Generic Environmental 

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 52

Regarding Davis-Besse

Nuclear Power Station 

Draft Report for Comment

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 52
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Generic Environmental

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 52

Regarding Davis-Besse

Nuclear Power Station 

Draft Report for Comment

Manuscript Completed: February 2014

Date Published: February 2014

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 52
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iii

1 ABSTRACT

2 This draft supplemental environmental impact statement (SEIS) has been prepared in response 

3 to an application submitted by FirstEnergy Nuclear Operating Company (FENOC) to renew the 

4 operating license for Davis-Besse Nuclear Power Station, Unit No.1, (Davis-Besse) for an 

5 additional 20 years.

6 This draft SEIS includes the preliminary analysis that evaluates the environmental impacts of 

7 the proposed action and alternatives to the proposed action. Alternatives considered include 

8 replacement power from a new, natural-gas-fired combined-cycle (NGCC) power plant; 

9 combination alternative of NGCC and wind farm; a coal-fired power plant; and not renewing the 

10 license (the no-action alternative). 

11 The NRC’s preliminary recommendation is that the adverse environmental impacts of license 

12 renewal for Davis-Besse are not great enough to deny the option of license renewal for energy13 planning decisionmakers. This recommendation is based on the following:

14 • analysis and findings in the generic environmental impact statement (GEIS), 

15 • the Environmental Report (ER) submitted by FENOC, 

16 • consultation with Federal, State, Tribal, and local agencies, 

17 • NRC staff’s own independent review, and

18 • NRC staff’s consideration of public comments received during the scoping process. 
 
 

v 

TABLE OF CONTENTS

ABSTRACT ...................................................................................................................................iii

TABLE OF CONTENTS................................................................................................................ v 

FIGURES..................................................................................................................................... xi

TABLES ......................................................................................................................................xiii

EXECUTIVE SUMMARY ............................................................................................................ xv

ABBREVIATIONS AND ACRONYMS......................................................................................... xxi 

1.0 PURPOSE AND NEED FOR ACTION........................................................................... 1-1 

1.1 Proposed Federal Action.................................................................................... 1-1 

1.2 Purpose and Need for Proposed Federal Action................................................ 1-1 

1.3 Major Environmental Review Milestones............................................................ 1-2 

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

1.5 Supplemental Environmental Impact Statement ................................................ 1-6 

1.6 Cooperating Agencies ........................................................................................ 1-7 

1.7 Consultations...................................................................................................... 1-7 

1.8 Correspondence................................................................................................. 1-8 

1.9 Status of Compliance ......................................................................................... 1-8 

1.10 References ......................................................................................................... 1-8 

2.0 AFFECTED ENVIRONMENT......................................................................................... 2-1 

2.1 Facility Description ............................................................................................. 2-1 

2.1.1 Reactor and Containment Systems..................................................... 2-6 

2.1.2 Radioactive Waste............................................................................... 2-7 

2.1.3 Nonradioactive Waste Management ................................................. 2-10

2.1.4 Plant Operation and Maintenance ..................................................... 2-12

2.1.5 Power Transmission System ............................................................. 2-12

2.1.6 Cooling and Auxiliary Water Systems ............................................... 2-15

2.1.7 Facility Water Use and Quality .......................................................... 2-17

2.2 Affected Environment ....................................................................................... 2-18

2.2.1 Land Use ........................................................................................... 2-18

2.2.2 Air and Meteorology .......................................................................... 2-18

2.2.3 Geologic Environment ....................................................................... 2-25

2.2.4 Surface Water Resources ................................................................. 2-27

2.2.5 Groundwater Resources.................................................................... 2-30

2.2.6 Aquatic Resources ............................................................................ 2-33

2.2.7 Terrestrial Resources ........................................................................ 2-40

2.2.8 Protected Species and Habitats ........................................................ 2-44

2.2.9 Socioeconomic Factors ..................................................................... 2-56

2.2.10 Historic and Archaeological Resources............................................. 2-69

2.3 Related Federal and State Activities ................................................................ 2-73

2.3.1 Coastal Zone Management Act ......................................................... 2-74

2.4 References ....................................................................................................... 2-74

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT ................................................. 3-1 

3.1 Refurbishment Activities at Davis Besse............................................................ 3-3 

3.2 Environmental Impacts of Refurbishment........................................................... 3-3 

3.2.1 Terrestrial Resources—Refurbishment Impacts.................................. 3-3 

3.2.2 Threatened and Endangered Species................................................. 3-5 

3.2.3 Housing Impacts—Refurbishment....................................................... 3-6 
Table of Contents

vi

3.2.4 Public Services: Public Utilities—Refurbishment................................. 3-7 

3.2.5 Public Services: Education—Refurbishment ....................................... 3-7 

3.2.6 Offsite Land Use—Refurbishment....................................................... 3-7 

3.2.7 Public Services: Transportation—Refurbishment................................ 3-8 

3.2.8 Historic and Archaeological Resources............................................... 3-8 

3.2.9 Environmental Justice—Refurbishment............................................... 3-9 

3.2.10 Air Quality .......................................................................................... 3-10

3.3 Evaluation of New and Potentially Significant Information on Impacts of 

Refurbishment .................................................................................................. 3-12

3.4 Summary Impacts of Refurbishment ................................................................ 3-12

3.5 References ....................................................................................................... 3-12

4.0 ENVIRONMENTAL IMPACTS OF OPERATION ........................................................... 4-1 

4.1 Land Use ............................................................................................................ 4-1 

4.2 Air Quality........................................................................................................... 4-2 

4.3 Geologic Environment ........................................................................................ 4-3 

4.3.1 Geology and Soils ............................................................................... 4-3 

4.4 Surface Water Resources .................................................................................. 4-4 

4.4.1 Generic Surface Water Issues............................................................. 4-4 

4.4.2 Surface Water Use Conflicts ............................................................... 4-4 

4.5 Groundwater Resources .................................................................................... 4-4 

4.5.1 Groundwater Use Conflicts.................................................................. 4-5 

4.5.2 Radionuclides Released to Groundwater............................................ 4-5 

4.6 Aquatic Resources ............................................................................................. 4-5 

4.6.1 Exposure of Aquatic Organisms to Radionuclides............................... 4-6 

4.7 Terrestrial Resources ......................................................................................... 4-7 

4.7.1 Generic Terrestrial Resources Issues ................................................. 4-7 

4.7.2 Exposure of Terrestrial Organisms to Radionuclides .......................... 4-7 

4.7.3 - Effects on Terrestrial Resources (Non-cooling System Impacts)..... 4-8 

4.8 Protected Species and Habitats ......................................................................... 4-8 

4.8.1 Species Protected Under the Endangered Species Act. .....................4-9 

4.8.2 Species Protected Under the Bald and Golden Eagles 

Protection Act .................................................................................... 4-12

4.8.3 Species Protected Under the Migratory Bird Treaty Act.................... 4-12

4.8.4 Species Protected by the State of Ohio............................................. 4-12

4.8.5 Conclusion......................................................................................... 4-13

4.9 Human Health .................................................................................................. 4-13

4.9.1 Generic Human Health Issues........................................................... 4-13

4.9.2 Electromagnetic Fields—Acute Effects.............................................. 4-16

4.9.3 Electromagnetic Fields—Chronic Effects .......................................... 4-17

4.10 Socioeconomics ............................................................................................... 4-18

4.10.1 Generic Socioeconomic Issues ......................................................... 4-18

4.10.2 Housing Impacts................................................................................ 4-19

4.10.3 Public Services—Public Utilities ........................................................ 4-20

4.10.4 Public Services—Transportation ....................................................... 4-20

4.11 Environmental Justice ...................................................................................... 4-21

4.12 Offsite Land Use............................................................................................... 4-27

4.12.1 Population Related Impacts............................................................... 4-28

4.12.2 Tax Revenue Related Impacts .......................................................... 4-28

4.13 Historic and Archaeological Resources............................................................ 4-29

4.14 Evaluation of New and Potentially Significant Information ............................... 4-30
Table of Contents

vii

4.15 Cumulative Impacts.......................................................................................... 4-31

4.15.1 Cumulative Impacts on Air Quality .................................................... 4-33

4.15.2 Cumulative Impacts on Water Resources ......................................... 4-35

4.15.3 Cumulative Impacts on Aquatic Resources....................................... 4-38

4.15.4 Cumulative Impacts on Terrestrial Resources................................... 4-40

4.15.5 Cumulative Human Health Impacts ................................................... 4-42

4.15.6 Cumulative Socioeconomic Impacts.................................................. 4-44

4.15.7 Cumulative Historic and Archaeological Impacts............................... 4-45

4.15.8 Cumulative Impacts of Environmental Justice................................... 4-45

4.15.9 Summary of Cumulative Impacts....................................................... 4-46

4.16 References ....................................................................................................... 4-47

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS................................... 5-1 

5.1 Design Basis Accidents...................................................................................... 5-1 

5.2 Severe Accidents ............................................................................................... 5-2 

5.3 Severe Accident Mitigation Alternatives ............................................................. 5-3 

5.3.1 Overview of SAMA Process ................................................................ 5-3 

5.3.2 Estimate of Risk................................................................................... 5-4 

5.3.3 Potential Plant Improvements.............................................................. 5-6 

5.3.4 Evaluation of Risk Reduction and Costs of Improvements.................. 5-6 

5.3.5 Cost Benefit Comparison..................................................................... 5-7 

5.3.6 Conclusions ......................................................................................... 5-8 

5.4 References ......................................................................................................... 5-8 

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE AND 

SOLID WASTE MANAGEMENT.................................................................................... 6-1 

6.1 The Uranium Fuel Cycle..................................................................................... 6-1 

6.2 Greenhouse Gas Emissions............................................................................... 6-3 

6.2.1 Existing Studies ................................................................................... 6-3 

6.2.2 Conclusions: Relative Greenhouse Gas Emissions ........................... 6-8 

6.3 References ......................................................................................................... 6-9 

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ............................................. 7-1 

7.1 References .........................................................................................................7-3 

8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES ..................................................... 8-1 

8.1 Natural Gas-Fired Combined-Cycle (NGCC) Alternative ................................... 8-5 

8.1.1 Air Quality ............................................................................................ 8-7 

8.1.2 Groundwater Use and Quality ........................................................... 8-10

8.1.3 Surface Water Use and Quality ......................................................... 8-10

8.1.4 Aquatic Ecology................................................................................. 8-11

8.1.5 Terrestrial Ecology............................................................................. 8-12

8.1.6 Human Health.................................................................................... 8-12

8.1.7 Land Use ........................................................................................... 8-13

8.1.8 Socioeconomics ................................................................................ 8-13

8.1.9 Transportation ................................................................................... 8-14

8.1.10 Aesthetics .......................................................................................... 8-15

8.1.11 Noise ................................................................................................. 8-15

8.1.12 Historic and Archaeological Resources............................................. 8-16

8.1.13 Environmental Justice ....................................................................... 8-16

8.1.14 Waste Management .......................................................................... 8-17
Table of Contents

viii

8.1.15 Climate Change-Related Impacts of a Natural Gas-Fired 

Combined Cycle Alternative .............................................................. 8-18

8.2 Combination Alternative ................................................................................... 8-19

8.2.1 Air Quality .......................................................................................... 8-21

8.2.2 Groundwater Use and Quality ........................................................... 8-25

8.2.3 Surface Water Use and Quality ......................................................... 8-25

8.2.4 Aquatic Ecology................................................................................. 8-26

8.2.5 Terrestrial Ecology............................................................................. 8-27

8.2.6 Human Health.................................................................................... 8-29

8.2.7 Land Use ........................................................................................... 8-29

8.2.8 Socioeconomics ................................................................................ 8-31

8.2.9 Transportation ................................................................................... 8-33

8.2.10 Aesthetics .......................................................................................... 8-34

8.2.11 Noise ................................................................................................. 8-35

8.2.12 Historic and Archaeological Resources............................................. 8-35

8.2.13 Environmental Justice ....................................................................... 8-36

8.2.14 Waste Management .......................................................................... 8-37

8.2.15 Climate Change-Related Impacts of the Combination Alternative..... 8-38

8.3 Coal-Fired Alternative....................................................................................... 8-39

8.3.1 Air Quality .......................................................................................... 8-42

8.3.2 Groundwater Use and Quality ........................................................... 8-45

8.3.3 Surface Water Use and Quality ......................................................... 8-46

8.3.4 Aquatic Ecology................................................................................. 8-46

8.3.5 Terrestrial Ecology............................................................................. 8-47

8.3.6 Human Health.................................................................................... 8-48

8.3.7 Land Use ........................................................................................... 8-49

8.3.8 Socioeconomics ................................................................................ 8-49

8.3.9 Transportation ................................................................................... 8-50

8.3.10 Aesthetics .......................................................................................... 8-51

8.3.11 Noise ................................................................................................. 8-51

8.3.12 Historic and Archeological Resources............................................... 8-51

8.3.13 Environmental Justice ....................................................................... 8-52

8.3.14 Waste Management .......................................................................... 8-52

8.3.15 Climate Change-Related Impacts of a Coal-Fired Alternative........... 8-54

8.4 Alternatives Considered but Dismissed............................................................ 8-54

8.4.1 New Nuclear...................................................................................... 8-55

8.4.2 Wind .................................................................................................. 8-55

8.4.3 Solar Power....................................................................................... 8-63

8.4.4 Wood Waste ...................................................................................... 8-67

8.4.5 Conventional Hydroelectric Power .................................................... 8-67

8.4.6 Ocean Wave and Current Energy ..................................................... 8-68

8.4.7 Geothermal Power............................................................................. 8-68

8.4.8 Municipal Solid Waste ....................................................................... 8-69

8.4.9 Biomass Fuels ................................................................................... 8-70

8.4.10 Oil-Fired Power.................................................................................. 8-71

8.4.11 Fuel Cells........................................................................................... 8-71

8.4.12 Coal-Fired Integrated Gasification Combined Cycle.......................... 8-71

8.4.13 Energy Conservation/Energy Efficiency ............................................ 8-72

8.4.14 Purchased Power .............................................................................. 8-73

8.5 No-Action Alternative........................................................................................ 8-74

8.5.1 Air Quality .......................................................................................... 8-75
Table of Contents

ix

8.5.2 Groundwater Use and Quality ........................................................... 8-75

8.5.3 Surface Water Use and Quality ......................................................... 8-75

8.5.4 Aquatic Resources ............................................................................ 8-75

8.5.5 Terrestrial Resources ........................................................................ 8-75

8.5.6 Human Health.................................................................................... 8-76

8.5.7 Land Use ........................................................................................... 8-76

8.5.8 Socioeconomics ................................................................................ 8-76

8.5.9 Waste Management .......................................................................... 8-77

8.6 Alternatives Summary ...................................................................................... 8-77

8.7 References ....................................................................................................... 8-80

9.0 CONCLUSION ............................................................................................................... 9-1 

9.1 Environmental Impacts of License Renewal....................................................... 9-1 

9.2 Comparison of the Environmental Impacts of License Renewal and 

Alternatives ......................................................................................................... 9-1 

9.3 Resource Commitments..................................................................................... 9-2 

9.3.1 Unavoidable Adverse Environmental Impacts..................................... 9-2 

9.3.2 Relationship between Local Short-Term Uses of the Environment 

and the Maintenance and Enhancement of Long-Term 

Productivity .......................................................................................... 9-2 

9.3.3 Irreversible and Irretrievable Commitments of Resources................... 9-3 

9.4 Recommendation ............................................................................................... 9-4 

10.0 LIST OF PREPARERS ................................................................................................10-1 

11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF 

THIS SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT WERE SENT....11-1 

12.0 INDEX ..........................................................................................................................12-1 

APPENDIX A COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW .................... A-1 

APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS................................................... B-1 

APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS.......................... C-1 

APPENDIX D CONSULTATION CORRESPONDENCE ......................................................... D-1 

APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE....... E-1 

APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF 

SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR DAVIS BESSE 

NUCLEAR POWER STATION IN SUPPORT OF LICENSE RENEWAL 

APPLICATION REVIEW..................................................................................... F-1 
 
 

xi

FIGURES

Figure 1.3-1. Environmental Review Process ........................................................................ 1-3 

Figure 1.4-1. Environmental Issues Evaluated During License Renewal............................... 1-6 

Figure 2.1-1. Location of Davis-Besse, 50 mi (80 km) Region............................................... 2-2 

Figure 2.1-2. Location of Davis-Besse, 6 mi (10 km) Region................................................. 2-3 

Figure 2.1-3. Davis-Besse Site Boundary and Facility Layout ............................................... 2-4 

Figure 2.1-4. Davis-Besse Site Boundary and Facility Layout ............................................... 2-5 

Figure 2.1-5. Typical Pressurized Water Reactor .................................................................. 2-7 

Figure 2.1-6. Davis-Besse Transmission System ................................................................ 2-13

Figure 2.1-7. Davis-Besse Cooling Water System ............................................................... 2-15

Figure 2.2-1. Seismic Hazard Map....................................................................................... 2-26

Figure 2.2-2. Earthquake Epicenters Near Davis-Besse...................................................... 2-27

Figure 2.2-3. Groundwater Monitoring Well Locations ......................................................... 2-31

Figure 2.2-4. 2007–2011 Groundwater Monitoring Tritium Concentrations ......................... 2-32

Figure 2.2-5. May 2010–December 2010 Groundwater Monitoring Tritium 

Concentrations................................................................................................ 2-32

Figure 4.11-1. Census 2010 Minority Block Groups Within a 50-mi Radius of 

Davis-Besse.................................................................................................... 4-24

Figure 4.11-2. Census 2010 Low-Income Block Groups Within a 50-mi Radius of 

Davis-Besse.................................................................................................... 4-25

Figure 4.15-2. Projected Changes in Lake Levels Under a High Emission Scenario ............ 4-36

Figure 4.15-3. Observed Changes in Great Lakes Ice Cover, Seasonal Maximum 

Coverage 1973–2008 ..................................................................................... 4-37
 
 

xiii

TABLES

Table 2.1-1. Davis-Besse Transmission Lines ..................................................................... 2-14

Table 2.2-1. Annual Emissions Inventory Summaries for Sources at Davis-Besse, 

2006–2010 ....................................................................................................... 2-22

Table 2.2-2. National Ambient Air Quality Standards and Ohio State Ambient Air 

Quality Standards............................................................................................. 2-23

Table 2.2-3. Positive and Negative Trends in the Lake Erie Ecosystem Since the 1990s ... 2-35

Table 2.2-4. Sport and Commercial Harvests of Major Species in Ohio Waters of 

Lake Erie and its Tributaries, 2008................................................................... 2-37

Table 2.2-5. Relative Abundance of Species in Impingement Sampling, 1980.................... 2-38

Table 2.2-6. Entrainment Densities in Entrainment Sampling, 1980 .................................... 2-39

Table 2.2-7. Most Common Migrating Bird Species Near the Davis-Besse Site.................. 2-42

Table 2.2-8. ESA Species Under FWS’s Jurisdiction That Occur in Ottawa County............ 2-46

Table 2.2-9. Piping Plovers Observed During BSBO’s Lake Erie Marsh Migration 

Survey, 2003–2010 .......................................................................................... 2-47

Table 2.2-10. State-listed Species That Occur in Ottawa County .......................................... 2-49

Table 2.2-11. Songbird Bandings During Annual Migration Surveys, 2003–2009.................. 2-53

Table 2.2-12. Spring Raptor Survey Counts in the Lake Erie Marsh Region, 2006–2009 ..... 2-53

Table 2.2-13. Ducks, Swans, and Shorebirds Observed in Annual Spring Surveys 

at Navarre Marsh, 2006–2010.......................................................................... 2-54

Table 2.2-14. Davis-Besse, Employee Residence by County ................................................ 2-57

Table 2.2-15. Housing in Lucas, Ottawa, Sandusky, and Wood Counties in Ohio in 2010.... 2-58

Table 2.2-16. Major Public Water Supply Systems (Million Gallons Per Day)........................ 2-58

Table 2.2-17. Major Commuting Routes in the Vicinity of Davis-Besse, 2009 Average 

Annual Daily Traffic Count................................................................................ 2-59

Table 2.2-18. Population and Percent Growth in Lucas, Ottawa, Sandusky, and Wood 

Counties from 1970–2010 and Projected for 2020–2050................................. 2-61

Table 2.2-19. Demographic Profile of the Population in the Davis-Besse Four-County 

Socioeconomic Region of Influence in 2010 .................................................... 2-62

Table 2.2-20. Seasonal Housing in Counties Located within 50 Miles of Davis-Besse.......... 2-63

Table 2.2-21. Migrant Farm Workers and Temporary Hired Farm Labor in Counties 

Located Within 50 Miles of Davis-Besse .......................................................... 2-64

Table 2.2-22. Major Employers in Ottawa County, 2009........................................................ 2-65

Table 2.2-23. Employment by Industry in ROI, 2008-2010 3-Year Estimate.......................... 2-66

Table 2.2-24. Estimated Income Information for the Davis-Besse Four-County 

Socioeconomic Region of Influence, 2008–2010 3-Year Estimate .................. 2-67

Table 2.2-25. 2005–2009 3 Year Phase-In Rates Percentage Result of the July 2005 

Ohio Tax Reform Act and the Fully Phased-In 0.26 Percent Commercial 

Activity Tax ....................................................................................................... 2-67

Table 2.2-26. Davis-Besse Property Tax Distribution and Jurisdictional Operating 

Budgets, 2004–2008 ........................................................................................ 2-68

Table 3.1-1. Category 1 Issues Related to Refurbishment..................................................... 3-1 

Table 3.1-2. Category 2 Issues Related to Refurbishment..................................................... 3-2 

Table 4.1-1. Land Use Issues................................................................................................. 4-2 

Table 4.2-1. Air Quality Issues............................................................................................... 4-2 

Table 4.3-1. Geologic Environment Issue .............................................................................. 4-3 

Table 4.4-1. Surface Water Use and Quality Issues .............................................................. 4-4 

Table 4.5-1. Groundwater Use and Quality Issues................................................................. 4-4 

Table 4.6-1. Aquatic Resources Issues.................................................................................. 4-6 
Tables

xiv

Table 4.7-1. Terrestrial Resources Issues.............................................................................. 4-7 

Table 4.8-1. Protected Species Issues................................................................................... 4-9 

Table 4.8-2. Summary of Impacts to Federally Listed Species ............................................ 4-10

Table 4.9-1. Human Health Issues ....................................................................................... 4-13

Table 4.10-1. Socioeconomics During the Renewal Term ..................................................... 4-18

Table 4.15-1. Other Projects and Actions Considered in the Cumulative Analysis for 

Davis-Besse ..................................................................................................... 4-32

Table 4.15-4. Summary of Cumulative Impacts on Resource Areas...................................... 4-46

Table 5.1-1. Issues Related to Postulated Accidents. ............................................................ 5-1 

Table 5.3-1. Davis-Besse Internal Events Core Damage Frequency..................................... 5-5 

Table 5.3-2. Breakdown of Population Dose by Containment Release Mode........................ 5-5 

Table 6.1-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management........ 6-1 

Table 6.2-1. Nuclear GHG Emissions Compared to Coal ...................................................... 6-5 

Table 6.2-2. Nuclear GHG Emissions Compared to Natural Gas........................................... 6-6 

Table 6.2-3. Nuclear GHG Emissions Compared to Renewable Energy Sources ................. 6-7 

Table 7.1-1. Issues Related to Decommissioning .................................................................. 7-1 

Table 8.0-1. Summary of Alternatives Considered in Depth................................................... 8-4 

Table 8.1-1. Summary of Environmental Impacts of the NGCC Alternative Compared to 

Continued Operation of the Existing Davis-Besse.............................................. 8-6 

Table 8.2-1. Summary of Environmental Impacts of the Combination Alternative 

Compared to Continued Operation of the Existing Davis-Besse...................... 8-21

Table 8.3-1. Summary of Environmental Impacts of the Supercritical Coal-Fired 

Alternative Compared to Continued Operation of Davis-Besse ....................... 8-41

Table 8.5-1. Environmental Impacts of No-Action Alternative .............................................. 8-74

Table 8.6-1. Summary of environmental Impacts of Proposed Action and Alternatives....... 8-79

Table 10.1-1. List of Preparers ...............................................................................................10-1 

Table A-1. Commenters on the Scope of the Environmental Review................................. A-2 

Table A-2. Technical Issue Categories ............................................................................... A-6 

Table A-3. Comment Response Location in Order of Resource Area ................................ A-7 

Table B-1. Generic Summary Findings on NEPA Issues for License Renewal of 

Nuclear Power Plants........................................................................................ B-2 

Table C-1. Federal and State Environmental Requirements............................................... C-2 

Table C-2. Federal, State, and Local Permits and Other Requirements............................. C-5 

Table D-1. Consultation Correspondences ......................................................................... D-1 

Table F-1. Davis-Besse Core Damage Frequency for Internal Events................................ F-4 

Table F-2. Breakdown of Population Dose by Containment Release Mode........................ F-5 

Table F-3. Davis-Besse Probabilistic Risk Assessment Historical Summary ...................... F-7 

Table F-4. Davis-Besse Fire Zones and their Contribution to Fire Core Damage 

Frequency ........................................................................................................ F-11

Table F-5. Impact on Population Dose Risk and Offsite Economic Cost Risk for 

Selected Sensitivity Cases ............................................................................... F-15

Table F-6. SAMA Cost-Benefit Screening Analysis for Davis-Besse................................. F-24
 

xv

1 EXECUTIVE SUMMARY

2 Background

3 By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company (FENOC) submitted 

4 an application to the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating 

5 license for Davis-Besse Nuclear Power Plant, Unit No.1, (Davis-Besse) for an additional 20-year 

6 period.

7 Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)), 

8 the renewal of a power reactor operating license requires preparation of an environmental 

9 impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states 

10 that the NRC shall prepare an EIS, which is a supplement to the NRC’s NUREG-1437, “Generic 

11 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants.” 

12 The GEIS was originally published in 1996, and amended in 1999. Subsequently, on 

13 June 20, 2013, the NRC published a final rule (78 FR 37282) revising 10 CFR Part 51, 

14 “Environmental protection regulations for domestic licensing and related regulatory functions.” 

15 The final rule updates the potential environmental impacts associated with the renewal of an 

16 operating license for a nuclear power reactor for an additional 20 years. A revised GEIS, which 

17 updates the 1996 GEIS, provides the technical basis for the final rule. The revised GEIS 

18 specifically supports the revised list of National Environmental Policy Act (NEPA) issues and 

19 associated environmental impact findings for license renewal contained in Table B–1 in 

20 Appendix B to Subpart A of the revised 10 CFR Part 51. The 2013 rule revised the previous rule 

21 to consolidate similar Category 1 and 2 issues, change some Category 2 issues into Category 1 

22 issues, consolidate some of those issues with existing Category 1 issues, and adds new 

23 Category 1 and 2 issues.

24 The final rule became effective July 22, 2013, after publication in the Federal Register. 

25 Compliance by license renewal applicants is not required until June 20, 2014, (i.e., license 

26 renewal applications submitted later than 1 year after publication must be compliant with the 

27 new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license 

28 renewal Supplemental Environmental Impact Statement (SEIS), the potential significant impacts 

29 described by the revised rule’s new Category 2 issues, and to the extent there is any new and 

30 significant information, the potential significant impacts described by the revised rule’s new 

31 Category 1 issues. 

32 Upon acceptance of FENOC’s application, the NRC staff began the environmental review 

33 process described in 10 CFR Part 51 by publishing a Notice of Intent, in the Federal Register, to 

34 prepare a supplemental environmental impact statement (SEIS) and conduct scoping. In 

35 preparation of this SEIS for Davis-Besse, the NRC staff performed the following:

36 • conducted public scoping meetings on November 4, 2010, in Port Clinton, Ohio

37 • conducted a site audit at the plant in March 8–10, 2011

38 • reviewed FENOC’s environmental report (ER) and compared it to the GEIS

39 • consulted with other agencies
Executive Summary

xvi

1 • conducted a review of the issues following the guidance set forth in NUREG-1555, 

2 “Standard Review Plans for Environmental Reviews for Nuclear Power Plants, 

3 Supplement 1: Operating License Renewal”

4 • considered public comments received during the scoping process

5 Proposed Action

6 FENOC initiated the proposed Federal action—issuing a renewed power reactor operating 

7 license—by submitting an application for the license renewal of Davis-Besse, for which the 

8 existing license (NPF-003) will expire on April 22, 2017. The NRC’s Federal action is the 

9 decision whether or not to renew the license for an additional 20 years (April 22, 2037). 

10 Purpose and Need for Action

11 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 

12 option that allows for power generation capability beyond the term of the current nuclear power 

13 plant operating license to meet future system generating needs. Such needs may be 

14 determined by other energy-planning decisionmakers, such as state, utility, and, where 

15 authorized, Federal (other than NRC). This definition of purpose and need reflects the NRC’s 

16 recognition that, unless there are findings in the safety review required by the Atomic Energy 

17 Act (AEA) or findings in the National Environmental Policy Act (NEPA) environmental analysis 

18 that would lead the NRC to reject a license renewal application (LRA), the NRC does not have a 

19 role in the energy-planning decisions of whether a particular nuclear power plant should 

20 continue to operate.

21 If the renewed license is issued, the appropriate energy-planning decisionmakers, along with 

22 FENOC, will ultimately decide if the plant will continue to operate based on factors such as the 

23 need for power. If the operating license is not renewed, then the facility must be shut down on 

24 or before the expiration date of the current operating license—April 22, 2017.

25 Environmental Impacts of License Renewal

26 The SEIS evaluates the potential environmental impacts of the proposed action. The 

27 environmental impacts from the proposed action are designated as SMALL, MODERATE, or 

28 LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following 

29 criteria:

30 • The environmental impacts associated with the issue is 

31 determined to apply either to all plants or, for some issues, 

32 to plants having a specific type of cooling system or other 

33 specified plant or site characteristics.

34 • A single significance level (i.e., SMALL, MODERATE, or 

35 LARGE) has been assigned to the impacts, except for 

36 collective offsite radiological impacts from the fuel cycle 

37 and from high-level waste and spent fuel disposal.

38 • Mitigation of adverse impacts associated with the issue is 

39 considered in the analysis, and it has been determined 

40 that additional plant-specific mitigation measures are likely 

41 not to be sufficiently beneficial to warrant implementation.

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.
Executive Summary

xvii

1 For Category 1 issues, no additional site-specific analysis is required in this draft SEIS unless 

2 new and significant information is identified. Chapter 4 of this report presents the process for 

3 identifying new and significant information. Site-specific issues (Category 2) are those that do 

4 not meet one or more of the criterion for Category 1 issues; therefore, an additional site-specific 

5 review for these non-generic issues is required, and the results are documented in this SEIS. 

6 FENOC submitted its Environmental Report (ER) under NRC’s 1996 rule governing license 

7 renewal environmental reviews (61 FR 28467, June 5, 1996, as amended), as codified in NRC’s 

8 environmental protection regulation, 10 CFR 51. The 1996 GEIS and Addendum 1 to the GEIS 

9 provided the technical basis for the list of NEPA issues and associated environmental impact 

10 findings for license renewal contained in Table B–1 in Appendix B to 40 Subpart A of 10 CFR 

11 Part 51. For Davis-Besse, the NRC staff initiated its environmental review in accordance with 

12 the 1996 rule and GEIS and documented its findings in Chapter 4 of this SEIS. 

13 Under NEPA, the NRC must now consider and analyze in this SEIS the potential significant 

14 impacts described by the 2013 rule’s new Category 2 issues, and to the extent there is any new 

15 and significant information, the potential significant impacts described by the 2013 rule’s new 

16 Category 1 issues.

17 The new Category 1 issues include geology and soils, exposure of terrestrial organisms to 

18 radionuclides, exposure of aquatic organisms to radionuclides, human health impact from 

19 chemicals, and physical occupational hazards. Radionuclides released to groundwater, effects 

20 on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., 

21 environmental justice), and cumulative impacts were added as new Category 2 issues. These 

22 issues are described in Chapter 4 of this SEIS. 

23 The NRC staff did not identify any new issues applicable to Davis-Besse that have a significant 

24 environmental impact. The NRC staff, therefore, relies upon the conclusions of the 1996 and 

25 2013 GEIS for all Category 1 issues applicable to Davis-Besse.

26 Table ES-1 summarizes the Category 2 issues applicable to Davis-Besse, as well as the NRC 

27 staff’s findings related to those issues. If the NRC staff determined that there were no 

28 Category 2 issues applicable for a particular resource area, the findings of the GEIS, as 

29 documented in Appendix B to Subpart A of 10 CFR Part 51, stand. Hereafter in this SEIS, 

30 general references to the GEIS, without stipulation, are inclusive of the 1996 GEIS. Information 

31 and findings specific to the June 2013, final rule and GEIS, are identified as such. 

32 Table ES-1. Summary of NRC Conclusions Relating to Site-Specific Impact of License 

33 Renewal

Resource Area Relevant Category 2 Issues Impacts

Land use NONE SMALL

Air quality NONE SMALL

Geology and soils NONE(a) SMALL

Surface water resources NONE SMALL

Groundwater resources Radionuclides released to groundwater(a) SMALL

Aquatic resources NONE SMALL

Terrestrial resources Effects on terrestrial resources (non-cooling 

system impacts)(a) SMALL 
Executive Summary

xviii

Resource Area Relevant Category 2 Issues Impacts

Protected species Threatened or endangered species

No effect/ may affect, 

but is not likely to 

adversely affect(b)

Human health Electromagnetic fields-acute effects (electric 

shock) SMALL 

Socioeconomics

Housing Impacts

Public services (public utilities)

Offsite land use

Public services (public transportation)

Historic and archaeological resources

SMALL

SMALL 

SMALL 

SMALL 

SMALL to MODERATE

Cumulative Impacts Surface water resources(a) SMALL to MODERATE

Aquatic resources(a) LARGE

Terrestrial resources(a) MODERATE

Human health-microbiological organisms(a) MODERATE

All other evaluated resources(a) SMALL

(a) These issues are new Category 2 issues identified in the 2013 GEIS and Rule (78 FR 37282). U.S. Nuclear Regulatory 

Commission. "Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses." June 2013. 

(b): For Federally protected species, the 2013 GEIS and rule state that, in complying with the Endangered Species Act (ESA), the 

NRC will report the effects of continued operations and refurbishment in terms of its ESA findings, which varies by species for 

Davis-Besse. 

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (NRC 1996, 61 FR 28467), unless otherwise specified. 

1 With respect to environmental justice, the NRC staff determined that there would be no 

2 disproportionately high and adverse impacts to these populations from the continued operation 

3 of Davis-Besse during the license renewal period. Additionally, the NRC staff determined that 

4 no disproportionately high and adverse human health impacts would be expected in special 

5 pathway receptor populations in the region as a result of subsistence consumption of water, 

6 local food, fish, and wildlife.

7 Severe Accident Mitigation Alternatives

8 Since FENOC had not previously considered alternatives to reduce the likelihood or potential 

9 consequences of a variety of highly uncommon, but potentially serious, accidents at 

10 Davis-Besse, NRC regulation 10 CFR 51.53(c)(3)(ii)(L) requires that FENOC evaluate severe 

11 accident mitigation alternatives (SAMAs) in the course of the license renewal review. SAMAs 

12 are potential ways to reduce the risk or potential impacts of uncommon, but potentially severe, 

13 accidents and may include changes to plant components, systems, procedures, and training.

14 The NRC staff reviewed the ER’s evaluation of potential SAMAs. Based on the staff’s review, 

15 the NRC staff concluded that none of the potentially cost-beneficial SAMAs relate to adequately 

16 managing the effects of aging during the period of extended operation. Therefore, they need 

17 not be implemented as part of the license renewal, pursuant to 10 CFR Part 54.
Executive Summary

xix

1 Alternatives

2 The NRC staff considered the environmental impacts associated with alternatives to license 

3 renewal. These alternatives include other methods of power generation and not renewing the 

4 Davis-Besse operating license (the no-action alternative). Replacement power options 

5 considered were as follows:

6 • natural-gas-fired combined-cycle (NGCC), 

7 • combination alternative (wind, solar, NGCC, and compressed air energy storage), and

8 • coal-fired power. 

9 The NRC staff initially considered a number of additional alternatives for analysis as alternatives 

10 to license renewal of Davis-Besse; however, these were later dismissed due to technical, 

11 resource availability, or commercial limitations that currently exist and that the NRC staff 

12 believes are likely to continue to exist when the existing Davis-Besse license expires in 2017. 

13 The no-action alternative by the NRC staff, and the effects it would have, were also considered.

14 Where possible, the NRC staff evaluated potential environmental impacts for these alternatives 

15 located both at the Davis-Besse site and at some other unspecified alternate location. 

16 Alternatives considered but dismissed were as follows:

17 • wind power, 

18 • wind power with compressed air energy storage, 

19 • solar power, 

20 • solar power with compressed air energy storage, 

21 • wood waste, 

22 • conventional hydroelectric power, 

23 • ocean wave and current energy, 

24 • geothermal power, 

25 • municipal solid waste (MSW), 

26 • biofuels, 

27 • oil-fired power, 

28 • fuel cells, 

29 • energy conservation and energy efficiency, and

30 • purchased power. 

31 The NRC staff evaluated each alternative using the same impact areas that were used in 

32 evaluating impacts from license renewal.

33 Recommendation

34 The NRC’s preliminary recommendation is that the adverse environmental impacts of license 

35 renewal for Davis-Besse are not great enough to deny the option of license renewal for 

36 energy-planning decisionmakers. This recommendation is based on the following:

37 • analysis and findings in the GEIS; 

38 • ER submitted by FENOC; 

39 • consultation with Federal, State, and local agencies; 

40 • NRC staff’s own independent review; and

41 • consideration of public comments received during the scoping process. 
 
 

xxi

ABBREVIATIONS AND ACRONYMS

AADT annual average daily traffic

AEC Atomic Energy Commission

BSBO Black Swamp Bird Observatory

Btu British thermal unit

C Celsius

CDF core damage frequency

CEQ Council on Environmental Quality

CET containment event tree

CFR Code of Federal Regulations

cfs cubic feet per second

CO carbon monoxide

CO2 carbon dioxide

CWA Clean Water Act

CWS circulating water system

Davis-Besse Davis-Besse Nuclear Power Station

DSM demand-side management

EFH essential fish habitat

EIA Energy Information Administration

EPRI Electric Power Research Institute 

ER environmental report

ESA Endangered Species Act

F Fahrenheit

FBC fluidized-bed-combustion

FE FirstEnergy Corporation

FENGenCo FirstEnergy Nuclear Generation Corp.

FENOC FirstEnergy Nuclear Operating Company

FERC Federal Energy Regulatory Commission

FES final environmental statement

fps feet per second

ft3

 cubic feet

gal gallon

GEIS generic environmental impact statement

GHG greenhouse gas 

gpd gallons per day

gpm gallons per minute

IGCC integrated gasification combined cycle

IPA integrated plant assessment

kWh kilowatt-hour

kV kilovolt

lb pound

lb/MMBtu pounds per million British thermal units

LOS level of service
Abbreviations and Acronyms

xxii

m3

 cubic meters

mA milliampere

MAAP Modular Accident Analysis Program

MACCS2 MELCOR Accident Consequence Code System

MDC minimum detection concentration

mg/l milligrams per liter

mgd million gallons per day

MM million

MSW municipal solid waste

MW megawatt

MWd/MTU megawatt-days per metric ton uranium

MMBtumillion British thermal unit

MWe megawatts-electric

MWh megawatt-hour

MWt megawatts-thermal

NAAQS national ambient air quality standards

NEI Nuclear Energy Institute

NEPA National Environmental Policy Act

NESC National Electrical Safety Code

NGCC natural gas-fired combined cycle

NMFS National Marine Fisheries Service

NOx nitrogen oxides

NOAA National Oceanic and Atmospheric Administration

NPDES national pollutant discharge elimination system

NRC Nuclear Regulatory Commission

NRHP National Register of Historic Places

NRR Office of Nuclear Reactor Regulation

OAC Ohio Administrative Code

OCMP Ohio Coastal Management Program

ODCM offsite dose calculation manual

ODNR Ohio Department of Natural Resources

OEPA Ohio Environmental Protection Agency

OHPO Ohio Historic Preservation Office

ONWR Ottawa National Wildlife Refuge

OPSB Ohio Power Siting Board

pCi/L picocuries per liter

PDS plant damage state

PEIS programmatic environment impact statement

PCBs polychlorinated byphenyls

PM particulate matter

PM10 particulates with diameters less than 10 microns

PM2.5 particulates with diameters less than 2.5 microns

ppb parts per billion

ppm parts per million
Abbreviations and Acronyms

xxiii

ppt parts per thousand

PRA probabilistic risk assessment

Psig pounds per square inch gauge

rms root mean square

RC release category

RCS reactor coolant system 

REC renewable energy credits

ROW right of way

RPS renewable portfolio standards

SAMA severe accident mitigation alternative

scf standard cubic feet

SEIS supplemental environmental impact statement

SHPO State Historic Preservation Officer

SO2 sulfur dioxide

SOx sulfur oxides

SU standard units

SWS service water system 

USACE U.S. Army Corps of Engineers

USAR updated safety analysis report

USCB U.S. Census Bureau

USDOD U.S. Department of Defense

USDOE U.S. Department of Energy

USEPA U.S. Environmental Protection Agency

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

USOSHA U.S. Occupational Safety and Health Administration

wt% percent by weight

yr year
 
1-1 

1 1.0 PURPOSE AND NEED FOR ACTION

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

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

4 National Environmental Policy Act (NEPA), issuance of a new nuclear power plant operating 

5 license requires the preparation of an environmental impact statement (EIS).

6 The Atomic Energy Act of 1954 originally specified that licenses for commercial power reactors 

7 be granted for up to 40 years with an option to renew. The 40-year licensing period was based 

8 on economic and antitrust considerations rather than on technical limitations of the nuclear 

9 facility (AEA 1954). 

10 The decision to seek a license renewal rests entirely with nuclear power facility owners and, 

11 typically, is based on the facility’s economic viability and the investment necessary to continue 

12 to meet NRC safety and environmental requirements. The NRC makes the decision to grant or 

13 deny a license renewal based on whether the applicant has demonstrated that the 

14 environmental and safety requirements in the NRC’s regulations can be met during the period of 

15 extended operation.

16 1.1 Proposed Federal Action 

17 FirstEnergy Nuclear Operating Company (FENOC) initiated the proposed Federal action by 

18 submitting an application for license renewal of the Davis-Besse Nuclear Power Station, Unit 

19 No. 1 (Davis-Besse) for which the existing license, NPF-3, expires April 22, 2017

20 (FENOC 2010a). NRC’s Federal action is the decision whether to renew the license for an 

21 additional 20 years. In accordance with 10 CFR 2.109, if a licensee of a nuclear power plant 

22 files an application to renew an operating license at least 5 years before the expiration date of 

23 that license, the existing license will not be deemed to have expired until the safety and 

24 environmental reviews are completed and the NRC has made the final decision to either deny 

25 the application or issue a renewed operating license for the 20 additional years. 

26 1.2 Purpose and Need for Proposed Federal Action 

27 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 

28 option that allows for power generation capability beyond the term of a current nuclear power 

29 plant operating license to meet future system generating needs, as such needs may be 

30 determined by other energy-planning decisionmakers. This definition of purpose and need 

31 reflects the Commission’s recognition that, unless there are findings in the safety review 

32 required by the Atomic Energy Act or findings in the NEPA environmental analysis that would 

33 lead the NRC to reject a license renewal application (LRA), the NRC does not have a role in the 

34 energy-planning decisions of State regulators and utility officials as to whether a particular 

35 nuclear power plant should continue to operate.

36 If the renewed license is issued, State regulatory agencies and FENOC will ultimately decide 

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

38 matters within the State’s jurisdiction or the purview of the owners. If the operating license is 

39 not renewed, then the facility must be shut down on or before the expiration date of the current 

40 operating license—April 22, 2017.
Purpose and Need for Action

1-2 

1 1.3 Major Environmental Review Milestones

2 FENOC submitted an Environmental Report (ER) (FENOC 2010a) as part of its LRA

3 (FENOC 2010) in August 2010. After reviewing the LRA and ER for sufficiency, the NRC staff 

4 published a Federal Register Notice of Acceptability and Opportunity for Hearing (75 FR 65528) 

5 on October 25, 2010. Then, on October 28, 2010, NRC published another notice in the 

6 Federal Register (75 FR 66399) on the intent to conduct scoping, thereby beginning the 60-day 

7 scoping period.

8 Two public scoping meetings were held on November 4, 2010, in Port Clinton, OH. The 

9 comments received during the scoping process are presented in their entirety in the 

10 “Environmental Impact Statement Scoping Process, Summary Report, Davis-Besse Nuclear 

11 Power Station, Oak Harbor, OH,” published in November 2013 (NRC 2013b). The comments 

12 considered being within the scope of the environmental license renewal review and the NRC 

13 responses are presented in Appendix A of this supplemental environmental impact statement 

14 (SEIS). 

15 To independently verify information provided in the ER, NRC staff conducted a site audit at 

16 Davis-Besse in March 2011. During the site audit, staff met with plant personnel, reviewed 

17 specific documentation, toured the facility, and met with interested Federal, State, and local 

18 agencies. A summary of that site audit and the attendees is contained in the “Summary of Site 

19 Audit Related to the Review of the License Renewal Application for Davis-Besse Nuclear Power 

20 Station, Unit 1,” published June 2, 2011 (NRC 2011a).

21 Upon completion of the scoping period and site audit, the NRC staff compiled its findings in a 

22 draft SEIS (Figure 1.3-1). This document is available for public comment for 

23 45 days. During this time, the NRC staff will host public meetings and collect public comments. 

24 Members of the public can also submit written comments. Based on the information gathered, 

25 the NRC staff may amend the draft SEIS findings as necessary and publish the final SEIS. The 

26 NRC has established a license renewal process that can be completed in a reasonable period 

27 of time with clear requirements to assure safe plant operation for up to an additional 20 years of 

28 plant life. The safety review, which documents its finding in a safety evaluation report (SER), is 

29 conducted concurrently with the environmental review. The findings in the SEIS and the SER

30 are both factors in the Commission’s decision to either grant or deny the issuance of a new 

31 license.
Purpose and Need for Action

1-3 

Figure 1.3-1. Environmental Review Process

The process provides opportunities for public involvement.

1 1.4 Generic Environmental Impact Statement 

2 The NRC performed a generic assessment of the environmental impacts associated with 

3 license renewal to improve the efficiency of the license renewal review process. The Generic 

4 Environmental Impact Statement for License Renewal of Nuclear Power Plants (GEIS), 

5 NUREG-1437, (NRC 1996, 1999) documented the results of the NRC staff’s systematic 

6 approach to evaluate the environmental consequences of renewing the licenses of individual 

7 nuclear power plants and operating them for an additional 20 years. The NRC staff analyzed in 

8 detail and resolved those environmental issues that could be resolved generically in the GEIS. 

9 The GEIS was originally issued in 1996, and Addendum 1 to the GEIS was issued in 1999.

10 The GEIS established 92 separate issues for NRC staff to independently verify. Of these 

11 issues, the staff determined that 69 are generic to all plants (Category 1), and 21 issues do not 

12 lend themselves to generic consideration (Category 2). Two other issues remained 

13 uncategorized; environmental justice and chronic effects of electromagnetic fields must be 

14 evaluated on a site-specific basis. A list of all 92 issues is contained in Appendix B of this 

15 SEIS. 

16 On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 

17 protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 

18 “Environmental protection regulations for domestic licensing and related regulatory functions.” 

19 Specifically, the final rule updates the potential environmental impacts associated with the 

20 renewal of an operating license for a nuclear power reactor for an additional 20 years. A 

21 revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for the 

22 final rule. The revised GEIS specifically supports the revised list of NEPA issues and 
Purpose and Need for Action

1-4 

1 associated environmental impact findings for license renewal contained in Table B-1 in 

2 Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect 

3 lessons learned and knowledge gained during previous license renewal environmental reviews. 

4 In addition, public comments received on the draft revised GEIS and rule and during previous 

5 license renewal environmental reviews were reexamined to validate existing environmental 

6 issues and identify new ones.

7 The final rule identifies 78 environmental impact issues, of which 17 will require plant-specific 

8 analysis. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 

9 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 

10 issues. The final rule also adds new Category 1 and 2 issues. The new Category 1 issues 

11 include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of 

12 aquatic organisms to radionuclides, human health impact from chemicals, and physical 

13 occupational hazards. Radionuclides released to groundwater, effects on terrestrial resources 

14 (non-cooling system impacts), minority and low-income populations (i.e., environmental justice), 

15 and cumulative impacts were added as new Category 2 issues.

16 The final rule became effective 30 days after publication in the Federal Register. Compliance 

17 by license renewal applicants is not required until 1 year from the date of publication 

18 (i.e., license renewal environmental reports submitted later than 1 year after publication must be 

19 compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and 

20 analyze, in its license renewal SEISs, the potential significant impacts described by the final

21 rule’s new Category 2 issues and, to the extent there is any new and significant information, the 

22 potential significant impacts described by the final rule’s new Category 1 issues.

23 For each potential environmental issue, the GEIS does the following:

24 • describes the activity that affects the environment, 

25 • identifies the population or resource that is affected, 

26 • assesses the nature and magnitude of the impact on the affected population or resource, 

27 • characterizes the significance of the effect for both beneficial and adverse effects, 

28 • determines whether the results of the analysis apply to all plants, and

29 • considers whether additional mitigation measures would be warranted for impacts that 

30 would have the same significance level for all plants. 

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

32 Environmental Quality (CEQ) terminology for “significant.” The NRC established three levels of 

33 significance for potential impacts—SMALL, 

34 MODERATE, and LARGE—as defined below.

35 SMALL—Environmental effects are not detectable 

36 or are so minor that they will neither destabilize 

37 nor noticeably alter any important attribute of the 

38 resource.

39 MODERATE—Environmental effects are sufficient 

40 to alter noticeably, but not to destabilize, important 

41 attributes of the resource.

Significance indicates the importance of 

likely environmental impacts and is 

determined by considering two variables: 

context and intensity. 

Context is the geographic, biophysical, and 

social context in which the effects will occur. 

Intensity refers to the severity of the impact, 

in whatever context it occurs. 
Purpose and Need for Action

1-5 

1 LARGE—Environmental effects are clearly noticeable and are sufficient to destabilize important 

2 attributes of the resource.

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

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

5 (NRC 1996, 1999). Issues are assigned a Category 1 or a Category 2 designation. As set forth 

6 in the GEIS, Category 1 issues are those that meet the following criteria.

7 • The environmental impacts associated with the issue have been determined to apply 

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

9 or other specified plant or site characteristics.

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

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

12 high-level waste and spent fuel disposal).

13 • Mitigation of adverse impacts associated with the issue has been considered in the 

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

15 are likely not to be sufficiently beneficial to warrant implementation.

16 For generic issues (Category 1), no additional site-specific analysis is required in this SEIS 

17 unless new and significant information is identified. The process for identifying new and 

18 significant information is presented in Chapter 4. Site-specific issues (Category 2) are those 

19 that do not meet one or more of the criteria of Category 1 issues; therefore, additional 

20 site-specific review for these issues is required. The results of that site-specific review are 

21 documented in the SEIS. 
Purpose and Need for Action

1-6 

Figure 1.4-1. Environmental Issues Evaluated During License Renewal

Initially, 92 issues were evaluated in the GEIS. 

A site-specific analysis is required for 23 of those 92 issues.

1 1.5 Supplemental Environmental Impact Statement 

2 The SEIS presents an analysis that considers the environmental effects of the continued 

3 operation of Davis-Besse, alternatives to license renewal, and mitigation measures for 

4 minimizing adverse environmental impacts. Chapter 8 contains analysis and comparison of the 

5 potential environmental impacts from alternatives while Chapter 9 presents the preliminary 

6 recommendation to the Commission on that the environmental impacts of license renewal are 

7 so great that preserving the option of license renewal would be unreasonable. The final 

8 recommendation will be made after consideration of comments received during the public 

9 scoping period and on the draft SEIS. 

10 In the preparation of this draft SEIS for Davis-Besse, the NRC staff did the following:

11 • reviewed the information provided in the FENOC ER, 

12 • consulted with other Federal, state, and local agencies, 

13 • conducted an independent review of the issues during site audit, and

14 • considered the public comments received during the scoping process. 
Purpose and Need for Action

1-7 

New and significant information either:

(1) identifies a significant environmental issue 

not covered in the GEIS, or (2) was not 

considered in the analysis in the GEIS and 

leads to an impact finding that is different from 

the finding presented in the GEIS.

1 New information can be identified from many 

2 sources, including the applicant, NRC, other 

3 agencies, or public comments. If a new issue 

4 is identified, it is first analyzed to determine if it 

5 is within the scope of the license renewal 

6 evaluation. If it is not addressed in the GEIS, 

7 the NRC determines its significance and 

8 documents its analysis in the SEIS. 

9 FENOC submitted its ER under NRC’s 1996 rule governing license renewal environmental 

10 reviews (61 FR 28467, June 5, 1996, as amended), as codified in NRC’s environmental 

11 protection regulation, 10 CFR 51. The 1996 GEIS (NRC 1996) and Addendum 1 to the GEIS 

12 (NRC 1999) provided the technical basis for the list of NEPA issues and associated 

13 environmental impact findings for license renewal contained in Table B–1 in Appendix B to 

14 Subpart A of 10 CFR Part 51. For Davis-Besse, the NRC staff initiated its environmental review 

15 in accordance with the 1996 rule and GEIS (NRC 1996, 1999) and documented its findings in 

16 Chapter 4 of this SEIS. 

17 As described in Section 1.4, the NRC published a final rule (78 FR 37282, June 20, 2013) 

18 revising 10 CFR 51 including the list of NEPA issues and findings in Table B–1 of 10 CFR 51. 

19 Under NEPA, the NRC must now consider and analyze in this SEIS the potential significant 

20 impacts described by the final rule’s new Category 2 issues, and to the extent there is any new 

21 and significant information, the potential significant impacts described by the final rule’s new 

22 Category 1 issues. The new Category 1 issues include geology and soils, exposure of 

23 terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human 

24 health impact from chemicals, and physical occupational hazards. Radionuclides released to 

25 groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low26 income populations (i.e., environmental justice), and cumulative impacts were added as new 

27 Category 2 issues. These new issues are also analyzed in Chapter 4 of this SEIS. Hereafter in 

28 this SEIS, general references to the “GEIS” without stipulation are inclusive of the 1996 GEIS 

29 and 1999 Addendum (NRC 1996, 1999). Information and findings specific to the June 2013 

30 final rule (78 FR 37282) or the June 2013 GEIS (NRC 2013) or both are appropriately 

31 referenced as such.

32 1.6 Cooperating Agencies

33 During the scoping process, no Federal, State, or local agencies were identified as cooperating 

34 agencies in the preparation of this SEIS.

35 1.7 Consultations

36 The Endangered Species Act of 1973, as amended (ESA 1973); the Magnuson–Stevens 

37 Fisheries Management Act of 1996, as amended (MSFMA 1996); and the National Historic 

38 Preservation Act of 1966 (NHPA 1966) require that Federal agencies consult with applicable 

39 State and Federal agencies and groups prior to taking action that may affect endangered 

40 species, fisheries, or historic and archaeological resources, respectively.

41 Listed below are the agencies and groups with whom the NRC consulted.

42 • Advisory Council on Historic Preservation, 

43 • Ohio Historic Preservation Office, 
Purpose and Need for Action

1-8 

1 • U.S. Fish and Wildlife Service, 

2 • National Oceanic and Atmospheric Administration, National Marine Fisheries Service, 

3 • Ohio Department of Natural Resources, 

4 • Delaware Nation, 

5 • Forest County Potawatomi Community, 

6 • Hannahville Indian Community Council, 

7 • Miami Tribe of Oklahoma, 

8 • Shawnee Tribe, 

9 • Wyandotte Nation, 

10 • Peoria Tribe of Indians of Oklahoma, and

11 • Ottawa Tribe of Oklahoma. 

12 1.8 Correspondence

13 During the course of the environmental review, the NRC staff contacted Federal, State, regional, 

14 local, and Tribal agencies listed in Section 1.7. Appendix E contains a chronological list of all 

15 the documents sent and received during the environmental review

16 A list of persons who received a copy of this draft SEIS is provided in Chapter 12.

17 1.9 Status of Compliance

18 FENOC is responsible for complying with all NRC regulations and other applicable Federal, 

19 State, and local requirements. A description of some of the major Federal statutes can be found 

20 in the Appendix H of the GEIS. Appendix C of this SEIS includes a list of the permits and 

21 licenses issued by Federal, State, and local authorities for activities at Davis-Besse.

22 1.10 References

23 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

24 protection regulations for domestic licensing and related regulatory functions.”

25 61 FR 28467. U.S. Nuclear Regulatory Commission. “Environmental Review for Renewal of 

26 Nuclear Power Plant Operating Licenses.” Federal Register 61 (109): 28467-28497. 

27 June 5, 1996.

28 75 FR 65528. U.S. Nuclear Regulatory Commission. “Notice of Acceptance for Docketing of 

29 the Application, Notice for Opportunity for Hearing for Facility Operating License No. NPF-003 

30 for an Additional 20-year Period: FirstEnergy Nuclear Operating Company, Davis-Besse 

31 Nuclear Power Station, Unit 1” Federal Register. Volume 75(130): 65528-65531. 

32 October 25, 2010.

33 75 FR 66399. U.S. Nuclear Regulatory Commission. “FirstEnergy Nuclear Operating 

34 Company; Notice of Intent to Prepare an Environmental Impact Statement and Conduct the 

35 Scoping Process for Davis-Besse Nuclear Power Station, Unit 1,” Federal Register. 

36 Volume 75(208): 66399-66401. October 28, 2010.

37 78 FR 37282. U.S. Nuclear Regulatory Commission. "Revisions to Environmental Review for 

38 Renewal of Nuclear Power Plant Operating Licenses." Federal Register Volume 78(119): 

39 37282-37324. June 20, 2013. 
Purpose and Need for Action

1-9 

1 Atomic Energy Act, 42 U.S.C. §2011 (1954).

2 Endangered Species Act, 16 U.S.C. §1531, et seq. (1973). 

3 [FENOC] FirstEnergy Nuclear Operating Company (FENOC), “Davis-Besse Nuclear Power 

4 Station License Renewal Application,” Toledo, OH, August 2010, Agencywide Documents 

5 Access and Management System (ADAMS) Accession Nos. ML102450572 

6 Magnuson–Stevens Fishery Conservation and Management Act, 16 U.S.C. §1855, et seq. 

7 (as amended by the Sustainable Fisheries Act of 1996).

8 National Environmental Policy Act, 42 U.S.C. §4321, et seq. (1969).

9 National Historic Preservation Act, 16 U.S.C. §470, et seq.

10 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 

11 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996. 

12 ADAMS Accession Nos. ML040690705 and ML040690738.

13 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3—Transportation, Table 9.1, 

14 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic

15 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 

16 NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 

17 No. ML04069720.

18 [NRC] U.S. Nuclear Regulatory Commission. 2011. Summary of Site Audit Related to the 

19 Review of the License Renewal Application for Davis-Besse Nuclear Power Station, NRC. 

20 June 3, 2011, ADAMS Accession No. ML110820276.

21 [NRC] U.S. Nuclear Regulatory Commission. 2012. Staff Requirements, SECY-12-0063—Final 

22 Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating 

23 Licenses (10 CFR Part 51; RIN 3150–AI42). December 6, 2012. ADAMS Accession 

24 No. ML12341A134. 

25 [NRC] U.S. Nuclear Regulatory Commission. 2013a. Environmental Impact Statement Scoping 

26 Process, Summary Report, Davis-Besse Nuclear Power Station, Oak Harbor, OH. 

27 Rockville, MD: NRC. October 2013, ADAMS Accession No. ML11168A197. 

28 [NRC] U.S. Nuclear Regulatory Commission. 2013b. Generic Environmental Impact Statement 

29 for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation. 

30 NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession 

31 Nos. ML13106A241, ML13106A242, and ML13106A244.

2-1 

1 2.0 AFFECTED ENVIRONMENT

2 Davis-Besse Nuclear Power Station, Unit No. 1, (Davis-Besse) is located 25 mi (40 km) east of 

3 Toledo, OH. It is situated on the southwest coastline of Lake Erie. The 954-acre (ac) 

4 (386-hectare (ha)) site is located in Caroll Township, Ottawa County, just north of the Toussaint 

5 River with approximately 7,500 ft (2,300 m) of Lake Erie frontage. Approximately 700 ac 

6 (300 ha) are marshland that is leased to the U.S. Government as a national wildlife refuge. 

7 Figure 2.1-1 and Figure 2.1-2 present the 50-mi (80- km) and 6-mi (10-km) vicinity maps, 

8 respectively (FENOC 2010c). 

9 For purposes of the evaluation in this report, the “affected environment” is the environment that 

10 currently exists at and around Davis-Besse. Because existing conditions are at least partially 

11 the result of past construction and operation at the plant, the impacts of these past and ongoing 

12 actions and how they have shaped the environment are presented here. The facility and its 

13 operation are described in Section 2.1 and the affected environment is presented in Section 2.2.

14 2.1 Facility Description

15 This assessment of the affected environment begins with a description of Davis-Besse, which is 

16 the source of potential environmental effects. Davis-Besse is a single-unit pressurized water 

17 reactor (PWR) plant that uses closed-cycle cooling (using cooling towers to recirculate up to 

18 95 percent of the cooling water). The plant is licensed for an electrical output of 

19 2,817 megawatts-thermal (MWt) and 913 megawatt-electric (MWe). 

20 The most visible structures on the Davis-Besse site include the cooling tower, switchyard, 

21 forebay and intake canal, and the plant structures. Figure 2.1-3 shows the site layout 

22 referencing these features. The plant structures include structures such as the containment 

23 building, turbine building, and auxiliary building. A more detailed layout of these structures can 

24 be seen on Figure 2.1-4. On this figure, additional structure locations such as the 

25 meteorological tower can also be located. Davis-Besse’s used (or spent) fuel is stored in a pool 

26 inside the plant until it is cooled and transferred to dry storage containers located onsite called 

27 the independent spent fuel storage installation (ISFSI). Spent fuel will be stored there until the 

28 Federal Government removes it to be reprocessed or stored at a Government facility.
Affected Environment

2-2 

Figure 2.1-1. Location of Davis-Besse, 50 mi (80 km) Region

Source: FENOC 2010c 
Affected Environment

2-3 

Figure 2.1-2. Location of Davis-Besse, 6 mi (10 km) Region

Source: FENOC 2010c 
Affected Environment

2-4 

Figure 2.1-3. Davis-Besse Site Boundary and Facility Layout 

Source: FENOC 2010c 
Affected Environment

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Figure 2.1-4. Davis-Besse Site Boundary and Facility Layout

Source: FENOC 2010c 
Affected Environment

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1 2.1.1 Reactor and Containment Systems

2 Davis-Besse is single unit nuclear power plant that began commercial operation on 

3 April 22, 1977. Davis-Besse is equipped with a Babcock and Wilcox-designed PWR. 

4 Davis-Besse includes a nuclear steam supply system supplied by Babcock and Wilcox 

5 Company and a turbine generator designed and manufactured by General Electric Company.

6 Davis-Besse was initially licensed to operate at a maximum steady-state core power level of 

7 2,772 MWt. In 2008, amendments of the operating license and technical specifications allowed 

8 an increase in the rated thermal power of 1.63 percent. The reactor has a current electrical 

9 output of 2,817 MWt and 913 MWe gross. An additional 17 MWt is contributed to the cycle by 

10 the reactor coolant pumps, resulting in a net electrical output of about 925 MWe

11 (FENOC 2010c). 

12 Davis-Besse’s fuel for the reactor core consists of slightly enriched (less than 5 percent by 

13 weight) uranium dioxide pellets sealed in Zircaloy-4 or M5 tubes. The complete core has 

14 177 fuel assemblies arranged in a square lattice to approximate a cylinder.

15 In a PWR power generation system, reactor heat is transferred from the primary coolant to a 

16 lower pressure secondary coolant loop, allowing steam to be generated in the steam supply 

17 system. Each of the primary coolant loops contains one steam generator, one reactor coolant 

18 pump, and interconnected piping. Reactor coolant is pumped from the reactor through the 

19 steam generators and back to the reactor. Each steam generator has a heat exchanger that 

20 produces superheated steam at a constant pressure over the reactor’s operating power range. 

21 Coolant flows through the tubes as steam is generated on the lower pressure shell side. The 

22 steam then flows from the steam generator to the turbine unit that turns the electrical generator.

23 Figure 2.1-5 presents a typical PWR.
Affected Environment

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Figure 2.1-5. Typical Pressurized-Water Reactor

1 The containment system for the station uses a free-standing containment vessel surrounded by 

2 a reinforced concrete shield building. The shield building is a reinforced concrete structure of 

3 right cylinder configuration with a shallow dome roof. The shield building has a height of 

4 279.5 ft (85 m) measured from the top of the foundation ring to the top of the dome. The 

5 structure is designed to withstand an internal pressure of 40 pounds per square inch gage (psig) 

6 and design-basis accidents (DBAs) (FENOC 2010c). DBAs include, but are not limited to, wind 

7 and tornado events, water level (floods), and seismic events, where the systems are required to 

8 avoid or mitigate the consequences of abnormal operational transients or accidents.

9 2.1.2 Radioactive Waste

10 The radioactive waste systems collect, treat, and dispose of radioactive and potentially 

11 radioactive wastes that are byproducts of operations. The byproducts are activation products 

12 resulting from the irradiation of reactor water and impurities therein (principally metallic 

13 corrosion products) and fission products resulting from defective fuel cladding or uranium 
Affected Environment

2-8 

1 contamination within the reactor coolant system (RCS). Operating procedures for the 

2 radioactive waste system ensure that radioactive wastes are safely processed and discharged 

3 from Davis-Besse. The systems are designed and operated to assure that the quantities of 

4 radioactive materials released from Davis-Besse are as low as is reasonably achievable 

5 (ALARA). They also comply with the dose standards set forth in Title 10 of the Code of Federal 

6 Regulations (CFR) Part 20, “Standards for Protection against Radiation,” and Appendix I to 

7 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.” The Davis-Besse 

8 offsite dose calculation manual (ODCM) contains the methodology and parameters used to 

9 calculate offsite doses resulting from radioactive effluents. The methodology is used to ensure 

10 that radioactive material discharged from Davis-Besse meets regulatory dose standards.

11 Radioactive wastes resulting from Davis-Besse operations are classified as liquid, gaseous, and 

12 solid. Radioactive wastes generated by Davis-Besse operations are collected and processed to 

13 meet applicable regulations. The design and operational objectives of the radioactive waste 

14 management systems are to limit the release of radioactive effluents from Davis-Besse during 

15 normal operation and anticipated operational occurrences (FENOC 2010c). 

16 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 

17 as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh 

18 fuel assemblies during routine refueling outages. Spent fuel assemblies are stored in a spent 

19 fuel pool located in the auxiliary building and in the dry fuel storage facility located south of the 

20 containment building (FENOC 2010c). 

21 2.1.2.1 Radioactive Liquid Waste

22 The liquid radioactive waste system is designed so that effluents released by the system, when 

23 mixed with the cooling tower blowdown, meet the requirements in Appendix B of 

24 10 CFR Part 20 and 10 CFR Part 50. The design is based on receiving, segregating, and 

25 batch-storing two categories of solutions—clean liquid radwaste and miscellaneous liquid 

26 radwaste. The major source of clean liquid radwaste for this system is reactor coolant letdown 

27 resulting from boron dilution operations or from coolant expansion during reactor startups. 

28 Other sources include leakage, drainage, and relief flows from valves and equipment containing 

29 reactor-grade liquid. The major sources of miscellaneous liquid radwaste are further 

30 categorized as non-detergent and detergent wastes. Non-detergent wastes are categorized as 

31 miscellaneous system leakage, drainage from area washdown, sampling and laboratory 

32 operations, and condensate polishing demineralizer backwash (if there is a significant 

33 primary-secondary leak). Detergent waste comes from the hot showers (used to decontaminate 

34 personnel) and drains in the laboratory.

35 The liquid radioactive waste system can accommodate the full range of volumes and activities 

36 delivered to it. Suitability for discharge is determined not only by comparison of waste samples 

37 with applicable limits but also by the opportunity afforded the station to further reduce activity 

38 with existing equipment. Before processed water is released to the environment, it is mixed in a 

39 collection box with the discharge from the service water system (SWS), the dilution pump, a 

40 cooling tower make up pump, or the cooling tower blowdown. Processed liquid waste enters 

41 Lake Erie. The ODCM provides the day-to-day methods for determining release rates and

42 cumulative releases and for calculating the corresponding dose rates and cumulative quarterly 

43 and yearly doses (FENOC 2010c). 
Affected Environment

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1 2.1.2.2 Radioactive Gaseous Waste

2 The gaseous radioactive waste disposal system is designed to process effluents to meet the 

3 requirements of 10 CFR Part 20, 10 CFR Part 50, Appendix I, and 40 CFR Part 40. The system 

4 provides selective holdup such that the short-lived isotopes sufficiently decay prior to release. It 

5 also provides a 30-day holdup of these gases when refueling cold shutdown degassing is 

6 required.

7 When a decay tank is full, (i.e., contains gas at 150 psig) or when the operator decides, it is 

8 valved out-of-service and another is put in its place. A sample is then taken from the isolated 

9 tank and analyzed. If it shows a sufficiently low activity level, the stored gas can be released in 

10 a controlled manner through waste gas charcoal and high efficiency particulate air filters to the 

11 station vent. If the analysis indicates significant radioactivity, the gases are allowed to decay 

12 until future sampling shows that they are suitable for release to the environment. Using two of 

13 the decay tanks, gases can be held for at least 60 days with release spread out over the next 

14 30 days.

15 Gaseous wastes that contain little or no radioactivity or may contain oxygen are handled 

16 separately. These gases are collected, passed through a charcoal filter, and then released 

17 through the station vent.

18 The ODCM provides the day-to-day methods for determining release rates and cumulative 

19 releases and for calculating the corresponding dose rates and cumulative quarterly and yearly 

20 doses (FENOC 2010c). 

21 2.1.2.3 Radioactive Solid Waste

22 The solid waste management system collects, processes, and packages solid radioactive 

23 wastes for storage and offsite shipment and burial. The system is located in the low-level 

24 radioactive waste storage facility (LLRWSF). The system is designed to process waste while 

25 maintaining occupational exposure ALARA. To ensure compliance with applicable regulations 

26 in 10 CFR Part 20, 10 CFR Part 61, and 10 CFR Part 71, characterization, classification, 

27 processing, waste storage, handling and transportation of solid wastes are controlled by the 

28 Davis-Besse Process Control Program.

29 The materials handled by the solid waste system include bead-type resins, spent filter 

30 cartridges, powdered resins, and miscellaneous solid waste such as paper, rags, contaminated 

31 clothing, gloves and shoe coverings. The solid waste system area was designed to provide the 

32 necessary shielding to prevent the overexposure of operating personnel to radioactive sources. 

33 This is accomplished through the use of lead shielding, concrete shielding, and safe operating 

34 procedures.

35 The LLRWSF provides interim onsite storage for dry active waste (DAW) boxes and 

36 liners/high-integrity containers (HIC) and also provides DAW compaction and segregation 

37 areas. The following activities are also permitted, with administrative controls in place, in the 

38 LLRWSFs: 

39 • opening of DAW containers in the cell area for inventory, 

40 • sorting, re-packaging, or both, 

41 • loading a sea land container with DAW and preparing the container for offsite shipment 

42 in the truck bay, 
Affected Environment

2-10

1 • opening of radioactive material (RAM) containers in the cell area for retrieval of tools and 

2 equipment, and

3 • refurbishing, minor repair, or both, of tools and equipment in the cell area. 

4 Approximately 5 years of storage area is available in the LLRWSF. The facility has separate 

5 radiation monitoring and floor drain collection systems.

6 Solid radioactive wastes are packaged and shipped from Davis-Besse in containers that meet 

7 the requirements established by the Department of Transportation (DOT) and by the U.S. 

8 Nuclear Regulatory Commission (NRC). All Class A radioactive waste is sent out for processing 

9 and ultimately transported to Clive, Utah, for disposal at a commercial low-level radioactive 

10 waste disposal facility. Class B and Class C resins and filters are shipped in HICs to Studsvic, 

11 Inc., in Erwin, Tennessee, for thermal oxidation and reduction processing to reduce the volume 

12 for burial (FENOC 2011).

13 Class A LLRW waste is shipped to processing facilities as shipping containers are filled. As a 

14 result, there is no need for storage of Class A waste. The contract with Studsvic, Inc., for 

15 processing Class B and Class C LLRW has resulted in the processing of all Class B and 

16 Class C LLRW; consequently, there is no Class B or Class C LLRW in long-term storage onsite 

17 (FENOCb 2011).

18 The LLRWSF has the capability to store 108 HICs of LLRW. Since Class A waste is not stored 

19 at the LLRWSF, the space is available for Class B and Class C LLRW storage. FirstEnergy 

20 Nuclear Operating Company (FENOC) is currently generating approximately three Class B and 

21 Class C HICs during a 2-year operating cycle. Assuming that Davis-Besse had to store Class B 

22 and Class C LLRW and not ship it offsite for processing, and assuming that Davis-Besse 

23 continued to generate three Class B and Class C HICs during each 2-year operating cycle from 

24 2011 through the period of extended operation (i.e., conservatively, 14 cycles), there would be 

25 14x3=42 HICs that would require long-term storage in the LLRWSF. With storage capacity for 

26 108 HICs in the LLRWSF, Davis-Besse would have sufficient storage space for LLRW for the 

27 period of extended operation (FENOCb 2011).

28 2.1.3 Nonradioactive Waste Management

29 Davis-Besse generates nonradioactive wastes as part of routine plant maintenance, cleaning 

30 activities, and plant operations. The Resource Conservation and Recovery Act of 1976 (RCRA) 

31 waste regulations governing the disposal of solid and hazardous waste are contained in 

32 40 CFR Parts 239 through 299. In addition, 40 CFR Parts 239 through 259 contain regulations 

33 for solid (nonhazardous) waste, and 40 CFR Parts 260 through 279 contain regulations for 

34 hazardous waste. RCRA Subtitle C establishes a system for controlling hazardous waste from 

35 “cradle to grave,” and RCRA Subtitle D encourages states to develop comprehensive plans to 

36 manage nonhazardous solid waste and mandates minimum technological standards for 

37 municipal solid waste landfills. Ohio State RCRA regulations are administered by the Ohio 

38 Environmental Protection Agency (OEPA) and address the identification, generation, 

39 minimization, transportation, and final treatment, storage, or disposal of hazardous and 

40 nonhazardous waste. 
Affected Environment

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1 Nonradioactive Waste Streams

2 Davis-Besse generates solid waste, defined by the RCRA, as part of routine plant maintenance, 

3 cleaning activities, and plant operations. Ohio administers the RCRA Program in Ohio 

4 Administrative Code (OAC) 3745-50.

5 The U.S. Environmental Protection Agency (EPA) classifies certain nonradioactive wastes as 

6 hazardous based on characteristics including ignitability, corrosivity, reactivity, or toxicity 

7 (hazardous wastes are listed in 40 CFR Part 261). State-level regulators may add wastes to the 

8 EPA’s list of hazardous wastes. RCRA supplies standards for the treatment, storage, and 

9 disposal of hazardous waste for hazardous waste generators (regulations are available in 

10 40 CFR Part 262).

11 The EPA recognizes the following main types of the hazardous waste generators 

12 (40 CFR 260.10) based on the quantity of the hazardous waste produced:

13 • large quantity generators that generate 2,200 lb (1,000 kg) per month or more of 

14 hazardous waste, more than 2.2 lb (1 kg) per month of acutely hazardous waste, or 

15 more than 220 lb (100 kg) per month of acute spill residue or soil, 

16 • small quantity generators that generate more than 220 lb (100 kg) but less than 2,200 lb 

17 (1,000 kg) of hazardous waste per month, and

18 • conditionally exempt small quantity generators that generate 220 lb (100 kg) or less per 

19 month of hazardous waste, 2.2 lb (1 kg) or less per month of acutely hazardous waste, 

20 or less than 220 lb (100 kg) per month of acute spill residue or soil. 

21 OEPA recognizes Davis-Besse as a small quantity generator of hazardous wastes under 

22 OAC 3745-52. However, during refueling outage years, hazardous waste generation may 

23 exceed 2,200 lb in a month, requiring Davis-Besse to file a report with the OEPA for a 

24 temporary large quantity generator status in accordance with the OAC, Rule 3745-52-41. 

25 Davis-Besse hazardous wastes include spent and off-specification (e.g., shelf-life expired) 

26 chemicals, laboratory chemical wastes, and occasional project-specific wastes (FENOC 2010).

27 The EPA classifies several hazardous wastes as universal wastes. These universal wastes 

28 include batteries, pesticides, mercury-containing items, and fluorescent lamps. OEPA has 

29 incorporated EPA’s regulations (40 CFR Part 273) regarding universal wastes in OAC 3745-51. 

30 Universal wastes produced by Davis-Besse are disposed of or recycled in accordance with 

31 OEPA regulations.

32 Conditions and limitations for wastewater discharge by Davis-Besse are specified in National 

33 Pollution Discharge Elimination System (NPDES) Permit No. 2IB00011*ID. Radioactive liquid 

34 waste is addressed in Section 2.1.2 of this supplemental environmental impact statement 

35 (SEIS). Section 2.2.4 gives more information about the Davis-Besse NPDES permit and 

36 permitted discharges.

37 The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable 

38 facilities to supply information about hazardous and toxic chemicals to local emergency planning 

39 authorities and the EPA (42 USC 11001). On October 17, 2008, the EPA finalized several 

40 changes to the Emergency Planning (Section 302), Emergency Release Notification 

41 (Section 304), and Hazardous Chemical Reporting (Sections 311 and 312) regulations that were 

42 proposed on June 8, 1998 (63 FR 31268). Davis-Besse is subject to Federal EPCRA reporting 
Affected Environment

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1 requirements; thus, Davis-Besse submits an annual Section 312 (Tier II) report on hazardous 

2 substances to local emergency response agencies.

3 Pollution Prevention and Waste Minimization

4 Currently, Davis-Besse has waste minimization measures in place, which were verified by the 

5 NRC during the Davis-Besse site visit conducted in March 2011. In support of nonradiological 

6 waste-minimization efforts, the EPA’s Office of Prevention and Toxics has established a 

7 clearinghouse that supplies information about waste management and technical and operational 

8 approaches to pollution prevention (EPA 2010a). The EPA clearinghouse can be used as a 

9 source for additional opportunities for waste minimization and pollution prevention at Davis10 Besse, as appropriate.

11 The EPA also encourages the use of environmental management systems (EMSs) for 

12 organizations to assess and manage the environmental impacts associated with their activities, 

13 products, and services in an efficient and cost-effective manner. The EPA defines an EMS as 

14 “a set of processes and practices that enable an organization to reduce its environmental 

15 impacts and increase its operating efficiency.” EMSs help organizations fully integrate a wide 

16 range of environmental initiatives, establish environmental goals, and create a continuous 

17 monitoring process to help meet those goals. The EPA Office of Solid Waste especially 

18 advocates the use of EMSs at RCRA-regulated facilities to improve environmental performance, 

19 compliance, and pollution prevention (EPA 2010b). 

20 2.1.4 Plant Operation and Maintenance

21 Maintenance activities conducted at Davis-Besse include inspection, testing, and surveillance to 

22 maintain the current licensing basis of the facility and to ensure compliance with environmental 

23 and safety requirements. Various programs and activities currently exist at Davis-Besse to 

24 maintain, inspect, test, and monitor the performance of facility equipment. These maintenance 

25 activities include inspection requirements for reactor vessel materials and pressure vessel 

26 inservice inspection and testing, the structures monitoring program, and maintenance of water 

27 chemistry.

28 Additional programs include those implemented to meet technical specification surveillance 

29 requirements, those implemented in response to NRC generic communications, and various 

30 periodic maintenance, testing, and inspection procedures. Certain program activities are 

31 performed during the operation of the unit, while others are performed during scheduled 

32 refueling outages. Nuclear power plants must periodically discontinue the production of 

33 electricity for refueling, periodic inservice inspection, and scheduled maintenance. Davis-Besse 

34 refuels on an approximate 24-month interval (FENOC 2010c).

35 2.1.5 Power Transmission System

36 Three 345-kilovolt (kV) transmission lines connect Davis-Besse to the regional electric grid, all 

37 three of which are owned and operated by FirstEnergy Corporation (FirstEnergy). The 

38 transmission line description in this section discusses the entire length of the transmission lines

39 that were constructed to connect the Davis-Besse facility with the existing transmission system. 

40 At Davis-Besse, an onsite switchyard lies just east of the containment building and south of the 

41 cooling tower. Lines beyond this switchyard have been integrated into the regional electric grid 

42 and would stay in service regardless of Davis-Besse license renewal. Each of these lines is 

43 owned and operated by FirstEnergy and not the applicant, FENOC, and are, therefore, outside 

44 of NRC’s regulatory purview.
Affected Environment

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1 2.1.5.1 Transmission Line Descriptions

2 The three transmission lines are as follows (FENOC 2010c): 

3 • Bay Shore Line: From the site, this line 

4 extends 21 mi west and then northwest to 

5 the Bay Shore substation in Lucas 

6 County.

7 • Lemoyne Line: From the site, this line 

8 extends 21 mi west and then southwest to 

9 the Lemoyne Substation in Wood County.

10 • Beaver Line: From the site, this line extends 15 mi south and then southeast to a tie 

11 point between Toledo Edison and Ohio Edison’s line ownership in Sandusky County.

12 Figure 2.1-6 is a map of the Davis-Besse transmission system.

13

14 Figure 2.1-6. Davis-Besse Transmission System

15 Source: FENOC 2010c 

A transmission line right-of-way (ROW) is a strip 

of land used to construct, operate, maintain and 

repair transmission line facilities. The 

transmission line is usually centered in the ROW. 

The width of a ROW depends on the voltage of 

the line and the height of the structures. ROWs 

must typically be clear of tall-growing trees and 

structures that could interfere with a power line.
Affected Environment

2-14

1 All three transmission lines have 150-ft-wide ROWs that encompass approximately 1,000 ac 

2 (405 ha), most of which is comprised of flat to gently rolling agricultural land. In order to ensure 

3 power system reliability and to comply with applicable Federal and State regulations, 

4 FirstEnergy maintains transmission line ROWs to prevent physical interference that could result

5 in short-circuiting. This maintenance generally consists of removing or cutting tall-growing 

6 vegetation under the lines and removing or trimming of any trees near the edge of the ROWs 

7 that could fall on the lines. Table 2.1-1 lists the Davis-Besse transmission lines, and a more 

8 detailed discussion of transmission line maintenance appears in the following section.

9 Table 2.1-1. Davis-Besse Transmission Lines 

Substation 

Number of 

Lines kV

Approximate 

Distance ROW Width ROW Area

mi (km) ft (km) ac (ha)

Bay Shore Line 1 345 21 (34) 150 (0.05)(b) 381 (154)

Lemoyne Line 1 345 21 (34) 150 (0.05) 381 (154)

Beaver Line(a) 1 345 15 (24)(c) 150 (0.05)(d) 273 (110)

(a) This is also referred to as the Ohio Edison-Beaver substation. 

(b) ROW width is 150 ft except where it parallels the existing Bay Shore to Ottawa 138-kV line. In this region, the ROW is 145 ft, 

contiguous to the existing 100 ft for the 138 kV line. 

(c) The Beaver line has an approximate length of 59 mi. Only 15 mi were constructed for Davis-Besse, the remaining 44 miles were

constructed for a separate project. 

(d) ROW width was not specifically referenced in the applicants Environmental Report (ER). 

Source: FENOC 2010c

10 2.1.5.2 Transmission Line Maintenance 

11 FirstEnergy uses an Integrated Vegetative Management Program that combines manual, 

12 mechanical, biological, and chemical control techniques to maintain proper clearance from 

13 transmission lines and structures. The degree and type of clearance varies by line voltage and 

14 the type, growth rate, and branching characteristics of trees and vegetation. The majority of the 

15 in-scope transmission lines traverse agricultural land and wetland habitat. Those areas that are 

16 not already cultivated or developed in some other way are maintained to promote herbaceous 

17 vegetation, which includes shrubs, bushes, and other low-growing groundcover.

18 FirstEnergy maintains a “clearance zone” of 15 to 30 ft (4.6 to 9.2 meters (m)) on either side of 

19 transmission lines (FENOC 2011c). Within this clearance zone, FirstEnergy cuts back all 

20 incompatible vegetation (woody, tall-growing species) as low as practical or treats areas with 

21 herbicides on a 4-year cycle. Workers follow the current American National Standards Institute 

22 (ANSI) guideline document, “A300 Standards for Tree Care Operations,” which contains 

23 requirements and recommendations for tree care practices including pruning, lightning 

24 protection, and integrated vegetation management. In areas where herbicides are applied, 

25 FirstEnergy’s vegetative management protocol (FirstEnergy 2007) requires all herbicide 

26 applicators to hold a current and appropriate pesticide application license from the State. 

27 Transmission line maintenance workers and contractors must follow FirstEnergy’s established 

28 procedures, FirstEnergy Vegetative Management Specifications, and FirstEnergy Guide to 

29 Vegetation Control with Herbicides, to ensure compliance with all applicable State and Federal 

30 regulations.
Affected Environment

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1 2.1.6 Cooling and Auxiliary Water Systems

2 Davis-Besse uses a closed-cycle heat-dissipation system that withdraws water from, and 

3 discharges cooling tower blowdown to, Lake Erie. Davis-Besse has one natural draft hyperbolic 

4 cooling tower that dissipates heat from the plant’s steam cycle to the atmosphere. Unless 

5 otherwise noted, information contained in this section was gathered from FENOC’s ER, the final 

6 environmental statement (FES) related to the construction of Davis-Besse (AEC 1973), and the 

7 FES related to the operation of Davis-Besse (NRC 1975). Figure 2.1-7 illustrates Davis-Besse’s 

8 cooling water system.

Figure 2.1-7. Davis-Besse Cooling Water System

Source: AEC 1973 
Affected Environment

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1 2.1.6.1 Water Intake

2 When withdrawn, water from Lake Erie first enters a submerged intake crib located 

3 approximately 3,000 ft (900 m) offshore at a water depth of 14 ft (4.3 m). The intake crib is 

4 octagonal in shape, and water enters the intake crib via slots in the top of the structure. At its 

5 design capacity, the intake crib can withdraw a maximum of 42,000 gallons per minute (gpm) 

6 (160 cubic meters per minute (m3/min)). However, during normal operations, the intake crib 

7 withdraws 21,000 gpm (80 m3/min). Water flows into the intake crib at about 0.25 feet per 

8 second (fps) (0.08 meters per second (m/s)). 

9 After water enters the intake crib, it travels through an 8-ft (2.4-m) diameter intake pipe buried 

10 beneath Lake Erie’s bottom at a maximum rate of 1.8 fps (0.55 m/s). Once through the intake 

11 pipe, water flows into the intake canal, which is separated from the lake by a beach and 

12 beachfront dike. The intake canal functions as a reservoir for station water use. Water flows 

13 through the intake canal at about 0.11 fps (0.03 m/s).

14 The intake canal widens into a forebay as it reaches the intake structure. Before entering the 

15 intake structure, water in the intake canal flows through trash racks with 4 in. x 26 in. 

(10 cm x 66 cm) openings and then through traveling screens with 1 16 /4-in. (0.635-cm) openings 

17 and backwash sprays. These features prevent debris and aquatic organisms from entering the 

18 intake structure. Debris and aquatic organisms washed off the screens are deposited in a 

19 holding basin and disposed of onsite. Once water passes through the traveling screens, it 

20 enters one of three pumps that then circulate the water through the condenser for use as 

21 cooling water.

22 2.1.6.2 Cooing Tower Blowdown and Water Discharge 

23 Four pumps carry heated cooling water from Davis-Besse’s condenser at a rate of 480,000 gpm 

(1,800 m3

/min)—120,000 gpm (450 m3 24 /min) per pump. Heated cooling water that is pumped 

25 into the cooling tower is either lost to evaporation, drift, blowdown, or flows back to the 

26 circulating pumps. The cooling tower dissipates 98 percent of the total heat that the condenser 

27 adds to the cooling water. The remaining 2 percent of heat is discharged to Lake Erie as 

28 cooling water blowdown.

29 FENOC monitors and controls the cooling tower blowdown’s dissolved solids concentration and 

30 periodically chlorinates water that is returned to the circulating water system with sodium 

31 hypochlorite and sodium bromide to prevent algae growth within the system.

32 Before cooling tower blowdown returns to Lake Erie, it is routed to an open-air settling basin. In 

33 the settling basin, the cooling tower blowdown mixes with dilution water, which dissipates some 

34 of the heat load remaining in the cooling tower blowdown. From the settling basin, water travels 

35 1,300 ft (400 m) eastward through a 6-ft (1.8-m) diameter buried pipe and discharges into 

36 Lake Erie 9 ft (2.7 m) below the lake’s surface through a jet discharge. Water flows out of the 

discharge at about 3.6 fps (1.1 m/s), and an average of 11,000 gpm (42 m3 37 /min) of water 

discharges to Lake Erie during normal operations—9,225 gpm [35 m3 38 /min] of blowdown water 

plus 1,775 gpm [7 m3 39 /min] of dilution water.

40 2.1.6.3 Makeup Water

41 The service water system supplies makeup water to the cooling system to account for cooling 

42 tower blowdown loss. The service water system supplies approximately 18,450 gpm 

(70 m3

/min) to account for the 9,225 gpm (35 m3 43 /min) in evaporative loss and 9,225 gpm 
Affected Environment

2-17

(35 m3 1 /min) in blowdown loss. The service water system draws water from Lake Erie as 

2 previously described under the subsection “Water Intake.”

3 2.1.7 Facility Water Use and Quality

4 The dominant water usage at the Davis-Besse plant is the makeup water, obtained from 

5 Lake Erie, for the plant’s cooling system. Groundwater is not used as a resource at the site. 

6 The following sections describe water use by the facility.

7 2.1.7.1 Surface Water Use

8 As discussed in Section 2.1.6, the intake system is comprised of an intake crib, a pipeline, and 

9 an intake canal. The crib is a wooden structure about 3,000 ft offshore in Lake Erie, in water 

10 that is 11 ft below the lake’s low water datum (AEC 1973). Water entering the crib flows through 

11 an 8-ft diameter pipe buried beneath the lake bottom and then enters the intake canal. The 

12 canal is separated from the lake by a beach and a beachfront dike.

13 The intake flow rate averages 21,000 gpm (or 30 million gallons per day (mgd)) according to the 

14 applicant’s ER (FENOC 2010c).The facility has a state registration to withdraw water at a rate 

15 up to 50 mgd (Toledo Edison 1990).

16 Closed-system cooling at Davis-Besse is provided by the circulating water system (CWS). This 

17 system includes the condenser, natural draft cooling tower, circulating water pumps, makeup 

18 pumps, and water chlorination and chemical feed systems (FENOC 2010c). Four pumps 

19 withdraw water from the discharge channel of the cooling tower basin and deliver it to the 

20 condenser.

21 The Davis-Besse service water system (SWS) supplies cooling water to components in the 

22 turbine building during normal power-generating operation. Water for the SWS is obtained from 

23 Lake Erie. Three pumps are present at the intake structure, although only two are needed for 

24 normal operation (FENOC 2010c). The SWS also is the main source of makeup water for the 

25 CWS. Water is taken from the intake structure for use in the makeup water treatment system to 

26 supply high-quality water for primary and secondary plant makeup following a vendor’s 

27 treatment process to create demineralized water (FENOC 2010c). According to FENOC staff 

28 during the site audit, the vendor is Ecolochem, and reverse osmosis is used to produce the 

29 demineralized water. Pumps at the intake structure can also use lake water directly as makeup 

30 water (FENOC 2010c). 

31 Discharge of blowdown, other effluents, and dilution water to Lake Erie occurs via a submerged 

32 discharge structure 1,300 ft offshore (AEC 1973), as discussed in Section 2.2.4.

33 Domestic water for the facility is supplied by the offsite Carroll Township water system 

34 (FENOC 2010c). The source for this system is an intake on Lake Erie northwest of 

35 Davis-Besse. This water is filtered and treated to meet the requirements of the OEPA. The 

36 Carroll Township system pressure is maintained by an elevated 500,000-gallon storage tank 

37 (FENOC 2010b). 

38 2.1.7.2 Groundwater Use

39 The Davis-Besse facility does not use groundwater for plant operations. There are no plans to 

40 use groundwater from the site for current operations or during the period of extended operation 

41 (FENOC 2010b). 
Affected Environment

2-18

1 No drinking water wells are known to be within 5 mi of the site (ERM 2007). The groundwater is 

2 unsuitable as a drinking water source because of strong hydrogen sulfide odor and high levels 

3 of carbonate and total dissolved solids (ERM 2007). Private wells within 2 to 3 mi of the site are 

4 not used for drinking water but rather for irrigation and sanitary purposes 

5 (FENOC 2010c). 

6 During site construction, a grout curtain was installed, and dewatering wells were operated to 

7 remove groundwater from the excavation area. Dewatering no longer takes place.

8 2.2 Affected Environment

9 2.2.1 Land Use

10 Davis-Besse is located on the southwestern shore of Lake Erie in Ottawa County, Ohio. The 

11 site is comprised of 954 ac (386 ha), of which approximately 733 ac (297 ha) is undisturbed 

12 marshland and additional maintained lands. The Ottawa National Wildlife Refuge encompasses 

13 much of the marshland area (see Figure 2.1-1). The developed portion of the station, 

14 containing the power block and associated plant structures, is located approximately in the 

15 center of the site, 3,000 ft (914.4 m) from the shoreline, which provides a minimum exclusion 

16 distance of 2,400 ft (731.5 m) from any point on the site boundary (FENOC 2010c). 

17 To the west is the main unit of the Ottawa National Wildlife Refuge and the State of Ohio Magee 

18 Marsh Wildlife Area. On the southern boundary is the Toussaint River, which empties into Lake 

19 Erie. The entrance to the Magee Marsh Wildlife Area is less than 1 mi east of the power station. 

20 The land area surrounding the site is generally agricultural with no major industry in the vicinity.

21 Motor vehicle access to the site is by a two-lane road off State Highway 2, which is a two-lane 

22 artery located west of the station. U.S. Highway 80 is about 14 mi south of the site.

23 Oak Harbor is the nearest community to Davis-Besse at approximately 8 mi (13 km) southeast, 

24 Fremont 16 mi (26 km) south, and Toledo 25 mi (40 km) west northwest (FENOC 2010c). 

25 Features within a 6-mi radius of Davis-Besse are shown on Figure 2.1-2. Prominent features 

26 within 50 mi of the Davis-Besse plant site are shown in Figure 2.1-1. 

27 2.2.2 Air and Meteorology

28 The climate of Ohio is humid continental, characterized by a relatively wide range of seasonal 

29 variability, from warm and humid summers to cold winters (NCDC 2011a). Due to equal 

30 exposure to air from Canada and the Tropics, Ohio experiences drastic changes in daily 

31 weather and a wide range of extremes. Warm maritime tropical air masses bring summer heat 

32 and humidity into the State, but can also produce occasional mild winter days. Ohio also 

33 experiences cold and dry continental arctic air masses, which bring cool and bright summer 

34 days and very cold winter days. Northern counties in Ohio along Lake Erie experience 

35 moderating effects resulting from lake and land breezes, water’s higher heat capacity, and 

36 wintertime lake ice cover. 

37 Davis-Besse is located 0.5 mi (0.8 km) west off the southwestern shore of Lake Erie in Ottawa 

38 County, Ohio. The topography of the site and vicinity is flat with marsh areas bordering the 

39 lake. The upland area rises 10 to 15 ft (3.0 to 4.6 m) above the lake low-water datum level in 

40 the general surrounding area (FENOC 2010c). Davis-Besse’s topography has no special 

41 influence on local climate. Due to its proximity to Lake Erie, the site location experiences milder 
Affected Environment

2-19

1 climate, smaller diurnal and seasonal temperature ranges, higher cloudiness, and more 

2 precipitation than a site located further inland of comparable latitude.

3 The wind can blow from any direction in Ohio, depending on the relative location of 

4 high-pressure systems and storm systems that are continually alternating across the country. 

5 However, the primary wind direction over much of Ohio is from the southwest (NCDC 2011a). 

6 Meteorological data—wind speed, temperature, and precipitation—collected at the Toledo 

7 Express Airport, located about 37 mi (60 km) west of the Davis-Besse, is presented below. 

8 From 1955 through 2012, annual average temperature at the airport was 49.4 °Fahrenheit (F) 

9 (9.7 °Celsius (C)) (NCDC 2013a). January is the coldest month with an average minimum of 

10 16.5 °F (–8.6 °C), and July is the warmest month with an average maximum of 84.1 °F 

11 (28.9 °C). As mentioned above, the proximity to Lake Erie and other Great Lakes has a 

12 moderating effect on the temperature, and extremes seldom occur. In warm months, onshore 

13 breezes from the relatively cool lake make the site cooler than more inland areas. From 1955-

14 2012 the highest temperature, 104 °F (40.0 °C), was reached in July 1995. The lowest, -20 °F

15 (-28.9 °C), was reached in January 1984. 

16 In Ohio, precipitation from October through March occurs due to mid-latitude wave cyclones 

17 traversing the country, while the remainder of the year experiences varying amounts of 

18 convective thunderstorm rainfall (NCDC 2011a). From 1955 through 2012, annual precipitation 

19 at the airport averaged about 33.28 in. (84.5 cm) (NCDC 2013a). Precipitation is rather 

20 uniformly distributed throughout the year, with monthly precipitation ranging between 2.0 and 

21 3.5 in. (5.0 and 8.9 cm). At the airport, precipitation tends to be the highest in summer and 

22 lowest in winter. Heavy snowstorms typically occur once or twice a winter, but light snows are 

23 common (NOAA 2009). Snow in this area starts as early as October and continues as late as 

24 May. Most of the snow falls from November through March. The annual average snowfall at 

25 the airport is about 36.8 in. (93.5 cm).

26 Wind data collected at the airport indicates that wind blows predominantly from the west27 southwest or southwest throughout the year, with the exception of March and April, when the 

28 winds blow from the east or east-northeast (NCDC 2013a). From 2008 through 2012, average 

29 wind speed was about 7.7 miles per hour (mph). Average wind speeds were the highest in 

30 winter and lowest in summer.

31 The prominence of convective weather during the warm season causes Ohio to be subjected to 

32 thunderstorm-induced severe weather (NCDC 2011a). Severe weather events—such as floods, 

33 hail, high winds, thunderstorm winds, winter storms, and tornadoes, have been reported for 

34 Ottawa County (NCDC 2013b). From January 2000 through October 2012, the following severe 

35 weather events were reported for Ottawa County:

36 • Floods: 4, 

37 • Hail events: 74, 

38 • Thunderstorm winds: 89, 

39 • High wind events: 27, 

40 • Tornadoes: 4, and

41 • Winter storms: 17. 

42 Hurricanes and tropical storms were not reported from 2000 through 2012 in the area.
Affected Environment

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1 Recent research on global climate change impacts in the U.S. developed by the U.S. Global 

2 Change Research Program (USGCRP), a Federal Advisory Committee (USGCRP 2009), has 

3 been considered in preparation of this SEIS. In the near term (2010 through 2029), the 

4 temperatures around Davis-Besse are projected to rise an additional 2 to 3 °F (1.1 to 1.7 °C), 

5 compared to the recent past (1961 through 1979). Model projections indicate that, due to the 

6 northward shift of storm tracks in winter and spring, northern areas will become wetter, while 

7 southern areas, particularly in the west, will become drier (USGCRP 2009). Higher 

8 temperatures and reduced lake ice in winter, due to the rise in temperatures, will cause more 

9 evaporation and will likely result in reductions of lake water levels (USGCRP 2009). Average 

10 lake water levels depend on the balance between precipitation (and corresponding runoff) in the 

11 Lake Erie Basin and evaporation and outflow. Based on NOAA’s Great Lakes model, water 

12 level changes in Lake Erie were projected to lower by about 0.2 ft (0.06 m) under a higher 

13 emissions scenario from 2010 through 2039, which encompasses the license renewal period

14 (USGCRP 2009). 

15 The onsite meteorological observation system at Davis-Besse has been in place since 

16 October 1968. This monitoring system will continue to serve in that capacity for the period of 

17 extended operations with no major changes or upgrades anticipated. The current 

18 meteorological monitoring system consists of primary and auxiliary towers and equipment 

19 shelters that collect meteorological data and process the information into usable data. The 

20 primary 328-ft (100-m) meteorological tower is located about 2,950 ft (900 m) southwest of the 

21 reactor building, and the 33-ft (10-m) auxiliary tower is located near the primary tower. The 

22 primary tower has instruments at three levels (33 ft (10 m), 246 ft (75 m), and 328 ft (100 m)). 

23 The base of the tower is 574 ft (175 m) above MSL (FENOC 2005). Wind speed and wind 

24 direction are collected at 33 ft (10 m) on the auxiliary tower and 246 ft (75 m) and 328 ft (100 m) 

25 on the primary tower. Temperature differences are measured between 328 and 33 ft levels and 

26 between the 246 and 33 ft levels on the primary tower to determine the atmospheric stability. 

27 Ambient temperature, barometric pressure, dew point, and solar insolation is collected at the 

28 33 ft (10 m) level on the primary tower. Precipitation is collected near the base of the auxiliary 

29 tower.

30 Each sensor is wired to environmentally controlled shelters located near the base of the towers, 

31 which house the recording and signal-conditioning equipment. Signals from tower-mounted 

32 instruments are converted from analog to digital at the meteorological data processing system 

33 (MDPS), which collects all real-time data and yields 15-minute and hourly averages. These 

34 outputs are transmitted on a continuous basis directly to the control room and emergency 

35 control room via data acquisition display system (DADS) to display and record meteorological 

36 data. Most of these signals are also fed to strip-chart recorders.

37 2.2.2.1 Air Quality Impacts

38 The Division of Air Pollution Control (DAPC) of the OEPA is the regulatory agency whose 

39 primary responsibility is to achieve and maintain air quality that is protective of public health and 

40 the natural environment. In doing so, DAPC reviews, issues, and enforces permits for 

41 installation and operation of sources of air pollution and operates an extensive ambient air

42 monitoring network. DAPC also oversees an Automobile Emission Testing Program to minimize 

43 mobile source emissions.

44 A facility is defined as a “major” source if it has the potential to emit 100 tons (90.7 metric tons) 

45 or more per year of one or more of the criteria pollutants, 10 tons (9.07 metric tons) or more per 

46 year of any of the listed hazardous air pollutants (HAPs), or 25 tons (22.7 metric tons) or more 
Affected Environment

2-21

1 per year of an aggregate total of HAPs. Under the CAA, the U.S. EPA has set National Ambient 

2 Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the 

3 environment (40 CFR Part 50). NAAQS are established for criteria pollutants—carbon 

4 monoxide (CO); lead (Pb); nitrogen dioxide (NO2); particulate matter with an aerodynamic

5 diameter of 10 microns or less and 2.5 microns or less (PM10 and PM2.5, respectively); ozone 

6 (O3); and sulfur dioxide (SO2), as shown in Table 2.2-2 (EPA 2012a). A HAP is defined as any 

7 pollutant listed under Section 112(b) of the Federal Clean Air Act.

8 Major sources are subject to Title V of the Clean Air Act (CAA) (42 U.S.C. 7401 et seq.), which 

9 standardizes air quality permits and the permitting process across the U.S. Permit stipulations 

10 include regulating source-specific emission limits, monitoring, operational requirements, 

11 recordkeeping, and reporting. A “synthetic minor” (or “conditional major”) source has the 

12 potential to exceed major source emission thresholds but is the one that avoids major source 

13 requirements by accepting permit conditions limiting emissions below major source thresholds. 

14 The “small” (or “minor”) source has no potential to exceed major source emission thresholds.

15 Davis-Besse has many sources of criteria pollutants and HAPs to include the following: 

16 • combustion sources, such as auxiliary boiler, station blackout diesel generators, 

17 emergency diesel generators, and fire pump engines; 

18 • bulk material storage, such as diesel, gasoline, and lube oil storage tanks; 

19 • other sources, such as natural draft cooling towers and sandblasting and painting 

20 operations; and

21 • miscellaneous sources, such as small diesel generators, welding, and laboratory hoods. 

22 No OEPA air permits have been issued to Davis-Besse for emissions to the atmosphere during 

23 normal operations (OEPA 2011a). The only conventional air pollution sources at Davis-Besse 

24 are the emergency diesel generators and startup boilers, which are not used during normal 

25 operations. Davis-Besse currently has one operation permit for an auxiliary boiler (Permit 

26 Application No. 0362000091B001) (FENOC 2010c). Davis-Besse applied to OEPA for a 

27 “synthetic minor” permit to encompass all site-wide emission sources on July 9, 2012

28 (FENOC 2013). 

29 Air emission sources at Davis-Besse emit criteria pollutants, volatile organic compounds

30 (VOCs), and HAPs into the atmosphere. Emissions inventory data reported to the OEPA for 

31 calendar years 2006 through 2010 are presented in Table 2.2-1, which includes air emissions 

32 from all stationary sources at the site (FENOC 2011c). During the period from 2006 through 

33 2010, emissions of criteria pollutants, VOCs, and HAPs varied from year to year, but all reported 

34 annual emissions were well below the emission thresholds for a major source. In recent years, 

35 Davis-Besse has not received a notice of violation (NOV) associated with site operations from 

36 the OEPA. 

37 On February 25, 2010, NRC issued an NOV to Davis-Besse associated with the failure to 

38 implement the emergency classification and action level scheme during an actual event for an 

39 explosion in the switchyard on June 25, 2009 (NRC 2010). During the event, the transformers 

40 caught on fire. During fires, polychlorinated biphenyls (PCBs) and chlorinated benzenes in the 

41 transformers can produce polychlorinated dibenzofurans (PCDFs) and polychlorinated 

42 dibenzo-p-dioxins (PCDDs), respectively (EPA 1987). EPA determined that the continued use 

43 of PCBs-contaminated transformers (50 to 500 ppm PCBs) and non-PCB transformers (less 

44 than 50 ppm PCBs) did not present unreasonable risks to public health. In 1992, Davis-Besse
Affected Environment

2-22

1 completed a program to eliminate PCB transformers onsite; electrical transformers were either

2 changed out with non-PCB fluid or retrofilled with non PCB-liquid (FENOC 2011b). Hence,

3 potential impacts of emissions from non-PCB transformers at the site would likely be minor.

4 As shown in Table 2.2-1, annual emissions for greenhouse gases (GHGs), which include those 

5 from stationary and mobile sources, are presented in terms of carbon dioxide equivalent 

(CO2e). 1 6 Total annual GHG emissions from Davis-Besse was 4,693 metric tons CO2e in 2010 

7 (FENOC 2011c), which is well below the U.S. EPA’s mandatory reporting threshold of 

8 25,000 metric tons CO2e per year (74 FR 56264).

9 Table 2.2-1. Annual Emissions Inventory Summaries for Sources at Davis-Besse, 

10 2006–2010

Annual Emissions (tons/yr)(a)

Year CO NOx PM10/PM2.5 SOx VOCs HAPs CO2e

2006 2.31 9.72 0.54 7.35 0.17 0.8(b) -

(c)

2007 1.14 4.31 0.14 1.37 0.11 0.8 -

2008 2.42 10.16 0.56 2.35 0.18 0.8 -

2009 1.90 7.77 0.39 1.87 0.15 0.8 -

2010 2.31 9.75 0.56 2.09 0.17 0.8 5,173 (4,693)(d)

(a) CO = carbon monoxide; CO2e = carbon dioxide equivalent; HAPs = hazardous air pollutants; NOx = nitrogen oxides; 

PM2.5 = particulate matter ≤2.5 μm; PM10 = particulate matter ≤10 μm; SOx = sulfur oxides; and VOCs = volatile organic compounds.

(b) Maximum HAP emissions are estimated based on maximum potential operating hours (500 hours per year for diesel generators 

and fire pumps and 8,760 hours per year for auxiliary boilers). Actual emissions are substantially lower than these maximum 

emissions.

(c) A hyphen denotes that the data are not available. 

(d) Values in parentheses are in metric tons carbon dioxide equivalent. 

Source: FENOC 2011c

11 The CAA established two types of NAAQS—primary standards to protect public health, 

12 including sensitive populations, such as asthmatics, children, and the elderly and secondary 

13 standards to protect public welfare, including protection against decreased visibility and damage 

14 to animals, crops, vegetation, and buildings. Any individual state can have its own State 

15 Ambient Air Quality Standards (SAAQS), but SAAQS must be at least as stringent as the 

16 NAAQS. If a state has no standard corresponding to one of the NAAQS or the SAAQS is not as 

17 stringent as the NAAQS, then the NAAQS apply. The State of Ohio has its own SAAQS 

18 (OEPA 2011b), which are almost the same as the NAAQS presented in Table 2.2-2. 

 

1 A measure used to compare the emissions from various greenhouse gases (GHG) on the basis of their 

global warming potential (GWP), defined as the cumulative radiative forcing effects of a gas over a 

specified time horizon resulting from the emission of a unit mass of gas relative to a reference gas, CO2. 

The carbon dioxide equivalent (CO2e) for a gas is derived by multiplying the mass of the gas by the 

associated global warming potential GWP. The carbon dioxide equivalent for a gas is derived by 

multiplying the tons of the gas by the associated GWP. For example, the GWP for CH4 is estimated to be 

21; thus, one 1 ton of CH4 emission is equivalent to 21 tons of CO2 emissions.
Affected Environment

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1 Table 2.2-2. National Ambient Air Quality Standards and Ohio State Ambient Air Quality 

Standards(a) 2 

Pollutant(b) Averaging Time

NAAQS

Value Type SAAQS (c)

CO 1-hour 35 ppm

(40 mg/m3) 

P 35 ppm

8-hour 9 ppm

(10 mg/m3)

P 9 ppm

Pb Quarterly average -

(d) - 1.5 μg/m3

Rolling 3-month average 0.15 μg/m3 (e) P, S -

NO2 1-hour 100 ppb P -

Annual

(arithmetic average)

53 ppb P, S 53 ppb

(100 μg/m3) 

PM10 24-hour 150 μg/m3 P, S 150 μg/m3

PM2.5 24-hour 35 μg/m3 P, S 35 μg/m3

Annual

(arithmetic average)

12.0 μg/m3 P 15 μg/m3

Annual

(arithmetic average)

15 μg/m3 S 15 μg/m3

O3 1-hour 0.12 ppm(f) P, S -

8-hour 0.08 ppm

(1997 standard)

P, S 0.08 ppm

8-hour 0.075 ppm

(2008 standard)

P, S -

SO2 1-hour 75 ppb P -

3-hour 0.5 ppm S 1,300 μg/m3 (0.5 ppm)

24-hour 365 μg/m3 (0.14 ppm)

Annual

(arithmetic average)

80 μg/m3 (0.03 ppm)

(a) Refer to 40 CFR Part 50 for detailed information on attainment determination and reference method for monitoring. 

(b) CO = carbon monoxide; NO2 = nitrogen dioxide; O3 = ozone; Pb = lead; PM2.5 = particulate matter ≤2.5 μm; PM10 = particulate 

matter ≤10 μm; and SO2 = sulfur dioxide. 

(c) P = primary standards, which set limits to protect public health, including the health of “sensitive” populations such as 

asthmatics, children, and the elderly. S = secondary standards, which set limits to protect public welfare including protection 

against decreased visibility, damage to animals, crops, vegetation, and buildings. 

(d) A hyphen denotes that no standard exists. 

(e) Final Rule signed October 15, 2008. The 1978 lead standard (1.5 μg/m3

 as a quarterly average) remains in effect until 1 year 

after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 

standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

(f) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing obligations under that standard 

(“anti-backsliding”). 

(g) OEPA references this value as 0.053 ppm 

Source: EPA 2013b; OEPA 2011b
Affected Environment

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1 Areas considered to have air quality as good as or better than NAAQS are designated by EPA 

2 as “attainment areas.” Areas in which air quality is worse than NAAQS are designated as 

3 “non-attainment areas.” Areas that previously were non-attainment areas but where air quality 

4 has since improved to meet the NAAQS are redesignated “maintenance areas,” subject to an air 

5 quality maintenance plan. Ottawa County, which encompasses Davis-Besse, is located in the 

6 Sandusky Intrastate Air Quality Control Region (AQCR) (40 CFR 81.203), including 

7 north-central counties in Ohio, such as Erie, Huron, Sandusky, and Seneca Counties. Ottawa 

8 County is designated as an attainment area for carbon monoxide (CO), lead (Pb), nitrogen 

9 dioxide (NO2), particulate matter less than 2.5 μm (PM2.5), for particulate matter less than 10 μm

10 (PM10), and is not designated for sulfur dioxide (SO2) (OEPA 2013). Lucas and Wood Counties 

11 abutting Ottawa County to the north and west, respectively, are designated as maintenance 

12 areas for 1997 ozone 8-hour NAAQS (EPA 2013a). The nearest non-attainment area is 

13 Monroe County, Michigan, for PM2.5 NAAQS (EPA 2013a). 

14 Through operation of a network of air monitoring stations, OEPA has determined that the area 

15 complies with the NAAQS and SAAQS. Only PM10 was collected in Ottawa County until 2001 

16 and in other counties in the Sandusky Intrastate AQCR until 2004 (EPA 2011h). However, PM10

17 monitoring was discontinued due to consistently low concentrations in the Sandusky Intrastate 

18 AQCR. The nearest monitoring station around Davis-Besse is located about 13 mi (21 km) 

19 west-northwest in Lucas County, where ozone is measured. There are five monitoring stations 

20 in the city of Toledo, Lucas County. These stations are located within a range of about 21 mi 

21 (34 km) to 29 mi (47 km) west or west-northwest of Davis-Besse. Pollutants monitored at these 

22 stations include PM10, PM2.5, O3, and SO2. Two additional monitoring stations can be found in 

23 Waterville, Lucas County and Bowling Green, Wood County. These stations are located 33 mi 

24 (53 km) and 31 mi (50 km), respectively, west-southwest of Davis-Besse. Ozone is the pollutant 

25 measured at these stations. 

26 While the NAAQS place upper limits on the levels of air pollution, prevention of significant 

27 deterioration (PSD) regulations (40 CFR 52.21) place limits on the total increase in ambient 

28 pollution levels above established baseline levels for SO2, NO2, PM10, and PM2.5, thus 

29 preventing “polluting up to the NAAQS.” These allowable increments are smallest in Class I 

30 areas, such as national parks and wilderness areas, and less limiting in other areas. A major 

31 new or modification of an existing major source located in an attainment or unclassified area 

32 must meet stringent control technology requirements. As a matter of policy, EPA recommends 

33 that the permitting authority notify the Federal Land Managers (FLMs) when a proposed PSD 

34 source will be located within 62 mi (100 km) of a Class I area. If the source’s emissions are 

35 considerably large, EPA recommends that sources beyond 62 mi (100 km) be brought to the 

36 attention of the FLMs. The FLMs then become responsible for demonstrating that the source’s 

37 emissions could have an adverse effect on air quality-related values (AQRVs), such as scenic, 

38 cultural, biological, and recreational resources. There are no Class I areas in Ohio, and none of 

39 the Class I areas in other states are situated within the aforementioned 62-mi (100-km) range. 

40 The nearest Class I area is Otter Creek Wilderness Area in West Virginia managed by the 

41 U.S. Forest Service (40 CFR 81.435), which is located about 253 mi (407 km) southeast of 

42 Davis-Besse. Considering the locations and elevations of any Class I areas around 

43 Davis-Besse, prevailing southwesterly wind directions, distances from Davis-Besse, and the 

44 minor nature of air emissions from Davis-Besse, there is little likelihood that activities at 

45 Davis-Besse would adversely impact air quality and AQRVs in any of these Class I areas.
Affected Environment

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1 2.2.3 Geologic Environment

2 Davis-Besse Station is situated in the eastern lake section of the central lowland physiographic 

3 province (USGS 2011). The topography is characterized as being very flat, resulting from 

4 fine-grained sediment deposition in a glacial lake. The marsh bottom is slightly below lake level, 

5 while the upland areas are about 6 ft above lake level (FENOC 2010c). 

6 Soil unit mapping by the National Resources Conservation Service (NRCS) (NRCS 2011) 

7 identifies the majority of the Davis-Besse site as gently sloping fill soils. Adjacent areas are 

8 Toledo silty clay, derived from glaciolacustrine sediments. The Toledo silty clay is very poorly 

9 drained, has a slope of 0 to 2 percent, and is ponded in the nearby marsh areas.

10 The surface material is comprised of glaciolacustrine sediments (cohesive brown silt with some 

11 sand and clay) and till (brown to dark gray silty clay), along with fill (ERM 2008). Below the 

12 unconsolidated material, at a depth of about 13 ft, is the Silurian age Tymechtee-Greenfield 

13 Formation (AEC 1973). The uppermost portion of the bedrock is about 10 ft of laminated 

14 dolomite (thin layers of interbedded dolomite, gypsum, anhydrite, and shale) (ERM 2008). 

15 Below this is about 10 ft of massive dolomite, underlain by laminated dolomite (ERM 2008).

16 Foundations for Seismic Class I station facilities are mat or strip footings on bedrock, glacial till, 

17 or compacted granular fill, or pier footings into bedrock (FENOC 2010b). The nearest fault is 

18 the Bowling Green Fault, located 35 mi west of the site (FENOC 2010b). No evidence of fault 

19 traces, offset geomorphologic features, shear zones, faults, sand boils, soil flows, or any other 

20 direct or indirect physical effects of prior earthquakes have been observed in site investigations 

21 (FENOC 2010b). The U.S. Geological Survey (USGS) Earthquake Hazards Program 

22 designates the Davis-Besse region as having a 0.02 g peak horizontal acceleration with a 

23 10 percent probability in 50 years, and a 0.06 g peak horizontal acceleration with a 2 percent

24 probability in 50 years (USGS 2008).
Affected Environment

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1 

2 Figure 2.2-1. Seismic Hazard Map 

3 Peak Ground Acceleration - 2% Probability in 50 years 

4 Source: USGS 2008 

5 The Ohio Department of Natural Resources, Division of Geologic Survey, as part of the Ohio 

6 seismic network, compiles and updates the occurrences of seismic events. The database 

7 includes information such as the epicenter location, magnitude, time and date, and whether the 

8 earthquake was measured with an instrument or if the information is reliant on historical 

9 information and reports. The database reflects over 220 earthquakes that have occurred in 

10 Ohio since 1804. The mapping software shows four earthquakes that had an epicenter within 

11 approximately 20 mi of the Davis-Besse site (ODNR 2008). Figure 2.2-2 shows the locations of 

12 the epicenters.

13 On January 1, 1984, at 8:14 pm, a 2.6 magnitude earthquake (as measured on the Richter 

14 scale) occurred approximately 20 mi west of Davis-Besse. The earthquake occurred in Lucas 

15 County, east of Toledo, Ohio. Four historical and one instrumental earthquake, ranging from a 

16 magnitude of 2 to 3.5 have been recorded within 2 to 8 mi in this general vicinity (ODNR 2008). 

17 On April 12, 2007, at 10:03 pm, a 2.5 magnitude earthquake occurred approximately 11 mi 

18 northeast of Davis-Besse. The earthquake occurred in western Lake Erie approximately 5 km 

19 below the calculated surface. This occurrence did not have any reports of being felt. Prior to 

20 this incident, no previous records of seismic activity were recorded or historically reported in this 

21 general area of Lake Erie (ODNR 2008). 
Affected Environment

2-27

1 On April 24, 2007, at 1:09 am, a 2.3 magnitude earthquake occurred approximately 14 mi 

2 northeast of Davis-Besse. The earthquake occurred in western Lake Erie approximately 5 km 

3 below the calculated surface. This occurrence did not have any reports of being felt. Prior to 

4 this incident; the Geological Survey of Canada recorded microearthquakes in this approximate 

5 location at their station on Pelee Island on April 15 and two on April 17 (ODNR 2008). 

6 On May 13, 2010, at 1:02 pm, a 2.6 magnitude earthquake occurred approximately 18 mi 

7 southwest of Davis-Besse. The earthquake occurred approximately 3 mi west of Hessville, 

8 Ohio. Approximately 8 mi from this epicenter, a historical earthquake of Magnitude 3.3 was 

9 recorded (ODNR 2008).

Figure 2.2-2. Earthquake Epicenters Near Davis-Besse 

Source: ODNR 2008 

10 2.2.4 Surface Water Resources

11 Davis-Besse’s discharge to surface water is permitted under an NPDES permit (OEPA 2006b), 

12 which was issued on August 14, 2006. The permit specifies discharge limits and sampling 

13 frequency at the main station outfall (Outfall 001) for dissolved oxygen, pH (acidity and 

14 alkalinity), total residual oxidants (TRO), total residual chlorine (TRC), and chlorination and 

15 bromination duration. It also calls for the sampling frequency for water temperature and copper 

16 concentration, and for the 24-hour estimate of flow rate. Permit requirements regarding TRO 

17 and TRC specify that these cannot be discharged from any single generating unit for more than 
Affected Environment

2-28

1 2 hours per day. A modification to the permit 

2 (OEPA 2006a) that was proposed by the state 

3 and accepted by FENOC, allowed such 

4 discharges to be greater than 2 hours in duration, 

5 provided the discharge is dosed with a dehalogenating agent to achieve specified limits of TRC 

6 and TRO.

7 Outfall 001 is downstream of the “collection box,” which receives discharges from the cooling 

8 tower blowdown, settling basins, stormwater runoff, and radwaste systems. These discharges 

9 are combined, within the collection box, with dilution water (FENOC 2010d). The dilution water 

10 is pumped directly from the intake to the collection box to reduce concentrations in the 

11 discharge water. Water flows by gravity from the collection box, through a 6-ft diameter 

12 underground pipe, to the discharge structure about 1,300 ft offshore (AEC 1973). The 

13 combined average flow rate at Outfall 001 is 29.0 mgd (FENOC 2010d). Average flow rates of 

14 contributions are 13.50 mgd of blowdown, 9.00 mgd of dilution water, 7.05 mgd from the primary 

15 and secondary heat exchangers, and small amounts from water treatment and radwaste 

16 systems (FENOC 2010d). 

17 Several internal outfalls supply discharge to the collection box. These include outfalls receiving 

18 water from turbine building drains, boiler drains, pump house sumps, the wastewater treatment 

19 system, water treatment residues, condensate polishing resins, and stormwater runoff 

20 (Davis-Besse 2004a, 2009). In addition to the NPDES discharge requirements described for 

21 Outfall 001, these internal outfalls may have discharge limits or sampling frequencies or both for 

22 total suspended solids, oil and grease, and biochemical oxygen demand (OEPA 2006b). Some 

23 of the outfalls require the monitoring of flow, specific metals, asbestos, arsenic, color, odor, and 

24 turbidity.

25 The facility has a group of onsite basins for wastewater (Brown 2010). The southernmost is the 

26 sewage treatment plant pond. The central one is the No. 1 settling basin, which receives 

27 discharge from the sewage treatment plant pond along with demineralizer system discharge and 

28 building sumps and drains. The northernmost is the No. 2 settling basin, which receives 

29 discharge from a screen wash outfall and from the No. 1 settling basin.

30 The NPDES permit calls for an annual sewage sludge report to be filed with the OEPA, 

31 describing the amount of sludge, the method of disposal, and a summary of all analyses made 

32 on the sludge. During the site audit, FENOC staff stated that the sewage sludge is analyzed for 

33 radioactivity using gamma spectroscopy. The facility documented a procedure for this 

34 monitoring and calls for approval of the radiation protection supervisor for release of the sludge 

35 (Davis-Besse 2004b). This monitoring is performed in support of NRC guidance (NRC 1988), 

36 which encourages licensees to monitor their sewage sludge. Annual submittals to the OEPA for 

37 the last 5 years indicate that 30,000 to 129,700 gallons of sewage sludge have been removed 

38 each year and transferred to Sandusky Waste Water Treatment Plant 

39 (FENOC 2007, 2008, 2009, 2010a, 2011a). 

40 The liquid radioactive waste system is one of the internal outfalls that discharge into the 

41 collection box. Its effluents, when mixed in the collection box with dilution water and other flows 

42 (as described above), meet the requirements in Appendix B of 10 CFR Part 20 and 

43 10 CFR Part 50 (FENOC 2010c). 

44 An EPA online database indicates that Davis-Besse has had no effluent exceedances in the last 

45 3 years and no Clean Water Act NOVs, enforcement actions, or penalties in the last 5 years 

NPDES permits require the monitoring of TRO 

and TRC due to chlorines toxicity on aquatic 

species.
Affected Environment

2-29

1 (EPA 2011a, 2011b). In addition, detailed online discharge data from 2006 through 2010 

2 (EPA 2011c) were inspected by NRC staff, and no infractions were noted. Infractions noted 

3 elsewhere by the state have been a pH violation of 0.1 standard units (S.U.) above the limit of 

4 9.0 S.U. (OEPA 2010a) and a dissolved oxygen measurement frequency violation 

5 (OEPA 2010b).

6 An application for an NPDES permit renewal (FENOC 2010d) was made prior to the expiration 

7 of the 5-year permit, granted in 2006. The application includes a diagram of all site flows 

8 (intake, CWS, SWS, blowdown, process waters, sanitary effluent, stormwater, marsh discharge) 

9 along with the associated flow rates. It also includes outfall criteria for maximum daily 

10 concentration and, in some cases, maximum daily mass for numerous chemical and physical 

11 parameters. The permit application includes EPA Form 2F, “Application for Permit to Discharge 

12 Storm Water Discharges Associated with Industrial Activity.” On the form, the applicant listed 

13 the stormwater treatment at specific outfalls, including floatation and sedimentation. The form 

14 also states that “there have been no significant leaks or spills of any toxic or hazardous 

15 pollutants at the Davis-Besse Plant in the last three years.” 

16 During the site audit, FENOC staff indicated there have been violations of the NPDES permit. 

17 These NOVs would not, however, appear in the OEPA online database unless the violations 

18 were ongoing, and changes were not made to correct the problem. They provided several 

19 examples. In December 2010, they failed to sample on a 2-week sampling frequency. In 

20 August 2010, they observed a high pH reading at the training center pond. Historically, they 

21 have received several NOVs due to overuse of chlorine in the SWS and CWS. A dechlorination 

22 system has, therefore, been in place for about 15 years with treatment occurring at the 

23 collection box.

24 FENOC staff explained, during the site audit, a change anticipated in their chemical usage in 

25 2012. They plan to use zinc acetate, which is commonly used in PWRs to lower the risk of 

26 corrosion cracking during operations and outages. They intend to submit an application to 

27 make this change to the OEPA.

28 Blowdown from the cooling tower takes place in order to limit the dissolved solids concentration 

29 in the circulating water. Slime and algae control in the CWS is provided by addition of sodium 

30 hypochlorite (FENOC 2010c). Sodium bromide may also be added to increase the biocide 

31 treatment without increasing the level of chlorine (FENOC 2010c). A chemical feed system is 

32 used to control scaling and to disperse silt (FENOC 2010c). 

33 The lake intake and pipe are monitored by divers for silt and debris, according to FENOC staff 

34 during the site audit. The discharge structure in Lake Erie is about 1,300 ft offshore where the 

35 lake is about 9 ft deep (AEC 1973). Beyond the discharge point, the lake bottom is covered with 

36 a riprap rock surface for about 200 ft (60 m) to minimize scouring and turbidity.

37 According to FENOC staff during the site audit, dredging does not take place in the intake 

38 canal’s safety-related portion, which is the portion closest to the site structures and which 

39 satisfies NRC regulations (RG 1.27) by holding an appropriate volume of water for a safe 

40 shutdown. This portion of the canal has walls designed to satisfy seismic safety requirements. 

41 In the remaining portion of the canal, hydraulic dredging last took place in 2008 due to silt 

42 buildup. Along the southeast edge of the canal, settling pits were excavated in non-wetland 

43 areas to receive the hydraulic dredging discharge. The canal is monitored for silt every 3 years. 

44 In the past, spoils were placed at the Unit 2 site south of the operating Unit 1 site.
Affected Environment

2-30

1 Stormwater at the site drains to the collection box or to the training center pond 

2 (FENOC 2010d). From the pond, stormwater flows via an outfall to Navarre Marsh Pool No. 3, 

3 where it may be pumped to the Toussaint River (FENOC 2010d). Several pools in the 

4 surrounding marsh are pumped by Davis-Besse to reduce their volume under the direction of 

5 the U.S. Fish and Wildlife Service (FWS). Discharge is to Lake Erie or the Toussaint River. 

6 Davis-Besse has a stormwater pollution prevention plan that includes procedures for 

7 inspections, best management practices, employee training, and spill response procedures 

8 (Davis-Besse 2009). Stormwater sampling does not normally take place, but it was performed 

9 for the NPDES application.

10 2.2.5 Groundwater Resources

11 The local shallow stratigraphy is described by ERM (2008) and summarized above in 

12 Section 2.2.3. Groundwater flow in the glacial drift, shallow dolomite, and deeper dolomite is 

13 generally to the east toward the marshes and Lake Erie; however, flow is complicated by the 

14 grout curtain, fractures in the bedrock, and excavated bedrock (ERM 2008).

15 The nearest aquifer designated as a sole source aquifer by the U.S. EPA is the Catawba Island

16 aquifer (OEPA 2011). This aquifer is over 10 mi (16 km) east of the facility, across a portion of 

17 Lake Erie.

18 The site has had a total of 78 historical wells (in 39 locations with pairs of shallow and deep 

19 wells), including some installed for the purpose of dewatering the excavation during site 

20 construction (ERM 2008). Some of these wells are used as groundwater monitoring wells. 

21 However, 24 of these wells (12 shallow and deep pairs) cannot be located and are assumed to 

22 have been destroyed.

23 In response to the Nuclear Energy Institute’s (NEI’s) groundwater protection initiative, 16 new 

24 monitoring wells were installed based on the site hydrogeology (Figure 2.2-3). Groundwater 

25 sampling takes place at the new wells plus some of the historical wells. Tritium monitoring 

26 results from June through August of 2007 indicated that the highest tritium observed in the 

27 monitoring well network (up to 7,535 pCi/L in well 32S) is east of the containment and is higher 

28 in shallow dolomite than in deep dolomite (ERM 2008). The background level of tritium has 

29 been established to be 178 to 348 pCi/L (ERM 2008). The U.S. EPA drinking water limit is 

30 20,000 pCi/l (40 CFR 141.66).
Affected Environment

2-31

Figure 2.2-3. Groundwater Monitoring Well Locations

Source: FENOC 2011c 

1 Graphs of tritium results at six wells with relatively high tritium levels were provided by FENOC 

2 staff for viewing during the site audit. The graphs of tritium concentrations are included as 

3 Figure 2.2-4 and Figure 2.2-5. The graphs covered the period of summer 2007 through 

4 December 2010 at wells 30S, 31S, 32S, 34S, 37S, and 105A. The activity concentrations in the 

5 wells showed erratic behavior from 2007 to the spring of 2010. The highest levels were at 

6 wells 32S and 31S, which were both above 7,000 pCi/L in summer 2007. Well 32S was above 

7 6,000 pCi/L in spring 2007, but all other measurements in this 2007 to 2010 timeframe at the six 

8 wells were below 5,000 pCi/L. Beginning in spring 2010 and continuing to December 2010, 

9 tritium levels in all six wells showed a strong downward trend. All six wells have been below 

10 2,000 pCi/L in the October through December 2010 timeframe. The tritium levels continued to 

11 trend downward through 2011, and, by the end of the year, tritium levels in all wells were below 

12 1,000 pCi/L. The maximum value reported at the end of 2011 was 794 pCi/L in well 37s 

13 (FENOC 2011b). 
Affected Environment

2-32

Figure 2.2-4. 2007–2011 Groundwater Monitoring Tritium Concentrations 

Source: FENOC 2011c 

Figure 2.2-5. May 2010–December 2010 Groundwater Monitoring Tritium Concentrations 

Source: FENOC 2011c 
Affected Environment

2-33

1 ERM (2008) provided a plausible explanation regarding tritium release and migration. It stated 

2 that “potential inadvertent releases from the power block, including the spent fuel pool, would 

3 migrate vertically down through the unsaturated zone to the water table. Potential releases from 

4 structures below ground could release tritium directly to the upper or lower dolomite unit.” 

5 Potential tritium sources in the power block are the reactor containment, auxiliary building, 

6 circulating water pump house, turbine building, and borated water storage tank (ERM 2007), 

7 (ERM 2008). In addition, several spent fuel pool leaks have been documented 

8 (Davis-Besse Undated).

9 In May 1990, leaking piping from the east turbine building sump and condensate demineralizer 

10 backwash receiving tank resulted in low-level radioactivity in soil around the broken piping 

11 (NRC 1991). The licensee initiated Potential Condition Adverse to Quality (PCAQ) Report 

12 No. 90-0404 on May 11, 1990, and the leak was repaired September 12, 1990. Soil excavation 

to remediate took place in August 1990; sampling showed Ce-137 from 7x10-7 to 2x10-5 13 μCi/g, 

and Ce-134 from 8x10-8 to 9x10-6 14 μCi/g (NRC 1991).

15 The facility has had several spills of petroleum products, resulting in product retrieval wells and 

16 in situ bioremediation. In 1998, a diesel tank overfill resulted in a spill of over 50 gallons 

17 (FENOC 1998). This tank was an aboveground tank classified as an underground tank 

18 because of placement of an earthen cover for missile protection. Because there was no 

19 apparent release to the environment beyond the immediate vicinity of the spill, and because of 

20 the purpose of the earthen cover, contaminated soils were not removed. Davis-Besse intends 

21 to investigate and remediate soil as appropriate upon closure of the tank facility.

22 In 1994, a spill of about 1,300 gallons of gasoline occurred by Service Building 4 (Centerior 

23 Energy 1994). An equipment malfunction was repaired and, as of 5 weeks after the event, 

24 about 500 gallons of product had been recovered. The remaining gasoline was believed to be 

25 in the porous fill beneath a parking lot. It remained onsite and was not observed in the marsh 

26 area. Stormwater lines were plugged as a precaution (Centerior Energy 1994).

27 During the audit, another incident was described that involved an underground leak of fuel oil, 

28 which appeared in a stormwater catch basin and in the training center pond. Booms and an 

29 underflow weir were used to remediate the product, and there was no offsite release.

30 FENOC staff also described during the audit that the sodium hydroxide tank has leaked twice, 

31 but no release to the environment occurred because of the tank’s secondary containment 

32 system.

33 2.2.6 Aquatic Resources

34 2.2.6.1 Lake Erie Overview

35 Davis-Besse is located on the southwestern shore of Lake Erie, the shallowest of the Great 

36 Lakes. The Detroit River accounts for 80 percent of freshwater inflow to Lake Erie. 

37 Precipitation accounts for 11 percent of inflow, and the remaining 9 percent comes from 

38 tributaries that flow into the lake from Michigan, Ohio, Pennsylvania, New York, and Ontario, 

39 Canada (EPA 2004). Lake Erie discharges into Lake Ontario through the Niagara River. Lake 

40 Erie is divided into three basins—the western basin, the central basin, and the eastern basin. 

41 Davis-Besse lies along the western basin, which has a mean depth of 24.1 ft (7.4 m) and a 

42 maximum depth of 62 ft (19 m) (EPA 2004). All waters in the western basin are classified as 

43 seasonally cool water (68 to 80 °F (20 to 28 °C)). Generally, Lake Erie is considered to be 

44 mesotrophic (having moderate levels of nutrients) (Tyson et al. 2009).
Affected Environment

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1 Because a third of the total Great Lakes population lives within the Lake Erie watershed, Lake 

2 Erie experiences the greatest impacts from residential and industrial development, agricultural 

3 production, and other human-caused stressors. Lake Erie was the first of the Great Lakes to 

4 develop problems with nutrient loading in the 1950s, which led to high levels of eutrophication 

5 and major algal blooms, oxygen depletion, and subsequent die-offs of fish and other biota (EPA 

6 2004). Toxic contaminants from point and non-point sources have also threatened the water 

7 quality of Lake Erie. By the late 1970s, chemical bans, more stringent water quality standards, 

8 and the development of the Great Lakes Water Quality Agreement (GLWQA) in 1972 aided in 

9 lessening the threat of accelerated eutrophication. Under the GLWQA, the U.S. and Canada 

10 must develop and implement lakewide management plans (LaMPs) for lake waters and 

11 Remedial Action Plans for Areas of concern. The Lake Erie LaMP work group completed the 

12 most recent update to the Lake Erie LaMP in 2008. The 2008 LaMP highlighted that a large 

13 load of PCB-contaminated sediments have been removed from the Ashtabula River area of 

14 concern, numerous habitat improvement projects have begun in the Buffalo area of concern, 

15 and over 400 ac (160 ha) of forest and wetland habitat has been restored in southwest Ontario 

16 (EPA 2008).

17 In a study of the correlation between lake productivity (eutrophication level) and species 

18 richness, Ludsin et al. (2001) found that the decrease in phosphorus levels between 1969 and 

19 1996 as a result of various phosphorus abatement programs was likely correlated with the 

20 increased species richness in the Lake Erie central basin over the same period. From 1969

21 through 1996, bottom anoxia stopped occurring in the summers; macroinvertebrate prey 

22 species, such as Hexagenia spp., recovered; and water clarity improved (Ludsin et al. 2001). 

23 All of these factors allowed many previously depleted fish populations to begin to recover.

24 Invasive species serve as another major stressor to Lake Erie and have caused drastic changes 

25 to the Lake Erie fish community over the past century. The first recorded invasive fish, the 

26 alewife (Alosa pseudoharengus), invaded the Great Lakes as early as 1819 (Emery 1985). As 

27 of 2008, 132 non-native invasive species have been discovered in the Lake Erie watershed, 

28 which include 23 fish, 12 mollusks, and 20 algae (EPA 2008). The International Joint 

29 Commission (IJC) estimates that a new invasive species enters the Great Lakes system every 

30 8 months (IJC 2004). In 1993, the U.S. passed regulations that required ships entering the 

31 Great Lakes to exchange their ballast water with seawater. This regulation change has not 

32 slowed the rate of aquatic invasive introductions; however, the Great Lakes system has 

33 experienced a shift to smaller, open water non-native organisms such as zooplankton and 

34 phytoplankton beginning in the 1990s and 2000s (IJC 2004).

35 The sea lamprey (Petromyzon marinus), which invaded the Great Lakes in the early 1900s, and 

36 the zebra mussel (Dreissena polymorpha), which was introduced to Lake Erie in the 1980s, 

37 have caused the most noticeable changes to the biological community (EPA 2004). The sea 

38 lamprey is an aggressive predator that had been attributed to the collapse of lake trout 

39 (Salvelinus namaycush), lake whitefish (Coregonus clupeaformis), and lake herring (Coregonus 

40 artedi) populations beginning in the 1940s and 1950s (GLFC 2000). Zebra and quagga 

41 mussels (D. rostriformis bugensis) easily outcompete native mussel species and have 

42 significantly altered the Lake Erie food web and nutrient and contaminant cycling (EPA 2004). 

43 Prior to the introduction of these dreissenid mussels, amphipods, chironomids, annelids, 

44 ephemeropterans, and unionid clams dominated Lake Erie’s shallow and nearshore waters 

45 (Conroy and Culver 2005). Once zebra and quagga mussel populations became established in 

46 Lake Erie, they changed the flow of energy through the lake’s food web by adding an additional 

47 level between lower (pelagic) and higher (benthic) trophic levels, which ultimately slowed the 

48 energy transfer through the lake’s biological system (Conroy and Culver 2005).
Affected Environment

2-35

1 Because of the exotic species discussed above and other exotic predators, many native 

2 predators, such as the lake trout, sauger (Sander canadensis), and blue pike (Sander vitreus 

3 glaucus), have suffered population depletion or even disappeared from the lake. The lake 

4 herring, lake whitefish, and lake sturgeon (Acipenser fulvescens) are also species that have 

5 been severely reduced in number. Meanwhile, small, short-lived, exotic species, such as 

6 rainbow smelt (Osmerus mordax), white perch (Morone americana), and alewife, have 

7 increased in numbers and now maintain large and relatively stable populations (GLFC 2003).

8 In their Twelfth Biennial Report on Great Lakes water quality, the IJC (2004) focused on the 

9 Lake Erie watershed to illustrate the changes in the Lake Erie ecosystem and explain how these 

10 changes related to ecosystem integrity. The IJC (2004) noted that many trends in water and 

11 ecosystem quality have varied year-to-year, are not able to be linked to clear causes and 

12 effects, and are simultaneously positive and negative. For instance, the invasive zebra and 

13 quagga mussels have caused the decline of native mussel species and may be causing 

14 seasonal increases in phosphorus levels each spring (IJC 2004). However, zebra and quagga 

15 mussels have also been linked to increased water clarity, which, in turn, has allowed for a 

16 dramatic increase in established rooted aquatic plant populations (IJC 2004). Table 2.2-3

17 includes a summary of the positive and negative trends identified by the IJC in their Twelfth 

18 Biennial Report. 

19 Table 2.2-3. Positive and Negative Trends in the Lake Erie Ecosystem Since the 1990s

Trend Positive Negative

Blue-green algae blooms x

Burrowing mayfly recovery x

Cladophora shoreline accumulations x

Diporeia decline x

Establishment of invasive species x

Fish & wildlife die-offs from botulism x

Increased water clarity x

Lake whitefish decline (eastern basin) x

Lake whitefish recovery (central basin) x

Phosphorus increase in water column x

Phytoplankton decline in offshore waters x

Re-establishment of rooted aquatic plant communities x

Walleye recovery x

Source: IJC 2004 

20 In the 1990s, burrowing mayflies (Hexagenia spp.) began to recolonize Lake Erie’s western 

21 basin after a 40-year absence (Bridgeman et al. 2006). Mayflies are an indicator of 

22 environmental health and are an important food source for commercially valuable species such 

23 as the yellow perch (Perca flavescens) (Bridgeman et al. 2006). Their return indicates that the 

24 pollution and eutrophication concerns in Lake Erie are lessening.
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1 Aquatic Invertebrates

2 In the 1970s, the Center for Lake Erie Area Research (CLEAR) studied aquatic invertebrate 

3 abundance and composition as part of monitoring to determine the effects of Davis-Besse’s 

4 thermal discharge on the aquatic environment (Reutter et al. 1980). Diatoms were the most 

5 abundant phytoplankton in the Locust Point region of Lake Erie and typically peaked in the 

6 spring and fall. Species of the genera Melosira, Fragillaria, Asterionella, Stephanodiscus, and 

7 Synedra were the most common diatoms. Green algae (class Chlorophyceae) densities were 

8 much lower than diatom densities and must less predictable over the study period. 

