NUREG-1437

Supplement 26

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 26

Regarding

Monticello Nuclear Generating Plant

Final Report

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington, DC 20555-0001
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NUREG-1437

Supplement 26

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 26

Regarding

Monticello Nuclear Generating Plant

Final Report

Manuscript Completed: August 2006

Date Published: August 2006

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
NUREG-1437, Supplement 26, has been

reproduced from the best available copy.
Abstract

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

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

Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), NUREG-1 437,

Volumes 1 and 2, and codified the results in 10 CFR Part 51. In the GElS (and its

Addendum 1), the staff identifies 92 environmental issues and reaches generic conclusions

related to environmental impacts for 69 of these issues that apply to all plants or to plants with

specific design or site characteristics. Additional plant-specific review is required for the

remaining 23 issues. These plant-specific reviews are to be included in a supplement to the

GELS.

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

an application submitted to the NRC by Nuclear Management Company, LLC (NMC), to renew

the OL for the Monticello Nuclear Generating Plant (Monticello) for an additional 20 years under

10 CFR Part 54. This SEIS includes the NRC staff's analysis that considers and weighs the

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

proposed action, and mitigation measures available for reducing or avoiding adverse impacts.

It also includes the staff's recommendation regarding the proposed action.

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

staff has identified information that is both new and significant for any GElS generic conclusion

that applies to Monticello. In addition, the staff determined that information provided during the

scoping process did not call into question the conclusions in the GELS. Therefore, the staff

concludes that the impacts of renewing the Monticello OL would not be greater than impacts

identified for these issues in the GElS. For each of these issues, the staff's conclusion in the

GElS is that the impact is of SMALL(a) significance (except for collective offsite radiological

impacts from the fuel cycle and high-level waste and spent fuel, which were not assigned a

single significance level).

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

The staff concludes that the significance of the potential environmental impacts of renewal of

the OLs is SMALL for each applicable issue, with one exception. The magnitude of impact for

the chronic effects of electromagnetic fields is "uncertain." The staff also concludes that

additional mitigation measures are not likely to be sufficiently beneficial as to be warranted.

The staff determined that information provided during the scoping process did not identify any

new issue that has a significant environmental impact.

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

noticeably alter any important attribute of the resource.

August 2006 iii NUREG-1437, Supplement 26 1
Abstract

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

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

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

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

Report submitted by MC; (3) consultation with Federal, State, and local agencies; (4) the staff's

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

NUREG-1437, Supplement 26 iv August 2006 1
Contents

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

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

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

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

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

1.2 Background ....................................................... 1-2

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

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

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

1.4 The Purpose and Need for the Proposed Action ........................... 1-7

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

1.6 References ....................................................... 1-8

2.0 Description of Nuclear Power Plant and Site and Plant Interaction

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

2.1 Plant and Site Description and Proposed Plant Operation During the

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

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

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

2.1.3 Cooling and Auxiliary Water Systems .............................. 2-4

2.1.4 Radioactive Waste Management Systems and Effluent Control Systems ... 2-8

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls ........... 2-9

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls ........ 2-10

2.1.4.3 Solid W aste Processing ................................... 2-11

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

2.1.6 Plant Operation and Maintenance .......... ...................... 2-11

2.1.7 Power Transmission System .................................... 2-12

2.2 Plant Interaction with the Environment .................................. 2-14

2.2.1 Land Use ................................................... 2-14

2.2.2 W ater Use .................................................. 2-15

2.2.3 W ater Quality ............................................... 2-16

2.2.4 Air Q uality .................................................. 2-17

2.2.5 Aquatic Resources ......... . ............................. 2-19

2.2.6 Terrestrial Resources ................... ................. 2-24

2.2.7 Radiological Impacts .......................... ....... 2-29

2.2.8 Socioeconomic Factors ........................................ 2-30

2.2.8.1 Housing ............................................... 2-30

2.2.8.2 Public Services ....... . .............................. 2-31

2.2.8.3 Offsite Land Use .......................................... 2-34

2.2.8.4 Visual Aesthetics and Noise ................................ 2-36

August 2006 v NUREG-1437, Supplement 26
Contents

2.2.8.5 Demography ............................................ 2-36

2.2.8.6 Economy .............................................. 2-38

2.2.9 Historic and Archaeological Resources ............................ 2-40

2.2.9.1 Cultural Background ....................................... 2-40

2.2.9.2 Historic and Archaeological Resources at the Monticello Site ........ 2-41

2.2.10 Related Federal Project Activities and Consultations ................ 2-41

2.3 References ...................................................... 2-42

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

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

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

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

4.1.1 Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using

Makeup Water from a Small River with a Low Flow) .................... 4-12

4.1.2 Entrainment of Fish and Shellfish in Early Life Stages .................. 4-13

4.1.3 Impingement of Fish and Shellfish ................................. 4-16

4.1.4 Heat Shock ............................................ 4-18

4.1.5 Microbiological Organisms (Public Health) ........................ 4-21

* 4.2 Transmission Lines ................................................. 4-22

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

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

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

4.4 Socioeconomic Impacts of Plant Operations During the License Renewal Term ... 4-29

4.4.1 Housing Impacts During Operations .............................. 4-30

4.4.2 Public Services: Public Utility Impacts During Operations .............. 4-32

4.4.3 Offsite Land Use During Operations .............................. 4-32

4.4.4 Public Services: Transportation Impacts During Operations ............ 4-34

4.4.5 Historic and Archaeological Resources ............................ 4-35

4.4.6 Environmental Justice ......................................... 4-36

4.5 Groundwater Use and Quality ......................................... 4-40

4.5.1 Groundwater Use Conflicts (Make-Up From a Small River) ............. 4-41

4.6 Threatened or Endangered Species ..................................... 4-41

4.6.1 Aquatic Species .............................................. 4-42

4.6.2 Terrestrial Species ............................................ 4-42

4.7 Evaluation of Potential New and Significant Information on Impacts of Operations

During the Renewal Term ............................................ 4-43

4.8 Cumulative Impacts ................................................. 4-44

4.8.1 Cumulative Impacts Resulting from Operation of the Plant Cooling System 4-44

4.8.2 Cumulative Impacts Resulting from Continued Operation of the

Transmission Lines ........................................... 4-46

4.8.3 Cumulative Radiological Impacts ................................. 4-47

4.8.4 Cumulative Socioeconomic Impacts .............................. 4-47

4.8.5 Cumulative Impacts on Groundwater Use and Quality ............... 4-48

4.8.6 Cumulative Impacts on Threatened or Endangered Species ............ 4-48

NUREG-1437, Supplement 26 vi August 2006 1
Contents

4.8.7 Conclusions Regarding Cumulative Impacts ........................ 4-49

4.9 Summary of Impacts of Operations During the Renewal Term ................ 4-49

4.10 References .................................................... 4-50

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

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

5.1.1 Design-Basis Accidents ......................................... 5-1

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

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

5.2.1 Introduction .................................. ; ............... 5-5

5.2.2 Estimate of Risk .............................................. 5-6

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

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

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

5.2.6 Conclusions .................................................. 5-10

5.3 References ...... ................................................ 5-11

6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management ..... 6-1

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

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

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

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

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

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

8.1 No-Action Alternative ................................................. 8-1

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

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

8.2.2 Natural Gas-Fired Generation ................................... 8-18

8.2.3 Coal Gasification ............................................. 8-26

8.2.4 Nuclear Power Generation ..................................... 8-34

8.2.4.1 Closed-Cycle Cooling System .............................. 8-35

8.2.4.2 Once-Through Cooling System ............................. 8-42

8.2.5 Purchased Electrical Power ..................................... 8-43

8.2.6 Other Alternatives ............................................ 8-44

8.2.6.1 Oil-Fired Generation ...................................... 8-44

8.2.6.2 W ind Power ............................................ 8-45

8.2.6.3 Solar Power ............................................ 8-46

8.2.6.4 Hydropower ........................................... 8-47

8.2.6.5 Geothermal Energy ...................................... 8-47

8.2.6.6 W ood W aste ............................................ 8-47

8.2.6.7 Municipal Solid W aste .................................... 8-48

8.2.6.8 Other Biomass-Derived Fuels ............................... 8-49

8.2.6.9 Fuel Cells .............................................. 8-49

August 2006 vii NUREG-1437, Supplement 26
Contents

8.2.6.10 Delayed Retirement ...................................... 8-50

8.2.6.11 Utility-Sponsored Conservation ............................. 8-50

8.2.7 Combination of Alternatives ..................................... 8-51

8.3 Summary of Alternatives Considered ................................... 8-54

8.4 References ....................................................... 8-55

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

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

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

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

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

9.2 Relative Significance of the Environmental Impacts of License Renewal

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

9.3 Staff Conclusions and Recommendations ................................. 9-8

9.4 References ........................................................ 9-8

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

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

Appendix C: Chronology of NRC Staff Environmental Review Correspondence Related

to Nuclear Management Company, LLC's Application for License Renewal of Monticello

Nuclear Generating Plant .................................................. C-1

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

Appendix E: Nuclear Management Company, LLC's Compliance Status and Consultation

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

Appendix F: GElS Environmental Issues Not Applicable to Monticello Nuclear Generating

Plant ................................................................... F-1

I Appendix G: NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) for

Monticello Nuclear Generating Plant ........................................... G-1

NUREG-1437, Supplement 26 viii August 2006 1
Figures

Figure 2-1.

Figure 2-2.

Figure 2-3.

Figure 2-4.

Figure 2-5.

Figure 4-1.

Figure 4-2.

Location of Monticello, 50-mi Region ................................ 2-2

Location of Monticello, 6-mi Region ................................. 2-3

Monticello Site Powerblock Area ................................... 2-5

Monticello Cooling and Auxiliary Water System ........................ 2-6

Monticello Transmission Lines .................................... 2-13

Geographic Distribution of Minority Populations (Shown in Shaded Areas)

Within 50 mi of Monticello Based on Census Block Group Data .......... 4-38

Geographic Distribution of Low-Income Populations (Shown in Shaded

Areas) Within 50 mi of Monticello Based on Census Block Group Data .... 4-39

August 2006 ix NUREG-1437, Supplement 26 1
Contents

Tables

Table 2-1. Monticello Transmission Line Rights-of-Way ......................... 2-14

Table 2-2. Circulating Water System Operating Modes .......................... 2-16

Table 2-3. Threatened or Endangered Aquatic Species Potentially Occurring in the

Vicinity of Monticello and the Associated Transmission Corridors .......... 2-23

Table 2-4. State of Minnesota Identified Natural Communities in the Vicinity of the

Transmission Corridors ..................... .. 2-27

Table 2-5. Threatened or Endangered Terrestrial Species Potentially Occurring in the Vicinity

of Monticello and the Associated Transmission Corridors ................ 2-28

Table 2-6. Housing Units and Housing Units Vacant (Available) by County During

1990 and 2000 ................................................ 2-31

Table 2-7.. Major Public Water Supply Systems in Wright and Sherburne Counties ..... 2-32

Table 2-8. Traffic Counts for Roads in the Vicinity of Monticello ................... 2-33

Table 2-9. Land Use in Wright County, 1980s ................................. 2-34

Table 2-10. Land Use in Sherburne County, 1991 ....................... .... 2-35

Table 2-11. Estimated Populations and Average Annual Growth Rates in Wright and

Sherburne Counties from 1970 to 2040 ............................. 2-37

Table 2-12. Major Employment Facilities Within 10 mi of the Monticello Site ........... 2-38

Table 2-13. Property Taxes Paid from 1998 to 2002; Monticello Contribution to County

Property Tax Revenues ......................................... 2-39

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

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

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

Cooling System During the Renewal Term ............................ 4-3

Table 4-2. Category 2 Issues Applicable to the Operation of the Monticello

Cooling System During the Renewal Term ........................... 4-11

Table 4-3. Category 1 Issues Applicable to the Monticello Transmission Lines

During the Renewal Term ........................................ 4-23

Table 4-4. Category 2 and Uncategorized Issues Applicable to the Monticello

Transmission Lines During the Renewal Term ........................ 4-25

Table 4-5. Category 1 Issues Applicable to Radiological Impacts of Normal

Operations During the Renewal Term ............................... 4-28

Table 4-6. Category 1 Issues Applicable to Socioeconomics During the

Renewal Term ................................................ 4-29

Table 4-7. Environmental Justice and GElS Category 2 Issues Applicable to

Socioeconomics During the Renewal Term .......................... 4-31

Table 4-8. Category 1 Issue Applicable to Groundwater Use and Quality During

the Renewal Term ............................................. 4-40

Table 4-9. Category 2 Issue Applicable to Groundwater Use and Quality During

the Renewal Term ............................................. 4-41

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

in the Vicinity of Monticello During the License Renewal Term ............ 4-42

NUREG-1437, Supplement 26A X August 2006 1
Contents

Table 5-1. Category 1 Issue Applicable to Postulated Accidents During the

Renewal Term ........................................... 5-3

Table 5-2. Category 2 Issue Applicable to Postulated Accidents During the

Renewal Term ................................................. 5-4

Table 5-3. Monticello Core Damage Frequency for Internal Events ................... 5-6

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

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

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

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

Following the Renewal Term ....................................... 7-2

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

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

Alternate Greenfield Site Using Closed-Cycle Cooling ................... 8-9

Table 8-3. Summary of Environmental Impacts of Natural Gas-Fired Generation at an

Alternate Greenfield Site Using Closed-Cycle Cooling .................. 8-20

Table 8-4. Summary of Environmental Impacts of a Coal Gasification Generation

Plant at an Alternate Greenfield Site Using Closed-Cycle Cooling ......... 8-28

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

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

Table 8-6. Summary of a Comparison of Environmental impacts of a New Nuclear

Power Plant Sited at the Monticello Site with Once-Through Cooling ....... 8-42

Table 8-7. Summary of Environmental Impacts for an Assumed Combination of

Generating (Combined-Cycle Natural Gas-Fired Generation, Wind Power

and DSM) and Acquisition Alternatives at Monticello and a Greenfield Site 8-52

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

No-Action Alternative, and Alternative Methods of Generation Using

Once-Through Cooling ...................................... 9-7

Table A-I. Individuals Providing Comments During Scoping Comment Period ......... A-2

Table A-2. Comments Received on the Draft SEIS ............................. A-38

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

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

Other Approvals for Monticello ..................................... E-2

Table F-i. GElS Environmental Issues Not Applicable to Monticello ................. F-1

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

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

Table G-3. Monticello PSA Historical Summary ............................. G-6

Table G-4. SAMA Cost-Benefit Screening Analysis for Monticello .................. G-18

August 2006 xi NUREG-1437, Supplement 26 1

Executive Summary

By letter dated March 16, 2005, Nuclear Management Company, LLC (NMC), submitted an

application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating license

(OL) for Monticello Nuclear Generating Plant (Monticello) for an additional 20-year period. If the

OL is renewed, State regulatory agencies and NMC will ultimately decide whether the plant will

continue to operate, based on factors such as the need for power or other matters within the

State's jurisdiction or the purview of the owners. If the OL is not renewed, then the plant must

be shut down on or before the expiration date of the current OL, which is September 8, 2010.

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

(42 USC 4332) in Title 10 of the Code of Federal Regulations (CFR) Part 51 (10 CFR Part 51).

In 10 CFR 51.20(b)(2), the Commission requires preparation of an environmental impact

statement (EIS) or a supplement to an EIS for renewal of a reactor OL. In addition,

10 CFR 51.95(c) states that the EIS prepared at the OL renewal stage will be a supplement to

the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS),

NUREG-1437, Volumes 1 and 2.=

Upon acceptance of the NMC application, the NRC began the environmental review process

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

scoping. The staff visited the Monticello site in June 2005 and held public scoping meetings on

June 30, 2005, in Monticello, Minnesota. In the preparation of this.supplemental environmental

impact statement (SEIS) for Monticello, the staff reviewed the NMC Environmental Report (ER)

and compared it to the GELS, consulted with other agencies, conducted an independent review

of the issues, following the guidance set forth in NUREG-1 555, Standard Review Plans for

Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal,

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

comments received during the scoping process that were considered to be within the scope of

the environmental review are provided in Appendix A, Part 1, of this SEIS.

The staff held two public meetings in Monticello, Minnesota, in March 2006 to describe the

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

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

When the 75-day comment period ended, the staff considered and dispositioned all of the

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

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

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

and measures for reducing or avoiding adverse effects. It also includes the staff's

recommendation regarding the proposed action.

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

to the "GELS" include the GElS and its Addendum 1.

August 2006 xiii NUREG-1437, Supplement 26 1
Executive Summary

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

from the GELS:

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

provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs,

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

(other than NRC) decisionmakers.

The evaluation criterion for the staff's environmental review, as defined in 10 CFR 51.95(c)(4)

and the GELS, is to determine

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

that preserving the option of license renewal for energy planning decisionmakers would

be unreasonable.

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

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

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

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

SEISs prepared at the license renewal stage:

The Supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of

the proposed action or of alternatives to the proposed action except insofar as such

benefits and costs are either essential for a determination regarding the inclusion of an

alternative in the range of alternatives considered or relevant to mitigation. In addition,

the supplemental environmental impact statement prepared at the license renewal stage

need not discuss other issues not related to the environmental effects of the proposed

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

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

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

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

The GElS contains the results of a systematic evaluation of the consequences of renewing an

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

environmental issues using the NRC's three-level standard of significance-SMALL,

MODERATE, or LARGE-developed using the Council on Environmental Quality guidelines.

The following definitions of the three significance levels are set forth in footnotes to Table B-1 of

10 CFR Part 51, Subpart A, Appendix B:

SMALL-Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

NUREG-1437, Supplement 26 xiv August 2006 1
Executive Summary

MODERATE-Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE-Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

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

conclusions:

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

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

system or other specified plant or site characteristics.

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

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

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

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

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

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

These 69 issues were identified in the GElS as Category 1 issues; In the absence of new and

significant information, the staff relied on conclusions as amplified by supporting information in

the GElS for issues designated as Category I in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B.

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

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

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

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

plant-specific supplement to the GELS. Information on the chronic effects of electromagnetic

fields was not conclusive at the time the GElS was prepared.

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

GElS. The staff considered the environmental impacts associated with alternatives to license

renewal and compared the environmental impacts of license renewal and the alternatives. The

alternatives to license renewal that were considered include the no-action alternative (not

renewing the OL for Monticello) and alternative methods of power generation. Based on

projections made by the U.S. Department of Energy's Energy Information Administration

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

alternatives if the power from Monticello is replaced. These alternatives are evaluated

assuming that the replacement power generation plant is located at either the Monticello site or

some other unspecified alternate location.

August 2006 xv NUREG-1437, Supplement 26
Executive Summary

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

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

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

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

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

a significant environmental impact. Therefore, the staff relies upon the conclusions of the GElS

for all of the Category 1 issues that are applicable to Monticello.

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

environmental justice and chronic effects from electromagnetic fields. The staff has reviewed

the NMC analysis for each issue and has conducted an independent review of each issue.

Three Category 2 issues are not applicable, because they are related to plant design features

or site characteristics not found at Monticello. Four Category 2 issues are not discussed in this

SEIS, because they are specifically related to refurbishment. NMC has stated that its

evaluation of structures and components, as required by 10 CFR 54.21, did not identify any

major plant refurbishment activities or modifications as necessary to support the continued

operation of Monticello for the license renewal period. In addition, any replacement of

components or additional inspection activities are within the bounds of normal plant operation,

and are not expected to affect the environment outside of the bounds of the plant operations

evaluated in the U.S. Atomic Energy Commission's 1972 Final Environmental Statement

Related to Operation of Monticello Plant.

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

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

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

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

relation to operation during the renewal term. For all 14 Category 2 issues and environmental

justice, the staff concludes that the potential environmental effects are of SMALL significance in

the context of the standards set forth in the GELS. In addition, the staff determined that

appropriate Federal health agencies have not reached a consensus on the existence of chronic

adverse effects from electromagnetic fields. Therefore, no further evaluation of this issue is

required. For severe accident mitigation alternatives (SAMAs), the staff concludes that a

reasonable, comprehensive effort was made to identify and evaluate SAMAs. Based on its

review of the SAMAs for Monticello, and the plant improvements already made, the staff

concludes that one of the candidate SAMAs is potentially cost-beneficial. However, this SAMA

does not relate to adequately managing the effects of aging during the period of extended

operation. Therefore, it does not need to be implemented as part of license renewal pursuant

to 10 CFR Part 54.

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

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

mitigation measures were deemed sufficiently beneficial to be warranted.

NUREG-1437, Supplement 26 August 2006 1
Executive Summary

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

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

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

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

cumulative impacts on potentially affected resources.

If the Monticello operating license is not renewed and the unit ceases operation on or before the

expiration of the current operating license, then the adverse impacts of likely alternatives will

not be smaller than those associated with continued operation of Monticello. The impacts may,

in fact, be greater in some areas.

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

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

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

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

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

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

scoping process.

August 2006 xvii NUREG-1437, Supplement 26

Abbreviations/Acronyms

0 degree

pCi microcurie(s)

pCi/mL microcurie(s) per milliliter

pm micrometer(s) (microns)

ac acre(s)

AC alternating current

ACC averted cleanup and decontamination costs

ADAMS NRC documents access and management system

AEC U.S. Atomic Energy Commission

ALARA as low as reasonably achievable

AOC present value of averted offsite property damage costs

AOE present value of averted occupational exposure

AOSC present value of averted onsite costs

APE present value of averted public exposure

ASDS automatic (or alternate) shutdown system

B.C. before the common era

BTU British thermal unit(s)

BTU/kWh British thermal unit(s) per kilowatt-hour

BWR boiling water reactor

BWROG boiling water reactor owners group

CAIR Clean Air Interstate Rule

CDF core damage frequency

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic feet per second

Ci curie(s)

CO carbon monoxide

CO2 carbon dioxide

COE cost of enhancement

CRD control rod drive

CST condensate storage tank

CT combustion turbine

CWA Clean Water Act

DBA design-basis accident

dc direct current

August 2006 xix NUREG-1437, Supplement 26
Abbreviations/Acronyms

DOE U.S. Department of Energy

DOI U.S. Department of the Interior

DOT U.S. Department of Transportation

DSM demand-side management

EDG emergency diesel generator

EIA Energy Information Administration (of DOE)

EIS environmental impact statement

ELF-EMF extremely low frequency electromagnetic. field

EPA U.S. Environmental Protection Agency

EPRI Electric Power Research Institute

ER Environmental Report

ESW emergency service water

F Fahrenheit

FES final environmental statement

FIVE fire-induced vulnerability evaluation

FPS fire protection system

FR Federal Register

FSAR final safety analysis report

FSW fire service water

ft foot/feet

ft/s foot/feet per second

ft3 cubic foot/feet.

ft3/s cubic foot/feet per second

FWS U.S. Fish and Wildlife Service

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

NUREG-1 437

GL generic letter

gpd gallons per day

gpm gallons per minute

GWh gigawatt-hours

HLW high-level waste

HPCI high-pressure coolant injection

hr hour(s)

HRSG heat recovery steam generator

Hp horsepower

Hz hertz

in. inch(es)

NUREG-1437, Supplement 26 xx. August 2006
Abbreviations/Acronyms

IPE

IPEEE

J

kV

kW

kWh

lb

lb/MWh

LLW

LOS

individual plant examination

individual plant examination of external events

joule(s)

kilovolt(s)

kilowatt(s)

kilowatt hour(s)

pound

pound(s) per megawatt-hour

low-level waste

level of service

MAAP

mA

MACCS2

MAPP

MCBS

MDC

MDEED

MDOT

mi

mi

mL

MMACR

MNDNR

MNSHPO

MOU

mph

MPCA

MPSDC

MPUC

mrem

mrem/yr

MSA

mSv

mSv/yr

MTED

MTHM

MT'U

August 2006

modular accident analysis program

milliampere(s)

MELCOR Accident Consequence Code System 2

Mid-Continent Area Power Pool

Minnesota County Biological Survey

Minnesota Department. of Commerce

Minnesota Department of Employment and Economic Development

Minnesota Department of Transportation

mile(s)

square mile(s)

milliliter(s)

modified maximum averted cost-risk

Minnesota Department of Natural Resources

Minnesota State Historic Preservation Office

Memorandum of Understanding

miles per hour

Minnesota Pollution Control Agency

Minnesota Plannihg State Demographic Center

Minnesota Public Utilities Commission

millirem(s)

millirem(s) per year

metropolitan statistical area

millisievert(s)

millisievert(s) per year

Minnesota Trade and Economic Development

metric tons of heavy metal (a conventional unit for high-level nuclear waste)

metric ton(s) uranium

xxi NUREG-1437, Supplement 26 1
Abbreviations/Acronyms

MW megawatt(s)

MWd megawatt-days

MWd/MTU megawatt-days per metric ton(s) uranium

MW(e) megawatt(s) electric

MW(t) megawatt(s) thermal

MWh megawatt hour(s)

N/A not applicable

NAAQS National Ambient Air Quality Standards

NAS National Academy of Sciences

NEPA National Environmental Policy Act of 1969

NESC National Electrical Safety Code

ng/J nanogram(s) per joule

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMC Nuclear Management Company

NO 2 nitrogen dioxide

NO, nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System

NPSH net positive suction head

NRC U.S. Nuclear Regulatory Commission

NRHP National. Register of Historic Places

NSP Northern States Power Company

ODCM Offsite Dose Calculation Manual

OL operating license

PARS publically available records

PCB polychlorinated biphenyl

pCi/L picocuries per liter

PIO Public Information Officer

PM10 particulate matter, 10 microns or less in diameter

ppm parts per million

PRA probabilistic risk analysis

PSA probabilistic safety assessment

PSD prevention of significant deterioration

RAI request for additional information

RCIC reactor core isolation cooling

RCRA Resource Conservation and Recovery Act

RDS rapid dewatering system

NUREG-1 437, Supplement 26 xxii August 2006 1
Abbreviations/Acronyms

rem roentgen equivalent man, equal to 0.01 sievert

REMP radiological environmental monitoring program

RHR residual heat removal

RM river mile(s)

ROW right-of-way

RPC replacement power costs

SAMA severe accident mitigation alternative

SAR safety analysis report

SBO station blackout

scfm standard cubic feet per minute

SCR selective catalytic reduction

SEIS supplemental environmental impact statement

SER safety evaluation report

SHPO State Historic Preservation Officer

SMITTR surveillance, monitoring, inspections, testing, trending, and record keeping

S02 sulfur dioxide

SOx sulfur oxide(s)

SRV safety/relief valve

Sv sievert(s) (special unit of dose equivalent)

SW service water

TB turbine building

TVA Tennessee Valley Authority

U.S. United States

USAR updated safety analysis report

USC United States Code

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

USGS U.S. Geological Survey

USI unresolved safety issue

V volt(s)

WMD Wetland Management District

yr year

August 2006 xxiii NUREG-1437, Supplement 26 I

1.0 Introduction

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

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

Environmental Policy Act (NEPA), renewal of a nuclear power plant operating license (OL)

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

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

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

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

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

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

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

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

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

need to be addressed by the applicants in plant-by-plant renewal proceedings. The GElS

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

process.

Nuclear Management Company, LLC (NMC), operates the Monticello Nuclear Generating Plant

(Monticello) in central Minnesota under OL No. DPR-22, which was issued by the NRC. NMC is

a licensee for the purposes of its current OL and an applicant for the renewal of the OL.

Monticello is owned by Northern States Power Company (NSP) which is a wholly owned utility

operating subsidiary of Xcel Energy Inc. (Xcel Energy). This OL will expire on

September 8, 2010. NMC submitted an application dated March 16, 2005, to the NRC to renew

the Monticello OL for an additional 20 years beyond the expiration of the current license

pursuant to 10 CFR Part 54. Pursuant to 10 CFR 54.23 and 51.53(c), NMC submitted an

Environmental Report (ER; NMC 2005a) in which NMC analyzed the environmental impacts

associated with the proposed license renewal action, considered alternatives to the proposed

action, and evaluated mitigation measures for reducing adverse environmental effects.

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

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

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

in accordance with 10 CFR Part 54.

1.1 Report Contents

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

this SEIS, including the development of the GElS and the process used by the staff to assess

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

action to renew the Monticello OL, (3) discuss the purpose and need for the proposed action,

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

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

August 2006 1-1 NUREG-1437, Supplement 26
Introduction

and (4) present the status of NMC's compliance with environmental quality standards and

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

responsible for environmental protection.

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

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

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

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

potential environmental impacts of plant accidents and includes consideration of severe

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

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

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

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

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

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

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

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

received on the environmental review for license renewal and staff responses to the public

comments. Appendixes B through G, respectively, list the following:

" the preparers of the supplement

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

* the organizations contacted during the development of this SEIS

" NMC's compliance status in Table E-1 (this appendix also contains copies of consultation

correspondence prepared and sent during the evaluation process)

" GElS environmental issues that are not applicable to Monticello

* NRC staff evaluation of severe accident mitigation alternatives (SAMAs).

1.2 Background

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

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

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

of renewal of OLs.

NUREG-1437, Supplement 26 1-2 August 2006 1
Introduction

1.2.1 Generic Environmental Impact Statement

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

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

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

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

power plant license renewal EISs.

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

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

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

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

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

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

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

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

same significance level for all plants.

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

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

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

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

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

Subpart A, Appendix B, as follows:

SMALL-Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE-Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE-Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

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

mitigation measures would continue.

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

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

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

issues are those that meet all of the following criteria:

August 2006 1-3 NUREG-1 437, Supplement 26 1
Introduction

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

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

system or other specified plant or site characteristics.

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

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

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

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

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

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

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

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

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

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

In the GELS, the staff assessed 92 environmental issues and determined that 69 qualified as

• Category 1 issues and 21 qualified as Category 2 issues. Two issues, environmental justice

I and chronic effects of electromagnetic fields, were not categorized and are addressed in plantspecific analysis. Environmental justice was not evaluated on a generic basis in the GElS and

information on the chronic effects .of electromagnetic fields was not conclusive at the time the

GElS was prepared. Of the 92 issues, 11 are related only to refurbishment, 6 are related only

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

refurbishment and operation during the renewal term. A summary of the findings for all 92

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

1.2.2 License Renewal Evaluation Process

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

license-renewal evaluation process involves careful review of the applicant's ER as well as

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

available during the GElS evaluation is identified, reviewed, and assessed to verify the

environmental impacts of the proposed license renewal.

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

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

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

* discuss actions to mitigate any adverse impacts associated with the proposed action and

environmental impacts of alternatives to the proposed action.

NUREG-1437, Supplement 26 1-4 August 2006 1
Introduction

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

* consider the economic benefits and costs of the proposed action and alternatives to the

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

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

considered, or (2) relevant to mitigation

* consider the need for power and other issues not related to the environmental effects of the

proposed action and the alternatives

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

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

* contain an analysis of any Category 1 issue unless there is significant new information on a

specific issue-this is pursuant to 10 CFR 51.23(cX3)(iii) and (iv).

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

issue not covered in the GElS and codified in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, or (2) information that was not considered in the analyses summarized in the GElS

and that leads to an impact finding that is different from the finding presented in the GElS and

codified in 10 CFR Part 51.

In preparing to submit its application to renew the Monticello OL, NMC developed a process to

ensure that (1) information not addressed in or available during the GElS evaluation regarding

the environmental impacts of license renewal for Monticello would be properly reviewed before

submitting the ER and (2) such new and potentially significant information related to renewal of

the license for Monticello would be identified, reviewed, and assessed during the period of NRC

review. NMC reviewed the Category 1 issues that appear in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, to verify that the conclusions of the GElS remained valid with respect.to

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

who were familiar with NEPA issues and the scientific disciplines involved in the preparation of

a license renewal ER.

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

is described in detail in NUREG-1 555, Standard Review Plans for Environmental Reviews for

Nuclear Power Plants, Supplement 1: Operating License Renewal (ESRP), (NRC 2000). The

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

discovering and evaluating the significance of new information; (2) review of records of public

comments; (3) review of environmental quality standards and regulations; (4) coordination with

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

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

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

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

August 2006 1-5 NUREG-1 437, Supplement 26 1
Introduction

I assessment of the relevant new and significant information. The scope of the assessment does

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

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

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

identifies the issues to be addressed and lists the sections in the GElS where the issue is

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

issues for which there is no new and significant information, the table is followed by a set of

short paragraphs that state the GElS conclusion codified in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, followed by the staff's analysis and conclusion. For Category 2 issues,

in addition to the list of GElS sections where the issue is discussed, the tables list the

subparagraph of 10 CFR 51.53(c)(3)(ii) that describes the analysis required and the SEIS

sections where the analysis is presented. The SEIS sections that include discussions of the

Category 2 issues are presented immediately following the table.

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

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

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

docketing in the Federal Register (FR); (70 FR 25117 [NRC 2005a]) on May 12, 2005. The

staff published a notice of intent to prepare an EIS and conduct scoping (70 FR 32381 [NRC

2005b]) on June 2, 2005. Two public scoping meetings were held on June 30, 2005, in

Monticello, Minnesota. Comments received during the scoping period were summarized in the

Environmental Impact Statement Scoping Process: Summary Report, Monticello Nuclear

Generating Plant, Monticello, Minnesota (NRC 2005c) dated October 7, 2005. These

comments are also presented in Part 1 of Appendix A.

The staff followed the review guidance contained in NUREG-1555, Supplement 1 (NRC 2000).

The staff and contractors retained to assist the staff visited the Monticello site on June 28 and

29, 2005, to gather information and to become familiar with the site and its environs. The 'staff

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

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

Other documents related to Monticello were reviewed and are referenced in this report.

A 75-day comment period to allow members of the public to comment on the preliminary results

of the NRC staff's review began on the date of publication of the U.S. Environmental Protection

Agency Notice of Filing of the draft SEIS. During this comment period, two public meetings

were held in Monticello, Minnesota, on March 22, 2006. During these meetings, the staff

described the preliminary results of the NRC environmental review and answered questions

related to it to provide members of the public with information to assist them in formulating their

comments.

NUREG-1 437, Supplement 26 1-6 August 2006 1
Introduction

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

the proposed renewal of the OL for Monticello, the environmental impacts of alternatives to

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

Chapter 9, "Summary and Conclusions," provides the NRC staff's recommendation to the

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

great that preserving the option of license renewal for energy-planning decisionmakers would

be unreasonable.

1.3 The Proposed Federal Action

The proposed Federal action is renewal of the OL for Monticello. Monticello is located in central

Minnesota on the southern bank of the Mississippi River, approximately 22 mi southeast of St.

Cloud, and 30 mi northwest of Minneapolis, St. Paul. The plant has one General Electric

Company-designed boiling-water reactor, with a design power level of 1670 megawatts thermal

(MW[t]) and a net power output of 545 megawatts electric (MW[e]). An authorized power

uprate in 1998 increased power levels to approximately 1775 MW(t) (600 MW[e]). Plant cooling

is primarily provided by an open-cycle system that draws and discharges water to the

Mississippi River. Monticello is also equipped with two mechanical draft cooling towers which

enable complete or partial recirculation of the cooling water when required by special permit. •

conditions. Monticello produces electricity to supply the needs of more than 585,000 homes.

The current OL for Monticello expires on September 8, 2010. By letter dated March 16, 2005,

NMC submitted an application to the NRC (NMC 2005b) to.renew this OL for an additional 20

years of operation (i.e., until September 8, 2030).

1.4 The Purpose and Need for the Proposed Action

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

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

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

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

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

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

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

need (GElS Section 1.3):

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

provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs,

as such needs may be determined by State, utility, and where authorized, Federal (other

than NRC) decisionmakers.

August 2006 1-7 NUREG-1437, Supplement 26 I
Introduction

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

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

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

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

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

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

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

current term of the plant's license.

1.5 Compliance and Consultations

NMC is required to hold certain Federal, State, and local environmental permits, as well as

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

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

environmental approvals and consultations associated with Monticello license renewal.

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

Appendix E of this SEIS.

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

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

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

environmental issues. *The ER states that NMC is in compliance with applicable environmental

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

issues that are both new and significant.

1.6 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

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

1508, "Terminology and Index."

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

Nuclear Management Company (NMC). 2005a. Applicant's Environmental Report--Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

NUREG-1437, Supplement 26 1-8 August 2006 1
Introduction

Nuclear Management Company (NMC). 2005b. Application for Renewed Operating License,

Monticello Nuclear Generating Plant. Monticello, Minnesota.

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4332, et seq.

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

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

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

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

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

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

Reviews for Nuclear Power Plants, Main Report, Supplement 1: Operating License Renewal.

NUREG-1555, Supplement 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005a. "Notice of Acceptance for Docketing of

the Application and Notice of Opportunity for a Hearing Regarding Renewal of License No.

DPR-22 for an Additional Twenty-Year Period." Federal Register, Vol. 70, No. 91, pp.

25117-25119. Washington, D.C. May 12, 2005.

U.S. Nuclear Regulatory Commission (NRC). 2005b. "Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process." Federal Register, Vol. 70,

No. 105, pp. 32381-32382. Washington, D.C. June 2, 2005.

U.S. Nuclear Regulatory Commission (NRC). 2005c. Environmental Impact Statement

Scoping Process: Summary Report, Monticello Nuclear Generating Plant, Monticello,

Minnesota. Washington, D.C. October 7, 2005.

August 2006 1-9 NUREG-1437, Supplement 26 I

2.0 Description of Nuclear Power Plant and Site and

Plant Interaction with the Environment

Monticello Nuclear Generating Plant (Monticello) is located in the City of Monticello, Wright

County, Minnesota, on the southern bank of the Mississippi River (River Mile [RM] 900). The

plant consists of one unit. The unit is a boiling-water reactor that produces steam which passes

through turbines to generate electricity. Plant cooling is primarily provided by an open-cycle

system that draws and discharges water to the Mississippi River. Monticello is also equipped

with two mechanical draft cooling towers which enable complete or partial recirculation of the

cooling water when required by special permit conditions. The plant and its environs are

described in Section 2.1, and the plant's interaction with the environment is presented in

Section 2.2.

2.1 Plant and Site Description and Proposed Plant Operation

During the Renewal Term

Monticello is located in central Minnesota on the southern bank of the Mississippi River,

approximately 22 mi southeast of St. Cloud, and 30 mi northwest of Minneapolis/St. Paul. The

area within 6 mi of Monticello includes portions of Wright and Sherburne counties and is

primarily agricultural. The MontiCello site is located in a region dominated by rivers, streams,

* and lakes, with numerous public recreational and natural areas located within 50 mi of the site.

The site consists of 2150 ac with approximately 2 mi of frontage on the north and south banks

of the Mississippi River. Approximately 50 ac are occupied by the plant and its supporting

facilities (NMC 2005a). Figures 2-1 and 2-2 show the site location and features within 50 mi

and 6 mi, respectively.

2.1.1 External Appearance and Setting

Site structures include a reactor building, a turbine building, a radioactive-waste building, an

off-gas stack, two mechanical draft cooling towers, a diesel emergency generator building, and

the Monticello Substation. Transmission lines and corridors are also prominent features on and

near the Monticello site. The site's exclusion zone has been designated as being within the

Owner Controlled Area fence. Of the site's 2150,ac, approximately 450 ac are located on the

northern bank of the Mississippi River, with the majority of the acreage on the southern bank.

Approximately 50 ac on the southern bank are occupied by the facility structures, and the

remaining acres are undeveloped with land leased by local farmers for growing row crops, and

under lease for recreational use.

August 2006 2-1 NUREG-1437, Supplement 26 1
Description of Site and Environment

50-MILE REGION

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Figure 2-1. Location of Monticello, 50-mi Region

NUREG-1437, Supplement 26 2-2 August2006 I
Description of Site and Environment

6-MILE SITE VICINITY

Figure 2-2. Location of Monticello, 6-mi Region

August 2006 2-3 NUREG-1437, Supplement 26 1
Description of Site and Environment

Natural surface drainage of the Monticello site is generally to the southwest at a 2- to 3-percent

grade away from the Mississippi River. The land cover of the site is predominated by formerly

cultivated fields in various stages of ecological succession (NMC 2005a).

2.1.2 Reactor Systems

Monticello is a single-unit electric generating plant. The unit is a single-cycle, forced circulation,

low-power density boiling water reactor. General Electric Company designed and supplied the

nuclear steam supply system, the initial reactor fuel, and the turbine-generator unit and its

related systems. Monticello was designed for operation at power levels up to 1670 megawatts

thermal (MW[t]) and an electrical output of up to 545 megawatts electric (MW[e]) (AEC 1972).

However, an uprate license amendment was submitted and subsequently approved by the

Nuclear Regulatory Commission (NRC) on January 21, 1998 (NRC 1998). The current rated

thermal power level for the unit is 1775 MW(t) and 600 MW(e).

The Monticello facility is depicted in Figure 2-3. The reactor containment structure consists of a

drywell, which encloses the reactor vessel and recirculation pumps; a pressure suppression.

chamber, which stores a large volume of water; a connecting vent system between the drywell

and the suppression chamber; and isolation valves. The concrete reactor building serves as a

radiation shield and fulfills a secondary containment function. The reactor building is

maintained under a slight negative pressure, with the building exhaust monitored prior to

release to the atmosphere through the reactor building ventilation exhaust stack. The

containment for the unit is designed to withstand an internal pressure of 56 pounds per square

inch above atmospheric pressure (NMC 2005b). Monticello uses low-enriched uranium dioxide

fuel with enrichments below 5.0 percent by weight uranium-235, with peak fuel-rod burn-up

levels less than 62,000 megawatt-days per metric ton uranium (MWd/MTU) (NMC 2005c).

2.1.3 Cooling and Auxiliary Water Systems

The Mississippi River is the source of water at Monticello for plant condenser cooling and some

auxiliary water systems, such as service water cooling, screen wash, and fire protection. Five

groundwater wells provide water for other auxiliary systems, such as water for the reverse

osmosis/make-up demineralizer system used to produce purified water for the plant primary

systems and seal water to pumps located at the intake structure. Groundwater is also used for

domestic potable use, including drinking water, lavatories, and showers at the plant. Figure 2-4

shows the locations of the two induced-draft cooling towers and the discharge canal.

NUREG-1437, Supplement 26 2-4 AUgust 2006 1
Description of Site and Environment

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August 2006 2-5 NUREG-1437, Supplement 26 1
Description of Site and Environment

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Figure 2-4. Monticello Cooling and Auxiliary Water System

Mississippi River water enters the intake structure through an approach channel formed by

sheet pile structures that are 98 ft apart and extend 59 ft into the river, angled at 81 degrees to

NUREG-1437, Supplement 26 2-6 August 2006 1
Description of Site and Environment

the shoreline. At the intake structure,-the approach channel reduces to approximately 63 ft

wide. Water enters the intake structure over a 63-ft wide concrete sill that serves as a sediment

barrier. At the center of the sill is a 12.5-ft wide stop log section that can be removed during

low river levels to allow water to flow unobstructed. On the plant side of the sill is a concrete

apron extending the width of the approach channel and 16 ft upstream of the bar rack. The bar

rack includes a motor-operated bar rack rake that prevents large debris from entering the intake

structure. The bar rack rake lifts debris into a trash hopper to prevent the debris from

re-entering the river. After the bar rack, the water is divided into two separate streams that

pass through two parallel traveling screens located 10 ft behind the bar racks. The traveling

screens have 3/8-in. mesh that removes fine debris. The traveling screens are normally rotated

and rinsed every 12 hours and are run'continuously When the river temperature is above 500F.

The debris, as well as any impinged organisms, are rinsed from the traveling screens into a

common sluiceway that extends back to the river downstream of the intake structures. From

the traveling screens, water passes through the service water pump bay and two parallel

motor-operated sluice gates before reaching the circulating water pumps.

The circulating water system consists of two circulating water pumps, each rated 140,000 gpm,

mounted over each end of the intake structure. These pumps are designed to circulate

292,000 gpm of cooling water through the main condenser. The plant service water system

consists of three service water pumps each with 6000 gpm capacity. These pumps supply over

10,000 gpm to meet all nonreactor requirements during normal operating conditions.

Effluent from the condenser and service water system is piped approximately 600 ft through two

108-in. steel pipes to the discharge structure at the head of the discharge canal. The discharge

structure is constructed of reinforced concrete and measures 50 ft by 54 ft by 38 ft high, with

the roof approximately 5 ft above grade. The discharge structure includes two isolation and two

sluice gates. The motor-operated sluice gates can isolate the discharge flow from the

discharge canal. During once-through or open-cycle operation, the sluice gates are open and

the circulating water is returned to the Mississippi River through the discharge canal. The

bottom of the discharge canal was constructed on a 0.25 percent slope in an easterly direction

approximately 1000 ft to where it enters the river. An overflow weir was added in 1980 to allow

normal outflow of cooling water from the discharge canal, re-establishing the previously existing

shoreline of the river. The weir inhibits fish from entering the canal. The discharge weir

consists of an earth filled dike and a vertical sheet-pile overflow section.

Monticello also has the capability of utilizing two mechanical draft cooling towers to meet

surface water appropriations limits and thermal discharge limits as needed (see Section 2.2.2.).

Two cooling tower pumps are located at the discharge structure and are designed to deliver

151,000 gpm to each cooling tower. In this mode of operation, control gates can isolate the

Mississippi River from the main intake structure and the discharge structure. Cooled water

from the cooling tower basins is then allowed to flow by gravity to the circulating water pumps in

the intake structure. Cooling tower blowdown is piped by gravity to the discharge canal.

Makeup water to replace water lost from cooling tower evaporation, drift, and blowdown is

August 2006 2-7 NUREG-1437, Supplement 26 1
Description of Site and Environment

serviced by two designated pumps, each rated 14,000 gpm, located at the intake structure.

Cooling towers are normally operated in May through September, when Mississippi River

temperatures have typically exceeded 680F, or during periods of extremely low flow. One tower

is used occasionally during the winter to provide a flow path of heated water to the intake to

keep the intake area free of ice.

I Five groundwater wells at Monticello provide water for domestic potable use and some auxiliary

systems. Two wells, each equipped with a 1 00-gpm capacity pump, are manifold together and

provide raw water to the reverse osmosis/make-up demineralizer system, and seal water to

pumps at the plant intake structure. Two other wells provide additional domestic water as

I needed. The final well was installed in 2004 at the Security Training Facility for potable water

use.

2.1.4 Radioactive Waste Management Systems and Effluent Control Systems

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

radioactive materials that are produced as a byproduct of plant operations. The design

objective for the radwaste systems is to provide equipment, instrumentation, and operating

procedures such that the discharge of radioactivity from the plant will not exceed the limits set

forth in 10 CFR Part 20. The radwaste systems are also designed and operated to meet the

dose design objectives of 10 CFR Paht 50, Appendix I, to meet the criterion "as low as

reasonably achievable," or ALARA.

Radioactive material produced from fission of uranium-235 and neutron activation of metals in

the reactor coolant system is the primary source of liquid, gaseous, and solid radioactive waste.

The radioactive fission products build up within the fuel and are contained in the fuel pellets and

sealed fuel rods, but small quantities escape from the fuel rods into the reactor coolant.

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

zirconium, iron, and cobalt creates radioactive isotopes of these metals. Both fission and

activation products in liquid and gaseous forms are continuously removed from reactor coolant

and captured on filter media followed by demineralization. Monticello operates separade liquid,

solid, and gaseous radwaste processing systems (NMC 2005b).

Fuel rods that have exhausted a certain percentage of their fuel and that are removed from the

reactor core for disposal are called spent fuel. Spent fuel assemblies, removed from the

reactor core, are stored in a spent fuel pool located on the refueling floor of the reactor building.

Xcel Energy has applied for a Certificate of Need from Minnesota Public Utilities Commission

that would authorize construction of a dry fuel storage area for additional spent fuel assemblies.

Dry active waste includes contaminated protective clothing, paper, rags, and other trash

generated during operation and maintenance activities. Filter media include paper and glass

fiber cartridge filters, resin beads or powder, and metallic filters. Class A, B, and C solid waste,

as defined in 10 CFR Part 61, may be processed for volume reduction, or is shipped to a

licensed disposal facility.

NUREG-1 437, Supplement 26 2-8 August 2006 1
Description of Site and Environment

The Monticello Offsite Dose Calculation Manual (ODCM) (NMC 2004b) contains the

methodology and parameters used in the calculation of off-site doses resulting from radioactive

gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm

and trip set points, and in the conduct of the Radiological Environmental Monitoring Program

(REMP). The ODCM also contains the radioactive effluent controls and radiological

environmental monitoring activities and descriptions of the information that should be included

in the Radiological Environmental Operating Program report and Radioactive Effluent Release

reports required by 10 CFR Part 50, Appendix I, and 10 CFR Part 50.36a.

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls

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

and auxiliary systems is processed through the radwaste system. Final disposition of

processed liquid includes either return of the liquid to the condensate system for plant re-use,

or solidification of chemical liquid waste and shipment of the resulting solid to an off-site

location.

Liquid waste is collected in sumps and drain tanks in the various buildings and then transferred

* to the appropriate subsystem collection tanks in the radwaste building for subsequent

treatment, re-use, and disposal. In order to keep the releases to a minimum, modifications

*. were made to the liquid radwaste system to allow reclaiming of floor drains as well as

equipment drains. The modified system limits the release of liquid effluents to the minimum

practicable extent and to satisfy the design objectives of Appendix I to 10 CFR Part 50. The

radioactive and chemical contaminants are removed from the liquid waste streams by either

filtration or filtration followed by mixed deep-bed demineralization. The filters remove insoluble

particulate contaminants and the demineralizer removes soluble materials. The filter and

demineralizer sludge are backwashed into receiving tanks, dewatered to less than 0.5 percent

liquid and packaged as solid waste for disposal off-site at NRC-approved sites.

NMC manages the radwaste system at Monticello so that there are no routine releases of liquid

radioactive effluents from the plant. Therefore, NMC states that there are no radioactive liquid

effluents during normal operations. However, in some years, the plant may release a small

amount of liquid containing radioactive material. NMC considers these releases as abnormal,

but they are controlled, monitored, reported, and within Federal release limits and guidelines.

A review of the 2004 Radioactive Effluent Release Report (NMC 2005e) confirmed that no liquid

waste was released from Monticello. A review of previous years release reports (NMC 2004a,

2003, 2002, 2001) also confirmed that no liquid effluents were released during normal

operations; however, abnormal releases occurred during this five-year period. For example, in

2nd Quarter 2003, one abnormal release of 904 liters of liquid effluent diluted with 66,600 liters

of water was released from Monticello. A total of 5.07 x 10"oqcuries (Ci) of fission and activation

products (with average diluted concentration of 7.61 x 10.' pCi/ml) and 1.06 x 10-3 Ci of tritium

(with average diluted concentration of 1.59 x 1 0" pCi/ml) were released. Since issuance of the

August 2006 2-9 NUREG-1437, Supplement 26 1
Description of Site and Environment

draft SEIS, NMC issued the effluent release report for 2005 (NMC 2006) and reported no

I abnormal liquid effluent releases during the calendar year.

Based on the system description above, design, and previous performance, no liquid effluents,

other than occasional abnormal releases, are expected from Monticello during the renewal

period. If abnormal releases were to occur, they would result in doses to members of the public

that are well below the dose design objectives of 10 CFR Part 50, Appendix I, as discussed in

Section 2.2.7.

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls

The gaseous radwaste system provides for sufficient off-gas holdup time to allow decay of the

short-lived radioisotopes (such as nitrogen-1 6 and oxygen-1 9) and fission product noble gases

(primarily xenon and krypton). The gaseous radwaste system also removes radioactive

particulates and iodine from the off-gas stream, and recombines radiolytic hydrogen and

oxygen to form liquid water to be treated in the liquid radwaste system. Radioactive gases are

then filtered and released through the plant off-gas stack. During normal operations, the

gaseous radwaste system operates on a continuous basis with effective monitoring and control

provided so as not to exceed the limits of 10 CFR Part 20 or the dose objectives of Appendix I

to 10 CFR Part 50 (NMC 2005b).

Off gas from the main condenser air ejector effluent passes through a 42-in. diameter delay line

and is stored in the compressed gas'storage system near the base of the off-gas stack. Five

compressed gas storage tanks, approximately 1250 ft3 each, provide for a minimum total

holdup time of approximately 50 hours at a design off-gas release rate of 28 standard cubic feet

per minute (scfm). For typical off-gas rate of 10 scfm, the holdup time could be as high as

140 hours. Off gases from the steam packing exhaust system, the mechanical vacuum pump

effluent, and the high-pressure coolant injection (HPCI) gland seal effluent are all collected and

processed in the steam packing exhauster off-gas subsystem. These gases are discharged on

a continuous basis into a 1.75-minute holdup line and mixed with the air ejector off-gases at the

stack base. The off-gas stack provides for mixing, dilution with fresh makeup air, monitoring,

and release of the off gas to the atmosphere at an elevation of 328 ft above ground. The stack

height and plume buoyancy aids in the dispersion of the gases into the atmosphere (NMC

2005b).

A review of the 2004 Radioactive Effluent Release Report (NMC 2005e) provided data on

radioactive effluent release rates for Monticello. For calendar year 2004, releases included

1371 Ci of fission and activation gases, 1.5 x 1 0- Ci of iodine-1 31, 1.2 x 10.3 Ci of particulates,

and 16.2 Ci of tritium. These activities are typical of past years, and are expected during the

renewal period. See Section 2.2.7 for a discussion of the theoretical doses to the maximally

exposed individual as a result of these releases. Since issuance of the draft SEIS, NMC issued

the effluent release report for 2005 (NMC 2006) and gaseous releases were consistent with

past years.

NUREG-1 437, Supplement 26 2-10 August 2006 1
Description of Site and Environment

2.1.4.3 Solid Waste Processing

The solid radwaste system is designed to process, package, store, monitor, and provide

shielded storage facilities for solid waste to allow for radioactive decay and/or temporary

storage prior to shipment from the plant for off-site disposal. The solid radioactive waste is

shipped off-site in vehicles equipped with adequate shielding to comply with Department of

Transportation (DOT) regulations. Radioactive solid waste generated from the plant includes:

process waste filter sludge and spent resins from the liquid processing systems; reactor system

spent control rod blades, temporary control curtains, fuel channels, and in-core ion chambers;

maintenance waste contaminated clothing, tools, rags and small pieces of equipment; operating

waste laundry cartridge filters, paper, rags, off-gas filters, and ventilation filters; and

miscellaneous solidified chemical and liquid wastes.

A rapid dewatering system (RDS) is a waste processing system installed for use at Monticello.

This self-contained system is used for accelerated dewatering of particulate waste material.

Extracted water from this system is routed to the liquid drains and subsequently routed back to

the plant for processing. Radioactive sludge from the RDS unit is stored in the radwaste

storage building and shipped offsite to a licensed facility in accordance with applicable DOT and

NRC regulations (NMC 2005b).

In 2004, Monticello made a total of five low-level waste shipments. The solid waste volumes

--were 3.41 m3 of spent resins, filter sludge, evaporator bottoms, etc., with an activity of

approximately 264 Ci; and 151 m3 of dry compressible waste, contaminated equipment, etc.,

with an activity of approximately 3.81 Ci. No irradiated components or control rods were

shipped. These solid waste volumes and radioactive material activity levels are typical of

annual waste shipments for Monticello and are not expected to increase during the renewal

period.

2.1.5 Nonradioactive Waste Systems

Nonradioactive liquid waste at Monticello consists of wastewater from lavatories, showers, and

sinks. These wastewaters are discharged from the Monticello sanitary sewer system to the City

of Monticello sanitary sewage disposal system. A lift station and forced main were installed in

1983 to connect the plant to the city system. Nonradioactive solid waste at Monticello consists

of hazardous waste (such as oils) and nonhazardous waste (such as office waste, garbage, and

demolition debris materials). The Nuclear Management Company, LLC (NMC), is required to

manage its hazardous waste in accordance with the Hazardous Waste Generator License from

the State of Minnesota Pollution Control Agency (MPCA).

2.1.6 Plant Operation and Maintenance

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

maintain the current licensing basis of the facility and to ensure compliance with environmental

August 2006 2-11 NUREG-1437, Supplement 26 1
Description of Site and Environment

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

while others require that the facility be shut down. Long-term outages are scheduled for

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

component. NMC refuels Monticello on a nominal 22- to 24-month fuel cycle. During refueling

outages, site employment increases by as many as 600 workers for temporary duty (NMC

2005a).

The updated safety analysis report (USAR) (NMC 2005b) regarding the effects of aging on

systems, structures, and components was included as part of the Monticello application for

renewal of its operating license (OL), in accordance with 10 CFR Part 54. Appendix A of the

application includes a supplement to the facility USAR that describes the programs and

activities that will manage the effects of aging during the license renewal period. NMC expects

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

or refueling and other outages, but plans no outages specifically for the purpose of

refurbishment. NMC does not plan to add additional full-time staff (non-outage workers) at

Monticello during the period of the renewed license.

2.1.7 Power Transmission System

The transmission corridors of concern for license renewal are the corridors that were

constructed for the specific purpose of connecting the plant to the electrical grid. Thus, for this

license renewal, the transmission lines subject to review are the Monticello-Coon Creek 345-kV

line and the Monticello-Parkers Lake 345-kV line (see Figure 2-5 and Table 2-1).

The Monticello-Coon Creek 345-kV line (Line #0991) exits the substation to the northeast and

continues 5.9 mi northwest to the Sherburne County Substation on a 240-ft wide easement (the

Sherburne County corridor). It then extends 37.2 mi to the southeast to connect to the Coon

Creek Substation on an easement that varies in width from 125 ft to 150 ft (Xcel Energy 2005a).

The original Monticello to Coon Creek Line was modified in 1975 to connect the Sherburne

County Generating Plant to the 345-kV system. The NRC addressed the configuration of the

Monticello to Coon Creek Substation line in its environmental review for the initial Monticello

operating license application.

The Monticello-Parkers Lake 345-kV line (Line #0978) exits the substation to the southeast on a

240-ft wide easement for approximately 23.8 mi and then continues approximately 13.3 mi on a

165-ft-wide easement to the Parkers Lake Substation (Xcel Energy 2005a). The line was

originally constructed to connect Monticello directly to Parkers Lake and was energized in 1971.

The NRC also addressed the line's impacts in its environmental review for the initial Monticello

operating license application. The Elm Creek Substation was installed on the MonticelloParkers Lake line in 1996 (NMC 2005a).

NUREG-1437, Supplement 26 2-12 August 2006 1
Description of Site and Environment

MONTICELLO 345-KV TRANSMISSION CORRIDORS

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August 2006 2-13 NUREG-1437, Supplement 26 1
Description of Site and Environment

Table 2-1. Monticello Transmission Line Rights-of-Way

No. of Approximate Corridor Corridor

Substation Lines kV Distance (mi) Corridor Width (ft) Area (ac)

Sherburne 1 345 43 Monticello-Coon Varies from 750

County Creek 125 to 240

Elm Creek 1 345 37 Monticello- Varies from 957

Parkers Lake 165 to 240

Source: Xcel Energy 2005a

Major portions of both corridors pass through rural areas, utilizing railroad rights-of-way and

highways where possible. The Monticello-Coon Creek corridor is predominantly cultivated fields

with scattered forests and some wetlands. The Monticello-Parkers Lake corridor is a mix of

agriculture, rural residential, scattered forests, and wetlands (NMC 2005a). Vegetation control

within the transmission line corridors is performed every four years to ensure the continued

reliability of the lines. Vegetation control includes removing or trimming woody vegetation to

ensure adequate line clearance and to allow vehicle access along the corridor. Qualified

line-clearance tree trimmers manually cut and prune using approved mechanical equipment

and perform selective application of approved herbicides to remove all tall-growing trees and

brush from the complete width of the corridor (Xcel Energy 2005b).

2.2 Plant Interaction with the Environment

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

background information. They also provide detailed descriptions where needed to support the

analysis of potential environmental impacts of refurbishment and operation during the renewal

term, as discussed in Chapters 3 and 4. Section 2.2.9 describes the historic and archaeological

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

Federal project activities.

2.2.1 Land Use

The Monticello site is located in the City of Monticello, Wright County, Minnesota, on the

southern bank of the Mississippi River. The nearest large city is St. Cloud, 22 mi northwest and

upstream of the Monticello site. The Twin Cities area of Minneapolis/St. Paul, and its

surrounding suburbs, is approximately 30 mi southeast and downstream of the site. This is the

largest urban area within 50 mi of the site exerting a strong influence on the region as the

surrounding cities and townships respond to the Twin City area's demand for suburban

development.

NUREG-1437, Supplement 26 2-14 August 2006 1
Description of Site and Environment

The Monticello site is located in an upland region of gently rolling hills dominated by rivers,

streams, and lakes. The site consists of approximately 2150 ac, with roughly 2 mi of frontage

on the north and south banks of the Mississippi River in Wright and Sherburne Counties. The

majority of the acreage is located on the southern side of the river, with approximately 450 ac

on the northern side of the river. Approximately 50 ac are occupied by the plant and its

supporting facilities. The remaining acres are undeveloped, with approximately 174 ac leased

by local farmers for growing row crops, and 144 ac under lease for recreational use (NMC

2005a).

2.2.2 Water Use

Monticello draws water from the Mississippi River for plant condenser cooling and auxiliary

water systems, such as service water cooling, intake screen wash, and fire protection. Under

typical river conditions, the circulating water system removes heat from the Monticello

condenser by the once-through circulating water system. Under certain discharge canal

temperature, river temperature, and river flow conditions, the circulating water system can

utilize the two mechanical draft cooling towers in partial or complete recirculation of the cooling

water in compliance with permit limits. The operating modes for the circulating water system

are required by the National Pollutant Discharge Elimination System (NPDES) permit discharge

* limits and the Surface Water Appropriations Permit. The Surface Water Appropriations Permit

allows NMC to withdraw up to 645 cfs (or 290,000 gpm) of water from the Mississippi River,

with special operating conditions if the river flow is less than 860 cfs, and further restrictions if

river flow is 240 cfs or less (see Table 2-2). The NPDES permit specifies maximum daily

average temperature at the end of the discharge canal depending on the month: 95°F in April

through October; 85 0F in November and March; and 80°F in December through February. The

operating modes and conditions are summarized in Table 2-2.

Five groundwater wells provide domestic water for potable use, including drinking water,

lavatories, and showers at the plant, and raw water to the reverse osmosis/make-up

demineralizer system which is used to produce purified water for the plant primary systems and

seal water to pumps located at the intake structure. Two wells, each equipped with a 1 00-gpm

capacity pump, are connected together and are regulated under a single water appropriations

permit with a withdrawal limit of 200 gpm. From 1998 to 2000, actual usage averaged less than

30 gpm. These two wells provide domestic potable water to the plant administration building,

raw water to the reverse osmosis/make-up demineralizer system, and seal water to pumps at

the plant intake structure. Two other wells, each equipped with a 45-gpm pump, provide

additional domestic water to a warehouse and the site administration building. The fifth well,

equipped with a 1 0-gpm pump, provides domestic water to a security training facility. Annual

usage for these wells is less than 1.9 gpm, for which water appropriation permits are not

required.

August 2006 2-15 NUREG-1437, Supplement 26 I
Description of Site and Environment

2.2.3 Water Quality

Potential environmental issues associated with water quality at the Monticello plant include

surface water quality in the Mississippi River. During 2002 and 2003, the MPCA conducted

stream assessments under Section 305b of the Clean Water Act to estimate the extent to which

Minnesota water bodies meet the goals of the Clean Water Act and attain state water quality

standards (MPCA 2004a). The Mississippi River in the area of the Monticello plant is identified

as impaired; however, the MPCA is still developing its strategy for addressing these findings.

Table 2-2. Circulating Water System Operating Modes

Operating Mode Temperature and River Flow Conditions

OPEN CYCLE OR ONCE-THROUGH: WHEN:

Water is withdrawn from and discharged directly to - Discharge canal temperature is below permit

the Mississippi River. limits, and

- River flow exceeds 860 cfs.

HELPER CYCLE: WHEN:

Water is withdrawn from and discharged directly to - Discharge canal temperature approaches permit

the Mississippi River. limits, and

Cooling towers cool water prior to discharge to the - Upstream river temperatures are consistently at

river. or above 680F.

PARTIAL RECIRCULATION: WHEN:

75% of the Mississippi River flow is withdrawn. - River flow is less than 860 cfs but greater than

Cooling towers are operating. A portion of the 240 cfs, and

cooled water is recirculated to the intake and the - River temperature is elevated.

remainder is discharged to the river.

Operating Mode Temperature and River Flow Conditions

CLOSED CYCLE: WHEN:

Cooling towers are operating and all cooled water is - River is at or less than 240 cfs, and

recirculated to the intake, except for cooling tower

blowdown, which is discharged to the discharge - River temperature is elevated.

canal.

Water quality discharges at Monticello are regulated by a NPDES permit with the MPCA. This

NPDES permit regulates effluent water quality to the Mississippi River and discharges from

certain in-plant processes. The NPDES permit also has monitoring, reporting, and permit limit

requirements on water quality parameters including chlorine, pH, temperature, total suspended

solids, oil and grease, and oxidants. Based on these monitoring reports, plant discharges are

NUREG-1437, Supplement 26 2-16 August 2006 1
Description of Site and Environment

typically within MPCA limits. Discharges from the Monticello sanitary sewer system to the City

of Monticello sanitary sewer system is covered under a separate permit with the City of

Monticello.

NMC applies biocides at the service water and circulating water pump bays located in the intake

structure to control biofouling in the circulating water system and service water systems. NMC

applies a non-oxidizing biocide at the service water header to control biofouling in several

service water systems that are only operated intermittently (residual heat removal service water,

emergency diesel generator service water, and fire water protection). NMC also applies

anti-scalant during warm summer months to control scale buildup in the condenser tubes. NMC

uses these approved chemicals in accordance with all the use and discharge requirements of

the NPDES permit.

2.2.4 Air Quality

The climate surrounding the Monticello site has wide seasonal variations in temperature, with

relatively light winter precipitation, and substantial summer rainfall. Representative weather

data was found at the nearby Buffalo, Minnesota, weather station located 10 mi southwest of

the plant. Average total annual precipitation is approximately 30 in. per year, with 54 percent

falling in the months of May through August. For the period of 1948-2004, rainfall ranged from

a monthly average high of 4.25 in. in June, to a monthly average low of 0.89 in. in December.

Average total annual snowfall is approximately 43 in. per year, with 94 percent falling in the

months of November through March. For the period of 1948-2004, the highest average

monthly snowfall was 9.6 in. in the month of January (HPRCC 2004).

Minnesota lies along the north edge of the region of maximum tornado occurrence in the United

States. Tornadoes have occurred in Minnesota in every month from March through November.

Nearly three quarters of all tornadoes in Minnesota have occurred during the three months of

May (16 percent), June (33 percent), and July (27 percent) (SCO 2004). Between 1950 and

2004, eighteen tornados were reported in Wright County (NMC 2005a). The tornado strike

probability for the Monticello Plant is approximately 6 x 10"4 (Ramsdell 2005).

The strongest winds typically occur in the early spring and the lightest winds in late summer.

The topography of the region is generally flat plains to rolling hills and uplands, with few

obstructions to wind. Wind energy potential is generally rated on a scale of Class 1 through

Class 7. The western part of Minnesota has Class 3 and 4 wind resources at exposed areas.

Areas suitable for wind turbine applications have a rating of 3 or higher. The wind power class

for the Monticello site is Class 2 (Elliot et al. 1987).

Nonradioactive air emissions from the Monticello site are regulated by the Minnesota Pollution

Control Agency. With respect to National Ambient Air Quality Standards (NAAQS), there are

currently no non-attainment areas in the state of Minnesota. In prior years, some areas of the

state have been designated non-attainment, but were later re-designated as attainment based

August 2006 2-17 NUREG-1437, Supplement 26 1
Description of Site and Environment

on improved air quality data. The most recent re-designation by U.S. Environmental Protection

Agency (EPA) became effective on September 24, 2002. Areas that were previously

non-attainment areas are now referred to as maintenance areas (MPCA 2005). The Monticello

plant is located in Wright County, a portion of which was in non-attainment for carbon monoxide

(CO) during the 1990s, and therefore continues to be a maintenance area for CO.

In 1997, the EPA revised the national standard for ground-level ozone from a 0.12 ppm 1-hour

"peak" standard to a 0.08 ppm 8-hour "average" standard, now commonly called the 8-hour

standard. In April 2004, EPA published the 8-hour ozone non-attainment designations, and

announced that the 1-hour "peak" standard will be phased out. The entire state of Minnesota is

in attainment with the new 8-hour ozone standard (EPA 2004).

There are no mandatory Class I Federal areas, in which visibility is an important value

designated in 40 CFR Part 81, within 100 mi of the Monticello site.

Diesel engines, a boiler, and other sources associated with the Monticello site emit various

nonradioactive air pollutants to the atmosphere, such as NOX, S02 and CO. Air emissions from

these sources are subject to the terms and conditions of a Title V air pollution control operation

permit issued by the MPCA (Air Emission Permit No. 17100019-003). The Monticello plant

must comply with the associated conditions of the permit, including fuel specifications, source

testing, emissions limitations, record-keeping, and reporting requirements. Plant compliance

with the air permit conditions has been good, and some minor compliance issues were*

successfully resolved in the mid-1990s. Permitted equipment with nonradioactive air emissions

at the facility includes:

A. EU 001 Boiler

B. EU 002 Diesel Generator 11

C. EU 003 Diesel Generator 12

D. EU 004 Security Diesel Generator

E. EU 005 Fire Pump Diesel Engine

F. EU 006 Diesel Generator 13

G. EU 007 Temporary Engine > 600 Hp

H. EU 008 Temporary Engine < 600 Hp

In calendar year 2003, the total annual NO, emission was 5.55-tons and the total annual CO

emission was 1.32 tons, while all other emission constituents were less than one ton (MPCA

2004b). There are no significant changes proposed for nonradioactive air emissions from the

NUREG-1 437, Supplement 26 2-18 August 2006 1
Description of Site and Environment

Monticello site, and there are no significant changes proposed to the limits and conditions of the

air permit.

2.2.5 Aquatic Resources

The principal aquatic resource in the vicinity of Monticello is the Mississippi River, which is the

source and receiving body of the water for the Monticello cooling system. The main aquatic

habitats on the Monticello site are the Mississippi River and the cooling-system discharge canal.

The discharge canal is approximately 1000 ft long by 200 ft wide at the surface, sloping down to

a width of 92 ft on the bottom. It is 18 ft deep at the center. In 1980, an overflow weir was

added to the discharge canal that closely approximates the shoreline of the Mississippi River.

The weir was added to minimize cold shock mortality from sudden plant shutdowns within the

discharge canal and in the river area adjacent to the discharge (MPCA 1979). It allows normal

outflow of water while reducing the movement of fish into the discharge canal (NMC 2005a).

The transmission lines associated with Monticello cross several streams and rivers. The

Monticello-Elm Creek-Parkers Lake line crosses Otter Creek, County Ditch #9, Crow River,

Rush Creek, and Elm Creek; while the Monticello-Sherburne County-Coon Creek line crosses

the Mississippi River, Elk River, St. Francis River, Tibbits Brook, Trott Brook, and the Rum

River. Transmission line right-of-way maintenance activities in the vicinity of stream and river

crossings employ procedures to minimize erosion and shoreline disturbance While encouraging

vegetative cover.

The Monticello plant facilities are located on the southern bank of the Mississippi River in

Wright County at Mississippi River Mile 900. Near Monticello, the Mississippi River is broad and

turbulent. The average river velocity varies from about 1.5 to 2.5 ft/s. The river 1.5 mi

upstream to 1.5 mi downstream of the plant loses 10 ft in elevation, resulting in rapids and

current velocities that exceed 4.9 ft/s (NMC 2005a). The main channel of the Mississippi River

is approximately 980 ft wide in the vicinity of the Monticello site. This portion of the river is also

shallow, averaging about 6.2 ft deep (Knutson et al. 1976). Within backwaters and protected

shoreline areas, the river is less than 2 ft deep with silt and mud substrates, whereas the main

channel substrates consist of gravel, rubble, and boulders with some sand (Afzal et al. 1975).

River flow past Monticello averages 7217 cfs, which meets the NRC's annual flow criterion for

classification as a small river. Flow has ranged from a minimum of 240 cfs to a maximum of

51,000 cfs. It exceeds 1100 cfs 90 percent of the time, and 300 cfs 99 percent of the time.

Ambient river temperature in summer averages 71 OF, while winter temperatures are at freezing

(32°F) (NMC 2005b).

A number of physical and chemical stresses have caused major changes and modifications to

the aquatic resources within the Upper Mississippi River Basin. Dams and six associated

headwater reservoirs occur on the Mississippi River between its headwaters at Lake Itasca and

St. Anthony Falls Lock and Dam (river mile [RM] 854) near the Twin Cities. However, as the

August 2006 2-19 NUREG-1437, Supplement 26 I
Description of Site and Environment

river is not used for commercial navigation above the Twin Cities, there are no locks on these

headwater dams (NMC 2005a). The Mississippi River in Minnesota is used for a variety of

purposes, including drinking water, industrial use, irrigation, recreation, tourism, and

conservation. The warm water discharges from Monticello provide year-round fishing

-opportunities at Montissippi County Park (the nearest point~of access to the river downstream

from Monticello) (NMC 2005a).

Fish consumption guidelines have been established in Minnesota due to the high leve~ls of

mercury and polychlorinated biphenyls (PCBs) found in some species (Minnesota Department

of Health 2005). The guidelines are more restrictive for pregnant women, women who may

become pregnant, and children under age 15 than for the general population. Consumption

guidelines exist within the reach of the Mississippi River that includes Monticello for various

species of sunfish, suckers, catfish, and other game fish mainly due to the presence of

mercury; although guidelines for common carp (Cyprinus carpio) and channel catfish (Ictalurus

punctatus) are also associated with potential PCB contamination (Minnesota Department of

Health 2005).

Despite the modifications and multiple competing uses of the Upper Mississippi River, the

overall fish biodiversity has been persistent and resilient (USGS 1999). In Minnesota,

75 species of fish have been reported within the upper portion of the Mississippi River (Hatch

and Schmidt 2004). Fifty-one species have been collected by electroshocking and seining in

the Monticello site vicinity (Xcel Energy 2004). The fish community in the Monticello area has

remained about the same since before the plant became operational, with only minor

differences occurring between areas upstream and downstream from the Monticello discharge

(Xcel Energy 2004). Among the 27 species collected by electroshocking, the major species

include the shorthead redhorse (Moxostoma macrolepidotum), silver redhorse (M. anisurum),

common carp, smallmouth bass (Micropterus dolomieu), northern hog sucker (Hypentelium

nigricans), white sucker (Catostomus commersont), channel catfish, and walleye (Sander

vitreus). The channel catfish was first collected in electroshocking samples in 1988, and has

been consistently collected since then (Xcel Energy 2004). Forty-four species have been

collected in seining samples since 1970. The major species collected included the sand shiner

(Notropis stramineus), spotf in shiner (Cyprinella spiloptera), bluntnose minnow (Pimephales

notatus), and bigmouth shiner (N. dorsalis) (Xcel Energy 2004).

The Monticello area is considered rough fish habitat due to the prevalence of shorthead

redhorse, silver redhorse, white sucker, and common carp (Afzal et al. 1975), The spotfin and

sand shiners are the major forage fish species in the area (Xcel Energy 2004); common game

species included smallmouth bass, black crappie (Pomoxis nigromaculatus), yellow perch

(Perca flavescens), and walleye. Other sport fish include northern pike (Esox lucius), common

carp, and black bullhead (Ameiurus melas) (Amish et al. 1978). There is no commercial fishery

near Monticello (Amish et al. 1978).

Some Mississippi River species such as quillback (Carpiodes cyprinus), gizzard shad

(Dorosoma cepedianum), lake sturgeon (Acipenser fulvescens), and paddlefish (Polyodon

NUREG-1437, Supplement 26 2-20 August 2006 1
Description of Site and Environment

spathula) were absent in the upper reaches of the Mississippi River due to river blockage at

St. Anthony Falls. However, the construction of St. Anthony Falls Lock and Dam in 1963

removed this barrier to fish passage. As a result, species such as channel catfish, flathead

catfish (Pylodictis olivaris), gizzard shad, northern hog sucker, golden redhorse (Moxostoma

erythrurum), and white crappie (Pomoxis annularis) now occur above St. Anthony Falls. The

Coon Rapids Dam (RM 866), located approximately 12 mi upstream from St. Anthony Falls,

remains a barrier to upstream movement; although some fishes can circumvent the dam at

times (e.g., during floods) (Hatch et al. 2003). This may account for the presence of channel

catfish, northern hog sucker, white crappie, and, most recently, flathead catfish near Monticello.

The major primary producers within the Monticello area are periphyton. The periphyton

community consists of diatoms, blue-green algae, green algae, and golden algae; periphyton

contributes an estimated 60 to 82 percent of the primary production in the Monticello area.

Nearly 150 species of periphyton were collected near Monticello between 1968 and 1976, and

were dominated by diatom species throughout the year. During the summer, blue-green algae

were co-dominant with diatoms (Amish et al. 1978). Peak periphyton production occurs in

summer. Species composition was found to be similar between preoperational and operational

years (Amish et al. 1978). Phytoplankton is generally not abundant in flowing waters. Most of

the phytoplankton that occurs in the main river channel originates from backwater areas and

from periphyton scour. Phytoplankton in the Upper Mississippi River is dominated by diatoms

and green algae, and contributes 18 to 40 percent of the primary productivity in the Monticello

area (Amish et al. 1978).

Between 1968 and 1970, the only macrophytes found in the immediate area near Monticello

were the American pondweed (Potamogeton nodosus), sago pondweed (Stuckenia pecinatus),

and antifever fontinalis moss (Fontinalis antipyretica). The macroscopic green alga Cladophora

glomerata also occurs in the area. Overall, macrophytes abundance is low in the Monticello

area due to fast-moving currents and shifting sand and gravel substrates (Amish et al. 1978).

Zooplankton populations are limited within the main channel of the Mississippi River near

Monticello due to high gradients. Near Monticello, the zooplankton community is comprised of

protozoans, rotifers, cladocerans, and copepods (Afzal et al. 1975; Amish et al. 1978).

The benthic macroinvertebrate community near Monticello includes oligochaetes (aquatic

annelid worms), mayflies, caddisflies, aquatic beetles, midges, black flies, aquatic snails, and

fingernail clams (Amish et al. 1978). The non-channel areas of the Upper Mississippi River

consistently support more species than the main channel area (USGS 1999). Near Monticello,

66 genera of macroinvertebrates were collected in the backwaters, while only 24 genera were

collected from the main channel (Amish et al. 1978).

The Upper Mississippi River contains a rich assemblage of freshwater mussels. Historically, as

many as 50 species of mussels have been documented from the Upper Mississippi River, but

only 30 species have been reported in recent surveys. Many are rare (e.g., listed as

endangered, threatened, or of special concern by one or more states [USGS 1999]). The

August 2006 2-21 NUREG-1437, Supplement 26 1
Description of Site and Environment

freshwater mussels within the Upper Mississippi River have been adversely impacted by

activities such as collection for the pearl button and cultured pearl industries, siltation

(associated with agriculture, poor land management, and impoundments), pollution from

agriculture and industrial chemicals, establishment and maintenance of the navigation channel,

dams, loss of appropriate fish host species, and competition from exotic species, particularly

the non-native zebra mussel (Dreissena polymorpha) (USGS 1999; Weitzell et al. 2003).

The range of some mussel species has been expanding above St. Anthony Falls as fish hosts

for mussel glochidia (ectoparasitic larvae of native freshwater mussels) can now circumnavigate

the two navigation locks at this location (Kelner and Davis 2002). Approximately 13 mussel

species currently occur upstream of St. Anthony Falls (Siteman 2003). Only six species were

recently collected above Coon Rapids Dam: white heelsplitter (Lasmigona complanata), giant

floater (Pyganodon grandis), plain pocketbook (Lampsilis cardium), fatmucket (Lampsilis.

siliquoidea), black sandshell (Ligumia recta), and pink heelsplitter (Potamilus alatus) (Kelner

and Davis 2002). No information on mussel species within the immediate area of Monticello is

available.

The zebra mussel became established in the Upper Mississippi River by 1992 and has

continued to spread throughout the river system. Its increase causes a decline among many

native mussels, as it can out-compete native species for oxygen and food and is so prolific that

it can smother native mussel beds (FWS 2001). Until recently, populations of the zebra mussel

within the Mississippi River had not been observed above the Twin Cities area (St. Anthony .

Falls Lock and Dam) (MNDNR 2005). They were not observed between RM 854 and RM 848

(Pool 1) and were found to be sparse between RM 848 and RM 797 (pools 2 and 3) (Kelner and

Davis 2002). However, in October 2005, it was reported that zebra mussels had been found in

Rice Lake, an impoundment of the Mississippi River, in Brainerd, Crow Wing County,

Minnesota (MNDNR 2006). Brainerd is about 94 mi upstream of Monticello. The Asiatic clam

(Corbicula fluminea), another invasive mollusc species that can cause condenser tube clogging

problems, has been found at the Monitcello site (e.g., in the discharge canal), but was not

observed in the traveling screen forebays that were recently dredged (NMC 2006).

Few Federally or State-listed aquatic species are known to occur in the four counties in which

Monticello and the related transmission lines of concern occur (i.e., Wright, Sherburne,

Hennepin, and Anoka counties) (see Table 2-3). No Federally or State-listed fish species have

been collected from the Mississippi River near the Monticello site (Xcel Energy 2004). The

Higgins' eye pearlymussel (Lampsilis higginsii) is the only Federally listed aquatic species

reported from the four-county area (Hennepin County), and this species is both Federally and

State-listed as endangered (FWS 2005a,c). Two State-listed mussel species of special

concern (MNDNR 2005), the creek heelsplitter (Lasmigona compressa) and black sandshell,

have been reported downstream from the Monticello site within the Coon Rapids Pool of the

Mississippi River and within the Rum River in the. Hennepin and Anoka counties area (Kelner

and Davis 2002).

NUREG-1 437, Supplement 26 2-22 August 2006 1
Description of Site and Environment

-Table 2-3. Threatened or Endangered Aquatic Species Potentially Occurring in the

Vicinity of Monticello and the Associated Transmission Corridors

Status(a)

Scientific Name Common Name Minnesota U.S.

Lampsilis higginsii Higgins' eye pearlymussel E E

Lasmigona compressa creek heelsplitter SPC

Ligumia recta black sandshell SPC

Source: FWS 2005a,c; MNDNR 2005; Kelner and Davis 2002

(a)E = endangered, SPC = species of concern,'- = no listing.

The Higgins' eye pearlymussel was Federally listed as an endangered species on

June 14, 1976 (FWS 1976). It is only found in the Mississippi River, the St. Croix River in

Wisconsin, the Wisconsin River, and the Rock River in Illinois. It was never abundant,

historically comprising approximately 0.5 percent of the mussel population. At the time the

original recovery plan was written in 1982, the Higgins' eye pearlymussel had undergone a

53 percent decrease in its known range (FWS undated). The Higgins' eye pearlymussel most

frequently occurs in medium to large rivers with current velocities of approximately 0.5 to

1.5 ft/s and in depths of 3 to 20 ft, with firm, coarse sand or mud-gravel substrates (FWS 2000,

2001). It is generally found in mussel beds with at 16ast 15 other species present

(Hornbach 2004).

Much of the historic habitat for the Higgins' eye pearlymussel has been altered from a

free-flowing river system to an impounded river system. This has altered flow patterns,

substrates, and fish host habitats and movements (FWS 2001). Other impacts to the species

have included water quality degradation from municipal, industrial, and agricultural run-off;

dredging; waterway traffic; and, particularly, zebra mussels (FWS 2004a; Hornbach 2004).

No critical habitat has been designated for the Higgins' eye pearlymussel. However, ten

Essential Habitat Areas (EHAs) for the Higgins' eye pearlymussel occur within the Upper

Mississippi River watershed. EHAs are locations known to contain reproducing populations of

the Higgins' eye pearlymussel in association with a healthy and diverse unionid community

(e.g., mussel beds) (Hornbach 2004). No EHAs within the Mississippi River occur close to the

Monticello site (RM 900). The most upstream area is at Whiskey Rock, Iowa, (RM 656) which

is over 240 RM downstream of the Monticello site. However, three EHAs occur in the St. Croix

River, which flows into the Mississippi River at RM 811, downstream from Lock and Dam 2

(Hornbach 2004). The furthest upstream Essential Habitat Area on the St. Croix River is the

only EHA that is free of zebra mussels (Hornbach 2004).

Suitable fish hosts for the glochidia of the Higgins' eye pearlymussel include freshwater drum

(Aplodinotus grunniens), largemouth bass (Micropterus salmoides), black crappie, yellow perch,

sauger (Sander canadensis), and walleye; while marginal fish hosts include northern pike,

bluegill (Lepomis macrochirus), and green sunfish (L. cyanellus) (Hornbach 2004).

August 2006 2-23 NUREG-1 437, Supplement 26 1
Description of Site and Environment

In 2000-2001, an empty Higgins' eye pearlymussel shell was collected from Upper Pool 3

(RM 815) of the Mississippi River (near the area where the St. Croix River enters the Mississippi

River) (Kelner and Davis 2002). Since 2000, individual Higgins' eye pearlymussels have been

transplanted from areas near Cassville, Wisconsin, and Cordova, Illinois, to Pools 2 and 3 near

Minneapolis and Hastings, Minnesota, respectively. Additionally, cleaning of mussels infested

with zebra mussels and artificial propagation and release have been conducted to alleviate the

effects of zebra mussels on the Higgins' eye pearlymussel (Hornbach 2004).

The State-listed creek heelsplitter is a widespread but generally uncommon species. It

generally occurs in fine gravel or sand substrates of small- or medium-sized rivers (NPS 2004).

Host fish species for the creek heelsplitter include the spotf in shiner, guppy (Poecilia reticulata),

slimy sculpin (Cottus cognatus), black crappie, and yellow perch (NPS 2004). It is most

common, but seldom abundant, in headwater streams (Siteman 2003).

The black sandshell, which is also State-listed, is a widespread but generally uncommon

species. It occurs in medium to large rivers, in gravel or firm sand substrates (NPS 2004).

Host fish species include common carp, green sunfish, bluegill, largemouth bass, rock bass

(Ambloplites rupestris), and white crappie (NPS 2004). It can be common to abundant where it

occurs (Siteman 2003).

2.2.6 Terrestrial Resources

The plant site comprises approximately 2150 ac and has roughly 2 mi of shoreline on the north

and south banks of the Mississippi River in Wright and Sherburne counties (NMC 2005a,b).

The Monticello site is located in an upland region of low relief dominated by rivers, streams, and

lakes (NMC 2005a). Land use within the region is primarily agricultural; therefore, natural

deciduous climax vegetation communities previously found within the city limits of Monticello

have been reduced to remnant patches of maple (Acer spp.), basswood (Ti/ia americana), elm

(Ulmus spp.), oak (Quercus spp.), and hackberry (Celtis occidentalis). These remnants are

restricted mostly to larger river islands and small isolated pockets along the river banks (AEC

1972). Prior to European settlement, the southern sections of the Upper Mississippi River

Basin, where Monticello and its associated transmission line corridors are located, were a mix

of prairie, wetland prairie, oak woodland, brushland, and maple-basswood forest (MPCA 2000).

Terrestrial habitats on the Monticello site include formerly cultivated fields in various stages of

ecological succession, with remnant climax hardwood forest in isolated pockets along the river

and on the larger islands, and some actively cultivated fields (AEC 1972). Of the 2150 ac

encompassed by the Monticello site, the majority of acreage is located on the southern side of

the Mississippi River, with approximately 450 ac on the northern side of the river (NMC 2005a).

Approximately 50 ac are developed and occupied by the Monticello plant and supporting

facilities, with an additional 174 ac leased to local farmers for row crop production (NMC

2005a). Approximately 144 ac are leased for recreational purposes, while the remainder is

undeveloped.

NUREG-1437, Supplement 26 2-24 August 2006 1
Description of Site and Environment

The terrestrial habitats near the Monticello site support a variety of plant and animal species

that are typical of free-flowing, upper-midwestern rivers (NMC 2005a). In general, facilities in

use at the Monticello site are located on previously cultivated areas and consist of early

succession forbs and grasses. Upland forests on the Monticello site are predominately

northern pin oak (Quercus ellipsoidalis), green ash (Fraxinus pennsylvanica), basswood, and

prickly ash (Zanthosxylum americanum). Forested wetlands on the northeast bank of the river

and the river islands include American elm (Ulmus americana), box elder (Acer negundo), silver

maple (A. saccharinum), cottonwood (Populus deltoides), and black willow (Salix nigra) (MCBS

1998).

MNDNR has identified the following native plant communities as occurring on the Monticello

site: floodplain forest, silver maple-Virginia creeper floodplain forest, bur oak woodland, oak

woodland brushland, willow swamp, dry oak savannah, and dry prairie. Representative

localities are as follows: the floodplain forest community is known to occur on the northeast

bank of the Mississippi River and on the portion of the Monticello site in Wright County. The

silver maple-Virginia creeper floodplain forest community is found to occur on Cedar Island

(NMC 2005a). Patches of bur oak woodland community occur south and west of the power

block (Hoffman 2004). Two patches of oak woodland brushland occur adjacent to the river in

Sherburne county (Hoffman 2004; Delaney and Epp 1993; MNDNR 1993). The willow swamp

community, dominated by shrubby willow (Salix spp.), occurs on Oxbow Island located on the

north side of the Mississippi River and downstream of the station. An area of dry oak savannah

occurs on the Sherburne County side of the site, on the first terrace north of the Mississippi

River (NMC 2005a). An area of dry prairie occurs to the west of the power block on the narrow

sloping area between the railroad right-of-way and the Mississippi River (NMC 2005a).

Extensive farming, logging, and grazing have occurred throughout these plant communities,

which are, therefore, much changed from the original climax condition (AEC 1972). There are

no public waters or wetlands Within the Monticello site that are designated as protected under

Minnesota Statute 103G.005 (MNDNR 1983, 1984, 2004a), although the U.S. Fish and Wildlife

Service (FWS) National Wetland Inventory indicated that wetlands exist along the Mississippi

River and on islands as seasonally flooded patches of scrub-scrub, deciduous forest, and

emergent vegetation (DOI 1991).

Mammals typical of the area and identified within the Monticello site include white-tailed deer

(Odocoileus virginianus), red fox ( Vulpes vulpes), raccoon (Procyon lotor), red squirrel

(Tamiasciurus hudsonicus), grey squirrel (Sciurus carolinensis), short-tailed shrew (Blarina

brevicauda), southern red-backed vole (Cleithrionomys gappen), meadow vole (Microtus

pennsylvanicus), mice (Peromyscus spp.), pocket gopher (Geomys bursarius), white-tailed

jackrabbit (Lepus townsendii), beaver (Castor canadensis), muskrat (Ondatra zibethicus), gray

fox (Urocyon cinereoargenteus), coyote (Canis latrans), fox squirrel (Sciurus niger), chipmunk

(Tamias striatus), mink (Mustela vison), weasels (Mustela frenata, M. erminea, M. nivalis), and

striped skunk (Mephitis mephitis) (AEC 1972; NMC 2005b).

August 2006 2-25 NUREG-1437, Supplement 26 1
Description of Site and Environment

Furthermore, the Sherco Environmental Monitoring and Ecological Studies Program identified

99 avian species over a ten-year monitoring period during breeding season road transects

surveys and in a floodplain near the Monticello site. The most abundant species observed

during these surveys were mourning dove (Zenaida macroura), cliff swallow (Petrochelidon

pyrrhonota), barn swallow (Hirundo rustica), American robin (Turdus migratorius), European

starling (Sturnus vulgaris), vesper sparrow (Pooecetes gramineus), red-winged blackbird

(Agelaius phoeniceus), common grackle (Quiscalus quicula), American goldfinch (Carduelis

tristis), and house sparrow (Passer domesticus). Game species commonly harvested within the

vicinity of Monticello are ruffed grouse (Bonasa umbellus), grey partridge (Perdix perdix) and

ring-necked pheasant (Phasianus colchicus) (NMC 2005a). Waterfowl commonly encountered

along the river shoreline are Canada goose (Branta canadensis), mallard (Anas platyrhynchos),

and wood duck (Aix sponsa). Grassland/woodland ecotone avian species include eastern

meadowlark (Stumella magna), western meadowlark (Stumella neglecta), American robin, blue

jay (Cyanocitta cristata), eastern bluebird (Sialia sialis), northern flicker (Colaptes auratus),

red-tailed hawk (Buteojamaicensis), and American kestrel (Falco sparverius) (NMC 2005a).

Two transmission lines in two corridors that are within scope of the license renewal review

originate from the Monticello site. These are discussed in Section 2.1.7. Major portions of both

corridors pass through rural areas, utilizing railroad.rights-of-way (ROW) and highways where

possible. The Monticello-Coon Creek corridor is predominantly cultivated fields with scattered

forests and some wetlands. The Monticello-Parkers Lake corridor is a mix of agriculture, rural

residential, scattered forests, and wetlands (NMC 2005a). MNDNR identified native plant

communities of significant biodiversity. associated with transmission corridors, as shown in

Table 2-4. The majority of transmission corridors are adjacent to the areas where native plant

communities occur and do not traverse them (NMC 2005a).

There are no Federally designated critical habitats for threatened or endangered species within

the Monticello site or along the associated transmission corridors (FWS 2004b). The FWS has

designated 13 species known to occur in Minnesota as threatened or endangered, and 4

species known to occur in the state have been designated as candidates for such listing.

However, only 2 of these species, the bald eagle (Haliaeetus leucocephalus) and the gray wolf

(Canis lupus) are indicated by the FWS as potentially occurring on or in the vicinity of the site or

transmission lines associated with Monticello (Table 2-5) (FWS 2005c).

