, Florida.

http://nas.er.usgs.gov/queries/SpFactSheet.asp?specieslD=713 (Accessed February 23, 2004).

Fuller, K., H. Shear, and J. Witting, eds. 1995. The Great Lakes - An Environmental Atlas and

Resource Book. Government of Canada and U.S. Environmental Protection Agency.

http://www.epa.gov/glnpo/atlas/index.html (Accessed February 25, 2004).

Fuller, P., L. Nico, and E. Maynard. 2004. Petromyzon marinus. Nonindigenous Aquatic

Species Database, Gainesville, Florida.

http://nas.er.usgs.gov/queries/SpFactSheet.asp?specieslD=836 (Accessed November 23,

2004).

GeoSyntec Consultants. 2002. "Abandonment Plan: Wastewater Retention Pond, Point

Beach Nuclear Plant." Prepared by GeoSyntec Consultants for Wisconsin Electric-Wisconsin

Corporation. Chicago, Illinois. February 2002.

Goldstein, L., and J. Freeman. 1997. "Aztalan - A Middle Mississippian Village." The

Wisconsin Archaeologist, Vol. 78, Numbers 1 and 2, pp. 223-248.

Great Lakes Archaeological Research Center (GLARC). 1993. Phase I Archaeological

Reconnaissance of a Proposed Storage Site at the Point Beach Power Plant, Manitowoc

County, Wisconsin. GLARC Project 93-069, Milwaukee, Wisconsin. August 1993.

Great Lakes Inter-Tribal Council. 2003. Native Wisconsin, Official Guide to Native American

Communities in Wisconsin. Great Lakes Inter-Tribal Council, Inc. Lac du Flambeau,

Wisconsin.

NUREG-1437, Supplement 23 2-58 August 2005

I I
Plant and the Environment

Great Lakes Science Center. 2003. Great Lakes Issues - Round Goby.: U.S. Geological

Survey (USGS), Great Lakes Science Center, Ann'Arbor, Michigan.

http://www.glsc.usgs.gov/research/greatlakesissues.asp?lD=-3 (Accessed February 24, 2004).

Green, W. 1997. "The Middle Mississippian Peoples." Wisconsin Archaeology, Chapter 8.

The Wisconsin Archaeological Society, The Wisconsin Archaeologist, Vol.78, Numbers

1 and 2, pp. 202-222. -

Hasz, J. 2004. Yellow Perch - Southern Green Bay. Lake Michigan Management Reports.

Wisconsin Department of Natural Resources, 'Peshtigo, Wisconsin. - - -

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Great%20Lakes%Fishery0 /o2OCommissio

n%2OReport%202004.pdf (Accessed November 11, 2004).

Hirenth6ta, P. 2004. Yellow Perch - Lake Michigan. Lake Michigan Management Reports.

Wisconsin Department of Natural Resources, Milwaukee, Wisconsin. -

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Great%2OLakes%Fishery%2OCommissio

n%2OReport%202004.pdf (Accessed November 11 2004). -

Hogler, S., and S. Surendonk. 2004. Smelt Withdrawal By the Commercial Trawl Fishery.'

Lake Michigan Management Reports. Wisconsin Department of Natural Resources, Mishicot,

Wisconsin. I

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Great%2OLakes%Fishery%20Commissio

n%20Report%202004.pdf (Accessed November 11, 2004).

Horvath, T.G., K.M. Martin, and G.A. Lambbdrti. '1999. "Effect of Zebra Mussels, Dreissena

polymorpha, on Macroinvertebrates in a Lake-outlet Stream." American Midland Naturalist,

Vol. 142, pp. 340-347. '

Illinois State Museum. 2004. The Retreat of Glaciers in'the Midwestem U.S. -

http://www.museum.state.il.us/exhibits/larson/glacier maps.html (Accessed August 3, 2004).

Jude, D.J. 1995. Impact on Aquatic Organisms of Increased Heat Input to the Thermal

Discharge of the Donald C. Cook Nuclear Plant, Southeastem Michigan. Center for Great -

Lakes and Aquatic Sciences, University of Michigan, Ann Arbor, Michigan. December 1995.

Kroeff, T.' 2004. Status of the Commercial Chub Fishery and Chub Stocks. Lake Michigan.

Management Reports. Wisconsin Department of Natural Resources, Sturgeon Bay, Wisconsin.

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Great%2OLakes%Fishery%/2OCommissio

n%2OReport%202004.pdf (Accessed November 11, 2004).

August 2005 2-59 NUREG-1 437, Supplement 23
- L LL

Plant and the Environment

Lee, D.M. 1991. Letter from D.M. Lee, Water Quality Engineer, Wisconsin Electric Power

Company, Milwaukee, Wisconsin to B. E. Barbieur, Wisconsin Department of Natural

Resources, Madison, Wisconsin. Subject: 'WPDES Permit No. WI-0000957 Point Beach

Nuclear Plant Zebra Mussel Control." December 3, 1991.

Lei, J. 1993. Estimation of Filtration Rate of Zebra Mussels. Technical Note ZMR-4-06. U.S.

Army Engineer Waterways Experiment Station, Vicksburg, Mississippi.

http://sgnis.org/publicat/papers/zmr..406.pdf (Accessed November 23, 2004).

Lehman, J.T. 1991. "Causes and Consequences of Cladoceran Dynamics in Lake Michigan:

Implications of Species Invasion by Bythotrephes." J. Great Lakes Res., Vol. 17, pp. 437-445.

Liebig, J., and A. Benson. 2004. Bythotrephes longimanus. Nonindigenous Aquatic Species

Database, Gainesville, Florida. http:llnas.er.usgs.gov/queries/SpFactSheet.asp?specieslD=1 62

(Accessed November 23, 2004).

Madenjian, C.P., G.L. Fahnenstiel, T.H. Johengen, T.F. Nalepa, H.A. Vanderploeg, G.W.

Fleischer, P.J. Schneeberger, D.M. Benjamin, E.B. Smith, J.R. Bence, E.S. Rutherford, D.S.

Lavis, D.M. Robertson, D.J. Jude, and M.P. Ebener. 2002. "Dynamics of the Lake Michigan

Food Web, 1970-2000." Canadian Journal of Fisheries and Aquatic Sciences, Vol. 59,

pp. 736-753.

Madenjian, C.P., T.J. Desorcie, and J.D. Holuszko. 2004. Status and Trends of Prey

Populations in Lake Michigan, 2003. Great Lakes Fishery Commission, Lake Michigan

Committee Meeting, Ypsilanti, Michigan. March 24, 2004.

Makarewicz, J.C., T. Lewis, and P. Bertram. 1994. Epilimnetic Phytoplankton andZooplankton

Biomass and Species Composition in Lake Michigan, 1983 to 1992. U.S. Environmental

Protection Agency, Great Lakes National Program, Chicago, Illinois.

http://www.epa.gov/glnpo/monitoring/plankton/mich83-92/index.html

(Accessed November 23, 2004).

Manitowoc County Planning and Park Commission (MCPPC). 1981. Manitowoc County

Farmland Preservation Plan. Manitowoc, Wisconsin.

Manitowoc County Planning and Park Commission (MCPPC). 2004. Town of Two Creeks

2022 Comprehensive Land Use Plan, Draft. Manitowoc, Wisconsin.

NUREG-1437, Supplement 23 2-60 August 2005
I

Plant and the Environment

Manz, C.H. 1998. 'The Round Goby: An Example of the 'Perfect' Invader?" Illinois Natural

History Survey Reports, Nov-Dec 1998.

http://www.inhs.uiuc.edu/chf/pub/surveyreports/nov-dec98/goby.html

(Accessed February 24, 2004).

Marsden, J.E., and M.A. Chotkowski. 1995. 'The Round Goby Invades Lake Michigan."

Illinois Natural History Survey Reports, Nov-Dec 1995.

http://www.inhs.uiuc.edu/chf/pubs/surveyreports/nov-dec95/gobies.html

(Accessed February 24,2004).

Mason, C. l. 1997. "The Historic Period in Wisconsin Archaeology, Native Peoples." The

Wisconsin Archaeologist, Vol. 78, Numbers 1 and 2, pp. 293-319.

Mason, R. J. 1997. "The Paleo-lndian Tradition." The Wisconsin Archaeologist, Vol. 78,

Numbers 1 and 2, pp. 78-i 10.

Michigan Department of Natural Resources (MDNR). 2004. Overview of Michigan's Fish

Hatchery System. Michigan Department of Natural Resources,Ann Arbor, Michigan.,

http://www.michigan.gov/dnr/0,1607,7-153-10364_28277--,00.html

(Accessed February 26,2004).

Midwestern Regional Climate Center (MRCC). 2003. Historical Climate Data, Precipitation

Summary. http://www.aos.wisc.edu/%7Esco/stations/475017.html

(Accessed August 25,2004).

Nalepa, T. F., D. J. Hartson, D. C. Fanslow, G. A. Lang, and S. J. Lozano. 1998. ."Declines in

Benthic Macroinvertebrate Populations in Southern Lake Michigan, 1980-1993." Canadian

Journal of Fisheries and Aquatic Sciences, Vol. 55, pp. 2402-2413.

Nalepa, T. F., D. W. Schloesser, S. A. Pothoven, D. W. Hondorp, D. L. Fanslow,

M. L. Tuchman, and G. W. Fleischer. 2001. "First Finding of the Amphipod Echinogammarus

ischnus and the Mussel Dreissena bugensis in Lake Michigan." Journal of Great Lakes

Research, Vol. 27, pp. 384-391.-

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

National Historic Preservation Act of 1966 (NHPA). 16 USC 470 et seq.

National Park Service. 2004. Native American Consultation Database. Query for Manitowoc

County, WI. Updated 5/11/2004. http://www.cast.uark.edu/other/nps/nacd/

(Accessed August 4, 2004).

August 2005 2-61 NUREG-1437, Supplement 23
- _ LLL

Plant and the Environment

NatureServe. 2004. NatureServe Explorer: An Online Encyclopedia of Life (Web Application).

Version 3.1. NatureServe, Arlington, Virginia.

http://www.natureserve.org/explorer (Accessed April 27, 2004).

Nuclear Management Company, LLC (NMC). 2000. Point Beach Nuclear Plant Annual

Monitoring Report 1999. Two Rivers, Wisconsin. April 2000.

Nuclear Management Company, LLC (NMC). 2001. Point Beach Nuclear Plant Annual

Monitoring Report 2000. Two Rivers, Wisconsin. April 2001.

Nuclear Management Company, LLC (NMC). 2002. Point Beach Nuclear Plant Annual

Monitoring Report 2001. Two Rivers, Wisconsin. April 2002.

Nuclear Management Company, LLC (NMC). 2003a. Point Beach Nuclear Plant Units 1 & 2

Final Safety Analysis Report (FSAR). Two Rivers, Wisconsin. June 2003.

Nuclear Management Company, LLC (NMC). 2003b. Point Beach Nuclear Plant Offsite Dose

Calculation Manual, Revision 15. Two Rivers, Wisconsin. June 30, 2003.

Nuclear Management Company, LLC (NMC). 2004a. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

February 26, 2004.

Nuclear Management Company, LLC (NMC). 2004b. Application for Renewed Operating

Licenses, Point Beach Nuclear Plant Units 1 and 2. Two Rivers, Wisconsin.

February 26, 2004.

Nuclear Management Company, LLC (NMC). 2004c. Point Beach Nuclear Plant Annual

Monitoring Report 2003. Two Rivers, Wisconsin, April 2004.

Nuclear Management Company, LLC (NMC). 2004d. Letter from G. Van Middlesworth, Site

Vice President, to T. Olson, Wisconsin Department of Administration. Subject: "License

Renewal Application for Point Beach Nuclear Plant Federal Consistency Certification for

Federal Permit and License Applicants." March 2, 2004.

Overstreet, D. F. 1997. "Oneota Prehistory and History." The Wisconsin Archaeologist,

Vol. 78, Numbers 1 and 2, pp. 250-296.

Peeters, P. 1998. "Into Lake Michigan's Waters. Exotic Fish Took Hold by Many Routes."

Wisconsin Natural Resources Magazine, June/July, 1998.

NUREG-1437, Supplement 23 2-62 August 2005

I I
Plant and the Environment

Peeters, P. 2004. Status of the Lake Whitefish Population. Lake Michigan Management

Reports. Wisconsin Department of Natural Resources, Sturgeon Bay, Wisconsin.

httpJ/www.dnr.state.wi.us/org/water/fhp/fish/lakemich/Great%2OLakes%Fishery/o20Commissio

n%2OReport%202004.pdf (Accessed November 11, 2004) (ADAMS Accession Number

ML041960212). -

Ramsdell, J. V., and G. L. Andrews. 1986. Tomado Climatography of the Contiguous United

States. NUREG/CR-4461, Nuclear Regulatory Commission, Washington, D.C.

Ray, W.J., and L.D. Corkum. 1997. "Predation of Zebra Mussels by Round Gobies, Neogobius

melanostomus." Environmental Biology of Fishes, Vol. 50, pp. 267-273.

Resource Conservation and Recovery Act of 1976 (RCRA). 42 USC 6901 et seq.

Schloesser, D. W., T. F. Nalepa, and G. L. McKie. 1996. "Zebra Mussel Infestation of Unionid

Bivalves (Unionidae) in North America." American Zoologist 36, pp. 300-310. -

Snyder, Van Vechten & Co. 1878. Map of Manitowoc County. Historical Atlas of Wisconsin,

1878. Milwaukee, Wl. David Rumsey Map Collection. http://www.davidrumsey.com/

(Accessed August 6, 2004).

Spevacek, C. J. 1985. "The History of the Village of East Two Creeks." Manitowoc County

Historical Society, Occupational Monograph 55. Manitowoc, Wisconsin.

State of Wisconsin. 2003. Environmental Radioactivity Survey, Point Beach-Kewaunee, 2002.

Madison, Wisconsin.

State of Wisconsin. 2004a. Environmental Radioactivity Survey, Point Beach-Kewaunee,

2003. Madison, Wisconsin.

State of Wisconsin. 2004b. Highlights of History in Wisconsin. Blue Book 2003-2004:

684-730. Wisconsin State Legislature. http://www.legis.state.wi.us/lrb/bb/684-730.pdf

(Accessed August 4, 2004).

Stein, R.A., M.E. Gaden, and C.l. Goddard. 2003. Protecting and Restoring the Great Lakes

Fishery. Great Lakes Fishery Commission, Ann Arbor, Michigan.

http://www.senate.gov/!epw/1 08th/Stein_082503.pdf (Accessed December 18, 2003).

Stevenson, K. P., R. F. Boszhardt, C. R. Moffat, P. H. Salkin, T. C. Pleger, J. L. Theler, and

C. M. Arzigian. 1997. "The Woodland Tradition." The Wisconsin Archaeologist, Vol. 78,

Numbers 1 and 2, pp. 140-201.

August 2005 2-63 - NUREG-1437, Supplement 23
- - -LL

Plant and the Environment

Stewart, T. W., J. G. Miner, and R. L. Lowe. 1998a. "Quantifying Mechanisms for Zebra

Mussel Effects on Benthic Macroinvertebrates: Organic Matter Production and Shell-Generated

Habitat." Journal of the North American Benthological Society, Vol. 17, pp. 81-95.

Stewart, T.W., J.G. Miner, and R.L. Lowe. 1998b. "Macroinvertebrate Communities on Hard

Substrates in Western Lake Erie: Structuring Effects of Dreissena." Journal of Great Lakes

Research, Vol. 24, pp. 868-879.

Stoltman, J. B. 1997. "The Archaic Tradition." The Wisconsin Archaeologist, Vol. 78,

Numbers 1 and 2, pp. 112-139.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Point Beach Nuclear Plant Units 1 and 2. Docket Nos. 50-266 and 50-301.

Washington, D.C.

U.S. Census Bureau (USCB). 2000. Profile of Selected Economic Characteristics: 2000.

Census 2000 Summary File 4 (SF4), Table DP-3 for Manitowoc County, Wisconsin.

http://factfinder.census.gov/ (Accessed July 30, 2004).

U.S. Census Bureau (USCB). 2004. Wisconsin QuickFacts.

http://quickfacts.census.gov/qfd/states/55000.html (Accessed July 30, 2004).

U.S. Environmental Protection Agency (EPA). 2002. Lake Michigan Lakewide Management

Plan (LaMP) 2002. U.S. Environmental Protection Agency, Chicago, Illinois.

http://www.epa.gov/glnpo/lakemich/lmO2/index.html (Accessed February 25, 2004).

U.S. Environmental Protection Agency (EPA). 2004a. Letter from M. Leavitt, EPA

Administrator, to Wisconsin Governor J. Doyle designating areas of Wisconsin in nonattainment

of the 8-hour ozone standard. April 15, 2004.

http://www.epa.gov/region5/air/8hours/R5Wisconsin.pdf (Accessed November 24, 2004).

U.S. Environmental Protection Agency (EPA). 2004b. Fact Sheet: Clean Air Act Ozone Rules

of 2004. Final Rule Designating and Classifying Areas Not Meeting the National Ambient Air

Quality Standard For 8-Hour Ozone. http://www.epa.gov/ozonedesignations/finrulefs.htm

(Accessed November 24, 2004).

NUREG-1437, Supplement 23 2-64 August 2005

I I
Plant and the Environment

U.S. Environmental Protection Agency (EPA). 2005. Agreement Between Canada and the

United States of America on Great Lakes Ouality, 1978 (also called the Great Lakes Water

Quality Agreement). Signed by the Government of Canada and the Government of the United

States of America, Ottawa, Canada, November 22,1978. Accessed at

http://www.epa.gov/grtlakes/glwqa/1 978/articles.html#ARTICLE%201 (Accessed on June 16,

2005).

U.S. Fish and Wildlife Service (FWS). 2001. "Endangered and Threatened Wildlife and Plants;

Final Determination of Critical Habitat for the Great Lakes Breeding Population of the Piping

Plover." Federal Register, Vol. 60, No. 88, pp.22938-22969. Washington, D.C., May 7, 2001.

U.S. Fish and Wildlife Service (FWS). 2003. Recovery Plan for the Great Lakes Piping Plover

(Charadrius melodus). Region 3, Fort Snelling, Minnesota. September 2003.

U.S. Fish and Wildlife Service (FWS). 2004. Letter from J. Smith, Field Supervisor, Green Bay

Field Office, to A. J. Cayia, Site Vice President, Point Beach Nuclear Plant, Nuclear

Management Company. No Subject. February 26, 2004.

U.S. Geological Survey (USGS). 2002. Water Use in Wisconsin. Open file report 02-356.

httpi/wi.water.usgs.gov/pubs/publistO6O4.html (Accessed July 1, 2004).

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

forLicense Renewalof NuclearPlants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Note to File: Docketing of Material Sent in

Support of the Point Beach Nuclear Plant Units 1 and 2 Environmental Review and License

Renewal Application. Washington, D.C.

University of Wisconsin Sea Grant Institute (UWSGI).' 2001 a. Fish of Lake Michigan.

University of Wisconsin Sea Grant Institute, Madison, Wisconsin.

httpi/www.seagrant.wisc.edu/greatlakesfish/LakeMichFishlndex.html

(Accessed April 28, 2004). -

University of Wisconsin Sea Grant Institute (UWSGI). 2001 b. Alewife Watch 2001. University

of Wisconsin Sea Grant Institute, Madison, Wisconsin.

http://www.seagrant.wisc.edu/outreach/fisheries/Alewife/alewife.html (Accessed July 14, 2004).

University of Wisconsin Sea Grant Institute (UWSGI). 2002. Why Are the Alewives Dying?

University of Wisconsin Sea Grant Institute, Madison, Wisconsin.

http://www.seagrant.wisc.edu/greatlakesfish/alewifenews.html (Accessed July 14,2004).

August 2005 2-65 NUREG-1437, Supplement 23
I HI

Plant and the Environment

University of Wisconsin. 2004a. University of Wisconsin-Cooperative Extension Website for

Manitowoc County Agricultural Statistics. http://www.uwex.edulces/cty/manitowoclag/stats.htmI

(Accessed July 31, 2004).

| University of Wisconsin. 2004b. University of Wisconsin-Cooperative Extension, Kewaunee

| County Agriculture: Value and Economic Impact.

I http://www.uwex.edu/ces/cty/kewaunee/ag/documents/KewauneeCountyAglmpacts2004.pdf

| (Accessed July 22, 2005).

Vogl, W. 1986. "Forest Fires in Manitowoc County-1 871." Manitowoc County Historical

Society, Occupational Monograph 58. Manitowoc, Wisconsin.

We Energies. 2004a. WDNR Consolidated Reporting System 2003 Hazardous Waste Report

Certification. Milwaukee, Wisconsin. January 2004.

We Energies. 2004b. Letter from N. Cutright, Senior Terrestrial Ecologist, to G. Van

Middlesworth, Site Vice President, Nuclear Management Company. No Subject.

May 12, 2004.

We Energies 2004c. Letter from S. Schumacher, Environmental Specialist, to J. DeRose,

Wisconsin Historical Society. Subject: "Determination of Eligibility of the Biel Fishing Shed

Located on the Point Beach Nuclear Power Plant Property, Two Rivers, Manitowoc."

September 1, 2004.

We Energies. 2004d. Piping Plover Habitat on We Energies' Property Near the Point Beach

Nuclear Plant. Milwaukee, Wisconsin. October 13, 2004.

Wei, A., P. Chow-Fraser, and D. Albert. 2004. "Influence of Shoreline Features on Fish

Distribution in the Laurentian Great Lakes." Canadian Journal of Fisheries and Aquatic

Sciences, Vol. 61, pp. 1113-1123.

Whitman, Administrator of Environmental Protection Agency, et al. v. American Trucking

Associations, Inc., etal., D.C., 531 U.S. 457, (U.S. Supreme Court 2001).

Wisconsin Department of Administration (WDA). 2004a. Selected Housing Unit Information

For Wisconsin Counties And Municipalities: April 1, 1990 And April 1, 2000.

http://www.doa.state.wi.us/pagesubtext detail.asp?linksubcatid=379 (Accessed June 30, 2004).

Wisconsin Department of Administration (WDA). 2004b. Total Population Of Wisconsin

Counties And Municipalities: 1970-2000 Census Counts.

http://www.doa.state.wi.us/pagesubtextdetail.asp?linksubcatid=379 (Accessed June 30, 2004).

NUREG-1 437, Supplement 23 2-66 August 2005

, , II
Plant and the Environment

Wisconsin Department of Administration (WDA). 2004c. Wisconsin Population Projection

Tables: 2000-2030. http://www.doa.state.wi.us/pagesubtext detail.asp?linksubcatid=-105

(Accessed July 26, 2004).

Wisconsin Department of Administration (WDA). 2004d. Population Projections for Wisconsin

Counties by Age and Sex: 2000-2030.

http://www.doa.state.wi.us/pagesubtext detail.asp?linksubcatid=105 (Accessed July 26, 2004).-

Wisconsin Department of Administration (WDA). 2004e. Number of Males and Females by

Occupation for the Employed Civilian Population 16 Years and Over for Wisconsin Counties

and Municipalities: April 1, 2000.

http://www.doa.state.wi.us/pagesubtext detail.asp?linksubcatid=379 (Accessed June 4, 2004).

Wisconsin Department of Administration (WDA). 2005. Wisconsin Coastal Management

Program Federal Consistency Review Process.

http://www.doa.state.wi.us/dir/documents/federalconsistencyreviewprocess.pdf (Accessed -

June 1,2005). . I

Wisconsin Department of Natural Resources (WDNR). 2002. Letter from P. Luebke to

E. Hellman, Wisconsin Energy Corporation, regarding abandonment plan for settling pond.

Wisconsin Department of Natural Resources, Madison, Wisconsin. April 30, 2002. .1

Wisconsin Department of Natural Resources (WDNR). 2003a. Wisconsin's Comprehensive

Management Plan to Prevent Further Introductions and Control Existing Populations of Aquatic

Invasive Species. Wisconsin Department of Natural Resources, Madison, Wisconsin.

http://www.dnr.state.wi.us/org/water/w,/GLWSP/exotics/compstateansplanfinal1 0903.pdf

(Accessed November 11, 2004).

Wisconsin Department of Natural Resources (WDNR). 2003b. Lake Michigan Trout and

Salmon Frequently Asked Questions. Wisconsin Department of Natural Resources, Madison,

Wisconsin. http://www.dnr.state.wi.us/org/water/fhp/fish/faq/troutsalmon.htm

(Accessed November 12, 2004).

Wisconsin Department of Natural Resources (WDNR). 2003c. Monkeyface Quadrula

metanevra (Raf.). Wisconsin Department of Natural Resources, Madison, Wisconsin.

http://www.dnr.state.wi.us/org/land/er/invertebrates/mussels/monkeyface.htm

(Accessed November 24,2004).

Wisconsin Department of Natural Resources (WDNR). 2003d. The Wisconsin Lake Sturgeon

Management Plan. Wisconsin Department of Natural Resources, Madison, Wisconsin.

http://dnr.wi.gov/org/water/fhp/fish/sturgeon/lndex.htm (Accessed November 11, 2004).

August 2005 2-67 - NUREG-1437, Supplement 23
IINPlant and the Environment

Wisconsin Department of Natural Resources (WDNR). 2003e. Redfin Shiner (Lythrurus

umbratilis). Wisconsin Department of Natural Resources, Madison, Wisconsin.

http://www.dnr.state.wi.us/org/land/er/factsheets/fish/Rdfshn.htm

(Accessed November 24, 2004).

Wisconsin Department of Natural Resources (WDNR). 2003f. Greater Redhorse (Moxostoma

valenciennesi). Wisconsin Department of Natural Resources, Madison, Wisconsin.

http:/Iwww.dnr.state.wi.us/org/landler/factsheets/fish/Grtred.htm

(Accessed November 22, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004a. WPDES Permit, effective

July 1, 2004. Wl-0000957-07-0. Madison, Wisconsin. July 1, 2004.

Wisconsin Department of Natural Resources (WDNR). 2004b. Lake Michigan Integrated

Fisheries Management Plan 2003-2013. Administrative Report No. 56. Wisconsin Department

of Natural Resources, Madison, Wisconsin.

http://www.dnr.state.wi.us/org/water/fhp/fish/lakemich/LMI FMP%202003-2013.pdf

(Accessed November 11, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004c. Choose Wisely. A Health

Guide for Eating Fish in Wisconsin. PUB-FH-824 2004. Wisconsin Department of Natural

Resources, Madison, Wisconsin.

http://dnr.wi.gov/org/water/fhp/fish/pages/consumption/choosewiselyO4.pdf

(Accessed November 11, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004d. White Perch (Morone

americana). Wisconsin Department of Natural Resources, Madison, Wisconsin.

http://www.dnr.state.wi.us/org/water/wm/GLWSP/exotics/whiteperch.html

(Accessed November 12, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004e. Spiny Waterflea (Bythotrephes

cederstroemi) and Fishhook Waterflea (Cercopagis pengoi). Wisconsin Department of Natural

Resources, Madison, Wisconsin.

http://www.dnr.state.wi.us/org/water/wm/GLWSP/exotics/spiny.html

(Accessed November 12, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004f. WDNR-Natural Heritage

Inventory On-line Database. http://www.dnr.state.wi.us/org/land/er/nhi/NHIimslonlinedb.htm

(Accessed August 3, 2004).

NUREG-1437, Supplement 23 2-68 August 2005

II
Plant and the Environment

Wisconsin Department of Natural Resources (WDNR). 2004g. Piping Plover (Charadrius

melodus). http://www.dnr.state.wi.us/org/land/er/factsheets/birds/PLOVER.HTM

(Accessed August 3,2004).

Wisconsin Department of Natural Resources (WDNR). 2004h. Dune Thistle (Cirsium pitchen).

http://www.dnr.state.wi.us/org/1and/er/factsheets/birds/THISTLE.htm

(Accessed August 3, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004i. Dwarf Lake Iris (Iris lacustris).

httpJ/www.dnr.state.wi.us/org/land/er/factsheets/birds/dwarf.htm (Accessed August 3, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004j. Wisconsin Natural Heritage

Inventory Natural Community Descriptions.-

http://www.dnr.state.wi.us/org/land/er/communities/descriptions.htm

(Accessed August 3, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004k. Snow Trillium, Dwarf White

Trillium (Trillium nivale). http://www.dnr.state.wi.us/org/land/er/factsheets/birds/snwtril.htm

(Accessed August 3, 2004).

Wisconsin Department of Natural Resources (WDNR). 2005. Email correspondence from

P. Luebke to S. Imboden, NRC, regarding onsite settling pond at PBNP. May 25, 2005..

Wisconsin Department of Revenue (WDR). 2003a. Municipal and County Aid (State Shared

Revenues). http://www.dor.state.wi.us/report/s.html#shared (Accessed July 29, 2004).

Wisconsin Department of Revenue (WDR). 2003b. County and Municipal Revenues and

Expenditures 2001. Bulletin No. 101, February 2003.

http://www.dor.state.wi.us/reportlr.html#revenues (Accessed July 29, 2004).

Wisconsin Department of Revenue (WDR). 2004. County and Municipal Revenues and

Expenditures 2002. Bulletin No. 102, February 2004.

http://www.dor.state.wi.us/report/r.html#revenues (Accessed July 29, 2004).

Wisconsin Department of Transportation (WDOT). 2002. Manitowoc County Annual Average

Daily Traffic. http://www.dot.wisconsin.gov/traveVcounts/manitowoc.htm

(Accessed July 13, 2004).

Wisconsin Department of Workforce Development (WDWD). 2004. LMI - Local Area

Unemployment Statistics (LAUS) 2004.

http://www.dwd.state.wi.us/lmVlaus_view_current.htm#T (Accessed July 27, 2004).

August 2005 2-69 NUREG-1 437, Supplement 23
Plant and the Environment

Wisconsin Electric Power Company (WEPCO). 1976. Point Beach Nuclear Plant Final Report

on Intake Monitoring Studies Performed by Wisconsin Electric Power Company in Fulfillment of

Condition of Wisconsin Pollution Discharge Elimination System Permit No. WI-0000957.

Wisconsin Electric Power Company, Milwaukee, Wisconsin. June 1,1976.

Wisconsin Electric Power Company (WEPCO). 2003. Letter from E. Hellman, WEPCO, to

WDNR. Subject: 'Application for Reissuance of WPDES Permit No. WI-0000957-06, Point

Beach Nuclear Plant." Milwaukee, Wisconsin. September 22, 2003.

Wisconsin Historical Society (WHS). 1996. The Farm Landscape. Compiled by P. L. Beedle.

Edited by G. M. Gyrisco. Wisconsin Historical Society, Madison, Wisconsin.

Wisconsin Historical Society (WHS). 2000. Mapping Wisconsin History: Teacher's Guide and

Student Materials. Native American Treaty Lands 1825.

http://www.wisconsinstories.org/2001 season/native/map/nj.map_1 825.html

(Accessed August 4, 2004).

Wisconsin Historical Society (WHS). 2004a. Wisconsin National Register of Historic Places.

Kewaunee County. http://www.wisconsinhistory.org/hp/register/search.asp?cnty=KE

(Accessed August 6, 2004).

Wisconsin Historical Society (WHS). 2004b. Wisconsin National Register of Historic Places.

Manitowoc County.

http://www.wisconsinhistory.org/hp/register/search.asp?cnty=MN (Accessed August 6, 2004).

Wisconsin Historical Society (WHS). 2004c. Letter from S. Banker to S. Schumacher, We

Energies. Subject: 'SHSW# 03-1046/MN, Re: License Renewal, Point Beach Nuclear Plant."

October 21, 2004.

Wisconsin Public Service Corporation. 1972. Kewaunee Nuclear Power Plant Environmental

Report: Operating License Stage. Green Bay, Wisconsin. December 1972.

Wojta, J. F. 1945. A History of the Town of Two Creeks, Manitowoc County, Wisconsin.

Privately published. Available at Lester Public Library, Two Rivers, Wisconsin.

Yanda, M., Geographic Information Systems Coordinator, Manitowoc County, Wisconsin.

2004. Email correspondence documenting transmittal of land use cover inventory to W. Rued,

Lawrence Livermore National Laboratory. June 1, 2004.

NUREG-1 437, Supplement 23 2-70 August 2005

I D
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).(a) 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 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 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

that 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.

(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.

August 2005 3-1 NUREG-1437, Supplement 23
I

Environmental Impacts of Refurbishment

Table 3-1. Category i 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

AouATic ECOLOGY (FOR ALL PLANTS)

Refurbishment 3.5

GROUNDWATER USE AND QUALITY

Impacts of refurbishment on groundwater use and quality 3.4.2

LAND USE

Onsite land use 3.2

HUMAN HEALTH

Radiation exposures to the public during refurbishment 3.8.1

Occupational radiation exposures during refurbishment 3.8.2

SOCIOECONOMICS

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4;

3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

Category 1 and Category 2 issues related to refurbishment that are not applicable to Point

Beach Nuclear Plant Units 1 and 2 (PBNP) because they are related to plant design features or

site characteristics not found at PBNP are listed in Appendix F.

The potential environmental impacts of refurbishment actions would be identified, and the

analysis would be summarized within this section, if such actions were planned. Nuclear

Management Company, LLC (NMC) indicated that it has performed an evaluation of structures

and components pursuant to Title 10 of the Code of Federal Regulations (CFR) 54.21 to

identify activities that are necessary to continue operation of PBNP during the requested

20-year period of extended operation. These activities include replacement of certain

components as well as new inspection activities and are described in the Environmental Report

(NMC 2004).

NUREG-1437, Supplement 23 3-2 August 2005

I I
Environmental Impacts of Refurbishment

Table 3-2. Category 2 Issues for Refurbishment Evaluation

- 10 CFR 51.53

ISSUE -10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections. (c)(3)(ii)

Subparagraph

TERRESTRIAL RESOURCES

Refurbishment impacts 3.6 E

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 3.9 E

AIR OuALrrY

Air, A-A-h. H4 nin, rknkmantnnntfnnn* onei '- 2 . i'.II 4ULIILy UUll IV I UI UIII IIII I II.IQILUII III IVll I IL dI IU

maintenance areas) "." I

SOCIOECONOMICS

Housing impacts 3.7.2

Public services: public utilities 3.7.4.5 1

Public services: education (refurbishment) 3.7.4.1 1

Offsite land use (refurbishment) 3.7.5 .

Public services, transportation 3.7.4.2 J

Historic and archaeological resources 3.7.7 K.

ENVIRONMENTAL JUSTICE

Environmental justice Not Not

addressedma) 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 staff's

environmental impact statement.

However, NMC stated that the replacement of these components and the additional inspection

activities are within the bounds of normal plant component replacement and inspections;

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

operations as evaluated in the final environmental statement (U.S. Atomic Energy

Commission 1972). In addition, NMC's evaluation of structures and components as required by

10 CFR 54.21 did not identify any major plant refurbishment activities or modifications

necessary to support the continued operation of PBNP beyond the end of the existing operating

licenses. Therefore, refurbishment is not considered in this SEIS. I

August 2005 3-3 NUREG-1 437, Supplement 23
Environmental Impacts of Refurbishment

3.1 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.'

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

Renewal of Operating Ucenses for Nuclear Power Plants."

Nuclear Management Company, LLC. (NMC). 2004. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin. February 2004.

U.S. Atomic Energy Commission. 1972. Final Environmental Statement Related to Operation

of Point Beach Nuclear Plant Units 1 and2. Dockets No. 50-266 and 50-301, 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.

i

NUREG-1 437, Supplement 23 3-4 August 2005

Il
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).(a) 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 [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-s'pecific 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 Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B,

and are applicable to the Point Beach Nuclear Plant Units 1 and 2 (PBNP). Section 4.1

addresses issues applicable to the PBNP 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

(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.

August 2005 4-1 NUREG-1437, Supplement 23
I n

Environmental Impacts of Operation

impacts. The results 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 PBNP because they

are related to plant design features or site characteristics not found at PBNP 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 PBNP cooling system operation during the renewal term are listed in Table 4-1. Nuclear

Management Company, LLC (NMC) stated in its Environmental Report (ER) (NMC 2004a) that

it is not aware of any new and significant information associated with the renewal of the PBNP

operating licenses (OLs). The staff has not identified any new and significant information

during its independent review of the NMC ER (NMC 2004a), the staff's site visit, the scoping

I process, the staff's evaluation of other available information, or public comments on the draft

| supplemental environmental impact statement (SEIS). Therefore, the staff concludes that there

are no impacts related to these issues beyond those discussed in the GEIS. For all of the

issues, the 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.

Table 4-1. Category 1 Issues Applicable to the Operation of the PBNP 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 (FOR ALL PLANTS)

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

Water use conflicts (plants with once-through cooling systems) 4.2.1.3

NUREG-1437, Supplement 23 4-2 August 2005

II
Environmental Impacts of Operation

Table 4-1. (contd)

-

ISSUE - 10 CFR Part 51, Subpart A, Appendix B, Table B-1

AQUAnc ECOLOGY (FOR ALL PLANTS)

Accumulation of contaminants in sediments or biota

Entrainment of phytoplankton and zooplankton

Cold shock

Thermal plume barrier to migrating fish

Distribution of aquatic organisms

Premature emergence of aquatic insects

Gas supersaturation (gas bubble disease)

Low dissolved oxygen in the discharge

Losses from predation, parasitism, and disease among organisms

exposed to sublethal stresses

Stimulation of nuisance organisms

GEIS Sections

4.2.1.2.4

4.2.2.1.1

4.2.2.1.5

4.2.2.1.6

4.2.2.1.6

4.2.2.1.7

4.2.2.1.8

4.2.2.1.9

4.2.2.1.10

4.2.2.1.11

I

I

I

I

I:

I

I

I

I

I

HUMAN HEALTH

Noise 4.3.7

A brief description of the staff's review and the'GEIS conclusions, as codified in Table B-1, for

each of these issues follows:

* 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of altered current patterns at intake and discharge

structures during the renewal term beyond those discussed in the GEIS.

I

I

I

I

August 2005 4-3- NUREG-1437, Supplement 23
Environmental Impacts of Operation

* 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, its review of monitoring

programs, the staff's evaluation of other available information, or public comments on the

draft SEIS. Therefore, the staff concludes that there are 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's review of

monitoring programs, the staff's evaluation of other available information, or public

comments on the draft SEIS. Therefore, the staff concludes that there are no impacts of

scouring caused by discharged cooling water during the renewal term beyond those

discussed in the GEIS.

NUREG-1 437, Supplement 23 4-4 August 2005

II
Environmental Impacts of Operation

* 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's review of

monitoring programs, the staff's evaluation of other available information including plant

monitoring data and technical reports, or public comments on the draft SEIS. Therefore,

the staff concludes that there are 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information including the Wisconsin Pollutant Discharge Elimination System

(WPDES) permit for PBNP, discussion with the Wisconsin Department of Natural.

Resources (WDNR 2004a), or public comments on the draft SEIS. Therefore, the staff

concludes that there are 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 NPDES permit and periodic

modifications, if needed, and are not expected to be a problem during the

license renewal term.

The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information including the WPDES permit for PBNP, discussion with the

WPDES compliance office (WDNR), or public comments on the draft SEIS. .Therefore, the

staff concludes that there are no impacts of discharges of sanitary wastes and minor

chemical spills during the renewal term beyond those discussed in the GEIS.

August 2005 4-5 NUREG-1437, Supplement 23
II L

Environmental Impacts of Operation

* 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.

The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information including the WPDES permit for PBNP, discussion with the

WDNR, or public comments on the draft SEIS. Therefore, the staff concludes that there are

no impacts of discharges of other metals in wastewater during the renewal term beyond

those discussed in the GEIS.

* Water-use conflicts (plants with once-through cooling systems). Based on information in

the GEIS, the Commission found that

These conflicts have not been found to be a problem at operating nuclear

power plants with once-through heat dissipation systems.

The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of water-use conflicts for plants with once-through

cooling systems 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

available information, or public comments on the draft SEIS. Therefore, the staff concludes

that there are no impacts of accumulation of contaminants in sediments or biota during the

renewal term beyond those discussed in the GEIS.

NUREG-1437, Supplement 23 4-6 August 2005

I I
Environmental Impacts of Operation

* 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process,'the staff's review of

monitoring programs, the staff's evaluation of other available information, or public

comments on the draft SEIS. 'Therefore, the staff concluded that there are 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff - I

concludes that there are 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS.- Therefore, the staff -

concludes that there are no impacts of thermal plume barriers to migrating fish during the

renewal term beyond those discussed in the GEIS.

August 2005 4-7 NUREG-1437, Supplement 23
I nm

Environmental Impacts of Operation

* 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 effect the

larger geographical distribution of aquatic organisms.

The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's review of

monitoring programs, the staff's evaluation of other available information, or public

comments on the draft SEIS. Therefore, the staff concludes that there are 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of premature emergence of aquatic insects during the

renewal term beyond those discussed in the GEIS.

* Gas suDersaturation (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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of gas supersaturation during the renewal term beyond

those discussed in the GEIS.

NUREG-1 437, Supplement 23 4-8 August 2005

I I
Environmental Impacts of Operation

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 staff has not identified any new and significant information during its independent

review of the NIMVC ER, the staff's site visit, the scoping process, the staff's review of

monitoring programs, the staff's evaluation of other available information, or public

comments on the draft SEIS. Therefore, the staff concludes that there are 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 staff has not identified any new and significant information during its independent

review of the N.MVC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are 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.

* 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

August 2005 4-9 NUREG-1437, Supplement 23.
Environmental Impacts of Operation

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of stimulation of nuisance 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of noise during the renewal term beyond those

discussed in the GEIS.

The Category 2 issues related to cooling system operation during the renewal term that are

applicable to PBNP are discussed in the sections that follow and are listed in Table 4-2.

Table 4-2. Category 2 Issues Applicable to the Operation of the PBNP Cooling System

during the Renewal Term

10 CFR

ISSUE -10 CFR Part 51, Subpart A, GEIS 51.53(c)(3)(II) SEIS

Appendix B. Table B-1 Sections Subparagraph Section

AouAxc ECOLOGY

(FOR PLANTS WITH ONCE-THROUGH AND COOLING POND HEAT-DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life 4.2.2.1.2 B 4.1.1

stages

Impingement of fish and shellfish 4.2.2.1.3 B 4.1.2

Heat shock 4.2.2.1.4 B 4.1.3

I

I

I

I

4.1.1 Entrainment of Fish and Shellfish in Early Life Stages

For plants with once-through cooling systems, entrainment of fish and shellfish in early life

stages into cooling-water systems associated with nuclear power plants is considered a

Category 2 issue, requiring a site-specific assessment before license renewal. To perform this

evaluation, the staff reviewed the NMC ER (NMC 2004a); visited the PBNP site; and reviewed

the applicant's WPDES Permit No. WI-0000957-07-0 (Table E-2, Appendix E), effective on

NUREG-1437, Supplement 23 4-10 August 2005

Il
Environmental Impacts of Operation

July 1, 2004, and in force until June 30, 2009 (WDNR 2004a), documents submitted to WDNR

in support of the'WPDES Permit application, and correspondence between the applicant and

WDNR.

Section 316(b) of the Clean Water Act of 1977 (CWA) (33 United States Code [USC] 1326

et seq.) requires that the location, design,-construction, and capacity of the cooling-water intake

structure reflect the best technology available for minimizing adverse environmental impacts.

Entrainment of fish and shellfish into the cooling-water system is a potential adverse

environmental impact that can be minimized by use of the best available technology.

On July 9, 2004, the U.S. Environmental Protection Agency (EPA) published a final rule in the

Federal Register(EPA 2004) addressing cooling-'water'intake structures at existing power

plants whose flow levels exceed a minimum threshold value of 190,000 m3/d (50 million gpd).

The rule is Phase II in EPA's development of 316(b) regulations and establishes national

requirements applicable to the location, design, construction, and capacity of cooling-water

intake structures at existing facilities that exceed the threshold value for water withdrawals. The

national requirements, implemented through National Pollutant Discharge Elimination System

(NPDES) (or equivalent state) permits, minimize the adverse environmental impacts associated

with the continued use of the intake systems. Licensees are required to demonstrate

compliance with the Phase II performance standards at the time of renewal of their NPDES (or

equivalent state) permit. Licensees may be required as part of the permit renewal to alter the

intake structure, redesign the cooling system, modify'station operation, or take other mitigation'

measures as a result of this regulation.' The new performance standards are designed to

significantly reduce entrainment losses due to water withdrawals associated with cooling water

intake structures used for power production'. Any site-specific mitigation would result in less

impact from entrainment during the license renewal period.

Condenser cooling water is withdrawn from Lake Michigan through two, 4.3-m (1 4-ft) diameter

pipes buried beneath the lakebed. Water enters these pipes at the offshore intake structure, a

cylinder of steel pilings filled with limestone blocks that stands upright on the lakebed

approximately 530 m (1750 ft) offshore in 6.7 m (22 ft) of water (NMC 2004a). At peak

capacity, water is circulated at a maximum rate of 22 m3/s (777 cfs) for each unit.

As a condition of an earlier WPDES permit,-the applicant was required to perform a one-year

intake monitoring study to determine potential impacts to the environment caused by the

cooling-water intake system (WEPCO 1976);- Forty-nine entrainment samples were collected

between April 15 and October 31, 1975. It was estimated that 2,082,525 fish larvae were

entrained at PBNP during the study period. Among these; 20 percent (416,505) were alewife

(Alosa pseudoharengus), 61 percent (1,270,340) were rainbow smelt (Osmerus mordax),

August 2005 4-11 NUREG-1437, Supplement 23
. ML_

Environmental Impacts of Operation

17 percent (354,029) were sculpin (probably slimy sculpin [Cottus cognatus] based on

impingement collections), and two percent (41,651) were longnose sucker (Catostomus

catostomus). Additionally, an estimated 4,661,410 fertilized alewife eggs were entrained

(WEPCO 1976).

To interpret the impacts of entrainment on the fish community of Lake Michigan, entrainment

losses must be compared to the distribution, abundance, and life history of the species that

occur near the PBNP and assess the associated impacts on individual fish populations and

community structure.

Entrainment of fish eggs can be compared to the production of eggs per fish. For example, an

individual alewife produces between 10,000 to 12,000 eggs (Scott and Crossman 1973).

Therefore, the 4.66 million alewife eggs entrained in 1975. (WEPCO 1976) would be equivalent

to the egg production output of only 388 to 460 gravid females. Levels of egg entrainment at

PBNP would be expected to be relatively low as the habitats in the plant vicinity are not

preferred spawning habitat (e.g., coastal wetlands, bedrock, sandy beach-dunes, or bluffs;

Wei et al. 2004). In contrast, egg entrainment (consisting mostly of alewives) at D.C. Cook

Nuclear Plant, which is located on the eastern shore of Lake Michigan in an area of extensive

sandy beach-dune habitat, ranged from 743.2 million to 7.0 billion eggs per year between 1975

and 1982 (Noguchi et al. 1985).

Natural mortality of alewife larvae has been shown to be in excess of 90 percent

(WEPCO 1976). Therefore, of the 416,505 alewife larvae entrained at PBNP during 1975, it

could be assumed that only 41,650 would have survived to be age I alewives. In 1972, there

were about 10 billion age I alewives in Lake Michigan. Therefore, loss of alewife larvae due to

entrainment at PBNP represents only a small fraction of one percent of the standing crop of

alewives in Lake Michigan (WEPCO 1976). Annual mortality for older alewives is 40 to

60 percent (DFO 2004). Using the more conservative 60 percent mortality rate, an expected

25,000 alewife larvae would have been lost due to entrainment at PBNP. This is a very small

percentage of the billions of adult alewives that occur in Lake Michigan (i.e., 16.5 billion in 2003;

[Madenjian et al. 2004]).

Using similar assumptions, the 1,270,340 rainbow smelt larvae entrained in 1975 would equate

to 127,034 age I rainbow smelt. It was conservatively estimated that nearly 60 million age I

rainbow smelt occurred in Lake Michigan in 1974 (WEPCO 1976). Therefore, entrained

rainbow smelt larvae at PBNP would have been only 0.2 percent of this amount.

In the early 1970s, there was an estimated 100 to 200 million sculpins (all species combined)

beyond the larval stage in Lake Michigan (WEPCO 1976). Therefore the 354,029 sculpin

larvae entrained at PBNP during 1975 would equate to a small fraction of one percent of the

lakewide sculpin population (assuming a 90 percent larval mortality rate). Overall, larval

NUREG-1437, Supplement 23 4-12 August 2005

I n
Environmental Impacts of Operation

entrainment losses at PBNP during 1975 represent a very small percentage of the lakewide

production for the alewife, rainbow smelt, and slimy sculpin. Furthermore, as long as discharge

temperatures do not exceed 37.80C (100F) some degree of entrainment survival can be

expected (LaJeone and Monzingo 2000).

Macroinvertebrates entrained between April 15 and October 31,1975, included the amphipod

Diporeia spp. and the opossum shrimp Mysis relicta (WEPCO 1976). Approximately 14 million

amphipods (Diporeia spp.) and 10 million Mysis relicta were entrained during this period.

Diporeia densities near PBNP at the 7.3-m (24-ft) contour were estimated at about

1.2 million/ha (3 million/ac), while at deeper depths they have been estimated at densities of

14 million/ha (35 million/ac) (WEPCO 1976).

No significant phytoplankton mortality from thermal and physical stresses associated with

entrainment was observed during the early years of plant operations. Zooplankton mortality

varied from 8 to 19 percent of entrained organisms (AEC 1972). This level of entrainment

mortality would not have a significant impact on the nearshore zooplankton community in the

area of the PBNP.

Based on its review of the WEPCO (1976) study, the WDNR determined that the location and

operation of the PBNP intake had minimal environmental impact as a result of entrainment

(WDNR 1978).

The recently renewed WPDES permit for PBNP takes into account the new EPA 316(b)

requirements for once-through cooling systems. The permit requires the applicant to conduct a

study of the cooling-water intake for potential adverse environmental impacts in accordance

with Section 316(b) of the CWA. The proposal for the study was submitted to WDNR on

December 24, 2004, with the comprehensive demonstration study due in 2007 (WDNR 2004a).

Any requirements resulting from the water intake study would be reflected in future WPDES

permits. Under the conditions of the recently renewed WPDES permit, the location and

operation of the intake would continue to have minimal environmental impact.

The staff considered mitigation measures for the continued operation of PBNP. Based on its

assessment to date, the staff expects that the measures in place at PBNP (i.e.,-an offshore

intake located where there are no bays or points to act as fish nurseries or other attracting

features [except for the limestone blocks of the intake structure itself]; and the intake structure

constructed in a location devoid of unique spawning habitat [NMC 2004a; Wei et al. 2004]) -

provide adequate mitigation for impacts related to entrainment. The acoustic fish-deterrent

system'installed in 2002 to reduce fish impingement (see Section 4.1.2) would also reduce

August 2005 4-13 NUREG-1437, Supplement 23
Environmental Impacts of Operation

spawning activities near the intake for species such as alewife. This would also reduce

entrainment of fish eggs and larvae. The staff concludes that the potential impacts of

entrainment of fish and shellfish in the early life stages into the cooling water intake system

would be SMALL.

4.1.2 Impingement of Fish and Shellfish

For plants with once-through cooling systems, impingement of fish and shellfish on debris

screens of cooling-water system intakes is considered a Category 2 issue, requiring a

site-specific assessment before license renewal. To perform this evaluation, the staff reviewed

the NMC ER (NMC 2004a); visited the PBNP site; and reviewed the applicant's WPDES Permit

No. WI-0000957-07-0 (Table E-2, Appendix E), effective on July 1, 2004, and in force until

June 30, 2009 (WDNR 2004a), documents submitted to WDNR in support of the WPDES

Permit application, and correspondence between the applicant and WDNR.

Condenser cooling water is withdrawn from Lake Michigan through two, 4.3-m (14-ft) diameter

pipes buried beneath the lakebed. Water enters these pipes at the offshore intake structure, a

cylinder of steel pilings filled with limestone blocks that stands upright on the lakebed

approximately 530 m (1750 ft) offshore in 6.7 m (22 ft) of water (NMC 2004a). At peak

capacity, water is circulated at a maximum rate of 22 m3/s (777 cfs) for each unit. Bar grates

and eight traveling screens with 0.95-cm (0.38-in.) square mesh are located in the forebay,

where debris and impinged fish can be removed before they enter the cooling-water system.

Section 316(b) of the CWA requires the location, design, construction, and capacity of cooling

water intake structures to reflect the best technology available for minimizing adverse

environmental impacts (33 USC 1326). Impingement of fish and shellfish on the debris screens

of the cooling water intake system is a potential adverse environmental impact that can be

minimized by use of the best available technology.

On July 9, 2004, EPA published a final rule in the Federal Register (69 FR 41575) (EPA 2004)

addressing cooling water intake structures at existing power plants whose flow levels exceed a

minimum threshold value of 190,000 m3/d (50 million gpd). The rule is Phase II in EPA's

development of 316(b) regulations and establishes national requirements applicable to the

location, design, construction, and capacity of cooling water intake structures at existing

facilities that exceed the threshold value for water withdrawals. The national requirements,

which are implemented through NPDES (or equivalent state) permits, minimize the adverse

environmental impacts associated with the continued use of the intake systems. Licensees are

required to demonstrate compliance with the Phase II performance standards at the time of

renewal of their NPDES (or equivalent state) permit. Licensees may be required as part of the

permit renewal to alter the intake structure, redesign the cooling system, modify station

operation, or take other mitigative measures as a result of this regulation. The new

NUREG-1437, Supplement 23 4-14 August 2005

i n
Environmental Impacts of Operation

performance standards are designed to significantly reduce impingement losses due to plant

operation. Any site-specific mitigation would result in less impact from impingement during the

renewal period.

As a condition of an earlier WPDES permit, the applicant was required to perform a one-year

intake monitoring study (March 1, 1975, to February 29, 1976) to determine potential impacts to;

the environment caused by the cooling-water intake system (WEPCO 1976). Further

impingement studies were carried out from 2001 to 2003. The results of these studies are

summarized below.

During a one-year period between March 1, 1975, and February 29,1976, an impingement

study was conducted at PBNP. Over 313,000 fish from 31 species (including one hybrid trout)

were collected in eighty-eight 24-hour impingement samples that were generally obtained every

fourth day of plant operation (WEPCO 1976). Total estimated impingement for the year was

1,056,724 fish, with numbers of fish impinged monthly ranging from 113 (March 1975) to l

467,869 (June 1975). Except for alewife and rainbow smelt, all species were impinged - I

infrequently or in low numbers. Therefore, an impingement summary for most species is more

readily evaluated by species groups. Alewives and rainbow smelt constituted over 99 percent |

of all fish impinged during the study. -The total numbers of alewives, rainbow smelt, and other

fish groups impinged during the one-year study period are listed in Table 4-3. -

Table 4-3. Fish Impinged at PBNP during the 1975-1976 Impingement Study }

Species or Fish Group Number Percent of Total Impinged(')

Alewife (Alosa pseudoharengus) 886,394 84

Rainbow smelt (Osmerus mordax) 161,389 15

Forage fishes 7285 0.69

Salmonids 468 - 0.04

Game and food fishes 979 0.09

I

I I '

I

I

I

I

Rough fishes 209 0.02 |

(a) Totals may not equal 100 percent due to rounding. Source: WEPCO 1976. .

The number of alewives imipinged at PBNP represented only about 0.003 percent of thetLake

Michigan alewife population and 0.009 percent of the annual lakewide mortality of alewives

during the early 1970s. Only 0.005 percent of the adult ale'wives in Lake Michigan were.

impinged at PBNP in 2003 (WEPCO 1976; Madenjian et al. 2004). In addition, most of the

impinged alewives were assumed to be dead or dying' individuals associated with the annual

spring die-off (WEPCO 1976). At two coal-fired power plants located at Lake Erie, more than

I

'I

 I

August 2005 4-15 NUREG-1437, Supplement 23
Environmental Impacts of Operation

73 percent of the impinged fishes (excluding gizzard shad [Dorosoma cepedianum]) was

composed of dead or terminally ill fishes whose condition was not a result of impingement.

Seventy-seven percent of the total impinged fishes at these plants were gizzard shad. Most of

them exhibited the typical symptoms associated with natural winter and spring mortality

(White et al. 1987). Therefore, impinged fish, including most of the alewives at PBNP, cannot

be considered wholly the result of plant-induced impingement mortality.

The estimated 161,389 rainbow smelt impinged at PBNP during the 1975 to 1976 study had an

equivalent weight of 973 kg (2145 lb) (WEPCO 1976). In comparison, the 2003 commercial

catch of rainbow smelt for the Wisconsin waters of Lake Michigan totaled 46,075 kg

(101,578 lb) (Hogler and Surendonk 2004), and the lake-wide biomass of rainbow smelt was

estimated at 1386 metric tons (1528 tons) (Madenjian et al. 2004). By weight, the impinged

rainbow smelt represent 2.1 percent and 0.07 percent of the commercial catch and lake-wide

population, respectively.

Excluding alewife and rainbow smelt, 12 species made up the forage group. The slimy sculpin

was the most numerous of these, and would account for the prevalence of sculpin larvae

collected in the entrainment samples (discussed in Section 4.1.1). Among the other forage

species impinged, the more numerous included gizzard shad and ninespine stickleback

(Pungitiuspungitius) (WEPCO 1976).

Most of the salmon and trout species (salmonids) that occur in the Wisconsin waters of Lake

Michigan were found in impingement samples. These included rainbow trout (Oncorhynchus

mykiss), brown trout (Salmo trutta), brook trout (Salvelinus fontinalis), lake trout

(S. namaycush), tiger trout (hybrid brook trout and brown trout, no longer stocked in the

Wisconsin waters of Lake Michigan), Chinook salmon (tshawytscha), and coho salmon (0.

kisutch). The impingement totals for the trout and salmon species were 452 and 16,

respectively. The number of salmonids impinged was only a small fraction of the numbers

stocked annually into Lake Michigan (i.e., an average of 14.5 million) (Bronte and Schuette

2002). The impinged salmonids were equated to a loss of only 56 salmonids, or 0.013 percent,

of the recreational catch of 1974. This was based on an estimate that 12 percent of the

stocked salmonids were caught by fishermen (WEPCO 1976). In 2003, the sport fishery catch

for salmonids (lake trout, rainbow trout, brown trout, coho salmon, and Chinook salmon) in the

Wisconsin waters of Lake Michigan totaled 464,327 (Eggold 2004). The 468 salmonids

estimated to have been impinged in the WEPCO (1976) study are only 0.1 percent of this total.

The game and food fishes collected in impingement samples included three coolwater species

(bloater [Coregonus hoyi], lake whitefish [C. clupeaformis], and round whitefish (Prosopium

cylindraceum]) and six warmwater species (northern pike [Esox lucius], channel catfish

[Ictalurus punctatus], largemouth bass [Micropterus salmoides], bluegill [Lepomis macrochirus],

NUREG-1437, Supplement 23 4-16 August 2005

I r
Environmental Impacts of Operation

and yellow perch [Perca flavescens]). As only a total of 979 individuals of these species were

impinged (WEPCO 1976), their loss would have an insignificant effect on the Lake Michigan

populations of these species.

The rough fishes impinged at PBNP included common carp (Cyprinus carplo), white sucker

(Catostomus commersom), and longnose sucker. As only 209 individuals were impinged

(WEPCO 1976), their loss would not be'considered significant.

Generally, immature fish were more prevalent in the impingement samples (WEPCO 1976).

This is attributed to (1) the greater relative abundance of younger fish, (2) juvenile fish of some

species may concentrate in nearshore waters, and (3) immature fish are weaker swimmers than

adults. Small fish could potentially pass through the openings in the screenwash collection

basket and be returned to the Lake. However, the intake screens are cleaned on a regular

schedule and when a pressure differential value is exceeded across the screens because of |

fouling. The extended period of time the fish remain on the intake screens, in addition to the

high-pressure spray water during the screen cleaning process,'would result in a potentially high

mortality rate to the impinged fish. Larger fish retained with other debris collected in the

screenwash collection basket are not returned to the Lake. Therefore, there is no impingement

survival for larger fish.

Based on its review of the WEPCO (1976) study, the WDNR determined that the location and

operation of the PBNP intake had minimal environmental impact as a result of impingement '

(WDNR 1978). None of the State-listed fish species that may occur near PBNP (discussed in

Section 2.2.5) were collected in the impingement samples.

In 2002, WEPCO installed a permanent fish-deterrent system around the intake structures,

under a compliance agreement with the U.S. Fish and Wildlife Service (FWS): -This system

makes use of high-frequency sound (125 kHz) to minimize the influx of fish into the intake -- -

structures. The decision to add a fish-deterrent system was based in part on an unusual event

at Unit 2 on June 27, 2001, when an influx of thousands of alewives caused a reduction in

intake water levels. The clogged intake screens reduced water levels in the plant circulating

water pump bay area'that supplies cooling water to the plant. Some of the traveling Water

screens were severely damaged by the weight of the fish. Fish baskets were ripped off, and*-l

some screens were bowed. The condenser Water boxes'and condensate coolers were partially

plugged with fish. The volume of fish removed from the forebay, the'condenser water boxes,'

and the condensate coolers following the June 27, 2001, event was estimated at approximately

4500 kg (10,000 lb). Another large influx of alewives into the forebay occurred on July 3, 2001.

Approximately 1700 kg (3800 lb) of fish were removed from the forebay during this event. A

third event occurred on July 7, 2001, with approximately 1400 kg (3000 lb) of fish removed from

the forebay (WEPCO 2000; NMC 2001).r NMC attributed these incursions to'several factors,

predominately the attraction of alewives to the warm water discharge. There was exceptionally

August 2005 4-17. NUREG-1437, Supplement 23 '
IIEL

Environmental Impacts of Operation

cold lake water that summer. This suggested that, at some point, the discharge plume may

have drifted over the intakes (NMC 2001). There was an estimated 42,876 metric tons

(47,262 tons) of alewives in Lake Michigan in 2003 (Madenjian et al. 2004). The loss of the

alewives due to this unusual impingement event was insignificant relative to the lakeside

population levels. The fish deterrent system used at PBNP is identical to the system currently

in use at the James A. Fitzpatrick Nuclear Plant (Ross et al. 1993) on Lake Ontario and at D.C.

Cook Nuclear Plant located on the eastern shore of Lake Michigan near Bridgman, Michigan.

The system has a minimum sound pressure of 170 dB at about 10 m (33 ft) from the intake and

190 dB at 1 m (3 ft) from the intake (Ross et al. 1993).

Operation of the fish-deterrent system at the James A. Fitzpatrick Nuclear Plant decreased fish

densities near the intake by as much as 96 percent, and the number of alewives impinged

decreased by as much as 87 percent. Following an unusually cold winter, alewife impingement

was reduced by 81 to 84 percent. The lower percent reduction following a cold winter was

probably due to the deterrent system not being as effective on alewives that are in poor

condition (Ross et al. 1993, 1996). The use of a similar sound deterrent system for a power

plant located on a Belgium estuary decreased total fish impingement by 60 percent

(Maes et al. 2004). Avoidance response varied among species, with impingement rates for the

Atlantic herring (Clupea harengus), a species similar to the alewife, decreasing by 95 percent.

During periods of maximum herring abundance in the estuary, more than 99 percent of the

herring were deterred by the sound system (Maes et al. 2004). The use of high-frequency

sound is considered a practical alternative to physical barriers to prevent alewives from entering

power plant intakes (Dunning et al. 1992). Since the system was installed at PBNP, NMC staff

has observed avoidance behavior by schools of alewife.

After the modification of the intake (i.e., change from a partially above- to below-water

structure), NMC recorded birds and fish recovered from the trash basket associated with the

screen-wash system for the traveling screens from 2001 to 2003. NMC reported these results

to the FWS (NMC 2002, 2003a, 2004b). The following summarizes the results from those

reports.

In the June 1, 2001, to December 31, 2003, monitoring program (NMC 2002, 2003a, 2004b),

fish larger than 15 cm (6 in.) contributed to a greater percentage of impinged fish than what

was found in the previous investigation by WEPCO (1976). This was due to the fact that only

fish retained in the screen-wash basket were analyzed, rather than all fishes impinged. As a

result, a greater percentage of the collected fish were salmonids, larger game and food fish

species, and larger rough fish species, with a low prevalence of smaller forage fish. During the

course of the study, 110 salmonids, 288 game and food fish, 932 rough fish, 62 unidentifiable

fish, and 226 other fish (i.e., 195 alewives <15 cm [<6 in.], 27 unidentifiable fish <15 cm [<6 in.],

and four unidentifiable forage fish >15 cm [>6 in.]) were collected. The species of about

20 percent of the fish from the salmonid, game and food fish, and rough fish groups could not

NUREG-1437, Supplement 23 4-18 August 2005

II
Environmental Impacts of Operation

be identified. Among those that could be identified were lake trout (salmonid group), burbot - |

(Lota Iota) and lake whitefish (Coregonus clupeaformis) (food and game group), and freshwater -

drum (Aplodinotus grinniens) and suckers (rough fish group) (NMC 2002, 2003a,2004b).-

Based on commercial, recreational, or lake-wide populations for the fish caught during the

impingement monitoring study (Section 2.2.5); the low number of fish impinged would have a

negligible impact on the Lake Michigan fish community.

No double-crested cormorants were collected in the June 1, 2001, to December 31, 2003,

impingement samples (NMC 2002, 2003a, 2004b). A total of 33 birds were collected. These

were primarily gull species. The FWS will continue to work with the licensee regarding the bird

impingement and mortality issue at PBNP (U.S. Department of the Interior 2005). - -

The recently renewed WPDES permit for PBNP takes into account the new EPA 316(b)

requirements for once-through cooling systems. The permit requires the applicant to conduct a

study of the cooling-water intake for potential adverse environmental impacts in accordance

with Section 316(b) of the CWA. The proposal for the study was submitted to WDNR on

December 24, 2004, with the "comprehensive demonstration study'. due in 2007

(WDNR 2004a). -Any requirements resulting from the water intake study would be reflected in

future WPDES permits. Under the conditions of the recently renewed WPDES permit, the

location and operation of the intake would continue to have minimal environmental impact.

The staff considered mitigation measures for the continued operation of PBNP. Based on the

assessment to date, the staff expects that the measures in place at PBNP (e.g., an offshore

intake located where there are no bays or points to act as fish nurseries or other attracting -

features [except for the limestone blocks of the intake structure]; and the intake structure

constructed in a location devoid of unique spawning habitat [AEC 1972; NMC 2004a;-

Wei et al. 2004]) provide mitigation for impacts related to impingement.- The acoustic

fish-deterrent system installed in 2003 also reduces fish impingement, especially for species

such as alewife. The staff concludes that the potential impacts of impingement of fish and

shellfish in the early life stages into the cooling water intake system would be SMALL, and

further mitigation measures would not be warranted.

4.1.3 Heat Shock

For plants with once-through cooling systems, the effects of heat shock are listed as a

Category 2 issue and require plant-specific evaluation before license renewal. The NRC

considers impacts on fish and shellfish that result from heat shock to be a Category 2 issue

because of continuing concerns about thermal discharge effects and the possible need to

modify thermal discharges in the future in response to changing environmental conditions

(NRC 1996). Information to be considered includes (1) the type of cooling system-(whether

once-through or cooling pond) and (2) evidence of a CWA Section 316(a) variance or

August 2005 4-19 _ NUREG-1437, Supplement 23
_ _ _ I I 1 [

Environmental Impacts of Operation

equivalent State documentation. To perform this evaluation, the staff reviewed the NMC ER

(NMC 2004a); visited the PBNP site; reviewed the applicant's 316(a) demonstration submitted

to the WDNR; and reviewed the applicant's WPDES Permit No. WI-0000957-07-0 (Table E-2,

Appendix E), effective on July 1, 2004, and in force until June 30, 2009 (WDNR 2004a),

documents submitted to WDNR in support of the WPDES Permit application, and

correspondence between the applicant and WDNR.

Section 316(a) of the CWA establishes a process whereby applicants can obtain facility-specific

thermal discharge limits (CWA 1977). Based on the thermal studies it conducted in 1975,

WEPCO submitted an application to WDNR for exemption from thermal standards (equivalent

to a CWA Section 316[a] demonstration). WDNR approved the exemption from the thermal

standards, and the current WPDES permit, WI-0000957-07-0, does not contain thermal effluent

limitations. However, the applicant is required to monitor the temperature daily at the discharge

and report these data on a yearly basis (WDNR 2004a).

PBNP has a once-through heat-dissipation system that uses water from Lake Michigan for

condenser cooling. Water is circulated through the condensers and returned to the lake

through two steel-piling troughs extending in opposite directions (at a 30-degree angle from the

plant centerline) approximately 61 m (200 ft) out into Lake Michigan. The average temperature

differential between the intake and discharge as reported in 1976 was 160C (290F), with a

maximum of 190C (340F) (WEPCO 1976). During the winter de-icing period, the ambient Lake

Michigan water temperature is about 0.60C (330F). Highest intake temperature during the

January-February 1976 period was 15.60C (60 0F), indicating that the maximum theoretical

increase in intake temperatures due to de-icing was 150C (27 0F), with an average influent

temperature of 7.80C (460F), giving a routine temperature increase of 7.20C (13 0F) (WEPCO

1976). A predictive model was used to estimate the extent of the thermally-affected zones for

varying temperatures and weather conditions. The applicant estimated that the total surface

area enclosed within the 0.60C, 1.10C, 2.80C, 5.60C, and 8.30C (1OF, 20F, 50F, 10F, and 150F)

isotherms would be 1781 ha, 465 ha, 146 ha, 8 ha, and 2.4 ha (4400 ac, 1150 ac, 360 ac, 20

ac, and 6 ac), respectively, when both units are operating. Out to depths of 6 m (20 ft), the

temperature field would probably extend to the bottom. Beyond a depth of 6 m (20 ft), as depth

increases, the thermal plume would be expected to become progressively shallower and

confined to the surface layer. This would extend to the limit of stability of the thermal plume

which is generally accepted as the 0.60C (1OF) isotherm (AEC 1972). Lake Michigan has a

surface area of 5.78 million ha (14.28 million ac), so any thermal influence of PBNP on aquatic

species would be very localized.

Any thermal plume impacts can be considered to be very localized due to the small maximum

plume size relative to that within the nearshore areas of northwestern Lake Michigan. Also,

discharges are located within a relatively featureless sandy substrate that has several positive

features for minimizing thermal impacts: (1) rapid plume dissipation; (2) no bays or points to

NUREG-1437, Supplement 23 4-20 August 2005

I I
Environmental Impacts of Operation

act as fish nurseries or other attracting features; and (3) no substantial unique spawning

grounds occur in the plant area (AEC 1972; NMC 2004a, Wei et al. 2004). Also, local currents

are sufficiently strong that the substrate is continually scoured resulting in relatively turbid

waters that are not attractive to fish species as a spawning area (AEC 1972).

The PBNP. thermal discharges are located such that fish do not become entrapped in'areas of

elevated temperatures. Thus, acute thermal impacts (e.g., death or immediate disability) are

unlikely. Fish and other biota are constantly exposed to large, natural fluctuations of water

temperatures, especially during upwellings and downwellings, which are common features in

the nearshore zone to which aquatic biota have adapted (Jude 1995). The inshore waters in

the PBNP area reach an annual maximum of 14.4 to 20.60C (58 to 690F) (AEC 1972). Thus,

the thermal discharge temperature at the point of discharge during summer would normally.

range as high as 30.6 to 36.70C (87 to 980F), with a predicted maximum of 39.40C (1 030F).

Generally, the maximum plume temperature differential would be within the tolerance range for

most warmwater species (Talmage and Opresko 1981). Furthermore, the thermal plume

encompassed by the 0.6 to 2.80C (1 to 50F) isotherms are sufficiently large that fishes would

not be abruptly exposed to higher temperature differentials that could be potentially harmful.

Coldwater species, such as salmonids, would be able to avoid adverse temperatures. Also, no

strong currents or physical obstruction are present that would force fish to remain in areas of

potentially harmful water temperatures (AEC 1972).

The WDNR is in the process of developing thermal effluent rules based on water quality. It is

likely that the current discharge will need to be evaluated against these new rules. This

evaluation will be covered under the WPDES permitting process, and NMC will comply with any

additional applicable permit requirements regarding thermal discharge that may be imposed in

the future.

The staff has reviewed the available information', including that provided by the applicant, the

staff's site visit, the WPDES permit, the 316(a) demonstration, and other public sources, such

as public comments on the draft SEIS. The staff has evaluated the potential impacts to aquatic

resources due to heat shock during continued operation. The staff concludes that the potential

impacts to fish and shellfish due to heat shock would be SMALL and further mitigation

measures would not be warranted. - - -

4.2 Transmission Lines

The NMC ER (NMC 2004a) describes four transmission lines that connect PBNP with the

transmission system (Figure 2-4 and Table 2-1). These transmission line rights-of-way (ROW)

cover approximately 791 ha (1955 ac) over a total length of approximately 117 km (73 mi).