9 Cyanobacteria, or blue-green algae (class Myxophyceae), generally demonstrated sudden, 

10 large mid-summer increases.

11 Zooplankton in Lake Erie’s western basin generally consist of protozoans, rotifers, and 

12 microcrustaceans. Reutter et al. (1980) found Brachionus, Keratella, Polyarthra, and Synchaeta

13 species to be the dominant rotifers. Rotifers generally peaked in October. Copepods were 

14 most abundant in spring and fall and were dominated by calanoid and cyclopoid forms.

15 In addition to phytoplankton and zooplankton, Reutter et al. (1980) described many benthic 

16 macroinvertebrates typical of the area. Generally, benthic macroinvertebrate populations were 

17 highest in early summer and fall. Burrowing oligochaetes and chironomid midge larvae were 

18 the dominant annelids. Freshwater mussels and fingernail clams were the dominant mollusks. 

19 Crustaceans typical of the area included the amphipod Gammarus fasciatus, water fleas, 

20 isopods, seed shrimp, and crayfish.

21 Fish

22 Lake Erie’s fish community has changed drastically during the past century due to the 

23 environmental factors already mentioned. Before 1900, lake trout highly influenced the fish 

24 community because it was the dominant predator. Walleye (Sander vitreus) and burbot 

25 (Lota lota) were also major predators at that time. Prey species included emerald shiner 

26 (Notropis atherinoides), spottail shiner (N. hudsonius), gizzard shad (Dorosoma cepedianum), 

27 and cisco (Coregonus spp.) (Tyson et al. 2009). The lake trout was extirpated from Lake Erie in 

28 the early 1900s (Tyson et al. 2009). From 1900 to 1950, walleye and blue pike became the 

29 major predators in the lake (Tyson et al. 2009). By the 1960s, many invasive species, including 

30 sea lamprey, alewife, white perch, and rainbow smelt established stable populations and began 

31 to outcompete native predators. The blue pike’s population dipped and eventually became 

32 extinct by the late 1950s to early 1960s after the last reported spawning in 1954 

33 (Niskanen 2008). The cisco, lake whitefish, and walleye populations severely declined during 

34 that time as well. Beginning in the 1980s, the lake’s fish community stabilized and only natural 

35 annual fluctuations in abundance are now observed (Tyson et al. 2009).

36 Of the estimated 143 fish species in Lake Erie, 19 are commercially or recreationally harvested

37 or both. Lake Erie fisheries are unique in that they (unlike other Great Lakes fisheries) are 

38 sustained by naturally reproducing fish (Tyson et al. 2009). The lake trout is the exception to 

39 this because natural resource agencies are working together to recover the population. Overall, 

40 sport fishing yields more landings annually than commercial fishing within the lake and its 

41 tributaries. The Ohio Department of Natural Resources (ODNR) manages Lake Erie fisheries 

42 and publishes yearly status reports on yellow perch, walleye, smallmouth bass (Micropterus 

43 dolomieu), steelhead trout (Oncorhynchus mykiss), lake whitefish, temperate basses (Morone

44 spp.), and other major species. A summary of sport and commercial harvests of major species 

45 for 2008 appears in Table 2.2-4. In 2008, 9.6 million pounds of fish were harvested from Lake 

46 Erie and its tributaries (ODNR 2009a). Commercial and sport fishing accounted for 
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1 43.4 percent and 56.6 percent of landings, respectively (ODNR 2009a). Yellow perch 

2 accounted for the majority of commercial landings (36 percent of commercial landings; about 

3 1.5 million pounds), while walleye dominated the sport harvest (69 percent of sport landings; 

4 about 3.8 million pounds) (ODNR 2009a). 

5 Table 2.2-4. Sport and Commercial Harvests of Major Species in Ohio Waters of Lake 

6 Erie and its Tributaries, 2008

Scientific Name Common Name Sport Harvest Commercial 

Harvest

Total Combined Harvest

Aplodinotus grunniens freshwater drum 14,939 423,705 438,644

Ictalurus punctatus channel catfish 7,014 447,232 454,246

Micropterus dolomieu smallmouth bass 3,406 0 3,406

Morone americana white perch 15,379 545,138 560,517

Morone chrysops white bass 91,406 424,225 515,631

Oncorhynchus mykiss steelhead trout 19,605 0 19,605

Perca flavescens yellow perch 1,528,460 1,515,666 3,044,126

Sander vitreus walleye 3,779,130 0 3,779,130

Other species(a) - 827,551 827,551

TOTAL 5,459,339 4,183,517 9,642,856

(a) Data is not available for sport harvest of species other than those listed. Commercial harvest of “other species” include buffalo 

(Ictiobus spp.), bullhead (Ameiurus spp.), burbot, carp (family Cyprinidae), gizzard shad, goldfish (Carassius auratus auratus), 

quillback (Carpiodes cyprinus), suckers (family Catostomidae), and lake whitefish. 

Source: ODNR 2009a

7 2.2.6.2 Impingement Studies at Davis-Besse

8 In 1980, CLEAR published a report that summarized an impingement study conducted jointly by 

9 CLEAR and the Toledo Edison Company at Davis-Besse (Reutter 1981b). The impingement 

10 study ran from January 1 through December 31. Toledo Edison personnel checked the 

11 traveling screens regularly, collected impinged fish from the screens, and froze the collected fish 

12 for sampling. CLEAR identified, measured, and weighed each sample. During the study year, 

13 Reutter (1981b) estimated that 9,056 fish within 23 taxa were impinged on the Davis-Besse 

14 traveling screens. Goldfish and gizzard shad accounted for the overwhelming majority of 

15 impinged individuals during the sample year at an estimated 47.2 percent and 28.8 percent, 

16 respectively. Yellow perch, emerald shiner, and white crappie (Pomoxis annularis) accounted 

17 for a combined estimate of 15.3 percent. The remaining 18 taxa accounted for an estimated 

18 8.7 percent. 

19 Table 2.2-5 summarizes the 23 taxa that appeared in the impingement sampling and each 

20 taxa’s relative abundance.
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1 Table 2.2-5. Relative Abundance of Species in Impingement Sampling, 1980

Scientific Name Common Name Estimated Impingement (%)

Carassius auratus auratus goldfish 47.2

Dorosoma cepedianum gizzard shad 28.7

Perca flavescens yellow perch 8.3

Notropis atherinoides emerald shiner 3.8

Pomoxis annularis white crappie 3.3

Pomoxis nigromaculatus black crappie 2.0

Aplodinotus grunniens freshwater drum 2.0

Osmerus mordax rainbow smelt 1.3

Percina caprodes logperch darter 0.7

Percopsis omiscomaycus trout-perch 0.6

Morone chrysops white bass 0.5

Alosa pseudoharengus alewife 0.3

Umbra limi mudminnow 0.3

family Centrarchidae unidentified sunfish 0.3

Lepomis macrochirus bluegill 0.2

Ameiurus nebulosus brown bull head 0.1

Notropis hudsonius spottail shiner 0.1

Pomoxis spp. unidentified crappie 0.1

Lepomis gibbosus pumpkinseed sunfish <0.1

Lepomis cyanellus green sunfish <0.1

Ameiurus spp. unidentified bullhead <0.1

family Cyprinidae carp <0.1

Noturus flavus stonecat madtom <0.1

Source: Reutter 1981b 

2 The relative number of individuals lost to impingement correlated with lake populations for all 

3 but five species—goldfish, black bullhead (Ameiurus melas), brown bullhead (A. nebulosus), 

4 black crappie (Pomoxis nigromaculatus), and white crappie. These species’ relative abundance 

5 was higher in impingement samples than in Lake Erie, which indicated that these species most 

6 likely use the intake canal as a permanent residence (Reutter 1981b). Reutter (1981b) also 

7 concluded that these five species likely spawn within the intake canal due to the high proportion 

8 of impinged young-of-the-year.

9 2.2.6.3 Entrainment Studies at Davis-Besse

10 In addition to the 1980 impingement sampling conducted at Davis-Besse (Reutter 1981b), 

11 CLEAR and the Toledo Edison Company conducted entrainment sampling from April through 

12 August 1980 (Reutter 1981a). During 13 samples days, CLEAR took four 3-minute 
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1 bottom-to-surface tows at the intake with a 0.75-m diameter plankton net and then computed 

2 entrainment density by comparing the samples to the volume of water taken into the plant. 

3 Table 2.2-6 summarizes the estimated entrainment densities of eggs and larvae by taxa. 

4 Gizzard shad, freshwater drum (Aplodinotus grunniens), yellow perch and white bass (Morone 

5 chrysops) were entrained at the highest densities (Reutter 1981a). Reutter (1981a) concluded 

6 that the entrainment losses at Davis-Besse were relatively small when compared to lake-wide 

7 populations and that the loss of gizzard shad, walleye, and perch eggs and larvae accounted for 

8 a loss of fecundity of less than 0.2 percent of the number captured in sport fishery in 1980.

9 Table 2.2-6. Entrainment Densities in Entrainment Sampling, 1980

Scientific Name Common Name Estimated Entrainment Density 

(larvae/100 m3) 

Dorosoma cepedianum gizzard shad 189.18

Aplodinotus grunniens freshwater drum 130.67

Perca flavescens yellow perch 91.00

Morone chrysops white bass 23.80

Sander vitreus walleye 2.76

Notropis hudsonius spottail shiner 1.75

family Cyprinidae carp 1.67

Osmerus mordax rainbow smelt 0.97

Notropis atherinoides emerald shiner 0.86

Percina caprodes logperch darter 0.85

Coregonus spp. whitefish 0.49

unidentified spp. unidentified spp. 0.34

family Cottidae unidentified sculpin 0.30

Cottus bairdii mottled sculpin 0.20

Source: Reutter 1981a 

10 2.2.6.4 Thermal Studies at Davis-Besse

11 From 1972 to 1979, CLEAR gathered data on the aquatic environment surrounding 

12 Davis-Besse to determine the thermal impacts of Davis-Besse’s operation, which began in 

13 1977. The results of this study were summarized in a report prepared for the ODNR (Reutter et 

14 al. 1980). CLEAR collected phytoplankton, zooplankton, benthic macroinvertebrate, fish, and 

15 icythyoplankton samples from 25 stations in Lake Erie—18 on the open lake, 2 in the intake 

16 canal, 2 in the marshes, and 3 along the shoreline—plus several control stations. The species 

17 composition and abundances observed during this study are discussed previously in this section 

18 under the heading “Aquatic Invertebrates.” Reutter et al. (1980) concluded that no clear 

19 correlation existed between any aquatic populations and Davis-Besse’s thermal discharge.
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1 2.2.7 Terrestrial Resources

2 2.2.7.1 Davis-Besse Ecoregion and Surrounding Vicinity

3 Davis-Besse lies in the Marblehead Drift/Limestone Plain Level IV subecoregion within the 

4 larger Huron/Erie Lake Plains Level III ecoregion. The Marblehead Drift/Limestone Plain 

5 subecoregion lies along the southern shore of Lake Erie from Ottawa National Wildlife Refuge 

6 east to Huron, Ohio. It encompasses Sandusky Bay and spreads inland to Tiffin, Ohio. Broad, 

7 flat plains with thin glacial drifts and limestone-dolomite ridges characterize the area. 

8 Historically, beech forests, elm-ash swamp forests, mixed oak forests, wetland, and fen habitats 

9 were prevalent. Today, the area has been largely converted to farmland for hay, soybeans, and 

10 corn (EPA 2009)

11 The ODNR characterizes the State’s geographic profile by dividing it into five physiographic 

12 regions. Davis-Besse lies within the Lake Plains region, a narrow strip of land along the 

13 southern shore of Lake Erie that broadens west of Cleveland, Ohio (ODNR 2011e). Effectively, 

14 this physiographic region covers the U.S. EPA’s Marblehead Drift/Limestone Plain subecoregion 

15 as well as the adjacent Erie Lake Plain subecoregion. ODNR (2011e) notes that the 

16 northwestern area of the Lake Plains physiographic region (where Davis-Besse is located) was 

17 historically called the Great Black Swamp and is characterized by rich, black soils, and poor 

18 drainage. The Great Black Swamp originally encompassed about an area 120 mi (190 km) in 

19 length and an average of 40 mi (60 km) in width (ODNR and OEPA 1999). Between the 

20 mid-1700s and 1980s, residential and commercial development and associated wetland 

21 draining reduced the Great Black Swamp to about 5 percent of its historic size, and much of 

22 what remains of the swamp consists of isolated wetlands on uncultivated farmland 

23 (ODNR and OEPA 1999).

24 In the immediate vicinity of the Davis-Besse site, the majority of the undeveloped or uncultivated 

25 land is wetlands. Within Ottawa County, wetlands account for about 14 percent of the land use 

26 type (ODNR and OEPA 1999). The major wetland types present in Ottawa County, as 

27 classified by ODNR and OEPA (1999), are hydric woods, open water, shallow marsh, and shrub 

28 scrub. Originally, the majority of wetlands were naturally seasonal with some permanent 

29 wetlands lying behind barrier beaches along the Lake Erie coast (FWS 2001). Lakefront 

30 development and wetland draining has drastically reduced the amount of wetlands and changed 

31 the water regimes of those remaining wetland areas. The majority of remaining wetlands in the 

32 region are in Federal refuges, state management areas, and private hunting clubs and are 

33 surrounded by man-made dikes, which protect the wetlands from wave damage during high 

34 water storm events (FWS 2001). American elm (Ulmus americana), red maple (Acer rubrum), 

35 and black ash (Fraxinus nigra) make up the majority of climax vegetation (FENOC 2010).

36 The Ottawa National Wildlife Refuge lies adjacent to and to the west of the Davis-Besse site 

37 and encompasses 4,755 ac (1,924 ha). This refuge was established in 1961 and contains two 

38 discontinuous sections—the Darby Marsh and the Navarre Marsh. The Darby Marsh contains a 

39 combined FWS office and visitor’s center and limited access public hiking trails. The Navarre

40 Marsh portion is owned by FENOC and leased to the FWS for management as part of the 

41 wildlife refuge. The Navarre Marsh is discussed in more detail below under “Davis-Besse Site.” 

42 According to the FWS’s (2011g) national wetlands inventory, the majority of the refuge consists 

43 of freshwater emergent wetland and freshwater forested and shrub wetland.

44 The Ottawa National Wildlife Refuge is part of a larger complex of three national wildlife refuges 

45 (Ottawa, Cedar Point, and West Sister Island) that comprise approximately 9,000 ac (3,600 ha) 

46 in total. Cedar Point National Wildlife Refuge lies along the coast of Lake Erie about 15 mi 
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1 (24 km) to the west of the Davis-Besse site. It was established in 1965 and comprises 2,445 ac 

2 (989 ha) of contiguous marsh—the largest stretch of contiguous marsh along Lake Erie 

3 (ONWRA 2011). West Sister Island National Wildlife Refuge lies to the north of Davis-Besse 

4 about 10 mi (16 km) offshore of Lake Erie. The 82-ac (33-m) island is home to the largest 

5 wading bird colony in the U.S. Great Lakes and was designated as part of the National 

6 Wilderness Preservation System in 1975 (ONWRA 2011). The island is 35 ft (11 m) above 

7 Mean Sea Level (MSL) at its highest point and is covered by an almost pure stand of hackberry 

8 (Celtis spp.) (OWL 2011). Thick mats of poison ivy (Toxicodendron radicans), ferns, 

9 wildflowers, and mushrooms make up the understory (FWS 2011h). 

10 Birds 

11 A vast diversity of birds inhabit and migrate through the natural habitats surrounding 

12 Davis-Besse. The Ottawa National Wildlife Refuge complex and surrounding region provides 

13 habitat for over 325 species of birds (FWS 2001). The National Audubon Society recognizes 

14 600,000 ac (240,000 ha) on the Lake Erie western basin (including the Davis-Besse site and 

15 surrounding vicinity) as an important bird area because it provides essential wintering, breeding, 

16 and migrating habitat for many species of birds to include the following (Audubon 2011):

17 • ruddy duck (Oxyura jamaicensis), 

18 • American black duck (Anas rubripes), 

19 • red-breasted merganser (Mergus serrator), 

20 • ring-billed gull (L. delawarensis), 

21 • great black-backed gull (Larus marinus), 

22 • herring gull (L. smithsonianus), 

23 • common tern (Sterna hirundo), and

24 • bald eagle (Haliaeetus leucocephalus). 

25 Though the Mississippi Flyway lies to the west of the Great Lakes, many major branches of the 

26 flyway follow the southwestern shore of Lake Erie. The Black Swamp Bird Observatory

27 (BSBO), located just to the west of Davis-Besse, conducts long-term research projects on bird 

28 migration and breeding in the area. In 2009, the BSBO recorded 152 species of migrating 

29 passerines, 30 species of migrating shorebirds, and 22 species of migrating raptors in Lake Erie 

30 marshes alone (BSBO 2009a, 2009b, 2009c). 

31 Table 2.2-7 lists the passerine, shorebird, and raptor species that the BSBO most commonly 

32 reported as occurring during migrations in Lake Erie marshes. Note that, for passerines, the 

33 bird species provided are specific to Navarre Station, which is located within Navarre Marsh on 

34 the Davis-Besse property.

35 The region also provides wintering habitat for dabbling ducks (subfamily Anatinae), diving ducks 

36 (subfamily Aythyinae), geese, and other waterfowl (Herndendorf 1987). Gulls (family Laridae), 

37 terns (family Sternidae), and cormorants (family Phalacrocoracidae) nest along the coast of 

38 Lake Erie and on the islands off the coast of the lake. Raptors, including the bald eagle, turkey 

39 vulture (Cathartes aura), osprey (Pandion haliaetus), American kestrel (Falco sparverius), and 

40 many hawk species also nest in the area (Herndendorf 1987).
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1 Table 2.2-7. Most Common Migrating Bird Species Near the Davis-Besse Site 

Spring Migration Fall Migration 

Passerines at the Navarre Station

• eastern screech owl (Megascops asio) • blackpoll warbler (Dendroica striata)

• hairy woodpecker (Picoides villosus) • Swainson’s thrush (Catharus ustulatus)

• red-headed woodpecker 

(Melanerpes erythrocephalus) 

• white-throated sparrow (Zonotrichia albicollis)

• Gambel’s white-crowned sparrow 

(Zonotrichia leucophrys ssp. gambelii) 

• golden-crowned kinglet (Regulus satrapa)

• yellow palm warbler 

(Dendroica palmarum ssp. hypochrysea) 

• hermit thrush (Catharus guttatus)

Shorebirds in Lake Erie Marshes

• common snipe (Gallinago gallinago) • killdeer (Charadrius vociferous)

• pectoral sandpiper (Calidris melanotos) • short-billed dowitcher (Limnodromus griseus)

• American golden plover (Pluvialis dominica) • least sandpiper (Calidris minutilla)

• lesser yellowlegs (Tringa flavipes) • solitary sandpiper (Tringa solitaria)

• greater yellowlegs (Tringa melanoleuca) • semipalmated sandpiper (Calidris pusilla)

Raptors in Lake Erie Marshes

• turkey vulture (Cathartes aura) • cooper’s hawk (A. cooperii)

• red-tailed hawk (Buteo jamaicensis) • bald eagle (Haliaeetus leucocephalus)

• sharp-shinned hawk (Accipiter striatus) • northern harrier (Circus cyaneus)

• broad-winged hawk (B. platypterus) • osprey (Pandion haliaetus)

• red-shouldered hawk (B. lineatus) • American kestrel (Falco sparverius)

Source: BSBO 2009a, 2009b, 2009c 

2 On West Sister Island, the FWS estimates that a colony of great blue herons (Ardea herodias), 

3 great egrets (Ardea alba), double-crested cormorants (Phalacrocorax auritus), and 

4 black-crowned night herons (Nycticorax nycticorax) totals 3,500 nesting pairs (FWS 2001). This 

5 colony contains the largest black-crowned night heron rookery in the Great Lakes (FWS 2001). 

6 Because the shores of West Sister Island do not provide any wading habitat, birds that nest on 

7 West Sister Island fly to the Lake Erie shore to feed multiple times per day.

8 Despite the vast array of birds that make use of habitat within the Davis-Besse region, the Ohio 

9 Audubon Society reports that many common species are in decline due to urban sprawl, 

10 non-native invasive species, and the expansion of industrialized agriculture. 

11 The Ohio Audubon Society (2007) summarized the most vulnerable common species in decline 

12 and their percent decline since 1967 as follows:

13 • green heron (Butorides virescens)—82 percent decline, 

14 • red-headed woodpecker (Melanerpes erythrocephalus)—78 percent decline, 

15 • eastern meadowlark (Sturnella magna)—75 percent decline, 
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1 • northern flicker (Colaptes auratus)—67 percent decline, and

2 • yellow-breasted chat (Icteria virens)—63 percent decline. 

3 In addition to these five common species in decline, the Ohio Audubon Society’s (2009) watch 

4 list identifies five species of birds that are the most critically imperiled birds in the U.S. and at 

5 greatest risk of regional extirpation. These five species are the red-headed woodpecker (also 

6 included above on the “most vulnerable” list), Henslow’s sparrow (Ammodramus henslowii), 

7 prothonotary warbler (Protonotaria citrea), prairie warbler (Dendroica discolor), and cerulean 

8 warbler (Dendroica cerulean). 

9 Mammals

10 Northwestern Ohio’s mammal population is dominated by rodents, smaller predators, and deer. 

11 About 30 species in total occur in the Ottawa Refuge Complex (FWS 2001). Common 

12 mammals in the region include muskrat (Ondatra zebethicus), raccoon (Procyon lotor), and 

13 white-tailed deer (Odocoileus virginianus), all of which inhabit or use wetland habitats. 

14 Numerous muskrat houses are visible within inundated areas of Darby Marsh. Eastern 

15 cottontail (Sylvilagus floridanus), woodchuck (Marmota monax), fox squirrels (Sciurus niger), 

16 and striped skunk (Mephitis mephitis) occupy meadows, dikes, and forest edges. Small 

17 predators in the western Lake Erie marshes include long-tailed weasels (Mustela frenata), mink 

18 (M. vison), and red fox (Vulpes fulva). The majority of larger predators were extirpated from the 

19 area when northwestern Ohio was first settled. These include the wolverine (Gulo gulo), 

20 panther (Felis concolor), lynx (F. lynx), bobcat (F. rufus), gray wolf (Canis lupus), and black bear 

21 (Ursus americanus) (Hendendorf 1987). 

22 Amphibians and Reptiles

23 A variety of amphibians and reptiles inhabit the area, including salamanders, newts, toads, and 

24 frogs. One lizard (the five-lined skink (Eumeces fasciatus)) and 16 species of turtles and 

25 snakes occur in the Ottawa Refuge Complex (FWS 2001). Mudpuppies (Necturus 

26 maculosus)—a species of aquatic salamander—inhabit wetlands and small streams with soft 

27 bottoms (Hendendorf 1987). Spotted salamanders (Ambystoma maculatum), tiger salamanders 

28 (A. tigrinum), Jefferson salamanders (A. jeffersonianum), and smallmouth salamanders (A. 

29 texanum) hatch and develop in wetlands, move to moist woodlands at adulthood, and return to 

30 wetlands annually to breed and lay eggs. The dusky salamander (Desmognathus fuscus) and 

31 red back salamander (Plethodon cinereus) inhabit the Lake Erie coast. Toads and frogs use 

32 both wetland waters, ponds, streams, and a variety of land habitats. Common species in the 

33 region include the American toad (Bufo americanus), spring peepers (Pseudacris crucifer), 

34 western chorus frog (Pseudacris triseriata), cricket frogs (Acris spp.), pickerel frog (Rana 

35 palustris), and northern leopard frog (R. pipiens). The snapping turtle (Chelydra spp.) is the 

36 largest reptile in western Lake Erie. Members of the water and box turtle family—map turtles 

37 (Graptemys spp.), spotted turtle (Clemmys guttata), midland painted turtle (Chrysemys picta

38 ssp. marginata), box turtles (Terrapene spp.), and Blanding’s turtle (Emys blandingii)—inhabit 

39 ponds and wetlands with standing water and thick aquatic vegetation. The Lake Erie water 

40 snake is the most common snake species in the region. Gartner snakes (Thamnophis spp.), 

41 black rat snakes (Elaphe obsolete), Dekay’s snakes (Storeria dekayi), and hog-nosed snakes 

42 (family Colubridae) also inhabit the area (Hendendorf 1987). 

43 Vegetation

44 The Lake Erie western basin has the greatest diversity of wetland plant species. The majority 

45 (over 700 of the estimated 800 vascular plant species) of vegetation in the region are grasses, 
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1 reeds, aquatic plants, and other non-tree or shrub species (Bolsenga and Herdendorf 1993). 

2 Dominant wetland species include cattail (Typha spp.), bur reed (Sparganium spp.), grasses 

3 (Echinochloa spp., Leersia oryzoides, Calamagrostis Canadensis), spatterdock (Nuphar 

4 advena), water lily (Nymphaea spp.), and water smartweed (Polygonum coccineum) (Bolsenga 

5 and Herdendorf 1993). Within dikes, common greenbriar (Smilax rotundifolia), thistles, 

6 coneflower, common milkweed (Asclepias syriaca), asters (Aster spp.), river bank grape (Vitis 

7 riparia), and burdock (Arctium spp.) dominate (FENOC 2010c). Within swamps, riparian, and 

8 forested areas, eastern cottonwood (Populus deltoides), hackberry, sycamore (Platanus 

9 occidentalis), riverbank grape, black willow (Salix nigra), and staghorn sumac (Rhus typhina) 

10 constitute the climax vegetation assemblage (FENOC 2010c).

11 Many invasive species are present in the region, including purple loosestrife (Lythrum salicaria), 

12 reed canary grass (Phalaris arundinacea), common reed (Phragmites australis), and flowering 

13 rush (Butomus umbellatus). FENOC does not manage these species on its site. However, the 

14 FWS uses a variety of techniques (hand-pulling, burning, and mowing; herbicides; and 

15 loosestrife-controlling weevils and beetles) to control invasive plants within the Ottawa National 

16 Wildlife Refuge, which includes Navarre Marsh on the Davis-Besse site (FWS 2001).

17 2.2.7.2 Davis-Besse Site

18 The Davis-Besse site consists of 954 ac (386 ha), of which 733 ac (297 ha) is the Navarre 

19 Marsh. As previously mentioned, the FWS leases the Navarre Marsh for management as part 

20 of the Ottawa National Wildlife Refuge. The remaining 221 ac (89 ha) of the site is composed of 

21 developed areas containing facility buildings, structures, and parking lots; woodlands; low 

22 grasslands; and marginal agricultural land (FENOC 2010c). 

23 The Navarre Marsh lies on the southeast end of the Davis-Besse site and is composed of 

24 freshwater marsh, swamp forest, wet meadow, and small areas of deciduous forest 

25 (FENOC 2010c). A beach ridge separates the Navarre Marsh from the southern shore of Lake 

26 Erie. Sandbar willow (Salix interior), staghorn sumac, and elderberry (Sambucus spp.) 

27 dominate this beach ridge (FENOC 2010c). A hardwood swamp—part of Navarre Marsh—lies 

28 directly behind the beach ridge. As discussed previously, the BSBO has a research station 

29 within the Navarre Marsh where it conducts migration surveys.

30 2.2.7.3 Transmission Line Corridors

31 FENOC manages approximately 1,800 ac (730 ha) of transmission line corridors as part of its 

32 transmission line maintenance, the majority of which is flat agricultural land (FENOC 2010c). 

33 The transmission lines also traverse a combination of wetlands, forests, streams, and 

34 developed land, and the Beaver Line crosses the Toussaint and Portage rivers to the south of 

35 the Davis-Besse site. Management of these corridors is discussed in Section 2.1.5. 

36 2.2.8 Protected Species and Habitats

37 This section discusses species and habitats that are: (1) Federally protected under the 

38 Endangered Species Act of 1973, as amended (ESA); (2) Federally protected under the Bald 

39 and Golden Eagles Protection Act of 1940, as amended; (3) Federally protected under the 

40 Migratory Bird Treaty Act of 1918, as amended (MBTA); and (4) State-protected species under 

41 Chapter 1518, Endangered Species, of the Ohio Revised Code.

42 No essential fish habitat exists in the vicinity of the Davis-Besse site; therefore, species 

43 protected under the Magnuson–Stevens Fishery Conservation and Management Act, as 
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1 amended, are not considered in this section. Additionally, no marine waters are affected by the 

2 proposed license renewal; therefore, species protected under the Marine Mammal Protection 

3 Act of 1972, as amended, are not considered in this section.

4 2.2.8.1 Species and Habitats Protected Under the Endangered Species Act

5 The FWS and the National Marine Fisheries Service (NMFS) jointly administer the ESA of 1973 

6 (16 USC 1531 et seq.). The FWS manages the protection of and recovery effort for listed 

7 terrestrial and freshwater species, while the NMFS manages the protection of and recovery 

8 effort for listed marine and anadromous species. 

9 Action Area

10 The implementing regulations for section 7(a)(2) of the ESA define “action area” as all areas 

11 affected directly or indirectly by the Federal action and not merely the immediate area involved 

12 in the action (50 CFR 402.02). The action area effectively bounds the analysis of 

13 ESA-protected species and habitats because only species that occur within the action area may 

14 be affected by the Federal action. The action area includes the lands and waters described 

15 below. The NRC staff expects all direct and indirect effects of the proposed action to be 

16 contained within these areas.

17 The Davis-Besse site lies on the southwestern shore of Lake Erie in Ottawa County, Ohio. The 

18 site encompasses 954 ac (386 ha), of which FENOC leases approximately 733 ac 

19 (297 ha)—designated as “Navarre Marsh”—to the FWS for management as part of the Ottawa 

20 National Wildlife Refuge. The remaining 221 ac (89 ha) of the site are composed of developed 

21 areas containing facility buildings, structures, and parking lots; woodlands; low grasslands; and 

22 marginal agricultural land. The proposed license renewal would include continued operation of 

23 the site and continued lease of Navarre Marsh to the FWS. License renewal would not involve 

24 any new construction or refurbishment activities on either the developed or the undeveloped 

25 portions of the site. The proposed license renewal would continue to use the existing onsite 

26 switchyard and transmission facilities and would not require the construction or modification of 

the existing transmission system.

2 27

28 Davis-Besse withdraws water from, and discharges cooling tower blowdown to, Lake Erie. 

29 Water is withdrawn approximately 3,000 ft (900 m) offshore. During normal operations, 

 

2

 The GEIS (NRC 1996) does not define the scope of transmission lines that should be considered for the site-specific (Category 2) 

issue, “Threatened or Endangered Species.” In 1999, the NRC staff made a policy decision to consider the scope of transmission 

lines for its “Threatened or Endangered Species” analyses to be that defined at 10 CFR 51.53(c)(3)(ii)(H), which states that “If the 

applicant’s transmission lines that were constructed for the specific purpose of connecting the plant to the transmission line system 

do not meet the recommendations of the National Electric Safety Code for preventing electric shock from induced currents, an 

assessment of the impact of the proposed action on the potential shock hazard from the transmission lines must be provided.” (NRC 

1999b). The NRC has consistently applied this scope to its “Threatened or Endangered Species” license renewal analyses since 

that time. In preparing the GEIS, Revision 1 (NRC 2013), the NRC staff reviewed and incorporated lessons learned and knowledge 

gained from license renewal environmental reviews conducted by the NRC since 1996. The 2013 GEIS recognizes that since 

construction, many transmission lines have been incorporated into the regional power grid and that, in many cases, lines are no 

longer owned or managed by NRC licensees, and would, thus, remain energized regardless of license renewal. The 2013 GEIS 

concludes that “only those transmission lines that connect the power plant to the switchyard where electricity is fed into the regional 

distribution system (encompassing those lines that connect the nuclear plant to the first substation of the regional electric power 

grid) and power lines that feed the plant from the grid during outages are considered within the regulatory scope of license renewal 

environmental review[s].” In the case of Davis-Besse, an onsite switchyard lies just east of the containment building and south of 

the cooling tower. This switchyard is the first substation of the Toledo Edison grid, at which point electricity is fed into the regional 

distribution system. Lines beyond this switchyard are owned and operated by FirstEnergy and not the NRC applicant, FENOC. 

These lines would stay in service regardless of Davis-Besse license renewal because they are interconnected with other utilities 

(FENOC 2010c) and, thus, would not be affected by the proposed action. For these reasons, the NRC staff will consider the scope 

of the transmission lines for its “Threatened or Endangered Species” analysis to be that defined in the 2013 GEIS. Under this 

definition, all in-scope transmission lines are contained within the footprint of the Davis-Besse site. 
2-46

21,000 gpm (80 m3 1 /min) of water is withdrawn at a rate of about 0.25 fps (0.08 m/s). Water is 

2 returned to the lake via a 6-ft (1.8-m) diameter buried pipe located about 9 ft (2.7 m) below the 

lake’s surface. During normal operations, an average of 11,000 gpm (42 m3 3 /min) of water is 

4 discharged at a rate of 3.6 fps (1.1 m/s). The proposed license renewal would involve the 

5 continued use of Lake Erie as a source of cooling water. Section 2.2.6 describes the ecology of 

6 Lake Erie.

7 Within the action area, Federally listed terrestrial species could experience impacts such as 

8 habitat disturbance associated with refurbishment or other ground-disturbing activities, cooling 

9 tower drift, collisions with cooling towers and transmission lines, exposure to radionuclides, and 

10 other direct and indirect impacts associated with station, cooling system, and in-scope 

11 transmission line operation and maintenance. The proposed action has the potential to affect 

12 Federally listed aquatic species in several ways: impingement or entrainment of individuals into 

13 the cooling system; alteration of the riverine environment through water level reductions, 

14 changes in dissolved oxygen, gas supersaturation, eutrophication, and thermal discharges from 

15 cooling system operation; habitat loss or alteration from dredging; and exposure to 

16 radionuclides.

17 Species and Habitats Under NMFS’s Jurisdiction

18 No Federally listed species or critical habitats under NMFS’s jurisdiction exist in the action area. 

19 The NMFS confirmed this by letter dated December 21, 2010 (NMFS 2010).

20 Species and Habitats Under FWS's Jurisdiction

21 Table 2.2-8 identifies species under the FWS’s jurisdiction within Ottawa County. The NRC 

22 created this list based on the FWS’s Endangered Species Program online database (FWS 

23 2013); ODNR’s online Natural Heritage Database (ODNR 2013); and correspondence between 

24 the NRC and FWS (FWS 2010c).

25 Table 2.2-8. ESA Species Under FWS’s Jurisdiction That Occur in Ottawa County

Species Common Name Federal Status(a)

Birds

Charadrius melodus(b) piping plover LE

Mammals

Myotis sodalis Indiana bat LE

Plants 

Platanthera leucophaea eastern prairie fringed orchid LT

Tetraneuris herbacea lakeside daisy LT

(a) LE=Federally listed as endangered; LT=Federally listed as threatened 

(b) Great Lakes watershed population 

Source: FWS 2010c, 2013; ODNR 2013 

26 Piping Plover (Charadrius melodus)—Great Lakes Watershed Population. The FWS listed the 

27 Great Lakes watershed population of piping plover as endangered in 1985 (50 FR 50726). The 

28 species occurs through much of the northern Great Plains, Great Lakes region, Atlantic coast, 

29 and Gulf Coast region. A recent study of the taxonomy of the species (Miller et al. 2009) 
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1 confirmed genetic uniqueness of only two subspecies—Atlantic (C.m. melodus) and Interior 

2 (C.m. circumcinctus), though the FWS recognizes three distinct population segments in its ESA 

3 rulemakings—the Atlantic Coast, the Great Lakes, and the Northern Great Plains populations 

4 (FWS 2009a). The Atlantic Coast population is C.m. melodus, while the Great Lakes and 

5 Northern Great Plains populations are C.m. circumcinctus. 

6 Piping plovers inhabit open, sandy, sparsely vegetated beaches and barrier islands along the 

7 Great Lakes’ shorelines. They avoid high bluffs or areas where the beach has been severely 

8 eroded. Historically, the Great Lakes watershed population bred throughout the Great Lakes’ 

9 shorelines in within eight states, including Ohio, as well as Ontario (Haig 1992). Currently, 

10 breeding is restricted to several beaches along Lake Superior and Lake Michigan in northern 

11 Michigan (Haig 1992). The population winters along the Gulf coasts of Texas, Lousiana, 

12 Alabama, and Florida.

13 Piping plovers have not nested on Lake Erie since 1942 (ODNR 2011d). Since the late 1970s, 

14 piping plovers have been considered extirpated from the Great Lakes beaches in Ohio, Illinois, 

15 Indiana, New York, Pennsylvania, and Ontario (FWS 2003). In its five-year review of the 

16 species, the FWS (2009b) noted that piping plovers are infrequently sited in Ohio during 

17 migration on Headlands Beach in Mentor and Sheldon Marsh in Huron, which lie about 150 mi 

18 (240 km) and 110 mi (180 km) west of Davis-Besse, respectively. In the available data years 

19 (2003-2010), the BSBO has recorded the piping plover in 4 years within the Lake Erie marsh 

20 region (see Table 2.2-9). Thus, shoreline within the Davis-Besse site may provide marginal 

21 habitat for migrating piping plovers, but the occurrence of this species within the action area 

22 would be rare.

23 Table 2.2-9. Piping Plovers Observed During BSBO’s Lake Erie Marsh Migration Survey, 

24 2003–2010

Number of Individuals Observed

Year Spring Migration Fall Migration

2003 0 0

2004 0 0

2005 0 1

2006 0 0

2007 1 0

2008 0 2

2009 0 0

2010 0 5

Source: BSBO 2003b, 2004b, 2005, 2006c, 2007a, 2008a, 2009b, 2010b 

25 The FWS designated critical habitat for the Great Lakes breeding population in May 2001 

26 (66 FR 22938). Two critical habitat units (OH-1 and OH-2) are located within Ohio. However, 

27 these units lie outside of the action area in Erie and Lake Counties.

28 Indiana Bat (Myotis sodalis). The FWS listed the Indiana bat as endangered wherever found in 

29 1967 under the Endangered Species Preservation Act of 1966, the predecessor of the ESA 

30 (32 FR 4001). Indiana bats appear dark brown in color, but individual hairs are tricolored, which 

31 distinguishes the Indiana bat from the little brown bat (Myotis lucifugus) (ODNR 2011c). 
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1 Indiana bats inhabit Ohio seasonally during the spring and summer months, during which time 

2 they rear young. Menzel et al., (2005) concluded that habitat use is highly correlated with 

3 insect abundance, which means that Indiana bats often forage in riparian areas where insect 

4 densities are highest. Menzel et al., (2005) also found that Indiana bats were more closely 

5 associated with linear landscape features (forest corridors and roads) than open areas 

6 (agricultural land, grasslands, or meadows). The Davis-Besse site includes riparian areas that 

7 may provide habitat to the species. Thus, this species may occur in the action area.

8 FENOC’s (2011) “Environmental Best Management Practices” include procedures for cutting 

9 trees in areas with suitable Indiana bat habitat. The procedure directs staff to cut trees between 

10 September 30 and April 1. If trees must be cut outside these months, FENOC must complete a 

11 net survey in May or June prior to cutting to ensure that the cutting will not result in disturbance 

12 of Indiana bat roosts. These specifications apply to the Davis-Besse site as well as the in-scope 

13 transmission line corridors. The FWS has not designated critical habitat for the species in Ohio 

14 (41 FR 41914).

15 Eastern Prairie Fringed Orchid (Platanthera leucophaea). The eastern prairie fringed orchid is a 

16 Federally threatened species. The species is an 8- to 40-in. (20- to 100-cm) tall perennial herb 

17 with lance shaped leaves and a single flower spike of small white flowers. The orchid grows in 

18 mesic prairie, sage meadows, marsh edges, bogs, and other wetland habitats with full sun 

19 (FWS 2011c). Eastern prairie fringed orchids form a mycorrhizal association with soil fungus 

20 and are pollinated by hawkmoths (FWS 2011c). Though suitable habitat exists in the action 

21 area, during the NRC’s site audit (NRC 2011), the FWS noted that it was unable to find any 

22 eastern prairie fringed orchid populations during a 2010 survey within the Ottawa National 

23 Wildlife Refuge. Thus, the NRC staff concludes that the species does not occur in the action 

24 area. The FWS has not designated any critical habitat for this species.

25 Lakeside Daisy (Tetraneuris herbacea). The lakeside daisy is a Federally threatened species. 

26 It inhabits full sun areas of dry, rocky prairie grassland that contain limestone deposits 

27 (ODNR 2011f). Suitable habitat for this species does not exist within the action area. The FWS 

28 has not designated any critical habitat for this species.

29 2.2.8.2 Species Protected Under the Bald and Golden Eagle Protection Act

30 The Bald and Golden Eagle Protection Act prohibits anyone from taking bald eagles (Haliaeetus 

31 leucocephalus) or golden eagles (Aquila chrysaetos), including their nests or eggs, without a

32 FWS-issued permit. The term “take” in the Act is defined as to “pursue, shoot, shoot at, poison, 

33 wound, kill, capture, trap, collect, molest, or disturb” (50 CFR 22.3). “Disturb” means to take 

34 action that causes injury to an eagle; decreases its productivity by interfering with breeding, 

35 feeding, or sheltering behavior; or results in nest abandonment (50 CFR 22.3).

36 According to the ODNR, Ottawa County has one of the highest densities of bald eagle nests in 

37 Ohio (FWS 2010b). Many bald eagle nests are located on the Davis-Besse site and along each 

38 of the four transmission line corridors described in Section 2.1.5. Two bald eagle nests are 

39 specifically located on the Davis-Besse site—one within Navarre Marsh and one northwest of 

40 the cooling tower near the site boundary (FWS 2010b). 

41 FENOC’s (2011) “Environmental Best Management Practices” include procedures to ensure 

42 that bald eagles and their nests are not disturbed during ground disturbing activities, tree 

43 clearance, or other habitat modifications. The procedure directs FENOC staff and contractors to 

44 avoid any activities that could disturb eagles within 660 ft (200 m) of any known nest from 

45 January 1 through July 31. If activities that have the potential to disturb eagles must be 
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1 conducted within these months, FENOC must coordinate with the FWS to discuss potential 

2 mitigation options that could reduce or minimize impacts to eagles. These specifications apply 

3 to the Davis-Besse site as well as the in-scope transmission line corridors.

4 2.2.8.3 Species Protected Under the Migratory Bird Treaty Act

5 The FWS administers the Migratory Bird Treaty Act (MBTA), which prohibits anyone from taking 

6 native migratory birds or their eggs, feathers, or nests. The MBTA definition of a “take” differs 

7 from that of the ESA and is defined as “to pursue, hunt, shoot, wound, kill, trap, capture, or 

8 collect, or any attempt to carry out these activities” (50 CFR 10.12). Unlike a take under the 

9 ESA, a take under the MBTA does not include habitat alteration or destruction. The MBTA 

10 protects 1,007 migratory bird species (75 FR 9282). Of these 1,007 species, the FWS allows 

11 for the legal hunting of 58 species as game birds (FWS undated). Within Ohio, the ODNR 

12 manages migratory bird hunting seasons and associated hunting licenses. All Federally and 

13 State-listed bird species that appear in Tables 2.3-8 and 2.2-10 are protected under the MBTA. 

14 Additionally, all U.S.-native bird species that belong to the families, groups, or species listed at 

15 50 CFR 10.13 are protected under the MBTA. Section 2.2.8.4 discusses occurrences of 

16 protected bird species on and near the Davis-Besse site in more detail.

17 2.2.8.4 Species Protected by the State of Ohio

18 Ohio adopted a Statewide Threatened and Endangered Species Program in 1974. The Ohio 

19 Revised Code prohibits the taking or possession of State-designated endangered wildlife or the 

20 willful uprooting, destruction, or removal of native and State-designated threatened or 

21 endangered plants from public highways, public property, or waters of the state (Ohio Revised 

22 Code §1518.02; Ohio Revised Code §1531.25). Table 2.2-10 lists the Ohio-protected species 

23 that occur in Ottawa County.

24 Table 2.2-10. State-listed Species That Occur in Ottawa County

Species Common Name State Status(a)

Birds

Accipiter striatus(b) sharp-shinned hawk SC

Anas clypeata northern shoveler SI

Anas crecca green-winged teal SI

Anas strepera gadwall SI

Aythya americana redhead SI

Bartramia longicauda upland sandpiper T

Botaurus lentiginosus american bittern E

Casmerodius albus(b) great egret SC

Catharus guttatus(b) hermit thrush T

Chlidonias niger black tern E

Circus cyaneus(b) northern harrier E

Cistothorus platensis sedge wren SC

Cygnus buccinators(b) trumpeter swan E

Dendoica magnolia(b) magnolia warbler SI

Egretta thula(b) snowy egret E
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Species Common Name State Status(a)

Empidonax minimus(b) least flycatcher T

Falco peregrinus(b) peregrine falcon T

Gallinago delicata(b) Wilson’s snipe SI

Grus canadensis(b) sandhill crane E

Haliaeetus leucocephalus bald eagle T

Ixobrychus exilis least bittern T

Nycticorax nycticorax(b) black-crowned night-heron T

Oporornis Philadelphia(b) mourning warbler SI

Oxyura jamaicensis ruddy duck SI

Pandion haliatus(b) osprey T

Porzana carolina sora SC

Protonotaria citrea prothonotary warbler SC

Rallus elegans king rail E

Rallus limicola Virginia rail SC

Sphyrapicus varius(b) yellow-bellied sapsucker E

Sterna hirundo common tern E

Sturnella neglecta western meadowlark SI

Vermivora chrysoptera(b) golden-winged warbler E

Wilsonia Canadensis(b) Canada warbler SI

Fish

Acipenser fulvescens lake sturgeon E

Fundulus diaphanus menona western banded killifish E

Percina copelandi channel darter T

Freshwater Mussels

Cyclonaias tuberculata purple wartyback SC

Ligumia nasuta eastern pondmussel E

Ligumia recta(c) black sandshell T

Obliquaria reflexa threehorn wartyback T

Ptychobranchus fasciolaris kidneyshell SC

Truncilla donaciformis fawnsfoot T

Truncilla truncata deertoe SC

Insects

Aeshna canadensis Canada darner E

Plants

Acorus americanus(c) American sweet-flag P

Ammophila breviligulata american beach grass T

Arabis drummondii Drummond’s rock cress E

Arabis hirsuta var. adpressipilis southern hairy rock cress P
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Species Common Name State Status(a)

Artemisia campestris beach wormwood T

Astragalus canadensis Canada milk-vetch P

Cakile edentula(c) inland sea rocket P

Calamintha arkansana limestone savory T

Campanula rotundifolia harebell T

Carex aquatilis leafy tussock sedge P

Carex atherodes wheat sedge P

Carex aurea golden-fruited sedge P

Carex bebbii Bebb’s sedge P

Carex brevior tufted fescue sedge T

Carex cephaloidea thin-leaved sedge P

Carex garberi Garber’s sedge E

Carex sprengelii Sprengel’s sedge T

Carex viridula little green sedge P

Cyperus diandrus low umbrella-sedge P

Cyperus schweinitzii Schweinitz’s umbrella-sedge T

Dichanthelium lindheimeri Lindheimer's panic grass T

Draba reptans Carolina whitlow-grass T

Eleocharis compressa flat-stemmed spike-rush P

Eleocharis geniculata Caribbean spike-rush E

Eleocharis ovata ovate spike-rush E

Euphorbia polygonifolia seaside spurge P

Hedeoma hispida rough pennyroyal P

Juncus alpinoarticulatus alpine rush P

Juncus balticus baltic rush P

Minuartia michauxii rock sandwort P

Nuphar variegata bullhead-lily E

Oenothera oakesiana Oakes’ evening-primrose P

Packera paupercula balsam squaw-weed T

Panicum philadelphicum philadelphia panic grass E

Panicum tuckermanii Tuckerman’s panic grass T

Phragmites australis ssp. americanus american reed grass T

Platanthera leucophaea prairie fringed orchid T

Potamogeton natans floating pondweed P

Potamogeton richardsonii Richardson’s pondweed P

Potamogeton zosteriformis flat-stemmed pondweed T

Potentilla arguta tall cinquefoil E

Ranunculus fascicularis early buttercup T
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Species Common Name State Status(a)

Rosa blanda smooth rose T

Sagittaria cuneata wapato T

Sagittaria rigida deer’s-tongue arrowhead P

Salix candida hoary willow P

Schoenoplectus smithii Smith’s bulrush E

Sisyrinchium mucronatum narrow-leaved blue-eyed-grass E

Spiranthes magnicamporum great plains ladies’-tresses P

Tortella inclinata curved tortella E

Triglochin palustris marsh arrow-grass P

Triplasis purpurea(c) purple sand grass P

Ulmus thomasii rock elm P

Viola nephrophylla northern bog violet E

Zizania aquatica wild rice T

Reptiles

Elaphe vulpina gloydi eastern fox snake SC

Emydoidea blandingii Blanding’s turtle SC

Nerodia sipedon insularum Lake Erie water snake E

Thamnophis sirtalis(c) melanistic garter snake SC

(a)State status defined by the Ohio Department of Natural Resources under Ohio Revised Code 1531.25. E=endangered; 

P=potentially threatened; SC=species of concern; SI=special interest; T=threatened.

(b)The ODNR’s Natural Heritage Database (ODNR 2013) does not list these species as occurring in Ottawa County. However, 

the BSBO (2003, 2004, 2006a, 2007b, 2007c, 2008a, 2008d, 2008f, 2008e, 2009b, 2009e, 2009f, 2010, 2011a) observed these 

species during annual bird surveys.

(c)The ODNR’s Natural Heritage Database (ODNR 2013) does not list these species as occurring in Ottawa County. However, in 

correspondence between ODNR and FENOC (ODNR 2010), these species were identified as occurring on or near the DavisBesse site.

Source: BSBO 2003, 2004, 2006a, 2007b, 2007c, 2008a, 2008d, 2008f, 2008e, 2009b, 2009e, 2009f, 2010, 2011a; ODNR 

2010a, 2013

1 Birds. The majority of the State-listed birds in Table 2-2.10 occur on the Davis-Besse site 

2 based on data from the BSBO, which conducts long-term research on breeding and migration of 

3 songbirds, raptors, shorebirds, and rails.

4 For songbirds, Table 2.2-11 summarizes the number of individuals banded in 2003, 2004, 2008, 

5 and 2009 at the BSBO’s Navarre Station, which is located within Navarre Marsh (discussed in 

6 more detail in Section 2.2.6) on the Davis-Besse site. According to the BSBO’s progress report 

7 data, the Davis-Besse site and surrounding area provides habitat for eight of the State-listed

8 songbirds. State-listed species account for an average of 10.9 percent of the birds banded 

9 each season. The magnolia warbler (Dendroica magnolia) and hermit thrush 

10 (Catharus guttatus) are the most common State-listed songbirds during both the spring and fall 

11 migration. The Canada warbler (Wilsonia canadensis), mourning warbler (Oporornis 

12 philadelphia), and least flycatcher (Empidonax minimus) primarily use the Davis-Besse area 

13 during spring migration, but they are present in very small numbers during the fall migration as 

14 well. The golden-winged warbler (Vermivora chrysoptera) and yellow-bellied sapsucker 

15 (Sphyrapicus varius) are present, but rare, during both the spring and fall migration. The sedge 
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1 wren (Cistothorus platensis) was not banded during any of the data years, but one individual 

2 was observed on a point count in Navarre Marsh in 2009 (BSBO 2009a). The western 

3 meadowlark (Sturnella neglecta) was not banded at Navarre Station or any of the other 

4 monitoring stations and was also not observed on point counts for the data years. 

5 Table 2.2-11. Songbird Bandings During Annual Migration Surveys, 2003–2009

Species

Number of Individuals Banded

Spring Migration Fall Migration

20032004200820092003200420082009

Canada warbler 90 156 106 125 2 4 9 9

golden-winged warbler 2 2 1 3 1 0 0 0

magnolia warbler 600 879 414 686 190 103 88 115

mourning warbler 126 19 88 109 6 10 5 12

hermit thrush 123 95 95 142 187 172 169 212

least flycatcher 131 39 56 108 2 7 7 2

yellow-bellied sapsucker 1 5 2 1 5 3 3 8

Total Banded

(State-Listed Species) 1,073 1,195 1,762 1,174 393 299 281 358

Total Banded

(All Species) 7,841 8,970 7,822 10,042 4,191 3,206 2,790 3,645

Source: BSBO 2003, 2004, 2008a, 2009b 

6 For raptors, the BSBO conducts annual spring surveys between late February and early May. 

7 Table 2.2-12 summarizes the number of birds counted by species for the available data years 

8 (2006 through 2009). The BSBO surveys 23 sites throughout the marshes on the southwestern 

9 shore of Lake Erie. State-listed raptor species make up an average of 9.7 percent of the 

10 observed raptors each year. Sharp-shinned hawks (Accipiter striatus) and bald eagles 

11 (Haliaeetus leucocephalus) are the most commonly observed raptors, while peregrine falcons 

12 (Falco peregrinus) are the least commonly observed.

13 Table 2.2-12. Spring Raptor Survey Counts in the Lake Erie Marsh Region, 2006–2009

Species

Number of Individuals Observed

2006 2007 2008 2009

sharp-shinned hawk 245 492 389 467

northern harrier 95 122 167 61

peregrine falcon 10 8 3 4

bald eagle 247 181 371 153

osprey 12 14 29 31

Total Count

(State-Listed Species) 364 817 959 716
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Species

Number of Individuals Observed

2006 2007 2008 2009

Total Count

(All Species) 4,339 8,645 8,760 7,184

Source: BSBO 2007c, 2008f, 2009f 

1 For ducks, swans, and shorebirds, the BSBO conducts annual spring surveys in Navarre Marsh 

2 that captures species presence or absence on each day during the spring migration period 

3 (generally from early April through early June). Table 2.2-13 summarizes whether each species 

4 was observed in the survey for the years 2006 through 2011. Of the state-listed duck, swan, 

5 and shorebird species, six were consistently observed each survey year—the great egret 

6 (Ardea alba), black-crowned night-heron (Nycticorax nycticorax), trumpeter swan (Cygnus 

7 buccinator), Virginia rail (Rallus limicola), sora (Porzana carolina), and common tern (Sterna 

8 hirundo). The least bittern (Ixobrychus exilis), northern shoveler (Anas clypeata), and ruddy 

9 duck (Oxyura jamaicensis) were observed during the majority of the survey years (4 out of the 

10 6 years). The remaining species listed in Table 2.2-13 are relatively rare in the area and were 

11 observed less than half of the survey years. The king rail (Rallus elegans), black tern

12 (Chlidonias niger), piping plover, and upland sandpiper (Bartramia longicauda) were not 

13 observed during the annual spring surveys. However, as discussed previously, the piping 

14 plover is known to seasonally occur in the area based on the BSBO’s spring and fall banding 

15 program. Though not recorded in the annual spring surveys, the upland sandpiper has been 

16 recorded during the BSBO’s shorebird migration and habitat use surveys in 2003, 2007, and 

17 2009.

18 Table 2.2-13. Ducks, Swans, and Shorebirds Observed in Annual Spring Surveys at 

19 Navarre Marsh, 2006–2010

Species

Species Observed During Survey Year (Y/N) 

2006 2007 2008 2009 2010 2011

great egret Y Y Y Y Y Y

snowy egret Y N Y N N N

black-crowned night-heron Y Y Y Y Y Y

least bittern N Y Y Y N Y

American bittern N Y Y N N Y

trumpeter swan Y Y Y Y Y Y

green-winged teal N N Y Y N Y

northern shoveler N Y Y Y N Y

redhead N N N Y Y Y

ruddy duck N N Y Y Y Y

sandhill crane N N N Y N Y

Virginia rail Y Y Y Y Y Y

sora Y Y Y Y Y Y

Wilson’s snipe N N N Y N N
Affected Environment

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Species

Species Observed During Survey Year (Y/N) 

2006 2007 2008 2009 2010 2011

common tern Y Y Y Y Y Y

Source: BSBO 2006a, 2007b, 2008d, 2008e, 2009e, 2010, 2011a 

1 Plants. The ODNR (ODNR 2010) identified one Ohio-listed plant species as occurring onsite—

2 the Canada milk-vetch (Astragalus canadensis). The Canada milk-vetch inhabits moist prairies, 

3 open woodlands, roadsides, and streambanks. Because this species occurs in a wide variety of 

4 habitats, it may occur on both the developed and undeveloped portions of the Davis-Besse site. 

5 However, the ODNR (2010) last recorded the Canada milk-vetch on the Davis-Besse site in 

6 1979, and FENOC did not specifically note the occurrence of this species on the site in their ER. 

7 Therefore, it is unknown whether the species still occurs on the Davis-Besse site.

8 The ODNR (2010) noted six additional Ohio-listed plant species that are known to occur along 

9 the Davis-Besse site perimeter or just outside of the site. The six species and their habitats are

10 as follows: 

11 • Schweinitz’s umbrella-sedge (Cyperus schweinitzii)—sandy shores, beaches, and 

12 barrens, 

13 • inland sea rocket (Cakile edentula)—sandy beaches above the high tide line, 

14 • purple sand grass (Triplasis purpurea)—sand dunes, 

15 • seaside spurge (Euphorbia polygonifolia)—sand dunes, 

16 • deer’s-tongue arrowhead (Sagittaria rigida)—swamps and shallow water, and

17 • American sweet-flag (Acorus americanus)—emergent wetlands. 

18 ODNR (2010) has recorded three of these species—Schweinitz’s umbrella-sedge, purple sand 

19 grass, and deer’s-tongue arrowhead—as occurring in the vicinity of the Davis-Besse site as 

20 recently as 2009. The inland sea rocket was last recorded in 1997, the sea side spurge in 1990, 

21 and the American sweet-flag in 1971 (ODNR 2010). Due to these species’ habitat 

22 requirements, if they occur on the Davis-Besse site, all six of these plants would be restricted to 

23 the Lake Erie shoreline and Navarre Marsh. None of these species are likely to occur on the 

24 developed portion of the Davis-Besse site.

25 Fish and Freshwater Mussels. Within the vicinity of Davis-Besse, three State-listed fish species 

26 potentially occur. However, none of these species were identified by the ODNR (ODNR 2010) 

27 as occurring on or in the immediate vicinity of the Davis-Besse site.

28 Five Ohio-listed mussel species have been recorded as occurring in Lake Erie near the portion 

29 of the shoreline adjacent to the Davis-Besse site (ODNR 2010a). These species are: 

30 • purple wartyback (Cyclonaias tuberculata), 

31 • fawnsfoot (Truncilla donaciformis), 

32 • eastern pondmussel (Ligumia nasuta), 

33 • black sandshell (Ligumia recta), and

34 • deertoe (Truncilla truncata). 
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1 However, the ODNR (2010) has not recorded any of these species as occurring in this area 

2 since the late-1960s to late-1970s. The lack of recorded native mussel occurrences likely 

3 coincides with the introduction of the Eurasian dreissenid mussels—the zebra (Dreissena 

4 polymorpha) and quagga (Dreissena rostriformis bugensis) mussels—to Lake Erie in the 1980s.

5 From 2007 through 2009, Crail et al. (2011) surveyed numerous sites along the Lake Erie coast 

6 and within associated coastal marshes for native mussel species. The Toussaint River, which 

7 lies near the southern boundary of the Davis-Besse site, was one of the surveyed sites. Crail et 

8 al. (2011) found live mussels of eight species at the Toussaint River site, none of which were 

9 any of the five State-listed species above. However, Crail et al. (2011) identified three 

10 State-listed species at other sites northeast of the Davis-Besse site—live eastern pondmussel 

11 and deertoe individuals in Bayshore; fresh dead deertoe individuals at the Mamee Bay site; and 

12 fresh dead fawnsfoot individuals at Luna Pier. The Crail et al. (2011) survey indicates that 

13 though these mussel species may no longer occur in the immediate vicinity of Davis-Besse, at 

14 least three of the State-listed species continue to occur within Lake Erie’s western basin.

15 Reptiles. The ODNR (2010) identified three Ohio-listed reptiles as having known occurrences 

16 on the Davis-Besse site—the Blanding’s turtle (Emydoidea blandingii), the eastern fox snake 

17 (Elaphe vulpina gloydi), and the melanistic garter snake (Thamnophis sirtalis). The Blanding’s 

18 turtle is a semi-aquatic turtle that occurs in coves, bays, ponds, and shallow marsh waters. The 

19 eastern fox snake is found in freshwater marshes along Lake Erie and Lake Huron, exclusively. 

20 The melanistic garter snake occurs in a wide variety of habitats, including forests, fields, 

21 prairies, streams, wetlands, meadows, and ponds. All three of these species are likely to inhabit 

22 Navarre Marsh on the Davis-Besse site.

23 Insects. The ODNR (2010) did not identify the occurrence of any State-listed insects on or near

24 the Davis-Besse site. The BSBO conducts annual butterfly surveys within Navarre Marsh and 

25 other areas with the Ottawa National Wildlife Refuge. According to survey results from 2006

26 through 2009, the BSBO did not observe any State-listed butterfly species during their surveys 

27 (BSBO 2006b, 2007d, 2008c, 2009d). Navarre Marsh is likely to provide suitable habitat for the 

28 Canada darner (Aeshna canadensis), which inhabits wooded lakes and ponds, as well as 

29 marshes and bogs, fens, and slow-moving streams.

30 2.2.9 Socioeconomic Factors 

31 This section describes current socioeconomic factors that have the potential to be directly or 

32 indirectly affected by changes in operations at Davis-Besse. Davis-Besse and the communities 

33 that support it can be described as a dynamic socioeconomic system. The communities provide 

34 the people, goods, and services required to operate the nuclear power plant. Power plant 

35 operations, in turn, provide wages and benefits for people and dollar expenditures for goods and 

36 services. The measure of a communities’ ability to support Davis-Besse operations depends on 

37 the ability of the community to respond to changing environmental, social, economic, and 

38 demographic conditions.

39 The socioeconomic region of influence (ROI) is defined by the area where Davis-Besse 

40 employees and their families reside, spend their income, and use their benefits, thereby 

41 affecting the economic conditions of the region. The Davis-Besse ROI consists of a four-county 

42 area (Lucas, Ottawa, Sandusky, and Wood counties), where approximately 88 percent of 

43 Davis-Besse employees reside (FENOC 2010c).

44 FENOC employs a permanent workforce of approximately 825 employees at Davis-Besse 

45 (FENOC 2010c). Approximately 722 employees, or 88 percent, live in Ottawa, Lucas, Wood, 
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1 and Sandusky Counties (Table 2.2-14). Most of the remaining 12 percent of the workforce are 

2 divided among 21 counties in Ohio, Michigan, and Pennsylvania, with numbers ranging from 

3 1 to 46 employees per county. Given the residential locations of Davis-Besse employees, the 

4 most significant impacts of plant operations are likely to occur in Ottawa, Lucas, Wood, and 

5 Sandusky Counties. The focus of the socioeconomic impact analysis in this SEIS is, therefore, 

6 on the impacts of continued Davis-Besse operations on these four counties.

7 Table 2.2-14. Davis-Besse, Employee Residence by County

County Number of Employees Percentage of Total

Ohio

Lucas 163 19.8

Ottawa 307 37.2

Sandusky 124 15.0

Wood 128 15.5

Other counties 103 12.5

Total 825 100.0

Source: FENOC 2010c

8 Refueling outages at Davis-Besse normally occur at 24-month intervals. During refueling 

9 outages, site employment increases by as many as 1,300 temporary workers for approximately 

10 48 days (FENOC 2010c). Most of these workers are assumed to be similarly distributed across 

11 the same geographic areas as Davis-Besse employees. The following sections describe the 

12 housing, public services, offsite land use, visual aesthetics and noise, population demography, 

13 and the economy in the ROI surrounding Davis-Besse.

14 2.2.9.1 Housing

15 Table 2.2-15 lists the total number of occupied and vacant housing units, vacancy rates, and 

16 median value in the four-county ROI. According to 2010 Census estimates, there were 

17 approximately 310,000 housing units in the socioeconomic region, approximately 271,000 of 

18 which were occupied. The vacancy rate was lowest in Wood County (8.1 percent) and highest 

19 in Ottawa County (37.3 percent) of the four counties. The 2009 through 2011 3-year estimated 

20 median value of owner occupied housing units in Lucas, Ottawa, Sandusky, and Wood Counties 

21 was $113,500, $137,200, $112,300, and $153,900, respectively (USCB 2012). 
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1 Table 2.2-15. Housing in Lucas, Ottawa, Sandusky, and Wood Counties in Ohio in 2010

Lucas Ottawa Sandusky Wood ROI

total 202,630 27,909 26,390 53,376 310,305

occupied housing units 180,267 17,503 24,182 49,043 270,995

vacant units 22,363 10,406 2,208 4,333 39,310

vacancy rate (percent) 11.0 37.3 8.4 8.1 12.7

median value, owner occupied 

housing (dollars) (estimated) 113,500 137,200 112,300 153,900 129,225

Source: USCB 2012 

2 2.2.9.2 Public Services

3 This section presents information regarding public services including water supply, education, 

4 and transportation.

5 Water Supply

6 There are six major public water suppliers In Lucas and Ottawa Counties. Toledo Public Water 

7 System in Lucas County serves a population of 380,000, while Ottawa County Regional system 

8 serves a population of 14,500 with the largest capacity and daily demand served, with smaller 

9 systems supplying other municipalities in the county (Table 2.2-16). There are also two major 

10 public water suppliers in Sandusky County—Fremont City Public Water System has the largest 

11 capacity at 7,500,000 gallons per day, while the Clyde Public Water System, serves a 

12 population of 5,900.

13 Davis-Besse obtains water from the Carroll Township water system, which has excess capacity 

14 of 700,000 gallons per day (FENOC 2010c). 

15 Table 2.2-16. Major Public Water Supply Systems (Million Gallons Per Day)

Counties Public Water System Population 

Served

Water Use Treatment Capacity

Lucas Toledo 380,000 75,838 181,000

Oregon City 18,334 4,463 8,087

Ottawa Marblehead Village 1,600 193 553

Put-in-Bay Village 700 67 140

Ottawa County Regional 14,500 3,507 9,000

Carroll 200 300 1,000

Sandusky Clyde 5,900 958 2,000

Fremont City 500 4,317 7,500

Wood Bowling Green City 30,000 3,389 5,400

North Baltimore 3,361 550 1,600

Source: FENOC 2010a 
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1 Education

2 There are eight school districts in Lucas County with 117 schools and an enrollment of 

3 55,548 students during the 2009 to 2010 school year. Sandusky County has four school 

4 districts with 19 schools and 8,537 students. Wood County has 10 school districts with 

5 49 schools and 17,917 students. In Ottawa County, the county in which Davis-Besse is located, 

6 there are seven school districts with 19 schools and 5,530 students (NCES 2010).

7 There are three public universities within 50 mi of Davis-Besse, which employed approximately 

8 6,024 full- and part-time faculty during the 2009 school year. Student enrollment at the public 

9 universities in 2009 was approximately 80,176 (IES 2010).

10 Transportation. There are many major roads used by plant workers commuting to Davis-Besse. 

11 State Highway Route 2, located immediately adjacent to Davis-Besse, provides local access to 

12 the surrounding area. State Highway Route 2 runs through mostly rural and uncongested 

13 areas. The two-lane highway is used extensively by commercial truck carriers. Approximately 

14 6 mi east of the site (and continuing east), Route 2 becomes a four-lane, divided and 

15 limited-access highway (FENOC 2010c). Table 2.2-17 lists commuting routes to Davis-Besse 

16 and average annual daily traffic (AADT) volume values. The AADT values represent traffic 

17 volumes for a 24-hour period factored by both day of week and month of year.

18 Table 2.2-17. Major Commuting Routes in the Vicinity of Davis-Besse, 2009 Average 

19 Annual Daily Traffic Count

Roadway & Location Average Annual Daily Traffic (AADT)(a)

SR-2, West of Davis-Besse

at Lucas County line 6,200

at SR-579 intersection 6,510

at SR-590 intersection 7,310

at SR-19 intersection 7,330

SR-2, East of Davis-Besse

at SR-358 intersection 6,950

at SR-163 intersection 11,990

at SR-53 intersection 12,970

(a) All AADTs represent traffic volume during the average 24-hour day during 2009. 

Source: OHDOT 2010

20 2.2.9.3 Offsite Land Use

21 Offsite land use conditions in Lucas, Ottawa, Sandusky, and Wood Counties are described in 

22 this section because 88 percent of the Davis-Besse permanent workforce lives in these four 

23 counties.

24 Lucas County has the largest urban area, accounting for nearly 37 percent of the total county 

25 area. It is also the most populated of the of the four-county area, with Toledo being the county 

26 seat and largest city (Lucas 2011). Ottawa County, the smallest of the four counties in land 

area (approximately 260 m2 (670 km2 27 ), is typical of the rural land-use character of the 
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1 four-county area. Over 90 percent of the total county area comprises cropland, pasture, forest, 

2 open water, and wetlands. Urban areas, on the other hand, account for less than 10 percent of 

3 the total county area. Wood and Sandusky Counties have a similar distribution of land area. 

4 Ottawa County, although the smallest in land area, has the most open water (7 percent), as its 

5 northeastern boundary abuts Lake Erie and includes a peninsula and several islands 

6 (Ottawa 2011). Sandusky County is similar in land category to Wood County, with most land in 

farms. The county’s land area (approximately 410 m2 (1,060 km2 7 )), number of farms (770) is 

8 second only to Wood County (Sandusky 2011). Wood County is the largest county in land area 

(approximately 620 m2 (1,600 km2 9 )) and comprises the most land in farms (269,000 ac) and 

10 most number of farms (1,180). Wood and Sandusky county have a similar average farm size at 

11 approximately 230 ac (90 ha)) (Wood 2011).

12 2.2.9.4 Visual Aesthetics and Noise

13 The topography of the Davis-Besse site and vicinity is relatively flat, bordered by marsh areas, 

14 Lake Erie, and the upland area rising to only 10 to 15 ft above the lake level. The site varies in 

15 elevation from marsh bottom, below lake level, to approximately 6 ft above lake level 

16 (FENOC 2010c).

17 The developed portions of the Davis-Besse site have 17 major structures, located approximately 

18 3,000 ft (914 m) from the Lake Erie shoreline. The turbine building is 104 ft (approximately 

19 32 m) high. West of the turbine building is the containment building standing 225 ft 

20 (approximately 69 m) high. West of the containment building is the switchyard and south of 

21 there is the 328 ft (100 m) meteorological tower. Visible from State Highway 2 and Lake Erie, 

22 the cooling tower stands approximately 490 ft (150 m) high (AEC 1973).

23 Given the industrial nature of the Davis-Besse station site, noise emissions from the site are 

24 intermittent minor nuisance in the vicinity. Noise levels may sometimes exceed the 55 dba level 

25 that the U.S. EPA uses as a threshold to protect against excess noise during outdoor activities 

26 (EPA 1974). To date, FENOC has received no complaints concerning noise from station 

27 operations. 

28 2.2.9.5 Demography

29 According to the 2010 Census, an estimated 105,944 U.S. residents live within 20 mi (32 km) of 

30 Davis-Besse, which equates to a population density of 178 persons per square mile 

31 (CAPS 2012). This translates to a Category 4, “least sparse,” population density using the 

32 GEIS measure of sparseness (greater than or equal to 120 persons per square mile within 

33 20 mi (32 km) of the plant). An estimated 1,809,026 U.S. residents live within 50 mi (80 km) of 

34 Davis-Besse with a population density of 365 persons per square mile (CAPS 2012). This 

35 translates to a Category 4, “in close proximity,” population using the GEIS measure of proximity 

36 (greater than or equal to 190 persons per square mile within 50 mi (80 km) of the plant). 

37 Therefore, Davis-Besse is located in a high-population area based on the GEIS sparseness and 

38 proximity matrix.

39 Table 2.2-18 shows population projections and growth rates from 1970 through 2050 in Lucas, 

40 Ottawa, Sandusky, and Wood Counties in Ohio. The growth rate in Lucas and Sandusky 

41 Counties showed a decrease of 2.9 and 1.4 percent, respectively, for the period of 2000

42 through2010. Ottawa and Wood County population shows an increase from 1990 through 2000 

43 (1.1 and 3.6 percent, respectively). Wood County population is expected to increase over the 

44 next decades and through 2050, while Lucas and Sandusky Counties are expected to continue 
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1 to decrease; Ottawa County population is expected to initially decrease and then slightly 

2 increase over the same period.

3 Table 2.2-18. Population and Percent Growth in Lucas, Ottawa, Sandusky, and Wood 

4 Counties from 1970–2010 and Projected for 2020–2050

Lucas Ottawa Sandusky Wood

Year Population

Percent 

Growth(a) Population

Percent 

Growth(a) Population

Percent 

Growth(a) Population

Percent 

Growth(a) 

1970 484,370 ----- 37,099 ----- 60,983 ----- 89,722 -----

1980 471,741 -2.6 40,076 8.0 63,267 3.7 107,372 19.7

1990 462,361 -2.0 40,029 -0.1 61,963 -2.1 113,269 5.5

2000 455,050 -1.6 40,990 2.4 61,790 -0.3 121,070 6.9

2010 441,815 -2.9 41,428 1.1 60,944 -1.4 125,488 3.6

2020 434,648 -1.6 40,269 -2.8 57,903 -5.0 133,326 6.2

2030 417,873 -3.9 38,522 -4.3 56,416 -2.6 141,877 6.4

2040 410,519 -1.8 40,638 5.5 56,831 0.7 150,388 6.0

2050 400,011 -2.6 40,854 0.5 55,922 -1.6 158,266 5.2

---- = No data available. 

(a) Percent growth rate is calculated over the previous decade. 

Source: Population data for 1970–2000 (USCB 2012); population projections for 2010–2030 (ODD 2003); projections for 2040 and 

2050 (calculated).

5 Demographic Profile

6 The demographic profiles of the four-county ROI population are presented in Table 2.2-19. In 

7 2010, minorities (race and ethnicity combined) comprised 22.7 percent of the total four-county 

8 population. The largest minority populations in the four-county area include Black or African 

9 American at 13 percent, followed by Hispanic or Latino (of any race) at 5.9 percent.
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1 Table 2.2-19. Demographic Profile of the Population in the Davis-Besse Four-County 

2 Socioeconomic Region of Influence in 2010

Lucas Ottawa Sandusky Wood ROI

total population 441,815 41,428 60,944 125,488 669,675

Race (Percent of Total Population, Not-Hispanic or Latino)

White 71.0 93.6 86.2 90.1 77.3

Black or African American 18.7 0.7 2.7 2.3 13.0

American Indian & Alaska Native 0.2 0.1 0.2 0.2 0.2

Asian 1.5 0.3 0.3 1.5 1.3

Native Hawaiian or other Pacific Islander 0.0 0.0 0.0 0.0 0.0

some other race 0.2 0.0 0.1 0.1 0.1

two or more races 2.3 1.0 1.7 1.3 2.0

Ethnicity 

Hispanic or Latino 26,974 1,755 5,435 5,663 39,827

percent of total population 6.1 4.2 8.9 4.5 5.9

Minority Population (Including Hispanic or Latino Ethnicity) 

total minority population 128,219 2,648 8,417 12,467 151,751

percent minority 29.0 6.4 13.8 9.9 22.7

Source: USCB 2012 

3 Transient Population

4 Within 50 mi (80 km) of Davis-Besse, colleges and recreational opportunities attract daily and 

5 seasonal visitors who create demand for temporary housing and services. In 2009, there were 

6 approximately 105,672 students attending universities within 50 mi (80 km) of Davis-Besse 

7 (IES 2010).

8 There are 19 counties across two states within a 50-mi radius of Davis-Besse. Of those 

9 counties, approximately 3.0 percent of the housing units are considered temporary housing for 

10 seasonal, recreational, or occasional use in 2010. Over 30 percent of the housing units in 

11 Ottawa County are considered seasonal housing. By comparison, seasonal housing accounted 

12 for 0.4, 1.1, and 0.6 percent of total housing units in Lucas, Sandusky and Wood Counties, 

13 respectively (USCB 2012). Four counties in Michigan within 50 mi (80 km) of Davis-Besse, only 

14 one (Lenawee) has seasonal housing units comprising more than 5 percent of total housing 

15 units. Table 2.2-20 provides information on seasonal housing for the 19 counties located all or 

16 partly within 50 mi of Davis-Besse (USCB 2012).
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1 Table 2.2-20. Seasonal Housing in Counties Located within 50 Miles of Davis-Besse

County(a) Housing Units

Vacant Housing Units—for seasonal, 

Recreational, or Occasional Use Percent

Ohio

Ashland 22,141 413 1.9

Crawford 20,167 90 0.4

Erie 37,845 2,866 7.6

Fulton 17,407 112 0.6

Hancock 33,174 161 0.5

Henry 11,963 66 0.6

Huron 25,196 246 1.0

Lorain 127,036 714 0.6

Lucas 202,630 755 0.4

Ottawa 27,909 8,581 30.7

Richland 54,599 405 0.7

Sandusky 26,390 281 1.1

Seneca 24,122 121 0.5

Wood 53,376 329 0.6

Wyandot 9,870 62 0.6

Michigan

Lenawee 43,452 2,414 5.6

Monroe 62,971 426 0.7

Washtenaw 147,573 1,403 1.0

Wayne 821,693 2,544 0.3

Total 1,747,373 21,576 2.9

(a) These are counties within 50 mi (80 km) of Davis-Besse with at least one block group located within the 50-mi (80-km) radius. 

Source: USCB 2012

2 Migrant Farm Workers

3 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

4 crops. These workers may or may not have a permanent residence. Some migrant workers 

5 follow the harvesting of crops, particularly fruit, throughout rural areas of the U.S. Others may 

6 be permanent residents near the Davis-Besse who travel from farm to farm harvesting crops.

7 Migrant workers may be members of minority or low-income populations. Because they travel 

8 and can spend a significant amount of time in an area without being actual residents, migrant 

9 workers may be unavailable for counting by census takers. If uncounted, these workers would 

10 be “underrepresented” in U.S. Census Bureau (USCB) minority and low-income population 

11 counts.
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1 Information on migrant farm and temporary labor was collected in the 2007 Census of 

2 Agriculture. Table 2.2-21 provides information on migrant farm workers and temporary farm 

3 labor (less than 150 days) within 50 mi of Davis-Besse. According to the 2007 Census of 

4 Agriculture, approximately 11,126 farm workers were hired to work for less than 150 days and 

5 were employed on 2,313 farms within 50 mi of Davis-Besse. The county with the largest 

6 number of temporary farm workers (1,595) on 122 farms was Huron County (NASS 2009).

7 Table 2.2-21. Migrant Farm Workers and Temporary Hired Farm Labor in Counties 

8 Located Within 50 Miles of Davis-Besse

County(a) Number of farms 

With Hired Farm 

Labor

(b)

Number of Farms 

Hiring Workers for 

Less Than 150 Days(b)

Number of Farm 

Workers Working for 

Less Than 150 Days(b)

Number of Farms 

Reporting Migrant 

Farm Labor(b)

Ohio

Ashland 213 184 421 5

Crawford 119 107 313 4

Erie 88 68 383 9

Fulton 173 148 686 13

Hancock 146 130 324 6

Henry 128 119 487 9

Huron 145 122 1,595 7

Lorain 195 156 651 14

Lucas 91 78 519 14

Ottawa 92 78 408 10

Richland 146 113 385 4

Sandusky 158 140 699 23

Seneca 179 154 347 12

Wood 170 148 600 11

Wyandot 100 82 350 4

County Subtotal 1,143 1,827 8,168 145

Michigan

Lenawee 262 214 908 22

Monroe 222 193 1,035 27

Washtenaw 250 198 835 12

Wayne 86 65 601 6

County Subtotal 820 670 3,379 67

Total 2,963 2,497 11,547 212

(a) These are counties within 50 mi of Davis-Besse with at least one block group located within the 50-mi radius. 

(b) Table 7. Hired Farm Labor—Workers and Payroll: 2007 

Source: NASS 2011a, 2011b, 2011c
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1 In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 

2 any hired migrant workers, defined as a farm worker whose employment required travel that 

3 prevented the migrant worker from returning to their permanent place of residence the same 

4 day. Within the 50-mi radius of the Davis-Besse, 207 farms reported hiring migrant workers in 

5 the 2007 Census of Agriculture. Monroe County in Michigan reported the most farms (27) with 

6 hired migrant workers, followed by Sandusky County in Ohio, with 23 farms (NASS 2009). 

7 According to the 2007 Census of Agriculture estimates, 519 temporary farm workers (those 

8 working fewer than 150 days per year) were employed on 78 farms in Lucas County, and 

9 408 temporary farm workers were employed on 78 farms in Ottawa County. Sandusky County 

10 has 699 temporary farm workers (those working fewer than 150 days per year) employed on 

11 140 farms, and 600 emporary farm workers were employed on 148 farms in Ottawa County 

12 (NASS 2009). 

13 2.2.9.6 Economy

14 This section contains a discussion of the economy, including employment and income, 

15 unemployment, and taxes.

16 Employment and Income

17 A list of some of the major employers in Ottawa County is provided in Table 2.2-22. As shown 

18 in the table, nine major employers are identified in Ottawa County; three of which were 

19 Government, two manufacturing, two service, one trade, and one (FENOC) utility.

20 Table 2.2-22. Major Employers in Ottawa County, 2009

Employer Type of Industry 

Benton-Carroll-Salem Local Schools Government

Brush Wellman, Inc. manufacturing 

FirstEnergy Corp utility

Luther Home of Mercy service 

Magruder Hospital service

Ottawa County Government Government

Port Clinton City Schools Government

USGS Corp/U.S. Gypsum Co. manufacturing

Wal-Mart Stores, Inc. trade

Source: http://www.development.ohio.gov/research/files/S0/Ottawa.pdf

21 According to the 2008 through 2010 American Community Survey 3-year estimates, education 

22 services, health care, and social assistance represented the largest sector of employment 

23 (26.2 percent) followed by manufacturing (15.7 percent). In Ottawa County, retail services 

24 represented the largest sector of employment (22.4 percent) followed by manufacturing 

25 (17.0 percent). In Sandusky County, manufacturing represented the largest sector of 

26 employment followed by education services, health care, and social assistance. A list of 

27 employment by industry in the ROI is presented in Table 2.2-23. 
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1 Table 2.2-23. Employment by Industry in ROI, 2008-2010 3-Year Estimate

Industry Lucas Ottawa Sandusky Wood Total Percent

Total employed civilian workers 196,651 19,861 28,753 61,250 306,515 100

Agriculture, forestry, fishing and 

hunting, and mining 570 306 762 609 2,247 0.7

Construction 9,136 1,564 1,681 2,737 15,118 4.9

Manufacturing 27,661 3,162 7,597 9,627 48,047 15.7

Wholesale trade 5,816 386 522 1,735 8,459 2.8

Retail trade 23,758 2,443 3,022 7,165 36,388 11.9

Transportation, warehousing, and 

utilities 11,750 1,607 1,553 3,231 18,141 5.9

Information 3,102 166 300 1,122 4,690 1.5

Finance, insurance, real estate, rental, 

and leasing 9,998 927 811 2,947 14,683 4.8

Professional, scientific, management, 

administrative, and waste 

management services

16,826 946 1,285 4,662 23,719 7.7

Educational, health, and social 

services 52,035 4,477 6,503 17,315 80,330 26.2

Arts, entertainment, recreation, 

accommodation, and food services 20,721 2,232 2,607 5,105 30,665 10.0

Other services (except public 

administration) 8,946 909 1,359 2,858 14,072 4.6

Public administration 6,332 736 751 2,137 9,956 3.2

Source: USCB 2012 

2 Estimated income information for the Davis-Besse ROI is presented in Table 2.2-24. According 

3 to the U.S. Census Bureau’s (USBCs) 2008 through 2010 American Community Survey 3-year 

4 estimates, median household income were above the State average in Ottawa, Sandusky, and 

5 Wood Counties and lower in Lucas County. Ottawa and Wood Counties per capita income 

6 were above the State average, and they were lower in Lucas and Sandusky Counties. An 

7 estimated 19.1, 10, 11.6, and 12.2 percent of individuals in Lucas, Ottawa, Sandusky, and 

8 Wood Counties were living below the official poverty level, respectively, while Ohio, as a whole, 

9 had 14.8 percent of individuals living below the poverty level. The percentage of families living 

10 below the poverty level in Lucas, Ottawa, Sandusky, and Wood Counties was 14.9, 6.9, 7.9, 

11 and 7.3 percent, respectively. The percentage of families in Ohio as a whole was 10.8 percent 

12 (USCB 2012).
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1 Table 2.2-24. Estimated Income Information for the Davis-Besse Four-County 

2 Socioeconomic Region of Influence, 2008–2010 3-Year Estimate

Lucas Ottawa Sandusky Wood Ohio

median household income (dollars)(a) 40,017 51,712 46,024 52,512 46,563

per capita income (dollars)(a) 23,127 27,113 21,748 25,724 24,738

individuals living below the poverty level 

(percent) 19.1 10.0 11.6 12.2 14.8

families living below the poverty level 

(percent) 14.9 6.9 7.9 7.3 10.8

(a) In 2010 inflation-adjusted dollars 

Source: USCB 2012

3 Unemployment

4 According to the USCB’s 2008 through 2010 American Community Survey 3-year estimates, the 

5 unemployment rates in Lucas, Ottawa, Sandusky, and Wood Counties were 8.8, 4.9, 5.0, and 

6 7.7 percent, respectively (USCB 2012). The unemployment rate for the State of Ohio was 6.3 

7 (USCB 2012).

8 Taxes

9 The Ohio Tax Reform Act (Amended Substitute House Bill 66,126th General Assembly) went 

10 into effect on July 1, 2005. The Act has made significant changes in the structure of almost all 

11 major state and local taxes. Major business tax components of the Ohio Tax Reform Act 

12 consist of the phase-out of, tangible personal property tax (which excludes electric companies), 

13 corporate franchise tax, and the phase-in of the commercial activity tax. It is a privilege tax 

14 measured by gross receipts from activities within the State. The fully phased-in 0.26 percent 

15 commercial activity tax rate took effect on April 1, 2009 (impacting fiscal year 2010 tax 

16 revenues). Table 2.2-25 shows prior phase-in rates.

17 Table 2.2-25. 2005–2009 3-Year Phase-In Rates Percentage Result of the July 2005 Ohio 

18 Tax Reform Act and the Fully Phased-In 0.26 Percent Commercial Activity Tax

Tax Period Base Tax Rate (Percent) Phase-On Percentage Effective Rate (Percent)

July–December 2005 0.06 N/A 0.0600

January–March 2006 0.26 23 0.0598

April 2006–March 2007 0.26 40 0.1040

April 2007–March 2008 0.26 60 0.1560

April 2008–March 2009 0.26 80 0.2080

After March 2009 0.26 100 0.2600

Source: FENOC 2010c 

19 Table 2.2-26 compares property taxes paid by FENOC for Davis-Besse to the annual total 

20 operating budgets for Ottawa County, Carroll Township, Benton-Carroll-Salem School District, 

21 and the Penta County Joint Vocational School for the years 2004 through 2008. During this 
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1 5-year period, Davis-Besse property taxes contributed less than 10 percent to the Ottawa 

2 County total operating budget. The percentage of Davis-Besse property tax to the operating 

3 budget in Carroll Township, where Davis-Besse is located, varied widely from about 11 percent 

4 to nearly 28 percent. Property taxes paid to the Benton-Carroll-Salem School District and the 

5 Penta County Joint Vocational School, on the other hand, were more stable, averaging about 

6 17 percent for the school district and 1.6 percent for the vocational school.

7 The amount of future property tax payments for Davis-Besse and the proportion of those 

8 payments are dependent on future market value of the units, future valuations of other 

9 properties in these jurisdictions, and other factors. FENOC assumes that the values presented 

10 in Table 2.2-26 are substantially representative of conditions that would exist in the license 

11 renewal term of the unit.

12 Table 2.2-26. Davis-Besse Property Tax Distribution and Jurisdictional Operating 

13 Budgets, 2004–2008

Year Property Tax Paid by

Davis-Besse (Dollar) 

Operating Budget (Dollar) Percent of Operating Budget 

(Percent) 

Ottawa County

2004 846,190 13,808,101 6.1

2005 1,171,511 13,909,810 8.4

2006 830,177 15,111,168 5.9

2007 949,380 15,846,381 6.0

2008 897,881 16,053,182 5.6

Carroll Township

2004 485,644 4,334,322 11.2

2005 675,842 3,510,297 19.3

2006 533,277 1,908,000 27.9

2007 551,766 2,307,692 23.9

2008 558,791 4,829,032 11.6

Benton-Carroll-Salem Local School District

2004 3,211,588 20,142,955 15.9

2005 4,484,582 21,114,350 21.2

2006 3,495,600 20,953,869 16.7

2007 3,607,888 22,038,419 16.4

2008 3,707,221 23,938,413 15.5

Penta County Joint Vocational School

2004 372,018 24,832,789 1.5

2005 507,832 25,644,335 2.0

2006 397,738 26,553,076 1.5

2007 412,907 28,015,110 1.5
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Year Property Tax Paid by

Davis-Besse (Dollar) 

Operating Budget (Dollar) Percent of Operating Budget 

(Percent) 

2008 417,247 29,793,427 1.4

Source: FENOC 2010c 

1 2.2.10 Historic and Archaeological Resources 

2 This section discusses the cultural background and known historic and archaeological 

3 resources in and around Davis-Besse.

4 2.2.10.1 Cultural Background

5 The area in and around Davis-Besse has a low-to-moderate potential for significant prehistoric 

6 and historic resources. Human occupation of the Ohio area is generally characterized based on 

7 the following chronologic cultural sequence (Lepper 2005): 

8 • Paleo-Indian Period (14,000+ to 10,000 years before present (BP)), 

9 • Archaic Period (10,000 to 2,500 BP), 

10 • Early Woodland Period (2,800 to 2,000 BP), 

11 • Middle Woodland Period (2,100 to 1,500 BP), 

12 • Late Woodland Period (1,500 to 1,100 BP), and

13 • Late Prehistoric Period (1,100 to 400 BP). 

14 The Paleo-Indian Period is generally characterized by highly mobile bands of hunters and 

15 gatherers. Little information regarding subsistence is available for the Paleo-Indian Period in 

16 Ohio, although it is likely that these groups hunted small game and now-extinct megafauna 

17 (e.g., mastodon, saber-tooth tiger, and ground sloth) and gathered wild plants. Typical 

18 Paleo-Indian sites in Ohio consist of an isolated projectile point (of a style characteristic of the 

19 period, notably the fluted Clovis points). Over 1,000 projectile points have been found in the 

20 State, especially in the Ohio River drainage south of Davis-Besse (Neusius and Gross 2007). 

21 One documented fluted projectile point is located at the Peters site in Ottawa County, south of 

22 Davis-Besse along the Portage River was discovered (Prufer and Shane 1973). In addition to 

23 projectile points (both fluted and unfluted lancelote points), the Paleo-Indian tool kit included 

24 gravers, scrapers, knives, and biface blanks used to construct tools. Paleo-Indians prized 

25 high-quality stone for making their stone tools, especially the black flint from Coshocton County 

26 in Ohio (well to the southeast of the Davis-Besse), which was used for making most of the fluted 

27 Paleo-Indian projectile points that have been found in the state (Lepper 2005). However, there 

28 are several sites in Ohio that consist of more substantial Paleo-Indian cultural artifacts. At 

29 Sheridan Cave, about 45 mi (72 km) south of Davis-Besse, archaeologists found projectile 

30 points and stone tools associated with more than 60 species of the aforementioned extinct 

31 megafauna (Tankersly 1997). A Paleo-Indian base camp with a concentration of 6,835 stone 

32 tools was found at the Nobles Pond site in Stark County, southeast of Davis-Besse near 

33 Canton, Ohio (Lepper 2005).

34 The Archaic Period is generally distinguished from the preceding Paleo-Indian Period by 

35 changes in technology, population growth, and a changing environment. Technological 

36 changes are evidenced by the manufacture of notched projectile points, as well as tools and 

37 ornaments made from both bone and copper, in addition to ground stone tools. Toward the end 

38 of the Archaic Period, pottery was also being manufactured. As the Archaic period progressed, 

39 groups began adapting to a more stable, drier, and warmer environment, becoming more settled 
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1 in their residential patterns. Toward the end of the Archaic Period, groups that resided in the 

2 river floodplains began the process of plant domestication and agriculture (Smith 1989). 

3 Additionally, as groups became more settled, they engaged in long-distance exchange 

4 networks. Their reduced mobility required them to establish connections with other groups that 

5 would engage in trade and exchange (Neusius and Gross 2007). Archaic sites in the vicinity of 

6 Davis-Besse are unlikely, as the area was a part of the Great Black Swamp. Prior to draining in 

7 the 19th and 20th centuries, the Great Black Swamp encompassed an area about 

8 120 mi(190 km) long, and 30 to 40 mi (50 to 60 km) wide. Most of that area would not have 

9 been a favorable location for groups to inhabit during this time. However, Archaic sites have 

10 been found around the margins of the swamp, as well as fishing camps on the islands in Lake 

11 Erie (Lepper 2005). A predictive model for archaeological deposits has been proposed by 

12 Murphy (1988), suggesting that sites are most likely to be found on slightly elevated soils, 

13 specifically the Nappanee soil type.

14 During the Early Woodland Period, native groups began a gradual transition to a heavier 

15 reliance on domesticated plants, pottery, and established a more elaborate mortuary ritual. 

16 Building upon some of the characteristics of the cultures from the Early Woodland Period, the 

17 Hopewell Culture occupied large portions of Ohio in the subsequent Middle Woodland Period; 

18 however, some of the groups in the northern and eastern parts of Ohio continued the Early 

19 Woodland Period lifestyle without adopting the Hopewell lifeways. The Hopewell Culture was 

20 characterized by vast trade networks, increasing dependence on agriculture, mound and 

21 earthwork construction, as well as elaborate artifacts that were created and often found in vast 

22 amounts in burial contexts. These included plain and effigy pipes, pottery effigies, Hopewell 

23 series pottery, pottery and copper ear spools, panpipes and celts, and other artifacts fashioned 

24 from non-local materials (Neusius and Gross 2007). Most Early and Middle Woodland Period 

25 sites are found farther south than the area in and around Davis-Besse, although there are some 

26 sites that have been found in northern Ohio that would not be characterized as Hopewell but are 

27 from the same period (Lepper 2005).

28 The Late Woodland Period saw the decline of the Hopewell Culture and the vast trade networks 

29 that accompanied it. Consequently, most of the artifacts from this period were crafted from 

30 more locally procured materials. Despite the fact that the Hopewell Culture no longer continued 

31 to thrive, population continued to grow, and groups continued to congregate in villages and 

32 increase their social organization. Settlements were not just located in river valleys (as had 

33 been the norm in previous periods) but spread out into the landscape (Lepper 2005). 

34 Technological changes included the bow and arrow, which was adopted by 1,200 BP, 

35 evidenced by smaller notched and un-notched triangular projectile points. Agriculture played a 

36 large role in the subsistence systems of many Late Woodland groups, with increasing focus on 

37 domesticated crops; however, groups located near the margin of Lake Erie continued to rely on 

38 hunting, gathering, and fishing. In some areas, the Late Woodland Period continued unchanged 

39 until contact with European groups, while in other areas, the Late Prehistoric Period (also known 

40 as the Mississippian Period in parts of Ohio) began around 1,100 BP. The Late Prehistoric 

41 Period groups adopted maize agriculture along with beans and squash but continued a mixed 

42 economy in which hunting and gathering still played a prominent role.

43 Groups in and around Davis-Besse were not direct participants of the Mississippian or Iroquois 

44 culture’s but likely were influenced by some elements (Lepper 2005). Several sites associated 

45 with the Mississippian Culture have been located along the Maumee River and its tributaries 

46 (Prahl et al. 1973). Those who resided on the western portion of Lake Erie during the Late 

47 Prehistoric Period were a part of the Sandusky Culture. Referred to as the Fire Nation by the 

48 Iroquois, the Sandusky Culture was both a trading and war partner of the Iroquois. There is 
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1 evidence for increasing violence between Late Prehistoric groups, with some villages 

2 surrounded by palisades, and burials with traumatic injury incurred by projectile points 

3 (Lepper 2005). Almost 200 years prior to the arrival of Europeans in Ohio, Native American 

4 groups came into contact with European trade goods such as glass beads and iron and brass 

5 implements, as well as European diseases (Neusius and Gross 2007). At least four sites in 

6 close proximity to Davis-Besse have been documented with these European trade goods (the 

7 Indian Hills site, the La Salle site, the Petersen site, and the Edwards site). During this 

8 Proto-Historic Period, European demand for furs encouraged Native American groups to 

9 respond to this need. The Iroquois Tribe, in particular, made trade connections with European 

10 groups, forcing out many of the groups along Lake Erie, especially in the fur-rich Great Black 

11 Swamp area, in an effort to control the fur trade (Lepper 2005). The area around Davis-Besse, 

12 and most of Ohio, saw successive waves of Native American refugees as they were pushed out 

13 of their eastern seaboard and southern Appalachian piedmont areas. It is likely that the 

14 Wyandot and Ottawa tribes would have used the land in the area of Davis-Besse in this period 

15 prior to their forced move west into the area around southern Wisconsin by the Iroquois 

16 Confederation (Lepper 2005; Tanner 1987).

17 During the historic period, Native American groups continued to live in the area around 

18 Davis-Besse, trading with Europeans and colonists. The Euro-American presence continued to 

19 press into the territory occupied by the Native Americans, constructing trading posts and forts 

20 near Lake Erie. The area around present day Sandusky was home to both a French and British 

21 fort, as well as a French trading post during the mid-18th century (Tanner 1987). Three 

22 Wyandot settlements were also in the Sandusky region at the same time, and other Native 

23 American villages were located along the Maumee River to the north of Davis-Besse 

24 (Tanner 1987). Native American groups continued to fight back against the white settlement for 

25 their territory. This conflict came to a head at the Battle of Fallen Timbers along the Maumee 

26 River, just outside of Perrysburg, OH, west of Davis-Besse. The infamous General “Mad 

27 Anthony” Wayne commanded the American forces and engaged the Native Americans on 

28 August 20, 1794. The American forces drove the Native Americans from the battlefield, after 

29 which they fled to Fort Miamis and were denied refuge by the British forces. The Treaty of 

30 Greenville was signed the following year; it secured the Ohio and the Northwest Territory for the 

31 U.S. and allowed additional settlement by American pioneers (Ohio History Central 2005). By 

32 the 1830s, white populations had pushed the Native American groups out of the area currently 

33 occupied by Davis-Besse. The influx of white settlers was precipitated by the construction of 

34 the Erie Canal in 1825, which facilitated settlement of the western portion of the lake 

35 (Tanner 1987). The construction of the Maumee and Western Reserve Road, connecting 

36 Perrysburg to Fremont, OH, through the Great Black Swamp, also helped settlers migrate to the 

37 area. Initially, this road was a trail used by Native Americans, but, after several treaties, the 

38 31-mi (50-km) long road was ceded to the U.S. Government by 1808. The road was used 

39 heavily during the War of 1812 and became a part of the “Great Trail” that connected Pittsburgh 

40 to Detroit. By 1827, the road had been improved enough so as to make it relatively passable for 

41 wagons, but, after a few years, its condition worsened. The road became notorious for its 

42 difficult conditions. It was given the nickname “Mud Pike,” and, consequently, several taverns 

43 were constructed along the route to service the troubled travelers. In the 1840s, the road was 

44 improved and made a toll road, after extensive draining of the Great Black Swamp took place 

45 (Coleman 2002).

46 As settlement continued, the area around Davis-Besse was used for agriculture. The early 

47 settlers drained the Great Black Swamp, put in several ditches, drain tiles, and removed trees; 

48 this turned the area into the fertile farm region that it is today.
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1 In 1907, the U.S. National Guard Camp Perry was established, about 5 mi (8 km) to the 

2 southeast of Davis-Besse. The camp is named for Oliver Hazard Perry, a hero of the 

3 War of 1812, and it maintains the largest outdoor firing range in the world. During the First 

4 World War, officers and marksmen were trained there, and, during the Second World War, 

German and Italian prisoners were kept there. Today, the camp is home to the 213th 5 Ordinance 

6 Company, the 200th Civil Engineering Squadron, the 372nd Missile Maintenance Company 

7 Detachment 1, the U.S. Coast Guard Port Security Unit 309, and the Ohio Naval Reserve. 

8 Since 1907, Camp Perry has hosted the “World Series of the Shooting Sports,” a marksmanship 

9 event that boasts more than 4,000 participants (Ohio History Central 2008). The former Erie 

10 Army Depot takes up the rest of the area around Camp Perry, consisting of a privately owned 

11 industrial park and the Locust Point Anti-Aircraft Artillery Firing Area (LPAAAFA).

12 The LPAAAFA was an artillery training area located on the edge of Lake Erie used by the 

371st 13 Anti-Aircraft Artillery Group of the U.S. Army Ohio National Guard. In February of 1953, 

14 approximately 69 ac (28 ha) that would be used as the LPAAAFA was leased by the U.S. Army 

15 from the state of Ohio, and, in August of 1963, the land was transferred to private owners when 

16 the LPAAAFA was closed. A portion of the land occupied by the LPAAAFA extended from the 

17 coast of Lake Erie inland about 0.5 mi (0.8 km) adjacent to what is now the canal associated 

18 with Davis-Besse. The area associated with the LPAAAFA has been assessed for hazards and 

19 has been subsequently cleared; however, there is potential for Davis-Besse personnel to 

20 encounter remnants of Department of Defense (DoD) activities, including unexploded ordnance, 

21 on their property. There were three associated firing points for the LPAAAFA; two points within 

22 Davis-Besse property north of the Toussaint River along the shore of Lake Erie and a third 

23 point, a short guard tower, on the Camp Perry property, also along the Lake Erie shoreline. 

24 Each firing point location consisted of a 50-ft (15.2-m) tall safety tower equipped with a siren 

25 and horn, none of which are still in existence. During the 10-year period of use, guardsmen 

26 would use remote controlled aerial targets as well as towed targets for training, impacting 

27 93,585 ac (37,873 ha) in the lake (ACE 2010).

28 On July 31, 1978, Davis-Besse began commercial operation, servicing customers in the Great 

29 Lakes region. Consisting of one reactor, the site sits on 954 ac (390 ha), much of which is 

30 leased by the FWS for use as the Ottawa National Wildlife Refuge.

31 2.2.10.2 Historic and Archaeological Resources

32 Davis-Besse encompasses 954 ac (390 ha) of land. Disturbed areas include the power block 

33 area, borrow pits, and quarry. Undisturbed areas include approximately 733 ac (297 ha) of 

34 marshland and additional maintained lands within the owner-controlled perimeter on the south 

35 side, a portion of the east side (to the south) and along the western side (south of the 

36 Davis-Besse railroad). An exact acreage of this land was not available. The Ottawa National 

37 Wildlife Refuge encompasses much of the marshland area and is managed by the FWS. Prior 

38 to the construction of the site, the area had been cleared, drained, and farmed since the 

19th 39 century. The land area adjacent to the Davis-Besse property is still used mainly for 

40 agricultural purposes, and directly west of Davis-Besse is the State of Ohio Magee Marsh 

41 Wildlife Area.

42 The parcel of land on which Davis-Besse is situated has not been surveyed for archaeological 

43 resources; however, the Ohio Archaeological Society and the Ohio State Historic Preservation 

44 Office (SHPO) had concluded that no archaeological resources would be affected by the plant’s 

45 construction (AEC 1973). This is likely due to the fact that the area in and around Davis-Besse 

46 is a marshy wetland, and, consequently, the potential for significant cultural resources in this 
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1 area is low. The western portion of Davis-Besse was cleared, drained, and farmed during the 

2 19th century, and during construction of the main power block, the ground surface was graded 

3 up to an elevation of 6 to 12 ft (1.8 to 3.7 m) above the original surface grade. Consequently, 

4 the potential for significant archaeological resources in this area is also low. However, because 

5 no archaeological surveys have been conducted in and around Davis-Besse, the potential for 

6 the presence of unrecorded cultural resources remains. It should be noted that Nappanee soils 

7 are present in the southwestern portion of Davis-Besse property, and based on the model 

8 proposed by Murphy (1988), there is potential for archaeological materials at those locations. 

9 Additionally, the southwest portion of the property is also potentially undisturbed. One known 

10 cultural resource is located on Davis-Besse property. The Refuge Site, 33-OT-25, is situated on 

11 a small peninsula of dry land in the marshy area of the southeast corner of the property. This is 

12 a historic site consisting of nails, glass mason jar fragments, and a kaolin pipe fragment that has 

13 been determined to be ineligible for listing in the National Register of Historic Places (NRHP). It 

14 was also noted in discussions with the applicant that one pre-plant structure may still be in 

15 existence on the Davis-Besse site. It was indicated that a house and barn were originally on the 

16 site; the house had been moved at the time of construction, but the barn was kept in place. The 

17 barn has subsequently been re-sided. It is located in the undisturbed portion of the site within 

18 the owner-controlled area.

19 A recent query in the Ohio Historic Preservation Office’s online mapping system by NRC staff 

20 identified 14 archaeological surveys have been conducted within 6 mi (10 km) of Davis-Besse. 

21 Additionally, within this 6-mi (10-km) radius, 378 properties (archaeological sites, historic 

22 structures, and cemeteries) were identified. Of those properties, 99 archaeological sites were 

23 recorded, of which 71 are prehistoric, 15 are historic, and 13 are multicomponent, having both 

24 prehistoric and historic elements. Four of the properties have been determined eligible for 

25 listing in the NRHP—sites 33-OT-88, 33-OT-91, 33-OT-141, and a historic structure located in 

26 Oak Harbor. In addition, there are 32 properties listed in the NRHP in Ottawa County, OH;

27 however, only one, Carroll Township Hall, is located within 6 mi (10 km) of Davis-Besse 

28 (NPS 2011). Carroll Township Hall is within view of Davis-Besse.

29 2.3 Related Federal and State Activities

30 The NRC staff reviewed the possibility that activities of other Federal agencies might impact the 

31 renewal of the operating license for Davis-Besse. There are no Federal projects that would 

32 make it necessary for another Federal agency to become a cooperating agency in the 

33 preparation of this draft SEIS. There are no known American Indian lands within 50 mi of 

34 Davis-Besse; however, eight tribes were identified to have potential interests in the surrounding 

35 area. The tribes identified and contacted during the scoping period are the Delaware Nation, 

36 Forest County Potawatomi Community, Hannahville Indian Community Council, Miami Tribe of 

37 Oklahoma, Shawnee Tribe, Wyandotte Nation, Peoria Tribe of Indians of Oklahoma, and 

38 Ottawa Tribe of Oklahoma.

39 Federally owned facilities within 50 mi of Davis-Besse are listed below: 

40 • U.S. National Guard Camp Perry—5 mi, 

41 • Ottawa National Wildlife Refuge and Visitors Center—6 mi, and

42 • Cedar Point National Wildlife Refuge—13 mi. 
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1 2.3.1 Coastal Zone Management Act

2 In the U.S., coastal areas are managed through the Coastal Zone Management Act of 1972 

3 (CZMA). The Act, administered by NOAA’s Office of Ocean and Coastal Resource 

4 Management, provides for management of the Nation’s coastal resources, including the 

5 Great Lakes, and balances economic development with environmental conservation. Federal 

6 consistency is the CZMA requirement where Federal agency activities that have reasonably 

7 foreseeable effects on any land or water use or natural resource of the coastal zone must be 

8 consistent to the maximum extent practicable with the enforceable policies of a coastal state’s 

9 Federally approved Coastal Management Program. The Federal consistency regulations 

10 implemented by the NOAA are contained in 15 CFR Part 930. This law authorizes individual 

11 states to develop plans that incorporate the strategies and policies they will employ to manage 

12 development and use of coastal land and water areas. NOAA must approve each plan. One of 

13 the components of an approved plan is “enforceable policies,” by which a state exerts control 

14 over coastal uses and resources (NOAA 2011a, 2011b).

15 NOAA approved the Ohio Coastal Zone Management Program in May 1997. In Ohio, the 

16 approved program is the Ohio Coastal Management Program (OCMP), which was authorized by 

17 the Ohio General Assembly passage of the Ohio Coastal Management Law in 1988. 

18 Davis-Besse, located in Ottawa County, is within the OCMP. Accordingly, FENOC has 

19 contacted the Ohio Department of Natural Resources. The applicants ER illustrated the 

20 activities considered to have a direct and significant impact on the coastal lands. It reflects 

21 30 of the 41 policies in the OCMP that FENOC has deemed enforceable pursuant to Title 15 of 

22 the Ohio Revised Code, “Conservation of Natural Resources” (FENOC 2010c). 

23 2.4 References 

24 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

25 Protection Against Radiation.”

26 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

27 Production and Utilization Facilities.”

28 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

29 protection regulations for domestic licensing and related regulatory functions.”

30 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

31 Renewal of Operating Licenses for Nuclear Power Plants.”

32 10 CFR Part 60. Code of Federal Regulations, Title 10, Energy, Part 60, “Licensing 

33 Requirements for Land Disposal of Radioactive Waste.” 

34 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

35 Requirements for Land Disposal of Radioactive Waste.”

36 10 CFR Part 70. Code of Federal Regulations, Title 10, Energy, Part 70, “Packaging and 

37 Transportation of Radioactive Material.” 

38 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

39 Transportation of Radioactive Material.”
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1 15 CFR Part 930. Code of Federal Regulations, Title 15, Commerce and Foreign Trade, Part 

2 930, “Federal Consistency with Approved Coastal Management Programs.”40 CFR Part 20. 

3 Code of Federal Regulations, Title 10, Protection of the Environment, Part 20, “National Primary 

4 Drinking Water Regulations,” Subpart G, “National Primary Drinking Water Regulations: 

5 Maximum Contaminant Levels and Maximum Residual Disinfectant Levels,” §66 “Maximum 

6 Contaminant Levels for Radionuclides.” 

7 40 CFR Part 40. Code of Federal Regulations, Title 40, Protection of Environment, Part 40, 

8 “Research and Demonstration Grants.” 

9 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

10 “National Primary and Secondary Ambient Air Quality Standards.”

11 40 CFR Part 52. Code of Federal Regulations, Title 40, Protection of Environment, Part 52,

12 “Approval and Promulgation of Implementation Plans.” 

13 40 CFR Part 80. Code of Federal Regulations, Title 40, Protection of Environment, Part 

14 80,“Designation of Areas for Air Quality Planning Purposes.” 

15 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

16 “Designation of Areas for Air Quality Planning Purposes.”

17 40 CFR Part 141.66. Code of Federal Regulations, Title 40, Protection of the Environment, Part 

18 141 “National Primary Drinking Water Regulations,” Subpart G, “National Primary Drinking 

19 Water Regulations: Maximum Contaminant Levels and Maximum Residual Disinfectant Levels,” 

20 §66, “Maximum Contaminant Levels for Radionuclides.”

21 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

22 “Environmental Radiation Protection Standards for Nuclear Power Operations.”

23 40 CFR Part 239, et seq. Code of Federal Regulations, Title 40, Protection of Environment, 

24 Chapter I, Environmental Protection Agency, Subchapter I, “Solid Wastes.”

25 40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260, 

26 “Hazardous Waste Management System: General.”

27 40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 

28 “Identification and Listing of Hazardous Waste.”

29 40 CFR Part 262. Code of Federal Regulations. Title 40, Protection of Environment, Part 262, 

30 “Standards Applicable to Generators of Hazardous Waste.”

31 40 CFR Part 266. Code of Federal Regulations, Title 40, Protection of Environment, Part 266, 

32 “Storage, Treatment, Transportation, and Disposal of Mixed-Waste.”

33 40 CFR Part 273. Code of Federal Regulations, Title 40, Protection of Environment, Part 273, 

34 “Standards for Universal Waste Management.”

35 50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, 

36 “General Provisions.”

37 50 CFR Part 20. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 20, “Eagle 

38 Permits.” 
Affected Environment

2-76

1 50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, “Eagle 

2 Permits.”

3 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

4 “Interagency Cooperation—Endangered Species Act of 1973, As Amended.”

5 32 FR 4001. U.S. Fish and Wildlife Service. Native fish and wildlife; endangered species. 

6 Federal Register 32(48):4001. March 11, 1967. Available at 

7 <http://ecos.fws.gov/docs/federal_register/fr18.pdf> (accessed 10 May 2013).

8 41 FR 41914. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, 

9 determination of critical habitat for American crocodile, California condor, Indiana bat, and 

10 Florida manatee. Federal Register 41(187):41914–41916. September 24, 1976. Available at 

11 <http://ecos.fws.gov/docs/federal_register/fr115.pdf> (accessed 8 May 2013).

12 49 FR 21664. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

13 review of invertebrate wildlife for listing as endangered or threatened species.” 

14 Federal Register: 49(100):21664-21675. May 22, 1984. Available at: 

15 <http://ecos.fws.gov/docs/federal_register/fr836.pdf> (accessed 4 January 2011).

16 63 FR 31268. U.S. Environmental Protection Agency. “Emergency Planning and Community 

17 Right-to-Know Programs; Amendments to Hazardous Chemical Reporting Thresholds, 

18 Streamlining Requirements.” Federal Register, Vol. 63: 31268 et seq. June 8, 1998.

19 66 FR 22938. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 

20 final determination of critical habitat for the Great Lakes breeding population of the piping 

21 plover. Federal Register 66(88):22938-22969. May 7, 2001.

22 73 FR 66964. U.S. Environmental Protection Agency. “National Ambient Air Quality Standards 

23 for Lead; Final Rule.” Federal Register, Vol. 73: 66964 et seq. November 12, 2008.

24 74 FR 56264. U.S. Environmental Protection Agency. “Mandatory Reporting of Greenhouse 

25 Gases; Final Rule.” Federal Register, Vol. 74: 56264 et seq. October 30, 2009.

26 75 FR 6474. U.S. Environmental Protection Agency. “Primary National Ambient Air Quality 

27 Standards for Nitrogen Dioxide; Final Rule.” Federal Register, Vol. 75: 6474 et seq. 

28 February 9, 2010.

29 75 FR 9282, U.S. Fish and Wildlife Service, “General Provisions; Revised List of Migratory 

30 Birds: Final Rule.” Federal Register, Vol. 75: 9282 et seq. March 1, 2010

31 75 FR 35520. U.S. Environmental Protection Agency. “Primary National Ambient Air Quality 

32 Standard for Sulfur Dioxide; Final Rule.” Federal Register, Vol. 75: 35520 et seq. 

33 June 22, 2010.

34 75 FR 67551. U.S. Fish and Wildlife Service. “Endangered and Threatened Wildlife and Plants; 

35 Listing the Rayed Bean and Snuffbox as Endangered; Proposed Rule,” Federal Register, 

36 Volume 75(211): 67551–67583. November 2, 2010. 

37 3745-50 OAC. Ohio Administrative Code. Chapter 3745-50, “Hazardous Waste Management 

38 System-General.” 

39 3745-52 OAC. Ohio Administrative Code. Chapter 3745-52, “Generator Standards.” 
Affected Environment

2-77

1 15 ORC Chapter 1518.02. Ohio Revised Code, Title 15, Conservation of Natural Resources, 

2 Chapter 1518.02, “Injuring or Removing Endangered or Threatened Plant.” 

3 15 ORC Chapter 1531.25. Ohio Revised Code, Title 15, Conservation of Natural Resources 

4 Chapter 1532.25, “Protection of Species Threatened with Statewide Extinction.” 

5 [ACE] U.S. Army Corps of Engineers. 2010. Draft Final Preliminary Assessment Report: 

6 Locust Point Anti-Aircraft Artillery Firing Area FUDS Property No. G05OH0996, Formerly Used 

7 Defense Sites Military Munitions Response Program. Prepared by Shaw Environmental & 

8 Infrastructure, Inc. for the U.S. Army Corps of Engineers, Buffalo District. 

9 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the 

10 Construction of Davis-Besse Nuclear Power Station, Docket No, 50-346. Washington, D.C., 

11 March 1973, ADAMS Accession No. ML 110140258. 

12 [ANSI] American National Standards Institute. 2011. A300 Standards for Tree Care 

13 Operations. New York, NY: Tree Care Industry Association. 9th Part. 

14 [Audubon] National Audubon Society. 2011. Important Bird Areas: Lake Erie Western Basin,, 

15 Available URL: <http://iba.audubon.org/iba/viewSiteProfile.do?siteId=2044&navSite=state> 

16 (accessed 19 March 2011).

17 Bald and Golden Eagles Protection Act of 1940, as amended, 16 U.S.C. §668–668c. 

18 Bolsenga, S.J. and C.E. Herdendorf, Lake Erie and Lake St. Clair Handbook, Wayne State 

19 University Press, Detroit, MI, 1993.

20 Bridgeman T.B., et al., “Recruitment of Hexagenia Mayfly Nymphs in Western Lake Erie Linked 

21 to Environmental Variability,” Ecological Applications, 16(2): 601–611, 2006.

22 [BSBO] Black Swamp Bird Observatory, 2003. Migrational Movements and Habitat Usage of 

23 Migrant Passerines in the Great Lakes Region: Ottawa National Wildlife Refuge, Ohio—2003, 

24 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2003_PasserineMigration_PR.pdf> 

25 (accessed 21 April 2011).

26 [BSBO] Black Swamp Bird Observatory, 2004. Migrational Movements and Habitat Usage of 

27 Migrant Passerines in the Great Lakes Region: Ottawa National Wildlife Refuge, Ohio—2004, 

28 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2004_PasserineMigration_PR.pdf> 

29 (accessed 21 April 2011).

30 [BSBO] Black Swamp Bird Observatory, 2005. Migrational Survey and Habitat Usage of 

31 Shorebirds in the Lake Erie Marsh Region—2005, Available URL: 

32 <http://www.bsbo.org/research/pdf/BSBO_2005_Shorebird_PR.pdf> (accessed 7 June 2011).

33 [BSBO] Black Swamp Bird Observatory, 2006a. Navarre Marsh Bird Sightings—Spring 2006, 

34 Available URL: <http://www.bsbo.org/passerine/pdf/2006_spring_bird_sightings.pdf> (accessed 

35 7 June 2011).

36 [BSBO] Black Swamp Bird Observatory, 2006b. Standardized Surveys of Butterflies on Ottawa 

37 National Wildlife Refuge and the Surrounding Western Basin of Lake Erie, Ohio—2006,

38 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2006_Butterfly_PR.pdf >(accessed

39 7 June 2011).
Affected Environment

2-78

1 [BSBO] Black Swamp Bird Observatory, 2007a. Migrational Survey and Habitat Usage of 

2 Shorebirds in the Lake Erie Marsh Region—2007, Available URL: 

3 <http://www.bsbo.org/research/pdf/BSBO_2007_Shorebird_PR.pdf> (accessed 7 June 2011).

4 [BSBO] Black Swamp Bird Observatory, 2007b. Navarre Marsh Bird Sightings—Spring 2007, 

5 Available URL: <http://www.bsbo.org/passerine/pdf/2007_spring_sightings.pdf> (accessed 

6 7 June 2011).

7 [BSBO] Black Swamp Bird Observatory, 2007c. Spring Raptor Migration Surveys—2007 in the 

8 Lake Erie Region Marsh, Updated April 4, 2011, Available URL: 

9 <http://www.bsbo.org/raptor/2007_raptor_migration_survey.htm> (accessed 7 June 2011).

10 [BSBO] Black Swamp Bird Observatory, 2007d. Standardized Surveys of Butterflies on Ottawa 

11 National Wildlife Refuge and the Surrounding Western Basin of Lake Erie, Ohio—2007, 

12 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2007_Butterfly_PR.pdf> (accessed 

13 7 June 2011).

14 [BSBO] Black Swamp Bird Observatory, 2008a. Migrational Survey and Habitat Usage of 

15 Shorebirds in the Lake Erie Marsh Region—2008, Available URL: 

16 <http://www.bsbo.org/research/pdf/BSBO_2008_Shorebird_PR.pdf >(accessed 7 June 2011).

17 [BSBO] Black Swamp Bird Observatory, 2008b. Migrational Movements and Habitat Usage of 

18 Migrant Passerines in the Great Lakes Region: Ottawa National Wildlife Refuge, Ohio—2008,” 

19 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2009_PasserineMigration_PR.pdf> 

20 (accessed 7 June 2011).

21 [BSBO] Black Swamp Bird Observatory, 2008c. Standardized Surveys of Butterflies on Ottawa 

22 National Wildlife Refuge and the Surrounding Western Basin of Lake Erie, Ohio—2008, 

23 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2008_Butterfly_PR.pdf> (accessed 

24 7 June 2011).

25 [BSBO] Black Swamp Bird Observatory, 2008d. Navarre Marsh Bird Sightings—Spring 2008, 

26 Data for April 13–April 30. Available URL: 

27 <http://www.bsbo.org/passerine/pdf/05012008-0607-2008_spring_bird_survey.pdf> (accessed 

28 7 June 2011).

29 [BSBO] Black Swamp Bird Observatory, 2008e. Navarre Marsh Bird Sightings—Spring 2008, 

30 Data for May 1–June 7. Available URL: 

31 <http://www.bsbo.org/passerine/pdf/05012008-0607-2008_spring_bird_survey.pdf> (accessed 

32 7 June 2011).

33 [BSBO] Black Swamp Bird Observatory, 2008f. 17th Spring Raptor Migration Surveys—2008 in 

34 the Lake Erie Region Marsh, Updated April 4, 2011, Available URL: 

35 <http://www.bsbo.org/raptor/2008_raptor_migration_survey.htm> (accessed 7 June 2011).

36 [BSBO] Black Swamp Bird Observatory,2009a. Migrational Movements and Habitat Usage of 

37 Migrant Passerines in the Great Lakes Region: Ottawa National Wildlife Refuge, Ohio—2009, 

38 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2009_PasserineMigration_PR.pdf> 

39 (accessed 15 April 2011).
Affected Environment

2-79

1 [BSBO] Black Swamp Bird Observatory, 2009b. Migrational Survey and Habitat Usage of 

2 Shorebirds in the Lake Erie Marsh Region—2009, Available URL: 

3 <http://www.bsbo.org/research/pdf/BSBO_2009_Shorebird_PR.pdf> (accessed 15 April 2011).

4 [BSBO] Black Swamp Bird Observatory, 2009c. Spring Raptor Migration in Ottawa National 

5 Wildlife Refuge and Surrounding Lake Erie Marshes, Ohio—2009, Available URL: 

6 <http://www.bsbo.org/research/pdf/BSBO_2009_Raptor_PR.pdf> (accessed 15 April 2011).

7 [BSBO] Black Swamp Bird Observatory, 2009d. Standardized Surveys of Butterflies on Ottawa 

8 National Wildlife Refuge and the Surrounding Western Basin of Lake Erie, Ohio—2009, 

9 Available URL: <http://www.bsbo.org/research/pdf/BSBO_2009_Butterfly_PR.pdf> (accessed 

10 7 June 2011).

11 [BSBO] Black Swamp Bird Observatory, 2009e. Navarre Marsh Bird Sightings—Spring 2009, 

12 Available URL: <http://www.bsbo.org/passerine/pdf/Navarre_Spring_Survey_2009.pdf> 

13 (accessed 7 June 2011).

14 [BSBO] Black Swamp Bird Observatory, 2009f. 18th Spring Raptor Migration Surveys—2009 in 

15 the Lake Erie Region Marsh, Updated April 4, 2011, Available URL: 

16 <http://www.bsbo.org/raptor/current_year_raptor_migration_survey.htm> (accessed 31 

17 May 2011).

18 [BSBO] Black Swamp Bird Observatory, 2010. Navarre Marsh Bird Sightings—Spring 2010, 

19 Data for April 1–May 31. Available URL: 

20 <http://www.bsbo.org/passerine/pdf/navarre_spring_survey_2010.pdf> (accessed 7 June 2011).

21 [BSBO] Black Swamp Bird Observatory, 2011a. Navarre Marsh Bird Sightings—Spring 2011, 

22 Data for April 12–May 31. Available URL: 

23 http://www.bsbo.org/passerine/pdf/navarre_spring_survey_2011.pdf (accessed 7 June 2011).

24 [BSBO] Black Swamp Bird Observatory, 2011b. Loggerhead Shrike: Fist Every Captured at the 

25 Navarre Banding Station, May 5, 2007, Available URL: 

26 <http://www.bsbo.org/passerine/losh_05052007_navarre.htm> (accessed 21 April 2011).

27 [CAPS] University of Missouri Circular Area Profiling System, 2012. Census population in a 20- 

28 and 50-mile radius around the Davis-Besse Station (41.596944 Lat., -83.087778 Long.). 

29 Available URL: http://mcdc.missouri.edu/websas/caps10c.html (accessed 17 September 2012).

30 Centerior Energy. 1994. Letter from Stortz, L.F., Vice President, to Hic, T.O., Division of 

31 Emergency and Remedial Response, OEPA, Subject: Submittal of Information Regarding Spill 

32 of Gasoline, Identification Number 01-62-0180. February 22, 1994.

33 Clean Air Act of 1963, as amended. 42 U.S.C. §7401 et seq.

34 Coastal Zone Management Act of 1972. 16 U.S.C. §1451–1464.

35 Coleman, K.B. 2002. “The Maumee & Western Reserve Road or ‘Mud Pike’: U.S. Route 20 

36 Between Perrysburg and Fremont, Northwest Ohio.” Available URL: 

37 <http://www.horizonview.net/~ihs/Transportation/Transp-Story-M&WRrd.html> (accessed 

38 22 April 2011) 
Affected Environment

2-80

1 Conroy J.D. and Culver D.A., 2005. Do Dreissenid Mussels Affect Lake Erie Ecosystem 

2 Stability Processes? American Midland Naturalist, 153(1): 20–32, 2005. 

3 Crail TD, Krebs RA, Zanatta DT. 2011. Unionid Mussels from Nearshore Zones of Lake Erie. 

4 Journal of Great Lakes Research 37(2011): 199–202, 2011, Available URL: 

5 <http://www.cst.cmich.edu/users/zanat1d/Crail%20JGLR%202011.pdf> (accessed 

6 31 May 2011).

7 Davis-Besse Nuclear Power Station (Davis-Besse), Undated. In 2004–05 Spent Fuel Pool 

8 Leakage to Onsite Groundwater. Condition Report #04-01719, Discovery date 5 May 2004. 

9 Davis-Besse, 2004a. National Pollutant Discharge Elimination System (NPDES) Program, 

10 Administrative Procedure DB-CN-00030. Prepared by S. Chimo, June 21, 2004. 

11 Davis-Besse, 2004b. Periodic Test Procedure DB-CN-04032, Wastewater Treatment Sludge 

12 Holding Tank Analysis. Revision 01, Prepared by R. Edwards, October 28, 2004. 

13 Davis-Besse, 2009. Business Practice DBBP-CHEM-2009: Storm Water Pollution Prevention 

14 Plan. Revision 00. 

15 Emergency Planning and Community Right-to-Know Act of 1986. 42 U.S.C. §116 et seq.

16 Emery, L. 1985. Review of Fish Species Introduced into the Great Lakes, 1819–1974. 

17 Great Lakes Fishery Commission, Technical Report No. 45, April 1985, Available URL: 

18 <http://www.glfc.org/pubs/TechReports/Tr45.pdf> (accessed 14 January 2011).

19 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq.

20 [EPA] U.S. Environmental Protection Agency, 1974. “Information on Levels of Environmental 

21 Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety,” 

22 Report 550/9-74-004, Washington, D.C., March 1974, Available URL: 

23 <http://www.nonoise.org/library/levels74/levels74.htm> (See also “EPA Identifies Noise Levels 

24 Affecting Health and Welfare,” September 21, 2007, Available URL: 

25 <http://www.epa.gov/history/topics/noise/01.htm> (accessed April 2011)).

26 [EPA] U.S. Environmental Protection Agency. 1987. “Project Summary: Characterization of 

27 PCB Transformer/Capacitor Fluids and Correlation with PCDDs and PCDFs in Soot. 

28 EPA/600/S2-87/004. Hazardous Waste Engineering Research Laboratory,” Cincinnati, Ohio. 

29 April. 

30 [EPA] U.S. Environmental Protection Agency. 2004. “2004 Lake Erie Lakewide Management 

31 Plan,” Available URL: <http://www.epa.gov/lakeerie/2004update/index.html> (accessed 

32 12 January 2011).

33 [EPA] U.S. Environmental Protection Agency. 2008. “2008 Lake Erie Lakewide Management 

34 Plan,” Available URL: <http://www.epa.gov/glnpo/lamp/le_2008/le_2008.pdf> (accessed 

35 12 January 2011).

36 [EPA] U.S. Environmental Protection Agency. 2009. “Ecoregions of Indiana and Ohio.” 

37 Available URL: <http://www.epa.gov/wed/pages/ecoregions/ohin_eco.htm#Ecoregionsdenote> 

38 (accessed 15 April 2011).
Affected Environment

2-81

1 [EPA] U.S. Environmental Protection Agency. 2010a. “Office of Solid Waste.” Available URL: 

2 <http://www.epa.gov/osw> (accessed December 2010).

3 [EPA] U.S. Environmental Protection Agency. 2010b. “Waste Environmental Management 

4 Systems.” Available URL: <http://www.epa.gov/osw/inforesources/ems/index.htm> (accessed 

5 December 2010).

6 [EPA] U.S. Environmental Protection Agency. 2010c. “Office of Solid Waste,” Available URL: 

7 http://www.epa.gov/osw (accessed December 2010).

8 [EPA] U.S. Environmental Protection Agency. 2010d. “Waste Environmental Management 

9 Systems,” Available URL: http://www.epa.gov/osw/inforesources/ems/index.htm (accessed 

10 December 2010).

11 [EPA] U.S. Environmental Protection Agency. 2010e. “Safe Drinking Water Information System 

12 (SDWIS),” County Search—Lucas, Sandusky, Ottawa, and Wood Counties, OH. Available 

13 URL: <http://iaspub.epa.gov/enviro/sdw_form_v2.create_page?state_abbr=OH> (accessed 

14 April 2011).

15 [EPA] U.S. Environmental Protection Agency. 2011a. “Enforcement & Compliance History 

16 Online (ECHO), Water Program Search Results.” Available URL: 

17 <http://www.epa-echo.gov/echo/compliance_report_water_icp.html> (accessed 4 March 2011).

18 [EPA] U.S. Environmental Protection Agency. 2011b. “Enforcement & Compliance History 

19 Online (ECHO), Detailed Facility Report.” Available URL: 

20 <http://www.epa-echo.gov/cgi-bin/get1cReport.cgi?tool=echo&IDNumber=OH0003786> 

21 (accessed 4 March 2011).

22 [EPA] U.S. Environmental Protection Agency. 2011c. “Envirofacts Warehouse Water 

23 Discharge Permit Detailed Reports.” Available URL: 

24 <http://oaspub.epa.gov/enviro/pcs_det_reports.detail_report?npdesid=OH0003786> (accessed 

25 4 March 2011).

26 [EPA] U.S. Environmental Protection Agency. 2011d. “Clean Energy, eGRID,” eGRID2010 

27 Version 1.0.Available URL: 

28 <http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html> (accessed 16 May 2011).

29 [EPA] U.S. Environmental Protection Agency. 2011e. “Energy CO2 Emissions by State, 

30 1990–2008.” Available URL: 

31 <http://www.epa.gov/statelocalclimate/documents/pdf/CO2FFC_2008.pdf> (accessed 

32 15 May 2011). 

33 [EPA] U.S. Environmental Protection Agency. 2011f. “Inventory of U.S. Greenhouse Gas 

34 Emissions and Sinks: 1990–2009,” EPA 430-R-11-005. April 15. Available URL: 

35 <http://www.epa.gov/climatechange/emissions/usinventoryreport.html> (accessed 

36 15 May 2011).

37 [EPA] U.S. Environmental Protection Agency. 2011h. AirData: Access to Air Pollution Data. 

38 Available URL: <http://www.epa.gov/oar/data/> (accessed 14 May 2011) 
Affected Environment

2-82

1 [EPA] U.S. Environmental Protection Agency. 2013b. National Ambient Air Quality Standards 

2 (NAAQS). Updated on December 14, 2012. Available URL: http://epa.gov/air/criteria.html 

3 (accessed 29 March 2013) 

4 [EPA] U.S. Environmental Protection Agency. 2013a. The Green Book Non-attainment Areas 

5 for Criteria Pollutants. Updated on December 14, 2012. Available URL: 

6 <http://www.epa.gov/oaqps001/greenbk/> (accessed 4 March 2013). 

7 [ERM] Environmental Resources Management, 2007. Groundwater Flow Characteristics 

8 Report, Davis-Besse Nuclear Power Station, Prepared for FENOC, Oak Harbor, OH, 

9 January 16.

10 [ERM] Environmental Resources Management, 2008. Groundwater Monitoring Well Installation 

11 & Monitoring Report, Davis-Besse Nuclear Power Station. Prepared for FENOC, Oak Harbor, 

12 OH, March 18.

13 [ESA] Endangered Species Act of 1973, as amended. 16 U.S.C. §1531, et seq.

14 [FENOC] FirstEnergy Nuclear Operating Company, 1998. Letter from Lash, J.H., Plant 

15 Manager, Davis-Besse, to C. Zipp, State Fire Marshall Office. Subject: Underground Storage 

16 Tank Overfill Release Report, Incident Number 6281145-00, September 18.

17 [FENOC] FirstEnergy Nuclear Operating Company. 2005. System Description for 

18 Meteorological Monitoring System for the Toledo Edison Company, Davis-Besse Nuclear Power 

19 Station, Unit 1, Oak Harbor, Ohio. SD-032C, Rev. 2.

20 [FENOC] FirstEnergy Nuclear Operating Company. 2007. Letter from Kaminskas, V.A., 

21 FENOC, Director of Site Operations, to A. Gall, Division of Surface Water, OEPA Subject: 

22 Submittal of 2006 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station,

23 January 29.

24 [FENOC] FirstEnergy Nuclear Operating Company. 2008. Letter from Kaminskas, V.A., 

25 FENOC, Director of Site Operations, to R. Zuzik, Division of Surface Water, OEPA, Subject: 

26 Submittal of the 2007 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power 

27 Station, January 18.

28 [FENOC] FirstEnergy Nuclear Operating Company. 2009. Letter from Allen, B., FENOC, Vice 

29 President-Nuclear, to A. Gall, Sewage Sludge Coordinator, OEPA. Subject: Submittal of the 

30 2008 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station, January 23.

31 [FENOC] FirstEnergy Nuclear Operating Company, 2010a. Letter from Boissoneault, PM, 

32 FENOC, Manager, Site Chemistry, to A. Gall, Sewage Sludge Coordinator, OEPA. Subject: 

33 Submittal of the 2009 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power 

34 Station, January 21.

35 [FENOC], FirstEnergy Nuclear Operating Company. 2010b. Updated Safety Analysis Report 

36 (USAR), Davis-Besse Nuclear Power Station No. 1, Docket No. 50-346, License No: NPF-3, 

37 Revision 27, June 2010 (2010b).

38 [FENOC] FirstEnergy Nuclear Operating Company. 2010c. “Davis-Besse Nuclear Power 

39 Station License Renewal Application,” Toledo, OH, August 2010, Agencywide Document 

40 Access and Management System (ADAMS) Accession No. ML102450572. 
Affected Environment

2-83

1 [FENOC] FirstEnergy Nuclear Operating Company, 2010d. Letter from Brown, S.F., FENOC, 

2 Senior Engineer, to R. Zuzik, Division of Surface Water, OEPA. Subject: National Pollutant 

3 Discharge Elimination System Permit Renewal Application, Davis-Besse Nuclear Power Station, 

4 EPA ID No. OH0003786, Permit No. 2IB00011*ID, October 21.

5 [FENOC] FirstEnergy Nuclear Operating Company. 2011a. Letter from Boissoneault, PM, 

6 FENOC, Manager, Site Chemistry, to A. Gall, Sewage Sludge Coordinator, OEPA. Subject: 

7 “Submittal of the 2010 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power 

8 Station,” January 25.

9 [FENOC] FirstEnergy Nuclear Operating Company. 2011b. “Combined Annual Radiological 

10 Environmental Operating Report and Radiological Efflulent Release Report for the Davis-Besse 

11 Nuclear Power Station–2011,” May 15, ADAMS Accession No. ML12174A090.

12 [FENOC] FirstEnergy Nuclear Operating Company. 2012. Davis-Besse, Unit 1. 2011 Annual 

13 Radiological Environmental Operating Report Including the Radiological Effluent Release 

14 Report. Oak Harbor, Ohio. ADAMS Accession No. ML12174A090. 

15 [FENOC] FirstEnergy Nuclear Operating Company. 2011c. Letter from Barry S. Allen, to 

16 Document Control Desk, NRC. Subject: Davis-Besse Nuclear Power Station, Unit No.1, 

17 Docket No. 50-346, License Number NPF-3, Reply to Requests for Additional Information for 

18 the Review of the Davis-Besse Nuclear Power Station. Unit No.1. License Renewal Application

19 (TAC No. ME4613) Environmental Report. May 27.

20 [FENCO] FirstEnergy Nuclear Operating Company. 2013. E-mail from S. Dort to E. Keegan. 

21 Subject: Answer to staff question about synthetic minor permit from Ohio Environmental 

22 Protection Agency. February 27, 2013. ADAMS Accession No. ML13280A272.

23 [FWS] U.S. Fish and Wildlife Service. 1984. “Endangered and Threatened Wildlife and Plants; 

24 Review of Invertebrate Wildlife for Listing as Endangered or Threatened Species,” 

25 Federal Register, Volume 49, No. 100, pp. 21664–21675, May 22. Available URL: 

26 <http://ecos.fws.gov/docs/federal_register/fr836.pdf> (accessed 4 January 2011).

27 [FWS] U.S. Fish and Wildlife Service. 2001. “Ottawa National Wildlife Refuge Complex 

28 Comprehensive Conservation Plan.” Available URL: 

29 <http://www.fws.gov/midwest/planning/ottawa/index.html> (accessed 20 April 2011).

30 [FWS] U.S. Fish and Wildlife Service. 2002. “Status Assessment Report for the Rayed Bean, 

31 Villosa fabalis, Occurring in the Mississippi River and Great Lake Systems (U.S. Fish and 

32 Wildlife Service Regions 3, 4, and 5, and Canada),” Prepared by the Ohio River Valley 

33 Ecosystem Team Mollusk Subgroup, September. Available URL: 

34 <http://www.fws.gov/midwest/endangered/clams/pdf/rayed-bean-sa.pdf> (accessed 

35 4 Janaury 2011).

36 [FWS] U.S. Fish and Wildlife Service. 2003. “Lake Erie Watersnake Recovery Plan,” FWS

37 Great Lakes-Big Rivers Region, September. Available URL: 

38 <http://www.fws.gov/midwest/endangered/reptiles/pdf/lews-fnl-rpla-sm.pdf> (accessed 

39 20 March 2011).

40 [FWS] U.S. Fish and Wildlife Service. 2003. “Recovery Plan for the Great Lakes Piping Plover 

41 (Charadrius melodus).” FWS Region 3. September 2003. 151 p. Available at 

42 <http://ecos.fws.gov/docs/recovery_plan/030916a.pdf> (accessed 8 May 2013).
Affected Environment

2-84

1 [FWS] U.S. Fish and Wildlife Servies, 2009a. Letter from Knapp, M., FWS, Field Supervisor, to 

2 B. Allen, FENOC. Subject: Comments on the Proposed Davis-Besse License Renewal. 

3 December 16. ADAMS Accession No. ML102450568.

4 [FWS] U.S. Fish and Wildlife Service. 2009b. Piping Plover (Charadrius melodus) 5-Year 

5 Review: Summary and Evaluation. Hadley, MA and Lansing, MI: FWS. September 2009. 214 

6 p. Available URL: 

7 http://www.fws.gov/midwest/endangered/recovery/5yr_rev/pdf/PipingPlover5yr2009.pdf 

8 (accessed 8 May 2013).

9 [FWS] U.S. Fish and Wildlife Service. 2010a. “Rayed Bean (freshwater mussel) Villosa 

10 fabalis),” October. Available URL: 

11 <http://www.fws.gov/cookeville/pdfs/Rayed%20Bean%20Fact%20Sheet.pdf> (accessed 

12 4 January 2011).

13 [FWS] U.S. Fish and Wildlife Services. 2010b. E-mail from Seymour, M., FWS, Wildlife 

14 Biologist, to R. Bulavinetz, NRC, Subject: Federally Listed Species along Davis-Besse 

15 Transmission Line Corridors. September 24. ADAMS Accession No. ML110730328.

16 [FWS] U.S. Fish and Wildlife Servies, 2010c. Letter from Knapp, M., FWS, Field Supervisor, to 

17 C. Bladey, NRC. Subject: Scoping Comments on the Davis-Besse License Renewal 

18 Application Review. December 16. ADAMS Accession No. ML110060289.

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11 Agriculture, National Cooperative Soil Survey. Available URL: 

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34 Program Administrator, to B.S. Allen, FENOC. Subject: Reply to Request for Information on 

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36 Accession No. ML102450568.