The bald eagle, listed as Federally threatened, is known to occur in the vicinity of the Monticello

site. Originally listed as endangered by the FWS in 1967, the bald eagle was down-listed to

threatened in 1995, and is currently proposed for delisting (Hoff mann 2004). The State's first

bald eagle survey in 1973 found 115 active nests; by 1995 the survey found over 600

(NMC 2005a). MNDNR has concluded that Minnesota's bald eagle population is growing slowly

but is at a healthy level (MNDNR 2004b). Bald eagles are typically associated with forested

areas near rivers and lakes where nest sites are readily available near food sources. One nest

site is known to occur just north-northwest of the power block on Beaver Island (NMC 2005a).

One additional nest occurs on a transmission tower on the Monticello-Coon Creek transmission

line.

NUREG-1437, Supplement 26 2-26 August 2006 1
Description of Site and Environment

Table 2-4. State of Minnesota Identified Natural Communities in the Vicinity of the

Transmission Corridors

Site Biodiversity

General Location Communities Significance

WRIGHT COUNTY

Immediately south of Monticello-ROW Dry prairie High

passes through area

SHERBURNE COUNTY

Approximately 3 mi northeast of Monticello Alder swamp Moderate

and south of the Thompson Lake Rich fen

Area-ROW adjacent to southernmost edge Dry oak savanna

of area

Approximately 4 mi northeast of City of Elk Oak forest High

River-ROW adjacent to southwest corner Mixed hardwood swamp

of area Alder swamp

Tamarack swamp

Willow swamp

Approximately 1 mi northeast of City of Elk Oak forest Moderate

River-ROW adjacent to northern

boundary of area

ANOKA COUNTY

Approximately 3.5 mi southwest of Andover Oak forest Outstanding

and immediately west of Bunker Hills Dry oak savanna

Regional Park-ROW runs through area

Approximately 1 mi south of Andover along Dry oak savanna High

State Highway 78-ROW is adjacent to Dry prairie

area

HENNEPIN COUNTY

Approximately .5 mi north of intersection of Maple-basswood forest High

1-494 and Highway 9 in Plymouth-ROW

adjacent to area

Source: Hoffman 2004

August 2006 2-27 NUREG-1437, Supplement 26 1
Description of Site and Environment

Table 2-5. Threatened or Endangered Terrestrial Species Potentially Occurring in

the Vicinity of Monticello and the Associated Transmission Corridors

Status(a)

Scientific Name Common Name Minnesota U.S.

Birds

Haliaeetus leucocephalus bald eagle SPC T

Lanius ludovicianus loggerhead shrike T

Falco peregrinus peregrine falcon' T

Cygnus buccinator trumpeter swan T

MAMMAL

Canis lupus gray wolf T

REPTILE

Emydoidea blandingii Blanding's turtle T

INSECT

Hesperia uncas Uncas skipper E

PLANT

Scleria triglomerata tall nut-rush E

'

8IE = endangered, T = threatened, SPC = species of concem, - = no listing.

The-gray wolf was listed in Minnesota as Federally endangered in 1974 as a result of human

persecution and reduced prey availability. Gray wolves in Minnesota were reclassified from

endangered to threatened in 1978, to allow for special regulation under Section 4(d) of the

Endangered Species Act. Since 1977, gray wolf populations in Minnesota have expanded.

Population recovery goals of 1250 to 1400 individuals have been achieved, with populations at

or above that level since the late 1970s (FWS 2005e). Today, wolves live in areas with higher

road and human densities than previously believed to be suitable for wolf survival. Wolves

continue to disperse to areas in west-central and east-central Minnesota (just north of

Minneapolis/St. Paul), North and South Dakota, and Wisconsin (FWS 2005e). As gray wolf

populations recover, it is likely that they will be within the vicinity of transmission corridors of

interest to the license renewal of Monticello. However, gray wolves have not been sighted in

the Monticello area to date.

The MNDNR has determined that the peregrine falcon (Falco peregrinus), loggerhead shrike

(Lanius ludovicianus), and trumpeter swan (Cygnus buccinator) are known to occur within the

vicinity of Monticello and associated transmission line corridors (MNDR 2004c). All of these

species are listed as threatened by the State of Minnesota. With the installation of a nest box

on the Monticello Off Gas Stack in 1992, peregrine falcons have been breeding successfully at

the site since 1995 (NMC 2005a). The loggerhead shrike, a grassland and open-land species,

is known to occur on site and in the vicinity of Monticello. It has been documented in several

areas along the transmission corridors in Anoka and Sherburne counties (NMC 2005a).

NUREG-1437, Supplement 26 2-28 August 2006 1
Description of Site and Environment

Trumpeter swans are increasing in numbers on the Mississippi River, and wintering swans

readily use open water associated with warm water discharged to the river and available food

(NMC 2005a).

One State-listed threatened reptile, the Blanding's turtle (Emydoidea blandingih), is documented

by MNDNR as occurring in the vicinity of the transmission corridors in Anoka and Sherburne

counties. In Sherburne County, the transmission corridor passes through land classified by

MNDNR as "known concentration areas" of Blanding's turtles. There are fifteen known areas

throughout Minnesota (Hoffman 2004).

A State-listed endangered butterfly, the Uncas skipper (Hesperia uncas), is documented by

MNDNR as occurring in the vicinity of the transmission corridor in Sherburne County (Hoffmann

2004). Uncas skippers are associated with xeric prairies and open woodlands, which are

declining due to fire suppression and natural forestation (Hoff 2000).

The tall nut-rush (Scleria triglomerata), a State-listed endangered species, occurs in the vicinity

of the transmission corridor that passes through Bunker Hills Regional Park. Tall nut-rush is

associated with dry or moist sandy ground in prairies and in the borders of marshes

(Hoffmann 2004).

2.2.7 Radiological Impacts

Monticello conducts an annual REMP in and around the Monticello site and publishes an

Annual Radiological Environmental Operating Report (NMC 2005d). Through this program,

radiological impacts to employees, the public, and the environment are monitored, documented,

and compared to the appropriate standards. The objectives of the REMP are the following:

Provide representative measurements of radiation levels and radioactive materials in the

exposure pathways and of the radionuclides that have the highest potential for radiation

exposures to members of the public; and

Supplement the radiological effluent monitoring program by verifying that the measurable

concentrations of radioactive materials and levels of radiation are not higher than expected

on the basis of effluent measurements and the modeling of the environmental exposure

pathways.

Radiological releases are summarized in two Monticello reports: the Annual Radiological

Environmental Operating Report (NMC 2005d) and the Radioactive Effluent Release Report

(NMC 2005e). The limits for all radiological releases are specified in the Monticello ODCM

(NMC 2004b), and these limits are used to meet Federal standards and requirements. The

REMP includes monitoring of the waterborne environment (ground, water, and shoreline

sediment); airborne environment (airborne radioiodine, gross beta, and gamma); ingestion

pathways (milk, fish and invertebrates, and food products); and direct radiation. The REMP

August 2006 2-29 NUREG-1 437, Supplement 26 1
Description of Site and Environment

I found that there were no indications of radiological effects of Monticello on the environment

(NMC 2005d).

A review of historical data on releases from Monticello and the resultant dose calculations

revealed that the calculated doses to maximally exposed individuals in the vicinity of Monticello

were a small fraction of the limits specified in the Monticello ODCM (NMC 2004b) to meet

10 CFR Part 50, Appendix I design objectives, 10 CFR Part 20 dose limits, and EPA radiation

standards in 40 CFR Part 190. For 2004, dose estimates were calculated based on actual

liquid and gaseous effluent release data and conservative models to simulate the transport

mechanisms. The results are described in the 2004 Radioactive Effluent Release Report (NMC

2005e). A breakdown of the calculated maximum dose to an individual located at the Monticello

boundary from liquid and gaseous effluents released during 2004 is summarized as follows:

" The maximum whole-body dose to offsite member of the general public from liquid effluents

was 1.94 x 10"10 mrem, well below the 3 mrem dose design objective in 10 CFR Part 50,

Appendix I.

* The maximum whole-body dose to the likely most exposed member of the general public

from gaseous effluents was 0.022 mrem, well below the 5 mrem dose design objective in

10 CFR Part 50, Appendix I.

The applicant does not anticipate any significant changes to the radioactive effluent releases or

exposures from Monticello operations during the renewal period and, therefore, the impacts to

the environment are not expected to change.

2.2.8 Socioeconomic Factors

2.2.8.1 Housing

Approximately 414 permanent employees and 105 contract and matrixed employees work at

Monticello (NMC 2005a). Approximately 41 percent of these employees live in Wright County,

32 percent live in Sherburne County, 7.5 percent live in Hennepin County, and 7.5 percent live

in Stearns County. The remaining employees (approximately 12 percent) live in various other

locations (NMC 2005a). Given the predominance of NMC and NSP employees living in Wright

County and Sherburne County, as well as the absence of the likelihood of significant

socioeconomic effects in other locations, the focus of the analysis undertaken in this

supplemental environmental impact statement (SEIS) are on these counties.

I NMC refuels Monticello on a nominal 22- to 24-month cycle. During refueling outages, site

employment increases by as many as 600 temporary workers for 30 to 40 days. Many of these

workers are assumed to be temporarily located in the same geographic areas as the permanent

staff.

NUREG-1437, Supplement 26 2-30 August 2006 1
Descfiption of Site and Environment

Table 2-6 provides the number of housing unit vacancies for Wright and Sherburne counties for

1990 and 2000, the latest year for which information is available.

Table 2-6. Housing Units and Housing Units Vacant (Available) by County During

1990 and 2000

Approximate Percentage

1990 2000 Change

WRIGHT COUNTY

Housing Units 26353 34355 30

Occupied Units 23013 31465 37

Vacant Units 3340 2890 -14

SHERBURNE COUNTY

Housing Units 14964 22827 53

Occupied Units 13643 21581 58

Vacant Units 1321 1246 -6

Sources: USCB 1990, 2000b

2.2.8.2 Public Services

* Water Supply

This discussion of public water systems focuses on Wright and Sherburne counties because.

the majority of Monticello employees reside in these counties (NMC 2005a). Local

municipalities provide public potable water service to residents who do not have individual

onsite wells. These providers are subject to regulation under the Federal Safe Drinking Water

Act, as implemented by the State of Minnesota Department of Health.

• Description of Site and Environment

Most water systems in the two-county area are operating below maximum capacity.

Portions of both Wright and Sherburne counties are experiencing significant population growth,

and several municipal water systems (Elk River, Joint Powers Water Board, and Otsego) are

responding by increasing capacity with additional wells (EPA 2005).

Table 2-7 provides the details of Wright and Sherburne counties' respective water suppliers

and capacities.

August 2006 2-31 NUREG-1437, Supplement 26
Description of Site and Environment

Table 2-7. Major Public Water Supply Systems in Wright and Sherburne

Counties

Maximum Daily Average Daily

Water System Capacity (ftis) Capacity (ftW/s)

WRIGHT COUNTY

Annandale 2.67 0.39

Buffalo 8.47 1.86

Cokato 2.23 0.53

Delano 3.34 0.62

Howard Lake 1.34 0.16

Joint Powers 13.14 2.74

Board System

Maple Lake 0.67 0.26

Monticello 12.13 1.72

Montrose 2.45 0.23

Otsego 8.91 0.48

Rockford 5.46 0.62

SHERBURNE COUNTY

Becker 1.86 0.39

Big Lake 8.91 0.81

Elk River 12.25 5.73

Zimmerman 1.11 0.6

Source: NMC 2005a

• Education

In 2002, 19,991 students attended Wright County mainstream public schools and 15,156

students attended Sherburne County mainstream public schools (NCES 2005). Although the

region's two school districts do not keep track of the number of Monticello employees' children

attending district schools, it is likely that they are served by these schools because a majority of

these employees live in Wright and Sherburne counties.

NUREG-1 437, Supplement 26 2-32 August 2006 1
Description of Site and Environment

* Transportation

Road access to Monticello is south of the power block via Wright County Road 75, a two-lane

paved road that runs roughly parallel to Interstate 94 in the vicinity of the site. Interstate 94

runs northwest from Minneapolis and passes within a mile southwest of the site. Access points

to the Interstate are approximately 4 mi to the southeast and 6 mi to the northwest of the site, at

the State Highway 25 intersection in Monticello and the Wright County Road 9 intersection,

respectively. Access to Sherburne County is via the State Highway 25 bridge in the City of

Monticello, approximately 3.5 mi to the south, and the State Highway 24 bridge at Clearwater,

approximately 11 mi to the north. The Minnesota Department of Transportation (MDOT) does

not normally calculate and keep up-to-date Level of Service (LOS) determinations for either

state or county roadways; however, LOS information based on threshold values developed by

MDOT for use in District Long Range Transportation Plans was available for State Highways 24

and 25 and Interstate 94 in Wright County. LOS determinations were made for current traffic

volumes and with the addition of 60 additional vehicles assumed for license renewal. Results

reveal that these roadways could accommodate the demand represented by the NMC bounding

estimate for additional employees during the renewal term without a noticeable effect on level of

service. MDOT long-term future plans (10 to 20 year time frame) included adding capacity to

1-94 in the area and constructing a new river crossing that would improve conditions on

Highway 24.

Table 2-8 lists roadways in the vicinity of Monticello and the average number of vehicles per.

day, as determined by MDOT (2002).

Table 2-8. Traffic Counts for Roads in the Vicinity of Monticello

Annual Average Daily

Roadway and Location Traffic

WRIGHT COUNTY

State Highway 25 from bridge south to 1-94 22600

State Highway 25 from 1-94 south 6.6 mri 14200

1-94 east of Highway 24 39000

1-94 adjacent to the Monticello site 4800

1-94 in the City of Monticello 45400

State Highway 24 from 1-94 south 5500

Wright County Road 8 north of 1-94 1700

Wright County Road 8 south of 1-94 1500

Wright County Road 75 south of State Highway 24 1850

Wright County Road 75 in vicinity of Enfield 1050

August 2006 2-33 NUREG-1437, Supplement 26
Description of Site and Environment

Table 2-8. (contd)

Annual Average Daily

Roadway and Location Traffic

SHERBURNE COUNTY

State Highway 24 bridge to Wright County Road 52 15500

State Highway 24 from Wright County Road 52 to State 12800

Highway 10

Highway 25 bridge 31300

Highway 25 north of bridge 0.5 mi 16200

Source: MDOT 2002

2.2.8.3 Offsite Land Use

In order to accommodate and regulate growth and development, Wright and Sherburne

counties have developed county-specific comprehensive growth management plans which

encourage growth in areas that can be served by existing infrastructure, while preserving open

space and environmentally sensitive areas. Sherburne County's plan was adopted in

December 1992 and updated in 2004. Wright County's plan was adopted in May 1988. Land

use planning and zoning regulations are primarily developed by the cities and towns within

Wright and Sherburne counties. Therefore, land use standards may vary greatly in different

regions within the counties. Neither county implements growth control measures that limit

residential housing development. As shown in Tables 2-9 and 2-10, land is available for new

housing developments in both Wright and Sherburne counties.

Table 2-9. Land Use in Wright County, 1980s

Land Use Acres Percent of Total

Cultivated fields 242280 52

Residential (urban or rural) 73890 16

Forest 63740 14

Water bodies 29600 6

Pasture and open land 28360 6

Marsh/wetland 17170 4

Urban and misc. 7680 2

Total 462720 100

Source: Wright County 1988

NUREG-1 437, Supplement 26 2-34 August 2006 1
Description of Site and Environment

Table 2-10. Land Use in Sherburne County, 1991

Land Use Acres Percent of

Total

Residential 14440 5

Commercial/industrial 1240 0.5

Incorporated areas 39990 13.5

Agriculture 73700 26

Open lands designated for environmental 34100 12

protection and not available for

development

Open lands available for development 122530 43

Total 286000 100

Source: Sherburne County 1992

Thirteen of the sixteen cities in Wright County have developed comprehensive land use plans

and guide growth and development in their communities through zoning subdividison

ordinances. The three cities that do not have active planning programs are the smallest in the

county (MDEED 2005a). Residential growth has been strongest in the northeastern cities, and

-the. United States Census Bureau (USCB) estimates show that Wright County was the 60th

fastest growing county in the nation for the period of 2000 to 2003 (USCB 2004). Agriculture is

*the predominant land use in the county, accounting for 52 percent of total acreage (Wright

County 1988).

Wetlands are an important natural resource in Wright County and development of associated

flood prone areas is restricted. Preservation of farmland is a.major concern and goal of

planning efforts, as Wright County contains approximately 337,240 ac of farmland that the

State of Minnesota classifies as either prime or of statewide importance, based on soil quality,

growing season, and moisture supply characteristics (Wright County 1988).

Sherburne County encompasses less land area than Wright County. Four of the six cities in

Sherburne County have developed comprehensive land use plans. The two that do not have

active planning programs are the smallest in the county (MDEED 2005b). Residential growth

has been the strongest in the southeastern cities and eastern townships, and the USCB

estimates show that Sherburne County is the 30th fastest growing county in the nation for the

period of 2000 to 2003 (USCB 2004). Open land is the county's largest land use category,

accounting for 43 percent of the county's total land area (Sherburne County 1992).

Wetlands are also an important natural resource in Sherburne County, and development is

restricted by county, State and Federal regulations. Only a small percentage of Sherburne

County is characterized by the State as prime farmlands or of statewide importance; however,

August 2006 2-35 NUREG-1437, Supplement 26 1
Description of Site and Environment

preservation of farmland and/or the rural character of the county is a major concern and goal of

planning efforts in Sherburne County (Sherburne County 1992).

Sherco, a coal-fired plant also owned by Xcel Energy, is the closest industrial facility on the

Mississippi river. Over 4500 ac comprise the Sherco site, the majority of which are leased for

agricultural purposes.

Numerous public recreational and natural areas are located within 50 mi of the Monticello site.

Federal properties include 35 ac owned by the National Park Service in the Mississippi National

River and Recreation Area, as well as three Federal wildlife refuges. Three State parks, three

State forests, eighteen State Scientific and Natural Areas, and numerous State wildlife

management areas are also located within a 50-mi radius of the Monticello site (NMC 2005a).

2.2.8.4 Visual Aesthetics and Noise

Monticello is situated on the north and south banks of the Mississippi River in Wright and

Sherburne counties. The local terrain is level to gently undulating. The area around Monticello

is largely small residential communities, farmland and forest. There are two 9-cell cooling

towers and one 328-foot-high off-gas stack on the site. The Monticello site is visible from the

highway along its border. The off-gas stack is visible from the local community. The majority of

the physical plant is not visible from the local communities. Noise has not been considered -a

problem due to:the plant's distance from other communities.

2.2.8.5 Demography

Census data from 2000 found at the USCB website and geographic information system

software (ArcView) were used to determine demographic characteristics in the Monticello

vicinity. NRC guidance calls for the use of the most recent USCB decennial census data,

which, in the case of publication of the NMC ER (NMC 2005a), was the 2000 Census.

Population was estimated from the Monticello site out to 50 mi.

As derived from 2000 USCB information, approximately 166,860 people live within 20 mi of

Monticello. Applying the GElS sparseness measures, Monticello has a population density of

133 persons/mi2 within 20 mi of the plant, and therefore falls into Category 4 of NRC's GElS

sparseness classification. The City of Buffalo is the largest city in Wright County and has a

population of 10,097 persons (USCB 2000a). As estimated from 2000 USCB information,

approximately 2,740,995 people live within 50 mi of Monticello. This equates to a population

density of 349 persons/mi2 within 50 mi, and falls into Category 4 of NRC's GElS proximity

classification.

According to the GElS sparseness and proximity matrix, the ranking (sparseness Category 4

and proximity Category 4), indicates that Monticello is located in a high-population area. All or

parts of 21 counties are located within 50 mi of the plant.

NUREG-1437, Supplement 26 2-36 August 2006 1
Description of Site and Environment

The Minneapolis-St. Paul-Bloomington, Minnesota-Wisconsin Metropolitan Statistical Area

(MSA), which lies partially within a 50-mi radius of the plant, includes eleven Minnesota

counties: Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Ramsey, Scott, Sherburne,

Washington, and Wright. This MSA also includes two Wisconsin counties: Pierce and

St. Croix. It is the 16th most populated MSA, with a current total population of approximately

2,968,806 (USCB 2000a). The St. Cloud, Minnesota MSA is entirely within Monticello's 50-mi

radius and includes both Benton and Stearns counties. It is the 22nd most populated MSA,

with a current total population of approximately 167,392 (USCB 2000a). From 1970 to 2000,

Minnesota's average annual population growth rate was 0.9 percent, while the average annual

population growth rates of Wright and Sherburne Counties were 2.8 percent and 4.3 percent,

respectively (USCB 2000a).

In 2000, Minnesota reported a population count of 4.92 million people (USCB 2000a), or

1.75 percent of the U.S. population, ranking 21st in population among the 50 states and the

District of Columbia. By the year 2030, Minnesota is projected to have 6.27 million residents

and remain the 21st most populous state (USCB 2000a). Between the years 2000 and 2030,

Wright and Sherburne counties are projected to grow at average annual rates of 1.8 percent

and 2.97 percent, respectively (Sherburne County 2004).

Table 2-11. shows estimated populations and annual growth rates (1980 to 2040) for Wright and

Sherburne counties, Minnesota, the counties with the greatest potential to be socioeconomically

affected by license renewal activities at Monticello.

Table 2-11. Estimated Populations and Average Annual Growth Rates in Wright and

Sherburne Counties from 1970 to 2040

Wright County Sherburne County

Year Population Percent(a) Population Percent(')

1970 38933 --- 18344 ---

1980 58681 4.19 29908 5.01

.1990 68710 1.59 41945 3.44

2000 89986 2.73 64417 4.38

2010 109700 2 86320 2.97

2020 126420 1.43 105620 2.04

2030 139020 0.95 121920 1.45

2040 152876 0.95 140736 1.45

Sources: Years 1970 through 1990, USCB 1990; Year 2000, USCB 2000a; Years 2010

through 2030, MPSDC 2002; Year 2040 is a projection using previous decade's rate of growth.

(a) Annual percent growth rate calculated using the equation N[t] = N[o] (1+r)t where N is

population, t is time in years, and r is the annual growth rate expressed as a decimal.

August 2006 2-37 NUREG-1437, Supplement 26 I
Description of Site and Environment

2.2.8.6 Economy

The economy within a 50-mi radius of Monticello is dominated by the cities of St. Paul and

Minneapolis. The Minneapolis/St. Paul metropolitan area has an economic employment profile

led by services (29.6 percent), manufacturing (16.4 percent), trade (23.9 percent), government

(11.6 percent), construction (4.2 percent), transportation and public utilities (5.5 percent),

agriculture (1 percent), and finance, insurance and real estate (7.8 percent).

The annualized unemployment rate for the state of Minnesota in June 2005 was 3.9 percent. In

June 2005, Wright County had an unemployment rate of 3.5 percent and Sherburne County

had an unemployment rate of 3.8 percent (MDEED 2005c). The major employment facilities

within 10 mi of Monticello are listed in Table 2-12. The estimated per capita household income

in Minnesota in 2000 was $23,198. Wright and Sherburne counties had estimated per capita

household incomes of $21,844 and $21,322, respectively (USCB 2000b).

In 2002 there were over 251,832 ac of farmland in Wright County, with an estimated market.

value of $92,839,000. Within Wright County, major crops consisted of corn (8,573,296

bushels); wheat (90,974 bushels); barley (24,578 bushels); oats (67,850 bushels); soybeans

(2,249,289 bushels); and hay (90,307 tons, dry). A total of 178,451 ac were planted, with an

average farm size of 171 ac (Cornell 2004).

Table 2-12. Major Employment Facilities Within 10 mi of the Monticello Site

Number of

Employer Employees

Outlet Mall at Albertville 800

Progressive Contractors, Inc. 540

Buffalo Public Schools 514

Wright County Government 450

Monticello Public Schools 450

Monticello-Big Lake Hospital 432

Xcel Energy 792

Wal-Mart 890

Guardian Angels Care Center 372

Great River Energy 316

Source: MTED 2004, NMC 2005a

In 1997 there were over 105,042 ac of farmland in Sherburne County, with an estimated market

value of $42,760,000. Major crops consisted of corn (3,106,412 bushels); wheat (6,477

bushels); oats (22,423 bushels); sunflowers (38,800 pounds); soybeans (505,869 bushels); and

NUREG-1437, Supplement 26 2-38 August 2006 1
Description of Site and Environment

hay (19,276 tons, dry). A total of 66,029 ac were planted in 1997, with an average farm size of

205 ac (Cornell 2004).

Monticello paid between $7.95 million and $12.22 million in property taxes each year between

1998 and 2002, which accounted for approximately 11 percent of the property taxes collected

over this period (see Table 2-13).

Table 2-13. Property Taxes Paid from 1998 to 2002; Monticello Contribution to County

Property Tax Revenues

Property Tax Paid by Percent of Total

Year Total Revenues ($) Monticello ($) Property Taxes

WRIGHT COUNTY(')

1998 46199186 3201300 6.9

1999 48271892 2915700 6

2000 51180648 2834800 5.5

2001 56286501 2692600 4.8

2002 59680999 2019300 3.4

CITY OF MONTICELLO(b)

1998 9395052 2803500 29.8

1999 9639772 3222200 33.4

2000 12320300 3166500 25.7

2001 12463189 3145300 25.2

2002 13782998 3384700 24.6

SCHOOL DISTRICT 8 8 2 (b)

1998 N/A 6222300 N/A

1999 28056186 5725500 20.4

2000 30032343 5425700 18.1

2001 33301451 5445300 16.4

2002 35555509 1856200 5.2

STATE GENERAL TAX(b)

2002 12211949000 691600 < 1

Source: (a)Havala, Robert, Wright County Auditor-Treasurer. Personal communication, 2005. (b)Wolfsteller, Rich, City of Monticello. Personal communication, 2005.

August 2006 2-39 NUREG-1437, Supplement 26 I
Description of Site and Environment

2.2.9 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological

resources at the Monticello site and surrounding area. Information was obtained from review of

previous work conducted at the facility, consultations with the Minnesota State Historic

Preservation Office (MNSHPO), and reports of recent cultural resource work conducted in

Wright County.

2.2.9.1 Cultural Background

The basic prehistoric cultural framework for central Minnesota is broadly divided into three

periods based upon patterns documented in the archaeological record (Minnesota State

Museum 2005). The earliest time period when people were known to have been in the region is

referred to as the Paleoindian Period (10,000 B.C. to 6000 B.C.). The economy is thought to

have centered on big game hunting. Finely made projectile points such as Clovis and Folsom

are characteristic of this period.

During the Archaic Period (6000 B.C. to 500 B.C.), settlement in the general area increased

significantly. The economy also changed, as Archaic peoples lived as semi-nomadic hunters

and gatherers, exploiting a much greater range of local resources than people had previously.

The diversity of tools used similarly increased.

The final prehistoric period is referred to as the Woodland 'Period (500 B.C. to A.D.1 750), which

is marked by several changes in prehistoric life. The people made extensive use of burial

mounds during this time, some complex and containing many grave goods. Earthenware.

pottery is also characteristic of the period. Evidence also reveals an increase in plant cultivation

and a more sedentary way of life compared to earlier periods.

In the mid-1 7th century, when European explorers and fur traders began arriving in the region,

the area was mostly occupied by Dakota Indians. The French initially claimed the land, sold it

to Spain in 1762, repurchased it in 1800, and sold it to the United States in 1803 as part of the

Louisiana Purchase. In the mid-1 7th century, people of Ojibwe tribal descent began moving

westward into the area, in some cases causing conflict with the resident Dakota tribes. The

Minnesota Territory formed in 1849, Indian Treaties were agreed to in 1850, and statehood was

achieved in 1858 (Blegan 1975; Folwell 1956).

Settlers, mostly of German and Swedish descent, began arriving in present-day Wright County

in the 1850s to farm. Settlement increased following the Civil War, stimulated by the arrival of

the railroad. Farming continued to dominate the local economy into the modern era

(Farnham 1976).

NUREG-1 437, Supplement 26 2-40 August 2006 1
Description of Site and Environment

2.2.9.2 Historic and Archaeological Resources at the Monticello Site

An archaeological records and literature search was conducted at the MNSHPO to identify

important resources that may be located in the area of potential effect. The area of potential

effect is defined by the NRC as the plant and its immediate environs. The plant is located on

the Mississippi River in an area typically considered to have high potential for archaeological

sites, and the area is known in Minnesota's early Indian and fur trade history.

The Final Environmental Statement (FES) for Monticello identified several properties within a

10-mi radius listed on the National Register of Historic Places, but none within the proposed

plant boundaries (AEC 1972; NSP 1971). The MNSHPO determined that there were no known

archaeological or architectural sites known in the immediate vicinity of the plant (Fridlay 1971).

Since the original FES was published, additional cultural resource work in the area has

confirmed the presence of cultural and historic resources in the vicinity of Monticello. No

resources have been identified within the plant boundaries, however, and none are anticipated

because of the disturbance created by the construction of the plant, as documented by aerial

photographs (Bloomberg 2005). Based on the absence of input from tribes with current or

historical ties to the region, no traditional cultural properties are believed to be located within the

area of potential effect. A review of plat maps from 1894, 1901, 1915, and 1931 housed at the

Minnesota State Historical Museum Library indicated that parts of the Monticello site were

owned as early as 1894. By 1915, the parcels had been purchased by Mississippi River

Electric Power Co., which planned to construct a dam at this location.

2.2.10 Related Federal Project Activities and Consultations

The staff reviewed the possibility that activities of other Federal agencies might impact the

renewal of the OL for Monticello Nuclear Generating Plant. Any such activities could result in

cumulative environmental impacts and the possible need for the Federal agency to become a

cooperating agency for preparation of the SEIS.

The Mississippi National River and Recreation Area is located approximately 20 mi from the

Monticello site. The park's boundaries enclose approximately 54,000 ac and 72 mi of river that

extend in a narrow corridor along the river from Dayton to Hastings, Minnesota. The National

Park Service owns 35 ac (NPS 2005).

Sherburne National Wildlife Refuge is located approximately 9 mi to the northeast of the

Monticello site. This refuge is 30,700 ac and its primary mission is to represent a diverse

biological community characteristic of the transition zone between tall-grass prairie and forest.

It also provides resting, nesting and feeding habitat for waterfowl and other migratory birds,! and

habitat for resident wildlife (FWS 2005b).

August 2006 2-41 A NUREG-1437, Supplement 26 I
Description of Site and Environment

The Minnesota Valley National Wildlife Refuge is located approximately 41 mi from the

Monticello site. The refuge comprises 14,000 ac stretching for 34 mi from Fort Snelling State

Park to Jordan, Minnesota. The Minnesota Valley National Wildlife Refuge also manages

fourteen county Wetland Management Districts (WMDs). This refuge assists in restoring

wetland and prairie habitats, and is a well-known area for bird watching (FWS 2005d).

Crane Meadows National Wildlife Refuge was established in 1992 to preserve a large, natural

wetland complex. The 1825-ac refuge is located approximately 58 mi from the Monticello site,

and is an important stop for many migrating bird species. It harbors one of the largest nesting

populations of greater sandhill cranes in Minnesota. The refuge also serves as the base for the

Federal private lands program in Morrison County, which focuses on restoring drained wetlands

through voluntary agreements with landowners (FWS 2005f).

The NRC is required under Section 102(2)(c) of the National Environmental Policy Act of 1969

to consult with and obtain the comments of any Federal agency that has jurisdiction by law or

special expertise with respect to any environmental impact involved. The NRC consulted with

the FWS. Consultation correspondence is included in Appendix E.

2.3 References

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Protection Against Radiation."

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Meet the Criterion 'As Low as is Reasonably Achievable' for Radioactive Materials in

Light-Water-Cooled Nuclear Power. Reactor Effluents."

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing

of Production and Utilization Facilities."

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

Renewal of Operating Licenses for Nuclear Power Plants."

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing

Requirements for Land Disposal of Radioactive Waste."

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"Environmental Radiation Protection Standards for Nuclear Power Operations."

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"Designation of Areas for Air Quality Planning Purposes."

NUREG-1437, Supplement 26 2-42 August 2006 1
Description of Site and Environment

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Accessed at: http://midwest.fws.gov/cranemeadows on June 7, 2005.

U.S. Fish and Wildlife Service (FWS). Undated. Higgins' Eye Pearly Mussel Recovery. U.S.

Fish and Wildlife Service, Rock Island, Illinois. Accessed at:

http://www.fws.gov/midwest/Rocklsland/activity/endangered/higgins.htm on August 12, 2005.

U.S. Geological Survey (USGS). 1999.. Ecological Status and Trends of the Upper Mississippi

River System 1998: A Report of the Long Term Resource Monitoring Program. U.S.

Geological Survey, Upper Midwest Environmental Sciences Center, La Crosse, Wisconsin.

TRMP 99-TOO1. Accessed at:

http://www.umesc.usgs.gov/reports-publications/statusand_trends.html on February 21, 2003.

U.S. Nuclear Regulatory Commission (NRC). 1998. Monticello Nuclear Generating Plant -

Draft Environmental Assessment Related to Issuance of Amendment R.E. Power Uprate

Program (TAC M96238). Office of Nuclear Reactor Regulation. Washington, D.C.

January 21, 1998.

Weitzell, R.E., Jr., M.L. Khoury, P. Gagnon, B. Schreurs, D. Grossman, and J. Higgins. 2003.

Conservation Priorities for Freshwater Biodiversity in the Upper Mississippi River Basin. Nature

Serve and The Nature Conservancy, Arlington, Virginia. Accessed at:

http://www.natureserve.org/library/uppermsriverbasin.pdf on June 17, 2005.

Wright County. 1988. Wrighit County Land Use Plan.

Xcel Energy Environmental Services (Xcel Energy). 2004. Monticello Nuclear Generating Plant

Environmental Monitoring Program 2002 - 2003 Report. Prepared by Xcel Energy

Environmental Services for Northern States Power Company, Minneapolis, Minnesota.

NUREG-1437, Supplement 26 2-50 August 2006 1
Description of Site and Environment

Xcel Energy Environmental Services (Xcel Energy). 2005a. E-mail correspondence from

P. Rasmussen to J. Holthaus at Monticello documenting transmission corridor lengths and

widths. E-mail dated June 29, 2005.

Xcel Energy Environmental Services (Xcel Energy). 2005b. "Vegetation Management

Guidelines." March 2005.

August 2006 2-51 NUREG-1 437, Supplement 26 I

3.0 Environmental Impacts of Refurbishment

Environmental issues associated with refurbishment activities are discussed in the Generic

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

Volumes 1 and 2 (NRC 1996, 1 999).(a) The GElS includes a determination of whether the

analysis of the environmental issues could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GElS, Category 1 issues are those that meet all of

the following criteria:

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

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

system or other specified plant or site characteristics.

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

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

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

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

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

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

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

required in this supplemental environmental impact statement (SEIS) unless new and

significant information is identified.

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

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

License renewal actions may require refurbishment activities for the extended plant life. These

actions may have an impact on the environment that requires evaluation, depending on the type

of action and the plant-specific design. Environmental issues associated with refurbishment

that were determined to be Category 1 issues are listed in Table 3-1.

Environmental issues related to refurbishment considered in the GElS for which these

conclusions could not be reached for all plants, or for specific classes of plants, are Category 2

issues. These are listed in Table 3-2.

Category 1 and Category 2 issues related to refurbishment that are not applicable to Monticello

because they are related to plant design features or site characteristics not found at Monticello

are listed in Appendix F.

('a The GElS was originally issued in 1996. Addendum I to the GElS was issued in 1999. Hereafter, all references

to the "GEIS" include the GElS and its Addendum 1.

August 2006 3-1 NUREG-1437, Supplement 26 1
Environmental Impacts of Refurbishment

Table 3-1. Category 1 Issues for Refurbishment Evaluation

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1

GElS Sections

SURFACE-WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Impacts of refurbishment on surface-water quality 3.4.1

Impacts of refurbishment on surface-water use 3.4.1

AQUATIC ECOLOGY (FOR ALL PLANTS)

Refurbishment 3.5

GROUND-WATER USE AND QUALITY

Impacts of refurbishment on ground-water 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 3.7.4; 3.7.4.3;

recreation 3.7.4.4; 3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

The potential environmental effects of refurbishment actions would be identified, and the

analysis would be summarized within this section, if such actions were planned. NMC indicated

that it has performed an evaluation of structures and components pursuant to 10 CFR 54.21 to

identify activities that are necessary to continue operation of Monticello during the requested

20-year period of extended operation. These activities include replacement of certain

components as well as new inspection activities and are described in the Environmental Report

(ER) (NMC 2005).

However, NMC stated that the replacement of these components and the additional inspection

activities are within the bounds of normal plant component replacement and inspections;

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

operations as evaluated in the final environmental statement (AEC 1972). In addition, NMC's

evaluation of structures and components as required by 10 CFR 54.21 did not identify any

major plant refurbishment activities or modifications necessary to support the continued

operation of Monticello beyond the end of the existing operating licenses. Therefore,

refurbishment is not considered in this SEIS.

NUREG-1437, Supplement 26 3-2 August 2006 1
Environmental Impacts of Refurbishment

Table 3-2. Category 2 Issues for Refurbishment Evaluation

10 CFR

ISSUE-10 CFR Part 51, Subpart A, 51.53(c)(3)(ii)

Appendix B, Table B-1 GElS Sections 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 3.3 F

(nonattainment and maintenance areas)

SOClOECONOMICS

Housing impacts 3.7.2 I

Public services: public utilities 3.7.4.5 1

Public services: education (refurbishment) 3.7.4.1 1

Offsite land use (refurbishment) 3.7.5 1

Public services: transportatiorn 3.7.4.2 J

Historic and archeological resources" 3.7.7 K

ENVIRONMENTAL JUSTICE

Environmental justice Not addressed(a) Not addressed(a)

(0) Guidance related to environmental justice was not in place at the time the GElS and the

associated revision to 10 CFR Part 51 were prepared. If an applicant plans to undertake

refurbishment activities for license renewal, environmental justice must be addressed in the

licensee's environmental report and the staff's environmental impact statement.

3.1 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

August 2006 3-3 NUREG-1437, Supplement 26 I
Environmental Impacts of Refurbishment

Nuclear Management Company (NMC). 2005. Applicant's Environmental Report--Operating

License Renewal Stage, Monticello Nuclear Generatin-g Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Monticello Nuclear Generating Plant, Northern States Power Company. Docket

No. 50-263, Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

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

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

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

NUREG-1437, Supplement 26 3-4 August 2006 1
4.0 Environmental Impacts of Operation

Environmental issues associated with operation of a nuclear power plant during the renewal

term are discussed in the Generic Environmental Impact Statement for License Renewal of

Nuclear Plants (GELS), NUREG-1 437, Volumes 1 and 2 (NRC 1996, 1999).Ca) The GElS

includes a determination of whether the analysis of the environmental issues could be applied

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

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

issues are those that meet all of the following criteria:

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

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

system or other specified plant or site characteristics.

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

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

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

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

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

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

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

required unless new and significant information is identified.

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

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

This chapter addresses the issues related to operation during the renewal term that are listed in

Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B

and are applicable to the Monticello Nuclear Generating Plant (Monticello). Section 4.1

addresses issues applicable to the Monticello cooling system. Section 4.2 addresses issues

related to transmission lines and onsite land use. Section 4.3 addresses the radiological

impacts of normal operation, and Section 4.4 addresses issues related to the socioeconomic

impacts of normal operation during the renewal term. Section 4.5 addresses issues related to

groundwater use and quality, while Section 4.6 discusses the impacts of renewal-term

operations on threatened and endangered species. Section 4.7 addresses potential new

information that was raised during the scoping period, and Section 4.8 discusses cumulative

impacts. The results of the evaluation of environmental issues related to operation during the

renewal term are summarized in Section 4.9. Finally, Section 4.10 lists the references for

Chapter 4. Category 1 and Category 2 issues that are not applicable to Monticello because

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

to the "GELS" include the GElS and its Addendum 1.

August 2006 4-1 NUREG-1437, Supplement 26.
Environmental Impacts of Operation

they are related to plant design features or site characteristics not found on the Monticello site

are listed in Appendix F.

4.1 Cooling System

Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, that are applicable

to the Monticello cooling system operation during the renewal term are listed in Table 4-1.

Nuclear Management Company (NMC) stated in its Environmental Report (ER) (NMC 2005a)

that it is not aware of any new and significant information associated with the renewal of the

I Monticello operating license (OL) that would warrant additional, plant-specific analysis of the

remaining applicable Category 1 issues. The staff has not identified any new and significant

information during its independent review of the NMC ER, the staff's site visit, the scoping

I process, its evaluation of other available information, or public comments on the draft

I Supplemental Environmental Impact Statement (SEIS). Therefore, the staff concludes that

there are no impacts related to these issues beyond those discussed in the GELS. For all of

these issues, the staff concluded in the GElS that the impacts are SMALL, and additional plantspecific mitigation measures are not likelyto be sufficiently beneficial to be warranted.

A brief description of the staff's review and the GElS conclusions, as codified in Table B-i, for

each of these issues follows:

Altered current patterns at intake and discharge structures. Based on information in the

GELS, the Commission found that

Altered current patterns have not been found to be a problem at operating

nuclear power plants and are not expected to be a problem during the license

renewal term.

The staff has not identified any new and significant information during the staff's

I independent review of the NMC ER, the scoping process, the staff's site visit, its

evaluation of other available information, or public comments on the draft SEIS.

Therefore, the staff concludes that there are no impacts of altered current patterns at

intake and discharge structures during the renewal term beyond those discussed in the

GELS.

Temperature effects on sediment transport capacity. Based on information in the GELS, the

Commission found that

These effects have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

NUREG-1 437, Supplement 26 4-2 August 2006 1
Environmental Impacts of Operation

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

Cooling System During the Renewal Term

ISSUE-b10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered current patterns at intake and discharge structures 4.2.1.2.1

Temperature effects on sediment transport capacity 4.2.1.2.3

Scouring caused by discharged cooling water 4.2.1.2.3

Eutrophication 4.2.1.2.3

Discharge of chlorine or other biocides 4.2.1.2.4

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4

Discharge of other metals in wastewater 4.2.1.2.4

Water use conflicts (plants with once-through cooling systems) 4.2.1.3

AQUATIC ECOLOGY (FOR ALL PLANTS)

Accumulation of contaminants in sediments or biota 4.2.1.2.4

Entrainment of phytoplankton and zooplankton 4.2.2.1.1

Cold shock 4.2.2.1.5

Thermal plume barrier to migrating fish 4.2.2.1.6

Distribution of aquatic organisms 4.2.2.1.6

Premature emergence of aquatic insects 4.2.2.1.7

Gas supersaturation (gas bubble disease) 4.2.2.1.8

Low dissolved oxygen in the discharge 4.2.2.1.9

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

Losses from predation, parasitism, and disease among organisms 4.2.2.1.10

exposed to sublethal stresses

Stimulation of nuisance organisms 4.2.2.1.11

AQUATIC ECOLOGY (FOR PLANTS WITH COOLING TOWER-BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life stages 4.3.3

Impingement of fish and shellfish 4.3.3

Heat shock 4.3.3

TERRESTRIAL RESOURCES

Cooling tower impacts on crops and ornamental vegetation 4.3.4

Cooling tower impacts on native plants 4.3.5.1

Bird collisions with cooling towers 4.3.5.2

HUMAN HEALTH

Microbiological organisms (occupational health) 4.3.6

Noise 4.3.7

August 2006 4-3 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

I information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of temperature effects on sediment transport capacity during the renewal term

beyond those discussed in the GELS.

Scouring caused by discharged cooling water. Based on information in the GELS, the

Commission found that

Scouring has not been found to be a problem at most operating nuclear power

plants and has caused only localized effects at a few plants. It is not expected to

be a problem during the license renewal term.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

I information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of scouring caused by discharged cooling water during the renewal term beyond those discussed in the GELS.

* Eutrophication. Based on information in the GELS, the Commission found that

Eutrophication has not been found to be a problem at operating nuclear power

plants and is not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

I information, including plant monitoring data and technical reports, or public comments on the

I draft SEIS. Therefore, the staff concludes that there are no impacts at intake and discharge

structures during the renewal term beyond those discussed in the GELS.

* Discharge of chlorine or other biocides. Based on information in the GELS, the Commission

found that

Effects are not a concern among regulatory and resource agencies, and are not

expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

information, including the National Pollutant Discharge Elimination System (NPDES) permit for

Monticello, or public comments on the draft SEIS. Therefore, the staff concludes that there are

no impacts of discharge of chlorine or other biocides during the renewal term beyond those

discussed in the GELS.

NUREG-1437, Supplement 26 4-4 August 2006 1
Environmental Impacts of Operation

Discharge of sanitary wastes and minor chemical spills. Based on information in the GElS,

the Commission found that

Effects are readily controlled through NPDES permit and periodic modifications,

if needed, and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

information, including the NPDES permit for Monticello and the Sanitary Sewer Wastewater

Discharge Agreement, or public comments on the draft SEIS. Therefore, the staff concludes

that there are no impacts of discharges of sanitary wastes and minor chemical spills during the

renewal term beyond those discussed in the GELS.

* Discharge of other metals in wastewater. Based on information in the GELS, the

Commission found that

These discharges have not been found to be a problem at operating nuclear

power plants with cooling-tower-based heat dissipation systems and have been

satisfactorily mitigated at other plants. They are not expected to be a problem

during the license renewal term.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

information, including the NPDES permit for Monticello, or public comments on the draft SEIS.

Therefore, the staff concludes that there are no impacts of discharges of other metals in

wastewater during the renewal term beyond those discussed in the GELS.

* Water use conflicts (plants with once-through cooling systems). Based on information in

the GELS, the Commission found that

These conflicts have not been found to be a problem at operating nuclear power

plants with once-through heat dissipation systems.

The staff has not identified any new and significant information during the staff's independent

review of the NMC ER, the scoping process, the staff's site visit, its evaluation of other available

information, including the NPDES permit and the Surface Water Appropriations Permit, or

public comments on the draft SEIS. Therefore, the staff concludes that there are no impacts of

water-use conflicts for plants with once-through cooling systems during the renewaf term

beyond those discussed in the GELS.

* Accumulation of contaminants in sediments or biota. Based on information in the GElS, the

Commission found that

August 2006 4-5 NUREG-1437, Supplement 26 I
Environmental Impacts of Operation

Accumulation of contaminants has been a concern at a few nuclear power plants but

has been satisfactorily mitigated by replacing copper alloy condenser tubes with those of

another metal. It is not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of available information, or

I public comments on the draft SEIS. Therefore, the staff concludes that there are no impacts of

accumulation of contaminants in sediments or biota during the renewal term beyond those

discussed in the GELS.

Entrainment of phytoplankton and zooplankton. Based on information in the GElS, the

Commission found that

Entrainment of phytoplankton and zooplankton has not been found to be a

problem at operating nuclear power plants and is not expected to be a problem

during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of entrainment of phytoplankton and zooplankton during the renewal term

beyond those discussed in the GELS.

* Cold shock. Based on information in the GELS, the Commission found that

Cold shock has been satisfactorily mitigated at operating nuclear plants with

once-through cooling systems, has not endangered fish populations or been

found to be a problem at operating nuclear power plants with cooling towers or

cooling ponds, and is not expected to be a problem during the license renewal

term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

I information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of cold shock during the renewal term beyond those discussed in the GELS.

• Thermal plume barrier to migrating fish. Based on information in the GELS, the Commission

found that

Thermal plumes have not been found to be a problem at operating nuclear

* power plants and are not expected to be a problem during the license renewal

term.

NUREG-1437, Supplement 26 4-6 August 2006 1
Environmental Impacts of Operation

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of thermal plume barriers to migrating fish during the renewal term beyond

those discussed in the GELS.

0 Distribution of aquatic organisms. Based on information in the GELS, the Commission found

that

Thermal discharge may have localized effects but is not expected to effect the

larger geographical distribution of aquatic organisms.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts on distribution of aquatic organisms during the renewal term beyond those

discussed in the GELS.

* Premature emergence of aquatic insects. Based on information in the GElS, the

Commission found that

Premature emergence has been found to be a localized effect at some operating

nuclear power plants but has not been a problem and is not expected to be a

problem during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of premature emergence of aquatic insects during the renewal term beyond

those discussed in the GELS.

* Gas supersaturation (gas bubble disease). Based on information in the GELS, the

Commission found that

Gas supersaturation was a concern at a small number of operating nuclear

power plants with once-through cooling systems but has been satisfactorily

mitigated. It has not been found to be a problem at operating nuclear power

plants with cooling towers or cooling ponds and is not expected to be a problem

during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

August 2006 4-7 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

are no impacts of gas supersaturation during the renewal term beyond those discussed in the

GELS.

Low dissolved oxygen in the discharge. Based on information in the GELS, the Commission

found that

Low dissolved oxygen has been a concern at one nuclear power plant with a

once-through cooling system but has been effectively mitigated. It has not been

found to be a problem at operating nuclear power plants with cooling towers or

cooling ponds and is not expected to be a problem during the license renewal

term.

The staff has not identified any new and significant information during its independent review of

I the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of low dissolved oxygen during the renewal term beyond those discussed'in the

GELS.

* Losses from predation, parasitism, and disease among organisms exposed to sublethal

stresses. Based on information in the GELS, the Commission found that

These types of losses have not been found to be a problem at operating nuclear

power plants and are not expected to be a problem during the license renewal

term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of losses from predation, parasitism, and disease among organisms exposed to

sublethal stresses during the renewal term beyond those discussed in the GELS.

* Stimulation of nuisance organisms. Based on information in the GELS, the Commission

found that

Stimulation of nuisance organisms has been satisfactorily mitigated at the single

nuclear power plant with a once-through cooling system where previously it was

a problem. It has not been found to be a problem at operating nuclear power

plants with cooling towers or cooling ponds and is not expected to be a problem

during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

NUREG-1 437, Supplement 26 4-8 August 2006 1
Environmental Impacts of Operation

are no impacts of stimulation of nuisance organisms during the renewal term beyond those

discussed in the GELS.

Entrainment of fish and shellfish in early life stages (cooling tower based systems). Based

on information in the GELS, the Commission found that

Entrainment of fish has not been found to be a problem at operating nuclear

power plants with this type of cooling system and is not expected to be a

problem during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of entrainment of fish and shellfish in early life stages for cooling tower based

systems during the renewal term beyond those discussed in the GELS.

* Impingement of fish and shellfish (cooling tower based systems). Based on information in

the GELS, the Commission found that

The impingement has not been found to be a problem at operating nuclear

power plants with this type of cooling system and is not expected to be a

-'problem during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of impingement of fish and shellfish for cooling tower based systems during the

renewal term beyond those discussed in the GELS.

* Heat shock (cooling tower based systems). Based on information in the GElS, the

Commission found that

Heat shock has not been found to be a problem at operating nuclear power

plants with this type of cooling system and is not expected to be a problem

during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of heat shock for cooling tower based systems during the renewal term beyond

those discussed in the GELS.

* Cooling tower impacts on crops and ornamental vegetation. Based on information in the

GELS, the Commission found that

August 2006 4-9 NUREG-1 437, Supplement 26 1
Environmental Impacts of Operation

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.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation, or public comments on

the draft SEIS. Therefore, the staff concludes that there are no cooling tower impacts on crops

and ornamental vegetation during the renewal term beyond those discussed in the GELS.

Cooling tower impacts on native plants. Based on information in the GELS, the Commission

found that

Impacts from salt drift, icing, fogging, or increased humidity associated with cooling

tower operation have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

I information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no cooling tower impacts on native vegetation during the renewal term beyond those

discussed in the GELS:

* Bird collisions with cooling towers. Based on information in the GELS, the Commission

found that

These collisions have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of bird collisions with cooling towers during the renewal term beyond those

discussed in the GElS.

* Microbiological organisms (occupational health). Based on information in the GELS, the

Commission found that

Occupational health impacts are expected to be controlled by continued'

application of accepted industrial hygiene practices to minimize worker

exposures.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

NUREG-1437, Supplement 26 4-10 August 2006 1
Environmental Impacts of Operation

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of microbiological organisms during the renewal term beyond those discussed in

the GELS.

Noise. Based on information in the GELS, the Commission found that

Noise has not been found to be a problem at operating plants and is not

expected to be a problem at any plant during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of noise during the renewal term beyond those discussed in the GELS.

The Category 2 issues related to cooling system operation during the renewal term that are

applicable to Monticello are discussed in the sections that follow, and are listed in Table 4-2.

I

I

Table 4-2. Category 2 Issues Applicable to the Operation of the Monticello

Cooling System During the Renewal Term

10 CFR

ISSUE-10 CFR Part 51, Subpart A, Appendix B, 51.53(c)(3)(ii) SEIS

Table B-1 GElS Section Subparagraph Section

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Water use conflicts (plants with cooling ponds or 4.3.2.1; A 4.1.1

cooling towers using makeup water from a small 4.4.2.1

river with a low flow)

AQUATIc ECOLOGY (FOR PLANTS WITH ONCE THROUGH AND COOLING POND HEAT-DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life stages 4.2.2.1.2 B 4.1.2

Impingement of fish and shellfish 4.2.2.1.3 B 4.1.3

Heat shock 4.2.2.1.4 B 4.1.4

HUMAN HEALTH

Microbiological organisms (public health) (plants 4.3.6 G 4.1.5

using lakes or canals, or cooling towers or cooling

ponds that discharge to a small river)

August 2006 4-11 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

4.1.1 Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using

Makeup Water from a Small River with a Low Flow)

Water use conflicts for plants with cooling ponds or towers using makeup water from small river

with low flow is a Category 2 issue, requiring a site-specific assessment before license renewal.

Monticello utilizes cooling towers and withdraws make-up water from the Mississippi River

which has annual flow rate of less than the 3.15 x 1012 cubic ft per year threshold value in

10 CFR 51.53(c)(3)(ii)(A).

The impact of consumptive loss on the downstream riparian communities is associated with the

small difference it can cause in the river surface elevation. Section 2.2.2 describes Monticello

surface water withdrawal from the Mississippi River, which is regulated by the Minnesota

Pollution Control Agency (MPCA) NPDES permit and by the Minnesota Department of Natural

Resources (MNDNR) Surface Water Appropriations Permit. During normal conditions, river

flows in the Mississippi River exceed 860 cfs and cooling of circulating water meets NPDES

permit limits. Under these conditions, the NPDES permit allows Monticello to withdraw a

maximum of 645 cfs and Monticello operates in a once-through mode. When water

temperatures approach NPDES permit limits, Monticello operates: in helper cycle (see

Section 2.2.2) and some of the cooling water is passed through the cooling towers before

discharging into the discharge canal. United States Geological Survey (USGS) gage station

data is available approximately 26 mi upstream from Monticello since 1988 (Station 05270700,

Mississippi River at St. Cloud). This gage station represents a conservative estimate of flow, at

Monticello because this does not take into account additional flow inputs between the USGS

gage station and Monticello. Furthermore, review of the MNDNR online database of water

allocation permits indicate there are no significant surface water withdrawals between the

measuring station and the intake at Monticello (MNDNR 2005a). From September 1988

through September 2004, the maximum and minimum daily flows at the upstream USGS gage

station were 45,100 cfs and 1010 cfs, occurring on April 9, 1997, and August 24, 1989,

respectively (USGS 2005). A separate flow analysis was conducted by NMC in the ER using

data from USGS gage stations both upstream and downstream of Monticello. In this analysis,

the flow at Monticello was estimated based on its drainage area relative to the drainage areas

of the USGS gage stations. This analysis estimated the lowest daily river flow at 586 cfs (NMC

2005a). If the Mississippi River is between 240 and 860 cfs, NMC is only allowed to withdraw 75

percent of the river flow (see Section 2.2.2). At a river flow of 586 cfs, NMC is allowed to

withdraw 440 cfs. Under these conditions, and with an assumed evaporative loss of water from

the cooling towers of 18 cfs (AEC 1972), the consumptive loss due to evaporation from the

cooling towers represents four percent of the river flow, which is not considered significant.

The staff independently reviewed the NMC ER, visited the site, and reviewed the Monticello

NPDES permit, the Surface Water Appropriations permit, and other reports. Based on this

information, the staff concludes that the potential impacts of water use conflicts are SMALL.

During the course of this evaluation, staff considered mitigation measures for continued

'operation of Monticello. Based on this evaluation, the staff expects that the existing State

NUREG-1437, Supplement 26 4-12 August 2006 1
Environmental Impacts of Operation

restrictions on water withdrawal during low-flow conditions in the Mississippi River are

appropriate and no additional mitigation measures are warranted.

4.1.2 Entrainment of Fish and Shellfish in Early Life Stages

For plants with a once-through cooling system, entrainment of fish and shellfish in early life

stages into cooling water systems associated with nuclear power plants is considered a

Category 2 issue, requiring a site-specific assessment before license renewal. To perform this

evaluation, the staff reviewed the applicant's ER (NMC 2005a) and related documents

(including the Clean Water Act (CWA) Section 316(b) Demonstration [Amish et al. 1978]);

visited the Monticello site; and reviewed the applicant's State of Minnesota NPDES Permit No.

0000868, issued on August 22, 2002, and in force until July 31, 2007 (MPCA 2002).

Section 316(b) of the CWA requires that the location, design, construction, and capacity of

cooling water intake structures reflect the best technology available for minimizing adverse

environmental impacts. Entrainment of fish and shellfish into the cooling water system is a

potential adverse environmental impact that can be minimized by use of the best available

technology.

On July 9, 2004, the U.S. Environmental Protection Agency (EPA) published a final rule in the

Federal Register (EPA 2004) addressing cooling water intake structures at existing power

plants, such as Monticello, whose flow levels exceed a minimum threshold value of

50 million gpd. The rule is Phase II in the EPA's development of CWA 316(b) regulations that

establish national requirements applicable to the location, design, construction, and capacity of

cooling water intake structures at existing facilities that exceed the threshold value for water

withdrawals. The national requirements, which are implemented through NPDES permits,

minimize the adverse environmental impacts associated with the continued use of the intake

systems. Licensees are required to demonstrate compliance with the Phase II performance

standards at the time of renewal of their NPDES permit. Licensees may be required as part of

the NPDES renewal to alter the intake structure, redesign the cooling system, modify station

operation, or take other mitigative measures as a result of this regulation. The new

performance standards are designed to significantly reduce entrainment losses due to water

withdrawals associated with cooling water intake structures used for power production. Any

site-specific mitigation would result in less impact from entrainment during the license renewal

period.

Condenser cooling water is withdrawn from the Mississippi River through an approach channel

angled at 81 0 to the shoreline (Amish et al. 1978; NMC 2005a). Water enters the intake over a

concrete sill equipped with a 12.5-ft wide stop log section in the center of the sill. After passing

over the sill, the water passes through a bar rack. The water is then diverted into two separate

streams that each pass through paired traveling screens with 3/8-in. mesh (NMC 2005a). The

Mississippi River is also used for service water cooling, screen wash, and fire protection (MPCA

2002).

August 2006 4-13 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

Under the current Surface Water Appropriations Permit, Monticello is allowed to withdraw a

maximum of 645 cfs for once-through or helper-cycle mode cooling and plant process water

from the Mississippi River. Special operating conditions are required when the river flow is less

than 860 cfs. For example, plant water intake may not exceed 75 percent of river flow when the

river flow is less than 860 cfs but greater than 240 cfs (NMC 2005a). When river flow is less

than 240 cfs, there are further restrictions, including use of a closed-cycle mode of operation

(NMC 2005a). Withdrawn water is returned to the river except for that amount evaporated in

the discharge canal and cooling towers. During 2002, the mean river flow was 6351 cfs while

mean intake flow was approximately 529 cfs; similar means for 2003 were 4572 cfs and 491.9

cfs, respectively (Xcel Energy 2004).

The cooling water flow path for open-cycle or once-through cooling includes (1) the Mississippi

River, (2) the intake, (3) the condenser, (4) the discharge structure, (5) the discharge canal,

(6) the discharge weir, and (7) the Mississippi River. From the discharge canal, the cooling

water returns to the river at a point approximately 1500 ft downstream from the intake. For the

other modes of operation (see Table 2-2), all, part, or none of the cooled water from the cooling

towers can be sent back to the circulating water pump intake (Afzal et al. 1975). Approximately

5 to 6 percent of total cooling water flow needs to be replaced with makeup water from the

Mississippi River during closed-cycle operation (NMC 2005a). Makeup water is supplied by two

31 cfs pumps that replace water lost by.cooling tower evaporation, drift, and blowdown (Afzal et

al. 1975).

Entrainment samples were collected at Monticello from September 12, 1973, to

August 18, 1974, by Knutson et al. (1976). During that period, river flow used for cooling

ranged from 1.6 to 19.4 percent of river flow with a mean of 10.1 percent (Knutson et al. 1976).

Entrainment rates for young-of-the-year fish were estimated at 9.2/hr from September 12, 1973,

to March 13, 1974; 5986/hr from May 22, 1974, to June 28, 1974; and 35/hr from June 28 to

August 18, 1974. The entrainment rate was estimated to be 1617/hr or 38,805/day for all

fishes. The maximum estimated entrainment rate was 22,635/hr on June 12, 1974.

Approximately 98 percent of all entrainment occurred between May 22 and June 28, 1974

(Knutson et al. 1976).

Entrainment losses consisted of twenty-three fish species or species groups (Knutson et al.

1976). Catostomid (sucker) fry comprised 96.5 percent of the entrainment. Black crappie

(Pomoxis nigromaculatus) comprised 1.3 percent, walleye (Sander vitreus) comprised 0.5

percent, and cyprinids (minnows) comprised 0.8 percent of total fish entrained (Knutson et al.

1976). Entrainment of young-of-the-year shorthead redhorse (Moxostoma macrolepidotum),

silver redhorse (M. anisurum), and white sucker (Catostomus commersoni) during April to

August 1974 was estimated at 7.8 million individuals; while only a combined 8400 black

crappie, walleye, and smallrnouth bass (Micropterus dolomieu) were entrained (Knutson et al.

1976). Since regular fish surveys have been initiated at Monticello before the plant started

operation, suckers have been the predominant species collected in electroshocking samples

(Xcel Energy 2004). Thus, entrainment has not apparently had an impact on sucker species

production.

NUREG-1437, Supplement 26 4-14 August 2006 1
Environmental Impacts of Operation

In addition to elevated temperatures, entrained organisms are exposed to biocides and

mechanical stresses. Experimental studies using fathead minnow (Pimephales promelas) fry

demonstrated that up to 11.8 percent survived temperature elevations of 25.6 to 41.60 F; while

8.5 to 42.4 percent showed signs of mechanical damage from passing through the condensers.

The incidence of external injuries for fish that were alive at recapture was only approximately

2 percent (Knutson et al. 1976). However, survival was found to be very low (0.0 to

1.6 percent) when ambient river temperatures were 55.00 F or higher or when the change in

temperature was 59.40 F (Knutson et al. 1976). Overall, it was concluded that sublethal thermal

and mechanical effects would result in long-term survival of less than 10 percent of entrained

fishes (Knutson et al. 1976).

Entrainment monitoring was also conducted at Monticello between April 23 and

September 4, 1976, for the CWA 316(b) Demonstration. This sampling period encompassed a

low-flow year in the Mississippi River. Therefore, Monticello withdrew a relatively high

percentage of river water, and consequently, entrainable organisms (Amish et al. 1978). During

the year, an average of 19.3 percent of the Mississippi River flow passed though the plant,

ranging from a high of 36 percent in August 1976 to a low of 7 percent in April 1976 (Amish et

al. 1978).

In the 1976 study, 2.83 million young-of-the-year fish and 1.08 million fish eggs were estimated

to have been entrained at Monticello. The predominant species entrained as larvae were

879,000 logperch (Percina caprodes) (31.8 percent); 633,000 shorthead redhorse (22.4

percent); 388,000 unidentifiable darters (13.7 percent); and 308,000 unidentifiable minnows

(10.9 percent). The eggs were not identified to species (Amish et al. 1978). The maximum

number of equivalent adult fish estimated to have been lost due to this entrainment was

250,124 fishes, including 218,000 logperch, 9230 shorthead redhorse, 1410 darters, and

13,600 minnows (Amish et al. 1978).

Generally, buoyant eggs are the only ones capable of being entrained at Monticello. Most fish

species in the area of Monticello have adhesive eggs. Therefore, it was assumed that

free-floating eggs were either diseased or accidentally removed from the riverbed by current

and scouring action. These eggs would have had a naturally low potential for survival (Knutson

et al. 1976).

To interpret the impacts of entrainment on fish community species populations and structure,

entrainment losses must be compared to the distribution, abundance, and life cycles of the

species that occur near Monticello. The ultimate impact of entrainment losses must be

evaluated in terms of a system's resiliency (i.e., environmental stability, productivity, population

compensation, and ecological and economic importance of the individual species) (Noguchi et

al. 1985). The fish community has been persistent and stable since the plant became

operational; and species composition has been similar between locations upstream and

downstream of the Monticello site (Xcel Energy 2004). Based on the CWA 316(b)

Demonstration (Amish et al. 1978), the Minnesota Pollution Control Agency concluded that

entrainment at Monticello does not pose a substantial detrimental effect on the fish population

August 2006 4-15 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

(MPCA 1979). Under conditions of the current State of Minnesota NPDES permit, the location

and operation of the intake will continue to have minimal environmental impact.

During the course of the SEIS preparation, the staff considered mitigation measures for the

continued operation of Monticello. Based on the assessment conducted, the staff expects that

the measures in place at Monticello (e.g., the intake structure is situated in a location devoid of

unique spawning habitat and the capability of the plant to operate in a partial recirculation or

closed-cycle mode) provide mitigation for impacts related to entrainment. The staff concludes

that the potential impacts of entrainment of fish and shellfish in the early life stages into the

cooling water intake system are SMALL, and further mitigation measures would not be

warranted.

4.1.3 Impingement of Fish and Shellfish

For plants with once-through cooling systems, impingement of fish and shellfish on debris

screens of cooling water system intakes is considered a Category 2 issue, requiring a

site-specific assessment before license renewal. To perform this evaluation, the staff reviewed

the applicant's ER (NMC 2005a) and related documents [including the CWA 316(b)

Demonstration (Amish et al. 1978)]; visited the Monticello site; and reviewed the applicant's

State of Minnesota NPDES Permit No. 0000868, issued on August 22, 2002, and in force until

July 31, 2007 (MPCA 2002).

Condenser cooling water is withdrawn from the Mississippi River through an approach channel

angled at 810 to the shoreline (Amish et al. 1978). Water enters the intake over a concrete sill

equipped with a 12.5 ft wide stop log section in the center of the sill. After passing over the sill,

the water passes through a bar rack. The water is then diverted into two separate streams that

each pass through paired traveling screens with 3/8-in. mesh (NMC 2005a). The Mississippi

River is also used for service water cooling, screen wash, and fire protection (MPCA 2002).

The traveling screens at Monticello are normally rotated and rinsed every 12 hours, but run

continuously when the river temperature is higher than 500F. The screen rinse sluiceway was

installed in 1973 to decrease mortality of impinged fish. During periods of continuous screen

washing, the sluiceway produces up to 95 percent survival of impinged fish (Amish et al. 1978).

Monticello may withdraw a maximum of 645 cfs for once-through or helper-cycle mode cooling

and plant process water from the Mississippi River. Special operating conditions are required

when the river flow is less than 860 cfs. For example, plant water intake may not exceed

75 percent of river flow when the river flow is less than 860 cfs but greater than 240 cfs (NMC

2005a). When river flow is less than 240 cfs, there are further restrictions, including use of a

closed-cycle mode of operation (NMC 2005a). Withdrawn water is returned to the river except

for that amount evaporated in the discharge canal and cooling towers. During 2002, the mean

river flow was 6351 cfs, while mean intake flow was approximately 529 cfs; similar means for

2003 were 4572 cfs and 491.9 cfs, respectively (Xcel Energy 2004).

NUREG-1437, Supplement 26 4-16 August 2006 1
Environmental Impacts of Operation

Section 316(b) of the CWA requires that the location, design, construction, and capacity of

cooling water intake structures reflect the best technology available for minimizing adverse

environmental impacts. Impingement of fish and shellfish on the traveling screens of the

cooling water intake system is a potential adverse environmental impact that can be minimized

by use of the best available technology.

On July 9, 2004, the EPA published a final rule in the Federal Register (EPA 2004) addressing

cooling water intake structures at existing power plants such as Monticello, whose flow levels

exceed a minimum threshold value of 50 million gpd. The rule is Phase II in the EPA's

development of CWA 316(b) regulations that establish national requirements applicable to the

location, design, construction, and capacity of cooling water intake structures at existing

facilities that exceed the threshold value for water withdrawals. The national requirements,

which are implemented through NPDES permits, minimize the adverse environmental impacts

associated with the continued use of the intake systems. Licensees are required to

demonstrate compliance with the Phase II performance standards at the time of renewal of their

NPDES permit. Licensees may be required as part of the NPDES renewal to alter the intake

structure, redesign the cooling system, modify station operation, or take other mitigative

measures as a result of this regulation. The new performance standards are designed to

significantly reduce impingement losses due to plant operation. Any site-specific mitigation

would result in less impact due to continued plant operation.

* Impingement studies at Monticello were conducted from 1972 to 1975, and were summarized

by Amish et al. (1978):

" Between June and September 1972, an estimated 2952 fish were impinged; 65 percent

were black bullheads (Ameiurus melas) and nearly 26 percent were black crappies.

Impinged smallmouth bass, northern pike (Esox lucius), and common carp (Cyprinus

carpio) were mostly young-of-the-year.

" Between July and December 1973, an estimated 18,030 fish were impinged; 75 percent

were bluegills (Lepomis macrochirus) and 8 percent were black crappies.

Young-of-the-year (including all of the bluegills) made up 94 percent of the impinged fish.

" During 1974, an estimated 16,343 fish (52 percent being young-of-the-year) were impinged.

Among these, 28 percent were black crappies and 35 percent were black bullheads.

Smallmouth bass and white sucker each comprised 4 percent of the impinged fish. Highest

impingement occurred in late summer and fall when young-of-the-year had attained an

impingeable size.

" During 1975, an estimated 34,157 fish were impinged; 73 percent were black bullheads.

Common carp and black crappies together comprised 9 percent of the impinged fish.

During the year-long study, only 20 percent of the impinged fish were young-of-the-year.

However, Monticello was shut down in the fall of 1975 when young-of-the-year impingement

primarily occurs.

August 2006 4-17 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

Additional impingement studies were conducted at Monticello between April 16, 1976, and

April 8, 1977, as part of the CWA 316(b) Demonstration (Amish et al. 1978). An estimated

39,767 fish were impinged. The predominant fish impinged were 15,295 shorthead redhorse

(38.5 percent), 7385 silver redhorse (18.6 percent); 3381 logperch (8.5 percent); 2506 common

I carp (6.3 percent); 2254 black crappie (5.7 percent); 2121 white sucker (5.3 percent); and

1799 black bullhead (4.5 percent) (Amish et al. 1978). The maximum number of equivalent

adult fish estimated to have been lost due to this impingement was 10,838, including:

1820 shorthead redhorse; 635 silver redhorse; 3381 logperch; 215 common carp; 230 black

I crappie; 252 white sucker; and 1799 black bullhead (Amish et al. 1978).

Based on the CWA 316(b) Demonstration (Amish et al. 1978), the Minnesota Pollution Control

Agency concluded that impingement at Monticello does not pose a substantial detrimental

effect on the fish population (MPCA 1979). The Mississippi River fish community has been

persistent and stable since the plant became operational, and species composition has been

similar between locations upstream and downstream of the Monticello site (Xcel Energy 2004).

Under the current State of Minnesota NPDES permit, the location and operation of the intake

will continue to have minimal environmental impact.

During the course of the SEIS preparation, the staff considered mitigation measures for the

continued operation of Monticello. Based on the assessment conducted, the staff expects that.

the measures in place at Monticello (e.g., the intake structure located in an area where fish

congregation does not occur and that is devoid of unique spawning habitat, and a screen wash

system that returns impinged fish to the river) provide mitigation for impacts related to

impingement. Based on the results of past impingement studies and the operating history of

Monticello's intake structure, the staff concludes that the potential impacts of impingement of

fish and shellfish are SMALL, and further mitigation measures would not be warranted.

4.1.4 Heat Shock

For plants with once-through cooling systems, the impacts of heat shock are listed as a

Category 2 issue and require plant-specific evaluation before license renewal. The NRC made

impacts on fish and shellfish resources resulting from heat shock a Category 2 issue because

of continuing concerns about thermal discharge impacts and the possible need to modify

thermal discharges in the future in response to changing environmental conditions (NRC 1996).

Information to be considered includes (1) the type of cooling system (whether once-through or

cooling pond) and (2) evidence of a CWA Section 316(a) variance or equivalent State

documentation. Heat shock can be defined as thermal stress caused by exposure to a sudden

elevation of water temperature that adversely affects the metabolism and behavior of fish and

can lead to death. Heat shock is most likely to occur when an off line unit returns to service. To

perform this evaluation, the staff reviewed the applicant's ER (NMC 2005a) and related

documents (including the CWA 316(a) Demonstration [Afzal et al. 1975]); visited the Monticello

site; and reviewed the applicant's State of Minnesota NPDES Permit No. 0000868, issued on

August 22, 2002, and in force until July 31, 2007 (MPCA 2002).

NUREG-1437, Supplement 26 4-18 August 2006 1
Environmental Impacts of Operation

Monticello has a once-through heat dissipation system. However, due to a potential

combination of low flows and high ambient water temperatures, Monticello has two cooling

towers that can be used to meet thermal discharge standards through helper cycle mode or by

complete or partial recirculation of the cooling water (NMC 2005a). The Surface Water

Appropriations Permit requires that the cooling towers must be operated in partial recirculation

mode when the river flow is between 240 and 860 cfs, or closed-cycle mode when the river flow

is less than 240 cfs, and in accordance with allowable thermal discharge limits set forth by the

MPCA in the NPDES Permit. NPDES Permit stipulations specify that the maximum daily

average temperature at the end of the discharge canal cannot exceed the following limiting

temperatures: 95 0F from April through October; 85 0F in November and March; and 80°F from

December through February (MPCA 2002). However, discharge temperatures in excess of

these limits is allowed, on a limited basis, when the plant is required to operate in a partial

recirculation or closed-cycle mode to meet the Surface Water Appropriations Permit limitation

(NMC 2005a). When reduced river flows and/or elevated ambient river temperatures limit the

ability for Monticello to meet thermal discharge limits, plant procedures require a reduction in

power output to maintain compliance with the State of Minnesota NPDES permit (NMC 2005a).

The cooling towers are normally used when the ambient river temperature reaches 68°F or

when the discharge canal temperature approaches permitted temperature limits (NMC 2005a).

In partial recirculation mode, a portion of the cooled water from the cooling towers is

recirculated to the intake, while the remainder is discharged to the river. When river flow is less

than 860 cfs, a maximum of 75 percent of river flow at the intake may be withdrawn. Partial

recirculation may used to comply with this restriction (NMC 2005a). During extreme low flow

conditions, Monticello can operate as a closed system. During this operational mode, the

makeup requirement is only 54 cfs (NMC 2005a). Occasionally, one cooling tower may be

used during winter to provide a flow path for heated water to the intake structure when

suspended ice is present in the river (NMC 2005a).

Monticello has operated in a once-through or helper mode approximately 98 percent of the time

(NMC 2005). The remainder of the time Monticello has operated in a partial recirculation or

closed-cycle mode.

In 2002, the mean ambient river temperature was 49.70F while the discharge canal temperature

was 77.90F. In 2003, these temperatures were 50.9 0F and 78.20F, respectively (Xcel Energy

2004). In winter, when ambient river temperatures were near freezing (320F), the discharge

temperatures generally ranged between 70 and 75°F; whereas in summer when ambient river

temperatures range from approximately 70 to 800F, the discharge temperatures ranged from

approximately 84 to 91 *F (NSP 2004). The main body of the thermal plume is generally

confined to the south bank of the river; and 30 to 70 percent of the river was unffected by the

thermal plume (NMC 2005a). The 90F plume is considered the immediate discharge zone,

while the 3°F plume is considered the intermediate discharge zone (Afzal et al. 1975). During

approximately 70 percent of the period from June through September, the 90F isotherm

extended less than half the river width and less than 700 ft downstream of the discharge. The

August 2006 4-19 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

intermediate discharge zone extended across the entire river at spots and extended at least

3.5 mi downstream (Afzal et al. 1975).

Afzal et al. (1975) noted that some fish remained in the discharge canal (during the early years

of operation before the weir was installed) when temperatures were 91 to 950F, but avoided the

canal when temperatures reached 1040F. In 1980, an overflow weir that closely approximates

the preconstruction shoreline of the Mississippi River was added to the discharge canal. Under

normal conditions the weir effectively prevents movement of fish from the river into the

discharge canal. Fish species that frequent the area immediately downstream of the weir

included smallmouth bass, black crappie, walleye, northern pike, common carp, shorthead

redhorse, silver redhorse, and white sucker. The fish population inhabiting the discharge canal

in the fall and winter of 1974-1975 was estimated at 147 black bullhead, 354 rock bass

(Ambloplites rupestris), 22 black crappie, and 216 bluegill (Afzal et al. 1975). These

observations were made before the channel catfish (Ictalurus punctatus) first appeared in the

Monticello area.

Spawning areas for shorthead redhorse, silver redhorse, white sucker, and black crappie were

identified from both sides of the Mississippi River and from areas both upstream and

downstream of Monticello (Afzal et al. 1975). Thus, thermal effects would not be expected to

have a significant impact on local fish production. The fish community has been persistent and

stable since the plant became operational, and species composition has been similar between

locations upstream and downstream of the discharge (Xcel Energy 2004).

The Monticello thermal discharge to the Mississippi River does not entrap fish in an area of

elevated temperatures. Thus, acute thermal impacts (e.g., death or immediate disability) are

unlikely. Generally, the maximum plume temperature differential would be within the tolerance

range of most warmwater species (Talmadge and Opreska 1981). Furthermore, the thermal

plume in the Mississippi River encompassed by the 30F isotherm is sufficiently large that fish

would rarely be exposed to abrupt temperature differentials that would be high enough to be

potentially harmful. Also, no currents or physical deterrents are present that would force fish to

remain in areas of potentially harmful water temperatures.

There have been periods of non-compliance with the NPDES permit; however, there have been

no indications of adverse impacts to the aquatic biota within the area of influence from the

Monticello discharge (Afzal.et al. 1975). Based on the results of the CWA 316(a)

Demonstration, the Minnesota Pollution Control Agency concluded that the thermal discharges

from Monticello do not pose a substantial detrimental effect on the fish and benthic

macroinvertebrate communities (MPCA 1979).

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, the NPDES permit, the CWA 316(a) demonstration, and other public sources.

During the course of this SEIS preparation, the staff considered mitigation measures for the

continued operation of Monticello during the license renewal period. Based on the staff's

assessment of measures in place at Monticello (e.g., the discharge is located in an area where

NUREG-1437, Supplement 26 4-20 August 2006 1
Environmental Impacts of Operation

fish congregation does not occur and that is devoid of unique spawning habitat, the installation

of the discharge canal fish weir that limits fish movem-ent into the discharge canal, and the

capability of the plant to operate in a partial recirculation or closed-cycle mode) further

mitigation measures are not warranted. It is the staff's conclusion that potential impacts to fish

and shellfish due to heat shock during the renewal term are SMALL, and further mitigation

measures would not be warranted.

4.1.5 Microbiological Organisms (Public Health)

The effects of microbiological organisms on human health are listed as a Category 2 issue and

require plant-specific evaluation before license renewal for those plants with closed-cycle

cooling on a small river. The average annual flow of Mississippi River discharge in the vicinity

of the Monticello site is approximately 2.3 x 1011 cubic ft per year (NMC 2005a), which is less

than the 3.15 x 1012 cubic ft per year threshold value in 10 CFR 51.53(c)(3)(ii)(G) for thermal

discharge to a small river. Hence, the staff considers this a small river and the effects of its

discharge on microbiological organisms must be addressed for Monticello.

Thermophilic bacteria generally occurat temperatures of 77 to 1760F, with maximum growth

occurring between 122 and 1400F. Bacteria pathogenic to humans typically have optimum.

temperatures of approximately 99-F (Joklik and Willett 1976). Populations of the pathogenic

amoeba Naegleria fowleri can be enhanced in thermally altered water bodies at temperatures

ranging from 95 to 106 0F or higher, but this organism is rarely found in water cooler than 950F

based on studies reviewed and coordinated by Tyndall et al. (1989).

'The Mississippi River in the vicinity of the plant is a broad turbulent stream with a boulder

substrate. Recreational uses including boating, fishing, and canoeing are frequent in the

vicinity of the plant. NMC employees also perform sampling in the river. All of these activities

create the potential for human exposure. The ambient temperatures of the Mississippi River

near the Monticello site vary from freezing (approximately 320F) in the winter to 83 0F in the

summer (AEC 1972). Therefore, ambient river conditions are not likely to support the

proliferation of pathogenic organisms of concern.

The Monticello site discharge monitoring data collected from 1999 through 2001 for the months.

of June through September were reviewed. During those months the monthly average water

temperature within the discharge canal ranged from 86 to 91 OF. Additionally, the plant's

NPDES permit limits the maximum daily average temperature at the end of the discharge canal

to 95 0F, the temperature specified for the warmer months of the year (April through October).

Based on monthly average water temperatures within the discharge canal and maximum

discharge temperatures at the end of the discharge canal, coupled with the dilution provided by

the Mississippi River, thermophilic microorganisms are not expected to cause any appreciable

public health risk (NMC 2005a).

August 2006 4-21 A NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

The staff independently reviewed the NMC ER, visited the Monticello site, and reviewed the

applicant's State of Minnesota NPDES permit. Based on the evaluation presented above,

thermophilic microbiological organisms are not likely to occur as a result from Monticello

discharges to the Mississippi River. The staff concludes that impacts on public health from

thermophilic microbiological organisms from continued operation of Monticello in the license

renewal period are SMALL, and further mitigation would not be warranted.

4.2 Transmission Lines

The Final Environmental Statement (FES) for the Monticello site (AEC 1972) describes two

transmission lines that connect Monticello substation with the transmission system. These

transmission corridors cover approximately 1441 ac over a total corridor length of approximately

80 mi. There are five additional transmission lines emanating from the Monticello substation;

however, they are not part of this review. The Xcel Energy program for conductor and tower

maintenance includes monthly fixed-wing aerial patrols for the 345-kV lines and annual

helicopter patrols on all lines in the system. These patrols ipclude surveillance for system

anomalies and land use changes that could impact design assumptions. The objective of Xcel

Energy's transmission line vegetation management program is to keep the corridors clear of

trees, bushes, and other tall-growing vegetation that could come into close proximity with the

conductors and cause line outages. They achieve this objective by selectively removing

tall-growing trees and brush from the transmission corridors while encouraging the growth of

lower-growing trees, shrubs, and grasses. Herbicides are used occasionally, primarily applied

to individual trees or shrubs to prevent re-sprouting (Xcel Energy 2005).

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

transmission lines from the Monticello Site are listed in Table 4-3. NMC stated in its ER that it

is not aware of any new and significant information associated with the renewal of the

Monticello site. The staff has not identified any new and significant information during its

I independent review of the NMC ER, the staff's site visit, the scoping process, its evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to these issues beyond those discussed in the

GELS. For all of those issues, the staff concluded in the GElS that the impacts are SMALL, and

additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be

warranted.

A brief description of the staff's review and the GElS conclusions, as codified in Table B-i, for

each of these issues follows:

* Power line right-of-way management (cutting and herbicide application). Based on

information in the GElS, the Commission found that

The impacts of right-of-way maintenance on wildlife are expected to be of small

significance at all sites.

NUREG-1437, Supplement 26 4-22 August 2006 1 -
Environmental Impacts of Operation

Table 4-3. Category 1 Issues Applicable to the Monticello Transmission

Lines During the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

TERRESTRIAL RESOURCES

Power line right-of-way management (cutting and herbicide application) 4.5.6.1

Bird collisions with power lines 4.5.6.2

Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, 4.5.6.3

honeybees, wildlife, livestock)

Flood plains and wetlands on power line right-of-way 4.5.7

AIR QUALITY

Air quality effects of transmission lines 4.5.2

LAND USE

Onsite land use 4.5.3

Power line right-of-way 4.5.3

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, consultation with the U.S. Fish and.

Wildlife Service (FWS), its evaluation of other information, or public comments on the draft

SEIS. Therefore, the staff concludes that there are no impacts of power line right-of-Way

maintenance during the renewal term beyond those discussed in the GELS.

* Bird collisions with power lines. Based on information in the GElS, the Commission found

that

I

Impacts are expected to be of small significance at all sites.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, consultation with the FWS, its evaluation

of other information, or public comments on the draft SEIS. Therefore, the staff concludes that

there are no impacts of bird collisions with power lines during the renewal term beyond those

discussed in the GELS.

Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees,

wildlife, livestock). Based on information in the GElS, the Commission found that

No significant impacts of electromagnetic fields on terrestrial flora and fauna

have been identified. Such effects are not expected to be a problem during the

license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, consultation with the FWS, its evaluation

I

I

August 2006 4-23 NUREG-1437, Supplement 26 I
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of other information, or public comments on the draft SEIS. Therefore, the staff concludes that

there are no impacts of electromagnetic fields on flora7and fauna during the renewal term

beyond those discussed in the GELS.

* Flood plains and wetlands on power line right-of-way. Based on information in the GELS,

the Commission found that

Periodic vegetation control is necessary in forested wetlands underneath power

lines and can be achieved with minimal damage to the wetland. No significant

impact is expected at any nuclear power plant during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, consultation with the FWS, its evaluation

I of other information, or public comments on the draft SEIS. Therefore, the staff concludes that

there are no impacts of power line rights-of-way on flood plains and wetlands during the

renewal term beyond those discussed in the GELS.

Air quality effects of transmission lines. Based on information in the GELS, the Commission

found that

Production of ozone and oxides of nitrogen is insignificant and does not

contribute measurably to ambient levels of these gases.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, public comments, its evaluation of other

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no air quality impacts of transmission lines during the renewal term beyond those discussed

in the GELS.

Onsite land use. Based on the information in the GELS, the Commission found that

Projected onsite land use changes required during ... the renewal period would

be a small fraction of any nuclear power plant site and would involve land that is

controlled by the applicant.

The staff has not identified any new and significant information during its independent review of

I the NMC ER, the staff's site visit, the scoping process, consultation with the FWS, its evaluation

of other information, or public comments on the draft SEIS. Therefore, the staff concludes that

there are no onsite land use impacts during the renewal term beyond those discussed in the

GELS.

NUREG-1437, Supplement 26 4-24 August 2006 1
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Power line right-of-way. Based on information in the GELS, the Commission found that

Ongoing use of power line rights of ways would continue with no change in

restrictions. The effects of these restrictions are of small significance.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, consultation with the FWS, its evaluation

of other information, or public comments on the draft SEIS. Therefore, the staff concludes that

there are no impacts of power lines on land use during the renewal term beyond those

discussed in the GELS.

There is one Category 2 issue related to transmission lines, and another issue related to

transmission lines is also evaluated. These issues are listed in Table 4-4 and are discussed in

Sections 4.2.1 and 4.2.2.

Table 4-4. Category 2 and Uncategorized Issues Applicable to the Monticello

Transmission Lines During the Renewal Term

10 CFR

ISSUE-10 CFR Part 51, Subpart A, Appendix B, GElS 51.53(c)(3)(1i) SEIS

Table B-1 Section Subparagraph -Section

HUMAN HEALTH

Electromagnetic fields, acute effects (electric shock) 4.5.4.1 H 4.2.1

Electromagnetic fields, chronic effects 4.5.4.2 N/A 4.2.2

4.2.1 Electromagnetic Fields-Acute Effects

Based on the GELS, the Commission found that electric shock resulting from direct access-to

energized conductors or from induced charges in metallic structures has not been found to-be a

problem at most operating plants and generally is not expected to be a problem during the ýlicense renewal term. However, site-specific review is required to determine the significance of

the electric shock potential along the portions of the transmission lines that are within the scope

of this SEIS.

In the GElS (NRC 1996), the staff found that without a review of the conformance of each

nuclear plant transmission line with National Electrical Safety Code (NESC) criteria (NESC

2001), it was not possible to determine the significance of the electric shock potential.

Evaluation of individual plant transmission lines is necessary because the issue of electric

shock safety was not addressed in the licensing process for some nuclear power plants. For

other nuclear power plants, land use in the vicinity of transmission lines may have changed, or

power distribution companies may have chosen to upgrade line voltage. To comply with

10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an assessment of the potential shock

August 2006 4-25 NUREG-1437, Supplement 26 I
Environmental Impacts of Operation

hazard if the transmission lines that were constructed for the specific purpose of connecting the

plant to the transmission system do not meet the recommendations of the NESC for preventing

electric shock from induced currents.

Two 345-kV transmission lines (Monticello to Coon Creek and Monticello to Parkers Lake

circuits) were originally constructed to connect Monticello to the transmission system. However,

changes to the 345-kV transmission system and to these lines have fully integrated Monticello

Substation into the 345-kV transmission system. Based on these considerations, Monticello

Substation now constitutes the transmission interconnection for Monticello.

All lines emanating from Monticello Substation were designed, constructed, and are operated in

compliance with the applicable sections of the NESC, including the most recent edition. These

lines meet the requirements in effect since the 1990 edition of the Code for lines exceeding

98 kV alternating current to ground, which limits "the steady state current due to electrostatic

effects to 5 mA if the largest anticipated truck, vehicle or equipment under the line were

short-circuited to ground." This current is induced in vehicles by the transmission line electric

field and is proportional to the voltage of the line and inversely proportional to the distance from

the line. The Electric Power Research Institute (EPRI) has performed measurements on

objects beneath lines to determine the level of electric field that will induce current in various

objects. Results indicate that an electric field of 7.8 kV per meter at 1 meter above ground is

required to induce a 5 mA current through a large tractor-trailer (EPRI 1987).

The 345-kV lines associated with Monticello Substation produce a maximum electric field at

1 meter above ground of 6.0 kV per meter. The unloaded sag at 120°F is limited by the NESC

to a minimum distance to ground of 30 ft in order to meet the minimum clearance required for

operation at 212'F, the highest operating temperature. For a large vehicle, the electric field

values indicated above could potentially generate an induced current of 3.84 mA, which is

below the NESC code criteria of 5 mA (NMC 2005a).

Transmission line compliance with the provisions of the NESC code discussed above is verified

by periodic air patrols (monthly), which monitor construction activities beneath and near the

lines that could alter corridor terrain and clearances. Based on these considerations, NMC

concluded that the Monticello 345-kV transmission lines meet the NESC recommendations for

preventing shock from induced currents and further assessment of the impact of the proposed

action on the potential shock hazard is not required (NMC 2005a). NMC's assessment under

10 CFR Part 51 concludes that electric shock is of small significance for Monticello transmission

lines. Due to the small significance of the issue, mitigation measures, such as the installation of

warning signs at roadway crossings or increasing wire clearance, are not warranted.

The staff has reviewed the available information, including that provided by the applicant, the

staff's site visit, the scoping process, and other public sources. Using this information, the staff

evaluated the potential impacts for electric shock resulting from operation of Monticello and

associated transmission lines. It is the staff's conclusion that the potential impacts for electric

shock during the renewal term are SMALL.

NUREG-1437, Supplement 26 4-26 August 2006 1
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4.2.2 Electromagnetic Fields-Chronic Effects

In the GElS, the chronic effects of 60-Hz electromagnetic fields from power lines were not

designated as either Category 1 or Category 2, and will not be until a scientific consensus is

reached on the health implications of these fields.

The potential for chronic effects from these fields continues to be studied and is not known at

this time. The National Institute of Environmental Health Sciences (NIEHS) directs related

research through the U.S. Department of Energy. A recent report (NIEHS 1999) contains the

following conclusion:

The NIEHS concludes that ELF-EMF (extremely low frequency-electromagnetic field)

exposure cannot be recognized as entirely safe because of weak scientific evidence that

exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to

warrant aggressive regulatory concern. However, because virtually everyone in the

United States uses electricity and therefore is routinely exposed to ELF-EMF, passive

regulatory action is warranted such as a continued emphasis on educating both the

public and the regulated community on means aimed at reducing exposures. The

NIEHS does not believe that other cancers or non-cancer health outcomes provide

* sufficient evidence of a risk to currently warrant concern.

This statement is not sufficient to cause the staff to change its position with respect to the

chronic effects of electromagnetic fields. Footnote 5 to Table B-1 states: "If, in the future, the

Commission finds that, contrary to current indications, a consensus has been reached by

appropriate Federal health agencies that there are adverse health effects from electromagnetic

fields, the Commission will require applicants to submit plant-specific reviews of these health

effects as part of their license renewal applications. Until such time, applicants for license

renewal are not required to submit information on this issue." The staff considers the GElS

finding of "uncertain" still appropriate and will continue to follow developments on this issue.

4.3 Radiological Impacts of Normal Operations

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

Monticello in regard to radiological impacts are listed in Table 4-5. NMC stated in its ER (NMC

2005a) that it is not aware of any new and significant information associated with the renewal of

the Monticello OL. The staff has not identified any new and significant information during its

independent review of the NMC ER, the staff's site visit, the scoping process, its evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to these issues beyond those discussed in the

GELS. For these issues, the staff concluded in the GElS that the impacts are SMALL, and

additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be

warranted.

August 2006 4-27 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

Table 4-5. Category I Issues Applicable to Radiological Impacts of

Normal Operations During the Renewal Term

ISSUE-b10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

HUMAN HEALTH

Radiation exposures to public (license renewal term) 4.6.2

Occupational radiation exposures (license renewal term) 4.6.3

A brief description of the staffs review and the GElS conclusions, as codified in Table B-i, for

each of these issues follows:

Radiation exposures to public (license renewal term). Based on information in the

GELS, the Commission found that

Radiation doses to the public will continue at current levels associated with

normal operations.

The staff has not identified any new and significant information during its independent review of

the NMC ER,the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft.SEIS. Therefore, the staff concludes that there

are no impacts of radiation exposures to the public during the renewal term beyond those

discussed in the GELS.