Tree trimming is normally required only every 5 to 7 years, depending on vegetation growth

August 2005 4-21 NUREG-1437, Supplement 23
I RV

Environmental Impacts of Operation

rates in a given area. Clearing activities are dependent upon the types and amount of

vegetation in the ROWs. Clearing may include tractor mowing, manual chainsaw clearing, and

application of herbicides by a State-licensed, commercial applicator.

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to

transmission lines from PBNP are listed in Table 4-4. The applicant stated in its ER that it is

not aware of any new and significant information associated with the renewal of the PBNP OLs.

The staff has not identified any new and significant information during its independent review of

the NMC ER (NMC 2004a), the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to these issues beyond those discussed in the

GEIS. For all of those issues, the 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.

Table 4-4. Category 1 Issues Applicable to PBNP Transmission Lines during the Renewal

Term

ISSUE - 10 CFR Part 51, Subpart A, Appendix B, Table B-1

TERRESTRIAL RESOURCES

GEIS Sections

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, 4.5.6.3

honeybees, wildlife, livestock)

Flood plains 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

i

A brief description of the staff's review and GEIS conclusions, as codified in Table B-1, for each

of these issues follows. (For each issue below, the "NMC ER" refers to NMC 2004a.)

NUREG-1437, Supplement 23 4-22 August 2005

I I
Environmental Impacts of Operation

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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, consultation with the FWS

and the WDNR, the staff's evaluation of other information, or public comments on the draft

SEIS. Therefore, the staff concludes that there are no impacts of power line right-of-way

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 staff has not identified any new and significant information during its independent,

review of the NMC ER, the staff's site visit, the scoping process, consultation with FWS and

WDNR, the staff's evaluation of other information, or public comments on the draft SEIS.

Therefore, the staff concludes that there are no impacts of bird collisions with power lines

during the renewal term beyond those discussed in the GEIS.

* lmpacts of electromagnetic fields on flora and fauna (glants, 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 staff has not identified any new and significant information during its independent|

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other information, or public comments on the draft SEIS. Therefore, the staff concludes

that there are no impacts of electromagnetic fields on flora and fauna during the renewal

term beyond those discussed in the GEIS.

August 2005 4-23 NUREG-1437, Supplement 23
M

Environmental Impacts of Operation

* Flood plains and wetlands on power line rights-of-way. Based on information in the GEIS,

the Commission found that

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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, consultation with the FWS

and the WDNR, the staff's evaluation of other information, or public comments on the draft

SEIS. Therefore, the staff concludes that there are no impacts of power line rights-of-way

on flood plains 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other information, or public comments on the draft SEIS. Therefore, the staff concludes

that there are no air quality impacts 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other information, or public comments on the draft SEIS. Therefore, the staff concludes

that there are no onsite land-use impacts during the renewal term beyond those discussed

in the GEIS.

NUREG-1437, Supplement 23 4-24 August 2005

I I
Environmental Impacts of Operation

* Power line rights-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 staff has not identified any new and significant information during' its'independent

review of the NMC ER, the staff's site visit, the scoping process', the'staff's evaluation of

other information, or public comments on the draft SEIS. Therefore, the staff concludes

that there are no impacts of power line rights-of-way on land use during the renewal term

beyond thosediscussed in the GEIS.

There is one Category 2 issue related to transmission lines, and another issue related to

transmission lines is'being treated as a Category 2 issue. 'These issues are listed in Table 4-5

and are discussed in Sections 4.2.1 and 4.2.2.

Table 4-5. Category 2 and Uncategorized Issues Applicable to PBNP Transmission Lines

during the Renewal Term

ISSUE -10 CFR Part 51, Subpart A, GEIS 10 CFR 51.53(c)(3)(;i) SEIS

Appendix B, Table B-1 Sections Subparagraph - 'Section

HUMAN HEALTH

Electromagnetic fields, acute effects (electric 4.5.4.1 H 4.2.1 - shock)

Electromagnetic fields, chronic effects 4.5.4.2 NA 4.2.2

4.2.1 Electromagnetic Fields - Acute Effects

In the GEIS (NRC 1996), the staff found that it was not possible to determine the significance of

the electric shock potential without a review of the conformance of each nuclear plant

transmission line with National Electrical Safety Code (NESC) criteria (NESC 1997). 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.

In its supplement to the ER for operating Point Beach Unit 2 (WEPCO 1971), WEPCO (the

operator prior to NMC) identified three 345-kilovolt (kV) transmission lines that were built to

August 2005 4-25 NUREG-1437, Supplement 23
Environmental Impacts of Operation

connect PBNP to the electric grid. A fourth 345-kV transmission line was constructed by

Wisconsin Public Service Corporation to connect the Kewaunee Nuclear Power Plant (KNPP) to

the substation at PBNP (see Section 2.1.7 for additional details). WEPCO and the Wisconsin

Public Service Corporation have since transferred ownership of their transmission lines to the

American Transmission Company (ATC). These lines are approximately 118 km (73 mi) long

and occupy approximately 791 ha (1955 ac) of easement. The transmission lines were

designed and constructed in the late 1960s and early 1970s in accordance with the Wisconsin

Electrical Code and industry guidance that was current when the lines were built (NMC 2004a).

NMC performed an analysis to demonstrate that the four transmission lines at PBNP are in

compliance with the NESC 5-mA, electric-field-induced current limit (NMC 2004a). NMC's

analysis of these transmission lines began by identifying the limiting case road crossing for

each line. The limiting case is the configuration along each line where the potential for

induced-current shock would be greatest. Once the limiting case was identified, NMC

calculated the electric field strength for each transmission line, then calculated the induced

current.

NMC calculated electric field strength and induced current using a computer code called

ACDCLINE (Version 3.0) (Electric Power Research Institute 1992). The results of this

computer program have been field verified through actual electric field measurements by

several utilities. The input parameters included the design features of the limiting case

scenario, the NESC requirement that line sag be determined at 48.9 OC (120 'F) conductor

temperature, and the maximum vehicle size under the lines. The maximum size vehicle was

modeled as a tractor-trailer truck.

The analysis determined that none of the transmission lines has the capacity to induce more

than 5 mA, the NESC limit of electric field-induced current, in a tractor-trailer truck parked

beneath the lines. Therefore, the PBNP transmission line designs conform to the NESC

provisions for preventing electric shock from induced current (NMC 2004a).

NMC's assessment under 10 CFR Part 51 concludes that electric shock is of small significance

for PBNP transmission lines. Because of the small significance of the issue, mitigation

measures, such as installing warning signs at road crossings or increasing clearances, are not

warranted. This conclusion would remain valid into the future, provided there are no changes in

line use, voltage, current, and maintenance practices and no changes in land use under the

lines - conditions over which the ATC has control.

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, public comments, and other public sources. Using this information, the staff

NUREG-1437, Supplement 23 4-26 August 2005

I M
EnvfrirnMental Impacts of Operation

has evaluated the potential impacts for electric shock resulting from operation of PBNP and

associated transmission lines. The staff concludes that the potential impacts'for electric shock

during the renewal term would be 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 designated 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. A recent report (NIEHS 1999) contains the

following conclusion:

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 staff to change its position with respect to the

chronic effects of electromagnetic fields. The staff considers the GEIS finding of "not

applicable" 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

PBNP in regard to radiological impacts are listed in Table 4-6. NMC stated in its ER

(NMC 2004a) that it is not aware of any new and significant information associated with the

renewal of the PBNP OLs. The staff has not identified any new and significant information

during its independent review of the NMC ER, the staff's-site visit, the scoping process, the

staff's evaluation of other available information, and public comments on the draft SEIS.

Therefore, the staff concludes that there are no impacts related to these issues beyond those

August 2005 4-27 NUREG-1437, Supplement 23
Environmental Impacts of Operation

discussed in the GEIS. For these issues, the staff concluded in the GEIS that the impacts

I would be SMALL, and additional plant-specific mitigation measures are not likely to be

sufficiently beneficial to be warranted.

I Table 4-6. 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 Sections

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:

v Radiation exposures to the 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, and public comments on the draft SEIS. Therefore, the staff

concludes that 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, and public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts of occupational radiation exposures during the renewal

term beyond those discussed in the GEIS.

NUREG-1437, Supplement 23 4-28 August 2005

IlI
Environmental Impacts of Operation

There are no Category 2 issues related to radiological impacts of routine operations.

4.4 Socioeconomic Impacts of Plant Operations during the

License Renewal Period

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 4-7. NMC stated in its ER

(NMC 2004a) that it is not aware of any new and significant information associated with the

renewal of PBNP OLs.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the staff's scoping process, the staff's site visit, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to these issues beyond those discussed in the

GEIS (NRC 1996). For these issues, the staff concluded in the GEIS that the impacts would be

SMALL and that additional plant-specific mitigation measures are not likely to be sufficiently

beneficial to be warranted.

Table 4-7. Category 1 Issues Applicable to Socioeconomics during the Renewal Term

ISSUE- 10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

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 staff's review and the GEIS conclusions, as codified in Table B-1, for

each of these issues follows:

* Public services: public safety, social servicesiand 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.

August 2005 4-29 NUREG-1 437, Supplement 23
Environmental Impacts of Operation

The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts on public safety, social services, and tourism and

recreation during the renewal term beyond those discussed in the GEIS.

* Public services: education (license renewal term). Based on information in the GEIS, the

Commission found that

Only impacts of small significance are expected.

The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that 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 staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that 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 staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no aesthetic impacts of transmission lines during the renewal term

beyond those discussed in the GEIS.

Table 4-8 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and

environmental justice, which was not addressed in the GEIS.

NUREG-1437, Supplement 23 4-30 August 2005

I n
Environmental Impacts of Operation

Table 4-8. Environmental Justice and GEIS Category 2 Issues Applicable to - -l

Socioeconomics during the Renewal Term

ISSUE -10 CFR Part 51, Subpart A, 10 CFR 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 - GEIS Sections Subparagraph 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 the staffss

environmental impact statement.

4.4.1 Housing Impacts during Operations

To determine housing impacts, the applicant chose to follow Appendix C of the GEIS

(NRC 1996), which presents a population characterization method that is based on two factors,

"sparseness" and "proximity" (GEIS, Section C.1.4 [NRC 1996]). 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, and a matrix

is used to rank the population category as low, medium, or high (GEIS, Table C.1 and

Figure C.1 [NRC 1996]).

The staff examined population densities within specified distances from the PBNP site,

employing the NRC's Geographical, Environmental, and Siting Information System (GEn&SIS)

to analyze the 2000 census data (NRC 2004b).- As derived from the 2000 U.S. Census Bureau

(USCB) information, 94,536 people live within 32 km (20 mi) of PBNP and 757,469 people live

within 80 km (50-mi) of PBNP. This equates to a population density of 75 persons/km2

(195 persons/mi 2) within an 80-km (50-mri) radius (note that this accounts for the fact that PBNP

is located on Lake Michigan; so only a portion of the area within an 80-km (50-mi) radius is land

area). The largest city within 80 km (50 mi) is Green Bay, Wisconsin, with a population of

102,313 (USCB 2000a).

All or parts of 12 counties and the City of Green Bay are located within 80 km (50 mi) of PBNP.

Approximately 81 percent of the employees live in Manitowoc County. The remaining

19 percent are distributed across 12 counties, with numbers ranging from 1 to 73 employees

August 2005 4-31- NUREG-1437, Supplement 23
I rM

Environmental Impacts of Operation

per county. According to the GEIS sparseness and proximity matrix, PBNP ranks as

Category 4 in terms of sparseness (i.e., greater than or equal to 46 persons/km2

[120 persons/mi 2] within 32 km [20 miu), and Category 3 in terms of proximity (i.e., one or more

cities with 100,000 or more persons and less than 73 persons/km2 [190 persons/mi 2] within

80 km [50 miles]). According to the GEIS, the sparseness and proximity scores identify PBNP

as being located in a high-population area.

Housing impacts are a Category 2 issue (10 CFR Part 51, Subpart A, Appendix B, Table B-1).

In 10 CFR Part 51, Subpart A, Appendix B, Table B-1, the NRC states that impacts on housing

availability are expected to be of SMALL significance at plants located in high-population areas

where growth-control measures that limit housing development are not in effect. PBNP is

located in a high-population area, and Manitowoc County is not subject to growth-control

measures.

SMALL impacts result when no discernible change in housing availability occurs, changes in

rental rates and housing values are similar to those occurring Statewide, and no housing

construction or conversion is required to meet new demand (NRC 1996). NMC anticipates that

the actual number of new employees will be no more than two during the license renewal term.

NMC does not plan any new refurbishment activity as part of the license renewal process;

therefore, employment is not anticipated to change in the area as result of license renewal.

Thus, NMC concludes that there are no impacts to housing from license renewal activities

(NMC 2004a).

However, to establish an upper bound on possible increased employment during the license

renewal term, the GEIS assumes that no more than 60 additional permanent workers might be

needed at each unit during the license renewal period to perform routine maintenance and

other activities related to license renewal. Hiring of these additional 60 employees could result

in 40 indirect jobs, or an increased demand for a total of 100 housing units. This demand could

be met from within Manitowoc County, which currently has approximately 1800 vacant units

available. However, in light of the relatively high unemployment rate in the County, it is

probable that most of these jobs would be filled by current County residents.

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, the scoping process, discussions with other agencies, and other public sources.

Using this information, the staff has evaluated the potential housing impacts resulting from

operation of PBNP during the license renewal term. The staff concludes that the potential

housing impacts during the renewal term would be SMALL and mitigation is not warranted.

NUREG-1437, Supplement 23 4-32 August 2005

I I
Environmental Impacts of Operation

4.4.2 Public Services: Public Utility Impacts'during OperationsImpacts on public utility services are considered to be SMALL if there is little or no change in

the ability of the system to respond to the level of demand, and thus, there is no need to add

capital facilities. Impacts are considered MODERATE if overtaxing of service capabilities

occurs during periods of peak demand. Impacts are considered LARGE if existing levels of

service (e.g., water or sewer services) are substantially degraded and additional capacity is

needed to meet ongoing demands for services. The GEIS indicates 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 (NRC 1996).

PBNP obtains its water supply from private wells, and does not use water from local water

suppliers (NMC 2004a). Consequently, the plant itself would have no impact on local water

supplies. The maximum total capacity of all the water suppliers in Manitowoc County is

approximately 53 million Uday (14 million gpd) greater than the current average daily use, or

about 2.5 times the current use (Table 2-4).' For individual water suppliers, the capacity ranges

from 1.5 to 10 times the current use. There is ample additional capacity to supply any potential

increase in demand due to license renewal.

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, the scoping process, discussions with other agencies, and other public sources.

Using this information, the staff has evaluated the potential impacts of increased water use

resulting from the potential increase in employment. NMC assumes that no more than one or

two additional employees will be needed to support PBNP operations during the renewal term.

The staff concludes thatthe potential impacts of increased water use resulting from the

potential increase in employment during the renewal term would be SMALL and that no

additional mitigation efforts would be warranted.

4.4.3 Offsite Land Use during Operations

Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51'.,

Subpart A, Appendix B, Table B-1). Table B-i of 10 CFR Part 51 Subpart A, Appendix B, notes

that "significant changes in land use may be associated with population and tax revenue

changes resulting from license renewal."

Sections 3.7.5 and 4.7.4 of the GEIS define'the magnitude of land-use changes as a result of

plant operation during the license renewal term as follows:

August 2005 4-33 NUREG-1437, Supplement 23
I m

Environmental Impacts of Operation

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,

tax-driven land-use changes during the plant's license renewal term would be SMALL,

especially where the community has pre-established patterns of development and has provided

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.

Manitowoc County and the Town of Two Creeks receive Shared Utility Payments because

PBNP is located within their jurisdictions. Table 2-12 shows that the Town of Two Creeks

received between $190,100 and $217,100 per year between 1996 and 2002, which

corresponded to between 13.7 and 72 percent of the town's budget. Note that the 72 percent

occurred in 1999, which was an anomalous year. Except for 1999, the highest portion of the

town's budget provided by PBNP revenues was 24.5 percent. Table 2-13 shows that

Manitowoc County has received approximately $800,000 per year between 1996 and 2002,

which constituted between 1.2 and 2.0 percent of the County budget.

For the Town of Two Creeks, these revenues represent a significant portion of its budget

(between 13.7 and 24.5 percent), and are expected to continue through the renewal period.

These revenues constitute only a very small portion of the budget of Manitowoc County, and

would not be expected to influence offsite development whether or not the PBNP operating

license is renewed. Using NRC's criteria, PBNP's Shared Utility Payments have a MODERATE

to LARGE impact on the Town of Two Creeks. However, NMC does not anticipate

refurbishment or major construction during the license renewal period and, therefore, does not

anticipate any increase in the assessed value of PBNP due to refurbishment-related

NUREG-1437, Supplement 23 4-34 August 2005

II
Environmental Impacts of Operation

improvements, nor any related tax-increase-driven changes to offsite land use and

development patterns (NMC 2004a). PBNP will continue to be a significant source of revenue

for the Town of Two Creeks. However, despite having this income source since the plant was

constructed, the Town of Two Creeks has experienced relatively little land use change over the

past several decades. The Town of Two Creeks does not currently have a land use plan, but

does use zoning to preserve it's rural character.- In addition, no new major land use 'changes

are planned for the Town of Two Creeks (NMC 2004a). For these reasons, NMC does not

anticipate changes to local land use and development patterns as a result of license renewal.

NMC has identified that no more than one or two additional employees would be needed to

support PBNP operations during the license renewal term, which is well below the assumption

in the GEIS. This additional staffing is within normal employment variances at PBNP

(NMC 2004a). In Section 3.7.5 of the GEIS (NRC 1996), the staff found that if plant-related

population growth is less than five percent of the study area's total population, then offsite

land-use changes would be SMALL. This is-especially pertinent if the study area has

established patterns of residential and commercial development, a population density of at least

23 persons/km2 (60 persons/mi 2), and at least one urban area with a population of 100,000 or

more within 80 km (50 mi). In the case of PBNP, population growth will be less than five*

percent of the County's total population, and Manitowoc County has established patterns of

residential and commercial development guided by local comprehensive plans. In addition,

there is a population density of 75 persons/km2 (195 persons/mi 2) within an 80-km (50-mi)

radius,-and there is an urban area (Green Bay) with a population of over.100,000 within 80 km

(50 mi). Consequently, the staff concludes that population changes resulting from license

renewal are likely to result in SMALL offsite land-use impacts.

The staff has evaluated the potential impacts of offsite land use resulting from operation of

PBNP. Because NMC does not anticipate refurbishment activities, the population growth

related to license renewal of PBNP is expected to be relatively small, and there would be no

new tax impacts on local land use, the staff concludes that the potential impacts of tax revenue

changes resulting from license renewal would be likely to result in SMALL offsite land-use

impacts.

4.4.4 Public Services: Transportation Impacts during Operations

On October 4,1999, '10 CFR 51.53(c)(3)(ii)(J) and 10 CFR Part 51', Subpart A, Appendix B,

Table B-1, were revised to clearly state that "Public Services: Transportation Impacts During

Operations" is a Category 2 issue (see NRC 1999 for more discussion of this clarification). The

issue is treated as such in this SEIS.

Employees access PBNP primarily via State Route 42. -Assuming' an upper bound of 60 new

employees to be hired during the license renewal period, the traffic on State Route' 42 would

August 2005 4-35 NUREG-1437, Supplement 23
I CL

Environmental Impacts of Operation

increase approximately 1.6 percent. During refueling events, approximately 300 additional

personnel are employed at PBNP. This could increase the traffic on State Route 42 by

8 percent, which will have a negligible impact on the free flow of traffic.

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, the scoping process, discussions with other agencies, and other public sources.

Using this information, the staff evaluated the potential impacts to transportation service

resulting from operation of PBNP. The staff concludes that the potential impacts to

transportation service during the renewal term would be SMALL and no mitigation efforts are

warranted.

4.4.5 Historic and Archaeological Resources

The National Historic Preservation Act (NHPA) requires that Federal agencies take into account

the effects of their undertakings on historic properties (16 USC 470 et seq.). 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 a

nuclear power plant OL is an undertaking that could potentially affect historic properties within

the area of effect. Therefore, according to the NHPA, the NRC is 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 (SHPO)

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.

Prior to submitting its license renewal application to the NRC, NMC requested information from

the Wisconsin SHPO about potential impacts of continued plant operation (NMC 2003b). The

NMC initially concluded that there should be no impacts or minimal impacts to cultural

resources because it anticipated that there would be little refurbishment or change in

operations. In its response, in a letter dated January 6, 2004, the SHPO stated that cultural

resources would need to be identified first to conclude that there were no adverse impacts

(Wisconsin Historical Society [WHSJ 2004). The SHPO further noted that the fishing shed,

described in Section 2.2.9.2, would need to be evaluated for eligibility for the National Register

of Historic Places (NRHP). The PBNP site, but not necessarily the area within direct plant

control, contains leased farm lands and the SHPO noted that "continued plowing of a significant

archaeological site may lead to the destruction of the site." Consequently, NMC initiated

activities to identify the cultural resources that may be affected, to examine the architectural

significance of the fishing shed, and to conduct surveys of the leased farm lands.

NMC (NMC 2004c) forwarded available information from its contractor, AVD Archaeological

Services, Inc. (AVD), to the SHPO to provide additional historical context for the fishing shed.

In a letter dated March 11, 2004, the SHPO responded to NMC that additional evaluation was

NUREG-1437, Supplement 23 4-36 August 2005

I I
Environmental Impacts of Operation

needed and also suggested that an archaeological survey be completed or that NMC enter into

a programmatic agreement with the SHPO (WHS 2004). Subsequently, an architectural l

historian was engaged by NMC to examine the fishing shed for significance under the NHPA.-}

As a result of this examination, on October 21, 2004, the WHS issued a Determination of- |

Eligibility stating that the shed is not eligible for inclusion on the NRHP (We Energies 2004c).

NMC's contractor, AVD, conducted further examinations to inventory cultural remains on leased

farmlands outside the area of direct plant control., Approximately 45 ha (112 ac) were not

inventoried. This land was not inventoried because it was either designated as part of the

cropland reserve program, which is set aside for natural revegetation, or it was too heavily

vegetated to survey. The area surveyed comprises 440 ha (1085 ac), or approximately

86 percent of the PBNP site. Four artifact scatters within the surveyed area were

recommended for avoidance or, in the event that avoidance is not possible, for additional

evaluation. NMC stated that these recommendations would be implemented for any future

construction in those areas (We Energies 2004a).- Agricultural activities can be expected to

continue in those areas during the period of license renewal. Therefore, some'continued

disturbance and soil loss at these four artifact scatters is possible. The four scatters appear to

be limited in size and complexity. The remaining PBNP site area has either been heavily

disturbed by construction of the plant and ancillary facilities or consists of second-growth

wooded areas.

NMC maintains an internal procedure entitled uControl of Excavation" (NP 8.4.19) that

establishes reviews to be conducted prior to excavation. As a result of interactions with the

Wisconsin SHPO, proposed revisions to this procedure set criteria for preliminary cultural -

resource reviews. In addition, the proposed revisions provide for monitoring (to be conducted

during excavation), and must include observations for cultural resources. Work will be stopped

if unanticipated historic or prehistoric archaeological remains are encountered. We Energies'.

review of excavations includes consultation with the SHPO prior to disturbance of known or. -

suspected cultural resources. The SHPO would be notified immediately upon the discovery of

unanticipated cultural resources as well. By implementing its environmental review procedure, -

the licensee would take care during normal ground-disturbing operations and maintenance to

ensure that historic properties are not inadvertently impacted. When modified, these

procedures would ensure that cultural resources are protected through the period of the

renewed license.

Major refurbishment of PBNP is not anticipated during the license renewal period;

consequently, it is not expected that currently undeveloped portions of the site will be used for

operations during the renewal period. No change in the amount or type of ground-disturbing

activities is expected at the PBNP site, the leased lands, or in conjunction with transmission line

August 2005 4-37 - NUREG-1437, Supplement 23
I CL_

Environmental Impacts of Operation

maintenance. Operation of PBNP, as outlined in NMC's application for license renewal, would

protect undiscovered historic or archaeological resources on the site because the undeveloped

natural landscape and vegetation would remain undisturbed and access to the site would

remain restricted.

The staff concludes that adverse impacts on identified historic properties are minimal. This

conclusion is based on the following: the staff's cultural resources analyses and consultation

with the SHPO; NMC's conclusions that major refurbishment activities or changes in type or

amount of ground disturbance will not be undertaken during the license renewal period; WHS's

determination that the fishing shed is not eligible for the NRHP; the limited size and complexity

of the artifact scatters; and the protection afforded to the other known archaeological site, which

is in a cropland reserve program and is not expected to be disturbed. Therefore, potential

impacts on historic and archaeological resources are expected to be SMALL, and no additional

mitigation is warranted. Based on the further examinations conducted by NMC, the proposed

revisions to procedures governing land-disturbing activities, and measures to notify the SHPO,

the staff concludes that it is unnecessary at this time to enter into a cultural resources

programmatic agreement with the SHPO to protect cultural resources.

4.4.6 Environmental Justice

Environmental justice refers to a Federal policy requiring Federal agencies to identify and

address, as appropriate, disproportionately high and adverse human health or environmental

impacts of its actions on minorityza) or low-income populations. The memorandum

accompanying Executive Order 12898 (59 FR 7629) directs Federal executive agencies to

consider environmental justice under the National Environmental Policy Act of 1969 (NEPA).

The Council on Environmental Quality (CEQ) has provided guidance for addressing

environmental justice (CEQ 1997). Although the executive order is not mandatory for

independent agencies, the NRC has voluntarily committed to undertake environmental justice

reviews. On August 24, 2004, the Commission published a Final Policy Statement in the

Federal Registeron the treatment of environmental justice matters in NRC regulatory and

licensing actions (NRC 2004e). The Final Policy Statement reaffirms that the Commission is

committed to full compliance with the requirements of NEPA. Specific guidance is provided in

NRC Office of Nuclear Reactor Regulation Office Instruction LIC-203, Revision 1, Procedural

Guidance for Preparing Environmental Assessments and Considering Environmental Issues

(NRC 2004c).

(a) The NRC guidance for performing environmental justice reviews defines "minority" as American Indian

or Alaskan Native, Asian, Native Hawaiian or other Pacific Islander, Black races, or Hispanic ethnicity.

'Other" races and multiracial individuals may be considered as separate minorities (NRC 2004c).

NUREG-1437, Supplement 23 4-38 August 2005

I II
Environmental Impacts of Operation

The scope of the review as defined in NRC guidance (NRC 2004c) includes identification of

impacts on minority and low-income populations, the location and significance of any

environmental impacts during operations on these 'populations, and information pertaining to

mitigation. It also includes evaluation of whether these impacts are likely to be

disproportionately high and adverse.

The staff looks for minority and low-income populations within the 80-km (50-mi) radius of the

site. For the purposes of the staff's review, a minority population exists in a census block

group(a) if the percentage of each minority and aggregated minority category within the census

block group exceeds the corresponding percentage of minorities in the state of which it is a part

by 20 percent, or if the percentage of minorities within the census block group is at least

50 percent. A low-income population exists if the percentage of low-income population in a

census block group within the area of study exceeds the percentage of low-income population

in the State of which it is a part by 20 percent, or if the percentage of low-income population

within a census block group is at least 50 percent.

The staff examined the geographic distribution of minority and low-income populations within

80 km (50 mi) of the PBNP site, employing GEn&SIS to analyze the 2000 census data

(NRC 2004b). The staff supplemented its analysis with field inquiries to county planning

departments and municipal officials.

Within an 80-km (50-mi) radius of PBNP, there are 567 block groups. Based on the NRC

criteria, and using the population of Wisconsin as the comparative population, the staff made

the following determinations:

(1) No populations of Native Hawaiian or other Pacific Islander, other single minorities, or

multiracial minorities exist in the geographic area.

(2) American Indian or Alaskan Native minority populations exist in five block groups.

These populations are located in Brown and Outagamie counties and are associated

with the Oneida reservation.

(3) Asian minority populations exist in a single block group located in Brown County.

(4) Black minority populations exist in a single block group also located in Brown County.

(5) The GEn&SIS database did not identify any block groups with Hispanic populations that

exceeded the 20-percent criterion.

(a) A census block group is a combination of census blocks, which are statistical subdivisions of a census

tract. A census block is the smallest geographic entity for which the USCB collects and tabulates

decennial census information. A census tract is a small, relatively permanent statistical subdivision of

counties delineated by local committees of census data users in accordance with USCB guidelines for

the purpose of collecting and presenting decennial census data. Census block groups are subsets of

census tracts (USCB 2001).

August 2005. 4-39 - NUREG-1437, Supplement 23
Environmental Impacts of Operation

The "greater than 50 percent" criterion did not apply to any block group.

Figure 4-1 shows the locations of block groups that meet the criteria for minority populations.

NRC guidance defines low-income" by using USCB statistical poverty thresholds (NRC 2004c).

A block group is considered to be low income if the following criteria are satisfied:

(1) The low-income population of the census tract or environmental impact site exceeds

50 percent, or

(2) The percentage of households below the poverty level in an environmental impact area

is significantly greater (typically at least 20 percentage points) than the low-income

population percentage in the geographic area chosen for comparative analysis.

According to the USCB, 5.6 percent of households in Wisconsin have incomes below the

poverty level (USCB 2000b).

Based on the "more than 20 percentage points" criterion, eight block groups contain a

low-income population. All are found in Brown County. Figure 4-2 shows their locations.

After identifying the locations of minority and low-income populations, the staff evaluated

whether any of the environmental impacts of the proposed action could affect these populations

in a disproportionately high and adverse manner. Based on staff guidance (NRC 2004c), air,

land, and water resources within approximately 80 km (50 mi) of the PBNP site were examined.

Within that area, a few potential environmental impacts could affect human populations, but all

of these impacts were considered to be SMALL for the general population.

The pathways through which the environmental impacts associated with PBNP license renewal

can affect human populations are discussed in each associated section of this report. During

the staff's review of the information, including that provided by the applicant, the staff's site visit,

the scoping process, discussions with other agencies, and other public sources, the staff has

found no unusual resource dependencies or practices, such as subsistence agriculture,

hunting, or fishing, through which minority and/or low-income populations could be

disproportionately highly and adversely affected. In addition, the staff has not identified any

location-dependent disproportionately high and adverse impacts that would affect these

minority and low-income populations. The staff concludes that potential offsite impacts from

PBNP to minority and low-income populations during the renewal term would be SMALL and no

mitigation measures would be warranted.

NUREG-1437, Supplement 23 4-40 August 2005

I I
Environmental Impacts of Operation -

LEG"D

rn cmrt Bomdarlos -

m Agregae Miity Poptlatos

t . Lakas and Rtnm

Wisconsin S

i Re- -ach

Nawmw Pt.

. 0 - S to Mee

£ - 6 -- *

6 6 12 t KoWs

Aggbugats Minoft Popuatio

Figure Geographic 4-1. Distribution of Minority Populations (Shown in Shaded IAreas)

Figur~e 4-1. Geographic Distribution of Minority Populations (Shown in Shaded Areas)

within 80 km (50 mi) of PBNP Based on Census Block Group Data(a)

(a) Note: Some of the census block groups extend into open water.

I

August 2005 4-41 NUREG-1437, Supplement 23
Environmental Impacts of Operation

4 0 4 a 12 15Mk

5 0 S 10 15 20 25 1

I Low4mcome Households

Figure Geographic 4-2. Distribution of Low-Income Populations (Shown in Shaded Areas)

I

Figure 4-2. Geographic Distribution of Low-Income Populations (Shown in Shaded Areas)

within 80 km (50 mi) of the PBNP Site Based on Census Block Group Data (a)

(a) Note: Some of the census block groups extend into open water.

NUREG-1 437, Supplement 23 4-42 August 2005

Il
Environmental Impacts of Operation

4.5 Groundwater Use and Quality

The Category 1 issue in 10 CFR Part 51, Subpart A; Appendix B, Table B-1, that is applicable

to PBNP groundwater use and quality is listed in Table 4-9. NMC stated in its ER that it is not

aware of any new and significant information associated with the renewal of the PBNP OLs

(NMC 2004a). The staff has not identified any new and significant information related to

groundwater use and quality resulting from operations at PBNP during its independent review of

the NMC ER (NMC 2004a), the staff's site visit, the scoping process, the staff's evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to this issue beyond those discussed in the GEIS.

For these issues, the GEIS concluded that the impacts would be SMALL; and additional

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

Table 4-9. Category 1 Issue Applicable to Groundwater Use and Quality during the

- Renewal Term

GEIS

ISSUE -10 CFR Part 51, Subpart A, Appendix B, Table B-i Sections

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and service water; plants that use <100 gpm). 4.8.1.1

A brief description of the staff's review and the GEIS conclusions, as codified in Table B-1,

10 CFR Part 51, follows.

* Groundwater use conflicts (potable and service water: plants that use <100 apm). Based

on information in the GEIS, the Commission found that

Plants using less than 100 gpm are not expected to cause any groundwateruse conflicts. -

As discussed in Section 2.2.2, PBNP groundwater use is less than 380 Umin (100 gpm).

WDNR has verified that currently there are no groundwater-related issues of concern to

WDNR at PBNP, and no discharges to groundwater from PBNP requiring permits by

regulatory agencies (WDNR 2005). The staff has not identified any new and significant

information during its independent review of the NMC ER, the staff's site visit, the scoping

process, the staff's evaluation of other available information, or public comments on the

draft SEIS. Therefore, the staff concludes that there would be no groundwater use conflicts

during the renewal term beyond those discussed in the GEIS.

Audust 2005 4-43 NUREG-1 437, Supplement 23
Environmental Impacts of Operation

There are no Category 2 issues related to groundwater use and quality for PBNP.

4.6 Threatened or Endangered Species

Threatened or endangered species are listed as a Category 2 issue in 10 CFR Part 51,

1 Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-10.

Table 4-10. Category 2 Issue Applicable to Threatened or Endangered Species during the

Renewal Term

ISSUE - 10 CFR Part 51, Subpart A, GEIS 10 CFR 51.53(c)(3)(ii) SEIS

Appendix B, Table B-1 Section Subparagraph 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 nuclear plant during the license renewal term. The presence of threatened or

endangered species in the vicinity of the PBNP site is discussed in Sections 2.2.5 and 2.2.6.

The staff initiated informal consultation with the FWS (NRC 2004a) and the National Marine

Fisheries Service of the National Oceanic and Atmospheric Administration (NRC 2004d) by

letter requesting information on species protected under the Endangered Species Act of 1973

(ESA) that occur in the vicinity of the PBNP site and its associated transmission line ROWs. No

response was received from the National Marine Fisheries Service; however, the FWS

responded by letter (FWS 2004) indicating no known occurrences of Federally listed threatened

or endangered species, proposed species, candidate species, or designated or proposed

critical habitats on the PBNP site. The FWS also noted that beach habitat near PBNP could be

suitable nesting habitat for piping plover (Charadrius melodus). The NRC staff identified three

other potentially occurring Federally listed species: the bald eagle (Haliaeetus leucocephalus),

the dune (or Pitcher's) thistle (Cirsium pitchen), and the dwarf lake iris (Ins lacustrs). Copies of

the consultation correspondence, including the FWS's approval of the staff's Biological

Assessment (BA) on May 5, 2005, are contained in Appendix E.

4.6.1 Aquatic Species

The staff has reviewed the information provided by the applicant and public information and has

contacted the FWS and the WDNR. No Federally listed threatened or endangered aquatic

species occur in Lake Michigan in the vicinity of the PBNP site (We Energies 2004b), and no

NUREG-1437, Supplement 23 4-44 August 2005

I n
Environmental Impacts of Operation

Federally listed threatened or endangered species occur in the streams crossing the

transmission line ROWs in the vicinity of the PBNP site. Therefore, license renewal would have

no effect on any Federally listed aquatic species. , -

4.6.2 Terrestrial Species

There are no Federally listed threatened or endangered terrestrial species known to occur at

the PBNP site or associated transmission line ROWs (NMC 2004a; We Energies 2004b).

There are four Federally listed threatened or endangered terrestrial species that have been

identified as potentially occurring in the vicinity of PBNP and its associated transmission line

ROWs. Three species have been recorded in Manitowoc County: the bald eagle, the piping '

plover, and the dune (or Pitcher's) thistle (WDNR 2004b). The dwarf lake iris, also a Federally '

listed species,' has been recorded in Brown County, which is traversed by'a PBNP transmission

line.

The staff has reviewed the information provided by the applicant, the FWS, WDNR, the scoping |

process, and public comments on the draft SEIS. - No Federally listed threatened or endangered .

terrestrial species have been reported to occur on the PBNP site or within the associated

transmission line ROWs. Four Federally listed terrestrial species have the potential to occur at |

the PBNP site or along associated transmission line ROWs. The staff has evaluated the

potential impact likely to result from operation of the PBNP foran additional 20 years during the

renewal term and has documented its conclusions in a biological assessment (BA) transmitted

to the FWS by letter dated November 22, 2004. A supplement to the BA was submitted on

April 21, 2005 (Appendix E), that included a detailed framework for piping plover monitoring and.-I

reporting. In a letter dated May 5, 2005 (FWS 2005), the FWS concurred with the staff's '

determination that the proposed action may affect but would not adversely affecththe piping l

plover, thus concluding consultations with the NRC under Section 7 of the ESA. The staff's

determination is that license renewal for the PBNP may affect, but is not likely to adversely I

affect, the bald eagle and the piping plover, and would have no effect on the dunre (or Pitcher's)

thistle or dwarf lake iris.' ''

4.6.3 Conclusions

Based on the discussion above, the staff concludes that the potential impacts of continued

operation'of the PBNP and its associated transmission line ROWs for an additional 20 years

during the renewal term on threatened or endangered species would be SMALL. During the

course of the staff's evaluation,' the staff considered mitigation measures for continued I

August 2005 4-45 NUREG-1437, Supplement 23
I rf

Environmental Impacts of Operation

operation of the PBNP. Based on this evaluation, the staff expects that measures in place at

the PBNP and its associated transmission line ROWs are appropriate (as described in the

amended BA submitted to the FWS [Appendix E]), and no additional mitigation measures are

warranted.

4.7 Evaluation of Potential New and Significant Information

on Impacts of Operations during the Renewal Term

The 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. The 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 operation during the renewal term. Processes for

identification and evaluation of new information are described in Section 1.2.2.

I 4.8 Cumulative Impacts of Operations during the Renewal

Term

The staff considered potential cumulative impacts during the evaluation of information

applicable to each of the potential impacts of operations of PBNP during the renewal term. The

impacts of the proposed license renewal are combined with other past, present, and reasonably

foreseeable actions to determine whether cumulative impacts exist. For the purposes of this

analysis, past actions were those related to the resources at the time of the plant licensing and

construction, present actions are those related to the resources at the time of current operation

of the power plant, and future actions are considered to be those that are reasonably

foreseeable through the end of plant operation. Therefore, the analysis considers potential

impacts through the end of the current license term, and through the 20-year license renewal

term. The geographical area to be evaluated over which past, present, and future actions that

could contribute to cumulative impacts would occur is dependent on the type of action

considered and is described below for each impact area.

The impacts of the proposed action, as described in Section 4, are combined with the impacts

of other past, present, and reasonably foreseeable future actions regardless of what agency

(Federal or non-Federal) or person undertakes such other actions. These 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

NUREG-1437, Supplement 23 4-46 August 2005

I I
Environmental Impacts of Operation,

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.

4.8.1 Cumulative Impacts Resulting from Operation of the Plant Cooling System

For the purposes of this analysis, the geographic'area considered for cumulative impacts

resulting from operation of the PBNP cooling system is primarily the western portion of Lake

Michigan within an'80-km (50-mi) radius of PBNP. As described in Section 4.1, the staff found

no new and significant information indicating that the conclusions regarding any of the

Category 1 issues related to the PBNP cooling system are inconsistent with the conclusions in

the GEIS (NRC'1996). Additionally, the staff has determined that none of the Category 2

issues related to the PBNP cooling system are likely to have greater than a SMALL impact on

local water quality or aquatic resources. -

Section 2.2.5 discusses the major changes and modifications within Lake Michigan that have

had the greatest impacts on aquatic resources . 'These include physical and'chemical stresses,

lakefront developments,' overfishing, and introduction of non-native species. The following

physical and chemical stresses have impacted Lake Michigan: urban, industrial, and

agricultural contaminants (e.g., nutrients, toxic chemicals, sediments); stream modifications

(e.g., dams); land-use changes (e.g., residential, recreational, agricultural,''and industrial

development); dredging; shoreline modifications; wetland elimination and modification; water

diversions (e.g., canals); impingement and entrainment in water-intake structures; thermal

loading from cooling water; ice control for navigation; and major degradative' incidents or

catastrophes (Francis et al. 1979; Fuller et al. 1995);: These, in turn, can affect fish, benthos,

and plankton populations; cause a loss of habitat; cause deformities'or tumors in fish and other'

biota; and contaminate fish, which' leads to restrictions on human consumption

(Eshenroder et al. 1995).

The dramatic changes to fish communities caused by habitat modification and development,

overf ishing, and non-native species introductions have been reviewed for the period from the

1 800s to 1970 (Wells and McLain 1973) and from 1970 to 2000 (Madenjian et al. 2002).

Disruptions in the native fish community (primarily caused by introduction of the sea lamprey

[Petromyzon marinus] and alewife [Alosa pseudoharengus]),'coupled with habitat alterations''

and degradation,'contributed to the decline of important commercial and sport fisheries by the

end of the 1950s. The alewife is believed to have 'contributed to thb extinction of three

deepwater cisco species (Coregonus spp.) and the suppression of burbot (Lota Iota), emerald

shiner (Notropis atherinoides), lake herring (Coregonus artedi), yellow perch (Perca

flavescens), deepwater sculpin (Myoxocephalus thomnpsoni), and spoonhead sculpin (Cottus

ricel). The alewife has recently been implicated as a possible factor inhibiting the success of

lake trout (Salvelinus namaycush) reproduction, as'alewives have been observed eating lake

August 2005 4-47 -- NUREG-1437, Supplement 23
Environmental Impacts of Operation

trout fry (Eshenroder et al. 1995). In the 1960s, programs to extend control of sea lamprey,

stocked trout, and salmon (Oncerhynchus) species began to rehabilitate the Lake Michigan fish

community, control alewife numbers, and provide recreational fisheries (Eshenroder et al.

1995).

Future contributions to cumulative impacts to aquatic resources within Lake Michigan would

generally occur from those actions that currently cause impacts (e.g., human habitation, urban

and industrial development, agriculture, commercial and recreational fisheries, and spread of

non-native species). The primary management challenges would be to keep the salmonid

community in balance with the available forage base, while keeping alewife levels suppressed

at a level that does not threaten native species (Eshenroder et al. 1995). Remaining problems

include inadequate natural reproduction of salmonids, low abundance or complete loss of many

native fish stocks, continued problems with exotic species, continued difficulties in suppressing

sea lampreys, and continued unacceptable levels of pollution and toxic chemicals

(Eshenroder et al. 1995).

The potential exists for severe impacts to aquatic resources from large oil or chemical spills

within Lake Michigan, but the risk of such spills is relatively small. The probability of smaller

spills is higher, but the impacts from such spills would probably be small, temporary, and

unlikely to severely affect aquatic resources, especially if spill response activities are

undertaken when such events occur.

The potential exists for the expansion of non-native species that have already begun to occur in

Lake Michigan, and for additional non-native species to become established within the lake

(Ricciardi and MacIsaac 2000; Ricciardi and Rasmussen 1998). Any future ecological changes

that may be associated with global climate change would occur much more slowly than those

induced by invasions of non-native species (Madenjian et al. 2002).

The lake water supply is adequate to meet the cooling-water needs of PBNP under all

conditions. As discussed in the NMC ER, KNPP is located on the western shore of Lake

Michigan in Kewaunee County, approximately 8 km (5 mi) north of the PBNP site. Studies

conducted of the hydrologic characteristics of this portion of Lake Michigan indicate that the

discharge heat of KNPP does not interact with the discharge heat of PBNP (Wisconsin Public

Service Corporation 1972). The staff, while preparing this assessment, assumed that other

industrial, commercial, or public installations could be located in the general vicinity of the

PBNP site prior to the end of PBNP operations. The discharge of water to Lake Michigan from

these facilities would be regulated by the WDNR. The discharge limits are set considering the

overall or cumulative impact of all of the other regulated activities in the area. Compliance with

the CWA and the WPDES permit minimizes PBNP's cumulative impacts on aquatic resources.

Continued operation of PBNP would require renewed discharge permits from the WDNR, which

would address cumulative water-quality objectives.

NUREG-1437, Supplement 23 4-48 August 2005
Environmental Impacts of Operation

The staff also considered cumulative impacts to threatened or endangered aquatic species. As

discussed in Section 2.2.5, there are no Federally listed threatened or endangered aquatic

species known to occur in the offshore areas associated with the PBNP site (NMC 2004a). 'For

these reasons, the staff has determined that the continued operation of PBNP would not

contribute to a regional cumulative impact to these species, regardless of whether other actions

occur that could have adverse impacts.

Therefore, the staff concludes that the SMALL impacts of PBNP cooling system operations,

including entrainment and impingement of fish and shellfish, heat shock, impacts on threatened

or endangered species, or any of the cooling system related Category 1 issues, are not

contributing to an overall decline in water quality, the status of the fishery, or other aquatic -

resources. Therefore, the staff concludes that the potential cumulative impacts of operation of -

the cooling system of PBNP would be SMALL and that no mitigation measures are warranted.

4.8.2 Cumulative Impacts Resulting from Continued Operation of the

Transmission Lines

The'continued operation of the electrical transmission facilities connecting PBNP to the -

transmission grid was evaluated to determine if there is the potential for interactions with other

past, present, and future actions that could result in adverse cumulative impacts. The staff

considered potential cumulative impacts to terrestrial resources. (such as wildlife populations

and the size and distribution of habitat areas), aquatic resources (such as wetlands, floodplains,

and stream-crossings), and both the acute and chronic effects of electromagnetic fields. For -

the purposes of this analysis, the geographic area that encompasses the past, present, and.

foreseeable future actions that could contribute to adverse cumulative effects is the area that

contains the transmission lines associated with the PBNP site. As described in Section 4.2, the

staff found no new and significant information indicating that the conclusions regarding any of

the Category 1 issues related to the PBNP transmission lines are inconsistent with the

conclusions in the GEIS.

As discussed in Section 4.6, ATC implements a ROW inspection and maintenance'program for,

transmission lines associated with PBNP using vegetation management procedures that are'

protective of wildlife and habitat resources over all of its ROWs (ATC 2004). -None of the

management procedures are expected to alter wetland or floodplain hydrology or adversely

affect vegetation characteristics of these or other habitats.' The ATC maintenance procedures

also ensure minimal disturbance to wildlife. Continued operation and maintenance of these

ROWs are not likely to contribute to a regional decline in wildlife and habitat resources during

the license renewal term.

August 2005 4-49 NUREG-1437, Supplement 23
Environmental Impacts of Operation

There are no known or planned activities within the 80-km (50-mi) radius area of consideration

that could potentially produce additional impacts associated with transmission lines. Therefore,

the staff has determined that the cumulative impacts of the continued operation of the PBNP

transmission lines would be SMALL, and that no mitigation measures are warranted.

4.8.3 Cumulative Radiological Impacts

The EPA and NRC established radiological dose limits for protection of the public and workers

from both acute and long-term exposure to radiation and radioactive materials. These dose

limits are codified in 40 CFR Part 190 and 10 CFR Part 20. As described in Section 2.2.7, the

public and occupational doses resulting from operation of PBNP are well below regulatory

limits, and as described in Section 4.3, the impacts of these exposures would be SMALL. For

the purposes of this analysis, the geographical area considered is the area included within an

80-km (50-mi) radius of the PBNP site (Figure 2-1).

EPA regulations at 40 CFR Part 190 limit the dose to members of the public from all sources in

the nuclear fuel cycle, including nuclear power plants, fuel fabrication facilities, waste disposal

facilities, and transportation of fuel and waste. In addition, as stated in Section 2.2.7, NMC has

conducted a radiological environmental monitoring program around the PBNP site since before

operations began in 1970. This program measures radiation and radioactive materials from all

sources, including PBNP.

NMC also conducts a radiological environmental monitoring program on and in the vicinity of

KNPP, which is located on the western shore of Lake Michigan in Kewaunee County,

approximately 8 km (5 mi) north of the PBNP site. Radionuclide concentrations from the

environmental monitoring program are compared to levels measured at control locations and in

preoperational studies, and any influence of KNPP on PBNP doses (and vice versa) is taken

into account.

The NRC would regulate any future actions associated with PBNP that could contribute to

cumulative radiological impacts. Therefore, the staff has determined that the cumulative

radiological impacts of continued operation of PBNP would be SMALL and that additional

mitigation is not warranted.

4.8.4 Cumulative Socioeconomic Impacts

The continued operation of PBNP is not likely to result in significant cumulative impacts for any

of the socioeconomic impact measures assessed in Section 4.4 (public services, housing, and

offsite land use) because operating expenditures, staffing levels, and local tax payments during

NUREG-1437, Supplement 23 4-50 August 2005

I
Environmental Impacts of Operation

renewal would be similar to those during the current license period. Similarly, the proposed

action is not likely to result in significant cumulative impacts on historic and archaeological

resources.

When combined with the impact of other potential activities likely in the area surrounding the

PBNP site, socioeconomic impacts resulting from PBNP license renewal would not produce an

incremental change in any of the impacts identified. The staff therefore determined that the

impacts on employment, personal income, housing, local public services, utilities, and education

occurring in the local socioeconomic environment as a result of license renewal activities, in

addition to the impacts of other potential economic activity in the area, would be SMALL.

The staff determined that the impact on offsite land use would be SMALL because no

refurbishment activities are planned at PBNP, and no new incremental sources of or changes to

plant related tax payments are expected that could influence land use by fostering considerable

growth. The impacts of license renewal on transportation and environmental justice would also

be SMALL. The staff identified the locations of minority and low-income populations, and

evaluated whether any of the environmental impacts of the proposed action could affect these

populations in a disproportionately high and adverse manner. Based on staff guidance

(NRC 2004c), air, land, and water resources within approximately 80 km (50 mi) of the PBNP

site were examined. Within that area, a few potential environmental impacts could affect

human populations, but all of these impacts were considered to be SMALL for the general

population. There are no reasonably foreseeable scenarios that would alter these conclusions

in regard to cumulative impacts.

Based on the archaeological surveys conducted to date at the PBNP site (discussed in

Section 4.4.5) and the very small likelihood that significant undiscovered cultural resources exist

within the site boundaries, it does not appear that the proposed license renewal would

adversely affect these resources. The applicant has indicated that no refurbishment or

replacement activities, including additional ground-disturbing activities, at the plant site (or

along existing transmission line ROWs) are planned for the license renewal period.

(NMC 2004a). Therefore, continued operation of PBNP would likely protect any cultural

resources present within the PBNP site boundary by protecting those lands from development

and providing secured access. Prior to ground-disturbing activity in an undisturbed area, the

applicant evaluates the potential for impacts to cultural resources, in consultation with the

SHPO and appropriate Native American tribes as required under Section 106 of the NHPA.

The staff therefore determined that the contribution to a cumulative impact on cultural resources

by continued operation of PBNP during the license renewal period is considered to be SMALL.

Therefore, the staff has determined that the cumulative socioeconomic impacts of continued

operation of PBNP would be SMALL and that additional mitigation is not warranted.

August 2005 4-51 NUREG-1 437, Supplement 23
I Ir1

Environmental Impacts of Operation

4.8.5 Cumulative Impacts on Groundwater Use and Quality

As discussed in Section 2.2.2, water for drinking and sanitary purposes at PBNP is withdrawn

from groundwater by five active onsite domestic supply wells having an average flow rate of

about 24 Umin (6.5 gpm), or 35,000 L/day (9300 gpd). PBNP groundwater use is not expected

to increase significantly during the license renewal period.

As discussed in Section 4.5, the impact of current plant operations and groundwater

withdrawals on the aquifer is considered to be SMALL and the staff did not identify any new and

significant information to indicate the possibility of groundwater use conflicts during the renewal

term beyond those discussed in the GEIS. There are no known current or planned projects

requiring groundwater withdrawals in the vicinity of PBNP that, if implemented in addition to

license renewal, would potentially cause an adverse impact on groundwater use and quality.

Therefore, the staff has determined that the cumulative impacts of continued operation of

PBNP on groundwater use and quality during the license renewal period would be SMALL and

that no mitigation measures are warranted.

4.8.6 Conclusions Regarding Cumulative Impacts

The staff considered the potential impacts resulting from operation of PBNP during the license

renewal term and other past, present, and future actions in the vicinity of PBNP. For each

impact area, the staff has determined that the potential cumulative impacts resulting from PBNP

operation during the license renewal term would be SMALL and mitigation is not warranted.

i 4.9 Summary of Impacts of Operations during the

Renewal Term

Neither NMC nor the staff is aware of information that is both new and significant related to any

of the applicable Category 1 issues associated with the PBNP operation during the renewal

term. Consequently, the staff concludes that the 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 10 Category 2 issues applicable to

PBNP operation during the renewal term and for environmental justice and chronic effects of

electromagnetic fields. For all 10 issues and environmental justice, the staff has concluded that

the potential environmental impact of renewal term operations of PBNP would be of SMALL

significance in the context of the standards set forth in the GEIS and that additional mitigation

NUREG-1437, Supplement 23 4-52 August 2005

I I:
Environmental Impacts of Operation

would not be warranted. In addition, the staff has determined that a consensus has not been;

reached by appropriate Federal health agencies regarding chronic adverse effects from

electromagnetic fields. Therefore, the staff did not evaluate this issue further. Finally, the staff

has considered potential cumulative impacts resulting from PBNP operation during the license

renewal term and has determined that the cumulative impacts of continued operation of PBNP

during the license renewal term would be SMALL.'

4.10 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for

Protection Against Radiation."

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,

Part 800, "Protection of Historic and Cultural Resources."

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

1508, 'Terminology and Index."

American Transmission Company (ATC). ATC Operating Instruction: Vegetation Management

Philosophy and Standards. May 1, 2004.

Bronte, C. R., and P. A. Schuette. 2002. Summary of Trout and Salmon Stocking in Lake

Michigan 1976-2001. Great Lakes Fishery Commission, Lake Michigan Committee Meeting,

Duluth, Minnesota. March 21-22, 2002.

Clean Water Act of 1977 (CWA). 33 USC 1326 et seq. (common name of the Federal Water

Pollution Control Act of 1977).

Council on Environmental Quality (CEQ). 1997. Environmental Justice: Guidance Under the

National Environmental Policy Act. Executive Office of the President, Washington, D.C.

August 2005 4-53 NUREG-1437, Supplement 23
Environmental Impacts of Operation

Department of Fisheries and Oceans Canada (DFO). 2004. 'The Alewife." Department of

Fisheries and Oceans Canada, Ottawa, Ontario, Canada.

http://www.dfo-mpo-gc.ca/zone/underwater-sous-marin/gasparealalewife-gaspareaue.htm

(Accessed July 14, 2004).

Dunning, D. J., Q. E. Ross, P. Geoghegan, J. J. Reichle, J. K. Menezes, and J. K. Watson.

1992. "Alewives Avoid High-Frequency Sound." North American Journal of Fisheries

Management, Vol. 12, pp. 407-416.

Eggold, B. 2004. Sportfishing Effort and Harvest. Lake Michigan Management Reports.

Wisconsin Department of Natural Resources, Milwaukee, Wisconsin.

http://www.dnr.stste.wi.us/org/water/fhp/fish/akemich/Great%2OLakes%Fishery%20Commissio

n%20Report%/202004.pdf (Accessed November 11, 2004).

Endangered Species Act of 1973 (ESA). 16 USC 1531, et seq.

Electric Power Research Institute. 1992. TL Workstation Code Version 2.3, Volume 7:

ACDCLINE Manual. EPRI EL-6420. June 1992.

Eshenroder, R. L., M. E. Holey, T. K. Gorenflo, and R. D. Clark, Jr. 1995. Fish-Community

Objectives for Lake Michigan. Great Lakes Fishery Commission Spec. Pub. 95-3.

http://www.glfc.org/pubs/SpecialPubs/Sp95_3.pdf (Accessed January 25, 2004).

Executive Order 12898. "Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations." Federal Register, Vol. 59, No. 32, Washington,

D.C. February 16, 1994.

Francis, G. R., J. J. Magnuson, H. A. Regier, and D. R. Talhelm. 1979. Rehabilitating Great

Lakes Ecosystems. Great Lakes Fishery Commission Tech. Report No. 37.

http://www.glfc.org/pubs1TechReportsTr37.pdf (Accessed April 27, 2004).

Fuller, K., H. Shear, and J. Witting, eds. 1995. The Great Lakes - an Environmental Atlas and

Resource Book. Government of Canada and U.S. Environmental Protection Agency.

http://www.epa.gov/ginpo/atlas/index.html (Accessed February 25, 2004).

Hogler, S., and S. Surendonk. 2004. Smelt Withdrawal By the Commercial Trawl Fishery.

Lake Michigan Management Reports. Wisconsin Department of Natural Resources, Mishicot,

Wisconsin.

http://www.dnr.stste.wi.us/org/water/fhp/fish/lakemich/Great%2OLakes%Fishery%2OCommissio

n%20Report%202004.pdf (Accessed November 11,2004).

NUREG-1437, Supplement 23 4-54 August 2005

Il
Environmental Impacts of Operation* -

Jude, D. J. 1995. Impact on Aquatic Organisms of Increased Heat Input to the Thermal

Discharge of the Donald C. Cook Nuclear Plant, Southeastern Michigan.' Center for Great

Lakes and Aquatic Sciences, University of Michigan, Ann Arbor, Michigan. December 1995.

LaJeone, L.J., and R. G. Monzingo. 2000. "316(b) and Quad Cities Station,'Commonwealth

Edison Company." Environmental Science & Policy. Vol. 3, Suppl. 1, pp. 313-322.

Madenjian, C. P., G. L. Fahnenstiel, T. H. Johengen, T.'F. Nalepa, H. A. Vanderploeg,

G. W. Fleischer, P. J. Schneeberger, D. M. Benjamin, E. B. Smith, J. R. Bence,

E. S. Rutherford,- D. S. Lavis, D. M. Robertson, D. J. Jude, and M. P. Ebener. '2002.

uDynamics of the Lake Michigan Food Web, 1970-2000." Canadian Journal of Fisheries and

Aquatic Sciences, Vol. 59, pp. 736-753.

Madenjian, C.P., TAJ. Desorcie, and J.D. Holuszko. 2004; Status and Trends of Prey.

Populations in Lake Michigan, 2003. Great Lakes Fishery Commission, Lake Michigan'

Committee Meeting, Ypsilanti, Michigan. March 24, 2004.

Maes, J., A. W. H. Turnpenny, D. R. Lambert, J. R. Nedwell, A' Parmentier,- and F. Ollevier.

2004. "Field Evaluation of a Sound System to Reduce Estuarine Fish Intake Rates at a Power

Plant Cooling Water Inlet." Joumal of Fish Biology, Vol. 64, pp. 938-946.

National Electrical Safety Code (NESC). 1997. Institute of Electrical and Electric Engineers.

New York, New York.

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

National Historic Preservation Act of 1966 (NHPA). 16 USC 470 et seq.

National Institute of Environmental Health Sciences (NIEHS). 1999. NIESH Report on Health

Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields. Publication

No. 99-4493. Research Triangle Park, North Carolina.

NatureServe. 2004.- NatureServe Explorer: an Online Encyclopedia of Life. Version 3.1,

NatureServe,-Arlington, Virginia. http://www.natureserve.org (Accessed November 9, 2004).

Noguchi, L. S., D. L. Bimber, H. T. Tin, P. J. Mansfield, and D. J. Jude. 1985. "Field

Distribution and Entrainment of Fish Larvae and Eggs at the Donald C.--Cook Nuclear Power

Plant, Southeastern Lake Michigan, 1980-1982." Special Report No. 116 of the Great Lakes

Research Division. Great Lakes and Marine Waters Center, The University of Michigan, AnnArbor, Michigan.

August 2005 4-55 NUREG-1437, Supplement 23
Environmental Impacts of Operation

Nuclear Management Company, LLC (NMC). 2001. Letter from A. Cayia, Site Vice President,

to E. Spoon, Special Agent, U.S. Fish and Wildlife Service. No Subject. July 19, 2001.

Nuclear Management Company, LLC (NMC). 2002. Letter from A. Cayia, Site Vice President,

to E. Spoon, Special Agent, U.S. Fish and Wildlife Service. Subject: "Point Beach Nuclear

Plant Fish and Bird Report for June 1, 2001, through December 31, 2001." January 14, 2002.

Nuclear Management Company, LLC (NMC). 2003a. Letter from A. Cayia, Site Vice President,

to E. Spoon, Special Agent, U.S. Fish and Wildlife Service. Subject: uPoint Beach Nuclear

Plant Fish and Bird Report for January 1,2002, through December 31, 2002." January 14,

2003.

Nuclear Management Company, LLC (NMC). 2003b. Letter from A. J. Cayia, Site Vice

President, Point Beach Nuclear Plant, to S. Banker, State Historical Society of Wisconsin.

Subject: "License Renewal Application for Point Beach Nuclear Plant, Request for Information

on HistoricaVArcheological Resources." December 22, 2003.

Nuclear Management Company, LLC (NMC). 2004a. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

Nuclear Management Company, LLC (NMC). 2004b. Letter from A. Cayia, Site Vice President,

to E. Spoon, Special Agent, U.S. Fish and Wildlife Service. Subject: "Point Beach Nuclear

Plant Fish and Bird Report for January 1, 2003, through December 31, 2003." January 15,

2004.

Nuclear Management Company, LLC (NMC). 2004c. Letter from G. D. Van Middlesworth, Site

Vice President, Point Beach Nuclear Plant, to R. Dexter, State Historical Society of Wisconsin.

Subject: "Case# 03-1046 License Renewal: Point Beach Nuclear Plant." March 2, 2004.

Ricciardi, A., and H. J. MacIsaac. 2000. "Recent Mass Invasion of the North American Great

Lakes by Ponto-Caspian Species." Trends in Ecology & Evolution, Vol. 15, pp. 62-65.

Ricciardi, A., and J. B. Rasmussen. 1998. "Predicting the Identity and Impact of Future

Biological Invaders: A Priority for Aquatic Resource Management." Canadian Journal of

Fisheries and Aquatic Sciences, Vol. 55, pp. 1759-1765.

Ross, Q. E., D. J. Dunning, R. Thorne, J. K. Menezes, G. W. Tiller, and J. K. Watson. 1993.

"Response of Alewives to High-Frequency Sound at a Power Plant Intake on Lake Ontario."

North American Journal of Fisheries Management, Vol. 13, pp. 291-303.

NUREG-1437, Supplement 23 4-56 August 2005

I 1
Environmental Impacts of Operation

Ross, 0. E., D. J. Dunning, J. K. Menezes, M. K. Kenna, Jr., and G. Tiller. 1996. "Reducing

Impingement of Alewives with High-Frequency Sound at a Power Plant Intake on Lake Ontario."

North American Joumal of Fisheries Management, Vol. 16, pp. 291-303.

Scott, W. B., and E. J. Crossman. 1973. Freshwater Fishes of Canada. Bulletin 184.

Fisheries Research Board of Canada, Ottawa.

Talmage, S. S., and D. M. Opresko. 1981. Literature Review: Response of Fish to Thermal

Discharges. EPRI EA-1 840, Research Project 877, ORNUEIS-1 93. Prepared by Oak Ridge

National Laboratory, Oak Ridge, Tennessee for Electric Power Research Institute, Palo Alto,

California.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Point Beach Nuclear Plant Units 1 and2. 'Docket Nos. 50-266 and 50-301.

Directorate of Licensing, Washington, D.C. - - -

U.S. Census Bureau (USCB). 2000a. County and City Data Book: 2000, Table C-1.

http://www.census.gov/statab/www/ccdb.html (Accessed July 30, 2004).

U.S. Census Bureau (USCB). 2000b. Profile of selected economic characteristics: -2000 for

Wisconsin, http://factfinder.census.gov/servlet/QTTable?-bm=y&-context=qt&-

reg=DECL2000_SF4_UDP3:001&-qr_name=DEC_2000_SF4_U_DP3&--

dsname=DEC_2000_SF4_U&-CONTEXT=qt&-tree id=404&-all-geo-types=N&-

redoLog=true&-geo, id=04000US55&-format=& -ang-en (Accessed Novermber 1, 2004).

U.S. Census Bureau (USCB). 2001. -Decennial Division Management Glossary.

http//www.census.gov/dmd/www/glossary.html (Accessed July 26, 2004). -

U.S. Department of the Interior (DOI). 2005. Letter from Mr. Michael T. Chezik,

U.S. Department of the Interior, to Nuclear Regulatory Commission. April 7, 2005.

U.S. Environmental Protection Agency (EPA). '2004. "National Pollutant Discharge Elimination -

System - Final Regulations to Establish Requirements for. Cooling Water Intake Structures'at ;

Phase II Existing Facilities: Final Rule." Federal Register, Vol. 69, No. 131, pp. 41575-41693.

Washington, D.C. 4uly9, 2004.' ;

U.S. Fish and Wildlife Service (FWS). 2004. Letter from J. Smith, U.S. Fish and Wildlife

Service, to Nuclear Regulatory Commission. Subject: "Response to the May 5, 2004, NRC

Staff Letter Requesting Information Regarding Threatened and Endangered Species in the

Vicinity of the PBNP." -August 5, 2004.

August 2005 4-57 NUREG-1437, Supplement 23
Environmental Impacts of Operation

U.S. Fish and Wildlife Service (FWS). 2005. Letter from J. Smith, U.S. Fish and Wildlife

Service, to Nuclear Regulatory Commission. Subject: "Biological Assessment, License

Renewal, Point Beach Nuclear Plant, Units 1 and 2, Manitowoc County, Wisconsin." May 5,

2005.

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

for License Renewal of Nuclear Plants. NUREG-1 437, 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). 2004a. Letter from NRC to J. Smith, U.S. Fish

and Wildlife Service. Subject: "Request List of Protected Species Within the Area under

Evaluation for License Renewal of Point Beach Nuclear Plant." Accession No. ML041280306.

May 5, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004b. Geographic, Environmental, and Siting

Information System (GEn&SIS). http://gensis.llnl.gov/ (Accessed November 3, 2004).

U.S. Nuclear Regulatory Commission (NRC). 2004c. Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues. NRC Office of Nuclear

Reactor Regulation, NRR Office Instruction LIC-203 Revision 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004d. Letter from NRC to P. A. Kurkul, National

Oceanic and Atmospheric Administration Fisheries. Subject: "Request for List of Protected

Species Within the Area under Evaluation for License Renewal of Point Beach Nuclear Plant

Units 1 and 2." Accession No. ML041330494. May 12,2004.

U.S. Nuclear Regulatory Commission (NRC). 2004e. "Policy Statement on the Treatment of

Environmental Justice Matters in NRC Regulatory and Licensing Actions." Federal Register,

Vol. 69, No. 163, pp. 52040-52048, Washington, D.C. August 24, 2004.

We Energies. 2004a. Letter from S. Schumacher, Environmental Specialist/Ecologist, to

R. Dexter, Wisconsin Historical Society. Subject: "License Renewal for the Point Beach

Nuclear Plant - Review of Agricultural Lands Owned by We Energies." October 11, 2004.

We Energies. 2004b. Letter from N. J. Cutright, Senior Terrestrial Ecologist, to Nuclear

Management Company. Subject: "Response to U.S. Fish and Wildlife Service Letter."

May 12, 2004.

NUREG-1437, Supplement 23 4-58 August 2005

I Il
Environmental Impacts of Operation --

We Energies 2004c. Letter from S. Schumacher, Environmental Specialist, to J. DeRose,

Wisconsin Historical Society. Subject: "Determination of Eligibility of the Biel Fishing Shed

Located on the Point Beach Nuclear Power Plant Property, Two Rivers, Manitowoc."

September 1, 2004.

Wei, A., P. Chow-Fraser, and D. Albert. 2004. "Influence of Shoreline Features on Fish

Distribution in the Laurentian Great Lakes." Canadian Journal of Fisheries andAquatic

Sciences, Vol. 61, pp. 1113-1123.

Wells, L., and A. L. McLain. 1973. "Lake Michigan: Man's Effects on Native Fish Stocks and

Other Biota." Technical Report No. 20. Great Lakes Fishery Commission, Ann Arbor,

Michigan. http://www.glfc.org/pubslTechReports/Tr2O.pdf (Accessed April 26, 2004).

White, A. M., l. Hlohowskyj, and D. M. Loucks. 1987. The Condition of Fishes Impinged at the

Cleveland Electric Illuminating Company Eastlake and Avon Lake Plants Excluding the Gizzard

Shad. Report 78. Prepared by Environmental Resource Associates, University Heights, Ohio

for The Centerior Energy Corp., Independence, Ohio. May 1987.

Wisconsin Department of Natural Resources (WDNR). 1978. Letter from T. A. Kroehn,

Administrator, Wisconsin Department of Natural Resources, to N. A. Ricci, Senior Vice

President Wisconsin Electric Power Company. Subject: "Regarding Cooling Water Intake

Structure Final Report."

Wisconsin Department of Natural Resources (WDNR). 2004a. WPDES Permit, effective

July 1, 2004. WI-0000957-07-0. Madison, Wisconsin. July 1, 2004.

Wisconsin Department of Natural Resources (WDNR). 2004b. Wisconsin State Threatened

and Endangered Species website.

http:/lwww.dnr.state.wi.us/org/land/er/working-list/taxalistslTandE.asp (Accessed May 5, 2004).

Wisconsin Department of Natural Resources (WDNR). 2005. Email correspondence from

P. Luebke to S. Imboden, NRC, regarding onsite settling pond at PBNP. May 25, 2005.

Wisconsin Electric Power Company (WEPCO) and Wisconsin Michigan Power Company.

1971. Supplement to Applicants' Environmental Report Operating License Stage Point Beach

Nuclear Plant 2. U.S. Atomic Energy Commission, Docket No. 503-01. Milwaukee, Wisconsin.

November 1971.

August 2005 4-59 NUREG-1437, Supplement 23
Environmental Impacts of Operation

Wisconsin Electric Power Company (WEPCO). 1976. Point Beach Nuclear Plant Final Report

on Intake Monitoring Studies Performed by Wisconsin Electric Power Company in Fulfillment of

Condition of Wisconsin Pollution Discharge Elimination System Permit. No. WI-0000957,

Milwaukee, Wisconsin. June 1, 1976.

Wisconsin Electric Power Company (WEPCO). 2000. Evaluation of Alternative Intake Designs

to Prevent the Entry of Cormorants, Point Beach Nuclear Plant. Prepared for Wisconsin

Electric Power Company by Alden Research Laboratory, Inc. Milwaukee, Wisconsin.

Wisconsin Historical Society. 2004. Letter from S. Banker, Office of Preservation Planning, to

R. Newton, Point Beach Nuclear Plant. Subject: "SHWS #03-1046/MN Re: License Renewal:

Point Beach Nuclear Plant." March 11, 2004.

Wisconsin Public Service Corporation. 1972. Kewaunee Nuclear Power Plant Environmental

Report: Operating License Stage. Green Bay, Wisconsin. December 1972.

NUREG-1437, Supplement 23 4-60 August 2005

Il
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-1 437,

Volumes 1 and 2 (NRC 1996, 1999).(a) 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). 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 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.

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

references to the 'GElS" include the GElS and its Addendum 1.

August 2005 5-1 NUREG-1437, Supplement 23
Environmental Impacts of Postulated Accidents

5.1.1 Design-Basis Accidents

In order to receive NRC approval to operate a nuclear power facility, an applicant for an initial

operating license 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.

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 of the Code of Federal Regulations

(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 operating licenses (OLs). The results of these evaluations are found in license

documentation such as the applicant's final safety analysis report (FSAR), the 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

maximum 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,

NUREG-1437, Supplement 23 5-2 August 2005

I I
Environmental Imnpacts of Postulated Accidents

under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This

issue, applicable to Point Beach Nuclear Plant Units 1 and 2 (PBNP), is listed in Table 5-1.

Table 5-1. Category 1 Issue Applicable to Postulated Accidents during the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

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. - .