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4 2010. ADAMS Accession No. ML102450568.

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10 Species List for Ottawa County as of 10/1/2010.” Available URL: 

11 <http://www.dnr.state.oh.us/LinkClick.aspx?fileticket=OgZRPyIpIg8%3d&tabid=20404> 

12 (accessed 20 March 2011).

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14 Species List for Sandusky County as of 10/1/2010.” Available URL: 

15 http://www.dnr.state.oh.us/LinkClick.aspx?fileticket=1E76Np%2b8VT4%3d&tabid=20404

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20 (accessed 20 March 2011).

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24 [ODNR] Ohio Department of Natural Resources. 2011b. “Eastern Massasauga.” Available 

25 URL: <http://www.dnr.state.oh.us/

26 Home/species_a_to_z/SpeciesGuideIndex/easternmassasauga/tabid/6610/Default.aspx> 

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31 March 2011).

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36 Available URL: 

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40 var. glabra).” Available URL: <http://www.fws.gov/Midwest/Endangered/plants/lakeside.html> 

41 (accessed 20 March 2011).
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2 Agency. 1999. “Ohio Wetland Restoration and Mitigation Strategy Blueprint.” 

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6 Processing Unit, Division of Surface Water, to FENOC. Subject: Ohio EPA Permit 

7 No. 2IB00011*ID, Facility Name Davis-Besse Nuclear Power Station. August 14. 

8 [OEPA] Ohio Environmental Protection Agency. 2006b. Letter from Smith, P.L., OEPA, Permit 

9 Processing Unit, Division of Surface Water, to FENOC. Subject: Ohio EPA Permit 

10 No. 2IB00011*ID, Facility Name Davis-Besse Nuclear Power Station. September 8. 

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12 Division of Water, to FENOC—Davis-Besse. Subject: Preliminary Compliance Review of 

13 Discharge Monitoring Report. September 21.

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15 Division of Water, to FENOC—Davis-Besse. Subject: Preliminary Compliance Review of 

16 Discharge Monitoring Report. November 20.

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20 Plants.” Available URL: 

21 <http://www.epa.state.oh.us/derr/ersis/er/docs/RAD/Oversite%20of%20the%20Nuclear%20Plan

22 ts.pdf> (accessed 9 March 2011) 

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32 Available URL: 

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34 June 2011).

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38 <http://www.ohiowilderness.org/WestSisterIslandWilderness.aspx> (accessed 19 March 2011).
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4 Updated January 3. Available URL: <http://www.puco.ohio.gov/emplibrary/files/media/

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6 (accessed 15 May 2011).

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9 Drainag Basin; A 1972 Symposium Revised. David S. Brose ed. Cleveland Museum of Natural 

10 History, 1976.

11 Prufer, O.H. and O.C. Shane. 1973. “The Portage-Sandusky-Vermilion River Region in Ohio.” 

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17 Research, CLEAR Technical Report No. 211. ADAMS Accession No. ML11227A197

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19 1980, Columbus, OH. Ohio State University Center for Lake Erie Area Research, CLEAR 

20 Technical Report No. 212. ADAMS Accession No. ML11227A197

21 Reutter, JM, Herdendorf CE, Barnes MD, Carey WE. 1980. Environmental Evaluation of a 

22 Nuclear Power Plant on Lake Erie, Columbus, OH. Ohio State University Center for Lake Erie 

23 Area Research, CLEAR Technical Report No. 181. ADAMS Accession No. ML11227A196

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25 http://development.ohio.gov/research/files/s0/Sandusky.pdf. Accessed September 2012.

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30 Tankersly, K.B. 1997. Sheriden: A Clovis Cave Site in Eastern North America. 

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2 3-Year Estimate, American Community Survey, State and County QuickFacts on Lucas, 

3 Ottawa, Sandusky, and Wood Counties, Ohio, and Housing Characteristics for 2010 and 2009–

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15 http://development.ohio.gov/research/files/s0/Wood.pdf. Accessed September 2012.
3-1 

1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

2 Facility owners or operators may need to undertake or, for economic or safety reasons, may 

3 choose to perform refurbishment activities in anticipation of license renewal or during the license 

4 renewal term. The major refurbishment class of activities characterized in the generic 

5 environmental impact statement (GEIS) (NRC 1996; 1999) is intended to encompass actions 

6 that typically take place only once in the life of a nuclear plant, if at all. Examples of these 

7 activities include, but are not limited to, replacement of recirculation piping in boiling-water

8 reactors or replacement of steam generators in pressurized-water reactors. These actions may 

9 have an impact on the environment beyond those that occur during normal operations and may 

10 require evaluation, depending on the type of action and the plant-specific design. As described 

11 in Chapter 1, the NRC published a final rule (78 FR 37282) revising its environmental protection 

12 regulations in 10 CFR Part 51 and issued a revised GEIS. However, the environmental impacts 

13 of refurbishment activities for Davis-Besse were reviewed in accordance with the 1996 rule and 

14 GEIS (NRC 1996, 1999). Table 3.1-1 lists the environmental issues associated with 

15 refurbishment that the U.S. Nuclear Regulatory Commission (NRC) staff (the staff) determined 

16 to be Category 1 issues in the GEIS. 

17 Table 3.1-1. Category 1 Issues Related to Refurbishment 

Issue GEIS Section(s)

Surface water quality, hydrology, and use (for all plants)

Impacts of refurbishment on surface water quality 3.4.1

Impacts of refurbishment on surface water use 3.4.1

Aquatic ecology (for all plants)

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

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51.

18 Table 3.1-2 lists environmental issues related to refurbishment that the NRC staff determined to 

19 be plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The 

20 definitions of Category 1 and 2 issues can be found in Section 1.4.
Environmental Impacts of Refurbishment

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1 Table 3.1-2. Category 2 Issues Related to Refurbishment

Issue GEIS Section(s) 10 CFR 51.53 (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 quality

Air quality during refurbishment

(non-attainment and maintenance areas) 3.3 F

Socioeconomics

Housing impacts 3.7.2 I

Public services: public utilities 3.7.4.5 I

Public services: education (refurbishment) 3.7.4.1 I

Public services: transportation 3.7.4.2 J

Offsite land use (refurbishment) 3.7.5 I

Historic and archaeological resources 3.7.7 K

Environmental justice

Environmental justice(a) Not addressed Not addressed

(a) Guidance related to environmental justice was not in place at the time the NRC prepared the GEIS and the associated revision to 

10 CFR Part 51. If an applicant plans to undertake refurbishment activities for license renewal, the applicant’s Environmental

Report (ER) and the staff’s environmental impact statement must address environmental justice.

Source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51.

2 Table B.2 of the GEIS identifies systems, structures, and components (SSCs) that are subject to 

3 aging and might require refurbishment to support continued operation during the license 

4 renewal period of a nuclear facility. In preparation for its license renewal application, 

5 FirstEnergy Nuclear Operating Company (FENOC) performed an evaluation of these SSCs 

6 pursuant to 10 CFR 54.21 in order to identify the need to undertake any major refurbishment 

7 activities that would be necessary to support the continued operation of Davis-Besse during the 

8 proposed 20-year period of extended operation. FENOC addressed refurbishment activities in 

9 Section 3.2 of its Environmental Report (ER), “Refurbishment Activities,” which is included as 

10 Appendix E of the license renewal application (FENOC 2010).

11 The NRC requirements for the assessment of refurbishing in a license renewal of operating 

12 nuclear power plants includes the preparation of an integrated plant assessment (IPA) under 

13 10 CFR 54.21. The IPA must identify and list SSCs subject to an aging management review

14 (AMR). Items that are subject to aging and might require refurbishment include, for example, 

15 the reactor vessel (RV), piping, supports, and pump casings, as well as those that are not 

16 subject to periodic replacement.
Environmental Impacts of Refurbishment

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1 3.1 Refurbishment Activities at Davis-Besse

2 The NRC regulations for implementing the National Environmental Policy Act (NEPA) require 

3 ERs to describe in detail and assess the environmental impacts of refurbishment activities, such 

4 as planned modifications to SSCs or plant effluents, as stated in 10 CFR 51.53. FENOC 

5 replaced the RV head in October 2011, and the two original steam generators will be replaced 

6 in 2014. In order to facilitate the most cost-effective method for long-term storage, a new 

7 permanent storage facility was constructed in 2011. This storage facility will provide dedicated 

8 onsite storage for the vessel head, steam generator, and other large, irradiated plant equipment. 

9 A new warehouse to store the new steam generators was started in late 2012 and completed in 

10 early 2013. To house the personnel that will support the vessel head replacement and steam 

11 generator, a permanent multi-story office building will be constructed adjacent to the auxiliary 

12 building. 

13 The activities associated with the vessel head replacement and the construction of the storage 

14 facility and multi-story office building are being performed under the current facility-operating 

15 license. Thus, the environmental impacts were previously determined under the final 

16 environmental statement (FES) for the Davis-Besse operating license. 

17 FENOC considers the activities associated with the replacement of the steam generators and 

18 the associated hot leg piping as license renewal refurbishment activities. These construction 

19 activities will be performed during an extended refueling outage (RFO), scheduled for the spring 

20 of 2014. The duration of the activity is expected to be 70 days.

21 3.2 Environmental Impacts of Refurbishment

22 The following sections discuss the Category 2 issues associated with refurbishment activities at 

23 Davis-Besse. Any environmental impacts from refurbishment will be in addition to those 

24 associated with continued operation of Davis-Besse for the period of license renewal. 

25 Chapter 4 of this report discusses those issues.

26 3.2.1 Terrestrial Resources—Refurbishment Impacts

27 FENOC’s planned refurbishment activities (discussed in Section 3.1) will require FENOC to 

28 construct several new buildings and designate areas for decontamination and building material 

29 and supplies lay down. The descriptions of terrestrial resources in Section 2.2.6 and protected 

30 species and habitats in Section 2.2.7 serve as the basis for the assessment of refurbishment 

31 impacts to terrestrial resources contained in this section. The information concerning 

32 refurbishment activity timing and logistics was drawn from FENOC’s ER (2010). Changes to 

33 FENOC’s refurbishment plan will be submitted with the annual update to their license renewal 

34 application.

35 Onsite Impacts. FENOC plans to complete all refurbishment activities during an extended RFO

36 in the spring of 2014, which would last approximately 70 days. During the refurbishment period, 

37 FENOC would construct temporary and permanent buildings, move heavy equipment and 

38 machinery, and create lay down areas on previously disturbed areas within the owner-controlled 

39 area of the Davis-Besse site. FENOC estimates that total land disturbance would be less than 

40 10 acres (ac) (4 hectares (ha)). 

41 FENOC has constructed or plans to construct the following refurbishment-related buildings and 

42 facilities:
Environmental Impacts of Refurbishment

3-4 

• an 18,000-square foot (ft2

) (740-square meter (m2 1 )) permanent storage facility to store 

2 the current RV head, the original steam generators, and the reactor coolant system

3 (RCS) hot legs; 

• an 18,000-ft2 (1670-square meter (m2 4 )) permanent structure to house the replacement 

5 steam generators until they are installed in the plant; 

6 • a permanent multi-story office building to support the extra personnel required for 

7 refurbishment activities; and 

• various temporary facilities totaling 68,000 ft2

 (6320 m2 8 ) including tents and portable 

9 trailers for fabrication and assembly activities, mock-up activities, weld testing, 

10 decontamination, warehouse storage, and lay down areas. 

11 Additionally, FENOC may opt to construct a concrete pad to serve as a base for the temporary 

12 buildings described above. If FENOC constructs a concrete pad, the pad would remain on the 

13 site as a permanent structure following the completion of refurbishment activities.

14 All land that would be disturbed for construction and other refurbishment-related activities is 

15 previously disturbed and currently maintained as parking lots or other paved surface or as

16 landscaped areas that are regularly mowed. Because of this, no terrestrial habitat would be 

17 affected by refurbishment. Some sediment transport or erosion may occur during construction. 

18 Some wildlife in neighboring marsh and grassland habitat would likely avoid habitat margins 

19 during the refurbishment period due to increased noise and lighting, which would reduce the 

20 available habitat for those species. Edges species would be affected more than interior 

21 species. Because refurbishment is planned for the spring, construction activities could affect 

22 the nesting behavior of certain bird species. However, these impacts would be short-term 

23 because the refurbishment period will only last for about 70 days. Additionally, all nesting birds 

24 would benefit from the protective measures that FENOC follows regarding the bald eagle 

25 (Haliaeetus leucocephalus) and its nesting season (discussed below under “Protected Species 

26 and Habitats”).

27 Onsite impacts to terrestrial resources would be SMALL. The protective measures in place for 

28 bald eagles (discussed below) would benefit all wildlife in the immediate area. Increased noise 

29 and lighting may reduce habitat usage for a short time, but no undisturbed land would be 

30 immediately impacted; therefore, refurbishment would not result in the long-term conversion or 

31 loss of habitat or noticeably alter the behavior of any wildlife populations. 

32 Offsite Impacts. Babcock and Wilcox Canada, Ltd., will transport and deliver the steam 

33 generators to the Davis-Besse site via railroad. FENOC noted in their ER that physical 

34 modifications to the rail lines might be necessary to safely transport the new steam generators 

35 to the site. If rail lines need to be widened or improved, this would likely be contained within the 

36 established rail line right-of-way. However, depending on the surrounding habitat, construction 

37 activities could lead to loss of habitat, erosion, and altered wildlife behavior. Edge species and 

38 nesting birds would be affected more than interior species. Because the extent of offsite 

39 impacts is unknown at this stage, the impacts could range from SMALL to MODERATE.

40 Protected Species and Habitats. As discussed in Section 2.2.7, the U.S. Fish and Wildlife 

41 Service (FWS) identified two bald eagle nests that are located on the Davis-Besse site—one 

42 within Navarre Marsh and one northwest of the cooling tower near the site boundary 

43 (FWS 2010). FENOC’s (2011) environmental best management practices specify that no 

44 ground disturbing activity, tree clearing, or habitat modification occur within 660 feet (ft) 

45 (200 meters (m)) of any bald eagle nest from January 1 through July 31. If activities are 
Environmental Impacts of Refurbishment

3-5 

1 planned during this timeframe, FENOC’s procedures require them to coordinate with the FWS 

2 prior to taking action (FENOC 2011). Additionally, the Bald and Golden Eagle Protection Act of 

3 1940, as amended (16 U.S.C. §668-668c), prohibits the taking of eagles without a FWS-issued 

4 eagle permit. Taking includes any action or activity that decreases an eagle’s productivity by 

5 interfering with breeding, feeding, or sheltering behavior or any activity that results in an eagle 

6 abandoning its nest (50 CFR 22.3). Because the refurbishment activities would likely be within 

7 a 660 ft (200 m) radius of one or more bald eagle nest, FENOC would have to consult with the 

8 FWS prior to beginning refurbishment activities in the spring of 2014 to ensure that the 

9 appropriate mitigation measures are taken to minimize adverse impacts to bald eagles during 

10 the 70-day refurbishment period.

11 FENOC also maintains procedures concerning the Indiana bat (Myotis sodalis) (discussed in 

12 Section 2.2.7). If any Indiana bats inhabit natural areas on the Davis-Besse site, these 

13 individuals may avoid the area for a short period during refurbishment activities due to increased 

14 noise and lighting. However, because FENOC will not remove trees as part of the 

15 refurbishment activities, the NRC staff does not anticipate any measurable impacts to the 

16 Indiana bat.

17 None of the refurbishment activities are expected to impact any other Federally listed species, 

18 migratory birds, or State-listed species. Many State-listed plant species are known to occur on 

19 the Davis-Besse site (discussed in Section 2.2.7), but, because only previously disturbed land 

20 would be involved in refurbishment activities, no State-protected plants would be affected. 

21 State-listed animals that are known to occur on the site may avoid the immediate area and 

22 neighboring habitat edges due to construction noise and lighting. No critical habitat is 

23 designated in the vicinity of Davis-Besse.

24 Impacts to protected species and habitats would be SMALL because FENOC has procedures in 

25 place to protect the bald eagle, which is the protected species most likely to be affected by 

26 refurbishment activities. These protective measures would, in turn, benefit all migratory birds 

27 and other protected wildlife in the immediate area. Federally and State-listed plant species 

28 would not be impacted because all refurbishment activities would take place on previously 

29 disturbed land.

30 Conclusion. The NRC staff concludes that impacts on terrestrial resources from refurbishment 

31 would be SMALL to MODERATE. Some animals, especially nesting birds, may avoid habitats 

32 neighboring refurbishment activities due to increased noise and lighting during the 70-day 

33 refurbishment period. This impact would reduce the available habitat for a short time for certain 

34 animal populations. If any refurbishment activities are planned within 660 ft (200 m) of any bald 

35 eagle nest, FENOC would have to consult with the FWS regarding impacts to bald eagles and 

36 potential mitigation measures to reduce or avoid impacts. Offsite impacts will vary depending 

37 on the necessity to widen or improve rail lines to transport the steam generators to the 

38 Davis-Besse site. Potential mitigation measures that could reduce impacts to terrestrial 

39 resources during the refurbishment period include installing silt fences to minimize sediment 

40 transport and the use of best management practices, such as those currently in place regarding 

41 the bald eagle and Indiana bat.

42 3.2.2 Threatened and Endangered Species

43 Section 3.1.1 discusses FENOC’s planned refurbishment activities. The description of 

44 protected species and habitats in Section 2.2.7 serves as the basis for the assessment of 

45 refurbishment impacts to protected species and habitats contained in this section. The 
Environmental Impacts of Refurbishment

3-6 

1 information concerning refurbishment activity timing and logistics was drawn from FENOC’s 

2 ER (2010). 

3 Terrestrial Species and Habitats. Section 3.2.1 discusses terrestrial protected species and 

4 habitats and concludes that the impacts to these species would be SMALL because 

5 refurbishment activities would take place on previously disturbed areas of the site and would 

6 occur for only a short time (approximately 70 days). Additionally, impacts to the bald eagle, 

7 which is the most likely protected species to be affected by refurbishment activities, would be 

8 mitigated by the protective measures identified in FENOC’s (2011) environmental best 

9 management practices and by the bald eagle permit regulations (50 CFR Part 22) implementing 

10 the Bald and Golden Eagles Protection Act.

11 Aquatic Species and Habitats. Aquatic protected species and habitats, identified in 

12 Section 2.2.7, would not be affected by any refurbishment activities on the Davis-Besse site 

13 because FENOC does not anticipate any in-water work as part of refurbishment, and the 

14 replacement steam generators will be transported overland by rail (versus over-water barge).

15 Conclusion. The NRC staff concludes that the impacts to protected species and habitats from 

16 refurbishment would be SMALL. Refurbishment is most likely to affect bald eagles. However, if 

17 any refurbishment activities are planned within 660 ft (200 m) of any bald eagle nest, FENOC 

18 would have to consult with the FWS regarding impacts to bald eagles and potential mitigation 

19 measures to reduce or avoid impacts.

20 3.2.3 Housing Impacts—Refurbishment

21 Employment-Related Housing Impacts. Housing impacts is a Category 2 refurbishment issue. 

22 Table B-1 of Appendix B to 10 CFR Part 51, Subpart A, notes the following:

23 Housing impacts are expected to be of small significance at plants located in a 

24 medium or high population area and not in an area where growth control 

25 measures that limit housing development are in effect. Moderate or large 

26 housing impacts of the workforce associated with refurbishment may be 

27 associated with plants located in sparsely populated areas or in areas with 

28 growth control measures that limit housing development.

29 FENOC estimates that steam generator replacement would require a one-time increase in the 

30 number of RFO workers for up to 70 days at Davis-Besse. Approximately 900 additional 

31 workers would be needed to perform replacement activities in addition to the normal number of 

32 RFO workers (FENOC 2010).

33 Conclusion. The number of additional workers would cause a short-term increase in the 

34 demand for temporary (rental) housing units in the vicinity of Davis-Besse, beyond what is 

35 normally experienced during RFOs. Since Davis-Besse is located in a high-population area, 

36 and the number of available housing units has kept pace or exceeded changes in county 

37 populations (see Section 2.2.8.5), the additional number of workers would have no noticeable 

38 effect on the availability of rental housing. Due to the short duration of the replacement activity 

39 and the availability of housing in the region, employment-related housing impacts would be 

40 SMALL. 
Environmental Impacts of Refurbishment

3-7 

1 3.2.4 Public Services: Public Utilities—Refurbishment

2 Water Supply. Public utilities are a Category 2 refurbishment issue. Table B-1 of Appendix B to 

3 10 CFR Part 51, Subpart A, notes that, “[a]n increased problem with water shortages at some 

4 sites may lead to impacts of moderate significance on public water supply availability.”

5 Davis-Besse acquires potable water from the Carroll Township Water System, which has an 

6 excess capacity of 700,000 gallons per day (FENOC 2010). Hydro-demolition, if used, could 

7 require up to approximately 230,000 gallons of water per day, which is approximately one-third 

8 of the excess capacity of the Carroll Township Water Supply System. Coordination between 

9 Davis-Besse and Carroll Township Water Supply personnel during hydro-demolition could 

10 minimize the impact of this potential increased demand in water use at Davis-Besse 

11 (FENOC 2010).

12 As discussed in Section 3.2.4, steam generator replacement at Davis-Besse would require a 

13 one-time increase in the number of RFO workers for up to 70 days. The additional number of 

14 RFO workers needed to replace the steam generator would cause a short-term increase in the 

15 amount of public water and sewer services used in the immediate vicinity of Davis-Besse. 

16 Conclusion. Since there is no water shortage in the region, and the public water systems 

17 located in the four counties have excess capacity, any changes in demand for public water from 

18 the additional number of workers at Davis-Besse would have no noticeable effect on water 

19 supply availability in the four counties. As a result, the impacts to public utilities would be 

20 SMALL. 

21 3.2.5 Public Services: Education—Refurbishment

22 Educational Services. Education is a Category 2 refurbishment issue. Table B-1 of Appendix B 

23 to 10 CFR Part 51, Subpart A, notes that, “[m]ost sites would experience impacts of small 

24 significance but larger impacts are possible depending on site- and project-specific factors.”

25 Conclusion. As discussed in Section 3.2.4, steam generator replacement at Davis-Besse would 

26 require a one-time increase in the number of workers at the station during the RFO for up to 

27 70 days. Because of the short duration of the replacement activity, families and school age 

28 children would not accompany the workers; therefore, there would be no impact on educational 

29 services during the extended RFO. 

30 3.2.6 Offsite Land Use—Refurbishment

31 Land Assessment. Offsite land use is a Category 2 refurbishment issue. Table B-1 of 

32 Appendix B to 10 CFR Part 51, Subpart A, notes that, “[i]mpacts may be of moderate 

33 significance at plants in low population areas.”

34 Since Davis-Besse is in a high-population area, any changes in employment would have no 

35 noticeable effect on offsite land use in the region. Because of the short duration of the 

36 replacement activity, the additional number of RFO workers is not expected to cause any 

37 permanent changes in population and tax-revenue-related offsite land use in the immediate 

38 vicinity of Davis-Besse. Nevertheless, the replacement of the existing steam generators could 

39 increase the assessed value of Davis-Besse, and property tax payments to Ottawa County, 

40 Carroll Township could increase. However, it is expected that any increase in assessed 

41 property value would be small because the station improvement is replacing existing equipment. 
Environmental Impacts of Refurbishment

3-8 

1 Conclusion. Since FENOC’s tax payments to Ottawa County are a small percentage (around 

2 6 percent per year) of the total annual county operating budget, the incremental contribution and 

3 resulting impact to the county’s tax revenue—even with an increased assessment—would have 

4 no noticeable effect on offsite land use.

5 3.2.7 Public Services: Transportation—Refurbishment

6 Traffic Flow. Transportation is a Category 2 refurbishment issue. Table B-1 of Appendix B to 

7 10 CFR Part 51, Subpart A, notes the following:

8 Transportation impacts (level of service) of highway traffic generated during plant 

9 refurbishment and during the term of the renewed license are generally expected 

10 to be of small significance. However, the increase in traffic associated with 

11 additional workers and the local road and traffic control conditions may lead to 

12 impacts of moderate or large significance at some sites.

13 As previously discussed in Section 2.2.8.2, commuting routes to Davis-Besse via State 

14 Highway 2 are in rural and uncongested areas. According to FENOC, increased traffic volumes 

15 entering and leaving Davis-Besse during RFOs, which occur at intervals of approximately 24 

16 months, has not degraded the level of service capacity on local roads. Portable flashing caution 

17 and warning signs on State Route 2 are needed to slow traffic during outages to allow site traffic 

18 exiting the station to merge safely into traffic flow on State Route 2 (FENOC 2010). 

19 Conclusion. Due to the information presented in the ER, the short duration of the replacement 

20 activity (up to 70 days), and given that the steam generator replacement would occur during an 

21 extended RFO, transportation (level of service) impacts would be SMALL. 

22 3.2.8 Historic and Archaeological Resources

23 National Register-Eligible Historic or Archeological Resources. Historic and archeological 

24 resources are a Category 2 refurbishment issue. Table B-1 of Appendix B to 10 CFR Part 51, 

25 Subpart A, notes the following:

26 Generally, plant refurbishment and continued operation are expected to have no 

27 more than small adverse impacts on historic and archaeological resources. 

28 However, the National Historic Preservation Act requires the Federal agency to 

29 consult with the State Historic Preservation Officer to determine whether there 

30 are properties present that require protection.

31 FENOC has not proposed any new facilities, service roads, or transmission lines to support 

32 continued operations at Davis-Besse. However, as discussed in Section 3.1, FENOC plans to 

33 replace Davis-Besse steam generators in 2014. Ground disturbance would be limited to the 

34 construction of temporary and permanent concrete pads, temporary buildings to support 

35 construction activities, a permanent storage facility to house the retired steam generators, and a 

36 permanent multi-story office building. Construction of the steam generator storage facility and 

37 office building occurred in 2011. All construction activities have occurred or would occur on land 

38 that was previously disturbed during the construction of Davis-Besse. In addition, existing 

39 onsite rail lines may be improved for the transport of new steam generators (FENOC 2010).

40 The transport of the new steam generators to Davis-Besse would make use of existing 

41 infrastructure with little or no additional offsite land disturbance. The replacement generators 

42 would travel by rail and barge and, after delivery, would be transported over an existing service 
Environmental Impacts of Refurbishment

3-9 

1 road by a heavy-duty, self-propelled modular transporter. A load-haul path, consisting of fill and 

2 gravel, would be constructed onsite to haul the old steam generators to the permanent storage 

3 facility (FENOC 2010).

4 Conclusion. Steam generator replacement would not adversely impact any known historic or 

5 archeological resources on or in the vicinity of Davis-Besse as all activities are taking place on 

6 land that was previously disturbed during the construction of Davis-Besse. Furthermore, 

7 FENOC has formal guidelines in its Environmental Procedure (NOP-OP-2010 Revision 5) for 

8 protecting historic and archaeological resources prior to ground-disturbing activities. Therefore, 

9 impacts from this activity on National Register-eligible historic or archeological resources are 

10 SMALL.

11 3.2.9 Environmental Justice—Refurbishment

12 Environmental Justice. Environmental justice is a Category 2 refurbishment issue. Table B-1 of 

13 Appendix B to 10 CFR Part 51, Subpart A, notes that, “[t]he need for and the content of an 

14 analysis of environmental justice will be addressed in plant specific reviews.”

15 Potential impacts to minority and low-income populations from refurbishment-related plant 

16 modifications (steam generator replacement) at Davis-Besse would mostly consist of 

17 environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing 

18 impacts). Radiation doses from plant operations after steam generator replacement are 

19 expected to remain at current levels and well within regulatory limits.

20 Noise and dust impacts during steam generator replacement would be short-term and limited to 

21 onsite activities at Davis-Besse. Construction activities associated with steam generator 

22 removal would likely increase noise levels at the station (primarily from hydro-demolition, if 

23 used, or other mechanical means of concrete removal) greater than those associated with 

24 normal reactor operations at Davis-Besse. The loudest noise from construction activities, 

25 however, would be intermittent and relatively brief, and noise levels would decrease as the 

26 distance from the noise source increases.

27 Minority and low-income populations residing along site access roads would experience 

28 increased commuter vehicle traffic during RFO shift changes. In addition, increased demand for 

29 rental housing in the vicinity of Davis-Besse during the RFO and steam generator replacement 

30 could disproportionately affect low-income populations. However, due to the short duration of 

31 this refurbishment activity and the availability of rental housing in the four-county region of 

32 interest (ROI), any impact experienced by low-income populations would be short-term and 

33 limited. According to the American Community 3-year Estimate Survey 2007–2009, there were 

34 over 40,000 vacant housing units in Ottawa, Lucas, Wood, and Sandusky Counties 

35 (USCB 2010). 

36 Conclusion. Due to the short duration of the replacement activity, and based on the analysis of 

37 impacts for the other resource areas discussed in Section 3.2, impacts to minority and 

38 low-income populations living near Davis-Besse would be temporary and not disproportionately

39 high and adverse. 
Environmental Impacts of Refurbishment

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1 3.2.10 Air Quality

Air quality during refurbishment (non-attainment and maintenance areas) is a Category 2 issue1 2 . 

3 Table B-1 of Appendix A to Subpart B, “Environmental Effect of Renewing the Operating

4 License of a Nuclear Power Plant,” of 10 CFR Part 51, “Environmental Protection Regulations

5 for Domestic Licensing and Related Regulatory Functions,” notes the following:

6 Air quality impacts from plant refurbishment associated with license renewal are

7 expected to be small. However, vehicle exhaust emissions could be cause for

8 concern at locations in or near nonattainment or maintenance areas. The

9 significance of the potential impact cannot be determined without considering the

10 compliance statutes of each site and the numbers of workers expected to be

11 employed during the outage.

12 Specifically, 10 CFR 51.53(c)(3)(ii)(F) requires the following:

13 If the applicant’s plant is located in or near a nonattainment or maintenance area,

14 an assessment of vehicle exhaust emissions anticipated at the time of peak

15 refurbishment work force must be provided in accordance with the Clean Air Act 

16 (CAA) as amended.

17 The 1996 GEIS states the following:

18 The 1990 CAA amendments include a provision that no federal agency shall

19 support any activity that does not conform to a state implementation plan

20 designed to achieve the National Ambient Air Quality Standards (NAAQS) for

21 criteria pollutants (sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, lead,

22 and particulate matter less than 10 μm in diameter). On November 30, 1993, the

23 U.S. Environmental Protection Agency (EPA) issued a final rule (58 FR 63214)

24 implementing the new statutory requirements, effective January 31, 1994. The

25 final rule requires that federal agencies prepare a written conformity analysis and

26 determination for each pollutant where the total of direct and indirect emissions

27 caused by proposed federal action would exceed established threshold emission

28 levels in a nonattainment or maintenance area. An area is designated

29 “nonattainment” for a criteria pollutant if it does not meet the NAAQS for the

30 pollutant. A maintenance area has been redesignated by a State from

31 nonattainment to attainment; the State must submit to EPA a plan for maintaining

32 the NAAQS as a revision to its State Implementation Plan.

33 Activities associated with refurbishment at Davis-Besse are discussed in Section 3.1. Minor and 

34 short-duration air quality impacts can be expected to occur during the steam generator 

35 replacement project activities. As described in the ER (FENOC 2010), the applicant identified 

36 the need to construct a new steam generator storage facility to support site refurbishment 

37 activities. In the interim, construction of this new, permanent facility was completed in 2011. 

38 The main contributors to air quality impacts associated with completed and ongoing 

39 refurbishment activities would be fugitive dust generation from facility construction activities, 

 

1 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 

10 CFR Part 51, “Environmental protection regulations for domestic licensing and related regulatory functions” (NRC 2012). With 

respect to air quality, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by changing “Air Quality during 

refurbishment (non-attainment and maintenance areas)” issue from, a Category 2 to a Category 1 issue and renamed, “Air Quality 

impacts (all plants).” This Category 1 issue, “Air Quality impacts (all plants),” has an impact level of SMALL. There was no change 

to the Category 1, “Air Quality effects of transmission lines” issue. The NRC staff performed its review of air quality issues in 

accordance with the 1996 GEIS (NUREG-1437) and rule for this issue. 
Environmental Impacts of Refurbishment

3-11

1 refurbishment work to open the shield building and containment vessel to replace the steam 

2 generators and related equipment, and exhaust emissions from motorized equipment and 

3 vehicles of temporary workers. Best management practices in accordance with FENOC and 

4 site procedures will be implemented to minimize the amount of fugitive dust (FENOC 2010). 

5 Additionally, fugitive emissions and exhaust emission from motorized equipment will be 

6 temporary and short term.

7 As discussed in Section 2.2.2.1, Davis-Besse is located in Ottawa County, which is part of the 

8 Sandusky Intrastate Air Quality Control Region (AQCR) (40 CFR 81.203). Ottawa County is 

9 designated in attainment for CO, Pb, NO2, PM10, PM2.5 and is not designated for SO2

10 (OEPA 2013). Lucas and Wood Counties abutting Ottawa County to the north and west, 

11 respectively, are designated as maintenance areas for 1997 8-hour ozone NAAQS (EPA 2013). 

12 The nearest nonattainment area is Monroe County, Michigan, for PM2.5 NAAQS; Monroe County 

13 is also designated as a maintenance area for 1997 8-hour ozone NAAQS (EPA 2013). 

14 Wood County is about 17 miles from Davis-Besse (distance can range from 17 to 51 miles), 

15 Lucas County is about 5 miles from Davis-Besse (distance can range from 5 to 43 miles), and 

16 Monroe County is about 21 miles from Davis-Besse (distance can range from 21 to 

17 49 miles).Refurbishment activities will require an estimated additional 900 workers 

18 (FENOC 2010). As noted in the ER, 74 percent of Davis-Besse employee’s reside in Ottawa 

19 County (37.2 percent), Lucas County (19.8 percent), Wood County(15.5 percent) and Monroe 

20 County (1.4 percent) (FENOC 2010). Therefore, it can be expected that the additional 

21 workforce would reside in these counties, which are within the 50-mile radius of Davis-Besse 

22 (see distances above). Consequently, it is assumed that the additional workforce needed would 

23 travel from areas within the 50-mile radius of Davis-Besse and that each of the 900 workers 

24 would travel 100 miles daily commuting to and from Davis-Besse. This would result in an 

25 additional 900 vehicles and 90,000 vehicle miles per day within the region. In 2011, the 

26 average number of vehicle miles traveled within Lucas, Wood, and Monroe counties was 

27 6,940,080, 4,807,420 and 3,172,149 per day, respectively (MDOT 2013; ODOT 2013). The 

28 additional number of vehicle miles that would be traveled in the region per day during 

29 refurbishment represents 1.3, 1.87, and 2.83 percent of the total miles traveled daily in Lucas, 

30 Wood or Monroe County, respectively. Because the additional workforce would travel from all 

31 over the 50-mile region and not necessarily have a 100-mile roundtrip commute, this projected 

32 increase in miles traveled daily for each county is conservative. As noted above, Lucas, Wood, 

33 and Monroe counties are designated maintenance areas for 1997 8-hour ozone NAAQS, and 

34 Monroe County is a nonattainment area for PM2.5 NAAQS. The increase in emissions for each 

35 of these pollutants resulting from the additional workforce was estimated to determine if 

36 emissions would be likely to exceed established threshold emission levels in a non-attainment 

37 or maintenance area. Ozone is formed when NOx and VOCs combine in the presence of heat 

38 and sunlight; hence, VOCs and NOx are precursors that contribute to the formation of ozone. 

39 PM2.5 can be emitted directly as well as indirectly as a result of chemical reactions of gases 

40 (NOx, SO2, VOCs, and ammonia) that form PM2.5. The Michigan Department of Environmental 

41 Quality (MDEQ) has determined that SO2 and NOx are the main precursors of PM2.5; therefore, 

42 only direct PM2.5, NOx, and SO2 from vehicle emissions are analyzed in the assessment below 

43 (MDEQ 2008). Replacement of Davis-Besse’s steam generators, with work estimated to 

44 commence in February 2014, is estimated to be completed within 70 days. Therefore, the total 

45 vehicle miles during the steam generator replacement and RFO would be 6.3 million miles 

46 (assuming a daily 100-mile roundtrip commute as discussed above). It is estimated that the 

47 additional 6.3 million miles would result in an additional 12.54 tons of VOCs, 24.62 tons of NOx, 

48 0.54 tons of SO2, and 0.76 tons of PM2.5 (direct emissions) being emitted, which do not exceed 

49 the de minimis levels of 100 tons per year of NOx, 50 tons per year of VOCs for ozone 
Environmental Impacts of Refurbishment

3-12

1 maintenance areas, 100 tons per year of direct emissions of PM2.5, 100 tons per year of SO2, 

2 and 100 tons per year of for PM2.5 maintenance areas set forth in 40 CFR 93.153(b).

3 Additionally, a screening analysis in the 1996 GEIS determined that emissions from 

4 2,300 vehicles over a 9 month refurbishment period may exceed the thresholds for carbon 

5 monoxide, oxides of nitrogen, and VOCs in non-attainment and maintenance areas and that the 

6 amount of road dust generated by the vehicles traveling to and from the work site would exceed 

7 the threshold for PM10 in serious non-attainment areas. Consequently, vehicular emissions that 

8 will result from the additional 900 workers for 70 days will not be significant. On this basis, the 

9 NRC staff concludes that the impact of vehicle exhaust emissions associated with steam 

10 generator replacement activities would be SMALL.

11 3.3 Evaluation of New and Potentially Significant Information on Impacts of

12 Refurbishment

13 The NRC staff reviewed the information presented in the Davis-Besse ER, supporting 

14 documentation, and information gathered during the site audits and interviews. During the 

15 review, the staff did not identify any new and significant information that would affect the 

16 conclusion presented in the ER. The staff does not expect that the environmental impacts 

17 caused by Davis-Besse during the renewal term will be beyond those that occur during the 

18 normal plant operations. Therefore, the NRC staff adopts the findings in the GEIS for 

19 Category 1 issues associated with refurbishment and concludes that there would be no 

20 environmental impacts during the renewal term beyond those discussed in the GEIS for these 

21 issues. 

22 3.4 Summary Impacts of Refurbishment

23 For all but one of the eight Category 2 issues and environmental justice, the impacts of 

24 refurbishment at Davis-Besse range from unnoticeable impacts to a SMALL impact. The NRC 

25 staff concludes that there would be a SMALL impact for the following refurbishment issues: 

26 • Threatened or Endangered Species, 

27 • Offsite Land Use, 

28 • Historic and Archeological Resources, and

29 • Air Quality. 

30 The NRC staff concludes that the potential environmental effects are unnoticeable to SMALL for 

31 the following refurbishment issues: 

32 • Housing Impacts, 

33 • Public Services: Education, 

34 • Public Services: Public Utilities, and

35 • Public Services: Transportation. 

36 The NRC staff concludes that the potential environmental impacts to terrestrial resources are

37 SMALL to MODERATE. 

38 3.5 References

39 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

40 Production and Utilization Facilities.”
Environmental Impacts of Refurbishment

3-13

1 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

2 Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

3 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

4 Renewal of Operating Licenses for Nuclear Power Plants.”

5 50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, “Eagle 

6 Permits.”

Bald and Golden Eagles Protection Act of 1940, as amended, 16 U.S.C. § 668–668c. 7 

8 [EPA] U.S. Environmental Protection Agency. 2013. The Green Book Nonattainment Areas for 

9 Criteria Pollutants. Updated on December 14, 2012. Available URL: 

10 <http://www.epa.gov/oaqps001/greenbk/> (accessed 4 March 2013). 

11 [FENOC] FirstEnergy Nuclear Operating Company. 2010. “Davis-Besse Nuclear Power Station 

12 License Renewal Application,” Toledo, OH, August 2010, Agencywide Documents Access and 

13 Management System (ADAMS) Accession Nos. ML102450572 

14 [FENOC] FirstEnergy Nuclear Operating Company. 2011. Letter from Barry S. Allen, to 

15 Document Control Desk, NRC. Subject: Davis-Besse Nuclear Power Station, Unit No.1, Docket 

16 No. 50-346, License Number NPF-3, “Reply to Requests for Additional Information for the 

17 Review of the Davis-Besse Nuclear Power Station. Unit No.1. License Renewal Application 

18 (TAC No. ME4613) Environmental Report.” May 27. ADAMS Accession No. ML111930294. 

19 [FWS] U.S. Fish and Wildlife Service. 2010ms. E-mail from Seymour M, Wildlife Biologist, to 

20 Bulavinetz R, NRC. Subject: Federally listed species along Davis-Besse transmission line 

21 corridors. September 24, 2010. ADAMS Accession No. ML110730328.

22 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 

23 for License Renewal of Nuclear Plants, NUREG-1437, Washington, D.C., May. ADAMS 

24 Accession Nos. ML040690705 and ML040690738.

25 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 

26 for License Renewal of Nuclear Plants, Main Report, NUREG-1437, Section 6.3, Table 9.1, 

27 Volume 1, Addendum 1, Washington, D.C.

28 [ODOT] Ohio Department of Transportation. 2013. Division of Planning, Office of Technical 

29 Services, Daily Vehicle Miles Traveled Report (DVMT). Available URL: 

30 http://www.dot.state.oh.us/Divisions/Planning/TechServ/TIM/Pages/DVMT.aspx. 

31 [OEPA] Ohio Environmental Protection Agency. 2013. National Ambient Air Quality 

32 Standards—Attainment Status. Available URL: 

33 http://www.epa.state.oh.us/dapc/general/naaqs.aspx (accessed 4 June 2013).

34 [MDEQ] Michigan Department of Environmental Quality. 2008. State Implementation Plan 

35 Submittal. Available URL: http://www.michigan.gov/documents/deq/deq-aqd-air-aqe-PM25-

36 SIP-Final-2008_238092_7.pdf. 

37 [MDOT] Michigan Department of Transportation. 2013. Traffic Monitoring Information System 

38 (TMIS), 2011 Traffic Estimates. Available URL: 

39 http://mdotnetpublic.state.mi.us/tmispublic/ReportLinks.aspx 
Environmental Impacts of Refurbishment

3-14

1 [USCB] U.S. Census Bureau. 2010. “American FactFinder, Census 2000 and 2006–2008, 

2 3-Year Estimate, American Community Survey, State and County QuickFacts on Lucas, 

3 Sandusky, Ottawa and Wood Counties, Ohio, and Housing Characteristics for 2000 and 

4 2006–2008, 3-Year Estimate.” Available URLs: <http://factfinder.census.gov> and 

5 <http://quickfacts.census.gov> (accessed April 2011).
4-1 

4.0 ENVIRONMENTAL IMPACTS OF OPERATION

This chapter addresses potential environmental impacts related to the period of extended 

operation of Davis-Besse Nuclear Power Station, Unit No.1, (Davis-Besse). These impacts are 

grouped and presented according to resource. Generic issues (Category 1) issues rely on the 

analysis provided in the generic environmental impact statement (GEIS) 

(NRC 1996, 1999a, 2013a) and are generally discussed briefly. Site-specific issues 

(Category 2) have been analyzed for Davis-Besse and assigned a significance level of SMALL, 

MODERATE, or LARGE, accordingly. Some remaining issues are not applicable to 

Davis-Besse because of site characteristics or plant features. For an explanation of the criteria 

for Category 1 and Category 2 issues, as well as the definitions of SMALL, MODERATE, and 

LARGE, refer to Section 1.4 of this supplemental environmental impact statement (SEIS). As 

also described in Section 1.4, the U.S. Nuclear Regulatory Commission (NRC) has published a 

final rule (78 FR 37282, June 20, 2013) revising its environmental protection regulation, Title 10 

of the Code of Federal Regulations (10 CFR) Part 51, “Environmental protection regulations for 

domestic licensing and related regulatory functions.” The final rule consolidates similar 

Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and 

consolidates some of those issues with existing Category 1 issues. The final rule also adds new 

Category 1 and 2 issues.

As described in Section 1.5 of this SEIS, FENOC submitted its Environmental Report (ER) 

under NRC's 1996 rule governing license renewal environmental reviews (61 FR 28467, 

June 5, 1996, as amended), as codified in NRC's environmental protection regulation, 10 CFR 

Part 51. The 1996 GEIS (NRC 1996) and Addendum 1 to the GEIS (NRC 1999) provided the 

technical basis for the list of NEPA issues and associated environmental impact findings for 

license renewal contained in Table B–1 in Appendix B to Subpart A of 10 CFR Part 51. For 

Davis-Besse, the NRC staff initiated its environmental review in accordance with the 1996 rule 

and GEIS (NRC 1996, 1999) and documented its findings in this chapter of the SEIS. General 

references within this SEIS that refer to the “GEIS” without stipulation are inclusive of the 1996 

and 1999 GEIS (NRC 1996, 1999). Information and findings specific to the June 2013, final 

rule (78 FR 37282) and/or the June 2013 GEIS (NRC 2013) are appropriately referenced as 

such. 

4.1 Land Use

Onsite land use issues that could be affected by license renewal are listed in Table 4.1-1. As 

discussed in the GEIS, onsite land use and powerline right-of-way (ROW) conditions are 

expected to remain unchanged during the license renewal term at all nuclear plants; thus, 

impacts would be SMALL. These issues were, therefore, classified as Category 1 issues. 

Section 2.2.1 of this SEIS describes the land use conditions at Davis-Besse.

Davis-Besse’s Environmental Report (ER) (FENOC 2010), scoping comments, and other 

available data records for Davis-Besse were reviewed and evaluated for new and significant 

information. The review included a data gathering site visit to Davis-Besse. No new and 

significant information was identified during this review that would change the conclusions 

presented in the GEIS. Therefore, for these Category 1 issues, impacts during the renewal term 

are not expected to exceed those discussed in the GEIS and are SMALL. 
Environmental Impacts of Operation

4-2 

Table 4.1-1. Land Use Issues

Issues GEIS Section Category

Onsite land use 4.5.3 1

Powerline ROW 4.5.3 1

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

4.2 Air Quality

As described in Section 1.4 of this SEIS, the NRC approved a revision to its environmental 

protection regulation, 10 CFR Part 51, “Environmental protection regulations for domestic 

licensing and related regulatory functions” (NRC 2013). With respect to air quality, the final rule 

amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by changing “Air quality during 

refurbishment (non-attainment and maintenance areas)” issue from a Category 2 to a 

Category 1 issue and renamed “Air quality impact (all plants).” This Category 1 issue, “Air 

quality impacts (all plants),” has an impact level of SMALL. There was no change to the 

Category 1, “Air quality effects of transmission lines” issue. The NRC staff performed its review, 

as discussed below, of air quality issues in accordance with the 1996 GEIS. 

The air quality issues applicable to Davis-Besse are listed in Table 4.2-1. In evaluating the 

potential impacts on air quality associated with license renewal, the NRC staff uses as its 

baseline the existing air quality conditions described in Section 2.2.2.1 of this SEIS. These 

baseline conditions encompass the existing air quality conditions (EPA’s National Ambient Air 

Quality Standards county designations) potentially affected by air emissions from license 

renewal. Davis-Besse is located in Ottawa County, which is part of the Sandusky Intrastate Air 

Quality Control Region (AQCR) (40 CFR 81.203). Ottawa County is designated in attainment 

for CO, Pb, NO2, PM10, PM2.5 and is not designated for SO2 (OEPA 2013).

Table 4.2-1. Air Quality Issues

Issue GEIS Section Category

Air quality during refurbishment (non-attainment & maintenance areas) 3.3 2

Air quality effects of transmission lines 4.5.2 1

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

Air quality impacts from planned refurbishment activities associated with license renewal is a 

Category 2 issue. As discussed in Section 3.2.10, refurbishment activities will require an 

estimated additional 900 workers for 70 days. Exhaust emissions from vehicles of temporary 

workers can contribute to air quality impacts. Vehicular emissions that will result from the 

additional 900 workers for 70 days will be temporary and will not be significant. As discussed in 

Section 3.2.10, the NRC staff concludes that the impact of vehicle exhaust emissions 

associated with refurbishment activities would be SMALL

For the Category 1 issue of air quality effects of transmission lines, the NRC found that 

“production of ozone and oxides of nitrogen is insignificant and does not contribute measurably 

to ambient levels of these gases.” The NRC staff did not identify any new and significant 

information based on review of the ER (FENOC 2010), the public scoping process, or as a 

result of the environmental site audit that would change the conclusions presented in the GElS 

(NRC 1996), and therefore, the NRC staff concludes the impacts are SMALL. 
Environmental Impacts of Operation

4-3 

4.3 Geologic Environment 

The geologic environment issue related to the Davis-Besse license renewal is listed in 

Table 4.3-1 (also see Table B-1 of Appendix B of 10 CFR Part 51 (78 FR 37282)). This is a 

new Category 1 issue that was identified in the 2013 GEIS. 

Table 4.3-1. Geologic Environment Issue 

Issue GEIS Section Category

Geology and Soils 4.4 1

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (78 FR 37282, NRC 2013). 

4.3.1 Geology and Soils

As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

protection regulation, 10 CFR Part 51, “Environmental protection regulations for domestic 

licensing and related regulatory functions” (NRC 2013). With respect to the geologic 

environment of a plant site, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 

CFR Part 51 by adding a new Category 1 issue, “Geology and soils.” This new issue has an 

impact level of SMALL. This new Category 1 issue considers geology and soils from the 

perspective of those resource conditions or attributes that can be affected by continued 

operations during the renewal term. An understanding of geologic and soil conditions has been 

well established at all nuclear power plants and associated transmission lines during the current 

licensing term, and these conditions are expected to remain unchanged during the 20-year 

license renewal term for each plant. The impact of these conditions on plant operations and the 

impact of continued power plant operations and refurbishment activities on geology and soils 

are SMALL for all nuclear power plants and not expected to change appreciably during the 

license renewal term. Operating experience shows that any impacts to geologic and soil strata 

would be limited to soil disturbance from construction activities associated with routine 

infrastructure renovation and maintenance projects during continued plant operations. 

Implementing best management practices would reduce soil erosion and subsequent impacts 

on surface water quality. Information in plant-specific SEISs prepared to date and reference 

documents have not identified these impacts as being significant.

Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to 

Davis-Besse. The NRC staff did not identify any new and significant information with regard to 

this Category 1 (generic) issue based on review of the ER (FENOC 2010), the public scoping 

process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS 

and as identified in the ER (FENOC 2010), FENOC plans to construct new facilities in support of 

associated refurbishment activities that could affect up to 10 ac (4 ha) of land (see 

Section 3.2.1). Such activities would require site clearing, grading, ground excavation, and 

placement of backfill. However, ground-disturbing activities would be confined to previously 

disturbed areas that currently exist as impervious surface (e.g., parking lots), or are currently 

maintained as landscaped areas. This work would be performed in accordance with 

Davis-Besse’s stormwater pollution prevention plan (see Section 2.2.4) and associated best 

management practices to control runoff from disturbed areas and to prevent or significantly 

mitigate soil erosion and loss. It is also anticipated that plant operation and maintenance 

activities would be confined to previously disturbed areas or existing ROWs during the license 

renewal term. Based on this information, it is expected that any incremental impacts on geology 

and soils during the license renewal term would be SMALL (NRC 2013). 
Environmental Impacts of Operation

4-4 

4.4 Surface Water Resources 

The surface water issues applicable to Davis-Besse are listed in Table 4.4-1 (also see 

Table B-1 of Appendix B of 10 CFR Part 51). Surface water use and water quality relative to 

Davis-Besse are described in Sections 2.1.7.1 and 2.2.4 of this SEIS, respectively.

4.4.1 Generic Surface Water Issues

The NRC staff did not identify any new and significant information based on review of the ER 

(FENOC 2010), the public scoping process, or the environmental site audit. The NRC staff also 

reviewed other sources of information such as various permits, assorted applicant files, and 

data reports. As a result, no information or impacts related to these issues was identified that 

would change the conclusions presented in the GEIS (NRC 1996). Therefore, it is expected 

that there would be no impacts related to these Category 1 issues during the period of extended 

operation beyond those discussed in the GEIS. For these surface water issues, the GElS 

concludes that the impacts are SMALL.

Table 4.4-1. Surface Water Use and Quality Issues

Issue GEIS Section Category

Altered current patterns at intake & discharge structures 4.2.1.2.1 1

Altered thermal stratification of lakes 4.2.1.2.3 1

Temperature effects on sediment transport capacity 4.2.1.2.3 1

Scouring caused by discharged cooling water 4.2.1.2.3 1

Eutrophication 4.2.1.2.3 1

Discharge of chlorine or other biocides 4.2.1.2.4 1

Discharge of sanitary wastes & minor chemical spills 4.2.1.2.4 1

Discharge of other metals in wastewater 4.2.1.2.4 1

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

4.4.2 Surface Water Use Conflicts

No Category 2 surface water issues were found to be applicable to the continued operation of 

the facility, and no further evaluation was performed for Davis-Besse.

4.5 Groundwater Resources

The groundwater issues applicable to Davis-Besse are listed in Table 4.5-1 (also see Table B-1 

of Appendix B of 10 CFR Part 51). Groundwater use and water quality relative to Davis-Besse 

are described in Sections 2.1.7.2 and 2.2.5 of this SEIS, respectively.

Table 4.5-1. Groundwater Use and Quality Issues

Issue GEIS Section Category

Groundwater use conflicts (potable & service water; plants that use 

<100 gallons per minute (gpm))

4.8.1.1 1

Radionuclides released to groundwater 4.5.1.2(a) 2
Environmental Impacts of Operation

4-5 

Issue GEIS Section Category

(a)NRC 2013: 78 FR 37282

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996). 

4.5.1 Groundwater Use Conflicts 

Groundwater is not used at the Davis-Besse plant, and groundwater withdrawal has not taken 

place since construction phase dewatering. The NRC staff did not identify any new and 

significant information based on review of the ER (FENOC 2010), the public scoping process, or 

the environmental site audit that would change the conclusions presented in the GEIS. 

Therefore, it is expected that were would be no impacts related to this Category 1 issue during 

the period of extended operation beyond those discussed in the GEIS (NRC 1996). For the 

single Category 1 (generic) groundwater issue applicable to Davis-Besse, the GEIS concludes 

that the impact is SMALL.

4.5.2 Radionuclides Released to Groundwater

As described in Section 1.4 of this SEIS, in 2013, the NRC has approved a revision to its 

environmental protection regulation, 10 CFR Part 51. With respect to groundwater quality, the 

final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

Category 2 issue, “Radionuclides released to groundwater,” with an impact level range of 

SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from

plant systems into groundwater. This new Category 2 issue has been added to evaluate the 

potential impact to groundwater quality from the discharge of radionuclides from plant systems, 

piping, and tanks. This issue was added because, within the past several years, there have 

been events at nuclear power reactor sites that involved unknown, uncontrolled, and 

unmonitored releases of radioactive liquids into the groundwater. 

Davis-Besse has had leaks of tritium to onsite groundwater, as described in Section 2.2.5. 

Tritium-contaminated groundwater has not moved offsite. Identified sources of groundwater 

leaks were repaired. The highest tritium concentrations reported are well below the U.S. EPA 

drinking water standard of 20,000 pCi/l (40 CFR 141.66). At the end of 2011, tritium 

concentrations in all monitoring wells were at or very close to background concentrations. The 

impact of radionuclides released to groundwater is determined to be SMALL and is expected to 

remain SMALL during the license renewal term. 

4.6 Aquatic Resources

Table 4.6-1 lists the issues related to aquatic resources applicable to Davis-Besse. No 

Category 2 issues are related to aquatic resources. The NRC staff did not find any new and 

significant information during the review of the applicant’s ER (FENOC 2010), the site audit, the 

scoping process, or the evaluation of other available information. As a result, no information or 

impacts related to these issues was identified that would change the conclusions presented in 

the GEIS (NRC 1996). Therefore, the NRC staff concludes that there would be no impacts 

related to these issues beyond those discussed in the GEIS. The GEIS concludes that the 

impacts are SMALL. 
Environmental Impacts of Operation

4-6 

Table 4.6-1. Aquatic Resources Issues 

Issue GEIS Section Category

For all plants

Accumulation of contaminants in sediments or biota 4.2.1.2.4 1

Entrainment of phytoplankton & zooplankton 4.2.2.1.1 1

Cold shock 4.2.2.1.5 1

Thermal plume barrier to migrating fish 4.2.2.1.6 1

Distribution of aquatic organisms 4.2.2.1.6 1

Premature emergence of aquatic insects 4.2.2.1.7 1

Gas supersaturation (gas bubble disease) 4.2.2.1.8 1

Low dissolved oxygen in the discharge 4.2.2.1.9 1

Losses from predation, parasitism, & disease among organisms exposed to 

sublethal stresses

4.2.2.1.10 1

Stimulation of nuisance organisms 4.2.2.1.11 1

Exposure of aquatic organisms to radionuclides 4.6.1.2(a) 1

For plants with cooling tower-based heat-dissipation systems

Entrainment of fish & shellfish in early life stages 4.3.3 1

Impingement of fish & shellfish 4.3.3 1

Heat shock 4.3.3 1

(a) NRC 2013: 78 FR 37282

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

4.6.1 Exposure of Aquatic Organisms to Radionuclides

As described in Section 1.4 of this SEIS, in 2013, the NRC approved a revision to its 

environmental protection regulation, 10 CFR Part 51, governing environmental impact reviews 

of nuclear power plant operating renewed licenses. With respect to the aquatic organisms, the 

final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

Category 1 issue, “Exposure of aquatic organisms to radionuclides,” among other changes. 

This new Category 1 issue considers the impacts to aquatic organisms from exposure to 

radioactive effluents discharged from a nuclear power plant during the license renewal term. An 

understanding of the radiological conditions in the aquatic environment from the discharge of 

radioactive effluents within NRC regulations has been well established at nuclear power plants 

during their current licensing term. Based on this information, the NRC concluded that the 

doses to aquatic organisms are expected to be well below exposure guidelines developed to 

protect these organisms and assigned an impact level of SMALL.

The NRC staff has not identified any new and significant information related to the exposure of 

aquatic organisms to radionuclides during its independent review of the applicant’s ER

(FENOC 2010) , the site audit, and the scoping process. Section 2.1.2 of this SEIS describes 

the applicant’s Radioactive Waste Management Program to control radioactive effluent 

discharges to ensure that they comply with NRC regulations in 10 CFR Part 20. Section 4.9.1 
Environmental Impacts of Operation

4-7 

of this SEIS contains the NRC staff’s evaluation of Davis-Besse’s radioactive effluent and 

radiological environmental monitoring programs. Based on its evaluation of Davis-Besse’s 

radioactive effluent and radiological environmental monitoring programs, the NRC staff 

concludes that the impacts from radioactive effluents to aquatic organisms are SMALL. The 

NRC staff concludes that there would be no impacts to aquatic organisms from radionuclides 

beyond those impacts contained in the GEIS (NRC 2013) and therefore, the impacts to aquatic 

organisms from radionuclides are SMALL.

4.7 Terrestrial Resources

The issues related to terrestrial resources applicable to Davis-Besse are discussed in the 

following sections and listed in Table 4.7-1. 

4.7.1 Generic Terrestrial Resources Issues

The NRC did not identify any new and significant information during the review of the applicant’s 

ER (FENOC 2010), the NRC staff’s site audit, the scoping process, or the evaluation of other 

available information that would change the conclusions presented in the GEIS. Therefore, it is 

expected that there would be no impacts related to these the Category 1 issues beyond those 

discussed in the GEIS (NRC 1996). For these issues, the GEIS concludes that the impacts are 

SMALL. 

Table 4.7-1. Terrestrial Resources Issues 

Issue GEIS Section Category

Cooling tower impacts on crops & ornamental vegetation 4.3.4 1

Cooling tower impacts on native plants 4.3.5.1 1

Bird collisions with cooling towers 4.3.5.2 1

Powerline right-of-way management (cutting herbicide application) 4.5.6.1 1

Bird collisions with powerlines 4.5.6.1 1

Impacts of electromagnetic fields on flora & fauna (plants, agricultural crops, 

honeybees, wildlife, livestock) 4.5.6.3 1 

Floodplains & wetland on powerline right-of-ways 4.5.7 1

Exposure of terrestrial organisms to radionuclides 4.6.1.1(a) 1

Effects on terrestrial resources (non-cooling system impacts) 4.6.1.1 (a) 2

(a) NRC 2013: 78 FR 37282

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996). 

4.7.2 Exposure of Terrestrial Organisms to Radionuclides

As described in Section 1.4 of this draft SEIS, in 2013, the NRC approved a revision to its 

environmental protection regulation, 10 CFR Part 51, governing environmental impact reviews 

of nuclear power plant operating renewed licenses (NRC 2013). With respect to the terrestrial 

organisms, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by 

adding a new Category 1 issue, “Exposure of terrestrial organisms to radionuclides,” among 

other changes. This new issue has an impact level of SMALL. This new Category 1 issue 

considers the impacts to terrestrial organisms from exposure to radioactive effluents discharged 
Environmental Impacts of Operation

4-8 

from a nuclear power plant during the license renewal term. An understanding of the 

radiological conditions in the terrestrial environment from the discharge of radioactive effluents 

within NRC regulations has been well established at nuclear power plants during their current 

licensing term. Based on this information, the NRC concluded that the doses to terrestrial 

organisms are expected to be well below exposure guidelines developed to protect these 

organisms and assigned an impact level of SMALL.

The NRC staff has not identified any new and significant information related to the exposure of 

terrestrial organisms to radionuclided during its independent review of Davis-Besse's ER

(FENOC 2010), the site audit, and the scoping process. Chapter 2 of this SEIS describes the 

applicant’s radioactive waste management program to control radioactive effluent discharges to 

ensure that they comply with NRC regulations. Section 4.9.1 of this SEIS contains the NRC 

staff’s evaluation of the applicant’s radioactive effluent and radiological environmental 

monitoring programs. Based on its review of Davis-Besse’s radioactive effluent and radiological 

environmental monitoring programs, the NRC staff concludes that the impacts from radioactive 

effluents to terrestrial organisms would be SMALL. The NRC staff concludes that there would be 

no impact to terrestrial organisms to radionuclides beyond those impacts described in the GEIS 

(NRC 2013), and therefore, the impacts to terrestrial organisms from radionuclides would be 

SMALL.

4.7.3 - Effects on Terrestrial Resources (Non-cooling System Impacts)

As described in Section 1.4 of this SEIS, in 2013, the NRC approved a revision to its 

environmental protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, 

the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the 

Category 2 issue, “Refurbishment impacts,” among others, to include normal operations, 

refurbishment, and other supporting activities during the license renewal term. This issue 

remains a Category 2 issue with an impact level range of SMALL to LARGE; however, the final

rule renames this issue, “Effects on terrestrial resources (non-cooling system impacts).” 

Section 2.2.7 describes the terrestrial resources on and in the vicinity of the plant site and 

vicinity, and Section 2.2.8 describes protected species and habitats. As discussed in Chapter 3 

of this SEIS and described in Section 4.3.1 above, FENOC plans to construct new facilities in 

support of associated refurbishment activities that could affect up to 10 ac (4 ha) of land. 

However, ground-disturbing activities would be confined to previously disturbed areas. 

FENOC (2010) anticipates no new impacts on terrestrial resources because of refurbishment or 

as a result of operation and maintenance on the plant site or along the in-scope transmission 

line corridors during the license renewal term. Based on the NRC staff’s independent review, 

the NRC staff concurs that refurbishment activities and operation and maintenance activities 

that FENOC might undertake during the renewal term, such as maintenance and repair of plant 

infrastructure (e.g., roadways, piping installations, onsite transmission lines, fencing, and other 

security infrastructure), likely would be confined to previously disturbed areas of the 

Davis-Besse site. Therefore, the NRC staff expects non-cooling system impacts on terrestrial 

resources during the license renewal term to be SMALL. 

4.8 Protected Species and Habitats

Section 2.2.7 of this SEIS describes protected species and habitats in the vicinity of the 

Davis-Besse site. Table 4.8-1 lists the one Category 2 issue related to protected species and 

habitats that is applicable to Davis-Besse. 
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Table 4.8-1. Protected Species Issues 

Issue GEIS Section Category

Threatened or endangered species 4.1 2

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

This site-specific, or Category 2 issue, requires consultation with the appropriate agencies to 

determine whether threatened or endangered species are present and whether they would be 

affected by continued operation of Davis-Besse during the license renewal term. In the case of 

Davis-Besse, the U.S. Fish and Wildlife Service (FWS) is responsible for terrestrial and 

freshwater species listed under the Endangered Species Act (ESA), the Bald and Golden 

Eagles Act, and the Migratory Bird Treaty Act (MBTA). The National Marine Fisheries Service 

(NMFS) is responsible for marine and anadromous species listed under the ESA. The Ohio 

Department of Natural Resources (ODNR) is responsible for species protected by the State of 

Ohio. Descriptions of protected species and habitats appear in Section 2.2.8 of this SEIS. 

4.8.1 Species Protected Under the Endangered Species Act. 

4.8.1.1 Chronology of Endangered Species Act Section 7 Consultation

The NRC staff corresponded with both the FWS and NMFS to determine impacts to Federally

listed species and to decide whether to initiate section 7 consultation as a result of the proposed

Davis-Besse license renewal. No species under the NMFS’s jurisdiction are present on the 

Davis-Besse site or within Lake Erie (NMFS 2010). Thus, NRC has no obligations under 

section 7 of the ESA for species under NMFS’s jurisdiction.

For species under FWS’s jurisdiction, the FWS provided information to FENOC on protected 

species in 2009 (FWS 2009) and confirmed that the information contained in their 2009 letter to 

FENOC remained current in a letter to the NRC in 2010 (FWS 2010). The NRC developed a list 

of Federally listed species potentially on or in the vicinity of the Davis-Besse site and requested 

concurrence on this list in a June 1, 2011, letter (NRC 2011a). Since that time, the NRC has 

defined the action area (see Section 2.2.8.1) and reviewed available information on the FWS’s 

Endangered Species Program Web site to ensure that it considers any newly listed species or 

updated information concerning species that could be affected by the proposed license renewal.

Following the publication of the draft SEIS, the NRC intends to submit the draft SEIS to FWS for 

concurrence in accordance with the ESA section 7 regulations at 50 CFR 402.12(j). The final 

SEIS will include an updated status of the section 7 consultation in this section. 

4.8.1.2 Species and Habitats Under NMFS’s Jurisdiction

No Federally listed or proposed species or proposed or designated critical habitat under the 

NMFS’s jurisdiction occur in the action area.

4.8.1.3 Species and Habitats Under FWS’s Jurisdiction

Section 2.2.8.1 discusses species and habitats protected under the ESA and within FWS’s 

jurisdiction that occur in Ottawa County and have the potential to occur in the action area. Of 

the four Federally listed species identified in Table 2.2-8 as occurring in Ottawa County, the 

NRC staff determined that three of these species—piping plover (Charadrius melodus), eastern 

prairie fringed orchid (Platanthera leucophaea), and lakeside daisy (Tetraneuris herbacea)—
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are very unlikely to occur in the action area based on habitat requirements or occurrence data. 

The NRC concludes that the proposed license renewal would have no effect on these species

based on the lack of suitable habitat and unlikelihood of occurrence in the vicinity of the 

Davis-Besse site (see Table 4.8-2). The remaining species, the Indiana bat (Sodalis myotis),

may occur in the action area. Table 4.8-2 lists the four Federally listed species and summarizes

the habitat, the likelihood of occurrence in the action area, and the NRC’s ESA effect 

determinations for each species.

Table 4.8-2. Summary of Impacts to Federally Listed Species

Scientific Name Common Name Habitat Suitable Habitat 

Present?(a)

Effect 

Determination(b)

Charadrius melodus piping plover nesting: N/A for Lake Erie

foraging: sandy beaches; 

mudflats

Yes No effect

Myotis sodalis Indiana bat hibernating: cool, humid 

caves; abandoned mines

roosting: dead trees with 

loose tree bark

foraging: forest edges; 

riparian zones

Yes

May affect, but is 

unlikely to 

adversely affect

Platanthera 

leucophaea

eastern prairie fringed 

orchid

mesic prairie; sage 

meadows; marsh edges; 

bogs

Yes No effect

Hymenoxy acaulis var. 

glabra

lakeside daisy dry, rocky prairie with full 

sun and limestone deposits No No effect

(a) This column indicates whether suitable habitat occurs in the action area as defined in Section 2.2.8.1. 

(b) Conclusions presented are consistent with effect determinations under the ESA: (1) no effect, (2) unlikely to adversely affect, or (3) 

likely to adversely affect.

Piping Plover (Charadrius melodus). The Davis-Besse site may provide marginal habitat for 

migrating piping plovers, but the occurrence of this species within the action area would be rare. 

The Black Swamp Bird Observatory (BSBO) has recorded this species as occurring within Lake 

Erie marsh region, which includes the Navarre Marsh on the Davis-Besse site, which FENOC

leases to the FWS for management as part of the Ottawa National Wildlife Refuge.

Continued operation and maintenance of the Davis-Besse site during the proposed license 

renewal term would not involve any construction, ground-disturbing activities or changes to 

existing land use conditions in either natural or developed areas. Thus, continued operation of 

Davis-Besse would not affect habitat or prey availability. Noise levels and human activity would 

remain similar to current operations and would not cause any additional disturbances that would 

cause piping plovers to avoid or abandon habitat within the action area. The NRC staff did not 

identify any direct or indirect adverse effects to piping plovers that would result from continued 

operation during the proposed license renewal term. Furthermore, the continued operation of 

Davis-Besse during the proposed license renewal term would preserve the existing habitats on 

the Davis-Besse site.

If piping plovers are observed on the Davis-Besse site by plant personnel, the NRC has 

measures in place to ensure that it would be notified so that the NRC staff could determine the 

appropriate course of action, such as possibly reinitiating section 7 consultation under the ESA 
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with the FWS at that time. The NRC’s regulations containing notification requirements that 

necessitate operating nuclear power reactors to report to the NRC within 4 hours “any event or 

situation, related to...protection of the environment, for which a news release is planned or 

notification to other government agencies has been or will be made” (10 CFR 50.72(b)(2)(xi)). 

Such notifications include reports regarding Federally listed species, as described in 

Section 3.2.12 of NUREG-1022, Event Reporting Guidelines for 10 CFR 50.72 and 50.73

(NRC 2013 ).

The NRC staff concludes that the proposed license renewal would have no effect on the piping 

plover.

Indiana Bat side (Sodalis myotis). The Indiana bat may occur within areas of suitable roosting 

and foraging habitat in the action area, such as riparian areas, grasslands, and meadows. As 

indicated in the discussion of impacts to the piping plover, the proposed license renewal term 

would not involve any construction, ground-disturbing activities or changes to existing land use 

conditions in either natural or developed areas. Tree removal as part of site or transmission line 

maintenance could affect the Indiana bat. However, FENOC’s (2011) Environmental Best 

Management Practices require FENOC staff to conduct all tree removal or disturbance from 

September 30 through April 1 when bats would not be in the region. If trees need to be 

removed during the summer months, FENOC’s procedure specifies that FENOC must conduct 

a net survey for those tree species that are likely to provide Indiana bat roosting habitat. 

FENOC must complete such surveys before disturbing any trees to ensure that the Indiana bat 

is not adversely affected. FENOC could also perform such maintenance in the fall or winter 

months when the Indiana bat has migrated to hibernation sites. Thus, this potential adverse 

impact would be insignificant because it is unlikely to result in a take.

If Indiana bats are observed on the Davis-Besse site by plant personnel, the measures in place 

to ensure that the NRC takes appropriate action upon identification of a Federally listed species 

on the Davis-Besse site (described previously for the piping plover) would apply for the Indiana 

bat as well.

The NRC staff concludes that the proposed license renewal may affect, but is unlikely to 

adversely affect, the Indiana bat. 

Eastern Prairie Fringed Orchid (Platanthera leucophaea). The eastern prairie fringed orchid 

may occur in areas of suitable habitat within the action area, such as mesic prairie, sage 

meadows, marsh edges, bogs, and other wetland habitats within Navarre Marsh. Though 

suitable habitat exists in the action area, during the NRC’s site audit (NRC 2011b), the FWS 

noted that it was unable to find any eastern prairie fringed orchid populations during a 2010 

survey within the Ottawa National Wildlife Refuge. Nonetheless, FWS’s continued management 

of the Navarre Marsh as part of the Ottawa National Wildlife Refuge would ensure that, if 

present, the eastern prairie fringed orchid would not be adversely affected. The NRC staff did 

not identify any direct or indirect adverse effects to this species that would result from continued 

operation during the proposed license renewal term.

The NRC staff concludes that the proposed license renewal would have no effect on the eastern 

prairie fringed orchid.

Lakeside Daisy (Tetraneuris herbacea). Suitable habitat for the lakeside daisy does not occur 

within the action area. Thus, the NRC staff concludes that the proposed license renewal would 

have no effect on the lakeside daisy.
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4.8.1.4 Critical Habitat and Proposed Species

As noted in Section 2.2.7 of this SEIS, no critical habitat occurs in the action area. Therefore, 

the proposed license renewal would have no effect on proposed or designated critical habitat. 

Additionally, no proposed species occur on the Davis-Besse site or along the transmission line 

corridors; therefore, the proposed license renewal would have no effect on any proposed 

species.

4.8.2 Species Protected Under the Bald and Golden Eagles Protection Act

Bald eagles (Haliaeetus leucocephalus) are relatively common in the vicinity of the Davis-Besse 

site. Several bald eagle nests are located on the Davis-Besse site. Two bald eagle nests are 

specifically located on the Davis-Besse site—one within Navarre Marsh and one northwest of 

the cooling tower near the site boundary (FWS 2010ms).

No activities on the Davis-Besse site would disturb bald eagles during the proposed license 

renewal term. Ground disturbing activities, increased noise and lighting, and other 

refurbishment impacts to bald eagles are discussed in Sections 3.2.1 and 3.2.2. Transmission 

line corridor maintenance has the potential to disturb eagles if trees with nests need to be 

trimmed or cut down. However, FENOC’s (2011) Environmental Best Management Practices

(discussed in Section 2.2.7) require that activities within 660 ft (200 m) of eagle nests that could 

disturb those nests be limited to August 1 through December 31, when eagles are least likely to 

be in the area. Additionally, the procedure requires FENOC to coordinate with the FWS to 

discuss potential mitigation options that could reduce or minimize impacts to eagles if activities 

must take place from January 1 through July 31. These specifications apply to the Davis-Besse 

site as well as the in-scope transmission line corridors. Additionally, the Bald and Golden Eagle 

Protection Act prohibits the taking of eagles without an FWS-issued eagle permit. Therefore, 

any activities that would require coordination per the procedures in FENOC’s Environmental 

Best Management Practices may also require an eagle permit under the Bald and Golden Eagle 

Act implementing regulations (50 CFR Part 22). As a result of these two processes, impacts to 

the bald eagle as a result of transmission line maintenance during the proposed renewal term 

would be minimal.

4.8.3 Species Protected Under the Migratory Bird Treaty Act

No activities associated with the proposed license renewal would directly impact migratory birds. 

Transmission line corridor maintenance has the potential to disturb migratory bird nests if trees 

or shrubs containing nests are trimmed or cut down. However, the MBTA only pertains to direct 

impacts to migratory birds and does not protect migratory bird habitat (as described in 

Section 2.2.7.3).

4.8.4 Species Protected by the State of Ohio

Many Ohio-listed species occur (or have been recorded as historically occurring) on and in the 

vicinity of the Davis-Besse site, including many species of birds, seven species of plants, five 

species of mussels, and three species of reptiles. These species are discussed in 

Section 2.2.8.4 of this SEIS. Section 4.14.4 discusses cumulative impacts on Ohio State-listed 

species.

In their correspondence with FENOC prior to FENOC’s submittal of the Davis-Besse license 

renewal application (LRA) to the NRC, the ODNR determined that the proposed license renewal 

would not impact any State-listed species because no tree removals, in-water work, or other 
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major construction activities would take place that might disturb the habitat of or otherwise 

impact any species (ODNR 2010). The NRC (NRC 2010a, 2010b) sent letters to the ODNR 

during its scoping process to confirm the information contained in ODNR’s previous letter to 

FENOC and to request any updated information concerning State-listed species. In a letter 

dated August 30, 2011 (ODNR 2011), the ODNR provided the NRC staff with its concurrence on 

this list. The ODNR provided no updated information concerning effects to State-listed species 

as a result of the proposed Davis-Besse license renewal. Based on correspondence with the 

ODNR and the NRC staff’s independent review, the NRC staff concludes that the proposed 

Davis-Besse license renewal will have no adverse impacts on any State-listed species.

4.8.5 Conclusion

The NRC staff concludes that the proposed Davis-Besse license renewal will have no adverse 

effects on three Federally protected species (piping plover, eastern prairie fringed orchid, and 

lakeside daisy) and may affect, but is unlikely to adversely affect, one species (Indiana bat). 

4.9 Human Health

Table 4.9-1 lists the human health issues identified in the GEIS. 

Table 4.9-1. Human Health Issues

Issue GEIS Section Category

Radiation exposures to the public during refurbishment 3.8.1(a) 1

Occupational radiation exposures during refurbishment 3.8.2(a) 1

Microbiological organisms (occupational health) 4.3.6 1

Microbiological organisms (public health, for plants using lakes or canals or 

cooling towers or cooling ponds that discharge to a small river) 4.3.6(b) 2 

Noise 4.3.7 1

Radiation exposures to public (license renewal term) 4.6.2 1

Occupation radiation exposures (license renewal term 4.6.3 1

Electromagnetic fields—acute effects (electric shock) 4.5.4.1 2

Electromagnetic fields—chronic effects 4.5.4.2 Uncertain

Human health impact from chemicals 4.9.1.1.2(c) 1

Physical occupational hazards 4.9.1.1.5(c) 1

(a) Issues apply to refurbishment, an activity that Davis-Besse plans to undertake.

(b) Issue applies to plants with features such as cooling lakes of cooling towers that discharge to a small river. This issue does not 

apply to Davis-Besse.

(c) NRC 2013: 78 FR 37282

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

4.9.1 Generic Human Health Issues

.The NRC staff has not identified any new and significant information during its independent 

review of the applicant’s ER (FENOC 2010), the site audit, the scoping process, or its evaluation 
Environmental Impacts of Operation

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of other available information that would change the conclusions in the GEIS (NRC 1996) for 

the Category 1 human health issues. For the Category 1 human health issues, the GEIS (NRC 

1996) concludes the impacts to be SMALL. For the new Category 1 issues identified in the 

2013 GEIS, human health impact from chemicals and physical occupational hazards, the 

impacts have been determined to be SMALL.

The information presented below is a discussion of new human health issues followed by a 

discussion of selected radiological programs conducted at Davis-Besse.

4.9.1.1 New Category 1 Human Health Issues

As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its 

environmental protection regulation, 10 CFR Part 51, governing environmental impact reviews 

of nuclear power plant operating renewed licenses (NRC 2013). With respect to the human 

health, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding 

two new Category 1 issues, “Human health impact from chemicals” and “Physical occupational 

hazards.” The first issue considers the impacts from chemicals to plant workers and members 

of the public. The second issue only considers the nonradiological occupational hazards of 

working at a nuclear power plant. An understanding of these nonradiological hazards to nuclear 

power plant workers and members of the public have been well established at nuclear power 

plants during the current licensing term. The impacts from chemical hazards are expected to be 

minimized through the applicant’s use of good industrial hygiene practices as required by 

permits and Federal and State regulations. Also, the impacts from physical hazards to plant 

workers will be of small significance if workers adhere to safety standards and use protective 

equipment as required by Federal and State regulations. The impacts to human health for each 

of these new issues from continued plant operations are SMALL.

The NRC staff has not identified any new and significant information related to these 

nonradiological issues during its independent review of applicant’s ER (FENOC 2010), the site 

audit, and the scoping process. Therefore, the NRC staff concludes that there would be no 

impact to human health from chemicals or physical hazards beyond those impacts described in 

Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 of the final rule; therefore, the impacts 

are SMALL.

4.9.1.2 Davis-Besse Radiological Environmental Monitoring Program

Davis-Besse conducts a Radiological Environmental Monitoring Program (REMP) to assess the 

radiological impact, if any, to its employees, the public, and the environment from its operations. 

The REMP measures the aquatic, terrestrial, and atmospheric environment for radioactivity, as 

well as the ambient radiation. In addition, the REMP measures background radiation 

(i.e., cosmic sources, global fallout, and naturally occurring radioactive material, including 

radon). The REMP supplements the Radioactive Effluent Monitoring Program by verifying that 

any measurable concentrations of radioactive materials and levels of radiation in the 

environment are not higher than those calculated using the radioactive effluent release 

measurements and transport models.

Radiation levels and radioactivity have been monitored within a 25-mi radius around 

Davis-Besse since 1972. The REMP was established at Davis-Besse about 5 years before the 

station became operational. This pre-operational sampling and analysis program provided data 

on radiation and radioactivity normally present in the area as natural background. Davis-Besse 

has continued to monitor the environment by sampling air, groundwater, milk, wild meat, fruit 
Environmental Impacts of Operation

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and vegetables, wild animal feed, drinking water, surface water, fish, and shoreline sediment, as 

well as through direct measurement of radiation.

The Davis-Besse REMP is made up of four categories based on the radiation exposure 

pathways to the public. The REMP collects and measures environmental media samples from 

the following: atmospheric, terrestrial, aquatic, and direct radiation. The air is sampled in areas 

around the plant site by measuring the levels of radioactive iodine and particulate matter on 

filters. Terrestrial monitoring includes the collection and analysis of milk, groundwater, meat, 

fruits, vegetables, animal feed, and soil samples. Aquatic monitoring includes the collection and 

analysis of drinking water, untreated surface water, fish, and shoreline sediment from the plant 

site and the vicinity of Lake Erie. Direct radiation is measured at various locations around the 

plant site using thermoluminescent Dosimeters (TLDs). In addition to the REMP, Davis-Besse 

began monitoring groundwater wells near the plant site in 2007, as part of the FENOC 

Groundwater Protection Initiative (GPI). The initiative is designed to determine whether there 

have been any inadvertent releases of radioactivity that have impacted groundwater or could 

potentially affect local water supplies. A detailed discussion of the GPI is contained in section 

2.2.5 of this SEIS. 

The NRC staff reviewed Davis-Besse’s annual radiological environmental operating reports for 

2008 through 2012 to look for any significant impacts to the environment or any unusual trends 

in the data (FENOC 2009a, 2010b, 2011a, 2012, 2013). The NRC staff uses a multi-year time 

period because it provides a data set that covers a broad range of activities that occur at a 

nuclear power plant such as; refueling outages, non-refueling outage years, routine operation, 

and years where there may be significant maintenance activities. Based on the NRC staff’s 

review of FENOC’s reports, no adverse trends (i.e., steadily increasing buildup of radioactivity 

levels) were observed and the data showed that there was no measurable impact to the 

environment from operations at Davis-Besse.

4.9.1.3 Davis-Besse Radioactive Effluent Release Program

All nuclear plants were licensed with the expectation that they would release radioactive 

material to both the air and water during normal operation. However, NRC regulations require 

that radioactive gaseous and liquid releases from nuclear power plants must meet radiation 

dose based limits specified in 10 CFR Part 20, and the as low as is reasonably achievable 

(ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation 

dose that members of the public can receive from radioactive material released by a nuclear 

power plant. In addition, nuclear power plants are required by 10 CFR 50.36(a) to submit an 

annual report to the NRC, which lists the types and quantities of radioactive effluents released 

into the environment. The radioactive effluent release and radiological environmental 

monitoring reports are available for review by the public through the Agencywide Documents 

Access and Management System (ADAMS) electronic reading room, which is available through 

the NRC Web site. 

The NRC staff reviewed the annual radioactive effluent release reports for 2008 through 2012 

(FENOC 2009b, 2010c, 2011b, 2012, 2013). The review focused on the calculated doses to a 

member of the public from radioactive effluents released from Davis-Besse. The doses were 

compared to the radiation protection standards in 10 CFR 20.1301, the ALARA dose design 

objectives in Appendix I to 10 CFR Part 50, and the EPA’s 40 CFR Part 190.

Dose estimates for members of the public are calculated based on radioactive gaseous and 

liquid effluent release data and atmospheric and aquatic transport models. The 2012 annual 

radioactive material release report (FENOC 2013) contains a detailed presentation of the 
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radioactive discharges and the resultant calculated doses. The following information 

summarizes the calculated maximum dose to a member of the public located outside the 

Davis-Besse site boundary from radioactive gaseous and liquid effluents released during 2012: 

• The maximum total body dose to an offsite member of the public from radioactive liquid 

effluents was 4.49x10-3 mrem (4.49x10-5 mSv), which is well below the 3 mrem 

(0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50.

• The maximum organ (liver) dose to an offsite member of the public from radioactive 

liquid effluents was 1.14x10-2 mrem (1.14x10-4 mSv), which is well below the 10 mrem 

(0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50.

• The maximum air dose at the site boundary from gamma radiation in gaseous effluents 

was 9.09x10-5 mrad (9.09x10-7 mGy), which is well below the 10 mrad (0.1 mGy) dose 

criterion in Appendix I to 10 CFR Part 50.

• The maximum air dose at the site boundary from beta radiation in gaseous effluents was 

1.58x10-4 mrad (1.58x10-6 mGy), which is well below the 20 mrad (0.2 mGy) dose 

criterion in Appendix I to 10 CFR Part 50.

• The maximum organ (thyroid) dose to an offsite member of the public from radioactive 

iodine and radioactive material in particulate form was 3.13x10-3 mrem (3.13x10-5 mSv), 

which is well below the 15 mrem (0.15 mSv) dose criterion in Appendix I to 

10 CFR Part 50.

• The maximum total body dose to an offsite member of the public from the combined 

radioactive releases (i.e., gaseous, liquid, and direct radiation) was 7.49x10-2 mrem 

(7.49x10-4 mSv), which is well below the 25 mrem (0.25 mSv) dose standard in 

40 CFR Part 190.

The NRC staff’s review of the Davis-Besse Radioactive Effluent Control Program showed that 

the radiation doses to members of the public from radioactive effluents were controlled within 

the Federal radiation protection standards contained in 10 CFR Part 20, Appendix I to 

10 CFR Part 50 and 40 CFR Part 190.

Routine plant operational and maintenance activities currently performed will continue during 

the license renewal term. Based on the past performance of the radioactive waste system to 

maintain the dose from radioactive effluents to be ALARA, similar performance is expected 

during the license renewal term.

The radiological impacts from the current operation of Davis-Besse, including those from 

refurbishment, are not expected to change significantly. Continued compliance with regulatory 

requirements is expected during the license renewal term; therefore, the impacts from 

radioactive effluents would be SMALL.

4.9.2 Electromagnetic Fields—Acute Effects

Based on the GEIS (NRC 1996), the NRC found that electric shock resulting from direct access 

to energized conductors or from induced charges in metallic structures has not been found to be 

a problem at most operating plants and generally is not expected to be a problem during the 

license renewal term. However, site-specific review is required to determine the significance of 

the electric shock potential along the portions of the transmission lines that are within the scope 

of this SEIS.
Environmental Impacts of Operation

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In the GEIS, the NRC staff found that without a review of the conformance of each nuclear plant 

transmission line with National Electrical Safety Code (NESC) criteria, it was not possible to 

determine the significance of the electric shock potential (IEEE 2002). 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 impact of the proposed action on the potential shock hazard from the 

transmission lines 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. The NRC uses the NESC criteria as its 

baseline to assess the potential human health impact of the induced current from an applicant’s 

transmission lines. As discussed in the GEIS, the issue of electric shock is of small significance 

for transmission lines that are operated in adherence with the NESC criteria.

Davis-Besse electrical output is delivered via three separate 345 kilovolt (kV) transmission lines 

to three different Toledo Edison substations. The Bay shoreline is about 21 mi long, extending 

from the Davis-Besse switchyard west and then northwest to Toledo Edison’s Bay Shore 

substation. The Lemoyne line also is about 21 mi long, extending from the Davis-Besse 

switchyard west and then southwest to Toledo Edison’s Lemoyne substation. The Beaver line 

is about 59 mi long, extending from the Davis-Besse switchyard south and then southeast to 

Ohio Edison’s Beaver substation.

The Bay Shore, the Lemoyne, and the Beaver transmission lines were constructed before the 

1977 NESC adoption of the 5 milliamperes (mA) provision for electric shock produced from 

induced currents. Therefore, FENOC conducted a screening analysis for each road crossing 

under the three transmission lines to determine conformance with the 5 mA NESC standard. 

FENOC’s evaluation of their transmission lines concluded that the induced current was less 

than the 5 mA NESC standard (FENOC 2010).

The Davis-Besse transmission line corridor consists of approximately 1,800 acres of primarily 

flat agricultural land for ROWs. FENOC conducts routine vegetation maintenance of its rural 

transmission line corridors approximately every 5 years. Maintenance includes removal or 

pruning of woody vegetation, as necessary, to ensure adequate line clearance and to allow 

vehicular access for maintenance (FENOC 2010).

The NRC staff reviewed the available information, including the applicant’s evaluation and 

results. Based on this information, and because the transmission lines are operated in 

adherence with NESC criteria, the NRC staff concludes that the potential impacts from electric 

shock during the renewal period would be SMALL.

4.9.3 Electromagnetic Fields—Chronic Effects

In the GEIS, the effects of chronic exposure to 60-hertz (Hz) electromagnetic fields from 

powerlines were not designated as Category 1 or 2 and will not be until a scientific consensus is 

reached on the health implications of these fields.

The potential effects of chronic exposure from these fields continue to be studied and are not 

known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs 

related research through the U.S. Department of Energy (DOE).
Environmental Impacts of Operation

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The report by NIEHS (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 continued 

emphasis on educating both the public and the regulated community on means 

aimed at reducing exposures. The NIEHS does not believe that other cancers or 

non-cancer health outcomes provide sufficient evidence of a risk to currently 

warrant concern.

This statement is not sufficient to cause the NRC staff to change its position with respect to the 

chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of 

“UNCERTAIN” still appropriate and will continue to follow developments on this issue.

4.10 Socioeconomics

The socioeconomic issues applicable to Davis-Besse are shown in Table 4.10-1 for Category 1 

and Category 2. Section 2.2.9 of this SEIS describes the socioeconomic conditions near 

Davis-Besse.

Table 4.10-1. Socioeconomics During the Renewal Term

Issues GEIS Section(s) Category

Housing impacts 4.7.1 2

Public services—public safety, social services, and tourism &

recreation

4.7.3; 4.7.3.3; 4.7.3.4; 

4.7.3.6

1

Public services—public utilities 4.7.3.5 2

Public services—education (license renewal term) 4.7.3.1 1

Public services—transportation 4.7.3.2 2

Aesthetic impacts (license renewal term) 4.7.6 1

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1

Environmental justice minority & low-income populations 4.10.1(a) 2

Offsite land use (license renewal term) 4.7.4 2

Historic & archaeological resources 4.7.7 2

(a) NRC 2013, 78 FR 37282. 

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996).

4.10.1 Generic Socioeconomic Issues

The Davis-Besse ER (FENOC 2010), scoping comments, other available data records on 

Davis-Besse were reviewed and evaluated for new and significant information. The review 

included a data gathering site visit to Davis-Besse. No new and significant information was 

identified during this review that would change the conclusions presented in the GEIS. 
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Therefore, for these Category 1 issues, impacts during the renewal term are not expected to 

exceed those discussed in the GEIS. Impacts for Category 2 and environmental justice, which 

was listed as an uncategorized issue in the 1996 rule (61 FR 28467), are discussed in Sections 

4.10.2 through 4.10.4, 4.11, 4.12, and 4-13. The NRC uses the existing socioeconomic 

conditions described in Section 2.2.9 of this SEIS as its baseline to evaluate the potential 

socioeconomic impacts resulting from license renewal. These baseline socioeconomic 

conditions include existing housing, transportation, offsite land use, demographic information, 

public services, and economic conditions affected by ongoing operations at the nuclear power 

plant.

4.10.2 Housing Impacts

Appendix C of the GEIS presents a population characterization method based on two factors—

sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 

within 20 mi (32 km) of the site, and proximity measures population density and city size within 

50 mi (80 km). Each factor has categories of density and size (GEIS, Table C.1). A matrix is 

used to rank the population category as low, medium, or high (GEIS, Figure C.1).

According to the 2000 Census, an estimated 129,411 people lived within 20 mi (32 km) of 

Davis-Besse, which equates to a population density of 169 persons per square mile (mi2

) 

(FENOC 2010). This translates to a Category 4, “least sparse,” population density using the 

GEIS measure of sparseness (greater than or equal to 120 persons per mi2 within 20 mi). An 

estimated 2,375,624 people live within 50 mi (80 km) of Davis-Besse with a population density 

of 316 persons per mi2 (FENOC 2010). Applying the GEIS proximity measures, Davis-Besse is 

classified as proximity Category 4 (greater than, or equal to, 190 persons per mi2 within 50 mi). 

Therefore, according to the sparseness and proximity matrix presented in the GEIS, rankings of 

sparseness Category 4 and proximity Category 4 result in the conclusion that the Davis-Besse 

is located in a high-population area.

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 

are expected to be of small significance in a medium or high-density population area where 

growth-control measures are not in effect. Since Davis-Besse is located in a high-population 

area and Lucas, Ottawa, Sandusky and Wood counties are not subject to growth-control 

measures that would limit housing development, any changes in employment at Davis-Besse 

would have little noticeable effect on housing availability in these counties. Since FENOC has 

no plans to add non-outage employees during the license renewal period, employment levels at 

Davis-Besse would remain relatively constant with no additional demand for permanent housing 

during the license renewal term. Based on this information, there would be no additional impact 

on housing during the license renewal term beyond what has already been experienced; 

therefore, the NRC staff concludes that the impact on housing would be SMALL. 

FENOC indicated in their ER (FENOC 2010) that the steam generators would be replaced 

during the license renewal term in 2017, however steam generator replacement is now 

scheduled to be done during the 2014 refueling outage. FENOC estimates that steam 

generator replacement would require a one-time increase in the number of refueling outage 

workers for up to 70 days (FENOC 2010). These additional workers would create an additional 

demand for temporary (rental) housing in the immediate vicinity of Davis-Besse. Steam 

generator replacement impacts are discussed in Chapter 3 of this SEIS. As a result of replacing 

the steam generators, there will be a one-time increase in the need for temporary housing for 

the additional workers. However, the NRC staff concludes that the overall impacts on housing 

due to steam generator replacement will remain SMALL.
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4.10.3 Public Services—Public Utilities

While the impact findings of SMALL, MODERATE and LARGE are defined in Section 1.4 of this 

SEIS, the definitions for these three findings are slightly different with respect to the impact on 

public utilities. Impacts on public utility services (e.g., water, sewer) are considered SMALL if 

the public utility has the ability to respond to changes in demand and would have no need to 

add or modify facilities. Impacts are considered MODERATE if service capabilities are 

overtaxed during periods of peak demand. Impacts are considered LARGE if additional system 

capacity is needed to meet ongoing demand.

Analysis of impacts on the public water systems considered both plant demand and 

plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and 

actual use of water for reactor cooling at Davis-Besse.

Since FENOC has no plans to add non-outage employees during the license renewal period, 

employment levels at Davis-Besse would remain relatively unchanged with no additional 

demand for public water services. Public water systems in the region are adequate to meet the 

demands of residential and industrial customers in the area. Therefore, there would be no 

additional impact to public water services during the license renewal term beyond what is 

currently being experienced.

As discussed in Section 4.9.2, FENOC indicated in their ER that steam generators would be 

replaced during the license renewal term in 2017, however steam generator replacement is now 

scheduled to be done during the 2014 refueling outage (FENOC 2010). The additional number 

of refueling outage workers needed to replace the steam generators would cause a short-term 

increase in the amount of public water and sewer services used in the immediate vicinity of 

Davis-Besse. The impacts to public utilities from refurbishment activities are discussed in 

Chapter 3 of this SEIS, and have been determined to be SMALL. 

4.10.4 Public Services—Transportation

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following:

Transportation impacts (level of service) of highway traffic generated...during the 

term of the renewed license are generally expected to be of SMALL significance. 

However, the increase in traffic associated with additional workers and the local 

road and traffic control conditions may lead to impacts of MODERATE or LARGE 

significance at some sites.

The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of 

highway traffic generated by the proposed project on the level of service of local highways 

during the term of the renewed license. Since FirstEnergy Davis-Besse has no plans to add 

non-outage employees during the license renewal period, traffic volume and levels of service on 

roadways in the vicinity of Davis-Besse would not change. Therefore, there would be no 

transportation impacts during the license renewal term beyond those already being 

experienced.

As discussed in Section 4.9.2, FENOC indicated in their ER that steam generators would be 

replaced during the license renewal term in 2017, however steam generator replacement is now 

scheduled to be done during the 2014 refueling outage (FENOC 2010). The additional number 

of refueling outage workers and truck material deliveries needed to support the replacement of 

the steam generators would cause a short-term transportation impact on access roads in the 
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immediate vicinity of Davis-Besse. The impacts to transportation from refurbishment activities

are discussed in Chapter 3 of this SEIS, and have been determined to be SMALL. 

4.11 Environmental Justice

As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

protection regulation, 10 CFR Part 51. With respect to environmental justice concerns, the final

rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

Category 2 issue, “Minority and low-income populations,” to evaluate the impacts of continued 

operations and any refurbishment activities during the license renewal term on minority

populations and low-income populations living in the vicinity of the plant. Environmental justice 

was listed in Table B-1 as a concern before this final rule, but it was not evaluated in the 1996 

GEIS and, therefore, is addressed in each SEIS. 

Under Executive Order (EO) 12898 (59 FR 7629), Federal agencies are responsible for 

identifying and addressing, as appropriate, disproportionately high and adverse human health 

and environmental impacts on minority and low-income populations. In 2004, the Commission 

issued a Policy Statement on the Treatment of Environmental Justice Matters in NRC 

Regulatory and Licensing Actions (69 FR 52040), which states, “The Commission is committed 

to the general goals set forth in EO 12898, and strives to meet those goals as part of its NEPA 

review process.” 

The Council of Environmental Quality (CEQ) provides the following information in Environmental 

Justice: Guidance Under the National Environmental Policy Act (CEQ 1997):

Disproportionately High and Adverse Human Health Effects. 

Adverse health effects are measured in risks and rates that could result in latent 

cancer fatalities, as well as other fatal or nonfatal adverse impacts on human 

health. Adverse health effects may include bodily impairment, infirmity, illness, or 

death. Disproportionately high and adverse human health effects occur when the 

risk or rate of exposure to an environmental hazard for a minority or low-income 

population is significant (as employed by NEPA) and appreciably exceeds the 

risk or exposure rate for the general population or for another appropriate 

comparison group (CEQ 1997).

Disproportionately High and Adverse Environmental Effects. 

A disproportionately high environmental impact that is significant (as employed 

by NEPA) refers to an impact or risk of an impact on the natural or physical 

environment in a low-income or minority community that appreciably exceeds the 

environmental impact on the larger community. Such effects may include 

ecological, cultural, human health, economic, or social impacts. An adverse 

environmental impact is an impact that is determined to be both harmful and 

significant (as employed by NEPA). In assessing cultural and aesthetic 

environmental impacts, impacts that uniquely affect geographically dislocated or 

dispersed minority or low-income populations or American Indian tribes are 

considered (CEQ 1997).

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority and low-income populations that 

could result from the operation of Davis-Besse during the renewal term. In assessing the 
Environmental Impacts of Operation

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impacts, the following definitions of minority individuals and populations and low-income 

population were used (CEQ 1997):

Minority Individuals. Individuals who identify themselves as members of the following 

population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or 

African American, Native Hawaiian or Other Pacific Islander, or two or more races, meaning 

individuals who identified themselves on a Census form as being a member of two or more 

races, for example, Hispanic and Asian.

Minority Populations. Minority populations are identified when (1) the minority population of an 

affected area exceeds 50 percent or (2) the minority population percentage of the affected area 

is meaningfully greater than the minority population percentage in the general population or 

other appropriate unit of geographic analysis.

Low-income Population. Low-income populations in an affected area are identified with the 

annual statistical poverty thresholds from the Census Bureau’s Current Population Reports, 

Series P60, on Income and Poverty.

Minority Population

According to 2010 Census data, approximately 23 percent of the U.S. population (approximately 

1,809,000 persons) residing within a 50-mi (80 km) radius of Davis-Besse identified themselves 

as minority individuals. The largest minority group was Black or African American 

(11.4 percent), followed by Hispanic or Latino (of any race) (7.0 percent) (CAPS 2012).

According to 2010 Census data, minority populations in the socioeconomic ROI (Lucas, Ottawa, 

Sandusky, and Wood) comprised 22.7 percent of the total four-county population (see 

Table 2.2-17). Persons identifying themselves as Black or African American comprised the 

largest minority race population at 13 percent of the combined total four-county population. 

Hispanic or Latinos comprised the next largest minority population at 5.9 percent (USCB 2012). 

Figure 4.11-1 shows minority block groups, using 2010 Census data for race and ethnicity, 

within 50-mi (80-km) radius of Davis-Besse that exceed 23 percent or more minority 

populations. 

Census block groups were considered minority population block groups if the percentage of the 

minority population within any block group exceeded 23 percent (the percent of the minority 

population within the 50-mi radius of Davis-Besse). A minority population block group exists if 

the percentage of the minority population within the block group is meaningfully greater than the 

minority population percentage in the 50-mi (80-km) radius. Of the approximately 1,629 census 

block groups located within the 50-mi radius of Davis-Besse, 504 block groups were found to 

have minority race population percentages that exceeded 23 percent or more. Minority 

population block groups are concentrated primarily in the Toledo and Detroit metropolitan areas, 

with smaller concentrations in Fremont and Sandusky in Ohio. The minority population nearest 

to Davis-Besse is located in Oak Harbor, Ohio.

Low-Income Population

According to 2010 Census data, approximately 15.4 percent of the U.S. population residing 

within a 50-mi (80 km) radius of Davis-Besse were identified as living below the Federal poverty 

threshold in 2010. The 2010 Federal poverty threshold was $22,314 for a family of four 

(USCB 2012). According to 2010 American Community Survey 1-year estimates, 11.8 percent 
Environmental Impacts of Operation

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of families and 15.8 percent of individuals in Ohio were living below the Federal poverty 

threshold in 2010, and the median household income for Ohio was $45,090 (USCB 2012). 

According to 2008-2010 American Community Survey 3-year estimates, Ottawa County had a 

higher median household income average ($51,712) and lower percentages of individuals 

(10 percent) and families (6.9 percent) living below the poverty level when compared to the 

state average. Conversely, Lucas County had the lowest median household income average 

($40,017) and highest percentage of individuals (19.1 percent) and families (14.9 percent) living 

below the poverty level when compared to the other three counties. Sandusky County had a 

median household income of $46,024 with 11.6 percent of individuals and 7.9 percent of 

families living below the poverty level. Wood County had the highest median household income 

($52,512) and the lowest percentage of families (7.3 percent) living below the poverty level 

amongst the four counties (USCB 2012).

Figure 4.11-2 shows low-income census block groups within a 50-mi (80 km) radius of 

Davis-Besse that exceeds 15.4 percent or more low-income populations. Census block groups 

were considered low-income population block groups if the percentage of individuals living 

below the Federal poverty threshold within any block group exceeded the percent of the 

individuals living below the Federal poverty threshold within the 50-mile radius of Davis-Besse. 

Approximately 582 of the 1,629 census block groups located within the 50-mile (80-kilometer) 

radius of Davis-Besse were determined to have meaningfully greater low-income populations.

Low-income population block groups appear evenly distributed throughout the 50-mi (80 km) 

radius including the block group that contains Davis-Besse. Similar to the locations of minority 

population block groups, the majority of low-income population block groups are located in the 

Toledo and Detroit metropolitan areas, with smaller concentrations in Fremont and Bowling 

Green, Ohio.
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Figure 4.11-1. Census 2010 Minority Block Groups Within a 50-mi Radius of Davis-Besse 

Source: USCB 2012
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Figure 4.11-2. Census 2010 Low-Income Block Groups Within a 50-mi Radius of 

Davis-Besse

Source: USCB 2012
Environmental Impacts of Operation

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Analysis of Impacts 

The NRC addresses environmental justice matters for license renewal through (1) identification 

of minority and low-income populations that may be affected by the proposed license renewal, 

and (2) examining any potential human health or environmental effects on these populations to 

determine if these effects may be disproportionately high and adverse.

The discussion and figures above identifies the minority and low-income populations residing 

within a 50-mi (80-km) radius of Davis-Besse. This area of impact is consistent with the impact 

analysis for public and occupational health and safety, which also focuses on populations within 

a 50-mi (80-km) radius of the plant. As previously discussed for the other resource areas in 

Chapter 4, the analyses of impacts for all environmental resource areas indicated that the 

impact from license renewal would be SMALL.

Potential impacts to minority and low-income populations (including migrant workers or Native 

Americans) would mostly consist of radiological effects; however radiation doses from continued 

operations associated with this license renewal are expected to continue at current levels, and 

would remain within regulatory limits. Chapter 5 of this SEIS discusses the environmental 

impacts from postulated accidents that might occur during the license renewal term, which 

include design basis accidents. The Commission has generically determined that impacts 

associated with such accidents are SMALL because the plant was designed to successfully 

withstand design basis accidents.

Therefore, based on this information and the analysis of human health and environmental 

impacts presented in Chapters 4 and 5, it is unlikely there would be any disproportionately high 

and adverse impacts to minority and low-income populations from the continued operation of 

Davis-Besse during the license renewal term.

Subsistence Consumption of Fish and Wildlife

As part of addressing environmental justice concerns associated with license renewal, the NRC 

also assessed the potential radiological risk to special population groups (such as minority and 

low-income populations, migrant workers, and Native Americans) from exposure to radioactive 

material received through their unique consumption and interaction with the environment. 

Patterns of exposure include subsistence consumption of fish, native vegetation, surface 

waters, sediments, and local produce; absorption of contaminants in sediments through the 

skin; and inhalation of airborne radioactive material released from the plant during routine 

operation. The special pathway receptors analysis is important to the environmental justice 

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in the area, such as migrant workers or Native Americans. 

This analysis is presented below.

Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

appropriate, to collect and analyze information on the consumption patterns of populations that 

rely principally on fish or wildlife for subsistence and to communicate the risks of these 

consumption patterns to the public. In this SEIS, NRC considered whether there were any 

means for minority or low-income populations to be disproportionately affected by examining 

impacts to Native Americans, Hispanics, migrant workers, and other traditional lifestyle special 

pathway receptors. Special pathways that took into account the levels of contaminants in native 

vegetation, crops, soils and sediments, groundwater, surface water, fish, and game animals on 

or near Davis-Besse were considered.
Environmental Impacts of Operation

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The following is a summary discussion of the NRC’s evaluation from Section 4.8.2 of the 

radiological environmental monitoring programs that assess the potential impacts for 

subsistence consumption of fish and wildlife near the Davis-Besse site.

FENOC has an ongoing comprehensive REMP at Davis-Besse to assess the impact of site 

operations on the environment. To assess the impact of the nuclear power station on the 

environment, samples of environmental media are collected and analyzed for radioactivity. Two 

types of samples are taken. The first type, control samples, is collected from areas that are 

beyond measurable influence of the nuclear plant. These samples are used as reference data. 

Normal background radiation levels, or radiation present due to causes other than nuclear 

power generation, can be compared to the environment surrounding the nuclear plant. Indicator 

samples are the second sample type obtained. These samples show how much radiation or 

radioactivity is contributed to the environment by the nuclear power plant. Indicator samples are 

taken from areas close to the station where any contribution will be at the highest concentration. 

An effect would be indicated if the radioactive material detected in an indicator sample was 

significantly larger than the background level or control sample.

Samples of environmental media are collected from the aquatic and terrestrial pathways in the 

vicinity of Davis-Besse. Over 2,000 radiological environmental samples were collected and 

analyzed in 2010. The aquatic pathways include groundwater, surface water, drinking water, 

fish, and shoreline sediment. The terrestrial pathways include airborne particulates, milk, food 

products (i.e., fruit apples and leafy vegetables such as kale and cabbage, are collected from 

gardens and farms in the vicinity of the Station), wild animal feed (i.e., edible portions of 

cattails), wild animal meat (i.e., waterfowl, deer, rabbits and muskrats), and leafy vegetation. 

During 2010, analyses performed on samples of environmental media showed no significant or 

measurable radiological impact above background levels from site operations (FENOC 2011).

Based on the radiological environmental monitoring data from Davis-Besse, the NRC finds that 

no disproportionately high and adverse human health impacts would be expected in special 

pathway receptor populations in the region as a result of subsistence consumption of water, 

local food, fish, and wildlife.

4.12 Offsite Land Use

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-1 notes that “significant changes in land use may 

be associated with population and tax revenue changes resulting from license renewal.” 

Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 

operation during the license renewal term as SMALL when there will be little new development 

and minimal changes to an area’s land-use pattern. It is defined as MODERATE when there 

will be considerable new development and some changes to the land-use pattern, and it is 

defined as LARGE when there will be 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 the following: 

• the size of the plant’s tax payments relative to the community’s total revenues, 

• the nature of the community’s existing land-use pattern, and
Environmental Impacts of Operation

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• 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 

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 tax payments are 10 to 20 percent of the community’s 

total revenue, new tax-driven land-use changes would be MODERATE. If tax payments are 

greater than 20 percent of the community’s total revenue, new tax-driven land-use changes 

would be LARGE. This would be especially true where the community has no pre-established 

pattern of development or has not provided adequate public services to support and guide 

development.

4.12.1 Population-Related Impacts

Since FENOC has no plans to add non-outage employees during the license renewal period, 

there would be no plant operations-driven population increase in the vicinity of Davis-Besse. 

Therefore, there would be no additional population-related offsite land use impacts during the 

license renewal term beyond those already being experienced.

As discussed in Section 4.9.2, FENOC indicated in their ER that steam generators would be 

replaced during the license renewal term in 2017 (FENOC 2010), however the steam 

generators will actually be replaced during the 2014 refueling outage.. Due to the short amount 

of time needed to replace the steam generators, the additional number of refueling outage 

workers would not cause any permanent population-related land use changes in the immediate 

vicinity of Davis-Besse. These impacts are discussed in Chapter 3 of this SEIS.

4.12.2 Tax Revenue-Related Impacts

As discussed in Chapter 2, FENOC pays property taxes for Davis-Besse to Ottawa County, 

Carroll Township, the Benton-Carroll-Salem School District, and the Penta County Joint 

Vocational School. Since FENOC started making property tax payments to local jurisdictions, 

population levels and land use conditions in Ottawa County have declined; therefore, tax 

revenue has had not any effect on land use activities within the county. For the 5-year period 

from 2005 through 2009, property tax payments to Ottawa County contributed less than 

10 percent of the total operating budget. Property tax payments to Carroll Township ranged 

from 11 to 28 percent of the operating budget, while payments to the Benton-Carroll-Salem 

School District averaged about 17 percent of the operating budget. Payments to the Penta 

County Joint Vocational School averaged 1.6 percent (FENOC 2010).

Since FirstEnergy Davis-Besse has no plans to add non-outage employees during the license 

renewal period, employment levels at Davis-Besse would remain relatively unchanged. There 

would be no increase in the assessed value of Davis-Besse, and annual property tax payments 

would also remain relatively unchanged throughout the license renewal period. Based on this 

information, there would be no additional tax-revenue-related offsite land use impacts during the 

license renewal term beyond those already being experienced.

As discussed in Section 4.9.2, FENOC indicated in their ER that steam generators would be 

replaced during the license renewal term in 2017 (FENOC 2010), however the steam 

generators will actually be replaced during the 2014 refueling outage. The replacement of the 
Environmental Impacts of Operation

4-29

existing steam generators could increase the assessed value of Davis-Besse, and property tax 

payments could increase. These and other tax-revenue related impacts associated with 

refurbishment are discussed in Chapter 3 of this SEIS. The NRC staff has determined there will 

be no noticeable effect on offsite land use .

4.13 Historic and Archaeological Resources

As listed in Table 4.10.1, historic and archaeological resources is a Category 2 issue, and 

therefore, the NRC staff is required to perform a site-specific review. The National Historic 

Preservation Act of 1966 (NHPA), as amended through 2000, requires Federal agencies to take 

into account the potential effects of their undertakings on historic properties. Historic properties 

are defined as resources that are eligible for listing on the National Register of Historic Places

(NRHP). The criteria for eligibility include the following (ACHP 2008):

• association with significant events in history; 

• association with the lives of persons significant in the past; 

• embodiment of distinctive characteristics of type, period, and construction; and

• association with or potential to yield important information. 

The historic preservation review process mandated by Section 106 of the NHPA is outlined in 

regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800.

The issuance of a renewed operating license for a nuclear power plant is a Federal undertaking 

that could possibly affect either known or currently undiscovered historic properties located on 

or near the plant site and its associated transmission corridors. In accordance with the 

provisions of the NHPA, the NRC is required to make a reasonable effort to identify historic 

properties in the area of potential effect. 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.

In accordance with 36 CFR 800.8(c), the NRC initiated Section 106 consultation with the ACHP 

and the Ohio SHPO in December 2010 by notifying them of the agency’s intent to conduct a 

review of a request from FENOC to renew Davis-Besse’s operating license 

(NRC 2010c, 2010d). Documentation for consultation with the ACHP and the Ohio SHPO is 

presented in Appendix D. As of the time of publication of this SEIS, the Ohio SHPO and ACHP 

have not responded to the NRC.

The NRC also initiated consultation with eight Federally recognized Native American tribes, 

notifying them of the proposed action and requesting comments and concerns (NRC 2010e). 

To date, one of the tribes, the Peoria Tribe of Indians of Oklahoma, has responded 

(Peoria Tribe of Indians of Oklahoma 2010). They indicated no objection to the undertaking, but 

asked to be contacted in the event skeletal remains were discovered within the area of potential 

effect. Documentation for tribal consultation is presented in Appendix D. As of the time of 

publication of this SEIS, the other seven tribes contacted have not responded to the NRC.

FENOC has not proposed any new facilities, service roads, or transmission lines to support 

continued operations at Davis-Besse. FENOC has formal guidelines in its Environmental 

Procedure (NOP-OP-2010 Revision 5) for protecting historic and archaeological resources and 

consulting with the SHPO prior to ground-disturbing activities. An additional procedure, FENOC 

Environmental Best Management Practices (NOBP-OP-2000 Revision 002) requires work to be 
Environmental Impacts of Operation

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stopped and consultation with the SHPO if any human remains or archaeological, cultural, or 

historic resource is encountered. These guidelines are in place to ensure that any 

archaeological resources that may be present receive consideration and protection. On 

Davis-Besse lands leased to the FWS, the FWS personnel have procedures in place to stop 

work upon the discovery of a cultural resource, protect the area from further disturbance, and 

contact the FWS Cultural Resource Specialist in their Minnesota office. It is the responsibility of 

the Cultural Resource Specialist to contact the Ohio SHPO should cultural resources be 

encountered.

As noted in Section 2.2.10.2, the potential for any significant historic and archaeological 

resources in this area is low. However, since no formalized survey has been conducted of the 

entire property and portions of the area are undisturbed, the potential for additional resources to 

be present on the property and disturbed during normal operations remains. The only historic or 

cultural resource recorded on Davis-Besse property by the Ohio SHPO was listed as not eligible 

for the NRHP. The Refuge Site, 33-OT-25, is situated on a small peninsula of dry land in the 

marshy area of the southeast corner of the property. This is a historic site consisting of nails, 

glass mason jar fragments, and a kaolin pipe fragment that has been determined to be ineligible 

for listing in the National Register of Historic Places (NRHP). There are no historic properties 

located on Davis-Besse property. 

Therefore, based on the NRC staff’s review of Ohio SHPO files, review of FENOC’s cultural 

resource management plan, and the potential for additional resources to be located on 

Davis-Besse property, NRC staff concludes that potential impacts from license renewal of 

Davis-Besse on historic and archaeological resources would be SMALL to MODERATE. There

would be no adverse effect on historic properties per 36 CFR 800.4(d)(1).

4.14 Evaluation of New and Potentially Significant Information

New and significant information is information that identifies a significant environmental issue 

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

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 Davis-Besse operating license, FENOC 

developed a process to ensure that information not addressed in or available during the GEIS 

evaluation regarding the environmental impacts of license renewal for Davis-Besse would be 

properly reviewed before submitting the ER. It also ensured that such new and potentially

significant information related to renewal of the operating license for Davis-Besse would be 

identified, reviewed, and assessed during the period of NRC review. FENOC 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 Davis-Besse. This review was 

performed by personnel from Davis-Besse and its support organization that 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 NUREG-1555, Supplement 1, Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 1999b). 

The search for new information includes the following:
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• review of an applicant’s ER and the process for discovering and evaluating the 

significance of new information; 

• review of records of public comments; 

• review of environmental quality standards and regulations; 

• coordination with Federal, State, and local environmental protection and resource 

agencies; and

• review of the technical literature. 

New information discovered by the NRC staff is evaluated for significance using the criteria set 

forth in the GEIS. For Category 1 issues where new and significant information is identified, 

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

relevant new and significant information. The scope of the assessment does not include other 

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

The NRC staff has not identified any new and significant information on environmental issues 

listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of 

Davis-Besse during the period of license renewal. The NRC staff also determined that 

information provided during the public comment period did not identify any new issues that 

require site-specific assessment. The NRC staff reviewed the discussion of environmental 

impacts in the GEIS (NRC 1996) and conducted its own independent review (including the 

public scoping meetings held in July 2008) to identify new and significant information.

4.15 Cumulative Impacts

As described in Section 1.4 of this SEIS, the NRC 

has approved a revision to its environmental 

protection regulation, 10 CFR Part 51. With 

respect to cumulative impacts, the final rule

amends Table B-1 in Appendix B, Subpart A, to 

10 CFR Part 51 by adding a new Category 2 

issue, “Cumulative impacts,” to evaluate the 

potential cumulative impacts of license renewal. 

The NRC staff considered potential cumulative impacts in the environmental analysis of 

continued operation of Davis-Besse during the 20-year license renewal period. Cumulative 

impacts may result when the environmental effects associated with the proposed action are 

overlaid or added to temporary or permanent effects associated with other past, present, and 

reasonably foreseeable actions. Cumulative impacts can result from individually minor, but 

collectively significant, actions taking place over time. It is possible that an impact that may be 

SMALL by itself could result in a MODERATE or LARGE cumulative impact when considered in 

combination with the impacts of other actions on the affected resource. Likewise, if a resource 

is regionally declining or imperiled, even a SMALL individual impact could be important if it 

contributes to or accelerates the overall resource decline.

For the purposes of this cumulative analysis, past actions are those before the receipt of the 

LRA. Present actions are those related to the resources at the time of current operation of the 

power plant, and future actions are those that are reasonably foreseeable through the end of 

plant operation including the period of extended operation. Therefore, the analysis considers 

Cumulative Impacts, as defined by CEQ in 

§1508.7, are the impacts on the environment 

which result from the incremental impact of the 

action when added to other past, present, and 

reasonably foreseeable future actions regardless 

of what agency (Federal or non-Federal) or 

person undertakes such other actions. 

Cumulative impacts can result from individually 

minor but collectively significant actions taking 

place over a period of time.
Environmental Impacts of Operation

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potential impacts through the end of the current license terms, as well as the 20-year renewal 

license term. The geographic area over which past, present, and reasonably foreseeable 

actions would occur is dependent on the type of action considered.

To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

in Sections 4.1 through 4.12, are combined with other past, present, and reasonably 

foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

undertakes such actions. The NRC staff used the information given in the ER (FENOC 2010); 

responses to requests for additional information; information from other Federal, State, and local 

agencies; scoping comments; and information gathered during the visits to the Davis-Besse site 

to note other past, present, and reasonably foreseeable actions. To be considered in the 

cumulative analysis, the NRC staff determined if the project would occur within the geographic 

areas of interest and within the period of extended operation, if it was reasonably foreseeable, 

and if there would be potential overlapping effect with the proposed action. For past actions, 

consideration within the cumulative impacts assessment is resource- and project-specific. In 

general, the effects of past actions are included in the description of the affected environment in 

Chapter 2, which serves as the baseline for the cumulative impacts analysis. However, past 

actions that continue to have an overlapping effect on a resource potentially affected by the 

proposed action are considered in the cumulative analysis. Other actions and projects that 

were noted during this review and considered in the NRC staff’s independent analysis of the 

potential cumulative effects are described in Table 4.15-1. 

Table 4.15-1. Other Projects and Actions Considered in the Cumulative Analysis for 

Davis-Besse

Project/Action Location Status 

Locust Point Firing Range; served as an 

anti-aircraft artillery range in support of 

the Erie Army Depot

Northeast of Davis-Besse, a portion of 

the site is within the eastern section of 

the Davis-Besse site

Closed in 1963; In 1996 & 2001, 

Davis-Besse personnel found 

ordnance rounds along the 

beach area near the mouth of the 

Toussaint River (FENOC 2010)

Camp Perry Military Reservation; site is

part of the Ohio National Guard

Between Davis-Besse & Port Clinton 

(6 mi southeast of Davis-Besse)

Operational (FENOC 2010)

Lake Erie Industrial Park Between Davis-Besse & Port Clinton 

(6 mi southeast of Davis-Besse)

Operational (FENOC 2010)

Cleveland-Toledo-Detroit Passenger 

Rail Line; addition to regional 

transportation hub with rail lines 

connecting Cleveland, Buffalo, Toronto, 

Pittsburgh, Cincinnati, & Detroit

Rail line would run from Cleveland to 

Toledo, passing through Ottawa 

County

Proposed; schedule 

undetermined (MHR 2011)

FWS Private Lands Program Northwestern Ohio Ongoing; total of 6,898 acres on 

801 sites across Ohio have been 

restored since program 

implementation (FWS 2011).

Energy projects

Independent Spent Fuel Storage 

Installation on Davis-Besse site; dry 

spent-fuel storage

Davis-Besse site Spent fuel storage at 1,624 fuel 

assemblies and additional 

temporary storage of 90 fuel 

assemblies in the fuel transfer pit 

(NRC 2001)

Fremont Energy Center; 540 megawatts Sandusky Township, Ohio (15 mi In construction; operations 
Environmental Impacts of Operation

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Project/Action Location Status 

(MW) natural gas-fired combined-cycle 

electric generating plant, with a peaking 

capacity of 704 MW

south of Davis-Besse) projected to begin in mid-2012 

(OPSB 2011a) 

Bay Shore Plant; 648 MW of electricity 

produced from three coal-fired units, 

one petroleum coke-fired unit, & one oilfired unit 

Maumee Bay in Oregon, Ohio (16 mi 

northwest of Davis-Besse)

Operational (Feco 2007)

Toledo Refinery Substation Project; 

construction of a new 138/69 kV 

substation to provide additional 

electrical power & improved reliability to 

the BP-Husky Refinery

Oregon, Ohio, near the intersection of 

(19 mi west of Davis-Davis-Besse) 

Proposed (OPSB 2011b)

Troy Energy Facility; 600 MW gas 

turbine peaking plant

Lemoyne Industrial Park, Troy 

Township, Ohio (20 mi southwest of 

Davis-Besse)

Operations began in 2002 

(OPSB 2003)

J.R. Whiting Power Plant; 328 MW coalfired plantOn Lake Erie in Luna Pier, MI (23 mi 

northeast of Davis-Besse)

Operational (CE 2011)

Detroit Edison Monroe Power Plant; 

3,280 MW coal-fired plant

On Lake Erie in Monroe, MI (24 mi 

northeast of Davis-Besse)

Operational (DTE 2011a)

Fermi Nuclear Power Plant, Unit 1 Near Monroe, MI, on Lake Erie (27 mi 

northeast of Davis-Besse)

Not operational; proposed 

decommissioning & demolition of 

the plant (DTE 2011b)

Fermi Nuclear Power Plant Unit 2; 

1,098 MW nuclear power plant

Near Monroe, MI, on Lake Erie (27 mi 

northeast of Davis-Besse) 

Operational (DTE 2011b)

Fermi Nuclear Power Plant Unit 3; 

1,535 MW proposed nuclear reactor 

Near Monroe, MI, on Lake Erie (27 mi 

northeast of Davis-Besse)

Proposed; operations could 

begin as early as 2021 

(DTE 2011b)

Independent spent fuel storage 

installation on Fermi site; dry spent-fuel 

storage

Near Monroe, MI, on Lake Erie (27 mi 

northeast of Davis-Besse)

Proposed (DTE 2011b)

4.15.1 Cumulative Impacts on Air Quality

The following analysis considers potential impacts through the end of the current license term 

as well as the 20-year renewal license term. In evaluating the potential impacts on air quality 

associated with license renewal, the NRC staff uses as its baseline the existing air quality 

conditions described in Section 2.2.2.1 of this SEIS. These baseline conditions encompass the 

existing air quality conditions (EPA’s NAAQS county designations) potentially affected by air 

emissions from the continued operations and refurbishment activities. As described in 

Section 2.2.2.1, Ottawa County—where Davis-Besse is located—is designated in attainment for 

CO, Pb, NO2, PM10, PM2.5 and is not designated for SO2 (OEPA 2013). Lucas and Wood 

counties, abutting Ottawa County to the west, are designated as maintenance area for 8-hour 

ozone NAAQS. The nearest non-attainment area is Monroe County1 in Michigan, for PM2.5

NAAQS, which is northwest of Ottawa County. 

 

1 Michigan Department of Environmental Quality finds that, based in part on air quality monitoring data collected in the 2007 

through 2010 period, all its counties are currently in compliance with the PM2.5 standards and has drafted a letter to the U.S. EPA 

requesting that it make a determination that Southeast Michigan is in attainment with the PM2.5 NAAQS (see 

http://www.michigan.gov/documents/deq/deq-aqd-draft-SE-redesignation_pm2.5v9_350980_7.pdf).
Environmental Impacts of Operation

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Currently, Davis-Besse is operating under one air permit for an auxiliary boiler but exempt for 

emergency generators. Davis-Besse is applying for a “synthetic minor” permit to OEPA, which 

covers the sitewide emission sources. Davis-Besse operations comply with its air pollution 

control permit application, and FENOC has no plans that would change this practice for the 

license renewal term (FENOC 2010). Annual emissions of criteria pollutants, volatile organic 

compounds (VOCs), and hazardous air pollutants (HAPs) at Davis-Besse vary from year to year 

but are well below the threshold for a major source (see Table 2.2-1). Accordingly, air 

emissions from continued operation of the plant and associated impacts on ambient air quality 

would not be expected to change during the license renewal period. Considering the location of 

nearby non-attainment and maintenance areas and the prevailing southwesterly wind direction 

in the area, these emissions are not anticipated to deteriorate the current nonattainment and 

maintenance status. Minor and short-duration air quality impacts can be expected to occur 

during the steam generator replacement project activities. The main contributors to air quality 

impacts associated with completed and ongoing refurbishment activities would be fugitive dust 

generation from facility construction activities, refurbishment work to open the shield building 

and containment vessel to replace the steam generators and related equipment, and exhaust 

emissions from motorized equipment and vehicles of temporary workers.

Combustion-related greenhouse gas (GHG) emissions (such as CO2, CH4, and N2O) at 

Davis-Besse are minor, given the nature of a nuclear facility that is not burning fossil fuels to 

generate electricity. As discussed in Section 2.2.2.1, GHG stationary emission sources at the 

station include primarily auxiliary boilers, small and large emergency diesel generators, and 

miscellaneous diesel-powered equipment. These combustion sources are designed for 

efficiency and operated using good combustion practices on a limited basis throughout the year 

(i.e., often only for testing). Other combustion-related GHG emission sources at Davis-Besse 

include commuter, visitor, support, and delivery vehicle traffic within, to, and from the plant. In 

addition, small amounts of HFCs, PFCs, and sulfur hexafluoride (SF6) might be released into the 

atmosphere during normal operations or at various stages of the equipment’s life cycle. 

In April 2012, EPA published the official U.S. inventory of GHG emissions, which finds and 

quantifies the primary anthropogenic sources and sinks of GHGs. EPA reported that, in 2010, 

the total amount of carbon dioxide equivalent2 (CO2e) emissions related to electricity generation 

was 2,277.3 teragrams (2,277.3 MMT) (EPA 2012). The EIA reported that, in 2010, electricity 

production in Ohio was responsible for 121 teragrams of CO2 emissions (121 MMT CO2e) 

(EIA 2012). The NRC staff estimates that annual carbon dioxide equivalent emissions from 

operation at Davis-Besse amount to 4,693 MT/year.

In Ohio, Senate Bill 221, Alternative Energy Portfolio Standard (AEPS) and Energy Efficiency 

Portfolio Standard (EEPS)—which establishes annual benchmarks for renewable energy and 

energy efficiency—was signed into law on May 1, 2008 (Ohio Department of 

Development 2011). SB 221 requires Ohio investor-owned utilities to meet both AEPS and 

EEPS by 2025. The AEPS includes requirements for renewable energy sources to supply 

12.5 percent of electricity demand, and the EEPS will achieve a cumulative, annual energy 

savings in excess of 22 percent. Ohio’s renewable energy standard requires at least 6,000 MW 

of new wind and solar capacity. Solar photovoltaics, of about 450 to 800 MW, will be deployed 

or delivered to the State due to the 0.5 percent solar requirement.

 

2 Carbon dioxide equivalent (CO2e) is a measure used to compare the emissions from various GHGs on the basis on their global 

warming potential (GWP), defined as the cumulative radiative forcing effects of a gas over a specified time horizon resulting from the 

emission of a unit mass of gas relative to a reference gas, CO2. The CO2e for a gas is derived by multiplying the mass of the gas by 

the associated GWP. For example, the GWP for CH4 is estimated to be 21; thus, one ton of CH4 emission is equivalent to 21 tons 

of CO2 emissions.
Environmental Impacts of Operation

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Based on all of the above information, the NRC staff concludes that combined with the 

emissions from other past, present, and reasonably foreseeable future actions, cumulative 

impacts of criteria and hazardous air pollutants on ambient air quality from operations at 

Davis-Besse would be SMALL. 

4.15.2 Cumulative Impacts on Water Resources

This section addresses the direct and indirect effects of license renewal on water resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. Water availability and water quality are both considered. The geographic area 

considered in this analysis is defined for groundwater as an area within a 3-mi (5-km) radius of 

the site, groundwater impacts to tributaries for impacts to Lake Erie, and, for surface water, as 

Lake Erie in its entirety.

4.15.2.1 Groundwater

The U.S. Global Change Research Program predicts an increase in precipitation intensity in 

winter and spring, with more frequent heavy downpours. The increased intensity of storms will 

likely cause faster runoff rates and a reduction in overall recharge of groundwater and aquifers. 

As documented in the Lake Erie Lakewide Management Plan (LAMP) the reduction in 

groundwater recharge due to the increase of spring runoff has resulted in a reduction in summer 

groundwater base flows. In addition, the continued human use and consumption of 

groundwater resources reduced water tables and consequently reduced spring water flow to 

rivers and streams that feed into Lake Erie (EPA 2008). 

Although Davis-Besse has not withdrawn groundwater since construction-phase dewatering,

60 percent of all Ottawa County residents rely on groundwater (Graham et al., 1997). As a 

result, NRC staff concludes that the impact to groundwater quantity is MODERATE due to the 

noticeable cumulative impacts due to urbanization and climate change. The direct and indirect 

impacts from continued operation of Davis-Besse however would be SMALL.

Groundwater quality in the vicinity of the site may be affected by point source pollution, such as 

industries or septic tanks, and non-point source pollution, such as agricultural chemical usage 

and lawn chemicals (Graham et al. 1997). In a study summarized by Graham et al. (1997), 

nitrate-nitrogen (a common agricultural chemical) results from a county-wide Groundwater 

Sampling Program were found to be below the safe drinking water standard of 10 ppm. As 

described in Section 2.2.5, groundwater at Davis-Besse has been shown to have tritium 

elevated above background but well below the drinking water standard. Tritium concentrations 

have been decreasing. Petroleum products have been released onsite but are not believed to 

have traveled offsite, and they have undergone partial remediation. Other operational or 

planned projects or industries, such as those in Table 4.15-1, could affect groundwater quality 

but likely would not result in significant, widespread groundwater impacts, especially within 

several miles of Davis-Besse.

The NRC staff concludes that the cumulative impacts on groundwater quality from the proposed 

license renewal and other past, present, and reasonably foreseeable projects would be SMALL. 

The direct and indirect impacts from continued operation of Davis-Besse on groundwater quality 

would also be SMALL.
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4.15.2.2 Surface Water

The water of Lake Erie is a valuable resource both in the relatively shallow western basin 

adjacent to Davis-Besse and across the entire lake. Public supply systems in Ottawa County 

relying on surface water (mainly from Lake Erie) withdraw an average of 3,447,000 gallons per 

day (Graham et al. 1997). The intake for Toledo, OH, is 12 mi west of Davis-Besse; average 

withdrawal is 77,800,000 gallons per day (FENOC 2010d). In total, U.S. and Canadian annual 

Lake Erie water use was over 56,543 MGD in 2004, with 54,723 MGD as power plant 

withdrawals and 1,106 MGD as public-supply withdrawals (GLC 2006). In 2004, the total 

consumptive use was 485 MGD (GLC 2006). Active or proposed projects, such as those listed 

in Table 4.15-1, have the potential to consume large amounts of lake water, especially for 

cooling systems at power plants. In addition to the projects listed, other industries relying on 

Lake Erie water will be operating in the U.S. and Canada during the license renewal term.

Climate change has the potential to affect water resources available for cooling systems and the 

impact of reactor operations on water resource availability for other users. A recent compilation 

of the state of the knowledge in this area (USGCRP 2009) projects the changes in the climate 

for the region of interest during the license renewal period to include an increase in average 

temperature. Precipitation is expected to increase slightly in the winter and spring, with more 

intense rainstorms year-round. The average level of Lake Erie could decrease more than a foot 

(more than 0.3 m) due to increased evaporation caused by the warmer temperatures, resulting 

in a decrease of the lake’s volume. As discussed in 2.1.7.1, the intake is about 14 ft (4.3 m) 

below the lake surface, so operations should be able to continue. However, warmer lake water 

would result in increased cooling water use by power plants. The impact from climate change 

could be measureable in Lake Erie, and these changes are potentially significant (Figure 4.15-2

and Figure 4.15-3). 

 

Figure 4.15-2. Projected Changes in Lake Levels Under a High Emission Scenario

Source: USGCRP 2009
Environmental Impacts of Operation

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Figure 4.15-3. Observed Changes in Great Lakes Ice Cover, Seasonal Maximum Coverage 

1973–2008

Source: USGCRP 2009

Point and non-point sources of pollution have affected the water quality of the western basin of 

Lake Erie. Ottawa County rivers and creeks, including the Toussaint River, are affected by 

non-point source contamination (Graham et al. 1997). Sources include channelization, sanitary 

landfills, urbanization, silviculture, livestock, and agricultural production. These rivers and 

creeks are tributaries to Lake Erie. Similar issues have the potential to affect water quality from 

numerous other Lake Erie tributaries located in Ohio, Pennsylvania, New York, and Ontario. 

The two main water quality concerns in Lake Erie are increased phosphorus loading, which can 

cause toxic algal blooms, and elevated concentrations of the bioaccumulative contaminants 

dioxin, polychlorinated biphenyls (PCBs), and mercury (Brannan 2009; Hartig et al. 2007). In 

the ER (FENOC 2010), over 200 facilities were identified that have an NPDES permit to 

discharge in the four-county (Ottawa, Lucas, Wood, Sandusky) area closest to Davis-Besse. 

These discharges are generally made to Lake Erie or its tributaries. Numerous other 

dischargers are present in the Lake Erie watershed in the U.S. and Canada.

The EPA’s Great Lakes National Program Office has initiated the Great Lakes Restoration 

Initiative (EPA 2011e), a consortium of 11 Federal agencies that developed an action plan to 

address environmental issues. These issues fall into five areas—cleaning up toxics and areas 

of concern, combating invasive species, promoting nearshore health by protecting watersheds 

from polluted runoff, restoring wetlands and other habitats, and tracking progress and working 

with strategic partners. This long-term initiative includes the water quality concerns of Lake 

Erie.

Climate change, discussed above, could affect surface water quality in the region 

(USGCRP 2009). Greater storm intensity could increase erosion and sediment loads in 

tributaries of Lake Erie. Lower lake levels could magnify factors such as sediment loading, 

phosphorous loading, and bioaccumulative contaminants. The thermal plume from power plant 
Environmental Impacts of Operation

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cooling systems would increase, and a reduced lake volume would result in a larger thermal 

mixing zone. Warmer average lake water temperature would result in increased water usage 

for cooling systems, further increasing the thermal plumes. These changes are potentially 

significant.

The NRC staff concludes that cumulative impacts on surface water resources in the geographic 

area of interest from the proposed license renewal and other past, present, and reasonably 

foreseeable actions would be SMALL to MODERATE. However, the overall direct and indirect 

impacts from the proposed license renewal would be SMALL and would not noticeably alter 

onsite or adjacent water bodies, including Lake Erie.

4.15.3 Cumulative Impacts on Aquatic Resources

This section addresses the direct and indirect effects of license renewal on aquatic resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. The geographic area considered in the cumulative aquatic resources analysis includes 

the western basin of Lake Erie, along which the Davis-Besse site is located.

Consistent with other agencies’ and CEQ’s (1997) NEPA guidance, the term “baseline” pertains 

to the condition of the resource without the action (i.e., under the no-action alternative). Under 

the no-action alternative, the plant would shutdown, and the resource would conceptually return 

to its condition without the plant (which is not necessarily the same as the condition before the 

plant was constructed). The baseline, or benchmark, for assessing cumulative impacts on 

aquatic resources takes into account the pre-operational environment as recommended by the 

EPA (1999) for its review of NEPA documents:

Designating existing environmental conditions as benchmark may focus the 

environmental impact assessment too narrowly, overlooking cumulative impacts 

of past and present actions or limiting assessment to the proposed action and 

future actions. For example, if the current environmental condition were to serve 

as the condition for assessing the impacts of relicensing a dam, the analysis 

would only identify the marginal environmental changes between the continued 

operation of the dam and the existing degraded state of the environment. In this 

hypothetical case, the affected environment has been seriously degraded for 

more than 50 years with accompanying declines in flows, reductions in fish 

stocks, habitat loss, and disruption of hydrologic functions. If the assessment 

took into account the full extent of continued impacts, the significance of the 

continued operation would more accurately express the state of the environment 

and thereby better predict the consequences of relicensing the dam.

The geographic area considered in the cumulative aquatic resources analysis includes the 

western basis of Lake Erie, along which the Davis-Besse site is located.

Sections 2.2.5 and 2.2.7 present an overview of the condition of Lake Erie near Davis-Besse 

and the history and factors that led to its current condition.

Invasive Species. Invasive species have caused dramatic shifts in fish populations in the lake 

and have resulted in the extirpation of many species (see Section 2.2.5). Invasive species have 

irreversibly altered the Lake Erie ecosystem and will continue to affect Lake Erie fish and 

invertebrate populations in the foreseeable future. Ballast water releases have introduced about 

30 percent of the invasive species in the Great Lakes today (EPA 2011e). The U.S. Coast 

Guard is in the process of developing ballast water discharge standards, which would limit the 
Environmental Impacts of Operation

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introduction of additional exotic species in the future. However, the existing exotic species in 

the Lake Erie system will continue to affect the ecosystem balance in the future. Zebra mussels 

(Dreissena polymorpha) and quagga mussels (D. rostriformis bugensis) outcompete native 

species. These mussels clog the intake pipes and cooling systems of power plants and make 

efforts to recover native mussel and clam populations difficult. The sea lamprey is attributed to 

the collapse of lake trout (Salvelinus namaycush), whitefish (Coregonus clupeaformis), and 

chub (Couesius plumbeus) populations, which has negatively affected the fishing economy 

(GLFC 2000). The Lake Erie Lakewide Management Plan (EPA 2008) includes management 

objectives and measures to reduce the impact of current invasive species on the lake’s 

ecosystem and prevent new exotic species from entering the lake.

Fishing. Fishing has been a major influence on commercially and recreationally sought fish 

species within Lake Erie. The ODNR manages the fishing of the 19 harvested fish species in 

the lake, which are discussed in Section 2.2.5. Many native fish species have suffered 

population declines due to invasive species. The most acute declines have been those of the 

lake trout, whitefish, and chub beginning in the 1940s and 1950s (GLFC 2000). The walleye 

population recovered considerably in the 1980s but has since declined. Continued fishing of 

these and other fish will slow the recovery of those species in decline.

Energy Development. Many energy-producing facilities are located near Davis-Besse (see ) 

that affect aquatic resources. Fermi Nuclear Power Plant, the Bay Shore Plant, J.R. Whiting 

Power Plant, and the Detroit Edison Monroe Power Plant all use Lake Erie as a source of 

cooling water. Though each plant’s impact on aquatic populations for impingement, 

entrainment, and thermal discharge is individually small, the cumulative impact may result in 

disproportionate loss of nearshore species and those species with pelagic (buoyant) eggs, 

which are more likely to be swept into the intake. Proposed energy-producing facilities—such 

as the proposed new unit at Fermi Nuclear Power Plant, Fremont Energy Center, and others 

listed in —will likely increase this cumulative impact.