Occupational radiation exposures (license renewal term). Based on information in the

GELS, the Commission found that

Projected maximum occupational doses during the license renewal term are

within the range of doses experienced during normal operations and normal

maintenance outages, and would be well below regulatory limits.

The staff has not identified any new and significant information during its independent review

of the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of occupational radiation exposures during the renewal term beyond those

discussed in the GELS.

There are no Category 2 issues related to radiological impacts of routine operations.

NUREG-1437, Supplement 26 4-28 August 2006 1
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4.4 Socioeconomic Impacts of Plant Operations During the

License Renewal Term

Category I issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

socioeconomic impacts during the renewal term are listed in Table 4-6. NMC stated in its ER

(NMC 2005a) that it is not aware of any new and significant information associated with the

renewal of Monticello. The staff has not identified any new and significant information during

its independent review of the NMC ER, the staff's site visit, the scoping process, its evaluation

of other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to these issues beyond those discussed in the

GEIS'(NRC 1996). For all of those issues, the GElS concluded that the impacts are SMALL,

and plant-specific mitigation measures are not likely to be sufficiently beneficial to be

warranted.

Table 4-6. Category 1 Issues Applicable to Socioeconomics During the

Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

SOCIOECONOMICS

Public services: public safety, social services, and tourism and recreation 4.73; 4.7.3.3 4.7.3.4;

4.7.3.6

Public services: education (license renewal term) 4.7.3.1

Aesthetic impacts (license renewal term) 4.7.6

Aesthetic impacts of transmission lines (license renewal term) 4.5.8

A brief description of the staff's review and the GElS conclusions, as codified in Table B-i, for

each of these issues follows:

Public services: public safety, social services, and tourism and recreation. Based on

information in the GElS, the Commission found that

Impacts to public safety, social services, and tourism and recreation are

expected to be of small significance at all sites.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts on public safety, social services, and tourism and recreation during the renewal

term beyond those discussed in the GELS.

August 2006 4-29 NUREG-1437, Supplement 26 I
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* Public services: education (license renewal term). Based on information in the GELS, the

Commission found that

Only impacts of small significance are expected.

The staff has not identified any new and significant information during its independent review of

I the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts on education during the renewal term beyond those discussed in the GELS.

* Aesthetic impacts (license renewal term). Based on information in the GELS, the

Commission found that

No significant impacts are expected during the license renewal term.

The staff has not identified any new and significant information during its independent review of

I the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no aesthetic impacts during the renewal term beyond those discussed in the GElS.

* Aesthetic impacts of transmission lines (license renewal term). Based on information in the

GELS, the Commission found that

No significant impacts are expected during the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public'comments on the draft SEIS. Therefore, the staff concludes that there

are no aesthetic impacts during the renewal term beyond those discussed in the GELS.

Table 4-7 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and

environmental justice, which was not addressed in the GELS.

4.4.1 Housing Impacts During Operations

In determining housing impacts, the applicant chose to follow Appendix C of the GElS

(NRC 1996), which presents a population characterization .method that is based on two factors,

"sparseness" and "proximity" (GELS Section C.1.4 [NRC 1996]). Sparseness measures

population density within 20 m'i of the site, and proximity measures population density and city

size within 50 mi. Each factor has categories of density and size (GELS Table C.1 [NRC 1996]),

and a matrix is used to rank the population category as low, medium, or high (GELS Figure C.1

[NRC 1996]).

According to the U.S. Census Bureau (USCB) 2000 information, the population living within

20 mi of the Monticello site was estimated to be approximately 166,860. This translates to

NUREG-1437, Supplement 26 4-30 August 2006 1
Environmental Impacts of Operation

approximately 133 persons/mi2 living on the land area present within a 20-mi radius of

Monticello.

Table 4-7. Environmental Justice and GElS Category 2 Issues Applicable to

Socioeconomics During the Renewal Term

10 CFR

ISSUE-10 CFR Part 51, Subpart A, 51.53(c)(3)(11)

Appendix B, Table B-1 GElS Section Subparagraph SEIS Section

SOCIOECONOMICS

Housing impacts 4.7.1 I 4.4.1

Public services: public utilities 4.7.3.5 I 4.4.2

Offsite land use (license renewal term) 4.7.4 I 4.4.3

Public services: public transportation 4.7.3.2 J 4.4.4

Historic and archeological resources 4.7.7 K 4.4.5

Environmental justice Not addressed(a) Not addressed(a) 4.4.6

(a) Guidance related to environmental justice was not in place at the time the GElS and the associated revision to

10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in the staff's

environmental impact statement.

This concentration falls into GElS sparseness Category 4. As estimated from 2000 USCB

information, approximately 2,740,995 people live within 50 mi of Monticello. This equates to a

population density of 349 persons/mi2 within 50 mi. According to the GElS proximity measures

(NRC 1996), Monticello is therefore classified as Category 4. Applying the GElS sparseness

and proximity matrix (sparseness Category 4 and proximity Category 4) results in the

conclusion that Monticello is located in a high-population area.

SMALL impacts result when no discernible change in housing occurs, changes in rental rates

and housing values are similar to those occurring statewide, and no housing construction or

conversion is required to meet new demand (NRC 1996). The GElS assumes that no more

than a total additional staff of 60 permanent workers might be needed during the license

renewal period to perform routine maintenance and other activities. The number of vacant

housing units in Wright County and Sherburne County are 8.4 percent or 2890 housing units

and 5.5 percent or 1246 housing units, respectively (USCB 2000). Therefore, the addition of

60 workers and 74 indirect jobs generated by those additional employees (NMC 2005a) could

be comfortably absorbed without significant impact to the housing market during the license

renewal period.

Monticello is not projecting new employment due to license renewal activities. As a result, NMC

indicated that the impacts would be SMALL and mitigation measures would not be necessary

(NMC 2005a). The staff reviewed the available information relative to housing impacts and

NMC conclusions. Based on this review, the staff concludes that the impact on housing during

August 2006 4-31 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

the license renewal period would be SMALL, and additional mitigation measures are not

warranted.

4.4.2 Public Services: Public Utility Impacts During Operations

Impacts on public utility services are considered SMALL if there is little or no change in the

ability of the system to respond to the level of demand, and thus there is no need to add capital

facilities. Impacts are considered MODERATE if overtaxing of service capabilities occurs

during periods of peak demand. Impacts are considered LARGE if existing levels of service

(e.g., water or sewer services) are substantially degraded and additional capacity is needed to

meet ongoing demands for services. The GElS indicates that, in the absence of new and

significant information to the contrary, the only impacts on public utilities that could be

significant are impacts on public water supplies (NRC 1996).

Analysis of impacts on the public water supply system considered plant demand and

plant-related population growth. Section 2.2.2 describes the Monticello permitted withdraw rate

and actual use of water. There are no plans for refurbishment at Monticello, so plant demand.

would not change (NMC 2005a).

In the bounding analysis, Monticello assumed 60 new employees and 74 indirect jobs created

by the new employees due to license renewal activity. Most area water capacities are below

maximum withdraw capacities (see Table 2-7). The additional direct and indirect employees

would use less than 1 percent-of the current usage from these facilities. The staff finds that the

impact of increased water use on area water systems is SMALL, and that no further mitigation

measures are warranted.

4.4.3 Offsite Land Use During Operations

Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51,

* Subpart A, Appendix B, Table B-i). Table B-1 of 10 CFR Part 51 Subpart A, Appendix B notes

that "significant changes in land use may be associated with population and tax revenue

changes resulting from license renewal."

Section 4.7.4 of the GElS defines the magnitude of land use changes as a result of plant

operation during the license renewal term as follows:

SMALL-Little new development and minimal changes to an area's land use pattern.

MODERATE-Considerable new development and some changes to the land use

pattern.

LARGE-Large-scale new development and major changes in the land use pattern.

NUREG-1437, Supplement 26 4-32 August 2006 1
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Tax revenue can affect land use because it enables local jurisdictions to be able to provide the

public services (e.g., transportation and utilities) necessary to support development.

Section 4.7.4.1 of the GElS states that the assessment of tax-driven land use impacts during

the license renewal term should consider (1) the size of the plant's payments relative to the

community's total revenues, (2) the nature of the community's existing land use pattern, and

(3) the extent to which the community already has public services in place to support and guide

development. If the plant's tax payments are projected to be small relative to the community's

total revenue, tax-driven land use changes during the plant's license renewal term would be

SMALL, especially where the community has pre-established patterns of development and has

provided adequate public services to support and guide development. Section 4.7.2.1 of the

GElS states that if tax payments by the plant owner are less than 10 percent of the taxing

jurisdictions revenue, the significance level would be SMALL. If the plant's tax payments are

projected to be medium to large relative to the community's total revenue, new tax-driven land

use changes would be MODERATE. If the plant's tax payments are projected to be a dominant

source of the community's total revenue, new tax-driven land use changes would be LARGE.

This would be especially true where the community has no pre-established pattern of

development or has not provided adequate public services to support and guide development.

Northern States Power Company (NSP) is assessed annual property taxes for the Monticello

site by Wright.County, the City of Monticello, School District 882, and the Monticello-Big Lake

Hospital District. NSP is also assessed the State General Tax. Property taxes are paid directly

to Wright County, which in turn distributes the money to the aforementioned taxing jurisdictions..

Property taxes fund local government services such as highway maintenance, education, public

health, public safety, public libraries, and various other social services (NMC 2005a).

From 1994 to 2001, NSP's largest annual property tax contributions for Monticello went to

School District 882. Payments during the period from 1998 to 2002 decreased by 70.2 percent

as a result of the passage of a tax bill by the State in 2001 which replaced the State Assessed

School Levy with the State General Tax. Assessments under the State General Tax are paid

into the State General Fund and redistributed by a State-determined formula to school districts

statewide in part based on student numbers. The State Assessed School Levy had been

included in School District 882 payments prior to year 2002. Contributions to School District

882 accounted for 20.4 percent of the school district's total revenues and 18.5 percent of the

total operating budget in 1999. By 2002, payments for Monticello represented a much smaller

percentage of both the school district's total revenues and total operating budget, 5.2 percent

and 5.5 percent, respectively (NMC 2005a).

Annual property tax payments to Wright County decreased from approximately 3.2 to 2.0 million

dollars from 1998 to 2002, a 36.9 percent decrease. These contributions represented 6.9 to

3.4 percent of the county's total annual revenues during the period.

Annual payments to the hospital district decreased 30 percent during the period from 1998 to

2003. These payments represented an increasingly smaller percentage of total revenues from

1998 to 2002, 1.4 to 0.5 percent. When viewed in relation to total Wright County property tax

August 2006 4-33 NUREG-1437, Supplement 26 1
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dollars received by the hospital district, NSP's tax payment for Monticello represented between

27.9 percent and 21.3 percent of the total tax levy during the period.

Annual NSP payments to the City of Monticello increased from approximately 2.8 to 3.4 million

dollars from 1998 to 2002, a 20.9 percent increase, but represented a smaller percentage of the

city's total revenues than in previous years, decreasing from 29.8 to 24.6 percent between 1998

to 2002. In addition, these annual payments represented a slightly increasing percentage (11.7

to 12.8) of the total operating budget for the City of Monticello during the same period (NMC

2005a).

NSP projects that future tax payments will gradually increase due to increased levies by the

aforementioned taxing jurisdictions. NSP's tax liability for Monticello could also be influenced by

changes at higher levels of government. The Minnesota Department of Revenue is currently

reviewing the rules determining the way electric utilities are valued. These reviews may result

in a reduction of NSP's apportionable value regarding its Monticello property, thereby potentially

lowering future tax payments for NSP. However, state lawmakers have discussed reducing

some of the exemptions currently available to NSP, resulting in potentially higher future tax

liabilities for Monticello (NMC 2005a).

Because (1) Monticello does not propose to employ additional personnel during the license.

renewal period, and (2) Monticello does not anticipate major refurbishment or construction

during -this period, and therefore, does not anticipate any increase in the assessed value of

Monticello .during the license renewal period, the staff concludes that the net impact of

plant-related population changes is likely to be SMALL. However, if the operating license for

Monticello was not renewed and the plant was decommissioned, the impacts to the tax base for

Wright County, the City of Monticello, School District 882, and the Monticello-Big Lake Hospital

District could be significant. Therefore, the staff concludes that the net impact of tax-related

land use impacts of not renewing the operating license for Monticello are MODERATE.

4.4.4 Public Services: Transportation Impacts During Operations

Table B-1, 10 CFR Part 51 states: "Transportation impacts (level of service) of highway traffic

generated during the term of the renewed license are generally expected to be of small

significance. However, the increase in traffic associated with additional workers and the local

road and traffic control conditions may lead to impacts of moderate or large significance at

some sites." All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of

highway traffic generated by the proposed project on the level of service of local highways

during the term of the renewed license.

Expected population growth in the area around Monticello is not due to changes in employment

at Monticello, but due to the migration away from the Minneapolis/St. Paul area and the

successful recruitment of outlet malls and retail. Current employment associated with

Monticello is approximately 414 permanent employees and 105 contract and matrixed

employees (NMC 2005a). Monticello refuels on a nominal 22- to 24-month cycle. During

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refueling outages, site employment increases by as many as 600 temporary workers for 30 to

40 days. During surveillance, monitoring, inspections, testing, trending, and recordkeeping

(SMITTR), Monticello believes that these tasks can be performed within this schedule and

employment level. NRC uses 60 workers as a conservative estimate of additional permanent

workers needed per unit for license renewal SMITTR activities. GElS Section C.3.1.2 was

written using this approach in order to "...provide a realistic upper bound to potential

population-driven impacts...." (NRC 1996). NMC submitted its opinion on the effects of an

additional 60 workers and concluded that there would be no significant transportation impacts

during operations.

This additional analysis did not change the staff's conclusions related to impacts on

transportation service.

The staff reviewed Monticello's assumptions and resulting conclusions. Based on its

independent review, the staff concludes that any impact of Monticello employees on

transportation service degradation is SMALL and no further mitigation measures are warranted.

4.4.5 Historic and Archaeological Resources

The National Historic Preservation Act (NHPA) requires that Federal agencies take into account

the impacts of their undertakings on historic properties. The historic preservation review -

process mandated by Section 106 of the NHPA is outlined in regulations issued by the Advisory

Council on Historic Preservation at 36 CFR Part 800. Renewal of an OL is an undertaking that

could potentially affect historic properties. Therefore, according to the NHPA, the NRC is to

make a reasonable effort to identify historic properties in the areas of potential effect. If no

historic properties are present or affected, the NRC is required to notify the State Historic

Preservation Officer (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 Part 800.8(c), the NRC informed the Advisory Council on Historic

Preservation, the Minnesota State Historic Preservation Office (MNSHPO), and tribes-with

current and historical ties to the region that the Section 106 process is being integrated with the

NEPA process and "the SEIS will include analyses of potential impacts to historic and cultural

resources" (NRC 2005b,c). The NRC then conducted an archaeological records and literature

search at the MNSHPO in June 2005 to identify important resources that may be located in the

area of potential effect.

Based on the site records search, the input from MNSHPO (Bloomberg 2005), and absence of

input from tribes concerning traditional properties in the vicinity, the NRC has determined that

no historic properties will be affected by this undertaking. Further, due to the extensive

disturbance resulting from the original plant construction, no impacts to historic properties are

anticipated during operation. According to plant procedures that are in place, ground-disturbing

activities will be reviewed by the Environmental Coordinator, and, in the unlikely event that

resources are discovered within the area of potential effect during the course of operations, the

August 2006 4-35 NUREG-1437, Supplement 26 1
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I MNSHPO will be notified and consulted in developing any response needed to address the

I discovery. In April 2006, MN SHPO concurred with thie-se findings following a review of the draft

I SEIS (Bloomberg 2006).

Due to the extensive disturbance present in the area of potential effect, and the lack of

substantial land-altering aspects of this license renewal, it is the staff's conclusion that the

potential impacts to historic and archaeological resources are expected to be SMALL and

mitigation is not warranted.

4.4.6 Environmental Justice

Environmental justice refers to a Federal policy that Federal agencies identify and address, as

appropriate, disproportionately high and adverse human health or environmental effects of its

action on minority(a) or low-income populations. The memorandum accompanying Executive

Order 12898 directs Federal executive agencies to consider environmental justice under the

National Environmental Policy Act of 1969 (NEPA). The Council on Environmental Quality

(CEQ) has provided guidance for addressing environmental justice. Although the Executive

Order is not mandatory for independent agencies, the NRC has voluntarily committed to

undertake environmental justice reviews. Specific guidance is provided in NRC Office of

Nuclear Reactor Regulation Office Instruction LIC-203, Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues Rev. 1 (NRC 2004a). In

2004, the Commission issued a Final Policy Statement on the Treatment of Environmental

Justice Matters in NRC Regulatory and Licensing Actions (NRC 2004b).

The scope of the review as defined in NRC guidance (NRC 2004a) includes identification of

impacts on minority and low-income populations, the location and significance of any

environmental impacts during operations on populations that are particularly sensitive, and

information pertaining to mitigation. It also includes evaluation of whether these impacts are

likely to be disproportionately high and adverse.

The staff looks for minority and low-income populations within the 50-mi radius of the site. For

the staff's review, a minority population exists in a census block group(b) if the percentage of

each minority and aggregated minority category within the census block group exceeds the

(a) The NRC guidance for performing environmental justice reviews defines "minority" as American Indian

or Alaskan Native; Asian, Native Hawaiian, or other Pacific Islander; or Black races; or Hispanic

ethnicity. "Other" races and multiracial individuals may be considered a separate minority category

(NRC 2004a).

(b) A census block group is a combination of census blocks, which are statistical subdivisions of a census

tract. A census block is the smallest geographical entity for which the USCB collects and tabulates

decennial census information. A census tract is a small, relatively permanent statistical subdivision of

counties delineated by local committees of census data users in accordance with USCB guidelines for

the purpose of collecting and presenting decennial census data. Census block groups are subsets of

census tracts.

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corresponding percentage of minorities in thestate of which it is a part by 20 percentage points,

or the corresponding percentage of minorities within the census block group is at least

50 percent. A low-income population exists if the percentage of low-income population within a

census block group exceeds the corresponding-percentage of low-income population in the

state of which it is a part by 20 percent, or if the corresponding percentage of low-income

population within a census block group is at least 50 percent.

For the NMC review, the staff examined the geographical distribution of minority and

low-income populations within 50 mi of the site, employing the 2000 census for low-income and

minority populations. NMC conducted its analysis for minority and low-income populations

using the convention of including a census tract or block group if any part of its area lay within

50 mi of Monticello. The 50-mi radius includes 2166 census block groups. NMC used USCB

2000 census data to determine the minority and low-income characteristics on a block-group

level. NMC included in its analysis census block groups that were 50 percent or more within the

50-mi radius of Monticello. The criterion of more than 20 percentage points was used to

determine whether a census tract or block group should be counted as containing a minority or

low-income population. Figures 4-1 and 4-2 show the distribution of census blocks for the

minority and low-income populations, respectively.

Based on the NRC criterion, the staff determined that Black minority populations exist in

149 block groups. American Indian or Native American minority populations exist in 3 census

block groups. Asian minority populations exist in 46 census block groups. Hispanic or Latino

minority populations exist in 52 census block groups. "Other" minority populations exist in

11 census block groups. Figure 4-1 shows the location of census block groups with minority

populations. By the NRC criteria, 91 census blocks contained areas of low-income populations,

as shown in Figure 4-2.

With the locations of minority and low-income populations identified, the staff evaluated whether

any of the environmental impacts of the proposed action could affect these populations in a

disproportionately high or adverse manner. Based on staff guidance (NRC 2004a), air, land

and water resources within 50 mi of the Monticello site were examined. Within that area, a few

potential environmental impacts could affect human populations; all of these were considered

SMALL for the general population.

The pathways through which the environmental impacts associated with Monticello license

renewal can affect human populations are discussed in each associated section. The staff

evaluated whether minority or low-income populations could be disproportionately affected by

these impacts. The staff found that a specific ethnic group, the Hmong, identified within the

Asian minority population, depends on fishing and consuming fish from local rivers at a

disproportionately higher level than other populations. However, the staff did not identify any

significant effects from the plant on local fish. In addition, the staffdid not identify any

location-dependent disproportionate impacts affecting these minority and low-income

populations. The staff concludes that offsite impacts from Monticello to minority and

low-income populations are SMALL, and no mitigation actions are warranted.

August 2006 4-37 NUREG-1437, Supplement 26 1
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Figure 4-1. Geographic Distribution of Minority Populations (Shown in

Shaded Areas) Within 50 mi of Monticello Based on Census

Block Group Data

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Figure 4-2. Geographic Distribution of Low-Income Populations (Shown in

Shaded Areas) Within 50 mi of Monticello Based on Census

Block Group Data

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4.5 Groundwater Use and Quality

The Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that is applicable to

Monticello groundwater use and quality is listed in Table 4-8. NMC stated in its ER that it is not

aware of any new and significant information associated with the renewal of the Monticello OL

(NMC 2005a). The staff has not identified any new and significant information during its

independent review of the NMC ER, the staff's site visit, the scoping process, its evaluation of

I other available information, or public comments on the draft SEIS (NMC 2005a). Therefore, the

staff concludes that there are no impacts related to this issue beyond that discussed in the

GELS. For this issue, the GElS concluded that the impacts are SMALL, and additional

plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

A brief description of the staff's review and the GElS conclusions, as codified in Table B-i,

10 CFR Part 51, Subpart A, Appendix B, Table B-i, follows.

Table 4-8. Category I Issue Applicable to Groundwater Use and Quality

During the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section

GROUND-WATER USE AND QUALITY

Ground-water use conflicts (potable and servicewater; plants that use < 100 gpm) 4.8.1.1

Ground-water use conflicts (potable and service water: plants that use < 100 gom). Based

on information in the GELS, the Commission found that

Plants using less than 100 gpm are not expected to cause any ground-water use

conflicts.

As discussed in Section 2.2.2, Monticello groundwater use is less than 100 gpm. The staff has

not identified any new and significant information during its independent review of the NMC ER,

the staff's site visit, the scoping process, its evaluation of other available information, or public

I comments on the draft SEIS. Therefore, the staff concludes that there are no groundwater use

conflicts during the renewal term beyond those discussed in the GELS.

The Category 2 issue related to groundwater use and quality during the renewal term that is

applicable to the Monticello site is discussed in the section that follows. This issue, which

requires plant-specific analysis, is listed in Table 4-9.

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Table 4-9. Category 2 Issue Applicable to Groundwater Use and Quality

During the Renewal Term

10 CFR

ISSUE-l0 CFR Part 51, Subpart A, Appendix B, GElS 51.53(c)(3)(ii) SEIS

Table B-1 Section Subparagraph Section

GROUND-WATER USE AND QUALITY

Ground-water use conflicts (plants using cooling 4.8.1.3; A 4.5.1

towers withdrawing make-up water from a small river) 4.4.2.1

4.5.1 Groundwater Use Conflicts (Make-Up From a Small River)

Groundwater use conflicts for plants that have cooling towers withdrawing makeup water from a

small river is a Category 2 issue, requiring a site-specific assessment before license renewal.

Surface-water withdrawals from small water bodies during low-flow conditions may result in

groundwater use conflicts with nearby groundwater users.

Groundwater use at Monticello is regulated by a Water Appropriations Permit with MNDNR.

The permit required NMC to measure groundwater elevations during 1967 to 1994, which

showed that the groundwater level is higher than river elevations (NMC 2005a). The impact of

consumptive loss on nearby groundwater users is associated with the difference it could

potentially cause in aquifer recharge, especially if other new groundwater or upstream surface

water users begin withdrawals. However, since groundwater flows towards the Mississippi

River, groundwater withdrawals would not be impacted by changes in river flow.

The staff reviewed available information relative to potential groundwater-use conflicts due to

consumptive loss of aquifer recharge. Based on this review, the staff concludes that the

potential impacts are SMALL, and additional mitigation is not warranted.

4.6 Threatened or Endangered Species

Federally threatened or endangered species are listed as e Category 2 issue in 10 CFR

Part 51, Subpart A, Appendix B, Table B-I. This issue is listed in Table 4-10.

This issue requires consultation with appropriate agencies to determine whether threatened or

endangered species are present and whether they would be adversely affected, by continued

operation of the nuclear plant during the license renewal term. The presence of threatened or

endangered species in the vicinity of the Monticello site is discussed in Sections 2.2.5 and

2.2.6. On June 3, 2005, the staff contacted the FWS to request information on threatened and

endangered species and the impacts of license renewal (NRC 2005a). In response, on

July 13, 2005, the FWS provided additional information regarding Federally listed species that

have been observed or may occur in the four-county area (Wright, Sherburne, Hennepin, and

Anoka counties) that includes the Monticello site and its associated transmission lines, as well

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as concerns that the FWS has regarding those species (FWS 2005). The staff has prepared a

biological assessment (BA) documenting its review of Federally listed threatened or

endangered species at the Monticello site and associated transmission lines and submitted it to

the FWS for concurrence (NRC 2005d).

Table 4-10. Category 2 Issue Applicable to Threatened or Endangered

Species in the Vicinity of Monticello During the License

Renewal Term

ISSUE-i 0 CFR Part 51, 10 CFR

Subpart A, Appendix B, 51.53(c)(3)(ii)

Table B-1 GElS Section Subparagraph SEIS Section

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered 4.1 E 4.6

species

4.6.1 Aquatic Species

The Higgins' eye pearlymussel (Lampsilis higginsih) is the only Federally listed (endangered)

aquatic species reported from the four-county area that includes the Monticello site and its

associated transmission lines (FWS 2005). As discussed in Section 2.2.5, the closest Essential

Habitat Areas for the.Higgins' eye pearlymussel occur in the St. Croix River (RM 811), which

flows into the Mississippi River approximately 89 mi downstream from Monticello (RM 900).

Also, the Higgins' eye pearlymussel is not known to occur further upstream than Pool 2

(RM 848 to RM 815) of the Mississippi River, which is mostly located downstream from the Twin.;

Cities area (Kelner and Davis 2002; Hornbach 2004). Therefore, potential impacts from the

operation of Monticello are too far removed to adversely affect the species. The Monticello

cooling-water intake and discharge are closely monitored under the NPDES program. NPDES

permit limits are reviewed on a regular basis by the Minnesota Pollution Control Agency to

ensure the protection of aquatic biota, including fish species that can serve as hosts for the

glochidia of the Higgins' eye pearlymussel.

There are no plans to conduct refurbishment or construction activities at Monticello. Therefore,

the staff has concluded that continued operation of the plant during the license renewal term will

have no effect on the Higgins' eye pearlymussel. Thus, it is the staff's finding, as documented

in its BA (see Appendix E), that the impacts on threatened or endangered aquatic species from

an additional 20 years of operation of Monticello would be SMALL, and additional mitigation is

not warranted.

4.6.2 Terrestrial Species

There are two Federally listed threatened or endangered terrestrial species that have the

potential to occur on or in the vicinity of the Monticello site and its associated transmission lines.

These two species are discussed in Section 2.2.6. One Federally threatened species, the bald

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eagle, is known to occur on the Monticello site and on one of its associated transmission

corridors. The gray wolf, also a Federally threatened species, occurs in the northern portions of

Minnesota and has recovered significantly, compared with its numbers in past decades.

Continued recovery and dispersal of this species into central and southern portions of

Minnesota is probable.

Two active bald eagle nests occur in the vicinity of the Monticello site. One nest is located on

Beaver Island in the Mississippi River north-northwest of the Monticello power block; the second

nest is located in a transmission tower along the Monticello-Coon Creek 345 kV line. Public

access to both nest sites is limited. The nest located on Beaver island is approximately 1000 ft

from the Monticello power block in which the majority of site activity occurs and would not be

affected by routine site operation or maintenance activities. The nest located in the

transmission tower is in a remote area and Xcel Energy has restricted right-of-way maintenance

activities in the vicinity of the nest (NMC 2005b).

NMC has not identified any additional construction or refurbishment activities that would result

in greater land disturbance during the license renewal period (NMC 2005a). Furthermore, Xcel

Energy has in place a program to install flight diverters on its transmission lines to reduce'the

potential for avian collisions and has entered into a memorandum of understanding (MOU) with

the FWS to develop and implement an Avian Protection Plan (Xcel Energy et al. 2002).

Electrocutions in the U.S. of large raptors almost always occur on comparatively low voltage

distribution lines, not transmission lines. NMC and Xcel Energy are not aware of any adverse

impacts to threatened or endangered species that have resulted from the operation of the

Monticello plant during its 30-year operating history (NMC 2005a). Therefore the staff

concludes that operations and maintenance activities on the Monticello site or its associated

transmission line corridors are not likely to adversely affect the bald eagle.

The gray wolf currently does not occur on the Monticello site or associated transmission line

corridors. Operations and maintenance activities at Monticello and its associated transmission

corridors will have no effect on the gray wolf.

Based on this information, as documented in its BA (NRC 2005d), the staff concludes that the

potential impacts on threatened or endangered terrestrial species from an additional 20 years of

operation of Monticello on terrestrial threatened and endangered species would be SMALL, and

additional mitigation is not warranted.

4.7 Evaluation of Potential New and Significant Information

on Impacts of Operations During the Renewal Term

The staff has not identified new and significant information on environmental issues listed in

10 CFR Part 51, Subpart A, Appendix B, Table B-i, related to operation during the renewal

term. The staff also determined that information provided during the public comment period did

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not identify any new issue that requires site-specific assessment. The staff reviewed the

discussion of environmental impacts associated with operation during the renewal term in the

GElS and has conducted its own independent review, including public scoping meetings, to

identify issues with new and significant information. Processes for identification and evaluation

of new information are described in Section 1.2.2.

4.8 Cumulative Impacts

The staff considered potential cumulative impacts of operations of Monticello during the renewal

term. For the purposes of this analysis, past actions are those related to the resourcesat the

time of the plant licensing and construction, present actions are those related to the resources

at the time of current operation of the power plant, and future actions are considered to be

I those that are reasonably foreseeable through the end of the current license term, as well as

I during the 20-year license renewal term. Therefore, the analysis considers potential impacts

through the end of the current license term as well as the 20-year renewal license term. The

geographical area over which past, present, and future actions would occur is dependent on the

type of action considered and is described below for each impact area.

The impacts of the proposed action, as described in Section 4, are combined with other past,

present, and reasonably foreseeable future actions at Monticello regardless of what agency

(Federal or non-Federal) or person undertakes such other actions. These combined impacts

are defined as "cumulative" in 40 CFR 1508.7 and include individually minor but collectively

significant actions taking place over a period of time. It is possible that an impact that may be

SMALL by itself could result in a MODERATE or LARGE impact when considered in

combination with the impacts of other actions on the affected resource. Likewise, if a resource

is regionally declining or imperiled, even a SMALL individual impact could be important if it

contributes to or accelerates the overall resource decline.

4.8.1 Cumulative Impacts Resulting from Operation of the Plant Cooling System

For the purposes of this analysis, the geographic area considered for cumulative impacts

resulting from operation of the Monticello cooling system is primarily the upper portion of the

Mississippi River, particularly that area bounded by St. Cloud upstream of the plant (RM 900)

and St. Anthony Falls Lock and Dam (RM 854) downstream of the plant. As discussed in

Section 4.1, the staff found no new and significant information that would indicate that the

conclusion regarding any of the cooling system-related Category 1 issues related to Monticello

is inconsistent with the conclusions in the GElS (NRC 1996). Additionally, the staff determined

that none of the cooling system-related Category 2 issues would have greater than a SMALL

impact on local water quality and aquatic resources.

The cumulative impacts of past actions have resulted in the existing water quality and aquatic

resource conditions near Monticello. The major changes and modifications within the upstream

reach of the Mississippi River that have had the greatest impacts on aquatic resources include

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physical and chemical stresses and introduction of nonnative species. The physical and

chemical stresses include urban, industrial, and agricultural contaminants (e.g., nutrients, toxic

chemicals, sediments); stream modification; water diversions; land-use changes (e.g.,

residential, recreational, agricultural and industrial development); dredging; shoreline

modifications; wetland elimination and modification; dams and impoundments; impingement

and entrainment in water-intake structures; thermal loading from cooling water; and major

degradative incidents or catastrophes (Weitzell et al. 2003; Genet and Chirhart 2004). These in

turn can affect fish, benthic macroinvertebrates, and plankton populations; cause a loss of

habitat; cause deformities or tumors in fish and other biota; and contaminate fish, which leads

to restrictions on human consumption.

Industrial, municipal, agricultural, and power plant usage of the Mississippi River occurs

between St. Cloud and the Twin Cities (NMC 2005a). While pollution from domestic sewage

has been reduced since passage of the Federal Water Pollution Control Act of 1972 (CWA), the

Mississippi River still receives contaminants from agricultural, industrial, municipal, and

residential sources (Fremling and Drazkowski 2000). The Monticello intake area requires

dredging every six to eight years to prevent excess sand and silt from being drawn into the

plant circulating water system (Amish et al. 1978). This causes a temporary, localized stress to

aquatic biota within the immediate area near the Monticello plant.

The river water supply is adequate to meet the needs of the facility for cooling purposes under

* all conditions. The staff, while preparing this assessment, assumed that other industrial,

commercial, or public installations could be located in the general vicinity of the Monticello site

prior to the end of Monticello operations. Any discharge of water by such facilities into the

Mississippi River would be regulated by the MPCA. The discharge limits are set considering

the overall or cumulative impact of all of the other regulated activities in the area. Compliance

with the CWA and its NPDES permit minimizes Monticello's cumulative impacts on aquatic

resources. Continued operation of Monticello would require renewed discharge permits from

the MPCA, which would address changing requirements so that cumulative water quality

objectives would be served.

Future contributions to cumulative impacts to aquatic resources within the Mississippi River

would generally occur from those actions that currently cause impacts (e.g., human habitation,

urban and industrial development, agriculture, recreational fisheries, and spread of nonnative

species). The quality of the aquatic resources within the Upper Mississippi River will continue

to decline unless inputs of sediments, nutrients, and toxic substances are reduced or eliminated

(Fremling and Drazkowski 2000).

The potential exists for the expansion of nonnative species that have already begun to occur in

the Upper Mississippi River, and for additional nonnative species to become established within

the river. Four species of Asian carp are established within the Upper Mississippi River. As

mentioned, the common carp (Cyprinus carplo) is a prominent species within the Monticello

area, while the grass carp (Ctenopharyngodon idella), silver carp (Hypophthalmichthys

molotrix), and bighead carp (H. nobilis) have become established within the Upper Mississippi

.August 2006 4-45 NUREG-1 437, Supplement 26 1
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River (but not within Minnesota) during the past two decades (Chick 2002). These species can

impact native species by destroying habitat, reducing water quality, and by consuming aquatic

vegetation (grass carp) or planktonic organisms (silver and bighead carp) (USGS 2004). The

silver and bighead carp have the potential to adversely affect every species of fish within the

Upper Mississippi River (Chick 2002). These three carp species are moving towards

Minnesota. The closest known populations are in the Iowa waters of the Mississippi River

(MNDNR 2005b).

The Higgins' eye pearlymussel is the only Federally listed aquatic species that is reported from

the Mississippi River in the four-county area being considered for cumulative impacts. As

mentioned in Section 2.2.5, past actions that have adversely affected this species have

included siltation; impoundments; in-stream habitat disturbance; contaminants; pearl button and

cultured pearl industries; and introduced species, particularly the zebra mussel (Dreissena

polymorpha) (Hornbach 2004).

As discussed in Section 4.6.1, existing Higgins' eye pearlymussel populations are too far

removed from Monticello for plant operations to contribute to the cumulative impacts that are

affecting this species. Additionally, entrainment, impingement, thermal discharges, and

infrequent cold shock events have only a minimal localized impact on fish species that are

suitable hosts for the glochidia of the Higgins' eye pearlymussel.

The staff concludes that the potential cumulative impacts of the Monticello cooling system

operations, including entrainment and impingement of fish and shellfish, heat shock, or any ofthe cooling system-related Category I issues (including cold shock) contributed by the

continued operation of the facility will be SMALL and that no further mitigation measures are

warranted.

4.8.2 Cumulative Impacts Resulting from Continued Operation of the

Transmission Lines

Continued operation of the electrical transmission facilities associated with renewal of the

operating license for Monticello was evaluated to determine if there is the potential for

interactions with other past,-present, and future actions that could result in adverse cumulative

impacts to terrestrial resources (e.g., wildlife populations, the size and distribution of habitat

areas), wetlands, floodplains, or aquatic resources. For the purposes of this analysis, the

geographic area that encompasses the past, present, and foreseeable future actions that could

contribute to adverse cumulative impacts includes .those Minnesota counties that contain the

transmission lines associated with the Monticello site (Wright, Hennepin, Sherburne, and Anoka

counties). The staff is unaware of any planned activities within the area of consideration that

could potentially produce additional impacts in association with the continued operation of the

transmission lines. The presence of transmission lines generally precludes further activities

that could affect the environment.

NUREG-1437, Supplement 26 4-46 August 2006 1
Environmental Impacts of Operation

Therefore, the staff has determined that the cumulative impacts of the continued operation of

the Monticello transmission lines are SMALL, and that no additional mitigation would be

warranted.

4.8.3 Cumulative Radiological Impacts

The radiological dose limits for protection of the public and workers have been developed by

the EPA and NRC to address the cumulative impact of acute and long-term' exposure to

radiation and radioactive material. These dose limits are codified in 40 CFR Part 190 and

10 CFR Part 20. For the purpose of this analysis, the area within a 50-mi radius of the

Monticello site was included. The radiological environmental monitoring program (REMP)

conducted by NMC in the vicinity of the Monticello site measures radiation and radioactive

materials from all sources, including Monticello; therefore, the monitoring program measures

cumulative radiological impacts. There are no other nuclear power plants within a 50-mi radius

of Monticello. Monitoring results for the 5-year period from 1999 to 2004 were reviewed as part

of the cumulative impacts assessment. Additionally, in Sections 2.2.7 and 4.3, the staff

concluded that impacts of radiation exposure to the public and workers (occupational) from

operation of Monticello during the renewal term are SMALL. The NRC and the State of

Minnesota would regulate any future actions in the vicinity of the Monticello site that could

contribute to cumulative radiological impacts.

Therefore, the staff concludes that cumulative radiological impacts.of continued operations of

Monticello are SMALL, and that no further mitigation measures are warranted.

4.8.4 Cumulative Socioeconomic Impacts

The continued operation of Monticello is not likely to result in significant cumulative impacts for

any of the socioeconomic impact measures assessed in Section 4.4 of this SEIS (public

services, housing, and offsite land use). This is because operating expenditures, staffing

levels, and local tax payments during renewal would be similar to those during the current

license period. Similarly, the proposed action is not likely to result in significant cumulative

impacts on historic and archaeological resources.

When combined with the impact of other potential activities likely in the area surrounding the

plant, socioeconomic impacts resulting from Monticello license renewal would not produce an

incremental change in any of the impact measures used. The staff therefore determined that

the impacts on employment, personal income, housing, local public services, utilities, and

education occurring in the local socioeconomic environment as a result of license renewal

activities, in addition to the impacts of other potential economic activity in the area, would be

SMALL. The staff determined that the impact on offsite land use would be SMALL because no

refurbishment activities are planned at Monticello, and no new incremental changes to

plant-related tax payments are expected that could influence land use by fostering considerable

growth. The impacts of license renewal on transportation and environmental justice would also

August 2006 4 -47 NUREG-1 437, Supplement 26 1
Environmental Impacts of Operation

be SMALL. There are no reasonably foreseeable scenarios that would alter these conclusions

in regard to cumulative impacts.

Although no archaeological or architectural surveys have been conducted to date at the

Monticello site, and the potential exists for significant cultural resources to be present within the

site boundaries, it does not appear that the proposed license renewal will adversely affect these

resources. The applicant has indicated that no refurbishment or replacement activities,

including additional land-disturbing activities, at the plant site (or along existing transmission

corridors) are planned for the license renewal period. Therefore, continued operation of

Monticello would likely protect any cultural resources present within the Monticello site boundary

by protecting those lands from development and providing secured access. On the basis of the

staff's analysis of cultural resources, the contribution to a cumulative impact on cultural

resources by continued operation of Monticello during the license renewal period is considered

SMALL.

4.8.5 Cumulative Impacts on Groundwater Use and Quality

Monticello's groundwater appropriations permit for two wells limits groundwater withdrawal to a

maximum of 200 gpm for both wells. From 1998 to 2000, actual usage averaged 30 gpm.

Three other wells have an annual usage of under 1.9 gpm and do not require appropriation

permits. The current impact of Monticello on the alluvial aquifer due to plant operations and

current groundwater withdrawals is small, as discussed in Section 4.5. There are no known or

planned projects requiring withdrawal of groundwater, either at the plant or within its vicinity,

that would potentially cause an adverse impact on groundwater if implemented in addition to the

Monticello unit license renewal. On the basis of this analysis, the staff concludes that the

cumulative impact to groundwater resources during the license renewal period would be SMALL

and that additional mitigation would not be warranted.

4.8.6 Cumulative Impacts on Threatened or Endangered Species

The geographic area considered in the analysis of potential cumulative impacts to threatened or

endangered species includes the counties of Wright, Sherburne, Minnesota. The Monticello

site and its associated transmission line rights-of-way that are within scope of the license

renewal review are found within these two counties. As discussed in sections 2.2.5 and 2.2.6,

there are three Federally listed species that potentially could inhabit Wright and Sherburne

counties. No Federally designated candidate species, nor critical habitat for any threatened or

endangered species are known to occur within the geographic area of consideration.

The staff's findings on the three Federally protected species are presented in the

December 22, 2005 (NRC 2005d) BA (Appendix E) and in Section 4.6 of this SEIS. The staff

concluded in the BA and Section 4.6 that continued operation of Monticello, and the continued

use of the existing transmission lines within the scope of this review, will have no effect on the

Higgins' eye pearlymussel and grey wolf and is not likely to adversely affect the bald eagle.

Therefore, the staff determined that since there is currently no adverse impact to these species

NUREG-1437, Supplement 26 4-48 August 2006 1
Environmental Impacts of Operation

and there is little or no likelihood of any impact during the renewal period the contributions to

cumulative impacts to Federally listed threatened or endangered species due to continued

operation of Monticello and its transmission lines is.SMALL and no mitigation is warranted.

4.8.7 Conclusions Regarding Cumulative Impacts

The staff considered the potential impacts resulting from operation of Monticello during the

license renewal term and other past, present, and future actions in the vicinity of Monticello.

For each impact area, the staff has determined that the potential cumulative impacts resulting

from Monticello operation during the license renewal term are SMALL, and mitigation is not

warranted.

rE

4.9 Summary of Impacts of Operations During the Renewal

Term

Neither NMC nor the staff -is aware of information that is both new and significant related to any

of the applicable Category-1 issues associated with the Monticello operations during the

renewal term. Consequently, the staff concludes that the environmental impacts associated

with these issues are bounded by the impacts described in the GELS. For each of these issues,

the GEIS concluded that the impacts would be SMALL and that additional plant-specific

mitigation measures are not likely to be sufficiently beneficial to warrant implementation.

Plant-specific environmental evaluations were conducted for 13 Category 2 issues applicable to

Monticello operations during the renewal term, and for environmental justice and chronic effects

of electromagnetic fields. For1 3 issues and environmental justice, the staff concluded that the

potential environmental impacbof renewal term operations of Monticello would be of SMALL

significance in the context of the standards set forth in the GElS, and that additional mitigation

would not be warranted. In addition, the staff determined that a consensus has not been

reached by appropriate Federal health agencies regarding chronic adverse effects from

electromagnetic fields. Therefore, the staff did not conduct an evaluation of this issue:

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

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

other actions. For purposes of this :analysis, where Monticello license renewal impacts are

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

cumulative impacts on potentially affected resources.

August 2006 4-49 NUREG-1437, Supplement 26
Environmental Impacts of Operation

4.10 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for

Protection Against Radiation."

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,

Part 800, "Advisory Council on Historic Preservation."

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

"Environmental Radiation Protection Standards for Nuclear Power Operations."

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

1508, "Terminology and Index."

Afzal, M., B.R. Oblad, B.B. Owen, F.P. Richards, and G.C. Slawson. 1975. Effects of a Heated

Discharge on the Ecology of the Mississippi River 316(a) Type I Demonstration on the

Monticello Nuclear Generating Plant, Monticello, Minnesota. Prepared by NUS Corporation,

Pittsburgh, Pennsylvania for Northern States Power Company, Minneapolis, Minnesota.

Amish, R.A., V.R. Kranz, B.D. Lorenz, D.B. Wilcox, L.K. Davis, and B.B. Owen, Jr. 1978.

Section 316(b) Demonstration for the Monticello Nuclear Generating Plant on the Mississippi

River at Monticello, Minnesota (NPDES Permit No. MN 0000868). Prepared by NUS

Corporation, Pittsburgh, Pennsylvania for Northern States Power Company, Minneapolis,

Minnesota.

Bloomberg, B.L. 2005. Letter to James Holthaus "Monticello Nuclear Generating Plant."

Minnesota Historic Preservation Office. Saint Paul, Minnesota. March 30, 2005.

I Bloomberg, B.L. 2006. Letter to Rani Franovich "Monticello Nuclear Generating Plant License

Renewal." Minnesota Historic Preservation Office. Saint Paul, Minnesota. April 26, 2006.

Chick, J.H. 2002. "Asian Carp in the Upper Mississippi River System." Illinois Natural History

Survey Reports. Spring 220, No. 371, p. 6.

Electric Power Research Institute (EPRI). 1987. Transmission Line Reference Book, 345 kV

and Above. Second Edition. Palo Alto, CA.

Executive Order 12898. 1994. "Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations." Federal Register. Volume 59, No. 32, p. 7629.•

Washington, D.C. February 16, 1994.

NUREG-1 437, Supplement 26 4-50 August 2006 1
Environmental Impacts of Operation

Fremling, C., and B. Drazkowski. 2000. Ecological, Institutional, and Economic History of the

Upper Mississippi River. St. Mary's University of Minnesota, Resources Studies Center.

-Accessed at: http://www.umbsn.org/news/documents/UMREcologicaLHistory.htm. Accessed

February 21, 2003.

Genet, J., and J. Chirhart. 2004. Development of a Macroinvertebrate Index of Biological

Integrity (MIBI) for Rivers and Streams of the Upper Mississippi River Basin. Minnesota

Pollution Control Agency, Biological Monitoring Program, St. Paul, Minnesota. Accessed at:

http://www.pca.state.mn.us/publications/reports/biomonitoring-mibi-uppermiss.pdf on

June 17, 2005.

Hornbach, D.J. 2004. Higgins Eye Pearlymussel (Lmsiris hilainsii) Recovery Plan: First

Revision. U.S. Fish and Wildlife Service, Region 3, Ft. Snelling, Minnesota. Accessed at:

http://ecos.fws.gov/docs/recovery-plans/2004/040714.pdf on July 22, 2005.

Joklik, W.K. and H.P. Willett (eds.). 1976. Microbiology. 16th edition. Appelton Centry-Crofts.

New York, NY.

Kelner, D., and M. Davis. 2002. Final Report: Mussel (Bivalvia: Unionidae) Survey of the

Mississippi National River and Recreation Corridor, 2000-01. Contract Report to the National

Park Service Mississippi National River and Recreation Areas and the Great Lakes Network

Inventory and Monitoring Program. Minnesota Department of Natural Resources, Division of

Ecological Services, St. Paul, Minnesota. Accessed at:

http://files.dnr.state.mn.us/ecological-services/nongame/projects/consgrant-reports/2002-kein

er_davis.pdf on August 4, 2005.

Knutson, K.M., S.R. Berguson, D.L. Rastetter, M.W. Mischuk, F.B. May, and G.M. Kuhl. 1976.

Seasonal Pumped Entrainment of Fish at the Monticello, MN Nuclear Power Installation.

Prepared by Department of Biological Sciences, St. Cloud State University, St. Cloud,

Minnesota for Northern States Power Company, Minneapolis, Minnesota.

Minnesota Department of Natural Resources (MNDNR). 2005a. "DNR Water Appropriation

Permits." Accessed at:

http://www.dnr.state.mn.us/waters/watermgmt-section/appropriations/wateruse.html on

August 1, 2005.

Minnesota Department of Natural Resources (MNDNR). 2005b. Invasive Species of Aquatic

Plants & Animals in Minnesota: Annual Report for 2004. Minnesota Department of Natural

Resources, St. Paul, Minnesota. Accessed at:

http:llfiles.dnr.state.mn.us/ecological-services/invasives/annualreport.pdf on June 17, 2005.

Minnesota Pollution Control Agency (MPCA). 1979. "Environmental Issues-NSP Monticello

Nuclear Generating Plant." Letter from T. Hoffman, Minnesota Pollution Control Agency,

August 2006 4-51 NUREG-1437, Supplement 26 1
Environmental Impacts of Operation

St. Paul, Minnesota, to D.E. Sells, U.S. Nuclear Regulatory Commission, Washington, D.C.

September 18, 1979.

Minnesota Pollution Control Agency (MPCA). 2002. National Pollutant Discharge Elimination

System (NPDES) and State Disposal System (SDS) Permit MN 0000868. Minnesota Pollution

Control Agency, Majors and Remediation Division, St. Paul, Minnesota.

National Electrical Safety Code (NESC). 2001. Institute of Electrical and Electric Engineers,

New York.

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

National Historic Preservation Act (NHPA). 16 USC 470, et seq.

National Institute of Environmental Health Sciences (NIEHS). 1999. "NIEHS Report on Health

Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields." Publication

No. 99-4493, Research Triangle Park, North Carolina.

Noguchi, L.S., D.L. Bimber, H.T. Tin, P.J. Mansfield, and D.J. Jude. 1985. "Field Distribution

and Entrainment of Fish Larvae and Eggs at the Donald C. Cook Nuclear Power Plant,

Southeastern lake Michigan, 1980-1982." Special report No. 116 of the Great Lakes Research

Division. Great Lakes and Marine Waters Center, The University of Michigan, Ann Arbor,

Michigan.

Northern States Power Company (NSP). 2004. Monticello Nuclear Generating Plant

Environmental Monitoring Program: 2003-2004. Monticello, Minnesota.

Nuclear Management Company (NMC). 2005a. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

Nuclear Management Company, LLC (NMC). 2005b. E-mail from J. Holthaus, NMC, to

J. Davis, NRC, Ecology Information Request. Monticello, Minnesota. November 18, 2005.

Talmadge, S.S., and D.M. Opreska. 1981. Literature Review: Response of Fish to Thermal

Discharges. EPRI EA-1 840, Research Project 877, ORNL/EIS-1 93. Prepared by Oak Ridge

National Laboratory, Oak Ridge, Tennessee for Electric Power Research Institute, Palo Alto,

California.

Tyndall, R.L., K.S. Ironside, P.L. Metier, E.L. Tan, T.C. Hazen, and C.B. Flierman. 1989.

"Effect of Thermal Additions on the Density and Distribution of a Thermophilic Amoebae and

Pathogenic Naegleria Fowleri in a Newly Created Cooling Lake." Applied and Environmental

Microbiology. 55(3): 722-732.

NUREG-1437, Supplement 26 4-52 August 2006
Environmental Impacts of Operation

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Monticello Nuclear Generating Plant. Northern States Power Company. Docket

No. 50-263. November 1972.

U.S. Census Bureau (USCB). 2000. Census 2000 Demographic Profile Highlights. Accessed

at: http://factfinder.census.gov/sevlet on August 4, 2005.

U.S. Census Bureau (USCB). 2001. Glossary of Basic Geographic and Related Terms -

Census 2000. Accessed at: http:llwww.census.gov/geo/Www/tiger/glossary.html#glossary on

December 21, 2005.

U.S. Environmental Protection Agency (EPA). 2004. "National Pollutant Discharge Elimination

System-Final Regulations to Establish Requirements for Cooling Water Intake Structures at

Phase II Existing Facilities." Federal Register, Vol. 68. pp. 41576-41693. July 9, 2004.

U.S. Fish and Wildlife Service (FWS). 2005. "List of Federally Threatened or Endangered

Species." Letter from D.P. Stinnett, U.S. Fish and Wildlife Service, Bloomington, Minnesota, to

P.T. Kuo, U.S. Nuclear Regulatory Commission, Washington, D.C. July 13, 2005.

U.S. Geological Service (USGS). 2004. Asian Carp. U.S.: Geological Survey, Upper Midwest

Environmental Sciences Center, La Crosse, Wisconsin. Accessed at:

http://www.umesc.usgs.gov/invasive-species/asian-carp.html on September 3, 2005.

U.S. Geological Survey (USGS). 2005. "USGS 05270700 MISSISSIPPI RIVER AT ST.

CLOUD, MN." Accessed at:

http://waterdata.usgs.gov/nwis/discharge?search-criteria=station_nm&submitted_form=introduc

tion on August 1, 2005.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

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

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

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004a. Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues. Office of Nuclear Reactor

Regulation Office Instruction LIC-203, Revision 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004b. "Treatment of Environmental Justice

Matters in NRC Regulatory and Licensing Actions." Federal Register, Vol. 69, No. 163,

pp. 52040-52049. Washington, D.C. August 24, 2004.

August 2006 4-53 NUREG-1437, Supplement 26 I
Environmental Impacts of Operation

U.S. Nuclear Regulatory Commission (NRC). 2005a. Letter from P.T. Kuo, Program Director,

Office of Nuclear Reactor Regulation to D.P. Stinnett, Field Supervisor, U.S. Fish and Wildlife

Service, Bloomington, Minnesota. June 3, 2005.:-1

U.S. Nuclear Regulatory Commission (NRC). 2005b. Letter from P.T. Kuo, Program Director,

Office of Nuclear Reactor Regulation to D. Klima, Director, Advisory Council on Historic

Preservation, Washington, D.C. May 27, 2005.:

U.S. Nuclear Regulatory Commission (NRC). .2005c. Letter from P.T. Kuo, Program Director,

Office of Nuclear Reactor Regulation to N. Archabal, State Historic Preservation Officer,

Minnesota State Historical Society, St. Paul, Minnesota. June 2, 2005.

U.S. Nuclear Regulatory Commission (NRC). 2005d. Letter from NRC to D. Stinnett, Field

Supervisor, U.S. Fish and Wildlife Service (FWS). Subject: Biological Assessment for

Monticello Nuclear Generating Plant License Renewal Review. December 22, 2005.

Weitzell, R.E., Jr., M.L. Khoury, P. Gagnon, B. Schreurs, D. Grossman, and J. Higgins. 2003.

Conservation Priorities for Freshwater Biodiversity in the Upper Mississippi River Basin. Nature

Serve and The Nature Conservancy, Arlington, Virginia. Accessed at:

http://www.natureserve.org/library/uppermsriverbasin.pdf on June 17, 2005.

Xcel Energy Environmental Services, U.S. Fish and Wildlife Service, Minnesota Department of

Natural Resources, North Dakota State Game and Fish Department, South Dakota Game,- Fish

and Parks Department (Xcel Energy et al.). 2002. Memorandum of Understanding.

April 19, 2002.

Xcel Energy Environmental Services (Xcel Energy). 2004. Monticello Nuclear Generating Plant

Environmental Monitoring Program 2002 - 2003 Report. Prepared by Xcel Energy

Environmental Services for Northern:States Power Company, Minneapolis, Minnesota.

Xcel Energy Environmental Services (Xcel Energy). 2005. "Vegetation Management

Guidelines." March 2005.

NUREG-1437, Supplement 26 4-54 August 2006 - I
5.0 Environmental Impacts of Postulated Accidents

Environmental issues associated with postulated accidents are discussed in the Generic

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

Volumes 1 and 2 (NRC 1996, 1999).(a) The GElS includes a determination of whether the

analysis of the environmental issue could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GElS, Category 1 issues are those that meet all of

the following criteria:

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

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

system or other specified plant or site characteristics.

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

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

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

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

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

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

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

required unless new and significant information is identified.

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

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

This chapter describes the environmental impacts from postulated accidents that might occur

during the license renewal term.

5.1 Postulated Plant Accidents

Two classes of accidents are evaluated in the GELS. These are design-basis accidents (DBAs)

and severe accidents, as discussed below.

5.1.1 Design-Basis Accidents

In order to receive NRC approval to operate a nuclear power facility, an applicant for an initial

operating license must submit a safety analysis report (SAR) as part of its application. The

(a) The GElS was originally issued in 1996. Addendum I to the GElS was issued In 1999. Hereafter, all references

to the 'GELS" include the GElS and its Addendum 1.

August 2006 5-1 NUREG-1437, Supplement 26 1
Environmental Impacts of Postulated Accidents

SAR presents the design criteria and design information for the proposed reactor and

comprehensive data on the proposed site. The SAR also discusses various hypothetical

accident situations and the safety features that are provided to prevent and mitigate accidents.

The NRC staff reviews the application to determine whether the plant design meets the

Commission's regulations and requirements and includes, in part, the nuclear plant design and

its anticipated response to an accident.

DBAs are those accidents that both the licensee and the NRC staff evaluate to ensure that the

plant can withstand normal and abnormal transients, and a broad spectrum of postulated

accidents, without undue hazard to the health and safety of the public. A number of these

postulated accidents are not expected to occur during the life of the plant, but are evaluated to

establish the design basis for the preventive and mitigative safety systems of the facility. The

acceptance criteria for DBAs are described in Title 10 of the Code of Federal Regulations

(CFR) Part 50 and 10 CFR Part 100.

The environmental impacts of DBAs are evaluated during the initial licensing process, and the

ability of the plant to withstand these accidents is demonstrated to be acceptable before

issuance of the operating license (OL). The results of these evaluations are found in license

documentation such as the applicant's final safety analysis report (FSAR), the staff's safety

evaluation report (SER), the final environmental statement (FES), and Section 5.1 of.this

supplemental environmental impact statement (SEIS). A licensee is required to maintain the

acceptable design and performance criteria throughout.the life of the plant, including any

extended-life operation. The consequences for these events are evaluated for the hypothetical

maximum exposed individual; as such, changes in the plant environment will not affect these

evaluations. Because of the requirements that continuous acceptability of the consequences

and aging management programs be in effect for license renewal, the environmental impacts

as calculated for DBAs should not differ significantly from initial licensing assessments over the

life of the plant, including the license renewal period. Accordingly, the design of the plant

relative to DBAs during the extended period is considered to remain acceptable and the

environmental impacts of those accidents were not examined further in the GELS.

The Commission has determined that the environmental impacts of DBAs are of SMALL

significance for all plants because the plants were designed to successfully withstand these

accidents. Therefore, for the purposes of license renewal, DBAs are designated as a Category

1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The early resolution of the DBAs

makes them a part of the current licensing basis of the plant; the current licensing basis of the

plant is to be maintained by the licensee under its current license and, therefore, under the

provisions of 10 CFR 54.30, is not subject to review under license renewal. This issue,

applicable to Monticello, is listed in Table 5-1.

NUREG-1437, Supplement 26 5-2 August 2006 1
Environmental Impacts of Postulated Accidents

Table 5-1. Category I Issue Applicable to Postulated Accidents During

the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

POSTULATED AccIDENTS

Design basis accidents 5.3.2; 5.5.1

Based on information in the GELS, the Commission found that:

The NRC staff has concluded that the environmental impacts of design basis accidents

are of small significance for all plants.

Nuclear Management Company (NMC) stated in its Environmental Report (ER) (NMC 2005a)

that it is not aware of any new and significant information associated with the renewal of the

Monticello OL. The staff has not identified any new and significant information during its

independent review of the NMC ER, the staff's site visit, the scoping process, its evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no impacts related to design basis accidents beyond those discussed

in the GElS.

5.1.2 Severe Accidents

Severe nuclear accidents are those that are more severe than DBAs because they could result

in substantial damage to the reactor core, whether or not there are serious offsite

consequences. In the GELS, the staff assessed the impacts of severe accidents during the

license renewal period, using the results of existing analyses and site-specific information to

conservatively predict the environmental impacts of severe accidents for each plant during the

renewal period.

Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes,

fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and

were not specifically considered for the Monticello site in the GElS (NRC 1996). However, in

the GElS, the NRC staff did evaluate existing impact assessments performed by the NRC and

by the industry at 44 nuclear plants in the United States and concluded that the risk from

beyond design-basis earthquakes at existing nuclear power plants is SMALL. Additionally, the

NRC regulatory requirements under 10 CFR Part 73 provide reasonable assurance that the risk

from sabotage is SMALL. Furthermore, the NRC staff concluded that the risks from other

external events are adequately addressed by a generic consideration of internally initiated

severe accidents.

August 2006 5-3 NUREG-1437, Supplement 26 I
Environmental Impacts of Postulated Accidents

Based on information in the GELS, the Commission found that:

The probability weighted consequences of atmospheric releases, fallout onto open

bodies of water, releases to groundwater, and societal and economic impacts from

severe accidents are small for all plants. However, alternatives to mitigate severe

accidents must be considered for all plants that have not considered such alternatives.

Therefore, the Commission has designated mitigation of severe accidents as a Category 2

issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-I. This issue, applicable to

Monticello, is listed in Table 5-2.

Table 5-2. Category 2 Issue Applicable to Postulated Accidents During

the Renewal Term

ISSUE-b10 CFR Part 51, Subpart 10 CFR 51.53(c)(3)(ii) SEIS

A, Appendix B, Table B-1 GElS Sections Subparagraph Section

POSTULATED ACCIDENTS

Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3; L 5.2

5.3.3.4; 5.3.3.5; 5.4; 5.5.2

The staff has not identified any new and significant information with regard to the

consequences from severe accidents during its independent review of the NMC ER, the staff's

site visit, the scoping process, its evaluation of other available information, or public comments

on the draft SEIS. Therefore, the staff concludes that there are no impacts of severe accidents

beyond those discussed in the GELS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L),

the staff has reviewed severe accident mitigation alternatives (SAMAs) for Monticello. The

results of its review are discussed in Section 5.2.

5.2 Severe Accident Mitigation Alternatives

10 CFR 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to

mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicant's

plant in an environmental impact statement (EIS) or related supplement or in an environmental

assessment. The purpose of this consideration is to ensure that plant changes (i.e., hardware,

procedures, and training) with the potential for improving severe accident safety performance

are identified and evaluated. SAMAs have not been previously considered for Monticello;

therefore, the remainder of Chapter 5 addresses those alternatives.

NUREG-1437, Supplement 26 5-4 August 2006 1
Environmental Impacts of Postulated Accidents

5.2.1 Introduction

This section presents a summary of the SAMA evaluation for Monticello conducted by NMC,

and described in the ER, and the NRC's review of this evaluation. The details of the review are

described in the NRC staff evaluation that was prepared with contract assistance from

Information Systems Laboratories, Inc. The entire evaluation for Monticello is presented in

Appendix G.

The SAMA evaluation for Monticello was conducted with a four-step approach. In the first step

NMC quantified the level of risk associated with potential reactor accidents using the

plant-specific probabilistic safety assessment (PSA) and other risk models.

In the second step NMC examined the major risk contributors and identified possible ways

(SAMAs) of reducing that risk. Common ways of reducing risk are changes to components,

systems, procedures, and training. NMC initially identified 40 potential SAMAs for Monticello.

NMC screened out 24 SAMAs from further consideration because they are not applicable at

Monticello due to design differences, require extensive changes that would involve

implementation costs known to exceed any possible benefit, or exceed the dollar value

associated with completely eliminating all internal and external event severe accident risk at

Monticello. The remaining 16 SAMAs were subjected to further evaluation. During the second

phase of the evaluation, NMC screened out one additional SAMA based on risk insights and

other factors, leaving 15 SAMAs.

In the third step NMC estimated the benefits and the costs associated with each of the

remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those

estimates were developed in terms of dollars in accordance with NRC guidance for performing

regulatory analyses (NRC 1997a,b). The cost of implementing the proposed SAMAs was also

estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were

compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the

SAMA were greater than the cost (a positive cost-benefit). NMC found seven SAMAs to be

potentially cost-beneficial in the baseline analysis, and three additional SAMAs to be potentially

cost-beneficial when alternative discount rates and analysis uncertainties are considered (NMC

2005a).

NMC recognized that a combination of low-cost SAMAs can provide much of the risk reduction

associated with higher-cost SAMAs, and may act synergistically to yield a combined risk

reduction greater than the sum of the benefits for each SAMA if implemented individually.

Since the ER was submitted, NMC has implemented six SAMAs, and reassessed the value of

the remaining SAMAs. Implementation of the six SAMAs reduces the benefit of the remaining

SAMAs such that only one SAMA remains potentially cost-beneficial.

August 2006 5-5 NUREG-1437, Supplement 26 I
Environmental Impacts of Postulated Accidents

The one potentially cost-beneficial SAMA does not relate to adequately managing the effects of

aging during the period of extended operation; therefore, it need not be implemented as part of

license renewal pursuant to 10 CFR Part 54. NMC indicates that it plans to further evaluate the

potentially cost-beneficial SAMA for possible implementation. NMC's SAMA analyses and the

NRC's review are discussed in more detail below.

5.2.2 Estimate of Risk

NMC submitted an assessment of SAMAs for Monticello as part of the ER (NMC 2005a). This

assessment was based on a slight modification of the 2003 Level 1 and Level 2 PSA model, a

plant-specific offsite consequence analysis performed using the MELCOR Accident

Consequence Code System 2 (MACCS2) computer program, and insights from the Monticello

Individual Plant Examination (IPE) (NSP 1992) and Individual Plant Examination of External

Events (IPEEE) (NSP 1995a,b).

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 4.5 x 10*5 per year. This CDF is based on the risk assessment for internally

initiated events. NMC did not include the contribution to risk from external events within the

Monticello risk estimates; however, it did account for the potential risk reduction benefits

associated with external events by increasing the estimated benefits for internal events by a

factor of two. The breakdown of CDF by initiating event is provided in Table 5-3.

Table 5-3. Monticello Core Damage Frequency for Internal Events

CDF % Contribution

Initiating Event (per year) to CDF

Fire protection system (FPS) line break in turbine building 3.2 x 10-5 71

(TB) 931-ft elevation west

Service water (SW) line break in TB 931-ft elevation west 5.8 x 10-4 13

SW line break in TB 911 -ft elevation 1.8 x 106 4

Loss of offsite power 1.8 x 10- 4

SW line break in residual heat removal (RHR) A room 8.9 x 10-7 2

SW line break in RHR B room 8.9 x 10"7 2

SW line break in reactor building 896-ft elevation 4.5 x 10"7 1

Turbine trip 4.5 x 10.7 1

Loss of feedwater 4.5 x 107 1

Other 4.5 x 10"7 1

Total CDF (internal events) 4.5 x 10-1 100

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As shown in Table 5-3, internal flood events initiated by FPS and SW pipe breaks are the

dominant contributors to CDF. Loss of offsite power and other transient initiators contribute

about 6 percent of the CDF.

In the ER, NMC estimated the dose to the population within 50 mi of the Monticello site to be

approximately 38 person-rem per year. The breakdown of the total population dose by

containment release mode is summarized in Table 5-4. Containment failures within the late

time frame (greater than 6 hours following declaration of a general emergency) and early time

frame (less than 6 hours following declaration of a general emergency) provide similar

contributions to the population dose risk at Monticello.

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

Population Dose

Containment Release Mode (person-rem(s) per year) % Contribution

Late containment failure 20.4 54

Early containment failure 17.6 46

Intact containment Negligible Negligible

Total 38 100

(a) 1 person-rem per year = 0.01 person-Sv per year

The NRC staff has reviewed NMC's data and evaluation methods and concludes that the quality

of the risk analyses is adequate to support an assessment of the risk reduction potential for

candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs and

offsite doses reported by NMC.

5.2.3 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, NMC searched for ways to reduce

that risk. In identifying and evaluating potential SAMAs, NMC considered insights from the

plant-specific PSA, SAMA analyses performed for other operating plants that have submitted

license renewal applications, as well as SAMAs that could further reduce the risk of the

dominant internal fires. NMC identified 40 potential risk-reducing improvements (SAMAs) to

plant components, systems, procedures and training.

Twenty-four SAMAs were removed from further consideration because they are not applicable

at Monticello due to design differences, require extensive changes that would involve

implementation costs known to exceed any possible benefit, or exceed the dollar value

associated with completely eliminating all internal and external event severe accident risk at

Monticello. The remaining 16 SAMAs were subjected to further evaluation. During the second

phase of the evaluation, NMC screened out one additional SAMA based on risk insights and

August 2006 .' 5-7 NUREG-1437, Supplement 26 I
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other factors. A detailed cost-benefit analysis was performed for each of the 15 remaining

SAMAs.

The staff concludes that NMC used a systematic and comprehensive process for identifying

potential plant improvements for Monticello, and that the set of potential plant improvements

identified by NMC is reasonably comprehensive and, therefore, acceptable.

5.2.4 Evaluation of Risk Reduction and Costs of Improvements

NMC evaluated the risk-reduction potential of the remaining 15 SAMAs. The SAMA evaluations

were performed using realistic assumptions with some conservatism.

NMC estimated the costs of implementing the 15 candidate SAMAs through the application of

engineering judgement, use of other licensees' estimates for similar improvements, and

development of site-specific cost estimates. The cost estimates conservatively did not include

the cost of replacement power during extended outages required to implement the

modifications, nor did they include contingency costs associated with unforeseen

implementation obstacles.

The staff reviewed NMC's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and somewhat conservative (i.e., the estimated risk reduction is similar to or

somewhat higher than what would actually be realized).. Accordingly, the staff based its

estimates of averted risk for the various SAMAs on NMC's risk reduction estimates.

The staff reviewed the bases for the applicant's cost estimates. For certain improvements, the

staff also compared the cost estimates to estimates developed elsewhere for similar

improvements, including estimates developed as part of other licensees' analyses of SAMAs for

operating reactors and advanced light-water reactors. The staff found the cost estimates to be

consistent with estimates provided in support of other plants' analyses.

The staff concludes that the risk reduction and the cost estimates provided by NMC are

sufficient and appropriate for use in the SAMA evaluation.

5.2.5 Cost-Benefit Comparison

The cost-benefit analysis performed by NMC was based primarily on NUREG/BR-01 84 (NRC

.1 997b) and was executed consistent with this guidance. NUREG/BR-0058 has recently been

revised to reflect the agency's revised policy on discount rates. Revision 4 of NUREG/BR-0058

states that two sets of estimates should be developed-one at three percent and one at seven

percent (NRC 2004). NMC provided both sets of estimates (NMC 2005a).

NMC identified seven potentially cost-beneficial SAMAs in the baseline analysis contained in

the ER (using a seven-percent discount rate):

NUREG-1437, Supplement 26 5-8 August 2006 1
Environmental Impacts of Postulated Accidents

0 SAMA 2-enhance DC power availability by providing a direct connection from diesel

generator 13, the security diesel, or another source, to the 250-V battery chargers or other.

required loads.

* SAMA 4-install a direct-drive diesel injection pump as additional high-pressure injection

system.

• SAMA 6-install additional fan and louver pair for emergency diesel generator heating,

ventilation, and air conditioning.

* SAMA 11--enhance alternate injection reliability by including the residual heat removal

service water and fire service water cross-tie valves in the maintenance program.

* SAMA 12-proceduralize the use of a fire pumper truck to pressurize the fire service water

system.

" SAMA 16-provide passive overpressure relief by changing the containment vent valves to

fail open and improving the strength of the rupture disk.

" SAMA 36--install an interlock to open the door to hot machine shop and change swing

direction of door to plant administration building to divert water from turbine building

931-foot elevation east.

When benefits are evaluated using a three-percent discount rate, two additional SAMAs were

determined to be potentially cost-beneficial:

* SAMA 39-upgrade the automatic shutdown system (ASDS) panel to include additional

system controls for opposite division.

* SAMA 40-add emergency level control sensor and control valve to the hotwell.

NMC performed additional analyses to evaluate the impact of parameter choices and

uncertainties on the results of the SAMA assessment (NMC 2005a). If the benefits are

increased by a factor of 2.5 to account for uncertainties, one additional SAMA (SAMA 9,

dedicated alternate low-pressure injection/drywell spray system) was determined to be

potentially cost-beneficial.

NMC recognized that a combination of low-cost SAMAs could provide much of the risk

reduction associated with higher-cost SAMAs, and may act synergistically to yield a combined

risk reduction greater than the sum of the benefits of each SAMA if implemented individually

(NMC 2005a). NMC identified six low-cost SAMAs as a recommended combination of SAMAs

which substantially reduces risk at Monticello for a relatively low cost of implementation. These

include previously identified SAMAs 2, 11, 12, and 36, and two additional SAMAs not identified

as being cost-beneficial:

August 2006 5-9 NUREG-1437, Supplement 26 1
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* SAMA 28-develop a procedure to refill the condensate storage tank with fire service water

system.

0 SAMA 37-develop guidance to allow local, manual control for reactor core isolation cooling

system operation.

Since the ER was submitted, NMC has implemeted the six recommended SAMAs (SAMAs 2,

11, 12, 28, 36, and 37), and has reassessed the value of the remaining SAMAs.

Implementation of the six recommended SAMAs reduces the benefit of the remaining SAMAs

(including SAMA 9, which was identified as a result of the uncertainty analysis), such that only

one SAMA that has no been implemented yet, remains potentially cost-beneficial. SAMA 16

(passive overpressure relief for containment) becomes even more cost-beneficial because the

set of SAMAs implemented by NMC shifts the risk to categories influenced by containment

venting, which could be mitigated by SAMA 16. NMC stated that the improvement is being

pursued to determine if cost-effective modifications can be implemented (NMC 2005b).

The staff concludes that, with the exception of the one potentially cost-beneficial SAMA

discussed above, the costs of the SAMAs evaluated would be higher than the associated

benefits.

5.2.6 Conclusions

The staff reviewed NMC's analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

support the general conclusion that the SAMA evaluations performed by NMC are reasonable

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external

events was somewhat limited by the unavailability of an external event PSA, the likelihood of

there being cost-beneficial enhancements in this area was minimized by including several

candidate SAMAs related to dominant fire events, and increasing the estimated SAMA benefits

for internal events by a factor of two to account for potential benefits in external events.

Based on its review of the SAMA analysis, and on the implementation of the six recommended

low-cost SAMAs by NMC, the staff concurs with NMC's identification of areas in which risk can

be further reduced in a cost-beneficial manner through the implementation of one potentially

cost-beneficial SAMA. Given the potential for cost-beneficial risk reduction, the staff agrees

that further evaluation of this SAMA by NMC is warranted. However, this potentially

cost-beneficial SAMA does not relate to adequately managing the effects of aging during the

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

renewal pursuant to 10 CFR Part 54.

NUREG-1437, Supplement 26 5-10 August 2006 1
Environmental Impacts of Postulated Accidents

5.3 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing

of Production and Utilization Facilities."

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site

Criteria."

Northern States Power Company (NSP). 1992. Letter from Thomas M. Parker, NSP, to U.S.

NRC Document Control Desk. Subject: "Monticello Nuclear Generating Plant, Docket No.

50-263, License No. DPR-22, Submittal of Monticello Individual Plant Examination (IPE)

Report," February 27, 1992.

Northern States Power Company (NSP). 1995a. Letter from W.J. Hill, NSP, to U.S. NRC

Document Control Desk. Subject: "Monticello Nuclear Generating Plant, Docket No. 50-263,

License No. DPR-22, Submittal of Monticello Individual Plant Examination of External Events

(IPEEE) Report," March 1, 1995.

Northern States Power Company (NSP). 1995b. Letter from W.J. Hill, NSP, to U.S. NRC

Document Control Desk. Subject: "Monticello Nuclear Generating Plant, Docket No. 50-263,

License No. DPR-22, Submittal of Monticello Individual Plant Examination of External Events

(IPEEE) Report, Revision 1; Seismic Analysis, Revision 0, and Internal Firest Analysis,

Revision 1 (TAC M83644)," November 20, 1995.

Nuclear Management Company (NMC). 2005a. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

Nuclear Management Company (NMC). 2005b. Letter from John T. Conway, NMC to U.S.

NRC Document Control Desk. Subject: "Response to Request for Additional Information

Regarding Severe Accident Mitigation Alternatives for the Monticello Nuclear Generating Plant

(TAC MC6441 )," July 27, 2005.

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

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

August 2006 5-11 NUREG-1437, Supplement 26 1
Environmental Impacts of Postulated Accidents

U.S. Nuclear Regulatory Commission (NRC). 1997a. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. Regulatory Analysis Technical

Evaluation Handbook. NUREG/BR-0184, Washington, D.C.

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

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

Summary of findings on NEPA issues for license renewal of nuclear power plants.

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

-f

NUREG-1 437, Supplement 26 5-12 August 2006 1
6.0 Environmental Impacts of the Uranium

Fuel Cycle and Solid Waste Management

Environmental issues associated with the uranium fuel cycle and solid waste management are

discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear

Plants (GELS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999).(a) The GElS includes a

determination of whether the analysis of the environmental issue could be applied to all plants

and whether additional mitigation measures would be warranted. Issues are then assigned a

Category 1 or a Category 2 designation. As set forth in the GELS, Category 1 issues are those

that meet all of the following criteria:

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

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

system or other specified plant or site characteristics.

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

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

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

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

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

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

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

required unless new and significant information is identified.

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

therefore, additional plant-specific review of these issues is required. There are no Category 2

issues for the uranium fuel cycle and solid waste management.

This chapter addresses the issues that are related to the uranium fuel cycle and solid waste

management during the license renewal term that are listed in Table B-1 of Title 10 of the Code

of Federal Regulations (CFR) Part 51, Subpart A, Appendix B, and are applicable to Monticello.

The generic potential impacts of the radiological and nonradiological environmental impacts of

the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in

the GElS based, in part, on the generic impacts provided in 10 CFR 51.51 (b), Table S-3, "Table

of Uranium Fuel Cycle Environmental Data," and in 10 CFR 51.52(c), Table S-4, "Environmental

Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear

Power Reactor." The staff also addresses the impacts from radon-222 and technetium-99 in

the GElS.

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

to the "GEIS" include the GElS and its Addendum 1.

August 2006 6-1 NUREG-1437, Supplement 26 I
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6.1 The Uranium Fuel Cycle

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

Monticello from the uranium fuel cycle and solid waste management are listed in Table 6-1.

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

Management During the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

URANIUM FUEL CYCLE AND WASTE MANAGEMENT

Offsite radiological impacts (individual effects from other than 6.1; 6.2.1; 6.2.2.1;

the disposal of spent fuel and high-level waste 6.2.2.3; 6.2.3; 6.2.4;

6.6

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4;

6.6

Offsite radiological impacts (spent fuel and HLW disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4;

6.6

Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7;

6.2.2.8; 6.2.2.9; 6.2.3;

6.2.4; 6.6

Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3;

6.4.3.1; 6.4.3.2; 6.4.3.3;

6.4.4; 6.4.4.1; 6.4.4.2;

6.4.4.3; 6.4.4.4; 6.4.4.5;

6.4.4.5.1; 6.4.4.5.2;

6.4.4.5.3; 6.4.4.5.4;

6.4.4.6; 6.6

Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3;

6.4.5.4; 6.4.5.5; 6.4.5.6;

6.4.5.6.1; 6.4.5.6.2;

6.4.5.6.3; 6.4.5.6.4; 6.6

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

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2;

6.5.3; 6.6

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3;

6.3.4; 6.6, Addendum 1

Nuclear Management Company (NMC) stated in its Environmental Report (ER) (NMC 2005)

that it is not aware of any new and significant information associated with the renewal of the

NUREG-1 437, Supplement 26 6-2 August 2006
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

Monticello operating license (OL). The staff has not identified any new and significant

information during its independent review of the NMC ER, the staff's site visit, the scoping

process, its evaluation of other available information, or public comments on the draft SEIS.

Therefore, the staff concludes that there are no impacts related to these issues beyond those

discussed in the GELS. For these issues, the staff concluded in the GElS that the impacts are

SMALL except for the collective offsite radiological impacts from the fuel cycle and from HLW

and spent fuel disposal, as discussed below, and that additional plant-specific mitigation

measures are not likely to be sufficiently beneficial to be warranted.

A brief description of the staff review and the GElS conclusions, as codified in Table B-i,

10 CFR Part 51, for each of these issues follows:

Offsite radiological impacts (individual effects from other than the disposal of spent fuel and

HLW). Based on information in the GElS, the Commission found that

Off-site impacts of the uranium fuel cycle have been considered by the

Commission in Table S-3 of [10 CFR 51.51 (b)]. Based on information in the

GELS, impacts on individuals from radioactive gaseous and liquid releases

including radon-222 and te.chnetium-99 are small.

The staff has not identified any new and significant information on this issue during its

independent review of the NMC ER, the staff's site visit, the scoping process, its evaluation of

other available information, or public comments on the draft SEIS. Therefore, the staff

concludes that there are no offsite radiological impacts of the uranium fuel cycle during the

renewal term beyond those discussed in the GELS.

* Offsite radiological impacts (collective effects). In the GELS, the staff found that

The 100-year environmental dose commitment to the U.S. population from the

fuel cycle, HLW and spent fuel disposal excepted, is calculated to be about

14,800 person rem, or 12 cancer fatalities, for each additional 20-year power

reactor operating term. Much of this, especially the contribution of radon

releases from mines and tailing piles, consists of tiny doses summed over large

populations. This same dose calculation can theoretically be extended to include

many tiny doses over additional thousands of years as well as doses outside the

U.S. The result of such a calculation would be thousands of cancer fatalities

from the fuel cycle, but this result assumes that even tiny doses have some

statistical adverse health effect which will not ever be mitigated (for example no

cancer cure in the next thousand years), and that these doses projected overt

thousands of years are meaningful. However, these assumptions are

questionable. In particular, science cannot rule out the possibility that there will

be no cancer fatalities from these tiny doses. For perspective, the doses are

very small fractions of regulatory limits, and even smaller fractions of natural

background exposure to the same populations.

August 2006 6-3 NUREG-1437, Supplement 26 1
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Nevertheless, despite all the uncertainty, some judgement as to the regulatory

National Environmental Policy Act (NEPA) implications of these matters should

be made and it makes no sense to repeat the same judgement in every case.

Even taking the uncertainties into account, the Commission concludes that these

impacts are acceptable in that these impacts would not be sufficiently large to

require the NEPA conclusion, for any plant, that the option of extended operation

under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission

has not assigned a single level of significance for the collective effects of the fuel

cycle, this issue is considered Category 1.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

I information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no offsite radiological impacts (collective effects) from the uranium fuel cycle during the

renewal term beyond those discussed in the GELS.

I ° Offsite radiological impacts (spent fuel and HLW disposal). Based on information in the

GELS, the Commission found that

For the HLW and spent fuel disposal component of the fuel cycle, there are no

current regulatory limits-for offsite releases of radionuclides for the current

candidate repository site. However, if we assume that limits are developed along

the lines of the 1995 National Academy of Sciences (NAS) report, "Technical

Bases for Yucca Mountain Standards," and that in accordance with the

Commission's Waste Confidence Decision, 10 CFR 51.23, a repository can and

likely will be developed at some site which will comply with such limits, peak

doses to virtually all individuals will be 100 mrem 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 mrem 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 mrem per year. The lifetime individual

risk from 100 mrem 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

U.S. Department of Energy in the Final Environmental Impact Statement:

Management of Commercially Generated Radioactive Waste [DOE 1980]. The

evaluation estimated the 70-year whole-body dose commitment to the maximum

individual and to the regional population resulting from several modes of

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Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

breaching a reference repository in the year of closure, after 1000 years, after

100,000 years, and after 100,000,000 years. S-ubsequently, the NRC and other

Federal agencies have expended considerable effort to develop models for the

design and for the licensing of a HLW repository, especially for the candidate

repository at Yucca Mountain. More meaningful estimates of doses to population

may be possible in the future as more is understood about the performance of

the proposed Yucca Mountain repository. Such estimates would involve very

great uncertainty, especially with respect to cumulative population doses over

thousands of years. The standard proposed by the NAS is a limit on maximum

individual dose. The relationship of potential new regulatory requirements,

based on the NAS report, and cumulative population impacts has not been

determined, although the report articulates the view that protection of individuals

will adequately protect the population for a repository at Yucca Mountain.

However, EPA's generic repository standards in 40 CFR Part 191 generally

provide an indication of the order of magnitude of cumulative risk to population

that could result from the licensing of a Yucca Mountain repository, assuming the

ultimate standards will be within the range of standards now under consideration.

The standards in 40 CFR Part 191 protect the population by imposing "containment requirements" that limit the cumulative amount of radioactive

material released over 10,000 years. Reporting performance standards that will

be required by EPA are expected to result in releases and associated health

consequences in the range between 10 and 100 premature cancer deaths with

an upper limit of 1000 premature cancer deaths worldwide for a 100,000 metric

tonne (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgement as to the regulatory

NEPA implications of these matters should be made and it makes no sense to

repeat the same judgement in every case. Even taking the uncertainties into

account, the Commission concludes that these impacts are acceptable in that

these impacts would not be sufficiently large to require the NEPA conclusion, for

any plant, that the option of extended operation under 10 CFR Part 54 should be

eliminated. Accordingly, while the Commission has not assigned a single level of

significance for the impacts of spent fuel and HLW disposal, this issue is

considered Category 1.

On February 15, 2002, based on a recommendation by the Secretary of the Department of

Energy, the President recommended the Yucca Mountain site for the development of a

repository for the geologic disposal of spent nuclear fuel and high-level nuclear waste. The

U.S. Congress approved this recommendation on July 9, 2002, in Joint Resolution 87, which

designated Yucca Mountain as the repository for spent nuclear waste. On July 23,.2002, the

President signed Joint Resolution 87 into law; Public Law 107-200, 116 Stat. 735 (2002)

approved Yucca Mountain as the site for the development of a repository for the disposal of

high-level radioactive waste and spent nuclear fuel. This development does not represent new

August 2006 6-5 NUREG-1437, Supplement 26 1
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

and significant information with respect to the offsite radiological impacts from license renewal

related to disposal of spent nuclear fuel and high-level nuclear waste.

- The EPA developed Yucca Mountain-specific repository standards, which were subsequently

adopted by the NRC in 10 CFR Part 63. In an opinion, issued July 9, 2004, the U.S. Court of

Appeals for the District of Columbia Circuit (the Court) vacated EPA's radiation protection

standards for the candidate repository, which required compliance with certain dose limits over

a 10,000 year period. The Court's decision also vacated the compliance period in NRC's

licensing criteria for the candidate repository in 10 CFR Part 63. In response to the Court's

decision, the EPA issued its proposed revised standards on August 22, 2005 (Federal Register,

Volume 40, page 49014 [70 FR 49014]). In order to be consistent with the EPA's revised

standards, the NRC proposed revisions to 10 CFR Part 63 on September 8, 2005

(70 FR 53313).

Therefore, for the HLW and spent fuel disposal component of the fuel cycle, there is some

uncertainty with respect to regulatory limits for offsite releases of radioactive nuclides for the

current candidate repository site. However, prior to promulgation of the affected provisions of

the Commission's regulations, the staff assumed that limits would be developed along the lines

of the 1995 National Academy of Sciences report, Technical Bases for Yucca Mountain

Standards, and that in accordance with the Commission's Waste Confidence Decision, 10 CFR

51.23, a repository that would comply with such limits could and likely would be developed at

some site.

Despite the current uncertainty with respect to these rules, some judgment as to the regulatory

NEPA implications of offsite radiological impacts of spent fuel and HLW disposal should be

made. The staff concludes that these impacts are acceptable in that the impacts would not be

sufficiently large to require the NEPA conclusion that the option of extended operation under 10

CFR Part 54 should be eliminated.

The staff has not identified any new and significant information during its independent review of

I the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no offsite radiological impacts related to spent fuel and HLW disposal during the renewal

term beyond those discussed in the GELS.

Nonradiolopical impacts of the uranium fuel cycle. Based on information in the GELS, the

Commission found that

The nonradiological impacts of the uranium fuel cycle resulting from the renewal

of an operating license for any plant are found to be small.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

I information, or public comments on the draft SEIS. Therefore, the staff concludes that there

NUREG-1 437, Supplement 26 6-6 August 2006 1
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

are no nonradiological impacts of the uranium fuel cycle during the renewal term beyond those

discussed in the GElS.

Low-level waste storage and disposal. Based on information in the GELS, the Commission

found that

The comprehensive regulatory controls that are in place and the low public

doses being achieved at reactors ensure that the radiological impacts to the

environment will remain small during the term of a renewed license. The

maximum additional on-site land that may be required for low-level waste

storage during the term of a renewed license and associated impacts will be

small. 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 lowlevel waste disposal capacity will be made available when needed for facilities to

be decommissioned consistent with NRC decommissioning requirements.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of low-level waste (LLW) storage and disposal associated with the renewal term

beyond those discussed in the GElS.

* Mixed waste stora-qe and disposal. Based on information in the GELS, the Commission

found that

The comprehensive regulatory controls and the facilities and procedures that are

in place ensure proper handling and storage, as well as negligible doses and

exposure to toxic materials for the public and the environment at all plants.

License renewal will not increase the small, continuing risk to human health and

the environment posed by mixed waste at all plants. The radiological and

nonradiological environmental impacts of long-term disposal of mixed waste from

any individual plant at licensed sites are small. In addition, the Commission

concludes that there is reasonable assurance that sufficient mixed waste

disposal capacity will be made available when needed for facilities to be

decommissioned consistent with NRC decommissioning requirements.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of mixed waste storage and disposal associated with the renewal term beyond

those discussed in the GElS.

August 2006 6-7 NUREG-1437, Supplement 26 1
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

Onsite spent fuel. Based on information in the GELS, the Commission found that

The expected increase in the volume of spent fuel from an additional 20 years of

operation can be safely accommodated on site with small environmental effects

through dry or pool storage at all plants if a permanent repository or monitored

retrievable storage is not available.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the.staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of onsite spent fuel associated with license renewal beyond those discussed in

the GELS.

* Nonradioloqical waste. Based on information in the GELS, the Commission found that

No changes to generating systems are anticipated for license renewal. Facilities

and procedures are in place to ensure continued proper handling and disposal at

all plants.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process,its evaluation of other available

information, or. public comments on the draft SEIS. Therefore, the staff concludes that there

are no nonradiological waste impacts during the renewal term beyond those discussed in the

GELS.

* Transportation. Based on information contained in the GELS, the Commission found that

The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with

average burnup for the peak rod to current levels approved by NRC up to

62,000 MWd/MTU and the cumulative impacts of transporting HLW 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 LightWater-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.

Monticello meets the fuel enrichment and burnup conditions set forth in Addendum 1 to the

GELS. The staff has not identified any new and significant information during its independent

review of the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts of transportation associated with license renewal beyond those discussed in the

GElS.

NUREG-1437, Supplement 26 6-8 August 2006 1
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

6.2 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, "Disposal of HighLevel Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada."

40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191,

"Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear

Fuel, High-Level and Transuranic Radioactive Waste."

Energy Policy Act of 1992, Public Law No. 102-486, § 801, 1069 Stat. 2921. (codified at

42 USC 10101 note).

National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards.

Washington, D.C.

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

Nuclear Management Company (NMC). 2005. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License

No. DPR-22. Monticello, Minnesota.

Nuclear Energy Institute, Inc. v. EPA, 373 F.3d 1251, 1273, 1299 (D.C. Cir. 2004).

U.S. Department of Energy (DOE). 1980. Final Environmental Impact Statement:

Management of Commercially Generated Radioactive Waste. DOE/EIS-0046F.

Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2. Washington, D.C.

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

for License Renewal of Nuclear Plants, Main Report. Section 6.3 - Transportation, Table 9.1,

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

August 2006 6-9 NUREG-1437, Supplement 26 1
Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management

U.S. Nuclear Regulatory Commission (NRC). 2001. "Disposal of High-Level Radioactive

Wastes in a Proposed Geological Repository at Yucca Mountain, Nevada." Federal Register,

Vol. 66, No. 213, p. 55792. Washington, D.C. November 2,2001.

NUREG-1437, Supplement 26 6-10 August 2006 1
7.0 Environmental Impacts of Decommissioning

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in the Generic Environmental

Impact Statement for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the

Decommissioning of Nuclear Power Reactors, NUREG-0586 (NRC 2002). The staff's

evaluation of the environmental impacts of decommissioning presented in NUREG-0586,

Supplement 1 identifies a range of impacts for each environmental issue.

The incremental environmental impacts associated with decommissioning activities resulting

from continued plant operation during the renewal term are discussed in the Generic

Environmental Impact Siatement for License Renewal of Nuclear Plants (GELS), NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999).(a) The GElS includes a determination of whether the

analysis of the environmental issue could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GElS, Category 1 issues are those that meet all of

the following criteria:

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

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

system or other specified plant or site characteristics.

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

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

and from high level waste and spent fuel disposal).

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

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

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

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

required unless new and significant information is identified.

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

therefore, additional plant-specific review of these issues is required. There are no Category 2

issues related to decommissioning.

• The GElS was originally issued in 1996; Addendum I to the GElS was issued in 1999. Hereafter, all references

to the "GELS" include the GElS and its Addendum 1.

August 2006 7-1 NUREG-1437, Supplement 26 1
Environmental Impacts of Decommissioning

7.1 Decommissioning

Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51,

Subpart A, Appendix B that are applicable to Monticello decommissioning following the renewal

term are listed in Table 7-1. Nuclear Management Company (NMC) stated in its Environmental

Report (ER) (NMC 2005) that it is aware of no new and significant information regarding the

environmental impacts of Monticello license renewal. The staff has not identified any new and

significant information during its-independent review of the NMC ER, the staff's site visit, the

I scoping process, its evaluation of other available information, or public comments on the draft

I Supplemental Environmental Impact Statement (SEIS). Therefore, the staff concludes that

there are no impacts related to these issues beyond those discussed in the GELS. For all of

these issues, the staff concluded in the GElS that the impacts are SMALL, and additional plantspecific mitigation measures are not likely to be sufficiently beneficial to be warranted.