Nuclear Management Company, LLC (NMC) stated in its Environmental Report (ER)

(NMC 2004) that it is not aware of any new and significant information associated with the

renewal of the PBNP OLs. The staff has not identified any new and significant information

during its independent review of the NMC ER (NMC 2004), the staff's site visit, the scoping

process, the staff's evaluation of other available information, and public comments on the draft

SEIS. Therefore, the 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, whether or not there are serious offsite

consequences.- In the GEIS, the staff assessed the impacts of severe accidents during the

license renewal period, 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 tomadoes, floods, earthquakes,

fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and

were not specifically considered for the PBNP site in the GEIS (NRC 1996). However, in the

GEIS the 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 sabotage

and beyond design basis earthquakes at existing nuclear power plants is SMALL. Additionally,

the staff concluded that the risks from other external events are adequately addressed by a

generic consideration of internally initiated severe accidents.

August 2005 5-3 NUREG-1 437, Supplement 23
I Mi

Environmental Impacts of Postulated Accidents

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 PBNP, is

listed in Table 5-2.

Table 5-2. Category 2 Issue Applicable to Postulated Accidents during the Renewal Term

ISSUE-10 CFR Part 51, Subpart 10 CFR 51.53(c)(3)(i) SEIS

A, Appendix B, Table B-1 GEIS Sections Subparagraph Section

Postulated Accidents

Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3; L 5.2

5.3.3.4; 5.3.3.5; 5.3.4;

5.4; 5.5.2

I

The staff has not identified any new and significant information with regard to the

consequences from severe accidents during its independent review of the NMC ER (NMC

2004), the staff's site visit, the scoping process, the staff's evaluation of other available

information, and public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of severe accidents beyond those discussed in the GEIS. However, in

accordance with 10 CFR 51.53(c)(3)(ii)(L), the staff has reviewed severe accident mitigation

alternatives (SAMAs) for PBNP. The results of its review are discussed in Section 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 PBNP; therefore,

the remainder of Chapter 5 addresses those alternatives.

NUREG-1437, Supplement 23 5-4 August 2005

I I
Environmental Impacts of Postulated Accidents

5.2.1 Introduction

This section presents a summary of the SAMA evaluation for PBNP conducted by NMC and

described in the ER and the NRC's review of those evaluations. The details-of the review are

described in the NRC staff evaluations that were prepared with contract assistance from Pacific

Northwest National Laboratory. The'entire evaluation is presented in Appendix G.

The SAMA evaluations for PBNP were conducted with a'four-step approach. In the first step

NMC quantified the level of risk associated with potential reactor accidents using the

plant-specific probabilistic risk assessment -(PRA) and other risk models. -

In the second step NMC 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. NMC initially identified 202 potential SAMAs. NMC

screened out SAMAs that were not applicable to PBNP or had already been implemented at

PBNP (or the PBNP design met the intent of the SAMA). This screening reduced the list of

potential SAMAs to 65.

In the third step NMC 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). NMC concluded that none of these

65 SAMAs would be cost-beneficial for PBNP (NMC 2004). However, the staff has concluded

that one of the SAMAs may be cost-beneficial.

This SAMA does not relate to adequately managing the effects of aging during the period of

extended operation; therefore, it need not be implemented as part of license renewal pursuant

to 10 CFR Part 54. NMC's SAMA analysis and the NRC's review are discussed in more detail

below.

5.2.2 Estimate of Risk

NMC submitted an assessment of SAMAs for PBNP as part of the ER (NMC 2004). This

assessment was based on the most recent PBNP PRA available at that time, a plant-specific

offsite consequence analysis performed using the MELCOR Accident Consequence Code

August 2005 5-5 NUREG-1437, Supplement 23'
Environmental Impacts of Postulated Accidents

System 2 (MACCS2) computer program, and insights from the PBNP Individual Plant

Examination (IPE) (WEPCO 1993) and IPE of External Events (IPEEE) (WEPCO 1995).

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 3.59 x 1 0-5 per year. This CDF is based on the risk assessment for internally

initiated events. NMC did not include the contribution to risk from external events within the

PBNP risk estimates; however, it did account for the potential risk reduction benefits associated

with external events by increasing the estimated benefits by an amount equal to the ratio of the

sum of the internal and external event CDF to the internal event CDF. This ratio is

approximately two. The breakdown of CDF by initiating event is provided in Table 5-3.

As shown in Table 5-3, steam generator tube rupture (SGTR) events, transients without the

power conversion system (PCS) available, loss of component cooling water, and loss of offsite

power are dominant contributors to the CDF.

Table 5-3. Core Damage Frequency

Initiating Event CDF Percent

(per year) Contribution

SGTR 8.75 x 10.6 24.4

Transient without PCS 6.40 x 10.6 17.8

Loss of component cooling 4.39 x 10.6 12.2

Loss of offsite power (dual unit) 4.13 x 10-6 11.5

Steam/feed break inside containment 2.76 x 10-6 7.7

Loss of service water 2.43 x 10.6 6.8

Steam/feed break outside containment 1.90 x 10.6 5.3

Medium loss-of-coolant accident (LOCA) (>2 to 6 in.) 1.80 x 10.8 5.0

Excessive LOCA (vessel failure) 9.90 x 10'7 2.8

Transient with PCS 6.84 x 10 ' 1.9

Station blackout (SBO) 4.41 x 10'7 1.2

Small LOCA (3/8 to 2 in.) 3.77 x 10'7 1.1

Loss of bus D-01 2.76 x 107 0.8

Loss of instrument air 2.27 x 10'7 0.6

Large LOCA (>6 in.) 1.39 x 10' 7 0.4

Interfacing systems LOCA (ISLOCA) 1.10 x 107 0.3

Loss of bus 0-02 6.74 x 108 0.2

Total CDF (from internal events) 3.59 x 105 100

NUREG-1 437, Supplement 23 5-6 August 2005
Environmental Impacts of Postulated Accidents

NMC estimated the dose to the population within 80 km (50 mi) of the PBNP site from severe

accidents to be approximately 0.0149 person-Sv (1.49 person-rem) per year. The breakdown

of the total population dose by containment release mode is summarized in Table 5-4. SGTR

events dominate the population dose risk.

The NRC staff has reviewed NMC'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 NMC.

Table 5-4. Breakdown of Population Dose by Containment Release Mode

Population Dose Percent Contribution

Containment Release Mode (Person-Rem' per Year)

Late SGTR 1.09 x 10° 73 -

Early SGTR 1.65x10-1 11

Containment Isolation failure 8.49 x 1 04 <0 .1

ISLOCA -1.24 x 10-'- 8

Other Core Melt Sequences' 1.04 x 10' 7

Total Population Dose 1.49 x 100 100

'One person-rem = 0.01 person-Sv

5.2.3 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, NMC 'searched for ways to reduce

that risk. In identifying and evaluating potential SAMAs, NMC considered insights from the

plant-specific PRA, as well as industry and NRC documents that discuss potential plant

improvements, such as NUREG/CR-5630 (NRC 1991). NMC identified 202 potential

risk-reducing iniprbveents (SAMAs) to plant components, systems, procedures and training.

All but 65 of the SAMAs were removed from further consideration because they were not

applicable to PBNP, or they had already been implemented at PBNP (or the' PBNP design met:

the intent of the SAMA).

The staff concludes that NMC used a systematic and comprehensive'process for identifying

potential plant im'provements for PBNP, and that the set of potential plant improvements

identified by NMC is reasonably comprehensive and, therefore, acceptable.

August 2005 5-7 NUREG-1437, Supplement 23
- I r M

Environmental Impacts of Postulated Accidents

5.2.4 Evaluation of Risk Reduction and Costs of Improvements

NMC evaluated the risk-reduction potential of the remaining 65 SAMAs that were applicable to

PBNP. A majority of the SAMA evaluations were performed in a bounding fashion in that the

SAMA was assumed to completely eliminate the risk associated with the proposed

enhancement. Such bounding calculations overestimate the benefit of the risk reduction and

are conservative. The benefits were increased by a factor of approximately two to account for

benefits in external events.

NMC estimated the cost of implementing the 65 SAMAs through consideration of estimates

from other licensee submittals for similar improvements and site-specific cost estimates. For

some of the SAMAs considered, the cost estimates were sufficiently greater than the benefits

calculated that it was not necessary to perform a detailed cost estimate. Cost estimates

typically included procedures, engineering analysis, training, and documentation, in addition to

any hardware.

The staff has reviewed NMC's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the staff based its estimates of averted risk for the

various SAMAs on NMC's risk reduction estimates.

The staff has reviewed the bases for the applicant's cost estimates. For certain improvements,

the staff has 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 has found the cost estimates to

be reasonable and generally consistent with estimates provided in support of other plants'

analyses.

The staff concludes that the risk reduction and the cost estimates provided by NMC are

sufficient and adequate for use in the SAMA evaluation.

5.2.5 Cost-Benefit Comparison

The cost-benefit analysis performed by NMC was based primarily on NUREG/BR-0184

(NRC 1997) and was executed consistent with this guidance. Sensitivity calculations were

performed to examine the potential impact of uncertainties, discount rates other than seven

percent, and several parameters and assumptions involved in the severe accident dose

calculations. As a result of this analysis, the cost-benefit analysis showed that none of the

candidate SAMAs were cost-beneficial. Therefore, NMC's conclusion was that there were no

cost-beneficial SAMAs.

NUREG-1437, Supplement 23 5-8 August 2005

I I
Environmental Impacts of Postulated Accidents

The staff has reviewed NMC's calculation methods and assumptions and concluded that they

were sound. Based on this evaluation, none of the SAMAs are cost-beneficial in the baseline

analysis. However, the staff has concluded that one SAMA could be cost-beneficial when

uncertainties or alternative discount rates are taken into account. This SAMA involves providing

a portable generator to power the auxiliary feedwater turbine after battery depletion

(SAMA 169).

The staff concludes that, with the exception of this SAMA, the costs of implementing the'

SAMAs would be higher than the associated benefits. This conclusion is supported by

uncertainty assessment and sensitivity analysis. -

5.2.6 Conclusions

The staff has reviewed the NMC analysis and concluded that the methods used and the'

implementation of those methods were sound. The treatment of SAMA benefits and costs, the

generallylarge negative net benefits, and the inherently small baseline risks support the

general conclusion that the SAMA evaluations performed by NMC are reasonable and sufficient

for the license renewal submittal.

Although none of the SAMAs appear cost-beneficial in the baseline analysis, the staff has,.

concluded that one SAMA could be cost-beneficial when uncertainties or alternative discount

rates are taken into account. This SAMA involves providing a portable generator to power the

auxiliary feedwater turbine after battery depletion (SAMA 169).:' However,'this SAMA does not

relate to adequately managing the effects of aging during the period of extended operation.

Therefore, it need not be implemented as part of license renewal pursuant to 10 CFR Part 54.

The staff concludes that none of the other candidate SAMAs is cost-beneficial. This conclusion

is consistent with the low residual level of risk indicated in the PRA for both units and the fact

that PBNP has already implemented many of the plant improvements identified from the IPE

and IPEEE processes.

5.3 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing

of Production and Utilization Facilities."

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

August 2005 5-9 NUREG-1437, Supplement 23
I M

Environmental Impacts of Postulated Accidents

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site

Criteria."

Nuclear Management Company, LLC. (NMC). 2004. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

U.S. Nuclear Regulatory Commission (NRC). 1991. UPWR Dry Containment Parametric

Studies," NUREG/CR-5630, Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1 437, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatoty Analysis Technical Evaluation

Handbook. NUREG/BR-0184, 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.

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

Wisconsin Electric Power Company (WEPCO). 1993. Letter from Bob Link, to Document

Control Desk, Subject: Generic Letter 88-20 (TAC NOS. 74452 and 74453) "Summary Report

on Individual Plant Examination for Severe Accident Vulnerabilities, Point Beach Nuclear Plant,

Units 1 and 2," dated June 30, 1993.

Wisconsin Electric Power Company (WEPCO). 1995. Letter from Bob Link, to Document

Control Desk, Subject: Generic Letter 88-20 (TAC NOS. 74452 and 74453) "Summary Report

Examination of External Events for Severe Accident Vulnerabilities, Point Beach Nuclear Plant,

Units 1 and 2," June 30, 1995.

NUREG-1437, Supplement 23 5-10 August 2005
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).(a) 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~'pecified pla'It or site characteristics. - -

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

the impacts (except for collective'offsit6-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 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-i of Title 10 of the

Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B, and are applicable to Point

Beach Nuclear Plant Units 1 and 2 (PBNP). 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

(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.

August 2005 6-1 NUREG-1 437, Supplement 23
I rV

Fuel Cycle

impacts provided in 10 CFR 51.51 (b), Table S-3, "Table of Uranium Fuel Cycle Environmental

Data," and in 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and

Waste to and from One Light-Water-Cooled Nuclear Power Reactor." The 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

PBNP 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

I 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 6.1; 6.2.1; 6.2.2.1; 6.2.2.3;

disposal of spent fuel and high-level waste) 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) 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;

Low-level waste storage and disposal

I Mixed waste storage and disposal

Onsite spent fuel

Nonradiological waste

6.2.2.9; 6.2.3; 6.2.4; 6.6

6.1; 6.2.2.2;6.4.2; 6.4.3;

6.4.3.1; 6.4.3.2; 6.4.3.3;

6.4.4; 6.4.4.1; 6.4.4.2;

6.4.4.3; 6.4.4.4; 6.4.4.5;

6.4.4.5.1; 6.4.4.5.2;

6.4.4.5.3; 6.4.4.5.4;

6.4.4.6; 6.6

6.1, 6.4.5.1; 6.4.5.2; 6.4.5.3;

6.4.5.4; 6.4.5.5; 6.4.5.6;

6.4.5.6.1; 6.4.5.6.2;

6.4.5.6.3; 6.4.5.6.4; 6.6

6.1; 6.4.6; 6.4.6.1; 6.4.6.2;

6.4.6.3; 6.4.6.4; 6.4.6.5;

6.4.6.6; 6.4.6.7; 6.6

6.1; 6.5; 6.5.1; 6.5.2; 6.5.3;

6.6

6.1; 6.3.1; 6.3.2.3; 6.3.3;

6.3.4; 6.6, Addendum 1

Transportation

NUREG-1437, Supplement 23 6-2 August 2005

I I
Fuel Cycle

Nuclear Management Company, LLC (NMC) stated in its Environmental Report (ER)

(NMC 2004) that it is not aware of any new and significant information associated with the

renewal of the PBNP operating licenses. The staff has not identified any new and significant

information during its independent review of the NMC ER (NMC 2004), the staff's site visit, the

scoping process, the staff's evaluation of other available information, or public comments on the

draft supplemental environmental impact statement (SEIS); Therefore, the staff concludes that

there would be no impacts related to these issues beyond those discussed in the GEIS. For

these issues, the staff concluded in the GEIS that the impacts would be SMALL except for the

collective offsite radiological impacts from the fuel cycle and from 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 Part 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

Offsite 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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 [148 person Sv], 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

August 2005 6-3 NUREG-1 437, Supplement 23
Fuel Cycle

which will not ever be mitigated (for example no cancer cure in the next

thousand years), and that these doses projected over thousands of years are

meaningful. However, these assumptions are questionable. In particular,

science cannot rule out the possibility that there will be no cancer fatalities

from these tiny doses. For perspective, the doses are very small fractions of

regulatory limits and even smaller fractions of natural background exposure to

the same populations.

Nevertheless, despite all the uncertainty, some judgement 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 judgement 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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

100 millirem [1 mSv] 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

NUREG-1437, Supplement 23 6-4 August 2005

Il
Fuel Cycle

NAS report indicated that 100 millirem [1 mSv] per year should be considered

as a starting point for limits for individual doses, but notes that some measure

of consensus exists among national and international bodies that the limits

should be a fraction of the 100 millirem [1 mSv] per year. The lifetime

individual risk from 100 millirem [1 mSv] annual dose limit is about 3 x 104.

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

[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 afterl 00,000,000 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, 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 judgement as to the regulatory

NEPA implications of these matters should be made and it makes no sense to

August 2005 6-5 NUREG-1437, Supplement 23
I Et

Fuel Cycle

repeat the same judgement 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 HLW. The U.S. Congress

approved this recommendation on July 9, 2002, in Joint Resolution 87, which designated

Yucca Mountain as the repository for spent nuclear waste. On July 23, 2002, the President

signed 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 HLW.

The U.S. Environmental Protection Agency (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 the NRC's licensing criteria for

the candidate repository in 10 CFR Part 63.

Therefore, for the HLW 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, the staff assumed that limits would be developed along the

lines of the 1995 National Academy of Sciences report, Technical Bases for Yucca

Mountain Standards, 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) per year 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 HLW disposal

NUREG-1437, Supplement 23 6-6 August 2005

II
Fuel Cycle

should be made. The staff concludes that these impacts would be 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be no offsite radiological impacts related to spent fuel

and HLW disposal during the renewal term beyond those discussed in the GEIS.'

Nonradiolopical 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.

The staff has not identified any new and significant information during its independent*

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be no nonradiological impacts of the uranium fuel cycle

during the renewal term beyond those discussed in the GEIS.

* Low-level waste storace 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'thatfthe 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. Nonradiological impacts on air and water'will be negligible. The

radiological and nonradiological environmental impacts of lorig-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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

August 2005 6-7 ' NUREG-1437, Supplement 23
_____L-CL

Fuel Cycle

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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.

The staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be no impacts of mixed waste storage and disposal

associated with the renewal term beyond those discussed in the GEIS.

* Onsite 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be no impacts of onsite spent fuel associated with

license renewal beyond those discussed in the GEIS.

NUREG-1437, Supplement 23 6-8 August 2005

II
Fuel Cycle

* Nonradiolopical 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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(c), Summary

Table S-4 - Environmental Impact of Transportation of Fuel and Waste to and

from One Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or

burnup conditions are not met, the applicant must submit an assessment of

the implications for the environmental impact values reported in § 51.52.

PBNP meets the fuel enrichment and burnup conditions set forth in Addendum 1 to the

GEIS. The staff has not identified any new and significant information during its - -

independent review of the NMC ER (NMC 2004), the staff's site visit, the scoping process,

the staff's evaluation of other available information, or public comments on the draft SEIS.|

Therefore, the staff concludes that there would be no impacts of transportation associated

with license renewal beyond those discussed in the GEIS.

There are no Category 2 issues for the uranium fuel cycle'and solid-waste management.

6.2 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

August 2005 6-9 I NUREG-1437, Supplement 23
Fuel Cycle

10 CFR Part 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 Part 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."

Joint Resolution approving the site at Yucca Mountain, Nevada, for the development of a

repository for the disposal of high-level radioactive waste and spent nuclear fuel, pursuant to

the Nuclear Waste Policy Act of 1982. 2002. Public Law 107-200, 116 Stat. 735.

National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards.

Washington, D.C.

National Environmental Policy Act of 1969 (NEPA), as amended. 42 United States Code (USC)

4321 et seq.

Nuclear Energy Institute, Inc. v. EPA, 373 F.3d 1251 (D.C. Circuit Court 2004).

Nuclear Management Company, LLC (NMC). 2004. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

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.

NUREG-1437, Supplement 23 6-10 August 2005

Ir
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 for Decommissioning of Nuclear Facilities, NUREG-0586, Supplement -

(NRC 2002). The staff's evaluation of the environmental impacts of decommissioning-'

presented in Supplement 1 resulted in a range of impacts for each environmental issue. These

results may be used by licensees as a starting point for a plant-specific evaluation of the

decommissioning impacts at their facilities.

The incremental environmental impacts associated with decommissioning activities resulting

from continued plant operation during the renewal term are evaluated in the Generic

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

Volumes 1 and 2 (NRC .1996, 1999).a) The evaluation in NUREG-1 437 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 I 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. There are no Category 2

issues related to decommissioning.

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

references to the UGEIS' include the GEIS and its Addendum 1.

August 2005 7-1 NUREG-1437, Supplement 23
Environmental Impacts of Decommissioning

7.1 Decommissioning

Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51,

Subpart A, Appendix B, that are applicable to Point Beach Nuclear Plant Units 1 and 2 (PBNP)

decommissioning following the renewal term are listed in Table 7-1. Nuclear Management

Company, LLC (NMC) stated in its Environmental Report (ER) (NMC 2004) that it is aware of

no new and significant information regarding the environmental impacts of PBNP license

renewal. The staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft supplemental

environmental impact statement (SEIS). Therefore, the staff concludes that there would be no

impacts related to these issues beyond those discussed in the GEIS. For all of these issues,

the 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.

Table 7-1. Category 1 Issues Applicable to the Decommissioning of PBNP following the

Renewal Term

ISSUE-10 CFR Part 51, Subpart A,

Appendix B, Table B-i 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 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 [0.01 person-Sv] caused by buildup

of long-lived radionuclides during the license renewal term.

NUREG-1437, Supplement 23 7-2 August 2005

I n
Environmrental Impacts of Decommissioning

The staff has' not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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 staff has not iden'tified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's 'site visit, the scoping process, the staff's

evaluation of other available information, or'public comments'on the draft SEIS. Therefore,

the staff concludes that there would be no impacts from solid waste associated with

decommissioning following the license renewal term beyond those discussed in the GEIS.

Air qualitv. 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's '

evaluation of other available information, or public comments on the draft SEIS.- Therefore,

the staff concludes that there would be 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 decommissioninig 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..

August 2005 7-3 NUREG-1437, Supplement 23
I Ina

Environmental Impacts of Decommissioning

The staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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.

The staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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 staff has not identified any new and significant information during its independent

review of the NMC ER (NMC 2004), the staff's site visit, the scoping process, the staff's

evaluation of other available information, or public comments on the draft SEIS. Therefore,

the staff concludes that there would be 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."

Nuclear Management Company, LLC (NMC). 2004. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

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.

NUREG-1437, Supplement 23 7-4 August 2005

I I
Environmental Impacts of Decommissioning

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

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

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

Report. NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of

Nuclear Power Reactors. NUREG-0586, Volumes 1 and 2, Washington D.C.

August 2005 7-5 NUREG-1437, Supplement 23
8.0 Environmental Impacts of Alternatives

to-License Renewal

This chapter examines the potential environmental impacts associated with the following:

denying the renewal of operating licenses (OLs) for the Point Beach Nuclear Plant Units 1

and 2 (PBNP) (i.e., the no-action alternative); electric generating sources other thant PBNP;

purchasing electric power from other sources to replace power generated by Units 1 and 2; a

combination of generating and conservation measures; and other generation alternatives that

were deemed unsuitable for replacement of power gerierated by'PBNP. The environmental

impacts are evaluated using the U.S. Nuclear Regulatory Commission's (NRC's) three-level

standard of significance - SMALL, MODERATE, or LARGE - deveioped using the Council on

Environmental Quality guidelines and set forth in the footnotes to Table B-i of Title 10 of the

Code of Federal Regulations (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.

The impact categories evaluated in this chapter are the same as those used in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) NUREG-1 437,

Volumes 1 and 2 (NRC 1996, 1 999)(a) with the additional impact category of environmental

justice.

8.1 No-Action Alternative

The NRC's regulations implementing the National Environmental Policy Act of 1969 (NEPA)

specify that the no-action alternative be discussed in an NRC environmental impact statement;

see 10 CFR Part 51, Subpart A, Appendix A, Section 4. For license renewal, the no-action

alternative refers to a scenario in which the NRC would not renew the PBNP OLs, and Nuclear

Management Company, LLC (NMC) would then cease plant operations by the end of the

current licenses and decommission Units 1 and 2.

(a) The GElS was originally issued in 1996. Addendum ito the GElS was issued in 1999. Hereafter,-all

references to the UGEIS' include the GEIS and its Addendum 1.

August 2005 , 8-11 NUREG-1437, Supplement 23
Alternatives

NMC will be required to shut down PBNP and to comply with NRC decommissioning

requirements in 10 CFR 50.82 whether or not the PBNP OLs are renewed. If the PBNP OLs

are renewed, then shutdown of the units and decommissioning activities will not be avoided, but

will be postponed for up to an additional 20 years.

The environmental impacts associated with decommissioning following a license renewal period

of up to 20 years or following the no-action alternative would be bounded by the discussion of

impacts in Chapter 7 of the license renewal GEIS (NRC 1996), Chapter 7 of this supplemental

environmental impact statement (SEIS), and the Final Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 (NRC 2002). The

impacts of decommissioning after 60 years of operation are not expected to be significantly

different from those occurring after 40 years of operation.

Impacts from the decision to permanently cease operations are not considered in

NUREG-0586, Supplement 1.(a) Therefore, immediate impacts that occur between plant

shutdown and the beginning of plant dismantlement are considered here. These impacts will

occur when the units shut down regardless of whether the licenses are renewed or not and are

discussed below, with the results presented in Table 8-1. Plant shutdown will result in a net

reduction in power production capacity. The power not generated by PBNP during the license

renewal term would likely be replaced by (1) power purchased from other electricity providers,

(2) generating alternatives other than PBNP, (3) demand-side management (DSM) and energy

conservation, or (4) some combination of these options. The environmental impacts of these

options are discussed in Section 8.2.

Land Use

In Chapter 4, the staff concluded that the impacts of continued operation of PBNP on land

use would be SMALL. Onsite land use will not be immediately affected by the cessation of

operations. Plant structures and other facilities are likely to remain in place until

decommissioning. The transmission lines associated with the project are expected to

remain in service after the plants stop operating. As a result, maintenance of the

transmission line rights-of-way (ROWs) will continue as before. Therefore, the staff

concludes that the impacts on land use from plant shutdown would be SMALL.

(a) Appendix J of NUREG-0586, Supplement 1, discusses the socioeconomic impacts of plant closure,

but the results of the analysis in Appendix J are not incorporated in the analysis presented in the main

body of the NUREG (NRC 2002).

NUREG-1437, Supplement 23 8-2 August 2005

I I
Alternatives

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

Impact Category Impact Comment

Land Use -

Ecology

Water Use and QualitySurface Water

Water Use and Quality -

Groundwater

Air Quality

SMALL

SMALL

SMALL

SMALL

SMALL

Impacts are expected to be SMALL because plant

shutdown is not expected to result in changes to

onsite or offsite land use.

Impacts are expected to be SMALL because aquatic

impacts are generally positive and terrestrial impacts

are not expected because there will not be any

land-use changes.

Impacts are expected to be SMALL because

surface-water intake and discharges will decrease.

Impacts are expected to be SMALL because

groundwater use will decrease. -

Impacts are expected to be SMALL because

emissions related to plant operation and worker

transportation will decrease.

Impacts are expected to be SMALL because

generation of high-level waste (HLW) will stop,-and

generation of low-level and mixed waste will decrease.

Impacts are expected to be SMALL because

radiological doses to workers and members of the

public, which are within regulatory limits, will be

reduced.

Impacts are expected to be SMALL to MODERATE'

E because of a decrease in employment and tax

revenues. -

--impacts are expected to be SMALL because the

~ decrease in employment would reduce traffic. -

Waste SMALL

Human Health

Socioeconomics

Transportation

SMALL

SMALL to

MODERATI

SMALL

Aesthetics SMALL

Historic and Archaeological

Resources

Environmental Justice

SMALL

'SMALL

Impacts are expected to SMALL because plant

structures will remain in place.

Impacts are expected to be SMALL because

shutdown of the plant will not change land use.

Impacts are expected to be SMALL because very few

minority/low-income persons live in the immediate

vicinity of PBNP. The staff did not identify any

location-dependent disproportionately high and

adverse impacts that would affect these minority and

low-income populations.

August 2005' 8-3 - NUREG-1437, Supplement 23
Alternatives

* Ecology

In Chapter 4, the staff concluded that the ecological impacts of continued operation of

PBNP would be SMALL. Cessation of operations will be accompanied by a significant

reduction in cooling-water flow and elimination of impingement impacts, entrainment

impacts, and the thermal plume. The environmental impacts to aquatic species, including

threatened and endangered species, associated with these changes are generally positive.

The transmission lines associated with PBNP are expected to remain in service after PBNP

stops operating. As a result, maintenance of the transmission line ROWs and subsequent

impacts to the terrestrial ecosystem will continue as before. Therefore, the staff concludes

that ecological impacts from shutdown of the plant would be SMALL.

* Water Use and Quality - Surface Water

In Chapter 4, the staff concluded that the impacts of continued operation of PBNP on

surface-water use and quality would be SMALL. When the plant stops operating, there will

be an immediate reduction in the consumptive use of water because of reduction in

cooling-water flow and in the amount of heat rejected to Lake Michigan. There will also be

a significant reduction in biocide use. Therefore, the staff concludes that the impacts on

surface-water use and quality from plant shutdown would be SMALL.

* Water Use and Quality - Groundwater

In Chapter 4, the staff concluded that impacts of continued operation of PBNP on

groundwater use and groundwater availability and quality would be SMALL. When the plant

stops operating, there will be a reduction in the use of well water because of reduced

potable water consumption and sanitary use as the plant staff decreases. Therefore, the

staff concludes that impacts on groundwater use and quality from shutdown of the plant

would be SMALL.

* Air Quality

In Chapter 4, the staff concluded that the impacts of continued operation of PBNP on air

quality would be SMALL. When the plant stops operating, there will be a reduction in

emissions from activities related to plant operations, such as use of diesel generators and

worker transportation. Therefore, the staff concludes that the impact on air quality from

shutdown of the plant would be SMALL.

NUREG-1437, Supplement 23 8-4 August 2005

II
Alternatives

* Waste

The impacts of waste generated by continued operation of PBNP are discussed in

Chapter 6. The impacts of low-level and mixed waste from plant operation are

characterized as SMALL. When PBNP stops operating, the plant will stop generating HLW.

Generation of low-level and mixed waste associated with plant operation and maintenance

will be reduced. Therefore, the staff concludes that the impact of waste generated after

shutdown of the plant would be SMALL.-

* Human Health

In Chapter 4, the staff concluded that the impacts of continued operation of PBNP on

human health would be SMALL. After the cessation of operations, the amount of,

radioactive material released to the environment in gaseous and liquid forms will be

reduced. Therefore, the staff concludes that the impact of shutdown of the plant on human

health will be SMALL. In addition, the variety of potential accidents at the plant will be -

reduced to a limited set associated with shutdown events and fuel handling. In Chapter 5,

the staff concluded that the impacts of accidents during operation were SMALL. Therefore,

the staff concludes that the impacts of potential accidents following shutdown of the plant

would be SMALL.

* Socioeconomics

In Chapter 4, the staff concluded that the socioeconomic impacts of continued operation of

PBNP would be SMALL. There would be immediate socioeconomic impacts associated

with the shutdown of the plant because of the reduction in the staff at the plant. There may

also be an immediate reduction in the Shared Utility Payments for-the town of Two Creeks

and Manitowoc County. The staff concludes that the socioeconomic impacts of plant

shutdown would range from SMALL to MODERATE. Some of these impacts could be offset

if new power generating facilities are built at or near the current site.' See Appendix J to

NUREG-0586, Supplement 1, for additional discussion of the potential socioeconomic

impacts of plant shutdown (NRC 2002).

* Transportation

In Chapter 4, the staff concluded that the impacts of continued operation of PBNP on

transportation would be SMALL. Cessation of operations will be accompanied by a

reduction of traffic in the vicinity of the plant. Most of the reduction will be associated with a

reduction in the plant workforce, but there will also be a reduction in shipment of material to

and from the plant. Therefore, the staff concludes that the impacts of plant shutdown on

transportation would be SMALL.

August 2005 8-5 NUREG-1 437, Supplement 23
Alternatives

* Aesthetics

In Chapter 4, the staff concluded that the aesthetic impacts of continued operation of PBNP

would be SMALL. The plant structures will remain in place upon shutdown. Operational

noise would be reduced or eliminated. Noise would be generated during decommissioning

operations that may be detectable off site; however, the impact is unlikely to be of large

significance and can normally be mitigated. Therefore, the staff concludes that the

aesthetic impacts associated with the shutdown of PBNP would be SMALL.

* Historic and Archaeological Resources

In Chapter 4, the staff concluded that the impacts of continued operation of PBNP on

historic and archaeological resources would be SMALL. Onsite land use would not be

affected immediately by the cessation of operations. Plant structures and other facilities are

likely to remain in place until decommissioning. The transmission lines associated with the

project are expected to remain in service after the plant stops operating. As a result,

maintenance of transmission line ROWs would continue as before. Therefore, the staff

concludes that the impacts on historic and archaeological resources from plant shutdown

would be SMALL.

* Environmental Justice

In Chapter 4, the staff concluded that the impact of continued operation of PBNP on

environmental justice would be SMALL because continued operation of the plant would not

have disproportionately high and adverse impacts on minority and low-income populations.

Shutdown of the plant could result in the loss of employment opportunities at the PBNP site

and secondary socioeconomic impacts (e.g., loss of patronage at local businesses).

However, shutdown of the plant is unlikely to have disproportionately high and adverse

impacts on minority and low-income populations. The staff concludes that the

environmental justice impacts of plant shutdown would be SMALL. Some of these impacts

could be offset if new power generating facilities are built at or near the current site. See

Appendix J to NUREG-0586, Supplement 1, for additional discussion of these impacts

(NRC 2002).

8.2 Alternative Energy Sources

This section discusses the environmental impacts associated with alternative sources of electric

power to replace the power generated by PBNP, assuming that the OLs for Units 1 and 2 are

NUREG-1437, Supplement 23 8-6 August 2005

I I
Alternatives

not renewed. The order of presentation of alternative energy sources in Section 8.2 does not

imply which alternative would be most likely to occur or to have the least environmental

impacts.

The following generation alternatives are considered in detail:

* Coal-fired generation at the PBNP site and a greenfielda) alternate site (Section 8.2.1)

* Natural gas-fired generation at the PBNP site and a greenfield alternate site (Section 8.2.2)

* Nuclear generation at the PBNP site and a greenfield alternate site (Section 8.2.3).

The alternative of purchasing power from other sources to replace power generated at PBNP is

discussed in Section 8.2.4. Other power generation alternatives and conservation alternatives

considered by the staff and found not to be reasonable replacements for Units 1 and 2 are

discussed in Section 8.2.5. Section 8.2.6 discusses the environmental impacts of a -

combination of generation and conservation alternatives.

Each year the Energy Information Administration (EIA), a component of the U.S. Department of.

Energy (DOE), issues an Annual Energy Outlook. -In its Annual Energy Outlook 2004 with -

Projections to 2025, EIA projects that combined cycle,(b) distributed generation, or combustion

turbine technology fueled by natural gas is likely to account for approximately 62 percent of new

electric generating capacity between the years 2002 and 2025 (DOE/EIA 2004a). Both

technologies are designed primarily to supply peak and intermediate-capacity, but gas

combined-cycle technology can also be used to meet baseload(c) requirements:

Coal-fired plants are projected by EIA to account for approximately one-third of new capacity

during this period. Coal-fired plants are generally used to meet baseload requirements.

Renewable energy sources, primarily wind and biomass units, are projected by EIA to account.

for the remaining 5 percent of capacity additions. EIA's projections assume that providers of

new generating capacity will seek to minimize cost while meeting applicable environmental

requirements. Combined-cycle plants are projected by EIA to have the lowest generation cost

in 2010, followed by wind generation and then coal-fired plants (DOE/EIA 2004a). By 2025,

(a) A greenfield site is assumed to be an undeveloped site with no previous construction, and the

environmental impacts are expected to be greater than those at an already developed alternate site.

(b) In a combined cycle unit, hot combustion gas in a combustion turbine rotates the turbine to generate

electricity. The hot exhaust from the comiibusti6n turbine is routed through a heat-recovery boiler to

make steam to generate additional electricity.

(c) A baseload plant normally operates to supply all or part of the minimum continuous load of a system

and consequently produces electricity at an essentially constant rate. -Nuclear power plants are

commonly used for baseload generation; i.e., these units generally run near full load.

August 2005 8-7 NUREG-1437, Supplement 23
I --,I nAlternatives

coal-fired plants are projected by EIA to have the lowest generation cost, followed by gas

combined-cycle plants and then wind generation (DOEIEIA 2004a).

EIA projects that oil-fired plants will account for very little of new generation capacity in the

United States during the 2002 to 2025 time period because of higher fuel costs and lower

efficiencies (DOE/EIA 2004a). Consequently, an oil-fired power plant is not considered to be a

reasonable alternative to replace the power generated by PBNP.

EIA also projects that new nuclear power plants will not account for any new generation

capacity in the United States during the 2002 to 2025 time period because natural gas and

coal-fired plants are projected to be more economical (DOE/EIA 2004a). In spite of this

projection, a new nuclear plant alternative to power generated by PBNP is considered for

reasons stated in Section 8.2.3. NRC established a new reactor licensing program organization

in 2001 to prepare for and manage future reactor and site licensing applications (NRC 2001).

Therefore, a new nuclear plant alternative for replacing power generated by PBNP is

considered in this SEIS.

PBNP has a combined net rating of 1036 megawatts electric (MW[e]). For the coal-fired

alternative, the staff assumed the construction of two 600 MW(e) units that would operate at

about 78 percent efficiency. For the natural-gas alternative, the staff assumed four 380 MW(e)

units operating at 85 percent efficiency. For the new nuclear alternative, the staff assumed

construction of a plant with a net electric output of 1000 MW(e). The coal and gas alternatives

are consistent with the NMC Environmental Report (ER) (NMC 2004). The ER did not discuss

a new nuclear alternative.

8.2.1 Coal-Fired Generation

The coal-fired alternative is analyzed for both the PBNP site and an alternate site. For

purposes of analysis, the staff assumed the coal-fired alternative would use an integrated coal

gasification combined-cycle (IGCC) process, which would have lower impacts than the

supercritical pulverizing process. Construction of a rail spur 16 to 24 km (10 to 15 mi) in length

would be needed at the PBNP site and likely would be needed at an alternate site.

Construction at an alternate site also may require the construction of a new transmission line to

connect the coal-fired plant to existing lines.

Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.1 are

from the NMC ER (NMC 2004). The staff reviewed this information and compared it to

environmental impact information in the GEIS. Although the OL renewal period is only

20 years, the impact of operating the coal-fired alternative for 40 years is considered (as a.

reasonable projection of the operating life of a coal-fired plant). The staff assumed that PBNP

would remain in operation while the alternative coal-fired plant was constructed.

NUREG-1437, Supplement 23 8-8 August 2005

I I
Alternatives

The staff assumed the construction of two 600 MW(e) units operating at 78 percent efficiency

as potential replacements for PBNP. The coal-fired plant would consume approximately

2.1 million metric tons (MT) (2.3 million tons) per year of pulverized bituminous coal

(NMC 2004). NMC assumed a heat rate(a) of 2.78 J of fuel /J of electricity (9500 Btu/kWh) and

a capacity factor(b) of 0.78 in its ER (NMC 2004). The IGCC process would generate about

91,000 MT (100,000 tons) of a vitrified, glass-like waste material rather than ash, which would

be collected and disposed of at the PBNP site. In addition, approximately 16,000 MT

(18,000 tons) of elemental sulfur would be generated and disposed of at the PBNP site.

In addition to the impacts discussed below for a coal-fired plant at the PBNP site or an alternate

site, impacts would occur off site as a result of mining of coal. Impacts of mining operations

include an increase in fugitive dust emissions; surface water runoff; erosion; sedimentation;

changes in water quality; disturbance of vegetation and wildlife; disturbance of historic and

archaeological resources; changes in land use; and impacts on employment. The magnitude of

these offsite impacts would largely be proportional to the amount of land affected by mining

operations. In the GEIS, the 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 MW(e) coal plant

during its operational life. Partially offsetting this offsite land use would be the elimination of the

need for uranium mining to supply fuel for PBNP. In the GEIS, the staff estimated that

approximately 400 ha (1000 ac) would be affected for mining the uranium and processing it

during the operating life of a nuclear power plant.

Coal for a coal-fired plant sited at PBNP most likely would be delivered by rail line. Rail delivery

would also be the most likely option for delivering coal to an alternate site, although barge

delivery would also be a possibility.

8.2.1.1 Closed-Cycle Cooling System

The overall impacts of a coal-fired generating system using a closed-cycle cooling system and

cooling towers at either the PBNP or alternate sites are discussed in the following sections and

summarized in Table 8-2. The magnitude of impacts for an alternate site would depend on the

location of the particular site selected. PBNP currently uses a once-through cooling system.

For the purposes of comparison with an alternate site, however, it is assumed that a

replacement coal-fired plant on the PBNP site would use a closed-cycle cooling system.

(a) Heat rate is the measure of generating station thermal efficiency. In English units, it is generally

expressed in British thermal units (Btu) per net kilowatt-hour (kWh). It is computed by dividing the

total Btu content of the fuel burned for electric generation by the resulting kWh generation. The

corresponding metric unit for energy is the joule (J).

(b) 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.

August 2005 8-9 NUREG-1437, Supplement 23
*I r

Alternatives

Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation Using

Closed-Cycle Cooling at the PBNP Site and an Alternate Site

PBNP Site Altemate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Land Use MODERATE to

LARGE

Ecology SMALL to

MODERATE

Would use approximately

355 ha (880 ac) for plant, waste

disposal, and rail spur. There

would be additional offsite land

impacts from coal mining.

Would use over 320 ha

(790 ac) of undeveloped and

farmland areas at the current

PBNP site, plus rail corridor.

There would be potential

habitat loss and fragmentation

and reduced productivity and

biological diversity.

MODERATE

to LARGE

MODERATE

to LARGE

Would use approximately

700 ha (1700 ac) for plant,

offices, parking,

transmission line, and rail

spur. There would be

additional land impacts

from coal mining.

Impact would depend on

the location and ecology of

the site, surface-water

body used for intake and

discharge, and

transmission line and rail

spur routes. There would

be potential habitat loss

and fragmentation and

reduced productivity and

biological diversity.

Water Use and

Quality -

Surface Water

Water Use and

Quality - Groundwater

SMALL

SMALL

Would use parts of the existing

cooling system (intake and

discharge structures).

Operational impacts would be

similar or less than PBNP.

Groundwater use would be

limited.

SMALL to

MODERATE

SMALL to

MODERATE

Impact would depend on

the volume of water

withdrawn and discharged

and the characteristics of

the surface-water body.

Impact would depend on

the volume of water

withdrawn and discharged

and the characteristics of,

the aquifers.

NUREG-1437, Supplement 23 8-10 August 2005

I I
Alternatives

Table 8-2. (contd)

PBNP Site Alternate Site

.. IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Air Ouality - MODERATE

Waste MODERATE

Sulfur oxides

* 795 MT/yr (876 tons/yr)

Nitrogen oxides -

* 1856 MT/yr (2046 tons/yr)

Particulates

* 291 MT/yr (321 tonstyr) of

total suspended

particulates including PM,,

Carbon monoxide

* 1359 MT/yr (1498 tonslyr)

Small amounts of mercury and

other hazardous air pollutants

and naturally occurring

radioactive materials - mainly

uranium and thorium.

Total waste volume would be

approximately 1.1 x 106 m3

(1.4 x 106 yd3) of waste

requiring approximately 76 ha

(190 ac) for disposal during the

40-year life of the plant..

Impacts are considered to be

SMALL in the absence of more

quantitative risk data.,

During construction, impacts

would be MODERATE.

Between 500 and 2500

additional workers would be

employed during the peak of

the 5-year construction period,

followed by reduction from

current PBNP workforce of 971

to 200; the Shared Utility

Payments would continue. -

Impacts during operation would

be SMALL.

MODERATE Impacts would be -

potentially the same as at

the PBNP site, although

pollution-control standards

may vary depending on

location.

MODERATE Impacts would be the

same as at the PBNP site;

waste disposal constraints

may vary.

Human Health

Socioeconomics

SMALL

MODERATE

SMALL

MODER/

to LARGI

Impacts would be the

same as at the PBNP site. I

ATE Construction impacts

depend on location, but

could be LARGE if the

plant is located in an area

that is more rural than the

PBNP site. Manitowoc

County and Two Rivers

would experience loss of

Shared Utility Payments

and employment,

potentially offset by

proximity to Green Bay.

August 2005 8-11 NUREG-1437, Supplement 23
I I

Alternatives

Table 8-2. (contd)

I

I

PBNP Site Altemate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Transportation SMALL to Transportation impacts SMALL to Transportation impacts

LARGE associated with construction LARGE associated with

workers could be MODERATE construction workers could

to LARGE. Transportation be MODERATE to LARGE.

impacts after PBNP shutdown Transportation impacts

and startup of the coal plant are after PBNP shutdown and

considered to be SMALL. startup of the coal plant

are considered to be

For rail transportation of coal SMALL

and lime, the impact is considered to be MODERATE to For rail or barge

LARGE. For any barge transportation of coal and

transportation, the impact is lime, the impact is

considered to be SMALL considered to be

MODERATE to LARGE.

Aesthetics MODERATE The aesthetic impact of plant MODERATE Impacts would depend on

units, stacks, and cooling to LARGE the characteristics of the

towers would be MODERATE. site but would generally be

Intermittent noise from similar to PBNP site

construction, commuter traffic, impacts with additional

and waste disposal; continuous impacts from the

noise from cooling towers and transmission lines and any

mechanical equipment; and rail rail spur that may be

transportation of coal and lime needed.

would result in MODERATE

noise impacts.

Historic and SMALL to Some construction would affect SMALL to An alternate site would

Archaeological MODERATE previously developed parts of MODERATE necessitate cultural

Resources the PBNP site; a cultural resource studies.

resource inventory should

minimize any impacts on

undeveloped lands.

Environmental SMALL to Impacts on minority and SMALL to Impacts would vary

Justice MODERATE low-income communities MODERATE depending on population

should be similar to those distribution and makeup at

experienced by the population the site.

as a whole. Some impacts on

housing might occur during

construction.

NUREG-1437, Supplement 23 8-12 August 2005

I I
Alternatives

* Land Use

The existing facilities and infrastructure at the PBNP site would be used to the extent

practicable, limiting the amount of new construction that would be required. Specifically, the

staff assumed that the'coal-fired replacement plant alternative would require modification and

use of the switchyard, offices, and transmission line ROWs. Much of the land that would be

used has been previously disturbed. However, it is assumed that PBNP would continue to

operate while the new units are built.

The coal-fired generation alternative would necessitate converting roughly an additional 240 ha

(600 ac) of the PBNP site for the plant and coal storage, plus an additional 77 ha (190 ac) for

waste disposal (NMC 2004). Although the PBNP site has an existing once-through cooling

system, the system would need to be significantly modified to accommodate a coal plant with a'

closed-cycle cooling system. It is assumed that the once-through cooling system would be -

used for the continued safe operation of PBNP while the new units areT built. Therefore, some

of the leased farm lands on the PBNP site would be converted to industrial use under this

alternative. In addition, 24 to 36 ha (60 to 90 ac) would be disturbed to construct a rail spur for

coal delivery. Additional land-use changes would occur off site in an undetermined coal mining'

area to supply coal for the plant.

The impact of a coal-fired generating unit on land use'at the existing PBNP site is best'

characterized as MODERATE to LARGE. The impact would be greater than'the OL renewal

alternative.

Construction of the coal-fired plant at an alternate site could impact up-to 700 ha (1700 ac)

(NRC 1996). While transmission facilities would factor into the site selection process, new

transmission lines may be necessary, and additional land may be disturbed if a rail spur is :

needed for coal delivery. This alternative would result in MODERATE to LARGE land-use

impacts.

* Ecology

Locating a coal-fired plant at the PBNP site would alter ecological resources because of the

need to convert roughly 320 ha (790 ac) of land to industrial use (plant, coal storage, vitrified

waste and elemental sulfur disposal). Additional land would be disturbed for the construction

and use of the closed-cycle cooling system and rail spur. -However, some of the land on PBNP

has already been disturbed. Therefore, the impacts to terrestrial resources would be

considered to be SMALL to MODERATE. Impacts to aquatic resources would be reduced and

remain SMALL should closed-cycle cooling replace the once-through system.-

Locating a coal-fired plant at an alternate site would alter ecological resources because of the

need to convert up to roughly 700 ha (1700 ac) (NRC 1996) of previously undisturbed land to

August 2005 8-13 NUREG-1437, Supplement 23
Alternatives

industrial use (plant, coal storage, vitrified waste and elemental sulfur disposal). Additional land

likely would be disturbed for a rail spur and any new transmission facilities. Impacts could

include wildlife habitat loss, reduced productivity, and a local reduction in biological diversity.

The closed-cycle cooling system alternative would likely have a SMALL impact to aquatic

resources. Overall, the ecological impacts at an alternate site would be MODERATE to

LARGE.

* Water Use and Quality - Surface Water

Coal-fired generation at the PBNP site would likely use water from Lake Michigan for cooling. It

is possible that some of the existing intake and discharge structures could be used, but the

construction of additional cooling infrastructure would be needed to accommodate a

closed-cycle cooling system. Plant discharges would consist mostly of cooling-tower blowdown,

primarily characterized by an increased temperature and concentration of dissolved solids

relative to the receiving water body and intermittent, low concentrations of biocides (e.g.,

chlorine). Treated process waste streams and sanitary wastewater may also be discharged.

All discharges would be regulated by the Wisconsin Department of Natural Resources (WDNR)

through a Wisconsin Pollutant Discharge Elimination System permit. There would be a

consumptive use of water due to evaporation from the cooling towers. Some erosion and

sedimentation would likely occur during construction (NRC 1996). The staff considers the

impacts to surface-water use and quality of a new coal-fired plant with a closed-cycle cooling

system located at the PBNP site to be SMALL.

Cooling water at an alternate site would likely be withdrawn from a surface-water body and

would be regulated by permit. Depending on the source water body, the impacts of water use

for cooling system makeup water and the effects on water quality due to cooling-tower

blowdown could have noticeable impacts. Therefore, the staff considers the impacts of a new

coal-fired plant utilizing a closed-cycle cooling system at an alternate site to be SMALL to

MODERATE.

* Water Use and Quality - Groundwater

| The staff assumed that groundwater wells would continue to be used for PBNP related

activities. Groundwater withdrawals would be equal to or less than the no-action and license

renewal alternatives. Overall, impacts of a coal-fired power plant with a closed-cycle cooling

system at the PBNP site on groundwater use and quality are considered to be SMALL. Use of

groundwater for a coal-fired plant located at an alternate site is a possibility. Groundwater

withdrawals at an alternate site would likely require a State permit. The impacts will depend on

the characteristics of the site and the amount of groundwater used. Therefore, the impacts at

an alternate site are considered to be SMALL to MODERATE, depending on the volume of

groundwater withdrawn.

NUREG-1437, Supplement 23 8-14 August 2005

Il
Alternatives

* Air Quality

The air-quality impacts of coal-fired generation vary considerably from those of nuclear

generation because burning coal emits sulfur oxides (SO.), nitrogen oxides (NO.), particulates,

carbon monoxide, hazardous air pollutants such as mercury, and naturally occurring radioactive

materials.

PBNP is located in the Lake Michigan Intrastate Air Quality Control Region (AQCR), formerly

known as the Menominee-Escanaba (Michigan)-Marinette (Wisconsin) Interstate AQCR. The

AQCR is currently in attainment for all air-quality criteria pollutants, with the exception'of ozone.

The U.S. Environmental Protection Agency (EPA) designated Manitowoc County, Wisconsin, as

a "basic" ionattainment area for the 8-hour ozone standard, with June 2009 as the latest date

to achieve attainment. The County must comply with the more general nonattainment

requirements of the Clean Air Act of 1970 (CAA) (42 United States Code [USC] 7491).

Therefore, improved emissions controls likely would be required for a new coal-fired plant

located at the PBNP site.

A new coal-fired generating plant located in Wisconsin would need an operating permit under

the CM. The plant would need to comply with the new source performance standards set forth

in 40 CFR Part 60, Subpart Da. The standards establish limits for particulate matter and

opacity (40 CFR 60.42(a)), for sulfur dioxide (SO2) (40 CFR 60.43(a)), and for NOX '

(40 CFR 60.44(a)). The facility would be designed to meet best. available control technology or

lowest achievable emissions rate standards, as applicable, for control of criteria air pollutants.

The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

Subpart P, including a specific requirement for review of any new major stationary source in an

area designated as attainment or unclassified under the CM. PBNP and nearby alternate sites

are in areas designated as being in attainment or unclassified for criteria pollutants with the

exception of ozone.

Section 169A of the CM establishes a national goal of preventing future impairment of visibility

and remedying existing impairment of visibility in mandatory Class I Federal areas when

impairment results from man-made air pollution. The EPA issued a new regional haze rule in

1999 (EPA 1999). The rule specifies that for each mandatory Class I Federal area, 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-impaired 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 could be imposed. There are no Class I areas within 160 km (100 mi) of the

PBNP site.

August 2005 - 8-15 NUREG-1437, Supplement 23
. I I ITI

Alternatives

Impacts for particular pollutants are as follows:

* Sulfur oxides. A new coal-fired power plant would be subject to the requirements in Title IV

of the CM. Title IV was enacted to reduce emissions of S0 and NO,, the two principal

precursors of acid rain, by restricting emissions of these pollutants from power plants.

Title IV caps aggregate annual power plant S02 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 S02 emissions, although it might do so

locally. Regardless, S02 emissions would be greater for the coal alternative than the OL

renewal alternative.

NMC estimates that by using the best technology to minimize SO, emissions, the total

annual stack emissions would be approximately 795 MT (876 tons) of SO, (NMC 2004).

* Nitrogen oxides. Section 407 of the CM establishes technology-based emission limitations

for NOX emissions. The market-based allowance system used for SO2 emissions is not

used for NO, emissions. A new coal-fired power plant would be subject to the new source

performance standards for such plants at 40 CFR 60.44a(d)(1). This regulation (EPA 1998)

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.

NMC estimates that the total annual NO, emissions for a new coal-fired power plant would

be approximately 1856 MT (2046 tons) (NMC 2004). This level of NO, emissions would be

greater than the OL renewal alternative.

* Particulates. NMC estimates that the total annual stack emissions would be about 291 MT

(321 tons) of total suspended particulates and particulate matter having an aerodynamic

diameter less than or equal to 10 pm (PM10) (NMC 2004). Fabric filters or electrostatic

precipitators likely would be used for control. In addition, coal-handling equipment would

introduce fugitive particulate emissions. Particulate emissions would be greater under the

coal alternative than the OL renewal alternative.

During the construction of a coal-fired plant, fugitive dust would be generated. In addition,

exhaust emissions would come from vehicles and motorized equipment used during the

construction process.

NUREG-1437, Supplement 23 8-16 August 2005

I I
Alternatives

* Carbon monoxide. NMC estimates that the total carbon monoxide emissions would be

approximately 1359 MT (1498 tons) per year for a coal-fired power plant (NMC 2004). This

level of emissions is greater than the OL renewal alternative.

* Hazardous air pollutants including mercury. In December 2000, the EPA issued regulatory

findings on emissions of hazardous air pollutants from electric utility steam-generating units

(EPA 2000a). The 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 the EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen

chloride, hydrogen fluoride, lead, manganese, and mercury (EPA 2000a). The EPA

concluded that mercury is the hazardous air pollutant of greatest concern. The 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 2000a).

Accordingly, the EPA added coal- and oil-fired electric utility steam-generating units to the

list of source categories under Section 112(c) of the CAA for which emission standards for

hazardous air pollutants will be issued (EPA 2000a).

* Uranium and thorium. Uranium and thorium occur naturally in coal. Uranium

concentrations are generally in the range of 1 to 10 parts per million. Thorium'

concentrations are generally about 2.5 times greater than uranium concentrations

(Gabbard 1993). One estimate is that a typical coal-fired plant released roughly

4.7 MT (5.2 tons) of uranium and 11.6 MT (12.8 tons) of thorium in 1982 (Gabbard 1993).

The population dose equivalent from the uranium and thorium releases and daughter -

products produced by the decay of these isotopes has been calculated to be significantly -

higher than that from nuclear power plants'(Gabbard 1993).'

* Carbon dioxide. A coal-fired plant would also have unregulated carbon dioxide emissions

that could contribute to global warming. The level of emissions from a coal-fired plant would

be greater than the OL renewal alternative.

* Summar . 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 SO,, and NO,, emissions as

potential impacts (NRC 1996). Adverse human health effects such as cancer and

emphysema have been associated with the products of coal combustion. The appropriate

characterization of air impacts from coal-fired generation would be MODERATE. The

impacts would be clearly noticeable, but would not destabilize air quality.

August 2005 8-17 NUREG-1437, Supplement 23'
I "

Alternatives

Siting a coal-fired generation plant at a site other than PBNP would not significantly change

air-quality impacts from those described above, although it could result in installing more or

less stringent pollution-control equipment to meet applicable local requirements. Therefore,

the impacts would be MODERATE.

Waste

The IGCC coal combustion technology would generate a vitrified, glass-like waste material

(slag). Two 600-MW(e) coal-fired plants would generate approximately 1.1 x 106 m3

(1.4 x 1 05 cu yds) of this waste over 40 years. The waste would be disposed of on site and

account for approximately 77 ha (190 ac) of land area over the 40-year plant life. Waste

impacts to groundwater and surface water could extend beyond the operating life of the plant if

leachate and runoff from the waste storage area occur. Disposal of the waste could noticeably

affect land use and groundwater quality, but with appropriate management and monitoring, it

would not destabilize any resources. After closure of the waste site and revegetation, the land

could be available for other uses. Debris would be generated during construction activities.

In May 2000, the EPA issued a uNotice of Regulatory Determination on Wastes From the

Combustion of Fossil Fuels" (EPA 2000b). EPA concluded that some form of national

regulation is warranted to address coal combustion waste products because (1) the

composition of these wastes could present danger to human health and the environment under

certain conditions; (2) EPA has identified 11 documented cases of proven damages to human

health and the environment by improper management of these wastes in landfills and surface

impoundments; (3) present disposal practices are such that, in 1995, these wastes were being

managed in 40 percent to 70 percent of landfills and surface impoundments without reasonable

controls in place, particularly in the area of groundwater monitoring; and (4) the EPA identified

gaps in State oversight of coal combustion wastes. Accordingly, the EPA announced its

intention to issue regulations for disposal of coal combustion waste under Subtitle D of the

Resource Conservation and Recovery Act. EPA held a stakeholders meeting on minefill

practices for coal combustion residue in May 2003 and a series of "listening" meetings on coal

combustion byproducts in April and May 2004, but has not yet issued regulations for the

disposal of coal combustion waste.

Siting the coal-fired power plant at PBNP or at an alternate site other than PBNP would not alter

waste generation, although other sites might have more constraints on disposal locations.

Therefore, the waste impacts would be MODERATE.

NUREG-1437, Supplement 23 8-18 August 2005

I I
Alternatives

* Human Health

Coal-fired power generation introduces worker risks from fuel and limestone mining, from fuel

and lime/limestone 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 alternative also introduces the risk of coal-pile

fires and attendant inhalation risks.

In the GEIS, the staff stated that there could 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). In addition, the discharges of uranium and thorium from coal-fired

plants can'potentially produce radiological doses in excess of those arising from nuclear power

plant operations (Gabbard 1993).

Regulatory agencies, including the 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, the 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. However, in the'- -'

absence of more quantitative data, human health impacts from radiological doses and inhaling

toxins and particulates generated by burning coal are characterized as SMALL.

Socioeconomics

Construction of the coal-fired alternative would take approximately 5 years. The staff assumed

that construction would take place while PBNP continues operation and would be completed by,

the time Units 1 and 2 permanently cease operations. The workforce would be expected to

vary between 1200 and 2500 workers during the 5-year construction period (NRC 1996),

although NMC estimated approximately 500 to 600 construction workers (NMC 2004). These

workers would be in addition to the approximately 971 'workers employed at PBNP. During

construction, the surrounding communities would experience demands on housing "and public

services that could have MODERATE impacts. These impacts would be tempered by

construction workers commuting to the site from other parts of Manitowoc County or from-other

counties. After construction, the communities would be impacted by the loss of the construction

jobs.

If the coal-fired replacement plant were constructed at the PBNP site and Units'1 and 2 were

shut down, there would be a loss of approximately 971 permanent jobs. Approximately

200 permanent jobs would be created to operate the coal-fired plant. There would be a

reduction in demand on socioeconomic resources and contribution to the regional economy

commensurate with the loss of 771 permanent jobs. The economic projections for the area

August 2005 8-19 NUREG-1437, Supplement 23
Alternatives

suggest that the slow growth likely would not temper or offset the projected loss of jobs from

the shutdown of Units 1 and 2. However, the proximity to Green Bay likely would mitigate the

impacts. The coal-fired plants would provide for Shared Utility Payments to at least partially

offset the loss of these payments associated with the nuclear units. For all of these reasons,

the appropriate characterization of nontransportation socioeconomic impacts for a coal-fired

plant constructed at the PBNP site would be MODERATE.

Construction of a replacement coal-fired power plant at an alternate site would relocate some

socioeconomic impacts, but would not eliminate them. The communities around PBNP would

still experience the impact of PBNP operational job losses, and the communities around the

new site would have to absorb the impacts of a large, temporary workforce (up to 2500 workers

at the peak of construction) and a permanent workforce of approximately 200 workers. In the

GEIS, the staff stated that socioeconomic impacts at a rural site would be larger than at an

urban site because more of the peak construction workforce would need to move to the area to

work. The PBNP site is within commuting distance of the Green Bay metropolitan area and,

therefore, is not considered a rural site. Alternate sites would need to be analyzed on a

case-by-case basis. Socioeconomic impacts at a rural site could be MODERATE to LARGE.

- Transportation

During the 5-year construction period of replacement coal-fired units, up to 2500 construction

workers would be working at the PBNP site in addition to the 971 workers at PBNP. The

addition of these workers could place significant traffic loads on existing highways, particularly

those leading to the PBNP site. Such impacts would be MODERATE to LARGE.

For transportation related to commuting of plant operating personnel, the impacts are

considered to be SMALL. After PBNP shutdown and startup of the coal-fired plant, the

maximum number of coal-fired plant operating personnel would be approximately 200. The

current PBNP workforce is approximately 971. Therefore, traffic impacts associated with plant

personnel commuting to a coal-fired plant would be expected to be SMALL compared to the

current impacts from PBNP operations.

For rail transportation related to coal and lime delivery to the PBNP site, the impacts are

considered to be MODERATE to LARGE. Approximately 230 trains per year would be needed

to deliver the coal and lime for the two coal-fired units. A total of five train trips would be

expected per week, or more than one trip per day, because for each full train delivery there

would be an empty train.

NUREG-1437, Supplement 23 8-20 August 2005

I
Alternatives

Transportation-related impacts associated with commuting construction workers at an alternate

site are site dependent, but could be MODERATE to LARGE. Transportation impacts related to

commuting of plant operating personnel would also be site dependent, but can be characterized

as SMALL to MODERATE.

At an alternate site, coal would likely be delivered by rail,-although barging would be possible if

located on Lake Michigan at a site with the potential for barge dock facilities. Transportation

impacts would depend upon the site location. Socioeconomic impacts associated with rail

transportation or barging would likely be MODERATE to LARGE.

Aesthetics

If sited at PBNP, the cooling towers, plumes, and exhaust stacks of the two coal-fired units

would be visible for many miles in daylight hours. The exhaust stacks would be up to

91 m (300 ft) in height. In addition, the IGCC technology would produce a flare of about

61 m (200 ft). The units and associated stacks would also be visible at night because of

outside lighting and the flare.' 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 use of lighting and appropriate use of shielding.

Overall, the addition of a coal-fired unit and the associated stack at the PBNP site would likely

have a MODERATE aesthetic impact.

Coal-fired generation would introduce mechanical sources of noise that would be audible off

site. 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 delivery, use of outside

loudspeakers, and the commuting of plant employees. The incremental noise impacts of a

coal-fired plant compared to existing PBNP operations are considered to be MODERATE.

Noise impacts associated with rail delivery of coal to a plant at the PBNP 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. Nevertheless, given the frequency of train transport

and the many residents likely to be within hearing distance of the rail route, the impact of noise

on residents in the vicinity of the facility and the rail line is considered to be MODERATE.

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 an aesthetic

impact associated with construction of a new rail spur and transmission line. -Noise and light

from the plant would be detectable off site. Aesthetic impacts at the plant site would be

mitigated if the plant were located in an industrial area adjacent to other power plants. Noise

August 2005 8-21 NUREG-1437, Supplement 23
Alternatives

impacts from a rail spur would be similar to the impacts at the existing site. Overall the

aesthetic impacts associated with a coal-fired plant at an alternate site can be categorized as

MODERATE to LARGE.

Historic and Archaeological Resources

A new coal-fired plant at the PBNP site or an alternate site would likely require a cultural

resource inventory of 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 impacts from subsequent ground-disturbing actions related to

physical expansion of the plant site.

Before construction at the PBNP site or 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 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 line ROWs, rail lines, or other ROWs). Historic and archaeological

resource impacts need to be evaluated on a site-specific basis. The impacts can generally be

effectively managed, and as such, impacts would vary between SMALL to MODERATE,

depending on the historic and archaeological resources that may be present and whether

mitigation is necessary.

Environmental Justice

No environmental pathways or locations have been 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 PBNP site. Some impacts on

housing availability and prices during construction might occur, which could disproportionately

affect minority and low-income populations. Shutdown of PBNP would result in a decrease in

employment of approximately 771 operating employees, possibly offset by growth in the area.

Following construction, it is possible that the ability of local government to maintain social

services could be reduced at the same time as diminished economic conditions reduce

employment prospects for minority or low-income populations. Overall, impacts would be

SMALL to MODERATE and would depend on potential economic growth in the area and the

ability of minority or low-income populations to commute to other jobs in the area.

Impacts at an alternate site would depend upon the site chosen and the nearby population

distribution but are also likely to be SMALL to MODERATE.

NUREG-1 437, Supplement 23 8-22 August 2005

I I
Alternatives

8.2.1.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a coal-fired plant with a

once-through cooling system at the PBNP site. The impacts (SMALL, MODERATE, or LARGE)

of this option are the same as the impacts for a coal-fired plant using the closed-cycle system.

However, there are minor environmental differences between the closed-cycle and

once-through cooling systems. Table 8-3 summarizes the incremental differences.

Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation with a

Once-Through Cooling System at the PBNP Site

Impact Category Impact

Land Use - MODERATE to

Ecology

LAHUE

SMALL to -

MODERATE

Comparison with

Closed-Cycle Cooling System

Impacts may be less (e.g., through

elimination of cooling towers).

Possible impacts include entrainment of

fish and shellfish in early life stages,

impingement of fish and shellfish, and.

heat shock.

Increased water withdrawal could lead

to possible water-use conflicts; thermal

load would be higher than with

closed-cycle cooling.

-

Water Use and Quality -

Surface Water

SMALL

Water Use and

Quality- Groundwater

Air Quality

Waste

Human Health

Socioeconomics

Transportation

Aesthetics

Historic and Archaeological

Resources

Environmental Justice

SMALL

MODERATE

MODERATE

SMALL

MODERATE

No change.

No change.

No change.

No change.

o ch No change.

SMALL to LARGE

MODERATE - .:.

SMALL to 6; - -

MODERATE

No change.

Cooling towers would be eliminated.-

No change. ' - -

SMALL to

MODERATE

No change.

August 2005- B-23 NUREG-1437, Supplement 23
Alternatives

8.2.2 Natural Gas-Fired Generation

The environmental impacts of a natural gas-fired alternative are examined in this section for

both the PBNP site and an alternate site. The staff assumed that the plant would use a

closed-cycle cooling system. In Section 8.2.2.2, the staff also evaluated the impacts of using

the existing once-through cooling system at the PBNP site.

The PBNP site and an alternate site would need a 61-cm (24-in.) diameter natural gas pipeline

constructed from the plant site to a supply point where a reliable supply of natural gas would be

available. NMC identified that a pipeline to the PBNP site would be approximately 64 km

(40-mi) long and disturb about 81 ha (200 ac) of land at the site (NMC 2004).

The staff assumed that a replacement natural gas-fired plant would include four units using

combined-cycle technology (NMC 2004). 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 boiler to make steam to generate

additional electricity. The staff assumed that a replacement natural gas-fired plant would use

combined-cycle combustion turbines as described by NMC (NMC 2004). NMC estimates that

the plant would consume approximately 1.3 billion m3 (46.2 billion ft3) of natural gas annually

(NMC 2004).

Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.2 are

from the NMC ER (NMC 2004). The staff reviewed this information and compared it to

environmental impact information in the GEIS. Although the OL renewal period is only

20 years, the impact of operating the natural gas-fired alternative for 40 years is considered (as

a reasonable projection of the operating life of a natural gas-fired plant).

In addition to the impacts discussed below for a gas-fired plant at either the PBNP site or an

alternate site, impacts would occur off site as a result of gas production and transportation.

Impacts of production operations include an increase in fugitive dust emissions; surface water

runoff; erosion; sedimentation; changes in water quality; disturbance of vegetation and wildlife;

disturbance of historic and archaeological resources; changes in land use; and impacts on

employment.

8.2.2.1 Closed-Cycle Cooling System

The overall impacts of the natural gas-fired generating system with a closed-cycle cooling

system are discussed in the following sections and summarized in Table 8-4. The extent of

impacts at an alternate site will depend on the location of the particular site selected.

NUREG-1437, Supplement 23 8-24 August 2005

II
Alternatives

* Land Use

The existing facilities and infrastructure at the PBNP site would be used to the extent

practicable, limiting the amount of new construction that would be required. Specifically, the

staff assumed that the natural gas-fired alternative would require modification and use of the

switchyard, offices, and transmission line ROWs. Much of the land that would be used has

been previously disturbed. The staff assumed that approximately 20 ha (50 ac) at PBNP would

be needed for the plant and associated infrastructure (NMC 2004). There would be an

additional impact to 81 ha (200 ac) for construction of a 64-km (40-mi) gas pipeline.

For construction at an alternate site, the staff assumed that 20 ha (50 ac) would be needed for

the plant and associated infrastructure for a 1000 MW(e) plant (NRC 1996). In addition,

construction of an underground pipeline would result in additional land disturbance at an

alternate site. Regardless of where the natural gas-fired plant is built, 1500 ha (3600 ac) of

additional land would be required for natural gas wells, collection stations, and pipelines

(NRC 1996).

These offsite land requirements would be partially offset by eliminating the need for uranium

mining to supply fuel for PBNP. In the GEIS (NRC 1996), the staff estimated that uranium

mining and processing would affect approximately 400 ha (1000 ac) during the operating life of

a nuclear power plant. Additional impacts from uranium mining are discussed in

Section 8.2.3.1.

The impact of a natural gas-fired generating unit on land use at the existing PBNP site is best

characterized as MODERATE, and the land-use impacts on an alternate site would be

MODERATE to LARGE.

August 2005 8-25 NUREG-1 437, Supplement 23
Alternatives

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

Closed-Cycle Cooling at the PBNP Site and an Alternate Site

PBNP Site Alternate Site

IMPACT CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Land Use MODERATE 20 ha (50 ac) would be required

for power block, offices, roads,

and parking areas. There would

be an additional impact of up to

approximately 80 ha (200 ac) for

construction and/or upgrade of

an underground gas pipeline.

MODERATE

to LARGE

Ecology MODERATE Undeveloped areas at the

current PBNP site would be

used, and a gas pipeline would

be constructed through habitat.

Potential habitat would be lost

and fragmented; productivity and

biological diversity would be

reduced. Ukely plant sites

already have power generation

facilities.

MODERATE

20 ha (50 ac) would be

required for powerblock,

offices, roads, and parking

areas. There would be an

additional impact (1500 ha

[3600 acd) for construction

and/or upgrade of an

underground gas pipeline

and transmission line.

Impact would depend on

the location and ecology of

the site, the surface-water

body used for intake and

discharge, and

transmission and pipeline

routes; potential habitat

would be lost and

fragmented; productivity

and biological diversity

would be reduced.

Impact would depend on

the volume of water

withdrawal and discharge

and characteristics of

surface-water body.

Impact would depend on

the volume of water

withdrawal.

Emissions would be the

same as at the PBNP site.

Water Use and

Quality - Surface

Water

Water Use and

Quality -

Groundwater

Air Quality

SMALL

SMALL

Partial use of existing cooling

system (intake and discharge

structures). Operational impacts

would be similar or less than for

PBNP.

Little groundwater would be

used.

SMALL to

MODERATE

SMALL to

MODERATE

MODERATE Sulfur oxides

* 15.9 MT/yr (17.5 tons/yr)

Nitrogen oxides

* 2705 MT/yr (2982 tons/yr)

Particulates

* 446 MT/yr (492 tons/yr) of

total suspended particulates

including PM,,

Some hazardous air pollutants.

Unregulated CO2 emissions

could contribute to global

warming.

MODERATE

Waste SMALL A small amount of ash would be SMALL

produced.

The waste produced would

be the same as at the

PBNP site.

NUREG-1437, Supplement 23 8-26 August 2005

Il
Alternatives

Table 8-4. (contd)

PBNP Site Alternate Site

IMPACT CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Human Health SMALL Impacts are considered to be SMALL Impacts are considered to

Socioeconomics

Transportation

minor.

SMALL to Up to 1200 construction workers

MODERATE during the peak of the 3-year

construction period could create

temporary demands on housing and public services. There

would be a reduction in workers

from 971 PBNP workers to a

new plant workforce of 30.