Urbanization and Shoreline Development. About one-third of the Great Lakes population 

(11.6 million people) lives within the Lake Erie watershed (EPA 2008). Given that Lake Erie is

also the smallest Great Lake, it has experienced the most dramatic effects from urbanization 

and shoreline development. Lake Erie was the first Great Lake to experience massive algal 

blooms and depleted oxygen levels characteristic of a eutrophic environment. Beginning in the 

1950s, phosphorus and oxygen levels from developed and agricultural runoff became a major 

concern in the lake. In the 1970s, industrialization and chemical production became another 

stressor to the lake and resulted in an additional source of contaminants. Phosphorus levels 

decreased in the 1980s due to various control measures and monitoring but began to increase 

again in the 1990s (EPA 2008). Filling of Lake Erie’s wetland and marshes (discussed in 

Section 4.11.2) exacerbated the lake’s nutrient imbalances. Today, many programs and 

initiatives, including the Great Lakes Water Quality Agreement, are helping to restore the 

integrity of the lake, but Lake Erie continues to be significantly altered by past changes in land 

use and continued urban development.

Climate Change. The potential cumulative effects of climate change on Lake Erie could result in 

a variety of changes that would affect aquatic resources. The U.S. Global Change Research 

Program (USGCRP) (2009) identified higher temperatures as a major concern for the Great 

Lakes because it will cause more evaporation and, thus, likely reduce the Great Lakes water 

levels. In turn, reduced amount of lake ice would form in the winter, exacerbating the 

evaporation (USGCRP 2009). Lower water levels could ultimately contribute to loss of species; 
Environmental Impacts of Operation

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loss of habitat, especially nearshore spawning areas; and increased concentrations of 

contaminants (USGCRP 2009).

Conclusion. The NRC staff examined the cumulative effects of historical conditions of Lake 

Erie’s western basin and the impacts from invasive species, fishing, energy development, 

urbanization and shoreline development, and climate change. While the aquatic impacts 

associated with the continued operation of Davis-Besse are SMALL, the NRC staff believes that 

the factors discussed in this section—especially invasive species and urban development—

have led to LARGE cumulative impacts to Lake Erie aquatic resources.

4.15.4 Cumulative Impacts on Terrestrial Resources

This section addresses the direct and indirect effects of license renewal on terrestrial resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. The geographic area considered in this analysis is the Davis-Besse site and in-scope 

transmission line corridors.

Section 2.2.6 presents an overview of the current condition of the Davis-Besse site and in-scope 

transmission line corridors and the history and factors that led to its current condition. At 

present, the area is predominantly wetlands, much of which is managed by the FWS as part of 

the Ottawa National Wildlife Refuge. The 733 ac (297 ha) leased to the FWS connect other 

marsh areas within the Ottawa National Wildlife Refuge network and serve as vital habitat for 

migrating bird species and wetland-dependent wildlife.

Historical Conditions. Historically, the Great Black Swamp in northwestern Ohio covered an 

area about the size of the State of Connecticut. The USGS (1999) estimates that wetland 

drainage of Lake Erie marshes likely began in 1836, and Ohio’s swamp forests were heavily 

logged for a mix of birch, ash, elm, oak, cottonwood, poplar, maple, basswood, and hickory. 

Settlers also cleared many of the forests and filled in wetlands to create land for building houses 

and cultivating crops (UT, undated). To fill in the wetlands, series of ditches were dug to drain 

the land, which caused a drastic reduction in wetland-dependent species’ populations.

Protected Species. Sections 2.2.8 and 4.7 discuss protected species. Many protected species 

occur on the Davis-Besse site including many species of migratory birds and six species of 

Ohio-listed plants. Additionally, the Davis-Besse site and transmission line corridors have the 

potential to provide habitat for four Federally listed species (see Section 4.7), as well as other 

State-listed amphibians, reptiles, insects, and mammals. The Davis-Besse site and 

transmission line corridors, as well as the network of wetlands within the Ottawa National 

Wildlife Refuge, will continue to provide habitat for protected species. However, other factors 

discussed in this section—such as invasive species, habitat fragmentation, and climate 

change—may reduce the population sizes of some protected species and force species to 

compete for more limited resources in the future.

Invasive Species. Invasive species are non-native species that thrive outside of their natural 

range due to favorable environmental conditions and a lack of natural predators or other 

environmental controls. Invasive species are able to colonize and rapidly spread, threatening 

the success of native species populations in the process. The invasive purple loosestrife 

(Lythrum salicaria), reed canary grass (Phalaris arundinacea), common reed (Phragmites 

australis), and flowering rush (Butomus umbellatus) occur on the Davis-Besse site. Additionally, 

many non-native insect and other wildlife species occur in the region. As discussed in 

Section 2.2.6, the FWS maintains portions of the Ottawa National Wildlife Refuge, including 

Navarre Marsh on the Davis-Besse site, for invasive plant species through a variety of methods. 
Environmental Impacts of Operation

4-41

Continued efforts to control these species will help to protect native species populations in the 

future. However, the high number of invasive plant and pest species in Ohio—138 and 21, 

respectively (EFETAC 2011)—means that some invasive species that are not currently in the 

Davis-Besse region will likely spread to this area in the future.

Energy Development. Table 4.15-1 summarizes many energy development projects that are in 

operation now as well as those that are planned for future operation including, coal-fired plants, 

gas-fired plants, and one nuclear facility (Fermi Nuclear Power Plant). Coal-fired plants are a 

major source of air pollution in the U.S. because they release sulfur dioxide, nitrogen oxides, 

mercury, carbon dioxide, and particulates. Nitrous oxides and sulfur dioxides combine with 

water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury 

deposits onto soil and surface water, which may then be taken up by terrestrial and aquatic 

plant or animal species and poses the risk of bioaccumulation. Gas-fired plants also emit 

nitrogen oxides and carbon dioxide but at a lower rate than coal-fired plants. Gas-fired plants 

can also emit methane, a GHG, if the natural gas is not burned completely. Impacts on the 

terrestrial environment from Fermi Nuclear Power Plant can be expected to be similar to those 

from Davis-Besse, as discussed in Section 4.6.

Urbanization and Habitat Fragmentation. As the region surrounding Davis-Besse becomes 

more developed, habitat fragmentation will increase. Species that require larger ranges, 

especially predators, will likely suffer reductions in their populations. In contrast, herbivores will 

experience less predation pressure, and their populations are likely to increase. Edge species 

will likely benefit from the fragmentation, while species that require interior forest or swamp 

habitat will likely suffer. The transmission line corridors established for Davis-Besse’s 

transmission lines represent habitat fragmentation, though many of these corridors pass through 

cultivated land that has already been converted from its native habitat. Habitat fragmentation of 

surrounding areas may increase the value of the network of wetlands within the Ottawa National 

Wildlife Refuge, part of which is on the Davis-Besse site, because this land will not experience 

fragmentation or other human-induced impacts.

Habitat Restoration. The FWS has worked to convert a total of 6,898 ac on 801 sites across 

northwestern Ohio to native wetlands through the FWS Private Lands Program (FWS 2011). As 

part of this effort, the FWS is in the process of acquiring an 800-ac parcel of farmland through a 

fee title adjacent to Metzger Marsh in Lucas County (GLRC 2009). The U.S. Army Corps of 

Engineers is developing a program to convert and restore 200 ac of Lake Erie coastal wetland 

habitat along Maumee Bay near Toledo (GLRC 2009). The U.S. Army Corps of Engineer’s 

Great Lakes Habitat Restoration Database lists 32 other restoration or habitat enhancement 

projects within the Great Lakes region of Ohio. The cumulative effect of these programs will 

strengthen the overall integrity of terrestrial habitats and provide connectivity between habitat 

areas.

Climate Change. The U.S. Global Climate Change Research Program (USCGRP 2009) 

predicts that rainfall within the midwestern States will intensify in the winter and spring, which 

could lead to increased runoff and erosion, especially within habitat adjacent to developed, 

impervious surfaces and riparian areas. In contrast, rainfall will decrease in the summer 

months, and increased average temperatures will lead to increased evaporation rates and 

longer period between rainfalls (USCGRP 2009). Summer drought conditions will likely lead to 

a reduced area of wetland habitat. Given the high value of wetlands in the Davis-Besse region 

for dozens of migrating bird species, the reduction in wetland habitat could negatively affect 

certain migrating bird species populations as they compete with one another for limited 

resources within a reduced area of land. Changing climate conditions will also cause many 
Environmental Impacts of Operation

4-42

native wildlife species to shift their ranges and allow invasive species, especially pest insects 

that are now controlled by harsh winters, to become more successful colonizers and grow into 

larger populations (USCGRP 2009).

Conclusion. As stated in Section 4.7.1, the NRC staff concluded that the impacts associated 

with the Davis-Besse license renewal are SMALL. However, the NRC staff examined the 

cumulative effects of historical conditions at the Davis-Besse site, protected species, invasive 

species, urbanization and habitat fragmentation, and climate change. The NRC staff believes 

that the cumulative impact of the historical draining of wetlands and loss of forested swamps—

when added to present conditions and future impacts from urban development, habitat 

fragmentation, and climate change—will result in loss of habitat and a decline in species 

diversity of MODERATE impact to the terrestrial environment.

4.15.5 Cumulative Human Health Impacts

4.15.5.1 Radiological

The NRC and EPA established radiological dose limits for protection of the public and workers 

from both acute and long-term exposure to radiation and radioactive materials. As discussed in 

Section 4.8.1, the doses resulting from operation of Davis-Besse are below regulatory limits, 

and the impacts of these exposures would be SMALL. For the purposes of this analysis, the 

geographical area considered is the area included within an 50 mi (80 km) radius of the 

Davis-Besse site.

EPA regulations in 40 CFR Part 190 limit the annual cumulative radiation 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 to 25 mrem 

(0.25 mSv). The NRC staff’s review of radioactive releases from Davis-Besse shows that the 

annual radiation dose to the public has been less than 1.0 mrem (0.01 mSv). This dose is well 

within the NRC’s and EPA’s radiation protection standards. In addition, as discussed in 

Section 4.8.1, Davis-Besse conducts an REMP around its site. The program measures 

radiation and radioactive materials in the environment from Davis-Besse and all other sources

(i.e., other nuclear power plants as well as other licensed users of radioactive material). 

Therefore, the REMP would monitor any cumulative impacts. As discussed in Section 4.8.1, the 

NRC staff reviewed the historical radiological environmental monitoring results for Davis-Besse 

and found no significant environmental impact associated with the operation of the plant.

Davis-Besse operates an independent spent fuel storage installation (ISFSI) on the plant site. 

There is currently one other uranium fuel cycle facility within a 50-mi (80 km) radius of 

Davis-Besse that can contribute to the cumulative radiological impacts. The Fermi Nuclear 

Power Plant, Units 1 and 2, are located near Monroe, MI, on Lake Erie, approximately 27 mi 

northeast of Davis-Besse. Fermi Nuclear Power Plant, Unit 1, is non-operational and 

undergoing decommissioning. Fermi Nuclear Power Plant, Unit 2, is a 1,098 MW operating 

nuclear power plant, licensed by the NRC. Proposed projects on the Fermi plant site include 

the construction and operation of a 1,535 MW nuclear power plant (Fermi Nuclear Power Plant, 

Unit 3) and an ISFSI for dry storage of spent nuclear fuel.

The currently-operating facilities and proposed new nuclear facilities at the Fermi plant site 

would contribute to the cumulative radiological impacts in the vicinity of the Davis-Besse site. 

However, as discussed above, the cumulative radiological impacts from all uranium fuel cycle 

facilities in proximity to each other are limited to the radiation protection standards in 

10 CFR Part 20 and 40 CFR Part 190.
Environmental Impacts of Operation

4-43

Based on the NRC staff’s review of Davis-Besse’s radioactive effluent and environmental 

monitoring data, the information on the refurbishment of the reactor vessel head, the proposed 

steam generator replacement, and the expected continued compliance with Federal radiation 

protection standards, the cumulative radiological impacts from the operation of Davis-Besse and 

its ISFSI and the present and future radiological impacts from the Fermi plant site during the 

renewal term would be SMALL. The NRC will regulate any future nuclear power facility 

construction and operation near the Davis-Besse site that could contribute to cumulative 

radiological impacts. In addition, the State of Ohio will regulate facilities using radioactive 

material licensed by the State. Therefore, the NRC staff concludes that the cumulative 

radiological impacts to human health from the continued operation of Davis-Besse, including the 

nuclear facilities discussed above, during the license renewal term would be SMALL.

4.15.5.2 Microbiological Organisms 

This section addresses the direct and indirect effects of license renewal on Human Health due 

to the presence of microbiological organisms when added to the aggregate effects of other past, 

present, and reasonably foreseeable future actions. The geographic area considered in this 

analysis is Lake Erie.

Because of the Davis-Besse scoping process, public comments informed the NRC staff of the 

cyanobacterial effects occurring on Lake Erie. Although several forms of bacteria and algae 

exist within Lake Erie two nuisance species, Microcystis aeruginosa and Lyngbya wollei, were 

the species of greatest concern. Farm fertilizer runoff and sewage overflows

In the 1960s and 1970s, the cyanobacterial blooms were a yearly occurrence. The blooms 

were visibly apparent due to the aqua colored shoreline trim and thick blankets in offshore 

waters. The implementation of phosphorus controls resulted in the reduction of Lake Erie’s 

phosphorous levels and the blooms ultimately disappeared. Suddenly and unexpectedly, in 

1995, the blooms reappeared dominated by Microcystis aeruginosa. The blooms did not return 

in 1996 or 1997, but have been present every year thereafter since 1998. In 2006, blooms of 

Lyngbya wollei were present along the shoreline of Maumee Bay and have since been recurrent 

in various severities. Lyngbya wollie, although known to exist in Lake Erie, had never been 

documented in bloom proportions within Lake Erie prior to the initial occurrence in 2006 The 

origin of the blooms is not known but is likely related to farm fertilizer runoff and sewage 

overflows (EPA 2008). 

Some species of cyanobacteria, for instance Microcystis aeruginosa, release toxins into the 

water. Humans can be affected by these toxins with symptoms such as, skin irritation, stomach 

cramps, vomiting, nausea, diarrhea, fever, sore throat, headache, muscle and joint pain, blisters 

of the mouth and liver damage. Partaking in recreational activities including and similar to 

swimming in water bodies, where the toxins are present, may result in allergic reactions, such 

as asthma, eye irritation, rashes, and blisters around the mouth and nose. The World Health 

Organization (WHO) has documented cases resulting in skin rashes from contact with 

Microcystis aeruginosa (WHO 1999). 

Current operation of Davis-Besse has not been linked to the presence or growth of the 

cyanobacteria in Lake Erie. Based on the reported health effects from contact of the 

cyanobacteria, NRC staff concludes that the cumulative impact on human health because of the 

presence of microbiological organisms is MODERATE.
Environmental Impacts of Operation

4-44

4.15.5.3 Electromagnetic Fields

For electromagnetic fields, the NRC staff concludes that the Davis-Besse transmission lines are 

operating within NESC criteria, and the impacts would be SMALL. Any additional transmission 

lines would be required to meet the NESC criteria. 

For the effects of chronic exposure to extremely low frequency-electromagnetic fields 

(ELF-EMFs), although the GEIS finding of “UNCERTAIN” is appropriate for Davis-Besse, the 

transmission lines associated with Davis-Besse are unlikely to significantly contribute to the 

regional exposure to ELF-EMFs.

Therefore, the NRC staff has concluded that the cumulative impacts of continued operation of 

the Davis-Besse transmission lines and other lines in the area would be SMALL. 

4.15.6 Cumulative Socioeconomic Impacts

This section addresses socioeconomic factors that have the potential to be directly or indirectly 

affected by changes in operations at Davis-Besse in addition to the aggregate effects of other 

past, present, and reasonably foreseeable future actions. The primary geographic area of 

interest considered in this cumulative analysis is Lucas, Ottawa, Sandusky, and Wood counties 

where approximately 87.5 percent of Davis-Besse employees reside (FENOC 2010). This area 

is where the economy, tax base, and infrastructure would most likely be affected since 

Davis-Besse employees and their families reside, spend their income, and use their benefits 

within these counties.

As discussed in Section 4.9 of this SEIS, continued operation of Davis-Besse during the license 

renewal term would have no impact on socioeconomic conditions in the region beyond those 

already experienced. Since FENOC has no plans to hire additional workers during the license 

renewal term, overall expenditures and employment levels at Davis-Besse would remain 

relatively constant with no additional demand for permanent housing and public services. In 

addition, since employment levels and tax payments would not change, there would be no 

population or tax revenue-related land use impacts. Based on this and other information 

presented in Chapter 4 of this SEIS, there would be no additional contributory effect on 

socioeconomic conditions in the future from the continued operation of Davis-Besse during the 

license renewal term beyond what is currently being experienced.

FENOC indicated in their ER that steam generators would be replaced during the license 

renewal term in 2017 but will be replacing the steam generators during the 2014 refueling 

outage. FENOC estimates that steam generator replacement would require a one-time 

increase in the number of refueling outage workers for up to 70 days (FENOC 2010). These 

additional workers would create a one-time short-term increase in the demand for temporary 

(rental) housing and increased use of public water and sewer services and transportation 

impacts on access roads in the immediate vicinity of Davis-Besse. Given the short amount of 

time needed to replace the steam generators, the additional number of refueling outage workers 

and truck material deliveries needed to support this one-time replacement of the steam 

generators could have a temporary cumulative effect on socioeconomic conditions in the vicinity 

of the nuclear plant. However, there would be no long-term cumulative socioeconomic impacts 

from the steam generator replacement in the region. The NRC staff concludes that the 

cumulative socioeconomic impacts of continued operation of Davis-Besse would be SMALL.
Environmental Impacts of Operation

4-45

4.15.7 Cumulative Historic and Archaeological Impacts

It does not appear likely that the proposed license renewal would adversely affect cultural 

resources at Davis-Besse. Any ground-disturbing activities that would occur during the license 

renewal term are unlikely to result in the loss of historic and archaeological resources, provided 

that the existing earth-moving procedures to protect presently undiscovered resources are 

implemented and because the disturbance of known historic and archaeological resources in 

coastal or inland areas are unlikely to occur. However, as noted in Section 2.2.9, there is 

potential for additional cultural resources to be present in the undisturbed areas in the southern 

portions of the site. Therefore, prior to any ground-disturbing activity in an undisturbed area, it 

is expected that the applicant would evaluate the potential for impacts on historic and 

archaeological resources according to their procedures and in consultation with the SHPO and 

appropriate Native American Tribes, as required under Section 106 of the NHPA. In the vicinity 

of Davis-Besse and its transmission lines, some projects have the potential to affect historic and 

archaeological resources, such as new or expanded road systems or pipeline construction; 

however, linear projects have some flexibility in the siting process and can typically avoid 

significant cultural resources, minimizing the potential for impact.

The NRC staff concludes that, when combined with past, present, and reasonably foreseeable 

future actions, the cumulative impact on historic and archaeological resources by continued 

operation of Davis-Besse during the license renewal period would be SMALL and would not 

result in the loss of historic and cultural resources. 

4.15.8 Cumulative Impacts of Environmental Justice

The environmental justice cumulative impact analysis assesses the potential for 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations that could result from past, present, and reasonably foreseeable future 

actions including Davis-Besse operations during the renewal term. Adverse health effects are 

measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. 

Disproportionately high and adverse human health effects occur when the risk or rate of 

exposure to an environmental hazard for a minority or low-income population is significant and 

exceeds the risk or exposure rate for the general population or for another appropriate 

comparison group. Disproportionately high environmental effects refer to impacts or risk of 

impact on the natural or physical environment in a minority or low-income community that are 

significant and appreciably exceeds the environmental impact on the larger community. Such 

effects may include biological, cultural, economic, or social impacts. Some of these potential 

effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and 

low-income populations are subsets of the general public residing in the area, and all would 

exposed to the same hazards generated from Davis-Besse operations. As previously discussed 

in this chapter, the impact from license renewal for all resource areas (e.g., land, air, water, 

ecology, and human health) would be SMALL.

As discussed in Section 4.10 of this SEIS, there would be no disproportionately high and 

adverse impacts to minority and low-income populations from the continued operation of 

Davis-Besse during the license renewal term. Since FENOC has no plans to hire additional 

workers during the license renewal term, employment levels at Davis-Besse would remain 

relatively constant with no additional demand for housing or increased traffic. Based on this 

information, and the analysis of human health and environmental impacts presented in 

Chapters 4 and 5, it is unlikely that there would be any disproportionately high and adverse 
Environmental Impacts of Operation

4-46

contributory effect on minority and low-income populations from the continued operation of 

Davis-Besse during the license renewal term.

Potential impacts to minority and low-income populations from refurbishment-related plant 

modifications (steam generator replacement) at Davis-Besse would mostly consist of 

environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing 

impacts). Radiation doses from plant operations after steam generator replacement are 

expected to remain at current levels and well within regulatory limits.

Noise and dust impacts during steam generator replacement would be short-term and limited to 

onsite activities at Davis-Besse. Minority and low-income populations residing along siteaccess roads would experience increased commuter vehicle traffic during shift changes. In 

addition, increased demand for rental housing during the refueling outages and steam generator 

replacement at the Davis-Besse could disproportionately affect low-income populations. 

However, due to the short duration of this refurbishment activity and the availability of rental 

housing in the four-county ROI, impacts to minority and low-income populations would be 

short-term and limited. According to American Community Survey 3-year estimates for 

2008 through 2010, there were a combined total of over 39,000 vacant housing units in Lucas, 

Ottawa, Sandusky, and Wood counties (USCB 2012).

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the steam generator replacement would not have any long-term 

cumulative disproportionately high and adverse human health and environmental operational 

effects on minority and low-income populations residing in the vicinity of Davis-Besse.

4.15.9 Summary of Cumulative Impacts

The NRC staff considered the potential impacts resulting from operation of Davis-Besse during 

the period of extended operation and other past, present, and future actions in the vicinity of 

Davis-Besse. The preliminary determination is that the potential cumulative impacts would 

range from SMALL to MODERATE depending upon the resource area (Table 4.15-4). 

Table 4.15-4. Summary of Cumulative Impacts on Resource Areas 

Resource Area Impact Discussion

Air Quality SMALL

Considering the distance to nearby non-attainment and 

maintenance areas and the prevailing southwesterly wind 

direction in the area, GHG emissions are not anticipated to 

deteriorate the current nonattainment/maintenance status. 

Accordingly, air emissions from continued operation of the 

plant and associated impacts on ambient air quality would not 

be expected to change during the license renewal period.

Water Resources

Groundwater SMALL 

Although Davis-Besse has not withdrawn groundwater since 

construction-phase dewatering, 60 percent of all Ottawa 

County residents rely on groundwater. Groundwater quality 

in the vicinity of the site may be affected by point source 

pollution, such as industries or septic tanks, and non point 

source pollution, such as agricultural chemical usage and 

lawn chemicals. Other operational or planned projects or 

industries, could affect groundwater quality but likely would 

not result in significant, widespread groundwater impacts, 

especially within several miles of Davis-Besse.

Water Resources SMALL to Precipitation is expected to increase slightly in the winter and 

spring, with more intense rainstorms year round. The 
Environmental Impacts of Operation

4-47

Resource Area Impact Discussion

Surface water MODERATE average level of Lake Erie could decrease more than a foot 

(more than 0.3 m) due to increased evaporation caused by 

the warmer temperatures, resulting in a decrease of the 

lake’s volume. Warmer lake water would result in increased 

cooling water use by power plants

Aquatic Resources LARGE

The impact on aquatic resources from only the Davis-Besse 

license renewal has been determined to be SMALL. 

However, factors, such as invasive species, fishing, energy 

development, urbanization and shoreline development have 

led to LARGE cumulative impacts to Lake Erie aquatic 

resources.

Terrestrial Resources MODERATE

The cumulative impact of the historical draining of wetlands 

and loss of forested swamps—when added to present 

conditions and future impacts from urban development, 

habitat fragmentation, and climate change—will result in loss 

of habitat and a decline in species diversity. 

Human Health—Radiological SMALL

The cumulative radiological impacts from all uranium fuel 

cycle facilities in proximity to each other are limited to the 

radiation protection standards in 10 CFR Part 20 and 40 CFR 

Part 190. 

Human Health—

Microbiological Organisms MODERATE

Some species of cyanobacteria, for instance Microcystis 

aeruginosa, release toxins into the water. Humans can be 

affected by these toxins with symptoms such as, skin 

irritation, stomach cramps, vomiting, nausea, diarrhea, fever, 

sore throat, headache, muscle and joint pain, blisters of the 

mouth and liver damage. Partaking in recreational activities 

including and similar to swimming in water bodies, where the 

toxins are present, may result in allergic reactions, such as 

asthma, eye irritation, rashes, and blisters around the mouth 

and nose.

Human Health—

Electromagnetic Fields SMALL The cumulative impacts from Davis-Besse’s transmission would be SMALL.

Socioeconomics SMALL

FENOC has no plans to hire additional workers during the 

license renewal term, overall expenditures and employment 

levels at Davis-Besse would remain relatively constant with 

no additional demand for permanent housing and public 

services. In addition, since employment levels and tax 

payments would not change, there would be no population or 

tax revenue related land use impacts. 

Historic & Archaeological SMALL

Prior to any ground disturbing activity in an undisturbed area, 

it is expected that the applicant would evaluate the potential 

for impacts according to their procedures and in consultation 

with the SHPO and appropriate Native American Tribes, as 

required under Section 106 of the NHPA. 

Environmental Justice SMALL

FENOC has no plans to hire additional workers during the 

license renewal term, employment levels at Davis-Besse 

would remain relatively constant with no additional demand 

for housing or increased traffic. 

4.16 References

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Protection Against Radiation.” 
Environmental Impacts of Operation

4-48

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 

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36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

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40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

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50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, “Eagle 

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5-1 

1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

2 This chapter describes the environmental impacts from postulated accidents that might occur 

3 during the period of extended operation. The term “accident” refers to any unintentional event 

4 outside the normal plant operational envelope that results in a release or the potential for 

5 release of radioactive materials into the environment. Two classes of postulated accidents are 

6 evaluated in the generic environmental impact statement (GEIS). These are design-basis 

7 accidents (DBAs) and severe accidents. Table 5.1-1 notes the issues related to postulated 

8 accidents.

9 Table 5.1-1. Issues Related to Postulated Accidents. 

10 Two issues related to postulated accidents are evaluated under National Environmental Policy 

11 Act (NEPA) in the license renewal review, DBAs, and severe accidents.

Issue Category 

DBAs 1

Severe accidents 2

12 5.1 Design-Basis Accidents

13 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 

14 power facility, an applicant for an initial operating license must submit a safety analysis report 

15 (SAR) as part of its application. The SAR presents the design criteria and design information for 

16 the proposed reactor and comprehensive data on the proposed site. The SAR also discusses 

17 various hypothetical accident situations and the safety features that are provided to prevent and 

18 mitigate accidents. The NRC staff reviews the application to determine whether the plant 

19 design meets the Commission’s regulations and requirements and includes, in part, the nuclear 

20 plant design and its anticipated response to an accident.

21 DBAs are those accidents that both the applicant and the NRC staff evaluate to ensure that the 

22 plant can withstand normal and abnormal transients, and a broad spectrum of postulated 

23 accidents, without undue hazard to the health and safety of the public. Many of these 

24 postulated accidents are not expected to occur during the life of the plant, but are evaluated to 

25 establish the design basis for the preventive and mitigative safety systems of the facility. The 

26 acceptance criteria for DBAs are described in Title 10 of the Code of Federal Regulations (CFR) 

27 Part 50 (10 CFR Part 50) and 10 CFR Part 100. 

28 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 

29 ability of the plant to withstand these accidents is demonstrated to be acceptable before 

30 issuance of the operating license. The results of these evaluations are found in applicant

31 documentation such as the applicant’s final safety analysis report (FSAR), the safety evaluation 

32 report (SER), the final environmental statement (FES), and Section 5.1 of this supplemental 

33 environmental impact statement (SEIS). An applicant is required to maintain the acceptable 

34 design and performance criteria throughout the life of the plant, including any extended-life 

35 operation. The consequences for these events are evaluated for the hypothetical maximum 

36 exposed individual; as such, changes in the plant environment will not affect these evaluations. 

37 Because of the requirements that continuous acceptability of the consequences and aging 

38 management programs be in effect for the period of extended operation, the environmental 

39 impacts as calculated for DBAs should not differ significantly from initial licensing assessments 
Environmental Impacts of Postulated Accidents

5-2 

1 over the life of the plant, including the period of extended operation. Accordingly, the design of 

2 the plant relative to DBAs during the period of extended operation is considered to remain 

3 acceptable, and the environmental impacts of those accidents were not examined further in the 

4 GEIS.

5 The Commission has determined that the environmental impacts of DBAs are of SMALL 

6 significance for all plants because the plants were designed to successfully withstand these 

7 accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 

8 Category 1 issue. The early resolution of the DBAs makes them a part of the current licensing 

9 basis of the plant; the current licensing basis of the plant is to be maintained by the applicant

10 under its current license and, therefore, under the provisions of 10 CFR 54.30, is not subject to 

11 review under license renewal. 

12 No new and significant information related to DBAs was identified during the review of the 

13 Davis-Besse Nuclear Power Station’s (Davis-Besse’s) Environmental Report (ER) 

14 (FENOC 2010), the site audit, the scoping process, or the evaluation of other available 

15 information. Therefore, there are no impacts related to these issues beyond those discussed in 

16 the GEIS. 

17 5.2 Severe Accidents

18 Severe nuclear accidents are those that are more severe than DBAs because they could result 

19 in substantial damage to the reactor core, whether or not there are serious offsite 

20 consequences. In the GEIS, the staff assessed the impacts of severe accidents during the 

21 license renewal period, using the results of existing analyses and site-specific information to 

22 conservatively predict the environmental impacts of severe accidents for each plant during the 

23 renewal period.

24 Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, 

25 fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and 

26 were not specifically considered for the Davis-Besse site in the GEIS (NRC 1996). However, 

27 the GEIS did evaluate existing impact assessments performed by NRC and by the industry at 

28 44 nuclear plants in the U.S. and concluded that the risk from beyond design basis earthquakes 

29 at existing nuclear power plants is SMALL. The GEIS for license renewal performed a 

30 discretionary analysis of terrorist acts in connection with license renewal and concluded that the 

31 core damage and radiological release from such acts would be no worse than the damage and 

32 release expected from internally initiated events. In the GEIS, the Commission concludes that 

33 the risk from sabotage and beyond design-basis earthquakes at existing nuclear power plants is 

34 SMALL and, additionally, that the risks from other external events are adequately addressed by 

35 a generic consideration of internally initiated severe accidents (NRC 1996).

36 Based on information in the GEIS, the staff found the following to be true:

37 The probability weighted consequences of atmospheric releases, fallout onto 

38 open bodies of water, releases to ground water, and societal and economic 

39 impacts from severe accidents are small for all plants. However, alternatives to 

40 mitigate severe accidents must be considered for all plants that have not 

41 considered such alternatives.

42 The staff identified no new and significant information related to postulated accidents during the 

43 review of Davis-Besse’s ER (FENOC 2010), the site audit, the scoping process, or the 

44 evaluation of other available information. Therefore, there are no impacts related to these 
Environmental Impacts of Postulated Accidents

5-3 

1 issues beyond those discussed in the GEIS. However, in accordance with 

2 10 CFR 51.53(c)(3)(ii)(L), the staff has reviewed severe accident mitigation alternatives 

3 (SAMAs) for Davis-Besse. The results of the review are discussed in Section 5.3.

4 5.3 Severe Accident Mitigation Alternatives

5 Section 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to 

6 mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant’s 

7 plant in an environmental impact statement (EIS) or related supplement or in an environmental 

8 assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware, 

9 procedures, and training) with the potential for improving severe accident safety performance 

10 are identified and evaluated. SAMAs have not been previously considered for Davis-Besse; 

11 therefore, the remainder of Chapter 5 addresses those alternatives.

12 5.3.1 Overview of SAMA Process

13 This section presents a summary of the SAMA evaluation for Davis-Besse conducted by 

14 FirstEnergy Nuclear Operating Company, LLC (FENOC), and the NRC staff’s review of that 

15 evaluation. The NRC staff performed its review with contract assistance from Pacific Northwest 

16 National Laboratory (PNNL). The NRC staff’s review is available in full in Appendix F, and the 

17 SAMA evaluation is available in full in Appendix E of the FENOC ER.

18 The SAMA evaluation for Davis-Besse was conducted with a four-step approach. In the first 

19 step, FENOC quantified the level of risk associated with potential reactor accidents using the 

20 plant-specific probabilistic risk assessment (PRA) and other risk models.

21 In the second step, FENOC examined the major risk contributors and identified possible ways 

22 (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 

23 systems, procedures, and training. FENOC identified 167 potential SAMAs for Davis-Besse. 

24 FENOC performed an initial screening to determine if any SAMAs could be eliminated for the 

25 following reasons:

26 • The SAMA has design differences or has already been implemented at Davis-Besse.

27 • The SAMA is not applicable to Davis-Besse.

28 • The SAMA has estimated implementation costs that would exceed the dollar value 

29 associated with eliminating all severe accident risk at Davis-Besse.

30 • The SAMA is related to a non-risk significant system and, therefore, has a very low 

31 benefit.

32 • The SAMA is similar in nature and could be combined with another SAMA candidate. 

33 Based on this screening, 152 SAMAs were eliminated, leaving 15 candidate SAMAs for further 

34 evaluation.

35 In the third step, FENOC estimated the benefits and the costs associated with each of the 

36 SAMAs. Estimates were made of how much each SAMA could reduce risk. Those estimates 

37 were developed in terms of dollars in accordance with NRC guidance for performing regulatory 

38 analyses. The cost of implementing the proposed SAMAs was also estimated. 

39 Finally, in the fourth step, the cost and benefit of each of the remaining SAMAs were compared 

40 to determine whether the SAMA was cost-beneficial, meaning the benefits of the SAMA were 
Environmental Impacts of Postulated Accidents

5-4 

1 greater than the cost (a positive cost benefit). FENOC concluded in its ER that SAMA 

2 AC/DC-03, adding a portable, diesel-driven battery charger to the existing DC system, would be 

3 potentially cost-beneficial. SAMA AC/DC-03 does not relate to adequately managing the effects 

4 of aging during the period of extended operation; therefore, it need not be implemented as part 

5 of license renewal pursuant to 10 CFR Part 54. FENOC’s SAMA analyses and the NRC’s 

6 review are discussed in more detail below.

7 5.3.2 Estimate of Risk

8 FENOC submitted an assessment of SAMAs for Davis-Besse as part of the ER. This 

9 assessment was based on the most recent Davis-Besse PRA available at that time; a plant10 specific offsite consequence analysis performed using the MELCOR Accident Consequence 

11 Code System 2 (MACCS2) computer program; and insights from the Davis-Besse individual 

12 plant examination (IPE) (Centerior Energy 1993) and individual plant examination of external 

13 events (IPEEE) (Centerior Energy 1996).

14 The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is 

approximately 1x10-5 15 per year for internal events including internal flooding events. FENOC 

16 accounted for the potential risk reduction benefits associated with external events by applying a 

17 multiplier to the estimated benefits for internal events. FENOC used a multiplier of 5.6 to 

account for external events, which assumes a seismic CDF of 6.7×10-6 18 per year, a fire CDF of 

2.9×10-5 19 per year, and a high winds, tornadoes, external floods, and other external events CDF 

of 1.0×10-5 20 per year (FENOC 2011).

21 The breakdown of CDF by initiating event is provided in Table 5.3-1. As shown in this table, 

22 loss of offsite power (LOOP), loss of component cooling water (CCW), and reactor or turbine 

23 trips are the dominant contributors to the CDF. Anticipated transient without scram (ATWS) 

24 sequences are modeled as a failure to trip after an initiating event; ATWS sequences contribute 

25 approximately 1 percent to CDF. Station blackout (SBO) sequences involve a LOOP (as the 

26 initiating event or following an initiating event), along with subsequent failure of power to both 

27 safety buses (i.e., a loss of both emergency diesel generators (EDGs) and the SBO diesel 

28 generator). SBO sequences contribute approximately 5 percent to CDF and are dominated by 

29 sequences initiated by a LOOP. Column totals in Table 5.3-2 may differ due to round off. 

30 FENOC estimated the dose to the population within 50 miles (mi) (80 kilometers (km)) of the 

31 Davis-Besse site to be approximately 0.023 person-Sievert (Sv) (2.3 person-rem) per year for 

32 internal events (FENOC 2011). The breakdown of the total population dose by containment 

33 release mode is summarized in Table 5.3-2. SGTR and interfacing system LOCA (ISLOCA), 

34 both containment bypass events, dominate the population dose risk for internal events at 

35 Davis-Besse. Column totals in Table 5.3-2 may differ due to round off.
Environmental Impacts of Postulated Accidents

5-5 

1 Table 5.3-1. Davis-Besse Internal Events Core Damage Frequency

Initiating Event CDF (per year) % Contribution

to CDF

Loss of offsite power (LOOP) 1.9×10-6 19

Loss of component cooling water (CCW) pump(s) 1.7×10-6 18

Reactor or turbine trip 1.3×10-6 13

Steam generator tube rupture (SGTR) 6.2×10-7 6

Loss of main feedwater 5.7×10-7 6

Loss of main feedwater flow control 5.1×10-7 5

Reactor vessel (RV) rupture 5.0×10-7 5

Small loss-of-coolant accident (LOCA) 4.3×10-7 4

Flooding in CCW pump room 2.0×10-7 2

Medium LOCA 1.5×10-7 2

Loss of service water pump room ventilation 1.3×10-7 1

Loss of direct current (DC) power from Bus d2p 1.1×10-7 1

Flooding in turbine building 8.8×10-8 1

Loss of non-nuclear instrumentation cabinets 1-4 (NNIX) DC power supply 8.2×10-8 1

Other 1.5x10-6 15

Total CDF (internal events) 9.8x10-6 100

2 Table 5.3-2. Breakdown of Population Dose by Containment Release Mode

Containment Release Mode

POPULATION dose (person-rem

per year) % Contribution

SGTR 1.45 63

ISLOCA 0.59 26

Large containment isolation failure 0.01 1

Small containment isolation failure 0.05 2

Large early release 0.03 1

Sidewall failure (early) 0.02 1

Late containment failure 0.03 1

Basemat failure 0.10 4

No containment failure 0.02 1

Total 2.30 100

3 The NRC staff has reviewed FENOC’s data and evaluation methods and concludes that the 

4 quality of the risk analyses is adequate to support an assessment of the risk reduction potential 
Environmental Impacts of Postulated Accidents

5-6 

1 for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the 

2 CDF and offsite doses reported by FENOC.

3 5.3.3 Potential Plant Improvements

4 FENOC’s process for identifying potential plant improvements (SAMAs) consisted of the 

5 following elements:

6 • review of the dominant cutsets and most significant basic events from the current, 

7 plant-specific PRA, 

8 • review of potential plant improvements identified in the Davis-Besse IPE and IPEEE, 

9 • review of SAMA candidates identified for license renewal applications (LRAs) for 

10 representative pressurized-water reactor (PWR) plants, and

11 • review of other industry documentation discussing potential plant improvements. 

12 Based on this process, an initial set of 167 candidate SAMAs was identified. FENOC performed 

13 a qualitative screening of the initial list of SAMAs using the following criteria: 

14 • The SAMA has design differences or has already been implemented at Davis-Besse.

15 • The SAMA is not applicable to Davis-Besse. 

16 • The SAMA has estimated implementation costs that would exceed the dollar value 

17 associated with eliminating all severe accident risk at Davis-Besse.

18 • The SAMA is related to a non-risk significant system and, therefore, has a very low 

19 benefit.

20 • The SAMA is similar in nature and could be combined with another SAMA candidate. 

21 Based on this screening, 152 SAMAs were eliminated, leaving 15 for further evaluation. A 

22 detailed cost-benefit analysis was performed for each of the remaining SAMAs.

23 The NRC staff concludes that FENOC used a systematic and comprehensive process for 

24 identifying potential plant improvements for Davis-Besse, and the set of SAMAs evaluated in the 

25 ER, together with those evaluated in response to NRC staff inquiries, is reasonably 

26 comprehensive and, therefore, acceptable. 

27 5.3.4 Evaluation of Risk Reduction and Costs of Improvements

28 FENOC evaluated the risk-reduction potential of the remaining candidate 15 SAMAs. The 

29 SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to 

30 eliminate the risk associated with the proposed enhancement. FENOC also provided the 

31 risk-reduction potential of six additional SAMAs identified in response to requests for additional 

32 information (RAIs) using the same bounding approach. This bounding approach overestimates 

33 the benefit and is conservative.

34 The NRC staff reviewed FENOC’s bases for calculating the risk reduction for the various plant 

35 improvements and concludes that the rationale and assumptions for estimating risk reduction 

36 are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

37 would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for 

38 the various SAMAs on FENOC’s risk reduction estimates.
Environmental Impacts of Postulated Accidents

5-7 

1 The staff also reviewed the bases for the applicant’s cost estimates. For certain improvements, 

2 the staff also compared the cost estimates to estimates developed elsewhere for similar 

3 improvements, including estimates developed as part of other applicants’ analyses of SAMAs 

4 for other operating reactors. The staff found the cost estimates to be reasonable and generally 

5 consistent with estimates provided in support of other plants’ analyses.

6 The staff concludes that the risk reduction and the cost estimates provided by FENOC are 

7 sufficient and appropriate for use in the SAMA evaluation.

8 5.3.5 Cost-Benefit Comparison

9 The methodology used by FENOC was based on NRC’s guidance for performing cost-benefit 

10 analysis (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook

11 (NRC 1997a)). The guidance involves determining the net value for each SAMA. If the net 

12 present value of a SAMA is negative, the cost of implementing the present SAMA is larger than 

13 the benefit associated with the SAMA, and it is not considered cost-beneficial. FENOC’s 

14 derivation of each of the associated costs is summarized in Appendix E. Revision 4 of 

15 NUREG/BR-0058 states that two sets of estimates should be developed, one at a 3 percent

16 discount rate and one at a 7 percent discount rate (NRC 2004). FENOC provided a base set of 

17 results using the 7 percent discount rate and a sensitivity study using the 3 percent discount 

18 rate (FENOC 2010, 2011).

19 FENOC developed plant-specific costs of implementing the 15 candidate SAMAs. The NRC 

20 staff asked FENOC to describe the level of detail used to develop the cost estimates and to 

21 clarify whether the cost estimates accounted for inflation, contingency costs associated with 

22 unforeseen implementation obstacles, replacement power during extended outages, and 

23 maintenance and surveillance costs during plant operation (NRC 2011a). In response to the 

24 RAI, FENOC clarified that the cost estimates conservatively did not include inflation, 

25 contingency costs associated with unforeseen implementation obstacles, or the cost of 

26 replacement power during extended outages required to implement the modifications 

27 (FENOC 2011). 

28 The NRC staff reviewed the bases for the applicant’s cost estimates. For certain improvements, 

29 the NRC staff also compared the cost estimates to estimates developed elsewhere for similar 

30 improvements, including estimates developed as part of other applicants’ analyses of SAMAs 

31 for operating reactors. The NRC staff reviewed the costs and found them to be reasonable and 

32 generally consistent with estimates provided in support of other plants’ analyses. 

33 FENOC’s SAMA analysis determined that SAMA AC/DC-03 would be potentially cost-beneficial. 

34 This SAMA would increase battery capacity and, therefore, increase the time available for 

35 recovery of offsite or onsite power by adding a portable, diesel-driven battery charger to the 

36 existing DC system. This SAMA candidate would provide longer battery lifetime during SBO 

37 events. FENOC states in Section E.9 of the ER that SAMA AC/DC-03, which was determined 

38 to be potentially cost-beneficial in both the baseline analysis and the sensitivity analysis, will be 

39 considered for implementation through the normal processes for evaluating possible plant 

40 modifications. 

41 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMA 

42 discussed above, the costs of the other SAMAs evaluated would be higher than the associated 

43 benefits.
Environmental Impacts of Postulated Accidents

5-8 

1 5.3.6 Conclusions

2 The NRC staff reviewed FENOC’s analysis and concludes that the methods used and the 

3 implementation of those methods were sound. The treatment of SAMA benefits and costs 

4 support the general conclusion that the SAMA evaluations performed by FENOC are 

5 reasonable and sufficient for the license renewal submittal. 

6 Based on its review of the SAMA analysis, the NRC staff agrees with FENOC’s identification of 

7 areas in which risk can be further reduced in a cost-beneficial manner through the 

8 implementation of the identified, potentially cost-beneficial SAMA. Given the potential for 

9 cost-beneficial risk reduction, the NRC staff agrees that further evaluation of SAMA AC/DC-03 

10 by FENOC is warranted. However, this SAMA does not relate to adequately managing the 

11 effects of aging during the period of extended operation. Therefore, it need not be implemented 

12 as part of license renewal pursuant to 10 CFR Part 54.

13 5.4 References

14 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

15 Production and Utilization Facilities.”

16 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

17 Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

18 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

19 Renewal of Operating Licenses for Nuclear Power Plants.”

20 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site 

21 Criteria.”

22 Centerior Energy. 1993. Letter from Donald C. Shelton (Centerior Energy) to NRC Document 

23 Control Desk. Subject: “Individual Plant Examination (IPE) for Severe Accident Vulnerabilities 

24 for the Davis-Besse Nuclear Power Station, Unit 1 (Response to NRC Generic Letter 88-20),” 

25 February 26, 1993.

26 Centerior Energy. 1996. Letter from John K. Wood (Centerior Energy) to NRC Document 

27 Control Desk. Subject: “Individual Plant Examination for External Events for Severe Accident 

28 Vulnerabilities for the Davis-Besse Nuclear Power Station, Unit 1 (Response to NRC Generic 

29 Letter 88-20, Supplement 4),” December 16, 1996.

30 [FENOC] FirstEnergy Nuclear Operating Company. 2010. “Davis-Besse Nuclear Power Station 

31 License Renewal Application,” Toledo, OH, August 2010, Agencywide Documents Access and 

32 Management System (ADAMS) Accession Nos. ML102450572 

33 [FENOC] FirstEnergy Nuclear Operating Company. 2011. Letter from Kendall W. Byrd, 

34 FENOC, to NRC Document Control Desk. Subject: Reply to Request for Additional Information 

35 for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal 

36 Application (TAC No. ME4613) Environmental Report Severe Accident Mitigation Alternatives 

37 Analysis, and License Renewal Application Amendment No.10 (L-11-154). June 24. ADAMS 

38 Accession No. ML11180A233.
Environmental Impacts of Postulated Accidents

5-9 

1 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 

2 for License Renewal of Nuclear Plants, NUREG-1437, Washington, D.C., May. ADAMS 

3 Accession Nos. ML040690705 and ML040690738.

4 [NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation 

5 Handbook. NUREG/BR-0184. Washington, D.C. January 1997.

6 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 

7 for License Renewal of Nuclear Plants, Main Report, NUREG-1437, Section 6.3, Table 9.1, 

8 Volume 1, Addendum 1, Washington, D.C.

9 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from Paula E. Cooper, U.S. NRC, 

10 to Barry S. Allen, FENOC. Subject: Requests for Additional Information for the Review of the 

11 Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application. Washington, D.C. 

12 April 20, 2011. ADAMS Accession No. ML110910566.

13 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Memo from John G. Parillo, U.S. NRC, to 

14 Travis L. Tate, U.S. NRC. Subject: Request For Additional Information Response 

15 Clarifications From Davis-Besse Nuclear Power Station In Support Of License Renewal

16 Application Review (TAC No. ME4613). Washington, D.C. August 15, 2011. ADAMS 

17 Accession No. ML112270139.

6-1 

1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE AND 

2 SOLID WASTE MANAGEMENT

3 6.1 The Uranium Fuel Cycle

4 This chapter addresses issues related to the uranium fuel cycle and solid waste management 

5 during the period of extended operation (listed in Table 6.1-1). The uranium cycle includes 

6 uranium mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel 

7 fabrication, reprocessing of irradiated fuel, transportation of radioactive materials and 

8 management of low-level wastes and high-level wastes related to uranium fuel cycle activities. 

9 The generic potential impacts of the radiological and nonradiological environmental impacts of 

10 the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in 

11 the Generic Environmental Impact Statement (GEIS) (NRC 1996, 1999). They are based, in 

12 part, on the generic impacts provided in Title 10, Part 51.51(b) of the Code of Federal 

13 Regulations (10 CFR 51.51(b)), Table S-3, “Table of Uranium Fuel Cycle Environmental Data,” 

14 and in 10 CFR 51.52(c), Table S-4, “Environmental Impact of Transportation of Fuel and Waste 

15 to and from One Light-Water-Cooled Nuclear Power Reactor.”

16 Table 6.1-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management.

17 There are nine generic issues related to the fuel cycle and waste management. There are no 

18 site-specific issues.

19

Issues GEIS Sections Category

Offsite radiological impacts (individual effects 

from other than the disposal of spent fuel and 

high-level waste) 

6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 1 

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1

Offsite radiological impacts (spent fuel and 

high-level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 

Nonradiological impacts of the uranium fuel 

cycle

6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 

6.6 1 

Low-level waste storage and disposal

6.1; 6.2.2.2;6.4.2; 6.4.3; 6.4.3.1; 6.4.3.2; 6.4.3.3; 

6.4.4; 6.4.4.1; 6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; 

6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 6.4.4.5.4; 6.4.4.6;6.6

1 

Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 6.4.5.5; 6.4.5.6; 

6.4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 1 

Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; 6.4.6.5; 

6.4.6.6; 6.4.6.7; 6.6 1 

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, Addendum 1 1

20 The NRC staff’s evaluation of the environmental impacts associated with spent nuclear fuel is 

21 addressed in two issues in Table 6.1-1, “Offsite radiological impacts (spent fuel and high-level 

22 waste disposal)” and “Onsite spent fuel.” However, as explained later in this chapter, the scope 

23 of the evaluation of these two issues in this SEIS has been revised. The issue, “Offsite 

24 radiological impacts (spent fuel and high-level waste disposal),” is not evaluated in this SEIS. In 
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-2 

1 addition, the issue, “Onsite spent fuel,” only evaluates the environmental impacts during the 

2 license renewal term.

3 For the term of license renewal, the NRC staff did not find any new and significant information 

4 related to the remaining uranium fuel cycle and solid waste management issues listed in 

5 Table 6.1-1 during its review of the Davis-Besse Environmental Report (ER) (FENOC 2010), the 

6 site visit, and the scoping process. Therefore, there are no impacts related to these issues 

7 beyond those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the 

8 impacts are SMALL, except for the issue, “Offsite radiological impacts (collective effects),” which 

9 the NRC has not assigned an impact level. This issue assesses the 100-year radiation dose to 

10 the U.S. population (i.e., collective effects or collective dose) from radioactive effluents released 

11 as part of the uranium fuel cycle for a nuclear power plant during the license renewal term 

12 compared to the radiation dose from natural background exposure. It is a comparative 

13 assessment for which there is no regulatory standard to base an impact level.

14 For the offsite radiological impacts resulting from spent fuel and high-level waste disposal and 

15 the onsite storage of spent fuel, which will occur after the reactors have been permanently 

16 shutdown, the NRC’s Waste Confidence Decision and Rule represented the Commission’s 

17 generic determination that spent fuel can continue to be stored safely and without significant 

18 environmental impacts for a period of time after the end of the licensed life for operation. This 

19 generic determination meant that the NRC did not need to consider the storage of spent fuel 

20 after the end of a reactor’s licensed life for operation in National Environmental Policy Act 

21 (NEPA) documents that support its reactor and spent fuel storage application reviews.

22 The NRC first adopted the Waste Confidence Decision and Rule in 1984. The NRC amended 

23 the decision and rule in 1990, reviewed them in 1999, and amended them again in 2010 

24 (49 FR 34694; 55 FR 38474; 64 FR 68005; and 75 FR 81032 and 81037). The Waste 

25 Confidence Decision and Rule are codified in 10 CFR 51.23.

26 On December 23, 2010, the Commission published in the Federal Register a revision of the 

27 Waste Confidence Decision and Rule to reflect information gained from experience in the 

28 storage of spent fuel and the increased uncertainty in the siting and construction of a permanent 

29 geologic repository for the disposal of spent nuclear fuel and high-level waste (75 FR 81032 

30 and 81037). In response to the 2010 Waste Confidence Decision and Rule, the States of 

31 New York, New Jersey, Connecticut, and Vermont—along with several other 

32 parties—challenged the Commission’s NEPA analysis in the decision, which provided the 

33 regulatory basis for the rule. On June 8, 2012, the United States Court of Appeals, District of 

34 Columbia Circuit in New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012) vacated the NRC’s Waste 

35 Confidence Decision and Rule after finding that it did not comply with NEPA.

36 In response to the court’s ruling, the Commission, in CLI-12-16 (NRC 2012a), determined that it 

37 would not issue licenses that rely upon the Waste Confidence Decision and Rule until the issues 

38 identified in the court’s decision are appropriately addressed by the Commission. In CLI-12-16, 

39 the Commission also noted that the decision not to issue licenses only applies to final license 

40 issuance; all licensing reviews and proceedings should continue to move forward.

41 In addition, the Commission directed in SRM-COMSECY-12-0016 (NRC 2012b) that the NRC 

42 staff proceed with a rulemaking that includes the development of an environmental impact 

43 statement (EIS) to support a revised Waste Confidence Rule and to publish both the EIS and 

44 the revised rule in the Federal Register within 24 months (by September 2014). The 

45 Commission indicated that both the EIS and the revised Waste Confidence Rule should build on 

46 the information already documented in various NRC studies and reports, including the existing 
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-3 

1 environmental assessment that the NRC developed as part of the 2010 Waste Confidence 

2 Decision and Rule. The Commission directed that any additional analyses should focus on the 

3 issues identified in the court’s decision. The Commission also directed that the NRC staff 

4 provide ample opportunity for public comment on both the draft EIS and the proposed rule.

5 The revised rule and supporting EIS are expected to provide the necessary NEPA analyses of 

6 waste confidence-related human health and environmental issues. As directed by the 

7 Commission, the NRC will not issue a renewed license before the resolution of waste 

8 confidence-related issues. This will ensure that there would be no irretrievable or irreversible 

9 resource commitments or potential harm to the environment before waste confidence impacts 

10 have been addressed.

11 On September 13, 2013, the NRC published a proposed revision of the Waste Confidence Rule

12 and supporting EIS for public comment. Further information on the Waste Confidence 

13 rulemaking and supporting EIS is available on the NRC’s Waste Confidence website: 

14 http://www.nrc.gov/waste/spent-fuel-storage/wcd.html. 

15 If the results of the Waste Confidence Rule and supporting EIS identify information that requires 

16 a supplement to this SEIS, the NRC staff will perform any appropriate additional NEPA review 

17 for those issues before the NRC makes a final licensing decision.

18 6.2 Greenhouse Gas Emissions

19 This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the 

20 nuclear fuel cycle. The GEIS does not directly address these emissions, and its discussion is 

21 limited to an inference that substantial carbon dioxide (CO2) emissions may occur if coal- or 

22 oil-fired alternatives to license renewal are implemented. 

23 6.2.1 Existing Studies

24 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 

25 electricity generating methods have been widely studied. However, estimates and projections 

26 of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done. 

27 Additionally, considerable debate exists among researchers regarding the relative effects of 

28 nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG 

29 emissions from nuclear power plants generally take one of the following forms:

30 • qualitative discussions of the potential to use nuclear power to reduce GHG emissions 

31 and mitigate global warming or 

32 • technical analyses and quantitative estimates of the actual amount of GHGs generated 

33 by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the 

34 operational or life cycle emissions from other energy generation alternatives. 

35 6.2.1.1 Qualitative Studies

36 The qualitative studies consist primarily of broad, large-scale public policy or investment 

37 evaluations on whether an expansion of nuclear power is likely to be a technically, 

38 economically, or politically workable means of achieving global GHG reductions. Studies found 

39 by the U.S. Nuclear Regulatory Commission (NRC) staff during the subsequent literature search 

40 include the following:
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-4 

1 • Evaluations determined if investments in nuclear power in developing countries should 

2 be accepted as a flexibility mechanism to assist industrialized nations in achieving their 

3 GHG reduction goals under the Kyoto Protocols (IAEA 2000; NEA 2002; 

4 Schneider 2000). Ultimately, the parties to the Kyoto Protocol did not approve nuclear 

5 power as a component under the clean development mechanism (CDM) due to safety 

6 and waste disposal concerns (NEA 2002).

7 • Analyses were developed to assist governments, including the U.S. Government, in 

8 making long-term investment and public policy decisions in nuclear power (Hagen et 

9 al. 2001; Keepin 1988; MIT 2003).

10 Although the qualitative studies sometimes reference and analyze the existing quantitative 

11 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 

12 rely heavily on discussions of other aspects of nuclear policy decisions and investment such as 

13 safety, cost, waste generation, and political acceptability. Therefore, these studies are typically 

14 not directly applicable to an evaluation of GHG emissions associated with the proposed license 

15 renewal for a given nuclear power plant.

16 6.2.1.2 Quantitative Studies

17 A large number of technical studies, including calculations and estimates of the amount of 

18 GHGs emitted by nuclear and other power generation options, are available in the literature and 

19 were useful to the NRC staff’s efforts to address relative GHG emission levels. Examples of 

20 these studies include—but are not limited to—Mortimer (1990), Andseta et al. (1998), 

21 Spadaro (2000), Storm van Leeuwen and Smith (2005), Fritsche (2006), Parliamentary Office of 

22 Science and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), 

23 Weisser (2006), Dones (2007), and Fthenakis and Kim (2007).

24 Comparing these studies, and others like them, is difficult because the assumptions and 

25 components of the lifecycles that the authors evaluate vary widely. Examples of areas in which 

26 differing assumptions make comparing the studies difficult include the following:

27 • energy sources that may be used to mine uranium deposits in the future, 

28 • reprocessing or disposal of spent nuclear fuel, 

29 • current and potential future processes to enrich uranium and the energy sources that will 

30 power them, 

31 • estimated grades and quantities of recoverable uranium resources, 

32 • estimated grades and quantities of recoverable fossil fuel resources, 

33 • estimated GHG emissions other than CO2, including the conversion to CO2 equivalents 

34 per unit of electric energy produced, 

35 • performance of future fossil fuel power systems, 

36 • projected capacity factors for alternatives means of generation, and

37 • current and potential future reactor technologies. 

38 In addition, studies may vary with respect to whether all or parts of a power plant’s lifecycle are 

39 analyzed. For example, a full lifecycle analysis will typically address plant construction, 

40 operations, resource extraction (for fuel and construction materials), and decommissioning. A 

41 partial lifecycle analysis primarily focuses on operational differences.
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-5 

1 In the case of license renewal, a GHG analysis for that portion of the plant’s lifecycle (operation 

2 for an additional 20 years) would not involve GHG emissions associated with construction 

3 because construction activities have already been completed at the time of relicensing. In 

4 addition, the proposed action of license renewal would also not involve additional GHG 

5 emissions associated with facility decommissioning because that decommissioning must occur 

6 whether the facility is relicensed or not. However, in some of the above-mentioned studies, the 

7 specific contribution of GHG emissions from construction, decommissioning, or other portions of 

8 a plant’s lifecycle cannot be clearly separated from one another. In such cases, an analysis of 

9 GHG emissions would overestimate the GHG emissions attributed to a specific portion of a 

10 plant’s lifecycle. Nonetheless, these studies supply some meaningful information with respect 

11 to the relative magnitude of the emissions among nuclear power plants and other forms of 

12 electric generation, as discussed in the following sections.

13 In Table 6.2-1, Table 6.2-2, and Table 6.2-3, the NRC staff presents the results of the 

14 above-mentioned quantitative studies to supply a weight-of-evidence evaluation of the relative 

15 GHG emissions that may result from the proposed license renewal as compared to the potential 

16 alternative use of coal-fired, natural gas-fired, and renewable generation. Most studies from 

17 Mortimer (1990) onward suggest that uranium ore grades and uranium enrichment processes 

18 are leading determinants in the ultimate GHG emissions attributable to nuclear power 

19 generation. These studies show that the relatively lower order of magnitude of GHG emissions 

20 from nuclear power, when compared to fossil-fueled alternatives (especially natural gas), could 

21 potentially disappear if available uranium ore grades drop sufficiently while enrichment 

22 processes continued to rely on the same technologies.

23 6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal

24 Considering that coal fuels the largest share of electricity generation in the U.S., and that its 

25 burning results in the largest emissions of GHGs for any of the likely alternatives to nuclear 

26 power generation (including Davis-Besse), most of the available quantitative studies focused on 

27 comparisons of the relative GHG emissions of nuclear to coal-fired generation. The quantitative 

28 estimates of the GHG emissions associated with the nuclear fuel cycle—and, in some cases, 

29 the nuclear lifecycle—as compared to an equivalent coal-fired plant, are presented in

30 Table 6.2-1. This table does not include all existing studies, but it gives an illustrative range of 

31 estimates developed by various sources.

32 Table 6.2-1. Nuclear GHG Emissions Compared to Coal

Source GHG Emission Results

Mortimer (1990) Nuclear—230,000 tons CO2

Coal—5,912,000 tons CO2

Note: Future GHG emissions from nuclear will increase because of declining 

ore grade.

Andseta et al. (1998) Nuclear energy produces 1.4% of the GHG emissions compared to coal.

Note: Future reprocessing and use of nuclear-generated electrical power in 

the mining and enrichment steps are likely to change the projections of earlier 

authors, such as Mortimer (1990).

Spadaro (2000) Nuclear—2.5–5.7 grams (g) of carbon equivalent per kilowatt hour (Ceq/kWh)

Coal—264–357 g Ceq/kWh

Storm van Leeuwen & Smith (2005) Authors did not evaluate nuclear versus coal.

Fritsche (2006) (Values estimated 

from graph in Figure 4)

Nuclear—33 g Ceq/kWh

Coal—950 g Ceq/kWh
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-6 

Source GHG Emission Results

POST (2006) (Nuclear calculations 

from AEA 2006)

Nuclear—5 g Ceq/kWh

Coal—>1000 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would increase nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and storage 

could reduce coal-fired GHG emissions by 90%.

Weisser (2006) (Compilation of 

results from other studies)

Nuclear—2.8–24 g Ceq/kWh

Coal—950–1250 g Ceq/kWh

Fthenakis & Kim (2007) Authors did not evaluate nuclear versus coal.

Dones (2007) Author did not evaluate nuclear versus coal.

1 6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas

2 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle—and, in 

3 some cases, the nuclear lifecycle—as compared to an equivalent natural gas combined 

4 cycle-fired plant, are presented in Table 6.2-2. This table does not include all existing studies, 

5 but it gives an illustrative range of estimates developed by various sources.

6 Table 6.2-2. Nuclear GHG Emissions Compared to Natural Gas 

Source GHG Emission Results 

Mortimer (1990) Author did not evaluate nuclear versus natural gas.

Andseta et al. (1998) Author did not evaluate nuclear versus natural gas.

Spadaro (2000) Nuclear—2.5–5.7 g Ceq/kWh

Natural Gas—120–188 g Ceq/kWh

Storm van Leeuwen & Smith (2005) Nuclear fuel cycle produces 20–33% of the GHG emissions compared to 

natural gas (at high ore grades).

Note: Future nuclear GHG emissions will increase because of declining ore 

grade.

Fritsche (2006) (Values estimated 

from graph in Figure 4)

Nuclear—33 g Ceq/kWh

Cogeneration Combined Cycle Natural Gas—150 g Ceq/kWh

POST (2006) (Nuclear calculations 

from AEA 2006)

Nuclear—5 g Ceq/kWh

Natural Gas—500 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would increase nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and storage 

could reduce natural gas GHG emissions by 90%.

Weisser (2006) (Compilation of 

results from other studies)

Nuclear—2.8–24 g Ceq/kWh

Natural Gas—440–780 g Ceq/kWh

Fthenakis & Kim (2007) Authors did not evaluate nuclear versus natural gas.

Dones (2007) Author analyzed methods and assumptions of Storm van Leeuwen and Smith 

(2005) and concluded that the nuclear fuel cycle produces 15–27% of the 

GHG emissions of natural gas.
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-7 

1 6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable 

2 Energy Sources

3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 

4 compared to equivalent renewable energy sources, are presented in Table 6.2-3. Calculation of 

5 GHG emissions associated with these sources is more difficult than the calculations for nuclear 

6 energy and fossil fuels because of the large variation in efficiencies due to their different 

7 sources and locations. For example, the efficiency of solar and wind energy is highly dependent 

8 on the location in which the power generation facility is installed. Similarly, the range of GHG 

9 emissions estimates for hydropower varies greatly depending on the type of dam or reservoir 

10 involved (if used at all). Therefore, the GHG emissions estimates for these energy sources 

11 have a greater range of variability than the estimates for nuclear and fossil fuel sources. As 

12 noted in Section 6.2.1.2, the following table does not include all existing studies, but it gives an 

13 illustrative range of estimates developed by various sources.

14 Table 6.2-3. Nuclear GHG Emissions Compared to Renewable Energy Sources

Source GHG Emission Results 

Mortimer (1990) Nuclear—230,000 tons CO2

Hydropower—78,000 tons CO2

Wind power—54,000 tons CO2

Tidal power—52,500 tons CO2

Note: Future GHG emissions from nuclear will increase because of declining ore grade.

Andseta et al. (1998) Author did not evaluate nuclear versus renewable energy sources.

Spadaro (2000) Nuclear—2.5–5.7 g Ceq/kWh

Solar Photovoltaic (PV)—27.3–76.4 g Ceq/kWh

Hydroelectric—1.1–64.6 g Ceq/kWh

Biomass—8.4–16.6 g Ceq/kWh

Wind—2.5–13.1 g Ceq/kWh

Storm van Leeuwen & 

Smith (2005)

Author did not evaluate nuclear versus renewable energy sources.

Fritsche (2006) (Values 

estimated from graph in 

Figure 4)

Nuclear—33 g Ceq/kWh

Solar PV—125 g Ceq/kWh

Hydroelectric—50 g Ceq/kWh

Wind—20 g Ceq/kWh

POST (2006) (Nuclear 

calculations from 

AEA 2006)

Nuclear—5 g Ceq/kWh

Biomass—25–93 g Ceq/kWh

Solar PV—35–58 g Ceq/kWh

Wave/Tidal—25–50 g Ceq/kWh

Hydroelectric—5–30 g Ceq/kWh

Wind—4.64–5.25 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would increase nuclear to 

6.8 g Ceq/kWh. 

Weisser (2006) 

(Compilation of results 

from other studies)

Nuclear—2.8–24 g Ceq/kWh

Solar PV—43–73 g Ceq/kWh

Hydroelectric—1–34 g Ceq/kWh

Biomass—35–99 g Ceq/kWh

Wind—8–30 g Ceq/kWh

Fthenakis & Kim (2007) Nuclear—16–55 g Ceq/kWh

Solar PV—17–49 g Ceq/kWh

Dones (2007) Author did not evaluate nuclear versus renewable energy sources.
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-8 

1 6.2.2 Conclusions: Relative Greenhouse Gas Emissions

2 The sampling of data presented in Table 6.2-1, Table 6.2-2, and Table 6.2-3 demonstrates the 

3 challenges of any attempt to determine the specific amount of GHG emission attributable to 

4 nuclear energy production sources, as different assumptions and calculation methods will yield 

5 differing results. The differences and complexities in these assumptions and analyses will 

6 further increase when they are used to project future GHG emissions. Nevertheless, several 

7 conclusions can be drawn from the information presented.

8 First, the various studies show a consensus that nuclear power currently produces fewer GHG 

9 emissions than fossil-fuel-based electrical generation. The GHG emissions from a complete 

10 nuclear fuel cycle currently range from 2.5 to 55 g Ceq/kWh, as compared to the use of coal 

11 plants (264 to 1,250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh). The studies 

12 also give estimates of GHG emissions from five renewable energy sources based on current 

13 technology. These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh), hydroelectric 

14 (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), and tidal 

15 (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion is that 

16 current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as from 

17 these renewable energy sources.

18 Second, the studies show no consensus regarding future relative GHG emissions from nuclear

19 power and other sources of electricity. There is substantial disagreement among the various 

20 authors about the GHG emissions associated with declining uranium ore concentrations, future 

21 uranium enrichment methods, and other factors to include changes in technology. Similar 

22 disagreement exists about future GHG emissions associated with coal and natural gas for 

23 electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 

24 currently produces fewer GHG emissions than fossil-fuel-based sources, and it is expected to 

25 continue to do so in the near future. The primary difference between the authors is the 

26 projected cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed 

27 those of fossil-fuel-based sources) or whether cross-over will actually occur.

28 Considering the current estimates and future uncertainties, it appears that GHG emissions 

29 associated with the proposed Davis-Besse relicensing action are likely to be lower than those 

30 associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the 

31 following rationale:

32 • As shown in Table 6.2-1and Table 6.2-2, the current estimates of GHG emissions from 

33 the nuclear fuel cycle are far below those for fossil-fuel-based energy sources.

34 • License renewal of a nuclear power plant like Davis-Besse will involve continued GHG 

35 emissions due to uranium mining, processing, and enrichment, but it will not result in 

36 increased GHG emissions associated with plant construction or decommissioning (as 

37 the plant will have to be decommissioned at some point whether the license is renewed 

38 or not).

39 • Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 

40 within a timeframe that includes the Davis-Besse period of extended operation. Several 

41 studies suggest that future extraction and enrichment methods, the potential for 

42 higher-grade resource discovery, and technology improvements could extend this 

43 timeframe.
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-9 

1 With respect to comparison of GHG emissions among the proposed Davis-Besse license 

2 renewal action and renewable energy sources, it appears likely that there will be future 

3 technology improvements and changes in the type of energy used for mining, processing, and 

4 constructing facilities of all types. Currently, the GHG emissions associated with the nuclear 

5 fuel cycle and renewable energy sources are within the same order of magnitude. Because 

6 nuclear fuel production is the most significant contributor to possible future increases in GHG 

7 emissions from nuclear power—and because most renewable energy sources lack a fuel 

8 component—it is likely that GHG emissions from renewable energy sources would be lower 

9 than those associated with Davis-Besse at some point during the period of extended operation.

10 The NRC staff also supplies an additional discussion about the contribution of GHG to 

11 cumulative air quality impacts in Section 4.11.2 of this supplemental environmental impact 

12 statement (SEIS).

13 6.3 References

14 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

15 Production and Utilization Facilities.”

16 [AEA] Atomic Energy Authority Technology. 2006. “Carbon Footprint of the Nuclear Fuel Cycle, 

17 Briefing Note,” Prepared for British Energy, March 2006.

18 Andseta et al. 1998. “CANDU Reactors and Greenhouse Gas Emissions,” Canadian Nuclear 

19 Association, 11th Pacific Basin Nuclear Conference, Banff, Alberta, Canada, May.

20 Dones, R. 2007. “Critical Note on the Estimation by Storm Van Leeuwen J.W., and Smith P. of 

21 the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain,” 

22 Paul Sherer Institute, April.

23 [FENOC] FirstEnergy Nuclear Operating Company. 2010. “Davis-Besse Nuclear Power 

24 Station License Renewal Application,” Toledo, OH, August 2010, Agencywide Documents 

25 Access and Management System (ADAMS) Accession Nos. ML102450572. 

26 Fritsche, U.R. 2006. “Comparison of Greenhouse-Gas Emissions and Abatement Cost of 

27 Nuclear and Alternative Energy Options from a Life-Cycle Perspective,” Oko-Institut, Darmstadt 

28 Office, January.

29 Fthenakis, V.M. and H.C. Kim. 2007. “Greenhouse-Gas Emissions from Solar-Electric and 

30 Nuclear Power: A Life Cycle Study,” Energy Policy, Volume 35, Number 4.

31 Hagen, R.E. et al. 2001. “Impact of U.S. Nuclear Generation on Greenhouse Gas Emissions,” 

32 IAEA, Vienna, Austria, November.

33 [IAEA] International Atomic Energy Agency. 2000. “Nuclear Power for Greenhouse Gas 

34 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM),” November.

35 Keepin, B. 1988. “Greenhouse Warming: Efficient Solution of Nuclear Nemesis?,” Rocky 

36 Mountain Institute, Joint Hearing on Technologies for Remediating Global Warming, 

37 Subcommittee on Natural Resources, Agriculture Research and Environment and 

38 Subcommittee on Science, Research and Technology, U.S. House of Representatives, June. 
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6-10

1 [MIT] Massachusetts Institute of Technology. 2003. “The Future of Nuclear Power: An 

2 Interdisciplinary MIT Study,” 2003.

3 Mortimer, N. 1990. “World Warms to Nuclear Power,” SCRAM Safe Energy Journal, 

4 December 1989 and January. Available URL: 

5 <http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php> (accessed 15 July 2010).

6 [NEA] Nuclear Energy Agency. 2002. Nuclear Energy and the Kyoto Protocol, Organization for 

7 Economic Co-Operation and Development.

8 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 

9 for License Renewal of Nuclear Plants, NUREG-1437, Washington, D.C., May. ADAMS 

10 Accession Nos. ML040690705 and ML040690738.

11 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 

12 for License Renewal of Nuclear Plants, Main Report, NUREG-1437, Section 6.3, Table 9.1, 

13 Volume 1, Addendum 1, Washington, D.C.

14 [NRC] U.S. Nuclear Regulatory Commission. 2012a. “Commission, Memorandum and Order 

15 CLI-12-16.” August 7, 2012. ADAMS Accession No. ML12220A094.

16 [NRC] U.S. Nuclear Regulatory Commission. 2012b. “SRM-COMSECY-12-0016—Approach 

17 for Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence 

18 Decision and Rule.” September 6, 2012. ADAMS Accession No. ML12250A032.

19 [POST] Parliamentary Office of Science and Technology. 2006. “Carbon Footprint of Electricity 

20 Generation,” Postnote, No. 268, October.

21 Schneider, M. 2000. Climate Change and Nuclear Power, World Wildlife Fund for Nature, April. 

22 Spadaro, J.V., et al. 2000. “Greenhouse Gas Emissions of Electricity Generation Chains: 

23 Assessing the Difference,” IAEA Bulletin 42/2/2000, Vienna, Austria.

24 Storm van Leeuwen, J.W. and P. Smith. 2005. Nuclear Power—The Energy Balance, 

25 August 2005.

26 Weisser, D. 2006. “A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 

27 Supply Technologies,” Available URL: <http://www.iaea.org/OurWork/ST/NE/Pess/assets/

28 GHG_manuscript_pre-print_versionDanielWeisser.pdf> (accessed 24 November 2010).
7-1 

1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

2 Environmental impacts from the activities associated with the decommissioning of any reactor 

3 before, or at the end of, an initial or renewed license are evaluated in the Generic Environmental 

4 Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 

5 Decommissioning of Nuclear Power Reactors, NUREG 0586, Supplement 1 (NRC 2002). The 

6 U.S. Nuclear Regulatory Commission (NRC) staff’s evaluation of the environmental impacts of 

7 decommissioning—presented in NUREG 0586, Supplement 1—notes a range of impacts for 

8 each environmental issue.

9 Additionally, the incremental environmental impacts associated with decommissioning activities 

10 resulting from continued plant operation during the renewal term are discussed in 

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

12 Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the 

13 environmental issues could be applied to all plants and whether additional mitigation measures 

14 would be warranted. Issues were then assigned a Category 1 or a Category 2 designation. 

15 Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines 

16 the impact designations of SMALL, MODERATE, and LARGE. The NRC staff analyzed 

17 site-specific issues (Category 2) for the Davis-Besse Nuclear Power Station, Unit No. 1 

18 (Davis-Besse) and assigned them a significance level of SMALL, MODERATE, or LARGE, or 

19 not applicable to Davis-Besse because of site characteristics or plant features. There are no 

20 Category 2 issues related to decommissioning.

21 Regarding the offsite radiological impacts resulting from spent fuel and high-level waste 

22 disposal and the onsite storage of spent fuel, which will occur after the reactors have been 

23 permanently shut down, the NRC’s Waste Confidence Rule (i.e., 10 CFR 51.23) represented 

24 the Commission’s generic determination that spent fuel can continue to be stored safely and 

25 without significant environmental impacts for a period of time after the end of the licensed life for 

26 operation. This generic determination meant that the NRC did not need to consider the storage 

27 of spent fuel after the end of a reactor’s licensed life for operation in National Environmental 

28 Policy Act (NEPA) documents that support its reactor and spent fuel storage application 

29 reviews.

30 However, as discussed in Chapter 6 of this SEIS, the Commission’s Waste Confidence Rule

31 was vacated on June 8, 2012, by the United States Court of Appeals, District of Columbia. In 

32 response to the court’s ruling, the Commission directed the NRC staff to proceed with a 

33 rulemaking that includes the development of a generic environmental impacts statement (EIS) 

34 to support a revised Waste Confidence Rule. The revised rule and supporting EIS are expected 

35 to provide the necessary NEPA analyses of waste confidence-related human health and 

36 environmental issues related to decommissioning. 

37 The issue of spent nuclear fuel and the Waste Confidence Rule is discussed in more detail in 

38 Chapter 6 of this SEIS.

39 Table 7.1-1. Issues Related to Decommissioning

Issues GEIS Sections Category

Radiation doses 7.3.1; 7.4 1
Environmental Impacts of Decommissioning

7-2 

Issues GEIS Sections Category

Waste management 7.3.2; 7.4 1

Air quality 7.3.3; 7.4 1

Water quality 7.3.4; 7.4 1

Ecological resources 7.3.5; 7.4 1

Socioeconomic impacts 7.3.7; 7.4 1

1 Decommissioning would occur regardless of whether Davis-Besse, is shut down at the end of its 

2 current operating license or at the end of the period of extended operation. There are no 

3 site-specific issues related to decommissioning.

4 A brief description of the NRC staff’s review and the GEIS (NRC 1996, 1999) conclusions—as 

5 codified in Table B-1 of 10 CFR Part 51—for each of the issues follows:

6 • Radiation doses. Based on information in the GEIS, the NRC noted that “[d]oses to the 

7 public will be well below applicable regulatory standards regardless of which 

8 decommissioning method is used. Occupational doses would increase no more than 1 

9 person rem (1 person mSv) caused by buildup of long lived radionuclides during the 

10 license renewal term.”

11 • Waste management. Based on information in the GEIS, the NRC noted that 

12 “[d]ecommissioning at the end of a 20 year license renewal period would generate no 

13 more solid wastes than at the end of the current license term. No increase in the 

14 quantities of Class C or greater than Class C wastes would be expected.”

15 • Air quality. Based on information in the GEIS, the NRC noted that “[a]ir quality impacts 

16 of decommissioning are expected to be negligible either at the end of the current 

17 operating term or at the end of the license renewal term.”

18 • Water quality. Based on information in the GEIS, the NRC noted that “[t]he potential for 

19 significant water quality impacts from erosion or spills is no greater whether 

20 decommissioning occurs after a 20 year license renewal period or after the original 40 

21 year operation period, and measures are readily available to avoid such impacts.”

22 • Ecological resources. Based on information in the GEIS, the NRC noted that 

23 “[d]ecommissioning after either the initial operating period or after a 20 year license 

24 renewal period is not expected to have any direct ecological impacts.”

25 • Socioeconomic Impacts. Based on information in the GEIS, the NRC noted that 

26 “[d]ecommissioning would have some short term socioeconomic impacts. The impacts 

27 would not be increased by delaying decommissioning until the end of a 20 year relicense 

28 period, but they might be decreased by population and economic growth.” 

29 The NRC staff has not identified any new and significant information during the review of the 

30 FirstEnergy Nuclear Operating Company’s (FENOC’s) environmental report (ER) 

31 (FENOC, 2010), the site audit, or the scoping process. Therefore, there are no impacts related 

32 to these issues beyond those discussed in the GEIS (NRC 1996, 1999). For the issues listed in 

33 Table 7.1-1 above, the GEIS concluded that the impacts are SMALL.
Environmental Impacts of Decommissioning

7-3 

1 7.1 References

2 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

3 protection regulations for domestic licensing and related regulatory functions.”

4 [FENOC] FirstEnergy Nuclear Operating Company. 2010. “Davis-Besse Nuclear Power Station 

5 License Renewal Application,” Toledo, OH, August 2010, Agencywide Documents Access and 

6 Management System (ADAMS) Accession No. ML102450572. 

7 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 

8 for License Renewal of Nuclear Plants, NUREG-1437, Washington, D.C., May. ADAMS 

9 Accession Nos. ML040690705 and ML040690738.

10 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 

11 for License Renewal of Nuclear Plants, Main Report, NUREG-1437, Section 6.3, Table 9.1, 

12 Volume 1, Addendum 1, Washington, D.C.

13 [NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement 

14 for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

15 Nuclear Power Reactors, NUREG-0586. Washington, D.C.

8-1 

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 

2 The National Environmental Policy Act (NEPA) requires that Federal agencies consider 

3 reasonable alternatives to the proposed action in an environmental impact statement (EIS). In 

4 this case, the proposed action is issuance of a renewed license for the Davis-Besse Nuclear 

5 Power Station (Davis-Besse), which will allow the plant to operate for 20 years beyond its 

6 current license expiration date. 

7 An operating license, however, is just one of many authorizations that an applicant must obtain 

8 in order to operate a nuclear plant. Energy-planning decisionmakers and the owners of the 

9 nuclear power plant ultimately decide whether the plant will continue to operate, and economic 

10 and environmental considerations play important roles in this decision. In general, the U.S. 

11 Nuclear Regulatory Commission’s (NRC’s) responsibility is to ensure the safe operation of 

12 nuclear power facilities and not to formulate energy policy or encourage or discourage the 

13 development of alternative power generation.

14 The license renewal review process is designed to assure safe operation of the nuclear power 

15 plant during the license renewal term. Under the NRC’s environmental protection regulations in 

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

17 Section 102(2) of NEPA, renewal of a nuclear power plant operating license also requires the 

18 preparation of an EIS.

19 To support the preparation of these EISs, the NRC prepared the Generic Environmental Impact 

20 Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, in 1996. The NRC 

21 prepared the 1996 GEIS to assess the environmental impacts associated with the continued 

22 operation of nuclear power plants during the license renewal term, disposition environmental 

23 issues that result in essentially the same impact at all nuclear power plants (or all plants with 

24 similar characteristics), and identify issues that require a plant-specific analysis to determine 

25 impacts. The NRC addressed plant-specific issues in a supplemental environmental impact 

26 statement (SEIS).

27 NRC regulations in 10 CFR 51.71(d) require that the NRC staff document does the following in 

28 a SEIS: 

29 ....include a preliminary analysis that considers and weighs the environmental 

30 effects of the proposed action [license renewal]; the environmental impacts of 

31 alternatives to the proposed action; and alternatives available for reducing or 

32 avoiding adverse environmental effects. 

33 In this chapter, the NRC staff examines the potential environmental impacts of alternatives to 

34 license renewal for Davis-Besse and, where applicable, considers alternatives that may reduce 

35 or avoid adverse environmental impacts from the proposed license renewal.

36 While the 1996 GEIS reached generic conclusions regarding many environmental issues 

37 associated with license renewal, it did not determine which alternatives are reasonable, and it 

38 did not reach conclusions about site-specific environmental impact levels for alternatives. As 

39 such, the NRC must evaluate the environmental impacts of alternatives on a site-specific basis.
Environmental Impacts of Alternatives

8-2 

1 As stated in Chapter 1 of this document, alternatives to the proposed action of license renewal 

2 for Davis-Besse must meet this purpose and need for the proposed action; they must do the 

3 following (NRC 1996): 

4 provide an option that allows for power generation capability beyond the term of 

5 a current nuclear power plant operating license to meet future system generating 

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

7 authorized, Federal (other than NRC) decisionmakers.

8 The NRC ultimately makes no decision about which alternative (or the proposed action) to carry 

9 out because that decision falls to utility, state, or 

10 other Federal officials. Comparing the 

11 environmental effects of these alternatives, 

12 however, will help the NRC decide whether the 

13 adverse environmental impacts of license 

14 renewal are so great as to deny the option of 

15 license renewal for energy-planning 

16 decisionmakers (10 CFR 51.95(c)(4)). If the NRC 

17 acts to issue a renewed license, then all of the 

18 alternatives, including the proposed action, will be 

19 available to energy-planning decisionmakers. If 

20 the NRC decides not to renew the license (or 

21 takes no action at all), then energy-planning 

22 decisionmakers may no longer elect to continue 

23 operating Davis-Besse and will have to resort to 

24 another alternative—which may or may not be 

25 one of the alternatives considered in this 

26 section—to meet their energy needs now being 

27 satisfied by Davis-Besse.

28 In evaluating alternatives to license renewal, the 

29 NRC staff considers energy technologies or 

30 options that are currently in commercial operation, as well as some technologies not currently in

31 commercial operation but likely to be commercially available by the time the current 

32 Davis-Besse operating license expires on April 22, 2017. Reasonable alternatives must be 

33 available (constructed, permitted, and connected to the grid) by the time the current license 

34 expires to be considered likely to become available. Because the applicant submitted the 

35 license renewal application more than 5 years prior to the expiration date of the current 

36 operating license as specified in 10 CFR Part 2, then the current operating license will remain in 

37 effect, and thus will be deemed not to have expired, until the NRC has completed the review 

38 and made the final decision to either deny the application or issue a new operating license for 

39 the period of extended operation. Alternatives that cannot meet future system needs by 

40 providing amounts of baseload power equivalent to Davis-Besse’s current generating capacity 

41 and, in some cases, those alternatives whose costs or benefits do not justify inclusion in the 

42 range of reasonable alternatives were eliminated from detailed study. The remaining 

43 alternatives were evaluated and are discussed in depth in this chapter. Each alternative 

44 eliminated from detailed study is briefly discussed, and a basis for its removal is provided at the 

45 end of this section. In total, 17 energy technology options and alternatives to the proposed 

46 action were considered (see text box) and then narrowed to the 3 alternatives considered in 

47 Sections 8.1 through 8.3. A summary of these alternatives considered in depth is provided in 

48 Table 8.0-1. 

Alternatives Evaluated In-Depth:

• Natural gas-fired combined-cycle (NGCC);

• combination alternative (wind, solar, NGCC, 

and compressed air energy storage); and

• coal-fired power.

Other Alternatives Considered:

• wind power,

• wind power with compressed air energy 

storage,

• solar power,

• solar power with compressed air energy 

storage,

• wood waste,

• conventional hydroelectric power,

• ocean wave and current energy,

• geothermal power,

• municipal solid waste (MSW),

• biofuels, 

• oil-fired power,

• fuel cells,

• energy conservation and energy efficiency, and

• purchased power.
Environmental Impacts of Alternatives

8-3 

1 The 1996 GEIS presents an overview of some energy technologies but does not reach any 

2 conclusions about which alternatives are most appropriate for a given license renewal. Since 

3 1996, many energy technologies have evolved significantly in capability and cost while 

4 regulatory structures have changed to either promote or impede development of particular 

5 alternatives.

6 As a result, the analyses include updated information from the following sources:

7 • Energy Information Administration (EIA), 

8 • other offices within the Department of Energy (DOE), 

9 • U.S. Environmental Protection Agency (EPA), 

10 • industry sources and publications, and

11 • information submitted by FirstEnergy Nuclear Operating Company (FENOC) in its 

12 Environmental Report (ER). 

13 The evaluation of each alternative considers the environmental impacts across seven impact 

14 categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, (4) 

15 ecology, (5) human health, (6) socioeconomics, and (7) waste management. A three-level 

16 standard of significance—SMALL, MODERATE, or LARGE—is used to indicate the intensity of 

17 environmental effects for each alternative undergoing in depth evaluation. The order of 

18 presentation is not meant to imply increasing or decreasing level of impact, and it does not imply 

19 that an energy-planning decisionmaker would select one or another alternative.

20 In some cases, the NRC considers the environmental effects of locating an alternative at the 

21 existing plant site. Selecting the existing plant site allows for the maximum use of existing 

22 transmission and cooling system infrastructures and minimizes the overall environmental 

23 impact. However, in the case of Davis-Besse, there may not be sufficient land available to site 

24 some of the alternatives evaluated here while, at the same time, allowing the continued 

25 operation of the reactor until its license expiration date.

26 To ensure that the alternatives analysis was consistent with state or regional energy policies, 

27 the NRC reviewed energy related statutes, regulations, and policies within the State of Ohio, 

28 including, for example, State renewable portfolio standards (RPS).

29 The Ohio Edison Company, the Cleveland Electric Illuminating Company, and the Toledo 

30 Edison Company are FENOC Service Company’s electric utility operating companies that 

31 provide electric service in the State of Ohio. The NRC staff considered the current generation 

32 capacity and electricity production within these three service areas as well as the rest of the 

33 State of Ohio. Ohio is much more dependent on coal-fired generation than the U.S. as a whole. 

34 In 2010, coal-fired generators produced 82.1 percent of electricity in Ohio, compared to 

35 44.7 percent nationwide. Other forms of generation were smaller contributors than in the rest of 

36 the U.S., with natural gas providing 5 percent of production in the State, versus 23.9 percent

37 nationwide. Nuclear accounted for 11 percent in Ohio (versus 19.6 percent in the nation as a 

38 whole). Production from renewable sources was the area in which Ohio diverged most as a 

39 proportion from national averages—renewable generation provided 0.49 percent of electricity in 

40 the State compared to 4.1 percent nationwide. Electricity production from petroleum-fired 

41 generators was virtually the same for both Ohio and the nation at 1 percent (EIA 2012a).
Environmental Impacts of Alternatives

8-4 

1 Although it is one of the nation’s top generators of electricity, Ohio is a net importer of power. 

2 Ohio’s total electricity consumption is high due to the State’s energy-intensive industrial sector, 

3 which accounts for more than one-third of the State’s electricity consumption (EIA 2012a). The 

4 NRC concludes that since a loss of power from the Davis-Besse reactor would potentially 

5 impact electricity consumers throughout Ohio, but the power would ultimately be replaced by 

6 FENOC’s three electric operating companies, the evaluation of alternatives to the continued 

7 operation of the Davis-Besse reactor should consider alternatives located throughout these 

8 companies’ service areas.

9 The State of Ohio has established an RPS that requires electricity providers to obtain a 

10 minimum percentage of their power through renewable energy resources or energy efficiency 

11 measures or both. The RPS requirement for Ohio was adopted in 2008 and requires at least 

12 25 percent of all electricity sold in the State to come from renewable sources by 2025, at least 

13 half of which must be generated within the State. Half of the standard (12.5 percent of the 

14 electricity sold) must be met using renewable sources such as wind, solar, hydroelectric power, 

15 geothermal, and biomass. The other half can be met through alternative energy resources such 

16 as third-generation nuclear power plants, fuel cells, energy-efficiency programs, and clean coal 

17 technology (DSIRE 2013). In a compliance report filed with the Public Utilities Commission of 

18 Ohio on April 15, 2010, FENOC reported it had met its revised 2010 benchmarks for renewable 

19 energy credits (RECs) and out-of-state solar RECs, but fell slightly short in meeting its Ohio 

20 solar benchmark due to the insufficiency of Ohio-based solar energy resources (PUCO 2011).

21 Sections 8.1 through 8.5 describe the environmental impacts from alternatives to license 

22 renewal. These alternatives include a natural gas-fired combined-cycle (NGCC) in Section 8.1; 

23 a combination alternative that includes wind power, solar power, compressed air energy 

24 storage, and NGCC capacity in Section 8.2; and a coal-fired alternative in Section 8.3. In 

25 Section 8.4, alternatives considered but dismissed from detailed consideration are identified. 

26 Finally, the environmental effects that may occur if NRC takes no action and does not issue a 

27 renewed license for Davis-Besse are discussed in Section 8.5. Section 8.6 summarizes the 

28 impacts of each of the alternatives considered.

29 Table 8.0–1. Summary of Alternatives Considered in Depth

Natural Gas (NGCC) 

Alternative Combination Alternative Supercritical Pulverized Coal (SCPC) Alternative 

Summary of 

alternative

Two NGCC units for a total 

of 910 MW 

Wind: 1,500 MW of installed wind 

capacity (315 MW for baseload;

360 MW to power CAES facility)

Solar: 400 MW of installed solar 

PV (75 MW for baseload; 75 MW 

to power CAES)

NGCC: One 305 MW unit

Two to three SCPC units for a total 

of 910 MW

Location

 

Davis-Besse; maximum 

use of existing transmission 

and cooling system 

infrastructures; Some 

pipeline transmission 

system upgrades may be

required 

Wind: Onshore wind projects 

would be spread across multiple 

sites throughout Ohio and CAES 

would be located at Norton Energy 

Storage Project in Norton, Ohio

Solar: PV facility would likely be 

located on agricultural land in 

Ohio; CAES would be located at 

Norton Energy Storage Project in 

Norton, Ohio

Alternative location due to space 

limitations at Davis-Besse site 

(FENOC 2011); Preferably an 

existing power plant site or 

brownfield site
Environmental Impacts of Alternatives

8-5 

Natural Gas (NGCC) 

Alternative Combination Alternative Supercritical Pulverized Coal (SCPC) Alternative 

NGCC: Plant would be located at

Davis-Besse site and use existing 

transmission and cooling system 

infrastructures

Cooling 

System

Closed-cycle with one 

natural draft cooling tower; 

Consumptive water use 

would be less than 

Davis-Besse 

(FENOC 2011)

Wind/Solar: CAES would use 

small-scale cooling towers; 

NGCC: Plant would use closedcycle cooling with one natural draft 

cooling tower; 

Total: Consumptive water use 

from CAES and NGCC unit 

considerably less than 

Davis-Besse

Closed-cycle cooling system with 

one natural draft cooling tower; 

Consumptive water use would be 

similar to Davis-Besse 

(FENOC 2011)

Land 

Requirements

110 ac (40.5 ha) land 

needed for the plant; 150 

ac (61 ha) land needed for 

25-mi pipeline (NRC 1996)

Wind: 75,000 ac (30,000 ha), with 

construction disturbance of 3,750 

ac (1,517 ha) (FENOC 2011)

Solar: 2,400 ac (970 ha) (NREL 

2008)

NGCC: Plant would require 

approximately 1/3 less than 

NGCC alternative; Pipeline would 

require 150 ac (61 ha) 

1,547 ac (626 ha) for the plant 

(FENOC 2011)

Work Force 1,092 to 2,275 during 

construction; 137 during 

operations (FENOC 2011)

Wind: 200 during construction; 50

during wind farm operations 

Solar: 200 during construction; 50 

for PV facility operations

CAES: 50 to 100 workers for 

CAES facility operations 

(FENOC 2011)

NGCC: 150 to 500 during 

construction; 91 during operations

1,092 to 2,275 during construction; 

228 during operations 

(FENOC 2011)

1 8.1 Natural Gas-Fired Combined-Cycle (NGCC) Alternative

2 Natural gas-fired combined-cycle (NGCC) systems represent the large majority of the total 

3 number of plants currently under construction or planned in the United States. Factors that 

4 contribute to NGCCs popularity include high capacity factors, low relative construction cost, low 

5 gas prices, and low air emissions. Development of new natural gas-fired plants may be affected 

6 by uncertainties regarding the continued availability and price of natural gas (though less so 

7 than in the recent past) and future regulations that may limit greenhouse gas (GHG) emissions. 

8 A gas-fired power plant, however, produces markedly fewer GHGs per unit of electrical output 

9 than a coal-fired plant of the same electrical output.

10 Combined cycle power plants differ significantly from most coal-fired and all existing nuclear 

11 power plants. Combined cycle plants derive the majority of their electrical output from a gas 

12 turbine and then generate additional power—without burning any additional fuel—through a 

13 second, steam turbine cycle. The exhaust gas from the gas turbine is still hot enough to boil 

14 water to steam. Ducts carry the hot exhaust to a heat recovery steam generator, which 

15 produces steam to drive a steam turbine and produce additional electrical power. The 
Environmental Impacts of Alternatives

8-6 

1 combined cycle approach is significantly more efficient than any one cycle on its own; thermal 

2 efficiency can exceed 60 percent versus 38 percent (NETL 2010; Siemens 2012). In addition, 

3 because the natural gas-fired alternative derives much of its power from a gas-turbine cycle, 

4 and because it wastes less heat than the existing Davis-Besse unit, it requires significantly less 

5 cooling water.

6 While nuclear reactors, on average, operate with capacity factors above 90 percent, an NGCC 

7 power plant would operate with roughly an 85 percent capacity factor. Nonetheless, a similarly

8 sized NGCC facility would be capable of providing adequate replacement power for the 

9 purposes of this NEPA analysis. Typical power trains for large-scale combined cycle power 

10 generation would involve one, two, or three combined cycle units, available in a variety of 

11 standard sizes. Appropriately sized units could produce electrical power in amounts equivalent 

12 to the Davis-Besse reactor. The combined cycle units are presumed to each be similar in 

13 operation to General Electric’s (GE’s) Advanced F Class design, equipped with dry-low-nitrogen 

14 oxide combustors to suppress nitrogen oxide formation and selective catalytic reduction (SCR) 

15 of the exhaust with ammonia for post-combustion control of nitrogen oxide emissions.

16 For the purpose of this analysis, the NRC staff will evaluate the impacts of a new 910 MW 

17 NGCC alternative. Installing the NGCC alternative on the Davis-Besse site would allow for the 

18 fullest use of existing infrastructure, such as transmission lines and cooling systems, and 

19 minimize construction impacts. Only a limited amount of buildable vacant land is available on 

20 the Davis-Besse site while allowing the reactor to continue operating until license expiration. 

21 However, the relatively modest footprint of an NGCC power plant, together with the expectation 

22 that the existing cooling tower and substation would be used to support the NGCC alternative, 

23 supports the conclusion that an NGCC facility could be installed on the Davis-Besse site. An 

24 NGCC alternative would also require a pipeline to deliver natural gas to the site. Depending on 

25 the availability of pipeline capacity, the existing pipeline transmission system may require some 

26 upgrades to support the new facility.

27 Natural gas fired power plants are feasible, commercially available options for providing electric 

28 generating capacity beyond Davis-Besse’s current license expiration. Environmental impacts 

29 from the NGCC alternative are summarized in Table 8.1-1 and discussed in depth in 

30 Section 8.1.1-9.

31 Table 8.1-1. Summary of Environmental Impacts of the NGCC Alternative Compared to 

32 Continued Operation of the Existing Davis-Besse

New NGCC at the Davis-Besse 

Site 

Continued Operation of the 

Davis-Besse Reactor

Air quality SMALL to MODERATE SMALL

Groundwater SMALL SMALL

Surface water SMALL SMALL

Aquatic resources SMALL SMALL

Terrestrial resources SMALL SMALL

Human health SMALL SMALL

Land use SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL
Environmental Impacts of Alternatives

8-7 

New NGCC at the Davis-Besse 

Site 

Continued Operation of the 

Davis-Besse Reactor

Transportation SMALL to MODERATE SMALL

Aesthetics SMALL SMALL

Historic & archeological resources SMALL to MODERATE SMALL to MODERATE

Waste management SMALL SMALL

1 8.1.1 Air Quality

2 Various Federal and State regulations aimed at controlling air pollution would impact a fossil 

3 fuel-fired power plant, including the NGCC alternative Davis-Besse is located in Ottawa County, 

4 which is part of the Sandusky Intrastate Air Quality Control Region. Ottawa County is 

5 designated as an attainment area for carbon monoxide (CO), ozone (O3), and particulate matter 

6 less than 2.5 μm (PM2.5). The county is designated as an unclassifiable area for particulate 

7 matter less than 10 μm (PM10), not designated for lead (Pb), better than the national air quality 

8 standards for sulfur dioxide (SO2) and cannot be classified or is better than national standards 

9 for nitrogen dioxide (NO2) (40 CFR 81.336). A new gas-fired 910 MWe (net) generating plant 

10 developed at the Davis-Besse site would qualify as a new major source of criteria pollutants 

11 (one with the potential to release more than 100 tons per year of any criteria pollutant) and 

12 require a New Source Review (NSR)/Prevention of Significant Deterioration (PSD) of Air Quality 

13 Review. The natural gas-fired plant would need to comply with the standards of performance 

14 for stationary gas turbines set forth in 40 CFR Part 60, Subpart KKKK.

15 Section 169A of the Clean Air Act (CAA) (42 USC 7401) establishes a national goal of 

16 preventing future and remedying existing impairment of visibility in mandatory Class I Federal 

17 areas when impairment results from anthropogenic air pollution (pollution resulting from human 

18 activities). The Regional Haze Rule, promulgated by EPA in 1999 and last amended in 

19 October 2006 (71 FR 60631), requires states to demonstrate reasonable progress toward the 

20 national visibility goal established in 1977 to prevent future impairment of visibility due to 

21 anthropogenic pollution in Class I areas. The visibility protection regulatory requirements are 

22 contained in 40 CFR Part 51, Subpart P, including the review of the new sources that would be 

23 constructed in the attainment or unclassified areas and may affect visibility in any Federal 

24 Class I area. If a gas-fired alternative were located close to a mandatory Class I area, 

25 additional air pollution control requirements would potentially apply; however, there are no 

26 Class I areas within 50 mi of the Davis-Besse site (EPA 2013).

27 EPA first promulgated the Clean Air Interstate Rule (CAIR) in 2005, permanently capping sulfur 

28 dioxide and nitrogen oxide emissions from stationary sources located in 28 states, including 

29 Ohio. However, the D.C. Circuit Court vacated the Federal rule on February 8, 2008. In 

30 December 2008, the U.S. Court of Appeals for the D.C. Circuit Court reinstated the rule, 

31 allowing it to remain in effect but also requiring EPA to revise both the rule and its 

32 implementation plan. On July 6, 2010, EPA instead proposed replacing CAIR with the 

33 Cross-State Air Pollution Rule (CSARP) for control of sulfur dioxide and nitrogen oxide 

34 emissions that cross State lines. On July 16, 2011, the EPA finalized the CSARP that requires 

35 28 states to improve air quality by reducing power plant emissions that cross state lines. 

36 CASRP required that the state of Ohio reduce annual SO2, NOx, and ozone emissions to assist 

37 in attaining clean air standards. However, on August 21, 2012, the U.S. Court of Appeals 

38 vacated the 2011 Cross-State Air Pollution rule and the 2005 CAIR rule remains in effect. A 
Environmental Impacts of Alternatives

8-8 

1 new NGCC source constructed in Ohio would be subject to emission limits for sulfur dioxide and 

2 nitrogen oxide promulgated under CAIR. 

3 Under the Federal Acid Rain Program, a new natural gas-fired plant would have to comply with 

4 Title IV of the CAA reduction requirements for sulfur dioxide and nitrogen oxide, which are the 

5 main precursors of acid rain and the major cause of reduced visibility. Title IV establishes 

6 maximum sulfur dioxide and nitrogen oxide emission rates from the existing plants and a system 

7 of the sulfur dioxide emission allowances that can be used, sold, or saved for future use by new 

8 plants.

9 Ohio is subject to nitrogen oxide State Implementation Plan (SIP) call regulations designed to 

10 reduce transport of ground-level ozone across State lines. A new NGCC alternative located in 

11 those states would be required to comply with those regulations limiting nitrogen oxide 

12 emissions (EPA 2009b).

13 In response to the Consolidated Appropriations Action of 2008 (Public Law 110-161), EPA 

14 promulgated final mandatory greenhouse gas (GHG) reporting regulations for major sources 

15 (emitting more than 25,000 tons/year (22,680 metric tons (MT)/year) of all GHGs), effective in 

16 December 2009 (EPA 2010a). This new NGCC plant would be subject to those reporting 

17 regulations. 

18 A natural gas-fired plant capable of producing utility-scale amounts of power would qualify as a 

19 major generator of GHGs under the “Tailoring Rule” promulgated by EPA. The Tailoring Rule 

20 established thresholds to regulate GHG emissions from stationary sources under the Clean Air 

21 Act (CAA), Prevention of Significant Deterioration (PSD), and Title V Operating Permit 

22 programs. Operating permits issued to major sources of GHG under the PSD or Title V Federal 

23 permit programs must contain provisions requiring the use of best available control technology 

24 (BACT) to limit the emissions of GHGs if those sources would be subject to PSD or Title V 

25 permitting requirements due to their non-GHG pollutant emission potentials and their estimated 

GHG emissions are at least 75,000 tons per year of carbon dioxide equivalents (CO2e).1 26 

27 Meeting permit limitations for GHG emissions may require installation of carbon capture and 

28 sequestration (CCS) devices on any new natural gas-fired power plant. Ohio EPA has adopted 

29 regulations equivalent to the Federal GHG Tailoring Rules (OEPA 2012).

30 8.1.1.1 Construction Impacts 

31 Activities associated with the construction of the new natural gas-fired plant at the Davis-Besse 

32 site would cause air impacts as a result of emissions from construction equipment and fugitive 

33 dust from operation of the earth-moving and material handling equipment. Gas-fired power 

34 plants are constructed relatively quickly; construction lead times for NGCC plants are around 

35 2 to 3 years (EIA 2011d; OECD/IEA, 2005). 

36 Analogous impacts would occur in association with offsite pipeline construction. All such 

37 impacts would be temporary. Workers’ vehicles and motorized construction equipment would 

38 generate temporary criteria pollutant emissions. Dust-control practices would reduce fugitive 

39 dust, which would be temporary in nature. Given the expected, relatively short construction 

40 period for both the NGCC facility and the pipeline, the NRC concludes that the impact of vehicle 

 

1 Carbon dioxide equivalents (CO2e) is a metric used to compare the emissions of GHG based on their Global warming potential 

(GWP). GWP is a measure used to compare how much heat a GHG traps in the atmosphere. GWP is the total energy that a gas 

absorbs over a period of time, compared to carbon dioxide. Carbon dioxide equivalents is obtained by multiplying the amount of the 

GHG by the associated GWP. For example, the GWP of CH4 is estimated to be 21; therefore, one ton of CH4 emission is equivalent 

to 21 tons of CO2 emissions. 
Environmental Impacts of Alternatives

8-9 

1 exhaust emissions, construction equipment, and fugitive dust from operation of earth-moving 

2 and material-handling equipment would be SMALL.

3 8.1.1.2 Operating Impacts

4 Using data and algorithms published by EPA and EIA and performance guarantees provided by 

5 pollution control equipment vendors, the NRC staff projects the following emissions for an 

6 NGCC alternative to the Davis-Besse reactor:

7 • sulfur oxides—70 tons (64 MT) per year, 

8 • nitrogen oxides—204 tons (185 MT) per year, 

9 • particulate matter less than or equal to 10 μm—136 tons (123 MT) per year, 

10 • carbon monoxide—309 tons (280 MT) per year, and

11 • carbon dioxide—2,270,000 tons (2,060,000 MT) per year. 

12 Sulfur and Nitrogen Oxides. As stated above, the new natural gas-fired alternative would 

13 produce 70 tons (64 MT) per year of sulfur oxide and 204 tons (185 MT) per year of nitrogen 

14 oxide based on the use of the dry low nitrogen oxide combustion technology and use of 

15 selective catalytic reduction (SCR) in order to significantly reduce nitrogen oxide emissions.

16 The new plant would be subjected to the continuous monitoring and reporting requirements of 

17 sulfur dioxide, nitrogen oxides, and carbon dioxide specified in 40 CFR Part 75. 

18 Particulates. The new natural gas-fired alternative would produce 136 tons (123 MT) per year

19 of particulates, all of which would be emitted as PM10. In addition to particulate emissions from 

20 the NGCC facility, small amounts of particulate would be released as drift from the cooling tower 

21 that supports the steam cycle. However, because the NGCC facility would have a smaller heat 

22 rejection demand than the reactor, the amount of drift presently being released from the tower 

23 as it supports the reactor is considered to be a bounding condition. FENOC estimated the 

24 release of particulates contained in cooling tower drift during reactor operation is 1.4 tons

25 per year, assuming calculation of particulate emissions contained in drift based on an average 

26 total dissolved solids (TDS) concentration of 228 parts per million (ppm) (TRC 1995).

27 Carbon Monoxide. Based on EPA emission factors (EPA 1998), the NRC staff estimates that 

28 the total CO emissions would be approximately 309 tons (280 MT) per year. 

29 Carbon Dioxide. The NRC estimates that uncontrolled emissions of CO2 from operation of the 

30 NGCC alternative would amount to 2.27 million tons per year (2.06 MMT per year). Although 

31 natural gas combustion in the combustion turbines would be the primary source, other 

32 miscellaneous ancillary sources—such as truck and rail deliveries of materials to the site and 

33 commuting of the workforce—would make minor contributions.

34 The Tailoring Rule will require that BACT be applied to control CO2 emissions. Carbon capture 

35 and sequestration (CCS) technologies can capture and remove as much as 90 percent of the 

36 CO2 from the exhausts of combustion turbines (CT) (NETL 2010). However, such equipment 

37 imposes a significant parasitic load that will result in a power production capacity decrease of 

38 approximately 14 percent, a reduction in net overall thermal efficiency of the CTs studied from 

39 50.8 percent to 43.7 percent, and a potential increase in the levelized cost of electricity 

40 produced in NGCC units so equipped by as much as 30 percent (NETL 2010). This can result 

41 in an increase in other air pollutants because more generation capacity would be necessary to 

42 supply the same electrical demand.
Environmental Impacts of Alternatives

8-10

1 Hazardous Air Pollutants. In December 2000, the EPA issued regulatory findings (EPA 2000b) 

2 on emissions of hazardous air pollutants (HAPs) from electric utility steam-generating units, 

3 which identified that natural gas-fired plants emit hazardous air pollutants such as arsenic, 

4 formaldehyde, and nickel. The EPA stated that “[t]he impacts due to HAP emissions from 

5 natural gas-fired electric utility steam generating units were negligible based on the results of 

6 the study. The Administrator finds that regulation of HAP emissions from natural gas-fired 

7 electric utility steam generating units is not appropriate or necessary.” As a result, the NRC 

8 staff will not further address HAPs here.

9 In addition to the air quality impacts associated with operation of the NGCC facility, additional air 

10 quality impacts would result from vehicles used by the commuting operating workforce. 

11 However, the NGCC workforce is smaller than the current operating workforce at Davis-Besse, 

12 so a change to an NGCC alternative will result in reductions in commuting-related air emissions. 

13 The impact from SO2, CO, PM, and NOX emissions during operation would be noticeable. 

14 Based on this information, the overall air quality impacts of operation of an NGCC plant located 

15 at the Davis-Besse site would be SMALL to MODERATE. 

16 8.1.2 Groundwater Use and Quality

17 8.1.2.1 Construction

18 As described in Section 2.1.7.2, groundwater at the Davis-Besse site is unsuitable as a drinking 

19 water source. Private wells within 2 to 3 mi of the site are not used for drinking water, but rather 

20 for irrigation and sanitary purposes. The impacts associated with groundwater use during 

21 construction would be similar to those associated with the construction of Davis-Besse. All 

22 open excavations will require dewatering, which would have a minor, localized impact on 

23 groundwater levels and flow rate at the site. The NRC assumes that during construction, liquid 

24 construction wastes will either temporarily be retained in lined evaporation ponds or will be 

25 stored in drums for shipment to offsite disposal facilities. With the application of best 

26 management practices and the controls established in a General Stormwater Permit, no 

27 noticeable impacts on groundwater quality due to the construction of the NGCC alternative are 

28 expected. As a result, impacts to groundwater quality would be SMALL.

29 8.1.2.2 Operation

30 Groundwater is not used at the Davis-Besse facility. The NRC presumes groundwater will not 

31 be used to operate the NGCC alternative; thus, the impacts to the groundwater resource would 

32 be SMALL.

33 8.1.3 Surface Water Use and Quality

34 8.1.3.1 Construction

35 A minimal amount of surface water is expected to be used to construct the NGCC, primarily for 

36 fugitive dust control, cleaning, and concrete mixing. Some impacts on surface water quality 

37 may result in increased sediment loading to stormwater runoff from active construction zones or 

38 from the dewatering of excavations; however, the NRC expects that a Stormwater General 

39 Permit would require best management practices that would prevent or significantly mitigate 

40 such impacts. Best management practices include controlling drainage by ditches, berms, and 

41 sedimentation basins; prompt revegetation to control erosion; stockpiling and reusing excavated 

42 topsoil; and various other techniques used to control soil erosion and water pollution. As a 
Environmental Impacts of Alternatives

8-11

1 result, surface water use and quality impacts during construction at Davis-Besse would be 

2 SMALL.

3 8.1.3.2 Operation

4 The gas-fired alternative would require much less cooling water than the existing Davis-Besse 

5 facility, because it operates at a higher thermal efficiency (nearly 60 percent) and because it 

6 requires much less water for steam cycle condenser cooling. The existing closed loop cooling 

7 system now supporting the reactor would be able to support a natural gas alternative on the 

8 Davis-Besse site without any increase in its current capacity. It would be supported by using 

9 freshwater recovered from the existing cooling water intake canal and discharging the blowdown 

10 water through the existing cooling system discharge pipe into Lake Erie. Under such a 

11 configuration, the rate of withdrawal of freshwater to support steam cycle cooling would be 

12 reduced. In conclusion, the impacts on surface water due to the operation of an NGCC plant 

13 would be less than the impacts associated with the continued operation of Davis-Besse (as 

14 discussed in Section 2.4, “Surface Water Resources”) and, thus, are considered to be SMALL.

15 8.1.4 Aquatic Ecology

16 8.1.4.1 Construction

17 Construction activities for the NGCC alternative would cause minimal impacts on aquatic 

18 resources in Lake Erie because construction would occur far enough inland to remove the 

19 likelihood of the erosion and sedimentation. Additionally, stormwater control measures, which 

20 would be required to comply with Ohio’s NPDES permitting, would minimize the flow of 

21 disturbed soils into aquatic habitats.

22 8.1.4.2 Operation

23 During operations, the NGCC alternative would require less cooling water to be withdrawn from 

24 and discharged to Lake Erie than required for Davis-Besse. Therefore, thermal impacts would 

25 be less for the NGCC alternative than Davis-Besse. The cooling system for a new NGCC plant 

26 would have similar chemical discharges as Davis-Besse. Air emissions from the NGCC plant 

27 would emit particulates that would settle onto the lake surface and introduce a new source of 

28 pollutants. However, lake tides would likely dissipate and dilute the concentration of pollutants 

29 resulting in minimal exposure to aquatic biota.

30 Consultation under the ESA would be required to assess the occurrence and potential impacts 

31 to Federally protected aquatic species and habitats within affected surface waters. Coordination 

32 with State natural resource agencies would further ensure that the NGCC operator would take 

33 appropriate steps to avoid or mitigate impacts to State-listed species, habitats of conservation 

34 concern, and other protected species and habitats. The NRC relies on these consultations to,

35 or eliminate, potential impacts to protected aquatic species and habitats.

36 The impacts on aquatic ecology would be minor because construction activities would require 

37 BMPs and stormwater management permits. Also, surface water discharge for this alternative 

38 would be less than for Davis-Besse. Deposition of pollutants into aquatic habitats from the 

39 plant’s air emissions would be minimal because the concentration of pollutants would be diluted 

40 with the lake tides. Therefore, the NRC staff concludes that impacts on aquatic ecology would 

41 be SMALL.
Environmental Impacts of Alternatives

8-12

1 8.1.5 Terrestrial Ecology

2 8.1.5.1 Construction

3 Construction of an NGCC alternative would occur on the Davis-Besse site and would use 

4 existing transmission lines. Because the onsite land requirement is relatively small, the entire 

5 NGCC alternative construction footprint would likely be sited in already developed areas of the 

6 Davis-Besse site, which would minimize impacts to terrestrial habitats and species. However, 

7 the level of direct impacts would vary based on the specific location of new buildings and 

8 infrastructure on the site. Offsite construction would occur mostly on land where gas extraction 

9 is already occurring. Erosion and sedimentation, fugitive dust, and construction debris impacts 

10 would be minor with implementation of BMPs. Construction noise could modify wildlife 

11 behavior; however, these effects would be temporary. Road improvements or construction of 

12 additional service roads to facilitate construction could result in the temporary or permanent loss 

13 of terrestrial habitat. Construction of gas pipelines along existing, previously disturbed utility 

14 corridors would result in temporary noise and displacement of wildlife, but would minimize the 

15 removal or destruction of undisturbed habitats. Impacts to terrestrial habitats and species from 

16 transmission line operation and corridor vegetation maintenance, and operation of the cooling 

17 towers would be similar in magnitude and intensity as those resulting from GGNS and would, 

18 therefore, be SMALL. 

19 As discussed under aquatic ecology impacts, consultation with the FWS under the ESA would 

20 ensure that the construction and operation of an NGCC alternative would not adversely affect 

21 any Federally listed species or adversely modify or destroy designated critical habitat. 

22 Coordination with state natural resource agencies would further ensure that the NGCC operator 

23 would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of 

24 conservation concern, and other protected species and habitats. The NRC assumes that these 

25 consultations would result in avoidance or mitigation measures that would minimize or eliminate 

26 potential impacts to protected terrestrial species and habitats. Consequently, the impacts of 

27 construction and operation of a new nuclear alternative on protected species and habitats would 

28 be SMALL.

29 8.1.5.2 Operation

30 Impacts on terrestrial species due to the operation of an NGCC plant would be similar to the 

31 impacts associated with the present operation of Davis-Besse. The monitoring of cooling-tower 

32 drift effects on terrestrial vegetation has shown no visible damage. In addition, where lines 

33 cross croplands and little or no vegetation control is required, impacts due to right-of-way 

34 (ROW) management on wildlife has all been determined to be small. As a result, the impacts 

35 on terrestrial resources from the operation of the NGCC alternative on the Davis-Besse site 

36 would be SMALL.

37 8.1.6 Human Health

38 8.1.6.1 Construction

39 Impacts on human health from construction of the NGCC alternative would be similar to impacts 

40 associated with the construction of any major industrial facility. Compliance with worker 

41 protection rules would control those impacts on workers at acceptable levels. Impacts from 

42 construction on the general public would be minimal since limiting active construction area 

43 access to authorized individuals is expected. Impacts on human health from the construction of 

44 the NGCC alternative would be SMALL.
Environmental Impacts of Alternatives

8-13

1 8.1.6.2 Operation

2 Human health effects of gas-fired generation are generally low. However, in Table 8-2 of the 

3 GEIS (NRC 1996), the NRC staff identified cancer and emphysema as potential health risks 

4 from gas-fired plants. NOx emissions contribute to ozone formation, which contributes to human 

5 health risks. Emission controls on the NGCC alternative can be expected to maintain NOx

6 emissions well below air quality standards established for the purposes of protecting human 

7 health, and emissions trading or offset requirements mean that overall NOx releases in the 

8 region will not increase. Health risks for workers may also result from handling spent catalysts 

9 used for NOx control that may contain heavy metals; however, appropriate handling precautions 

10 are expected to be followed. Impacts on human health from the operation of the NGCC 

11 alternative would be SMALL.

12 8.1.7 Land Use

13 The GEIS generically evaluates the impacts of constructing and operating various replacement 

14 power plant alternatives on land use, both on and off each power plant site. The analysis of 

15 land use impacts focuses on the amount of land area that would be affected by the construction 

16 and operation of a natural gas-fired combined-cycle power plant at the Davis-Besse site. 

17 Locating the new NGCC power plant at the Davis-Besse site would maximize the availability of 

18 support infrastructure and reduce the need for additional land.

19 8.1.7.1 Construction

20 Based on GEIS estimates, approximately 110 ac (40.5 ha) of land would be needed to support a 

21 new NGCC power plant (NRC 1996). This amount of land use would include other plant 

22 structures and associated infrastructure. Depending on the location and availability of existing 

23 natural gas pipelines, an additional 150 ac (61 ha) of land could be needed for a new 25-mi (41-

24 km) gas supply pipeline. 

25 In addition to onsite land requirements, land would be required offsite for natural gas wells and 

26 collection stations. Scaling from GEIS estimates, approximately 3,275 ac (1,325 ha) (based on 

27 3,600 ac per 1,000 MWe and 910 MWe for NGCC) (NRC 1996) would be required for wells, 

28 collection stations, and pipelines to bring the gas to the plant. Most of this land requirement 

29 would occur on land where gas extraction already occurs. Therefore, land use impacts from 

30 land acquisition would be SMALL to MODERATE, depending on location of a new gas supply 

31 pipeline and off-site wells and collection stations. 

32 8.1.7.2 Operation

33 The elimination of uranium fuel for Davis-Besse would partially offset some, but not all, of the 

34 land requirements for an NGCC alternative. Scaling from GEIS estimates, approximately 635 

35 ac (256 ha) (based on 35 ac/yr disturbed per 1,000 MWe for 20 years) would no longer be 

36 needed for mining and processing uranium during the operating life of the plant (NRC 1996). 

37 Operational land use impacts from an NGCC power plant would be SMALL. 

38 8.1.8 Socioeconomics

39 Socioeconomic impacts are defined in terms of changes to the demographic and economic 

40 characteristics and social conditions of a region. For example, the number of jobs created by 

41 the construction and operation of a new NGCC power plant could affect regional employment, 

42 income, and expenditures. Two types of jobs would be created by this alternative:(1) 
Environmental Impacts of Alternatives

8-14

1 construction jobs, which are transient, short in duration, and less likely to have a long-term 

2 socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for 

3 permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

4 operation of the NGCC power plant were evaluated to measure their possible effects on current 

5 socioeconomic conditions.

6 8.1.8.1 Construction

7 FENOC estimates a construction workforce ranging from 1,092 to 2,275 workers, which is 

8 consistent with GEIS estimates (FENOC 2011). During construction of the NGCC power plant, 

9 the communities surrounding the power plant site would experience increased demand for 

10 rental housing and certain public services. The relative economic impact of this many workers 

11 on the local economy and tax base would vary, with the greatest impacts occurring in the 

12 communities where the majority of construction workers would reside and spend their income. 

13 As a result, local communities could experience a short term economic “boom” from increased 

14 tax revenue and income generated by construction expenditures and the increased demand for 

15 temporary (rental) housing and business services. Some construction workers could relocate in 

16 order to be closer to the construction work site. However, given the proximity of Davis-Besse to 

17 the Toledo metropolitan area, workers could commute to the construction site, thereby reducing 

18 the need for rental housing.

19 After completing the installation of the NGCC plant, local communities could experience a return 

20 to pre-construction economic conditions. The rental housing market could experience increased 

21 vacancies and decreased prices. Based on this information and given the number of 

22 construction workers, socioeconomic impacts during construction in communities near the new 

23 NGCC at the Davis-Besse site could range from SMALL to MODERATE.

24 8.1.8.2 Operation

25 FENOC estimates an operations workforce of 137 employees (FENOC 2011). FENOC’s 

26 estimate appears to be reasonable and is consistent with trends toward lowering labor costs by 

27 reducing the size of power plant operations workforces. The reduction in employment at Davis28 Besse from reactor shutdown and decommissioning could affect property tax revenue and 

29 income in local communities and businesses. In addition, the permanent housing market could 

30 also experience increased vacancies and decreased prices if operations workers and their 

31 families move out of the region. However, the amount of taxes paid under the NGCC alternative 

32 may increase if additional land is required offsite to support this alternative. Based on the above 

33 discussion, socioeconomic impacts during operations could range from SMALL to MODERATE.

34 8.1.9 Transportation

35 Commuting workers and truck deliveries of materials and equipment to the Davis-Besse site 

36 would cause transportation impacts during the construction and operation of the NGCC power 

37 plant. 

38 8.1.9.1 Construction

39 During construction, 1,092 to 2,275 workers could be commuting daily to the construction site. 

40 Arriving by site access roads, the volume of traffic on nearby roads could increase substantially 

41 during shift changes. In addition to commuting workers, trucks would be transporting 

42 construction materials and equipment to the worksite, thus increasing the amount of traffic on 

43 local roads. Traffic volumes would peak during shift changes, resulting in temporary levels of 
Environmental Impacts of Alternatives

8-15

1 service impacts and delays at intersections. Pipeline construction and modifications to existing 

2 natural gas pipeline systems could also have a temporary traffic impact. Some power plant 

3 components and materials could be delivered by train or barge. Train deliveries could cause 

4 additional traffic delays at railroad crossings. Overall, traffic-related transportation impacts 

5 during construction likely would be MODERATE.

6 8.1.9.2 Operation

7 Traffic-related transportation impacts would be greatly reduced after completing the installation 

8 of the NGCC alternative. Transportation impacts would include daily commuting by the 

9 operating workforce, equipment and materials deliveries, and the removal of commercial waste 

10 material by truck to offsite disposal or recycling facilities. Since fuel is transported by pipeline, 

11 the transportation infrastructure would experience little to no increased traffic from fuel 

12 operations. Overall, transportation impacts would be SMALL during plant operations.

13 8.1.10 Aesthetics

14 The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC 

15 alternative and the surrounding landscape and the visibility of the new NGCC plant at the 

16 Davis-Besse site.

17 8.1.10.1 Construction

18 During construction, all of the clearing and excavation would occur on the existing Davis-Besse 

19 power plant site. These activities could be visible from offsite roads. Since the existing power 

20 plant site would already appear industrial, construction of the NGCC power plant would appear 

21 similar to other ongoing onsite activities. Aesthetic changes during construction would be 

22 limited to the immediate vicinity of the existing Davis-Besse site, and overall impacts would be 

23 SMALL. 

24 8.1.10.2 Operation

25 The facility would be visible offsite during daylight hours, and some structures, such as the 

26 approximately 150 ft (45 m) high exhaust stacks or natural draft cooling tower, may require 

27 aircraft warning lights (FENOC 2011). During certain weather conditions, the plume from the 

28 cooling tower would be visible for long distances. In general, given the industrial appearance of 

29 the Davis-Besse site, an NGCC alternative would blend in with the surroundings if the existing 

30 Davis-Besse facility remains. In addition, the visible appearance of the NGCC power block 

31 could look similar to the existing Davis-Besse power block. Since the new NGCC power plant 

32 would appear similar to the existing Davis-Besse power plant, overall operational impacts would 

33 be SMALL.

34 8.1.11 Noise 

35 Ambient noise conditions in the vicinity of Davis-Besse would be affected by the construction 

36 and operation of a new NGCC power plant.

37 8.1.11.1 Construction

38 Noise levels at the Davis-Besse site would increase during the construction of the new NGCC 

39 power plant. Noise during construction, however, would be intermittent and limited to the peak 
Environmental Impacts of Alternatives

8-16

1 periods of activity and would diminish over distance. Noise impacts during construction of the 

2 NGCC power plant could range from SMALL to MODERATE.

3 8.1.11.2 Operation

4 Noise during NGCC power plant operations would be similar to noise generated during reactor 

5 operations and would be limited to those caused by normal industrial processes and 

6 communications. Pipelines delivering natural gas fuel could be audible near gas compressor 

7 stations. Noise impacts during NGCC power plant operations would be SMALL.

8 8.1.12 Historic and Archaeological Resources

9 The potential for impacts on historic and archaeological resources from the NGCC alternative 

10 would vary greatly depending on the location of the proposed plant on the Davis-Besse site. As 

11 the parcel of land on which Davis-Besse is situated has not been surveyed for historic and 

12 archaeological resources, plant operators would need to survey all areas associated with 

13 operation of the alternative (e.g., a new pipeline, roads, transmission corridors, other ROWs). If 

14 a previously disturbed area of the site was used, an inventory would still be necessary to verify 

15 the level of disturbance and evaluate the potential for intact subsurface resources. Any 

16 resources found in these surveys would need to be evaluated for eligibility on the National 

17 Register of Historic Properties (NRHP), and mitigation of adverse effects would need to be 

18 addressed if eligible resources were encountered. Areas with the greatest sensitivity should be 

19 avoided. Visual impacts on significant cultural resources—such as the viewsheds of historic 

20 properties near the site—also should be assessed. 

21 As the Davis-Besse site has not been previously surveyed, the level of impact to historic and 

22 archaeological resources would vary depending on the specific resources found to be present in 

23 the area of potential effect. However, given that the majority of the site is unusable marsh land 

24 and the preference is to use previously disturbed areas of the site and existing infrastructure, 

25 avoidance of significant historic and archaeological resources should be possible. Therefore, 

26 the impacts on historic and archaeological resources from the NGCC alternative would be 

27 SMALL to MODERATE. 

28 8.1.13 Environmental Justice

29 The environmental justice impact analysis evaluates the potential for disproportionately high and 

30 adverse human health, environmental, and socioeconomic effects on minority and low-income 

31 populations that could result from the construction and operation of a new power plant. Minority 

32 and low-income populations are subsets of the general public living near the proposed power 

33 plant site.

34 Adverse health effects are measured in terms of the risk and rate of fatal or non-fatal adverse 

35 impacts on human health. Disproportionately high and adverse human health effects occur 

36 when the risk or rate of exposure to an environmental hazard for a minority or low-income 

37 population is significant and exceeds the risk or exposure rate for the general population or for 

38 another appropriate comparison group. Disproportionately high environmental effects refer to 

39 impacts or risk of impact on the natural or physical environment in a minority or low-income 

40 community that are significant and appreciably exceed the environmental impact on the larger 

41 community. Such effects may include biological, cultural, economic, or social impacts. For 

42 example, increased demand for rental housing during replacement power plant construction 

43 could disproportionately affect low-income populations that rely on the previously inexpensive 

44 rental housing market.
Environmental Impacts of Alternatives

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1 8.1.13.1 Construction

2 Potential impacts to minority and low-income populations would mostly consist of environmental 

3 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

4 housing impacts). Noise and dust impacts during construction would be short term and 

5 primarily limited to onsite activities. Minority and low-income populations residing along site 

6 access roads would be directly affected by increased commuter vehicle and truck traffic. 

7 However, because of the temporary nature of construction, these effects are unlikely to be high 

8 and adverse and would be contained to a limited time period during certain hours of the day. 

9 Increased demand for rental housing during construction could cause rental costs to rise 

10 disproportionately affecting low-income populations living near the site who rely on inexpensive 

11 housing. However, given the proximity of Davis-Besse to the Toledo metropolitan area, workers 

12 could commute to the construction site, thereby reducing the need for rental housing. 

13 Based on this information and the analysis of human health and environmental impacts 

14 presented in Section 8.1 of this chapter, the construction of a new NGCC power plant would not 

15 have disproportionately high and adverse human health and environmental effects on minority 

16 and low-income populations.

17 8.1.13.2 Operation

18 Emissions from the operation of an NGCC plant could affect minority and low-income 

19 populations as well as the general population living in the vicinity of the new power plant. 

20 However, all would be exposed to the same potential effects from NGCC power plant 

21 operations, and any impacts would depend on the magnitude of the change in ambient air 

22 quality conditions. Permitted air emissions are expected to remain within regulatory standards.

23 Based on this information and the analysis of human health and environmental impacts 

24 presented in Section 8.1 of this chapter, the construction and operation of a new NGCC power 

25 plant would not have disproportionately high and adverse human health and environmental 

26 effects on minority and low-income populations.

27 8.1.14 Waste Management

28 8.1.14.1 Construction

29 During the construction stage of this alternative, land clearing and other construction activities 

30 would generate waste that can be recycled, disposed of onsite, or shipped to an offsite waste 

31 disposal facility. Because the NGCC alternative would most likely be constructed on the 

32 previously disturbed portions of the Davis-Besse site, the amounts of wastes produced during 

33 land clearing would be minimal. As a result, construction related impacts due to the 

34 construction of the NGCC alternative due to waste management would be SMALL.

35 8.1.14.2 Operation

36 This NGCC alternative would produce relatively little waste, primarily in the form of spent SCR 

37 catalysts used for control of NOx emissions. The NRC staff presumes that the SCR technology 

38 employed would involve introducing ammonia into the exhaust ducts of the cooling towers 

39 where it combines with NOx in a nickel catalyst bed to form zero valent nitrogen and water. 

40 Based on data provided by the Institute of Clean Air Companies, EPA acknowledges that typical 

41 SCR devices can demonstrate removal efficiencies of 70 to 90 percent (EPA 2000a).
Environmental Impacts of Alternatives

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1 Because the specific NOx emission control equipment cannot be specified at this time, the 

2 amount of spent catalysts that would be generated during each year of operation of the NGCC 

3 alternative also cannot be calculated with precision. However, the amount would be modest. 

4 Domestic and sanitary wastes would be expected to decrease from amounts now generated 

5 during the operation of the reactors due to a reduced operational workforce for the NGCC 

6 alternative. According to the 1996 GEIS, a natural gas-fired plant would generate minimal 

7 waste; therefore, waste impacts from an NGCC facility at Davis-Besse would be SMALL.

8 8.1.15 Climate Change-Related Impacts of a Natural Gas-Fired Combined Cycle 

9 Alternative

10 Combustion of fossil fuels, including natural gas, is the greatest anthropogenic source of GHG 

11 emissions in the U.S. After a thorough examination of the scientific evidence and careful 

12 consideration of public comments, the EPA announced on December 7, 2009, that GHGs 

13 threaten the public health and welfare of the American people and meet the CAA definition of air 

14 pollutants. Carbon dioxide (CO2) is the largest GHG emitted during fossil fuel combustion and is 

15 of primary concern for global climate change. Climate changes (in the U.S. and globally) have 

16 been observed over the past 50 years and future climate changes are expected to continue 

17 (USGCRP 2009). The observed global climate-related changes are primarily due to 

18 human-induced emissions of GHGs (USGCRP 2009). The extent and nature of climate change 

19 is not specific to where GHGs are emitted, as these emissions are transported and mixed in the 

20 atmosphere. However, an NGCC alternative would contribute GHG emissions. This section 

21 presents an assessment of the potential impacts the construction and operation of an NGCC 

22 alternative will have on climate change.

23 8.1.15.1 Construction

24 Impacts to climate change from the construction of an NGCC alternative would result primarily 

25 from the consumption of fossil fuels in the engines of construction vehicles and equipment, 

26 workforce vehicles used in commuting to and from the work site, and delivery vehicles. 

27 Analogous impacts would occur in association with offsite pipeline construction. All such 

28 impacts, however, would be temporary. 

29 Although natural gas combustion in the combustion turbines would be the primary source, other 

30 miscellaneous ancillary sources such as truck and rail deliveries of materials to the site and 

31 commuting of the workforce would make minor contributions.

32 Given an expected relatively short construction period for both the NGCC facility and the 

33 pipeline, the overall impact on climate change from the releases of GHGs during construction of 

34 the NGCC alternative would be SMALL.

35 8.1.15.2 Operation

36 The NRC estimates that emissions of CO2e from operation of the NGCC alternative would 

37 amount to 2.07 MMT (2.29 million tons) per year. GHG emissions resulting from operation 

38 would be noticeable. Estimated GHG emissions would be three times larger than the threshold 

39 in EPA’s tailoring rule for GHG (75,000 tons (68,000 MT) per year of carbon dioxide equivalent). 

40 EPA reported that, in 2010, the total amount of carbon dioxide equivalent (CO2e) emissions 

41 related to electricity generation was 2,277.3 teragrams (2,277.3 MMT) (EPA 2012). EIA 

42 reported that, in 2010, electricity production in Ohio was responsible for 121 MMT of CO2

43 emissions (123 MMT CO2e) (EIA 2012). The estimated CO2e emitted from operation of the 

44 NGCC alternative amount represents 0.099 percent and 1.7 percent, respectively, of 2010 U.S. 
Environmental Impacts of Alternatives

8-19

1 and Ohio CO2e emissions. This amount represents an increase of 1.7 percent over the 2010 

2 Ohio CO2e emissions. Although natural gas combustion in the combustion turbines would be 

3 the primary source, other miscellaneous ancillary sources—such as truck and rail deliveries of 

4 materials to the site and commuting of the workforce—would make minor GHG contributions.

5 As previously discussed, CCS will capture and remove as much as 90 percent of the CO2 from 

6 the exhausts of combustion turbines (NETL 2010). With CCS in place, the NGCC alternative 

7 would release 0.21 MMT per year (0.23 million tons) of CO2, and the impact on climate change 

8 from this alternative would be further reduced.

9 The impact of the operation of an NGCC facility on climate change would be SMALL to 

10 MODERATE. 

11 8.2 Combination Alternative

12 The combination alternative consists of 1,500 MW of installed wind capacity spread out over 

13 multiple sites—315 MW effective capacity for baseload generation and 360 MW to power CAES 

14 facility, 400 MW of installed solar photovoltaic (PV) capacity (75 MW effective capacity for 

15 baseload generation and 75 MW to power CAES facility), and 305 MW of NGCC capacity to 

16 provide the balance needed to replace Davis-Besse. All wind projects would be land-based 

17 because there are currently no operating offshore wind projects in the U.S.

18 The feasibility of wind as a baseload power source depends on the availability, accessibility, and 

19 constancy of the wind resource within the region of interest. Ohio has approximately 

20 55,000 MW of wind power potential (NREL 2011) and has approximately 449 MW of operating 

21 wind projects, 802 MW of OPSB-approved projects that have not yet started operations, and 

22 524 MW of wind projects in review for a Certificate of Environmental Compatibility and Public 

23 Need (OPSB 2013). The largest wind project in Ohio history, Blue Creek Wind Farm, was 

24 recently completed in March 2012 and has an installed capacity of 304 MW. 

25 Wind power installations, which may consist of several hundred turbines, produce variable 

26 amounts of electricity. Davis-Besse, however, produces electricity almost constantly. Because 

27 wind power installations deliver variable output when wind conditions change, wind power 

28 cannot substitute for existing baseload generation on a one-to-one basis. A study by Archer 

29 and Jacobsen (2007) found that an array of 19 sites spread across the American southwest

30 (with approximately 850 km (530 mi) distance from east to west and north to south) could 

31 provide 21 percent of installed capacity 79 percent of the time. In other words, 21 percent of the 

32 array’s capacity was essentially available as baseload generation. While wind power 

33 installations in Archer and Jacobsen’s study, in most cases, accessed higher power-class wind 

34 resources than are available onshore in Ohio, the NRC staff will adopt Archer and Jacobsen’s 

35 approach for the purpose of this analysis. For the combination alternative analysis, the NRC 

36 staff assumes that an array containing 1,500 MW installed wind capacity could potentially 

37 replace a portion—315 MW—of Davis-Besse’s capacity. (The NRC staff is unable to find any 

38 determination for effective capacity factors from regional transmission organizations or 

39 independent system operators that are based on an interconnected array of wind installations, 

40 as none currently exists. The NRC staff also notes that it is possible that no interconnected 

41 arrays will exist in any state by 2017.)

42 Wind power, in general, cannot be stored without first being converted to electrical energy. 

43 There are limited energy storage opportunities available to overcome the variability of wind 

44 resource availability. CAES is a commercially viable technology for energy storage, though it is 
Environmental Impacts of Alternatives

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1 seldom used on a utility scale. In CAES, an electric motor uses excess electricity to pump air 

2 intro an underground, pressurized cavity. When electricity is needed, the compressed air is 

3 released through a gas turbine generator. The compressed air provides some power to the 

4 generator (essentially, reducing the need for compression by the turbine), and burning natural 

5 gas provides head to increase the pressure and power the turbine. Thus, CAES is not solely an 

6 energy storage technology, but it also relies on additional fossil fuel. This technology is 

7 currently in use at one site in the U.S. and one site in Germany, with capacities of 110 MWe and 

8 290 MWe, respectively.

9 For the combination alternative, the remaining 24 percent of the total 1,500 MW installed wind 

10 capacity—equivalent to 360 MW—will provide power to the Norton Energy Storage Project, a 

11 CAES facility that can supply power to the grid when the wind is not blowing. FENOC indicates 

12 that the Norton Energy Storage facility could have a maximum of 536 MW of capacity available 

13 by 2017 (although it has not committed to install this capacity in that time period) and the 

14 maximum potential storage capacity at the facility is 2,700 MWe. The NRC staff recognizes that 

15 wind dynamics, daily and seasonal variation, and Norton’s operational characteristics may limit 

16 the ability to store and release energy to offset the wind’s variability. CAES is less effective at 

17 offsetting seasonal wind variation than it is at offsetting intra-day or day-to-day variation. 

18 Offsetting month-to-month variations or seasonal variations would require very large air 

19 reservoirs. However, for the purposes of this analysis, the NRC staff will assume that Norton 

20 Energy Storage is capable of capturing the extra energy produced for purposes of this analysis 

21 and releasing it when needed. 

22 In addition, the NRC staff considers 400 MW of installed PV capacity (150 MW effective 

23 capacity) as part of this combination alternative. Solar PV systems use the sun’s energy to 

24 produce electricity at a utility scale, converting the energy contained in the photons of sunlight 

25 incident to direct current electricity that is aggregated, converted to alternating current, and 

26 connected to the high-voltage transmission grid. Currently, Ohio’s largest completed solar PV 

27 installation, the Wyandot Solar Farm, has 12 MW of capacity (PSEG Solar 2010), though the 

28 Turning Point Solar Facility is currently under construction, and will ultimately have 49.9 MW of 

29 solar capacity. Turning Point and Ohio Air Quality claim the Turning Point facility will be the 

30 largest solar facility east of the Mississippi, with the first 20 MW scheduled to come on-line in 

31 2013 (OAQDA undated). In its supplement to the ER, FENOC indicated that the average 

32 capacity factors for solar projects were 24 percent based on an NREL publication from 2002 

33 (FENOC 2011). The NRC staff notes that PJM Interconnection (PJM) (the regional 

34 transmission operator that manages most of Ohio’s electricity market, though not the First 

35 Energy service territories) published more recent information that indicates that solar power 

36 within the PJM system has an effective capacity factor of 38 percent (PJM 2010). In order to 

37 achieve an effective capacity of 150 MW and relying on PJM’s capacity factor, 400 MW of new 

38 installed solar PV capacity would be required by 2017. While this amount of PV capacity 

39 exceeds planned utility-scale installations in Ohio, this capacity may be achievable by 2017 

40 given the short lead times necessary for PV installation and experience with facilities like 

41 Wyandot and Turning Point. Of the 150 MW effective capacity, 75 MW would be used 

42 immediately, and 75 MW would be used to power the Norton Energy Storage project, which 

43 could then run during times when the sun is not shining or is otherwise less intense. 