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

Monticello Following the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Sections

DECOMMISSIONING

Radiation doses 7.3.1; 7.4

Waste management. 7.3.2; 7.4

Air quality 7.3.3; 7.4

Water quality 7.3.4; 7.4

Ecological resources 7.3.5; 7.4

Socioeconomic impacts 7.3.7; 7.4

A brief description of the staff's review and the GElS conclusions, as codified in Table B-i, for

each of the issues follows:

Radiation doses. Based on information in the GELS, the Commission found that

Doses to the public will be well below regulatory standards regardless of which

decommissioning method is used. Occupational doses would increase no more

than 1 man-rem [0.01 person-Sv] caused by buildup of long-lived radionuclides

during the license renewal term.

The staff has not identified any new and significant information during its independent review of

I the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no radiation dose impacts associated with decommissioning following the license renewal

term beyond those discussed in the GELS.

NUREG-1437, Supplement 26 7-2 August 2006 1
Environmental Impacts of Decommissioning

Waste management. Based on information in the GElS, the Commission found that

Decommissioning at the end of a 20-year license renewal period would generate

no more solid wastes than at the end of the current license term. No increase in

the quantities of Class C or greater than Class C wastes would be expected.

The staff has not identified any new and significant information during its independent review of

the. NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts from solid waste associated with decommissioning following the license renewal

term beyond those discussed in the GELS.

* Air quality. Based on information found in the GELS, the Commission found that

Air quality impacts of decommissioning are expected to be negligible either at

the end of the current operating term or at the end of the license renewal term.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts on air quality associated with decommissioning following the license renewal

term beyond those discussed in the GELS.

* Water quality. Based on information found in the GELS, the Commission found that

The potential for significant water quality impacts from erosion or spills is no

greater whether decommissioning occurs after a 20-year license renewal period

or after the original 40-year operation period, and measures are readily available

to avoid such impacts.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available I

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no impacts on water quality associated with decommissioning following the license renewal

term beyond those discussed in the GELS.

* Ecological resources. Based on information found in the GELS, the Commission found that

Decommissioning either after the initial operating period or after a 20-year

license renewal period is not likely to have any direct ecological impacts.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

August 2006 7-3 NUREG-1437, Supplement 26 1
Environmental Impacts of Decommissioning

are no impacts on ecological resources associated with decommissioning following the license

renewal term beyond those discussed in the GELS.

Socioeconomic impacts. Based on information found in the GELS, the Commission found

that

Decommissioning would have some short-term socioeconomic impacts. The

impacts would not be increased by delaying decommissioning until the end of a

20-year relicense period, but they might be decreased by population and

economic growth.

The staff has not identified any new and significant information during its independent review of

the NMC ER, the staff's site visit, the scoping process, its evaluation of other available

information, or public comments on the draft SEIS. Therefore, the staff concludes that there

are no socioeconomic impacts associated with decommissioning following the license renewal

term beyond those discussed in the GELS.

7.2 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

Nuclear Management Company (NMC). 2005. Applicant's.Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

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

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

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

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

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of

Nuclear Power Reactors. NUREG-0586, Supplement 1, Vols. 1 and 2, Washington, D.C.

NUREG-1437, Supplement 26 7-4 August 2006 1
8.0 Environmental Impacts of Alternatives to License

Renewal

This chapter examines the potential environmental impacts associated with denying the renewal

of an operating license (OL) for Monticello Nuclear Generating Plant (Monticello) (the no-action

alternative); the potential environmental impacts from electric generating sources other than the

Monticello site; the possibility of purchasing electric power from other sources to replace power

generated by Monticello and the associated environmental impacts; the potential environmental

impacts from a combination of generating and conservation measures; and other generation

alternatives that were deemed unsuitable for replacement of power generated by Monticello.

The environmental impacts are evaluated using the U.S. Nuclear Regulatory Commission's

(NRC's) three-level standard of significance-SMALL, MODERATE, or LARGE-developed

using the Council on Environmental Quality guidelines and set forth in the footnotes to

Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B:

SMALL-Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE-Environmental effects are sufficient to alter noticeably, but not to

destabilize important attributes of the resource.

LARGE-Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

The impact categories evaluated in this chapter are the same as those used in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), NUREG-1 437,

Volumes 1 and 2 (NRC 1996, 1999)(a) with the additional impact category of environmental

justice.

8.1 No-Action Alternative

NRC's regulations implementing the National Environmental Policy Act (NEPA) of 1969 specify

that the no-action alternative be discussed in an NRC environmental impact statement (EIS),

(see 10 CFR Part 51, Subpart A, Appendix A[4]). For license renewal, the no-action alternative

refers to a scenario in which the NRC would not renew the Monticello OL. The Northern States

Power Company (NSP) would then cease plant operations when the current license expires and

initiate the decommissioning of the plant.

€ The GElS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references

to the "GEIS" include the GElS and its Addendum 1.

August 2006 8-1 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

NSP would be required to shut down Monticello and to comply with NRC decommissioning

requirements in 10 CFR 50.82 whether or not the OL is renewed. If the Monticello OL is

renewed, shutdown of the unit and decommissioning activities will not be avoided, but will be

postponed for up to an additional 20 years.

The environmental impacts associated with decommissioning following a license renewal period

of up to 20 years or following the no-action alternative would be bounded by the discussion of

impacts in Chapter 7 of the license renewal GElS (NRC 1996), Chapter 7 of this supplemental

environmental impact statement (SEIS), and the Final Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 (NRC 2002). The

impacts of decommissioning after 60 years of operatiorh are not expected to be significantly

different from those occurring after 40 years of operation.

Impacts from the decision to permanently cease operations are not considered in

NUREG-0586, Supplement 1.(a) Therefore, immediate impacts that occur between plant

shutdown and the beginning of decommissioning are considered here. These impacts, which

will occur when the unit permanently shuts down regardless of whether the license was to be

renewed or not, are discussed below, with the results presented in Table 8-1. Plant shutdown

will result in a net reduction in power production capacity. The power not generated by

Monticello during the license renewal term would likely be replaced by (1) power purchased

from other electricity providers, (2) generating alternatives other than Monticello, (3)

demand-side management (DSM) and energy conservation, or (4) some combination of these

-options. The environmental impacts of these options are discussed in Section 8.2.

* Land Use

In Chapter 4, the staff concluded that the impacts on land use of continued plant operation

during the renewal term would be SMALL. Onsite land use will not be affected immediately by

the cessation of operations. Plant structures and other facilities are likely to remain in place

until decommissioning. The transmission lines associated with the project would be expected to

remain in service after the plant stops operating. As a result, maintenance of the transmission

corridors will continue as before. Therefore, the staff concludes that the impacts on land use

from plant shutdown would be SMALL.

(a) Appendix J of NUREG-0586 Supplement I discusses the socioeconomic impacts of plant closure, but the results

of the analysis in Appendix J are not incorporated in the analysis presented in the main body of the NUREG.

NUREG-1437, Supplement 26 8-2 August 2006. 1
Environmental Impacts of Alternatives

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

Alternative

Impact Category Impact Comment

Land Use

Ecology

Water Use and

Quality-Surface

Water

Water Use and

QualityGroundwater

Air Quality

Waste

Human Health

Socioeconomics

Socioeconomics

(Transportation)

Aesthetics

Historic and

Archaeological

Resources

Environmental

Justice

SMALL

SMALL

SMALL

SMALL

SMALL

SMALL

SMALL

Impacts are expected to be SMALL because plant shutdown is not

expected to result in changes to onsite or offsite land use.

Impacts are expected to be SMALL because current aquatic

impacts are SMALL. Terrestrial impacts are not expected

because there will not be any land use changes.

Impacts are expected to be SMALL because surface water intake

and discharges will decrease.

Impacts are expected to be SMALL because groundwater use will

decrease.

Impacts are expected to be SMALL because releases related to

plant operation and worker transportation will decrease.

Impacts are expected to be SMALL because generation of

high-level waste will end, and generation of low-level and mixed

waste will decrease.

Impacts are expected to be SMALL because radiological doses to

workers and members of the public, which are within regulatory

limits, will be reduced.

SMALL to Impacts are expected to be SMALL to LARGE because of a

LARGE decrease in employment and tax revenues.

SMALL

SMALL

SMALL

Impacts are expected to be SMALL because the decrease in

employment would reduce traffic.

Impacts are expected to be SMALL because plant structures will

remain in place..

Impacts are expected to be SMALL because shutdown of the plant

will not result in changes to onsite or offsite land use.

SMALL to Impacts are expected to be SMALL to LARGE because loss of

LARGE employment opportunities is expected.

• Ecology

In Chapter 4 of this SEIS, the NRC staff concluded that the ecological impacts of continued

plant operation would be SMALL. Cessation of operations will be accompanied by a reduction

in cooling water flow and the thermal plume from the plant. The environmental impacts to

aquatic species, including threatened and endangered species, associated with these changes

are generally positive. The impact of plant closure on the terrestrial ecosystem will be

negligible because the transmission lines to the plant will remain energized. Therefore, the

staff concludes that ecological impacts from shutdown of the plant would be SMALL.

August 2006 8-3 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

0 Water Use and Quality-Surface Water

In Chapter 4 of this SEIS the NRC staff concluded that impacts of continued plant operation on

surface water use and quality would be SMALL. When the plant stops operating there will be

an immediate reduction in the consumptive use of water because of reduction in cooling water

flow and in the amount of heat rejected to the Mississippi River. Therefore, the staff concludes

that the impacts on surface water use and quality from plant shutdown would be SMALL.

* Water Use and Quality-Groundwater

In Chapter 4, the staff concluded that impacts of continued plant groundwater use on

groundwater availability and quality would be SMALL. When the plant stops operating, there

will be an immediate reduction in use of groundwater for makeup. In addition, there will be a

gradual reduction in groundwater use for potable water as the plant staff decreases. Therefore,

the staff concludes that groundwater use and quality impacts from shutdown of the plant would

be SMALL.

• Air Quality

In Chapter 4, the staff found the impacts of continued plant operation on air quality would likely

be SMALL. When the plant stops operating, there will be a reduction in emissions from

activities related to plant operation, such as use of diesel generators and workers'

transportation. Therefore, the staff concludes thatthe impact on air quality from shutdown of

the plant would be SMALL.

* Waste

The impacts of waste generated by continued plant operation are discussed in Chapter 6. The

impacts of low-level and mixed waste from plant operation are characterized as SMALL. When

the plant stops operating, the plant will stop generating high-level waste, and generation of

low-level and mixed waste associated with plant operation and maintenance will be reduced.

Therefore, the staff concludes that the impact of waste generated after shutdown of the plant

would be SMALL.

• Human Health

In Chapter 4 of this SEIS the NRC staff concluded that the impacts of continued plant operation

on human health would be SMALL. After the cessation of operations the amount of radioactive

material released to the environment in gaseous and liquid forms will be reduced. Therefore,

the staff concludes that the impact of shutdown of the plant on human health would be SMALL.

In addition, the variety of potential accidents at the plant will be reduced to a limited set

associated with shutdown events and fuel handling. In Chapter 5 of this SEIS the NRC staff

NUREG-1 437, Supplement 26 8-4 August 2006 1
Environmental Impacts of Alternatives

concluded that the impacts of accidents during operation were SMALL. Therefore, the staff

concludes that the impacts of potential accidents following permanent shutdown of the plant

would be SMALL.

* Socloeconomics

In Chapter 4, the NRC staff concluded that the socioeconomic impacts of continued plant

operation would range from SMALL to MODERATE. There would be immediate socioeconomic

impacts associated with the shutdown of the plant because of the reduction in the staff at the

plant. There may also be an immediate reduction in property tax revenues for Wright County.

The NRC staff concludes that the socioeconomic impacts of permanent plant shutdown could

range from SMALL to LARGE. Some of these impacts could be offset if new power generating

facilities are built at or near the current site. See Appendix J to NUREG-0586, Supplement 1

(NRC 2002), for additional discussion of the potential impacts of plant shutdown.

* Socioeconomics (Transportation)

In Chapter 4, the staff concluded that the impacts of continued plant operation on transportation

would be SMALL. Cessation of operations will be accompanied by a reduction of traffic in the

vicinity of the plant. Most of the reduction will be associated with a reduction in the plant

workforce, but there will also be a reduction in shipment of material to and from the plant.

Therefore, the staff concludes that the impacts of plant shutdown on transportation would be

SMALL.

* Aesthetics

In Chapter 4, the staff concluded that the aesthetic impacts of continued plant operation would

be SMALL. Cessation of operations will be accompanied by a reduction in visible plumes from

the cooling towers. Plant structures and other facilities are likely to remain in place until

decommissioning. Therefore, the staff concludes that the aesthetic impacts of plant shutdown

would be SMALL.

* Historic and Archaeological Resources

In Chapter 4,'the staff concluded that the impacts of continued plant operation on historic and

archaeological resources would be SMALL. Onsite land use will not be affected immediately by

the cessation of operations. Plant structures and other facilities are likely to remain in place

until decommissioning. The transmission lines associated with the project are expected to

remain in service after the plant stops operating. As a result, maintenance of transmission line

corridors will continue as before. Therefore, the staff concludes that the impacts on historic and

archaeological resources from plant shutdown would be SMALL.

August 2006 . 8-5 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

Environmental Justice

In Chapter 4, the staff concluded that the environmental justice impact of continued operation of

the plant would be SMALL because continued operation of the plant would not have a

disproportionately high and adverse irnpact on minority and low-income populations.

Permanent shutdown of the plant could have disproportionately high and adverse impacts on

minority and low-income populations because of the loss of employment opportunities at the

site and because of secondary socioeconomic impacts (e.g., loss of patronage at local

businesses). The staff concludes that the environmental justice impacts of plant shutdown

could range from SMALL to LARGE. Some of these impacts could be offset if new power

generating facilities are built at or near the current site. See Appendix J to NUREG-0586,

Supplement 1 (NRC 2002), for additional discussion of these impacts.

8.2 Alternative Energy Sources

This section discusses the environmental impacts associated with alternative sources of electric

power to replace the power generated by Monticello, assuming that the OL for Monticello is not.

renewed. The order of presentation of alternative energy sources in Section 8.2 does not imply

which alternative would be most likely to occur or to have the least environmental impact.

The following generation alternatives are considered in detail:

• coal-fired generation at an alternate greenfield site(a) (Section 8.2.1)

" natural gas-fired generation at an alternate greenfield site (Section 8.2.2)

* coal gasification at an alternate greenfield site (Section 8.2.3)

* nuclear generation at the Monticello site and an alternate greenfield site (Section 8.2.4).

The alternative of purchasing power from other sources to replace power generated Monticello

is discussed in Section 8.2.5. Other power generation alternatives and conservation

alternatives considered by the staff and found not to be reasonable replacements for Monticello

are discussed in Section 8.2.6. Section 8.2.7 discusses the environmental impacts of a

combination of generation and conservation alternatives.

(a) A greenfield site is assumed to be an undeveloped site with no previous construction.

NUREG-1437, Supplement 26 8-6 August 2006 1
Environmental Impacts of Alternatives

Each year the Energy Information Administration (EIA), a component of the U.S. Department of

Energy (DOE), issues an Annual Energy Outlook. In its Annual Energy Outlook 2005 with

Projections to 2025, EIA projects that combined-cycle(a) or combustion turbine technology

fueled by natural gas is likely to account for approximately 60 percent of new electric generating

capacity between the years 2005 and 2025 (DOE/EIA 2005). Both technologies are designed

primarily to supply peak and intermediate capacity, but combined-cycle technology can also be

used to meet baseload() requirements. Coal-fired plants are projected by EIA to account for

approximately 35 percent of new capacity during this period (DOE/EIA 2005). Coal-fired plants

are generally used to meet baseload requirements. Renewable energy sources, primarily wind,

biomass gasification, and municipal solid waste units, are projected by EIA to account for the

remaining 5 percent of capacity additions. EIA's projections are based on the assumption that

providers of new generating capacity will seek to minimize cost while meeting applicable

environmental requirements. Combined-cycle plants are projected by EIA to have the lowest

generation cost in 2005 and 2025, followed by coal-fired plants and then wind generation

(DOE/EIA 2005).

EIA projects that oil-fired plants will account for very little of new generation capacity in the

United States during the 2005 to 2025 time period because of higher fuel costs and lower

efficiencies (DOE/EIA 2005).

EIA also projects that new nuclear power plants will not account for any new generation

capacity in the United States during the 2005 to 2025 time period because natural gas and

coal-fired plants are projected to be more economical (DOE/EIA 2005). In spite of this

projection, a new nuclear plant alternative for replacing power generated by Monticello is

considered for reasons stated in Section 8.2.4. NRC established a new reactor licensing

program organization in 2001 to prepare for and manage future reactor and site licensing

applications (NRC 2001).

Monticello has a net rating of 600 megawatts electric (MW[e]); therefore, for the coal

alternative, the staff assumed construction of a 600-MW(e) plant. For the natural gas

alternative, the staff assumed construction of a 550-MW(e) plant consisting of two team

combustion turbines (CTs). These assumptions are consistent with the NMC Environmental

Report (ER) (NMC 2005). For the coal gasification alternative, the staff assumed construction

of two 340-MW(e) modules. This assumption slightly overstates the environmental impacts of

replacing the 600 MW(e) from Monticello. For the new nuclear alternative, the staff assumed

construction of a 600-MW(e) plant. This assumption is roughly equivalent to the environmental

impacts of replacing the 600 MW(e) from Monticello.

(a) In a combined-cycle unit, hot combustion gas In a combustion turbine rotates the turbine to generate electricity.

The hot exhaust from the combustion turbine is routed through a heat-recovery boiler to make steam to generate

additional electricity.

N A baseload plant normally operates to supply all or part of the minimum continuous load of a system, and

consequently produces electricity at an essentially constant rate. Nuclear power plants are commonly used for

baseload generation; i.e., these nuclear units generally run near full load.

August 2006 8-7 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

8.2.1 Coal-Fired Generation

The staff believes that the Monticello site would not be a viable location for a representative

coal-fired plant. The configuration of the area, the proximity to County Road 75 and

Interstate 94, and the fact that the river bisects the site all present significant constraints to an

optimal layout of plant facilities. Potentially significant issues include the possible need to

realign County Road 75 and insufficient suitable area for onsite disposal of air emission control

waste south of the river. The latter constraint would necessitate transport of this waste to an

existing disposal facility at NSP's Sherburne County Generating Plant site or a new facility

developed offsite or on suitable land on the Monticello site north of the river.

Construction at an alternate site would necessitate approximately ten miles of new rail for

delivery of coal and limestone. In addition, approximately five miles of new 345-kV transmission

would be needed to connect to the grid (NMC 2005).

Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.1 are

from the NMC ER (NMC 2005). The staff reviewed this information and compared it to

environmental impact information in the GELS. Although the OL renewal period is only

20 years, the impact of operating the coal-fired alternative for 40 years is considered (as a

reasonable projection of the operating life of a coal-fired plant).

The coal-fired plant would consume approximately 2.7 million tons per year of pulverized

sub-bituminous coal with an ash content of approximately 5.7 percent. NMC assumes a heat

rate(a) of 9800 BTU/kWh and a capacity factor(b) of 85 percent in its ER. After combustion,

99.9 percent of the ash would be collected. Thirty percent of this ash would go to beneficial

uses such as concrete products and roadbed material. The remaining 69.9 percent would be

disposed of at the plant site. In addition, approximately 51,000 tons of scrubber sludge would

be disposed of at the plant site based on annual calcium hydroxide usage of approximately

31,000 tons. Calcium hydroxide is used in the scrubbing process for control of sulfur dioxide

(SO2) emissions.

(a) Heat rate is a measure of generating station thermal efficiency. In English units, it is generally expressed in

British thermal units (BTUs) per net kilowatt-hour (kWh). It is computed by dividing the total BTU content of the

fuel burned for electric generation by the resulting kWh generation. The corresponding metric unit for energy is

the joule (J).

t The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy that could

have been generated at continuous full-power operation during the same period.

NUREG-1437, Supplement 26 8-8 August 2006 1
Environmental Impacts of Alternatives

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

at an Alternate Greenfield Site Using Closed-Cycle Cooling

Impact

Category Impact Comment

Land Use

Ecology

MODERATE

SMALL to

MODERATE

Water Use and

Quality-Surface

Water

Water Use and

QualityGroundwater

Air Quality

SMALL to

MODERATE

SMALL to

MODERATE

MODERATE

The total site could consist of approximately 1700 ac for facilities and an

appropriate buffer for adjacent land uses. Land occupied by a 120-ac

landfill would be permanently restricted to noninvasive uses for the long

term. Offsite, an estimated 60 ac of land would be converted to

transportation use and 90 ac would be converted for utility use.

Impact depends on whether the site has been previously developed.

Factors to consider include location and ecology of the site, transmission

line route and rail spur route. In total, impacts could include habitat

degradation, fragmentation, or loss as a result of construction activities

and conversion of land to industrial use. Ecological communities might

experience reduced productivity and biological diversity from disturbance

of previously intact land.

The impact on the surface water is site-dependent and would depend on

the volume of water needed for makeup water, the discharge volume,

and the characteristics of the receiving body of water.

Impact depends on volume of water withdrawn and the characteristics of

the groundwater source..

Sulfur oxides: 1755 tons/yr. National and regional impacts would be

minimal because of emissions offsets through the SO2 trading program.

Nitrogen oxides: 486 tons/yr

Particulates: 18 tons/yr of PM,0

Carbon monoxide: 675 tons/yr

Small amounts of mercury and other hazardous air pollutants and

naturally occurring radioactive materials-mainly uranium and thorium.

Total waste volume would be approximately 107,000 tons of ash and

51,000 tons of flue gas desulfurization waste annually for 40 years.

Approximately 30 percent of the ash would be beneficially used and the

remainder of the waste would be disposed of onsite, accounting for

approximately 120 ac of land area over the 40-year plant life.

Impacts are uncertain, but considered SMALL in the absence of more

quantitative data.

Construction impacts depend on location, but could be LARGE if the

plant is located in an area that is more rural than the Monticello site.

Wright County would experience loss of tax base and employment,

potentially offset by projected economic growth.

Transportation impacts associated with construction workers could be

SMALL to MODERATE.

Waste

Human Health

Socioeconomics

MODERATE

SMALL

SMALL to

LARGE

Socioeconomics

(Transportation)

SMALL to

MODERATE

For rail transportation of coal and lime, the impact is considered SMALL

to MODERATE. For barge transportation, the impact is considered

SMALL.

August 2006 8-9 NUREG-1437, Supplement 26 I
Environmental Impacts of Alternatives

Table 8-2. (contd)

Impact

Category Impact Comment

Aesthetics SMALL to Impacts could include visual impairment and infrastructure for delivery of

MODERATE coal and limestone. The severity of impacts is dependent on location.

Historic and SMALL An alternate location would necessitate cultural resource studies.

Archaeological

Resources

Environmental SMALL to Impacts will vary depending on population distribution and makeup at the

Justice MODERATE site.

For purposes of this evaluation, the staff assumed that a coal-fired plant located at an alternate

site would use a closed-cycle cooling system. The overall impacts of the coal-fired generating

system are discussed in the following sections and summarized in Table 8-2. The extent of

impacts at an alternate greenfield site will depend on the location of the particular site selected.

Land Use

Although potential impacts on land use from a new coal-fired plant would be location-specific

and therefore conjectural for a greenfield site, potentially affected areas are predominantly rural

agricultural land interspersed in some areas with natural vegetation, all of which are abundant

in the region. The total site could consist of approximately 1700 ac to provide flexibility in

facility arrangement and appropriate buffer from adjacent land uses. Land uses would be

entirely precluded on 380 ac onsite for plant facilities and waste disposal. The waste would be

disposed of onsite, accounting for approximately 120 ac of land area over the 40-year plant

life.(a) Offsite, an estimated 60 ac of land would be converted to transportation use (rail spur)

and 90 ac would be converted to utility use (transmission line). Land occupied by the 120-ac

landfill would be permanently restricted to noninvasive uses (e.g., recreation) for the long term.

In view of the large amount of land affected and the permanent land use change from the

landfill, the staff concludes that land use impacts would be clearly noticeable but not

destabilizing. Therefore, the staff concludes that land use impacts from construction and

operation of a new coal-fired plant at an alternative greenfield site would be MODERATE. The

impact would be greater than the OL renewal alternative.

* Ecology

Potential impacts on ecological resources from construction and operation of the representative

coal-fired plant are highly site-dependent. Development of the representative coal-fired plant at

a greenfield site in southern Minnesota would likely result in the loss of 380 ac of terrestrial

habitat for onsite plant facilities and air emission control waste landfill, loss of approximately

60 ac of offsite habitat for the rail line, and modification of 90 ac of offsite terrestrial habitat for a

new transmission line to serve the plant. Development of the transmission line would limit

(a) Because the new coal-fired plant is assumed to have a 40-year life, only half of the land area needed for

byproduct disposal is directly attributable to the alternative of renewing the Monticello OL for 20 years.

NUREG-1437, Supplement 26 8-10 August 2006
Environmental Impacts of Alternatives

changes in future land uses in the transmission corridor to those that are compatible with the

line, but most agricultural practices and other currently compatible uses could continue.

Depending on route specifics, clearing of forest and shrubland, some of which may qualify as

wetland, would also likely be required. However, hydrologic regimes of wetlands would not be

appreciably affected and the conversion of transmission corridor areas currently in forest to

open habitats could be advantageous to species with affinities for remnant prairie habitats.

The most significant potential impacts to aquatic communities relate to the operation of the

cooling water system; however, regulatory controls would be expected to ensure appropriate

protection of aquatic communities from thermal discharges and the location and operation of

cooling water intakes. In addition, because the new coal-fired plant is assumed to use

closed-cycle cooling, the cooling water intake and discharge flows would be much lower than

that of Monticello, the impact from which is considered to be SMALL.

Given this information, the staff concludes that development of the representative coal-fired

plant at a greenfield site would have a SMALL to MODERATE impact on ecological

communities.

* Water Use and Quality-Surface Water

Impacts on water quality of greatest potential concern from construction of a new coal-fired

plant at a greenfield site include (1) erosion and sedimentation associated with land clearing

operations, and (2) suspension of bottom sediments during construction of cooling water intake

and discharge structures (NRC 1996). These adverse effects would be localized and

temporary.

Potential impacts on water quality and use associated with operation of the representative coalfired plant would be site-dependent. The impact on the surface water would depend on the

volume of water needed for makeup water, the discharge volume, and the characteristics of the

receiving body of water. Cooling water, wastewater, and storm water discharges would be

regulated under the Clean Water Act and corresponding state programs by a National Pollutant

Discharge Elimination System (NPDES) permit. Cooling water intake and discharge flows for

the representative coal-fired plant, assumed to use a closed-cycle cooling system, would be

substantially lower than those for Monticello, which primarily operates in a once-through mode

that results in SMALL impacts. The staff concludes that the impacts of surface water use and

quality from operation of a representative coal-fired plant located at a greenfield site would be

SMALL to MODERATE, depending on the site chosen.

Water Use and Quality-Groundwater

Use of groundwater is possible for a coal-fired plant at an alternate site. Any groundwater

withdrawal would require a permit from the local permitting authority. Overall, impacts to

groundwater use and quality of a new coal-fired plant with a closed-cycle cooling system at an

alternate site are considered SMALL to MODERATE, depending on the volume of groundwater

withdrawn and the characteristics of the groundwater source.

August 2006 8-11 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

* Air Quality

The air-quality impacts of coal-fired generation vary considerably from those of nuclear

generation due to emissions of sulfur oxides (SO,), nitrogen oxides (NO,), particulates, carbon

monoxide, hazardous air pollutants such as mercury, and naturally occurring radioactive

materials.

Monticello is located in an area designated by the National Ambient Air Quality Standards as

being in attainment for all criteria pollutants. The nearest area of non-attainment is the

Milwaukee metropolitan area. However, Monticello is in a non-attainment area with respect to

the eight-hour ozone standard (NMC 2005).

A new coal-fired generating plant located in southern Minnesota would likely need a prevention

of significant deterioration (PSD) permit and an operating permit under the Clean Air Act. The

plant would need to comply with the new source performance standards for such plants set

forth in 40 CFR Part 60, Subpart Da. The standards establish limits for particulate matter and

opacity (40 CFR 60.42a), SO2 (40 CFR 60.43a), and NO, (40 CFR 60.44a).

The U.S. Environmental Protection Agency (EPA) has various regulatory requirements for

visibility protection in 40 CFR Part 51, Subpart P, including a specific requirement for review of

any new major stationary source in an area designated as attainment or unclassified under the

Clean Air Act (40 CFR 51.307).

Section 169A of the Clean Air Act establishes a national goal of preventing future and

remedying existing impairment of visibility in mandatory Class I Federal areas when impairment

results from man-made air pollution. The EPA issued a new regional haze rule in 1999 (EPA

1999). The rule specifies that for each mandatory Class I Federal area located within a State,

the State must establish goals that provide for reasonable progress towards achieving natural

visibility conditions. The reasonable progress goals must provide for an improvement in

visibility for the most-impaired days over the period of the implementation plan and ensure no

degradation in visibility for the least-impaired days over the same period [40 CFR 51.308(d)(1 )].

If a coal-fired plant were located close to a mandatory Class I areas, additional air pollution

control requirements could be imposed. The nearest Class I Federal area is in Northern

Minnesota, several hundred miles from Monticello.

In March 2005, the EPA issued the Clean Air Interstate Rule (CAIR) (EPA 2005b). CAIR will

permanently cap emissions of SO, and NO, in the eastern United States. CAIR achieves large

reductions of SO2 and/or NO. emissions across 28 eastern states and the District of Columbia.

When fully implemented, CAIR will reduce SO2 emissions in these states by over 70 percent,

and NO, emissions by over 60 percent from 2003 levels. This will result in $85 to $100 billion in

health benefits and nearly $2 billion in visibility benefits per year by 2015, and will substantially

reduce premature mortality in the eastern United States. The benefits will continue to grow

each year with further implementation. By 2015, CAIR will help Minnesota sources reduce

emissions of SO by 40,000 tons, or 36 percent, and emissions of NO, by 53,000 tons, or 59

percent (EPA 2005a).

NUREG-1 437, Supplement 26 8-12 August 2006 1
Environmental Impacts of Alternatives

Impacts from the various pollutants that would be expected to result from operation of a new

coal-fired plant are described below.

Sulfur oxides emissions. A new coal-fired power plant would be subject to the requirements

in Title IV of the Clean Air Act (42 USC 7651-7651o). Title IV was enacted to reduce emissions

of SO2 and NO,, the two principal precursors of acid rain, by restricting emissions of these

pollutants from power plants. Title IV caps aggregate annual power plant S emissions and

imposes controls on SO2 emissions through a system of marketable allowances. The EPA

issues one allowance for each ton of S that a unit is allowed to emit. New units do not

receive allowances, but are required to have allowances to cover their S emissions. Owners

of new units must therefore acquire allowances from owners of other power plants by purchase

or reduce SO2 emissions at other power plants they own. Allowances can be banked for use in

future years. Thus, a new coal-fired power plant would not add to net regional S02 emissions,

although it might do so locally.

Regardless, S emissions would be greater for the coal alternative than the OL renewal

alternative.

NSP estimates that by using the best technology to minimize SO,, emissions, the total annual

stack emissions would be approximately 1755 tons of SO,.

Nitrogen oxides emissions. Section 407 of the Clean Air Act (42 USC 7651f) establishes

technology-based emission limitations for NO, emissions. The market-based allowance system

used for S emissions is not used for NOx emissions. A new coal-fired power plant would be

subject to the new source performance standards for such plants at 40 CFR 60.44a(d)(1). This

regulation, issued on September 16, 1998 (EPA 1998), limits the discharge of any gases that

contain nitrogen oxides (expressed as NO2) in excess of 200 ng/J of gross energy output (1.6

lb/MWh), based on a 30-day rolling average.

NSP estimates that by using NO,, burners with overfire air and selective catalytic reduction

(SCR), the total annual NO, emissions for a new coal-fired power plant would be approximately

486 tons. Regardless of the control technology, this level of NOx emissions would be greater

than the OL renewal alternative, because a nuclear power plant releases almost no NOx during

normal operations.

Particulate emissions. NSP estimates that the total annual stack emissions for a new coalfired plant would include 77 tons of filterable total suspended particulates and 18 tons of

particulate matter having an aerodynamic diameter less than or equal to 10 pm (PM10)

(40 CFR 60.6). Fabric filters or electrostatic precipitators would be used for control. In addition,

coal-handling equipment would introduce fugitive particulate emissions. Particulate emissions

would be greater under the coal alternative than the OL renewal alternative because a nuclear

plant releases few particles during normal operations.

August 2006 8-13 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

During the construction of a coal-fired plant, fugitive dust would be generated. In addition,

exhaust emissions would come from vehicles and motorized equipment used during the

construction process.

Carbon monoxide emissions. NSP estimates that the total carbon monoxide emissions from

a new coal-fired plant would be approximately 675 tons per year. This level of emissions is

greater than the OL renewal alternative.

Hazardous air pollutants including mercury. In December 2000, the EPA issued regulatory

findings on emissions of hazardous air pollutants from electric utility steam-generating units

(EPA 2000b). The EPA determined that coal- and oil-fired electric utility steam-generating units

are significant emitters of hazardous air pollutants. Coal-fired power plants were found by the

EPA to emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen

fluoride, lead, manganese, and mercury (EPA 2000b). The EPA concluded that mercury is the

hazardous air pollutant of greatest concern. The EPA found that (1) there is a link between

coal consumption and mercury emissions; (2) electric utility steam-generating units are the

largest domestic source of mercury emissions; and (3) certain segments of the U.S. population

(e.g., the developing fetus and subsistence fish-eating populations) are believed to be at

potential risk of adverse health effects due to mercury exposures resulting from consumption of

contaminated fish (EPA 2000b). Accordingly, the EPA added coal- and oil-fired electric utility

steam-generating units to the list of source categories under Section 112(c) of the Clean Air Act

for which emission standards for hazardous air pollutants will be issued (EPA 2000b).

Uranium and thorium. Coal contains uranium and thorium. Uranium concentrations are

generally in the range of 1 to 10 parts per million. Thorium concentrations are generally about

2.5 times greater than uranium concentrations (Gabbard 1993). One estimate is that a typical

coal-fired plant released roughly 5.2 tons of uranium and 12.8 tons of thorium in 1982 (Gabbard

1993). The population dose equivalent from the uranium and thorium releases and daughter

products produced by the decay of these isotopes has been calculated to be significantly higher

than that from nuclear power plants (Gabbard 1993).

Carbon dioxide. A coal-fired plant would also have unregulated carbon dioxide emissions that

could contribute to global warming. The level of emissions from a coal-fired plant would be

greater than the OL renewal alternative.

Summary. The GElS analysis did not quantify emissions from coal-fired power plants, but

implied that air impacts would be substantial. The GElS also mentioned global warming from

unregulated carbon dioxide emissions and acid rain from SO,, and NO,, emissions as potential

impacts (NRC 1996). Adverse human health effects such as cancer and emphysema have

been associated with the products of coal combustion. The appropriate characterization of air

impacts from coal-fired generation would be MODERATE. The impacts would be clearly

noticeable, but would not destabilize air quality.

NUREG-1437, Supplement 26 8-14 August 2006 1
Environmental Impacts of Alternatives

Waste

Coal combustion generates waste in the form of ash, and equipment for controlling air pollution

generates additional ash and scrubber sludge. The representative coal-fired plant would

generate approximately 107,000 tons of ash and 51,000 tons of flue gas desulfurization waste

annually for 40 years. Approximately 30 percent of the ash would be beneficially used and the

remainder of the waste would be disposed of in a landfill on site, accounting for approximately

120 ac of land area over the 40-year plant life. Waste impacts to groundwater and surface

water could extend beyond the operating life of the plant if leachate and runoff from the landfill

occurs. Disposal of the waste could noticeably affect land use and groundwater quality, but

with appropriate management and monitoring, it would not destabilize any resources. After

closure of the waste site and revegetation, the land could be available for noninvasive uses.

Debris would be generated during construction activities.

In May 2000, the EPA issued a "Notice of Regulatory Determination on Wastes From the

Combustion of Fossil Fuels" (EPA 2000a). The EPA concluded that some form of national

regulation is warranted to address coal combustion waste products because: (a) the

composition of these wastes could present danger to human health and the environment under

certain conditions; (b) EPA has identified 11 documented cases of proven damages to human

--health and the environment by improper management of these wastes in landfills and surface

impoundments; (c) present disposal practices are such that, in 1995, these wastes were being

managed in 40 percent to 70 percent of landfills and surface impoundments without reasonable

controls in place, particularly in the area of groundwater monitoring; and (d) the EPA identified

gaps in state oversight of coal combustion wastes. Accordingly, the EPA announced its

intention to issue regulations for disposal of coal combustion waste in landfills or surface

impoundments under subtitle D of the Resource Conservation and Recovery Act (RCRA).

For all of the preceding reasons, the appropriate characterization of impacts from waste

generated from burning coal is MODERATE; the impacts would be clearly noticeable, but would

not destabilize any important resource.

* Human Health

Coal-fired power generation introduces worker risks from coal and limestone mining, from coal

and lime/limestone transportation, and from disposal of coal combustion waste. In addition

there are public risks from inhalation of stack emissions. Emission impacts can be widespread

and health risks difficult to quantify. The coal alternative also introduces the risk of coal-pile

fires and attendant inhalation risks.

In the GElS, the staff stated that the operating impacts of new coal-fired plants would result in

substantial human health impacts (cancer and emphysema) from inhalation of toxins and

particulates, but it did not quantify these impacts (NRC 1996). In addition, the discharges of

uranium and thorium from coal-fired plants can potentially produce radiological doses in excess

of those arising from nuclear power plant operations (Gabbard 1993).

August 2006 8-15 NUREG-1437, Supplement 26 I
Environmental Impacts of Alternatives

Regulatory agencies, including the EPA and State agencies, set air emission standards and

requirements based on human health impacts. These agencies also impose site-specific

emission limits as needed to protect human health. As discussed previously, the EPA has

recently concluded that certain segments of the U.S. population (e.g., the developing fetus and

subsistence fish-eating populations) are believed to be at potential risk of adverse health effects

due to mercury exposures from sources such as coal-fired power plants. However, in the

absence of more quantitative data, human health impacts from radiological doses and inhaling

toxins and particulates generated by burning coal are characterized as SMALL.

Socloeconomics

Construction of the coal-fired alternative would take approximately 5 years. The staff assumed

that construction would take place while Monticello continues operation and would be

completed by the time Monticello permanently ceases operations. The work force would be

expected to vary between 400 and 1000 workers during the 5-year construction period (NRC

1996). These workers would be in addition to the approximately 519 workers employed at

Monticello. During construction, the surrounding communities would experience demands on

housing and public services that could have SMALL impacts. These impacts would be

tempered by construction workers commuting to the site from other parts of Wright County or

from other counties. After construction, the communities would be impacted by the loss of the

construction jobs, although this loss would be possibly offset by other growth currently being

projected for Wright and Sherburne counties (USCB 2004).

Construction of a replacement coal-fired power plant at an alternate greenfield site would

relocate some socioeconomic impacts, but would not eliminate them, The communities around

Monticello would still experience the impact of Monticello operational job loss, although this

impact would be potentially tempered by projected economic growth, and the communities

around the new site would have to absorb the impacts of a temporary work force (up to 1000

workers at the peak of construction) and a permanent work force of approximately 80 workers.

Communities in Wright County in particular would experience losses in both employment and

tax revenues due to the Monticello site closure, assuming the plant is constructed outside the

area. This impact could be MODERATE to LARGE. In the GELS, the staff noted that

socioeconomic impacts at a rural site would be larger than at an urban site, because more of

the peak construction work force would need to move to the area to work. Alternate greenfield

sites would need to be analyzed on a case-by-case basis. Socioeconomic impacts at a rural

site could be LARGE.

The appropriate characterization of socioeconomic impacts from coal-fired generation would be

SMALL to LARGE.

* Socloeconomics (Transportation)

Transportation-related impacts associated with the commuting of construction workers at an

alternate greenfield site are site-dependent, but could be SMALL to MODERATE.

NUREG-1437, Supplement 26 8-16 August 2006 1
Environmental Impacts of Alternatives

Transportation impacts related to commuting of plant operating personnel would also be sitedependent, but can be characterized as SMALL to MODERATE.

Coal and limestone would likely be delivered to an alternate site by rail or barge.

Socioeconomic impacts associated with rail transportation would likely be SMALL to

MODERATE. For example, there would be delays to highway traffic as trains pass and there

could be negative impacts on the value of property close to the train tracks. The

socioeconomic impacts of barge delivery of coal and limestone would likely be SMALL.

Aesthetics

Potential aesthetic impacts of construction and operation of a coal-fired plant include visual

impairment resulting from the presence of an industrial facility, particularly a 500-ft high exhaust

stack and condensate plume from the cooling tower. However, the topography throughout

most of southern Minnesota is rolling, and forested tracts are common in some areas. Both of

these factors act to reduce the viewshed and limit potential for impairment of visual aesthetics

from onsite and offsite infrastructure.

Coal-fired generation using cooling towers would introduce mechanical sources of noise that

would be audible offsite. Sources contributing to total noise produced by plant operation are

classified as continuous or intermittent. Continuous sources include the mechanical equipment

associated with normal plant operations. Intermittent sources include the equipment related to

coal handling, solid-waste disposal, transportation related to coal and lime delivery, use of

* outside loudspeakers, and the commuting of plant employees.

Noise impacts associated with rail delivery of coal and lime to a plant would be most significant

for residents living in the vicinity of the facility and along the rail route. Although noise from

passing trains significantly raises noise levels near the rail corridor, the short duration of the

noise reduces the impact. Nevertheless, given the frequency of train transport and the many

residents likely to be within hearing distance of the rail route, the impacts of noise on residents

in the vicinity of the facility and the rail line is considered MODERATE.

The staff assumes that adequate buffer and vegetation screens would be provided at the plant

site as needed to reduce visual and noise impacts. Overall the aesthetic impacts associated

with locating at an alternate site can be categorized as SMALL to MODERATE.

* Historic and Archaeological Resources

At an alternate site, a cultural resource inventory would likely be needed for any onsite property

that has not been previously surveyed. Other lands, if any, that are acquired to support the

plant would also likely need an inventory of field cultural resources, identification and

documentation of existing historic and archaeological resources, and possible mitigation of

adverse effects from subsequent ground-disturbing actions related to physical expansion of the

plant site.

August 2006 8-17 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

Prior to construction at an alternate greenfield site, studies would likely be needed to identify,

evaluate, and address mitigation of the potential impacts of new plant construction on cultural

resources. The studies would likely be needed for all areas of potential disturbance at the

proposed plant site and along associated corridors where new construction would occur (e.g.,

roads, transmission corridors, rail lines, or other rights-of-way). Historic and archaeological

resource impacts can generally be effectively managed and as such are considered SMALL.

* Environmental Justice

Closure of the Monticello site would result in a decrease in employment of approximately

519 operating employees, possibly offset by projected growth in Wright and Sherburne

counties. Following construction of a new coal-fired plant, it is possible that the ability of local

government to maintain social services could be reduced at the same time as diminished

economic conditions reduce employment prospects for minority or low-income populations.

Overall, impacts would be SMALL to MODERATE, and would depend on the extent to which

projected economic growth is realized and the ability of minority or low-income populations to

commute to other jobs outside the Wright County area. Impacts at other sites would depend

upon the site chosen and the nearby population distribution, but are likely to also be SMALL to

MODERATE.

8.2.2 Natural Gas-Fired Generation

The staff believes that the Monticello site would not be a viable location for a representative

natural gas-fired plant. Optimal arrangement of the natural gas-fired plant would likely require

locating it within 0.5 mi of Monticello spent fuel storage, which would require specific NRC

approval. Assuming this constraint were overcome, approximately 35 mi of 16-in. natural gas

pipeline occupying a 30-ft wide corridor would be required to supply the plant. The Viking Gas

Transmission interstate pipeline, which traverses Benton and Mille Lacs counties north of

Monticello, is the closest pipeline with the potential for sufficient capacity. This additional

infrastructure needed to support a natural gas-fired plant represents an economic and

environmental constraint.

The environmental impacts of the natural gas-fired alternative are examined in this section for

an alternate greenfield site. The staff assumed that the plant would use a closed-cycle cooling

system. Construction at an alternate site would necessitate approximately 5 mi of new natural

gas supply pipeline to supply the natural gas-fired plant. In addition, an estimated 5 mi of new

345-kV transmission lines would be needed to connect to the grid (NMC 2005).

The staff assumed that a replacement natural gas-fired plant would use combined-cycle

technology. In a combined-cycle unit, hot combustion gases in a CT rotate the turbine to

generate electricity. Waste combustion heat from the CT is routed through a heat-recovery

boiler to make steam to generate additional electricity.

The staff assumed the construction of the natural gas-fired units would be timed to coincide

with the expiration of the Monticello operating license period. Consistent with the NMC ER

NUREG-1437, Supplement 26 8-18 August 2006 1
Environmental Impacts of Alternatives

(NMC 2005), the representative plant would consist of two team CTs, each with an associated

heat recovery steam generator (HRSG) that together supply steam to a single steam turbine

generator. Net generating capacity of the representative plant is approximately 550 MW(e).

This assumption understates the environmental impacts of. replacing the 600 MW(e) from

Monticello. However, the staff has determined that the differences in impacts between

550 MW(e) and 600 MW(e) of natural gas-fired generation would be less than 10 percent and

would not change the magnitude (SMALL, MODERATE, or LARGE) of any impacts.

The staff assumed that the plant would use closed-cycle cooling using a mechanical-draft

cooling tower, which is assumed to be approximately 45 ft tall. Exhaust from the two HRSGs

would be dispersed through individual 200-ft high stacks.

Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.2 are

from the NMC ER (NMC 2005). The staff reviewed this information and compared it to

environmental impact information in the GELS. Although the OL renewal period is only

20 years, the impact of operating the coal-fired alternative for 40 years is considered (as a

reasonable projection of the operating life of a coal-fired plant).

The overall impacts of the natural gas-generating system are discussed in the following

sections and summarized in Table 8-3. The extent of impacts at an alternate greenfield site will

depend on the location of the particular site selected.

Land Use

Although potential impacts on land use would be location-specific and therefore conjectural for

a greenfield site, potentially affected areas are predominantly rural agricultural land

interspersed in some areas with natural vegetation. Approximately 110 ac of rural agricultural

land and/or natural plant communities abundant in the region would be converted to industrial

use, of which 25 ac would be occupied by plant facilities. The staff assumes that

non-conflicting land uses (i.e., agriculture) on the balance of the plant site would remain

unaffected and would provide appropriate buffer with respect to any highly incompatible land

use such as residential development. Development.of offsite infrastructure (i.e., transmission

line, gas pipeline), involving a corridor of approximately 110 ac, would similarly limit

development of future land uses; however, compatible land uses, including most agricultural

practices, could continue.

Regardless of where the gas-fired plant is built, additional land would be required for natural

gas wells and collection stations. Partially offsetting these offsite land requirements would be

the elimination of the need for uranium mining to supply fuel for Monticello. In the GElS (NRC

1996), the staff estimated that approximately 1000 ac would be affected for mining the uranium

and processing it during the operating life of a nuclear power plant. Overall, land-use impacts

would be SMALL to MODERATE depending on site-specific factors.

August 2006 8-19 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

Table 8-3. Summary of Environmental Impacts of Natural Gas-Fired

Generation at an Alternate Greenfield Site Using Closed-Cycle

Cooling

Impact Category Impact Comment

Land Use

Ecology

Water Use and

Quality-Surface

Water

Water Use and

QualityGroundwater

Air Quality

SMALL to

MODERATE

SMALL to

MODERATE

SMALL to

MODERATE

SMALL to

MODERATE

MODERATE

SMALL

SMALL

SMALL to

MODERATE

SMALL to

MODERATE

SMALL to

MODERATE

Approximately 110 ac of rural agricultural land and/or natural plant

communities converted to industrial use, of which 25 ac would be

occupied by plant facilities. An additional 110 ac would be

developed as a transmission and pipeline corridor.

Impact depends on whether the site has been previously developed.

Factors to consider include location and ecology of the site,

transmission line route and rail spur route. In total, impacts could

include habitat degradation, fragmentation, or loss as a result of

construction activities and conversion of land to industrial use.

Ecological communities might experience reduced productivity and

biological diversity from disturbing previously intact land.

Intake and discharge would involve relatively small quantities of

water compared to the coal alternative. The impact on the surface

water would depend on the volume of water needed for makeup

water, the discharge volume, and the characteristics of the receiving

body of water.

Impact depends on volume of water withdrawn and the

characteristics of the groundwater source.

Sulfur oxides: 9 tons/yr

Nitrogen oxides: 134 tons/yr

Carbon monoxide: 203 tons/yr

Particulates: 26 tons/yr of PM,0

Other: (1) hazardous air pollutants, including arsenic, formaldehyde,

and nickel and (2) C02 emissions, which contribute to global

warming.

Natural gas-fired alternative would generate only small quantities of

municipal and industrial waste, including spent catalyst used for NO,

control.

Impacts are considered to be minor.

During construction, impacts would be MODERATE. Up to 450

additional workers would be required during the peak of the 2-year

construction period. Wright County would experience loss of tax

base and employment, potentially offset by projected economic

growth in Wright and Sherburne counties.

Transportation impacts associated with construction workers would

be SMALL to MODERATE depending on the site selected.

Transportation impacts associated with operational workers would'

be SMALL.

The significance of Impacts would depend on the characteristics of

the alternate site.

Waste

Human Health

Socioeconomics

Socioeconomics

(Transportation)

Aesthetics

NUREG-1437, Supplement 26 8-20 August 2006 1
Environmental Impacts of Alternatives

Table 8-3. (contd)

Impact Category Impact Comment

Historic and SMALL Any potential impacts can likely be effectively managed.

Archaeological

Resources

Environmental SMALL to Impacts vary depending on population distribution and makeup at

Justice MODERATE the alternate site.

* Ecology

Potential impacts on ecological resources from construction and operation of the representative

natural gas-fired plant are highly site specific. Development of the representative natural

gas-fired plant at a greenfield site in southern Minnesota would likely result in the loss of

approximately 25 ac of terrestrial habitat for onsite plant facilities and modification of

approximately 110 ac of existing offsite terrestrial habitat for a new natural gas supply pipeline

and transmission line corridor. Development of the transmission line would limit changes in

future land uses in the transmission corridor to those that are compatible with the line, but most

agricultural practices and other currently compatible uses could continue. Depending on route

specifics, clearing of forest and shrubland, some of which may qualify as wetlands, would also

likely be required. However, hydrologic regimes of wetlands would not be appreciably affected

and the conversion of transmission corridor areas currently in forest and woodland habitats

could be advantageous to species with affinities for remnant prairie habitats.

The most significant potential impacts to aquatic communities relate to the operation of the

cooling water system, but regulatory controls would be expected to ensure appropriate

protection of aquatic communities from thermal discharges and the location and operation of

cooling water intakes. In addition, because the plant is assumed to use closed-cycle cooling,

the cooling water intake and discharge flows would be much lower than that of Monticello, the

impact from which is considered to be SMALL.

Given this information, the staff concludes that development of the representative natural

gas-fired plant at a greenfield site would have a SMALL to MODERATE impact on ecological

communities.

Water Use and Quality-Surface Water

Each of the natural gas-fired units would include a heat-recovery boiler, using a portion of the

waste heat from the combustion turbines to make steam. The steam would then turn an

electric generator. The net result would be an overall reduction in the amount of waste heat

rejected from the plant, with an associated reduction in the amount of cooling water required by

the plant. Thus, the cooling water requirements for the natural gas-fired combined-cycle units

would be much less than for conventional steam-electric generators, including the existing

nuclear unit. Plant discharge would consist mostly of cooling tower blowdown, with the

August 2006 8-21 NUREG-1 437, Supplement 26 1
Environmental Impacts of Alternatives

discharge having a higher temperature and increased concentration of dissolved solids relative

to the receiving body of water and intermittent low concentrations of biocides. In addition to the

cooling tower blowdown, process waste streams and sanitary wastewater might also be

discharged. All discharges would be regulated through a NPDES permit. Finally, some erosion

and sedimentation would probably occur during construction (NRC 1996). These adverse

effects would be localized and temporary.

A natural gas-fired plant at an alternate greenfield site is assumed to use a closed-cycle cooling

system with cooling towers. The staff assumed that surface water would be used for cooling

makeup water and discharge. Intake and discharge would involve relatively small quantities of

water compared to the coal alternative. The impact on'the surface -water would depend on the

volume of water needed for makeup water, the discharge volume, and the characteristics of the

receiving body of water. The staff expects that these impacts would range from SMALL to

MODERATE.

* Water Use and Quality-Groundwater

Use of groundwater is possible for a natural gas-fired plant at an alternate site. Any

groundwater withdrawal would require a permit from the local permitting authority. Overall,

impacts to groundwater use and quality of a new natural gas-fired plant with a closed-cycle

cooling system at an alternate site are considered SMALL to MODERATE, depending on the

* volume of groundwater withdrawn and the characteristics of the groundwater source.

* Air Quality

Natural gas is a relatively clean-burning fuel. The gas-fired alternative would release similar

types of emissions, but in lesser quantities than the coal-fired alternative.

A new gas-fired generating plant located in Minnesota would likely need a PSD permit and an

operating permit under the Clean Air Act. A new combined-cycle natural gas power plant would

also be subject to the new source performance standards for such units at 40 CFR Part 60,

Subparts Da and GG. These regulations establish emission limits for particulates, opacity, SO.,

and NOX.

In March 2005, the EPA issued CAIR, which will permanently cap emissions of SO2 and NOx in

the eastern United States (70 CFR 25162). CAIR achieves large reductions of SO2 and/or NOx

emissions across 28 eastern states and the District of Columbia. When fully implemented,

CAIR will reduce SO emissions in these states by over 70 percent and NO, emissions by over

60 percent from 2003 levels. This will result in $85 to $100 billion in health benefits and nearly

$2 billion in visibility benefits per year by 2015, and will substantially reduce premature mortality

in the eastern United States. The benefits will continue to grow each year with further

implementation. By 2015, CAIR will help Minnesota sources reduce emissions of SO2 by

40,000 tons, or 36 percent, and emissions of NOx by 53,000 tons, or 59 percent (EPA 2005a).

NUREG-1437, Supplement 26 8 -22 August 2006 1
Environmental Impacts of Alternatives

The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

Subpart P, including a specific requirement for review of any new major stationary source in an

area designated attainment or unclassified under the Clean Air Act (40 CFR 51.307). Wright

County is an area designated by the National Ambient Air Quality Standards as being in

attainment for all criteria pollutants. However, the area is in non-attainment with respect to the

eight hour ozone standard.

Section 169A of the Clean Air Act establishes a national goal of preventing future and

remedying existing impairment of visibility in mandatory Class I Federal areas when impairment

results from man-made air pollution. The EPA issued a new regional haze rule in 1999 (EPA

1999). The rule specifies that for each mandatory Class I Federal area located within a state,

the State must establish goals that provide for reasonable progress towards achieving natural

visibility conditions. The reasonable progress goals must provide for an improvement in

visibility for the most impaired days over the period of the implementation plan and ensure no

degradation in visibility for the least-impaired days over the same period [40 CFR 51.308(d)(1)].

If a natural gas-fired plant were located close to a mandatory Class I area, additional air

pollution control requirements could be imposed. The nearest Class I Federal area is in

Northern Minnesota, several hundred miles from Monticello.

NMC projects the following emissions for the natural gas-fired alternative (NMC 2005):

Sulfur oxides-9 tons/yr

Nitrogen oxides-134 tons/yr

Carbon monoxide-203 tons/yr

PM1o particulates-26 tons/yr

A natural gas-fired plant would also have unregulated carbon dioxide emissions that could

contribute to global warming.

In December 2000, the EPA issued regulatory findings on emissions of hazardous air pollutants

from electric utility steam-generating units (EPA 2000b). Natural gas-fired power plants were

found by EPA to emit arsenic, formaldehyde, and nickel (EPA 2000b). Unlike coal- and oil-fired

plants, the EPA did not determine that emissions of hazardous air pollutants from natural

gas-fired power plants should be regulated under Section 112 of the Clean Air Act.

Construction activities would result in temporary fugitive dust. Exhaust emissions would also

come from vehicles and motorized equipment used during the construction process.

Impacts from the above emissions would be clearly noticeable, but would not be sufficient to

destabilize air resources as a whole. The overall air-quality impact for a new natural gas-fired

plant at an alternate greenfield site is considered MODERATE.

August 2006 8-23 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

* Waste

There would be spent SCR catalyst from NO. emissions control and small amounts of

solid-waste products (i.e., ash) from burning natural gas fuel. In the GElS, the staff concluded

that waste generation from gas-fired technology would be minimal (NRC 1996). Gas firing

results in very few combustion byproducts because of the clean nature of the fuel.

Waste-generation impacts would be so minor that they would not noticeably alter any important

resource attribute. Construction-related debris would be generated during construction

activities.

Overall, the waste impacts would be SMALL for a natural gas-fired plant sited at an alternate

greenfield site.

* Human Health

In Table 8-2 of the GELS, the staff identifies cancer and emphysema as potential health risks

from gas-fired plants (NRC 1996). The risk may be attributable to NO. emissions that

contribute to ozone formation, which in turn contribute to health risks. NO. emissions from any

gas-fired plant would be regulated. For a plant sited in Minnesota, NO, emissions would be

regulated by the Minnesota Pollution Control Agency (MPCA). Human health effects would not

be detectable or would be sufficiently minor that they would neither destabilize nor noticeably

alter any important attribute of the resource. Overall, the impacts on human health of the

natural gas-fired alternative sited at an alternate greenfield site are considered SMALL.

* Socioeconomics

Construction of a natural gas-fired plant would take approximately 2 years. Peak employment

would be approximately 450 workers (NMC 2005). The staff assumed that construction would

take place while Monticello continues operation and would be completed by the time it

permanently ceases operations. During construction, the communities surrounding the

Monticello site would experience demands on housing and public services that could have

MODERATE impacts. These impacts would be tempered by construction workers commuting

to the site from other parts of Wright County or from other counties. After construction, the

communities would be impacted by the loss of jobs. The current Monticello work force

(519 workers) would decline through a decommissioning period to a minimal maintenance size.

The gas-fired plant would introduce a replacement tax base at an alternate greenfield site and

approximately 24 new permanent jobs. For siting at an alternate greenfield site, impacts in

Wright County resulting from decommissioning of Monticello may be offset by economic growth

projected to occur in Wright and Sherburne counties.

In the GElS (NRC 1996), the staff concluded that socioeconomic impacts from constructing a

natural gas-fired plant would not be very noticeable and that the small operational work force

would have the lowest socioeconomic impacts of any nonrenewable technology. Also, the

shorter construction time frame and the smaller size of the operations work force for a natural

NUREG-1437, Supplement 26 8-24 August 2006 1
Environmental Impacts of Alternatives

gas-fired plant would result in smaller socioeconomic impacts than the coal-fired or nuclear

alternatives.

For these reasons, gas-fired generation socioeconomic impacts associated with construction

and operation of a natural gas-fired power plant would be SMALL to MODERATE for siting at

an alternate greenfield site. Depending on other growth in the area, socioeconomic effects

could be noticed, but they would not destabilize any important socioeconomic attribute.

* Socloeconomics (Transportation)

Transportation-related impacts associated with commuting construction workers at an alternate

greenfield site are site-dependent, but could be SMALL to MODERATE. Transportation

impacts related to commuting of plant operating personnel can be characterized as SMALL.

* Aesthetics

Potential aesthetic impacts of construction and operation of a natural gas-fired plant include

visual impairment resulting from the presence of an industrial facility and associated

transmission line corridors, particularly 200-ft high exhaust stacks and the condensate plume

from the cooling tower. However, the topography throughout most of southern Minnesota is

* rolling, and forested tracts are common in some areas. Both of these factors act to reduce the

viewshed and limit potential for impairment of visual aesthetics from onsite and offsite

infrastructure.

Natural gas generation would introduce mechanical sources of noise that would be audible

offsite. Sources contributing to total noise produced by plant operation are classified as

continuous or intermittent. Continuous sources include the mechanical equipment associated

with normal plant operations. Intermittent sources include the use of outside loudspeakers and

the commuting of plant employees.

The staff assumes that adequate buffer and vegetation screens would be provided at the plant

site as needed to reduce visual and noise impacts. Overall the aesthetic impacts associated

with locating at an alternate site can be categorized as SMALL to MODERATE, depending on

the location.

• Historic and Archaeological Resources

At an alternate greenfield site, a cultural resource inventory would likely be needed for any

onsite property that has not been previously surveyed. Other lands, if any, that are acquired to

support the plant would also likely need an inventory of field cultural resources, identification

and recording of existing historic and archaeological resources, and possible mitigation of

adverse effects from subsequent ground-disturbing actions related to physical expansion of the

plant site.

August 2006 8-25 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

Before construction at an alternate greenfield site, studies would likely be needed to identify,

evaluate, and address mitigation of the potential impacts of new plant construction on cultural

resources. The studies would likely be needed for all areas of potential disturbance at the

proposed plant site and along associated corridors where new construction would occur (e.g.,

roads, transmission and pipeline corridors, or other rights-of-way). Impacts to cultural

resources can be effectively managed under current laws and regulations and kept SMALL.

Environmental Justice

Closure of Monticello would result in a decrease in employment of approximately 519 operating

employees, possibly offset by growth in Wright and Sherburne counties. Following

construction, it is possible that the ability of local government to maintain social services could

be reduced at the same time as diminished economic conditions reduce employment prospects

for minority or low-income populations. Overall, impacts would be SMALL to MODERATE, and

would depend on the extent to which projected economic growth is realized and the ability of

minority or low-income populations to commute to other jobs outside the Wright County area.

Impacts at other sites would depend upon the site chosen and the nearby population

distribution, but are likely to also be SMALL to MODERATE.

8.2.3 Coal Gasification

Coal gasification is a method of producing relatively clean, burnable gas from almost any type

of coal or from petroleum coke. The basic process involves crushing the coal and partially

oxidizing the carbon in the coal. Partial oxidation converts the coal into a gaseous fuel

composed primarily of combustible hydrogen and carbon monoxide. The gas can be piped

directly into a gas turbine to generate electricity. The exhaust from the gas turbine is ducted

into a heat recovery steam generator to produce steam for a conventional steam turbine

generator. To make the overall process both environmentally safe and thermally efficient, a

coal gasification plant must integrate a number of different technologies. Major systems include

fuel preparation, an air separation unit, a gasifier, acid gas removal, sulfur recovery, a

combustion turbine generator, a heat recovery steam generator, and a steam turbine generator

(TVA 2003).

I Consideration of a coal gasification generating plant to replace Monticello was not included as

an alternative in the NMC ER. Due to size constraints, the staff believes that the Monticello site

would not be a viable location for a representative coal gasification plant. The environmental

impacts of the coal gasification alternative are examined in this section for an alternate

greenfield site. The staff assumed that the plant would use a closed-cycle cooling system. To

replace the 600-MW(e) generating capacity of Monticello the coal gasification plant would have

two 340-MW(e) modules, each consisting of one coal gasification plant, one combustion

turbine, and one heat recovery steam generator. The steam recovered from each module

would be collected and routed to a low-pressure steam turbine generator. An air separation

plant would be constructed for each gasifier to supply the pressurized 95 percent (by volume)

oxygen required for the oxygen-blown gasifiers (TVA 2003). This assumption overstates the

environmental impacts of replacing the 600 MW(e) from Monticello since the coal gasification

NUREG-1437, Supplement 26 8-26 August 2006 1
Environmental Impacts of Alternatives

plant would have slightly larger capacity in MW(e) than the existing Monticello plant. However,

the staff has determined that the differences in impacts between 680 MW(e) and 600 MW(e) of

coal gasification would not be significant and would not change the standard of significance

(SMALL, MODERATE, or'LARGE) of any impacts.

Delivery of coal and/or petroleum coke to an alternate greenfield site would be needed.

Approximately 3698 tons would be shipped in daily, probably via barge (TVA 2003).

Approximately 38 tons of limestone per day would likely be required for air pollution control.

Trucking would be used for limestone delivery. Fuel oil would be required for startup activities,

but would not be used as a backup fuel (TVA 2003).

The overall impacts of constructing a coal gasification plant using closed-cycle cooling at an

alternate greenfield site are discussed in the following sections and summarized in Table 8-4.

The impact categorizations in Table 8-4 are based on 680 MW(e) of coal gasification

generating capacity.

Land Use

NRC staff assumes siting of the coal gasification plant at an alternate greenfield site.

Approximately 1700 ac would be impacted for the power block; fuel handling, storage and

transportation facilities; infrastructure facilities; and waste disposal. There would be additional

land impacts for coal and limestone mining, electric power transmission lines, and cooling water

intake and discharge pipelines.

In the GELS, the staff estimated that approximately 21,745 ac would be affected for mining the

coal and disposing of the waste to support a 1000-MW(e) coal plant during its operational life

(NRC 1996). A replacement coal gasification plant to replace the 600-MW(e) capacity of

Monticello would affect proportionately less land.

Overall, land use impacts can be characterized as MODERATE to LARGE.

* Ecology

At an alternate site, the coal gasification alternative would introduce construction impacts and

operational impacts. Even assuming siting at a previously disturbed area, the impacts would

alter the ecology. Impacts could include wildlife habitat loss, reduced productivity, habitat

August 2006 8-27 NUREG-1437, Supplement 26 I
Environmental Impacts of Alternatives

Table 8-4. Summary of Environmental Impacts of a Coal Gasification

Generation

Cooling

Plant at an Alternate Greenfield Site Using Closed-Cycle

Impact Category Impact Comment

Land Use MODERATE to

LARGE

Several hundred acres would be impacted for the power block; fuel

handling, storage and transportation facilities; infrastructure facilities;

waste disposal; and an appropriate buffer for adjacent land uses.

There would be additional land impacts for coal and limestone mining,

electric power transmission lines, and cooling water intake and

discharge pipelines.

Ecology

Water Use and

Quality-Surface

Water

Water Use and

QualityGroundwater

Air Quality

SMALL to

LARGE

SMALL to

MODERATE

* SMALL to

MODERATE

MODERATE

Impact depends on whether the site has been previously developed.

Factors to consider include location and ecology of the site,

transmission line route, and rail spur route. In total, impacts could

include habitat degradation, fragmentation, or loss as a result of

construction activities and conversion of land to industrial use.

Ecological communities might experience reduced productivity and

biological diversity from disturbing previously intact land.

Total impacts depend on the volume of water withdrawn, the

constituents of the discharge water, the characteristics of the surface

water body, and the new intake structures required.

Impact depends on volume of water withdrawn and the characteristics

of the groundwater source.

Sulfur oxides: 1815 tons/yr. National and regional impacts would be

minimal because of emissions offsets through the SO2 trading

program.

Nitrogen oxides: 828 tons/yr.

Particulates: 259 tons/yr of PM, 0.

Carbon monoxide: 960 tons/yr.

Small amounts of mercury and other hazardous air pollutants would

be discharged along with approximately 4.7 million tons/yr of

unregulated carbon dioxide.

Waste streams from the 680-MW(e) plant would be approximately

126,000 tons/yr of slag, 10,000 tons/yr of fly ash, 50,000 tons/yr of

sulfur, 320 tons/yr of raw water treatment sludge, 201 tons/yr of

general waste water treatment sludge, and 10 tons/yr of sludges from

the biotreatment of gasification process waste water.

Impacts are uncertain, but considered SMALL in the absence of more

quantitative data.

Peak construction employment would be approximately 1000

workers. The operating workforce would be between 100 to 150

employees. Construction impacts depend on location, but could be

LARGE if plant is located In an area that is more rural than the

Monticello site. Wright County would experience loss of tax base and

employment, potentially offset by projected economic growth.

Waste MODERATE

I Human Health

Socloeconomics

SMALL

SMALL to

LARGE

NUREG-1437, Supplement 26 8-28 August 2006 1
Environmental Impacts of Alternatives

Table 8-4. (contd)

Impact Category Impact Comment

Socioeconomics SMALL to Peak construction employment would be approximately 1000

LARGE workers. The operating workforce would be between 100 to 150

employees. Construction impacts depend on location, but could be

LARGE If plant is located in an area that is more rural than the

Monticello site. Wright County would experience loss of tax base

and employment, potentially offset by projected economic growth.

Socioeconomics SMALL to Transportation impacts associated with construction workers could

(Transportation) MODERATE be SMALL to MODERATE.

For rail transportation of coal and lime, the impact is considered

SMALL to MODERATE. For barge transportation, the Impact is

considered SMALL.

Aesthetics SMALL to Impacts could include visual impairment, infrastructure for delivery of

LARGE coal and limestone, and noise. The severity of impacts range from

SMALL to LARGE and are dependent on location.

Historic and SMALL A new plant at a greenfield location would necessitate cultural

Archaeological resource studies. Any potential impacts can likely be effectively

Resources managed.

Environmental SMALL to Impacts will vary depending on population distribution and makeup

Justice MODERATE at the site.

fragmentation, and a local reduction in biological diversity. Use of cooling makeup water from a

nearby surface water body could have adverse aquatic resource impacts. Construction and

maintenance of a transmission line and a rail spur or barge facility, if needed, would also have

ecological impacts.

Overall, with the large degree of uncertainty in the magnitude of impacts resulting from not

analyzing a specific site or design, the ecological impacts from a new coal gasification

generating plant at an alternate greenfield site could range from SMALL to LARGE.

* Water Use and Quality-Surface Water

At an alternate site, water use and quality impacts would depend on the volume of water

withdrawn and discharged, the constituents in the discharge water, and the characteristics of

the surface water body. For purposes of this analysis, the staff adjusted the water volume for a

single-unit site. The highest sustained water needs during operation would be approximately

9175 gpm. Of the 9175 gpm almost half would be for cooling system makeup water (TVA

2003). Discharges would be regulated by the State or by the EPA. Construction-related

impacts would be mitigable and temporary.

Overall, surface water use and quality impacts at an alternate greenfield site can be

characterized as SMALL to MODERATE depending on the location chosen.

I

I

August 2006 8-29 NUREG-1437, Supplement 26 I
Environmental Impacts of Alternatives

* Water Use and Quality-Groundwater

Any impacts to groundwater during operation would most likely be associated with storage and

handling of feedstocks and the storage, handling, and disposal of wastes generated. Runoff

from the coal and petroleum coke storage areas would be collected in a drainage basin and

treated as needed (TVA 2003). Impacts would depend on the volume of groundwater

withdrawn and the characteristics of the groundwater source.

Overall, groundwater use and quality impacts at an alternate greenfield site can be

characterized as SMALL to MODERATE depending on the location chosen.

* Air Quality

The air quality impacts of coal-fired generation vary considerably from those of nuclear

generation emissions of SO2, NOx, particulates, carbon monoxide, hazardous air pollutants

such as mercury, and naturally occurring radioactive materials.

Estimated air emissions for a coal gasification plant meeting all applicable regulatory

requirements and sized to fully replace the 600-MW(e) capacity of Monticello are shown in

Table 8-4 (TVA 2003). The estimated emissions are based on using petroleum coke as fuel.

Emissions of SOX are higher for petroleum coke than if coal is used as the fuel.

A new coal gasification generating plant would need to meet the new source review

requirements in Title I of the Clean Air Act (42 USC 7401-7515). The plant would need an

operating permit issued under Title V of the Clean Air Act (42 USC 7661-7661 f). The plant

would also need to comply with the new source performance standards for new generating

plants in 40 CFR Part 60, Subpart D. The standards establish limits for particulate matter and

opacity, SO2 , and NOX.

The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

Subpart P, including a specific requirement for review of any new major stationary source in an

area designated as attainment or unclassified under the Clean Air Act (40 CFR 51.307).

Section 169A of the Clean Air Act establishes a national goal of preventing future and

remedying existing impairment of visibility in mandatory Class I Federal areas when impairment

is from air pollution resulting from human activities. In addition, the EPA issued a new regional

haze rule in 1999 (EPA 1999). The rule specifies that for each mandatory Class I Federal area

located within a state, state agencies must establish goals that provide for reasonable progress

towards achieving natural visibility conditions. The reasonable progress goals must provide for

an improvement in visibility for the most-impaired days over the period of the implementation

plan and ensure no degradation in visibility for the least-impaired days over the same period

(40 CFR 51). If a new coal gasification power plan were located close to a mandatory Class I

Federal area, additional air pollution control requirements could be imposed.

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Environmental Impacts of Alternatives

In March 2005, the EPA issued CAIR, which will permanently cap emissions of SO2 and NO, in

the eastern United States (EPA 2005b). CAIR achieves large reductions of S and/or NO,

emissions across 28 eastern states and the District of Columbia. When fully implemented,

CAIR will reduce SO2 emissions in these states by over 70 percent, and NO, emissions by over

60 percent from 2003 levels. This will result in $85 to $100 billion in health benefits, and nearly

$2 billion in visibility benefits per year by 2015, and will substantially reduce premature mortality

in the eastern United States. The benefits will continue to grow each year with further

implementation. By 2015, CAIR will help Minnesota sources reduce emissions of SO2 by

40,000 tons, or 36 percent, and emissions of NO, by 53,000 tons, or 59 percent (EPA 2005a).

Any new fossil-fired power plant sited in Minnesota would be subject to the CAIR limitations.

A coal gasification plant would also have unregulated carbon dioxide emissions that could

contribute to global warming. The staff estimates that coal gasification plants sufficient to

replace the power generated at Monticello would emit approximately 4.7 million tons per year of

carbon dioxide (TVA 2003).

Overall, the air quality impacts associated with new coal gasification plants to replace the power

generated at Monticello would be MODERATE. The impacts would be clearly noticeable, but

would not destabilize air quality.

° Waste

The major solid waste and by-product streams would be generated by the gasifiers. Slag, fly

ash, and sulfur account for more than 99 percent of the solids produced by coal gasification

plants, with the remaining 1 percent consisting of spent catalysts and water treatment sludges.

The generation rates in tons per year for a 680-MW(e) plant are shown in Table 8-4 (TVA

2003). The slag produced is an inert, glass-like material that has been found in coal

gasification demonstrations to be non-leachable (TVA 2003). Based on testing at gasification

demonstration plants, the slag and fly ash from gasification of eastern bituminous coal is

expected to be below the RCRA threshold limits for hazardous designation (TVA 2003). Most

of the sulfur in the coal is converted to hydrogen sulfide in the synthetic gas. The hydrogen

sulfide is removed by acid gas removal and then converted to elemental sulfur by-product in the

sulfur recovery system.

There would be three process solid waste streams composed of sludges from raw water or

waste water treatment: raw water treatment sludge, general waste water treatment sludge, and

sludge from the biotreatment of gasification process waste water. Generation amounts are

shown in Table 8-4. These sludges are typically not hazardous and would be disposed of at

nearby State-approved municipal disposal sites (TVA 2003).

Construction-related debris would be generated during construction activities for the coal

gasification units and disposed at a landfill.

August 2006 8-31 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

For all the preceding reasons, the appropriate characterization of waste impacts from coal

gasification is MODERATE; the impacts would be clearly noticeable but would not destabilize

any important resource.

* Human Health

Power generation from coal introduces worker risks from coal and limestone mining, worker

and public risks from coal and lime/limestone transportation, worker and public risks from

disposal of coal combustion wastes, and public risks from inhalation of stack emissions.

Emission impacts can be widespread and health risks difficult to quantify. The coal gasification

alternative also introduces the risk of coal-pile fires and attendant inhalation risks.

The staff stated in the GElS that there could be human health impacts (cancer and

emphysema) from inhalation of toxins and particulates from a coal-fired plant, but did not

identify the significance of these impacts (NRC 1996).

Regulatory agencies, including the EPA and State agencies, set air emission standards and

requirements based on human health impacts. These agencies also impose site-specific

emission limits as needed to protect human health.

I Overall, human health impacts from inhaling toxins and particulates generated by burning coal

at a newly constructed coal gasification plant are characterized as SMALL.

Socioeconomics

Peak employment during construction would be approximately 1000 workers (Bily 2005).

During construction of the coal gasification plant, the surrounding communities would

experience demands on housing and public services that could have SMALL impacts. These

impacts would be tempered by construction workers commuting to the site from other parts of

Wright County or from other counties. After construction, the communities would be impacted

by the loss of the construction jobs, although this loss would be possibly offset by other growth

currently being projected for Wright and Sherburne counties (USCB 2004). The permanent

operating staff would be between 100 to 150 workers (Bily 2005).

Construction of a replacement coal gasification plant at an alternate greenfield site would

relocate some socioeconomic impacts, but would not eliminate them. The communities around

Monticello would still experience the impact of the loss of permanent employees, contractors,

and temporary workers associated with Monticello operations. This would be partially offset by

projected economic growth; the communities around the new site would have to absorb the

impacts of a temporary work force and a permanent work force of approximately 100 to 150

workers (Bily 2005). Communities in Wright County in particular would experience losses in

both employment and tax revenues due to the Monticello site closure, assuming the plant is

constructed outside the area. This impact could be MODERATE to LARGE. In the GELS, the

staff stated that socioeconomic impacts at a rural site would be larger than at an urban site,

NUREG-1437, Supplement 26 8-32 August 2006 1
Environmental Impacts of Alternatives

because more of the peak construction work force would need to move to the area to work.

Alternate greenfield sites would need to be analyzed on a case-by-case basis. Socioeconomic

impacts at a rural site could be LARGE.

Overall, socioeconomic impacts of a new coal gasification plant would be SMALL to LARGE

depending on the site.

* Socioeconomics (Transportation)

Transportation-related impacts associated with commuting construction workers at an alternate

greenfield site are site-dependent, but could be SMALL to MODERATE. Transportation

impacts related to commuting of plant operating personnel would also be site-dependent, but

can be characterized as SMALL to MODERATE.

Coal and limestone would likely be delivered to an alternate site by rail or barge.

Socioeconomic impacts associated with rail transportation would likely be SMALL to

MODERATE. For example, there would be delays to highway traffic as trains pass and there

could be negative impacts on the value of property close to the train tracks. The

socioeconomic impacts of barge delivery of coal and limestone would likely be SMALL.

* Aesthetics

Potential aesthetic impacts of construction and operation of a coal gasification plant include

visual impairment resulting from the presence of an industrial facility, particularly exhaust stacks

and flaring stacks to burn waste gas. Flaring operations would generally be visible within a 3-mi

radius, particularly at night. Vapor fog from the cooling towers and stack emissions could be

visible up to 10 mi or more. However, the topography throughout most of southern Minnesota

is rolling, with forested tracts common in some areas. Both of these factors act to reduce the

viewshed and limit potential for impairment of visual aesthetics from onsite and offsite

infrastructure. If needed, new electric power transmission lines and/or a rail spur could have

significant aesthetic impacts.

Overall, the aesthetic impacts at an alternate site would be SMALL to LARGE depending on the

location chosen.

A coal gasification plant would introduce mechanical sources of noise that would be audible

offsite. Sources contributing to total noise produced by plant operation are classified as

continuous or intermittent. Continuous sources include the mechanical equipment associated

with normal plant operations. Intermittent sources include the equipment related to coal

handling, solid-waste disposal, transportation related to coal and lime delivery, use of outside

loudspeakers, and the commuting of plant employees.

Noise impacts associated with rail delivery of coal and lime to a plant would be most significant

for residents living in the vicinity of the facility and along the rail route. Although noise from

August 2006 8-33 NUREG-1437, Supplement 26 I
Environmental Impacts of Alternatives

passing trains significantly raises noise levels near the rail corridor, the short duration of the

noise reduces the impact. Nevertheless, given the frequency of train transport and the many

residents likely to be within hearing distance of the rail route, the impacts of noise on residents

in the vicinity of the facility and the rail line is considered MODERATE. Overall, the noise

impacts at an alternate site would be MODERATE to LARGE depending on the location

chosen.

* Historic and Archaeological Resources

At an alternate site, a cultural resource inventory would likely be needed for any onsite property

that has not been previously surveyed. Other lands, if any, that are acquired to support the

plant would also likely need an inventory of field cultural resources, identification and recording

of existing historic, and archaeological resources, and possible mitigation of adverse effects

from subsequent ground-disturbing actions related to physical expansion of the plant site.

Before construction at an alternate greenfield site, studies would likely be needed to identify,

evaluate, and address mitigation of the potential impacts of new plant construction on cultural

resources. The studies would likely be needed for all areas of potential disturbance at the

proposed plant site and along associated corridors where new construction would occur (e.g.,

roads, transmission corridors, rail lines, or other rights-of-way). Historic and archaeological

resource impacts can generally be effectively managed and as such are considered SMALL.

• Environmental Justice

Environmental justice impacts would depend upon the population distribution around the

chosen location. Construction activities would offer new employment possibilities, but could

have negative impacts on the availability and cost of housing, which could disproportionately

affect minority and low-income populations. Overall, environmental justice impacts are likely to

be SMALL to MODERATE.

8.2.4 Nuclear Power Generation

Since 1997, the NRC has certified three new standard designs for nuclear power plants under

10 CFR Part 52, Subpart B. These designs are the 1300-MW(e) U.S. Advanced Boiling Water

Reactor (10 CFR Part 52, Appendix A), the 1300-MW(e) System 80+ Design (10 CFR Part 52,

Appendix B), and the 600-MW(e) AP600 Design (10 CFR Part 52, Appendix C). All of these

plant designs are light-water reactors. Although no applications for a construction permit or a

combined license based on these certified designs have been submitted to NRC, the

submission of the design certification applications indicates continuing interest in the possibility

of licensing new nuclear power plants. In addition, recent escalation in prices of natural gas

and electricity have made new nuclear power plant construction more attractive from a cost

standpoint. Consequently, construction of a new nuclear power plant at either the Monticello

site or an alternate greenfield is considered in this section. The staff assumed that the new

NUREG-1437, Supplement 26 8-34 August 2006 1
Environmental Impacts of Alternatives

nuclear plant would have a 40-year period of plant operation. Consideration of a new nuclear

generating plant to replace Monticello was not included in the NMC ER.

NRC has summarized environmental data associated with the uranium fuel cycle in Table S-3

of 10 CFR 51.51. The impacts shown in Table S-3 are representative of the impacts that would

be associated with a replacement nuclear power plant built to one of the certified designs, sited

at Monticello or an alternate greenfield site. The impacts shown in Table S-3 are for a

1 000-MW(e) reactor and would need to be adjusted to reflect impacts of 600 MW(e) of new

nuclear power. The environmental impacts associated with transporting fuel and waste to and

from a light-water cooled nuclear power reactor are summarized in Table S-4 of 10 CFR 51.52.

The summary of NRC's findings on NEPA issues for license renewal of nuclear power plants in

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, is also relevant, although not directly

applicable, for consideration of environmental impacts associated with the operation of a

replacement nuclear power plant. Additional environmental impact information for a

replacement nuclear power plant using closed-cycle cooling is presented in Section 8.2.4.1 and

using open-cycle cooling in Section 8.2.4.2.

8.2.4.1 Closed-Cycle Cooling System

The overall impacts of the nuclear generating system are discussed in the following sections.

* The impacts are summarized in Table 8-5. The extent of impacts at an alternate greenfield site

* will depend on the location of the particular site selected.

* Land Use

The existing facilities and infrastructure at the Monticello site would be used to the extent

practicable, limiting the amount of new construction that would be required. Specifically, the

staff assumed that a replacement nuclear power plant would use the existing circulating water

system, switchyard, offices, and transmission line rights-of-way. Much of the land that would be

used has been previously disturbed.

A replacement nuclear power plant at the Monticello site would alter approximately 500 to

1000 ac of land to industrial use. There would be no net change in land needed for uranium

mining because land needed for the new nuclear plant would offset land needed to supply

uranium for fuel for Monticello.

The impact of a replacement nuclear generating plant on land use at the existing Monticello site

is best characterized as MODERATE. The impact would be greater than the OL renewal

alternative.

Land-use impacts at an alternate greenfield site would be similar to siting at Monticello except

for the land needed for a transmission line to connect to existing lines to transmit power to

NSP's customers in the Southern Minnesota area. Assuming a 60-mi transmission line, an

additional 2500 ac would be needed. In addition, it may be necessary to construct a rail spur to

August 2006 8-35 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

an alternate site to bring in equipment during construction. Depending particularly on

transmission line routing,siting a new nuclear plant at an alternate greenfield site would result

in MODERATE to LARGE land-use impacts.

Ecology

Locating a replacement nuclear power plant at the Monticello site would alter ecological

resources because of the need to convert roughly 500 to 1000 ac of land to industrial use.

Some of this land, however, would have been previously disturbed.

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

Generation at the Monticello Site and an Alternate Site Using

Closed-Cycle Cooling

Impact Monticello Site Alternate Greenfield Site

Category Impact Comment Impact Comment

Land Use MODERATE Requires approximately MODERATE Same as Monticello site plus

500 to 1000 ac for the to LARGE land for transmission line

plant and 1000 ac for (2500 ac assuming a 60-mi line).

uranium mining.

Ecology MODERATE Uses undeveloped areas MODERATE Impact depends on location and

at current Monticello site. to LARGE ecology of the site, surface

water body used for intake and

discharge, and transmission line

route; potential habitat loss and

fragmentation; reduced

productivity and biological

diversity.

Water Use SMALL Uses existing cooling canal SMALL to Impact will depend on the

and Quality- system. MODERATE volume of water withdrawn and

Surface discharged and the

Water characteristics of the surface

water body.

Water Use SMALL Uses existing cooling canal SMALL to Impact will depend on the

and Quality- system. MODERATE volume of water withdrawn and

Groundwater discharged and the

characteristics of the

groundwater source.

Air Quality SMALL Fugitive emissions and SMALL Same impacts as Monticello site.

emissions from vehicles

and equipment during

construction. Small

amount of emissions from

diesel generators and

possibly other sources

during operation.

NUREG-1437, Supplement 26 8-36 August 2006 1
Environmental Impacts of Alternatives

Table 8-5. (contd)

Impact M

Category Impact

Waste SMALL

Human

Health

SMALL

lonticello Site

Category

Waste impacts for an

operating nuclear power

plant are set out in 10 CFR

51, Appendix B, Table B-1.

Debris would be generated

and removed during

construction.

Human health impacts for

an operating nuclear

power plant are set out in

10 CFR 51, Appendix B,

Table B-1.

During construction,

impacts would be

MODERATE. Up to

2500 workers during peak

period of the 6-year

construction period.

Operating work force

assumed to be similar to

current Monticello plant;

tax base preserved.

Impacts during operation

would be SMALL.

SMALL

SMALL to

LARGE

Socio- SMALL to

economics MODERATE

Alternate Greenfield Site

Impact Category

SMALL Same impacts as Monticello site.

Same impacts as Monticello site.

Construction impacts depend on

location. Impacts at a rural

location could be LARGE.

Wright County would experience

loss of tax base and

employment, possibly offset by

economic growth.

Socioeconomics

(Transportation)

SMALL to Transportation impacts

LARGE associated with

construction workers could

be MODERATE to LARGE.

Transportation impacts of

commuting plant personnel

would be SMALL.

SMALL to Transportation impacts of

LARGE construction workers could be

MODERATE to LARGE.

Transportation impacts of

commuting plant personnel

could be SMALL to MODERATE.

SMALL to Greatest impact is from the new

LARGE transmission line that would be

needed.

Aesthetics SMALL No exhaust stacks or

cooling towers would be

needed. Daytime visual

impact could be mitigated

by landscaping and

appropriate color selection

for buildings. Visual

impact at night could be

mitigated by reduced use

of lighting and appropriate

shielding. Noise Impacts

would be relatively small

and could be mitigated.

August 2006 8-37 NUREG-1437, Supplement 26
Environmental Impacts of Alternatives

Table 8-5. (contd)

Impact Monticello Site Alternate Greenfield Site

Category Impact Category Impact Category

Historic and SMALL Any potential impacts can SMALL Any potential impacts can likely

Archaeo- likely be effectively be effectively managed.

logical managed.

Resources

Historic and

Environ- SMALL Impacts on minority and SMALL to Impacts will vary depending on

mental low-income communities MODERATE population distribution and

Justice should be similar to those makeup at the site. Impacts to

experienced by the minority and low-income

population as a whole. residents of Wright County

Some impacts on housing associated with closure of

may occur during Monticello could be significant,

construction. but could also be mitigated by

projected economic growth for

the area.

Siting a replacement nuclear plant at Monticello would have a MODERATE ecological impact

that would be greater than renewal of the Monticello OL.

At an alternate site, there would be construction impacts and new incremental operational

impacts. Even assuming siting at a previously disturbed area, the impacts would alter the

ecology. Impacts could include wildlife habitat loss, reduced productivity, habitat fragmentation,

and a local reduction in biological diversity. Use of cooling makeup water from a nearby

surface water body could have adverse aquatic resource impacts. Construction and

maintenance of the transmission line, if needed, would also have ecological impacts. Overall,

the ecological impacts of a replacement nuclear plant at an alternate site could range from

MODERATE to LARGE.

Water Use and Quality-Surface Water

The replacement nuclear plant alternative at the Monticello site is assumed to use the existing

circulating water system, which would minimize incremental water-use and quality impacts.

Surface-water impacts are expected to remain SMALL; the impacts would be sufficiently minor

that they would not noticeably alter any important attribute of the resource.

Cooling towers would likely be used at an alternate site. For an alternate site, the impact on the

surface water would depend on the volume of water needed for makeup water, the discharge

volume, and the characteristics of the receiving body of water. Intake from and discharge to

any surface body of water would be regulated the Minnesota Department of Natural Resources

(MNDNR). The impacts would be SMALL to MODERATE.

NUREG-1 437, Supplement 26 8-38 August 2006 1
Environmental Impacts of Alternatives

* Water Use and Quality-Groundwater

The staff assumed that a new nuclear power plant located at Monticello would obtain potable,

process, and fire-protection water from onsite wells similar to the current practice for Monticello

(see Section 2.2.2). NMC operates five groundwater wells to meet the domestic water needs of

the Monticello site. It is unlikely that groundwater use for an alternative nuclear power plant at

Monticello would be significantly different than existing use at Monticello. Any groundwater

withdrawal would require a permit from the local permitting authority.

Overall, the impacts of the nuclear alternative at the Monticello site would be SMALL. The

impacts of the nuclear alternative at an alternate site would be SMALL to MODERATE.

* Air Quality

Construction of a new nuclear plant at Monticello or an alternate site would result in fugitive

emissions during the construction process. Exhaust emissions would also come from vehicles

and motorized equipment used during the construction process. These emissions are not

regulated. An operating nuclear plant would have minor air emissions associated with diesel

generators and other minor intermittent sources. These minor operating emissions for a plant

sited in Minnesota would be regulated by the MPCA. Overall, emissions and associated

impacts at either the Monticello site or an alternate site are considered SMALL.

* Waste

The waste impacts associated with operation of a nuclear power plant are set out in Table B-1

of 10 CFR Part 51, Subpart A, Appendix B. Construction-related debris would be generated

during construction activities and removed to an appropriate disposal site. Overall, waste

impacts of a new nuclear plant at either the Monticello site or an alternate site are considered

SMALL.

* Human Health

Human health impacts for an operating nuclear power plant are set out in 10 CFR Part 51,

Subpart A, Appendix B, Table B-1. Overall, human health impacts of a new nuclear plant at

either the Monticello site or an alternate site are considered SMALL.

* Socloeconomics

The construction period and the peak work force associated with construction of a new nuclear

power plant are currently unquantified (NRC 1996). In the absence of quantitative data, staff

assumed a construction period of 6 years and a peak work force of 2500. The staff assumed

that construction would take place while the existing nuclear unit continues operation and would

be completed by the time Monticello permanently ceases operations. During construction, the

communities surrounding the Monticello site would experience demands on housing and public

August 2006 8-39 NUREG-1437, Supplement 26
Environmental Impacts of Alternatives

services that could have MODERATE impacts. These impacts could be tempered by

construction workers commuting to the site from other parts of Wright County or from other

counties. After construction, the communities would be impacted by the loss of the construction

jobs, although this loss would be possibly offset by other growth currently being projected for

Wright and Sherburne counties.

The replacement nuclear unit is assumed to have an operating work force comparable to the

519 workers currently working at Monticello. The replacement nuclear unit would provide a new

tax base to offset the loss of tax base associated with decommissioning of Monticello.

For all of these reasons, the appropriate characterization of non-transportation socioeconomic

impacts for replacement nuclear units constructed at Monticello would be SMALL to

MODERATE; the socioeconomic impacts would be noticeable, but would be unlikely to

destabilize the area.

Construction of a replacement nuclear power plant at an alternate greenfield site would relocate

some socioeconomic impacts, but would not eliminate them. The communities around the

Monticello site would still experience the impact of Monticello operational job loss (although

potentially tempered by projected economic growth). The communities around the new site

would have to absorb the impacts of a large, temporary work force (up to 2500 workers at the

peak of construction) and a permanent work force of approximately 519 workers. In the GElS

(NRC 1996), the staff indicated that socioeconomic impacts at a rural site would be larger than

at an urban site because more of the peak construction work force would need to move to the

area to work. The Monticello site is within commuting distance of the Minneapolis/St. Paul

metropolitan area and is therefore not considered a rural site. Impacts at an alternate

greenfield site would need to be analyzed on a case-by-case basis and could range from

SMALL to LARGE.

Socloeconomics (Transportation)

During the 6-year construction period, up to 2500 construction workers would be working at the

Monticello site in addition to the 519 workers at Monticello. The addition of the construction

workers could place significant traffic loads on existing highways, particularly those leading to

the Monticello site. Such impacts would be MODERATE to LARGE. Transportation impacts

related to commuting of plant operating personnel would be similar to current impacts

associated with operation of Monticello and are considered SMALL.

Transportation-related impacts associated with commuting construction workers at an alternate

greenfield site are site-dependent, but could be MODERATE to LARGE. Transportation

impacts related to commuting of plant operating personnel would also be site-dependent, but

can be characterized as SMALL to MODERATE.