Manitowoc County would

experience a reduced demand

on socioeconomic resources as

well as a loss of Shared Utility Payments and employment, potentially offset by the proximity of the site to Green Bay.

Wisconsin.

MODERATE Transportation impacts

associated with construction

workers would be MODERATE.

Impacts associated with

operations would be SMALL.

be minor.

SMALL to Construction impacts

MODERATE depend on location, but

could be greater than the

PBNP site if the plant is

located in an area that is

more rural. There would

be up to 1200 temporary

construction jobs during

the peak of a 3-year

construction period;'

Operation of the plant

would result in 30

permanent jobs.

Manitowoc County could

experience greater loss of

Shared Utility Payments

and employment than at

the PBNP site if the

alternate site is outside of

Manitowoc County.

MODERATE Transportation impacts

associated with

construction workers would

be MODERATE. Impacts

associated with operations

would be SMALL.

SMALL to Impacts would depend on

MODERATE- characteristics of the site

but would be generally

similar to impacts at the

PBNP site.

Aesthetics SMALL to

MODERATE

The aesthetic impact of plant

units, stacks, and cooling towers

would be MODERATE.

Historic and

Archaeological

Resources

SMALL to 'Some construction would affect

MODERATE previously developed parts of

the PBNP site; a cultural

resource inventory should

minimize any impacts on

-undeveloped lands.

SMALL to

'MODERATE

Impacts would be the

-same as at the PBNP site;

any potential impacts can

likely be effectively

managed.

Environmental

Justice

SMALL to

MODERATE

Impacts on minority and

low-income communities should

be similar to those experienced

by the population as a whole.

Some impacts on housing may

occur during construction.

SMALL to

MODERATE

Impacts would vary

depending on the

population distribution and

makeup at site.

August 2005 8-27 _ NUREG-1437, Supplement 23
Alternatives

* Ecology

Locating a natural gas-fired plant at the PBNP site would create ecological impacts to land use.

Bringing a new underground gas pipeline to the site would also cause substantial ecological

impacts. Ecological impacts at an alternate site would depend on the nature of the land

converted for the plant and the likely need for a new gas pipeline and/or transmission line.

Construction of a transmission line and construction and/or upgrading of a gas pipeline to serve

the plant would be expected to have temporary ecological impacts. Ecological impacts to the

plant site and utility easements could include impacts on threatened or endangered species and

could cause wildlife habitat loss, reduced productivity, habitat fragmentation, and a local

reduction in biological diversity. At an alternate site, the cooling makeup water intake and

discharge could have aquatic resource impacts. Overall, the ecological impacts are considered

to be MODERATE at either location.

* Water Use and Quality - Surface Water

Each of the gas-fired units would include a heat recovery boiler from which steam would turn an

electric generator. Steam would be condensed and circulated back to the boiler for reuse. A

natural gas-fired plant with a closed-cycle cooling system with cooling towers sited at PBNP

would require the construction of additional cooling infrastructure, although it is possible that

some of the existing intake and discharge structures could be used. Surface-water impacts are

expected to be SMALL; the impacts would be sufficiently minor that they would not noticeably

alter any important attribute of the resource.

The staff assumed that a natural gas-fired plant at an alternate site would use a closed-cycle

cooling system with cooling towers. The staff assumed that surface water would be used for

cooling makeup water and discharge. Intake and discharge would involve relatively small

quantities of water compared to the coal-fired alternative. 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 State. The impacts would be SMALL to MODERATE.

Water-quality impacts from sedimentation during construction were characterized in the GEIS

as SMALL. The staff also noted in the GEIS that operational water-quality impacts would be

similar to, or less than, those from other generating technologies.

* Water Use and Quality - Groundwater

The staff assumed that the groundwater wells would continue to be used for PBNP activities.

Groundwater withdrawals for a natural gas-fired plant at the PBNP site would be equal to or

less than groundwater withdrawals for license renewal. Overall, impacts of a gas-fired power

NUREG-1437, Supplement 23 8-28 August 2005

I 1i
Alternatives

plant with a closed-cycle cooling system at the PBNP site on groundwater use and quality are

considered to be SMALL. Use of groundwater for a gas-fired plant located at an alternate site

is a possibility. Groundwater withdrawals at an alternate site would likely require a State permit.

The impacts will depend on the characteristics of the site and the amount of groundwater used.

Therefore, the impacts at an alternate site are considered to be SMALL-to MODERATE,

depending on the volume of groundwater withdrawn.

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.

A new gas-fired generating plant located in Wisconsin would likely need an operating permit

under the CM. A new combined-cycle natural gas power plant would also be subject to the

new source performance standards for such units found in 40 CFR Part 60, Subparts Da and

GG. These regulations establish emission limits for particulates, opacity, SO2, and NOX.

The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

Subpart P, including a specific requirement for review of any new major stationary source in an

area designated attainment or unclassified under the CAA. PBNP and alternate sites are most

likely in areas that are designated as attainment or unclassified for criteria pollutants with the

exception of ozone.

Section 1 69A of the CAA 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. The EPA issued a new regional haze rule in 1999 (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-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 could be imposed. There are no Class I areas within 160 km (100 mi) of the

PBNP site.

NMC projects the following emissions for the natural gas-fired alternative (NMC 2004):

* Sulfur oxides -15.9 MT/yr (17.5 tons/yr)

• Nitrogen oxides - 2705 MT/yr (2982 tons/yr)

* PM10 particulates - 446 MT/yr (492 tons/yr)

August 2005 8-29 NUREG-1437, Supplement 23
I I

Alternatives

A natural gas-fired plant would also have unregulated carbon dioxide emissions that could

contribute to global warming.

In December 2000, the EPA issued regulatory findings on emissions of hazardous air pollutants

from electric utility steam-generating units (EPA 2000a). Natural gas-fired power plants were

found by the EPA to emit arsenic, formaldehyde, and nickel (EPA 2000a). The EPA determined

that emissions of hazardous air pollutants from natural gas-fired power plants, unlike emissions

from coal- and oil-fired plants, should not be regulated under Section 112 of the CM.

Construction activities would result in temporary fugitive dust. Exhaust emissions would also

come from vehicles and motorized equipment used during the construction process.

The amount and type of emissions produced would likely be the same at PBNP or at an

alternate site. Impacts from the above emissions would be clearly noticeable but would not be

sufficient to destabilize air resources as a whole.

Therefore, the staff concludes that the overall air-quality impact for a new natural gas-fired plant

at the PBNP site or at an alternate site is considered to be MODERATE.

* Waste

Burning natural gas fuel would produce spent scrubber catalysts from NO, emissions controls

and small amounts of solid-waste products (i.e., ash). In the GEIS, the staff concluded that

waste generation from gas-fired technology would be minimal (NRC 1996). Natural gas firing

results in very few combustion by-products because of the clean nature of the fuel.

Waste-generation impacts would be so minor that they would not noticeably alter any important

resource attribute. Construction-related debris would be generated during construction

activities. Overall, the waste impacts would be SMALL for a natural gas-fired plant sited at

PBNP or at an alternate site.

* Human Health

In Table 8-2 of the GEIS, the staff identifies cancer and emphysema as potential health risks

from gas-fired plants (NRC 1996). The risk may be attributable to NO, emissions that

contribute to ozone formation, which in turn contributes to health risks. NO, emissions from any

gas-fired plant would be regulated. For a plant sited in Wisconsin, NO, emissions would be

regulated by the WDNR. Human health effects would not be detectable or would be sufficiently

minor that they would neither destabilize nor noticeably alter any health parameter. Overall, the

impacts of the natural gas-fired alternate sited at PBNP or at an alternate site on human health

are considered to be SMALL.

NUREG-1437, Supplement 23 8-30 August 2005

I I
Alternatives

* Socioeconomics

Construction of a natural gas-fired plant would take approximately 3 years. Peak employment

would be approximately 1200 workers (NRC 1996), although NMC estimated a construction

workforce of 300 workers (NMC 2004). The staff assumed that construction would take place

while PBNP continues operation and would be completed by the time PBNP permanently

ceases operations. During construction, the communities surrounding the PBNP site would

experience demands on housing and public services that could have MODERATE impacts.

These impacts would be tempered by construction workers commuting to the site from other -

counties. After construction, the communities would be impacted by the loss of jobs. The

current PBNP workforce (971 workers) would decline through a decommissioning period to a

minimal maintenance size. The gas-fired plant would introduce a replacement Shared Utility

Payment at PBNP or an alternate site and create approximately 30 new permanent jobs. -For

siting at an alternate site, impacts in Manitowoc County resulting from decommissioning of

Units 1 and 2 would be a loss of jobs and Shared Utility Payment that likely would not be rapidly

replaced based on the slow growth projected for the region. However, the proximity to Green

Bay likely would mitigate the impacts.

In the GEIS (NRC 1996), the staff concluded that socioeconomic impacts from constructing a

natural gas-fired plant would not be very noticeable and that the small operational workforce

would have the lowest socioeconomic impacts of any nonrenewable technology. Compared to

the coal-fired and nuclear alternatives, the smaller size of the construction workforce, the

shorter construction time frame, and the smaller size of the operations workforce would mitigate

socioeconomic impacts. For these reasons, socioeconomic impacts associated with

construction and operation of a natural gas-fired power plant would be SMALL to MODERATE

for siting at PBNP or at an alternate site. Depending on other growth in the area,

socioeconomic effects could be noticed, but they would not destabilize any important

socioeconomic attribute.

Transportation

Transportation impacts associated with construction include temporary commuter traffic for

1200 construction and operating personnel commuting to the plant site and would depend on

the population density and transportation infrastructure in the vicinity of the site. 'The impacts

can be classified as MODERATE for siting at PBNP or at an alternate site. Operational impacts

from a workforce that is smaller in size than the construction workforce would be SMALL. |

Overall, transportation impacts resulting from construction of a natural gas-fired plant at PBNP

or an alternate site would be SMALL to MODERATE.

August 2005 8-31 NUREG-1437, Supplement 23
Alternatives

* Aesthetics

The turbine buildings, exhaust stacks (approximately 76 m [250 ft] tall), cooling towers, the

plume from the cooling towers, and the associated transmission line and gas pipeline

compressors would be visible from off site during daylight hours. Noise and light from the plant

would be detectable off site. Overall, the aesthetic impacts associated with the construction

and operation of a gas-fired plant located at the PBNP site are categorized as SMALL to

MODERATE.

At an alternate site, impacts would be similar to impacts at the PBNP site but would also

depend on surrounding land uses. Overall, the aesthetic impacts associated with an alternate

site are categorized as SMALL to MODERATE.

* Historic and Archaeological Resources

Natural gas-fired generation at the PBNP site or an alternate site would likely require a cultural

resource inventory of 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 impacts from subsequent ground-disturbing actions related to

physical expansion of the plant site.

Before construction at the PBNP site or 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 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 line ROWs, pipelines, or other ROWs). Historic and archaeological

resource impacts need to be evaluated on a site-specific basis. The impacts can generally be

effectively managed, and as such, impacts would vary between SMALL to MODERATE,

depending on the historic and archaeological resources present, and whether mitigation is

necessary.

* Environmental Justice

Disproportionately high and adverse environmental impacts on minority and low-income

populations have not been identified for a natural gas-fired plant built at the PBNP site. Some

impacts on housing availability and prices during construction might occur, and this could

disproportionately affect the minority and low-income populations. The shutdown of PBNP

would result in a loss of approximately 971 jobs. Only 30 employees would be needed to

operate the gas-fired plant. The loss of jobs would possibly be offset by growth in the area and

proximity to Green Bay. Following construction, it is possible that the ability of local government

NUREG-1437, Supplement 23 8-32 August 2005

Il
Alternatives

to maintain social services could be reduced at the same time as diminished economic

conditions reduce employment prospects for minority or low-income populations. Overall,

impacts would be SMALL to MODERATE and would depend on potential economic growth in

the area and the ability of minority or low-income populations to commute to other jobs in the

area.

Impacts at other sites would depend upon the site chosen and the nearby population

distribution, but are likely to also be SMALL to MODERATE.

8.2.2.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a natural gas-fired generation

system at the PBNP site using once-through cooling. The impacts (SMALL, MODERATE, or

LARGE) of this option are the same as the impacts for a natural gas-fired plant using the

closed-cycle system. However, there are minor environmental differences between the

closed-cycle and once-through cooling systems. Table 8-5 summarizes the incremental

differences. -

Table 8-5. Summary'of Environmental Impacts of Natural Gas-Fired Generation with'

Once-Through Cooling at the PBNP Site

Comparison with

Impact Category Impact Closed-Cycle Cooling System

Land Use MODERATE

Ecology

Water Use and Quality -

Surface Water

MODERATE

SMALL

Impacts may be less (e.g., through

elimination of cooling towers).

Potential impacts include entrainment of

fish and shellfish in early life stages,

impingement of fish and shellfish,-and

heat shock.

Increased water withdrawal could lead to

possible water-use conflicts, and the

thermal load would be higher than with

closed-cycle cooling.

Water Use and Quality - No change.

Groundwater

SMALL

Air Quality

Waste

Human Health

Socloeconomics

Transportation

MODERATE No change.

SMALL No change.

SMALL ' No change.

SMALL to MODERATE - No change.

MODERATE No change.

August 2005 8-33 NUREG-1437, Supplement 23
Alternatives

Table 8-5. (contd)

Comparison with

Impact Category Impact Closed-Cycle Cooling System

Aesthetics SMALL to MODERATE Cooling towers would be eliminated.

Historic and Archaeological SMALL to MODERATE No change.

Resources

Environmental Justice SMALL to MODERATE No change.

8.2.3 Nuclear Power Generation

Since 1997 the NRC has certified three new standard designs for nuclear power plants under

10 CFR Part 52, Subpart B. These designs are the 1300-MW(e) U.S. Advanced Boiling Water

Reactor (10 CFR Part 52, Appendix A), the 1300-MW(e) System 80+ Design (10 CFR Part 52,

Appendix B), and the 600-MW(e) AP600 Design (10 CFR Part 52, Appendix C). All of these

plants are light-water reactors. On September 13, 2004, the Commission issued the Final

Design Approval for the AP1 000 Design; the staff anticipates that the certification for this

design will be finalized in December 2005 (NRC 2004). Although no applications for a

construction permit or a combined license based on these certified designs have been

submitted to NRC, the submission of the design certification applications indicates continuing

interest in the possibility of licensing new nuclear power plants. Recent escalation in prices of

natural gas and electricity have made new nuclear power plant construction more attractive

from a cost standpoint. Additionally, System Energy Resources, Inc., Exelon Generation

Company, LLC, and Dominion Nuclear North Anna, LLC, have recently submitted applications

for early site permits for new advanced nuclear power plants under the procedures in

10 CFR Part 52, Subpart A (SERI 2003; Dominion 2003; Exelon 2003). Consequently,

construction of a new nuclear power plant at either the PBNP site or an alternate site is

considered in this section. The staff assumed that the new nuclear plant would have a 40-year

lifetime. Consideration of a new nuclear generating plant to replace PBNP was not included in

the NMC ER.

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 PBNP or an alternate site. The impacts shown in Table S-3 are for a 1 000-MW(e) reactor

and would need only minor scaling to reflect impacts of replacing the 1036 MW(e) of power

currently provided by the PBNP plant. 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. The summary of NRC's findings on NEPA issues for license

renewal of nuclear power plants in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, is also

NUREG-1437, Supplement 23 8-34 August 2005

I M
Alternatives

relevant, although not directly applicable, for consideration of environmental impacts associated

with the operation of a replacement nuclear power plant. Additional environmental impact

information for a replacement nuclear power plant using closed-cycle cooling is presented in

Section 8.2.3.1, and for one using once-through cooling in Section 8.2.3.2.

In addition to the impacts discussed below for a nuclear plant at either the PBNP site or an

alternate site, impacts would occur offsite as a result of uranium mining. Impacts of mining

include an increase in fugitive dust emissions; surface water runoff; erosion; sedimentation;

changes in water quality; disturbance of vegetation and wildlife; disturbance of historic and

archaeological resources; changes in land use; and impacts on employment.

The magnitude of these offsite impacts would largely be proportional to the amount of land

affected by mining.. However, there would be no 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 for Units 1 and 2.

8.2.3.1 Closed-Cycle Cooling System

The overall impacts of the nuclear generating system are discussed in the following sections.

The impacts are summarized in Table 8-6. The extent of impacts at an alternate site will

depend on the location of the particular site selected.

August 2005 8-35 NUREG-1437, Supplement 23
Alternatives

Table 8-6. Summary of Environmental Impacts of New Nuclear Power Generation Using

Closed-Cycle Cooling at the PBNP Site and an Alternate Site

PBNP Site Alternate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Land Use MODERATE

Ecology SMALL to

MODERATE

Would require approximately

200 to 400 ha (500 to

1000 ac) for the plant.

Would use up to 400 ha

(1000 ac) of undeveloped and

farmland areas at the current

PBNP site. There would be

potential habitat loss and

fragmentation and reduced

productivity and biological

diversity.

MODERATE

to LARGE

Same as PBNP site plus

land for transmission line.

MODERATE

to LARGE

Water Use and

Quality -

Surface Water

Water Use and

Quality -

Groundwater

SMALL

SMALL

Would use parts of the

existing cooling system (intake

and discharge structures).

Operational impacts would be

similar or less than PBNP.

Little groundwater would be

used.

SMALL to

MODERATE

SMALL to

MODERATE

Impacts would depend on

the location and ecology

of the site, the surfacewater body used for

intake and discharge, and

transmission line route.

There would be potential

habitat loss and

fragmentation and

reduced productivity and

biological diversity.

Impact would depend on

the volume of water

withdrawn and discharged

and the characteristics of

the surface-water body.

Impact would depend on

the volume of water

withdrawn and discharged

and the characteristics of

the surface-water or

groundwater source.

Impacts would be the

same as at the PBNP

site.

Impacts would be the

same as at the PBNP

site.

August 2005

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.

Waste impacts for an

operating nuclear power plant

are set out in 10 CFR Part 51,

Appendix B, Table B-1.

Debris would be generated

and removed during

construction.

SMALL

Waste SMALL SMALL

NUREG-1437, Supplement 23 8-36

I 11
Alternatives

Table 8-6. (contd)

PBNP Site Alternate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Human Health - SMALL *Human health impacts for an

operating nuclear power plant

are set out in 10 CFR Part 51,

Subpart A, Appendix B,

Table B-1.

SMALL Impacts would be the

same as at the PBNP

site.

Socioeconomics SMALL to

MODERATE

During construction, impacts

would be MODERATE. Up to

2500 workers would be

employed during the peak of

the 6-year construction period.

The operating workforce is

assumed to be similar to

PBNP; the Shared Utility

Payment would be preserved.

Impacts during operation

would be SMALL.-

MODERATE

to LARGE

Construction impacts

depend on location.

Impacts at a rural location

could be LARGE.

Manitowoc County would

experience loss of Shared

Utility Payment and

employment, possibly

offset by proximity to

Green Bay.

Transportation SMALL to Transportation impacts

LARGE associated with construction

workers could be MODERATE

to LARGE. Transportation

impacts of commuting plant

personnel would be SMALL.

SMALL to Transportation impacts of

LARGE construction workers

could be MODERATE to

LARGE. Transportation

impacts of commuting

plant personnel could be

SMALL to MODERATE.'

Aesthetics

Historic and

Archaeological

Resources

SMALL to

MODERATE

SMALL to

MODERATE

No exhaust stacks would be

needed. Cooling towers and

plumes would be visible.

Impact could be mitigated by landscaping and appropriate

color selection for buildings.

Visual impact at night could

be mitigated by reduced use

of lighting and appropriate

shielding. Noise impacts

would be relatively small and

could be mitigated.

Some construction would

affect previously developed

parts of the PBNP site; a

cultural resource inventory

should minimize any impacts

on undeveloped lands.

SMALL to

MODERATE

SMALL to

MODERATE

Impacts would depend on

characteristics of the site

but would be generally

similar to PBNP site

impacts.

Impacts would be the

same as at PBNP; any

potential impacts can

likely be effectively

managed.

August 2005 8-37 NUREG-1437, Supplement 23
I ~~ rm

Alternatives

Table 8-6. (contd)

PBNP Site Alternate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Environmental SMALL to Impacts on minority and SMALL to Impacts would vary

Justice MODERATE low-income communities MODERATE depending on population

should be similar to those distribution and makeup

experienced by the population at the site. Impacts to

as a whole. Some impacts on minority and low-income

housing might occur during populations associated

construction. with closure of PBNP

Units 1 and 2 could be

mitigated by proximity to

Green Bay.

* Land Use

According to the GEIS, a new nuclear unit at an alternate site would require approximately

200 to 400 ha (500 to 1000 ac) of land (NRC 1996). Additional land could be needed for an

electric power transmission line, a rail spur to bring construction materials to the plant site,

and/or pipelines to supply cooling-water intake and discharge. Depending particularly on

transmission line routing, siting a new nuclear plant with closed-cycle cooling at an alternate site

would result in MODERATE to LARGE land-use impacts.

The existing facilities and infrastructure at the PBNP site would be used to the extent

practicable, which would limit the amount of new construction that would be required.

Specifically, the staff assumed that a replacement nuclear power plant would require a new

closed-cycle system including cooling towers; however, the existing intake and discharge

structures would be used if practicable. In addition, the staff assumed other existing structures

would be used including the switchyard, offices, and transmission line ROWs. Much of the land

that would be used has been previously disturbed by farming. It is assumed that PBNP would

continue to operate while the new unit is built.

A replacement nuclear power plant at the PBNP site would alter approximately 200 to 400 ha

(500 to 1000 ac) of land to industrial use. There would be no net change in land needed for

uranium mining because the area of land needed for uranium mining to supply fuel for the new

nuclear plant would be the same area as land needed for uranium mining to supply fuel for

PBNP.

The impact of a replacement nuclear generating plant on land use at the existing PBNP site is

best characterized as MODERATE. The impact would be greater than the OL renewal

alternative.

NUREG-1437, Supplement 23 8-38 August 2005

I I
Alternatives

Land-use impacts at an alternate site would be similar to siting at PBNP except for the land

needed for a transmission line to connect to existing lines.: Assuming a 64-k m (40-mi)

transmission line, an additional 678 ha (1675 ac) would be needed. In addition, it may be

necessary to construct a rail spur to bring in equipment during construction at an alternate site.

Depending particularly on transmission line routing, siting a new nuclear plant at an alternate

site would result in MODERATE to LARGE land-use impacts.

Ecology

Locating a replacement nuclear power plant at the PBNP site would alter ecological resources

because of the need to convert roughly 200 to 400 ha (500 to 1000 ac) of land to industrial use.

Most of this land, however, would have been previously disturbed; however, additional land

would have to be acquired. Impacts on terrestrial resources would result from cooling tower

drift. Impacts to aquatic resources would result from intake makeup water and the possible

entrainment and impingement of fish and blowdown from the circulating water system affecting

receiving water quality.

Siting at PBNP would have a SMALL to MODERATE ecological impact that would be greater

than renewal of the Unit 1 and 2 OLs.

At an alternate site, there would be construction impacts and new incremental operational

impacts. Even if the site was an already-developed alternate site, the impacts would alter the

ecology. Impacts could include wildlife habitat loss, reduced productivity, habitat fragmentation,

and a local reduction in biological diversity. Use of cooling makeup water from a nearby

surface-water body could have adverse aquatic resource impacts. Construction and

maintenance of the transmission line, if needed, would have ecological impacts. Overall, the

ecological impacts at an alternate site would be MODERATE to LARGE.

Water Use and Quality - Surface Water

The replacement nuclear plant alternative at the PBNP site is assumed to use a new

closed-cycle cooling system (including cooling towers) and the existing intake and discharge

structures. This would minimize incremental impacts to water use and quality. Surface-water

impacts are expected to be SMALL; the impacts would be sufficiently minor that they would not

noticeably alter any important attribute of the resource.

For alternate sites, the impact on 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 State under

its NPDES program, including compliance with revised Clean Water Act Section 316(b)

requirements. The impacts would be SMALL to MODERATE.

August 2005 8-39 NUREG-1437, Supplement 23
Alternatives

* Water Use and Quality - Groundwater

The staff assumed that a new nuclear power plant located at the PBNP site would obtain

potable, process, and fire-protection water from the groundwater wells used for Units 1 and 2,

similar to the current practice for PBNP (see Section 2.2.2). Therefore, the impact to

groundwater would be SMALL.

Use of groundwater for a nuclear power plant located at an alternate site is a possibility for the

cooling system and other uses. Any groundwater withdrawal would require a permit from the

WDNR. Therefore, the impact to groundwater would be SMALL to MODERATE depending on

the volume of water withdrawn.

* Air Quality

Construction of a new nuclear plant located at the PBNP site or an alternate site would result in

fugitive emissions during the six-year construction period. Exhaust emissions would also come

from vehicles and motorized equipment used during the construction process. An operating

nuclear plant would have minor air emissions associated with diesel generators and other minor

intermittent sources. Emissions for a plant sited in Wisconsin would be regulated under the

CAA. Overall, emissions and associated impacts for a plant located at the existing PBNP site

or an alternate site are considered to be SMALL.

* Waste

The waste impacts associated with operation of a nuclear power plant are described in

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, including operational impacts such as the

potential for degradation of groundwater quality or radiation exposure on- and off-site;

transportation impacts; waste storage and disposal impacts; and waste generated during.

refurbishment and/or decommissioning. In addition, construction-related debris would be

generated during construction activities and removed to an appropriate disposal site. Overall,

waste impacts are considered to be SMALL.

Siting the replacement nuclear power plant at a location other than the PBNP site would not

alter waste generation. Therefore, the impacts would be SMALL.

NUREG-1437, Supplement 23 8-40 August 2005

II
Alternatives

* 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, including the potential for on- and off-site radiation -

exposures during operation, refueling, waste management and transportation activities,

refurbishment, and decommissioning. Overall, human health impacts are considered to be

SMALL.

Siting the replacement nuclear power plant at a location other than the PBNP site would not

alter human health impacts. Therefore, the impacts would be SMALL.

* Socioeconomics

The construction period and the peak workforce associated with construction of a new nuclear

power plant are currently unquantified (NRC 1996). In the absence of quantitative data, staff

assumed a construction period of 6 years and a-peak workforce of 2500. The staff assumed

that construction would take place while the existing nuclear units continue operation and would

be completed by the time PBNP permanently ceases operation. During construction, the

communities surrounding the PBNP site would experience demands on housing and public

services that could have MODERATE impacts. These impacts would be tempered by -

construction workers commuting to the site from other counties. After construction, the

communities would be impacted by the loss of the construction jobs, although this loss would

be possibly offset by the proximity to Green Bay.

The replacement nuclear units are assumed to have an operating workforce comparable to the

971 workers currently working at PBNP. The replacement nuclear units would provide a new

tax base to offset the loss of tax base associated with decommissioning of PBNP. For all of

these reasons, the appropriate characterization of nontransportation socioeconomic impacts for

replacement nuclear units constructed at the PBNP site would be SMALL to MODERATE; 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 PBNP site,

would still experience the impact of operational job losses at PBNP (although these losses

would be potentially tempered by proximity to Green Bay). The communities around the new

site would have to absorb the impacts of a large, temporary workforce (up to 2500 workers at

the peak of construction) superimposed on a refueling outage workforce of approximately 300

and a permanent workforce of approximately 971 workers. In the GEIS (NRC 1996), the staff

indicated that socioeconomic impacts at a rural site would be larger than at an urban site.

because more of the peak construction workforce would need to move to the area to work. The

August 2005 8-41 NUREG-1437, Supplement 23
In,

Alternatives

PBNP site is within commuting distance of Green Bay and therefore is not considered a rural

site. Alternate sites would need to be analyzed on a case-by-case basis. Socioeconomic

impacts at a rural site could be LARGE.

* Transportation

During the 6-year construction period, up to 2500 construction workers would be working at the

PBNP site in addition to the 971 workers at Units 1 and 2. The addition of the construction

workers could place significant traffic loads on existing highways especially during normal

refueling outages for Units 1 and 2. Such impacts would be MODERATE to LARGE.

Transportation impacts related to commuting of plant operating personnel would be similar to

current impacts associated with operation of PBNP and are considered to be SMALL.

Transportation-related impacts associated with commuting construction workers at an alternate

site are site dependent, but could be MODERATE to LARGE. Transportation impacts related to

commuting of plant operating personnel would also be site dependent, but can be characterized

as SMALL to MODERATE.

* Aesthetics

The containment buildings for a replacement nuclear power plant sited at PBNP, other

associated buildings, cooling towers, and cooling tower plumes would likely be visible over

many miles in daylight hours. The replacement nuclear units would also likely 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; however, cooling towers constructed for the closed-cycle system would be visible.

Therefore, impacts can be characterized as MODERATE.

Noise impacts from a new nuclear plant would be similar to those from the existing PBNP.

Mitigation measures, such as reduced use or no use of outside loudspeakers, could be

employed to reduce noise levels and maintain SMALL noise impacts.

At an alternate site, there would be an aesthetic impact from the buildings, cooling towers, and

the plume associated with the cooling towers. There would also be an aesthetic impact

associated with construction of a new transmission line. Noise and light from the plant would

be detectable off site. Overall the aesthetic impacts associated with locating a nuclear power

plant at an alternate site can be categorized as SMALL to MODERATE.

NUREG-1437, Supplement 23 8-42 August 2005

I I
Alternatives

* Historic and Archaeological Resources

A new nuclear power plant at the PBNP site or an alternate site would likely require a cultural

resource inventory of 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 impacts from subsequent ground-disturbing actions related to

physical expansion of the plant site.

Before construction at the PBNP site or 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 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 line ROWs, rail lines, or other ROWs). Historic and archaeological

resource impacts need to be evaluated on a site-specific basis. The impacts can generally be

effectively managed, and as such, impacts would vary between SMALL and MODERATE,

depending on the historic and archaeological resources present.

* Environmental Justice

Disproportionately high and adverse environmental impacts on minority and low-income

populations have not been identified for a replacement nuclear power plant at the PBNP site.

Some impacts on housing availability and prices during construction might occur, which could

disproportionately affect minority and low-income populations. Shutdown activities at PBNP

would result in a decrease in employment of approximately 941 operating employees, with the

likelihood that a portion of these losses would be absorbed with the'startup and operation of the

new nuclear unit. Overall, impacts would be SMALL to MODERATE and would depend on

potential economic growth in the area, the ability of minority or low-income populations to

commute to other jobs in the area, and the transition of the workforce from the existing Units 1

and 2 to the new unit. -

Impacts at other sites would depend upon the site chosen and the nearby population

distribution but are also likely to be SMALL to MODERATE.

8.2.3.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a nuclear power plant at the

PBNP site using once-through cooling. The impacts (SMALL, MODERATE, or LARGE) of this

option are the same as the impacts for a nuclear power plant using a closed-cycle system,

However, there are minor environmental differences between the closed-cycle and

once-through cooling systems. Table 8-7 summarizes the incremental differences.

August 2005 8-43 NUREG-1437, Supplement 23
I m

Alternatives

Table 8-7. Summary of Environmental Impacts of a New Nuclear Power Plant with

Once-Through Cooling at the PBNP Site

Comparison with

Impact Category . Impact Closed-Cycle Cooling System

Land Use MODERATE Impacts may be less (e.g., through elimination

of cooling towers).

Ecology SMALL to Possible impacts include entrainment of fish

MODERATE and shellfish in early life stages, impingement of

fish and shellfish, and heat shock.

Water Use and Quality - SMALL Increased water withdrawal could lead to

Surface Water possible water-use conflicts, and the thermal

load would be higher than with closed-cycle

cooling.

Water Use and SMALL No change.

Quality - Groundwater

Air Quality SMALL No change.

Waste SMALL No change.

Human Health SMALL No change.

Socioeconomics SMALL to No change.

MODERATE

Transportation SMALL to LARGE No change.

Aesthetics SMALL to Cooling towers would be eliminated.

MODERATE

Historic and Archaeological SMALL to No change.

Resources MODERATE

Environmental Justice SMALL to No change.

MODERATE

8.2.4 Purchased Electrical. Power

If available, power purchased from other sources could potentially obviate the need to renew

the PBNP OLs. It is unlikely, however, that a firm power supply with a sufficient baseload would

be available to replace the capacity of PBNP Units 1 and 2.

Currently, Wisconsin Electric Power Company (WEPCO) purchases about 600 MW(e) of power

annually to meet customer demand and supplement power generation (NMC 2004). Similarly,

Wisconsin is a net importer of power; it imported 11.4 billion kWh of electricity in 2002

(NMC 2004).

NUREG-1437, Supplement 23 8-44 August 2005

I I
Alternatives

Power imported from Canada or Mexico is unlikely to be available to replace PBNP capacity. In

Canada, 60 percent of the country's electrical generation capacity is derived from renewable

energy sources,-principally hydropower (DOE/EIA 2004b). Canada has plans to continue

developing hydroelectric power: more than 6000 MW(e) of hydroelectric capacity are either

under construction or planned (DOE/EIA 2004b). Canada's nuclear generation capacity is

projected to increase by 23 percent by 2025, by bringing four Pickering reactor units in Ontario

Province back into operation over the next several years to assist in replacing coal-fired

generation (DOE/EIA 2004b). The EIA projects that total gross United States imports of

electricity from Canada and Mexico will gradually increase from 38.4 billion kWh in year 2001 to

48.9 billion kWh in year 2005 and then gradually decrease to 15.2 billion kWh in year 2025 - --

(DOE/EIA 2004b). It is unlikely that electricity imported from Canada or Mexico would be able

to replace the existing PBNP capacity through the license renewal period, because less imports

of electricity from Canada and Mexico will be available through the license renewal period.

If power to replace the existing PBNP capacity were to be purchased from sources within the

United States or a foreign country, the generating technology would likely be one of those '.

described in this SEIS and in the GEIS (probably coal, natural gas, or nuclear). The description

of the environmental impacts of other technologies in Chapter 8 of the GEIS is representative of

the purchased electrical power alternative to renewal of the PBNP OLs. Thus, the

environmental impacts of imported power would still occur but would be located elsewhere

within the region, nation, or another country.

8.2.5 Other Alternatives

Other generation technologies considered by NRC are discussed in the following subsections.

8.2.5.1 Wind Power

Wind power, by itself, is not suitable for large baseload 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 (less than 30 percent). Wind power, in conjunction with energy

storage mechanisms, might serve as a means of providing baseload power. However, current

energy storage technologies are too expensive for wind power to serve as a large baseload

generator.

Since 1998, 55 utility scale wind turbines, each rated for 660 kW(e), have been installed at five

locations in Wisconsin (NMC 2004). Wisconsin is in a wind power Class 2 region (average

wind speeds'at 10-m (30-ft) elevation-of 5.6 to 6.4 m/s [12.6 to 14.3 mph]). On the coast,

Wisconsin is in a wind power Class 3 region (average wind speeds at 1 0-m (30-ft) elevation of

6.4 to 7.0 m/s [14.3 to 15.7 mph]))(DOE 2004a). In wind power Class 2 areas, wind turbines

are economically marginal for development, but in' Class 3 areas, they may be suitable for

August 2005 8-45 NUREG-1437, Supplement 23
I m

Alternatives

future technology (DOE 2004a). The staff concludes that locating a wind-energy facility on or

near the PBNP site would not be economically feasible given the current state of wind-energy

generation technology and because energy storage technologies are too expensive for wind

power to serve as a large baseload generator.

Access to many land based wind power sites near the coast would likely require extensive road

building, as well as clearing (for towers and blades) and leveling (for tower bases and

associated facilities) in variable terrain. Although impacts would depend on the site chosen,

common issues of concern include visual impacts, noise generation, and bird and bat collisions.

Also, many of the best quality wind sites are on ridges and hilltops that could have greater

archaeological sensitivity than surrounding areas. For these reasons, development of

large-scale, land based wind power facilities are likely to be costly and also have MODERATE

to LARGE impacts on aesthetics, archaeological resources, land use, and terrestrial ecology.

8.2.5.2 Solar Power

Solar technologies use the sun's energy and light to provide heat and cooling, light, hot water,

and electricity for homes, businesses, and industry. In the GEIS, the staff noted that by its

nature, solar power is intermittent. Therefore, solar power by itself is not suitable for baseload

capacity and is not a feasible alternative to license renewal of PBNP. The average capacity

factor of photovoltaic cells is about 25 percent, and the capacity factor for solar thermal

systems is about 25 percent to 40 percent. Solar power, in conjunction with energy storage

mechanisms, might serve as a means of providing baseload power. However, current energy

storage technologies are too expensive to permit solar power to serve as a large baseload

generator. Therefore, solar power technologies (photovoltaic and thermal) cannot currently

compete with conventional fossil-fueled technologies in grid-connected applications, due to high

costs per kilowatt of capacity (NRC 1996).

There are substantial impacts to natural resources (wildlife habitat, land-use, and aesthetic

impacts) from construction of solar generating facilities. As stated in the GEIS, land

requirements are high-1 4,000 ha (35,000 ac) per 1000 MW(e) for photovoltaic systems and

approximately 5700 ha (14,000 ac) per 1000 MW(e) for solar thermal systems. Neither type of

solar electric system would fit at the PBNP site, and both would have large environmental

impacts at an alternate site.

The PBNP site receives approximately 3 to 3.5 kWh of solar radiation per square meter per day

(NMC 2004), compared to 6 to 8 kWh of solar radiation per square meter per day in areas of

the western United States, such as California, which are most promising for solar technologies

(DOE/EIA 2000). Because of the natural resource impacts (land and ecological), the area's

relatively low rate of solar radiation, and high cost, solar power is not deemed a feasible

baseload alternative to renewal of the PBNP OLs. Some solar power may substitute for electric

NUREG-1437, Supplement 23 8-46 August 2005

I I
Alternatives

power in rooftop and building applications. Implementation of nonrooftop solar generation on a

scale large enough to replace PBNP would likely result in LARGE environmental impacts.'

8.2.5.3 Hydropower

Wisconsin has an estimated 26.2 MW(e) of undeveloped hydroelectric resources (Idaho

National Engineering Laboratory 1996). This amount is far less than needed to replace the

1036 MW(e) capacity of PBNP. In Section 8.3.4 of the GEIS, the staff points out hydropower's

percentage of United States generating capacity is expected to decline because hydroelectric

facilities have become difficult to site as a'result'of public concern about flooding, destruction of

natural habitat, and alteration of natural river courses.

The staff estimated in the GEIS that land requirements for hydroelectric power are

approximately 400,000 ha (1 million ac) per 1000 MW(e). Replacement of PBNP generating

capacity would require flooding more than this amount of land. Because of the relatively small

number of undeveloped hydropower resources in Wisconsin and the large land-use and related

environmental and ecological resource impacts associated with siting hydroelectric facilities

large enough to replace PBNP, the staff concludes that local hydropower on its own is not a

feasible alternative to renewing PBNP OLs. Any attempts to site hydroelectric facilities large

enough to replace PBNP would result in LARGE environmental impacts.

8.2.5.4 Geothermal Energy

Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

power where available. However, geothermal technology is not widely used as baseload

generation due to the limited geographical availability of the resource and immature status of

the technology (NRC 1996). As illustrated by Figure 8-4 in the GEIS, geothermal plants are

most likely to be sited in the western continental United States, Alaska, and Hawaii where

hydrothermial reservoirs are prevalent. There is no feasible midwestern location for geothermal

capacity to serve as an alternative to PBNP. The staff concludes that geothermal energy is not

a feasible alternative to renewal of the PBNP OLs.

8.2.5.5 Wood Waste '

The use of wood waste to generate electricity is largely'limited to those states with significant

wood resources, such as California, Maine, Georgia, Minn'esota, Oregon, Washington, and

Michigan. Electric power is generated in these states by the pulp,- paper, and paperboard

industries, which consume wood and wood waste for energy, benefitting from the use of waste

materials that could otherwise represent a disposal problem.

August 2005 8-47- NUREG-1 437, Supplement 23
Alternatives

A wood-burning facility can provide baseload power and operate with an average annual

capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC 1996).

The fuels required are variable and site specific. A significant barrier to the use of wood waste

to generate electricity is the high delivered-fuel cost and high construction cost per MW of

generating capacity. The larger wood-waste power plants are only 40 to 50 MW(e) in size.

Estimates in the GEIS suggest that the overall level of construction impact per MW of installed

capacity should 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.

Due to uncertainties associated with obtaining sufficient wood and wood waste to fuel a

baseload generating facility, ecological impacts of large-scale timber cutting (e.g., soil erosion

and loss of wildlife habitat), and high inefficiency, the staff has determined that wood waste is

not a feasible alternative to renewing the PBNP OLs.

8.2.5.6 Municipal Solid Waste

Municipal waste combustors incinerate the waste and use the resultant heat to generate

steam, hot water, or electricity. The combustion process can reduce the volume of waste by up

to 90 percent and the weight of the waste by up to 75 percent (DOE/EIA 2004a). Municipal

waste combustors use three basic types of technologies: mass burn, modular, and

refuse-derived fuel (DOE/EIA 2001). Mass burning technologies are most commonly used in

the United States. This group of technologies process raw municipal solid waste "as is," with

little or no sizing, shredding, or separation before combustion.

Growth in the municipal waste combustion industry slowed dramatically during the 1990s after

rapid growth during the 1980s. The slower growth was due to three primary factors: (1) the

Tax Reform Act of 1986 (Public Law 99-514, 100 Stat. 2085), which made capital-intensive

projects such as municipal waste combustion facilities more expensive relative to less

capital-intensive waste disposal alternatives such as landfills; (2) the 1994 Supreme Court

decision (C&A Carbone, Inc. v. Town of Clarkstown), which 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; and (3) increasingly stringent environmental

regulations that increased the capital cost necessary to construct and maintain municipal waste

combustion facilities (DOEIEIA 2001).

NUREG-1437, Supplement 23 8-48 August 2005

I I
Alternatives

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, however, it is unlikely that many landfills

will begin converting waste to energy because of unfavorable economics, particularly with

inflation-adjusted electricity prices declining. .

Municipal solid waste combustors generate an ash residue that is buried in landfills. The ash

residue is composed of bottom ash and fly ash. 'Bottom ash refers to that portion of the

unburned waste that falls to the bottom of the grate or fumace. Fly'ash-represents the small

particles that rise from the furnace during the combustion process. Fly ash is'generally

removed from flue gases using fabric filters and/or scrubbers (DOE/EIA 2001).

Currently there are approximately 89 waste-to-energy plants operating in the United States.

These plants generate approximately 2500 MW(e), or an' average of approximately 28 MW(e)

per plant (Integrated Waste Services Association 2004), much smaller than needed to replace

the 1036 MW(e) of PBNP.

The initial capital costs'for municipal solid-waste plants are greater than for comparable steam

turbine technology at wood-waste facilities. This is due to the need for specialized

waste-separation and -handling equipment for municipal solid waste (NRC 1996). Furthermore,

estimates in the GEIS suggest that the overall level of construction impact from a waste-fired

plant should be approximately the same as that for a coal-fired plant. Additionally, waste-fired

plants have the same or greater operational impacts' (including impacts on the aquatic - '

environment, air, and waste disposal). Some of these impacts would be moderate, but still

larger than the environmental effects of license renewal of PBNP. Therefore, municipal solid

waste would not be a feasible alternative to renewal of the PBNP OLs, particularly at the scale

required.

8.2.5.7 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 staff points'out that nbne'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 PBNP. For these reasons, such fuels do

not offer a feasible alternative to renewal of the PBNP OLs. -

8.2.5.8 Fuel Cells

Fuel cells work without combustion and its environmental side effects. Power is produced

electrochemically by passing a hydrogen-rich fuel over an anode and air over a cathode and

separating the two by an electrolyte. The only by-products are heat, water, and carbon dioxide.

August 2005 , 8-49 NUREG-1437, Supplement 23
Alternatives

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.

Phosphoric acid fuel cells are generally considered first-generation technology. These fuel cells

are commercially available at cost of approximately $4500 per kW of installed capacity

(DOE 2004b). Higher-temperature second-generation fuel cells achieve higher

fuel-to-electricity and thermal efficiencies. The higher temperatures contribute to improved

efficiencies and give the second-generation fuel cells the capability to generate steam for

cogeneration and combined-cycle operations.

DOE has a new initiative to reduce costs to as low as $400 per kW by the end of the decade

(DOE 2004b). For comparison, the installed capacity cost for a natural gas-fired,

combined-cycle plant is about $456 per kW (DOE/EIA 2004a). As market acceptance and

manufacturing capacity increase, natural gas-fueled fuel cell plants in the 50- to 100-MW range

are projected to become available. At the present time, however, fuel cells are not

economically or technologically competitive with other alternatives for baseload electricity

generation. Fuel cells are, consequently, not a feasible alternative to renewal of the

PBNP OLs.

8.2.5.9 Delayed Retirement

WEPCO has no current plans to retire any existing generating units. For this reason, delayed

retirement of other WEPCO generating units would not be a feasible alternative to renewal of

the PBNP OLs.

8.2.5.10 Utility-Sponsored Conservation

Historically, WEPCO has maintained State-wide residential, commercial, and industrial

programs to reduce both peak demands and daily energy consumption. These programs are

commonly referred to as demand-side management (DSM). In 1999, these DSM programs

resulted in a State-wide reduction of demand of 67 MW(e) and an energy savings of

approximately 393,000 MWh (NMC 2004). These load reductions are acknowledged in load

forecasts; therefore, they cannot be used as credits to offset the power generated by PBNP.

An additional 1000 MW(e) of savings, or a 750 percent increase in the State-wide reduction in

peak demand after 2010, would be required to offset the power generated by PBNP.

Therefore, the conservation option by itself is not considered a reasonable alternative to

renewing the PBNP OLs.

NUREG-1437, Supplement 23 8-50 August 2005

Il
Alternatives

8.2.6 Combination of Alternatives

Even though individual alternatives to PBNP might not be sufficient on their own to replace

PBNP generating capacity due to the small size of the resource or lack of cost-effective

technologies, it is conceivable that a combination of alternatives might be cost effective.

As discussed in Section 8.2, PBNP has a combined net electrical output of 1036 MW(e). For

the coal-fired alternative, the staff assumed the construction of two 600 MW(e) units that would

operate at about 78 percent efficiency (to produce 1045 MW[e]), and for the natural gas-fired

alternative, the staff assumed four 380 MW(e) units operating at 85 percent efficiency as

potential replacements for PBNP.

There are many possible combinations of alternatives. Table 8-8 contains a summary of the

environmental impacts if one assumed a combination of alternatives consisting of two,

380 MW(e) of combined cycle natural gas-fired units generating power at 85 percent efficiency

(net 646 MW[e]) using closed-cycle cooling, 200 MW(e) of purchased power, and 190 MW(e)

gained from additional DSM measures. The impacts are based on the gas-fired generation

impact assumptions discussed in Section 8.2.2, adjusted for the reduced generating capacity.

While the DSM measures would have few environmental impacts, operation of the new

gas-fired plant would result in increased emissions and environmental impacts. The staff

concludes that it is very unlikely that the environmental impacts of any reasonable combination

of generating and conservation options could be reduced to the level of impacts associated with

renewal of the PBNP OLs.

August 2005 8-51 NUREG-1437, Supplement 23
Alternatives

Table 8-8. Summary of Environmental Impacts of 646 MW(e) of Natural Gas-Fired

Generation, 200 MW(e) of Purchased Power, and 190 MW(e) from

Demand-Side Management Measures (Combination of Alternatives)

PBNP Site Alternate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Land Use MODERATE

Ecology

Water Use and

Quality -

Surface Water

MODERATE

SMALL

Would require 10 ha (25 ac)

for power block, offices, roads,

and parking areas. There

would be an additional impact

for construction of an

underground gas pipeline.

Would use undeveloped areas

and farmlands at the current

PBNP site, plus gas pipeline

through habitat. There would

be potential habitat loss and

fragmentation and reduced

productivity and biological

diversity.

Would use part of the existing

cooling system (intake and

discharge structures).

Operational impacts would be

similar or less than PBNP.

Little groundwater would be

used.

to LARGE

MODERATE Would require 10 ha

MODERATE

SMALL to

MODERATE

(25 ac) for power block,

offices, roads, and

parking areas. There

would be additional

impacts for construction

of an underground gas

pipeline and a

transmission line.

Impact would depend on

the location and ecology

of the site, the

surface-water body used

for intake and discharge,

and transmission and

pipeline routes. There

would be potential habitat

loss and fragmentation

and reduced productivity

and biological diversity.

Impact would depend on

the volume of water

withdrawal and discharge

and characteristics of

surface-water body.

Impact would depend on

the volume of water

withdrawal and discharge.

Impacts would be the

same as siting at PBNP.

Water Use and

Quality -

Groundwater

Air Quality

SMALL SMALL to

MODERATE

MODERATE Natural Gas-Fired Units:

Sulfur oxides

* 8.0 MT/yr (8.8 tons/yr)

Nitrogen oxides

* 1353 MT/yr (1491 tons/yr)

PM, 0 particulates

* 223 MT/yr (246 tons/yr)

Some hazardous air pollutants

would be released..

MODERATE

NUREG-1437, Supplement 23 8-52 August 2005

IJ
Alternatives

Table 8-8. (contd)

PBNP Site Alternate Site

IMPACT

CATEGORY IMPACT COMMENTS IMPACT COMMENTS

Waste SMALL

Human Health

Socioeconomics

Transportation

Aesthetics

Historic and

Archaeological

Resources

Environmental

Justice

SMALL

SMALL to

MODERATE

SMALL to

MODERATE

SMALL to

MODERATE

A small amount of ash would

be produced from gas-fired

plant.

Impacts are considered to be

minor.

During construction, impacts

would be MODERATE. Up to

1200 additional workers would

be employed during the peak

of the 3-year construction

period, followed by a reduction

from the current PBNP

workforce of 971 to 30; the

Shared Utility Payment would

be preserved. Impacts during

operation would be SMALL.

Transportation impacts

associated with construction

workers would be

MODERATE. Impacts

associated with operations

would be SMALL.

Aesthetic impacts of plant

units, exhaust stacks, and

cooling towers would be

MODERATE.

SMALL

SMALL

SMALL to

MODERATE

SMALL to

MODERATE

SMALL to*

MODERATE

SMALL to

MODERATE

SMALL to

MODERATE

The same waste would be

produced as at PBNP.

Impacts are considered to

be minor.

Constwuction impacts

depend on location, but

could be significant if the

location is in a more rural

area than PBNP.

Manitowoc County would

experience a loss of

Shared Utility Payment

and employment, - -

potentially offset by

proximity to Green Bay.

Transportation impacts

associated with

construction workers

would be MODERATE.

Impacts associated with

operations would be

SMALL.

Impacts would depend on

characteristics of site but

would be generally similar

to those at the PBNP site.

Impacts would be the

same as siting PBNP; any

potential impacts could

likely be effectively

managed.

Impacts would vary.

depending on the

population distribution

and makeup at the site.

SMALL

MODEl

to Some construction would

FIATE affect previously developed

parts of PBNP; a cultural

resource inventory should

minimize any impacts on

undeveloped lands and

farmlands.

to Impacts on minority and

RATE low-income communities

should be similar to those

- experienced by the population

as a whole. Some impacts on

housing may occur during

construction.

SMALL

MODEl

August 2005 8-53 NUREG-1 437, Supplement 23
Alternatives

8.3 Summary of Alternatives Considered

The environmental impacts of the proposed action, license renewal, are SMALL for all impact

categories (except collective offsite radiological impacts from the fuel cycle and from HLW and

spent fuel disposal, for which a single significance level was not assigned). The alternative

actions, i.e., no-action alternative (discussed in Section 8.1), new generation alternatives (from

coal, natural gas, and nuclear discussed in Sections 8.2.1 through 8.2.3, respectively),

purchased electrical power (discussed in Section 8.2.4), alternative technologies (discussed in

Section 8.2.5), and the combination of alternatives (discussed in Section 8.2.6) were

considered.

The no-action alternative would require the replacement of electrical generating capacity by

(1) DSM and energy conservation, (2) power purchased from other electricity providers,

(3) generating alternatives other than PBNP, or (4) some combination of these options. For

each of the new generation alternatives (coal, natural gas, and nuclear), the environmental

impacts would not be less than the impacts of license renewal. For example, the

land-disturbance impacts resulting from construction of any new facility would be greater than

the impacts of continued operation of PBNP. The impacts of purchased electrical power

(imported power) would still occur, but would occur elsewhere. Alternative technologies are not

considered feasible at this time, and it is very unlikely that the environmental impacts of any

reasonable combination of generation and conservation options could be reduced to the level of

impacts associated with renewal of the PBNP OLs.

The staff concludes that the alternative actions, including the no-action alternative, may have

environmental impacts in at least some impact categories that reach MODERATE or LARGE

significance.

8.4 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing

of Production and Utilization Facilities."

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

Protection Regulations for Domestic Licensing and Related Functions."

10 CFR Part 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 Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

"Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

NUREG-1437, Supplement 23 8-54 August 2005

II
Alternatives

40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60,

"Standards of Performance for New Stationary Sources."

Clean Air Act of 1970 (CM). 42 USC 7491 et seq.

C & A Carbone, Inc. v. Town of Clarkstown, New York, 511 U.S. 383, (U.S. Supreme Court

1994).

Dominion Nuclear North Anna, LLC (Dominion). 2003. Letter from D. A. Christian, Dominion,

to J. E. Dyer, NRC. Subject: "North Anna Early Site Permit Application." September 25, 2003.

Exelon Generation Company, LLC (Exelon). 2003. Letter from M. C. Kray, Exelon, to NRC. -

Subject: "Early Site Permit Application." Septem ber 25, 2003.

Gabbard, Alex. 1993. Coal Combustion: Nuclear Resource or Danger, Oak Ridge National

Laboratory Review. Oak Ridge National Laboratory: Oak Ridge, Tennessee.. Summer/Fall

1993. http://w~w.ornl.gov/ORNLReview/rev26-34/text/colmain.htmI (Accessed June 21, 2004).

Idaho National Engineering Laboratory. 1996. U.S. 'Hydropower Resource Assessment for -

Wisconsin. DOE/ID-10430(WI). Idaho Falls, Idaho. May 1996.-

http://hydropower.inel.gov/resourceassessment/wVwi.pdf (Accessed August 12, 2004).

Integrated Waste Services Association. 2004. About Waste to Energy.

http://www.wte.org/waste.html (Accessed November 4, 2004).

National Environmental Policy Act of 1969, as amended. 42 USC 4321 et seq.

Nuclear Management Company, LLC (NMC). 2004. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report.'' Two Rivers, Wisconsin.

Resource Conservation and Recovery Act of 1976. 42 USC 6901.

System Energy Resources, Inc. (SERI). 2003. Letter from W. A. Eaton, SERI, to NRC.

Subject: "Early Site Permit Application." 'October 16, 2003.

Tax Reform Act of 1986.- Public Law 99-514 (100 Stat. 2085).

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2000. Eniergy

Consumption and Renewable Energy Development Potential on Indian Lands.

SR/CNEAF/2000-01. Washington, D.C.

http://www.eia.doe.gov/cneaf/solar.renewables/ilands/ilands.pdf (Accessed August 3, 2004).

August 2005 8-55 NUREG-1437, Supplement 23
I Et

Alternatives

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2001. Renewable

Energy 2000: Issues and Trends. DOE/EIA-0628(2000), Washington, D.C.

http://www.eia.doe.gov/cneaf/solar.renewables/rea issues/062800.pdf

(Accessed August 3, 2004).

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2004a. Annual

Energy Outlook 2004 With Projections to 2025. DOE/EIA-0383(2004). Washington, D.C.

http://www.eia.doe.gov/oiaf/aeo/index.htmV (Accessed June 21, 2004).

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2004b.

International Energy Outlook 2004. DOE/EIA-0484(2004). Washington, D.C.

http://www.eia.doe.gov/oiaffieo/ (Accessed June 21, 2004).

U.S. Department of Energy (DOE). 2004a. Map of Wisconsin AnnualAverage Wind Power.

http://www.eere.energy.gov/windandhydro/wind-potential.html and

http://rredc.nrel.gov/wind/pubslatlas/maps/chap3/3-19m.html (Accessed August 11, 2004).

U.S. Department of Energy (DOE). 2004b. Future Fuel Cells R&D.

http://www.fossil.energy.gov/programs/powersystems/fuelcells/index.html

(Accessed August 3, 2004).

U.S. Environmental Protection Agency (EPA). 1998. "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. 35714-35774. Washington, D.C. July 1, 1999.

U.S. Environmental Protection Agency (EPA). 2000a. "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). 2000b. "Notice of Regulatory Determination on

Wastes From the Combustion of Fossil Fuels." Federal Register, Vol. 65, No. 99,

pp. 32214-32237. Washington, D.C. May 22, 2000.

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

for License Renewal of Nuclear Plants. NUREG-1 437, Volumes 1 and 2, Washington, D.C.

NUREG-1437, Supplement 23 8-56 August 2005

I I
Alternatives

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). 2001. NRC Organizes Future Licensing Project

Organization. Press Release No. 01-035, March 30, 2001.

http://www.nrc.gov/OPA/gmo/nrarcv/01 -035.html (Accessed August 3,2004).

U.S. Nuclear Regulatory Commission (NRC). 2002. Final Supplement 1 to the Generic

Environmental Impact Statement on Decommissioning of Nuclear Facilities. NUREG-0586,

Supplement 1, Volumes 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from J. E. Dyer, Director, Office of

Nuclear Reactor Regulation, to Mr. W. E. Cummins, Director, AP600 & AP1 000 Projects,

Westinghouse Electric Company, Pittsburgh, PA. Subject: 'Final Design Approval for AP1000.0

September 13, 2004.

http://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PUADAMSAPBNTAD01 &ID=04

2640099 (Accessed June 20, 2005).

August 2005 8-57 NUREG-1437, Supplement 23
9.0 Summary and Conclusions

By letter dated February 25, 2004, the Nuclear Management Company, LLC (NMC) submitted

an application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating

licenses (OLs) for Point Beach Nuclear Plant Units 1 and 2 (PBNP) for an additional 20-year

period (NMC 2004a). If the OLs are renewed, State regulatory agencies and the Wisconsin

Electric Power Company (WEPCO) 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 OLs are not renewed, then the plants must be

shut down at or before the expiration of the current OLs, which expire on October 5, 2010, for

Unit 1 and March 8, 2013, for Unit 2.

Section 102 of the National Environmental Policy Act of 1969 (NEPA) (42 United States Code

[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 10 Code of Federal Regulations (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).(a)

Upon acceptance of the NMC 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 (NRC 2004a) on May 13,2004. The staff visited the PBNP site in June 2004 and held

public scoping meetings on June 15, 2004, in Mishicot, Wisconsin (NRC 2004b). The staff has

reviewed the NMC Environmental Report (ER) (NMC 2004b) and compared it to the GEIS,

consulted with other agencies, and conducted an independent review of the issues following the

guidance set forth in NUREG-1 555, Supplement 1, the Standard Review Plans for

Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal

(NRC 2000). The staff also considered the public comments received during the scoping

process for preparation of the draft supplemental environmental impact statement (SEIS) for

PBNP. 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 I, of this SEIS.

The staff held two public meetings in Mishicot, Wisconsin, on March 3, 2005, to describe the |

preliminary results of the NRC environmental review and to answer questions in order to

(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.

August 2005 9-1 NUREG-1437, Supplement 23
Summary and Conclusions

provide members of the public with information to assist them in formulating their comments on

the draft SEIS. All the comments received on the draft SEIS were considered by the staff in

developing this final SEIS. These comments are presented and addressed in Appendix A,

Part II.

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

impacts 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 impacts. This SEIS also includes the 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) decisionmakers.

The evaluation criterion for the 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 decisionmakers 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

NUREG-1437, Supplement 23 9-2 August 2005

I I
Summary and Conclusions

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).(8 )

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 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 offsite 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.

(a) The title of 10 CFR 51.23 is "Temporary Storage of Spent Fuel after Cessation of Reactor

Operations-Generic Determination of No Significant Environmental Impact."

August 2005 9-3 NUREG-1 437, Supplement 23
I :L

Summary and Conclusions

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

significant information, the staff relied on conclusions as amplified by supporting information in

the GEIS for issues designated 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 also be addressed in a

plant-specific 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 staff's consideration of all 92 environmental issues identified in the

GEIS. The 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 PBNP OLs) and alternative methods of power generation. These alternative

methods of power generation were evaluated assuming that the replacement power generation

plant is located at either the PBNP site or some other unspecified greenfield location.

9.1 Environmental Impacts of the Proposed Action - License

Renewal

NMC and the staff have established independent processes for identifying and evaluating the

significance of any new information on the environmental impacts of license renewal. Neither

NMC nor the staff has identified information that is both new and significant related to

Category 1 issues that would call into question the conclusions in the GEIS. Similarly, neither

the public comments, NMC, nor the staff has identified any new issue applicable to PBNP that

has a significant environmental impact. Therefore, the staff relies upon the conclusions of the

GEIS for all Category 1 issues that are applicable to PBNP.

NMC's license renewal application presents an analysis of the Category 2 issues that are

applicable to PBNP, plus environmental justice and chronic effects from electromagnetic fields.

The staff has reviewed the NMC analysis for each issue and has conducted an independent

review of each issue plus environmental justice and chronic effects from electromagnetic fields.

Six Category 2 issues are not applicable because they are related to plant design features or

site characteristics not found at PBNP. Four Category 2 issues are not discussed in this SEIS

because they are specifically related to refurbishment. NMC 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

NUREG-1437, Supplement 23 9-4 August 2005

I I
Summary and Conclusions

PBNP for the license renewal period (NMC 2004b). 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 the Operation of

Point Beach NuclearPlant Units 1 and2 (U.S. Atomic Energy Commission 1972).

Eleven 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 discussed in this SEIS

only in relation to operation during the renewal term. For all 11 Category 2 issues and

environmental justice, the staff concludes that the potential environmental impacts would be of -

SMALL significance in the context of the standards set forth in the GEIS. In addition, the 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 staff concludes that a reasonable,

comprehensive effort was made to identify and evaluate SAMAs. Based on its review of the

SAMAs for PBNP and the plant improvements already made, the staff concludes that none of

the candidate SAMAs is cost-beneficial. Although none of the SAMAs appear cost-beneficial in

the baseline analysis, the staff concludes that one SAMA could be cost-beneficial when

uncertainties or alternative discount rates are taken into account. However, this SAMA does

not relate to adequately managing the effects of aging during the period of extended operation.

Therefore, it need not be implemented as part of the license renewal pursuant to 10 CFR

Part 54.

Mitigation measures were considered for each Category 2 issue. Current measures to mitigate

the environmental impacts of plant operation were found to be adequate, and no additional

mitigation measures were deemed sufficiently beneficial to be warranted.

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 facility 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

August 2005 9-5 NUREG-1437, Supplement 23
I CL

Summary and Conclusions

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, and none warrants implementation of additional mitigation measures. The

adverse impacts of likely alternatives if PBNP ceases operation at or before the expiration of

the current OLs will not be smaller than those associated with continued operation of these

units, and the adverse impacts 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 PBNP during the current

license period was made when the facility was built. The resource commitments to be

considered in this SEIS are associated with continued operation of the plants 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.

The most significant resource commitments related to operation during the renewal term are

the fuel and the permanent HLW storage space. Approximately one third of the fuel

assemblies in each of the two PBNP units are replaced during every refueling outage, which

occurs on a nominal 18-month cycle.

The likely power generation alternatives if PBNP ceases operation on or before the expiration of

the current OLs 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

PBNP site was set when the plants were approved and construction began. That balance is

now well established. Renewal of the PBNP OLs 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 OLs will lead to a 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 PBNP site into a park or an industrial facility are quite different.

NUREG-1437, Supplement 23 9-6 August 2005

I I
Summary and Conclusions

9.2 Relative Significance of the Environmental Impacts of

License Renewalland Alternatives

The proposed action is renewal of the PBNP OLs. Chapter 2 describes the site, the power.

plant, and interactions of the plant with the environment. As noted in Chapter 3, no

refurbishment and no refurbishment impacts are expected at PBNP. Chapters 4 through 7.

discuss environmental issues associated with renewal of the PBNP OLs. Environmental issues

associated with the no-action alternative and alternatives involving power generation and use

reduction are discussed in Chapter 8.

The significance of the environmental impacts from the proposed action (approval of the

application for renewal of the OLs); the no-action alternative (denial of the application);

alternatives involving nuclear, coal-, or gas-generated power at the PBNP site and an

unspecified alternate site; and a combination of alternatives are compared in Table 9-1.

Substitution of once-through cooling for the recirculating cooling system in the evaluation of the

nuclear, gas-, and coal-fired generation alternatives would result in somewhat greater

environmental impacts in some impact categories.

Table 9-1 shows that the significance of the environmental impacts of the proposed action

would be SMALL for all impact categories (except for collective offsite radiological impacts from

the fuel cycle and from HLW and spent fuel disposal, for which a single significance level was

not assigned [see Chapter 6]). The alternative actions, including the no-action alternative, may,

have environmental impacts in at least some impact categories that reach MODERATE or

LARGE significance.

9.3 Staff Conclusions and Recommendations

Based on (1) the analysis and findings in the GEIS (NRC 1996, 1999); (2) the ER submitted by

NMC (NMC 2004b); (3) consultation with Federal, State, and local agencies; (4) the staff's own

independent review, and (5) the staff's consideration of public comments, the recommendation .

of the staff is that the Commission determine that the adverse environmental impacts of license

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

energy-planning decisionmakers would be unreasonable.

August 2005 9-7 NUREG-1437, Supplement 23
z

C

:12

CA)

Table 9-1. Summary of Environmental Significance of License Renewal, the No-Action Alternative, and Alternative

Methods of Generation (from Chapters 4 and 8)

Proposed No-Action Coal-Fired New Nuclear Combination of

Action Alternative Generation Natural-Gas-Fired Generation Generation Alternatives

U, License Denial of

I Impact Category Renewal Renewal PBNP Site Alternate Site PBNP Site Alternate Site PBNP Site Alternate Site PBNP Site Alternate Site

Land Use SMALL' -' 'SMALL'- MODERATE to - MODERATE to.' MODERATE., MODERATE to; MOPERATEa MODERATE to' ;' MODERATE', MODERATE to; C ,D,, ,; RGE't; , ii H ARG ;",;AT s a L GE to

CD Ecology SMALL SMALL SMALL to MODERATE to MODERATE MODERATE SMALL to MODERATE to MODERATE MODERATE

MODERATE LARGE MODERATE LARGE

N WaterUs-: SMALL'' 'SM LI ALL - SM to - - SM -?.-SMA to ' SMALL '~" SMALL to SMALL SMALLto

and u-alityl--, MOERT MO-ODRT

Surface Water . ' *- ' h< R MOD - M - ATE

Water Use and SMALL SMALL SMALL SMALL to SMALL SMALL to SMALL SMALL to SMALL SMALL to

Quality - MODERATE MODERATE MODERATE MODERATE

Groundwater

AirQuality " '. SMALL-. rSMIL- . M','ODERATE 'tAODERATE, MODERAT E- MODEALT '':, S, ; S ALL 'MODRATE' QDRATE

Waste SMALL SMALL MODERATE MODERATE SMALL SMALL SMALL SMALL SMALL SMALL

Human Health SMALLER< -;--,; So; SMALLi'" t'1 SMALL ; - SMALL' ) SMAL ' ' SMALA -' - SMALL '' SMALL

Socioeconomics SMALL SMALL to MODERATE MODERATE to SMALL to SMALL to SMALL to MODERATE to SMALL to SMALL to

CD MODERATE LARGE MODERATE MODERATE MODERATE LARGE MODERATE MODERATE

Trans" otaton 'SMALL SML? .ODERATE OALto' MODERAI M-,MALL to: - .LARGE -';LAGE: w i- ARGR LARE,' A3 _MODERATE , MODERATE

Aesthetics SMALL SMALL MODERATE MODERATE to SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to

LARGE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE Ns''SAL SAL10 >"nd ALiS MAAtoL'A _.SMAL to Histon-an;''';',-- SMALL SMLLto' .TS Lio; 0 ' tSMa ,Sto

Archaeolog calMODERATE,. .- ,MODERATE *;-. MODERATE ~", :MODERATE ,"~. ,MODERATE~:-' '" MODERATEI. rMODERATE:MODERATE~

Environmental SMALL SMALL SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to

Justice MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE

(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.

C

C

Cn

0

0
I ;I ; -! r, I s 

Summary and Conclusions

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."

National Environmental Policy Act of 1969. 42 USC 4321 et seq.

Nuclear Management Company, LLC (NMC). 2004a. Application for Renewed Operating

Licenses, Point Beach Nuclear Plant Units 1 and 2. Two Rivers, Wisconsin.

Nuclear Management Company, LLC (NMC). 2004b. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

U.S. Atomic Energy Commission. 1972. Final Environmental Statement Related to the

Operation of Point Beach Nuclear Plant Units 1 and 2. Wisconsin Electric Power Company and

Wisconsin Michigan Power Company. Docket Nos. 50-266 and 50-301, Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1 437, 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). 2000. Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1 555,

Supplement 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004a. "Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process." Federal Register, Vol. 69,

No. 93, pp. 26624-26626, Washington, D.C. May 13, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004b. Environmental Impact Statement

Scoping Process: Summary Report - Point Beach Nuclear Plant Units 1 & 2, Manitowoc

County, Wisconsin. Washington, D.C.

August 2005 9 9 NUREG-1437, Supplement 23
Appendix A

Comments Received on the Environmental Review
Appendix A

Comments Received on the Environmental Review

Part I - Comments Received During Scoping

On May 13, 2004, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of Intent

in the Federal Register (69 Federal Register 26624) to notify the public of the staff's intent to

prepare a plant-specific supplement to the Generic Environmental Impact Statement for

License Renewal of Nuclear Plants (GEIS), NUREG-1 437, Volumes 1 and 2, to support the

renewal application for the Point Beach Nuclear Plant Units 1 and 2 (PBNP) operating licenses

and to conduct scoping. The plant-specific supplement to the GEIS has been prepared in

accordance with the National Environmental Policy Act (NEPA), Council on Environmental

Quality guidelines, and Title 10 of the Code of Federal Regulations (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, Tribal, and local government agencies;

local organizations; and individuals to participate in the scoping process by providing oral

comments at the scheduled public meetings and/or submitting written suggestions and

comments no later than July 14, 2004.

The scoping process included two public scoping meetings, which were held at the Fox Hills

Conference Center in Mishicot, Wisconsin, on June 15, 2004. Approximately 60 members of

the public attended the meetings. Both sessions began with NRC staff members providing a

brief overview of the license renewal process and the NEPA process. After the NRC's prepared

statements, the meetings were open for public comments. Attendees provided either oral or

written statements that were recorded and transcribed by a certified court reporter. The

meeting transcripts are an attachment to the Scoping Meeting Summary dated

September 3, 2004. In addition to the comments received during the public meetings,

41 comment letters were received by the NRC in response to the Notice of Intent.

At the conclusion of the scoping period, the NRC staff and its contractor reviewed the

transcripts and all written material to identify individual comments. All comments and

suggestions received orally during the scoping meetings or in writing were considered. Each

set of comments from a given commenter was given a unique identifier (commenter ID

number), so that each set of comments from a commenter could be traced back to the

transcript or letter by which the comments were submitted. Several commenters submitted

comments through multiple sources (e.g., afternoon and evening scoping meetings and/or

written comments). All of the comments received and the staff responses are included in the

PBNP Scoping Summary Report, dated September 2004.

Table A-1 identifies the individuals who provided comments and the commenter ID number

associated with each person's set(s) of comments. The individuals are listed in the order in

which they spoke at the public meeting. 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.

August 2005 A-1 NUREG-1437, Supplement 23
Appendix A

I Table A-1. Individuals Providing Comments during Scoping Comment Period

Comment Source and

Commenter Commenter Affiliation (If Stated) ADAMS Accession

ID Numbersa

PB-A

PB-B

PB-C

PB-D

Mr. Frank Lasee

Mr. Ken Petersen

Mr. Greg Buckley

Mr. Meyer

PB-E

PB-F

PB-G

PB-H

PB-I

PB-J

PB-K

PB-L

PB-M

PB-N

PB-O

PB-P

PB-Q

PB-R

PB-S

PB-T

PB-U

PB-V

Mr. Rick Kuester

Mr. Jim Shaw

Mr. Curt Andersen

Mr. Roger Hirst

Mr. Tim Schroeder

Mr. David Jurss

Mr. Mike Zimmer

Mr. Tom Kocourek

Mr. Robert Hermann

Mr. Dan Pawlitzke

Mr. Rick Kuester

Mr. Jim Shaw

Mr. Dan Rahif

Mr. John Nikolai

Mr. John Busby

Mr. Kelly S. Jackson

Mr. Robert Domrois

Mr. Mark R. Honadel

(Local) State Representative

Manitowoc County Sheriff

Two Rivers, WI, City Manager

Village of Mishicot, Board

Representative

President & CEO of We

Energies Generation Group

PBNP Plant Manager

Clean Water Action Council

Citizen

Secretary/Treasurer, Two

Rivers Business Association

Vice-Chairman, Unit 2, Local

2150 International Brotherhood

of Electrical Workers (PBNP)

Executive Director, Two Rivers

Main Street Program

Executive Director, Big Brothers/Big Sisters of

Manitowoc County

Sheriff's Department, Manitowoc County

Economic Development Supervisor, City of Two Rivers,

Wisconsin

President & CEO of We

Energies Generation Group

PBNP Plant Manager

Community Member

Citizen

Miller Compressing Company

Lac Du Flambeau Band, Lake

Superior Chippewa Nation

Wisconsin Paperboard Corp.