44 Finally, this combination alternative contains a 305-MW NGCC unit capable of within-day 

45 cycling to provide the remaining 158 MW of Davis-Besse’s capacity and to provide back-up 

46 capacity to the wind and solar installations with the remaining capacity. As needed, this 

47 alternative also provides additional output to the Norton Energy Storage project during times 

48 when the unit would otherwise function in a spinning-reserve or hot-standby mode. Such a unit 
Environmental Impacts of Alternatives

8-21

1 is commercially available and operates with a relatively high thermal efficiency of 57 percent

2 (Siemens 2011). The NRC staff notes that this NGCC unit would spend a substantial amount of 

3 time either generating electricity to account for variable wind and solar outputs or functioning as 

4 spinning reserve.

5 The NRC staff notes that Norton Energy Storage has an additional 29 MW of capacity that is not 

6 expressly accounted for in this alternative, but it is likely that this capacity would be fully used at 

7 some times given the variability of wind and solar energy outputs. The NRC staff also notes 

8 that Norton Energy Storage provides power from a mix of natural gas combustion and 

9 compressed air. The Norton Energy Storage Project, by using stored energy, acts like a natural 

10 gas combustion turbine with a 78 percent thermal efficiency. The stored energy in the Norton 

11 Energy Storage Project, however, cannot be released without combustion of natural gas.

12 Table 8.2-1 summarizes the environmental impacts of the combustion alternative compared to 

13 the continued operation of Davis-Besse. 

14 Table 8.2-1. Summary of Environmental Impacts of the Combination Alternative 

15 Compared to Continued Operation of the Existing Davis-Besse

Combination Alternative Continued Operation of the 

Davis-Besse Reactor

Air quality SMALL SMALL

Groundwater SMALL SMALL

Surface water SMALL SMALL

Aquatic resources SMALL SMALL

Terrestrial resources SMALL to MODERATE SMALL

Human health SMALL SMALL

Land use SMALL to LARGE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics SMALL to LARGE SMALL

Historic & archeological resources SMALL to LARGE SMALL to MODERATE

Waste management SMALL SMALL

16 8.2.1 Air Quality

17 Air quality impacts from this alternative come primarily from the operation of the NGCC and 

18 Norton Energy Storage Project portions. Wind and solar power produce no direct air emissions 

19 during operations. During construction, wind and solar installations have the potential to create 

20 fugitive dust and emissions from equipment used during construction and installation. These 

21 impacts are limited in duration, however, and dust would be controlled by best management 

22 practices on construction sites. This section, then, focuses on the impacts that result from the 

23 NGCC portion of the alternative and from the Norton Energy Storage Project. 

24 Various Federal and State regulations aimed at controlling air pollution would impact a fossil 

25 fuel-fired power plant, including the NGCC portion of this alternative located anywhere within 
Environmental Impacts of Alternatives

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1 FENOC’s three Ohio service areas, and to the Norton Energy Storage Project. A new gas-fired 

2 305 MWe (net) generating plant developed at the Davis-Besse site would qualify as a new 

3 major source of criteria pollutants (one with the potential to release more than 100 tons per year

4 of any criteria pollutant) and require an New Source Review (NSR)/Prevention of Significant 

5 Deterioration (PSD) of Air Quality Review. The natural gas-fired plant would need to comply 

6 with the standards of performance for stationary gas turbines set forth in 40 CFR Part 60, 

7 Subpart KKKK.

8 Compressed air energy storage creates operational air-quality impacts because the Norton 

9 Energy Storage Project relies on gas-fired turbines to heat the air released from underground 

10 storage and, thus, provide some of the energy produced by the compressed air storage system. 

11 FENOC estimated emissions for the Norton Energy Storage Project based on a six combustion 

12 trains and one cooling tower, to match the amounts permitted by the Norton Energy Storage

13 Project’s air emissions permit. The NRC staff notes that this overestimates the air quality 

14 impacts from the four trains that FENOC indicates could be operational at the Norton Energy 

15 Storage Project by 2017. The NRC staff has scaled the air emissions from the Norton Energy 

16 Storage Project to provide an estimate for four trains rather than six, while acknowledging that 

17 this estimate may slightly over or underestimate impacts of four trains, depending on their 

18 operational characteristics and whether additional trains benefit from efficiencies of scale or 

19 require additional support services. The Norton Energy Storage project would also be subject to 

20 the standards of performance for stationary gas turbines set forth in 40 CFR Part 60, 

21 Subpart KKKK.

22 Section 169A of the CAA (42 USC 7401) establishes a national goal of preventing future, and 

23 remedying existing, impairment of visibility in mandatory Class I Federal areas when impairment 

24 results from anthropogenic air pollution. The Regional Haze Rule, promulgated by EPA in 1999 

25 and last amended in October 2006 (71 FR 60631), requires states to demonstrate reasonable 

26 progress toward the national visibility goal established in 1977 to prevent future impairment of 

27 visibility due to anthropogenic pollution in Class I areas. The visibility protection regulatory 

28 requirements are contained in 40 CFR Part 51, Subpart P, including the review of the new 

29 sources that would be constructed in the attainment or unclassified areas and may affect 

30 visibility in any Federal Class I area. If the gas-fired portion or the Norton Energy Storage 

31 project were located close to a mandatory Class I area, additional air pollution control 

32 requirements would potentially apply; however, there are no Class I areas within 50 mi of the 

33 Davis-Besse site or Norton, Ohio (EPA 2013).

34 A newly constructed natural gas-fired plant and the Norton Energy Storage project in Ohio 

35 would be subject to emission limits for sulfur dioxide and nitrogen oxide promulgated under 

36 CAIR. 

37 Under the Federal Acid Rain Program, the NGCC and the Norton Energy Storage project would 

38 have to comply with Title IV of the CAA reduction requirements for SO2 and NOx, which are the 

39 main precursors of acid rain and the major cause of reduced visibility. Title IV establishes 

40 maximum SO2 and NOx emission rates from the existing plants and a system of the SO2

41 emission allowances that can be used, sold, or saved for future use by new plants.

42 Ohio is subject to NOx SIP call regulations designed to reduce transport of ground-level ozone 

43 across state lines. A new NGCC alternative located in those states would be required to comply 

44 with those regulations limiting NOx emissions (EPA 2009b).

45 In response to the Consolidated Appropriations Action of 2008 (Public Law 110-161), EPA 

46 promulgated final mandatory GHG reporting regulations for major sources (emitting more than 
Environmental Impacts of Alternatives

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1 25,000 tons per year (22,680 MT per year) of all GHGs), effective in December 2009 

2 (EPA 2010a). This new NGCC plant and Norton Energy Storage project would be subject to 

3 those reporting regulations. Future regulations may require control of CO2 emissions. 

4 The NGCC and the Norton Energy Storage capable of producing utility-scale amounts of power 

5 would qualify as a major generator of GHGs under the “Tailoring Rule” promulgated by EPA. 

6 The Tailoring Rule established thresholds to regulate GHG emissions from stationary sources 

7 under the Clean Air Act (CAA), Prevention of Significant Deterioration (PSD), and Title V 

8 Operating Permit programs. Operating permits issued to major sources of GHG under the PSD 

9 or Title V Federal permit programs must contain provisions requiring the use of best available 

10 control technology (BACT) to limit the emissions of GHGs if those sources would be subject to 

11 PSD or Title V permitting requirements due to their non-GHG pollutant emission potentials and 

12 their estimated GHG emissions are at least 75,000 tons per year of carbon dioxide equivalents. 

13 Meeting permit limitations for GHG emissions may require installation of carbon capture and 

14 sequestration (CCS). Ohio EPA has adopted regulations equivalent to the Federal GHG 

15 Tailoring Rules (OEPA 2012). 

16 8.2.1.1 Construction Impacts 

17 Activities associated with the construction of all portions of this alternative would result in 

18 emissions from construction equipment, installation, and fugitive dust from operation of the 

19 earth-moving material. Dust-control practices would reduce fugitive dust. Offsite pipeline 

20 construction activity would be temporary. Workers’ vehicles and motorized construction 

21 equipment would generate criteria pollutant emissions. Given the expected relatively short 

22 construction period, the overall air quality impacts would be SMALL. 

23 8.2.1.2 Operating Impacts

24 Operation of the NGCC and Norton Energy Storage project are the primary portions of the 

25 combination alternative that will result in emissions. Beyond maintenance of the wind turbines

26 and solar PV (e.g., serving equipment or repairs), there would be no direct air emissions 

27 associated with operations from wind generation or from solar PV. 

28 Using data and algorithms published by EPA and EIA and performance guarantees provided by 

29 pollution control equipment vendors, the NRC staff projects the following emissions for the 

30 NGCC portion of this alternative:

31 • sulfur oxide—24 tons (22 MT) per year, 

32 • nitrogen oxide—105 tons (95 MT) per year, 

33 • particulate matter less than or equal to 10 μm—47 tons (43 MT) per year, 

34 • carbon monoxide—106 tons (96 MT) per year, and 

35 • carbon dioxide—825,000 tons (748,000 MT) per year. 

36 The NRC staff estimates that the Norton Energy Storage project would have the following 

37 emissions:

38 • sulfur oxide—28 tons (25 MT) per year, 

39 • nitrogen oxide—62 tons (57 MT) per year, 

40 • particulate matter less than or equal to 10 μm—31 tons (28 MT) per year, 

41 • carbon monoxide—60 tons (55 MT) per year, and 

42 • carbon dioxide—450,000 tons (410,000 MT) per year. 
Environmental Impacts of Alternatives

8-24

1 Sulfur and Nitrogen Oxides. The combination of the NGCC portion of this alternative and the 

2 Norton Energy Storage project would produce a combined 52 tons (47 MT) per year of SOx and 

3 167 tons (152 MT) per year of NOx based on the use of the dry low NOx combustion technology 

4 and the use of SCR in order to significantly reduce NOx emissions.

5 The new plant would be subjected to the continuous monitoring and reporting requirements of 

6 SO2, NOx, and CO2 specified in 40 CFR Part 75.

7 Particulates. The combination of the NGCC portion of this alternative and the Norton Energy 

8 Storage project would produce a combined 78 tons (71 MT) per year of particulates, all of which 

9 would be emitted as PM10. In addition to particulate emissions from the NGCC facility, small 

10 amounts of particulate would be released as drift from the cooling tower that supports the 

11 NGCC facility and the Norton Energy Storage project. The amount of drift released by the 

12 NGCC portion and Norton Energy Storage (which does not require water for steam condensing) 

13 would be less than that presently being released from the Davis-Besse tower as it supports the 

14 reactor since the cooling tower for a nuclear reactor has higher heat rejection demands and is 

15 considered to be a bounding condition.

16 Carbon Monoxide. Based on EPA emission factors (EPA 1998), NRC staff estimates that the 

17 total CO emissions would be approximately 166 tons (151 MT) per year. 

18 Carbon Dioxide. The NRC estimates that uncontrolled emissions of CO2 from operation of the 

19 NGCC alternative and Norton Energy Storage would amount to 1.28 million tons (approximately 

20 1.16 million MT) per year. Although natural gas combustion in the combustion turbines at the 

21 NGCC facility and the Norton Energy Storage project would be the primary source, other 

22 miscellaneous ancillary sources—such as truck and rail deliveries of materials to the site and 

23 commuting of the workforce—would make minor contributions.

24 The Tailoring Rule will require that BACT be applied to control CO2 emissions. Carbon capture 

25 and sequestration (CCS) technologies will eventually capture and remove as much as 

26 90 percent of the CO2 from the exhausts of combustion turbines (NETL 2010). However, NETL 

27 estimates that such equipment imposes a significant parasitic load that will result in a power 

28 production capacity decrease of approximately 14 percent, a reduction in net overall thermal 

29 efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a potential increase in the 

30 levelized cost of electricity produced in NGCC units so equipped by as much as 30 percent

31 (NETL 2010). The reduced efficiencies that would come with CCS, however, would necessitate 

32 that the facilities consume more fuel and emit larger amounts of other pollutants to provide the 

33 same output.

34 Hazardous Air Pollutants. In December 2000, the EPA issued regulatory findings (EPA 2000b) 

35 on emissions of HAPs from electric utility steam-generating units, which identified that natural 

36 gas-fired plants emit hazardous air pollutants such as arsenic, formaldehyde, and nickel. The 

37 EPA stated that “[t]he impacts due to HAP emissions from natural gas-fired electric utility steam 

38 generating units were negligible based on the results of the study. The Administrator finds that 

39 regulation of HAP emissions from natural gas-fired electric utility steam generating units is not 

40 appropriate or necessary.” As a result, the NRC staff will not further address HAPs here.

41 In addition to the air quality impacts associated with operation of the NGCC facility and Norton 

42 Energy Storage project, additional air quality impacts would result from vehicles used by the 

43 commuting operating workforce. However, the workforce employed by this combination 

44 alternative is smaller than the current operating workforce at Davis-Besse, so this alternative will 

45 result in reductions in commuting-related air emissions. 
Environmental Impacts of Alternatives

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1 Based on this information, the overall air quality impacts of the combination alternative would be 

2 SMALL.

3 8.2.2 Groundwater Use and Quality

4 8.2.2.1 Construction

5 FENOC (2011) indicated that groundwater would be used during construction of wind turbines 

6 only if other potable water supplies are limited and that “minor” amounts may be necessary 

7 during operation if other supplies are unavailable. In addition, FENOC indicates that solar PV 

8 installation would not use groundwater for any purpose. The impacts from construction of wind 

9 and solar construction would be SMALL.

10 FENOC (2011) also indicates that a CAES facility would not rely on groundwater for cooling and 

11 that regulations for groundwater extraction for potable water would limit impacts. Further, 

12 state-level bodies would regulate potential impacts to groundwater resources. The NRC staff 

13 finds that impacts during construction of the Norton Energy Storage project would be SMALL.

14 The impacts associated with groundwater use during construction of the NGCC portion would 

15 be similar to, but smaller than, those discussed in Section 8.1 for the full NGCC alternative, 

16 which the NRC staff considered to be SMALL.

17 8.2.2.2 Operation

18 As the NRC staff indicated in the preceding section, wind turbines and solar PV installations do 

19 not rely on water for cooling, and the lack of onsite crews at wind installations means that 

20 installations do not generally require water to support staff activities (e.g., drinking, washing, 

21 sanitation). As a result, the NRC staff does not expect any noticeable impacts to groundwater 

22 from the wind or solar PV portions of this alternative; thus, the impact is SMALL.

23 As noted above, FENOC (2011) also indicates that a compressed air energy storage facility 

24 would not rely on groundwater for cooling and that regulations for groundwater extraction for 

25 potable water would limit impacts. The NRC staff agrees that groundwater would likely not be 

26 used for cooling and that consumption of groundwater for potable water supply would have a 

27 SMALL impact.

28 The NRC staff presumed that the NGCC alternative in Section 8.1 would not rely on 

29 groundwater for any purposes. The NRC staff notes that the NGCC portion of this combination 

30 alternative could rely on groundwater for some onsite usage but would likely not rely on 

31 groundwater for cooling or service water. The NRC staff finds that impacts to the groundwater 

32 resources from the NGCC portion of this alternative would be SMALL.

33 The NRC staff finds that the overall impact of this combination alternative on groundwater use 

34 and quality would be SMALL, and the widely scattered wind and solar PV sites would likely not 

35 impose noticeably cumulative effects on groundwater resources.

36 8.2.3 Surface Water Use and Quality

37 8.2.3.1 Construction

38 The use of minimal amounts of surface water is expected in the construction of all portions of 

39 this alternative, primarily for fugitive dust control, cleaning, and concrete mixing. Some impacts 
Environmental Impacts of Alternatives

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1 on surface water quality may result in increased sediment loading to stormwater runoff from 

2 active construction zones; however, the NRC expects that Stormwater General Permits would 

3 require best management practices that would prevent or significantly mitigate such impacts. 

4 Best management practices include controlling drainage by ditches, berms, and sedimentation 

5 basins; prompt revegetation to control erosion; stockpiling and reusing excavated topsoil; and 

6 various other techniques used to control soil erosion and water pollution. As a result, surface 

7 water use and quality impacts during construction would be SMALL.

8 8.2.3.2 Operation

9 The NGCC and Norton Energy Storage project are the primary users of surface water in this 

10 alternative. The NRC staff notes that the wind and solar PV portions of this alternative do not 

11 rely on water for cooling or operations and only affect surface water as a result of potential 

12 surface runoff and water consumption by crews during construction and during maintenance.

13 FENOC (2011) indicates that the Norton Energy Storage project would rely on cooling towers to 

14 dissipate the heat that the gas turbines and compressors create, though the cooling towers 

15 would be much smaller than those typically used for coal and gas generation plants. FENOC 

16 (2011) indicates that cooling water makeup losses would be considerably less than those from 

17 Davis-Besse or an NGCC alternative, as would discharge flows. The NRC staff concludes that 

18 water consumption from the Norton Energy Storage Project will have a SMALL impact.

19 The gas-fired alternative would require much less cooling water than Davis-Besse because it 

20 operates at a higher thermal efficiency (nearly 60 percent) and because it requires much less 

21 water for steam cycle condenser cooling. In Section 8.1, the NRC staff noted that an NGCC 

22 alternative constructed at the Davis-Besse site would have SMALL impacts, and the NGCC 

23 portion of this alternative would use approximately one-sixth of the cooling water of the full 

24 NGCC replacement considered in the full-NGCC alternative. The impact to surface water from 

25 the operation of the NGCC portion of this alternative is SMALL.

26 Overall, the impacts from the combination of alternatives on surface water use and quality are 

27 SMALL.

28 8.2.4 Aquatic Ecology

29 8.2.4.1 Construction

30 Impacts from construction of wind installations and solar PV installations would be spread over 

31 wide areas and would have the ability to affect surface water as a result of runoff from disturbed 

32 lands. Impacts would likely be controlled by permit conditions and application of good 

33 management practices. Impacts to aquatic ecology would be short-lived and would cease after 

34 construction ceases. Impacts are likely to be SMALL.

35 Impacts on aquatic ecosystems from construction of the NGCC and Norton Energy Storage 

36 project portions of this alternative would be controlled through adherence to provisions of the 

37 aforementioned Stormwater General Permits and, as a result, would be SMALL.

38 Overall, the impact from the combination alternative on aquatic ecology during construction is

39 SMALL.
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1 8.2.4.2 Operation

2 Impacts from the wind installations and solar PV installations would not be noticeable as neither 

3 portion of the combination alternative would use water during operation, except for limited 

4 quantities during periodic maintenance. Impacts to aquatic ecology from the wind and solar 

5 portions would be SMALL.

6 FENOC (2011) indicated that water consumption and discharges at the Norton Energy Storage 

7 project would be regulated by NPDES limitations and provisions under Sections 316(a) and (b) 

8 of the Clean Water Act. As NRC staff established in the surface water use and quality 

9 discussion above, the Norton Energy Storage project would not have a noticeable effect on 

10 surface water and would use much less water than the NGCC alternative. Impacts from the 

11 Norton Energy Storage project would be SMALL

12 Aquatic ecosystems subject to blowdown from the NGCC’s and Norton Energy Storage’s 

13 cooling systems would be affected by the thermal and chemical characteristics of the discharge 

14 water, all of which would be controlled at accepted levels by an NPDES permit issued by State 

15 or local authorities. Aquatic ecology impacts during operations of the NGCC portion of this 

16 alternative would be SMALL.

17 Overall, the impact from the combination alternative on aquatic ecology during operation is 

18 SMALL.

19 8.2.5 Terrestrial Ecology

20 8.2.5.1 Construction

21 FENOC (2011) indicates that interconnected wind installations could have a LARGE impact on 

22 ecological resources, especially during construction as a result of land areas used by wind 

23 projects. Further, FENOC notes that wind installations could have noticeable impacts on 

24 migratory birds, eagles and raptors, and bats. FENOC indicates that wind installations in some 

25 parts of the U.S. have minor impacts, although FENOC also asserts that one cannot assume 

26 that similar impacts would occur in Ohio, particularly if any wind turbines are sited in or near 

27 Lake Erie. Given development efforts to date, the NRC staff does not expect offshore wind to 

28 significantly contribute to the wind power portion of this alternative.

29 FENOC (2011) indicates that best management practices and awareness of habitats would 

30 minimize impacts to ecological resources. The NRC staff notes that most land on which wind 

31 installations would be sited is likely to already be in agricultural use, given the predominant land 

32 use patterns in Ohio. As a result, surface disruptions and equipment are likely to affect only 

33 those ecological resources that exist on agricultural lands, which have already been 

34 substantially modified by human activities. Terrestrial impacts during construction are likely to 

35 be SMALL.

36 The NRC staff notes that most land on which solar installations would be sited is also likely to 

37 already be in agricultural use, given the predominant land use patterns in Ohio, so surface 

38 disruption and equipment are likely to affect only those ecological resources that exist on 

39 agricultural lands, which have already been substantially modified by human activities. The 

40 impact from the solar PV portion of this alternative is likely to be SMALL during construction.

41 FENOC (2011) indicates that the impacts from constructing the Norton Energy Storage project 

42 would be SMALL, given that it would only affect 92 ac of land surface. As this land has already 
Environmental Impacts of Alternatives

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1 been disturbed by historic mining activities, the NRC staff finds that the Norton Energy Storage 

2 project portion of this alternative would have a SMALL impact on terrestrial ecology during 

3 construction.

4 As indicated in Section 8.1, the NRC presumes that an NGCC alternative could be constructed 

5 on the existing Davis-Besse property. The reduced NGCC portion of this alternative (roughly 

6 one-third of the alternative considered in the previous section) could be located on previously 

7 disturbed industrialized portions currently maintained as parking lots or other paved surface or 

8 as landscaped areas that are regularly mowed. Because of this, no undisturbed terrestrial 

9 habitat would be affected by the construction of the NGCC plant at the Davis-Besse site. Some 

10 sediment transport or erosion may occur and some wildlife in neighboring marsh and grassland 

11 habitat would likely avoid habitat margins during construction due to increased noise and 

12 lighting. Edge species would be affected more than interior species. Offsite impacts will occur 

13 at the locations affected by the construction of the natural gas pipeline connecting the site to 

14 existing infrastructure, though long-linear projects can often be sited to minimize important 

15 resources. Dependent on the timing of construction activities, the nesting behavior of certain 

16 species could be adversely affected. NRC presumes protective measures, similar to those 

17 implemented by FENOC regarding the bald eagle, would continue during construction to 

18 prevent further impacts. Impacts on terrestrial resources from the construction of the NGCC 

19 alternative on the Davis-Besse site would be SMALL.

20 Overall, the construction impacts of this alternative are likely to be SMALL.

21 8.2.5.2 Operation

22 Interconnected wind installations could have operational impacts to birds and bats. Generally, 

23 however, the NRC staff finds that impacts will not destabilize any resources. The impact to 

24 ecological resources from an interconnected array of wind installations is, thus, SMALL to 

25 MODERATE.

26 FENOC (2011) indicates that development of solar PV installations could have major impacts on 

27 land resources, which could have significant impacts on terrestrial ecological resources. The 

28 NRC staff notes that most land on which solar installations would be sited is likely to already be 

29 in agricultural use given the predominant land use patterns in Ohio. As a result, operational 

30 impacts are likely to affect only those ecological resources that exist on agricultural lands. 

31 These impacts are unlikely to be noticeable on the scale of the solar PV portion of this 

32 alternative; thus, they are SMALL.

33 Air emissions from the Norton Energy Storage project, which have a SMALL impact to air 

34 quality, are unlikely to have a noticeable impact to terrestrial resources during operations. 

35 Further, operations at the Norton site will take place on area previously disturbed by mining 

36 activities. As a result, the impacts from the Norton Energy Storage project portion of this 

37 alternative are SMALL.

38 Impacts on terrestrial species due to the operation of an NGCC plant would be similar to the 

39 impacts associated with the present operation of Davis-Besse. The monitoring of cooling-tower 

40 drift effects on terrestrial vegetation has shown no visible damage. In addition, where lines 

41 cross croplands and little or no vegetation control is required, impacts due to ROW 

42 management on wildlife has also been determined to be small. As a result, the impacts on 

43 terrestrial resources from the operation of the NGCC alternative on the Davis-Besse site would 

44 be SMALL.
Environmental Impacts of Alternatives

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1 Overall operational impacts from this alternative are SMALL to MODERATE.

2 8.2.6 Human Health

3 8.2.6.1 Construction

4 FENOC (2011) indicates that the only major human health risk from construction and operation 

5 of an interconnected array of wind installations is accidents. FENOC indicated that compliance 

6 with applicable occupational safety and health regulations (those implemented by the 

7 Occupational Safety and Health Administration (OSHA)) would ensure that impacts are SMALL. 

8 The NRC staff agrees that impacts from construction and operation of an array of wind 

9 installations would be SMALL.

10 FENOC (2011) indicates that human health impacts from construction of solar PV installations 

11 would be regulated by OSHA; thus, they would be SMALL.

12 The Norton Energy Storage project poses some unique challenges, such as construction of an 

13 energy facility within and near a cavern, though OSHA standards would still apply. The NRC 

14 staff further finds that impacts on human health from the compressed air energy storage 

15 facility’s air emissions would also not be noticeable. As a result, the NRC staff finds that human 

16 health impacts from this portion of the alternative would be SMALL.

17 Impacts on human health from construction of the NGCC alternative would be similar to impacts 

18 associated with the construction of any major industrial facility. Compliance with worker 

19 protection rules would control those impacts on workers at acceptable levels. Impacts from 

20 construction on the general public would be minimal since limiting active construction area 

21 access to authorized individuals is expected. Impacts on human health from the construction of 

22 the NGCC alternative would be SMALL.

23 8.2.6.2 Operation

24 FENOC (2011) indicates that human health impacts from operation of solar PV would be 

25 regulated by the OSHA and would be SMALL. FENOC also indicates that accidents, the only 

26 potential human health impact from operation of wind turbines, would be mitigated by OSHA 

27 regulations and would be SMALL

28 FENOC (2011) indicates that OSHA regulation of the Norton Energy Storage project would 

29 prevent noticeable impacts on human health. The NRC staff further notes that human health 

30 effects of gas-fired generation are generally low, although in Table 8-2 of the GEIS (NRC 1996), 

31 the NRC staff identified cancer and emphysema as potential health risks from gas-fired plants. 

32 NOx emissions contribute to ozone formation, which contributes to human health risks. 

33 Emission controls on the NGCC alternative can be expected to maintain NOx emissions well 

34 below air quality standards established for the purposes of protecting human health, and 

35 emissions trading or offset requirements mean that overall NOx releases in the region will not 

36 increase. Health risks for workers may also result from handling spent catalysts used for NOx

37 control that may contain heavy metals. Impacts on human health from the operation of the 

38 NGCC portion of the alternative would be SMALL.

39 8.2.7 Land Use

40 As discussed in Section 8.1.7, the GEIS (NRC 1996) generically discusses the impact of 

41 constructing and operating various replacement power plant alternatives on land use, both on 
Environmental Impacts of Alternatives

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1 and off each power plant site. The analysis of land use impacts here focuses on the amount of 

2 land area that would be affected by the construction and operation of a combination of wind 

3 turbines, solar PV installations, and an NGCC power plant at Davis-Besse.

4 8.2.7.1 Construction

5 Most of the wind farms would be located on an open agricultural cropland, which would remain 

6 largely unaffected by the presence of the wind turbines. As wind turbines require ample spacing 

7 between one another to avoid air turbulence, the footprint of a utility scale wind farm could be 

8 quite large. Under the wind portion of this alternative, land-based turbines would be located on 

9 multiple wind farms spread across approximately 75,000 ac (30,000 ha) of land as 50 ac (20 ha) 

10 of land would be required for each MW of capacity. (FENOC 2011). A portion of this land, 

11 approximately 3,750 ac (1,517 ha), would be directly affected by the placement of the wind 

12 turbines (FENOC 2011). This land would be temporarily affected during the installation of the 

13 turbines and the construction of support facilities, and about one-third of the land across a very 

14 wide area would be permanently impacted during the operation. This amount of land 

15 disturbance would occur primarily on agriculture land and would be widely spread across Ohio 

16 (and perhaps into neighboring states to allow for adequate geographic dispersal). 

17 Delivering heavy and oversized wind turbine components would also require the construction of 

18 temporary site access roads, some of which may require a circuitous route to their destination. 

19 However, once construction is completed, many temporary access roads can be reclaimed and 

20 replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land 

21 used for equipment and material lay down areas, turbine assembly, and installation could be 

22 returned to its original state or some other compatible use, such as farming or grazing. As wind 

23 farms would require a substantial amount of open land, though only a small portion would be 

24 used for wind turbines, access roads, and infrastructure, land use impacts from the wind portion 

25 of this alternative would range from MODERATE to LARGE. 

26 The solar PV portion of this alternative requires approximately 2,400 ac (970 ha) (NREL 2008). 

27 As indicated for the wind-powered portion of this alternative, the solar PV installations are also 

28 likely to occur on agricultural land. Land required for a standalone solar PV installation would 

29 alter the existing land use to energy production, and would preclude most other land uses from 

30 coexisting. Land would also be needed for transmission lines to connect solar PV installations 

31 to the electrical power grid and site access roads for maintenance purposes. Installing solar PV 

32 technologies on building rooftops would reduce the amount of land required for standalone 

33 solar. Based on this information, overall land-use impacts from the solar PV portion of this 

34 alternative would range from SMALL to LARGE, depending on the extent to which PV 

35 installations occur on existing buildings rather than standalone sites.

36 Land use impacts from the CAES portion of this alternative would be similar to the impacts 

37 described for an NGCC power plant (see Section 8.1.7). Only a minor amount of land would be 

38 needed above the geologic storage formation; however, additional land might be needed to 

39 connect the CAES to the electrical power grid, site access roads, or construction of a gas supply 

40 pipeline. If the Norton Energy Storage Project is used, no construction of an underground 

41 storage facility would be necessary. Therefore, land use impacts from the CAES portion of this 

42 alternative would be SMALL to MODERATE depending on location.

43 A new 305-MW NGCC plant would require approximately 74 ac (30 ha) of land and could be 

44 constructed largely within the existing developed industrial footprint of the Davis-Besse site. 

45 This amount of land use would include other plant structures and associated infrastructure. 

46 Similar to the NGCC replacement alternative considered in Section 8.1.7, an additional 150 ac 
Environmental Impacts of Alternatives

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1 (61 ha) of land could be needed for a new 25-mi (41-km) gas supply pipeline. In addition to 

2 onsite land requirements, land would be required offsite for natural gas wells and collection 

3 stations. Scaling from GEIS estimates, approximately 1,098 ac (444 ha) (based on 3,600 ac per 

4 1,000 MWe and 305 MWe for NGCC) (NRC 1996) would be required for wells, collection 

5 stations, and pipelines to bring the gas to the plant. Most of this land requirement would occur 

6 on land where gas extraction already occurs. Therefore, land use impacts from the NGCC 

7 portion of this combination alternative at the Davis-Besse site could range from SMALL to 

8 MODERATE.

9 Based on this information, overall land use impacts from the construction and operation of a

10 combination of wind turbine, solar, PV, CAES, and NGCC components of the combination 

11 alternative would range from SMALL to LARGE. 

12 8.2.7.2 Operation

13 The elimination of uranium fuel for Davis-Besse would partially offset some, but not all, of the 

14 land requirements for this combination alternative. Scaling from GEIS estimates, approximately 

15 635 ac (256 ha) (based on 35 ac/yr disturbed per 1,000 MWe for 20 years) would no longer be 

16 needed for mining and processed uranium during the operating life of the plant (NRC 1996). 

17 Operational land use impacts caused by the components of the combination alternative would 

18 be SMALL.

19 8.2.8 Socioeconomics

20 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

21 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

22 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 

23 long-term socioeconomic impacts. Workforce requirements for the construction and operation 

24 of a combination of wind turbines, solar PV, NGCC and a CAES facility were evaluated in order 

25 to measure their possible effects on current socioeconomic conditions.

26 8.2.8.1 Construction

27 FENOC estimates that approximately 1,200 workers would be needed during construction of the 

28 wind turbine component of this alternative (FENOC 2011). FENOC’s estimate appears to be 

29 overly conservative for the small size and megawattage of this construction project and 

30 inconsistent with recent license renewal reviews. Exelon’s wind farm construction workforce 

31 estimate for a similar combination alternative to replace Limerick, Units 1 and 2, appears to be 

32 more reasonable and in line with current construction trends. Therefore, Exelon’s estimate of 

33 approximately 200 construction workers (Exelon 2011) is used in this analysis.

34 In addition to constructing the wind farms, solar PV installations would also create temporary 

35 construction jobs, economic activity, and increased demand for short-term rental housing and

36 public services in communities nearest to the construction sites. Exelon estimated 

37 200 construction workers would be needed to install solar PV for a similar combination 

38 alternative to replace Limerick, Units 1 and 2 (Exelon 2011). However, given the smaller scale 

39 and megawattage of the wind farm and solar PV components, an even smaller construction 

40 workforce would likely be required than what was estimated for the Limerick, Units 1 and 2, 

41 combination alternative. Given the relatively small number of construction workers scattered 

42 over a large area at various construction sites, the relative socioeconomic impact of this many 

43 construction workers for these two components would be SMALL.
Environmental Impacts of Alternatives

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1 FENOC estimated approximately 728 to 1,517 workers would also be needed to construct the 

2 NGCC component of this alternative (FENOC 2011). FENOC’s estimate appears to be overly 

3 conservative for the small size and megawattage of this construction project and inconsistent 

4 with recent license renewal reviews. Exelon’s wind farm construction workforce estimate for a 

5 similar combination alternative to replace Limerick, Units 1 and 2, appears to be more 

6 reasonable and in line with current construction trends. Therefore, Exelon’s estimate of 

7 approximately 200 construction workers (Exelon 2011) is used in this analysis.

8 The relative economic impact of this many workers on the local economy and tax base would 

9 vary, with the greatest impacts occurring in the communities where the majority of construction 

10 workers would reside and spend their income. As a result, local communities could experience 

11 a short-term economic “boom” from increased tax revenue and income generated by 

12 construction expenditures and the increased demand for temporary (rental) housing and 

13 business services. Some construction workers could relocate in order to be closer to the 

14 construction work site. However, given the proximity of Davis-Besse to the Toledo metropolitan 

15 area, workers could commute to the construction site, thereby reducing the need for rental 

16 housing. Given the small number of construction workers, socioeconomic impacts would be 

17 SMALL.

18 Construction of the CAES portion of this alternative would temporarily increase employment in 

19 the vicinity of the Norton Energy Storage project (approximately 85 mi east-southeast of 

20 Davis-Besse). Similar to the NGCC portion of this alternative, the relative economic impact of 

21 this many workers on the local economy and tax base would vary, with the greatest impacts 

22 occurring in the communities where the majority of construction workers would reside and 

23 spend their income. Some construction workers could relocate in order to be closer to the 

24 construction work site. However, given the proximity of the site to Akron and Cleveland, 

25 workers could commute to the construction site, thereby reducing the need for rental housing.

26 Given that the small number of construction workers would be scattered over a large area at 

27 various construction sites under this combination alternative, socioeconomic impacts would be 

28 SMALL and localized near the construction sites. After the installation of each component is 

29 completed, local communities could experience a return to pre-construction economic 

30 conditions. Based on this information, the combined overall socioeconomic impacts of 

31 construction under the combination alternative could range from SMALL to MODERATE, due to 

32 overlapping effects should more than one construction activity occur within the same area. 

33 8.2.8.2 Operation

34 FENOC (2011) estimated that 150 to 200 workers would be required to operate the wind power 

35 portion of this alternative (FENOC 2011). FENOC’s estimate appears to be overly conservative 

36 for the small size and megawattage of this construction project and inconsistent with recent 

37 license renewal reviews. Exelon’s wind farm construction workforce estimate for a similar 

38 combination alternative to replace Limerick, Units 1 and 2, appears to be more reasonable and 

39 in line with current construction trends. Therefore, Exelon’s estimate of approximately 

40 50 operations workers (Exelon 2011) is used in this analysis. Given the relatively small number 

41 of operations workers and potentially large area (i.e., 75,000 ac (30,000 ha)) covered by the 

42 wind power and solar PV installations at standalone sites and other locations, the relative 

43 economic impact of this many workers on local communities and the tax base would be SMALL 

44 and spread over a large region.

45 FENOC estimated the operations workforce for the NRCC portion of this alternative workforce to 

46 be approximately 91 workers (FENOC 2011). This estimate, while very conservative, appears 
Environmental Impacts of Alternatives

8-33

1 to be reasonable. FENOC estimates that 50 to 100 workers would be needed for operations at 

2 the CAES facility. Increased demand for housing and public services caused by the relatively 

3 small number of operations workers would have a SMALL socioeconomic impact on the region 

4 around Davis-Besse.

5 The reduction in employment at Davis-Besse could affect property tax revenue and income in 

6 local communities and businesses. This alternative would result in the loss of approximately 

7 825 relatively high-paying jobs at Davis-Besse, with a corresponding reduction in purchasing 

8 activity and tax contributions to the regional economy. In addition, the permanent housing 

9 market could also experience increased vacancies and decreased prices if operations workers 

10 and their families move out of the Davis-Besse region. However, the amount of property taxes 

11 paid by wind farms, solar PV installations, and CAES may offset some of the lost tax revenues 

12 from Davis-Besse because of the large amount of land required for wind farm and solar PV 

13 installations. 

14 Overall, the socioeconomics of operation of this alternative would range from SMALL to 

15 MODERATE because of the small number of operations workers required to operate each 

16 component of this combination alternative and because of the reduction in employment at 

17 Davis-Besse and the potential overall net reduction of tax revenue from this combination

18 alternative. 

19 8.2.9 Transportation

20 Commuting workers and truck deliveries of materials and equipment would cause transportation 

21 impacts during the construction and operation of the wind farm, solar PV installations, CAES, 

22 and NGCC power plant.

23 8.2.9.1 Construction

24 Transportation impacts during the construction and operation of the wind, solar PV, NGCC, and 

25 CAES components of this combination alternative would be less than the overall impacts from 

26 the construction of a single replacement power plant (i.e., NGCC power plant). This is because 

27 the construction workforce for each component and the volume of materials and equipment 

28 needing to be transported to each respective construction site would be smaller than the 

29 concentrated effects at one power plant site. In other words, the transportation impacts would 

30 not be as concentrated at Davis-Besse under the NGCC alternative (see Section 8.1.9), but 

31 spread out over a wider area under this combination alternative. 

32 Commuting workers to each construction site would arrive by site access roads, and traffic 

33 volumes on nearby roads could increase during shift changes. In addition to commuting 

34 workers, trucks would be transporting construction materials and equipment to the worksite, 

35 thus increasing the amount of traffic on local roads near the construction site. The increase in 

36 vehicular traffic would peak during shift changes, resulting in temporary levels of service 

37 impacts and delays at intersections. Transporting heavy and oversized wind turbine 

38 components on local roads could have a noticeable impact over a larger area. Some 

39 components and materials could also be delivered by train or barge, depending on location. 

40 Train deliveries could cause additional traffic delays at railroad crossings. Based on this 

41 information, traffic-related transportation impacts during construction could range from SMALL 

42 to MODERATE depending on the location and concentration of wind farms, solar PV 

43 installations, NGCC power plant, and CAES; and road capacities.
Environmental Impacts of Alternatives

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1 8.2.9.2 Operation 

2 During operations, transportation impacts would be less noticeable during shift changes and 

3 maintenance activities. Given the small number of operations workers needed for each 

4 component, the levels of service traffic impacts on local roads from the combination alternative

5 would be SMALL.

6 8.2.10 Aesthetics

7 The analysis of aesthetic impacts focuses on the degree of contrast between the components of 

8 the combination alternatives and the surrounding landscape. In general, aesthetic changes 

9 would be limited to the immediate vicinity of the wind farms, solar PV installations, NGCC, and 

10 CAES facility. 

11 8.2.10.1 Construction

12 During construction, all of the clearing and excavating would occur on the existing construction 

13 site. These activities could be visible from offsite roads. Wind turbines would have the greatest 

14 potential visual impact; wind turbines often dominate the view and become the major focus of 

15 attention. On flat terrain, wind turbines would be visible from miles away and would be the 

16 tallest man-made structures in rural settings. Because wind farms are generally located in rural 

17 or remote areas, the introduction of wind turbines will be in sharp contrast to the visual 

18 appearance of the surrounding environment. Similarly, the footprint of a solar PV installation 

19 would be quite large and could create a noticeable visual impact. Spread across a large site, a 

20 solar PV installation could dominate the view and would likely become the major focus of 

21 attention. The introduction of a solar PV installation would be in sharp contrast to the visual 

22 appearance of the surrounding environment. Installing solar PV technologies on building 

23 rooftops, although noticeable to a lesser degree, would reduce the amount of land required for 

24 standalone solar sites. 

25 Aesthetic impacts from the NGCC plant component of the combination alternative would be 

26 essentially the same as those described for the NGCC alternative in Section 8.1.7.4., except 

27 there would be one unit rather than two. As the CAES component of this alternative would be 

28 sited at former industrial (mining) site, the aesthetic impacts would be similar to those of the 

29 NGCC alternative. 

30 Construction of exhaust stacks and mechanical draft cooling towers would, however, impact the 

31 surrounding landscape. 

32 The overall aesthetic impact would be SMALL to LARGE, depending on the location of wind 

33 farms, type of solar PV installation, and location of the NGCC and CAES component at

34 industrial sites. 

35 8.2.10.2 Operation

36 Wind turbines and solar PV technologies would be visible offsite during daylight hours, and 

37 some structures may require aircraft warning lights. During certain weather conditions, the 

38 plume from the NGCC cooling tower would be visible for long distances. In general, given the 

39 industrial appearance of the Davis-Besse site, an NGCC power plant would blend in with the 

40 surroundings if the existing Davis-Besse facility remains. In addition, the visual appearance of 

41 the NGCC power block could look similar to the existing Davis-Besse power block. Since the 
Environmental Impacts of Alternatives

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1 new NGCC power plant would appear similar to the existing Davis-Besse power plant, overall 

2 operational impacts would be SMALL.

3 8.2.11 Noise

4 Ambient noise conditions would be affected by the construction and operation of wind farms, 

5 solar PV installations, and the construction and operation of a single-unit NGCC power plant.

6 8.2.11.1 Construction

7 Noise levels would increase during wind farm, solar PV technology, and CAES installation and 

8 NGCC construction. Noises during construction, however, would be intermittent and limited to 

9 the peak periods of activity and would diminish over distance. Noise impacts during 

10 construction could range from SMALL to MODERATE. 

11 8.2.11.2 Operation

12 Noise during wind farm, solar PV, and CAES component operations would be limited to those 

13 caused by normal industrial processes and communications. Wind turbines would also 

14 generate noise. Pipelines delivering natural gas fuel to the NGCC or CAES component could 

15 be audible offsite near gas compressor stations, but all noise would be within EPA established 

16 limits. Overall noise impacts would be SMALL.

17 8.2.12 Historic and Archaeological Resources

18 To consider effects on historic and archaeological resources, any areas potentially affected by 

19 the construction of the wind, solar PV, CAES, and NGCC components of this alternative would 

20 need to be surveyed to identify and record historic and archaeological resources. Any 

21 resources found in these surveys would need to be evaluated for eligibility on the NRHP, and 

22 mitigation of adverse effects would need to be addressed if eligible resources were 

23 encountered. The owner of the wind farms would need to survey all areas associated with 

24 operation of the alternative (e.g., roads, transmission corridors, other ROWs). Areas with the 

25 greatest sensitivity should be avoided. Visual impacts on significant cultural resources—such 

26 as the viewsheds of historic properties near the sites—also should be assessed.

27 The potential for impacts on historic and archaeological resources from the wind component of 

28 this alternative would vary greatly, depending on the location of the proposed sites. Areas with 

29 the greatest sensitivity could be avoided or effectively managed under current laws and 

30 regulations. However, construction of wind farms and their support infrastructure have the 

31 potential to notably impact historic and archaeological resources because of earthmoving 

32 activities (e.g., grading and digging) and the aesthetic changes they may bring to the viewshed 

33 of historic properties located nearby. Therefore, depending on the resource richness of the site 

34 chosen for the wind farms and associated infrastructure, the impacts could range from SMALL 

35 to LARGE. 

36 The impacts of the construction of a new solar PV alternative on historic and archaeological 

37 resources will vary depending on the form of the solar capacity installed. Rooftop installations 

38 minimize land disturbance and the modifications necessary to the transmission system, thereby 

39 minimizing impacts to historic and archaeological resources. Land-based installations are larger 

40 than rooftop installations and will require some degree of land disturbance for installation 

41 purposes, potentially causing greater impacts to historic and archaeological resources. 

42 Aesthetic changes caused by the installation of both forms could have a noticeable effect on the 
Environmental Impacts of Alternatives

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1 viewshed of nearby historic properties. Using previously disturbed sites for land-based 

2 installations and collocating any new transmission lines with existing right-of-ways could 

3 minimize impacts to historic and archaeological resources. Areas with the greatest sensitivity 

4 could be avoided or effectively managed under current laws and regulations. Therefore, 

5 depending on the resource richness of the sites chosen and the type of solar technology 

6 installed, the impacts could range from SMALL to LARGE. 

7 The impacts to historic and archaeological resource are expected to be similar to the discussion 

8 of the NGCC alternative in Section 8.1.12. The NRC staff assumes that prior mining and 

9 industrial use of the 92-ac (37-ha) Norton Energy Storage site has removed or otherwise 

10 affected the historic and archaeological resources at the former mine site. As a result, the 

11 Norton Energy Storage project is likely to have SMALL impact on historic and archaeological 

12 resources. 

13 Overall impacts to historic and archaeological resources for this alternative range from SMALL 

14 to LARGE. 

15 8.2.13 Environmental Justice

16 The environmental justice impact analysis evaluates the potential for disproportionately high and 

17 adverse human health, environmental, and socioeconomic effects on minority and low-income 

18 populations that could result from the construction and operation of wind turbines, solar PV 

19 installations, an NGCC plant and a CAES facility. As previously discussed in Section 8.1.13, 

20 such effects may include human health, biological, cultural, economic, or social impacts. Some 

21 of these potential effects have been identified in resource areas discussed in this SEIS. 

22 8.2.13.1 Construction

23 Potential impacts to minority and low-income populations would mostly consist of environmental 

24 and socioeconomic effects during construction of all components of this alternative (e.g., noise, 

25 dust, traffic, employment, and housing impacts). Noise and dust impacts during construction 

26 would be short term and primarily limited to onsite activities. Minority and low-income 

27 populations residing along site access roads would be affected by increased commuter vehicle 

28 and truck traffic. However, because of the temporary nature of construction, these effects would 

29 only occur during certain hours of the day and are unlikely to be high and adverse and would be 

30 contained to a limited time period during certain hours of the day. During construction, 

31 increased demand for rental housing in the vicinity of the site could affect low-income 

32 populations living near the alternatives. However, given the small number of construction 

33 workers and the possibility that workers could commute to the construction site, the need for 

34 rental housing would not be significant. 

35 Based on this information and the analysis of human health and environmental impacts 

36 presented in Section 8.2 of this chapter, the construction of wind turbines, solar PV installations, 

37 an NGCC plant, and CAES facility would not have disproportionately high and adverse human 

38 health and environmental effects on minority and low-income populations. 

39 8.2.13.2 Operation

40 Minority and low-income populations living in close proximity to the wind farms, solar PV 

41 installations, and CAES facility could be disproportionately affected by operations. However, 

42 operational impacts would mostly be limited to noise and aesthetic effects. The general public 

43 living near the wind farms, solar PV installations, and CAES facility would also be exposed to 
Environmental Impacts of Alternatives

8-37

1 the same effects. As discussed in Section 8.1.13, emissions from the operation of an NGCC 

2 plant could affect minority and low-income populations as well as the general population living in 

3 the vicinity of the new power plant. However, all would be exposed to the same potential effects 

4 from NGCC power plant operations, and any impacts would depend on the magnitude of the 

5 change in ambient air quality conditions. Permitted air emissions are expected to remain within 

6 regulatory standards.

7 Based on this information and the analysis of human health and environmental impacts 

8 presented in Section 8.2 of this chapter, the construction and operation wind turbines, solar PV 

9 installations, an NGCC plant, and CAES facility would not have disproportionately high and 

10 adverse human health and environmental effects on minority and low-income populations.

11 8.2.14 Waste Management

12 8.2.14.1 Construction 

13 FENOC (2011) indicates that hazardous materials, such as cadmium and lead, are used in the 

14 manufacture of solar PV panels; thus, solar PV could create environmental impacts during 

15 manufacture and disposal. The NRC staff notes that no waste is generated during the lifetime 

16 of a solar PV project from the PV installation itself and that some land-clearing debris may be 

17 generated during installation. The NRC staff finds it likely that solar manufacturers would 

18 employ best practices to minimize release and disposal of hazardous wastes and recycle any 

19 commercially valuable quantities of waste items. Further, site crews are likely to manage 

20 land-clearing debris in accordance with best practices. As agricultural sites are likely already 

21 cleared and graded, the NRC staff expects impacts from the solar PV portion of this alternative 

22 to SMALL. 

23 FENOC (2011) indicates that construction of an interconnected array of wind installations could 

24 result in generation of large amounts of land-clearing debris, but proper waste management 

25 activities would minimize these impacts. The NRC staff notes that most land used for wind 

26 installations is likely to already be in agricultural use; thus, it is already cleared and, in many 

27 cases, relatively flat. As such, the NRC staff finds that the impacts from waste management 

28 would be SMALL.

29 During construction of the NGCC portion of this alternative, land clearing and other construction 

30 activities would generate waste that can be recycled, disposed of onsite, or shipped to an offsite 

31 waste disposal facility. Because the NGCC portion of this alternative would likely be 

32 constructed on the previously disturbed portions of the Davis-Besse site, the amounts of wastes 

33 produced during land clearing would be minimal. As a result, construction related impacts due 

34 to the construction of the NGCC alternative due to waste management would be SMALL.

35 Construction of the Norton Energy Storage project would generate similar wastes to the NGCC 

36 portion of this alternative. Some wastes may be generated as a result of reservoir-preparation 

37 activities at the Norton site, though it is unlikely that these wastes will require offsite disposal. In 

38 general, the Norton Energy Storage project portion of this alternative will have SMALL waste 

39 disposal impacts.

40 8.2.14.2 Operation 

41 Wind turbine installations and solar PV installations generate no appreciable waste during 

42 operations, except for occasional component replacements, wash water, and—for wind 
Environmental Impacts of Alternatives

8-38

1 turbines—lubricants. Waste management effects from solar PV and wind installations are 

2 SMALL.

3 The NGCC portion of this alternative would produce relatively little waste, primarily in the form of 

4 spent SCR catalysts used to control NOx emissions from the natural gas-fired plants. Domestic 

5 and sanitary wastes would be expected to decrease from amounts now generated during the 

6 operation of the reactors due to a reduced operational workforce for the NGCC portion of this 

7 alternative. The NRC staff established, in Section 8.1.8, that impacts from a full NGCC 

8 alternative would be SMALL, and the waste generated by the NGCC portion of this alternative 

9 will be smaller; therefore, waste impacts from an NGCC facility at Davis-Besse would be 

10 SMALL.

11 FENOC (2011) indicates that operation of the Norton Energy Storage project would generate 

12 minimal waste during operation, like other gas-fired facilities, and that its impact would also be 

13 SMALL. The NRC staff notes that the primary types of waste generated by gas-fired power 

14 plants are SCR catalysts and other operational wastes.

15 Overall, the NRC staff finds that a combination would have SMALL waste management impacts.

16 8.2.15 Climate Change-Related Impacts of the Combination Alternative

17 Combustion of fossil fuels, including natural gas, is the greatest anthropogenic source of GHG 

18 emissions in the U.S. After a thorough examination of the scientific evidence and careful 

19 consideration of public comments, the EPA announced on December 7, 2009, that GHGs 

20 threaten the public health and welfare of the American people and meet the CAA definition of air 

21 pollutants. Carbon dioxide (CO2) is by far the largest GHG emitted during fossil fuel 

22 combustion. This section presents an assessment of the potential impacts the construction and 

23 operation of the combination alternative will have on climate change

24 8.2.15.1 Construction

25 Impacts to climate change from the construction of components of this alternative would result 

26 primarily from the consumption of fossil fuels in the engines of construction vehicles and 

27 equipment, workforce vehicles used in commuting to and from the work site, and delivery 

28 vehicles. However, all such impacts would be temporary. Given the expected relatively short 

29 construction period for constructing the alternatives’ components, the overall impact on climate 

30 change from the releases of GHGs during construction of the combination alternative would be 

31 SMALL. 

32 8.2.15.2 Operation

33 Although natural gas combustion in the combustion turbines (at both the NGCC facility and 

34 Norton Energy Storage project) would be the primary source of GHG emissions, maintenance 

35 activities of wind turbines and solar PV, and other miscellaneous ancillary sources such as truck 

36 and rail deliveries of materials to the site and commuting of the workforce would make minor 

37 contributions.

38 The NRC estimates that operation of the NGCC alternative and Norton Energy Storage would 

39 amount to 1.29 million tons of carbon dioxide equivalent (CO2e) (1.17 million MT of CO2e) 

40 per year. EPA reported that, in 2010, the total amount of CO2e emissions related to electricity 

41 generation was 2,277.3 teragrams (2,277.3 MMT) (EPA 2012). The EIA reported that, in 2010, 

42 electricity production in Ohio was responsible for 121 MMT of CO2 emissions (123 MMT CO2e) 
Environmental Impacts of Alternatives

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1 (EIA 2012). Operation of the NGCC alternative and Norton Energy Storage would amount to

2 less than 1 percent of Ohio’s 2010 GHG emissions.

3 NETL estimates that CCS will capture and remove as much as 90 percent of the CO2 from the 

4 exhausts of combustion turbines (NETL 2010). With CCS in place, the NGCC alternative would 

5 release 0.116 MMT per year (0.128 million tons) of CO2, and the impact on climate would be 

6 further reduced. The impact on climate change from the operation of the combination 

7 alternative would be SMALL.

8 8.3 Coal-Fired Alternative

9 In this section, NRC evaluates the environmental impacts of a coal-fired alternative to 

10 Davis-Besse. In the State of Ohio, over 83 percent of electricity was generated using coal-fired 

11 power plants in 2009. As noted by EIA in its Annual Energy Outlook (EIA 2013), coal-fired 

12 generation has historically been the largest source of electricity and is expected to remain a 

13 large source through 2040, though coal’s share of total U.S. generation is expected to decline 

14 from 42 percent in 2011 to 35 percent in 2040. Baseload coal units have proven their reliability 

15 and can routinely sustain capacity factors as high as 85 percent. Among the various boiler 

16 designs that are available, pulverized coal boilers producing supercritical steam (SCPC boilers) 

17 are the most likely variant for a coal-fired alternative given their generally high thermal 

18 efficiencies and overall reliability.

19 While nuclear reactors, on average, operate with capacity factors above 90 percent, the new 

20 SCPC coal-fired alternative would operate with roughly an 85 percent capacity factor. Despite 

21 the slightly lower capacity factor, an SCPC plant would be capable of providing adequate 

22 replacement power for a nuclear plant for the purposes of this NEPA analysis. The NRC staff 

23 notes that the lower capacity factor slightly reduces the level of air emissions and fuel 

24 consumption estimated for the coal-fired alternative. However, the NRC staff determined that 

25 none of the slight underestimates are significant enough to result in impact levels that are 

26 different from those described below for the coal-fired alternative. Further, the NRC staff notes 

27 that the average capacity factor from Davis-Besse has been lower in recent years than the 

28 nuclear fleet average, and by applying this capacity-factor approximation, the NRC staff avoids 

29 assigning excessive impacts to the coal-fired alternative.

30 A myriad of sizes of pulverized coal boilers and steam turbine generators are available; 

31 however, the NRC staff presumes that two equally sized boiler/STG powertrains, operating 

32 independently and simultaneously, would likely be used to match the power output of 

33 Davis-Besse. To complete this analysis, the NRC staff presumes that both powertrains would 

34 have the same features, operate at generally the same conditions, have similar impacts on the 

35 environment, and be equipped with the same pollution-control devices such that once all 

36 parasitic loads are overcome, the net power collectively available would be roughly equal to 

37 908 MWe. The NETL has estimated that approximately 7.5 percent of an SCPC boiler’s gross 

38 MW capacity is needed to supply typical parasitic loads (plant operation plus control devices for 

39 criteria pollutants to meet New Source Performance Standards). Introducing controls for GHG 

40 emissions (i.e., CCS) would cause the parasitic load to increase to 27 percent of the boiler’s 

41 gross rated capacity (NETL 2010). NRC has elected to introduce a 5.2 percent performance 

42 penalty (50 MW in this case) on the MW rating of SCPC boilers to account for typical parasitic 

43 loads while still allowing net capacity equivalent to Davis-Besse. However, because of 

44 uncertainty regarding future GHG regulations and the limited real-world experience in CCS at 

45 utility-scale power plants, parasitic loads associated with CCS are not considered. Thus, the 

46 gross power required of the coal-fired alternative is 958 MWe.
Environmental Impacts of Alternatives

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1 Various bituminous coal sources are available to coal-fired power plants in Ohio. EIA reports 

2 that, in 2008, the State of Ohio produced electricity from coal with heating values of 

3 11,444 British thermal units per pound (Btu/lb), sulfur content of 1.96 percent, and ash of 

4 9.42 percent (EIA 2010b). For the purpose of this evaluation, NRC presumes that coal burned 

5 in 2008 will be representative of coal that would be burned in a coal-fired alternative regardless 

6 of where it was located. Approximately one-third of the coal burned in Ohio in 2008 came from 

7 mines in the Appalachian basin in the eastern part of the State. The remaining coal was 

8 brought in primarily by railcar and river barge from West Virginia, Wyoming, Kentucky, and 

9 Pennsylvania (EIA 2011b). Bituminous coals from Appalachian mines have CO2 emission 

10 factors ranging from 202.8 to 210.2 lb per million Btu of heat input (Hong and Slatick 1994). As 

11 a conservative estimate, NRC used a CO2 emission factor of 210.2 lb per million Btu for carbon 

12 dioxide calculations in this evaluation.

13 The boilers comprising the supercritical coal-fired alternative are presumed to have the following 

14 characteristics and be equipped with the following pollution control devices:

15 • dual wall-fired, dry-bottom boilers, configured to be New Source Performance Standards 

16 (NSPS)-compliant;

17 • overall thermal efficiency of 39 percent; 

18 • capacity factor of 85 percent; 

19 • collective rating of 976 MWe (gross), 908 MWe (net);

20 • supercritical steam (see text box);

21 • bituminous coal from Appalachian mines; caloric value 11,444 Btu/lb, ash 9.42 percent, 

22 sulfur 1.96 percent, CO2 emission factor of 210.2 lb/million Btu, pulverized to more than

23 70 percent passing a 200-mesh sieve;

24 • fabric filter for particulate control, operating at 99.9 percent removal efficiency; 

25 • wet calcium carbonate SO2 scrubber operating at 95 percent removal efficiency; and

26 • low-NOx burners with overfire air and selective catalytic reduction for nitrogen oxide 

27 controls capable of attaining a NOx removal of 86 percent (or an emission rate less than 

28 or equal to 2.5 parts per million per volume (ppmv) (dry basis)). 
Environmental Impacts of Alternatives

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1 In its ER, FENOC determined that the current 

2 Davis-Besse site was not viable to accommodate 

3 a coal-fired alternative with net generating 

4 capacity sufficient to meet the power production 

5 of Davis-Besse due to limited space on the 

6 Davis-Besse site, as explained in Chapter 8 

7 (FENOC 2010). The NRC staff concurs with that 

8 assessment and its analysis of the impacts of the 

9 coal-fired alternative presumes that the SCPC

10 coal-fired power plant would operate only at an 

11 alternative site.

12 It is reasonable to assume that a coal-fired 

13 alternative would use supercritical steam (see 

14 text box). Supercritical steam technologies are 

15 increasingly common in new coal-fired plants. 

16 Supercritical plants operate at higher 

17 temperatures and pressures than older subcritical 

18 coal-fired plants and, therefore, can attain higher 

19 thermal efficiencies. While supercritical facilities 

20 are more expensive to construct than subcritical 

21 facilities, they consume less fuel for a given 

22 output, reducing environmental impacts throughout the fuel life cycle. The NRC staff expects 

23 that a new, supercritical coal-fired plant beginning operation in 2017 would operate at a heat 

24 rate of 9,069 Btu/kWh, or approximately 38 to 39 percent thermal efficiency. However, heat 

25 inputs could be less, depending on the coal source and whether fuel blending is practiced in 

26 order to remain compliant with emission limitations.

27 In an SCPC coal-fired power plant, burning coal heats pressurized water. As the supercritical 

28 steam and water mixture moves through plant pipes to a turbine generator, the pressure drops 

29 and the mixture flashes to steam. The heated steam expands across the turbine stages, 

30 spinning them, and driving the generator to produce electricity. After passing through the 

31 turbine, any remaining steam is condensed back to water and recycled back to the boiler for 

32 additional steam production.

33 SCPC coal-fired power plants are currently commercially available and currently feasible 

34 alternatives to Davis-Besse license renewal. The overall environmental impacts of a coal-fired 

35 alternative, as well as the environmental impacts of the proposed Davis-Besse license renewal, 

36 are shown in Table 8.3-1. Additional details of the impacts on individual resources of the 

37 coal-fired alternative are provided in subsequent sections.

38 Table 8.3-1. Summary of Environmental Impacts of the Supercritical Coal-Fired 

39 Alternative Compared to Continued Operation of Davis-Besse

Supercritical Coal-Fired Generation Continued Davis-Besse Operation

Air quality MODERATE SMALL

Groundwater SMALL SMALL

Surface water SMALL SMALL

Aquatic resources SMALL to LARGE SMALL

Supercritical Steam

“Supercritical” refers to the thermodynamic 

properties of the steam being produced. Steam 

whose temperature and pressure is below water’s 

“critical point” (3,200 pounds per square inch 

absolute (psia) and 705 °F) is subcritical. 

Subcritical steam forms as water boils and both 

liquid and gas phases are observable in the 

steam. The majority of coal boilers currently 

operating in the U.S. produce subcritical steam 

with pressures around 2,400 psia and 

temperatures as high as 1,050 °F. Above the 

critical point pressure, water expands rather than 

boils, and the liquid and gaseous phases of water 

are indistinguishable in the supercritical steam 

that results. More than 150 coal boilers currently 

operating in the U.S. produce supercritical steam 

with pressures between 3,300 and 3,500 psia and 

temperatures between 1,000 and 1,100 °F. 

Ultrasupercritical boilers produce steam at 

pressures above 3,600 psia and temperatures 

exceeding 1,100 °F. There are only a few of 

these boilers in operation worldwide, and none in 

the U.S. 
Environmental Impacts of Alternatives

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Supercritical Coal-Fired Generation Continued Davis-Besse Operation

Terrestrial resources SMALL SMALL

Human health SMALL SMALL

Land use SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to LARGE SMALL

Aesthetics SMALL SMALL

Historic & archeological 

resources

SMALL to MODERATE SMALL to MODERATE

Waste management MODERATE SMALL

1 8.3.1 Air Quality

2 8.3.1.1 Construction 

3 Activities associated with the construction of the coal-fired power plant would cause air impacts 

4 as a result of emissions from construction equipment and fugitive dust from operation of the 

5 earth-moving and material handling equipment. Impacts result from the consumption of fossil 

6 fuels in the engines of construction vehicles and equipment, workforce vehicles used in 

7 commuting to and from the work site, and delivery vehicles. All such impacts would be 

8 temporary. Construction lead times for coal power plants are typically 4-5 years 

9 (OECD/IEA 2005). Workers’ vehicles and motorized construction equipment would generate 

10 temporary criteria pollutant emissions. Dust-control practices would reduce fugitive dust, which 

11 would be temporary in nature. Given the expected workforces and a relatively short 

12 construction period for both the coal-fired power plant, the NRC concludes that the impact of 

13 vehicle exhaust emissions and fugitive dust from operation of earth-moving and material 

14 handling equipment would be SMALL.

15 The overall air quality impacts associated with construction of a new coal-fired power plant 

16 would be SMALL.

17 8.3.1.2 Operation

18 Section 8.1.1 discusses the various state and Federal regulations that would control the 

19 construction and operation of an NGCC facility. Although this alternative examines the impact 

20 of a coal-fired power plant, many of the same regulatory controls would apply to pollutant 

21 releases. Air quality impacts from coal-fired generation can be substantial, resulting from the 

22 emissions of significant quantities of SOx, NOx, PM, CO, and HAPs such as mercury. Coal 

23 combustion is also a major source of the greenhouse gas CO2. However, many of these 

24 pollutants can be effectively controlled by various technologies, albeit with performance 

25 penalties that result in reductions in net power-generating capacity.

26 There are many major regulatory controls applicable to large fossil fuel external combustion 

27 sources. Air pollution control regulations promulgated under authority of the CAA would apply 

28 throughout FENOC’s service area. Emission limits for criteria pollutants would be reflective of 

29 existing ambient air quality at the selected location. Additionally, Ohio is subject to NOx SIP call 

30 regulations designed to reduce transport of ground-level ozone across State lines (EPA 2011b). 
Environmental Impacts of Alternatives

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1 A new coal-fired alternative located in Ohio would also be required to comply with those 

2 regulations.

3 This coal-fired alternative would be subject to New Source Performance Standards (NSPS) and 

4 New Source Review (NSR)/PSD reviews, leading to an operating permit that would specify 

5 limits to emissions of all criteria pollutants. The coal-fired plant would need to comply with the 

6 standards of performance set forth in 40 CFR Part 60 Subpart D and limits for particulate matter 

7 and opacity (40 CFR 60.42(a)), sulfur dioxide (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)). 

8 The Regional Haze Rule, promulgated by EPA in 1999 and last amended in October 2006 

9 (71 FR 60631), requires states to demonstrate reasonable progress toward the national visibility 

10 goal established in 1977 to prevent future impairment of visibility due to anthropogenic pollution 

11 in Class I areas. The visibility protection regulatory requirements are contained in 

12 40 CFR Part 51, Subpart P, including the review of the new sources that would be constructed 

13 in the attainment or unclassified areas and may affect visibility in any Federal Class I area. If a 

14 gas-fired alternative were located close to a mandatory Class I area, additional air pollution 

15 control requirements would potentially apply; however, there are no Class I areas in Ohio 

16 (EPA 2013). Regulations promulgated under the Acid Rain Program would cap SO2 and NOx

17 emissions from the coal-fired alternative and may require participation in an emissions trading 

18 program if sufficient reductions were not possible through the use of pollution control devices, 

19 fuel blending, or other strategies. In addition to being major sources of criteria pollutants, 

20 coal-fired plants can also be sources of HAPs as a result of hazardous constituents contained in 

21 the coal. Consequently, coal-fired plants would be subject to EPA’s mercury and air toxic 

22 standards (MATS) for power plants. A new coal-fired plant would be subject to emission limits 

23 for sulfur dioxide and nitrogen oxide promulgated under the Clean Air Interstate Rule (CAIR). 

24 In response to the Consolidated Appropriations Action of 2008 (Public Law 110-161), EPA 

25 promulgated final mandatory GHG reporting regulations on October 30, 2009, that became 

26 effective in December 2009 (EPA 2010a). Section 8.1.1 provides additional discussion 

27 regarding reporting regulations. A coal-fired plant capable of producing utility-scale amounts of 

28 power would qualify as a major generator of GHGs under the “Tailoring Rule,” recently 

29 promulgated by EPA (Section 8.1.1). 

30 Estimated Quantities of Pollutants Emitted. Although the NRC staff has identified the primary 

31 features and operating parameters of the supercritical pulverized coal boiler represented in this 

32 coal-fired alternative, many more aspects of system design, boiler firing conditions, and 

33 operating procedures can influence the quantity of criteria pollutants ultimately released to the 

34 environment. Consequently, the quantifications of pollutant emissions appearing below should 

35 be considered only as estimates. Algorithms and emission coefficients developed by EPA 

36 (EPA 1998) or empirical data from other relevant sources were used to estimate the amounts of 

37 pollutants that would result from operation of the coal-fired alternative. With a collective gross 

38 generating capacity of 960 MWe, the coal-fired alternative, operating at a capacity factor of 

39 85 percent, would produce 7,130,000 MWh of electricity per year to the grid. With an overall 

40 power plant thermal efficiency of 39 percent and an average caloric value of bituminous coal of 

41 12,886 Btu/lb, the amount of coal consumed annually would be approximately 2.88 million tons 

42 per year or (2.61 million MT per year).

43 Sulfur Oxides. The coal-fired alternative at an alternate site would likely use wet, 

44 limestone-based scrubbers to remove SO2. The NETL indicates that this technology can 

45 remove 95 to 98 percent of SO2 from flue gases (gases that exit to the atmosphere via a pipe or 

46 channel) (NETL 2007). SO2 emissions from a new coal-fired power plant would be subject to 

47 the requirements of Title IV of the CAA. Title IV was enacted to reduce emissions of SO2 and 
Environmental Impacts of Alternatives

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1 NOx, the two principal precursors of acid rain, by restricting emissions of these pollutants from 

2 power plants. Title IV caps aggregate annual power plant SO2 emissions and imposes controls 

3 on SO2 emissions through a system of marketable allowances.

4 Nitrogen Oxides. A coal-fired alternative at an alternate site would most likely employ various 

5 available NOx control technologies, which can involve combustion modifications, 

6 post-combustion controls, or both. Combustion modifications include low-NOx burners, over-fire 

7 air, and operational modifications. Post-combustion processes include selective catalytic 

8 reduction and selective non-catalytic reduction. An effective combination of the combustion 

9 modifications and post-combustion processes allow the reduction of NOx emissions by up to 

10 95 percent (EPA 1998). As discussed above, the most likely NOx control would involve a 

11 combination of low-NOx burners and selective catalytic reduction technologies to reduce NOx

12 emissions from this alternative by approximately 86 percent.

13 Particulates. The new coal-fired power plant would use fabric filters to remove particulates from 

14 flue gases with an expected 99.9 percent removal efficiency (NETL 2007). When present, wet 

15 SO2 scrubbers further reduce particulate matter emissions (EPA 2008). Coal-handling 

16 equipment would introduce fugitive dust emissions when fuel is transferred to onsite storage 

17 and then reclaimed from storage for use in the plant. FENOC estimated the release of 

18 particulates contained in cooling tower drift during reactor operation is 1.4 tons per year 

19 (TRC 1995). The cooling tower drift from the coal-fired alternative would be less than that 

20 released by Davis-Besse, since the cooling tower for a nuclear reactor has higher heat rejection 

21 demands and is considered to be a bounding condition.

22 Carbon Monoxide. Based on firing conditions and the boiler’s overall firing efficiency, 

23 supercritical pulverized coal boilers will emit carbon monoxide in limited quantities. Emission 

24 limits for CO will be based on heat input and typically expressed as pounds per million Btu input.

25 Carbon Dioxide. The amount of CO2 released per unit of power produced would be dependent 

26 on the quality of the fuel, the firing conditions, and the overall firing efficiency of the boiler. As 

27 discussed above, NRC presumes a CO2 emission factor of 210.2 lb/million Btu for the coal-fired 

28 alternative. 

29 Hazardous Air Pollutants. The EPA has determined that coal- and oil-fired electric utility 

30 steam-generating units are significant emitters of the following HAPs: arsenic, beryllium, 

31 cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and 

32 mercury (EPA 2000b). The EPA concluded that mercury is the HAP of greatest concern and 

33 that the following is true (EPA 2000b):

34 • A link exists between coal combustion and mercury emissions.

35 • Electric utility steam-generating units are the largest domestic source of mercury 

36 emissions.

37 • Certain segments of the U.S. population (e.g., the developing fetus and subsistence 

38 fish-eating populations) are believed to be at potential risk of adverse health effects 

39 resulting from mercury exposures caused by the consumption of contaminated fish. 

40 Using data and algorithms published by EPA and EIA and performance guarantees provided by 

41 pollution-control equipment vendors, the estimated annual emissions of criteria pollutants and 

42 CO2 from the operation of the coal-fired alternative are presented below.

43 • sulfur oxide—5,356 tons (4,860 MT) per year with 95 percent-efficient scrubbing, 
Environmental Impacts of Alternatives

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1 • nitrogen oxide—1,490 tons (1,350 MT) per year with 86 percent-efficient control, 

2 • particulate matter less than or equal to 10 μm—27.4 tons (24.9 MT) per year with 

3 99.9 percent-efficient control, 

4 • all particulate matter—135 tons (123 MT) per year with 99.9 percent percent-efficient 

5 control, 

6 • carbon monoxide—719 tons (652 MT) per year, 

7 • carbon dioxide—6,920,000 tons (6,280,000 MT) per year, and

8 • mercury—0.12 tons (0.11 MT) per year. 

9 The above analysis shows that emissions of air pollutants—including SOx, NOx, CO, PM2.5, and 

10 PM10—far exceed those produced by the existing nuclear power plant during operation, as well 

11 as those of the other fossil fuel alternatives considered in this section. Adverse human health 

12 effects, such as cancer and emphysema, have also been associated with air emissions from 

13 coal combustion and are discussed further in Section 8.4.5.

14 The NRC analysis of air quality impacts for a coal-fired alternative at an alternate site indicates 

15 that impacts would have clearly noticeable effects. However, given existing regulatory regimes, 

16 permit requirements, and emissions controls, the coal-fired alternative would not destabilize air 

17 quality. Therefore, NRC characterizes air impacts from a coal-fired plant located at an 

18 alternative site as MODERATE. Federal and state regulations would require the installation of 

19 pollution-control equipment to meet applicable local requirements and permit conditions and 

20 may eventually require participation in emissions trading schemes.

21 8.3.2 Groundwater Use and Quality

22 8.3.2.1 Construction

23 The use of groundwater is not expected in the construction of the coal-fired alternative at the 

24 alternative location. The alternative location may result in a greater area of impervious surface; 

25 thus, water that previously infiltrated the soil would instead become stormwater runoff. 

26 Groundwater recharge could be reduced, and resulting aquifer recharge rates may be reduced.

27 Dewatering of all open excavations would likely consume a small amount of groundwater. The 

28 NRC staff assumes that, during construction, liquid construction wastes would either be 

29 temporarily retained in lined evaporation ponds or stored in drums for shipment to offsite 

30 disposal facilities. With the application of best management practices and the controls 

31 established in a General Stormwater Permit, no impacts on groundwater quality due to the 

32 construction of the coal-fired alternative are expected. As a result, impacts to groundwater 

33 quality would be SMALL.

34 8.3.2.2 Operation

35 Impacts to the groundwater may result from the use of chemicals and fuels. The NRC 

36 presumes that a Groundwater Monitoring Program would be implemented, and any groundwater 

37 contamination from chemical spills would be detected and mitigated to restore the groundwater 

38 quality. As a result, no changes in the groundwater quality are likely to result from operation of 

39 the coal-fired alternative; thus, the impacts to the groundwater resource would be SMALL.
Environmental Impacts of Alternatives

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1 8.3.3 Surface Water Use and Quality

2 8.3.3.1 Construction

3 Minor impacts on surface water would occur during construction of the coal-fired alternative due 

4 to ground disturbances, alteration of natural drainage patterns, and from dewatering of 

5 excavations. A sitewide stormwater plan would be established for the construction period and 

6 would include controls and mitigations that would limit adverse impacts on surface water quality. 

7 The elements of that plan would be incorporated into a General Stormwater Permit, enforceable 

8 under the NPDES program authority, and would result in impacts on surface water during 

9 construction being SMALL.

10 8.3.3.2 Operation

11 During operation, surface water would be used for cooling and a water withdrawal, and NPDES 

12 permits would be required to regulate the thermal and chemical character of blowdown water 

13 from the cooling tower that would be discharged back to that surface water resource. 

14 Discharges of all other wastewaters associated with plant operation would also require an 

15 NPDES permit. Compliance with NPDES permits would assure that the operational impacts of 

16 the coal-fired alternative to surface water would remain SMALL.

17 8.3.4 Aquatic Ecology

18 8.3.4.1 Construction

19 Construction activities for the coal-fired alternative would cause minimal impacts on aquatic 

20 resources in Lake Erie because construction would occur far enough inland to remove the 

21 likelihood of the erosion and sedimentation. Additionally, stormwater control measures, which 

22 would be required to comply with Ohio’s NPDES permitting, would minimize the flow of 

23 disturbed soils into aquatic habitats. Depending on the available infrastructure at the selected 

24 site, the coal-fired alternative may require modification or expansion of the existing intake or 

25 discharge structures, or construction of new intake and discharge structures. Construction of 

26 new or modified intake and discharge structures may require dredging. Dredging activities 

27 would require BMPs for in-water work to minimize sedimentation and erosion. Due to the 

28 short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would 

29 likely be localized and temporary. Therefore, the impacts to the aquatic ecology during 

30 construction would be SMALL.

31 8.3.4.2 Operation

32 During operations, the coal-fired alternative would require a similar amount of cooling water as 

33 Davis-Besse. Impingement and entertainment would be minimized because NRC assumes that 

34 the plant would use a closed-cycle cooling system. However, the effects to particular species 

35 would vary based on site selection and surface water source. A similar amount of water would 

36 be discharged as at Davis-Besse. However, thermal impacts would also vary based on site 

37 selection and surface water source. The cooling system for a new coal-fired plant would have 

38 similar chemical discharges as Davis-Besse. While air emissions from the coal-fired plant 

39 would emit ash and particulates that could settle onto surface waters and introduce a new 

40 source of pollutants, lake or river tides would likely dissipate and dilute the concentration of 

41 pollutants resulting in minimal exposure to aquatic biota. Although the coal-fired alternative 

42 would have similar surface water usage, cooling system discharges, and chemical discharges 
Environmental Impacts of Alternatives

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1 as Davis-Besse, the impacts on aquatic ecology could range from SMALL to MODERATE 

2 because the impacts would vary substantially based on site selection for this alternative.

3 In addition, consultation under the ESA would be required to assess the occurrence and 

4 potential impacts to Federally protected aquatic species and habitats within affected surface 

5 waters. Coordination with State natural resource agencies would further ensure that the plant 

6 operator would take appropriate steps to avoid or mitigate impacts to state-listed species, 

7 habitats of conservation concern, and other protected species and habitats. The NRC assumes 

8 that these consultations would result in avoidance or mitigation measures that would minimize 

9 or eliminate potential impacts to protected aquatic species and habitats.

10 8.3.5 Terrestrial Ecology

11 8.3.5.1 Construction

12 Construction of a coal-fired plant would require land for both the plant site as well as land for 

13 coal mining and processing. Additionally, land would be required for disposal of ash and 

14 scrubber sludge. Because of the relatively large land requirement for the site, a portion of the 

15 site would likely be land that had not been previously disturbed, which would directly affect 

16 terrestrial habitat by removing existing vegetative communities and displacing wildlife. The level 

17 of direct impacts would vary substantially based on site selection. Offsite construction would 

18 occur mostly on land where coal extraction is ongoing. Erosion and sedimentation, fugitive 

19 dust, and construction debris impacts would be minor if appropriate BMPs are implemented. 

20 Impacts to terrestrial habitats and species from transmission line operation and corridor 

21 vegetation maintenance, and operation of the cooling system would be similar in magnitude and 

22 intensity as those resulting from operating nuclear reactors and would, therefore, be SMALL. 

23 Because of the potentially large area of undisturbed habitat that could be affected from 

24 construction of a coal-fired plant, the impacts of construction on terrestrial habitats and species 

25 could range from SMALL to MODERATE depending on the specific site location. 

26 8.3.5.2 Operation

27 During operation, cooling towers could deposit chemically treated water on surrounding land 

28 areas as drift that could affect existing vegetation. Drift impacts would be confined to the 

29 immediate vicinity of the cooling tower. Coal-mining operation would also affect terrestrial 

30 ecology in offsite coal mining areas, although the coal is likely to be provided from existing 

31 mines where land disturbances have already occurred. The operation of a coal-fired alternative 

32 would result in the generation of substantial amounts of solid and liquid wastes. It is not 

33 reasonable to conclude that disposal of those operational wastes would take place on the 

34 alternative site. Any offsite waste disposal by landfilling of coal combustion residues (CCR) 

35 would affect terrestrial ecology, at least throughout the active life of the disposal facility and until 

36 the land was reclaimed through a closure action. Deposition of acid rain resulting from NOx or 

37 SOx emissions, as well as the deposition of other pollutants, could also affect terrestrial ecology. 

38 Because of the expected controls on emissions in necessary operating permits, air deposition 

39 impacts might be noticeable but would not likely be destabilizing. Primarily because of the 

40 potential habitat disturbances, impacts on terrestrial resources from a coal-fired alternative 

41 would be SMALL and would occur mostly during construction. Section 8.3.8 provides an 

42 additional analysis of waste management. 

43 As discussed under aquatic ecology impacts, consultation with FWS under the ESA would avoid 

44 potentially adverse impacts to Federally listed species or adverse modification or destruction of 

45 designated critical habitat. Coordination with State natural resource agencies would further 
Environmental Impacts of Alternatives

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1 ensure that the plant operator would take appropriate steps to avoid or mitigate impacts to 

2 state-listed species, habitats of conservation concern, and other protected species and habitats. 

3 The NRC assumes that these consultations would result in avoidance or mitigation measures 

4 that would minimize or eliminate potential impacts to protected aquatic species and habitats. 

5 Consequently, the impacts operation of a coal-fired alternative on protected species and 

6 habitats would be SMALL.

7 8.3.6 Human Health

8 8.3.6.1 Construction

9 Construction of a coal-fired alternative would carry the same risks as construction of any major 

10 industrial facility. Federal and state regulations for worker protection would adequately control 

11 impacts on construction workers, and it is reasonable to assume that access to the active 

12 construction site would be limited to authorized, adequately trained personnel equipped with 

13 appropriate personal protection equipment. Impacts on the public would depend on existing 

14 land uses in parcels adjacent to the active construction zone but are expected to be SMALL.

15 8.3.6.2 Operation

16 Coal-fired power plants introduce worker risks from coal and limestone mining, from coal and 

17 limestone transportation, and from disposal of coal combustion residues and scrubber wastes. 

18 In addition, there are public risks from inhalation of stack emissions and the secondary effects of 

19 eating foods grown in areas subject to deposition from plant stacks.

20 Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the 

21 GEIS (NRC 1996). Cancer and emphysema, as a result of the inhalation of toxins and 

22 particulates, are identified as potential health risks to occupational workers and members of the 

23 public (NRC 1996). The human health risks associated with coal-fired power plants, both for 

24 occupational workers and members of the public, are greater than those of the current 

25 Davis-Besse reactor, due to exposures to chemicals such as mercury; SOx; NOx; radioactive 

26 elements such as uranium and thorium contained in coal and coal ash; and polycyclic aromatic 

27 hydrocarbon (PAH) compounds.

28 Regulations restricting emissions, enforced by either EPA or delegated state agencies, have 

29 reduced potential health effects but have not entirely eliminated them. These agencies also 

30 impose site-specific emission limits, as needed, to protect human health. Even if the coal-fired 

31 alternative were located in a non-attainment area, emission controls and trading or offset 

32 mechanisms could prevent further regional degradation; however, local effects could be visible. 

33 Many of the byproducts of coal combustion responsible for health effects are largely controlled, 

34 captured, or converted in modern power plants, although some level of health effects may 

35 remain.

36 Aside from emissions impacts, the coal-fired alternative introduces the risk of coal pile fires and, 

37 for those plants that manage coal combustion residue liquids and sludge in waste 

38 impoundments, the release of the waste may result due to a failure of the impoundment. Good 

39 housekeeping practices to control coal dust greatly reduce the potential for coal dust explosions 

40 or coal pile fires. Although there have been several instances in recent years, sludge 

41 impoundment failures are still rare. Free water could also be recovered from such waste 

42 streams and recycled, and the solid or semi-solid portions could be removed to permitted offsite 

43 disposal facilities.
Environmental Impacts of Alternatives

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1 Overall, given extensive health-based regulation and controls likely to be imposed as permit 

2 conditions applicable to waste handling and disposal, the NRC staff expects human health 

3 impacts from operation of the coal-fired alternative at an alternate site to be SMALL.

4 8.3.7 Land Use

5 The GEIS generically evaluates the impact of constructing and operating various replacement 

6 power plant alternatives on land use, both on and off each power plant site. The analysis of 

7 land-use impacts focuses on the amount of land area that would be affected by the construction 

8 and operation of an SCPC power plant at an alternate brownfield site.

9 8.3.7.1 Construction

10 Based on FENOC estimates, 1,547 ac (626 ha) of land could be needed to support a coal-fired 

11 alternative to replace Davis-Besse, along with 10 miles of transmission lines. It is expected that 

12 the SCPC alternative would be located at an existing power plant site or an industrial brownfield 

13 site with existing infrastructure, thus minimizing land requirements and construction impacts. 

14 Depending on existing power plant infrastructure, additional land may be needed for frequent 

15 coal and limestone deliveries by rail or barge. Therefore, land use impacts from land acquisition 

16 and construction would be SMALL to MODERATE.

17 8.3.7.2 Operation

18 Offsite land use would be affected by coal mining during power plant operations. Using the 

19 GEIS estimate, the SCPC alternative might require up to 20,020 ac (8,101 ha) of land for coal 

20 mining and ash and scrubber sludge disposal during power plant operations, based on an 

21 assumption of 22,000 ac (8,903 ha) of land required per 1,000 MWe and 910 MWe of 

22 generating capacity (NRC 1996). However, much of the land in existing coal mining areas has 

23 already experienced some level of disturbance. 

24 The elimination of uranium fuel for Davis-Besse would partially offset some of the land 

25 requirements for the SCPC alternative. Scaling from GEIS estimates, approximately 635 ac 

26 (256 ha) (based on 35 ac/yr disturbed per 1,000 MWe for 20 years) would no longer be needed 

27 for mining and processing uranium during the operating life of the plant (NRC 1996). 

28 Based on this preference to site the SCPC alternative on a previously disturbed industrial site, 

29 land use impacts from an NGCC power plant would range from SMALL to MODERATE 

30 depending on the amount on land needed to support coal mining and processing uranium 

31 during the operating life of the SCPC plant. 

32 8.3.8 Socioeconomics

33 As previously discussed in Section 8.1.8, two types of jobs would be created by this alternative: 

34 (1) construction jobs, which are transient, short in duration, and less likely to have long-term 

35 socioeconomic impacts; and (2) power plant operation jobs, which have a greater potential for 

36 permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

37 operation of the coal-fired alternative were evaluated to measure their possible effects on 

38 current socioeconomic conditions.
Environmental Impacts of Alternatives

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1 8.3.8.1 Construction

2 FENOC projected a construction workforce ranging from 1,092 to 2,275 workers would be 

3 required to construct the SCPC alternative at an alternative site. The relative economic impact 

4 of this many workers on the local economy and tax base would vary, with the greatest impacts 

5 occurring in the communities where the majority of construction workers would reside and 

6 spend their income. As a result, local communities could experience a short-term “boom” from 

7 increased tax revenue and income generated by construction expenditures and the increased 

8 demand for temporary (rental) housing and business services. After construction, local 

9 communities could experience a return to pre-construction economic conditions. Based on this 

10 information, and given the number of construction workers, socioeconomic impacts during 

11 construction in local communities could range from SMALL to MODERATE.

12 8.3.8.2 Operation

13 FENOC estimated an operational workforce of 228 workers. This alternative would result in a 

14 loss of approximately 825 relatively high-paying jobs at Davis-Besse, with a corresponding 

15 reduction in purchasing activity and tax contributions to the regional economy. In addition, the 

16 permanent housing market could also experience increased vacancies and decreased prices if 

17 operations workers and their families move out of the region. However, the amount of property 

18 taxes paid to local jurisdictions under the SCPC alternative may increase if additional land is 

19 required to support this alternative. Based on the above discussion, socioeconomic impacts 

20 during operations could range from SMALL to MODERATE.

21 8.3.9 Transportation

22 Commuting workers and truck deliveries of materials and equipment would cause transportation 

23 impacts during the construction and operation of the SCPC power plant.

24 8.3.9.1 Construction 

25 Transportation impacts associated with construction of the SCPC alternative would consist of 

26 commuting workers and truck deliveries of construction materials. During periods of peak 

27 construction activity, up to 2,275 workers could be commuting daily to the site significantly 

28 adding to the normal flow of traffic (NRC 1996). Vehicular traffic would peak during shift 

29 changes, resulting in temporary levels of service impacts and delays at intersections. Materials 

30 also could be delivered by rail or barge, depending on site location. Traffic-related 

31 transportation impacts during construction likely would range from MODERATE to LARGE. 

32 8.3.9.2 Operation 

33 Once construction of the SCPC alternative is complete, traffic-related transportation impacts on 

34 local roads would be greatly reduced. The estimated number of operations workers would be 

35 228 (NRC 1996). Traffic on roadways would peak during shift changes, resulting in temporary 

36 levels of service impacts and delays at intersections. Frequent deliveries of coal and limestone 

37 by rail would cause levels of service impacts on certain roads because of delays at railroad 

38 crossings. Onsite coal storage would make it possible to receive several trains per day at a site 

39 with rail access. Limestone delivered by rail could also add additional traffic (though 

40 considerably less traffic than that generated by coal deliveries). If a site on navigable waters 

41 were used, barge delivery of coal and other materials would be feasible. Overall, the SCPC 

42 alternative transportation impacts would be SMALL to MODERATE during plant operations.
Environmental Impacts of Alternatives

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1 8.3.10 Aesthetics

2 The analysis of aesthetic impacts focuses on the degree of contrast between the SCPC 

3 alternative and the surrounding landscape and the visibility of the new SCPC plant at an existing 

4 power plant site. 

5 During construction, all of the clearing and excavation would occur on the existing power plant 

6 site. These activities could be visible from offsite roads. The coal-fired power plant could be 

7 approximately 100 ft (30 m) tall, with two to four exhaust stacks several hundred feet tall with 

8 natural draft cooling towers approximately 400 to 500 ft (122 to 152 m) in height. 

9 The power block of the SCPC alternative could look very similar to the existing power plant, and 

10 construction would appear similar to other ongoing onsite activities. Aesthetic changes during 

11 construction would be limited to the immediate vicinity of the existing power plant site, and 

12 overall impacts would be SMALL.

13 8.3.11 Noise

14 Ambient noise conditions in the vicinity of the existing power plant site would be affected by the 

15 construction and operation of a new SCPC power plant.

16 8.3.11.1 Construction 

17 Overall noise levels at the existing power plant site would increase during the construction of the 

18 new SCPC power plant. Construction noises during construction, however, would be 

19 intermittent and relatively brief, and noise levels would decrease as the distance from the noise 

20 source increases. Impacts due to noise as a result of the construction of the SCPC alternative 

21 could range from SMALL to MODERATE.

22 8.3.11.2 Operation 

23 Noise generated during power plant operations would be limited to routine industrial processes 

24 and communications. Therefore, noise impacts due to the operation of the SCPC power plant

25 would be SMALL.

26 8.3.12 Historic and Archeological Resources

27 Lands needed to support construction of a coal-fired plant and associated corridors would need 

28 to be surveyed for historic and archaeological resources. Resources found in these surveys 

29 would need to be evaluated for eligibility on the NRHP, and mitigation of adverse effects would 

30 need to be addressed if eligible resources were encountered. When constructing a coal-fired 

31 plant on a previously disturbed former plant (brownfield) site, an inventory may still be 

32 necessary if the site has not been previously surveyed or to verify the level of disturbance and 

33 evaluate the potential for intact subsurface resources. The potential for impacts on historic and 

34 archaeological resources from this alternative would vary greatly depending on the resource 

35 richness and location of the proposed site. However, given that the preference is to use a 

36 previously disturbed former plant site, avoidance of significant historic and archaeological 

37 resources should be possible and effectively managed under current laws and regulations. 

38 Therefore, the impacts on historic and archaeological resources from the coal-fired alternative 

39 would be SMALL to MODERATE.
Environmental Impacts of Alternatives

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1 8.3.13 Environmental Justice

2 The environmental justice impact analysis evaluates the potential for disproportionately high and 

3 adverse human health, environmental, and socioeconomic effects on minority and low-income 

4 populations that could result from the construction and operation of a new power plant. As 

5 previously discussed in Section 8.1.12, such effects may include human health, biological, 

6 cultural, economic, or social impacts. 

7 8.3.13.1 Construction

8 Potential impacts to minority and low-income populations from the construction of an SCPC 

9 alternative would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, 

10 traffic, employment, and housing impacts). Noise and dust impacts from construction would be 

11 short-term and primarily limited to onsite activities. Minority and low-income populations 

12 residing along site access roads would be directly affected by increased commuter vehicle 

13 traffic during shift changes and truck traffic. However, because of the temporary nature of 

14 construction, these effects are unlikely to be high and adverse and would be contained to a 

15 limited time period during certain hours of the day. Increased demand for rental housing during 

16 construction could cause rental costs to rise disproportionately affecting low-income populations 

17 who rely on inexpensive housing. However, given the likelihood of locating the SCPC 

18 alternative at the site of an existing or former power plant and the proximity of most power plant 

19 sites to metropolitan areas, workers could commute to the construction site, thereby reducing 

20 the need for rental housing.

21 Based on this information and the analysis of human health and environmental impacts 

22 presented in Section 8.3 of this chapter, the construction of the SCPC power plant would not 

23 have disproportionately high and adverse human health and environmental effects on minority 

24 and low-income populations.

25 8.3.13.2 Operation

26 Emissions from the operation of an SCPC plant could affect minority and low-income 

27 populations as well as the general population living in the vicinity of the new power plant. 

28 However, all would be exposed to the same potential effects from SCPC power plant 

29 operations, and any impacts would depend on the magnitude of the change in ambient air 

30 quality conditions. Permitted air emissions are expected to remain within regulatory standards.

31 Based on this information and the analysis of human health and environmental impacts 

32 presented in Section 8.3 of this chapter, the operation of the SCPC power plant would not have 

33 disproportionately high and adverse human health and environmental effects on minority and 

34 low-income populations.

35 8.3.14 Waste Management

36 8.3.14.1 Construction

37 The coal-fired alternative would result in wastes during construction as a result of activities such 

38 as vegetation removal, excavation, and preparing the site surface before other crews begin 

39 actual construction of the plant. Wastes typical of the construction of large industrial facilities 

40 would also be generated. Because this alternative would be located an alternative site, 

41 additional construction of new transmission lines and a new rail spur would be necessary.
Environmental Impacts of Alternatives

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1 The impacts from waste generated during construction stage would be short-lived. The amount 

2 of construction waste would be small compared to the amount of waste generated during 

3 operational stage, and most could be recycled. Overall, the impacts from waste generated 

4 during construction stage would be SMALL.

5 8.3.14.2 Operation

6 Coal combustion generates several waste streams, including ash (a dry solid recovered from 

7 both pollution control devices (fly ash) and from the bottom of the boiler (bottom ash)) and 

8 sludge (a semi-solid by-product of emission control system operation, in this case, primarily 

9 calcium sulfate from the operation of the wet calcium carbonate SO2 scrubber). Although EPA 

10 has not classified coal residue as hazardous waste, it does contain hazardous constituents that 

11 might leach from improperly designed or operated disposal cells and threaten surface or 

12 groundwater resources.

13 Particulates. Combustion of 2.88 million tons per year (2.61 million MT per year) of coal would 

14 result in substantial amounts of CCR, which includes both fly and bottom ash recovered from 

15 the fabric filter and from the bottom of the boiler. The NRC staff estimates that 271,960 tons of 

16 ash would be generated each year; of that, approximately 271,830 tons per year would be 

17 collected as bottom ash and fly ash in the fabric filter. Some additional fly ash might also be 

18 captured in the SO2 scrubber downstream of the fabric filter. That amount has not been 

19 quantified; however, some CCR and scrubber sludge could be put to beneficial use, such as an 

20 admixture for lightweight concrete, road base, and road embankment stabilization. The 

21 remainder of the CCR and scrubber sludge would require disposal. Because the recycle 

22 potential for CCR relies on both the physical properties of the ash and the leachability of any 

23 toxic constituents present, a more conservative estimate of 50 percent being recycled is 

24 appropriate, with the remaining amount—135,400 tons per year—requiring disposal. Disposal 

25 of this amount of ash annually by landfilling over the expected 40-year lifetime of the coal-fired 

26 plants could noticeably affect land use, groundwater, and surface water quality. Landfill 

27 locations would require proper siting in accordance with state solid waste regulations and 

28 leachate from the disposal cells would need to be monitored and possibly captured for treatment 

29 because of leaching of toxic components (including heavy metals) in the ash. After closure of 

30 the waste site and revegetation, the land could be available for other uses.

31 Sulfur Oxides. Combustion of 2.88 million tons per year (2.61 million MT per year) of coal with 

32 1.96 percent sulfur would result in the generation of 102,260 tons per year (92,770 MT per year) 

33 of SO2, 95 percent of which would be captured in the wet scrubber and converted to an 

34 equimolar amount of calcium sulfate or 217,288 tons per year (197,120 MT per year) (dry 

35 basis). The NRC staff presumes that as much as 90 percent of the scrubber sludge could be 

36 recycled for such applications as gypsum wallboards. The remaining 21,730 tons per year 

37 (19,710 MT per year) could be co-disposed with the previously mentioned remaining CCR.

38 Spent Catalysts. The NRC staff has not estimated the amount of spent catalysts that would be 

39 produced, but it presumes that the entire amount would have no recycling opportunities and 

40 would require disposal. Depending on the catalysts used, special handling might also be 

41 required to address the potential hazardous character of these spent catalysts.

42 The impacts from waste generated during operation of this coal-fired alternative would be 

43 MODERATE; the affects would be clearly visible but would not destabilize any important 

44 resource, provided appropriate controls were applied. Failure to implement proper controls 

45 could result in a LARGE impact on surface water and land. The extent of disposal would be 

46 dependent on the percentage of the CCR and scrubber sludge that could be recycled.
Environmental Impacts of Alternatives

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1 Therefore, the NRC staff concludes that the overall impacts on wastes from construction and 

2 operation of this alternative would be MODERATE.

3 8.3.15 Climate Change-Related Impacts of a Coal-Fired Alternative

4 Combustion of fossil fuels, including coal, is the greatest anthropogenic source of GHG 

5 emissions in the U.S. After a thorough examination of the scientific evidence and careful 

6 consideration of public comments, the EPA announced on December 7, 2009, that GHGs 

7 threaten the public health and welfare of the American people and meet the CAA definition of air 

8 pollutants. Carbon dioxide (CO2) is by far the largest GHG emitted during fossil fuel 

9 combustion. This section presents an assessment of the potential impacts the construction and 

10 operation of a coal-fired plant will have on climate change. 

11 8.3.15.1 Construction

12 Impacts on climate change from the construction of a coal-fired alternative would result primarily 

13 from the consumption of fossil fuels in the engines of construction vehicles and equipment, 

14 workforce vehicles used in commuting to and from the work site, and delivery vehicles. All such 

15 impacts would be temporary. However, given the expected relatively short construction period, 

16 the overall impact on climate change from the releases of GHGs during construction of a 

17 coal-fired alternative would be SMALL.

18 8.3.15.2 Operation

19 EPA reported that, in 2010, the total amount of carbon dioxide equivalent (CO2e) emissions 

20 related to electricity generation was 2,277.3 MMT (EPA 2012). The EIA reported that, in 2010, 

21 electricity production in Ohio was responsible for 121 MMT of CO2 emissions (123 MMT of 

22 CO2e) (EIA 2012). The NRC staff estimates that operation of the coal-fired alternative would 

23 amount to 6.98 million tons of CO2e per year (6.33 MMT of CO2e per year). This amount would 

24 represent 5 percent of the GHGs emitted in Ohio in 2010. This amount represents a 5 percent 

25 increase over the 2010 Ohio CO2e emissions. Although coal combustion in the boilers would be 

26 the primary source, other miscellaneous ancillary sources such as truck and rail deliveries of 

27 materials to the site, commuting of the workforce, and deliveries of wastes to offsite disposal or

28 recycling facilities would make contributions to the CO2e emissions from continued operations.

29 NETL estimates that further development could yield technologies that could capture and 

30 remove as much as 90 percent of the CO2 from the exhausts of supercritical pulverized 

31 coal-fired boilers (NETL 2010). With CCS in place, the coal-fired alternative would release 

32 625,000 tons per year (567,000 metric tons per year), and impacts to climate change would be 

33 further reduced. 

34 A coal-fired alternative would be expected to have a MODERATE impact on climate change. 

35 GHG emissions resulting from operation would be noticeable. Estimated GHG emissions would 

36 be nine times larger than the threshold in EPA’s tailoring rule for GHG (75,000 tons (68,000 MT) 

37 per year of CO2e). 

38 8.4 Alternatives Considered but Dismissed

39 Alternatives to Davis-Besse license renewal that were considered and eliminated from detailed 

40 study are presented in this section. The order of presentation does not imply a priority. These 

41 alternatives were eliminated because of technical, resource availability, or current commercial 
Environmental Impacts of Alternatives

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1 limitations associated with these alternatives. As such, these alternatives would not be able to 

2 supply the replacement power needed if Davis-Besse were to shutdown in 2017. 

3 8.4.1 New Nuclear

4 Given the current combined license (COL) application schedule, the time needed to review an

5 application, and the anticipated length of construction, the NRC staff considers it unlikely that a 

6 new nuclear reactor could be sited, constructed, and become operational by the time the 

7 Davis-Besse license expires on April 22, 2017, and so it will not be considered by NRC staff as 

8 an alternative to license renewal.

9 8.4.2 Wind

10 Ohio has approximately 55,000 MW of wind power potential (NREL 2011), though only 67 MW

11 of wind power capacity was in service as of mid-2011 (Wind Powering America 2011). Ohio has 

12 lagged the neighboring states of Pennsylvania, West Virginia, and Indiana in wind power 

13 implementation. 

14 The largest wind project in Ohio history, the Blue Creek Wind Farm, was completed in 

15 March 2012 and has a capacity of 304 MW. Preliminary work for Blue Creek began in 2006. 

16 The State of Ohio currently has 802 MW of OPSB-approved projects that have not yet started 

17 operations and 524 MW of wind projects in review for a Certificate of Environmental 

18 Compatibility and Public Need (OPSB 2013). All of the approved projects are located onshore.

19 Offshore wind resources in Lake Erie are of high quality, though no wind installations currently 

20 operate there. The Lake Erie Energy Development Corporation (LEEDCo), a private non-profit 

21 group, has plans to install 20 to 30 MW of wind capacity 7 miles offshore of Cleveland. This 

22 would be the first freshwater, offshore wind facility in the U.S. LEEDCo aims to develop 

23 1,000 MW of offshore windpower in Lake Erie by 2020 (LEEDCo 2013), though no turbines 

24 have yet been sited in Lake Erie.

25 Efforts to build offshore wind installations elsewhere in the Great Lakes have yet to succeed. 

26 For example, the New York Power Authority (NYPA) proposal to site and develop wind power 

27 resources in New York’s portions of Lake Erie or Lake Ontario were shelved in 

28 September 2011, when NYPA found that offshore wind installations would cost two to four times 

29 more than land-based wind (Reuters 2011). 

30 In the Atlantic Ocean, several wind-power projects have been proposed, but none have yet to 

31 begin construction. The most prominent of these projects, Cape Wind, was first proposed in 

32 2001 and, after a lengthy and controversial permitting process, construction may begin in 2014. 

33 . Other projects offshore of Rhode Island and New Jersey are smaller than Cape Wind 

34 (Wald 2011), and another organization has proposed—though not yet constructed—a 

35 high-voltage direct-current powerline on the seafloor to connect offshore projects (Atlantic Wind 

36 Connection undated; Wald 2011). Finally, a group working near Long Island proposes an 

37 installation of 700 MW of wind capacity (Con Edison 2009). Backers are optimistic and the 

38 potential is great, but despite strong interest in offshore wind on the Great Lakes and the 

39 Atlantic Coast, no offshore wind power installations have yet materialized in the U.S. As no 

40 offshore wind capacity yet exists in either the Great Lakes or on the Atlantic Coast and as none 

41 appear likely to exist on a large commercial scale by 2017 (given the current state of 

42 development), the NRC staff finds that offshore wind will not be a reasonable alternative to 

43 Davis-Besse by 2017.
Environmental Impacts of Alternatives

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1 Comments received during scoping suggest that wind power could replace Davis-Besse. The 

2 NRC staff notes that, although wind power is intermittent and individual installations are unable 

3 to support baseload power supply, some individuals or groups have proposed that multiple, 

4 interconnected wind installations separated by long distances (and thus exposed to different 

5 weather and wind conditions) could function as a virtual power plant and provide wind power 

6 that could replace baseload generators like Davis-Besse. To date, however, no states or 

7 utilities operate arrays of wind installations as virtual power plants.

8 While Ohio is not large enough to site wind turbines as far apart as in the Archer and 

9 Jacobsen (2007) study discussed in Section 8.2, assuming that wind turbines could be 

10 constructed in neighboring states, approximately 4,300 MW of new wind capacity would be 

11 necessary to replace Davis-Besse. Provided that Blue Creek Wind Farm and all other approved 

12 wind projects in Ohio are completed as planned, this amount of wind power would exceed by 

13 approximately 2,300 MW the planned capacity in the State. To date, only Texas has more than 

14 4,300 MW of installed wind capacity, and it is also the only state that has seen construction of 

15 4,300 MW of wind capacity in 5 years’ time.

16 Unlike Ohio, Texas has outstanding onshore wind resources, with potential for over 

17 1,900,000 MW of wind power, or more than 34 times the amount of wind potential that NREL 

18 found could exist in Ohio (Texas’ potential is also more than 31 times greater than Ohio’s, 

19 Pennsylvania’s, West Virginia’s, and New Jersey’s potentials combined) (NREL 2011). To date, 

20 Texas has approximately 10,135 MW of installed capacity (Wind Powering America 2011). 

21 Iowa, which has the largest installed capacity after Texas at 3,675 MW (Ibid.), has more than 

22 10 times Ohio’s wind potential (and more than 9 times the wind potential in Ohio, West Virginia, 

23 Pennsylvania, and New Jersey, combined) (NREL 2011). In short, to replace Davis-Besse with 

24 a wholly wind-powered alternative would require the second-fastest build-out of wind capacity in 

25 U.S. history in a State with relatively modest (19th of 50 states, and lower than the mean of all 

26 states) wind potential (NREL 2011).

27 Given the amount of wind capacity necessary to replace Davis-Besse, Ohio’s wind resource 

28 potential (as well as the wind resources of surrounding states), Ohio’s pace of wind 

29 development to date, and the 5 years available prior to license expiration, the NRC staff finds a 

30 completely wind-based alternative to be unreasonable.

31 Wind With Power Storage. Two storage options exist on a large enough scale to prove useful in 

32 supporting large wind installations. The largest energy storage installations in use in the U.S. 

33 are pumped storage hydroelectric facilities. These facilities use two reservoirs, one above the 

34 other in elevation. One or more electric pumps, driven by excess electricity, push water into the 

35 upper reservoir during periods of low demand or high electrical availability. During periods of 

36 high demand or low availability, operators release water from the upper reservoir to the lower 

37 reservoir through turbines that generate electricity. As the NRC staff notes in Section 8.4.5, 

38 Ohio has approximately 183 MW of undeveloped hydropower potential, an amount that is 

39 insufficient to back up wind power to function as an alternative to license renewal. Further, EIA 

40 is projecting a 2.2 percent growth in pumped storage capacity through 2040 (DOE/EIA 2013).

41 In compressed air energy storage (CAES), an electric motor uses excess electricity to pump air 

42 into an underground, pressurized cavity, and when electricity is needed, the compressed air is 

43 released through a gas turbine generator. The compressed air provides some power to the 

44 generator (essentially, reducing the need for compression by the turbine), and burning natural 

45 gas provides heat to increase the pressure and power the turbine. Thus, CAES is not solely an 
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1 energy storage technology but also relies on additional fossil fuel (future, as-yet-undeveloped 

2 compressed air energy storage technologies promise no reliance on natural gas).

3 The other option, CAES, is a commercially viable technology for energy storage, though it is 

4 seldom used on a utility scale. CAES is discussed as part of the combination alternative in 

5 Section 8.2. 

6 Currently, no CAES facilities exist in Ohio, though—as discussed in Section 8.2—First Energy 

7 has acquired the Norton Energy Storage project, a proposed CAES facility that could be 

8 constructed in a retired limestone mine. 

9 Without detailed wind-speed data, specific site information, and detailed information on the full 

10 energy-storage capacity of the Norton Energy Storage project (measured in MWh, as opposed 

11 to its maximum instantaneous power output, measured in MW), it is difficult to estimate how 

12 much less wind capacity would be necessary if 536 MW of CAES are available. CAES is less 

13 effective at offsetting seasonal wind variation than it is at offsetting intra-day or day-to-day 

14 variation, as very large air reservoirs would be necessary to offset month-to-month or 

15 season-to-season variation. The McIntosh facility in Alabama provides up to 26 hours of 

16 compressed-air storage, while the Huntorf facility in Germany provides up to 2 hours of storage. 

17 Based on current experience, the NRC staff finds that CAES is unlikely to offset seasonal wind 

18 variability.

19 Currently, no state or utility in the U.S. is operating wind power in combination with CAES to 

20 offset baseload power supplies. A group of utilities had proposed a 270-MW project of that type 

21 in Iowa but has since terminated the project due to geologic unsuitability of the proposed site 

22 (ISEPA 2011). The McIntosh facility is the only existing U.S. CAES installation, and it is 

23 approximately one-fifth the size of the maximum capability FENOC indicates could exist at the 

24 Norton Energy Storage site by 2017. Further, the geology of the Norton Energy Project site 

25 (limestone) differs from both the Huntorf facility in Germany and the McIntosh facility in 

26 Alabama, which are in salt domes. Given the relatively rarity of these facilities, despite a 

27 33-year span since the Huntorf facility went into operation, the challenges encountered to date 

28 at other sites where CAES has been considered, and the unique geology necessary for 

29 compressed air energy storage to work on a utility scale, the NRC staff assumes that the Norton 

30 Energy Storage project is the only viable nearby option for CAES at this time.

31 Archer and Jacobsen found that a widely dispersed array of interconnected wind installations 

32 could provide a portion of its nameplate capacity at a high availability. Under most conditions, a 

33 19-site array (the largest array Archer and Jacobsen considered) produced more than 

34 21 percent of its nameplate capacity, ultimately yielding 45 percent of the nameplate capacity 

35 when averaged over a year’s time. Conceivably, the extra 24 percent of the array’s nameplate 

36 output could be stored and dispatched during periods of low wind availability to allow a smaller 

37 wind array to serve the same load with the same availability, the same wind installation to serve 

38 a larger load with the same availability, or the same array to serve the same load with a higher 

39 availability (or some combination of the three possible outcomes). Assuming that CAES could 

40 allow a multiple site wind power array to capture all of the wind power up to its 45 percent

41 capacity factor, approximately 2,018 MW of installed wind capacity would be necessary to 

42 replace Davis-Besse. This assumption oversimplifies the challenges associated with using the 

43 Norton project to store and release power. The maximum theoretical output of Norton by 2017 

44 is 536 MW; therefore, it would be unable to provide enough power on days with little or no wind 

45 to offset the capacity provided by Davis-Besse. A utility would have to construct more than 

46 2,018 MW, but less than 4,300 MW, in order to rely on a project like Norton to provide baseload 
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1 wind when paired with a wind power array. Properly sizing a wind array to match the available 

2 energy storage would depend on detailed wind power information, operational characteristics for 

3 each installation, and performance characteristics of the storage site.

4 The amount of new wind power (2,018 MW) would exceed the amount of windpower installed in 

5 Ohio, West Virginia, Pennsylvania, Michigan, and New Jersey, combined, over the past 

6 12 years. When combined with the fact that no utility is currently using CAES in combination 

7 with wind power to provide baseload power, the NRC staff does not consider this combination to 

8 be a reasonable alternative to Davis-Besse license renewal.

9 Environmental Impacts of a Wind Array and a Wind Array with the Norton Project. Although 

10 wind power or wind power with CAES are not considered reasonable alternatives, FENOC 

11 provided an analysis of potential impacts from both of these alternatives in its

12 September 19, 2011, supplement to the Davis-Besse ER (FENOC 2011). The potential impacts 

13 of these dismissed alternatives to provide a comparison to the impacts of the proposed action.

14 Land Use. FENOC indicated that an array of interconnected wind installations would have a 

15 MODERATE to LARGE impact on land use, depending on the locations of the wind installations 

16 (FENOC 2011). FENOC assumed that an individual wind farm would require 50 ac (20 ha) per 

17 MW of capacity and that approximately 5 percent of the total land area would actually be 

18 occupied by turbines and support equipment. FENOC noted that Ohio’s predominant land uses 

19 are rural agricultural croplands with scattered residences and woodlots and that turbines could 

20 be placed with adequate buffers around incompatible land uses. Assuming that 50 ac (20 ha) is 

21 required for each MW, a total of 10,800 ac (4,370 ha) will be occupied by the wind farm 

22 throughout its operation, while turbine installations will be spread across 216,000 ac 

(87,400 ha).2 23 As this amount of land use is widely spread across Ohio, and perhaps into 

24 neighboring states or, in small amounts, to offshore Lake Erie, and is unlikely to prevent 

25 complimentary land uses from continuing in adjoining lands. Overall land use impacts from an 

26 interconnected wind array would be MODERATE. 

27 Two elements change if CAES is paired with wind farm power generation. First, less land is 

28 required if the number of turbines is reduced due to energy storage. The amount of land 

29 required would vary from 5,040 ac (2,040 ha) to 10,800 ac (4,370 ha), depending on the 

30 characteristics of the CAES technology and specific wind characteristics at each site. Second, 

31 the North Energy Storage project site, with 92 ac (37 ha) at the surface, would be added to the 

32 total land use for the project, though that site is already a former mining site and committed to 

33 First Energy’s uses. The amount of total land would range from 5,132 ac (2,080 ha) to 

34 10,892 ac (4,410 ha). Again, overall land use impacts from a combination of wind power 

35 generation and CAES would be MODERATE. 

36 Water Use and Quality—Surface Water. As FENOC noted in its supplement to the ER, wind 

37 turbines require no cooling water or water intakes, and the only potential impacts to surface 

38 water are a result of erosion or sedimentation during construction. As any projects within Ohio 

39 would have to minimize erosion and sedimentation through the use of onsite best management 

40 practices, and as construction-related issues would be short-lived with only temporary effects, 

41 the NRC staff finds that these impacts would only be temporarily noticeable and would be 

 

2 While FENOC calculated that 3,030 turbines would occupy 4,550 ac, the NRC staff here estimates that 2,150 turbines would 

occupy 10,750 ac. In reviewing FENOC’s supplement, the NRC staff identified an error that caused FENOC to underestimate the 

potential land use of the wind installation rather than calculating land use on the size of the total installation (6,060 MW), FENOC 

appears to have calculated land use based only on the credited capacity factor (1,820 MW). Thus, although NRC staff assumed 

fewer turbines would be necessary to replace Davis-Besse than FENOC did, the NRC staff found the wind alternative requires more 

land area used than FENOC did.
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1 unlikely to affect any important attributes of surface water resources. Further, as any offshore 

2 portion of an interconnected array of wind installations will be limited in size, the NRC staff does 

3 not expect these impacts to be significant. Overall, the NRC staff estimates that impacts to 

4 surface water use and quality will be SMALL.

5 Surface water use will increase if CAES is paired with an interconnected array of wind 

6 installations. FENOC indicates that the Norton Energy Storage project would rely on cooling 

7 towers to dissipate the heat that the gas turbines and compressors create, though the cooling 

8 towers would be much smaller than those typically used for coal and gas generation plants. 

9 FENOC indicates that cooling water makeup losses would be considerably less than those from 

10 Davis-Besse, as would discharge flows. FENOC indicates that this is primarily because less 

11 power would be derived from a steam cycle, though FENOC’s ER supplement provides no 

12 indication that a CAES would rely on a steam cycle for any of its power generation. FENOC 

13 cites its 2007 ER from Beaver Valley Generating Station to support this proposition, though 

14 FENOC did not consider CAES in that ER. Based on a review of CAES technologies and 

15 FENOC’s assertions regarding the Norton Energy Storage project, the NRC staff concludes that 

16 FENOC’s overall assertion regarding water consumption is correct and is likely conservative, as 

17 it appears that no water is necessary to condense steam at the Norton Energy Storage project 

18 site. As a result, the NRC staff concludes that water consumption will not have a noticeable 

19 effect on surface water use or quality from an interconnected array of wind installations 

20 combined with compressed air energy storage. The overall impact on surface water use and 

21 quality is SMALL.

22 Water Use and Quality—Groundwater. FENOC indicated that groundwater would be used 

23 during construction only if other potable water supplies are limited and that “minor” amounts 

24 may be necessary during operation if other supplies are unavailable. As indicated in the 

25 preceding section, wind turbines do not rely on water for cooling, and the lack of onsite crews at 

26 wind installations means that installations do not generally require water for operations or to 

27 provide for the potable and sanitary needs of personnel. As a result, impacts to groundwater 

28 from an interconnected array of wind installations would be SMALL

29 CAES, as noted in the previous section, increases the amount of water the interconnected array 

30 of wind installations would require, but FENOC indicates that a CAES plant would not rely on 

31 groundwater for cooling and that regulations for groundwater extraction for potable water would 

32 limit impacts to SMALL. Groundwater would not be used for cooling, and consumption of 

33 groundwater for potable water supply would have a SMALL impact.

34 Air Quality. FENOC indicates that there are no air quality impacts associated with the operation 

35 of interconnected wind farms, and construction of the installations could result in short-term 

36 impacts from fugitive dust and equipment emissions. FENOC indicates that the emissions are 

37 SMALL. The NRC staff’s review of potential air emissions from wind power installation shows 

38 that some maintenance equipment may produce emissions during operations, but, generally, 

39 the turbines themselves do not create air emissions. During construction, crews will employ 

40 dust-control practices, and emissions from installation equipment will be temporary and will not 

41 noticeably affect air quality. The air quality impacts from an interconnected array of wind 

42 installations is SMALL.

43 CAES creates operational air-quality impacts because the Norton Energy Storage project relies 

44 on gas-fired turbines to heat the air released from underground storage and provide some of the 

45 energy produced by the compressed air storage system. FENOC estimated emissions for the 

46 Norton Energy Storage project based on six combustion trains and one cooling tower, to match 
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1 the amounts permitted by the Norton Energy Storage project’s air emissions permit. The NRC 

2 staff notes that this overestimates the air quality impacts from the four trains that FENOC 

3 indicates could be operational at the Norton Energy Storage project by 2017. The NRC staff 

4 has scaled the air emissions from the Norton Energy Storage project to provide an estimate for 

5 four trains rather than six, while acknowledging that this estimate may slightly over or 

6 underestimate impacts of four trains, depending on their operational characteristics and whether 

7 additional trains benefit from efficiencies of scale or require additional support services.

8 The NRC staff estimates that the Norton Energy Storage project would have the following 

9 emissions:

10 • sulfur dioxide—28 tons (26 MT), 

11 • nitrogen oxide—62 tons (57 MT), 

12 • particulate matter less than or equal to 10 μm—31 tons (28 MT), 

13 • VOCs—18 tons (16 MT), and

14 • carbon dioxide—450,000 tons (410,000 MT). 

15 FENOC indicated that both sulfur dioxide and nitrogen oxide emissions would be subject to cap 

16 and trade programs; they would not add to regional emissions of either pollutant (in all seasons 

17 for sulfur dioxide and in ozone season for nitrogen oxides) as well as permit-based emissions 

18 controls for all listed pollutants. FENOC indicated that air quality impacts would be 

19 MODERATE. Earlier in this chapter, however, the NRC staff found these air emissions to be 

20 SMALL. The NRC staff notes that impacts are substantially lower than those of the NGCC 

21 alternative considered in Section 8.1. As a result, the NRC staff finds that the impacts of the 

22 Norton Energy Storage facility portion of this combination alternative on air quality would be 

23 SMALL.

24 Ecological Resources. FENOC indicates that interconnected wind installations could have a 

25 LARGE impact on ecological resources, especially during construction. Further, FENOC notes 

26 that wind installations could have noticeable impacts on migratory birds, eagles and raptors, and 

27 bats. FENOC indicates that wind installations in some parts of the U.S. have minor impacts, 

28 although FENOC also asserts that one cannot assume that similar impacts would occur in Ohio, 

29 particularly if any wind turbines are sited in or near Lake Erie. FENOC indicates that best 

30 management practices and awareness of habitats would minimize impacts to ecological 

31 resources. FENOC concludes that impacts to migratory species would depend on the location 

32 of wind installations and could be SMALL to MODERATE.

33 Most of the land on which wind farms would be located is already in agricultural use. As a 

34 result, terrestrial impacts would be SMALL, though impacts to birds and bats could increase in 

35 some locations. Generally, however, impacts would not destabilize any resources. The impacts 

36 to ecological resources from an interconnected array of wind installations would, therefore, 

37 range from SMALL to MODERATE.

38 Combining wind farms paired with CAES would likely affect fewer sites or have a smaller impact 

39 on the same number of sites. The types of impact from the wind portion, however, would 

40 remain the same. FENOC indicates that the impacts from the Norton Energy Storage project 

41 would be SMALL, given that it would only affect 92 ac (37 ha) of land surface and that water 

42 consumption and discharges would be regulated by NPDES limitations and provisions under 

43 Sections 316(a) and (b) of the Clean Water Act. Water consumption, water discharges, and air 

44 emissions are unlikely to noticeably affect important attributes of ecological resources except at 

45 the immediate Norton Energy Storage project site, which has already been degraded by 
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1 previous mining operations. The overall impact of wind plus CAES is thus SMALL to 

2 MODERATE and dependent largely on the locations and characteristics of the wind 

3 installations.

4 Human Health. FENOC indicated that the only major human health risk from construction and 

5 operation of an interconnected array of wind installations is accidents. FENOC indicated that 

6 compliance with applicable occupational safety and health regulations (those implemented by 

7 OSHA) would ensure that impacts will be SMALL. The NRC staff agrees that impacts from 

8 construction and operation of an array of wind installations would be SMALL.

9 Construction of the Norton Energy Storage project would likely reduce the number of wind 

10 turbines necessary, but it would not eliminate the potential for accidents. In addition, it would 

11 add the same types of risks to human health as the NRC power plant alternative. Human health 

12 risks for the NGCC alternative would be SMALL. The Norton Energy Storage project poses 

13 some unique challenges, such as construction activities within a cavern, but the potential for 

14 health effects from its markedly lower emissions is much smaller. As a result, the overall impact 

15 level for the array of interconnected wind farms with CAES would be SMALL as well.

16 Socioeconomics. Constructing an interconnected array of wind installations would create 

17 temporary construction jobs, economic activity, and increased demand for short-term rental 

18 housing and public services in communities nearest to the construction sites. FENOC further 

19 indicates that the impacts would be spread throughout the region and that losses of jobs, tax 

20 revenues, and economic activity from Davis-Besse would have a significant impact on 

21 communities near Davis-Besse. FENOC also indicates that renewable resources are taxed at a 

22 lower rate than “conventional” energy generating facilities. The NRC staff notes that an 

23 interconnected array of wind farms would affect many rural communities during installation. 

24 However, given the relatively small number of construction workers scattered over a large area 

25 at various construction sites, the relative socioeconomic impact of this many construction 

26 workers would be SMALL. CAES construction workers are most likely to commute from nearby 

27 Akron and Cleveland during the short duration of construction activities. Commuting workers 

28 and transportation of wind-turbine components would noticeably increase traffic volumes on 

29 local roads and could create SMALL to MODERATE transportation impacts. 

30 During operations, FENOC estimates that 50 to 100 CAES workers would be employed at the 

31 Norton Energy Storage project site. Fewer wind turbines would be installed under this wind 

32 combined with CAES alternative than the interconnected wind installation alternative. Since 

33 less land may be required for wind turbines due to energy storage, property tax payments to 

34 local communities would be smaller. 

35 Wind turbines would have the greatest potential visual impact; wind turbines often dominate the 

36 view and become the major focus of attention. On flat terrain, wind turbines would be visible 

37 from miles away and would be the tallest man-made structures in rural settings. Placing 

38 turbines along ridgelines would maximize their visibility. Because wind farms are generally 

39 located in rural or remote areas, the introduction of wind turbines would be in sharp contrast to 

40 the visual appearance of the surrounding environment. Assuming the interconnected array of 

41 wind installations consisted of 2-MW turbines, 2,150 turbines would be required. These turbines 

42 would be spread widely over the region and would affect many viewsheds. Overall, the 

43 aesthetic impacts would range from MODERATE to LARGE.

44 Combining the Norton Energy Storage project with a somewhat smaller array of interconnected 

45 wind turbines would not reduce the overall aesthetic impact. The Norton project would be 

46 similar in appearance to the NGCC power plant alternative, but smaller. It does not have heat 
Environmental Impacts of Alternatives

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1 recovery steam generators and uses smaller cooling towers than the NGCC power plant. 

2 Overall, the aesthetic impacts would likely remain MODERATE to LARGE.

3 A widely scattered array of wind installations has the potential to affect historical and 

4 archaeological resources as well. Each turbine will require construction of a base structure that 

5 may extend up to 40 ft (12 m) below ground, depending on soils and topography (BLM 2005), 

6 and each would be 15 to 20 ft (5 to 6 m) wide depending on the turbine model. Construction 

7 crews may encounter some archaeological resources, even in areas that have been extensively 

8 farmed. FENOC indicates that impacts could be LARGE, but construction activity was likely to 

9 take place under OPSB or other comparable program rules; thus, actions would be taken to 

10 avoid, recover, or otherwise mitigate resource loss or disturbance during construction. Turbines 

11 would be widely spaced but could affect thousands of acres of land spread across the state. 

12 Given the potential for discovery, impacts to historical and archaeological resources from the 

13 wind and CAES alternative could range from SMALL to MODERATE. . 

14 Combining wind farms with the Norton Energy Storage CAES project would reduce the number 

15 of wind turbines and ground disturbance, thus reducing the overall impact to historic and 

16 archeological resources from wind turbines installation. The only potential new effects would 

17 come from the Norton project site, which was previously used for limestone mining. Mining and 

18 industrial use of the 92-ac (37-ha) site has removed or otherwise affected the historic and 

19 archaeological resources at the former mine site. As a result, the Norton Energy Storage 

20 project is unlikely to contribute any additional impacts to existing historical and archaeological 

21 resources. Given the potential for discovery, impacts to historical and archaeological resources 

22 from the wind and CAES alternative could range from SMALL to MODERATE.

23 Overall, the interconnected array of wind installations would be noticeable and could affect 

24 important socioeconomic attributes. Therefore, overall socioeconomic impacts could range from 

25 MODERATE to LARGE. In addition, overall socioeconomic effects of the Norton Energy CAES 

26 project, in conjunction with a somewhat smaller interconnected array of wind farm installations, 

27 would be similar to the impacts from the standalone interconnected array of wind farm 

28 installations. Socioeconomic impacts under this alternative could also range from MODERATE 

29 to LARGE.

30 Waste Management. FENOC indicated that construction of an interconnected array of wind 

31 farm installations could generate large amounts of vegetation debris from land-clearing 

32 activities, and appropriate waste disposal activities would minimize these impacts. Most of the 

33 land used for wind farm installations is likely to be in agricultural use and fairly clear of 

34 vegetation, and wind turbines generate no waste during operations. As such, impacts from 

35 waste management would be SMALL.

36 FENOC indicated that operation of the Norton Energy Storage project would generate a small 

37 volume of waste during operations, like other gas-fired facilities, and that impacts would be 

38 SMALL. The primary types of waste generated by gas-fired power plants are SCR catalysts 

39 and other operational wastes. Overall, a combination of the Norton Energy Storage project with 

40 an interconnected array of wind installations would have SMALL waste management impacts.

41 Environmental Justice. Minority and low-income populations could be disproportionately 

42 affected by the visual impact and noise from the wind turbines. However, the turbines could be 

43 positioned away from these communities, thus reducing or avoiding disproportionately affecting 

44 minority and low-income populations. 
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1 Noise from CAES storage operations could have a localized impact on minority and low-income 

2 populations living near the Norton Energy Storage project site. Impacts from both components 

3 of this alternative could disproportionately affect minority or low-income populations.

4 8.4.3 Solar Power

5 Solar technologies, including PV and solar thermal (also known as concentrated solar power

6 (CSP)), use the sun’s energy to produce electricity at a utility scale. In PV systems, the energy 

7 contained in photons of sunlight incident on special PV materials results in the production of 

8 direct current (DC) electricity that is aggregated, converted to alternating current (AC), and 

9 connected to the high-voltage transmission grid. CSP technologies produce electricity by 

10 capturing the sun’s heat energy. Two types of CSP technology that have enjoyed the greatest 

11 utility-scale applications are the parabolic trough and the power tower; both involve capturing 

12 the sun’s heat and converting it to steam, which powers a conventional Rankine cycle steam 

13 turbine generator. Although some aspects of solar generation result in few environmental 

14 impacts, solar technology requires substantial land areas, and CSP technologies require 

15 roughly the same amount of water for cooling of the steam cycle as most other thermoelectric 

16 technologies.

17 The potential for solar technologies to serve as reliable baseload power alternative to 

18 Davis-Besse depends on the value, constancy, and accessibility of the solar resource. Both PV 

19 and CSP are enjoying growth worldwide, especially for various off-grid applications or to 

20 augment grid-provided power at the point of consumption; however, discrete baseload 

21 applications still have technological limitations. Although thermal storage can markedly 

22 increase the value of CSP-derived power for baseload applications by providing energy storage 

23 capabilities, low energy conversion efficiencies and the inherent weather-dependent 

24 intermittency of solar power limit its application as baseload power in all but those geographic 

25 locations with the highest and most constant solar energy values.

26 Ohio’s RPS requires utilities to obtain 12.5 percent of their electricity through renewables by 

27 2054. At least 0.5 percent of the renewable requirement must be met through solar energy 

28 resources (DSIRE 2013). EIA reports the total solar generating capacity (solar thermal and 

29 solar PV) in the U.S. in 2009 was 619 MW, 0.005 percent of the total nationwide generating 

30 capacity of 1,025,400 MW. Solar power produced 891,000 MWh of power in 2009, 0.02 percent

31 of the nationwide production of 3,950,331 thousand MWh (EIA 2011a). In Ohio in 2010, all 

32 renewables (excluding hydroelectric) were responsible for 1,129,000 MWh, or 0.79 percent of 

33 the State’s total generation of 143,598,000 MWh (EIA 2012a).

34 The DOE’s NREL reports that the State of Ohio has average solar insolation useful for PV 

applications on the order of 4.0 kWh/m2 35 /day and direct normal irradiance (DNI) suitable for use 

in CSP applications averaging 3.5 kWh/m2 36 /day (NREL 2010b). Both of these solar insolation 

37 values are below the ideal for efficient and cost-effective application of PV and CSP 

technologies. For utility-scale development, insolation levels below 6.5 kWh/m2 38 /day are 

39 considered “not economically viable” given current technologies (BLM/DOE 2010).

40 PV installations have no ability to provide power at night, and they provide reduced levels of 

41 power on overcast days, during fog events, and when snow accumulates. While their 

42 generation during summer months is high when electricity consumption is high, their capacity to 

43 generate electricity in winter declines before the evening electricity demand peaks.

44 To date, PV installations have been the dominant technology installed in Ohio, and they are also 

45 the largest installations in the State are PV installations (the 10 MW Wyandot facility and the 
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1 under-construction 49.9 MW Turning Point project, to be completed in 2015). As a result, the 

2 solar capacity considered as part of a combination alternative is from PV installations. Because 

3 PV does not produce electricity at night and produces diminished amounts of power during 

4 particular weather conditions, PV is not considered a viable, standalone alternative to license 

5 renewal. Further, because no CSP installations exist in Ohio, and because CSP has lower 

6 insulation values than PV, the NRC staff does not consider CSP to be a viable alternative to 

7 Davis-Besse license renewal.

8 As discussed in the wind power section, CAES could conceivably offset the variable power 

9 output of solar PV facilities and allow them to store some energy to be released when the sun is 

10 not shining or when output is low due to weather conditions. Because Ohio has very limited 

11 potential for new hydro development, the NRC staff will not consider pumped storage as a 

12 means of offset solar PV variability.

13 As noted in the combination alternative section, First Energy recently purchased the Norton 

14 Energy Storage project and could conceivably have 536 MW of capacity available by 2017 

15 However, the Norton Energy Storage project is too small to provide for production of sufficient 

16 power to replace Davis-Besse while the sun is not shining, so the NRC staff does not consider 

17 solar plus the Norton Energy Storage project to be a reasonable alternative. 

18 FENOC (2011) evaluated the potential environmental impacts of a combined solar and CAES 

19 alternative, and the NRC staff provides a brief discussion of its results here.

20 Environmental Impacts of Solar PV with the Norton Project

21 Land Use. FENOC indicated that a solar facility with sufficient capacity to replace Davis-Besse 

22 and provide electricity to a CAES facility (a total of 1,820 MW of solar capacity) would require 

23 approximately 37,900 ac (15,300 ha). The Norton Energy Storage project would require an 

24 additional 92 ac (37 ha) of a former mining site. This alternative would require more land than 

25 any other alternative. The land use impacts of this alternative would range from MODERATE to 

26 LARGE.

27 Water Use and Quality—Surface Water. FENOC indicated that a solar PV facility requires no 

28 water for cooling or operations. FENOC further notes that the only effects on surface water 

29 would occur during construction, when sedimentation or runoff could affect surface water, but 

30 best management practices would minimize this impact. The solar facility would have to comply 

31 with storm water discharge limits, and the from the Norton Energy Storage project would be 

32 SMALL. The NRC staff, therefore, finds that surface water impacts would be SMALL.

33 Water Use and Quality—Groundwater. FENOC assumed that neither solar PV installations nor 

34 the Norton Energy Storage project would use groundwater for any purpose. The NRC staff 

35 finds this to be a reasonable assumption. If the project does not use any groundwater, then the 

36 impacts to groundwater would be SMALL.

37 Air Quality. FENOC indicated that solar PV installations would have no effect on air quality. 

38 However, PV construction, installation, and maintenance (serving equipment or repairs) would 

39 cause some temporary air pollutant emissions.

40 The Norton Energy Storage project would have the following emissions, assuming that the 

41 maximum 536 MW would be installed by 2017:

42 • sulfur dioxide—28 tons (26 MT), 
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1 • nitrogen oxide—62 tons (57 MT), 

2 • particulate matter less than or equal to 10 μm—31 tons (28 MT), 

3 • VOCs—18 tons (16 MT), and

4 • carbon dioxide—450,000 tons (410,000 MT). 

5 FENOC indicated that both sulfur dioxide and nitrogen oxide emissions would be subject to cap 

6 and trade programs; thus, they would not add to regional emissions of either pollutant (in all 

7 seasons for sulfur dioxide, and ozone season for nitrogen oxides) or permit-based emissions 

8 controls for all listed pollutants. FENOC indicated that air quality impacts would be 

9 MODERATE. However, the NRC staff found these air emissions to be SMALL. The impacts 

10 would be substantially lower than those of the NGCC alternative considered in Section 8.1. As 

11 a result, the impacts of the Norton Energy Storage facility portion of this combination alternative 

12 on air quality would be SMALL.

13 Ecological Impacts. FENOC indicated that development of solar PV installations could have 

14 major impacts on land resources as well as significant impacts on terrestrial ecological 

15 resources.

16 Most land would already be in agricultural use, given the predominant land use patterns in Ohio. 

17 As a result, terrestrial impacts are likely to affect those ecological resources that exist on 

18 agricultural lands. These impacts are likely to be noticeable; however, they are unlikely to be 

19 destabilizing, so impacts are MODERATE. Effects from the Norton Energy Storage project 

20 would be SMALL. Overall impacts to terrestrial ecological resources would be MODERATE.

21 As the solar PV portion of this alternative does not rely on any water during operation, and as 

22 permitting and practices during construction will limit impacts to surface water, the solar PV 

23 portion is unlikely to noticeably affect aquatic ecological resources. The Norton Energy Storage 

24 project is also unlikely to noticeably affect aquatic ecological resources. As a result, impacts to 

25 aquatic ecological resources will be SMALL.

26 Human Health. FENOC indicated that human health impacts from construction and operation of 

27 both solar PV and CAES would be regulated by OSHA and would, therefore, be SMALL. 

28 Impacts on human health from the CAES facility’s air emissions would also not be noticeable. 

29 As a result, the NRC staff finds that human health impacts from this alternative would be 

30 SMALL.

31 Socioeconomics. Constructing solar PV installations would create temporary construction jobs, 

32 economic activity, and increased demand for short-term rental housing and public services in 

33 communities nearest to the construction sites. FENOC further indicates that the impacts would 

34 be spread throughout the region and that losses of jobs, tax revenues, and economic activity 

35 from Davis-Besse would have a significant impact on communities near Davis-Besse. FENOC 

36 also indicates that renewable resources are taxed at a lower rate than “conventional” energy 

37 generating facilities. Solar PV facilities would affect many rural communities during installation. 

38 However, given the relatively small number of construction workers scattered over a large area, 

39 the relative socioeconomic impact of this many construction workers would be SMALL. CAES 

40 construction workers are most likely to commute from nearby Akron and Cleveland given the 

41 short duration of construction activities. Commuting workers and transportation of solar PV 

42 components could noticeably increase traffic volumes on local roads and could create SMALL to 

43 MODERATE transportation impacts
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1 During operations, FENOC estimates that 150 to 200 workers would be employed at both the 

2 solar PV installations and the Norton Energy Storage project. FENOC indicated that the Norton 

3 project would generate additional revenues for the communities near the project. 

4 Socioeconomic impacts would be SMALL to MODERATE.

5 FENOC indicates that solar PV facilities would be located in remote areas, would likely not 

6 generate large aesthetic concerns, and would likely meet minor resistance. The footprint of a 

7 utility scale, standalone solar PV installation would be quite large (approximately 37,900 ac 

8 (15,300 ha)) and would create a noticeable visual impact. Spread across a large site, the utility 

9 scale, standalone solar PV installation would dominate the view and would likely become the 

10 major focus of attention. The introduction of a utility scale, standalone solar PV installation 

11 would be in sharp contrast to the visual appearance of the surrounding environment. Installing 

12 solar PV technologies on building rooftops, although noticeable to a lesser degree in urban 

13 settings, would reduce the amount of land required for standalone solar sites. Any noise at a 

14 utility scale, standalone solar PV installation would be limited to industrial processes and 

15 communications. Based on this information, aesthetic impacts from the construction and 

16 operation of a solar PV alternative could range from MODERATE to LARGE depending on the 

17 type of solar technology installed and its location and surroundings. 

18 FENOC indicated that the large amount of land needed for this alternative could have a large 

19 impact on cultural resources, but OPSB or other comparable program rules could reduce or 

20 minimize these impacts. Solar PV installations will require smaller and shallower excavations 

21 than wind turbines; so, they are less likely to disturb historical and archaeological resources 

22 beyond those already disturbed by farming or other activities.

23 Mining and industrial use of the 92-ac (37-ha) Norton Energy Storage project site has removed 

24 or otherwise affected the historic and archaeological resources at the former mine site. As a 

25 result, the Norton Energy Storage project is unlikely to contribute to impacts to existing historical 

26 and archaeological resources. Given the potential for discovery, impacts to historical and 

27 archaeological resources could range from SMALL to MODERATE. 

28 Overall, solar PV installations paired with the Norton Energy Storage project would be 

29 noticeable and could affect socioeconomic attributes. Therefore, overall socioeconomic impacts 

30 could range from SMALL to MODERATE.

31 Waste Management. FENOC indicated that hazardous materials, such as cadmium and lead, 

32 are used in the manufacture of solar PV panels; thus, solar PV could create environmental 

33 impacts during manufacture and disposal. Solar PV technology manufacturers would employ 

34 best practices to minimize release and disposal of hazardous wastes and recycle any 

35 commercially valuable quantities of waste items. Some debris may be generated during 

36 installation. FENOC indicated that CAES would generate minimal amounts of wastes, similar to 

37 the NGCC alternative. Overall, waste management impacts would be SMALL.

38 Environmental Justice. Predominately minority and low-income communities could be 

39 disproportionately affected by the visual impact from the vast size of the solar PV installations if 

40 located near the installation. However, because of the large amount of land necessary for solar 

41 PV installations, solar PV installations could be positioned away from communities, thus 

42 reducing or avoiding disproportionately affecting minority and low-income populations.

43 Solar PV installations and CAES storage operations are unlikely to have any high and adverse 

44 effects on minority and low-income populations. given their lack of emissions, lack of water 

45 consumption or discharge, and minimal aesthetic impacts. However, noise from the existing 
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1 CAES storage operations component of this alternative would continue to have a localized 

2 impact on people living near the Norton Energy Storage project site. Impacts from both 

3 components of this alternative could disproportionately affect nearby minority or low-income 

4 populations but the overall effects would not be high and adverse. 

5 8.4.4 Wood Waste

6 As noted in the GEIS (NRC 1996), the use of wood waste to generate utility-scale baseload 

7 power is limited to those locations where wood waste is plentiful. Wastes from pulp, paper, and 

8 paperboard industries and from forest management activities can be expected to provide 

9 sufficient, reliable supplies of wood waste as feedstocks to external combustion sources for 

10 energy generation. Beside the fuel source, the technological aspects of a wood-fired generation 

11 facility are virtually identical to those of a coal-fired alternative—combustion in an external 

12 combustion unit such as a boiler to produce steam to drive a conventional STG. Given 

13 constancy of the fuel source, wood waste facilities can be expected to operate at equivalent 

14 efficiencies and reliabilities. Costs of operation would depend significantly on processing and 

15 delivery costs. Wood waste combustors would be sources of criteria pollutants and GHGs, and 

16 pollution control requirements would be similar to those for coal plants. Unlike coal plants, there 

17 is no potential for the release of HAPs such as mercury. Co-firing of wood waste with coal is 

18 also technically feasible. Processing the wood waste into pellets can improve the overall 

19 efficiency of such co-fired units. Although co-fired units can have capacity factors similar to 

20 baseload coal-fired units, such levels of performance are dependent on the continuous 

21 availability of the wood waste fuel. In the State of Ohio, 2008 electricity generating capacity 

22 from wood waste was 65 MW and produced 418,000 MWh (EIA 2011c). Given the limited 

23 capacity and modest actual electricity production, the NRC staff has determined that production 

24 of electricity from wood waste at levels equivalent to Davis-Besse would not be a feasible 

25 alternative to Davis-Besse license renewal.

26 8.4.5 Conventional Hydroelectric Power

27 Three technology variants of hydroelectric power exist—dam and release (also known as 

28 impoundment), run-of-the-river (also known as diversion), and pumped storage. In each variant, 

29 flowing water spins turbines of different designs to drive a generator to produce electricity. Dam 

30 and release facilities affect large amounts of land behind the dam to create reservoirs but can 

31 provide substantial amounts of power at capacity factors greater than 90 percent. Power 

32 generating capacities of run-of-the-river dams fluctuate with the flow of water in the river, and 

33 the operation of such dams is typically constrained (and stopped entirely during certain periods) 

34 so as not to create undue stress on the aquatic ecosystems present. Pumped storage facilities 

35 use grid power to pump water from lower impoundments or flowing watercourses to higher

36 elevations during off-peak load periods. Water is then released during peak load periods 

37 through turbines to generate electricity. Capacities of pumped storage facilities are dependent 

38 on the configuration and capacity of the elevated storage facility.

39 A comprehensive survey of hydropower resources in Ohio was completed in 1997 by DOE’s 

40 Idaho National Environmental Engineering Laboratory (now known as the Idaho National 

41 Laboratory). In the study, generating potential was defined by a model that considered the 

42 existing hydroelectric technology at developed sites or applied the most appropriate technology 

43 to undeveloped sites and introduced site-specific environmental considerations and limitations. 

44 Ohio had little hydroelectric potential, with a total generating potential of 183 MW (INEEL 1998). 

45 More recently, EIA reported that, in 2008, conventional hydroelectric power (excluding pumped 

46 storage) was the principal electricity generation source among renewable sources in Ohio 
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1 (EIA 2011c). Nevertheless, only 527 gigawatt-hours (GWh) of hydroelectric power was 

2 generated in 2009, 0.19 percent of the nationwide total of 273,445 GWh (EIA 2011a). Although 

3 hydroelectric facilities can demonstrate relatively high capacity factors, the small potential 

4 capacities and actual recent power generation of hydroelectric facilities in Ohio, combined with 

5 the diminishing public support for large hydroelectric facilities because of their potential for 

6 adverse environmental impacts, supports NRC’s conclusion that hydroelectric is not a feasible 

7 alternative to Davis-Besse.

8 8.4.6 Ocean Wave and Current Energy

9 Ocean waves, currents, and tides represent kinetic and potential energies. The total annual 

10 average wave energy off the U.S. coastlines at a water depth of 60 m (197 ft) is estimated at 

11 2,100 terawatt-hours (TWh) (MMS 2006). Waves, currents, and tides are often predictable and 

12 reliable; ocean currents flow consistently, while tides can be predicted months and years in 

13 advance with well-known behavior in most coastal areas. Four principal wave energy 

14 conversion (WEC) technologies have been developed to date to capture the potential or kinetic 

15 energy of waves—point absorbers, attenuators, overtopping devices, and terminators. All have 

16 similar approaches to electricity generation but differ in size, anchoring method, spacing, 

17 interconnection, array patterns, and water depth limitations. Point absorbers and attenuators 

18 both allow waves to interact with a floating buoy, subsequently converting its motion into 

19 mechanical energy to drive a generator. Overtopping devices and terminators are also similar 

20 in their function. Overtopping devices trap some portion of the incident wave at a higher 

21 elevation than the average height of the surrounding sea surface, thus giving it higher potential 

22 energy, which is then transferred to power generators. Terminators allow waves to enter a tube, 

23 compressing air trapped at the top of the tube, which is then used to drive a generator.

24 Capacities of point absorbers range from 80 to 250 kW, with capacity factors as high as 

25 40 percent; attenuator facilities have capacities of as high as 750 kW. Overtopping devices 

26 have design capacities as high as 4 MW, while terminators have design capacities ranging from 

27 500 kW to 2 MW and capacity factors as high as 50 percent (MMS 2007).

28 The most advanced technology for capturing tidal and ocean current energy is the submerged 

29 turbine. Underwater turbines share many design features and functions with wind turbines, but 

30 because of the greater density of water compared to air, they have substantially greater 

31 power-generating potential than wind turbines with comparably sized blades. Only a small 

32 number of prototypes and demonstration units have been deployed to date, however. 

33 Underwater turbine “farms” are projected to have capacities of 2 to 3 MW, with capacity factors 

34 directly related to the constancy of the current with which they interact.

35 The Great Lakes do not experience large tides, and the limited energy output for wave 

36 technologies in the Great Lakes would outweigh the high cost. Consequently, the relatively 

37 modest power capacities, relatively high costs, and limited resource availability in Lake Erie 

38 support the NRC staff’s conclusion that water energy current technologies are not feasible 

39 substitutes for Davis-Besse.

40 8.4.7 Geothermal Power

41 Geothermal technologies extract the heat contained in geologic formations to produce steam to 

42 drive a conventional steam-turbine generator. The following variants of the heat exchanging 

43 mechanism have been developed: 
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1 • Hot geothermal fluids contained under pressure in a geological formation are brought to 

2 the surface where the release of pressure allows them to flash into steam (the most 

3 common of geothermal technologies applied to electricity production).

4 • Hot geothermal fluids are brought to the surface in a closed loop system and directed to 

5 a heat exchanger where they convert water in a secondary loop into steam.

6 • Hot dry rock technologies involve fracturing a rock formation and extracting heat through 

7 injection of a heat transfer fluid.

8 Facilities producing electricity from geothermal energy can routinely demonstrate capacity 

9 factors of 95 percent or greater, making geothermal energy clearly eligible as a source of 

10 baseload electric power. However, as with other renewable energy technologies, the ultimate 

11 feasibility of geothermal energy serving as a baseload power replacement for Davis-Besse is 

12 dependent on the quality and accessibility of geothermal resources within or proximate to the 

13 region of interest—in this case, FirstEnergy’s Ohio service territory. As of April 2010, the U.S.

14 had a total installed geothermal electricity production capacity of 3,087 MW originating from 

15 geothermal facilities in nine states—Alaska, California, Hawaii, Idaho, Nevada, New Mexico, 

16 Utah, and Wyoming. Additional geothermal facilities are being considered for Colorado, Florida, 

17 Louisiana, Mississippi, and Oregon. Ohio does not have adequate geothermal resources to 

18 support utility-scale electricity production (GEA 2010). NRC concludes, therefore, that 

19 geothermal energy does not represent a feasible alternative to Davis-Besse.

20 8.4.8 Municipal Solid Waste

21 Municipal solid waste (MSW) combustors use three types of technologies—mass burn, modular, 

22 and refuse-derived fuel. Mass burning is currently the method used most frequently in the U.S.

23 and involves no (or little) sorting, shredding, or separation. Consequently, toxic or hazardous 

24 components present in the waste stream are combusted, and toxic constituents are exhausted 

25 to the air or become part of the resulting solid wastes. Currently, approximately 

26 86 waste-to-energy plants operate in 24 states, processing 97,000 tons (88,000 MT) of 

27 municipal solid waste per day. Latest estimates are that 26 million tons (24 million MT) of trash 

28 were processed in 2008 by waste-to-energy facilities. With a reliable supply of waste fuel, 

29 waste-to-energy plants have an aggregate capacity of 2,572 MW and can operate at capacity 

30 factors greater than 90 percent (ERC 2010). Currently, there are no waste-to-energy facilities 

31 operating in Ohio.

32 The EPA estimates that, on average, air impacts from MSW-to-energy plants are as follows: 

33 • 3,685 lb (1,672 kg)/MWh of carbon dioxide,

34 • 1.2 lb (0.54 kg)/MWh of sulfur dioxide, and 

35 • 6.7 lb (3.0 kg)/MWh of nitrogen oxide.

36 Depending on the composition of the municipal waste stream, air emissions can vary greatly, 

37 and the ash produced may exhibit hazardous characteristics that require special treatment and 

38 handling (EPA 2010d).

39 Estimates in the GEIS suggest that the overall level of construction impact from a waste-fired 

40 plant would be approximately the same as that for a coal-fired power plant. Additionally, 

41 waste-fired plants have the same or greater operational impacts as coal-fired technologies 

42 (including impacts on the aquatic environment, air, and waste disposal). The initial capital costs 

43 for municipal solid-waste plants are greater than those for comparable steam-turbine technology 
Environmental Impacts of Alternatives

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1 at coal-fired facilities or at wood-waste facilities because of the need for specialized waste 

2 separation and handling equipment (NRC 1996).

3 The decision to burn municipal waste to generate energy is usually driven by the need for an 

4 alternative to landfills, rather than energy considerations. The use of landfills as a waste 

5 disposal option is likely to increase in the near term as energy prices increase (and especially 

6 since such landfills, of sufficient size and maturity, can be sources of easily recoverable 

7 methane fuel); however, it is possible that municipal waste combustion facilities may become 

8 attractive again.

9 Regulatory structures that once supported municipal solid waste incineration no longer exist. 

10 For example, the Tax Reform Act of 1986 made capital-intensive projects, such as municipal 

11 waste combustion facilities, more expensive relative to less capital-intensive waste disposal 

12 alternatives such as landfills. Additionally, the 1994 Supreme Court decision C&A Carbone, Inc. 

13 v. Town of Clarkstown, New York, struck down local flow control ordinances that required waste 

14 to be delivered to specific municipal waste combustion facilities rather than landfills that may 

15 have had lower fees. In addition, environmental regulations have increased the capital cost 

16 necessary to construct and maintain municipal waste combustion facilities.

17 Given the small average installed size of municipal solid waste plants, the likelihood that 

18 additional stable streams of MSW are unlikely to be available to support numerous new 

19 facilities, the increasingly unfavorable regulatory environment, especially with respect to 

20 expanding pollution control regulations, and the fact that Ohio does not have any operating 

21 MSW plants, the NRC staff does not consider municipal solid waste combustion to be a 

22 reasonable alternative to Davis-Besse license renewal.

23 8.4.9 Biomass Fuels

24 When used here, “biomass fuels” includes crop residues, switchgrass grown specifically for 

25 electricity production, forest residues, methane from landfills, methane from animal manure 

26 management, primary wood mill residues, secondary wood mill residues, urban wood wastes, 

27 and methane from domestic wastewater treatment. The feasibility of using biomass fuels for 

28 baseload power depends on its geographic distribution, available quantities, constancy of 

29 supply, and energy content. A variety of technical approaches has been developed for 

30 biomass-fired electric generators, including direct burning, conversion to liquid biofuels, and 

31 biomass gasification. In a study completed in December 2005, Milbrandt of NREL documented 

32 the geographic distribution of biomass fuels within the U.S., reporting the results in metric tons 

33 available (dry basis) per year (NREL 2005). Limited amounts of potential biomass fuels are 

34 available in Ohio, with the highest potential located in the western half of the State. 

35 Power-generating capacity from biomass fuels is only 41 MW in Ohio and, in 2008, generated 

36 only 191,000 MWh (EIA 2011c).

37 In the GEIS, the NRC indicated that technologies relying on a variety of biomass fuels had not 

38 progressed to the point of being competitive on a large scale or of being reliable enough to 

39 replace a baseload plant such as Davis-Besse. After reevaluating current technologies, and 

40 after reviewing existing State-wide capacities and the extent to which biomass is currently being 

41 used to produce electricity in Ohio, the NRC staff finds biomass-fired alternatives are still unable 

42 to reliably replace the Davis-Besse capacity and are not considered feasible alternatives to 

43 Davis-Besse license renewal.
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1 8.4.10 Oil-Fired Power

2 Although oil has historically been used extensively in the Northeast for comfort heating, EIA 

3 projects that oil-fired plants will account for very little of the new generation capacity constructed 

4 in the U.S. during the 2008 to 2030 time period. In 2008, Ohio generated approximately 

5 1,311,743 MWh of electricity from oil-fired generation, just 1 percent of its total electricity profile. 

6 Further, EIA does not project that oil-fired power will account for any significant additions to 

7 capacity (EIA 2013).

8 The variable costs of oil-fired generation tend to be greater than those of nuclear or coal-fired 

9 operations, and oil-fired generation tends to have greater environmental impacts than natural 

10 gas-fired generation. In addition, future increases in oil prices are expected to make oil-fired 

11 generation increasingly more expensive (EIA 2013). The high cost of oil has prompted a steady 

12 decline in its use for electricity generation. Thus, the NRC staff does not consider oil-fired 

13 generation as a reasonable alternative to Davis-Besse license renewal.

14 8.4.11 Fuel Cells

15 Fuel cells oxidize fuels without combustion and its environmental side effects. Power is 

16 produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 

17 over a cathode and separating the two by an electrolyte. The only byproducts (depending on 

18 fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a variety of 

19 hydrocarbon resources by subjecting them to steam reforming under pressure. Natural gas is 

20 typically used as the source of hydrogen.

21 Currently, fuel cells are not economically or technologically competitive with other alternatives 

22 for electricity generation. EIA projects that fuel cells may cost $5,478 per installed kW (total 

23 overnight costs, 2008 dollars) (EIA 2010c). This amount is substantially greater than coal 

24 ($2,223), advanced (natural gas) combustion turbines ($648), onshore wind ($1,966), or 

25 offshore wind ($3,937), but it is cost-competitive with solar PV ($6,171) or CSP solar ($5,132). 

26 Installed costs provided for PV and CSP solar are before application of Investment Tax Credits 

27 provided in Federal statutes. More importantly, fuel cell units are likely to be small in size (the 

28 EIA reference plant is 10 MWe). While it may be possible to use a distributed array of fuel cells 

29 to provide an alternative to Davis-Besse, it would be extremely costly to do so and would require 

30 many units and wholesale modifications to the existing transmission system. Accordingly, the 

31 NRC staff does not consider fuel cell technology to be a reasonable alternative to Davis-Besse 

32 license renewal.

33 8.4.12 Coal-Fired Integrated Gasification Combined Cycle

34 Integrated gasification combined cycle (IGCC) is an emerging technology for generating 

35 electricity with coal that combines modern coal gasification technology with both gas turbine and 

36 steam turbine power generation. Gasifiers similar to those used in oil refineries use heat 

37 pressure and steam to pyrolyze (thermally reform complex organic molecules without oxidation) 

38 coal to produce synthesis gases (generically referred to as syngas) typically composed of 

39 carbon monoxide, hydrogen, and other flammable constituents. After processing to remove 

40 contaminants and produce various liquid chemicals, the syngas is combusted in a combustion 

41 turbine to produce electric power. Separating the CO2 from the syngas prior to combustion is 

42 also possible. Latent heat is recovered both from the syngas as it exits the gasifier and from the 

43 combustion gases exiting the combustion turbine and directed to a heat recovery steam 

44 generator feeding a conventional Rankine cycle STG to produce additional amounts of 

45 electricity. Emissions of criteria pollutants would likely be slightly higher than those from an 
Environmental Impacts of Alternatives

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1 NGCC alternative but significantly lower than those from the supercritical coal-fired alternative. 

2 Depending on the gasification technology employed, IGCC would use less water than SCPC 

3 units but slightly more than NGCC (NETL 2007). Long-term maintenance costs of this relatively 

4 complex technology would likely be greater than those for a similarly sized SCPC or NGCC 

plant. 5 

6 Only a few IGCC plants are operating at utility scale. Operating at higher thermal efficiencies 

7 than supercritical coal-fired boilers, IGCC plants can produce electrical power with fewer air 

8 pollutants and solid wastes than coal-fired boilers. To date, however, IGCC technologies have 

9 had limited application and have been plagued with operational problems such that its effective, 

10 long-term capacity factors are often not high enough for them to reliably serve as baseload 

11 units. Although IGCC technology is likely to become more commonplace in the future, current 

12 operational problems that compromise reliability result in the dismissal of this technology as a 

13 viable alternative to Davis-Besse.

14 8.4.13 Energy Conservation/Energy Efficiency

15 Though often used interchangeably, energy conservation and energy efficiency are different 

16 concepts. Energy efficiency typically means deriving a similar level of service by using less 

17 energy, while energy conservation simply indicates a reduction in energy consumption. Both fall 

18 into a larger category known as demand-side management (DSM). DSM measures—unlike the 

19 energy supply alternatives discussed in previous sections—address energy end uses. DSM 

20 can include measures that do the following:

21 • shift energy consumption to different times of the day to reduce peak loads; 

22 • interrupt certain large customers during periods of high demand; 

23 • interrupt certain appliances during high demand periods; 

24 • replace older, less efficient appliances, lighting, or control systems; and

25 • encourage customers to switch from gas to electricity for water heating and other similar 

26 measures that utilities use to boost sales. 

27 Unlike other alternatives to license renewal, the GEIS notes that conservation is not a discrete 

28 power-generating source; it represents an option that states and utilities may use to reduce their 

29 need for power generation capability (NRC 1996).

30 In a 2008 staff report, the FERC outlined the results of the 2008 FERC Demand Response and 

31 Advanced Metering Survey (FERC 2008). Nationwide, approximately 8 percent of retail 

32 electricity customers are enrolled in some type of demand response program. The potential 

33 demand response resource contribution from all U.S. demand response programs is estimated 

34 to be close to 41,000 MW, or about 5.8 percent of U.S. peak demand. A national assessment of 

35 demand response (DR) potential, required of FERC by Section 529 of the Energy Independence 

36 and Security Act of 2007, evaluated potential energy savings in 5- and 10-year horizons for four 

37 development scenarios—Business As Usual, Expanded Business As Usual, Achievable 

38 Participation, and Full Participation. Each of these scenarios represents successively greater 

39 demand response program opportunities and proportionally increasing levels of customer 

40 participation (FERC 2009). The greatest savings would be realized under the Full Participation 

41 scenario, with peak demand reductions of 188 GW by the year 2019, a 20 percent reduction of 

42 the anticipated peak load that would result without any DR programs in place. Under the 

43 Achievable Participation scenario, reflecting a more realizable voluntary participation level of 
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1 60 percent of eligible customers, peak demand would be reduced by 138 GW by 2019, a 

2 14 percent reduction. The Business-as-Usual scenario considers the amount of demand 

3 response that would take place if existing and currently planned demand response programs 

4 continued unchanged over the next 10 years. 

5 FERC’s State-specific analysis indicates that by the year 2019, the Full Participation scenario 

6 would yield a 6,753 MW peak demand reduction in Ohio (17.5 percent of the State’s projected 

7 peak demand). The Business as Usual scenario suggests that DR programs would yield a 

8 reduction of 483 MW (1.2 percent of the State’s projected peak demand) (FERC 2009).

9 In July 2008, the Ohio legislature passed SB 221, which established an energy-efficiency 

10 resource standard that requires electric utilities to implement an energy-efficiency and peak 

11 demand reduction program that will yield a cumulative electricity savings of 22 percent by the 

12 end of 2025, with specific annual benchmarks. The bill also requires utilities to implement 

13 programs to reduce peak energy demand by 1 percent in 2009, and an additional 0.75 percent

14 each year through 2018 (DSIRE 2013). In its ER, FENOC discussed that DSM load reductions 

15 are already considered in load forecasts; therefore, the reductions do not offset the projected 

16 power demands that Davis-Besse is expected to supply (FENOC 2010). Because the energy 

17 efficiency resource standard would require utilities to achieve savings of anywhere between 

18 0.3 and 2 percent each year, and Davis-Besse contributes 5 percent of Ohio’s total electrical 

19 generation annually, it is unlikely that the energy savings would completely replace the power 

20 generated by Davis-Besse by 2017, which is when the Davis-Besse operating license would 

21 have expired if FENOC had not applied for license renewal. Thus, the NRC staff concludes that 

22 passive DR programs are not a feasible baseload power alternative to Davis-Besse.

23 8.4.14 Purchased Power

24 Under the Purchased Power alternative, no new generating capacity would necessarily be built 

25 and operated by FirstEnergy; instead, the company would purchase electricity from other 

26 generators, in amounts equivalent to what Davis-Besse currently supplies. Those generators 

27 could be located anywhere within or outside the FirstEnergy service territory, although 

28 far-distant sources may not be immediately available to serve nearby load centers without 

29 substantial transmission system build-outs or without significant line loss when power delivered 

30 to Davis-Besse load centers originates at distant generation sources.

31 In theory, purchased power is a feasible alternative; however, because there are no assurances 

32 that sufficient capacity would exist during the entire license renewal timeframe to replace 

33 Davis-Besse, FENOC has determined that purchased power would not be a reasonable 

34 alternative (FENOC 2010). Davis-Besse is located in the region administered by the Midwest 

35 Independent System Operator (MISO), and ReliabilityFirst Corporation (RFC) enforces reliability 

36 standards in the areas in which Davis-Besse operates. The North American Electric Reliability 

37 Corporation’s (NERC’s) 2008 Regional Reliability Assessment estimates that the total internal 

38 demand of MISO will increase by 14,500 MW from 2008 through 2017, while the increase in 

39 planned generation additions through 2017 is only 4,400 MW. The reserve margins are 

40 expected to be 14.1 percent through 2014; however, additional generating capacity would be 

41 needed in the region in order to maintain sufficient capacity reserves beyond 2017 

42 (NERC 2008). If Davis-Besse were not to operate beyond its current license period, existing 

43 resources may not be sufficient to support a purchased power alternative beyond 2017. NRC, 

44 therefore, concludes that a purchased power option is not a viable discrete alternative to 

45 extending the Davis-Besse reactor license.
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1 8.5 No-Action Alternative

2 This section examines the environmental effects that occur if NRC takes no action. No action, 

3 in this case, means that NRC denies the renewed the operating license for Davis-Besse and the 

4 license, NPF-3, expires at the end of the current license term, on April 22, 2017. If NRC denies 

5 the renewed operating license, the plant will shut down at or before the end of the current 

6 license. After shutdown, plant operators will initiate decommissioning in accordance with 

7 10 CFR 50.82.

8 No action is the only alternative that we consider in depth that does not satisfy the purpose and 

9 need for this SEIS, as it neither provides power-generation capacity nor meets the needs 

10 currently met by Davis-Besse or that the alternatives evaluated in Sections 8.1 through 8.3 

11 would satisfy. Assuming that a need currently exists for the power generated by Davis-Besse, 

12 the no-action alternative would require the appropriate energy-planning decisionmakers (not 

13 NRC) to rely on an alternative to replace the capacity of Davis-Besse or rely on energy 

14 conservation or power purchases to offset parts of the Davis-Besse capacity.

15 This section addresses only those impacts that arise directly as a result of plant shutdown. The 

16 environmental impacts from decommissioning and related activities have already been 

17 addressed in several other documents, including the Final Generic Environmental Impact 

18 Statement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 (NRC 2002); 

19 the license renewal GEIS, Chapter 7 (NRC 1996); and Chapter 7 of this SEIS. These analyses 

20 either directly address or bound the environmental impacts of decommissioning whenever 

21 FENOC ceases to operate Davis-Besse.

22 Even with a renewed operating license, Davis-Besse will eventually shut down, and the 

23 environmental effects we address in this section will occur at that time. Because these effects 

24 have not otherwise been addressed in this SEIS, the impacts are addressed in this section. As 

25 with decommissioning effects, shutdown effects are expected to be similar whether they occur 

26 at the end of the current license or at the end of a renewed license. Table 8.5-1 provides a 

27 summary of the environmental impacts of the no-action alternative.

28 Table 8.5-1. Environmental Impacts of No-Action Alternative

No-Action Alternative Continued Operation of the 

Davis-Besse Reactor

Air quality SMALL SMALL

Groundwater SMALL SMALL

Surface water SMALL SMALL

Aquatic resources SMALL SMALL

Terrestrial resources SMALL SMALL

Human health SMALL SMALL

Land use SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL SMALL

Aesthetics SMALL SMALL
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No-Action Alternative Continued Operation of the 

Davis-Besse Reactor

Historical & archeological resources SMALL SMALL to MODERATE

Waste Management SMALL SMALL

1 8.5.1 Air Quality

2 When the plant stops operating, there will be a reduction in emissions from activities related to 

3 plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the 

4 NRC staff determined that these emissions would have a SMALL impact on air quality during 

5 the renewal term; therefore, if emissions decrease, the impacts to air quality from the no-action 

6 alternative will be SMALL.

7 8.5.2 Groundwater Use and Quality

8 Chapter 4 of this SEIS discusses the impact on groundwater that is currently occurring as a 

9 result of operation of Davis-Besse. No groundwater is used to support operation of the plant. 

10 Tritium contamination has been detected in groundwater monitoring wells, though no 

11 concentrations have been detected at or above the EPA drinking water limit of 

12 20,000 picocuries per liter (pCi/L) (FENOC 2010). Once the reactor ceases operating, the 

13 potential for additional releases of tritium to the groundwater is expected to diminish. However, 

14 releases of tritium may not totally cease until decommissioning is completed. NRC concludes 

15 that impacts on groundwater from the no-action alternative would be SMALL.

16 8.5.3 Surface Water Use and Quality

17 Chapter 4 of this SEIS discusses the impacts on surface water from plant operation. 

18 Operational impacts include water withdrawals from Lake Erie in association with operation of 

19 the closed-cycle cooling system. Impacts also include stormwater runoff from industrial areas of 

20 the plant, controlled through provisions of a stormwater general permit. Once reactor operation 

21 stops, impacts associated with water withdrawals would cease; however, stormwater discharges 

22 from industrialized portions of the site would continue largely unchanged until decommissioning 

23 activities commence. The current stormwater general permit would continue in effect after 

24 reactor operation stops and would be replaced by an amended permit once decommissioning 

25 actions commence. The NRC staff concludes that impacts on surface water from the no-action 

26 alternative would be SMALL.

27 8.5.4 Aquatic Resources

28 If the plant were to cease operating, impacts on aquatic ecology would decrease because the 

29 plant would withdraw and discharge less water than it does during operations. Shutdown would 

30 reduce the already SMALL impacts on aquatic ecology.

31 8.5.5 Terrestrial Resources

32 If the plant were to cease operating, the terrestrial ecology impacts would be SMALL, assuming 

33 that no additional land disturbances on or offsite would occur during decommissioning activities.
Environmental Impacts of Alternatives

8-76

1 8.5.6 Human Health

2 In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant operation 

3 on human health would be SMALL. After cessation of plant operations, the amounts of 

4 radioactive material released to the environment in gaseous and liquid forms, all of which are 

5 currently within respective regulatory limits, would be reduced or eliminated. Therefore, the 

6 NRC staff concludes that the impact of plant shutdown on human health would also be SMALL. 

7 In addition, the potential for a variety of accidents would also be reduced to only those 

8 associated specifically with shutdown activities and fuel handling. In Chapter 5 of this SEIS, the 

9 NRC staff concluded that impacts of accidents during operation would be SMALL. It follows, 

10 therefore, that impacts on human health from a reduced suite of potential accidents after reactor 

11 operation ceases would also be SMALL. Therefore, the NRC staff concludes that impacts on 

12 human health from the no-action alternative would be SMALL.

13 8.5.7 Land Use

14 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 

15 remain in place until decommissioning. Most transmission lines connected to Davis-Besse 

16 would remain in service after the plant stops operating. Maintenance of most existing 

17 transmission lines would continue as before. The transmission lines could be used to deliver 

18 new replacement electrical power from the Davis-Besse site. Impacts on land use from plant 

19 shutdown would be SMALL.

20 8.5.8 Socioeconomics

21 Plant shutdown would have a noticeable impact on socioeconomic conditions in the 

22 communities near Davis-Besse. Should the plant shut down, there would be immediate 

23 socioeconomic impacts from the loss of jobs (some, though not all, of the approximately 

24 880 employees would begin to leave), and tax payments may be reduced. Impacts at the 

25 county level would be concentrated in Ottawa County as well as Lucas, Sandusky, and Wood 

26 counties, where the majority of Davis-Besse employees live. Revenue losses from Davis-Besse 

27 operations would directly affect Ottawa County and other local taxing districts and communities 

28 closest to, and most reliant on, the nuclear power plant’s tax revenue. The impact of job loss, 

29 however, may not be as noticeable given the amount of time required to decontaminate and 

30 decommission the nuclear power plant and the proximity of Davis-Besse to the Toledo 

31 metropolitan area. The socioeconomic impacts of power plant shutdown (which may not 

32 entirely cease until after decommissioning) could, depending on the jurisdiction, range from 

33 SMALL to MODERATE. See Appendix J to NUREG-0596, Supplement 1 (NRC 2002) for a 

34 description of the potential socioeconomic impacts of plant decommissioning.

35 8.5.8.1 Transportation

36 Traffic volumes on the roads near Davis-Besse would be reduced after plant shutdown due to 

37 the loss of jobs. Deliveries of materials and equipment to Davis-Besse would also be reduced 

38 until decommissioning. Transportation impacts from the termination of power plant operations 

39 would be SMALL.

40 8.5.8.2 Aesthetics

41 Plant structures and other facilities would likely remain in place until decommissioning. Noise 

42 caused by reactor plants operation would cease. Therefore, aesthetic impacts of plant closure 

43 would be SMALL.
Environmental Impacts of Alternatives

8-77

1 8.5.8.3 Historic and Archaeological Resources

2 Impacts from the no-action alternative on historic and archaeological resources would be 

3 SMALL. A separate environmental review would be conducted for decommissioning. That 

4 assessment would address the protection of historic and archaeological resources.

5 8.5.8.4 Environmental Justice

6 Impacts to minority and low-income populations when Davis-Besse ceases operations would 

7 depend on the number of jobs and the amount of tax revenues lost by the communities in the 

8 immediate vicinity of Davis-Besse after the termination of reactor operations. Closure of 

9 Davis-Besse would reduce the overall number of jobs and tax revenue for social services 

10 attributed to nuclear power plant operations. Minority and low-income populations in the 

11 township vicinity of Davis-Besse could experience some socioeconomic effects from power 

12 plant shutdown, but these effects would not likely be disproportionately high and adverse.

13 8.5.9 Waste Management

14 The wastes generated by continued plant operation are discussed in Chapters 2 and 6 of this 

15 SEIS. The impacts of low-level and mixed waste from plant operation are characterized as 

16 SMALL. Once Davis-Besse stops operating, generation of high-level waste would cease, and 

17 generation of low-level and mixed wastes would be diminished, limited only to those wastes 

18 associated with reactor shutdown and fuel handling activities. Therefore, the NRC staff 

19 concludes that the impacts of waste generation after shutdown would be SMALL.

20 Significant amounts of waste would be generated as a result of decommissioning, regardless of 

21 whether that takes place immediately after license expiration or at some point beyond that. 

22 However, pursuit of the no-action alternative would not impact the amounts or types of wastes 

23 that would be generated during decommissioning.

24 8.6 Alternatives Summary

25 In this SEIS, the NRC staff has considered alternative actions to license renewal of 

26 Davis-Besse, including in-depth evaluations of new generation alternatives 

27 (Sections 8.1 through 8.3), alternatives that the NRC staff dismissed from detailed evaluation as 

28 infeasible or inappropriate (Section 8.4), and the no-action alternative in which the operating 

29 license is not renewed (Section 8.5). Impacts of all alternatives considered in detail are 

30 summarized in Table 8.6-1. 

31 Based on the above evaluations, the NRC staff concludes that the environmental impacts of 

32 renewal of the operating license for Davis-Besse would be smaller than those of feasible and 

33 commercially viable alternatives studied in this SEIS that satisfy the purpose and need of 

34 license renewal (provision of 908 MWe of baseload power to the grid). Impacts on air quality 

35 are less from continued operation of Davis-Besse than from any of the alternatives involving 

36 fossil fuels (including dismissed combinations that rely on CAES to support wind or solar power 

37 installations). The NRC staff considered a combination of alternatives that includes wind, solar, 

38 CAES, and a small amount of NGCC capacity, and it found that such a combination would have 

39 noticeable environmental impacts in more areas would have resulted from pursuit of NGCC 

40 generation alone or license renewal. Finally, the NRC concluded that under the no-action 

41 alternative, the act of shutting down Davis-Besse on or before its license expiration would have 

42 only SMALL impacts in all categories except socioeconomics, where it could have a 

43 MODERATE impact in areas immediately adjacent to Davis-Besse. However, depending on 
Environmental Impacts of Alternatives

8-78

1 how the power lost to the region from reactor shutdown was replaced (decisions outside of 

2 NRC’s authority and made instead by FirstEnergy, other power producers, and State or

3 non-NRC Federal authorities or both), the net environmental impact of the no-action alternative 

4 could be greater than continued reactor operation, especially when fossil energy power plants 

5 were selected as full or partial replacements.
8-79

Table 8.6-1. Summary of environmental Impacts of Proposed Action and Alternative1 

Alternative 

Impact Area

Quality Air 

Groundwater

Water Surface 

Aquatic ResourcesTerrestrial Resources

Health Human 

SocioeconomicsWaste Management

License renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL 

NGCC at Davis-Besse SMALL to 

Moderate SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE SMALL 

Combination SMALL SMALL SMALL SMALL SMALL to 

MODERATE SMALL MODERATE SMALL 

Supercritical pulverized 

coal at an alternate site 

MODERATE SMALL SMALL SMALL to 

LARGE SMALL SMALL SMALL to MODERATE MODERATE 

No-action alternative SMALL SMALL SMALL SMALL SMALL SMALL SMALL to 

MODERATE SMALL 

 2 
8-80

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9 Siemens Combined Cycle Power Plants. Available at: 

10 http://www.energy.siemens.com/us/en/power-generation/power-plants/gas-fired-power-plants/

11 combined-cycle-power-plant-concept/scc6-5000f-1x1-flex-plant-30.htm. Accessed 

12 November 9, 2011, and December 2, 2011.

13 [Siemens] Siemens Power Generation. 2012. “Siemens Combined Cycle Power Plants.” 

14 Available at: http://www.energy.siemens.com/hq/pool/hq/power-generation/power-plants/gas15 fired-power-plants/combined-cycle16 powerplants/Siemens%20Combined%20Cycle%20Plants.pdf. Accessed March 2013.

17 Sovacool, B. 2008. Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical 

18 Survey. Energy Policy 36 (2008) 2940–2953. Available at: 

19 http://www.nirs.org/climate/background/sovacool_nuclear_ghg.pdf. Accessed 

20 December 16, 2010.

21 [TRC] TRC Environmental Corporation. 1995. Emission Inventory Report, Centerior Energy 

22 Corporation, Davis-Besse Nuclear Power Station, Oak Harbor, OH. February 10.

23 Wald, Matthew L. “Offshore Wind Is a Bit Closer, Backers Say.” Green: A Blog About Energy 

24 and the Environment. The New York Times. October 13, 2011. Available at: 

25 http://green.blogs.nytimes.com/2011/10/13/offshore-wind-is-inching-closer-backers-say/. 

26 Accessed May 6, 2013. 

27 Wind Powering America. 2011. “Installed Wind Capacity by State.” Updated April 29, 2011. 

28 Available at: http://www.windpoweringamerica.gov/docs/installed_wind_capacity_by_state.xls. 

29 Accessed November 3, 2011.
9-1 

1 9.0 CONCLUSION

2 This supplemental environmental impact statement (SEIS) contains the preliminary 

3 environmental review of FirstEnergy Nuclear Operating Company’s (FENOC) application for a 

4 renewed operating license for the Davis-Besse Nuclear Power Station, Unit No. 1 

5 (Davis-Besse), as required by Title 10 of the Code of Federal Regulations (CFR) Part 51 

6 (10 CFR Part 51), which implements the National Environmental Policy Act (NEPA). Chapter 9 

7 presents the conclusions and recommendations from the site-specific environmental review of 

8 Davis-Besse and summarizes site-specific environmental issues of license renewal that were 

9 identified during the review. The environmental impacts of license renewal are summarized in 

10 Section 9.1; a comparison of the environmental impacts of license renewal and energy 

11 alternatives is presented in Section 9.2; unavoidable impacts of license renewal and energy 

12 alternatives and resource commitments are discussed in Section 9.3; and conclusions and U.S. 

13 Nuclear Regulatory Commission (NRC) staff recommendations are presented in Section 9.4.

14 9.1 Environmental Impacts of License Renewal

15 Based on the NRC staff’s review of site-specific environmental impacts of license renewal

16 presented in this SEIS, the staff concludes that issuing a renewed license would have SMALL 

17 impacts. The site-specific review included 12 Category 2 issues and 2 uncategorized issues. 

18 Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines 

19 the impact designations of SMALL, MODERATE, and LARGE. 

20 The NRC staff also considered cumulative impacts of past, present, and reasonably foreseeable 

21 future actions, regardless of what agency (Federal or non Federal) or person undertakes them. 

22 The cumulative impacts of renewing Davis-Besse’s operating license, described in Section 4.13, 

23 ranges from SMALL to LARGE depending on the resource. There would be SMALL cumulative 

24 impacts for Air and Meteorology, Human Health—Radiological, Socioeconomics, Historic and

25 Archaeological Resources, and Environmental Justice. There would also be MODERATE 

26 cumulative impacts for Water Resources—Groundwater, Water Resources—Surface water, 

27 Terrestrial Resources, and Human Health—Microbiological Organisms, and there would be 

28 LARGE cumulative impacts to Aquatic Resources. 

29 9.2 Comparison of the Environmental Impacts of License Renewal and 

30 Alternatives

31 In the conclusion to Chapter 8, the NRC staff determined that impacts from license renewal are 

32 generally less than the impacts of alternatives to license renewal. In comparing likely 

33 environmental impacts from natural-gas-fired combined-cycle (NGCC), combination alternative 

34 (wind, solar, NGCC, and compressed air energy storage), coal-fired power, and environmental 

35 impacts from license renewal, the NRC staff found that license renewal would result in the 

36 lowest environmental impact. Based on the NRC staff’s analysis, the impacts of license renewal 

37 are reasonable in light of the impacts from alternatives to the license renewal.
Conclusion

9-2 

1 9.3 Resource Commitments 

2 9.3.1 Unavoidable Adverse Environmental Impacts

3 Unavoidable adverse environmental impacts are impacts that would occur after implementation 

4 of all feasible mitigation measures. Implementing any of the energy alternatives considered in 

5 this SEIS, including the proposed action, would result in some unavoidable adverse 

6 environmental impacts.

7 Minor unavoidable adverse impacts on air quality would occur due to emission and release of 

8 various chemical and radiological constituents from power plant operations. Nonradiological 

9 emissions resulting from power plant operations are expected to comply with U.S. 

10 Environmental Protection Agency (EPA) emissions standards, though the alternative of 

11 operating a fossil-fueled power plant in some areas may worsen existing attainment issues. 

12 Chemical and radiological emissions would not exceed the national emission standards for 

13 hazardous air pollutants (HAPs). 

14 During nuclear power plant operations, workers and members of the public would face 

15 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 

16 exposed to radiation and chemicals associated with routine plant operations and the handling of 

17 nuclear fuel and waste material. Workers would have higher levels of exposure than members 

18 of the public, but doses would be administratively controlled and would not exceed any 

19 standards or administrative control limits. Construction and operation of non-nuclear power 

20 generating facilities would also result in unavoidable exposure to hazardous and toxic chemicals 

21 to workers and the public.

22 Also unavoidable would be the generation of spent nuclear fuel and waste material, including 

23 low-level radioactive waste, hazardous waste, and nonhazardous waste. Hazardous and 

24 nonhazardous wastes would also be generated at non-nuclear power generating facilities. 

25 Wastes generated during plant operations would be collected, stored, and shipped for suitable 

26 treatment, recycling, or disposal, in accordance with applicable Federal and state regulations. 

27 Due to the costs of handling these materials, power plant operators would be expected to 

28 conduct all activities and optimize all operations in a way that generates the smallest amount of 

29 waste practical.

30 9.3.2 Relationship between Local Short-Term Uses of the Environment and the 

31 Maintenance and Enhancement of Long-Term Productivity

32 The operation of power-generating facilities would result in short-term uses of the environment, 

33 as described in Chapters 4, 5, 6, 7, and 8. “Short-term” is the period of time during which 

34 continued power generating activities would take place.

35 Power plant operations would necessitate short-term use of the environment and commitments 

36 of resources and would also commit certain resources (e.g., land and energy) indefinitely or 

37 permanently. Certain short-term resource commitments would be substantially greater under 

38 most energy alternatives, including license renewal, than under the no-action alternative due to 

39 the continued generation of electrical power as well as continued use of generating sites and 

40 associated infrastructure. During operations, all energy alternatives would entail similar 

41 relationships between local short-term uses of the environment and the maintenance and 

42 enhancement of long-term productivity.
Conclusion

9-3 

1 Air emissions from power plant operations would introduce small amounts of radiological and 

2 nonradiological constituents to the region around the plant site. Over time, these emissions 

3 would result in increased concentrations and exposure, but they are not expected to impact air 

4 quality or radiation exposure to the extent that public health and long-term productivity of the 

5 environment would be impaired.

6 Continued employment, expenditures, and tax revenues generated during power plant 

7 operations would directly benefit local, regional, and state economies over the short term. Local 

8 governments investing project-generated tax revenues into infrastructure and other required 

9 services could enhance economic productivity over the long term.

10 The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous 

11 waste, and nonhazardous waste would require an increase in energy and would consume 

12 space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to 

13 meet waste disposal needs would reduce the long-term productivity of the land.

14 Power plant facilities would be committed to electricity production over the short term. After 

15 decommissioning these facilities and restoring the area, the land could be available for other 

16 future productive uses.

17 9.3.3 Irreversible and Irretrievable Commitments of Resources

18 Irreversible and irretrievable commitment of resources for electrical power generation would 

19 include the commitment of land, water, energy, raw materials, and other natural and manmade 

20 resources required for power plant operations. This section describes the irreversible and 

21 irretrievable commitments of resources that have been identified in this SEIS. A commitment of 

22 resources is irreversible when primary or secondary impacts limit the future options for a 

23 resource. An irretrievable commitment refers to the use or consumption of resources neither 

24 renewable nor recoverable for future use. In general, the commitment of capital, energy, labor, 

25 and material resources would also be irreversible.

26 The implementation of any of the energy alternatives considered in this SEIS would entail the 

27 irreversible and irretrievable commitment of energy, water, chemicals, and—in some cases—

28 fossil fuels. These resources would be committed during the license renewal term and over the 

29 entire life cycle of the power plant and would essentially be unrecoverable.

30 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 

31 operations and electricity for equipment and facility operations. Electricity and fuels would be 

32 purchased from offsite commercial sources. Water would be obtained from existing water 

33 supply systems. These resources are readily available, and the amounts required are not 

34 expected to deplete available supplies or exceed available system capacities.

35 The irreversible and irretrievable commitment of material resources includes materials that 

36 cannot be recovered or recycled, materials that are rendered radioactive and cannot be 

37 decontaminated, and materials consumed or reduced to unrecoverable forms of waste. 

38 However, none of the resources used by these power-generating facilities is in short supply, 

39 and, for the most part, are readily available.

40 Various materials and chemicals, including acids and caustics, would be required to support 

41 operations activities. These materials would be derived from commercial vendors, and their 

42 consumption is not expected to affect local, regional, or national supplies.
Conclusion

9-4 

1 The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste, 

2 hazardous waste, and nonhazardous waste would require the irretrievable commitment of 

3 energy and fuel and would result in the irreversible commitment of space in disposal facilities.

4 9.4 Recommendation

5 The preliminary recommendation of the NRC staff is that the adverse environmental impacts of 

6 license renewal for Davis-Besse are not so great that preserving the option of license renewal 

7 for energy-planning decisionmakers would be unreasonable. The NRC staff based this 

8 recommendation of the following:

9 • the analysis and findings in the generic environmental impact statement (GEIS), 

10 • information provided in the environmental report (ER) submitted by FENOC, 

11 • consultation with Federal, State, and local agencies, 

12 • a review of pertinent documents and reports, and

13 • consideration of public comments received during scoping. 
10-1 

1 10.0 LIST OF PREPARERS

2 This supplemental environmental impact statement (SEIS) was prepared by members of the 

3 Office of Nuclear Reactor Regulation (NRR) with assistance from other U.S. Nuclear Regulatory 

4 Commission (NRC) organizations and contract support from Argonne National Laboratory (ANL) 

5 and Pacific Northwest National Laboratory (PNNL). 

6 Table 10.1-1 provides a list of NRC staff that participated in the development of the SEIS. ANL

7 provided contract support for terrestrial, socioeconomic, aquatic ecology, cultural resources, air 

8 quality, and hydrology, presented primarily in Chapters 2, 4, and 8. PNNL provided contract 

9 support for the severe accident mitigation alternatives (SAMAs) analysis, which is presented in 

10 Chapter 5 and Appendix F.

11 Table 10.1-1. List of Preparers

Name Affiliation Function or Expertise

NRC

Allison Travers NRR Alternatives

Andrew Imboden NRR Branch Chief, Environmental

Andrew Stuyvenberg NRR Alternatives

April BeBault NRR Air & Meteorology 

Historic & Archeological Resources 

Briana Balsam NRR Aquatic Ecology 

Terrestrial Ecology

David Wrona NRR Branch Chief

Brian Wittick NRR Branch Chief

Dennis Beissel NRR Hydrology

Emily Larson NRR Historic & Archeological Resources

Socioeconomics

Jeff Rikhoff NRR Environmental Justice 

Land Use 

Socioeconomics

Kevin Folk NRR Hydrology

Jerry Dozier NRR SAMAs

John Parillo NRR SAMAs

Michelle Moser NRR Cumulative Impacts

Paula Cooper NRR Project Manager

Hydrology

Elaine Keegan NRR Project Manager

Travis Tate NRR Branch Chief, SAMAs

William Rautzen NRR Human Health

Radiation Protection

Solid Waste
List of Preparers

10-2 

Name Affiliation Function or Expertise

Stephen Klementowicz NRR Human Health

Radiation Protection

Solid Waste

Lab Contractor(a)

John Quinn ANL Hydrology

Konstance Wescott ANL Project Manager, Contract Staff

Historic & Archeological Resources

Ron Kolpa ANL Alternatives

Youngsoo Chang ANL Air & Meteorology

SAMA Contractor(b) 

Steve Short PNNL SAMAs

G. Coles PNNL SAMA

(a) ANL is operated for the U.S. Department of Energy by the University of Chicago Argonne, LLC.

(b) PNNL is operated for the U.S. Department of Energy by Battelle.
11-1 

1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM 

2 COPIES OF THIS SUPPLEMENTAL ENVIRONMENTAL IMPACT 

3 STATEMENT WERE SENT

Commenter Affiliation (If Stated)

Environmental Impact Statement (EIS)

Filing Section

U.S. Environmental Protection Agency (EPA)

1200 Pennsylvania Ave NW

Washington, D.C. 20004

EIS Filing Section

U.S. EPA, Region 5

National Environmental Policy Act (NEPA) Implementation Section (Mail 

Code E-19J)

77 W. Jackson Blvd

Chicago, IL 60604

Mr. Reid Nelson

Director, Office of Federal Agency 

Programs 

Advisory Council on Historic Preservation (ACHP)

1100 Pennsylvania Ave NW, Suite 803

Old Post Office Building

Washington, D.C. 20004

John P. Froman 

Chief, Peoria Tribe of Indians of Oklahoma

Peoria Tribe of Indians of Oklahoma

P.O. Box 1527

Miami, OK 74355

Mr. Clyde Scoles

Director

Toledo-Lucas County Public Library

325 Michigan St 

Toledo, OH 43604

Ms.Deborah Rossman

Director

Ida Rupp Public Library 

310 Madison St 

Port Clinton, OH 43452

Mr. Edgar L. French

Delaware Nation

P.O. Box 825

Anadarko, OK 73005

Mr. Harold G. Frank

Forest County Potawatomi Community

Community of Wisconsin

P.O. Box 340

Crandon, WI 54520

Mr. Kenneth Meshiguad

Hannahville Indian Community Council

N14911 Hannahville B1 Rd

Wilson, MI 49896

Mr. Floyd E. Leonard 

Miami Tribe of Oklahoma

P.O. Box 1326

Miami, OK 74355

Mr. Ron Sparkman 

Shawnee Tribe

P.O. Box 189

Miami, OK 74355

Mr. Leaford Bearskin 

Wyandotte Nation

P.O. Box 250

Wyandotte, OK 74370

Mr. Charles Todd 

Ottawa Tribe of Oklahoma

P.O. Box 110

811 Third Ave NE

Miami, OK 74355
List of Agencies, Organizations, and Persons to Whom Copies of This Supplemental 

Environmental Impact Statement Were Sent

11-2 

Commenter Affiliation (If Stated)

Ms. Patricia Kurkul

Regional Administrator

National Oceanic & Atmospheric Administration (NOAA) Fisheries 

Service 

Northeast Regional Office

55 Great Republic Dr

Gloucester, MA 01930-2276

Mr. Mark Epstein

Department Head, 

Resource Protection & Review

Ohio Historic Preservation Office

182 Velma Ave 

Columbus, OH 43211-2497

Mr. Brian Mitch

Environmental Review Manager

Ohio Department of Natural Resources

Division of Engineering

Environmental Services Section

2045 Morse Rd, Building F-3 

Columbus, OH 43229-6693

Mark Stahl

[Current President - James M. Sass] 

President of the Ottawa County Commissioners

315 Madison Street, Rm 103

Port Clinton, Ohio 43452

Jere Witt

[Current Administrator - Dennis C. Jensen] 

County Administrator Ottawa County

315 Madison Street

Port Clinton, Ohio 43452

Fred Petersen

Director of the Emergency Management Agency Ottawa County

315 Madison Street, Rm 056

Port Clinton, Ohio 43452

Chris Galvin 

Director, United Way Ottawa County chris.galvin@unitedwayottawacounty.org

Jackie VanTress Office & Professional Employees International Union (OPEIU) Local 19

jackiev@bex.net

Kimberly Kaufman 

Executive Director, 

Black Swamp Bird Observatory

KimKaufman@bsbo.org

Black Swamp Bird Observatory

13551 W. State Route 2

Oak Harbor, OH 43449

Steve Inchak Representative Congressman Kucinich

Beth Leggett 

Director, American Red Cross 

Ottawa County

American Red Cross

1854 E. Perry St, Suite 600

Port Clinton, OH 43452

redcross@thirdplanet.net

Brad Goetz

International Brotherhood of Electrical Workers Local 1413

P.O. Box 122

Oak Harbor, OH 43449

bngoets@wcnet.org

Ann Heckerd 

Food Coordinator, 

St. Vincent DePaul Food Pantry

St. Vincent DePaul Food Pantry

1117 E. 3rd St 

Port Clinton, OH 43452

ajh1117@msn.com

Brian Boles 

Plant Manager, Davis-Besse Bdboles@firstenergycorp.com
List of Agencies, Organizations, and Persons to Whom Copies of This Supplemental 

Environmental Impact Statement Were Sent

11-3 

Commenter Affiliation (If Stated)

Larry Tscherne 

International Brotherhood of Electrical 

Workers

larry@ibew245.com

Mike Drusbacky

Deputy Director, Ottawa County

315 Madison Street

Port Clinton, Ohio 43452

Joseph DeMare

Ohio Green Party

Ohio Green Party

1111 West Elm Tree Rd

Rossford, OH 43460

electricity2@cs.com

Jane Ridenour 

President, OPEIU Local 19

OPEIU Local 19

2300 Ashland Ave, Rm 224A

Toledo, OH 43620

opeiu19@sbcglobal.net

Patricia Marida 

Chair, Nuclear Issues Committee 

Sierra Club

Sierra Club

1710 Dorsetshire Rd

Columbus, OH 43229

marida@wideopenwest.com

131 North High St, Suite 605

Columbus, OH 43215-3026

Matthew Heyrman No affiliation given 

Anita Rios Ohio Green Party

Kevin Kamps Beyond Nuclear

Al Compaan Professor, University of Toledo

Katie Hoepfl Student, University of Toledo

Tony Szilagye No affiliation given

Ed McArdle Sierra Club of Michigan

Phyllis Oster No affiliation given

Dave Ellison No affiliation given

Michael Keegan 

mkeeganj@comcast.net

Coalition for a Nuclear Free Great Lakes, 

Don’t Waste Michigan

Monroe, Michigan 48161

Ralph Semrock Associate Professor, Owens

Mike Leonardi No affiliation given

Eric Britton No affiliation given

Suzanne Patser No affiliation given

James Whitaker No affiliation given

Scott Robinson No affiliation given

Simone Morgan Sierra Club

Emily Journey No affiliation given

Bob Patraicus No affiliation given
List of Agencies, Organizations, and Persons to Whom Copies of This Supplemental 

Environmental Impact Statement Were Sent

11-4 

Commenter Affiliation (If Stated)

Kevin Malcolm No affiliation given

Doug Todd No affiliation given

Connie Hammond Sierra Club

Bernadine Kent No affiliation given

Pete Johnson No affiliation given

Connie Gadwell-Newton Ohio Green Party

Sierra Club

Lee Blackburn Sierra Club

Mary Knapp 

Field Supervisor, 

U.S. Fish & Wildlife Service

Fish & Wildlife Serives, Ecological Services

4625 Morse Road, Suite 104

Columbus, OH 43230

Dennis Kucinich,

Member of Congress, 

10th District Ohio House of 

Representatives

14400 Detroit Ave

Lakewood, OH 44107

Marilyn & Paul Nesser No affiliation given

Jessica Lillian Weinberg No affiliation given

Erika Agner 

Sierra Club Sierra Club

Christian George Sierra Club

Amanda Baldino Sierra Club

Inez George 

Sierra Club Sierra Club

Leeza Perry 

Sierra Club Sierra Club

Jeremy Bantz Sierra Club

David Greene Sierra Club

Jean Puchstein Sierra Club

Sandy Bihn Sierra Club

Bob Greenbaum Sierra Club

Carol Rainey Sierra Club

Leonard Bildstein Sierra Club

Cate Renner Sierra Club

Karen Hansen Sierra Club

Natalie Schafrath Sierra Club

Kathleen Bodnar Sierra Club

Margaret Holfinger Sierra Club

Ben Shapiro Sierra Club
List of Agencies, Organizations, and Persons to Whom Copies of This Supplemental 

Environmental Impact Statement Were Sent

11-5 

Commenter Affiliation (If Stated)

Susan Jones Sierra Club

Leslie Stansbery Sierra Club

Stephen & Connie Caruso Sierra Club

Robert Kyle Sierra Club

Andy Trokan Sierra Club

Joan DeLauro Sierra Club

Joan Lang Sierra Club

Jim Wagner Sierra Club

June Douglas Sierra Club

Tekla Lewin Sierra Club

Tim Wagner Sierra Club

Virginia Douglas Sierra Club

Mary Beth Lohse Sierra Club

George M. Williams Sierra Club

Donna Emig Sierra Club

Liz Loring Sierra Club

Lance Wilson Sierra Club

Mike Fremont Sierra Club

Nick Mellis Sierra Club

Paul Wojoski Sierra Club

Linda Milligan Sierra Club

Elisa Young Sierra Club

Matt Trokan Sierra Club

12-1 

12.0 INDEX

accidents, xviii, 2-7, 4-26, 5-1–5-5, 8-29, 

8-61, 8-76, A-6, A-23, A-26, A-29, A-30, 

A-32, A-36, A-38, A-40, A-41, B-8, C-4, F-4, 

F-6, F-9, F-12, F-18, F-29–F-31

Advisory Council on Historic 

Preservation (ACHP), iii, xviii, xix, 1-7, 

4-29, 4-48, 4-52, 11-1, C-4, D-1, E-2 

alternatives, 1-6, 4-38, 5-2, 5-3, 6-3, 6-4, 

6-5, 8-1–8-74, 8-77, 8-79, 9-1, 9-2, 9-3, A-1, 

A-7–A-10, A-12–A-19, A-23, A-31, A-33, 

A-36, A-40, A-47, B-8, C-3, F-2, F-21, F-23, 

F-33, F-34

archaeological resources, xviii, 1-7, 2-69, 

2-70–2-73, 3-2, 3-8, 3-9, 4-18, 4-29, 4-30, 

4-45, 8-16, 8-35, 8-36, 8-51, 8-62, 8-66, 

8-77, B-8, C-5, D-1 

biocide, 2-29

biota, 2-34, 4-6, 8-11, 8-46, B-3 

burnup, B-10

chronic effects, 1-3, 4-13, 4-18, B-1, B-7 

Clean Air Act (CAA), 2-21, 2-22, 2-79, 

3-10, 8-7, 8-8, 8-18, 8-22, 8-23, 8-38, 8-42, 

8-43, 8-54, C-2, C-4, C-5 

closed-cycle cooling, 2-1, 2-15, 8-5, 8-46, 

8-75, B-5 

Coastal Zone Management Act (CZMA), 

2-74, 2-79, 2-87, C-2 

core damage frequency (CDF), 5-4–5-6, 

F-1– F-12, F-17–F-24, F-30, F-31, F-32

Council on Environmental Quality (CEQ), 

1-4, 4-21, 4-22, 4-31, 4-38, 4-48, A-16

critical habitat, 2-46–2-48, 2-76, 3-5, 4-9, 

4-12, 8-12, 8-47, A-23, A-49

cultural resources, 2-72, 4-30, 4-45, 8-16, 

8-35, 8-66, 10-1, A-23, C-1 

decommissioning, 8-76

demography, 2-56, 2-57, 2-61, 4-19, 8-13, 

A-18

design-basis accident, 2-7, 5-1, A-40, B-8 

discharges, 2-8, 2-11, 2-16, 2-17, 2-27–

2-29, 2-36, 2-39, 4-4–4-8, 4-13, 4-37–4-39, 

8-11, 8-26, 8-27, 8-46, 8-59, 8-64, 8-66, 

8-75, A-20–A-22, A-28, B-3, B-7, C-3, C-5 

dose, 2-8, 2-9, 4-15, 4-16, 4-42, 5-4, 5-5, 

6-2, A-25–A-27, B-6, B-8, B-9, F-4, F-5,

F-12, F-14–F-17, F-23, F-24, F-29, F-30, 

F-32, F-33

education, 2-58, 2-65, 3-2, 4-18, B-7 

electromagnetic fields, 1-3, 4-7, 4-17, 

4-18, 4-44, B-1, B-6, B-7 

endangered and threatened species, xviii, 

1-7, 2-48, 2-76, 3-2, 4-9, 4-53, B-6, C-1, D-1 

Endangered Species Act (ESA), xviii, 1-7, 

1-9, 2-44–2-49, 2-76, 2-80, 2-82, 4-9, 4-10, 

4-49, 8-11, 8-12, 8-47, C-4, D-1 

entrainment, 2-38, 2-46, 4-39, A-20, B-3, 

B-4 

environmental justice (EJ), xvii, xviii, 1-3, 

1-4, 1-7, 3-2, 3-9, 3-12, 4-19, 4-21, 4-26, 

4-45, 8-16, 8-36, 8-52, B-1, B-11

essential fish habitat (EFH), 2-44, D-1 

Fish and Wildlife Coordination Act 

(FWCA), C-4 

Generic Environmental Impact Statement 

(GEIS), iii, xvi– xix, 1-3–1-9, 2-45, 2-60, 

2-87, 2-88, 3-1, 3-2, 3-10, 3-12, 3-13, 4-1–

4-9, 4-13–4-19, 4-21, 4-27, 4-28, 4-30, 4-31, 

4-44, 4-52, 5-1–5-3, 5-9, 6-1–6-3, 6-10, 

7-1–7-3, 8-1, 8-3, 8-13, 8-14, 8-18, 8-29, 

8-31, 8-48, 8-49, 8-67, 8-69, 8-70, 8-72, 

8-74, 8-84, 9-4, A-1, A-5, A-16, A-30, A-34, 

A-40, A-41, B-1, B-8 

greenhouse gases, 2-22, 4-34, 6-3, 8-5, 

8-8, 8-42, A-9, A-19

groundwater, xvii, 1-4, 1-7, 2-17, 2-18, 

2-30, 3-1, 4-4, 4-5, 4-14, 4-15, 4-26, 4-27, 

4-35, 4-46, 8-3, 8-10, 8-25, 8-45, 8-53, 8-59, 
Index

12-2 

8-64, 8-75, A-18, A-27, A-28, B-1, B-4, B-5, 

B-8, C-1 

hazardous waste, 2-10, 2-11, 8-37, 8-53, 

8-66, 9-2–9-4, C-3, C-6 

heat shock, B-4 

high-level waste, xvi, 1-5, 6-1, 6-2, 7-1, 

8-77, B-10

impingement, 2-37, 2-38, 2-46, 4-39, A-20, 

B-3, B-4 

independent spent fuel storage 

installation (ISFSI), 2-1, 4-42, 4-43, A-42

invasive species, 2-34–2-36, 2-42, 2-44, 

4-37–4-42, 4-47

low-level waste, 6-1, B-10

Marine Mammal Protection Act (MMPA), 

2-45

maximum occupational doses, B-7 

mitigation, xvi, xviii, 1-4–1-6, 2-49, 3-5, 3-6, 

4-12, 7-1, 8-12, 8-16, 8-35, 8-47, 8-48, 8-51, 

9-2, A-16, A-40, A-41

mixed waste, 8-77, B-10

National Environmental Policy Act 

(NEPA), xv, xvi, xvii, 1-1, 1-3, 1-4, 1-7, 1-9, 

2-87, 3-3, 4-1, 4-21, 4-30, 4-38, 4-48, 4-49, 

4-51, 5-1, 6-2, 6-3, 7-1, 8-1, 8-6, 8-39, 8-84, 

9-1, 11-1, A-16, A-17, A-34, B-1, B-2, B-8, 

B-9, C-3, D-1 

National Marine Fisheries Service 

(NMFS), 1-8, 2-45, 2-46, 2-87, 4-9, 4-52, 

D-1 

National Pollutant Discharge Elimination 

System (NPDES), 2-11, 2-27–2-30, 2-80, 

2-83, 4-37, 8-11, 8-27, 8-46, 8-60, A-22, 

A-28, B-2, C-1, C-3, C-5 

Native American, 2-71, 4-21, 4-26, 4-29, 

4-45, 4-47

no-action alternative, iii, xix, 4-38, 8-74–

8-77, 9-2 

nonattainment, 2-23, 3-10, 3-11, 4-34, 

4-46, B-6 

once-through cooling, B-2–B-4, F-23

peak dose, B-9 

postulated accidents, 4-26, 5-1, 5-2, A-40

pressurized water reactor, 2-1, 2-6, 5-6, 

F-17, F-18, F-20

reactor, xv, xvi, xxiii, 1-3, 2-6–2-8, 2-12, 

2-20, 2-33, 2-72, 3-2, 3-4, 3-9, 4-5, 4-20, 

4-33, 4-36, 4-43, 5-1–5-6, 6-2, 6-4, 7-1, 8-3, 

8-4, 8-6, 8-9, 8-11, 8-14, 8-16, 8-24, 8-44, 

8-48, 8-55, 8-73, 8-75–8-78, A-14, A-25, 

A-26, A-34, A-37, A-38, A-44, B-1, B-5, B-8, 

F-3, F-6, F-7, F-12, F-13, F-17, F-21, F-22, 

F-31

refurbishment, xviii, 2-45, 2-46, 3-1–3-12, 

4-2, 4-3, 4-8, 4-12, 4-13, 4-16, 4-20, 4-21, 

4-29, 4-33, 4-34, 4-43, 4-46, A-23, B-2–B-8, 

F-30, F-32

replacement power, iii, 5-7, 8-6, 8-13, 

8-16, 8-29, 8-33, 8-39, 8-49, 8-55, F-27, 

F-30, F-31

scoping, iii, xv, xvi, xix, 1-2, 1-6, 1-7, 2-73, 

4-1–4-8, 4-13, 4-14, 4-18, 4-31, 4-32, 4-43, 

4-53, 5-2, 6-2, 7-2, 8-56, 9-4, A-1– A-3, A-6, 

A-7, A-21, A-25, A-29–A-33, A-36, E-7 

seismic, 2-7, 2-26, 2-29, 5-4, A-41, F-9–

F-11, F-18, F-21, F-22, F-28, F-32

severe accident mitigation alternative 

(SAMA), xviii, 5-3–5-8, 10-1, 10-2, A-6, A-7, 

A-40, A-41, F-1–F-3, F-6– F-35, F-37

severe accidents, xviii, 5-1, 5-2, 5-3, 5-6, 

10-1, A-40, A- 41, B-8, F-1, F-6, F-9, F-12, 

F-18, F-30, F-31, F-35

solid waste, xix, 2-9–2-11, 6-1, 6-2, 7-2, 

8-2, 8-53, 8-69, 8-70, 8-72, A-15, A-44, 

B-11, C-3 

spent fuel, xvi, 1-5, 2-8, 2-33, 4-33, 6-1, 

6-2, 7-1, A-40, B-8–B-10

State Historic Preservation Office 

(SHPO), 2-72, 3-8, 4-29, 4-30, 4-45, 4-47, 

B-8, E-4 

State Pollutant Discharge Elimination 

System (SPDES), C-1 

stormwater, 2-28–2-30, 2-33, 4-3, 8-10, 

8-11, 8-26, 8-45, 8-46, 8-75

surface water, 2-27, 3-1, 4-3, 4-4, 4-15, 

4-26, 4-27, 4-35–4-38, 4-41, 8-3, 8-10, 8-11, 
12-3 

8-25–8-27, 8-46, 8-47, 8-53, 8-58, 8-59, 

8-64, 8-65, 8-75, A-18, A-28, B-2, B-4, C-1 

taxes, 2-65, 2-67, 4-28, 8-14, 8-33, 8-50

transmission lines, 2-12–2-14, 2-44–2-46, 

3-4, 3-8, 3-10, 4-1–4-3, 4-7, 4-8, 4-16–4-18, 

4-29, 4-41, 4-44, 4-45, 8-6, 8-12, 8-16, 8-30, 

8-35, 8-36, 8-49, 8-52, 8-76, B-6, B-8 

tritium, 2-30, 2-31, 2-33, 4-5, 4-35, 8-75, 

A-26–A-28

U.S. Department of Energy (DOE), 4-17, 

4-49, 8-3, 8-56, 8-63, 8-67, 8-80, 8-81, 8-83, 

8-84, 10-2, A-17, B-9 

U.S. Environmental Protection Agency 

(EPA), xv–xix, 1-1, 11-1, 2-10–2-12, 2-21–

2-24, 2-28–2-30, 2-33, 2-34, 2-40, 2-60, 

2-75, 2-76, 2-80–2-83, 2-90, 3-10, 3-11, 

3-13, 4-2, 4-5, 4-15, 4-33–4-39, 4-42, 4-43, 

4-49, 4-53, 7-1, 8-1, 8-3, 8-7–8-10, 8-17, 

8-18, 8-22–8-24, 8-35, 8-38, 8-42–8-44, 

8-48, 8-53, 8-54, 8-69, 8-75, 8-81, 8-82, 

8-85, 9-1, 9-2, A-17, A-20, A-22, A-27, A-28, 

A-35, B-9, C-1–C-6, F-14, F-36

U.S. Fish and Wildlife Service (FWS), 1-8, 

2-30, 2-40–2-49, 2-72, 2-76, 2-83–2-85, 

3-4–3-6, 3-13, 4-9–4-12, 4-30, 4-32, 4-40, 

4-41, 4-51, 4-52, 8-12, 8-47, A-4, A-49, C-4, 

D-1, E-1, E-4–E-6 

uranium, 2-6–2-8, 4-42, 4-47, 6-1–6-8, 

8-13, 8-31, 8-48, 8-49, A-14, A-19, A-43, 

A-44, B-8, B-10

wastewater, 2-11, 2-28, 4-4, 8-70, A-20, 

B-2, C-5 

Yucca Mountain, A-41, A-42, B-9, B-10

APPENDIX A 

COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW 

A-1 

1 A COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW 

2 A.1 A.1 Comments Received During Scoping

3 The scoping process began on October 28, 2010, with the publication of the U.S. Nuclear 

4 Regulatory Commission’s (NRC) notice of intent to conduct scoping in the Federal Register

5 (75 FR 66399). As part of the scoping process, NRC held two public meetings at Camp Perry 

6 Lodging and Conference Center, Port Clinton, OH, on November 4, 2010. Approximately 

7 40 members of the public attended the meetings. After the NRC staff presented prepared 

8 statements pertaining to the license renewal and the scoping process, the meetings were 

9 opened to the for public for their comments. Attendees provided oral statements that were 

10 recorded and transcribed by a certified court reporter. Transcripts of the entire meeting are 

11 attached at the end of this appendix. In addition to the comments received during the public 

12 meetings, comments were received through the mail and e-mail.

13 Each commenter was given a unique identifier so that every comment could be traced back to 

14 its author. Table A-1 identifies the individuals who provided comments applicable to the 

15 environmental review and the commenter ID associated with each person’s set of comments. 

16 The individuals are listed in the order in which they spoke at the public meeting, then at the 

17 people’s hearing, then at the Sierra Club meeting, and in random order for the comments 

18 received by letter or e-mail. The submitter of the two videos provided the NRC with a 

19 transcribed version of one of their meetings. In order to respond to comments, the other meeting 

20 was transcribed by the Environmental Project Manager. The video transcribed by the Project 

21 Manger remains the submitted comments. To maintain consistency with the scoping summary 

22 report, the unique identifier used in that report for each set of comments is retained in this 

23 appendix.

24 Specific comments were categorized and consolidated by topic. Comments with similar specific 

25 objectives were combined to capture the common essential issues raised by participants. 

26 Comments fall into one of the following general groups: 

27 • Specific comments that address environmental issues within the purview of the NRC 

28 environmental regulations related to license renewal. These comments address the 

29 Category 1 (generic) or Category 2 (site-specific) issues identified in NUREG-1437, 

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

31 or issues not addressed in the GEIS. The comments also address alternatives to 

32 license renewal and related Federal actions. There are also comments that do not 

33 identify new information for the NRC to analyze as part of its environmental review. 

34 • There are comments that address issues that do not to fall within or are specifically 

35 excluded from the purview of NRC environmental regulations related to license renewal. 

36 These comments typically address issues such as the need for power, emergency 

37 preparedness, security, current operational safety issues, and safety issues related to 

38 operation during the renewal period.

39
Appendix A

A-2 

1 Table A-1. Commenters on the Scope of the Environmental Review

2 Each commenter is identified along with their affiliation and how their comment was submitted.

Commenter Affiliation (If Stated) ID Comment Source

ADAMS Accession 

Number

Mark Stahl President of the Ottawa 

County Commissioners 1 

Afternoon scoping 

meeting ML110140231

Evening scoping 

meeting ML110140232

Jere Witt County Administrator Ottawa 

County 2 

Afternoon scoping 

meeting ML110140231

Evening scoping 

meeting ML110140232

Fred Petersen

Director of the Emergency 

Management Agency Ottawa 

County

3 Afternoon scoping 

meeting ML110140231

Chris Galvin Director, United Way Ottawa 

County 4 

Afternoon scoping 

meeting ML110140231

Meeting notes ML110680510

Jackie VanTress

Office and Professional 

Employees International 

Union (OPEIU) Local 19

5 Afternoon scoping 

meeting ML110140231

Kimberly Kaufman Executive Director, Black 

Swamp Bird Observatory 6 Afternoon scoping meeting ML110140231

Steve Inchak Representative 

Congressman Kucinich 7 Afternoon scoping meeting ML110140231

Beth Leggett Director, American Red 

Cross Ottawa County 8 Afternoon scoping meeting ML110140231

Brad Goetz

International Brotherhood of 

Electrical Workers Local 

1413

9 Afternoon scoping 

meeting ML110140231

Ann Heckerd Food Coordinator, St. 

Vincent DePaul Food Pantry 10 Afternoon scoping meeting ML110140231

Brian Boles Plant Manager, Davis-Besse 11

Afternoon scoping 

meeting ML110140231

Evening scoping 

meeting ML110140232

Larry Tscherne International Brotherhood of 

Electrical Workers 12 Afternoon scoping meeting ML110140231

Mike Drusbacky Deputy Director, Ottawa 

County 13 Evening scoping meeting ML110140232

Joseph DeMare Ohio Green Party 14

Evening scoping 

meeting ML110140232

People’s hearing ML11348A017

Meeting notes ML110680517
Appendix A

A-3 

Commenter Affiliation (If Stated) ID Comment Source

ADAMS Accession 

Number

Jane Ridenour

President, OPEIU Local 19

15

Evening scoping 

meeting ML110140232

Meeting notes ML110680512

Patricia Marida Chair, Nuclear Issues 

Committee Sierra Club 16

Evening scoping 

meeting ML110140232

Sierra Club meeting ML11348A013

Letter ML103370043

Letter ML110680515

Matthew Heyrman 17 Evening scoping 

meeting ML110140232

Anita Rios Ohio Green Party 18 People’s hearing ML11348A017

Kevin Kamps Beyond Nuclear 19 People’s hearing ML11348A017

Al Compaan Professor, University of 

Toledo 20 People’s hearing ML11348A017

Katie Hoepfl Student, University of Toledo 21 People’s hearing ML11348A017

Tony Szilagye 22 People’s hearing ML11348A017

Ed McArdle Sierra Club of Michigan 23 People’s hearing ML11348A017

Phyllis Oster 24 People’s hearing ML11348A017

Dave Ellison 25 People’s hearing ML11348A017

Michael Keegan

Coalition for a Nuclear Free 

Great Lakes 

Don’t Waste Michigan

26 People’s hearing

ML11348A017

Ralph Semrock Associate Professor, Owens 27 People’s hearing ML11348A017

Mike Leonardi 28 People’s hearing ML11348A017

Unidentifiable Woman 29 People’s hearing ML11348A017

Eric Britton 30

People’s hearing ML11348A017

E-mail ML110680350

Suzanne Patser 31 Sierra Club meeting ML11348A013

James Whitaker 32 Sierra Club meeting ML11348A013

Scott Robinson 33 Sierra Club meeting ML11348A013

Simone Morgan Sierra Club 34

Sierra Club meeting

E-mail ML110680350

Emily Journey 35 Sierra Club meeting ML11348A013

Bob Patraicus 36 Sierra Club meeting ML11348A013

Kevin Malcolm 37 Sierra Club meeting ML11348A013

Doug Todd 38 Sierra Club meeting ML11348A013
Appendix A

A-4 

Commenter Affiliation (If Stated) ID Comment Source

ADAMS Accession 

Number

Connie Hammond Sierra Club 39

Sierra Club meeting ML11348A013

E-mail ML110680350

Bernadine Kent 40 Sierra Club meeting ML11348A013

Unknown 41 Sierra Club meeting ML11348A013

Pete Johnson 42 Sierra Club meeting ML11348A013

Connie GadwellNewton Ohio Green Party 43

Sierra Club meeting ML11348A013

E-mail ML110680350

Lee Blackburn Sierra Club 44

E-mail ML103430609

E-mail ML110680350

Mary Knapp Field Supervisor, U.S. Fish 

and Wildlife Service 45 Letter ML110060289

John P. Froman Chief, Peoria Tribe of Indians 

of Oklahoma 46 Letter ML103570365

Dennis Kucinich

Member of Congress, 10th 

District Ohio House of 

Representatives

47 Letter ML110680518

Marilyn & Paul 

Nesser 48 E-mail ML110680519

Jessica Lillian 

Weinberg 49 E-mail ML110680520

Erika Agner Sierra Club 50 E-mail ML110680350

Christian George Sierra Club 51 E-mail ML110680350

Amanda Baldino Sierra Club 52 E-mail ML110680451

Inez George Sierra Club 53 E-mail ML110680530

Leeza Perry Sierra Club 54 E-mail ML110680350

Jeremy Bantz Sierra Club 55 E-mail ML110680350

David Greene Sierra Club 56 E-mail ML110680537

Jean Puchstein Sierra Club 57 E-mail ML110680350

Sandy Bihn Sierra Club 58 E-mail ML110680350

Bob Greenbaum Sierra Club 59 E-mail ML110680350

Carol Rainey Sierra Club 60 E-mail ML110680350

Leonard Bildstein Sierra Club 61 E-mail ML110680455

Cate Renner Sierra Club 62 E-mail ML11116A124

Karen Hansen Sierra Club 63 E-mail ML110680529

Natalie Schafrath Sierra Club 64 E-mail ML110680532

Kathleen Bodnar Sierra Club 65 E-mail ML110680350
Appendix A

A-5 

Commenter Affiliation (If Stated) ID Comment Source

ADAMS Accession 

Number

Margaret Holfinger Sierra Club 66 E-mail ML110680350

Ben Shapiro Sierra Club 67 E-mail ML110680350

Susan Jones Sierra Club 68 E-mail ML110680453

Leslie Stansbery Sierra Club 69 E-mail ML110680528

Stephen & Connie 

Caruso Sierra Club 70 E-mail ML110680525

Robert Kyle Sierra Club 71 E-mail ML110680350

Andy Trokan Sierra Club 72 E-mail ML110680350

Joan DeLauro Sierra Club 73 E-mail ML110680350

Joan Lang Sierra Club 74 E-mail ML110680452

Jim Wagner Sierra Club 75 E-mail ML110680350

June Douglas Sierra Club 76 E-mail ML110680350

Tekla Lewin Sierra Club 77 E-mail ML110680539

Tim Wagner Sierra Club 78 E-mail ML110680350

Virginia Douglas Sierra Club 79 E-mail ML110680350

Mary Beth Lohse Sierra Club 80 E-mail ML110680350

George M. Williams Sierra Club 81

E-mail ML110680449

E-mail ML110680454

Donna Emig Sierra Club 82 E-mail ML110680350

Liz Loring Sierra Club 83 E-mail ML110680350

Lance Wilson Sierra Club 84 E-mail ML110680350

Mike Fremont Sierra Club 85 E-mail ML110680523

Nick Mellis Sierra Club 86 E-mail ML110680350

Paul Wojoski Sierra Club 87 E-mail ML110680350

Linda Milligan Sierra Club 88 E-mail ML110680350

Elisa Young Sierra Club 89 E-mail ML110680350

Matt Trokan Sierra Club 90 E-mail ML110680350

1 In order to evaluate the comments, the NRC staff gave each comment a unique identification 

2 code that categorizes the comment by technical issue and allows each comment or set of 

3 comments to be traced back to the commenter and original source (transcript, video recording, 

4 letter, or e-mail) from which the comments were submitted.

5 Comments were placed into one of 17 technical issue categories, which are based on the topics 

6 that will be contained within the staff’s supplemental environmental impact statement (SEIS) for 

7 Davis-Besse, as outlined by the GEIS. These technical issue categories and their abbreviation 

8 codes are presented in Table A-2. 
Appendix A

A-6 

1 Table A-2. Technical Issue Categories

2 Comments were divided into one of the 17 categories below, each of which has a unique 

3 abbreviation code.

Code Technical Issue

AL Alternative energy sources

AM Air & meteorology

AQ Aquatic resources

CI(a) Cumulative impacts

CR Cultural resources

HH Human health

HY Hydrology

LR License renewal & its process

LU(a) Land use

NO(a) Noise

OL Opposition to license renewal

OS Outside of scope(b)

PA Postulated accidents & SAMA

RW Radioactive & non-radioactive waste

SE Socioeconomics

SL Support of license renewal

TR Terrestrial resources

(a) No comments specific to the categories of cumulative impacts, land use, or noise were submitted during the Davis-Besse 

scoping period.

(b) Outside of scope are those comments that pertain to issues that are not evaluated during the environmental review of license 

renewal and include, but are not limited to, issues such as need for power; emergency preparedness; safety; security; terrorism; 

and spent nuclear fuel storage and disposal.

4 Comments received during scoping applicable to this environmental review are presented in this 

5 section along with the NRC response. They are presented in the order shown in Table A-3. The 

6 comments that are outside the scope of the environmental review for Davis-Besse are not 

7 included here but can be found in the scoping summary report, which can be accessed through 

8 the Agencywide Documents Access and Management System (ADAMS), Accession 

9 No. ML11168A197. 
Appendix A

A-7 

1 Table A-3. Comment Response Location in Order of Resource Area

Comment Category Page 

Alternative Energy Sources (AL) 7

Air & Meteorology (AM) 19

Aquatic Resources (AQ) 20

Cultural Resources (CR) 23

Human Health (HH) 23

Hydrology (HY) 29

License Renewal and its Process (LR) 32

Opposition to License Renewal (OL) 37

Postulated Accidents & SAMA (PA) 42

Radioactive & Non-Radioactive Waste (RW) 43

Socioeconomics (SE) 47

Support of License Renewal (SL) 50

Terrestrial Resources (TR) 51

2 A.1.1 Alternative Energy Sources (AL)

3 Comment: 5-2-AL; Research has shown that nuclear power is clean, is efficient and produces 

4 more energy at a lower cost than any other means of generation. So, it is important that we 

5 keep this plant in operation. 

6 Comment: 11-1-AL; It’s a priority for us as a company because Davis-Besse is a significant 

7 asset to our company. It provides a large source of safe, reliable, environmental friendly 

8 electricity to the surrounding area. 

9 Comment: 12-3-AL; By extending the license here at Davis-Besse, it would continue to provide 

10 good clean power that’s critical. 

11 Comment: 15-3-AL, 15-7-AL; Research has shown that nuclear power is clean, it is efficient 

12 and it produces more energy at a lower cost than any other means of generation. So, it is 

13 important that we keep this plant in operation. 

14 Response: These comments are generally supportive of nuclear power, citing the cleanliness, 

15 efficiency and the cost of electricity. The discussion of alternatives, including license renewal, 

16 are presented in Chapter 8. No new and significant information was found as a result of these 

17 scoping comments and further evaluation was not considered in the development of the SEIS.

18 Comment: 16-6-AL; In Ohio, the use of electricity has been increasing for a number of years. 

19 Now, with progressive legislation and Ohio Senate Bill 221, energy efficiency and conservation 

20 combined with the renewable sources of solar, wind and geothermal, these are providing so 

21 much additional and conserve energy to all plants and new coal plants in our state have been 

22 cancelled, and there’s a strong movement to shut down the old polluting coal-fired plants. 
Appendix A

A-8 

1 Comment: 16-27-AL; In Ohio, the use of electricity has been decreasing for a number of years. 

2 Now with progressive legislation like Ohio’s SB 221, energy efficiency and conservation, 

3 combined with the renewable sources of solar, wind, and geothermal, are providing so much 

4 additional and conserved energy that all plans for new coal plants in our state have been 

5 cancelled and there is a strong movement to shut down the old polluting coal-fired plants. The 

6 argument of US rising energy needs is irrational at best and at worst the resulting global 

7 warming would threaten our life-support system, and yes, our “way of life.” 

8 Comment: 20-1-AL; One of the things that I think is important to keep in mind is that First 

9 Energy and Davis-Besse provides about 8.3% of First Energy’s baseload power generation, so 

10 that’s important to recognize in terms of the alternatives. Now, in Ohio, Senate bill 221, which 

11 was passed in the spring of 2008, mandates for the investor-owned utilities that they should, 

12 achieve a higher efficiency by reducing demand by 2025 by 22%, a much larger number than 

13 the 8.3%, generation that’s provided by Davis-Besse. And in addition, achieve 12 1/2% 

14 generation from renewals by 2025 and another 12 1/2% generation from so-called advanced 

15 energy, which may include new, new advanced nuclear, but continuation of Davis-Besse would 

16 not qualify for that additional gen..., for that 12 1/2%. Distributed generation will also qualify for 

17 a, a credit under the Senate bill 221. And alternative sources are very attractive for...wind, as 

18 Kevin mentioned, and also solar. 

19 Comment: 20-7-AL; It may be done by advanced nuclear, and that’s requiring NRC 

20 Generation III. Davis-Besse, I believe, is Generation II technology, but Generation III 

21 incorporates a passive safety systems. So even if the power goes out, such as when the 

22 tornado came through and disconnected the power plant from its emergency diesel generators,

23 there would be passive safety equipment in the Gen-II, Gen-III design. And the Gen-III design 

24 would be for 60 years of operation instead of 40 years. 

25 Comment: 22-9-AL; Here are a few suggestions. In the year 2021, Senate bill 221 will 

26 eliminate or generate as much power as Davis-Besse produces. If First Energy takes seriously 

27 the opportunities available for generating power through energy efficiency and making 

28 agreements for a better payoff for exceeding the energy efficiency targets the Senate bill 221 

29 mandates, they can be more profitable without Davis-Besse. If they take an aggressive look at 

30 the potential of combined heat and power, wind, compressed air storage, solar, they can 

31 generate either through efficiency or through greater uses of existing resources, the needed 

32 capacity that the loss of Davis-Besse will create. There are solution for generating capacity. 

33 For every one cent invested in elec...in energy efficiency, three cents profit is gained. the 

34 solutions and incentives...alternative to the continuation of nuclear power to the elimination of 

35 nuclear power are already out there. 

36 Response: The comments are in general support of alternative energy production sources and 

37 reference The Ohio Senate Bill 221 as legislative support for renewable energy sources. The 

38 comments also represent a general opposition to nuclear energy.

39 The Ohio Senate Bill (Am. Sub. S. B. No. 221) passed through the Ohio House of 

40 Representatives on Tuesday, April 22, 2008, and it passed through the Ohio Senate on 

41 Wednesday April 23, 2008, the effective date of the bill was July 31, 2008.

42 The bill focuses on energy pricing and sources. The pricing of electricity is outside the scope of 

43 the environmental review and is not discussed further in the SEIS. According to the bill analysis 

44 published by the Ohio Legislative Service Commission, the primary points of the bill, as it relates 

45 to energy sources, are as follows: 
Appendix A

A-9 

1 • requires an electric distribution utility and an electric services company to provide a 

2 portion of their electricity supplies from alternative energy resources

3 • defines alternative energy resources as consisting of specified advanced energy 

4 resources and renewable energy resources with a placed-in-service date of 

5 January 1, 1998, or later, and as consisting of existing or new mercantile customer-sited 

6 resources

7 • specifies that the requisite portion of the electric supply derived from alternative energy

8 sources must equal 25 percent of the total number of kilowatt hours of electricity sold by 

9 the utility or company to any and all retail electric consumers whose electric load centers 

10 are served by the utility and are located within the utility’s certified territory or, in the case 

11 of an electric services company, are served by the company and are located within Ohio

12 • provides that half of the alternative energy can be generated from advanced energy 

13 resources, but at least half must be generated from renewable energy resources, 

14 including 0.5 percent from solar energy resources, subject to yearly, minimum, 

15 renewable and solar benchmarks that increase as a percentage of electric supply 

16 through 2024

17 • authorizes the Public Utilities Commission of Ohio (PUCO) to enforce the renewable 

18 energy and solar energy resource benchmarks through the assessment of compliance 

19 payments

20 • prescribes energy savings and peak demand reduction requirements for electric 

21 distribution utilities through 2025, sets yearly benchmarks, and authorizes PUCO 

22 enforcement of compliance through the assessment of forfeitures

23 • authorizes the PUCO to approve a revenue decoupling mechanism for an electric 

24 distribution utility if it reasonably aligns the interests of the utility and of its customers in 

25 favor of energy efficiency or energy conservation programs

26 • requires the PUCO, to the extent permitted by Federal law, to adopt rules establishing 

27 greenhouse gas (GHG) emissions reporting and carbon dioxide control planning 

28 requirements for each electric generating facility located in Ohio that is owned or 

29 operated by a public utility that is subject to PUCO jurisdiction and that emits GHGs, 

30 including facilities in operation on the act’s effective date

31 The NRC staff is aware of Senate Bill 221 and incorporated information about the legislation into 

32 its own alternatives analysis. State regulatory agencies and FirstEnergy Nuclear Operating 

33 Company (FENOC) will ultimately decide whether the plant will continue to operate based on 

34 factors such as the need for power or other matters within the State’s jurisdiction or the purview 

35 of the owners. Alternatives are discussed in Chapter 8, “Alternatives,” of this SEIS; they include 

36 conservation (demand-side management) and renewable energy sources such as wind and 

37 solar energy.

38 Comment: 16-8-AL; There is good reason why there are no nuclear power plants coming on 

39 line to replace the old ones. Wall Street will not support them. The normal up-front cost and a 

40 12- to 20-year length of time for completion makes it financially uncompetitive with wind and 

41 solar. On the latter, decentralize, meaning that jobs are being created all over the state. As 

42 compared to Davis Besse’s extended shut-downs, if the wind stops blowing or the sun is behind 

43 a cloud, somewhere, it is likely not too serious or a long-term power shortage problem. 
Appendix A

A-10

1 Comment: 16-20-AL; We are closing down Coal plants now because Ohio is actually using 

2 less electricity than they used to. We’ve got efficiency we’ve got solar we have wind we have 

3 geothermal we have all kinds of sustainable ways. 

4 Comment: 19-11-AL; And, there was another, license extension, that I wanted to mention, 

5 that’s being challenged. I brought some things to look at over here, some old posters from 

6 Seabrook New Hampshire, in the mid-1970s. you know, fifteen hundred people got arrested on 

7 a single day in 1977 trying to block the construction of Seabrook. Well, Seabrook has gone for 

8 a 20-year license extension and they’ve gone for it 20 years early, incredibly. They’re only 

9 20 years old. They have 20 more years on their license, and they’ve asked for a 20-year 

10 license extension. So Paul Gunter, my coworker, has challenged this 20-year early application, 

11 and his main challenge is the wind power potential off the gulf of Maine, which is tremendous. 

12 So showing that wind power is a great alternative. And, I’ll just close now, by saying that the 

13 wind power potential of the Great Lakes is there. That will be one of our contentions against 

14 Davis-Besse for 20 more years. And add to that solar potential, with the biggest solar panel

15 manufacturing factory in the country right here in Toledo. Add to that the efficiency potential, 

16 and there’s no need for 20 more years of radioactive Russian roulette on the Lake Erie 

17 shoreline. Thank you Very much. 

18 Comment: 20-6-AL; But we, should also know that there are some very good alternatives for, 

19 generating electricity, and one of those normally not thought about as generation, but it’s energy 

20 conservation. And that is now widely accepted as the cheapest way to get more effectively, to 

21 get more energy, it’s to use our energy more, more wisely. And then there’s a very strong wind 

22 resources and solar resources. So, the important thing that, we need to recognize is that, is that 

23 these components, energy conservation, wind and solar, are already mandated by Senate bill 

24 221 in the state of Ohio. And, windmills are, used by the, the publicly-owned, utilities, they are 

25 allowed by Ohio law to pass through, to pass those costs on to the customers, so, on to the 

26 consumers of the electricity. That, that might not have been my favorite way of doing it, but 

27 that’s the way, the legislators have decided in the Public Utility Commission of Ohio. 

28 Comment: 20-9-AL; So, let’s take a little bit closer look at the resources that are available for 

29 wind. Lake Erie and the Lake Erie shore, as well as all of the Great Lakes, are great resources 

30 for, for wind energy. So, I, I’m showing here this, wind energy map. This is for the average 

31 wind power across the United States. And it may be hard to see from there, but, we hear a lot 

32 about the, the wind corridor in the Great Midwest, from Texas through to North Dakota. That’s 

33 this, region of the Great Plains. But now, the wind, resources in...increase, the average wind 

34 power increases as you go from white, actually the key is down here, from white to the light blue 

35 to the darker blue and still darker, and you can see that, Ohio, for the most part, has a lot of 

36 wind resources that are similar to Texas. We hear about Texas because it has the most wind 

37 power of any of the any of the states. And Ohio has similar resources. But if you look at, in 

38 Lake Erie and on the near shore and, up to the border with Canada, you can see it’s a very dark 

39 blue, and that’s similar to some of these mountain passes here. So wind, resource availability in 

40 Lake Erie is really, really prime. much higher than almost any of the places in, in Texas, for 

41 example. So that’s an indication that there really are tremendous resources out there and wind 

42 power is very competitive in terms of, rates for electricity generated by wind power. The big, let 

43 me just back up...One of the big issues with Texas, which is now struggling with getting the 

44 power, of course they have some major cities, but they can generate more than what can be 

45 used in their cities, is how you are going to get the power out to the big metropolitan areas like 

46 Chicago and Cleveland and Toledo and so on, and Detroit. That is not a problem when you 

47 generate the power in Lake Erie, we have a lot of major metropolitan areas that are very nearby. 
Appendix A

A-11

1 Comment: 20-10-AL; For solar, Ohio has, actually very good solar isolation as well. and I 

2 want to point out that in this, in this Environmental Report, that’s part of the First Energy petition 

3 for the renewal, there are some errors in that, in that report. For example, they, they say that 

4 the amount of sunlight in Ohio is less than half of what it is in some of the best areas in the 

5 country. that’s a bit of a, an error and I’ll point out why in just a moment. And then, they also 

6 used some data for the costs, which came from back in 1988, and the costs for solar 

7 photo-voltaic electricity has come down dramatically since 1988. One of the mistakes that is 

8 commonly, made when you think about solar, is you think about being able to see a sun, the 

9 sun in a clear day. And you think, you think, that, well, it’s only on those clear days that 

10 photo-voltaics will generate usable power. And this is the kind of map that you would use if you 

11 were really worried only about direct sunlight, being able to have a clear sky, and being able to 

12 see a clear sun out there. And then when you take and you compare Toledo or, or Lake Erie 

13 with some areas in the Southwest, and I did the numbers here. actually, for the...for the South. 

14 when you compare Toledo with Orlando, even when you consider only direct sunshine, Toledo 

15 gets 75% of what Orlando does, down here in Florida. But it’s not as good as San Diego, it’s 

16 almost 60% of San Diego, >>>. and if you go out to the Mojave Desert, Toledo gets about 

17 45%. So that’s a number that’s consistent with what, First Energy claimed in that report. 

18 However, the real data that you need to look at are the, us, the full sky radiation. The point 

19 of...Most solar panels are flat panels and they will accept light which is indirect, that is, as it 

20 comes scattered in hazy days or light cloudy days and light is scattered from those clouds and 

21 still make it to those panels. And so this is the appropriate math that needs to be looked for, the 

22 amount of electricity that can be produced by solar panels over the years. So, in that case, if 

23 you compared Toledo with Orlando, or Toledo with San Diego, Toledo gets 86% of what,

24 Orlando gets, 79% of what Sand Diego gets. So the argument that the solar resources in Ohio, 

25 in Northern Ohio, are not very good, and actually you can see that the best resources here are 

26 Western Ohio and in certain...that’s an argument that doesn’t, work when you address solar. 

27 And that last point that I’d like to make about solar is that there are huge changes that have 

28 been happening in the last several years in terms of the costs of solar panels. And the cost 

29 driver on this is actually FirstEnergy, First Solar, sorry, First Solar, which is, started here in 

30 Toledo, by Toledo industrialists such as Harold, Harold McMaster, and our only US generating, 

31 US manufacturing facility is in Perrysburg. 

32 Comment: 20-12-AL; Energy conservation, retro-fitting of homes and businesses and so with 

33 the more energy-efficient lights, and motors, and thermal efficiency saves, saves, save energy 

34 for everyone. It reduces the need for, generating capacity. Ohio has a lot of manufactures that 

35 supply components for wind turbines. The maintenance of wind turbines generates many jobs. 

36 I’ve already mentioned, First Solar is the largest manufacturer in the world. So manufacturing 

37 creates jobs. And there are several other PV manufacturers that are beginning, in Ohio, most of 

38 them actually in northwest Ohio, in the Toledo area. PV design and insulation creates a num...a 

39 large set of jobs. 

40 Comment: 21-2-AL; So what I have done is done some statistical modeling using systems that 

41 are already in place here in northwest Ohio. I used one of the wind turbines in Bowling Green, 

42 owned by Bowling Green municipalities, and a solar array mounted on the home of Professor

43 Compaan. This model is a little bit confusing. What it is here is on the X axis we have the 

44 volatility or the intermittency of the system that FirstEnergy mentioned. So what that means is 

45 that at some points throughout the day it can be high, it can be low. It’s unexpected, the power 

46 production that would be produced. On here [indicating the Y axis] it’s the actual output of the 

47 system. So along our curve here we have an entire wind, only wind system, and at the other 

48 end we have only solar. And, along the middle is a combination of the two. what I’m going to 

49 show you today is that it’s not a matter of using one or the other. The combination of these 
Appendix A

A-12

1 different forms of renewable energy that’s really going to help us offset the loss of nuclear power

2 by closing Davis-Besse. So over here on the end of the curve is where we have the least 

3 volatility in the system. For this specific northwest Ohio that turned out to be about half wind 

4 and half solar that’s going to produce the best outcome for us. Just an example here of what I 

5 mean by this. So in a 100% wind system has a volatility something like this. This is the power 

6 production over the course of the week by the Bowling Green wind turbine. you can see it’s 

7 pretty unexpected what it’s going to produce throughout the day. And on the opposite end, a 

8 100% solar system, follows a pattern, you only get power production during the day, but even 

9 throughout the day you not sure if you’re going to get a sunny day, cloudy day things like that re 

10 unexpected...So, by optimizing the system, using similar rating, say one megawatt wind turbine 

11 farm and one megawatt solar array, you get something that’s quite a bit more predictable. Now 

12 put this here against a demand curve. This is from EBCOT it’s in Texas, but the demand curve 

13 for any big city is gonna look about the same. A lot of high peaks during the afternoon, evening 

14 hours and lower at night time when we’re sleeping. It’s quite a bit more predictable, it follows 

15 the demand curve. What I want to point out here, though is that my graph is still quite a bit 

16 volatile here, but it’s only taking into consideration two specific sites. We only have one wind 

17 turbine and one solar array. But, if FirstEnergy were to take their resources and erect, um sorry, 

18 use the wind and solar throughout their entire area that they service. Solar, it’s not going to be 

19 cloudy in all the areas that they service. That’s exactly what the (Go to my summary slide, here) 

20 European Wind Energy Association in their annual report in 2009. They said exactly that. That 

21 as wind and solar is developed across the entire area, the volatility in one specific area does not 

22 infect the overall baseload that it’s generating. That’s another thing I’d like to point out in 

23 FirstEnergy’s application for Renewal, they kept mentioning that solar and wind are not a good 

24 replacement because they can’t satisfy a baseload. But, as Dr. Compaan mentioned in his 

25 speech, Davis-Besse only produces 8.3% of FirstEnergy’s baseload. So, we’re not trying to 

26 make these curves fit identical. It just has to back up the coal and everything else that’s already 

27 being produced. So we’re using a combination of wind, solar and all the other technologies that 

28 are out there. They’ll be able to easily offset the production lost by Davis-Besse. 

29 Comment: 23-4-AL; The second article I refer is the November, 2009 cover story in Scientific 

30 American. I bought this issue and bring it with me to almost everything I go to. This article is 

31 entitled “A Plan for Sustainable Future. How to Get All Energy from Wind, Solar and Water by 

32 2030 using Present Technology.” The article by Mark Z. Jacobsen of Stanford University and 

33 Mark A. Delucchi of University of California, Davis it is describe by the editors of Scientific 

34 American as a “pragmatic hard headed study.” Supply 100% clean energy by 2030 at the same 

35 or lower cost of traditional fossil and nuclear resources. Frankly, I’m amazed by this article. 

36 This is something, I think, we’ve been waiting for, and something we should push. 

37 Comment: 25-4-AL; We should come up with energy conservation and efficiency measures 

38 that replace that 8.3%. Forget creating any alternative fuels or advanced nuclear. Just energy 

39 in energy conservation efficiency alone, we make up for this. The system that requires that we 

40 maintain the amount of consumption that we currently have as part of the licensure relicensure 

41 application is absurd because so much of the future depends on our reduction of and our 

42 conservation and our efficient use of energy. It’s absurd to perpetuate the existing system. 

43 Comment: 31-3-AL; There are so many other clean ways to provide energy. Wind Solar 

44 geothermal there is no reason to bring a nuclear plant online. There would have to be some 

45 other agenda involved we hope that is not military agenda. But we know that we don’t the 

46 electricity from that plant in this state. 
Appendix A

A-13

1 Comment: 35-2-AL; I believe we should be going in different directions when it comes to 

2 supplying energy to our communities. Direction that is not destructive that can provide new 

3 green jobs. Thank you. 

4 Comment: 36-2-AL; It is located there on the great lakes, the largest clean water source in the 

5 world and it seems extremely dangerous and unnecessary

6 Comment: 39-3-AL; We need to invest our money into green technologies that would create 

7 job and also help our economy which is leaving the toxic legacy for our children as well as these 

8 nuclear power plants. 

9 Comment: 41-1-AL; I wish to join the wave of the future. Which is alternative energy sources. 

10 Fossil fuels and nuclear energy are part of the past. 

11 Comment: 30-4-AL, 34-6-AL, 39-9-AL, 43-7-AL, 44-5-AL, 50-4-AL, 51-4-AL, 53-4-AL, 

12 54-4-AL, 57-4-AL, 58-4-AL, 59-4-AL, 60-4-AL, 62-4-AL, 65-4-AL, 66-4-AL, 67-4-AL, 69-4-AL, 

13 70-4-AL, 71-A-AL, 72-4-AL, 73-4-AL, 74-4-AL, 75-4-AL, 76-4-AL, 77-4-AL, 78-4-AL, 79-4-AL, 

14 80-4-AL, 81-4-AL, 81-9-AL, 82-4-AL, 83-4-AL, 84-4-AL, 85-4-AL, 86-4-AL, 87-4-AL, 88-4-AL, 

15 89-4-AL, 90-4-AL; I do not want Davis-Besse to continue generating electricity and want the 

16 Nuclear Regulatory Commission to end the operating license for the plant. I care about the 

17 environment and support clean energy solutions such as energy efficiency and renewable 

18 power, and I know that Davis-Besse compromises my safety and the safety of my loved ones. 

19 Comment: 55-4-AL; I do not want Davis-Besse to continue generating electricity and want the 

20 Nuclear Regulatory Commission to end the operating license for the plant. I care about the 

21 environment and support clean energy solutions such as energy efficiency and renewable 

22 power, and I know that Davis-Besse compromises my safety and the safety of potentially 

23 everyone that lives in the entire Midwest. The risk is unacceptable.

24 Comment: 52-4-AL; I do not want Davis-Besse to continue generating electricity and want the 

25 Nuclear Regulatory Commission to end the operating license for the plant. I care about the 

26 environment and support clean energy solutions such as energy efficiency and renewable 

27 power, and I know that Davis-Besse compromises my safety and the safety of my loved ones. 

28 This concerns me much.

29 Comment: 68-4-AL; I do not want Davis-Besse to continue generating electricity and want the 

30 Nuclear Regulatory Commission to end the operating license for the plant. I care about the 

31 environment and support clean energy solutions such as energy efficiency and renewable 

32 power, and I know that Davis-Besse compromises my safety and the safety of my loved ones. 

33 So Please stop the relicense of this very dangerous power plant it is not worth risking the lives 

34 of millions of people for energy when there are safer and cheaper options out there.

35 Comment: 61-4-AL; I do not want Davis-Besse to continue generating electricity and want the 

36 Nuclear Regulatory Commission to end the operating license for the plant. I care about the 

37 environment and support clean energy solutions such as energy efficiency and renewable 

38 power, and I know that Davis-Besse compromises my safety and the safety of my loved ones. 

39 This plant has the worst safety record in the U.S.A. and should be closed! You have no right to 

40 continue operating this unsafe plant. We have two coal plants in the area that produce more 

41 than enough electricity for this area and are safe!

42 Comment: 63-4-AL; There have been too many near-disasters at this plant. This, because of 

43 its proximity to the Great lakes, is unconscionable! To continue to put resources into this risky 
Appendix A

A-14

1 plant and to continue to endure the toxic side effects is insane! We should be putting all our 

2 energy investments into clean, safe, green alternatives, and that does NOT include nuclear 

3 power!

4 Comment: 64-4-AL; It’s high time we step up our efforts to help protect the future generations 

5 by doing what we can to ensure a safe environment for species diversity. We cannot live in this 

6 world without being connected to the web of life that exists in every ecosystem. The nuclear 

7 waste generated from this plant would not only effect ourselves, and our children, but every 

8 species that struggles to survive as well. As someone who is SUPPOSE to represent the 

9 demands on their constituents I hope it is clear to you that Ohioans DON’T AGREE with this 

10 form of energy!

11 Comment: 56-4-AL; The Davis-Besse power plant must stop generating electricity and the 

12 Nuclear Regulatory Commission must end the operating license for the plant. In 2002, the 

13 Davis-Besse plant nearly melted down almost causing a nuclear disaster. Neither First Energy 

14 nor the Nuclear Regulatory Commission discovered an enormous rust hole in the reactor head 

15 until it was almost too late! According to the Nuclear Regulatory Commission, 2 of the top 5 

16 most dangerous nuclear incidences since 1979 have happened at Davis-Besse. Nuclear power 

17 has too many problems from waste to extreme expense to oversight. This is not an 

18 environmentally sound solution. I support clean energy solutions such as energy efficiency and 

19 renewable power, and I know that Davis-Besse compromises my safety and the safety of my 

20 loved ones. Nuclear power uses and pollutes significant amounts of water, while the mining, 

21 transportation, and enriching of uranium is carbon intensive which contributes to global 

22 warming.

23 Comment: 85-4-AL; I do not want Davis Besse to continue generating electricity and want the 

24 Nuclear Regulatory Commission to end the operating license for the plant. I care about the 

25 environment and support clean energy solutions such as energy efficiency and renewable 

26 power, and I know that Davis Besse compromises my safety and the safety of my loved ones. 

27 In the early 80s Cincinnati’s Zimmer Nuclear Plant was adjudged, according to the Wall Street 

28 Journal, to be the worst-built nuke plant in the U.S., for a number of reasons, one being that 

29 much of the crucial reactor steel was bought from a local scrap dealer. It could have ruined the 

30 Ohio River downstream from Cincinnati all the way to New Orleans. Davis-Besse could wreck 

31 Lake Erie and quite a land area around Toledo. Save us from that! We can do it cheaper, safer 

32 and cleaner with windmills in the lake.

33 Response: These comments relate to the use of renewal sources of energy as an alternative 

34 to nuclear power. The NRC staff evaluated reasonable alternatives in Chapter 8, “Alternatives.” 

35 In this chapter, the staff examines the potential environmental impacts of alternatives to license 

36 renewal for Davis-Besse, as well as alternatives that may reduce or avoid adverse 

37 environmental impacts from license renewal and when and where these alternatives are 

38 applicable.

39 In evaluating alternatives to license renewal, the NRC staff first selected energy technologies or 

40 options currently in commercial operation, as well as some technologies not currently in 

41 commercial operation but likely to be commercially available by the time the current 

42 Davis-Besse operating license expires in 2017. Second, the NRC staff screened the 

43 alternatives to remove those that cannot meet future system needs. Then, the NRC staff 

44 screened the remaining options to remove those whose costs or benefits do not justify inclusion 

45 in the range of reasonable alternatives. The remaining alternatives, constituted comprise the 

46 alternatives to the proposed action that the NRC staff evaluated in-depth in this Chapter 8 of the 
Appendix A

A-15

1 SEIS. The NRC staff considered 17 energy technology options and alternatives to the proposed 

2 action and then narrowed to the three alternatives considered.

3 The alternatives evaluated in-depth include the following: 

4 • natural-gas-fired combined-cycle (NGCC); 

5 • combination alternative (wind, solar, NGCC, and compressed air energy storage); and 

6 • coal-fired power. 

7 Other alternatives considered, but not evaluated further, are listed below:

8 • wind power, 

9 • wind power with compressed air energy storage, 

10 • solar power, 

11 • solar power with compressed air energy storage, 

12 • wood waste, 

13 • conventional hydroelectric power, 

14 • ocean wave and current energy, 

15 • geothermal power, 

16 • municipal solid waste (MSW), 

17 • biofuels, 

18 • oil-fired power, 

19 • fuel cells, 

20 • energy conservation and energy efficiency, and

21 • purchased power. 

22 The NRC staff’s alternatives analysis also involved consideration of combinations of alternatives 

23 including renewable technologies and conventional baseload technologies, as well as options 

24 not involving new generation capacity such as purchased power and conservation measures.

25 Comment: 20-11-AL; They’ve been, leading the cost reductions. So if you look here, this is a 

26 study that was done by Deutsch Bank and updated in 2009. It doesn’t go back, to 1998, which 

27 is when, when First Energy pulled their numbers, but, you can, you can extrapolate back further 

28 if you want. There, it was something on the order of 40 cents/kilowatt-hour for the levelized cost 

29 of electricity, as it’s called. but in 2010, the cost is about 20 centers/kilowatt-hour for cadmium 

30 telluride. This is, this is the type of material in the panels that are made by First Solar. Some of 

31 the other kinds of solar panels are shown here, a little bit higher in cost. But what Deutsch Bank 

32 projected is that there’s going to be a crossover, a convergence between the cost of 

33 solar-generated electricity, as you go out here to, what is the number, it’s like 2017 or so, so, 

34 2017, at about the time when, when FirstEnergy wants to extend the license on the plant, solar 

35 is going to be, completely competitive, if not lower cost than, the electricity, than the 

36 conventional electricity. Notice that Deutsch Bank is using an average over the United States. 

37 Now the cost of electricity in the FirstEnergy territory is actually higher, those of you who live in 

38 FirstEnergy territory, your home costs, your home electricity costs are something like 12 or 

39 12 1/2 cents/kilowatt-hour, so the curve for us should really start a little bit higher, and that 

40 convergence will happen even sooner. So First Energy has the option of extending, a nuclear 

41 generating plant with all of its associated dangers and also its costs. The cost of nuclear 

42 generated power is high, higher than most of the baseload, generating capacity of FirstEnergy. 

43 And its costs is continuing to increase. The alternative is to jump on some of the new 

44 technology, jump on those bandwagons, and those costs are decreasing. So that’s the kind of 

45 options that FirstEnergy has, and you’d think that if they really look at it seriously and look at the 
Appendix A

A-16

1 options that they ought to conclude, that some of these alternative forms of electricity are the 

2 ones that ought to be, the ones, that are developed for the long-term future of their, of their 

3 company. So, just to make one final point, and that is alternative, alternative energy resources 

4 generate lots of jobs. They actually generate, many more jobs than what nuclear power does. 

5 Comment: 16-28-AL; There is good reason why there are no new nuclear power plants 

6 coming online to replace the old ones. Wall Street will not support them. The enormous 

7 up-front costs and 12-20 year length of time for completion makes them financially 

8 uncompetitive with wind and solar. And the latter are decentralized, meaning that jobs are 

9 being created all over the state. As compared to Davis Besse’s extended shutdowns, if the 

10 wind stops blowing or the sun is behind a cloud somewhere, there is likely not to be a serious or 

11 long-term power shortage problem. 

12 Response: These comments oppose nuclear power based on the costs associated with 

13 construction and operation when compared to other alternative sources of power. The 

14 regulatory authority over licensee economics falls within the jurisdiction of the states and, to 

15 some extent, the Federal Energy Regulatory Commission (FERC). The proposed rule for 

16 license renewal included a cost-benefit analysis and consideration of licensee economics as 

17 part of the National Environmental Policy Act (NEPA) review. However, during the comment 

18 period, state, Federal, and licensee representatives expressed concern about the use of 

19 economic costs and cost-benefit balancing in the proposed rule and the GEIS. They noted that 

20 the President’s Council on Environmental Quality (CEQ) regulations interpret NEPA to require 

21 only an assessment of the cumulative effects of a proposed Federal action on the natural and 

22 man-made environment, and the determination of the need for generating capacity has always 

23 been the states’ responsibility.

24 For this reason, the purpose and need for the proposed action (i.e., license renewal) is defined 

25 in the GEIS as follows:

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

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

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

29 generating needs, as such needs may be determined by state, licensee, and, 

30 where authorized, Federal (other than NRC) decisionmakers.

31 Title 10 of the Code of Federal Regulations, Section 51.95(c)(2) (10 CFR 51.95(c)(2)) states the 

32 following: 

33 The supplemental environmental impact statement for license renewal is not 

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

35 economic benefits of the proposed action except insofar as such benefits and 

36 costs are either essential for a determination regarding the inclusion of an 

37 alternative in the range of alternatives considered or relevant to mitigation.

38 The NRC staff identified feasible technologies in the GElS, and the staff will use information in 

39 the GEIS, updating it as necessary to reflect recent technological advancements, as the basis 

40 for its alternative analysis. Since 1996, many energy technologies have evolved significantly in 

41 capability and cost, while regulatory structures have changed to either promote or impede 

42 development of particular alternatives, of this SEIS. 

43 As a result, the analyses include updated information from the following sources:
Appendix A

A-17

1 • Energy Information Administration (EIA), 

2 • other offices within the Department of Energy (DOE), 

3 • U.S. Environmental Protection Agency (EPA), 

4 • industry sources and publications, and

5 • information submitted by the applicant in the FENOC Environmental Report (ER). 

6 The result of this analysis provided for three in-depth alternatives—Natural-gas-fired 

7 combined-cycle (NGCC), combination alternative (wind, solar, NGCC, and compressed air 

8 energy storage), coal-fired power. The details of this analysis can be viewed in Chapter 8, 

9 “Alternatives.” 

10 Comment: 21-1-AL; Hello everybody, my name is Katie Hopeful, student of Professor 

11 Compaan’s at the University of Toledo. I’m a major in physics. My research is in this renewable 

12 energy area. So, what I’m going to be talking about today is alternatives to nuclear power. In 

13 FirstEnergy’s license renewal application, they dismissed the possibility of almost any form of 

14 renewable energy to replace the power production that would be lost by the closing of 

15 Davis-Besse. 

16 Response: This comment questions FENOC’s evaluation of alternatives to relicensing 

17 Davis-Besse contained in the ER. The requirements associated with the analysis of alternatives 

18 for FENOC’s ER are based on NRC regulations.

19 Section 51.43(c) of 10 CFR states the following: “Analysis. The Environmental Report must 

20 include an analysis that considers and balances the environmental effects of the proposed 

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

22 available for reducing or avoiding adverse environmental effects...”

23 The acceptance review determines whether the application contains sufficient information to 

24 allow the NRC staff to proceed with the environmental review. On October 18, 2010, the NRC 

25 staff determined that the application was complete and acceptable for docketing, in accordance 

26 with 10 CFR 51.43. The acceptance of the application shows that the applicant met the 

27 regulatory requirements, but it does not reflect the opinion of the NRC in the selection of 

28 alternatives. The NRC conducts an independent review of alternatives, selected based on the 

29 technical experience of the agency, in accordance with NEPA. This review is documented in 

30 Chapter 8 of this SEIS. In contrast to the Davis-Besse ER, Chapter 8 reflects analysis in depth 

31 of a combination alternative that includes renewable energies.

32 Comment: 21-3-AL; the only other thing that I was wanting to mention is the jobs that are 

33 going to be created. As he had already mentioned, the maintenance of the wind turbines; the 

34 installation of the protects; and also the forecasting that can be done. This was also mentioned 

35 in the European Wind Energy Association’s annual report. The new technologies. They are 

36 able to forecast four hours ahead exactly what the wind speeds are going to be. So that they 

37 can predict if they need to have boost up the coal or other forms of production. It makes it really 

38 a lot more stable. So, this argument of volatility doesn’t quite hold. 

39 Response: This comment relates to the benefit of creating jobs by supporting alternative 

40 energy sources. The NRC regulations at 10 CFR 51.71(d) require that a SEIS consider the 

41 environmental, economic, and technical impacts, and other benefits and costs of the proposed 

42 action and alternatives.
Appendix A

A-18

1 The evaluation of each alternative considers the environmental impacts across seven impact 

2 categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, 

3 (4) ecology, (5) human health, (6) socioeconomics, and (7) waste management.

4 Socioeconomic impacts are defined in terms of changes to the demographic and economic 

5 characteristics and social conditions of a region. For example, the number of jobs created by 

6 the construction and operation of an alternative could affect regional employment, income, and 

7 expenditures. The NRC acknowledges that job creation would result from alternatives. Two 

8 types of job creation would likely result— construction-related jobs (transient, short in duration, 

9 and less likely to have a long-term socioeconomic impact) and operation-related jobs in support 

10 of operations (greater potential for permanent, long-term socioeconomic impacts). Workforce 

11 requirements for the construction and operation of each in-depth alternative were evaluated in 

12 order to measure their possible effects on current socioeconomic conditions. The results of 

13 each analysis are documented in Chapter 8, “Alternatives.” 

14 Comment: 23-2-AL; I would first like to quote excerpts from an article in The Nation magazine 

15 dated February 15, 2010, “The Case for Grade Power.” This is generally referred to as using 

16 waste heat or cogeneration from large facilities of which Ohio has plenty. The article uses Ohio 

17 as an example for this opportunity. The article states that according to an analysis by Recycled 

18 Energy Development, the Libbey Glass Plant in Toledo, the Arselor (unintelligible) Middle 

19 School in Cleveland and the (unintelligible) Chemical Plant in Cincinnati together produces 

20 enough waste heat to produce between 145 and 185 megawatts of additional electricity. The 

21 study also indicates that Ohio has enough cogeneration potential to retire up to 8 nuclear power 

22 plants. According to Oak Ridge National Laboratory this strategy will cost less than half of a 

23 coal plant. 

24 Comment: 23-3-AL; A recent report by Policy Matters of Ohio estimates that recycling 7.7 

25 GigaWatts would require a $10.5 billion investment with a three year payback. This would have 

26 the further effect of making Ohio industries more competitive, more profit, saving both jobs and 

27 the environment. 

28 Response: These comments request the NRC staff to consider cogeneration and energy 

29 recycling as alternatives to license renewal. Cogeneration, also known as combined heat and 

30 power (CHP) is the simultaneous production of both heat and power. Davis-Besse produces 

31 electricity but dispels the waste heat through the cooling water system, as described in Chapter 

32 2. In cogeneration plants, the waste heat (typically in the form of steam) is captured for other 

33 uses such as industrial process requiring steam or district heating or both. District heating 

34 systems that transfer waste heat, in the form of steam, for residential and commercial heating, 

35 are currently in operation in cities such as New York, NY, Detroit, MI, and Boston, MA. 

36 Currently no district heating systems in the U.S. are supplied with nuclear reactors as the steam 

37 source; however, countries such as Russia, the Czech Republic, Slovakia, Hungary, Bulgaria, 

38 and Switzerland have nuclear powered district heating from cogeneration plants.

39 The NRC recognizes that cogeneration plants have the potential to offset power demand. In 

40 July 2008, the Ohio legislature passed Senate Bill 221, which established an energy-efficiency 

41 resource standard that requires electric utilities to implement an Energy-Efficiency and Peak 

42 Demand Reduction Program that will yield a cumulative electricity savings of 22 percent by the 

43 end of 2025, with specific annual benchmarks. Cogeneration can be retrofitted to existing 

44 power plants, and represents an option that states and utilities may use to reduce their need for 

45 power generation capability. The need for power may be determined by state, licensee, and, 

46 where authorized, Federal (other than NRC) decisionmakers. If the renewed license is issued, 
Appendix A

A-19

1 state regulatory agencies and FENOC will ultimately decide whether the plant will continue to 

2 operate based on factors such as the need for power or other matters within the state’s 

3 jurisdiction or the purview of the owners.

4 The NRC did not consider cogeneration specifically as an alternative but did evaluate energy 

5 efficiency and conservation. Further information can be found in Chapter 8, “Alternatives.” 

6 A.1.2 Air & Meteorology (AM)

7 Comment: 16-5-AM; Added together, the disposal to support the industry’s nuclear power also 

8 comes with a heavy carbon price, which means that nuclear power will not address the 

9 pollution, global warming. 

10 Comment: 16-7-AM; The argument of rising energy is irrational at best, and at worst, the 

11 resulting global warming would threaten our life support system and, yes, our way of life. 

12 Comment: 16-26-AM; Enormous amounts of energy go into this process. Added together 

13 along with disposal, these supporting industries cause nuclear power to also come with a heavy 

14 carbon price, which means that nuclear power will not address but will worsen global warming. 

15 Comment: 23-6-AM; It is not carbon free as claimed, and not sustainable. 

16 Comment: 39-2-AM; The process of production of nuclear energy from mining through 

17 disposal of waste is very carbon intensive and would contribute heavily to global warming. 

18 Response: These comments represent concerns about greenhouse gases (GHGs), not 

19 specifically for the operation of the nuclear power plant but generally from impacts from the 

20 entire nuclear fuel cycle. A large number of technical studies, including calculations and 

21 estimates of the amount of GHGs emitted by nuclear and other power generation options, are 

22 available in literature. These studies, however, are inconsistent in their application of full 

23 lifecycle analyses, including plant construction, decommissioning, and resource extraction 

24 (uranium ore, fossil fuel). Almost every existing study has been critiqued, and its assumptions 

25 challenged by later authors. Therefore, no single study has been selected to represent 

26 definitive results in this SEIS. Instead, the results from a variety of the studies are presented in 

27 SEIS Tables 6.2-1, 6.2-2, and 6.2-3 to provide a weight-of-evidence argument comparing the 

28 relative GHG emissions resulting from the proposed Davis-Besse relicensing compared to the 

29 potential alternative use of coal-fired plants, natural gas-fired plants, and renewable energy 

30 sources. The NRC staff provides a more detailed discussion on GHGs in Chapter 6, where

31 comparisons of GHG emissions are presented from a variety of energy generation technologies. 

32 The NRC staff’s analysis of alternatives in Chapter 8 also addresses relative levels of GHG

33 emissions for alternatives.

34 Comment: 14-21-AM; Transformer fires cause unique pollutions such as dioxin. Since the 

35 cause of the 2009 Davis-Besse transformer fire has not been determined, the possibility of 

36 another fire must be considered. The EIS must include the impact of missions created by 

37 transformer fires. 

38 Response: This comment expresses concerns regarding the air pollution created by a 

39 transformer fire and the potential release of toxins as a result of postulated future failures of the 

40 transformer. A polychlorinated biphenyls (PCB) transformer is a transformer that contains PCBs 

41 at concentrations greater than 500 parts per million (ppm). From 1929 through 1979, these 

42 transformers were installed in apartments, residential and commercial buildings, industrial 
Appendix A

A-20

1 facilities, campuses, and shopping centers. PCBs are used in electrical transformers because 

2 of their useful quality as being a fire retardant. 

3 The EPA regulates the use, storage and disposal of PCB transformers in accordance with the 

4 Toxic Substances Control Act (15 USC 2605) promulgated under 40 CFR Part 761. 

5 PCB-contaminated transformers containing between 50 and 499 ppm PCBs are also subject to 

6 EPA’s regulations. Davis-Besse, at the time of construction, had PCB transformers; however, in 

7 1992, FENOC completed a program to eliminate PCB transformers onsite. Information relating 

8 to the transformer fire and air emissions can be found in Chapter 2 of this SEIS. Further 

9 information on the regulation of PCB transformers can be found at 

10 http://www.epa.gov/epawaste/hazard/tsd/pcbs/index.htm. 

11 A.1.3 Aquatic Resources (AQ) 

12 Comment: 14-3-AQ; Another is the possible effect on the seven-billion-dollar fishery in Lake 

13 Erie. Specifically, I think you should look at how the wastewater and how the temperature 

14 effluent from this plant would affect and possibly affect indicia species such is the Asian carp. In 

15 other words, does the operation of Davis-Besse make it more or less likely that indicia species 

16 could come in here and ruin our fishing. 

17 Comment: 22-2-AQ; We need to protect our water resources first from the effects of nuclear 

18 forms of pollution. Lake Erie provides drinking water and other consumptive uses to millions of 

19 people and many different industries in northern Ohio. We rely on Lake Erie for recreation, and 

20 we are entrusted to care for and protect the Lake for future generations as well. They have as 

21 much a right to the use and enjoyment of Lake Erie as our present generation, even if the 

22 comments do not agree. Davis-Besse is one of the greatest threats to the health of our Lake. 

23 Davis-Besse was strategically located on Lake Erie to meet the tremendous needs of 

24 Davis-Besse for water as a coolant. This is great for Davis-Besse but not so good for the Lake. 

25 Davis-Besse uses water from the Lake and spews it back as thermal pollution. Over the years, 

26 this has had consequences for Lake Erie. We have once again had increasing algae problems 

27 for Lake Erie. the growth of lyngbya wollei, a toxic algae, has accelerated over the past few 

28 years along with microcystis. These toxic algae have numerous conditions which contribute to 

29 their growth. One, of course, is the presence of ample amount of phosphorous and nitrogen. 

30 Another ingredient is an abundance of warm water. We have billions of gallons of thermal 

31 pollution from the power plants surrounding Lake Erie. 

32 Comment: 22-3-AQ; studies on water use, fish kills, and the thermal impacts at the bay shore 

33 park land are over 30 years old. The intake for Davis-Besse is in less than 30 feet of water in 

34 the Great Lakes...should have been...in the Great Lakes, in Lake Erie’s shallowest most 

35 biologically productive waters. Davis-Besse uses an estimated 50 million gallons of water a day 

36 which causes fish kills and thermal impacts. While cooling towers at Davis-Besse limit water 

37 use and fish kills with the best available technology, there should be an assessment of water 

38 use and fish kills. This request is made as the number of walleye are declining from an ODNRS 

39 estimate of 80 million about 5 years ago to less than 20 million in 2010. 

40 Comment: 22-5-AQ; If Davis-Besse were to close on schedule, there would be fewer fish killed 

41 and no more warm water discharge. The estimated number of fish that would not be killed is 

42 unknown because there are no counts of fish impingement, that is, fish caught against screens, 

43 and entrainments, fish that go through screens. In assessing whether Davis-Besse should 

44 remain open or closed, an updated, independent analysis of the Davis-Besse water impacts, to 

45 fish impingement and entrainment and thermal impacts using Clean Water Act 316 A and B 
Appendix A

A-21

1 protocol needs to be conducted. If the incremental increase in fish kills and added temperature 

2 to the water in aiding algae growth and in decreasing walleye numbers, the environmental and 

3 economic impact of the fish kills and algae growth should be considered in the requested 

4 re-licensing of Davis-Besse. Furthermore, should the licensing go forward, the license needs to 

5 require periodic impingement and entrainment fish counts and thermal mixing zone plume 

6 impacts on algae growth and water quality. 

7 Comment: 26-9-AQ; In addition, a scoping comment I have is the thermal pollution coming off 

8 the nuclear power plant. It’s about a thousand nine hundred, about nine hundred megawatt

9 facility. That’s close to three thousand megawatts of thermal heat coming off of that. And, as 

10 we’ve seen, Lake Erie is beyond the tipping point when it comes to algal blooms. We are 

11 beyond that point. We have several facilities in the western basin of Lake Erie; several coal 

12 plants, and several nuke plants and the Lake cannot take the load. So I am requesting that the 

13 algal blooms that are occurring on Lake Erie, the lyngbya wollei, which is a toxic algae - - it’s 

14 leading to the eutrophication of Lake Erie, the death of Lake Erie, I am requesting that this 

15 concept of algal blooms be investigated, and thermal pollution from the nuclear power plant be 

16 considered. 

17 Comment: 16-17-AQ; We are also concerned about fish and Lake Erie and the heat coming 

18 out of the plant.

19 Comment: 19-10-AQ; So, just to conclude, I’d like to leave you all with some hope that now 

20 license extensions are being seriously challenged, almost the minute that they’re brought up. 

21 Another one to mention is Indian Point, New York, River Keeper, Hudson River Keeper headed 

22 by Bobby Kennedy Junior, has seriously challenged the Indian Point license extension. The 

23 State of New York has joined that proceeding. The Attorney General of New York, the 

24 Environmental Department of New York, they are also requiring now Indian Point to install 

25 cooling towers, to lessen the thermal damage to the Hudson River, just like the thermal 

26 damage, the catastrophic destruction of marine organisms going on at these plants that lack 

27 cooling towers. That’s not an issue at Davis-Besse because they have a cooling tower. But as 

28 we raised Fermi III, we add up all the thermal impacts, of all power plants in this neck of the 

29 woods, and all the toxic chemicals they’re releasing, I’m talking nuclear and coal and others. 

30 You got to look at even the thermal impacts going on now, the destruction of the eco-system in 

31 Lake Erie, especially when Fermi III is being proposed. 

32 Comment: 29-1-AQ; Resource Center and talk about the rise in microcystine levels due to the 

33 thermal pollution. And how that. I mean are they aware that did anyone comment on that

34 Comment: 29-2-AQ; Are they aware! That did anyone comment on that for them.

35 Comment: 29-4-AQ; No they don’t. I just wanted to make sure that someone said that to 

36 them. And realize that the microcystine levels are rising. 

37 Response: These comments express concern over the health of Lake Erie. The concerns cite 

38 the presence of nuisance species and thermal pollution in the lake. 

39 The heated effluents of nuclear power plants can cause mortality among fish and other aquatic 

40 organisms from either thermal discharge effects or cold shock. Temperatures high enough to 

41 kill organisms are found in the cooling water systems, often in the area nearest the effluent 

42 discharge structure. Because thermal effects were among the earliest potential impacts 

43 identified for power plant operation, a great deal of research and regulatory effort has been 

44 aimed at understanding and controlling thermal discharges. Upper lethal temperatures (and 
Appendix A

A-22

1 various other expressions of temperature tolerance) have been determined for many important 

2 species and life stages. As a result, conditions that can lead to thermal discharge effects are 

3 relatively predictable.

4 A variety of nuisance organisms or nonnative species may become established or proliferate as 

5 a result of power plant operations, including fouling organisms such as the recently introduced 

6 zebra mussel, Dreissena polymorpha.

7 Mitigative measures have been employed at Davis-Besse to reduce the potential for thermal 

8 discharge effects. Davis-Besse is equipped with a cooling tower, offshore intake, closed intake 

9 canal, bottom intake, and a high-velocity discharge nozzle. The high-velocity discharge nozzle 

10 enhances the rapid mixing and heat dissipation of the heated effluent at the outfall.

11 Colonization of Lake Erie by zebra mussels resulted in several years of improved water clarity 

12 and dramatic food web changes, especially a shift in algal production from phytoplankton to 

13 bottom-dwelling algae and plants; however, recently, the zebra mussels have been linked to the 

14 blue-green alga (cyanobacteria) Microcystis aeruginosa. Microcystis had been a common 

15 species in Lake Erie for at least a century but recently has grown into nuisance bloom 

16 proportions. Research performed by the Great Lakes Environmental Research Laboratory 

17 (GLERL) showed video evidence of zebra mussels’ selective eating habits. GLERL was able to 

18 capture the zebra mussels filtering the water, regardless of the presence of microcystis, and 

19 releasing the microcystis aeruginosa back into the lake. The zebra mussels however continued 

20 to eat the other algae. Zebra mussels, in response to the consumption of the algae, release 

21 phosphorous that, in turn, feeds the microcystis, further facilitating their growth.

22 The concentrations of phosphorous, despite years of decline, have recently been showing a 

23 gradual increase. Phosphorous has been linked to microcystis; however, it has also been 

24 theorized, coupled with thermal pollution, to encourage the growth of lyngbya wollei, a toxic 

25 algae. In Maumee Bay, large populations of lyngbya wollei have recently emerged. Research 

26 indicates the concern was initially detected in 2006, and the population has since been growing. 

27 The Ohio EPA, Division of Surface Water, has the authority over the Maumee Bay. According

28 to the Ohio EPA: 

29 [L]ittle scientific information exists to determine the complicated biological 

30 processes that encourage the spread of Lyngbya wollei. In order to investigate 

31 this issue further, Ohio EPA has formed a Phosphorus Task Force to more 

32 formally review the phosphorus loading data from Ohio tributaries to Lake Erie; to 

33 consider possible relationships between trends in dissolved reactive phosphorus 

34 loading and in-lake conditions; to determine possible causes for increased 

35 soluble phosphorus loading; and, to evaluate possible management options for 

36 reducing soluble phosphorus loading.

37 Regarding studies under Sections 316(a) and 316(b) of the Clean Water Act, the Ohio EPA, and 

38 not the NRC, is responsible for regulating Davis-Besse’s intake and discharge through the 

39 National Pollutant Discharge Elimination System (NPDES) permitting process and for 

40 implementing the requirements of Sections 316(a) and 316(b). Modifications to the NPDES 

41 permit are outside the regulatory authority of the NRC. The Ohio EPA will ultimately decide if 

42 modification to the permit is necessary in response to the presence of microcytosis aeruginosa 

43 and lyngbya wollei.

44 The Davis-Besse discharge, however, is not a major contributor of phosphorous to Lake Erie. 

45 The source of nuisance populations of microcystis aeruginosa or lyngbya wollei or both have not 
Appendix A

A-23

1 been observed near the discharge location of Davis-Besse or the immediate surrounding area. 

2 The NRC staff acknowledges that Lake Erie is experiencing cumulative impacts to its water 

3 resources as a result of these species. These impacts have been included in Chapter 4 under 

4 cumulative impacts.

5 Comment: 45-2-AQ; There are no Federal wilderness areas or designated critical habitat 

6 within the vicinity of the proposed site. Davis-Besse consists of 954 acres, of which 

7 approximately 

8 733 acres are marshland that is leased to the U.S. Government as part of the Ottawa National 

9 Wildlife Refuge. In a letter dated December 16, 2009, we provided comments to FENOC on the 

10 proposed 20-year renewal of the operating license for Davis-Besse. At this time we have no 

11 additional comments. 

12 Response: This comment was provided by the USFWS. The NRC staff incorporated the 

13 USFWS’s information provided in this comment into the draft SEIS, including the information in 

14 the referenced December 16, 2009, letter to FENOC, which was provided in Appendix C of 

15 FENOC’s ER.

16 A.1.4 Cultural Resources (CR)

17 Comment: 46-1-AR; The Peoria Tribe has no objection to the proposed construction. 

18 However, if any human skeletal remains and/or any objects falling under NAGPRA are 

19 uncovered during construction, the construction should stop immediately, and the appropriate 

20 persons, including state and tribal NAGPRA representatives contacted.

21 Response: The staff addresses the potential impacts to Cultural Resources associated with 

22 renewing the Davis-Besse operating license in Chapter 2. Programs associated with new 

23 ground disturbance related to refurbishment and/or the inadvertent discovery of Cultural 

24 Resources is described and/or sited in Chapter 3 and Chapter 4 of this SEIS. Finally, the 

25 environmental impacts of alternatives evaluated in depth is discussed in Chapter 8 of the SEIS, 

26 including cultural resource impacts.

27 A.1.5 Human Health (HH)

28 Comment: 14-4-HH; There are several safety issues that impact on the environmental 

29 questions. First of all, I personally know a first responder. We’ve had conversations about 

30 Davis-Besse. He told me that they have been told that in the event of some sort of accident, the 

31 only thing they have to worry about is radioactive iodine, and since they will be given pills for 

32 radioactive iodine, they don’t even have to worry about that. 

33 Comment: 14-10-HH; Also, downwind from Davis-Besse in the local communities here, there 

34 is a cancer cluster. The state studied this cluster and it was woefully inadequate. It consisted of 

35 dosimeters, given to about a fifth of the families. They went out in the yards and ran the 

36 dosimeters themselves looking at the sky. They didn’t find anything, but I’m not sure they --

37 believe this happened when Davis-Besse wasn’t actually running, and it doesn’t address the 

38 fact that there may have been emissions in the past, and there could be emissions in the future. 

39 So, I think that any federal environmental impact statement would have to look at known 

40 emissions from Davis-Besse which are routine, such as I have, and correlate those with the 

41 cancer cluster in these local counties and look for cancers that are specifically known to 

42 correlate with the nucleates that we know of at least, such as thyroid cancer. I know I only have 

43 about five minutes here. I want to say that I know - - as an environmentalist, I know that the 
Appendix A

A-24

1 NRC is given an impossible task here. Any process that generates radioactive pollution that will 

2 be able to cause cancer, birth defects and hurt people for the next - - for millions of years in 

3 some cases, by definition, it can’t be done safely. 

4 Comment: 26-5-HH; And in fact there is a cancer cluster near Clyde, Ohio which is about 15 to 

5 18 miles as the crow flies from Davis-Besse. So, the comment that I have on Scoping is that I 

6 am requesting that baseline epidemiological studies be done. And that we explore what is 

7 coming out of that nuclear power plant. They are allowed by licensing to release gaseous, liquid 

8 from the plant. Below “permissible” levels. But there are cancers over in Clyde, and families 

9 are decimated. And I would request that baseline epidemiological studies be done in the entire 

10 region. 

11 Comment: 28-1-HH; I would go farther than to say the Nuclear Regulatory Commission is a 

12 “rogue” organization. I would call it a “terrorist” organization. And I would say that the cancer 

13 that people are suffering from in Clyde, Ohio, I know that Lucas County, when I left 10 years 

14 ago had the highest cancer rates of the State of Ohio. We’re all facing cancer as our future. 

15 And this cancer, I would say is on the most part, is on the hands of...It’s a legacy of industrial 

16 capitalism, but this cancer is on the Nuclear Regulatory Commission’s hands because they 

17 have done nothing to police or regulate or control this industry. It’s disgusting, it makes me sick 

18 to my stomach. 

19 Comment: 28-2-HH; I was listening to public radio the other day and they were talking about 

20 how they felt like “the Rust Belt” was kind of offensive terminology to use for this area of the 

21 country. And the thought crossed my mind well why not “The Cancer Belt” instead? Because 

22 that’s the number one killer in this area. So, if the “rust belt” is too niccy-nice. You know, they 

23 want to consider it the “water belt” but the “water belt” is contaminated. 

24 Comment: 14-19-HH; Something else I just wanted to mention that Tony Mangano, Anthony 

25 Mangno has pointed out that thyroid cancers in Ottawa County, right around the plant, went 

26 from below the national average before the plant started operating to above the national 

27 average now. And, in fact, research says that cancer rates, thyroid cancer rates particularly, 

28 just about double when you put a nuclear power plant in. So, iodine, radioactive iodine is very 

29 rare. Thyroid cancer is very rare. Pretty much you can count on the fact that those people who 

30 are dying from thyroid cancer are dying because of radioactive releases from the plant. 

31 Radioactive releases that are casual, that are average, that are “normal,” part of their normal 

32 operations. So, people are dying. They’re in the hundreds now. If we keep doing this plant and 

33 radioactive thyroid. Iodine, radioactive isotopes of Iodine stay radioactive for 20 million years. 

34 So the more we generate the more we’ll be. People will die from the cancers caused by this 

35 radioactive Iodine. They’re in the hundreds now. Another 20 years they’ll be in the thousands. 

36 So what we are trying to do here is prevent thousands of people from being killed by an 

37 unnecessary form of energy. We’ve heard testimony here today about just exactly why that’s so 

38 unnecessary. 

39 Comment: 43-3-HH; Yeah I want to make a statement on behalf of kids whose environment is 

40 being destroyed. There used to be a lot more nature to go to and tromp around in and now kids 

41 don’t have that we have urban environments that are polluted kids getting cancer because of 

42 this kind of stuff and it’s really not ok. So this is Connie Gadwell Newton urging you to not 

43 renew the licensing for Davis-Besse. Thank you.

44 Response: The NRC’s primary mission is to protect the public health and safety and the 

45 environment from the effects of radiation from nuclear reactors, materials, and waste facilities. 

46 The NRC’s regulatory limits for radiological protection are set to protect workers and the public 
Appendix A

A-25

1 from the harmful health effects (i.e., cancer and other biological impacts) of radiation on 

2 humans. Radiation standards reflect extensive scientific study by national and international 

3 organizations. The NRC actively participates and monitors the work of these organizations to 

4 keep current on the latest trends in radiation protection. 

5 Recently, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art 

6 study on cancer risk for populations surrounding nuclear power facilities. The NAS study will 

7 update the 1990 U.S. National Institutes of Health—NCI report, “Cancer in Populations Living 

8 near Nuclear Facilities.” 

9 The study will be carried out in two consecutive phases. A Phase 1 scoping study will identify 

10 scientifically sound approaches for carrying out an epidemiological study of cancer risks. This 

11 scoping study began on September 1, 2010, and will last for 15 months. The result of this 

12 Phase 1 study will be used to inform the design of the cancer risk assessment, which will be 

13 carried out in a future Phase 2 study.

14 The Sandusky County Health Department (SCHD) and the Ohio Department of Health (ODH) 

15 conducted a study of childhood cancer incidence, from the years 1996 through 2006, in the city 

16 of Clyde and Green Creek Township, both located within 50 miles of Davis-Besse. The study’s 

17 objective was to identify factors that may have contributed to the higher-than-expected 

18 childhood cancer rates found in that area. The families of 21 childhood cancer patients 

19 participated in the study, responding to questionnaires administered by SCHD staff. The 

20 questionnaires addressed a variety of topics, including possible exposure to ionizing radiation. 

21 The report concluded that there were no exposures or variables that were common to the 21 

22 children with cancer who participated in this profile. The report can be viewed online at: 

23 http://www.sanduskycohd.org/Template/Childhood%20Cancer%20in%20Eastern%20Sandusky

24 %20County%20a%20Profile%205%2026%2011.pdf

25 Although radiation may cause cancers at high doses, currently there are no data to

26 unequivocally establish the occurrence of cancer following exposure to low doses, below about 

27 10 rem (0.1 Sv). However, radiation protection experts conservatively assume that any amount 

28 of radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk 

29 is higher for larger radiation exposures. Therefore, a linear, no-threshold dose response 

30 relationship is used to describe the relationship between radiation dose and detriments such as 

31 cancer induction; simply stated, any increase in dose, no matter how small, is assumed to result 

32 in an incremental increase in health risk. This theory is accepted by the NRC as a conservative 

33 model for estimating health risks from radiation exposure, recognizing that the model probably 

34 over-estimates those risks. Based on this theory, the NRC conservatively establishes limits for 

35 radioactive effluents and radiation exposures for workers and members of the public. While the 

36 public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC (10 CFR Part 20), the 

37 NRC has imposed additional constraints on nuclear power reactors. Each nuclear power 

38 reactor, including Davis Besse, has license conditions that limit the total annual whole body 

39 dose to a member of the public outside the facility to 25 mrem (0.25 mSv). In addition, there are 

40 license conditions to limit the dose to a member of the public from radioactive material in 

41 gaseous effluents to an annual dose of 

42 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem 

43 (0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ.

44 The amount of radioactive material released from nuclear power facilities is well measured, well 

45 monitored, and known to be very small. The doses of radiation that are received by members of 

46 the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few 
Appendix A

A-26

1 millirem) that resulting cancers attributed to the radiation have not been observed and would not 

2 be expected. 

3 A number of studies have been performed to examine the health effects around nuclear power 

4 facilities. The following is a list of some of the studies that have been conducted: 

5 • In 1990, at the request of Congress, the National Cancer Institute (NCI) conducted a 

6 study of cancer mortality rates around 52 nuclear power plants and 10 other nuclear 

7 facilities. The study covered the period from 1950 through 1984 and evaluated the 

8 change in mortality rates before and during facility operations. The study concluded 

9 there was no evidence that nuclear facilities may be casually linked to excess deaths 

10 from leukemia or from other cancers in populations living nearby.

11 • Investigators from the University of Pittsburgh found no link between radiation released 

12 during the 1979 accident at the Three Mile Island Nuclear Station and cancer deaths 

13 among nearby residents. This study followed more than 32,000 people who lived within 

14 5 miles (mi) (8 kilometers (km)) of the facility at the time of the accident.

15 • In January 2001, the Connecticut Academy of Sciences and Engineering issued a report 

16 on a study around the Haddam Neck Nuclear Power Plant in Connecticut and concluded 

17 that exposures to radionuclides were so low as to be negligible and found no meaningful 

18 associations to the cancers studied.

19 • In 2001, the American Cancer Society concluded that, although reports about cancer 

20 clusters in some communities have raised public concern, studies show that clusters do 

21 not occur more often near nuclear plants than they do by chance elsewhere in the 

22 population. Likewise, there is no evidence linking the isotope strontium-90 with 

23 increases in breast cancer, prostate cancer, or childhood cancer rates.

24 • In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there 

25 are striking increases in cancer rates in southeastern Florida counties caused by 

26 increased radiation exposures from nuclear power plants. However, using the same 

27 data to reconstruct the calculations on which the claims were based, Florida officials did 

28 not identify unusually high rates of cancers in these counties compared with the rest of 

29 the state of Florida and the nation.

30 • In 2000, the Illinois Public Health Department compared childhood cancer statistics for 

31 counties with nuclear power plants to similar counties without nuclear plants and found 

32 no statistically-significant difference.

33 In summary, there are no studies to date that are accepted by the nation’s leading scientific 

34 authorities that indicate a causative relationship between radiation dose from nuclear power 

35 facilities and cancer in the general public. The amount of radioactive material released from 

36 nuclear power facilities is well measured, well monitored, and known to be very small.

37 These comments provided no new and significant information. Therefore, no changes have 

38 been made to the SEIS.

39 Comment: 20-4-HH; So tritium is an isotope of hydrogen, it’s hydrogen-3, which means one 

40 proton and two neutrons, and, it is not naturally occurring and has a half-life of 12.3 years. so it 

41 is produced in all nuclear reactors by a neutron bombardment either of lithium-6, or boron-10. 

42 And, some of you may remember boron is the acid, well, there’s boron in the cooling water that 

43 is in the pressure vessel, and it was that leaking of boric acid, that was responsible for going 

44 through 6 inches of carbon steel in the reactor head. So, the presence of that boron is, under 
Appendix A

A-27

1 neutron, impact, can produce the, tritium. It’s radioactive, it decays, in 12.3 years half-life, and it 

2 emits a high-energy electron which is, known as a beta particle, and, and there’s another 

3 particle which is an anti-neutrino, which almost interacts, so, so, so little that, neutrinos can, 

4 pass completely through the earth. So we don’t worry about the neutrinos or the anti-neutrinos, 

5 but the beta particle is 5.7 kilo, uh...KEV, kilo electron volts, and, this also has a fairly, fairly low 

6 penetration. It, it barely gets into your skin, it stops almost with the dead layers of the skin. 

7 However, if you ingest it, or you breath it, then it’s very dangerous because it, it has a very 

8 short, penetration distance in your lungs or, or in your intestinal tract. So, bec...it’s likely to be 

9 ingested either as water vapor, as, hydrogen, actually it would be an analog...isotope, one atom 

10 of hydrogen, one atom of normal hydrogen, one atom of tritium, or it, it forms, H2O, water, as, 

11 hydrogen, one atom of tritium, or it, it forms, H2O, water, as most likely a normal hydrogen 

12 isotope and a tritium isotope together with oxygen, so you will ingest it if you drink water from 

13 one of these contaminated wells. So, just a couple of things to remind us of the danger of, of 

14 these reactors. Even if there is not a catastrophic meltdown, there are ever-present dangers in 

15 these, in the operation of these nuclear reactors. 

16 Comment: 26-7-HH; In addition, it was mentioned earlier that there were Tritium leaks in 2009. 

17 There was also a Tritium leak in 2008. The grounds are contaminated. I’m concerned about 

18 the buried piping at the Davis-Besse plant, about the leaking of Tritium, about the potential of 

19 flooding externally, the potential of flooding internally at the Davis-Besse plant. This is an aging 

20 plant. And with that Tritium leak and as you run a nuclear power plant into the ground, which is 

21 being proposed, another 20 years there are going to be increasing leaks, increasing 

22 contamination. 

23 Response: These comments are concerned with tritium in the groundwater. NRC regulations 

24 require licensees to control and limit radioactive releases, including tritium, to the environment 

25 (the air and water). As part of the NRC requirements for operating a nuclear power facility, 

26 licensees must comply with radiation dose limits for the public in 10 CFR Part 20 and keep 

27 releases of radioactive material into the environment during normal operations as low as is 

28 reasonably achievable (ALARA), in accordance with 10 CFR 50.36a.. 

29 Information on FENOC’s groundwater monitoring program is contained in Chapters 2 and 4 of 

30 this draft SEIS. 

31 No new and significant information is provided in these comments. Therefore, no changes have 

32 been made to the SEIS because of these comments.

33 Comment: 22-4-HH; In addition, the amount of toxic algae has increased over the last, 10 to 

34 15 years, so much that the Ohio EPA reports that physical contact with the toxic algae in Lake 

35 Erie probably causes illnesses, probably caused illnesses to 10 people in the summer of 2010. 

36 Comment: 29-3-HH; It’s not a question! I just want the panel to know that inadvertently when 

37 people start dying or getting sick because the levels occur. Is there any way that they could 

38 possibly be held responsible or get sued?

39 Response: These comments express concerns relating to the nuisance organisms in Lake Erie 

40 as they apply to Human Health. Lyngbya wollei and Microcystis aeruginosa are two different 

41 species of cyanobacteria. Both currently exist in Lake Erie and have become a nuisance in the 

42 Maumee Bay area. When conditions are present to facilitate a rapid growth, a dense population 

43 forms, known as a bloom. Some Blooms are harmless; however, when these organisms

44 contain toxins, other noxious chemicals, or pathogens, it is referred to as harmful algal blooms 
Appendix A

A-28

1 (HAB). HABs may cause health concerns dependant on the method an individual comes in 

2 contact with the toxin produced.

3 Thermal pollution has been referenced as a contributor to the growth of HABs. Davis-Besse’s 

4 thermal effluent is warmer than the receiving waters. HABs, however, require calm, low-flow 

5 water conditions in order to facilitate their growth. The Davis-Besse outflow is equipped with a 

6 high-velocity discharge nozzle. The high-velocity discharge nozzle, as part of the NPDES 

7 permit, is intended to enhance the rapid mixing and heat dissipation of the heated effluent at the 

8 outfall. As referenced in 2.2.6, Aquatic Resources, of this SEIS, the regulation of surface waters 

9 is within the regulatory authority of the Ohio EPA. In addition, the thermal discharges, regulated 

10 by the NPDES permit, are also under the authority of the Ohio EPA.

11 NRC staff did not discover any studies linking Davis-Besse as a direct contributor to the 

12 formation of HABs. The health impacts associated with HABs and the impairment of Lake Erie 

13 are discussed in the “Cumulative Health Impacts,” section of Chapter 4. 

14 A.1.6 Hydrology (HY)

15 Comment: 20-3-HY; This is a study by Davis-Besse. In Appendix E, that’s the Environmental 

16 Report, on this page (Page 2.3-2), I quote here, they’re, they’re required, by their operating 

17 license to have monitoring wells to monitor the quality of the groundwater in the, within the 

18 perimeter. And one of their wells in 2..., in the spring of 2009 showed a tritium level that was 

19 rising, 4000, pico curies/liter. And, this is a quote from their study. “As a result, the First Energy 

20 Nuclear Operating, Company,” notice that’s a separate operating company from First Energy, 

21 from the rest of First Energy, “is pursuing a root cause approach to identify the source of the 

22 tritium in the wells. No tritium concentrations of...have been detected above the, 

23 US EPA drinking water limit of 20,000 picocuries.” But, this to me is very troubling. Even 

24 though the, the, concentration is not that high yet, but is an increasing amount, the question is 

25 where does it come from?

26 Response: The comment expresses concern relating to the source of the tritium noted in 

27 FENOC’s ER. 

28 The NRC staff describes the groundwater resources at Davis-Besse and the effects of plant 

29 operations on groundwater hydrology and quality in Chapters 2 and 4 of this SEIS. Chapter 2

30 summarizes the results of NRC’s review of Davis-Besse’s Groundwater Protection Program, 

31 including the placement of site groundwater monitoring wells. As part of this evaluation, the 

32 NRC staff specifically reviewed the conceptual groundwater model prepared for Davis-Besse in 

33 2007 and 2008. All studies reviewed by the NRC staff are cited in Chapter 2 of this SEIS, 

34 including analysis of tritium information. 

35 No new and significant information is provided in this comment. Therefore, no changes have 

36 been made to the SEIS because of this comment.

37 Comment: 26-6-HY; Earlier again, this week, I got several documents from Connie Klein who 

38 was one of the interveners at Davis-Besse on the first Operating. And she shared with me 

39 photos of the flooding of the Davis-Besse in 1972. This was during construction. The entire site 

40 was flooded for two to three weeks. Um I have concerns about the Davis-Besse flooding. As 

41 you all know Lake Erie is very shallow. The western basin is very very shallow, and it is subject 

42 to something called a seiches where the wind blows out the water, blows it east. Then the 

43 water comes back, like a bathtub, and floods the western shore. I’m concerned about the 

44 potential flooding of that Davis-Besse Plant. 
Appendix A

A-29

1 Response: This comment expresses concern regarding the potential of flooding at 

2 Davis-Besse. As part of the initial design of Davis-Besse, consideration for flooding was 

3 required to ensure the safety of structures and continued operation of the plant. The plants 

4 design basis included the determination of the probable maximum surge flood level and is 

5 documented in the final safety analysis report (FSAR). 

6 The static water levels in the western basin of Lake Erie are subject to long term, annual cyclical 

7 variation, and short period variations. These variations are due to wind tides and seiches. 

8 Seiches are a movement on the surface of an enclosed body of water, in this case Lake Erie, 

9 usually caused by intense storm activity. 

10 The short period variations in the daily level from the monthly mean level are due to both a 

11 lengthwise wind tide which produces the greatest disturbance of water level and a transverse 

12 seiche in the west end of Lake Erie which can oscillate between the northern and southern 

13 shores. A traverse seiche of 0.8 ft has been recorded but for design purposes, 1.0 ft has been 

14 used in the design considerations. 

15 Based on collected and available data since 1860, the maximum variations in the mean monthly 

16 water level are 4.2 feet above datum and 1.2 feet below datum. Not included in this range were 

17 two occurrences in 1973 and 1974, when an all-time high lake level was recorded at 4.9 ft 

18 above datum. Davis-Besse, in its design considerations, used a probable maximum variation of 

19 4.8 feet above and 1.5 feet below datum. Although 4.8 ft is less than the recorded 4.9 ft, the 

20 0.1 ft difference is accounted by the rounding up of the daily level variation from 0.8 ft to 1.0 ft. 

21 A probable maximum meteorological event was used to determine the maximum rise in lake 

22 level due to wind tides. This meteorological event would have a maximum ENE wind at anyone 

23 location of 100 miles per hour for a 10-minute period, and the wind speed could exceed 

24 70 miles per hour during the six-hour period both before and after the maximum wind speed. 

25 The force or push of the wind driving the water level up, resulted in a maximum wind tide rise of 

26 9.3 ft. 

27 The probable maximum surge flood level that could occur at Davis-Besse would be a 

28 combination of all these occurrences, for both the cumulative high and the cumulative low. For 

29 flooding concerns, the design would relate to the cumulative high. Thus, the 4.8 high monthly 

30 mean, 1.0 ft seiche, and the 9.3 ft wind tide would result in a 15.1 ft rise in low water datum to 

31 reach a static high elevation of 583.7 ft. Davis-Besse has a finished floor elevation set above 

32 the static high and is further protected by an earthfill breakwall built up to an elevation of 591.0 ft 

33 to further protect the site from potential wave action. 

34 As a result of the 2011 earthquake and tsunami that struck Japan, resulting in extensive 

35 damage to the nuclear power reactors at the Fukushima Dai-ichi facility, the NRC has taken 

36 significant action to enhance the safety of reactors in the United States. Operating nuclear 

37 reactors were directed to use present-day information to reevaluate the flooding hazards that 

38 could impact their site and to submit their reevaluations to the NRC for evaluation in a Hazard 

39 Reevaluation Report. Information on the NRC’s actions relating to Fukushima Dai-ichi accident 

40 can be found at: http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html. 

41 A.1.7 License Renewal and its Process (LR)

42 Comment: 14-1-LR; Good evening. Like most people in the Northwest Ohio area, I first found 

43 out about the scoping meeting earlier in the week when there was a story in the Blade. So, I 

44 had not had an opportunity to completely read the Environmental Impact Statement that’s been 
Appendix A

A-30

1 prepared with the application for the license renewal. But, I think that is one of the issues that 

2 should be dealt with in the scoping process at either another later meeting or perhaps further 

3 announcements, and at the very least, I would like to request a hard copy also be placed in the 

4 Wood County Library in Bowling Green, Ohio. 

5 Comment: 16-1-LR; My name is Patricia Marida. I’m the Chair of the Nuclear Issues 

6 Committee of the Ohio Sierra Club. And, we had a whopping four days to know about this 

7 meeting. I had four days ahead. I learned about it this morning and have come up from 

8 Columbus here. 

9 Comment: 14-15-LR; And though...I felt at the time, those people should be at this hearing, 

10 but most people didn’t even know it happened. It went by before people could get their thoughts 

11 together. And so we asked the NRC to hold another one here in Toledo, they refused, but we 

12 have decided to hold our own and that’s what this is...that’s what this is about. 

13 Comment: 16-23-LR; First let me say that the Sierra Club is disappointed that the NRC only 

14 gave 10 days notice of these scoping meetings in the Federal Register, and that the public only 

15 had 3 days notice from an article in The Toledo Blade. The Davis-Besse Environmental Report 

16 and License Renewal Application were almost 2000 pages, not including the NRC Generic 

17 Environmental Impact Statement for Nuclear License Renewal. Therefore, we would like to 

18 request that the NRC hold at least one additional scoping meeting, and that this be held in 

19 Toledo, close to the population center with residents who are informed by The Blade. Also, 

20 setting the comment deadline during the holiday season makes it difficult for people to have 

21 time to digest the material and comment. Therefore, we would also like to request an extension 

22 of the comment period, preferably until the end of January. 

23 Comment: 44-1-LR; I would be very interested in a scoping meeting taking place in Toledo, 

24 Ohio where more people would be able to attend. I also think more time should be allotted for 

25 the comment period as December 27, 2010 falls in the middle of the holiday period. Perhaps an 

26 additional 30 day period would be appropriate. 

27 Comment: 49-1-LR; The people of Northwest Ohio, Southeast Michigan, and other 

28 communities that would be the most adversely affected by an accident at Davis-Besse deserve 

29 a longer comment period and more hearings before the NRC automatically approves First 

30 Energy’s request to re-license. Please attend our hearing, as outlined below. PUBLIC 

31 HEARING on re-licensing of the Davis-Besse Atomic Reactor Saturday Dec. 18 from 12 noon to 

32 3 pm St. Mark’s Episcopal Church 2272 Collingwood Blvd Toledo, Ohio 20 MORE Years of 

33 Radioactive Russian Roulette on the Great Lakes shore?! We are calling for input from all 

34 interested parties regarding First Energy’s mismanagement of Davis-Besse, and the Nuclear 

35 Regulatory Commission’s lack of oversight of that facility, in particular residents of Ohio, the 

36 Toledo area, South East Michigan, or residents of any community that would be directly 

37 adversely effected by an accident at Davis-Besse. Anyone can testify, sign in will be required. 

38 This hearing will be videotaped and presented to the NRC. FirstEnergy has applied to the U.S. 

39 Nuclear Regulatory Commission (NRC) for a 20-year operating license extension at its 

40 Davis-Besse nuclear power plant near Oak Harbor, Ohio, just over 20 miles east of Toledo. 

41 Davis-Besse is one of the most problem-plagued atomic reactors in the entire country: it has 

42 suffered six “significant accident sequence precursors,” three times more than any other 

43 American nuclear plant. The original license was granted in 1977 and will expire in 2017. If the 

44 extension is approved Davis-Besse can operate until 2037. In the past 10 years NRC has 

45 rubber-stamped 60 or 60 license renewals sought by industry. The NRC Office of Inspector 

46 General has reported serious problems with NRC’s license extension program: NRC staff have 
Appendix A

A-31

1 “cut and pasted” the nuclear utility’s own work, sometimes word for word, falsely presenting it as 

2 an independent safety

3 Comment: 14-13-LR; So, I’d like to welcome you all. My name is Joe DeMare and I spoke at 

4 the official NRC hearing on November 4. And I have to tell you, it was a, a rather disappointing 

5 experience, because almost everyone there was either employed by Davis-Besse or they were 

6 from an organization that received money from Davis-Besse.

7 Response: The environmental scoping period is an opportunity for the public, tribal 

8 governments, and local, state and Federal government entities to assist the NRC in identifying 

9 areas of concern, impacts, and alternatives as staff develops the SEIS for license renewal. The 

10 NRC announced the start of the scoping period by use of a Federal Register Notice, published 

11 on October 28, 2010. The 60-day review period for the environmental scoping period ended on 

12 December 27, 2010. 

13 The purpose of the environmental scoping meeting was to provide a brief summary of the 

14 license renewal and scoping process and to allow the public an opportunity to provide 

15 comments. Although the NRC emphasizes the purpose for the solicitation of comments, it does

16 not restrict the topic of those comments to those applicable to license renewal. As a result, the 

17 public, in some instances, takes this opportunity to voice their opinion in support or against the 

18 approval or denial of the renewed license. 

19 The environmental scoping meeting was one method for providing scoping comments. 

20 Comments were also sent to the NRC in response to this draft SEIS by the following methods: 

21 • Comments were submitted electronically via the Federal rulemaking Web site: 

22 http://www.regulations.gov and search for documents filed under Docket ID 

23 NRC-2010-0298. 

24 • Comments were mailed to: Chief, Rulemaking and Directives Branch (RADB), Division 

25 of Administrative Services, Office of Administration, Mail Stop: TWB-05-B01M, U.S. 

26 Nuclear Regulatory Commission, Washington, DC 20555-0001. Comments were faxed 

27 to RADB at (301) 492-3446.

28 Additional details relating to the license renewal can be found in Chapter 1 of this draft SEIS or 

29 at http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0291/br0291-r2.pdf. 

30 Comment: 18-3-LR; Now we’re looking at what the NRC is doing in, in its laughable oversight 

31 of all the nuclear power plants but Davis-Besse in particular. And it occurs to me that, that...the 

32 NRC is a rogue agency and just as the, as the, SEC failed us, failed us, the citizens that it 

33 should be, watching out for, that is our goals, that is our tool, that is the thing that, the entity that 

34 we have put in place through our government to make sure that everybody plays by the rules. 

35 And that is what the, Nuclear Regulatory Commission is as well. However, it is failing to do that, 

36 it has, it has absolutely failed to do that. And what it has done in reference to Davis-Besse and 

37 the numerous problems that we have seen is, at Davis-Besse, demonstrates that very clearly. 

38 Comment: 25-2-LR; We need to broaden the idea of what environmental consequences, 

39 environmental impact means when it comes to nuclear power and something like Davis-Besse, 

40 and other people who have spoken here today have done a better job at talking about what 

41 specifically, The common definition of what environmental impacts might be. But I’d like to say 

42 something about the political environment that is affected by the operation of nuclear power 

43 plants and Davis-Besse relicensing, the potential licensure of a plant down in Piketon a new 
Appendix A

A-32

1 power plant that our Democratic Governor invited in to this situation that Kucinich will probably 

2 go right along with and that is the credibility and the competency of something called the 

3 Nuclear Regulatory Commission. Already while the residents of this area would be most directly 

4 affected by the power plant, Cleveland is not that far away and the NRC should have solicited 

5 input from people from a broader radius around the power plant including Michigan and Indiana. 

6 Because what we’ve found from the Chernobyl accident is that radioactive waste doesn’t stop at 

7 municipal boundaries or national boundaries. And the environmental impact is much broader 

8 than how some fish that get caught in an intake pipe or the other kind of more immediate sort of 

9 environmental impacts that people might think of. The fact that the NRC didn’t hold multiple 

10 hearings on this is a problem, but they shouldn’t and I’m speaking directly to the NRC at this 

11 point. The NRC shouldn’t take as the expression of the people of Ohio the testimony of just 

12 those people who attended the hearing on November 6th or 4th or whenever it was right after

13 election day. That the people are economically benefitting from the conduct of FirstEnergy by 

14 the operation of that power plant whether it’s through their jobs or through charitable 

15 contributions, that is not a legitimate expression. We have a political problem in this country of 

16 disengagement and alienation and generally, the government and its regulatory bodies are 

17 treated with contempt by the mass media. And a culture of contempt is built among the people 

18 for our government and for the mechanisms that we as people use collectively to monitor things 

19 like the banking industry or the nuclear industry. It’s not to our benefit that that is happening, 

20 but it is. So that small group of people who testified in favor of this relicensing is not a complete 

21 or an inclusive representation of the people that are concerned with this. And I would suggest 

22 that most of the people that are concerned with this are disengaged and are not paying 

23 attention. And the credibility of the NRC is at stake. 

24 Comment: 26-4-LR; So the lesson I take out of this was I learned that the NRC is incapable of 

25 learning lessons. As mentioned earlier, they are indeed a rogue agency. This past week, the 

26 61st nuclear power plant that had applied for relicensing was relicensed. They are now batting 

27 1000%. 1000, Batting 1000. 61 for 61 on relicensing applications. So, the NRC has not a 

28 shred of credibility with the public, and they are there, running interference, keeping the people 

29 away from confronting these utilities when they run these abysmal plants. 

30 Comment: 28-3-LR; I don’t have any faith in the Nuclear Regulatory Commission to do 

31 anything about the issue, but, thanks. That’s all I have to say. 

32 Comment: 26-10-LR; So, I do not have confidence in the NRC to force about proper 

33 equipment, maintenance. Perpetually, there are exemptions that are requested and just as a 

34 matter of rubberstamping - - the Nuclear Regulatory Commission, the Nuclear Rubberstamp 

35 Commission, allows them exemption time after time. Again. Production over safety. Profit over 

36 people. 

37 Response: These comments express a lack of confidence relating to NRC’s oversight and 

38 regulation. To ensure that U.S. nuclear power plants are operated safely, the NRC licenses the 

39 plants, licenses the plant operators, and establishes license conditions for the safe operation of 

40 each plant. 

41 In addition, the safe operation of nuclear power plants is not limited to license renewal but is and 

42 will be dealt with on a daily basis as a part of the current operating license. The NRC, on an 

43 ongoing basis, at every nuclear power plant, addresses safety issues and concerns. The NRC 

44 conducts safety inspections throughout the operating life of the plant, whether during the original 

45 or renewed operating license. If the NRC discovers safety issues at a nuclear power plant, they 
Appendix A

A-33

1 are addressed immediately, and any necessary changes are incorporated under the current 

2 operating license. As such, the regulatory safety oversight of Davis-Besse is ongoing. 

3 Comment: 18-4-LR; This is the beginning. Certainly, we don’t have enough people in this 

4 room. We never do when we try to do something like this. We fit it in between all of the things 

5 that we do as, as mothers, as fathers, as, as parts of families, as parts of communities, we fit it 

6 in with our jobs, and we are determined to make a change. So as we approach that process 

7 here, in, in making comments, that the Nuclear Regulatory Commission will do their utmost to 

8 ignore, as, as we approach this process, we have to understand that this is the beginning of the 

9 process. This is the beginning of the process of us as citizens, and I believe that “We the 

10 People” is one of the most powerful statements that anybody can make. And “We the People” 

11 embodies our democracy, so “We the People” will be the ones who will have to challenge not 

12 only Davis-Besse but the NRC. 

13 Comment: 23-1-LR; Hi folks. Um I prepared written comments for the NRC. I’m really 

14 pleading with you all because I’m not sure they’ll listen or read them. 

15 Response: These comments express a lack of confidence over the NRC’s ability to address 

16 and incorporate scoping comments. To further enhance the development of the SEIS, public 

17 participation is solicited as part of the license renewal scoping process. NRC held two public 

18 meetings on November 4, 2010, to solicit comments from the public.

19 Two additional meetings, not sponsored by the NRC, were also conducted to obtain comments 

20 from the public. The People’s Hearing, held by the Green Party of Ohio, represented by Anita 

21 Rios and Joseph DeMare, was held on December 17, 2010. The Sierra Club, represented by 

22 Patricia Marida, also held a separate meeting on December 11, 2010. Prior to the Davis-Besse 

23 scoping period, scoping comments in video format had never been submitted. The Peoples 

24 Hearing provided a transcript of the meeting, in addition to the video submission, to ensure the 

25 accurate capture of their comments. The NRC, to provide complete representation of the 

26 comments, developed an unofficial transcript of the Sierra Club meeting. Comments are both 

27 welcomed and encouraged as part of the Draft SEIS comment period for incorporation into the 

28 final SEIS.

29 The NRC makes a conscious effort to address public concerns provided in the scoping 

30 comments. The NRC acknowledges there is public dissatisfaction when comments, are 

31 categorized as out of scope. The Scoping Summary Report and Appendix A of this SEIS, 

32 however, has included expansive responses. Where the comments were deemed in scope, a 

33 summarized response is provided and the reader is directed to the appropriate section within 

34 the SEIS to gain additional details. Where the comments are categorized as out of scope, staff 

35 responded to the comments and redirected the reader to where the comments are addressed. 

36 Comment: 26-2-LR; We’ve heard that there are several alternatives to Davis-Besse. 

37 Replacement power is available now. Could be generated much cheaper. It is about the 

38 consecration of wealth and a cartel of the utilities that like the monopoly status that they enjoy, 

39 and they are locking out the people. It is not power, not energy for the people. It is power and 

40 political power against the people. 

41 Comment: 16-25-LR; The environmental effects that occur in other parts of the United States 

42 should come under consideration when the NRC develops the Environmental Impact Statement. 
Appendix A

A-34

1 Response: These comments request evaluation of the cumulative effects of license renewal on 

2 the United States. The cumulative effects of license renewal are evaluated in this SEIS. A 

3 detailed discussion can be found in Chapter 4. 

4 Comment: 16-32-LR; Even the 40-year time frame for operation of a power plant does not 

5 have an engineering basis, but was based on the time needed to pay off construction bonds. 

6 What happened to the engineering responsibility to oversee and advice an operation of this 

7 magnitude of danger? 

8 Response: The Atomic Energy Act provides the NRC with the regulatory authority for to issue 

9 licenses for commercial power reactors to operate for up to 40 years and allows these licenses 

10 to be renewed for another 20 years. A 40-year license term was selected based on economic

11 and antitrust considerations -- not technical limitations. The NRC has established a license

12 renewal with clear requirements to assure safe plant operation for an additional 20 years of 

13 plant life.

14 The license renewal rule, 10 CFR Part 54, establishes the technical and administrative

15 requirements for renewing a reactor operating license. Part 54 focuses the staff’s review on

16 managing the adverse effects of aging to ensure that important systems, structures and

17 components will continue to perform their intended function during the 20-year period of

18 extended operation. An applicant must provide the NRC with an evaluation that addresses the

19 technical aspects of plant aging and describes the ways those effects will be managed. The

20 NRC reviews the application and documents the conclusions in the safety evaluations. 

21 The applicant must also prepare an evaluation of the potential impact on the environment if the

22 plant operates for another 20 years. The NRC performs plant-specific reviews of the

23 environmental impacts of license renewal in conformance with the National Environmental

24 Policy Act and the requirements of 10 CFR Part 51. To facilitate the environmental review for

25 license renewal, certain issues were evaluated generically for all plants rather than separately in

26 each plant’s renewal application. The generic evaluation, NUREG-1437, Generic 

27 Environmental Impact Statement for License Renewal of Nuclear Plants, (GEIS) assesses the

28 scope and impact of environmental effects that would be associated with license renewal at any

29 nuclear power plant site. A plant-specific supplement to the GElS, commonly referred to as the 

30 SEIS, is prepared for each licensee that applies for license renewal.

31 Before a new license is issued, the NRC will ensure that there is a technically credible and

32 legally sufficient basis for granting a renewed license for an extended 20 years as reflected in 

33 the NRC’s safety evaluation report, final environmental impact statement supplement, and the

34 proposed renewed license.

35 A.1.8 Opposition to License Renewal (OL)

36 Comment: 7-1-OL; FirstEnergy should not be allowed to continue to operate Davis-Besse after 

37 2017. 

38 Comment: 14-12-OL; In this specific case, Davis-Besse has one of the worst operating records 

39 in the industry. That’s widely known. This will actually be a very interesting test case to see if 

40 the NRC is able to deny any license. I think if any license should be denied, it would be 

41 Davis-Besse. 

42 Comment: 16-2-OL; The Sierra Club opposes nuclear energy in its entirety, citing serious 

43 environmental health and public expense issues throughout the nuclear fuel cycle. 
Appendix A

A-35

1 Comment: 14-14-OL; And I know that there are many people, thousands of people, in the 

2 Northwest Ohio area, that don’t want this license renewed and think it’s an insane gamble with 

3 our health and safety to run this plant for another 20 years. 

4 Comment: 14-16-OL; So, we have a lot of very educated, very well-informed speakers. And 

5 we have people that are just plain citizens that, but I think most of the people that we’ve 

6 scheduled to speak...feel that Davis-Besse should not be renewed. We have opened this up to 

7 the public and if anyone here wants to, to speak that hasn’t been asked to already, you just 

8 need to sign up, there’s a little sheet outside, I’ll ask you to sign. 

9 Comment: 18-1-OL; And Davis-Besse is about 20 miles from here. And, I have been opposed 

10 to nuclear power for a very long time. But as I was thinking about, what we are doing here 

11 today and, what I wanted to talk about today, it kept, coming back to me that I think that even if I 

12 was in favor of nuclear power, this is still a nuclear power plant that I would want shut down. 

13 Comment: 18-7-OL; And in the face of that, in the face of that lack of responsibility and lack of 

14 planning for the future, the NRC has continued to do nothing. They just slapped them on the 

15 wrist for that, they slapped them on the wrist, they fined them. But if you look at, FirstEnergy’s 

16 profits, they have gone up, they have, they have never gone down, they never had to really pay 

17 for, for what they did here at Davis-Besse. They have shown, a complete lack of responsibility

18 to the people they serve. And the NRC has failed to hold them accountable. 

19 Comment: 18-8-OL; Now the other thing about FirstEnergy is, First Energy holds a corporate 

20 charter from here in Ohio. And I think that one of the next steps that, that we should be pushing 

21 towards is to revoke that corporate charter for FirstEnergy. They are, they are a rogue 

22 corporation. They have failed to, to provide oversight of their own facilities, and they have failed 

23 to, show any real determination to actually learn from that situation that transpired back when 

24 the, Davis-Besse almost, melted down actually. So I hope that these proceedings are the first 

25 step towards preventing, a nuclear meltdown. In the face of the failure of First Energy to be 

26 vigilant and maintain its, its facilities appropriately, and in the face of, of the failure of the 

27 Nuclear Regulatory Commission to provide adequate oversight, and I would invite each of you 

28 to be a part of that next step because certainly we must grow this movement if we are to be 

29 effective. Thank you. 

30 Comment: 19-8-OL; And there’s ongoing problems with Davis-Besse, to the present day. I’d 

31 like to just share some figures for, what might happen if there were a major radioactivity release 

32 at Davis-Besse. This comes from a 1982 NRC report entitled “Calculation of Reactor Accident 

33 Consequences,” or CRAC, which is a nice little acronym the NRC came up with. So, if there 

34 were a major radioactivity release from Davis-Besse, the NRC and the Sandia National Lab in 

35 New Mexico, which conducted the study, determined that there could be 1,400 peak early 

36 fatalities, they call them, 1,400 peak early fatalities, 73,000 peak early injuries, and 10,000 peak 

37 cancer deaths. And they attributed a dollar figure of 84 billion dollars for property damage. So, 

38 that study came out in 1982. NRC tried to cover it up. Congressman Ed Markey of 

39 Massachusetts, got it ousted by subpoena by holding a hearing and out came the figures. So if 

40 you increase, all those casualties due to the increase in population since 1982, if you, increase, 

41 due to inflation the, property value damages, that would go up to $185 billion dollars. And a little 

42 update to mention, just came out in, mid-September, “Inside the EPA,” which is a trade press, 

43 publication in Washington, DC, scooped the story that they did a freedom of information act 

44 release to the NRC, the EPA, and the Federal Emergency Management Agency, and 

45 discovered, internal e-mails between the agencies, the lawyers of the agencies, fighting with 

46 each other over a little minor detail of after a major radioactivity release who would, be in charge 
Appendix A

A-36

1 of the clean-up and how would it be paid for. So it turns out that the lawyers at these 3 

2 agencies, were discussing how Price-Anderson, the national liability, coverage for major nuclear 

3 power plant accidents, will not cover the cleanup costs. It would cover other things, property 

4 damage and, and some very strictly controlled categories, but not clean up costs. So, that’s a 

5 little issue. 

6 Comment: 19-9-OL; Davis-Besse, which is deteriorated with age, has already had so many 

7 close calls, 2 major accidents. So, you can see things are pretty out of control. Anita 

8 mentioned the, NRC as a rogue agency. And we keep trying to figure out what the NRC stands 

9 for. Is it Nobody Really Cares? Is it Nuclear Rubberstamp Commission? it might be Nuclear 

10 Rubberstamp Commission, because of, the 60 license extension applications they’ve 

11 considered so far, they have rubberstamped every single one of them. And, these are oldest 

12 reactors in the country with major problems. 

13 Comment: 14-17-OL; OK, so while Al’s setting up, I just want to mention that, technically what 

14 these comments are going to be is part of the Environmental scoping comments for the 

15 Environmental Impact Statement, which is part of the application for the 20-year renewal. So 

16 part of that process is that if we could show that there are cheaper, safer, more environmentally 

17 friendly alternatives to doing nuclear power, to renewing this license for another 20 years, 

18 technically the NRC is supposed to say “OK, you’re right, nuclear power isn’t that, we won’t 

19 extend this, licensing application.” 

20 Comment: 22-1-OL; Water is the foundation of life. And it’s our most precious resource in 

21 Ohio. Nuclear energy is not needed for life here in northwest, Ohio. 

22 Comment: 22-7-OL; Davis-Besse should not be re-licensed. The other question that has to be 

23 considered - is the safety culture within Davis-Besse changed? And if one were to assess the 

24 safety culture in personnel...Technology doesn’t fail on its own, technology fails...People 

25 operate technology. 

26 Comment: 23-2-OL; So, we urge the Commissioners to deny the 20 year relicensing. If there 

27 ever was a candidate for the first denial of a relicense, this is it. As the history of the facility 

28 proves, it is too dangerous and expensive to continue this operation, especially since it is too 

29 dangerous and expensive to continue this operation, especially since it is not needed for 

30 present or future power generation. I would like to refer the Commissioners to two articles 

31 quoting studies that support this latter statement. 

32 Comment: 23-5-OL; It’s past time to admit that we can no longer afford this complicated and 

33 dangerous technology - - not the feed-in tariff, I’m referring to Davis-Besse.

34 Comment: 24-3-OL; As a very senior citizen, I would like to encourage the members of the 

35 audience who are opposing the relicensing of the plant to keep fighting. It can sometimes get 

36 discouraging, but the opposition that was mounted to the original building of nuclear plants in 

37 the 1960s and 70s did result in enough added expense for the electrical industry to put a halt to 

38 the building of new plants, although Davis-Besse was approved. 

39 Comment: 25-1-OL;. Some people may remember me from the early 90s. I know at least 

40 Mike Leonardi was here in the room. There he is! That’s when we fought off the whole 

41 proposition to build a low level radioactive waste dump here in Ohio. I’m sorry I wasn’t here in 

42 the 70s to resist against the Davis-Besse, but if I lived in Ohio then, I would’ve. 
Appendix A

A-37

1 Comment: 26-1-OL; We are blessed in that we live in 20% of the world’s surface freshwater 

2 here in the Great Lakes the most precious resource on the planet. Without it, life is not 

3 possible. And yet we have a nuclear power plant that has an abysmal record, Davis-Besse. 

4 But I’m here to tell you that it’s not about the generation of energy. It’s about the concentration 

5 of wealth and power. Political economy. 

6 Comment: 26-12-OL; Now we’ve got to stop the production of this material, and I say do not 

7 relicense this and the plant should be shut down immediately.

8 Comment: 27-2-OL; So, I just agree that they should not get relicensing whatsoever. They 

9 have done the worst job in managing this plant. They do not follow good engineering principles. 

10 They’re making the same mistakes all over again. They should be shut down permanently, and 

11 they should not be relicensed. 

12 Comment: 14-18-OL; We haven’t done enough. We haven’t killed this monster yet. But, I 

13 think I had hopes that it would die a natural death. That as each plant reached the end of its 

14 operating license it would simply be pulled off the market for economic reasons. Now they’re 

15 trying to give us undead nuclear power plants. Nuclear zombie power plants. 

16 Comment: 14-20-OL; So, I wanted to thank everyone here for keeping up the fight. And I think 

17 Kevin has one more comment about the next step would be after this comment period is over. 

18 We’ll submit comments. But after this is finished then we’re going to have interventions. Once 

19 they grant the license. We’re expecting they’ll grant it. We’ll be able to perhaps put in one last 

20 line of defense to stop this monster. Let it die a natural death. So, here’s Kevin one last time. 

21 Comment: 31-1-OL; Hello my name is Suzanne Patser and I live in Columbus Ohio and I’m 

22 very concerned about the Davis-Besse plant coming back online. I can’t think of anything that 

23 would be a worse idea for our state. 

24 Comment: 31-5-OL; So I am absolutely 100% against any nuclear plant opening anywhere. It 

25 is not the type of energy that our country needs, our State needs, that Toledo needs that 

26 anybody needs that lives or works in that area. 

27 Comment: 33-1-OL; Hello my name is Scott Robinson from Worthington Ohio and I’m opposed 

28 to the relicensing of the Davis-Besse nuclear power plant. Thank you. 

29 Comment: 34-2-OL; It puts people in Toledo especially in danger and could possibly extend as 

30 far south as Columbus. So I really do not think that this should be renewed. 

31 Comment: 35-1-OL; I’m Emily Journey and I’m from Westerville Ohio. I’d like you to know that 

32 I do not support the relicensing of the Davis-Besse Atomic reactor. 

33 Comment: 36-4-OL: So because of the ongoing contamination and the inherent nature of the 

34 radioactive contamination in the process of it being mined and transported. I would like the 

35 commission to look very closely at this and do what we all know is correct and keep 

36 Davis-Besse closed. 

37 Comment: 37-1-OL; Alright. I’m totally against the nuclear power. I just I’m an old guy and 

38 I’ve been around for many years and I know the history damages that it can cause and I’m really 

39 opposed to it. That’s why I’m on camera here. That’s why I’m on camera and I will do whatever 

40 I can to support the cause against it. The actions, take actions against it. That what all I got to 

41 say. Thank you very much. 
Appendix A

A-38

1 Comment: 38-2-OL; By all means please do not approve the relicensure of Davis-Besse. 

2 Thank you

3 Comment: 39-5-OL; I’m very disconcerned for the future of our children and future generations 

4 in terms of the toxicity and global warming. Also we don’t need this energy and it is just not a 

5 good way for our country to be going. Thank You

6 Comment: 40-1-OL; My name is Bernadine Kent and I’m from Columbus Ohio and I have been 

7 informed of the Davis-Besse power plant in Toledo. I’m concerned about this plant extending 

8 their license for the next 20 years. To me that doesn’t make any sense especially since they 

9 have problems. 

10 Comment: 42-1-OL; My name is Pete Johnson I’m associated with the Columbus free press 

11 and citizens alliance for secure elections and I’m definitely opposed to relicensing Davis-Besse.

12 Comment: 43-1-OL; Basically I mean I’ve heard a lot of the science about it and I can’t really 

13 say a whole lot about that. But what I can say is that you it’s going to be relicensed supposedly 

14 for 20 more years and that would be to 2037, I believe, so I’m opposed to the relicensing of 

15 Davis-Besse because I think it’s a youth issue and basically this is an important youth issue its 

16 important to the young people who are not allowed to vote and be politically active and children 

17 and the future generations. 

18 Comment: 16-14-OL; Hi my name is Patricia Marida. I’m the chair of the nuclear issues 

19 committee at the Ohio Sierra Club. I gave a presentation before the Nuclear Regulatory 

20 Commission on November 4, 2010, as to why the Sierra Club opposes the extension of a 

21 license at Davis-Besse. 

22 Comment: 16-15-OL; Tonight I’m going to give my personal statement. I think that it’s well 

23 recorded there are 10 pages of documentation of very serious violations and illegalities, and 

24 actually nuclear accidents at Davis-Besse. It is the most accident ridden power plant, nuclear 

25 power plant in the nation. It is very clear that we have a serious problem here also because the 

26 Nuclear Regulatory Commission has been very laxed in enforcing Davis-Besse. In fact allowing 

27 them to, allowing FirstEnergy and Davis-Besse Operating Company to continue operating the 

28 plant when it was supposed to be shut down for an inspection. And the reactor head came 

29 within 1/8" or metal left between containment and a nuclear holocaust. So It is very clear that 

30 the regulatory and the supervision is lacking were also would like the NRC to be sure to cover 

31 the safety issues there, there are many safety issues. 

32 Comment: 47-1-OL; First Energy should not be allowed to continue to operate Davis-Besse 

33 after 2017. The people of Northeast Ohio are familiar with First Energy’s pathetic record in 

34 protecting the safety of people who live in the region. 

35 Comment: 48-1-OL; We are area residents near the Davis-Besse plant as we live in Wood 

36 County. We would like to have this nuclear power plant eliminated. We say the article about it 

37 in our local paper, the Sentinel-Tribune. It is an old plant and has had a history of 

38 accidents/problems. 

39 Comment: 14-14-OL, 14-16-OL, 14-17-Ol, 14-18-OL, 14-20-OL, 16-14-OL, 16-15-OL, 

40 30-1-OL, 34-3-Ol, 34-7-OL, 39-6-OL, 39-10-OL, 43-4-OL, 44-2-OL, 50-1-OL, 51-1-OL, 

41 52-1-OL, 53-1-OL, 54-1-OL, 55-1-OL, 56-1-OL, 57-1-OL, 58-1-OL, 59-1-OL, 60-1-OL, 61-1-OL, 

42 62-1-OL, 63-1-OL, 64-1-OL, 65-1-OL, 66-1-OL, 67-1-OL, 68-1-OL, 69-1-OL, 70-1-OL, 71-1-OL, 

43 72-1-OL, 73-1-OL, 74-1-OL, 75-1-OL, 76-1-OL, 77-1-OL, 78-1-OL, 79-1-OL, 80-1-OL, 81-1-OL, 
Appendix A

A-39

1 81-6-OL, 82-1-OL, 83-1-OL, 84-1-OL, 85-1-OL, 86-1-OL, 87-1-OL, 88-1-OL, 89-1-OL, 

2 90-1-OL; Ohioans are concerned about the environment, the rising costs of energy, and the 

3 dangers associated with nuclear power! However, that has not stopped First Energy from 

4 irresponsibly pursuing to get the Davis-Besse nuclear plant on Lake Erie relicensed to continue 

5 operation until 2037. 

6 Comment: 30-5-OL, 43-8-OL, 44-6-OL, 50-5-OL, 51-5-OL, 52-5-OL, 54-5-OL, 55-5-OL, 

7 56-5-OL, 57-5-OL, 58-5-OL, 59-5-OL, 60-5-OL, 61-5-OL, 62-5-OL, 63-5-OL, 64-5-OL, 65-5-OL, 

8 66-5-OL, 67-5-OL, 68-5-OL, 70-5-OL, 71-5-OL, 72-5-OL, 73-5-OL, 76-5-OL, 77-5-OL, 78-5-OL, 

9 79-5-OL, 80-5-OL, 81-10-OL, 82-5-OL, 83-5-OL, 84-5-OL, 85-5-OL, 86-5-OL, 87-5-OL, 

10 88-5-OL, 89-5-OL, 90-5-OL; Dear Nuclear Regulatory Commission, please say NO to 

11 Davis-Besse! Make them accountable for the lapses in safety and help protect Ohioans from a 

12 potential disaster at Davis-Besse. 

13 Comment: 53-5-OL; Until nuclear power can be made safe for the environment by solving the 

14 waste problem, I do not want it to continue in operation. Dear Nuclear Regulatory Commission, 

15 please say NO to Davis-Besse! Make them accountable for the lapses in safety and help 

16 protect Ohioans from a potential disaster at Davis-Besse. 

17 Comment: 69-5-OL; Now is not the time to expand nuclear energy in Ohio. Dear Nuclear 

18 Regulatory Commission, please say NO to Davis-Besse! Make them accountable for the lapses 

19 in safety and help protect Ohioans from a potential disaster at Davis-Besse. 

20 Comment: 70-5-OL; These plants have been a financial leach on the people long enough! 

21 Dear Nuclear Regulatory Commission, please say NO to Davis-Besse! Make them accountable 

22 for the lapses in safety and help protect Ohioans from a potential disaster at Davis-Besse. 

23 Comment: 74-5-OL; Davis-Besse is not safe and we seem to want to wait until something 

24 really disastrous happens before anything is done—when it is too late! Nuclear energy is NOT 

25 clean energy and we have the perpetual problem of what to do with nuclear waste. Dear 

26 Nuclear Regulatory Commission, please say NO to Davis Besse! Make them accountable for 

27 the lapses in safety and help protect Ohioans from a potential disaster at Davis Besse. 

28 Comment: 77-5-OL; Davis-Bess is far too dangerous. Dear Nuclear Regulatory Commission, 

29 please say NO to Davis-Besse! Make them accountable for the lapses in safety and help 

30 protect Ohioans from a potential disaster at Davis-Besse. 

31 Comment: 81-5-OL; We are moving to Westlake, Oh. soon and don’t want to have to worry 

32 about unsafe Davis-Besse blowing up near us. I have read this petition and agree with it all. 

33 Dear Nuclear Regulatory Commission, please say NO to Davis Besse! Make them accountable 

34 for the lapses in safety and help protect Ohioans from a potential disaster at Davis Besse

35 Comment: 81-10-OL; Thank you for your prompt action on this matter for the safety and health 

36 of the People of Ohio. I have read this petition and agree with it all!!!! Dear Nuclear Regulatory 

37 Commission, please say NO to Davis-Besse! Make them accountable for the lapses in safety 

38 and help protect Ohioans from a potential disaster at Davis-Besse. 

39 Response: These comments are general in nature and express opposition to FENOC, nuclear 

40 power, the license renewal of Davis-Besse, or all of these. The majority of these comments 

41 express opposition for reasons outside the scope of license renewal. Expanded responses to 

42 these comments are documented in the Davis-Besse Scoping Summary Report. Those 

43 comments that express opposition for in-scope reasons are documented in the applicable 
Appendix A

A-40

1 technical area within this appendix. The NRC did not evaluate these comments in the 

2 development of the SEIS, as they did not provided any new and significant information.

3 A.1.9 Postulated Accidents & SAMA (PA)

4 Comment: 14-8-PA; I think an environmental review needs to look at what would happen if the 

5 concrete wall either collapsed from radiation or if the perimeter was destroyed through the 

6 attack of a plane or through the attack of some motorist or some terrorist group planting 

7 explosives. What would happen to the radioactive dust and the containment structure because 

8 of the weakening?

9 Comment: 16-12-PA; And, I would like to add also that the pools of radioactive waste are 

10 extremely vulnerable to terrorists attacks or to other explosions. So, that certainly should be a 

11 consideration of the NRC to look at; that is, how are we going to protect those pools of 

12 radioactive waste?

13 Response: These comments express concern for the potential adverse environmental impacts 

14 associated with postulated accidents. The comments also raise concerns that the GEIS and 

15 SEIS do not adequately evaluate the possible impacts of beyond-design-basis accidents 

16 initiated by terrorist attacks or sabotage. Under 10 CFR 51.53(c)(3)(ii)(L), license renewal 

17 applicants must consider alternatives to mitigate severe accidents if the staff has not previously 

18 evaluated SAMAs for the applicant’s plant in an environmental impact statement or related 

19 supplement or in an environmental assessment. The purpose is to ensure that potentially cost20 beneficial, aging-related plant changes (i.e., hardware, procedures, and training) with the 

21 potential for improving severe accident safety performance are identified and evaluated

22 An analysis was developed to support offsite consequence estimates for Level 3 probabilistic 

23 risk assessments of severe accidents at light water reactors. Such assessments have long 

24 served as the foundation for NRC regulatory decisions, which include analyses of health and 

25 safety, land contamination, and economic consequences (NRC, 2009). A description of the 

26 code that was used to perform the calculations of the offsite consequences of a severe accident 

27 for Davis-Besse can be found in NUREG/CR 6613, Code Manual for MACCS2: Volumes 1 

28 and 2 (NRC, 1998). It is beyond the scope of the Environmental Report (ER) and the SEIS to 

29 describe in detail the code’s analytical process. However, a description of the application of the 

30 MACCS2 code for the Davis-Besse analysis has been provided in the relevant portions in 

31 Appendix F of this SEIS.

32 The SEIS provides a site-specific evaluation of SAMAs in Chapter 5 and Appendix F. However, 

33 in the GEIS, the NRC staff did evaluate existing impact assessments performed by the NRC 

34 and by industry at 44 nuclear plants in the United States and concluded that the risk from 

35 beyond-design-basis accidents at existing nuclear power plants would be small. 

36 With respect to spent fuel pool accidents, onsite storage of spent fuel is considered a 

37 Category 1 issue, which was evaluated in the GEIS; therefore, accidents would be 

38 encompassed by the analysis of the Category 1 issue of onsite spent fuel storage. As such, the 

39 need for mitigation alternatives within the context of renewal has been considered, and the 

40 Commission concludes that its regulatory requirements already in place provide adequate 

41 mitigation incentives for onsite storage of spent fuel. No discussion of mitigation alternatives is 

42 needed in an LRA because the Commission has generically concluded that additional site 

43 specific mitigation alternatives are unlikely to be beneficial (NRC, 1996). In addition, the NRC 
Appendix A

A-41

1 staff did not find any new and significant information that would call the analysis of the Category 

2 1 issue into question.

3 A detailed discussion of Postulated Accidents and SAMAs can be found in Chapter 5 and 

4 Appendix F of this SEIS.

5 Comment: 14-9-PA; We are in an area of the country that could be affected by the fault if there 

6 is a large earth quake, and I think this may not have been examined sufficiently in the 

7 environmental impact study.

8 Response: The comment expresses concern for the seismic design of Davis-Besse. The 

9 seismic design of the plant is outside the scope of the environmental review; however, 

10 structures that are in scope of license renewal are examined and the results are documented in 

11 the publication of NRC’s Davis-Besse safety evaluation report (SER). 

12 Results of prior geologic, seismologic, and subsurface investigations indicate no evidence of 

13 fault traces, offset geomorphic features, shear zones, faults, sand boils, soil flows, or any other 

14 direct or indirect physical effects of prior earthquakes. The nearest fault is the Bowling Green 

15 Fault, which is located 35 miles west of the site. Geologic, including seismic, information is 

16 presented in Chapter 2 of this SEIS. 

17 Insofar as the comments suggest that a seismic event during the period of license renewal 

18 could result in environmental impacts, such impacts were considered as part of the SEIS 

19 discussion of severe accidents initiated by external phenomena and by the GEIS in its “Review 

20 of Existing Impacts.” As discussed in Chapter 5 of the draft SEIS, the NRC staff evaluated the 

21 risk of beyond-design-basis earthquakes at existing nuclear power plants, and determined that 

22 the risk from such events is SMALL; further, the NRC determined that the risks from other 

23 external events are adequately addressed by the generic consideration of internally-generated 

24 severe accidents in the GEIS, and that this issue should be considered on a site-specific basis 

25 in a plant’s SAMA analysis. FENOCs SAMA analysis included a search for mitigation measures 

26 for accident scenarios initiated by fire and seismic external events. A detailed discussion can 

27 be found in Chapter 5 and Appendix F of this SEIS. 

28 Additionally, the NRC has directed operators of nuclear power plants to reaffirm their existing 

29 abilitiy to resist earthquakes and flooding as a result of the accident at the Fukushima Dai-ichi 

30 nuclear power plants in 2011. Plant-specific actions taken in reponse to lessons learned from 

31 the Fukushima Dai-ichi accident can be found at: http://www.nrc.gov/reactors/operating/ops32 experience/japan-dashboard/japan-plants.html. 

33 A.1.10 Radioactive & Non-Radioactive Waste (RW)

34 Comment: 20-2-RW; Kevin already mentioned this, but, the expectation when Davis-Besse 

35 and all the other nuclear reactors were built was that would mean that there would be a federal 

36 repository for all of the high-level nuclear waste and that is not available. And as Kevin 

37 mentioned, the Yucca Mountain, facility has been, the funding for it has been discontinued, it 

38 has no operating license. That means that for 33 years, all of the high-level radioactive waste 

39 generated at Davis-Besse are still being stored on-site, initially in a cooling pool, as I understand 

40 it, and then, a few years ago, they, they constructed above-ground containers for the fuel after it 

41 cools off, in this pool. So, my, position would be that no nuclear plant license extensions should 

42 be granted until there’s a long-term storage facility available for these nuclear wastes. And, one 

43 of the troubling indicators, I think, is I read through the Environmental Study that is, is mandated 

44 for this license extension. 
Appendix A

A-42

1 Comment: 23-7-RW; There’s no place to put the waste and we believe that it is immoral to 

2 burden our children and generations far into the future with deadly waste.

3 Comment: 24-1-RW; At that time, planning for the long term containment of the radioactive 

4 waste was to be done in the future. We now know that we still do not have any methods 

5 approved for the long term storage and isolation of the tons of spent radioactive rods and other 

6 radioactive material that is made during the mining and processing of the fuel. This material will 

7 be dangerously radioactive to humans and other living things for hundreds of thousands of 

8 years. To put that into perspective, we will be starting on the year 2011 of the common era on 

9 January 1st. 

10 Comment: 26-11-RW; In addition there is a ISFSI. It’s dry cask storage of high level nuclear 

11 waste. High level nuclear waste is currently stored outside at the Davis-Besse. This has 

12 a..there..No one wants this nuclear waste. Yucca Mountain is not going to happen. It’s not 

13 geologically sound. It’s not scientifically sounds. It’s not going to happen. Nobody wants this 

14 stuff. Yet, the NRC runs a con game. They have “confidence” a “waste confidence” decision. It 

15 is a con game. They’re asking the public, the folks of Toledo, of Ohio, “Please accept our 

16 promise to take this waste at some point. We don’t know what to do with it just yet. But, we’ll 

17 figure it out later on. But, in the meantime just let us go and make more.” It’s been said that 

18 nuclear power is the gift that keeps on giving. It keeps on giving the radioactive waste, and the 

19 power is fleeting. But we are left with the deadly lethal legacy for tens of thousands of years. 

20 Comment: 39-1-RW; My name is Connie Hammond I live in Columbus Ohio. I’m a member of 

21 the Sierra Club nuclear issues committee and the Ohio Green party. My primary concern is with 

22 the toxic legacy that we are leaving for our Children and Grandchildren. Beyond the obvious 

23 radioactivity and pollution that these plants produce. 

24 Response: These comments address concerns regarding the management of radioactive 

25 waste at the Davis-Besse site. 

26 No new and significant information is provided in these comments. Therefore, no changes have 

27 been made to the SEIS because of these comments. The management of radiological and non28 radiological waste is discussed in Chapter 2 of this SEIS. In addition, Chapter 6 of this SEIS 

29 contains information on spent nuclear fuel.

30 Comment: 24-4-RW; Originally nuclear power was touted as power that would be produced so 

31 cheaply that it would not even have to be metered. Now we are being told that it will solve the 

32 problem of pollution generated by using fossil fuels. We will be replacing carbon problems of 

33 pollution, generated by using fossil fuels, with problems of radioactive pollution for which there is 

34 no cleanup but time. 

35 Comment: 36-1-RW; Hi my name is Bob Patraicus, I have a PhD in political Science. I am a 

36 JD. My concerns with Davis-Besse begin with the obvious. There has been contamination. 

37 Radioactive contamination at that plant in the past it continues to occur. Moreover the entire 

38 process of mining transporting and allowing radioactivity as a fuel source is inherently 

39 contaminating. 

40 Comment: 43-2-RW; A lot of the people who are working to relicense this nuclear facility are 

41 going to have died of old age by the time its finished and then when it’s finished we are going to 

42 need to worry about cleaning it up keeping it in repair and I don’t think that people are really 

43 looking ahead to the future and considering you know the work that is going to be involved to 

44 make sure that its safe. Nuclear waste and radioactivity has a half life of gabillion years to put it 
Appendix A

A-43

1 in kids terminology and you know a lot of the people who are going to be effected by nuclear 

2 waste are not even born yet. And so speaking on behalf of the youth, babies, people who 

3 cannot speak for themselves. I just wanted to say that relicensing Davis-Besse and using 

4 nuclear energy is wrong. It may be expedient for the people who are only planning on living you 

5 know 10 or 20 more years then fine but they don’t care if the world is going to be destroyed. But 

6 there are people who that effects and I would just urge the people who are making this decision 

7 to think of the future generations and to be able to think about somebody other than yourselves 

8 really. 

9 Comment: 16-4-RW; Contamination occurs throughout the milling, refining, transport and 

10 conversion of uranium to uranium hexafluoride and then enrichment in which the gaseous 

11 diffusion process took as much energy as a large city to enrich the uranium. Then additional 

12 uranium must be formulated to ground. An enormous waste - - uranium hexafluoride which is 

13 99 percent of the original uranium but is not fissionable and, therefore, not useable for energy. 

14 However, it is just as radioactive and must be then converted back to the more stable uranium 

15 oxide. A newly-operated plant at Piketon will take 25 years running around the clock to 

16 deconvert the 40,000, 14-ton canisters containing hexafluoride that are already on the site, and 

17 that is not counting how much more that might be generated from other conventional facilities, 

18 enormous amounts of energy due to this process. 

19 Comment: 16-24-RW; The Sierra Club opposes nuclear energy in its entirety, citing serious 

20 environmental, health, and public expense issues throughout the nuclear fuel cycle. The time 

21 frames needed to guard the radioactive nuclear waste generated from this process are geologic 

22 in nature. Isolating the radioactive nuclear waste will consume public time and money for 

23 generations to come. The only viable solution for radioactive waste is to stop generating it. 

24 Radioactive contamination and waste are a major reason to discontinue the use of nuclear 

25 power. The risk and reality is that radioactive contamination has occurred, is occurring and will 

26 continue to occur throughout the nuclear power cycle. Mining is leaving radioactive tailings 

27 exposed to the air and water on First Nations land in the US, Canada, and Australia. 

28 Contamination occurs throughout the milling, refining, transport, conversion of uranium to 

29 uranium hexafluoride (UF6), and then enrichment - which in the gaseous diffusion process at 

30 Piketon, Ohio, took as much energy as a large city. Then the fissionable uranium must be 

31 formulated into rods. An enormous waste stream is the depleted uranium hexafluoride (DUF6), 

32 which is 99% of the original uranium but is not fissionable and therefore not usable for energy. 

33 However, it is just as radioactive and must be deconverted back to the more stable uranium 

34 oxide. A newly operating plant at Piketon will take 25 years running round-the-clock to 

35 deconvert the 40,000 14-ton canisters of DUF6 already on the site, not counting how much 

36 more will be generated from other enrichment facilities. 

37 Comment: 32-1-RW; Hi my name is James Whitaker and I’m from in Columbus Ohio and as 

38 far as the creation of more radioactive waste here in the state of Ohio I don’t think we need to 

39 do that I think that the any of the fuels that we have as far as fossil fuels is adequate if it’s done 

40 properly. But I certainly don’t want to create more nuclear waste.

41 Comment: 16-18-RW; So the fleeting use of electricity in the past has left us with a legacy of 

42 nuclear waste. But however we understand that the Nuclear Regulatory Commission does not 

43 have to even consider that when they are deciding whether or not to license Davis-Besse 

44 because in the past the Nuclear Regulatory Commission has made a decision that they are not 

45 going to, that this doesn’t have anything to do with a new license despite the fact that much 

46 more of this dangerous radioactivity is going to be stored at the plant there is no solution for it 

47 there is no magic solution that will turn lead into gold it will remain radioactive for millions of 
Appendix A

A-44

1 years and will gradually spread itself around. It is so important for the Nuclear Regulatory 

2 Commission to look at issues of the onsite storage and to look at containing at least in the near 

3 future making this waste safe. The new waste is going to be generated there really does need 

4 to be a plan for isolating it onsite. We are not asking for a plan to isolate it for a hundred million 

5 years because we all know that’s an impossibility. We are asking for some sort of a plan 

6 working with Doctor Arjun Makhijani of the Institute for Environmental and Economic Research 

7 in Washington DC, we are asking for you the NRC to work with him and look at some serious 

8 ways of isolating this waste in canister that are hidden in bunkers where they are safe from 

9 terrorist attack.

10 Comment: 30-3-RW, 34-5-RW, 39-8-RW, 43-6-RW, 44-4-RW, 50-3-RW, 51-3-RW, 52-3-RW, 

11 53-3-RW, 54-3-RW, 55-3-RW, 56-3-RW, 57-3-RW, 58-3-RW, 59-3-RW, 60-3-RW, 61-3-RW, 

12 62-3-RW, 63-3-RW, 64-3-RW, 65-3-RW, 66-3-RW, 67-3-RW, 68-3-RW, 69-3-RW, 70-3-RW, 

13 71-3-RW, 72-3-RW, 73-3-RW, 74-3-RW, 75-3-RW, 76-3-RW, 77-3-RW, 78-3-RW, 79-3-RW, 

14 80-3-RW, 81-3-RW, 81-8-RW, 82-3-RW, 83-3-RW, 84-3-RW, 85-3-RW, 86-3-RW, 87-3-RW, 

15 88-3-RW, 89-3-RW, 90-3-RW; NUCLEAR ENERGY IS NOT CLEAN OR GREEN ENERGY! 

16 Every nuclear reactor generates about 20 tons of highly radioactive waste per year, and after 40 

17 years of nuclear power, the U.S. still has not found an acceptable solution for the waste. The 

18 waste can cause cancer, birth defects, and even death. Nuclear power uses and pollutes 

19 significant amounts of water, while the mining, transportation, and enriching of uranium is 

20 carbon intensive which contributes to global warming.

21 Response: These comments express concern over the uranium fuel cycle and of the 

22 management of nuclear waste. The environmental impacts of the uranium fuel cycle and solid 

23 waste management are contained in Chapter 6 of this SEIS. 

24 No new and significant information is provided in these comments. Therefore, no changes have 

25 been made to the SEIS because of these comments.

26 A.1.11 Socioeconomics (SE)

27 Comment: 1-1-SE; Good afternoon. My name is Mark Stahl, and I’m the President of Ottawa 

28 County Commissioners. Ottawa County is successful because we surround ourselves with 

29 successful community partners, and Davis-Besse is one of those community partners, who we 

30 look very favorably upon. You will hear from some other agencies, the nonprofits, the 

31 contributions that you make back to our community helps us tremendously, and we greatly 

32 appreciate that. We also as Commissioners appreciate our NRC partnership. We have had 

33 conversations with you, I know, through the years, and we appreciate those unbiased 

34 conversations that we’ve had in regard to Davis-Besse.

35 Comment: 2-3-SE; Many of the Davis-Besse employees live in the community and are 

36 important assets to Ottawa County. I think it’s very important that the corporate structure that’s 

37 been put in place to oversee the operations of Davis-Besse continue, and I think it’s a good 

38 structure.

39 Comment: 4-1-SE; I’m Chris Galvin, Director of the United Way in Ottawa County. The 

40 Davis-Besse Nuclear Power Station and on a larger scale the First Energy Corporation are a 

41 tremendous community partner to the local United Way. Since 1993, First Energy has 

42 contributed more than 13.5 million dollars to United Way of Greater Toledo which serves 

43 Ottawa, Wood and Lucas Counties. 3.1 million came from corporate gifts, 10.4 million from its 

44 incredibly generous employees. First Energy has also earned United Way’s Pillar Award each 
Appendix A

A-45

1 year since at least 1992. Our data doesn’t go back any further than that. It seems they 

2 consistently give more than a hundred thousand dollars each year to the Greater Toledo 

3 campaign. Not only does this community consistently get solid financial support from First 

4 Energy and its employees, but executive leadership has also demonstrated exceptional 

5 personal commitment to our work. In 1993, Don Saunders chaired the local United Way 

6 campaign, raising 12.5 million Dollars. In 2005, Jim Murray, now retired, but formerly First 

7 Energy President of Ohio Operations, chaired the local United Way campaign. Under Mr. 

8 Murray’s leadership, the campaign raised 13.3 million Dollars. We also presented Mr. Murray 

9 with our Prestigious Caring Award in 2006 for demonstrating value and concern for our 

10 community through vision, leadership, service and commitment to the people of our community. 

11 In 2009, Trent Smith, Regional President of Toledo Edison First Energy, became chairman of 

12 the United Way of Greater Toledo’s Board of Trustees and has drawn to a close on his second 

13 year of service. Mr. Smith has gone above and beyond the level of service, dedication and 

14 commitment we typically see from board chairs. He has become involved in virtually every level 

15 of our work, digging in and helping find real solutions. In addition to these executive leaders, 

16 numerous upper-level management have supported United Way by using their voice and 

17 relationships to help secure financial and volunteer support as well as advocating on behalf of 

18 the United Way and the Northwest Ohio Region. In addition to 

19 Don Saunders, Jim Murray, and Trent Smith, some of the stand-out employees include Debbie 

20 Paul, Mike Adams, and Mel Lomack. Additionally, in the 1990s Jennifer Schreiber served five 

21 years as the chair of our community impact cabinet, the highest level of community impact 

22 volunteers who decide how money is allocated in this community. Also joining her on the 

23 cabinet was Jenny Ammadon. Both are not retired. First Energy also demonstrates incredible 

24 commitment to the communities through sponsorships and/or participation in programs and 

25 events. In 1993 and 1994, Davis-Besse sponsored our loaned executive program. Jim Ferris, 

26 now retired from Davis-Besse, was the landed executive in those two years. First Energy has 

27 also sponsored loaned executives over the years, from 1996 continuing for 11 years. 

28 Employees consistently contribute to and participate in Stamp Out Hunger and/or Scouting for 

29 Food efforts each year. They were a major sponsor of our Family Food Fund in 2008. First 

30 Energy was the sponsor of our Community Building event in 2005, and was the initiator and 

31 sponsor of the Veterans Appreciation Event in 2006, which continued until 2009.

32 Comment: 5-1-SE; On behalf of the Union, I would like to voice our support in this public. A 

33 renewal of this license will not only promote and maintain employment for our members who live 

34 and shop and send their children to school in that area, but it will also assure the delivery of 

35 reliable electric service to our customers. 

36 Comment: 8-2-SE; We also because we have the mandate but we do not receive government 

37 funds, I can speak to what Chris Galvin of United Way said with regards to the money that 

38 comes into the United Way. We are a United Way Agency, but even besides that, we have 

39 profited, the Red Cross organization, from financial support on many levels from First Energy 

40 and Davis-Besse as well as from the volunteer aspect of the employees that respond through 

41 the involvement of their families. We have three or four blood drives that we conduct at 

42 Davis-Besse that are very successful. We have had a lot of leadership that has come out of the 

43 Davis-Besse plant. Chuck Witt was a six-year chairman for our local advisory board. Currently, 

44 Terry Mortis, who is the Regional Manager also of the Ottawa County District with First Energy 

45 that provides a lot of leadership, a lot of guidance to the Red Cross. 

46 Comment: 9-2-SE; Davis-Besse over the years has provided a good living, a good income for 

47 many residents of Ottawa County and surrounding counties and especially now in a time when 

48 unemployment is high. 
Appendix A

A-46

1 Comment: 10-1-SE; Davis-Besse has been very generous with their donations to the Food 

2 Pantry in the past years. I also would like to say that if it were to close, they may be coming to 

3 our Food Pantry, and I would hate to see that. 

4 Comment: 11-2-SE; It is also important from a license renewal aspect, 20 additional years of 

5 this asset to provide for the employment opportunities for the local community, and many of our 

6 young engineers are graduating from college today who wonder if nuclear power is a viable 

7 future and a career path. It’s important to know that plants such as Davis-Besse and others are 

8 undergoing renewal process have a future that they can depend on. 

9 Comment: 12-4-SE; By extending the license here at Davis-Besse, it would continue to provide 

10 good clean power that’s critical. In addition to that, also supporting the much-needed tax base, 

11 not only to this area but to the State, and I’m confident along with our members, that IBEW, 

12 Local 245, that Davis-Besse will continue to be safe, not only for the employees but also for the 

13 area.

14 Comment: 1-3-SE; And, the county isn’t successful unless you’re surrounded by successful 

15 community partners, and I can tell you that Brush-Romley (ph) is one of those partners. They 

16 contribute tremendously to the good of this community. We also cherish the NRC’s partnership 

17 that we have. You are our eyes and our ears. You are what helps us maintain the public safety 

18 here, and we appreciate that as well. 

19 Comment: 2-5-SE; So I’ve had some broad experience with the Davis-Besse people and with 

20 the Nuclear Regulatory Commission, and I think this process and the processes that the NRC 

21 uses are great processes, but I think it’s important to know that when we look at what 

22 Davis-Besse has done over the years and how they have responded to Ottawa County as a 

23 community, we couldn’t have asked for anything more. 

24 Comment: 15-2-SE; The renewal of this license will promote maintaining employment of not 

25 only our members who live and shop and send their children to the schools in this area, but it 

26 will also ensure the delivery of reliable electric service to all of our customers. 

27 Comment: 11-5-SE; We have long-term employment opportunities for the surrounding 

28 communities. Younger engineers graduating from college need to know that the nuclear power 

29 is very efficient and is a great career. Davis-Besse has a significant impact on the economy of 

30 the local area, providing folks, several hundred people employment, providing materials and 

31 service in support of the operation of the plant. We have always had a commitment to ensure 

32 public safety and a protection of the environment, and that commitment continues today. As 

33 you have already heard from several of those speakers, we enjoy a good relationship with the 

34 surrounding communities, and we look forward to sustaining this relationship for an additional 

35 20 years. 

36 Comment: 4-3-SE; The Davis Besse Nuclear Power Station, and on a larger scale, the First 

37 Energy Corporation, are the tremendous community partner to the local United Way. Since 

38 1993, First Energy has contributed more than $13.5 million to United Way of Greater Toledo 

39 which serves Ottawa, Wood, and Lucas counties. $3.1 million came from corporate gifts. 

40 $10.4 million from its incredibly generous employees: First Energy has also earned United 

41 Way’s Pillar Award each year since at least 1992...which means they consistently give more 

42 than $100,000 each year to the greater Toledo campaign. Not only does this community 

43 consistently get solid financial support from First Energy and its employees, but executive 

44 leadership has also demonstrated exceptional personal commitment to our work. In 1993, Don 

45 Saunders chaired the local United Way campaign, raising $12.5 million. In 2005, Jim Murray, 
Appendix A

A-47

1 now retired, but formerly First Energy President of Ohio Operations, chaired the local United 

2 Way campaign. Under Mr. Murray’s leadership, the campaign raised $13.3 million. We also 

3 presented Mr. Murray with our prestigious Spirit of Caring award in 2006 for demonstrating 

4 value and concern for our community through vision, leadership, service, and commitment to 

5 the people of our community. In 2009, Trent Smith, regional president of Toledo Edison/First 

6 Energy, became chairman of United Way of Greater Toledo’s Board of Trustees and is drawing 

7 to a close on his second year of service. Mr. Smith has gone above and beyond the level of 

8 service, dedication, and commitment we typically see from Board chairs. He has become 

9 involved in virtually every level of our work, digging in and helping find real solutions. In addition

10 to these executive leaders, numerous upper level management have supported United Way by 

11 using their voice and relationships to help secure financial and volunteer support as well as 

12 advocating on behalf of United Way and the NW Ohio region. In addition to Don Saunders, Jim 

13 Murray, and Trent Smith, some of these standout employees include Debbie Paul, Meg Adams, 

14 and Mel Womack. Additionally, in the 1990s, Jennifer Shriver served five years as the chair of 

15 our Community Impact Cabinet, the highest level of community impact volunteers who decide 

16 how money is allocated in the community. Also joining her on the cabinet was Jenny Amidon. 

17 Both are now retired. First Energy also demonstrates incredible commitment to the community 

18 through sponsorships of or participation in programs and events. In 1993 and 1994, Davis 

19 Besse sponsored our Loaned Executive program, a program that provides United Way with 

20 temporary campaign employees. First Energy began sponsoring this program in 1996 and 

21 continued for 11 years. Employees consistently contribute to and participate in Stamp Out 

22 Hunger and/or Scouting for Food efforts each year. They were a major sponsor of our Family 

23 Food Fund in 2008. First Energy was a sponsor of our Community Building Event in 2005 and 

24 was the initiator and sponsor of our Veterans’ Appreciation Event in 2006 which continued until 

25 2009. 

26 Comment: 15-6-SE; A renewal of this license will promote and maintain employment of not 

27 only our members, who live and shop and send their children to schools in this area, but...it will 

28 assure the delivery of reliable electric service to all our customers. 

29 Comment: 25-5-SE; And economically, as we all know, and others have testified to, nuclear 

30 power does not make economic sense. In as much as our economy is the management of our 

31 household, I think it relates directly to the ecology of our house or our State or our community 

32 here, and that ecological system that we are all part of and that this nuclear power plant and the 

33 NRC and the other governmental leaders and the other citizens that aren’t here, that ecosystem 

34 is very much a part of the environment, and any hearing that focuses on environmental impacts 

35 has to include all of that as the one ecosystem or environmental that we’re in. 

36 Response: These comments concern the socioeconomic impact of Davis-Besse. The majority 

37 of the comments are supportive of license renewal, the applicant, in general, and describe the 

38 socioeconomic benefits of Davis-Besse. Comment 25-5-SE expresses opposition to license 

39 renewal because of the environmental costs. The socioeconomic impacts of renewing the 

40 Davis-Besse operating license are discussed in Chapters 2 and 4. In addition, the 

41 socioeconomic impact of not renewing the operating license (no action alternative) is discussed 

42 in Chapter 8.

43 A.1.12 Support of License Renewal (SL)

44 Comment: 1-2-SL; So, I will let these two gentlemen fill you in, but as President of the Ottawa 

45 County Commissioners, I’m here to offer our support to you, Davis-Besse, in your application 

46 process.
Appendix A

A-48

1 Comment: 2-4-SL; We look forward to a license renewal. Ottawa County wants Davis-Besse 

2 to stay, and welcome them in the future and urge the NRC to move forward with this license 

3 renewal.

4 Comment: 3-2-SL; So, really, all this adds up to the fact that our relationship in Ottawa County 

5 with Davis-Besse is a benefit to the residents of Ottawa County

6 Comment: 4-2-SL; Davis-Besse and First Energy are a valued community partner, both 

7 philanthropically and economically. They have been incredible contributors to our community 

8 over the past 20 years, and we only hope that this will continue for at least another 20 years. 

9 Comment: 6-3-SL; So, it is opinion of the Black Swamp Bird Observatory that the Davis-Besse 

10 Nuclear Power Plant is a critical player in bird conservation in the entire region of the western 

11 hemisphere. 

12 Comment: 8-3-SL; I ask hard questions and I sometimes like the answers, sometimes I’m not 

13 so sure about the answers, but I am confident in the safety of the Davis-Besse plant and the 

14 good that it does in the community for the people that are involved. 

15 Comment: 9-3-SL; We support the license renewal, and we ask the NRC to support it as well.

16 Comment: 12-2-SL; In addition to that, we not only work out local issues but something more 

17 important or just as important. We work together on issues in Washington also through our 

18 labor management committee. A lot of people probably aren’t aware of that, but we do that 

19 through our Land Pact Committee. 

20 Comment: 1-4-SL; With that said, we’re going to have a few people from the Agency describe 

21 what Davis-Besse does for Ottawa County, and on behalf of the Ottawa County Commissioners, 

22 I would like to extend our full support in regards to their application. 

23 Comment: 15-1-SL; And, on behalf of the Union, I would like to voice our support at this public 

24 meeting for a multitude of reasons. 

25 Comment: 11-4-SL; This effort is important to us for several reasons. This licensing extension 

26 will allow us to continue to provide safe, reliable environmentally friendly electricity to our 

27 customers for years to come. Davis-Besse is an important asset, and the Company’s 

28 generation portfolio shows we have a good mix of power generation service. 

29 Comment: 4-4-SL; Davis Besse and First Energy are a valued community partner, both 

30 philanthropically and economically. They have been incredible contributors to our community 

31 over the past 20 years and we only hope this will continue for at least another 20. 

32 Comment: 15-5-SL; My name is Jane Ridenour and I am President of OPEIU Local 19. 

33 OPEIU stands for Office & Professional Employees International Union and we represent the 

34 clerical support staff at Davis Besse. On behalf of the Union I’d like to voice our support at this 

35 public meeting. 

36 Response: These comments are general in nature and express support for nuclear power or

37 the license renewal of Davis-Besse or both. The comments provide no new and significant 

38 information and will not be evaluated further. 
Appendix A

A-49

1 A.1.13 Terrestrial Resources (TR)

2 Comment: 6-1-TR; Our organization has been conducting migratory bird regions in this area 

3 for more than 20 years, and we really take pride in this marriage, and we work hard like a good 

4 spouse to maintain it. The marsh represents a critical stop-over habitat for millions of migratory 

5 birds. And, in fact, many the world’s leading bird experts consider this marsh to be one of the 

6 most critical areas of stop-over habitat in the entire western hemisphere. 

7 Comment: 6-2-TR; The observatory in these 20 years have had the full support of First Energy 

8 and Davis-Besse to conduct this critical research and, in fact, during a very exciting tumultuous 

9 time in this country’s history, we were very afraid that our consistent effort meaning that seven 

10 days a week, spring and fall, during song bird migration, our research staff was out at that 

11 marsh in front of the power tank conducting this research seven days a week for more than 20 

12 years. When the tragedy occurred on 9/11, we were very concerned for, of course, the human 

13 tragedy, but also concerned that our research would be interrupted. And, in fact, Davis-Besse 

14 really fully understood the importance of this research, and the importance of conserving the 

15 integrity of the data set, and we didn’t miss a single day. And, perhaps nothing else, no other 

16 event in our history or recent history speaks more to how much they have said they understand 

17 the critical role that they play in local environmental and conservation issues than that event. 

18 So, based on our long-standing relationship, it is our opinion the Davis-Besse and First Energy 

19 have not only worked to fully understand and fully support the environmental issues for this local 

20 community, but have also fully embraced the role that they play in all of these issues. 

21 Response: The NRC staff agrees with the Black Swamp Bird Observatory in its 

22 characterization of Davis-Besse marsh habitat as critical stop-over habitat. Additionally, the 

23 NRC staff incorporated the Black Swamp Bird Observatory’s publically available research 

24 publications into Chapter 2 of the draft SEIS.

25 Comment: 45-1-TR; There are no Federal wilderness areas or designated critical habitat within 

26 the vicinity of the proposed site. Davis-Besse consists of 954 acres, of which approximately 

27 733 acres are marshland that is leased to the U.S. Government as part of the Ottawa National 

28 Wildlife Refuge. In a letter dated December 16, 2009, we provided comments to FENOC on the 

29 proposed 20-year renewal of the operating license for Davis-Besse. At this time we have no 

30 additional comments. 

31 Response: The NRC staff incorporated the U.S. Fish and Wildlife Services’ information 

32 provided in this comment into the draft SEIS, including the information in the referenced 

33 December 16, 2009, letter to FENOC, which was provided in Appendix C of FENOC’s ER.
Appendix A

A-50

1 Comment Letters and Meeting Transcripts

2 The following pages contain the comments, identified by commenter designation (from 

3 Table A-1) and comment number, from letters, e-mails, public scoping meeting

4 transcripts and the transcript from the People’s Hearing.
Appendix A

A-51

Commenter: Mark Stahl 

1-1-SE

1-2-SL
Appendix A

A-52

Commenter: Jere Witt

2-1-OS
Appendix A

A-53

2-1-OS

continued

2-2-OS
Appendix A

A-54

2-2-OS

continued

2-3-SE
Appendix A

A-55

Commenter: Fred Petersen

2-4-SL

3-1-OS
Appendix A

A-56

3-1-OS

continued
Appendix A

A-57

Commenter: Chris Galvin

3-1-OS

continued

3-2-SL

4-1-SE
Appendix A

A-58

4-1-SE

continued
Appendix A

A-59

4-1-SE

continued
Appendix A

A-60

Commenter: Jackie VanTress

4-1-SE

continued

4-2-SL
Appendix A

A-61

Commenter: Kimberly Kaufman

5-1-SE

5-2-AL

5-3-OS
Appendix A

A-62

6-1-TR

6-2-TR
Appendix A

A-63

6-2-TR

continued

6-3-SL
Appendix A

A-64

Commenter: Steve Inchak

6-3-SL

continued

7-1-OL

7-2-OS
Appendix A

A-65

7-2-OS

continued
Appendix A

A-66

7-2-OS

continued
Appendix A

A-67

7-2-OS

continued
Appendix A

A-68

7-2-OS

continued
Appendix A

A-69

Commenter: Beth Leggett

7-2-OS

continued

8-1-OS
Appendix A

A-70

8-1-OS

continued

8-2-SE
Appendix A

A-71

Commenter: Brad Goetz

8-3-SL

9-1-OS
Appendix A

A-72

Commenter: Ann Heckerd

9-1-OS

continued

9-2-SE

9-3-SL

10-1-SE
Appendix A

A-73

Commenter: Brian Boles

11-1-AL

11-2-SE

11-3-OS
Appendix A

A-74

Commenter: Larry Tscherne

11-3-OS

continued
Appendix A

A-75

12-1-OS
Appendix A

A-76

12-2-SL

12-3-AL

12-4-SE

12-5-OS
Appendix A

A-77

Commenter: Mark Stahl

1-3-SE

1-4-SL
Appendix A

A-78

Commenter: Jere Witt

1-4-SL

continued

2-5-SE

2-6-OS
Appendix A

A-79

Commenter: Mike Drusbacky

2-6-OS

continued
Appendix A

A-80

13-1-OS
Appendix A

A-81

Commenter: Joseph DeMare

13-1-OS

continued

14-1-LR
Appendix A

A-82

14-1-LR

continued

14-2-OS

14-3-AQ

14-4-HH
Appendix A

A-83

14-4-HH

continued

14-5-OS

14-6-OS

14-7-OS
Appendix A

A-84

14-9-PA

14-8-PA

14-10-HH
Appendix A

A-85

Commenter: Jane Ridenour

14-10-HH

continued

14-12-OL

14-11-OS
Appendix A

A-86

15-4-OS

15-1-SL

15-3-AL

15-2-SE
Appendix A

A-87

Commenter: Patricia Marida

16-1-LR

16-3-OS

16-2-OL
Appendix A

A-88

16-3-OS

continued

16-5-AM

16-4-RW
Appendix A

A-89

16-6-AL

16-7-AM

16-8-AL
Appendix A

A-90

16-10-OS

16-8-AL

continued

16-9-OS
Appendix A

A-91

16-10-OS

continued

16-11-OS
Appendix A

A-92

16-13-OS

16-11-OS

continued

16-12-PA
Appendix A

A-93

Commenter: Brian Boles

11-4-SL

11-5-SE
Appendix A

A-94

Commenter: Matthew Heyrman

11-5-SE

continued

17-1-OS
Appendix A

A-95

 

17-1-OS

continued
Appendix A

A-96

 
Appendix A

A-97

Commenter: Joseph DeMare

14-13-LR
Appendix A

A-98

Commenter: Anita Rios

14-14-OL

14-15-LR

14-16-OL
Appendix A

A-99

18-1-OL

18-2-OS

18-3-LR
Appendix A

A-100

18-4-LR

18-5-OS

18-6-OS
Appendix A

A-101

 

18-6-OS

continued

18-7-OL

18-8-OL
Appendix A

A-102

Commenter: Kevin Kamps

18-8-OL

continued
Appendix A

A-103

19-1-OS
Appendix A

A-104

19-1-OS

continued

19-2-OS

19-3-OS

19-4-OS

19-5-OS
Appendix A

A-105

19-5-OS

continued

19-6-OS
Appendix A

A-106

19-6-OS

continued

19-7-OS
Appendix A

A-107

19-7-OL

continued

19-8-OL
Appendix A

A-108

19-9-OL
Appendix A

A-109 

19-10-AQ

19-11-AL
Appendix A

A-110

Commenter: Joseph DeMare

19-11-AL

continued

14-17-OL
Appendix A

A-111

Commenter: Al Compaan

20-1-AL
Appendix A

A-112

20-2-RW

20-3-HY

20-4-HH
Appendix A

A-113

20-4-HH

continued

20-5-OS

20-6-AL
Appendix A

A-114

20-6-AL

continued

20-7-AL

20-8-AL
Appendix A

A-115

20-8-AL

continued

20-9-AL
Appendix A

A-116

20-9-AL

continued

20-10-AL
Appendix A

A-117

20-10-AL

continued

20-11-AL
Appendix A

A-118

20-11-AL

continued

20-12-AL
Appendix A

A-119

Commenter: Katie Hoepfl

21-1-AL
Appendix A

A-120

21-2-AL
Appendix A

A-121

21-2-AL

continued

21-3-AL
Appendix A

A-122

 Commenter: Tony Szilagye

21-3-AL

continued

22-1-OL

22-2-AQ
Appendix A

A-123

22-2-AQ

continued

22-3-AQ
Appendix A

A-124

22-4-HH

22-5-AQ

22-6-OS
Appendix A

A-125

22-6-OS

continued

22-7-OL

22-8-OS

22-9-AL
Appendix A

A-126

Commenter: Ed McArdle

22-9-AL

continued

23-1-LR
Appendix A

A-127

23-2-OL

23-3-AL

23-4-AL
Appendix A

A-128

23-4-AL

continued
Appendix A

A-129

23-5-OL

23-6-AM 

23-7-RW

23-4-AL

(continued)
Appendix A

A-130
Appendix A

A-131

Commenter: Phyllis Oster

24-1-RW

24-2-OS
Appendix A

A-132

Commenter: Davis Ellison

24-2-OS

continued

24-3-OL

24-4-RW
Appendix A

A-133

25-1-OL

25-2-LR
Appendix A

A-134

25-2-LR

continued

25-3-OS

25-4-AL
Appendix A

A-135

Commenter: Michael Keegan

25-5-SE
Appendix A

A-136

26-1-OL

26-2-LR

26-3-OS
Appendix A

A-137

26-3-OS

continued

26-4-LR

26-5-HH

26-6-HY
Appendix A

A-138

26-6-HY

continued

26-8-OS

26-9-AQ

26-7-HH

 (HY) 
Appendix A

A-139

26-9-AQ

continued

26-10-LR

26-11-RW
Appendix A

A-140

Commenter: Ralph Semrock

26-11-RW

continued

26-12-OL

27-1-OS
Appendix A

A-141

27-1-OS

continued
Appendix A

A-142

27-1-OS

continued
Appendix A

A-143

Commenter: Mike Leonardi

27-1-OS

continued

27-2-OL
Appendix A

A-144

28-1-HH
Appendix A

A-145

28-1-HH

continued

28-2-HH
Appendix A

A-146

 Commenter: Joseph DeMare 

28-3-LR

14-18-OL
Appendix A

A-147

Commenter: Unidentifiable Woman, 

29-1-AQ
Appendix A

A-148

29-2-AQ

29-3-HH
Appendix A

A-149

Commenter: Joseph DeMare

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Appendix A

A-150

Commenter: Kevin Kamps 

14-19-HH

continued

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Appendix A

A-151
Appendix A

A-152
Appendix A

A-153
Appendix A

A-154

Commenter: Suzanne Patser James Whitaker

Suzanne Patser

Hello my name is Suzanne Patser and I live in Columbus Ohio and I’m very 

concerned about the Davis-Besse plant coming back online. I can’t think of 

anything that would be a worse idea for our state. 

I believe that we have plenty of electricity. We do not need to bring this power plant 

back online. I don’t care how many jobs you think it might create or how much you 

want to justify the expense of building the plant to begin with but nothing is worth 

the lives of the people that are going to live near that plant and all of us because 

it’s going to affect everybody if there was any type of accident. 

I know there is always just radioactive leakage anyway that we aren’t even told 

about. 

There are so many other clean ways to provide energy. Wind Solar geothermal 

there is no reason to bring a nuclear plant online. There would have to be some 

other agenda involved we hope that is not military agenda. But we know that we 

don’t the electricity from that plant in this state. 

And we know that it had a hole in a very vulnerable spot earlier. We don’t trust the 

people that run these type of plants that the safety is there and regardless if it 

takes a million years to get rid of radioactive waste how is that a benefit to anybody 

and human kind or on this planet. 

So I am absolutely 100% against any nuclear plant opening anywhere. It is not the 

type of energy that our country needs, our state need, that Toledo needs that 

anybody needs that lives or works in that area.

James Whitaker

Hi my names is James Whitaker and I’m from in Columbus Ohio and as far as the 

creation of more radioactive waste here in the state of Ohio I don’t think we need to 

do that I think that the any of the fuels that we have as far as fossil fuels is 

adequate if it’s done properly. But I certainly don’t want to create more nuclear 

waste.

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Appendix A

A-155

Commenter: Scott Robinson, Simone Morgen, Emily Journey, Bob Patraicus

Scott Robinson

Hello my name is Scott Robinson from Worthington Ohio and I’m opposed to the 

relicensing of the Davis-Besse nuclear power plant. Thank you.

Simone Morgen

Hi my name is Simone Morgen I’m a Columbus resident and I just want to say that 

a facility such as Davis Besse that has had numerous failures cumulating in that 

lovely hole that endangered people with a possible meltdown has no business 

having a renewal without stringent oversight if it should have renewal at all. 

It puts people in Toledo especially in danger and could possibly extend as far 

south as Columbus. So I really do not think that this should be renewed.

Emily Journey

I’m Emily Journey and I’m from Westerville Ohio. I’d like you to know that I do not 

support the relicensing of the Davis-Besse Atomic reactor. 

I believe we should be going in different directions when it comes to supplying 

energy to our communities. Direction that is not destructive that can provide new 

green jobs. Thank You. 

Bob Patraicus

Hi my name is Bob Patraicus, I have a PhD in political Science. I am a JD. My 

concerns with Davis-Besse begin with the obvious. There has been contamination. 

Radioactive contamination at that plant in the past it continues to occur. 

Moreover the entire process of mining transporting and allowing radioactivity as a 

fuel source is inherently contaminating. 

It is located there on the great lakes, the largest clean water source in the world 

and it seems extremely dangerous and unnecessary since there is other 

alternative fuel sources to allow for Davis-Besse to ever be reopened with its 

incredibly bad history safety history with its dome. 

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Appendix A

A-156

Commenter: Bob Patraicus, Kevin Malcolm, Doug Todd, Connie Hammond

Bob Patraicus (continued)

So because of the ongoing contamination and the inherent nature of the 

radioactive contamination in the process of it being mined and transported. I would 

like the commission to look very closely at this and do what we all know is correct 

and keep Davis-Besse closed.

Kevin Malcolm

Alright. I’m totally against the nuclear power. I just I’m an old guy and I’ve been 

around for many years and I know the history damages that it can cause and I’m 

really opposed to it. That’s why I’m on camera here. That’s why I’m on camera and 

I will do whatever I can to support the cause against it. The actions, take actions 

against it. That what all I got to say. Thank you very much. 

My name is Kevin Malcolm Jones originally from Cleveland Ohio but I’ve been here 

in Columbus for 6 years.

Doug Todd

Hi my name is Doug Todd I’m from Columbus Ohio. I’m very concerned about the 

Davis-Besse Plant. From what little I know the most recent containment failure a 

few years ago was a result of laxed inspection. I’m aware that FirstEnergy had 

requested a delay in inspection on the plant. And it was this delay that almost led 

to the containment break down which would have been a Chernobyl type disaster 

for Northern Ohio. By all means please do not approve the relicensure of DavisBesse. Thank You

Connie Hammond

My name is Connie Hammond I live in Columbus Ohio. I’m a member of the Sierra 

Club nuclear issues committee and the Ohio Green party. My primary concern is 

with the toxic legacy that we are leaving for our Children and Grandchildren. 

Beyond the obvious radioactivity and pollution that these plants produce. 

The process of production of nuclear energy from mining through disposal of waste 

is very carbon intensive and would contribute heavily to global warming. 

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Appendix A

A-157

Commenter: Bernadine Kent, Unknown, Pete Johnson

Connie Hammond (continued)

We need to invest our money into green technologies that would create job and 

also help our economy which is leaving the toxic legacy for our children as well as 

these nuclear power plants. 

Davis-Besse is not a safe plant it has a very bad track record and the Nuclear 

Regulatory Commission has been laxed in its inspections. I really am concerned 

I’m very disconcerned for the future of our children and future generations in terms 

of the toxicity and global warming. Also we don’t need this energy and it is just not 

a good way for our country to be going. Thank You

Bernadine Kent

My name is Bernadine Kent and I’m from Columbus Ohio and I have been 

informed of the Davis-Besse power plant in Toledo. I’m concerned about this plant 

extending their license for the next 20 years. To me that doesn’t make any sense 

especially since they have problems. 

Rather than extending the license there should be some type of investigation or 

some kind of attempt to resolve these problems instead of just saying ok for the 

next 20 years these problems can continue. So my concern is that anyone that 

anyone that would allow this license to continue is not acting in the best interest of 

the citizens.

Unknown

I wish to join the wave of the future. Which is alternative energy sources. Fossil 

fuels and nuclear energy are part of the past.

Pete Johnson

My name is Pete Johnson I’m associated with the Columbus free press and 

citizens alliance for secure elections and I’m definitely opposed to relicensing 

Davis-Besse. 

It’s dangerous, it’s been mismanaged for a long time and I’m definitely opposed to 

the relicensure of Davis-Besse. Thank you. I live in Franklin County, Ohio.

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Appendix A

A-158

Commenter: Constance Gadwell-Newton Esq 

Constance Gadwell-Newton Esq 

This is Connie Gadwell-Newton I’m an attorney. I’m active with the Ohio Green 

party and I wanted to express my opposition to the relicensing of Davis-Besse for 

20 years. 

Basically I mean I’ve heard a lot of the science about it and I can’t really say a 

whole lot about that. But what I can say is that you know it’s going to be relicensed 

supposedly for 20 more years and that would be to 2037, I believe, so I’m opposed 

to the relicensing of Davis-Besse because I think it’s a youth issue and basically 

this is an important youth issue its important to the young people who are not 

allowed to vote and be politically active and children and the future generations. A 

lot of the people who are working to relicense this nuclear facility are going to have 

died of old age by the time its finished and then when it’s finished we are going to 

need to worry about cleaning it up keeping it in repair and I don’t think that people 

are really looking ahead to the future and considering you know the work that 

going to be involved to make sure that its safe. 

Nuclear waste and radioactivity has a half life of gabillion years to put it in kids 

terminology and you know a lot of the people who are going to be effected by 

nuclear waste are not even born yet. And So speaking on behalf of the youth, 

babies, people who cannot speak for themselves. I just wanted to say that 

relicensing Davis-Besse and using nuclear energy is wrong. It may be expedient 

so for the people who are only planning on living you know 10 or 20 more years 

then fine but they don’t care if the world is going to be destroyed. But there are 

people who that effects and I would just urge the people who are making this 

decision to think of the future generations and to be able to think about somebody 

other than yourselves really. 

Yeah I want to make a statement on behalf of kids whose environment is being 

destroyed. There used to be a lot more nature to go to and tromp around in and 

now kids don’t have that we have urban environments that are polluted kids getting 

cancer because of this kind of stuff and it’s really not ok. So this is Connie Gadwell 

Newton urging you to not renew the licensing for Davis-Besse. Thank you.

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Appendix A

A-159

Commenter: Patricia Marida

Patricia Marida

Hi my name is Patricia Marida. I’m the chair of the nuclear issues committee at the 

Ohio Sierra Club. I gave a presentation before the Nuclear Regulatory Commission 

on November 4, 2010 as to why the Sierra Club opposes the extension of a license 

at Davis-Besse. 

Tonight I’m going to give my personal statement. I think that it’s well recorded there 

are 10 pages of documentation of very serious violations and illegalities, and 

actually nuclear accidents at Davis-Besse. It is the most accident ridden power 

plant, nuclear power plant in the nation. It is very clear that we have a serious 

problem here also because the Nuclear Regulatory Commission has been very 

laxed in enforcing Davis-Besse. In fact allowing them to, allowing FirstEnergy and 

Davis-Besse Operating Company to continue operating the plant when it was 

supposed to be shut down for an inspection. And the reactor head came within 1/8” 

of metal left between containment and a nuclear holocaust. So It is very clear that 

the regulatory and the supervision is lacking were also would like the NRC to be 

sure to cover the safety issues there, there are many safety issues. 

Apparently when an accident, when there is an alarm there is no response. People 

say oh that’s just a false alarm. So no one seems to get very excited, when an 

alarm goes off at Davis-Besse. 

We are also concerned about fish and Lake Erie and the heat coming out of the 

plant. 

Even more we are concerned about the possibility of contamination of all the water 

in the great lakes from a reactor accident. This would be a nightmarish...

So the fleeting use of electricity in the past has left us with a legacy of nuclear 

waste. But However we understand that the nuclear regulatory commission does 

not have to even consider that when they are deciding whether or not to license 

Davis-Besse because in the past the Nuclear Regulatory Commission has made a 

decision that they are not going to, that this doesn’t have anything to do with a new 

license despite the fact that much more of this dangerous radioactivity is going to 

be stored at the plant there is no solution for it there is no magic solution that will 

turn lead into gold it will remain radioactive for millions of years and will gradually 

spread itself around. It is so important for the Nuclear Regulatory Commission to 

look at issues of the onsite storage and to look at containing and at least in the 

near future making this waste safe. The new waste is going to be generated there 

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Appendix A

A-160

Patricia Marida (continued)

really does need to be a plan for isolating it onsite. We are not asking for a plan to 

isolate it for a hundred million years because we all know that’s an impossibility. 

We are asking for some sort of a plan working with Doctor Arjune Macajohny of the 

institute for environmental and economic research in Washington DC, we are 

asking for you the NRC to work with him and look at some serious ways of 

isolating this waste in canister that are hidden in bunkers where they are safe from 

terrorist attack. 

So this fleeting use of electricity when we don’t even need any more electricity. 

What happened when Davis-Besse was shut down? We got along fine. 

We are closing down Coal plants now because Ohio is actually using less 

electricity than they used to. We’ve got efficiency we’ve got solar we have wind we 

have geothermal we have all kinds of sustainable ways. 

We don’t need more nuclear power and we need to have the Nuclear Regulatory 

Commission look at wether or not more electric is needed especially the large 

amount that Davis-Besse produces because we think it could be shut down today 

we think it should be shut down today. 

Dr. David Lochbaum has sent you a very well documented statement as to why 

that this plant needs to be shut down now, it is dangerous to operate and the NRC 

dismissed it out of hand with what Dr. Lauchbaum characterized as superfluous 

reasons.

16-18-RW

continued

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Appendix A

A-161

 Commenter: Patricia Marida
Appendix A

A-162

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Appendix A

A-163

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Appendix A

A-164

 Commenter: Lee Blackburn

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Appendix A

A-165

 Commenter: Mary 

Knapp

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Appendix A

A-166

 Commenter: John P. Froman

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Appendix A

A-167

 Commenter: Chris Galvin

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Appendix A

A-168

4-3-SE

continued

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Appendix A

A-169

 Commenter: Jane Ridenour

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Appendix A

A-170

 Commenter: Joseph DeMare

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Appendix A

A-171

 Commenter: Dennis Kucinich

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Appendix A

A-172

47-2-OS

continued
Appendix A

A-173

 Commenter: Marilyn & Paul Nesser

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Appendix A

A-174

 Commenter: Jessica Lillian Weinberg

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Appendix A

A-175

49-1-LR

continued
Appendix A

A-176

 Commenter: Eric Britton

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Appendix A

A-177

 Commenter: Matt Trokan

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Appendix A

A-178

 Commenter: Lee Blackburn

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Appendix A

A-179

 Commenter: Bob Greenbaum

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Appendix A

A-180

 Commenter: Robert Kyle

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Appendix A

A-181

 Commenter: Tim Wagner

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Appendix A

A-182

 Commenter: Jim Wagner

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Appendix A

A-183

 Commenter: Sandy Bihn

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Appendix A

A-184

 Commenter: Elisa Young

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Appendix A

A-185

 Commenter: Linda Milligan

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Appendix A

A-186

 Commenter: Connie Hammond

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Appendix A

A-187

 Commenter: Paul Wojoski

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Appendix A

A-188

 Commenter: Carol Rainey

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Appendix A

A-189

 Commenter: Margaret Holfinger

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Appendix A

A-190

 Commenter: Simone Morgen

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Appendix A

A-191

 Commenter: Constance Gadwell-Newton Esq

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Appendix A

A-192

 Commenter: Mary Beth Lohse

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Appendix A

A-193

 Commenter: Jean Puchstein

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Appendix A

A-194

 Commenter: Andy Trokan

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Appendix A

A-195

 Commenter: Christian George

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Appendix A

A-196

 Commenter: Donna Emig

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Appendix A

A-197

 Commenter: Ben Shapiro

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Appendix A

A-198

 Commenter: Nick Mellis

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Appendix A

A-199

 Commenter: Kathleen Bodnar

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Appendix A

A-200

 Commenter: Joan DeLauro

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Appendix A

A-201

 Commenter: Virginia Douglas

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Appendix A

A-202

 Commenter: June Douglas

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Appendix A

A-203

 Commenter: Jeremy Bantz

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A-204

 Commenter: Leeza Perry

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Appendix A

A-205

 Commenter: Lance Wilson

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A-206

 Commenter: Erika Agner

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A-207

 Commenter: Liz Loring

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A-208

 Commenter: Cate Renner

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A-209

 Commenter: George M Williams

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 Commenter: Amanda Baldino

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A-211

 Commenter: Joan Lang

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 Commenter: Susan Jones

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 Commenter: George M Williams

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 Commenter: Leonard Bildstein

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A-215

 Commenter: Mike Fremont

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 Commenter: Stephen & Connie Caruso

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 Commenter: Leslie Stansbery

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 Commenter: Karen Hansen

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Appendix A

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 Commenter: Inez George

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 Commenter: Natalie Schafrath

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 Commenter: David Greene

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Appendix A

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 Commenter: Tekla Lewin

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APPENDIX B 

NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS

B-1 

B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 

LICENSE RENEWAL OF NUCLEAR POWER PLANTS

NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Power 

Plants (referred to as the GEIS), document the results of the U.S. Nuclear Regulatory 

Commission (NRC) staff’s (staff's) systematic approach to evaluating the environmental impacts 

of renewing the licenses of individual nuclear power plants. The GEIS was originally published 

in 1996 and Addendum 1 to the GEIS, which only addresses transportation issues, was

published in 1999. Of the 92 total environmental issues that the staff identified in the 1996 

GEIS, the staff determined that 69 are generic to all plants (Category 1), while 21 issues must 

be discussed on a site-specific basis (Category 2). Two other issues, environmental justice and 

the chronic effects of electromagnetic fields, are uncategorized and must be evaluated on a 

site-specific basis.

Table B-1 in this appendix lists all 92 environmental issues, including the possible 

environmental significance (SMALL, MODERATE, LARGE, or uncategorized) as appropriate. 

This table is provided in Chapter 9 of the 1996 GEIS. 

On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 

protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 

“Environmental protection regulations for domestic licensing and related regulatory functions.” 

Specifically, the final rule updates the potential environmental impacts associated with the 

renewal of an operating license for a nuclear power reactor for an additional 20 years. A 

revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for the 

final rule. The revised GEIS specifically supports the revised list of NEPA issues and 

associated environmental impact findings for license renewal contained in Table B-1 in 

Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect 

lessons learned and knowledge gained during previous license renewal environmental reviews. 

In addition, public comments received on the draft revised GEIS and rule and during previous 

license renewal environmental reviews were reexamined to validate existing environmental 

issues and identify new ones.

This SEIS, which discusses the environmental impacts associated with Davis-Besse license 

renewal, is reviewed against the criteria from the 1996 GEIS. However, new issues identified, 

or recategorized, in the 2013 GEIS are also included in this SEIS. The new Category 1 issues 

identified in the 2013 GEIS which are discussed and evaluated in this SEIS are geology and 

soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to 

radionuclides, human health impact from chemicals, and physical occupational hazards. New 

Category 2 issues that are addressed in this SEIS are radionuclides released to groundwater, 

effects on terrestrial resources (non-cooling system impacts), minority and low-income 

populations (i.e., environmental justice), and cumulative impacts. 
Appendix B

B-2 

Table B-1. Generic Summary Findings on NEPA Issues for License Renewal of Nuclear 

Power Plants

Issue Type of Issue Finding

Surface water quality, hydrology, and use 

Impacts of 

refurbishment on 

surface water quality

Generic SMALL. Impacts are expected to be negligible during refurbishment 

because best management practices are expected to be employed to control 

soil erosion and spills.

Impacts of 

refurbishment on 

surface water use

Generic SMALL. Water use during refurbishment will not increase appreciably or will 

be reduced during plant outage.

Altered current 

patterns at intake 

and discharge 

structures 

Generic SMALL. 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.

Altered salinity 

gradients

Generic SMALL. Salinity gradients 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.

Altered thermal 

stratification of lakes

Generic SMALL. 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.

Temperature effects 

on sediment 

transport capacity

Generic SMALL. 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.

Scouring caused by 

discharged cooling 

water

Generic SMALL. 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.

Eutrophication Generic SMALL. 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.

Discharge of 

chlorine or other 

biocides

Generic SMALL. Effects are not a concern among regulatory and resource agencies, 

and are not expected to be a problem during the license renewal term.

Discharge of 

sanitary wastes and 

minor chemical spills

Generic SMALL. Effects are readily controlled through National Pollutant Discharge 

Elimination System (NPDES) permit and periodic modifications, if needed, 

and are not expected to be a problem during the license renewal term.

Discharge of other 

metals in wastewater

Generic SMALL. 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.

Water use conflicts 

(plants with 

once-through cooling 

systems)

Generic SMALL. These conflicts have not been found to be a problem at operating 

nuclear power plants with once-through heat dissipation systems.

Water use conflicts 

(plants with cooling 

ponds or cooling 

towers using 

makeup water from 

a small river with low 

flow)

Site-specific SMALL OR MODERATE. The issue has been a concern at nuclear power 

plants with cooling ponds and at plants with cooling towers. Impacts on 

instream and riparian communities near these plants could be of moderate 

significance in some situations. See § 51.53(c)(3)(ii)(A).
Appendix B 

B-3 

Issue Type of Issue Finding

Aquatic ecology 

Refurbishment Generic SMALL. During plant shutdown and refurbishment, there will be negligible 

effects on aquatic biota because of a reduction of entrainment and 

impingement of organisms or a reduced release of chemicals.

Accumulation of 

contaminants in 

sediments or biota

Generic SMALL. 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.

Entrainment of 

phytoplankton and 

zooplankton

Generic SMALL. 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.

Cold shock Generic SMALL. 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.

Thermal plume 

barrier to migrating 

fish

Generic SMALL. 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.

Distribution of 

aquatic organisms

Generic SMALL. Thermal discharge may have localized effects but is not expected 

to affect the larger geographical distribution of aquatic organisms.

Premature 

emergence of 

aquatic insects

Generic SMALL. 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.

Gas supersaturation 

(gas bubble disease)

Generic SMALL. 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.

Low dissolved 

oxygen in the 

discharge

Generic SMALL. 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.

Losses from 

predation, 

parasitism, and 

disease among 

organisms exposed 

to sublethal stresses

Generic SMALL. 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.

Stimulation of 

nuisance organisms 

(e.g., shipworms)

Generic SMALL. 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.
Appendix B

B-4 

Issue Type of Issue Finding

Aquatic ecology (for plants with once-through and cooling-pond heat dissipation systems)

Entrainment of fish 

and shellfish in early 

life stages

Site-specific SMALL, MODERATE, OR LARGE. The impacts of entrainment are small at 

many plants but may be moderate or even large at a few plants with 

once-through and cooling-pond cooling systems. Further, ongoing efforts in 

the vicinity of these plants to restore fish populations may increase the 

numbers of fish susceptible to intake effects during the license renewal 

period, such that entrainment studies conducted in support of the original 

license may no longer be valid. See § 51.53(c)(3)(ii)(B).

Impingement of fish 

and shellfish

Site-specific SMALL, MODERATE, OR LARGE. The impacts of impingement are small 

at many plants but may be moderate or even large at a few plants with 

once-through and cooling-pond cooling systems. See § 51.53(c)(3)(ii)(B).

Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of continuing concerns about 

heat shock and the possible need to modify thermal discharges in response 

to changing environmental conditions, the impacts may be of moderate or 

large significance at some plants. See § 51.53(c)(3)(ii)(B). 

Aquatic ecology (for plants with cooling-tower-based heat dissipation systems)

Entrainment of fish 

and shellfish in early 

life stages

Generic SMALL. Entrainment of fish has not been found to be a problem at 

operating nuclear power plants with this type of cooling system and is not 

expected to be a problem during the license renewal term.

Impingement of fish 

and shellfish

Generic SMALL. The impingement has not been found to be a problem at operating 

nuclear power plants with this type of cooling system and is not expected to 

be a problem during the license renewal term.

Heat shock Generic SMALL. Heat shock has not been found to be a problem at operating 

nuclear power plants with this type of cooling system and is not expected to 

be a problem during the license renewal term.

Groundwater use and quality

Impacts of 

refurbishment on 

groundwater use 

and quality

Generic SMALL. Extensive dewatering during the original construction on some sites 

will not be repeated during refurbishment on any sites. Any plant wastes 

produced during refurbishment will be handled in the same manner as in 

current operating practices and are not expected to be a problem during the 

license renewal term.

Groundwater use 

conflicts (potable 

and service water; 

plants that use <100 

gallons per minute 

(gpm)

Generic SMALL. Plants using less than 100 gpm are not expected to cause any 

groundwater use conflicts.

Groundwater use 

conflicts (potable 

and service water, 

and dewatering 

plants that use >100 

gpm

Site-specific SMALL, MODERATE, OR LARGE. Plants that use more than 100 gpm may 

cause groundwater use conflicts with nearby groundwater users. 

See § 51.53(c)(3)(ii)(C). 

Groundwater use 

conflicts (plants 

using cooling towers 

withdrawing makeup 

water from a small 

river) 

Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts may result from 

surface water withdrawals from small water bodies during low flow conditions 

which may affect aquifer recharge, especially if other groundwater or 

upstream surface water users come online before the time of license 

renewal. See § 51.53(c)(3)(ii)(A).
Appendix B 

B-5 

Issue Type of Issue Finding

Groundwater use 

conflicts (Ranney 

wells)

Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can result in potential 

groundwater depression beyond the site boundary. Impacts of large 

groundwater withdrawal for cooling tower makeup at nuclear power plants 

using Ranney wells must be evaluated at the time of application for license 

renewal. See § 51.53(c)(3)(ii)(C). 

Groundwater quality 

degradation (Ranney 

wells)

Generic SMALL. Groundwater quality at river sites may be degraded by induced 

infiltration of poor-quality river water into an aquifer that supplies large 

quantities of reactor cooling water. However, the lower quality infiltrating 

water would not preclude the current uses of groundwater and is not 

expected to be a problem during the license renewal term.

Groundwater quality 

degradation 

(saltwater intrusion)

Generic SMALL. Nuclear power plants do not contribute significantly to saltwater 

intrusion.

Groundwater quality 

degradation (cooling 

ponds in salt 

marshes)

Generic SMALL. Sites with closed-cycle cooling ponds may degrade groundwater 

quality. Because water in salt marshes is brackish, this is not a concern for 

plants located in salt marshes.

Groundwater quality 

degradation (cooling 

ponds at inland 

sites)

Site-specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling ponds 

may degrade groundwater quality. For plants located inland, the quality of 

the groundwater in the vicinity of the ponds must be shown to be adequate 

to allow continuation of current uses. See § 51.53(c)(3)(ii)(D).

Terrestrial ecology

Refurbishment 

impacts

Site-specific SMALL, MODERATE, OR LARGE. Refurbishment impacts are insignificant 

if no loss of important plant and animal habitat occurs. However, it cannot 

be known whether important plant and animal communities may be affected 

until the specific proposal is presented with the license renewal application. 

See § 51.53(c)(3)(ii)(E).

Cooling tower 

impacts on crops 

and ornamental 

vegetation

Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity 

associated with cooling tower operation have not been found to be a 

problem at operating nuclear power plants and are not expected to be a 

problem during the license renewal term.

Cooling tower 

impacts on native 

plants

Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity 

associated with cooling tower operation have not been found to be a 

problem at operating nuclear power plants and are not expected to be a 

problem during the license renewal term.

Bird collisions with 

cooling towers

Generic SMALL. These collisions have not been found to be a problem at operating 

nuclear power plants and are not expected to be a problem during the 

license renewal term.

Cooling pond 

impacts on terrestrial 

resources

Generic SMALL. Impacts of cooling ponds on terrestrial ecological resources are 

considered to be of small significance at all sites.

Power line right of 

way (ROW) 

management 

(cutting and 

herbicide 

application)

Generic SMALL. The impacts of ROW maintenance on wildlife are expected to be of 

small significance at all sites.

Bird collisions with 

power lines

Generic SMALL. Impacts are expected to be of small significance at all sites.
Appendix B

B-6 

Issue Type of Issue Finding

Impacts of 

electromagnetic 

fields on flora and 

fauna

Generic SMALL. 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.

Floodplains and 

wetland on power 

line ROW 

Generic SMALL. 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.

Threatened and endangered species

Threatened or 

endangered species

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and 

continued operation are not expected to adversely affect threatened or 

endangered species. However, consultation with appropriate agencies 

would be needed at the time of license renewal to determine whether or not 

threatened or endangered species are present and whether or not they 

would be adversely affected. See § 51.53(c)(3)(ii)(E).

Air quality

Air quality during 

refurbishment 

(non-attainment and 

maintenance areas)

Site-specific SMALL, MODERATE, OR LARGE. Air quality impacts from plant 

refurbishment associated with license renewal are expected to be small. 

However, vehicle exhaust emissions could be cause for concern at locations 

in or near nonattainment or maintenance areas. The significance of the 

potential impact cannot be determined without considering the compliance 

status of each site and the number of workers expected to be employed 

during the outage. See § 51.53(c)(3)(ii)(F).

Air quality effects of 

transmission lines

Generic SMALL. Production of ozone and oxides of nitrogen is insignificant and does 

not contribute measurably to ambient levels of these gases.

Land use

Onsite land use Generic SMALL. Projected onsite land use changes required during refurbishment 

and the renewal period would be a small fraction of any nuclear power plant 

site and would involve land that is controlled by the applicant.

Power line ROW Generic SMALL. Ongoing use of power line ROWs would continue with no change in 

restrictions. The effects of these restrictions are of small significance.

Human health

Radiation exposures 

to the public during 

refurbishment

Generic SMALL. During refurbishment, the gaseous effluents would result in doses 

that are similar to those from current operation. Applicable regulatory dose 

limits to the public are not expected to be exceeded.

Occupational 

radiation exposures 

during refurbishment

Generic SMALL. Occupational doses from refurbishment are expected to be within 

the range of annual average collective doses experienced for 

pressurized-water reactors and boiling-water reactors. Occupational 

mortality risk from all causes including radiation is in the mid-range for 

industrial settings.

Microbiological 

organisms 

(occupational health)

Generic SMALL. Occupational health impacts are expected to be controlled by 

continued application of accepted industrial hygiene practices to minimize 

exposure to workers.
Appendix B 

B-7 

Issue Type of Issue Finding

Microbiological 

organisms (public 

health) (plants using 

lakes or canals, or 

cooling towers or 

cooling ponds that 

discharge to a small 

river) 

Site-specific SMALL, MODERATE, OR LARGE. These organisms are not expected to be 

a problem at most operating plants except possibly at plants using cooling 

ponds, lakes, or canals that discharge to small rivers. Without site-specific 

data, it is not possible to predict the effects generically. 

See § 51.53(c)(3)(ii)(G). 

Noise Generic SMALL. 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.

Electromagnetic 

fields – acute effects 

(electric shock)

Site-specific SMALL, MODERATE, OR LARGE. Electrical shock resulting from direct 

access to energized conductors or from induced charges in metallic 

structures have not been found to be a problem at most operating plants and 

generally are not expected to be a problem during the license renewal term. 

However, site-specific review is required to determine the significance of the 

electric shock potential at the site. See § 51.53(c)(3)(ii)(H).

Electromagnetic 

fields – chronic 

effects 

Uncategorized UNCERTAIN. Biological and physical studies of 60-hertz (Hz) 

electromagnetic fields have not found consistent evidence linking harmful 

effects with field exposures. However, research is continuing in this area 

and a consensus scientific view has not been reached.

Radiation exposures 

to public (license 

renewal term)

Generic SMALL. Radiation doses to the public will continue at current levels 

associated with normal operations.

Occupational 

radiation exposures 

(license renewal 

term) 

Generic SMALL. 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.

Socioeconomic impacts

Housing impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are expected to be of 

small significance at plants located in a medium or high population area and 

not in an area where growth control measures that limit housing 

development are in effect. Moderate or large housing impacts of the 

workforce associated with refurbishment may be associated with plants 

located in sparsely populated areas or in areas with growth control measures 

that limit housing development. See § 51.53(c)(3)(ii)(I).

Public services: 

public safety, social 

services, and 

tourism and 

recreation

Generic SMALL. Impacts to public safety, social services, and tourism and 

recreation are expected to be of small significance at all sites.

Public services: 

public utilities

Site-specific SMALL OR MODERATE. An increased problem with water shortages at 

some sites may lead to impacts of moderate significance on public water 

supply availability. See § 51.53(c)(3)(ii)(I).

Public services: 

education 

(refurbishment)

Site-specific SMALL, MODERATE, OR LARGE. Most sites would experience impacts of 

small significance but larger impacts are possible depending on site- and 

project-specific factors. See § 51.53(c)(3)(ii)(I).

Public services: 

education (license 

renewal term)

Generic SMALL. Only impacts of small significance are expected.

Offsite land use 

(refurbishment)

Site-specific SMALL OR MODERATE. Impacts may be of moderate significance at 

plants in low population areas. See § 51.53(c)(3)(ii)(I).
Appendix B

B-8 

Issue Type of Issue Finding

Offsite land use 

(license renewal 

term) 

Site-specific SMALL, MODERATE, OR LARGE. Significant changes in land use may be 

associated with population and tax revenue changes resulting from license 

renewal. See § 51.53(c)(3)(ii)(I).

Public services: 

transportation

Site-specific SMALL, MODERATE, OR LARGE. Transportation impacts (level of service) 

of highway traffic generated during plant refurbishment and during the term 

of the renewed license are generally expected to be of small significance. 

However, the increase in traffic associated with the additional workers and 

the local road and traffic control conditions may lead to impacts of moderate 

or large significance at some sites. See § 51.53(c)(3)(ii)(J).

Historic and 

archaeological 

resources

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and 

continued operation are expected to have no more than small adverse 

impacts on historic and archaeological resources. However, the National 

Historic Preservation Act requires the Federal agency to consult with the 

State Historic Preservation Officer to determine whether or not there are 

properties present that require protection. See § 51.53(c)(3)(ii)(K).

Aesthetic impacts 

(refurbishment)

Generic SMALL. No significant impacts are expected during refurbishment.

Aesthetic impacts 

(license renewal 

term) 

Generic SMALL. No significant impacts are expected during the license renewal 

term. 

Aesthetic impacts of 

transmission lines 

(license renewal 

term) 

Generic SMALL. No significant impacts are expected during the license renewal 

term. 

Postulated accidents

Design basis 

accidents

Generic SMALL. The staff has concluded that the environmental impacts of 

design-basis accidents are of small significance for all plants.

Severe accidents Site-specific SMALL. 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. See § 51.53(c)(3)(ii)(L).

Uranium fuel cycle and waste management

Offsite radiological 

impacts (individual 

effects from other 

than the disposal of 

spent fuel and high 

level waste)

Generic SMALL. Offsite impacts of the uranium fuel cycle have been considered by 

the Commission in Table S-3 of this part. Based on information in the GEIS, 

impacts on individuals from radioactive gaseous and liquid releases 

including radon-222 and technetium-99 are small.

Offsite radiological 

impacts (collective 

effects)

Generic The 100-year environmental dose commitment to the U.S. population from 

the fuel cycle, high level waste, and spent fuel disposal excepted, is 

calculated to be about 14,800 person rem, or 12 cancer fatalities, for each 

additional 20-year power reactor operating term. Much of this, especially the 

contribution of radon releases from mines and tailing piles, consists of tiny 

doses summed over large populations. This same dose calculation can 

theoretically be extended to include many tiny doses over additional 

thousands of years as well as doses outside the United States. The result of 

such a calculation would be thousands of cancer fatalities from the fuel 

cycle, but this result assumes that even tiny doses have some statistical 

adverse health effect which will not ever be mitigated (for example no cancer 

cure in the next thousand years), and that these doses projected over 

thousands of years are meaningful; however, these assumptions are 

questionable. In particular, science cannot rule out the possibility that there 
Appendix B 

B-9 

Issue Type of Issue Finding

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 judgment as to the regulatory 

NEPA implications of these matters should be made and it makes no sense 

to repeat the same judgment in every case. Even taking the uncertainties 

into account, the Commission concludes that these impacts are acceptable 

in that these impacts would not be sufficiently large to require the NEPA 

conclusion, for any plant, that the option of extended operation under 10 

CFR Part 54 should be eliminated. Accordingly, while the Commission has 

not assigned a single level of significance for the collective effects of the fuel 

cycle, this issue is considered Category 1 (Generic).

Offsite radiological 

impacts (spent fuel 

and high level waste 

disposal)

Generic 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 it is assumed 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 per year or less. However, while the Commission has reasonable 

confidence that these assumptions will prove correct, there is considerable 

uncertainty since the limits are yet to be developed, no repository application 

has been completed or reviewed, and uncertainty is inherent in the models 

used to evaluate possible pathways to the human environment. The NAS 

report indicated that 100 millirem per year should be considered as a starting 

point for limits for individual doses, but notes that some measure of 

consensus exists among national and international bodies that the limits 

should be a fraction of the 100 millirem per year. The lifetime individual risk 

from 100 millirem annual dose limit is about 3 x 10-3.

Estimating cumulative doses to populations over thousands of years is more 

problematic. The likelihood and consequences of events that could seriously 

compromise the integrity of a deep geologic repository were evaluated by 

the Department of Energy in the “Final Environmental Impact Statement: 

Management of Commercially Generated Radioactive Waste,” October 

1980. The evaluation estimated the 70-year whole-body dose commitment 

to the maximum individual and to the regional population resulting from 

several modes of breaching a reference repository in the year of closure, 

after 1,000 years, after 100,000 years, and after 100,000,000 years. 

Subsequently, the NRC and other federal agencies have expended 

considerable effort to develop models for the design and for the licensing of 

a high level waste repository, especially for the candidate repository at 

Yucca Mountain. More meaningful estimates of doses to population may be

possible in the future as more is understood about the performance of the 

proposed Yucca Mountain repository. Such estimates would involve very 

great uncertainty, especially with respect to cumulative population doses 

over thousands of years. The standard proposed by the NAS is a limit on 

maximum individual dose. The relationship of potential new regulatory 

requirements, based on the NAS report, and cumulative population impacts 

has not been determined, although the report articulates the view that 

protection of individuals will adequately protect the population for a 

repository at Yucca Mountain. However, the 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 the amount 

of radioactive material released over 10,000 years. The cumulative release 

limits are based on the EPA's population impact goal of 1,000 premature 
Appendix B

B-10

Issue Type of Issue Finding

cancer deaths worldwide for a 100,000 metric ton (MT) repository.

Nevertheless, despite all the uncertainty, some judgment as to the regulatory 

NEPA implications of these matters should be made and it makes no sense 

to repeat the same judgment in every case. Even taking the uncertainties 

into account, the Commission concludes that these impacts are acceptable 

in that these impacts would not be sufficiently large to require the NEPA 

conclusion, for any plant, that the option of extended operation under 10 

CFR Part 54 should be eliminated. Accordingly, while the Commission has 

not assigned a single level of significance for the impacts of spent fuel and 

high level waste disposal, this issue is considered in Category 1 (Generic).

Nonradiological 

impacts of the 

uranium fuel cycle

Generic SMALL. The nonradiological impacts of the uranium fuel cycle resulting from 

the renewal of an operating license for any plant are found to be small.

Low-level waste 

storage and disposal

Generic SMALL. The comprehensive regulatory controls that are in place and the 

low public doses being achieved at reactors ensure that the radiological 

impacts to the environment will remain small during the term of a renewed 

license. The maximum additional onsite 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 long-term disposal of low-level 

waste from any individual plant at licensed sites are small. In addition, the 

Commission concludes that there is reasonable assurance that sufficient 

low-level waste disposal capacity will be made available when needed for 

facilities to be decommissioned consistent with NRC decommissioning 

requirements.

Mixed waste storage 

and disposal

Generic SMALL. 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.

Onsite spent fuel Generic SMALL. 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.

Nonradiological 

waste

Generic SMALL. 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.

Transportation Generic SMALL. 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 megawatt days per metric-ton uranium Wd/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.
Appendix B 

B-11

Issue Type of Issue Finding

Decommissioning

Radiation doses Generic SMALL. Doses to the public will be well below applicable regulatory 

standards regardless of which decommissioning method is used. 

Occupational doses would increase no more than 1 man-rem caused by 

buildup of long-lived radionuclides during the license renewal term. 

Waste management Generic SMALL. 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.

Air quality Generic SMALL. 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.

Water quality Generic SMALL. The potential for significant water quality impacts from erosion or 

spills is no greater whether decommissioning occurs after a 20-year license 

renewal period or after the original 40-year operation period, and measures 

are readily available to avoid such impacts.

Ecological resources Generic SMALL. Decommissioning after either the initial operating period or after a 

20-year license renewal period is not expected to have any direct ecological 

impacts.

Socioeconomic 

impacts

Generic SMALL. 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.

Environmental justice

Environmental 

justice

Uncategorized NONE. The need for and the content of an analysis of environmental justice 

will be addressed in plant-specific reviews.

Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 (61 FR 28467, June 5, 1996.)

APPENDIX C 

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

C-1 

1 C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

2 The Atomic Energy Act of 1954 (AEA) authorizes states to establish programs to assume U.S. 

3 Nuclear Regulatory Commission (NRC) regulatory authority for certain activities. For example, 

4 in accordance with Section 274 of the AEA, as amended, beginning on August 31, 1999, the 

5 State of Ohio assumed regulatory responsibility over the following: 

6 • byproduct materials as defined in Section 11e.(1) of the Act, 

7 • byproduct materials as defined in Section 11e.(2) of the Act, 

8 • source materials, 

9 • special nuclear materials in quantities not sufficient to form a critical mass, 

10 • the regulation of the land disposal of byproduct, source, or special nuclear waste 

11 materials received from other persons, and

12 • the evaluation of radiation safety information on sealed sources or devices containing 

13 byproduct, source, or special nuclear materials and the registration of the sealed 

14 sources or devices for distribution, as provided for in regulations or orders of the NRC. 

15 The Ohio Agreement State Program is administered by the Bureau of Radiation Protection in 

16 the Ohio Department of Health.

17 In addition to implementing some Federal programs, state legislatures develop their own laws. 

18 State statutes supplement as well as implement Federal laws for protection of air, water quality, 

19 and groundwater. State legislation may address Solid Waste Management Programs, locally 

20 rare or endangered species, and historic and cultural resources.

21 In addition, the Clean Water Act (CWA) allows for primary enforcement and administration 

22 through state agencies, provided the state program is at least as stringent as the Federal 

23 program and conforms to the CWA and delegation of authority for the Federal National Pollutant 

24 Discharge Elimination System (NPDES) Program from the Environmental Protection Agency 

25 (EPA) to the state. The primary mechanism to control water pollution is the requirement that 

26 direct dischargers to obtain an NPDES permit or in the case of states where the authority has 

27 been delegated from the EPA, a State Pollutant Discharge Elimination System (SPDES) permit, 

28 pursuant to the CWA.

29 One important difference between Federal regulations and certain state regulations is the 

30 definition of waters regulated by the state. Certain state regulations may include underground 

31 waters while the CWA only regulates surface waters.

32 C.1 Federal &State Environmental Requirements

33 Certain environmental requirements, including some discussed earlier, may have been 

34 delegated to state authorities for implementation, enforcement, or oversight. Table C-1 provides 

35 a list of representative state environmental requirements that may affect license renewal 

36 applications (LRAs) for nuclear power plants.
Appendix C 

C-2 

1 Table C-1. Federal and State Environmental Requirements

2 Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse) is subject to numerous state 

3 requirements regarding their environmental program. Those requirements are briefly described 

4 below.

Agency Law/Regulation Requirements

NRC Title 10 of the Code of 

Federal Regulations (CFR) 

Part 51

“Environmental Protection Regulations for Domestic Licensing and 

Related Regulatory Functions.” This part contains environmental 

protection regulations applicable to the NRC’s domestic licensing 

and related regulatory functions.

NRC 10 CFR Part 54 “Requirements for Renewal of Operating Licenses for Nuclear 

Power Plants.” This part focuses on managing adverse effects of 

aging rather than identification of all aging mechanisms. The rule 

is intended to ensure that important systems, structures, and 

components (SSCs) will continue to perform their intended function 

in the period of extended operation.

NRC 10 CFR Part 50 Regulations promulgated by the NRC pursuant to the Atomic 

Energy Act of 1954, as amended (68 Stat. 919), and Title II of the 

Energy Reorganization Act of 1974 (88 Stat. 1242), to provide for 

the licensing of production and utilization facilities. This part also 

gives notice to all persons who knowingly provide to any licensee, 

applicant, contractor, or subcontractor, components, equipment, 

materials, or other goods or services, that relate to a licensee’s or 

applicant’s activities subject to this part, that they may be 

individually subject to NRC enforcement action for violation of 

§ 50.5.

Air quality protection

Ohio EPA, Division 

of Air Pollution 

Control

Ambient Air Quality &

Emergency Episode 

Standards

Ohio Administrative Code 

Chapter 3745-25

Primary ambient air quality standards define levels of air quality,

which are necessary, with an adequate margin of safety, to protect 

the public health. Secondary ambient air quality standards define 

levels of air quality, which are necessary to protect the public 

welfare from any known or anticipated adverse effects of a 

pollutant.

Ohio EPA, Division 

of Air Pollution 

Control

Permits to Install New 

Sources of Pollution

Ohio Administrative Code 

Chapter 3745-31

This chapter provides requirements for installation, modification,

and operation of new and existing air contaminant sources at 

facilities that are not subject to Chapter 3745-77 of the 

Administrative Code. This chapter also provides requirements for 

installation and modification of air contaminant sources at facilities 

that are, or will be, subject to Chapter 3745-77 of the 

Administrative Code.

EPA Clean Air Act (CAA) 

(42 U.S.C. § 7401 et seq.)

The Clean Air Act (CAA) is the law that defines EPA’s 

responsibilities for protecting and improving the nation’s air quality 

and the stratospheric ozone layer. The CAA requires EPA to set 

National ambient air quality standards for six common air 

pollutants—particle pollution (often referred to as particulate 

matter), ground-level ozone, carbon monoxide, sulfur oxides, 

nitrogen oxides, and lead.

Coastal zone protection

U.S. Department of 

Commerce

Coastal Zone Management 

Act of 1972

(16 U.S.C. § 1451-1464)

The Congress finds and declares that it is the National policy to do 

the following:

• to preserve, protect, develop, and where possible, to restore or 

enhance, the resources of the Nation’s coastal zone for this and 
Appendix C 

C-3 

Agency Law/Regulation Requirements

succeeding generations and

• to encourage and assist the states to effectively exercise their 

responsibilities in the coastal zone through the development 

and implementation of management programs to achieve wise 

use of the land and water resources of the coastal zone, giving 

full consideration to ecological, cultural, historic, and esthetic 

values as well as the needs for compatible economic 

development. 

Ohio Department of 

Natural Resources—

Office of Coastal 

Zone Management

Ohio Coastal Management 

Program 

Ohio Administrative Code 

Chapter 1506

In an effort to balance diverse economic and environmental 

interests, the Ohio Coastal Management Program sets forth the 

guidelines for use of Ohio’s coastal resources to ensure their 

continued benefit for this and future generations.

Water resources protection

EPA Clean Water Act (CWA) 

(33 U.S.C. § 1251 et seq.)

The NPDES permit is required for plant industrial, sanitary, and 

storm water discharges to waters of the state. The NPDES permit 

requires the compliance of each point source with authorized 

discharge levels, monitoring requirements, and other appropriate 

requirements.

EPA Section 401 of the CWA 

(33 U.S.C. § 1341)

Section 401 Water Quality Certification of the CWA requires a 

Section 401 water quality certification and payment of applicable 

fees before the issuance of a Federal permit or license to conduct 

any activity that may result in any discharge to waters of the state. 

EPA Section 404 of the CWA 

(33 U.S.C. § 1344)

Section 404 of the CWA established a program to regulate the 

discharge of dredged and fill material into waters of the U.S., 

including wetlands. The U.S. Army Corps of Engineers (USACE) 

and the EPA jointly administer this program. Under the 

404 Program, no discharge of dredged or fill material is allowed if a 

practicable alternative exists that is less damaging to the aquatic 

environment or if the Nation’s waters would be significantly 

degraded. A Federal permit is required to discharge dredged or fill 

material into wetlands and waters of the U.S. 

EPA Comprehensive 

Environmental Response, 

Compensation, and 

Liability Act (CERCLA) 

(42 U.S.C. § 9601 et seq.) 

Section 101 of CERCLA requires a permit to cover consumptive 

water use over 20,000 gallons per day (over a 30-day average) of 

surface and ground water.

EPA Wild and Scenic River Act 

(16 U.S.C. §1271 et seq.)

This act created the national wild and scenic rivers system, 

established to protect the environmental values of free flowing 

streams from degradation by impacting activities including water 

resources projects.

EPA Floodplain Executive Order 

(No. 11988. May 24, 1977, 

42 Federal Register (FR) 

26951) and Wetlands 

Executive Order 

(No. 11990. May 24, 1977, 

42 FR 26961)

Both Executive Orders require Federal agencies to consider the 

impacts of their actions on floodplains and wetlands through 

existing review procedures such as the National Environmental 

Policy Act of 1969 (NEPA).

Waste Management & Pollution Prevention

EPA Resource Conservation 

and Recovery Act (RCRA) 

(42 U.S.C. § 6901 et seq.)

Before a material can be classified as a hazardous waste, it must 

first be a solid waste as defined under the RCRA. Hazardous 

waste is classified under Subtitle C of the RCRA. All applicable 

generators of hazardous waste regulations are contained in 
Appendix C 

C-4 

Agency Law/Regulation Requirements

40 CFR Parts 261 and 262. Parts 261.5(a) and 261.5(e) contain 

requirements for conditionally-exempt small-quantity generators 

(CESQGs). Part 262.34(d) contains requirements for 

small-quantity generators (SQGs). Parts 262 and 261.5(e) contain 

requirements for large-quantity generators (LQGs). 

EPA Pollution Prevention Act

(42 U.S.C. § 13101 et seq.)

This act formally established a National policy to prevent or reduce 

pollution at its source whenever feasible. It provides funds for 

state and local pollution prevention programs through a grant 

program to promote the use of pollution prevention techniques by 

business.

Emergency planning & response

Ohio EPA, Division 

of Air Pollution 

Control 

Risk Management Program 

Ohio Administrative Code 

Chapter 3745-104

The intent of section 112(r) of the CAA is to prevent accidental 

releases to the air and mitigate the consequences of releases that 

do occur by focusing on prevention measures on chemicals that 

pose the greatest risk to the public and the environment. Under 

these requirements, industry has an obligation to prevent accidents 

and operate safely.

Ohio EPA, Division 

of Air Pollution 

Control 

Emergency Planning and 

Preparedness

Ohio Administrative Code

Chapter 1301:7-7-04

The Emergency Planning and Community Right-to-Know Act 

(EPCRA) was passed by Congress in 1986. EPCRA was included 

as Title III of the Superfund Amendments and Reauthorization Act 

(SARA) and is sometimes referred to as SARA Title III. EPCRA 

provides for the collection and availability of information regarding 

the use, storage, production, and release of hazardous chemicals 

to the public and emergency responders in your communities. The 

law promotes a working relationship among Government at all 

levels, business and community leaders, environmental and other 

public interest organizations, and individual citizens to improve 

hazard communications and emergency planning.

Ohio EPA, Division 

of Air Pollution 

Control 

Toxic Release Inventory 

Rules 

Ohio Administrative Code 

Chapter 3745-100

These rules establish reporting requirements and schedules for 

each toxic chemical known to be manufactured (including 

imported), processed, or otherwise used in excess of an applicable 

threshold quantity. It applies only to facilities of a certain 

classification.

Biotic resources protection

U.S. Fish & Wildlife 

Services (FWS)

Endangered Species Act 

(ESA) (16 U.S.C. § 1531 et 

seq.)

This act forbids any Government agency, corporation, or citizen 

from taking (harming or killing) endangered animals without an 

Endangered Species Permit.

FWS Fish and Wildlife 

Coordination Act (16 

U.S.C. § 661 et seq.)

To minimize adverse impacts of proposed actions on fish and 

wildlife resources and habitat, this act requires that Federal 

agencies consult Government agencies regarding activities that 

affect, control, or modify waters of any stream or bodies of water. 

It also requires that justifiable means and measures be used in 

modifying plans to protect fish and wildlife in these waters.

Ohio EPA, Division 

of Surface Water—

Isolated Wetland 

Permitting 

General and individual 

Isolated wetland permits

Ohio Administrative Code 

Chapter 6111.021

A person that proposes to engage in an activity that involves the 

filling of an isolated wetland shall apply to the director for coverage 

under a general state-isolated wetland permit or shall apply for an 

individual state-isolated wetland permit. No person shall engage in 

the filling of an isolated wetland unless authorized to do so by a 

general or individual state-isolated wetland permit. 

Cultural resources protection

Advisory Council on 

Historic Preservation

National Historic 

Preservation Act (NHPA) 

This act directs Federal agencies to consider the impact of their 

actions on historic properties. The NHPA also encourages state 
Appendix C 

C-5 

Agency Law/Regulation Requirements

(ACHP) (16 U.S.C. § 470 et seq.) and local preservation societies.

Ohio Historic 

Preservation Office

Ohio Historical 

Society

Historical Society

Ohio Administrative Code 

Chapter 149-1-02

These are guidelines for archaeological investigations on public 

land, archaeological preserves, and sites listed in the state registry 

of archaeological landmarks.

1 C.2 Operating Permits and Other Requirements

2 Several operating permit applications may be prepared and submitted, and regulatory approval 

3 or permits or both would be received prior to license renewal approval by the NRC. Table C-2 

4 lists representative Federal, state, and local permits.

5 Table C-2. Federal, State, and Local Permits and Other Requirements

6 Davis-Besse is subject to other requirements regarding various aspects of their environmental 

7 program. Those requirements are briefly described below.

License, Permit, or Other 

Required Approval

Responsible 

Agency

Authority Relevance & Status

License to operate NRC AEA

(42 U.S.C. 2011, et seq.) 

10 CFR 50.10

Operation of Davis-Besse

Permit Number: NPF-3 

Issued: 04/22/1977

Expires: 04/22/2017

Storage of spent nuclear 

fuel & high-level 

radioactive waste

NRC 10 CFR Part 72 Use of Radioactive waste cask

Certificate Number: 1004

Issued: 01/23/1995

Expired: 01/31/2015

Air quality protection

Permit to operate an air 

containment source

Ohio EPA, 

Division of Air 

Pollution Control

CAA, 40 U.S.C. 1857 et 

seq.; Ohio Air Pollution 

Control Act (Ohio 

Administrative Code 

Chapter 3745-31)

Operation of station auxiliary boiler

Permit Application No. 0362000091B001

Issued: Annual Reporting

Expires: Indefinite

Water resources protection

NPDES Ohio EPA, 

Division of 

Surface Water

CWA (33 U.S.C. 1251 et 

seq.); 

40 CFR Part 122

Ohio Water Pollution 

Control Act (Ohio Revised 

Code 6111)

Construction of Switchyard project and 

control-discharge of storm water in 

Ottawa County, Carrol Township

Ohio Permit No. 2GC02563*AG

Issued: 12/21/2009

Expires: Upon Project Completion

NPDES Ohio EPA, 

Division of 

Surface Water

CWA (33 U.S.C. 1251 et 

seq.); 40 CFR Part 122

Ohio Water Pollution 

Control Act (Ohio Revised 

Code 6111)

Treatment of wastewater and effluent 

discharge to surface receiving waters 

(Toussaint River and Lake Erie)

Ohio Permit No. 21B00011*ID
Appendix C 

C-6 

License, Permit, or Other 

Required Approval

Responsible 

Agency

Authority Relevance & Status

Issued: 09/01/2006

Expires: 04/30/2011

(every 5 years)

Water withdrawal and use 

registration and file annual 

report

Ohio Department 

of Natural 

Resources, 

Division of Water 

Resources

Ohio Revised Code 

Section 1521.16

Withdrawal and use of more than 

100,000 gallons of water daily from all 

sources

Registration # 00598

Issued: 01/01/1990

Expires: Indefinite

Waste management and pollution prevention

Notification of regulated 

waste activity

EPA RCRA, as amended 

(42 U.S.C. s/s 321 et seq. 

(1976)

Generation and accumulation of 

hazardous waste

EPA ID# OHD000720508

Issued: --- 

Expires: Indefinite

Report of regulated waste 

activity

Ohio EPA,

Division of 

Hazardous Waste 

Management

Ohio Administrative Code 

Chapter 3745-52-41

Generation. Accumulation and offsite 

disposal of hazardous waste

EPA ID# OHD000720508

Issued: Annual Reporting

Expires: Indefinite

Emergency planning and response

Hazardous material 

registration

U.S. Department 

of Transportation

Hazardous Materials 

Transportation Act 

(HMTA) (49 U.S.C. 1501 

et seq.); AEA, as 

amended (42 U.S.C. 2011 

et seq.); 

49 CFR Parts 107 

Subpart G, 172, 173, 174, 

177, and 397

Transportation of hazardous materials

Permit Number: 042009 450 002RT

Issued: 05/19/2009

Expires: 06/30/2012

(Renewed Triennially)

License to deliver 

radioactive waste

Tennessee 

Department of 

Environment and 

Conservation

Tennessee Code 

Annotated 68-202-206

Shipment of radioactive material to a 

licensed disposal-processing facility 

within the State of Tennessee

Tennessee Delivery License 

# T-OH003-LO9

Issued: Annually

Expires: 12/31/2010

Underground storage tank 

registration

Ohio Department 

of Commerce, 

Division of State 

Fire Marshal

Ohio Administrative Code 

1301: 7-9-04

Registration of underground diesel 

storage tanks T00001, T00002, and 

T00003

Certificate # 62000072

Issued: Annually

Expires: 06/30/2011
Appendix C 

C-7 

License, Permit, or Other 

Required Approval

Responsible 

Agency

Authority Relevance & Status

Human health

X-ray generating 

equipment registration

Ohio Department 

of Health

Ohio Administrative Code 

3701:1-38-03(C); Ohio 

Revised Code 3748.06 

and 3748.07

Operation of X-ray generation 

Equipment

Registration # 17-M-07181-005

Issued: Biennially

Expires: 05/31/2012

Biotic resource protection

Scientific Collection Permit Ohio Department 

of Natural 

Resources, 

Division of Wildlife

Ohio Revised Code 

Section 1531.08

Collection of wildlife specimens for 

Radiological Environmental Monitoring 

Program (REMP)

Permit# 10-21

Issued: Annually

Expires: 03/15/2011

APPENDIX D 

CONSULTATION CORRESPONDENCE

D-1 

1 D CONSULTATION CORRESPONDENCE

2 The Endangered Species Act of 1973, as amended; the Magnuson–Stevens Fisheries 

3 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 

4 require that Federal agencies consult with applicable state and Federal agencies and groups 

5 prior to taking action that may affect threatened and endangered species, essential fish habitat, 

6 or historic and archaeological resources, respectively. This appendix contains consultation 

7 documentation.

8 Table D–1. Consultation Correspondences

9 This is a list of the consultation documents sent between the U.S. Nuclear Regulatory 

10 Commission (NRC) and other agencies that it is required to consult with based on National 

11 Environmental Policy Act (NEPA) requirements.

Author Recipient Date of Letter

NRC

(David J. Wrona, Chief)

Advisory Council on Historic Preservation

(Mr. Reid Nelson, Director)

November 22, 2010

NRC

(David J. Wrona, Chief)

Ohio Historic Preservation Office 

(Mark Epsein)

December 7, 2010

U.S. Fish and Wildlife Service (USFWS)

(Mary Knapp, Field Supervisor)

NRC

(Cindy Bladey, Chief)

December 16, 2010

NRC

(David J. Wrona, Chief)

USFWS

(Mary Knapp, Field Supervisor)

June 1, 2011

NRC

(David J. Wrona, Chief)

National Oceanic and Atmospheric 

Administration (NOAA) National Marine 

Fisheries Service (NMFS) 

(Patricia Kurkul, Regional Administrator)

December 6, 2010

NRC

(David J. Wrona, Chief)

Ohio Department of Natural Resources 

(David Graham, Chief)

November 22, 2010

NRC

(David J. Wrona, Chief)

Ohio Department of Natural Resources 

(Brian Mitch, Environmental Review 

Manager)

November 23, 2010

NOAA NMFS

(Mary A. Colligan, Assistant Regional 

Administrator)

NRC

(David J. Wrona, Chief)

December 21, 2010

NRC

(David J. Wrona, Chief)

Delaware Nation 

(Edgar L. French)

November 23, 2010

NRC

(David J. Wrona, Chief)

Forest County Potawatomi Community 

(Harold G. Frank)

November 23. 2010

NRC

(David J. Wrona, Chief)

Hannahville Indian Community Council 

(Kenneth Meshiguad)

November 23, 2010

NRC

(David J. Wrona, Chief)

Miami Tribe of Oklahoma 

(Floyd E. Leonard)

November 23, 2010

NRC

(David J. Wrona, Chief)

Shawnee Tribe 

(Ron Sparkman)

November 23, 2010

NRC

(David J. Wrona, Chief)

Wyandotte Nation 

(Leaford Bearskin)

November 23, 2010
Appendix D 

D-2 

Author Recipient Date of Letter

NRC

(David J. Wrona, Chief)

Peoria Tribe of Indians of Oklahoma 

(John P. Froman)

November 23, 2010

NRC

(David J. Wrona, Chief)

Ottawa Tribe of Oklahoma 

(Charles Todd)

November 23, 2010

Peoria Tribe of Indians of Oklahoma 

(John P. Froman)

Chief, Rules and Directives Branch December 8, 2010
Appendix D 

D-3 
Appendix D 

D-4 
Appendix D 

D-5 
Appendix D 

D-6 
Appendix D 

D-7 
Appendix D 

D-8 
Appendix D 

D-9 
Appendix D 

D-10
Appendix D 

D-11
Appendix D 

D-12
Appendix D 

D-13
Appendix D 

D-14
Appendix D 

D-15
Appendix D 

D-16
Appendix D 

D-17
Appendix D 

D-18
Appendix D 

D-19
Appendix D 

D-20
Appendix D 

D-21
Appendix D 

D-22
Appendix D 

D-23
Appendix D 

D-24
Appendix D 

D-25
Appendix D 

D-26
Appendix D 

D-27
Appendix D 

D-28
Appendix D 

D-29
Appendix D 

D-30
Appendix D 

D-31
Appendix D 

D-32
Appendix D 

D-33
Appendix D 

D-34
Appendix D 

D-35
Appendix D 

D-36
Appendix D 

D-37
Appendix D 

D-38
Appendix D 

D-39
Appendix D 

D-40
Appendix D 

D-41
Appendix D 

D-42
Appendix D 

D-43
Appendix D 

D-44
Appendix D 

D-45
Appendix D 

D-46
Appendix D 

D-47
Appendix D 

D-48
Appendix D 

D-49
Appendix D 

D-50
Appendix D 

D-51
Appendix D 

D-52
Appendix D 

D-53

APPENDIX E 

CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

E-1 

1 E CHRONOLOGY OF ENVIRONMENTAL REVIEW 

2 CORRESPONDENCE

3 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

4 Regulatory Commission (NRC) and external parties as part of its environmental review for 

5 Davis-Besse Nuclear Power Station, Unit 1. All documents, with the exception of those 

6 containing proprietary information are available electronically from the NRC’s Public Electronic 

7 Reading Room found on the Internet at the following Web address: 

8 http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC’s 

9 Agencywide Documents Access and Management Systems (ADAMS), which provides text and 

10 image files of NRC’s public documents. The ADAMS accession number for each document is 

11 included below.

August 27, 2010 Letter from Barry S. Allen, “Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, License Renewal 

Application and Ohio Coastal Management Program Consistency 

Certification” (ADAMS Accession No. ML1024505650)

September 14, 2010 Letter to Deborah Rossman, Director, Ida Rupp Public Library

“Maintenance of Reference Materials at the Ida Rupp Public Library in 

Regards to the Review of the Davis-Besse Nuclear Power Station, 

Unit 1, License Renewal Application” (ADAMS Accession 

No. ML1024503420)

September 14, 2010 Letter to Mr. Clyde Scoles, Director, Toledo-Lucas County Public 

Library, “Maintenance of Reference Materials at the Toledo-Lucas 

County Public Library in Regards to the Review of the Davis-Besse 

Nuclear Power Station, Unit 1, License Renewal Application” (ADAMS

Accession No. ML1024507070)

September 17, 2010 Letter to Barry S. Allen, Receipt and Availability of the License 

Renewal Application for the Davis-Besse Nuclear Power Station, 

Unit 1 (ADAMS Accession No. ML1023003250)

September 20, 2010 Press Release: NRC Announces Availability of License Renewal 

Application for Davis-Besse Nuclear Plant (ADAMS Accession 

No. ML102630380)

September 24, 2010 E-mail from Megan Seymore, Wildlife Biologist, U.S. Fish and Wildlife 

Service, to Richard Bulavinetz, NRC, titled Davis-Besse Transmission 

line corridor (ADAMS Accession No. 103630080)
Appendix E

E-2 

October 12, 2010 Memorandum to David Wrona, NRC, from Andy Imboden, NRC,

Acceptance of License Renewal Application, Davis-Besse Nuclear 

Power Station, Unit 1 (ADAMS Accession No. ML102850303)

October 18, 2010 Letter to Barry S. Allen, Determination of Acceptability and Sufficiency 

for Docketing, and Opportunity for a Hearing Regarding the 

Application from FirstEnergy Nuclear Operating Company, for renewal 

of the Operating License for the Davis-Besse Nuclear Power Station, 

Unit 1 (ADAMS Accession No. ML1027105840)

October 20, 2010 Letter to Barry S. Allen, “Notice of Intent to Prepare an Environmental 

Impact Statement and Conduct Scoping Process for License Renewal 

for the Davis-Besse Nuclear Power Station, Unit 1” (ADAMS 

Accession No. ML1027006031)

October 22, 2010 Memorandum to David J. Wrona, NRC, from Paula Cooper, NRC, and 

Brian Harris, NRC, Forthcoming Meeting to Discuss the License 

Renewal Process and Environmental Scoping for Davis-Besse 

Nuclear Power Station License Renewal Application Review (ADAMS 

Accession No. ML102870261)

October 26, 2010 Press Release: NRC Announces Opportunity for Hearing on 

Application to Renew Operating License For Davis-Besse Nuclear 

Power Plant (ADAMS Accession No. ML102990387)

October 28, 2010 Press Release: NRC to Conduct Environmental Scoping Meeting as 

Part of the License Renewal Application for Davis-Besse: Meeting 

November 4 (ADAMS Accession No. ML103010069)

November 4, 2010 Transcript Davis-Besse License Renewal Public Meeting—Afternoon 

Session, pages 1–46 (ADAMS Accession No. 110140231)

November 4, 2010 Transcript Davis-Besse License Renewal Public Meeting—Evening 

Session, pages 1–37 (ADAMS Accession No. 110140232) 

November 22, 2010 Letter from NRC to Reid Nelson, Director, Advisory Council on 

Historic Preservation (ACHP) Davis-Besse Nuclear Power Station, 

Unit 1, License Renewal Application Review (ADAMS Accession 

No. ML1029801401)
Appendix E

E-3 

November 22, 2010 Letter to David Graham, Chief, Division of Wildlife, Ohio Department 

of Natural Resources (OHDNR), “Request for List of Protected 

Species Within the Area Under Evaluation for the Davis-Besse 

Nuclear Power Station License Renewal Application Review” (ADAMS 

Accession No. ML102980688)

November 23, 2010 Letter to Brian Mitch, Environmental Review Manager, OHDNR, 

“Request for List of Protected Species Within the Area Under 

Evaluation for the Davis-Besse Nuclear Power Station License 

Renewal Application Review” (ADAMS Accession No. ML102980430)

November 23, 2010 Letter to Edgar L, French, Delaware Nation, “Request for Scoping 

Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, 

License Renewal Application Review” (ADAMS Accession 

No. ML1030001644) 

November 23, 2010 Letter to Harold G. Frank, Forest County Potawatomi Community, 

“Request for Scoping Comments Concerning the Davis-Besse 

Nuclear Power Plant, Unit 1, License Renewal Application Review” 

(ADAMS Accession No. ML1030001644) 

November 23, 2010 Letter to Kenneth Meshiguad, Hannahville Indian Community Council,

“Request for Scoping Comments Concerning the Davis-Besse 

Nuclear Power Plant, Unit 1, License Renewal Application Review” 

(ADAMS Accession No. ML1030001644) 

November 23, 2010 Letter to Floyd E. Leonard, Miami Tribe of Oklahoma, “Request for 

Scoping Comments Concerning the Davis-Besse Nuclear Power 

Plant, Unit 1, License Renewal Application Review” (ADAMS 

Accession No. ML1030001644) 

November 23, 2010 Letter to Ron Sparkman, Shawnee Tribe, “Request for Scoping 

Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, 

License Renewal Application Review” (ADAMS Accession 

No. ML1030001644) 

November 23, 2010 Letter to Leaford Bearskin, Wyandotte Nation, “Request for Scoping 

Comments Concerning the Davis-Besse Nuclear Power Plant, Unit 1, 

License Renewal Application Review” (ADAMS Accession 

No. ML1030001644) 
Appendix E

E-4 

November 23, 2010 Letter to John P. Froman, Peoria Tribe of Indians of Oklahoma, 

“Request for Scoping Comments Concerning the Davis-Besse 

Nuclear Power Plant, Unit 1, License Renewal Application Review” 

(ADAMS Accession No. ML1030001644) 

November 23, 2010 Letter to Charles Todd, Ottawa Tribe of Oklahoma, “Request for 

Scoping Comments Concerning the Davis-Besse Nuclear Power 

Plant, Unit 1, License Renewal Application Review” (ADAMS 

Accession No. ML1030001644) 

December 6, 2010 Letter from NRC to Patricia Kurkul, National Oceanic and Atmospheric 

Administration Fisheries Service (NOAA), “Request for List of 

Protected Species Within the Area Under Evaluation for the 

Davis-Besse Nuclear Power Station License Renewal Application 

Review” (ADAMS Accession No. ML1029806923) 

December 7, 2010 Letter from NRC to Mark Epstein, Ohio State Historic Preservation 

Officer, “Davis-Besse Nuclear Power Station, Unit 1, License Renewal 

Application Review” (ADAMS Accession No. ML1029806874) 

December 11, 2010 Video Recording of Public Comments on the NRC Relicensing of the 

Davis-Besse Nuclear Plant in Columbus, Ohio (ADAMS Accession 

No. ML11348A013) 

December 16, 2010 Letter from Mary Knapp, United States Department of the Interior, 

Fish and Wildlife Services, “Docket ID NRD-2010-0298” (ADAMS 

Accession No. ML1100602894)

December 18, 2010 Transcript and Video Recording of the People’s Hearing on 

Davis-Besse Relicensing (ADAMS Accession No. ML 11209C0801)

December 21, 2010 Letter from Mary A. Colligan, NOAA, “Re: Davis-Besse Nuclear 

Power Station” (ADAMS Accession No. ML1101402300)

December 28, 2010 Letter to Barry S. Allen, “Schedule for the Conduct of Review of the 

Davis-Besse Nuclear Power Station, Unit 1, License Renewal 

Application” (ADAMS Accession No. ML1034305800)

February 2, 2011 E-mail to Laura Bonneau, FWS, “Educational Program” (ADAMS 

Accession No. ML11236A085) 
Appendix E

E-5 

February 9, 2011 E-mail from Laura Bonneau, FWS, “Educational Program” (ADAMS 

Accession No. ML11235A564) 

February 10, 2011 E-mail to Laura Bonneau, FWS, “Educational Program” (ADAMS 

Accession No. ML11236A083) 

February 10, 2011 E-mail from Laura Bonneau, FWS, “Educational Program” 

(ADAMS Accession No. ML11235A558) 

February 15, 2011 E-mail to Mary Knapp, FWS, for invitation to the license renewal 

environmental audit (ADAMS Accession No. ML11236A075) 

February 15, 2011 E-mail from Mary Knapp, FWS, in response to audit invitation 

(ADAMS Accession No. ML11235A748) 

February 15, 2011 E-mail to Brain Mitch, OHDNR, for invitation to the License renewal 

environmental audit (ADAMS Accession No. ML11236A077) 

February 15, 2011 E-mail to Dave Snyder, OHPO, for invitation to the license renewal 

environmental audit (ADAMS Accession No. ML11236A079) 

February 23, 2011 Letter to Barry S. Allen, “Requests for Additional Information (RAIs) 

for the Review of the Davis-Besse Nuclear Power Station, Unit 1, 

License Renewal Application (ADAMS Accession 

No. ML1101304942)

February 28, 2011 Letter to Barry S. Allen, “Environmental Site Audit Regarding 

Davis-Besse Nuclear Power Station, Unit 1, License Renewal 

Application” (ADAMS Accession No. ML1101901132)

March 4, 2011 E-mail to Mary Knapp, FWS, to provide environmental audit schedule 

(ADAMS Accession No. ML11236A069) 

March 4, 2011 E-mail to Mark Epstein, OHPO, for invitation to the license renewal 

environmental audit (ADAMS Accession No. ML11236A071) 

March 4, 2011 E-mail from Dave Snyder, OHPO, in response to audit invitation 

(ADAMS Accession No. ML11236A071) 
Appendix E

E-6 

March 4, 2011 E-mail to Dave Snyder, OHPO, for scheduling of Audit telephone 

conference (ADAMS Accession No. ML11236A073) 

March 8, 2011 E-mail from Laura Bonneau, FWS, for confirmation of audit activities 

(ADAMS Accession No. ML11235A556 ) 

March 8, 2011 E-mail to Dave Snyder, OHPO, to provide audit-related conference 

call information (ADAMS Accession No. ML11236A067) 

March 9, 2011 E-mail to Laura Bonneau, FWS, to provide audit-related conference 

call information and scheduling (ADAMS Accession 

No. ML11236A065 ) 

March 14, 2011 E-mail to Megan Seymour, FWS, to provide update on transmission 

line mapping (ADAMS Accession No. ML 1107303280)

March 23, 2011 Letter from Barry S. Allen, “Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346. License Number NPF-3, Reply to RAI for 

the Review of the Davis-Besse Nuclear Power Station, Unit 1, License 

Renewal Application” (TAC No. ME4640) (ADAMS Accession 

No. ML1108800582)

May 27, 2011 RAI responses from applicant, “Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, Reply to RAIs for 

the Review of the Davis-Besse Nuclear Power Station, Unit 1, License 

Renewal Application” (TAC No. ME4613) Environmental Report 

(ADAMS Accession No. ML11193A093) 

April 20, 2011 Letter to Barry S. Allen, “RAI for the Review of the Davis-Besse 

Nuclear Power Station, Unit 1, License Renewal Application” (ADAMS 

Accession No. ML1109105664)

April 26, 2011 Letter to Barry S. Allen, “RAI for the Review of the Davis-Besse 

Nuclear Power Station, Unit 1, License Renewal Application” (ADAMS 

Accession No. ML11094A0993)

June 1, 2011 Letter to Mary Knapp, FWS, “Request for Lost of Federally Protected 

Species and Important Habitats within the Area Under Evaluation for 

the Davis-Besse Nuclear Power Station License Renewal Application 

Review” (ADAMS Accession No. ML11131A1765)
Appendix E

E-7 

June 3, 2011 Summary of site audit to support review of LRA of Davis-Besse 

Nuclear Power Station, Unit 1 (ADAMS Accession 

No. ML1108202760)

July 11, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, Ohio Department 

of Natural Resources Office of Coastal Management Concurrence 

with Federal Consistency Certification Related to the Review of the 

Davis-Besse Nuclear Power Station, Unit 1, License Renewal 

Application Environmental Report (TAC No. ME4613) (ADAMS 

Accession No. ML11195A1460)

June 24, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, Reply to RAI for 

the Review of the Davis-Besse Nuclear Power Station, Unit 1, License 

Renewal Application (TAC No. ME4613) Environmental Report 

Severe Accident Mitigation Alternatives Analysis and License 

Renewal Application Amendment No.1 (ADAMS Accession 

No. ML11180A233) 

July 11, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, Ohio Department 

of Natural Resources, Office of Coastal Management Concurrence 

with Federal Consistency Certification Related to the Review of the 

Davis-Besse Nuclear Power Station, Unit 1, License Renewal 

Application Environmental Report (TAC No. ME4613) (ADAMS 

Accession No. ML11195A146) 

August 1, 2011 Summary of scoping meeting held in support of the environmental 

review for the Davis-Besse Nuclear Power Station, Unit 1, LRA 

(ADAMS Accession No. ML11173A200) 

August 15, 2011 Memorandum from John Parillo, NRC, to Travis L. Tate, Branch Chief, 

NRC, “RAI Response Clarifications from Davis-Besse Nuclear Power 

Station in Support of License Renewal Application” (TAC 

No. ME4613) (ADAMS Accession No. ML112270139) 

August 31, 2011 Memorandum from Travis L. Tate, Branch Chief, NRC, to David J. 

Wrona, Branch Chief, NRC, “Evaluation of Severe Accident Mitigation 

Alternatives for Davis-Besse Nuclear Power Station” 

(TAC No. ME4613) (ADAMS Accession No. ML112300844) 
Appendix E

E-8 

September 1, 2011 Letter from Barry S. Allen, Davis-Besse Nuclear Power Station, Unit 1, 

Docket No. 50-346, License Number NPF-3, Reply to Supplemental 

RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, 

License Renewal Application (TAC No. ME4613) Environmental 

Report Severe Accident Mitigation Alternatives Analysis (ADAMS 

Accession No. ML11250A0680)

September 19, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, License Renewal 

Application Amendment No. 16, Supplemental Information for the 

Review of the Davis-Besse Nuclear Power Station, Unit 1, License 

Renewal Application Environmental Report (TAC No. ME4613)

(ADAMS Accession No. ML11266A0620) 

September 19, 2011 Letter from Kendall W. Byrd, Davis-Besse Nuclear Power Station, 

Unit 1, Docket No. 50-346, License Number NPF-3, License Renewal 

Application Amendment No. 17, Supplemental Information for the 

Review of the Davis-Besse Nuclear Power Station, Unit 1, License 

Renewal Application Environmental Report (TAC No. ME4613) 

(ADAMS Accession No. ML11266A0090)

October 31, 2011 Letter to Barry S. Allen, “Schedule Revision for the Environmental and 

Safety Review of the Davis-Besse Nuclear Power Station, Unit 1, 

License Renewal Application” (ADAMS Accession No. ML11256A164)

July 31, 2013 Letter to Barry S. Allen, “Schedule Revision for the Environmental and 

Safety Review of the Davis-Besse Nuclear Power Station, Unit 1, 

License Renewal Application” (ADAMS Accession No. ML13205A036)
APPENDIX F 

U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF 

SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR DAVIS-BESSE 

NUCLEAR POWER STATION IN SUPPORT OF LICENSE RENEWAL 

APPLICATION REVIEW

F-1 

1 F U.S. NUCLEAR REGULATORY COMMISSION STAFF

2 EVALUATION OF SEVERE ACCIDENT MITIGATION 

3 ALTERNATIVES FOR DAVIS-BESSE NUCLEAR POWER STATION 

4 IN SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW

5 F.1 Introduction

6 FirstEnergy Nuclear Operating Company (FENOC), on behalf of FirstEnergy Nuclear 

7 Generation Corporation, submitted to the U.S. Nuclear Regulatory Commission (NRC) an 

8 assessment of severe accident mitigation alternatives (SAMAs) for the Davis-Besse Nuclear 

9 Power Station, Unit 1 (Davis-Besse) as part of the Environmental Report (ER) (FENOC 2010). 

10 This assessment was based on the most recent Davis-Besse probabilistic risk assessment 

11 (PRA) available at that time, a plant-specific offsite consequence analysis performed using the 

12 MELCOR Accident Consequence Code System 2 (MACCS2) computer code (NRC 1998a), and 

13 insights from the Davis-Besse individual plant examination (IPE) (Centerior Energy 1993) and 

14 individual plant examination of external events (IPEEE) (Centerior Energy 1996). In identifying 

15 and evaluating potential SAMAs, FENOC considered SAMA candidates that addressed the 

16 major contributors to core damage frequency (CDF) and large early release frequency (LERF) 

17 at Davis-Besse, as well as SAMA candidates for other operating plants that have submitted 

18 license renewal applications (LRAs). FENOC identified 167 potential SAMA candidates. The 

19 SAMA candidates were reduced to 15 by eliminating SAMAs that are not applicable for one or 

20 more of the following reasons:

21 • The SAMA has design differences or has already been implemented at Davis-Besse.

22 • The SAMA is not applicable to Davis-Besse.

23 • The SAMA has estimated implementation costs that would exceed the dollar value 

24 associated with eliminating all severe accident risk at Davis-Besse.

25 • The SAMA is related to a non-risk significant system and, therefore, has a very low 

26 benefit.

27 • The SAMA is similar in nature and could be combined with another SAMA candidate. 

28 FENOC assessed the costs and benefits associated with each of these 15 potential SAMAs and 

29 concluded in the ER that one of the candidate SAMAs evaluated is potentially cost-beneficial.

30 Based on a review of the SAMA assessment, the NRC issued a request for additional 

31 information (RAI) to FENOC by letter dated April 20, 2011 (NRC 2011a). Key questions 

32 concerned the following: 

33 • additional details regarding the plant-specific PRA model and changes to CDF and 

34 LERF since the IPE, 

35 • additional information on the internal and external reviews of the PRA model performed 

36 since the IPE, 

37 • the process used to map Level 1 PRA results into the Level 2 analysis and group 

38 containment event tree (CET) end states into release categories, 

39 • justification for the multiplier used for external events, 

40 • population assumptions used in the Level 3 analysis, 
Appendix F

F-2 

1 • the use of importance analysis in identifying plant-specific SAMA candidates, and

2 • further information on the cost-benefit analysis of several specific candidate SAMAs and 

3 low-cost alternatives. 

4 FENOC submitted additional information to the NRC by letter dated June 24, 2011 

5 (FENOC 2011). FENOC also provided clarifications to the RAI responses via e-mail on July 18 

6 and July 27, 2011 (NRC 2011b). In response to the RAIs, FENOC provided the following 

7 information:

8 • identification of key factors for a significant change in CDF associated with particular 

9 version of the Davis-Besse PRA model, 

10 • clarification of the scope of the peer reviews and the status of peer review findings, 

11 • description of the process for mapping Level 1 results into the Level 2 analysis and for 

12 assigning CET sequences to release categories, 

13 • a revised SAMA analysis reflecting a higher maximum benefit, higher external events 

14 multiplier, and the 95th percentile CDF, 

15 • clarification of the sensitivity analysis, 

16 • an assessment of SAMAs previously found to be potentially cost beneficial for Babcock 

17 and Wilcox (B&W) plants, 

18 • additional rationale for not identifying SAMAs for many of the basic events on the risk 

19 importance lists, 

20 • additional rationale for considering SAMAs related to improved procedures or training or 

21 automated functions that would eliminate high risk operator error, 

22 • an assessment of SAMAs subsumed by other more costly SAMAs, and

23 • additional information regarding several specific SAMAs. 

24 Subsequent to the RAI responses, FENOC submitted a supplement to the ER that corrected the 

25 following five errors in the SAMA assessment (FENOC 2012a):

26 (1) An inaccurate land area conversion factor for acres to hectares was used.

27 (2) Dollar values for Ohio farmland and non-farmland were selected from Ohio Department 

28 of Taxation ‘tax assessment’ values instead of ‘appraised’ values. 

29 (3) The escalation of decontamination costs was not performed in accordance with 

30 approved guidance. 

31 (4) Core inventory isotopic ‘activity’ was used instead of isotopic ‘mass’ in the Modular 

32 Accident Analysis Program (MAAP) software code runs in contrast to updated industry 

33 guidance. 

34 (5) The wind direction from the Davis-Besse Meteorological Tower was not converted from 

35 the ‘blowing from’ direction to the ‘blowing toward’ direction for use in the SAMA Analysis 

36 calculations. 

37 Based on a review of this updated SAMA assessment, the NRC held a conference call with 

38 FENOC on September 25, 2012, to clarify the decontamination cost escalation factor used in 

39 the assessment and the updated release category results (FENOC 2012b).
Appendix F

F-3 

1 FENOC’s response to the RAIs, as well as FENOC’s response to the ER supplement 

2 clarification questions, addressed all the concerns raised by the NRC staff. 

3 An assessment of SAMAs for Davis-Besse is presented below.

4 F.2 Estimate of Risk for Davis-Besse

5 FENOC’s estimates of offsite risk at Davis-Besse are summarized in Section F.2.1. The 

6 summary is followed by the NRC staff’s review of FENOC’s risk estimates in Section F.2.2.

7 F.2.1 FENOC’s Risk Estimates

8 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 

9 analysis; the Davis-Besse Level 1 and 2 PRA model, which is an updated version of the IPE 

10 (Centerior Energy 1993), and a supplemental analysis of offsite consequences and economic 

11 impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The 

12 SAMA analysis is based on the most recent Davis-Besse Level 1 and Level 2 PRA model 

13 available at the time of the ER, which is referred to as “SAMA Analysis Model,” and is a special 

14 update of the Davis-Besse Revision 4 PRA to support the SAMA evaluation. The scope of this 

15 Davis-Besse PRA does not include external events.

The Davis-Besse CDF is approximately 9.8×10-6 16 per year for internal events using a truncation 

value of 5x10-13 17 per year. This CDF includes contributions from internal flooding and high winds 

18 (not including tornado-generated missiles). When determined from the sum of the CET 

19 sequences, or Level 2 model, the release frequency (from all release categories including intact 

containment, early and late releases) is approximately 1.0x10-5 20 per year using a truncation value 

of 5x10-13 21 per year. The latter value was used as the baseline CDF in the SAMA evaluations. 

22 The CDF is based on the risk assessment for internally initiated events, which includes internal 

23 flooding. FENOC did not explicitly include the contribution from external events in the 

24 Davis-Besse PRA risk estimates; however, it did account for the potential risk reduction benefits 

25 associated with external events by multiplying the estimated benefits for internal events by a 

26 factor of 3.0. As a result of NRC review, FENOC revised the external events multiplier to a 

27 factor of 4.6. This is discussed further in Sections F.2.2 and F.6.2.

28 The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, loss 

29 of offsite power (LOOP), loss of component cooling water (CCW), and reactor or turbine trips 

30 are the dominant contributors to the CDF. Anticipated transient without scram (ATWS) 

31 sequences are modeled as a failure to trip after an initiating event; ATWS sequences contribute 

32 approximately 1 percent to CDF. Station Black Out (SBO) sequences involve a LOOP (as the 

33 initiating event or following an initiating event), along with subsequent failure of power to both 

34 safety buses, (i.e., a loss of both emergency diesel generators (EDGs) and the SBO diesel 

35 generator); SBO sequences contribute approximately 5 percent to CDF and are dominated by 

36 sequences initiated by a LOOP. 

37 The Level 2 PRA model that forms the basis for the SAMA evaluation represents a complete 

38 revision of the original IPE Level 2 model. The current Level 2 model uses a single CET 

39 containing both phenomenological and systemic events. The Level 1 core damage sequences 

40 are grouped into core damage bins according to similarities in their impact on containment 

41 response. The core damage bins, together with the states of containment systems comprise 

42 the plant damage states (PDSs), which provide the interface between the Level 1 analysis and 

43 Level 2 CET analysis. The CET probabilistically evaluates the progression of the damaged core 
Appendix F

F-4 

1 with respect to release to the environment. CET nodes are evaluated using supporting fault 

2 trees and logic rules. The CET end states are then examined for considerations of timing and 

3 magnitude of release and assigned to release categories.

4 The result of the Level 2 PRA is a set of 34 specific release categories, also referred to as 

5 source term categories, with their respective frequency and release characteristics. The results 

6 of this analysis for Davis-Besse are provided in Table E.3-13 of Appendix E to the ER 

7 (FENOC 2010). The frequency of each release category was obtained by summing the 

8 frequency of the individual accident progression CET endpoints assigned to each release 

9 category. Source terms were developed for each of the 34 release categories using the results 

10 of Modular Accident Analysis Program (MAAP) Version 4.0.6 computer code calculations based 

11 on characteristics that determine the timing and magnitude of the release, whether or not the 

12 containment remains intact, and isotopic composition of the release material (FENOC 2010). 

13 The offsite consequences and economic impact analyses use the MACCS2 code to determine 

14 the offsite risk impacts on the surrounding environment and public. Inputs for these analyses 

15 include plant-specific and site-specific input values for core radionuclide inventory, source term 

16 and release characteristics, site meteorological data, projected population distribution within a 

17 50-mi (80-km) radius for the year 2040, emergency response evacuation planning, and 

18 economic parameters. The core radionuclide inventory corresponds to the end-of-cycle values 

19 for Davis-Besse operating at 2,827 megawatt thermal (MWt), which bounds the currently 

20 approved power level. The magnitude of the onsite impacts (in terms of cleanup and 

21 decontamination costs and occupational dose) is based on information provided in 

22 NUREG/BR-0184, “Regulatory Analysis Technical Evaluation Handbook” (NRC 1997a).

23 Table F-1. Davis-Besse Core Damage Frequency for Internal Events

Initiating Event(a) CDF (per year)(d) % Contribution to 

CDF(d) 

LOOP 1.9×10-6 19

Loss of CCW pump(s) 1.7×10-6 18

Reactor or turbine trip 1.3×10-6 13

Steam generator tube rupture (SGTR) 6.2×10-7 6

Loss of main feedwater 5.7×10-7 6

Main feedwater flow control(b) 5.1×10-7 5

Reactor vessel (RV) rupture 5.0×10-7 5

Small loss-of-coolant accident (LOCA) 4.3×10-7 4

Flooding in CCW pump room 2.0×10-7 2

Medium LOCA 1.5×10-7 2

Loss of service water pump room ventilation 1.3×10-7 1

Loss of direct current (DC) power from Bus d2p 1.1×10-7 1

Flooding in turbine building 8.8×10-8 1

Loss of non-nuclear instrumentation cabinets 1–4 (NNIX) 

DC power supply 8.2×10-8 1 
Appendix F

F-5 

Initiating Event(a) CDF (per year)(d) % Contribution to 

CDF(d) 

Other(c) 1.5x10-6 15

Total CDF (internal events) 9.8×10-6 100

(a) This table is based on model quantification using 5x10-13 per year truncation.

(b) In response to an NRC staff RAI, FENOC explains that T2A-1 and T2B-1 are main feedwater flow control valve initiators, and 

T2A-2 and T2B-2 are the associated flow controller initiators. These four initiators combined form the main feedwater flow control 

initiator (FENOC 2011).

(c) This is calculated from information in ER Table E.3-1.

(d) Column totals may be different due to round off.

1 In response to an NRC staff RAI, FENOC estimated the dose to the population within 50 mi 

2 (80 km) of the Davis-Besse site to be approximately 0.0212 person-Sievert (Sv) 

3 (2.12 person-rem) per year (FENOC 2012a). The breakdown of the total population dose by 

4 containment release mode is summarized in Table F-2. SGTR and interfacing system LOCA 

5 (ISLOCA), both containment bypass events, dominate the population dose risk at Davis-Besse.

6 Table F-2. Breakdown of Population Dose by Containment Release Mode

Containment release mode(a,b) Population Dose (person-rem(c,d) per year) % Contribution (d)

SGT 1.35 64

ISLOCA 0.35 17

Large containment isolation failure 0.02 1

Small containment isolation failure 0.06 3

Large early release 0.03 1

Sidewall failure (early) 0.03 1

Late containment failure 0.06 3

Basemat failure 0.21 10

No containment failure 0.02 1

Total 2.12 100

(a) This table is based on model quantification using 5x10-13 per year truncation.

(b) Estimated population doses calculated from revised information provided in Table E.3-21 of response to NRC staff RAI 4.b 

(FENOC 2011).

(c) One person-rem = 0.01 person-Sv.

(d)Column totals may be different due to round off

7 F.2.2 Review of FENOC’s Risk Estimates 

8 FENOC’s determination of offsite risk at Davis-Besse is based on the following major elements 

9 of analysis:

10 • the Level 1 and 2 risk models that form the bases for the 1993 IPE submittal (Centerior 

11 Energy 1993) and the external event analyses of the 1996 IPEEE submittal (Centerior 

12 Energy 1996); 
Appendix F

F-6 

1 • the major modifications to the IPE model that have been incorporated in the 

2 Davis-Besse PRA, including a complete revision of the Level 2 risk model; and

3 • the MACCS2 analyses performed to translate fission product source terms and release 

4 frequencies from the Level 2 PRA model into offsite consequence measures. 

5 Each of these analyses was reviewed to determine the acceptability of the Davis-Besse risk 

6 estimates for the SAMA analysis, as summarized below.

7 The NRC staff’s review of the Davis-Besse IPE is described in a safety evaluation report (SER) 

8 (NRC 1996). Based on the review of the original IPE submittal and responses to RAIs, the NRC 

9 staff concluded that the IPE submittal met the intent of generic letter (GL) 88-20, “Individual 

10 Plant Examination for Severe Accident Vulnerabilities” (NRC 1988); that is, the applicant’s IPE 

11 process is capable of identifying the most likely severe accidents and severe accident 

12 vulnerabilities. Although no vulnerabilities were identified in the IPE, 11 improvements to the 

13 plant or procedures were identified. These improvements have been either implemented at the 

14 site or included in the SAMA evaluation process (FENOC 2010). These improvements are 

15 discussed in Section F.3.2.

16 There have been five revisions to the IPE model between the 1993 IPE submittal and the model 

17 used for the SAMA analysis. A listing of the major changes in each revision of the PRA was 

18 provided by FENOC in Section E.3.1.1.2 of the ER (FENOC 2010) and in response to an NRC 

19 staff RAI (FENOC 2011). The revisions to the IPE are summarized in Table F-3. FENOC 

20 clarified that the large decrease in CDF between Revision 0 and Revision 1 is primarily due to 

21 reduction in transient frequencies for reactor or turbine trips and loss of main feedwater. 

22 Additionally, the sizeable decrease between Revision 3 and Revision 4 was primarily due to 

23 update of data and an increase in the time operators have to trip the reactor cooling pumps 

24 following loss of seal cooling. A comparison of the internal events CDF between the 1993 IPE 

and the SAMA analysis model indicates a decrease of approximately 85 percent (from 6.6x10-5 25

per year to 9.8x10-6 26 per year).

The CDF value from the 1993 Davis-Besse IPE (6.6x10-5 27 per year) is near the higher end of the 

28 range of the CDF values reported in the IPEs for B&W plants. Figure 11.6 of NUREG-1560 

shows that the IPE-based internal events CDF for these plants range from about 1×10-5 29 per year 

to 7x10-5 per year, with an average CDF for the group of 3x10-5 30 per year (NRC 1997b). It is 

31 recognized that other plants have updated the values for CDF subsequent to the IPE submittals 

32 to reflect modeling and hardware changes. The internal events CDF result for Davis-Besse 

used for the SAMA analysis (9.8x10-6 33 per year, including internal flooding) is comparable to that 

34 for other plants of similar vintage and characteristics.

35 The NRC staff considered the peer reviews performed for the Davis-Besse PRA and the 

36 potential impact of the review findings on the SAMA evaluation. In the ER (FENOC 2010) and 

37 in response to an NRC staff RAI (FENOC 2011), FENOC describes a B&W owner’s group peer 

38 review performed from 1999 through 2000 on internal events and LERF and a “gap self 

39 assessment” performed by a team of industry peers and internal staff using the 2005 American 

40 Society of Mechanical Engineers (ASME) PRA standard (ASME 2005). The owner’s group peer 

41 review identified no Level A (important and necessary to address before the next regular PRA 

42 update) and 18 Level B (important and necessary to address, but disposition may be deferred 

43 until the next PRA update) facts and observations (F&Os). FENOC clarifies that 13 of these 

44 open findings were closed prior to implementation of the mitigating systems performance index 

45 (MSPI) document, four were closed in the SAMA analysis model, and the remaining F&O is 
Appendix F

F-7 

1 essentially addressed by the SAMA evaluation. This last finding recommended additional 

2 sensitivity studies be performed to study the sensitivity of results to modeling PRA assumptions. 

3 The SAMA evaluation includes an importance analysis of basic and initiating events as well as a 

4 Level 3 parameter sensitivity analysis, and, in response to an NRC staff RAI, FENOC provided 

5 the results of an uncertainty analysis (further discussed in Section F.6.1). Therefore, further 

6 insights gained from an additional sensitivity analysis would not be expected to yield significant 

7 new insights. FENOC explained in the ER and in an RAI response that the gap self8 assessment covered Level 1 and LERF elements excluding internal flooding and high winds, 

9 and that it focused on identifying gaps to meeting Capability Category II of the ASME PRA 

10 standard (ASME 2005). There were four Level A findings and 23 Level B findings from this gap 

11 self-assessment. FENOC summarized these findings, and the model changes made to address 

12 the findings in Section E.3.1.1.2 of the ER (FENOC 2010), and stated in the RAI response that 

13 all of the Level A and B findings are addressed in the SAMA analysis model. 

14 Table F-3. Davis-Besse Probabilistic Risk Assessment Historical Summary

PRA Version Summary of Changes From Prior Model CDF (per year)

1993 IPE Submittal 6.6×10-5

Revision 0

Revision 1

Revision 2

1999

• Performed plant-specific update of failure rates, unavailability, common 

cause, initiating event frequency, and human reliability analysis (HRA)

• Made modifications to reflect plant and procedure changes including adding 

the SBO diesel generator (DG), removal of a startup feed pump, 

improvements to CCW and service water system modeling, update of SGTR 

emergency response modeling, and internal flooding modeling

• Improved model documentation to comply with draft PRA standard 

requirements

1.4x10-5

1.6x10-5

1.7x10-5

Revision 3

5/2001

• Added explicit LERF model

• Addressed all Level B peer review findings

• Improved model quantification logistics including reducing truncation limit to 

2.0x10-10

• Deleted ISLOCA sequence judged not credible and RV rupture as negligible

• Added conditional probability that reactor will trip due to loss of 4160 Volt 

Bus C or D

• Revised logic for loss of start-up feedwater due to circulating water flooding

• Revised success criteria for large and medium LOCAs to one of two core 

flood tanks

• Improved model documentation to comply with draft PRA standard 

requirements

1.3x10-5

Revision 4

9/2007

• Updated model for new PRA software 

• Increased available response time following loss of CCW for manual tripping 

of Reactor Coolant Pumps (RCPs) from 10 minutes to 1 hour

• Added tornado initiating events, excluding consideration of missile generation

• Performed module management changes

• Reduced truncation limit to 5.0x10-13

4.7x10-6

SAMA analysis • Reviewed and updated all system fault trees for system dependencies 9.8x10-6
Appendix F

F-8 

PRA Version Summary of Changes From Prior Model CDF (per year)

model

7/2009

• Added RV rupture initiating event

• Changed success criteria in case of a large LOCA back to two core flood 

tanks

• Made model improvements to CCW and service water models to correct 

errors 

• Adjusted system fault trees to and reflect simultaneous alignments using split 

fraction

• Revised common cause failure modeling to use of multiple greek letter 

approach

• Updated HRA using Electric Power Institute (EPRI) HRA calculator

• Structured support system initiating event modeling to comply with EPRI 

guidance (EPRI 2006)

• Removed modules from fault trees

• Added fire modeling functionality in preparation for performing a National Fire 

Protection Association (NFPA) 805 analysis

• Improved modeling with respect to success gates and mutually exclusive 

terms 

• Adapted a two-step quantification approach to facilitate incorporation of 

recovery events

1 In response to an NRC staff RAI (FENOC 2011), FENOC describes the quality control process 

2 used at Davis-Besse for the development and maintenance of the PRA. An operating manual 

3 related to the PRA Program and a business practice document related to PRA model 

4 management both identify requirements for maintaining and updating the PRA models and 

5 applications in accordance with regulatory guide (RG) 1.200, “An Approach for Determining the 

6 Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities”

7 (NRC 2007) and ensure that the PRA models are current with the changes to the plant. These 

8 control documents cover updates; identifying, tracking, and disposition of plant changes; 

9 personnel qualification; self-assessment; PRA software and computer control including software 

10 quality assurance; and PRA records and documentation. The NRC staff considers FENOC’s 

11 quality control process to be of sufficient quality to support the SAMA evaluation.

12 The NRC staff asked FENOC to identify any changes to the plant, including physical and 

13 procedural modifications, since the July 2009 SAMA analysis model that could have a 

14 significant impact on the results of the SAMA analysis (NRC 2011a). In response to the RAI, 

15 FENOC stated that while there have been some plant changes since the SAMA analysis model, 

16 no changes have been identified that would have a significant impact on the SAMA evaluation 

17 (FENOC 2011). Furthermore, FENOC states that plant procedures for managing the PRA 

18 model specify that plant changes are to be evaluated to determine if they would cause a change 

19 of greater than 10 percent CDF, or greater than 20 percent LERF; there have been no changes 

20 that meet these criteria.

21 Given that the Davis-Besse internal events PRA model has been peer-reviewed and the peer 

22 review findings were all addressed, and that FENOC has satisfactorily addressed NRC staff 

23 questions regarding the PRA, the NRC staff concludes that the internal events Level 1 PRA 

24 model is of sufficient quality to support the SAMA evaluation.
Appendix F

F-9 

1 As indicated above, the current Davis-Besse PRA does not include external events. In the 

2 absence of such an analysis, FENOC used the Davis-Besse IPEEE to identify the highest risk 

3 accident sequences and the potential means of reducing the risk posed by those sequences, as 

4 discussed below and in Section F.3.2.

5 FENOC submitted the Davis-Besse IPEEE in February 1996 (Centerior Energy 1996) in 

6 response to Supplement 4 of GL 88-20 (NRC 1991). This submittal included a seismic margins 

7 analysis, an internal fire PRA, and an evaluation of high winds, external flooding, and other 

8 hazards. While no fundamental weaknesses or vulnerabilities to severe accident risk in regard 

9 to the external events were identified, a limited set of plant improvements based on an external 

10 events finding was identified and is discussed below. In a letter dated February 8, 2001, the 

11 NRC staff concluded that the submittal met the intent of Supplement 4 to GL 88-20, and the 

12 applicant’s IPEEE process is capable of identifying the most likely severe accidents and severe 

13 accident vulnerabilities (NRC 2001).

14 The seismic portion of the IPEEE consisted of a reduced-scope seismic evaluation using the 

15 EPRI methodology (EPRI 1991) for seismic margins assessment (SMA), with enhancements 

16 specified in NUREG-1407 (NRC 1991), in conjunction with the Seismic Qualification User’s 

17 Group (SQUG) methodology (SQUG 1992). This method is qualitative and does not provide 

18 numerical estimates of the CDF contributions from seismic initiators (EPRI 1991). FENOC 

19 indicates in the ER that the SMA has not been updated since the IPEEE. Although the size of 

20 an earthquake is usually reported in terms of Richter magnitude, ground-shaking forces are 

21 most commonly reported in units of acceleration as a fraction of the force (acceleration) of 

22 gravity (g). For the IPEEE seismic assessment, Davis-Besse was categorized as a 0.3 g 

23 focused-scope plant per NUREG-1407; however, the applicant performed a 0.15 g reduced 

24 scope SMA based on a perceived lower seismic risk at Davis-Besse. The applicant judged 

25 seismic risk to be lower at Davis-Besse based on its review of revised Lawrence Livermore 

26 National Laboratory (LLNL) seismic hazard curves (NRC 1994a), its review of information notice 

27 (IN) 94-32, “Revised Seismic Hazard Estimates” (NRC 1994b), and its commitment to address 

28 the outliers identified by the walkdowns for the Unresolved Safety Issue (USI) A-46 Program. 

29 The SMA determined that the lowest high confidence in low probability of failure (HCLPF) value 

30 for the components evaluated was 0.26 g. In the letter dated February 8, 2001, the NRC staff 

31 concluded that the applicant came close to meeting the objectives of a focused scope analysis 

32 (NRC 2001).

33 The NRC staff asked about whether plant improvements had been made to the five structures 

34 and components, four masonry walls, and borated water storage tank (BWST) roof determined 

35 to have an HCLPF value of less than 0.3 g in the IPEEE (NRC 2011a). In response to the RAI, 

36 FENOC stated that plant improvements had been performed for the four components involving 

37 masonry walls and that no modifications have been made to the BWST roof. Updated analyses 

38 were performed to ensure allowable stresses and design-basis requirements for masonry 

39 structures were met (FENOC 2011). In a followup clarification to the RAI responses, FENOC 

40 further explained that a SAMA candidate already identified and evaluated in the ER meets the 

41 intent of improving the seismic capacity of the BWST roof. This is further discussed in 

42 Section F.3.2.

43 The Davis-Besse IPEEE seismic evaluation identified one unresolved outlier remaining from 

44 implementation of the USI A-46 Program. The one unresolved outlier was the identification of 

45 two flammable compressed gas bottles with inadequate seismic mounting. This is further 

46 discussed in Section F.3.2. The USI A-46 SER for Davis-Besse indicates that the license 

47 completed the resolution of all outliers (NRC 2000).
Appendix F

F-10

1 To provide additional insight into the appropriate seismic CDF to use for the SAMA evaluation, 

2 the NRC staff used NRC information notice (IN) 2010-18, generic issue 199, “Implications of 

3 Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on 

4 existing Plants,” which informs applicants that updated seismic data and models show 

5 increased seismic hazard estimates for some plants. The NRC report cited in the IN estimates 

of the seismic CDF for Davis-Besse to be between 6.7x10-7 and 6.7x10-6 6 per year using 

7 2008 U.S. Geological Survey (USGS) seismic hazard curves. Since FENOC did not provide a 

seismic CDF contribution in the ER, the NRC staff used a seismic CDF of 6.7x10-6 8 per year to 

9 assess the appropriateness of the external event multiplier used in the SAMA evaluation. The 

10 multiplier is discussed further later in this section.

11 The Davis-Besse IPEEE fire analysis employed a combination of the EPRI’s fire-induced 

12 vulnerability evaluation (FIVE) methodology (EPRI 1993) and PRA analysis. Since the FIVE 

13 methodology allowed only a few of the Davis-Besse fire compartments to be screened, 

14 modification of the FIVE process was employed to include more detailed analysis of affected 

15 circuits, improved fire initiation frequency quantification, inclusion of fire effects evaluations, and 

16 crediting fire prevention and suppression. These enhancements were primarily based on 

17 guidance from the EPRI Fire PRA Implementation Guide (EPRI 1995). In the first phase, initial 

18 qualitative and quantitative screening was used to identify potentially risk significant fire 

19 compartments. Safe shutdown equipment was identified, and the routing of the associated 

20 supporting electrical cables was determined and qualitatively evaluated to determine if there 

21 were any plant locations that could be screened out due to the absence of safe shutdown 

22 equipment or cables. Fire barriers were evaluated to ensure that any screened out 

23 compartments could not cause a fire in an adjacent compartment. The results of the fire 

24 compartment interaction analysis were used in the detailed fire analyses of each compartment.

25 The second phase considered equipment failures beyond those caused by the fire. Using the 

PRA, plant areas with a fire-induced CDF below 1.0x10-6 26 per year were screened from further 

27 evaluation. The third phase involved detailed fire analysis of the unscreened compartments 

28 using guidance from the Fire PRA Implementation Guide (EPRI 1995), detailed evaluation of the 

29 potential for fire damage due to specific fires within an area, and detailed evaluation of the 

30 function of specific safe shutdown equipment cables. In this phase, fire frequencies were 

31 adjusted to remove some of the conservatism in the frequencies for specific fire initiation 

32 sources. This included applying severity factors for certain fixed sources of ignition and 

33 crediting early suppression of welding-related fires based on historical fire events data, crediting 

34 early suppression of other transient fires based on the presence of an automatic fire detection 

35 system in the fire compartment, crediting restrictions on the quantity of transient combustibles 

36 and the use of approved storage containers for transient combustibles, crediting the frequency 

37 of inspections to verify compliance with the requirements for control of transient combustibles, 

38 and eliminating conduits and cable trays that were determined to not be credibly damaged by a 

39 fire based on its distance from the ignition source. Based on these results, the fire-induced 

40 equipment failure list was modified and more compartments were screened.

41 FENOC stated that the fire PRA has not been updated since the IPEEE. In Section 3.1.2.1 of 

42 the ER, FENOC provides the fire CDF for the four areas having a CDF greater than the 

screening criteria of 1.0x10-6 43 per year. In response to an NRC staff RAI, FENOC acknowledges 

44 that IPEEE Table 4.2.3.2 (Centerior Energy 1996) provides the CDF for 15 fire compartments 

45 that were screened out prior to detailed analysis. The NRC IPEEE SER presents the total CDF 

of these screened out fire compartments to be 3.8x10-6 46 per year. This CDF, and those for each 

of the four fire zones have a CDF greater than 1.0x10-6 47 per year, are presented in Table F-4. 

The total fire CDF, determined from summing the values in Table F-4, is 2.9x10-5 48 per year.
Appendix F

F-11

1 Table F-4. Davis-Besse Fire Zones and their Contribution to Fire Core Damage 

2 Frequency

Fire Zone Fire Zone Description CDF (per year)

Q.01 High voltage switchgear Room B 8.2x10-6

S.01 High voltage switchgear Room A 6.5x10-6

X.01 Low voltage switchgear room 5.9x10-6

FF.01 Control room cabinets 4.3x10-6

Other(a) 3.8x10-6

Total Fire CDF (all fire zones) 2.9x10-5

(a) From the IPEEE SER (NRC 2001).

3 The NRC staff inquired about additional measures that FENOC had already taken to reduce fire 

4 risk since the IPEEE for the four dominant fire areas identified in ER Section E.3.1.2.1 

5 (NRC 2011a). FENOC provided a description of a software tool implemented after issuance of 

6 the IPEEE for managing fire risk. This tool tracks inoperable or degraded fire protection 

7 features and manages combustible loads and travel paths. This software is maintained by the 

8 site fire marshal and controlled by a set of operational procedures. FENOC also provided a 

9 SAMA evaluation of these four dominate fire areas, which is discussed further in Section F.3.2.

10 Considering the above discussion, and the actions taken by FENOC to reduce fire risk since the 

IPEEE, NRC staff concludes that the fire CDF of 2.9x10-5 11 per year is reasonable for the SAMA 

12 analysis.

13 The Davis-Besse IPEEE analysis of HFO events (high winds, tornadoes, external floods, and 

14 other external events) followed the screening and evaluation approaches specified in 

15 Supplement 4 to GL 88-20 (NRC 1991) and did not identify any sequences or vulnerabilities that 

exceeded the 1.0x10-6 16 per year criterion (FENOC 2001). Based on this result, the applicant 

17 concluded that these other external hazards would be negligible contributors to overall core 

18 damage and did not consider any plant-specific SAMAs for these events. However, the 

19 applicant did note that the updated safety analysis report and the control room habitability study 

20 did not accurately reflect the current chemicals stored onsite. This is discussed further in 

21 Section F.3.2.

22 Based on the aforementioned results, including the NRC staff assessment of the Davis-Besse 

23 seismic CDF, the external events CDF is approximately 3.6 times the internal events CDF 

(based on a seismic CDF of 6.7x10-6 per year, a fire CDF of 2.9x10-5 24 per year, and an internal 

events CDF of 9.8x10-6 25 per year). The NRC staff requested FENOC increase the internal 

26 events benefits from a factor of 3 to 3.6 to account for the seismic hazard and for the CDF 

27 associated with screened fire compartments (NRC 2011a). In response to the RAI, FENOC 

28 chose to provide a revised SAMA evaluation using an external events multiplier of 4.6 resulting 

in a total multiplier of 5.6 ((2.9x10-5+6.7x10-6+1.0x10-5)/(1.0x10-5 29 )+1)) to account for external 

events, which assumes a seismic CDF of 6.7x10-6 per year, a fire CDF of 2.9x10-5 30 per year, and 

an HFO CDF of 1.0x10-5 31 per year (FENOC 2011). This is discussed further in Section F.6.2.

32 The NRC staff reviewed the general process used by FENOC to translate the results of the 

33 Level 1 PRA into containment releases, as well as the results of the Level 2 analysis, as 

34 described in the ER and in response to NRC staff RAIs (FENOC 2010, 2011. The Level 2 
Appendix F

F-12

1 model is completely revised from the model used in the IPE and reflects the Davis-Besse plant 

2 as designed and operated as of September 2009. In response to NRC RAIs, FENOC explains 

3 that one of the most significant changes in the Level 2 model was the increase in level detail 

4 reflected in the PDSs and the manner in which their frequency is calculated. To better define 

5 the status of containment systems to support CET quantification, 14 PDSs were added. 

6 Another important change was developing a probability distribution for containment failure as a 

7 function of internal pressure. The Level 1 core damage sequences grouped into core damage 

8 bins according to similarities in their impact on containment response. The core damage bins, 

9 together with the states of containment systems, comprise the nearly 500 PDSs that provide the 

10 interface between the Level 1 analysis and Level 2 CET analysis.

11 Each PDS is analyzed through the Level 2 CET to evaluate the phenomenological progression 

12 of the sequence. The current Level 2 model uses a single CET containing both 

13 phenomenological and systemic events. In response to an NRC staff RAI, FENOC clarified that 

14 the Davis-Besse CET was developed from a B&W owner’s group generic CET and refined to 

15 address phenomena that could impact reactor cooling system integrity, containment response, 

16 and release from containment. The CET end states are assigned to one of nine general and 

17 34 specific release categories based on characteristics that determine the timing and magnitude 

18 of the release, whether or not the containment remains intact, and isotopic composition of the 

19 release material (FENOC 2010). The frequency of each release category was obtained by 

20 summing the frequency of the individual accident progression CET endpoints binned into the 

21 release category.

22 Source term release fractions were developed for each of the 34 release categories based on 

23 the results of plant-specific calculations using the MAAP Version 4.0.6. A separate MAAP 

24 calculation was performed for each of the 34 release categories. The 2012 SAMA supplement 

25 provided updated MAAP results to correct an error in the ER MAAP results (FENOC 2012a). 

26 The release categories and their release characteristics and frequencies are presented in 

27 Table E.3-13 of the 2012 SAMA supplement (FENOC 2012a) and Table E.3-20 of Appendix E 

28 to the ER (FENOC 2010) as corrected in the 2012 SAMA supplement (FENOC 2012a). The 

29 updated baseline dose risk and offsite economic risk from the 2012 SAMA supplement were 

30 used in the SAMA evaluation (FENOC 2012a).

The total Level 2 release frequency, based on the sum of CET sequences, is 1.0x10-5 31 per year, 

which is 2 percent higher than the Level 1 internal events CDF of 9.8x10-6 32 per year. This is due 

33 to the additional systems included in the Level 2 PRA models and to the presence of minimal 

34 cutsets that do not represent viable event sequences. The NRC staff considers that use of the 

35 release frequency, rather than the Level 1 CDF, will have a negligible impact as it is very small 

36 in comparison to the external events multiplier. The NRC staff asked FENOC to identify the 

37 release categories that comprise the LERF and to confirm that these contribute to the LERF 

38 importance analysis listing presented in Table E.3-4 (NRC 2011a). In response to the RAI, 

39 FENOC identified the release categories comprising LERF and provided a new LERF 

40 importance listing based on a re-review and identification of a few minor discrepancies. ER 

41 Table E.5-3 was revised to correct the identified discrepancies. This is discussed further in

42 Section F.3.2.

43 The NRC staff’s review of the Level 2 IPE concluded that it addressed the most important 

44 severe accident phenomena normally associated with large, dry containments, and it identified 

45 no significant problems or errors (NRC 1996). The revisions to the Level 2 model since the IPE, 

46 to update the methodology and to address peer review recommendations, are described in 

47 Section E.3.2.2 of the ER and in response to NRC staff RAIs (FENOC 2011). The Level 2 PRA 
Appendix F

F-13

1 model was included in the B&W owner’s group peer review mentioned previously. All peer 

2 review findings have been addressed and are considered closed. The NRC staff asked FENOC 

3 about the implementation status of suggested plant improvements made in the IPE “back-end” 

4 analysis and asked FENOC to identify and evaluate SAMA candidates for those that have not 

5 been implemented (NRC 2011a). In response to the RAI, FENOC states that each of the 

6 suggested improvements has been implemented (FENOC 2011). This is discussed further in 

7 Section F.3.2.

8 Based on the following information, the NRC staff concludes that the Level 2 PRA provides an 

9 acceptable basis for evaluating the benefits associated with various SAMAs:

10 • the NRC staff’s review of the Level 2 methodology, 

11 • the fact that FENOC adequately addressed NRC staff RAIs, 

12 • the fact that the Level 2 PRA model was reviewed as part the 1999 owner’s group peer 

13 review of the LERF analysis, and

14 • the 2008 gap self-assessment. 

15 In response to NRC staff RAIs, FENOC explains that the reactor core radionuclide inventory 

16 used in the consequence analysis corresponds to the end-of-cycle values for Davis-Besse 

17 operating at 2,827 MWt, which incorporates a 2 percent uncertainty in core power. In 

18 Section 3.1.2 of the ER, it is stated that the operating license and technical specifications were 

19 amended in 2008 to allow an increase in rated thermal power from 2,772 MWt to 2,817 MWt.

20 The reactor core radionuclide inventory assumes a 2 percent uncertainty margin; therefore, it 

21 bounds the uprated power level. The core radionuclide inventory is provided in Table E.3-17 of 

22 Appendix E of the ER (FENOC 2010). The ER noted that the description of plant facilities and 

23 operations and associated impact evaluations in this ER, therefore, assume operation at 

24 2,827 MWt.

25 The NRC staff reviewed the process used by FENOC to extend the containment performance 

26 (Level 2) portion of the PRA to an assessment of offsite consequences (Level 3). This included 

27 consideration of the source terms used to characterize fission product releases for the 

28 applicable containment release categories and the major input assumptions used in the offsite 

29 consequence analyses. Version 1.12 of the MACCS2 code was used to estimate offsite 

30 consequences. Plant-specific input to the code includes the source terms for each release 

31 category and the reactor core radionuclide inventory (both discussed above), site-specific 

32 meteorological data, projected population distribution within a 50-mi (80-km) radius for the 

33 year 2040, emergency evacuation planning, and economic parameters including agricultural 

34 production. This information is provided in Section 3.0 of Attachment E to the ER 

35 (FENOC 2010), as corrected in the 2012 SAMA supplement for four errors in the MACCS2 input 

36 data (FENOC 2012a).

37 Releases were modeled as occurring at four different elevations, specific to each of the MAAP 

38 cases. These heights were ground level, 2.13 meters (m), 18.44 m, or 45.42 m. Building wake 

39 effects were modeled assuming a building width of 44 m and height of 73 m. The release 

40 energy varied from 265 watts (ambient) to 97 megawatts (MW). These are documented in 

41 Table E.3-13 of the ER by release category (FENOC 2010). In response to an NRC staff RAI, 

42 FENOC identified the heat release for each release category for sensitivity case A1 

43 (FENOC 2012a). A sensitivity study, Case A1, was performed on the methodology used to 

44 calculate the release energy, which resulted in a higher release energy for each release 
Appendix F

F-14

1 category. In the sensitivity study, the energy of release was obtained from MAAP by multiplying 

2 the mass flow rate times the enthalpy of the release gas. The results showed a decrease in 

3 population dose risk of 3.3 percent and in offsite economic cost risk of 5.3 percent 

4 (FENOC 2012a). This result is expected since a higher energy release will both increase the 

5 radioactive decay period of the plume and increase the extent of dispersion of the plume. Since 

6 a higher energy release results in decreased population dose and offsite economic cost risk, the 

7 NRC staff concludes that the release parameters used are acceptable for the purposes of the 

8 SAMA evaluation.

9 FENOC used site-specific meteorological data for the year 2006 as input to the MACCS2 code. 

10 Meteorological data included wind speed, wind direction, delta-temperature, and precipitation for 

11 each hour of the year. Wind speed and direction are collected from various levels at a 100-m 

12 primary tower and a nearby 10-m backup tower. The 100-m tower also measures differential 

13 temperatures at several levels to determine atmospheric stability. The development of the 

14 meteorological data is discussed in Sections 2.10 and E.3.4 of the ER (FENOC 2010). Data 

15 from 2006 through 2008 was considered, but the 2006 data was chosen because it was the 

16 most complete data set. Data from year 2008 was considered unusable as it contained too 

17 many missing long data sequences of unusable data. A sensitivity study, Case M1, was 

18 performed using year 2007 data. The results showed a decrease in population dose risk of 

19 0.5 percent and an increase in offsite economic cost risk of 1.1 percent (FENOC 2012a). The 

20 NRC staff notes that these results are consistent with previous SAMA analyses that have shown 

21 little sensitivity to year-to-year differences in meteorological data.

22 Missing data were estimated using data substitution methods (FENOC 2011). The 100-m tower 

23 measures differential temperatures at several levels to determine atmospheric stability. Mixing 

24 heights, which are presented in Table E.3-12 of the ER, were specified for a.m. and p.m. hours 

25 and are based on Environmental Protection Agency (EPA) data (EPA 1972). A sensitivity study, 

26 Case A2, was performed assuming more extreme values of the meteorological boundary 

27 parameters (e.g., stability class, rainfall, wind speed). This resulted in no change in the 

28 population dose risk or offsite economic cost risk (FENOC 2012a). The NRC staff concludes 

29 that the use of the 2006 meteorological data in the SAMA analysis is reasonable.

30 The population distribution the applicant used as input to the MACCS2 analysis was estimated 

31 for the year 2040 using year 2000 census data as accessed by SECPOP2000 (NRC 2003). In 

32 response to an NRC staff RAI, FENOC identified that known code errors in SECPOP2000 did 

33 not apply as only the SECPOP2000 population data were used (FENOC 2011). All other site 

34 file parameters were developed independently. The year 2040 is 3 years beyond the renewed 

35 license year 2037. The baseline population was determined for each of 160 sectors, consisting 

36 of the 16 directions for each of 10 concentric distance rings with outer radii at 1, 2, 3, 4, 5, 10, 

37 20, 30, 40 and 50 mi surrounding the site. County population growth estimates were applied to

38 year 2000 census data to develop year 2040 population distribution.

39 In response to an NRC staff RAI, FENOC revised the Level 3 PRA to include the Canadian 

40 population (FENOC 2011). SECPOP2000 contains only United States population data, and the 

41 Canadian population was not included in the Level 3 assessment. The year 2000 population 

42 from SECPOP2000 and Table 2.6-1 of the ER, which contains the population for Ontario, 

43 Canada from the 2001 Canadian census, were used to revise the total population within the 

44 50-mi radius of Davis-Besse. The revised population was escalated to year 2040, resulting in a 

45 total population of 2,903,790.
Appendix F

F-15

1 In a clarification to a response to an NRC staff RAI, FENOC confirmed that transient population 

2 was included in the revised population (between 0 and 30 mi) (NRC 2011b). The transient 

3 population segment includes seasonal residents, transient population, and boating population. 

4 The seasonal population group comprises those people who reside in the area during warmer 

5 months, principally May through October. The transient population group comprises those 

6 people who enter the area for a specific purpose (e.g., recreation) and who leave on the same 

7 day or stay overnight at motels and hotels. The distribution of the population is given for the 

8 10-mi radius from the Davis-Besse plant site and for the 50-mi radius from the Davis-Besse site 

9 in the revised Table E.3-11 of the RAI responses (FENOC 2011). The SAMA analysis was 

10 revised to use the revised population estimate, and relevant revised sections of the ER were 

11 provided in the RAI response. The revisions included the addition of the Canadian population, 

12 revised cost-benefit results, and revised base case and sensitivity case comparisons discussed 

13 in this section and in Section F.6. The population dose reported in Table F-2 also incorporates 

14 the results of the revised population estimate. A sensitivity case, Case S1, was performed 

15 using a population escalation to year 2060 and a second sensitivity case, Case S2, for a less 

16 conservative population escalation to year 2040 (1.5 percent per decade). A base population 

17 escalation of 4.7 percent per decade was used in the SAMA analysis, which is the rate of 

18 increase in the population of Ohio between 1990 and 2000 based on census records. The 

19 escalation to year 2060 showed an increase in population dose risk of 9.4 percent and in offsite 

20 economic cost risk of 9.2 percent (FENOC 2012a). The 1.5 percent escalation showed a 

21 decrease in population dose risk of 11.3 percent and in offsite economic cost risk of 

22 10.9 percent (FENOC 2012a). The NRC staff considers the methods and assumptions for 

23 estimating population reasonable and acceptable for purposes of the SAMA evaluation.

24 FENOC performed sensitivity analyses to determine the impact on population dose risk and 

25 offsite economic cost risk for changes to release energy, meteorology, warning delay time, 

26 evacuation speed, sheltering, population and water shed assumptions as shown in Table F-5. 

27 Table F-5. Impact on Population Dose Risk and Offsite Economic Cost Risk for Selected 

28 Sensitivity Cases 

Sensitivity Case

Population Dose Risk 

(person-rem/year)

Offsite economic Cost Risk 

(dollars/year x 1000) 

Baseline 

Result

Sensitivity 

Result

% 

Difference

Baseline 

Result

Sensitivity 

Result

% 

Difference

Case A1—Simpler release energy 

methodology

2.12 2.05 -3.3 3.59 2.40 -5.3

Case A2—More extreme values 

of meteorological boundary 

parameters

2.12 2.12 0 3.59 3.59 0

Case A3—Increase warning delay 

time to 20 minutes

2.12 2.12 0 3.59 3.59 0

Case E1—Increase evacuation 

speed to 1.0 mps

2.12 2.11 -0.5 3.59 3.59 0

Case E2—Change sheltering 

shielding to brick housing

2.12 1.62 -23.6 3.59 2.16 -39.8
Appendix F

F-16

Sensitivity Case

Population Dose Risk 

(person-rem/year)

Offsite economic Cost Risk 

(dollars/year x 1000) 

Baseline 

Result

Sensitivity 

Result

% 

Difference

Baseline 

Result

Sensitivity 

Result

% 

Difference

Case E3—4.7% per decade 

escalation in population and 

proportional decrease in 

evacuation speed

2.12 2.12 0 3.59 3.59 0

Case M1—Use year 2007 

meteorological data

2.12 2.11 -0.5 3.59 3.63 +1.1

Case S1—Population escalation 

to year 2060

2.12 2.32 +9.4 3.59 3.92 +9.2

Case S2—Population escalation 

of 1.5% per decade

2.12 1.88 -11.3 3.59 3.20 -10.9

Case S3—Watershed index of 1.0 

for all sectors

2.12 2.18 +2.8 3.59 3.59 0

1 The emergency evacuation model was modeled as a single evacuation zone extending out 

2 10 mi (16 km) from the plant. FENOC assumed that 95 percent of the population would 

3 evacuate. This assumption is conservative relative to the NUREG-1150 study (NRC 1990), 

4 which assumed evacuation of 99.5 percent of the population within the emergency planning 

5 zone (EPZ). The evacuated population was assumed to move at an average speed of 

6 approximately 0.58 meters per second (mps) (1.3 miles per hour (mph)) with a delayed start 

7 time of 4 hours and 55 minutes after declaration of a general emergency. The evacuation 

8 speed was derived from the projected time to evacuate the entire EPZ under the most 

9 conservative (long-time) conditions for “Summer, Midday, Weekend” (FENOC 2010). In 

10 response to an NRC staff RAI, FENOC identified that the evacuation analysis did not clearly 

11 identify a reference year for the EPZ population, and it was assumed to be year 2000 

12 (FENOC 2011). No correction of the EPZ evacuation speed was made for the year 2040 

13 population. In further response to the RAI, FENOC performed a sensitivity study, Case E3, 

14 using a 4.7 percent per decade escalation of the year 2000 EPZ population to year 2040 and 

15 assumed the evacuation speed decreased proportional to the population increase, or to 

16 0.52 mps (1.2 mph). This resulted in no change in population dose risk and no change in offsite 

17 economic cost risk (FENOC 2011). A sensitivity study, Case E1, was performed in which the 

18 evacuation speed was increased to 1.0 mps (2.2 mph). This resulted in a 0.9 percent decrease 

19 in the total offsite population dose risk and no change in the offsite economic cost risk 

20 (FENOC 2011). An additional sensitivity study, Case A3, was performed for the warning delay 

21 time. The base case assumed about 300 seconds (5 minutes). The sensitivity case increased 

22 the warning time to 20 minutes. This resulted in no change in population dose risk and no 

23 change in offsite economic cost risk (FENOC 2012a). One additional sensitivity case was 

24 performed for shielding factors. The base case assumed wood housing, and the sensitivity 

25 case, Case E2, assumed brick. The sensitivity results showed a decrease in population dose 

26 risk of 23.6 percent and in offsite economic cost risk of 39.8 percent (FENOC 2012a). The NRC 

27 staff concludes that the evacuation assumptions and analysis are reasonable and acceptable 

28 for the purposes of the SAMA evaluation.
Appendix F

F-17

1 Site-specific agriculture and economic data were provided from 2007 National Census of 

2 Agriculture (USDA 2009a, 2009b) data for each of the 10 counties surrounding Davis-Besse to 

3 a distance of 50 mi (80 km). This included the fraction of land devoted to farming, annual farm 

4 sales, the fraction of farm sales resulting from dairy production, and the value of both farmland 

5 and non-farmland. Non-farm wealth was derived from 2005 and 2006 property tax valuations 

6 (MDT 2007; ODT 2008). A sensitivity case, Case S3, was performed using a water shed index 

7 of 1.0 (maximum runoff consequences) for all sectors. The results showed an increase in 

8 population dose risk of 2.8 percent and no change to offsite economic cost risk (FENOC 2011). 

9 Area-wide farm wealth was determined from 2005 and 2006 property tax valuations (MDT 2007; 

10 ODT 2008) and county statistics for farmland, buildings, and machinery, with only the fraction of 

11 each county within 50 mi of Davis-Besse considered. The daily cost of compensation for 

12 evacuees and short-term relocatees used the year 2000 census economic data for each state 

13 (USCB 2000; USGSA 2000). In addition, parameters describing the cost of population and 

14 business relocation, farm and non-farmland decontamination, and decontamination labor used 

15 MACCS2 default values (NRC 1998a). An escalation factor of 1.95 based on the consumer 

16 price index was applied to these parameters to account for cost escalation from 1986 (the year 

17 the input was first specified) to 2009 (FENOC 2012b). 

18 The NRC staff concludes that the methodology used by FENOC to estimate the offsite 

19 consequences for Davis-Besse provides an acceptable basis from which to proceed with an 

20 assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based 

21 its assessment of offsite risk on the CDF and offsite doses reported by FENOC.

22 F.3 Potential Plant Improvements

23 The process for identifying potential plant improvements, an evaluation of that process, and the 

24 improvements evaluated in detail by FENOC are discussed in this section.

25 F.3.1 Process for Identifying Potential Plant Improvements

26 FENOC’s process for identifying potential plant improvements (SAMAs) consisted of the 

27 following elements:

28 • review of the dominant cutsets and most significant basic events from the current, 

29 plant-specific PRA, 

30 • review of potential plant improvements identified in the Davis-Besse IPE and IPEEE, 

31 • review of SAMA candidates identified for LRAs for selected pressurized-water reactor 

32 (PWR) plants, and

33 • review of other industry documentation discussing potential plant improvements. 

34 Based on this process, an initial set of 167 candidate SAMAs, referred to as Phase I SAMAs, 

35 was identified. In Phase I of the evaluation, FENOC performed a qualitative screening of the 

36 initial list of SAMAs and eliminated SAMAs from further consideration using the following 

37 criteria: 

38 • The SAMA has design difference or has already been implemented at Davis-Besse.

39 • The SAMA is not applicable to Davis-Besse.
Appendix F

F-18

1 • The SAMA has estimated implementation costs that would exceed the dollar value 

2 associated with eliminating all severe accident risk at Davis-Besse.

3 • The SAMA is related to a non-risk significant system and, therefore, has a very low 

4 benefit.

5 • The SAMA Is similar in nature and could be combined with another SAMA candidate.

6 Based on this screening, 152 SAMAs were eliminated, leaving 15 for further evaluation. The 

7 remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.7-1 of the ER 

8 (FENOC 2010). In Phase II, a detailed evaluation was performed for each of the 15 remaining 

9 SAMA candidates, as discussed in Sections F.4 and F.6 below. To account for the potential 

10 impact of external events, the estimated benefits based on internal events were multiplied by a 

11 factor of 5.6, as previously discussed. 

12 In response to NRC staff RAIs, FENOC re-evaluated all SAMAs screened in Phase I as “Very 

13 Low Benefit” using a recalculated maximum benefit based on an increased multiplier of 5.6 to 

14 account for the impact of external events. Based on this reevaluation, no additional SAMAs 

15 screened in Phase I were retained for the detailed Phase II evaluation.

16 F.3.2 Review of FENOC’s Process

17 FENOC’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

18 initiating events but also included explicit consideration of potential SAMAs for fire and seismic 

19 events. The initial list of SAMAs generally addressed the accident sequences considered to be 

20 important to CDF from functional, initiating event, and risk reduction worth (RRW) perspectives 

21 at Davis-Besse.

22 FENOC’s SAMA identification process began with a review of the list of potential PWR 

23 enhancements in Table 14 of Nuclear Energy Institute (NEI) 05-01 (NEI 2005). Review of this 

24 generic SAMA list resulted in all of the SAMAs from this table being identified as Phase I 

25 SAMAs, for a total of 154 Phase I SAMAs.

26 FENOC provided a tabular listing of the Level 1 PRA basic events sorted according to their 

27 RRW and the top 100 cutsets (FENOC 2010). SAMAs impacting these cutsets and basic 

28 events would have the greatest potential for reducing risk. For the basic events listing, FENOC 

29 used an RRW cutoff of 1.005, which corresponds to about a 0.5 percent change in CDF given 

30 100-percent reliability of the SAMA. The NRC staff requested FENOC to identify the SAMA 

31 candidates that address each of the basic events having an RRW equating to a benefit greater 

32 than the minimum cost of a procedure change (NRC 2011a). In response to the RAI, FENOC 

33 provided a review of all Level 1 basic events having an RRW greater than or equal to 1.03, 

34 which corresponds to about a 3 percent change in CDF given 100-percent reliability of the 

35 SAMA (FENOC 2011). This equates to a benefit of approximately $10,000 for internal events, 

36 which is the estimated minimum cost of a procedure change. Based on the review of 

37 evaluations from other plants, the $10,000 estimated minimum cost for a procedure change is 

38 conservative. 

39 Of the over 40 basic events reviewed, SAMA candidates were identified for all but 12 of the 

40 basic events. These remaining basic events were found to be: (1) events that had no physical 

41 meaning (such as a flag event or a plant configuration probability event); (2) events for which no 

42 feasible SAMA was identified; (3) events that could only be addressed by a hardware 

43 modification and had a maximum benefit less than the minimum cost of $100,000 for a 
Appendix F

F-19

1 hardware change; or, (4) events that are being addressed by the installation of new steam 

2 generators in 2013.

3 In addition, as a result of the reevaluation of the Level 1 basic importance list in the RAI 

4 response, FENOC identified new SAMA candidate OT-09R, “present the highest worth PRA 

5 human actions to the Davis-Besse operator training.” This SAMA candidate was, however, 

6 subsequently found by FENOC to already be implemented at Davis-Besse. Davis-Besse 

7 provides PRA information such as risk significant initiating events, high worth operator actions 

8 and high worth equipment. This information is provided to various departments and is 

9 presented on posters throughout the plant. In response to other NRC staff RAIs, FENOC 

10 explained that the following eight SAMA candidates were identified from plant-specific risk 

11 insights during the review of the cutsets and Level 1 basic events importance list: CB-20, install 

12 relief valves in the CCW system; CB-21, install pressure measurements between the two DHR 

13 suction valves in the line from the RCS hot leg; CC-19, provide automatic switchover of HPI and 

14 LPI suction from the BWST to containment sump for LOCAs; CC-21, reduce the BWST level at 

15 which switchover to containment recirculation is initiated; CP-19, install a redundant

16 containment fan system; CW-24, replace the standby CCW pump with a pump diverse from the 

17 other two CCW pumps; CW-25, provide the ability to cool makeup pumps using fire water in the

18 event of loss of CCW; and FW-16, perform surveillances on manual valves used for backup 

19 AFW pump suction. (FENOC 2011).

20 The NRC staff asked FENOC to specifically address the potential for SAMAs for the following 

21 basic events in the importance listing: WHAF3ISE, failure to isolate flood in room 328 before 

22 CCW pumps are affected; SHAF2ISE, failure to isolate flood before service water pumps are 

23 affected; F3AM, maximum flood in CCW pump room from service water (initiating event) and 

24 F7L, large circulating water flood in turbine building (initiating event) (NRC 2011a). In response 

25 to the RAI, FENOC explained that no SAMAs were identified for the first three events because 

26 they did not have an RRW benefit value equal to or greater than the cost of a procedural 

27 change (FENOC 2011). However, Phase I SAMA candidate FL-01, “improve inspection of 

28 rubber expansion joints on the main condenser,” was identified to address basic event F7L. 

29 FENOC determined, after further evaluation of this SAMA, that it was already implemented at 

30 Davis-Besse and, as a result, the screening disposition for FL-01 was reclassified in the Phase I 

31 screening from having a very low benefit to already implemented.

32 The NRC staff asked FENOC to evaluate a SAMA for basic events QMBAFP11 and 

33 QMBAFP12, which involve maintenance outages of the auxiliary feedwater (AFW) trains, which 

34 would make improvements to AFW maintenance practices or hardware (NRC 2011a). In 

35 response to the RAI, FENOC explained that AFW maintenance unavailability data used in the 

36 PRA is based on Maintenance Rule data and is consistent with the generic industry 

37 unavailability data reported in NUREG/CR-6928 (FENOC 2011). FENOC further explained that 

38 improvements to maintenance practices at Davis-Besse are proposed and evaluated as an 

39 element of normal business practices to maintain the AFW train unavailability at its lowest 

40 achievable value. Based on the unavailability of the AFW being consistent with the industry 

41 unavailability data, and because of the high cost of making improvements to safety-related 

42 hardware, FENOC concluded that a SAMA to improve the availability of the AFW pumps is not 

43 expected to be cost-beneficial. Based on this information, the NRC staff agrees that a SAMA to 

44 improve the availability of the AFW pumps is unlikely to be cost-beneficial.

45 The NRC staff noted that there are a significant number of operator errors and non-recovery 

46 actions that appear in the CDF and LERF importance listings and top 100 cutsets listing, yet no 

47 weakness in training or procedures was identified. In light of this, the NRC staff asked FENOC 
Appendix F

F-20

1 to explain the process used to make the determination that no opportunities exist to improve 

2 training or procedures and to discuss whether opportunities exist for reducing risk by providing 

3 automatic functions to risk significant operator actions (NRC 2011a). In response to the RAI, 

4 FENOC explains that, based on its analysis of human failure events using the EPRI HRA 

5 calculator, no specific vulnerabilities in procedures, training, staff, assumptions, performance 

6 shaping factors, or timing were found (FENOC 2011). FENOC further explains, however, that 

7 two additional SAMA candidates were evaluated to address risk-significant operations—

8 AC/DC-28R, “automatically start and load the SBO DG on Bus D2 upon loss of power to the 

9 bus,” and OT-08R, “automatically start and load the SBO DG on Bus D2 upon loss of power to 

10 the bus in combination with automatically starting the motor-driven feedwater pump (MDFP).” 

11 These are discussed further in Section F.6.2. In a clarification to the RAI response, FENOC 

12 concludes that the opportunities to automate operator actions has been fully considered 

13 because, in addition to these two additional SAMA candidates, three new SAMA candidates 

14 related to automating operator actions were evaluated in response to other NRC staff RAIs 

15 (SAMAs CC-22R, CW-26R, and FW-17R defined in Table F-6 and discussed in Section F.6.2). 

16 Five SAMA candidates were identified and evaluated in the ER to evaluate automating operator 

17 actions (SAMAs AC/DC-14, AC/DC-25, AC/DC-26, AC/DC-17, and CC-19), and other additional 

18 Phase I SAMA candidates to automate operator actions were identified but screened from the 

19 Phase II evaluation. Additionally, all basic events having an RRW equal to or greater than the 

20 cost of a procedure change were reviewed for SAMA candidates (NRC 2011b). The NRC staff 

21 concludes that the opportunity for SAMA candidates to automate operator actions has been 

22 adequately explored, and it is unlikely that there are additional cost-beneficial SAMA candidates 

23 to automate operator actions.

24 FENOC also provided and reviewed the LERF-based RRW events down to a RRW of 1.005 

25 (FENOC 2010). In response to an NRC staff RAI, FENOC provided a review of all Level 2 basic 

26 events having an RRW greater than or equal to 1.03 as was done for the Level 1 basic events

27 (FENOC 2011). FENOC explained that the RRW for the Level 2 basic events was calculated 

28 based on LERF rather than CDF and that the estimated benefit for each basic event was 

29 derived by taking the RRW for LERF and applying the maximum benefit used for the CDF 

30 event, which is conservative. Of the over 20 basic events reviewed, SAMA candidates were 

31 identified for about half of the basic events. The remaining basic events were found to be: 

32 (1) events that had no physical meaning (such as a flag event or a plant configuration probability 

33 event); (2) events for which no feasible SAMA was identified; (3) events that could only be 

34 addressed by a hardware modification and had a maximum benefit less than the minimum cost 

35 of $100,000 for a hardware change; or, (4) that are being addressed by the installation of new 

36 steam generators in 2013. No new SAMA candidates were identified from this review.

37 FENOC reviewed the SAMA candidates from prior SAMA analyses for nine PWR sites. 

38 FENOC’s review did not identify any additional SAMA candidates applicable to Davis-Besse that 

39 were not already identified from the importance analysis review described above.

40 For some of the SAMAs listed in the ER, the information provided did not sufficiently describe 

41 the proposed modification. Therefore, the NRC staff asked the applicant to provide more 

42 detailed descriptions of the modifications for several of the SAMA candidates (NRC 2011a). In 

43 response to the RAI, FENOC provided the requested information on the modifications for 

44 SAMAs: AC/DC-01, provide additional DC battery capacity; CC-19, install a redundant

45 containment fan system; AC/DC-25, provide a dedicated DC power system (battery/battery 

46 charger) for TDAFW control; and CW-24, replace the standby CCW pump with a pump diverse 

47 from the other two CCW pumps (FENOC 2011).
Appendix F

F-21

1 FENOC considered both the potential plant improvements and risk insights described in the IPE 

2 and IPEEE in the identification of plant-specific candidate SAMAs for internal and external 

3 events. Although the IPE did not identify any vulnerabilities, seven “front-end” (Level I PRA) 

4 and four “back-end” (Level II PRA) plant improvements were identified in Part 6, Sections 3.1 

5 and 3.2, respectively, of the IPE report. FENOC identified five additional SAMA candidates to 

6 address the five “front-end” plant improvements from the IPE—AC/DC-25, AC/DC-26, 

7 AC/DC-27, HV-06 (Provide procedural guidance for establishing an alternate means of room 

8 ventilation to the service water pump room), and CC-20 (Modify hardware and procedures to

9 allow using the makeup pumps for high pressure recirculation from the containment sump). 

10 The NRC staff requested information regarding the status of the four suggested “back-end” 

11 improvements from the IPE (NRC 2011a). In response to the RAI, FENOC clarified that the four 

12 suggested improvements (i.e., reduce the BWST level during switchover to sump recirculation, 

13 improve operator actions for inadequate core cooling, re-examine the emergency plan 

14 evacuation criteria, and monitor carbon monoxide levels in containment) have been 

15 implemented.

16 The NRC staff requested information regarding lower cost alternatives to some of the SAMAs 

17 evaluated (NRC 2011a), including those listed below:

18 (a) automate RCP trip on high motor bearing cooling temperature, 

19 (b) use the decay heat removal (DHR) system as an alternate suction source for 

20 high-pressure injection (HPI)

21 (c) automate HPI injection on low pressurizer level (in loss of secondary side heat removal 

22 cases where the reactor coolant system (RCS) pressure remains high while the RCS 

23 level drops), 

24 (d) automate refill of the BWST, 

25 (e) automate start of AFW pump in the event the automated emergency feedwater (EFW) 

26 system is unavailable, and

27 (f) purchase or manufacture of a “gagging device” that could be used to close a stuck-open 

28 steam generator safety valve for an SGTR event prior to core damage. 

29 In response to the RAIs, FENOC addressed the suggested lower cost alternatives and 

30 determined that they were either already implemented at Davis-Besse (b), not feasible (c), or 

31 not cost-beneficial (a, d, e, and f)(FENOC 2011). This is discussed further in Section F.6.2.

32 Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 

33 together with those identified in response to NRC staff RAIs, addresses the major contributors 

34 to internal event CDF.

35 The Davis-Besse IPEEE seismic evaluation identified one unresolved outlier remaining from 

36 implementation of the USI A-46 Program. The one unresolved outlier was the identification of 

37 two flammable compressed gas bottles in the auxiliary building with inadequate seismic 

38 mounting. An action to address the seismic-fire interaction issues associated with these 

39 flammable compressed gas bottles was identified and implemented by the applicant 

40 (NRC 2001). The USI A-46 SER for Davis-Besse indicates that the license had completed the 

41 resolution of all outliers (NRC 2000).
Appendix F

F-22

1 As discussed in Section F.2.2, the NRC staff requested information regarding any plant 

2 improvements for identified structures and components with an HCLPF value of less than 0.3 g 

3 (i.e., BWST roof, Masonry Wall No. 2367, Masonry Wall No. 3407, Masonry Wall No. 4786, and 

4 Masonry Wall No. 6107). The NRC staff asked the applicant to identify and evaluate SAMAs to 

5 improve the seismic capacity of these components and structures (NRC 2011a). In response to 

6 the RAI, FENOC explains that seismic improvements have been made to two of the masonry 

7 walls and that the Davis-Besse masonry wall analysis has been updated to ensure that the 

8 other two masonry walls met allowable stresses and design basis requirements (FENOC 2011). 

9 In a clarification to the RAI response, FENOC further explains that SAMA CC-10, which 

10 considers providing an in-containment reactor water storage tank, meets the intent of improving 

11 the seismic capacity of the BWST by providing a tank independent of the BWST (NRC 2011b).

12 The IPEEE did not identify opportunities for improvements related to fire events (FENOC 1996). 

13 FENOC also did not identify any other plant vulnerabilities in the IPEEE that would impact the 

14 PRA CDF (FENOC 2010).

15 The NRC staff asked FENOC to review each of the four dominant fire areas discussed in 

16 Section F.2.2 to identify potential SAMA candidates to reduce fire risk and to provide an 

17 assessment of identified SAMA candidates (NRC 2011a). FENOC responded that the main 

18 contributors to fire risk in all four areas are the MDFP, AFW system, and pilot-operated relief 

19 valve (PORV) (FENOC 2011). Loss of all feedwater or the inability to perform feed and bleed 

20 cooling are the primary contributors to CDF. FENOC’s search for SAMA candidates, therefore, 

21 focused on these two fire-induced failure scenarios and determined that existing Phase I 

22 SAMAs (CC-16, FW-02, FW-08, FW-09, FW-10, and FW-11) already adequately address these 

23 contributors to CDF.

24 The NRC staff identified three SAMA candidates (CB-02, CP-21, and OT-07) that were 

25 screened on very low benefit based on low contribution to LERF. In light of the fact that the 

26 release categories comprising LERF were not identified in the ER, the NRC staff asked FENOC 

27 to justify screening out these SAMA candidates (NRC 2011a). In response to the RAI, FENOC 

28 explains two of these SAMAs (CB-02 and CP-21) do not contribute to LERF and, therefore, are 

29 appropriately screened (FENOC 2011). FENOC also clarified that the screening basis in the ER 

30 for SAMA OT-07 was incorrect and that this SAMA was screened on the basis of its contribution 

31 to both CDF and LERF.

32 The NRC staff noted that several Phase I SAMAs were screened by being subsumed into other 

33 SAMAs and asked FENOC to either confirm that cost to implement these SAMAs is lower than 

34 those into which the SAMA was subsumed or provide a revised basis for the Phase I screening 

35 (NRC 2011a). In response to the RAI, FENOC explained that four such SAMAs 

36 (i.e., AC/DC-06, AC/DC-09, AC/DC-20, and CC-08) have an equivalent or higher 

37 implementation cost than the SAMAs into which they were subsumed (FENOC 2011). FENOC 

38 also provided a cost-benefit evaluation of these SAMAs. This is discussed further in 

39 Section F.6.2. FENOC further explained that the fifth subsumed SAMA (i.e., CB-07) was 

40 subsumed into SAMA CB-08, which was screened as already implemented at Davis-Besse. 

41 FENOC also determined that SAMA CB-08 was already implemented and rescreened this 

42 SAMA on that basis.

43 The NRC staff noted that Phase I SAMA CB-18, “direct steam generator flooding after an 

44 SGTR, prior to core damage,” was screened because it could impact efforts to mitigate SGTR, 

45 but it points out that this SAMA has been shown to be cost-beneficial in other SAMA analyses 

46 and asked FENOC to evaluate this SAMA (NRC 2011a). FENOC explained that in the 
Appendix F

F-23

1 Davis-Besse PRA model the SGTR sequences are grouped into core damage bins in which

2 either feedwater is unavailable to the steam generators and, therefore, flooding the steam 

3 generators is not possible or feedwater is available and scrubbing is already expected to occur 

4 so that flooding the steam generators provides no additional scrubbing benefit (FENOC 2011). 

5 Based on this, FENOC concludes that further evaluation of SAMA CB-18 is not warranted. 

6 Based on the once-through steam generator design used at Davis-Besse, the NRC staff agrees 

7 with this conclusion.

8 FENOC did not identify any additional SAMA candidates in the 2012 SAMA supplement 

9 (FENOC 2012a)

10 The NRC staff notes that the set of SAMAs submitted is not all-inclusive, since additional, 

11 possibly even less expensive, design alternatives can always be postulated. However, the NRC 

12 staff concludes that the benefits of any additional modifications are unlikely to exceed the 

13 benefits of the modifications evaluated and that the alternative improvements would not likely 

14 cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 

15 with maintenance, procedures, and training are considered.

16 The NRC staff concludes that FENOC used a systematic and comprehensive process for 

17 identifying potential plant improvements for Davis-Besse, and the set of SAMAs evaluated in the 

18 ER, together with those evaluated in response to NRC staff inquiries, is reasonably 

19 comprehensive and, therefore, acceptable. This search included reviewing insights from the 

20 plant-specific risk studies and reviewing plant improvements considered in previous SAMA 

21 analyses. While explicit treatment of external events in the SAMA identification process was 

22 limited, it is recognized that the prior implementation of plant modifications for fire risks, the 

23 absence of external event vulnerabilities (as documented in the IPEEE), and the use of an 

24 external events multiplier reasonably justifies examining primarily the internal events risk results 

25 for this purpose.

26 F.4 Risk Reduction Potential of Plant Improvements

27 FENOC evaluated the risk-reduction potential of the 15 SAMAs retained for the Phase II 

28 evaluation in the ER. The SAMA evaluations were generally performed in a bounding fashion in 

29 that the SAMA was assumed to eliminate all of the risk associated with the proposed 

30 enhancement. FENOC also provided the risk-reduction potential of six additional SAMAs 

31 (i.e., AC/DC-28R, OT-08R, CW-26R, CC-22R, FW-17R, and CB-22R) identified in response to 

32 RAIs using the same bounding approach. This bounding approach overestimates the benefit 

33 and is conservative.

34 FENOC used model re-quantification to determine the potential benefits. The CDF, population 

35 dose, and offsite economic cost reductions were estimated using the Davis-Besse SAMA 

36 analysis model. The changes made to the model to quantify the impact of SAMAs are detailed 

37 in Table E.7-1 of Attachment E to the ER (FENOC 2010). The changes made to the model to 

38 determine the risk reduction for the six SAMAs identified in response to NRC staff RAIs are 

39 provided in a clarification to the RAI responses (NRC 2011b). Table F-6 lists the assumptions 

40 considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk 

41 reduction in terms of percent reduction in CDF and population dose, and the estimated total 

42 benefit (present value) of the averted risk. The estimated benefits reported in Table F-6 reflect 

43 the combined benefit in both internal and external events. The determination of the benefits for 

44 the various SAMAs is further discussed in Section F.6.
Appendix F

F-24

1 The NRC staff requested FENOC to clarify why the population dose risk reduction in 

2 Table E.7-2 of the ER is either 10 percent or 0 percent and to explain how population dose risk 

3 was calculated (NRC 2011a). In response to the RAI, FENOC clarified that binary appearance 

4 of the reported population dose risk reduction is due to the round-off used in spreadsheet 

5 calculations (FENOC 2011). It was further explained that the population dose for each SAMA 

6 candidate is determined using the population dose determined by MACCS2 for each release 

7 category, the release category frequency from the PRA, and the sum of the population dose risk 

8 times the frequency for all release categories. The percent change is determined by 

9 comparison of the population dose risk for each SAMA candidate compared with the base case. 

10 In addition, FENOC regenerated the population dose risk reduction for all SAMAs evaluated, 

11 including the new SAMAs evaluated in response to NRC RAIs, to a higher number of significant 

12 digits to illustrate the distinction between the population dose risk values for each SAMA 

13 candidate. The regenerated population dose risk reduction for each SAMA candidate includes 

14 the revised Level 3 PRA analysis to include the Canadian population, as discussed in 

15 Section F.2.2. The revised population dose risk values having more significant figures are 

16 provided in Table F-6.

17 The NRC staff noted that the risk reduction reported for SAMA AC/DC-14, “install a gas turbine 

18 generator,” which assumes failure of the SBO DG is eliminated, does not appear to credit the 

19 situation where all emergency diesel generators (EDGs) are unavailable, and it asked FENOC 

20 to provide an assessment of this apparent omission (NRC 2011a). FENOC responded that, in 

21 the PRA model, the SBO DG is modeled as a backup to either EDG 1 or EDG 2 or both when 

22 they are unavailable (FENOC 2011). FENOC also explained that the analysis of this SAMA 

23 conservatively eliminated failure of the SBO DG ensuring that one train of emergency power 

24 was always available. 

25 The NRC staff has reviewed FENOC’s bases for calculating the risk reduction for the various 

26 plant improvements and concludes that the rationale and assumptions for estimating risk 

27 reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher 

28 than what would actually be realized). Accordingly, the NRC staff based its estimates of averted 

29 risk for the various SAMAs on FENOC’s risk reduction estimates.

Table F-6. SAMA Cost-Benefit Screening Analysis for Davis-Besse(a) 30

SAMA Modeling Assumptions

% Risk Reduction Total benefit ($)(c)

Cost ($)

CDF Population

Dose(c)

Using 7% 

Discount 

Rate 

Using 3% 

Discount 

Rate 

AC/DC-01—Provide 

additional DC battery 

capacity

Reduce the offsite power nonrecovery probabilities to reflect 

an increase in battery life to 

7 hours from 1 hour

6 2 100K 150K 1.75M

AC/DC-03—Add a 

portable, diesel-driven 

battery charger to 

existing DC system

Eliminate loss of DC power 

from station batteries due to 

loss of DC battery chargers

22 12 400K 600K 330K

AC/DC-14—Install a 

gas turbine generator

Eliminate failure of the SBO 

DG and associated operator 

actions

10 16 240K 360K 2.0M
Appendix F

F-25

SAMA Modeling Assumptions

% Risk Reduction Total benefit ($)(c)

Cost ($)

CDF Population

Dose(c)

Using 7% 

Discount 

Rate 

Using 3% 

Discount 

Rate 

AC/DC-19—Use fire 

water system as a 

backup source for 

diesel cooling

Eliminate failure of the EDGs

due to loss of CCW system

2 2 39K 60K 700K

AC/DC-21—Develop 

procedures to repair or 

replace failed 4 kV 

breakers

Eliminate failure of the 4 kV 

breakers

3 <1 48K 72K 100K

AC/DC-25—Provide a 

dedicated DC power 

system (battery/battery 

charger) for turbinedriven auxiliary 

feedwater (TDAFW) 

control

Eliminate failure of the 

TDAFW system due to loss of 

DC power

15 3 240K 370K 2.0M

AC/DC-26—Provide 

an alternator/generator 

that would be driven 

by each TDAFW pump 

to provide DC control 

power

Eliminate failure of the 

TDAFW system due to loss of 

DC power

15 3 240K 370K 2.0M

AC/DC-27—Increase 

the size of the SBO 

fuel oil tank

Eliminate failure of the 

operators to refuel the oil tank

0 0 0 0 550K

CB-21—Install 

pressure 

measurements 

between the two DHR 

suction valves in the 

line from the RCS hot 

leg

Eliminate latent failure of the 

upstream DHR suction valve 

(i.e., eliminate failures of the 

inboard isolation valve DH12 

prior to demand)(d)

0 6 30K 46K 550K

CC-01—Install an 

independent active or 

passive HPI system

Eliminate failure of one HPI 

train 

0 1 3.4K 5.3K 6.5M

CC-04—Add a diverse 

low-pressure injection 

(LPI) system

Eliminate failure of one LPI 

train 

0 0 0 0 5.5M

CC-05—Provide 

capability for alternate 

LPI via diesel-driven 

fire pump

Eliminate failure of one LPI 

train and eliminate failure of 

LPI due to loss of AC/DC 

power

0 0 0 0 6.5M

CC-19—Provide 

automatic switchover 

of HPI and LPI suction 

from the BWST to 

containment sump for 

LOCAs

Eliminate operator failures to 

switchover HPI and LPI 

suction to the containment 

sump

1 0 15K 23K 1.5M
Appendix F

F-26

SAMA Modeling Assumptions

% Risk Reduction Total benefit ($)(c)

Cost ($)

CDF Population

Dose(c)

Using 7% 

Discount 

Rate 

Using 3% 

Discount 

Rate 

HV-01—Provide a 

redundant train or 

means of ventilation

Eliminate failure of the low 

voltage switchgear room

ventilation

0 <1 1.4K 2.1K 50K

HV-03—Stage backup 

fans in switchgear 

rooms

Eliminate failure of the low 

voltage switchgear room 

ventilation

0 <1 1.4K 2.1K 400K

AC/DC-28R(b)—

Automatic start and 

load SBO DG on Bus 

D2 on loss of power to 

that bus

Eliminate operator failure to 

start the SBO DG

17 4 280K 420K 1.6M

CB-22R(b)—Purchase 

or manufacture of a 

“gagging device” that 

could be used to close 

a stuck-open steam 

generator safety valve 

for an SGTR event 

prior to core damage

Eliminate failure of main steam 

safety valve to close

3 12 110K 170K 4.6M

CC-22R(b)—Automatic 

refill of the BWST

Eliminate operator failure to 

refill the BWST

0 0 0 0 2.2M

CW-26R(b)—Automatic 

RCP trip on high motor 

bearing cooling 

temperature

Eliminate operator failure to 

trip the RCPs on loss of seal 

cooling and injection

23 3 365K 550K 1.5M

FW-17R(b)—Automatic 

start of AFW pump in 

the event the 

automated emergency 

system is unavailable

Eliminate operator failure to 

start the MDFP

25 6 410K 620K 2.8M

OT-08R(b)—Automatic 

start and load SBO 

DG on Bus D2 on loss 

of power to that bus in 

combination with 

automatically starting 

the MDFP

Eliminate operator failure to 

start the MDFP and SBO DG

43 9 700K 1.1M 4.4M

(a) SAMAs in bold are potentially cost-beneficial.

(b) SAMA description and evaluation provided in response to NRC staff RAIs 5.d and 7a–f (FENOC 2011). SAMA modeling 

assumptions provided in a clarification to the RAI responses (NRC 2011b).

(c) Estimated population doses and benefits reflect revised values provided in response to NRC staff RAIs 3.c, 4.b, and 6.e and to 

correct five errors identified in the 2012 SAMA supplement (FENOC 2011, 2012a).

(d) Modeling assumption clarified in response to NRC staff RAI 6.h (FENOC 2011).
Appendix F

F-27

1 F.5 Cost Impacts of Candidate Plant Improvements

2 FENOC developed plant-specific costs of implementing the original 15 Phase II candidate 

3 SAMAs as well as 6 additional SAMAs identified in response to NRC staff RAIs. The NRC staff 

4 asked FENOC to describe the level of detail used to develop the cost estimates and to clarify 

5 whether the cost estimates accounted for inflation, contingency costs associated with 

6 unforeseen implementation obstacles, replacement power during extended outages, and 

7 maintenance and surveillance costs during plant operation (NRC 2011a). In response to the 

8 RAI, FENOC clarified that the cost estimates conservatively did not include inflation, 

9 contingency costs associated with unforeseen implementation obstacles, or the cost of 

10 replacement power during extended outages required to implement the modifications 

11 (FENOC 2011). FENOC also clarified that the cost estimates considered the cost of equipment, 

12 fuel, space requirements, and the extent of the modifications and were developed by an expert 

13 panel that was composed of experienced staff drawn from engineering, operations, 

14 procurement, and project management. It was further explained that some implementation 

15 costs were assigned standard values based on plant experience or estimated man-hour 

16 requirements and that the following is true: 

17 • minimal procedure changes would be between $10,000 and $50,000, 

18 • procedural changes with engineering support would be between $50,000 and $200,000, 

19 • procedural changes with engineering support and testing or training would be between 

20 $200,000 and $300,000, and

21 • minimal physical plant changes would start at $100,000. 

22 Support activities included costs associated with procurement, installation, long-term 

23 maintenance, surveillance, calibration, and initial and on-going training.

24 The NRC staff reviewed the bases for the applicant’s cost estimates (presented in Section E.7.2 

25 of Attachment E to the ER). For certain improvements, the NRC staff also compared the cost 

26 estimates to estimates developed elsewhere for similar improvements, including estimates 

27 developed as part of other applicant’s analyses of SAMAs for operating reactors. Specifically, 

28 the NRC staff requested justification for the estimated cost of $1.5 million for implementation of 

29 SAMA CC-19, “provide automatic switch over of HPI and LPI suction from the BWST to 

30 containment sump for LOCAs.” This amount seems high for what is described as a capability 

31 that already exists at Davis-Besse but has been deactivated and is also higher than that 

32 estimated by other applicants (NRC 2011a). FENOC explained that the expert panel made the 

33 following assumptions in developing the cost estimate for this SAMA candidate (FENOC 2011): 

34 • reconnection and reactivation of automatic switchover equipment that is already in place, 

35 • re-performing the Appendix R analyses since the associated valves were de-powered to 

36 meet Appendix R criteria (approximately $500,000), 

37 • modifications to safety-related equipment and the associated calculation support 

38 (approximately $500,000), 

39 • procedure changes and initial testing and training (approximately $300,000), and

40 • ongoing testing, surveillances, maintenance, and training (approximately $200,000). 
Appendix F

F-28

1 Based on the need for the Appendix R analysis, the NRC staff finds FENOC’s justification for 

2 the cost estimate for SAMA CC-19 reasonable.

3 The NRC staff requested justification for the estimated cost of $2 million for implementation of 

4 SAMA AC/DC-25, “provide a dedicated DC power system (battery/battery charger) for the 

5 TDAFW control valve and NNI-X for steam generator level indication.” This amount seems high 

6 for a system dedicated to just the TDAFW control valves and in light of the lower estimated 

7 costs for similar SAMA candidates AC/DC-01 and AC/DC-03 (NRC 2011a). In response to the 

8 RAI, FENOC explained that the expert panel made the following assumptions in developing the 

9 cost estimate for this SAMA candidate (FENOC 2011): 

10 • a dedicated set of batteries and battery charger with a longer battery lifetime than the 

11 existing safety-related DC system and automatic steam generator level control, 

12 • safety-related space for the batteries (approximately $400,000), 

13 • modifications to safety-related equipment with seismic evaluation and associated 

14 calculation support (approximately $500,000), 

15 • procedure changes and initial testing and training (approximately $300,000), and

16 • procurement and installation of batteries and other components and equipment 

17 (approximately $700,000). 

18 Based on the estimated cost for additional safety-related space for the batteries, the NRC staff 

19 finds FENOC’s justification for the cost estimate for SAMA AC/DC-25 reasonable.

20 The NRC staff requested justification for the estimated cost of $7.5 million for implementation of 

21 SAMA CW-24, “replace the standby CCW pump with a pump diverse from the other two CCW 

22 pumps.” This amount seems high for a pump replacement (NRC 2011a). FENOC explained 

23 that the expert panel made the following assumptions in developing the cost for this SAMA 

24 candidate (FENOC 2011): 

25 • additional safety-related space is needed to provide separation from the existing CCW 

26 pumps (approximately $2 million), 

27 • design, procurement, and installation of the pump and associated components and 

28 equipment (approximately $4 million), 

29 • modifications to safety-related equipment with seismic evaluation and associated 

30 calculation support (approximately $1 million), and

31 • procedure changes and initial testing and training (approximately $500,000). 

32 Based on the estimated cost for additional safety-related space for the pump, the NRC staff 

33 finds FENOC’s justification for the cost estimate for SAMA CW-24 reasonable.

34 The NRC staff requested justification for the estimated cost of $1.75 million for SAMA 

35 AC/DC-01, “provide additional DC battery capacity” (NRC 2011a). In response to the RAI, 

36 FENOC explained that the expert panel made the following assumptions in developing the cost 

37 for this SAMA candidate (FENOC 2011): 

38 • safety-related space for the batteries (approximately $500,000), 

39 • major modifications to equipment (approximately $200,000), 
Appendix F

F-29

1 • procedure changes and initial testing and training (approximately $300,000), and

2 • procurement and installation of batteries and other components and equipment 

3 (approximately $600,000). 

4 Based on the estimated cost for additional safety-related space for the batteries, the NRC staff 

5 finds FENOC’s justification for the cost estimate for SAMA AC/DC-01 reasonable.

6 The NRC staff reviewed the costs provided in the ER, and in response to NRC staff RAIs, and 

7 found them to be reasonable and generally consistent with estimates provided in support of 

8 other plants’ analyses. The NRC staff concludes that the cost estimates provided by FENOC 

9 are sufficient and appropriate for use in the SAMA evaluation.

10 F.6 Cost-Benefit Comparison

11 FENOC’s cost-benefit analysis and the NRC staff’s review are described in the following 

12 sections.

13 F.6.1 FENOC’s Evaluation

14 The methodology used by FENOC was based primarily on NRC’s guidance for performing 

15 cost-benefit analysis (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation 

16 Handbook (NRC 1997a)). The guidance involves determining the net value for each SAMA 

17 according to the following formula:

18 Net Value = (APE + AOC + AOE + AOSC) – COE where the following is true: 

19 APE = present value of averted public exposure ($)

20 AOC = present value of averted offsite property damage costs ($)

21 AOE = present value of averted occupational exposure costs ($)

22 AOSC = present value of averted onsite costs ($)

23 COE = cost of enhancement ($)

24 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 

25 benefit associated with the SAMA and it is not considered cost-beneficial. FENOC’s derivation 

26 of each of the associated costs is summarized below.

27 NUREG/BR-0058 has been revised to reflect the agency’s policy on discount rates. Revision 4 

28 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3 percent 

29 and one at 7 percent (NRC 2004). FENOC provided a base set of results using the 7 percent 

30 discount rate and a sensitivity study using the 3 percent discount rate (FENOC 2010, 2012a).

31 Averted Public Exposure Costs. The APE costs were calculated using the following formula:

32 APE = Annual reduction in public exposure (Δperson-rem/year)

33 x monetary equivalent of unit dose ($2,000 per person-rem)

34 x present value conversion factor (12.27 based on a 28-year period with a 

35 7-percent discount rate)

36 As stated in NUREG/BR-0184 (NRC 1997a), the monetary value of the public health risk after 

37 discounting does not represent the expected reduction in public health risk due to a single 

38 accident. Rather, it is the present value of a stream of potential losses extending over the 

39 remaining lifetime (in this case, the renewal period) of the facility. FENOC based its calculations 
Appendix F

F-30

1 on a 28-year period, which is the summation of the 20-year license renewal period and the 

2 8-year period remaining in the current plant license, which is conservative. For the purposes of 

3 initial screening, which assumes elimination of all severe accidents caused by internal events, 

4 FENOC calculated, in response to an NRC staff RAI, an APE of approximately $52,000 for the 

5 20-year license renewal period and the 8 years of remaining life in the current plant license 

6 (FENOC 2012a).

7 Averted Offsite Property Damage Costs. The AOCs were calculated using the following 

8 formula:

9 AOC = Annual CDF reduction

10 x offsite economic costs associated with a severe accident (on a 

11 per-event basis)

12 x present value conversion factor

13 This term represents the sum of the frequency-weighted offsite economic costs for each release 

14 category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which

15 assumes elimination of all severe accidents caused by internal events, FENOC calculated, in 

16 response to an NRC staff RAI, an annual offsite economic cost of about $3,590 based on the 

17 Level 3 risk analysis (FENOC 2012a). This results in a discounted value of approximately 

18 $44,000 for the 20-year license renewal period and the 8 years of remaining life in the current 

19 plant license (FENOC 2012a).

20 Averted Occupational Exposure Costs. The AOE costs were calculated using the following 

21 formula:

22 AOE = Annual CDF reduction

23 x occupational exposure per core damage event

24 x monetary equivalent of unit dose

25 x present value conversion factor

26 FENOC derived the values for AOE from information provided in Section 5.7.3 of the Regulatory 

27 Analysis Handbook (NRC 1997a). Best estimate values provided for immediate occupational 

28 dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem over a 10-year 

29 cleanup period) were used. The present value of these doses was calculated using the 

30 equations provided in the handbook in conjunction with a monetary equivalent of unit dose of 

31 $2,000 per person-rem, a real discount rate of 7 percent, and a time period of 28 years to 

32 represent the license renewal period and the remaining plant life in the current license. For the 

33 purposes of initial screening, which assumes elimination of all severe accidents caused by 

34 internal events, FENOC calculated an AOE of approximately $4,300 for the 20-year license 

35 renewal period and the 8 years of remaining life in the current plant license (FENOC 2010).

36 Averted Onsite Costs. AOSCs include averted cleanup and decontamination costs (ACCs) and 

37 averted power replacement costs. Repair and refurbishment costs are considered for 

38 recoverable accidents only and not for severe accidents. FENOC derived the values for AOSC 

39 based on information provided in Section 5.7.6 of NUREG/BR-0184, the Regulatory Analysis 

40 Handbook (NRC 1997a).

41 FENOC divided this cost element into two parts—the onsite cleanup and decontamination cost, 

42 also commonly referred to as ACCs, and the replacement power cost (RPC).
Appendix F

F-31

1 ACCs were calculated using the following formula:

2 ACC = Annual CDF reduction

3 x present value of cleanup costs per core damage event

4 x present value conversion factor

5 The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 

NUREG/BR-0184 to be $1.5x109 6 (undiscounted). This value was converted to present costs 

7 over a 10-year cleanup period and integrated over the term of the proposed license extension 

8 and remaining plant life. For the purposes of initial screening, which assumes elimination of all 

9 severe accidents caused by internal events, FENOC calculated an ACC of approximately 

10 $132,400 for the 20-year license renewal period and the 8 years of remaining life in the current 

11 plant license.

12 Long-term RPCs were calculated using the following formula: 

13 RPC = Annual CDF reduction

14 x present value of replacement power for a single event

15 x factor to account for remaining service years for which replacement 

16 power is required

17 x reactor power scaling factor

18 FENOC based its calculations on the 910 megawatt-electric (MWe) reference plant in 

19 NUREG/BR-0184 (NRC 1997a) and did not scale down to the 908 MWe rating for Davis-Besse. 

20 Therefore, FENOC did not apply a power scaling factor to determine the RPCs, which are 

21 conservative. For the purposes of initial screening, which assumes elimination of all severe 

22 accidents caused by internal events, FENOC calculated an RPC of approximately $133,900 and 

23 an AOSC of approximately $266,300 for the 20-year license renewal period and the 8 years of 

24 remaining life in the current plant license.

25 Using the above equations, FENOC estimated the total present dollar value equivalent 

26 associated with eliminating severe accidents from internal events at Davis-Besse to be about 

27 $367,000 (FENOC 2012a). As discussed in Section F.2.2, in response to an NRC staff RAI, 

28 FENOC used a multiplier of 5.6 to account for external events, which increases the value to 

29 $2.05 million and represents the dollar value associated with eliminating all internal and external 

30 event severe accident risk at Davis-Besse, also referred to as the modified maximum averted 

31 cost risk (MMACR).

32 FENOC’s Results. If the implementation costs for a candidate SAMA exceeded the calculated 

33 benefit, the SAMA was considered not to be cost-beneficial. In the revised baseline analysis 

34 contained in the responses to an NRC staff RAI (FENOC 2011) and in the 2012 SAMA 

35 supplement (FENOC 2012a), using a 7 percent discount rate, FENOC identified one potentially 

36 cost-beneficial SAMA. Based on the results of the revised sensitivity analysis using a 3 percent 

37 discount rate, FENOC did not identify any additional potentially cost-beneficial SAMAs. FENOC 

38 also provided a revised uncertainty analysis using the multiplier of 7.0 to account for external 

39 events benefits, which resulted in no additional potentially cost-beneficial SAMAs.

40 The potentially cost-beneficial SAMA for Davis-Besse is SAMA AC/DC-03, “add a portable, 

41 diesel-driven battery charger to existing DC system.” This potentially cost-beneficial SAMA, and 

42 FENOC’s plans for further evaluation of this SAMA, is discussed in more detail in Section F.6.2.
Appendix F

F-32

1 F.6.2 Review of FENOC’s Cost-Benefit Evaluation 

2 The cost-benefit analysis performed by FENOC was based primarily on NUREG/BR-0184 

3 (NRC 1997a) and discount rate guidelines in NUREG/BR-0058 (NRC 2004), and it was 

4 executed consistent with this guidance.

5 SAMAs identified primarily on the basis of the internal events analysis could also provide 

6 benefits in certain external events. FENOC accounted for the potential risk reduction benefits 

7 associated with external events by applying a multiplier to the estimated benefits for internal 

8 events. In the analysis reported in the ER, FENOC multiplied the estimated benefits for internal 

9 events by a factor of 4.0 incorporating an external events multiplier of 3.0 to account for external 

10 events (based on the assumption that fire, seismic and other external events each contribute a 

11 benefit equivalent to that from internal events). As discussed in Section F.2.2, the NRC staff 

12 noted in an RAI that the external events multiplier should be 3.6 (based on a fire CDF of 

2.9x10-5 per year, a seismic CDF of 6.7x10-6 13 per year, a negligible contribution from HFO 

events, and an internal events CDF of 9.8x10-6 14 per year). The NRC staff asked FENOC to 

15 assess the impact on the SAMA evaluation of using the higher multiplier (NRC 2011a). In 

16 response to the RAI, FENOC provided a revised baseline evaluation by applying an external 

events multiplier of 4.6 resulting in a total multiplier of 5.6 (based on a fire CDF of 2.9x10-5 17 per 

year, a seismic CDF of 6.7x10-6 per year, an HFO CDF of 1.0x10-5 18 per year, and an internal 

events CDF of 1.0x10-5 19 per year) to the estimated SAMA benefits in internal events to account 

20 for potential SAMA benefits in both internal and external events (FENOC 2011). The results of 

21 this revised evaluation, incorporating the revised SAMA analysis provided in the 2012 SAMA 

22 supplement, are provided in Table F-6 (FENOC 2012a). As a result of the revised baseline 

23 analysis (using a multiplier of 5.6 and a 7 percent discount rate), FENOC found one SAMA 

24 (SAMA AC/DC-03) to be potentially cost-beneficial.

25 The NRC staff asked FENOC to provide an assessment of the uncertainty distribution for CDF 

26 and an assessment of the impact on the SAMA analysis of using the 95th percentile CDF 

27 (NRC 2011a). In response to the RAI, FENOC presented the results of an uncertainty analysis 

28 of the internal events CDF for Davis-Besse, which indicates that the 95th percentile value is a 

29 factor of 1.45 greater than the mean CDF for Davis-Besse (FENOC 2011). FENOC reexamined 

30 both the Phase I and Phase II SAMAs to determine if any would be potentially cost-beneficial if 

31 the revised baseline benefits were increased by an additional factor of 1.45 (in addition to the 

32 multiplier of 5.6 to account for external events). No additional SAMAs became cost-beneficial 

33 as a result of this analysis or the revised analysis provided in the 2012 SAMA supplement 

34 (FENOC 2012a).

35 FENOC provided the cost-benefit results of additional sensitivity analyses in the ER, including 

36 the following:

37 • assuming the cost of repair and refurbishment of damaged plant equipment is 

38 20 percent of the baseline RPC (FENOC 2011), 

39 • using 3 percent and 10 percent discount rates, 

40 • using 14,000 person-rem for short term dose and 30,000 person-rem for long term 

41 doses, 

42 • using an onsite cleanup and decontamination cost of $2.0 billion, 

43 • escalating the annual RPC to 2009 dollars by an average annual inflation rate of 

44 2.3 percent (FENOC 2011), 
Appendix F

F-33

1 • using a multiplier of 8.0 to account for external events, 

2 • using a higher population evacuation speed of 1.0 mps (NRC 2011b), and

3 • In addition, FENOC provided in the ER the results of sensitivity analyses of variations in 

4 MACCS2 input parameters (as discussed in Section F.2.2).

5 Revised results for all of these sensitivity cases are provided in Table E.8-1 of the 2012 SAMA 

6 supplement to account for the revised external events multiplier discussed above, to account for 

7 the correction to the population estimate discussed in Section F.2.2, and to correct the five 

8 errors in the ER SAMA analysis discussed in Section F.2.2 (FENOC 2012a). No additional 

9 SAMAs became cost-beneficial as a result of these analyses. It is noted that the sensitivity 

10 case using a 3 percent discount rate results in the most bounding cost-benefit results for all 

11 SAMAs, all sensitivity analyses, and the uncertainty analysis. The results for the 3 percent 

12 discount rate sensitivity case are provided in Table F-6.

13 The NRC staff noted that the higher evacuation speed sensitivity case resulted in a lower 

14 population dose, as would be expected, but the net benefit increased by about $2,000 for each 

15 SAMA, which would be expected to decrease. The NRC staff asked FENOC to explain this 

16 anomalous result (NRC 2011a). In response to an NRC staff RAI, FENOC clarified that this 

17 anomalous behavior was due to the difference in the number of significant digits used in the 

18 Level 3 PRA analysis and in the cost-benefit evaluation (FENOC 2011). Revised results were 

19 provided for this sensitivity case in which a consistent use of significant figures was applied 

20 between the Level 3 PRA and cost-benefit analyses, the revised external events multiplier was 

21 used, the revised population estimates discussed in Section F.2.2 were used, the scenario was 

22 changed to be a reduction in the baseline evacuation speed of 9.6 percent, and the five errors in 

23 the ER SAMA analysis discussed in Section F.2.2 were corrected. The revised results for this 

24 sensitivity case are provided in Table E.8-1 of the 2012 SAMA supplement (FENOC 2012a). No 

25 additional SAMAs became cost-beneficial as a result of this analysis. In addition, the results for 

26 this sensitivity case continued to be bounded by the 3 percent discount rate sensitivity case.

27 As indicated in Section F.3.2, the NRC staff asked the applicant to discuss opportunities for 

28 reducing risk by providing automatic functions to risk significant operator actions (NRC 2011a). 

29 In response to the RAI, FENOC identified and evaluated the following additional SAMA 

30 candidates that address risk-significant operations (FENOC 2011):

31 • AC/DC-28R, “automatically start and load the SBO diesel generator (DG) on Bus D2 

32 upon loss of power to the bus”—The cost-benefit evaluation of this SAMA candidate is 

33 provided in Table F-6 and was determined to not be cost-beneficial in either the revised 

34 baseline evaluation or the revised uncertainty and sensitivity analyses.

35 • OT-08R, “automatically start and load the SBO DG on Bus D2 upon loss of power to the 

36 bus in combination with automatically starting the motor-driven feedwater pump 

37 (MDFP)”—The cost-benefit evaluation of this SAMA candidate is provided in Table F-6 

38 and was determined to not be cost-beneficial in either the revised baseline evaluation or 

39 the revised uncertainty and sensitivity analyses.

40 As indicated in Section F.3.2, the NRC staff asked the applicant to evaluate potentially lower 

41 cost alternatives to the SAMAs considered in the ER (NRC 2011a), as summarized below:

42 • Automate RCP trip on high motor bearing cooling temperature—In response to the RAI, 

43 FENOC provided a cost-benefit evaluation of this SAMA candidate, referred to as 

44 SAMA CW-26R (FENOC 2012a). The evaluation of this SAMA is provided in Table F-6 
Appendix F

F-34

1 and was determined to not be cost-beneficial in either the revised baseline evaluation or 

2 the revised uncertainty and sensitivity analyses.

3 • Use the DHR system as an alternate suction source for HPI—In response to the RAI, 

4 FENOC explained that the Davis-Besse PRA already credits use of the DHR system as 

5 a suction source for HPI and that this is effectively already implemented (FENOC 2011). 

6 The NRC staff concludes that this alternative has been adequately addressed.

7 • Automate HPI injection on low pressurizer level (in loss of secondary side heat removal 

8 cases where the RCS pressure remains high while the RCS level drops)—In response to 

9 the RAI, FENOC explained that this proposed alternative is not viable for implementation 

10 at Davis-Besse because of design and system configuration differences between the 

11 Davis-Besse plant and other B&W plants (FENOC 2011). Specifically, this proposed 

12 improvement is applicable to B&W plants in which the HPI system is also the makeup 

13 system, and HPI cooling must be established earlier enough to prevent uncovering of 

14 the core due to RCS inventory depletion. For the Davis-Besse design, the HPI system is 

15 separate from the makeup system, and the HPI system is not capable of injecting water 

16 into the RCS until a specific pressure threshold is reached. In addition, makeup and HPI 

17 cooling can be delayed at Davis-Besse because Davis-Besse has two makeup pumps. 

18 The NRC staff concludes that this alternative has been adequately addressed.

19 • Automate refill of the BWST—In response to the RAI, FENOC provided a cost-benefit 

20 evaluation of this SAMA candidate, referred to as SAMA CC-22R (FENOC 2012a). The 

21 evaluation of this SAMA is provided in Table F-6 and was determined to not be 

22 cost-beneficial in either the revised baseline evaluation or the revised uncertainty and 

23 sensitivity analyses.

24 • Automate start of AFW pump in the event the automated EFW system is unavailable—In 

25 response to the RAI, FENOC provided a cost-benefit evaluation of this SAMA candidate, 

26 referred to as SAMA FW-17R (FENOC 2012a). The evaluation of this SAMA is provided 

27 in Table F-6 and was determined to not be cost-beneficial in either the revised baseline 

28 evaluation or the revised uncertainty and sensitivity analyses.

29 • Purchase or manufacture of a “gagging device” that could be used to close a stuck-open 

30 steam generator safety valve for an SGTR event prior to core damage. In response to 

31 the RAI, FENOC provided a cost-benefit evaluation of this SAMA candidate, referred to 

32 as SAMA CB-22R (FENOC 2012a). The evaluation of this SAMA is provided in 

33 Table F-6 and was determined to not be cost-beneficial in either the revised baseline 

34 evaluation or the revised uncertainty and sensitivity analyses.

35 As indicated in Section F.3.2, in response to an NRC staff RAI, FENOC provided a revised 

36 baseline evaluation for four Phase I SAMAs that were screened by being subsumed into other 

37 SAMAs (FENOC 2012a). The four subsumed SAMAs are AC/DC-06, AC/DC-09, AC/DC-20, 

38 and CC-08, which FENOC estimated to have implementation costs of $1.75 million, $2.8 million, 

39 $700,000, and $1.5 million, respectively. FENOC estimated the baseline benefit of these 

40 SAMAs to be the same as the SAMAs into which they were subsumed, namely SAMAs 

41 AC/DC-01, AC/DC-14, AC/DC-19, and CC-19, respectively. The revised benefits for these 

42 SAMAs are provided in Table F-6, and, in each case, the implementation cost of the subsumed 

43 SAMA is much greater than the estimated benefit. FENOC consequently determined the 

44 subsumed SAMAs to not be cost-beneficial.

45 FENOC states in Section E.9 of the ER that the one SAMA (SAMA AC/DC-03) determined to be 

46 potentially cost-beneficial in both the baseline analysis and the sensitivity analysis will be 
Appendix F

F-35

1 considered for implementation through the normal processes for evaluating possible plant 

2 modifications.

3 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMA 

4 discussed above, the costs of the other SAMAs evaluated would be higher than the associated 

5 benefits.

6 F.7 Conclusions

7 FENOC initially compiled a list of 167 SAMAs based on a review of the dominant cutsets and 

8 most significant basic events from the plant-specific PRA, insights from the plant-specific IPE 

9 and IPEEE, Phase II SAMAs from LRAs for other plants, and review of other industry 

10 documentation. An initial qualitative screening removed the SAMA candidates:

11 • The SAMA has design differences or has already been implemented at Davis-Besse.

12 • The SAMA is not applicable to Davis-Besse.

13 • The SAMA has estimated implementation costs that would exceed the dollar value 

14 associated with eliminating severe accident risk at Davis-Besse.

15 • The SAMA is related to a non-risk significant system and, therefore, has a very low 

16 benefit.

17 • The SAMA is similar in nature and could be combined with another SAMA candidate.

18 Based on this screening, 152 SAMAs were eliminated, leaving 15 candidate SAMAs for 

19 evaluation as well as 6 additional SAMAs identified in response to NRC staff RAIs.

20 For the remaining 21 SAMA candidates, more detailed design and cost estimates were 

21 developed, as shown in Table F-6. In response to NRC staff RAIs, and in the 2012 SAMA 

22 supplement, FENOC provided revised cost-benefit analyses that showed that one of the SAMA 

23 candidates was potentially cost-beneficial in the revised baseline analysis (SAMA AC/DC-03). 

24 FENOC also performed additional analyses to evaluate the impact of parameter choices and 

25 uncertainties on the results of the SAMA assessment. As a result, no additional SAMAs were 

26 determined to be potentially cost-beneficial.

27 The NRC staff reviewed the FENOC analysis and concludes that the methods used and the 

28 implementation of those methods were sound. The treatment of SAMA benefits and costs 

29 support the general conclusion that the SAMA evaluations performed by FENOC are 

30 reasonable and sufficient for the license renewal submittal. Although the treatment of SAMAs 

31 for external events was somewhat limited, the likelihood of there being cost-beneficial 

32 enhancements in this area was minimized by improvements that have been realized as a result 

33 of the IPEEE process and inclusion of a multiplier to account for external events.

34 The NRC staff concurs with FENOC’s identification of areas in which risk can be further reduced 

35 in a cost-beneficial manner through the implementation of the identified, potentially 

36 cost-beneficial SAMA. Given the potential for cost-beneficial risk reduction, the NRC staff 

37 agrees that further evaluation of this SAMA by FENOC is warranted. However, this SAMA does 

38 not relate to adequately managing the effects of aging during the period of extended operation. 

39 Therefore, it is not required to be implemented as part of license renewal pursuant to Title 10 of 

40 the Code of Federal Regulations, Part 54 (10 CFR Part 54).
Appendix F

F-36

1 F.8 References

2 [ASME] American Society of Mechanical Engineers. 2005. “Standard for Level 1/Large Early 

3 Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications,” 

4 ASME/ANS RA-S-2005. New York, New York.

5 Centerior Energy. 1993. Letter from Donald C. Shelton (Centerior Energy) to NRC Document 

6 Control Desk. Subject: “Individual Plant Examination (IPE) for Severe Accident Vulnerabilities 

7 for the Davis-Besse Nuclear Power Station, Unit 1 (Response to NRC Generic Letter 88-20),” 

8 February 26, 1993.

9 Centerior Energy. 1996. Letter from John K. Wood (Centerior Energy) to NRC Document 

10 Control Desk. Subject: “Individual Plant Examination for External Events for Severe Accident 

11 Vulnerabilities for the Davis-Besse Nuclear Power Station, Unit 1 (Response to NRC Generic 

12 Letter 88-20, Supplement 4),” December 16, 1996.

13 [EPA] U.S. Environmental Protection Agency. 1972. Mixing Heights, Wind Speeds, and 

14 Potential for Urban Air Pollution Throughout the Contiguous United States, AP-101. 

15 Washington D.C. January 1972.

16 [EPRI] Electric Power Research Institute. 1991. “A Methodology for Assessment of Nuclear 

17 Power Plant Seismic Margin,” EPRI NP-6041-SL, Revision 1. Palo Alto, CA. August 1991.

18 [EPRI] Electric Power Research Institute. 1995. “Fire PRA Implementation Guide,” EPRI 

19 TR-105928. Palo Alto, CA. December 1995.

20 [EPRI] Electric Power Research Institute. 1993. “Fire-Induced Vulnerability Evaluation (FIVE),” 

21 EPRI TR-100370, Revision 1. Palo Alto, CA. September 1992.

22 [EPRI] Electric Power Research Institute (EPRI). 2006. “Support System Initiating Events: 

23 Identification and Quantification Guideline,” EPRI Interim Report 1013490. Palo Alto, CA. 

24 September 1993.

25 [FENOC] FirstEnergy Nuclear Operating Company. 2010. Davis-Besse Nuclear Power 

26 Station---License Renewal Application, Applicant’s Environmental Report, Operating License 

27 Renewal Stage. August 2010. ADAMS Accession Nos. ML102450563 and ML102450568.

28 [FENOC] FirstEnergy Nuclear Operating Company. 2011. Letter from Kendall W. Byrd, 

29 FENOC, to NRC Document Control Desk. Subject: Reply to Request for Additional Information 

30 for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal 

31 Application (TAC No. ME4613) Environmental Report Severe Accident Mitigation Alternatives 

32 Analysis, and License Renewal Application Amendment No.10. June 24, 2011. ADAMS 

33 Accession No. ML11180A233.

34 [FENOC] FirstEnergy Nuclear Operating Company. 2012a. Letter from John C. Dominy, 

35 FENOC, to NRC Document Control Desk. Subject: Correction of Errors in the Davis-Besse 

36 Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4613) 

37 Environmental Report Severe Accident Mitigation Alternatives Analysis, and License Renewal 

38 Application Amendment No.29. July 16, 2012. ADAMS Accession No. ML11180A233.

39 [FENOC] FirstEnergy Nuclear Operating Company. 2012b. Memo from Steven Dort, FENOC, 

40 to File. Subject: NRC Telecon Regarding Davis-Besse License Renewal—Severe Accident 
Appendix F

F-37

1 Mitigation Alternatives Analysis Questions. September 25, 2012. ADAMS Accession 

2 No. ML14028A534. 

3 [MDT] Michigan Department of Taxation. 2007. Guide to Michigan’s School District Income 

4 Tax, November 2007.

5 [NEI] Nuclear Energy Institute. 2005. “Severe Accident Mitigation Alternative (SAMA) Analysis 

6 Guidance Document,” NEI 05-01 (Revision A). Washington, D.C. November 2005.

7 [NRC] U.S. Nuclear Regulatory Commission. 1988. Generic Letter 88-20, “Individual Plant 

8 Examination for Severe Accident Vulnerabilities.” Washington, D.C. November 23, 1988.

9 [NRC] U.S. Nuclear Regulatory Commission. 1991. Generic Letter No. 88-20, Supplement 4, 

10 Individual Plant Examination of External Events for Severe Accident Vulnerabilities, 

11 NUREG-1407. Washington, D.C. June 28, 1991.

12 [NRC] U.S. Nuclear Regulatory Commission. 1994a. Revised Livermore Seismic Hazard 

13 Estimates for 69 Sites East of the Rocky Mountains. NUREG-1488. Washington, D.C. April 

14 1994. U.S. Nuclear Regulatory Commission (NRC). 1994b. Information Notice 94-32, 

15 “Revised Seismic Hazard Estimates.” Washington, D.C. April 29, 1994.

16 [NRC] U.S. Nuclear Regulatory Commission. 1994b. Information Notice No. 94-32, “Revised 

17 Seismic Hazard Estimate.” Washington, D.C. April 29, 1994.

18 [NRC] U.S. Nuclear Regulatory Commission. 1996. Letter from Linda L. Gundrum, U.S. NRC, 

19 to John K. Wood, Centerior Energy. Subject: Staff Evaluation Report for Generic letter 88-20, 

20 “Individual Plant Examination—Davis-Besse Nuclear Power Station, Unit No. 1” (TAC 

21 No. M74402). Washington, D.C. October 2, 1996.

22 [NRC] U.S. Nuclear Regulatory Commission. 1997a. Regulatory Analysis Technical Evaluation 

23 Handbook. NUREG/BR-0184. Washington, D.C. January 1997.

24 [NRC] U.S. Nuclear Regulatory Commission. 1997b. Individual Plant Examination Program: 

25 Perspectives on Reactor Safety and Plant Performance. NUREG-1560. Washington, D.C., 

26 December 1997.

27 [NRC] U.S. Nuclear Regulatory Commission. 1998a. Code Manual for MACCS2: Volume 1, 

28 User’s Guide. NUREG/CR-6613. Washington, D.C. May 1998.

29 [NRC] U.S. Nuclear Regulatory Commission. 2000. “Davis-Besse Nuclear Power Station, 

30 Unit 1—Plant-Specific Safety Evaluation Report for USI A-46 Program Implementation” (TAC 

31 No. M69441) Washington, D.C. September 21, 2000. ADAMS Accession No. ML003777680.

32 [NRC] U.S. Nuclear Regulatory Commission. 2001. “Davis-Besse Nuclear Power Station, 

33 Unit 1—Review of Individual Plant Examination of External Events (TAC No. M83613)” 

34 Washington, D.C. February 8, 2001. ADAMS Accession No. ML010860075.

35 [NRC] U.S. Nuclear Regulatory Commission. 2003. Sector Population, Land Fraction, and 

36 Economic Estimation Program. SECPOP: NUREG/CR-6525. Washington D.C. April 2003.

37 [NRC] U.S. Nuclear Regulatory Commission. 2004. Regulatory Analysis Guidelines of the U.S. 

38 Nuclear Regulatory Commission. NUREG/BR-0058, Revision 4. Washington, D.C. 

39 September 2004.
Appendix F

F-38

1 [NRC] U.S. Nuclear Regulatory Commission. 2005. EPRI/NRC-RES Fire PRA Methodology for 

2 Nuclear Power Facilities. NUREG/CR-6850, Volume 2, Washington, D.C., September, 2005.

3 [NRC] U.S. Nuclear Regulatory Commission. 2007. “An Approach for Determining the 

4 Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.” 

5 Regulatory Guide 1.200, Revision 1. Washington, D.C. January 2007.

6 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from Paula E. Cooper, U.S. NRC, 

7 to Barry S. Allen, FENOC. Subject: Requests for Additional Information for the Review of the 

8 Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application. Washington, D.C. 

9 April 20, 2011. ADAMS Accession No. ML110910566.

10 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Memo from John G. Parillo, U.S. NRC, to 

11 Travis L. Tate, U.S. NRC. Subject: Request For Additional Information Response Clarifications 

12 From Davis-Besse Nuclear Power Station In Support Of License Renewal Application Review 

13 (TAC No. ME4613). Washington, D.C. August 15, 2011. Accessible at ML112270139 [ODT] 

14 Ohio Department of Taxation. 2008. Guide to Ohio’s School District Income Tax, 

15 November 2008.

16 [SQUG] Seismic Qualification Users Group. 1992. “Generic Implementation Procedure (GIP) 

17 for Seismic Verification of Nuclear Plant Equipment,” Revision 2, Corrected. February 14, 1992.

18 [USCB] U.S. Census Bureau (USCB). 2000. State and County QuickFacts, Web site: 

19 http://www.census.gov/main/www/cen2000.html, accessed July 2009.

20 [USDA] U.S. Department of Agriculture. 2009a. “2007 Census of Agriculture: Michigan State 

21 and County Data,” Volume 1, Geographic Area Series, Part 22.

22 [USDA] U.S. Department of Agriculture. 2009b. “2007 Census of Agriculture: Ohio State and 

23 County Data,” Volume 1, Geographic Area Series, Part 35.

24 [USGS] U.S. Geological Survey. 2008. “2008 NSHM Gridded Data, Peak Ground 

25 Acceleration.” Available at 

26 http://earthquake.usgs.gov/hazards/products/conterminous/2008/data/. 

27 [USGSA] U.S. General Services Administration. 2009. Per Diem Rates, Web site: 

28 http://www.gsa.gov, accessed July 2009.



UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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OFFICIAL BUSINESS
 

 

NUREG-1437

Draft

Supplement 52

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Davis-Besse Nuclear Power Station