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Environmental Impacts of Alternatives

* Aesthetics

The containment buildings for a replacement nuclear power plant sited at Monticello and other

associated buildings would likely be visible in daylight hours over many miles. The replacement

nuclear plant would also likely be visible at night because of outside lighting. Visual impacts

could be mitigated by landscaping and selecting a color for buildings that is consistent with the

environment. Visual impact at night could be mitigated by reduced use of lighting and

appropriate use of shielding. No exhaust stacks would be needed.

Noise impacts from a new nuclear plant would be similar to those from the existing Monticello

site. Mitigation measures, such as reduced or no use of outside loudspeakers, can be

employed to reduce noise levels and maintain the impact of noise SMALL.

At an alternate greenfield site, there would be an aesthetic impact from the buildings, cooling

towers, and the plume associated with the cooling towers. There would also be a significant

aesthetic impact associated with construction of a new 60-mi transmission line to connect to

other lines to enable delivery of electricity to the southern Minnesota area. Noise impacts from

a new nuclear plant would be similar to those from the existing Monticello site. Mitigation

measures, such as reduced or no use of outside loudspeakers, can be employed to reduce

noise levels and maintain the impact of noise SMALL. Aesthetic impacts at a greenfield site

would be mitigated if the plant is located in an industrial area adjacent to other power plants.

Overall the aesthetic impacts associated with locating at an alternative site can be categorized

as SMALL to LARGE. The greatest contributor to this categorization is the aesthetic impact of

the new transmission line, if needed.

* Historic and Archaeological Resources

At both Monticello and an alternate greenfield site, a cultural resource inventory would likely be

needed for any onsite property that has not been previously surveyed. Other lands, if any, that

are acquired to support the plant would also likely need an inventory of field cultural resources,

identification and recording of existing historic and archaeological resources, and possible

mitigation of adverse effects from subsequent ground-disturbing actions related to physical

expansion of the plant site.

Before construction at Monticello or another site, studies would likely be needed to identify,

evaluate, and address mitigation of the potential impacts of new plant construction on cultural

resources. The studies would likely be needed for all areas of potential disturbance at the

proposed plant site and along associated corridors where new construction would occur (e.g.,

roads, transmission corridors, rail lines, or other rights-of-way). Historic and archaeological

resource impacts can generally be effectively managed and would be SMALL at either

Monticello or a greenfield site.

August 2006 8-41 NUREG-1 437, Supplement 26 I
Environmental Impacts of Alternatives

* Environmental Justice

No environmental pathways or locations have been identified that would result in

disproportionately high and adverse environmental impacts on minority and low-income

* populations if a replacement nuclear plant were built at the Monticello site. Some impacts on

housing availability and prices during construction might occur, and this could disproportionately

affect the minority and low-income populations. After completion of construction, it is possible

that the ability of the local government to maintain social services could be reduced at the same

time as diminished economic conditions reduce employment prospects for the minority and

low-income populations. Overall, impacts are expected to be SMALL. Projected economic

growth in Wright and Sherburne counties and the ability of minority and low-income populations

to commute to other jobs outside the Wright County area could mitigate any adverse effects.

Impacts at other sites would depend upon the site chosen and the nearby population

distribution, but are likely to be SMALL to MODERATE. Impacts to minority and low income

residents of Wright County associated with closure of Monticello could be significant, but could

also be mitigated by projected economic growth for the area.

8.2.4.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a nuclear power plant at the

Monticello site using onCe-through cooling. The impacts (SMALL, MODERATE, or LARGE) of

this option are the same as the impacts for a nuclear power plant using a closed-cycle system.

However, there are minor environmental differences between the closed-cycle and

once-through cooling systems. Table 8-6 summarizes the incremental differences.

Table 8-6. Summary of a Comparison of Environmental Impacts of a New Nuclear

Power Plant Sited at the Monticello Site with Once-Through Cooling

Impact Category Change in Impacts from Closed-Cycle Cooling

Land Use Impacts may be less (e.g., through elimination of cooling towers) or greater

(e.g., if a reservoir is required).

Ecology Impacts would depend on ecology at the site. Possible impacts associated

with entrainment of fish and shellfish in early life stages, impingement of

fish and shellfish, and heat shock.

Water Use and Increased water withdrawal leading to possible water-use conflicts, thermal

Quality-Surface Water load higher than with closed-cycle cooling.

Water Use and Quality- No change.

Groundwater

Air Quality No change.

NUREG-1437, Supplement 26 8-42 August 2006 1
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Table 8-6. (contd)

Impact Category Change In Impacts from Closed-Cycle Cooling

Waste No change.

Human Heath No change.

Socioeconomics No change.

Socioeconomics No change.

(Transportation)

Aesthetics Elimination of cooling towers.

Historic and No change.

Archaeological

Resources

Environmental Justice No change.

8.2.5 Purchased Electrical Power

If available, purchased power from other sources could potentially obviate the need to renew

the Monticello OL. Purchased power accounted for approximately 14 percent of NSP power

sales in 2004 (NSP 2004).

In Canada, 62 percent of the countryrs electrical generation capacity is derived from renewable

energy sources, principally hydropower (DOEIEIA 2001). Canada has plans-to continue

developing hydroelectric power, but the plans generally do'not include large-scale projects

(DOE/EIA 2001). Canada's nuclear generation is projected to increase by 1.7 percent by 2020,

but its share of power generation in Canada is projected to decrease from 14 percent currently

to 13 percent by 2020 (DOE/EIA 2001). Consequently, it is unlikely that electricity imported

from Canada would be able to replace the Monticello generating capacity.

The staff assumes that 100 mi of new 345-kV transmission lines on a 1 50-ft wide corridor in

southern Minnesota, potentially affecting approximately 1800 ac, would be required toimport

purchased power. Considering the nature of transmission line development and potential

mitigation measures available, impacts of greatest concern are those related to change in land

use, terrestrial ecological communities, and aesthetics. Land use and terrestrial ecological

habitats in the region where it is assumed the line would be built consists predominantly of rural

agricultural land interspersed in some areas with natural vegetation. Development of the

transmission line would limit changes in future land uses on the corridor to those that are

compatible with the line, but most agricultural practices and other currently compatible uses

could continue.

Establishment of a corridor for the transmission line would have little effect on either the amount

or value of habitat represented by agricultural land, the predominant habitat expected on lands

traversed by these facilities, because compatible agricultural practices could continue.

Similarly, open wetlands would be spanned and therefore little effected. Some visual

August 2006 8-43 NUREG-1 437, Supplement 26 1
Environmental Impacts of Alternatives

impairment of rural landscape could result from development of the transmission line.

However, the topography throughout most of southern -Minnesota is rolling, and forested tracts

occur in some parts of the area. Both of these attributes would act to reduce the viewshed and

limit potential for impairment of visual aesthetics. In addition, the presence of transmission

lines is not out of character for the existing rural southern Minnesota landscape. The staff

expects that routing of the line could be accomplished such that highly incompatible land uses,

important habitats and associated important species, and areas of potentially high impact on

visual aesthetics would be recognized and avoided or appropriately mitigated such that

important attributes of these resources would not be destabilized.

If power to replace Monticello capacity were to be purchased from sources within the United

States or a foreign country, the generating technology would likely be one of those described in

this SEIS and in the GElS (probably coal, natural gas, coal gasification, or nuclear). The

description of the environmental impacts of other technologies in Chapter 8 of the GElS is

representative of the purchased electrical power alternative to renewal of the Monticello OL.

Thus, the environmental impacts of imported power would still occur but would be located

elsewhere within the region, nation, or another country.

8.2.6 Other Alternatives

Other generation technologies considered by the staff in its analyses are discussed in the

following subsections.

8.2.6.1 Oil-Fired Generation

EIA projects that oil-fired plants will account for very little of the new generation capacity in the

United States during the 2000 to 2020 time period because of higher fuel costs and lower

efficiencies (DOE/EIA 2000).

NSP has several oil-fired units; however, they produce less than one percent of NSP's power

generation (NSP 2004). Oil-fired operation is more expensive than nuclear or coal-fired

operation. In addition, future increases in oil prices are expected to make oil-fired generation

increasingly more expensive than coal-fired generation. The high cost of oil has prompted a

steady decline in its use for electricity generation. In 2001, only 0.82 billion kWh of electricity

was generated from petroleum in the Mid-Continent Area Power Pool (MAPP), 0.5 percent of

the total generation in the region. The percentage of total generation from oil in MAPP is

projected to decrease to 0.1 percent by 2010 (DOE/EIA 2004).

Also, construction and operation of an oil-fired plant would have environmental impacts. For

example, in Section 8.3.11 of the GELS, the staff estimated that construction of a 1 000-MW(e)

oil-fired plant would require about 120 ac. Additionally, operation of oil-fired plants would have

environmental impacts (including impacts on the aquatic environment and air) that would be

similar to those from a coal-fired plant.

NUREG-1437, Supplement 26 8 -44 August 2006 1
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For these reasons, the staff does not consider oil-fired generation, by itself, a feasible

alternative to replace the baseload generating capacity at Monticello.

8.2.6.2 Wind Power

Wind power, by itself, is not suitable for large baseload capacity. As discussed in Section 8.3.1

of the GELS, wind has a high degree of intermittency, and average annual capacity factors for

wind plants are relatively low (on the order of 30 percent). Wind power, in conjunction with

energy storage mechanisms, might serve as a means of providing baseload power. However,

current energy storage technologies are too expensive for wind power to serve as a large

baseload generator.

Wind turbines are economical in wind power Classes 4 through 7 (average wind speeds of 12.5

to 21.1 mph) (DOE 2001). In Minnesota, Class 4 wind potential exists in exposed uplands in

the southern part of the state and in the Red River Valley between North Dakota and northern

Minnesota. These resources, particularly in the Buffalo Ridge area in the southwestern part of

the state, could support development approaching 3000 MW(e) by 2010, but significant

transmission constraints exist (MDC 2004). EIA projects that wind-power generating capacity in

MAPP totaled 1120 MW(e) in 2004 and will increase by 590 MW(e) by 2010 (DOEEIA 2004).

From a practical perspective, the scale of this technology is too small to directly replace a

* power generating plant equivalent to the output capacity of Monticello.

There are substantial impacts to natural resources (wildlife habitat, land-use, and aesthetic

impacts) from construction of wind power facilities. As stated in the GElS, land requirements

are high-1 50,000 ac of land to generate 1000 MW(e) of power. Approximately 90,000 ac

would be required for 600 MW(e) of wind power generating capacity to replace the Monticello

plant. The installation of large-scale wind farms requires construction of access roads for

turbine installation and maintenance and installation of transmission lines.

The impacts associated with large-scale construction, particularly in remote or sensitive areas,

could be LARGE. After the turbines and transmission lines are installed, the continuing impacts

from operation would include the aesthetic impact of the turbines and transmission lines, and

impacts to terrestrial biota, primarily birds, as a result of physical impacts with the turbine

blades.

For these reasons, the staff concludes that wind power alone is not a feasible substitute at this

time for the base load generation from Monticello. However, the staff recognizes that wind

power projects are being developed in areas with significant wind potential. Therefore, it is

reasonable to include wind power in a combination of alternatives that could replace the

generation from Monticello. Combined alternatives are discussed in Section 8.2.7.

August 2006 8-45 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

8.2.6.3 Solar Power

Solar technologies use the sun's energy and light to provide heat and cooling, light, hot water,

and electricity for homes, businesses, and industry. The two leading solar technologies are

photovoltaic and solar thermal. Photovoltaic devices use semiconducting materials that absorb

sunlight and convert it directly into electricity. Solar thermal devices use direct heat from the

sun, concentrating it in some manner (such as by reflection) to heat a transfer fluid to useful

temperatures. In the GElS, the staff noted that by its nature, solar power is intermittent.

Therefore, solar power by itself is not suitable for baseload capacity and is not a feasible

alternative to license renewal at Monticello. The average capacity factor of photovoltaic cells is

about 25 percent, and the capacity factor for solar thermal systems is about 25 percent to

40 percent. Solar power, in conjunction with energy storage mechanisms, might serve as a

means of providing baseload power. However, current energy storage technologies are too

expensive to permit solar power to serve as a large baseload generator. In addition, solar

technologies require high operation and maintenance cost, due to the need to clean reflectors

or collectors to ensure efficient operation.

Therefore, solar power technologies (photovoltaic and thermal) cannot currently compete with

conventional fossil-fueled technologies in grid-connected applications, due to high costs per

kilowatt of capacity (NRC 1996).

There are substantial impacts to natural resources (wildlife habitat, land-use, and aesthetic

impacts) from construction of solar-generating facilities. .As stated in the GElS, land

requirements are high-approximately 14,000 ac per 1000 MW(e) for solar thermal and

35,000 ac per 1000 MW(e) for photovoltaic systems. Approximately 8000 and 21,000 ac would

be required for 600 MW(e) of solar thermal or solar photovoltaic generating capability,

respectively, to replace the Monticello site. Neither type of solar electric system could be

accommodated at the Monticello site, and both would have large environmental impacts at a

greenfield site.

The Monticello site receives approximately 3.3 to 4.4 kWh of solar radiation per square meter

per day, compared to 6 to 8 kWh of solar radiation per square meter per day in areas of the

western United States, such as California, which are most promising for solar technologies

(NMC 2005). Some solar power may substitute for electric power in rooftop and building

applications. Implementation of non-rooftop solar generation on a scale large enough to

replace Monticello would likely result in LARGE environmental impacts.

Because of the natural resource impacts (land and ecological), the area's relatively low rate of

solar radiation, and high cost, solar power is not deemed a feasible baseload alternative to

renewal of the Monticello OL. However, the staff recognizes that distributed solar power can

provide generation and that during the license renewal period generation from solar power

could continue to grow.

NUREG-1 437, Supplement 26 8-46 August 2006 1
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8.2.6.4 Hydropower

Minnesota has an estimated 137 MW(e) of undeveloped hydroelectric resources (NMC 2005).

This amount is far less than needed to replace the 600 MW(e) capacity of Monticello. In

Section 8.3.4 of the GELS, the staff points out hydropower's percentage of U.S. generating

capacity is expected to decline because hydroelectric facilities have become difficult to site as a

result of public concern about flooding, destruction of natural habitat, and alteration of natural

river courses.

The staff estimated in the GElS that land requirements for hydroelectric power are

approximately 1 million ac per 1000 MW(e). Replacement of Monticello's generating capacity

would require flooding approximately 600,000 ac. Due to the large land-use and related

environmental and ecological resource impacts associated with siting hydroelectric facilities

large enough to replace Monticello, the staff concludes that local hydropower is not a feasible

alternative to Monticello OL renewal on its own. Any attempts to site hydroelectric facilities

large enough to replace Monticello would result in LARGE environmental impacts.

8.2.6.5 Geothermal Energy

Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

power where available. However, geothermal technology is not widely used as baseload

generation due to the limited geographical availability of the resource and immature status of

the technology (NRC 1996). As illustrated by Figure 8.4 in the GELS, geothermal plants are

most likely to be sited in the western continental United States, Alaska, and Hawaii where

hydrothermal reservoirs are prevalent. There is no feasible location in the MAPP for

geothermal capacity to serve as an alternative to Monticello. The staff concludes that

geothermal energy is not a feasible alternative for replacement of the baseload generating

capacity by renewal of the Monticello OL.

8.2.6.6 Wood Waste

The use of wood waste to generate electricity is largely limited to those states with significant

wood resources, such as California, Maine, Georgia, Minnesota, Oregon, Washington, and

Michigan. Electric power is generated in these states by the pulp, paper, and paperboard

industries, which consume wood and wood waste for energy, benefitting from the use of waste

materials that could otherwise represent a disposal problem.

A wood-burning facility can provide baseload power and operate with an average annual

capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC 1996).

The fuels required are variable and site-specific. A significant barrier to the use of wood waste

to generate electricity is the high delivered-fuel cost and high construction cost per MW of

generating capacity. The larger wood-waste power plants are only 40 to 50 MW(e) in size.

Estimates in the GElS suggest that the overall level of construction impact per MW of installed

capacity should be approximately the same as that for a coal-fired plant, although facilities

August 2006 8-47 NUREG-1437, Supplement 26
Environmental Impacts of Alternatives

using wood waste for fuel would be built at smaller scales. Like coal-fired plants, wood-waste

plants require large areas for fuel storage and processing and involve the same type of

combustion equipment.

The biomass power generating capacity in MAPP was 160 MW(e) in 2004 and is not expected

to increase through 2025 (DOE/EIA 2004). Due to uncertainties associated with obtaining

sufficient wood and wood waste to fuel a baseload generating facility, ecological impacts of

large-scale timber cutting (e.g., soil erosion and loss of wildlife habitat), and high inefficiency,

the staff has determined that wood waste is not a feasible alternative to renewing the

Monticello OL.

8.2.6.7 Municipal Solid Waste

Municipal waste combustors incinerate the waste and use the resultant heat to generate steam,

hot water, or electricity. The combustion process can reduce the volume of waste by up to

90 percent and the weight of the waste by up to 75 percent (EPA 2001). Municipal waste

combustors use three basic types of technologies: mass burn, modular, and refuse-derived

fuel (DOE/EIA 2001). Mass burning technologies are most commonly used in the United

States. This group of technologies process raw municipal solid waste "as is," with little or no

sizing, shredding, or separation before combustion.

Growth in the municipal waste combustion industry slowed dramatically during the 1990s after

rapid growth during the 1980s. The slower growth was due to three primary factors: (1) the

Tax Reform Act of 1986, which made capital-intensive projects such as municipal waste

combustion facilities more expensive relative to less capital-intensive waste disposal alternative

such as landfills; (2) the 1994 Supreme Court decision (C&A Carbone, Inc. v. Town of

Clarkstown), which struck down local flow control ordinances that required waste to be

delivered to specific municipal waste combustion facilities rather than landfills that may have

had lower fees; and (3) increasingly stringent environmental regulations that increased the

capital cost necessary to construct and maintain municipal waste combustion facilities

(DOE/EIA 2001).

The decision to burn municipal waste to generate energy is usually driven by the need for an

alternative to landfills rather than by energy considerations. The use of landfills as a waste

disposal option is likely to increase in the near term; however, it is unlikely that many landfills

will begin converting waste to energy because of unfavorable economics, particularly with

electricity prices declining in real terms. In 2002, only 110 MW(e) of municipal solid waste

generating capacity was available in MAPP, and only 10 MW(e) of additional capacity is

anticipated to be developed in the region through 2025 (DOE/EIA 2004).

Municipal solid waste combustors generate an ash residue that is buried in landfills. The ash

residue is composed of bottom ash and fly ash. Bottom ash refers to that portion of the

unburned waste that falls to the bottom of the grate or furnace. Fly ash represents the small

NUREG-1437, Supplement 26 8-48 August 2006 1
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particles that rise from the furnace during the combustion process. Fly ash is generally

removed from flue-gases using fabric filters and/or scrubbers (DOE/EIA 2001).

Currently there are approximately 102 waste-to-energy plants operating in the United States.

These plants generate approximately 2800 MW(e), or an average of approximately 28 MW(e)

per plant (IWSA 2004), much smaller than needed to replace the Monticello site.

The initial capital costs for municipal solid-waste plants are greater than for comparable

steam-turbine technology at wood-waste facilities. This is due to the need for specialized

waste-separation and -handling equipment for municipal solid waste (NRC .1996). Furthermore,

estimates in the GElS suggest that the overall level of construction impact from a waste-fired

plant should be approximately the same as that for a coal-fired plant. Additionally, waste-fired

plants have the same or greater operational impacts (including impacts on the aquatic

environment, air, and waste disposal). Some of these impacts would be moderate, but still

larger than the environmental effects of license renewal of Monticello. Therefore, municipal

solid waste would not be a feasible alternative to renewal of the Monticello OL, particularly at

the scale required.

8.2.6.8 Other Biomass-Derived Fuels

In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling

electric generators, including burning crops, converting crops to a liquid fuel such as ethanol,

and gasifying crops (including wood waste). In the GELS, the staff points out that none of these

technologies has progressed to the point of being competitive on a large scale or of being

reliable enough to replace a baseload plant such as Monticello. For these reasons, such fuels

do not offer a feasible alternative to renewal of the Monticello OL.

8.2.6.9 Fuel Cells

Fuel cells work without combustion and its environmental side effects. Power is produced

electrochemically by passing a hydrogen-rich fuel over an anode and air over a cathode and

separating the two by an electrolyte. The only by-products are heat, water, and carbon dioxide.

Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to steam

under pressure. Natural gas is typically used as the source of hydrogen.

Phosphoric acid fuel cells are generally considered first-generation technology. These fuel cells

are commercially available at cost of approximately $4500 per kilowatt of installed capacity. By

contrast, a diesel generator costs $800 to $1500 per kilowatt, and a natural gas turbine can be

even less (DOE 2004). Higher-temperature second-generation fuel cells achieve higher

fuel-to-electricity and thermal efficiencies. The higher temperatures contribute to improved

efficiencies and give the second-generation fuel cells the capability to generate steam for

cogeneration and combined-cycle operations. DOE has a performance target to reduce the

cost of fuel cells to $400 per kilowatt by 2010 (DOE 2004).

August 2006 8-49 NUREG-1 437, Supplement 26 I
Environmental Impacts of Alternatives

Two second-generation fuel cell technologies using molten carbonate and solid oxide

technology are currently being developed for commercial use. As market acceptance and

manufacturing capacity increase, natural gas-fueled fuel cell plants are projected to become

available (DOE 2004). At the present time, fuel cells are not economically or technologically

competitive with other alternatives for baseload electricity generation. Fuel cells are,

consequently, not a feasible alternative to renewal of the Monticello OL.

8.2.6.10 Delayed Retirement

Extending the lives of existing non-nuclear generating plants beyond the time they were

originally scheduled for retirement represents another potential alternative to license renewal.

However, delaying retirement in order to compensate for Monticello generally would be

unreasonable without major construction to upgrade or replace plant components. NSP

undertakes upgrades of its older baseload plants in cases where it is reasonable to do so.

Such actions are currently accounted for in NSP's plans to meet anticipated demands

irrespective of the loss of generating capacity if the Monticello OL is not renewed and,

therefore, does not represent a realistic option.

For this reason, delayed retirement of other NSP generating units would not be a feasible

alternative to renewal of the Monticello OL.

8.2.6.11 Utility-Sponsored Conservation

The utility-sponsored conservation alternative refers to a situation in which Monticello ceases to

operate, no new generation is brought online to meet the lost generation, and the lost

generation is instead replaced by more efficient use of electricity. More efficient use would

arise from utility-sponsored conservation programs, potentially including energy audits,

incentives to install endrgy-efficient equipment, and informational programs to inform electricity

consumers of the benefits of, and possibilities for, electricity conservation.

Under provisions of Minnesota Statute 216B.241, Minnesota public utilities, rural electric

cooperatives, and municipal utilities are required to invest 1.5 percent of in-state revenues in

projects designed to reduce their customers' consumption of electricity and improve efficient

use of energy resources. Utilities that operate nuclear generating facilities like Monticello are

required to invest 2.0 percent of revenues in this manner. NSP has in place a wide variety of

electrical energy conservation programs and activities including conservation programs, energy

efficiency programs, and load management programs. Conservation programs such as NSP's

Energy Solutions newsletter and internet-based information resources are designed to educate

and inform customers about energy efficiency and NSP offerings. Energy efficiency programs

like ConservationWise from Xcel Energy help customers increase energy efficiency by

providing rebates, pricing, or other incentives to purchase energy-efficient systems or

components; renovate facilities that meet specific energy efficiency standards; undertake

energy conservation assessments; and obtain expert energy conservation design assistance.

Load management programs such as OperationWise from Xcel Energy encourage customers

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to switch load to customer-owned standby generators during periods of peak demand, and

include features like Saver's Switch that encourages customers to allow a portion of their load

to be interrupted during periods of peak demand.

In its order approving Xcel Energy's 2000 Integrated Resource Plan, the Minnesota Public

Utilities Commission (MPUC) adopted the DSM goal referred to as the 175 percent incentive

scenario for the 2000-2014 planning period. This scenario established aggressive targets of

3253 gigawatt-hours (GWh) of cumulative energy savings and 1174 MW of cumulative peak

demand savings in NSP's service area over this period. NSP surpassed its annual goals in the

early years of the program, but anticipates that it will become increasingly difficult to

cost-effectively maintain annual targets (50 to 80 MW) in the future.

Additionally, even if these aggressive annual DSM savings targets are achieved, the cumulative

savings through 2010 would be insufficient to replace generation lost as a result of Monticello

operations termination at the end of its current operating license. Moreover, NSP credits these

DSM goals in its demand forecasts; therefore, they cannot be used as credits to offset the

power generated by Monticello.

Therefore, the staff does not consider energy.efficiency, by itself, as a feasible alternative to

license renewal. However, the staff recognizes that energy conservation is promoted and

increases in energy efficiency occur as a normal result of replacing older equipment with

modern equipment. It is reasonable to include conservation in a combination of generation..

sources that could replace Monticello. Combined alternatives are discussed in Section 8.2.7.

8.2.7 Combination of Alternatives

Even though individual alternatives to renewal of the Monticello OL might not be sufficient on

their own to replace Monticello's generating capacity due to the small potential generating

capacity of the resource or lack of cost-effective opportunities, it is conceivable that a

combination of alternatives might be cost-effective.

There are many possible combinations of alternatives. As discussed previously, these

combinations could include baseload gas-fired or coal-fired plants, purchased power,

alternative and renewable technologies, and conservation. For the purpose of this discussion,

one combination of alternatives has been assumed: 300 MW(e) of combined-cycle natural

gas-fired generation using closed-cycle cooling, 150 MW(e) purchased from other generators,

50 MW(e) produced by new wind power facilities in southern Minnesota state, and 100 MW(e)

of energy conservation. The impacts of other combinations, such as those from combinations

that include solar power, would be different and possibly less than from the assumed i

combination. In some areas, such as the aesthetic impact of solar panels, the impacts would

be at least as large as the impact of the assumed combination of alternatives. In other areas,

such as waste, impacts would be smaller for these alternative technologies.

Table 8-7 contains a summary of the environmental impacts of the assumed combination of

alternatives. The impacts are based on the gas-fired generation impact assumptions discussed

August 2006 8-51 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

in Section 8.2.2, adjusted for the reduced generating capacity. While the DSM measures would

have few environmental impacts, operation of the new gas-fired plant would result in increased

emissions and environmental impacts. The environmental impacts associated with power

purchased from other generators would still occur but would be located elsewhere within the

region or nation, as discussed in Section 8.2.5. The impacts of purchased power are not shown

in Table 8-7. The staff concludes that it is very unlikely that the environmental impacts of any

reasonable combination of generating and conservation options could be reduced to the level of

impacts associated with renewal of the Monticello OL.

Table 8-7. Summary of Environmental Impacts for an Assumed Combination of

Generating (Combined-Cycle Natural Gas-Fired Generation, Wind

Power, and DSM) and Acquisition Alternatives at Monticello and a

Greenfield Site

Impact Monticello Site Alternate Greenfield Site

Category Impact Comment Impact Comment

Land Use SMALL to 23 ac for gas-fired plant SMALL to Same as Monticello site.

MODERATE power block, offices, roads, MODERATE

and parking areas.

Additional impact at wind

power sites (at least 50 ac).

Additional impact for

construction of underground

natural gas pipeline, electric

power transmission line,

and cooling-water

intake/discharge piping.

Ecology SMALL to Uses undeveloped areas at SMALL to Impact depends on location and

MODERATE current Monticello site, plus MODERATE ecology of the sites, surface

gas pipeline. Habitat loss water body used for intake and

due to development of wind discharge, and transmission and

power sites could have a pipeline routes; potential habitat

MODERATE impact. Some loss and fragmentation; reduced

increase in bird mortality at productivity and biological

wind turbines, diversity. Some increase in bird

mortality at wind turbines.

Water Use SMALL Uses existing circulating SMALL to Impact depends on volume of

and Quality- water system. MODERATE water withdrawn, the

Surface constituents in the discharge

Water water, and the characteristics of

surface water body.

Water Use SMALL Uses existing groundwater SMALL to Impact depends on volume of

and Quaiity- wells. MODERATE water withdrawn.

Groundwater

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Table 8-7. (contd)

Impact Monticello Site Alternate Greenfield Site

Category Impact Comment Impact Comment

Air Quality MODERATE Sulfur oxides: 4.5 tons/yr MODERATE Same as Monticello site.

Nitrogen oxides: 67 tons/yr

Carbon monoxide: 102

tons/yr

PM,0 particulates: 13 tons/yr

Some hazardous air

pollutants. Additional

emissions from producers of

purchased power.

Waste

Human

Health

SMALL

SMALL

Socio- SMALL to

economics MODERATE

Socio- MODERATE

economics

(Transportation)

Aesthetics SMALL

Minimal waste generated.

Impacts considered to be

minor.

During construction,

Impacts would be SMALL to

MODERATE. Up to 250

additional workers during

the peak of the 2-year

construction period,

followed by reduction from

current Monticello work

force of 519 to 24. Impacts

during operation would be

SMALL.

Transportation impacts

associated with construction

workers would be

MODERATE.

SMALL aesthetic impacts

due to impacts of plant units

and stacks for gas plant

(similar to current Monticello

plant). Additional impact

from wind turbines.

Impacts can generally be

managed or mitigated.

Wind turbines often placed

along ridgelines that may

have higher likelihood of

historic or archaeological

significance.

SMALL to

MODERATE

Construction impacts depend on

location, but could be significant

if location is in a more rural area

than Monticello. Wright County

would experience loss of tax

base and employment with

potentially SMALL to

MODERATE impacts.

SMALL

SMALL

Same as Monticello site.

Same as Monticello site.

MODERATE Same as Monticello site.

MODERATE

to LARGE

SMALL to

MODERATE

MODERATE to LARGE impact

from wind turbine towers as well

as the gas-fired plant, stacks,

and cooling towers and

associated plumes. Additional

Impact that could be LARGE if a

lengthy new electrical power

transmission line is needed.

Historic and Same as Monticello site.

Archaeological

Resources

SMALL to

MODERATE

August 2006 8-53 NUREG-1437, Supplement 26 I
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Table 8-7. (contd)

Impact Monticello Site Alternate Greenfield Site

Category Impact Comment Impact Comment

Environ- SMALL Impacts on minority and SMALL Impacts vary depending on

mental low-income communities population distribution and

Justice should be similar to those makeup at site. Wright County

experienced by the would lose tax revenue and jobs;

population as a whole. however, the impacts on

Some impacts on housing minority and low-income

may occur during populations would be SMALL.

construction; loss of 519

operating jobs at Monticello

likely SMALL due to the

proximity of the plant to a

diverse urban job market.

8.3 Summary of Alternatives Considered

The environmental impacts of the proposed action, renewal of the Monticello OL, are SMALL

for all impact categories, except for collective offsite radiological impacts from the fuel cycle and

from high-level waste and spent fuel disposal. Collective offsite radiological impacts from the

fuel cycle and from high-level waste and spent fuel disposal were not assigned a single

significance level but were determined by the Commission to be Category 1 issues

nonetheless. The alternative actions, i.e., no-action alternative (discussed in Section 8.1), new

generation alternatives (from coal, natural gas, coal gasification, and nuclear power, discussed

in Sections 8.2.1 through 8.2.4, respectively), purchased electrical power (discussed in

Section 8.2.5), alternative technologies (discussed in Section 8.2.6), and a combination of

alternatives (discussed in Section 8.2.7) were considered.

The no-action alternative would require the replacement of electrical generating capacity by

(1) demand-side management and energy conservation, (2) power purchased from other.

electricity providers, (3) generating alternatives other than Monticello, or (4) some combination

of these options. For each of the new generation alternatives (coal, natural gas, coal

gasification, and nuclear power), the environmental impacts would not be less than the impacts

of license renewal. For example, the land-disturbance impacts resulting from construction of

any new facility would be greater than the impacts of continued operation of Monticello. The

impacts of purchased electrical power (imported power) would still occur, but would occur

elsewhere. Alternative technologies are not considered feasible at this time and it is very

unlikely that the environmental impacts of any reasonable combination of generation and

conservation options could be reduced to the level of impacts associated with renewal of the

Monticello OL.

The staff concludes that the alternative actions, including the no-action alternative, may have

environmental effects in at least some impact categories that reach MODERATE or LARGE

significance.

NUREG-1437, Supplement 26 8-54 August 2006 1
Environmental Impacts of Alternatives

8.4 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing

of Production and Utilization Facilities."

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

Protection Regulations for Domestic Licensing and Related Functions.

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Early Site Permits;

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants."

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

"Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60,

"Standards of Performance for New Stationary Sources."

Bily, B. 2005. Energy Plan Sparks Interest: Mesaba coal-gasification project lights up Itasca

business community. Mesabi Daily News. July 21, 2005. Accessed at:

http://www.virginiamn.com/mdn/index.php?sect_rank=l &story-id=204418 on August 19, 2005.

C&A Carbone, Inc. v. Town of Clarkstown, New York, 511 U.S. 383 (U.S. Supreme Court

1994).

Clean Air Act. 42 USC 7401, et seq.

Integrated Waste Services Association (IWSA). 2004. About Waste to Energy. Accessed at:

http://www.wte.org/waste.html on September 16, 2005.

Minnesota Department of Commerce (MDC). 2004. Draft Energy Policy and Conservation

Report. Accessed at:

http://www.state.mn.us/mn/externalDocs/Commerce/2004_QuadrennialReport071404101313

_DraftQuadRptl 1-04.pdf on July 13, 2005.

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

Northern States Power Company (NSP). 2004. NSP Resource Plan-Appendix D. July 2004.

Nuclear Management Company (NMC). 2005. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

August 2006 8-55 NUREG-1437, Supplement 26 1
Environmental Impacts of Alternatives

Tennessee Valley Authority (TVA). 2003. Applicant's Environmental Report-Operating

License Renewal Stage, Browns Ferry Nuclear Power--lant Units 1, 2, and 3. Tennessee

Valley Authority, Knoxville, Tennessee.

U.S. Census Bureau (USCB). 2004. 100 Fastest Growing Counties. Accessed at:

http://www.census.gov/popest/counties/CO-EST2004-09.html on June 8, 2005.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2000. The

Changing Structure of the Electric Power Industry 2000: An Update. DOE/EIA-0562(00).

Accessed at: http:llwww.eia.doe.gov/cneaf/electricity/chgstr.update/update2000.html on

July 13, 2005.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2001. Renewable

Energy 2000: Issues and Trends. DOE/EIA-0628 (2000). Washington, D.C. Accessed at:

http://tonto.eia.doe.gov/ftproot/renewables/06282000.pdf on July 18, 2005.

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2004. Table 80:

Renewable Energy Generation by Fuel Mid-Continent Area Power Pool. Accessed at:

http://www.eia.doe.gov/oiaf/aeo/supplement/index.html on July 13, 2005

U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2005. Annual

Energy Outlook 2005. Accessed at: http://www.eia.doe.gov/oiaf/aeo/electricity.html on

July 14, 2005.

U.S. Department of Energy (DOE). 2001. U.S. Wind Energy Resource Map. Accessed at:

http://www.eren.doe.gov/wind/we-map.html on February 27, 2001.

U.S. Department of Energy (DOE). 2004. Future Fuel Cells R&D. Accessed at:

http://www.fossil.energy.gov/programs/powersystems/fuelcells on September 16, 2005.

U.S. Environmental Protection Agency (EPA). 1998. "Revision of Standards of Performance

for Nitrogen Oxide Emissions From New Fossil-Fuel Fired Steam Generating Units; Revisions

to Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam

Generating Units, Final Rule." Federal Register, Vol. 63, No. 179, pp. 49442-49455.

Washington, D.C. September 16, 1998.

U.S. Environmental Protection Agency (EPA). 1999. "Regional Haze Regulations, Final Rule."

Federal Register, Vol. 64, No. 126, pp. 35714. Washington, D.C. July, 1, 1999.

U.S. Environmental Protection Agency (EPA). 2000a. "Notice of Regulatory Determination on

Wastes From the Combustion of Fossil Fuels." Federal Register, Vol. 65, No. 99,

pp. 32214-32237. Washington, D.C. May 22, 2000.

NUREG-1 437, Supplement 26 8-56 August 2006 1
Environmental Impacts of Alternatives

U.S. Environmental Protection Agency (EPA). 2000b. "Regulatory Finding on the Emissions of

Hazardous Air Pollutants From Electric Utility Steam Generating Units." Federal Register,

Vol. 65, No. 245, pp. 79825-79831. Washington, D.C. December 20, 2000.

U.S. Environmental Protection Agency (EPA). 2001. Municipal Solid Waste Disposal.

Accessed at: http:llww.epa.gov/epaoswer/non-hw/muncplldisposal.htm on

September 16, 2005.

U.S. Environmental Protection Agency (EPA). 2005a. CAIR Reduces Minnesota's Emissions.

Accessed at: http://www.epa.gov/cair/state/mn.html on July 13, 2005.

U.S. Environmental Protection Agency (EPA). 2005b. "Rule to Reduce Interstate Transport of

Fine Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program;

Revisions to the NOX %g SIP Call; Final Rule." Federal Register, Vol. 70, No. 91, pp. 25162-

25405. Washington, D.C. May 12, 2005.

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

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

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

for License Renewal of Nuclear Plants: Main Report, Section 6.3 - Transportation, Table 9.1

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2001. NRC Organizes Future Licensing Project

Organization. Press Release No. 01-035, March 30, 2001. Accessed at:

http://www.nrc.gov/reading-rm/doc-collections/news/1 001/01 -035.html on August 3, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2002. Final Generic Impact Statement on

Decommissioning of Nuclear Facilities, Supplement 1. NUREG-0586, Washington, D.C.

August 2006 8-57 NUREG-1437, Supplement 26 1

9.0 Summary and Conclusions

By letter dated March 16, 2005, Nuclear Management Company, LLC (NMC), submitted an

application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating license

(OL) for Monticello Nuclear Generating Plant (Monticello) for an additional 20-year period (NMC

2005a). If the OL is renewed, State regulatory agencies and NMC will ultimately decide

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

matters within the State's jurisdiction or the purview of the owners. If the OL is not renewed,

then the plant must be shut down at or before the expiration of the current OL, which expires on

September 8, 2010.

Section 102 of the National Environmental Policy Act (NEPA) (42 USC 4332) requires an

environmental impact statement (EIS) for major Federal actions that significantly affect the

quality of the human environment. The NRC has implemented Section 102 of

NEPA in Title 10 of the Code of Federal Regulations (CFR) Part 51. Part 51 identifies licensing

and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the Commission requires

preparation of an EIS or a supplement to an EIS for renewal of a reactor OL; 10 CFR 51.95(c)

states that the EIS prepared at the OL renewal stage will be a supplement to the Generic

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

Volumes 1 and 2 (NRC 1996; 1999).(a)

Upon acceptance of the NMC application, the NRC began the environmental review process

described in 10 CFR Part 51 by publishing a notice of intent in the Federal Register to prepare

an EIS and conduct scoping (NRC 2005a) on June 2, 2005. The staff visited the Monticello site

in June 2005 and held public scoping meetings on June 30, 2005, in Monticello, Minnesota

(NRC 2005b). The staff reviewed the NMC Environmental Report (ER) (NMC 2005b) and

compared it to the GELS, consulted with other agencies, and conducted an independent review

of the issues following the guidance set forth in NUREG-1 555, the Standard Review Plans for

Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal

(NRC 2000). The staff also considered the public comments received during the scoping

process for preparation of the draft Supplemental Environmental Impact Statement (SEIS) for

Monticello. The public comments received during the scoping process that were considered to

be within the scope of the environmental review are provided in Appendix A, Part 1, of this

SEIS.

The staff held two public meetings in Monticello, Minnesota on March 22, 2006, to describe the

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

of the public with information to assist them in formulating their comments on this SEIS. All the

comments received on the draft SEIS were considered by the staff in developing this final SEIS.

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

(8) The GElS was originally issued in 1996. Addendum I to the GElS was issued in 1999. Hereafter, all references

to the "GEIS" include the GElS and its Addendum 1.

August 2006 9-1 NUREG-1437, Supplement26 I
Summary and Conclusions

This SEIS includes the NRC staff's analysis that considered and weighed the environmental

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

I and mitigation measures available for reducing or avoiding adverse impacts. This SEIS also

I includes the staff's recommendation regarding the proposed action.

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

the GELS:

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

provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs,

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

(other than NRC) decisionmakers.

The evaluation criterion of the staff's environmental review, as defined in 10 CFR 51.95(c)(4)

and the GElS, is to determine:

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

that preserving the option of license renewal for energy planning decisionmakers would

be unreasonable.

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

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

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

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

SEISs prepared at the license renewal stage:

The supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of

the proposed action or of alternatives to the proposed action except insofar as such

benefits and costs are either essential for a determination regarding the inclusion of an

alternative in the range of alternatives considered or relevant to mitigation. In addition,

the supplemental environmental impact statement prepared at the license renewal stage

need not discuss other issues not related to the environmental effects of the proposed

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

within the scope of the generic determination in § 51.23(a) and in accordance with

§51.23(b).(a)

(a) The title of 10 CFR 51.23 is "Temporary Storage of Spent Fuel After Cessation of Reactor Operations-Generic

Determination of No Significant Environmental Impact."

NUREG-1 437, Supplement 26 9-2 August 2006 1
Summary and Conclusions

The GElS contains the results of a systematic evaluation of the consequences of renewing

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

92 environmental issues using the NRC's three-level standard of significance-SMALL,

MODERATE, or LARGE-developed using the Council on Environmental Quality guidelines.

The following definitions of the three significance levels are set forth in the footnotes to

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B:

SMALL-Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE-Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE-Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

For 69 of the 92 issues considered in the GELS, the staff analysis in the GElS shows the

following:

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

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

system or other specified plant or site characteristics.

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

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

and from high-level waste [HLW] and spent fuel disposal).

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

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

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

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

significant information, the staff relied on conclusions as amplified by supporting information in

the GElS for issues designated Category 1 in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B.

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

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

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

Environmental justice was not evaluated on a generic basis and, therefore, must be addressed

in a plant-specific supplement to the GElS. Information on the chronic effects of

electromagnetic fields was not conclusive at the time the GElS was prepared.

August 2006 9-3 NUREG-1 437, Supplement 26 I
Summary and Conclusions

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

GELS. The staff considered the environmental impacts'associated with alternatives to license

renewal and compared the environmental impacts of license renewal and the alternatives. The

alternatives to license renewal that were considered include the no-action alternative (not

renewing the OL for Monticello) and alternative methods of power generation. These

.alternatives were evaluated assuming that the replacement power generation plant is located at

either the Monticello site (nuclear generation) or some other unspecified greenfield location.

9.1 Environmental Impacts of the Proposed Action -

License Renewal

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

the significance of any new information on the environmental impacts of license renewal.

Neither NMC nor the staff has identified information that is both new and significant related

to Category 1 issues that would call into question the conclusions in the GELS. Similarly,

neither the scoping process, NMC, nor the staff has identified any new issue applicable to

Monticello that has a significant environmental impact. Therefore, the staff relies upon the

conclusions of the GElS for all Category 1 issues that are applicable to Monticello.

NMC's license renewal application presents an analysis of the Category 2 issues that are

applicable to Monticello, as well as environmental justice and chronic effects from

electromagnetic fields. The staff has reviewed the NMC analysis for each issue and has

conducted an independent review of each issue. Three Category 2 issues are not

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

I at Monticello. Four Category 2 issues are not discussed in this SEIS because they are

specifically related to refurbishment. NMC has stated that its evaluation of structures and

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

activities or modifications as necessary to support the continued operation of Monticello for

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

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

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

operations evaluated in the Final Environmental Statement Related to Operation of

Monticello Nuclear Generating Plant (AEC 1972).

Fourteen Category 2 issues related to operational impacts and postulated accidents during

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

fields, are discussed in detail in this draft SEIS. Five of the Category 2 issues and

environmental justice apply to both refurbishment and to operation during the renewal term

and are only discussed in this draft SEIS in relation to operation during the renewal term.

For all 14 Category 2 issues and environmental justice, the staff concludes that the potential

environmental effects are of SMALL significance in the context of the standards set forth in

the GELS. In addition, the staff determined that appropriate Federal health agencies have

NUREG-1 437, Supplement 26 9-4 August 2006 1
Summary and Conclusions

not reached a consensus on the existence of chronic adverse effects from electromagnetic

fields. Therefore, no further evaluation of this issue is required.

For severe accident mitigation alternatives (SAMAs), the staff concludes that a reasonable,

comprehensive effort was made to identify and evaluate SAMAs. Based on its review of the

SAMAs for Monticello, and the plant improvements already made, the staff concludes that

one of the candidate SAMAs is potentially cost-beneficial. However, this SAMA does not

relate to adequately managing the effects of aging during the period of extended operation.

Therefore, it does not need to be implemented as part of license renewal pursuant to

10 CFR Part 54.

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

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

additional mitigation measures were deemed sufficiently beneficial to be warranted.

The following sections discuss unavoidable adverse impacts, irreversible or irretrievable

commitments of resources, and the relationship between local short-term use of the

environment and long-term productivity.

9.1.1 Unavoidable Adverse Impacts

An environmental review conducted at the license renewal Stage differs from the review

conducted in support of a construction permit because the plant is in existence at the license

renewal stage and has operated for a number of years. As a result, adverse impacts

associated with the initial construction have been avoided, have been mitigated, or have

already occurred. The environmental impacts to be evaluated for license renewal are those

associated with refurbishment and continued operation during the renewal term.

The adverse impacts of continued operation identified are considered to be of SMALL

significance, and none warrants implementation of additional mitigation measures. The

adverse impacts of likely alternatives if Monticello ceases operation at or before the expiration

of the current OL will not be smaller than those associated with continued operation of this unit,

and they may be greater for some impact categories in some locations.

9.1.2 Irreversible or Irretrievable Resource Commitments

The commitment of resources related to construction and operation of Monticello during the

current license period was made when the plant was built. The resource commitments to be;

considered in this SEIS are associated with continued operation of the plant for an additional,20

years. These resources include materials and equipment required for plant maintenance and

operation, the nuclear fuel used by the reactors, and ultimately, permanent offsite storage

space for the spent fuel assemblies.

August 2006 9-5 NUREG-1437, Supplement 26 I
Summary and Conclusions

The most significant resource commitments related to operation during the renewal term are

the fuel and the permanent storage space. Monticello replaces approximately thirty percent of

the fuel assemblies in the unit during every refueling outage, which occurs on a nominal

24-month cycle.

The likely power generation alternatives if Monticello ceases operation on or before the

expiration of the current OL will require a commitment of resources for construction of the

replacement plants as well as for fuel to run the plants.

9.1.3 Short-Term Use Versus Long-Term Productivity

An initial balance between short-term use and long-term productivity of the environment at the

Monticello site was set when the plant was approved and construction began. That balance is

now well established. Renewal of the OL for Monticello and continued operation of the plant will

not alter the existing balance, but may postpone the availability of the site for other uses.

Denial of the application to renew the OL will lead to shutdown of the plant and will alter the

balance in a manner that depends on subsequent uses of the site. For example, the

environmental consequences of turning the Monticello site into a park or an industrial facility are

quite different.

9.2 Relative Significance of the Environmental Impacts of

License Renewal and Alternatives

The proposed action is renewal of the OL for Monticello. Chapter 2 describes the site, power

plant, and interactions of the plant with the environment. As noted in Chapter 3, no

refurbishment and no refurbishment impacts are expected at Monticello. Chapters 4 through 7

discuss environmental issues associated with renewal of the OL. Environmental issues

associated with the no-action alternative and alternatives involving power generation and use

reduction are discussed in Chapter 8.

The significance of the environmental impacts from the proposed action (approval of the

application for renewal of the OL), the no-action alternative (denial of the application),

alternatives involving nuclear, coal, coal gasification, or natural gas-generation of power, and a

combination of alternatives are compared in Table 9-1. Continued use of an open-cycle cooling

system for Monticello is assumed for Table 9-1.

Table 9-1 shows that the significance of the environmental effects of the proposed action are

SMALL for all impact categories (except for collective offsite radiological impacts from the fuel

cycle and from HLW and spent fuel disposal, for which a single significance level was not

assigned [see Chapter 6]). The alternative actions, including the no-action alternative, may

have environmental effects in at least some impact categories that reach MODERATE or

LARGE significance.

NUREG-1437, Supplement 26 9-6 August 2006 1
z

a

:mG)

CA,

C)

Table 9-1. Summary of Environmental Significance of License Renewal, the No-Action Alternative, and Cn

Alternative Methods of Generation Using Once-Through Cooling 3

Natural

Coal-Fired Gas-Fired Coal

Proposed Action No-Action Alternative Generation Generation Gasification New Nuclear Generation Combination of Alternatives C.

Alternate Alternate Alternate Alternate

License Denial of Greenfield Greenfield Greenfield Monticello Greenfield Monticello Alternate

Impact Category Renewal Renewal Site Site Site Site Site Site Greenfield Site

C) 0

0

=3

Ecology SMALL SMALL SMALL to SMALL to SMALL to MODERATE MODERATE SMALL to SMALL to

MODERATE MODERATE LARGE to LARGE MODERATE MODERATE

a n ct 77 111 MQ D E RA.B

Water Use SMALL SMALL SMALL to SMALL to SMALL to SMALL SMALL to SMALL SMALL to

and Quality- MODERATE MODERATE MODERATE MODERATE MODERATE

Groundwater _ - . .__ .- ~ -

AO9 E M0 1JRAT.MODERAIM SMALL M I V -- 4 SA$ MAW, 

Waste SMALL SMALL MODERATE SMALL MODERATE SMALL SMALL SMALL SMALL

Fll", W"..-•S--.. S- SMA"r•SMAL. .~MLL , -

Socioeconomics SMALL SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to

LARGE LARGE MODERATE LARGE MODERATE LARGE MODERATE MODERATE

• .•.s.•,,S,,A. • •--,MA-.-OI. .. . .. , MAL•t_ M.U1 M•:O. R•;, 

Aesthetics SMALL SMALL SMALL to SMALL to. SMALL to SMALL SMALL to SMALL MODERATE to

MODERATE MODERATE LARGE LARGE LARGE

Environmental SMALL SMALL to SMALL to SMALL to SMALL to SMALL SMALL to SMALL SMALL

Justice LARGE MODERATE MODERATE MODERATE MODERATE
Summary and Conclusions

9.3 Staff Conclusions and Recommendations

Based on (1) the analysis and findings in the GEIS (NRC 1996,1999), (2) the ER submitted by

NMC (NMC 2005b), (3) consultation with Federal, State, and local agencies, (4) the staff's own

independent review, and (5) the staff's consideration of public comments, the recommendation

of the staff is that the Commission determine that the adverse environmental impacts of license

renewal for Monticello are not so great that preserving the option of license renewal for energy

planning decisionmakers would be unreasonable.

9.4 References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

Renewal of Operating Licenses for Nuclear Power Plants."

Nuclear Management Company (NMC). 2005a. Application for Renewed Operating License,

Monticello Nuclear Generating Plant. Monticello, Minnesota.

Nuclear Management Company (NMC). 2005b. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

National Environmental Policy Act of 1969, Section 102 (NEPA). 42 USC 4332.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Monticello Nuclear Generating Plant. Northern States Power Company. Docket

No. 50-263, Washington, D.C.

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

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

for License Renewal of Nuclear Plants: Main Report, Section 6.3, - Transportation, Table 9.1,

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

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

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

Environmental Reviews for Nuclear Power Plants, Supplement 1: "Operating License

Renewal." NUREG-1555, Supplement 1, Washington, D.C.

NUREG-1437, Supplement 26 9-8 August 2006 1
Summary and Conclusions

U.S. Nuclear Regulatory Commission (NRC). 2005a. "Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process." Federal Register, Vol. 70,

No. 105, pp. 32381-32382. Washington, D.C. June 2, 2005.

U.S. Nuclear Regulatory Commission (NRC). 2005b. Environmental Impact Statement

Scoping Process: Summary Report, Monticello Nuclear Generating Plant, Monticello,

Minnesota. Washington, D.C. October 7, 2005.

August 2006 9-9 NUREG-1437, Supplement 26 1

Appendix A

Comments Received on the Environmental Review

Appendix A: Comments Received on the

Environmental Review

Part I-Comments Received During Scoping

On June 2, 2005, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of Intent

in the Federal'Register (70 FR 32381), to notify the public of the staff's intent to prepare a

plant-specific supplement to the Generic Environmental Impact Statement for License Renewal

of Nuclear Plants (GELS), NUREG-1 437, Volumes 1 and 2, to support the renewal application

for the Monticello Nuclear Generating Plant operating license and to conduct scoping. The

plant-specific supplement to the GElS has been prepared in accordance with the National

Environmental Policy Act (NEPA), Council on Environmental Quality (CEO) guidance, and

10 CFR Part 51. As outlined by NEPA, the NRC initiated the scoping process with the issuance

of the Federal Register Notice. The NRC invited the applicant; Federal, State, and local

government agencies; Native American tribal organizations; local organizations; and individuals

to participate in the scoping process by providing oral comments at the scheduled public

meetings and/or submitting written suggestions and comments no later than August 2, 2005.

The scoping process included two public scoping meetings, which were held at the Monticello

Community Center in Monticello, Minnesota on June 30, 2005. Approximately 50 members of

the public attended the meetings. Both sessions began with NRC staff members providing a

brief overview of the license renewal process and the NEPA process. After the NRC's prepared

statements, the meetings were open for public comments. Ten attendees provided oral

statements that were recorded and transcribed by a certified court reporter. The meeting

transcripts are an attachment to the July 28, 2005, Scoping Meeting Summary. In addition to

the comments received during the public meetings, thirteen comment letters and seven e-mail

messages were received by the NRC in response to the Notice of Intent.

At the conclusion of the scoping period, the NRC staff and its contractors reviewed the transcripts and all written material to identify specific comments and issues. Each set of comments

from a given commenter was given a unique identifier (Commenter ID), so that each set of

comments from a commenter could be traced back to the transcript or letter by which the

comments were submitted. Specific comments were numbered sequentially within each

comment set. Several commenters submitted comments through multiple sources (e.g.,

afternoon and evening scoping meetings). All of the comments received and the staff

responses are included in the Monticello Scoping Summary Report dated October 7, 2005.

Table A-1 identifies the individuals who provided comments applicable to the environmental

review and the Commenter ID associated with each person's set of comments. The individuals

are listed in the order in which they spoke at the public meeting. To maintain consistency with

the Scoping Summary Report, the unique identifier used in that report for each set of comments

is retained in this appendix.

August 2006 A-1 NUREG-1437, Supplement 26 I
Appendix A

Specific comments were categorized and consolidated by topic. Comments with similar specific

objectives were combined to capture the common essential issues raised by the commenters.

The comments fall into one of the following general groups:

" Specific comments that address environmental issues within the purview of the NRC

environmental regulations related to license renewal. These comments address Category 1

or Category 2 issues or issues that were not addressed in the GELS. They also address

alternatives and related Federal actions.

* General comments (1) in support of or opposed to nuclear power or license renewal or (2)

on the renewal process, the NRC's regulations, and the regulatory process. These

comments may or may not be specifically related to the Monticello license renewal

application.

• Questions that do not provide new information.

* Specific comments that address issues that do not fall within or are specifically excluded

from the purview of NRC environmental regulations related to license renewal. These

comments typically address issues such as the need for power, emergency preparedness,

security, current operational safety issues, and safety issues related to operation during the

renewal period.

Table A-i. Individuals Providing Comments During Scoping Comment Period

Comment Source and

Commenter ADAMS Accession

ID Commenter Affiliation (if stated) Number(-)

MS-A John Grubb Nuclear Management Company Afternoon Scoping Meeting

MS-B Charles Bomberger Xcel Energy Afternoon Scoping Meeting

MS-C Wayne Mayer Magic Moments Photographic Afternoon Scoping Studio Meeting

MS-D George Crocker North American Water Office Afternoon Scoping

Meeting

MS-E Lea Foushee North American Water Office Afternoon Scoping

Meeting

MS-F Kristen R-CURE Afternoon Scoping

Eide-Tollefson Meeting

MS-G Carol Overland Overland Law Office Afternoon Scoping

Meeting

MS-H Clint Herbst City of Monticello Evening Scoping Meeting

NUREG-1 437, Supplement 26 A-2 A

August 2006 1
Appendix A

Commenter

ID

MS-I

MS-J

MS-K

MS-L

MS-M

MS-N

MS-O

MS-P

MS-Q

MS-R

MS-S

MS-T

MS-U

MS-V

MS-W

MS-X

MS-Y

MS-Z

MS-AA

MS-AB

MS-AC

MS-AD

Commenter

Tom Palmisano

Kent Larsen

Joseph Steffel

Lynne DahI-Fleming

Alan Loch

Mike Benedetto

Barbara Schwientek

Dan Olson

Mark Ourada

Susan Struckness

Julie Risser

Pat Sawatzke

Susu Jeffrey

Carol Overland

George Crocker

Justin Eibenholzl

Christine Ziebold

Bruce Anderson

Don Orrock

Ewald Petersen

Bruce Thielen

Tom Fenski

Affiliation (it stated)

Nuclear Management Company

Xcel Energy

City of Buffalo

DESIGN for PRINT [&Web!]

Loch Jewelers

Monticello Public Schools

Monticello-Big Lake Community

Hospital District

State Farm Insurance

State of Minnesota Senate

District 19

Monticello Chamber of

Commerce

Citizen of Edina, Minnesota

Commissioner-District 2

Citizen of Minneapolis.

Overland Law Office

North American Water Office

Southeast Minneapolis

Neighborhoods

Citizen of Minneapolis

Minnesota House of

Representatives

Big Lake City Council

Big Lake Township Board of

Supervisors

Monticello City Council

Monticello Chamber of

Commerce

Comment Source and

ADAMS Accession

Number(')

Evening Scoping Meeting

Evening Scoping Meeting

Letter (ML051960028)

Letter (ML051810330)

Letter (ML051810327)

Letter (ML051810325)

Letter (ML051810324)

Letter (ML051810543)

Letter (ML052090152)

Letter (ML051810333)

Email (ML052220380)

Email (ML052220387)

Email (ML052220381)

Email (ML052220353)

Email (ML052220384)

Email (ML052220382)

Email (ML052220355)

Letter (ML052220378)

Letter (ML052220378)

Letter (ML052220378)

Letter (ML052220378)

Letter (ML052220378)

(a) The afternoon and evening transcripts can be found as an attachment under accession number

ML052030005.

August 2006 A-3 NUREG-1437, Supplement 26 1
Appendix A

The subject areas the comments were grouped into are as follows:

1. Comments in Support of License Renewal at Monticello Nuclear Generating Plant

2. Comments in Opposition to License Renewal at Monticello Nuclear Generating Plant

3. General Comments Regarding License Renewal and Its Processes

4. Comments Concerning Water Quality and Use Issues

5. Comments Concerning Aquatic Ecology Issues

6. Comments Concerning Terrestrial Resource Issues

7. Comments Concerning Air Quality Issues

8. Comments Concerning Land Use Issues

9. Comments Concerning Human Health Issues

10. Comments Concerning Socioeconomic Issues

11. Comments Concerning Postulated Accidents

12. Comments Concerning Uranium Fuel Cycle and Waste Management Issues

13. Comments Concerning Alternatives14. Comments Concerning Aging Management

Each comment is summarized in the following pages. For reference, the unique identifier for

each comment (Commenter ID letter listed in Table A-1 plus the comment number) is provided.

In those cases where no new information was provided by the commenter, no further evaluation

will be performed.

The preparation of the plant-specific supplement to the GElS (which is the SEIS) will take into

account all the relevant issues raised during the scoping process. The SEIS will address both

Category 1 and 2 issues, along with any new information identified as a result of scoping. The

SEIS will rely on conclusions supported by information in the GElS for Category 1 issues, and

will include the analysis of Category 2 issues and any new and significant information. The

draft plant-specific supplement to the GElS will be made available for public comment. The

comment period will offer the next opportunity for the applicant; interested Federal, State, and

local government agencies; local organizations; and members of the public to provide input to

the NRC's environmental review process. The comments received on the draft SEIS will be

considered in the preparation of the final SEIS. The final SEIS, along with the staff's Safety

Evaluation Report (SER), will provide much of the basis for the NRC's decision on the

Monticello license renewal application.

NUREG-1 437, Supplement 26 A-4 August 2006
Appendix A

A.1 Comments and Responses

1. Comments in Support of License Renewal at Monticello Nuclear Generating

Plant

Comment: I'm here today to provide my support for this request for license renewal from the

Monticello station. The mission of everybody who works and supports Monticello is clear; and

that's safe, reliable, economic operation of the plant. The safety of the public and the

employees being the No. 1 priority. Two of our key values include being a good neighbor, a

steward of the environment in which we operate. (MS-A-i)

Comment: In conclusion, the Monticello plant has been a productive contributor to the energy

needs of the State of Minnesota and a valuable asset and good neighbor to the surrounding

communities. We remain committed to operating safely, reliably, economically, and focus on

being a good neighbor and a good steward of the environment. I and the rest of the employees

at Monticello look forward to serving you and meeting the needs of the community for many

years to come. (MS-A-8; MS-l-8)

Comment: And I would like to share why license renewal is the most economic and

responsible energy choice for our million and a half customers here in the Upper Midwest.

(MS-B-1; MS-J-1)

Comment: In closing, we believe that continued operation of Monticello is vitally important to

the state's energy needs, important to the local economy, and important to more than 500

employees who keep it running every day. We look forward to operating Monticello safely for

many years to come. (MS-B-9; MS-J-9)

Comment: The City looks forward to working with Xcel Energy into the future, especially as

our city continues its growth and expands its boundaries towards the west. In closing, I would

like to commend all personnel working at the Monticello nuclear generating facility for their

excellent safety management. (MS-C-3)

Comment: I guess I was asked to come and speak just a little bit about what I feel Xcel has

been for the community. And I kind of consider myself an expert, not as far as the day-to-day

operations, but being that we moved here in 1972 and I've continued to raise my family here.

Also, I feel that it's a very safe operation, a much needed operation, being that now I'm on the

government side of it, to see what kind of impact Xcel does have on the community and what

kind of impact they could potentially have on the community if there was any problem with

relays and things.

August 2006 A-5 NUREG-1 437, Supplement 26 I
Appendix A

I feel very confident that I can speak for previous councils because this is an issue that came

up quite some time ago, and Xcel kind of delayed it for some reason. They're looking at

different things. But, past councils and the present council, I think are well behind Xcel, hoping

that everything goes well, hoping that they stay a part of, a huge part of the community like they

have been. (MS-H-i)

Comment: I'm here tonight to provide my support and comments on our request to renew the

operating license for the Monticello plant. The mission of everyone who works at Monticello is

very clear and very simple: safe, reliable, and economic operation of the plant. And, quite

frankly, the safety of the public and the safety of our employees is the No. 1 priority and has

been and continues to be as we operate. And as part of that, two of our key values includes

being a good neighbor and a good steward of the environment in which we operate, and

certainly that's very pertinent to tonight. (MS-I-1)

Comment: I would like to recommend to the U.S. Nuclear Regulatory Commission that Xcel

Energy be granted an operating license renewal for the Monticello Nuclear Generating Plant.

(MS-K-i)

Comment: I am writing to express my support for the relicensing of the Monticello Xcel (sic)

Energy Nuclear Power Plant. I have been a resident of Monticello for over forty years. During

that time, I have had ample opportunity to see the impact of the plant in our community. This

impact has been nothing but positive throughout that time. (MS-L-l)

Comment: I am writing to give my support for the renewal of the license of the Xcel Energy

Monticello plant. Loch Jewelers has been in Monticello since 1977. Our personal experience

with the staff and employees of the Xcel plant has been very positive. They have always

worked well with the business community, exhibiting good ethics and sound business practices

and putting the safety of the community first. (MS-M-l)

Comment: Please accept this letter as our school district's [Monticello Public Schools] support

for the license renewal of the Monticello Nuclear Plant. (MS-N-i)

Comment: The Monticello-Big Lake Community Hospital District Board of Directors and staff

members support the license renewal for the Monticello Nuclear Generating Plant. (MS-O-l)

Comment: I have lived and worked in Monticello for the past twenty one years. I am writing

you a letter in support of the license renewal for the Monticello plant. I cannot think of any local

business who has been a better good neighbor than our local nuclear plant. (MS-P-i)

Comment: I would like to express my strong.support for the license renewal application for the

Monticello Nuclear Power Plant. (MS-Q-i)

Comment: BE IT RESOLVED, THAT the Monticello Chamber of Commerce, located in

Monticello, Minnesota, does hereby take a position of support for the re-licensing of the

NUREG-1437, Supplement 26 A-6 August 2006 1
Appendix A

Monticello Nuclear Generating Plant. The Nuclear Plant and its employees are of great

importance to the City of Monticello, and to Minnesota as a whole. (MS-R-1)

- Comment: The Monticello Chamber of Commerce also is a strong supporter of nuclear energy

as a power source for our State, thereby working to produce energy with no greenhouse gas

effects. Nuclear is a clean, reliable source of energy for our state. (MS-R-3)

Comment: As a member of the Wright County Board of Commissioners that represents the

area in which the plant exists, please let me extend my support to NMC in their efforts to

re-license the Nuclear Power Plant in Monticello, Minnesota. (MS-T-4)

Comment: I write today in support of the Monticello Nuclear Generating Plant and advocate for

a license extension for its continued operation. (MS-Z-l)

Comment: NOW THEREFORE BE IT RESOLVED by the City Council of the City of Big Lake,

Minnesota, that the City of Big Lake go on record supporting construction of an Independent

Spent Fuel Storage Installation, and License Renewal at the Monticello Nuclear Generating

Plant. (MS-AA-5)

Comment: NOW, THEREFORE, BE IT RESOLVED.that the Town of Big Lake, Sherburne

County, supports the license renewal to continue operations for up to 20 years.... (MS-AB-3)

Comment: NOW THEREFORE BE IT RESOLVED, That the City of Monticello go on record

supporting construction of an Independent Spent Fuel Storage Installation, and License

Renewal at the Monticello Nuclear Generating Plant. (MS-AC-6)

Comment: We, the Monticello Chamber of Commerce, support construction of an Independent

Spent Fuel Storage Installation, and License Renewal of our local Monticello Nuclear

Generating Plant, owned by Xcel Energy and managed by Nuclear Management Company.

(MS-AD-1)

Comment: NOW THEREFORE BE IT RESOLVED, that the Monticello Chamber of Commerce

Board of Directors, go on record supporting construction of an Independent Spent Fuel

Installation, and License Renewal at the Monticello Nuclear Generating Plant. (MS-AD-6)

Response: The comments are supportive of license renewal at Monticello Nuclear Generating

Plant and are general in nature. The comments provide no new and significant information;

therefore, the comments will not be evaluated further.

2. Comments in Opposition to License Renewal at Monticello Nuclear

Generation Plant

Comment:- And you're going to find that the political support for the commercial nuclear

industry may be broad, but it's skin deep. And when that event happens, and when you've

August 2006 A-7 NUREG-1437, Supplement 26 1
Appendix A

made the commitment to keep us committed to nuclear operations, what will happen then is

we'll have chaos in the utility industry because we can't use the reactors anymore, and that will

be piled on top of somebody's nuclear nightmare. (MS-D-1 4)

Comment: Extending the license to operate until 2030 will mean future generations will have to

spend valuable resources safeguarding and storing more spent nuclear fuel; this is hardly

beneficial to environmental resources. (MS-S-1 1)

Comment: Remaining dependent on nuclear power puts Minnesotans at risk for bearing the

environmental and economic costs of maintaining toxic waste for centuries; the economic cost

of maintaining this waste outweighs the value of the energy generated by it. (MS-S-19)

Comment: Given the location of the Monticello plant upstream from a densely populated urban

area, the fact that Minnesota's current economic and political climate is weak, the fact that

political leaders from the two major parties cannot function adequately to keep the government

running under normal circumstances, and the fact that the soils at Monticello raise the

prospects of groundwater contamination, it is clear that relicensing Monticello is inappropriate

and irresponsible at this time. The NRC should reject Xcel Energy's application for license

renewal. (MS-S-27)

Comment: We have no guarantees. We do however have a rising cancer rate, relative

disincentives for alternative, decentralized energy production, and huge inefficiencies in energy

use accounting for about half of the energy produced according to experts. It would be safer

and cheaper to become efficient. Where is the leadership for tightening-up? (MS-U-6)

Comment: Nuclear technology is dinosauric it's from the last millennium. It's too big,

inappropriate, uncontrollable. Transmitting electricity from big generating stations is wasteful,

destructive of the environment, and extremely profitable until something goes wrong. (MS-U-8)

Comment: Are you the heroes who will say no to nukes and yes to progressive, decentralized,

safe energy production? This is America. We invented modern citizen democracy. We are an

inventive society. We can supply the world with smart power tools or continue our decline and

deliver to ourselves a dirty bomb of our own making. "The peaceful atom is a bomb."

(MS-U-1 0)

Comment: NRC currently gravely underestimates the risk of Monticello's operations to human

and ecosystem health, uses outdated non-protective radiation standards, procures no tracking

of health effects, provides lax oversight over safety and security, and by delivering a flawed

alternatives-analysis seeks to ensure Xcel Energy's continued nuclear power operations.

(MS-Y-41)

Response: The comments oppose license renewal at Monticello Nuclear Generating Plant and

are general in nature. The comments provide no new and significant information; therefore, the

comments will not be evaluated further.

NUREG-1437, Supplement 26 A-8 . . August 2006 1
Appendix A

3. General Comments Regarding License Renewal and Its Processes

Comment: Because the scope of public outreach was limited to Buffalo, Minnesota and

Monticello, Minnesota the Nuclear Regulatory Commission (NRC) failed to provide residents of

other effected communities with information and opportunities to participate in the EIS Scoping

process; people were denied the chance to weigh in on whether or not the Monticello nuclear

power plant should be relicensed. Furthermore the NRC appears to have intensionally (sic)

undermined the process for allowing the public to participate at the public meetings that it did

hold in Monticello to discuss the EIS Scoping. (MS-S-i)

Comment: The residents of the Twin Cities Metro Area have a vested interest in this resource

it is a fundamental component of their survival;- and they need to be included in public

discussion about license renewal for Monticello. (MS-S-4)

Comment: The NRC failed to hold one public meeting in the Twin Cities during the EIS

Scoping period..

The NRC failed to publish information about the Open Houses that it held in Monticello, MN on

June 30th in both the Minneapolis Star Tribune and the Saint Paul Pioneer Press.

The NRC failed to get any local television stations to provide information about the Open

Houses in Monticello.

The NRC failed to get any radio stations to provide information about the Open Houses in

Monticello.

The NRC failed to provide transport from the Twin Cities to Monticello for those who do not own

cars or have the financial resources to take a taxi to Monticello. (MS-S-5)

Comment: During the EIS Scoping period the NRC failed to provide libraries in the Twin Cities

Metro Area with any documentation regarding the license renewal for Monticello; the NRC

made this documentation available only at public libraries in Buffalo and Monticello.

People who learned about the Open Houses were instructed to contact Jennifer A. Davis

301-415-3835 or Jason Flemming 301-415-5787. I called Jason Flemming long-distance and

left messages twice. Jason Flemming never returned my calls even though I clearly stated in

both messages that I wanted to participate in the Monticello Open House as a concerned

member of the public.

The NRC failed to provide people with a toll-free number so they could learn about the forum;

public comments are likely to be skewed toward views of the middle-class and wealthy the poor

were not provided a means to participate in this basic dialog.

August 2006 A-9 NUREG-1437, Supplement 26 .j
Appendix A

The NRC failed to provide people with contacts who would respond to their questions in a timely

way; the NRC undermined the ability of the public to participate.

People who were able to make it to the June 30th Open House in Monticello were given a

handout "Welcome to the NRC's Open House Associated with the Environmental Review for

License Renewal at the Monticello Nuclear Generating Plant" that clearly stated in the first

sentence of the second paragraph that the NRC was seeking comments supporting relicensing:

"The NRC is gathering information necessary to prepare an Environmental Impact Statement

(EIS) in support of the proposed renewal of the operating license for the Monticello Nuclear

Generating Plant" (I have added the italics). This sentence alone may have discouraged

members of the public who showed up intending to make a statement against the relicensing

from voicing their concerns or entering them into the record.

In the "Welcome to the NRC's Open House Associated with the Environmental Review for

License Renewal at the Monticello Nuclear Generating Plant" the first sentence of the second

paragraph makes it clear that the EIS Scoping period was not a time for the NRC to consider

the pros and cons of relicensing; for the NRC it was a time to gather information that supported

a predetermined course of action relicense the plant. (MS-S-6)

Comment: Because the NRC failed to inform large communities that will be effected by the

relicensing of Monticello about the EIS Scoping, because the NRC did not demonstrate a -

credible effort to engage members of the public in the EIS Scoping process, and because the

NRC appears to have consciously set out to undermine participation from members of thepublic who are against the relicensing of Monticello the entire EIS Scoping Process needs to

start over. To fail to do so will result in damage to Xcel Energy's reputation and damage to the

credibility of all relicensing efforts for nuclear reactors throughout the United States. At this

point in our nation's history undermining the democratic process for something as serious as

relicensing nuclear power plants could have significant and harmful negative fallout as far as

public confidence in the government's ability to put the long-term needs of the people before

corporate desires for profit and gaining market share is concerned. Failure to engage in honest

dialog regarding relicensing the plant creates the very real possibility that Monticello will be

relicensed without the public or the NRC considering very serious problems; this is public policy

at its worst. (MS-S-8)

Comment: I wish to underscore the opening comments made by Christine Ziebold, MD, PhD,

MPH, and Julie Risser, who both pointed out ways in which the NRC, and NRC process,

worked against public participation. I have an anecdote of my own: I emailed the contact

person listed, Jennifer Davis, a day or two prior to the June 30 meeting to verify place and time

because it was listed as "tentative" on the site, and did not receive a response until July 5! I live

in Red Wing, and Monticello is a ways away, and I had no way to confirm.

It was not clarified for the audience the purpose of the meeting, that it is for determining the

scope of the EIS, and what that meant, what types of Comments were specifically being

solicited. Because this is not clear, the record contains comments from people supporting

NUREG-1437, Supplement 26 A-1 0 August 2006 1
Appendix A

nuclear power (I) and Monticello, but not offering anything relevant to the comment purpose.

People attending the meeting were not able to tailor their comments to be effective. (MS-V-1)

Comment: The Nuclear Regulatory Commission's (NRC) relicensing process has dramatically

deteriorated over the past decade.

NRC needs to clearly communicate, best establish a SEARCHABLE website, indexed on major

search engines regarding Monticello. NRC's EIS scoping is a non-transparent process,

EXTREMELY poorly communicated through the media. The search engine on NRC's website

will not retrieve the website for Monticello on the first 20 hits, and neither will Google. If NRC

wants to enjoy any credibility for its "seeking public involvement" it needs to fix this problem.

(MS-Y-1)

Comment: NRC needsto honestly relate information about realistic health and environmental

concerns due to the routine release of fission products to air, water and land and the unsolved

long term storage situation, aside from issues due to catastrophic events. The NRC EIS

scoping process as is and NRC communications in general keep the public at large uninformed.

In my experience NRC meetings are tightly controlled and orchestrated. NRC's public relations

have replaced solid information or even public health education. The process is virtually

exclusive of the public at large. (MS-Y-3)

Comment: I kindly request that NRC hold another EIS scoping meeting in the TwinCities

ASAP.

The Monticello meeting on June 30, 2005 serves as a case in point. The public meeting (which

really was one, not two as stated in the NRC press release, even though there might have been

two basically back to back sessions within the same 12 hours) took place at the virtual

exclusion of Twin Cities stakeholders, due to its location at Monticello and its timing. Twin

Cities residents are stakeholders too, since a catastrophic event would affect a

disproportionately larger number of us. (MS-Y-4)

Response: As outlined in the Introduction section, the NRC published a Notice of Intent in the

Federal Register (70 FR 32381) on June 2,2005. This was the official notice to inform the

public of its opportunity to participate as the NRC undertakes the environmental review of the

request to renew the operating license of the Monticello Nuclear Generating Plant. Every

Federal agency is required to publish its notices in the Federal Register, which is issued every

work day, to ensure that the public is informed of its opportunity to participate in the work of the

Federal Government. In the Notice of Intent, the NRC invited the applicant; Federal, State, and

local government agencies; local organizations; and individuals to participate in the scoping

process and to provide comments to the NRC about the scope of the environmental review no

later than August 2, 2005. The NRC staff is supported by its contractors and any interested

member of the public in undertaking this environmental review. The outcome is not

predetermined, but an environmental review will be performed and an EIS will be prepared to

support the review whether or not the request to renew the license is granted. The NRC

August 2006 A-1 1 NUREG-1437, Supplement 26 1
Appendix A

provided the public with information on the application located in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm.html, the

Public Electronic Reading Room. Toll free telephone numbers were provided in the Notice to

assist the public with the use of ADAMS and in contacting key NRC personnel on the project.

Although not required by NEPA, the NRC has elected to take steps during the scoping process

to ensure that interested parties have additional opportunities to become informed about the

project and to gain access to process and site-specific information to enhance their participation.

at the level they so choose. In addition to the official source of information in the NRC Public

Document Room and ADAMS, the NRC believed that it would be useful to the public to provide

a copy of the environmental information associated with the application for inspection at a

public library close to the site area; for the Monticello project, two public libraries (Monticello

and Buffalo) were kind enough to support our effort. The local libraries also have information to

assist the public in using ADAMS if an individual does not have intemet access from another

source. Consequently, any individual who is interested in obtaining information from the NRC

related to any environmental review for any license renewal project can go to any public library

and use library resources to obtain access.

The NRC has established an open process to permit all members of the public to participate in

the scoping process. Comments can be provided to the NRC in person, by mail, and by e-mail.

In addition, the NRC has elected to conduct public meetings during the scoping process to

ensure that interested parties have an additional opportunity to gain access to information about

the project and the process to effectively participate. The NRC provided the information about

the public meetings in the Federal Register Notice and posted the meeting time and location at

the NRC's website (www.nrc.gov). The NRC also published a press release to inform the

media about the purpose, time and location of the meetings, but the NRC does not control the

actions of the media; consequently, the NRC also pays for advertisements in a reasonable set

of local newspapers (the St. Cloud Times and the Monticello Times) to share the information

with the public. The NRC meetings were facilitated and, in advance of the meetings, the

facilitator contacted elected and appointed officials as well as known representatives of interest

groups so that they could inform their constituencies of the opportunity to participate in the

meetings. Finally, the NRC placed posters about the meeting in public places in the Monticello

site area.

Two meetings were held on the same day to make it convenient for interested parties who had

obligations (e.g., work or family) to choose whether they would participate in one or both

meetings. Preregistering for either of the meetings assists the staff in determining the quantity

of materials that it should bring to enhance the level of understanding and participation. During

the days leading up to the meetings, the environmental review team generally conducts an

audit in the site area and may no longer have access to office resources; consequently, the

public was encouraged to contact the staff by June 23, 2005, to preregister. However, the NRC

attempts to accommodate all interested parties at the public meetings whether they were

preregistered or not. No member of the public was denied the opportunity to participate in the

NUREG-1437, Supplement 26 A-12 August 2006 1
Appendix A

scoping process. If an individual made the effort to attend the public meeting, then she or he

was given the opportunity, to share her or his views on the record to ensure that it would be

captured by the NRC and treated equally as any written comment submitted by August 2, 2005.

If an individual was unable to attend the meeting or elected to defer offering her or his

comments at that time, then she or he still had the opportunity to share views with the NRC

through the end of the comment period as outlined in the Notice. Those who provided

comments at the public meetings were not precluded in any way from providing additional

comments through the end of the comment period.

The comments raised concerns about the additional opportunities provided by the NRC to

comment during the scoping process, but do not provide new and significant information.

Therefore, the comments will not be evaluated further.

Comment: In a telephone conversation with Jennifer Davis, NRC contact for Monticello on

8/1/05 at 3pm CST I learned that NRC has a generic EIS for all nuclear plants and that "2/3 of

the issues contained therein won't be revisited." Even if true, this was not a great motivation to

submit comment. This generic EIS however is NOT posted under "Documents Available for

Comment" which is the hyperlink provided for Public Involvement on NRC's Monticello website,

which I only found today. (MS-Y-2)

Response: The impact evaluation performed by the staff and presented in the Generic

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

identified 92 environmental issues that were considered within the scope of a license renewal

review. *For each of the 92 issues, the staff evaluated existing data from the nuclear power

plants throughout the U.S. From this evaluation, the staff determined which issues were

amenable to generic consideration and which issues can only be resolved on a site-specific

basis. Sixty-nine of the issues were found to be generic to all sites, whereas, 23 of the issues

would require a site-specific analysis. Generic issues are termed Category 1 because the

conclusions related to their environmental impacts were found to be common to all plants or all

plants with certain design features (e.g., cooling towers), mitigation of adverse impacts was

considered, and it has been determined that additional mitigation measures are likely not to be

beneficial to warrant implementation. Absent "new and significant information" that the NRC

may obtain during its independent site-specific review, which includes public comments in the

scoping process, Category 1 issues are not reevaluated in the site-specific EIS. Nevertheless,

the conclusions from the applicable 69 Category 1 issues are adopted (using a NEPA concept

known as tiering) in the site-specific EIS.

Category 2 issues are those that require a site-specific review, prepared in the staff's site

specific supplement to the GELS. The NRC staff evaluates site-specific data provided by the

applicant, other Federal Agencies, State agencies, tribal and local governments, as well as

information from members of the public.

August 2006 A-13 NUREG-1437, Supplement 26 1
Appendix A

The GElS is available on the NRC's website at

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/. The comment provides no

new and significant information; therefore, the comment will not be evaluated further.

Comment: The NRC must evaluate the environmental impact of ownership and operation

scheme, in this case, where Xcel is the owner of the plant with full liability for operations as

conducted by NMC.

The application was made in the name of Nuclear Management Company, LLC. Xcel Energy,

the owner of Monticello, should also be an applicant. (MS-V-6)

Response: Nuclear Management Company (NMC) is the holder of the operating license, and

has applied for license renewal of the operating license of Monticello Nuclear Generating Plant.

NMC submitted the application, dated March 16, 2005, individually and as agent for the owner

of the plant, Northern States Power Company, a wholly owned subsidiary of Xcel Energy

Corporation.

4. Comments Concerning Water Quality and Use Issues.

Comment: There is (sic) some thermal issues. They may be generic, but they may be pretty

specific to Monticello, being as Monticello is really on the upper waters of the Mississippi River.

You cannot-count on the cooling that this river has historically provided over the forecast period

for a re-licensing period. (MS-D-10)'

Comment: The NRC analysis on water quality and surface runoff fails to adequately address

issues concerning erosion, changing weather patterns we are experiencing in Minnesota, and

the risks to ground water contamination. (MS-S-23)

Comment: The EIS needs to define the impact on water. The EIS needs to assess in detail

how reactor operations impacts water contamination. (MS-Y-33)

Response: Temperature effects and other water quality issues were evaluated in the GElS

and determined to be Category 1 issues. Water quality will be discussed in Chapters 2 and 4 of

the SEIS.

Comment: And it was '95 -- or '85 or '86, maybe it was '87 when we did experience extremely

low flow. Some of you who were here at the plant at that time remember those low flows.

7Q10 I believe it's called, is what we named it. Very, very close to opening up some of the

reservoirs in the dams upstream from Monticello certainly, upstream from the Twin Cities to

provide greater flows. We're going to see more and more of that. We're going to see less

flows with higher temperatures. We know what happened a year ago in France when they had

very, very high temperatures and the waters were too hot to take the cooling water from the

reactors, and they had to shut the reactors down. Your EIS needs to take much more account

of that than I think we historically have. (MS-D-1 1)

NUREG-1 437, Supplement 26 A-1 4 August 2006 1
Appendix A

Comment: The NRC does not address the fact that while torrential down pours followed by

days of hot dry weather used to be unusual in the state ten years ago, they have become

common; cities are scrambling to address rapidly changing water levels that fluctuate from

unusually high to unusually low. (MS-S-24)

Comment: Item 12 & 13, Physical Impacts on Water resources, Water Use. Xcel Energy uses

water to cool reactors and this topic should be addressed in the EIS, because of the definite

and apparent impacts on local aquifers and water resources. (MS-X-4)

Comment: The EIS needs to tabulate concisely how much of which contaminant is estimated

to have been released for the past 2 decades of operation. The EIS needs to show water flow

rates and respective volumes in which continuous and batch releases have and are expected to

occur, and model the effects of these releases, taking into consideration latest scientific

evidence (see 3,4,5)- not the references from 10 years ago as in the generic EIS. This

modeling should include mitigating factors related to global climate change, such as volatile

changes in available water quantity, especially of the Mississippi River. The EIS needs to show

how adequate water monitoring would be performed, by whom and who would pay for it.

(MS-Y-35)

Response: The specific impacts of climate change within a particular region or watershed are

* highly speculative, and are therefore beyond the scope of a NEPA review for reactor license

renewal. Furthermore, any changes in watershed characteristics would likely be gradual,

allowing water-use conflicts to be resolved as needed. Operating license holders are required

to submit Annual Effluent Monitoring Reports and are also required to submit event reports

during abnormal conditions. Water use conflicts will be discussed in Chapter 4 of the SEIS.

5..ei Comments Concerning Aquatic Ecology Issues

Comment: The EIS must consider the impact of hot water discharges into the Mississippi river

on aquatic plant, animal and human life. (MS-V-10)

Response: The comment is related to aquatic ecology. Impacts to aquatic species will be

addressed in Chapter 4 of the SEIS.

6. Comments Concerning Terrestrial Resource Issues

Comment: Monticello is a strong supporter of the environment. We take great care in our

daily activities to ensure that the environment is well protected. Our employees feel fortunate

that the location of Monticello rests on the bank of the Mississippi River within the reaches of

the Montissippi County Park and the Lake Maria State Park. The site is home to numerous

wildlife, aquatic species and plant life. Our efforts have made Monticello a safe and sound

habitat for many years, and it remains our commitment to maintain that for years to come.

(MS-A-6; MS-l-6)

August 2006 A-1 5 NUREG-1437, Supplement 26 1
Appendix A

Comment: Item 25, Nearby resources. First glance appears to be an incomplete list which

does not include resources identified by the local community other than one "biologically

sensitive area." This section also needs more discussion about impacts in the event of a

release or accident. (MS-X-8)

Response: The comments are related to terrestrial resource issues, which will be addressed in

Chapters 2 and 4 of the SEIS.

7. Comments Concerning Air Quality Issues

Comment: The next thing I would like to just mention briefly is that we are moving into a totally

different climate paradigm. Global warming is on us. Nuclear reactors were not designed and

built, and the functions that are provided within the redundant safety systems and so forth were

not designed for the brave, new global warming world. (MS-D-9)

Comment: The EIS must consider the C02 releases of the nuclear cycle in comparison with

other generation fuels, including uranium mining, milling, and other aspects of fuel production,

transportation and concrete C02 emissions. (MS-V-9)

Comment: Item 22, Vehicle Emissions. More discussion is needed as this is the only

identifiable source of air emissions. Trucks,ý hauling equipment, and vehicles used to perform

ongoing maintenance need to be quantified and compared to USEPA guidelines especially

considering the fact that this area is in danger of falling out of "Attainment" for ozone. Vehicle

emissions are a primary source of ozone precursors as identified by the Minnesota Pollution

Control Agency and Xcel Energy in various publications. (MS-X-6)

Comment: Item 23, Stationary Source Emissions. This topic should include a more complete

discussion of the radioactive emissions and also the impacts of particulate from construction of

cask storage facilities and other activities related to plant operation that are on-going (back up

systems for heating, cooling, etc). (MS-X-7)

Comment: The EIS needs to describe the impact on air quality and green house gas

emissions.

The specific EIS needs to consider CO2 production. The EIS needs to include data on C02

production numbers by the nuclear fuel cycle. (how much has been released should be

concisely presented in table format for the past 2 decades of operation). In comparison to

renewable energy, energy from nuclear power releases 4-5 times more C02 per unit of energy

produced. Contrary to the generic EIS and public belief, C02 is emitted at every stage of the 7

stages of the nuclear fuel cycle: mining uranium milling, conversion, enrichment (90% of C02

production), fabrication into fuel rods, reactor operations and finally waste "disposal".

(MS-Y-36)

NUREG-1437, Supplement 26 A-1 6 August 2006 1
Appendix A

Comment: The EIS needs to quantify air releases, show how adequate air monitoring would

be performed, by whom and who would pay for it. The generic EIS only admits that small

amounts of ozone and smaller amounts of oxides of nitrogen are produced by transmission

lines (how much should be concisely presented in table format for the past 2 decades of

operation). (MS-Y-37)

Comment: The power created is clean, with virtually no harmful air emissions. (MS-Z-3)

Response: Air quality issues were evaluated in the GElS and determined to be Category 1

issues. The comments provide no new and significant information on air quality and will,

therefore, not be evaluated further.

8. Comments Concerning Land Use Issues

Comment: The EIS must consider the impact of the growth of the Metropolitan area, which is

now encroaching on the plant, putting more people in harms way, downwind and downriver.

(MS-V-11i)

Response:. Land use issues were evaluated in the GElS and determined to be Category 1

issues. The comment provides no new and significant information on land use and will,

therefore, not be evaluated further.

9. Comments Concerning Human Health Issues

Comment: The second issue I would like to address has to do with, well, this new information

out. As we spoke yesterday or the day before, the National Academy of Scientists, it's not the

BEIR [Biological Effects of Ionizing Radiationj reports anymore. They don't call them the BEIR,

but the panel of the National Academy of Science that looks at biological consequences of

long-term, low-level exposure released the next round. And they confirm that there is no safe

threshold. In other words, if you are exposed to the degree that you are exposed, particularly

we will find if the exposure is not background, but rather internal because then it's ongoing, it

doesn't stop. It never stops if it's internal. And you can't escape it if it's internal, if you've

ingested or inhaled beta in particular. There is no safe threshold for that; and the degree of

exposure, the symptoms that will be exhibited increase proportional to the amount of exposure

that has happened all the way down to zero.

So based on that knowledge, why, we have a problem, in my opinion, with the monitoring that

goes on because we don't know -- we do know that these reactors as they explode uranium

atoms and provide the entire periodic chart of other elements, including all of their radioactive

sons and daughters. And then we release many of them because they're gases in particular.

And we store them for a while. And then we wait for a while. And then at some point we decide

it's time to let them go. And they report them to the NRC, and we've got a boxful of reports as

to how many curies of this and that went out. And the monitoring looks very convincing if you

August 2006 A-1 7 NUREG-1437, Supplement 26 1
Appendix A

don't know what you're looking at because it's dominated with TLD's, thermoluminescent

dosimeters, which are gamma ray detectors.

Well, that's fine. We have a monitoring system that essentially will tell us when we have an

accident. We shouldn't need a monitoring system to tell us that. We should know that from

other sources. And what we should know is where are the reported releases going? Because

unless we know where they go, we don't know where the receptors are. And unless we know

where the receptors are, we don't know what the biological consequences of that reception are.

And so the scope of this EIS needs to include a requirement -- you need to have data included

in this EIS if what you're talking about is whether the consequences -- I saw it on the slide.

What are the consequences of continued operation? You need to know before you can say

with any veracity what the consequences of continued operations are. You need to know where

do reported releases go? If you don't know that and if the EIS can't say that, you have no

business making any conclusions on whether the consequences, the environmental

consequences of your continued operations. (MS-D-7)

Comment: Extending operations at Monticello for 20 more years will also mean more

cancer-causing radiation emissions will be pumped into the atmosphere. (MS-S-1 0)

Comment: As with problems surrounding public involvement, problems surrounding

environmental concerns reveal broad segments of the population have been ignored by the

NRC. The NRC relies on studies that assume a healthy adult male who weighs approximately

150 pounds is the recipient of radiation emissions. (MS-S-12)

Comment: The NRC does not consider how radiation effects women, children, developing

fetuses, the elderly, people with immune deficiency problems, people who are obese, and

people who are underweight. The studies of radiation used by the NRC reveals a clear

discrimination against well over 50% of the population; it is sexist, ageist, and elitist. On this

latter point subjects are assumed to be healthy, i.e., individuals who have the resources to care

for their bodies and their diets. (MS-S-14)

Comment: The NRC does not consider long-term radiation exposure. It does not weigh basic

facts about human physiology. For example girls are born with all of their eggs intact. What is

the effect of long-term exposure to human eggs? Will there be decline in human health and

abilities over the next two to ten generations? (MS-S-15)

Comment: Generating electricity from nuclear material requires tremendous amounts of

energy to process the uranium. Much of this electricity comes from coal plants which produce

high levels of global warming carbon dioxide and high levels of mercury emissions which

ultimately end up in human bodies; the EPA now estimates that one in six pregnant women

have levels of mercury in their bodies high enough to jeopardize the development of the fetal

nervous system. (MS-S-17)

NUREG-1437, Supplement 26 A-1 8 August 2006
Appendix A

Comment: The EIS needs to acknowledge that there is no safe threshold for radiation

exposure. The widely acknowledged absence of a "safe" threshold for radiation exposure

should provide a strong reason for NRC not to renew Xcel Energy's reactor license. Its routine

operations cause radioactive pollution. "The fact that humans cannot escape exposure to

ionizing radiation from various natural sources, is no reason to let human activities increase the

exposure." (MS-Y-5)

Comment: The EIS needs to accurately reflect actual radiation exposure.

The EIS needs to consider the so-called "routine radioactive releases" for Monticello

specifically. During Monticello's operation radioactivity is both continuously emitted and

periodically batch-released to air and water. It is unclear in what quantities, and how often.

These data should be presented in concise table format for the past two decades of operation.

Dilution with large volumes of station circulating water into reservoirs, rivers and lakes makes

the releases "disappear." This is not "natural background" radiation. (MS-Y-6)

Comment: The EIS needs to consider that NRC does not tightly regulate radioactive releases.