Wisconsin State Assembly

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Afternoon Scoping Meeting

Evening Scoping Meeting

Evening Scoping Meeting

Evening Scoping Meeting

Evening Scoping Meeting

Evening Scoping Meeting

Evening Scoping Meeting

Letter (ML041600105)

Letter (ML041620343)

Letter (ML041620340)

Letter (ML041750351)

I (a) The afternoon and evening transcripts can be found under accession number ML041960121.

NUREG-1437, Supplement 23 A-2 August 2005

I I
Appendix A

Table A-1. (contd)

Comment Source and

Commenter Commenter Affiliation (If Stated) ADAMS Accession

ID , Numbere "

PB-W

PB-X

PB-Y

D. H. Tredwell

C. W. Fay

Mr. Dale Scherbert

PB-Z

PB-AA

PB-AB

PB-AC

PB-AD

PB-AE

PB-AF

PB-AG

PB-AH

PB-Al

PB-AJ

Mr. Robert Reynolds

Ms. Kathryn L. Smith

Ms. Cheryl Brocher

Mr. Richard Wagner

Mr. Kenneth J.

Petersen

J. A. Mellowes

Mr. Richard W.

Wanta

Mr. David J. Jenkins

Mr. Chad E. Cordle

Mr. William J. Welch

Mr. Zach Pahmahmie

Citizen

Citizen

Director, Community Memorial

Hospital

ORBIS Corporation

Citizen

Citizen

Trega Foods

Sheriff, Manitowoc County

Charter Mfg. Co.

Wisconsin Underground

Contractors

Association

Wisconsin Federation of

Cooperatives

Cellu Tissue Neenah

Fox Cities Chamber of

Commerce and Industry

Prairie Band Potawatomi Nation

Letter (ML041750352)

Letter (ML041750353)

Letter (ML041750356)

Letter (ML041.750358)

Letter (ML041750360)

Letter (ML041750361)

Letter (ML041750364)

Letter (ML041750365)

Letter (ML041750366)

Letter (ML041750367)

Letter (ML041750369)

Letter (ML041830247)

Letter (ML041830250)

Letter (ML041890189)

PB-AK

PB-AL

PB-AM

PB-AN

PB-AO

PB-AP

PB-AQ

PB-AR

PB-AS

PB-AT

PB-AU

Mr. Steve Bongers

Mr. John H. Goetsch

Mr. Earl Gustafson

Mr. James J. Graf

Mr. Herman Viets

Mr. R. J. Pirlot

Mr. John H. Meinke

Mr. Donald Kaye

Mr. Orville Krueger

Mr. Bob DeKoch

Mr. Joseph H.

Pomeroy

Outokumpu Copper Valleycast

Citizen

Wisconsin Paper Council

Alderman, City of Sheboygan

Milwaukee School of

Engineering

Wisconsin Manufacturers and

Commerce

Neenah Technical Center

Citizen

Citizen

The Boldt Company

Mercury Marine

Letter (ML041940367)

Letter (ML041940378)

Letter (ML041980016)

Letter (ML041980024)

Letter, (ML041980026)

Letter (ML04201 0179)

Letter (ML041970655)

Letter (ML041970654)

Letter (ML041970650)

Letter (ML041980013)

Letter (ML041980021)

August 2005 A-3 NUREG-1437, Supplement 23
Appendix A

Table A-1. (contd)

Commenter

ID

PB-AV

PB-AW

PB-AX

PB-AY

PB-AZ

PB-BA

PB-BB

PB-BC

PB-BD

PB-BE

PB-BF

PB-BG

Commenter

Mr. Allen J.

Prochnow

Mr. Daniel J.

Sutheimer

Mr. Kenneth

Westlake

Mr. Don C.

Markwardt

Mr. Joe Leibham

Mr. George P. Brown

Mr. Carl Otter

Ms. Carol Roessler

Dr. John G. Gonis

Mr. Edward J. Zore

Mr. Jeffrey S. Mason

Mr. Steve Bongers

Affiliation (If Stated)

Concordia University

Pierce Manufacturing

U.S. Environmental Protection

Agency (EPA)

Chair, Legislative Review

Committee, Manitowoc County Board of Supervisors

Wisconsin State Senator, 9th

Senate District

Regional Director, Humana, Inc.

Citizen

Wisconsin State Senator, 18th

Senate District

Dental Associates, Ltd.

President and Chief Executive

Officer, Northwestern Mutual

Chief Executive Officer, BayCare Health Systems, LLC

Outokumpu Copper Valleycast

Comment Source and

ADAMS Accession

Number<"

Letter (ML042010181)

Letter (ML042170122)

Letter (ML041910394)

Letter (ML042150282)

Letter (ML042170106)

Letter (ML042170114)

Letter (ML042170117)

Letter (ML042170118)

Letter (ML042170119)

Letter (ML042170120)

Letter (ML042170121)

Letter (ML041970658)

Specific comments were categorized and consolidated by topic. Comments with similar specific

objectives were combined to capture the common essential issues raised by the commenters.

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 PBNP license renewal

application.

* Questions that do not provide new information.

NUREG-1437, Supplement 23 A-4 August 2005

II
Appendix A

* 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.

Each comment applicable to this environmental review and the staff's responses are

summarized in this section. This information, which was extracted from the PBNP Scoping

Summary Report, is provided for the convenience of those interested in the scoping comments

applicable to this environmental review. The comments that are general or outside the scope of

the environmental review for PBNP are not included here. More detail regarding the disposition

of general or inapplicable comments can be found in the summary report, which was assigned

an accession number to facilitate access to the document through the Public Electronic

Reading Room (ADAMS) at http://www.nrc.gov/reading-rm.html. The ADAMS accession

number for the summary report is ML042510283.

The following pages summarize the comments and suggestions received as part of the scoping

process that are applicable to this environmental review and discuss the disposition of the

comments and suggestions. The parenthetical alpha-numeric identifier after each comment

refers to the comment set (commenter ID) and the comment number.

Comments in this section are grouped in the following categories:

A.1.1 Comments Concerning Terrestrial Resource Issues

A.1.2 Comments Concerning Aquatic Ecology Issues

A.1.3 Comments Concerning Water Quality Issues

A.1.4 Comments Concerning Air Quality Issues

A.1.5 Comments Concerning Socioeconomic Issues

A.1.6 Comments Concerning Human Health Issues

A.1.7 Comments Concerning Uranium Fuel Cycle and Waste Management Issues

A.1.8 Comments Concerning Alternatives

A.1.1 Comments Concerning Terrestrial Resource Issues

Comment: We take great strides in our daily activities to ensure .that the environment is well

protected. Our employees feel fortunate that the location of Point Beach is along Lake

Michigan and reaches to within the Point Beach State Park area. The site is home to numerous

wildlife, aquatic species and plant life. Our efforts have made Point Beach a safe and sound

habitat for many years and it's our commitment to maintain that habitat for years to come. -

(PB-F-9)

Comment: The trees, the flowers, the weeds and grass, they're still growing, growing good.

(PB-H-5)

August 2005 . - A-5 NUREG-1437, Supplement 23
. .9-

Appendix A

Comment: We take great strides in our daily activities to ensure that the environment is well

protected. Our employees feel fortunate that Point Beach is located on the shores of Lake

Michigan. The site is home to numerous wildlife, aquatic species and plant life. Our efforts

have made Point Beach a safe and sound habitat for many years and it is our commitment to

maintain that habitat for many years to come.

(PB-P-9)

Response: Terrestrial resource issues were evaluated in the GEIS and determined to be

Category 1 issues. The comments do not provide new and significant information and,

therefore, will not be evaluated further.

A.1.2 Comments Concerning Aquatic Ecology Issues

Comment: We expect the draft SEIS to discuss the effects of thermal discharge on the lake

and fish communities. Currently, the State of Wisconsin does not have active thermal water

quality standards, though an advisory group is in the process of developing new standards.

The new standards may be in place, or exist in draft form, by the time of license renewal. The

draft SEIS should address the applicability of the upcoming State standards to Point Beach.

Regardless of permit conditions, however, temperature effects from plant operation should be

included in the draft SEIS, as part of assessing impacts to the environment.

(PB-AX-3)

Comment: During the plant audit tour it was mentioned that Point Beach will need to comply

with the newly revised Clean Water Act Section 316(b), which regulates impacts of cooling

water intakes. The draft SEIS should indicate modifications planned by the applicant to comply

with the rule.

(PB-AX-4)

Response: The comments relate to aquatic ecology issues and are discussed in Chapters 2

and 4 of the SEIS.

A.1.3 Comments Concerning Water Quality Issues

Comment: As part of describing site hydrogeology, the draft SEIS should discuss the on-site

drinking water wells, drinking water quality, and treatment of the drinking water. In addition, we

believe the potential for ground water contamination should be described in the draft SEIS,

especially with regard to the abandoned settling pond.

(PB-AX-5)

Response: The comment is noted. Water quality, water use, and other water issues were

evaluated in the GEIS and determined to be Category I issues. The comment does not provide

new and significant information on water quality and, therefore, will not be evaluated further.

Water quality is discussed in Chapters 2 and 4 of the SEIS.

NUREG-1437, Supplement 23 A-6 August 2005

I 11
Appendix A

A.1.4 Comments Concerning Air Quality Issues

Comment: It's protected the environment by not having any CO2 going into the air or mercury

or sulfur dioxide.

(PB-H-3)

Comment: With respect to environmental concerns, it is significant that the southeast area of

Wisconsin has been and remains a closely watched non-attainment area for purposes of

federal Clean Air Act enforcement. -As a result, all new sources of monitored emissions will

carry added burdens of expensive remediation measures which are not required for the

commensurate amount of nuclear generation produced at Point Beach. While these costs are

known in some cases, as in the instance of sulfur dioxide, other remediation expenses, such as

those for nitrogen oxide'and mercury emissions are evolving in their estimates and could prove

prohibitively expensive for new coal generation sources. The picture gets murkier when

regional ozone transport issues and fine particulate emissions regulation are added. It is thus

vital for Wisconsin's future air quality to keep a non-emitting source of generation the size of

Point Beach in its generation portfolio.

(PB-AP-4)

Response: 7he comments are related to air quality issues. Air quality issues were evaluated

in the GEIS and determined to be Category 1 issues. The comments do not provide new and

significant information on air quality and, therefore, will not be evaluated further. n a

A.1.5 Comments Concerning Socioeconomic Issues

Comment: Now, going back 24 years we, the Sheriff's' Department formed what was called an

Emergency Response Unit or SWAT Team. At that point, Point Beach was their force. We

needed support financially and assist with training in order to get that unit off the ground.

(PB-B-4)

Comment: The Energy Information Center has provided educational programs for more than

300,000 of these visitors. Most of these are school groups that have made our energy center a

staple in their curriculum. We continue to host school groups and other organizations throughreservation at this point.

(PB-F-1 0)

Comment: And when you go around the plant, you can't get in it anymore, there used to be

some good fishing there. The fishermen are gone due to security problems. But the fish are

still there.

(PB-H-4)

Comment: Point Beach itself, as a plant, is very friendly to our community. It supports a lot of

our events. One of our biggest events and services is our ethnic festival and they're one of the

major sponsors of that event.

(PB-1-3)

Comment: And additionally, my newest position as executive for Big Brothers/Big Sisters, I

can attest that Point Beach Nuclear Power Plant has been very supportive of local non-profit

August 2005 A-7 NUREG-1437, Supplement 23
Appendix A

service agencies as well. Without the support of the local community these service agencies

could not exist and do the good work that they do for our communities.

(PB-L-4)

Comment: All previous companies relocated to Mexico, or in Hamilton's case has a potential

to leave for Mexico. Power companies do not have the luxury of leaving for Mexico. They are

here for the long haul. Point Beach Nuclear Power Plant has been a good corporate citizen by

annually contributing to the excellent quality of life for the families right here in Two Rivers.

(PB-N-6)

Comment: The Energy Information Center has provided educational programs for more than

300,000 of these visitors. Most of these are school groups, most of them are local school

groups that have made our energy center a staple in their curriculum. We continue to host

school groups and other organizations through reservations.

(PB-P-1 0)

Comment: We also know that when you look at socioeconomic factors that the Point Beach

Plant is a huge factor in our local economy with approximately 700 high quality jobs having a

significant economic impact in the communities of Two Rivers, Manitowoc and, as

Representative Lasee noted, throughout northeast Wisconsin. That's in addition to the

significant impact of the many contractors employed at the facility and extensive purchases of

goods and services throughout the area.

(PB-C-3)

Comment: Point Beach also generates significant economic benefits to the local and state

economy. Point Beach provides over 700 full time family supporting jobs. Those families

purchase goods and services from local businesses, pay taxes in area communities and

contribute to local charities and community organizations. Point Beach is committed to being a

good neighbor and fostering continued economic growth in the region.

(PB-E-1 0)

Comment: Regardless of where power is being shipped right now, we believe that power

generation is crucial to the future of Wisconsin, to attracting new industries, to attracting the

kind of jobs that we need to rebuild from the industries that have left over the last 10 years or

so. Point Beach has always provided safe, clean nuclear power to Wisconsin and wherever

else that it ships it along the grid.

(PB-K-2)

Comment: And as previously stated, they employ 700 people in good quality jobs which are

desperately needed in the Manitowoc County area.

(PB-L-5)

Comment: Point Beach Nuclear Power Plant started in 1969 and brought 100 employees and

has seen a 700 percent increase in its workforce to the existing 700 employees in 2004.

Energy production is a significant employer in our community now and hopefully will be well into

the future. These are high quality jobs that are hard to find in today's economy.

(PB-N-2)

NUREG-1437, Supplement 23 A-8 August 2005

I I
Appendix A

Comment: The economic impact of the 700 employees at Point Beach Nuclear Power can be

felt in the local communities where they live. 69 percent of Point Beach Nuclear Plant

employees live in Manitowoc County.

(PB-N-5)

Comment: Finally and in conclusion, the license renewal of Point Beach Nuclear Power Plant

presents a unique opportunity to create a win-win-win scenario for the rate payers, taxpayers,

the state and our community by: ...(2) preserving hundreds of well-paying jobs that help attract

young, successful people to Wisconsin and the Lake Shore area.

(PB-N-1 0)

Comment: Point Beach also generates significant economic benefits to the local and state

economy. Point Beach provides over 700 full-time family supporting jobs. These families

purchase goods and services from local businesses, pay taxes in local communities and

contribute to local charities and community organizations. Point Beach is committed to being a

good neighbor and fostering continued economic growth in the region.

(PB-0-1 0)

Comment: -The continued operation of Point Beach is vital to meeting Wisconsin's energy

needs. It's important to the local economy and important to more than 700 employees who

keep it running everyday safely.

(PB-E-1 1, PB-0-1 1)

Comment: Finally, Wisconsin benefits from the economic benefit of Point Beach and the

700 family supporting jobs that these nuclear facilities provide. '

(PB-S-3)

Comment: In response to your letter dated May 14, 2004, the Lac du Flambeau Band of Lake

Superior Chippewa Indians would like to express NO CONCERNS with any impacts to historic

properties located within the project area of potential effect for the Point Beach Nuclear Plant,

located on the western shore of Lake Michigan in Two Rivers, Wisconsin.

(PB-T-1)

Comment: Fortunately through both the business and environmental stewardship of We

Energies, Wisconsin continues to be a state that supports manufacturing jobs through energy

management and growth.

(PB-Z-2)

Comment: I see this as a positive item for the community. With all the manufacturing leaving

this area, we are about the only place left that is a big contributor to the local economy.

(PB-AA-2)

Comment: Another important reason for Point Beach to stay is our economy. We have lost so

many industrial jobs in 'the county. We need the jobs that Point Beach provides. Without it, our

county would really be in bad shape.

(PB-AB-4)

August 2005 A-9 NUREG-1437, Supplement 23
Appendix A

Comment: In addition, the plant employs over 700 family supporting jobs, while providing

significant economic benefits to the state and the local economy.

(PB-AE-4)

Comment: Lastly, the Point Beach Nuclear Plant provides 700 family supporting jobs in

addition to other significant economic benefits to the State of Wisconsin and the local economy.

(PB-AF-3)

Comment: At this time, we are unaware of any historical cultural resources in the proposed

development area. However, we do request to be immediately contacted if any inadvertent

discoveries are uncovered at anytime throughout the various phases of the project.

(PB-AJ-2)

Comment: The continued operation of its two units for another 20 years will be a significant

benefit to Wisconsin's economy.

(PB-AM-4)

Comment: Located in Two Creeks, the Point Beach facility employs approximately 730 area

residents with family-sustaining jobs.

(PB-AN-2, PB-AR-2, PB-AT-2, PB-AU-2, PB-AZ-2, PB-BB-2, PB-BC-2, PB-BD-2, PB-BF-2)

Comment: It's significant contribution to Wisconsin's energy generation is priceless to the

economic development of our region and quality of life of our residents.

(PB-AN-4, PB-AR-4, PB-AT-4, PB-AU-4, PB-AZ-4, PB-BA-4, PB-BB-4, PB-BC-4, PB-BD-4,

PB-BF-4)

Comment: The stability of energy availability has been absolutely essential to the growth of my

institution and the growth of the business partners who support this institution. Any interruption

of these energy sources will have dire consequences, particularly for existing businesses in the

area and for Wisconsin's ability to build and attract new business. It is essential to the

economic success of this region to have the Point Beach Nuclear Plant's license renewed.

(PB-AO-3)

Comment: Continued operation of the Point Beach plant is key to providing an overall climate

of economic health and growth in the local area as well as throughout the state.

(PB-AQ-3)

Comment: If nuclear power is no longer part of that energy mix, businesses throughout the

state will be faced with serious economic issues and the potential for new businesses coming

into the area will be limited.

(PB-AV-5)

Comment: The Point Beach Nuclear Plant is an important part of keeping Wisconsin business

competitive in the nation and around the world.

(PB-AW-4)

NUREG-1437, Supplement 23 A-10 August 2005

I I
Appendix A

Comment: The 700 permanent jobs at Point Beach and the extensive use of contracts for

ongoing maintenance and special projects are recognized as vitally important to the economy of

Manitowoc County and Northeast Wisconsin.

(PB-AY-3)

Comment: While the Point Beach facility employees approximately 730 area residents with

family-sustaining jobs; clean, reliable, and efficient energy is critical to many businesses

affecting many thousands of jobs.

(PB-BA-2)

Comment: If nuclear power is no longer part of that energy mix, business throughout the state

could be faced with serious economic issues'and the potential for new businesses coming into

the area will be limited.

(PB-BE-4)

Response: Public services involving education, social services, and recreation were evaluated

in the GEIS and were determined to be Category 1 issues. Those comments related to these

public service issues do not provide new and significant information and, therefore, will not be

evaluated further. Socioeconomic issues specific to Point Beach are Category 2 issues and are

addressed in Chapters 2 and 4 of the SEIS.

A.1.6 Comments Concerning Human Health Issues

Comment: But I have some very, very serious concerns about public health.

(PB-G-5)

Comment: The draft SEIS should discuss planned or potential power uprates at Point Beach,

and the estimated resulting increases in radiological emissions, spent fuel, and other emissions.

Although U.S. NRC's regulations (10 CFR § 51.53(c)(2)) state that an applicant's environmental

report need not discuss the demand for power, we consider power uprates to be reasonably

foreseeable actions that contribute to a cumulative radiological impact, under 40 CFR § 1508.7

and therefore should be discussed in U.S. NRC's draft SEIS.

(PB-AX-1)

Response: Human health issues were evaluated in the GEIS and were determined to be

Category 1 issues. The comments do not provide new and significant information on these

issues and, therefore, will not be evaluated further. Human health issues are addressed in

Chapter 4 of the SEIS.

The following paragraph contains additional information that was not included in the scoping

summary report dated September2004:

The SEIS contains an evaluation of severe accident mitigation alternatives (SAMAs), as

required by NRC regulations. This is contained in Chapter 5 and Appendix G. The staff notes

that the Nuclear Management Company Environmental Report SAMA analysis included a

sensitivity study to assess the impact of a 8.7 percent power uprate, which would increase

reactor power level to 1678 MW(t). The sensitivity study found that the power uprate had no

significant impact on SAMA benefits.

August 2005 A-1 1 NUREG-1 437, Supplement 23
Appendix A

Although the power uprate information was considered in the SAMA analysis, the staff

recognizes that the Commission has stated that for NEPA purposes, a possible future action

umust at least constitute a proposal pending before the agency" for it to be considered along

with the proposed action, which here is license renewal. The Commission's decision is set forth

in the following case: Duke Energy Corp. (McGuire Nuclear Station, Units 1 and 2; Catawba

Nuclear Station, Units 1 and 2) CLI-02-14, 55 NRC 278, 294-297 (2002). Since Nuclear

Management Company does not at this time have a proposal pending before the NRC that

relates to a power uprate for PBNP, the SEIS does not address future power uprates. In

addition, the Commission in that case stated that for the license renewal action and a separate

proposal (such as a power uprate application) to be considered together, both actions must be

"interdependent", such that one cannot go forward without the other. Should a power uprate

amendment request for PBNP be filed, the staff will then consider whether there are cumulative

impacts associated with the power uprate.

A.1.7 Comments Concerning Uranium Fuel Cycle and Waste Management

Comment: Some people will say that nuclear waste is an issue and I've been to Yucca

Mountain and looked at it quite a bit and I'm not a science expert, although I can read things

and take a good hard look at it. And I think that's a good place to put spent fuel.

(PB-A-3)

Comment: So I view Yucca Mountain, unlike the government does, the government I think

views it as a permanent repository. I view it as a much more short term repository until we find

a better use for that waste that we're generating here and storing on-site. And I would urge the

Federal government to get going so we can move some of that stuff out of here and take it to

Yucca Mountain.

(PB-A-4)

Comment: That goes to operational issues, that goes to the dry cask storage issue which we

realize is still an interim fix and we want to frankly keep our federal politician's feet to the fire on

a permanent solution to that issue which our rate payers have paid for.

(PB-C-6)

Comment: So the solution to the waste? It looks like it could be Wisconsin, right in our area,

and the Canadian Shield, the Wolf River-which is nice and solid. It doesn't have any

earthquake problems and I don't like the idea of our area being turned into a nuclear waste

repository.

(PB-G-3)

Comment: Like all nuclear reactors, Point Beach produces spent fuel. The overwhelming

majority of both houses of Congress have expressed their will that the spent fuel storage

repository at Yucca Mountain, Nevada, be made operational.

(PB-AG-4)

Comment: In addition, the draft SEIS should discuss spent fuel storage capacity and spent

fuel transportation issues that may arise from power uprates.

(PB-AX-2)

NUREG-1437, Supplement 23 A-12 August 2005

I I
Appendix A

Response: Uranium fuel cycle and waste management issues were evaluated in the GEIS and

were determined to be Category 1 issues. The comments do not provide new and significant

information on these public service issues and, therefore, will not be evaluated further.

A.1.8 Comments Concerning Alternatives

Comment: Nuclear power is the way to go. We won't be here, but oil won't last forever,

neither will coal.

(PB-H-2)

Comment: And I asked him what he thought about nuclear power. And he feels that nuclear

power is the safest, most practical form of energy that we can have, outside of 'solar energy and

wind power. Much more practical, much safer than coal, oil or any other forms of energy.

(PB-1-4)

Comment: If Point Beach Nuclear Power Plant's license is not renewed, its electrical

generation capacity would have to be replaced. The likely replacement is some sort of fossil

fuel. As air quality becomes more and more of an issue in Wisconsin, especially along the

Lake Shore which sees much of its pollution, air pollution that is imported, the license renewal

of Point Beach Nuclear Power Plant can serve to help protect our local environment.

(PB-N-7)

Comment: New coal plants are being proposed for southeast Wisconsin but are vigorously

opposed by local residents. Wind generators are also planned but nowhere near

1000 megawatts. New natural gas plants are under construction. However, these are

presumably peaking plants not base-load as is Point Beach. Further, an article in the

June 14 [2004] Wall Street Journal points out that not only is natural gas becoming very

expensive but thatthe availability is in question. To quote: 'The underlying demand from the

power sector is such that you are always going to be strained to meet the demand on the ~- ' - -'

supply side.' The Wisconsin transmission system is generally considered inadequate to import

large amounts of power and new lines-are planned but are also opposed by many residents.'

(PB-X-2)

Comment: To replace this power production today would not only mean a large capital

investment but either the environmental damage of a (sic) burning coal or the use of precious

national gas which is needed for heating'our homes. Nuclear plants still represent the most

environmentally sound form'of energy production we have available to us and keeping this plant

operational as long as possible is critical to Wisconsin's economy and environment. -

(PB-Y-3) -

Comment: We don't need any more polluted air. Clean production of electricity is crucial to

our environment.

(PB-AB-2)

August 2005 A-13 NUREG-1437, Supplement 23
Appendix A

Comment: Continued operation of this particular nuclear plant as such will enable our utility to

have time to obtain newer nuclear technology as it becomes available. Continued operation of

this particular nuclear plant as such will enable our utility to have some breathing room and

transition time as they explore and act to bring much more renewable energy supplies on line.

(PB-AC-3)

Comment: Technically, nuclear energy output comes without any of the environmental impacts

to the atmosphere that coal, natural gas, or other fuels have.

(PB-AC-5)

Comment: The current trend in the electric industry is to rely more heavily on natural gas-fired

plants. We have seen the cost of natural gas for summer rise from $ 3.00/dth to over $6.00/dth

over the last several years. Siting and constructing of new power plants is expensive and

difficult. With consideration to the projected maintenance cost, usually the best investment is to

maintain existing facilities.

(PB-AE-2)

Comment: Point Beach is a zero-emissions resource. Only hydroelectric and some (not all)

renewable resources have zero emissions. This is especially beneficial in an area of the state

which has close proximity to Lake Michigan and urban areas such as Milwaukee.

(PB-AG-3)

Comment: License renewal is expected to cost $22 million which Wisconsin Energy projects to

be $474 million more economical than other options, such as building a new fossil fuel plant or

purchasing replacement power.

(PB-AM-5)

Comment: Nuclear power also represents, and will continue to represent, the most cost

effective electricity to produce in Wisconsin and nationwide. Recent data provided by the

Nuclear Energy Institute show nuclear energy surpassing coal in overall fuel production cost

effectiveness, with none of the attendant emissions-related concerns of coal-fired generation.

In contrast, the alternative generation construction required to replace the output of Point

Beach, in the event of an untimely retirement, would necessarily rely upon natural gas or coal.

Natural gas prices have reached nearly historic levels of expense and volatility, with further use

in electricity production likely to cause further price flux and supply displacement for

manufacturing and home heating needs. Coal generation carries very large capital costs, long

construction cycles and protracted public opposition. None of these alternatives to Point Beach

represent good choices for Wisconsin ratepayers, who already face sizable rate increases once

currently pending generation and transmission upgrades begin commercial operation.

(PB-AP-3)

Response: The GEIS included an extensive discussion of alternative energy sources.

Environmental impacts from reasonable alternatives to renewal of the operating licenses for the

Point Beach Nuclear Plant Units 1 and 2 are evaluated in Chapter 8 of the SEIS.

NUREG-1437, Supplement 23 A-14 August 2005

I I
Appendix A

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 Point Beach Nuclear Plant, Units 1 and 2,

Draft Report for Comment (NUREG-1437, Supplement 23, referred to as the draft

Supplemental Environmental Impact Statement [SEIS]) to Federal, State, and local government agencies; Indian tribes; and interested members of the public. As part of the process to solicit

public comments on the draft SEIS, the staff,

* Placed a copy of the draft SEIS into the NRC's Public Electronic Reading Room, its license

renewal website, and at the Lester Public Library;

* Sent copies of the draft SEIS to the applicant, members of the public who requested copies, representatives of Indian tribes, and certain Federal, State, and local agencies;

* Published a-notice of availability of the draft SEIS in the Federal Registeron January 26,

2005 (70 FR 3744);

* 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 Mishicot, Wisconsin, on March 3, 2005, 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.

During the comment period, the staff received a total of five written comments. No comments

were received during the public meetings on the draft SEIS.

The staff has reviewed the public meeting transcripts and the five written comments that are

part of the docket file for the application, all of which are available at 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. Appendix A, Part II, Section A.3,

contains the comment letters.

Each comment identified by the staff was assigned a specific alphanumeric identifier (marker).

That identifier is typed in the margin at the beginning of the discussion of the comment in aletter. A cross-reference of the alphanumeric identifiers, the 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.

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.

August 2005 A-1 5 NUREG-1 437, Supplement 23
Appendix A

* A comment that was either related to support or opposition of license renewal in general (or

specifically, PBNP) or that makes a general statement about the license renewal process. It

may make only a general statement regarding Category 1 and/or Category 2 issues. In

addition, it does not provides new and significant information and does not pertain to safety

considerations reviewed under 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) that

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 new and significant 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.2.1 1), 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.

NUREG-1437, Supplement 23 A-16 August 2005

Il
Appendix A

Table A-2. Comments Received on the Draft SEIS

Comment Comment Section(s) Where

I

ID Commenter .. I

PB-CA-1 Mr. Daniel Hahn

PB-CB-1

PB-CC-1

Mr. J. Kevin McCoy

Mr. Dennis L. Koehl

- Source

Electronic mail

(ML050700105)

Letter (ML05090021 1 Le ( 5

Letter (ML05109033!

Letter (ML05109033!

Letter (ML05109033!

Letter (ML05i09033!

Letter (ML05109033!

A-34 A.2.11

.

Location Addressed -

PB-CC-2 Mr. Dennis L. Koehl

PB-CC-3 Mr. Dennis L. Koehl

PB-CC-4

PB-CC-5

PB-CC-6

PB-CC-7

PB-CC-8

PB-CC-9

PB-CC-1 0

PB-CC-i 1

PB-CC-12

PB-CC-13

PB-CC-14

PB-CC-15

PB-CC-16

PB-CC-17

PB-CC-18

PB-CC-19

PB-CC-20

PB-CC-21

PB-CC-22

PB-CC-23

PB-CC-24

PB-CC-25

PB-CC-26

PB-CC-27

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Letter (ML05109033'

Letter (ML05109033!

Letter (ML05109033'

Letter (ML05109033'

Letter (ML05109033'

Letter (ML05109033:

Letter (ML05109033!

Letter (ML05109033T

Letter (ML05109033!

Letter (ML051090331

Letter (ML05109033'

Letter (ML05i109033.1

Letter (ML.5 O9033.

Letter (ML05109033'

Letter (ML05109033C

Letter (ML05109033!

Letter (ML05109033C

Letter (ML05109033'

Letter (ML05109033r

Letter (ML.5 .09033E

Letter (ML05109033!

3) A-20 A.2.1

3) A-29 Executive Summary,

A.2.10

3) A-29 Executive Summary,

A.2.1 0

3) A-29 Executive Summary,

1.2.2, 9.0, A.2.10

3) A-29 1.0, A.2.10

3) A-29 Executive Summary,

1.2.2, 9.0, A.2.1 0

5) A-29 1.3, A.2.10

5) A-30 1.5, A.2.10

5) A-30 1.4, A.2.10

5) A-30 1.3, A.2.10

5) A-30 2.1.1, A.2.10

5) A-30 2.2.1, A.2.10

5) A-30 2.2.5, A.2.1i

5) A-21 2.2.4, A.2.2

5) A-30 2.2.7, A.2.10

5) A-30 2.2.7, A.2.10

5) A-30 2.2.7, A.2.10

5) A-30 2.2.8.3, A.2.1 0

5) A-31 2.1.2, A.2.10

5) A-31 2.2.8.4, A.2.1 0

5) A-31 2.2.10, A.2.10

5) A-31 Figure 2-3, A.2.1 0

5) A-31 Figure 2-3, A.2.1 0

5) A-31 2.1.5, A.2.10

5) A-31 2.1.5, A.2.10

5) 'A-32 2.1.6, A.2.10

5) A-32 2.2.3, A.2.10

5) A-32 2.2.4, A.2.10

. I

I

I

. I

I

I

-1

I

I  I ..  I

I

I

- I

I. I . I

I

.I

I

I

I - I

I

I

I

I

I

I

I

I

-I

August 2005 A-1 7 NUREG-1437, Supplement 23
Appendix A

Table A-2. (contd)

Comment

ID

I PB-CC-28

I PB-CC-29

I PB-CC-30

I PB-CC-31

I PB-CC-32

I PB-CC-33

I PB-CC-34

I PB-CC-35

I PB-CC-36

Comment Section(s) Where

I

I I

I

I

I

I I

I

I I

I I

I

I

I I

I

I

I

I

I

I

I

PB-CC-37

PB-CC-38

PB-CC-39

PB-CC-40

PB-CC-41

PB-CC-42

PB-CC-43

PB-CC-44

PB-CC-45

PB-CC-46

PB-CC-47

PB-CC-48

PB-CC-49

PB-CC-50

PB-CC-51

PB-CC-52

PB-CC-53

PB-CC-54

PB-CC-55

PB-CD-1

Commenter

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Dennis L. Koehl

Mr. Kenneth A.

Westlake, U.S.

Environmental

Protection Agency

(EPA)

Source

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051090335)

Letter (ML051160259)

Location

A-22

A-32

A-32

A-22

A-32

A-32

A-32

A-33

A-29

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-26

A-27

A-27

A-20

Addressed

2.2.5, A.2.4

2.2.8.1, A.2.10

4.1.1, 4.1.2, A.2.10

4.1.2, A.2.4

4.1.1, 4.1.2, A.2.10

4.4.5, A.2.10

8.2.5.9, A.2.10

9.0, A.2.10

Executive Summary,

1.2.2,9.0, A.2.10

5.2.1, A.2.6

5.2.6, A.2.6

G.5, A.2.6

G.6.2, A.2.6

G.6.2, A.2.6

G.7, A.2.6

5.2.2, A.2.6

5.2.4, A.2.6

Table G-4, A.2.6

G.6.2, A.2.6

G.7, A.2.6

G.7, A.2.6

Table 5-3, A.2.6

Table G-1, A.2.6

Table 5-4, A.2.6

Table G-2, A.2.6

G.2.2, A.2.6

G.5, A.2.6

G.7, A.2.6

A.2.1

NUREG-1 437, Supplement 23 A-1 8 August 2005

II
Appendix A

Table A-2. (contd)

I -

Comment

ID Commenter

PB-CD-2 Mr. Kenneth A.

Westlake, EPA

PB-CD-3 Mr. Kenneth A.

Westlake, EPA

PB-CD-4 Mr. Kenneth A.

Westlake, EPA

PB-CD-5 Mr. Kenneth A.

Westlake, EPA

PB-CD-6 Mr. Kenneth A.

Westlake, EPA

PB-CD-7 Mr. Kenneth A.

Westlake, EPA

PB-CD-8 Mr. Kenneth A.

Westlake, EPA

PB-CD-9 Mr. Kenneth A.

Westlake, EPA

PB-CD-10 Mr. Kenneth A.

Westlake, EPA

PB-CD-1 1 Mr. Kenneth A.

Westlake, EPA

PB-CD-12 Mr. Kenneth A.

Westlake, EPA

PB-CD-13 Mr. Kenneth A.

Westlake, EPA

PB-CD-14 Mr. Kenneth A.

Westlake, EPA

PB-CD-15 Mr. Kenneth A.

Westlake, EPA

PB-CD-16 Mr. Kenneth A.

Westlake, EPA

PB-CD-1 7 Mr. Kenneth A.

Westlake, EPA

PB-CE-1 - Mr. Michael T.

Chezik, Departme

of Interior (DOI)

PB-CE-2 ---Mr. Michael T.

Source

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML51 160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051;160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051160259)

Letter (ML051050351)

nt

Letter (ML051050351)

Letter (ML051050351)

Letter (ML051050351)

Comment

Location

A-21

A-33

A-33

A-33

A-33

A-27

A-27

A-28

A-34

A-21

A-25

A-29

A-25

A-23

A-35

A-21

A-24

A-24

A-23

A-24

Section(s) Where

Addressed

2.1.3, A.2.3

2.2.7, A.2.1 0

A.2.1 0

A.2.1 0

4.8.3, A.2.10

A.2.6

A.2.7

A.2.8

A.2.10

A.2.2

A.2.5

A.2.9

A.2.5

A.2.4

A.2.11

2.2.2, 2.2.3, 4.5, A.2.3

A.2.4

4.6.2, A.2.4

A.2.4

4.1.2, A.2.4

-

-- Chezik, DOI

PB-CE-3

PB-CE-4

Mr. Michael T.

- Chezik, DOI

Mr. Michael T.

Chezik, DOI

August 2005 A-19 NUREG-1437, Supplement 23
Appendix A

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 Comments Concerning Air Quality Issues

A.2.3 Comments Concerning Water Quality Issues

A.2.4 Comments Concerning Aquatic Ecology, Terrestrial Ecology, and Threatened and

Endangered Species Issues

A.2.5 Comments Concerning Human Health Issues

A.2.6 Comments Concerning Postulated Accident Issues

A.2.7 Comments Concerning Uranium Fuel Cycle and Waste Management Issues

A.2.8 Comments Concerning Decommissioning Issues

A.2.9 Comments Concerning Alternatives

A.2.10 Editorial Comments

A.2.1 1 Comments Concerning Issues Outside the Scope of License Renewal

A.2.1 General Comments Concerning License Renewal and Its Processes

Comment: I find that the supplement has acceptably evaluated the environmental impacts of

license renewal for the Point Beach Nuclear Plant. I recommend that the report be issued as

final. (PB-CB-1)

Response: The comment relates to the license renewal process at PBNP Units 1 and 2, and is

general in nature. The comment does not provide new and significant information and,

therefore, will not be evaluated further.

Comment: Based on the review of the Point Beach Nuclear Plant draft SEIS, the U.S. EPA

has rated the project and document "Environmental Concerns- insufficient information" (EC-2).

This means that the U.S. EPA has identified environmental impacts that should be avoided and

suggests corrective measures which may require changes to the preferred alternative or

mitigation measures that can reduce impacts. The rating also means that the draft SEIS needs

further information to fully assess environmental impacts of the preferred alternative or other

alternatives that are reasonably available to the project. Our main concerns include: adequacy

and clarity of the radiological impacts and risk estimates, entrainment of fish and shellfish at

early life stages, impacts of foreseeable power uprates, and impacts to ground water.

(PB-CD-1)

NUREG-1437, Supplement 23 A-20 August 2005

I I
Appendix A

Response: The comment relates to the license renewal process at PBNP Units 1 and2, and is

general in nature: Each of the specific comments provided by the commenter regarding the

concerns noted above is addressed individually elsewhere in this Appendix.

A.2.2 Comments Concerning Air Quality Issues

Comment: This sentence does not seem to be factually correct. More than one tornado has

caused major property damage in the state. (PB-CC-13)

Response: The comment is noted.- The language of Section 2.2.4 indicates that a damaging

tornado has occurred in the vicinity of the site in the past, specifically in Green Bay in 1959. As

a tornado has occurred within a fifty mile radius of the plant in the past (1959), it is possible to

have a tornado again in the future in the vicinity of PBNP, albeit with a low likelihood. The text

in Section 2.2.4 has been changed to reflect this information.

Comment: Section 8.2.1.1, Closed Cycle Cooling System, page 8-17, under the bullet

Uranium and thorium. A better comparison or quantification of the relative concentrations of the

uranium and thorium to the background levels needs to be provided. As is, this presentation is

confusing. (PB-CD-1 1)

Response: Uranium and thorium occur naturally in coaL Uranium concentrations are

generally in the range of 1 to 10 parts per million.- Thorium concentrations are generally about

2.5 times greater than uranium concentrations. 'Any deposition of uranium or thornum as a

result of the burning of coal would add to natural background levels. For the basis of comparing

alternatives, the staff does not perform a complete assessment of impacts for the alternatives, -

but rather a qualitative and, if possible, a quantitative comparison. The text in Section 8.2.1.1

has been changed to reflect this information more clearly.

A.2.3 Comments Concerning Water Quality Issues

Comment: Section 2.1.3, Cooling and Auxiliary Water Systems, page 2-4 to 2-6. There is no

description of the actual intake or outflow amounts in this system. We recommend including

this specific information or explaining the reasons for excluding it. (PB-CD-2)

Response: The comment is noted. The text in Section 2.1.3 has been changed to include this

information.

Comment: As part of its July 1, 2004 scoping comments, the U.S. EPA recommended the

draft SEIS describe site hydrogeology, on-site drinking water'wells,' drinking water quality, and

treatment of the drinking water. The U.S. EPA also recommended that NRC evaluate the

potential for ground water contamination under the license'renewal period,-especially with

regard to the abandoned settling pond. iThe'draft SEIS responded to these comments by

stating that the water issues were found to be Category 1 issues (no additional site-specific

analysis required) during development of the Generic Environmental Impact Statement (GEIS).

It is not clear how this issue can be a Category I issue, because it is site-specific; 'that is, it does

not seem likely that other plants have the same groundwater regime and configuration of

drinking water wells and an abandoned retention pond on site (see the first criteria for

August 2005 A-21 NUREG-1437, Supplement 23
Appendix A

Category 1 determination). Chapter 4.5, Groundwater Use and Quality, states that no new and

significant information is found; however, the section does not provide information about

groundwater at the site. Without hydrological information or ground water quality information,

the SEIS does not successfully describe the impact of extended plant operation, including

management of the abandoned settling pond, on groundwater and drinking water. Therefore,

we recommend that the SEIS include an evaluation of ground water conditions and potential

impacts of extended plant operation as part of the license renewal SEIS for this site.

(PB-CD-1 7)

Response: This EIS is, by NRC rules, a supplement to the GEIS. It relies to a great degree on

impact analyses presented in the GEIS (NUREG- 1437), including evaluations of groundwater

use and quality. Every site is unique, but many environmental issues are not unique. As a

supplement, this SEIS does not need to repeat all analyses and conclusions of the GEIS.

Appropriate sections of the GEIS are referenced, when necessary. Volumes 1 and 2 of the

GEIS are available at http://www.nrc.gov/reading-rm/doc-collection/nuregs/stafflsrl437/vl/ and

http:/Iwww.nrc.gov/reading-rmldoc-collection/nuregs/staff/srl437/v2, respectively.

Site hydrogeology, potential for groundwater contamination, current status and issues related to

the former settling pond, and other related information was reviewed by the staff during the

preparation of the draft SEIS. This review included an evaluation as to whether any new and

significant information existed that would warrant reconsideration of the conclusions reached in

the GE/S with regard to groundwater. The staff determined that potential impacts on

groundwater quality would be SMALL, as discussed in Section 4.5. Communications with the

Wisconsin Department of Natural Resources (WDNR) confirmed that the WDNR does not have

concerns regarding the potential for groundwater contamination at PBNP. Absent new and

significant information, the NRC is to rely on the findings of the GEIS that are codified in NRC

regulations as Category 1 issues. Nevertheless, text has been changed in Sections 2.2.2,

2.2.3, and 4.5 to describe more fully the conduct and results of the staff's review of groundwater

quality issues, in response to the comment.

A.2.4 Comments Concerning Aquatic Ecology, Terrestrial Ecology, and Threatened and

Endangered Species Issues

Comment: Per WDNR, Lake Michigan is not on the fish advisory due to mercury. (PB-CC-28)

Response: The comment is noted. The statement that mercury and polychlorinated biphenyls

(PCBs) are the main contaminants that account for fish advisories was meant as a generalized

statement that referred to the entire State. The text has been changed in Section 2.2.5 to

clarify that fish advisories within Lake Michigan apply only to PCBs.

Comment: WEPCO designed and installed the fish deterrent system under a compliance

agreement with the U.S. Fish & Wildlife Service. (PB-CC-31)

Response: The comment is noted. The text in Section 4.1.2 has been changed to reflect the

information provided in the comment.

NUREG-1 437, Supplement 23 A-22 August 2005

I I
Appendix A

Comment: The U.S. EPA's new rules under Section 316(b) of the Clean Water Act (in

40 CFR Part 125) require Point Beach Nuclear Plant to reduce its entrainment of fish and

shellfish in early life stages. Although the draft SEIS identifies current measures already in

place to mitigate for entrainment (such as intake location and a high-frequency fish deterrent

system), it is not clear that these measures will satisfy the rule's requirements. We recommend

the final SEIS not include the following statement: "The staff concludes that the potential

impacts of entrainment of fish and shellfish in the early life stages into the cooling water intake

system are SMALL, and further mitigation measures are not warranted." This conclusion is

premature pending the results of the study required by the Wisconsin Department of Natural -

Resources (WDNR) to comply with the new regulations. The WDNR will use the results of the

study to determine whether other measures are necessary and need to be reflected in the

plant's next discharge permit. Instead, the final SEIS could discuss how the current

entrainment mitigation measures may function as a compliance alternative under the rule and

achieve the targeted performance standard for the facility. (PB-CD-15)

Comment: The Draft Supplement 23 discusses the entrainment and impingement of birds,

fish, and shellfish as a result of the continued operation of the cooling water intake system and

indicates that entrainment and impingement of fish and shellfish will also be addressed during.

renewal, of the plant's National Pollution Discharge Elimination System permit. The permit

renewal is under the authority of the Wisconsin Department of Natural Resources (DNR) and

will be subject to the Environmental Protection Agency's recently published 316(b) Phase II

regulations. The Service will coordinate with the Wisconsin DNR on the review of the data

related to renewal of the permit.- (PB-CE-3)

Response: Chapters 2 and 4 of this SEIS discuss how PBNP, like all thermal electric power

plants having surface water discharges, is subject to the compliance requirements of the Clean

Water Act, including the recently revised Section 316(b) Phase II regulations. These are and

will continue to be administered at PBNP by the State of Wisconsin Department of Natural

Resources (WDNR) as part of the PBNP Wisconsin Pollutant Discharge Elimination System

(WPDES) permit, irrespective of the outcome of the license renewal action that is the subject of

this SEIS.

The final rule issued by EPA on February 16, 2004 (commonly referred to as the Clean Water

Act Section 316(b) Phase II regulations), establishes requirements to minimize adverse effects

to fish and shellfish from cooling waterintake structures at large powerplants. Facilities will

have several compliance altematives to meet the performance standards defined in the final

rule. The alternatives include demonstrating that the existing cooling water intake configuration

provides adequate protection, selecting additional fish protection technologies (such as screens

with fish return systems), and using restoration measures. Additional information regarding the --

rule can be found at httpi/www.epa.gov/waterscience/316b/. The rule became effective

sixty (60) days after the date of its publication in the Federal Register (July 9, 2004,

69 FR 41575). The rule provides a period of up to approximately 4 years from the effective

date of the regulation for facilities to determine the compliance alternative to be pursued, and to

complete studies .or facility modifications, as necessary. PBNP will be subject to the provisions

of the final rule and will determine which of the compliance alternatives it will be pursuing.

As stated above, compliance with this rule is accomplished as part of each regulated facility's

implementation of the Clean Water Act National Pollutant Discharge Elimination System

August 2005 A-23 NUREG-1437, Supplement 23
Appendix A

(NPDES) program. For PBNP, this program is administered by the WDNR, who reissued the

PBNP WPDES permit on July 1, 2004. PBNP submitted their initial deliverable to the WDNR in

response to the Section 316(b) Phase II requirements on December 24, 2004. WDNR, in their

review of PBNP's Phase II demonstration, will clarify how the proposed mitigation measures

would function as a compliance alternative and how the changes to the facility will meet the

targeted performance standard.

As part of this environmental review, the NRC staff consulted with WDNR regarding PBNP's

compliance with WPDES requirements, including potential changes in response to the revised

Section 316(b) Phase II regulations. For the purposes of this license renewal action, the NRC

staff has determined that the impacts of current and reasonably foreseeable future PBNP

operations related to entrainment would be SMALL. Nevertheless, if at some time in the future

the WDNR requires PBNP to implement additional mitigation measures under the new

regulations, any entrainment impacts would be reduced further. The comment does not provide

new and significant information and, therefore, will not be evaluated further.

Comment: The Generic EIS and Draft Supplement 23 adequately discuss most of the impacts

of continued operations of the plant on fish and wildlife resources, as well as species protected

by the Endangered Species Act. (PB-CE-1)

Response: The comment relates to aquatic ecology, terrestrial ecology, and threatened and

endangered species issues. The comment does not provide new and significant information

and, therefore, will not be evaluated further.

Comment: With regard to entrainment and mortality of birds, the Draft Supplement 23

correctly states that the applicant has been reporting bird entrainment and mortality to the

Service on an annual basis. While the intent of the previous modification of the intake structure

was to eliminate any further mortality of cormorants (see page 2-27), the reports from

June 1, 2001, to December 31, 2003, indicate bird entrainment and mortality has continued

(see page 4-18). Service personnel visited the site in 2004 and viewed bird carcasses that had

undergone appreciable decomposition after intake entrainment. The carcasses were tentatively

identified as those of grebes and other waterfowl. The Service will continue to work with the

applicant in addressing this issue. (PB-CE-4)

Response: The comment relates to impingement of waterfowl at PBNP. At PBNP, waterfowl

have been impinged (i.e., been trapped) against the traveling screens but have not been

reported to pass through the screens into the plant's cooling system. Entrainment is the

process whereby an organism small enough to pass through the traveling screens passes

through the plant's cooling system. No entrainment of waterfowl has been reported. Text in

Section 4.1.2 has been changed to address impingement of waterfowl.

Comment: The fourth species considered in the BA is the piping plover. Although no piping

plovers have been observed on the project site, there is designated critical habitat for the plover

located to the south of the plant and there is also suitable habitat for the plover on the plant

grounds. The Great Lakes piping plover population is rapidly expanding, and there is some

probability that plovers may attempt to use the beaches on the plant property in the near future.

The Service and the Commission are continuing informal consultation concerning the specifics

NUREG-1437, Supplement 23 A-24 August 2005

I I
Appendix A

of annual surveys the applicant has agreed to conduct for plover use of the plant grounds over

the life of the license renewal period. The Department appreciates the willingness of the

applicant to cooperate with the agencies in protection of the plover. (PB-CE-2)

Response: The comment relates to aquatic ecology, terrestrial ecology, and threatened and

endangered species issues. The staff has evaluated the potential impact likely to result from

operation of the PBNP for an additional 20 years. This evaluation was documented in a

biological assessment (BA) submitted to the U.S. Fish and Wildlife Service (FWS) on

November22, 2004. A supplement to the BA was submitted on April 21, 2005, that included a

detailed framework for piping plover monitoring and reporting. In a letter dated May 5, 2005,

the FWS concurred with the staff's determination that the proposed action may affect but would

not adversely affect the piping plover, thus concluding consultations with the NRC under

Section 7 of the Endangered Species Act. The text in Section 4.6.2 has been revised to reflect

this information.

A.2.5 Comments Concerning Human Health Issues

Comment: Section 8.2.1.1, Closed-Cycle Cooling System, page 8-19, under Human Health.

We recommend the draft SEIS either cite specific dose estimates for this alternative or provide

estimates that use currently available data or that can be logically extrapolated from currently

available information. We further recommend evaluating any dose estimates that fall in the risk

range of 10-6 to 10-4 or greater for potential public health risk impacts and noting specific

doses that are subject to regulatory requirements. This information would be useful to the

public in comparing alternatives. (PB-CD-12)

Response: The impacts to air quality and human health resulting from the operation of a

coal-fired plant are discussed in general in the GEIS (NUREG-1437). The GElS acknowledges

public health risks from emphysema and cancer would likely result from coal-fired power plant

emissions of regulated pollutants and radionuclides. While it is possible to estimate the dose

from a coal-fired power plant, many assumptions would be required, including location and

makeup of the affected population. For the basis of comparing alternatives, the staff does not

perform a complete assessment of impacts of the alternatives, but rather a qualitative, and, if

possible, a quantitative comparison. Because the location of an alternative to the PBNP and,

the surrounding population distribution for this indeterminate location is purely speculative, an

estimated dose would have little real meaning. The comment does not provide new and

significant information and, therefore, will not be evaluated further.

Comment: Section 8.2.3.1, Closed-Cycle Cooling System, page 8-44, under bullet point

Human Health. Human-health impacts need to be specified, rather than merely referenced to

provide a clearer understanding of the risk determination in this section of the document.

(PB-CD-1 4)

Response: The SEIS relies to a great degree on impact analyses presented in the GEIS

(NUREG-1437) by the use of a process called tiering. The concept of tiering was promulgated

by CEO in 1978. As a supplement, this SEIS relies on tiering from the GEIS and does not need

to repeat all analysis and conclusions presented in the GEIS. Appropriate sections of the GEIS

are referenced, when necessary. Human health impacts are presented in 10 CFR Part 51,

Appendix B, Table B-i. For ease of review, this table can be found at

August 2005 A-25- NUREG-1437, Supplement 23
Appendix A

http://www.nrc.gov/reading-rm/doc-collections/cfrlpartO5 lpartO5l-appb.html. More detailed

information on this topic can be found in Volumes 1 and 2 of the GEIS, which are available at

http://www.nrc.gov/reading-rmldoc-collections/nuregs/staff/sr1437/vl/ and

http://www.nrc.gov/reading-rm/doc-collectionslnuregs/staff/sr1437/v21, respectively. The

comment does not provide new and significant information and, therefore, will not be evaluated

further.

A.2.6 Comments Concerning Postulated Accident Issues

Comment: The HEP that the NRC recommends to reduce by implementing an automatic

pump trip on low RWST level does not include the action to trip the pumps as a critical action

because there is so much time available to complete it. (The first pump is tripped at 60%

RWST level and additional actions to swap to containment sump recirculation are initiated at

34% RWST level.) There would, therefore, be no measurable benefit to implementing this

modification at Point Beach to offset the cost. There is the potential of increasing the

probability of a spurious pump trip from the additional low RWST level pump trip circuitry. This

spurious pump trip would actually result in a slight risk increase if the modification were

implemented. SAMA 126 does not appear cost beneficial. (PB-CC-37 through PB-CC-42)

Response: Text in Chapter 5 and Appendix G has been modified in response to the comments.

Comment: External events are considered in this analysis by increasing the internal CDF by a

factor of (1 + CDF-ext/CDF-int), NOT by a factor of 2.0. This is discussed in the Analysis File

prepared documenting this study. Factor of (1 + CDF-ext/CDF-int) not 2.0. (PB-CC-43 through

PB-CC-48)

Response: Text in Chapter 5 and Appendix G has been modified in response to the comments.

Comment: Change % Contribution from "12.3" to "12.2." (PB-CC-49, PB-CC-50)

Response: Tables in Chapter 5 and Appendix. G have been modified in response to the

comments.

Comment: Change population dose for 'Other Core Melt Sequences" in Table 5-4 from

"1.04 x 10-2" to ""1.04 x 10-1." (PB-CC-51)

Response: Table 5-4 has been modified in response to the comment.

Comment: Change population dose for "Other Core Melt Sequences' in Table G-2 from

"0.0104" to "0.104.' (PB-CC-52)

Response: Table G-2 has been modified in response to the comment.

Comment: Change containment ISLOCA" to ISLOCA." (PB-CC-53)

Response: Text in Appendix G has been modified in response to the comment.

NUREG-1437, Supplement 23 A-26 August 2005

I I
Appendix A

Comment: Paragraph is not correct. This seems to be a misinterpretation of response to RAI

1 Od. An accurate description of the RAI response is provided on Page G-28, lines 17-31.

(PB-CC-54)

Response: Text in Appendix G has been modified in response to the comment.

Comment: Change 'maximum allowable benefit" to "maximum attainable benefit." (PB-CC-55)

Response: Text in Appendix G has been modified in response to the comment.

Comment: Section 5.2.2 Estimate of Risk, pages 5-5, 5-6. The draft SEIS states: "The

baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 3.59 x 10-5 per year. This CDF is based on the risk assessment for internally

initiated events. NMC did not include the contribution to risk from external events within the

PBNP 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 2.0."

We recommend evaluating and presenting risk estimates from both internal and external

events. In addition, given the draft SEIS statements referenced above, effects of external

events should be included in the risk decision considerations, as necessary, to get an accurate

portrayal of the risk of the licensing renewal. If the final SEIS does not incorporate external

events into risk calculations or risk decisions, it should provide a rationale for using

internally-initiated events only. (PB-CD-7)

Response: Risk estimates for both internal and external events are presented and discussed

in Section G.2 of Appendix G of this SEIS. The risk from external events at PBNP is lower than

from intemalevents (approximately 1.3x 10-5peryearforseismiceventsand 1.2x 10-5per

year for fire events, compared to 3.5 x 10-5 per year for internal events). Numerous plant

modifications and procedural/training program enhancements to reduce seismic and fire risk

have already been implemented at PBNP, leading the staff to conclude in Section G.2.2 that it

is unlikely that further modifications would both substantially reduce risk and remain cost

beneficial. Nevertheless, as described in Section G.6.2 of Appendix G, the risk associated with

external events was specifically accounted for in the risk calculations that were used to support

the decision regarding potentially cost-beneficial SAMAs at PBNP.

A.2.7 Comments Concerning Uranium Fuel Cycle and Waste Management Issues

Comment: Section 6.1, The Uranium Fuel Cycle. page 6-8, under On-Site Spent Fuel. We

recommend providing a site-specific evaluation of the volume of spent fuel expected to be

generated during the additional period of operation, along with more specific information on

site-specific circumstances that may impact or improve the risk values for potential exposures

to this spent fuel. In addition, the final SEIS should state whether additional spent fuel storage

capacity is already available or will need to be built in the future. If new capacity will be

constructed, we recommend the final SEIS discuss what type or storage units are proposed,

noting any differences from current operations. -(PB-CD-8)

Response: Each PBNP unit contains 121 nuclear fuel assemblies, and each is currently

refueled on a nominal 18-month refueling cycle. Typically, approximately one-third of the fuel

assemblies are replaced during each refueling, generating approximately 40 spent fuel

August 2005 A-27- NUREG-1437, Supplement 23
Appendix A

assemblies per unit. The fresh fuel and remaining assemblies are rearranged in the reactor

core in a pattern designed to optimize fuel burnup while remaining within safe operating

margins. Over a 20-year license renewal period, refueling would occur about 13 times,

generating a total of approximately 530 spent fuel assemblies for each unit. A total of

approximately 1060 spent fuel assemblies would be generated over the period of license

extension for PBNP Units 1 and 2. Improvements in technology during the 20-year period of

license extension could reduce the overall number of containers and/or refueling cycles,

thereby making this an upper-bound estimate of potential impact.

Onsite storage and offsite disposal of spent nuclear fuel are Category 1 issues. The safety and

environmental effects of long-term storage of spent fuel on site 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/doc-collections/cfr/partO51/partO5l- 0023.html), the NRC

generically detemnined 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 installations.

Further, the Commission believes there is reasonable assurance that at least one mined

geologic repository will be available within the first quarter of the twenty-first century and

sufficient repository capacity will be available within 30 years beyond the licensed life for

operation of any reactor to dispose of the commercial high-level waste and spent fuel

originating in any such reactor and generated up to that time. TMSection 6.1 provides the most

current information available regarding the status of the application for a high-level waste

repository. The comment does not provide new and significant information and, therefore, will

not be evaluated further.

A.2.8 Comments Concerning Decommissioning Issues

Comment: Section 7.1, Decommissioning, pages 7-2, 7-3, under Radiation Doses. Since the

Generic Environmental Impact Statement (GEIS) is based on a forty-year licensing period, an

extension of another twenty years would have an impact that needs to be quantified and

reported. This information should be included specifically in the final SEIS as part of the risk

that would be associated with the license extension. The specific methodology needs to be

provided and fully explained. (PB-CD-9)

Response: 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 GEIS

(NUREG- 1437) and in NUREG-0586 Generic Environmental Impact Statement for

Decommissioning Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear

Power Reactors, published in 2002. The findings from these two documents are used to

support the findings in the SEIS by the use of tiering. Tiering is a process by which agencies

eliminate repetitive discussions. The effects of license renewal on the impacts of

decommissioning are stated in Chapter 7 of this SEIS. The radiation doses to the public during

the period of extended operation are expected to be well below applicable regulatory limits, and

the occupational dose would be expected to increase only slightly. The comment does not

provide new and significant information and, therefore, will not be evaluated further.

NUREG-1437, Supplement 23 A-28 August 2005

II
Appendix A

A.2.9 Comments Concerning Alternatives

Comment: Section 8.2.3.1, Closed -Cycle Cooling System, page 8-40, under Waste. Waste

impacts need to be specified rather than merely referenced to provide a clearer understanding

of the risk determination made in this section of the document. (PB-CD-13)

Response: The SEIS relies to a great degree on impact analyses presented in the GEIS

(NUREG-1437). As a supplement, this SEIS does not need to repeat all analyses and

conclusions of the GEIS. Appropriate sections of the GEIS are referenced, when necessary.

Waste impacts are summarized in 10 CFR Part 51, Appendix B, Table B-i. For ease of review,

this table can be found at http:I/www.nrc.gov/reading-rm/doc-collections/cfr/partO51/

partO51-appb.html. More detailed information on this topic can be found in Volumes 1 and 2 of

the GEIS, which are available at http://www.nrc.gov/reading-rmldoc-collection/nuregs/staff!

sr14371v1/and http//www.nrc.gov/reading-rm/doc-collection/nuregs/staff/srl437/v2,

respectively. The comment does not provide new and significant information and, therefore, will

not be evaluated further.

A.2.10 Editorial Comments

Comment: Sentence states that "...NMC will ultimately decide whether the plant will continue

to operate... Remainder of sentence infers that NMC is the "owner". Consider clarifying this

sentence to note that NMC submitted the renewal application on behalf of the owner, Wisconsin

Electric Power Company (WEPCO). WEPCO will ultimately decide whether the plant will

continue to operate. (PB-CC-1)

Response: Text in the Executive Summary has been modified in response to the comment.

Comment: Wisconsin is misspelled. (Wisconsin) (PB-CC-2)

Response: Text in the Executive Summary has been modified in response to the comment.

Comment: Public meetings were held in March 2005 and not February 2005. (PB-CC-3,

PB-CC-5, PB-CC-36)

Response: Text in the Executive Summary and Sections 1.2.2 and 9.0 has been modified in

response to the comment.

Comment: This paragraph should identify that NMC operates Point Beach but the plant is

owned by WEPCO. (PB-CC-4) -

Response: Text in Section 1.0 has been modified in response to the comment.

Comment: PBNP does not produce electricity for "250 million customers." WEPCO serves

only about 1 million customers in total. On page 7-3 of our Environmental Report NMC states

that PBNP provides about 25 % of the energy that WEPCO provides to its 1.08 million

customers. (PB-CC-6)

Response: Text in Section 1.3 has been modified in response to the comment.

August 2005 A-29 NUREG-1437, Supplement 23
Appendix A

Comment: Sentence states that "NMC is required to hold certain Federal, State, and local

environmental permits..." Sentence should read "NMC or Wisconsin Electric Power Company

are required to hold certain Federal, State, and local environmental permits..." (PB-CC-7)

Response: Text in Section 1.5 has been modified in response to the comment.

Comment: Another reference to the fact that the "owners" will ultimately decide whether the

plant will continue to operate. Reinforces need to assure that the document identifies WEPCO

as the owner. (PB-CC-8)

Response: Text in Section 1.4 has been modified in response to the comment.

Comment: This "design rating" discussion would be clearer if it were stated that the reactors

were "originally" designed to produce a reactor thermal output of 1518.5 megawatts thermal.

This is the language used on page 2-4 lines 9-12. Suggest that the language on page 1-7 be

made consistent with that on page 2-4. (PB-CC-9)

Response: Text in Section 1.3 has been modified in response to the comment.

Comment: "NMC has provided riprap to control further recession of the shoreline at the site."

WEPCO provided the riprap and has the responsibility for controlling beach erosion at the plant.

(PB-CC-10, PB-CC-12)

Response: Text in Sections 2.1.1 and 2.2.5 has been modified in response to the comment.

Comment: "To counter this erosion, NMC has placed riprap along the most sensitive

stretches." WEPCO provided the riprap and has the responsibility for controlling beach erosion

at the plant. (PB-CC-1 1)

Response: Text in Section 2.2.1 has been modified in response to the comment.

Comment: Consider deleting the word annual.' The monitoring program is essentially

continuous. (PB-CC-14)

Response: Text in Section 2.2.7 has been modified in response to the comment.

Comment: Replace NWEPCO assessed doses" with 'NMC assessed doses." (PB-CC-15)

Response: Text in Section 2.2.7 has been modified in response to the comment.

Comment: Consider replacing "boundary" with "site boundary". (PB-CC-1 6)

Response: Text in Section 2.2.7 has been modified in response to the comment.

Comment: The word "south" appears to be missing from the sentence. The state park is

"south of PBNP. (PB-CC-17)

NUREG-1437, Supplement 23 A-30 August 2005

Il
Appendix A

Response: Text in Section 2.2.8.3 has been modified in response to the comment.

Comment: Sentence states that "The PBNP reactor containment structures are encased in

vinyl coated steel buildings that are colored to blend with the green and brown Wisconsin

countryside. This sentence is a slightly different characterization of a similar sentence on

page 2-4 lines 28-29 which states "The containment structures are enclosed in vinyl coated

steel buildings that are colored green and brown to blend in with the Wisconsin countryside.'

The sentence on page 2-39 is more accurate. Page 2-4 should be changed to be consistent

with 2-39. (PB-CC-1 8)

Response: Text in Section 2.1.2 has been modified in response to the comment.

Comment: *reactor containment vessels" should be "reactor containment buildings.".

(PB-CC-1 9)

Response: Text in Section 2.2.8.4 has been modified in response to the comment.

Comment: Inconsistent use of the term "radiological surveillance program" On page 2-32, the

term 'radiological environmental monitoring program" is used. (PB-CC-20)

Response: Text in Section 2.2.10 has been modified in response to the comment.

Comment: The drawing has holes in the fence perimeter at the northeast corner of the

switchyard and the southeast corner of the switchyard. Consider revising the drawing to assure

fence perimeter accurately reflects current design. (PB-CC-21)

Response: Figure 2-3 has been modified in response to the comment.

Comment: The Warehouse & Office" building (commonly referred to as the north gatehouse)

has been demolished. Consider revising the drawing to depict that this building no longer

exists. (PB-CC-22)

Response: Figure 2-3 has been modified in response to the comment.

Comment: Section 2.1.5, - Technically, the vacuum fabric filter system does not treat the

sanitary waste. The on-site sewage treatment plant treats the sanitary waste such that the . -

effluent is suitable for discharge without further filtration. Therefore, a more accurate statement

would be, -A vacuum fabric filter system is now used for treating the wastewater." (PB-CC-23)

Response: Text in Section 2.1.5 has been modified in response to the comment.

Comment: Section 2.1.5, - Recommend the revision of the statement that says PBNP is a

large quantity generator. It should read that PBNP has historically and may in the future

fluctuate between a small quantity and large quantity generator. (PB-CC-24)

Response: Text in Section 2.1.5 has been modified in response to the comment.

August 2005 A-31 NUREG-1437, Supplement 23
Appendix A

Comment: Sentence notes that NMC does not plan to add additional full-time staff at PBNP

during the period of the renewed license. This is in conflict with a sentence on page 4-31, lines

25-26 which states that PBNP anticipates that no more than 2 new employees will be added

during the license renewal term. Recommend that following statement is more correct: NMC

does not plan to add significant additional full-time staff at PBNP during the period of the

renewed license.' (PB-CC-25)

Response: Text in Section 2.1.6 has been modified in response to the comment.

Comment: Section 2.2.3, - The current WPDES permit was actually issued on July 1, 2004,

not on July 7, 2004. The permit dates are mentioned in several other places throughout the

report, but the 3 other places checked all had the correct date. It appears that just this one

instance is incorrect. (PB-CC-26)

Response: Text in Section 2.2.3 has been modified in response to the comment.

Comment: Correct permit number is 436034500-PlO. (PB-CC-27)

Response: Text in Section 2.2.4 has been modified in response to the comment.

Comment: Add the word "nominal." Sentence should note that PBNP reactors are on a

nominal 18-month refueling cycle. (PB-CC-29)

Response: Text in Section 2.2.8.1 has been modified in response to the comment.

Comment: Section 4.1.1, and Section 4.1.2, - The acoustic fish-deterrent system was installed

in 2002, not 2003. (PB-CC-30)

Response: Text in Sections 4.1.1 and 4.1.2 has been modified in response to the comment.

Comment: Section 4.1.1, and Section 4.1.2, - The proposal for the study that was due on

December 31, 2004, was submitted to WDNR (transmittal letter dated 12/24/04). (PB-CC-32)

Response: Text in Sections 4.1.1 and 4.1.2 has been modified in response to the comment.

Comment: There is no mention that the Wisconsin State Historical Society issued a

Determination of Eligibility, (sic) State Historic Preservation Office that states that the Alois Biel

Fishing Shed is not eligible for the National Register of Historic Places (WSHS letter dated

Oct 21, 2004). The draft EIS states that NMC did not recommend the shed for inclusion - but it

is the WSHS that makes the final determination. (PB-CC-33)

Response: Text in Section 4.4.5 has been modified in response to the comment.

Comment: NMC owns no generating assets. This paragraph should discuss WEPCO's plans

for delayed retirement and not NMC's. (PB-CC-34)

Response: Text in Section 8.2.5.9 has been modified in response to the comment.

NUREG-1437, Supplement 23 A-32 August 2005

I I
Appendix A

Comment: Sentence states that "...NMC will ultimately decide whether the plant will continue

to operate..." Actually, WEPCO will decide if PBNP continues to operate. (See Comment #1

above regarding similar paragraph on Page xv) This summary section should clarify that

WEPCO is owner and NMC is operator. (PB-CC-35)

Response: Text in Section 9.0 has been modified in response to the comment.

Comment: Section 2.2.7, Radiological Impacts, pages 2-32 through 2-34. The references to

the specific environmental standards need to be included (i.e., complete citations including title

of the rule or regulation; along with the basic standard for comparison). All environmental

standards that could be used for a comparison should be used, including 40 CFR 61

Radionuclide National Emission Standards for Hazardous Air Pollutants values. This will assist

the public in verifying values that are cited in the text and evaluating the radiation values.

(PB-CD-3)

Response: The comment is noted. The complete citation for each of the environmental

standards referenced in the text is provided in the references for Chapters 2 (Section 2.3)

and 4 (Section 4.10). These standards are readily accessible on the Internet to members of the

public. Text in Section 2.2.7 has been modified to refer to the basic standard for comparison (a

25-mrem total annual dose).

Comment: Section 3.0 Environmental Impacts of Refurbishment, page 3-2, Table 3-1. Under

the section on Human Health, specific information supporting any assertion that this area needs

no further evaluation needs to be presented or more completely cited and described.-.

(PB-CD-4)

Response: The impact of refurbishment is not considered in the SEIS because, as stated in

Section 3.0, the applicant does not plan any refurbishment actions at the site. The comment

does not provide new and significant information and, therefore, will not be evaluated further.

Comment: Section 4.3, Radiological Impacts of Normal Operations,' pages 4-27, 4-28,

Table 4-5, and following paragraphs in the section. -The draft supplemental environmental

impact statement (SEIS) cites the location of radiological exposure information in the GEIS, but

does not include specific values. The final SEIS should provide the specific exposure values, in

addition to the GEIS citation. This will be clearer and assist the public in understanding the

project's impacts. (PB-CD-5)

Response: Radiological impacts of normal operations were considered and evaluated in the

GEIS. In this SEIS, issued as a supplement to the GEIS, the staff determined whether any new

and significant information is available that would change the conclusion reached in the GEIS

(i.e., that these impacts would be small). The comment does not provide new and significant'

information and, therefore, will not be evaluated further.

Comment: Section 4.8.3, Cumulative Radiological Impacts, page 4-69, Paragraph 1.-

Information or procedures used to generate values to support the assertions in this section

need to be provided in a clearermanner to support the conclusions. (PB-CD-6)

August 2005 A-33- NUREG-1437, Supplement 23
Appendix A

Response: Text in Section 4.8.3 has been modified in response to the comment.

Comment: Section 8.1, No-Action Alternative, page 8-5, under Human Health. This section

refers in general terms to reductions in the amount of radioactive material; we recommend

adding actual values, which will assist the public in comparing alternatives. (PB-CD-10)

Response: The conclusion presented in the SEIS is based on the logical argument that

cessation of operations at PBNP would result in a reduction in radioactive emissions, since the

operations producing those emissions would cease. Since the radiological impacts of normal

operations were determined to be SMALL (as discussed in Section 4.3), the impact of the

no-action alternative, which would result in the cessation of those operations, would logically be

even less, and therefore, also SMALL. The comment does not provide new and significant

information and, therefore, will not be evaluated further.

A.2.11 Comments Concerning Issues Outside the Scope of License Renewal

Comment: My question is: can you address the impact a terrorist attack would have on the

Spent Fuel Pool located between the two units at Point Beach Nuclear Plant? Since the World

Trade Center complex went down, I think we all realize just what our enemies can do if given

the chance. Some people feel it's just a matter of time before another similar attack is

attempted. I am asking about this particular component of the Systems at Point Beach

because that Spent Fuel Pool seems to me to be relatively exposed since it is housed inside a

metal building. I know the actual Reactor Vessels are in a stronger environment, although, I

guess so were the Buildings that were destroyed on 9-11. If this plant were ever to be a target;

what would catastrophic damage to the Pool mean to us as residents of this area? What would

happen to Lake Michigan? How much damage would be permanent? Thank You. (PB-CA-1)

Response: In response to the September 11, 2001 attacks, the NRC has moved aggressively

to further enhance safety and security, and has comprehensively re-evaluated and

strengthened security at nuclearpowerplants and other facilities and for radioactive material it

regulates. Actions taken by NRC since September 11, 2001, to protect nuclear facilities from

attack are identified in the report entitled Protecting the Nation Since 9-11-01, which is available

on the Internet at http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/brO314/.

Major actions include the following:

• Ordering plant owners to increase physical security to defend against a more challenging

adversarial threat.

* Requiring strict site access controls for personnel

• Requiring utilities to conduct vehicle checks at greater stand-off distances.

• Improving liaison with Federal, State, and local agencies responsible for protection of the

national critical infrastructure through integrated response planning.

• Enhancing communication and liaison with the intelligence community.

NUREG-1437, Supplement 23 A-34 August 2005

II
Appendix A

* Improving communication between military surveillance authorities, NRC, and its licensees

to prepare power plants and to effect safe shutdown should it be necessary.

* Ordering plant owners to improve their capability to respond to events involving explosions

or fires.

* Enhancing readiness of security organizations by strengthening training and qualification

programs for plant security forces.

• Enhancing force-on-force exercises to provide a more realistic test of plant capabilities to

defend against an adversary force.

• Working with national experts to predict the realistic consequences of terrorist attacks on

nuclear facilities, including one from a large commercial aircraft. For the facilities analyzed,

the results confirm that the likelihood of both damaging the reactor core and releasing

radioactive material that could affect public health and safety is low.

Even in the unlikely event of a radiological release due to terrorist use of a large aircraft against

a nuclear power plant, studies indicate that there would be time to implement the required

onsite mitigating actions, whether involving the reactor or the spent fuel pool. These results

have also validated the offsite emergency planning basis. However, the Commission has

determined that malevolent acts, including aircraft impacts, are not considered within the scope

of issues to be addressed in its Environmental Impact Statements. Such events cannot be

reasonably quantified and are considered speculative. The Commission's position is that NEPA

does not require the NRC to evaluate the effects of impacts of a speculative and unquantifiable

event.

Comment: The final SEIS should discuss planned or potential power uprates at the Point

Beach Nuclear Plant and estimate resulting increases in radiological emissions, spent fuel, and

other emissions. Although U.S. NRC's regulations (10 C.F.R Part 51 .53(c)(2)) state that an

applicant's environmental report need not discuss the demand for power, we consider power

uprates to be reasonably foreseeable actions that contribute to a cumulative radiological impact

under 40 C.F.R Part 1508.7, and therefore should be discussed in U.S. NRCs final SEIS.

(PB-CD-1 6)

Response: Although the power uprate information was considered in the SAMA analysis for

sensitivity purposes, the Commission has already stated that, for NEPA purposes, a possible

future action "must at least constitute a proposal pending before the agency' for it to be

considered along with the proposed action, which here is license renewal. The Commission's

decision was set forth in the following case: Duke Energy Corp. (McGuire Nuclear Station,

Units 1 and 2; Catawba Nuclear Station, Units 1 and 2) CLI-02-14, 55 NRC 278, 294-297

(2002). Since NMC does not at this time have a proposal pending before the NRC that relates

to a power uprate for PBNP, the SEIS does not address future power uprates in the evaluation

of the impacts of license renewal on individual issues or on cumulative impacts. In addition, the

Commission in the aforementioned case stated that, for the license renewal action and a

separate proposal (such as a power uprate application) to be considered together, both actions

must be "interdependent, " such that one cannot go forward without the other. License renewal

does not depend on a power uprate, and a power uprate does not depend on license renewal;

August 2005 A-35- NUREG-1437, Supplement 23
Appendix A

each action has separate utility. Should a power uprate amendment request for PBNP be filed,

the staff would then consider whether there are cumulative impacts associated with the power

uprate.

NUREG-1437, Supplement 23 A-36 August 2005

II
Appendix A

From:

To

Date:

Subject:

'Dariel Hahn' cdhahn~lsotnetb

cPointeachEISSr nwcgov>

Sat. Feb 262005 8.03 AM

Question /7oAv. a/-,~

PB-CA-i Hello, My question s: can you address the impact a terrorist attack would have on the Spent Fuel Pood C,

located between the two units at Point Beach Nuclear Plant?

Since the World Trade Center complex went down, I think we all realize just what our enemies can do

if given the chance. Some people feel it's justa matter fime before anotherssimilarattack is attempted.

lam asking about this particular oomponent d the Systems at Point Beach because that Spent Fuel Pool

seemsto me to be retativetyexposedcsince t is housed inside a metal building. I knowthe actualReactor Vesselsare ina strongerenvionment.although. I guessso

were the Buildingsthat were destroyedon9-11. If this plant were ever to be a target what would

catasbtphic damage to the Pool mean to us as residents of this area? What would happen to Lake

Midigan? How much damage would be permanent?

Thank You

DanielHahn

Two Rivers Wi

dhahn lsol.net

r,5f ez-6S 7 ,e-,tfx P 5; =,OO ) ,fC -,O ---3

7;~:~ .- 6-3

August 2005 A-37 NUREG-1437, Supplement 23
Appendix A

rkqs q r-c

J. Kevin McCoy

225 Farcy Branch Drive

Lynchburg, V'rginia 24502-2364

March 12, 2005

Chief, Rules Review and Directives Branch

US. Nuclear Regulatory Conunission

Mail Stop T6-D59

Washington, DC 20555-0001

deva-f .._ 

P,Cex',y,3g

Dear Sir or Madarm

I have reviewed NUREG-1437. Supplement 23, dmft(Generic EnvironmentalrmpacJ Statement

for License Renetval ofNudear Plants. Supplement 23. Regarding Point Beach Nuclear Plant

P-CEW Units I and2, Draft Reportfor Comment). I find that the supplement has acceptably evaluated

the environmental impacts of license renewal for the Point Beach Nuclear Plant. I recommend

that the report be issued as finaL

Sincerely.

J. Kevin McCo

N rEG-1 437Z, S upple me 2 3

NUREG-1437, Supplement 23

Cc A5. ugus 25,)

A-38 August 2005

I I
Appendix A

,. . .

Comniricrd to N rkaEce Point Beach Nuclear Plant

Operated by Nuclear Management Company. LUC

Apnl 11, 2005 NRC 2005D0042

10CFR54

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, DC 20555

Point Beach Nuclear Plant, Units I and 2

Dockets 50-266 and 50-301

License Nos. DPR-24 and DPR-27

Comments on Draft NUREG-1437 Supolement 23

Regarding the Point Beach Nuclear Plant License Renewal Aeplication

(TAC Nos. MC2049 and MC20501

By letter dated February 25.2004, Nuclear Management Company. LUC (NMC),

submitted the Point Beach Nuclear Plant (PBNP) Units I and 2 License Renewal

Application (LRA). On January 13. 2005. the Nuclear Regulatory Commission

(NRC) published for comment NUREG-1437 Supplement 23, "Generic

Environmental Impact Statement for Ucense Renewal Of Nuclear Plants,

Supplement 23. Regarding Point Beach Nuclear Plant Units I and 2.' The

enclosure to this letter contains NMC's comments on this Supplement.

Should you have any questions concerning this submittal, please contact

Mr. James E. Knorr at (920) 755.6863.

This letter contains no new commitments and no revisions to existing

commitments.

Dennis L Koehl

Site Vice-President, Point Beach Nuclear Plant

Nuclear Management Company, LLC

Enclosure

6590 Nuclear Road * Two Rivers.Wisconsin 54241

Telephone: 920.7552321

August 2005 A-39 NUREG-1437, Supplement 23
Appendix A

Document Desk

Page 2

cc: Administrator, Region Ill. USNRC

Project Manager. Point Beach Nuclear Plant. USNRC

Resident Inspector, Point Beach Nuclear Plant. USNRC

PSCW

NUREG-1437, Supplement 23 A-40 August 2005

I n
Appendix A

PB-CC-1

PB-CC-2

PB-CC-3

PB-CC-4

PB-CC-5

PB-CC-6

PB-CC-7

PB-CC-8

ENCLOSURE

COMMENTS ON DRAFTNUREG-1437SUPPLEMENT23

REGARDING POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

LICENSE RENEWAL APPLICATION

The following information is provided to comment on the draft NUREG-1437

Supplement 23 regarding the Point Beach Nuclear Plant (PBNP) Uicense

Renewal Application (LRA).

Speclifc Comments

Comment Page Reference Comment

Number _ Unes - 1 xv 7-9 Sentence states that ...;.NMC will ultimately decide whether the plant will continue to

operate...." Remainder of sentence Infers that

NMC Is the downer. Consider clarifying this

sentence to note that NMC submitted the

renewal application on behalf of the owner,

Wisconsin Electric Power Company (WEPCO). WEPCO will ultimately decide whether the

plant will continue to operate.

2 xv 24 & 34 Wisconsin Is misspelled. iWiscsonsin)

3 xv 34 Public meetings were held In March 2005 and

not February 2005.

4 1-- - 20-22 This paragraph should Identify that NMC

operates Point Beach but the plant Is owned

bY WEPCO.

5 1-7 17 Public meetings were held In March 2005 and

not February 2005.

6 1-8 4 PBNP does not produce electricity for 250

million customers. WEPCO serves only about

1 milion customers In total. On page 7-3 of

our Environmental Report NMC states that

PBNP provides about 25 % of the energy that

WEPCO provides to Its 1.08 million customers.

7 1-9 3-5 Sentence states that NMC Is required to hold

certaIn Federal, Slate, and local environmental

permits..... Sentence should read "NMC or

Wisconsin Electric Power Company are

required to hold certain Federal, State, and

local environmental permrits..

8 1-8 16-18 Anotherreferencetothefactthatthe 'owners'

will ultimately decide whether the plant wiil - continue to operate. Reinforces need to

assure that the document Identifies WEPCO

as the owner.

Page 1 of 5

August 2005 A-41 NUREG-1437, Supplement 23
Appendix A

PB-CC-9

PB-CC-10

P8-CC-il

PB-CC-I2

PB-CC-13

PB-CC- 14

PB-CC-i15

PB-CC-la

PB-CC-17

PB1-CC-IS

Comment Page Reference Comment

Number . Lines

9 1-7 36-39 This'design rating' discussion would be

cdearer if It were stated that the reactors were

"orlginallf designed to produce a reactor

thermal output of1151 8.5 megawatts thermal.

This Is the language used on page 2-4 lines 9-

12. Suggest that the language on page 1-7 be ________ _____made consistent with that on page 2-4.

1 0 2-4 4 7NMC has provided riprap to control further

recession of the shoreline at the sit e.'

WEPCO provided the Riprap and has the

responsibility for controlling beach erosion at ______ the plant.

1 1 2-16 1 9 'To counter this erosion, NMC has placed riprap along the most sensitkve stretc~hes.'

WEPOO provided the Riprap and has the

responsibility for controllIng beach erosion at _____ _____ ____ the plant.

12 2-20 25 INMC has provilded riprap to control further

recesson, of the shoreline at the site.'

WEPCO provided the Riprap, and has the

responsibility for controlling beach erosion at __________the plant.-

13 2-19 6-7 This sentence does not seem to be factually correct. More than one tornado has caused ___________major property damage In the state.

1 4 2-32 26 Consider ,deleting the word 'annual.' The ______ __________monitoring program Is essentiafly continuous.

1 5 2-33 21 Replace 7WEPCO assessed doses' with __________ NMC assessed doses"

1 6 2-33 2-5 Consider replacing boundary' with 'site ____ ___ ___ boundary"

1 7 2-38 32 The word 'south' appears to be missing from

fth sentence. The state park Is "south" of _____ ____ PBNP.

1 8 2-39 37-39 Sentence states that 'The PBNP reactor

containme*nt structures are encased In vinyl coated steel buildings that are colored to blend

with the green and brown Wisconsin

countryside.' This sentence Is a slightly different characterization of a similar sentence

on page 2-4 lines 28-29 which states "The

containment structures are enclosed In vinyl

coated steel buildings that are colored green and brown to blend In With the Wisconsin

countryside.

The sentence on page 2-39 is more accurate.

Page 2-4 should be changed to be consistent ____ ____ ____ _ __ ____ ___ w ith 2-39.

Page 2 of 5

NUREG-1 437, Supplement 23 A-42 August 2005

IrI
Appendix A

PB-CC-19

PB-CC-20

PB-CC-21

PB-CC-22

PB-CC-23

PB-CC-24

PB-CC-25

PB-CC-26

PB-CC-27

Comment Page Reference Comment

Number iUnes

19 2-40 5-6 'reactor containment vessels should be

-r Reactor containment buildinas

20 2-52 25 Inconsistent use of the term radiological

surveillance program' On page 2-32, the

term radiologfcal environmental monitoring

vroraramf Is used.

21 2-5 Figure 2-3 The drawing has holes In the fence perimeter

at the northeast comer of the switchyard and

the southeast corner of the switchyard.

Consider revising the drawing to assure fence _perimeter accurately reflects current design.

22 2-5 Figure 2-3 The Warehouse & Office building (commonly

referred to as the north gatehouse) has been

demolished. Consider revising the drawing to

depict that this building no longer exists.

23 2-11 20 Section 2.1.5. - Technically, the vacuum fabric

filter system does not treat the sanitary waste.

The on-site sewage treatment plant treats the

sanitary waste such that the effluent Is suitable

for discharge without further filtration.

Therefore, a more accurate statement would

be, 'A vacuum fabric filter system Is now used

for treating the wastewater.

24 2-11 23-31 SectIon 2.1.5. Recommend the revision of the

statement that says PBNP Is a large quantity

generator. It should read that PBNP has

historically and may In the future fluctuate

between a small quantity and large quantity

generator.

25 2-12 18-20 Sentence notes that NMC does not plan to add

additional full-time staff at PBNP during the

period of the renewed license. This Is In

conflict with a sentence on page 4-31 lines

25-26 which states that PBNP anticipates that

no more than 2 new employees will be added

during the license renewal term. Recommend

that following statement Is more correct: 'NMC

does not plan to add significant additional fulltime staff at PBNP during the period of the

renewed license.'

26 2-18 6 Section 2.2.3. - The current WPDES permit

was actually Issued on July 1, 2004. not on

July 7,2004. The permit dates are mentioned

In several other places throughout the report.

but the 3 other places checked all had the

correct date. It appears that just this one

Instance Is Incorrect.

27 2-20 9 Correct permit number Is 436034500-P10

Page 3 of 5 I

August 2005 A-43 NUREG-1 437, Supplement 23
Appendix A

PB-CC-28

PB-CC-29

PB-CC-30

PB-CC-31

PB-CC-32

PB-CC-33

PB-CC-34

PB-CC-35

PB-CC-36

Comment Page Reference Comment

Number Lines

28 2-21 6-18 Per WDN R, Ltake Michigan is not onthe fish

_ -_ __ advisory due to mercury;

29 2-34 22 Add the word nominal.' Sentence should note

that PBNP reactors are on a'nominal

18-month refueling cycle.

30 4-13 26 and 40 Section 4.1.1. and Section 4.1.2, - The

and acoustic fish-deterrent system was Installed In

4-.16 2002, not 2003.

31 4-16 40 a... NMC installed a pemanent fish deterrent

system around the Intake structures ... ' WEPCO designed and Installed the fish

deterrent system under a compliance

agreement with the U.S. Fish & Wildlife

Service.

32 4-13 14 Section 4.1.1, and Section 4.1.2. - The

and proposal for the study that was due on

4-18 30-31 December 31.2004. was submitted to WDNR

(transmittal letter dated 12f24104)

33 4-36 7-8 There Is no mention that the Wisconsin State

Historical Society Issued a Determination of

Ellgibility. State Historic Preservation Office

that states that the Alois Biel Fishing Shed is

not eligible for the National Register of Historic

Places (WSHS letter dated Oct 21, 2004). The

draft EIS states that NMC did not recommend

the shed for Inclusion - but it Is the WSHS that

makes the final deterrmination.

34 8.49 31-33 NMC owns no generating assets. This

paragraph should discuss WEPCO's plans for

delayed retirement and not NMCs.

35 9-1 5-8 Sentence states that " ... NMC will ultimately

decide whether the plant will continue to

operate..7 Actually, WEPCO will decide if

PBNP continues to operate.

(See Comment #1 above regarding similar

paragraph on Page xv) This summary section

should clarily that WEPCO Is owner and NMC

Is operator.

36 9.1 36 Public meetings were held In March 2005 and

not February 2005.

NMC continues to believe that the SAMA 126 would not be cost beneficial. The

benefit would be small (only reduce one of the current human error probabilities

(HEPs), would incorporate new failure mechanisms) and the cost would be

considerable (safety related modifications).

Page 4 of 5

NUREG-1437, Supplement 23 A-44 August 2005

II
Appendix A

.I. . .

PB-CC-37-42

PB-CC-37

PB-CC-38

PB-CC-39

PB-CC-40

PB-CC-41

PB-CC-42

PB-CC-43-55

The HEP that the NRC recommends to reduce by implementing an automatic

pump trip on low RWST level does not Include the action to trip the pumps as a

critical action because there is so much time available to complete it. (The first

pump is tripped at 60% RWST level and additional actions to swap to

containment sump recirculation are Initiated at 34% RWST level.) There would.

therefore. be no measurable benefit to Implementing this modification at Point

Beach to offset the cost. There Is the potential of Increasing the probability of a

spurious pump trip from the additional low RWST level pump trip circuitry. This

spurious pump trip would actually result In a slight risk Increase If the modification

were Implemented.

Comment Page Reference Comment

Number Unes

37 5'5 23-28 SAMA 126 does not appear cost beneficial

38 569 - 17-28 SAMA 126 does not appear cost beneficial

39 G-16 - t-19 SAMAt126 does not appear cost beneficial

40 G-29 25-31 SAMA 126 does not appear cost beneficial

41 6-31 15-16 SAMA 126 does not appear cost beneficial

42 G-32 8-13 SAMA 126 does not appear cost beneficial

Extemal events are considered In this analysis by Increasing the Intemal CDF by

a factor of (1 + CDF dCDFw). NOT by a factor of 2.0. This Is discussed In the

Analysis File prepared documenting this study.

Comment Page Reference Comment

Number Llnes -

43 5-6. 5 Factor of (1 + CDF d/CDFkw) not 2.0

44 5-8 6 Factor of (1 + CDFiCDF.v) not 2.0

45 G-27 Table Notes Factor of 01 + CDFe,,CDFW) not 2.0

46 G-28 9 Factorof (1 +CDFodCDFtm)not2.0

47 G-31 31 Factor of (I 1 CDF.WCDF:,.) not 2.0

48 G-32 2 Factor of (1 + CDF dCDFb) not 2.0

49 5-6 14 Change % Contribution from'12.3"to'122.

50 5-7 -16 Change % Contribution from 12. to'122.

51 G-3 15 Change population dose for 'Other Core Melt

Sequences7 In Table 5-4 from 1.04 x 1 o2 to

01.04 x l0". -

52 G-4 37 Change population dose for 'Other Core Melt

Sequences" in Table G-2 from 0.0104 to

53 G-9 33 Change 'containment ISLOCA" to "JSLOCA".

54 G-15 31-36 Paragraph Is not correct. This seems to be a

mIsinterpretation oa response to RAtI tOd.

An accurate description of the RAI response is provided on Page G-28, lines 17-31.

55 G-31 27 Change maximum allowable benefit to - maximum attainable benefit.

PB-CC-43

PB-CC-44

PB-CC-45

PBC-46

PB-CC-47

PB-CC-48

PB-CC-49

PB-CC-So

PB-CC-51

PB-CC-52

PB-CC-53

PB-CC-54

PB-CC-SS

Page 5of5

August 2005 A-45 NUREG-1437, Supplement 23
Appendix A

12 0)13 1 f-i cle 4kA/ 5-

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5/

77 WEST JACKSON BOULEVARD

CHICAGO. IL eD604-3590

APR 1 3205 3 

RtPLY TO SHE ATrER0N OF:

B-19i

Chief, Rules Review and Directives Branch

U.S. Nuclear Regulatory Commission

Mail Stop T6-D59

Washington. D.C. 20555-0001

Re: Generic Environmental Impact Statement ror License Renewal of Nuclear Plant,

Supplement 23: Point Beach Nuclear Plant Units 1 and 2, Draft Report

(CEQ No. 050021)

Dear Sir or Madam:

In accordance with Section 309 of the Clean Air Act and the National Environmental Policy

Act (NEPA), the U.S. Environmental Protection Agency (US. EPA) has reviewed the Draft

Generic Environmental Impact Statement for License Renewal of Nuclear Plant, Supplement

23 (SEIS): Point Beach Nuclear Plant Units I and 2.- According to the draft SEIS, the current

operating licenses for Point Beach Units I and 2 will expire in October2010 and March

2013, respectively. The proposed Federalaction would renew the current operating licenses

for an additional 20 years.

The Nuclear Regulatory Commission (NRC) developed the Generic Environmental Impact

Statement (GEIS) to streamlinc the license renewal process on the premise that

environmental impacts of most nuclear power plant license renewals are similar, in most

cases. NRC develops facility-specific SEIS documents for individual plants as the facilities

apply for license renewal. The U.S.EPA provided comments on the GEIS during its

development process in 1992 and 1996.

The Point Beach Nuclear Plant is located in Manitowoc County, Wisconsin, on the shoreline

of Lake Mfichigan. Units I and 2 are pressurized light-water reactors. Point Beach Units 1

and 2 each currently produce 1540 megawatts of thermal energy and generate 545 megawatts

of electrical power. Each unit is refueled on a 18-month cycle. Plant cooling is provided by

a once-through circulating water system that draws and discharges to Lake Mlichigan. The

U.S. EPA participated in a site visit on June 16, 2004 and provided scoping comments dated

July 1, 2004.

PS-CD-1 Based on the review of the Point Beach Nuclear Plant draft SEIS, the US. EPA has rated the

project and document "Environmental Concerns- insufficient information" (EC-2). This

means that the U.S. EPA has identified environmental impacts that should be avoided and

suggests corrective measures which may require changes to the preferred alternative or

S1517 1erAey e EhT-l)i

URE ,1- 437 pplemt ew ntr. 2 .Su -4 6August200 d P3' ( S F)

NUREGi-1437, Supplement 23 A-46 August 2005

Il
Appendix A

PB-CD-1 mitigation measures that can reduce impacts. The rating also means that the draft SEIS needs

further information to fully assess environmental impacts of the preferred alternative or other

alternatives that are reasonably available to the project. Our main concerns include:

adequacy and clarity of the radiological impacts and risk estimates. entrainment of fish and

shellfish at early life stages, impacts of foreseeable power uprates, and impacts to ground

water.

We have enclosed our comments and the U.S. EPA rating system summary. If you have any

questions or wish to discuss any aspect of the comments, please contact Anna Miller of my

staffat (312) 886-7060.

Sincerely,

Kenneth A. Westlake, Chief

NEPA Implementation Section

Office of Science, Ecosystems, and Communities

Enclosures

August 2005 A-47 NUREG-1437, Supplement 23
Appendix A

U.S. Environmental Protection Agency Comments on

Generic Environmental Impact Statement for License Renewal of Nuclear Plant,

Supplement 23: Point Beach Nuclear Plant Units I and 2, Draft Report,

NUREG-1437

PB-CD-2 1. Section 2.1.3, Cooling and Auxiliary Water Systems, page 2-4 to 2-6. There is no

description of the actual intake or outflow amounts from this system. We recommend

including this specific information or explaining the reasons for excluding it.

PB-CD-3 2. Section 2.27, Radiological Impacts, pages 2-32 through 2-34. The references to the

specific environmental standards need to be included (i.c., complete citations including

title of the rule or regulation, along with the basic standard for comparison). All

environmental standards that could be used for a comparison should be used, including

40 CFR 61 Radionuclide National Emission Standards for Hazardous Air Pollutants

values. This will assist the public in verifying values that are cited in the text and

evaluating the radiation values.

PB-CD-4 3. Section 3.0 EnvironmentalImpacts of Refirbishmcnt. page3-2, Table 3-1. Under the

section on Human Health, specific information supporting any assertions that this area

needs no further evaluation needs to be presented or more completely cited and

described.

PB-CD-S 4. Section 4.3, Radiological Impacts of Normal Operations, pages 4-27, 4-28, Table 4-5,

-and following paragraphs in the section. The draft supplemental environmental impact

statement (SEIS) cites the location of radiological exposure information in the GEIS, but

does not include specific values. The final SEIS should provide the specific exposure

values, in addition to the GElS citation. This will be clearer and assist the public in

understanding the project's impacts.

PB-CD-6 5. Section 4.8.3, Cumulative Radiological Impacts, page 4-49, Paragraph 1. Information or

procedures used to generate values to support the assertions in this section need to be

provided in a clearer manner to support the conclusions.

PB-CD-7 6. Section 5.2.2, Estimate of Risk, pages 5-5, 5-6. The draft SEIS stales:

'The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation

is approximately 3.59 x 10' per year. This CDF is based on the risk assessment for

internally initiated events. NMC did not include the contribution to risk from cxtemal

events wvithin the PBNP 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 2.0.'

We recommend evaluating and presenting risk estimates from both internal and external

events. In addition, given the draft SEIS statements referenced above, effects of external

events should be included in the risk decision considerations, as necessary, to get an

accurate portrayal of the risk of the licensing renewal. If the final SEIS does not

incorporate external cvents into risk calculations or risk decisions, it should provide a

rationale for using intcmally-initiated events only.

NUREG-1437, Supplement 23 A-48 August 2005

Il
Appendix A

PB-CD-8 7. Section 6.1, The Uranium Fuel Cycle, page -8, under On-Site Spent Fuel. We

recommend providing a site-specific evaluation of the volume of spent fuel expected to

be generated during the additional period of operation, along with more specific

information on site-specific circumstances that may impair or improve the risk values for

potential exposures to this spent fuel. In addition, the final SEIS should state whether

additional spent fuel storage capacity is already available or will need to be built in the

future. If new capacity will be constructed, we recommend the final SEIS discuss what

type of storage units are proposed, noting any differences (rom current operations.

PB-CD-9 8. Section 7.1. Decommissioning, pages 7-2,7-3, under Radiation Doses. Since the Generic

Environmental Impact Statement (GEIS) is based on a forty-year licensing period, an

extension of another twenty years would have an impact that needs to be quantified and

reported. This information should be included specifically in the final SEIS as part of the

risk that would be associated with the license extension. The specific methodology

needs to be provided and fully explained.

PB-CD-t0 9. Section 8.1, No-Action Alrernative, page 8-5, under Human Health. This section refers in

general terms to reductions in the amount of radioactive material; we recommend

including actual values, which will assist the public in comparing alternatives.

PB-CD-11 10. Section 8.2.1.1, Closed-Cycle Cooling System, page 8-17, under the bullet Uranium and

- thorium. Abetter comparison or quantification of the relative concentrations of the

uranium and thorium to the background levels need to be provided. As is, this

presentation is confusing.

PB-CD-12 I1. Section 8.2.1.1, Clased-Cycle CoolingSysrem, page 8-19, under Human Health. We

recommend the draft SEIS either cite specific dose estimates for this alternative or

provide estimates that use currently available data or that can be logically extrapolated

from currently available information. We further recommend evaluating any dose

estimates that fall in the risk range Or I o1 to I O' or greater for potential public health risk

impacts and noting specific doses that are subject to regulatory requirements. This

information would be useful to the public in comparing alternatives.

PB-CD-13 12. Section 8.2.3.1, Closed -Cycle Cooling System, page 8.40, under Waste. Waste impacts

need to be specified rather than merely referenced to provide a clearer understanding of

the risk determination made in this section of the document.

PB-CD-14 13. Section 82.3.1, Closed-Cycle Cooling Systcm, page 8-40, undcr Human Health.

Human-health impacts need to be specified rather than merely referenced to provide a

clearer understanding of the risk determination in this section of the document.

PB-CD-15 14. The U.S. EPA's new rules under Section 316(b) of the Clean Water Act (in 40 C.F.R. §

125) require Point Beach Nuclear Plant to reduce its entrainment or fish and shellfish in

early life stages. Although the draft SEIS identifies current measures already in place to

August 2005 A-49 NUREG-1437, Supplement 23
Appendix A

PB-CD-1S mitigate for entrainment (such as intake location and a high-frequency fish deterrent

system), it is not clear that these measures will satisfy the rule's requirements. We

recommend the final SETS not include the following statement: "The staff concludes that

the potential impacts of entrainiment of fish and shellfish in the early life stages into the

cooling water intake system are SMALL, and further mitigation measures are not

warranted:" This conclusion is premature pending the results of the study required by

the Wisconsin Department of Natural Resources (WDNR) to comply with the new

regulations. The WDNR will use the results of the study to determine whether other

measures are necessary and need to be reflected in the plant's next discharge permiL

Instead, the final SEIS could discuss how the current entrainment mitigation measures

may function as a compliance alternative under the rule and achieve the targeted

performance standard for the facility.

PB-CD-16 15. The final SEIS should discuss planned or potential power uprates at the Point Beach

Nuclear Plant and estimate resulting increases in radiological emissions, spent fuel, and

other emissions. Although U.S. NRC's regulations (10 C.F.R §. 51.53(c)(2)) state that an

applicant's environmental report need not discuss the demand for power, we consider

power uprates to be reasonably foreseeable actions that contribute to a cumulative

radiological impact, under 40 C.F.R § 1508.7, and therefore should be discussed in U.S.

NRC's final SEIS.

PB-CD-17 16. As part of its July 1, 2004 scoping comments, the U.S. EPA recommended the draft SEIS

describe site hydrogeology, on-site drinking water wells, drinking water quality, and

treatment of the drinking water. The U.S. EPA also recommended that NRC evaluate the

potential for ground water contamination under the license renewal period. especially

with regard to the abandoned settling pond. The draft SEIS responded to these

comments by stating that the water issues were found to be Category I issues (no

additional site-specific analysis required) during development of the Generic

Environmental Impact Statement (GEIS). It is not clear how this issue can be a Category

I issue, because it is site-specific; that is, it does not seem likely that other plants have

the same groundwater regime and configuration of drinking water wells and an

abandoned retention pond on site (see the first criteria for Category I determination).

Chapter 4.5 Groundwater Use and Oualitv states that no new and significant information

is found; however, the section does not provide information about groundwater at the

site. Without hydrological information or ground water quality information. the SEIS

does not successfully describe the impact of extended plant operation, including

management of the abandoned settling pond, on groundwatcr and drinking water.

Therefore, we recommend that the SEIS include an evaluation of ground water

conditions and potential impacts of extended plant operation as pan of the license

renewal SEIS for this site.

NUREG-1437, Supplement 23 A-50 August 2005
Appendix A

SUMMNLARY OF RATING DEFINITIONS AND FOLLOW UP ACTION'

Environmental Impact of the Action

LQ-LackofObiccioM

The EPA review has not identified any potential environmental impacts requiring substantive changes to the

proposaL The revcw may have disclosed opportunities for application of mitigation measures that could be

accomplished with no more thin minor changes to the proposal.

EC-Environnental Concerns

The EPA review has identified environmental impacts that should be avoided in order to fullyprotect the

environert Corrective measures tiny require changes to the preferred alternative or application of mitigation

meastoes that can reduce the environmental impacts. EPA vould like to work with the lead agency to reduce these

impacts.

EO-Fnvironrnental Obiections

The EPA review has identified significant environmnltal irmacts that mist be avoided in order to provide adequate

protection for the environment. Corrective measures may require substantial changes to the prefcrred alternative or

consideration of some other project alternative (including the no action alternative or a new alternative). EPA

intends to work with the kad agency to reduce these impacts.

EU-Envirw tallv Unsatisfactory

The EPA review has identifed adverse environmental impacts that are of suflicient rrnagnitude that they are

unsatisfactory from the standpoint of public health or welfare or environmental quality. EPAiuite sds to work with

the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected at the final EOS

sate, this proposal will be recommended for referral to the CEQ.

Adequacy of the Impact Statement

Catetorv I -Adequate

The EPA believes the draft EIS adequately sets forth the environmental impact(s) of the prefirred alterative and

those of the alternatives reasonably available to the project or action. No further analysis or data collecting is

necessary. but the reviewer rny suggest the addition of clarifying language or information.

Catetzorv 2-Insuffcicnt Information

Tbe dral EIS does not contin suffcient information for the EPA to fullyaassess the environmental impacts that

should be avoided in order to fully protect the environment, or the EPA reviewccr has identified new reasonably

available alternatives that are within the spectrum of aternatives analyzed in the draft EIS, which could reduce the

environmental impacts of the action. The identified additional information, data, analyses or discussion should be

included in the final EIS.

Catetorv 3-Mnadcouate

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the

action, or the EPA reviewer has identifiled new, reasonably available alternatives that are outside of the spectrun of

alternatives analyzed in the draft EIS. which should be analyzed in order to reduce the potentially significant

environmental impacts. EPA believes that the identifed additional information data analyses, or discussions are of

such a rmagnitudc that they should have full public review at a draft stage. EPA does not believe that the drall EIS is

adequate for the purposes of the KEPA and'or Section 309 review, and thus should be formally revised and made

availabk for public comment in a supplemental or rised draft EIS. On the basis of the potential significant inpacts

involved, this proposal could be a candidate for referral to the CEQ.

*Fsm EPA NtMil 1643 Polity A Proedduns f$i the Siriew of Lk Federal Aaioms bvparv tsr Ernvomc

August 2005 A-51 NUREG-1437, Supplement 23
Appendix A

United States Department of the Interior

OFFICE OF THE SECRETARY

Orice or Envronmental Portcy and Compliance

Custom House. Room 244

200 Chestnul Strcet

Phibdelphia. Pennsylrania 19106-2904 RQC'cI

April 7,2005

TAKE PRIDE

,"AM ERICA

a-\~ a le

,I -0 5 s

ER 05/84

Chief, Rules Review and Directives Branch

US. Nuclear Regulatory Commission

Mail Stop T6-D59

Washington, DC 20555-0001

70 I /a

The U.S. Departmnent of the Interior (Department) has reviewed the Generic Environmental

Impact Statement (EIS) for License Renewal of Nuclear Plants (NUREG-1437) and Draft

Supplement 23 for license Renewal of the Point Beach Nuclear Plant Unils No. I

and 2, Manitowoc County, Wisconsin. The plant is owned by Wisconsin Electric Power

Company and operated by Nuclear Management Company LLC.

The proposed action would renew the operating license for the plant for a period of 20 years but

does not involve any major construction, refurbishment, or physical alteration of the project area.

PB-CE-I The Generic EIS and Draft Supplement 23 adequately discuss most of the impacts of continued

operations of the plant on fish and wildlife resources, as well as species protected by the

Endangered Species Act.

In a letter dated November 22,2004, the Nuclear Regulatory Commission (Commission)

requested the concurrence of the US. Fish and Wildlife Service (Service) with the Commission's

determination ofeffects ofthe proposed license renewal on four federally listed threatened and

endangered species documented as occurring in Manitowoc County, as described in the

Commission's Biological Assessment (BA) dated November 2004. The letter and BA are

included in Appendix E of Draft Supplement 23. Byletterdated January31, 2005, the Service

concurred with the determinations for the bald eagle, Pitcher's thistle, and dwarf lake iris.

PB-CE-2 The fourth species considered in the BA is the piping plover. Although no piping plovers have

been observed on the project site, there is designated critical habitat for the plover located to the

south of the plant and there is also suitable habitat for the plover on the plant grounds. T1ie Great

Lakes piping plover population is rapidly expanding, and there is some probability that plovers

may attempt to use the beaches on the plant property in the near future. Te Service and the

Commission are continuing informal consultation concerning the specifics ofannual surveys the

applicant has agreed to conduct for plover use of the plant grounds over the life of the license

renewal period. The Department appreciates the willingness of the applicant to cooperate with

the agencies in protection of the plover.

$25/ 64~eg- =- 6. -Aee

@k',F)

NUREG-1437, Supplement 23 A-52 August 2005
Appendix A

.,.

PB-CE-3 The Draft Supplement 23 discusses the entrainment and impingement orbirds, fish, and shellfish

as a result of the continued opertioni orthe cooling water intake sysiem and indicates that

entrainment and impingement of fish and shellfish will also be adidressed during renewal of the

plant's National Pollution Discharge Elimnination System permiL The permit renewal is under

the authority of the Wisconsin Department of Natural Resources (DNR) and will be subject to

the Environmental Protection Agencys recentlyjublished316(b) Phase 11 regulations. The

Service will coordinate with the Wisconsin DNR on the review of the data related to renewal of

the permit.

PB-CE-4 With regard to entrainment and rmortality of birds, the Draft Supplement 23 correctly states that

the applicant has been reporting bird entrainment and mortality to the Service on an annual basis.

While the intent of the previous modification of the intake structure was to eliminate any firther

mortality of cormorants (see page 2-27). the reports from June 1, 2001, to December31,2003,

indicate bird entrainment and mortality has continued (see page. 4-18). Service personnel visited

the site in 2004 and viewed bird carcasses that had undergone appreciable decomposition after

intake entrainment. The carcasses were tentatively identified as those ofgrebes and other

waterfowL The Service will continue to work with the applicant in addressing this issue.

The Department has a continuing interest in working with the Commission and the applicant to

ensure that impacts to resources of concern to the Department are adequately addressed. For

continued consultation and coordination on fish and wildlife matters and threatened and

endangered species, please contact the Field Supervisor, U.S. Fish and Wildlife Service,

2661 Scott Tower Drive, New Franken, Wisconsin 54229; Telephone: (920) 866-3650;

Fax: (920) 866-1710.

We appreciate the opportunity to provide these comments.

Sincerely,

Michael T. Chczic

Regional Environrnental Officer

August 2005 A-53 NUREG-1437, Supplement 23
Appendix B

Contributors to the Supplement
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 statement was

prepared by members of the Office of Nuclear Reactor Regulation with assistance from other

NRC organizations, the Los Alamos National Laboratory,- Argonne National Laboratory,

Lawrence Livermore National Laboratory, Energy Research Incorporated, and the Information

Systems Laboratory.

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Stacey Imboden Nuclear Reactor Regulation - Project Manager

Richard Emch Nuclear Reactor Regulation Project Management, Radiological

Safety

James Wilson Nuclear Reactor Regulation Aquatic and Terrestrial Ecology

Harriet Nash Nuclear Reactor Regulation Aquatic Ecology

Cristina Guerrero Nuclear Reactor Regulation General Scientist

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation

Alternatives

Andrew Kugler Nuclear Reactor Regulation Section Chief

Barry Zalcman Nuclear Reactor Regulation Technical Monitor

Nina Bamett Nuclear Reactor Regulation Administrative Support

Los ALAMOS NATIONAL LABORATORY(a)

Paul Schumann Task Leader

Allyn Pratt Deputy Task Leader

Ted Doerr Alternatives

Lars Soholt Terrestrial Ecology

Sam Loftin Terrestrial Ecology

Cheryl Olson Radiation Protection, Human Health

Peggy Powers Cultural Resources

Craig Carmer Technical Editor

James Liljenwall Technical Editor

Jolene Catron Compositor

Sherrye Lovato Administrative Support

Janelle Vigil Administrative Support

August 2005 B-1 NUREG-1437, Supplement 23
Appendix B

Name Affiliation Function or Expertise

ARGONNE NATnONAL LABORATORYb)

Dave Miller Hydrology and Water Quality

Bill Vinikour Aquatic Ecology

LAWRENCE LIVERMORE NATIONAL LABORATORY(c)

Warren Rued Task Leader, Land Use

Amit Basu Water Resources, Water Use, Waste

Treatment

Alan Lamont Socioeconomics

Bill Hoppes Aquatic Ecology

Dave Armstrong Meteorology, Air Quality

PACIF-C NORTHWEST NATnONAL LABORATORy(d)

Fred Leverenz Severe Accident Mitigation

Alternatives

Bruce Schmitt Severe Accident Mitigation

Alternatives

Steve Short Severe Accident Mitigation

Alternatives

(a) Los Alamos National Laboratory is operated for the U.S. Department of Energy by the University of

California.

(b) Argonne National Laboratory is operated for the U.S. Department of Energy by the University of Chicago.

(c) Lawrence Livermore National Laboratory is operated for the U.S. Department of Energy by the University of

California.

(d) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by the Battelle Memorial

Institute.

NUREG-1437, Supplement 23 B-2 August 2005

Il
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Nuclear Management Company, LLC's

Application for License Renewal of

Point Beach Nuclear Plant Units 1 and 2
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Nuclear Management Company, LLC's

Application for License Renewal of

Point Beach Nuclear Plant Units 1 and 2

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and Nuclear Management Company, LLC (NMC) and other

correspondence related to the NRC staff's environmental review, under Title 10 of the Code of -

Federal Regulations Part 51, of NMC's application for renewal of the Point Beach Nuclear Plant

Units 1 and 2 (PBNP) operating licenses. All documents, with the exception of those containing

proprietary information, have been placed in the Commission's Public Document Room, at One

White Flint North, 11555 Rockville Pike (first floor), Rockville, Maryland, and are available

electronically from the Public Electronic Reading Room found on the Internet at the following

web address: http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to

the NRC's Agencywide Document Access and Management System (ADAMS), which provides

text and image files of NRC's public documents in the publicly available records (PARS)

component of ADAMS. The ADAMS accession numbers for each document are included

below.

December 22, 2003 Letter from Mr. A. J. Cayia, NMC, to Mr. J. Michael Blaska, Wisconsin

Department of Administration, regarding Federal Consistency

Certification for license renewal of PBNP (Accession No. ML041210524).

January 6, 2004 Letter from Mr. Richard Dexter, Wisconsin Historical Society, to Mr. A. J.

Cayia, NMC, regarding historic and archaeological resources in the area

under review for the license renewal of PBNP (Accession No.

ML041470098).

February 25, 2004 Point Beach Units 1 and 2, Applicant's Environmental Report-Operating

License Renewa! Stage (Accession No. ML040580025).

February 26, 2004 Letter from Ms. Janet M. Smith, U.S. Fish and Wildlife Service, to Mr.

A. J. Cayia, NMC, regarding the environmental impact of license renewal

of PBNP (Accession No. ML040610963).

March 1, 2004 NRC press release No. 04-029, UNRC Announces Availability of License

Renewal Application for Point Beach Nuclear Power PIant"

(Accession No. ML040611048).

August 2005 C-1 NUREG-1437, Supplement 23
Appendix C

March 2, 2004

March 2, 2004

March 8, 2004

March 11, 2004

April 7, 2004

April 7,2004

April 13,2004

April 16, 2004

April 21, 2004

1 April 26,2004

Letter from Mr. Gary Van Middlesworth, NMC, to Mr. Travis Olson,

Wisconsin Department of Administration, regarding Federal Consistency

Certification for license renewal of PBNP (Accession No. ML041420323).

Letter from NRC to Mr. Gary Van Middlesworth, NMC, regarding the

receipt and availability of the license renewal application for PBNP

(Accession No. ML040640628).

Federal Register Notice of Receipt and Availability of Application for

Renewal of Point Beach Nuclear Plant, Units 1 and 2; Facility Operating

License Nos. DPR-24 and DPR-27 for an Additional 20-Year Period

(69 FR 10765).

Letter from Mr. Sherman Banker, Wisconsin Historical Society, to

Mr. Roger Newtown, NMC, regarding the application for license renewal

of PBNP (Accession No. ML041470090).

Letter from NRC to Mr. Gary Van Middlesworth, NMC, regarding

acceptance of the application for license renewal of PBNP and

opportunity for a hearing (Accession No. ML040980219).

Letter from NRC to Mr. Nick Niederlander, Lester Public Library,

regarding the maintenance of reference material for the PBNP license

renewal review (Accession No. ML041050642).

Federal Register Notice of Acceptance for Docketing of the Application

and Notice of Opportunity for Hearing Regarding the Renewal of Facility

Operating License Nos. DPR-24 and DPR-27 for an Additional 20-Year

Period (69 FR 19559).

NRC press release announcing opportunity for hearing on application for

license renewal of PBNP (Accession No. ML041070354).

Summary of telecommunication with NMC to discuss environmental

review of license renewal application and schedule

(Accession No. ML041140404).

Letter from Mr. Kris McKinney, We Energies, to NRC providing

documents requested during April 8, 2004, conference call

(Accession No. ML041250592).

NUREG-1437, Supplement 23 C-2 August 2005

I I
Appendix C -

April 30, 2004

May 5, 2004

May 5, 2004

May 5,2004

May 5, 2004

May 12, 2004

May 13, 2004

May 14, 2004

May 14, 2004

E-mail from Mr. Kris McKinney, We Energies, to NRC providing follow-up

to action items discussed in April 8, 2004, conference call

(Accession No. ML041240446).

Letter from NRC to Mr. Richard Dexter, Wisconsin Historical Society,

inviting participation in the environmental scoping process for license

renewal of PBNP and requesting a determination of effects of license

renewal on historic properties in accordance with the National Historic

Preservation Act (Accession No. ML041270553).

Letter from NRC to Mr. Don Klima, Advisory Council on Historic

Preservation, inviting comments on the effects of license renewal of

PBNP on historic properties in accordance with the National Historic

Preservation Act (Accession No. ML041270559).

Letter from NRC to Ms.-Janet Smith, U.S. Fish and Wildlife Service,

requesting a list of protected species within the area under evaluation for

license renewal of PBNP (Accession No. ML041280306).

Letter from NRC to Mr. Gary Van Middlesworth, NMC, forwarding the

Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process for the license renewal of Point Beach -Nuclear

Plant (Accession No. ML041280448).

Letter from NRC to Ms. Patricia A. Kurkul, National Oceanic and

Atmospheric Administration Fisheries, requesting a list of protected

species within the area under evaluation for license renewal of PBNP

(Accession No. ML041330494).

Federal Register Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process regarding the application for

license renewal of Point Beach Nuclear Plant (69 FR 26624).

Letter from NRC to Ms. Lisa Bresette, Red Cliff Band of Lake Superior

Chippewas, inviting participation in the environmental scoping process for

the license renewal of PBNP (Accession No. ML041400252).

Letter from NRC to Mr. Robert Chicks, Stockbridge-Munsee Community

of Wisconsin, inviting participation in the environmental scoping process

for the license renewal of PBNP (Accession No. ML041400405).

I

August 2005 C-3 NUREG-1437, Supplement 23
Appendix C

May 14, 2004

May 14, 2004

May 14, 2004

May 14,2004

May 14, 2004

May 14, 2004

May 14, 2004

May 14, 2004

May 14, 2004

Letter from NRC to Ms. Cristina Danforth, Oneida Tribe of Indians of

Wisconsin, inviting participation in the environmental scoping process for

the license renewal of PBNP (Accession No. ML041410555).

Letter from NRC to Ms. Joan Delabreau, Menominee Indian Tribe of

Wisconsin, inviting participation in the environmental scoping process for

the license renewal of PBNP (Accession No. ML041410534).

Letter from NRC to Mr. Ray DePerry, Red Cliff Band of Lake Superior

Chippewa Indians of Wisconsin, inviting participation in the environmental

scoping process for the license renewal of PBNP

(Accession No. ML041410377).

Letter from NRC to Mr. Gus Frank, Forest County Potawatomi Indian

Community, inviting participation in the environmental scoping process

for the license renewal of PBNP (Accession No. ML041410240).

Letter from NRC to Mr. David Grignon, Menominee Indian Tribe of

Wisconsin, inviting participation in the environmental scoping process for

the license renewal of PBNP (Accession No. ML041400392).

Letter from NRC to Ms. Kelly Jackson, Lac du Flambeau Band of Lake

Superior Chippewa Indians, inviting participation in the environmental

scoping process for the license renewal of PBNP

(Accession No. ML041410513).

Letter from NRC to Mr. George Lewis, Ho-Chunk Nation of Wisconsin,

inviting participation in the environmental scoping process for the license

renewal of PBNP (Accession No. ML041400343).

Letter from NRC to Mr. Donald Moore, Bad River Band of Lake Superior

Chippewa Indians, inviting participation in the environmental scoping

process for the license renewal of PBNP (Accession No. ML041400150).

Letter from NRC to Mr. Jerry Smith, Lac Courte Oreilles Band of Lake

Superior Chippewa Indians of Wisconsin, inviting participation in the

environmental scoping process for the license renewal of PBNP

(Accession No. ML041410206).

NUREG-1437, Supplement 23 C-4 August 2005

Ir
Appendix C

May 14, 2004

May 14, 2004

May 14, 2004

May 17, 2004

May 17, 2004

May 18, 2004

May 21, 2004

Letter from NRC to Mr. Henry St.-'Germaine, Lac du Flambeau Band of

Lake Superior Chippewa Indians of Wisconsin, inviting participation in the

environmental scoping process for the license renewal of PBNP

(Accession No. ML04141 0068).

Letter from NRC to Mr. Louis Taylor, Lac Courte Oreilles Band of Lake

Superior Chippewa Indians of Wisconsin, inviting participation in the

environmental scoping process for the license renewal of PBNP

(Accession No. ML041410352).

Letter from NRC to Ms. Corina Williams, Oneida Nation of Wisconsin,

inviting participation in the environmental scoping process for the license

renewal of PBNP (Accession No. ML041410094).

Letter from NRC to Mr. David Merrill, St. Croix Chippewa Indians of

Wisconsin, inviting participation in the environmental scoping process for

the license renewal of PBNP (Accession No. ML041410612).

Letter from NRC to Ms. Sandra Rachal, Sokaogon Chippewa (Mole Lake)

Community of Wisconsin, inviting participation in the environmental

scoping process for the license renewal of PBNP

(Accession No. ML041410580).

Letter from Mr. Gary Van Middlesworth, NMC, to Ms. Janet M. Smith,

U.S. Fish and Wildlife Service, responding to concerns raised in

February 26, 2004 letter (Accession No. ML041530208).

Letter from NRC to Ms. Cassandra Dixon inviting participation in the

environmental scoping process for the license renewal of PBNP

(Accession No. ML041450240).

May21, 2004 NRC meeting notice announcing public meeting in Mishicot, Wisconsin,

on June 15, 2004, to discuss the environmental scoping process for the

application for the license renewal of PBNP

- - (Accession No. ML041420535).

2004 Letter from Mr. Sherman Banker, Wisconsin Historical Society, to NRC

regarding the application for license renewal of PBNP

(Accession No. ML041600062).

May 25,

August 2005 - C-5- NUREG-1437, Supplement 23
Appendix C

May 26, 2004

June 1, 2004

June 1, 2004

June 1, 2004

June 2, 2004

June 2, 2004

June 9, 2004

June 10, 2004

June 10, 2004

June 14, 2004

Letter from Mr. John E. Busby, Miller Compressing Company, to NRC

expressing support for license renewal of PBNP

(Accession No. ML041600105).

Letter from Ms. Kelly Jackson, Lac du Flambeau Band of Lake Superior

Chippewa Indians, to NRC expressing no concerns with impacts to

historic properties from the proposed license renewal of PBNP

(Accession No. ML041620343).

Letter from NRC to Mr. John A. Barrett, Jr., Citizen Potawatomi Nation,

inviting participation in the environmental scoping process for the license

renewal of PBNP (Accession No. ML041540192).

Letter from NRC to Mr. Zachariah Pahmahmie, Prairie Band Potawatomi

Tribal Council, inviting participation in the environmental scoping process

for the license renewal of PBNP (Accession No. ML041540246).

Letter from Mr. Robert Domrois, Newark Paperboard Mills, to NRC

expressing support for license renewal of PBNP

(Accession No. ML041620340).

Letter from NRC to Mr. Kenneth Meshiguad, Hannahville Indian

Community, inviting participation in the environmental scoping process

for the license renewal of PBNP (Accession No. ML041540263).

Letter from Mr. Mark R. Honadel, Wisconsin State Assembly, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041750351).

Letter from Mr. John A. Mellowes, Charter Manufacturing Company, to

NRC providing scoping comments regarding the license renewal review

for PBNP (Accession No. ML041750366).

Letter from Mr. Zach Pahmahmie, Prairie Band Potawatomi Nation, to

NRC expressing no concerns with impacts to historic properties from the

proposed license renewal of PBNP (Accession No. ML041890189).

E-mail from Mr. Bob Reynolds, ORBIS Corporation, to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML041750358).

NUREG-1437, Supplement 23 C-6 August 2005

Il
Appendix C

June 14, 2004 E-mail from Mr. Dale Scherbert, Community Memorial Hospital, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041750356).

June 14,2004 Letter from Mr. David J. Jenkins; Wisconsin Federation of Cooperatives,

to NRC providing scoping comments regarding the license renewal

review for PBNP (Accession No. ML041750369).

June 14, 2004 Letter from Mr. Richard W. Wanta, Wisconsin Underground Contractors'

Association, Inc., to NRC providing scoping comments regarding the

license renewal review for PBNP (Accession No. ML041750367).

June 15, 2004 E-mail from C. W. Fay to NRC providing scoping comments regarding the

license renewal review for PBNP (Accession No. ML041750353).

June 15, 2004 E-mail from D. H. Tredwell to NRC providing scoping comments

regarding the license renewal review for PBNP

(Accession No. ML041750352).

June 15, 2004 Letter from Mr. Kenneth J. Petersen, Manitowoc County Sheriff's

Department, to NRC providing scoping comments regarding the license

renewal review for PBNP (Accession No. ML041750365).

June 16, 2004 E-mail from Mr. Richard Wagner, Trega Foods, to NRC providing scoping

comments regarding the license renewal review for PBNP

(Accession No. ML041750364).

June 17, 2004 E-mail from Ms. Cheryl Brocher to NRC providing scoping comments

regarding the license renewal review for PBNP

(Accession No. ML041750361).

June 17, 2004 E-mail from Ms. Kathryn L. Smith to NRC providing scoping comments.

regarding the license renewal review for PBNP

(Accession No. ML041750360).

June 21, 2004 - E-mail from Mr. Chad E. Cordle, Cellu Tissue Neenah, to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML041830247). - -

August 2005 C-7 NUREG-1437, Supplement 23
Appendix C

June 21, 2004

June 21, 2004

June 25, 2004

July 1,2004

July 1, 2004

July 1, 2004

July 1, 2004

July 1, 2004

July 2, 2004

July 2, 2004

Letter from Mr. Don Markwardt, Manitowoc County Board of Supervisors,

to NRC providing scoping comments regarding the license renewal

review for PBNP (Accession No. ML042150282).

Letter from Mr. William J. Welch, Fox Cities Chamber of Commerce and

Industry, to NRC providing scoping comments regarding the license

renewal review for PBNP (Accession No. ML041830250).

Letter from NRC to Mr. Mitchell "Mickey" J. Maricque regarding hearing

request for the license renewal review for PBNP

(Accession No. ML041810651).

Letter from Dr. John G. Gonis, Dental Associates, Ltd., to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML042170119).

Letter from Mr. Donald Kaye to NRC providing scoping comments

regarding the license renewal review for PBNP

(Accession No. ML041970654).

Letter from Mr. Carl Otter to NRC providing scoping comments regarding

the license renewal review for PBNP (Accession No. ML042170117).

Letter from Ms. Carol Roessler, Wisconsin State Senator, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML042170118).

Letter from Mr. Kenneth A. Westlake, U.S. Environmental Protection

Agency, to NRC providing scoping comments regarding the license

renewal review for PBNP (Accession No. ML041910394).

E-mail from Mr. Steve Bongers, Outokumpu Copper Valleycast, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041940367).

Letter from Mr. Steve Bongers, Outokumpu Copper Valleycast, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041970658).

NUREG-1437, Supplement 23 C-8 August 2005

II
Appendix C

July 2, 2004

July 2, 2004

July 5, 2004

July 6, 2004

July 7, 2004

July 7, 2004

July 7, 2004

July 8, 2004

July 8, 2004

July 12, 2004

Letter from Mr. John H. Meinke, Neenah Technical Center, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041970655).

Letter from NRC to Mr. Dennis L. Koehl, NMC, forwarding request for

additional information regarding severe accident mitigation alternatives

for PBNP (Accession No. ML041890271).

Letter from Mr. Orville Krueger to NRC providing scoping comments

regarding the license renewal review for PBNP

(Accession No. ML041970650).

Letter from Mr. Allen J. Prochnow, Concordia University, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML042010181).

E-mail from Mr. John H. Goetsch to NRC providing scoping comments

regarding the license renewal review for PBNP

(Accession No. ML041940378).

Letter from Mr. Bob DeKoch,-The Boldt Company, to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML041980013).

Letter from Mr. Joseph H. Pomeroy, Mercury Marine, to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML041980021).

Letter from NRC to Mr. James E. Knorr, NMC, announcing project

manager change for the license renewal environmental review for PBNP

(Accession No. ML041950081).

Summary of Public Scoping Meetings To Support Review of PBNP

License Renewal Application (Accession No. ML041960121).

Letter from Mr. George P. Brown, Humana-Inc., to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML042170114).

August 2005 C-9 NUREG-1437, Supplement 23
Appendix C

July 12, 2004

July 13, 2004

July 13,2004

July 13, 2004

July 13, 2004

July 14, 2004

July 14, 2004

July 16, 2004

July 19, 2004

July 23, 2004

E-mail from Mr. Earl Gustafson, Wisconsin Paper Council, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041980016).

E-mail from Mr. James J. Graf, City of Sheboygan Alderman, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML041980024).

E-mail from Mr. Hermann Viets, Milwaukee School of Engineering, to

NRC providing scoping comments regarding the license renewal review

for PBNP (Accession No. ML041980026).

Letter from Mr. Jeffrey S. Mason, BayCare Health Systems, LLC, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML042170121).

Letter from Mr. Edward J. Zore, Northwestern Mutual, to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML042170120).

Letter from Mr. Joe Leibham, Wisconsin State Senator, to NRC providing

scoping comments regarding the license renewal review for PBNP

(Accession No. ML042170106).

E-mail from Mr. R. J. Pirlot, Wisconsin Manufacturers and Commerce, to

NRC providing scoping comments regarding the license renewal review

for PBNP (Accession No. ML042010179).

Letter from Mr. Daniel J. Sutheimer, Pierce Manufacturing, to NRC

providing scoping comments regarding the license renewal review for

PBNP (Accession No. ML042170122).

Response to open items from June 16-17, 2004, NRC environmental

audit to support license renewal of PBNP (Accession No. ML042020469).

Summary of site audit to support review of license renewal application for

PBNP (Accession No. ML042080516).

NUREG-1 437, Supplement 23 C-10 August 2005

I l
Appendix C

August 5, 2004 Letter from Ms. Janet M. Smith, U.S. Fish and Wildlife Service, to NRC

responding to NRC request for a list of protected species within the area

under evaluation for license renewal of PBNP

(Accession No. ML042290328).

August 20, 2004 Note to file docketing email pertaining to environmental review for PBNP

(Accession No. ML042330285).

August 31, 2004 Letter from Mr. Dennis L. Koehl, NMC, transmitting responses to

July 2, 2004, request for additional information regarding severe accident

mitigation alternatives for PBNP (Accession No. ML042530218).

September 3, 2004 Letter from NRC to Mr. Dennis L. Koehl, NMC, transmitting environmental

scoping summary report associated with the staff's review of the PBNP

(Accession No. ML042510283).

September 8, 2004 Letter from Mr. Lars Bengtsson, Stora Enso's North American Division, to

NRC providing scoping comments regarding the license renewal review

for PBNP (Accession No. ML042750132)

September 8, 2004 Letter from Mr. Thomas G. Scharff, Consolidated Water Power

Company, to NRC providing scoping comments regarding the license

renewal review for PBNP (Accession No. ML042750138)

October 12, 2004 Note to file docketing email pertaining to comments to request-foradditional-information responses for PBNP

(Accession No. ML042870219).

October 15, 2004 E-mail from Mr. Kris McKinney, We Energies, transmitting piping plover

habitat survey on PBNP site (Accession No. ML043150318).

October 20, 2004 Letter from NRC to Mr. Dennis L. Koehl, NMC, stating that the license

renewal schedule may be impacted by the delay in responses to the

October 12, 2004, e-mail (Accession No. ML042940650).

October 28, 2004 Summary of conference call with NMC to discuss responses to the

severe accident mitigation alternatives (SAMAs) requests for additional

information (Accession No. ML043020631).- -

August 2005 C-1 1 NUREG-1437, Supplement 23
Appendix C

November 5, 2004

November 22, 2004

November 22, 2004

December 6, 2004

December 23, 2004

January 13, 2005

January 13, 2005

January 26, 2005

January 31, 2005

NUREG-1437, Supplem

Fax from Mr. Kris McKinney, We Energies, to Stacey Imboden, NRC

stating that piping plover habitat survey recommendations in the

October 15, 2004 e-mail will be implemented.

(Accession No. ML043150311).

Letter from Mr. Dennis L. Koehl, NMC, to the NRC, providing responses

to the additional SAMA RAls in the October 12, 2004 e-mail

(Accession No. ML043360138).

Letter from NRC to Ms. Janet Smith, U.S. Fish and Wildlife Service,

requesting concurrence on biological assessment

(Accession No. ML043280682).

Note To File: Docketing of Material in Support of the PBNP

Environmental Review and License Renewal Application

(Accession No. ML043420094).

Email from Ms. Leakhena Au, U.S. Fish and Wildlife Service, regarding

biological assessment (Accession No. ML043640231).

Letter from NRC to Mr. Dennis L. Koehl, NMC, forwarding Notice of

Availability of the Draft Plant-Specific Supplement 23 to the Generic

Environmental Impact Statement Regarding License Renewal for Point

Beach Nuclear Plant, Units 1 and 2 (Accession No. ML050180307).

Letter from NRC to U.S. Environmental Protection Agency transmitting

Draft Supplement 23 to the Generic Environmental Impact Statement

Regarding License Renewal for Point Beach Nuclear Plant, Units 1 and 2

(Accession No. ML050180447).

Federal Register Notice of Availability of the Draft Supplement 23 to the

Generic Environmental Impact Statement and Public Meeting for the

License Renewal of Point Beach Nuclear Plant, Units 1 and 2

(70 FR 3744).

Letter from Ms. Janet Smith, U.S. Fish and Wildlife Service, to NRC

regarding November 22, 2004 request for concurrence on biological

assessment (Accession No. ML050480192).

ent 23 C-12 August 2005

Il
Appendix C

February 10, 2

February 17, 2

February 24, 2

February 26, 2

March 7, 2005

March 12, 200

March 15, 200

March 31, 200

April 6, 2005

.005

!005

NRC meeting notice announcing public meeting in Mishicot, Wisconsin

on March 3, 2005, to discuss the Draft Supplemental Environmental

Impact Statement for license renewal of Point Beach Nuclear Plant

(Accession No. ML050410118).

Letter from Dr. Noel J. Cutright, We Energies, to Ms. Janet Smith,

U.S. Fish and Wildlife Service, regarding framework for monitoring

Piping Plovers (Accession No. ML050540119).

.005 NRC Press Release No. 111-05-006, "NRC Seeks Public Input on

Environmental Impact Statement For Proposed Point Beach Nuclear

Plant License Renewal" (Accession No. ML050550457).

!005 E-mail from Mr. Daniel Hahn to NRC providing comments regarding the

license renewal review for Point Beach Nuclear Plant

(Accession No. ML050700105).

Letter from Ms. Janet Smith, U.S. Fish and Wildlife Service, to

Dr. Noel J. Cutright, We Energies, suggesting revision to Piping Plover

monitoring framework (Accession No. ML050760398).

5 Comment letter from Mr. J. Kevin McCoy, to NRC providing comments

regarding the license renewal review for Point Beach Nuclear Plant

(Accession No. ML050900218).

5 Letter from Dr. Noel J. Cutright, We Energies, to Ms. Janet Smith,

U.S. Fish and Wildlife Service, updating Piping Plover monitoring

framework (Accession No. ML050760463).

5 Summary of Public Draft Supplemental Environmental Impact Statement

'Meeting to Support Review of the Point Beach Nuclear Plant, Units 1

and 2, License Renewal Application

(Package Accession No. ML050920006).

Docketing of Point Beach Nuclear Plant Proposal for Information

Collection regarding cooling water intake structures, and revised

schedule for impingement and entrainment sampling

(Package Accession No. ML050950139).

August 2005 C-13 NUREG-1437, Supplement 23
Appendix C

April 7, 2005

April 11,2005

April 13, 2005

April 21,2005

May 5, 2005

May 25, 2005

May 25, 2005

June 14, 2005

Letter from Mr. Michael T. Chezik, Department of Interior, transmitting

comments on Draft Supplemental Environmental Impact Statement

regarding Point Beach Nuclear Plant, Units 1 and 2

(Accession No. ML051050351).

Letter from Mr. Dennis L. Koehl, NMC, transmitting comments on Draft

Supplemental Environmental Impact Statement regarding Point Beach

Nuclear Plant, Units 1 and 2 (Accession No. ML051090335).

Letter from Mr. Kenneth A. Westlake, EPA, transmitting comments on

Draft Supplemental Environmental Impact Statement regarding Point

Beach Nuclear Plant, Units 1 and 2 (Accession No. ML051160259).

Letter from NRC to Ms. Janet Smith, U.S. Fish and Wildlife Service,

requesting concurrence on supplemented biological assessment

(Accession No. ML051110687).

Letter from Ms. Janet Smith, U.S. Fish and Wildlife Service, to NRC

providing concurrence with supplemented biological assessment

(Accession No. ML051330355).

E-mail from Mr. Paul Luebke, WDNR, providing information regarding

settling pond onsite at Point Beach Nuclear Plant

(Accession No. ML051470092).

Docketing of letter dated April 30, 2002, from Mr. Paul Luebke, WDNR, to

Ms. Elizabeth Hellman, Wisconsin Energy Corporation, approving

abandonment plan for settling pond (Accession No. ML051470098).

E-mail from Mr. Jim Knorr, NMC, providing information regarding

potentially cost-beneficial SAMA (Accession No. ML051720047).

NUREG-1437, Supplement 23 C-14 August 2005
Appendix D

Organizations Contacted
Appendix D

Organizations Contacted

During the course of the staff's independent review of environmental impacts from operations

during the renewal term, the following Federal, State, regional, local, and Native American tribal

agencies were contacted:

Bad River Band of Lake Superior Chippewa Indians, Odanah, Wisconsin

Bay-Lake Regional Planning Commission, Green Bay, Wisconsin

City Manager, Greg Buckley, Two Rivers, Wisconsin

Economic Development Director, Dan Pawlitzke, -Two Rivers, Wisconsin

Fire Chief, Mike Pohlman, Two Rivers, Wisconsin

Forest County Potawatomi Indian Community, Crandon, Wisconsin

Hannahville Indian Community, Wilson, Michigan

Ho-Chunk Nation of Wisconsin, Black River Falls, Wisconsin

Lac Courte Oreilles Band of Lake Superior Chippewa Indians of Wisconsin, Hayward,

Wisconsin

Lac du Flambeau Band of Lake Superior Chippewa Indians of Wisconsin, Lac du Flambeau,

Wisconsin

Manitowoc-Two Rivers Chamber of Commerce, Manitowoc, Wisconsin

Manitowoc County Department of Parks and Planning, Manitowoc, Wisconsin

Menominee Indian Tribe of Wisconsin, Keshena, Wisconsin

Mishicot Area Growth and Improvement Committee, Mishicot, Wisconsin

Mishicot School District, Office of the Superintendent, Mishicot, Wisconsin

Oneida Nation of Wisconsin, Oneida, Wisconsin

August 2005 D-1 NUREG-1437, Supplement 23
Appendix D

Prairie Band Potawatomi Tribal Council, Mayetta, Kansas

Red Cliff Band of Lake Superior Chippewa Indians of Wisconsin, Bayfield, Wisconsin

Sokaogon Chippewa (Mole Lake) Community of Wisconsin, Crandon, Wisconsin

St. Croix Chippewa Indians of Wisconsin, Hertel, Wisconsin

Stockbridge-Munsee Community of Wisconsin, Bowler, Wisconsin

U.S. Environmental Protection Agency, Region 5, Chicago, Illinois

U.S. Fish and Wildlife Service, Green Bay Ecological Services Field Office, New Franken,

Wisconsin

Wisconsin Department of Health and Family Services, Madison, Wisconsin

Wisconsin Department of Natural Resources, Bureau of Watershed Management, Madison,

Wisconsin

Wisconsin Department of Natural Resources (Fisheries), Madison, Wisconsin

Wisconsin Department of Natural Resources (Wildlife), Madison, Wisconsin

Wisconsin Department of Natural Resources, Mishicot Field Office, Mishicot, Wisconsin

Wisconsin State Historic Preservation Office, Madison, Wisconsin

NUREG-1437, Supplement 23 D-2 August 2005

lr
Appendix E

Nuclear Management Company, LLC's Compliance Status

and Consultation Correspondence
Appendix E

Nuclear Management Company, LLC's Compliance Status

and Consultation Correspondence

Correspondence issued and received during the process of evaluation of the application for

renewal of the operating licenses for Point Beach Nuclear Plant Units 1 and 2 (PBNP) is

identified in Table E-1. Copies of the correspondence are included at the end of this appendix.

The licenses, permits, consultations, and other approvals obtained from Federal, State,

regional, and local authorities for PBNP are listed in Table E-2.

Table E-1. Consultation Correspondence

-

Source

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

Wisconsin Historical Society

(S. Banker)

U.S. Fish and Wildlife Service

(J. Smith)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

U.S. Fish and Wildlife Service

(J. Smith)

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

U.S. Fish and Wildlife Service

(J. Smith)

Wisconsin Department of Natural

Resources (P. Luebke)

Recipient

Advisory Council on Historic

Preservation (D. Klima)

U.S. Fish and Wildlife Service

(J. Smith)

Wisconsin Historical Society

(R. Dexter)

National Oceanographic and

Atmospheric Administration

Fisheries (P. Kurkul)

U.S. Nuclear Regulatory Commission

(P.T. Kuo)

U.S. Nuclear Regulatory Commission

(P.T. Kuo)

U.S. Fish and Wildlife Service

(J. Smith)

U.S. Nuclear Regulatory Commission

(P.T. Kuo)

U.S. Fish and Wildlife Service

(J. Smith)-

U.S. Nuclear Regulatory Commission

(P.T. Kuo)

U.S. Nuclear Regulatory Commission

(S. Imboden)

Date of Letter

May 5, 2004

May 5, 2004

May5, 2004,

May 12,2004

May 25, 2004

August 5, 2004

November 22, 2004

January 31, 2005

April 21, 2005

May 5, 2005

May 25, 2005

August 2005 E-1 NUREG-1437, Supplement 23
Z

C

-Po

C.

Table E-2. Federal, State,

PBNP

Local, and Regional Licenses, Permits, Consultations, and Other Approvals for 'a

(t

3

X

Agency Issue Expiration m Authority Description Number Date Date Remarks

NBC 10 CFR Part 50 Operating License, DPR-24 10/5/70 10/5/10 Authorizes operation of Unit 1.

Pt. Beach Unit 1

NRC

FWS

10 CFR Part 50

Section 7 of the

Endangered Species

Act (16 USC 1536)

Operating Ucense,

Pt. Beach Unit 2

DPR-27 11/16/71 3/8/13 Authorizes operation of Unit 2.

Consultation Requires a Federal agency to consult with

FWS regarding whether a proposed action

will affect endangered or threatened

terrestrial species.

Requires a Federal agency to consult with

NMFS regarding whether a proposed action

will affect endangered or threatened aquatic

species.