NRC only asks Xcel Energy to "make every reasonable effort to maintain radiation exposures,

and releases of radioactive materials in effluents to unrestricted areas, as low as reasonably

achievable" (ALARA, 10 CFR 20). This is unacceptably vague and not considered a standard

procedure for health risk limit settings in regulatory toxicology. (MS-Y-7)

Comment: The EIS needs to consider, and if none isavailable or found, fund the collection of

up-to-date, in vivo radiation exposure data. NRC's generic EIS at 4.6.2 "Public Radiation

Doses" presents unacceptably outdated, crudely modeled and ultimately uninformative data of

"maximally exposed individuals" from 1985-87. NRC's so-called "latest" report, Population

Dose Commitments Due to Radioactive Releases from Nuclear Power Plant Sites (1989), is 16

years old. None of the data are actual in-vivo measurements. (MS-Y-8)

Comment: The EIS must not exclusively rely on projections of radiation exposures. NRC

needs to review the population density around the plant. NRC need to review and reference

recent health studies that would confirm any low cancer incidence it assumes in the generic

EIS. (MS-Y-9)

Comment: The EIS for Monticello needs to use a dose commitment that integrates radiation

dose over time. NRC calculates radiation exposure only for the year of radiation release. In

contrast, most European nations use a dose commitment that integrates dose over time, rather

than only a one-time release. This non-dynamic modeling is akin to determining the cost of a

loan merely on the basis of the principal. (MS-Y-1 0)

Comment: The EIS needs to consider the effects and costs of long-term exposures by several

radionuclides including tritium. While most radionuclides emitted from Monticellos' nuclear

power reactor are relatively short-lived, there are some with long half-lives (like C14), and some

with infinitely long half lives (Ur238, 4.5 billion years) that can deliver harmful exposures for

August 2006 .A-1 9 NUREG-1 437, Supplement 26 I
Appendix A

months, -years, thousands and millions of years. Despite of its relatively short half-life (12 y)

tritium is of high concern. It is a highly mobile radionuclide moving anywhere hydrogen does.

While it is a relatively weak beta emitter, humans can inhale, ingest and absorb tritiated water

and food, where it becomes an internal hazard, irradiating the tissue. Tritium can

bioaccumulate through the aquatic foodchain. However, NRC's generic EIS at 4.6.1.1

(Radionuclide Deposition) argues on the one hand that Tritium is not known to build up, but

admits on the other hand that buildup is not explicitly accounted for in the aquatic food pathway.

NRC's tritium release limits remain lax, despite animal, human cell and DNA studies indicating

its toxicity. Paragraph 4.6.1 on public exposure falls woefully short on what needs to be

considered at Monticello, and seems more intent to deliver assurances than science based

information. (MS-Y-1 1)

Comment: The EIS needs to consider physiological or ecological interactions that would

mitigate exposures. Radionuclides can unite with carbon in the human body, plants, or animals.

Even though Tritium passes through the human body in 12 days, some becomes organically

bound and can remain in a person for much longer (450 to 650 days). One study even found

traces of tritium in the body 10 years after exposure. Similar processes happen in the natural

environment: As released radioactive gases decay, some form particulate and join other

persistent radioactive isotopes released as fallout. Long-lived isotopes persist, accumulate and

"bio-magnify". in biota through the food chain. (MS-Y-1 2)

Comment: The EIS needs to accurately estimate radiation-induced health risks in the general

population both at Monticello and the larger region.

NRC needs to include emerging evidence on health effects in its EIS. More specifically the

1992 Energy Policy Act requires EPA to set public health and safety standards "based upon

and consistent withu the recommendations of the National Academy of Sciences. NAS just

published their latest report on radiation risk in June 2005 (BEIR VII report). Sixty years after

Hiroshima, the full scope of effects of radiation on human beings is still incompletely

understood, but progress has been made in the past 10 years since writing of NRC's (sic)

generic EIS. (MS-Y-14)

Comment: The EIS needs to consider that NRC's radiation protection standards are not

protective of the majority of the US population. (MS-Y-1 6)

Comment: The EIS needs to consider that cancer risks from radiation exposure are higher

than previously estimated. The BEIR VII report is an improvement in so far as it estimates

cancer incidence and mortality according to age of exposure, gender and by cancer type. The

average risks to the population are estimated to be 10-15 % higher than the reference value

currently used for radiation protection of the general population (565 cancer fatalities per million

rem exposure in BEIR VII compared to 500). (MS-Y-17)

Comment: The EIS needs to consider non-cancer health risks. Newly emerging evidence

points to the fact that radiation can cause a spectrum of effects, such as reproductive and

NUREG-1 437, Supplement 26 A-20 August 2006 1
Appendix A

cognitive impairment. We now know that certain life stages and situations exist, when exposure

to both radiation and hormonally-active compounds pose an increased risk to human health.

As the BEIR VII report does not touch on publications after 2000, it is likely still underestimating

the true health impact. See below. (MS-Y-1 8)

Comment: The EIS needs to show how NRC intends to monitor for health effects in the

general population. The EIS needs to specify how NRC would achieve the monitoring rather

than relying on projections assisted by third parties with significant interest in a downplaying of

effects. In the absence of other tracking systems in Minnesota this should include at a

minimum an annual review of data from the state's cancer surveillance and birth defect registry,

and the specification as to who would pay for the monitoring of health effects. (MS-Y-1 9)

Comment: The EIS needs to account for sensitive subpopulations. NRC models still use a

hypothetical 154-lb. adult white male for dosimetric modeling and protection standard setting.

This does not take sensitive or divergent populations into account, such as

a) women

b) infants and children

c) the unborn

d) the elderly

e) immunocompromised (MS-Y-20)

Comment: The EIS needs to account for women's increased vulnerability. Women's critical

organ doses and effective doses (as defined in International Commission on Radiological

Protection 60) are about 25% higher than for men. Women's gonad doses may even be as

much as factors of 10-30 higher than in men. The risk for women to contract solid tumors like

lung, breast, kidney, and liver cancer due to radiation exposure is about double those for men.

The cancer mortality risks for females are 38% higher. Only for a few cancers, including

leukemia, the risk estimates for men are higher. The special hormonal status of females

increases cancer risk from exposure to ionizing radiation. Pregnant women appear to have an

increased risk of cancer. Furthermore, research in both humans and animals has shown that

interactions between hormonally-active chemicals and ionizing radiation may increase some

types of cancer. For instance, low doses of neutrons were more effective in inducing breast

cancer in female rats in combination with prolactin than without it. Hence radiation during

pregnancy, when prolactin is increased is adding to the cancer risk. (MS-Y-21)

Comment: The EIS needs to account for infants and children's increased vulnerability.

Current NRC standards and models do not consider newborn's special vulnerability to radiation.

Many radionuclides are excreted in breast milk, providing a special exposure pathway for

infants. The brain continues to develop during the first 2 years of life. Numerous studies show

August 2006 A-21 NUREG-1437, Supplement 26 1
Appendix A

that ionizing radiation can impair the developing human brain and affect cognitive processes.

Further evidence is from children treated for leukemia or brain tumors, although confounding

factors cloud the issue somewhat. A recent study from Sweden examined 3000 men who

received irradiation for a skin problem as young children. It clearly demonstrated a significant

dose-response relationship for all cognitive tests at doses equivalent to those from computed

tomography of the skull. IQ loss is a lifelong health effect. Several longitudinal birth cohort

studies have shown that optimal brain development in utero and in the first years of life are a

determinant for how well cognitive abilities are preserved in old age. In other words brain

development impaired through radiation exposure during infancy and early childhood predicts

cognitive decline in old age. Therefore costs from this health effect accrue over a long time.

The risk for children to contract radiation-induced cancer is high, even higher than for women.

For instance, the same radiation in the first year of life for boys produces 3-4 times the cancer

risk as exposure between age 20 and 50. Female infants have almost double the risk as male

infants. A study in the August 2003 issue of the Archives of Environmental Health showed that

children growing up in regions with nuclear power plants develop cancer twice as frequently as

controls/the national average. Milk teeth from the 47 cancer-stricken children contained higher

levels of Sr-90. Radiation induced child health effects that need to be considered in the EIS are

not merely loss of life and cancer, like leukemia later in life, but also chronic health conditions,

such as an increased chance of birth defects, impaired fertility or 10 loss. The societal impacts

and costs due to lost earning potential and mental retardation deserve NRC's special

consideration. Unfortunately NRC de facto ignores the risk of low dose radiation in its

protection standards. (MS-Y-22)

Comment: The EIS needs to account for the increased vulnerability of the developing fetus.

Since the bombing of Hiroshima and Nagasaki it is well known that the unborn child is very

sensitive to the effects of radiation. One reason is that the cells of the embryo are rapidly

dividing and growing into specialized cells and tissues. This is accomplished through a

complicated orchestration of high-level hormonal activity. A growing body of literature informs

on synergism between hormonally-active compounds and radiation. The hypothalamo pituitary

axis is a major regulator for endocrine activities, which are increasingly impacted by ubiquitous

endocrine disrupting chemicals. There is general support for the view that development and

programming of this axis during fetal life is the most sensitive window to permanently alter the

homeostatic mechanisms of the endocrine system, including the mature reproductive system.

Prenatal radiation exposures clearly are causes of endocrine-related cancers or susceptibility

thereto. Low doses of X-rays to the fetus, especially during the last trimester, cause an

increased risk of leukemia and all other types of cancer during childhood. Even use of

therapeutic X ray of infants is associated with thyroid and breast cancer later in life. It is my

understanding that current models to calculate internal radiation doses do not permit adequate

modeling of the dose to individual organs within the fetus, even though this would obviously be

quite important for safety assessments. Very few authors.have attempted to make such

individual organ dose estimates. However, with each additional study it is becoming clearer

that placental transfer and fetal dose estimates have historically been underestimated. For

example, the fetus is .cradled above and behind the mother's bladder, which concentrates

radionnuclides and can provide additional radiation exposure, a source previously discounted.

NUREG-1437, Supplement 26 A-22 August 2006 1
Appendix A

Despite available evidence the quantification of the unborn child's health risks from exposure of

parents to radiation is a task that NAS still has to tackle. Yet, NRC cannot afford to wait

another 15 years fort the next NAS report. NRC needs to err on the side of caution and

consider birth defects, intellectual and reproductive impairment as radiation related health effect

in its impact analysis. (MS-Y-23)

Comment: The EIS needs to account for the increased vulnerability of the elderly. Older age

radiation exposures are associated with higher cancer mortality. (MS-Y-24)

Comment: The EIS needs to account for the increased vulnerability of the

immunocompromised. Radiation-induced cell damages are less likely to be repaired by a

person with an incompetent immune system as can be gleaned from the secondary cancer rate

in cancer survivors after radiation therapy. The number of people whose immune system is

compromised is rapidly increasing in our region due to immunosuppressive medical treatments

and increased survival of people with infections and congenital immune deficiencies.

(MS-Y-25)

Response: The comments are related to human health issues. Human health issues were

evaluated in the GElS and were determined to be Category 1 issues. The GElS evaluated

radiation exposures to the public for all plants including Monticello; and concluded that the

impact was small. During the plant-specific environmental review of Monticello, the NRC will

determine whether there is any new and significant information bearing on the previous analysis

in the GELS. The information provided by the comments will be reviewed as part of that search.

In addition, evaluation of new studies and analyses of the health effects of radiation exposure,

such as BEIR VII, is an ongoing effort at the NRC. ff significant new information is found, the

NRC will perform a plant-specific analysis of this environmental impact. This issue will be

addressed in Chapter 4 of the SEIS.

10. Comments Concerning Socioeconomic Issues

Comment: On a different note, Monticello is more than a power plant operated by highly

skilled workers. Monticello is part of this community. Not only does the plant rely upon many

local companies for goods and services, but our employees live in and contribute to these

communities and the surrounding communities on a daily basis.

We're proud to participate and give back to the community in a variety of ways, including

serving on city and town boards, as leaders in civic and community organizations, as sports

coaches, on church committees, boards and councils, and as members of charitable

organizations. Our employees also help raise money for our local United Way organizations,

the Relay for Life, the American Cancer Society, the Rotary Club, STARS Hockey Association,

just to list a few. (MS-A-7; MS-l-7)

Comment:' Monticello provides significant benefiis, as John has pointed out, to the local and

state economies by providing more than 500 full-time, family-supporting jobs. The plants and

August 2006 A-23 NUREG-1437, Supplement 26 1
Appendix A

its employees purchase numerous goods and services from the local businesses and contribute

and support the local charities and community organizations.

The plant also provides significant tax support to the local community. Xcel Energy is

committed to being a good neighbor and fostering those continued economic growth in the

region. (MS-B-8; MS-J-8)

Comment: This facility with the 500 jobs it does offer our community offers excellent .career

growth and retirement for the residents. It brings about economic vitality to all of our

community.

Xcel closely works with city officials and county officials dealing with safety and security issues.

During refueling, hundreds more contractors and subcontractors frequent our hotel, motels and

restaurants, bringing more economic vitality to our community. (MS-C-i)

Comment: Previously you heard many examples of Xcel being a good neighbor. Another

example is its commitment to youth and actually other older residents, such as myself. They

have provided excellent softball and youth league baseball/softball facilities. It's a modern

facility where many residents and non-resident families come to spend quality time. Prior to this

location, NSP had provided a men's softball complex adjacent to Montissippi Park. This has

now been converted to an area for radio-controlled model airplane enthusiasts. (MS-C-2)

Comment: The plant has provided stable good paying jobs for many people in the community

and has aided the community in this respect by bringing many people to Monticello for

employment. A great number of these individuals have contributed much to the town in terms

of leadership and volunteerism. (MS-L-2)

Comment: Xcel (sic) has made it a policy to aggressively seek to provide sponsorship for a

great for a large number of community activities designed to make Monticello a cleaner, safer

and better place to live. Their contribution to Monticello's tax base alone has also assisted

many community residents by lowering property taxes. (MS-L-4)

Comment: The Monticello Nuclear Plant has been an excellent neighbor to our community and

school district for more than 35 years. Over the years many of the employees have resided in

our community and sent their children to our schools. In addition, the employees have been

civic minded members of our community. Numerous employees have joined local organizations

and have served as community volunteers. Members of the Monticello Nuclear Plant have

historically supported various community events such as the United Way and the annual River

Fest Celebration. (MS-N-2)

Comment: The plant has also provided the area with a substantial tax base for our city,

township and school district. (MS-N-4)

NUREG-1437, Supplement 26 A-24 August 2006
Appendix A

Comment: The Hospital District provides several programs such as Home Delivered Meals,

Childbirth Education Classes, and music therapy for our Nursing Home residents that receive

financial support from the United Way. Employees of the nuclear plant have supported the

United Way. Plant employees are a part of our volunteer activities for our patients and

residents. The local economy is better with the tax support provided by the nuclear plant.

Monticello is growing rapidly and having the license renewal for the nuclear plant will provide

stability for our community. (MS-O-3)

Comment: I also operate a local business and we say that many of our best customers are

employees of the plant. They have been known to hire first class people and pay a very nice

wage. In addition you will find employees to be active in local churches, coaching a youth

hockey and baseball team, president of a local group like rotary. They do a wonderful job of

having a quiet and almost invisible physical location while being very visible around the

community. In addition to the employees it is easy to see and notice how the plant itself prides

itself in supporting a whole variety of local efforts and charitable type events. (MS-P-3)

Comment: Last but not least is that I know they pay a whole lot of money in taxes. This is

critical for all of us locally here in Monticello, but also spreads much further throughout all of

Minnesota. (MS-P-4)

Comment: The plant employs nearly 500 people with an annual payroll of over $50 million

dollars, which is of course of great benefit to our community. But these employees are also a

wonderful asset to the spirit of Monticello with their generosity, volunteerism and support of our

local business and school district. Both-the employees and the Company have been extremely

generous to the United Way and many additional local charities in our continuing quest for an

active and vibrant community. (MS-R-2)

Comment: Beyond this fact, there are many local benefits to the Nuclear Plant in Monticello. It

plays an important role in the local economy, both as an employer and taxpayer to local families

and governments. The company and its employees have demonstrated their support to the

community through donations and volunteer efforts to various local groups, organizations and

charities. (MS-T-2)

Comment: The plant is a vital asset to our state and important to my community. More than

500 people are employed full time at the plant. (MS-Z-2)

Comment: WHEREAS, a reliable, low cost and environmentally sound electric supply with a

diverse energy mix is critical to economic well-being; (MS-AA-1; MS-AC-1)

Comment: WHEREAS, the Monticello Nuclear Generating Plant provides nearly 500 full-time

jobs and contributes significantly to the local and state economy; (MS-AA-3; MS-AC-3;

MS-AD-4)

August 2006 A-25 NUREG-1437, Supplement 26 1
Appendix A

Comment: WHEREAS, the Monticello Nuclear Generating Plant is now, and will continue to

be, a significant contributor to the local tax base, ... (MS-AC-5)

Comment: WHEREAS, nuclear power is a reliable, low cost and environmentally sound source

of electricity, and is an important factor in a diverse energy mix that is critical to our economic

well-being; (MS-AD-2)

Response: The comments are supportive of license renewal at Monticello Nuclear Generating

Plant, and are general in nature. The comments provide no new and significant information on

socioeconomic issues, and therefore, will not be evaluated further.

Comment: The EIS needs to assess the negative socioeconomic impacts on Monticello

a) The EIS should specify Monticello nuclear plant tax payments as the percentage of the total

city and county revenue. The data under 4.7.2 Taxes in the generic EIS show tremendous

variation and are not helpful (<1 - 88%).

* b) The EIS should specify how many jobs and how many families depend on the Monticello

nuclear plant as the percentage of the total city and county population. This would better

illustrate an impact that needs to be explicitly considered, not projected. Dependence on

the nuclear plant is a risk factor to the region.

c) The EIS should provide actual details about the change in land use pattern since licensing

of the reactor. The generic EIS paragraph 4.7.4 Off-Site Land Use is insufficient in judging

whether sprawl with all its negative human and ecosystem health impacts is a result of the

plant. The area to the immediate southeast of the reactor is one of the fastest growing

communities in Minnesota. (MS-Y-32)

Response: The comment is related to socioeconomic impacts on taxes, employment, and land

use issues specific to Monticello. Socioeconomic impacts such as taxes, employment, and land

use are Category 2 issues. These issues will be addressed in Chapters 2 and 4 of the SEIS.

Comment: It's interesting as the severe accident mitigation alternatives, whatever that is, we

have a substantial southeast Asian immigrant population in Minnesota, and they don't speak

English and they eat a lot of fish. And so if we have a severe accident at Monticello and we

contaminate a stretch of the river, we need to have a specific methodology of notification of all

those communities and those individuals that may fish in the upper reaches of the Mississippi.

And so that includes like four southeast Asian languages and all that type of thing. And they

don't necessarily follow the strict rules and regulations that we might have. And so it's going to

be a substantial effort of notification. Otherwise you're going to have missed a large population

that would be directly impacted. And also a large Hispanic, Latino community as well that in

fact probably also does not speak English. And so you have all these groups that you must

include in your analysis. (MS-E-3)

NUREG-1437, Supplement 26 A-26 August 2006 1
Appendix A

Comment: The NRC also fails to address how low-income people in the Twin Cities Metro

area would be able to procure safe drinking water in the event that the Mississippi River

became contaminated by nuclear material. (MS-S-1 3)

Response: Environmental justice is an issue specific to Monticello and will be discussed in

Chapter 4 of the SEIS.

11. Comments Concerning Postulated Accidents

Comment: I also work with the North American Water Office, and my primary interest is that

the Monticello Nuclear Facility is upstream from water intake, drinking water intake, for the

Minneapolis city. And it is the only source of drinking water.

And so I would charge the NRC in their EIS analysis if there is an accident and there is a

substantive discharge into that waterway, we have no alternative drinking water. And I would

charge you that it is a severe environmental justice issue because people can't go and buy

bottled water. Who is going to supply the water supply for 2 million people? And what are the

costs of that, and how are you going to protect the water supply of Minneapolis?

St. Paul also gets a substantive percentage of its.water from the Mississippi. They do have

some deep wells and some lakes that they can also -- that they do also use. And so there is an

additional exposure for St. Paul that you must consider. (MS-E-1)

Comment: So I'm inquiring about the severe accident mitigation alternatives. I found the

analysis in they call it consequence bins quite helpful and, you know, easy to follow. But what

was very unclear to me when the EIS explained these different categories of release potential,

extreme, more than 50 percent of the inventory of cesium iodine being released. And then

large, between 20 and 50 percent, which, of course, is really a huge range I think in terms of

impact. Medium, small and negligible.

It explained that the severity depends upon the amount of the release in relation to the time in

.which general emergency was declared and people were alerted and were able to be,

mitigation measures were able to be taken.

What was completely unclear to me in the environmental review is whether or not the NRC has

any specific standards for this. How that decision is made? Who makes the decision as to

whether the general emergency is declared? When people are notified? Whether they're --

and I think this bears upon the question of the water supply as well. I became aware of this

question when I was sitting in on a technical representatives meeting, which they have monthly

in the Environmental Quality Board.

And I think it's the Health Department. I'm not sure if it's the Health Department or the PCA, but

many of the agencies are involved right now in a review of protections for service waters that

serve as drinking waters under the EPA requirement, voluntary requirement.

August 2006 A-27 NUREG-1 437, Supplement 26 1
Appendix A

And there were ten -- this has been like a six-month or eight-month, year-long process

identifying the inventory, the service water inventories. And then determining what the priority

contaminants were that they were going to consider. And one of those priority contaminants

was specifically radioactive contamination from Monticello plant. And so this is something that

is on the docket in this review, EPA review. (MS-F-i)

Comment: The Monticello nuclear power plant is located upstream from the Twin Cities on the

Mississippi River. Residents of Minneapolis, St. Paul, as well as substantial numbers of people

who live in sections of first-ring suburbs such as Edina get their drinking water from the

Mississippi. (MS-S-2)

Comment: The NRC has failed to adequately address risks to ground water contamination.

According to the NRC's own study the soils at the Monticello site are primarily Hubbards which

are highly permeable and also have limited available water capacity. These soils readily

transmit rainwater and surface water to groundwater supplies. In the event of radio-active

material seeping out of containment units it is quite likely that groundwater sources and even

aquifers could become contaminated. (MS-S-25)

Response: The comments are related to the impacts of design basis accidents and severe

accidents. The impacts of design basis accidents were evaluated in the GElS and determined

to be small for all plants; therefore, it is a Category 1 issue. The GElS evaluated severe*

accidents for all plants including Monticello, and concluded that the impact was small.

However, alternatives to mitigate severe accidents must be considered for all plants that have*

not considered such alternatives. During the plant-specific environmental review of Monticello,

the NRC will determine whether there is any new and significant information bearing on the

previous analysis in the GELS. Section 5.1.2 of the plant-specific SEIS for Monticello will

address severe accidents. The applicant provided a severe accident mitigation alternatives

(SAMA) analysis as part of the license renewal application for Monticello. The NRC staff's

review of the SAMA analysis will discussed in Section 5.2 of the plant-specific SEIS for

Monticello.

12. Comments Concerning Uranium Fuel Cycle and Waste Management Issues

Comment: Relicensing Monticello will result in more spent nuclear waste being generated near

this valuable water resource. (MS-S-3)

Comment: The NRC makes no provisions to ensure that the energy needed to process

uranium, and extract uranium is generated by sources such as wind or solar that do not

produce harmful mercury, carbon dioxide, and nitrogen oxide emissions. (MS-S-1 8)

Comment: The NRC fails to acknowledge that there is no way to access accurately the true

cost of securing and storing spent nuclear fuel for future taxpayers. Such an exercise is futile

as there is no way to know how strong future economies will be.

NUREG-1 437, Supplement 26 A-28 August 2006 1
Appendix A

The NRC fails to acknowledge that a large percentage of our financial resources will be diverted

from other areas in order to provide financial resources for securing nuclear facilities and

storing nuclear waste. (MS-S-20)

Comment: An obscure amendment to the federal energy bill (S706, HR2189) just passed

7/29/05, eases the restriction on overseas export of bomb grade uranium. (Sorry, I don't have

the section number.) Exporting toxic and hazardous waste is a common practice for a rich

country such as ours.

With the clear and present threat of nuclear terrorism, exporting bomb grade uranium would be

unthinkable if it were not real. Amassing deadly bomb-grade materials tempts corporate

decision-makers to take the export "solution." What guarantees exist to keep this waste in our

own state or nation? (MS-U-i)

Comment: There is an assumption that the federal government will somehow "take care of"

the N-waste. However, since the last century when nuclear weapons/power came on-line there

is no clear solution about long term storage. There has been a lot of money spent and rhetoric

said, but nothing is settled. (MS-U-5)

Comment: The EIS must address the environmental impact due to continued operation for an

extended (sic) license lerm, where there is more radioactive material to be stored, higher

burnup rate waste is dangerous for longer periods, more casks needed, etc. Assemblies will

increase from 1630 to 4512, nearly tripled, by 2030. (MS-V-8)

Comment: Is this temporary or permanent storage? The EIS must determine what will happen

to the nuclear waste at the end of the term of licensure. If there is no answer, a number of

reasonable scenarios must be fully analyzed, with caretaking of waste and maintenance of

casks and facility assured to end point. (MS-V-13)

Comment: Additionally, due to the fact that a long-term storage facility is unlikely to be built

anytime soon, and that facility will not have room for additional waste from Monticello, this issue

will be affecting generations of Minnesotans and metro residents. (MS-X-l)

Comment: Item 28, Infrastructure impacts. More information needs to be included including

impacts of transporting nuclear fuel to the facility by truck or rail and explanation of whythe

plant needs electricity, it is a nuclear power plant after all. (MS-X-9)

Comment: Item 30, Social, Economic, and Community impacts (Other). There needs to be a

discussion of the larger impacts of transporting nuclear fuel into the Monticello Community and

metro area, the ongoing operations of the plant, and the long term impacts of storing highly

reactive nuclear waste at a site for 200-10,000 years. (MS-X-11)

Comment: The long-term ability of humans to store, contain, and manage nuclear waste is

something yet untested. While some may argue that we have done so effectively for the most

August 2006 A-29 NUREG-1437, Supplement 26 I
Appendix A

of the last 50 years there are numerous case studies to argue the opposite point (e.g. Three

Mile Island, Chernoble Disaster). Since the production of nuclear electricity is non-sustainable

in its current form and since there are no methods to properly address long-term storage of

deadly nuclear waste we think it is fairly myopic and somewhat reckless to move forward unless

all risks are clearly delineated in the public's view. (MS-X-1 2)

Comment: The EIS needs to consider transportation accidents involving nuclear material.

(MS-Y-27)

Response: The comments are related to the environmental impacts associated with the

uranium fuel cycle, which were evaluated in the GElS and determined to be Category 1 issues.

The GElS evaluated impacts associated with the uranium fuel cycle for all plants including

Monticello, and determined that the impact was small. During the plant-specific environmental

review of Monticello, the NRC will determine whether there is any new and significant

information bearing on the previous analysis in the GELS. ff significant new information is

found, the NRC will perform a plant-specific analysis of these environmental impacts. Chapter

6.0 of the plant-specific SEIS for Monticello will address these issues. The comments provide

no new information and, therefore, will not be evaluated further.

13. Comments Concerning Alternatives

Comment: Our analyses show that keeping Monticello and Prairie Island as part of that

diverse energy mix will benefit our customers by an estimated $1 billion in today's dollars during

the life extension periods, compared with the next best replacement options. Our analysis also

shows that keeping the plants running will result in significantly lower air emissions than would

occur if they were shut down and replaced with the only realistic alternatives, which are coal or

natural gas-fired plants. (MS-B-5; MS-J-5)

Comment: And it's incumbent upon the Nuclear Regulatory Commission in its scoping of a

commitment for an additional 20 years of reactor operations to at least be mindful of what's

happening in the next five years relative to how electric utility services are going to be delivered.

CBED stands for Community Based Energy Development. And what it means is that we have

an opportunity of taking advantage of the modern technologies, as opposed to the obsolete

ones, which we're talking about here today, to look at the distributed dispersed capacity that

can and will be coming on-line very rapidly in the next five years.

CBED enables those energy systems to come on line in a way that we've never experienced

before. It provides a negotiating framework for the power companies to negotiate power

purchase agreements with independent qualifying producers of energy. Locally owned,

community-based energy. The type of energy development that will have to happen if we are

ever to get out of our commitments to central station power and all of the problems that that

represents in terms of how you manage nuclear waste for 140,000 years or more. What do we

do about the mercury contamination? What do we do about global warming in particular from

NUREG-1437, Supplement 26 A-30 August 2006 1
Appendix A

the coal chain? What about all the security threats from the nukes and all of the routine

releases from the nukes and the catastrophic threats that nuclear power represents?

If we're going to work out of those binds, we will need to make a transition. And CBED is a

profound tool that will enable that transition to happen. Right now it's true. It's for wind, and we

recognize that wind can be an intermittent resource, not a base-load resource. And we all like

to have the lights turned on even when the wind isn't blowing.

But it's also true that CBED projects provide an opportunity for us to now move forward to the

hybrid systems where wind is married to combustion technologies. And right now -- well, there

is the Public Utilities Commission meets next week, where we will be authorizing a test burn of

a 2-megawatt diesel generator to a wind system in Southwest Minnesota in Rock County by

Luverne.

And what will happen there is we're going to figure out how, as the wind tapers off, the

combustion capacity can come on. And before very long, before this year is out, we'll have a

pretty good handle on how to handle about 600 megawatts of peak during the year, which will

be extremely lucrative to power producers because having 600 megawatts -- 600 hours, having

a megawatt available on demand for 600 hours a year, your call utility, that's worth about six or

seven thousand dollars a month, in addition to the energy, to have the capacity.

So we have the economic opportunity for this development to happen. And before two or three

years -are up, we'll'be down on the shoulders of that peak. We'll be up to 14, 16, 1800 hours a

year. And before this plant gets renewed, we're going to be swinging with a load duration curve

just like Sherco 3 does. And then we're in business. (MS-D-3).

Comment: And as an afterthought, we go through the IRP, the Integrated Resource Planning

process, to figure something out about conservation, because that's in the public good. Well,

we're going to figure out at some point it is my fondest hope -- well, maybe second fondest --

that we figure out how to tie the financial health of the utility systems to what we all really want,

which is the efficient use of resources, rather than the wasteful consumption..

And when we do that, we're going to find that we're wasting right now well over 50, 60, 70

percent of all of the kilowatt hours we consume. We don't need to if what we're focused on is

how to get us the light that we want, or the refrigeration that we want, or the industrial drive that

we want, rather than just selling bulk kilowatt hours.

So these are changes that are coming at you, NRC, in the time period that you're looking at for

renewing this license. And I'm just really, I'm confused as to how you are going .to evaluate

that. (MS-D-5)

Comment: But when you consider alternatives, which you need to do, I would like to urge you

to consider putting coal gasification that is slated to go elsewhere in Minnesota down here

August 2006 A-31 NUREG-1437, Supplement 26 I
Appendix A

instead of nuclear. You preserve the jobs. You get rid of nuclear. You don't have to deal with

those types of environmental issues, and I'll submit information in detail about that. (MS-G-1)

Comment: I am also concerned about alternatives. And again I live in Red Wing, which is

right by Prairie Island, down river from Prairie Island, and also down river from this plant. So I

would urge you to consider everything that Kristen particularly was talking about, and I will just

give details on this later. But in alternatives, there are options being considered for Minnesota

that would work really well here. This site is set up for it. It's time to consider some of those.

(MS-G-3)

Comment: The "permanent" solution is transition to gasification, wind, solar roof panels,

weather stripping, tighter windows a thousand improvements to improve our quality of life and

also boost local employment. (MS-U-9)

Comment: No Action Alternative. Comment 1: EIS must consider current levels of load and

generation in the region and state.

Comment 2: EIS must consider load and generation to evaluate impact of no action alternative:

MAPP 2004 Load and Capability Report.

MAPP Form 3 (most recent version)

NERC 2004 Long-Term Reliability Assessment Report'

CapX2020 Report

Rationale for Comments 1 and 2: The Federal Register notes that the "No Action" alternative

will be considered. As a part of this alternative analysis, the NRC must consider the current

levels of load and generation in the region and state to put the "No Action" alternative in

context, including, but not limited to the MAPP 2004 Load and Capability Report and the MAPP

Form 3 list of generation, the 2004 NERC Reliability Assessment Report, particularly the MAPP

and MAIN sections, and the CapX2020 report claiming a "need" of 6,000 MW and the MISO

queue with 16,712 MW in generation waiting in line. (MS-V-2)

Comment: Reasonable Alternative Energy Sources. Comment 3: The EIS must consider

reasonable alternatives including natural gas fueled combined cycle plant as a reasonable

alternative to Monticello.

Comment 4: The EIS must consider the Mesaba coal gasification plant as replacement,

electrically and physically, for Monticello.

Comment 5: The EIS must consider the efficiencies and environmental benefits of utilizing

pre-existing infrastructure and plant components in replacing Monticello with the Mesaba coal

NUREG-1 437, Supplement 26 A-32 August 2006 1
Appendix A

gasification generation balanced against continuation of Monticello nuclear generation and

construction and operation of Mesaba elsewhere. -

Comment 6: The EIS must consider system wide distributed, renewable generation as a

reasonable alternative to Monticello.

Rationale for Comments 3, 4, 5 and 6: Rationale: Xcel claims it needs generation and that it

should rely on coal and nuclear. The coal gasification option was mandated by the legislature,

yet because of the market realities of high electrical availability, a power contract was also

mandated. Because of these mandates, Mesaba should be analyzed as the first replacement

option for nuclear power. Monticello relicensing is before us right now, and the Mesaba

application to the EQB is imminent. (MS-V-3)

Comment: Comment 7: The NRC must evaluate, as reasonable alternatives, combinations of

different intermittent generation, such as wind with gas and/or biomass, to give capacity

equivalent to capacity percentages of "baseload" coal and nuclear.

Rationale for Comment 7: Xcel unreasonably relies exclusively on coal and nuclear when

combinations of other fuel options could provide generation equal to, for example, the 70% or

so availability of Monticello (40% wind plus just 30% gas = 70% capacity! See, that wasn't so.

hard.). (MS-V-4)

Comment: We would also suggest that alternatives to continued operations at the Monticello

facility be properly evaluated, particularly part 5 titled "Systemwide Renewable, distributed

generation" which could include the construction of wind farms, solar farms, or other renewable

energy sources where the fuel is present locally and the method of generation not inherently

dangerous. The # four option of "Wind and Gas" would also be a much more benign scenario

to continued operations and infinitely long storage of nuclear waste on-site. (MS-X-3)

Comment: WHEREAS, replacement of the Monticello Nuclear Generating Plant would result in

an electric rate increase and significantly increased emissions of carbon dioxide, nitrogen

oxides, and sulfur dioxide. (MS-AA-4)

Comment: WHEREAS, replacement of the Monticello Nuclear Generating Plant would result in

an electric rate increase and significant increased emissions of carbon dioxide, nitrogen oxides

and sulfur dioxide... (MS-AC-4; MS-AD-5)

Response: The comments are related to the environmental impacts of alternatives to license

renewal at Monticello. The GElS included a discussion of alternative energy sources.

Environmental impacts associated with various reasonable alternatives to renewal of the

Monticello operating license will be evaluated in Chapter 8 of the SEIS.

Comment: The latest scientific evidence needs to be researched and referenced. The

references of the generic EIS are testimony that the document is at the minimum 11 years old

August 2006 A-33 NUREG-1437, Supplement 26 I
Appendix A

and largely outdated when it comes to renewable energy literature. The EIS needs to show, for

example, that solar power holds tremendous promise in our region now, as there is increased

PV efficiency, state governmental support, and PV panel costs continue to decline an average

of 5% annually. The argument of land use and solar is incredibly exaggerated, as PV-panels in

urban areas are readily mounted on existing buildings. Solar energy has one of the highest job

intensities per unit of output of any energy technology, and thus has huge benefits to the local

economies that adopt them. In addition to jobs from the contractors that install systems, the

Minnesota economy is projected to benefit from an expanding solar energy manufacturing

industry including growth in such areas as semiconductors, plastic films, electronic equipment,

instrument measuring, switchgear and switchboard apparatus, wiring, storage batteries, sheet

metal, and flat glass. (MS-Y-39)

Response: The GElS is subject to periodic review and update; in 2003, the NRC initiated an

effort to update the GELS. As new information becomes available, the NRC determines

whether it is sufficiently significant to change a position. In Section 8.3 of the GELS, the staff

described the alternative energy technologies and evaluated the environmental impacts of

supply and demand alternatives with the focus of "... the purpose and need of the proposed

action [i.e., to provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs as such

needs may be determined by state, utility, and, where authorized, federal (other than NRC)

decision makers]...." The staff focus is on the power generation capability of a baseload

nuclear power plant. Alternative energy sources will be discussed in Chapter 8 of the SEIS.

Comment: The EIS needs to be sensitive to the issue of C02 reduction. (MS-Y-40)

Response: The comment raises issues related to alternative energy sources, which will be

evaluated in Chapter 8 of the SEIS.

Comment: The EIS needs to present a fair and accurate alternatives analysis..

The energy alternatives need to be discussed in an impartial manner. The generic EIS has a

definite inherent pro-nuclear spin. Could it be because the nuclear power industry has been

given more taxpayer dollars for research and development than any other energy sector?

(MS-Y-38)

Response: The comment is outside the scope of license renewal related environmental

impacts. The NRC's regulations in 10 CFR Part 51 require the NRC to consider all reasonable

alternatives to a proposed action as part of its NEPA review. The license renewal review

evaluates a reasonable range of alternatives to supply baseload electric power generation. The

analysis of alternatives to license renewal presented in the GEIS will be supplemented by a

plant-specific alternatives analysis of license renewal at Monticello. The comment fails to

provide any new and significant information, and will not be evaluated further.

NUREG-1437, Supplement 26 A-34 August 2006 1
Appendix A

14. Comments Concerning Aging Management

Comment: The Monticello plant has also been well maintained over its lifetime. Approximately

every two years we perform a refueling and maintenance outage, in which we typically carry out

over 2,500 individual maintenance and inspection activities. This is in addition to the ongoing

maintenance, inspection, and rigorous testing activities that are performed at the time the plant

is operating on-line.

Over on the years, we have continued to invest in a wide range of equipment improvements to

take advantage of technology and materials to ensure future reliable and safe operation. As

computer training methods have evolved, we are able to broaden the training available. As we

move forward, we will continue to upgrade the equipment and technology at the station.

(MS-A-4; MS-J-4)

Comment: And then we get to the aging issues for these reactors. Now, I understand, as I

said in my opening remarks, I understand the commitment of the work force and the intent of

the work force. But I also know that we have part of the fail-safe systems bolted to the packing

crate at Monticello'as well as at Duane Arnold for 35 years before it was discovered. Never

took the bolts off.

So just because you're good and paying attention doesn't mean things can't happen. I know

what happened at Davis Besse, where they were looking really hard, and they didn't find it

because they weren't looking in the right place. I know it happened at Point Beach when the

nuclear physicists forgot their high school chemistry and they caused an explosion in a cask.

Damned near tipped the lid into the pool, which could have drained the pool; and then we would

have some fire works. It didn't happen, fortunately.

But these are all examples; and there is many, many more. NRC knows them, so I won't bore

you with them, but we're pushing the envelope with all of this stuff. You guys to got to do a

better job of figuring out where to look when. You have to have more different ways of -- you

have to find more diverse ways of looking at things. You've got to figure out not only where to

look, but when to look. And you have to do that in a way that provides more assurance, thanwe have in the past, you're not overlooking things.

Things age. As things age, I mean it's the bathtub curve. Are you familiar with the bathtub

curve concept? Things of life where in the early -- using a human example, there is a death

mortality rate for infants which is higher than'for juveniles and adults. And then it goes up again

at the end, and in the long run we'll all be dead.

Well, the same with reactors or any other piece of equipment. It goes through a curve. And

now that we're doing re-licensing, you see we're getting into the tail end of that curve, and that's

why we look at aging things. But you're not looking at them good enough is the point. And the

unfortunate point is that there is no way that you can look at it good enough because you can't

always look everywhere. (MS-D-12)

August 2006 A-35 NUREG-1437, Supplement 26 1
Appendix A

Comment: Objectively, relicensing an old nuclear power plant beyond its expected peak

performance is an accident waiting to happen. Picture-a Bell Curve, problems with a

complicated energy plant occur at the beginning and end of its production-time. Where is

Monticello on that curve? Three Mile Island, Chernobyl the lesson will be repeated until it is

learned. (MS-U-7)

Response: The NRC's environmental review focuses on environmental impacts relevant to the

extended period of operation requested by the applicant. Safety matters related to aging are

outside the scope of this review. An NRC safety review for the license renewal period is

conducted separately, and will be documented in an NRC staff Safety Evaluation Report. The

comments provide no new information and will not be evaluated further in the context of the

environmental review. However, the comments will be forwarded to the project manager for the

license renewal safety review for consideration.

Comment: In addition, it has recently come to our attention that there are some age related

component degradation (sic) issues the EIS needs to address. Specifically, the potential of

mounting base plates, grout, and/or mounting hardware for pumps, heat exchangers,

compressors, tanks, turbines and motors to fail due to age-related degradation needs to be

examined.

Further, valve stem and pump shaft packing and gasket material, and other sealing materials

required to prevent system leakage to the environment where shafts penetrate through a pump

casings, valve body/bonnets, and other components needs to be analyzed for age-related

degradation.

Further, consumables such as lubrication media including oils and greases must be analyzed

from the perspective of age-related degradation.

Finally, valve internals flow isolation sealing subcomponents such as valve discs, plugs, and/or

gates must be analyzed from an aging management program perspective. (MS-W-1)

Response: The NRC's environmental review focuses on environmental impacts relevant to the

extended period of operation requested by the applicant. Safety matters related to aging are

outside the scope of this review. An NRC safety review for the license renewal period is

conducted separately, and will be documented in an NRC staff Safety Evaluation Report. The

safety review looks at the applicant's aging management programs for passive long-lived

systems, structures and components. The comments provide no new information and will not

be evaluated further in the context of the environmental review. However, the comments will be

forwarded to the project manager for the license renewal safety review for consideration.

NUREG-1437, Supplement 26 A-36 August 2006 1
Appendix A

Part II Comments Received on the Draft SEIS

Pursuant to 10 Code of Federal Regulations (CFR) Part 51, the staff transmitted the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Monticello

Nuclear Generating Plant, Draft Report for Comment (NUREG-1 437, Supplement 26, referred

to as the draft SEIS) to Federal, State, Native American Tribal, local government agencies, and

interested members of the public. As part of the process to solicit public comments on the draft

SEIS, the staff:

* placed a copy of the draft SEIS into the U.S. Nuclear Regulatory Commission's (NRC's)

Public Electronic Reading Room, its license renewal website, and at the Monticello Public

Library, located in Monticello, Minnesota, and at the Buffalo Public Library, located in

Buffalo, Minnesota;

" sent copies of the draft SEIS to the applicant, members of the public who requested copies,

and certain Federal, Native American Tribal, State, and local agencies;

" published a notice of availability of the draft SEIS in the Federal Register on February 2,

2006 (71 Federal Register 5694);

issued public announcements, such as advertisements in local newspapers and postings in'

public places; of the availability of the draft SEIS;

* announced and held two public meetings in Monticello, Minnesota, on March 22, 2006, to

describe the results of the environmental review and answer related questions;

" issued public service announcements and press releases announcing the issuance of the

draft SEIS, the public meetings, and instructions on how to comment on the draft SEIS; and

* established an email address to receive comments on the draft SEIS through the Internet.

During the draft SEIS comment period, the staff received a total of six comment letters and

emails in addition to the comments received during the public meetings. The staff reviewed the

public meeting transcripts and the six comment letters that are part of the docket file for the

application, all of which are available in the NRC's Agencywide Documents Access

Management System (ADAMS). ADAMS is accessible at http://www.nrc.gov.readingrm/adams.html. The ADAMS accession number for the pubic meeting summary, which

includes the complete meeting transcripts, is ML061380004. Appendix A, Part II, Section A.2

contains a summary of the comments and the staff's responses. Appendix A, Part II, Section

A.3 contains copies of the March 22, 2006, public meeting transcripts and comment letters.

August 2006 A-37 NUREG-1437, Supplement 26 1
Appendix A

Each comment identified by the staff was assigned a specific alpha-numeric identifier (marker).

That identifier is typed in the margin of the letter at the beginning of the discussion of the

comment. A cross-reference of the alpha-numeric identifiers, the author of the comment, the

page where the comment can be found, and the section(s) of this report in which the comment

is addressed is provided in Table A-2. The six comment letters are identified by the letters D

through I. The accession number is provided for the written comments after the letter date to

facilitate access to the document through ADAMS.

Table A-2. Comments Received on the Draft SEIS

Comment Commenter Comment Source and ADAMS Accession Page of Section(s)

ID Number Comment Where

Addressed

A-I Todd Afternoon Transcript, ML061380007 A-53

A-2 Todd Afternoon Transcript, ML061380007 A-53

A-3 Todd Afternoon Transcript, ML061380007 A-43

A-4 Todd Afternoon Transcript, ML061380007 A-42

A-5 Todd Afternoon Transcript, ML061380007 A-53

B-i Crocker Evening Transcript, ML061 380008 A-43

B-2 Crocker Evening Transcript, ML061380008 A-47

B-3 Crocker Evening Transcript, ML061380008 A-53

B-4 Crocker Evening Transcript, ML061380008 A-42

C-1 Conway Evening Transcript, ML061380008 A-43

C-2 Conway Evening Transcript, ML061380008 A-46

C-3 Conway Evening Transcript, ML061380008 A-58

C-4 Conway Evening Transcript, ML061380008 A-43

D-1 Lodermener Email, ML061220619 A-59

D-2 Lodermeier Email, ML061220619 A-42

E-1 Rykken Email, ML061220611 A-43

E-2 Rykken Email, ML061220611 A-59

E-3 Rykken Email, ML061220611 A-53

A.2.17

A.2.17

A.2.4

A.2.2

A.2.17

A.2.5

A.2.11

A.2.17

A.2.1

A.2.4

A.2.9

A.2.19

A.2.4

A.2.19

A.2.3

A.2.4

A.2.19

A.2.17

NUREG-1 437, Supplement 26 A-38 August 2006 1
Appendix A

Table A-2. (contd)

Comment Commenter Comment Source and ADAMS Accession Page of Section(s)

ID Number Comment Where

Addressed

F-1 NMC Letter, ML061210175 A-56 A.2.18

F-2 NMC Letter, ML061210175 A-56 A.2.18

F-3 NMC Letter, ML061210175 A-56 A.2.18

F-4 NMC Letter, ML061210175 A-44 A.2.6

F-5 NMC Letter, ML061210175 A-45 A.2.6

F-6 NMC Letter, ML061210175 A-45 A.2.6

F-7 NMC Letter, ML061210175 A-45 A.2.6

F-8 NMC Letter, ML061210175 A-57 A.2.18

F-9 NMC Letter, ML061210175 A-57 A.2.18

F-10 NMC Letter, ML061210175 A-57 A.2.18

F-i1 NMC Letter, ML061210175 A-57 A.2.18

F-12 NMC Letter, ML061210175 A-45 A.2.6

F-13 NMC Letter, ML061210175 A-45 A.2.6

F-14 NMC Letter, ML061210175 A-45 A.2.6

F-15 NMC Letter, ML061210175 A-45 A.2.7

F-16 NMC Letter, ML061210175 A-45 A.2.8

F-17 NMC Letter, ML061210175 A-49 A.2.12

F-18 NMC Letter, ML061210175 A-49 A.2.12

F-19 NMC Letter, ML061210175 A-46 A.2.10

F-20 NMC Letter, ML061210175 A-49 A.2.13

F-21 NMC Letter, ML061210175 A-57 A.2.18

F-22 NMC Letter, ML061210175 A-50 A.2.14

F-23 NMC Letter, ML061210175 A-57 A.2.18

F-24 NMC Letter, ML061210175 A-57 A.2.18

August 2006 A-39 NUREG-1 437, Supplement 26 1
Appendix A

Table A-2. (contd)

Comment Commenter Comment Source and ADAMS Accession Page of

ID Number Comment

Section(s)

F-25 NMC Letter, ML061210175 A-57

F-26 NMC Letter, ML061210175 A-58

F-27 NMC Letter, ML061210175 A-58

F-28 NMC Letter, ML061210175 A-58

F-29 NMC Letter, ML061210175 A-58

F-30 NMC Letter, ML061210175 A-58

F-31 NMC Letter, ML061210175 A-58

G-1 Chezik Letter, ML061320037 A-45

H-1 Westlake Letter, ML061370511 A-49

H-2 Westlake Letter, ML061370511 A-48

H-3 Westlake Letter, ML061370511 A-59

H-4 Westlake Letter, ML061370511 A-50

H-5 Westlake Letter, ML061370511 A-51

H-6 Westlake Letter, ML061370511 A-51

H-7 Westlake Letter, ML061370511. A-51

H-8 Westlake Letter, ML061370511 A-50

H-9 Westlake Letter, ML061370511 A-52

H-10 Westlake Letter, ML061370511 A-52

H-11 Westlake Letter, ML061370511 A-52

H-1 2 Westlake Letter, ML061370511 A-54

H-13 Westlake Letter, ML061370511 A-54

H-14 Westlake Letter, ML061370511 A-55

H-15 Westlake Letter, ML061370511 A-55

H-16 Westlake Letter, ML061370511 A-55

H-17 Westlake Letter, ML061370511 A-56

Where

Addressed

A.2.18

A.2.18

A.2.18

A.2.18

A.2.18

A.2.18

A.2.18

A.2.8

A.2.13

A.2.11

A.2.19

A.2.15

A.2.15

A.2.15

A.2.15

A.2.14

A.2.15

A.2.15

A.2.16

A.2.17

A.2.17

A.2.17

A.2.17

A.2.17

A.2.17

NUREG-1437, Supplement 26 A-40 August 2006 1
Appendix A

Table A-2. (contd)

Comment Commenter Comment Source and ADAMS Accession Page of Section(s)

ID Number Comment Where

Addressed

H-1 8 Westlake Letter, ML061370511 A-56

I-1 Bloomberg Letter, ML061520200 A-44

A.2 Comments and Responses

Comments in this section are grouped in the following categories:

A.2.1 General Comments in Opposition of Nuclear Power

A.2.2 General Comments in Support of Nuclear Power

A.2.3 General Comments in Opposition to License Renewal at Monticello

A.2.4 General Comments in Support of License Renewal at Monticello

A.2.5 Comments Related to License Renewal and Its Processes

A.2.6 Comments.Concerning Water Use and Quality

A.2.7 Comments Concerning Air Quality

A.2.8 Comments Concerning Aquatic Resources

A.2.9 Comments Concerning Terrestrial Resources

A.2.10 Comments Concerning Threatened and Endangered Species

A.2.11 Comments Concerning Human Health Issues

A.2.12 Comments Concerning Socioeconomic Issues

A.2.13 Comments Concerning Cumulative Impacts

A.2.14 Comments Concerning Postulated Accidents

A.2.15 Comments Concerning Uranium Fuel Cycle and Waste Management

A.2.16 Comments Concerning Decommissioning

August 2006 A-41 NUREG-143;

A.2.17

A.2.5

r, Supplement 26 1
Appendix A

A.2.17 Comments Concerning Alternatives

A.2.18 Editorial Comments

A.2.19 Comments Concerning Issues Outside the Scope of License Renewal: Aging

Management and the Independent Spent Fuel Storage Installation (ISFSI)

A.2.1 General Comments in Opposition of Nuclear Power

Comment: That is also behavior, institutional behavior that is typical of failing institutions. And

the real tragedy here is that the technology you are managing is so terribly unforgiving. (B-4)

Response: The comment opposes nuclear power and is general in nature. The comment

provides no new and significant information; therefore, no changes were made to the SEIS text.

A.2.2 General Comments in Support of Nuclear Power

Comment: The other thing I want to talk about is to be able to congratulate the people in

Monticello that had the foresight to allow NSP to build this facility in the first place. Because

myself, I think I was probably a little bit critical at the time that it was being proposed-we really

didn't understand what nuclear energy was all about-where today I'm almost on the other side

that I think we have to expand nuclear energy all over the United States. In fact, I'm thinking we

probably will need at least 500 nuclear plants by this 2030 date, so I can see that you're going

to be a very busy group here trying to get that accomplished. And the reason that I say that is

there is no reason-no way that we can get from a 15-trillion- to 20-trillion-dollar economy in

this country without nuclear power. (A-4)

Response: The comment supports nuclear power and is general in nature. The comment

provides no new and significant information; therefore, no changes were made to the SEIS text.

A.2.3 General Comments in Opposition to License Renewal at Monticello

Comment: I cant belive (sic) Xcel energy, holding people hostage at the end of an extension

cord to get their way. It's no wonder they want to "get this one under the radar screen", the

whole thought scares the living daylights out of me. I say shut 'em down and put up wind

generating towers on the same property! (D-2)

Response: The comment opposes license renewal at Monticello, and is general in nature.

The comment provides no new and significant information; therefore, no changes were made to

the SEIS text.

NUREG-1437, Supplement 26 A-42 August 2006 1
Appendix A

A.2.4 General Comments in Support of License Renewal at Monticello

Comment: I'm here today and I'm going to speak in favor of the Monticello Nuclear Plant being

bxtended, because I believe that if the Monticello plant has to be shut down in 2010, it will have

an adverse effect on central Minnesota. (A-3)

Comment: Nuclear Management Company supports the conclusions contained in the Draft

Supplemental Environmental Impact Statement. The rigorous audits and inspections

conducted by the Nuclear Regulatory Commission have led to a report confirming our own

conclusions that continued operation of the plant will have minimal impact to the environment.

The Draft Impact Statement supports the key elements of our mission at the facility, namely,

the safe, reliable, and economical operation in that order of priority, with safety of the public, our

employees, and the environment being the top priority. We value and expect our organization

to be both a good neighbor and a responsible steward of the environment in which we operate.

Our 500 highly-experienced and well-trained employees take great care in their daily activities

to ensure that the environment is well protected. (C-1)

Comment: In conclusion, the Monticello plant has been a productive contributor to the energy

needs of the State of Minnesota and a valuable asset and gbod neighbor to the surrounding

communities and environment. But we remain committed to operating safely, reliably, and

economically, primarily being focused on being a good neighbor and a good steward of the

environment. As I mentioned previously, it's the safety of the public, our employees, and the

environment that remain our highest priority. I and the rest of Ihe employees at Monticello look

forward to serving the community in that regard for many years to come. (C-4)

Comment: I am in favor of making full utilization of existing nuclear plant by re-licensing. I

have toured this facility personally, albeit before 9/11 security restraints. Their record of error

free operation warrants continued operation for as long as the facility can be safely operated

with prudent maintenance. (E-1)

Response: The comments are supportive of license renewal at Monticello and are general in

nature. The comments provide no new and significant information; therefore, no changes were

made to the SEIS text.

A.2.5 Comments Related to License Renewal and Its Processes

Comment: In my experience environmental impact statements are usually decision-informing

documents. What I've reviewed is a rationalization for a decision thatis already made. I realize

there's nothing I can do or say to make this better, because I don't think you care. So this is

sort of a fool's errand that I'm on; and not really liking being a fool, I'm going to make it short.

Your significance levels-small, moderate, large-appallingly subjective. Rational people

looking at the same facts could come to dramatically different conclusions about what's small,

about what's moderate, about what's large. Small means not detectable, not noticeable? By

whom? Using what? (B-i)

August 2006 A-43 NUREG-1437, Supplement 26 1
Appendix A

Response: Many of the impacts due to an activity are by nature subjective and qualitative; for

example aesthetic impacts. The staff used qualitative measures of impacts where possible.

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

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

consideration of both "context" and "intensity"). 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. Using the CEQ terminology, the NRC established three significance

levels - SMALL, MODERATE, or LARGE. The definitions of the three significance levels are set

forth in the footnotes to Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, as follows:

SMALL-Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE-Environmental effects are sufficient to alter noticeably, but not to destabilize,

important attributes of the resource.

LARGE-Environmental effects are clearly noticeable and are sufficient to destabilize important

attributes of the resource.

For Category 1 issues, the NRC staff assigned a significance level to each environmental issue

analyzed in the Generic Environmental Impact Statement for License Renewal (GELS). The

discussion of each environmental issue in the GElS includes an explanation of how the

significance category was determined. The determination of the significance category was

made independently of the consideration of the potential benefit of additional mitigation.

For Category 2 issues, the uncategorized issues, and the newly identified issues, the NRC will

assign the significance level after an in-depth evaluation.

This comment does not provide new and significant information; therefore, no changes were

made to the SEIS text.

Comment: As you know, you consulted with our office regarding the undertaking in 2005, and

we concluded at that time that no historic properties would be affected. Based on our review of

the information recently submitted, we see no reason to alter that conclusion. (I-1)

Response: This comment does not provide new and significant information; therefore, no

changes were made to the SEIS text.

A.2.6 Comments Concerning Water Use and Quality

Comment: Page 2-4, Line 26: Change "Four" to "Five". (F-4)

NUREG-1437, Supplement 26 A-44 August A 2006 1
Appendix A

Comment: Page 2-7, Line 21: Remove "two of'. NMGP typically runs three service water

pumps in the summer. Plans are to replace service water pumps with higher capacity pumps

so the plant will only have to run 2 out of 3 in the summer. (F-5)

Comment: Page 2-8, Line 9: Change "Four" to "Five". (F-6)

Response: The text in Section 2.1.3 of this SEIS has been changed based on the information

provided in these comments.

Comment: Page 2-8, Line 9: Change "two" to "three". (F-7)

Response: Line 9 on page 2-8 of the draft SEIS does not contain the word 'two." Therefore,

no changes were made to the SEIS text.

Comment: Page 2-16, Line 9: Change "Four" to "Five". (F-12)

Comment: Page 2-16, Line 17: Change 'The other two wells" to 'Two other wells". (F-1 3)

Comment: Page 2-16, Line 18: Add sentence which reads: 'The fifth well, equipped with a

10-gpm pump, provides domestic water to a security training facility". (F-14)

Response: The text in Section 2.2.2 of this SEIS has been changed based on the information

provided in these comments.

A.2.7 Comments Concerning Air Quality

Comment: Page 2-18, Line 24 Replace "EO 008" with "EU 008". (F-1 5)

Response: The text has been changed based on the information provided in this comment.

A.2.8. Comments Concerning Aquatic Resources

Comment: Page 2-22, Line 20-22: Corbicula (sic) have been found in the vicinity of

Monticello, present in the baskets during 316(b) studies. They have also been recently found in

the discharge canal, but none were present in the traveling screen forebays that were recently

dredged. (F-16)

Comment: On page 2-22, line 16, the statement that 'To date, populations of the zebra

mussel within the Mississippi River have not been found above the Twin Cities area (St.

Anthony Falls Lock and Dam) (MNDNR 2005)" is no longer correct. On OctJ 19,'2005, the

MNDNR issued a news release confirming the presence of zebra mussels within Rice La ke, an

.impoundment within the Mississippi River near the City of Brainerd in Crow Wing County.

Brainerd is approximately 94 miles upstream of Monticello. (G-1)

August 2006 A-45 NUREG-1437, Supplement 26 I
Appendix A

Response: The text in Section 2.2.5 of this SEIS has been changed based on the information

provided in these comments.

A.2.9 Comments Concerning Terrestrial Resources

Comment: We feel fortunate that the location of the Monticello plant rests on the banks of the

Mississippi River within close proximity of the Montissippi County Park and the Lake Mariah

State Park. The site is home to a wide variety of wildlife, aquatic species, and plant life. Our

efforts have made the site a safe and sound habitat for many years, and it remains our

commitment to maintaining that for the years to come. (C-2)

Response: This comment is supportive of NMC's management of the existing surrounding

habitat and is general in nature. This comment does not provide new and significant

information;.therefore, no changes were made to the SEIS text.

A.2.10 Comments Concerning Threatened and Endangered Species

Comment: Page 4-43, Line 15: The MOU that Xcel has entered into is with the FWS only, not

the MNDNR. Remove "and MNDNR". (F-19)

Response: The text in Section 4.6.2 of this SEIS has been changed based on the information

provided in this comment.

A.2.11 Comments Concerning Human Health Issues

Comment: Let's just look at how we monitor for radiation releases as an example.

Acknowledging that the radionuclides are released, where do they go? You haven't a clue.

Your monitoring doesn't tell you where they go. Your monitoring says where you don't find

them, but you're not looking for where they are. They're out there. You let them go.

And all you have to define what happens after you release them are some calculations and

some modeling that tell us nothing about where they go. Well, the Bier VII says that there's no

such thing as a safe dose. You acknowledge that you're releasing radionuclides, and it is

absolutely untenable to conclude, with no data and only calculations, that none of them are

inhaled or ingested by humans. You have no scientific basis, no factual basis, no data to

support such a contention. You have calculations and dispersion models, and that's all you

have. Where do they go? So you don't look for where they are, you don't find them, and

therefore it's not detectable, therefore it's small.

You see, quite arguably what this means is that while you're looking at this as a dispersion,

dilution being a solution, what another I would say more rational person could argue is that what

you've created is a very efficient distribution mechanism in which the maximum number of

people can have the opportunity to get enough of it inside of them to cause the cancers. And it

NUREG-1437, Supplement 26 A-46 August 2006 1
Appendix A

turns out that we don't have the cancer registries on a county-by-county basis to really allow us

to come to those conclusions because of the way they're compared. But if you look at it the

way it could be, you will see elevated concentrations of particulate cancers in communities that

are in close proximity to the reactors. But you don't look at that, so it's small. Small compared

to what? Small compared to background?

Well, you see some of us now finally understand the difference between background radiation

and the insult when the radiation is ingested or inhaled. Entirely different things. Background is

background. Why do you think your thigh bones are so big? It's to keep the background out.

But once it's inside of you each radionuclide becomes very, very efficient at causing the

destruction that ultimately leads to the cancer. Small. No facts. Conjecture. Subjective. (B-2)

Response: The amounts of radioactive isotopes released from Monticello in liquid and

gaseous effluents are constantly monitored and recorded by NMC. The meteorological

conditions at the site are also constantly monitored and recorded. NRC health physics experts

routinely inspect these monitoring programs to ensure that they are being properly conducted.

All of this information is fed into calculational models that estimate the amount of radiation dose

a member of the public might receive. The calculational models are in the ODCM and have

been reviewed and approved by the NRC. These models include estimates of dose from

internally deposited radioactive isotopes as well as direct radiation exposure. In addition, NMC

conducts an environmental radiological monitoring program in the area around Monticello. The

program samples and measures the amount of radioactive isotopes in the air, water, soil, and

agricultural products and measures direct radiation from the plant. This program confirms that

the levels of radioactive isotopes in the environment that are predicted by the computer dose

models. The State of Minnesota also conducts an environmental radiological monitoring

program around Monticello that confirms the results of NMC's program. These programs show

that the radiation doses to members of the public from operation of Monticello are very low, well

within the limits set by NRC and EPA, and very small compared the dose from natural

background sources of radiation.

In spring 2006, the National Research Council of the National Academies published, "Health

Risks from Exposure to Low Levels of Ionizing Radiation, BEIR VII Phase 2." A pre-publication

version of the report was made public in June 2005. The major conclusion of the report is that

current scientific evidence is consistent with the hypothesis that there is a linear, no-threshold

dose response relationship between exposure to ionizing radiation and the development of

cancer in humans. This conclusion is consistent with the system of radiological protection that

*the NRC uses to develop its regulations. Therefore, the NRC`S regulations continue to be

adequately protective of public health and safety and the environment. None of the findings in

the BEIR VII report warrant changes to the NRC regulations. The BEIR VII,1 report does not say

there is no safe level of exposure to radiation; it does not address "safe versus not safe" It

does continue to support the conclusion that there is some amount of cancer risk associated

with any amount of radiation exposure and that risk increases with exposure and exposure rate.

It does also conclude that risk of cancer induction at the dose levels in NRC's and EPA's

radiation standards is very small. Similar conclusions have been made in all of the associated

August 2006 A-47 NUREG-1437, Supplement 26 I
Appendix A

BEIR reports since 1972 (BEIR I, Ill, and V); the BEIR VII report does not constitute new and

significant information. The comment provides no new and significant information; therefore, no

changes were made to the SEIS text.

Comment: We are concerned about the abnormal releases mentioned in the Draft SEIS. The

Draft SEIS references abnormal releases of fission and activation products and tritium during

the period from 2001 to 2004 (page 2-9). This is the only place these releases are discussed in

the document, and their mention raises questions that are not addressed. Information on the

abnormal releases is unclear. For example, it is not clear whether there was one releases

event or more, or where the event occurred. In addition, while the concentration of the

release(s) is given, readers are referred elsewhere in the document and regulations to

determine for themselves whether this is within effluent limits or how this impacts the public or

the environment. This section implies that occasional abnormal releases are expected during

the renewal period. The Final SEIS needs to explain the past and future expected frequency of

these releases. Finally, the Draft SEIS also claims that if future abnormal release occur, they

will be below design dose objectives. It is not clear how this statement could be supported for

hypothetical incidents. We also note that abnormal releases are not discussed in sections on

radiological impacts or water quality, presuming that these abnormal releases were issued to a

water body.

With the GElS approach, NRC generally does not include an analysis of impacts where staff.

reviewers have not found .new or significant information. We believe that past abnormal

releases, and the potential for future abnormal releases, qualify as new and significant

information: We therefore recommend that the subsequent Final SEIS discuss the abnormal

releases fully and in context to the environmental impacts-analyses. We recommend including

a discussion of past or potential future releases and steps to prevent releases. Specifically, the

Final SEIS needs to explain the number of releases and where releases occurred (i.e., describe

whether the release was effluent into the Mississippi River, an on-site spill, or some other

release). It should clarify how abnormal releases are difference from liquid effluent releases, if

this is the case. We recommend that where concentrations are mentioned, the document place

these concentrations in context by giving effluent limits, dose limits, or other relevant

measurements. We also recommend that abnormal releases be discussed in Chapter 4.0

Environmental Impacts of Operation. (H-2)

Response: The releases that occurred between 2001 and 2004 are listed as "abnormal"by

NMC because Monticello is a "zero-liquid-release facility," which means that the goal of NMC is

to have zero liquid radioactive discharges to the Mississippi River. Although NMC's goal is

zero-liquid release, under the terms of its operating license, NMC is allowed by NRC regulations

to periodically release liquid effluents to the Mississippi River, provided that the releases are

below regulatory limits. Future releases of tritium, as well as other isotopes, are possible during

the renewal period. The releases that were mentioned in Section 2.1.4.1 of the draft SEIS were

monitored, and the concentrations of all liquid releases were well below regulatory limits. The

text in Section 2.1.4.1 of this SEIS has been clarified to reflect the above information.

NUREG-1437, Supplement 26 A-48 August 2006 1
Appendix A

A.2.12 Comments Concerning Socioeconomic Issues

Comment: Page 4-32, Line 8: Add "In the bounding analysis, Monticello assumes..." This

should eliminate any confusion with 4-31, line 25. (F-17)

Response: The text in Section 4.4.2 of this SEIS has been changed based on the information

provided in this comment.

Comment: Page 4-35, Line 27: Change "procedures that will be in place" to "procedures that

are in place". (F-1 8)

Response: The text in Section 4.4.5 of this SEIS has been changed based on the information

provided in this comment.

A.2.13 Comments Concerning Cumulative Impacts

Comment: Page 4-48, Line 16-17: Change sentence to read: 'Three other wells have an

annual usage of under 1.9 gpm and do not require appropriations permits." (See page 2-16)

(F-20)

Response: The text in Section 4.8.5 of this SEIS has been changed based on the information

provided in this comment.

Comment: We are concerned that the Draft SEIS does not discuss potential power uprates at

Monticello or estimate resulting increases in radiological emissions, spent fuel, and other

emissions. We recognize that NRC's regulations (10 C.F.R Section 51.53(c)(2)) state that an

applicant's environmental report need not discuss the demand for power, and we are not asking

for an assessment of need. Separate from purpose and need, we consider power uprates to be

reasonably foreseeable actions that contribute to a cumulative radiological impact, under 40

C.F.R Section 1508.7, and therefore should be discussed in NRC's final SEIS. (H-i)

Response: The Commission has stated that for NEPA purposes, a possible future action

"must at least constitute a proposal pending before the agency" for it to be considered along

with the proposed action, which here is license renewal. The Commission's decision was set

forth in the following case: Duke Energy Corp. (McGuire Nuclear Station, Units 1 and 2;

Catawba Nuclear Station, Units 1 and 2) CLI-02-14, 55 NRC 278,294-297 (2002). Since NMC

does not at this time have a proposal pending before the NRC that relates to a power uprate for

Monticello, the SEIS does not address future power uprates in the evaluation of the impacts of

license renewal on individual issues or on cumulative impacts. In addition, the Commission in

the aforementioned case stated that, for the license renewal action and a separate proposal

(such as a power uprate application) to be considered together, both actions must be

"interdependent," such that one cannot go forward without the other. -License renewal does not

depend on a power uprate, and a power uprate does not depend on license renewal; each

action has separate utility. Should a power uprate amendment for Monticello be filed, the staff

August 2006 A-49 NUREG-1 437, Supplement 26
Appendix A

would be required to conduct an environmental assessment and would consider whether there

are cumulative impacts associated with the power uprate.

A.2.14 Comments Concerning Postulated Accidents

Comment: Page 5-5 & 5-7, Lines 32-34 and 1-14: Replace this text with the text in Appendix

G on page G-3, lines 16-31 and page G-4, lines 1-17. The information is correct in Appendix G

but not in Chapter 5. Specifically, the distinction between "early" and "late" releases is based

on the delay between declaration of general emergency and containment failure, not between

accident initiation and containment failure. (F-22)

Response: The discussion of timing of releases in Section 5.2.2 of the SEIS has been

changed based on the information provided in this comment. The detailed discussions noted in

the comment have not been moved, since Chapter 5 is intended to be a brief summary of the

staff's analyses discussed in Appendix G.

Comment: Section 5.2.2, Estimate of Risk, page 5-6. The Draft SEIS states that the baseline

core damage frequency (CDF) for the purpose of the severe accident mitigation alternatives

(SAMA) is approximately 4.5 x 10`5 per year. This CDF is based on the risk assessment for

internally-initiated events. The Draft SEIS does not include the contribution to risk from external

events with the Monticello risk estimates; however it does account for the potential risk

reduction benefits associated with external events by increasing the estimated benefits for

internal events by a factor of two. The estimates for risks from both areas should be evaluated

and presented along with a rationale for not basing risk decisions on the external events or

including them in the considerations as necessary to get an accurate portrayal of the risk of the

licensing renewal. (H-8)

Response: Risk estimates for both internal and external events are presented and discussed

in Section G.2 of Appendix G of the SEIS. The risk from external events at Monticello is much

lower than from internal events (e.g., 7.8 x 106 per year for fire events compared to 4.5 x 1015

per year for internal events). Nevertheless, potential SAMAs to further reduce external event

risk were explored as part of the SAMA evaluation (see Sections G.2.2 and G.3.2.). As

described in Section G.6.2, the risk associated with external events was specifically accounted

for in the risk calculations that were used to support the decision regarding potentially costbeneficial SAMAs at Monticello. The comment provides no new and significant information;

therefore, no changes were made to the SElS text.

A.2.15 Comments Concerning the Uranium Fuel Cycle and Waste Management

Comment: Section 2.1.4.2, Gaseous Waste Processing Systems and Effluent Controls, page

2-10, first paragraph. Citations of dose values should also include the dose value, in addition to

just the citation, to make the values clearer. (H-4)

NUREG-1437, Supplement 26 A-50 August 2006 1
Appendix A

Response: As described at the end of Section 2.1.4.2, the reader is referred to Section 2.2.7

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

releases. Section 2.2.7 provides the Appendix I design objectives which include the

requirement not to exceed 3 mrem/year maximum whole body dose from liquid effluents and 5

mrem/year maximum whole body dose from gaseous effluents. The comment provides no new

and significant information; therefore, no changes were made to the SEIS text.

Comment: Section 2.1.4.2, Gaseous Waste Processing Systems and Effluent Controls, page

2-10, third paragraph. The total curie values provided do not add up to the total curie emissions

stated. Please correct or clarify this discrepancy. (H-5)

Response: Section 2.1.4.2 of this SEIS has been revised to clarify the quantities of airborne

releases.

Comment: Section 2.2.7, Radiological Impacts, pages 2-29, 2-30, last paragraph. The

references to the environmental standards need to be complete citations including title of the

rule or regulation, along with the basic standard for comparison provided consistently. All of the

environmental standard that could be used for a comparison should be used, including 40 CFR

61 Radionuclide National Emission Standards for Hazardous Air Pollutants values. This will

reduce the time needed to look up these citations and verify values that are cited in the text.

• (H-6)

Response:• As stated in Section 2.2.7, 'The limits for all radiological releases are specified in

the Monticello ODCM (NMC 2004b), and these limits are used to meet Federal standards and

requirements." The primary radiological standards applicable to Monticello are contained in

10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 50, Appendix I. The complete citation for

each of the environmental standards referenced in the text is provided in the references for

Chapters 2 (Section 2.3) and 4 (Section 4.10). These standards are readily accessible on the

Internet to members of the public. Text in 2.2.7 has been modified to refer to the basic

standard for comparison (a 25-mrem total annual dose).

Regarding the comment to include 40 CFR 61, the EPA rescinded Subpart I as it applies to

power reactors on September 5, 1995 (60 FR 46206), because 'the regulatory program

established by the NRC pursuant to the Atomic Energy Act provides an ample margin of safety

to protect the public health." The comment provides no new and significant information;

therefore, no changes were made to the SEIS text.

Comment: Section 4.3, Radiological Impacts of Normal Operations, page 4-27, 4-28, Table

4-7, and paragraph 1 on 4-28. The specific values for exposure need to be provided in addition

to the complete citation of the location of this information. This will help to provide the

information better and be less confusing than a citation only, that then must be referred to allow

verification of the standard being cited. (H-7)

August 2006 A-51 NUREG-1437, Supplement 26 I
Appendix A

Response: Radiological impacts of normal operations were considered and evaluated in the

GEIS and the staff concluded that these impacts were small. In this SEIS, issued as a

supplement to the GELS, the staff determined whether any new and significant information is

available that would change the conclusion reached in the GElS (i.e., that these impacts would

be small). No such new and significant information was identified. The comment does not

provide any new and significant information; therefore, no changes were made to the SEIS text.

Comment: Section 6.1, The Uranium Fuel Cycle, page 6-3. Under the bullet point for Off-site

radiological impacts (individual effects from other than disposal of spent fuel and high level

waste disposal), no consideration appears to be given to the potential long term storage of the

spent fuel and high level waste materials on site until such time as a permanent facility is finally

licensed and begins to accept these materials for disposal. A reference to other sections that

this evaluation may have been included in should be provided here as well as in other sections,

or if this evaluation has not been adequately conducted, the issue needs to be considered and

an appropriate evaluation conducted. (H-9)

Comment: Section 6.1, The Uranium Fuel Cycle, page 6-8, under the bullet point for On-site

Spent Fuel. A more thorough evaluation for the volume of spent fuel expected to be generated

during the additional licensed time needs to be provided along with more specific information as

to site specific circumstances that may impair or improve the risk values for potential exposures

to this spent fuel storage. (H-1 0)

Response: Onsite storage of spent nuclear fuel is a Category-1 issue. The safety and

environmental effects of long-term storage of spent fuel onsite have been evaluated by the

NRC and, as set forth in the Waste Confidence Rule at 10 CFR 51.23 (available at

htt:I//www.nrc.qov/readinq-rm/doc-collections/cfr/partO51/part051-0O23.html), the NRC

generically determined that "..if necessary, spent fuel generated in any reactor can be stored

safely and without significant environmental impacts for at least 30 years beyond the licensed

life for operation (which may include the term of a revised or renewed license) of that reactor at

its spent fuel storage basin or at either onsite or offsite independent spent fuel storage

installations. Further, the Commission believes there is reasonable assurance that at least one

mined geologic repository will be available within the first quarter of the twenty-first century and

sufficient repository capacity will be available within 30 years beyond the licensed life for

operation of any reactor to dispose of the commercial high-level waste and spent fuel

originating in any such reactor and generated up to that time." Section 6.1 provides the

information available regarding the status of the application for a high-level waste repository.

The comment provides no new and significant information; therefore, no changes were made to

the SEIS text.

A.2.16 Comments Concerning Decommissioning

Comment: Section 7.1, Decommissioning, page 7-2, under bullet point Radiation Doses. As

the GElS is based on a forty-year licensing period, an extension of this period would have an

impact that we suggest needs to be quantified and reported. We recommend including this

NUREG-1437, Supplement 26 A-52 August 2006 1
Appendix A

information in the Final SEIS as part of the risk that would be associated with the license

extensions and providing the specific methodology used to estimate risk. (H-1 1)

Response: Environmental impacts from the activities associated with the decommissioning of

any reactor before or at the end of an initial or renewed license are evaluated in the GElS

(NUREG-1437) and in NUREG-0586 Generic Environmental Impact Statement for

Decommissioning Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear

Power Reactors, published in 2002. The findings from these two documents are used to

support the findings in the SEIS by the use of tiering. Tiering is a process by which agencies

eliminate repetitive discussions. The effects of license renewal on the impacts of

decommissioning are stated in Chapter 7 of this SEIS. The radiation doses to the public during

the period of extended operation are expected to be well below applicable regulatory limits, and

the occupational dose during the time the station undergoes decommissioning would be

expected to increase only slightly. The comment provides no new and significant information;

therefore, no changes were made to the SEIS text.

A.2.17 Comments Concerning Alternatives

Comment: My question is would the statement have been changed at all if you hadn't used

natural gas or oil in your analysis? (A-i)

Comment: Just basically if you hadn't used it, I think that the impact of this facility being shut

downwould have been much greater in your analysis if you couldn't use natural gas or oil. You

-pretty well explained the wind and solar. (A-2)

Comment: And then, finally, I think that I want to explain a little bit on the natural gas and oil

question that I had, because I feel that with using that in Minnesota, it puts us at a

disadvantage, because this last winter our natural gas costs went up 30 percent-and not

necessarily because of the gas-fired plants that have already been built around the country,

Katrina definitely caused some problems with it, but it's just not a good source for generating

electricity in Minnesota. (A-5)

Comment: Minnesota's power supply cannot be replaced by conservation and renewables

alone; forcing migration to natural gas for base-load power generation is a short-sighted

squandering of a very limited resource. (E-3)

Comment: Wind, 30 percent capacity factor? I don't think so. Go look at the Minnesota

Department of Commerce website for their wind maps and see what kind of capacity factors

they come up with.

When you have a decision-making process like this one in which there is not even attempt to

make a reasonable simulation of 600 megawatts of baseload to compare it with and then come

to the conclusion that alternatives such as wind have moderate to large impacts while a reactor

August 2006 A-53 NUREG-1437, Supplement 26 I
Appendix A

that creates waste that must be managed for 240,000 plus years with routine emissions that

aren't managed and that's small, you're sick. That is sickness. (B-3)

Response: The SEIS for Monticello presents the staff's analyses of the environmental impacts

of the proposed action (i.e., renewal of the operating license for Monticello) and of reasonable

alternatives. The decision regarding which type of generation to deploy is made by the

applicant and State agencies, not the NRC. Additionally, the staff's evaluation of wind capacity

factors in Minnesota identified capacity ranges from 15.8 percent to 44.8 percent (average

capacity of 30.2 percent); therefore, the SEIS's projections of wind power generating capacity,

as well as the U.S. Department of Energy's Energy Information Administration's capacity

projections in the Mid-Continent Area Power Pool (MAPP), which includes Minnesota, is

consistent with the capacities Identified by the Minnesota Department of Commerce. The staff

conducted a qualitative assessment of impact due to the construction and operation of a wind'

farm and concluded that wind power alone is not a feasible alternative at this time to replace

the baseload generation capacity of Monticello. The comment provides no new and significant

information, therefore, no change was made to the SEIS text.

Comment: Section 8.1, No-Action Altemative, page 8-4, 8-5, under the bullet point Human

Health. The actual value representing the cited percent value should be specifically provided in

addition to the citation. This will help to reduce unnecessary additional research, except for

value verifications, and avoid potential misunderstandings or confusion about the actual

value(s). (H-12)

Response: .1The staff conducted a qualitative assessment of impact resulting from the no action

alternative (permanent cessation of operations followed by decommissioning). A detailed

evaluation of radiological consequences of decommissioning is provided in the Generic

Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the

Decommissioning of Nuclear Power Reactors (NUREG-0586), November 2002; and is available

on the NRC's website. As a supplement, this SEIS relies on tiering or incorporation by

reference, from other NRC generic evaluations or publicly available documents consistent with

CEQ guidelines. The conclusion presented in the SEIS is based on the logical argument that

cessation of operations at Monticello would result in a reduction in radioactive emissions, since

the operations producing those emissions would cease. Since the radiological impacts of

normal operations were determined to be SMALL (as discussed in Section 4.3), the impact of

the no-action alternative, which would result in the cessation of those operations, would

logically be even less, and therefore, also SMALL. The comment does not provide new and

significant information and, therefore, will not be evaluated further.

* Comment: Section 8.2.1, Coal-Fired Generation, page 8-16, under bullet point Human Health.

Any dose estimate that would have the potential to fall is the risk range of 106 to 10 4 or greater

needs to be specifically evaluated for potential regulatory requirements or risk impacts to the

public health. This should be estimated conservatively using the data that is currently available

or that can be logically extrapolated from currently available information. (H-13)

NUREG-1 437, Supplement 26 A-54 AAugust 2006 1
Appendix A

Response: The impacts to air quality and human health resulting from the operation of a coalfired plant are discussed in general in the GElS (NUREG-1437). The GElS acknowledges

public health risks from emphysema and cancer would likely result from coal-fired power plant

emissions of regulated pollutants and radionuclides. While it is possible to estimate the dose

from a coal-fired plant, many assumptions would be required, including location and makeup of

the affected population. 'F-or the basis of comparing alternatives, the staff does not perform a

complete assessment of impacts of each alternative, but rather a qualitative, and, if possible, a

quantitative comparison. Because the location of an alternative to the Monticello and

surrounding population is purely speculative, an estimated dose would have little real meaning.

The comment provides no new and significant information; therefore, no changes were made to

this SEIS.

Comment: Section 8.2.3, Coal Gasification, page 8-32, under bullet point Waste. We

recommend specifically describing waste impacts, rather than making reference to them, to

provide a clearer understanding of the risk determination made in this section of the document.

(H-14)

Response: For the basis of comparing alternatives, the staff does not perform a complete

assessment of impacts of the alternatives, but rather a qualitative, and, if possible, a

quantitative comparison. For the analysis of coal-gasification waste, the staff did provide an

estimate of the projected waste streams. This comment does not provide new and significant

information; therefore, no changes were made to this SEIS.

.Comment: Section 8.2.3, Coal Gasification, page 8-32, 8-33, under bullet point Human Health.

We recommend specifically describing human-health impacts, rather than making reference to

them, to provide a clearer understanding of the risk determination made in this section of the

document. (H-15)

Response: For the basis of comparing alternatives, the staff does not perform a complete

assessment of impacts of the alternatives, but rather a qualitative, and, if possible, a

quantitative comparison. The staff did-provide a qualitative assessment of human health

impacts, which is characterized as small (see Table A-4). The comment provides no new and

significant information; therefore, no changes were made to the SEIS text.

Comment: Section 8.2.4, Nuclear Power Generation, page 8-36. We recommend specifically

describing the differences in potential risk-associated with changes in power production, rather

than making reference to them, to provide-a clearer understanding of the risk determination

made in this section of the document. (H-1 6)

Response: As stated in Section 8.2.4, the impacts shown in Table S-3 (of 10 CFR 51.51) are

for a 1000-MW(e) reactor and would need to be adjusted to reflect the replacement of 600-

MW(e) generated by Monticello. For the basis of comparing alternatives, the NRC staff

assumes that a hypothetical plant would produce the same amount of power currently

generated by Monticello. Therefore, the risk associated with this hypothetical plant is not

August 2006 A-55 NUREG-1437, Supplement 26 1
Appendix A

expected to exceed that of the current plant at Monticello. The comment provides no new and

significant information; therefore, no changes were made to the SEIS text.

Comment: Section 8.2.4.1, Closed-Cycle Cooling System, page 8-40, under bullet point

Waste. We recommend specifically describing waste impacts, rather that making reference to

them, to provide a clearer understanding of the risk determination made in this section of the

document. (H-17)

Comment: Section 8.2.4.1, Closed-Cycle Cooling System, page 8-40, under bullet point

Human Health. Human-health impacts needed to be specified rather than merely referenced to

provide a clearer understanding of the risk determination in this section of the document.

(H-18)

Response: As a supplement, this SEIS relies on tiering from the GElS and does not need to

repeat all analysis and conclusions presented in the GELS. The SEIS relies to a great degree

on impact analyses presented in the GElS (NUREG- 1437) by the use of a process called

tiering. Tiering was promulgated by the Council on Environmental Quality in 1978 in 40 CFR

Part 1502.20. Appropriate sections of the GElS are referenced, when necessary. Human

health impacts are presented in 10 CFR Part 51, Appendix B, Table B-1. For ease of review,

this table can be found at http://www.nrc.gov/reading-rm/doc-collections/cfr/partO5l/partO5l-

.appb.html. More detailed information on this topic can be found in Volumes 1 and 2 of the

GELS, which are available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staffl

sr1437/vl and http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/v2,

-respectively. The comments do hot provide any new and significant information; therefore, no

changes were made tothe SEIS text.

A.2.18 Editorial Comments

Comment: Page 1-1, Line 18: Change ,southern" to "central". (Appears this way in ER, page

2-36). (F-1)

Response: The text in Section 1.0 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page 1-7, Line 10: Change "southeastern" to "central". (Appears this way in ER,

page 2-36). (F-2)

Response: The text in Section 1.3 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page 2-1, Line 13: Change "southeastern" to "central". (Appears this way in ER,

page 2-36). (F-3)

NUREG-1437, Supplement 26 A-56 August 2006 1
Appendix A

Response: The text in Section 2.1 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page 2-9, Line 19: Add "re-use" after "treatment" since the water is continually reused. (F-8)

Response: The text in Section 2. 1.4.1 of the SEIS has been changed based on the

information provided in this comment.

Comment: Page 2-10, Line 3: Insert period at end of sentence. (F-9)

Response: The text in Section 2.1.4.1 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page 2-11, Line 35: Change to "nominal 22-24 month fuel cycle" to be consistent

with page 2-30, line 30. (F-10)

Response: The text in Section 2.1.6 of the SEIS has been changed based on the information

provided in this comment

Comment: Page 2-12, Line 28: Correct name is "Parkers Lake". (F-1 1)

Response: The text in Section 2.1:7 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page 4-48, Line 27 & 30: Change to Minnesota counties of Wright and

Sherburne." Change "Shelburne" to "Sherburne". (F-21)

Response: The text in Section 4.8.6 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page 8-40, Line 4: Change "four" to "five". (F-23)

Comment: Page 8-42, Line 4: Change "units" to "plant" for consistency with rest of discussion.

(F-24).

Response: The text in Section 8.2.4.1 of the SEIS has been changed based on the

information provided in these comments.

Comment: Page 8-44, Line 14: Change '25 percent" to "14 percent". The same footnote can

be used. For verification, see NSP 2004 IRP, Appendix D, Table 7610.0310, item B, 2004 data.

(F-25)

August 2006 A-57 NUREG-1437, Supplement 26 I
Appendix A

Response: The text in Section 8.2.5 of the SEIS has been changed based on the information

provided in this comment.

Comment: Page E-2, Line 4: The US Fish and Wildlife Service Migratory Bird Treaty Act

Permit was reissued on 04/01/2006. Authorization information is as follows: Number

MB074020-0, Expiration Date: 03/31/09. (F-26)

Comment: Page E-2, Line 10: The MNDNR Division of Fish and Wildlife Special Permit was

reissued on 11/21/2005. Authorization information is as follows: Number 13315, Expiration

Date: 12/31/06. (F-27)

Comment: Page E-4, Line 24: Remove "NYDSEC: New York State Department of

Environmental Conservation"--not relevant to discussion. (F-28)

Comment: Page E-4, Line 3: The South Caroline Radioactive Waste Transport Permit was

reissued for 2006. Authorization information is as follows: Number 0026-22-06-Y, Expiration

Date: 12/31/06. (F-29)

Comment: Page E-4, Line 8: The Tennessee Radioactive Shipment License was reissued for

2006. Authorization information is as follows: Number T-MN-002-L06, Expiration Date:

12/31/06. (F-30)

Response: The text in Appendix E of the SEIS has been changed based on the information

provided in these comments.

Comment: Page G-23, Line 18: Replace "$1.1 x1 09" with "$1.1 x 109." (F-31)

Response: The text in Appendix G of the SEIS has been changed based on the information

provided in this comment.

A.2.19 Comments Concerning Issues Outside the Scope of License Renewal: Aging

Management and Independent Spent Fuel Storage Installation (ISFSI)

Aginq Management

Comment: The Monticello plant has been extremely well maintained over its lifetime, ensuring

it can operate safely for at least an additional twenty years beyond the original operating license

period. Approximately every two years, we perform a refueling and major maintenance outage

in which we typically carry out over 2500 individual maintenance and inspection activities. This

is in addition to the ongoing maintenance, inspection, and rigorous testing activities that are

performed routinely during the period of plant operation.

We have continued to invest in a wide range of equipment improvements to take advantage of

technology and materials to ensure future reliable and safe operation, and this is relevant to the

NUREG-1437, Supplement 26 A-58 August 2006 I
Appendix A

aging management aspects of the license renewal process. As we move forward, we will

continue to upgrade and improve the equipment, the technology, and the training to the

employees of the station. (C-3)

Response: Comments regarding aging management issues are outside the scope of license

renewal and provide no new information; therefore, no changes were made to the SEIS.

Independent Spent Fuel Storage Installation (ISFSI)

Comment: Are you folks crazy, or do you think storing nuclear waste next to one of the largest

freshwater rivers in the world is a good idea. (D-1)

Comment: We are aware that there was a proposal before the Minnesota Environmental

Quality Board for dry cask storage facility for spent nuclear fuel at Monticello. We note that the

Environmental Impacts section of the Draft SEIS does not discuss the potential impacts

associated with adding this type of spent fuel storage facility to the existing operation. We

suggest that a new dry cask storage facility constitutes a new set of circumstances for this site

and should be evaluated in greater detail for additional impacts to the environment. (H-3)

Comment: The Federal Government's failure to site a nuclear waste repository should not be

cause to close a functional, and large capital cost, generation plant before its' time. (E-2)

Response: Onsite storage facilities are licensed separately from the reactor license renewal

process. The NRC authorizes storage of spent nuclear fuel at an independent spent fuel

storage installation (ISFSI) under two licensing options: a site-specific license or a general

license.

A general license authorizes a nuclear power plant licensee to store spent fuel in NRCapproved casks at an existing site that is licensed for operating of a power reactor under 10

CFR Part 50. An NRC-approved cask is one that has undergone a technical review of its safety

aspects and been found to meet all of the NRC's requirements in 10 CFR Part 72. The NRC

issues a Certificate of Compliance for a cask design to a cask vendor after a rulemaking

determines its adequacy. Licensees are required to perform evaluations of their sites to

demonstrate that the site is adequate for storing spent fuel in dry casks. These evaluations

must show that the cask Certificate of Compliance conditions and technical specifications can

be met. The licensee must also review its security program, emergency plan, quality assurance

program, training program, and radiation protection program, and make any necessary changes

to incorporate the ISFSl at its reactor site.

The safety and environmental effects of long-term storage of spent fuel onsite have been

evaluated by the NRC and, as set forth in the Waste Confidence Rule at 10 CFR 51.23

(available at http://www.nrc.qov/reading-rm/doc-collections/cfr/partO51/artO5. -0023.html), the

NRC generically determined that "J..if necessary, spent fuel generated in any reactor can be

stored safely and without significant environmental impacts for at least 30 years beyond the

August 2006 A-59 NUREG-1437, Supplement 26 1
Appendix A

licensed life for operation (which may include the term of a revised or renewed license) of that

reactor at its spent fuel storage. basin or at either onsite or offsite independent spent fuel

storage installations. Further, the Commission believes there is reasonable assurance that at

least one mined geologic repository will be available within the first quarter of the twenty-first

century and sufficient repository capacity will be available within 30 years beyond the licensed

life for operation of any reactor to dispose of the commercial high-level waste and spent fuel

originating in any such reactor and generated up to that time." Section 6.1 provides the most

current information available regarding the status of the application for a high-level waste

repository.

Comments regarding Xcel Energy's Certificate of Need application currently before the Public

Utilities Commission to establish an independent spent fuel storage installation at the Monticello

site are outside of the scope of license renewal. The comments provide no new and significant

information related to any Category 1 or Category 2 issue, and therefore, will not be evaluated

further.

A.3 Public Meeting Transcript Excerpts and Comment Letters

A.3.1 Transcript of the Afternoon Public Meeting on March 22, 2006, in

Monticello, Minnesota

[Introduction by Chip Cameron]

[Presentation by Rani Franovich]

[Presentation by Crystal Quinly]

A-1 PURVES TODD: My question is would the statement have been changed at all if you hadn't

used natural gas or oil in your-analysis?

CHIP CAMERON: Sir, what was your-your name is?

PURVES TODD: Purves Todd

CHIP CAMERON: Purves-this is Purves Todd. Thank you. Thank you very much, Mr. Todd.

Crystal?

CRYSTAL QUINLY: Actually, we did look-in the alternativesPURVES TODD: Yes, I saw you had natural gas and oil in there.

CRYSTAL QUINLY: We did look at those, yes.

PURVES TODD: But if you hadn't used thoseCHIP CAMERON: We'll have to get you on the microphone, Mr. Todd.

NUREG-1437, Supplement 26 A-60 August 2006 1
Appendix A

A-2 PURVES TODD: Just basically if you hadn't used it, I think that the impact of this facility being

shut down would have been much greater in your analysis if you couldn't use natural gas or oil.

You pretty well explained the wind and solar.

CRYSTAL QUINLY: Right.

CHIP CAMERON: Except we did look at natural gas and oil.

CRYSTAL QUINLY: Yeah, we did look at both of those and including coal gasification.

PURVES TODD: As alternatives.

CHIP CAMERON: And I think Mr. Todd's point-he's making a point aboutCRYSTAL QUINLY: Okay.

PURVES TODD: I'll be talking later.

CHIP CAMERON: Yeah. Okay. Good. All right. Anybody else?

(No response.)

And now we have Bob Palla, who's going to talk about something called "SAMAs," which are

severe accident mitigation alternatives. Bob Palla.

[Presentation by Robert Palla]

CHIP CAMERON: Okay. Thank you, Bob. Any questions about the severe accident mitigation

alternatives that Bob was talking about?

(No response.)

Okay. Thanks, Bob. And, finally, we're going to go Jennifer for-Jennifer Davis for information

on how comments can be submitted. Jennifer?

JENNIFER DAVIS: Turning now to our preliminary conclusions, we found that the impacts of

license renewal are small in all areas. We have also preliminarily concluded that the impacts of

alternatives, including the no-action alternative, may have moderate to large environmental

effects in some impact categories. Based on these results, it is the staff's preliminary

recommendation that the adverse environmental impacts of license renewal for Monticello' are

not so great that preserving the option of license renewal for energy planning decisionmakers

would be unreasonable.

August 2006 A-61 NUREG-1437, Supplement 26 1
Appendix A

This slide is just a quick recap of some milestone dates. We issued the Draft Environmental

Impact Statement for Monticello on January 23rd, 2006. We are currently in the middle of the

public comment period, and that is scheduled to end on May 4th of this year.

We will address any public comments received and make any necessary revisions to the Draft

Environmental.Impact Statement and issue a Final Environmental Impact Statement in

September of 2006.

This slide identifies me as your primary point of contact with the NRC for the Environmental

Review. It also identifies what documents related to our review may be found in the local area.

The Monticello Draft EIS is available publicly at the Monticello Public Library and the Buffalo

Public Library.

Additionally, documents related to the review are also available on NRC's website at

www.NRC.qov. In addition, as you came in you were asked to fill out a registration card. If you

have included your address on that card, we will mail a copy of the Final EIS to you.

If you did not receive a copy of the Draft Environmental Impact Statement, we have copies

available in the back of the room. If you did not fill out a card and you want a copy of the final

EIS and have not yet filled in a card, please see Jason.

Jason, please raise your hand. Thank you.

Now, in addition to providing us comments at this meeting, there are other ways you can submit

comments for our Environmental Review process. You can provide written comments to the

Chief of the Rules and Directives Branch at the address on the screen. You can also make

comments in person if you happen to be in the Rockville, Maryland, area. Or we have

established a specific e-mail address at the NRC for the purpose of receiving your comments

on the Draft EIS, and that e-mail address is MonticelloEIS@NRC.gov. All relevant addresses

are listed in your handout. All of your comments will be collected and considered.

This concludes my remarks, and I'd like to thank each and every one of you for coming out

today.

CHIP CAMERON: Great. Thanks, Jennifer. Is it clear how to submit comments? Anybody

have any questions on that?

(No response.)

Okay. Great. And now we're going to go into listening to any comments that you have. And

our first speaker is Mr. Purves Todd, who we have heard from, and I think he's going to explain

a little further the implications of his question on alternatives.

Mr. Todd, would you join us up here?

NUREG-1437, Supplement 26 A-62 August2006 I
Appendix A

PURVES TODD: Thank you very much.

CHIP CAMERON: You're welcome.

A-3 PURVES TODD: I'm here today and I'm going to speak in favor of the Monticello Nuclear Plant

being extended, because I believe that if the Monticello plant has to be shut down in 2010, it will

have an adverse effect on central Minnesota. And I think now I want to thank Kirstie Marone for

her article on the Monticello Nuclear Plant. It was very well explained in here (indicating) what

the plant had done, and it's a very good article for this area.

A-4 The other thing I want to talk about is to be able to congratulate the people in Monticello that

had the foresight to allow NSP to build this facility in the first place. Because myself, I think I

was probably a little bit critical at the time that it was being proposed-we really didn't

understand what nuclear energy was all about-where today I'm almost on the other side that I

think we have to expand nuclear energy all over the United States. In fact, I'm thinking we

probably will need at least 500 nuclear plants by this 2030 date, so I can see that you're going

to be a very busy group here trying to get that accomplished. And the reason that I say that is

there is no reason-no way that we can get from a 15-trillion- to 20-trillion-dollar economy in

this country without nuclear power.

A-5 And then, finally, I think that I want to explain a little bit on the natural gas and oil question that I

had, because I feel that with using that in Minnesota, it puts us at a disadvantage, because this

last winter our natural gas costs went up 30 percent-and not necessarily because of the

gas-fired plants that have already been built around the country, Katrina definitely caused some

problems with it, but it's just not a good source for generating electricity in Minnesota..

Thank you very much.

CHIP CAMERON: Thank you, Mr. Todd. And we're going to go Mr. Rick Jacobs at this point,

and-Mr. Jacobs is the Site Director at the Monticello facility.

(Off the record discussion.)

CHIP CAMERON: Okay. Let me find out: Does anybody else want to make a comment at this

point?

(No response.)

Okay. And Rick, it's totally up to you. We're having another meeting tonight, and if there are

some comments that the site wants to submit, we can do it at that time.

RICK JACOBS: Okay.

August 2006 A-63 NUREG-1437, Supplement 26 1
Appendix A

CHIP CAMERON: All right. Great. Okay. Well, I would just thank all of you for attending. And

I'm going to ask Rani if she wants to make any final comments, Rani Franovich. (Response.)

Okay. She's fine. And the staff, NRC staff will be here after the meeting for informal

discussion, and including Ms. Quinly. And we'll be here tonight if anybody wants to join us

again. And once again, we do have our Safety Project Manager here with us, so if there's any

questions on the safety side or whatever, Dan is here. And I would just thank you, and we're

adjourned and we'll be back tonight. Great.

(Whereupon, at 2:35 p.m. the proceedings were adjourned.)

A.3.2 Transcript of Evening Public Meeting on March 22, 2006, in Monticello,

Minnesota

[Introduction by Chip Cameron]

[Presentation by Rani Franovich]

[Presentation by Crystal Quinly]

[Presentation by Robert Palla]

GEORGE CROCKER: Thank you, Chip. In my experience environmental impact statements

are usually decision-informing documents. What I've reviewed is a rationalization for a decision

that's already made.

B-1 I realize there's nothing I can do or say to make this better, because I don't think you care. So

this is sort of a fool's errand that I'm on; and not really liking being a fool, I'm going to make it

short.

Your significance levels-small, moderate, large-appallingly subjective. Rational people

looking at the same facts could come to dramatically different conclusions about what's small,

about what's moderate, about what's large.

Small means not detectable, not noticeable? By whom? Using what?

B-2 Let's just look at how we monitor for radiation releases as an example. Acknowledging that the

radionuclides are released, where do they go? You haven't a clue. Your monitoring doesn't tell

you where'they go. Your monitoring says where you don't find them, but you're not looking for

where they are. They're out there. You let them go. And all you have to define what happens

after you release them are some calculations and some modeling that tell us nothing about

where they go.

Well, the Bier VII says that there's no such thing as a safe dose. You have no scientific basis,

no factual basis, no data to support such a contention. You have calculations and dispersion

models, and that's all you have. Where do they go?

NUREG-1437, Supplement 26 A-64 August 2006 1
Appendix A

So you don't look for where they are, you don't find them, and therefore it's not detectable,

therefore it's small. You see, quite arguably what this means is that while you're looking at this

as a dispersion, dilution being a solution, what another I would say more rational person could

argue is that what you've created is a very efficient distribution mechanism in which the

maximum number of people can have the opportunity to get enough of it inside of them to

cause the cancers. And it turns out that we don't have the cancer registries on a

county-by-county basis to really allow us to come to those conclusions because of the way

they're compared. But if you look at it the way it could be, you will see elevated concentrations

of particulate cancers in communities that are in close proximity to the reactors. But you don't

look at that, so it's small.

Small compared to what? Small compared to Well, you see some of us now finally understand

the difference between background radiation and the insult when the radiation is ingested or

inhaled. Entirely different things. Background is background. Why do you think your thigh

bones are so big? It's to keep the background out. But once it's inside of you each

radionuclide becomes very, very efficient at causing the destruction that ultimately leads to the

cancer.

Small. No facts. Conjecture. Subjective.

B-3 Wind, 30 percent capacity factor? I don't Commerce website for their wind maps and see what

kind of capacity factors they come up with. When you have a decision-making process like this

B-4 one in which there is no even attempt to make a reasonable simulation of 600 megawatts of

baseload to compare it with and then come to the conclusion that alternatives such as wind

have moderate to large impacts while a reactor that creates waste that must be managed for

240,000 plus years with routine emissions that aren't managed and that's small, you're sick.

That is sickness. That is also behavior, institutional behavior that is typical of failing institutions.

And the real tragedy here is that the technology you are managing is so terribly unforgiving.

CHIP CAMERON: Thank you, Mr. Crocker, for the time to come down and talk to us tonight.

And we're going to go our next speaker, who is Mr. John Conway, who is the Vice President

Monticello Generating-Yes, please.

JOHN CONWAY: Good evening. My name is John Conway. I work for the Nuclear

Management Company. I am the site Vice President at Monticello station here in Monticello.

And I'm here today to give Nuclear Management Company's position on the NRC's Draft

Supplemental Environmental Impact Statement provide a few additional comments regarding

the Monticello Nuclear Generating Plant.

C-1 Nuclear Management Company supports the conclusions contained in the Draft Supplemental

Environmental Impact Statement. The rigorous audits and inspections conducted by the

Nuclear Regulatory Commission led to a report confirming our own conclusions that continued

operation of the plant will have impact to the environment.

August 2006 A-65 NUREG-1437, Supplement 26 I
Appendix A

The Draft Impact Statement supports the key elements of our mission at the facility, namely,

the safe, reliable, and economical operation in that order of priority, with safety of the public, our

employees, and the environment being the top priority. We value and expect our organization

to be both a good neighbor and a responsible steward of the environment in which we operate.

C-2 Our 500 highly-experienced and employees take great care in their daily activities to ensure

that the environment is well protected. We feel fortunate that the location of the Monticello

plant rests on the banks of Mississippi River within close proximity of the Montissippi County

Park and the Lake Mariah State Park. The site is home to a wide variety of wildlife, aquatic

species, and plant life. Our efforts have made the site a safe and sound habitat for many

years, and it remains our commitment maintaining that for the years to come.

C-3 The Monticello plant has been extremely well maintained over its lifetime, ensuring it can

operate safely for at least an additional twenty years beyond the original operating license

period. Approximately every two years, we perform a refueling and major maintenance outage

in which we typically carry out over 2500 individual maintenance and inspection activities. This

is in addition to the ongoing maintenance, inspection, and testing activities that are performed

routinely during the period of plant operation.

We have continued to invest in a wide range of equipment improvements to take advantage of

technology and materials to ensure future reliable and safe operation, and this is relevant to the

aging management aspects of the license renewal process. As we move forward, we will

continue to upgrade and improve the equipment, the technology, and the training to the

employees of the station.

C-4 In conclusion, the Monticello plant has been a productive contributor to the energy needs of the

State of Minnesota and a valuable asset and neighbor to the surrounding communities and

environment. But we remain committed to operating safely, reliably, and economically, primarily

being focused on being a good neighbor and a good steward of the environment. As I

mentioned previously, it's the safety of the public, our employees, and the environment that

remain our highest priority. I and the rest of the employees at Monticello look forward to

serving the community that regard for many years to come.

That concludes my statement.

CHIP CAMERON: Okay. Thank you very much, Mr. Conway. Is there anybody else that would

like to make a statement tonight?

(No response.)

We do have some students here St. Cloud State University, and we welcome you tonight. Are

there any questions that any of have about the process, anything that you heard tonight? And

we'll be available after the meeting talk informally if you want to do that, but I just thought if you

had any questions that I think we the time to entertain them.

NUREG-1 437, Supplement 26 A-66 August 2006 1
Appendix A

Yes?

CHUCK HOSTOVSKY: I thought it was going to be a presentation onCHIP CAMERON: Let me get you on the mic so we can get you on the transcript.

CHUCK HOSTOVSKY: I thought there was going to be a presentation on the dry cask nuclear

storage technology. Or is that included in the SAMAs?

CHIP CAMERON: No-Well, let me-license renewal, as Rani Franovich talked about, looks at

particular things the passive-aging of passive components, plus the Environmental Review

covers a number of things. But I think that because of the fact that the spent fuel storage

situation is an every-day operational issue, it's considered another aspect. So maybe we can at

least tell you what framework is for that.

Rani, can you talk to us a little bit about that?

RANI FRANOVICH: Actually, I'm not well versed on what it takes to license one of the dry cask

storage facilities, but I can tell you the license renewal process focuses on aging management

of the system structures and components of the plant.

It's a separate process to license dry cask storage, so it's not part of tonight's meeting or the

staff's review of the license renewal application.

CHIP CAMERON: And Mike, do you want to add something for perhaps theRANI FRANOVICH: Dr. Masnick is a member of my staff.

CHIP CAMERON: Okay. Dr. Mike Masnik.

DR. MIKE MASNIK: As Rani said, it's really not part of this process, but I do know a little bit

about the dry cask storage. Our regulations allow for two ways in which a licensee can effect

dry cask storage on a site. They can apply for a site-specific license under Part 72 of our

regulations, which allows them to build a stand-alone facility on their site, and it's separately

licensed from the nuclear power plant.

There is also another provision in the regulations that allows them to request a general license.

And you have to understand that under current license, which is the Part 50 license, they

already can store spent fuel on site. So we have a provision under this general license in which

if they use an approved cask design, then they can build a pad and basically put the fuel in the

dry cask storage containers. So our activities associated with the general license is primarily

licensing the casks, and what we do is we have a very rigorous licensing procedure that looks

at a number of accidents and whether or not the cask will retain its integrity through the period

of time in which it's licensed.

August 2006 A-67 NUREG-1437, Supplement 26 1
Appendix A

The casks are licensed for a period of twenty years; at the end of the twenty-year period they

would have to re-certify that the cask was safe to store any longer period of time.

CHIP CAMERON: And the other process is a specific licenseDR. MIKE MASNIK: That's correct.

CHIP CAMERON:-that a particular facility can follow. But in this case they're using the

general license.

DR. MIKE MASNIK: Right. Right. In the case of Monticello they're pursuing the license option.

CHIP CAMERON: Okay. And Mr. Conway I think wants to add something here, and, again,

he's the Site Vice President at Monticello.

JOHN CONWAY: Although dry fuel storage outside the boundaries of the meeting, public

meeting here tonight, we have members of the staff from the Nuclear Management Company

that would be happy to within certain constraints, answer any regarding the dry fuel storage

campaign at after the meeting.

CHIP CAMERON: Okay. Thank you for that offer, Mr. Conway. Are there other issues, other

questions that any of you might have at this point?

(No response.)

Okay. And we're here after the meeting, so whatever you want to discuss. Okay. And we're

going to go Rani. Do you want to-I think we're done with the formal part. Do you want to

close this out and we can go to the informal discussion?

RANI FRANOVICH: Yeah.

CHIP CAMERON: Okay.

RANI FRANOVICH: In closing, I just wanted to take the opportunity to thank you all again for

being here. It really is important that the participates in our review process, and it enriches the

quality of our product. So thank you for being here with us tonight.

Again, comments can be received until May 4th. That's the close of our comment period. The

point of contact is Jennifer Davis or the e-mail address that you saw on the slide.

And I also wanted to let everyone know we have these NRC Public Meeting Feedback forms.

You may have picked one up as you came into the meeting. If you have any ideas or

suggestions on how we can improve our public meetings, maybe the way we can present

NUREG-1437, Supplement 26 A-68 August 2006 1
Appendix A

information a little bit better, please jot that down on this form. Postage is pre-paid, if you'd like

to just hand it to a member of staff on your way out, that's fine, too.

And again, thank you very much for coming, and we really appreciate your input. Good night.

CHIP CAMERON: Thank you.

(Whereupon, at 8:15 the proceedings were adjourned.)

August 2006 A-69 NUREG-1437, Supplement 26 I
Appendix A

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From: "Mark Lodermeier" <loghouse@warpdriveonline.com>

To: <MonticelloEIS@nrc.gov>

Subject: Dry Storage

Date: Sun, 19 Mar 2006 16:11:41 -0600

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D-1 Are you folks crazy, or do you think storing nuclear waste next to one of the

D-2 largest freshwater rivers in the world is a good idea. I cant belive Xcel energy,

holding people hostage at the end of an extension cord to get their way.

It's no wonder they want to "get this one under the radar screen", the whole

thought scares the living daylights out of me. I say shut 'em down and put up

wind generating towers on the same property!

Mark Lodermeier

9704 320th St.

St. Joseph, MN 56374

NUREG-1437, Supplement 26 .A'70 August 2006 1
Appendix A

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From: "Dennis Rykken" <drykken@mainstreetcom.com>

To: <MonticelloEIS@nrc.gov>

Cc: "Marty Sunderman" <martys@mainstreetcom.com>

Subject: Monticello Xcel Energy Relicense

Date: Sun, 19 Mar 2006 10:27:49 -0600

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E-1 I am in favor of making full utilization of existing nuclear plants by re-licensing.

I have toured this facility personally, albeit before 9/11 security restraints. Their record of error

free operation warrants continued operation for as long as the facility can be safely operated with

E-2 prudent maintenance. The Federal Government's failure to site a nuclear waste repository

should not be cause to close a functional, and large capital cost, generation plant before its' time.

E5-3. Minnesota's power supply cannot be replaced by conservation and renewables alone; forcing

migration to natural gas for base-load power generation is a short-sighted squandering of a very

limited resource.

I am responding as an individual who has served a Municipal Utility for the past 16 years.

Dennis N. Rykken, Chairman

Sauk Centre Municipal Utilities Commission

815 4th ST S

Sauk Centre MN 56378-1214

320-352-2458

August 2006 A-71 NUREG-1437, Supplement 26 1
Appendix A

MAY-08-2006 11:07 P.02

N • ~MonticelJlo Nuclear Gengratingl Plant

w ~d b Nu_--_Fxc•. ' Operaled by Nuclear Managemmt Cnmpsfny. LLC

April 26, 2006 L-MT-06-037

10 CFR Part 54

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, DC 20555 .

Monticello Nuclear Generating Plant.

Docket 50-263

License No. DPR-22

Comments Regarding th-e Draft Plant-Specific Sunolement 26 to the Genedc.

Environmental Impact Statement for Monticello Nuclear GeneratIng Plant License

Renewal Apolication (rAC No. MC6440)

Nuclear Management Company, LLC (NMC) has reviewed the Draft Supplemental

Environmental Impact Statement (SEIS) issued by the NRC on January 23, 2006, for the

Monticello Nuclear Generating Plant Ucense Renewal Application and Is providing

comments. NM.C's comments are Included in Enclosure 1. Our review.focused on

technical content, and the majority of our comments Identify corredions.

ronT. Conway. Site Vice President, Mortce lo-luuclear Generating Plant

Nuclear Management Company, LLC .

Enclosure:

cc-. Administrator, Region Ill. USNRC

Project Manager, Monticello, USNRC

Resident Inspector, Monticello, USNRC

License" Renewal Project Manager, Monticello, USNRC

License Renewal Environmental Project Manager, Monticelio,.USNRC

Minnesota Department of Commerce

Pillsbury, Winthrop, Shaw, Pittman; LLP (David Lewis)

2807 West County Road 75 - Montlceflo, Minnesota 55362-9637

Telephone: 763.295,5151 * Fax: 763295.1454

NUREG-1437, Supplement 26 A -72 August 2006 1
Appendix A

tAY-W8-2006 11! 07

'ENCLOSURE I

Nuclear Management Company, LLC Comments on MNGP DSEIS

P.83

Comment Page Line

Number Number Number , ..... . Proposed Change

F-1 1 1-1 18 Change "southem" to 'central'. (Appears this way In ER, page 2-36)

F-2 2 1-7 10 Change 'southeastern' to ocentral'. (Appears this way In ER, page 2-36)

F-3 3 2-1 13 Change southeastem" to "central'. (Appears this way In ER, page 2-36)

F-4 4 2-4 26 Change 'Four" to 'Five'.

F-5 6 2-7 21 Remove 'two or. MNGP typically runs three service water pumps In the

sunmer. Plans are to replace service water pumps with higher capacity

pumps so the plant will only have to run 2 out of 3 In the summer.

F-6 6 2-8 9 Change 'Four' to Five'.

F-7 7 2-8 .12 Change 'two' to 'three'.

F-8 8 2-9. 19 Add "re-use' after 'treatment! since the water Is continually re-used.

F-9 9 2-10 3 Insert period at end of sentence.

F-10 10 2-11 35 Change to 'nominal 22-24 month fuel cycle' to be consistent with page

2-30. line30.

F-11i 11 2-12 28 Correct name of line Is 'Parkers Lake'.

F-12 12 2-16 9 Change'Four'toFIve".

F-13 13 2-16 17 Change 'The other two wells" to 'Two other wells'.

F-14 14 2-18 18 Add sentence which reads: 'The fifth well, equipped with a I0-gpmn pump. provides domestic water to a security .tralning facility'.

F15 15 2-18 24 "Replace "EO boo, with NEU 008'.

F-16 16 2-22 20-22 Corbicula have been found In the vicinity of Monticello, present In the

baskets during 316(b) studies. They have also been recently found In the

discharge carnl, but none were present In the traveling screen forebays that were recently dredged.

F:17 17 4-32 8 Add 9In the bounding analysis, Monticello assumes..." This should

eliminate any confision with 4-31, line 25.

F-18 is 4-35 27 Change 'procedures that will be In pIae' to 'procedures that ate in place%.

F-19 19 4-43 15 The MOU that Xcel has entered Into Is with the FWS brly. not the MNDNR.

Remove "and MNDNR'.

F-20 20 4-48 16-17 Change sentence to read: 'Three other wells have an annual usage of

under 1.9 gpm and do not require appropriations permits." (see page 2-16)

F-21 21 4-48 27 & Change to 'Minnesota counties of Wright and Sherbume.' _ 30 Change 'Shelbume" to Sherbume."

Page I of 2

August 2006 A-73 NUREG-1437, Supplement 26 1
Appendix A

MAY-9-2006 11:06

ENCLOSURE t

Nuclear Management Company, LLC Comments on MNGP DSEIS

P.04

F-22

F-23

1-24

F-25

F-26

F-27

F-28.

F-29

F-30

F-31

22 5-6 & 5-7 32-34 & Replace this text with the text In Appendix O on pfage G-3, lines 16-31 and

1-14 page G-4, lines 1.17. The Information Is correct In Appendix G but not In

Chapter 5. Specifically, the distinction between 'early, and '1te" releases

Is based on the delay between declarationof.general emergency and

containment falure. not between accident Initiation and containment

failure.

23 8-40 4 ChAnge fourto hflveeon

| 24 8-42 4 Change "units' to "plant" for consistency with rest of discussion.

M 8-44 .14 Change'25 pement' to'14 percenr. The same footnote can be used. For

verification, see NSP 2004 IRP, Appendix D, Table 7610.0310, Item 1,

2004 data:

(received from other utilillestcolumn 3]- delivered for resale coarumn 4])

-divided by (consumption by MN customers [column 1] + consumption by

non-MN customers[column 2])

OR

(10496797-4475465)/(31439240 4 10331056) =-14%

(the value of 25% Ignored the subtraction of the delivered for resale value 1 _ _ [column 41)

VS E-2 4 The US Fish & Wildlife Service Migratory Bkrd Treaty Act Permit was reissued on 04/01/2006. Authorization Information Is as follows:

Number. MB074020-0

Expiration Date: 03/31/2009

27 E-2 10 The MNDNR Division of Fish and Wildlife Special Permit was reissued on 11121/2005. Authorization Information Is =follows:

Number. 13315

Expration Date: 12/31/06

28 E-4 24 Remo *NYSDEC: New York State Department of Environmental •

Conservation"- not relevant to dlscumslon."

29 E-4 3 The South Carolina Radioactive Waste Transport Permit w-s reissued for

2006. Authorization Information Is as follows:

Number-. 0026-22-06-Y ______ Expiration Date: 12/31/2006

30 E-4 8 The Tennessee Radioactive Shipment License was reissuid for 2006.

Authorization Information is as follaws;.. Number. T-MN-002-L06

Expiration Date: 12/31/2006

31 G'-23 18 Replace "$1.1 x 109 with "$1.1 x 10 "

Page 2 of 2

NUREG-1437, Supplement 26 A-74 August 2006 1
Appendix A

United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

Custom House, Room 244 M ERM

200 Chestnut Street

ta W.Y A T& Philadelphia, Pennsylvania 19106-2904

May 2,2006

ER 06/73

Chief, Rules Review and Directives Branch

U.S. Nuclear Regulatory Commission

Mail Stop T6-D59

Washington, DC 20555-0001

The U.S. Department of the Interior (Department) has reviewed the Generic Environmental

Impact Statement (EIS) for License Renewal of Nuclear Plants, NUREG-1437, Draft

Supplement 26 (dated January 2006), regarding the Monticello Nuclear Generating Plant, Wright

County, Minnesota.

The license renewal for Monticello Nuclear generating Plant does not involve any major

construction or physical alteration of the project area. The Generic EIS and Draft Supplement 26

adequately address the concerns of the Department regarding fish and wildlife resources, as well

as species protected by the Endangered Species Act. We concur with the preliminary

conclusions of the U. S. Nuclear Regulatory Commission (NRC) staff with respect to the impacts

of continued operations on these resources.

In a letter to the U.S. Fish and Wildlife Service (Service) dated December 22, 2005, the NRC

transmitted a Biological Assessment on the proposed license renewal for the Monticello Plant

with a determination that the renewal for an additional 20 years is not likely to adversely affect

the bald eagle at the Monticello site or along the associated transmission lines. The Service has

indicated that it concurs with the determination and will be providing an official concurrence

directly to the NRC.

Correction needed in Final EIS: On page 2-22, line 16, the statement that "To date, populations

of the zebra mussel within the Mississippi River have not been found above the Twin Cities area G-1 (St. Anthony Falls Lock and Dam)(MNDNR 2005)" is no longer correct. On Oct. 19, 2005, the

MNDNR issued a news release confirming the presence of zebra mussels within Rice Lake, an

impoundment within the Mississippi River near the City of Brainerd in Crow Wing County.

Brainerd is approximately 94 miles upstream of Monticello.

We appreciate the opportunity to provide these comments.

Sincerely,

Michael T. Chezik

Regional Environmental Office

cc: L. MacLean, FWS, Fort Snelling, MN

August 2006 A-75 NUREG-1437, Supplement 26 I
Appendix A

t1lY-17-2fG 13:11 P.02

/~~' uNITE STATEs ENVIRONMENTAL PRoTECTION AGENCY

ArA REGION 5

.77 C"HIC..AGO, W6TJA SON BOULEVARD IL W439

MIAY O 3 2006

B-191

Chief& Rules Review and Directives Branch

U.S. Nuclear Regulatory Commission

Mail Stop T6-D$9

Washington, D.C. 20555-0001

Re: Generic £aviroumcntal Impact Statement for License Renewal of Nuclear Plant,

Supplement 26: Monticello Nuclear Generating Plant ('EQ 14o. 20060034)

Dear Sir or Madam:

In accordance with Section 309 of the Clean Air Act and the National Environmental Policy

Act (NEPA), the US. Envi'onmnentaJ Protection Agency (US. EPA) has reviewed the Draft

Generic Environmental Impact Statement for License Renewal of Nuclear Plant; Supplement

26. Monicello Nuclear Gcoceating Plant According to this Draft Supplemental

Environmenual Impact Statement (SEIS), the plant's current operating license expires on

September 8. 2010. The proposed Federal action would renew the current operating liHcn

for an additional 20 years.

Thc Monticello Nuclear Generating Plant is located in southeastern Minnesota on the bank of

the Mississippi River, 30 miles northwest ofMinneapolis. Monticello is a single-unit plant that

c, urrently generates approximately 1775 megawatt thernmaL as a result of an authorized power

uprate in 1998. The plant uses Mississippi River watcr for condenser cooling and can operate

as an open-cycle plant. returjing water to the river, or a closed-cycle plant, using two cooling

towers. The cooling towers re ntomaUlyoperatod May through September, when te

F Mississippi River is generally above 68B F, or during periods of low flow. Tbis system is In

effect to meet sirfacc water appropriations limits and thermal discharge limits.

The Nuclear Regulatory Commission (NRC) developed the Generic Envimonmental Impact

Statement (GELS) to streamline the license renewal process on the premise that cnvironmental

impacts of most nuclear power plant license renewals arc similar. NRC develops facility- specific supplemental environmental impact statement documents as the facilities apply (or license renewal. The U.S.EPA provided comments on the GElS during its development

proces in 1992 and 1996. In several reviews of dacilityapcpcirlc documents, U.S. EPA's

F Region 5 orficc has commented that these documents do not provide site-spccific information o= impacT9 or use site-,pecific data for air and radiation and exposure calculations. Rcccntly, F representatives of NRC and U.S. EPA's Office of Federal Activities discusse d-te NRC's GETS

approach. NRC rciteratfd that it will continue to use the GEIS approach, except in cases where

NRC is aware that site-specific data iTicates an impact at an individual plant site or when

F specific infooriadotn documenting potential impacts is provided by other Fedcral or State

agencies or other revlcweun. While we rccognize tho GElS approach, we will continue to note

Page I of 2

NUREG-1437, Supplement 26 A-76 August 2006 1
Appendix A

MAY-17-206 13:11 P.04

U.S. Environmental Protection Agency Comments on

Generic Enviroumeotal 7mpact Statement for License Renewal of Nuclear Plant,

Supplement 26: Monticello Nuclear Generating Plant, Draft TReport,

NUREG-1437

H-1 1. We arc concerned that the Draft SELS does not discuss potential power.uprates :u

Monticello or estimate resulting Increases in radiological emissions. spent fuel. and other

emissions. We recogni•z that NRC's regulations (10 C.F.R Section 51.53(c)(2)) state that

an applicant's envirorunmental report need not discus tho demand for power, and we ore not

asking for an assessment of need, Separate from purpose and need, we consider power

uprates to be reasonably foreseeable actions that contributc to a cumulative radiological

impact. under 40 C.F.R Section 1508.7. and therefore should be discussed in NRC's final

SEIS.

H-2 2. We awe concered about the abnormal releases mentioned in the Draft SEMS. The Draft

SEIS refernces abnormal releases of fission and activation products and tritium during.the

period from 2001 to 2004 (page 2-9). Thi is the only place these releases are discussed in

the document, and their mention raises questions that ame not addressed. Information on

the abnormal releases is unclear. For example, it is not clear whether there was one release

event or rmore, ocwhere the event occurred. In addition, while the concentration of the

release(s) is given, readers arc referred elsewhere in the documcnt and regulations to

determine for themselvcs whether this is within effluent limits or how this irnpacts the

public or the environment. This section implies that occasional abnormal releases are

expected duri•g•the renewal period. The Final SEIS needs to explain the past 2nd future

expected frequency of these releases. Finally, the Draft SBIS also claims that if fature

abnormal releases occur, they will be below design dose objectives: It is not cler how this

statement could be supported for hypothetical incidents. We also notc that abnormal

releases are not discussed in sections on radiological impacts or water quality, presuming

that these abnormal rele-ses were issued to a water body.

With the GElS approa*h, NRC generally does not include.an analysis ofimpacts where

staffroviewei; have not found new or significant informalion. We belicve thai past

abnormal rolcascs, and the potential for future abnormal relea.es, qualify as new and

significant information. We therefore recommend that the subsequent Final SEIS discuss

the abnormal releases ully and in context to the environmcntul impacts analysis. We

recommend including a discussion ofrpast or potential future releases and steps to prevent

releases. Specifically, the Final SEIS needs to explain the number of releases and where

releases occured (i.e., describe whether the release was effluent into the Mississippi River,

an on-site spill, or some other relcasc). It should clarify how abnormal releases arc

differmt from liquid effluent, if his is the case. We recommend that where concentrations

are mentioned, the document plce these concentrations In cortext by giving effluent

limits, dose limits, or other relevant measurements. We also recommend that abnormal

releases be discussed in Chapte., 4.0 Environmental impacts of Operaion.

H-3 3, We arc aware that there was a proposal before the Minnesota Environmental Quality Board

for dry cask storage facility for spent nuclear fuel at Monticello. We note that the

Environmental Impacts section of the Dramft SETS does not discuss the potential impacts

associated with adding this type ofspent fuel storge facility to the txisuing operation. We

August 2006 A-77 NUREG-1 437, Supplement 26 1
Appendix A

MrAY-17-2006 13:12 P.

suggest that anew dry cask stompge facility constitutes a new Set of cilrcUStafeC for this

site and should be evaluated in gatcr deti'l for additional impacts to the environment.

H-4 4. Section 2.1.4.2. Gaseous Waste Prooeming Systems ard Effluent Controls, Page 2-10, irs

paragraph. Citations of dose values should also include the dose value, in addition to just

the citation, to make the values clearer.

H-5 5. Section 2.1.4.2, Gaseous Waste ProcessLng Systems and Effluent Controls, Page 2-10, third

paragraph. The total curic values provided do not add up to the total curie emissions

stated. Ple..se correct or clarify this discrepancy.

H-6 6. Section 2.2.7, Radiological Impacts, pages 2-29,2-30, last paragraph. The refereces to

the environmental standards need to be complete citations including tit. of the rule or

regulation, along with the basic standard for comparison provided consistently. AUl ofthe

cnvironmcntal standard that could be used for a comparison should be used, including 40

CFR 61 Radionuclide National Emission Standards for lazardoua Aii Pollutants values.

This will reduce the fime needed to look up these citations and verify values that arc cited

in th text.

H-7 7. Section 4.3. Radiologicalt(mpacti of tormal Operations, page 4-27, 4-28, Table 4-7, and

paragraph I On 4-28. The specific values for exposure need to be provided in addition to

the complete citation of the location of this infomauion. This will help to provide the

infornation bcttcr and be less confusing that a citation only, that then must be referred to

allow verification of the standard being cited.

H-8 8. Section 5.2.Z, J.timate oflik, page 5-6. The Draft SEIS states that the baseline core

damage frkquen'cy (CDI) for the purpose of the severe accident mitigation alternatives

(SAMA) is approximatoly 4.5 x 100 per year. This CDF is based on the risk ases~sment ror

intenA'LUY-initiated events. Tho Draft SEIS does not include the contribution to risk from

external events within the Monticello risk estimates; however it does account for the

potential risk reduction benefits associated with external events by increasing the estimared

benefits for internal events by a faitor of two. The estimates for risks from both areas

should be evaluated and presented along with a rationale for not basing risk decisions on

the external events or including them in the considerations as necessary to get an accurate

portrayal of the risk ofthe licensing renewal.

H-9 9. Section 6.1, The Uranium Fuel Cycle, page 6-3. Under the bullet point for Off-si

rUdiological.i iacLs (individual effeos from other thzn digposal_0f svent fuel and high level waste disnocal), no consideration appears to be given to the potential long term

storag of the spent fuel and high level waste materials on site until such time as a

permanent facility is finally liccnscd and begins to accept these materials for disposal. A

refereacc to other sections that this evaluation may have been included in should be

provided here as well as in other sections, or if this evaluation has not been adequately

conducted, the issue needs to be considered and an appropriate evaluation conducted.

H-10 10. Section 6.1. The Uranium Fuel Cycle, page 6-8, under the bullet point for Qi.te Spent Fuel. A more thorough evaluation for the volume of spent fuel expected to be generated during the additional licensed time needs to be provided along with morc specific

NUREG-1437, Supplement 26 A-78 August2006 I
Appendix A

IMAY-17-20O6 13:12 P.06

Information as to the specific circumstances that may impair or improve the rik vulucs for

poten6al exponr• to this spent fael storage.

H-11 11. Section 7.1. DemommLr• ioning, page 7-2, under bullet point Radiation Doe.. Asthe GELS

is based on afortyryear licensing period, an extension of this period would have an impact

1 that we suggest needs to be quantileed and repomd. We rccommend including this

information in the FPinal SEIS as part of the risk that would be associated with the license

exte•sioa and providing the specific methodology used to estimate riskL

H-12 12. Section 81. 1o-Aclon Ahtemacive, page 8-4, -5, under the bullet point HinHelth.

The actual value representing the cited percent valuc should be specifically provided in

Sadtion to the citation. This will help to reduce unnccessary additional esearch, except for

value verillcaions. and avoid potential misunderstandings or confusion about the actual

value(s).

H-13 13. Section 8.2. ). Coal-Fred Generatiom, page B-16, under bulletpoint Human Het. Any

dose estimate that would have the potential to fall is the risk range of 100 to 1I or greater

needs to be specifically evaluated for potential regulatory requirements or risk Impacts to

the public health. This should be estimated conservatively using the data that is currently

available or that can be logically extrapolated fom currently availablc infonmation.

H-1414. Section .2.3, Coal Gasification, page 8-32, under bullet point Waste. We recommend

speciacslly describing wasm impacts, rather than making reference to them, to provide a

clearer understanding of the risk determination made in this section ofthe documct.

H-1 5 15. Section 8.23, Coal Gasiflcation, page 8-32, 8-33. under bullct point THtuma .,nl We

recommend specifically describing human-health impacts, rather than making reference to

them, to provide a clearer understanding orthe risk dctermination madc in this section of

the document.

H-16 16. Section 8.2.4. Nudl"r Power Generation, page 8-36. Wo recommend specifically

describing the differ•nces in potential risk associated with changes in power prodcrtion,

rather tbao making refere.nce to them, to provide a clearer understanding of the risk

deicemination made in this section of the document.

H-17 17. Section 8.2.4. 1. Closed -Cycle Cooling stxem, p age 8-40. unde bullet poin t We

recommend specifically describing waste impacts, rather than making reference to them, to

provide a clearer understanding of the risk determination made in this section orethe

documenL

H-18 18. Secaon 8,2.4.1, Closed -Cyle CooliNg Sys)tm, page 8-40, under bullet point 1

Henit. Human-hcalth impacts need to be specified rather than merely referenced to

provide a clearer underatanding of the risk determination in this section orths documcnL

TOTAL P.OG

August 2006 A-79 NUREG-1437, Supplement 26 1
MAY-31-2006 15:31 P.02

MINNE'SO'AHISTORICAL SOCIETY.

State Histotic Preservation Office

Ap•l 26. 2006

Rani Franovich, Branch Chief

Environmental Branch B

Division of Ucense Renewal

Office of Nudear Reactor Regulation

Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Re: Monticello Nuclear Generating Plant Ucense Renewal

Monticello, Wright County

SHPO Number. 2004-2193

Dear Rani Franovich:

Thank you for your recent submittals regarding the above referenced undertaking.

As you know, you consulted with our office regarding the undertaking In 2005, and we

- conduded at that time that no historic properties would be affected. Based on our

review of the Information recently submitted, we see no reason to alter that conclusion.

Contact us at 651-296-5462 with questions or concerns.

Sincerely.

Britta L Bloomberg

Deputy State Historic Preservation Officer

34S Khlot Boulev&Mr West/Sghit Pooll MinnesoaL 55102-l1fl6tTetphomi 651-2996-6126

TOT.L P.06

NUREG-1437, Supplement 26 A-80 August 2006 1
Appendix B

Contributors to the Supplement

Appendix B: Contributors to the Supplement

The overall responsibility for the preparation of this supplement was assigned to the Office of

Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The statement was

prepared by members of the Office of Nuclear Reactor Regulation with assistance from other

NRC organizations, the Lawrence Livermore National Laboratory, Argonne National Laboratory,

Pacific Northwest National Laboratory, Energy Research Incorporated, and the Information

Systems Laboratory.

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Jennifer A. Davis Nuclear Reactor Regulation Project Manager

Robert G. Schaaf Nuclear Reactor Regulation Backup Project Manager

Andrew Kugler Nuclear Reactor Regulation Section Chief

Rani Franovich Nuclear Reactor Regulation Section Chief

Barry Zalcman Nuclear Reactor Regulation Program Manager

Jason Flemming Nuclear Reactor Regulation Project Support

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation

Alternatives

James Wilson Nuclear Reactor Regulation Alternatives

Michael Masnik Nuclear Reactor.Regulation Aquatic/Terrestrial Ecology

Stacey Imboden Nuclear Reactor Regulation Health Physics

Meghan Thorpe-Kavanaugh Nuclear Reactor Regulation Health Physics

LAWRENCE LIVERMORE NATIONAL LABORATORY(n)

Crystal Quinly

Lily A. Sanchez

Lisa Crawford

Hank Khan

Dave Armstrong

Jeff Stewart

Jim Woollett

Michael van Hattem

Task Leader

Deputy Task Leader/Water Use,

Hydrology

Alternatives/Land Use, Related

Federal Programs

Health Physics

Meteorology/Air Quality

Socioeconomics/ Environmental

Justice

Terrestrial Ecology

August 2006 B-1 NUREG-11437, Supplement 26 I
Appendix B

Name

Karen McWilliams

Nancy Woods

Carolyn AIm

Jennifer Nivens

Kim Martin

Affiliation Function or Expertise

Technical Editor

Technical Editor

Technical Editor

Administrative Support

Administrative Support

ARGONNE NATIONAL LABORATORYb)

Bill Vinikour Aquatic Ecology

PACIFIC NORTHWEST NATIONAL LABORATORY(c)

Darby Stapp Cultural Resources

INFORMATION SYSTEMS LABORATORY

Robert Schmidt Severe Accident Mitigation

Alternatives

Kimberly Green Severe Accident Mitigation

Alternatives

(a) Lawrence Uvermore National Laboratory is operated for the U.S. Department of Energy by the University of

California.

(b) Argonne National Laboratory is operated for the U.S. Department of Energy by the University of Chicago.

fc) Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by the Batelle Memorial

Institute.

NUREG-1 437, Supplement 26 B-2 August 2006 1
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to Nuclear Management Company, LLC's Application for

License Renewal of Monticello Nuclear Generating Plant

Appendix C: Chronology of NRC Staff Environmental

Review Correspondence Related to Nuclear

Management Company, LLC's Application for License

Renewal of Monticello Nuclear Generating Plant

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and Nuclear Management Company (NMC), and other

correspondence related to the NRC staff's environmental review, under Title 10 of the Code of

Federal Regulations (CFR) Part 51, of NMC's application for renewal of the Monticello operating

license. All documents, with the exception of those containing proprietary information, have

been placed in the Commission's Public Document Room, at One White Flint North, 11555

Rockville Pike (first floor), Rockville, MD, and are available electronically from the Public

Electronic Reading Room found on the Internet at the following Web address:

http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC's

Agencywide Documents Access and Management System (ADAMS), which provides text and

image files of NRC's public documents in the Publicly Available Records (PARS) component of

ADAMS. The ADAMS accession number for each document is included below.

March 16, 2005

March 24, 2005

March 31, 2005

May 5, 2005

Letter from Mr. Thomas J. Palmisano, NMC, to the NRC, submitting

the application for renewal of the operating license for Monticello

Nuclear Generating Plant (Accession No. ML050880241).

NRC press release announcing the availability of the license

renewal application for Monticello Nuclear Generating Plant

(Accession No. ML050830481).

NRC letter to Mr. Thomas J. Palmisano, NMC, Receipt and

Availability of the License Renewal Application for Monticello

Nuclear Generating Plant (Accession No. ML050900052).

NRC letter to Mr. Thomas J. Palmisano, NMC, forwarding the

Determination of Acceptability and Sufficiency for Docketing,

Proposed Review Schedule, and Opportunity for a Hearing

Regarding the Application from Nuclear Management Company,

LLC for Renewal of the Operating License for Monticello Nuclear

Generating Plant (Accession No. ML051260029).

August 2006 C-1 NUREG-1 437, Supplement 26 1
Appendix C

May 9, 2005

May 9, 2005

May 12, 2005

May 12, 2005

May 26, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

NRC letter to Ms. Margo Askin, Head Librarian Monticello Public

Library regarding the maintenance of documents related to the

Monticello Nuclear Generating Plant license renewal review

(Accession No. ML051300167).

NRC letter to Ms. Amy Wittmann, Branch Librarian Buffalo Public

Library regarding the maintenance of documents related to the

Monticello Nuclear Generating Plant license renewal review

(Accession No. ML051300195).

NRC press release announcing the opportunity for hearing on

application to renew operating license for Monticello Nuclear Power

Plant (Accession No. ML051320170).

Federal Register Notice of Acceptance for Docketing of the

Application and Notice of Opportunity for Hearing Regarding the

Renewal of Facility Operating License No. DPR-22 for an Additional

20-Year Period (70 FR 25117).

NRC letter to Mr. Thomas J. Palmisano, NMC, forwarding the

Federal Register notice of intent to prepare an Environmental

Impact Statement and conduct scoping process for license renewal

for Monticello Nuclear Generating Plant (Accession No.

ML051 460549).

NRC letter to Mr. Don Klima, Director, Advisory Council on Historic

Preservation, regarding the Monticello Nuclear Generating Plant

license renewal review (Accession No. ML051470309).

NRC letter to Mr. Thomas J. Palmisano, NMC, requesting additional

information regarding Severe Accident Mitigation Alternatives

(SAMA) for Monticello Nuclear Generating Plant (Accession No.

ML051470339).

NRC letter to the Fond Du Lac Reservation Tribal Council, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051520264).

NRC letter to the Flandreau Santee Sioux Executive Committee,

inviting participation in the scoping process for the Monticello

Nuclear Generating Plant license renewal review (Accession No.

ML051520356).

NUREG-1 437, Supplement 26 C-2 August 2006 1
Appendix C

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May.27, 2005

NRC letter to the Turtle Mountain Band of Chippewa Tribal Council,

inviting participation in the scoping process for the Monticello

Nuclear Generating Plant license renewal review (Accession No.

ML051520418).

NRC letter to the Upper Sioux Indian Community, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051520483).

NRC letter to the Bois Forte Reservation Tribal Council, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

MIL051520372).

NRC letter to the White Earth Tribal Council, inviting participation in

the scoping process for the Monticello Nuclear Generating Plant

license renewal review (Accession No. ML051520395).

NRC letter to the St. Croix Chippewa of Wisconsin, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051520525).

NRC letter to the Spirit Lake Tribe, inviting participation in the

scoping process for the Monticello Nuclear Generating Plant license

renewal review (Accession No. ML051520546).

NRC letter to the Sokaogon Chippewa Community, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051520568).

NRC letter to the Sisseton Wahpeton Oyate of the Lake Traverse

Reservation, inviting participation in the scoping process for the

Monticello Nuclear Generating Plant license renewal review

(Accession No. ML051520578).

NRC letter to the Keweenaw Bay Tribal Council, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051530421).

August 2006 C-3 NUREG-1437, Supplement 26 I
Appendix C

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

May 27, 2005

NRC letter to the Lao Courte Orielles Governing Board, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051530539).

NRC letter to the Lac du Flambeau Band of Lake Superior

Chippewa, inviting participation in the scoping process for the

Monticello Nuclear Generating Plant license renewal review

(Accession No. ML051540187).

NRC letter to the Lac Vieux Desert Band of Lake Superior

Chippewa, inviting participation in the scoping process for the

Monticello Nuclear Generating Plant license renewal review

(Accession No. ML051540250).

NRC letter to the Leech Lake Band of Ojibwe, inviting participation

in the scoping process for the Monticello Nuclear Generating Plant

license renewal review (Accession No. ML051540294).

NRC letter to the Mille Lacs Band of 0jibwe, inviting participation in

the scoping process for the Monticello Nuclear Generating Plant

license renewal review (Accession No. ML051540402).

NRC letter to the Prairie Island Community Council, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051540436).

NRC letter to the Red Lake Tribal Council, inviting participation in

the scoping process for the Monticello Nuclear Generating Plant

license renewal review (Accession No. ML051540461).

NRC letter to the Santee Sioux Tribal Council, inviting participation

in the scoping process for the Monticello Nuclear Generating Plant

license renewal review (Accession No. ML051540473).

NRC letter to the Shakopee Dakota Community Council, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant (Accession No. ML051540487).

NRC letter to the Grand Portage Reservation Council, inviting

participation in the scoping process for the Monticello Nuclear

Generating Plant license renewal review (Accession No.

ML051550002).

NUREG-1437, Supplement 26 C-4 August 2006 1
Appendix C

June 1,2005

June 2, 2005

June 2, 2005

June 3, 2005

June 3, 2005.

June 3, 2005

June 6, 2005

June 14, 2005

July 13,2005

NRC letter to the Lower Sioux Indian Community of Minnesota

Mdewakanton Sioux Indians, inviting participation in the scoping

process for the Monticello Nuclear Generating Plant license renewal

review (Accession No. ML051560007).

NRC letter to Dr. Nina M. Archabal, State Historic Preservation

Officer for Minnesota, inviting participation in the scoping process

relating to the Monticello Nuclear Generating Plant license renewal

review (Accession No. ML051560004).

Federal Register Notice of Intent to Prepare an Environmental

Impact Statement and Conduct Scoping Process of Facility

Operating License No. DPR-22 (70 FR 32381).

NRC letter to Mr. Dan P. Stinnett, Field Supervisor, U.S. Fish and

Wildlife Service, requesting list of protected species within the area

under evaluation for the Monticello Nuclear Generating Plant license

renewal review (Accession No. ML051560006).

NRC letter to the Red Cliff Band of Lake Superior Chippewa,

inviting participation in the scoping process for the Monticello

Nuclear Generating Plant license renewal review (Accession No.

ML051560008).

NRC letter to the Bad River Band of Lake Superior Chippewa,

inviting participation in the scoping process for the Monticello

Nuclear Generating Plant license renewal review (Accession No.

ML051560009).

NRC meeting notice informing public of scoping meeting to be held

in Monticello, Minnesota, on June 30, 2005 (Accession No.

ML051610403).

NRC letter to Monticello Nuclear Generating Plant summarizing the

telecommunication to discuss the Severe Accident Mitigation

Alternatives (SAMA) Requests for Additional Information (RAIs)

(Accession No. ML051650157).

Letter from Dan P. Stinnet, Field Supervisor, U.S. Fish and Wildlife

Service forwarding list of protected species which are under

evaluation for the Monticello Nuclear Generating Plant license

renewal (Accession No. ML052070060).

I

I

August 2006 C-5 NUREG-1437, Supplement 26 1
Appendix C

July 27, 2005

July 28, 2005

July 28, 2005

August 4, 2005

.August 16, 2005

September 1, 2005

October 7, 2005

December 22, 2005

January 23, 2006

Letter from John T. Conway, NMC, to NRC providing the responses

to Request for Additional Information Regarding Severe Accident

Mitigation Alternatives for Monticello Nuclear Generating Plant

(Accession No. ML052130197).

NRC letter to NMC, summarizing telephone conference concerning

draft Request for Additional Information pertaining to the Monticello

Nuclear Generating Plant license renewal application (Accession

No. ML052100060).

NRC letter to NMC forwarding summary of public scoping meetings

for Monticello Nuclear Generating Plant license renewal review

(Accession No. ML052030005).

NRC letter summarizing the site audit regarding the Monticello

Nuclear Generating Plant license renewal review (Accession No.

ML052200039).

Letter from John T. Conway, NMC providing response to Request

for Additional Information regarding Monticello Nuclear Generating

Plant (Accession No. ML052340510).

NRC letter to NMC summarizing a telephone conference call held

on August 10, 2005, to discuss follow-up items regarding the

Severe Accident Mitigation Alternatives (SAMA) Request for

Additional Information (RAI) for Monticello Nuclear Generating Plant

(Accession No. ML052450030).

NRC letter to John T. Conway, NMC, forwarding the Environmental

Scoping Summary Report regarding Monticello Nuclear Generating

Plant license renewal review (Accession No. ML052800329).

NRC letter to Dan P. Stinnett, FWS, forwarding the Biological

Assessment for Monticello Nuclear Generating Plant license

renewal review (Accession No. ML053570019).

NRC letter to John T. Conway, NMC forwarding the Notice of

Availability of the Draft Plant-Specific Supplement 26 to the Generic

Environmental Impact Statement (GElS) regarding Monticello

Nuclear Generating Plant license renewal (Accession No.

ML060230264).

NUREG-1437, Supplement 26 C-6 August 2006 1
Appendix C

January 23, 2006

February 2, 2006

February 10, 2006

February 28, 2006

March 19, 2006

March 19, 2006

April 26, 2006

April 26, 2006

May 2, 2006

NRC letter to EPA, filling of Draft Supplement 26 to the Generic

Environmental Impact Statement regarding Monticello Nuclear

Generating Plant license renewal (Accession No. ML060230222).

NRC press release announcing the issuance of the Draft

Environmental Impact Statement for Monticello Nuclear Power

Plant license renewal (Accession No. ML060330500).

NRC letter to Minnesota State Historic Preservation Officer,

requesting comments on the Draft Supplement Environmental

Impact Statement for Monticello Nuclear Generating Plant license

renewal (Accession No. ML060440138).

Meeting notice announcing the public meeting to discuss the Draft

Supplemental Environmental Impact Statement for Monticello

Nuclear Generating Plant license renewal (Accession No.

ML060590612).

E-mail from Dennis Rykken, providing comments related to the

license renewal of the .Monticello Nuclear Generating Plant

(Accession No. ML061220611).

E-mail from Mark Lodermeier, providing comments related to the

.license renewal of the Monticello Nuclear Generating Plant

(Accession No. ML061220619).

Letter from John T. Conway, NMC providing comments regarding

the Draft Supplement Environmental Impact Statement for

Monticello Nuclear Generating Plant license renewal (Accession No.

ML061210175).

Letter from Britta L. Bloomberg, Deputy State Historic Preservation

Officer, Minnesota State Historic Preservation Office, providing

comments on the Monticello Nuclear Generating Plant license

renewal (Accession No. ML061520200).

E-mail from Darby Valincia submitting comments from U.S.

Department of the Interior, U.S. Fish and Wildlife Service, on the

Draft Supplement Environmental Impact Statement for Monticello

Nuclear Generating Plant (Accession No. ML061320037).

August 2006 C-7 NUREG-1437, Supplement 26 I
Appendix C

May 3, 2006 Letter from the U.S. Environmental Protection Agency, providing

comments regarding the Draft Supplement Environmental Impact

Statement for Monticello Nuclear Generating Plant license renewal

(Accession No. ML061370511).

NUREG-1 437, Supplement 26 C-8 August 2006 1
Appendix D

Organizations Contacted

Appendix D: Organizations Contacted

During the course of the staff's independent review of environmental impacts from operations

during the renewal term, the following Federal, State, regional, local, and Native American tribal

agencies were contacted:

Advisory Council on Historic Preservation, Washington, D.C.

Bad River Band of Lake Superior Chippewa, Odanah, Wisconsin

Bois Forte Reservation Tribal, Net Lake, Minnesota

City of Monticello, Administrator and Planning, Monticello, Minnesota

City of Monticello Economic Development, Monticello, Minnesota

City of Monticello Administrator, Monticello, Minnesota

Flandreau Santee Sioux Executive Committee, Flandreau, South Dakota

Fond Du Lac Reservation Tribal Council, Cloquet, Minnesota

Grand Portage Reservation Council, Grand Portage, Minnesota

Keweenaw Bay Tribal Council, Baraga, Mi6higan

Lac Courte Orielles Governing Board, Hayward, Wisconsin

Lac du Flambeau Band of Lake Superior Chippewa, Lac du Flambeau, Wisconsin

Lac Vieux Desert Band of Lake Superior Chippewa, Watersmeet, Wisconsin

Leech Lake Band of Ojibwe, Cass Lake, Minnesota

Lower Sioux Indian Community of Minnesota Mdewakanton Sioux Indians, Morton, Minnesota

Mille Lacs Band of Ojibwe, Onamia, Minnesota

Minnesota Department of Natural Resources, St. Paul, Minnesota

Minnesota State Historic Preservation Office, St. Paul, Minnesota

Monticello Area Chamber of Commerce, Monticello, Minnesota

August 2006 D-1 NUREG-1437, Supplement 26 1
Appendix D

Wright County Assessor, Buffalo, Minnesota

Wright County Assessor, Auditor-Treasurer, Buffalo, Minnesota

Prairie Island Community Council, Welch, Minnesota

Red Lake Tribal Council, Red Lake, Minnesota

Red Cliff Band of Lake Superior Chippewa, Bayfield, Wisconsin

Santee Sioux Tribal Council, Niobrara, Nebraska

Shakopee Dakota Community Council, Prior Lake, Minnesota

Sherburne County, Auditor-Treasurer, Elk River, Minnesota

Sherburne County Department of Public Works, Elk River, Minnesota

Sherburne County Emergency Management, Elk River, Minnesota

Sisseton Wahpeton Oyate of the Lake Traverse Reservation, Sisseton, South Dakota

Sokaogon Chippewa Community, Crandon, Wisconsin

Spirit Lake Tribe, Fort Totten, North Dakota

St. Croix Chippewa of Wisconsin, Webster, Wisconsin

Turtle Mountain Band of Chippewa Tribal Council, Belcourt, North Dakota

United States Fish and Wildlife Service, Bloomington, Minnesota

Upper Sioux Indian Community, Granite Falls, Minnesota

White Earth Tribal Council, White Earth, Minnesota

Wright County Emergency Response Management (Civil Defense), Monticello, Minnesota

Wright County Treasury Department, Buffalo, Minnesota

NUREG-1437, Supplement 26 D-2 August 2006
Appendix E

Nuclear Management Company, LLC's Compliance Status and

Consultation Correspondence

Appendix E: Nuclear Management Company, LLC's

Compliance Status and Consultation Correspondence

Correspondence received during the process of evaluation of the application for renewal of the

license for Monticello Nuclear Generating Plant is identified in Table E-1. Copies of the

correspondence are included at the end of this appendix.

-The licenses, permits, consultations, and other approvals obtained from Federal, State,

regional, and local authorities for Monticello are listed in Table E-2.

Table E-1. Consultation Correspondence

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission Advisory Council of Historic May 27, 2005

Preservation (D. Klima)

U.S. Nuclear Regulatory Commission Minnesota Historical Society, State June 2, 2005

Historic Preservation Officer

(N. Archabal)

U.S. Nuclear Regulatory Commission U.S. Fish and Wildlife Service June 3, 2005

(D. Stinnett)

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory July 13, 2005

(D. Stinnett) Commission

U.S. Nuclear Regulatory Commission U.S. Fish and Wildlife Service December 22, 2005

(D. Stinnett)

Minnesota Historical Society, Deputy U.S. Nuclear Regulatory April 26, 2006

State Historic Preservation Officer Commission

(B. Bloomberg)

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory May 2, 2006

(D. Valincia) Commission

I

I

August 2006 E-1 NUREG-1437, Supplement 26 I
z

G)

4-.

CD

3

CD

Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and Other Approvals for Monticello

Expiration

Agency Authority Description Number Issue Date Date Remarks

CD

0.

m

NRC

FWS

DOT

10 CFR Part 50

Migratory Bird Treaty

Act (16 USC 703-712)

49 CFR Part 107,

Subpart G

Operating license,

Monticello

Permit

Certificate of

Registration for

Transportation of

Hazardous

Materials

General Permit

DPR-22 09/8/10 Authorizes operation of

Monticello Unit.

MB074020-0

062706 552

0090

03/31/09 Authorizes handling of injured

and dead migratory birds.

06/30/07 Authorization to transport

hazardous materials.

ACOE

MDNR

m

MDNR

MDNR

MDNR

C

o aT o

Section 10 of the

Rivers and Harbors

Act of 1988

Minnesota Statutes

Chapter 103G.271

Minnesota Statutes

Chapter 103G.271

Minnesota Statutes

Chapter 103G.315

Minnesota Rule

Chapter 6115.0200

Minnesota Statutes

Chapter 97A.401

Water

Appropriations

Permit

Water

Appropriations

Permit

State Dredging

Permit

Division of Fish

and Wildlife

Special Permit

67-0083

66-1172

01-02982-GPGAE

N/A(8)

Authorizes maintenance

dredging, dewatering, and

settling system discharge, and

dredged material disposal.

Authorizes groundwater

withdrawals from well #1 and

well #2.

Authorizes surface water

withdrawals from the

Mississippi River.

Authorizes maintenance

dredging, dewatering, and

settling system discharge, and

dredged material disposal.

67-0743

GP.100-MN

N/A(&)

13315 12/31/06 Authorizes collection of fish

for biological evaluation.

his permit does not expire.
Cn

N0

Table E-2. (contd)

Expiration

Agency Authority Description Number Issue Date Date Remarks

MDNR

I MPCA

MPCA

Minnesota Statutes

Chapter 97A.401

Minnesota Statutes

Chapters 115 and 116

Minnesota Statutes

Chapters 115 and 116

Minnesota Statutes

Chapters 115 and 116

Minnesota Statutes

Chapters 115 and 116

Division of

Ecological

Services Special

Perrmit

NPDES permit

General

Stormwater.

Permit for

Industrial Activity

State Disposal

System Permit

State Disposal

System Permit

12683

MN0000868

MN G611000

12131108 Authorizes collection of

mussels for radioactive

exposure analysis.

07/31/07 Authorizes discharge of

wastewaters to waters of the

state.

10/31/02 Authorizes discharge of

stormwater to waters of the

state. (Permit renewal

application submitted 4/16/02.)

MPCA

MPCA

12915 .N/A(8) Authorized the construction

and operation of a sanitary

sewer extension.

MN0058343

I MPCA Minnesota Statutes

Chapters 7045.0225

Minnesota Statutes

Chapters 7007.0105

Hazardous Waste

Generator

License

MND000686139

MPCA Air Emission 17100019-003

Permit

03/31/04 Authorizes maintenance

dredging, dewatering, and

settling system discharge, and

dredged material disposal.

(Permit renewal application

submitted 9/24/03.)

06/30/07 Authorizes facility to operate as

a hazardous waste generator.

08/16/05 Authorizes facility to operate air

emission facility (oil- and gasfired heating boiler, four

emergency diesel generators,

and an emergency fire pump

diesel engine). (Permit renewal

application submitted 2/17/05.) >

-o

('D

CL

0•.

X

z

C

:14

CD)

CD

M0 aThis permit does not expire.
z

C

:1)

J,4

cn

CD

CD

0)

Table E-2. (contd)

Expiration Agency Authority Description Number Issue Date Date Remarks

City of Ordinance Title 14, Sanitary Sewer 001 N/Aa Authorizes discharge of

Monticello Chapter 4 Wastewater domestic sanitary waste Into

Discharge the City of Monticello sanitary

Agreement sewer collection system.

South Carolina SC ADC 61-83 South Carolina 0026-22.06-Y 12/31/06 Authorization to transport

Department of radioactive waste radioactive materials in South

Health and transport permit Carolina.

Environmental

Control

-Tennessee TDEC 1200-2-10-30 Tennessee T-MN002-L06 12/31/06 Authorization to ship

Department of radioactive radioactive material to a

Environment shipment license licensed disposal/processing and facility within Tennessee.

Conservation

(D

a.

171

I

I

Il1 ACOE = U.S. Army Corps of Engineers

CFR = Code of Federal Regulations

DOT = U.S. Department of Transportation

FWS = U.S. Fish and Wildlife Service

MDNR = Minnesota Department of Natural Resources

MPCA = Minnesota Pollution Control Agency

NRC = Nuclear Regulatory Commission

SC = South Carolina

TDEC = Tennessee Department of Environment and Conservation

NPDES = National Pollutant Discharge Elimination System

USC = United States Code

0

0

0) aThis permit does not expire.
Appendix E

UNITED STATES

-" NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

Hay 27, 2005

Mr. Don Klima, Director

Office of Federal Agency Programs

Advisory Council on Historic Preservation

Old Post Office Building

1100 Pennsylvania Avenue. NW, Suite 809

Washington, DC 20004

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT LICENSE RENEWAL

REVIEW (TAC NO. MC6441)

Dear Mr. Klima:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating license for Monticello Nuclear Generating Plant (Monticello) which Is located in the

City of Monticello, Wright County, Minnesota, on the south bank of the Mississippi River.

Monticello Is operated by Nuclear Management Company, LLC (NMC). The application for

renewal was submitted by NMC on March 24,2005, pursuant to NRC requirements at Title 10

of the Code of Federal Regulations Part 54 (10 CFR Part 54). The NRC has established that.

as part of the staff review of any nuclear power plant license renewal action, a site-specific

Supplemental Environmental Impact Statement (SEIS) to Its "Generic Environmental Impact

Statement for License Renewal of Nuclear Plants" (GElS). NUREG-1437, will be prepared

under the provisions of 10 CFR Part 51, the NRC regulation that implements the National

Environmental Policy Act of 1969 (NEPA). In accordance with 36 CFR 800.8, the SEIS will

Include analyses of potential Impacts to historic and cultural resources. A draft SEIS Is

scheduled for publication In February of 2006, and will be provided to you for review and

comment.

If you have any questions or require additional Information, please contact the Environmental

Project Manager. Ms. Jennifer Davis, at 301-415-3835 or JXD10 @ nrc.gov.

Sincerely.

Pao-Tsln Kuo. Program Director

License Renewal and Environmental Impacts Programs

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket No.: 50-263

cc: See next page

August 2006 E-5 NUREG-1437, Supplement 26 I
Appendix E

'0 UNITED STATES , ,, NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

June 2, 2005

Dr. Nina M. Archabal

State Historic Preservation Officer

Minnesota Historical Society

State Historic Pres. Office

345 Kellogg Blvd West

St. Paul, MN 55102-1906

SUBJECT: MONTICELLO NUCLEAR GENERATING PLANT LICENSE RENEWAL

REVIEW (TAC NO. MC6441) (SHPO Number-. 2004o2193)

Dear Dr. Archabal:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating license for Monticello Nuclear Generating Plant (Monticello). which is located in

Wright County, Minnesota, on the southern bank of the Mississippi River. The nearest large

city is St. Cloud, 22 miles to the northwest and upstream of the Monticello site. The Twin Cities area of Minneapolis. St. Paul, and their surrounding suburbs, is approximately 30 miles to the

southeast of the site. Monticello Is operated by Nuclear Management Company (NMC) and

owned by Northern States Power Company, a wholly owned utility operating subsidiary of Xcei

Energy, Inc. The application for renewal was submitted by NMC on March 24, 2005, pursuant to

NRC requirements at Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54).

The NRC has established that, as part of the staff review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

'Generic Environmental Impact Statement for Ucense Renewal of Nuclear Plants" (GELS),

NUREG-1437, will be prepared under the provisions of 10 CFR Part 51, the NRC regulation

that Implements the National Environmental Policy Act of 1969 (NEPA). In accordance with

36 CFR 800.8, the SEIS will Include analyses of potential Impacts to historic and archaeological

resources.

In the context of the National Historic Preservation Act of 1966, as amended, the NRC staff has

determined that the area of potential effect (APE) for a license renewal action Is the area at the

power plant.site and its Immediate environs that may be Impacted by post-license renewal

land-disturbing operations or projected refurbishment activities associated with the proposed

action. The APE may extend beyond the immediate environs In those Instances where postlicense renewal land-disturbing operations or projected refurbishment activities specifically

related to license renewal may potentially have an effect on known or proposed historic sites.

This determination is made Irrespective of ownership or control of the lands of interest.

While preparing its application, NMC contacted your office by letter dated February 10, 2005.

In that letter, NMC stated there are no plans to significantly alter current operations or engage

in any land-disturbing activities during the license renewal period. NMC further stated that it is

currently revising existing site procedures to incorporate guidance for the handling of items of

NUREG-1437, Supplement 26 E-6 August 2006 1
Appendix E

N. Archabal -2-

potential historic and archaeological significance, and cultural resources during any landdisturbing activities. Your office responded by letter dated March 30. 2005. stating that no

historic properties listed on or eligible for listing on the National Register of Historic Places will

be affected by the proposed action.

On June 30, 2005, the NRC will conduct two public NEPA scoping meetings at the Monticello

Community Center. 505 Walnut Street In Monticello, Minnesota. You and your staff are Invited

to attend. Your office will receive a copy of the draft SEIS along with a request for comments.

The anticipated publication date for the draft SEIS is February 2006. If you have any questions

or require additional Information, please contact Ms. Jennifer A. Davis, Project Manager, at

301-415-3835 or JXD10)nrc.gov.

Sincerely.

Pao-Tsln Kuo. Program Director

License Renewal and Environmental Impacts

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket No.: 50-263

cc: See next page

August 2006 E-7 NUREG-1 437, Supplement 26 I
Appendix E

0 UNITED STATES 710 NUCLEAR REGULATORY COMMISSION

0 WASINGTON, D.C. 20555-001

June 3, 2005

Mr. Dan P. Stinnett

Field Supervisor

U.S. Fish and Wildlife Service

1 Federal Drive

BHW Federal Building

Fort Snelling, MN 55111-4056

SUBJECT: REQUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR THE MONTICELLO NUCLEAR GENERATING PLANT

LICENSE RENEWAL (TAC NO. MC6441)

Dear Mr. Stinnett:

The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application submitted by

Nuclear Management Company, LLC (NMC) for the renewal of the operating license for

Monticello Nuclear Generating Plant (Monticello). Monticello, a single nuclear unit plant, is

located In the City of Monticello In Wright County. Minnesota. on the south bank of the

Mississippi River. As part of its review of the license renewal application, the NRC Is preparing

a Supplemental Environmental Impact Statement (SEIS) under the provisions of the National

Environmental Policy Act (NEPA) of 1969, as amended, which Includes an analysis of pertinent

environmental Issues. including endangered or threatened species and impacts to fish and

wildlife. This letter Is being submitted under the provisions of the Endangered Species Act of

1973, as amended and the Fish and Wildlife Coordination Act of 1934, as amended.

If the license is renewed, the unit that would operate under the renewed license would use

existing plant facilities and transmission lines and would not require additional construction or

disturbance of new areas. Any maintenance activities would be limited to previously disturbed

areas. The site consists of approximately 2,150 acres with roughly two miles of frontage on

both banks of the Mississippi River in Wright and Sherburne Counties. The majority of the

acreage Is located on the southern side of the river with approximately 450 acres on'the

northern side of the River. Approximately 50 acres are occupied by the plant and its supporting

facilities. The remaining acres are undeveloped with approximately 174 acres leased by local

farmers and 144 acres are under lease for recreational use.

The circulating water system utilizes both open and dosed cycle operating modes, as well as a

combination of the two. Cooling water Is drawn and discharged to the Mississippi River through

an approach channel and discharge canal. Monticello Is also equipped with two mechanical

draft cooling towers enabling complete or partial recirculation of cooling water when required by

special permit (NPDES) conditions. The circulating water system components include the

intake structure, circulating water pumps, main condenser, discharge structure, cooling tower

pumps, two Induced-draft cooling towers, and discharge canal.

Currently, there are seven transmission lines emanating from the Monticello Substation. The

transmission lines in the scope of the environmental review for license renewal are those that

were constructed for the specific purpose of connecting the plant to the transmission system.

Transmission lines installed as a result of the construction and operation of Monticello are the

Monticello-Coon Creek 345kV line and the Monticello-Parkers Lake 345kV line totaling about 60

NUREG-1 437, Supplement 26 E-8 August 2006 1
Appendix E

D. Stinnett -2-

miles of rights-of way. Xcel Energy controls these corridors through permanent easements

purchased from land owners at the time of construction. These easements prohibit the use of

property that could adversely affect the safe and reliable operation of the transmission lines.

These transmission line corridors traverse Sherburne, Anoka, Wright, and Hennepin Counties.

The transmission lines and site boundary are Identified in Enclosures 1 and 2.

To support the environmental Impact statement preparation process and to ensure compliance

with Section 7 of the Endangered Species Act, the NRC requests a list of species and

information on protected, proposed, and candidate species and critical habitat that may be In

the vicinity of Monticello and Its associated transmission line rights-of-way. In addition, please

provide any Information you consider appropriate under the provisions of the Fish and Wildlife

Coordination Act.

On June 28 through 29, 2005, we plan to conduct an environmental site audit at the Monticello

site. We will hold two public NEPA scoping meetings on June 30. 2005. at the Monticello

Community Center in Monticello, Minnesota. You and your staff are invited to attend both the

site audit and the public meetings. Your office will receive a copy of the draft SEIS along with a

request for comments. The anticipated publication date for the draft SEIS Is February 2006. If

you have any questions concerning Monticello, the license renewal application, or other aspects

of this project, please contact Jennifer A. Davis, Environmental Project Manager, at

301-415-3835 or by e-mail at JXD10@nrc.gov.

Sincerely,

/7•Pao-Tsin Kuo, Program Director

(Lcense Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket No.: 50-263

Enclosures: As stated

cc w/enc.: See next page

August 2006 E-9 NUREG-1437, Supplement 26 I
Appendix E

Monticello Nuclear Generating Plant

Application for Renewed Operating License

Appendix r - Environmental Report

FIGURE 3.1-2

MONTICELLO 345-KV TRANSMISSION CORRIDORS

THE PROPOSED ACTION Page 3-19

NUREG-1437, Supplement 26 E-1I0 August 2006 1
Appendix E

Monticello Nuclear Generating Plant

Application for Renewed Operating License

Appendix E - Environmental Report

FIGURE 2.1-3

SITE BOUNDARY

I' .If........ -

>a I ... 1• ••............. ...................

% M,

____ '... -•' I

I!

,, • • .. I ... . i

-w Rw wo•.d A F.nm .m P'M"y Roads •"wowe•

- au-m~d - - -PW 2-W

O- n. -" N aI Irhwnwd eB*,' Fem O 0 W012001800c2400 Fed

200 0 2W 400 •I•

SITE AND ENVIRONMENTAL INTERFACES Page 2-75

August 2006 E-1 1 NUREG-1437, Supplement 26 1
Appendix E

. United States Department of the Interior

HSH AND WVILDLTFE SERVICE

TwAn a•ili Feld Office

4101FAst UOd Street

Bloominpm. Min•..•oa 55425.1665

JUL 13 2005

Mr. Pao-Tsin Kuo

Program Director

License Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington. D.C. 20555-0001

Dear Mr. Kuo:

ThWs responds to your June 3, 2005, letter, requesting a list of federally threatened or

endangered species and information on proposed and candidate species and critical habitat

that may be in the vicinity of the Monticello Nuclear Generating Plant. The project site is

located on the right descending bank of the Mississippi Riverjust upriver of Monticello in

theNEl/4 of the SEIl4 of Section 32, T122N, RP25W, Wright County, Minnesota. The

U.S. Nuclear Regulatory Commission (NRC) Is currently reviewing an application

submitted by Nuclear Management Compaiy, LLC (NMC) for the renewal of the operating

license for the Monticello plant. NMC has applied for a 20 year extension on its current

operating license, which expires in 2010.

In addition to the nuclear generating plant, the project also consists of two transmission

lines. The Coon Creek line extends from the faciliiy across the Mississippi River to

Sherbume County and then cast to Anoka County and south to the city ofCoon Creek. The

Parkers Lake line extends from the facility southeast through Wright County to Hennepin

County and then south to Parkers Lake in the city of Plymouth. As part of the license

renewal application, the NRC is preparing a Supplemental Environmental Impact

Statement under the provisions of the National Environmental Policy Act of 1969, as

amended.

The Endangered Species Act (Act) of 1973, as amended, requires Federal agencies to

consult with the Fish and Wildlife Service (Service) on proposed actions that may affect

federally-listed threatened and endangered species and listed critical habitat. The following

listed species may be present in the action area:

NUREG-1437, Supplement 26 E-1 2 August 2006 1
Appendix E

Common Name Scientific Name Status Counti

Bald eagle HIaloaetus leucocephalus threatened Anoka, Hennepin

Sherburne, Wright

Gray wolf Canis lupus threatened Sherburne

Higgins' eye

pearlymussel Lampsilis hIggins!i endangered Hennepin

As the lead Federal agency for the proposed action, the NRC is responsible for rcviewing

the proposed action and determining whether the action may affect any of the above listed

species. If the NRC determines that the proposed action may adversely affcct any fcderally

listed species then it must notify the Service and initiate consultation under section 7(a)(2)

of the Act.

If you have questionsregarding our comments, please call Mr. R. Nicholas Rowse of my

staff at (612) 725-3549, extension 210 orby email at nick row.reri)Lw.ri',.

Sincerely.

Field Supervisor

August 2006 E-1 3 NUREG-1437, Supplement 26 1
Appendix E

_4 NUCLEAR UNITED STATES

0A NUCLEAR REGULATORY COMMISSION

0 WASHINGTON, D.C. 20555• 1

December 22, 2005

Mr. Dan P. Stinnett Field Supervi.so

U.S. Fish and Wildlife Service

I Federal Drive

BHW Federal Building

Fort Snelling. MN 55111-4056

SUBJECT: -BIOLOGICAL ASSESSMENT FOR MONTICELLO NUCLEAR GENERATING

PLANT LICENSE RENEWAL REVIEW (TAC NO. MC6441)

Dear Mr. Stinnett

The U.S. Nuclear Regulatory Commission (NRC) has prepared the enclosed biological'

assessment (BA) (Enclosure 1) to evaluate whether the proposed renewal of the Monticello

Nuclear Generating Plant (Monticello) operating license, for a period of an additional 20 years,

would have adverse effects on listed species. The proposed action (license renewal) Is not a

major construction activity. Monticello. a single nuclear unit plant, Is located in the City of

Monticello in Wright County. Minnesota, on the south bank of the Mississippi River. 30 miles

northwest of the TwIn Cities metropolitan area.

By letter dated June 3, 2005, the NRC requested that the U.S. Fish and Wildlife Service (FWS)

provide lists of Federally listed endangered or threatened species, and information on

protected, proposed, and candidate species, as well as any designated critical habitat, that may

be in the vicinity of Monticello and Its associated transmission line rightsof.way.. The FWS

responded to the NRC request on July 13, 2005. and indicated that two threatened species, the

bald eagle (Haliaeetus leucoeephalus) end the gray wolf (Canis lupus), and one endangered ,

species, the Higgins' eye pearlymussel (Lampsllls higginsh), be considered for potential impacts

of license renewal and operation.

This BA provides an evaluation of the potential Impact of renewing the Monticello operating

license for an additional 20 years of operation on two Federally listed threatened species and

* one Federally listed endangered species with the potential to occur within the vicinity of the

Monticello site or along Its associated transmission line corridors.

The NRC staff has determined the license reneval for Monticello may affect, but Is not likely to

adversely affect, the bald eagle; It will have no effect on the gray wolf or the Higgins' eye

pearlymussel.

I NUREG-1437, Supplement 26 E-14 August 2006
Appendix E

A. Stinnet : -2-

' !We are requesting youro(c•uC. rený.e;ith our detarminatio. In reaching ourconclusion, the

" NRC;3taf relied on I•nfioation .provided by the applicant,-,n rsearch pe•formed by the NRC

s".taff, andninformato from FMS (including current lifings'of.endangered species provided..

:by,*,Jhe I )].."f.yo have any•oestons rep gardg this BA or.the st6.! request,:please contact

Ms Jehrnii fer•s Environmental Prtject Manager at 301 -41 5- 5 or by e-mail at

•........:• : •.... ... ".Sincerel,.. -.. • • - .... ":

" :.n .- anovich ,Bratnh Chief

Environmental Brianich B

Division of License Renýwt

. Office of Nuclear Riactor(.Riulation

Docket No.: 50-263.' - .

.Enclosure: %As stated. " .* 

cow/end.:-.,Se next page

: .,.

I August 2006 E-1 5 NUREG-1437, Supplement 26
Appendix E

Biological 'Assess'ment

Monticello Nuclear' Plant*

Liceinse Renewal Review

Docket Number

50-263

December 2005

U.S. Nuclear Regulatory Commission

-R'ckvile, MD

I NUREG-1437, Supplement 26 E-1 6 August 2006
Appendix E

1.0 Introdution.

The U.S. Nuclear Regulatory Commission (NRC) Issues operating licenses for domestic

nuclear power plants in accordance with the provisions of the Atomic Energy Act of 1954

(AEC 1954).'as amended. and NRC.implementing regulations. The purpose and need for the

proposed action (that is;renewal of-ano'perating license) is to provide an option that allows

electric power generation to continue beyond the term of the current nuclear power plant

operating license; so future generating needs can be met If the operator and State regulatory

agencies pursue that option.

Northern States Power Company (NSP), which is a wholly owned utility operating subsidiary of

Xcel Energy Inc. (XWel Energy), has exclusive right to the energy generated by Monticello

Nuclear Generating Plant (Monticello).. Ndclear.Management Company. LLC (NMC) operates

and maintains Monticello on behalf of NSP.• NMC Is the licensee for the purposes of its current

operating license (OL) and an applicant for the renewal oftthe OL. NMC has prepared an

environmental report (ER) In conjunction with its application for renewal of the Monticello

operating license, as provided for by the f611owing NRC regulations:

Title 1 ,.'Energy, Code of Federal Regulations (CFR) Part 54."Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.' Section 54.23, "Contents

of Application - Environmental Information (10 CFRr54.23).

" . Titde 10. Energy, CFR Part 51. "Envirnmental Protection Regulations for Domestic

Licensing and Related Regulatory Functions,* Section 51.53, "Postconstruction

'Environmental Reports.' Subsection 51.53(c), "Operating License Renewal Stage'

[10 CFR 51.53(c)].

The NRC is reviewing an application submitted by.NMC (the applicant) for the renewal of the

operating license for Monticello for a period of an additional 20 years. There will be no major

construction, refurbishment. or replacement activities associated with this action. This

biological assessment examines the poteritial effects of the continued operation of Monticello

on three Federally-listed species that could occur Within the'Monticello site, near the site, or * along its associated transmission line rights4of-way (ROWs) pursuant to Section 7(a)(2) of the.

Endangered Species Act.

In aletter dated June 3. 2005 (NRC 2005a), the NRC requested that the U.S.- Fish and Wildlife

Service (FWS) provide lists of Federally listed endangered or threatened species, and

Information on protected, proposed, and candidate species, as well as any designated critical

habitat, that may be in the vicinity of Monticello and Its associated transmission line ROWs.

The FWS responded (FWS 2005a) to the NRC request on July 13,2005, and indicated that the

Federally threatened bald eagle (Haliaeetus leucocephalus) and gray wolf (Canls Iupus) and the

endangered Higgin's eye pearlymussel (Lampsllis higglnsi7) be considered for potential Impacts of license renewal and operation.

.. I '.

I August 2006 E-1 7 NUREG-1437, Supplement 26
Appendix E

• :................ ". ........ -..... '

20. Proposed4Action",•

The proposed action is the renewal of the operating licensi for Monticello.- Moticello Is located

rIn southeastern'Minnesota on the southern bank of the Mississippi River. approximately 22 ml southeast of SL'CloUd, Minhesota~and 30 mi noithwest of Minneapolis-St..Paut, Minnesota.

'The area within 6,'mi of Monicello, Minn6esta'(see Figure 1). Includes portions of Wright and

Sherbume. counties which are primad.ly agricultural (NMC 2005). The current op~erating license

for Monticello expires Septeniber'8,2010..'NMC has submitted an application to the NRC. to

renew .thioperating license for an additional 20 years of operation (until September 8. 2030).

'The renewed license, if issued, would be.effective from the date of Issuance until 20 years after

the expiration date of the current oprating ,icense .

3.0 . Environmental Setting .

.3.1 Aquatic Resources "

* The principal aquatic resource In-the vicinity of Monticello Is the Mississippi River, which Is the

,source and receiving body'of the water for the Monticello cooling system. The main aquatic

habitats on the Monticello site are the coQling-system.discharge canal and Mississippi River.

The transmission lines'that are ,fithin scope of the lice'nse'renewal review for Monticello cross

several streams and rivers. The Monticello&Parkers Lake'line crosses Otter Creek, County

Ditch #9. Crow River. Rush Greek, and Elm Cdreek; whe the Monticello-Sherbume

County-Coon Creek line crosses the*Mississippl RiverElk River,:St Francis'River, Tibbits

Brook, Trott Brook, and the Rum River.

The Montmello plant facilities are located on the southern bank of the Mississippi River In

Wright County at Mississippi RIver.Mile.(RM) 900. Near Monticello, the Mississippi River Is

broad and turbulent' The average river velocity varies from about 1;5 to 2.5 ft/s. -The river 1.5

ml upstrean to 1.5 ml downstream of the plant loses 10 ft in elevation, resulting In rapids and

current velocities that exceed 4.9 ft/sec (NMC 2005). T'[he main channel of the Mississippi River

Is approximately 980 ft wide in the vicinity of the Mon.ticello site. This portion of the river is also'

shallow, averaging about 6.2 ft deep (Knutson et ;iL.1976).. WIthin backwaters and protected

shoremfine&areas."the river:is less than 2 ft deep withlift and ihud substrates, whereas the main.

channel substrates consist of gravel, rubble, and boulders with.some sand (Afzal et al. 1975).

:.A number of physical and themical stresses have'caused major changes and modifications to

the aquatic resources within'the Upper Missis~lppl River. Basin. Dams, arn six associated..

headwater reservoirs, occur on the Mississippi River between Its headwaters at Lake tasca and

St. Anthony Falls Lock'and Dam.(RM 854) nearth6 Twin Cities. Sinoe there Pre no locks on

these headwater dams, the river Isnot used for commercial navigation above the Twin Cities -

(NMC 2005). The' Mississippi River In. Ainresota Isused for a .arety of purposes, Including '

drinkIng'water, Industrial use, Irrigatin, ecreatio, toursm. ar: conservation.

2

I NUREG-1 437, Supplement 26 E-1 8 August 2006
Appendix E

6-M.LE SITE VICINITY

Figure 1. Location of Monticello

Despite the modifications and multiple competing uses of the Upper Mississippi River, the

overall fish blodiversity has been persistent and resilient (USGS 1999). Impacts to the river

include urban. Industrial, and agricultural cohtarninants; steam modification; water diversions;

land use changes; dredging; shoreline modifications; and wetland deliniations and modifications

(Weitzell et al. 2003; Genet and Chlrhart 2004). In Minnesota, 75 species of fish have been -

reported within the upper portion of the Mississippi River (Hatch and Schmidt 2004). Fifty-one

species have been collected by electroshocking and seining within the Monticello site vicinity

since sampling began during pre-operational years (NSP 2004). The fish community In the

Monticello area has remained about the same since before the plant became operational, with

only minor variations occurring between areas upstream and downstream from the Monticello

I August 2006 E-1 9 NUREG-1437, Supplement 26
Appendix E

discharge (NSP 2004). Among the 27:specles collected by electroshocking, the major species

Include the shorthead redhorse (Moiostoma macrolepidotum). silver redhorse (M. anisurum).

common carp (Cypnnus carpio), srnilmouth bass (Micropterus dolomieu), northern hog sucker

(Hypentelium nigricans); white sucker (Catostomn 4ommersohn),,channel s catfish (Ictalurus

punctatus), and walleye (Sander yitreus) (NSP 2004). Forty-four species have been collected

In seining samples since 1970. The major species collected Include the sand shiner (Notropis

stramineus), spotfin shiner (Cypdinela spiloptera), bluntnose minnow (Pimnephales notatus), and

bigmouth shiner (N. dorsaffs) (NSP 2004)....

The spotfin and sand shiners are the rnajor forage fish -species in the'area (NSP 2004).

Common game species Included the smallmouth bass, black crappie (Pomoxis

nlgromaculatus); yellow perch (Perca flavescens), and walleye: Other sport fish include

northern pike (Esox lucus), common carp; and black bullhead (Arnelurus melas) (Amish et al.

1978). A commercial fishery does not occur near Monticello (Amish et al. 1978).

The major primary produce rs within the Monticello area are periphyton.which contribute an estimated 60 to 82% of the primary production In the Monticello area (Amish et al. 1978). Peak

pedphyton production occurs In summer. Phytoplankton In the Upper Mississippi River is

dominated by diatoms and green algae,. and contributes..18 to 40% of the primary productivity In

the Monticello area.("Aish et al 1978). The macrophytesifound In the immediate area near.

Monticello Include the American pondweed (Potamogeton nodosus). sago pondweed (Stuckenia pectinatus), and antifever fontinalis moss (Fontinalis antipyretica). The macroscopic

green alga (Cladophora glomerata) also occurs in the area. Overall, a low abundance of

macrophytes occurs in theMonticello area due to high currents and shifting sand and gravel

substrates (Amish et al. 1978).

Near Monticello, the zooplankton community is comprised of protozoans, rotifers, cladocerans,

and copepods (Afzal et al. 1975; Amish et al. 1978).

The most abundant groups of benthic macroinvertebrates near Monticello Include oligochaetes

(aquatic annelid worms), mayflies, caddisflles, aquatic beetles, midges, black flies, aquatic

-snails, and fingernail dams (Amish et al.'1978). The non-channel areas of th6 Upper

Mississippi River consistently support more benthic macroinvertebrate speclesthan the main

channel area (USGS 1999). This-was also noted near Monticello where 66 genera (of

macroinvertebrates were collected In the backwaters, while only 24 genera were collected from

the main channel (Amish et al. 1978).

The Upper Mississippi River contains a rich assemblage of freshwater mussels. Historically, as

many as 50 species of mussels have been docurnihted from the Upper Mississippi River, but

only 30 species have been reported In recent surveys. Many are rare (i.e.. listed as

endangered, threatened, or of special concermby one or more states [USGS 1999]). The

freshwatermussels within the Upper Mississippi River have been adveisely Impacted by

activiJes such as collection for fh pear! button and cultured pearl Industries,. siltation

(associated with agriculture, poor land management, and Impoundments), pollution from

4

I NUREG-1437, Supplement 26 E-20 August 2006
Appendix E

agriculture and industrial chemicals, establishment and maintenance of the navigation channel,

dams, loss of appropriate fish host species, and competition from exotic species, particularly

the zebra mussel (Dreissena polyorpha).(USGS 1999; Weitzell et al..2003).

The range of some mussel species has been expanding above St. Anthony Falls (located at

RM 854.46 mi downstream of Monticello), as fish (hosts for mu~sel glochidia [the parasitic larvae of native freshwater mussels]) can now circumnavigate the two navigation locks at this

location (Kelner and Davis 2002). About 13 mussel specles currenty occur upstream of St.

Anthony Falls (MNDNR 2003a). Only six species were recently collected above Coon Rapids

Dam (RM 866) white heelsplitter (Lasmigona complanata), giant floater (Pyganodon grandis),

plain pocketbook (Lampsllis cardium), fatmucket.(L s/llquoidea), black sandshell (Ugumia

recta), and pink h'eelsplitter (Potamilus alatus) (Kelner and Davis 2002). No inf6rrnation on

mussel species within the immediate area of Monticello Is available..

The zebra mussel became established in the Upper Mississippi River by 1992 and has

continued to spread throughout the river sys'tem.-Its increase causes a decline among many

native mussels, as It can out-compete native species for oxygen and food and Is so prolific that

It can smother native mussel beds (FWS 2001b). To date, known populations of the zebra

mussel within the Mississippi River have not been found above the Twin Cities area (St.

Anthony Falls Lock'and Dam) (MNDNR 2005). They were not present between RM 854 and

RM 848 (Pool 1), and were found to be sparse between RM 848 and RM 797 (Pools 2 and 3)

(Kelner and Davis 2002). Similarly, the Asiatic clam (Corbicula flur~inea), another invasive

mollusc species that has caused condense'r tube dogging problems at power plants,'has not

been found above the Twin Cities area of the Mississippi River (MNDNR 2003a).

3.2 Terrstrial Resources

The Monticello site is approximately 2150 acres, and has roughly 2 mi of shoreline on the north

and south banks of the Mississippi River. in Wright and Sherburne Counties (NMC 2005). The

Monticello site is located in a region dominated by rivers, streams, and lakes (NMC 2005). r Land use within the region is primarily agricultural; therefore,, natural deciduous climax

.vegetation communities previously found within the city limits of Monticello have been reduced

to remnant patches of maple (Acer.spp.),*basswood (Tilia americana), elm (Ulmus spp.), oak

(Quercus spp.). and hackberry (Celtis occidentalis). These patches are restricted mostly to

larger river islands and small Isolated pockets along the river banks (AEC 1972).

The Upper Mississippi River near the Monticello site supports a variety of plant and animal

species that are typical of free-flowing. upper Midwestem rivers (NMC 2005). In general, facilities In use at the Monticello site are located on previously cultivated areas and consist of

early-succession forbs and grasses. Upland forests on the Monticello site are predominantly

northern pin oak (Quercus belipsoldalis), green ash (Fraxinus pennsylvanlca), basswood, and

prickly ash (Zanthosxylum amerlcahun). Forested wetlands on the northeast bank of the river

and the river islands include American elm (Ulmus americana), box elder (Acernegundo), silver

maple (Acer sacchadnum), cottonwood (Populus deltoldes), and black willow (Salix nigra)

.(MCBS 1998).

I Augusit 2006 E-21 NUREG-1437, Supplement 26
Appendix E

Mammals typical of the area and Identified within the Monticello site Indlude white-tailed deer

(Odocotleus virginianus); red fox (Vulpes vulpes), racooor .(Pr6cyon lotor), red squirrel.:.'..'

(Tamiasciurus hudsonicus), grey squirrel (Sciurus carolinensis), short-tailed shrew.(Blarna

brevicauda), southern red-backed vole (CleIthrononys gapperi); meadow vole (Microtus

pennsylvanicus),;mice (Peromyscus spp.). plains pocket gopher (Geomys bursadius). .

white-tailed Jackrabbit (Lepus townsendii), beaver (Castor canadensls), muskrat (Ondatra

zibethicus), gray fox (Urocyon cinereoargenteus). coyOte 4(Canis iatrans), eastern fox squirrel

(Sciurus niger), eastern chipmunk (Tamias striatus), Americanmink (Mustela vison), weasels

(Mustela frenata, M. "ermlnea, and M. nlvalis). and striped skunk (Mephitis mephitis) (AEC 1972;

NMC 2005).

Furthermore, the Sherco Environmental Monitoring and Ecological Studies Program (NMC

2005) identified 99 avian species over a.ten-yearmontdorlng period during breeding season

road transects surveys and in a floodplain near the Monticello site. The most abundant species

observed during these surveys weire mou.ring dove (Zenalda macroura), cliff swallow

(Petrochelidon pyrdhonota), barn swallow (Hirundo rustica), American robin (Turdus

migmtorius), European starling (Stumus vulgarts), vesper sparrow (Pooecetes gramineus);.

red-winged blackbird (Agelaius phoeniceus). common grackle (Quiscalus quicula), American

goldfinch (Carduelis t.sftis), and house sparrow (Passer domesticps)..Game species commonly

harvested within the vicinity of Monticello are ruffed grouse (Bonesa umbellus), grey partridge

(Perdix perdix) and ring-necked pheasant (Phasianus co/chicus) (NMC 2005). Waterfowl

commonly encountered along the river shoreline are Canada goose (Branta canadensls),

mallard (Arias platyrhynchos). and wood duck (Abr sponsa)..: Grassland/woodland ecotone

avian species include'eastern meadowlark (Stumella magna), western meadowlark (Sturnella

neglecta), American'robin. blue jay (Cyanocitta-crfstata). eastern bluebird (S/ei.a sialls),

northern flicker (Colaptes auratus), red-tailed hawk (Buteojamaicensis). and American kestrel

(Falco'sparvedus)(NMC 2005).

In Its Environmental Report, the applicant Identified seven transmission lines that emanate from

the Monticello site. The two transmission lines Installed as a direct result of initial construction

and'operation of the Monticello site (and are, therefore, within the scope of the license renewal

environmental report) are the Monticello-Coon Creek 345-kV line and the Monticello-Parkers

Lake 345-kV line (AEC 1972), and are pertinent to this analysis (see Figure 2 and Table 1).

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

system even after the decommissioning of Monticello.

I NUREG-1437, Supplement 26 E-22 August 2006
Appendix E

" MWNTICELLO 345-K• TRA.NSMOION CORIPDORS

-" ..?

C.

Figure 2. Monticello Transmnission Lries

: '7 " "-

I August 2006 E-23 NUREG-1437, Supplement 26
Appendix E

Table 1. Monticello Transmission Unae" Rights-of-Way

No. of .Approximate Corridor Corridor

Substation Lines,.. kV Distance (ml) Corridor Width (ft) Area (ac)

Sherbume 1 345, 43.1 Montcello-Coon .Varies from 749.7

Cotunty Creek . 125 to240

Elm Creek 1 345 37.1 Monticello- Vales from 957

Parkers Lake 165 to 240

Source: Xcel 2005

Xcel Energy is responsible for maintenance on transmission line ROWs for Monticello's owner

(NSP) and operator (NMC). Xcel Energy. Implements specific programs for ensuring continued

operation of its transmission lines, continued compatibility of land uses on the transmission

corridors, and environmentally sound maintenance of the corridors (NMC 2005). The Xcel

Energy program for conductor and tower maintenance Includes monthly fixed-wing aerial

patrols for the 345-kV lines and annual helicopter patrols'on all lines in the system (NMC 2005).

Xcel Energy's vegetaion management in ROWs is focused on reducing risk to transmission

lines by keeping corridors free of tall-growing vegetation. Low-growing trees, shrubs, and

grasses are encouraged by selectively removing tall-growing trees and brush. Qualified

line-clearance tree trimmers manually cut andi prune using approved mechanical equipment.

such as hydro-axes, and selective application of approved herbicides (NMC 2005). Approved

herbicides are applied In strict compliance with all Federal, state, and local laws and

regulations. Similarly, talg frees typically located Just off the right-of-way that have a high

probability of failure and sufficient height toymake contact with the conductors and/or structures

are pruned or cut as appropriate. Vegetation control Pycles vary based on line voltage and

vegetation conditions, but typically occur on interVaif from 2 to 8 years.

4.0 Assessment of Federally Listed Species and Critical Habitat

Three Federally listed species are evaluated In this biological assessment because of their

proximity. to Monticello or its associated transmission lines (Table 2).' No Federally designated

candidate species, nor ciltical habitat for any threatened or endangered species, exist at the

Monticello site or along the associated transmission corridors (NMC 2005; FWS 2005a).

8

I NUREG-1437, Supplement 26 E-24 August 2006
Appendix E

Table 2. Terrestrial and Aquatic Species Listed as Endangered or Threatened by the U.S. Fish

and Wildlife Service and that Occur or Potentially Occur Within the Monticello Site or the

Associated Transmission Line Rights-of-Way

Scientific Name Type Common Name Federal Status Counties

Lampsllis higginsli Invertebrate Higgins' eye Endangered Hennepin

pealymussel

Haliaeetus Bird bald eagle Threatened Anoka, Hennepin,

leucocephalus Sherburne, Wright

Canils lupus Mammal gray wolf Threatened Sherbume

Source: FWS 2005a

Higgins'Eye Pearlymussel (Lampsilis higginsit)

The Federally listed endangered Higgins' eye peadymussel is only found in the Mississippi River,

St. Croix River in Wisconsin. the Wisconsin River. and the Rock River In Illinois. It may be

present within Hennepin County over 45 river miles (RM) downstream of the Monticello site

(FWS 2005a). It has not been reported from Sherburne or Wright counties where Monticello Is

located. The Higgins' eye pearlymussel spawns in late summer, but larvae are retained In the

marsupia until they are released during the following spring or summer (FWS 2003). The

Higgins' eye pearlymussel most frequently occurs In medium to large rivers with current velocities

of about 0.5 to 1.5 ft/sec and in depths of 3 to 20 ft. with firm, coarse sand or mud-gravel

substrates (FWS 2000, 2001a).

No critical habitat has been designated for the Higgins' eye pearlymussel. However, ten

Essential Habitat Areas (EHAs) for the Higgins' eye peadymussel occur within the Upper

Mississippi River watershed. EHAs are locations known to contain reproducing populations of the

Higgins' eye pearlymussel in association with a healthy and diverse unionid community (e.g.,

mussel beds) (FWS 1998). No EHAs occur within the Mississippi River drainage dose to

Monticello. The most upstream EHA Is at Whiskey Rock. Iowa, at Mississippi RM 656, which is

downstream from Lock and Dam 8. Monticello Is located some 240 RM upstream. The closest

EHA for the Higgins' eye pearlymussel occur In the St Croix River (Hornbach 2004). which flows

Into the Mississippi River at RM 811 about 89 mi downstream from Monticello.

Suitable fish hosts for the glochldia (larvae) Include freshwater drum (Aplodlnotus grunniens),

largemouth bass (Micropterus salmoides), black crappie, yellow perch, sauger (Sander

canadensls), and.walleye; while marginal fish hosts Include northern pike, bluegill (Lepornis

macmchirus). and green sunfish (L. cyanellus) (FWS 2003).

In 2000-2001, an empty Higgins' eye peartymussel shell was found In Upper Pool 3 of the

Mississippi River (the area below Lock and Dam 3 in the area where the St. Croix River enters

the Mississippi River at RM 811 (Kelner and Davis 2002). In 2000. 200 specimens of Higgins'

9'

I August 2006 E-25 NUREG-1437, Supplement 26
Appendix E

eye pearlymussel were relocated from Pool 14 of the Mississippi River, to Upper Pool 2 and 3

(Keiner.and Davis 2002). The transplanted mrussels are over 50 RM downstream of Monticello.

Reintroductions of the Higgins' eye peadymussel Into the rivers from which It has been

extirpated hýI e been conducted since 2000, but It is toodearly to determine the success of

these reintroductions (FWS 2003).

The FWS (FWS 2000) has determined that the continuation of the current operation and

maintenance activities of the 9-ft navigation.channel in the Mississippi River for another 50

years would jeopardize the continued existence of.the Higgins' eye pearlymussel. Two of the

EHAs for the Higgins' eye pearlyrnussiel, both located In Wisconsin, are located within the

navigation channel (FWS 2000). However, the major adverse effect would be associated with

continuing upstream transport of zebra mussels by barge traffic. Currently, there are no

effective ways to control established populations of zebra mussels at the scale required to

elimrn•te their threat to the Higgins' eye peartymussel (FWS 2003).

Coon Rapids Dam. located over 5 ml downstream of where Rum River enters the Mississippi

River relative to the plant, serves as a faunal barrier to upstream migration of mussels via their

host fish (Kelner and Davis 2002)..

The Higgins' eye pearlymussel Is not known to occur further upstream than Pool 2 of the

Mississippi River, which Is mostly located downstream from the Twin Cities area (Kelner and

Davis 2002; Hombach 2004) over.50 RM downstream of Monticello.. Therefore, potential • Impacts from the operation of Monticello are too far removed to adversely affect the species.

The Monticello cooling-Water intake and discharge are closely monitored under.the National

Pollutant Discharge Elimination System (NPDES) program. NPDES permit limits are reviewed

on a regular basis by the Minnesota Pollution Control Agency to ensure the protection of

aquatic biota, Including fish species that can serve as hosts for the giochidia of the Higgins' eye

pearlymussel. Additionaily,-there are no plans to conduct refurbishment&or construction at.

Monticello.

On the baslsof the negligible anticipated impacts of the cOoling-water intake and discharge on

the Higgins' eye peartymussel and its current distribution, the NRC staff concludes that

continued operation of Monticello over the 20-year license renewal project will have no effect on the Higgins' eye pearlymussel.

Bald Eagle (Haliaietus; eucocephalus)

One active bald eagle nest is known from the Mpnticello site. The nest is located on Beaver

Island in the Mississippi River north-northwest of the Monticello pow~er block. Beaver Island is

wholly within the Monticello site. During the June 2005 site audit, the NRC staff observed an eagle perched next to the nest Subsequent discussions with the NMC biologist confirm that

this is an active nest (NRC 2005b).

10

I NUREG-1437, Supplement 26 E-26 August 2006
Appendix E

During the June 2005 site audit, the NRC staff also observed an additional nest on a

transmission towver located on the Monticell0-Coon Creek 345 kV line. Again, discussions with

the NMC biologist also confirm that this also Is an active nest (NRC 2005b).

NMC has adopted the Minnescta Department of Natural Resources Management Guidelines for

Bald Eagle Breeding Areas, and the U.S. Fish and Wildlife Service (FWS) Northern States Bald

Eagle Recovery Plan (MNDNR 2003b) recommendations for protecting individual occupied and

active nest sites. Additionally, on April .119, 2002, Xcel Energy entered intoa memorandum of

understanding (MOU) which establishes procedures and policies to avoid avian Injuries or

fatalities on company property (Xcel Energy et al. 2002).

The nest on Beaver Island Is located approximately 1000 feet north-northwest from the

Monticello power block In which the majority of site activityoccurs. Activitiesthat might affect

nesting success, such as landscape alterations and construction;would be outside both the

Primary and Secondary Protective Zones as defined by the MNDNR management guidelines.

The licensee does not engage in any buming or forest maintenance activities within these zones and physical security requirements ban unauthorized human entry and low flying aircraft

over company property on both sides of the Mississippi River. Additionally, the island

properties located within the river system (e.g. Beaver Island) are posted against trespassing.

There Is no vehicular access'to these areas except by boat; however, unauthorized access by

boat would result In action by the site security force.

The majority of adverse human activities would also be restricted throughout the year In the

Tertiary zonea(660 feet to 114 mile from the nest), with restrictions on landscape alterations and

burning. The fact that the station predates the construction of the nest, and that the station has

been in almost continuous operation during past nesting activity, strongly suggests that the

activities associated with Monticello operation are not likely to adversely affect bald eagles

using the nest. In fact,.the limitations on unauthorized access, the relatively pristine nature of

the majority of the 2,150 acre site, theroughly two miles of undeveloped shoreline on the north

and south banks of the river (with the exception of the area of the plant), and the warm water

discharge that attracts and concentrates fish for foraging, particularly during the winter,

suggests'that the Monticello site could be considered beneficial to the species.

The nest located on the transmission tower along the Monticello-Coon Creek 345kV line Is

located in an area of limited public access. Periodic line maintenance for vegetative control is

performed, on average, every 4 years and consists of the removal of danger trees on either

side of the ROW and the dearing of vegetative growth under the lines that could come within

close proximity orthe conductors (NMC 2005). Such line maintenance Is achieved by selective

tree removal Mong the edges of the transmission corridor that could pose a danger If toppled into the line and selectively removing potentially tall-growing trees and brush in the actual

* ROW. The area where the Monticello-Coon Creek line nest Is located Is relatively open and

poses little line risk due to danger trees; therefore, future removal of large trees along the

margins of the transmission lines Is unlikely. Additionally, because of the *eagle nest, selective

vegetative clearing activities within the ROW Is restidted to summer, which Is outside the

critical period of 10 February to 1 May, as defined In the MNDNR management guidelines.

.11

I August 2006 E-27 NUREG-1 437, Supplement 26
Appendix E

The remoteness of the Monticello-Coon Creek nest site, and.the timing of infreq'uent vegetative

maintenance leads the staff to conclude that contlnuel plant operation is not likely to adversely

affect the bald eagle nest site on the Monticello•Coon Creek transmission line.

Lehman (2001) summarized Ihe literature regarding raptorelectrocutions on power lines, and

emphasized that nearly all electrocutions In the United States occur on comparatively lowvoltage distribution lines supplying Individual user "and businesses, not transmission lines. The

spacing of conductors on transmission towers is typically greater than the wingspan of raptors,

and therefore, electrocdtions are highly unlikely.

There are no known reports of bald eagle collisions with the Monticello transmission lines or

other Monticello structures. Xcel Energy has a program In place to Install flight diverters on its

* transmission lines to reduce potential for avian collisions and has entered into a MOU with the.

FWS and MNDNR to develop and Implement an avian protection plan (Xcel Energy et al. 2002).

The MOU requires that any injuries or mortalities to bald eagles associated with transmission

line collisions would be reported to the MNDNR.-" The requirement to report all onsite raptor.

mortalities and any bald eagle lnju.ries or mortalities to"MNDNR is part of NMC's procedures.

Based on the location of the onsite nest relative to the power block, the remoteness of the riest

on the Monticelio-Coon Creek transmission line, NMC's commitment to follow the MNDNR

Management Guidelines for Bald Eagle Breeding Areas and the FWS Northern States Bald

Eagle Recovery Plan. the actual potential for disturbance during nestirng/breeding, either from

the Monticello site activities or from ROW maintenance, is highly unlikely. The potential for bald

eagle'electrocutions and collisions Is also highly unlikely. Consequently, the NRC staff has

determined that renewal of the Monticello operating license for an additional 20 years Is not

likely to adversely affect the bald eagle at the Monticello site or the associated transmission

lines.

Gray Wolf (Cenis lupus)

The gray wolf was listed in Minnesota as Federally endangered in 1974 as a result of human

persecution and reduced prey availability. Gray wolves.in Minnesota were redassified from

endangered to threatened In 1978, to allow for special regulation.under Section 4(d) of the Act.

Since 1977, gray wolf populations In Minnesota have expanded. Population recovery goals of

1250 to 1400 Individuals have been achieved, with populations at or above that level since the

'late 1970s (FWS 2005b). Today,wolves live In areas with higher road and human densities

than previously believed to be suitable for.wolf survival. Wolves continue to disperse to areas in west-central and east-central Minnesota Oust north of Minneapolis/St. Paul), North ,nd South

Dakota, and Wisconsin (FWS 2005b). Potential impacts to the Federally-threatened gray wolf

include direct destruction of the habitat from land-disturbing activities on site, and routine

vegetation.maintenance pratices on site and along the transmission corridors. However, NMC

has not identified any land-disturbing actMtles that would be undertaken for license renewal

(NMC 2005). As gray'wolf populations recover; it is likely that they may traverse the

transmission corridors of Interest to the license renewal of Monticello. Gray wolves have not

been sighted in the Monticeflo area or on the Monticello site to date. It is possible that If the

population of gray wolves continues to increase, the species may use the Monticello site

sometime in the future. However, activities associated with future plant operations would not be

detrimental to the species.

12

I NUREG-1437, Supplement 26 E-28 August 2006
Appendix E

Vegetation management may improve habitat quality for prey hems Important to the gray wolf.

In fact, the maintenance of a large trait of undeveloped property associated with the site,

dosed to the public, with no hunting pressure, may infact be benefical to the species.

However, continued high density developmrnt around the plant Site will likely preclude the

spedes from the area..

For these reasons, the NRC staff has determined that continued operation of Monticello over

the 20-year license renewal period will have no effect on the gray wolf.

5.0 Conclusions

The NRC staff has evaluated the potential impacts of an additional 20 years of continued

Monticello operation on two Federally listed threatened species and one Federally listed

endangered species with the potential to occur within the vicinity of the.Monticello site or along

its associated transmissiOn line corridors. "Athough the Federally protected bald eagle Is known

to ose the Monticello site and associated transmission corridors, NMC and Xcel Energy have.

developed and implemented procedures to protect the species and Important habitat.

The NRC staff has determined that license renewal for Monticello may affect, but is not likely to

adversely affect, the bald eagle; and will have no effect on the gray wolf or the Higgins' eye

peartymussel.

13

I August 2006 E-29 NUREG-1437, Supplement 26
Appendix E

6.0 References

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

Protection Regulations'for Domestic Ucensing and Related Regulatory Functions.'

10 CFR Part 54. Code of Federal Regulations, Title 1 0, Eneigy, Part 54, "Requirements for

Renewal of Operating Licenses -for Nuclear Power Plants."

Afzal, M.. B.R. Oblad, B.B. Owen, F.P. Richards, and G.C. Slawson. 1975. Effects of a Heated

Discharge on theEcologi of the Mississippl River 316(a) Type*I Demonstration on the

Monticello Nuclear Generating Plant, Monticeli, 'Minnesota." Prepared by NUS Corporation,

Pittsburgh, Pennsylvania for Northern States Power Company, Minneapolis, Minnesota.

Amish, RA, V.R. Kranz, B.D. Lorenz. D.B. Wilcox, LK. Davis. and B.B. Owen, Jr. 1978.

Section 316(b) Demonstration for the Monticello Nuclear Generating Plant on the Mississippi

River at Monticello, Minnesota (NPDES Permit No. MN 0000868). Prepared by NUS

-Corporation, Pittsburgh, Pennsylvania for Northern States Power Company, Minneapolis,

Minnesota. .

Atomic Energy Act of 1954. 42 United States Code (USC) 2011, et seq.

Genet. J., and J. ChirharL 2004.. Development of a Macro'invertebrate Index of Biological

Integrity (MIBI) for Rivers and Streams of the Upper Mississippi River Basin.. Minnesota

Pollution Control Agency. Biological Monitoring Program, St. Paul, Minnesota.' Accessed at:

http:/twww.pca.state.mn.Ls/publications/reports/biormnitoring-mibiN-uppermiss.pdf on June 17,2005.

Hatch, J.T., and K. Schmidt. 2004. Fishes of Minnesota Distribution In 8 Major Drainage

Basins. James Ford Bell Museum of Natural History,' Minneapolis, Minnesota. Accessed at:

http://www.gen.umn.edulresearchlfish/fishes/distribution_table.html on June 17,2005.

Hornbach, D.J. 2004. Higgins Eye Pearlymussel aLMo,._ m iggi.s. Recovery Plan: First

Revision. U.S. Fish and Wildlife Service,-Region 3, FL :Snelling, Minnesota. Accessed at:

http:/lecos.fws.govldocslrecoveryplans/2004/040714.pdf on July 22, 2005..

Kelner, D., and M. Davis. 2002. Final Report Mussel (Bivaeiva: Unionidae) Survey of the

Mississippi National River and Recreation Corridor, 2000-01. Contract Report to the National

Park Service Mississippi National River and Recreation Areas and the Great Lakes Network

Inventory and Monitoring Program. Minne.sota Department of Natural Resources. Division of

Ecological Services. SL Paul. Minnesota. Accessed at:.

http:/triles.dnr.fsate.mn.us/ecological-services/nongame/projectsrconsgrant-reports/2002-kein

er-davis.pdf on August 4,2005.

Knutson, K.M., S.R. Berguson, D.L Rastetter, M.W. Mischuk, F.B. May, and G.M. Kuhl. 1976.

Seasonal Pumped Entrainment of Fish at the Monticello, MN Nuclear Power Installation.

Prepared by Department of Biological Sciences, St. Cloud State University,. St. Cloud,

Minnesota for Northern States Power Company, Minneapolis. Minnesota.

14

I NUREG-1437, Supplement 26 E-30 August 2006
Appendix E

Lehman, R.N. 2001. Raptor Electrocution on Power ULnes: Current Issues and Outlook.

Wildlife Society Bulletin. 29(3):804-813. Providence. Utah.

Minnesota County Biological Survey (MCBS)." 1998. Natural Communities andRare Species of

Carver, Hennepin, endScott Counties, Minnesota, St. Paul, Minnesota.

Minnesota Department of Natural Resources (MNDNR). 2003a. Field Guide to the Freshwater

Mussels of Minnesota. Minnesota Department of Natural Resources, St. Paul, Minnesota.

Minnesota Department of Natural Resources (MNDNR). 2003b. Endangered. Threatened, and

Special Concern Species of Minnesota: Bald Eagle. Minnesota Department of Natural

Resources, St. Paul, Minnesota. Accessed at'

http:./files.dnr.state.mn.uslnatural resourceslanimals/birds/eagles/factsheeLpdf on November 22; 2005.

Minnesota Department of Natural Resource (MNDNR). 2005. Invasive Species ofAquatic

Plants & Animals in Minnesota. Minnesota Department of Natural Resources, St. Paul.

Minnesota. Accessed at:

http://files.dnr.state.mn.us/ecologicalservicesrinvasives/annualreport.pdf on June 17, 2005.

Northern States Power Company (NSP). 2004. Monticello Nuclear Generating Plant

Environmental Monitoring Program: 2003-2004. Monticello, Minnesota.

Nuclear Management Company (NMC), 2005. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. .Monticello, Minnesota.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Monticello Nuclear Generating Plant, Northern States Power Company. Docket

No. 50-263, Washington, D.C.

U.S. Fish and Wildlife Service (FWS). 1998. Revised Higgins' Eye Pearly Mussel(Lamosilis

hi-qgnsii Recovery Plan. U.S. Fish and Wddlife ServiceRegion 3, Division of Endangered

Species, Fort Snelling, Minnesota.

U.S. Fish and Wdlife Service (FWS). 2000. Biological Opinion for the Operation and

Maintenance of the 9-Foot Navigation Channel on the Upper Mississippi River System. U.S.

Fish and WildlifeService, Division of Endangered Species, Fort Snelling.Minnesota. Accessed

at: http'Jiww,fws.govlmidwestlendangeredlsectlon7/umrbofinal.pdf on August 15,'2005.

U.S. Fish and Wildlife Service (FWS). 2001a. Endarngered Species Facts Higgins' Eye Pearly

Mussel.. U.S. Fish and Wildlife Service. Region 3. Division of Endangered Species, Fort

.Snelling, Minnesota. Accessed at:

http:J/www.fws.gov/midwest/Endangered/dams/hlgginseye/higgins..fs.html on August 15, 2005.

U.S. Fish and Wildlife Service (FWS).. 2001b.: Saving the Higglns'Ee Pearly Mussel

Propagatfon at Genoa National Fish Hatchery'May 2001. U.S. Fish and Wildlife Service,

Division of Endangered Species, Fort Snelling; Minnesota. Accessed at:

15

I August 2006 E-31 NUREG-1437, Supplement 26
Appendix E

http:/Mww.fws.gov/mldwestlEndangeredlclams/higginseyelpropagaron.Js.html on August 15,

2005.

U.S.. Fish and Wildlife Service (FWS). 2003.. Histor, of Mussel Harvest on the River. U.S. Fish.

and Wildlife Service. .Accessed at: http:l/www.mldwest.fws.gov/mussellharvesthtml on August

15,2005.

U.S. Fish and Wildlife Service (FWS).. 2065a. Letter from D.P. Stinnett. U.S, Fish and Wildlife

Service, Bloomington, Minnesota. to P.T. Kuo, U.S. Nuclear Regulatory Commission,

Washington. D.C. Subject: 'List of Federally Threatened or Endangered Species.' July 13.

.2005.

U.S. Fish and Wildlife Service (FWS). 2005b. Gray Woff Recovery in Minnesota, Wisconsin,'

and Michigan. U.S. Fish and Wildlife Service. Accessed at:..

http:/lwww.fws.govlmldwestlwoif/recovery/r3wolfcthtm on August 1, 2005.

U.S. Geological Survey (USGS):' 1999. Ecobi;al Status and Trends of ,he Upper Mississippi

SRiver System 1998: A Report of the Long Term Resource Monitoring Program. U.S.

.Geological Survey.Upper Midwest Environmental Sciences Center, La Crosse. Wisconsin.

TRMP 99-T001. Accessed at

http://www.umesc.usgs.gov/reports._publicaO"nsistatus..and tfends.htm! on February 21, 2003.

U.S. Nuclear Reguiatory Conmission (NRC). 2005a. Letter from P.T. Kuo, U.S. Nuclear

Regulaiory Comisslon. Washington, D.C., to D.P. S'innett, U.S. Fish and Wildlife Service.

Fort Snelling, Minnesota. Subject: *Request for List of Protected Species Within the Area

Under Evaluation for the Monticello Nuclear Generating Plant Licence Renewal (TAC No.

MC6441).' June 3.2005.

U.S. Nuclear Regulatory Commisslon (NRC).ý 2005b. E-mail from NMC to NRC, describing

protective and mitigative measures for-bald eagles. Washington, D.C.:

WeltzelU, R.E.. Jr., M.L Khoury. P. Gagnon, B.. Schreurs. D. Grossman. and J. Higgins. 2003.

Conservation Pdor*ies for Freshwater Biodiversity in the Upper Mississippi River Basin. Nature

Serve and The Nature Conservancy. Arlington, Virginia. Accessed at

httpJ/www.natureserve.org/llbrarylupperrmsdrverbasin.pdf on June 17, 2005.

Xcel Energy Environmental Services, U.S. Fish and Wildlife Service, Minnesota Department of

Natural Resources, North Dakota State Game and Fish Department, South Dakota Game, Fish

and Parks Department (Xcel Energy et al.). 2002 Memorandum of Understanding.

April 19. 2002.

Xcel Energy (Xcel). 2005.:'E-Mall.correspondence from P. Rasmussen, Xcel Energy to J.

Holthaus, Monticello Nuclear Generating Plant Subject ,Documentation of Transmission

Corridor Lengths and Widths.' June 29, 2005.

16

I NUREG-1437, Supplement 26 E-32 August 2006
Appendix E

MAY-31-206 15:31 P.02

MINNESOTA HISTORICAL SOCIETY

State Histotic Preservation Office

April26. 2006

Rani Franovich, Branch Chief

Environmental Branch B

Division of Ucense Renewal

Office of Nuclear Reactor Regulation

Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Re: Monticello Nuclear Generating Plant Ucense Renewal

Monticello, Wright County

SHPO Number. 2004-2193

Dear Rani Franovich:

Thank you for your recent submittals regarding the above referenced undertaking.

As you know, you consulted with our office regarding the undertaking in 2005, and we

concluded at that tiUe that no historic properties would be affected. Based on our

review of the Information recently submitted, we see no reason to alter that conclusion.

Contact us at 651-296-5462 with questions or concerns.

Sincerely.

Britta L Bloomberg

Deputy State Historic Preservation Officer

345 Khl Bojlev&. %W6ait PaIMhiwna 55102-1906/Telephen 651-296-6126

TOTAL P.02

I August 2006 E-33 NUREG-1437, Supplement 26
Appendix E

WIN

gak , United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

Custom House, Room 244 ,AMERICtA

200 Chestnut Street

EMYR UUTO Philadelphia, Pennsylvania 19106-2904

May 2,2006

ER06n73

Chief, Rules Review and Directives Branch

U.S. Nuclear Regulatory Commission

Mail Stop T6-D59

Washington, DC 20555-0001

The U.S. Department of the Interior (Department) has reviewed the Generic Environmental

Impact Statement (EIS) for License Renewal of Nuclear Plants, NUREG-1437, Draft

Supplement 26 (dated January 2006), regarding the Monticello Nuclear Generating Plant, Wright

County, Minnesota.

The license renewal for Monticello Nuclear generating Plant does not involve any major

construction or physical alteration of the.project area. The Generic EIS and Draft Supplement 26

adequately address the concerns of the Department regarding fish and wildlife resources, as well

as species protected by the Endangered Species Act. We concur with the preliminary

conclusions of the U. S. Nuclear Regulatory Commission (NRC) staff with respect to the impacts

of continued operations on these resources.

In a letter to the U.S. Fish and Wildlife Service (Service) dated December 22, 2005, the NRC

transmitted a Biological Assessment on the proposed license renewal for the Monticello Plant

with a determination that the renewal for an additional 20 years is not likely to adversely affect

the bald eagle at the Monticello site or along the associated transmission lines. The Service has

indicated that it concurs with the determination and will be providing an official concurrence

directly to the NRC.

Correction needed in Final EIS: On page 2-22, line 16, the statement that "To date, populations

of the zebra mussel within the Mississippi River have not been found above the Twin Cities area

(St. Anthony Falls Lock and Dam)(MNDNR 2005)" is no longer correct. On Oct. 19,2005, the

MNDNR issued a news release confirming the presence of zebra mussels within Rice Lake, an

impoundment within the Mississippi River near the City of Brainerd in Crow Wing County.

Brainerd is approximately 94 miles upstream of Monticello.

We appreciate the opportunity to provide these comments.

Sincerely,

iZ i

Michael T. Chezik

Regional Environmental Office

cc: L. MacLean, FWS, Fort Snelling, MN

I NUREG-1437, Supplement 26 E-34 August 2006
Appendix F

GElS Environmental Issues Not Applicable to Monticello Nuclear

Generating Plant

Appendix F: GElS Environmental Issues Not

Applicable to Monticello Nuclear Generating Plant

Table F-1 lists those environmental issues listed in the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GELS), NUREG-1437, Volumes 1 and 2

(NRC 1996, 1 999)(a) and 10 CFR Part 51, Subpart A, Appendix B, Table B-i, that are not

applicable to Monticello because of plant or site characteristics.

Table F-i. GElS Environmental Issues Not Applicable to Monticello

ISSUE-1 0 CFR Part 51, Subpart A, GElS

Appendix B, Table B-1 Category Sections Comment

SURFACE WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Altered salinity gradients 1 4.2.1.2.2; Monticello cooling system does not

4.4.2.2 discharge to-an estuary.

Altered thermal stratification of lakes 1 4.2.1.2.2; Monticello cooling system does not

4.4.2.2 discharge into a lake.

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and 2 4.8.1.1; Monticello does not use more than

service water, and dewatering; plants 4.8.1.2 100 gpm groundwater.

that use >100 gpm)

Groundwater-use conflicts 2 4.8.1.4 Monticello does not have or use

(Ranney wells) Ranney wells.

Groundwater quality degradation 1 4.8.2.2 Monticello does not have or use

(Ranney wells) Ranney wells.

Groundwater quality degradation 1 4.8.2.1 Monticello does not discharge to

(saltwater intrusion) saltwater.

Groundwater quality degradation 1 4.8.3 Monticello does not have or use

(cooling ponds in salt marshes) cooling ponds.

Groundwater quality degradation 2 4.4.4 Monticello does not have or use

(cooling ponds at inland sites) cooling ponds.

TERRESTRIAL RESOURCES

Cooling pond impacts on terrestrial 1 4.4.4 Monticello does not have or use

resources cooling ponds.

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

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

I August 2006 F-1 NUREG-1437, Supplement 26
Appendix F

References

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

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

for License Renewal of Nuclear Plants: Main Report, Section 6.3 - Transportation, Table 9.1,

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

Report." NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

I NUREG-1 437, Supplement 26 F-2 August 2006
Appendix G

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Monticello Nuclear Generating Plant

Appendix G: NRC Staff Evaluation of Severe Accident

Mitigation Alternatives (SAMAs) for Monticello Nuclear

Generating Plant

G.1 Introduction

Nuclear Management Company, LLC (NMC) submitted an assessment of severe accident

mitigation alternatives (SAMAs) for Monticello Nuclear Generating Plant (Monticello) as part of

the environmental report (ER) (NMC 2005a). This assessment was based on the most recent

Monticello probabilistic safety assessment (PSA) available at that time, a plant-specific offsite

consequence analysis performed using the MELCOR Accident Consequence Code System 2

(MACCS2) computer code, and insights from the Monticello individual plant examination (IPE)

(NSP 1992) and individual plant examination of external events (IPEEE) (NSP 1995a,b). In

identifying and evaluating potential SAMAs, NMC considered SAMAs that addressed the major

contributors to core damage frequency (CDF) and population dose at Monticello, as well as

SAMA candidates for other operating plants which have submitted license renewal applications.

NMC identified 40 potential SAMA candidates. This list was reduced to 16 unique SAMA

candidates by eliminating SAMAs that: are not applicable to Monticello due to design : :

differences, are of low benefit in boiling water reactors, have already been implemented at

Monticello or whose benefit has been achieved at Monticello using other means, or have

estimated costs that would exceed the dollar value associated with completely eliminating all

severe accident risk at Monticello. NMC assessed the costs and benefits associated with each

of the potential SAMAs and concluded in the ER that several of the candidate SAMAs evaluated

may be cost-beneficial and warrant further review for potential implementation.

Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC)

issued a request for additional information (RAI) to NMC by letter dated May 27, 2005 (NRC

2005). Key questions concerned: changes to the Level 2 PSA model and source terms since

the IPE; MACCS2 input data (core inventory, releases, meteorology data, and offsite economic

costs); further information on several specific candidate SAMAs; additional

information/clarification regarding SAMAs related to external events; and the rationale used by

NMC to arrive at a set of "recommended" SAMAs for further evaluation. NMC submitted

additional information by letter dated July 27, 2005 (NMC 2005b). In the response, NMC

provided: a description of the current Level 2 model and dominant risk scenarios for each

accident consequence bin; results of sensitivity studies related to radionuclide inventories,

release heights and thermal content of the plume; rationale for seemingly larger offsite

economic cost risk at Monticello; specific requested information for SAMAs related to external

events; and the rationale used to arrive at the set of "recommended" SAMAs. NMC's

responses addressed the staff's concerns.

An assessment of SAMAs for Monticello is presented below.

August 2006 G-1 NUREG-1437, Supplement 26 I
Appendix G

G.2 Estimate of Risk for Monticello Nuclear Generating Plant

NMC's estimates of offsite risk at the Monticello are summarized in Section G.2.1. The

summary is followed by the staff's review of NMC's risk estimates in Section G.2.2.

G.2.1 Nuclear Management Company, LLC's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the Monticello Level 1 and 2 PSA model, which is an updated version of the IPE

(NSP 1992), and (2) a supplemental analysis of offsite consequences and economic impacts

(essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA

analysis is based on a slight modification of the 2003 Monticello Level 1 and 2 PSA model,

referred to as the SAMA model. The scope of the Monticello PSA does not include external

events.

The baseline CDE for the purpose of the SAMA evaluation is approximately 4.5 x 10-s per year.

The CDE is based on the risk assessment for internally-initiated events at extended power

uprate conditions. NMC did not include the contribution from external events within the

Monticello risk estimates; however, it did account for the potential risk reduction benefits

associated with external events by doubling the estimated benefits for internal events. This is

discussed further in Section G.6.2.

The breakdown of CDP by initiating event is provided in Table G-1. As shown in this table,

events initiated by internal floods are the dominant contributors to CDE. Station blackout (SBO)

sequences contribute 1.52 x 106 per year (about 3 percent of the total internal events CDE),

while anticipated transient without scram sequences are insignificant contributors to CDE

(8.24 x 10'8 per year). NMC defined SBO as loss of offsite power and both emergency diesel

generators. This definition excludes the SBO-like conditions resulting from flooding-induced

loss of electrical buses which are large contributors to the internal flooding CDE. When the

contribution from flooding events is also included, events resulting in SBO-like conditions

account for the majority of the CDE.

NUREG-1437, Supplement 26 G-2 August2006 I
Appendix G

Table G-1. Monticello Core Damage Frequency

CDF % Contribution

Initiating Event (per year) to CDF

Fire protection system line break in turbine building (TB) 3.2 x 1 0V 71

931-ft elevation west

Service water (SW) line break in TB 931-ft elevation east 5.8 x 10" 13

SW line break in TB 911-ft elevation 1.8 x 10 - 4

Loss of offsite power 1.8 x 10-6 4

SW line break in residual heat removal (RHR) A room 8.9 x 10-7 2

SW line break in residual heat removal (RHR) B room 8.9 x 10.7 2

SW line break reactor building 896-ft elevation 4.5 x 10"7 1

Turbine trip 4.5 x 10"7 1

Loss of feedwa~ter 4.5 x 10? 1

Other 4.5 x 10"7 1

Total CDF (from internal events) 4.5 x 10-5 100

The Level 2 Monticello PSA model that forms the basis for the SAMA evaluation represents an

adaptation and updating of the IPE Level 2 model. The IPE Level 2 model involved the

development of containment event trees that describe the response of the containment to the

severe accident phenomena for each of the Level 1 accident classes. The current Level 2

model retains the IPE containment event tree logic and is directly linked with the Level 1 model

via the linked fault tree process. In addition, the SAMA model incorporates several modeling

changes to better reflect an improved understanding of Level 2 PSA issues as suggested by an

independent peer review, most notably, drywell shell failure due to contact with core debris,

several items related to radionuclide release states, and net positive suction head (NPSH) limits

following containment venting.

The result of the Level 2 PSA is a set of release categories with their respective frequency and

release characteristics. The results of this analysis for Monticello are provided in Table F.2-4 of

the ER. The frequency of each release category was obtained from the quantification of the

linked Level 1 - Level 2 models. The release characteristics were obtained from the results of

modular accident analysis program (MAAP) analyses that were determined to bound the

release fraction for the sequences in each release category.

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for these analyses

August 2006 G-3 NUREG-1437, Supplement 26 I
Appendix G

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution (within an

80-kilometer (50-mile) radius) for the year 2030, emergency response evacuation modeling,

and economic data. The core radionuclide inventory is based on the generic boiling water

reactor (BWR) inventory provided in the MACCS2 manual, adjusted to represent the Monticello

uprated power level of 1,775 megawatt thermals [(MW(t)]. The magnitude of the onsite impacts

(in terms of clean-up and decontamination costs and occupational dose) is based on

information provided in NUREG/BR-01 84 (NRC 1997b).

In the ER, NMC estimated the dose to the population within 80 kilometers (50 miles) of the

Monticello site to be approximately 0.38 person-sievert (Sv) (38 person-rem) per year. The

breakdown of the total population dose by containment release mode is summarized in

Table G-2. Containment failures within the late time frame (greater than 6 hours following

declaration of a general emergency) and within the early time frame (less than 6 hours following

declaration of a general emergency) provide similar contributions to the population dose risk at

Monticello.

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

Population Dose

Containment Release Mode (person-rem•°) per year) % Contribution

Late containment failure 20.4 54

Early containment failure 17.6 46

Intact containment Negligible Negligible

Total 38.0 100

(a) 1 person-rem per year = 0.01 person-Sv per year

G.2.2 Review of Nuclear Management Company, LLC's Risk Estimates

NMC's determination of offsite risk at Monticello is based on the following three major elements

of analysis:

* The Level 1 and 2 risk models of the 1992 IPE submittals (NSP 1992) and the external

events analyses of the 1995 IPEEE submittals (NSP 1995a,b),

* The major modifications to the IPE models that have been incorporated in the Monticello

PSA models used to support the SAMA analyses, and

NUREG-1437, Supplement 26 G-4 August 2006 1
Appendix G

* The MACCS2 analyses performed to translate fission product release frequencies from the

Level 2 PSA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of NMC's risk estimates for

the SAMA analysis, as summarized below.

The staff's review of the Monticello IPE is described in an NRC report dated May 26, 1994

(NRC 1994). Based on a review of the original IPE submittal and subsequent supplements and

revisions, the staff concluded that the IPE submittal met the intent of Generic Letter (GL) 88-20;

that is, the IPE was of adequate quality to be used to look for design or operational

vulnerabilities. The IPE did not identify any severe accident vulnerabilities associated with

either core damage or poor containment performance.

Although no vulnerabilities were identified, a number of modifications to the plant, procedures

and training were identified that had either been implemented, were to be implemented, or were

being considered at the time of the completion of the IPE process. The outstanding items have

subsequently been implemented, further evaluated and found not to be sufficiently beneficial to

be considered further, or have been included as a SAMA in the current evaluation (NMC

2005a,b).

There have been numerous revisions to the IPE model since its submittal. A comparison of

internal events CDF between the IPE and the SAMA PSA models indicates an increase of

approximately 1.9x1 O- per year in the total CDF (from 2.6 x 10-5 per year to 4.47 x 10"5 per year).

The increase is mainly attributed to modeling and hardware changes that have been

implemented since the IPE was submitted. There has been a significant increase in internal

flooding CDF from 6.8 x 10.6 per year to 4.15 x 10-1 per year and a sizeable reduction in the loss

of offsite power contribution from 1.3 x 10"5 per year to 1.8 x 10.6 per year due to hardware and

modeling changes. A summary listing of those changes that resulted in the greatest impact on

the internal events CDF was provided in the ER (NMC 2005a) and are summarized in Table G-3.

The IPE CDF value for Monticello is close to the average of the CDF values reported in the

IPEs for BWR 3/4 plants. Figure 11.2 of NUREG-1560 shows that the IPE-based total internal

events CDF for BWR 3/4 plants ranges from 9 x10"8 to 8 x10"5 per year, with an average CDF

for the group of 2 x 10"' per year (NRC 1997a). It is recognized that other plants have updated

the values for CDF subsequent to the IPE submittals to reflect modeling and hardware

changes. The current internal events CDF results for Monticello are comparable to other plants

of similar vintage and characteristics.

August 2006 G-5 NUREG-1437, Supplement 26 I
Appendix G

Table G-3. Monticello PSA Historical Summary

PSA

Version Summary of Changes from Prior Model CDF

1992 IPE Submittal 2.6 x 10.5

1995 * Added non-safety diesel generator to supply battery chargers 1.37 x 10"5

- Added hard pipe containment vent

- Improved safety/relief valve (SRV) pneumatics

* Added cross-tie for diesel fire pump for low-pressure makeup

- Replaced instrument air compressor with one not dependent

on service water

- Established more realistic success criteria for service water

pumps

1999 * Incorporated effects of extended power uprate 1.44 x 10-5

2003 * Updated failure rate data 4.43 x 10"5

• Revised operator error structure to explicitly model

dependencies

* Credited manual alignment of low pressure safety systems

when control power not available

* Incorporated new findings on two significant flood scenarios

* Modified recovery modeling for offsite power and emergency

diesel generators

* Credited control rod drive injection under certain conditions

SAMA * Small number of event failure probability changes resulting 4.47 x 1O"s

from data update tasks

* Lowered truncation limit to 1 x 10"11

The staff considered the peer reviews performed for the Monticello PSA, and the potential

impact of the review findings on the SAMA evaluation. In the ER, NMC described the previous

peer reviews, the most significant of which was the Boiling Water Reactor Owners Group

(BWROG) Peer Review of the 1995 PSA model conducted in 1997. The BWROG review

concluded that the Monticello PSA can be effectively used to support applications involving

NUREG-1437, Supplement 26 G-6 August 2006
Appendix G

relative risk significance. NMC stated that all peer review comments, or the evolutions of those

peer review comments, are captured by the 2003 model, and that no outstanding model issues

exist outside the normal PSA maintenance program and that none of the PSA maintenance

tasks are known to have the potential to impact the SAMA conclusions.

Given that the Monticello internal events PSA model has been peer-reviewed and the peer

review findings were either addressed or judged to have no adverse impact on the SAMA

evaluation, and that NMC satisfactorily addressed staff questions regarding the PSA, the staff

concludes that the internal events Level 1 PSA model is of sufficient quality to support the

SAMA evaluation. Further consideration of the Level 2 PSA model is provided below.

As indicated above, the current Monticello PSA does not include external events. In the

absence of such an analysis, NMC used the Monticello IPEEE to identify the highest risk

accident sequences and the potential means of reducing the risk of posed by those sequences,

as discussed below.

The Monticello IPEEE was submitted in March 1995 (NSP 1995a), in response to Supplement 4

of Generic Letter 88-20. A revision to the IPEEE was submitted in November 1995 (NSP

1995b). Northern States Power did not identify any fundamental weaknesses or vulnerabilities

to severe accident risk in regard to the external events related to seismic, fire, or other external

events. In a letter dated April 14, 2000, the staff concluded that the submittals met the intent of

Supplement 4 to Generic Letter 88-20, and that the licensee's IPEEE process is capable of

identifying the most likely severe accidents and severe accident vulnerabilities (NRC 2000).

The Monticello IPEEE uses a focused scope Electric Power Research Institute (EPRI) seismic

margins analysis. This method is qualitative and does not provide numerical estimates of the

CDF contributions from seismic initiators. The seismic IPEEE identified a number of outliers of

items within the scope of the Unresolved Safety Issue (USI) A-46 program. Resolution of these

outliers was accomplished in the context of USI A-46. Given the satisfactory resolution of these

outliers, Monticello found that none of the plant's high confidence in low probability of failure

values were less than the 0.3g review level earthquake used in the IPEEE. The NRC-review

and closure of USI A-46 for Monticello are documented in a letter dated November 12, 1998

(NRC 1998).

Notwithstanding the conclusions of the IPEEE, as part of the SAMA evaluation NMC reviewed

the seismic analysis results and history to determine whether there were any unresolved issues

that could impact the seismic risk at Monticello, particularly, any unfinished plant enhancements

that were needed to ensure equipment on the safe shutdown list would be capable of

withstanding the review level earthquake, or any additional plant enhancements that were

identified as means of reducing seismic risk but were discarded due to cost considerations.

Based on their review, NMC concluded that there were no outstanding issues that could impact

the SAMA results.

August 2006 G-7 NUREG-1437, Supplement 26 I
Appendix G

Based on the licensee's IPEEE efforts to identify and address seismic outliers and the expected

cost associated with further seismic risk analysis and-otential plant modifications, the staff

concludes that the opportunity for seismic-related SAMAs has been adequately explored and

that there are no cost-beneficial, seismic-related SAMA candidates.

The Monticello IPEEE fire analysis employed a combination of a probabilistic risk analysis

(PRA) and EPRI's fire-induced vulnerability evaluation (FIVE) methodology. An initial screening

phase was performed for fire areas outside of the main reactor/turbine building complex. Fire

boundaries were then developed considering spread of fire across area boundaries using the

FIVE methodology. PRA techniques were then utilized to progressively analyze the various fire

accident sequences that could lead to core damage. This involved using the IPE model of

internal events to quantify the CDF resulting from a fire-initiating event. The CDF for each zone

was obtained by multiplying the frequency of a fire in a given fire zone by the conditional core

damage probability associated with that fire zone including, where appropriate, the impact of

fire suppression and fire propagation. The potential impact on containment performance and

isolation was evaluated following the core damage evaluation.

The total fire CDF was estimated as 7.81 x 1 0" per year (NSP 1995b). The following seven fire

areas (room/burn sequences) are considered to be the dominant contributors and comprise

more than 80 percent of the total fire CDF:

Fire Area Area Description CDF

VIII/9 Control room 1.5x 10"6

XII/BS5 Turbine building 931 -ft elevation 1.3 x 10-6

IX/BS4 Feedwater pump area 1.2 x 10.6

VI/8 Cable spreading room 9.0 x 10-7

II/BS2 Reactor building 935/962-ft elevation west 5.6 x 10-7

IX/12A Lower 4kV switchgear room 5.1 x 10.7

XXII/BS6 Div. II area of the emergency filtration train building 4.1 x 10"7

The fire CDF is approximately 17 percent of the current internal events CDF. In the ER, NMC

described each of the fire areas listed above and identified candidate SAMAs to potentially

reduce the associated fire risk. As a result, NMC identified potential enhancements which it

further considered as SAMAs. These include:

NUREG-1437, Supplement 26 G-8 August 2006 1 ,
Appendix G

" Permanently posting an operator at the alternate shutdown system (ASDS) panel

* Modifying the ASDS panel to include additional system controls, and

" Adding an emergency level control system to the hotwell.

The staff inquired about the status of several insights/potential improvements that were

identified by NMC in the IPEEE and Revision 1 to the IPEEE. NMC indicated that two of three

improvements identified in the original IPEEE submittal were actually PSA modeling changes

that would better reflect actual risk (NMC 2005b). These improvements involve a revision to the

service water pump success criteria and the elimination of the SRV dependence on alternating

current (ac) power for depressurization to be consistent with a previous plant change. Both

enhancements have been incorporated into the current SAMA PSA model. The third

improvement, taking credit for control rod drive (CRD) injection after bypassing the load shed

logic, has been incorporated into emergency operating procedures and credited in the current

PSA model.

Revision 1 of the IPEEE identified two additional modeling improvements (NSP 1995b). These

two improvements involve crediting manual fire suppression in areas other than the control

room, and crediting CRD injection and the main condenser as a heat sink for fires that do not

cause their failure. These improvements have not been credited in the Monticello fire analysis

but would tend to reduce the analyzed risk and the potential for cost-beneficial SAMAs; their

omission is therefore conservative.

The IPEEE analysis of high winds, floods and other external events followed the screening

specified in Supplement 4 to GL 88-20 (NRC 1991) and did not identify any significant

sequences or vulnerabilities (NSP 1995a). The Monticello ER qualitatively discusses the risks

from high winds, external flooding and probable maximum precipitation, and transportation and

nearby facility accidents. NMC considered the potential for SAMAs to reduce these risks, but

concluded that no further modifications would be cost-beneficial. It is noted that the risks from

aircraft were explicitly excluded since this was being considered in other forums along with

other sources of sabotage.

Due to the relatively low contribution to CDF from fire and other external events, NMC doubled

the benefit which was derived from the internal events model to account for the contribution

from external events. This doubling was not applied to those SAMAs that specifically

addressed fire risk (i.e., SAMAs 38 through 40), since these SAMAs are specific to fire risks

and would not have a corresponding risk reduction in internal events. The fire risk analysis is

described in the IPEEE and in the environmental report as producing conservative CDF results.

While conservative assumptions were used for the majority of fire areas, other aspects of the

analysis were considered to be optimistic (NRC 2000). Thus, the degree of conservatism in the

result is not clear. Notwithstanding the above, the staff agrees with the applicant's conclusion

August 2006 G-9 NUREG-1437, Supplement 26 1
Appendix G

that the risks posed by external events is less than that due to internal events. Therefore, the

staff concludes that the applicant's use of a multiplier of two to account for external events is

reasonable for the purposes of the SAMA evaluation.

The staff reviewed the general process used by NMC to translate the results of the Level 1 PSA

into containment releases, as well as the results of this Level 2 analysis. NMC characterized

the releases for the spectrum of possible radionuclide release scenarios using a set of seven

release categories, defined based on the timing and magnitude of the release. The frequency

of each release category was obtained from the quantification of a linked Level 1 - Level 2

model which effectively evaluates a containment event tree for each Level 1 accident

sequence. Four containment event trees were utilized that differentiated between intact or

failed containment at the time of reactor vessel failure and events with and without SBO. The

release characteristics for each release category were obtained from the results of MAAP 4.0.5

analyses of conservatively determined representative sequences for each category. The

process for assigning accident sequences to the various release categories and selecting a

representative accident sequence for each release category is described in the ER and in

response to RAIs (NMC 2005a,b). The release categories and their frequencies are presented

in Tables F.2-2, F.2-3, and F.2-4 of the ER (NMC 2005a). All releases were modeled as

occurring at ground level and with a thermal content the same as ambient. The staff concludes

that the process used for determining the release category frequencies and source terms is

reasonable and appropriate for the purposes of the SAMA analysis.

The total frequency of releases resulting from the Level 2 analysis is slightly greater than the

CDF. In the ER and in response to an RAI, NMC stated that the difference is due to the.

inclusion of some non-minimal cutsets for scenarios that have higher releases than the

corresponding minimal cutsets for the scenarios assessed for the CDF (NMC 2005a,b). The

frequency of these non-minimal cutsets should have been subtracted from the frequency of the

lower release categories. Therefore, this introduces a slight conservatism in the SAMA

analysis.

The staff's review of the Level 2 IPE (NRC 1994) concluded that it addressed the most

important severe accident phenomena normally associated with the Mark I containment type,

and identified no significant problems or errors.

The Level 2 PSA model was independently reviewed in 2004 by an NMC contractor who

concluded that the model was adequate to support the SAMA analysis subject to the resolution

of three issues. These issues are:

• Updating the drywell shell failure probabilities due to debris contact

" Addressing items related to radionuclide release states (including shell failure timing and

application of drywell spray for the prevention of shell failure, matching order of events in

NUREG-1437, Supplement 26 G-1 0 A

August 2006 1
Appendix G

accident sequences to emergency procedure instructions, and how accident scenarios are

represented in MAAP)

Including established NPSH limits for low pressure coolant injection/containment spray

operation following containment venting in the MAAP analysis.

These items were resolved in the Level 2 model used for the SAMA analysis. The staff notes

that the above issues could be important to accident progression. Therefore, the decision to

incorporate updates in these areas appears reasonable.

Based on the staff's review of the Level 2 methodology, and the fact that the Level 2 model was

reviewed in more detail as part of the BWROG peer review and a more recent independent

contractor review and updated to address the review findings, the staff concludes that the Level

2 PSA provides an acceptable basis for evaluating the benefits associated with various SAMAs.

As mentioned previously, the reactor core radionuclide inventory used in the consequence

analysis is based on the generic BWR inventory provided in the MACCS2 manual, adjusted to

represent the Monticello power level of 1775 MWt. In response to an RAI concerning the

impact of current and future fuel management practices, NMC performed an additional

Monticello-specific MACCS2 sensitivity calculation assuming a 65 percent increase in the

inventories for Sr-90, Cs-1 34, and Cs-1 37. This level of increase was based on a prior

calculation for Nine Mile Point in which the end-of-cycle activity levels for a bounding case of

1400 effective full power days were compared to the reference BWR inventories. Use of this

increased inventory results in an approximately 29 percent increase in the total costs

associated with a severe accident at Monticello. Using realistic mid-life or average conditions

would result in a smaller increase. NMC assessed the impact that this change might have on

the SAMA screening process and determined that one SAMA (SAMA 39) could become

marginally cost-beneficial. However, this SAMA was already identified as potentially

cost-beneficial when using a 3 percent real discount rate and when 95th percentile values are

used, as discussed in Section G.6.2. Based on this limited impact, the staff concludes that the

scaling based on the plant-specific power level yields sufficiently accurate and reasonable

results for the dose assessment.

The staff reviewed the process used by NMC to extend the containment performance (Level 2)

portion of the PSA to an assessment of offsite consequences (essentially a Level 3 PRA). This

included consideration of the source terms used to characterize fission product releases for the

applicable containment release category and the major input assumptions used in the offsite

consequence analyses. The MACCS2 code was utilized to estimate offsite consequences.

Plant-specific input to the code includes the source terms for each release category and the

reactor core radionuclide inventory (both discussed above), site-specific meteorological data,

projected population distribution within an 80-kilometer (50-mile) radius for the year 2030,

August 2006 G-1 1 NUREG-1437, Supplement 26 I
Appendix G

emergency evacuation modeling, and economic data. This information is provided in

Appendix F of the ER (NMC 2005a).

NMC used site-specific meteorological data for the 2000 calendar year as input to the MACCS2

code. The data were collected from the onsite meteorological tower. In response to an RAI,

NMC stated that it considered the year 2000 data to be representative of 5-year meteorological

data previously tabulated for the alternate source term project. Small data voids were filled

using interpolation between data points. Larger data voids were filled using data from the

previous, or following, week for the same time of day. The staff notes that previous SAMA

analyses results have shown little sensitivity to year-to-year differences in meteorological data

and concludes that the use of the 2000 meteorological data in the SAMA analysis is

reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated

for the year 2030, using SECPOP2000 (NRC 2003), U.S. Census block-group level population

data, and population growth rate estimates (USCB 2000a). The 1990 and 2000 census data

were used to estimate a regional annual average population growth rate (USCB 2000b). This

annual average population growth rate was applied uniformly to all sectors to calculate the year

2030 population distribution, which NMC has determined is conservative relative to the

population projections based on the county-specific growth rates. The staff concludes that the

methods and assumptions for estimating populationare reasonable and acceptable for

purposes of the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out

10 miles from the plant. It was assumed that 95 percent of the population would move at an

average speed of approximately 2.5 miles per hour with a delayed start time of 30 minutes

(NMC 2005a). This assumption is conservative relative to the NUREG-1 150 study (NRC 1990),

which assumed evacuation of 99.5 percent of the population within the emergency planning

zone. The staff concludes that the evacuation assumptions and analysis are reasonable and

acceptable for the purposes of the SAMA evaluation.

Much of the site-specific economic data was provided from SECPOP2000 (NRC 2003) by

specifying the data for each of the counties surrounding the plant, to a distance of 50 miles.

SECPOP2000 utilizes economic data from the 1997 Census of Agriculture (USDA 1998). In

addition, generic economic data that applied to the region as a whole were revised from the

MACCS2 sample problem input when better information was available. These included the

value of farm and non-farm wealth and the fraction of farm wealth from improvements (e.g.,

buildings, equipment). Information on the duration of growing seasons for the remaining crops

(pasture, green leafy vegetables, roots/tubers and other food crops) were the same as those

used in all five NUREG-1 150 sites (NRC 1990). NMC compared these data against the

information that was available for Minnesota and judged them to be reasonable.

NUREG-1437, Supplement 26 G-12 August 2006 1
Appendix G

The staff noted that the offsite economic cost risk at Monticello is larger than that estimated at

other sites having similar core damage frequency and population doses. In response to-the

staff's RAI, NMC stated that the economic value parameters used as input to the Monticello

MACCS2 analyses are consistent with industry guidance, and produced results that are

considered to be appropriate for the Monticello site. Upon further review by the staff, the

differences in offsite economic cost risk between sites appear to be due to the differences in

the site-specific 50-mile population distributions.

The staff concludes that the methodology used by NMC to estimate the offsite consequences

for Monticello provides an acceptable basis from which to proceed with an assessment of risk

reduction potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite

risk on the CDF and offsite doses reported by NMC.

G.3 Potential Plant Improvements.

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by NMC are discussed in this section.

G.3.1 Process for Identifying Potential Plant Improvements

NMC's process for identifying potential plant improvements (SAMAs) consisted of the following

elements:

* Review of the most significant basic events from the Levels 1 and 2 PSA,

" Review of Phase II SAMAs from license renewal applications for seven other U.S. nuclear

sites,

* Review of potential plant improvements identified in the Monticello IPE and IPEEE, and

" Review of seven dominant room/burn areas, and SAMAs that could potentially reduce the

associated fire risk.

Based on this process, an initial set of 40 candidate SAMAs, referred to as Phase I SAMAs,

was identified. In Phase I of the evaluation, NMC performed a qualitative screening of the initial

list of SAMAs and eliminated SAMAs from further consideration using the following criteria:

* The SAMA is not applicable at Monticello due to design differences,

* The SAMA is of low benefit in boiling water reactors,

August 2006 G-13 NUREG-1437, Supplement 26 I
Appendix G

" The SAMA has already been implemented at Monticello or its benefit has been achieved at

Monticello using other means, or

* The SAMA costs more than $8.6 million to implement (the modified maximum averted cost-risk (MMACR), which represents the dollar value associated with completely

eliminating all internal and external event severe accident risk at Monticello).

Based on this screening, 24 SAMAs were eliminated leaving 16 for further evaluation. The

remaining SAMAs, referred to as Phase II SAMAs, are listed in Table F.5-4 of the ER (NMC

2005a).

During Phase II of the evaluation, NMC screened out one additional SAMA because its benefit

was small compared to its relevant importance ranking. A detailed evaluation was performed

for each of the 15 remaining SAMA candidates, as described in Sections G.4 and G.6 below.

To account for the potential impact of external events, the estimated benefits based on internal

events were multiplied by a factor of two (except for those SAMAs specific to fire risks, since

those SAMAs would not have a corresponding benefit on the risk from internal events.)

NMC also assessed the impact on the initial screening if the MMACR were based on a

3 percent discount rate rather than 7 percent, or if the MMACR were increased by a factor of

2.5 to reflect the potential impact of uncertainties. As a result, three additional SAMAs would

have been retained for the Phase II analysis. Theses SAMAs are discussed further in

Section G.6.2.

G.3.2 Review of Nuclear Management Company, LLC's Process

NMC's efforts to identify potential SAMAs focused primarily on areas associated with internal

initiating events and internal fires. The initial list of SAMAs generally addressed the accident

sequences considered to be important to CDF from functional, initiating event, and risk

reduction worth perspectives at Monticello, and included selected SAMAs from prior SAMA

analyses for other plants.

The preliminary review of NMC's SAMA identification process raised some concerns regarding

the completeness of the set of SAMAs identified. The staff requested information on certain

improvements that were identified during the IPE but that did not appear to be addressed by a

candidate SAMA (NRC 2005). In response to the RAI, NMC explained that one of the

improvements (assure faster operation of the condensate demineralizer bypass valve on loss of

air) should have been considered as a SAMA but was not. Upon further review by NMC, the

potential benefit for the modification would be less than $2000, which is significantly less than

the cost, and therefore, would not be justified (NMC 2005b). NMC stated that a second

modification (operator training on recovery of the failed RHR) is addressed by SAMA 26,

operator training on a failed main condenser. For the remaining modification in question

NUREG-1437, Supplement 26 G-14 August 2006 1
Appendix G

(testing of the boron injection hose), NMC stated that the alternate boron injection has a very

small impact on CDF, and that the associated recommendation was subsumed by SAMA 13

(NMC 2005b).

The staff also questioned the ability of two SAMAs to accomplish their intended objectives, i.e.,

SAMA 7, rupture disk bypass line, and SAMA 36, divert water from TB931 East. SAMA 7 was

subsumed by SAMA 16, passive overpressure relief. The staff noted that SAMA 16 does not

address the same failure modes that are relevant to SAMA 7 (NMC 2005a). NMC stated that

SAMA 16 does not directly address rupture disk failure; however, SAMA 16 was chosen as the

best method to address containment vent reliability (NMC 2005b). With regard to SAMA 36, the

staff noted that in Table F.5-1 of the ER, basic event IEF_FS-TB931W, which is a flood in the

turbine building at the 931-foot elevation west, is indicated to be addressed by SAMA 36 (NMC

2005a). NMC clarified that this SAMA is only applicable to the east region of the turbine

building but was included in the importance list as part of the recommended flood mitigation

package (NMC 2005b).

Lastly, the staff questioned the applicant about two basic events that have a risk reduction

worth of 1.005, but for which no candidate SAMAs were considered. In response to the staff's

question, NMC stated that the components involved are a manual bypass switch and a manual

disconnect switch that support operation of an instrument ac panel. This particular instrument

panel is important because its failure precludes operation of all three containment vent paths,

fails division II containment heat removal, trips the mechanical vacuum pump, and fails high

pressure coolant injection. NMC argued that manual switches are extremely reliable (i.e., have

a very low failure probability); therefore, only an inexpensive modification that could mitigate the

consequence would be cost-beneficial (NMC 2005b). The staff agrees that there would be no

cost-beneficial SAMAs to address these basic events.

Based on this additional information as described above, the staff concludes that the set of

SAMAs evaluated in the ER addresses the major contributors to CDF and offsite dose.

NMC identified Monticello-specific candidate SAMAs for fire events using a combination of the

Monticello PSA model and the IPEEE. The fire risk at Monticello is dominated by seven

room/burn sequences, the largest contributor being the control room. As a result, three

fire-related SAMAs were identified and retained for the Phase II evaluation. Potential plant

enhancements for other external events (high winds, external floods, and transportation and

nearby facility accidents) were determined to be too costly or bounded by existing scenarios.

The staff concludes that the applicant's rationale for eliminating these enhancements from

further consideration is reasonable.

The staff notes that the set of SAMAs submitted is not all inclusive, since additional, possibly

even less expensive, design alternatives can always be postulated. However, the staff

concludes that the benefits of any additional modifications are unlikely to exceed the benefits of

August 2006 G-1 5 NUREG-1 437, Supplement 26 1
Appendix G

the modifications evaluated and that the alternative improvements would not likely cost less

than the least expensive alternatives evaluated, when the subsidiary costs associated with

maintenance, procedures, and training are considered.

The staff concludes that NMC used a systematic and comprehensive process for identifying

potential plant improvements for Monticello, and that the set of potential plant improvements

identified by NMC is reasonably comprehensive and therefore acceptable. This search

included reviewing insights from the plant-specific risk studies, reviewing plant improvements

considered in previous SAMA analyses, and using the knowledge and experience of its PSA

personnel.

GA Risk Reduction Potential of Plant Improvements

NMC evaluated the risk-reduction potential of the 15 remaining SAMAs that were applicable to

Monticello. The changes made to the model to quantify the impact of the SAMAs are detailed

in Section F.6 of Appendix F to the ER (NMC 2005a). The SAMA evaluations were performed

using realistic assumptions with some conservatism.

NMC used model re-quantification to determine the potential benefits. The CDF and population

dose reductions were estimated using the SAMA model version of the Monticello PSA.

Table G-4 lists the assumptions considered to estimate the risk reduction for each of the

evaluated SAMAs, the estimated risk reduction in terms Of percent reduction in CDF and

population dose, and the estimated total benefit (present value) of the averted risk. The

determination of the benefits for the various SAMAs is further discussed in Section G.6.

For those SAMAs that specifically address fire events (i.e., SAMAs 38 through 40), the

reduction in CDF and population dose was not directly calculated. For these SAMAs, a

bounding estimate of the impact of.the SAMA was made based on general assumptions

regarding the approximate contribution to total risk from external events (relative to that from

internal events), the fraction of the external event risk attributable to fire events, and the fraction

of the fire risk affected by the SAMA and associated with each fire compartment (based on

information from the IPEEE.) For example, it is assumed that the contribution to risk from

external events is approximately equal to that from internal events, and that internal fires

contribute 85 percent of the external events risk. The IPEEE fire analysis was then used to

identify the fraction of the fire risk that could be eliminated by potential enhancements in various

fire rooms/burn sequences. A similar process was applied to the proposed fire enhancements

for each fire room/burn sequence considered.

The staff has reviewed NMC's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and somewhat conservative (i.e., the estimated risk reduction is similar to or

NUREG-1437, Supplement 26 G-1 6 August 2006 1
Appendix G

somewhat higher than what would actually be realized). Accordingly, the staff based its

estimates of averted risk for the various SAMAs on NMC's risk reduction estimates.

G.5 Cost Impacts of Candidate Plant Improvements

NMC estimated the costs of implementing the 15 candidate SAMAs through the application of

engineering judgement, use of other licensees' estimates for similar improvements, and

development of site-specific cost estimates. The cost estimates conservatively did not include

the cost of replacement power during extended outages required to implement the

modifications, nor did they include contingency costs associated with unforeseen

implementation obstacles. The cost estimates provided in the ER did not generally account for

inflation. When using costs estimates prior to 1995, NMC applied a 2.75 percent per year

inflation rate to arrive at year 2004 estimated costs (e.g., SAMA 39).

The staff reviewed the bases for the applicant's cost estimates (presented in Section F.6 of

Appendix F to the ER). For certain improvements, the staff also compared the cost estimates

to estimates developed elsewhere for similar improvements, including estimates developed as

part of other licensees' analyses of SAMAs for operating reactors and advanced light-water

reactors. The staff reviewed the costs and found them to be consistent with estimates provided

in support of other plants' analyses.

The staff concludes that the cost estimates provided by NMC are sufficient and appropriate for

use in the SAMA evaluation.

August 2006 G-17 NUREG-1437, Supplement 26 1
z

mG)

-Al

CA)

-4

CD

OD

a

(0

C)

Table G-4. SAMA Cost-Benefit Screening Analysis for Monticello

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Population

SAMA Assumptions CDF Dose Discount Rate(S) Discount Rate(S) Cost($)

2-Enhance direct current (dc) power Additional credit given for alignment and <1 1 79,000 109,000 75,000

availability by providing a direct operation of direct feed line to battery

connection from DG-13, the security chargers from DG-13. Failure probability

diesel, or another source to the 250-volt of modification Is 1 E-02

(V) battery chargers or other required

loads.

4-Install a direct drive diesel Injection Failure probability of 1 E-02 for alignment 98 8 460,000 11,520,000 2,000,000

pump as additional high pressure and operation of this system with no

injection system. dependencies on other plant systems

and not subject to flooding failures.

Added to all high-pressure injection

failure gates.

6-Install additional fan and louver pair Additional credit given for modification In 2 1 103,000 137,000 100,000

for emergency diesel generator (EDG) case of failure of both trains of existing

heating, ventilation, and air conditioning. EDG room cooling. Failure probability of

modification Is 1 E-02.

8-Improve EDG-emergency service Failure probability of 1 E-02 for actuation 1.8 2.4 211,000 290,000 2,000,000

water (ESW) pumping capability by and operation of system. Added to all

utilizing the fire service water (FSW) gates for failure of both divisions of

system as a back up for EDG cooling. EDG-ESW.

10--Install drywell Igniters or passive Additional credit given to new system to 0 3.5 272,000 380,000 760,000

hydrogen ignition system. prevent hydrogen deflagration with failure

probability of 1 E-02 for new system.

1 1-Enhance alternate injection Assumed valve testing every 5 years <1. 9 687,000 959,999 50,000

reliability by including the residual heat leading to a factor of 10 reduction in

removal service water and FSW valve failure probability.

cross-tie valves in the maintenance

program.

CD

:3

G)
C

Cn

N,

a)

% Risk Reduction Total Benefit Total Benefit

Using 7% Using 3%

Population

SAMA Assumptions CDF Dose Discount Rate ($) Discount Rate ($) Cost ($)

12-Proceduralize use of fire pumper

truck to pressurize the FSW system.

13-Enhance, test and train on alternate

boron Injection with the control rod drive

system.

Replaced existing failure of fire pump

that credits a fire pumper truck, with a

failure probability of 1 E-02, and reduced

diesel fire pump failure probability by a

factor of 10 based on plant experience.

Additional credit given by revising the

failure probability for boron injection via

the reactor water clean up system to

1E-03 with complete dependence on

operator action to inject boron via the

standby liquid control.

<1 34 2,12,000 3,684,000 50,000

<1 0 3500 4200 50,000

G)t

CD

16-Provide passive overpressure relief

by changing the containment vent

valves to fail open and Improving the

strength of the rupture disk.

28-Develop procedure to refill

condensate storage tank (CST) with

FSW system.

36-Install Interlock to open door to hot

machine shop and change swing

direction of door to.plant administration

building to divert water from turbine

building 931-foot elevation east.

37-Develop guidance to allow local,

manual control for reactor core Isolation

cooling (RCIC) operation.

All hard pipe vent failures replaced with 2.5 3.5

effective rupture disk failure probability of

1 E-03.

Insufficient CST volume failure ANDed 0 -0

with 1 E-02 failure probability to refill CST.

Failure probability of door to open and 13 23

divert water to "safe zone" set to 1 E-03.

Failure probability of manual operation of 16 -

8 2 (a)

RCIC is set to 1 E-02 and credit for RCIC

injection given following heat removal

failure and containment vent success.

Dependence on electric power removed

for operator success In late injection.

279,000

1300

1,900,000

.5,581,000

383,000

1900

2,614,000

-7,850,000

200,000

50,000

100,000

100,000

z

M

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-L

M

CD

0X
z

CD

m

CD

% Risk Reduction Total 'Benefit

Using 7%

Total Benefit

Using 3% M

C. Population

SAMA Assumptions CDF Dose Discount Rate ($) Discount Rate ($) Cost ($)

38-Post an operator at the ASDS panel Eliminate all risk for Class 1 A sequences Not estimated 331,000 450,000 10,000,000

full time. due to fires that require control room

evacuation.

39-Enhance the ASDS panel to include Eliminate all risk for Class 1 D sequences Not estimated 753,000 1,025,000 787,000

additional system controls for opposite due to fires that require control room

division, evacuation.

40-Add an emergency level control Eliminate all risk for Class 2 sequences Not estimated 178,000 243,000 230,000

system to the hotwell. due to fires that require operator-based

hotwell makeup.

('Ilmplementation of this SAMA is estimated to result in an 82-percent Increase In dose-risk due to the timing of core damage relative to containment failure.

G)

0

C:

0

0

G)
Appendix G

G.6 Cost-Benefit Comparison

NMC's cost-benefit analysis and the staff's review are described in the following sections.

G.6.1 Nuclear Management Company, LLC's Evaluation

The methodology used by NMC was based primarily on NRC's guidance for performing

cost-benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis Technical Evaluation

Handbook (NRC 1997b). The guidance involves determining the net value for each SAMA

according to the following formula:

Net Value = (APE + AOC + ACE + AOSC) - COE where, APE = present value of averted public

exposure ($)

AOC = present value of averted offsite property damage costs ($)

ACE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($)

COE = cost of enhancement ($).

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. NMC's derivation of

each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed one at

3 percent and one at 7 percent (NRC 2004). NMC provided both sets of estimates (NMC

2005a)..

* Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (person-rem/year)

x monetary equivalent of unit dose ($2000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a

7 percent discount rate).

August 2006 G-21 NUREG-1437, Supplement 26 I
Appendix G

As stated in NUREG/BR-01 84 (NRC 1997b), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility.

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. For the purposes of initial screening, which assumes

elimination of all severe accidents, NMC calculated an APE of approximately $817,000 for the

20-year license renewal period.

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per-event basis)

x present value conversion factor.

For the purposes of initial screening which assumes all severe accidents are eliminated, NMC

calculated an annual offsite economic risk of about $253,600 based on the Level 3 risk

analysis. This results in a discounted value of approximately $2,730,000 for the 20-year license

renewal period.

• Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor.

NMC derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC 1997b). Best estimate values provided

for immediate occupational dose (3300 person-rem) and long-term occupational dose

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these

doses was calculated using the equations provided in the handbook in conjunction with a

NUREG-1437, Supplement 26 G -22 August 2006 1
Appendix G

monetary equivalent of unit dose of $2000 per person-rem, a real discount rate of 7 percent,

and a time period of 20 years to represent the license renewal period. For the purposes of

initial screening, which assumes all severe accidents are eliminated, NMC calculated an AOE of

approximately $17,000 for the 20-year license renewal period.

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are considered for recoverable

accidents only and not for severe accidents. NMC derived the values for AOSC based on

information provided in Section 5.7.6 of NUREG/BR-01 84, the regulatory analysis handbook

(NRC 1997b).

NMC divided this cost element into two parts the onsite cleanup and decontamination cost, also

commonly referred to as averted cleanup and decontamination costs, and the replacement

power cost.

Averted cleanup and decontamination costs (ACC) were calculated using the following formula:

ACC = Annual CDF reduction

x present value of cleanup costs per core damage event

x present value conversion factor.

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

NUREG/BR-01 84 to be $1.1 x 109 (discounted over a 10-year cleanup period). This value

integrated over the term of the proposed license extension. For the purposes of initial

screening, which assumes all severe accidents are eliminated, NMC calculated an ACC of

approximately $529,000 for the 20-year license renewal period.

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction

x present value of replacement power for a single event

x factor to account for remaining service years for which replacement power is

required

x reactor power scaling factor

August 2006 G-23 NUREG-1437, Supplement 26 1
Appendix G

NMC based its calculations on the value of 587 megawatt electrics (MWe), which is the current

electrical output for Monticello (after the extended power uprate). Therefore, NMC applied

power scaling factors of 587 MWe/91 0 MWe to determine the replacement power costs. For

the purposes of initial screening, which assumes all severe accidents are eliminated, NMC

calculated the AOSC to be approximately $227,500 for the 20-year license renewal period.

Using the above equations, NMC estimated the total present dollar value equivalent associated

.with completely eliminating severe accidents at Monticello to be about $4,320,000. To account

for additional risk reduction in external events, NMC doubled this value (to $8,642,000), to

provide the MMACR, which represents the dollar value associated with completely eliminating

all internal and external event severe accident risk at Monticello.

For each of the SAMAs remaining after the initial screening, the averted costs associated with

the SAMA were estimated using the above equations in conjunction with the CDF and

population dose reductions for the SAMA.

• NMC's Results

If the implementation costs for a candidate SAMA were greater than the MMACR of

$8,642,000, then the SAMA was screened from further consideration. A more refined look at

the costs and benefits was performed for the remaining SAMAs. If the implementation costs for

a candidate SAMA exceeded the calculated benefit, the SAMA was considered not to be

cost-beneficial. In the baseline analysis contained in the ER (using a 7-percent discount rate),

NMC identified seven potentially cost-beneficial SAMAs. Based on an analysis using a

3-percent real discount rate, as recommended in NUREG/BR-0058 (NRC 2004), two additional

SAMA candidates were determined to be potentially cost-beneficial. The potentially

cost-beneficial SAMAs are:

* SAMA 2-enhance dc power availability by providing a direct connection from diesel

generator 13, the security diesel, or another source to the 250 V battery chargers or other

required loads.

" SAMA 4-install a direct drive diesel injection pump as additional high pressure injection

system.

• SAMA 6-install additional fan and louver pair for EDG heating, ventilation, and air

conditioning.

* SAMA 11--enhance alternate injection reliability by including the residual heat removal

service water and FSW cross-tie valves in the maintenance program.

* SAMA 12-proceduralize the use of a fire pumper truck to pressurize the FSW system.

NUREG-1437, Supplement 26 G-24 August 2006 1
Appendix G

* SAMA 16- provide passive overpressure relief by changing the containment vent valves to

fail open and improving the strength of the rupture disk.

* SAMA 36--install an interlock to open the door to hot machine shop and change swing

direction of door to plant administration building to divert water from turbine building

931-foot elevation east.

" SAMA 39-upgrade the ASDS panel to include additional system controls for opposite

division (cost-beneficial at 3 percent discount rate).

* SAMA 40-add emergency level control sensor and control valve to the hotwell

(cost-beneficial at 3 percent discount rate).

NMC performed additional analyses to evaluate the impact of parameter choices and

uncertainties on the results of the SAMA assessment (NMC 2005a). If the benefits are

increased by a factor of 2.5 to account for uncertainties, one additional SAMA candidate

(beyond those identified in the 3 percent discount rate case) was determined to be potentially

cost-beneficial. The potentially cost-beneficial SAMAs, and NMC's plans for further evaluation

of these SAMAs are discussed in more detail in Section G.6.2.

G.6.2 Review of Nuclear Management Company, LLC's Cost-Benefit Evaluation

The cost-benefit analysis performed by NMC was based primarily on NUREG/BR-0184 (NRC

1997b) and was executed consistent with this guidance.

In order to account for external events, NMC multiplied the internal event benefits by a factor of

two for each SAMA, except those SAMAs that specifically address fire risk (SAMAs 38 through

40). Doubling the benefit for these SAMAs is not appropriate since these SAMAs are specific to

fire risks and would not have a corresponding risk reduction in internal events. Given that the

CDF from internal fires and other external events as reported by NMC is less than the CDF for

internal events, the staff agrees that the factor of two multiplier for external events is

reasonable.

NMC considered the impact that possible increases in benefits from analysis uncertainties

would have on the results of the SAMA assessment. Currently, an uncertainty distribution is not

available for the SAMA PSA model. Therefore, NMC reviewed the point estimate and 95th

percentile CDFs for several SAMA submittals. The factor by which the 95th percentile CDFs

exceed the point estimate CDFs ranged from 2.35 to 2.45 (NMC 2005a). NMC re-examined the

initial set of SAMAs to determine if any additional Phase I SAMAs would be retained for further

analysis if the benefits (and MMACR) were increased by a factor of 2.5. Three such SAMAs

were identified, specifically, SAMAs 1, 9, and 14. However, based on further consideration of

costs and limited effectiveness, NMC concluded that SAMAs 1 and 14 could not be

August 2006 G -25 NUREG-1437, Supplement 26 1
Appendix G

cost-beneficial even if the systems were 100 percent reliable. NMC also considered the impact

on the Phase II screening if the estimated benefits were increased by a factor of 2.5 (in addition

to the factor of two multiplier already included in the baseline benefit estimates to account for

external events). One additional SAMA (SAMA 9 dedicated alternate low-pressure

injection/drywell spray system) became potentially cost-beneficial in NMC's analysis.

NMC recognized that a combination of low-cost SAMAs can provide much of the risk reduction

associated with higher-cost SAMAs, and may act synergistically to yield a combined risk

reduction greater than the sum of the benefits for each SAMA if implemented individually. NMC

identified the following six low-cost SAMAs as a "recommended" combination of SAMAs that

substantially reduces risk at Monticello for a relatively low cost of implementation. They are:

" SAMA 2-enhance dc power availability by providing a direct connection from diesel

generator 13, the security diesel, or another source to the 250 V battery chargers or other

required loads.

* SAMA 11-enhance alternate injection reliability by including the residual heat removal

service water and FSW cross-tie valves in the maintenance program.

• SAMA 12-proceduralize the use of a fire pumper truck to pressurize the FSW system.

* SAMA 28--develop a procedure to refill the CST with FSW system.

* SAMA 36-install an interlock to open the door to hot machine shop and change swing

direction of door to plant administration building to divert water from turbine building

931-foot elevation east.

• SAMA 37-develop guidance to allow local, manual control for RCIC operation.

To assess the impact of the implementation of the recommended SAMAs, NMC made the same

modeling changes to the PSA as used previously to represent to the implementation of the

SAMAs individually. The combined implementation cost of the set was assumed to be the sum

of the individual SAMA implementation costs, without consideration given to the timing or

manner in which the SAMAs are implemented. Implementation of the recommended SAMAs

was estimated to result in an 86-percent reduction in CDF and an 80 percent reduction in dose,

yielding a total benefit of almost $7 million. The combined implementation cost for the set is

estimated to be $425,000.

The staff noted that two of the SAMAs in the set (SAMAs 28 and 37) were not previously

identified as cost-beneficial, and that one of the two SAMAs (SAMA 37, manual RCIC

operation) was actually estimated to result in an 82-percent increase in dose risk if implemented

individually. The staff questioned how the implementation of SAMA 37, in combination with

NUREG-1437, Supplement 26 G -26 August 2006 1
Appendix G

several other SAMAs, results in a large (approximately 80-percent) net decrease in risk (NRC

2005). In response to the staff's question, NMC stated that for a prolonged SBO, RCIC alone

does not represent a success path, i.e., SAMA 37 would not create a success path (NMC

2005b). During SBO, containment heat removal and containment venting are both unavailable.

Containment failure due to overpressure would preclude the operators from occupying the

RCIC room to support manual operation of the RCIC. Even with manual operation, the RCIC

will eventually fail due to lack of water in the CST or overheating if taking suction from the

suppression pool. Manual operation of RCIC (i.e., SAMA 37), therefore, delays the core

damage while the containment pressurizes due to lack of heat removal. Core damage and

vessel melt through in a pressurized containment results in a greater chance of containment

failure than if they occur in an unpressurized containment.

When SAMA 37 is implemented in combination with other SAMAs, particularly SAMAs 12 and

28, a new success path is created. SAMA 12 provides a source of containment spray and CST

makeup independent of electric power, while SAMA 28 provides for refilling the CST so that

RCIC can continue to function; i.e., SAMA 37 (manual operation of RCIC) is successful due to

the refill of the CST. SAMA 2 provides power to solenoid valves allowing containment venting

for prolonged SBO scenarios, and SAMA 36 delays or prevents loss of dc so that time is

available for manual operation of RCIC. The net result is a significantly reduced CDF and risk

when these SAMAs are implemented as a group.

Since the ER was submitted, NMC has implemented the six "recommended" SAMAs (SAMAs 2,

11, 12, 28, 36, and 37), and has reassessed the value of the remaining SAMAs.

Implementation of the recommended SAMAs reduces the benefit of the remaining Phase II

SAMAs (including SAMA 9, which was identified as a result of the uncertainty analysis) such

that only one SAMA remains potentially cost-beneficial. SAMA 16 (passive overpressure relief

for containment) becomes even more cost-beneficial (to approximately $1 million) because the

set of SAMAs implemented by NMC shifts the risk to categories influenced by containment

venting, which could be mitigated by SAMA 16. NMC did not identify SAMA 16 as a

modification planned for further consideration in the ER. However, in response to an RAI (NRC

2005), NMC stated that after re-evaluating SAMA 16, the value of modifying the hard pipe vent

design was found to still be significant, and that the improvement is being pursued to determine

if cost-effective modifications can be implemented (NMC 2005b).

The staff concludes that, with the exception of the one potentially cost-beneficial SAMA

discussed above, the costs of the SAMAs evaluated would be higher than the associated

benefits.

G.7 Conclusions

NMC compiled a list of 40 SAMAs based on a review of: the most significant basic events from

the plant-specific PSA, Phase II SAMAs from license renewal applications for other plants, and

August 2006 G-27 NUREG-1437, Supplement 26
Appendix G

insights from the plant-specific IPE and IPEEE. A qualitative screening removed SAMA

candidates that (1) were not applicable at Monticello due to design differences, (2) were of low

benefit in BWRs, (3) had already been implemented at Monticello, (4) had been achieved at

Monticello using other means, or (5) exceeded $8.6 million to implement (the modified

maximum averted cost-risk). Twenty-four SAMAs were eliminated leaving 16 for evaluation.

Another screening removed one additional SAMA leaving 15 SAMAs for further evaluation.

For the remaining SAMA candidates, a more detailed design and cost estimate were developed

as shown in Table G-4. The cost-benefit analyses showed that seven of the SAMA candidates

were potentially cost-beneficial in the baseline analysis. NMC performed additional analyses to

evaluate the impact of parameter choices and uncertainties on the results of the SAMA

assessment. As a result, several additional SAMAs were identified as potentially

cost-beneficial. NMC evaluated the impact of implementing a selected set of six

"recommended" row-cost SAMAs. The evaluation indicated that the remaining SAMAs, with the

exception of one SAMA, would no longer be cost-beneficial. Since the ER was submitted, NMC

stated that it has implemented all six of the "recommended" SAMAs (SAMAs 2, 11, 12, 28, 36,

and 37). NMC is in the process of further evaluating the one remaining cost-beneficial SAMA

(SAMA 16).

The staff reviewed the NMC analysis and concludes that the methods used and the

implementation of those methods was sound. The treatment of SAMA benefits and costs

support the general conclusion that the SAMA evaluations performed by NMC are reasonable

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external

events was somewhat limited by the unavailability of an external event PSA, the likelihood of

there being cost-beneficial enhancements in this area was minimized by: inclusion of several

candidate SAMAs related to dominant fire events, improvements that have been realized as a

result of the IPEEE process, and inclusion of a multiplier to account for external events.

The staff concurs with NMC's identification of areas in which risk can be further reduced in a

cost-beneficial manner through the implementation of all or a subset of the identified, potentially

cost-beneficial SAMAs. The staff agrees that the implementation of the "recommended"

SAMAs by NMC is beneficial, and that after implementing the recommended SAMAs, only one

additional SAMA remains potentially cost-beneficial. However, this SAMA does not relate to

adequately managing the effects of aging during the period of extended operation. Therefore, it

need not be implemented as part of license renewal pursuant to Title 10 of the Code of Federal

Regulations, Part 54.

G.8 References

Northern States Power Company (NSP). 1992. Letter from Thomas M. Parker, NSP to U.S.

Nuclear Regulatory Commission Document Control Desk. Subject: "Monticello Nuclear

NUREG-1437, Supplement 26 G-28 August 2006 1 -
Appendix G

Generating Plant, Docket No. 50-263, License No. DPR-22." Submittal of Monticello Individual

Plant Examination Report. February 27, 1992.

Northern States Power Company (NSP). 1995a. Letter from W. J. Hill, NSP to NRC Document

Control Desk. Subject: "Submittal of Monticello Individual Plant Examination of External Events

Report." March 1, 1995.

Northern States Power Company (NSP). 1995b. Letter from W. J. Hill, NSP to NRC Document

Control Desk. Subject: "Submittal of Monticello Individual Plant Examination of External Events

Report, Revision 1; Seismic Analysis, Revision 0 and Internal Fires Analysis, Revision 1 (TAC

M83644)." November 20, 1995.

Nuclear Management Company (NMC). 2005a. Applicant's Environmental Report-Operating

License Renewal Stage, Monticello Nuclear Generating Plant. Docket No. 50-263, License No.

DPR-22. Monticello, Minnesota.

Nuclear Management Company (NMC). 2005b. Letter from John T. Conway, NMC to NRC

Document Control Desk. Subject: "Response to Request for Additional Information Regarding

Severe Accident Mitigation Alternatives for the Monticello Nuclear Generating Plant (TAC

MC6441)." July 27, 2005.

U.S. Census Bureau (USCB). 2000a. Census 2000 Summary File 1 - 100 percent data.

Available online at: http://www.census.gov/Press-Release/www/2001/SumFilel .html

U.S. Census Bureau (USCB). 2000b. 2000 Redistricting Data (P.L. 94-171) Summary File and

1990 Census. Table 1 Counties in Alphabetical Sort within State, 1990 and 2000 Population,

Numeric and Percent Change: 1990 to 2000. April 2, 2001. Available online at:

http://www.census.gov/population/cen2000/phc-t4/tabO0 .xls

U.S. Department of Agriculture (USDA). 1998. 1997 Census of Agriculture, National

Agriculture Statistics Service, 1998. Available online at:

http://www.nass.usda.gov/census/census97/volumel/vol1pubs.htm.

U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment

for Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1991. Supplement 4 to Generic Letter 88-20,

"Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities,

10 CFR 50.54(f)," June 28, 1991.

August 2006 G-29 NUREG-1437, Supplement 26 1
Appendix G

U.S. Nuclear Regulatory Commission (NRC). 1994. Letter from Beth A. Wetzel, U.S. NRC, to

Roger 0. Anderson, NSP. Subject: "Staff Evaluation of the Monticello Nuclear Generating

Plant Individual Plant Examination - Internal Events Submittal (TAC M74435)." May 26, 1994.

U.S. Nuclear Regulatory Commission (NRC). 1997a. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance. NUREG-1 560, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. Regulatory Analysis Technical

Evaluation Handbook. NUREG/BR-0184, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from Tae Kim, U.S. NRC to

Roger 0. Anderson, NSP. Subject: "Plant-Specific Safety Evaluation for USI A-46 Program

Implementation at Monticello Nuclear Generating Plant (TAC No. 69460)."

November 12, 1998.

U.S. Nuclear Regulatory Commission (NRC). 2000. Letter from Carl F. Lyon, U.S. NRC to

Michael F. Hammer, NSP. Subject: "Review of Monticello Individual Plant Examination of

External Events Submittal." April 14, 2000.

U.S. Nuclear Regulatory Commission (NRC). 2003. SECPOP2000: Sector Population, Land

Fraction, and Economic Estimation Program. NUREG/CR-6525, Rev. 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory.Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005. Letter from Jennifer A. Davis, U.S. NRC,

to Thomas J. Palmisano, NMC. Subject: "Request for Additional Information Regarding

Severe Accident Mitigation Alternatives for Monticello Nuclear Generating Plant (TAC

MC6441)." May27, 2005.

NUREG-1 437, Supplement 26 G -30 August 2006 1
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, IN any.)

BIBLIOGRAPHIC DATA SHEET

(See iutnctions on e reverse) NUREG-1437, Supplement 26

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement MONTH YEAR

26 Regarding Monticello Generating Plant

Final Report August 2006

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

See Appendix B of Report Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division. Ofrce or Region. U.S. NuclearRegulatory Commission, and maltng address; if contractor,

provide name and maJwv address.)

Division of Ucense Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

9. SPONSORING ORGANIZATION -NAME AND ADDRESS (If NRC, te Same as above'; icontractor, provide NRC Dbion, Office or Region, U.S. Nuclear RegulatoryCommission,

and main address.)

" Same as 8. above

10. SUPPLEMENTARY NOTES 1`1r L-ft M,.- Im~ iz:n'!or Wý V

11. ABSTRACT (200 words or less)

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

Nuclear Regulatory Commission (NRC) by Nuclear Management Company, LLC (NMC), to renew the operating license for the

Monticello Nuclear Generating Plant (Monticello), for an additional 20 years under 10 CFR Part 54. This SEIS includes the

staffs analysis that considers and weighs the environmental effects of the proposed action, the environmental impacts of

alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also

includes the staff's recommendation regarding the proposed action and responses to the draft SEIS.

The recommendation of the NRC staff Is that the Commission determine that the adverse environmental impacts of license

renewal for Monticello are not so great that preserving the option of license renewal for energy-planning decisionmarkers would

be unreasonable. This recommendation is based on the following: (1) the analysis and findings in the Generic Environmental

Impact Statement for License Renewal of Nuclear Plants (NUREG-1437); (2) the Environmental Report submitted by NMC; (3)

consultation with other Federal, State, and Local agencies; (4) the staff's own independent review; and (5) the staffs

consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words orphrases that wil assist rseairchers ihn ocat•ig the eport.) 13. AVNLABILITY STATEMENT

Monticello Nuclear Generating Plant unlimited

Monticello 14. SECURITY CLASSIFICATION

Supplement to the Generic Environmental Impact Statement (This Page)

GElS unclassified

National Environmental Policy Act (This Report)

NEPA unclassified

License Renewal

15. NUMBER OF PAGES

16. PRICE

.NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
Federal Recycling Program