NOM

Fisheries

m Wisconsin

r!, Historical

Society

Wisconsin

Department of

Administration

Section 7 of the

Endangered Species

Act (16 USC 1536)

Section 106 of the

National Historic

Preservation Act

(16 USC 470f)

Section 307 of the

Coastal Zone

Management Act (16

USC 1456[c)[3][A])

Consultation

Consultation The National Historic Preservation Act

requires Federal agencies to take Into

account the effect of any undertaking on

any district, site, building, structure, or

object that is included in or eligible for

Inclusion in the National Register of Historic

Places.

Certification Requires an applicant to provide

certification to the Federal agency issuing

the license that license renewal would be

consistent with the Federally approved

State coastal zone management program.

Based on its review of the proposed activity,

the State must concur with or object to the

applicant's certification.

C

U3

0

0

01f
a

Uo

a

0'

0

0)

01n

Table E-2. (contd)

I

Agency Issue Expiration

Authority Description Number Date Date Remarks

USDOT 49 USC 5108 Registration 053003450 06/02/03 06/30/05"'a Hazardous materials shipments.

005L

EPA Resource

Conservation and

Recovery Act

(42 USC 6912) and

Ch. 101.09

Wisconsin Statutes

Notification of

Regulated Waste

Activity

WID093422

657

NA NA Hazardous waste generation and

transport.

WDNR Clean Water Act

(33 USC Section

1251 et seq.) and

Ch. 283 Wisconsin

Statutes

Individual WPDES

Permit

WI

0000957-

07-0

7/1/04 6/30/09 PBNP discharges to Lake Michigan.

Permit remains in effect pending State'

review of renewal application.

m

co)

I

WDNR

WDNR

WDNR

WDNR

Clean Water Act

(33 USC Section

1251 et seq.) and

Ch. 283 Wisconsin

Statutes

Federal Clean Air Act

(42 USC 7661-7671)

and Ch. 285

Wisconsin Statutes

Ch. 280 Wisconsin

Statutes

Ch. 280 Wisconsin

Statutes

Ch. 281 Wisconsin

Statutes

General WPDES

Industrial Storm

Water Discharge

Permit (Tier 2)

Renewed Air

Pollution Control

Operation Permit

Registration

Registration

High-Capacity Well

Approval

WI.

S067857-1

436034500-

P10

05/30/95 03/31/06

10/17/03 10/17/08

Storm water runoff from Industrial

facilities.

Air emissions from

a gas turbine, boilers, generators, a fire

pump, and a paint spray booth.

Nontransient noncommunity water

supply registration for PBNP.

Transient noncommunity water supply

registrations for Energy Info. Center,

North Gatehouse, and Site Boundary

Control Center.

Approval for wells with combined

capacity >1 x 105 gpd.

z

C:

M

0

*I

3~

co

CD,

436063430 NA NA

43612602,

43601096,

and

43603450

52824,

52825,

52826

NA NA

WDNR NA NA :0

CD

x

mT
z

C

:1)

m

CA)

C

CD

Table E-2. (contd) CD

o-

_.

x

m

Agency Issue Expiration

Authority Description Number Date Date Remarks

WDNR Ch. 29.614 Scientific Collecting SCP-LM-18- 01/13/02 12/31/05 Collection of fish for radioactivity I

Wisconsin Statutes Permit 9397 analysis. Remains in effect pending

State review of renewal application.

Wisconsin

Department of

Commerce

Federal Resource

Conservation and

Recovery Act

(42 USC 6912) and

Ch. 101.09

Wisconsin Statutes

Underground

Storage Tank

Registration

Owner ID:

382951 Site

ID: 118971

Tank IDs:

764837,

764843,

285454,

930217 and

930224

10/20/95

10/01/92

08/25/03

NA Storage of flammable materials in

underground tanks.

Wisconsin

Department of

Commerce

Ch. 101.09

Wisconsin Statutes

Aboveground

Storage Tank

Registration m

Owner ID:

382951 Site

ID: 118971

Tank IDs:

206578,

206579,

206580,

206581,

206582,

206583,

206584,

455264,

455274

206615,

206616

206690

10/01/92 NA

10/20/95

10/19/95

Storage of flammable materials in

aboveground tanks.

South

Carolina

Department of

Health and

Environmental

Control

South Carolina

Radioactive Waste

Transportation and

Disposal Act (S.C.

Code of Laws

13-7-110 et seq.)

Radioactive Waste

Transport Permit

00604805-X 11/02/04 12/31/05 Transportation of radioactive waste to

disposal facility in South Carolina.

c

ro

0

0

01
a

(a

a

C)

0

0n

Table E-2. (contd)

I

I

Agency Issue Expiration

Authority Description Number Date Date Remarks

Tennessee Tennessee Code License to Ship T-W1002- 01/01/04 12/30/04( ' Shipments of radioactive

Department of Annotated Radioactive Material L03 material to processing

Environment 68-202-206 facility in Tennessee.

and

Conservation

(a) Permit renewal application submitted.

> - greater than

CFR - Code of Federal Regulations

EPA - U.S. Environmental Protection Agency

FWS - U.S. Fish and Wildlife Service

gpd - gallons per day

NA - not applicable, one-time registration

NOAA - National Oceanographic and Atmospheric Administration

NMFS - National Marine Fisheries Service

NRC - U.S. Nuclear Regulatory Commission

USC - United States Code

USDOT - U.S. Department of Transportation

WDNR - Wisconsin Department of Natural Resources

WPDES - Wisconsin Pollutant Discharge Elimination System

m

z

C

m

CA)

CA

c;

-0

CD

r3an

CA)

'a

CD

X

mT
Appendix E

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON D.C. 20555OI01

May 5, 2004

Mr. Don KIlma, Director

Office of Federal Agency Programs

Advisory Council on Historic Preservation

'Old Post Office Building

1100 PennsylvanIa Avenue, NW, Suite 809

Washington, DC 20004

SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LiCENSE RENEWAL

REVIEW

Dear Mr. Kilima:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating licenses for Point Beach Nuclear Plant, Units I and 2 (PBNP), which is located on the

western shore of Lake Michigan In Two RIvers, Wisconsin, approximately 30 miles southeast of

Green Bay, Wisconsin. PSNP Is operated by Nuclear Management Company. LLC (NMC).

The application for renewal was submitted by NMC on February 26,2004, pursuant to NRC

requirements at Title 10 of the Code of Federal Regulatlons Part 54 (10 CFR Part 54). The

NRC has established that, as part of the staff review of any nuclear power plant license renewal

action, a site-specific Supplemental Environmental Impact Statement (SEIS) to ts Generlc

Environmental Impact Statement for Ucense Renewal of Nuclear Plants (GEIS),

NUREG-1437, will be prepared under the provisions of 10 CFR Part 51, which Implements the

National Environmental Policy Act of 1969 (NEPA). In accordance with 38 CFR 800.8, the

SEIS will Include analyses of potential Impacts to historic and cultural resources. A draft SEIS

is scheduled for publication in January 2005, and will be provided to you for review and

comment.

If you have any questions or require additional information, please contact the Environmental

Project Manager for the Point Beach project, Mr. Wiliam Dam, at 301-415-4014 or

WLD@nrc.gov.

Since /

P o-TsinKuo. Frogram )ror

ense Renewal and Environmental Impacts

isIon of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-266,50-301

cc: See next page

NUREG-1437, Supplement 23 E-6 August 2005

I I
Appendix E

UL UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGT0Wt. D.C. 20555.0001

May 5, 2004

Ms. Janet Smith

Field Supervisor

U.S. Fish and Wildlife Service

Green Bay ES Field Office

2661 Scott Tower Drive

New Franken, WI 54229-9565

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION (NRC) ENVIRONMENTAL

REVIEW AND REQUEST FOR PROTECTED SPECIES WITHIN THE AREA

UNDER EVALUATION FOR THE POINT BEACH NUCLEAR PLANT LICENSE

RENEWAL'

Dear Ms. Smith:

Thank you for providing my'staff the opportunity to meet with you on March 17, 2004, to discuss

the U.S. Nuclear Regulatory Commission's (NRC) process for reviewing an application to

extend the operating licenses of Point Beach Nuclear Plant, Units 1 and 2 (PBNP).

Mr. William Dam and our consultant with Los Alamos National Laboratory, Dr. Paul Schumann,

found the discussions with you, Ken Stromberg, and Larry Thompson to be very informative

and beneficial as we begin the process of collecting information to write a draft Supplemental

Environmental Impact Statement (SEIS).

The NRC has established that, as part of the staff review of any nuclear power plant license

renewal action, a site-specific SEIS to its 'Generic Environmental Impact Statement for Ucense

Renewal of Nuclear Plantse (GElS), NUREG-1 437, will be prepared under the provisions of

10 CFR Part 51, the NRC rules that implement the National Environmental Policy Act of 1969

(NEPA). In addition the NEPA Interactions satisfy the provisions of the Fish and Wildlife

Coordination Act of 1934.

To support the SEIS preparation process and to ensure compliance with Section 7 of the

Endangered Species Act of 1973, the NRC requests a list of species and information on

protected, proposed. and candidate species and critical habitat that may be in the vicinity of

PBNP and its associated transmission lines. As mentioned In your February 26, 2004 letter to

Nuclear Management Company, LLC (NMC), we understand that your office will coordinate and

request input from the Wisconsin Department of Natural Resources, which maintains the

Natural Heritage Inventory. In addition, our staff received the September 2003 report you sent

titled, 'Recovery Plan for the Great Lakes Piping Plover," which provides important information

that we will include in the SEIS.

Attached is a map of the transmission-line corridors from the NMC license application

(Enclosure). NMC has agreed to provide you with an additional detailed geo-referenced map of

the site and transmission-line corridors. The proposed action would include the use and

continued maintenance of existing plant facilities and transmission lines. The PBNP she

August 2005 E-7 NUREG-1437, Supplement 23
Appendix E

J. Smith 2

located in Manitowoc County, Wisconsin, covers approximately 1260 acres, of which

approximately 1050 acres are used for agriculture.

For the specific purpose of connecting PBNP to the regional transmission system, there is a

total of approximately 73 miles of transmission lines that occupy approximately 1955 acres of

land. These transmission line corridors are being evaluated as part of the SEIS process. The

transmission line corridors traverse Brown and Manitowoc Counties. The corridors pass

through land that is primarily rolling hills covered with forests or farm land. Three 345-kilovolt

(kV) lines connect PBNP to the electric grid. A fourth transmission line connects Kewaunee

Nuclear Power Plant to the PBNP substation.

NRC will hold two public scoping meetings for the PBNP license renewal supplement to the

GEIS on June 15, 2004, at Fox Hills, 250 West Church Street in Mishicot, Wisconsin. There

will be two sessions to accommodate interested parties with the first session convening at

1:30 p.m. and continuing until 4:30 p.m., as necessary. The second session will convene at

7:00 p.m., with a repeat of the overview portions of the meeting, and will continue until

10:00 p.m., as necessary. Additionally, the NRC staff will host Informal discussions one hour

before the start of each session. To be considered, comments must be provided either at the

transcribed public meetings or in writirig. No formal comments on the proposed scope of the

supplement to the GEIS will be accepted during informal discussions. In addition to attending

the public meetings, you and your staff are invited to attend our site audit at PBNP on

June 16-17, 2004. The audit will include a tour of the area surrounding the facility, examination

of the intake structure, screen house, and transmission line corridors, as well as document

reviews.

The comment period on the scope of the environmental review closes on July 14, 2004.

Comments should be submitted by mail to the Chief, Rules and Directives Branch, Division of

Administrative Services, Mail Stop T-6D59, U.S. Nuclear Regulatory Commission, Washington

DC 20555-0001, or by e-mail to PointoachEIS~nrc.gov. At the conclusion of the scoping

process, the NRC staff will prepare a summary of the significant Issues identified and the

conclusions reached and will mail a copy to you.

The NRC will Issue ihe draft SEIS for public comment (anticipated publication date, January

2005), and will hold another set of public meetings In the site vicinity to solicit comments on the

draft A copy of the draft SEIS will be sent to you for your review and comment. After

consideration of public comments received on the draft, the NRC will prepare a final SEIS. The

Issuance of a final SEIS for PBNP is planned for August 2005. It you have any questions or

require additional Information, please contact Mr. William Dam, Environmental Project Manager,

at 301-415-4014 or WLD~nrc.pov.

Sincerel 2

Pa Tsin Kuo, Pogram Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-266 and 50-301

Enclosure: As stated

cc: See next page

NUREG-1437, Supplement 23 E-8 August 2005

I I
Appendix E

Point Beach Nuclear Plant

Application for Renewed Operating Licenses

Chapter 3 Appendix E - Environmental Report

]

Page 3-12

August 2005 E-9 NUREG-1437, Supplement 23
Appendix E

Point Beach Nuclear Plant

Application for Renewed Operating Licenses

Chapter 3 Appendix E- Environmental Report

LEGEND

I C rs"P.~l b omsfitig Ikne

/ ,Ttmans sion Litn Rv Priaymd it linrted access P rif rmad

=J County Souflesn.8

Lakef W4d RFvr

hmLian Resenstoers

Uman Areas

a C 5 to Is 20uL,

6 0 6 12 IN 24 30 K

FIGURE 3-2

Transnission Une Map

[tant eee

Pzge 3-13

NUREG-1437, Supplement 23 E-10 August 2005

iiiII 
Appendix E

NUC A UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 205550001

May 5 2004

Mr. Richard Dexter

Wisconsin Historical Society

Division of Historic Preservation

816 State Street

Madison, WI 53706

SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL

REVIEW

Dear Mr. Dexter:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating licenses for Point Beach Nuclear Plant, Units 1 and 2 (PBNP), which is located on the

western shore of Lake Michigan in Two Rivers, Wisconsin, approximately 30 miles southeast of

Green Bay, Wisconsin. PBNP is operated by Nuclear Management Company, LLC (NMC).

The application for renewal was submitted by NMC on February 26,2004, pursuant to NRC

requirements at Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54). The

NRC has established that, as part of the staff review of any nuclear power plant license renewal

action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its 'Generic

Environmental Impact Statement for License Renewal of Nuclear Plants" (GEIS),

NUREG-1437, will be prepared under the provisions of 10 CFR Part 51, the NRC rules that

implement the National Environmental Policy Act of 1969 (NEPA). In accordance with

36 CFR 800.8, the SEIS will include analyses of potential impacts to historic and archaeological

resources.

In the context of the National Historic Preservation Act of 1966, as amended, the NRC staff has

determined that the area of potential effect (APE) for a license renewal action is the area at the

power plant site and its immediate environs that may be Impacted by post-license renewal landdisturbing operations or projected refurbishment activities associated with the proposed action.

The APE may extend beyond the immediate environs in those instances where post-license

renewal land-disturbing operations or projected refurbishment activities, specifically related to

license renewal, may potentially have an effect on known or proposed historic sites. This

determination Is made irrespective of ownership or control of the lands of interest.

While preparing its application, NMC contacted your office by letter dated December 22, 2003.

In its letter, NMC stated there are no plans to significantly alter current operations over the

license renewal period. NMC further stated that no expansion of existing facilities is planned.

In addition, no land-disturbing activities are anticipated beyond those required for routine

maintenance and repairs.

August 2005 E-1 1 - NUREG-1 437, Supplement 23
Appendix E

R. Dexter 2

On June 15, 2004, the NRC will conduct two public NEPA scoping meetings at Fox Hills,

250 West Church Street in Mishicot, Wisconsin. You and your staff are invited to attend. The

anticipated publication date for the draft SEIS is January 2005. Your office will receive a copy

of the draft SEIS along with a request for comments. If you have any questions or require

additional information, please contact Mr. William Dam, Project Manager at 301-415-4014 or

WLD6nrc.qov.

Sincerely,

P o-Tsin uo, gram Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs Office' of Nuclear Reactor Regulation

Docket Nos.: 50-266 and 50-301

cc: See next page

NUREG-1437, Supplement 23 E-1 2 August 2005

I I
Appendix E

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON D.C. 20555-0001

May 12,'2004

Ms. Patricia A. Kurkul

Regional Administrator

NOM Fisheries

Northeast Regional Office

One Blackburn Drive

Gloucester, MA 09130-2298

SUBJECT: REQUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2,

LiCENSE RENEWAL

Dear Ms. Kurkul:

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application submitted by

Nuclear Management Company, LLC (NMC) for the renewal of the operating licenses for Point

Beach Nuclear Plant, Units 1 and 2 (PBNP).-: PBNP is located on the western shore of Lake

Michigan In Two Rivers, Wisconsin. approximately 30 miles southeast of Green Bay,

Wisconsin. As part of the review of the license renewal application, the NRC Is preparing a

Supplemental Environmental Impact Statement (SEIS) under the provisions of the National

Environmental Policy Act (NEPA) of 1969, as amended, which includes an analysis of pertinent

environmental issues, Including endangered or threatened species and impacts to fish and

wildlife. This letter is being submitted under the provisions of the Endangered Species Act of

1973, as amended, and the Fish and Wildlife Coordination Act of 1934, as amended.

The proposed action would Include the use and continued maintenance of existing plant

facilities and transmission lines. The PBNP site covers approximately 1260 acres, of which

approximately 1050 acres are used for agriculture. Structures and parking lots occupy about

70 acres, and the remaining acreage Is a natural mix of woods, wetlands, and open areas. The

area within 6 miles of the plant Is mainly farmland, woods, and small residential communities.

Each PBNP unit uses a once-through cooling system with Intake and surface discharge to Lake

Michigan. The Intake structure had been reconfigured In 2001 due to bird mortality rates. The

intake structure now stands below the lake surface.

For the specific purpose of connecting PBNP to the regional transmission system, there is a

total of approximately 73 miles of transmission lines that occupy approximately 1955 acres of

land. These transmission line corridors are being evaluated as part of the SEIS process. The

transmission line corridors traverse Brown and Manitowoc Counties. The corridors pass

through land that Is primanly rolling hills covered with forests or farm land. The enclosed

transmission line map shows.the transmission system that is being evaluated In the SEIS.

Three 345-kilovolt (kV) lines connect PBNP to the electric grid. A fourth transmission line

connects Kewaunee Nuclear Power Plant to the PBNP Substation.

August 2005 E-1 3 NUREG-1437, Supplement 23
Appendix E

P. Kurkul -2 -

To support the EIS preparation process and to ensure compliance with Section 7 of the

Endangered Species Act of 1973, the NRC requests a list of endangered, threatened,

candidate, and proposed species, and designated and proposed critical habitat under the

jurisdiction of NOAA Fisheries, that 'may be in the vicinity of PBNP site and its transmission line

corridors. The NRC has also contacted the U.S. Fish and Wildlife Service and the Wisconsin

Department of Natural Resources and requested a. list of species and Information on protected,

proposed, and candidate species and critical habitat that may be in the vicinity of PBNP and its

associated transmission lines.

We plan to hold two public NEPA scoping meetings on June 15, 2004, at Fox Hills, 250 West

Church Street In Mishicot, Wisconsin. From June 16-17, 2004, we plan to conduct a site audiL.

You and your staff are Invited to attend both the site audit and. the public meetings. You! office

will receive a copy of the draft SEIS along with a request for comments. The anticipated.

publication date for the draft SEIS is January 2005.

If you have any questions concerning the NRC staff review of this license renewal application,

please contact Mr. William Dam, Project Manager, at 301-415-4014 or WLD nrc.gov.

Sincerely,

Pa In Kuo, rog ector

Uinse Renewal and Environmental Impacts

D sion of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-266 and 50.301

Enclosures: .1. PBNP Transmission Une Map

2. PBNP Site Layout

cc w/encls.: See next page

NUREG-1437, Supplement 23 E-14 August 2005
Appendix E

Chapter 3

Point Beach Nuclear Plant

Application for Renewed Operating Ucenses

Appendix E - Environmental Report

LEGEND

a Wells

/ ark

PatkbIg Lots

2DO a zo, 4zo ao F ..t

so 0 00 160 MOM

FIGURE 3-1

Facility Layout

Page 3-12

August 2005 E-1 5 NUREG-1437, Supplement 23
Appendix E

Point Beach Nucdear Plant

Application for Renewed Operating Licenses

Chapter 3 Appendix E - Environmental Report

, I . _

I +

Kewaunee

Green

Bay

Kewait'a

1 a- Oown

f.

n.-:'

.151

j . _ _

P"Wrt saacI

NrWi4n Plant

tilY

, . _ . -.. I ,,, .: - I,

I. ' ;

Ir j

Catumet ,I!

-. . I

I - Manitowoc

I

Maniovc

G3.

i :z .. I

. !Z

I.t

. . I

.I

a roe rom D cuibrq U Rox iii Ib

P"M MO wilUt Ikntd uccms

^ Pumdy rad

z= Coiuity 5mvdwi.s =. nand ResarvEo

Ub Areas

5 C S 10 Is 2D I

6 0 6 i2 IS IA 3D Itfall7

FIGURE 3-2

TransmisoJon Lino Map

Pzge 3-13

NUREG-1437, Supplement 23 E-16 August 2005S
Appendix E

mscONS

WISCONSIN

HISTORICAL

SOCIETY

May 25, 2004

Mr. PaoTsin Kuo

U.S. Nuclear Regulatory Commission

Washington DC 20555-0001

SHSW#: 03-1046/MN

RE: License Renewal: Point Beach Nuclear Plant

Dear Mr. Kuo:

We have received your submittal of May 5, 2004 regarding the above

referenced project. As indicated in our previous correspondence of March

1 1, 2004 to Roger Newton, it was not possible to determine that the

fisherman's shed is not eligible for inclusion in the National Register of

Historic Places based on the information that was submitted for review. We

recommended that a qualified architectural historian prepare a NPS 10-900

form for the property and submit it to our office for review and comment.

To date, we have not received the information needed to determine if the

fisherman's shed is eligible for inclusion in the National Register of Historic

Places.

As pointed out in our letter of January 6,2004 to the applicant, it is not

possible to determine if project activities, including leased property under

cultivation are having an adverse effect on unidentified archeological sites

within the proposed project area. As I mentioned in our telephone

conversation, there would be two options regarding archeological sites.

First, one could complete an archeological survey for all projects lands

pursuant to 36 CFR 800.4 or we could develop a Memorandum of

Agreement that would detail how and when archeological surveys would be

completed for land management activities.

August 2005 E-17 - NUREG-1437, Supplement 23
Appendix E

We look forward to working with you to complete the Section 106 review

process in a timely manner. If you would like to discuss these matters in

greater detail, please call me at (608) 264-6507.

Sincerely,

Sherman Banker

Office of Preservation Planning

NUREG-1437, Supplement 23 E-18 August 2005
Appendix E

a . -.

United States Departhent of the Interior'

FISH AND WLDLIFE SERVICE

aGnidbiy ES Field Office - 2661 Scot Tower Drive

New Fmnken, Wisconsin 54229-956S

Tclejeone9201866-1717

FAX 9201866-1710.

AugustS,,2004

I

I

.4

Dr. Pao-Tsin Kuo

Program Director

License Renewal and Environmental Impacts Program

Office of Nuclear Reactor Regulation

Nuclear Regulatory Commission

Washington, D.C. 20555-0001..

Dear Dr. Pao-Tsin Kuo: 2.

Your May 5.2004 letter (received May 10, 2004) requested a list of species and informiation on:

the protected, proposed, and candidate species and critical habitat that may be in the vicinity of

the Point Beach Nuclear Plant (Plant) and its associated transmission line corridos (Project). In

a February 26,2004 letter to the Nuclear Management Company LLC and copied to Mr. Nilliamn

Dam of the Nuclear Regulatory Coriinisiion (Corniniision), the US. Fish'and Wildlife Se rice

(FWS) identified the need for a more detailed apj 61theiProjeetiarea, c'e-iKa te'picted the

Project boundaries more precisely. Your letter attached a map that was also no't iletailed enough"

for the FVS t67query the Wisconsii Department of'Natural Resources' Natural Heritage

Inventory database, to obtain infonmadon reiarding'pecies or habitats that may be in the vicinity

of the Project: However, a more detailed m'ap was submitted by the Nuciear Management

Company LLC, in a letter dated May 18, 2004 (received by the FWS May 21, 2004), and the

FWS relied on that map to prepare this response.

Our understanding is that no Federally-listed threatened or' endangered species, proposed species,

candidate species, or designated or proposed critical habitat occur within the Project area at this

time.-Howdva'r, it is possible Idtht1abitatsgwithin b' near the Project may be used in the 'future bylisted, proposed, or candidate species that ire not present within the Project area at this time. For

example, while the Federally-listed (endangered) piping ploiver (Charadrius melodus) is

currently rare along the Wisconsin shore of Lake Michigan, expanding populations in Michigan

increase the likelihood it will disperse and occur with greater frequency in Wisconsin. In our

February 26,2004 letter to the Nuclear Management Company, the EWS recommended

evaluation of the shoreline habitat near the Plant, to assess its suitability'to the piping plover.

The FWS als6-recomnendeld the disriptioi of potential measures to control the levels of human

disturbance in any habitits deem'ed suifabie. - 'I* - ;:

A r n p ini to these rec6'mmendailons;b lNoelCutuight of We Ei~erie (dited

May 12, 2004 and addressed to Gary Van Middiesworth'oftbehNucleariManagemient Conipjany),

was delivered to the FWS Green Bay Ecological Services Field Office as an attachment to a

August 2005 E-19 NUREG-1437, Supplement 23
Appendix E

2

letter from the Nuclear Management Company LLC to the FWS, dated May 18, 2004. Dr.

Cutright'clarifies that no formal species surveys or habitat evaluations have been conducted at

the Plant or its associated lands (p.1). Regarding the piping plover, Dr. Cutright agrees that this

species may occupy or nest on the Plant beach area over the term ofthe new license (p. 2).

Regarding controls on human disturbance, Dr. Cutright notes the presence of boulders at the

north and south shoreline boundaries, offshore buoy markers to identify restricted waters near the

Plant, andi the presence of security personnel to prevent unauthorized access (p. 2). Dr. Cutright

concludes that other than restricted beach access along the Plant, there do not appear to be other

factors that would make the Project shoreline any more attractive to nesting piping plovers than

shoreline north orsouth (p. 2).

As in our February 26,2004 letter to the Nuclear Management Company, the FWS recommends

evaluation of the shoreline habitat near the Plant, to assess its suitability to the piping plover; we

are not recommending evaluation of shoreline outside the Project boundaries, north or south of

the Plant. The shoreline location of the Point Beach Nuclear Plant, its restricted access (that

reduces human disturbances), its proximity to 5 nules ordesignated critical habitat al6ngthenearby Point Beach State Forest, and low Lake Michigan surface elevations collectively suggest

that habitat could be suitable near the Plant for plovers to occupy or nest there in the future. Dr.

Cutright agrees that plovers may occupy or nest on the Plant beach ar over the term ofthe new

license. An on-site, shoreline evaluation would reveal the presence or absence of factors (eg.,

habitat elements) relevant to its attractiveness to plovers, and may also suggest measures to

enhance habitat suitability. Procedures should be developed to notify resource agency personnel

and provide timely acaess to the shoreline along the Plant. -in the event that plovers occupy or

nest there. Measures to control disturbances or nest predation (e g., by erecting an exclosure)

should be proposed, as well as additional monitoring requirements that may be warranted ifnests

appear.

To avoid delay and confusion, the recommendations discussed above and in our February 26,

2004 letter should be discussed between the Commission (the federal action agency) and the

Nuclear Management Company LLC (the non-federal entity in the infornal consultation

process). Following that coordination, we suggest the Commission contact the FWS to discuss

our recommendations and your suggestions for how to proceed. The FWS understands that our

point-of-contact with the Commission on this matter is no longer William Damn or Jim Wilson,

but is now Stacey Imboden. When the Commirssion contacts the FWS to consult further on this__ _ matter, we caucoiifiri on thisiiiii point. _ _ -

Please continue to direct issues regarding this matter to Iarry Thompson of my staff at (920)

866-1736. or you may contact me at (920) 866-1725.

Sincerely.

Janet M. Smith

Field Supervisor

NUREG-1 437, Supplement 23 E-20 August 2005

II
Appendix E

3

cc: Wisconsin DNR

Nuclear Management Company LLC

August 2005 E-21 NUREG-1 437, Supplement 23
Appendix E

+4 MUNITED STATES

go ,NUCLEAR REGULATORY COMMISSION

.WASHINGTON, D.C. 20555S0*

November 22, 2004

Ms. Janet Smith

Field Supervisor U.S. Fish and Wildlife Service

Green Bay ES Field Office

2661 Scott Tower Drive

New Franken, WI 54229-9565

SUBJECT: REQUEST FOR CONCURRENCE - BIOLOGICAL ASSESSMENT FOR

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 UCENSE RENEWAL

Dear Ms. Smith:

The U.S. Nuclear Regulatory Commission (NRC) has prepared the enclosed biological

assessment (BA) to evaluate whether the proposed renewal of the Point Beach Nuclear Plant, '

Units i 'and 2 (PBNP) operating licenses for aperiod of an additional 20 years would have

adverse effects on listed species. The proposed action (license renewal) is not a major

construction activity. PBNP Is located on the western shore of Lake Michigan in Manitowoc

County, Wisconsin, approximately 48 km (30 mi) southeast of Green Bay and 24 km (15 mi)

north-northeast of Manitowoc.

By letter dated May 5, 2004, to the U.S; Fish and Wildlife Service (FWS), the NRC requested a

list of Federally threatened or endangered species that may be in. the vicinity of PBNP and its'

associated transmission lines. In a letter dated August 5, 2004, the FWS provided a list of

Federally threatened or endangered species. The FWS stated that noFederally-listed

threatened or endangered species, proposed species; candidate species, or proposed critical

habitat occur at the PBNP site, but that beach habitat near PBNP could be suitable nesting

habitat for piping plover (Charadrus melodus) at some time in the future. The NRC staff has

also included in its evaluation three other potentially-occurring Federally-listed species.

In addifton the staff also contacted the National Oceanic and Atmospheric Administration - Fisheries (NOAA Fisheries) by letter dated May 12,.2004, requesting a list of Federally

threatened or endangered aquatic species that may be in the vicinity of PBNP. NOAA Fisheries

did not respond to the May 12, 2004, letter.

The staff has determined that license renewal for PBNP may affect, but is not likely to adversely

affect the bald eagle and the piping plover, and will have no effect on the dwarf lake iris and the

dune or Pitcher's thistle.

We are requesting your concurrence with our determination. 'In reaching our conclusion, the

NRC staff relied on information provided by the applicant, on literature research and interviews

with experts, and on information provided by FWS.

NUREG-1437, Supplement 23 E-22 August 2005

Il
Appendix E

,.~~~.. ;, *- , .; '

'.Smith ,, 2> . : ..

If youhaveanyquestionsregairdingtihist, iologii A-s'se'sstientort-he sta f'srequest, please

,. contact . Ms. Stacey lrnbbln6, Erkvird6omentat Pirojqt Mahager, at 301-4152462 or via e-mail at

. sf nrc'o.g v. ' '" '' '' ",".' ' -'. ' -. .' , ... ' , .,-, - s.. .rr dc. . . . ........ -................... - ... .. ..................... ..

:..'' ,, ' . 'Sincerel;.

Pa"Tsini Kuo iora ieco

Li nse Renewai and Environmental Impacts Program

- ,' ^- , '. . t; -; Divisioni of R. iiIutay Inipt~veiie'nt P>rograms.;' ' . .

: ,, . - ;;. .' . '.,-.Offic of Nucla eatr Regulation'. ;,' ,.:-

Docket Nos.: .50-266 and.50-301-'-..:.',7

Enclosure: As state -d : ' J. ... .. .... . .. . ..

cc w/encl.,S:eene pae

August 2005 E-23- NUREG-1 437, Supplement 23
Appendix E

Biological Assessment

Point Beach Nuclear Plant . License Renewal Review

S.

November 2004

Docket Numbers

50-266

50-301

U.S. Nuclear Regulatory Commission

-Rockville, Maryland

NUREG-1437, Supplement 23 E-24 August 2005

I l
Appendix E

1.0 Introduction

The U.S. Nuclear Regulatory Commission (NRC) issues operating licenses for domestic nuclear

power plants in accordance with the pr6visions oT the Atom-ic Energy Act of 1954, as amended,

and NRC implementing regulations. The purpose and need for the proposed action (that is,

renewal of an operating license) is to provide an option that allows electric powergeneration to

continue beyond the term of the current nuclear power plant operating license, so future

generating needs can be met If the operator and State regulatory agencies pursue that option.

Wisconsin Electric Power Company (WEPCO) owns Point Beach Nuclear Plant. Units 1 and 2

(PBNP), and Nuclear Management Company. LLC (NMC) operates PBNP. WEPCO is doing

business as We Energies, and is a wholly owned subsidiary of Wisconsin Energy Corporation. In August 2000, WEPCO transferred operating authority for PBNP to NMC (NMC 2004). NMC

has prepared an environmental report in conjunction with its application for renewal of the

PBNP operating licenses, as provided for by the following NRC regulations:

*itie 10, Energy. Code of Federal Regulations (CFR) Part 54, Requirements for Renewal of

Operating Licenses for Nuclear Power Plants, Section 54.23, Contents of Application - Environmental Information (10 CFR 5423).

* THle 10. Energy, CFR Part 51, Environmiental Protection Requirements for Domestic

Licensing and Related Regulatory Functions Section 51.53, Postconstruction Environmental

Reports, Subsection 51.53(c), Operating Ucense Renewal Stage [10 CFR 51.53(c)].

The NRC Is reviewing an application'submitted by NMC (the applicant) for the renewal of the

operating licenses for PBNP for a period of an additional 20 years. There will be no major

construction, refurbishment, or replacement activities associated with this action. This biological

assessment examines the potential effects of.the continued operation'of PBNP on four

Federally-listed species that could occur within the PBNP site, near the site, or along its

associated transmission line rights-of-way (ROWs) pursuant to Section 7(a)(2) of the

Endangered Species Act.

In a letter dated May 5,2004 (NRC 2004), the NRC requested that the U.S. Fish and Wildlife

Service (FWS) provide lists of Federally-listed endangered or threatened species and

information on protected, proposed, and candidate species, as well as any designated critical

habitat, that may be in the vicinity of PBNP and its associated transmission line ROWs. In a

response dated August 5,2004 (FWS 2004a).,the FWS Green Bay Field Office noted that

beach habitat near PBNP could be suitable nesting habitat for piping plover (Charadrus

melodus) at some time in the future. Three other potentially-occurring Federally-listed species

were identified by NRC staff and are Included In this assessment.

2.0 Proposed Action

The proposed action Is the renewal of the operating licenses for PBNP. The plant is located on

the western shore of Lake Michigan in Manitowoc County, Wisconsin, approximately 48 kn

(30 mi) southeast of Green Bay and 24 km (15 mi) north-northeast of Manitowoc (Figure 1)

August 2005 E-25 NUREG-1437, Supplement 23
Appendix E

Figure 1. Location of PBNP.

-2-

NUREG-1437, Supplement 23 E-26 August 2005
Appendix E

(NMC 2004). The current operating license for Unit 1 expires on October 5, 2010, and for Unit 2

on March 8, 2013. NMC has submitted an application to the NRC to renew these operating'

licenses foran'additionial 20 years of operation (i.e.. until October 5,2030. for Unit 1 and

March 8; 2033 for Unit 2). The renewed licenses, if issued, will be effective from their date of

Issuance until 20 years after the expiration date of the curTent operating licenses.

.3.0 Environmental Setting

3.1 Aquatic Resources

Impacts on Federally-listed terrestrial threatened or endangered species that could potentially

occuras a result of continued operation of the plant cooling water system during the renewal

period are outlined in this section.

Lake Michigan is the source of water for the cooling and auxiliary water systems at PBNP,

which operates as a once-through cooling plant. Water from Lake

Michigan reaches PBNP through a submerged offshore intake.' Water returns to Lake Michigan'

through a surface shoreline discharge. The system removes waste heat from the condensers

as well as other plant equipment and discharges water through separate flumes for each unit.

At peak capacity, water is circulated at a maximum rate of 22 m'Is (783 ftl3s) through each

condenser and then returned to the lake. The water withdrawn for these systems flows first

through the intake structure to the fdrebay, then to the condensers and other equipmentL

Auxiliary water systems include service water and fire protection. :

In May 2001. the intake structure was reconfigured to resolve a bird mortality issue. The

modified structure stands approximately 3.4 m (11 ft) above the lake floor, has an outside

diameter of about 33 m ( 10 ft), and has an inside chamber with a diameter of 18 m (60 1f). The

top is covered 'with a steel superstructure and a trash rack made of high-density polyethylene

having approximately 18 -cm by 45-cm (7-in. by 18-in.)'openings (NMC 2001). Water enters the

chamber through the trash rack as well as through void spaces around the limestone blocks and

through'76-cm (30:ln.) pipes that penetrate the blocks in a rinig about 1.5 m (5 ft) above tho

lakebed. The pipes are covered with 3-cm by 5-cm (1.2-in. by 2-in.) bar gratings to prevent

debris and large fish from entering the intake'systern. -

3.2 Terrestrial Resources

The PBNP site is located on 510 ha (1260 ac) on the shore of Lake Michigan (NMC 2004). The

site and surrounding area consist primarily of agricultural land and forest; Approximately 42 ha

(104 ac) of the property are devoted to industrial use. The site consists of land leased for - - -

farming and woodlots up to 19 ha (47 ac) Insize. The woodlots occupy a total of about 40 ha

(100 ac), making up about 9 percent of the PBNP. property. The plant communities here include

a variety of trees such as aspen (Populus tremuloides), blue beech (Fagus grandifolia), hemlock

(Tsuga canadensis), and maple (Acer) Species forming the overstory (AEC 1972). .The

woodlots are maintained in a natural state and provide food, cover, and nesting sites for a

variety of wildlife.

-3-

August 2005 E-27 NUREG-1437, Supplement 23
Appendix E

The terrestrial wildlife that occurs at PBNP site and surrounding areas Is typical of that found in

similar habitats throughout Wisconsin' (AEC 1972). Common mammals include white-tailed

deer (Odocoileus virginianus), cottontail rabbit (Sylvilagus floridanus), raccoon (Procyon lotor),

gray fox (Urocyon cineroargenteus), gray squirrel (Sciurus carolinensis), eastern chipmunk

(Tamias stdatus). and masked shrew (Sorex cinereus). Upland birds that occur on the property

Include ring-necked pheasant (Phaslanus colchicus), wild turkey (Meleagups gallopavo),

American goldfinch (Carduelis tristis), eastern bluebird (Sialia sialia), blue jay (Cyanocitta

cristata), and eastern meadowlark (Stumella magna). Several waterfowl also occur here,

Including the Canada goose (Branta canadensis) and the wood duck (Aix sponsa). Additionally.

the site is occupied by several common amphibians and reptiles such as the tiger salamander

(Ambystoma tigrinum), northern leopard frog (Rana pipiens), American toad (Bufo ameticanus),

and the painted turtle (Chrysemys picta)

The PBNP property contains about 3 km (2 mi) of Lake Michigan shoreline. The shoreline here

consists of mostly narrow, bare beaches ranging from 6 m to 15 m (20 f to 50 ft) wide that

extend from the water's edge to low bluffs created by years of erosion' Riprap has been placed

along the edges of the bluffs to reduce erosion, which had been occurring at the rate of 0.8 m to

1.5 m (2.5 ft to 5 ft) per year (AEC 1972). The shoreline on the PBNP property does not contain

any sand dunes.

In its Environmental Report, the applicant identified three 345-kilovolt (kV) transmission lines

that connect PBNP to the power grid. (Figure 2) (NMC 2004). A fourth 345-kV line connects the

Kewaunee Nuclear Power Plant to the substation at PBNP. Currently the four lines are owned

and maintained by the American Transmission Company (ATC). The transmission lines are

described below and each corridor's characteristics are shown in Table 1.

Table 1. PBNP Transmission Line Rights-of-Way

Approximate Approximate Approximate

Length Width Area

Rights- Number

Substation of-Way of LInes kV an (ml) m (ft) ha (ac)

Granville L-111 1 345 32.0 20.0 67 220 210 530

Arcadian L-121 1 345 29.0 18.0 67 220 190 480

North Appleton L-151 1 345 47.5 29.7 67 220 320 790

PBNP 0-303 1 345 9.0 5.6 67 220 61 150

Source: NMC 2004

Each ROW is 67 m (220 ft) wide.. Figure 2 shows the transmission system for PB1NP. For the

specific purpose of connecting PBNP to the power grid, ATC has a total of 118 km (73.3 mi) of

transmission lines occupying approximately 791 ha (1955 ac) of easement (NMC 2004). The

ROWs pass through land that is primarily rolling hills covered in forest and farmland. These

ROWs pass through rural areas with low population densities. The lines cross numerous State

and Federal highways, including Wisconsin Highways 42 and 147 and Interstate 43.

-4-

NUREG-1437, Supplement 23 E-28 August 2005

I l~
Appendix E

Q-303 a.

•1. ' .- 4Bug

-1 ''':'01 5- ....

- i/ * * ¶2 X0 f20d

_ * sio Line. Map

Figure 2. PBNP transmission lines.

^5-

August 2005 E-29 NUREG-1437, Supplement 23
Appendix E

ROWs that pass through farmland Generally continue to be managed as such. ATC plans to

maintain these lines indefinitely as they are an integral part of the larger transmission system.

These transmission lines are expected to remain a pemarient part of the regional transmission

system after decommissioning of PBNP.

ATC implements the ROW inspection and maintenance program for PBNP-associated

transmission lines (ATC 2004). ATC manages transmission line ROWs using a wire

zone/border zone concept. The wire zone Is directly below the transmission lines and

vegetation is primarily low growing forbs and grasses. The border zone extends from the wire

zone to the edge of the ROW and woody species less than 5 m (15 ft) tall provide a transition to

the surrounding habitats. Vegetation management activities may indride tractor mowing,

manual chainsaw clearing, and application of herbicides by a state-licensed, commercial

applicator. Trimming is usually performed every 5 to 7 years, depending on the growth rates of

vegetation in a given area. ATC recognizes that transmission line ROWs provide ancillary

compatible uses including wildlife habitat, biodiversity corridors, recreation, and aesthetics.

ATC practices a vegetation management program that utilizes physical, chemical, and biological,.

treatments to promote stable, diverse, low-growing plant communities in a way that promotes

wildlife habitat and reduces environmental impacts.

4.0 Assessment of Federally-Listed Species

There are no Federally-listed threatened or endangered aquatic species known to occur at the

PBNP site or on habitat crossed by the associated transmission line ROWs (NMC 2004). There

are four Federally-listed threatened or endangered terrestrial species that have been identified

by the staff as potentially occurring In the vicinity of PBNP and its associated transmission lines.

Three species have been recorded in Manitowoc County: the bald eagle (Haliaeehus

leucocephalus), th'e piping plover (Charadrius melodus), and the dune or Pitcher's thistle

(Cirslum pitchen) (WDNR 2004).. The dwarf lake iris (Ins lacustfis), also a Federally-listed

species, has been recorded in Brown County, which is traversed by a PBNP transmission line.

Table 2 presents those Federally and State-listed species that have been recorded in Brown

and Manitowoc Counties and could potentially occur on the PBNP site or transmission line

ROWs, if suitable habitat were available.

N - -

NUREG-1437, Supplement 23 E-30 August 2005

I I
Appendix E

Table 2. Terrestrial Species Listed as Endangered or Threatened by the FWS and

that Occur or Potentially Occur Within the PBNP Site or the Associated

Transmission Une 'Rights-of-Way

Scientific Name Common Name Federal Status>

Birds

Haliaeetus Ieucocephalus bald eagle T

Charadrus meAodus piping plover E

Plants

Cisiurm pitcher dune (or Pitcher's) thistle T

Iris lacustns dwarf lake Iris T

(a) E * endargeed. T * tVeatened. Sources: FWS 2004b.

Bald Eagle (Halfaeetus leucocephalus)

The bald eagle is Federally-listed as threatened in the lower 48 states (FWS 2004b). This

species is a large raptor that Is found along the coastline around lakes and rivers. Eagles

generally nest in tall trees or on cliff faces near water and away from human disturbance. No

bald eagle nesting occurs on the plant site and'none'havie been observed to forage In the

vicinity of the plant (We Energies 2004a). The transmission lines extend for the most part to the

west, away from Lake Michigan and bald eagle foraging habitat.

For these reasons, the staff has determined that continued operation of PBNP over the 20-year

license renewal period may affect, but Is not likely to adversely affect the bald eagle.

Piping Plover (Charadrius melodus)

The piping plover Is Federally-listed as endangered In the Great Lakes region (FWS 2004b).

Piping plovers breed only in three North American geographic regions: the Atlantic coast, the

Northern Great Plains, and the Great Lakes. "Great Lakes'piping plovers breed along sparsely

vegetated beaches, cobble' pans, and sand spits along the shoreline. The FWS defines their

essential breeding habitat as greater than 7 m (23 ft) wide beach. greater than 0.4 km (025 mi)

of shoreline length, dune area of .95 ha (4.82 ac), patches of cobble or degree cover, and

areas of beach with up to 50 percent of vegetation cover (FWS 2004b). The stretch of shoreline

nearest to PBNP that is designated as critical breeding habitat is at Point Beach State Forest,

approximately 5 km (3 mi) to the southeast, where about 13 km (8 mi) of shoreline have been

designated as suitable, although there are no records of breeding at this location (FWS 2004c).

The only breeding plovers known within Wisconsin in recent years are along the shores of Lake

Superior (WDNR 2004).

-7-

August 2005 E-31 NUREG-1437, Supplement 23
Appendix E

We Energies conducted an initial piping plover suitability assessment of their Lake Michigan

property on October 1, 2004. The aisessment concluded that portions of the shoreline appear

to be suitable nesting habitat (We Energies 2004b). Based on this result, a series of

recommendations was presented:

* No measures should be taken to enhance habitat suitability,

• A piping plover breeding census shouild be conducted annually between June 1 and June 15

using the International Piping Plover Breeding Census guidelines, and an individual census

report should be completed each year,

* The FWS Green Bay Field Office and the Wisconsin Department of Natural Resources

Bureau'of Endangered Resources should be contacted on the day that nesting piping plovers

are discovered on the site, and

* We Energies will collaborate with the above-mentioned agency staffs to determine beach

access, nesting habitat protection, and monitoring requirements.

In correspondence dated November 5, 2004, We Energies agreed to implement these

recommendations (We Energies 2004c). In addition, NMC restricts unauthorized public access

to the Lake Michigan beach area of the PBNP site with a line of boulders at the north and south

boundaries, buoy markers off the shoreline to mark restricted waters, and twenty-four hour

security personnel surveillance. For these reasons, the staff has determined that continued

operation of PBNP over the 20-year license renewal period may affect, but is not likely to

adversely affect the piping plover.

Dune or Pitcher's Thistle (Circlum pitcheri)

The dune or Pitcher's thistle is Federally-listed as threatened over its entire range (FWS 2004b).

The preferred site for the dune or Pitchers thistle is an area between a sandy beach and a fully

vegetated dune next to the shorelines of the Great Lakes (WDNR 2004). The primary threats to

the species are disturbance through'recreational activities (ATV use, trampling, etc.) and

overstory encroachment (NatureServe 2004). Although no suitabie habitat for this species has

been identified at ihe PBNP site or along associated transmission line corridors, beach habitat

is protected. NMC restricts unauthorized public access to the Lake Michigan beach area of the

PBNP site with a line of boulders at the north and south boundaries; buoy markers off the

shoreline to mark restricted waters, and twenty-four hour security personnel surveillance.

For these reasons, the staff has determined that. continued operation of PBNP over the 20-year

license renewal period will have no effect on the Pilcher's thistle.

-8-

NUREG-1437, Supplement 23 E-32 August 2005

Ilr
Appendix E

Dwarf Lake Iris (Irds lacutris)

The dwarf lake iris is Federally-listed as threatened over its entire range (FWS 2004b). The

dwarf lake iris is endemic 1o the northern shores of Lake Michigan and Lake Huron. This

species is found in association with the Niagara Escarpment, a limestone formation that extends

from the Door Peninsula to the north of the PBNP site through Michigan and Ontario to New

York. In Wisconsin the dwarf fake Iris is found on the northwestern shore of Lake Michigan and

the eastern shore of Green Bay in Brown and Door counties (WDNR 2004). The primary threat

to this species-is habitat degradation due to overstory encroachinent (NatureServe 2004). This

speies apparently thrives with frequent natural disturbance and does not appear to be

detrimentally impacted by human disturbance and is reported to do well in old-field conditions

(NatureServe 2004). Although this species has not been recorded at the PBNP site or along

associated transmission line corridors, potential beach habitat Is protected. NMC restricts

unauthorized public access to the Lake Michigan beach area of the PBNP site with a line of

boulders at the north and south boundaries, buoy markeis off the shoreline to mark restricted

waters, and twenty-four hour security personnel surveillance.

For these reasons, the staff has determined that continued operation of PBNP over the 20-year

license renewal period will have no effect on the dwarf lake Iris.

5.0 Conclusions

The NRC staff has evaluated the potential impacts of an additional 20 years of continued PBNP

operation on four species that are Federally-listed as threatened or endangered and have the

potential to occur at the PBNP site or along its associated transmission line corridors. Although

none of the four species are known to occur at the site or along transmission line corridors,

NMC and ATC have developed and implemented procedures to protect wildlife and habitat.

The staff has determined that license renewal for PBNP may affect, but is not likely to adversely

affect the bald eagle and the piping plover, and will have no effect on the dwarf lake iris and the

dune or Pitcher's thistle.

6.0 References

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

Protection Regulations for Domestic Ucensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants.'

Atomic Energy Act of 1954. 42 United States Code (USC) 201 1, et seq.

-9-

August 2005 E-33 - - NUREG-1437, Supplement 23
Appendix E

American Transmission Company (ATC). 2004. Routine Right-of-Way Maintenance. Accessed

at. httv://www atcilc.com/Prolects Tightofwav.shtml. on November 8,2004.

NatureServe 2004. NatureServe Explorer an Online Encyclopedia of Life. Version 3.1.

NatureServe, Arlington' Virginia. Accessed at httly/www.natureserve.org, on November 9,

2004.

Nuclear Management Company, LLC (NMC). 2004. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Mishicot, Wisconsin. February 2004.

U.S. Atomic Energy Com'mission (AEC). 1972. Final Environmental Statemnent Related to

Operation of Point Beach Nuclear Plant Units I and 2, Docket Nos. 50-266 and 50-301.

Directorate of Ucensing. Washington, DC.

U.S. Fish and Wildlife Service (FWS). 2004a. Letter from U.S. Fish and Wildlife Service to

Nuclear Regulatory Commission. Subject Response to the May 5; 2004 NRC staff letter

requesting information regarding threatened and endangered species in the vicinity of the

PBNP. (August 5,2004).

U.S. Fish and Wildlife Service (FWS). 2004b. Species Information, Threatened and

EndangeredAnimals and Plants website. Accessed at htto:/lendanaered~fws.pov/wildlife.htmi.

on August 2, 2004 through September 23, 2004.

U.S. Fish and Wildlife Service (FWS). 2004c. AU About Piping Plovers. Accessed at

htto //lover.Jws.oov/facts.html on November 9, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from Nuclear Regulatory

Commission to U.S. Fish and Wildlife Service. Subject Request for information regarding

threatened and endangered species In the vicinity of PBNP. (May 5, 2004).

We Energies. 2004a. Letter from We Energies Senior Terrestrial Ecologist, Dr'. N. Cutright, to

Nuclear Management Company Vice President Subject Response to U.S. Fish and Wildlife

Service Letter. (May 12,2004).

We Energies. 2004b. Piping plover Habitat on We Energies Property Near the Point Beach

Nuclear Plant Performed by Dr. N. Cutright. (October 15, 2004).

We Energies.. 2004c. Letter from We Energies to Nuclear Regulatory Commission. Subject:

Implementation of Piping Plover Habitat Survey Recommendations. (November 5, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004. Wisconsin State Threatened and

Endangered Species website. Accessed at:

http:tlwww.dnr.state.wi.us/org/landaerAvorking-listltaxalistsdTandE.asp on May 5, 2004.

-10-

NUREG-1437, Supplement 23 E-34 August 2005

l | : ! l
Appendix E

:

United States Deparinment of the Interior

-FSH ANDWILDLIFE SERVICE

Gren Biy ES Field Office

2661 Scot Tower Drive

New Franken, Wisconsin 54229-9565

Telephone 920/866-1717 -

FAX9201g66-1710

'January 31, 2005

Dr. Pao-Tsin Kuo '

Division of Regulatory Improvement Programs.

Otffice of Nuclear Reactor Regulation '. - - - -

-United Statei Nuclear Regulitory Commissi.on ; : _ 

Nlls'hiijon, D. C 20555-0001

'~re: - Request for Concurrenice

- K -Bioogical Assessmn'it for Point Beach

; i .- :NuclcarPlant"

' 'UnitsI and 2 License Renewal

-'Manitowoc County, !Wisconsin

Dear Dr. Ku&o * J ..: . .q~. t -:' z ;a ' '

Thislettcrrspondsto yourNoveiberr22,2004. rcqucst forU.S..Fish and VildliScrvic- -ce

(Scrviccj concurrcn~c vithyb6urrdcteminination 6fefccts ofthe-proposed license rcnewval on

federally-listed threatened and endangeitd species and is 3 follows up on a deccmbcr23 2004

electronic message to Ms. Staccy Imboaei.:Thc pro"pscd action rimuld renew the operating :

licensc for the Point Bcachuclca Uinits il 'nd2 (PBNP). fiin period of 20 years It

does not involve additional construction. Thc plant is iocated on the wvestern shore of Lake

Michigan in Manitowoc County; *Yisconsin . Wehiavc revieved the Biological Assessment (BA)

for the licensc rene val, n'd any other accompanying documents. Our comnients follow.

' ' T hree-federally-listed species, the bald eagle'pipiing plovrer, and Pitchcr's thistle, have becn

documented in Manitowoc County. Ani~dditional spccies, the dwarf lake iris, has been

documented in Browun County,\*hich is traiirsed by a PBNP transmission line.

Thc bald cagle is not known to nest in the plant area; and has not been observed foraging in or

near the plant area T'he transmission linesgenerally eitend to the west, away from La.ke

Michigan. Howvcver, we disagrec *;iththe BAthat it exteiids aay Lfrom bald eagle foraging habitat. Badagshaebnobig'mois maybei" c h ald eagles have been observed 1iraging on smaller, interior wvaterbodies that y

found near the tranmission line. N6nethei s, dh& license rinc%%al does not involvc additional

construciion, or cxpaso of lics Teifore,; we concur' with y-our detcrmninatior 'that the' ' '-'

proposed aiction affect, but will Iay not advcrsely affect the bald cagle.

S , ,. ,

August 2005 E-35 NUREG-1437, Supplement 23
Appendix E

2

The Pitcher's thistle has not been observed in the PBNP area, or along the transmission line

corridors. No suitable habitat has been observed for the thistle within the project area. Based on

this information, we concur with your determination that the proposed action will not affect the

Pitcher's thistle.

The dwarf lake iris has not been obsierved in the PBNP area, or along the transmission line

corridors. Hoivever, any suitable habitai for ihe iris is protected fron public accesiand would

not be disturbed as a rsult of the proposed action. Based on this informatibn, wev concur with

your determination that the proposed action wilnot affect the dwarf lake iris.

The piping plover has not been observed on the PBNPproperty.- However, there is designated

critical habitat for~the plover located to ite south of the plane There is also suitable habitat for.

the plover on the plant grounids. The Great Lakei piping plover population is rapidly cxpanding..' ' andtt're is some probability that ploversmay atternpt o usethc beaches ori the PBNP property'

inthe nea fuiture. The BA states that WE Energies has agreed to conduct an annual individual

census between June I and June 15 over the life of the license renewal period; they have agreed

to contact the Service's Green Bay Ecological Services Field Office and the Wisconsin

Department of Natural Resotirces (DNR)-Buicau of Endangered Resources on 'the same day that

* nesting is discovered; and they will collaborate with Service and DNR staffin protection and

monitoring of those nests. '

While we are encouraged by the wvillingness of the applicant to cooperate with agencies in

protection of the plover, we request the following modifications to the proposed plover-related actions. We prefer that two or more surveys be conducted during the breeding season, with one

occuring before May 30, and one or mor'e occurring between June I and June 15. Surveyi

shouldbe separated by at least 5 days. Howveverifonlyon "census is doneannually;we'

-requestthat itbe conductedbyJune 19. If one ormorepipingplovers are observed-duringthe

census, the Green Bay Ecological Services ield Off ice should be contacted immediately to,

initiate cobrdination on additional actions. The site should be monitored daily without disturbirig

the birds.- Ifpiping plovers persist on the site for more than a few days, trained Service staffshould be alldived tovisit the site, accompanied by appropriate personnel, to determine if iesting

has been initiated or will likely occur (based on the behavior of the birds). Ifnesting occurs, WE

Energies should collaborate with Service and DNR staffin protection and monitoring of the nests

' ini accordance ivith'the 2003eRecoveryPla Mor ihe Great LAicPiping Plioern * :;

Once we receive confirmation that the aforErientioned measures will be included in the license

renewal, we will be able to issue our concurrence with your determination for the piping plover.

We look forward to your response regarding our recommendations for piping plover monitoring

and/or protection.

While our concurrence with your determinations forthe bald eagle, Pitcher's thistle. and dwarf * .* * lake iris is current as of the date of this letter, please be aware that over time, habitats at or near

the project site may be utilized by listed or'proposed species not present at this time. Further,

* fish, wildlife or plant species occuming withini the project area may become federally-listcd as

threatened or endangered or proposed for listing; it also is possible that critical habitai could be

proposed or designated for a specics. The'reforc, if the project is modificd, this office should be

NUREG-1437, Supplement 23 E-36 August 2005

I I
Appendix E

- .

3

contacted for an' updated review of the project. O~ir species/critical habitat list is updated every 6

-ionths.

We appreciate the opportunity to respond. Questions pcrtaining to these comments can be..

directed to Ms. Lealkhena Au at 920-866-1734. : *

Sincerely,

Janet M Smith

Field Supervisor

. f- .: , .

I ..

... .. .

. I a .- . T!r* "I - : .. * . :. .

1: *:,. . . -- -- -r,.ZAugust 2005 E-37 NUREG-1437, Supplement 23
Appendix E

.?4 1 oUNITED ~ STATES

A \NUCLEAR REGULATORY COMMISSION

,WASHINGTON D.C. 20555-000

April 21, 2005

Ms. Janet Smith

Field Supervisor

U.S. Fish and Wildlife Service

Green Bay ES Field Office

2661 Scott Tower Drive

New Franken, WI 54229-9565

SUBJECT: REQUEST FOR CONCURRENCE - BIOLOGICAL ASSESSMENT FOR

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL

Dear Ms. Smith:

The U.S. Nuclear Regulatory Commission (NRC) has prepared a biological assessment (BA)

and transmitted It to U.S. Fish and Wildlife Service (FWS) on November 22, 2004. That BA

evaluated whether the proposed renewal of the Point Beach Nuclear Plant, Units 1 and 2

(PBNP) operating licenses for a period of an additional 20 years would have adverse effects on

listed species. In the BA, the staff has determined that license renewal for PBNP may affect,

but is not likely to adversely affect the bald eagle and the piping plover, and will have no effect

on the dwarf lake Iris and the Phcher's thistle.

By letter dated January 31, 2005, FWS concurred with NRC determinations regarding the bald

eagle, the Pitcher's thistle, and the dwarf lake iris. With regard to the piping plover, FWS noted

that the piping plover has not been observed on the PBNP properly but that piping plovers may

attempt to use the beaches on the PBNP property in the near future. Therefore, FWS

requested additional modifications to We Energies' proposed piping plover monitoring

framework.

We Energies revised its piping plover monitoring framework based on subsequent discussions

with FWS. The revised framework contains six points, as outlined in We Energies' letter to

FWS dated February 17, 2005. FWS responded to this revised monitoring framework by letter

to We Energies dated March 7, 2005, in which FWS said that it concurs with framework points

one through five but suggests a change to point six. This letter supplements the BA by

incorporating We Energies' commitment to modify monitoring framework point six by letter to

FWS dated March 15,2005. The We Energies Point Beach piping plover monitoring framework

incorporates the suggested changes from FWS, and stands as follows (as adapted from

March 15, 2005 letter from We Energies to FWS):

1. No measures will be taken to enhance habitat suitability along the stretch of beach

owned by We Energies near the PBNP;

2. An annual piping plover breeding census will be conducted at this location between

June 1 and June 15, with a target date of June 10 over the term of the new license;

3. The Intemational Piping Plover Breeding Census (IPPBC) guidelines will be followed,

and an IPPBC individual census report will be completed each year;

4. The Green Bay office of the FWS and the Wisconsin Department of Natural Resources

will be contacted on the same day that piping plovers are found nesting at this location;

NUREG-1437, Supplement 23 E-38 August 2005

I I
Appendix E

J. Smith -2-

5. Contacts with the natural resource agency staffs described in the above step will be used to

discuss beach access on the property, measures to protect the nest, and additional

monitoring requirements of the nest site;

6. If piping plovers are observed on the PBNP property, follow up surveys will be conducted in

the same year, earlier and repeated surveys will be conducted the next year, continuing for

as long as piping plovers are observed at the PBNP property.

NRC Is requesting your concurrence with our determination in the November 22, 2004, BA as

supplemented by this letter. The original BA is attached to this letter. The staff has determined

that license renewal for PBNP may affect, but is not likely to adversely affect the bald eagle and

the piping plover, and will have no effect on the dwarf lake iris and the Pitcher's thistle. In

reaching our conclusion, the NiRC staff relied on Information provided by the applicant, on

literature research and Interviews With experts, and on Information provided by FWS.

if you have any questions regarding this BA or the staffs request, please contact

Ms. Stacey Imboden, Environmental Project Manager, at 301-415-2462 or via e-mail at

sxf@nrc.ov.

Sincerely,

P n Kuo, rogram Director

Liense Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket Nos.: 50-266 and 50-301

Enclosure: Biological Assessment

cc w/o encl.: See next page

August 2005 E-39 NUREG-1 437, Supplement 23
Appendix E

United States Department of the Interior

FISH AND WILDLIFE SERVICE

Green Bay ES Field Olfice

2661 ScottTower Drive

New Franken. Wisconsin 54229-9565

.Telephone 920/866-1717

FAX 920366&1710

May 5,.2005

Dr. Pao-Tsin Kuo

License Renewal and Environmental Impacts Program

Office of Nuclear Reactor Regulation

Nuclear Regulatory Commission - Washington, District of Columbia-20555;0001 -:-- * - -

re: Biological Assessment

License Renewal

Point Beach Nuclear Plant, Units I and 2

Manitowoc County, Wisconsin

Dear Dr. Kuo: ' ' ; *

The U.S. Fish and Wildlife Service (Service) has receirved y'our lettir dated April 21, 2005, with

the Biological Assessment (BA) for the license renewal at Point Beach Nuclear Plant Units 1 and

2 in Manitowoc County, Wisconsin. Your letter includes a revised framework for piping plover

monitoring at the property and'requests'c'oncutrrence with the determination of effects of the

proposed action on federally-listed species tht'was included in the BA.'We have review'ed the.

ittiched information and our cornments follbW. , .

In a letter dated January 31, 2005, the Service concurred wvith'your determination of no adverse

efecrts to the bald eagle, Pitcher's th'isseii:, 'd dwvarf lake iris. As no new information has been _. received regarding these species, our concurrence remains valid. In the revised framework,

monitoring of the piping plover wvould be increased in the event that they are observed on the

property and Service staffwould be cdiotacted immediately ifnesting is observed. Based on the

information provided in your letter, as wll as in discussions with Dr. Noel Cutright of WE

Energies and Ms. Stacey Imboden oryour office, we concur with your determination that the

Action, as proposed, mnay affect but would nioAadversely affect the piping plover. Please note that

in accordance with Section 7 of the Endangerid.Species Act, if birds are repeatedly observed at

the project site, consultationi with this office should be ri-initiated.regardless of whether nesting

has been confirmed.

While these comments are current as of the'date of thiileiter, plea'se be aware ihat over time,

habitats at or near the project site may be utilized by listed or proposed species not present at this

time. Further, fish, wildlife or plant species occurring within the project area may become

NUREG-1437, Supplement 23 E-40 August 2005
Appendix E

- 9

federally-listed as threatened or endangered or proposed for listing; it also is possible that critical

habitat could be proposed or designated for a species. Thcrefore, if the project is modified, or if

there is a significant tag betweiri plan completion and construction; this office should be

contacted for an updated review of the project. Our speciestcritical habitat list is updated every 6

months.

We appreciate the opportunity to respond. Questions pertaining to these comments can be

directed to Ms. Leakhena Au at 920-866-1734. - -

Sincerely.

- ~ -- Janet-M . Smith-~- ~ - - -

Field Supervisor

cc: t-NRC, Washington, D.C. Atn: Stacey Imboden

August 2005 E-41 NUREG-1 437, Supplement 23
Appendix E

Stacey Imboden - RE: Point Beach Nuclear Plant-settling pond onsilo Page 1

From: 'Luebke, Paul W. cPauLLttebke0dnristale.wi.us>

To: *Slacey Imboden cSXFOnrcgov>

Date: 525/05 12:15PM

Subject: RE. Point Beach Nuclear Plant-settling pond onste

Here's some additional Information regarding the groundwaler at the Point Beach Nuclear Power Plant.

Paul Luebke

Our private water systems specialist here. Liz Heinen, who works with the smaller wells at the site,

indicated there haven't been any significant groundwater problems with those wells. That data is available

In the DNR Drinking Water System database. Also of note, the Dept. of Health and Family Services

conducted an oenvironmental radioactivity survey In 2003 for various locations at and by the plant, and It

doesn't appear that any significant groundwater problems were Identified. That survey Is avaiable at

httpItidhfs.wisconsln.gov/dph-boh/EnvMonitorng/PtBeach/PBK03Survey htm.

The wastewater pond abandonment project was completed November 1, 2002. The basin engineer, Dave

Gerfrnan, confirmed there are no current groundwater discharges at the power plant site, and neither the

power plant or the Department are aware of problems with the water supply. A public water supply

inspection was conducted In 2003. However, radioactive material wasn't sampled for, which may be

present In the upper aquifer from past discharges. The water supply wells aren't located In the upper aquifer.

-Original MessageFrom: Luebke. Paul W.

Sent: Tuesday, May 24,2005 2:05 PM

To: 'Stacey Imboden!

Subject RE. Point Beach Nuclear Plant-settling pond onseto

Thanks for providing the EPA comment. There's nothing specific with regard to problems with the pond

abandonment. EPA believes an evaluation of the groundwater conditions at the sitl Is warranted to

evaluate Impacts to water supply wells and power plant operation. They want some groundwater quality

data to confirm site conditions and that the old pond didn't contaminant groundwater. The fact the pond Is

abandoned, the potential source of contamination has been removed. I don't believe EPA`s comment

affects DNR previously stated position on closure of the pond. Paul

-Original Message From: Stacey Imboden jmalto:SXFOnrc.govj Sent: Tuesday. May 24. 2005 12:33 PM

To: Luebke. Paul W.

Subject RE: Point Beach Nuclear Plant-settling pond onshe

ThIs Is an excerpt of the EPA comment:

As part of Its July 1, 2004 scoping comments, the U.S. EPA recommended that the draft SEIS describe

site hydrogeology, on-site drinking water welts, drinking water quality, and treatment of the drinking water.

The U.S. EPA also recommended that NRIC evaluate the potential for groundwater contamination under

the license renewal period, especially with regard to the abandoned settling pond... it does not seem likely

that other plants have the same groundwater regime and configuration of drinking water wells and an

abandoned retention pond onsite..the SEIS does not successfully describe the Impact of extended plant

operation. including management of the abandoned settling pond, on groundwaler and drinking water.

Therefore, we recommend that the SEIS include an evaluation of ground water conditions and potential

Impacts of extended plant operation as part of the license renewal SEIS for this site.

The entire EPA comment letter is located In ADAMS on the NRC website (wwwnrc.gov) under accession

NUREG-1437, Supplement 23 E-42 August 2005
Appendix E

Stacey Imboden - RE: Point Beach Nuclear Plant-settling pond onsite Page 2

number ML051160259. I do not have it electronically.

Thanks.

Stacey

>>> Luebke. Paul W. cPauLLuebkeOdnr.state.wvtus> 05124/0512.09PM>>>

I agree with what you've stated is DNR's position In the email you sent me. We consider the

abandonment complete. rm not aware of what EPA's concerns are regarding the abandonment of the

wastewater setting pond. Could you please forward to me what their comments are. Thanks.

Paul W. Luebke, PH

Wastewater Specialist

Bureau of Watershed Management Wisconsin Department of Natural Resources

phone: (608) 266-0234

fax. (608) 267-2800

e-mail: pauLuuebkoOdnr state.wLus

-Original Message- From: Stacey Imboden [mailto:SXF~nrc.govj Sent: Tuesday. May24, 2005 9:52 AM

To: Luebke, Paul W.

Cc: schurnarnpObnl.gov basuO@iJ.gov

Subject: Point Beach Nuclear Plant-settling pond onsite

Paul,

rm completing NRC~s Final Environmental Impact Statement for License Renewal at Point Beach Nuclear

Plant I received a comment from EPA expressing concerns over the abandoned settling pond located

onsite. I want to follow up with you just to confirm that WDNR has no concerns regarding the settnmg pond, as was expressed to Amit Basu (from Lawrence Livermore National Laboratory) during his meeting

with you on June 15. 2004.

The Abandonment Plan for the Wastewater Retention Pond at Point Beach was approved by WDNR. per approval letter dated April 30. 2002 stating that WDNR is approving the abandonment plan . reviewed

for compliance with the applicable requirements, and that the report concluded the waters of the state

were not adversely impacted by the retention pond.

It Is my understanding that settling pond closure, and any groundwater release or contamination issues,

have been thoroughly reviewed by WDNR. Based on Amit Basu's discussions with you at WDNR on June

15.2004. there are no current groundwater Issues that WDNR is concerned about at Point Beach Nuclear

Plant. Afler reviewing the new WPDES permit for Point Beach (issued July 1 2004) It Is also my

understanding that there are no groundwater monitoring or Inspection Issues as part of the permit

requirements.

Additionally, I understand that there have been no known discharges to groundwater from Point Beach

Nuclear Plant since the settling pond was closed.

Is this a correct characterization of WDNRFs position? If not please lot me know of anyconcems.

Thanks,

Stacey Imboden

US. Nuclear Regulatory Commission

Project Manager- Point Beach License Renewal Review

August 2005 E-43 NUREG-1437, Supplement 23
Appendix E

IStacey Imboden- RE ;Point Beach Nuclear Plantsotiling pond onslto _ . Page I 31

Phone: 301-4152462

Email: sxflnrc.gov

CC: 'Gerdman. David A cDavid.Gerdman dnr state.wLus>

NUREG-1437, Supplement 23 E-44 August 2005

Il
Appendix F

GEIS Environmental Issues Not Applicable

to Point Beach Nuclear Plant Units 1 and 2
Appendix F

GEIS Environmental Issues Not Applicable

to Point Beach Nuclear Plant Units 1 and 2

Table F-1 lists those environmental issues listed in the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996, 1999)(a) and Title 10 of

the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B, Table B-1, that are not

applicable to Point Beach Nuclear Plant Units 1 and 2 (PBNP) because of plant or site

characteristics.

Table F-1. GEIS Environmental Issues Not Applicable to PBNP

ISSUE-10 CFR Part 51, Subpart A, Category GEIS

Appendix B, Table B-1 Sections Comment

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered salinity gradients 1 4.2.1.2.2 The PBNP cooling system

4.4.2.2. does not discharge to an

estuary.

Water-use conflicts (plants with cooling 2 4.3.2.1 The PBNP cooling system

ponds or cooling towers using makeup 4.4.2.1 does not use makeup water

water from a small river with low flow) from a small river with low

flow.

AOUATIC ECOLOGY (FOR PLANTS WITH COOLING-TOWER-BASED HEAT-DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early 1 4.3.3 -This issue is related to heatlife stages : .

Impingement of fish and shellfish 1 4.3.3

dissipation systems that are

not installed at PBNP.

This issue is related to heatdissipation systems that are

not installed at PBNP.

This issue is related to heatdissipation systems that are

not installed at PBNP.

Heat shock 1 4.3.3

(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.

August ,, 2005 F-1 - NUREG-1437. SuDolernent 2,'3
Appendix F

Table F-1. (contd)

ISSUE-10 CFR Part 51, Subpart A, Category GEIS

Appendix B, Table B-1 Sections Comment

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and 2 4.8.1.1 PBNP uses <100 gpm of

service water and dewatering; plants that 4.8.2.1 groundwater.

use >100 gpm)

Groundwater-use conflicts (plants using 2 4.8.1.3 This issue is related to heatcooling towers withdrawing makeup water 4.4.2.1 dissipation systems that are

from a small river) not installed at PBNP.

Groundwater-use conflicts (Ranney wells) 2 4.8.1.4 PBNP does not have or use

Ranney wells.

Groundwater quality degradation (Ranney 1 4.8.2.2 PBNP does not have or use

wells) Ranney wells.

Groundwater quality degradation 1 4.8.2.1 PBNP uses <100 gpm of

(saltwater intrusion) groundwater and is not

located near a saltwater body

Groundwater quality degradation (cooling 1 4.8.3 This issue is related to a

ponds in salt marshes) heat-dissipation system that

is not installed at PBNP.

Groundwater quality degradation (cooling 2 4.8.3 This issue is related to a

ponds at inland sites) heat-dissipation system that

is not installed at PBNP.

TERRESTRIAL RESOURCES

Cooling tower impacts on crops and

ornamental vegetation

1 4.3.4

Cooling tower impacts on native plants

Bird collisions with cooling towers

Cooling pond impacts on terrestrial

resources

1 4.3.5.1

1 4.3.5.2

1 4.4.4

This issue is related to a

heat-dissipation system that

is not installed at PBNP.

This issue is related to a

heat-dissipation system that

is not installed at PBNP.

This issue is related to a

heat-dissipation system that

is not installed at PBNP.

This issue is related to a

heat-dissipation system that

is not installed at PBNP.

NUREG-1437, Supplement 23 F-2 August 2005
Appendix F

Table F-1. (contd)

ISSUE-10 CFR Part 51, Subpart A, Category GEIS

Appendix B, Table B-1 Sections Comment

HUMAN HEALTH

Microbial organisms (occupational health)

(plants with cooling towers)

1 4.3.6 This issue is related to a

heat-dissipation system that

is not installed at PBNP.

This issue is related to a

heat-dissipation system that

is not installed at PBNP.

I

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

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.

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,

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

Report. NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

August 2005 F-3 NUREG-1437, Supplement 23
Appendix G

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Point Beach Nuclear Plant Units 1 and 2,

in Support of License Renewal Application
Appendix G

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Point Beach Nuclear Plant Units 1 and 2,

in Support of License Renewal Application

10 CFR 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. Point Beach

Nuclear Plant Units 1 and 2 (PBNP); therefore, the remainder of Appendix G addresses those

alternatives.

G.1 Introduction

Nuclear Management Company, LLC (NMC) submitted an assessment of SAMAs for PBNP as

part of the Environmental Report (ER) (NMC 2004a). This assessment was based on the most

recent PBNP Probabilistic Risk Assessment (PRA) available at that time, a plant-specific offsite

consequence analysis performed using the MELCOR Accident Consequence Code System 2

(MACCS2), and insights from the PBNP Individual Plant Examination (IPE) (WEPCO 1993),

and Revision 3.02 of the PBNP PRA model. In identifying and evaluating potential SAMAs,

NMC considered insights from the plant-specific PRA, as well as industry and NRC documents

that discuss potential plant improvements, such as NUREG/CR-5630 (NRC 1991) and

NUREG/CR-5575 (NRC 1990). NMC identified 202 potential SAMA candidates. This list was

reduced to 65 unique SAMAs by eliminating SAMAs that were not applicable to PBNP or had

already been implemented at PBNP. NMC assessed the costs and benefits associated with

each of these 65 SAMAs and concluded that none of the candidate SAMAs would be costbeneficial for PBNP.

Based on a review of the SAMA assessment, the NRC issued a request for additional

information (RAI) to NMC by letters dated July 2, 2004 (NRC 2004a) and October 20,2004

(NRC 2004b). Key questions concerned: dominant risk contributors at PBNP and the SAMAs

that address these contributors, the potential impact of uncertainties on assessment results, the

impact of human reliability analysis (HRA) modeling changes on the SAMA identification and

screening results, and more detail on some specific SAMA candidates. NMC submitted

additional information by letters dated August 31, 2004 (NMC 2004b) and November 22, 2004

August 2005 G-1 NUREG-1437, Supplement 23
Appendix G

(NMC 2004c), including tables showing relative core damage frequency (CDF) contributions, a

listing of basic events and importance measures, an uncertainty assessment, and additional

information regarding human error-related SAMAs. NMC's responses addressed all of the

staff's concerns.

Although none of the SAMAs appear cost-beneficial in the baseline analysis, the staff identified

one SAMA that could become cost-beneficial when uncertainties or alternative discount rates

are taken into account. However, this SAMA does not relate to adequately managing the

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

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

An assessment of SAMAs for PBNP is presented below.

G.2 Estimate of Risk for PBNP

NMC's estimates of offsite risk at PBNP are summarized in Section G.2.1. The summary is

followed by the staff's review of NMC's risk estimates in Section G.2.2.

G.2.1 NMC's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the PBNP PRA model, and (2) a supplemental analysis of offsite consequences

and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA

analysis. The SAMA analysis is based on the most recent PRA model available at the time of

the ER, referred to as Revision 3.02. It contains a Level 1 analysis to determine core damage

frequency (CDF) from internally-initiated events and a Level 2 analysis to assess containment

performance during severe accidents. The SAMA analysis is based on the Unit 1 PRA model.

The CDF for Unit 2 is within 5 percent of the Unit 1 CDF; thus, the results based on the Unit 1

model would be applicable to Unit 2 as well. The scope of the PBNP PRA does not include

external events.

The baseline CDF for the purpose of the SAMA evaluation is approximately 3.6 x 10-5 per year,

and is based on the risk assessment for internally-initiated events. Based on the Individual

Plant Examination of External Events (IPEEE) model (WEPCO 1995), seismic events have a

CDF of 1.3 x 1 51 per year, internal fires have a CDF of 5.1 x 1 0.5 per year, and internal flooding

has a CDF of 1.1 x 1i05 per year. In the ER, NMC states that the internal flooding and seismic

analyses have not been updated since the original IPEEE submittal. However, the fire analysis

has been updated once since the IPEEE submittal, and NMC provides the CDF for fire of

1.2 x 10-5 per year versus the IPEEE reported value of 5.1 x 10i5 per year. Other external

events were found to be insignificant contributors to plant risk. NMC did not include the

NUREG-1437, Supplement 23 G-2 August 2005

Il
Appendix G

contribution to risk from external events within the PBNP 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 approximately two. This is discussed

further in Section G.6.2.

The breakdown of CDF by initiating event/accident type is provided in Table G-1. As shown in

this table, steam generator tube rupture (SGTR) events, transients without the Power

Conversion System (PCS) available, loss of Component Cooling Water (CCW), and loss of

offsite power are dominant contributors to the CDF.-

I

I

I

Table G-1. PBNP Core Damage Frequency for Internal Events

Initiating Event

SGTR

Transient without PCS

Loss of component cooling

Loss of offsite power (dual unit)

Steam/feed break inside containment

Loss of service water

Steam/feed break outside containment

Medium loss-of-coolant accident (LOCA) (>2 to 6 in.)

Excessive LOCA (vessel failure)

Transient with PCS

Station blackout (SBO)

Small LOCA (3/8 to 2 in.)

Loss of bus D-01

Loss of instrument air

Large LOCA (>6 in.)

Interfacing systems LOCA (ISLOCA)

Loss of bus D-02

Total CDF (from Internal events)

CDF

(per year)

8.75 x 1i04

6.40 x 106

4.39 x 10-6

4.13 x 1 U 6

2.76 x 1 04

2.43 x 106

1.90 X 1 04

1.80 x 104

9.90 X 10'7

6.84 x 10'7

4.41 x 10'-

3.77 x 10'-

2.76x10'

2.27 x 10i1.39 x 10'7

1.10 x 107

6.74 x 10-8

3.59 x 10-5

* Percent

Contribution

24.4

17.8

12.2

11.5

7.7

6.8

5.3

5.0

2.8

1.9

1.2

1.1

0.8

*0.6

0.4

0.3

0.2

100

I

August 2005 G-3 NUREG-1437, Supplement 23
Appendix G

The Level 2 analysis utilized the containment event tree logic from the IPE and fault tree linking

to combine the Level 1 core damage sequence failures with the Level 2 containment

safeguards systems fault trees. The fault tree linking method was used to resolve

dependencies that occur between the Level 1 core damage sequence failures and containment

safeguards system failures. The combined sequences were then mapped into plant damage

states using the same method employed in the IPE. Only sequences in which the containment

is bypassed or containment isolation has failed were found to have volatile fission product

release fractions greater than 1x10 4. Based on these results, the bypass source term

categories of early SGTR, late SGTR, interfacing systems LOCA (ISLOCA), and containment

isolation failure were defined. An additional category, "other," was defined to represent all other

core melt sequences. The updated fission product release fractions were provided in response

to an RAI (NMC 2004c). Based on analyses using the Modular Accident Analysis Program

(MAAP) computer code, NMC concluded that late containment failures were so low a probability

as to be negligible. Containment leakage was, therefore, the release mechanism considered

for all sequences other than SGTR, containment isolation failure, and ISLOCA.

The offsite consequence and economic impact analysis uses the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for this analysis

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution (within a

80 km [50-mi] radius) for the year 2035, emergency response evacuation modeling, and

economic data.

NMC estimated the dose to the population within 80 km (50 mi) of the PBNP site to be

approximately 0.0149 person-Sv (1.49 person-rem) per year, based on NMC's response to an

RAI (NMC 2004c). This represents a correction to the population dose of 0.0183 person-Sv

(1.83 person-rem) per year reported in the ER. The breakdown of total population dose by

containment release mode is summarized in Table G-2.

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

Population Dose

Containment Release Mode (Person-Rem' Per Year) % Contribution

Late SGTR 1.09 73

Early SGTR 0.165 11

Containment Isolation Failure 8.49x104 <0.1

ISLOCA 0.124 8

Other Core Melt Sequences 0.104 7

Total Population Dose 1.49 100

'One person-Rem = 0.01 person-Sv

l

I

NUREG-1437, Supplement 23 G-4 August 2005

I r
Appendix G

G.2.2 Review of NMC's Risk Estimates

NMC's determination of offsite risk at PBNP is based on the following three major

elements of analysis:

* The PBNP Level 1 and 2 risk models that form the bases for the 1993 IPE submittal

(WEPCO 1993) and 1995 IPEEE submittal (WEPCO 1995).

* Major modifications to the IPE model that have been incorporated in the PBNP PRA, and

* The MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PRA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of NMC's risk estimates for

the SAMA analysis, as summarized below.

The staff's review of the PBNP IPE is described in an NRC report dated January 26,1995

(NRC 1995). In that review, the staff evaluated the methodology, models, data, and

assumptions used to estimate the CDF and characterize containment performance and fission

product releases. The staff concluded that NMC's analysis met the intent of Generic

Letter 88-20 (NRC 1988); that is, the IPE was of adequate quality to be used to look for design

or operational vulnerabilities. The staff, however, encouraged NMC to strengthen the HRA by

improving the pre-initiator event analysis. The staff believed the improved analysis would

increase the usefulness of NMC's PRA in other applications. As described below, the HRA was

subsequently updated.

In response to a staff RAI about changes in the various PRA versions since the IPE, NMC

provided additional details (NMC 2004b). There have been five revisions of the PBNP Level 1

PRA since the IPE was submitted and before the SAMA analysis was completed. A summary

of the differences in these revisions is provided in Table G-3.

The CDF values for PBNP are comparable to the CDF values reported in the IPEs for other

Westinghouse two-loop plants. As reported in NUREG-1 560, the total internal events CDF for

these plants range from approximately 3 x 1 05 per year to 2 x 1 0-4per year.

August 2005 G-5 - NUREG-1437, Supplement 23
Appendix G

Table G-3. Level 1 PRA Summary

Level 1 PRA Summary of Changes from Prior Revision CDF

Revision (per year)

September 1990 Base model for IPE. 1.15 x 10'4

December 1993 Updated model to reflect plant modifications; added operator- 9.74 x 1 5O

(PRA-93) induced auxiliary feedwater system (AFW) failure.

June 1996 Updated plant-specific data; changed Service Water success 5.77 x 105

(PRA-96) criteria; reflected addition of two new diesel generators.

December 1999 Changed logic modeling structure; added provision for 4.39 x 105

(Revision 3.00) alternate electrical feed lineups; updated various system

models and data.

February 2002 Reflected modification to motor driven AFW pumps for 3.78 x 10 5

(Revision 3.01) nitrogen backup supply to mini-recirculation valves.

May 2002 Reflected modification to turbine driven AFW pumps for air 3.59 x 10i5

(Revision 3.02) accumulator backup supply to mini-recirculation valves.

The staff considered the peer reviews performed for the PBNP PRA and the potential impact of

the review findings on the SAMA evaluation. Revision 3.00 of the PRA model was reviewed in

June 2001 by a Westinghouse Owners Group PRA Peer Review Team. The team concluded

that the PRA could be used effectively to support applications involving risk significance

determinations supported by deterministic analyses once the items in its report were

addressed. A major observation was that the thermal hydraulic bases for system and human

action success were largely either conservative design basis analyses or analyses that were not

specific to PBNP. These thermal hydraulic bases date from the original IPE PRA. Other

observations discussed the shortcomings with the basis and documentation of the common

cause failure analysis, a general lack of treatment of miscalibration errors in the model, the

need to complete the HRA update, and the need to complete the documentation of the

remainder of the model.

The SAMA analysis for PBNP is based on Level 1 PRA Revision 3.02. NMC subsequently

updated the PRA to address all of the Significance Level A peer review findings and many of

the Significance Level B findings. The majority of the changes relate to the HRA rather than the

system models. The revised Level 1 PRA is denoted Revision 3.13. While the total CDF did

not change much (3.59 x 10i5 per year in Revision 3.02 to 4.12 x 10 5 per year in Revision 3.13),

NUREG-1437, Supplement 23 G-6 August 2005

I r,
Appendix G

the dominant contributors to the CDF did change more significantly. The most significant

change was a reduction in the importance of the SGTR event and an increase in the

importance of the loss of offsite power (LOOP) and loss of DC power events. The impact of the

PRA update on SAMA identification and evaluation is discussed in Section G.3.2.

Given that (1) the PBNP PRA has been peer reviewed and the potential impact of the peer

review findings on the SAMA evaluation has been assessed, as described above, (2) NMC

satisfactorily addressed staff questions regarding the PRA (NMC 2004b and NMC 2004c), and

(3) the CDF is in the range of contemporary CDFs for Westinghouse two-loop plants, the staff

concludes that the Level 1 PRA model used for the SAMA analysis is of sufficient quality to

support the SAMA evaluation.

NMC submitted an IPEEE by letter dated June 30, 1995 (NMC 1995) in response to

Supplement 4 of Generic Letter 88-20. NMC did not identify any fundamental weaknesses or

vulnerabilities to severe accident risk in regard to the external events related to seismic, fire or

other external events. The NRC provided its review of the PBNP IPEEE in 1999 (NRC 1999).

The staff concluded that the licensee's IPEEE process is capable of identifying the most likely

severe accidents and severe accident vulnerabilities and, therefore, that the PBNP IPEEE met

the intent of Supplement 4 to Generic Letter 88-20.

The IPEEE approach to seismic analysis included extensive seismic walkdowns and

modification of the IPE Level 1 logic models and the IPE Level 2 containment events for

quantification. The dominant contributors to the seismic CDF were failure of cable trays inside

the cable spreading room (62 percent), failure of cable trays outside the cable spreading room

(7 percent), and failure of a surrogate element (16 percent). (The surrogate element

represented the effects of components that were screened out, e.g., soils, buildings/structures,

reactor vessel.) The inside cable spreading room sequences consisted of the seismically

induced failure of cable trays leading to loss of control combined with failure to shut down the

plant remotely. The outside cable spreading room sequences consisted of the seismically

induced failure of cable trays leading to loss of power to all essential equipment. The dominant

contributors to the estimated seismic CDF are operator actions (e.g., failure to shut down the

plant from the remote shutdown panel, failure to provide service water backup to auxiliary

feedwater), seismic faults that lead directly to core damage (e.g., failure of cable trays,

surrogate element), and failures of critical equipment (e.g., transformers, 480 V load centers,

level transmitter for condensate storage tank) (NRC 1999). In response to an RAI, NMC stated

that it has modified cable tray supports, re-anchored the 480 V load centers, and mitigated the

impacts of a 4 kV transformer failure with the addition of a third and fourth diesel generator and

associated switchgear. Other seismic issues have been addressed through changes in

August 2005 G-7 NUREG-1437, Supplement 23
Appendix G

procedures (NMC 2004b). NMC concluded that no further actions to address seismic events

are necessary. The staff notes that it is unlikely that cost-effective SAMAs that address

remaining seismic risk contributors will exist, due to the high cost of structural modifications

compared to the benefits expected and, therefore, agrees that further analyses of potential

SAMAs for seismic events are not warranted.

The IPEEE fire analysis was based on the fire-induced vulnerability evaluation methodology.

This methodology employs a graduated focus on the most important fire zones using qualitative

and quantitative screening criteria. The fire zones were subjected to several screening stages.

In the first stage, a zone was screened out if it did not contain any safety-related equipment. In

the later stages, a CDF of 1 x 10.6 per year was used for screening. The licensee used the IPE

model of internal events to quantify the CDF resulting from a fire initiating event. The

conditional core damage probability was based on the equipment and systems unaffected by

the fire. The CDF for each zone was obtained by multiplying the frequency of a fire in a given

fire zone by the conditional core damage probability associated with that fire zone. The

screening methodology applied by the licensee makes less and less conservative assumptions

(e.g., equipment that may survive the fires in the area) until a fire zone is screened out, the

results do not indicate a vulnerability, or a vulnerability is identified and addressed. Using this

method, the IPEEE fire CDF was estimated to be about 5.1 x 10i5 per year. In the ER, NMC

reported that the fire analysis had been updated, and that the CDF has been reduced from

5.1 x 1 0-5 per year to 1.2 x 10'5 per year.

The staff requested additional information regarding risk reduction measures taken to date for

each significant fire area in the IPEEE fire analysis.

In response, NMC described plant modifications and enhancements to procedures and training

to further reduce fire risk in the significant fire areas. NMC noted that the addition of two

additional diesel generators reduces the fire impact in the gas-fired turbine generator area, the

two diesel rooms (G01 and G02), and the switchgear room. NMC also determined that the

transformer oil thought to be combustible in the IPEEE analysis would not actually be

combustible, thereby reducing the fire risk in the Cable Spreading Room and the Unit 1 and

Unit 2 Electrical Equipment Rooms. NMC identified that the Monitor Tank Room Auxiliary

Operator's Station has a high fire initiating event frequency due to the large number of cables

routed in this compartment and the number of adjacent compartments. Plant personnel are

routinely trained to address fires in this area. NMC concluded that no further modifications

would be cost-beneficial for any of the fire compartments.

NUREG-1437, Supplement 23 G-8 August 2005
Appendix G

The staff notes that additional SAMAs to reduce the fire risk contributors might be viable at

PBNP. However, given that the fire CDF has been reduced by over a factor of four, and that

the plant meets 10 CFR Part 50, Appendix R, fire requirements, it is unlikely that further

modifications would both substantially reduce risk and remain cost-beneficial.

The risk associated with other external events is small. The CDF due to external floods is

about 2.8 x 1 0-6per year and the CDF due to high winds is about 3.4 x 10'7 per year. Other

external events (e.g., transportation and nearby facility accidents) are insignificant risk

contributors based on their low hazard frequencies.- Accordingly, the staff finds NMC's

consideration of external events to be acceptable.

The staff reviewed the process used by NMC to extend the containment performance (Level 2)

portion of the PRA to an assessment of offsite consequences (essentially a Level 3 PRA). This

included consideration of the source terms used to characterize fission product releases for the

applicable containment release category 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 reactor core radionuclide inventory (the reference

core inventory, scaled for the PBNP power level), source terms for each release category,

site-specific meteorological data, projected population distribution within a 80-km (50-mi) radius

for the year 2035, and emergency evacuation modeling. This information is provided in

Appendix F of the ER (NMC 2004a).

Even though NMC used the NRC-approved MACCS2 code and scaled the reference

pressurized-water reactor (PWR) core inventory for PBNP plant-specific power level, the staff

requested that NMC evaluate the impact on population dose if the core inventory were based

on the plant-specific burnup and enrichment. Based on the small impact of the calculated

change in baseline dose (an increase of approximately 10 percent in the total costs associated

with a severe accident), the staff concludes that the scaling based on the plant-specific power

level yields sufficiently accurate and reasonable results for the dose assessment.

NMC characterized the releases for the spectrum of possible radionuclide release scenarios

using a set of 5 release categories, defined based on the timing and magnitude of the release.

These were early SGTR, late SGTR, ISLOCA, containment isolation failure, and other (defined

to bound non-bypass releases). Each end state from the Level 2 analysis is assigned to one of

the release categories. In the ER, NMC states that the source terms used for the SAMA

evaluation are based on the MAAP 4.0.4 computer code for a power level of 1518 MW(t). A

1.4 percent power uprate was subsequently implemented in 2003. In its response to an RAI

(NMC 2004c), NMC also provided a correction to the population dose values reported in the.

August 2005 G-9 NUREG-1437, Supplement 23
. -L_

Appendix G

ER. The correction to population dose is relatively insignificant and does not impact

conclusions of the cost-benefit analyses. The staff concludes that the assignment of release

categories and source terms is consistent with typical PRA practice and acceptable for use in

the SAMA analysis.

NMC used a composite set of site-specific meteorological data, obtained from the plant

meteorological tower, the Kewaunee Nuclear Power Plant (3.6 miles north of PBNP), and the

Sheboygan County Memorial Airport (39 miles south of PBNP). The data were processed from

hourly measurements for the 2000 calendar year as input to the MACCS2 code. Data from

these locations and this year were selected because they provided an adequate representation

of the PBNP meteorological data. The staff notes that previous SAMA analyses results have

shown little sensitivity to year-to-year differences in meteorological data and considers use of

the 2000 data to be reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated

for the year 2035, based on extrapolation from the census for 1990. The 1990 segment

population was obtained by using the SECPOP90 (NRC 1997a) computer program to process

block-level census data. The year 1990 segment data were used with the U.S. Census Bureau

ratio of the county census growth from 1990 to 2000. Next, the Wisconsin county growth rate

data were used to project the 2000 data to the year 2020. Finally, the U.S. Census Bureau

state population projections were used to project the 2020 data to 2035. The staff considers

NMC's methods and assumptions for estimating population reasonable and acceptable for

purposes of the SAMA evaluation.

The emergency evacuation model was modeled as multiple evacuation zones extending out

16 km (10 mi) from the plant. The O0to 2-mile radius was treated as one 180-degree sector. It

was assumed that 100 percent of the population Would move at an average speed of

approximately 0.715 meters per second (1.6 miles per hour) with a delayed start time of

15 minutes (NMC 2004a). The evacuation assumptions and analysis are deemed reasonable

and acceptable for the purposes of the SAMA evaluation.

Much of the site-specific economic data was provided from SECPOP90 (NRC 1997a) by

specifying the data for each of the 11 counties surrounding the plant, to a distance of 80 km

(50 mi). In addition, generic economic data that are applied to the region as a whole were

revised from the MACCS2 sample problem input when better information was available. The

agricultural economic data were updated using available data from the 1997 Census of

Agriculture (USDA 1998). These included per diem living expenses, relocation costs, value of

farm and non-farm wealth, and fraction of farm wealth from improvements (e.g., buildings).

NMC did not perform sensitivity analyses for the MACCS2 parameters, such as evacuation and

population assumptions. However, sensitivity analyses performed as part of previous SAMA

NUREG-1437, Supplement 23 G-10 August 2005

I l
Appendix G

evaluations for other plants have shown that the total benefit of the candidate SAMAs would

increase by less than a factor of 1.2 (typically about 20 percent) due to variations in these

parameters. This change is small and would not alter the outcome of the SAMA analysis.

The staff concludes that the methodology used by NMC to estimate the offsite consequences

for PBNP provides an acceptable basis from which to proceed with an assessment of risk

reduction potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite

risk on the CDF and offsite doses reported by NMC.

G.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by NMC are discussed in this section.

G.3.1 Process for Identifying Potential Plant Improvements

NMC generated a list of SAMA candidates by considering plant-specific enhancements and

reviewing industry and NRC documents that discuss potential plant improvements. Eighteen

sources other than plant-specific sources were identified. Plant-specific sources included basic

events having the greatest risk reduction potential. From these sources, 202 SAMA candidates

were identified. NMC performed an initial qualitative screening based on two criteria:

* The SAMA is not applicable to PBNP (e.g., because the enhancement is only for boilingwater reactors, the Westinghouse AP600'design or PWR ice condenser'containments, or it

is a plant-specific enhancement that does not apply at PBNP)

* The SAMA has already been implemented at PBNP, or the PBNP design meets the intent of'

the SAMA.

Based on this initial screening, 137 SAMA items were eliminated, leaving 65 SAMAs subject to

the final evaluation process.

For the final evaluation, NMC estimated the cost of implementing the SAMA, as described in

Section G.5 below, and the associated potential risk reduction and dollar-equivalent benefit, as

described in Sections G.4 and G.6. If the estimated implementation cost was more than the

estimated benefit (including the multiplier of approximately two to account for not directly

evaluating external events), then the SAMA was not considered to be cost-beneficial.

NMC concluded that there are no SAMA candidates that are cost-beneficial.

August 2005 G-11, NUREG-1437, Supplement 23
Appendix G

G.3.2 Review of NMC's Process

NMC's efforts to identify potential SAMAs focused on areas associated with internal initiating

events. The initial list of SAMAs was based on a range of resources, including generic issues,

and internal PBNP PRA analyses. In the latter case, the PBNP Level 1 PRA Revision 3.02

importance measures were used to identify the most important basic events, with NMC

identifying potential SAMAs that would address these important basic events. The initial list of

SAMAs generally addressed the accident categories that are dominant CDF and containment

failure contributors, or issues that tend to have a large impact on a number of accident

sequences at PBNP.

In order to confirm that the set of SAMAs evaluated in the ER address the dominant risk

contributors, the staff requested that NMC provide a cross reference of the dominant PRA

contributors to the candidate SAMAs. NMC provided these data (NMC 2004b and NMC 2004c),

including a listing of the events with the greatest risk reduction worth importance measure, and

the SAMAs that addressed those risk contributors. This table showed that each of the top

52 risk contributors are addressed by at least one candidate SAMA. Based on this additional

assessment, the staff concludes that the set of SAMAs evaluated in the ER addresses the

major contributors to CDF and offsite dose, and that the review of the top risk contributors does

not reveal any new SAMAs.

The staff questioned NMC about lower-cost alternatives to some of the SAMAs evaluated that

could achieve much of the risk reduction at a lower cost. In its response (NMC 2004b), NMC

stated that it sought low-cost alternatives indirectly, through the identification of plant-specific

risk reduction opportunities identified by the PRA results. Examples include SAMAs 161, 162,

164, and 1 97(a). These SAMAs all impact AFW reliability. One expensive alternative was

SAMA 164, the addition of AFW pump redundancy. SAMA 197 relates to the risk importance of

a check valve in the AFW system. The resultant low-cost option was to review the necessity for

the check valve and, after investigation, a decision was made to remove the check valve

internals.

(a) SAMA 161 - Install manual isolation valves around AFW turbine steam admission valves.

SAMA 162- Install accumulators for turbine driven AFW pump flow control valves. SAMA 164 - Add a

motor train of AFW to the steam trains. SAMA 197 - Reduce likelihood of check valve in recirculation

line from AFW pumps to condensate storage tanks (CSTs) failing to open.

NUREG-1437, Supplement 23 G-12 August 2005

I,
Appendix G

The staff also requested that NMC evaluate several of the SAMAs found to be potentially costbeneficial in recent SAMA reviews for other plants for applicability to PBNP. Twelve such

options were further evaluated by NMC, including:

* Developing procedures for providing temporary ventilation to switchgear and diesel

generator rooms in events involving loss of room cooling

* Adding a capability to flash the field on the emergency diesel generator to enhance SBO

event recovery

* Providing a portable 120 VAC generator with manual clamps to supply power to the steam

generator level instrumentation in SBO events

* Developing procedures to extend the time to refueling water storage tank (RWST) depletion

in SGTR events.

NMC's evaluation of these additional SAMAs is discussed in Section G.6.2.

Since PRA Revision 3.13 was not used in the PBNP SAMA analysis, the staff requested that

NMC assess the impact of the resolution of the peer review findings (see Section G.2.2) on

SAMA identification and evaluation (NRC 2004a). In its response, NMC provided a table of the

changes in the CDF and the major contributors to the CDF relative to Revision 3.02. NMC

stated that these changes would not have had any impact on the set of SAMAs screened from

the cost-benefit analysis, but that it is possible that the operator action to cross-tie 480 VAC

power between buses 1B03 and 1B04 may have become one of the more important human

actions and would have been included in the SAMAs evaluated. While this event might have

been part of the set of operator action SAMAs considered if the screening had been based on

PRA Revision 3.13, NMC reported that the actions taken for the other operator action SAMAs

(i.e., implementation of procedure mark-offs for SAMAs 181 through 193) have also been

implemented for this additional risk-important operator action identified as a result of PRA

Revision 3.13, and no other cost-beneficial action is available (NMC 2004c).

NMC reviewed existing SAMAs relative to loss of power to see if they could become more costbeneficial based on PRA Revision 3.13. Three SAMAs that could be impacted by the PRA

revision were identified (SAMAs 63, 66 and 180). Since two of these SAMAs (SAMAs 63 and

66) affect the plant's response to SBO, which represents only a small portion of LOOP, it isexpected that these SAMAs would still be eliminated in the screening. SAMA 180 deals with

improving the capability for restoring power to the battery chargers following LOOP. NMC

August 2005 G-13 NUREG-1 437, Supplement 23
Appendix G

that the Human Error Probability (HEP) for manually restoring power to the battery chargers

was directly impacted by the HRA update. NMC concluded in its RAI response (NMC 2004b)

that this SAMA would not become cost-beneficial based on PRA Revision 3.13 (see Section

G.6.2 for further discussion of this SAMA).

The 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 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 staff concludes that NMC used a systematic and comprehensive process for identifying

potential plant improvements for PBNP, and that the set of potential plant improvements

identified by NMC is reasonably comprehensive and, therefore, acceptable. This process

included reviewing insights from the IPE and IPEEE and other plant-specific studies, reviewing

plant improvements considered in previous SAMA analyses, and using the knowledge and

experience of its personnel. 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 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

NMC evaluated the risk reduction potential of the 65 SAMAs that were retained from the initial

screening. A majority of the SAMA evaluations were performed in a bounding fashion in that

the SAMA was assumed to completely eliminate the risk associated with the proposed

enhancement. Such bounding calculations overestimate the benefit and are conservative.

NMC used model re-quantification to determine the potential benefits. The CDF and population

dose reductions were estimated using Revision 3.02 of the PBNP PRA. The changes made to

the model to quantify the impact of SAMAs are detailed in Section F.2 of Appendix E to the ER

(NMC 2004a). Table G-4 provides a summary of the assumptions used to estimate the risk

reduction for each of the 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 as

used in the staff's assessment. The determination of the benefits for the various SAMAs is

further discussed in Section G.6.

NMC did not further evaluate the risk reduction benefits for several of the SAMAs because

either the implementation cost was expected to exceed the total present dollar value equivalent

NUREG-1437, Supplement 23 G-14 August 2005
Appendix G

associated with completely eliminating all severe accidents at PBNP (SAMAs 71, 72, 158, 166,

and 176), or the associated initiating event frequency was extremely small and would result in a

benefit far less than the estimated $1 M implementation cost for these alternatives (SAMAs 77

and 78).

The staff has reviewed the bases used by NMC for estimating the risk reduction for the various

SAMAs and concludes that the rationale and assumptions used for estimating risk reduction are

reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the staff based its estimates of averted risk for the

various SAMAs on risk reduction estimates provided by NMC, as discussed in Section G.6.2.

G.5 Cost Impacts of Candidate Plant Improvements

NMC estimated the costs of implementing the 65 candidate SAMAs through the application of

engineering judgment, estimates from other licensee submittals for similar improvements, and

site-specific cost estimates. The cost estimates conservatively did not include the cost of

replacement power during extended outages required to implement the modifications, nor did

they include recurring maintenance and surveillance costs or contingency costs associated with

unforeseen implementation obstacles. Cost estimates typically included procedures,

engineering analysis, training, and documentation, in addition to any hardware.

NMC did not specifically estimate costs for 8 of the 65 SAMAs because:

* Implementation would require plant modifications that would cost significantly more than any

obtainable benefit (SAMAs 47, 108, 158, and 176), or

* Procedure step mark-offs have already been implemented and no further improvement

could be gained by making further changes to procedures or training (SAMAs 151, 181,

190, and 196).

Related to the last reason, in response to an RAI, NMC indicated that these SAMAs have been

implemented at PBNP through the addition of procedure mark-offs (i.e., place-keeping aids) in

the associated operating procedures. These changes were implemented subsequent to the

PRA revision used in the SAMA analysis (Revision 3.02). Therefore, the calculated benefits

reported in the ER represent an over-estimate of the benefits that could be achieved through

further procedure changes. In NMC's view, further improvements to procedures or training to

address these operator actions are not feasible. NMC notes that full automation of each of

these actions could further reduce the CDF; however, full automation would significantly

increase the cost of implementation and would not be cost-beneficial.

August 2005 G-1 5 NUREG-1437, Supplement 23
Appendix G

The ER discussion of cost estimates did not describe how NMC handled the cost of SAMAs for

which the implementation costs are incurred once (i.e., on a "per site" basis) but which provide

benefits for both units. In response to an RAI, NMC identified 27 SAMAs (14 human errorrelated and 13 hardware-related) in which the implementation cost for the SAMA on a per unit

basis could be conservatively assumed to be one-half the value reported in the ER. The staff

adopted these conservative cost estimates for the affected SAMAs.

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 reviewed these estimates and

found them to be consistent with estimates provided in support of other plants' analyses.

It is noted that the estimated implementation cost for SAMA 126, automatic switchover to

recirculation on RWST depletion, is greater than $1.OM, and is significantly higher than the

$265K estimated for the same SAMA in a license renewal SAMA analysis for another plant.

However, in response to an RAI, NMC indicated that a site-specific estimate had been

performed for this SAMA and resulted in an implementation cost estimate of $2.4M per unit

(NMC 2004b). This site-specific cost estimate is considered reasonable given the associated

hardware and engineering-related costs.

The staff concludes that the cost estimates provided by NMC are sufficient and appropriate for

use in the SAMA evaluation.

G.6 Cost-Benefit Comparison

NMC's cost-benefit analysis and the staff's review are described in the following sections.

NUREG-1437, Supplement 23 G-16 August 2005

* i |Ir
Appendix G

G.6.1 NMC Evaluation

The methodology used by NMC was based primarily on NRC's guidance for performing costbenefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis Technical Evaluation Handbook

(NRC 1997b). 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. NMC's derivation of

each of the associated costs is summarized below.

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (A person-rem/year)

x monetary equivalent of unit dose ($2,000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a 7

percent discount rate).

As stated in NUREG/BR-0184 (NRC 1997b); 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

August 2005 G-17 NUREG-1437, Supplement 23
Appendix G

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. NMC calculated an APE of approximately $32,000(a) for

the 20-year license renewal period, which assumes elimination of all severe accidents.

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.

NMC calculated an annual offsite economic risk of about $1,240(b) based on the Level 3 risk

analysis. This results in a discounted value of approximately $13,400 for the 20-year license

renewal period, which assumes all severe accidents are eliminated.

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.

NMC derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC 1 997b). Best estimate values provided

for immediate occupational dose (3,300 person-rem) and long-term occupational

dose (20,000 person-rem over a 10-year cleanup period) were used. The present value

(a) An APE value of $39,308 is reported in the ER based on a population dose of 1.83 person-rem per

year. As described in response to an RAI, the correct population dose is 1.49 person-rem per year.

The corrected APE value corresponding to elimination of severe accidents is approximately $32,000.

The change is insignificant to the results of the SAMA analysis.

(b) An AOC of $27,916 is reported in the ER based on an annual offsite economic risk of $2,594. As

described in response to an RAI, the correct annual offsite economic risk is about $1, 240. The

corrected AOC value corresponding to complete elimination of severe accidents is approximately

$13,400. The change is insignificant to the results of the SAMA analysis.

NUREG-1437, Supplement 23 G-18 August 2005

IlI
Appendix G

of these doses was calculated using the equations provided in the handbook in conjunction with

a monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of

7 percentia', and a time period of 20 years to represent the license renewal period. NMC

calculated an AOE of approximately $13,700'for the 20-year license renewal period, which

assumes all severe accidents are eliminated.

Averted Onsite Costs (AOSC)

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. -NMC derived the values for AOSC based on

information provided in Section 5.7.6 of the regulatory analysis handbook (NRC 1997b).

NMC divided this cost element into two parts - 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

the regulatory analysis handbook to be $1.5 x'10 (undiscounted). This'value was converted to

present costs over a 10-year cleanup period and integrated over the term of the proposed

license extension. NMC's calculation of ACC, which assumes all severe accidents are

eliminated, is approximately $416,000 for the 20-year license renewal period.

(a) NRC policy for the preparation and the contents of regulatory analyses is set forth in

NUREGIBR-0058, 'Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission."

Revision 3 of NUREG/BR-0058 (NRC 2000), which was in place at the time the NMC ER was

submitted, specifies the use of a 7 percent real discount rate in the base case, and the use of a 3

percent real discount rate for sensitivity purposes. Revision 4 of NUREG/BR-0058 (NRC 2004) was

issued after NMC submitted the ER, and states that two sets of base case estimates should be

developed, one at 3 percent and one at 7 percent. Since this'revision was released after NMC

completed and submitted its analysis, the results for a 3 percent discount rate are not specifically

reported in this report. However, NMC did provide the 3 percent results as part of its sensitivity

analysis of SAMAs.

August 2005 G-19 NUREG-1437, Supplement 23
Appendix G

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

NMC based its calculations on the value of 564 MW(e). Therefore, NMC applied a power

scaling factor of 564 MW(e)/91 0 MW(e) to determine the replacement power costs. NIMC's

calculation of RPC, which assumes all severe accidents are eliminated, is approximately

$176,000 for the 20-year license renewal period.

NMC calculated an AOSC of approximately $592,000 for the 20-year license renewal period,

which assumes all severe accidents are eliminated.

Using the above equations, NMC estimated the total present dollar value equivalent associated

with completely eliminating all severe accidents at PBNP to be about $651,000(a).

NMC's Results

Total benefits associated with each of the 65 SAMAs were evaluated by NMC. These values

were determined based on the above equations for the various averted costs, together with the

estimated annual reductions in CDF and population dose for each SAMA. In order to account

for the contribution of external events, NMC increased the estimated benefits for internal events

by a factor of approximately two. As a result, all SAMAs that were evaluated were eliminated

because the cost was expected to exceed the estimated benefit. The cost-benefit results for

the individual analysis of the 65 SAMA candidates are presented in Table G-4 and include the

multiplying factor to account for external events. If the calculated cost of implementation of the

SAMA is greater than the calculated benefit, the SAMA would not be considered cost-beneficial.

Based on these results, NMC identified no cost-beneficial SAMAs.

(a) A total present dollar value equivalent of $673,000 is reported in the ER. Based on corrections to the

annual population dose and annual offsite economic risk described in an RAI response, the corrected

total present dollar value equivalent associated with eliminating all severe accidents is approximately

$651,000. The change is insignificant to the results of the SAMA analysis.

NUREG-1437, Supplement 23 G-20 August 2005

l 1
z

C

71

m

CA)

-,4

CD

3

to

r,3

C)

0

0T

Table G-4. SAMA Cost/Benefit Screening Analysis V1

Percent Risk Reduction

Population Total Benefit, Estimated Cost

SAMA Assumptions COF Dose (S) (S)

4. Install tornado protection on gas turbine generator to Eliminated tomado-induced LOOP. 14 1 $181,200 >$500,0002

reduce tomado-Induced SBO.

32. Install MG set trip breakers in control room to reduce Eliminated all ATWS events. 2 0 $29,000 >$100,000

anticipated transient without scram (ATWS) CDF.

45. Procedural guidance for use of cross-tied CCW or Eliminated all small LOCA events, 1 0 $13,000 >$30,000

service water (SW) pumps. Reduces the frequency of including reactor coolant pump

loss of either system. (RCP) seal LOCA.

47. Provide self-cooled emergency core cooling system Eliminated the cooling requirement < 1 0 $0 > benefit

(ECCS) seals. Reduces failure frequency of ECCS for ECCS pump seals.

pumps currently cooled by CCW.

48. Provide centrifugal charging pump. Current charging Eliminated the common cause failure < 1 0 $300 >$500,000

pumps are positive displacement pumps. of the charging pumps.

50. Install a containment vent large enough to remove Eliminated all ATWS events. 2 0 $29,000 >$5,000,000

ATWS decay heat. Assuming injection Is available,

reduces likelihood of decay heat removal failure in

ATWS.

52. Add redundant and diverse limit switch to each Eliminated all Isolation failures. < 1 0 $200 >S50,000 per

containment isolation valve. Enhances isolation valve valve

position indication, reducing frequency of containment

isolation failure and ISLOCAS.

53. Self-actuating containment isolation valves. Reduces Eliminated all isolation failures. < I 0 $200 >$100,000

likelihood of isolation failure.

54. Provide containment Isolation design per General Eliminated all isolation failures. < 1 0 $200 >$100,000

Design Criteria and Standard Review Plan. Reduces

likelihood of isolation failure.

55. Add penetration valve leakage control system. Eliminated all isolation failures. 1 0 $200 >$100,000

Enhance capability to detect/control leakage from

penetration valves.

LO

C)
a

a:)

a

SAMA

Un 62. Provide additional DC battery capability during SBO,

reducing frequencies of long term SBO sequences.

63. Use fuel cells Instead of lead-acid batteries to extend

DC power availability in SBO.

66. Replace batteries to improve DC power reliability.

71. Install a filtered containment vent to remove decay

heat.

72. Install an unfiltered hardened containment vent.

77. Prevent tornado damage to RWST.

78. Protection for tanks or switchgear in Turbine Building

from tornados.

89. Upgrade feedwater digital control to reduce likelihood of

main feedwater (MFW) loss following plant trip.

93. Provide Auxiliary building Vent/Seal structure to

enhance building ventilation.

96. Install pressure or leak monitoring instruments between

Z first two pressure isolation valves on low-pressure

:D injection, residual heat removal (RHR) suction, and high

j) pressure injection lines to reduce ISLOCA frequency.

4 97. Increase frequency of valve leak testing to decrease

-.4 ISLOCA frequency.

n 98. Improve operator training on ISLOCA coping to

' decrease ISLOCA Impact. ID

3 100. Revise emergency operating procedures (EOPs) to

improve ISLOCA identification to ensures LOCA

Pa outside containment would be observed. c;A)

Assumptions

Eliminated all station blackout

events.

Eliminated all LOOP events.

Eliminated all LOOP events.

Not evaluated due to high cost.

Not evaluated due to high cost.

Not evaluated due to extremely

small initiating event frequency.

Not evaluated due to extremely

small initiating event frequency.

Eliminated all transients with loss of

power conversion system.

Eliminated all ISLOCA events.

Eliminated all ISLOCA events.

Eliminated all ISLOCA events.

Eliminated all ISLOCA events.

Eliminated all ISLOCA events.

-

Percent Risk Reduction

Population

CDF Dose

1 0

14 1

14 1

Not Not

evaluated evaluated

Not Not

evaluated evaluated

Not Not

evaluated evaluated

Not Not

evaluated evaluated

4 0

<1 0

< I 0

Total Benef It'

($)

$15,100

$181,200

$181,200

Not evaluated

Not evaluated

Not evaluated

Not evaluated

$52,300

$13,600

$13,600

$13,600

$13,600

$13,600

Estimated Cost

(5)

$75,000'

>$1 000,000

>$500,000

>$20,000.000

>$5,000,000

>$1 ,000,000

>S1,000,000

>$250,000

>$100,0002

>50,000 per line

>S100,000

>$25,0002

>S15,0002

-

I1 

1 I

1 I

0

0

0

:0

CD

C)
z

C

M

C.,

h-o

CA)

Percent Risk Reduction

Population Total Benefit' Estimated Cost

SAMA Assumptions CDF Dose (S) (S)

101. Ensure all ISLOCA releases are scrubbed (e.g., plug Eliminated all ISLOCA events. <1 0 $13,600 >S100,000

drains in the break area so the breakpoint would cover

with water).

102. Secondary side guard pipes up to main steam isolation Eliminated all steam line break 13 1 $170,800 >$1,000,000

valves (MSIVs) to prevents secondary side events.

depressurization should a steam line break occur

upstream of the MSIVs. Would also guard against or

prevent consequential multiple SGTRs following a main

steam line break.

103. Upgrade large break LOCA instrumentation to identify Eliminated all large break LOCA 1 0 $4,800 >$100,000

symptoms/precursors (leak before break) to reduce events.

likelihood of large break LOCA.-

108. Improve SGTR coping abilities by improving Eliminated all SGTR events. 29 79 $565,000 >>benefit

instrumentation to detect SGTR, or additional systems

to'scrub fission product releases to reduce

consequences of SGTR.

119. Independent reactor coolant pump (RCP) seal injection Eliminated small LOCA events, 1 0 $13,000 >$500,0002

with dedicated diesel adds redundancy to RCP seal Including RCP seal LOCA.

cooling, reducing CDF from loss of CCW, SW, or SBO.

126. Automatic switchover to recirculation on RWST Eliminated human error of failure to 30 48 $531,400 >$2,400,000 per

depletion. switchover to recirculation on RWST unit

depletion.

127. Improve RHR sump reliability by eliminating debris in Eliminated failure due to sump 1 0 $1,100 >$100,000

sump as common mode failure. clogging.

130. Upgrade chemical and volume control system to Eliminated small LOCA events, 1 0 $13,000 >$1,000,000

decrease CDF due to small LOCAs. including RCP seal LOCA.

137. Install additional high pressure Injection pump with Perfectly reliable safety injection < 1 0 $4,100 >$500,0002

Independent diesel. pumps.

'a

CD

G)

a

co

C

C')

0

0

L,
C

co

C

N)

0

0

rU

G)

O

A.

C,, C4

:qco

iD

CD3

Percent Risk Reduction

Population Total Benefit' Estimated Cost

SAMA Assumptions CDF Dose ($) ($)

138. Install independent AC high pressure injection system Perfectly reliable safety injection <1 0 $4,100 >500,000O

to provide make-up and feed and bleed capabilities pumps.

during SBO.

140. Prevent charging pump flow diversion from the relief Eliminated small LOCA events, 1 0 $13,000 >S50.000

valves to reduce frequency of loss of RCP cooling. including RCP seal LOCA.

142. Use firewater pumps as a backup seal injection and Eliminated small LOCA events, 1 0 $13,000 >$500,000O

high-pressure makeup to reduce RCP seal LOCA including RCP seal LOCA.

frequency and SBO core damage frequency.

148. Install nitrogen bottles as backup gas supply for safety Removed the air supply dependency <1 0 $0 >$50,0002

relief valves (SRVs) to extend operation of SRVs during to the power operated relief valves.

SBO.

149. Install redundant spray system to depressurize primary Eliminated all human errors related 17 52 $305,800 >$1.000,000

system during SGTR to enhanced depressurization to depressurization.

ability during SGTR.

150. Create/enhance reactor coolant system (RCS) Eliminated all human errors related 17 52 $305,800 >$1.000.000

depressurization ability. Low RCS pressure alleviates to depressurization.

some concerns about high-pressure melt ejection.

151. Make procedural changes only for the RCS Eliminated all human errors related 17 52 $305,800 No relevant HEP

depressurization option to reduce RCS pressure without to depressurization. improvement

cost of new system. found.'

153. Relief valve system to prevent equipment damage from Eliminated all ATWS events. 2 0 $29,000 >1 ,000,000

pressure spike during ATWS.

154. Consider other SGTR features: Eliminated all SGTR events. 29 79 $565,000 >S10000,000

a. Highly reliable (closed loop) steam generator shellside heat removal system

b. System that returns the discharge from steam

generator relief back to the primary containment

c. Increased pressure capability on the steam

generator shell-side corresponding Increase in safety

valve setpoints.

-c

CD

Q.

G)

_
z

C

M

S.

OA

-.4

CA

:04

(n.

CD

CD~

Percent Risk Reduction

Population Total Benefit, Estimated Cost

SAMA Assumptions CDF Dose (S) (S)

'a

CD

X

G) 155. Increase secondary side pressure capacity such that a

SGTR would not cause relief valves to lift eliminating

pathway to release from SGTR.

157. Revise maintenance practice to inspect 100 percent of

tubes In steam generator to reduce frequency of SGTR.

158. Create passive secondary side coolers that passively

removes heat. Would reduce CDF from loss of

feedwater.

165. Perform surveillance on manual valves used for

backup AFW pump suction (firewater system).

Eliminated all SGTR events.

Eliminated all SGTR events.

Not evaluated as design and

Installation at an existing plant is not

feasible.

29

29

79

70

$565,000 >$100,000,000

$565,000 $5,000,000'

Not Not

evaluated evaluated

Not evaluated Not evaluated

166. Either replace old CST with larger tank, or install a

backup to increase AFW system reliability.

Gi 169. Provide portable generators to be hooked up to turbine

!` 3 driven AFW after battery depletion.

1n . Relae.. re ..o v . . . . sr g .

176. Replace reactor vessel with stronger vessel. I

Eliminated failure of firewater valves

to open.

Not evaluated due to excessive cost.

Removed the dependency of AFW

on DC power.

Not evaluated due to excessive cost

of implementing on existing plant.

Eliminated all SW pump failures.

Always successful reloading battery

chargers.

0 $0 >$1 0,000

Not Not

evaluated evaluated

Not evaluated >$500,0002

8 0 $98,400

Not evaluated

>$100,0002

Not Not Not evaluated.

evaluated evaluated

177. Provide additional SW pump to reduce likelihood of SW

system failure.

180. Provide automatic re-powering of battery chargers

following a loss of offslte power event..

181. Provide procedural improvements and training to

improve operator performance for feed and bleed

cooling without safety injection (SI).

184. Provide procedural Improvements and training to

improve operator performance for manually contrining

AFW after loss of instrument air.

<1

9

0

1

$6,600

$120,400

>$2,500,0002

>$200.000 '

Reduced operator error likelihood in

related scenarios by a factor of 3.

Reduced operator error likelihood in

related scenarios by a factor of 3.

8

2

0

0

$102, 500 Not evaluated:

Procedure step

mark-off

implemented

after PRA 3.02

and considered

adequate.

aC

CoCl

0

0

01

$23,100 >$15,0002

Implementation

same as 181
C

coC

0

An

G)

CD

0)

z

C:

m

G)

P.)

-4

t)C

'O

'a

3

CA3

Percent Risk Reduction

Population Total Benefit, Estimated Cost

SAMA Assumptions CDF Dose (S) (S)

185. Provide procedural improvements and training to Reduced operator error likelihood in 13 7 $178,500 >$15,0002

improve operator performance for providing alternate related scenarios by a factor of 3. Implementation

water source for AFW following low CST level. same as 181

186. Provide procedural improvements and training to Reduced operator error likelihood in 2 0 $22,500 >$15,0002

improve operator performance for manually starting gas related scenarios by a factor of 3. Implementation

turbine generator. same as 181

187. Provide procedural improvements and training to Reduced operator error likelihood in 7 0 $82,900 >$15.0002

improve operator performance for opening valve for related scenarios by a factor of 3. Implementation

RWST charging. same as 181

188. Provide procedural improvements and training to Reduced operator error likelihood in >$15,0002

improve operator performance for the task of related scenarios by a factor of 3. 2 2 $36,900 Implementation

diagnosing SGTR same as 181

189. Provide procedural improvements and training to Reduced operator error likelihood in 2 0 $25,500 >$15.0002

improve operator performance for feed and bleed related scenarios by a factor of 3. Implementation

cooling with SI same as 181

190. Provide procedural improvements and training to Reduced operator error likelihood in 2 0 $19,200 Not determined.

improve operator performance for isolating service related scenarios by a factor of 3. Implementation

water header. same as 181

191. Provide procedural improvements and training to Reduced operator error likelihood in 1 5 $23,100 >$15,0002

improve operator performance for opening instrument related scenarios by a factor of 3. Implementation

air valves to containment. This item and #193 are an same as 181

action/recovery pair

192. Provide procedural improvements and training to Reduced operator error likelihood in 1 4 $22,500 >$15,O02

improve operator performance for opening instrument related scenarios by a factor of 3. Implementation

air valves to containment. same as 181

193. Provide procedural improvements and training to Reduced operator error likelihood in 2 7 $26,500 >$15,0002

improve operator performance for opening SW valve related scenarios by a factor of 3. Implementation

following a SI signal. same as 181

195. Improve running reliability of motor driven AFW pumps. Motor driven AFW pumps perfect 2 7 $159,700 >$500,0002

while running.

-0

'.CD

CL

x

G)
Z

C

m

C)

-P6

CA

CD

Percent Risk Reduction >

Population Total Benefit' Estimated Cost (D

SAMA Assumptions CDF Dose (S) (S) x

196. Reduce likelihood of RHR full flow test lines being left Reduce operator error likelihood by a 4 4 $49,900 Not evaluated$. 0

open. factor of 3 in related scenarios.

197. Improve reliability of check valve In AFW recirculation Check valve failure probability equal 1 1 $18,300 >$1 1,0002

line to CSTs. to zero. Implemented by

removal of

check valve

intemals.

199. Improve reliability of power supply to Bus 1B03 Bus is perfectly reliable. 4 0 $49.400 >$300.000.

Table Notes:

1. Benefit values are based on NMC's estimated benefits and Include a multiplier of approximately 2 to account for additional benefits in external

events.

2. Cost reported in ER has been reduced by a factor of two to account for shared cost between Unit 1 and Unit 2, per NMC response to an RAI

(NMC 2004b).

C 3. Revised value provided by an RAI response (NMC 2004c).

M 4. Procedure step'mark-offs have been implemented. NMC was not able to identify any further improvement that would substantially reduce the

HEP for this accident.

5. The probability for this pre-initiator human error used in PRA Revision 3.02 was a screening value of 1X10 3. Because there were actually two

valves in series In these lines that are both independently verified and locked closed, both would need to be left open for this event to become

important. A more correct value of 6.4x10,6 essentially eliminates this event from further consideration.

6. Value based on an estimated cost of $500,000 per outage (NMC 2004a) for 10 outages.

I

(am

C

Cn 0

0

01
Appendix G

G.6.2 Review of NMC's Cost-Benefit Evaluation

The cost-benefit analysis performed by NMC was based primarily on NUREG/BR-01 84

(NRC1 997b) and was conducted in a manner consistent with this guidance.

In order to account for external events, NMC multiplied each SAMA benefit by an amount equal

to the ratio of the sum of the internal and external event CDF to the internal event CDF. This

ratio is approximately two. Given that the CDF from internal fires, seismic events, and internal

flooding as reported by NMC (NMC 2004a) is approximately the same as the CDF for internal

events, the staff agrees that the use of this multiplier was appropriate for NMC's cost-benefit

analyses.

Fifteen of the final list of 65 SAMAs involve improvements to plant procedures and/or operator

training to improve operator performance. Several of these SAMAs appear to be cost-beneficial

(or very close to cost-beneficial) in the baseline analysis, specifically, SAMAs 181, 184-193, and

197. One of the factors that contribute to the positive cost-benefit for these SAMAs is the

assumption that the implementation costs would be incurred at one unit, but would benefit the

second unit at no additional cost. In response to an RAI, NMC indicated that these SAMAs

have been implemented at PBNP through the addition of procedure mark-offs (i.e., placekeeping aids) in the associated operating procedures. These changes were implemented

subsequent to the PRA revision used in the SAMA analysis (Revision 3.02). The use of such

mark-offs improves the overall performance of the operator by maintaining a positive indication

of the operator's location in the procedure, eliminating the need for the operator to locate his

position by reviewing previously completed steps. In NMC's view, further improvements to

procedures or training to address these operator actions are not feasible. NMC notes that

these actions are still very important to plant risk and that degradation of operator performance

on these actions must be avoided. NMC notes that full automation of each of these actions

could further reduce the CDF; however, full automation would significantly increase the cost of

implementation and would not be cost-beneficial. The staff agrees that for these operator

actions, the potential for further, significant risk reduction through additional procedure and

training enhancements is limited due to the implementation of the procedure mark-offs, and that

hardware alternatives are not likely to be cost-beneficial.

SAMA 197, improve reliability of check valve in AFW recirculation line to CSTs, also is

potentially cost-beneficial in the baseline analysis. In response to an RAI, NMC indicated that

this SAMA has effectively been implemented at PBNP. A low-cost approach was taken to

eliminate AFW system check valve failures by removing the check valve internals rather than

the entire check valve. The staff agrees with NMC that this modification essentially eliminates

the risk of these failures.

NUREG-1437, Supplement 23 G-28 August 2005
Appendix G

In response to a staff request, NMC also evaluated several of the SAMAs found to be

potentially cost-beneficial in recent SAMA reviews for other plants. Twelve such options were

evaluated by NMC, including:

* Developing procedures for providing temporary ventilation to switchgear and diesel

generator rooms in events involving loss of room cooling

* Adding a capability to flash the field on the emergency diesel generator to enhance SBO

event recovery

* Providing a portable 120 VAC generator with manual clamps to supply power to the steam

generator level instrumentation in SBO events

* Developing procedures to extend the time to RWST depletion in SGTR events.

All but two of these alternatives were determined to be either not applicable to PBNP or already

implemented at PBNP. The remaining two alternatives (adding a capability to flash the field on

the emergency diesel generator to enhance SBO event recovery, and providing a portable

120 VAC generator with manual clamps to supply power to the steam generator level

instrumentation in SBO events) were each estimated to have a benefit of approximately $5,000

and an implementation cost of greater than $30,000 for the PBNP site. On the basis of this

evaluation, NMC concluded that none of the additional SAMAs would be cost-beneficial for

PBNP.

Based on its review of NMC's SAMA evaluation, the staff concluded in the draft SEIS that two

SAMAs could be cost-beneficial when uncertainties, alternative discount rates, or broader

implementation options were taken into account. Specifically, these two SAMAs are a lower

cost alternative to SAMA 126, automatic switchover to recirculation on RWST depletion, and

SAMA 169, provide a portable generator to power the AFW turbine after battery depletion.

These SAMAs are discussed further below.

The staff concluded that SAMA 126, automatic switchover to recirculation on RWST depletion,

is not cost-beneficial, but that a less extensive modification involving only addition of an

automatic pump trip on low RWST level could be cost-beneficial. This alternative SAMA would

reduce a portion of the risk associated with failures of switchover by tripping the pumps prior to

failures due to low net positive suction head or cavitation. This would provide additional time for

operators to complete the manual switchover. As- noted in the draft SEIS, the alternative

modification would still involve costs for the engineering, hardware, and training associated with

changes'to safety-related systems and components, and there would still be potential for

operator error in performing the actual switchover.

August 2005 G-29- NUREG-1437, Supplement 23
Appendix G

Subsequent to the draft SEIS, NMC provided additional information regarding the costs

associated with installing an automatic pump trip on low RWST level at PBNP (NMC 2005).

NMC estimates that the costs would approach $1 M, and would include adding a third channel of

level instruments to provide for the required 2 out of 3 logic, re-routing cables to avoid certain

fire-vulnerable areas, and preparing a license amendment regarding the new pump trip. NMC

also noted that the HEP associated with switchover to recirculation does not include the action

to trip pumps as a critical action because there is so much time available to complete the

action. Accordingly, the HEP would not be substantially reduced by addition of an automatic

trip function. Based on the additional information provided by NMC, the staff concludes that the

addition of an automatic pump trip is not likely to be cost-beneficial at PBNP given its

substantial implementation costs and limited benefits.

For SAMA 169 (provide a portable generator to power the AFW turbine after battery depletion),

the benefit is estimated to be $98,400 and the cost is estimated to be greater than $100,000

(which accounts for the fact that the cost is shared between the two PBNP units). Based on

cost estimates developed previously for similar modifications at another plant, the staff

estimates that the costs associated with providing a portable generator would be approximately

$100,000 to $200,000 per unit(a). Also, the fact that when either uncertainty in the CDF mean (a

factor of two between the mean and the 95h percentile) or a lower discount rate are considered,

the SAMA could have a positive net value (e.g., a 3 percent discount rate changes the benefit

to $178,000). Therefore, the staff concludes that this SAMA could be cost-beneficial if

uncertainties or alternative discount rates were taken into account.

In response to an RAI, NMC considered the uncertainties associated with the internal event

CDF and the impact of uncertainties on the SAMA analysis results. Information regarding the

uncertainty distribution of the internal events CDF is summarized in Table G-5 (NMC 2004b).

The 95h percent confidence level for internal events CDF is approximately 2.0 times the best

estimate CDF. If the 95t percentile values of the CDF were used in the cost-benefit analysis

instead of the mean CDF value used in the baseline analysis, the estimated benefits of the

SAMAs would increase by about a factor of two in addition to the multiplier already included in

the baseline benefit estimates to account for external events (NMC 2004a).

(a) The cost associated with providing a portable generator to provide power to steam generator level

instrumentation was estimated at less than $100,000 per unit in the SAMA evaluation for another

plant. The cost to provide a portable generator for backup power to hydrogen igniters was estimated

as $200,000 per unit as part of the resolution of Generic Safety Issue 189, "Susceptibility of Ice

Condenser and Mark IlIl Containments to Early Failure From Hydrogen Combustion During a Severe

Accident" (NRC 2002).

NUREG-1437, Supplement 23 G-30 August 2005

. i I r
Appendix G

Table G-5. Uncertainty in the Calculated CDF for PBNP

Percentile CDF (per year)

5th 1.58 x 1 0-5

50m 3.09 x 10-5

mean 3.62 x 10-5

95k' 7.21 x 10-5

Based on information provided in the ER, three additional SAMAs (98, 100, and 180) also

appear to be potentially cost-beneficial based on the upper bound benefit. However, in

response to an RAI, NMC provided sufficient justification to show that the modeling

assumptions used to calculate the benefit for these three SAMAs were extremely conservative,

i.e, the SAMAs were assumed to completely eliminate the affected sequences or human errors

(NMC 2004b). Further, NMC stated that the HEP for the human error event (SAMA 180)

changed from 4.2 x 103 to 2.1 x 10-3 in PRA Revision 3.13, reducing the importance of this

SAMA from the original estimates in the ER. The staff concludes that, based on more realistic

risk reduction estimates, these SAMAs would not be cost-beneficial.

NMC also performed a sensitivity analysis that addressed variations in discount rate. The use

of a three-percent real discount rate (rather that seven percent used in the baseline) results in

an increase in the SAMA benefits of approximately 75 percent. The results of the sensitivity

study are bounded by the uncertainty assessment, which considered an increase of a factor of

two.

NMC assessed the impact of other factors on the analysis results, such as the use of a plantspecific core fission product inventory and substantially (100 percent) higher offsite doses and

economic impacts. The staff notes that accounting for each of these factors would tend to

increase the benefit as compared to the baseline case analysis. However, the impact on the"

SAMA benefits is small and more than offset by the conservatisms in the risk reduction and

cost estimates assumed in the baseline analysis.

The staff concludes that, with the exception of the one SAMA noted above, the costs of all of

the SAMAs assessed would be higher than the associated benefits.

G.7 Conclusions -

NMC compiled a list of 202 SAMA candidates using NRC and industry documents discussing

potential plant improvements, and insights from the IPE, IPEEE and current PRA. A qualitative

screening removed candidates that (1) were not applicable to PBNP due to design differences

August 2005. G-31 NUREG-1437, Supplement 23
Appendix G

or (2) had already been implemented at PBNP. A total of 137 SAMA candidates were

eliminated based on these criteria, leaving 65 SAMA candidates for further evaluation.

Using guidance in NUREG/BR-0184 (NRC 1997b), the current PRA model, and a Level 3

analysis developed specifically for SAMA evaluation, a maximum attainable benefit of about

$651,000, representing the total present dollar value equivalent associated with completely

eliminating severe accidents at PBNP, was derived. For the 65 remaining SAMA candidates, a

more detailed assessment and cost estimate were developed. To account for external events,

NMC increased the estimated benefits for internal events by a factor of approximately two

before comparing to the cost estimate. NMC concluded in the ER that none of the SAMAs

evaluated would be cost-beneficial for PBNP because their implementation costs would exceed

their estimated benefits.

The staff reviewed the NMC analysis and concluded that the methods used and the

implementation of those methods were sound. The unavailability of a seismic and fire PRA

model precluded a detailed quantitative evaluation of SAMAs specifically aimed at reducing risk

of these initiators. However, improvements have been realized as a result of the IPEEE

process at PBNP that would minimize the likelihood of identifying further cost-beneficial

enhancements in these areas, and NMC accounted for the potential impact of external events

by increasing the estimated benefits for internally-initiated events by a factor of approximately

two.

Although none of the SAMAs appear cost-beneficial in the baseline analysis, one SAMA could

become cost-beneficial when uncertainties or alternative discount rates are taken into account.

This SAMA involves providing a portable generator to power the AFW turbine after battery

depletion (SAMA 169). Based on the small difference between the cost and benefit of

SAMA 169, and considering the uncertainty in the PRA together with the possibility of a lower

discount rate (3 percent versus 7 percent, as used in the baseline analysis), the staff concludes

that SAMA 169 could be cost-beneficial.

Based on its review of the NMC SAMA analysis, the staff concurs that none of the candidate

SAMAs are cost-beneficial, except as noted above. This is based on conservative treatment of

cost and benefits. This conclusion is consistent with the low residual level of risk indicated in

the PBNP PRA and the fact that PBNP has already implemented all of the plant improvements

identified from the IPE and IPEEE process. The staff did conclude that SAMA 169 could be

cost-beneficial when uncertainties or alternative discount rates are taken into account.

However, this SAMA does not relate to adequately managing the effects of aging during the

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

pursuant to 10 CFR Part 54.

NUREG-1437, Supplement 23 G-32 August 2005

1 I1 1 II II
Appendix G

G.8 References

Wisconsin Electric Power Company (WEPCO). 1993. Letter from Bob Link, to Document

Control Desk, Subject: Generic Letter 88-20 (TAC NOS. 74452 and 74453) "Summary Report

on Individual Plant Examination for Severe Accident Vulnerabilities, Point Beach Nuclear Plant,

Units 1 and 2", dated June 30, 1993.

Wisconsin'Electric Power Company (WEPCO). 1995. Letter from Bob Link, to Document

Control Desk, Subject: Generic Letter 88-20 (TAC NOS. 74452 and 74453) "Summary Report

Examination of External Events for Severe Accident Vulnerabilities Point Beach Nuclear Plant,

Units 1 and 2", June 30, 1995.

Nuclear Management Company, LLC. (NMC). 2004a. Point Beach Nuclear Plant Operating

License Renewal Application Environmental Report. Two Rivers, Wisconsin.

Nuclear Management Company, LLC (NMC). 2004b. Response to Request for Additional

Information Regarding the Point Beach Nuclear Plant License Renewal Application (TAC Nos.

MC2099 and MC2100), Two Rivers, Wisconsin. August 31, 2004.

Nuclear Management Company, LLC (NMC). 2004c. Follow-up Response to Request for

Additional Information Regarding the Point Beach Nuclear Plant License Renewal Application

(TAC Nos. MC2099 and MC2100), Two Rivers, Wisconsin. November 22, 2004.

Nuclear Management Company, LLC (NMC). 2005. Email correspondence from J. Knorr to

S. Imboden, NRC, regarding cost of pump trip on low RWST level. June 14, 2005.

Chanin, D. I., et al, 1997. Code Manual for MACCS2: Volume 1, User's Guide, Sandia National

Laboratory, SAND97-054, March 1997.

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, national

Agriculture Statistics Service, 1998., Available online at:

http://www.nass.usda.gov/census97/volumel /voll pubs.htm.

U.S. Nuclear Regulatory Commission (NRC). 1990. NUREG/CR-5575, Quantitative Analysis

of Potential Performance Improvements for the Dry PWR Containment, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. NUREG/CR-5630, PWR Dry Containment

Parametric Studies, Washington, D.C.

August 2005 G-33 NUREG-1437, Supplement 23
Appendix G

U.S. Nuclear Regulatory Commission (NRC). 1995. "Review of Individual Plant Examination

Submittal for Internal Events - Point Beach Nuclear Plant, Units 1 and 2," (TAC Nos. M74452

and M74453)," Washington, D.C., January 26, 1995.

U.S. Nuclear Regulatory Commission (NRC). 1997a. NUREG/CR-6525, SECPOP90: Sector

Population, Land Fraction, and Economic Estimation Program, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. NUREG/BR-0184, Regulatory Analysis

Technical Evaluation Handbook, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. "Point Beach Nuclear Plant, Units 1 and 2

Review of Individual Plant Examination of External Events (IPEEE) Submittal (TAC Nos.

M83661 and M83662)," Washington, D.C., September 15, 1999.

U.S. Nuclear Regulatory Commission (NRC). 2000. NUREG/BR-0058, Regulatory Analysis

Guidelines of the U.S. Nuclear Regulatory Commission, Revision 3, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2002. Memorandum from Ashok C. Thadani,

RES, to Samuel J. Collins, NRR, Subject: RES Proposed Recommendations for Resolving

Generic Safety issue 189: "Susceptibility of Ice Condenser and Mark IlIl Containments to Early

Failure from Hydrogen Combustion During a Severe Accident," Washington, D.C., December

17, 2002.

U.S. Nuclear Regulatory Commission (NRC). 2004a. Letter from Stacey Imboden, NRC, to

Dennis L. Koehl, NMC, Subject: Request for Additional Information (RAI) Regarding Severe

Accident Mitigation Alternatives for Point Beach Nuclear Plant, Units 1 and 2, (TAC NOS.

MC2049 and MC2050), Washington, D.C., July 2, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004b. Letter from Stacey Imboden, NRC, to

Dennis L. Koehl, NMC, Subject: Request for Additional Information (RAI) Regarding Severe

Accident Mitigation Alternatives for Point Beach Nuclear Plant, Units 1 and 2, (TAC NOS.

MC2049 and MC2050), Washington, D.C., October 20, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004. NUREG/BR-0058, Regulatory Analysis

Guidelines of the U.S. Nuclear Regulatory Commission, Revision 4, Washington, D.C.

NUREG-1437, Supplement 23 G-34 August 2005

II i III
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC. Add Vol.. Supp., Rev.,

NRCMID 3.7 and Addendum Numbers, If any.)

BIBLIOGRAPHIC DATA SHEET

(See nstrudicons on the reverse) NUREG-1437, Supplement 23

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Generic Environmental Impact Statement for License Renewal of Nuclear Plants, MONTH YEAR

Supplement 23

Regarding Point Beach Nuclear Plant Units 1 and 2 August 2005

Final Report 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

See Appendix B of report. Technical

7. PERIOD COVERED (trciusive Dates)

8. PERFORMING ORGANIZATION -NAMEANDADDRESS(I NRC pwvieDisonOfriceorRegion. U.S NuearfegutatoryCommisrn andmlingadtress;fcontractor.

prfvide name and mahiwg address.)

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (it NRC. tye Same as above; i contrao or. provide NRC Division, Ofte or Region. U.S. Nuclear legutatory Commissison,

and mating addresi)

Same as 8 above.

10. SUPPLEMENTARY NOTES

Docket No. 50-266 and 50-301

11. ABSTRACT (20Wverds orkess)

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

the NRC by Nuclear Management Company, LLC (NMC) to renew the operating licenses for Point Beach Nuclear Plant Units 1

and 2 for an additional 20 years under 10 CFR Part 54. This Final SEIS includes the NRC staffs analysis that considers and

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

and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staffs recommendation

regarding the proposed action.

The NRC staffs recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for Point Beach Nuclear Plant Units 1 and 2 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 NMC; (3) consultation with Federal, State, Tribal, and local agencies; (4) the staffs own

independent review; and (5) the staffs consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that wl asswt researchers in iocating the report) 13. AVAILABILrTY STATEMENT

Point Beach Nuclear Plant Units 1 and 2 unlimited

Point Beach 14. SECURITY CLASSIFICATION

Pt. Beach (This Page)

Supplement to the Generic Environmental Impact Statement unclassified

GElS (Trhis Report)

National Environmental Policy Act unclassified

NEPA

License Renewal 15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (-2t04l) PRINTED ON RECYCLED PAPER
L Printed

on recycled

paper

Federal Recycling Program

11 I I 11
- -

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS