Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 42 

Regarding Duane Arnold 

Energy Center 

Final Report 

Office of Nuclear Reactor Regulation 

NUREG-1437 

Supplement 42 
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Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 42 

Regarding Duane Arnold 

Energy Center 

Final Report 

Manuscript Completed: October 2010 

Date Published: October 2010 

Office of Nuclear Reactor Regulation 

NUREG-1437 

Supplement 42 

October 2010 iii NUREG-1437, Supplement 42 

ABSTRACT 

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

to an application submitted by NextEra Energy Duane Arnold, LLC (formerly known as FPL 

Energy Duane Arnold, LLC [FPL-DA]) to renew the operating license for Duane Arnold Energy 

Center (DAEC) for an additional 20 years. 

This final SEIS evaluates the environmental impacts of the proposed action and alternatives to 

the proposed action. Alternatives considered include replacement power from a new 

supercritical coal-fired generation or natural gas combined-cycle generation plant; this is 

followed by a combination of alternatives that includes some energy conservation/energy 

efficiency measures, natural gas-fired capacity, and a wind power component. The analysis 

also evaluates the environmental effects that could occur if the U.S. Nuclear Regulatory 

Commission (NRC) takes no action to issue a renewed license for DAEC (No-Action 

alternative). Section 8.4 explains why the staff dismissed many other alternatives from in-depth 

consideration. 

The NRC has determined that the adverse environmental impacts of license renewal for DAEC 

are not great enough to deny the option of license renewal for energy-planning decision makers. 

This determination is based on (1) the analysis and findings in the Generic Environmental 

Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 

2; (2) the environmental report submitted by NextEra Energy Duane Arnold, LLC; (3) 

consultation with Federal, State, and local agencies; (4) the NRC staff’s own independent 

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

process and draft SEIS comment period. 

October 2010 v NUREG-1437, Supplement 42 

TABLE OF CONTENTS 

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

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

FIGURES ..................................................................................................................................... ix 

TABLES ........................................................................................................................................ x 

EXECUTIVE SUMMARY ............................................................................................................ xiii 

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

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

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

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

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

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

1.5 Supplemental Environmental Impact Statement ...................................................... 1-5 

1.6 Cooperating Agencies .............................................................................................. 1-6 

1.7 Consultations ............................................................................................................ 1-6 

1.8 Correspondence ....................................................................................................... 1-7

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

1.10 References ............................................................................................................. 1-10 

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

2.1 Facility and Site Description and Proposed Plant Operation during the 

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

2.1.1 Reactor and Containment Systems .................................................................... 2-5 

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

2.1.2.1 Radioactive Liquid Waste .......................................................................... 2-7

2.1.2.2 Radioactive Gaseous Waste ..................................................................... 2-8

2.1.2.3 Radioactive Solid Waste ............................................................................ 2-8

2.1.2.4 Nonradioactive Hazardous Waste Streams ............................................... 2-9

2.1.2.5 Pollution Prevention and Waste Minimization.......................................... 2-11

2.1.3 Facility Operation and Maintenance ................................................................. 2-11 

2.1.4 Power Transmission System ............................................................................ 2-11 

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

2.1.6 Facility Water Use and Quality ......................................................................... 2-15 

2.1.6.1 Groundwater Use .................................................................................... 2-15

2.1.6.2 Surface Water Use .................................................................................. 2-16

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

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

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

2.2.2.1 Air Quality ................................................................................................ 2-19

2.2.3 Groundwater Resources .................................................................................. 2-20 

2.2.4 Surface Water Resources ................................................................................ 2-21 

2.2.5 Description of Aquatic Resources .................................................................... 2-25 

2.2.5.1 Benthic Macroinvertebrates ..................................................................... 2-26
Table of Contents 

NUREG-1437, Supplement 42 vi October 2010 

2.2.5.2 Freshwater Mussels ................................................................................ 2-26

2.2.5.3 Fish .......................................................................................................... 2-27

2.2.6 Description of Terrestrial Resources ................................................................ 2-28 

2.2.7 Protected Species ............................................................................................ 2-30 

2.2.7.1 Aquatic Species ....................................................................................... 2-30

2.2.7.2 Terrestrial Species ................................................................................... 2-31

2.2.8 Socioeconomic Factors .................................................................................... 2-37 

2.2.8.1 Housing ................................................................................................... 2-38

2.2.8.2 Public Services ........................................................................................ 2-38

2.2.8.3 Offsite Land Use ...................................................................................... 2-40

2.2.8.4 Aesthetics and Noise ............................................................................... 2-40

2.2.8.5 Demography ............................................................................................ 2-41 

2.2.8.6 Economy ................................................................................................. 2-45

2.2.9 Historic and Archaeological Resources ............................................................ 2-48 

2.2.9.1 Cultural Background ................................................................................ 2-48

2.2.9.2 Historic and Archaeological Resources ................................................... 2-49

2.3 Related Federal and State Activities ...................................................................... 2-50 

2.4 References ............................................................................................................. 2-51 

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

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

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

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

4.2 Air Quality ................................................................................................................. 4-1 

4.3 Groundwater ............................................................................................................. 4-2 

4.3.1 Generic Groundwater Issues .............................................................................. 4-2 

4.3.2 Groundwater Use Conflicts (Plants That Use More Than 100 [378 Liter] 

Gallons per Minute) ............................................................................................ 4-3 

4.3.3 Groundwater Use Conflicts (Makeup from a Small River) .................................. 4-4 

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

4.4.1 Water Use Conflicts ............................................................................................ 4-5 

4.5 Aquatic Resources ................................................................................................... 4-6 

4.6 Terrestrial Resources ............................................................................................... 4-6 

4.7 Threatened and Endangered Species ...................................................................... 4-7 

4.7.1 Aquatic Species .................................................................................................. 4-7 

4.7.2 Terrestrial Species ............................................................................................. 4-8 

4.8 Human Health .......................................................................................................... 4-8

4.8.1 Generic Human Health Issues............................................................................ 4-8 

4.8.2 Microbiological Organisms – Public Health ...................................................... 4-10 

4.8.3 Electromagnetic Fields – Acute Shock ............................................................. 4-12 

4.8.4 Electromagnetic Fields – Chronic Effects ......................................................... 4-13 

4.9 Socioeconomics ..................................................................................................... 4-14 

4.9.1 Generic Socioeconomic Issues ........................................................................ 4-14 

4.9.2 Housing Impacts ............................................................................................... 4-15 

4.9.3 Public Services: Public Utility Impacts .............................................................. 4-16 

4.9.4 Offsite Land Use ............................................................................................... 4-16 

4.9.4.1 Population-Related Impacts .................................................................... 4-17

4.9.4.2 Tax-Revenue-Related Impacts ................................................................ 4-17

4.9.5 Public Services: Transportation Impacts .......................................................... 4-17 

4.9.6 Historic and Archaeological Resources ............................................................ 4-18 
Table of Contents 

October 2010 vii NUREG-1437, Supplement 42 

4.9.7 Environmental Justice ...................................................................................... 4-20 

4.9.7.1 Minority Population in 2000 ..................................................................... 4-21

4.9.7.2 Low-Income Population in 2000 .............................................................. 4-22 

4.9.7.3 Analysis of Impacts .................................................................................. 4-23

4.9.7.4 Subsistence Consumption of Fish and Wildlife ....................................... 4-24

4.10 Evaluation of New and Potentially Significant Information ..................................... 4-26 

4.11 Cumulative Impacts ................................................................................................ 4-27 

4.11.1 Land Use .......................................................................................................... 4-27

4.11.2 Cumulative Air Quality Impacts ........................................................................ 4-27 

4.11.3 Cumulative Impacts on Water Resources ........................................................ 4-28 

4.11.4 Cumulative Impacts on Aquatic Resources ...................................................... 4-28 

4.11.5 Cumulative Impacts on Terrestrial Resources .................................................. 4-29 

4.11.6 Cumulative Human Health Impacts .................................................................. 4-31 

4.11.7 Cumulative Socioeconomic Impacts................................................................. 4-32 

4.11.8 Historic and Archaeological Resources Cumulative Impacts ........................... 4-32 

4.11.9 Summary of Cumulative Impacts...................................................................... 4-33 

4.12 References ............................................................................................................. 4-35 

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

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

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

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

5.3.1 Introduction ......................................................................................................... 5-3 

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

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

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

5.3.5 Cost-Benefit Comparison ................................................................................... 5-6 

5.3.6 Conclusions ........................................................................................................ 5-7 

5.4 References ............................................................................................................... 5-7 

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, SOLID WASTE 

MANAGEMENT, AND GREENHOUSE GAS EMISSIONS ............................................ 6-1 

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

6.2 Greenhouse Gas Emissions ..................................................................................... 6-2 

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

6.2.2 Conclusions: Relative Greenhouse Gas Emissions ........................................... 6-9 

6.3 References ............................................................................................................. 6-10 

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

7.1 Decommissioning ..................................................................................................... 7-1 

7.2 References ............................................................................................................... 7-2 

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

8.1 Supercritical Coal-Fired Generation ......................................................................... 8-3 

8.1.1 Air Quality ........................................................................................................... 8-5 

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

8.1.3 Surface Water Use and Quality .......................................................................... 8-9 

8.1.4 Aquatic and Terrestrial Ecology.......................................................................... 8-9 

8.1.5 Human Health .................................................................................................. 8-10 

8.1.6 Socioeconomics ............................................................................................... 8-10 

8.1.7 Waste Management ......................................................................................... 8-13 
Table of Contents 

NUREG-1437, Supplement 42 viii October 2010 

8.2 Natural Gas Combined-Cycle Generation .............................................................. 8-14 

8.2.1 Air Quality ......................................................................................................... 8-16 

8.2.2 Groundwater Use and Quality .......................................................................... 8-18 

8.2.3 Surface Water Use and Quality ........................................................................ 8-18 

8.2.4 Aquatic and Terrestrial Ecology........................................................................ 8-18 

8.2.5 Human Health .................................................................................................. 8-19 

8.2.6 Socioeconomics ............................................................................................... 8-20 

8.2.7 Waste Management ......................................................................................... 8-23 

8.3 Combination Alternative ......................................................................................... 8-24 

8.3.1 Air Quality ......................................................................................................... 8-25 

8.3.2 Groundwater Use and Quality .......................................................................... 8-27 

8.3.3 Surface Water Use and Quality ........................................................................ 8-27 

8.3.4 Aquatic and Terrestrial Ecology........................................................................ 8-27 

8.3.5 Human Health .................................................................................................. 8-28 

8.3.6 Socioeconomics .............................................................................................. 8-28 

8.3.7 Waste Management ......................................................................................... 8-32 

8.4 Alternatives Considered But Dismissed ................................................................. 8-33 

8.4.1 Offsite Coal- and Gas-Fired Capacity............................................................... 8-33 

8.4.2 Coal-Fired Integrated Gasification Combined-Cycle ........................................ 8-33 

8.4.3 New Nuclear ..................................................................................................... 8-33 

8.4.4 Energy Conservation/Energy Efficiency ........................................................... 8-34 

8.4.5 Purchased Power ............................................................................................. 8-34 

8.4.6 Solar Power ...................................................................................................... 8-35 

8.4.7 Wood Waste ..................................................................................................... 8-35 

8.4.8 Hydroelectric Power ......................................................................................... 8-35 

8.4.9 Wave and Ocean Energy ................................................................................. 8-36 

8.4.10 Geothermal Power ........................................................................................... 8-36 

8.4.11 Municipal Solid Waste ...................................................................................... 8-36 

8.4.12 Biofuels ............................................................................................................. 8-36 

8.4.13 Oil-Fired Power ................................................................................................ 8-37 

8.4.14 Fuel Cells ......................................................................................................... 8-37 

8.4.15 Delayed Retirement .......................................................................................... 8-37 

8.5 No-Action Alternative .............................................................................................. 8-37 

8.5.1 Air Quality ......................................................................................................... 8-39 

8.5.2 Groundwater Use and Quality .......................................................................... 8-39 

8.5.3 Surface Water Use and Quality ........................................................................ 8-39 

8.5.4 Aquatic and Terrestrial Resources ................................................................... 8-39 

8.5.5 Human Health .................................................................................................. 8-39 

8.5.6 Socioeconomics ............................................................................................... 8-40 

8.5.7 Waste Management ......................................................................................... 8-41 

8.6 Alternatives Summary ............................................................................................ 8-41 

8.7 References ............................................................................................................. 8-43 

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

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

9.1.1 Other Environmental Impacts ............................................................................. 9-1 

9.2 Comparison of Environmental Impacts of License Renewal and Alternatives ......... 9-2 

9.3 Special Considerations Pursuant to Section 102(2) of NEPA .................................. 9-3 

9.3.1 Unavoidable Adverse Environmental Impacts .................................................... 9-3 

9.3.2 Relationship between Local Short-term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity............................... 9-4 
Table of Contents 

October 2010 ix NUREG-1437, Supplement 42 

9.3.3 Irreversible and Irretrievable Commitments of Resources ................................. 9-6 

9.4 Recommendations ................................................................................................... 9-7 

9.5 References ............................................................................................................... 9-7 

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

11.0 INDEX .......................................................................................................................... 11-1 

12.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THE 

SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT ARE SEND ................ 12-1 

APPENDIXES 

Appendix A - Comments Received On The Duane Arnold Energy Center 

Environmental Review .................................................................................................. A-1 

Appendix B - National Environmental Protection Agency Issues For License Renewal 

Of Nuclear Power Plants ............................................................................................... B-1 

Appendix C - Applicable Regulations, Laws, And Agreements ................................................ C-1 

Appendix D - Consultation Correspondences ........................................................................... D-1 

Appendix E - Chronology Of Environmental Review Correspondence ..................................... E-1 

Appendix F - U.S. Nuclear Regulatory Commission Staff Evaluation Of Severe Accident 

Mitigation Alternatives For Duane Arnold Energy Center In Support Of License 

Renewal Application Review .......................................................................................... F-1

FIGURES 

Figure 1-1. Environmental Review Process ............................................................................. 1-2 

Figure 1-2. Environmental Issues Evaluated during License Renewal .................................... 1-5 

Figure 2-1. Location of Duane Arnold Energy Center, within a 6-Mile Radius ......................... 2-1 

Figure 2-2. Plant Site, Switchyard, and Transmission Lines .................................................... 2-2 

Figure 2-3. Duane Arnold Energy Center Property Boundaries and Facility Layout ................ 2-3 

Figure 2-4. Location of Duane Arnold Energy Center, within a 50-Mile Radius ....................... 2-4 

Figure 2-5. Simplified Design of a Boiling Water Reactor ........................................................ 2-6 

Figure 2-6. The Process of Nuclear Fission ............................................................................. 2-6 

Figure 2-7. Duane Arnold Energy Center Transmission Line System ................................... 2-13 

Figure 4-1. Aggregate Minority Population within a 50-Mile Radius of 

Duane Arnold Energy Center .............................................................................. 4-22 

Figure 4-2. Low-Income Population within a 50-Mile Radius of 

Duane Arnold Energy Center .............................................................................. 4-23 
Table of Contents 

NUREG-1437, Supplement 42 x October 2010 

TABLES 

Table I-1. Comparison of the Impacts of the DAEC License Renewal and its Three 

Reasonable Alternatives ....................................................................................... xviii 

Table 1-1. List of persons who received a copy of the SEIS .................................................. 1-8 

Table 1-2. Licenses and Permits ............................................................................................ 1-9 

Table 2-1. Duane Arnold Energy Center Transmission Lines .............................................. 2-14 

Table 2-2. Monthly Flow Rates between 1903 and 2008 ..................................................... 2-17 

Table 2-3. Chemical Additives Listed in National Pollutant Discharge Elimination 

System Application .............................................................................................. 2-24 

Table 2-4. Listed Aquatic Species ........................................................................................ 2-31

Table 2-5. Listed Terrestrial Species .................................................................................... 2-34

Table 2-6. Duane Arnold Energy Center Permanent Employee Residence 

by County in 2006 ................................................................................................ 2-37 

Table 2-7. Housing in Linn and Benton Counties, Iowa ........................................................ 2-38 

Table 2-8. Major Public Water Supply Systems in Linn and Benton Counties ..................... 2-39 

Table 2-9. Population and Percent Growth in Linn and Benton Counties, Iowa, 

from 1970 to 2000 and Projected for 2010 and 2040 .......................................... 2-42 

Table 2-10. Demographic Profile of the Population in the Duane Arnold Energy Center 

Region of Influence in 2000 ................................................................................. 2-43 

Table 2-11. Seasonal Housing within 50 Miles of Duane Arnold Energy Center, 2000 .......... 2-44 

Table 2-12. Migrant Farm Worker and Temporary Farm Labor within 50 Miles of 

Duane Arnold Energy Center. ............................................................................. 2-45 

Table 2-13. Major Employers in Linn County in 2006 ............................................................. 2-46 

Table 2-14. Income Information for the Duane Arnold Energy Center 

Region of Influence, 2007 .................................................................................... 2-46 

Table 2-15. Property Tax Revenues in Linn County, 2005 to 2008. ....................................... 2-47 

Table 2-16. Historic and Archaeological Sites in the Duane Arnold Energy Center Associated 

Transmission Lines .............................................................................................. 2-50 

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 Onsite Land Use during the Renewal Term ....... 4-1 

Table 4-2. Air Quality Issue .................................................................................................... 4-2 

Table 4-3. Groundwater Use and Quality Issues .................................................................... 4-2 

Table 4-4. Surface Water Quality Issues ................................................................................ 4-5 

Table 4-5. Aquatic Resource Issues ....................................................................................... 4-6 

Table 4-6. Terrestrial Resource Issues ................................................................................... 4-6 

Table 4-7. Threatened or Endangered Species ...................................................................... 4-7 

Table 4-8. Human Health Issues ............................................................................................ 4-8

Table 4-9. The Maximum Daily Discharge Temperatures, Reported in 

DAEC NPDES Reports for the 2001–2008 Period .............................................. 4-11 

Table 4-10. Category 1 Issues Applicable to Socioeconomics during the Renewal Term .... 4-14 

Table 4-11. Category 2 Issues Applicable to Socioeconomics and Environmental Justice 

during the Renewal Term .................................................................................... 4-15 

Table 4-12. Summary of Cumulative Impacts on Resource Areas ......................................... 4-34 

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

Table 5-2. Duane Arnold Energy Center Core Damage Frequency for Internal Events ......... 5-4 

Table 5-3. Breakdown of Population Dose by Containment Release Mode ........................... 5-5 

Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management ........... 6-2 
Table of Contents 

October 2010 xi NUREG-1437, Supplement 42 

Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal ...................................... 6-6 

Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas .......................... 6-7 

Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources . 6-8 

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

Table 8-1. Summary of Environmental Impacts of Supercritical Coal-Fired Alternative 

Compared to Continued Operation of Duane Arnold Energy Center .................... 8-5 

Table 8-2. Summary of Environmental Impacts of the Natural Gas-Fired Combined-Cycle 

Generation Alternative Compared to Continued Operation of Duane Arnold 

Energy Center ..................................................................................................... 8-16 

Table 8-3. Summary of Environmental Impacts of the Combination Alternative Compared to 

Continued Operation of Duane Arnold Energy Center ........................................ 8-24 

Table 8-4. Summary of Environmental Impacts of No Action Compared to Continued 

Operation of Duane Arnold Energy Center .......................................................... 8-38 

Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives ......... 8-42 

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

Table A-1. Comments on the Scope of the Environmental Review. ...................................... A-1 

Table A-2. Commenters on the Draft SEIS. ........................................................................... A-7 

Table B-1. Summary of Issues and Findings. ........................................................................ B-1 

Table C-1. Environmental Authorizations for Current DAEC Operations. .............................. C-3 

Table C-2. Environmental Authorizations for DAEC License Renewal. ................................. C-5 

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

Table F-1. Duane Arnold Energy Center Core Damage Frequency for Internal Events. ........ F-3 

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

Table F-3. Duane Arnold Energy Center Probabilistic Risk Assessment Historical Summary.F-7 

Table F-4. Dominant Contributors to Seismic Core Damage Frequency. ............................. F-10 

Table F-5. Important Fire Areas and Their Contributions to Fire Core Damage Frequency. F-12 

Table F-6. Severe Accident Mitigation Alternative Cost/Benefit Screening Analysis. ........... F-25 

October 2010 xiii NUREG-1437, Supplement 42 

EXECUTIVE SUMMARY 

BACKGROUND 

By a letter dated September 30, 2008, NextEra Energy Duane Arnold, LLC (formerly known as 

FPL Energy Duane Arnold, LLC [FPL-DA]) submitted an application to the U.S. Nuclear 

Regulatory Commission (NRC) to issue a renewed operating license for Duane Arnold Energy 

Center (DAEC) for an additional 20-year period. 

The following document and the review it encompasses are requirements of NRC regulations 

implementing Section 102 of the National Environmental Policy Act (NEPA) of 1969, of the 

United States Code (42 U.S.C. 4321), 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 indicates that issuing a renewed 

power reactor operating license requires preparation of an environmental impact statement 

(EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the EIS 

prepared at the operating license renewal stage will be a supplement to the Generic 

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

Volumes 1 and 2 (NRC, 1996; 1999). 

Upon acceptance of the FPL-DA application, the NRC staff began the environmental review 

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

conduct a public scoping process. The NRC staff held public scoping meetings on April 22, 

2009, in Hiawatha, Iowa, and conducted a site regulatory audit at the plant in June 2009. 

In preparing this supplemental environmental impact statement (SEIS) for DAEC, the NRC staff 

performed the following: 

● Reviewed FPL-DA’s environmental report (ER) and compared it to the GEIS 

● Consulted with other agencies 

● Conducted a review of the issues following the guidance set forth in 

NUREG-1555, Supplement 1, Standard Review Plans for Environmental 

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

● Considered the public comments received during the scoping process 

● Considered public comments received during the draft SEIS comment period 

PROPOSED ACTION 

FPL-DA initiated the proposed Federal action—issuance of a renewed power reactor operating 

license—by submitting an application for license renewal of DAEC, for which the existing license 

(DPR-49) expires on February 21, 2014. NRC’s Federal action is the decision of whether or not 

to renew the license for an additional period of 20 years. 
Executive Summary 

NUREG-1437, Supplement 42 xiv October 2010 

 PURPOSE AND NEED FOR ACTION 

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

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

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

determined by State, utility, and, where authorized, Federal (other than NRC) decision-makers. 

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

findings in the safety review required by the Atomic Energy Act of 1954 (AEA) or findings in the 

NEPA environmental analysis that would lead the NRC to not grant a license renewal, the NRC 

does not have a role in the energy-planning decisions as to whether a particular nuclear power 

plant should continue to operate. 

If the renewed license is issued, State regulatory agencies and FPL-DA will ultimately decide 

whether or not 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 operating license 

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

current operating license, February 21, 2014. 

ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

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

environmental impacts of the proposed action can be assigned values of SMALL, MODERATE, 

or LARGE. The NRC staff established a process for identifying and evaluating the significance 

of any new and significant information on the environmental impacts of license renewal of 

DAEC. The NRC did not identify information that is both new and significant related to 

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

the scoping process nor the NRC staff’s review has identified any new issue applicable to DAEC 

that has a significant environmental impact. The NRC staff, therefore, relies upon the 

conclusions of the GEIS for all the Category 1 issues applicable to DAEC. 

LAND USE 

SMALL. The NRC staff did not identify any Category 2 impact issues for land use, nor did the 

staff identify any new and significant information during the environmental review; therefore, 

there would be no impacts beyond those discussed in the GEIS. 

AIR QUALITY 

SMALL. The NRC staff did not identify any Category 2 issues for the impact of transmission 

lines on air quality, nor did the staff identify any new or significant information during the 

environmental review; therefore, for plant operation during the license renewal term, there are 

no impacts beyond those discussed in the GEIS. 

GROUNDWATER USE AND QUALITY 

SMALL. Groundwater use conflicts: potable and service water—plants using greater than 

100 gallons per minute (gpm) and plants using cooling towers withdrawing makeup water from a 

small river—are Category 2 issues related to license renewal at DAEC. Information provided by 

FPL-DA, including groundwater level monitoring data and aquifer test data, shows that DAEC 

groundwater withdrawal has no significant effect on nearby groundwater wells and groundwater 

supplies. 
Executive Summary 

October 2010 xv NUREG-1437, Supplement 42 

SURFACE WATER USE AND QUALITY 

SMALL. Water use conflicts—plants with cooling ponds or cooling towers using makeup water 

from a small river with low flow—is a Category 2 issue related to license renewal at DAEC. 

Withdrawals of Cedar River water by DAEC are approximately 0.6 percent of the average 

annual flow of the river. By permit, when river flow falls below 500 cubic feet per second (cfs), 

an upstream reservoir may discharge to the river at a rate equal to the consumptive use rate. At 

this low-flow threshold, flow in the river is only 13 percent of the average flow, the withdrawal 

rate is 5 percent of the low flow, and the return of blowdown to the river results in a net 

consumptive rate of over 3 percent of the low flow. The Staff concludes the impact on surface 

water and indirectly on groundwater due to the use of river makeup water, even during a period 

of low flow, is SMALL. 

AQUATIC RESOURCES 

SMALL. With regard to operation of DAEC during the license renewal term, the NRC did not 

identify any Category 2 issues for aquatic resources, nor did the staff identify any new and 

significant information during the environmental review; therefore, there are no impacts beyond 

those discussed in the GEIS. 

TERRESTRIAL RESOURCES 

SMALL. With regard to operation of DAEC during the license renewal term, the NRC did not 

identify any Category 2 issues for terrestrial resources, nor did the staff identify any new or 

significant information during the environmental review; therefore, there are no impacts beyond 

those discussed in the GEIS. 

THREATENED AND ENDANGERED SPECIES 

SMALL. Impacts to threatened and endangered species during the period of extended 

operation are Category 2 issues. No Federally listed threatened or endangered terrestrial 

species are known to occur on the DAEC site or within the in-scope transmission line right of 

ways (ROWs). Nor are any threatened or endangered aquatic species known to occur within 

the Cedar River near the vicinity of DAEC or within any streams crossed by in-scope 

transmission line ROWs. The NRC staff did not identify any new or significant information 

during the environmental review; therefore, there are no impacts beyond those discussed in the 

GEIS. 

HUMAN HEALTH 

SMALL. With regard to Category 1 human health issues during the license renewal term—

microbiological organisms (occupational health), noise, radiation exposures to public, 

occupational radiation exposures, and electromagnetic fields (chronic effects)—the NRC staff 

did not identify any new or significant information during the environmental review. Therefore, 

there are no impacts beyond those discussed in the GEIS. The chronic effects of 

electromagnetic fields from power lines were not designated as Category 1 or 2 issues, and will 

not be until a scientific consensus is reached on the health implications of these fields. 

Microbiological organisms (public health) and electromagnetic fields–acute effects (electric 

shock) are Category 2 human health issues which are discussed below. 

The NRC staff considers the GEIS finding of “uncertain” for electromagnetic fields–chronic 

effects still appropriate and will continue to follow developments on this issue. 
Executive Summary 

NUREG-1437, Supplement 42 xvi October 2010 

The applicant has no plans to conduct refurbishment activities during the license renewal term, 

thus, no change to radiological conditions is expected to occur. Continued compliance with 

regulatory requirements is expected during the license renewal term; therefore, the impacts 

from radioactive effluents are not expected to change during the license renewal term. 

The NRC staff concludes that thermophilic microbiological organisms are not likely to present a 

public health hazard as a result of DAEC discharges to the Cedar River. The NRC staff 

concludes that impacts on public health from thermophilic microbiological organisms from 

continued operation of DAEC in the license renewal period would be SMALL. 

The NRC staff reviewed FPL-DA’s analysis of electromagnetic fields–acute shock resulting from 

induced charges in metallic structures, and verified that there are no locations under the 

transmission lines that have the capacity to induce more than 5 milliamps (mA) in a vehicle 

parked beneath the line. No induced shock hazard to the public should occur, since the lines 

are operating within original design specifications and meet current National Electric Safety 

Code (NESC) clearance standards. The NRC staff has reviewed the available information, 

including the applicant’s evaluation and computational results. Based on this information, the 

staff concludes that the potential impacts from electric shock during the renewal period would be 

SMALL. The NRC staff did not identify any cost benefit studies applicable to the mitigation 

measures. 

SOCIOECONOMICS 

SMALL to MODERATE. For the Category 1 issues involving public services and aesthetic 

impacts, the NRC staff identified no new and significant information during the environmental 

review; therefore, there would be no impacts beyond those discussed in the GEIS. Category 2 

socioeconomic impacts include housing impacts, public services (public utilities), offsite land 

use, public services (public transportation), and historic and archaeological resources. Since 

FPL-DA has indicated that they have no plans to add non-outage employees during the license 

renewal period, there would be no impact on housing during the license renewal term beyond 

what has already been experienced. DAEC operations during the license renewal term would 

also not increase plant-related population growth demand for public water and sewer services. 

Since there are no planned refurbishment activities at DAEC, there would be no land use 

impacts related to population or tax revenues, and no transportation impacts. 

Based on the NRC staff’s review of past surveys conducted at DAEC, review of the procedures 

for considering historic and archaeological materials at DAEC, and review of the Iowa Historical 

Society and Iowa State Archaeologist files for the region, the NRC staff concludes that the 

potential impacts on historic and archaeological resources at DAEC could be MODERATE. 

DAEC has implemented its revised procedures and cultural resource management plan. 

However, due to the dense concentration of cultural material in the area, there remains a high 

potential for undiscovered resources. Additionally, many of the resources found in the region 

are of high importance (e.g., mound groups). If cultural resources were encountered during 

plant construction or maintenance activities, the disturbance to these resources could constitute 

a MODERATE impact. 

With respect to environmental justice, an analysis of minority and low-income populations 

residing within a 50-mile (80-km) radius of DAEC indicated there would be no disproportionately 

high and adverse impacts to these populations from the continued operation of DAEC during the 

license renewal period. Recent monitoring results indicate that concentrations of contaminants 

in native vegetation, crops, soils and sediments, surface water, fish, and game animals in areas 

surrounding DAEC have been quite low (at or near the threshold of detection) and seldom 
Executive Summary 

October 2010 xvii NUREG-1437, Supplement 42 

above background levels. Consequently, no disproportionately high and adverse human health 

impacts would be expected in special pathway receptor populations in the region as a result of 

subsistence consumption of fish and wildlife. 

SEVERE ACCIDENT MITIGATION ALTERNATIVES 

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

consequences of a variety of highly uncommon but potentially serious accidents, NRC 

regulation 10 CFR 51.53(c)(3)(ii)(L) requires that DAEC evaluate Severe Accident Mitigation 

Alternatives (SAMAs) in the course of license renewal review. SAMAs are potential ways to 

reduce the risk or potential impacts of uncommon but potentially severe accidents, and may 

include changes to plant components, systems, procedures, and training. 

Based on the review of potential SAMAs, the staff concludes that DAEC made a reasonable, 

comprehensive effort to identify and evaluate SAMAs. Based on the review of the SAMAs for 

DAEC, and the plant improvements already made, the staff concludes that none of the 

potentially cost-beneficial SAMAs that relate to adequately managing the effects of aging are 

warranted during the period of extended operation; therefore, they need not be implemented as 

part of the license renewal pursuant to 10 CFR Part 54. 

ALTERNATIVES 

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

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

DAEC operating license (the No-Action alternative). Replacement power options considered 

were: supercritical coal-fired generation; natural gas combined-cycle generation; and as part of 

the combination alternative, some natural gas-fired capacity, construction of wind turbines, and 

a component of energy conservation/energy efficiency. Potential environmental impacts of 

these alternatives were considered at both the DAEC site and at some other unspecified 

alternate location for the wind power component of the combination alternative. Each 

alternative was evaluated using the same impact areas that were used in evaluating impacts 

from license renewal. The results of this evaluation are summarized in the table on the 

following page. 

COMPARISON OF ALTERNATIVES 

A comparison of the impacts of DAEC license renewal with its three reasonable alternatives is 

provided in Table I-1. In the staff’s best professional opinion, the coal-fired alternative is the 

least environmentally favorable alternative, due to: impacts to air quality from nitrogen oxides 

(NOx), sulfur oxides (SOx), particulate matter (PM), polycyclic aromatic hydrocarbons (PAHs), 

carbon monoxide (CO), carbon dioxide (CO2), and mercury—and the corresponding human 

health impacts. Construction impacts on land use, aquatic and terrestrial resources, and 

potentially historic and archaeological resources are also factors that added to this conclusion. 

The gas-fired alternative would have lower water usage and air emissions than the coal-fired 

plant, but emissions would still be sufficient to constitute an environmental concern; 

construction-related impacts on land use and historic and archaeological resources would be 

similar to the coal-fired alternative. The wind power component of the combination alternative 

would have lower air emissions over its life-cycle, but construction, land use, aesthetic, and 

terrestrial impacts could be larger. 

The NRC notes that the renewal of the DAEC license could have a SMALL to MODERATE 

impact on historic and archaeological resources, and would have SMALL impacts on all other 
Executive Summary 

NUREG-1437, Supplement 42 xviii October 2010 

categories evaluated; therefore, in the staff’s professional opinion, renewal of the DAEC license 

is the environmentally preferred action. All other action alternatives capable of meeting the 

needs currently served by DAEC entail potentially equivalent or greater impacts than the 

proposed action involving license renewal of DAEC. The No-Action alternative does not meet 

the purpose and need of this SEIS. 

RECOMMENDATION 

The NRC has determined that the adverse environmental impacts of license renewal for DAEC 

are not great enough to deny the option of license renewal for energy-planning decision makers. 

This determination is based on (1) the analysis and findings in the GEIS; (2) the environmental 

report submitted by NextEra Energy Duane Arnold, LLC; (3) consultation with Federal, State, 

and local agencies; (4) the NRC staff’s own independent review; and (5) the NRC staff’s 

consideration of public comments received during the scoping process and draft SEIS comment 

period. 

Table I-1. Comparison of the Impacts of the DAEC License Renewal and its Three 

Reasonable Alternatives 

Alternative 

Impact Area 

Land Use 

Air Quality 

Groundwater 

Surface Water 

Aquatic and Terrestrial 

Resources 

Human Health 

Socioeconomics 

Waste Management 

DAEC License 

Renewal S S S S S S S to M S(b)

Supercritical 

Coal-Fired Alternative 

at DAEC Site 

S-M M S S S to M S S to M M 

Natural Gas 

Combined-Cycle 

Alternative 

at DAEC Site 

S to M S to M S S S S S to M S 

Combination 

Alternative 1(a) S to M S S S S to M S S to L S 

No-Action Alternative S S S S S S S to M S 

(a) Combination alternative consists of gas-fired generation, wind power, and conservation 

(b) For the DAEC license renewal alternative, waste management was evaluated in Chapter 6. Consistent with the 

findings in the GEIS, these impacts were determined to be SMALL with the exception of collective offsite 

radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal. 

S – SMALL impact 

M – MODERATE impact 

L – LARGE impact
Executive Summary 

October 2010 xix NUREG-1437, Supplement 42 

REFERENCES 

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

License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C., 1996. 

Agencywide Documents Access and Management System (ADAMS) Accession Nos. 

ML040690705 and ML040690738. 

U.S. Nuclear Regulatory Commission (NRC). 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., 1999.

NUREG-1437, Supplement 42 xxi October 2010 

ABBREVIATIONS AND ACRONYMS 

5CBOD 5-day carbonaceous biochemical oxygen demand 

ac acre 

ACRS Advisory Committee on Reactor Safeguards 

ADAMS Agencywide Documents Access and Management System 

AEA Atomic Energy Act of 1954 

AEC U.S. Atomic Energy Commission 

AEO Annual Energy Outlook

ALARA as low as reasonably achievable 

AQCR Northeast Iowa Intrastate Air Quality Control Region 

BACT best available control technology 

BPC Bechtel Power Corporation 

Btu/ft3

 British thermal units per cubic feet 

Btu/kWh British thermal units per kilowatt hour 

Btu/lb British thermal units per pound 

BWR boiling water reactor 

cm centimeter 

CAA Clean Air Act 

CAIR Clean Air Interstate Rule 

CAMR Clean Air Mercury Rule 

CDC Center for Disease Control 

CDF core damage frequency 

CDM Clean Development Mechanism 

CENRAP Central Regional Air Planning Association 

CEQ Council on Environmental Quality 

CESQG conditionally exempt small quantity generator 
Abbreviations and Acronyms 

NUREG-1437, Supplement 42 xxii October 2010 

CFR Code of Federal Regulations

cfs cubic feet per second 

CH4 methane 

CO carbon monoxide 

CO2 carbon dioxide 

COPC chemicals of potential concern 

CRT cathode ray tube 

CWA Clean Water Act 

DAEC Duane Arnold Energy Center 

dB decibels 

DBA design-basis accident 

DDT dichlorodiphenyltrichloroethane 

DOE Department of Energy 

DOT Department of Transportation 

DPR demonstration power reactor 

DSEIS draft supplemental environmental impact statement 

DSM demand-side management 

E.O. Executive Order 

ECCS emergency core cooling system 

EIA Energy Information Administration (of DOE) 

EIS environmental impact statement 

ELF-EMF extremely low frequency-electromagnetic field 

EMF electromagnetic field 

EMS environmental management system 

EOP emergency operating procedure 

ER environmental report 

EPA Environmental Protection Agency 

EPCRA Emergency Planning and Community Right-to-Know Act 
Abbreviations and Acronyms 

October 2010 xxiii NUREG-1437, Supplement 42 

ESA Endangered Species Act of 1973 

ESW emergency service water 

ft/s feet per second 

ft3

/s cubic ft per second 

ft3

/year cubic ft per year 

FES final environmental statement 

FPL Florida Power and Light 

FPL-DA Florida Power and Light Energy Duane Arnold, LLC 

FR Federal Register

FSAR final safety analysis report 

ft feet 

ft/s feet per second 

ft3

/s cubic ft per second 

ft3

/yr cubic ft per year 

g Ceq/kWh grams of CO2 equivalents per kilowatt-hour 

GE General Electric 

GEIS generic environmental impact statement 

GHG greenhouse gas 

gpd gallons per day 

gpm gallons per minute 

ha hectare 

HAP hazardous air pollutants 

HFC hydrofluorocarbons 

HFE hydrofluorinated ethers 

HLW high-level waste 

HVAC heating, ventilation, and air conditioning 

Hz hertz 
Abbreviations and Acronyms 

NUREG-1437, Supplement 42 xxiv October 2010 

in inch 

IAC Iowa Administrative Code 

IBI Index of Biotic Integrity 

ICCAC Iowa Climate Change Advisory Council 

IDPH Iowa Department of Public Health 

IDNR Iowa Department of Natural Resources 

IGCC integrated gasification combined-cycle 

Inc. incorporated 

IPA integrated plant assessment 

IPE individual plant examination 

IPEEE individual plant examination of external events 

ISFSI independent spent fuel storage installation 

ISO International Standardization Organization 

ITC ITC Midwest LLC 

J joule 

kg kilogram 

km kilometers 

km2 kilometers squared 

kV kilovolts 

kW kilowatt 

kWh kilowatt hour 

lb pound 

lb/MWh pound per megawatt-hour 

LCCO Linn County Code of Ordinances 

LCPH Linn County Public Health Department 

LLC limited liability corporation 
Abbreviations and Acronyms 

October 2010 xxv NUREG-1437, Supplement 42 

LLMW low-level mixed waste 

LLW low–level radioactive waste 

LOCA loss of coolant accident 

LOS level of service 

LQG large quantity generator 

LWR light-water reactor 

m meter 

mA milliamps 

mi miles 

mg/L milligrams per liter 

mgd million gallons per day 

mGy milligray 

mi2 miles squared 

mph miles per hour 

m/s meters per second 

m3

/s cubic meters per second 

m3

/yr cubic meters per year 

m2 meters squared 

m3

/day cubic meters per day 

mrad milliradiation absorbed dose 

mrem milliroentgen equivalent man 

mrem/yr milliroentgen equivalent man per year 

MRS Midcontinent Rift System 

msl mean sea level 

mSv millisievert 

MT metric ton 

MTU metric ton uranium 

MW megawatt 

MWe megawatt-electric 
Abbreviations and Acronyms 

NUREG-1437, Supplement 42 xxvi October 2010 

MWt megawatt-thermal 

ug/L micrograms per liter 

ug/m3 micrograms per cubic meter 

N/A not applicable 

N2O nitrous oxide 

NAAQS National Ambient Air Quality Standards 

NAS National Academy of Sciences 

NAWQA National Water-Quality Assessment 

NCI National Cancer Institute 

NEPA National Environmental Policy Act of 1969 

NESC National Electrical Safety Code 

NF3 nitrogen trifluoride 

ng nanogram 

NHPA National Historic Preservation Act 

NIEHS National Institute of Environmental Health Sciences 

NOx nitrogen oxide(s) 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

NSR New Source Review 

NUREG NRC Regulatory Guide 

NWS National Weather Service 

O3 ozone 

PAH polycyclic aromatic hydrocarbon 

Pb lead 

PCB polychlorinated biphenol 

pCi/L picocuries per liter 
Abbreviations and Acronyms 

October 2010 xxvii NUREG-1437, Supplement 42 

PDS plant damage state 

PFC perfluorocarbons 

PM particulate matter 

PM2.5 particulate matter, 2.5 microns or less in diameter 

PM10 particulate matter, 10 microns or less in diameter 

POE potential to emit 

PRA probabilistic risk assessment 

PSA probabilistic safety assessment 

Psig pound-force per square inch gauge 

PTE potential to emit 

R-12 dichlorodifluoromethane 

R-22 chlorodifluoromethane 

RBCCW reactor building closed cooling water 

RCRA Resource Conservation and Recovery Act 

rem roentgen equivalent man 

REMP radiological environmental monitoring program 

RHRSW residual heat removal service water 

ROI region of influence 

ROP Reactor Oversight Process 

ROW(s) right of way(s) 

RPO regional planning organization 

RPV reactor pressure vessel 

SAMA Severe Accident Mitigation Alternative 

SAR safety analysis report 

SCR selective catalytic reductions 

SEIS supplemental environmental impact statement 

SER safety evaluation report 

SF6 sulfur hexafluoride 
Abbreviations and Acronyms 

NUREG-1437, Supplement 42 xxviii October 2010 

SHPO State Historic Preservation Office 

SLC standby liquid control 

SO2 sulfur dioxide 

SOx sulfur oxide(s) 

SQG small quantity generator 

SSC system, structure, and component 

STF stormwater and sewage treatment facility 

SPDS safety parameter display system 

Sv sievert 

TLD thermoluminescent dosimeter 

TSC technical support center 

TSP total suspended particles 

TSS total suspended solids 

U Uranium 

UFSAR updated final safety analysis report 

USACE United States Army Corps of Engineers 

USFWS U.S. Fish and Wildlife Service 

U.S. United States 

U.S.C. United States Code

USCB U.S. Census Bureau 

USGS U.S. Geological Survey 

USGCRP United States Global Change Research Program 
October 2010 1-1 NUREG-1437, Supplement 42 

1.0 PURPOSE AND NEED FOR ACTION 

Pursuant to the U.S. Nuclear Regulatory Commission’s (NRC’s) environmental protection 

regulations in Title 10, Part 51, of the U.S. Code of Federal Regulations (10 CFR 51), which 

implement the U.S. National Environmental Policy Act of 1969 (NEPA), an environmental impact 

statement (EIS) is required to be prepared for issuance of a new nuclear power plant operating 

license. 

The Atomic Energy Act of 1954 (AEA) originally specified that licenses for commercial power 

reactors be granted for a period up to 40 years with an option to renew for a period up to 

another 20 years. The 40-year licensing period is based on economic and antitrust 

considerations rather than on technical limitations of the nuclear facility. 

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

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

meet NRC safety and environmental requirements. The NRC staff (Staff) makes the decision to 

grant or deny a license renewal, based on whether or not the applicant has demonstrated that 

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

period of extended operation. 

1.1 PROPOSED FEDERAL ACTION 

NextEra Energy Duane Arnold, LLC (formerly known as FPL Energy Duane Arnold, LLC 

[FPL-DA]) initiated the proposed Federal action by submitting an application for license renewal 

of Duane Arnold Energy Center (DAEC), for which the existing license number DPR-49 

currently expires on February 21, 2014. The NRC’s Federal action is the decision of whether or 

not to renew the license for an additional 20 years. 

1.2 PURPOSE AND NEED FOR THE PROPOSED FEDERAL ACTION 

The purpose and need for the proposed action (issuance of a renewed 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, which may be determined by 

State, utility, and, where authorized, Federal (other than NRC) decision-makers. This definition 

of purpose and need reflects the Commission’s recognition that, unless there are findings in the 

safety review required by the AEA or findings in the NEPA environmental analysis that would 

lead the NRC to not grant a license renewal, the NRC does not have a role in the 

energy-planning decisions of State regulators and utility officials as to whether or not a particular 

nuclear power plant should continue to operate. 

If the renewed license is issued, State regulatory agencies and FPL-DA will ultimately decide 

whether the plant will continue to operate or not 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 operating 

license is not renewed, the facility must be shut down on or before the expiration date (February 

21, 2014) of the current operating license. 
Purpose and Need for Action 

NUREG-1437, Supplement 42 1-2 October 2010 

1.3 MAJOR ENVIRONMENTAL REVIEW MILESTONES 

Figure 1-1. Environmental Review Process. The 

environmental review provides opportunities for public 

involvement.

As part of its license renewal 

application, DAEC submitted an 

environmental report (ER) dated 

September 30, 2008 (FPL-DA, 

2008). After reviewing the 

application and the ER for 

sufficiency, the Staff published a 

notice of acceptance for docketing of 

the application on February 17, 

2009, in the Federal Register (FR) 

(73 FR 7489). On March 24, 2009, 

the NRC published another notice in 

the FR (74 FR 12399) on its intent to 

conduct scoping, thereby beginning 

a 60-day public scoping period for 

the supplemental environmental 

impact statement (SEIS). 

The NRC conducted two public 

scoping meetings on April 22, 2009, 

in Hiawatha, Iowa. The Staff 

prepared an SEIS scoping process 

summary report dated August 7, 

2009, which presents the comments 

received during the scoping process 

(NRC, 2009a). Appendix A to this 

SEIS presents comments considered 

to be within the scope of the 

environmental license renewal 

review and the associated NRC 

responses. 

To independently verify information 

provided in the ER, the Staff 

conducted a site audit at the DAEC 

site in June of 2009. During the site 

audit, the Staff met with plant 

personnel, reviewed specific 

documentation, toured the facility, 

and met with interested Federal, State, and local agencies. A summary of that site audit and 

the attendees is contained in the site audit summary report (NRC, 2009b). 
Purpose and Need for Action 

October 2010 1-3 NUREG-1437, Supplement 42 

On completion of the scoping period and site audit, the 

Staff compiled its findings in a draft SEIS (Figure 1-1). 

The draft SEIS was issued for public review, during 

which time, the Staff hosted public meetings and 

collected public comments. Based on the information 

gathered, the Staff amended the draft SEIS findings as 

necessary, and published this final SEIS. 

The Staff has established a license renewal process 

that can be completed in a reasonable period of time 

with clear requirements to assure safe plant operation 

for up to an additional 20 years. The safety review, 

which documents its finding in a safety evaluation report (SER), is conducted simultaneously 

with the environmental review process. Both the findings in the SEIS and the SER are factors 

considered in the Commission’s decision to either grant or deny the issuance of a new license. 

1.4 GENERIC ENVIRONMENTAL IMPACT STATEMENT 

To improve the efficiency of the license renewal process, the Staff prepared a generic 

assessment of the environmental impacts associated with license renewal. Specifically, the 

agency prepared NUREG-1437, Generic Environmental Impact Statement (GEIS) for License 

Renewal of Nuclear Power Plants, which evaluates the environmental consequences of 

renewing the licenses of individual nuclear power plants and operating them for an additional 

20 years (NRC, 1996), (NRC, 1999).1

 The Staff analyzed those environmental issues that could 

be resolved generically in the GEIS. 

The GEIS investigates 92 separate issues for the Staff to consider. Of these, the Staff 

determined that 69 are generic to all plants (Category 1), while 21 issues do not lend 

themselves to generic consideration (Category 2). Two other issues remain uncategorized; 

environmental justice and the chronic effects of electromagnetic fields, which must be evaluated 

on a site-specific basis. Appendix B of this report lists all 92 issues. 

For each environmental issue, the GEIS: (1) describes the activity that affects the environment, 

(2) identifies the population or resource that is affected, (3) assesses the nature and magnitude 

of the impact on the affected population or resource, (4) characterizes the significance of the 

effect for both beneficial and adverse effects, (5) determines whether the results of the analysis 

apply to all plants or not, and (6) considers whether additional mitigation measures are 

warranted or not for impacts that would have the same significance level for all plants. 

The GEIS assesses the significance of these issues, using the Council on Environmental 

Quality (CEQ) terminology for “significant.” The Staff established three levels of significance for 

potential impacts—SMALL, MODERATE, and LARGE. The three levels of significance are 

defined below: 

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

destabilize nor noticeably alter any important attribute of the resource. 

 

1

 The NRC originally issued the GEIS in 1996 and issued Addendum 1 to the GEIS in 1999. Hereafter, all references 

to the GEIS include the GEIS and Addendum 1. 

Significance indicates the 

importance of likely environmental 

impacts and is determined by 

considering two variables: context

and intensity. 

Context is the geographic, 

biophysical, and social context in 

which the effects will occur. 

Intensity refers to the severity of the 

impact, in whatever context it occurs. 
Purpose and Need for Action 

NUREG-1437, Supplement 42 1-4 October 2010 

MODERATE – Environmental effects are sufficient to alter noticeably, but not destabilize, 

important attributes of the resource. 

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize important 

attributes of the resource. 

The GEIS includes a determination of whether or not the analysis of the environmental issue 

could be applied to all plants and whether or not additional mitigation measures are warranted 

(Figure 1-2). Issues are assigned as a Category 1 or a Category 2 designation. As set forth in 

the GEIS, Category 1 issues are those that meet all of the following criteria: 

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

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

or other specified plant or site characteristics. 

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

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

high-level waste and spent fuel disposal. 

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

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

are not likely to be sufficiently beneficial to warrant implementation. 

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

unless new and significant information is identified. Chapter 4 of this report presents the 

process for identifying new and significant information. Site-specific issues (Category 2) are 

those that do not meet one or more of the criterion for Category 1 issues and, therefore, 

additional site-specific review for these issues is required. The SEIS documents the results of 

that site-specific review. 
Purpose and Need for Action 

October 2010 1-5 NUREG-1437, Supplement 42 

Figure 1-2. Environmental Issues Evaluated during License Renewal. Ninety-two issues 

were initially evaluated in the GEIS. A site-specific analysis is required for 23 of those 92 

issues. 

1.5 SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT 

This SEIS presents an analysis of the environmental effects of the continued operation of 

DAEC, potential alternatives to license renewal, and potential mitigation measures for 

minimizing adverse environmental impacts. Chapter 8 contains analyses and comparisons of 

environmental impacts from alternatives. Chapter 9 presents the recommendation to the 

Commission as to whether or not the environmental impact of license renewal are so great that 

preserving the option of license renewal would be unreasonable. 
Purpose and Need for Action 

NUREG-1437, Supplement 42 1-6 October 2010 

In preparing this SEIS, the Staff: 

● reviewed the information provided in the FPL-DA ER 

● consulted with other Federal, State, and local agencies 

● conducted an independent review of the issues during the site audit 

● considered the public comments received during the scoping process and on 

the draft SEIS 

● considered the public comments received during the draft SEIS public comment 

period 

New and significant information can be identified from a number of sources, including the Staff, 

the applicant, other agencies, and public comments. If a new issue is revealed, it is first 

analyzed to determine whether or not it is within the scope of the license renewal evaluation. If 

it is not addressed in the GEIS, then the NRC determines its significance and documents its 

analysis in the SEIS. 

1.6 COOPERATING AGENCIES 

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

agencies in the preparation of this SEIS. 

1.7 CONSULTATIONS 

The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries 

Conservation and Management Act of 1996, as amended; and the National Historic 

Preservation Act of 1966, require that Federal agencies consult with applicable State and 

Federal agencies and groups before taking action that may affect endangered species, 

fisheries, or historic and archaeological resources, respectively. 

Listed below are the agencies and groups with whom the NRC consulted; Appendix D of this 

report includes copies of consultation documents. 

● Iowa Department of Natural Resources 

● Region 3, U.S. Fish and Wildlife Service 

● Iowa State Archaeologist, Office of the State Archaeologist 

● Historic Preservation Officer, State Historical Society of Iowa 
Purpose and Need for Action 

October 2010 1-7 NUREG-1437, Supplement 42 

1.8 CORRESPONDENCE 

Table 1-1 lists persons and organizations to which a copy of this SEIS has been sent. 

Appendix E to this report contains a chronological list of all documents sent and received during 

the environmental review. During the course of the environmental review, the Staff 

corresponded or consulted with the following Federal, State, regional, local, or tribal agencies: 

Advisory Council on Historic Preservation 

National Oceanographic and Atmospheric Administration, National Marine 

Fisheries Service 

Iowa State Archaeologist, Office of the State Archaeologist 

Historic Preservation Officer State Historical Society of Iowa 

Iowa Department of Natural Resources 

Region 3, U.S. Fish and Wildlife Service 

Flandreau Santee Sioux Tribe 

Ho-Chunk Nation 

Iowa Tribe of Oklahoma 

Kickapoo Tribe in Kansas 

Prairie Band of Potawatomi Indians 

Prairie Island Indian Community 

Sac and Fox Nation of Missouri 

Sac and Fox Nation of Oklahoma 

Santee Sioux Nation 

Shakopee Mdewakanton Sioux Community of Minnesota 

Upper Sioux Community of Minnesota 

Winnebago Tribe of Nebraska 

The Sac and Fox Tribe of the Mississippi 

Lower Sioux Indian Community of Minnesota 

Omaha Tribal Council 

Kickapoo Tribe of Oklahoma 

Otoe-Missouria Tribe of Indians 

Iowa Tribe of Kansas and Nebraska 
Purpose and Need for Action 

NUREG-1437, Supplement 42 1-8 October 2010 

Table 1-1. List of persons who received a copy of the SEIS 

Mr. M. S. Ross 

Florida Power & Light Company 

Ms. Marjan Mashhadi 

Florida Power & Light Company 

T. O. Jones, VP 

Florida Power & Light Company 

Steven R. Catron, Manager 

Duane Arnold Energy Center 

U.S. Nuclear Regulatory Commission 

Resident Inspector’s Office 

Mano Nazar 

Sr. VP and Nuclear Chief Operating 

Officer 

Florida Power & Light Company 

D. A. Curtland 

Duane Arnold Energy Center 

Abdy Khanpour, VP 

Florida Power & Light Company 

Melanie Rasmusson 

Iowa Department of Public Health 

Linn County 

Board of Supervisors 

Peter Wells, Acting VP 

Florida Power & Light Company 

U.S. Environmental Protection 

Agency 

Mark E. Warner, VP 

Florida Power & Light Company 

Fredia Perkins, Chairperson 

Sac and Fox Nation of Missouri 

Christie Modlin, Chairperson 

Iowa Tribe of Oklahoma 

Steve Cadue, Chairman 

Kickapoo Tribe in Kansas 

Steve Ortiz, Chairman 

Prairie Band of Potawatomi Indians 

Joshua Weston, President, 

Flandreau Santee Sioux Tribe 

Roger Trudell, Chairman 

Santee Sioux Nation 

John Blackhawk 

Winnebago Tribe of Nebraska 

Ronald Johnson 

Prairie Island Indian Community 

Stanley R. Crooks 

Shakopee Mdewakanton Sioux 

Community of Minnesota 

Kevin Jensvold 

Upper Sioux Community of Minnesota 

Wilfred Cleveland 

Ho-Chunk Nation 

Dusky Terry 

Central Iowa Power Cooperative 

Bennett Brown 

member of the public 

Amir H. Moazzez 

member of the public 

Adrian Pushetonequa 

The Sac and Fox Tribe of the 

Mississippi 

Lori Nelson 

Lower Sioux Indian Community of 

Minnesota 

Amen Sheriden 

Omaha Tribal Council 

Marlon E. Frye 

Kickapoo Tribe of Oklahoma 

John Shotton 

Otoe-Missouria Tribe of Indians 

Leon Campbell 

Iowa Tribe of Kansas and Nebraska 

Dr. Roy Crabtree 

National Oceanic and Atmospheric 

Administration 

National Marine Fisheries Service 

Wayne Gieselman, Administrator 

Iowa Department of Natural Resources 

Tom Melius, Regional 3 Director 

U.S. Fish and Wildlife Service 

Charlene Dwin Vaughn, Assistant 

Director 

Advisory Council on Historic 

Preservation 

John Doershuck, State Archaeologist 

Office of the State Archaeologist 

Jerome Thompson, Interim State 

Historic Preservation Officer 

State Historical Society of Iowa 

George Thurman, Principal Chief 

Sac and Fox Nation of Oklahoma 

1.9 STATUS OF COMPLIANCE 

FPL-DA is responsible for complying with all NRC regulations and other applicable Federal, 

State, and local requirements; Appendix C describes some of the principle Federal statutes for 

which FPL-DA must comply. Table 1-2 lists the numerous permits and licenses issued by 

Federal, State, and local authorities for activities at DAEC. 
Purpose and Need for Action 

October 2010 1-9 NUREG-1437, Supplement 42 

Table 1-2. Licenses and Permits. Existing environmental authorizations for Duane Arnold 

Energy Center Operations. 

Permit/License Number Date Responsible Agency 

License to operate DAEC DPR-49 Issued: 02/21/1974 

Expires: 02/21/2014 

U.S. Nuclear Regulatory 

Commission 

Hazardous materials 

shipment registration 

070908 550 

040QS 

Issued: 07/09/2008 

Expires: 06/30/2011 

U.S. Department of 

Transportation 

Hazardous waste 

generation/transport IAD984566133 N/A U.S. Environmental Protection Agency 

Permit for water intake 

and discharge structures 

and low head dam on 

Cedar River 

71-192 Issued: 08/06/1971 

No expiration date 

Iowa Department of 

Natural Resources (DNR) 

Permit to store water in 

Pleasant Creek Reservoir 

and withdraw water from 

Cedar River 

3533-R3 Issued: 03/14/2004 

Expires:03/13/2014 Iowa DNR 

Dredging for constructing 

spur dikes and 

subsequent maintenance 

dredging 

05-I-113-08-02-S Issued: 08/26/2005 

No expiration date Iowa DNR 

Dredging for spur dikes 

and subsequent 

maintenance dredging 

CEMVR-OD-P-2005-1016 Issued: 09/20/2005 

Expires: 12/31/2010 

U.S. Army Corps of 

Engineers 

Flood Plain Development 

Permit PF07-015 

Issued: 12/04/2007 

One time event, not 

renewed Linn County 

Sovereign Lands 

Construction Permit 06-141 

Issued: 10/10/2006 

One time event, not 

renewed

Iowa DNR 

Sovereign Lands 

Construction Permit 07-175 

Issued: 11/07/2007 

One time event, not 

renewed 

Iowa DNR 

Drinking water system 

operation certification Operator ID# 6007 Issued: 08/29/2007 

Expires: 06/30/2011 Iowa DNR 

National Pollutant 

Discharge Elimination 

System Permit 

57-00-1-04 

IA0003727 

Issued: 07/06/2007 

Application under review 

for renewal. 

Iowa DNR 

Air Operation Permit 

4863, 4864, 4865, 

4866, 4867, 

4868, 4869, 4870 

Expires 10/1/2010 

Renewal in progress Linn County 

Transportation service 

license N/A Issued: 06/30/2011 

Expires: 06/30/2011 

Iowa Department of 

Public Health 

Permit to operate public 

water system ID# IA5715150 Issued: 9/16/2009 

Expires: 12/31/2012 Iowa DNR 

Permit to operate 4-well 

system for potable water 

3046-MR5 

SDWIS Well ID#s: 

WL04, WL05, W06, WL07 

Issued: 07/01/2002 

Expires: 06/30/2012 Iowa DNR 

Underground storage 

tanks N/A N/A Iowa DNR 
Purpose and Need for Action 

NUREG-1437, Supplement 42 1-10 October 2010 

Permit/License Number Date Responsible Agency 

License to ship 

radioactive material T-IA-001-L08 Expires: 12/31/2010 

Tennessee Department of 

Environment and 

Conservation 

License to ship 

radioactive material 0210001768 Expires: 11/24/2010 Utah Department of 

Environmental Quality 

1.10 REFERENCES 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

Atomic Energy Act of 1954. §42 U.S.C. §2011, et seq. 

Endangered Species Act of 1973. §16 U.S.C. §1531, et seq. 

Federal Register (73 FR 7489). U.S. Nuclear Regulatory Commission, Washington D.C., 

“Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing 

Regarding Renewal of Facility Operating License No. DPR-49 for an Additional 20-Year Period 

for FPL Energy Duane Arnold, LLC Duane Arnold Energy Center,” Vol. 74, No. 30, Page 7489–

7491, February 17, 2009. (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML090140399) 

Federal Register (74 FR 12399). U.S. Nuclear Regulatory Commission, Washington D.C., “FPL 

Energy Duane Arnold, LLC; Duane Arnold Energy Center; Notice of Intent to Prepare an 

Environmental Impact Statement and Conduct Scoping Process,” Vol. 74, No. 55, Page 12399–

2401, March 24, 2009. (ADAMS Accession No. ML090140399) 

FPL Energy Duane Arnold, LLC (FPL-DA). 2008. Duane Arnold Energy Center, License 

Renewal Application, Appendix E – Applicant’s Environmental Report – Operating License 

Renewal Stage, Duane Arnold Energy Center, September 2008. (ADAMS Accession No. 

ML082980481) 

Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 

Sustainable Fisheries Act of 1996. §16 U.S.C. §1855, et seq. 

National Environmental Policy Act of 1969. §42 United States Code (U.S.C.) §4321, et seq. 

National Historic Preservation Act of 1966. §16 U.S.C. §470, et seq. 

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

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. 

(ADAMS Accession Nos. ML040690705 and ML040690738) 

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). 2009a. Issuance of the Environmental Scoping 

Summary Report for the Staff’s Review of the License Renewal Application for Duane Arnold 

Energy Center (TAC No. MD9770), August 7, 2009. (ADAMS Accession No. ML092030185) 

U.S. Nuclear Regulatory Commission (NRC). 2009b. Summary of Environmental Site 

Information Review (Site Audit), Related to Review of the License Renewal Application for 

Duane Arnold Energy Center (TAC No. MD9770), July 2, 2009. (ADAMS Accession 

No. ML091750075) 
October 2010 2-1 NUREG-1437, Supplement 42 

2.0 AFFECTED ENVIRONMENT 

Duane Arnold Energy Center (DAEC) is located in Linn County, Iowa, on the western bank of a 

north-south reach of the Cedar River, approximately 2 miles (mi) north-northeast of the town of 

Palo and approximately 3 mi east of the Benton County line. Figure 2-1 shows the location of 

DAEC within a 6-mi radius. 

Because existing conditions are partially the result of past construction and operation at the 

plant, the impacts of these past and ongoing actions and how they have shaped the 

environment are presented in this chapter. Section 2.1 of this report describes the DAEC site, 

facility, and its operation; Section 2.2 discusses the affected environment; and Section 2.3 

describes related Federal and State activities near the DAEC site. 

Figure 2-1. Location of Duane Arnold Energy Center, within a 6-Mile Radius 

(Source: FPL-DA, 2008a, Figure 2.1-1) 
Affected Environment 

NUREG-1437, Supplement 42 2-2 October 2010 

2.1 FACILITY AND SITE DESCRIPTION AND PROPOSED PLANT OPERATION 

DURING THE RENEWAL TERM 

DAEC is located on an approximately 500-acre (ac) (202-hectare (ha)) site in a rural, sparsely 

populated area (Figure 2-2 shows an aerial photograph of the plant site, switchyard, and 

transmission lines). DAEC uses only a small portion of the area for power production; the 

remaining portion is leased to area farmers (FPL-DA, 2007a). The site’s property boundary and 

facility layout are shown in Figure 2-3 (FPL-DA, 2005a). The site is located on a strip of land 

running northeast and parallel to the Cedar River, which is the largest tributary of the Iowa 

River. The site is a flat plain, approximately 750 feet (ft) (230 meters (m)) above mean sea level 

(msl). The general topographical features in this portion of the Cedar River consist of broad 

valleys and narrow flood plains. Across the Cedar River from the site, the land rises to an 

elevation of about 900 ft (270 m). The slopes are heavily wooded, but away from the immediate 

vicinity of the river, the land is gently rolling farmland (FPL-DA, 2005a). 

Figure 2-2. Plant Site, Switchyard, and Transmission Lines (Source: FPL-DA, 2008a) 
Affected Environment 

October 2010 2-3 NUREG-1437, Supplement 42 

Figure 2-3. Duane Arnold Energy Center Property Boundaries and Facility Layout 

(Source: FPL-DA 2008a, Figure 2.1-3) 

Three metropolitan areas lie within 50 mi (80 kilometers (km)) of the DAEC site: Waterloo, 

approximately 34 mi (55 km) to the northwest; Iowa City, approximately 32 mi to the southeast; 

and Cedar Rapids, the closest city, approximately 5.7 mi (9 km) to the southeast (Figure 2-4 

shows a map of DAEC within a 50-mi (80 km) radius). Industrial activities within 10 mi (16km) 

of the site are confined principally to the Cedar Rapids metropolitan area. 
Affected Environment 

NUREG-1437, Supplement 42 2-4 October 2010 

Figure 2-4. Location of Duane Arnold Energy Center, within a 50-Mile Radius 

(Source: FPL-DA, 2008a) 

Located 1 mi northwest of the site is the Pleasant Creek State Recreation Area, a 1,927-ac 

(800-ha) park. Included in this acreage is a 410-ac (166 ha) lake that was jointly developed by 

the Iowa Conservation Commission and the Iowa Electric Light and Power Company to provide 
Affected Environment 

October 2010 2-5 NUREG-1437, Supplement 42 

a supplemental water supply for DAEC and, at the same time, regional recreation opportunities 

(IDNR, 2007a). 

Recreational activities at several park areas within 10 mi (16 km) of the site consist of boating, 

fishing, hunting, camping, hiking, picnicking, and swimming. Palo Marsh Wildlife Refuge, 

located 2 mi south of DAEC, is a 144-ac (58 ha) site featuring a wetland trail and bottomland 

forest for wildlife observation. Wickiup Hill is a 563-ac (228 ha) natural area located across from 

Cedar River just east of DAEC, which includes the 240-ac (97 ha) Wickiup Hill Outdoor Learning 

Area and a 10,000-square foot (930 square meters) learning center (LCCD, 2007). Cedar 

Rapids offers many attractions that draw visitors from surrounding areas, including the annual 

Cedar Rapids Freedom Festival which is typically a 16-day event (Cedar Rapids, 2007). 

2.1.1 Reactor and Containment Systems 

DAEC is the only nuclear reactor in the State of Iowa (FPL-DA, 2007a). The nuclear reactor is a 

single General Electric (GE) boiling water reactor (BWR) of the standard BWR-4 design, with a 

generating capacity of 610 gross megawatts-electric (MWe). Two mechanical draft cooling 

towers are used, drawing water from the Cedar River (Figure 2-2). Water used in the reactor 

and most other plant systems is piped in from the site’s well water supply (FPL-DA, 2007a). 

Other site structures include an administration building, control building, turbine building, 

radwaste building, low-level radwaste processing and storage building, pump house, intake 

structure, and off-gas stack. The independent spent fuel storage installation (ISFSI) is located 

on the northern part of the site’s property (Figure 2-3). 

Conceptually, a BWR design is not difficult to understand. A BWR uses water, which acts as a 

coolant and neutron moderator (Figure 2-5). A neutron moderator is a substance (e.g., light 

water) that slows the speed of neutrons allowing them to strike uranium-235 atoms contained 

within the reactor vessel. As the uranium-235 atoms are struck by the neutrons, they fission, or 

split apart (Figure 2-6). When uranium atoms fission, they produce energy. This energy causes 

the cooling water to boil, producing steam. The steam is directed to a turbine, causing it to spin. 

The spinning turbine is connected to a generator, which generates electricity. This electricity is 

transmitted along electrical transmission lines to power homes, offices, businesses, and 

industries. The steam is directed to a condenser where it cools and converts back to liquid 

water. This cool water is cycled back to the reactor core, completing the loop. 
Affected Environment 

NUREG-1437, Supplement 42 2-6 October 2010 

Figure 2-5. Simplified Design of a Boiling Water Reactor 

(http://www.nrc.gov/reading-rm/basic-ref/students/animated-bwr.html)

Figure 2-6. The Process of Nuclear Fission. This figure illustrates how a slow neutron 

collides with a uranium-235 atom (target nucleus). This collision causes the uranium-235 atom 

to split into two or more lighter atoms (fission products). This collision also releases other 

neutrons that go on to strike more uranium-235 atoms, producing a sustaining nuclear chain 

reaction. As the uranium-235 atom splits, it releases energy. 

(http://www.cfo.doe.gov/me70/manhattan/images/FissionChainReaction.gif)

 As indicated earlier, DAEC is a single unit plant with a BWR that uses a BWR-4 reactor design 

and a Mark I primary containment design. The nuclear steam supply system and the 

turbine-generator were supplied by GE. The balance of the plant was designed and constructed 

by Bechtel Power Corporation (BPC) as the architect-engineer and construction contractor. The 

primary containment for the unit consists of a drywell, a steel structure that encloses the reactor 

vessel and related piping; a pressure suppression chamber containing a large volume of water; 

and a vent system that connects the drywell to the suppression chamber. The concrete reactor 

building, which houses the primary containment, serves as a radiation shield and fulfills a 

secondary containment function (FPL-DA, 2008a). 

The reactor is fueled using slightly enriched (less than 5 weight percent) uranium dioxide pellets 

sealed in Zircoly-2 tubes with an average batch burnup between 33,000 and 60,000 megawatt 
Affected Environment 

October 2010 2-7 NUREG-1437, Supplement 42 

days per metric ton uranium. DAEC was originally licensed for a thermal output of 

1,658 megawatts-thermal (MWt) and a gross electrical output of 541 MWe. In 2001, the plant 

received a license amendment that increased the thermal output to 1,912 MWt. The generating 

capacity for the plant increased to about 610 gross MWe power. 

DAEC-generated radioactive waste is addressed in Section 2.1.2. Section 2.1.2.4 describes 

DAEC nonradioactive waste streams. 

2.1.2 Radioactive Waste Management 

The DAEC facility includes a radioactive waste system, which collects, treats, and provides for 

disposal of radioactive and potentially radioactive wastes that are byproducts of plant 

operations. Byproducts are activation products resulting from the irradiation of reactor water 

and impurities therein (principally metallic corrosion products) and fission products resulting 

from defective fuel cladding or uranium contamination within the reactor coolant system. 

Radioactive waste system operating procedures ensure that radioactive wastes are safely 

processed and discharged from the plant within the limits set forth in the Part 20, “Standards for 

Protection against Radiation,” of Title 10 of the Code of Federal Regulations (10 CFR Part 20) 

and 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.” 

DAEC produces radioactive wastes in the form of liquid, gaseous, or solid waste streams. 

Radioactive liquid wastes are generated from liquids received directly from portions of the 

reactor coolant system or contaminated by contact with liquids from the reactor coolant system. 

Radioactive gaseous wastes are generated from gases or airborne particulates vented from 

reactor and turbine equipment containing radioactive material. Solid radioactive wastes are 

solids from the reactor coolant system, solids that contacted reactor coolant system liquids or 

gases, or solids used in the reactor coolant system or the power conversion system. 

When reactor fuel has been exhausted, a certain percentage of its fissile uranium content is 

referred to as spent fuel. Spent fuel assemblies are removed from the reactor core and 

replaced with fresh fuel assemblies during routine refueling outages, typically every 24 months. 

Spent fuel assemblies are stored in the spent fuel pool. In addition to the spent fuel pool, spent 

nuclear fuel is stored in dry casks, located in a secure area onsite (FPL-DA, 2008a). 

2.1.2.1 Radioactive Liquid Waste 

A liquid radioactive waste system consists of subsystems that allow liquid wastes from various 

sources to be segregated and processed separately. Radioactive liquids are recycled within the 

plant to the extent practicable. Although allowed by U.S. Nuclear Regulatory Commission 

(NRC) regulations, DAEC has not made a batch release of liquid radioactive waste into the 

Cedar River since 1985. To the extent practical, liquid waste is purified and recycled. If this is 

not feasible, the liquid is evaporated and the sludge is solidified. 

Cross connections between the subsystems provide flexibility to process the wastes by 

alternative methods. Liquid wastes are classified, collected, and treated as high purity, low 

purity, chemical, detergent, sludge, or spent resins. The terms high purity and low purity refer to 

the conductivity and not the radioactivity. The liquid waste system design provides for the 

filtration and demineralization of effluents. Organics in the radioactive liquids may be processed 

by an ultraviolet ozone treatment system (FPL-DA, 2008a). 

DAEC radioactive effluent release reports for 2004 through 2008 for liquid effluents were 

reviewed by the NRC staff (Staff) (FPL-DA, 2005b), (FPL-DA, 2006), (FPL-DA, 2007b), 
Affected Environment 

NUREG-1437, Supplement 42 2-8 October 2010 

(FPL-DA, 2008b), (FPL-DA, 2009a). As reported by the applicant, there were no liquid batch 

discharges into the Cedar River; however, there were small volume liquid discharges from the 

sanitary sewage facility in 2007 and 2008 that contained small amounts of tritium. Tritium in the 

sanitary sewage facility originated from radioactive gaseous effluents discharged from the plant. 

Tritium, in the form of tritiated water vapor, was condensed by building air conditioning units and 

air compressors. Condensation is routed to the sewage treatment facility and the transformer 

pit. This mechanism was validated by the applicant’s radiological environmental monitoring 

program (REMP) (FPL-DA, 2008b), (FPL-DA, 2009a). All samples were within NRC reporting 

standards. 

Based on the liquid waste processing system’s performance from 2004 through 2008, the liquid 

discharges from the sanitary sewage system for 2008 are consistent with the radioactive liquid 

effluents discharged from 2004 through 2007. The applicant is expected to maintain its policy of 

minimizing radioactive liquid effluent during the license renewal term. The quantities of reported 

radioactive liquid wastes are reasonable and no unusual trends were noted. 

2.1.2.2 Radioactive Gaseous Waste 

The facility’s gaseous waste disposal system processes and disposes of radioactive gaseous 

effluents to the atmosphere. Gaseous wastes are processed through a recombiner-charcoal 

delay system to reduce radioactive materials in gaseous effluents before discharge to meet the 

dose limits in 10 CFR Part 20 and the dose design objectives in Appendix I to 10 CFR Part 50. 

Gaseous effluents are released to the atmosphere from the plant’s off-gas stack. Gaseous 

effluents are continuously monitored and the discharges are terminated if the effluents exceed 

pre-set radioactivity levels (FPL-DA, 2008a). 

Radioactive effluent release reports for 2004 through 2008 for gaseous effluents were reviewed 

by the Staff (FPL-DA, 2005b), (FPL-DA, 2006), (FPL-DA, 2007b), (FPL-DA, 2008b), (FPL-DA, 

2009a). Based on the gaseous waste processing system’s performance from 2004 through 

2008, the gaseous discharges for 2008 are consistent with the effluents discharged from 2004 

through 2007. Variations on the amount of radioactive effluents released from year to year are 

expected based on the overall performance of the plant and the number and scope of outages 

and maintenance activities. The radioactive gaseous wastes reported by DAEC are reasonable 

and no unusual trends were noted. 

2.1.2.3 Radioactive Solid Waste 

The radioactive solid waste system processes wet and dry solid wastes. The wet solid wastes 

are composed of spent demineralizer resins and filter sludge that are byproducts of plant water 

treatment processes. The dry solid wastes consist of air filters, contaminated clothing, and used 

reactor equipment generated from operation and maintenance activities (FPL-DA, 2008a). 

Because of differences in radioactivity or contamination levels of the many wastes, various 

methods are employed for processing and packaging. The disposition of a particular item of 

waste is determined by its radiation level, type, presence of hazardous material, and the 

availability of disposal space. Compressible material is compacted into either 55-gallon drums 

by a hydraulic press or metal containers by a box trash compactor. 

DAEC also generates and temporarily stores small quantities of low-level mixed waste (LLMW), 

which is waste that exhibits hazardous characteristics and contains low levels of radioactivity. 

The mixed waste is stored in the low-level radwaste processing and storage facility per DAEC’s 

treatment storage and disposal permit. When sufficient quantities are amassed, the material is 
Affected Environment 

October 2010 2-9 NUREG-1437, Supplement 42 

sent to a licensed processor who separates the hazardous material from the radioactive 

material. The hazardous material is sent to a waste processor for disposition while the 

radioactive component is sent for offsite burial at a licensed disposal facility (FPL-DA, 2008a). 

The State of South Carolina’s licensed low-level radioactive waste (LLW) disposal facility, 

located in Barnwell, has limited the access from radioactive waste generators located in States 

that are not part of the Atlantic Low-Level Waste Compact. Iowa is not a member of the Atlantic 

Low-Level Waste Compact. This has had a negligible effect on DAEC’s ability to handle its 

LLW. Radioactive wastes are shipped to offsite facilities for treatment, disposal, or both. In the 

past, DAEC has shipped waste to facilities in Pennsylvania and Tennessee for treatment prior to 

disposal at a permitted radioactive waste landfill in South Carolina or Utah. DAEC primarily 

uses the Utah facility for disposal. Shipments have been made in accordance with Department 

of Transportation (DOT) requirements by truck and by rail. 

DAEC LLW reports for 2004 through 2008 were reviewed by the Staff (FPL-DA, 2005b), 

(FPL-DA, 2006), (FPL-DA, 2007b), (FPL-DA, 2008b), (FPL-DA, 2009a). The solid waste 

volumes and radioactivity amounts generated in 2008 are typical of previous annual waste 

shipments. Variations in the amount of solid radioactive waste generated and shipped from 

year to year are expected based on the overall performance of the plant and the number and 

scope of outages and maintenance activities. The volume and activity of solid radioactive 

wastes reported by DAEC are reasonable and no unusual trends were noted. 

No plant refurbishment activities were identified by the applicant as necessary for the continued 

operation of DAEC through the license renewal term. Routine plant operational and 

maintenance activities currently performed will continue during the license renewal term. Based 

on past performance of the radioactive waste system, and the lack of any planned 

refurbishment activities, similar amounts of radioactive solid waste are expected to be 

generated during the license renewal term. 

2.1.2.4 Nonradioactive Hazardous Waste Streams 

The Resources Conservation and Recovery Act (RCRA) governs the disposal of solid and 

hazardous waste. RCRA regulations are contained in Title 40, Protection of the Environment, 

Parts 239 through 299 (40 CFR Part 239, et seq.). Parts 239 through 259 of these regulations 

cover solid (nonhazardous) waste, and Parts 260 through 279 regulate hazardous waste. 

RCRA Subtitle C establishes a system for controlling hazardous waste from “cradle to grave,” 

and RCRA Subtitle D encourages States to develop comprehensive plans to manage 

nonhazardous solid waste and mandates minimum technological standards for municipal solid 

waste landfills. 

Solid waste, defined by the RCRA, is generated by the facility as part of routine plant 

maintenance, cleaning activities, and plant operations. Iowa is a part of the Environmental 

Protection Agency (EPA) Region VII. The EPA authorized the State of Iowa to regulate and 

oversee most of the solid waste disposal programs, as recognized by Subtitle D of the RCRA. 

Compliance is assured through State-issued permits. The State of Iowa and local governments 

are the primary planning, permitting, regulating, implementing, and enforcement agencies for 

management and disposal of household and industrial or commercial nonhazardous solid 

wastes in the State. Some of the Federal waste regulations are incorporated by the Iowa 

Administrative Code (IAC) (IAC 567, Ch.100–121). 

The EPA classifies certain nonradioactive wastes as “hazardous” based on characteristics 

including ignitability, corrosivity, reactivity, or toxicity (identification and listing of hazardous 
Affected Environment 

NUREG-1437, Supplement 42 2-10 October 2010 

waste is available in 40 CFR Part 261). State-level regulators may add wastes to the EPA’s list 

of hazardous wastes. The RCRA provides standards for the treatment, storage, and disposal of 

hazardous waste for hazardous waste generators (40 CFR Part 262). The EPA recognizes 

three main types of hazardous waste generators (40 CFR 260.10) based on the quantity of the 

hazardous waste produced: 

● Large quantity generators (LQGs) that generate 2,200 pounds (lbs) 

(1,000 kilograms (kg)) per month or more of hazardous waste, more than 2.2 lbs 

(1 kg) per month of acutely hazardous waste, or more than 220 lbs (100 kg) per 

month of acute spill residue or soil. 

● Small quantity generators (SQGs) that generate more than 220 lbs (100 kg), but 

less than 2,200 lbs (1,000 kg), of hazardous waste per month. 

● Conditionally exempt small quantity generators (CESQGs) which generate 

220 lbs (100 kg) or less per month of hazardous waste, or 2.2 lbs (1 kg) or less 

per month of acutely hazardous waste, or less than 220 lbs (100 kg) per month 

of acute spill residue or soil. 

DAEC is an SQG of non-acute hazardous waste. 

Under the Emergency Planning and Community Right-to-Know Act (EPCRA), applicable 

facilities are required to provide information on hazardous and toxic chemicals to local 

emergency planning authorities and the EPA (Title 42, Section 11001, of the United States 

Code (U.S.C.) (42 U.S.C. 11001)). On October 17, 2008, the EPA finalized several changes to 

the Emergency Planning (Section 302), Emergency Release Notification (Section 304), and 

Hazardous Chemical Reporting (Sections 311 and 312) regulations that were proposed on 

June 8, 1998 (63 Federal Register (FR) 31268). DAEC is subject to Federal EPCRA reporting 

requirements and thus submits an annual Section 312 (TIER II) report on hazardous substances 

to local emergency agencies. 

The facility generates small amounts of hazardous wastes including spent and expired 

chemicals, laboratory chemical wastes, and occasional project-specific wastes. Used oil, 

produced during operation of DAEC, is sent offsite to the EPA-approved hazardous waste 

disposal facility (FPL-DA, 2008a). The EPA classifies several hazardous wastes as universal 

wastes; these include batteries, pesticides, mercury-containing items, and fluorescent lamps. In 

the State of Iowa, EPA Region VII administers Federal universal waste regulations 

(EPA, 2009a). 

Biocide and chemical wastes are generated during normal operating processes at DAEC that 

control the pH of the coolant, control scale and erosion in the cooling system, and clean and 

mechanically remove biofouling microorganisms from water circulation piping. DAEC employs a 

closed-cycle heat dissipation system with cooling towers. Blowdown water, containing biocides 

such as sodium bromide, is discharged into the Cedar River at Outfall 001. No bromine or other 

biocides are discharged from Outfall 002 (sanitary wastewater discharge). The use of chlorine 

and other biocides in the water circulating system and cooling water system is stipulated in 

DAEC National Pollutant Discharge Elimination System (NPDES) permit No. 5700104, issued 

by the Iowa Department of Natural Resources (IDNR) (IDNR, 2003), (IDNR, 2004a). 
Affected Environment 

October 2010 2-11 NUREG-1437, Supplement 42 

2.1.2.5 Pollution Prevention and Waste Minimization 

In 2008, Florida Power and Light Energy Duane Arnold, LLC (FPL-DA) initiated a recycling 

program at DAEC that focuses on pollution prevention, waste minimization, and education of 

personnel. As a result of the DAEC recycling efforts, 14 tons (12.7 metric tons) of office paper, 

6 tons (5.4 metric tons) of cardboard, 5,000 lbs (2.27 metric tons) of batteries, 6,800 lbs 

(3.08 metric tons) of electronic waste were recycled in the first 4 months of the implemented 

program. 

To promote nonradiological waste minimization efforts, the EPA’s Office of Pollution Prevention 

and Toxics has established a clearinghouse that provides information regarding waste 

management and technical and operational approaches to pollution prevention (EPA, 2009b). 

The EPA’s clearinghouse can be used as a source for additional opportunities for waste 

minimization and pollution prevention at DAEC, as appropriate. 

Additionally, the EPA encourages the use of environmental management systems (EMSs) for 

organizations to assess and manage the environmental impact associated with their activities, 

products, and services in an efficient and cost-effective manner. The EPA defines an EMS as 

“a set of processes and practices that enable an organization to reduce its environmental impact 

and increase its operating efficiency.” EMSs help organizations fully integrate a wide range of 

environmental initiatives, establish environmental goals, and create a continuous monitoring 

process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 

of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and 

pollution prevention (EPA, 2009c). FPL-DA is taking the initial steps in adopting an International 

Organization for Standardization (ISO) 14001 EMS at the DAEC site. 

2.1.3 Facility Operation and Maintenance 

Various types of maintenance activities are performed at DAEC, including inspection, testing, 

and surveillance to maintain the current licensing basis of the facility and to ensure compliance 

with environmental and safety requirements. Various programs and activities currently exist at 

DAEC to maintain, inspect, test, and monitor the performance of facility equipment. These 

maintenance activities include inspection requirements for reactor vessel materials, boiler and 

pressure vessel in-service inspection and testing, a maintenance structures monitoring program, 

and maintenance of water chemistry. 

Other programs include those implemented in response to NRC generic communications, those 

implemented to meet technical specification surveillance requirements, and various periodic 

maintenance, testing, and inspection procedures. Certain program activities are performed 

during the operation of the unit, while others are performed during scheduled refueling outages. 

Nuclear power plants must periodically discontinue the production of electricity for refueling, 

periodic in-service inspection, and scheduled maintenance. 

2.1.4 Power Transmission System 

Six transmission lines connect DAEC to the regional electric grid, all of which are owned and 

maintained by ITC Midwest LLC (ITC). Unless otherwise noted, the discussion of the power 

transmission system is adapted from the environmental report (ER) (FPL-DA, 2008a) or 

information gathered at NRC’s environmental site audit. 

Two 345-kilovolt (kV) lines connect to an existing 345-kV line, and three 161-kV lines deliver 

power to three substations (i.e., Washburn, Bertram, and Hiawatha). One additional 161-kV line 
Affected Environment 

NUREG-1437, Supplement 42 2-12 October 2010 

connects to the Sixth Street Generating Station substation; the additional 161-kV line is not 

described in the final environmental statement (FES) related to the operation of DAEC (AEC, 

1973) because it was constructed in 1978, after publication of the FES. The transmission lines 

cross through Linn, Benton, and Black Hawk counties, Iowa. In total, the transmission lines 

associated with the operation of DAEC comprise approximately 1,370 ac (554 ha) and span 

101 mi (163 km) of transmission line rights-of-way (ROWs). Generally, the transmission line 

ROWs pass through regions of agriculture and forested land. 

Transmission lines considered in-scope for license renewal are those constructed specifically to 

connect the facility to the transmission system (10 CFR 51.53(c)(3)(ii)(H)); therefore, the Hills, 

Hazelton, Washburn, Bertram, Hiawatha, and Sixth Street lines are considered in-scope for this 

supplemental environmental impact statement (SEIS) and are discussed in detail below. 

Figure 2-7 contains a map of the DAEC transmission system. The six transmission lines are as 

follows (see Table 2-1): 

● Hills Line: This 345-kV line extends west for 2.7 mi (4.3 km), at which point it 

turns south, eventually connecting with the Hills substation. This line shares a 

665-ft (203-m) wide ROW with the Hazelton, Washburn, and the Bertram lines 

for approximately 0.34 mi (0.55 km), at which point the Bertram line splits off. 

For the remainder of its length, the line shares a 500-ft (153-m) wide ROW with 

the Hazelton and the Washburn lines. This line is contained within Linn County. 

● Hazelton Line: This 345-kV line extends west for 2.7 mi (4.3 km) parallel to the 

Hills line and also connects to the Hazelton substation feed. This line shares a 

665-ft (203-m) wide ROW with the Hills, Washburn, and the Bertram lines for 

approximately 0.34 mi (0.55 km), at which point the Bertram line splits off. For 

the remainder of its length, the line shares a 500-ft (153-m) wide ROW with the 

Hills and the Washburn lines. This line is contained within Linn County. 

● Washburn Line: This 161-kV line extends west for 16 mi (26 km) to the Garrison 

substation and then an additional 30 mi (48 km) to the Washburn substation. 

This line shares a 500- to 665-ft (152- to 203-m) ROW with the Hills and 

Hazelton lines, as described above, and the remainder of the ROW ranges from 

60 to 120 ft (18 to 37 m) wide. This line spans Linn, Benton, and Black Hawk 

counties. 

● Bertram Line: This 161-kV line extends west for 0.34 mi (0.55 km) and then 

continues southeast for a total distance of 28 mi (45 km) to the Bertram 

substation. This line shares a 665-ft (203-m) wide ROW, as described above, 

and then has a 100-ft (30-m) wide ROW for the remainder of the line. This line 

is contained within Linn County. 

● Hiawatha Line: This 161-kV line extends east for 8 mi (13 km) to the Hiawatha 

substation. This line’s ROW varies from 60 to 120 ft (18 to 37 m) in width. The 

line crosses the Cedar River and is contained within Linn County. 

● Sixth Street Line: This 161-kV line extends southwest around the city of Palo 

and then continues southeast following a railroad corridor to the center of the 

city of Cedar Rapids. The total length of this line is 16 mi (26 km), and its ROW 
Affected Environment 

October 2010 2-13 NUREG-1437, Supplement 42 

varies from 60 to 120 ft (18 to 37 m) in width. This line is contained within Linn 

County. 

Figure 2-7. Duane Arnold Energy Center Transmission Line System 

(Source: FPL-DA, 2008a, Figure 3.1-1) 
Affected Environment 

NUREG-1437, Supplement 42 2-14 October 2010 

In addition to these six transmission lines, two substations were constructed for the operation of 

DAEC; the DAEC substation, located about 0.25 mi (0.4 km) west of the plant, and the 

Hiawatha substation, located approximately 8 mi (13 km) east of the plant. 

ITC employs an integrated vegetative management program, which utilizes a combination of 

manual, mechanical, biological, and chemical control techniques and is directed by certified 

foresters and planners. ITC conducts biannual aerial inspections of transmission lines to 

identify areas that require maintenance. A followup ground inspection is completed for any 

areas that have been marked as requiring maintenance, and a complete span-by-span 

inspection is completed once every 3 years. ITC maintains a 26-ft (8-m) clearance for 230-kV 

lines and a 30-ft (9-m) clearance for 345-kV lines on either side of the lines. The majority of the 

in-scope transmission lines traverse agricultural land. Those areas that are not already 

cultivated or developed in some other way are maintained to promote herbaceous vegetation, 

which includes shrubs, bushes, and other low-growing groundcover. The EPA-approved 

herbicides may be used to prevent regrowth from tree stumps and to control incompatible 

woody vegetation. A minimum of a 50-ft (15-m) buffer is maintained in areas near streams and 

wetlands. ITC maintains a database that includes known threatened and endangered species 

locations, raptor nests, and natural heritage areas to ensure that workers are aware of areas for 

which special consideration is required. 

All transmission lines were designed and built in accordance with industry standards in place at 

the time of construction. All transmission lines will remain a permanent part of the transmission 

system and will be maintained by ITC regardless of DAEC continued operation (FPL-DA, 

2008a); however, the Hazelton and Hills lines, which tie into the Hills substation feed, would be 

deactivated if the DAEC switchyard were no longer in use and would need to be reconnected to 

the grid if they were to remain in service beyond the operation of DAEC. 

Table 2-1. Duane Arnold Energy Center Transmission Lines. Six transmission lines convey 

electricity from DAEC to the regional electric transmission system via four ROWs. 

Approximate Distance ROW Width(a) Approx. 

ROW Area(b)

Line Owner kV mi (km) ft (m) ac (ha) 

Hills ITC 345 2.7 (4.3) 665 (203) 218 (88) 

Hazelton ITC 345 2.7 4.3) 665 (203) 218 (88) 

Washburn ITC 161 46 (74) 60 to 120 (18 to 37) 502 (203) 

Bertram ITC 161 28 (45) 100 (30) 339 (137) 

Hiawatha ITC 161 8 (13) 60 to 120 (18 to 37) 87 (35) 

Sixth Street ITC 161 16 (26) 60 to 120 (18 to 37) 175 (71) 

(a) ROW widths for the Washburn, Hiawatha, and Sixth Street lines are approximations and vary along the length 

of each line. 

(b) ROW area for the Washburn, Hiawatha, and Sixth Street lines are approximated using 90 ft (27 m) as the 

average ROW width for these lines. 

Source: (FPL-DA, 2008a) 
Affected Environment 

October 2010 2-15 NUREG-1437, Supplement 42 

2.1.5 Cooling and Auxiliary Water Systems 

DAEC uses a closed-cycle heat dissipation system that withdraws water from the Cedar River. 

DAEC employs two cross-flow mechanical-forced draft cooling towers, designed to dissipate 

heat from the plant’s steam cycle to the atmosphere (FPL-DA, 2008a). 

Water that is used to replenish losses (cooling tower evaporation, wind drift, and as blowdown 

returned to the Cedar River) is termed “makeup” water. Makeup water is withdrawn from the 

Cedar River via a reinforced concrete intake structure located on the west bank of the river. 

River water enters parallel pump pits of the intake structure by passing through trash bars, a 

sand control gate, and a traveling screen. During low flow, an overflow barrier located across 

the river intercepts the streambed flow and diverts it to the intake structure, thereby making 

available the entire flow of river water. River water diverted into the intake structure passes 

through bar racks and into two parallel intake channels. 

A gate is provided at the mouth of each intake channel to regulate the quantity of sand traveling 

into the pump pits. An additional gate is located between the two pump pits so that either of the 

two traveling screens may serve either or both pump pits. Water passes from the inlet end of 

each channel, through traveling screens into a separate pump wet pit. Wash water is provided 

by a screen wash pump to release impinged aquatic organisms and debris from the screens. 

The traveling screen operation will stop if the screen wash supply is lost. 

Under normal operation, a maximum of 11,200 gallons per minute (gpm) (25 cubic feet per 

second (cfs) or 0.71 cubic meters per second (m3

/s)) of makeup water is withdrawn from the 

Cedar River. This water circulates through the condenser to dissipate heat and then travels to 

the cooling towers at a rate of 155,000 gpm (345 cfs or 9.78 m3

/s) per tower, or 310,000 gpm 

(691 cfs or 19.6 m3

/s) overall. Of the water transferred to the cooling towers, 8,100 gpm (18 cfs 

or 0.51 m3

/s) is lost as evaporative dissipation and 3,100 gpm (6.9 cfs or 0.20 m3/s) is blowdown 

returned to the Cedar River. Most of the remaining water, approximately 298,800 gpm 

(665.7 cfs or 18.85 m3

/s), is recirculated through the condenser for cooling. 

2.1.6 Facility Water Use and Quality 

DAEC relies on the Cedar River as its source of makeup water for its cooling system, and it 

discharges various waste flows to the river. Onsite well water is used to cool many plant 

systems. 

2.1.6.1 Groundwater Use 

Groundwater at DAEC is present in river alluvium, unconsolidated glacial deposits, and deep 

sedimentary bedrock formations (FPL-DA, 2007c). At the plant site, outside the excavated 

area, the shallow overburden deposits are roughly 20 ft (6 m) thick, comprised of fine to coarse 

sand with some silt and gravel. This is underlain by 12 to 80 ft (3.7 to 24 m) of clayey glacial till 

with lenses of sand and gravel. The uppermost bedrock is the carbonate Wapsipinicon and 

Gower Formations, of middle Devonian and Upper Silurian age, respectively.
Affected Environment 

NUREG-1437, Supplement 42 2-16 October 2010 

The alluvial aquifer is recharged by precipitation and locally by periodic flooding or river 

recharge. Groundwater flows in a southeasterly direction, toward the Cedar River (FPL-DA, 

2007c). Groundwater in the bedrock is under confined (artesian) conditions and also flows 

toward the river. Minor saturated sand and gravel units may be present within the glacial 

deposits. 

Facility production wells are finished in the Wapsipinicon and Gower Formations. During the 

2008 flood, the production wellheads were reported to have stayed above water. 

DAEC provided a list of the closest residences to the power plant (FPL-DA, 2007d). All 16 of 

the residences rely on private well water and range in distance from 0.5 to 2.3 mi (0.8 to 3.7 km) 

from the site. The private wells located west and north of DAEC are hydraulically upgradient of 

the plant (FPL-DA, 2007c). Some of these wells are within about 1 mi of the site boundary. 

Private wells located south-southwest of the plant are cross-gradient to site groundwater. 

The four onsite production wells provide water for multiple purposes. Approximately 100 gpm is 

used for demineralizer makeup, and less than 10 gpm (0.022 cfs or 0.00063 m3

/s) is used for 

potable supply (FPL-DA, 2008a). The largest usage of groundwater, on the order of 1,400 to 

1,500 gpm (3.1 to 3.3 cfs or 0.088 to 0.094 m3

/s), is sent to an air cooling system (FPL-DA, 

2008a), (FPL-DA, undated #1). The wells also provide a backup water source for emergency 

reactor injection, the fire protection systems, and the reactor building closed cooling water heat 

exchangers. 

The wells are named A, B, C, and D and have total depths ranging from 285 to 380 ft (87 to 

116 m) (IDNR, 2005a) (see Figure 2-3). Well B is along the property’s west boundary. Wells A 

and C are in the southwest portion of the property. Well D is approximately 200 ft (61 m) north 

of the cooling towers and was installed in 1980. Wells A, B, and C were originally shallower, but 

were replaced by deeper bedrock wells in 2002, 1992, and 1999, respectively. Wells B and D 

are within their own buildings, while the wellheads for A and C are located outdoors. 

Normally, Wells D and A run continuously, and Wells B and C are used for backup (IDNR, 

2008a). The facility is permitted to pump a maximum annual quantity of 1,575 million gallons 

(5.962 million m3

) from the well system (IDNR, 2005a). Review of annual water use records 

(e.g., FPL-DA, 2009b) for calendar years 2001 to 2008 indicates an annual groundwater use of 

612 to 848 million gallons (2.32 to 3.21 million m3

). 

Water from Well D is chlorinated to allow use in plant systems (heating, ventilation, and air 

conditioning (HVAC), dry well coolers). The IDNR requires well water to meet drinking water 

standards if a chlorination system is used. 

2.1.6.2 Surface Water Use 

The DAEC is located in the Cedar River Basin and is built near the west bank of the Cedar 

River. At the DAEC site, the basin’s drainage area is approximately 6,250 square miles (m2

) 

(16,200 square kilometers (km2

) (FPL-DA, 2007c). The Cedar River is a tributary of the Iowa 

River, 133 mi (214 km) downstream from DAEC, and the combined flow is a tributary feeding 

into the Mississippi River. 

Between 1903 and 2008, flow in the Cedar River at Cedar Rapids, Iowa, varied from a 

7-day minimum of 224 cfs (6.34 m3

/s) in December 1989 to a maximum flow of 140,000 cfs 

(3,960 m3

/s) on June 13, 2008, during intense flooding (USGS, 2008). The average flow at the 
Affected Environment 

October 2010 2-17 NUREG-1437, Supplement 42 

station is 3,878 cfs (109.8 m3

/s). Statistics for the station are presented in Table 2-2. Average 

flows are lowest in the winter and highest in the spring and early summer. 

Table 2-2. Monthly Flow Rates between 1903 and 2008 (Source: USGS, 2008) 

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 

Mean 

flow 

(cfs) 2,445 2,427 1,870 1,607 2,477 6,609 7,090 5,649 6,379 4,424 3,065 2,455 

Mean 

flow 

(m3

/s) 69 69 53 46 70 187 201 160 181 125 87 70 

 

Max 

flow 

(cfs) 12,100 9,327 8,675 8,529 12,230 17,420 35,320 24,500 46,450 33,910 28,700 13,990 

Max 

flow 

(m3

/s) 343 264 246 242 346 493 1000 694 1315 960 813 396 

Water 

Year 2008 1973 1983 1973 1984 1929 1993 1991 2008 1993 1993 1993 

 

Min 

flow 

(cfs) 463 410 290 299 304 664 1,045 527 350 533 377 466 

Min 

flow 

(m3

/s) 13 12 8 8 9 19 30 15 10 15 11 13 

Water 

Year 1990 1990 1990 1911 1940 1934 1957 1934 1934 1989 1934 1934 

As described in Section 2.1.6, the Cedar River is the water source for the DAEC circulating 

water and service water systems. The intake at the river water supply system provides makeup 

water to the circulating water system to offset the evaporation and blowdown losses at the 

cooling towers. This reinforced concrete intake also serves as intake for the residual heat 

removal service water and the emergency service water. The intake is located on the west 

bank of the river; a series of wing dams on the east bank divert the flow toward the intake side. 

A permitted submerged dam was constructed across the Cedar River to maintain water depth 

near the intake (Iowa Natural Resources Council, 1971). 

The maximum river water requirements are 8,100 gpm (0.51 m3

/s) for evaporative losses and 

drift from the cooling towers and 3,100 gpm (0.20 m3

/s) for blowdown, for a total withdrawal rate 

of 11,200 gpm (0.71 m3

/s) (FPL-DA, 2007c). The facility is permitted to withdraw a maximum of 

12,575 million gallons (47,602,000 m3

) per year from the Cedar River (IDNR, 2005a). 

As part of DAEC construction, a reservoir was created about 2 mi (3 km) northwest of the power 

plant, in a tributary to the Cedar River. The purpose of the 410-ac (166-ha) Pleasant Creek 

Recreational Reservoir is to supply water to the Cedar River during low-flow conditions. DAEC 

may withdraw up to 16,000 acre-feet/year (19,700,000 m3

/yr) from the Cedar River to replenish 

the Pleasant Creek Reservoir (IDNR, 2005a). The IDNR (2005a) allows withdrawal of river 

water when flow in the Cedar River is greater than 937 cfs (26.5 m3

/s) as measured at a gage in 

Cedar Rapids. From April 1 to September 30, withdrawal is allowed if flow in Cedar Rapids is 
Affected Environment 

NUREG-1437, Supplement 42 2-18 October 2010 

between 500 and 937 cfs (14.1 and 26.5 m3

/s), and only if flow is increasing on a 24-hour basis. 

From October 1 to March 31, withdrawal is allowed if flow is greater than 500 cfs (14.1 m3

/s). 

IDNR (2005a) allows DAEC to discharge water from the reservoir for low-flow augmentation at a 

rate equal to the DAEC consumptive use. 

2.2 AFFECTED ENVIRONMENT 

This section provides general descriptions of the environment near DAEC as background 

information and to support the analysis of potential environmental impacts in Chapter 4. 

2.2.1 Land Use 

As indicated earlier, DAEC is located on approximately 500 ac (200 ha) of land, 8 mi (13 km) 

northwest of Cedar Rapids, Iowa, on the west bank of the Cedar River. The site is 

approximately 2.5 mi (4 km) north-northeast of Palo, Iowa, in Linn County (AEC, 1973). The 

general topographical features in this portion of the Cedar River are broad valleys with relatively 

narrow flood plains. Across the river from the site, the land rises to an elevation of about 900 ft 

(275 m), and is heavily wooded with sporadic fields or pastures. Away from the immediate 

vicinity of the river, to the south and west of the site, the land is relatively flat agricultural land, 

while to the northwest of the site, the land rises and tends to be sparsely wooded farmland. 

Only a small portion of the site, consisting of a relatively flat plain approximately 750 ft (230 m) 

above msl, is used by the power plant itself, with the remaining land leased for agricultural use 

(FPL-DA, 2008a). Power plant buildings include the turbine-generator building, control building, 

reactor building, administration building, pump house, and low-level radioactive waste building, 

which are co-located to form the main plant complex (see Section 2.1). A switchyard, 

substation, and a large parking lot are located to the west of the main complex. A discharge 

canal runs from the cooling tower area to the river, where intake and pump house facilities are 

located. A small sanitary sewage treatment facility is located north of the complex, and an 

off-gas stack is located to the south. 

The Pleasant Creek State Recreation Area, a 1,927-ac (780-ha) park, is located 1 mi northwest 

of the site. The park includes a 410-ac (165-ha) lake, jointly developed by the Iowa 

Conservation Commission and the Iowa Electric Light and Power Company to provide both a 

supplemental water supply for DAEC and provide regional recreation opportunities (FPL-DA, 

2008a). Recreational activities in the vicinity of the site include boating, fishing, hunting, 

camping, hiking, picnicking, and swimming. Palo Marsh Wildlife Refuge, located 2 mi south of 

DAEC, is a 144-ac (58-ha) site featuring a wetland trail and bottomland forest for wildlife 

observation. Wickiup Hill, located across the Cedar River to the east of the site, is a 563-ac 

(228-ha) natural area and includes the 240-ac (100-ha) Wickiup Hill Outdoor Learning Area and 

10,000-square foot (930-m2

) Learning Center (FPL-DA, 2008a). 

2.2.2 Air and Meteorology 

The closest National Weather Service (NWS) station is located in nearby Cedar Rapids, Iowa 

(IDNR, 2008b). 

All of Iowa is in a humid, continental climate zone characterized by hot humid summers, cold, 

relatively dry winters, and wet springs. The Iowa Annual Weather Summary for 2008, issued by 

the Iowa State Climatologist, includes the following data which are representative of some of the 

weather extremes that are possible in Iowa (IDNR, 2009a). Temperatures averaged 45.8°F 
Affected Environment 

October 2010 2-19 NUREG-1437, Supplement 42 

(7.67°C), which is about 2 degrees below normal. Precipitation totaled 43.79 inches 

(111 centimeters (cm)), which is about 9.71 inches (24.67 cm) above normal, making 2008 the 

11th coolest and 4th wettest year among 136 years of State weather records. The Statewide 

average rainfall of 9.03 inches (22.93 cm) over the period May 29th to June 12th resulted in 

widespread flooding over the southeastern two-thirds of Iowa with record flooding down the 

length of the Cedar River and along portions of the Des Moines, Iowa, and Mississippi Rivers. 

Cedar Rapids was the hardest hit with a June 13 flood crest 11 ft (3.35 m) higher than the 

previous record; however, despite record flooding and temporary flooding of site access roads, 

operations at the DAEC were unaffected. 

The State’s first F5 tornado since 1976 occurred on May 26, 2008.1

 The NWS reported a total 

of 105 tornadoes in the State in 2008, tying 2001 as the second highest annual total behind the 

120 tornadoes that occurred in 2004.2

 Overall, there were 13 fatalities in Iowa in 2008 due to 

tornadoes (Iowa State Climatologist, 2009). 

Queries of the National Climate Data Center database resulted in the following additional 

climate facts: over the period January 1, 1983, to December 31, 2008, Linn County, Iowa 

experienced 61 flood events; 14 funnel cloud sightings; 29 tornadoes ranging in intensity from 

F0 to F4, inflicting property damage as high as $25 million; 235 thunderstorm and high wind 

events; and no wild fire or forest fire events (NOAA, 2009b), (NOAA, 2009c), (NOAA, 2009d), 

(NOAA, 2009e), (NOAA, 2009f). 

2.2.2.1 Air Quality 

Linn County is in the Northeast Iowa Intrastate Air Quality Control Region (AQCR) 

(40 CFR 81.256). The IDNR Air Quality Bureau has primary responsibility for regulating air 

emission sources within the State of Iowa and, with the assistance from EPA Region VII and the 

local programs in Polk and Linn counties, developing a monitoring plan for the State. IDNR’s 

closest ambient air monitoring station to DAEC is located in Cedar Rapids, approximately 8 mi 

(13 km) southeast from DAEC. Three new monitors (particulate matter at the 2.5 micrometer 

range (PM2.5) standard, sulfur dioxide (SO2), and carbon monoxide (CO)) were added in 2008 to 

the Cedar Rapids monitoring site in Linn County (IDNR, 2009a). 

The Clean Air Act (CAA) of 1970 established National Ambient Air Quality Standards (NAAQS). 

The NAAQS identify six “criteria” pollutants—SO2, nitrogen oxides (NOx), CO, ozone (O3), 

particulate matter at the 10 micrometer range (PM10), particulate matter at the 2.5 micrometer 

range (PM2.5), and lead (Pb) (40 CFR Part 50). Collectively, the criteria pollutants provide a 

gauge of ambient air quality. The primary standards are referred to as “health effects 

standards.” These standards are set at levels to protect the health of the most sensitive 

individuals in the population. All of Iowa, including Linn County, is currently in attainment for all 

NAAQS (40 CFR 81.316). Linn County continues to be in attainment. 

 

1 The Fujita six-point scale (F0 to F5) is used to rate the intensity of a tornado based on the damage it inflicts to 

structures and vegetation. The lowest intensity is F0, the highest is F5. Fujita scale categories are based on 

estimated (not measured) sustained wind speeds compared against observed structural damage. The Enhanced 

Fujita Scale replaced the original Fujita Scale in February 2007. The Enhanced Fujita Scale still uses six categories 

of tornado intensity (EF0 to EF5) but defines those categories differently (NOAA, 2009a). Overall, most tornadoes 

(around 77 percent) in the United States are EF0 or EF1 and about 95 percent are below EF3 intensity. 

Approximately 0.1 percent of all tornadoes reach EF5 status with sustained winds in excess of 200 miles per hour 

(mph) (NOAA, 2008). For additional information about the Fujita Scales, see the NOAA Web site and its hypertext 

links at: http://www.spc.noaa.gov/efscale/. 2 The annual average number of tornadoes in Iowa (since Doppler Radar was installed at NWS) is 56. The annual 

average for the United States is 1,200 (NOAA, 2009a). 
Affected Environment 

NUREG-1437, Supplement 42 2-20 October 2010 

Under the Title V permit program, DAEC qualifies as a minor source4 and is, therefore, not 

required to obtain a Title V permit; however, eight stationary pollutant sources on DAEC operate 

under the auspices of permits issued by the Linn County Health Department (four emergency 

generators, one auxiliary boiler, one sulphuric acid tank, and two diesel fuel underground 

storage tanks). These permits establish limits for operation and require annual reports to the 

county. 

Sections 101(b)(1), 110, 169(a)(2), and 301(a) of the CAA as amended (42 U.S.C. 7410, 

7491(a)(2), 7601(a)) established 156 mandatory Class I Federal areas where visibility is an 

important value that cannot be compromised. There are no mandatory Class I Federal areas in 

the State of Iowa or within 62 mi (100 km) of DAEC. The closest Class I areas are the 

Boundary Waters National Wilderness Area and Voyageurs National Park in Minnesota, 

Badlands National Wilderness Area in North Dakota, and Hercules-Glades National Wilderness 

Area and Mingo National Wilderness Area in Missouri.5 Given the distances involved and the 

nature of the stationary air pollutant sources at DAEC, no adverse impacts on Class I areas are 

anticipated from continued DAEC operation. 

The primary meteorological tower is located approximately 1,700 ft (5,600 m) south-southeast of 

the reactor building and 1,125 ft (3,700 m2

) southeast of the off-gas stack (FPL-DA 2008a). 

These towers are constructed and located in locations that suggest that no significant 

interferences to air flow (e.g., building wakes, etc.) exist, which would compromise the quality of 

recovered meteorological data. Meteorological instruments are calibrated semiannually and are 

also subjected to routine inspection and maintenance. 

DAEC has committed to installing a new meteorological tower and replacing all meteorological 

instruments by the summer of 2010. DAEC will use the occasion of instrument replacement to 

completely revise all procedures (including training) for meteorological data retrieval, evaluation, 

management, and application. 

2.2.3 Groundwater Resources 

Installation of the current set of 12 monitoring wells began in 2006 (FPL-DA, 2007d). The wells 

are located in six nests (1 through 6), with an A and a B well at each location. The A series 

wells are about 14–30 ft (4.3–9.1 m) deep, while the B series wells are about 40–60+ ft (12.2–

18.3+ m) deep. 

Annual REMP reports document regular samplings of groundwater; reports for the years 2006 

through 2008 (FPL-DA, 2007e), (FPL-DA, 2008c), (FPL-DA, 2009c) (FPL-DA, 2010) were 

reviewed because they contain not only the results from upgradient offsite private wells and 

onsite water sources, but also from the new network of onsite monitoring wells. Results from 

the site water system and three upgradient private wells during 2006–2008 yielded a maximum 

gross beta of 8.6±2.2 picocuries per liter (pCi/L). The drinking water standard for gross beta is 4 

milliroentgen equivalent man per year (mrem/yr) (EPA, 2010), (IDNR, 2010), or a screening 

level of 50 pCi/L (UI, 1990). The water quality standard for tritium is 20,000 pCi/L (IDNR, 2010). 

The tritium results were all less than 193 pCi/L. No trends were apparent in the offsite gross 

 

4 Under the Title V Operating Permit program, the EPA defines a Major Source as a stationary source with the 

potential to emit (PTE) any criteria pollutant at a rate greater than 100 tons/year, or any single hazardous air pollutant 

(HAP) at a rate of greater 10 tons/year or a combination of HAPs at a rate greater than 25 tons/year (Title V of the 

1990 Federal Clean Air Act Amendments).

5

 A complete listing of all Class I areas can be found at 40 CFR 81, Subpart D. 
Affected Environment 

October 2010 2-21 NUREG-1437, Supplement 42 

beta or tritium data. Quarterly sampling of site monitoring wells began midway through 2006 at 

three well nests, with sampling at all six nests beginning in 2007. The maximum gross beta 

observed in the available 2006–2007 data was 17.7 ± 1.3 pCi/L in MW-06A. No trend was 

apparent at this or other monitoring wells. In the 11 other wells, the maximum gross beta was 

9.5 ± 2.2 pCi/L, with no apparent trends. Tritium was consistently highest at MW-01A, with 

measurements of less than 157 to 644 ± 114 pCi/L and a downward trend. Measurements at 

the other wells were generally below the detection limit, with a maximum reading of 433 ± 109 

pCi/L at the MW-06A well in the final quarter of available data. 

In 2009 twelve on-site monitoring wells (six shallow and six intermediate depth) were sampled 

and analyzed for gross beta and tritium. The annual mean for gross beta activity in six 

intermediate depth wells measured 4.0 pCi/liter. Measurements for the shallow wells averaged 

5.0 pCi/liter. The highest mean (6.7 pCi/L) was observed at shallow well MW-6A. The same 

pattern of concentration was observed in 2008. The most likely cause of higher beta activity is 

contribution from naturally-occurring isotopes. No plant effect was indicated. Tritium activity 

measured below the LLD of 170 pCi/L in all twenty four samples collected from the intermediate 

depth wells. Activity was identified in seven of the twenty-four samples taken from the shallow 

wells and ranged from 180 to 3905 pCi/L. The highest mean (1360 pCi/L) was observed at 

shallow well MW-IA. The lower concentrations observed in 2008 may have been due to a 

dilutive effect from heavy flooding in the area. The activity has been attributed to "washout" from 

gaseous effluents (FPL-DA, 2010?). 

During the site audit, a representative of IDNR provided a copy of a recent inspection of the 

water supply system (IDNR, 2008a). The inspection noted a possible cross-connection to be 

eliminated and several minor deficiencies and recommendations regarding equipment and 

procedures. 

The facility has a 20,000-gallon (76-m3

) sulphuric acid tank with secondary containment, a 

50,000-gallon (189-m3

) diesel tank, and a 40,535-gallon (153-m3) diesel tank. The two diesel 

tanks are located near the reactor building. Their liquid level is monitored by a sensor and 

alarm system and by manual checks. Additional aboveground tanks for gasoline and diesel are 

located at the south warehouse; these were moved during the rising floodwaters in 2008 

(FPL-DA, 2008e). 

2.2.4 Surface Water Resources 

Cedar River water quality is influenced by nonpoint source contaminants, such as runoff of 

fertilizer and animal wastes, because most of the basin is agricultural. Point-source discharges 

from municipal wastewater treatment plants or industries may also affect water quality. 

Significant flooding in the Cedar River watershed and elsewhere in the Midwest took place in 

June 2008, breaching a levee in Cedar Rapids and resulting in evacuations and extensive 

damage (National Climatic Data Center, 2008). Aerial photos taken on June 11, 2008, and 

viewed during the site audit, show the key plant areas, including the cooling towers, to be above 

water. The river covered the ground at the intake structure. Operations continued during the 

flood; no internal flooding was present in the power block (FPL-DA, 2008e). Because the site 

ditch for stormwater and wastewater effluent was full, effluent could not flow as normal to its 

outfall. Instead, the treated effluent was pumped from the wastewater treatment plant over the 

road to the outfall’s receiving ditch, until the level in the ditch subsided (FPL-DA, 2008e). 
Affected Environment 

NUREG-1437, Supplement 42 2-22 October 2010 

The U.S. Geological Survey (USGS) (2008) collected samples at Cedar Rapids on 

June 19, 2008, to assess the effect of the ongoing flood on water quality. Nutrients in the water 

included total nitrogen (unfiltered) at 8.76 milligrams per liter (mg/L), orthophosphorous as P 

(filtered) at 0.146 mg/L, and phosphorous as P (unfiltered) at 0.325 mg/L. Atrazine was 

measured as 0.92 micrograms per liter (ug/L). A variety of organics were found to be below 

detection levels. The USGS (2008) notes that prior water quality analyses from Cedar Rapids 

samples were performed in 1906–1907 and 1944–1954. 

New shoreline protection was emplaced in 2008 along the west bank of the Cedar River, 

downstream of the tributary ditch of stormwater and sewage treatment facility (STF) effluent. 

This action took place after the 2008 flood to counter erosion that took place during the flooding. 

The improvement consists of large pieces of limestone. 

The EPA granted the State of Iowa the authority to issue NPDES permits, and such a permit 

implies water quality certification under the Federal Clean Water Act (CWA) Section 401. The 

State has provided DAEC with an NPDES permit for Outfalls 001 and 002, subject to effluent 

limitations, monitoring requirements, and other stipulations (operation is allowed to continue 

pending State action) as discussed below (IDNR, 2004a). An application has been made for a 

renewal of the NPDES permit (FPL-DA, 2008f) which is under review by the Iowa Department of 

Natural Resources. The existing permit will continue in effect until issuance of the renewed 

permit. 

Outfall 001 is the discharge point for cooling tower blowdown and stormwater runoff. It is 

located near the power block in a discharge canal. The outfall is a pipe entering the canal; 

stormwater enters via another pipe about 30 ft (9 m) away. Effluent limitations are focused on 

pH, chlorine, chromium, zinc, acute toxicity, and duration of chlorine discharge. At Outfall 001, 

monitoring requirements include the following parameters, at varying sample frequencies: flow, 

pH, total residual chlorine, chromium, temperature, zinc, duration of chlorine discharge, acute 

toxicity, and visual observation. Monthly reporting is required. 

No bromine or other biocides are discharged from Outfall 002 (sanitary wastewater discharge). 

However, biocides, including bromine, are discharged from Outfall 001. DAEC employs a 

closed-cycle heat dissipation system with cooling towers. Blowdown water, containing biocides 

such as sodium bromide, is discharged into the Cedar River at Outfall 001. The NPDES permit 

does not include a limit on bromine discharged at Outfall 001. For the cooling water system, the 

State (IDNR, 2003) has permitted the use of Spectrus CT 1300 (Betz), Spectrus NX 1107 

(Betz), Spectrus OX 1201 (Betz), or Macrotech, Inc.’s electrolytic copper technology. Thus, 

bromine (as a Spectrus product) is permitted by the State (IDNR, 2003). IDNR concluded that 

the use of a sodium bromide Spectrus product and other biocides are not expected to be toxic 

to aquatic life in the Cedar River. The effluent from Outfall 001, along with stormwater, flows in 

a narrow open ditch toward the Cedar River. At the riverbank, the flow enters an 18-inch 

(46-cm) diameter pipe with a reducer to 15-inch (38-cm) diameter, flows under a sheet pile 

structure, and is released in a diffuser along the bottom of the river. The pipe openings are 

oriented so that discharge is aimed downstream and upward at a 20 degree angle. The diffuser 

is cleaned out using suction equipment. When flow in the canal exceeds 4,000 gpm (9 cfs or 

0.25 m3

/s), such as during heavy precipitation, flow goes over a weir at the discharge structure, 

into an open canal, and then into the river. 

IDNR (2005b) granted a Water Quality Certification pursuant to Section 401 of the CWA for the 

construction of four spur dikes (or wing dams) on the Cedar River and for dredging. The 

approval includes mechanical dredging of a 1,250-ft (381-m) long by 50-ft (15-m) wide channel, 
Affected Environment 

October 2010 2-23 NUREG-1437, Supplement 42 

with future maintenance dredging as needed. Dredged materials were to be hauled to an 

upland disposal site on the DAEC property. The dredging actions were also approved by the 

U.S. Army Corps of Engineers (USACE) (Department of the Army, 2005). 

Prior to the installation of wing dams, dredging near the intake is reported to have taken place 

annually. Dredged sediments were used to create the site firing range under permit of the 

USACE (Department of the Army, 2005), (IDNR, 2005b). Following the 2008 flood, river flow 

had lowered the river bottom near the intake to a level 12 ft (3.7 m) below the minimum level 

(IIHR, 2008). Therefore, no channel dredging is anticipated in the near future. 

Outfall 002 is the discharge point for a sequencing batch reactor STF, which treats domestic 

wastewater and stormwater. It is located where the plant’s discharge pipe enters a ditch across 

the street from the plant. The DAEC STF began operating in 1988 and has a design capacity of 

54,000 gallons (204 m3

) per day based on a 30-day average. Wastewater passes through the 

comminutor (grinder) before entering the first of two sequenced batch aerobic digesters for 

processing. Sludge, which is sampled once per year, is transferred to the nearby aerobic 

digestion tank for stabilization, and the wastewater is disinfected by chlorination prior to 

discharge at Outfall 002 (FPL-DA, 1988). The STF is operated by a contractor. Approximately 

9,500 gallons (36 m3

) per day of water are discharged to the Cedar River. The discharge flows 

in a pipe under the road to the south, discharging to an open ditch. Flow then mixes with 

stormwater in the ditch and is conveyed to the river at a point approximately 0.4 mi (0.6 km) 

upstream of the location of the intake and the discharge (blowdown) canal. 

Effluent limitations are focused on a 5-day carbonaceous biochemical oxygen demand 

(5CBOD), total suspended solids (TSS), pH, total residual chlorine, and fecal coliform. At 

Outfall 002, monitoring requirements include the following parameters, at varying sample 

frequencies: 5CBOD, TSS, pH, temperature, flow, chlorine, fecal coliform, settleable solids, 

visual observation, dissolved oxygen, and mixed liquor suspended solids. Sampling stations for 

particular parameters may be in the raw wastewater, the final effluent, the aeration basins, or 

the digester. Monthly reporting is required. 

As described earlier, an application has been made for a renewed NPDES permit (FPL-DA, 

2008f). The application’s attachment list includes a list of proposed chemical additives for the 

term of the renewed permit (Table 2-3). The application notes an additional discharge under 

discussion with the IDNR. It is located near Outfall 001. The discharge is approximately 15 to 

25 gpm (56 to 96 liter per minute) continuously, with an additional 100 gpm (378 liters per 

minute) for 6 minutes, three times per day. The source of water is outflow from an inline 

corrosion monitor, inline pH monitors, the pump house sump pumps, and periodic strainer 

backwash from the general service water system. 
Affected Environment 

NUREG-1437, Supplement 42 2-24 October 2010 

Table 2-3. Chemical Additives Listed in National Pollutant Discharge Elimination System 

Application (Source: FPL-DA, 2008f) 

Outfall Manufacturer Product Usage Rate Purpose Injection 

Point 

 001 GE Betz Continuum AEC 3110 50 gal/day (189 liter 

per day) 

Corrosion 

Inhibitor Cooling Tower 

 001 GE Betz Spectrus BD1501E 10 gal/day (38 liter 

per day) 

Minimize 

Scaling Cooling Tower 

 001 GE Betz Inhibitor AZ8100 Currently not in use Corrosion 

Inhibitor Cooling Tower 

 001 K.A. Steel 

Chemicals Sodium Hypochlorite 200 gal/day (757 liter per day) Algaecide Cooling Tower 

 001 Koch Sulfur 

Products Sulfuric Acid 93% 1,000 gal/day (3,785 

liter per day) pH Balance Cooling Tower 

 001 GE Betz Spectrus NX1007 

5 gal/week (19 liter 

per week), summer 

only 

Biocide Cooling Tower 

 001 GE Betz Corrshield MD4100 <10 gal/year (<19 liter 

per year) 

Corrosion 

Inhibitor 

Closed Cooling 

Systems 

 001 GE Betz Spectrus NX1105 (<0.26 gal/year) <1 

liter/year Biocide Closed Cooling 

Systems 

 001 GE Betz Spectrus NX1106 (<0.26 gal/year) <1 

liter/year Biocide Closed Cooling Systems 

 002 FMC Soda Ash 50 lbs/week (23 

kg/week) pH Balance 

Sewage 

Treatment 

Basins 

DAEC has a stormwater pollution prevention plan (FPL-DA, undated #2). The plan includes a 

listing of potential sources of pollutants and associated best management practices. 

A clay-lined sluice pond is located outside and south of the reactor area. In case of an event at 

the low-level radwaste processing and storage buildings, the pond would receive and retain its 

stormwater runoff. The sluice pond has no sampling program. 

During the 2008 flood, effluent was pumped overland to the ditch because a high water level in 

the ditch was preventing normal gravity flow from the STF. Chlorination continued during this 

flood event. 

The STF is listed in a State Web site as having no health-based violations in the last 10 years 

(IDNR, 2009b). The Web site does, however, describe monitoring violations since 2005. These 

include three violations for three parameters (coliform, total trihalomethanes, and total 

haloacetic acids), each taking place in 2007–2008. State compliance was later achieved for 

total trihalomethanes and total haloacetic acids. 

At the site audit conducted by the NRC, an IDNR representative provided a recent STF 

inspection report (IDNR, 2007b) and a written response (FPL-DA, 2007f). The response 

showed adequate resolution regarding modification of equipment and procedures. 
Affected Environment 

October 2010 2-25 NUREG-1437, Supplement 42 

The NPDES permit prohibits any discharge of polychlorinated biphenyl (PCB) compounds such 

as those used for transformer fluid. Cooling tower blowdown resulting from maintenance 

chemicals may not contain any of the 126 priority pollutants listed in Appendix A of 

40 CFR Part 423 except for chromium and zinc, as limited in the permit requirements. Neither 

free available chlorine nor total residual chlorine may be discharged from any source for more 

than two hours in any one day and not more than one source may discharge free available or 

total residual chlorine at any one time. No chemicals may be added to the circulating water 

system during offline conditions. The permit also calls for periodic sampling of the blowdown; 

stipulations on the frequency, duration, and concentration of molluscide treatments for zebra 

mussels; sewage sludge disposal requirements; and adherence to a stormwater pollution 

prevention plan. 

The IDNR (2009c) maintains Web-based information tracking systems that include DAEC data. 

Listed are 21 inspection dates from 1977–2007. No enforcement actions are noted. Monthly 

reported data are available from July 2004 to December 2008. These include several 

exceedences for the 5CBOD, total residual chlorine, TSS, and pH. The EPA (2009d) maintains 

a similar database tool, which tracks the monitoring data for the past 12 quarters. In three 

quarters, from first quarter 2006 to fourth quarter 2008, the exceedences for 5CBOD were 

determined by the EPA to be significant. TSS were significantly high in one quarter. 

Annual REMP reports document regular sampling of surface water and reports for 2006 and 

2007 (FPL-DA, 2007e), (FPL-DA, 2008c) were reviewed. Monthly results for 13 or more 

radioisotopes at the plant intake, the plant discharge (Outfall 001), an upstream location, a 

downstream location, and the Pleasant Creek reservoir were all below the laboratory reporting 

limit; tritium for example was less than 193 pCi/L in each case. At the STF discharge (Outfall 

002), however, measurable activity concentrations ranging up to 382 ± 98 pCi/L of tritium were 

observed in 7 of the 24 monthly samples. For the other months, tritium was less than 193 pCi/L, 

and the other 12 radionuclides were all below laboratory reporting limits. FPL-DA (2008d) 

attributes the relatively high tritium readings in the summer to condensation of tritiated water 

vapor by plant air conditioner systems. Several elevated wintertime readings were attributed to 

radiation workers breathing tritium water vapor in the work environment and releasing this 

tritium in their urine. 

2.2.5 Description of Aquatic Resources 

DAEC is located within the Cedar River Valley in Linn County, Iowa, on the western bank of the 

Cedar River, which is the largest tributary of the Iowa River. The headwaters of the Cedar River 

are located in Dodge County, Minnesota, where its tributaries, the Little Cedar and the Shell 

Rock rivers merge. The Cedar River flows southeast for 329 mi (529 km) through Iowa to its 

confluence with the Iowa River in Columbus Junction, Louisa County, Iowa, about 30 mi (48 km) 

upstream of the mouth of the Iowa River (Sullivan, 2000). The combined Cedar River and Iowa 

River Basins account for 12,640 mi2

 (32,740 km2) and are generally characterized by fertile 

farmland (Sullivan, 2000). 

In June 2008, heavy rainfall from late May to early June across the Midwest region caused 

major flooding events. The Iowa Statewide average rainfall was 9.03 inches (22.9 cm), which is 

6.58 inches (16.7 cm) above the normal level for the time period (NWS, 2009). Portions of the 

city of Cedar Rapids, located approximately 5.7 mi (9.2 km) southeast of DAEC, underwent 

mandatory evacuation in anticipation of the Cedar River water level rising above the city’s levee. 

On June 12, 2008, the levee broke, and approximately 1,300 city blocks, or 9.2 mi2

 (15 km2) 

were submerged (MCEER, 2009). The Cedar River at Cedar Rapids rose to 31.10 ft (9.48 m), 
Affected Environment 

NUREG-1437, Supplement 42 2-26 October 2010 

representing a 500-year recurrence interval and setting a new record flow of 150,000 cfs 

(4,250 m3

/s) (IWSC, 2009). The Cedar River rose to a level 11.44 ft (3.49 m) higher than the 

previous record of 19.66 ft (5.99 km) set on March 31, 1961 (IWSC, 2009). 

2.2.5.1 Benthic Macroinvertebrates 

Benthic macroinvertebrates were monitored at the DAEC site from 1971 through 1999. 

McDonald (2000) observed that a diverse community of macroinvertebrates was unlikely to 

inhabit the area due to the riverbed’s sandy substrate, which is easily transported; thus, 

preventing establishment of a macroinvertebrate community. Artificial substrates were placed 

upstream of, downstream of, and in the discharge canal, and larger and more diverse benthic 

communities readily developed on these surfaces within a 5-week period than what had 

previously been observed. A total of 30 taxa (26 species of insects, 1 annelid, 1 isopod, 

1 nematode, and 1 flatworm) were identified during two sampling periods in September and 

October of 1999. Nematoceran flies (family Chironomidae) and a species of netspinner 

caddisfly (Hydropsyche bidens) dominated all four sampling areas. Generally, diversity of 

organisms was significantly lower in the discharge canal sampling areas than in the river. 

Development of a diverse benthic community on artificial substrate during the sampling period 

suggests that the Cedar River’s natural substrates, and not poor quality of water, prevent the 

development of a diverse macroinvertebrate community (McDonald, 2000). 

Similarly, in the Cedar River Baseline Ecological Study Annual Report (McDonald,1972) 

conducted between April 1971 and April 1972, bottom samples in the vicinity of the site only 

yielded three benthic organisms mentioned in the report— tubificid worms, some chironomid 

larvae, and a significant population of the mayfly Stenoma in rocky, unsilted areas. This study 

concluded that scarce habitat, rather than water quality, prevented the development of larger, 

more diverse benthic populations (McDonald, 1972). 

2.2.5.2 Freshwater Mussels 

Approximately 55 species of native freshwater mussels were recorded in Iowa during European 

settlement; today, about 44 native species and 2 exotic species can be found within Iowa and in 

the Mississippi and Missouri rivers along the State’s border (CVRC&D, 2002). Within Iowa, 

mussels were historically important sources of food for Native Americans, and in the late 1800s, 

mussels were harvested for their shells, which were manufactured into pearl buttons until the 

1940s (CVRC&D, 2002). Overharvesting for the button industry greatly reduced the numbers of 

many of the mussel species native to Iowa. Freshwater mussel numbers have also been 

harmed by river damming because large areas of flowing, oxygenated water becomes 

low-flowing or stagnant after damming and no longer provides adequate mussel habitat. 

Competition with exotic mussel species and contaminants also threaten freshwater mussel 

species. 

Helms & Associates (2003) conducted mussel surveys in December 2002 along the west shore 

of the Cedar River upstream of the DAEC intake canal and found 14 individuals representative 

of 4 species, all of which are native to Iowa. Samples were collected via timed dive searches 

and whole-substrate collections along specified transects. The majority (10) of the individuals 

collected were plain pocketbook (Lampsilis cardium) (Helms, 2003), a species common to Iowa 

waters and found in small creeks to large rivers in a variety of substrate types (CVRC&D, 2002). 

Additionally, two black sandshells (Ligumia recta), one pink papershell (Potamilus ohiensis), and 

one white heelsplitter (Lasmigona complanata) (Helms, 2003) were found. Black sandshells 

and white heelsplitters are classified as uncommon by the IDNR and are generally found in 

interior rivers and streams (IDNR, 2001a), (IDNR, 2001b). Black sandshells prefer riffles with 
Affected Environment 

October 2010 2-27 NUREG-1437, Supplement 42 

gravel or sand substrate, and white heelsplitters prefer pools with mud of sand substrate (IDNR, 

2001a), (IDNR, 2001b). Pink papershells are common to Iowa waters and are generally found 

in the lower reaches of larger tributaries in slower moving waters and silt, mud, or sand 

substrate (IDNR, 2001c). An additional dead individual, a squawfoot (Strophitus undulatus), 

was collected during the 2002 survey. This species is threatened at the Iowa State level and is 

found in interior rivers and streams in mud, sand, or gravel substrate (IDNR, 2001d). More 

information about this species is provided in Section 2.2.7 of this SEIS. The study concluded 

that the substrate within the Cedar River near DAEC provides poor to marginal habitat for 

mussels, though a small community exists within the area (Helms, 2003). 

2.2.5.3 Fish 

In 1996, the USGS collected data on fish communities in eastern Iowa across 12 sites as part of 

the National Water-Quality Assessment (NAWQA) Program from mid-September to early 

October. A total of 56 fish species in 13 families were collected across all sites. Two of the 

data collection sites were located on the Cedar River: one at Gilbertville, Black Hawk County 

(approximately 35 mi (56 km) northwest and upstream of the DAEC site), representative of 

water quality near both row-crop agriculture and urban development; and one near Conesville, 

Muscatine County, at the mouth of the Cedar River Basin (approximately 60 mi (97 km) 

southeast and downstream of the DAEC site) (Sullivan, 2000). 

Minnows (Cyprinids) and suckers (Catastomids) dominated all large river sites that were 

sampled, including both of the Cedar River sites. At the upstream Cedar River site, minnows 

accounted for 81 percent of fish collected, followed by suckers (16 percent), sunfish 

(Centrarchids; 2 percent), catfish (Ictalurids; less than 1 percent), and perch (Percids; less than 

1 percent). The most abundant species at the upstream site were spotfin shiner (Cyprinella 

spiloptera; 749 individuals), bluntnose minnow (Pimephales notatus; 527 individuals), river 

carpsucker (Carpoides cyprinus; 293 individuals), and sand shiner (Notropis stramineus; 

130 individuals). At the downstream Cedar River site, suckers accounted for nearly 45 percent 

and minnows accounted for 43 percent of fish collected, followed by catfish (9 percent); sunfish 

(2 percent); and herrings (Clupids), temperate bass (Percichthyids), drums (Sciaenids), and 

gars (Lepisosteids) (each less than 1 percent). The most abundant species at the downstream 

site were river carpsucker (665 individuals), bullhead minnow (Pimephales vigilax; 

485 individuals), channel catfish (Ictalurus punctatus; 137 individuals), and spotfin shiner 

(127 individuals) (Sullivan, 2000). 

The fish community within the Cedar River sites was rated “fair” by Sullivan (2000) using the 

States of Ohio and Wisconsin’s Index of Biotic Integrity (IBI). The IBI system integrates 

information at multiple levels including individual, population, community, and ecosystem to 

produce a numerical rating of a fish community’s health. Of the six large-river sites, the 

upstream and downstream Cedar River sites received the second and third highest IBI score, 

though fish communities at all sites were considered to be somewhat degraded compared to 

reference conditions. The report concluded that conversion of prairie for agricultural use and 

the increasing population along the Iowa and southern Minnesota rivers account for the majority 

of this trend. Eutrophication (excessive nutrients in a body of water caused by runoff of 

nutrients such as animal waste, fertilizers, sewage from the land) from agricultural and urban 

runoff, contamination from pesticides and other chemicals, soil erosion, and sedimentation were 

also cited as factors that have degraded the aquatic environment in eastern Iowa (Sullivan, 

2000). 
Affected Environment 

NUREG-1437, Supplement 42 2-28 October 2010 

From 1979 through 1983, Ecological Analysts, Inc. conducted operational ecological studies for 

Iowa Electric Light and Power Company in the vicinity of the DAEC site. During the year 1983, 

a total of 1347 fish were collected, representing 41 species and 8 families. River carpsucker 

(Carpiodes carpio), spotfin shiner (Cyprinella spiloptera), and carp (Cyprinus carpio) were 

among the most prevalent fish collected each year, and generally, few differences were 

observed in species composition over the 5 years of sampling. During the 1983 sampling year, 

minnows (Cyprinids) accounted for 79.7 percent of fish collected, followed by suckers 

(Catastomids; 12 percent), sunfish (Centrarchids; 3.6 percent), catfish (Ictalurids; 2.8 percent), 

perch (Percids; 0.6 percent), and then herrings, pikes, and silversides (Clupids, Esocidae, and 

Atherinidae; each 0.1 percent). When compared, these sampling results are similar in species 

composition and density to the Sullivan (2000) study discussed above (Ecological Analysts, 

1984). 

2.2.6 Description of Terrestrial Resources 

DAEC is located on the western bank of the Cedar River, a tributary of the Iowa River and, 

geologically, within the Midcontinent Rift System (MRS). The MRS began to form about 

1,100 million years ago when tensional stresses, suggested to be the result of a mantle plume, 

caused a large fracture across the North American continent stretching in an arc from Kansas 

northeasterly through Lake Superior, and then southeasterly through lower Michigan (Anderson, 

1997), (Bornhorst et al., undated). Subsequently, compressive stresses forced sedimentary 

rock upwards, redepositing older rock over new rock (Anderson, 1997). Overall, the central 

portions of Iowa were uplifted as much as 30,000 ft (9,100 m) (Anderson, 1997). A unique 

characteristic of this rift system is that it cuts across a number of Precambrian basement 

terranes, each of which have different age, structure, and composition (Schmus and Hinze, 

1985). The rift system encompasses nearly 42,000 mi2

 (67,600 km2) and is characterized by a 

central horst bounded by fault zones and bordered by basins (Anderson, 1997). DAEC is 

located just east of the Williamsburg Basin, which is characterized by clastics, or rocks 

composed of pre-exisiting sedimentary rock, that was formed from the MRS. Black Hawk 

County, through which the Washburn transmission line passes, contains MRS clastics that 

reach thicknesses of up to 8,000 ft (2,400 m). 

The portion of the Cedar River on which the DAEC site is located generally consists of broad 

valleys and narrow floodplains and has an elevation of 750 ft (230 m) above msl. The DAEC 

site encompasses approximately 500 ac (200 ha), of which about 140 ac (57 ha) contain the 

generating facility, associated buildings, switchyard, parking lots, and mowed areas (FPL-DA, 

2008a). Of the remaining 360 ac (143 ha), about 126 ac (51 ha) is leased for agricultural use, 

and the remaining land is composed of oak-hickory forest, marsh, and riparian and floodplain 

habitat (FPL-DA, 2008a). 

Predominating floodplain and riparian vegetation include silver maple (Acer saccharinum), 

green ash (Fraxinus pennsylvanica), box elder (Acer negundo), and hawthorn (Crataegus 

mollis) (Neimann and McDonald, 1972). Understory species are less common within the vicinity 

of the DAEC site due to periodic flooding of the river floodplain. 

A variety of wildlife is known to inhabit the DAEC site, including white-tailed deer (Odocoileus 

virginianus), raccoon (Procyon lotor), muskrat (Ondatra zibethica), opossum (Didelphis 

virginiana), spotted skunk (Spilogale putorius), and striped skunk (Mephitis mephitis) (FPL-DA, 

2008a) (Collins and MacDonald, 1972). Commonly observed birds include meadowlarks 

(Sturnella spp.), barn swallows (Hirundo rustica), red-winged blackbirds (Agelaius phoeniceus), 

blue jays (Cyanocitta cristata), and wood duck (Aix sponsa) (FPL-DA, 2008a). Bird surveys 
Affected Environment 

October 2010 2-29 NUREG-1437, Supplement 42 

conducted for the FES, related to the operation of DAEC (AEC, 1973), also included pheasants 

and quail in the wooded areas, as well as doves and crows. 

The U.S. osprey (Pandion haliaeetus) population declined significantly between 1950 and 1970 

due to the species’ sensitivity to the insecticide dichlorodiphenyltrichloroethane (DDT) and other 

chemicals (Cornell, 2003). After DDT was banned from use in 1972, the species’ numbers 

began to increase, but migration to new breeding areas remains low. The species is not 

endangered nor threatened at the Federal or State level; however, State agencies have been 

working together to expand the bird’s breeding range because ospreys experience suppressed 

reproductive ability as the population becomes more dense, as has been observed in the Great 

Lakes population. In July of 2004, the IDNR released 24 (42-day-old) ospreys at five sites 

around the State in an effort to expand the species’ distribution (IDNR, 2004b). The young 

ospreys were relocated from areas in Minnesota and Wisconsin so that surviving mature birds 

will return to Iowa to nest within 3 to 4 years of release. During this effort, five ospreys were 

released at Wickiup Hill, which is located just east of the site and across the river 

(IDNR, 2004b). As of 2005, IDNR has recorded an active osprey nest at Hartman Reserve in 

Black Hawk County, and as of 2007, an active osprey nest at Wickiup Hill in Linn County 

(IDNR, 2008c). The pair that returned to Wickiup Hill is believed to be a pair that was released 

in 2006 (Fritzell, 2008). The pair incubated eggs in 2007, though none hatched (Fritzell, 2008). 

In 2008, three young hatched, but did not survive a storm in June (Fritzell, 2008). In July 2007, 

a nest site on the 280-ft (85-m) DAEC meteorological tower was discovered (Fritzell, 2008). 

The pair is believed to be a separate nesting pair from the one recorded at nearby Wickiup Hill, 

though specific banding of the pair is unknown (Fritzell, 2008). The pair returned in 2008, 

however, neither year resulted in successful hatching (Fritzell, 2008). DAEC staff has consulted 

with IDNR concerning the potential construction of artificial nesting platforms for the birds 

(FPL-DA, 2008a). 

DAEC maintains a U.S. Fish and Wildlife Service (USFWS) Permit (USFWS, 2009a) for 

depredation of turkey vultures. In the past, turkey vultures have nested on and caused 

interference with the communication towers on the site. This permit allows specified DAEC staff 

members to take four turkey vultures per year in the threatened area, which is defined as 

“private property or real property in danger of harm to its commercial value or recreational use” 

(USFWS, 2009a). DAEC must submit an annual report to the USFWS on January 31 of each 

year as a requirement of the permit. The 2008 Depredation Annual Report (FPL-DA, 2009d) 

specified that three turkey vultures had been killed in the 2008 calendar year. DAEC first 

sought this permit in 2008 and has since renewed it once. 

Four parks or designated wildlife areas are located near the DAEC site: 

● Pleasant Creek State Recreation Area is a 1,927-ac (780-ha) park that is 

located 1 mi (0.6 km) northwest of the site (FPL-DA, 2008a). The park contains 

a 410-ac (166-ha) lake and is designated as an Important Bird Area in Iowa 

(IDNR, 2009d). Over 200 bird species have been recorded within the park, 

including the threatened Henslow’s sparrow (Ammodramus henslowii), which is 

known to nest on the south end of the lake (IDNR, 2009d). 

● Lewis Preserve is located about 2 mi (2.4 km) north of the site and just east of 

the Pleasant Creek State Recreation Area. 

● The Palo Marsh Natural Area covers 144 ac (58 ha) and is located 2 mi (1.2 km) 

southwest of the DAEC site and just north of the town of Palo (FPL-DA, 2008a). 
Affected Environment 

NUREG-1437, Supplement 42 2-30 October 2010 

● Wickiup Hill encompasses 563 ac (228 ha) across the Cedar River and just east 

of the DAEC site. This area includes the Wickiup Hill Outdoor Learning Center, 

which hosts educational, historical, and cultural events. 

2.2.7 Protected Species 

Tables 2-5 and 2-6 list threatened, endangered, or candidate species known to occur in Linn 

County (in which DAEC is located) or Benton or Black Hawk counties (through which 

transmission line ROWs are associated with DAEC traverse). 

2.2.7.1 Aquatic Species 

No Federally or State-listed aquatic species are known to occur on or within the vicinity of the 

DAEC site (USFWS, 2009b), (IDNR, 2009e). However, one previously dead squawfoot mussel 

(Strophitus undulatus) was recovered during a 2002 mussel survey (Helms, 2003) that was 

conducted on the west bank of the Cedar River upstream of the DAEC intake canal, which 

indicates that this species has the potential to occur within the vicinity of the site. Additionally, 

the USFWS and IDNR are taking action to restore the Higgins eye pearlymussel (Lampsilis 

higginsii) to the Cedar River downstream of DAEC (USFWS, 2009b). Historic records 

(pre-1965) indicate that the species’ natural range included 14 Mississippi River tributaries, 

including the Cedar River (Miller and Payne, 2007). Impingement and entrainment into the 

DAEC cooling system is not expected to be a threat, nor is this species Federally or State-listed 

within Linn, Benton, or Black Hawk counties; therefore, the species is not discussed below in 

detail. 

Squawfoot

The squawfoot (also known as creeper or strange floater) is Iowa State-listed as threatened. 

The species’ range extends throughout the eastern and central United States and parts of 

Canada. The freshwater mussel species has an oval, moderately compressed, chestnut to dark 

brown shell with green rays (CVRC&D, 2002). The shell is smooth and shiny with a rounded 

anterior edge and bluntly pointed posterior edge with total length of up to 4 inches (10 cm) 

(Cummings and Mayer, 1992). The squawfoot is a habitat generalist and can be found in smallto medium-size interior rivers and streams with mud, sand, or gravel substrate (Cummings and 

Mayer, 1992). Increasing water temperatures in the spring induce males to release sperm into 

the water column (Mulcrone, undated). As females siphon water for food, they also take in the 

sperm to fertilize eggs in gill sacs (referred to as marsupia) where the fertilized eggs mature into 

a larval stage (referred to as glochoidia). Squawfoot eggs are fertilized in the summer, and the 

female carries the eggs through the following spring, at which point the glochidia are released 

into the water column (NatureServe, 2009). Glochoidia then attach themselves to a host fish 

parasitically and remain attached until they develop into juveniles. Juveniles then detach from 

the host and drop to the bottom of the water column (IDNR, 2001d). Squawfoot glochidia have 

been observed to have a wide range of possible host species, including numerous species of 

Cyprinids and Ictalurids (NatureServe, 2009). Juveniles and adults are filter feeders and prefer 

oxygenated, flowing water (CVRC&D, 2002). Squawfoot are preyed upon by muskrat (Ondatra 

zibethicus), raccoons (Procyon lotor), mink (Mustela vison), river otter (Lutra canadensis), as 

well as some species of birds. The main causes of this species’ decline are pollution from 

agricultural runoff, pesticides, and other chemicals; damming of rivers; over-harvesting; and 

competition with exotic mussel species. Although a dead squawfoot was found upstream of 

DAEC in 2002, no live specimens have been collected in recent years (IDNR, 2009e). 
Affected Environment 

October 2010 2-31 NUREG-1437, Supplement 42 

Table 2-4. Listed Aquatic Species. The species below are Federally-listed and/or Iowa-listed 

as threatened or endangered species. These species may occur on the DAEC site or within the 

Cedar River near the DAEC site or along in-scope transmission line ROWs. 

Scientific Name Common Name Federal 

Status(a)

State 

Status(b) County(ies) 

Fish 

Ammocrypta clara western sand darter - IT Black Hawk, 

Linn 

Esox americanus grass pickerel - IT Linn 

Etheostoma spectabile orangethroat darter - IT Linn 

Lampetra appendix American brook lamprey - IT Benton, Black 

Hawk, Linn 

Moxostoma duquesnei black redhorse - IT Benton, Black 

Hawk, Linn 

Notropis heterolepis blacknose shiner - IT Benton, Linn 

Notropis texanus weed shiner - IE Benton, Linn 

Freshwater Mussels

Alasmidonta viridis slippershell - IE Linn 

Anodontoides ferussacianus cylindrical papershell - IT Black Hawk, 

Linn 

Lampsilis teres yellow sandshell - IE Black Hawk, 

Linn 

Lasmigona compressa creek heelsplitter - IT Black Hawk, 

Linn 

Strophitus undulatus squawfoot - IT Black Hawk, 

Linn 

Tritogonia verrucosa pistolgrip - IE Linn 

Venustaconcha ellipsiformis ellipse - IE Linn 

(a) DL = Delisted; E = Federally endangered; T = Federally threatened; - = No listing 

(b) IE = Iowa endangered; IT = Iowa threatened 

Sources: IDNR, 2009f; IDNR, 2009g; IDNR, 2009h 

2.2.7.2 Terrestrial Species 

Two Federally-listed species, the prairie bush clover (Lespedeza leptostachya) and the western 

prairie fringed orchid (Platanthera praeclara), have been recorded within Linn, Benton, and 

Black Hawk counties (USFWS, 2009b); however, neither of these species is known to occur on 

the DAEC site (FPL-DA, 2008a). The State-listed species, the peregrine falcon (Falco 

peregrinus), is discussed below because the species was introduced to the site as part of Iowa’s 

Peregrine Falcon Restoration Project in 2002. The State-listed bald eagle (Haliaeetus 

leucocephalus) is also discussed because the USFWS lists the species as breeding in Linn 

County, as well as wintering along rivers and larger bodies of water in the area (USFWS, 

2007a). 
Affected Environment 

NUREG-1437, Supplement 42 2-32 October 2010 

Prairie Bush Clover

The prairie bush clover is Federally and Iowa State-listed as threatened. The species is a 

slender-leaved legume in the pea family with pink to cream flowers that bloom in July 

(Sather, 1990). The prairie bush clover is endemic to the Midwest and only occurs in 

Minnesota, Wisconsin, Iowa, and Illinois tall-grass prairie habitat within the upper Mississippi 

River Valley (USFWS, 2000). In 1990, about 100 known prairie bush clover sites existed, and 

by 2000, fewer than 40 known sites remained (USFWS, 2000), (Sather, 1990). Loss of prairie 

habitat is attributed to this species’ decline (USFWS, 2000). According to the IDNR Natural 

Areas Inventory Database, the species occurs in all three counties associated with DAEC and 

its in-scope transmission lines (IDNR, 2009b), (IDNR, 2009c), (IDNR, 2009d); however, the 

species is not known to occur on the DAEC site. No critical habitat has been designated for this 

species (USFWS, 2007a), (USFWS, 2009b). 

Western Prairie Fringed Orchid

The western prairie fringed orchid is Federally and Iowa State-listed as threatened. The species 

is characterized by a single 2.5- to 4-ft (0.8- to 1.2-m) stalk with up to 40 large white flowers and 

2 to 5 elongate leaves originating at the base of the plant (Sather, 1991). The species only 

occurs west of the Mississippi River in Iowa, Kansas, Minnesota, Nebraska, North Dakota, and 

in Manitoba, Canada (USFWS, 2004). Historic records indicated the existence of over 160 sites 

in 9 States, whereas today, only 55 sites in 7 States are known to exist (Sather, 1991). Western 

prairie fringed orchids occur in mesic to wet tallgrass prairie, wet meadows, and remnant native 

prairie (USFWS, 2004), (Sather, 1991). Conversion of prairie for agricultural use, filling in of 

wetlands, and use of pesticides and insecticides in and near the species’ habitat, which reduce 

numbers of available pollinators, are the major threats to the species (USFWS, 2004). 

According to the IDNR Natural Areas Inventory Database, the species occurs in all three 

counties associated with DAEC and its in-scope transmission lines (IDNR, 2009b), (IDNR, 

2009c), (IDNR, 2009d); however, the species is not known to occur on the DAEC site. No 

critical habitat has been designated for this species (USFWS, 2007a), (USFWS, 2009b). 

Peregrine Falcon

The peregrine falcon is endangered at the Iowa State level. The USFWS formally removed the 

peregrine falcon from the Federal List of Endangered and Threatened Wildlife effective August 

25, 1999, though the species continues to be protected under the Migratory Bird Treaty Act 

(64 FR 46541). Post-delisting monitoring results for the species published in 71 FR 60563 in 

2006 estimated the number of breeding pairs across the United States, Canada, and Mexico to 

be 3,005, an increase of 1,255 pairs when compared to the 1999 estimate of 1,750 pairs at the 

time of delisting. The monitoring results concluded that the peregrine falcon population is 

“secure and vital” (71 FR 60563). 

Adult peregrine falcons have a bluish-black head and wings, are 14 to 19 inches (36 to 48 cm) 

tall, and have a wingspan of 39 to 43 inches (99 to 109 cm) (Cornell, 2003). Adults nest from 

April to July on high cliffs and bluffs along the Mississippi River. Females lay two to five eggs, 

which hatch in 28 to 29 days, and young leave the nest within 6 to 9 weeks of hatching 

(MNDNR, 2008a). Peregrine falcons prey on ducks, pigeons, and other birds, as well as small 

mammals and insects (MNDNR, 2008a). 

Peregrine falcons have been recorded to nest in nine Iowa counties, including Linn and Black 

Hawk counties; however, prior to current ongoing reintroduction efforts, the last recorded nest in 

Iowa was in 1956 (IDNR, 2009i). Between 1989 and 1992, Iowa, in coordination with the 

Peregrine Fund, the Raptor Center at the University of Minnesota, and the Iowa Peregrine 
Affected Environment 

October 2010 2-33 NUREG-1437, Supplement 42 

Falcon Recovery Team, released 50 peregrine falcons in Cedar Rapids, Des Moines, and 

Muscatine as part of the Eastern Peregrine Recovery Program (IDNR, 2009i). By 2000, over 

900 peregrine falcons had been released across the Midwest region (IDNR, 2009i). Five 

nesting pairs have been recorded in Iowa (IDNR, 2009i). In 2002, representatives of the Iowa 

Peregrine Falcon Restoration Project released eight peregrine falcons at a hacking station on 

the off-gas stack on the DAEC site; however, the birds did not return to the site to nest (FPL-DA, 

2008a). 

Bald Eagle

The bald eagle is threatened at the Iowa State level. The USFWS formally removed the bald 

eagle from the Federal List of Endangered and Threatened Wildlife effective August 8, 2007, 

though the species continues to be protected under the Bald and Golden Eagle Protection Act 

and the Migratory Bird Treaty Act (72 FR 37346). Each of these acts protects the species by 

prohibiting killing, selling, or otherwise harming eagles, nests, or eggs. On June 4, 2007, the 

USFWS published National Bald Eagle Management Guidelines (USFWS, 2007b) to ensure the 

continued protection of the species under the applicable acts. 

Bald eagles mature at 4 to 5 years of age and average 8 to 9 lbs (3.6 to 4.1 kg) for males and 

10 to 14 lbs (4.5 to 6.4 kg) for females with a 6 to 7.5 ft (1.8 to 2.3 m) wingspan 

(MNDNR, 2008b). Juveniles have speckled white and brown plumage, which gradually 

changes to dark brown on the body and white on the head by the time adulthood is reached at 

about 5 years of age (USFWS, 2007b). Adults usually nest near coasts, rivers, or large bodies 

of water in old-growth trees, dead trees, or on cliffs (USFWS, 2007b). Females lay eggs 

between late April and early May in the northern United States, and eggs hatch in 33 to 35 days 

(USFWS, 2007b). Eaglets generally leave the nest within 6 weeks of hatching. Bald eagles 

prey primarily on fish, but also eat waterfowl, small mammals, and carrion. 

As part of the USFWS bald eagle regional recovery plan, the State of Iowa aimed to establish 

10 active bald eagle nests between 1981 and 2000 (Fritzell, 2008). This goal was more than 

surpassed; by 1991, 13 active nests were recorded, and in 1998, the State reported 84 active 

nests across 42 counties (Fritzell, 2008). The population continued to expand and by 2008, an 

estimated 210 active nests in 83 of the 99 Iowa counties have been recorded (Fritzell, 2008). 

According to the IDNR, bald eagles were recorded as first nesting in Benton, Black Hawk, and 

Linn counties in 1992, 1993, and 1994, respectively (Fritzell, 2008). No active nests have been 

observed on or near the DAEC site (FPL-DA, 2008a). 
Affected Environment 

NUREG-1437, Supplement 42 2-34 October 2010 

Table 2-5. Listed Terrestrial Species. This table shows the status of Federally-listed and/or 

Iowa-listed as threatened, endangered, or special concern species (note: none of these species 

are Federally-listed species). These species may occur on the DAEC site or within the in-scope 

transmission line ROWs. 

Scientific Name Common Name Federal 

Status(a)

State 

Status(b) County(ies) Habitat 

Reptiles and Amphibians 

Ambystoma laterale blue-spotted 

salamander 

- IE Black Hawk, 

Linn 

moist woodlands 

with small ponds 

Clemmys insculpta wood turtle - IE Benton, Black 

Hawk 

large rivers with 

sandy substrate 

Crotalus viridis prairie rattle 

snake 

- IE Benton prairie; grasslands; 

pastures 

Emydoidea blandingii Blanding’s turtle - IT Black Hawk, 

Linn 

shallow ponds; 

marshes; swamps 

Liochlorophis vernalis smooth green 

snake 

- SSC Benton fields and 

meadows; grassy 

areas 

Necturus maculosus mudpuppy - IT Black Hawk rivers; streams; 

canals; lakes 

Notophthalmus 

viridescens 

central newt - IT Black Hawk, 

Linn 

temperate forests 

with 

semi-permanent 

ponds 

Terrapene ornate ornate box turtle - IT Benton, Black 

Hawk, Linn 

dry prairie; oak 

savannahs 

Insects 

Euphydryas phaeton Baltimore 

butterfly 

- IT Linn wet meadows; 

bogs; marshes 

Problema byssus byssus skipper - IT Linn tall-grass prairie; 

coastal marshes 

Birds 

Ammodramus henslowii Henslow’s 

sparrow 

- IT Linn grasslands 

Buteo lineatus red-shouldered 

hawk 

- IE Benton, Black 

Hawk 

deciduous and 

deciduous-conifer 

forest; swamps 

Falco peregrinus peregrine falcon - IE Linn grasslands; 

meadowlands 

Haliaeetus leucocephalus bald eagle DL IE Benton, Black 

Hawk, Linn 

forested areas 

near open water 

Mammals 

Perognathus flavenscens plains pocket 

mouse 

- IE Benton, Black 

Hawk, Linn 

sparsely vegetated 

areas 

Spilogale putorius spotted skunk - IE Black Hawk rocky bluffs; 

canyon stream 

beds 
Affected Environment 

October 2010 2-35 NUREG-1437, Supplement 42 

Scientific Name Common Name Federal 

Status(a)

State 

Status(b) County(ies) Habitat 

Plants 

Adoxa moschatellina muskroot - SSC Benton damp cliffs and 

slopes 

Astragalus distortus bent milk-vetch - SSC Benton sparsely vegetated 

slopes 

Besseya bullii kitten-tail - IT Benton, Black 

Hawk, Linn 

prairie 

Betula pumila bog birch - IT Black Hawk bogs; calcareous 

fens; swamps; 

lakeshores 

Botrychium simplex little grape fern - IT Black Hawk, 

Linn 

dry fields; 

marshes; bogs; 

swamps 

Cacalia suaveolens sweet Indian 

plantain 

- IT Benton nutrient rich 

wooded areas; 

shaded, wet 

streamsides 

Carex leptalea slender sage - SSC Benton fens; wet meadows 

Chimaphila umbellata prince’s pine - IT Linn coniferous 

woodlands 

Cirsium muticum swamp thistle - SSC Benton wet meadows; 

moist wooded 

areas 

Cornus canadensis bunchberry - IT Linn woodland edges; 

bogs 

Cypripedium candidum small white 

lady’s slipper 

- SSC Benton fens; wet prairies 

Cypripedium reginae showy lady’s 

slipper 

- IT Black Hawk bogs; swamps; wet 

meadows and 

prairie 

Dalea villosa silky prairie 

clover 

- IE Black Hawk prairie 

Decodon verticillata swamp 

loosestrife 

- IE Black Hawk swamps; shallow 

water 

Dichanthelium borealis northern panic 

grass 

- IE Linn open woods; fields; 

shorelines 

Eriophorum angustifolium tall cotton grass - SSC Benton 

Equisetum sylvaticum woodland 

horsetail 

- IT Black Hawk, 

Linn 

moist, open woods; 

meadows; thickets 

Gaylussacia baccata black 

huckleberry 

- IT Linn open woodlands; 

clearings with dry, 

sandy soils 

Hypericum boreale northern St. 

John’s wort 

- IE Linn sunny, well-drained 

soils in agricultural 

areas and 

clearings 
Affected Environment 

NUREG-1437, Supplement 42 2-36 October 2010 

Scientific Name Common Name Federal 

Status(a)

State 

Status(b) County(ies) Habitat 

Ilex verticillata winterberry - IE Linn swamps; marshes 

Juncus greenei Green’s rush - SSC Benton wet meadows; 

pond and marsh 

margins 

Lechea intermedia narrowleaf 

pinweed 

- IT Benton dry, sandy soils on 

hillsides; open 

woodlands 

Lespedeza leptostachya prairie bush 

clover 

T IT Benton, Black 

Hawk, Linn 

prairie 

Menyanthes trifoliate buckbean - IT Linn shallow ponds; 

bogs 

Mimulus glabratus yellow monkey 

flower 

- IT Linn streamsides; 

shorelines; 

swamps 

Oenothera perennis small sundrops - IT Linn fields; open 

woodlands 

Ophioglossum pusillum northern 

Adder’s-tongue 

- SSC Benton open fens; bogs; 

marsh edges; 

pastures 

Opuntia macrorhiza prickly-pear - IE Linn open, sandy, rocky 

areas 

Phlox bifida cleft phlox - SSC Benton rocky, open 

wooded areas; 

ravines 

Platanthera flava tubercled orchid - IE Linn wet prairies; sedge 

meadows 

Platanthera praeclara western prairie 

fringed orchid 

T IT Benton, Black 

Hawk, Linn 

tallgrass prairie; 

sedge meadows 

Platanthera psycoides purple fringed 

orchid 

- IT Linn swamps; wet 

meadows 

Polygala incarnate pink milkwort - IT Black Hawk, 

Linn 

prairie; lakeshores; 

meadows 

Polygala polygama purple milkwort - IE Linn pine-oak 

woodlands; 

mountain ridgetops 

Salix candida sage willow - SSC Benton bogs; fens; willow 

thickets 

Salix pedicellaris bog willow - IT Benton, Black 

Hawk 

bogs; sedge 

meadows 

Selaginella rupestris ledge 

spikemoss 

- SSC Benton cliffs; rocky 

outcrops 

Spiranthes ovalis oval 

ladies-tresses 

- IT Linn moist, shady 

upland forests 

Biola lanceolata lance-leaved 

violet 

- SSC Benton bogs; swamps; wet 

meadows 

Xyris torta yellow-eyed - IE Benton, Linn bogs; pond 
Affected Environment 

October 2010 2-37 NUREG-1437, Supplement 42 

Scientific Name Common Name Federal 

Status(a)

State 

Status(b) County(ies) Habitat 

grass margins; fields; 

ditches 

Snails 

Vertigo meramecensis bluff vertigo - IT Linn wooded bluffs; 

caves 

(a) DL = Delisted; E = Federally endangered; T = Federally threatened; - = No listing 

(b) IE = Iowa endangered; IT = Iowa threatened; SSC = Iowa species of special concern 

Sources: USFWS, 2008; IDNR, 2009f; IDNR, 2009g; IDNR, 2009h 

2.2.8 Socioeconomic Factors 

This section describes current socioeconomic factors that have the potential to be directly or 

indirectly affected by changes in operations at DAEC. DAEC and the people and communities 

that support it can be described as a dynamic socioeconomic system. The communities provide 

the people, goods, and services required by power plant operations. DAEC, in turn, creates the 

demand for people, goods, and services and pays for them in the form of wages, salaries, and 

payments for goods and services. Income from wages and salaries, and payments for goods 

and services is then spent on other goods and services in the community, thus creating 

additional opportunities for employment and income. The measure of the communities’ ability to 

support the demands of DAEC depends on their ability to respond to changing environmental, 

social, economic, and demographic conditions caused by the plant. 

The socioeconomics region of influence (ROI) is defined by the areas where DAEC employees 

and their families reside, spend their income, and use their benefits, thereby affecting the 

economic conditions of the region. The DAEC ROI consists of a two-county area (Linn and 

Benton counties) where approximately 90 percent of DAEC employees reside and includes the 

city of Cedar Rapids. FPL-DA employs approximately 661 employees (FPL-DA, 2008a). 

Approximately 90 percent live in Linn and Benton counties, Iowa (Table 2-6). The remaining 

11 percent of the workforce are divided among 14 counties in Iowa, with numbers ranging from 

one to five employees per county. Given the residential locations of DAEC employees, the most 

significant impacts of plant operations are likely to occur in Linn and Benton counties. The 

focus of the analysis in this SEIS is, therefore, on the impacts of DAEC in these two counties. 

Table 2-6. Duane Arnold Energy Center Permanent Employee Residence by County in 

2006 

County Number of DAEC Personnel Percentage of Total 

Linn 504 76 

Benton 86 13 

Johnson 28 4 

Black Hawk 6 1 

Others 37 6 

Total 661 100 

Source: FPL-DA, 2008a 
Affected Environment 

NUREG-1437, Supplement 42 2-38 October 2010 

Refueling outages at DAEC normally occur at 18 to 24-month intervals. During refueling 

outages, site employment increases by 1,000 workers for approximately 25 to 30 days (FPL-DA, 

2008a). Most of these workers are assumed to be located in the same geographic areas as the 

permanent DAEC staff. The following sections describe the housing, public services, offsite 

land use, visual aesthetics and noise, population demography, and the economy in the ROI 

surrounding the DAEC site. 

2.2.8.1 Housing 

Table 2-7 lists the total number of occupied housing units, vacancy rates, and median value in 

the ROI. According to the 2000 Census, there were almost 91,000 housing units in the ROI, of 

which approximately 86,500 were occupied. The median value of owner-occupied units was 

almost $99,500 in Linn County, higher than in Benton County. The vacancy rate was lower in 

Linn County (4.7 percent) and higher in Benton County (6.1 percent) than in the ROI as a whole 

(4.8 percent). 

By 2005–2007, the total number of housing units in Linn County had grown by almost 

12,000 units to 102,748, while the total number of occupied units grew by 8,146 units to 94,645. 

As a result, the number of available vacant housing units increased by more than 3,700 units to 

8,103, or 7.9 percent of total housing units. 

Table 2-7. Housing in Linn and Benton Counties, Iowa 

Linn Benton ROI 

Year 2000 

Total 80,551 10,377 90,928 

Occupied housing units 76,753 9,746 86,499 

Vacant units 3,758 631 4,389 

Vacancy rate (percent) 4.7 6.1 4.8 

Median value (dollars) 99,400 82,700 97,494 

2005–2007; 3-year estimate 

Total 91,733 11,015 102,748 

Occupied housing units 84,535 10,110 94,645 

Vacant units 7,198 905 8,103 

Vacancy rate (percent) 7.8 8.2 7.9 

Source: USCB, 2009a; USCB, 2009b; USCB, 2009c 

2.2.8.2 Public Services 

This section presents a discussion of public services including water supply, education, and 

transportation. 

Water Supply

Water systems in Linn and Benton counties use groundwater sources. The largest water supply 

system in the two counties is the Cedar Rapids Water Department, which also operates a well 
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October 2010 2-39 NUREG-1437, Supplement 42 

system of shallow vertical and collector wells constructed in the sand and gravel deposits along 

the Cedar River. Because of continuous pumping of the city’s wells, most of the water in the 

aquifer is pulled from the river. The well system consists of four well fields with a total of four 

collector wells and 45 vertical wells. Local industries use 75 percent of the water and the 

remaining 25 percent is used by residential, commercial, and municipal customers 

(CRWD, 2005), (CRWD, undated). Table 2-8 lists the largest municipal water suppliers in Linn 

and Benton counties. 

Table 2-8. Major Public Water Supply Systems in Linn and Benton Counties. Average 

Daily and Maximum Daily Production and System Design Capacity (million gallons per day.)

Water Supplier (a) Water Source Average Daily 

Production Design Capacity

Linn County 

Cedar Rapids Water Department GW 39.4 45.0 

Marion Municipal Water Department GW 2.6 6.5 

Benton County 

Vinton Municipal Water Department GW 0.5 1.2 

GW = Groundwater 

(a) Source: EPA, 2007a; EPA, 2007b 

Education

DAEC is located in the Cedar Rapids Community School District, Linn County. The school 

district had 35 schools and an enrollment of approximately 17,263 students in 2007. Including 

the Cedar Rapids Community School District, Linn County had 11 school districts (NCES, 

2009), with 34,492 students enrolled in public schools in the county in 2007. Benton County 

has a total of 3 school districts with an enrollment of 3,988 students in 2007 (NCES, 2009). 

Transportation

DAEC is accessed by DAEC Road, which intersects with McClintock Road/Power Plant Road 

and terminates at Palo Marsh Road/County Road W36, which in turn links Interstate 380 to the 

north and continues southeast of Palo and terminates at an intersection with Interstate 380 in 

Cedar Rapids. Employees commuting from Cedar Rapids could take County Road W36 or take 

County Road E36 (also known as Blairs Ferry Road) (FPL-DA, 2008a), which has an 

interchange with Interstate 380 north of Cedar Rapids. Employees commuting from the north 

would also travel south on County Road W36. Employees from the west or southwest would 

travel to County Road E36 which intersects with County Road W36 in Palo. Those traveling 

from the northwest would travel to Interstate 380 and exit at the County Road W36 interchange 

(FPL-DA, 2008a). 

Of the road segments identified, traffic counts are only available for Interstate 380 at County 

Road E36 (Blairs Ferry Road) (28,800 annual average daily traffic trips) and County Road W36 

(F Avenue) (24,100 trips), both in Cedar Rapids (IDOT, 2006). Level of service (LOS) data, 

which describes operating conditions within a traffic stream and their perception by motorists, is 

available only for Interstate 380 in the northern Cedar Rapids metropolitan area (LOS C - stable 

flow, marking the beginning of the range of flow in which individual vehicle traffic is significantly 

affected by interaction with the traffic stream) and at the Blairs Ferry Road interchange 
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NUREG-1437, Supplement 42 2-40 October 2010 

(LOS D - high-density, stable flow in which speed and freedom to maneuver are severely 

restricted, where small increases in traffic will generally cause operational problems). 

The Linn County Regional Planning Commission’s (LCRPC) long-range transportation plan 

includes improvements to Interstate 380 and Blairs Ferry Road, although the planning area 

does not include DAEC (LCRPC, 2005). Benton County does not have a transportation plan. 

2.2.8.3 Offsite Land Use 

This section focuses on Linn and Benton counties because the majority of the permanent DAEC 

workforce (approximately 89 percent) live in these counties, and because DAEC pays property 

taxes in Linn County. 

Linn County is 717 mi2

 (458,180 ac) (LCRPC, 2003) and is primarily rural outside the Cedar 

Rapids metropolitan area. Urban area in Linn County comprises approximately 61,000 acres, or 

13 percent of the total acreage; the remaining 397,180 acres are unincorporated. Of the 

acreage located in the unincorporated areas, approximately 16 percent is either developed, 

considered public lands, or located in critical natural resource areas. The remaining 

303,958 acres are in agricultural use or woodlands (LCRPC, 2003). 

The LCRPC coordinates land use planning, zoning, transportation improvements, water and 

sewer systems, and other issues among the municipalities and in the Cedar Rapids 

metropolitan area (LCRPC, 2007). In addition, the City of Cedar Rapids has a comprehensive 

plan that addresses land use and other issues (Cedar Rapids, 1999). Linn County has a rural 

land use plan and map that provides the land use policy for the rural portions of the county. The 

plan is reviewed annually and is intended to serve as a guide for land use decision-making 

through the year 2020. 

Benton County covers 716 mi2

. Farm acreage totals approximately 400,000 acres (FPL-DA, 

2008a), about 87 percent of the total land area of the county. 

Benton County has a land preservation and use plan that provides the land use policy for the 

unincorporated areas of the county, ensuring the protection and preservation of agricultural land 

and other limited natural resources, while providing for growth in those areas that would be 

compatible with existing land uses and public facilities and services that are available (Benton 

County, 1986). The objectives of the plan are met through administration of the Benton County 

Agricultural Land Preservation Ordinance. The plan and ordinance are reviewed and amended 

from time-to-time by the Benton County Board of Supervisors (Benton County, 1994). 

2.2.8.4 Aesthetics and Noise 

A low-profile switchyard and substation are located to the west of the road to Palo. The 

turbine-generator building, control building, reactor building, administration building, pump 

house, and low-level radioactive waste building are co-located to form the main plant complex. 

An off-gas stack is located a few hundred feet south of the complex. Except for the off-gas 

stack, which rises to a height of 328 ft above ground, the 153-ft reactor building is the tallest 

onsite structure (AEC, 1973). 

Outer walls of all plant buildings consist of light buff-colored concrete. The upper area of the 

walls of the reactor and turbine-generator buildings is covered with light brown metal siding 

which has dark brown vertical stripes. The cooling towers are constructed with cedar and fir. 

All substation and switchyard equipment and supporting structures are painted light gray, and 
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October 2010 2-41 NUREG-1437, Supplement 42 

overhead aluminum conductors have a nonreflecting finish. Other areas of the site, which were 

disturbed during development and construction, have been largely restored and planted with 

grasses, shrubs, and trees. 

The three most significant noise sources associated with the plant are the cooling towers, 

transformers, and circuit breakers. 

The cooling towers have a source noise level of 138 decibels (dB). Persons visiting the Wickiup 

Conservation Area east of the plant, less than 1 mi across the river, would be subjected to an 

overall sound pressure level of about 55 dB from the cooling towers. The FES concluded that in 

no case will offsite sound levels from cooling tower operation be of such a magnitude as to 

cause actual hearing damage (AEC, 1973). 

A noise level of 89 db was associated with the transformers located in the turbine building and 

in the electrical power distribution substation located west of the plant. This noise level is much 

lower than the noise level at the cooling towers. Circuit breakers associated with the plant are 

air-operated and have a source noise level of 181 db. At the time of the FES, the applicant 

estimated that the breakers would operate approximately once per year, meaning that, although 

sound levels associated with circuit breaker operation are high, they would not result in a 

serious noise impact (AEC, 1973). 

Given the industrial nature of DAEC, noise emissions from the plant are generally nothing more 

than an intermittent minor nuisance. However, noise levels may occasionally exceed the 55 

dBA level that the U.S. Environmental Protection Agency (EPA) uses as a threshold level to 

protect against excess noise during outdoor activities. According to the EPA, this threshold 

does not constitute a standard, specification, or regulation, but was intended to provide a basis 

for State and local governments establishing noise standards. To date, no noise complaints 

associated with operations at DAEC have been reported from neighboring communities. 

2.2.8.5 Demography 

In 2000, approximately 210,081 persons lived within a 20-mi (32-km) radius of DAEC, which 

equates to a population density of 167 persons per m2

. This density translates to a Category 4 

(greater than or equal to 120 persons per m2

 within 20 mi) using the generic environmental 

impact statement (GEIS) measure of sparseness (FPL-DA, 2008a). At the same time, there 

were approximately 621,461 persons living within a 50-mi radius of the plant, for a density of 

79 persons per mi2

, meaning that DAEC falls into Category 3 (one or more cities with 100,000 or 

more persons and less than 190 persons per mi2

 within 50 mi (80 km)) on the NRC proximity 

scale. A Category 4 value for sparseness and a Category 3 value for proximity indicate that 

DAEC is in a high density population area. 

Table 2-9 shows population projections and growth rates from 1970 to 2050 in Linn and Benton 

counties. The growth rate in Linn County showed a decline of 0.6 percent for the period of 1980 

to 1990, but has grown, and is projected to grow, throughout the remainder of the period. A 

similar pattern of growth can be observed in Benton County, with a decline in population 

between 1980 and 1990, with population growth expected through 2040. 
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NUREG-1437, Supplement 42 2-42 October 2010 

Table 2-9. Population and Percent Growth in Linn and Benton Counties, Iowa, from 1970 

to 2000 and Projected for 2010 and 2040 

Year

Linn County Benton County 

Population Percent Growth(a) Population Percent Growth(a)

1970 163,213 — 22,885 — 

1980 169,775 4.0 23,649 3.3 

1990 168,767 -0.6 22,429 -5.2 

2000 191,701 13.6 25,308 12.8 

2010 211,489 10.3 26,815 6.0 

2020 231,345 9.4 27,846 3.8 

2030 252,057 9.0 28,980 4.1 

2040 273,054 8.3 30,142 4.0 

— = No data available. 

(a) Percent growth rate is calculated over the previous decade. 

Sources: Population data for 1970 through 1990 (USCB, 2009d); data for 2000 (USCB, 2009e); projected population 

data for 2010 to 2040 (State Library of Iowa, 2008). 

The 2000 demographic profile of the ROI population is included in Table 2-10. Persons 

self-designated as minority individuals comprise 5.5 percent of the total population. This 

minority population is composed largely of Black or African American and Asian residents. 
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October 2010 2-43 NUREG-1437, Supplement 42 

Table 2-10. Demographic Profile of the Population in the Duane Arnold Energy Center 

Region of Influence in 2000 

Linn 

County 

Percent of 

Total 

Population 

Benton 

County 

Percent of 

Total 

Population 

Region of 

Influence 

Percent of 

Total 

Population 

Total Population 191,701 100 25,308 100 217,009 100 

Race (2000) (percent of total population, Not-Hispanic or Latino) 

White 179,999 93.9 25,015 98.8 205,014 94.5 

Black or African American 4,919 2.6 51 0.2 4,970 2.3 

American Indian and 

Alaska Native 

418 0.2 37 0.1 455 0.2 

Asian 2,634 1.4 43 0.2 2,677 1.2 

Native Hawaiian and Other 

Pacific Islander 

91 0.0 4 0.0 95 0.0 

Some other race 881 1.5 27 0.1 908 0.4 

Two or more races 2,759 1.4 131 0.5 2,890 1.3 

Ethnicity 

Hispanic or Latino 2,722 1.4 156 0.6 2,878 1.3 

Minority Population (including Hispanic or Latino ethnicity) 

Total minority population 11,702 6.1 293 1.2 11,995 5.5 

Source: USCB, 2009f 

Transient Population

Within 50 mi (80 km) of DAEC, colleges and recreational opportunities attract daily and 

seasonal visitors who create demand for temporary housing and services in some counties 

within 50 mi of the plant. In 2000 in Linn County, 0.6 percent of all housing units were 

considered temporary housing for seasonal, recreational, or occasional use, while temporary 

housing accounted for only 1.2 percent of total housing units in Benton County. In 2007, there 

were 18,480 students attending colleges and universities within 50 mi (80 km) of DAEC. 
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NUREG-1437, Supplement 42 2-44 October 2010 

Table 2-11. Seasonal Housing within 50 Miles of Duane Arnold Energy Center, 2000 

County (a) Number of Housing Units

Vacant Housing Units for 

Seasonal, Recreational or 

Occasional Use Percent 

Clayton 8,619 717 8.3 

Poweshiek 8,556 637 7.4 

Delaware 7,682 465 6.0 

Jackson 8,949 415 4.6 

Louisa 5,133 284 1.7 

Others 338,617 2,020 0.6 

Total 377,556 4,538 1.2 

 (a) Counties within 50 mi of DAEC with at least one block group located within the 50-mi radius 

Source: USCB, 2009c 

Migrant Farm Workers

Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

crops. These workers may or may not have a permanent residence. Some migrant workers 

may follow the harvesting of crops, particularly fruit, throughout the northeastern U.S. rural 

areas. Others may be permanent residents near DAEC who travel from farm to farm harvesting 

crops. 

Migrant workers may be members of minority or low-income populations. Because they travel 

and can spend a significant amount of time in an area without being actual residents, migrant 

workers may be unavailable for counting by census takers. If uncounted, these workers would 

be “underrepresented” in U.S. Census Bureau (USCB) minority and low-income population 

counts. 

The 2007 Census of Agriculture collected information on migrant farm and temporary labor. 

Table 2-12 provides information on migrant farm workers and temporary (less than 150 days) 

farm labor within 50 mi of DAEC. According to 2007 Census of Agriculture estimates, Linn 

County hosts relatively small numbers of migrant workers, with 482 temporary farm laborers 

employed on 211 farms in the county (USDA, 2009). The county with the most temporary farm 

workers within 50 mi of DAEC was Johnson County with 1,240 workers on 253 farms. 
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October 2010 2-45 NUREG-1437, Supplement 42 

Table 2-12. Migrant Farm Worker and Temporary Farm Labor within 50 Miles of Duane 

Arnold Energy Center 

County(a)

Number of Farm 

Workers Working for 

Less that 150 Days 

Number of Farms 

Hiring Workers for 

Less than 150 Days 

Number of Farms 

Reporting Migrant 

Farm Labor 

Number of Farms 

with Hired Farm 

Labor 

Johnson 1,240 253 4 319 

Fayette 1,101 359 4 420 

Clinton 1,021 341 1 411 

Dubuque 865 295 4 395 

Delaware 855 327 6 444 

Others 7,249 4,106 23 4,321 

Total 12,331 5,681 42 6,310 

 (a) Counties within 50 mi of DAEC with at least one block group located within the 50-mi radius 

Source: USDA, 2009 

2.2.8.6 Economy 

This section contains a discussion of the economy, including employment and income, 

unemployment, and taxes. 

Employment and Income

Between 2000 and 2008, the civilian labor force in the Linn County area grew at an annual 

average rate of 0.9 percent to 120,241 (USDOL, 2009). The civilian labor force in the Benton 

County area grew at an annual rate of 0.7 percent to the 2008 level of 14,501. 

In 2006, manufacturing, retail, health care, and social assistance employment represented the 

largest sector of employment in both counties, followed by accommodation and food services 

(USCB, 2009g). The largest employer in Linn County in 2006 was Rockwell Collins with 

7,300 employees (Table 2-13). The majority of employment in Linn County is located in the city 

of Cedar Rapids. 
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NUREG-1437, Supplement 42 2-46 October 2010 

Table 2-13. Major Employers in Linn County 

Firm Number of Employees 

Rockwell Collins 7,300 

Cedar Rapids Community School District 2,800 

AEGON USA 2,600 

St. Luke’s Hospital 2,400 

Maytag Appliances 2,200 

Mercy Medical Center 2,060 

Hy-Vee Food Stores 2,044 

MCI 1,528 

City of Cedar Rapids 1,493 

Kirkwood Community College 1,443 

McLeod USA 1,361 

Alliant Energy-Interstate Power and Light 1,100 

Quaker Foods 1,100 

Source: Cedar Rapids Area Chamber of Commerce, undated 

Income information for the DAEC ROI is included in Table 2-14. There are slight differences in 

the income levels between the two counties. The median household and per capita incomes in 

Linn and Benton counties were higher than the Iowa average. Only 9.9 percent of the 

population in Linn County was living below the official poverty level, while in Benton County, 

7.2 percent of the population was below the poverty level. 

Table 2-14. Income Information for the Duane Arnold Energy Center Region of Influence, 

2007 

Linn County Benton County Iowa 

Median household income (dollars) 53,076 54,417 47,324 

Per capita income (dollars) 38,419 32,419 34,916 

Percent of persons below the poverty line 9.9 7.2 11.0 

Source: USCB, 2009g; USCB, 2009h 

Unemployment

In 2008, the annual unemployment average in Linn and Benton counties was 4 and 4.1 percent, 

respectively, which was similar to the annual unemployment average of 4.1 percent for Iowa 

(USDOL, 2009). 

Taxes

The owners of DAEC pay annual property taxes to Linn County. A portion of the total is 

retained for county operations, including public safety and legal services, physical health and 

social services, mental health services, roads and transportation, administration, and other 
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October 2010 2-47 NUREG-1437, Supplement 42 

expenses. Linn County forwards the remainder of the collected tax revenue to the townships, 

school districts, cities, and other taxing authorities in the county. 

During 2005 through 2008, Linn County collected approximately $236 to $262 million annually in 

property taxes (Table 2-15). DAEC’s property tax payments during this period represented 0.3 

to 0.4 percent of the total property tax revenues collected in the county. The sale of DAEC by 

Alliant Energy to Nextera Energy in 2006 resulted in a reassessment of the valuation of the 

plant, and consequently the amount of property tax paid by the plant to the county. Linn County 

retained $35 to $41 million dollars each year for its operations over the period 2002 to 2006, 

with tax payments made by DAEC constituting less than 1 percent of Linn County’s total 

operational costs. More than 50 percent of DAEC tax payments go to Cedar Rapids Community 

School District, which had expenditures of $159.1 million during 2006–2007 (NCES, 2009). 

Table 2-15. Property Tax Revenues in Linn County, 2005 to 2008; Florida Power and 

Light Property Tax, 2005 to 2008; and Florida Power and Light Property Tax as a 

Percentage of Total Property Tax Revenues in Linn County 

Year

Total Property Tax Revenues in Linn 

County 

(in millions of dollars, 2006) 

Property Tax Paid by FPL 

(in millions of dollars, 

2006)(a)

FPL Property Tax as 

Percentage of Total Property 

Tax Revenues in Linn 

County(a)

2005 236.0 603.2 0.3 

2006 245.3 1,049.2 0.4 

2007 259.3 1,135.5 0.4 

2008 261.6 844.9 0.3 

(a) Includes property taxes paid to all jurisdictions in Linn County 

Source: FPL-DA, 2008a 

In 1998, the Iowa Legislature established the “Deregulation and Restructuring of the Electric 

Utility Industry Study Committee” to review restructuring activities and experiences in other 

States, and at that time, the Committee did not make any formal recommendations. In 1999, 

the Iowa Utilities Board undertook an extensive study of electricity restructuring and issued a 

number of reports. In 2000, bills related to the restructuring of the electric utility industry were 

introduced to the Iowa General Assembly in the legislative session, although the legislative 

session ended with no further action on the bills. Currently, there has been no new action on 

the status of deregulating the electric power industry in Iowa (FEMP, 2006). Should 

deregulation ever be enacted in Iowa, this could affect utilities’ tax payments to counties; 

however, any changes to DAEC property tax rates due to deregulation would be independent of 

license renewal. 

The continued availability of DAEC and the associated tax base is an important feature in the 

ability of Linn County communities to continue to invest in infrastructure and to draw industry 

and new residents. 
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NUREG-1437, Supplement 42 2-48 October 2010 

2.2.9 Historic and Archaeological Resources 

This section discusses the cultural background and the known historic and archaeological 

resources at DAEC and surrounding areas. 

2.2.9.1 Cultural Background 

As indicated earlier, DAEC is located in eastern Iowa along the Cedar River. Archaeological 

evidence from all major prehistoric periods and the historic period has been found in the vicinity 

of the plant. There are 75 properties listed on the National Register of Historic Places (NRHP) 

in Linn County, Iowa. Three of the NRHP sites are within 10 mi of DAEC. Two of the sites are 

bridges and the third is the Taylor Van Note Building in Cedar Rapids. The Wickiup Hill Outdoor 

Learning Area, located across the Cedar River from DAEC, has several Native American 

mounds on the property. There are more than 40 known archaeological sites located within 

1 mi of DAEC (Louis Berger Group, Inc., 2008). 

The earliest evidence for people in Iowa dates to the Paleo Indian period (11,500 B.C. to 

8,500 B.C.). The Paleo Indian period occurred as the ice sheets that once covered North 

America were retreating. Climate during the Paleo Indian period was much cooler and wetter 

than today. Paleo Indians lived a nomadic lifestyle focused on hunting large game. Fluted 

spear points are the most common artifact found associated with the Paleo Indian cultures, such 

as Clovis or Folsom. Most Paleo Indian finds in Iowa consist of surface finds of isolated 

projectile points (Alex, 2000). 

The Archaic Period (8,500 B.C. to 800 B.C.) is defined by changes in technology from primarily 

large fluted points to smaller spear and dart points and grinding stones for processing plants. 

The intensification of resource use is seen as the result of increased population. During the 

Archaic period, the land cover transformed from wooded to the tall grass prairie of today. The 

transformation took most of the 7,700 years encompassed by the period and spread from west 

to east. The very long Archaic Period is commonly divided into an Early (8,500 B.C to 

5,500 B.C.), Middle (5,500 B.C. to 3,000 B.C.) and Late Period (3,000 B.C. to 800 B.C.). 

Climate during the Archaic Period underwent significant alterations with the Middle Period being 

extremely dry. Changes in technology accelerated during the Archaic Period. Projectile point 

types proliferate during the Archaic Period. The atlatl, a notched wood stick which increases the 

throwing velocity of a spear, became widespread and the first evidence of dogs being kept also 

comes from the Archaic Period. 

The Woodland Period is often divided into an Early (800 B.C. to 200 B.C.), Middle (200 B.C. to 

A.D. 300), and Late (A.D. 300 to A.D. 1250). Hallmarks of the Woodland Period are pottery, the 

burial mound, and horticulture mainly involving corn. The change to horticulture in the Late 

Woodland Period resulted in several changes to Native American societies. A horticultural 

tradition allows for a more predictable food supply but ties a population to specific locations. 

Burial mounds are a visible remnant of the Woodland Period. There are two types of mounds: 

burial and effigy. Large numbers of mounds and mound groups are found throughout the 

Midwest. 

The final prehistoric period known near the project area is the Oneota (c. A.D. 1250 to 1700s). 

The Oneota relied on an agriculture based on corn, beans, and squash, as well as seasonal 

hunting of small and large game and seasonal plant harvesting. Pottery styles and distinctive 

stone tools are hallmarks of the culture. Oneota sites usually contain numerous storage pits, 

multiple structures which can be of various construction types, and show evidence of 

reoccupation over time. Carved catlinite pipes and tablets are also indicative of Oneota culture. 
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October 2010 2-49 NUREG-1437, Supplement 42 

When the first Europeans entered Iowa, there were roughly 18 distinct groups living in the State. 

These groups were the Ioway, Oto, Winnebago, Omaha, Ottawa, Huron, Miami, Kitchigami, 

Mascouten, Chippewa, Sauk, Mequaki, Potowatomi, Pawnee, Santee, Yankton, Moingwena, 

and Peoria (Alex, 2000). Many of these groups were originally from the eastern States and 

Canada but had been removed to the West in the face of European expansion. Through a 

series of treaties and constant Euro-American settlement, most Native Americans were 

removed from Iowa by the middle of the 19th century. The only group that retains any land in 

the State is the Meskwakie. It is recognized by the Federal government as the Sac and Fox 

Tribe of the Mississippi in Iowa. 

The first historic contact between Native Americans and Europeans within modern Iowa was 

when Father Jacques Marquette and Louis Joliet traveled down the Mississippi in 1673 

(Schweider, 2009). In 1832, a group of Sauk Indians under Black Hawk resisted removal from 

northern Illinois. The group was eventually removed by mid-1832 in what was called the Black 

Hawk War. The Black Hawk Treaty of 1832, which ended the resistance, ceded the eastern 

portion of Iowa to Euro-American settlement. Linn County was created in 1837 as part of the 

Territory of Wisconsin. The county seat for Linn County is Marion. The first settler in Linn 

County arrived in 1839 (Brewer and Wick, 1911). Iowa became a State in December 1846, and 

railroads began crossing the State in the 1850s. With the coming of the railroads, Iowa became 

connected to the markets in Chicago. The primary products produced in Linn County were 

cattle and dairy products. By 1870, there were five railroad lines that crossed Iowa. 

The area near the DAEC was originally settled as farmland. The first farmers grew corn and 

wheat and conducted subsistence farming. Some pigs and sheep were raised. Maple sugaring 

was also common, following the practices established by Native Americans. The town of Palo 

was established in 1854 (Rogers and Page, 1993). The town contained a blacksmith and 

sawmill. The economy of the region changed to cattle and dairying by the 1870s. During the 

20th century, many of the farms were consolidated under large landowners. The consolidation 

of farm land continues to be present. Another industry occurring in the vicinity of Palo was 

limestone quarrying. There were eight quarries operating near Palo in the 1960s. 

2.2.9.2 Historic and Archaeological Resources 

Four archaeological sites are known to exist on the DAEC property. The sites 13LN362, 

13LN363, 13LN365, and 13LN366 were first identified in 1993 during a survey of the region 

(Rogers and Page, 1993). All four sites date to the late 19th century and are the remains of 

farmsteads. All but 13LN362 were recommended as potentially eligible for listing on the NRHP. 

The official status of all sites on the DAEC property is unevaluated. Additional investigations 

are necessary for a formal evaluation. A 2008 archival study of the DAEC property identified 

five locations that have the potential to contain archaeological remains. The locations are 

associated with historic era farmsteads and a platted town site that appear on historic maps of 

the area (Louis Berger Group, Inc., 2008). The locations identified in the report have not been 

investigated; therefore, it remains unknown if subsurface remains exist. 

Site 13LN362 is an artifact scatter associated with J. Craya who was reported as living in the 

location in 1859. There is some discrepancy in the location of the artifacts and the reported 

farm location (Louis Berger Group, Inc., 2008). 

Site 13LN363 is the remains of a farmstead originally belonging to a John H. Ray. The 

farmstead first appears on an 1875 map of Linn County. The farm also appears on maps from 

1907 and 1921, but was then associated with a Jonathon McClintock. The site does not appear 

on 1934 aerial photographs. A limestone foundation is still visible at the site. 
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NUREG-1437, Supplement 42 2-50 October 2010 

Site 13LN365 is a farmstead that is first associated with a Sarah McClintock in 1895. The 

farmstead appears on later maps (1907, 1914, and 1921) associated with Jonathan McClintock. 

The site, consisting of nine structures, appears in aerial photographs from 1934 and 1939. The 

nine structures also appear in a 1970 aerial photograph. The structures had been removed by 

the 1980s. No surface features were noted at the site in 1993. 

The final known site on the DAEC property is 13LN366. The site consists of a historic artifact 

scatter. No farms or structures appear in this location on any historic maps or aerial 

photographs of the region. 

Transmission Lines

There are roughly 101 mi of transmission line associated with the DAEC (FPL-DA, 2008a) (see 

Figure 2-7). A review of files at the Iowa Office of the State Archaeologist identified that there 

are 12 archaeological sites located in the ROW of the transmission lines associated with DAEC. 

The archaeological sites are listed in Table 2-16. Because the transmission lines were 

constructed prior to passage of the National Historic Preservation Act (NHPA), no historic and 

archaeological surveys were undertaken for the transmission lines. The resources listed were 

identified through surveys conducted for various highway projects and Section 106 compliance 

projects. The transmission lines are owned and maintained by ITC. 

Table 2-16. Historic and Archaeological Sites in the Duane Arnold Energy Center 

Associated Transmission Lines 

Site Name Cultural Affiliation NRHP Status 

13LN81 Prehistoric Unevaluated 

13LN88 Woodland Unevaluated 

13LN139 Prehistoric/Historic Unevaluated 

13LN141 Prehistoric Unevaluated 

13LN167 Prehistoric Unevaluated 

13LN173 Prehistoric Unevaluated 

13LN183 Prehistoric Unevaluated 

13LN228 Prehistoric Unevaluated 

13LN362 Historic Unevaluated 

13LN380 Historic Unevaluated 

13LN465 Prehistoric Unevaluated 

13LN810 Historic Unevaluated 

2.3 RELATED FEDERAL AND STATE ACTIVITIES 

The Staff reviewed the possibility that activities of other Federal agencies might impact the 

renewal of the operating license for DAEC. Any such activity could result in cumulative 

environmental impacts and the possible need for a Federal agency to become a cooperating 

agency in the preparation of the DAEC SEIS. 

There are no known Federal facilities within 50 mi of DAEC. The Staff has determined that 

there are no Federal projects that would make it desirable for another Federal agency to 
Affected Environment 

October 2010 2-51 NUREG-1437, Supplement 42 

become a cooperating agency in the preparation of the SEIS. Parks and wilderness areas 

located near the DAEC are listed below: 

● Pleasant Creek State Recreation Area 

● Palo Marsh Wildlife Refuge 

● Wickiup Hill Outdoor Learning Area 

The NRC is required under Section 102(2)(c) of the NEPA to consult with and obtain the 

comments of any Federal agency that has jurisdiction by law or special expertise with respect to 

any environmental impact involved. The NRC has consulted with the American Council on 

Historic Preservation and the USFWS. Federal agency consultation correspondence and 

comments on the SEIS are presented in Appendix D. 

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00-4194. Available URL: http://pubs.usgs.gov/wri/2000/wri004194/pdf/wri00_4194.pdf

(accessed April 24, 2009). 

University of Iowa (UI). 1990. “Testing of Bottled Waters Sold in Iowa,” UHL Hygienic 

Laboratory, August 30, 1990. Available URL: 

http://www.uhl.uiowa.edu/publications/archive/research/bottledWater.xml (Accessed May 17, 

2010). 

U.S. Atomic Energy Commission (AEC). 1973. “Final Environmental Statement Related to the 

Operation of Duane Arnold Energy Center,” Iowa Electric Light and Power Company, et al. 

Docket No. 50-331, Directorate of Licensing, Washington, D.C., March 1973, ADAMS 

Accession No. ML091200609. 

U.S. Bureau of the Census (USCB). 2009a. “QT-H1 General Housing Characteristics: 2000.” 

Available URL: 

http://factfinder.census.gov/servlet/QTTable?_bm=y&-context=qt&-qr_name=DEC_2000_SF1_

U_QTH1&-ds_name=DEC_2000_SF1_U&-tree_id=4001&-redoLog=true&-all_geo_types=N&-_

caller=geoselect&-geo_id=05000US12017&-search_results=01000US&-format=&-_lang=en. 

U.S. Bureau of the Census (USCB). 2009b. “QT-H14: Value, Mortgage Status, and Selected 

Conditions: 2000.” Available URL: 

http://factfinder.census.gov/servlet/QTTable?_bm=y&-context=qt&-qr_name=DEC_2000_SF3_

U_QTH14&-ds_name=DEC_2000_SF3_U&-tree_id=403&-redoLog=true&-all_geo_types=N&-_

caller=geoselect&-geo_id=05000US12017&-search_results=01000US&-format=&-_lang=en. 

U.S. Bureau of the Census (USCB). 2009c. 2007 American Community Survey. Available 

URL: 

http://factfinder.census.gov/servlet/STTable?_bm=y&-context=st&-qr_name=ACS_2007_3YR_

G00_S2504&-ds_name=ACS_2007_3YR_G00_&-tree_id=3307&-redoLog=true&-_caller=geose

lect&-geo_id=05000US12017&-format=&-_lang=en. 

U.S. Bureau of the Census (USCB). 2009d. “IOWA: Population of Counties by Decennial 

Census: 1900 to 1990.” Available URL: 

http://www.census.gov/population/www/censusdata/cencounts/files/ia190090.txt. 

U.S. Bureau of the Census (USCB). 2009e. American Fact Finder. Available URL: 

http://factfinder.census.gov/. 

U.S. Bureau of the Census (USCB). 2009f. “QT-P3 Race and Hispanic or Latino: 2000.” 

Available URL: 

http://factfinder.census.gov/servlet/QT,.?_bm=y&-context=qt&-qr_name=DEC_2000_SF1_U_Q

TP3&-ds_name=DEC_2000_SF1_U&-tree_id=4001&-redoLog=true&-all_geo_types=N&-_caller

=geoselect&-geo_id=05000US12017&-search_results=01000US&-format=&-_lang=en. 

U.S. Bureau of the Census (USCB). 2009g. “State and County Quickfacts – Linn County, 

Iowa.” Available URL: http://quickfacts.census.gov/qfd/states/19/19113.html. 

U.S. Bureau of the Census (USCB). 2009h. “State and County Quickfacts – Benton County, 

Iowa.” Available URL: http://quickfacts.census.gov/qfd/states/19/19011.html. 
Affected Environment 

NUREG-1437, Supplement 42 2-60 October 2010 

U.S. Department of Agriculture (USDA). 2009. 2007 Census of Agriculture, “Table 7. Hired 

Farm Labor - Workers and Payroll: 2007.” Available URL: 

http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_L

evel/Florida/st12_2_007_007.pdf. 

U.S. Department of Labor (USDOL). 2009. “Local Area Unemployment Statistics.” Available 

URL: http://www.bls.gov/lau/#tables. 

U.S. Fish and Wildlife Service (USFWS). 2000. “Threatened and Endangered Species: Prairie 

Bush Clover (Lespedeza leptostachya).” Available URL: 

http://www.fws.gov/midwest/endangered/plants/pdf/lelefctsht.pdf (accessed April 22, 2009). 

U.S. Fish and Wildlife Service (USFWS). 2004. “Prairie Fringed Orchids Fact Sheet.” 

Available URL: http://www.fws.gov/midwest/endangered/plants/prairief.html (accessed April 22, 

2009). 

U.S. Fish and Wildlife Service (USFWS). 2007a. Letter from R. Nelson, Field Supervisor, U.S. 

Fish and Wildlife Service, to G. Middlesworth, Vice President, FPL Energy Duane Arnold, LLC, 

Subject: “Response to request for information about impacts to species from license renewal 

project,” July 3, 2007, ADAMS Accession No. ML082980483. 

U.S. Fish and Wildlife Service (USFWS). 2007b. “National Bald Eagle Management 

Guidelines.” Available URL: 

http://www.fws.gov/pacific/eagle/NationalBaldEagleManagementGuidelines.pdf (accessed May 

12, 2009). 

U.S. Fish and Wildlife Service (USFWS). 2008. “Iowa County Distribution of Federally 

Threatened, Endangered, Proposed and Candidate Species.” Available URL: 

http://www.fws.gov/Midwest/Endangered/LISTS/iowa_cty.html (accessed April 3, 2009). 

U.S. Fish and Wildlife Service (USFWS). 2009a. Federal Fish and Wildlife Permit 

No. MB160836-0 for Depredation of Turkey Vultures, April 1, 2009. 

U.S. Fish and Wildlife Service (USFWS). 2009b. Letter from R. Nelson, Field Supervisor, Rock 

Island Field Office, to D. Pelton, Branch Chief, Division of License Renewal, Subject: “Response 

to letter requesting a list of protected species within the area under evaluation for the Duane 

Arnold Energy Center license renewal application,” May 29, 2009, ADAMS Accession 

No. ML092020070. 

U.S. Geological Survey (USGS). 2008. “Water-Data Report 2008 for 05464500 Cedar River at 

Cedar Rapids, IA.” Available URL: http://wdr.water.usgs.gov/wy2008/pdfs/05464500.2008.pdf

(accessed June 3, 2009). 
October 2010 3-1 NUREG-1437, Supplement 42 

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 

License renewal actions include refurbishment actions 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. If such actions were planned, the potential environmental 

effects of refurbishment actions would be identified and the analysis would be summarized 

within this section. 

Environmental issues associated with refurbishment activities are discussed in the Generic 

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

Volumes 1 and 2 (U.S. Nuclear Regulatory Commission (NRC) 1996; 1999).1

 The GEIS 

includes a determination of whether or not the analysis of the environmental issues can be 

applied to all plants and whether or not additional mitigation measures are warranted. Issues 

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

Category1 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 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, an additional plant-specific review of these issues is 

required. Environmental issues associated with refurbishment, which were determined to be 

Category 1 and Category 2 issues, are listed in Tables 3-1 and 3-2, respectively. 

Requirements for the renewal of operating licenses for nuclear power plants include the 

preparation of an integrated plant assessment (IPA) pursuant to Section 54.21 of Title 10 of the 

Code of Federal Regulations (CFR). The IPA must identify and list systems, structures, and 

components subject to an aging management review. The GEIS (NRC, 1996) provides helpful 

information on the scope and preparation of refurbishment activities to be evaluated. 

Environmental resource categories to be evaluated for impacts of refurbishment include 

terrestrial resources, threatened and endangered species, air quality, housing, public utilities 

and water supply, education, land use, transportation, and historic and archaeological 

resources. Items that are subject to aging and might require refurbishment include, for 

example, the reactor vessel piping, supports, and pump casings (see 10 CFR 54.21 for details), 

as well as items that are not subject to periodic replacement. 

 

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

to the GEIS include the GEIS and its Addendum 1. 
Environmental Impacts of Refurbishment 

NUREG-1437, Supplement 42 3-2 October 2010 

FPL Energy Duane Arnold, LLC (FPL-DA) performed an IPA on Duane Arnold Energy Center 

(DAEC) pursuant to 10 CFR 54.21. This assessment did not identify the need to undertake any 

major refurbishment or replacement actions to maintain the functionality of important systems, 

structures, and components during the DAEC license renewal period or other facility 

modifications associated with license renewal that would affect the environment or plant 

effluents (FPL-DA, 2008); therefore, an assessment of refurbishment activities is not considered 

in this SEIS. 

Table 3-1. Category 1 Issues for Refurbishment Evaluation 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 

Surface Water Quality, Hydrology, and Use (for all plants) 

Impacts of refurbishment on surface water quality 3.4.1 

Impacts of refurbishment on surface water use 3.4.1 

Aquatic Ecology (for all plants) 

Refurbishment 3.5 

Groundwater Use and Quality 

Impacts of refurbishment on groundwater use and quality 3.4.2 

Land Use 

Onsite land use 3.2 

Human Health 

Radiation exposures to the public during refurbishment 3.8.1 

Occupational radiation exposures during refurbishment 3.8.2 

Socioeconomics 

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 

3.7.4.4; 3.7.4.6 

Aesthetic impacts (refurbishment) 3.7.8 
Environmental Impacts of Refurbishment 

October 2010 3-3 NUREG-1437, Supplement 42 

Table 3-2. Category 2 Issues for Refurbishment Evaluation 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 

10 CFR 51.53 

(c)(3)(ii) 

Subparagraph 

Terrestrial Resources 

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 (nonattainment and maintenance areas) 3.3 F 

Socioeconomics 

Housing impacts 3.7.2 I 

Public services: public utilities 3.7.4.5 I 

Public services: education (refurbishment) 3.7.4.1 I 

Offsite land use (refurbishment) 3.7.5 I 

Public services: transportation 3.7.4.2 J 

Historic and archaeological resources 3.7.7 K 

Environmental Justice 

Environmental justice Not addressed(a) Not addressed(a)

(a) Guidance related to environmental justice was not in place at the time the NRC prepared the GEIS and the 

associated revision to 10 CFR Part 51. If an applicant plans to undertake refurbishment activities for license 

renewal, the applicant’s ER and NRC staff’s environmental impact statement must address environmental 

justice. 

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.” 

NUREG-1437, Supplement 33 3-4 August 2008. 

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

Renewal of Operating Licenses for Nuclear Power Plants.” 

Florida Power and Light Energy Duane Arnold (FPL-DA). 2008. Duane Arnold Energy Center, 

License Renewal Application, Appendix E – Applicant’s Environmental Report – Operating 

License Renewal Stage, Duane Arnold Energy Center, September 2008. (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML082980481) 

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

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

Regulatory Research, Washington, D.C. (ADAMS Accession Nos. ML040690705 and 

ML040690738) 

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

for License Renewal of Nuclear Plant, NUREG-1437, Volume 1, Addendum 1, Office of Nuclear 

Reactor Regulation, Washington, D.C. 

October 2010 4-1 NUREG-1437, Supplement 42 

4.0 ENVIRONMENTAL IMPACTS OF OPERATION 

Chapter 4 investigates potential environmental impacts related to the period of extended 

operation of Duane Arnold Energy Center (DAEC). These impacts are grouped and presented 

according to resource. Generic issues (Category 1) rely on the analysis provided in the Generic 

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

by the U.S. Nuclear Regulatory Commission (NRC) and are discussed briefly (NRC, 1996; 

1999a). The NRC staff (Staff) has also analyzed site-specific issues (Category 2) for DAEC and 

assigned them a significance level (e.g., SMALL, MODERATE, or LARGE). Some remaining 

site characteristics or plant feature issues are not applicable to DAEC. Section 1.4 of this report 

explains the criteria for Category 1 and Category 2 issues and defines the impact designations 

of SMALL, MODERATE, and LARGE. The issue of waste management is discussed in Chapter 

6. 

4.1 LAND USE 

Land use issues are listed in Table 4-1. The Staff did not identify any Category 2 issues for 

onsite land use and did not identify any new and significant information during the review of the 

environmental report (ER) (FPL Energy Duane Arnold, LLC (FPL-DA), 2008a), the site audit, or 

the public scoping process; therefore, there are no impacts related to these issues beyond 

those discussed in the GEIS. Consistent with the GEIS, the Staff concludes that the impacts 

are SMALL and additional site-specific mitigation measures are unlikely to be warranted. 

Table 4-1. Category 1 Issues Applicable to Onsite Land Use during the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

Onsite land use 

Onsite land use 4.5.3.1 

Power line right-of-way 4.5.3.1 

4.2 AIR QUALITY 

DAEC is a minor source with respect to its potential to emit (PTE) criteria pollutants or 

hazardous air pollutants (HAPs). As a result, DAEC is not required to secure a Title V permit for 

all stationary sources of air pollution. However, DAEC is nevertheless obligated to obtain and 

maintain permits to construct and operate certain stationary sources from the Linn County 

Public Health Department (LCPH) in accordance with Linn County Code of Ordinances (LCCO) 

#1-2-2005, Chapter 10, Section 10.5, Locally Required Permits. Permits (and respective permit 

numbers) are currently in place for the following stationary sources of criteria pollutants, which 

include: auxiliary boiler, diesel engines, a diesel generator, and underground tanks (LCPH, 

2005a through h). A waiver from permitting requirements was secured for a temporary boiler in 

2008 (LCPH, 2008). 

DAEC reports annually on the operation of its permitted sources (FPL-DA, 2009a), (FPL-DA, 

2008b), (FPL-DA, 2007a), (FPL-DA, 2006b), (FPL-DA, 2005a). All reports for the last 5 years 

indicated no violation of permit conditions. No open burning takes place on the DAEC site. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-2 October 2010 

Emergency generators are enrolled in preventative maintenance programs that involve monthly 

operation (FPL-DA, 2009a), (FPL-DA, 2009b). DAEC collects all used lubricating and hydraulic 

oils from internal combustion engines; compressors; hydraulic systems; heating, ventilation, and 

air conditioning (HVAC) vacuum pumps; and other miscellaneous equipment and recovered 

off-specification diesel fuels and provides them to an offsite contractor for recycling. DAEC 

does not recycle used oils or off-specification fuels on site or burn them on site for energy 

recovery. 

Internal procedures are in place to ensure proper management of refrigerants present in HVAC 

equipment and in industrial chillers and coolers, as well as evaluating HVAC compressor oils for 

possible radioactivity when they are removed from systems where airborne radioactivity is 

possible. 

Table 4-2 lists the air quality issue applicable to DAEC. The Staff did not identify any 

Category 2 issues for air quality. The Staff also did not identify any new and significant 

information during the review of the applicant’s ER (FPL-DA, 2008a), the site audit, or the 

scoping process; therefore, there are no impacts related to this issue beyond those discussed in 

the GEIS. Consistent with the GEIS, the Staff, therefore, concludes that the impacts are 

SMALL, and additional site-specific mitigation measures are unlikely to be warranted. 

Table 4-2. Air Quality Issue. Section 2.2.2 of this report describes air quality in the 

vicinity of DAEC. 

Issue GEIS Section Category 

Air quality effects of transmission lines 4.5.2 1 

4.3 GROUNDWATER 

The Category 2 groundwater issues applicable to DAEC are discussed below and listed in 

Table 4-3. There were no Category 1 issues related to the DAEC site. 

Table 4-3. Groundwater Use and Quality Issues. Groundwater use and quality at DAEC are 

discussed in Section 2.2.3. 

Issues GEIS Sections Category 

Groundwater use conflicts (potable and service water, and dewatering 

plants that use >100 gallons per minute (gpm)) 4.8.1.1, 4.8.2.1 2 

Groundwater use conflicts (plants using cooling towers withdrawing 

makeup water from a small river) 4.8.1.3, 4.4.2.1 2 

4.3.1 Generic Groundwater Issues 

Discussions during the site visit revealed several incidents, which had the potential to cause 

groundwater contamination. These include a diesel line break and several sulphuric acid tank 

leaks, which were contained. During the most recent dredging, a few gallons of diesel fuel were 

spilled into the Cedar River. Cleanup was directed toward removing the sheen at the surface of 

a backwater (water backed up in its course by an obstruction). In 1983, a 30 gallon barrel (114 

L) of condensate water was spilled and flowed into the storm sewer (FPL-DA, 2006c). The 

applicant has stated “there have been no identified instances of radioactivity released from the 

DAEC that resulted in groundwater concentrations exceeding the allowable Environmental 

Protection Agency (EPA) maximum contaminant levels for drinking water” (FPL-DA, 2006c). 
Environmental Impacts of Operation 

October 2010 4-3 NUREG-1437, Supplement 42 

The National Pollutant Discharge Elimination System (NPDES) application (FPL-DA, 2008c) 

describes several releases in the prior 3 years. These include a July 2006 sulphuric acid tank 

leak of approximately 1,000 gallons (3,800 L) into a concrete containment berm. Only a few 

gallons were not contained. In September 2007, some petroleum-contaminated soil was 

discovered beneath a concrete structure. The soil was excavated and disposed offsite. 

The potential impact to groundwater from the incidents described above is considered low 

because of the volume and type of contaminants and the mitigation measures taken in each 

instance. The Staff did not identify any new and significant information regarding Category 1 

issues during the review of DAEC’s ER (FPL-DA, 2008a), the site visit, or during the public 

scoping process. The Staff also evaluated and reviewed various permits, assorted applicant 

files, radiological environmental monitoring program (REMP) reports, and other sources of 

information. There are no impacts related to these issues beyond those discussed in the GEIS. 

The GEIS concluded that the impacts are SMALL, and additional site-specific mitigation 

measures are unlikely to be warranted. 

4.3.2 Groundwater Use Conflicts (Plants That Use More Than 100 Gallons (378 Liters 

Per Minute) 

For potential groundwater use conflicts, NRC specifies in Table B-1 of Part 51 of Title 10 of the 

Code of Federal Regulations (10 CFR Part 51), Subpart A, Appendix B, that, “plants that use 

more than 100 gpm, may cause ground-water use conflicts with nearby ground-water users”. 

The NRC further states that “if the applicant’s plant uses more than 100 gallons (total onsite) of 

groundwater per minute (gpm), an assessment of the impact of groundwater use must be 

provided” (10 CFR 51.53(c)(3)(ii)(C)). This applies to DAEC because, as discussed in Section 

2.1.6 of this report, DAEC uses over 1,500 gpm (5,700 LPM) of groundwater. 

The DAEC pumps groundwater from four production wells on a schedule that normally involves 

one or two wells pumping at a time. Approximately 1,400 gpm (5,300 lpm) are sent to an air 

cooling system, 100 gpm (378 LPM) of groundwater are used for demineralizer makeup, and 

less than 10 gpm (38 LPM) are used for potable supply. 

An initial drawdown test was performed in 1972 (Bechtel Corp., 1972) to determine potential 

sustainable well yields. In 2001, an aquifer test at Well A showed a stable water level in the well 

after five hours of pumping at 930 gpm (3,500 lpm) (Northway Well and Pump Co., 2001). More 

importantly, recent water level data from a set of six monitoring well nests (FPL-DA, 2007b) do 

not show a cone of depression at the site. Annual withdrawal volumes have remained fairly 

steady and are approximately one-half of the permitted amount (IDNR, 2005). Therefore, the 

Staff concludes the impact on groundwater from pumping more than 100 gpm is SMALL. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-4 October 2010 

4.3.3 Groundwater Use Conflicts (Makeup from a Small River) 

The NRC specifies that, “if the applicant’s plant utilizes cooling towers or cooling ponds and 

withdraws make-up water from a river whose annual flow rate is less than 3.15 x 1012 cubic feet 

per year (ft3

/year) (9 x 10E10 cubic meters per year)...[t]he applicant shall also provide an 

assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during 

low flow,” (10 CFR 51.53(c)(3)(ii)(A)). For water use conflicts, the NRC further states, in Table 

B-1 of Appendix B to Subpart A of 10 CFR Part 51 that, “water use conflicts may result from 

surface water withdrawals from small water bodies during low flow conditions which may affect 

aquifer recharge, especially if other groundwater or upstream surface water users come online 

before the time of license renewal.” This issue is applicable to DAEC because the water used 

for the plant cooling towers is withdrawn from the Cedar River, which has an annual mean flow 

of approximately 1.2 x 1011 ft3

/yr (3,878 cfs or 110 cubic meters per second (m3/s)), thus 

meeting the NRC’s definition of a small river. 

Flow in the Cedar River is monitored in Cedar Rapids, Iowa, about 15 miles (mi) (24 kilometers 

(km)) downstream of DAEC. Flow at DAEC is expected to be similar because no major 

tributaries enter the river between the facility and Cedar Rapids. Water withdrawal under 

operating conditions is 11,200 gpm (25 cfs or 0.71 m3

/s), or approximately 0.6 percent of the 

average river flow. Maximum consumptive use is 8,100 gpm (18 cfs or 0.51 m3

/s), or 

approximately 0.45 percent of the average river flow. 

During low-flow periods, the withdrawal rate and consumptive rate are higher proportions of the 

river flow. By a DAEC permit, when river flow falls below 500 cfs (14 m3

/s), the Pleasant Creek 

Recreational Reservoir may discharge to the Cedar River at a rate equal to the consumptive 

use rate (IDNR, 2005). At this low-flow threshold, the withdrawal rate is 5 percent of the low 

river flow, and the return of blowdown to the river results in a net consumptive rate of 3,6 

percent of the low river flow. Discharge from the reservoir is not a requirement of the permit. 

In summary, the withdrawal is typically less than 1 percent of river flow and the release of water 

from a reservoir is possible during low flow periods. In the vicinity of the plant, private wells do 

not pump from the alluvium layer so there are no conflicts (FPL-DA, 2008a). The Staff 

concludes that the impact on groundwater due to the use of makeup water from a small river is 

SMALL. 

4.4 SURFACE WATER 

Surface water quality issues applicable to DAEC are discussed below and listed in Table 4-4. 

The Staff did not identify any new and significant information during the review of DAEC’s ER 

(FPL-DA, 2008a), the site visit, or during the public scoping process. The Staff reviewed other 

sources of information such as various permits, the NPDES permit application, assorted 

applicant files, and REMP reports, and concludes there are no issues beyond those discussed 

in the GEIS. For surface water issues, the GEIS concluded that the Category 1 issues 

(including discharge of chlorine and other biocides) were SMALL, and additional site-specific 

mitigation measures are unlikely to be sufficiently beneficial to be warranted. As described in 

the following section, one Category 2 issue was identified related to surface water use conflicts. 
Environmental Impacts of Operation 

October 2010 4-5 NUREG-1437, Supplement 42 

Table 4-4. Surface Water Quality Issues. A description of the surface water quality 

conditions at DAEC is provided in Section 2.2.4. 

Issues GEIS Sections Category 

Altered current patterns at intake and discharge structures 4.2.1.2.1 1 

Temperature effects on sediment transport capacity 4.2.1.2.3 1 

Scouring caused by discharged cooling water 4.2.1.2.3 1 

Eutrophication 4.2.1.2.3 1 

Discharge of chlorine or other biocides 4.2.1.2.4 1 

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1 

Discharge of other metals in wastewater 4.2.1.2.4 1 

Water use conflicts (plants with cooling ponds or cooling towers using 

makeup water from a small river with low flow) 4.3.2.1, 4.4.2.1 2 

4.4.1 Water Use Conflicts 

For assessing water use conflicts on a “small river,” NRC specifies that, “if the applicant’s plant 

uses cooling towers or cooling ponds and withdraws makeup water from a river whose annual 

flow rate is less than 3.15 x 1012 ft3

/year (9 X 10E10 m3/y), an assessment of the impact of the 

proposed action on the flow of the river and related impacts on instream and riparian ecological 

communities must be provided” (10 CFR 51.53(c)(3)(ii)(A)). For water use conflicts, the NRC 

further states in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51, that the “issue has 

been a concern at nuclear power plants with cooling ponds and at plants with cooling towers. 

Impacts on instream and riparian communities near these plants could be of moderate 

significance in some situations.” 

This issue is applicable to DAEC because the plant uses a cooling-tower system. Water lost to 

evaporation in the cooling system is replaced with water withdrawn from the Cedar River (which 

NRC has defined as a “small river” based on mean annual flow). 

As discussed in Section 2.1.6, flow in the Cedar River at DAEC is expected to be similar to that 

at the Cedar Rapids gauge station because no major tributaries enter the river between the 

facility and Cedar Rapids (15 mi (924 km) downstream). Water withdrawn under normal 

operating conditions is approximately 0.6 percent of the average river flow. Maximum 

consumptive use (amount actually lost due to evaporative and drift loses) is 8,100 gpm (18 cfs), 

which is approximately 0.46 percent of the average river flow. 

During low-flow periods, the withdrawal rate and consumptive rate are higher proportions of the 

river flow. At this low-flow threshold, the net consumptive rate would constitute a relatively small 

proportion of total flow volume (i.e., 3.6 percent of the low flow). 

In summary, DAEC surface water withdrawals are typically less than 1 percent of mean river 

flow and the release of water from a reservoir is possible during a drought. The Staff concludes 

that the impact on surface water due to the use of river makeup water, even during a period of 

low flow, is SMALL. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-6 October 2010 

4.5 AQUATIC RESOURCES 

Table 4-5 lists issues related to aquatic resources applicable to DAEC. No Category 2 issues 

are related to aquatic resources. The Staff did not find any new and significant information 

during the review of the applicant’s ER, the site audit, the scoping process, or the evaluation of 

other available information; therefore, the Staff concludes that there are no impacts related to 

aquatic resource issues beyond those discussed in the GEIS (NRC, 1996). Consistent with the 

GEIS, the Staff concludes that the impacts are SMALL, and additional site-specific mitigation 

measures are unikely to be sufficiently beneficial to warrant implementation. 

Table 4-5. Aquatic Resource Issues. Section 2.1.6 of this report describes the DAEC 

cooling water system; Section 2.2.5 describes aquatic resources. 

Issues GEIS Section Category 

For All Plants 

Accumulation of contaminants in sediments or biota 4.2.1.2.4 1 

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1 

Cold shock 4.2.2.1.5 1 

Thermal plume barrier to migrating fish 4.2.2.1.6 1 

Distribution of aquatic organisms 4.2.2.1.6 1 

Premature emergence of aquatic insects 4.2.2.1.7 1 

Gas supersaturation (gas bubble disease) 4.2.2.1.8 1 

Low dissolved oxygen in the discharge 4.2.2.1.9 1 

Losses from predation, parasitism, and disease among organisms 

exposed to sublethal stresses 

Stimulation of nuisance organisms 

4.2.2.1.10 

4.2.2.1.11 

 1 

 

 1 

For Plants with Cooling-Tower-Based Heat Dissipation Systems 

Entrainment of fish and shellfish in early life stages 4.3.3 1 

Impingement of fish and shellfish 4.3.3 1 

Heat shock 4.3.3 1 

4.6 TERRESTRIAL RESOURCES 

The issues related to terrestrial resources applicable to DAEC are listed in Table 4-6. There are 

no Category 2 issues related to terrestrial resources. The NRC did not identify any new and 

significant information during the review of the applicant’s ER, the Staff’s site audit, the scoping 

process, or the evaluation of other available information. Therefore, there are no impacts 

related to these issues beyond those discussed in the GEIS. Consistent with the GEIS, the 

Staff concludes that the impacts are SMALL, and additional site-specific mitigation measures 

are not likely to be sufficiently beneficial to warrant implementation. 

Table 4-6. Terrestrial Resources Issues. Section 2.2.6 provides a description of the 

terrestrial resources at DAEC and in the surrounding area. 

Issues GEIS Section Category 

Cooling tower impacts on crops and ornamental vegetation 4.3.4 1 
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October 2010 4-7 NUREG-1437, Supplement 42 

Issues GEIS Section Category 

Cooling tower impacts on native plants 4.3.5.1 1 

Bird collisions with cooling towers 4.3.5.2 1 

Power line right-of-way management (cutting and herbicide 

application) 4.5.6.1 1 

Bird collisions with power lines 4.5.6.1 1 

Impacts of electromagnetic fields on flora and fauna (plants, 

agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1 

Floodplains and wetlands on power line right-of-way 4.5.7 1 

4.7 THREATENED AND ENDANGERED SPECIES 

The issues related to terrestrial resources applicable to DAEC are listed in Table 4-7. 

Table 4-7. Threatened or Endangered Species. Section 2.2.7 describes the 

threatened or endangered species on or near DAEC.

Issue GEIS Section Category 

Threatened or endangered species 4.1 2 

This site-specific, or Category 2 issue, requires consultation with the appropriate agencies to 

determine whether or not threatened or endangered species are present and whether or not 

they would be adversely affected by continued operation of DAEC during the license renewal 

term. The characteristics and habitats of threatened and endangered species in the vicinity of 

the DAEC site are discussed in Sections 2.2.5 through 2.2.7 of this SEIS. 

The NRC contacted the U.S. Fish and Wildlife Service (USFWS) on May 6, 2009, regarding 

threatened and endangered species at the DAEC site (NRC, 2009a). A description of the site 

and the in-scope transmission lines and a preliminary assessment of the Federal threatened, 

endangered, and candidate species potentially occurring on or near the DAEC site was 

provided in this letter. In response, on May 29, 2009, the USFWS indicated that the prairie bush 

clover (Lespedeza leptostachya) and the western prairie fringed orchid (Platanthera praeclara), 

both, designated as threatened on Federal and Iowa State lists, have the potential to occur in 

Linn County (USFWS, 2009). Neither species was identified during the pre-operational 

terrestrial flora study (Neimann and McDonald, 1972), nor have they been identified on the 

DAEC site since this time (FPL-DA, 2008a). 

The NRC contacted the Iowa Department of Natural Resources (IDNR) on May 6, 2009, to 

request data to aid in determining which State-listed species may be affected by continued 

operations and maintenance procedures at the DAEC site and associated transmission line right 

of ways (ROWs) (NRC, 2009b). The IDNR provided responses on May 18, 2009, indicating that 

its record search for rare species and significant natural habitats or communities yielded “no 

site-specific records that would be impacted by the use of existing plant facilities and 

transmission lines” (IDNR, 2009a). 

4.7.1 Aquatic Species 

The Staff has reviewed information provided by the applicant and information publicly available 

and has contacted the USFWS and IDNR (NRC, 2009a; 2009b). Currently, no threatened or 
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NUREG-1437, Supplement 42 4-8 October 2010 

endangered aquatic species are known to occur within the Cedar River near the vicinity of 

DAEC or within any streams crossed by in-scope transmission line ROWs. Therefore, license 

renewal of DAEC would have no effect on any Federally or State-listed aquatic species, and 

mitigation measures do not need to be considered. 

4.7.2 Terrestrial Species 

Currently, no known sightings of Federally-listed threatened or endangered terrestrial species 

have occurred on the DAEC site or within the in-scope transmission line ROWs. Operation of 

DAEC and its associated transmission lines are not expected to adversely affect any threatened 

or endangered terrestrial species during the license renewal term. 

The NRC staff concludes that the adverse impacts to threatened and endangered terrestrial 

species during the license renewal term would be SMALL. A potential mitigation measure that 

could further reduce this SMALL impact include would be for ITC Midwest LLC (ITC) to report 

existence of any Federally or State-listed endangered or threatened species within or near the 

transmission line ROWs to the IDNR and/or USFWS if any such species are identified during 

the renewal term. In particular, if any evidence of injury or mortality of migratory birds, Statelisted species, or Federally listed threatened or endangered species is observed within the 

corridor during the renewal period, coordination with the appropriate state or Federal agency 

would minimize impacts to the species and, in the case of Federally listed species, ensure 

compliance with the ESA. 

4.8 HUMAN HEALTH 

The human health issues applicable to DAEC are discussed below and listed in Table 4-8 for 

Category 1, Category 2, and uncategorized issues. 

Table 4-8. Human Health Issues. Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 

contains additional information on human health issues applicable to DAEC. 

Issues GEIS Section Category 

Microbiological organisms (occupational health) 4.3.6 1 

Microbiological organisms (public health, for plants using small 

rivers) 4.3.6 2 

Noise 4.3.7 1 

Radiation exposures to public (license renewal term) 4.6.1, 4.6.2 1 

Occupation radiation exposures (license renewal term) 4.6.3 1 

Electromagnetic fields – acute effects (electric shock) 4.5.4.1 2 

Electromagnetic fields – chronic effects 4.5.4.2 Uncategorized 

4.8.1 Generic Human Health Issues 

The Staff did not identify any new and significant information during its review of the FPL-DA 

ER, the site audit, or the public scoping process; therefore, there are no impacts related to 

generic human health issues beyond those discussed in the GEIS. For these issues, the GEIS 

concluded that the impacts are SMALL, and additional site-specific mitigation measures are 

unlikely to be sufficiently beneficial to be warranted. The information presented below 

discusses selected radiological programs conducted at DAEC. 
Environmental Impacts of Operation 

October 2010 4-9 NUREG-1437, Supplement 42 

DAEC conducts a REMP to assess the radiological impact, if any, to its employees, the public, 

and environs around the plant site. An annual radiological environmental operating report is 

issued with a discussion of the results of the monitoring program. The report contains data on 

the monitoring performed for the most recent year and graphs, which show data trends from 

prior years, and in some cases, provide a comparison to pre-plant operation baseline data. The 

objectives of the REMP include the following: 

● To measure and evaluate the levels of radiation and radioactive material in the 

environs around the DAEC site to assess the radiological impacts, if any, of 

plant operation on the environment. 

● To supplement the results of the radiological effluent monitoring program by 

verifying that the measurable concentrations of radioactive material and levels 

of radiation are not higher than expected based on the measurement of 

radioactive effluents and modeling for the applicable exposure pathways. 

● To demonstrate compliance with the requirements of applicable Federal 

regulatory agencies. 

The DAEC REMP collects samples of environmental media in the environs around the site to 

analyze and measure the radioactivity levels that may be present. The media samples are 

representative of radiation exposure pathways to the public from all plant radioactive effluents. 

The REMP measures the aquatic, terrestrial, and atmospheric environment, as well as ambient 

gamma radiation, for radioactivity. Ambient gamma radiation pathways include radiation from 

buildings and plant structures and airborne material that may be released from the plant. In 

addition, the REMP also measures background radiation (i.e., cosmic sources, global fallout, 

and naturally occurring radioactive material, including radon). Thermoluminescent dosimeters 

(TLDs) are used to measure direct radiation. Atmospheric environmental monitoring consists of 

sampling the air for particulates and radioiodine. Terrestrial environmental monitoring consists 

of analyzing samples of milk and food products. Aquatic environmental monitoring consists of 

analyzing samples of surface water, drinking water, groundwater, fish, and sediment from the 

Cedar River. There is also an onsite groundwater protection program designed to monitor the 

onsite plant environment for early detection of leaks from plant systems and pipes which convey 

radioactive liquids. 

The Staff reviewed the DAEC annual radiological environmental operating reports for 2004 

through 2009 to identify any significant impacts to the environment or any unusual trends in the 

data (FPL-DA, 2005b), (FPL-DA, 2006d), (FPL-DA, 2007c), (FPL-DA, 2008d), (FPL-DA, 2009d) 

(FPL-DA, 2010). The Staff’s review of the REMP reports revealed no unusual trends in the data 

and showed no measurable impact from the operations at DAEC on the environment. Further, 

NRC inspection reports were also reviewed supporting this conclusion. 

Historical data on radioactive releases from DAEC and the resultant dose calculations 

demonstrate that the amount of radiation received to a hypothetical maximally exposed 

individual in the vicinity of DAEC is a small fraction of the dose limits specified in 

10 CFR Part 20, the “as low as is reasonably achievable” (ALARA) dose design objectives in 

Appendix I to 10 CFR Part 50, and the EPA’s radiation standards in 40 CFR Part 190, 

“Environmental Radiation Protection Standards for Nuclear Power Operations.” Dose estimates 

for members of the public are calculated based on liquid and gaseous effluent release data and 

atmospheric and aquatic transport models. The DAEC 2009 annual radioactive material release 
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NUREG-1437, Supplement 42 4-10 October 2010 

report (FPL-DA, 2010) contains a detailed presentation of the radioactive discharges and the 

resultant calculated doses. The following conclusion summarizes the calculated hypothetical 

maximum dose to an individual located outside the DAEC site boundary from radioactive liquid 

and gaseous effluents released during 2009: 

● The maximum whole-body dose to an offsite member of the public from liquid 

effluents was 4.56 E-06 milliroentgen equivalent man (mrem) (3.23 E-07 

millisievert (mSv)), which is well below the 3 mrem (0.03 mSv) dose criterion in 

Appendix I to 10 CFR Part 50. 

● The maximum organ (child liver) dose to an offsite member of the public from 

liquid effluents discharged from the sanitary waste treatment facility effluents 

was 4.56 E-06 mrem (4.56 E-08 mSv), which is well below the 10 mrem 

(0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50. 

● The maximum air dose at the site boundary from gamma radiation in gaseous 

effluents was 3.81 E-03 milliradiation absorbed dose (mrad) (3.81 E-05 milligray 

(mGy)), which is well below the 10 mrad (0.1 mGy) dose criterion in Appendix I 

to 10 CFR Part 50. 

● The maximum air dose at the site boundary from beta radiation in gaseous 

effluents was 1.86 E-03 mrad (1.86 E-05 mGy), which is well below the 20 mrad 

(0.2 mGy) dose criterion in Appendix I to 10 CFR Part 50. 

● The maximum organ (child thyroid) dose to an offsite member of the public from 

radioactive iodine and radioactive material in particulate form was 6.05 E-03 

mrem (6.05 E-05 mSv), which is well below the 15 mrem (0.15 mSv) dose 

criterion in Appendix I to 10 CFR Part 50. 

Based on the Staff’s review and assessment of the DAEC radioactive waste system 

performance in controlling radioactive effluents and the resultant doses to members of the 

public in conformance with the ALARA criteria, the Staff found that the 2008 radiological effluent 

data for DAEC are consistent, with reasonable variation attributable to operating conditions and 

outages, with the 5-year historical radiological effluent releases and resultant doses (FPL-DA, 

2005c), (FPL-DA, 2006e), (FPL-DA, 2007d), (FPL-DA, 2008e), (FPL-DA, 2009e), (FPL-DA, 

2010). These results demonstrate that DAEC is operating in compliance with Federal radiation 

protection standards contained in Appendix I to 10 CFR Part 50 and 10 CFR Part 20. 

The applicant has no plans to conduct refurbishment activities during the license renewal term, 

thus, no significant change to radiological conditions is expected to occur. Continued 

compliance with regulatory requirements is expected during the license renewal term; therefore, 

the impacts from radioactive effluents are not expected to change during the license renewal 

term. 

4.8.2 Microbiological Organisms – Public Health 

The effects of thermophilic microbiological organisms on human health, listed in Table B-1 of 

Appendix to Subpart A of 10 CFR Part 51, are categorized as a Category 2 issue and require a 

plant-specific evaluation during the license renewal process for the plants using closed-cycle 

cooling, located on a small river. The average annual flow of the Cedar River nearest the DAEC 
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October 2010 4-11 NUREG-1437, Supplement 42 

measuring station is approximately 1.05 x 1011 ft3

/yr (2.97 x 109 cubic meters per year (m3/yr)) to 

1.19 x 1011 ft3

/yr (3.37 x 109 m3/yr), which is less than the threshold value of 3.15 x 1012 ft3/yr (9 

x 1010 m3/yr) in 10 CFR 51.53(c)(3)(ii)(G) for thermal discharge to a small river (FPL-DA, 2008a). 

Therefore, the effects of the DAEC cooling water discharge on microbiological organisms must 

be addressed for DAEC license renewal. 

The Category 2 designation is based on the magnitude of the potential public health impacts 

associated with thermal enhancement of enteric pathogens such as Salmonella spp. and 

Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living 

amoebae Naegleria spp., and Legionella spp. bacteria (NRC, 1996). Thermophilic 

microorganisms generally occur at temperatures of 77°F to 176°F (25°C to 80°C) with an 

optimal growth temperature range of 122°F to 150°F (50° to 66°C), and minimum and maximum 

temperature tolerances of 68°F (20°C) and 158°F (70°C), respectively; however, thermal 

preferences and tolerances vary across bacterial groups. Pathogenic thermophilic 

microbiological organisms of concern during nuclear reactor operation typically have optimal 

growing temperatures of approximately 99°F (37°C) (Joklik and Smith, 1972). 

Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal 

infections in immunocompromised individuals. The organism produces toxins harmful to 

humans and animals. It has an optimal growth temperature of 99°F (37°C) (Todar, 2007). 

Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for 

Legionnaires’ disease, with the onset of pneumonia in the first 2 weeks of exposure. Risk 

groups for Legionella spp. include elderly, cigarette smokers, persons with chronic lung or 

immunocompromising disease, and persons receiving immunosuppressive drugs. 

The ambient temperatures of the Cedar River near DAEC varies from freezing (32°F (0°C)) in 

the winter to 76°F–78°F (24.4°C–25.6°C) in the summer. Therefore, ambient river conditions 

are not likely to support the proliferation of the pathogenic organisms of concern. Table 4-9 

represents the maximum daily discharge temperatures at outfall 001, reported in DAEC NPDES 

monthly reports for the 2001–2008 period. 

Table 4-9. The Maximum Daily Discharge Temperatures, Reported in DAEC NPDES 

Reports for the 2001–2008 Period 

Date (month/year) Maximum Daily Discharge Temperature 

July, August 2001 89°F (31.7°C) 

June, July 2002 90°F (32.2°C) 

July 2003 89°F (31.7°C) 

July, August 2004 89°F (31.7°C) 

June, August 2005 88°F (31.1°C) 

July 2006 80°F (26.7°C) 

July, August 2007 78°F (25.6°C) 

August 2008 79°F (26.1°C) 

The highest daily discharge temperature reported at DAEC in the 2001–2008 period is 90°F 

(32.2°C) during June and July of 2002, which is below the optimal growing temperature of 

approximately 99°F (37°C) for the pathogenic thermophilic microbiological organisms that are of 

concern during nuclear power reactor operation. DAEC implements additional measures 

(disinfection and chlorination of water discharged from DAEC) to control and inhibit the 
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NUREG-1437, Supplement 42 4-12 October 2010 

proliferation of the pathogenic thermophilic microbiological organisms (FPL-DA, 2008a). 

Ambient temperatures within the Cedar River are below 77°F (25°C) from October to April. 

Based on this data, ambient river conditions are not likely to support the proliferation of the 

pathogenic organisms of concern. 

FPL-DA consulted the Bureau of Water Supply Management of the Iowa Department of Public 

Health (IDPH) to determine whether or not there was any concern about the possible 

occurrence of thermophilic microbiological organisms in the Cedar River at the DAEC location. 

The IDPH stated that no occurrences of infections caused by Naegleria fowleri and Legionella

from the Cedar River in the DAEC vicinity had been documented (FPL-DA, 2008a). 

Available data assembled into biannual reports by the Center for Disease Control (CDC) and 

biennial prevention for the years 1999 to 2006 (CDC, 2000), (CDC, 2002), (CDC, 2004), (CDC, 

2006) indicates no occurrence of waterborne disease outbreaks in the State of Iowa resulting 

from exposure to the thermophilic microbiological organisms Naegleria fowleri and 

Pseudomonas aeruginosa. 

The Staff reviewed all documents applicable to this Category 2 issue including the FPL-DA ER, 

the DAEC NPDES permit, and CDC reports. The Staff concludes that thermophilic 

microbiological organisms are unlikely to present a public health hazard as a result of DAEC 

discharges to the Cedar River. The Staff concludes that impacts on public health from 

thermophilic microbiological organisms from continued operation of DAEC in the license 

renewal period would be SMALL. 

The Staff identified measures that could mitigate the potential impacts of thermophilic 

microbiological organisms resulting from continued operation of DAEC. These mitigation 

measures include periodically monitoring for thermophilic microbiological organisms in water 

and sediments near the discharge, as well as prohibiting recreational use near the discharge 

plume. These mitigation measures could reduce human health impacts by minimizing public 

exposure to thermophilic microbiological organisms. The Staff did not identify any cost-benefit 

studies applicable to the mitigation measures mentioned above. 

4.8.3 Electromagnetic Fields – Acute Shock 

Based on the GEIS, the Commission found that electric shock resulting from direct access to 

energized conductors or from induced charges in metallic structures has not been a problem at 

most operating plants and generally is not expected to be a problem during the period of 

extended operation. However, a site-specific review is required to determine the significance of 

electric shock potential along the portions of the transmission lines within the scope of this 

SEIS. 

The GEIS states that it is not possible to determine the significance of the electric shock 

potential without a review of the conformance of each nuclear plant’s transmission lines with 

National Electrical Safety Code (NESC) (IEEE, 2007) criteria. An evaluation of individual plant 

transmission lines is necessary because the issue of electric shock safety was not addressed in 

the licensing process for some plants. For other plants, land use in the vicinity of transmission 

lines may have changed, or power distribution companies may have chosen to upgrade line 

voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an assessment of 

the potential shock hazard if the transmission lines that were constructed for the specific 

purpose of connecting the plant to the transmission system do not meet the recommendations 

of the NESC for preventing electric shock from induced currents. 
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October 2010 4-13 NUREG-1437, Supplement 42 

All transmission lines associated with DAEC were constructed in accordance with NESC and 

industry guidance in effect at that time (AEC, 1973). Transmission lines and facilities are 

maintained to ensure continued compliance with current standards. A transmission line 

assessment program implemented at DAEC ensures for continued monitoring and documenting 

of the transmission line conditions, maintenance, and compliance with existing standards. 

Routine aerial inspections are conducted every 6 months to identify any ground clearance 

problems and ensure integrity of the transmission line structures. Ground inspections are 

conducted biennially by transmission line technicians (FPL-DA, 2008a). 

Since the lines were constructed, a new criterion has been added to the NESC for power lines 

with voltages exceeding 98 kilovolts (kV). FPL-DA has reviewed the transmission lines for 

compliance with this criterion (FPL-DA, 2008a). FPL-DA indicated that all transmission lines 

within the scope of this review have been restudied, and the results show there are no locations 

under the transmission lines that have the capacity to induce more than 5 milliamperes (mA) in 

a vehicle parked beneath the line. No induced shock hazard to the public should occur since 

the lines are operating within original design specifications and meet current NESC clearance 

standards. 

The Staff has reviewed the available information, including the applicant’s evaluation and 

computational results. Based on this information, the Staff evaluated potential impacts for 

electric shock resulting from operation of DAEC and its associated transmission lines. The Staff 

concludes that the potential impacts from electric shock during the renewal period are SMALL. 

The Staff identified measures that could mitigate potential acute electromagnetic field (EMF) 

impacts resulting from continued operation of the DAEC transmission lines. These mitigation 

measures include erecting barriers along the length of the transmission lines to prevent 

unauthorized access to the ground beneath the conductors and installing road signs at road 

crossings. These mitigation measures could reduce human health impacts by minimizing public 

exposures to electric shock hazards. The Staff did not identify any cost-benefit studies 

applicable to the mitigation measures mentioned above. 

4.8.4 Electromagnetic Fields – Chronic Effects 

In the GEIS, the chronic effects of 60-hertz (Hz) electromagnetic fields from power lines are not 

designated as Category 1 or 2, and will not be until a scientific consensus is reached on the 

health implications of these fields. 

The potential for chronic effects from these fields continues to be studied and is not known at 

this time. A 1999 report by the National Institute of Environmental Health Sciences (NIEHS) 

directs related research through the Department of Energy (DOE). The report by NIEHS 

contains the following conclusion, which is supported by recently published Environmental 

Health Criteria Monograph No. 238 (WHO, 2007): 

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 
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NUREG-1437, Supplement 42 4-14 October 2010 

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 (10 CFR 51 Footnote 5 to Table B-1): 

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 a GEIS finding of an “uncertain” hazard appropriate and will continue to 

follow developments on this issue. 

4.9 SOCIOECONOMICS 

Category 1 issues depicted in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, which are 

applicable to socioeconomic impacts during the renewal term are listed in Table 4-10. As stated 

in the GEIS, the impacts associated with these Category 1 issues are determined to be SMALL, 

and plant-specific mitigation measures would not be sufficiently beneficial to be warranted. 

The Staff reviewed and evaluated the DAEC ER, public scoping comments, other available 

information, and visited DAEC in search of new and significant information that could change 

the conclusions presented in the GEIS. No new and significant information was identified during 

this review. Therefore, it is expected that there would be no impacts related to these Category 1 

issues during the renewal term beyond those discussed in the GEIS. 

Table 4-10. Category 1 Issues Applicable to Socioeconomics during the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

Socioeconomics 

Public services: public safety, social services, and tourism and recreation 4.7.3; 4.7.3.3; 4.7.3.4; 

4.7.3.6 

Public services: education (license renewal term) 4.7.3.1 

Aesthetic impacts (license renewal term) 4.7.6 

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 

4.9.1 Generic Socioeconomic Issues 

The results of the NRC review and brief statement of GEIS conclusions, as codified in Table B-1 

of 10 CFR Part 51, Subpart A, Appendix B, for each of the socioeconomic Category 1 issues 

over the license renewal term are provided below: 

Public services: public safety, social services, and tourism and recreation. Based on 

information in the GEIS, the Commission found that: Impacts to public safety, social services, 

and tourism and recreation are expected to be of small significance at all sites. 
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October 2010 4-15 NUREG-1437, Supplement 42 

Public services: education. Based on information in the GEIS, the Commission found that: 

Only impacts of small significance are expected. 

Aesthetic impacts. Based on information in the GEIS, the Commission found that: No 

significant impacts are expected during the license renewal term. 

Aesthetic impacts of transmission lines. Based on information in the GEIS, the Commission 

found that: No significant impacts are expected during the license renewal term. 

No new and significant information was identified for these issues during the review. Therefore, 

no impacts are expected during the renewal term beyond those discussed in the GEIS. 

Table 4-11 lists the Category 2 socioeconomic issues that require plant-specific analysis and an 

environmental justice impact assessment, which was not addressed in the GEIS. 

Table 4-11. Category 2 Issues Applicable to Socioeconomics and Environmental Justice 

during the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 GEIS Section 

Socioeconomics 

Housing impacts 4.7.1 

Public services: public utilities 4.7.3.5 

Offsite land use (license renewal term) 4.7.4 

Public services: transportation 4.7.3.2 

Historic and archaeological resources 4.7.7 

Environmental justice Not addressed(a)

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to 

10 CFR Part 51 were prepared; therefore, environmental justice must be addressed in plant-specific reviews. 

4.9.2 Housing Impacts 

Appendix C of the GEIS presents a population characterization method based on two factors: 

sparseness and proximity (NRC, Section C.1.4, 1996). Sparseness measures population 

density within 20 mi of the site, and proximity measures population density and city size within 

50 mi of the site. Each factor has categories of density and size (NRC, Table C.1, 1996). A 

matrix is used to rank the population category as low, medium, or high (NRC, Figure C.1, 1996). 

In 2000, approximately 210,081 persons lived within a 20-mi (32-km) radius of DAEC, which 

equates to a population density of 167 persons per square mile (mi2

). This density translates to 

a Category 4 (greater than or equal to 120 persons per mi2

 within 20 mi) using the GEIS 

measure of sparseness (FPL-DA, 2008a). At the same time, there were approximately 

621,461 persons living within a 50-mi radius of the plant, for a density of 79 persons per mi2

, 

meaning that DAEC falls into Category 3 (one or more cities with 100,000 or more persons and 

less than 190 persons per mi2 within 50 mi (80 km) on the NRC proximity scale. A Category 4 

value for sparseness and a Category 3 value for proximity indicate that DAEC is in a high 

density population area. 
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NUREG-1437, Supplement 42 4-16 October 2010 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 

are expected to be of small significance at plants located in medium-density population areas 

where growth-control measures are not in effect. Since DAEC is located in a high population 

area, Linn and Benton counties are not subject to growth-control measures that would limit 

housing development; any DAEC employment-related impact on housing availability would likely 

be small. Since FPL-DA has no plans to add non-outage employees during the license renewal 

period, employment levels at DAEC would remain relatively constant with no additional demand 

for permanent housing during the license renewal term. In addition, the number of available 

housing units has kept pace with growth in the area population. Based on this information, 

there would be no impact on housing during the license renewal term beyond what has already 

been experienced. 

4.9.3 Public Services: Public Utility Impacts 

Impacts on public utility services are considered SMALL if there is little or no change in the 

ability of the system to respond to demand and, thus, there is no need to add capital facilities. 

Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak 

demand. Impacts are considered LARGE if services (e.g., water, sewer) are substantially 

degraded and additional capacity is needed to meet ongoing demand. The GEIS indicated that, 

in the absence of new and significant information to the contrary, the only impacts on public 

utilities that could be significant are impacts on public water supplies. 

The Staff’s analysis of impacts on the public water and sewer systems considered both plant 

demand and plant-related population growth. Section 2.1.7 of this SEIS describes the DAEC 

permitted withdrawal rate and actual use of water. 

As discussed in Chapter 2, DAEC provides potable water for drinking, pump seal cooling, 

sanitation, and fire protection through the onsite groundwater well system. DAEC does not use 

water from a municipal system and plant groundwater usage during the renewed license period 

of operations would remain relatively unchanged. Further, no increase in plant demand is 

projected. 

Since FPL-DA has no plans to add non-outage employees during the license renewal period, 

employment levels at DAEC would remain relatively constant with no additional demand for 

public services. Public and private water systems in the region are adequate to meet the 

demand of residential and industrial customers in the area. Therefore, there would be no 

additional impact to public water services during the license renewal term beyond what is 

currently being experienced. 

4.9.4 Offsite Land Use 

Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, 

Subpart A, Appendix B, Table B-1). Table B-1 notes that, “significant changes in land use may 

be associated with population and tax revenue changes resulting from license renewal.” 

Section 4.7.4 of the GEIS defines the magnitude of land use changes as a result of plant 

operation during the license renewal term as follows: 

● SMALL—little new development and minimal changes to an area’s land use 

pattern 
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October 2010 4-17 NUREG-1437, Supplement 42 

● MODERATE—considerable new development and some changes to the land 

use pattern 

● LARGE—large-scale new development and major changes in the land use 

pattern 

Tax revenue can affect land use because it enables local jurisdictions to provide the public 

services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 

the GEIS states that the assessment of tax-driven land use impacts during the license renewal 

term should consider: (1) the size of the plant’s payments relative to the community’s total 

revenues, (2) the nature of the community’s existing land use pattern, and (3) the extent to 

which the community already has public services in place to support and guide development. If 

the plant’s tax payments are projected to be small, relative to the community’s total revenue, tax 

driven land use changes during the plant’s license renewal term would be SMALL, especially 

where the community has pre-established patterns of development and has provided adequate 

public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax 

payments by the plant owner are less than 10 percent of the taxing jurisdiction’s revenue, the 

significance level would be SMALL. If the plant’s tax payments are projected to be MODERATE 

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 if the community has no pre-established pattern of development or has not 

provided adequate public services to support and guide development. 

4.9.4.1 Population-Related Impacts 

Since FPL-DA has indicated that they have no plans to add non-outage employees during the 

license renewal period, there would be no noticeable change in land use conditions in the 

vicinity of DAEC. Therefore, there would be no population-related land use impacts during the 

license renewal term beyond those already being experienced. 

4.9.4.2 Tax-Revenue-Related Impacts 

As discussed in Chapter 2, FPL-DA pays annual real estate taxes to Linn County. For the 

4-year period from 2005 through 2008, tax payments to Linn County represented between 0.3 

and 0.4 percent of the county’s total property tax revenue collections. Since FPL-DA started 

making payments to local jurisdictions, population levels and land use conditions in Linn County 

have not changed significantly, which may indicate that these tax revenues have had little or no 

effect on land use activities within the county. 

Since FPL-DA has indicated that they have no plans to add non-outage employees during the 

license renewal period, employment levels at DAEC would remain relatively unchanged. There 

would be no increase in the assessed value of DAEC, and annual property tax payments to Linn 

County would be expected to remain relatively unchanged throughout the license renewal 

period. Based on this information, there would be no tax-revenue related land use impacts 

during the license renewal term beyond those already being experienced. 

4.9.5 Public Services: Transportation Impacts 

Table B-1 in 10 CFR Part 51 states the following: 
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NUREG-1437, Supplement 42 4-18 October 2010 

Transportation impacts (level of service) of highway traffic generated during the 

term of the renewed license are generally expected to be of SMALL significance. 

However, the increase in traffic associated with additional workers and the local 

road and traffic control conditions may lead to impacts of MODERATE or LARGE 

significance at some sites. 

The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of 

highway traffic generated by the proposed project on the level of service of local highways 

during the term of the renewed license. Since FPL-DA has no plans to add non-outage 

employees during the license renewal period, traffic volume and levels of service on roadways 

in the vicinity of DAEC would remain unchanged. Therefore, there would be no transportation 

impacts during the license renewal term beyond those already being experienced. 

4.9.6 Historic and Archaeological Resources 

The National Historic Preservation Act (NHPA) requires Federal agencies to take into account 

the potential effects of their undertakings on historic properties. Historic properties are defined 

as resources that are eligible for listing on the National Register of Historic Places (NRHP). The 

criteria for eligibility include: (1) association with significant events in history; (2) association with 

the lives of persons significant in the past; (3) embodiment of distinctive characteristics of type, 

period, or construction; and (4) association with or potential to yield important information on 

history or prehistory. The historic preservation review process mandated by Section 106 of the 

NHPA is outlined in regulations issued by the Advisory Council on Historic Preservation in Title 

36, Parks, Forests, and Public Property, Part 800, “Protection of Historic Properties” 

(36 CFR Part 800). The issuance of a renewed operating license for a nuclear power plant is a 

Federal undertaking that could possibly affect either known or potential historic properties 

located on or near the plant and its associated transmission lines. In accordance with the 

provisions of the NHPA, the NRC is required to make a reasonable effort to identify historic 

properties in the area of potential effect. If no historic properties are present or affected, the 

NRC is required to notify the State Historic Preservation Office (SHPO) before proceeding. If it 

is determined that historic properties are present, the NRC is required to assess and resolve 

possible adverse effects of the undertaking. 

In April 2007, DAEC contacted the State Historical Society of Iowa concerning the license 

renewal application being submitted by DAEC to the NRC. The State Historical Society of Iowa 

did not respond to the letter. The NRC contacted the Iowa SHPO by letter on May 7, 2009, 

concerning the proposed relicensing of DAEC. The NRC also contacted the Iowa State 

Archaeologist and the Advisory Council on Historic Preservation by letter dated May 7, 2009. 

The NRC contacted 17 Native American tribes in association with the relicensing action (see 

Appendix E). 

Five archaeological investigations have taken place on the DAEC property. Surveys have 

examined roughly 16.1 acres (ac) of the 900-ac property. The ER conducted for the initial 

construction of DAEC in 1973 did not identify any historic or archaeological resources. 

However, the final environmental statement (FES) acknowledged that surveys were being 

conducted for the Pleasant Creek Reservoir to the northwest of the DAEC (AEC, 1973). The 

Pleasant Creek Reservoir surveys were the first systematic surveys conducted in the vicinity of 

the plant. Fifty-five archaeological sites were identified during the Pleasant Creek survey 

(Benn, 1974). 

In 1993, an archaeological survey sponsored by Linn County titled the Archaeological, 

Historical, and Architectural Survey of Fayette Township in Linn County, Iowa, examined 
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October 2010 4-19 NUREG-1437, Supplement 42 

several areas near and at DAEC. The survey, which focused on historic era properties, 

identified the remains of four historic era sites on the DAEC property. The first site, 13LN362, is 

an artifact scatter associated with a mid-19th century farmstead. Rogers and Page 

recommended that site 13LN362 not be deemed eligible for listing on the NRHP (Rogers and 

Page, 1993). The second site, 13LN363, is the remains of a late 19th century farmstead; it was 

recommended as potentially eligible for listing on the NRHP (Rogers and Page, 1993). A 

limestone well is visible at the site. The third site, 13LN365, is a late 19th century farmstead that 

Rogers and Page recommended as potentially eligible for the NRHP. The final site, 13LN366, 

is an artifact scatter dating to the late 19th century; this site was recommended as potentially 

eligible by Rogers and Page. None of the sites were evaluated for listing on the NRHP. 

The next three surveys conducted at DAEC occurred between 2000 and 2006. An 8.5-ac 

survey of an independent spent fuel storage facility conducted in 2001 by the University of Iowa 

did not identify any archaeological remains (UI, 2001). In 2005, the Louis Berger Group, Inc. 

conducted an archaeological survey of 7 ac for a cellular communications tower. No 

archaeological material was identified (Higginbottom, 2005). The final field survey conducted on 

the DAEC property examined a 1.9 ac area of shoreline along the Cedar River. The survey, 

conducted by the Louis Berger Group, did not identify any archaeological remains (Louis Berger 

Group, Inc., 2006). 

In 2008, DAEC contracted with Louis Berger Group, Inc. to perform a historic document review 

for the entire 900-ac property in anticipation of license renewal. The archival research identified 

five locations on the DAEC property that could contain historic and archaeological remains in 

addition to the four known archaeological sites (Louis Berger Group, Inc., 2008). The records 

indicate the potential presence of four residences or farmsteads and a platted townsite on the 

DAEC site. The report does not agree with the 1993 recommendation by Rogers and Page that 

site 13LN362 is not eligible for listing on the NRHP. It recommends that 13LN362 be 

considered potentially eligible until further testing can be undertaken. Several of the landforms 

on the DAEC property contain the potential for archaeological remains (Louis Berger Group Inc., 

2008). As of July 2009, the SHPO review of the 2008 Louis Berger report had not occurred. 

The transmission assets connecting DAEC to the grid are owned by ITC. There are 12 historic 

and archaeological resources within the DAEC transmission line corridors. Information 

concerning the resources was provided to ITC. ITC indicated that they would coordinate 

management of the resources with the SHPO. 

Most impacts to historic and archaeological resources occur during ground disturbing activities. 

DAEC maintains excavation and trenching procedures. A Staff review of the procedures found 

that known resources are considered in the excavation and trenching procedures, however, 

undiscovered historic and archaeological sites could be affected by plant activities. The large 

numbers of historic and archaeological resources previously found in the vicinity of DAEC 

indicate a potential for undiscovered resources to be present on the DAEC site. DAEC in 

coordination with the SHPO has revised and implemented its excavation and trenching 

procedures and developed a cultural resource management plan for the plant property. These 

plans address potential impacts to both known and undiscovered resources. 

DAEC has not proposed any new facilities, service roads, or transmission lines associated with 

license renewal or refurbishment, therefore, no impacts are expected to historic and 

archaeological resources from license renewal.
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NUREG-1437, Supplement 42 4-20 October 2010 

Based on the Staff’s review of past surveys conducted at DAEC, review of the procedures for 

considering historic and archaeological materials at DAEC, and review of the Iowa Historical 

Society and Iowa State Archaeologist files for the region, the Staff concludes that the potential 

impacts on historic and archaeological resources at DAEC would be MODERATE. As 

mentioned, DAEC has implemented its revised procedures and cultural resource management 

plan. However, due to the dense concentration of cultural material in the area, there remains a 

high potential for undiscovered resources. Additionally, many of the resources found in the 

region are of high importance (e.g., mound groups). If resources were encountered during plant 

activities, the effect would be expected to be MODERATE. 

4.9.7 Environmental Justice 

Under Executive Order (E.O.) 12898 (59 FR 7629), Federal agencies are responsible for 

identifying and addressing, as appropriate, disproportionately high and adverse human health 

and environmental impacts on minority and low-income populations. In 2004, the Commission 

issued a Policy Statement on the Treatment of Environmental Justice Matters in NRC 

Regulatory and Licensing Actions (69 FR 52040), which states that “[t]he Commission is 

committed to the general goals set forth in E.O. 12898, and strives to meet those goals as part 

of its National Environmental Policy Act (NEPA) review process.” 

The Council on Environmental Quality (CEQ) provides the following information in 

Environmental Justice: Guidance Under the National Environmental Policy Act (CEQ, 1997). 

This guidance states: 

Disproportionately High and Adverse Human Health Effects. Adverse health 

effects are measured in risks and rates that could result in latent cancer fatalities, 

as well as other fatal or nonfatal adverse impacts on human health. Adverse 

health effects may include bodily impairment, infirmity, illness, or death. 

Disproportionately high and adverse human health effects occur when the risk or 

rate of exposure to an environmental hazard for a minority or low-income 

population is significant (as defined by NEPA) and appreciably exceeds the risk 

or exposure rate for the general population or for another appropriate comparison 

group (CEQ, 1997). 

Disproportionately High and Adverse Environmental Effects. A 

disproportionately high environmental impact that is significant (as defined by 

NEPA) refers to an impact or risk of an impact on the natural or physical 

environment in a low-income or minority community that appreciably exceeds the 

environmental impact on the larger community. Such effects may include 

ecological, cultural, human health, economic, or social impacts. An adverse 

environmental impact is an impact that is determined to be both harmful and 

significant (as defined by NEPA). In assessing cultural and aesthetic 

environmental impacts, impacts that uniquely affect geographically dislocated or 

dispersed minority or low-income populations or American Indian tribes are 

considered (CEQ, 1997). 

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority and low-income populations that 

could result from the operation of DAEC during the renewal term. In assessing the impacts, the 

following CEQ definitions of minority individuals and populations, and low-income population 

were used (CEQ, 1997): 
Environmental Impacts of Operation 

October 2010 4-21 NUREG-1437, Supplement 42 

Minority individuals. Individuals who identify themselves as members of the 

following population groups: Hispanic or Latino, American Indian or Alaska 

Native, Asian, Black or African American, Native Hawaiian or Other Pacific 

Islander, or two or more races, meaning individuals who identified themselves on 

a Census form as being a member of two or more races, for example, Hispanic 

and Asian. 

Minority populations. Minority populations are identified when (1) the minority 

population of an affected area exceeds 50 percent or (2) the minority population 

percentage of the affected area is meaningfully greater than the minority 

population percentage in the general population or other appropriate unit of 

geographic analysis. 

Low-income population. Low-income populations in an affected area are 

identified with the annual statistical poverty thresholds from the U.S. Census 

Bureau’s (USCB) Current Population Reports, Series PB60, on Income and 

Poverty. 

4.9.7.1 Minority Population in 2000 

According to 2000 census data, 7.6 percent of the population (49,296 individuals) residing within 

a 50-mi radius of DAEC identified themselves as minority individuals. The largest minority 

group was Black or African American (18,883 individuals, or 2.9 percent), followed by Hispanic 

(11,772 individuals, or about 1.8 percent). Approximately 6 percent of the Linn County 

population was minority, with Black or African American (2.5 percent) being the largest minority 

group, followed by Hispanic or Latino (1.4 percent). In Benton County, 1.2 percent of the 

population was minority, with Hispanic or Latino (0.6 percent) being the largest minority group, 

followed by Black or African American (0.2 percent). 

The 50-mi radius around DAEC consists of each county with at least one census block group 

located within the 50-mi radius. The population demographic data from these counties were 

added together to derive average regional percentages. Of the 512 census block groups 

located wholly or partly within the 50-mi radius of DAEC, 25 block groups were determined to 

have minority population percentages that exceeded the State percentage by 20 percentage 

points or more, or that were more than 50 percent minority. The largest number of minority 

block groups was Black or African American, with 14 block groups that exceed the State 

percentage by 20 percentage points or more, or that were more than 50 percent Black or 

African American. 

These block groups are concentrated in urban areas with high population densities in Black 

Hawk County, Linn County, and Johnson County. There are also minority population groups in 

Muscatine County and Tama County. The closest high density minority population to DAEC is 

located in the city of Cedar Rapids, Iowa. Based on 2000 census data, Figure 4-1 shows 

census block groups with minority groups within a 50-mi radius of DAEC. 
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NUREG-1437, Supplement 42 4-22 October 2010 

Figure 4-1. Minority Population Groups within a 50-Mile Radius of Duane Arnold Energy 

Center (USCB, 2009) 

4.9.7.2 Low-Income Population in 2000 

According to 2000 census data, 59,848 individuals (9.6 percent) residing within a 50-mi radius 

of DAEC were identified as living below the Federal poverty threshold. The 1999 Federal 

poverty threshold was $17,029 for a family of four. According to USCB data, the median 

household income for Iowa in 2007 was $47,324, while 11 percent of the State population was 

determined to be living below the 1999 Federal poverty threshold. Linn County had one of the 

higher median household incomes ($53,076) in the State, and a lower percentage (9.9 percent) 

of individuals living below the poverty level, when compared to the State. 

Census block groups were considered low-income block groups if the percentage of households 

below the Federal poverty threshold exceeded the State average by 20 percentage points or 

more. Based on 2000 census data, there were 15 block groups within the 50-mi radius of 
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October 2010 4-23 NUREG-1437, Supplement 42 

DAEC that exceeded the State average for low income households by 20 percentage points or 

more, or that were more than 50 percent low-income. The majority of census block groups with 

low-income populations were located in urban areas with high population densities in Black 

Hawk County, Johnson County, and Linn County. The nearest high density low-income 

population to DAEC is located in Cedar Rapids, Iowa. Based on 2000 census data, Figure 4-2 

shows census block groups with low-income block populations within a 50-mi radius of DAEC. 

Figure 4-2. Low-Income Population Groups within a 50-Mile Radius of Duane Arnold 

Energy Center (USCB, 2009) 

4.9.7.3 Analysis of Impacts 

The NRC addresses environmental justice matters for license renewal through: (1) identification 

of minority and low-income populations that may be affected by the proposed license renewal, 

and (2) examining any potential human health or environmental effects on these populations to 

determine if these effects may be disproportionately high and adverse. 
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NUREG-1437, Supplement 42 4-24 October 2010 

The discussion and figures above identify the location of minority and low-income populations 

residing within a 50-mi (80-km) radius of DAEC. This area of impact is consistent with the 

impact analysis for public and occupational health and safety, which also considers the 

radiological effects on populations located within a 50-mi (80-km) radius of the plant. As 

previously discussed for the other resource areas in Chapter 4, the analyses of impacts for all 

resource areas indicated that the impact from license renewal would be SMALL. 

Socioeconomic conditions at the Sac and Fox Reservation and Meskwaki Settlement would not 

change as a result of renewing the DAEC operating license. Employment levels at DAEC would 

remain relatively unchanged, so direct and indirect employment opportunities caused by DAEC 

would remain unchanged. The Sac and Fox Reservation and Meskwaki Settlement also receive 

no income from tax monies paid by FPL-DA to Linn County. Therefore, there would be no 

additional socioeconomic impact to minority and low-income populations during the license 

renewal term beyond what is currently being experienced. 

Potential impacts to minority and low-income populations would mostly consist of radiological 

effects; however, radiation doses from continued operations associated with this license 

renewal are expected to continue at current levels and would remain within regulatory limits. 

Chapter 5 discusses the environmental impacts from postulated accidents that might occur 

during the license renewal term, which include both design-basis and severe accidents. In both 

cases, the Commission has generically determined that impacts associated with such accidents 

are SMALL because nuclear plants are designed to successfully withstand design-basis 

accidents, and that any risk associated with severe accidents were also SMALL. 

Therefore, based on this information and the analysis of human health and environmental 

impacts presented in Chapters 4 and 5, there would be no disproportionately high and adverse 

impacts to minority and low-income populations from the continued operation of DAEC during 

the license renewal term. As part of addressing environmental justice associated with license 

renewal, the NRC also analyzed the risk of radiological exposure through the consumption 

patterns of special pathway receptors, including subsistence consumption of fish, native 

vegetation, surface waters, sediments, and local produce; absorption of contaminants in 

sediments through the skin; and inhalation of plant materials. The special pathway receptors 

analysis is important to the environmental justice analysis because consumption patterns may 

reflect the traditional or cultural practices of minority and low-income populations in the area. 

4.9.7.4 Subsistence Consumption of Fish and Wildlife 

Section 4-4 of E.O. 12898 (E.O. 12898, 1994) directs Federal agencies, whenever practical and 

appropriate, to collect and analyze information on the consumption patterns of populations who 

rely principally on fish or wildlife, or both, for subsistence and to communicate the risks of these 

consumption patterns to the public. In this SEIS, the NRC considered whether or not there were 

any means for minority or low-income populations to be disproportionately affected by 

examining impacts to American Indian, Hispanic, and other traditional lifestyle special pathway 

receptors. Special pathways that took into account the levels of contaminants in native 

vegetation, crops, soils and sediments, surface water, fish, and game animals on or near the 

DAEC site were considered. 

FPL-DA has a comprehensive REMP at DAEC to assess the impact of site operations on the 

environment. The monitoring program at DAEC is based on comparing indicator and control 

samples. Samples to detect radiation in the environment are collected at indicator locations, 

which are nearby, downwind, or downstream of the plant and at control locations, which are 

more distant, upwind, or upstream from the plant. Radiation in the environment from DAEC 
Environmental Impacts of Operation 

October 2010 4-25 NUREG-1437, Supplement 42 

operations would be indicated if the radiation level at an indicator location was significantly 

larger than that at the control location. 

Samples are collected from the aquatic and terrestrial pathways applicable to the site. The 

aquatic pathways include fish, surface waters, groundwater, and river sediment. The terrestrial 

pathways include airborne particulates and radioiodine, milk, grain, hay and broad leaf 

vegetation, and direct radiation. During 2007 through 2009, analyses were performed on 

collected samples of environmental media as part of the required REMP, which showed no 

significant or measurable radiological impact from DAEC operations (FPL-DA, 2008d, 2009d, 

2010). The 2007 DAEC REMP report is incorporated by reference in this SEIS. 

No effects of plant operation were found in air quality or precipitation data. Radioactive 

concentrations in airborne particulates at both the indicator and control locations, were similar to 

historical levels. Levels of airborne iodine-131 were below the lower limit of detection. 

Precipitation from an onsite location was analyzed for tritium and gamma-emitting isotopes. No 

tritium activity was measured and no gamma-emitting isotopes were detected. Downwind 

rainwater samples measured small concentrations of tritium. 

Milk data showed no radiological effects of plant operation. Iodine-131 results were below 

detection limits, and no gamma-emitting isotopes, except naturally occurring potassium-40, 

were detected in milk samples. 

For potable groundwater, tritium activity measured below the lower limit of detection in all water 

samples, indicating no effects from plant operation. Twelve onsite groundwater monitoring wells 

were sampled and analyzed for gross beta and tritium. Analyses for gamma emitting isotopes, 

strontium-89 and strontium-90 were also performed. Although beta activity was found, this was 

most likely from naturally-occurring isotopes. Tritium was identified in 24 samples taken from 

the intermediate depth wells. No plant operational impact on groundwater was observed. 

Tritium was also identified in samples taken from the shallow wells; these tritium levels are 

attributed to gaseous effluent releases. Tritium levels were at very low levels and well below 

reporting criteria. 

With the exception of potassium-40, all other gamma-emitting isotopes were below detection 

limits in vegetation samples (broadleaf, grain, and forage). Measurable strontium-90 and 

cesium-137 activity was found in soil samples of one out of the two onsite locations. Activity 

levels were similar to, or lower, than those observed from 1991 through 2006, and were 

primarily attributable to deposition of fallout from past weapons testing and Chernobyl. 

Measurable tritium was detected on site in 4 of 12 sewage effluent samples at levels well below 

the EPA’s drinking water standard of 20,000 picocuries per liter (pCi/L). Tritium levels were 

below the lower limit of detection in all other surface water samples. 

With the exception of naturally-occurring potassium-40, no gamma-emitting isotopes were 

identified in edible portions of fish. The levels of potassium-40 were similar at both the indicator 

and control locations. River sediments were also analyzed for gamma-emitting isotopes. 

Potassium-40 activity was found, together with trace levels of cesium-137 activity at similar 

levels in both indicator and control samples. All other gamma-emitting isotopes were below 

detection limits. Tritium levels were at very low levels and well below reporting criteria. 

The results of the REMP sampling and previous REMP reports demonstrate that the routine 

operation at the DAEC site has no significant or measurable radiological impact on the 
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NUREG-1437, Supplement 42 4-26 October 2010 

environment. No elevated radiation levels have been detected in the offsite environment as a 

result of plant operations and the storage of radioactive waste. The results of the REMP 

continue to demonstrate that the operation of the plant does not result in a significant 

measurable dose to a member of the general population or adversely impact the environment 

as a result of radiological effluents (FPL-DA, 2008d). 

Based on these monitoring results, concentrations of contaminants in native vegetation, crops, 

soils and sediments, surface water, fish, and game animals in areas surrounding DAEC have 

been quite low (at or near the lower limits of detection) and seldom above background levels 

(FPL-DA, 2009d, 2010). Consequently, no disproportionately high and adverse human health 

impacts would be expected in special pathway receptor populations in the region as a result of 

subsistence consumption of fish and wildlife. 

4.10 EVALUATION OF NEW AND POTENTIALLY SIGNIFICANT INFORMATION 

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

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

Appendix B; or (2) information that was not considered in the analyses summarized in the GEIS 

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

codified in 10 CFR Part 51. 

In preparing to submit its application to renew the DAEC operating license, FPL-DA developed a 

process to ensure that information not addressed in, nor available during, the GEIS evaluation 

regarding the environmental impacts of license renewal for DAEC, would be properly reviewed 

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

related to renewal of the operating license for DAEC would be identified, reviewed, and 

assessed during the period of NRC review. FPL-DA staff reviewed the Category 1 issues that 

appear in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, to verify that the conclusions of 

the GEIS remained valid with respect to DAEC. This review was performed by personnel from 

DAEC and its support organization who were familiar with NEPA issues and the scientific 

disciplines involved in the preparation of a license renewal ER. 

The Staff also has a process for identifying new and significant information. That process is 

described in detail in NUREG-1555, Supplement 1, Standard Review Plans for Environmental 

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC, 1999b). 

The search for new information includes: (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 GEIS. For Category 1 issues where new and significant information 

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

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

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

The Staff has not identified any new and significant information on environmental issues listed in 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of DAEC during 

the period of license renewal. The Staff also determined that information provided during the 

public comment period did not identify any new issues that require site-specific assessment. 

The Staff reviewed the discussion of environmental impacts in the GEIS (NRC, 1996) and 
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October 2010 4-27 NUREG-1437, Supplement 42 

conducted its own independent review (including two public scoping meetings held in April 

2008) to identify new and significant information. 

4.11 CUMULATIVE IMPACTS 

The Staff considered potential cumulative impacts in the environmental analysis of continued 

operation of DAEC. For the purposes of this analysis, past actions are those related to the 

resources at the time of the power plant licensing and construction; present actions are those 

related to the resources at the time of current operation of the power plant; and future actions 

are considered to be those that are reasonably foreseeable through the end of plant operation 

including the period of extended operation. Therefore, the analysis considers potential impacts 

through the end of the current license term, as well as the 20-year renewal license term. The 

geographic 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. 

4.11.1 Land Use 

Consistent with the findings in the GEIS, the Staff concludes that the impacts from continued 

operation of DAEC on land use are SMALL. For the purposes of this cumulative impact 

assessment, the spatial bounds of consideration include the region within a 50-mi radius of the 

site and the transmission line corridors. The Staff concludes that when combined with other 

past, present, and reasonably foreseeable future actions, the cumulative impact of 

DAEC-related actions during the term of license renewal on land use would be SMALL. 

4.11.2 Cumulative Air Quality Impacts 

DAEC is located in Linn County, Iowa, which belongs to the EPA Region VII. Linn County is a 

part of the Northeast Iowa Intrastate Air Quality Control Region as codified in 40 CFR §81.256. 

All counties in the State of Iowa are currently in attainment for all National Ambient Air Quality 

Standards (NAAQS). In the “2008 FPL Group Sustainability Report,” Florida Power and Light 

(FPL) highlighted the environmental goals of the company with the emphasis on lowering 

greenhouse gas (GHG) emissions by at least 50 percent below 2000 levels by 2050 and 

implementing energy efficiency measures along with the use of the renewable resources 

(FPL, 2009). 

Consistent with the findings in the GEIS, the Staff concludes that the impacts from continued 

operation of the DAEC on air quality are SMALL. As no refurbishment is planned at DAEC 

during license renewal period, no additional air emissions would result from refurbishment 

activities (FPL-DA 2008a). In comparison with construction and operation of a comparable 

fossil-fueled power plant, license renewal would result in a net cumulative deferral of GHG 

emissions, which would otherwise be produced if a new gas or coal-fired plant were instead 

constructed. When compared with the alternative of a new fossil-fuel power plant, the option of 

license renewal also results in a net cumulative deferral in toxic air emissions. 

For the purpose of this cumulative air impact assessment, the spatial bounds includes the 

Northeast Iowa Intrastate Air Quality Control Region. The Staff concludes that combined with 

the emissions from other past, present, and reasonably foreseeable future actions, cumulative 

hazardous and criteria emissions on air quality from DAEC-related actions would be SMALL. 

When considered with respect to an alternative of building a fossil-fuel powered plant, 

continuing the operation of the DAEC could constitute a net cumulative beneficial environmental 

impact in terms of emission offsets (i.e., reducing hazardous, criteria, and GHG air emissions) 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-28 October 2010 

that would otherwise be generated by a fossil-fuel plant; only the Combined Alternative 

(described in Chapter 6) would be equivalent to or would contribute less cumulative emissions 

than the option of license renewal. 

4.11.3 Cumulative Impact on Water Resources 

For the purposes of this cumulative impact assessment, the spatial bounds of the groundwater 

system are the alluvial aquifer and Wapsipinicon and Gower aquifer formations; and the surface 

water boundary is the Cedar River Basin. Cedar Rapids, Iowa, is about 15 mi (24 km) 

downstream of DAEC. The Cedar Rapids Water Department draws its water supply from the 

alluvium along the river, relying on four well fields with four collector wells and 45 vertical wells. 

The average supply rate to residential and industrial customers is 35 million gallons per day 

(gpd) (130,000 cubic meters per day (m3

/day)). 

Actions impacting groundwater and surface water resources in the region include overuse of 

groundwater and surface water resources, unregulated use of water resources, drought 

impacts, and the need for flow compensation for consumptive water users. Similar impacts from 

future activities are likely. 

Within the DAEC local area, private well users are not known to have experienced issues with 

declining water levels in their wells. Therefore, it appears reasonable that the use of 

groundwater by the plant is not contributing to a significant cumulative effect on local 

groundwater users or larger regional users. Based on this reasoning, the Staff concludes that 

when added to the groundwater usage from other past, present, and reasonably foreseeable 

future actions, the cumulative impact on groundwater use is SMALL. 

During a drought, the effect of low-flow river conditions on the Cedar River would be magnified. 

As discussed in Section 2.1.7.2, flow in the Cedar River at Cedar Rapids averages 3,878 cfs 

(110 m3

/s). Flow at DAEC is expected to be similar because no major tributaries enter the river 

between the facility and Cedar Rapids. The design rate for DAEC water withdrawal under 

operating conditions is 11,200 gpm (25 cfs or 0.71 m3

/s), or approximately 0.6 percent of the 

average river flow. 

During Cedar River low-flow periods, the withdrawal rate and consumptive rate are higher 

proportions of the river flow. By permit, when river flow falls below 500 cfs (14 m3

/s), the 

Pleasant Creek Recreational Reservoir may discharge to the Cedar River at a rate equal to the 

consumptive use rate of 18 cfs (0.51 m3

/s) (IDNR, 2005); However, discharge from the reservoir 

to the river is not a requirement of the permit. At this low-flow threshold, the withdrawal rate is 

5 percent of the low flow, and the return of blowdown to the river results in a net consumptive 

rate of 3.6 percent of the low river flow. Because the discharge from the river, even during 

periods of low flow, is relatively small, the DAEC consumptive use of water is not expected to 

have a substantial adverse affect on the water supply, recreation, or aquatic habitat. For this 

reason, the Staff has determined that consumptive use of water for continued DAEC operation, 

when combined with other past, present, and reasonably foreseeable future activities, including 

potential ethanol production would result in a SMALL cumulative surface water impact. 

4.11.4 Cumulative Impacts on Aquatic Resources 

This section addresses past, present, and future actions that could result in adverse cumulative 

impacts to aquatic resources within the Cedar River. The headwaters of the Cedar River are 

located in Dodge County, Minnesota, where its tributaries, the Little Cedar and the Shell Rock 
Environmental Impacts of Operation 

October 2010 4-29 NUREG-1437, Supplement 42 

Rivers merge. The Cedar River flows southeast for 329 mi (529 km) through Iowa to its 

confluence with the Iowa River in Columbus Junction, Louisa County, Iowa, about 30 mi (48 km) 

upstream of the mouth of the Iowa River (Sullivan, 2000). For purposes of this analysis, the 

geographic area considered for cumulative impacts on aquatic resources is the Cedar River 

Basin. 

Water quality is of concern in the Cedar River and multiple stretches of the river are on the 

Clean Water Act (CWA) Section 303(d) 2008 list of impaired waters for high levels of bacteria, 

algae, polychlorinated biphenyls (PCBs) in fish, and mercury in fish (IDNR, 2008). Eight total 

areas have been identified as “impaired,” none of which currently have a water quality 

improvement plan in place (IDNR, 2008). “Impaired,” as defined by the IDNR, does not 

necessarily mean that the water body is highly polluted. Many waters on the 2008 303(d) list 

are considered “impaired” rather than “fully supported” due to the absence of only a few key 

aquatic species, but these waters can continue to support a moderate level of aquatic diversity 

(IDNR, 2009b). However, for those waters with high levels of bacteria, the designation of 

“impaired” may indicate potential risks to recreational use (IDNR, 2009b). Because of the high 

percentage of agricultural land along the Cedar River, the majority of the pollution originates 

from nonpoint sources including pesticide and other chemical runoff, soil erosion, and nutrient 

loading from fertilizers and other organic sources. The IDNR has a Nonpoint Source 

Management Program to address some of these issues across the State. 

Current municipal and industrial effluents to the Cedar River in the vicinity of DAEC are, and will 

continue to be, regulated through NPDES permits by the IDNR. For facilities using the Cedar 

River as a source of cooling water, the NPDES permit will also contain regulations pertaining to 

the impingement and entrainment of fish and shellfish and temperature limits on heated 

effluents to the river. The IDNR periodically reviews and renews NPDES permits, thus 

regulating the flow of industrial effluents to the river in a manner that preserves water quality 

and protects aquatic resources from impingement and entrainment through implementation of 

the best technology available and other mitigative measures. 

Because the Cedar River is not a major navigational travel route, channelization and dredging is 

not an issue at this time. Erosion from severe weather and flooding has likely affected 

sedimentation and clarity of the Cedar River, which may affect fish habitat locally, though this 

impact is not expected to significantly alter any fish populations. 

As no protected aquatic species are known to occur on or in the vicinity of the DAEC site, 

protected species, discussed in Section 2.2.7, are not expected to be adversely affected due to 

future actions during the renewal term. 

The Staff examined the cumulative effects of effluents on Cedar River water quality, impacts to 

protected species, and effects of neighboring facilities. The Staff concludes that the minimal 

aquatic impacts on the continued DAEC operations would not contribute to the overall decline to 

the condition of aquatic resources. The Staff believes that the cumulative impacts of 

DAEC-related actions during the term of license renewal on aquatic habitat and associated 

species, when added to past, present, and reasonably foreseeable future actions, would be 

SMALL. 

4.11.5 Cumulative Impacts on Terrestrial Resources 

This section addresses past, present, and future actions that could result in adverse cumulative 

impacts to terrestrial resources, including wildlife populations, prairie and woodlands, riparian 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-30 October 2010 

zones, invasive species, protected species, and land use. For the purposes of this analysis, the 

geographic area considered in this evaluation includes the DAEC site and in-scope transmission 

line ROWs. 

Approximately 100 ac (40 hectares (ha)) of the 500-ac (200-ha) site was originally disturbed for 

plant construction and associated machinery (AEC, 1973). In total, 140 ac (57 ha) contain the 

generating facility, associated buildings, switchyard, parking lots, and mowed areas (FPL-DA, 

2008a). The site is situated on the western bank of the Cedar River. Before DAEC was 

constructed, the majority of the site’s land was cultivated with some grassland and woodland 

areas on and near the site (FPL-DA, 2008a). Because the land was previously farmed, no trees 

were removed during construction of DAEC (AEC, 1973). Removal of vegetation on the bank of 

the Cedar River for intake and discharge construction resulted in some erosion of the river bank; 

however, the FES (AEC, 1973) states that the applicant replanted these areas after construction 

to mitigate the effects of clearing the area. 

Construction of the transmission lines required 1,155 ac (467 ha) to be disturbed for the 85 mi 

(137 km) of lines constructed for plant operation (AEC, 1973). About 21 percent, or 18 mi 

(29 km), of the constructed lines were routed along public roads or railroads and utilized existing 

ROWs, which minimized the impact of land disturbance associated with line construction and 

ROW clearance. The remaining 67 mi (108 km) of constructed lines were constructed over 

private property, of which 85.9 percent was previously cultivated, 6.5 percent was pasture, 

3.6 percent was wooded, and 4 percent was marshland (AEC, 1973). Some minor habitat 

fragmentation may have occurred as a result of line construction and ROW clearance through 

forested and marsh areas, which may have resulted in edge effects such as changes in light, 

wind, and temperature; changes in abundance and distribution of interior species; and reduced 

habitat ranges for certain species. ROW maintenance has likely had past impacts and is likely 

to have present and future impacts on the terrestrial habitat, which may include bioaccumulation 

of chemicals, prevention of the natural successional stages of the surrounding vegetative 

communities in the ROWs, an increase in abundance of edge species, a decrease in 

abundance of interior species, and an increase in invasive species populations. 

As no protected terrestrial species are known to occur on or in the vicinity of the DAEC site, 

protected species, discussed in Section 2.2.7, are not expected to be adversely affected due to 

future actions during the renewal term. Numerous parks and natural areas are located in the 

vicinity of the DAEC site, which will continue to provide habitat for protected species and other 

wildlife. 

The Prairie Creek Generating Station, owned by Interstate Power and Light Company and 

operated by Alliant Energy, is located along the Cedar River approximately 20 mi (32 km) 

downstream of DAEC in Cedar Rapids, Iowa. The 245-megawatt (MW) coal-fired plant began 

operation in 1951 and has a total of four units, the latest of which began operating in 1997. In 

addition to the Prairie Creek Generating Station, five other fossil-fuel fired generating facilities 

are located within a 50-mi (80-km) radius of DAEC. These facilities are the 6th Street 

Generating Station and the Archer Daniels Midland Cedar Rapids Plant, both in Cedar Rapids, 

Iowa; and the Streeter Station, the Electrifarm Generating Station, and the Cedar Falls Gas 

Turbine Station, which are in Black Hawk County, Iowa (FPL-DA, 2008a). Coal-fired plants are 

a major source of air pollution in the United States because they release sulfur dioxide, nitrogen 

oxides, mercury, carbon dioxide, and particulates. Nitrous oxides and sulfur dioxides combine 

with water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury 

deposits onto soil and surface water, which may then be taken up by terrestrial and aquatic 

plant or animal species and poses the risk of bioaccumulation. For these reasons, the Prairie 
Environmental Impacts of Operation 

October 2010 4-31 NUREG-1437, Supplement 42 

Creek Generating Station and other generating facilities near DAEC are likely to have current 

and future adverse effects to the environment in the Cedar River Basin. 

The majority of land surrounding the DAEC site is rural and used for agricultural purposes. 

Pesticide and herbicide runoff is a primary contributor of water pollutants in the Cedar River and 

its tributaries. Additionally, the cities of Waterloo, Iowa City, and Cedar Rapids lie 34 mi (55 km) 

to the northwest, 32 mi (52 km) to the northeast, and 5.7 mi (9.2 km) to the southeast of DAEC, 

respectively. Continued development of these areas may result in additional runoff from roads 

and impervious surfaces, development adjacent to wetlands and riparian zones, and an 

increase in waste releases, all of which could have adverse impacts on terrestrial habitat. 

The Staff examined the cumulative effects of initial construction of the site and transmission 

lines, impacts to protected species, effects of neighboring facilities, and continued land 

development in the Cedar Rapids area. The Staff concludes that the minimal terrestrial impacts 

on the continued DAEC operations would not contribute to the overall decline in the condition of 

terrestrial resources. The Staff believes that the expected cumulative impacts of other and 

future actions during the term of license renewal on terrestrial habitat and associated species, 

when added to past, present, and reasonably foreseeable future actions, are SMALL. 

4.11.6 Cumulative Human Health Impacts 

The NRC and the EPA established radiological dose limits for protection of the public and 

workers from both acute and long-term exposure to radiation and radioactive materials. These 

dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. As discussed in Section 4.8.1, 

the doses resulting from operation of DAEC are below regulatory limits and the impacts of these 

exposures are SMALL. For the purposes of this cumulative impact analysis, the geographical 

area involves a 50-mi (80-km) radius around the DAEC site. 

EPA regulations in 40 CFR Part 190 limit the dose to members of the public from all sources in 

the nuclear fuel cycle, including nuclear power plants, fuel fabrication facilities, waste disposal 

facilities, and transportation of fuel and waste. In addition, as discussed in Section 4.8.1, DAEC 

conducts a REMP around its site, which was initiated before commercial operation began in 

1975. This program measures radiation and radioactive materials from DAEC and all other 

sources. 

As discussed in Section 4.8.1 of this report, the Staff reviewed the radiological environmental 

monitoring results for DAEC over the 5-year period from 2004–2008 as part of this cumulative 

impacts assessment. Cumulative radiological impacts from all uranium fuel cycle facilities within 

a 50-mi (80-km) radius of the DAEC site are limited by the dose limits in 10 CFR Part 20 and 

40 CFR Part 190. There are no other uranium fuel-cycle facilities within a 50-mi (80-km) radius 

of DAEC. 

Based on the Staff’s review of DAEC’s radiological environmental monitoring results, the 

radioactive effluent release data, and the expected continued compliance with Federal radiation 

protection standards, the cumulative radiological impacts to human health when combined with 

all past, present, and reasonably foreseeable future actions would be SMALL. The NRC and 

the State of Iowa will regulate any future development or actions in the vicinity of the DAEC site 

that could contribute to cumulative radiological impacts. 

As discussed in Section 4.8.2, the continued operation of DAEC has a low risk of causing 

outbreaks from thermophilic microbiological organisms associated with thermal discharges. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-32 October 2010 

Available data compiled into biannual reports by the CDC for the years 1999 to 2006 (CDC, 

2000), (CDC, 2002), (CDC, 2004), (CDC, 2006) indicates no occurrence of waterborne disease 

outbreaks in the State of Iowa resulting from exposure to the thermophilic microbiological 

organisms Naegleria fowleri and Pseudomonas aeruginosa.

As part of its evaluation of cumulative impacts, the Staff also considered the effects of thermal 

discharges from other facilities on the Cedar River located within 1 mi upstream of DAEC that 

are also producing thermal effluents. Such facilities could promote the growth of thermophilic 

microbiological organisms. The Staff did not identify any such facilities. The Staff concludes 

that thermophilic microbiological organisms are not likely to present a public health hazard as a 

result of DAEC discharges to the Cedar River. The Staff concludes that when combined with 

other past, present, and reasonably foreseeable future actions, the cumulative impact on public 

health from thermophilic microbiological organisms would be SMALL. 

The Staff determined that the DAEC transmission lines are operating within original design 

specifications and meet current NESC clearance standards. The DAEC transmission lines, 

when combined with other past, present, and reasonably foreseeable future electrical sources, 

contribute only a SMALL cumulative potential for electric shock. 

With respect to the chronic effects of EMF, although the GEIS finding of “uncertain” is 

appropriate to DAEC, the transmission lines associated with DAEC are not likely to detectably 

contribute to the regional exposure of ELF-EMFs. Therefore, the Staff has determined that 

when combined with other past, present, and reasonably foreseeable future actions, the 

continued operation of the DAEC transmission lines on cumulative chronic EMF impacts would 

be SMALL. 

4.11.7 Cumulative Socioeconomic Impacts 

For the purposes of this cumulative impact assessment, the geographical bounds of the 

analysis are Linn and Benton counties. As discussed in Section 4.9 of this DSEIS, the 

continued operation of DAEC during the license renewal term would have no measurable 

impact on socioeconomic conditions in the region beyond those already being experienced. 

Since FPL-DA has no plans to hire additional workers during the license renewal term, overall 

expenditures and employment levels at DAEC would remain relatively constant with no 

additional demand for permanent housing, public utilities, and public services. In addition, since 

employment levels and the value of DAEC would not change, there would be no population and 

tax revenue-related land-use impacts. There would also be no disproportionately high or 

adverse health or environmental impacts on minority and low-income populations in the region. 

Based on this and other information presented in Chapter 4 of this DSEIS, there would be no 

cumulative socioeconomic impacts from the continued operation of DAEC during the license 

renewal term beyond what is already being experienced. 

4.11.8 Historic and Archaeological Resources Cumulative Impacts 

As discussed in Section 4.9.6, potential impacts to historic and archaeological resources are 

possible due to the potential richness of archaeological resources on the DAEC property. 

DAEC in coordination with the SHPO has revised and implemented its excavation and trenching 

procedures and developed a cultural resource management plan for the plant property. These 

plans address potential impacts to both known and undiscovered resources. Plant procedures 

also include an inadvertent discovery (stop work) provision. NRC has concluded that the 
Environmental Impacts of Operation 

October 2010 4-33 NUREG-1437, Supplement 42 

impacts of continued operation could have a MODERATE impact on historic and archaeological 

resources. 

Past activities have included site clearing and the construction of facilities, parking lots, security 

trenches, roads, and other ancillary structures, as well as clearing, construction, and 

maintenance of the transmission line corridors. 

For the purposes of this cumulative impact assessment, the spatial bounds include the DAEC 

site and transmission lines corridors. Cumulative impacts to historic and archaeological 

resources can result from the incremental loss of unique site types. DAEC has no plans to alter 

the DAEC site for license renewal. Any land disturbing activities would be considered through 

the DAEC revised excavation and trenching procedures. Given that the DAEC plant property 

has the potential for unknown resources, the Staff concludes that when combined with other 

past, present, and reasonably foreseeable future land disturbing activities, the potential 

cumulative impacts on historic and archaeological resources could be MODERATE. Cumulative 

impacts could be partly mitigated through application of the mitigation measures discussed in 

Section 4.9.6. 

4.11.9 Summary of Cumulative Impacts 

The Staff considered the potential impacts resulting from operation of DAEC during the period of 

extended operation and other past, present, and reasonably foreseeable future actions in the 

vicinity of DAEC. The preliminary determination is that the potential cumulative impacts 

resulting from DAEC operation during the period of extended operation would range from 

SMALL to MODERATE. Table 4-12 summarizes the cumulative impact by resource area. 
Environmental Impacts of Operation 

NUREG-1437, Supplement 42 4-34 October 2010 

Table 4-12. Summary of Cumulative Impacts on Resource Areas 

Resource Area Impact Summary 

Land use SMALL With respect to the DAEC facility, no measurable changes in 

land use would occur over the proposed license renewal term. 

When combined with other past, present, and reasonably 

foreseeable future activities, impacts from continued operation 

of DAEC would constitute a SMALL cumulative impact on 

land use. 

Air quality resources SMALL Impacts of air emissions over the proposed license renewal 

term would be SMALL. When combined with other past, 

present, and reasonably foreseeable future activities, air 

emissions from DAEC would constitute a SMALL cumulative 

impact on air quality. In comparison with the alternative of 

constructing and operating a comparable gas or coal-fired 

power plant, license renewal would result in a net cumulative 

deferral in both GHG and other toxic air emissions, which 

would otherwise be produced by a fossil-fueled plant. 

Water resources SMALL The Staff concludes that DAEC groundwater consumption, 

when added to groundwater usage from other past, present, 

and reasonably foreseeable future withdraws, constitutes a 

SMALL cumulative impact on groundwater. 

Water taken from the Cedar River to support DAEC 

operations normally constitutes a SMALL effect upon water 

usage and conflicts even during times of drought. When this 

DAEC water consumption is added to other past, present, and 

reasonably foreseeable future surface water withdraws, the 

cumulative impact upon the Cedar River is SMALL. 

Aquatic resources SMALL Past and present activities have adversely impacted aquatic 

resources. Agricultural and other development activities 

continue to adversely affect aquatic resources, and will likely 

continue to do so in the future. When combined with other 

past, present, and reasonably foreseeable future activities, 

continued operation of DAEC would produce a SMALL 

cumulative impact on aquatic resources. 

Terrestrial resources SMALL Past and present activities have adversely affected terrestrial 

habitat and species in the vicinity of DAEC, and would likely to 

continue to do so into the future. When combined with other 

past, present, and reasonably foreseeable future activities, 

continued operation of DAEC would continue to produce a 

SMALL cumulative impact on aquatic resources. 

Human health SMALL When combined with the other past, present, and reasonably 

foreseeable future activities, the cumulative human health 

impacts of continued operation of DAEC from radiation 

exposure to the public, microbiological organisms from 

thermal discharge to the Cedar River, and 

electric-field-induced currents from the DAEC transmission 

lines would all be negligible to SMALL. 

Socioeconomics SMALL to 

MODERATE 

When combined with the other past, present, and reasonably 

foreseeable future activities, impacts to socioeconomic 

resources (with the exception of historic and archaeological) 

from continued operation of DAEC have no measurable 

cumulative impact. However, the potential cumulative land 

disturbance impact on historic and archaeological resources 

could be MODERATE. 
Environmental Impacts of Operation 

October 2010 4-35 NUREG-1437, Supplement 42 

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Linn County Public Health (LCPH). 2005. Letter from A. Daugherty, LCPH, Cedar Rapids, IA, 

to A. Gould, FPL Energy, Juno Beach, FL, Subject: “Air Construction Permits – Ownership 

Changes,” November 28, 2005. 

Linn County Public Health (LCPH). 2008. Letter from J. Hodina, LCPH, Cedar Rapids, IA, to R. 

Anderson, DAEC, Palo, IA, Subject: “Approval of Variance Request,” September 9, 2008. 

Louis Berger Group, Inc. 2006. “Phase I Archaeological Survey for Cedar River Rip-Rap, Linn 

County, Iowa,” Archaeological Survey Short Report Form, State Historical Society of Iowa, 

Prepared for United States Army Corps of Engineers, October 2006. 

Louis Berger Group, Inc. 2008. “Cultural Resource Assessment of the Duane Arnold Energy 

Center Property, Near Palo, Linn County, Iowa,” Prepared for Florida Power and Light Energy, 

LLC, DAEC, Palo, IA, June 2008. 

Niemann, M.S. and D.B. MacDonald. 1972. “An Ecological Study of the Terrestrial Plant 

Communities in the Vicinity of the Duane Arnold Energy Center,” Prepared for Iowa Electric 

Light and Power Company, Cedar Rapids, IA, August 1972. 

Northway Well and Pump Co. 2001. Data sheets from aquifer test performed November 13, 

2001 at Well A. 

Rogers, L.D. and W.C. Page. 1993. “Linn County Comprehensive Planning Project Phase 

Two: Archaeological, Historical, and Architectural Survey Subsection E (Fayette Township),” 

Prepared for the Linn County Historic Preservation Commission and the State Historical Society 

of Iowa, Historic Preservation Bureau, September 1993. 

Sullivan, D.J. 2000. “Fish Communities and Their Relation to Environmental Factors in the 

Eastern Iowa Basins in Iowa and Minnesota, 1996,” Water-Resources Investigations Report 

00-4194. Available URL: http://pubs.usgs.gov/wri/2000/wri004194/pdf/wri00_4194.pdf

(accessed April 24, 2009). 

Todar, K. 2007. “Todar’s online textbook of bacteriology.” Available URL: 

http://www.textbookofbacteriology.net

University of Iowa (UI). 2001. “Phase I Intensive Archaeological Survey of a Proposed Dry 

Spent Fuel Storage Facility, Alliant Energy Corporation, Section 9, T83N-R8W, Linn County, 

Iowa,” Office of the State Archaeologist, Iowa City, IA, December 4, 2001. 

U.S. Atomic Energy Commission (AEC). 1973. “Final Environmental Statement Related to 

Operation of Duane Arnold Energy Center,” Iowa Electric Light and Power Company Docket No. 

50-331, Facility Operating License DPR-49, Directorate of Licensing, Washington, D.C., March 

1973, ADAMS Accession No. ML091200609. 

U.S. Bureau of the Census (USCB). 2009. American Fact Finder. Available URL: 

http://factfinder.census.gov/

U.S. Fish and Wildlife Service (USFWS). 2009. Letter from R. Nelson, Field Supervisor, Rock 

Island Field Office, to D. Pelton, Branch Chief, Division of License Renewal, Subject: “Response 

to letter requesting a list of protected species within the area under evaluation for the Duane 

Arnold Energy Center license renewal application,” May 29, 2009, ADAMS Accession No. 

ML092020070.

U.S. Global Change Research Program (USGCRP). 2009. “Global Climate Change Impacts in 

the United States,” Cambridge University Press. 
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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., 

ADAMS Accession Nos. ML040690705 and ML040690738. 

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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., ADAMS Accession No. 

ML040690720. 

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Standard Review Plans for Environmental Reviews for Nuclear Power Plants, NUREG-1555, 

October 1999, ADAMS Accession No. ML003701937. 

U.S. Nuclear Regulatory Commission (NRC). 2009a. Letter from D. Pelton, Branch Chief, 

Division of License Renewal, to T. Melius, Regional Director, Region 3, U.S. Fish and Wildlife 

Service, Subject: “Request for List of Protected Species Within the Area Under Evaluation for 

the Duane Arnold Energy Center License Renewal Application Review,” May 6, 2009, ADAMS 

Accession No. ML091210033. 

U.S. Nuclear Regulatory Commission (NRC). 2009b. Letter from D. Pelton, Branch Chief, 

Division of License Renewal, to W. Gieselman, Administrator, Iowa Department of Natural 

Resources, Subject: “Request for List of Protected Species within the Area Under Evaluation for 

the Duane Arnold Energy Center License Renewal Application Review,” May 6, 2009, ADAMS 

Accession No. ML091200651. 

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Health Criteria Monograph No.238,” World Health Organization, Geneva, Switzerland. Available 

URL: http://www.who.int/peh-emf/publications/elf_ehc/en/index.html (accessed August, 2008 

October 2010 5-1 NUREG-1437, Supplement 42 

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 

This chapter describes the environmental impacts from postulated accidents that the Duane 

Arnold Energy Center (DAEC) might experience during the period of extended operation. For a 

more detailed discussion of this assessment, the reader is referred to Appendix F. The term 

“accident” refers to any unintentional event outside the normal plant operational envelope that 

results in a release or the potential for release of radioactive materials into the environment. 

Two classes of postulated accidents are evaluated in the Generic Environmental Impact 

Statements (GEIS) for License Renewal of Nuclear Power Plants (NRC, 1996), (NRC, 1999) 

prepared by the U.S. Nuclear Regulatory Commission (NRC), as listed in Table 5-1. These two 

classes include: 

● design-basis accidents (DBAs) 

● severe accidents 

Table 5-1. Issues Related to Postulated Accidents. Two issues related to postulated 

accidents are evaluated under the National Environmental Policy Act (NEPA) in the license 

renewal review: design-basis accidents and severe accidents.

Issues GEIS Section Category 

Design-basis accidents 5.3.2; 5.5.1 1 

Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3; 5.3.3.4; 5.3.3.5; 5.4; 5.5.2 2 

Generic issues (Category 1 issues, see Chapter 1) rely on the analysis provided in the GEIS and are discussed 

briefly (NRC 1996,1999a). 

5.1 DESIGN-BASIS ACCIDENTS 

As part of the process for receiving NRC approval to operate a nuclear power facility, an 

applicant for an initial operating license must submit a safety analysis report (SAR) as part of its 

application. The SAR presents the design criteria and design information for the proposed 

reactor and comprehensive data on the proposed site. The SAR also discusses various 

hypothetical accident situations and the safety features that are provided to prevent and mitigate 

accidents. The NRC staff (Staff) reviews the application to determine whether or not the plant 

design meets the NRC’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 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) Parts 50 

and 100. 

The environmental impacts of DBAs are evaluated during the initial licensing process. Before a 

license renewal is issued, the DBA assessment must demonstrate that the plant can withstand 

these accidents. The results of these evaluations are found in license documentation such as 
Environmental Impacts of Postulated Accidents 

NUREG-1437, Supplement 42 5-2 October 2010 

the applicant’s final safety analysis report (FSAR), the 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 maximumally 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 the period of extended operation, the environmental impacts, as 

calculated for DBAs, should not differ significantly from initial licensing assessments over the life 

of the plant, including the period of extended operation. Accordingly, the design of the plant 

relative to DBAs during the period of extended operation is considered to remain acceptable 

and the environmental impacts of those accidents were not examined further in the GEIS. 

The Commission has determined that the significance level of the environmental impacts of 

DBAs are SMALL for all plants because the plants were designed to successfully withstand 

these accidents. For the purposes of license renewal, DBAs have been designated as a 

Category 1 issue. 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. 

No new and significant information related to DBAs was identified during the review of Florida 

Power and Light Energy Duane Arnold, LLC’s (FPL-DA) environmental report (ER) (FPL-DA, 

2008), the site audit, the scoping process, or evaluation of other available information. 

Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. 

5.2 SEVERE ACCIDENTS 

Severe nuclear accidents are those that are more severe than DBAs because they could result 

in substantial damage to the reactor core, whether or not there are serious offsite 

consequences. In the GEIS, the Staff assessed the impacts of severe accidents during the 

period of extended operation, using the results of existing analyses and site-specific information 

to conservatively predict the environmental impacts of severe accidents for each plant during 

the period of extended operation. 

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 DAEC site in the GEIS (NRC, 1996). However, the 

GEIS did evaluate existing impact assessments performed by the Staff 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. The GEIS for license renewal 

performed a discretionary analysis of sabotage in connection with license renewal and 

concluded that the core damage and radiological release from such acts would be no worse 

than the damage and release expected from internally-initiated events. In the GEIS, the NRC 

concludes that the risk from sabotage and beyond design-basis earthquakes at existing nuclear 

power plants is SMALL and additionally, that the risks from other external events are adequately 

addressed by a generic consideration of internally-initiated severe accidents (NRC, 1996). 
Environmental Impacts of Postulated Accidents 

October 2010 5-3 NUREG-1437, Supplement 42 

Based on information in the GEIS, the NRC found that: 

The probability weighted consequences of atmospheric releases, fallout onto 

open bodies of water, releases to ground water, 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. 

The Staff identified no new and significant information related to postulated accidents during the 

review of FPL-DA’s ER (FPL-DA, 2008), the site audit, the scoping process, or evaluation of 

other available information. Therefore, there are no impacts related to these issues beyond 

those discussed in the GEIS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the Staff 

reviewed severe accident mitigation alternatives (SAMAs) for DAEC. The results of the review 

are discussed in Section 5.3. 

5.3 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

The Federal regulation 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), 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 DAEC, therefore, the remainder of Chapter 5 addresses those 

alternatives. 

5.3.1 Introduction 

This section presents a summary of the SAMA evaluation for DAEC conducted by FPL-DA and 

the Staff’s review of that evaluation. The Staff performed its review with contract assistance 

from Information Systems Laboratories. The Staff’s review is available in full in Appendix F; the 

SAMA evaluation is available in full in FPL-DA’s ER. 

The SAMA evaluation for DAEC was conducted with a four-step approach. In the first step, 

FPL-DA quantified the level of risk associated with potential reactor accidents using the 

plant-specific probabilistic risk assessment (PRA) and other risk models. 

In the second step, FPL-DA examined the major risk contributors and identified possible ways 

(i.e., SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 

systems, procedures, and training. FPL-DA identified 166 potential SAMAs for DAEC. FPL-DA 

performed an initial screening to determine if any SAMAs could be eliminated because they are 

not applicable to DAEC due to design differences, have already been implemented at DAEC, 

are similar in nature and could be combined with another SAMA candidate, or have excessive 

implementation costs. This screening reduced the list of potential SAMAs to 24. 

In the third step, FPL-DA estimated the benefits and costs associated with each of the 

remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 

estimates were developed in terms of dollars in accordance with NRC guidance for performing 

regulatory analyses (NRC, 1997). The cost of implementing the proposed SAMAs was also 

estimated. 
Environmental Impacts of Postulated Accidents 

NUREG-1437, Supplement 42 5-4 October 2010 

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). FPL-DA concluded in its ER that 

several of the SAMAs evaluated are potentially cost-beneficial (FPL-DA, 2008). 

FPL-DA’s SAMA analyses and the Staff’s review are discussed in more detail below. 

5.3.2 Estimate of Risk 

FPL-DA submitted an assessment of SAMAs for DAEC as part of the ER (FPL-DA, 2008). This 

assessment was based on the most recent DAEC PRA available at that time; a plant-specific 

offsite consequence analysis performed using the MELCOR Accident Consequence Code 

System 2 (MACCS2) computer program, and insights from the DAEC Individual Plant 

Examination (IPE) (IELP, 1992) and Individual Plant Examination of External Events (IPEEE) 

(IES, 1995). 

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is 

approximately 1.08 x 10-5 per year (see Appendix F for details). The CDF value is based on the 

risk assessment for internally-initiated events. FPL-DA did not include the contributions from 

external events within the DAEC risk estimates; however, it did account for the potential risk 

reduction benefits associated with external events by multiplying the estimated benefits for 

internal events by a factor of 1.57. The breakdown of CDF by initiating event is provided in 

Table 5-2 (see Appendix F.2 for details). 

Table 5-2. Duane Arnold Energy Center Core Damage Frequency for Internal Events 

Initiating Event 

CDF 

(per year) 

% Contribution to 

CDF 

Loss of Offsite Power 4.0 × 10–6 37 

Turbine Trip with Bypass 1.6 × 10–6 15 

Main Steam Isolation Valve (MSIV) Closure 1.4 × 10–6 13 

Inadvertent Open Relief Valve 1.2 × 10–6 11 

Loss of Condenser Vacuum 5.9 × 10–7 6 

Div 2 125 Volt DC Bus Failure 3.2 × 10–7 3 

Manual Shutdown 2.8 × 10–7 3 

Loss of River Water Supply 2.8 × 10–7 3 

Small Loss of Coolant Accident (LOCA) 2.7 × 10–7 3 

Loss of Feedwater 2.5 × 10–7 2 

Medium LOCA 1.9 × 10–7 2 

Div 1 125 Volt DC Bus Failure 1.3 × 10–7 1 

Others (less than 1 percent each) 2.8 × 10–7 3 

Total CDF (internal events) 1.08 × 10–5 100 

As shown in this table, events initiated by loss of offsite power and other transients (e.g., turbine 

trip, MSIV closure, and inadvertent opening of the relief valve) are the dominant contributors to 

the CDF. 
Environmental Impacts of Postulated Accidents 

October 2010 5-5 NUREG-1437, Supplement 42 

FPL-DA estimated the dose to the population within 50 miles (80 kilometers) of the DAEC site to 

be approximately 19.8 person-roentgen equivalent man (rem) (0.198 person-sievert (Sv)) per 

year. The breakdown of the total population dose by containment release mode is summarized 

in Table 5-3. Releases from the containment within the early timeframe (0 to less than 6 hours 

following event initiation) dominate the population dose risk at DAEC. 

Table 5-3. Breakdown of Population Dose by Containment Release Mode 

Containment Release Mode 

Population Dose 

(Person-Rem(a) Per Year) % Contribution 

Early Releases (< 6 hrs) 14.1 71 

Intermediate Releases (6 to <24 hrs) 4.2 21 

Late Releases (≥ 24 hrs) 1.5 8 

Total 19.8 100 

(a) One person-rem = 0.01 person-Sv

The Staff reviewed FPL-DA’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 FPL-DA. 

5.3.3 Potential Plant Improvements 

Once the dominant contributors to plant risk were identified, FPL-DA searched for ways to 

reduce that risk. In identifying and evaluating potential SAMAs, FPL-DA considered insights 

from the plant-specific PRA and SAMA analyses performed for other operating plants that have 

submitted license renewal applications. FPL-DA identified 166 potential risk-reducing 

improvements (i.e., SAMAs) to plant components, systems, procedures, and training. 

FPL-DA removed all but 24 of the SAMAs from further consideration because they are not 

applicable at DAEC due to design differences, have already been implemented at DAEC, are 

similar in nature and could be combined with another SAMA candidate, or have excessive 

implementation cost. A detailed cost-benefit analysis was performed for each of the remaining 

SAMAs. 

The Staff concludes that FPL-DA used a systematic and comprehensive process for identifying 

potential plant improvements for DAEC, and that the set of potential plant improvements 

identified by FPL-DA is reasonably comprehensive and, therefore, acceptable. 

5.3.4 Evaluation of Risk Reduction and Costs of Improvements 

FPL-DA evaluated the risk-reduction potential of the remaining 24 SAMAs. The majority of the 

SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to 

completely eliminate the risk associated with the proposed enhancement. 

FPL-DA estimated the costs of implementing the candidate SAMAs through the application of 

engineering judgment, use of other licensee’s estimates for similar improvements, and the use 

of DAEC actual experience for similar improvements. The cost estimates conservatively did not 

include the cost of replacement power during extended outages required to implement the 
Environmental Impacts of Postulated Accidents 

NUREG-1437, Supplement 42 5-6 October 2010 

modifications, nor did they include contingency costs associated with unforeseen 

implementation obstacles. 

The Staff reviewed FPL-DA’s bases for calculating the risk reduction for the various plant 

improvements and concludes that the rationale and assumptions for estimating risk reduction 

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

would actually be realized). Accordingly, the Staff based its estimates of averted risk for the 

various SAMAs on FPL-DA’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 

reasonable and generally consistent with estimates provided in support of other plants’ 

analyses. 

The Staff concludes that the risk reduction and the cost estimates provided by FPL-DA are 

sufficient and appropriate for use in the SAMA evaluation. 

5.3.5 Cost-Benefit Comparison 

The cost-benefit analysis performed by FPL-DA was based primarily on NUREG/BR-0184 

(NRC, 1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently 

been revised to reflect the agency’s revised policy on discount rates. Revision 4 of 

NUREG/BR-0058 states that two sets of estimates should be developed: one at 3 percent and 

the other at 7 percent (NRC, 2004). FPL-DA provided both sets of estimates (FPL-DA, 2008). 

FPL-DA identified two potentially cost-beneficial SAMAs in the baseline analysis contained in 

the ER. The potentially cost-beneficial SAMAs are: 

● SAMA 156 – Provide an alternate source of water for the residual heat removal 

service water (RHRSW)/emergency service water (ESW) pit. 

● SAMA 166 – Increase the reliability of the low pressure emergency core cooling 

system (ECCS) reactor pressure vessel (RPV) low pressure permissive 

circuitry. Install manual bypass of low pressure permissive. 

FPL-DA performed additional analyses to evaluate the impact of parameter choices and 

uncertainties on the results of the SAMA assessment (FPL-DA, 2008), (NextEra, 2009). If the 

benefits are increased by an additional factor of 2.5 to account for uncertainties, one additional 

SAMA candidate was determined to be potentially cost-beneficial: 

● SAMA 117 – Increase boron concentration or enrichment in the standby liquid 

control (SLC) system. 

FPL-DA indicated that they plan to further evaluate these SAMAs for possible implementation 

and have included these items in FPL-DA’s corrective action program (FPL-DA, 2008), 

(NextEra, 2009). 
Environmental Impacts of Postulated Accidents 

October 2010 5-7 NUREG-1437, Supplement 42 

The Staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 

above, the costs of the SAMAs evaluated would be higher than the associated benefits. 

5.3.6 Conclusions 

The Staff reviewed FPL-DA’s analysis and concluded that the methods used and the 

implementation of those methods are sound. The treatment of SAMA benefits and costs 

support the general conclusion that the SAMA evaluations performed by FPL-DA are 

reasonable and sufficient for the license renewal submittal. 

Based on its review of the SAMA analysis, the Staff concurs with FPL-DA’s identification of 

areas in which risk can be further reduced in a cost-beneficial manner through the 

implementation of all, or a subset of, potentially cost-beneficial SAMAs. Given the potential for 

cost-beneficial risk reduction, the Staff considers that further evaluation of these SAMAs by 

FPL-DA is warranted. The Staff considered the mitigating benefits of implementing the SAMAs. 

However, none of the SAMAs listed above are specifically related to an aging management 

review conducted under the license renewal safety review pursuant to 10 CFR Part 54. The 

applicant has not made a final determination to implement these SAMAs. 

5.4 REFERENCES 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.” 

Florida Power and Light Energy Duane Arnold, LLC (FPL-DA). 2008. Duane Arnold Energy 

Center – License Renewal Application, Applicant’s Environmental Report, Operating License 

Renewal Stage, September 2008, Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML082980480. 

IES Utilities, Inc. (IES). 1995. “Duane Arnold Energy Center Individual Plant Examination for 

External Events,” November 1995. 

Iowa Electric Light and Power Co. (IELP). 1992. “Duane Arnold Energy Center Individual Plant 

Examination,” November 1992. 

NextEra. 2009. Letter from C.R. Costanzo, NextEra, to U.S. Nuclear Regulatory Commission 

Document Control Desk, Subject: “Clarification of Response to Request for Additional 

Information Regarding Severe Accident Mitigation Alternatives for Duane Arnold Energy 

Center,” September 23, 2009. 

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., 

ADAMS Accession Nos. ML040690705 and ML040690738. 

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

Handbook, NUREG/BR-0184, Washington, D.C., January 1997. 

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). 2004. Regulatory Analysis Guidelines of the U.S. 

Nuclear Regulatory Commission, NUREG/BR-0058, Revision 4, Washington, D.C., 

September 2004. 

October 2010 6-1 NUREG-1437, Supplement 42 

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS 

6.1 THE URANIUM FUEL CYCLE 

This section addresses issues related to the uranium fuel cycle and solid waste management 

during the period of extended operation. The uranium cycle includes uranium mining and 

milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication, 

reprocessing of irradiated fuel, transportation of radioactive materials, and management of 

low-level wastes and high-level wastes related to uranium fuel cycle activities. The Generic 

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

Volumes 1 and 2 (NRC, 1996), (NRC, 1999) details the potential generic impacts of the 

radiological and nonradiological environmental impacts of the uranium fuel cycle including 

transportation of nuclear fuel and wastes. The GEIS is based, in part, on the generic impacts 

provided in Table S-3, “Table of Uranium Fuel Cycle Environmental Data,” in Title 10 of the 

Code of Federal Regulations (CFR), Section 51.51(a), and in Table S-4, “Environmental Impact 

of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power 

Reactor,” in 10 CFR 51.52(b). The GEIS also addresses the impacts from radon-222 and 

technetium-99. 

For these Category 1 issues, the GEIS concludes that the impacts are designated as SMALL, 

except for the collective offsite radiological impacts from the fuel cycle and from high-level waste 

and spent fuel disposal where no significance level was assigned to these two impacts. For the 

collective offsite radiological impacts, the Commission concludes that these impacts are 

acceptable in that these impacts would not be sufficiently large to require the National 

Environmental Policy Act of 1969 (NEPA) conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. The staff of the U.S. Nuclear Regulatory 

Commission (NRC) did not identify any new and significant information related to the uranium 

fuel cycle during the review of the Florida Power and Light Energy Duane Arnold, LLC (FPL-DA) 

environmental report (ER) (FPL-DA, 2008), the site audit, and the scoping process. Therefore, 

there are no impacts related to these issues beyond those discussed in the GEIS. 

Nine generic issues are related to the fuel cycle and solid waste management. These are 

shown in Table 6-1. There are no site-specific issues. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

NUREG-1437, Supplement 42 6-2 October 2010 

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

Issues GEIS Section Category 

Offsite radiological impacts (individual effects from other than the 

disposal of spent fuel and high-level waste) 

6.1, 6.2.1, 6.2.2.1, 

6.2.2.3, 6.2.3, 6.2.4, 

6.6 

1 

Offsite radiological impacts (collective effects) 6.1, 6.2.2.1, 6.2.3, 

6.2.4, 6.6 

1 

Offsite radiological impacts (spent fuel and high-level waste 

disposal) 

6.1, 6.2.2.1, 6.2.3, 

6.2.4, 6.6 

1 

Nonradiological impacts of the uranium fuel cycle 6.1, 6.2.2.6, 6.2.2.7, 

6.2.2.8, 6.2.2.9, 6.2.3, 

6.2.4, 6.6 

1 

Low-level waste storage and disposal 6.1, 6.2.2.2, 6.4.2, 

6.4.3, 6.4.3.1, 6.4.3.2, 

6.4.3.3, 6.4.4, 6.4.4.1, 

6.4.4.2, 6.4.4.3, 

6.4.4.4, 6.4.4.5, 

6.4.4.5.1, 6.4.4.5.2, 

6.4.4.5.3, 6.4.4.5.4, 

6.4.4.6, 6.6 

1 

Mixed waste storage and disposal 6.4.5.1, 6.4.5.2, 

6.4.5.3, 6.4.5.4, 

6.4.5.5, 6.4.5.6, 

6.4.5.6.1, 6.4.5.6.2, 

6.4.5.6.3, 6.4.5.6.4, 

6.6 

1 

Onsite spent fuel 6.1, 6.4.6, 6.4.6.1, 

6.4.6.2, 6.4.6.3, 

6.4.6.4, 6.4.6.5, 

6.4.6.6, 6.4.6.7, 6.6 

1 

Nonradiological waste 6.1, 6.5, 6.5.1, 6.5.2, 

6.5.3, 6.6 

1 

Transportation 6.1, 6.3.1, 6.3.2.3, 

6.3.3, 6.3.4, 6.6, 

Addendum 1 

1 

6.2 GREENHOUSE GAS EMISSIONS 

This section provides a discussion of potential impacts from greenhouse gases (GHGs) emitted 

from the nuclear fuel cycle. The GEIS does not directly address these emissions, and its 

discussion is limited to an inference that substantial carbon dioxide (CO2) emissions may occur 

if coal- or oil-fired alternatives to license renewal are implemented. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

October 2010 6-3 NUREG-1437, Supplement 42 

6.2.1 Existing Studies 

Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 

electricity generating methods have been widely studied. However, estimates and projections 

of the carbon footprint of the nuclear fuel cycle vary depending on the type of study conducted. 

Additionally, considerable debate also exists among researchers regarding the relative impacts 

of nuclear and other forms of electricity generation on GHG emissions. Existing studies on 

GHG emissions from nuclear power plants generally take two different forms: 

(1) Qualitative discussions of the potential to use nuclear power to reduce GHG emissions 

and mitigate global warming. 

(2) Technical analyses and quantitative estimates of the actual amount of GHGs generated 

by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the 

operational or life cycle emissions from other energy generation alternatives. 

Some of these studies are summarized below to give the reader an overview of the current state 

of these assessments. 

6.2.1.1 Qualitative Studies 

The qualitative studies consist primarily of broad, large-scale public policy or investment 

evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 

and/or politically feasible means of achieving global GHG reductions. Examples of the studies 

include: 

● Evaluations to determine whether investments in nuclear power in developing 

countries should be accepted as a flexibility mechanism to assist industrialized 

nations in achieving their GHG reduction goals under the Kyoto Protocols 

(Schneider, 2000), (IAEA, 2000), (NEA, 2002), (NIRS/WISE, 2005). Ultimately, 

the parties to the Kyoto Protocol did not approve nuclear power as a component 

under the Clean Development Mechanism (CDM) due to safety and waste 

disposal concerns (NEA, 2002). 

● Analyses developed to assist governments, including the United States, in 

making long-term investment and public policy decisions in nuclear power 

(Keepin, 1988), (Hagen et al., 2001), (MIT, 2003). 

Although the qualitative studies sometimes reference and critique the existing quantitative 

estimates of GHGs produced by the nuclear fuel cycle, their conclusions generally rely heavily 

on discussions of other aspects of nuclear policy decisions and investment such as safety, cost, 

waste generation, and political acceptability. Therefore, these studies are typically not directly 

applicable to an evaluation of GHG emissions associated with the proposed license renewal for 

a given nuclear power plant. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

NUREG-1437, Supplement 42 6-4 October 2010 

6.2.1.2 Quantitative Studies 

A large number of technical studies, including calculations and estimates of the amount of 

GHGs emitted by nuclear and other power generation options, are available in the literature and 

were useful to the NRC staff’s efforts in addressing relative GHG emission levels. Examples of 

these studies include – but are not limited to – Mortimer (1990), Andseta et al. (1998), Spadaro 

(2000), Storm van Leeuwen and Smith (2005), Fritsche (2006), Parliamentary Office of Science 

and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), 

Fthenakis and Kim (2007), and Dones (2007). 

Comparing these studies and others like them is difficult because the assumptions and 

components of the lifecycles the authors evaluate vary widely. Examples of areas in which 

differing assumptions make comparing the studies difficult include: 

● energy sources that may be used to mine uranium deposits in the future 

● reprocessing or disposal of spent nuclear fuel 

● current and potential future processes to enrich uranium and the energy sources 

that will power them 

● estimated grades and quantities of recoverable uranium resources 

● estimated grades and quantities of recoverable fossil fuel resources 

● estimated GHG emissions other than CO2, including the conversion to CO2

equivalents per unit of electric energy produced 

● performance of future fossil fuel power systems 

● projected capacity factors for alternative means of generation 

● current and potential future reactor technologies 

In addition, studies may vary with respect to whether all or parts of a power plant’s fuel cycle are 

analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, 

resource extraction (for fuel and construction materials), and decommissioning, whereas, a 

partial lifecycle analysis primarily focuses on operational differences). 

In the case of license renewal, a GHG analysis for that portion of the plant’s lifecycle (operation 

for an additional 20 years) would not involve GHG emissions associated with construction 

because construction activities have already been completed at the time of relicensing. In 

addition, the proposed action of license renewal would also not involve additional GHG 

emissions associated with facility decommissioning, because that decommissioning must occur 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

October 2010 6-5 NUREG-1437, Supplement 42 

whether the facility is relicensed or not. However, in some of the aforementioned studies, the 

specific contribution of GHG emissions from construction, decommissioning, or other portions of 

a plant’s lifecycle cannot be clearly separated from one another. In such cases, an analysis of 

GHG emissions would overestimate the GHG emissions attributed to a specific portion of a 

plant’s lifecycle. Nonetheless, these studies provide some meaningful information with respect 

to the relative magnitude of the emissions among nuclear power plants and other forms of 

electric generation, as discussed in the following sections. 

In Tables 6-2, 6-3, and 6-4, the NRC staff presents the results of the aforementioned 

quantitative studies to provide a weight-of-evidence evaluation of the relative GHG emissions 

that may result from the proposed license renewal as compared to the potential alternative use 

of coal-fired, natural gas-fired, and renewable generation. Most studies from Mortimer (1990) 

onward suggest that uranium ore grades and uranium enrichment processes are leading 

determinants in the ultimate GHG emissions attributable to nuclear power generation. These 

studies indicate that the relatively lower order of magnitude of GHG emissions from nuclear 

power when compared to fossil-fueled alternatives (especially natural gas) could potentially 

disappear if available uranium ore grades drop sufficiently while enrichment processes 

continued to rely on the same technologies. 

6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 

Considering that coal fuels the largest share of electricity generation in the United States and 

that its burning results in the largest emissions of GHGs for any of the likely alternatives to 

nuclear power generation, including Duane Arnold Energy Center (DAEC), most of the available 

quantitative studies focused on comparisons of the relative GHG emissions of nuclear to 

coal-fired generation. The quantitative estimates of the GHG emissions associated with the 

nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent 

coal-fired plant, are presented in Table 6-2. The following chart does not include all existing 

studies, but provides an illustrative range of estimates developed by various sources. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

NUREG-1437, Supplement 42 6-6 October 2010 

Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal 

Source GHG Emission Results 

Mortimer (1990) Nuclear—230,000 tons CO2 

Coal—5,912,000 tons CO2

Note: Future GHG emissions from nuclear to increase because of declining ore grade. 

Andseta, et al. (1998) Nuclear energy produces 1.4 percent of the GHG emissions compared to coal. 

Note: Future reprocessing and use of nuclear-generated electrical power in the mining 

and enrichment steps are likely to change the projections of earlier authors, such as 

Mortimer (1990). 

Spadaro (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Coal—264 to 357 g Ceq/kWh 

Storm van Leeuwen and 

Smith (2005) 

Authors did not evaluate nuclear versus coal. 

Fritsche (2006) (Values 

estimated from graph in 

Figure 4) 

Nuclear—33 g Ceq/kWh 

Coal—950 g Ceq/kWh 

POST (2006) (Nuclear 

calculations from AEA, 

2006) 

Nuclear—5 g Ceq/kWh 

Coal—>1000 g Ceq/kWh 

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could 

reduce coal-fired GHG emissions by 90 percent. 

Weisser (2006) 

(Compilation of results 

from other studies) 

Nuclear—2.8 to 24 g Ceq/kWh 

Coal—950 to 1250 g Ceq/kWh 

Fthenakis and Kim 

(2007) 

Authors did not evaluate nuclear versus coal. 

Dones (2007) Author did not evaluate nuclear versus coal. 

g Ceq/kWh = grams of CO2 equivalents per kilowatt-hour 

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 

The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 

some cases, the nuclear lifecycle), as compared to an equivalent natural gas-fired plant, are 

presented in Table 6-3. The following chart does not include all existing studies, but provides 

an illustrative range of estimates developed by various sources. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

October 2010 6-7 NUREG-1437, Supplement 42 

Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas 

Source GHG Emission Results 

Mortimer (1990) Author did not evaluate nuclear versus natural gas. 

Andseta, et al. (1998) Author did not evaluate nuclear versus natural gas. 

Spadaro (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Natural Gas—120 to 188 g Ceq/kWh 

Storm van Leeuwen 

and Smith (2005) 

Nuclear fuel cycle produces 20 to 33 percent of the GHG emissions compared to 

natural gas (at high ore grades). 

Note: Future nuclear GHG emissions to increase because of declining ore grade. 

Fritsche (2006) (Values 

estimated from graph in 

Figure 4) 

Nuclear—33 g Ceq/kWh 

Cogeneration Combined-Cycle Natural Gas—150 g Ceq/kWh 

POST (2006) (Nuclear 

calculations from AEA, 

2006) 

Nuclear—5 g Ceq/kWh 

Natural Gas—500 g Ceq/kWh 

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could 

reduce natural gas GHG emissions by 90 percent. 

Weisser (2006) 

(Compilation of results 

from other studies) 

Nuclear—2.8 to 24 g Ceq/kWh 

Natural Gas—440 to 780 g Ceq/kWh 

Fthenakis and Kim 

(2007) 

Authors did not evaluate nuclear versus natural gas. 

Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005), 

and concluded that the nuclear fuel cycle produces 15 to 27 percent of the GHG 

emissions of natural gas. 

6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

Sources 

The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 

compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of 

GHG emissions associated with these sources is more difficult than the calculations for nuclear 

energy and fossil fuels because of the large variation in efficiencies due to their different 

sources and locations. For example, the efficiency of solar and wind energy is highly dependent 

on the location in which the power generation facility is installed. Similarly, the range of GHG 

emissions estimates for hydropower varies greatly depending on the type of dam or reservoir 

involved (if used at all). Therefore, the GHG emissions estimates for these energy sources 

have a greater range of variability than the estimates for nuclear and fossil fuel sources. The 

following chart does not include all existing studies, but provides an illustrative range of 

estimates developed by various sources. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

NUREG-1437, Supplement 42 6-8 October 2010 

Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources 

Source GHG Emission Results 

Mortimer (1990) Nuclear—230,000 tons CO2 

Hydropower—78,000 tons CO2

Wind power—54,000 tons CO2

Tidal power—52,500 tons CO2

Note: Future GHG emissions from nuclear to increase because of declining ore grade. 

Andseta, et al. (1998) Author did not evaluate nuclear versus renewable energy sources. 

Spadaro (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Solar PV—27.3 to 76.4 g Ceq/kWh 

Hydroelectric—1.1 to 64.6 g Ceq/kWh 

Biomass—8.4 to 16.6 g Ceq/kWh 

Wind—2.5 to 13.1 g Ceq/kWh 

Storm van Leeuwen 

and Smith (2005) 

Author did not evaluate nuclear versus renewable energy sources. 

Fritsche (2006) (Values 

estimated from graph in 

Figure 4) 

Nuclear—33 g Ceq/kWh 

Solar PV—125 g Ceq/kWh 

Hydroelectric—50 g Ceq/kWh 

Wind—20 g Ceq/kWh 

POST (2006) (Nuclear 

calculations from AEA, 

2006) 

Nuclear—5 g Ceq/kWh 

Biomass—25 to 93 g Ceq/kWh 

Solar PV—35 to 58 g Ceq/kWh 

Wave/Tidal—25 to 50 g Ceq/kWh 

Hydroelectric—5 to 30 g Ceq/kWh 

Wind—4.64 to 5.25 g Ceq/kWh 

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 

6.8 g Ceq/kWh. 

Weisser (2006) 

(Compilation of results 

from other studies) 

Nuclear—2.8 to 24 g Ceq/kWh 

Solar PV—43 to 73 g Ceq/kWh 

Hydroelectric—1 to 34 g Ceq/kWh 

Biomass—35 to 99 g Ceq/kWh 

Wind—8 to 30 g Ceq/kWh 

Fthenakis and Kim 

(2007) 

Nuclear—16 to 55 g Ceq/kWh 

Solar PV—17 to 49 g Ceq/kWh 

Dones (2007) Author did not evaluate nuclear versus renewable energy sources. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

October 2010 6-9 NUREG-1437, Supplement 42 

6.2.2 Conclusions: Relative Greenhouse Gas Emissions 

The sampling of data presented in Tables 6-2, 6-3, and 6-4 above demonstrates the challenges 

of any attempt to determine the specific amount of GHG emission attributable to nuclear energy 

production sources, as different assumptions and calculation methodology will yield differing 

results. The differences and complexities in these assumptions and analyses will further 

increase when they are used to project future GHG emissions. Nevertheless, several 

conclusions can be drawn from the information presented. 

First, the various studies indicate a general consensus that nuclear power currently produces 

fewer GHG emissions than fossil-fuel-based electrical generation (e.g., the GHG emissions from 

a complete nuclear fuel cycle currently range from 2.5 to 55 g Ceq/kWh, as compared to the use 

of coal plants (264 to 1250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh)). The 

studies also provide estimates of GHG emissions from five renewable energy sources based on 

current technology. These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh), 

hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), 

and tidal (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion 

is that current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as 

from these renewable energy sources. 

Second, the studies indicate no consensus on future relative GHG emissions from nuclear 

power and other sources of electricity. There is substantial disagreement among the various 

authors regarding the GHG emissions associated with declining uranium ore concentrations, 

future uranium enrichment methods, and other factors, including changes in technology. Similar 

disagreement exists regarding future GHG emissions associated with coal and natural gas for 

electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 

currently produces fewer GHG emissions than fossil-fuel-based sources, and is expected to 

continue to do so in the near future. The primary difference between the authors is the 

projected cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed 

those of fossil-fuel-based sources) or whether cross-over will actually occur. 

Considering the current estimates and future uncertainties, it appears that GHG emissions 

associated with the proposed DAEC relicensing action are likely to be lower than those 

associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the 

following rationale: 

(1) As shown in Tables 6-2 and 6-3, the current estimates of GHG emissions from the 

nuclear fuel cycle are far below those for fossil-fuel-based energy sources. 

(2) DAEC license renewal will involve continued GHG emissions due to uranium mining, 

processing, and enrichment, but will not result in increased GHG emissions associated 

with plant construction or decommissioning (as the plant will have to be decommissioned 

at some point whether the license is renewed or not). 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

NUREG-1437, Supplement 42 6-10 October 2010 

(3) Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 

within a timeframe that includes the DAEC period of extended operation. Several 

studies suggest that future extraction and enrichment methods, the potential for higher 

grade resource discovery, and technology improvements could extend this timeframe. 

With respect to comparison of GHG emissions among the proposed DAEC license renewal 

action and renewable energy sources, it appears likely that there will be future technology 

improvements and changes in the type of energy used for mining, processing, and constructing 

facilities of all types. Currently, the GHG emissions associated with the nuclear fuel cycle and 

renewable energy sources are within the same order of magnitude. Because nuclear fuel 

production is the most significant contributor to possible future increases in GHG emissions 

from nuclear power, and because most renewable energy sources lack a fuel component, it is 

likely that GHG emissions from renewable energy sources would be lower than those 

associated with DAEC at some point during the period of extended operation. 

The NRC staff also provides an additional discussion about the contribution of GHG to 

cumulative air quality impacts in Section 4.11.2 of this SEIS. 

6.3 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 

High-Level Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada.” 

40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

“Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 

Fuel, High-Level and Transuranic Radioactive Waste.” 

AEA Technology (AEA). 2006. “Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note,” 

Prepared for British Energy, March 2006. 

Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast (Andseta, et al.). 1998. 

“CANDU Reactors and Greenhouse Gas Emissions,” Canadian Nuclear Association, 11th 

Pacific Basin Nuclear Conference, Banff, Alberta, Canada, May 1998. 

Dones, R. 2007. “Critical Note on the Estimation by Storm Van Leeuwen J.W., and Smith P. of 

the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain,” 

Paul Sherer Institute, April 2007. 

Fritsche, U.R. 2006. “Comparison of Greenhouse-Gas Emissions and Abatement Cost of 

Nuclear and Alternative Energy Options from a Life-Cycle Perspective,” Oko-Institut, Darmstadt 

Office, January 2006. 
Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gaseous Emissions 

October 2010 6-11 NUREG-1437, Supplement 42 

Fthenakis, V.M. and H.C. Kim. 2007. “Greenhouse-gas emissions from solar-electric and 

nuclear power: A life cycle study,” Energy Policy, Volume 35, Number 4. 

International Atomic Energy Agency (IAEA). 2000. “Nuclear Power for Greenhouse Gas 

Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM),” November 

2000. 

Mortimer, N. 1990. “World Warms to Nuclear Power,” SCRAM Safe Energy Journal, December 

1989 and January 1990. Available URL: 

http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php (accessed February 29, 2007). 

Florida Power and Light Energy Duane Arnold, LLC (FPL-DA). 2008. Duane Arnold Energy 

Center, License Renewal Application, Appendix E – Applicant’s Environmental Report – 

Operating License Renewal Stage, Duane Arnold Energy Center, September 2008, Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML082980483. 

Organization for Economic Co-Operation and Development, Nuclear Energy Agency (NEA). 

2002. Nuclear Energy and the Kyoto Protocol.

Parliamentary Office of Science and Technology (POST). 2006. “Carbon Footprint of Electricity 

Generation,” Postnote, Number 268, October 2006. 

Schneider, M. 2000. Climate Change and Nuclear Power, World Wildlife Fund for Nature, April 

2000. 

Spadaro, J.V., L. Langlois and B. Hamilton. 2000. “Greenhouse Gas Emissions of Electricity 

Generation Chains: Assessing the Difference,” IAEA Bulletin 42/2/2000, Vienna, Austria. 

Storm van Leeuwen, J.W. and P. Smith. 2005. Nuclear Power—The Energy Balance, August 

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, 

1996, ADAMS Accession Nos. ML040690705 and ML040690738. 

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. 

Weisser, D. 2006. “A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 

Supply Technologies.” Available URL: 

http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre-print_versionDanielWei

sser.pdf (accessed May 19, 2009) 

October 2010 7-1 NUREG-1437, Supplement 42 

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 

Environmental impacts from the activities associated with the decommissioning of any reactor 

before or at the end of an initial or renewed license are evaluated in the Generic Environmental 

Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 

Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC, 2002). The 

staff’s evaluation of the environmental impacts of decommissioning, presented in NUREG-0586, 

Supplement 1, identifies a range of impacts for each environmental issue. 

The incremental environmental impacts associated with decommissioning activities resulting 

from continued plant operation during the renewal term are discussed in the Generic 

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

Volumes 1 and 2 (NRC, 1996), (NRC, 1999). 

7.1 DECOMMISSIONING

Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations Part 51 

(10 CFR Part 51), Subpart A, Appendix B, that are applicable to Duane Arnold Energy Center 

(DAEC) decommissioning following the renewal term are listed in Table 7-1. 

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

Energy Center Following the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section

DECOMMISSIONING

Radiation doses 7.3.1 

Waste management 7.3.2 

Air quality 7.3.3 

Water quality 7.3.4 

Ecological resources 7.3.5 

Socioeconomic impacts 7.3.7 

A brief description of the U.S. Nuclear Regulatory Commission (NRC) staff’s (Staff’s) review and 

the GEIS conclusions, as codified in Table B-1, 10 CFR Part 51, for each of the issues follows: 

● Radiation doses. Based on information in the GEIS, the Commission found that: 

Doses to the public will be well below applicable regulatory standards regardless 

of which decommissioning method is used. Occupational doses would increase 

no more than 1 man-rem caused by buildup of long-lived radionuclides during the 

license renewal term. 
Environmental Impacts of Decommissioning 

NUREG-1437, Supplement 42 7-2 October 2010 

● Waste management. Based on information in the GEIS, the Commission found that: 

Decommissioning at the end of a 20-year license renewal period would generate 

no more solid wastes than at the end of the current license term. No increase in 

the quantities of Class C or greater than Class C wastes would be expected. 

● Air quality. Based on information in the GEIS, the Commission found that: 

Air quality impacts of decommissioning are expected to be negligible either at the 

end of the current operating term or at the end of the license renewal term. 

● Water quality. Based on information in the GEIS, the Commission found that: 

The potential for significant water quality impacts from erosion or spills is no 

greater whether decommissioning occurs after a 20-year license renewal period 

or after the original 40-year operation period, and measures are readily available 

to avoid such impacts. 

● Ecological resources. Based on information in the GEIS, the Commission found that: 

Decommissioning after either the initial operating period or after a 20-year 

license renewal period is not expected to have any direct ecological impacts. 

● Socioeconomic Impacts. Based on information in the GEIS, the Commission found that: 

Decommissioning would have some short-term socioeconomic impacts. The 

impacts would not be increased by delaying decommissioning until the end of a 

20-year license renewal period, but they might be decreased by population and 

economic growth. 

The Staff has not identified any new and significant information during the review of the Florida 

Power and Light Energy Duane Arnold, LLC (FPL-DA) environmental report (FPL-DA, 2008), 

the site audit, or the scoping process; therefore, there are no impacts related to these issues 

beyond those discussed in the GEIS (NRC, 1996), (NRC, 1999). For the issues listed in Table 

7-1 above, the GEIS concluded that the impacts are SMALL. 

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.” 

Florida Power and Light Energy Duane Arnold, LLC (FPL-DA). 2008. Duane Arnold Energy 

Center, License Renewal Application, Appendix E – Applicant’s Environmental Report – 

Operating License Renewal Stage, Duane Arnold Energy Center, September 2008. 

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. 

Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML061770605. 
Environmental Impacts of Decommissioning 

October 2010 7-3 NUREG-1437, Supplement 42 

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, Volumes 1 and 2, Washington, D.C. 

October 2010 8-1 NUREG-1437, Supplement 42 

8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 

The National Environmental Policy Act (NEPA) mandates that each environmental impact 

statement (EIS) consider alternatives to any proposed major Federal action significantly 

affecting the quality of the human environment. U.S. Nuclear Regulatory Commission (NRC) 

regulations implementing NEPA for license renewal require that a supplemental environmental 

impact statement (SEIS) consider and weigh “the environmental effects of the proposed action 

(license renewal); the environmental impacts of alternatives to the proposed action; and 

alternatives available for reducing or avoiding adverse environmental impacts,” (Title 10 of the 

Code of Federal Regulations (CFR) 51.71d). 

This SEIS considers the proposed Federal action of issuing a renewed license for the Duane 

Arnold Energy Center (DAEC), which would allow the plant to operate for 20 years beyond its 

current license expiration date. In this chapter, the NRC staff (Staff) examines the potential 

environmental impacts of alternatives to issuing a renewed operating license for DAEC, as well 

as alternatives that may reduce or avoid adverse environmental impacts from license renewal, 

when and where these alternatives are applicable. 

While the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 

Plants, NUREG-1437 (NRC, 1996), (NRC, 1999), reached generic conclusions regarding many 

environmental issues associated with license renewal, it did not determine which alternatives 

are reasonable or reach conclusions about site-specific environmental impact levels. As such, 

the Staff must evaluate environmental impacts of alternatives on a site-specific basis. 

Alternatives to the proposed action of issuing a renewed DAEC operating license must meet the 

purpose and need for issuing a renewed license; they must: 

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 ultimately makes no decision as to which alternative (or the proposed action) to 

implement, since that decision falls to utility, State, or other Federal officials to decide. 

Comparing the environmental effects of these alternatives will assist the Staff in deciding 

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

license renewal for energy planning decision-makers would be unreasonable 

(10 CFR 51.95[c][4]). If the NRC acts to issue a renewed license, all of the alternatives, 

including the proposed action, will be available to energy planning decision-makers. If NRC 

decides not to renew the license (or takes no action at all), then energy planning 

decision-makers may no longer elect to continue operating DAEC and will have to resort to 

another alternative—which may or may not be one of the alternatives considered in this 

section—to meet their energy needs. 

In evaluating alternatives to license renewal, the Staff first selects energy technologies or 

options currently in commercial operation, as well as some technologies not currently in 

commercial operation but likely to be commercially available by the time the current DAEC 

operating license expires. The current DAEC operating license will expire on February 21, 

2014, and an alternative must be available (constructed, permitted, and connected to the grid) 

by the time the current DAEC license expires. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-2 October 2010 

Second, the Staff screens the alternatives to remove 

those that cannot meet future system needs, and then 

screens the remaining options to remove those whose 

costs or benefits do not justify inclusion in the range 

of reasonable alternatives. Any alternatives 

remaining then constitute alternatives to the proposed 

action that the Staff evaluates in detail throughout this 

section. In Section 8.4, the SEIS briefly addresses 

each alternative that the Staff removed during 

screening and explains why each alternative was 

removed. 

The Staff initially considered 19 discrete potential 

alternatives to the proposed action, and then 

narrowed the list to the two discrete alternatives and 

one combination alternative considered in 

Sections 8.1 through 8.3. 

Once the Staff identifies alternatives for in-depth 

review, the Staff refers to generic environmental 

impact evaluations in the GEIS. The GEIS provides 

overviews of some energy technologies available at 

the time of its publishing in 1996, though it does not 

reach any conclusions regarding which alternatives 

are most appropriate, nor does it precisely categorize 

impacts for each site. In addition, since 1996, many 

energy technologies have evolved significantly in 

capability and cost, while regulatory structures have 

changed to either promote or impede development of 

particular alternatives. 

As a result, the Staff’s analyses starts with the GEIS 

and then includes updated information from sources 

like the Energy Information Administration (EIA), other 

organizations within the Department of Energy (DOE), 

the Environmental Protection Agency (EPA), industry 

sources and publications, and information submitted 

in the applicant’s (FPL Energy Duane Arnold, LLC 

[FPL-DA]) environmental report (ER). 

For each in-depth analysis, the Staff analyzes 

environmental impacts across seven impact 

categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, 

(4) biological, (5) human health, (6) socioeconomics, and (7) waste management. As in earlier 

chapters of this SEIS, the Staff uses the NRC’s three-level standard of significance—SMALL, 

MODERATE, or LARGE—to indicate the degree of the environmental effect on each of the 

seven aforementioned categories that have been evaluated. 

In-Depth Alternatives: 

• Coal-fired 

supercritical 

• Natural gas-fired 

combined-cycle 

• Combination 

• No-action 

Other Alternatives 

Considered: 

• Offsite coal- and 

gas-fired capacity 

• Coal-fired integrated 

gasification 

combined-cycle 

(IGCC) 

• New nuclear 

• Conservation 

• Purchased power 

• Solar power 

(photovoltaic and 

concentrating) 

• Wood-fired 

combustion 

• Conventional 

hydroelectric power 

• Wave and ocean 

energy 

• Geothermal power 

• Municipal solid waste 

• Biofuels 

• Oil-fired power 

• Fuel cells 

• Delayed retirement 
Environmental Impacts of Alternatives 

October 2010 8-3 NUREG-1437, Supplement 42 

Energy Outlook: Each year the Energy 

Information Administration (EIA), part of the 

U.S. Department of Energy (DOE), issues 

its updated Annual Energy Outlook (AEO). 

AEO 2009 indicates that natural gas, coal, 

and renewable are likely to fuel most new 

electrical capacity through 2030, with some 

growth in nuclear capacity (EIA, 2009a), 

though all projections are subject to future 

developments in fuel price or electricity 

demand: 

“Natural-gas-fired plants account for 

53 percent of capacity additions in the 

reference case, as compared with 

22 percent for renewable, 18 percent for 

coal-fired plants, and 5 percent for nuclear. 

Capacity expansion decisions consider 

capital, operating, and transmission costs. 

Typically, coal-fired, nuclear, and renewable 

plants are capital-intensive, whereas 

operating (fuel) expenditures account for 

most of the costs associated with 

natural-gas-fired capacity.” 

The in-depth alternatives that the Staff 

considered include a supercritical 

coal-fired plant in Section 8.1; a natural 

gas-fired, combined-cycle power plant in 

Section 8.2; and a combination of 

alternatives in Section 8.3 that includes 

some natural gas-fired capacity, energy 

conservation, and a wind power 

component. In Section 8.4, the Staff 

explains why it dismissed many other 

alternatives from in-depth consideration. 

Finally, in Section 8.5, the Staff 

considers the environmental effects that 

may occur if the NRC takes no action 

and does not issue a renewed license for 

DAEC. 

8.1 SUPERCRITICAL COAL-FIRED 

GENERATION 

The GEIS indicates that a 610 

megawatt-electric (MWe) supercritical 

coal-fired power plant (a plant equivalent 

in capacity to DAEC) could require 

1,040 acres (ac) (421 hectares (ha)) and 

thus would not fit on the existing DAEC 

site; however, the Staff notes that many coal-fired power plants with larger capacities have been 

located on smaller sites. In the ER, FPL-DA also indicated that onsite construction of a 

coal-fired alternative would be preferred over an offsite location. The Staff believes this to be 

reasonable and, as such, will consider a coal-fired alternative located on the current DAEC site. 

Table 8-1 provides a summary comparison of environmental impacts of the supercritical 

coal-fired alternative with those of the continued operation of DAEC. 

Coal-fired generation accounts for a greater share of U.S. electrical power generation than any 

other fuel (EIA, 2009b). Furthermore, the EIA projects that coal-fired power plants will account 

for the greatest share of added capacity through 2030—more than natural gas, nuclear, or 

renewable generation options. While coal-fired power plants are widely used and likely to 

remain widely used, the Staff notes that future coal capacity additions may be affected by 

perceived or actual efforts to limit greenhouse gas (GHG) emissions. For now, the Staff 

considers a coal-fired alternative to be a feasible, commercially available option that could 

provide electrical generating capacity after DAEC’s current license expires. 

Supercritical technologies are increasingly common in new coal-fired plants. Supercritical 

plants operate at higher temperatures and pressures than most existing coal-fired plants 

(beyond water’s “critical point,” where boiling no longer occurs and no clear phase change 

occurs between steam and liquid water). Operating at higher temperatures and pressures 

allows this coal-fired alternative to function at a higher thermal efficiency than many existing 

coal-fired power plants do. While supercritical facilities are more expensive to construct, they 

consume less fuel for a given output, reducing environmental impacts. Based on technology 

forecasts from EIA, the Staff expects that a new, supercritical coal-fired plant beginning 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-4 October 2010 

operation in 2014 would operate at a heat rate of 9,069 British thermal units per kilowatt hour 

(Btu/kWh), or approximately 38 percent thermal efficiency (EIA, 2009a). 

In a supercritical coal-fired power plant, burning coal heats pressurized water. As the 

supercritical steam/water mixture moves through plant pipes to a turbine generator, the 

pressure drops and the mixture flashes to steam. The heated steam expands across the 

turbine stages, which then spin and turn the generator to produce electricity. After passing 

through the turbine, any remaining steam is condensed back to water in the plant’s condenser. 

In most modern U.S. facilities, condenser cooling water circulates through cooling towers or a 

cooling pond system (either of which are closed-cycle cooling systems). Older plants often 

withdraw cooling water directly from existing rivers or lakes and discharge heated water directly 

to the same body of water (called open-cycle cooling). In this case, a coal-fired alternative 

constructed on the DAEC site would withdraw makeup water from and discharge blowdown 

(water containing concentrated dissolved solids and biocides) from cooling towers back to the 

Cedar River. Because DAEC already uses two mechanical draft cooling towers onsite, the 

coal-fired alternative would likely use these existing cooling towers for its closed-cycle cooling 

system. Because nuclear plants require more cooling capacity than the equivalently sized 

coal-fired plant, the existing cooling towers are expected to be adequate to support a coal-fired 

alternative without amendment or expansion. A coal-fired alternative may also make use of the 

existing river intake and discharge towers if such a retrofit can take place while DAEC continues 

operating. 

In order to replace the 610 net MWe that DAEC currently supplies, the coal-fired alternative 

would need to produce roughly 575 net MWe, using about 6 percent of power output for onsite 

power usage (FPL-DA, 2008). Onsite electricity demands include scrubbers, cooling towers, 

coal-handling equipment, lights, communication, and other onsite needs. A supercritical 

coal-fired plant equivalent in capacity to DAEC would require less cooling water than DAEC 

because the alternative operates at a higher thermal efficiency. 

This 610 MWe power plant would consume 2.25 million tons (2.04 million metric tons (MT)) of 

coal annually assuming an average heat content of 8,668 British thermal units per pound 

(Btu/lb) (EIA, 2006). The EIA reported that most coal consumed in Iowa originates in Wyoming. 

Given current coal mining operations in the State of Wyoming, the coal used in this alternative 

would likely be mined in surface mines, then mechanically processed and washed, before being 

transported—via an existing rail spur—to the power plant site. Limestone for scrubbers would 

also arrive by rail. This coal-fired alternative would produce roughly 116,800 tons (106,000 MT) 

of ash, and roughly 47,300 tons (43,000 MT) scrubber sludge annually. As noted above, much 

of the coal ash and scrubber sludge could be reused depending on local recycling and reuse 

markets. 

The coal-fired alternative would also include construction impacts such as clearing the plant site 

of vegetation, excavation, and preparing the site surface before other crews begin actual 

construction of the plant and any associated infrastructure. Because this alternative would be 

constructed at the DAEC site, it is unlikely that new transmission lines or a new rail spur would 

be necessary. 
Environmental Impacts of Alternatives 

October 2010 8-5 NUREG-1437, Supplement 42 

Table 8-1. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative 

Compared to Continued Operation of Duane Arnold Energy Center 

Supercritical Coal-Fired 

Generation 

Continued DAEC Operation 

Air Quality MODERATE SMALL 

Groundwater SMALL SMALL 

Surface Water SMALL SMALL 

Aquatic and Terrestrial Resources SMALL to MODERATE SMALL 

Human Health SMALL SMALL 

Socioeconomics SMALL to MODERATE SMALL 

Historic and Archaeological 

Resources 

MODERATE MODERATE 

Waste Management MODERATE SMALL 

8.1.1 Air Quality 

Air quality impacts from coal-fired generation can be substantial because they emit significant 

quantities of sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon monoxide (CO), 

and hazardous air pollutants (HAPs) such as mercury. However, many of these pollutants can 

be substantially reduced using various pollution control technologies. 

DAEC is located in Linn County, Iowa. There are no areas designated by the EPA as 

nonattainment or maintenance for any of the criteria pollutants in the 50-mile (mi) (81-kilometer 

(km) vicinity of DAEC. A new coal-fired generating plant would qualify as a new major-emitting 

industrial facility and would be subjected to Prevention of Significant Deterioration of Air Quality 

Review under the requirements of the Clean Air Act (CAA), adopted by the Iowa Department of 

Natural Resources (IDNR) Air Quality Bureau in Section 567 of the Iowa Administrative Code 

(IAC) (IDNR, 2008). A new coal-fired generating plant would need to comply with the new 

source performance standards for coal-fired plants set forth in 40 CFR 60, Subpart Da. The 

standards establish limits for particulate matter (PM) and opacity (40 CFR 60.42(a)), sulfur 

dioxide (SO2) (40 CFR 60.43(a)), and NOx (40 CFR 60.44(a)). Regulations issued by the IDNR 

adopt the EPA’s CAA rules (with modifications) to limit power plant emissions of SOx, NOx, PM, 

and HAPs. The new coal-fired generating plant would qualify as a Class I major source as 

identified in Section 567 of the IAC and would be required to obtain Class I major source 

permits from the IDNR, which the EPA may also elect to review prior to issuance of the permits 

(IDNR, 2008). 

Section 169A of the CAA (42 United States Code (U.S.C.) 7401) 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 (64 Federal Register (FR) 35714). 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 toward achieving natural visibility conditions. The reasonable progress 

goals must provide an improvement in visibility for the most-impaired days over the period of 

implementation plan and ensure no degradation in visibility for the least-impaired days over the 

same period (40 CFR 51.308(d)(1)). Five regional planning organizations (RPOs) collaborate 

on the visibility impairment issue, developing the technical basis for these plans. The State of 

Iowa is among nine member States (Iowa, Nebraska, Kansas, Oklahoma, Texas, Minnesota, 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-6 October 2010 

Missouri, Arkansas, and Louisiana) of the Central Regional Air Planning Association (CENRAP), 

along with tribes, Federal agencies, and other interested parties that identify regional haze and 

visibility issues and develop strategies to address them. The visibility protection regulatory 

requirements, contained in 40 CFR Part 51, Subpart P, include the review of the new sources 

that would be constructed in the attainment or unclassified areas and may affect visibility in any 

Federal Class I area (40 CFR Part 51, Subpart P, §51.307). If a coal-fired plant were located 

close to a mandatory Class I area, additional air pollution control requirements would be 

imposed. There are no mandatory Class I Federal areas in the State of Iowa and the closest 

mandatory Class I Federal area is Mingo Wilderness Area, which is located 365 mi southeast 

from the DAEC in the State of Missouri. 

Iowa is also subject to the Clean Air Interstate Rule (CAIR), which has outlined emissions 

reduction goals for both SO2 and NOx for the year 2015. CAIR will aid Iowa sources in reducing 

SO2 emissions by 7,000 tons (or 5 percent), and NOx emissions by 37,000 tons (or 49 percent) 

(EPA, 2008b). 

The Staff projects that the coal-fired alternative at the DAEC site would have the following 

emissions for criteria and other significant emissions based on published EIA data, EPA 

emission factors, and on performance characteristics for this alternative and likely emission 

controls: 

● Sulfur oxides (SOx) – 898.19 tons (814.83 MT) per year 

● Nitrogen oxides (NOx) – 562.77 tons (510.55 MT) per year 

● Total suspended particles (TSP) – 99.76 tons (90.50 MT) per year 

● Particulate matter (PM) PM10 – 22.95 tons (20.82 MT) per year 

● Particulate matter (PM) PM2.5 – 58.42 tons (52.99 MT) per year 

● Carbon monoxide (CO) – 562.77 tons (510.55 MT) per year 

8.1.1.1 Sulfur Oxides 

The coal-fired alternative at the DAEC site would likely use wet, limestone-based scrubbers to 

remove SOx. The EPA indicates that this technology can remove more than 95 percent of SOx 

from flue gases. The Staff projects total SOx emissions after scrubbing would be 898.19 tons 

(814.83 MT) per year. SOx emissions from a new coal-fired power plant would be subject to the 

requirements of Title IV of the CAA. Title IV was enacted to reduce emissions of SO2 and NOx, 

the two principal precursors of acid rain, by restricting emissions of these pollutants from power 

plants. Title IV caps aggregate annual power plant SO2 emissions and imposes controls on SO2

emissions through a system of marketable allowances. The EPA issues one allowance for each 

ton of SO2 that a unit is allowed to emit. New units do not receive allowances, but are required 

to have allowances to cover their SO2 emissions. Owners of new units must, therefore, 

purchase allowances from owners of other power plants or reduce SO2 emissions at other 

power plants they own. Allowances can be banked for use in future years. Thus, provided a 

new coal-fired power plant is able to purchase sufficient allowances to operate, it would not add 

to net regional SO2 emissions, although it might do so locally. 

8.1.1.2 Nitrogen Oxides 

A coal-fired alternative at the DAEC site would most likely employ various available NOx-control 

technologies, which can be grouped into two main categories: combustion modifications and 

post-combustion processes. Combustion modifications include low-NOx burners, overfire air, 

and operational modifications. Post-combustion processes include selective catalytic reduction 

(SCR) and selective non-catalytic reduction. An effective combination of the combustion 

modifications and post-combustion processes allow the reduction of NOx emissions by up to 
Environmental Impacts of Alternatives 

October 2010 8-7 NUREG-1437, Supplement 42 

95 percent (EPA, 1998). FPL-DA indicated in its ER that it would use a combination of low-NOx 

burners, overfire air, and SCR technologies to reduce NOx emissions from this alternative. 

Assuming the use of such technologies at the DAEC site, NOx emissions after scrubbing are 

estimated to be 562.77 tons (510.55 MT) annually. 

Section 407 of the CAA establishes technology-based emission limitations for NOx emissions. 

A new coal-fired power plant would be subject to the new source performance standards for 

such plants as indicated in 40 CFR 60.44a(d)(1). This regulation, issued on September 16, 

1998 (63 FR 49453), limits the discharge of any gases that contain NOx to 200 nanograms (ng) 

of NOx per joule (J) of gross energy output (equivalent to 1.6 pounds per megawatt-hour 

(lb/MWh)), based on a 30-day rolling average. Based on the projected emissions, the proposed 

alternative would easily meet this regulation. 

8.1.1.3 Particulates 

The new coal-fired power plant would use fabric filters to remove particulates from flue gases. 

FPL-DA indicates that fabric filters would remove 95 percent of PM (FPL-DA, 2008). The EPA 

notes that filters are capable of removing in excess of 99 percent of PM, and that SO2 scrubbers 

further reduce PM emissions (EPA, 2008a). Based on EPA emission factors, the new 

supercritical coal-fired plant would emit 99.76 tons (90.50 MT) per year and approximately 

22.95 tons (20.82 MT) per year of PM having an aerodynamic diameter less than or equal to 10 

microns (PM10) annually (EPA, 2009e). In addition, coal burning would also result in 

approximately 58.42 tons (52.99 MT) per year of particulate matter with an aerodynamic 

diameter of 2.5 microns or less (PM2.5). Coal-handling equipment would introduce fugitive dust 

emissions when fuel is being transferred to onsite storage and then reclaimed from storage for 

use in the plant. During the construction of a coal-fired plant, onsite activities would also 

generate fugitive dust. Vehicles and motorized equipment would create exhaust emissions 

during the construction process. These impacts would be intermittent and short-lived, however, 

and to minimize dust generation, construction crews would use applicable dust-control 

measures. 

8.1.1.4 Carbon Monoxide 

Based on EPA emission factors (EPA, 1998) and assumed plant characteristics, the Staff 

computed that the total CO emissions would be approximately 562.77 tons (510.55 MT) per 

year. 

8.1.1.5 Hazardous Air Pollutants 

Consistent with the D.C. Circuit Court’s February 8, 2008, ruling that vacated its Clean Air 

Mercury Rule (CAMR), the EPA is in the process of developing mercury emissions standards for 

power plants under the CAA (Section 112) (EPA, 2009a at 3). Before CAMR, the EPA 

determined that coal- and oil-fired electric utility steam-generating units are significant emitters 

of HAPs (EPA, 2000b). The EPA determined that coal plants emit arsenic, beryllium, cadmium, 

chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and mercury 

(EPA, 2000b). The EPA concluded that mercury is the HAP of greatest concern; it further 

concluded that: 

(1) a link exists between coal combustion and mercury emissions 

(2) electric utility steam-generating units are the largest domestic source of mercury 

emissions 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-8 October 2010 

(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 

resulting from mercury exposures caused by the consumption of contaminated fish 

(EPA, 2000b) 

On February 6, 2009, the Supreme Court dismissed the EPA’s request to review the 2008 

Circuit Court’s decision, and also denied a similar request by the Utility Air Regulatory Group 

later that month (EPA, 2009 at 3). 

8.1.1.6 Carbon Dioxide 

A coal-fired plant would also have unregulated carbon dioxide (CO2) emissions during 

operations as well as during mining, processing, and transportation, which the GEIS indicates 

could contribute to global warming. The coal-fired plant would emit between 4,123,000 tons 

(3,741,000 MT) and 4,272,000 tons (3,876,600 MT) of CO2 per year, depending on the type and 

quality of the coal burned. 

8.1.1.7 Summary of Air Quality 

While the GElS analysis mentions global warming from unregulated CO2 emissions and acid 

rain from SOx and NOx emissions as potential impacts, it does not quantify emissions from 

coal-fired power plants. However, the GElS analysis does imply that air impacts would be 

substantial (NRC, 1996). The above analysis shows that emissions of air pollutants, including 

SOx, NOx, CO, and particulates, exceed those produced by the existing nuclear power plant, as 

well as those of the other alternatives considered in this section. Operational emissions of CO2 

are also much greater under the coal-fired alternative, as reviewed by the Staff in Section 6.2 

and in the previous paragraph. Adverse human health effects such as cancer and emphysema 

have also been associated with air emissions from coal combustion, and are discussed further 

in Section 8.1.5. 

The NRC analysis for a coal-fired alternative at the DAEC site indicates that impacts from the 

coal-fired alternative would have clearly noticeable effects, but given existing regulatory 

regimes, permit requirements, and emissions controls, the coal-fired alternative would not 

destabilize air quality. Therefore, the appropriate characterization of air impacts from a 

coal-fired plant located at the DAEC site would be MODERATE. Existing air quality would result 

in varying needs for pollution control equipment to meet applicable local requirements, or 

varying degrees of participation in emissions trading schemes. 

8.1.2 Groundwater Use and Quality 

If the onsite coal-fired alternative continued to use groundwater for drinking water and service 

water, the need for groundwater at the plant would be minor. Total usage would likely be less 

than DAEC because many fewer workers would be onsite, and because the coal-fired unit 

would have fewer auxiliary systems requiring service water. No effect on groundwater quality 

would be apparent. 

Construction of a coal-fired plant could have a localized effect on groundwater due to temporary 

dewatering and run-off control measures. Because of the temporary nature of construction and 

the likelihood of reduced groundwater usage during operation, the impact of the coal-fired 

alternative would be SMALL. 
Environmental Impacts of Alternatives 

October 2010 8-9 NUREG-1437, Supplement 42 

8.1.3 Surface Water Use and Quality 

The alternative would draw approximately 9,000 gallons per minute (gpm) from the Cedar River, 

with an average consumption of about 11 million gallons per day (mgd). This consumptive loss 

is less than 0.1 percent of the average annual flow of the Cedar River and as such, the Staff 

concludes that the impact of surface water use would be SMALL. A new coal-fired plant would 

be required to obtain a National Pollutant Discharge and Elimination System (NPDES) permit 

from the IDNR for regulation of industrial wastewater, storm water, and other discharges. 

Assuming the plant operates within the limits of this permit, the impact from any cooling tower 

blowdown, site runoff, and other effluent discharges on surface water quality would be SMALL. 

A SMALL impact could occur during drought conditions with little or no reservoir recharge. 

8.1.4 Aquatic and Terrestrial Ecology 

8.1.4.1 Aquatic Ecology 

The number of fish and other aquatic resource organisms affected by impingement, 

entrainment, and thermal impacts produced by the alternative would be smaller than that 

associated with license renewal because water consumption from and blowdown to the Cedar 

River would be lower. Some temporary impacts to aquatic organisms might occur due to any 

construction that might occur or due to any effluent discharges to the river, but these activities 

would be monitored by the IDNR under the project’s NPDES permit. Although the number of 

affected organisms would be less than for license renewal, the NRC level of impact for license 

renewal is already modest and so the Staff expects that the levels of impact for impingement, 

entrainment, and thermal effects would also be SMALL for this alternative. 

8.1.4.2 Terrestrial Ecology 

As indicated in the applicant’s ER, constructing the coal-fired alternative onsite would require 

less than 96 ac (39 ha) of land (FPL-DA, 2008). Coal-mining would also affect terrestrial 

ecology in offsite coal mining areas, although some of the land is likely already disturbed by 

mining operations. Onsite and offsite land disturbances form the basis for impacts to terrestrial 

ecology. 

Onsite impacts to terrestrial ecology would be minor because most of the site has been 

previously disturbed and is currently used for agricultural activities. This could change if 

additional roads would need to be constructed through less disturbed areas. These 

construction activities may fragment or destroy habitats and could include a loss of onsite 

farmland. These land disturbances could affect food supply and habitat of native wildlife and 

migratory waterfowl, however, these impacts are not expected to be significant. Cooling tower 

operation could produce a visible plume as well as some deposition of dissolved solids on 

surrounding vegetation and soil from cooling tower drift, however, the GEIS indicated that the 

impact of cooling towers on agricultural crops is relatively small, and most of the land 

surrounding the DAEC site is farmland. 

Any onsite or offsite waste disposal by landfilling would also affect terrestrial ecology at least 

through the period when the disposal area is reclaimed. Deposition of acid rain resulting from 

NOx or SOx emissions, as well as the deposition of other pollutants, can also affect terrestrial 

ecology. Given the emission controls discussed in Section 8.1.1, air deposition impacts may be 

noticeable, but are not likely to be destabilizing. Primarily because of the potential habitat 

disturbances, impacts to terrestrial resources from a coal-fired alternative would be SMALL to 

MODERATE, and would occur mostly during construction. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-10 October 2010 

8.1.5 Human Health 

Coal-fired power plants introduce worker risks from coal and limestone mining, from coal and 

limestone transportation, and from disposal of coal combustion and scrubber wastes. In 

addition, there are public risks from inhalation of stack emissions (as addressed in 

Section 8.1.1) and the secondary effects of eating foods grown in areas subject to deposition 

from plant stacks. 

Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the 

GEIS (NRC, 1996). Cancer and emphysema as a result of the inhalation of toxins and 

particulates are identified as potential health risks to occupational workers and members of the 

public (NRC, 1996). The human health risks of coal-fired power plants, both to occupational 

workers and to members of the public, are greater than those of the current DAEC due to 

exposures to chemicals such as mercury; SOx; NOx; radioactive elements such as uranium and 

thorium contained in coal and coal ash; and polycyclic aromatic hydrocarbon (PAH) compounds, 

including benzo(a)pyrene. 

Regulations restricting emissions—enforced by the EPA or State agencies—have acted to 

significantly reduce potential health effects but have not entirely eliminated them. These 

agencies also impose site-specific emission limits as needed to protect human health. Even if 

the coal-fired alternative were located in a nonattainment area, emission controls and trading or 

offset mechanisms could prevent further regional degradation; however, local effects could be 

visible. Many of the byproducts of coal combustion responsible for health effects are largely 

controlled, captured, or converted in modern power plants (as described in Section 8.1.1), 

although some level of health effects may remain. 

Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires and 

for those plants that use coal combustion liquid and sludge waste impoundments, the release of 

the waste due to a failure of the impoundment. Although there have been several instances of 

this occurring in recent years, these types of events are still relatively rare. 

Overall, given extensive health-based regulation, the Staff expects human health impacts to be 

SMALL. 

8.1.6 Socioeconomics 

8.1.6.1 Land Use 

The GEIS generically evaluates the impacts of nuclear power plant operations on land use both 

on and off each power plant site. The analysis of land use impacts focuses on the amount of 

land area that would be affected by the construction and operation of a new supercritical 

coal-fired power plant on the DAEC site. 

FPL-DA indicated that approximately 96 ac (39 ha) of land would be needed to support a 

coal-fired alternative capable of replacing DAEC. This amount of land use includes power plant 

structures and associated coal delivery and waste disposal infrastructure. FPL-DA indicated 

that the site has an existing rail spur, however, an additional 100 ac (40 ha) of land area may be 

needed for waste disposal, which FPL-DA indicated could be accommodated onsite 

(FPL-DA, 2008). 

Offsite land use impacts would occur from coal mining, in addition to land use impacts from the 

construction and operation of the new power plant. Scaling from GEIS estimates, approximately 
Environmental Impacts of Alternatives 

October 2010 8-11 NUREG-1437, Supplement 42 

13,450 ac (5,450 ha) of land could be affected by mining coal and waste disposal to support the 

coal-fired alternative during its operational life (NRC, 1996). However, most of the land in 

existing coal-mining areas has already experienced some level of disturbance. The elimination 

of the need for uranium mining to supply fuel for DAEC would partially offset this offsite land use 

impact. Scaling from GEIS estimates, approximately 610 ac (247 ha) of land would be used for 

uranium mining, and processing would no longer be needed. 

Based on this information, and the need for additional land at DAEC, land use impacts could 

range from SMALL to MODERATE. 

8.1.6.2 Socioeconomics 

Socioeconomic impacts are defined in terms of changes to the demographic and economic 

characteristics and social conditions of a region. For example, the number of jobs created by 

the construction and operation of a new coal-fired power plant could affect regional 

employment, income, and expenditures. Two types of job creation result from this alternative: 

(1) construction-related jobs, and (2) operation-related jobs in support of power plant operations, 

which have the greater potential for permanent, long-term socioeconomic impacts. The Staff 

estimated workforce requirements during power plant construction and operation for the 

coal-fired alternative in order to measure their possible effect on current socioeconomic 

conditions. 

Based on GEIS estimates, FPL-DA projected a peak construction workforce of 937 to 

1,500 workers would be required to construct the coal-fired alternative at DAEC 

(FPL-DA, 2008). During the construction period, the communities surrounding the plant site 

would experience increased demand for rental housing and public services. The relative 

economic contributions of these workers to local business and tax revenues would. 

After construction, local communities may be temporarily affected by the loss of construction 

jobs and associated loss in demand for business services. In addition, the rental housing 

market could experience increased vacancies and decreased prices. As noted in the GEIS, the 

socioeconomic impacts at a rural construction site could be larger than at an urban site, 

because the workforce would need to relocate closer to the construction site. Although the ER 

indicates that DAEC is a rural site, it is located near three metropolitan areas: Waterloo (34 mi), 

Iowa City (32 mi), and Cedar Rapids (5.7 mi). Therefore, these effects may be somewhat 

lessened because workers are likely to commute to the site from these areas instead of 

relocating closer to the construction site. Based on the site’s proximity to these metropolitan 

areas, construction impacts would be SMALL. 

FPL-DA estimated an operational workforce of 66 to 150 workers for the 610 MWe supercritical 

coal-fired power plant alternative based on GEIS estimates (FPL-DA, 2008). The FPL-DA 

estimate appears reasonable and is consistent with trends calling for reduced workforces at 

power generating facilities. Operational impacts would, therefore, be SMALL. 

8.1.6.3 Transportation 

During construction, up to 900 to 1,500 workers would be commuting daily to the site. In 

addition to commuting workers, trucks would transport construction materials and equipment to 

the worksite, increasing the amount of traffic on local roads, while trains would transport some 

of the largest components to the plant site. The increase in vehicular traffic on roads would 

peak during shift changes resulting in temporary levels of service impacts and delays at 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-12 October 2010 

intersections. Trains would likely be used to deliver large components to the DAEC site given 

its existing rail spur. Transportation impacts would likely be MODERATE during construction. 

Transportation traffic-related impacts would be greatly reduced after construction, but would not 

disappear during plant operations. The maximum number of plant operating personnel 

commuting to DAEC would be approximately 150 workers. Frequent deliveries of coal and 

limestone by rail would add to the overall transportation impact, potentially causing frequent and 

lengthy delays at railroad crossings. Onsite coal storage would make it possible to receive 

several trains per day. Limestone delivered by rail could also add traffic-related impacts (though 

considerably less traffic than that generated by coal deliveries). The coal-fired alternative 

transportation impacts would range from SMALL to MODERATE transportation impacts during 

plant operations. 

8.1.6.4 Aesthetics 

The aesthetics impact analysis focuses on the degree of contrast between the coal-fired 

alternative and the surrounding landscape and the visibility of the coal plant. 

The coal-fired power plant would be up to 200 feet (ft) (61 meters (m)) tall with an exhaust stack 

up to 500 ft (152 m). The facility would likely be visible offsite during daylight hours. The 

supercritical coal-fired plant could be taller than the current DAEC reactor building, which stands 

at 140 ft (43 m) with a 328-ft (100-m) off-gas stack. The mechanical draft towers would also 

generate a condensate plume, which would be no more noticeable than the existing DAEC 

plume. The supercritical coal-fired alternative may only require the use of one cooling tower 

instead of two, thus minimizing the size of the plume. Noise from plant operations and coal 

delivery, as well as lighting on plant structures, may be detectable offsite. 

Overall, aesthetic impacts associated with the supercritical coal-fired alternative would range 

from SMALL to MODERATE. 

8.1.6.5 Historic and Archaeological Resources 

Cultural resources are the indications of human occupation and use of the landscape as defined 

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources 

are physical remains of human activities that predate written records; they generally consist of 

artifacts that may alone or collectively yield information about the past. Historic resources 

consist of physical remains that postdate the emergence of written records; in the United States, 

they are architectural structures or districts, archaeological objects, and archaeological features 

dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic, 

but exceptions can be made for such properties if they are of particular importance, such as 

structures associated with the development of nuclear power (e.g., Shippingport Atomic Power 

Station) or Cold War themes. American Indian resources are sites, areas, and materials 

important to American Indians for religious or heritage reasons. Such resources may include 

geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

The cultural resource analysis encompassed the power plant site and adjacent areas that could 

potentially be disturbed by the construction and operation of alternative power plants. 

The potential for historic and archaeological resources can vary greatly depending on the 

location of the proposed site. To consider a project’s effects on historic and archaeological 

resources, any proposed areas would need to be surveyed to identify and record historic and 

archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

develop possible mitigation measures to address any adverse effects from ground disturbing 
Environmental Impacts of Alternatives 

October 2010 8-13 NUREG-1437, Supplement 42 

activities. Studies would be needed for all areas of potential disturbance at the proposed plant 

site and along associated corridors where construction would occur (e.g., roads, transmission 

corridors, rail lines, or other ROWs). Areas with the greatest sensitivity should be avoided. 

The impact for a coal-fired alternative at the DAEC site would be MODERATE. As noted in 

Section 4.9.6, potential impacts to historic and archaeological resources are possible due to the 

richness of archaeological resources expected on the DAEC property. DAEC in coordination 

with the State Historic Preservation Office (SHPO) has revised and implemented its excavation 

and trenching procedures and developed a cultural resource management plan for the plant 

property. These plans address potential impacts to both known and undiscovered resources. 

Plant procedures also include an inadvertent discovery (stop work) provision. Depending on the 

resource richness of the area ultimately chosen for the coal-fired alternative, impacts could be 

MODERATE. 

8.1.6.6 Environmental Justice 

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of a new supercritical coal-fired power plant. 

Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 

impacts on human health. Disproportionately high and adverse human health effects occur 

when the risk or rate of exposure to an environmental hazard for a minority or low-income 

population is significant and exceeds the risk or exposure rate for the general population or for 

another appropriate comparison group. Disproportionately high environmental effects refer to 

impacts, or risk of impact, on the natural or physical environment in a minority or low-income 

community that are significant and appreciably exceeds the environmental impact on the larger 

community. Such effects may include biological, cultural, economic, or social impacts. Some of 

these potential effects have been identified in resource areas discussed in this SEIS. For 

example, increased demand for rental housing during power plant construction could 

disproportionately affect low-income populations. Minority and low-income populations are 

subsets of the general public residing around DAEC, and all are exposed to the same hazards 

generated from constructing and operating a new coal-fired power plant. Potential impacts to 

minority and low-income populations from the construction and operation of a new supercritical 

coal-fired power plant at DAEC would mostly consist of environmental and socioeconomic 

effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts 

from construction would be short-term and primarily limited to onsite activities. However, 

minority and low-income populations residing along site access roads could be affected by 

increased commuter vehicle traffic during shift changes. Increased demand for rental housing 

during construction in the vicinity of DAEC could affect low-income populations. However, these 

effects would be temporary during certain hours of the day and not likely to be high and 

adverse. Given the close proximity to three metropolitan areas, most construction workers 

would commute to the site, thereby reducing the potential demand for rental housing. 

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new supercritical coal-fired power 

plant would not have disproportionately high and adverse human health and environmental 

effects on minority and low-income populations residing in the vicinity of DAEC. 

8.1.7 Waste Management 

Coal combustion generates several waste streams including ash (a dry solid) and sludge (a 

semi-solid byproduct of emission control system operation). The Staff estimates that a 
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NUREG-1437, Supplement 42 8-14 October 2010 

610 MWe power plant would generate annually a total of 126,800 tons (115,000 MT) of dry solid 

ash and scrubber sludge. About 90,000 tons (81,600 MT) of this waste would be recycled. 

Disposal of the remaining waste from the 40-year operation of this alternative would require 

approximately 44 ac (18 ha). Disposal of the remaining waste could noticeably affect land use 

and groundwater quality, but would require proper citing in accordance with Title 567, 

Chapter 101, “Solid Waste Comprehensive Planning Requirements,” of the IAC and the 

implementation of the required monitoring and management practices in order to minimize these 

impacts (IDNR, 2009). After closure of the waste site and revegetation, the land could be 

available for other uses. 

In May 2000, the EPA issued a “Notice of Regulatory Determination on Wastes from the 

Combustion of Fossil Fuels” (EPA, 2000a) stating that it would issue regulations for disposal of 

coal combustion waste under Subtitle D of the Resource Conservation and Recovery Act. The 

EPA has not yet issued these regulations. 

The impacts from waste generated during operation of this coal-fired alternative would be 

MODERATE; the impacts would be clearly visible, but would not destabilize any important 

resource. 

The amount of the construction waste would be small compared to the amount of waste 

generated during the operational stage, and much of it could be recycled. Overall, the impacts 

from waste generated during the construction stage would be SMALL. 

Therefore, the Staff concludes that the overall impacts from construction and operation of this 

alternative would be MODERATE.

8.2 NATURAL GAS COMBINED-CYCLE GENERATION 

In this section, the Staff evaluates the environmental impacts of a natural gas-fired, 

combined-cycle generation plant at the DAEC site. Table 8-2 provides a summary comparison 

of environmental impacts of the natural gas combined-cycle generation alternative with that of 

continued operation of DAEC.

Natural gas fueled 22 percent of electric generation in the United States in 2007 (the most 

recent year for which data are available); this accounted for the second greatest share of 

electrical power after coal (EIA, 2009b). Like coal-fired power plants, natural gas-fired plants 

may be affected by perceived or actual actions to limit GHG emissions; however, they produce 

markedly lower GHG emissions per unit of electrical output than coal-fired plants. Natural 

gas-fired power plants are feasible and provide commercially available options for providing 

electrical generating capacity beyond DAEC’s current license expiration date. 

Combined-cycle power plants differ significantly from coal-fired and existing nuclear power 

plants. They derive the majority of their electrical output from a gas-turbine cycle, and then 

generate additional power—without burning any additional fuel—through a second, 

steam-turbine cycle. The first, gas turbine stage (similar to a large jet engine) burns natural gas 

that turns a driveshaft that powers an electric generator. The exhaust gas from the gas turbine 

is still hot enough, however, to boil water into steam. Ducts carry the hot exhaust to a heat 

recovery steam generator, which produces steam to drive a steam turbine and produce 

additional electrical power. The combined-cycle approach is significantly more efficient than 

any one cycle on its own; thermal efficiency can exceed 60 percent. Since the natural gas-fired 
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October 2010 8-15 NUREG-1437, Supplement 42 

alternative derives much of its power from a gas turbine cycle, and because it wastes less heat 

than either the coal-fired alternative or the existing DAEC, it requires significantly less cooling. 

In order to replace the 610 MWe that DAEC currently supplies, the Staff selected a gas-fired 

alternative that uses two Siemens SCC6-5000F combined-cycle generating units. While any 

number of commercially available combined-cycle units could be installed in a variety of 

combinations to replace the power currently produced by DAEC, the SCC6-5000F is a highly 

efficient model that would help minimize environmental impacts. Other manufacturers, like 

General Electric, offer similar high-efficiency models. This gas-fired alternative produces a net 

275 MWe per unit. Two units produce a total of 590 MWe, or nearly the same output as the 

existing DAEC. 

The combined-cycle alternative operates at a heat rate of 5,960 Btu/kWh, or about 57 percent 

thermal efficiency (Siemens, 2007). Allowing for onsite power usage, including cooling towers 

and site lighting, the gross output of these units would be roughly 615 MWe. As noted above, 

this gas-fired alternative would require much less cooling water than DAEC because it operates 

at a higher thermal efficiency and because it requires much less water for steam cycle 

condenser cooling. This alternative would likely make use of the site’s existing mechanical draft 

cooling towers, and may only require the use of one tower instead of the currently operating 

two. 

In addition to the already existing mechanical draft cooling towers, other visible structures onsite 

include the turbine buildings and HRSGs (which may be enclosed in a single building), two 

exhaust stacks, an electrical switchyard, and possibly, equipment associated with a natural gas 

pipeline, like a compressor station. While GEIS estimates indicate that this 590 MWe plant 

would require 68 ac (27 ha), FPL-DA indicated that a natural gas alternative of comparable size 

(610 MWe) would require only 24 ac (10 ha) (FPL-DA, 2008). The Staff believes FPL-DA’s 

estimate to be sound and will refer to it for the analysis of this alternative. 

This 590 MWe power plant would consume 26.5 billion cubic feet (ft3

) (752 million cubic meters 

(m3

)) of natural gas annually assuming an average heat content of 1,029 British thermal units 

per cubic feet (Btu/ft3

) (EIA, 2009c). Natural gas would be extracted from the ground through 

wells, then treated to remove impurities (like hydrogen sulfide), and blended to meet pipeline 

gas standards, before being piped through the interstate pipeline system to the power plant site. 

This gas-fired alternative would produce relatively little waste, primarily in the form of spent 

catalysts used for emissions controls. 

Environmental impacts from the gas-fired alternative would be greatest during construction. 

Site crews would clear vegetation from the site, prepare the site surface, and begin excavation 

before other crews begin actual construction on the plant and any associated infrastructure, 

including a 15-mi pipeline spur to serve the plant and electricity transmission infrastructure 

connecting the plant to existing transmission lines. Constructing the gas-fired alternative on the 

DAEC site would allow the gas-fired alternative to make use of the existing electric transmission 

system. 
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NUREG-1437, Supplement 42 8-16 October 2010 

Table 8-2. Summary of Environmental Impacts of the Natural Gas Combined-Cycle 

Generation Alternative Compared to Continued Operation of Duane Arnold Energy 

Center 

Natural Gas Combined-Cycle 

Generation 

Continued DAEC Operation 

Air Quality SMALL to MODERATE SMALL 

Groundwater SMALL SMALL 

Surface Water SMALL SMALL 

Aquatic and Terrestrial Resources SMALL SMALL 

Human Health SMALL SMALL 

Socioeconomics SMALL to MODERATE SMALL 

Historic and Archaeological 

Resources 

MODERATE MODERATE 

Waste Management SMALL SMALL 

8.2.1 Air Quality 

Linn County, Iowa, is in the EPA Region 7. All counties in the State of Iowa are in attainment for 

all criteria pollutants, except Muscatine County, which is a maintenance county for SO2. A new 

gas-fired generating plant developed at the DAEC site would qualify as a new major-emitting 

industrial facility and require a New Source Review (NSR)/Prevention of Significant 

Deterioration of Air Quality review under CAA requirements, adopted by the IDNR in 

Section 567 of the IAC (IDNR, 2008). The natural gas-fired plant would need to comply with the 

standards of performance for stationary gas turbines set forth in 40 CFR Part 60, Subpart GG. 

Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including 

the review of the new sources that would be constructed in the attainment or unclassified areas 

which may affect visibility in any Federal Class I area (40 CFR Part 51, Subpart P, §51.307). If 

a gas-fired alternative were located close to a mandatory Class I area, additional air pollution 

control requirements would potentially apply. There are no mandatory Class I Federal areas in 

the State of Iowa and the closest mandatory Class I Federal area is Mingo Wilderness Area, 

which is located 365 mi southeast of DAEC in Missouri. 

The Staff projects the following emissions for a gas-fired alternative based on data published by 

the EIA, the EPA, and on performance characteristics for this alternative and its emissions 

controls: 

● Sulfur oxides (SOx) – 46.40 tons (42.10 MT) per year 

● Nitrogen oxides (NOx) – 148.77 tons (134.96 MT) per year 

● Carbon monoxide (CO) – 30.93 tons (28.06 MT) per year 

● Total suspended particles (TSP) – 25.93 tons (23.53 MT) per year 

● Particulate matter (PM) PM10 – 25.93 tons (23.53 MT) per year 

● Carbon dioxide (CO2) – 1,581,300 tons (1,434,500 MT) per year 

A new natural gas-fired plant would have to comply with Title IV of the CAA reduction 

requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause 

of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the 

existing plants and a system of the SO2 emission allowances that can be used, sold, or saved 

for future use by new plants. 
Environmental Impacts of Alternatives 

October 2010 8-17 NUREG-1437, Supplement 42 

8.2.1.1 Sulfur and Nitrogen Oxides 

As stated above, the new natural gas-fired alternative would produce 46.40 tons (42.10 MT) per 

year of SOx and 148.77 tons (134.96 MT) per year of NOx based on the use of the dry, low NOx 

combustion technology and use of SCR in order to significantly reduce NOx emissions. 

The new plant would be subjected to the continuous monitoring requirements of SO2, NOx, and 

CO2 specified in 40 CFR Part 75. The Staff computed that the natural gas-fired plant would emit 

approximately 1.6 million tons (approximately 1.4 million MT) per year of unregulated CO2

emissions. As of today, there is no required reporting of GHG emissions for plants in Iowa. On 

June 3, 2010, the EPA published a final rule which set the applicability criteria that determine 

which stationary sources will become subject to permitting requirements for GHG emissions 

under the CAA (75 FR 31514). This rule establishes a significance level for GHGs of 

50,000 tons per year of CO2 equivalent. The EPA proposes that suppliers of fossil fuels or 

industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 MT or 

more per year of GHG emissions submit annual reports to the EPA. The gases covered by the 

proposed rule are CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), 

perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other fluorinated gases including nitrogen 

trifluoride (NF3) and hydrofluorinated ethers (HFE). 

8.2.1.2 Particulates 

The new natural gas-fired alternative would produce 25.93 tons (23.53 MT) per year of TSP, all 

of which would be emitted as PM10. 

8.2.1.3 Hazardous Air Pollutants 

The EPA issued in December 2000 regulatory findings (EPA, 2000b) on emissions of HAPs 

from electric utility steam-generating units, which identified that natural gas-fired plants emit 

HAPs, such as arsenic, formaldehyde, and nickel, and stated that: 

...the impacts due to HAP emissions from natural gas-fired electric utility steam 

generating units were negligible based on the results of the study. The 

Administrator finds that regulation of HAP emissions from natural gas-fired 

electric utility steam generating units is not appropriate or necessary. 

8.2.1.4 Carbon Monoxide 

Based on EPA emission factors (EPA, 1998), the Staff estimates that the total CO emissions 

would be approximately 30.93 tons (28.06 MT) per year. 

8.2.1.5 Construction Impacts 

Activities associated with the construction of the new natural gas-fired plant at the DAEC site 

would cause some additional air effects as a result of equipment emissions and fugitive dust 

from operation of the earth-moving and material handling equipment. Workers’ vehicles and 

motorized construction equipment would generate temporary exhaust emissions. The 

construction crews would employ dust-control practices in order to control and reduce fugitive 

dust, which would be temporary in nature. The Staff concludes that the impact of vehicle 

exhaust emissions and fugitive dust from operation of earth-moving and material handling 

equipment would be SMALL. 

The overall air-quality impacts of a new natural gas-fired plant located at the DAEC site would 

be SMALL to MODERATE. 
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NUREG-1437, Supplement 42 8-18 October 2010 

8.2.2 Groundwater Use and Quality 

The use of groundwater for a natural gas-fired, combined-cycle plant would likely be limited to 

supply wells for drinking water and possibly filtered service water for system cleaning purposes. 

Total usage would likely be much less than DAEC because many fewer workers would be 

onsite, and because the gas-fired alternative would have fewer auxiliary systems requiring 

service water. 

No effects on groundwater quality would be apparent except during the construction phase due 

to temporary dewatering and run-off control measures. Because of the temporary nature of 

construction and the likelihood of reduced groundwater usage during operation, the impact of 

the natural gas-fired alternative would be SMALL. 

8.2.3 Surface Water Use and Quality 

Total withdrawals of surface water from the Cedar River would be much less for a gas-fired 

plant than the 11,200 gpm (0.85 cubic meters per second (m3

/s)) currently used on average by 

DAEC, as well as the amount needed for the coal-fired alternative. Similarly, consumptive 

losses would be reduced, especially if the gas-fired alternative only requires the use of one of 

the mechanical draft cooling towers instead of the current two. Consumptive losses from the 

current DAEC unit are less than 0.1 percent of the average annual flow of the Cedar River, and 

would become much smaller if this gas-fired alternative were to replace DAEC. As such, the 

Staff concludes that the impact of surface water use would be SMALL. 

A new gas-fired plant would be required to obtain an NPDES permit from the IDNR for 

regulation of industrial wastewater, storm water, and other discharges. Assuming the plant 

operates within the limits of this permit, the impact from cooling tower blowdown, site runoff, and 

other effluent discharges on surface water quality would be SMALL. 

8.2.4 Aquatic and Terrestrial Ecology 

8.2.4.1 Aquatic Ecology 

Aquatic ecology actually benefits from the onsite, gas-fired alternative, compared to the existing 

plant, as the combined-cycle plant injects significantly less heat to the environment, thus 

requiring less water. The number of fish and other aquatic organisms affected by impingement, 

entrainment, and thermal impacts would be smaller than that associated with license renewal 

because water consumption and blowdown to the Cedar River would be substantially lower. 

Some temporary impacts to aquatic organisms might occur due to any construction or effluent 

discharge to the river, but the Staff assumes that the appropriate agencies would be monitoring 

and regulating such activities. Although the number of affected organisms would be 

substantially less than for license renewal, the NRC level of impact for license renewal is 

already modest, and so the Staff expects that the levels of impact for impingement, entrainment, 

and thermal effects of this alternative would likewise be SMALL. 

8.2.4.2 Terrestrial Ecology 

As indicated in previous sections, constructing the natural gas alternative would require 24 ac 

(10 ha) of land. These land disturbances form the basis for impacts to terrestrial ecology. 

Impacts to terrestrial ecology would be minor because the selected site has been previously 

disturbed and is mostly used for agricultural activities. (Gas extraction and collection would also 
Environmental Impacts of Alternatives 

October 2010 8-19 NUREG-1437, Supplement 42 

affect terrestrial ecology in offsite gas fields, although much of this land is likely already 

disturbed by gas extraction, and the incremental effects of this alternative on gas field terrestrial 

ecology are difficult to gauge.) 

Construction of the two natural gas-fired units could result in the loss of farmland, which could 

affect food supply and habitat of native wildlife. However, these effects are not expected to be 

significant. Operation of the cooling towers would produce a visible plume and cause some 

deposition of dissolved solids on surrounding vegetation (including some wetlands) and soil 

from cooling tower drift, however, the GEIS indicates that the impact of cooling towers on 

agricultural crops is of SMALL significance, and most of the land surrounding the cooling towers 

is farmland. These effects would be no more severe than the current DAEC operating cooling 

towers and could even be less if the gas-fired alternative uses only one of the two mechanical 

draft towers. 

Construction of the 15-mi (24-km) gas pipeline (to the nearest assumed tie-in) could lead to a 

conversion of up to 136 ac (55 ha) of forested lands used by terrestrial wildlife to a mowed 

right-of-way (ROW) as well as the loss of cropland from agricultural production, which could 

impact wildlife that use the croplands as a food source. Pipeline construction may fragment 

surrounding habitat and may increase edge habitat, which may adversely impact forest interior 

dwelling species, including migratory songbirds, as well as any threatened and endangered 

species in the affected area. However, much of the area surrounding DAEC is in agricultural 

use and, therefore, has been previously disturbed, so it is unlikely that a significant amount of 

forested land would be affected. FPL-DA also indicated that the pipeline would be routed along 

existing, previously disturbed ROWs to minimize any impacts. Because of the relatively small 

potential for undisturbed land to be affected, impacts from construction of the pipeline are 

expected to be small. 

Based on this information, impacts to terrestrial resources would be SMALL. 

8.2.5 Human Health 

Like the coal-fired alternative discussed above, a gas-fired plant would emit criteria air 

pollutants, but in smaller quantities (except NOx, which requires additional controls to reduce 

emissions). Human health effects of gas-fired generation are generally low, although in 

Table 8-2 of the GEIS (NRC, 1996), the Staff identified cancer and emphysema as potential 

health risks from gas-fired plants. NOx emissions contribute to ozone formation, which in turn 

contributes to human health risks. Emission controls on this gas-fired alternative maintain NOx 

emissions well below air quality standards established for the purposes of protecting human 

health, and emissions trading or offset requirements mean that overall NOx in the region would 

not increase. Health risks to workers may also result from handling spent catalysts that may 

contain heavy metals. 

Overall, human health risks to occupational workers and to members of the public from gas-fired 

power plant emissions sited at DAEC would be less than the risks described for the coal-fired 

alternative and, therefore, would likely be SMALL. 
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NUREG-1437, Supplement 42 8-20 October 2010 

8.2.6 Socioeconomics 

8.2.6.1 Land Use 

The analysis of land use impacts focuses on the amount of land area that would be affected by 

the construction and operation of a two unit natural gas-fired, combined-cycle power plant at the 

DAEC site. 

FPL-DA indicated that approximately 24 ac (10 ha) of land would be needed to support a natural 

gas-fired alternative to replace DAEC (FPL-DA, 2008). This amount of onsite land use would 

include other plant structures and associated infrastructure, and is unlikely to exceed 64 ac 

(26 ha), excluding land for natural gas wells and collection stations. Onsite land use impacts 

from construction would be SMALL. 

In addition to onsite land requirements, land would be required offsite for natural gas wells and 

collection stations. Scaling from GEIS estimates, approximately 5,200 ac (2,100 ha) would be 

required for wells, collection stations, and a 15-mi pipeline to bring the gas to the plant. Most of 

this land requirement would occur on land where gas extraction already occurs. In addition, 

some natural gas could come from outside of the United States and be delivered as liquefied 

gas. 

The elimination of uranium fuel for DAEC could partially offset offsite land requirements. 

Scaling from GEIS estimates, the Staff estimated that approximately 610 ac (247 ha) would not 

be needed for mining and processing uranium during the operating life of the plant. Based on 

this information and the need for additional land at DAEC, overall land use impacts from a 

gas-fired power plant would be SMALL to MODERATE. 

8.2.6.2 Socioeconomics 

Socioeconomic impacts are defined in terms of changes to the demographic and economic 

characteristics and social conditions of a region. For example, the number of jobs created by 

the construction and operation of a new natural gas-fired power plant could affect regional 

employment, income, and expenditures. Two types of job creation would result: 

(1) construction-related jobs, which are transient, short in duration, and less likely to have a 

long-term socioeconomic impact; and (2) operation-related jobs in support of power plant 

operations, which have the greater potential for permanent, long-term socioeconomic impacts. 

The Staff evaluated workforce requirements for construction and operation of the natural 

gas-fired power plant alternative in order to measure their possible effect on current 

socioeconomic conditions. 

The socioeconomic impacts from constructing and operating a gas-fired plant would have little 

noticeable effect. Compared to the coal-fired alternative, the small size of the construction and 

operations workforce would have little or no socioeconomic impact. 

While the GEIS estimates a peak workforce of 700, FPL-DA projected a maximum construction 

workforce of 344 (FPL-DA, 2008). The Staff finds this estimate to be reasonable and will refer 

to it for this analysis. During construction, the communities surrounding the power plant site 

would experience increased demand for rental housing and public services. The relative 

economic effect of construction workers on local economy and tax base would vary. 

After construction, local communities may be temporarily affected by the loss of construction 

jobs and associated loss in demand for business services, and the rental housing market could 
Environmental Impacts of Alternatives 

October 2010 8-21 NUREG-1437, Supplement 42 

experience increased vacancies and decreased prices. As noted in the GEIS, the 

socioeconomic impacts at a rural construction site could be larger than at an urban site, 

because the workforce may have to move to be closer to the construction site. Although the ER 

identifies the DAEC site as a primarily rural site, it is located near three metropolitan areas: 

Waterloo (34 mi), Iowa City (32 mi), and Cedar Rapids (5.7 mi). Therefore, these effects would 

likely be lessened because workers are likely to commute to the site from these areas instead of 

relocating closer to the construction site. Because of the site’s proximity to these larger 

population centers, the impact of construction on socioeconomic conditions would be SMALL. 

Scaling down from GEIS estimates of an operational workforce of 88 employees, FPL-DA 

estimated a power plant operations workforce of approximately 19 (FPL-DA, 2008). The 

FPL-DA estimate appears reasonable and is consistent with trends toward lowering labor costs 

by reducing the size of power plant operations workforces. The small number of operations 

workers is unlikely to have a noticeable effect on socioeconomic conditions in the region. 

Socioeconomic impacts associated with the operation of a gas-fired power plant at DAEC would 

be SMALL. 

8.2.6.3 Transportation 

Transportation impacts associated with construction and operation of a two unit gas-fired power 

plant would consist of commuting workers and truck deliveries of construction materials to the 

DAEC site. During construction, between 340 and 700 workers would be commuting to the site. 

In addition to commuting workers, trucks would transport construction materials and equipment 

to the worksite increasing the amount of traffic on local roads. The increase in vehicular traffic 

would peak during shift changes resulting in temporary levels of service impacts and delays at 

intersections. Some plant components are likely to be delivered by train via the existing onsite 

rail spur. Pipeline construction and modification to existing natural gas pipeline systems could 

also have an impact. Traffic-related transportation impacts during construction would be 

SMALL. 

During plant operations, traffic-related transportation impacts would almost disappear. 

According to FPL-DA, approximately 19 workers would be needed to operate the gas-fired 

power plant. Because fuel for the plant is transported by pipeline, a new gas-fired plant would 

have to be supported by the current gas pipeline system. If the required capacity is not 

available, any upgrades to the current pipeline system could have additional transportation 

impacts. 

The transportation infrastructure would experience little to no increased traffic from plant 

operations. Overall, the gas-fired alternative transportation impacts would be SMALL during 

plant operations. 

8.2.6.4 Aesthetics 

The aesthetics impact analysis focuses on the degree of contrast between the natural gas-fired 

alternative and the surrounding landscape and the visibility of the gas-fired plant. 

The two gas-fired units would be approximately 100 ft (30 m) tall, with an exhaust stack up to 

500 ft (152 m). The facility would be visible offsite during daylight hours. However, the 

gas-fired power plant would be shorter than the current DAEC reactor building, which stands at 

140 ft (43 m) with a 328–ft (100-m) off-gas stack. The mechanical draft towers would also 

generate a condensate plume, which would be no more noticeable than the existing DAEC 

plume. The gas-fired alternative may only require the use of one cooling tower instead of two, 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-22 October 2010 

thus minimizing the size of the plume. Noise from plant operations, as well as lighting on plant 

structures, may be detectable offsite. Pipelines delivering natural gas fuel could be audible 

offsite near gas compressors. 

In general, aesthetic changes would be limited to the immediate vicinity of DAEC and would be 

SMALL. 

8.2.6.5 Historic and Archaeological Resources 

Cultural resources are the indications of human occupation and use of the landscape as defined 

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources 

are physical remains of human activities that predate written records; they generally consist of 

artifacts that may alone or collectively yield information about the past. Historic resources 

consist of physical remains that postdate the emergence of written records; in the United States, 

they are architectural structures or districts, archaeological objects, and archaeological features 

dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic, 

but exceptions can be made for such properties if they are of particular importance, such as 

structures associated with the development of nuclear power (e.g., Shippingport Atomic Power 

Station) or Cold War themes. American Indian resources are sites, areas, and materials 

important to American Indians for religious or heritage reasons. Such resources may include 

geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

The cultural resource analysis encompassed the power plant site and adjacent areas that could 

potentially be disturbed by the construction and operation of alternative power plants. 

The potential for historic and archaeological resources can vary greatly depending on the 

location of the proposed site. To consider a project’s effects on historic and archaeological 

resources, any proposed areas would need to be surveyed to identify and record historic and 

archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

develop possible mitigation measures to address any adverse effects from ground disturbing 

activities. Site specific studies and surveys would be needed for all areas of potential 

disturbance at the proposed plant site and along associated corridors where construction would 

occur (e.g., roads, transmission corridors, rail lines, or other ROWs). Areas with the greatest 

sensitivity should be avoided. 

The impact for a gas-fired alternative at the DAEC site would be MODERATE. As noted in 

Section 4.9.6, potential impacts to historic and archaeological resources are possible due to the 

richness of archaeological resources expected on the DAEC property. DAEC in coordination 

with the SHPO has revised and implemented its excavation and trenching procedures and 

developed a cultural resource management plan for the plant property. These plans address 

potential impacts to both known and undiscovered resources. These plans would ensure that 

informed decisions are made prior to any ground disturbing activities onsite. Plant procedures 

also include an inadvertent discovery (stop work) provision. Depending on the resource 

richness of the area ultimately chosen for the natural gas-fired alternative, impacts could be 

MODERATE. 

8.2.6.6 Environmental Justice 

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of a new natural gas-fired, combined-cycle 

power plant. Adverse health effects are measured in terms of the risk and rate of fatal or 

nonfatal adverse impacts on human health. Disproportionately high and adverse human health 
Environmental Impacts of Alternatives 

October 2010 8-23 NUREG-1437, Supplement 42 

effects occur when the risk or rate of exposure to an environmental hazard for a minority or 

low-income population is significant and exceeds the risk or exposure rate for the general 

population or for another appropriate comparison group. Disproportionately high environmental 

effects refer to impacts, or risk of impact, on the natural or physical environment in a minority or 

low-income community that are significant and appreciably exceeds the environmental impact 

on the larger community. Such effects may include biological, cultural, economic, or social 

impacts. Some of these potential effects have been identified in resource areas discussed in 

this SEIS. For example, increased demand for rental housing during power plant construction 

could disproportionately affect low-income populations. Minority and low-income populations 

are subsets of the general public residing around DAEC, and all are exposed to the same 

hazards generated from constructing and operating a new natural gas-fired, combined-cycle 

power plant. 

Potential impacts to minority and low-income populations from the construction and operation of 

a new natural gas-fired, combined-cycle power plant at DAEC would mostly consist of 

environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing 

impacts). Noise and dust impacts from construction would be short-term and primarily limited to 

onsite activities. However, minority and low-income populations residing along site access 

roads could be affected by increased commuter vehicle traffic during shift changes. Increased 

demand for rental housing during construction in the vicinity of DAEC could affect low-income 

populations. However, these effects would be temporary during certain hours of the day and 

not likely to be high and adverse. Given the close proximity to three metropolitan areas, most 

construction workers would commute to the site, thereby reducing the potential demand for 

rental housing. 

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new natural gas-fired, 

combined-cycle power plant would not have disproportionately high and adverse human health 

and environmental effects on minority and low-income populations residing in the vicinity of 

DAEC. 

8.2.7 Waste Management 

During the construction phase of this alternative, land clearing and other construction activities 

would generate waste that can be recycled, disposed onsite, or shipped to an offsite waste 

disposal facility. Because the alternative would be constructed on the previously disturbed 

DAEC site, the amounts of wastes produced during land clearing would be reduced. 

During the operational stage, spent SCR catalysts used to control NOx emissions from the 

natural gas-fired plants would make up the majority of the waste generated by this alternative. 

This waste would be disposed of according to applicable Federal and State regulations. 

The Staff concluded in the GEIS (NRC, 1996) that a natural gas-fired plant would generate 

minimal waste and the waste impacts would be SMALL for a natural gas-fired alternative 

located at the DAEC site. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-24 October 2010 

8.3 COMBINATION ALTERNATIVE 

Consistent with a comment received from the public recommending that a wind-based energy 

alternative be investigated, the Staff has evaluated the environmental impacts of a combination 

of alternatives in this section. This combination would include a portion of the combined-cycle 

gas-fired capacity identified in Section 8.2, a conservation capacity component, and a wind 

power component. This alternative would require construction of a single gas-fired unit installed 

at the DAEC site and the construction of roughly 147 wind turbines (294-MWe nameplate 

capacity) at an offsite, or several different offsite locations. Table 8-3 provides a summary 

comparison of environmental impacts of the combination alternative compared with that of 

continued operation of DAEC.

In this alternative, a portion of DAEC’s output—100 MWe—would be replaced by conservation. 

Inclusion of this conservation component of the alternative is based on Iowa’s energy efficiency 

goals for the year 2013 (EPA, 2009b). Wind turbines constructed offsite would account for 

roughly 100 MWe of capacity (the 294 MWe of installed capacity would likely function at an 

average capacity factor of slightly greater than 30 percent, based on IDNR estimates) and 

400 MWe would come from one General Electric S107H combined-cycle power plant 

(IDNR, 2003). 

The only major construction the Staff anticipates would happen at the current DAEC site where 

the combined-cycle, gas-fired power plant would be erected; additionally, wind turbines would 

be constructed at an offsite location. No construction is necessary for the conservation portion. 

The appearance of the gas-fired facility would be similar to that of the full gas-fired alternative 

considered in Section 8.2, though a slightly larger, single unit would be constructed. The Staff 

estimates that this unit would require about 65 percent of the space necessary for the 

alternative considered in Section 8.2, and that all construction effects—as well as operational 

aesthetic, fuel-cycle, air quality, socioeconomic, land use, environmental justice, and water 

consumption effects—will scale accordingly.

Table 8-3. Summary of Environmental Impacts of the Combination Alternative Compared 

to Continued Operation of Duane Arnold Energy Center 

Combination Alternative Continued DAEC Operation 

Air Quality SMALL SMALL 

Groundwater SMALL SMALL 

Surface Water SMALL SMALL 

Aquatic and Terrestrial Resources SMALL to MODERATE SMALL 

Human Health SMALL SMALL 

Socioeconomics SMALL to LARGE SMALL 

Historic and Archaeological MODERATE MODERATE 

Waste Management SMALL SMALL 
Environmental Impacts of Alternatives 

October 2010 8-25 NUREG-1437, Supplement 42 

8.3.1 Air Quality 

Linn County, Iowa, where DAEC is located, is in EPA Region 7. All counties in the State of Iowa 

are in attainment for all criteria pollutants, except Muscatine County, which is a maintenance 

county for SO2. The IDNR is responsible for managing and monitoring air quality in the State of 

Iowa. 

This alternative is a combination of one 400-MWe natural gas-fired, combined-cycle generating 

unit, constructed onsite; 100 MWe equivalent of conservation/demand-side management; and 

294 MWe of wind capacity constructed offsite, possibly at several different locations. The 

alternative would be similar in air quality impacts to the gas-fired alternative considered in 

Section 8.2, but would emit lower levels of pollutants. The wind power and conservation 

portions would have little to no effect on air quality during operations, though construction of 

wind power installations and infrastructure may have short-term effects on air quality when site 

preparation or other construction activities generate fugitive dust. The wind option would also 

result in a net offset in air pollutant emissions that would otherwise be generated by the 

fossil-fuel alternative to compensate for the 294 MWe of wind generated capacity. 

A new gas-fired generating plant on the DAEC site would qualify as a new major-emitting 

industrial facility and require an NSR under the CAA and Section 567 of the IAC. The NSR 

program requires that a permit must be obtained before construction of the new major-emitting 

industrial facility (42 U.S.C. §7475(a)). The permit would be issued only if the new plant 

includes pollution control measures that reflect the best available control technology (BACT). 

The natural gas-fired unit would need to comply with the standards of performance for stationary 

gas turbines set forth in 40 CFR Part 60, Subpart GG. 

Subpart P to 40 CFR Part 51 contains the visibility protection regulatory requirements, including 

the review of the new sources that would be constructed in attainment or unclassified areas and 

may affect visibility in any Federal Class I area (40 CFR Part 51, Subpart P, §51.307). If a 

gas-fired unit were located close to a mandatory Class I area, additional air pollution control 

requirements would apply. There are no mandatory Class I Federal areas in the State of Iowa 

and the closest mandatory Class I Federal area is Mingo Wilderness Area, which is located 

365 mi southeast from DAEC in Missouri. 

The Staff projects the following emissions for the gas-fired portion of this alternative based on 

data published by the EIA, the EPA, and on performance characteristics for this alternative and 

its emissions controls: 

● Sulfur oxides (SOx) – 31.33 tons (28.42 MT) per year 

● Nitrogen oxides (NOx) (with SCR) – 100.44 tons (91.12 MT) per year 

● Carbon monoxide (CO) – 20.88 tons (18.94 MT) per year 

● Total suspended particles (TSP) – 17.51 tons (15.88 MT) per year 

● Particulate matter (PM) PM10 – 17.51 tons (15.88 MT) per year 

● Carbon dioxide (CO2) – 1,099,000 tons (997,000 MT) per year 

The natural gas-fired component of this alternative would produce 17.51 tons (15.88 MT) per 

year of TSP, all of which would be emitted as PM10. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-26 October 2010 

The EPA issued in December 2000 regulatory findings (EPA, 2000a) on emissions of HAPs 

from electric utility steam-generating units, which identified that natural gas-fired plants emit 

HAPs, such as arsenic, formaldehyde, and nickel, and stated that: 

...the impacts due to HAP emissions from natural gas-fired electric utility steam 

generating units were negligible based on the results of the study. The 

Administrator finds that regulation of HAP emissions from natural gas-fired 

electric utility steam generating units is not appropriate or necessary. 

The natural gas-fired plant would have to comply with Title IV of the CAA reduction 

requirements for SO2 and NOx, which are the main precursors of acid rain and major causes of 

reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the existing 

plants and a system of the SO2 emission allowances that can be used, sold, or saved for future 

use by the new plants. 

As stated above, the new natural gas-fired unit would produce 31.33 tons (28.42 MT) per year 

of SOx and 100.44 tons (91.12 MT) per year of NOx based on the use of the dry, low NOx 

combustion technology and the use of dry, low-NOx burners and SCR in order to significantly 

reduce NOx emissions. 

The natural gas-fired component of this alternative would be subjected to the continuous 

monitoring requirements of SO2, NOx, and CO2 specified in 40 CFR Part 75. The natural 

gas-fired plant would emit approximately 1.1 million tons (approximately 1 million MT) per year 

of unregulated CO2 emissions. As of today, there is no required reporting of GHG emissions in 

Iowa. In response to the Consolidated Appropriations Act of 2008, the EPA has proposed a rule 

that requires mandatory reporting of GHG emissions from large sources, applicable to the 

presented alternative, in the United States that would allow collection of accurate and 

comprehensive emissions data to inform future policy decisions. The EPA proposes that 

suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities 

that emit 25,000 MT or more per year of GHG emissions submit annual reports to the EPA 

(EPA, 2009c). The gases covered by the proposed rule are CO2, CH4, N2O, HFC, PFC, SF6, 

and other fluorinated gases including NF3 and HFE. American Wind Energy Association data 

shows that Iowa takes second place in the nation with the greatest existing total wind power 

capacity. There would be no direct emissions from operating the wind component of the 

combination alternative. 

Activities associated with the construction of the new natural gas-fired plant at the DAEC site 

would cause some additional air effects as a result of equipment emissions and fugitive dust 

from operation of the earth-moving and material handling equipment. Workers’ vehicles and 

motorized construction equipment would generate temporary exhaust emissions. The 

construction crews would employ dust-control practices in order to control and reduce fugitive 

dust, which would be temporary in nature. The Staff concludes that the impact of vehicle 

exhaust emissions and fugitive dust from operation of the earth-moving and material handling 

equipment would be SMALL. 

The overall air-quality impacts of the combination alternative consisting of a natural gas-fired 

plant located at DAEC site, energy conservation, and an offsite wind component would be 

SMALL. 
Environmental Impacts of Alternatives 

October 2010 8-27 NUREG-1437, Supplement 42 

8.3.2 Groundwater Use and Quality 

If the onsite gas-fired plant continued to use groundwater for drinking water and service water, 

the total usage would likely be much less than DAEC uses, because many fewer workers are 

onsite, and because the gas-fired unit would have fewer auxiliary systems requiring service 

water. The current annual average withdrawal rate is 1,394 gpm, and pumping tests indicate 

this rate would not cause an effect on nearby supply wells. A reduction in this withdrawal rate 

means that impacts of the combination alternative would remain SMALL. 

8.3.3 Surface Water Use and Quality 

Using a combined alternative with conservation and wind power as major components would 

reduce the amount of surface water consumed for cooling purposes as compared to the 

proposed action and other alternatives considered in this section. The maximum consumptive 

use would be reduced from the amount of surface water consumed by the closed-cycle cooling 

system currently in use by DAEC. This represents less than 0.1 percent of the average annual 

flow rate in the Cedar River. The impact of this withdrawal would be SMALL. 

8.3.4 Aquatic and Terrestrial Ecology 

8.3.4.1 Aquatic Ecology 

The wind and conservation components of this alternative would have no associated 

impingement, entrainment, and thermal impacts. The number of fish and other aquatic resource 

organisms affected by impingement, entrainment, and thermal impacts would be less than those 

associated with license renewal because water consumption and blowdown returned to the 

Cedar River would be substantially lower when compared to the gas-fired component or any of 

the other alternatives considered in this section. Some temporary impacts to aquatic organisms 

might occur due to any construction that might occur in the river or cause effluent to the river, 

although the Staff assumes that the appropriate agencies would monitor and regulate such 

activities. Although the number of affected organisms would be substantially less than for 

license renewal, the NRC level of impact for license renewal is already small, and so the Staff 

expects that the levels of impact for impingement, entrainment, and thermal effects would also 

be SMALL. 

8.3.4.2 Terrestrial Ecology 

The gas-fired component of this alternative would incorporate existing disturbed land and 

possibly some farmland at DAEC for the natural gas unit. This alternative would also require 

land offsite for the gas pipeline, and would require much additional land offsite to accommodate 

the number of turbines necessary in a wind farm to offset the power generated by DAEC. 

This alternative would use the existing plant site land, switchyard, one of the two existing 

mechanical draft cooling towers, and transmission line system for construction of the gas-fired 

unit. Scaling from FPL-DA’s previous estimation of a slightly larger gas-fired plant, 

approximately 16 ac (6.6 ha) of land would be required on the DAEC site to support a 400-MWe 

natural gas plant. 

Impacts to terrestrial ecology from onsite construction of this single gas-fired unit would be less 

than the impacts described for the two-unit, gas-fired alternative. The impacts to farmland 

onsite would be approximately two-thirds of the impacts of the two-unit, natural gas plant 

alternative. These onsite impacts are expected to be minor. Impacts to terrestrial ecology from 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-28 October 2010 

offsite construction of the gas pipeline for a single gas-fired unit would be the same as for the 

two gas-fired unit alternative previously discussed (FPL-DA, 2008). 

Based upon data in the GEIS, the wind farm component of the combination alternative 

producing 294 MWe of electricity would require approximately 19,000 ac (7,600 ha) spread over 

several offsite locations, with approximately 74 ac (30 ha) in actual use. The remainder of the 

land would remain in agriculture. Additional land may be needed for construction of support 

infrastructure to connect to existing transmission lines. 

Impacts to terrestrial ecology from construction of the wind farm portion of the combination 

alternative and any needed transmission lines could include loss of terrestrial habitat, an 

increase in habitat fragmentation and corresponding increase in edge habitat, and may impact 

threatened and endangered species. The GEIS notes that habitat fragmentation may lead to 

declines of migrant bird populations. Although bird mortality and disruptions to wildlife migratory 

routes could increase from construction of the wind farm, the GEIS notes that wind farms 

typically do not cause significant adverse impacts to bird populations (NRC, 1996). 

Based on this information, impacts to terrestrial resources would be MODERATE. 

8.3.5 Human Health 

The human health risks from a combination of alternatives include the already discussed 

combined-cycle, gas-fired plant. The GEIS (NRC, 1996) notes that the environmental impacts 

of a conservation/demand-side management alternative are likely to be centered on indoor air 

quality. This is due to increased weatherization of homes in the form of extra insulation and 

reduced air turnover rates from the reduction in air leaks. However, the actual impact from the 

conservation alternative is highly site-specific and not yet well established. For wind capacity, 

the GEIS notes that, except for a potential small number of occupational injuries, human health 

would not be affected by routine operations. 

The human health risks from the combination of alternatives are uncertain, but considered to be 

SMALL given that the construction and operation of the facilities are expected to comply with 

health-based Federal and State safety and emission standards. 

8.3.6 Socioeconomics 

8.3.6.1 Land Use 

The analysis of land use impacts for the combination alternative focuses on the amount of land 

area that would be affected by the construction and operation of a single natural gas-fired unit at 

DAEC and an offsite wind energy generating facility, and demand-side energy conservation. 

Land use impacts of an energy efficiency alternative would be SMALL. Rapid replacement and 

disposing of old energy inefficient appliances and other equipment could generate waste 

material and could potentially increase the size of landfills. However, given the time for program 

development and implementation, the cost of replacements, and the average life of appliances 

and other equipment, the replacement process would probably be more gradual. Older energy 

inefficient appliances and equipment would likely be replaced by more efficient appliances and 

equipment as they fail (especially frequently replaced items, like light bulbs). In addition, many 

items (like home appliances or industrial equipment) have substantial recycling value and would 

likely not be disposed of in landfills. 
Environmental Impacts of Alternatives 

October 2010 8-29 NUREG-1437, Supplement 42 

Based on FPL-DA estimates, approximately 16 ac (6.5 ha) would be needed to support the 

single natural gas-fired unit portion of the combination alternative. Land use impacts from 

construction of the natural gas-fired power plant at DAEC would be SMALL. 

In addition to onsite land requirements, land would be required offsite for natural gas wells and 

collection stations. Scaling from GEIS estimates, the natural gas-fired power plant at DAEC 

could require 1,469 ac (594 ha) for wells, collection stations, and pipelines to bring the gas to 

the facility. Most of this land requirement would occur on land where gas extraction already 

occurs. In addition, some natural gas could come from outside of the United States and be 

delivered as liquefied gas. 

The wind farm component of the combination alternative producing 294 MWe of electricity 

capacity would require approximately 19,000 ac (7,600 ha) spread over several locations with 

approximately 74 ac (30 ha) in actual use. The wind farm would most likely be located on 

agricultural cropland, which would be largely unaffected by the wind turbines. 

Although the offsite wind component of this alternative requires a large amount of land, only a 

small portion of that land would be in actual use. Also, the elimination of uranium fuel for DAEC 

could partially offset offsite land requirements. Scaling from GEIS estimates, approximately 

610 ac (247 ha) would be needed for mining and processing uranium during the operating life of 

the plant. Based on this information and the need for additional land, overall land use impacts 

from the combination alternative could range from SMALL to MODERATE.

8.3.6.2 Socioeconomics 

As previously discussed, socioeconomic impacts are defined in terms of changes to the 

demographic and economic characteristics and social conditions of a region. For example, the 

number of jobs created by the construction and operation of a new single, natural gas-fired 

power plant at DAEC and wind farm could affect regional employment, income, and 

expenditures. Two types of jobs would be created: (1) construction-related jobs, which are 

transient, short in duration, and less likely to have a long-term socioeconomic impact; and 

(2) operation-related jobs in support of power generating operations, which have the greater 

potential for permanent, long-term socioeconomic impacts. The Staff conducted evaluations of 

construction and operations workforce requirements in order to measure their possible effect on 

current socioeconomic conditions. 

Based on GEIS projections and a workforce of 1,200 for a 1,000-MWe plant, a single 400-MWe 

unit at DAEC would require a peak estimated construction workforce of 490 workers. An 

estimated additional 300 construction workers would be required for this combination 

alternative. These workers could cause a short-term increase in the demand for services and 

temporary (rental) housing in the region around the construction site. 

After construction, some local communities may be temporarily affected by the loss of the 

construction jobs and associated loss in demand for business services. The rental housing 

market could also experience increased vacancies and decreased prices. The combined 

impact of nearly 800 construction workers on socioeconomic conditions would range from 

SMALL to MODERATE. 

Following construction, a single unit gas-fired power plant at the DAEC could provide up to 

13 jobs, based on FPL-DA estimates. Additional estimated operations workforce requirements 

for this combination alternative would include 50 operations workers for the wind farm. Given 

the small numbers of operations workers at these facilities, socioeconomic impacts associated 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-30 October 2010 

with the operation of the natural gas-fired power plant at DAEC and the wind farm would be 

SMALL. 

Socioeconomic effects of an energy efficiency program would also be SMALL. As noted in the 

GEIS, the program would likely employ some additional workers. 

8.3.6.3 Transportation 

Construction and operation of a natural gas-fired power plant and wind farm would increase the 

number of vehicles on roads in the vicinity of these facilities. During construction, cars and 

trucks would deliver workers, materials, and equipment to the worksites. The increase in 

vehicular traffic would peak during shift changes resulting in temporary levels of service impacts 

and delays at intersections. Pipeline construction and modification to existing natural gas 

pipeline systems could also have an impact. Highway delivery of large wind farm components 

may also cause impacts to traffic. Traffic-related transportation impacts during construction 

could range from SMALL to MODERATE depending on the location of the wind farm site, 

current road capacities, and average daily traffic volumes. 

During plant operations, transportation impacts would almost disappear. Given the small 

numbers of operational workers at these facilities, levels of service traffic impacts on local roads 

from the operation of the natural gas-fired power plant at the DAEC, as well as the wind farm, 

would be SMALL. Transportation impacts at the wind farm site or sites would also depend on 

current road capacities and average daily traffic volumes, but are likely to be small given the low 

number of workers employed by that component of the alternative. 

8.3.6.4 Aesthetics 

Aesthetic impact analysis focuses on the degree of contrast between the power plant and the 

surrounding landscape and the visibility of the power plant. In general, aesthetic changes would 

be limited to the immediate vicinity of DAEC and the wind farm facilities. 

A single, natural gas-fired unit located at DAEC could be approximately 100 ft (30 m) tall, with 

an exhaust stack up to 175 ft (53 m) tall. This facility is likely to be less noticeable than the 

current DAEC reactor building at 140 ft (42 m) with a 328-ft (100-m) off-gas stack. Noise during 

power plant operations would be limited to industrial processes and communications. In 

addition to the power plant structures, construction of natural gas pipelines would have a 

short-term impact. Noise from the pipelines could be audible offsite near compressors. In 

general, aesthetic changes would be limited to the immediate vicinity of DAEC and would be 

SMALL. 

The wind farm would have the greatest visual effect. The 147 wind turbines at over 300 ft 

(100 m) tall would be spread across 19,000 ac (7,600 ha) on multiple sites. In some locations, 

they would dominate the view and would likely become a major focus of viewer attention. 

Depending on its location, the aesthetic impacts from the construction and operation of the wind 

farm would be SMALL to LARGE. 

Aesthetic impacts from energy efficiency programs would most likely be SMALL. 

8.3.6.5 Historic and Archaeological Resources 

Cultural resources are the indications of human occupation and use of the landscape as defined 

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources 

are physical remains of human activities that predate written records; they generally consist of 
Environmental Impacts of Alternatives 

October 2010 8-31 NUREG-1437, Supplement 42 

artifacts that may alone or collectively yield information about the past. Historic resources 

consist of physical remains that postdate the emergence of written records; in the United States, 

they are architectural structures or districts, archaeological objects, and archaeological features 

dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic, 

but exceptions can be made for such properties if they are of particular importance, such as 

structures associated with the development of nuclear power (e.g., Shippingport Atomic Power 

Station) or Cold War themes. American Indian resources are sites, areas, and materials 

important to American Indians for religious or heritage reasons. Such resources may include 

geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

The cultural resource analysis encompassed the power plant site and adjacent areas that could 

potentially be disturbed by the construction and operation of alternative power plants. 

The analysis of land use impacts for the combination alternative focuses on the amount of land 

that would be affected by the construction and operation of a new natural gas-fired power plant 

at the DAEC site, an offsite wind farm, and a conservation energy component. The impact of 

constructing and operating a combination alternative at the DAEC site would be MODERATE. 

As noted in Section 4.9.6, potential impacts to historic and archaeological resources are 

possible due to the richness of archaeological resources expected on the DAEC property. 

DAEC in coordination with the SHPO has revised and implemented its excavation and trenching 

procedures and developed a cultural resource management plan for the plant property. These 

plans address potential impacts to both known and undiscovered resources. Plant procedures 

also include an inadvertent discovery (stop work) provision. As discussed in Section 8.2.6, 

depending on the resource richness of the area selected for onsite development, the impact 

would be MODERATE. 

The wind farm component of the combination alternative would require approximately 19,000 ac 

(7,600 ha) spread over several locations with approximately 74 ac (30 ha) in actual use. Lands 

not previously surveyed should be investigated by a qualified archaeologist prior to any ground 

disturbing activity. Depending on the location of the wind farm, the visual impacts would also 

need to be assessed. The 147 wind turbines at over 300 ft (100 m) tall and spread across 

multiple sites covering 19,000 ac (7,600 ha) may, in some locations, dominate the view and 

could impact present views with historic significance. Depending on the resource richness of 

the alternative site ultimately chosen for the wind power alternative, the impacts could range 

between SMALL to MODERATE. 

Impacts to historic and archaeological resources from implementing the energy efficiency 

programs would be SMALL. A conservation alternative would not affect land use or historical or 

cultural resources onsite or elsewhere in the State. 

8.3.6.6 Environmental Justice 

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of a new single, natural gas-fired power plant 

unit at DAEC and a 19,000 ac (7,600 ha) wind farm. Adverse health effects are measured in 

terms of the risk and rate of fatal or nonfatal adverse impacts on human health. 

Disproportionately high and adverse human health effects occur when the risk or rate of 

exposure to an environmental hazard for a minority or low-income population is significant and 

exceeds the risk or exposure rate for the general population or for another appropriate 

comparison group. Disproportionately high environmental effects refer to impacts, or risk of 

impact, on the natural or physical environment in a minority or low-income community that are 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-32 October 2010 

significant and appreciably exceeds the environmental impact on the larger community. Such 

effects may include biological, cultural, economic, or social impacts. Some of these potential 

effects have been identified in resource areas discussed in this SEIS. For example, increased 

demand for rental housing during power plant construction could disproportionately affect 

low-income populations. Minority and low-income populations are subsets of the general public 

residing around a power plant, and all are exposed to the same hazards generated from 

constructing and operating a new single, natural gas-fired, combined-cycle power plant unit and 

wind farm. 

Low-income families could benefit from weatherization and insulation programs. This effect 

would be greater than the effect for the general population because (according to the Office of 

Management and Budget) low-income households experience home energy burdens more than 

four times larger than the average household (OMB, 2007). Weatherization programs could 

target low-income residents as a cost-effective energy efficiency option since low-income 

populations tend to spend a larger proportion of their incomes paying utility bills (OMB, 2007). 

Overall impacts to minority and low-income populations from energy efficiency programs would 

be nominal, depending on program design and enrollment. 

Potential impacts to minority and low-income populations from the construction and operation of 

a new single, natural gas-fired power plant unit at DAEC and the wind farm would mostly consist 

of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing 

impacts). Noise and dust impacts from construction would be short-term and primarily limited to 

onsite activities. However, minority and low-income populations residing along site access 

roads could be affected by increased commuter vehicle traffic during shift changes. Increased 

demand for rental housing during construction in the vicinity of DAEC and the wind farm could 

affect low-income populations. However, these effects would be temporary during certain hours 

of the day and not likely to be high and adverse. Given the close proximity to three metropolitan 

areas, most construction workers would commute to the site, thereby reducing the potential 

demand for rental housing. 

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the construction and operation of a new single, natural gas-fired power 

plant unit and the wind farm (depending on its location) would not have a disproportionately high 

and adverse human health and environmental effect on minority and low-income populations. 

8.3.7 Waste Management 

During the construction stage of this alternative, land clearing and other construction activities 

would generate waste that can be recycled, disposed onsite, or shipped to the offsite waste 

disposal facility. During the operational stage, spent SCR catalysts, which are used to control 

NOx emissions from the natural gas-fired plants, would make up the majority of the waste 

generated by this alternative. 

There would be an increase in wastes generated during installation or implementation of 

conservation measures, such as appropriate disposal of old appliances, installation of control 

devices, and building modifications. New and existing recycling programs would help to 

minimize the amount of generated waste. 

The Staff concludes that overall waste impacts from the combination of the natural gas-fired unit 

constructed onsite, wind capacity, and conservation are SMALL. 
Environmental Impacts of Alternatives 

October 2010 8-33 NUREG-1437, Supplement 42 

8.4 ALTERNATIVES CONSIDERED BUT DISMISSED 

In this section, the Staff presents the alternatives it initially considered for analysis as 

alternatives to license renewal of DAEC, but later dismissed due to technical, resource 

availability, or commercial limitations that currently exist and that the Staff believes are likely to 

continue to exist when the existing DAEC license expires. Under each of the following 

technology headings, the Staff indicates why it dismissed each alternative from further 

consideration. 

8.4.1 Offsite Coal- and Gas-Fired Capacity 

While it is possible that coal- and gas-fired alternatives like those considered in Sections 8.1 

and 8.2, respectively, could be constructed at sites other than DAEC, the Staff determined that 

they would likely result in greater impacts than alternatives constructed at the DAEC site. 

Greater impacts would occur from construction of support infrastructure, like transmission lines, 

roads, and railway spurs that are already present on the DAEC site. Further, the community 

around DAEC is already familiar with the appearance of a power facility and it is an established 

part of the region’s aesthetic character. Workers skilled in power plant operations would also be 

available in this area. These factors are only likely to be available on other recently-industrial 

sites. In cases where recently-industrial sites exist, other remediation may also be necessary in 

order to ready the site for redevelopment. In short, an existing power plant site would present 

the best location for a new power facility. 

8.4.2 Coal-Fired Integrated Gasification Combined-Cycle 

While utilities across the United States have considered, or are considering, plans for integrated 

gasification combined-cycle (IGCC) coal-fired power plants, few IGCC facilities have yet been 

constructed. All facilities constructed in the United States to date have been smaller than 

DAEC, though Duke Energy’s proposed Edwardsport IGCC would be similar in size (Duke 

Energy, 2008). The technology, however, is commercially available and essentially relies on a 

gasifier stage and a combined-cycle turbine stage. Existing combined-cycle gas turbines (like 

the ones considered in Section 8.2) could be used as a part of an IGCC alternative. Emissions 

would likely be slightly greater than those from the gas-fired alternative, but significantly lower 

than those from the coal-fired alternative. In addition, an IGCC alternative would require slightly 

less onsite space than the coal-fired alternative in Section 8.1 and operate at a higher thermal 

efficiency. Depending on gasification technology employed, it would likely use a similar quantity 

of water. 

The EIA indicates that IGCC and other advanced coal plants may become increasingly common 

in coming years, though uncertainties about construction time periods and commercial viability 

in the near future leads the Staff to believe that IGCC is an unlikely alternative to DAEC license 

renewal (EIA, 2009a). 

8.4.3 New Nuclear 

It is unlikely that a nuclear alternative could be sited, constructed, and operational by the time 

the DAEC operating license expires in February of 2014 (FPL-DA, 2008). Sources in the 

nuclear industry have recently indicated that reactor projects currently under development are 

likely eight or nine years from completion (Nucleonics Week, 2008), or possibly online in the 

2016–2017 timeframe. A potential plant would also require additional time to develop an 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-34 October 2010 

application. Given the relatively short time remaining on the current DAEC operating license, 

the Staff has not evaluated new nuclear generation as an alternative to license renewal. 

8.4.4 Energy Conservation/Energy Efficiency 

Though often used interchangeably, energy conservation and energy efficiency are different 

concepts. Energy efficiency typically means deriving a similar level of services by using less 

energy, while energy conservation simply indicates a reduction in energy consumption. Both fall 

into a larger category known as demand-side management (DSM). DSM measures—unlike the 

energy supply alternatives discussed in previous sections—address energy end uses. DSM 

can include measures that shift energy consumption to different times of the day to reduce peak 

loads, measures that can interrupt certain large customers during periods of high demand or 

measures that interrupt certain appliances during high demand periods, and measures like 

replacing older, less efficient appliances, lighting, or control systems. DSM also includes 

measures that utilities use to boost sales, such as encouraging customers to switch from gas to 

electricity for water heating. 

Unlike other alternatives to license renewal, the GEIS notes that conservation is not a discrete 

power generating source; it represents an option that States and utilities may use to reduce their 

need for power generation capability (NRC, 1996). 

In February of 2008, a “green government” initiative was established in the State of Iowa, 

creating a task force tasked with the goal of reducing electricity use in office buildings by at least 

15 percent by 2013. In addition, in May of 2008, S.F. 2386 was signed into effect by the 

governor which requires Iowa consumer-owned electric utilities to establish efficiency goals, 

setting an annual goal of a 1.5 percent improvement in demand-side energy efficiency 

(EPA, 2009d). On November 15, 2007, Iowa signed the Midwestern Regional Greenhouse Gas 

Reduction Accord, committing to an overall 2 percent reduction in energy use by 2015. If this 

goal was to be realized, however, conservation would still not be enough to replace the capacity 

of DAEC. Also, because these goals are considered optional (the utilities are only required to 

report back on their progress), it is unlikely that increased energy efficiency in the State of Iowa 

would have grown enough to offset the loss of DAEC by the license expiration in 2014. 

Because of this, the Staff has not evaluated energy conservation/efficiency as a discrete 

alternative to license renewal. It has, however, been considered as a component of the 

combination alternative. 

8.4.5 Purchased Power 

In its ER, FPL-DA indicated that purchased electrical power is not an economical alternative to 

DAEC license renewal. The Staff recognizes the potential for purchased power to offset a 

portion of the electricity generated by DAEC, however, for the 2014 to 2034 timeframe of DAEC 

renewal, FPL-DA indicated that there are no guaranteed available power sources to replace the 

610 MWe that DAEC provides (FPL-DA, 2008). Because of the lack of assured available 

purchased electrical power, the Staff has not evaluated purchased power as an alternative to 

license renewal. 
Environmental Impacts of Alternatives 

October 2010 8-35 NUREG-1437, Supplement 42 

8.4.6 Solar Power 

Solar technologies use the sun’s energy to produce electricity. Currently, the DAEC site 

receives approximately 3.5 to 4.5 kilowatt hour (kWh) per square meter per day, for solar 

collectors oriented at an angle equal to the installation’s latitude (NREL, 2008). Since flat-plate 

photovoltaics tend to be roughly 25 percent efficient, a solar-powered alternative would require 

at least 23,000 ac (9,300 ha) of collectors to provide an amount of electricity equivalent to that 

generated by DAEC. Space between parcels and associated infrastructure increase this land 

requirement. This amount of land, while large, is consistent with the land required for coal and 

natural gas fuel cycles. In the GEIS, the Staff noted that, by its nature, solar power is 

intermittent (i.e., it does not work at night and cannot serve baseload when the sun is not 

shining), and the efficiency of collectors varies greatly with weather conditions. A solar-powered 

alternative would require energy storage or backup power supply to provide electric power at 

night. Given the challenges in meeting baseload requirements, the Staff did not evaluate solar 

power as an alternative to license renewal of DAEC. 

8.4.7 Wood Waste 

In 1999, DOE researchers estimated that Iowa has biomass fuel resources consisting of forest, 

mill, agricultural, and urban residues, as well as energy crop potential. Excluding potential 

energy crops, DOE researchers projected that Iowa had 24,490,500 tons (22,217,800 MT) of 

plant-based biomass available at $50 per ton delivered (Walsh et al., 2000; costs are in 1995 

dollars). The Bioenergy Feedstock Development Program at Oak Ridge National Laboratory 

estimated that each air-dry pound of wood residue produces approximately 6,400 Btu of heat. 

Assuming a 33 percent conversion efficiency, biomass might be capable of generating 30.3 

terawatt hours of electricity. 

Walsh et al. (2000) go on to note that these estimates of biomass capacity contain substantial 

uncertainty, and that potential availability does not mean biomass would actually be available at 

the prices indicated or that resources would be usably free of contamination. Some of these 

plant wastes already have reuse value, and would likely be more costly to deliver because of 

competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest 

on a regular basis (the majority of biomass capacity in Iowa, however, comes from agricultural 

residues, with very little potential from forest residues). As a result, the available resource 

potential is likely less than the estimate totals in Walsh et al., and the total resource is not likely 

to be sufficient to substitute for the capacity provided by DAEC. As a result, the Staff has not 

considered a wood-fired alternative to DAEC license renewal. 

8.4.8 Hydroelectric Power 

According to researchers at the Idaho National Energy and Environmental Laboratory, Iowa has 

an estimated 455 MWe of technically available, undeveloped hydroelectric resources at 79 sites 

throughout the State (INEEL, 1997). Most of these sites have a potential capacity of less than 

1 MWe, though the largest undeveloped site in Iowa is in the Iowa River Basin, which has 

99 MWe of potential. Given that the available hydroelectric potential in the State of Iowa 

constitutes less than the generating capacity of DAEC, the Staff did not evaluate hydropower as 

an alternative to license renewal. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-36 October 2010 

8.4.9 Wave and Ocean Energy 

Ocean waves, currents, and tides are often predictable and reliable. Ocean currents flow 

consistently, while tides can be predicted months and years in advance with well-known 

behavior in most coastal areas. Most of these technologies are in relatively early stages of 

development. Because the DAEC site is not located near an ocean, the Staff did not consider 

wave and ocean energy as an alternative to DAEC license renewal. 

8.4.10 Geothermal Power 

Geothermal energy has an average capacity factor of 90 percent and can be used for baseload 

power where available. However, geothermal electric generation is limited by the geographical 

availability of geothermal resources (NRC, 1996). Although Iowa has some geothermal 

potential in a heating capacity, it does not have sufficient geothermal electricity potential for 

electricity generation. The Staff concluded that geothermal energy is not a reasonable 

alternative to license renewal at DAEC. 

8.4.11 Municipal Solid Waste 

Municipal solid waste combustors use three types of technologies—mass burn, modular, and 

refuse-derived fuel. Mass burning is currently the method used most frequently in the United 

States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or 

hazardous components present in the waste stream are combusted, and toxic constituents are 

exhausted to the air or become part of the resulting solid wastes. Currently, approximately 

89 waste-to-energy plants operate in the United States. These plants generate approximately 

2,700 MWe, or an average of 30 MWe per plant. More than 27 average-sized plants would be 

necessary to provide the same level of output as the other alternatives to DAEC license 

renewal. 

Estimates in the GEIS suggest that the overall level of construction impact from a waste-fired 

plant would be approximately the same as that for a coal-fired power plant. Additionally, 

waste-fired plants have the same or greater operational impacts than coal-fired technologies 

(including impacts on the aquatic environment, air, and waste disposal). The initial capital costs 

for municipal solid-waste plants are greater than for comparable steam-turbine technology at 

coal-fired facilities or at wood-waste facilities because of the need for specialized waste 

separation and handling equipment (NRC, 1996). 

The decision to burn municipal waste to generate energy is usually driven by the need for an 

alternative to landfills rather than energy considerations. The use of landfills as a waste 

disposal option is likely to increase in the near term as energy prices increase; however, it is 

possible that municipal waste combustion facilities may become attractive again. 

Given the small average installed size of municipal solid waste plants and the unfavorable 

regulatory environment, the Staff does not consider municipal solid waste combustion to be a 

feasible alternative to DAEC license renewal. 

8.4.12 Biofuels 

In addition to wood and municipal solid waste fuels, there are other concepts for biomass-fired 

electric generators, including direct burning of energy crops, conversion to liquid biofuels, and 

biomass gasification. In the GEIS, the Staff indicated that none of these technologies had 

progressed to the point of being competitive on a large scale or of being reliable enough to 
Environmental Impacts of Alternatives 

October 2010 8-37 NUREG-1437, Supplement 42 

replace a baseload plant such as DAEC. After re-evaluating current technologies, the Staff 

finds other biomass-fired alternatives are still unable to reliably replace the DAEC capacity. For 

this reason, the Staff does not consider other biomass-derived fuels to be feasible alternatives 

to DAEC license renewal. 

8.4.13 Oil-Fired Power 

The EIA projects that oil-fired plants would account for very little of the new generation capacity 

constructed in the United States during the 2008 to 2030 time period. Further, the EIA does not 

project that oil-fired power would account for any significant additions to capacity (EIA, 2009b). 

The variable costs of oil-fired generation tend to be greater than those of the nuclear or 

coal-fired operations, and oil-fired generation tends to have greater environmental impacts than 

natural gas-fired generation. In addition, future increases in oil prices are expected to make 

oil-fired generation increasingly more expensive (EIA, 2009b). The high cost of oil has 

prompted a steady decline in its use for electricity generation. Thus, the Staff did not consider 

oil-fired generation as an alternative to DAEC license renewal. 

8.4.14 Fuel Cells 

Fuel cells oxidize fuels without combustion and its environmental side effects. Power is 

produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 

over a cathode and separating the two by an electrolyte. The only byproducts (depending on 

fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a variety of 

hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically 

used as the source of hydrogen. 

At the present time, fuel cells are not economically or technologically competitive with other 

alternatives for electricity generation. The EIA projects that fuel cells may cost $5,374 per 

installed kilowatts (kW) (total overnight costs) (EIA, 2009b), or 3.5 times the construction cost of 

new coal-fired capacity and 7.5 times the cost of new, advanced gas-fired, combined-cycle 

capacity. In addition, fuel cell units are likely to be small in size (the EIA reference plant is 

10 MWe). While it may be possible to use a distributed array of fuel cells to provide an 

alternative to DAEC, it would be extremely costly to do so and would require many units. 

Accordingly, the Staff does not consider fuel cells to be an alternative to DAEC license renewal. 

8.4.15 Delayed Retirement 

FPL-DA indicated in the ER that it has no knowledge of any retired plants or any plans to retire 

plants in the State of Iowa prior to 2014 (FPL-DA, 2008). As a result, delayed retirement is not 

a feasible alternative to license renewal. Other generation capacity may be retired prior to the 

expiration of the DAEC license, but this capacity is likely to be older, less efficient, and without 

modern emissions controls. 

8.5 NO-ACTION ALTERNATIVE 

This section examines environmental effects that would occur if the Staff takes no action. No 

action in this case means that the Staff does not issue a renewed operating license for DAEC 

and the license expires at the end of the current license term, in February 2014. If the Staff 

takes no action, the plant would shutdown at or before the end of the current license. After 

shutdown, plant operators would initiate decommissioning according to 10 CFR 50.82. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-38 October 2010 

Table 8-4 provides a summary of environmental impacts of no action compared to continued 

operation of the DAEC.

The Staff notes that the option of no action is the only alternative considered in-depth that does 

not satisfy the purpose and need for this SEIS, as it does not provide power generation capacity 

nor would it meet the needs currently met by DAEC or that the alternatives evaluated in 

Sections 8.1 through 8.3 would satisfy. Assuming that a need currently exists for the power 

generated by DAEC, the no-action alternative would require that the appropriate energy 

planning decision-makers rely on an alternative to replace the capacity of DAEC or reduce the 

need for power. 

This section addresses only those impacts that arise directly as a result of plant shutdown. The 

environmental impacts from decommissioning and related activities have already been 

addressed in several other documents, including the Final Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 

(NRC, 2002); the license renewal GEIS (Chapter 7; NRC, 1996); and Chapter 7 of this SEIS. 

These analyses either directly address or bound the environmental impacts of decommissioning 

whenever FPL-DA ceases operating DAEC. 

The Staff notes that, even with a renewed operating license, DAEC would eventually shut down, 

and the environmental effects addressed in this section would occur at that time. Since these 

effects have not otherwise been addressed in this SEIS, the impacts will be addressed in this 

section. As with decommissioning effects, shutdown effects are expected to be similar whether 

they occur at the end of the current license or at the end of a renewed license. 

Table 8-4. Summary of Environmental Impacts of No Action Compared to Continued 

Operation of Duane Arnold Energy Center

No Action Continued DAEC Operation 

Air Quality SMALL SMALL 

Groundwater SMALL SMALL 

Surface Water SMALL SMALL 

Aquatic and Terrestrial Resources SMALL SMALL 

Human Health SMALL SMALL 

Socioeconomics SMALL to MODERATE SMALL 

Historic and archaeological 

resources 

Waste Management 

SMALL 

SMALL 

MODERATE 

SMALL 
Environmental Impacts of Alternatives 

October 2010 8-39 NUREG-1437, Supplement 42 

8.5.1 Air Quality 

When the plant stops operating, there would be a reduction in emissions from activities related 

to plant operation such as use of diesel generators and employee vehicles. In Chapter 4, the 

Staff determined that these emissions would have a SMALL impact on air quality during the 

renewal term. Therefore, if the emissions decrease, the impact to air quality would also 

decrease and would be SMALL. 

8.5.2 Groundwater Use and Quality 

The use of groundwater would diminish as plant personnel are removed from the site and 

operations cease. Some consumption of groundwater may continue as a small staff remains 

onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than 

during operations, but would remain SMALL. 

8.5.3 Surface Water Use and Quality 

The rate of consumptive use of surface water would decrease as the plant is shut down and the 

reactor cooling system continues to remove the heat of decay. Wastewater discharges would 

also be reduced considerably. Shutdown would reduce the already SMALL impact on surface 

water resources and quality. 

8.5.4 Aquatic and Terrestrial Resources 

8.5.4.1 Aquatic Ecology 

If the plant were to cease operating, impacts to aquatic ecology would decrease, as the plant 

would withdraw and discharge less water than it does during operations. Shutdown would 

reduce the already SMALL impacts to aquatic ecology. 

8.5.4.2 Terrestrial Ecology 

Terrestrial ecology impacts would be SMALL. No additional land disturbances on or offsite 

would occur. 

8.5.5 Human Health 

Human health risks would be smaller following plant shutdown. The plant, which is currently 

operating within regulatory limits, would emit less gaseous and liquid radioactive material to the 

environment. In addition, following shutdown, the variety of potential accidents at the plant 

(radiological or industrial) would be reduced to a limited set associated with shutdown events 

and fuel handling and storage. In Chapter 4 of this SEIS, the Staff concluded that the impacts 

of continued plant operation on human health would be SMALL. In Chapter 5, the Staff 

concluded that the impacts of accidents during operation were SMALL. Therefore, as 

radioactive emissions to the environment decrease, and as the likelihood and variety of 

accidents decrease following shutdown, the Staff concludes that the risks to human health 

following plant shutdown would be SMALL. 
Environmental Impacts of Alternatives 

NUREG-1437, Supplement 42 8-40 October 2010 

8.5.6 Socioeconomics 

8.5.6.1 Land Use 

Plant shutdown would not affect onsite land use. Plant structures and other facilities would 

remain in place until decommissioning. Most transmission lines connected to DAEC would 

remain in service after the plant stops operating. Maintenance of most existing transmission 

lines would continue as before. Impacts on land use from plant shutdown would be SMALL. 

8.5.6.2 Socioeconomics 

Plant shutdown would have an impact on socioeconomic conditions in the region around DAEC. 

Plant shutdown would eliminate approximately 669 jobs and would reduce tax revenue in the 

region. The loss of these contributions, which may not entirely cease until after 

decommissioning, would have a MODERATE impact. See Appendix J to NUREG-0586, 

Supplement 1 (NRC, 2002) for additional discussion of the potential socioeconomic impacts of 

plant decommissioning. 

8.5.6.3 Transportation 

Traffic volumes on the roads in the vicinity of DAEC would be reduced after plant shutdown. 

Most of the reduction in traffic volume would be associated with the loss of jobs at the plant. 

Deliveries of materials and equipment to the plant would be reduced until decommissioning. 

Transportation impacts would be SMALL as a result of plant shutdown. 

8.5.6.4 Aesthetics 

Plant structures and other facilities would remain in place until decommissioning. Noise caused 

by plant operation would cease. Aesthetic impacts of plant closure would be SMALL. 

8.5.6.5 Historic and Archaeological Resources 

Impacts from the no-action alternative would be SMALL, since DAEC would be 

decommissioned. A separate environmental review would be conducted for decommissioning. 

That assessment would address the protection of historic and archaeological resources. 

8.5.6.6 Environmental Justice 

Termination of power plant operations would not disproportionately affect minority and 

low-income populations outside of the immediate vicinity of DAEC. Impacts to all other resource 

areas would be SMALL to MODERATE. For socioeconomic data regarding the analysis of 

environmental justice issues, the reader is referred to the subsection on environmental justice in 

Section 8.1.6. Minority and low-income populations in the area are relatively small and only a 

small number of workers are needed to construct and operate a natural gas-fired power plant 

and wind farm; impacts on these communities would not be disproportionate with that of the rest 

of the population within the 50-mi radius. Therefore, because there are no high or adverse 

impacts, by definition, there is also no disproportionate impact upon low income or minority 

populations. See Appendix J of NUREG-0586, Supplement 1 (NRC, 2002) for additional 

discussion of these impacts. 
Environmental Impacts of Alternatives 

October 2010 8-41 NUREG-1437, Supplement 42 

8.5.7 Waste Management 

If the no-action alternative were implemented, the generation of high-level waste would stop and 

generation of low-level and mixed waste would decrease. Impacts from the implementation of 

the no-action alternative are expected to be SMALL. 

8.6 ALTERNATIVES SUMMARY 

In this chapter, the Staff considered the following action alternatives to DAEC license renewal: 

supercritical coal-fired generation, natural gas combined-cycle generation, and a combination 

alternative. No action by the Staff and the effects it would have were also considered. The 

impacts for all alternatives are summarized in Table 8-5 on the following page. 

Socioeconomic impacts could range from SMALL to MODERATE. The Staff did not determine a 

single significance level for these impacts, but the Commission determined them to be Category 

1 issues nonetheless. The environmental impacts of the proposed action (issuing a renewed 

DAEC operating license) would be SMALL for all other impact categories, except for the 

Category 1 issue of collective offsite radiological impacts from the fuel cycle, high-level waste, 

and spent fuel disposal. As a result of construction, the impacts of coal-fired, natural gas, and 

the combination alternatives on historic and archaeological resources would all be MODERATE, 

but would be SMALL for the no-action alternative. 

In the Staff’s professional opinion, the coal-fired alternative would have the greatest overall 

adverse environmental impact. This alternative would result in MODERATE waste 

management, land use, and air quality impacts. Its impacts upon socioeconomic and biological 

resources could range from SMALL to MODERATE. This alternative is not an environmentally 

preferable alternative due to air quality impacts from NOx, SOx, PM, HAPs, CO, CO2, and 

mercury (and the corresponding human health impacts), as well as construction impacts to 

aquatic and terrestrial, and potential historic and archaeological resources. 

With the exception of land use, socioeconomic, and air quality impacts, the gas-fired alternative 

would result in SMALL impacts. Socioeconomic, land use, and air quality impacts could range 

from SMALL to MODERATE. This alternative would result in substantially lower air emissions 

and waste management than the coal-fired alternative. 

The combination alternative would have lower air emissions and waste management impacts 

than both the gas-fired and coal-fired alternatives, however, it would have relatively higher 

construction impacts in terms of land use, aquatic and terrestrial resources, and potential 

disruption to historic and archaeological resources, mainly as a result of the wind turbine 

component. 

Under the no-action alternative, plant shutdown would eliminate approximately 669 jobs and 

would reduce tax revenue in the region. The loss of these contributions, which may not entirely 

cease until after decommissioning, would have a SMALL to MODERATE impact. However, the 

no-action alternative does not meet the purpose and need stated in this SEIS. 

Therefore, in the Staff’s best professional opinion, the environmentally preferred alternative in 

this case is the license renewal of DAEC. All other action alternatives capable of meeting the 

needs currently served by DAEC entail potentially greater impacts than the proposed action of 

license renewal of DAEC. 
Environmental Impacts of Alternatives 

Table 8-5. Summary of Environmental Impacts of Proposed Action and AlternativesNUREG-1437, Supplement 42 8-42 October 2010 

Alternative 

Impact Area 

Air Quality 

Groundwater 

Surface Water 

Aquatic and Terrestrial 

Resources 

Human Health 

Socioeconomics 

Waste Management 

License Renewal SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE SMALL(a)

Supercritical Coal-fired 

Alternative MODERATE SMALL SMALL SMALL to MODERATE SMALL SMALL to MODERATE MODERATE 

Gas-fired Alternative SMALL to MODERATE SMALL SMALL SMALL SMALL SMALL to MODERATE SMALL 

Combination Alternative SMALL SMALL SMALL SMALL to MODERATE SMALL SMALL to LARGE SMALL 

No-Action Alternative SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE SMALL 

(a) For the DAEC license renewal alternative, waste management was evaluated in Chapter 6. Consistent with the findings in the GEIS, these impacts were 

determined to be SMALL with the exception of collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal. 
Environmental Impacts of Alternatives 

October 2010 8-43 NUREG-1437, Supplement 42 

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NUREG-1437, Supplement 42 8-44 October 2010 

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http://hydropower.inl.gov/resourceassessment/pdfs/states/ia.pdf (accessed July 2009). 

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Available URL: http://www.iowadnr.gov/energy/newfiles/new_checklist.pdf (accessed August 

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(PSD) Permit Review Technical Support Document for Permit Issuance. Available URL: 

http://aq48.dnraq.state.ia.us:8080/psd/7001008/PSD_PN_06-494/factsheet.pdf (accessed July 

2009). 

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101: “Solid Waste Comprehensive Planning Requirements.” Available URL: 

http://www.iowadnr.gov/waste/policy/files/101_responsiveness.pdf (accessed July 2009). 

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Resources,” Interactive Map. Available URL: 

http://mapserve2.nrel.gov/website/Resource_Atlas/viewer.htm (accessed August 2009). 

Nucleonics Week. 2008. “US new reactors more likely online in 2016 and beyond, NEI official 

says,” Nucleonics Week, Vol. 49, No. 15, April 10, 2008. 

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Performance Data.” Available URL: 

http://www.powergeneration.siemens.com/products-solutions-services/power-plant-soln/combin

ed-cycle-power-plants/technical-data (accessed July 2009). 

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. 

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on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors, NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C. 

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on the Low Income Home Energy Assistance Program Assessment,” ADAMS Accession 

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http://www.whitehouse.gov/omb/expectmore/detail/10001059.2003.html (accessed June 2009). 
October 2010 9-1 NUREG-1437, Supplement 42 

9.0 CONCLUSION 

This supplemental environmental impact statement (SEIS) contains the environmental review of 

the Florida Power and Light Energy Duane Arnold, LLC (FPL-DA) application for a renewed 

operating license for Duane Arnold Energy Center (DAEC) as required by Part 51 of Title 10, of 

the Code of Federal Regulations (10 CFR Part 51), which are the U.S. Nuclear Regulatory 

Commission’s (NRC) regulations for implementing the National Environmental Policy Act 

(NEPA) of 1969. The following chapter: 

● provides a summary of environmental impacts of license renewal (Section 9.1) 

● compares environmental impacts of license renewal and alternatives 

(Section 9.2) 

● addresses three basic requirements required under Section 102(2) of NEPA 

(Section 9.3) 

● provides an NRC staff (Staff) recommendation regarding the license renewal 

alternative for DAEC (Section 9.4) 

9.1 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

License renewal impact issues have been previously reviewed and categorized in Chapter 4. 

Generic issues (Category 1) rely on the analysis provided in the Generic Environmental Impact 

Statement (GEIS) for License Renewal of Nuclear Power Plants prepared by the NRC and are 

discussed briefly in this SEIS (NRC, 1996) (NRC, 1999a). The Staff has also analyzed 

site-specific issues (Category 2) for DAEC. As explained in Chapter 1, impacts can be assigned 

a significance level of: SMALL, MODERATE, or LARGE. 

The Staff has reviewed the site-specific Category 2 issues in this SEIS. As applicable, 

mitigation measures were considered for Category 2 issues. In conducting this review, the Staff 

has concluded that with only one exception, issuing a license renewal would result in a SMALL 

impact to the issues reviewed in this SEIS. This exception involves potential impacts on historic 

and archaeological resources at DAEC, which could result in a MODERATE impact. 

9.1.1 Other Environmental Impacts 

No impacts beyond those discussed in the GEIS were identified for the issue of land use. The 

GEIS concluded that the impacts on land use are SMALL, and that additional site-specific 

mitigation measures are unlikely to be sufficiently beneficial to be warranted. 

No impacts beyond those discussed in the GEIS were identified for the issue of air quality. The 

GEIS concluded that the impacts on air quality are SMALL, and that additional site-specific 

mitigation measures are unlikely to be sufficiently beneficial to be warranted. 

No impacts beyond those discussed in the GEIS were identified for any of the generic surface 

water issues. Consistent with the GEIS, the staff concluded that these impacts are SMALL and 

that additional mitigation measures are unlikely to be sufficiently beneficial to be warranted. For 
Conclusion 

NUREG-1437, Supplement 42 9-2 October 2010 

Category 2 surface and groundwater use conflicts, the SEIS concluded that the potential 

impacts are SMALL even during a period of low flow. 

No impacts beyond those discussed in the GEIS were identified for any aquatic or terrestrial 

resources. Consistent with the GEIS, the Staff, therefore, concludes that the impacts to aquatic 

and terrestrial resources, including threatened and endangered species are SMALL, and 

additional site-specific mitigation measures are unlikely to be sufficiently beneficial to warrant 

implementation. 

No impacts beyond those discussed in the GEIS were identified for any of the generic human 

health-related issues. Consistent with the GEIS, the staff concluded that these impacts are 

SMALL, and that additional site-specific mitigation measures are unlikely to be sufficiently 

beneficial to be warranted. The GEIS determined that the effects of thermophilic microbiological 

organisms and acute shock are Category 2 issues requiring analysis in the SEIS; the SEIS 

concluded that the potential impacts from electric shock and thermophilic microbiological 

organisms on human health are SMALL; measures that could mitigate their potential impacts 

are described in Chapter 4. The SEIS adopted the finding in the GEIS, that the chronic affects 

of electromagnetic fields from power lines is as yet an “uncertain” hazard. 

With the exception of historic and archaeological resources (described above), the 

socioeconomic impacts (environmental justice considerations were not assigned a significance 

level) were determined to be SMALL, and plant-specific mitigation measures would not be 

sufficiently beneficial to be warranted. FPL-DA management in coordination with the SHPO has 

revised and implemented its excavation and trenching procedures and developed a cultural 

resource management plan to mitigate potential impacts on both known and undiscovered 

resources. 

No impacts beyond those discussed in the GEIS were identified for any uranium fuel cycle and 

waste management issues. Consistent with the GEIS, the Staff, therefore, concludes that the 

waste management impacts are SMALL, and additional site-specific mitigation measures are 

unlikely to be sufficiently beneficial to warrant implementation. 

9.2 COMPARISON OF IMPACTS OF LICENSE RENEWAL AND ALTERNATIVES 

The term “energy alternatives” is used to designate the supercritical coal-fired alternative, 

natural gas combined-cycle alternative, and the combination alternative. This section compares 

environmental impacts of license renewal with the reasonable energy alternatives, including the 

alternative of taking no-action, which are described in Chapter 8. 

As noted earlier, the alternative of license renewal could result in a MODERATE impact to 

historical or archaeological resources. On balance, this impact is considered to be smaller than 

the environmental degradation of terrestrial and aquatic resources, air quality including the 

release of greenhouse gas (GHG) emissions, and socioeconomic disruptions as a result of 

constructing and operating one of the energy alternatives. 

In the Staff’s best professional assessment, the impacts of license renewal are, on balance, less 

than or substantially less than those of the supercritical coal-fired alternative, particularly with 

respect to the issues of criteria pollutants, hazardous air pollutants (HAPs), GHG emissions, 

generation of waste products, and the potential for disrupting socioeconomic and biological 

resources. 
Conclusion 

October 2010 9-3 NUREG-1437, Supplement 42 

With respect to the gas-fired alternative, the option of license renewal is, on balance, deemed to 

be moderately better, particularly with respect to deferring air and GHG emissions that would be 

produced if the gas-fired alternative were pursued, as well as potential socioeconomic 

disruptions. 

When compared with the combination alternative, the option of license renewal is, on balance, 

deemed to be marginally better, particularly with respect to aquatic and terrestrial resource 

impacts, and potential socioeconomic disruptions. 

The only alternative that is equivalent to or is less detrimental than the license renewal 

alternative is that of taking no-action. However, in terms of lost jobs and tax revenue, the 

no-action alternative would result in a larger socioeconomic impact than license renewal. 

In summary, the Staff concludes that the impacts of license renewal are reasonable, and that on 

balance, the potential effects are generally less than those of pursuing the energy alternatives. 

Only the no-action alternative would result in equivalent or less impact than the alternative of 

license renewal; however, the no-action alternative does not meet the purpose and need for 

taking action. 

9.3 SPECIAL CONSIDERATIONS PURSUANT TO SECTION 102(2) OF NEPA 

Environmental impacts of license renewal are described in Chapters 4 and 6 of this SEIS, while 

impacts of alternatives are described in Chapter 8. In addition to investigating environmental 

impacts and alternatives to a proposed action, Section 102(2) of the NEPA statute also requires 

that an environmental impact statement (EIS) specifically address: 

● any adverse environmental effects which cannot be avoided should the proposal 

be implemented 

● the relationship between local short-term uses of man’s environment and the 

maintenance and enhancement of long-term productivity 

● any irreversible and irretrievable commitments of resources which would be 

involved in the proposed action should it be implemented 

These requirements are described in the following sections. 

9.3.1 Unavoidable Adverse Environmental Impacts 

Unavoidable adverse environmental impacts are those effects that would occur after 

implementation of all feasible mitigation measures. Implementing the license renewal 

alternative or any one of the energy alternatives considered in this SEIS would result in some 

unavoidable adverse environmental impacts; with the exception of a potential disruption to 

historical and archaeological resources, the unavoidable impacts of license renewal would be 

SMALL. 

Under the license renewal alternative, the existing plant and transmission corridors would 

continue to be used for their current mission. This alternative would continue to limit other land 

use options. However, no additional land would be required to support this alternative. 
Conclusion 

NUREG-1437, Supplement 42 9-4 October 2010 

The alternative of license renewal would result in a relatively minor unavoidable adverse impact 

on air quality as a result of equipment such as diesel generators and vehicles. Workers would 

be exposed to small amounts of hazardous nonradiological chemicals and waste, and the public 

would be exposed to very small levels of chemical emissions. Emissions and use of chemicals 

would comply with applicable Federal and State regulations and emissions standards. 

As described earlier, withdrawing surface water from the Cedar River could result in a small 

drawdown in the underlying groundwater system, which could limit water use for other 

purposes. This impact would be SMALL, even during periods of low flow. For both the Cedar 

River and underlying groundwater system, current practices for managing the impact of plant 

water usage are considered to be adequate. 

Under the alternative of license renewal, the existing plant and transmission corridors would 

continue to be used for their current mission. This land would continue to pose a SMALL impact 

on biological resources. However, no additional biological disturbances would occur under this 

alternative. 

Workers and members of the public would face exposure to small amounts of radioactive 

emissions. Workers would be exposed to small levels of radiation during routine plant 

operations, including routine nuclear fuel operations. Workers would have higher levels of 

exposure than members of the public, but doses would be administratively controlled and would 

comply with all applicable regulatory standards and administrative control limits. Chemical and 

radiological emissions would not exceed the National Emission Standards for criteria pollutants 

or HAPs. In comparison, construction and operation of one of the energy alternatives would 

also involve the use of hazardous chemicals and generation of hazardous waste products. 

Potential disturbance to historic and archaeological artifacts could result in a MODERATE 

impact to these resources. However, DAEC has implemented revised procedures and a cultural 

resource management plan which should help to minimize potential impacts. 

Workers would also face unavoidable exposure to small amounts of radiation from radioactive 

spent nuclear fuel and waste operations. Radiation levels that workers are exposed to are 

closely monitored. Exposures would not exceed applicable Federal regulatory standards. All 

personal operations are also conducted in strict compliance with applicable Federal regulations. 

Waste streams generated during plant operation would be collected, stored, and shipped for 

suitable treatment, recycling, or disposal in accordance with applicable Federal and State 

regulations. Due to the costs of handling these materials, power plant operators would be 

expected to conduct all activities and optimize all operations in a way that generates the 

smallest amount of waste practical. Management and disposal of this waste would require 

long-term funding and monitoring, and would consume space at treatment, storage, or disposal 

facilities to prevent release to the biosphere. 

9.3.2 Relationship Between Local Short-Term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity 

As used in this section, the term “short term” refers to the period of time during which DAEC 

power generating activities would continue. The principle short-term benefit derived from the 

alternative of license renewal would be the generation of a relatively clean (the impacts of 

radiological waste are described below) and economical supply of energy. 
Conclusion 

October 2010 9-5 NUREG-1437, Supplement 42 

As described in Chapters 4 and 6, continued operation of the DAEC over the license renewal 

term would result in a number of short-term uses and impacts upon environmental resources. 

Operation of DAEC would continue to consume diesel and gasoline to power equipment and 

vehicles, and electricity to power equipment. The plant site and the utility corridors would also 

result in a continued short-term impact to surrounding biological habitat and resources, and 

would limit land use options. After decommissioning the plant, the land might be released for 

other long-term productive uses, which could include re-establishment of biological habitat. 

Use of cooling water could result in a small short-term decrease in groundwater productivity. 

However, once the plant were shutdown and withdrawal of water from the Cedar River ceased, 

the groundwater aquifer could be recharged. Alternatively, water currently used for cooling 

purposes could be diverted to other long-term uses. 

DAEC air emissions would, over the short-term, introduce small amounts of hazardous and 

radioactive constituents into the biosphere. However, the exposure to hazardous and 

radioactive constituents is low, and it is unlikely that public health and long-term productivity of 

the environment would be significantly jeopardized. In comparison, the energy alternatives, 

particularly the supercritical coal-fired alternative, would result in emissions of GHGs and criteria 

air pollutants with potentially more serious and longer-term health concerns to humans and 

biota. In comparison to the option of license renewal, construction of any one of the energy 

alternatives described in Chapter 8 would result in a long-term or permanent consumption of 

sizeable quantities of materials and resources such as steel, concrete, diesel and gasoline 

fuels, electricity, water, land, and potentially loss of biological habitat. In addition to construction 

resource usage, the energy alternatives would also consume fuel and other operational 

resources. With the possible exception of the combination alternative, the construction and 

operational resource impacts resulting from pursuing one of the energy alternatives would 

generally be greater than that consumed in operating DAEC over a comparable timeframe; the 

combination alternative could result in long-term or permanent changes to land use, biological 

resources, and socioeconomic disruptions. 

Continued operation of DAEC would produce spent nuclear fuel and low-level radioactive waste 

(LLW), as well as hazardous and nonhazardous waste, which could have a long-term 

detrimental impact on the biosphere and environmental productivity. Management and disposal 

of this waste would require long-term funding and monitoring, and would consume space at 

storage or disposal facilities. Regardless of the location, geological containment and/or use of 

land to meet waste disposal needs would reduce the long-term productivity of the land and 

geological resources. In contrast, the supercritical coal-fired alternative, and to a less extent the 

natural-gas alternative, would also produce sizeable quantities of hazardous waste with 

associated long-term impacts on environmental productivity. 

Continued employment and employee expenditures, as well as tax revenues generated during a 

license renewal term, would directly benefit local, regional, and State economies over the short 

term. Local agencies investing tax generated revenues from the license renewal or one of the 

energy generation alternatives into infrastructure and other public services could enhance 

socioeconomic productivity over a longer-term. 

When compared with the no-action alternative, the short-term benefit of license renewal and the 

energy alternatives would be the production of electricity. Conversely, there would be no 

short-term electrical generation benefit derived from pursuing the no-action alternative. 
Conclusion 

NUREG-1437, Supplement 42 9-6 October 2010 

9.3.3 Irreversible and Irretrievable Commitments of Resources 

This section describes the irreversible and irretrievable commitments of resources described in 

this SEIS. An irreversible commitment of a resource refers to primary or secondary impacts 

which limit future options for a resource. An irretrievable commitment of resources refers to the 

use or consumption of a resource that is neither renewable nor recoverable for future use. 

With respect to license renewal, irreversible actions include the short-term commitment of land 

for the plant and corridors, which would limit other land use options. Also related to this issue is 

the irreversible loss of biological habitat and species, at least until the plant is decommissioned 

and the land is released. 

The license renewal alternative would result in an irretrievable commitment of cooling water 

which is diverted from other potential uses, including support of natural and biological 

resources. While surface water consumption represents a short-term loss of a renewable 

resource, lack of adequate groundwater recharge could constitute a relatively small longer-term 

irretrievable loss to the underlying aquifer. 

An irretrievable commitment of material resources includes materials that cannot be recovered 

or recycled, materials that are rendered radioactive and cannot be decontaminated, and 

materials consumed or reduced to unrecoverable forms of waste. 

One of the principle irreversible impacts is the generation of radioactive, and to a lesser extent, 

hazardous waste. The treatment, storage, and disposal of spent nuclear fuel, LLW, hazardous 

waste, and nonhazardous waste would require the long-term or permanent irretrievable 

commitment of land, as well as capital and personnel to manage and monitor the waste at 

storage, treatment, and disposal facilities. As an irreversible action, such waste might also have 

the potential to adversely affect the biosphere and other natural resources. In general, the 

commitment of capital and labor to provide long-term monitoring of this waste is an irretrievable 

commitment of socioeconomic resources. 

In comparison, one of the principle irreversible impacts of a fossil-fuel alternative involves 

release of hazardous air constituents into the biosphere which can have long-term adverse 

effects on human health and biological resources. Unlike the alternative of license renewal, a 

fossil-fuel plant would also release substantial amounts of CO2 and other GHGs. These GHGs 

might contribute to a global irretrievable degradation or loss of ecological and natural 

resources. 

The irreversible and irretrievable commitment of resources involved in constructing and 

operating any of the energy alternatives would generally be similar to, albeit, probably larger 

than those cited for the license renewal alternative. With respect to the energy alternatives, 

consumption of fossil fuels would be one of the irretrievable resources of principle concern. For 

the alternative of license renewal, the principle irretrievable resource commitment would be the 

consumption of uranium-235. 

The energy alternatives would also have the potential to result in an irretrievable loss of 

biological resources, water resources, and might adversely disrupt socioeconomic resources 

including historical and archaeological resources. 
Conclusion 

October 2010 9-7 NUREG-1437, Supplement 42 

9.4 RECOMMENDATIONS 

Based on: (1) the analysis and findings in the GEIS; (2) information provided in the 

environmental report submitted by FPL-DA; (3) consultation with Federal, State, and local 

agencies; (4) a review of pertinent documents and reports; and (5) consideration of public 

comments received during scoping, the recommendation of the Staff is that the NRC determine 

that the adverse environmental impacts of license renewal for DAEC are not great enough to 

deny the option of license renewal for energy-planning decision makers. 

9.5 REFERENCES 

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

The National Environmental Policy Act of 1969. Pub. L. 91-190, 42 U.S.C. 4321-4347, January 

1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 

97-258, § 4(b), September 13, 1982. 

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., 

Agencywide Documents Access and Management System (ADAMS) Accession Nos. 

ML040690705 and ML040690738. 

U.S. Nuclear Regulatory Commission (NRC). 1999a. 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). 1999b. Environmental Standard Review Plan: 

Standard Review Plans for Environmental Reviews for Nuclear Power Plants, NUREG-1555, 

October 1999. 

October 2010 10-1 NUREG-1437, Supplement 42 

10.0 LIST OF PREPARERS 

This supplemental environmental impact statement (SEIS) was prepared by members of the 

Office of Nuclear Reactor Regulation, with assistance from other NRC organizations and 

contract support from Argonne National Laboratory. 

Table 10-1. List of Preparers. Argonne National Laboratory provided contract support 

for preparing the SEIS. Information Systems Laboratories provided 

contract support in preparing the severe accident mitigation alternatives 

(SAMA) analysis, presented in Chapter 5 and Appendix F. 

Name Affiliation Function or Expertise 

Nuclear Regulatory Commission 

Charles Eccleston Nuclear Reactor Regulation Project Manager 

Dennis Beissel Nuclear Reactor Regulation Hydrology 

Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection 

Jennifer Davis Nuclear Reactor Regulation Historic and Archaeological 

Resources 

Ekaterina Lenning Nuclear Reactor Regulation Air Quality; Human Health 

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics; Land Use; 

Environmental Justice 

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation 

Alternatives 

Andrew Stuyvenburg Nuclear Reactor Regulation Alternatives (oversight) 

Allison Travers Nuclear Reactor Regulation Alternatives 

Dennis Logan 

Briana Balsam 

Nuclear Reactor Regulation 

Nuclear Reactor Regulation 

Aquatic/Terrestrial Ecology 

Aquatic/Terrestrial Ecology 

SEIS Contractor(a)

Ron Kolpa Argonne National Laboratory Air Quality/Meteorology 

John Quinn Argonne National Laboratory Hydrology 

Tim Allison Argonne National Laboratory Socioeconomics 

Dan O’Rourke Argonne National Laboratory Cultural Resources 

SAMA Contractor 

Bruce Mrowca Information Systems Laboratories Severe Accidents Mitigation 

Alternatives 

Robert Schmidt Information Systems Laboratories Severe Accidents Mitigation 

Alternatives 

(a) Argonne National Laboratory, U.S. Department of Energy

October 2010 11-1 NUREG-1437, Supplement 42 

11.0 INDEX 

accidents ..... ...xvii, 5-1, 5-2, 5-5, 8-41, 8-42, 

Appendix A -17, B-14, Appendix F 

aesthetic xvi, 2-41, 2-42, 4-14, 4-15, 8-12, 

8-22, 8-30, 8-40 

alternatives ....iii, xvii, xviii, 1-6, 5-3 - 5-7 8-1 

- 8-42, 9-2, 9-3, 9-4, 10-1, Appendix A, 

Appendix B 

archaeological resources .. ...xvi, 1-7, 1-8, 2-

47 - 2-50, 4-15, 4-18 - 4-20, 8-12, 8-13, 8-

22, 8-23, 8-31, 8-40, 8-41, B-13, 

Appendix D 

burnup ..................................................... 2-8 

chronic effects ..........xv, 1-4, 4-8, 4-13, 4-14 

Clean Air Act ...................... 2-22, 8-5, 8-25 

closed-cycle cooling ..... 4-110, 8-4, 8-27, B6, B-7 

Commission.... xiii, xiv, xvii, 2-1, 4-1, 4-12, 4-

14, 4-15, 4-21 

cultural resources ... ...3-12, 4-44, 8-12, 8-13, 

8-22, 8-31, 10-1, Appendix C 

decommissioning ... 7-1, 8-38 8-41Appendix 

demography 2-43 -2-47, 4-11, 8-11, 8-13, 8-

21 

design-basis accidents ..................... 5-1, 5-2 

discharges . ...xv, 2-8 2-12, 2-17, 2-19, 2-20, 

2-23 - 2-26, 2-27, 4-2 - 4-6, 4-11 - 4-12, 

4-30, 4-34, 8-4, 8-9, 8-19, 8-39, 8-44, B-1, 

B-3, B-4, B-11, Appendix C 

dose 2-9, 4-9, 4-10, 4-27, 5-5, 5-6, 

Appendix A, B-11, B-14, B-16, Appendix 

F 

Duane Arnold Energy Center XV, 1-1, 1-2, 2-

1, 2-3 - 2-17, 3-1 - 3-3 

dredging ..................................... Appendix C 

education ...... ...2-40, 4-14, 4-15, B-12, B-13 

electromagnetic fields... ...xv, xvi, 4-6, 4-8, 4-

18, 4-12 - 4-14, 4-34, B-9, B-12 

environmental justice... ...1-4, 4-15, 4-20 - 4-

26, 8-13, 8-14, 8-23, 8-24, 8-31, 8-32, 8-

40, 9-2, B-20 

EPA .....2-10 - 2-12, 2-16, 2-21, 2-22, 4-2, 4-

29, 4-33, 4-34, 8-2, 8-5, 8-7, 8-8, 8-10, 8-

14, 8-16 - 8-18, 8-24 - 8-26, 8-34, B-17, 

C-1, C-5 

GEIS xiv - xvi, xviii, 1-3 - 1-6, 2-43, 4-1 - 4-

19, 4-27 - 4-36, 5-1 - 5-3, 6-1, 6-2, 7-1, 8-

1, 8-2, 8-3, 8-9 - 8-12, 8-13, 8-14, 8-15, 8-

19 - 8-21, 8-23, 8-27 - 8-29, 8-34 - 8-37, 

B-14 

ground water ....xiv, xvii, 2-18, 2-23, 2-24, 4-

2 - 4-5, 4-9, 4-16, 4-26, 4-27, 4-30, 4-35, 

8-2, 8-5, 8-8, 8-9, 8-14, 8-16, 8-18, 8-24, , 

8-26, , 8-27, 8-38, 8-39, 8-41B-5, B-6, B7, C-1 

hazardous waste ... ....2-10 - 2-12, 8-36, 9-3, 

9-5, C-6 

high level waste ....... B-14, B-15, B-16, B-17 

impingement 4-6, 4-31, 8-9, 8-19, 8-27, B-3, 

B-5 

invasive species ........................... 4-31, 4-32 

mitigation xvi, xvii, 1-4 - 1-6, 4-1 - 4-34, 5-3 - 

5-7, 8-13, 8-23, 9-1 - 9-3 

mixed waste ................................. 8-41, B-18 

NEPA ...xiii, xiv, 1-1, 4-21, 5-1, 6-3, 8-41, 8-

42, 9-3, B-1, B-15, B-17 

no-action alternative ........ ....8-38, 8-41, 8-42 

nonattainment ....................... ..8-5, 8-10, B-9 

NPDES ...2-12, 2-24 - 2-26, 4-2, 4-11 - 4-13, 

B-2 

postulated accidents ....................... 5-1 - 5-3 

radon-222 ....................................... 4-9, B-14 

reactor ... ... 2-6 - 2-8, 5-1 - 5-3, 5-7, 8-12 8--

22, 8-30, 8-33, 8-39, B-6, B-14 

refurbishment .. ...xv, xvi, 2-10, 3-1, 3-2, 3-3, 

3, 4-10, 4-18, 4-20, 4-29, 4-34, B-1, B-3, 

B-5, B-9, B-10, B-11, B-12, B-13 

replacement power .................................. 5-5 

scoping.... ............... xvii, 1-3, 1-6, 4-1 - 4-27, 

Appendix A 

severe accidents (SAMA)....xxv, 5-3 - 5-7, 

10-1, Appendix A 

solid waste...2-9 - 2-12, 6-1, 6-2, 8-13, 8-36, 

8-37, Appendix B 

spent fuel . ...xxiv, 1-4, 2-6, 4-19, 6-1, 6-2, 8-

41, 8-42, B-14, B-15, B-17, B-18, B-19 

stormwater .................................. 2-23 - 2-26 

surface water .. ...xvi, xviii, 2-18, 2-23 - 2-27, 

3-2, 4-3 - 4-5, 4-9, 4-26, 4-27. 4-30, 4-32, 

4-35, 8-2, 8-5, 8-9, 8-16, 8-18, 8-24, 8-27, 
Index 

NUREG-1437, Supplement 42 11-2 October 2010 

8-38, 8-39, 8-42, 9-1, 9-4, 9-6, A-8, A-9, 

A-12, B-1, B-6, C-1 

taxes ................ 2-41, 2-42, 2-46 - 2-48, 4-17 

threatened and endangered species . ...2-16, 

2-29, 2-31 - 2-39, 4-5, 4-7, 4-8, B-7, C-1, 

C-5, D-1 

transmission lines and corridors 2-3, 2-13, 2-

16, 2-33, 2-36 - 2-39, 2-51, 4-7, 4-8, 4-12, 

4-13, 4-19, 4-20, 4-27, 4-31, 4-32, 4-33, 

4-34 

tritium .............. ...2-9, 2-22, 2-23, 4-25, 4-26 

U.S. Fish and Wildlife Service 2-31 - 2-35, 2-

39, 2-52, 4-7, 4-8 

uranium . ...2-6 - 2-8, 4-26, 4-32, 6-1, 6-2, 8-

10, 8-11, 8-20, 8-29 

Yucca ......................................... B-15 - B-14 
October 2010 12-1 NUREG-1437, Supplement 42 

12.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO 

WHOM COPIES OF THE SUPPLEMENTAL ENVIRONMENTAL IMPACT 

STATEMENT ARE SENT 

Name and Title Affiliation and Address 

Mr. M. S. Ross 

Managing Attorney 

Florida Power & Light Company 

P.O. Box 14000 

Juno Beach, FL 33408-0420 

Ms. Marjan Mashhadi 

Senior Attorney 

Florida Power & Light Company 

801 Pennsylvania Avenue, NW 

Suite 220 

Washington, DC 20004 

T. O. Jones 

Vice President, Nuclear Operations 

Mid-West Region 

Florida Power & Light Company 

P.O. Box 14000 

Juno Beach, FL 33408 

Steven R. Catron 

Manager, Regulatory Affairs 

Duane Arnold Energy Center 

3277 DAEC Road 

Palo, IA 52324 

Resident Inspector=s Office U.S. Nuclear Regulatory Commission 

Resident Inspector=s Office 

Rural Route #1 

Palo, IA 52324 

Mr. Mano Nazar 

Senior Vice President and Nuclear Chief 

Operating Officer 

Florida Power & Light Company 

P.O. Box 14000 

Juno Beach, FL 33408 

Mr. D. A. Curtland 

Plant Manager 

Duane Arnold Energy Center 

3277 DAEC Road 

Palo, IA 52324-9785 

Vice President, Engineering Support Florida Power & Light Company 

P.O. Box 14000 

Juno Beach, FL 33408 

Melanie Rasmusson 

Bureau of Radiological Health 

Iowa Department of Public Health 

Bureau of Radiological Health 

321 East 12th Street 

Lucas State Office Building, 5th Floor 

Des Moines, IA 50319-0075 
List of Agencies, Organizations, and Persons 

NUREG-1437, Supplement 41 12-2 October 2010 

Name and Title Affiliation and Address 

Chairman Linn County 

Board of Supervisors 

930 1st Street SW 

Cedar Rapids, IA 52404 

Peter Wells 

Acting Vice President, Nuclear Training and 

Performance Improvement 

Florida Power & Light Company 

P.O. Box 14000 

Juno Beach, FL 33408-0420 

Mark E. Warner 

Vice President, Nuclear Plant Support 

Florida Power & Light Company 

P.O. Box 14000 

Juno Beach, FL 33408-042 

George Thurman 

Principal Chief 

Sac and Fox Nation of Oklahoma 

Route 2 Box 246 

Stroud, OK 74079 

Fredia Perkins 

Chairperson 

Sac and Fox Nation of Missouri 

305 North Main Street 

Reserve, KS 66434 

Christie Modlin 

Chairperson 

Iowa Tribe of Oklahoma 

Route 1, Box 721 

Perkins, OK 74059 

Steve Cadue 

Chairman 

Kickapoo Tribe in Kansas 

P.O. Box 271 

Horton, KS 66439 

Steve Ortiz 

Chairman 

Prairie Band of Potawatomi Indians 

16281 Q Road 

Mayetta, KS 66509 

Joshua Weston 

President 

Flandreau Santee Sioux Tribe 

P.O. Box 283 

Flandreau, SD 57028 

Mr. Roger Trudell 

Chairman 

Santee Sioux Nation 

108 Spirit Lake Avenue, West 

Niobrara, SD 68760-7219 

John Blackhawk 

Chairman 

Winnebago Tribe of Nebraska 

100 Bluff Street 

P.O. Box 687 

Winnebago, NE 68071 
 List of Agencies, Organizations, and Persons 

October 2010 12-3 NUREG-1437, Supplement 42 

Name and Title Affiliation and Address 

Ronald Johnson 

President 

Prairie Island Indian Community 

5636 Sturgeon Lake Road 

Welch, MN 55089 

Stanley R. Crooks 

Chairman 

Shakopee Mdewakanton Sioux Community of 

Minnesota 

2330 Sioux Trail NW 

Prior Lake, MN 55372-9077 

Kevin Jensvold 

Chairman 

Upper Sioux Community of Minnesota 

P.O. Box 147 

Granite Falls, MN 56241-0147 

Wilfred Cleveland 

President 

Ho-Chunk Nation 

W9814 Airport Road 

P.O. Box 667 

Black River Falls, WI 54615

Adrian Pushetonequa 

Chairman 

The Sac and Fox Tribe of the Mississippi: 

349 Meskwaki Road 

Tama, IA 52339 

Lori Nelson 

Acting Chair 

Lower Sioux Indian Community of Minnesota 

39527 Res Highway 1 

P.O. Box 308 

Morton, MN 56270 

Amen Sheriden 

Chairman 

Omaha Tribal Council 

P.O. Box 368 

Macy, NE 68039 

Marlon E. Frye 

Chairman 

Kickapoo Tribe of Oklahoma 

P.O. Box 70 

McCloud, OK 74851 

John Shotton Otoe-Missouria Tribe of Indians 

8151 Highway 177 

Red Rock, OK 74651 

Leon Campbell 

Chairman 

Iowa Tribe of Kansas and Nebraska 

3345 Thrasher Road 

White Cloud, KS 66094 

Wayne Gieselman 

Administrator 

Iowa Department of Natural Resources 

Environmental Services Division 

502 East 9th Street 

Des Moines, IA 50319. 
List of Agencies, Organizations, and Persons 

NUREG-1437, Supplement 41 12-4 October 2010 

Name and Title Affiliation and Address 

Richard Nelson 

Field Supervisor 

U.S. Fish and Wildlife Service 

Rock Island Field Office 

1511 47th Ave. 

Moline, Illinois 61265 

Robert F. Stewart 

Regional Environmental Officer 

United States Department of the Interior 

Office of the Secretary 

Office of Environmental Policy and 

Compliance 

Denver Federal Center, Building 67, Room 

118 

Post Office Box 25007 (D-108) 

Denver, Colorado 80225-0007 

Charlene Dwin Vaughn 

Assistant Director 

Federal Permitting, Licensing, and Assistance 

Section 

Advisory Council on Historic Preservation 

Old Post Office Building 

1100 Pennsylvania Ave, NW, Suite 803 

Washington, DC 20004 

John Doershuck 

State Archaeologist 

Office of the State Archaeologist 

700 South Clinton Street Building 

University of Iowa 

Iowa City, IA 52242-1030 

Jerome Thompson 

Interim State Historic Preservation Officer 

State Historical Society of Iowa 

600 East Locust Street 

Des Moines, IA 50319 

Doug Jones State of Iowa Historical Building (Des Moines)

600 East Locust 

Des Moines, Iowa, 50319 

515-281-5111 

Dusky Terry 

Citizen 

Central Iowa Power Cooperative 

2600 Grand Avenue, Suite 410 

Des Moines, IA 50312 

Bennett Brown 

Citizen 

1025 Friendly Ave 

Iowa City, IA 52240 

Amir H. Moazzez 3650 Joseph Siewick, Dr. #309 

Fairfax VA 22033 
 List of Agencies, Organizations, and Persons 

October 2010 12-5 NUREG-1437, Supplement 42 

Name and Title Affiliation and Address 

Hiawatha Public Library Hiawatha Public Library 

150 W. William St., 

Hiawatha IA 

Mr. Joseph Cothern 

Environmental Review Coordinator 

Environmental Services Division 

USEPA, Region 7 

901 North 5th Street 

Kansas City, KS 66101 

Northwest University Northwest University

Northwestern University Library 

1970 Campus Drive 

Evanston, IL 60208-2300 

Dr. Robert Schultes 1000 Prairie Drive NE 

Cedar Rapids, Iowa 52402 

W. L. Taylor, Legal Chair and 

P. M Taylor, Energy Committee Chair 

Sierra Club 

Iowa Chapter Headquarters 

3839 Merle Hay Road 

Suite 280 

Des Moines, IA 50310 

APPENDIX A. 

COMMENTS RECEIVED ON THE DUANE ARNOLD ENERGY 

CENTER ENVIRONMENTAL REVIEW 

October 2010 A-1 NUREG-1437, Supplement 42 

A. COMMENTS RECEIVED ON THE DUANE ARNOLD ENERGY 

CENTER ENVIRONMENTAL REVIEW 

A.1. Comments Received During the Scoping Process 

The Duane Arnold Energy Center (DAEC) scoping process began on March 24, 2009, with the 

publication of the U.S. Nuclear Regulatory Commission’s (NRC) Notice of Intent to conduct 

scoping in the Federal Register (74 FR 12399). The scoping process included two public 

meetings held at Hiawatha City Hall, Iowa on April 22, 2009. Approximately 30 people attended 

the meetings. After the NRC’s prepared statements pertaining to the license renewal process, 

the meetings were open for public comments. Oral statements were recorded and transcribed 

by a certified court reporter. Transcripts of the meeting were attached to the Scoping Summary 

Report dated August 7, 2009 (NRC, 2009). A total of two attendees registered to speak at the 

afternoon meeting session. When called upon, one of these registered speakers indicated that 

he had no comments. No one provided comments at the evening session. No other public 

scoping comments were received either through the mail or email. 

The commenter was assigned a unique identifier. Table A-1 identifies the individual who 

registered to provide comments and the ID associated with the commenter’s set of comments. 

To maintain consistency with the Scoping Summary Report, the unique identifier used in that 

report is retained in this appendix. 

Specific comments were categorized and consolidated by topic. Comments can fall into one of 

the following general categories: 

Table A-1. Comments on the Scope of the Environmental Review. The comment is 

identified along with the affiliation and how the comment was submitted.

Commenter ID Commenter Affiliation Comment Source ADAMS Accession 

Number 

DAEC-1 Mr. Bennett 

Brown Member of the public Afternoon Scoping Meeting Session ML091910273 

Comment DAEC-1 has been organized and presented in terms of two different issues: 

● Alternatives 

● Safety and Postulated Accidents 

NRC responses are provided for each of these issues. 
Appendix A 

NUREG-1437, Supplement 42 A-2 October 2010 

A1.1 Mr. Brown’s Comments Concerning Alternatives 

Comment DAEC-1-1: The Department of Natural Resources and the state of Iowa assessed 

the state’s wind resource and concluded that the state of Iowa [is] developing only class 4 

jacobs sites. These are currently developable at two and-a-half cents a kilowatt hour, would 

produce six times as much electricity as needed by the state of Iowa. 

The Midwest Independent Systems Operators as well as other utility grid operators have studied 

how much wind penetration the grid could sustain given the variability of the wind and 

concluded that we could provide 15 to 25 percent of our electricity from wind without any 

alterations in the existing grid. So the percentage of electricity produced in the state of Iowa 

from Duane Arnold could easily be replaced by wind turbines with existing technology and 

existing market support. 

Response: This comment is related to the environmental impacts of alternatives to license 

renewal of the DAEC. The impacts of a range of reasonable alternatives are presented in 

Chapter 8 of this supplemental environmental impact statement (SEIS). In response to this 

comment, the NRC staff has evaluated a “combination alternative.” The combination alternative 

includes a portion of the combined-cycle gas-fired capacity identified in Section 8.2, as well as a 

conservation capacity component, and a wind power component. 

Comment DAEC-1-2: The second thing that I’d like to see that the SEIS addresses is the 

effect on employment decommissioning. As I see it, this is not a question of whether to extend 

the life of the plant by 20 years but rather a question as to whether to decommission it in 2014 

or 2034. And so the question is when would we rather have the jobs provided necessary to 

decommission this plant and construct a renewable source, or at least some other source of 

electricity whether that’s a new nuclear plant or a new coal plant or wind plants. And the 

Congress requires that the operators of this nuclear plant provide $359,000,000 in a trust fund 

by 2014. 

That money spent beginning in 2014 to provide job decommissioning in this plant would be a 

boon to the local economy and the 2.4 billion, and there that’s really a number off the top of my 

head there just saying, well, 800 megawatts times three per wind because of the name plate 

issue, I don’t know how familiar you are with wind, but an 800 megawatt nuclear plant takes 

2400 megawatts of wind to replace it. So that’s roughly $2.4 billion in construction of wind 

turbines and the associated jobs that come with that construction on top of some 300 full time 

jobs maintaining that wind energy. That would be a significant boon to the state of Iowa and I 

would encourage the NRC to look at the economic impact on the state of replacing this nuclear 

plant with wind as distributed around the state. 

Response: The environmental and socioeconomic impacts of decommissioning have been 

reviewed in Chapter 7 of the SEIS. Section 8.5 of the SEIS also examines environmental and 

socioeconomic effects that would occur if NRC takes no action to renew the DAEC operating 

license. Consistent with this comment, the NRC staff has also evaluated a “combination 

alternative.” This combination alternative includes a portion of the combined-cycle gas-fired 

capacity identified in Section 8.2 of the SEIS, as well as a conservation capacity component, 

and a wind power component. Section 8.3.6.2 of the SEIS discusses socioeconomic impacts, 

including those associated with employment and construction of a wind farm. 
Appendix A 

October 2010 A-3 NUREG-1437, Supplement 42 

A1.2 Mr. Brown’s Comments Concerning Safety and Postulated Accidents 

Comment DAEC-1-3: The third point that I’d like to make has to do with the environmental 

impact of a severe accident. And I understand that you also have a safety review portion of the 

process and I also understand that the 9th Circuit Court has ruled that your SEIS must include 

an analysis of accidents in the jurisdiction of the 9th Circuit Court. So in lack of ruling from this 

Circuit Court, I believe that ruling has precedence and I would ask that you include accidents 

and the impacts of accidents in the SEIS. 

Specifically on this point I would refer to the Sandia Lab Study commissioned by the NRC in 

1982 which calculated the impacts of a severe accident with core damage estimating 3,000 

peak fatalities immediately after the accident within a 25 mile radius, and 12,000 radiation 

injuries in the early aftermath of an accident within a 35 mile radius. And calculate the plant 

operators, calculate at any given time if all equipment is operating correctly, that the core 

damage frequency is one in 3,000,000 per reactor year. But sometimes parts are out of 

operation and the possibility that there’s a severe accident under their calculations go up. 

I would ask for this SEIS that the NRC address the likelihood of an accident taking into account 

more than the plant operators include in their calculation of the CDF, particularly their 

probabilistic risk assessment assumes that all parts operate as though they were new and have 

not been subjected to problems of radiation exposure, heat exposure, fluctuation of 

temperature, pressure exposure and embrittlement. 

In this regard, I’d specifically point out that the CDF excludes vessel failure. This is a Mark 1 

reactor. It’s one of 18 Mark 1 reactors in the country. A study published by the Union of 

Concerned Scientists in 1995 looked at the vessel internals aging in the 18 Mark 1 reactors in 

the country as a result of discoveries of major fissures and cracks in Mark 1 core shrouds and 

found that at about 20 years of operation the exposure to radiation and heat fluctuation caused 

moderate or extensive cracking in seven out of the 18 Mark 1 reactors. 

Duane Arnold at that time had no cracking evident and I would encourage the NRC to consider 

the possibility that a 40 year license that was initially granted to this reactor has allowed the 

investors to recoup their losses and that we are lucky today that the aging of the parts has not 

resulted in an accident. But a 20 year extension of the license represents too great a risk to this 

site specific plan for an accident. 

If the core shroud detailed in the UCS report is one of just 21 vessel internal components 

subject not only to the cracking that is described in that report, but also to erosion, 

embrittlement, fatigue, creep, as well as stress corrosion cracking. So if these vessel internal 

parts were to prevent an insertion of the control rods, then the consequences of an accident 

could be quite severe. 

In addition, the secondary containment which is meant to control the impact and mitigate the 

impact of such an accident in this particular reactor, was discovered to be faulty in the early 

days of operation of this reactor and the 17 other reactors like it in the country. 

In fact, in 1986 Harold Denton, at that time a Chief Safety Officer with the NRC, in leading a 

meeting of Mark 1 operators declared that the taurus, as it is known, a million gallon tank of 

water to suppress heat in the event that the reactor was unable to be shut down and no where 

for the heat to go because of a loss of connectivity to the grid for instance, that there was a 90 

percent probability that that taurus would fail at a meeting of Mark 1 operators. 
Appendix A 

NUREG-1437, Supplement 42 A-4 October 2010 

And so as a result of that assessment, Mark 1 operators were instructed to install a bypass 

system that instead of trying to contain the pressure from the reactor using secondary 

containment, would simply bypass secondary containment and vent the taurus directly to the 

atmosphere through a butterfly valve operated in the control room. And Duane Arnold officials 

here today verify that, in fact, that is the situation at Duane Arnold, that it’s not different than the 

other 17 Mark 1’s. 

And I think that I can understand why you would let a plant live out its 40 year operating license 

knowing that it had a design deficiency off by a factor of 10 in the size of the secondary 

containment in order to allow investors to recoup their investment. But to extend the plant’s life 

for another 20 years when a viable alternative exists that would be a boon to the state’s 

economy, I think is something that should be viewed with skepticism. 

Finally, I think that the NRC should look at the history of scrams. Every scram at this reactor 

significantly ages the components. It subjects the components to significant changes in 

temperature, just like when you take a hot glass and submerge it suddenly in cold water. It can 

shatter parts inside a reactor every time you scram the reactor or suddenly subject it from one 

pressure extreme to another, from one temperature extreme to another and this significantly 

ages parts. 

If the reactor, for instance, had in the non-radiation side, had a metal part break off at a filet 

weld simply because it had been cycled between hot and cold, and that metal part found its way 

through the system, scored open a number of tubes. Finally, the problem was turned up 

because water leaked first into one part and then overflowed into another part of the plant, and it 

was only once the plant was shut down and people investigated that they found tubes slashed 

open and eventually found the metal part that worked its way loose. That sort of risk is simply 

unnecessary and there’s a viable alternative to the nuclear plant’s continued operation. 

The final point that I’d like to make concerning the reactor itself is this plant’s specific risk to a 

terrorist attack. The plant is in proximity to the Rockwell Collins plant that used to be in the 

Soviet Union’s top three list of targets because of its role in our nation’s nuclear arsenal, missile 

guidance and intelligence. That means that both an attack on Rockwell Collins would have an 

impact on the plant, on its safety, on its ability to evacuate and so on. 

It also means that there could be an indirect threat to the plant because a terrorist attack might 

find the plant a useful target in order to move military protection away from Rockwell Collins or 

the further strategic air command in Omaha in order to free up the vulnerability of SEC. So the 

specific location of this plant represents a hazard that needs to be looked at from the 

perspective of a terrorist attack. 

And in addition, the Mark 1 design has a spent fuel pool that’s on top of a building that is 

essentially unprotected, that various studies have concluded that a piece of weaponry that can 

be moved around in the trunk of a car and launched from somebody’s shoulder, a howitzer, 

could penetrate that building and create a fire in the spent fuel pool. In addition, that spent fuel 

pool would be committed to use for five years beyond decommissioning because if we were to 

decommission the plant even today, then we would need to store the spent fuel for a minimum 

of five years on that local site. 

So we’re looking at a terrorist threat, a target, an attractive target for five years beyond 

decommission and I think it needs to be considered whether in this day and age it’s really 

necessary to continue maintaining such an attractive target. 
Appendix A 

October 2010 A-5 NUREG-1437, Supplement 42 

Response: As part of the license renewal environmental review, the NRC staff evaluates the 

environmental impacts of postulated accidents. This evaluation is documented in Chapter 5 of 

this DSEIS. This comment raises concerns regarding several different aspects of 

consequences from such potential accidents. 

First, with respect to a ruling from the Ninth Circuit Court of Appeals stating that the issue of 

terrorism must be considered in NEPA documents. The Commission respectfully disagreed 

with the Ninth Circuit’s view, but stated that it will follow that ruling in the Ninth Circuit, indicating 

its belief that a different outcome might be reached by other Courts of Appeals (Oyster Creek, 

CLI-07-8, 65 NRC at 128). The DAEC is not located within the jurisdiction of the Ninth Circuit 

and therefore this DSEIS is not subject to the court’s finding. However, Section 5.2 of this 

DSEIS does provide a discussion regarding the GEIS’s consideration of severe accidents from 

phenomena such as sabotage, and its conclusion that the core damage and radiological release 

from such acts would be no worse than the damage and release expected from internally 

initiated events. 

Further, in a recent case of The State of New York v. NRC, two states filed rulemaking petitions 

asking NRC to reverse its GEIS conclusion, which found that spent fuel pools located at nuclear 

reactors do not create a significant environmental impact--the GEIS classifies on-site storage of 

spent fuel in pools as a category I issues that causes a small impact. The risks posed by 

storing nuclear fuel in such pools, including the risk of fire, have been considered in various 

studies. Some of these studies (including those conducted since September 2001) have also 

considered the risk of fire precipitated by a terrorist attack and have classified that risk as low. 

In a ruling in favor of the NRC, the Second Circuit Court of Appeals concluded that NRC’s 

decision denying rulemaking petitions was reasoned.1

Secondly, the commenter raised an issue concerning the “Sandia Lab Study” (Sandia Siting 

Study). The 1982 Sandia Siting Study (also referred to as the CRAC-II report) attempted to 

estimate source terms (i.e., magnitude, timing, and characteristics of the radioactive material 

released to the environment from a severe accident) for a severe nuclear reactor accident. A 

later study, NUREG-0773, concluded that the source terms used in Sandia Siting Study were 

based on “known deficiencies which would tend to give overestimates of the magnitude of the 

releases” (NRC, 1982). Another study, NUREG-1150, used a probabilistic risk assessment to 

improve upon the Sandia Siting Study (NRC, 1991). The NUREG-1150 study confirmed that 

the Sandia Siting Study had produced invalid results because it looked at the effects of very 

unlikely severe accidents. 

The 1996 GEIS used information from 28 plant-specific EISs, where the impacts from severe 

accidents were analyzed in their plant-specific EISs to project the environmental impact from all 

U.S. plants (see Table 5.5, NRC 1996). As stated in Section 5.3.3.1 of the 1996 GEIS, the 

source terms used in assessing these severe accidents were generally based on those 

documented in the NUREG-0773 study (NRC, 1982). Since completion of NUREG-0773 study, 

additional information on source terms has been developed through experimental and analytical 

programs. The comparison of the new source term information to that used in the 1996 GEIS 

impact projection shows the amount of released radioactive material in a postulated severe 

accident to be less than that estimated in the 1996 GEIS. Thus, the environmental impacts 

used as the basis for the 1996 GEIS are even more conservative than an estimate using more 

recent source term information. In addition, a substantial effort is also ongoing to re-quantify 

 

1

 The State of New York v. NRC, United States Court of Appeals for the Second Circuit, Docket Nos. 

08-3903-ag (L), 08-4833-ag (con), 08-5571-ag (con). Decided: December 21, 2009. 
Appendix A 

NUREG-1437, Supplement 42 A-6 October 2010 

realistic severe accident source terms under the state-of-the-art reactor consequence analysis 

(SOARCA) project. Preliminary results indicate that source terms, timing, and magnitude may 

be significantly later and lower than quantified in previous studies, including the 1996 GEIS. 

Thirdly, the commenter asked that NRC address the likelihood of an accident, taking into 

account more than the current assumptions used for calculating CDF. Specifically, the 

commenter raised various concerns about systems and components including those identified in 

a 1995 Union of Concerned Scientists report. As stated above, with respect to the 

environmental impacts associated with all postulated accidents, Chapter 5 of this DSEIS 

provides a discussion of the NRC staff’s evaluation. With respect to the safety aspect of such 

systems and components being able to operate for another 20 years, the NRC staff makes that 

determination as part of its license renewal safety review, which focuses on the programs and 

processes that are designed to assure adequate protection of the public health and safety is 

maintained during the 20-year license renewal period through management of aging 

components. As part of the license renewal safety review, the applicant will be required to 

demonstrate that the effects of aging will be adequately managed. 

Finally, the commenter also raised various concerns about systems and components that are 

related to the safe day-to-day operation of the plant, such as scram history and the secondary 

containment’s ability to mitigate impacts of an accident involving a Mark 1 reactor. Although not 

within the scope of the license renewal review, which focuses on aging management, these 

issues are addressed as part of the NRC’s ongoing oversight role, which includes, among other 

things, rigorous inspections, performance monitoring, and enforcement capability to ensure safe 

operation of commercial reactors. 

A.1.3 References 

74 FR 12399. U.S. Nuclear Regulatory Commission, Washington, D.C, “FPL Energy Duane 

Arnold, LLC; Notice of Intent to Prepare an Environmental Impact Statement and Conduct 

Scoping Process.” Federal Register: Vol. 74, No. 55, pp. 12399–12401. March 24, 2009. 

U.S. Nuclear Regulatory Commission (NRC). 1982. The Development of Severe Reactor 

Accident Source Terms: 1957-1981, NUREG-0773, November 1982. 

U.S. Nuclear Regulatory Commission (NRC). 1991. Severe Accident Risks: An Assessment for 

Five U.S. Nuclear Power Plants, NUREG-1150. 

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. 

Agencywide Documents Access and Management System (ADAMS) Accession Nos. 

ML040690705 and ML040690738. 

U.S. Nuclear Regulatory Commission (NRC). 2009. “Issuance of the Environmental Scoping 

Summary Report, For the Staff’s Review of the License Renewal Application for Duane Arnold 

Energy Center,” ADAMS Accession No. ML092030185. 

Sandia National Laboratory. 1982. Sandia Siting Study (also referred to as the CRAC-II 

report), NUREG/CR-2239. 
Appendix A 

October 2010 A-7 NUREG-1437, Supplement 42 

A.2. COMMENTS RECEIVED ON THE DRAFT SUPPLEMENTAL ENVIRONMENTAL 

IMPACT STATEMENT 

The staff transmitted the Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants Supplement 42 Regarding Duane Arnold Energy Center, Draft Report for 

Comment [NUREG-1437, Supplement 42, referred to as the draft supplemental environmental 

impact statement (SEIS)] to Federal, State, and 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 NRC’s Public Electronic Reading Room, 

on its license renewal website, and at the Hiawatha Public Library in Hiawatha, 

Iowa. 

● sent copies of the draft SEIS to the applicant, members of the public who 

requested copies, and certain Federal, State, and local agencies 

● published a notice of availability of the draft SEIS in the Federal Register

● announced and held two public meetings on March 31, 2010 at the Hiawatha 

City Hall, Hiawatha, Iowa, to present the results of the environmental review and 

answer questions on the license renewal process 

● placed newspaper ads and issued press releases announcing the issuance of 

the draft SEIS, the public meetings, and instructions on how to comment on the 

draft SEIS 

● established an e-mail address to receive comments on the draft SEIS 

electronically 

During the draft SEIS comment period, the staff received one comment from an environmental 

organization and one e-mail from a member of the public. Comments were also received from 

the U.S. Environmental Protection Agency and NextEra Energy Duane Arnold, LLC. No 

comments were received during the two public meetings on March 21, 2010. A cross-reference 

of the Commenter ID, author of the comment, their affiliation, the comment source, and the 

ADAMS accession number are provided in Table A-2. 

Table A-2. Comments on the Draft SEIS

Commenter ID Commenter Affiliation Comment Source ADAMS Accession 

Number 

DAEC-2 Dr. Schultes Member of the public Email ML101120843 

DAEC-3 W. L. Taylor, 

P. Taylor 

Sierra Club 

Sierra Club Letter ML102560509 

DAEC-4 R. Hammerschmit EPA Letter ML101120600 

DAEC-5 C.R. Costanzo DAEC, Vice President Letter ML1011100550 

DAEC-6 J. Doershuk State Archaeologist 

for Iowa Email ML102560484 
Appendix A 

NUREG-1437, Supplement 42 A-8 October 2010 

There was no new and significant information provided on Category 1 issues, and no 

information that required further evaluation of Category 2 issues. Therefore, the conclusions in 

the GEIS and draft SEIS remained valid and bounding, and no further evaluation was 

performed. Where the comment or question resulted in a change in the text of the draft SEIS, 

the corresponding response refers the reader to the appropriate section of this SEIS where the 

change was made. Revisions to text in the draft SEIS are designated by vertical lines beside 

the text in this final SEIS. 

DAEC-2: Public Comment Received from Dr. Schultes on the Draft Supplemental 

Environmental Impact Statement 
Appendix A 

October 2010 A-9 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-10 October 2010 

DAEC-2-1: Response to Dr. Schultes Comments 

The letter by Dr. Schultes provided background comments concerning human health studies, 

uranium mining impacts, health effects from routine releases, and releases of low-level 

radioactive waste. His letter asks the following four questions: 

 (1) How can DAEC prove that increases in the radiation exposure in the Cedar Rapids area 

has [not] occurred and will [not] continue under the new proposed license? 

(2) How can DAEC assure us that there will be no increase in radiation beyond background 

levels in the Cedar Rapids area? 

(3) In connection with the environmental monitoring of DAEC, why is the effect of the 

nuclear power plant on milk no longer monitored? 

(4) How can the DAEC assure us that there will be no waste contaminating our air, water, 

land and living space? 

The NRC staff has taken his comments into consideration in finalizing the SEIS and offers the 

following information for consideration. 

The NRC’s primary mission is to protect the public health and safety and the environment from 

the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC’s 

regulatory limits for radiological protection are set to protect workers and the public from the 

harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. The 

limits are based on the recommendations of standards-setting organizations. Radiation 

standards reflect extensive scientific study by national and international organizations. The 

NRC actively participates and monitors the work of these organizations to keep current on the 

latest trends in radiation protection. If the NRC determines that there is a need to revise its 

radiation protection regulations, it will initiate new rules. The models recognized by the NRC for 

use by nuclear power reactors to calculate dose, incorporate conservative assumptions that 

account for differences in gender and age to ensure that workers and members of the public are 

adequately protected from radiation. 

Although radiation may cause cancers at high doses, currently there are no reputable 

scientifically conclusive data that unequivocally establish the occurrence of cancer following 

exposure to low doses, below about 10 rem (0.1 Sv). However, radiation protection experts 

conservatively assume that any amount of radiation may pose some risk of causing cancer or a 

severe hereditary effect and that the risk is higher for larger radiation exposures. Therefore, a 

linear, no-threshold dose response relationship is used to describe the relationship between 

radiation dose and detriments such as cancer induction; simply stated, any increase in dose, no 

matter how small, is assumed to result in an incremental increase in health risk. This theory is 

accepted by the NRC as a conservative model for estimating health risks from radiation 

exposure, recognizing that the model probably over-estimates those risks. Based on this 

theory, the NRC conservatively establishes limits for radioactive effluents and radiation 

exposures for workers and members of the public. While the public dose limit is 100 mrem (1 

mSv) for all facilities licensed by the NRC (10 CFR Part 20), the NRC has imposed additional 

constraints on nuclear power reactors. Each nuclear power reactor, including Duane Arnold, 

has license conditions that limit the total annual whole body dose to a member of the public 

outside the facility to 25 mrem (0.25 mSv). In addition, there are license conditions to limit the 

dose to a member of the public from radioactive material in gaseous effluents to an annual dose 
Appendix A 

October 2010 A-11 NUREG-1437, Supplement 42 

of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem (0.03 

mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ. 

The amount of radioactive material released from nuclear power facilities is well measured, well 

monitored, and known to be very small. The doses of radiation that are received by members of 

the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few 

millirem) that resulting cancers attributed to the radiation have not been observed and would not 

be expected. To put this in perspective, each person in this country receives a total annual 

dose of about 300 millirems (3 mSv) from natural sources of radiation (i.e., radon, 200 mrem; 

cosmic rays, 27 mrem; terrestrial [soil and rocks], 28 mrem; and radiation within our body, 39 

mrem) and about 63 mrem (0.63 mSv) from man-made sources (i.e., medical x-rays, 39 mrem; 

nuclear medicine, 14 mrem; consumer products, 10 mrem; occupational, 0.9 mrem; nuclear fuel 

cycle, <1 mrem; and fallout, <1 mrem). 

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have 

been conducted, there are no studies, accepted by the scientific community, that show a 

correlation between radiation dose from nuclear power facilities and cancer incidence in the 

general public. The following is a listing of a few studies recognized by the NRC staff. 

● In 1990, at the request of Congress, the National Cancer Institute conducted a 

study of cancer mortality rates around 52 nuclear power plants and 10 other 

nuclear facilities. The study covered the period from 1950 to 1984, and 

evaluated the change in mortality rates before and during facility operations. 

The study concluded there was no evidence that nuclear facilities may be linked 

causally with excess deaths from leukemia or from other cancers in populations 

living nearby. 

● In June 2000, investigators from the University of Pittsburgh found no link 

between radiation released during the 1979 accident at Three Mile Island power 

plant and cancer deaths among nearby residents. Their study followed 32,000 

people who lived within five miles of the plant at the time of the accident. 

● The Connecticut Academy of Sciences and Engineering, in January 2001, 

issued a report on a study around the Haddam Neck nuclear power plant in 

Connecticut and concluded radiation emissions were so low as to be negligible 

and found no meaningful associations to the cancers studied. 

● The American Cancer Society in 2000 concluded that although reports about 

cancer clusters in some communities have raised public concern, studies show 

that clusters do not occur more often near nuclear plants than they do by 

chance elsewhere in the population. Likewise, there is no evidence that links 

strontium-90 with increases in breast cancer, prostate cancer, or childhood 

cancer rates. Radiation emissions from nuclear power plants are closely 

controlled and involve negligible levels of exposure for nearby communities. 

● Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed 

claims that there are striking increases in cancer rates in southeastern Florida 

counties caused by increased radiation exposures from nuclear power plants. 

However, using the same data to reconstruct the calculations, on which the 

claims were based, Florida officials were not able to identify unusually high rates 
Appendix A 

NUREG-1437, Supplement 42 A-12 October 2010 

of cancers in these counties compared with the rest of the state of Florida and 

the nation. 

● In 2000, the Illinois Public Health Department compared childhood cancer 

statistics for counties with nuclear power plants to similar counties without 

nuclear plants and found no statistically significant difference. 

Recently, the Nuclear Regulatory Commission has asked the National Academy of Sciences 

(NAS) to perform a state-of-the-art study on cancer risk for populations surrounding nuclear 

power facilities. The NAS study will update the 1990 U.S. National Institutes of Health - 

National Cancer Institute (NCI) report, “Cancer in Populations Living near Nuclear Facilities.” 

The study is scheduled to begin in the summer 2010 and is expected to be completed within 

three years. 

To ensure that U.S. nuclear power plants are operated safely, the NRC licenses the nuclear 

power plants to operate, licenses the plant operators, and establishes license conditions for the 

safe operation of each plant. The NRC provides continuous oversight of plants through its 

Reactor Oversight Process (ROP) to verify that they are being operated in accordance with 

NRC regulations. The NRC has full authority to take whatever action is necessary to protect 

public health and safety, and the environment and may demand immediate licensee actions, up 

to and including a plant shutdown. 

As part of the license renewal process, the NRC staff reviewed the radiological environmental 

monitoring program at Duane Arnold. Duane Arnold conducts a radiological environmental 

monitoring program (REMP) in which radiological impacts to the environment and the public 

around the Duane Arnold site are monitored, documented, and compared to NRC standards. 

Duane Arnold summarizes the results of their REMP in an annual report. The reports are 

publically available on the NRC’s public website. 

The REMP samples environmental media in the environs around the site to analyze and 

measure the radioactivity levels that may be present. The media samples are representative of 

the radiation exposure pathways to the public from plant radioactive effluents. The REMP 

measures direct radiation, and the airborne and waterborne pathways for radioactivity in the 

vicinity of the Duane Arnold site. The REMP includes sampling of milk from local farms. The 

milk samples are analyzed for iodine-131 and gamma-emitting isotopes. In addition, the REMP 

also measures background radiation (i.e., cosmic sources, naturally occurring radioactive 

material, including radon and global fallout). 

Regarding the disposal of low level radioactive wastes (LLW), the Commission has performed a 

comprehensive assessment of the impacts associated with the disposal of LLW from nuclear 

power reactors. The evaluation is contained in NUREG-1437, “Generic Environmental Impact 

Statement for License Renewal of Nuclear Power Reactors” (GEIS). The following is a 

summary of the Commission’s findings: 

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. 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, 
Appendix A 

October 2010 A-13 NUREG-1437, Supplement 42 

the Commission concludes that there is reasonable assurance that sufficient 

low-level waste disposal capacity will be made available when needed for 

facilities to be decommissioned consistent with NRC decommissioning 

requirements. 

As part of the license renewal process, the NRC staff reviewed the radiological effluent release 

program, low-level radioactive waste program, and the radiological environmental monitoring 

program at Duane Arnold and found them to meet all applicable NRC requirements. The Staff’s 

radiological human health evaluation of Duane Arnold is provided in Chapter 4 of the SEIS. 

The NRC has not identified any new and significant information that would warrant a change in 

the SEIS. 
Appendix A 

NUREG-1437, Supplement 42 A-14 October 2010 

DAEC-3: Comments Received from the Sierra Club on the Draft Supplemental 

Environmental Impact Statement 
Appendix A 

October 2010 A-15 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-16 October 2010 
Appendix A 

October 2010 A-17 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-18 October 2010 
Appendix A 

October 2010 A-19 NUREG-1437, Supplement 42 

DAEC-3-1: Response to the Sierra Club Comment Concerning Purpose and Need 

This comment raises a concern similar to that of the U.S. EPA (described DAEC4-1) regarding 

purpose and need in the SEIS. As previously noted in response to the EPA’s comment, the 

definition of purpose and need in the 1996 GEIS reflects the Commission’s recognition that the 

NRC has no role in the energy planning decisions that may reside with authorities such as 

states or other federal agencies and utility officials. As such, the NRC will neither perform 

analyses of the need for power nor draw any conclusions about the need for generating 

capacity in a license renewal review. The purpose of renewing an operating license is to 

consider the availability of the nuclear plant option in meeting energy requirements beyond the 

term of the plant’s current license. 

The operation of a nuclear power plant beyond its initial license term involves separate 

regulatory actions, one taken by the utility and the NRC, and the other taken by the utility and 

other energy planning decision-makers. The NRC’s role is to determine whether it is 

reasonable to renew the operating license and allow such decision-makers the option of 

considering a currently operating nuclear power plant as an alternative for meeting future 

energy needs. The focus of the analysis is whether the environmental impacts anticipated for 

continued operation during the term of the renewed license reasonably compare with the 

impacts of alternatives considered for meeting generating requirements. Given the 

uncertainties involved and the lack of control that the NRC has in the choice of energy 

alternatives for the future, the Commission believes that it is reasonable to exercise its NEPA 

authority to reject license renewal applications only if the analysis demonstrates that the 

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

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

The objectives of the utility and other appropriate energy planning decision-makers may 

ultimately be the determining factors in whether a nuclear power plant will continue to operate. 

However, this decision-making process will not affect the scope or rigor of NRC’s analyses, 

including the consideration of the environmental impacts relevant to the license renewal 

decision and associated alternatives. For adduional information, the reader is referred to the 

NRC response to EPA’s comment in DAEC-4-1. 

No changes will be made to the SEIS based on this comment. 

DAEC-3-2: Response to the Sierra Club Comment Concerning Water Resource Issues 

The Sierra Club has requested an assessment of how DAEC water usage, combined with 

possible future increased water usage from ethanol production could affect water usage. DAEC 

water usage is permitted by the state. Decisions regarding future regional demands for water in 

support of ethanol production and other potential activities are also made by state agencies. 

Sections 4.3.2, 4.3.3, and 4.4.1 of the SEIS address the potential impact of site operations on 

groundwater and surface water resources. Section 4.11.3 of the SEIS has been revised to 

include “industrial usage, including expanded ethanol production” as one of the actions that 

could potentially affect water resource availability. The Staff has determined that when future 

consumptive use of water from ethanol production and other uses are combined with other past, 

present, and reasonably foreseeable future activities including the DAEC, the cumulative impact 

on surface water is SMALL. The cumulative impact section of the SEIS has been changed to 

address this of the comment. 
Appendix A 

NUREG-1437, Supplement 42 A-20 October 2010 

The second part of this comment deals with the potential siltation of the Pleasant Creek 

Reservoir. During the staff’s scoping and preparation of the SEIS, there was no definitive 

evidence leading to a conclusion of any substantial filling of the reservoir by silt. While a typical 

pond has a shallow basin that may be susceptible to silt problems, significant silt deposition 

would be needed to result in a substantial volume decrease of the Pleasant Creek Reservoir. 

An actual estimation of volume reduction due to silt cannot be determined without a detailed 

bathymetric survey. However, the staff estimates that the reservoir was originally constructed in 

a fairly deep valley in order to hold the capacity for supporting the plant cooling system during 

droughts. In addition, as previously noted, while the applicant is permitted to withdraw water 

from the reservoir, it is not obligated or required to do so; therefore, it always has the option of 

reducing power and consumptive water usage in situations where volume capacity is a concern. 

No change will be made to the SEIS based on this comment. 

DAEC-3-3: Response to the Sierra Club Comment Concerning Waste Issues 

The comment concerning storage of spent nuclear fuel is a Category 1 issue that is discussed in 

the GEIS and also addressed in Chapter 6 of this SEIS. The safety and environmental effects 

of spent fuel storage have been evaluated by the NRC and, as set forth in the Waste 

Confidence Rule (10 CFR 51.23). The GEIS for license renewal (NUREG-1437) evaluated a 

variety of spent fuel and waste storage scenarios, including onsite/offsite storage of these 

materials for up to 30 years following expiration of the operating license (including license 

renewal), transfer of these materials to a different plant, and transfer of these materials to an 

independent spent fuel storage installation (ISFSI). The Commission has made a generic 

determination that, if necessary, spent fuel can be stored safely and without significant 

environmental impacts for at least 30 years beyond the licensed life of operation (which may 

include the term of a revised or renewed license) of that reactor in its spent fuel storage basin or 

at either onsite or offsite independent spent fuel storage installations. 

During dry cask storage and transportation, spent nuclear fuel must be encased in 

NRC-approved casks. 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. These requirements 

are specified in 10 CFR Part 72 for storage casks and 10 CFR Part 71 for transportation casks. 

For each potential scenario involving spent fuel, the GEIS determined that existing regulatory 

requirements, operating practices, and radiological monitoring programs were sufficient to 

ensure that impacts resulting from spent fuel and waste storage practices during the term of a 

renewed operating license would be small. In Table B-1 of Appendix B to Subpart A of Part 51, 

the Commission concluded that the impacts associated with spent fuel and high level waste 

disposal are not great enough to deny the option of license renewal for energy-planning 

decision-makers. 

The Staff’s evaluation of the DAEC license renewal application did not find any new and 

significant information related to the storage of spent nuclear fuel. Thus, there are no impacts 

related to spent nuclear fuel storage beyond those discussed in the GEIS. 

The NRC has always required ISFSIs to have an onsite physical security system to protect 

against any unauthorized access to the spent nuclear fuel and its storage area. Safety and 

security are accomplished by using people, equipment, and physical protection. Well-trained, 

armed security guards, physical barriers, access controls, and intrusion detection and 

surveillance systems protect NRC-licensed commercial power reactors, spent fuel pools, and 

dry-cask storage installations. Additionally, the NRC responded to the September 11, 2001, 

terrorist attacks by developing new security measures requiring enhanced security at ISFSIs. 
Appendix A 

October 2010 A-21 NUREG-1437, Supplement 42 

The NRC’s vulnerability assessments included aircraft impacts and ground assaults consistent 

with the design basis threat. The results of these assessments provide high assurance that all 

approved cask systems can securely store and protect spent nuclear fuel. 

The comment does not present any significant new information or arguments that would warrant 

a change to the final SEIS. No changes will be made to the SEIS based on this comment. 

DAEC-3-4: Response to the Sierra Club Comment Concerning Availability of Fuel 

While the availability and cost of recoverable uranium are disputed, many resource specialists 

do in fact maintain that uranium will become an increasingly scarce commodity in the coming 

decades. Under such a scenario, a decrease in the amount of available uranium could affect 

the cost nuclear power generation. Chapter 9 of the SEIS states that for the alternative of 

license renewal, the principle irretrievable resource commitment would be consumption of 

uranium-235. It is important to note that such scenarios depend on many uncertainties and 

assumptions, including the possibility of nuclear fuel re-processing and breeder reactor 

technology. Thus, the ultimate effects of such a scenario on the availability and cost of uranium 

fuel are beyond what can be deemed as reasonably foreseeable and thus reliably forecast 

cannot be made this far into the future. 

The effects of early retirement of DAEC are bounded by the impact assessment of the no-action 

alternative in Section 8.5 of the SEIS. It is important to note that NRC does not have a role in 

the energy-planning decision-making process regarding whether or not a particular nuclear 

power plant would continue to operate under the aforementioned scenario. The NRC’s role is 

limited to determining if the operating license should be renewed. If the renewed license is 

issued, other energy-planning decision-makers and NextEra Energy Duane Arnold, LLC 

(NextEra) will ultimately decide whether the plant would continue to operate, based on factors 

such as the need for power, cost, and other matters outside the purview of the NRC. 

No changes will be made to the SEIS based on this comment. 

DAEC-3-5: Response to the Sierra Club Comment Concerning Safety and Reliability 

The NRC license renewal process establishes the technical and administrative requirements for 

renewal of operating power plant licenses. The reactor operating license was originally issued 

for 40 years, with an option for an additional 20 year renewal period. The DAEC license 

renewal process is proceeding along two tracks—one for review of environmental issues and 

another for safety issues. 

Separate from the environmental review, the safety review process is designed to ensure that 

the level of safety provided by an applicant’s current licensing basis would be maintained for the 

period of extended operation, and that the applicant can provide reasonable assurance that the 

effects of aging will be managed for the period of extended operation such that systems, 

structures, and components (SSCs) will continue to perform their intended functions in 

accordance with the plant’s current licensing basis. Many of the existing programs and 

regulatory requirements that already provide adequate aging management would continue to 

apply to the DAEC following a license renewal. The license renewal safety review focuses on 

those SSCs for which current activities and requirements may not be sufficient to manage aging 

in the period of extended operation. In addition, the NRC staff also performed site inspections 

as part of the DAEC license renewal safety review process to determine whether the applicant 

has implemented and complied with the regulations for license renewal. The results of the 
Appendix A 

NUREG-1437, Supplement 42 A-22 October 2010 

DAEC license renewal safety review were issued in a publicly available safety evaluation report 

(SER) in September 2010. The SER documents the results of the NRC staff’s review of 

aging-management and the applicant’s programs to address these matters during the period of 

extended operation. 

The comment is related to the safety review process and is not within the scope of the 

environmental review. No changes will be made to the SEIS based on this comment. 

DAEC-3-6: Response to the Sierra Club Comment Concerning Evaluation of Alternatives 

The NRC ultimately does not make the decision regarding which alternative (including the 

proposed action) to implement as part of its NEPA review, since that decision falls to utility and 

other energy-planning decision-makers. Comparing the environmental effects of the analyzed 

alternatives in Chapter 8 assists the NRC in deciding whether the environmental impacts of 

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

decision-makers would be unreasonable (10 CFR 51.95[c][4]). If the NRC acts to issue a 

renewed license, all of the alternatives, including the proposed action, will be available to 

energy-planning decision-makers. If NRC decides not to renew the license (or takes no action 

at all), then energy-planning decision-makers will have to resort to another alternative—which 

may or may not be one of the alternatives considered in Chapter 8. 

In determining the scope of alternatives to license renewal, the Staff first selected energy 

technologies or options currently in commercial operation as well as some technologies not 

currently in commercial operation but likely to be commercially available by the time the current 

DAEC operating license expires. The current DAEC operating license will expire on February 

21, 2014, and any alternative would need to be available (constructed, permitted, and 

connected to the grid) by the time the current DAEC license expires.

Next the Staff then screened the alternatives to remove those that cannot meet future system 

needs, and then screened the remaining options to remove those whose costs or benefits do 

not justify inclusion in the range of reasonable alternatives. Any remaining alternatives 

constitute potential options to the proposed action that the Staff evaluates in detail. The 

alternatives that the Staff considered most reasonable include a supercritical coal-fired plant in 

section 8.1, a natural gas-fired combined-cycle power plant in 8.2, and a combination of 

alternatives in 8.3, that includes some natural gas-fired capacity, energy conservation, and a 

wind power component. The no-action alternative was also evaluated in Section 8.5. Section 

8.4 of the SEIS briefly addresses each alternative that the Staff removed during screening 

process and explains why it was removed. In the Staff’s best professional opinion, an 

alternative capable of producing as much power as DAEC and which relied more significantly or 

exclusively on renewable energy was not deemed to be a reasonable option at this time. 

No changes will be made to the SEIS based on this comment. 
Appendix A 

October 2010 A-23 NUREG-1437, Supplement 42 

DAEC-4: Comments Received from the Environmental Protection Agency on the Draft 

Supplemental Environmental Impact Statement 
Appendix A 

NUREG-1437, Supplement 42 A-24 October 2010 
Appendix A 

October 2010 A-25 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-26 October 2010 
Appendix A 

October 2010 A-27 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-28 October 2010 
Appendix A 

October 2010 A-29 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-30 October 2010 
Appendix A 

October 2010 A-31 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-32 October 2010 
Appendix A 

October 2010 A-33 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-34 October 2010 
Appendix A 

October 2010 A-35 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-36 October 2010 

DAEC-4-1: Response to EPA Comment Concerning Purpose and Need 

In the June 5, 1996, Final rule for the Environmental Review for Renewal of Nuclear Power 

Plant Operating Licenses (61 FR 28467), the NRC addressed the concerns of the CEQ relative 

to consideration of appropriate alternatives and the narrow definition of purpose and need. The 

definition of purpose and need in the 1996 GEIS reflects the Commission’s recognition that the 

NRC has no role in energy planning decisions, and the NRC will neither perform analyses of the 

need for power nor draw any conclusions about the need for generating capacity in a license 

renewal review. The purpose of renewing an operating license is to maintain the availability of 

the nuclear plant option in meeting energy requirements beyond the term of the plant’s current 

license. 

The Commission expects that license renewal could be denied if the expected environmental 

effects of license renewal significantly exceed those of all or almost all of the alternatives. The 

Commission believes that this is a reasonable approach to addressing the issue of 

environmental impacts of license renewal, given NRC’s limited role in the area of energy 

systems planning. 

The operation of a nuclear power plant beyond its initial license term involves separate 

regulatory actions, one taken by the utility and the NRC, and the other taken by the utility and 

other energy planning decision-makers. The NRC would determine whether it is reasonable to 

renew the operating license and allow energy planning decision-makers the option of 

considering a currently operating nuclear power plant as an alternative for meeting future 

energy needs. The focus of the analysis is whether the environmental impacts anticipated for 

continued operation during the term of the renewed license reasonably compare with the 

impacts of alternatives considered for meeting generating requirements. The NRC could reject 

a license renewal application if the analysis demonstrated that the adverse environmental 

impacts of license renewal were so great that preserving the option of license renewal for 

energy planning decision-makers would be unreasonable. 

Given the uncertainties involved and the lack of control that the NRC has in the choice of energy 

alternatives in the future, the Commission believes that it is reasonable to exercise its NEPA 

authority to reject license renewal applications only when it has determined that the impacts of 

license renewal sufficiently exceed the impacts of all or almost all of the alternatives, and that 

preserving the option of license renewal for future decision-makers would be unreasonable. 

The objectives of the utility and other appropriate energy planning decision-makers may 

ultimately be the determining factors in whether a nuclear power plant will continue to operate. 

Such decision will not affect the scope or rigor of NRC’s analyses, including the consideration of 

the environmental impacts relevant to the license renewal decision and associated alternatives. 

The staff forwarded this comment to the group currently working on Revision 1 to NUREG-1437, 

the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (Draft 

Revised GEIS). The approach used in the Draft Revised GEIS more-clearly presents all 

alternatives (proposed action and other energy alternatives that are outside the agency’s 

purview) in a more parallel and directly comparable format. The NRC staff also notes that EPA 

headquarters staff provided specific comments on the Draft Revised GEIS during the comment 

period for that document that closed in January of 2010. 

Following receipt of the EPA’s comment letter, the NRC initiated a follow-up telephone call with 

EPA to better understand their concerns. As discussed on that phone call, the NRC staff 

requests EPA’s early and continued communication in future projects. 
Appendix A 

October 2010 A-37 NUREG-1437, Supplement 42 

The NRC staff notes that the comments provided by the EPA staff on the draft SEIS for the 

Duane Arnold Energy Center (DAEC) are made in the context of compliance with EPA’s 

regulations 40 CFR Part 1500-1508 and Section 309 of the Clean Air Act. The NRC takes its 

responsibility to perform an environmental impact statement in accordance with NEPA 

programmatic guidance very seriously. 

The NEPA regulations direct Federal agencies on matters related to environmental policy, 

including the public scoping process, use of lead agencies, and selection of alternatives. As an 

independent agency, the NRC has established its own regulations to implement NEPA. The 

NRC’s requirements for compliance with NEPA are contained in 10 CFR Part 51, Subpart A; 

National Environmental Policy Act – Regulations Implementing Section 102(2). 

The Commission recognizes a continuing obligation to conduct its domestic licensing and 

related regulatory functions in a manner which is both receptive to environmental concerns and 

consistent with the Commission’s responsibility as an independent regulatory agency for 

protecting the radiological health and safety of the public. 

No changes will be made to the SEIS based on this comment. 

DAEC-4-2: Response to EPA Comment Concerning Affected Environment and Impacts 

of Operation 

In order to address the EPA comments in other areas of their document and to better 

understand the NRC’s responses below, it is important to understand NRC’s license renewal 

process which classifies environmental and human health issues as either Category 1 (generic 

to all nuclear power plants) or 2 (requires a site specific evaluation). For license renewal, the 

NRC performed a comprehensive evaluation of all nuclear power plants in the United States to 

assess the scope and impact to public health and safety and the environment from radioactive 

material released from a nuclear power plant for an additional 20 years of operation. 

The impact evaluation performed by the staff and presented in the Generic Environmental 

Impact Statement for License Renewal of Nuclear Plants, NUREG-1437 (GEIS) identified 92 

environmental issues that were considered for the license renewal evaluation for power reactors 

in the U.S. The industry, Federal, state, and local governmental agencies, members of the 

public, and citizen groups commented on and helped identify these 92 issues during the 

preparation of the GEIS. For each of the identified 92 issues, the staff evaluated existing data 

from all operating power plants throughout the U.S. From this evaluation, the staff determined 

which issues could be considered generically and which issues do not lend themselves to 

generic consideration. The GEIS divides the 92 issues that were assessed into two principle 

categories: 

● one for generic issues (which are termed “Category 1 issues”) and 

● the other for site-specific issues (termed “Category 2 issues”). 

Category 1 (generic) issues are those that meet all of the following criteria: 

(a) 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 characteristic. 
Appendix A 

NUREG-1437, Supplement 42 A-38 October 2010 

(b) 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) for all plants. 

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

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

are not likely to be sufficiently beneficial to warrant implementation. 

Category 1 issues are termed “generic” issues because the conclusions related to their 

environmental impacts were found to be common to all plants (or, in some cases, to plants 

having specific characteristics such as a particular type of cooling system). For Category 1 

issues, a single level of significance was common to all plants, mitigation was considered, and 

the NRC determined that it was not likely to be beneficial. Issues that were resolved generically 

are not reevaluated in the site-specific supplement to the generic environmental impact 

statement on license renewal (SEIS) because the conclusions reached would be the same as in 

the GEIS, unless new and significant information is identified that would lead the NRC staff to 

reevaluate the GEIS’s conclusions. During the environmental reviews of license renewal 

applications, the NRC staff makes a concerted effort to determine whether any new and 

significant information exists that would change the generic conclusions for Category 1 issues. 

The following radiological issues: radiological impacts on human health, radiation doses to 

members of the public from the current operation of nuclear power facilities, were examined 

from a variety of perspectives, and the impacts were found to be well within NRC’s and EPA’s 

radiation protection standards in each instance. As a result, the issues are classified as 

Category 1 issues. 

Category 2 issues are those that require a site-specific review. For each of the Category 2 

issues applicable to the site under review, the staff evaluates site-specific data provided by the 

applicant, other Federal agencies, state agencies, Tribal and local governments, as well as 

information from the open literature and members of the public. From this data, the staff makes 

a site-specific evaluation of the particular issues and presents its analyses and conclusions in 

the SEIS for the facility. 

This does not mean that the NRC takes the generic (Category 1) issues “off the table” for public 

review. If there is new and significant information that would change the conclusions reached in 

the GEIS, then the staff notifies the Commission and the issue requires a site-specific analysis. 

During the scoping process and the environmental review, the NRC looks for any information 

that could demonstrate that there are unique characteristics related to the facility or the 

environment surrounding the facility that would lead to the conclusion that the generic 

determination for a particular issue is not valid for a specific site. The NRC staff discusses and 

evaluates potential new and significant information on impacts of operations during the renewal 

term in the SEIS. 

In accordance with NRC regulations, a number of issues are not considered in the 

environmental review for license renewal conducted by the NRC, including but not limited to: 

● safety, 

● operational issues that require a separate National Environmental Policy Act 

(NEPA) review (such as an independent spent fuel storage installation), 
Appendix A 

October 2010 A-39 NUREG-1437, Supplement 42 

● security and safeguard issues, 

● emergency preparedness (including distribution of potassium iodide), 

● need for power, 

● spent fuel disposal and storage, 

● economic feasibility, and 

● cost-benefit analyses. 

These issues are covered in other NRC regulations, licensing actions, inspection and 

enforcement program, and environmental assessment specific to the issue to ensure adequate 

protection of the public’s health and safety and the environment. 

DAEC-4-3: Response to EPA Comment Concerning Reactor and Confinement System 

The SEIS was revised to clarify that there were no radioactive liquid batch discharges into the 

Cedar River. 

DAEC-4-4: Response to EPA Comment Concerning Low-level Mixed Waste 

The Staff revised sections 2.1.2.3 and 2.1.2.5 to better coordinate and discuss LLMW issues. 

The staff deleted the discussion of LLMW from section 2.1.2.4 since it discussed 

non-radioactive hazardous waste. 

DAEC-4-5: Response to EPA Comment Concerning Tritium 

The radiological issues cited in the EPA comment above are Category 1 issues that have been 

generically resolved in the GEIS for license renewal. The Staff discussed the NRC’s license 

renewal process for handling Category 1 and 2 issues in the paragraphs above. In summary, 

the comments relating to radiological issues have been evaluated in the GEIS for license 

renewal and no new and significant information was identified during the scoping process, the 

review of the Duane Arnold Energy Center’s Environmental Report, and the Staff’s site visit that 

contradict the GEIS’s findings. Therefore, there are no impacts beyond those identified and 

evaluated in the GEIS. 

No changes will be made to the SEIS based on the comment. 

DAEC-4-6: Response to EPA Comment Concerning Bromine 

Section 2.2.4 of the draft SEIS already includes the following statement about biocide usage: 

“For the cooling water system, the State (IDNR, 2003) has permitted the use of Spectrus CT 

1300 (Betz), Spectrus NX 1107 (Betz), Spectrus OX 1201 (Betz), or Macrotech, Inc.’s 

electrolytic copper technology.” 

DAEC employs a closed-cycle heat dissipation system with cooling towers. No bromine or other 

biocides are discharged at Outfall 002 (sanitary wastewater discharge). Blowdown water 

containing biocides such as chlorine and sodium bromide is discharged to the Cedar River at 

Outfall 001. The NPDES permit does not include a limit on bromine discharged from Outfall 
Appendix A 

NUREG-1437, Supplement 42 A-40 October 2010 

001. Bromine (as a Spectrus product) is permitted by the state in a letter that is already cited in 

the SEIS (IDNR, 2003). Consistent with the conclusion cited from the GEIS, IDNR concluded 

that usage of this sodium bromide Spectrus product and other biocides is not expected to be 

toxic to aquatic life in the Cedar River. 

Discharge of biocides has been evaluated in the GEIS. The GEIS concluded that the impacts of 

discharged biocides is a Category 1 issue. Specifically, the GEIS concluded that the impacts 

are SMALL and that the “[e]ffects are not a concern among regulatory and resource agencies, 

and are not expected to be a problem during the license renewal term.” In summary, the 

impacts of released biocides from the facility have been evaluated in the GEIS for license 

renewal and no new and significant information was identified during the review of the DAEC’s 

license renewal application. Therefore, the staff appropriately relies on such findings and 

characterization in the GEIS. 

Text has been added to the SEIS (see Section 2.2.4), to clarify the permitted use of bromine (a 

Spectrus product) and its discharge into the Cedar River. 

DAEC-4-7: Response to EPA Comment Concerning Groundwater 

While groundwater radiological data are limited, section 2.1.1 of the SEIS does describe well 

installation and sampling, which began in 2006. Since the drafting of the SEIS, the 2008 REMP 

report became available. Its results are now included in the SEIS. Section 2.2.3 of the SEIS 

has been revised to address gross beta and tritium levels in groundwater samples. 

DAEC-4-8: Response to EPA Comment Concerning Aquatic Life 

The EPA’s comment on aquatic life has been divided into four issues, which are discussed 

below. 

(a) The commenter questions the intent of the benthic macroinvertebrate 

sampling/monitoring at DAEC. Physical, chemical, and biological sampling was carried 

out to identify any conditions that could result in environmental or water quality issues at 

DAEC, to enable the applicant to compare conditions near the intake with those 

downstream of the discharge, and to identify any impacts of plant effluent on 

downstream aquatic communities. The commenter also notes that sampling appears to 

have not been done continually from the period of 1971 through 1999 due to the 

references in the draft SEIS which refer to 1971 and 1999 sampling years. As stated in 

Section 2.2.5.1 of the SEIS, sampling for benthic macroinvertebrates at the DAEC site 

was completed each year from 1971 through 1999. Although only two studies 

representing the year before operations began and the last year that sampling was 

conducted were cited in the draft SEIS, the NRC staff reviewed all studies from the 

period of 1971 through 1999. From 1971 to 1978, the Department of Environmental 

Engineering of the University of Iowa conducted sampling, from 1979 through 1983, 

Ecological Analysts, Inc. conducted sampling, and from 1984 through 1999, the 

University of Iowa Hygienic Laboratory conducted sampling. 

 The commenter also suggests that an upstream/downstream sampling design using 

artificial substrates would provide a more defensible basis for the conclusion that an 

unstable sandy river bed has prevented the development of a larger, more diverse 

benthic population. The NRC staff agrees that this sampling method would provide 

more valuable data. However, it is not within the NRC’s regulatory purview to require 
Appendix A 

October 2010 A-41 NUREG-1437, Supplement 42 

benthic macroinvertebrate sampling. Such sampling requirements at nuclear power 

plants may fall under other regulatory statutes or authorities, e.g., the NPDES permit or 

as part of the Biological Opinion under the Endangered Species Act; this is not the case 

at DAEC. The NRC staff’s assessment of the benthic macroinvertebrate community 

considered the available and most relevant data in its conclusions. No changes to the 

SEIS were made as a result of this comment. 

(b) The commenter notes that the USGS data referenced for description of the fish 

community is too far away from the DAEC site and may lead to misinterpretation that the 

studies are representative of the fish community in the vicinity of DAEC. The commenter 

also asserts that the data collected at the DAEC site from 1979 through 1983 is almost 

30 years old and not referenced. Section 2.2.5.3 of the SEIS has been revised to reflect 

the distances of the USGS sampling sites from DAEC. During its review, the NRC staff 

searched, but was unable to locate, fish community data within the Cedar River at 

locations closer than that sampled by the USGS. The NRC staff used the USGS data 

and compared it with the most recent data available from the DAEC site, which were 

studies conducted from 1979 through 1983 by Ecological Analysts, Inc. The NRC staff 

concluded in Section 2.2.6 that though the USGS data was collected from locations 

upstream and downstream of DAEC, that the sampling results of the USGS data and 

Ecological Analysts, Inc. data yielded similar species compositions and densities. 

Regarding the citation of the Ecological Analysts, Inc. data from 1979 through 1983, this 

data is cited in the SEIS as “Ecological Analysts, 1984,” in-text in Section 2.2.5 and the 

full reference can be found in Section 2.4. 

 The commenter also suggests that an upstream and downstream sampling approach 

would yield more useful information. The NRC staff agrees that this sampling method 

would provide more valuable data. However, as previously indicated, the NRC is limited 

in its regulatory authority for such sampling requirements, and defers to the regulatory 

purview of other authorities where applicable. The NRC staff’s assessment of the 

benthic macroinvertebrate community considered the available and most relevant data in 

its conclusions. 

(c) The commenter notes that Section 4.5 of the draft SEIS does not contain any data or 

discussion regarding effluent temperatures from Outfall 001. All issues related to 

effluent temperature impacts on aquatic communities were concluded in the GEIS to be 

Category 1 and SMALL for plants with cooling towers, such as DAEC. These issues 

include cold shock, thermal plume barrier to migrating fish, and heat shock. As 

described in Section 1.4 of the SEIS, for generic issues (Category 1) issues, no 

additional site-specific analysis is required in the SEIS unless new and significant 

information is identified. No new and significant information was identified during the 

NRC staff’s review of impacts to aquatic resources. Therefore, no additional site-specific 

analysis is warranted in Section 4.5. No changes to the SEIS were made as a result of 

this comment. 

(d) The commenter notes that the draft SEIS does not analyze radiological impacts on fish, 

mussels, or wildlife with site-specific data characterizing the levels and trends of 

radiological dose in aquatic and terrestrial organisms near the DAEC site. 

 The NRC does not have a regulatory framework for radiological protection of nonhuman 

species to use in the SEIS. The NRC believes that if humans are adequately protected, 

other living things are also likely to be sufficiently protected. Nevertheless, a qualitative 

assessment of the impact to biota from radioactivity released into the Cedar River was 
Appendix A 

NUREG-1437, Supplement 42 A-42 October 2010 

performed using radiation protection standards for biota from recognized scientific 

organizations. 

 The International Atomic Energy Agency and the National Council on Radiation 

Protection and Measurements reported that a chronic dose rate of no greater than 1 

rad/d (10 mGy/d) to the maximally exposed individual in a population of aquatic 

organisms would ensure protection of the population. The IAEA also concluded that 

chronic dose rates of 0.1 rad/d (1 mGy/d) or less do not appear to cause observable 

changes in terrestrial animal populations. The cumulative effects to aquatic biota from 

radionuclides, including tritium, released into the Cedar River from Duane Arnold is 

assessed in relation to the calculated dose to a member of the public from radioactive 

liquid effluents. For 2007, the calculated annual whole body dose to a member of the 

public from radioactive liquid effluents was 3.23 E-05 mrem (3.23 E-07 mSv). This dose 

is well below the 25 mrem (0.25 mSv) EPA radiation protection standard in 40 CFR Part 

190 and the NRC’s ALARA criteria of 3 mrem (0.03 mSv) in Appendix I to 10 CFR Part 

50. In comparison to the dose rate criteria for aquatic and terrestrial biota, a dose of 

3.23 E-05 mrem (3.23 E-07 mSv) delivered over the course of a year from periodic 

radioactive liquid effluent discharges represents a negligible impact. No changes to the 

SEIS were made as a result of this comment. 

DAEC-4-9: Response to EPA Comment Concerning Stormwater 

The GEIS determined that human health impacts from the release of radioactive effluents from 

nuclear power plants is a Category 1 issue that is generic to all plants. The GEIS evaluated the 

radioactive gaseous and liquid effluents released into the environment and concluded that the 

impacts are of small significance, provided they are within NRC dose standards. The evaluation 

was based on the radioactive effluent release reports submitted by licensees to the NRC on an 

annual basis. These reports contain information on the types and quantities of radioactive 

material released from the plant from various plant specific release points (i.e, plant vent, liquid 

discharge line, storm water drains, and wastewater treatment facility) into the environment and 

the calculated dose to a member of the public that may be exposed to the material. The GEIS 

reported that trends for average doses for persons living around nuclear power plants reflect the 

small radiation dose levels seen in the calculated doses reported by the nuclear power industry. 

The GEIS further reported that radiation doses to members of the public from the operation of 

nuclear power plants were found to be well within NRC’s regulatory standards. 

The NRC requires that radioactive effluents discharged into the environment be accounted for, 

regardless of where they originated from (e.g., plant vent, liquid discharge line, storm water 

drains, or wastewater treatment facility) and reported in the annual effluent release report. In 

addition, the licensee is required to calculate the dose to a member of the public from 

radioactive gaseous and liquid releases. The calculated doses are required to be within NRC 

dose limits. Compliance with NRC dose limits is inspected by NRC regional inspectors on a 

routine basis. In addition to the radioactive effluent monitoring program, the NRC requires the 

plant to have a radiological environmental monitoring program (REMP) that monitors the 

environment around the site for radioactive contamination. The REMP supplements the 

radioactive effluent monitoring program by verifying that the measurable concentrations of 

radioactive materials and levels of radiation in the environment are not higher than those 

calculated using the radioactive effluent release measurements and transport models. The 

REMP can also provide an indication that there is an abnormal radioactive release if unusual or 

unexpected data is observed. 
Appendix A 

October 2010 A-43 NUREG-1437, Supplement 42 

In summary, the comments relating to radiological issues, such as the impacts from radioactive 

gaseous and liquid effluents released into the environment from the facility, have been 

evaluated in the GEIS for license renewal and no new and significant information was identified 

during the scoping process, the review of the Duane Arnold Energy Center’s, Environmental 

Report, and the staff’s site visit that contradict the GEIS’s findings. Therefore, there are no 

impacts beyond those identified and evaluated in the GEIS. 

No changes will be made to the SEIS based on this comment. 

DAEC-4-10: Response to EPA Comment Concerning Wastewater Treatment 

The radiological issues cited in this comment are Category 1 issues that have been generically 

resolved in the GEIS for license renewal. 

The NRC requires that radioactive effluents discharged into the environment be accounted for, 

regardless of where they originated from (i.e., plant vent, liquid discharge line, storm water 

drains, or wastewater treatment facility) and reported in the annual effluent release report. In 

addition, the licensee is required to calculate the dose to a member of the public from 

radioactive gaseous and liquid releases. The calculated doses are required to be within NRC 

dose limits. Compliance with NRC dose limits is inspected by NRC regional inspectors on a 

routine basis. In addition to the radioactive effluent monitoring program, the NRC requires the 

plant to have a radiological environmental monitoring program (REMP) that monitors the 

environment around the site for radioactive contamination. The REMP supplements the 

radioactive effluent monitoring program by verifying that the measurable concentrations of 

radioactive materials and levels of radiation in the environment are not higher than those 

calculated using the radioactive effluent release measurements and transport models. The 

REMP can also provide an indication that there is an abnormal radioactive release if unusual or 

unexpected data is observed. In summary, the comments relating to radiological issues, such 

as the impacts from radioactive gaseous and liquid effluents released into the environment from 

the facility have been evaluated in the GEIS for license renewal and no new and significant 

information was identified during the scoping process, the review of the Duane Arnold Energy 

Center’s Environmental Report, and the Staff’s site visit that contradict the GEIS’s findings. 

Therefore, there are no impacts beyond those identified and evaluated in the GEIS. 

No changes will be made to the SEIS based on this comment. 

DAEC-4-11: Response to EPA Comment Concerning Noise 

The comment regarding noise is a Category 1 issue that has been generically resolved in the 

GEIS for license renewal. The Staff previously discussed the NRC’s license renewal process 

for handling Category 1 and 2 issues. In summary, the comments relating to noise issues have 

been thoroughly evaluated in the GEIS for license renewal and no new and significant 

information was identified during the scoping process, the review of the Duane Arnold Energy 

Center’s Environmental Report, and the Staff’s site visit that contradict the GEIS’s findings. 

Therefore, there are no impacts beyond those identified and evaluated in the GEIS. 

No changes will be made to the SEIS based on the comment.
Appendix A 

NUREG-1437, Supplement 42 A-44 October 2010 

DAEC-4-12: Response to EPA Comment Concerning the Pleasant Creek Recreational 

Reservoir 

Annual Water Use Reports are submitted by DAEC to the Iowa Department of Natural 

Resources (IDNR). These include monthly and annual volumes of water withdrawn from the 

Cedar River, the site wells, and the Pleasant Creek Reservoir. Reports from 1999 to 2008 were 

inspected by the Staff at the site audit, and indicated zero discharge from the reservoir for the 

years in this period. As described in SEIS section 2.1.6.2, DAEC may withdraw up to 16,000 

acre-feet/year from the Cedar River to replenish the Pleasant Creek Reservoir, subject to 

restrictions on allowable conditions (Withdrawal of river water is allowed when flow in the Cedar 

River is greater than 937 cubic feet per second (cfs) as measured at a gage in Cedar Rapids. 

From April 1 to September 30, withdrawal is allowed if flow in Cedar Rapids is between 500 and 

937 cubic feet per second (cfs), only if flow is increasing on a 24-hour basis. From October 1 to 

March 31, withdrawal is allowed if flow is greater than 500 cfs). 

As described in Section 4.4.1, the withdrawal rate and consumptive rate are higher proportions 

of the river flow during low-flow periods. By permit, when river flow falls below 500 cfs (14 

m3

/s), the Pleasant Creek Recreational Reservoir may discharge to the Cedar River at a rate 

equal to the consumptive use rate of 18 cfs (0.51 m3

/s). However, discharge from the reservoir 

is not a requirement of the permit. At this low-flow threshold, flow in the river is 13 percent of 

the average flow; the withdrawal rate is 5 percent of the low flow; and the return of blowdown to 

the river results in a net consumptive rate of just over 3 percent of the low flow—less than the 

18 cfs (0.51 m3

/s) consumptive use rate. Since the area of the Pleasant Creek Recreational 

reservoir is 410 acres, and assuming an average depth of the reservoir at approximately 17 feet 

(consistent with a detailed bathymetric map2

), even over a two-week drought period, the 

estimated discharge from the reservoir would not equate to a significant amount (conservatively 

less than 10 percent of the reservoir’s volume). In other words, the net removal of water from 

the reservoir to compensate for the consumptive use from the river would be a relatively small 

fraction of the reservoir’s total capacity. The Staff does not believe that such a drawdown would 

severely affect either the reservoir’s ecosystem, or local socioeconomic conditions or recreation. 

In addition, there are a number of other considerations to mitigate any impact from the 

reservoir’s usage: 

• As mentioned above, a period of low flow would be an infrequent event and to 

date there has been no need to discharge water from the reservoir to the river. 

● In the case of a severe draught condition, the IDNR and DAEC would be 

coordinating the use of discharge from the reservoir to preclude or mitigate any 

potential impacts. 

● Although DAEC is permitted to discharge from the reservoir to the river, it is not 

a mandatory requirement, and DAEC is allowed to consider other options such 

as reducing power output and subsequent consumptive usage. 

The commenter also noted that climate change might accentuate a potential drawdown in 

reservoir water level. At present, a site-specific assessment of impacts, possibly resulting from 

 

2 http://limnology.eeob.iastate.edu/lakereport/images/bathymetric_images/pdf/095.pdf
Appendix A 

October 2010 A-45 NUREG-1437, Supplement 42 

increased greenhouse gas concentrations on the flow of the Cedar River is not sufficiently 

advanced to allow the staff to draw a conclusion for such a scenario. 

No changes will be made to the SEIS based on this comment.

DAEC-4-13: Response to EPA Comment Concerning Spent Fuel Storage and 

Independent Spent Fuel Storage Installation 

The storage of spent nuclear fuel is a Category 1 issue and discussed in Chapter 6 of the SEIS. 

The safety and environmental effects of spent fuel storage have been evaluated by the NRC 

and, as set forth in the Waste Confidence Rule (10 CFR 51.23), the Commission has made a 

generic determination that, if necessary, spent fuel generated in any reactor can be stored 

safely and without significant environmental impacts for at least 30 years beyond the licensed 

life of operation (which may include the term of a revised or renewed license) of that reactor at 

its spent fuel storage basin or at either onsite or offsite independent spent fuel storage 

installations. 

The GEIS for license renewal (NUREG-1437) evaluated a variety of spent fuel and waste 

storage scenarios, including on site storage of these materials for up to 30 years following 

expiration of the operating license, transfer of these materials to a different plant, and transfer of 

these materials to an Independent Spent Fuel Storage Installation (ISFSI). During dry cask 

storage and transportation, spent nuclear fuel must be “encased” in NRC-approved casks. 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. These requirements are specified in 10 CFR 

Part 72 for storage casks and 10 CFR Part 71 for transportation casks. For each potential 

scenario involving spent fuel, the GEIS determined that existing regulatory requirements, 

operating practices, and radiological monitoring programs were sufficient to ensure that impacts 

resulting from spent fuel and waste storage practices during the term of a renewed operating 

license would be small, and is a Category 1 issue. This conclusion is contained in NRC 

regulation; in Table B-1 of Appendix B to Subpart A to Part 51, the Commission concluded that 

the impacts associated with spent fuel and high level waste disposal 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. The Staff’s 

evaluation of the DAEC license renewal application did not find any new and significant 

information related to the storage of spent nuclear fuel. Thus, there are no impacts related to 

spent nuclear fuel storage beyond those discussed in the GEIS. 

No changes will be made to the SEIS based on this comment. 

DAEC-4-14: Response to EPA Comment Concerning Environmental Justice 

Socioeconomic conditions at the Sac and Fox Reservation and Meskwaki Settlement would not 

change as a result of renewing the DAEC operating license. Employment levels at DAEC would 

remain relatively unchanged, so direct and indirect employment opportunities caused by DAEC 

would remain unchanged. The Sac and Fox and Meskwaki Settlement receive no income from 

tax monies paid by NextEra Energy Duane Arnold, LLC to Linn County. Nevertheless, the SEIS 

has been revised to more fully describe the overall potential human health and environmental 

effects that could affect minority and low-income populations including the Sac and Fox 

Reservation and Meskwaki Settlement. 
Appendix A 

NUREG-1437, Supplement 42 A-46 October 2010 

The discussion in Section 4.9.7.4 summarizes the results from the DAEC 2007 REMP report 

and incorporates this document by reference. The analysis of impacts was performed on more 

than a single year’s worth of REMP data. While the REMP generates an annual report, each 

report provides several years of analytical and historic trend information on a number of critical 

pathways (e.g., airborne iodine, fish, milk, and broadleaf food crop vegetation). The results of 

the REMP continue to demonstrate that the operation of the DAEC does not result in a 

significant measurable dose to a member of the general population nor adversely impacts the 

environment as a result of radiological emissions and effluents. No changes will be made to the 

SEIS based on this comment. 

DAEC-4-15: Response to EPA Comment Concerning Super-Critical Coal-Fired 

Generation 

As mentioned in Section 8.1.1, air quality regulations are currently in place for new power 

plants, and any new construction would be subject to the Prevention of Significant Deterioration 

of Air Quality Review by the Iowa Department of Natural Resources (IDNR). NRC staff believes 

that, unless regional carbon regulations and monitoring systems are in place, assessing the air 

impacts of the coal-fired alternative in addition to the emissions of existing coal-burning facilities 

in the area does not meaningfully add to the alternatives discussion in Section 8.1. 

Section 8.1.7 estimates the amount of dry solid ash and scrubber sludge that this coal-fired 

plant would produce, in addition to the amount of waste that would be recycled. This discussion 

goes on to estimate the amount of area in that would be required to dispose of the waste over a 

40-year period of operation. The analysis states that such disposal could noticeably affect land 

use and groundwater quality, and that following closure of the waste site and revegetation, the 

land could be available for other uses. The Staff believes that this analysis is sufficient to allow 

the reader to compare this alternative to the waste management impacts of the other 

alternatives. 

No changes will be made to the SEIS based on this comment. 

DAEC-4-16: Response to EPA Comment on Evaluation of Alternatives 

In the SEIS the NRC staff concluded that license renewal of DAEC would result in smaller 

impacts than the other action alternatives. All alternatives were considered in detail, based on 

the technical review of the potential environmental impacts found in Chapters 4, 5, 6, 7, and 8. 

NRC staff found that the alternatives to license renewal of DAEC resulted in larger potentially 

adverse environmental impacts than the proposed action, the impacts of which were evaluated 

in Chapter 4 of the SEIS. 

The staff’s SEIS for the proposed DAEC license renewal, in addition to evaluating potential 

alternatives, must satisfy NRC regulations in 10 CFR 51.95(c)(4) that state “...the NRC staff, 

adjudicatory officers, and Commission shall determine whether or not the adverse 

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

renewal for energy planning decision-makers would be unreasonable.” Thus, by regulation, the 

Final SEIS must contain the staff’s recommendation on whether the impacts of license renewal 

ought to preclude its availability as a future system generating option. 

NRC staff rigorously explored and devoted sufficient treatment to each considered alternative to 

determine which alternatives were environmentally preferable. Each of the alternatives 

considered were evaluated in terms of potential environmental impacts by NRC technical staff in 
Appendix A 

October 2010 A-47 NUREG-1437, Supplement 42 

the same resource areas evaluated for the proposed action in Chapter 4 of the SEIS. Potential 

environmental impacts in each resource area were determined to be SMALL, MODERATE, or 

LARGE based on these technical evaluations in order to provide a clear basis for choice among 

the alternatives. These findings are presented in Table 8-5 alongside the impacts of the 

proposed action in order to present a clear comparison of the overall impact levels. 

Each alternative is evaluated separately to obtain a more accurate picture of the potential 

impacts. Table 8-5 is included at the end of Chapter 8 in order to provide a direct comparison of 

the potential impacts of each discussed alternative, including license renewal. From this 

comparison, NRC staff determined that these alternatives resulted in larger potentially adverse 

environmental impacts than the proposed action. 

No changes will be made to the SEIS based on this comment. 
Appendix A 

NUREG-1437, Supplement 42 A-48 October 2010 

DAEC-5: Comments Received from NextEra Energy Duane Arnold, LLC on the Draft 

Supplemental Environmental Impact Statement 
Appendix A 

October 2010 A-49 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-50 October 2010 
Appendix A 

October 2010 A-51 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-52 October 2010 
Appendix A 

October 2010 A-53 NUREG-1437, Supplement 42 
Appendix A 

NUREG-1437, Supplement 42 A-54 October 2010 
Appendix A 

October 2010 A-55 NUREG-1437, Supplement 42 

DAEC-5-1: Response to Comments Received from NextEra Energy Duane Arnold, LLC 

NRC Response: The SEIS has been changed to address the three principal comments (i.e., 

NPDES permit, corporate name change, and the significance level assigned to potential 

impacts on historical/archaeological resources) presented in the cover page to the comments 

submitted by NextEra Energy Duane Arnold, LLC. Specifically, the three comments have been 

addressed as follows: (1) With respect to the NPDES permit, section 2.2.4 of the SEIS has been 

changed to indicate that an application has been made for renewal of the NPDES permit, which 

is under review by the Iowa Department of Natural Resources, and that the existing permit will 

continue in effect until issuance of the renewed permit; (2) In several introductory sections of the 

SEIS, text has been added to indicate that the corporate name “FPL Energy Duane Arnold, 

LLC” has recently been changed to “NextEra Energy Duane Arnold, LLC;” (3) Section 4.9.6 of 

the SEIS has been changed to address implementation of the cultural resources management 

plan. However, based on consultations with the State Historic Preservation Office and the fact 

that dense concentration of cultural material may lie within the DAEC site, the Staff decision was 

made to maintain its finding that the impact level is “MODERATE.” 

As applicable, changes to the SEIS have also been made to address comments provided in the 

accompanying table to this letter. The following table shows NRC responses to DAEC 

comments. 
Appendix A 

NUREG-1437, Supplement 42 A-56 October 2010 

NRC responses to Comments on the SEIS made by NextEra Energy Duane Arnold, LLC 

Page Line Comment 

NRC 

Response 

 v 

xv 

1-1 

2 

3 

18 

The corporate name “FPL Energy Duane Arnold, LLC” 

was changed to “NextEra Energy Duane Arnold, LLC” in 

April 2009, several months after the license renewal 

application was filed. To avoid any confusion, we 

suggest that “FPL Energy Duane Arnold, LLC (FPLDA)” be replaced with “NextEra Energy Duane Arnold, 

LLC, fka FPL Energy Duane Arnold, LLC (FPL-DA)” in 

the Abstract (page v line 2), Executive Summary (page 

xv line 3), and Section 1.1 Proposed Federal Action 

(page 1-1 line 18). The NRC may also consider making 

conforming changes to the remainder of the DSEIS. 

The text has 

been changed 

to address this 

comment. 

xviii 

4-21 

4-21 

4-37 

33-35 

10-12 

23-28 

28-33 

In December 2009, Duane Arnold completed the 

development of a Cultural Resources Protection Plan 

and corresponding implementation procedures. The 

plan was a collaborative effort with the State Historic 

Preservation Office (SHPO), a division of the State 

Historic Society of Iowa and is on file with the society. 

Given that a plan is in place and no refurbishment 

activities are scheduled, a conclusion of SMALL seems 

more appropriate. 

Not accepted. 

Additional text 

provided in 

Section 4.9.6. 

xx Table I-1 This table needs to be reconciled against the prose in 

the introduction section, the tables in Section 8, the 

prose in Section 8 and the prose in Section 4. For 

example: 

1) For DAEC License Renewal, Land Use is designated 

S to M in Table I-1 while the prose on page xvi lines 27-

29 and page 4-1 lines 14-19 state SMALL. 

2) The tables in Section 8 do not include the impact on 

Land Use for any of the alternatives as it is considered 

as a subset of Socioeconomic Impacts. 

3) For the Combination Alternative, Socioeconomics is 

designated S to M, while the table on page 8-26 and 

supporting prose in Section 8-3 stipulate SMALL to 

LARGE. 

The responses 

to these three 

comments are: 

(1) The text has 

been changed; 

(2) In chapter 8, 

land use has 

been included 

within the 

socioeconomic 

sections; (3) 

The text has 

been changed. 

1-92-

24C-3 

Table 1-

236 

TableC-2 

With the exception of the NPDES permit and the one 

time dredging permits (PF07-015, 06-141and 07-175) 

all applicable permits have been renewed. In regard to 

the NPDES permit, Duane Arnold made a timely 

application for renewal and the application is under 

review by the Iowa Department of Natural Resources. 

Therefore, the permit issued July 2007 is valid. 

The status of 

DAEC permits 

has been 

updated. 
Appendix A 

October 2010 A-57 NUREG-1437, Supplement 42 

Page Line Comment 

NRC 

Response 

2-9 2 & 12 These sentences imply that Duane Arnold routinely 

solidifies liquid waste. This is inconsistent with the 

statement on page 2-8, lines 39-40 and with the 

Environmental Report. To the extent practical, liquid 

waste is purified and recycled. The sentence on line 2 

should be reworded to say: “To the extent possible 

liquid waste is purified and recycled. If that is not 

feasible the liquid is evaporated and the sludge 

solidified.” Similarly, the sentence on Line 12 should be 

reworded to say: “As indicated earlier, the liquid waste 

is purified and recycled, however...” 

The text has 

been changed 

to address this 

comment. 

2-12 24 The topic of mixed waste is contained in three 

subsections: 2.1.2.3 Radioactive Solid Waste (pg 2-10 

lines 11-18); 2.1.2.4 Nonradioactive Hazardous Waste 

Streams (pg 2-12 lines 6-10); and 2.1.2.5 Mixed Waste 

(pg 2-12 lines 25-30). This makes it difficult to 

determine how mixed waste is handled at the plant. 

Significant information should be consolidated in section 

2.1.2.5. If need be, the other sections could have 

pointer sentences referring to the Mixed Waste section. 

The text has 

been changed 

to address this 

comment. 

2-17 32, 33 Well water is used to cool many systems in the plant. 

Suggest wording this sentence as follows: “The DAEC 

relies on the Cedar River as its source of makeup water 

for its condenser cooling system, and it discharges 

various waste flows to the river.” 

The text has 

been changed 

to address this 

comment. 

2-26 4, 6 The two references to “new” permit should be changed 

to “renewed”. 

The text has 

been changed 

to address this 

comment. 

2-28 12 As currently written, this sentence implies the entire city 

was evacuated. That was not the case. Suggest 

replacing “The city of Cedar Rapids...” with "Portions of 

the city of Cedar Rapids..." 

The text has 

been changed 

to address this 

comment. 

2-33 32-33 Given that a squawfoot shell was found in the vicinity of 

DAEC in 2002, perhaps this should be worded more 

equivocally: “Although a dead squawfoot was found 

upstream of DAEC in 2002, no live specimens have 

been collected in recent years. “ 

The text has 

been changed 

to address this 

comment. 

2-43 22 To be consistent with Table 2-6, this should be 89%. The text has 

been changed 

to address this 

comment. 

4-4 Table 4-4 “Altered Salinity” should not be included in this table as 

it is not applicable for Duane Arnold. 

The text has 

been changed 

to address this 

comment. 
Appendix A 

NUREG-1437, Supplement 42 A-58 October 2010 

Page Line Comment 

NRC 

Response 

4-36 32 The Supplemental Environmental Impact Statement 

should address the impact on Iowa not Nebraska. If this 

is a typo merely change, otherwise the CDC's records 

for Iowa should be examined. 

The text has 

been changed 

to address this 

comment. 

5-7 26 Should read “SAMA 117 - Increase boron concentration 

or enrichment in the SLC system.” Enriching the B-10 is 

what is being examined in more detail. 

The text has 

been changed 

to address this 

comment. 

6-1 25 Should refer to FPL-DA not NPPD. The text has 

been changed 

to address this 

comment. 

6-11 19-20 Delete this reference. Add FPL Energy Duane Arnold's 

Environmental Report as a reference. 

The text has 

been changed 

to address this 

comment. 

8-2 Side Box The alternatives listed in the box are not consistent with 

those listed in Section 8.4. Methane and Wind are 

included in the box, but are not included in Section 8.4 

Conversely, Offsite Coal and Gas Fired Capacity is 

addressed in Section 8.4.1 but not included in the box. 

The text has 

been changed 

to address this 

comment. 

8-2 14 Depending on the disposition of the comment regarding 

the box on this page, 17 may or may not be the 

appropriate number of discreet alternatives considered. 

The text has 

been changed 

to address this 

comment. 

8-5 

8-17 

8-26 

Tables 8-

1, 8-2, 8-

3 and 8-4 

These tables, and their corresponding prose, have Land 

Use as a subset of Socioeconomic. On page xx Table I 

-1, Land Use is considered on its own. 

The Staff 

acknowledges 

that land use 

has been 

inconsistently 

subcategorized 

in the SEIS. 

Nevertheless, it 

has been 

evaluated as 

an issue per 10 

CFR Part 51. 

The Staff will 

consider 

applying a 

more consistent 

categorization 

of land use in 

the future. 
Appendix A 

October 2010 A-59 NUREG-1437, Supplement 42 

Page Line Comment 

NRC 

Response 

8-9 23-30 This is inconsistent with the conclusion of SMALL to 

MODERATE on page 4-6 lines 9-13. Both the new coal 

plant and continued operation of the DAEC will 

consume about 11 million gallons of river water a day. 

The impact on surface water use should be the same. 

The text has 

been changed 

to address this 

comment. 

8-37 31 Consider revising this analysis to reflect Iowa instead of 

Nebraska. 

The text has 

been changed 

to address this 

comment. 

8-45 Table 8-5 

vs 8-3 

For Combination Alternative, Socioeconomics is 

designated SMALL to MODERATE. This does not 

match the SMALL to LARGE designation on Table 8-3 

(page 8-26) nor the prose in Section 8-3. 

The text has 

been changed 

to address this 

comment. 

F-11 Table G4 The last descriptive case is a repeat of the second to 

the last case. It should be removed, and the core 

damage frequency for "Others" changed to 3.1 E-07. 

The text has 

been changed 

to address this 

comment. 

F-23 26 

30 

$14,000 should be $8,000 as the external events 

accounts for 36% of the total ( 0.57/1.57). 

$23,000 x 36% = $8,000. 

Similarly, $140,000 should be $80,000. 

The text has 

been changed 

to address this 

comment. 

xvii 3 

Change “...are a Category 2...” to “...is a Category 2...” The text has 

been changed 

to address this 

comment. 

1-7 9 This should be the Iowa State Archaeologist The text has 

been changed 

to address this 

comment. 

2-13 

xxv 

4-8 

27 

5 

23 

Delete “Information Technology Council”. The name of 

the company is ITC Midwest LLC. ITC is neither an 

abbreviation nor an acronym. 

The text has 

been changed 

to address this 

comment. 

2-14 7 & 14 “...500-foot (153-m)...” should be “...665-foot (203-m)...” The text has 

been changed 

to address this 

comment. 

2-14 10 & 17 “...665-foot (203-m)...” should be “...500-foot (153-m)...” The text has 

been changed 

to address this 

comment. 

2-14 13 “...Hills substation feed...” should be “...Hazelton 

substation feed...” 

The text has 

been changed 

to address this 

comment. 
Appendix A 

NUREG-1437, Supplement 42 A-60 October 2010 

Page Line Comment 

NRC 

Response 

2-17 7-8 The sentence “Water that is lost through cooling tower 

evaporation... is termed ‘makeup’ water” is confusing. 

The lost water isn’t called makeup water. Water used to 

replenish these losses is called makeup water. Suggest 

the sentence be reworded to: “Water which is 

replenished due to losses through cooling tower 

evaporation ... ‘makeup’ water.” 

The text has 

been changed 

to address this 

comment. 

2-19 22 Replace (47,602,000 m3) with (3.2 km). The text has 

been changed 

to address this 

comment. 

2-22 15 Replace “...northwest from DAEC.” to “...southeast from 

DAEC.” 

The text has 

been changed 

to address this 

comment. 

2-24 3 Change “...near the reactor.” to “...near the reactor 

building." 

The text has 

been changed 

to address this 

comment. 

2-24 11 The word “levy” should be "levee". The text has 

been changed 

to address this 

comment. 

2-25 3-5 Suggest adding a sentence referring to Table 2-3 for the 

intended use of the chemicals. 

The text has 

been changed 

to address this 

comment. 

2-29 5 As mussels are no longer an important source of food 

for Native Americans, change “...mussels are 

historically...” to “...mussels were historically...” 

The text has 

been changed 

to address this 

comment. 

2-29 31 There are several small populations of mussels in the 

area. Suggest the term “population” be replaced with 

“community”. 

The text has 

been changed 

to address this 

comment. 

2-30 25 Ecological Analysts (1984) don’t report the total number 

of fish collected over the five-year period, just the 

number of species collected each year. They do, 

however, report the number of fish collected in 1983 --- 

1,387. See p. 2.2-3 of DAEC LR ER. 

The text has 

been changed 

to address this 

comment. 

2-31 16 Box elder is Acer negundo, not negunde The text has 

been changed 

to address this 

comment. 

2-31 22 Two species of meadowlarks are observed. Change 

“...meadowlark...” to “...meadowlarks...” 

The text has 

been changed 

to address this 

comment. 
Appendix A 

October 2010 A-61 NUREG-1437, Supplement 42 

Page Line Comment 

NRC 

Response 

2-31 23 Change “...red-wing blackbirds...” to “...red-winged 

blackbirds...” 

The text has 

been changed 

to address this 

comment. 

2-33 4 If possible, please provide particulars on recovery 

efforts (how far downstream?). 

Comment was 

not accepted. 

2-33 6 The text regarding downstream recovery efforts is 

redundant to that the text on line 4 of this page. 

The text has 

been changed 

to address this 

comment. 

2-33 27 “Cyprinids” and “Ictalurids” shouldn't be italicized. The text has 

been changed 

to address this 

comment. 

2-33 29 The common name is “river otter” and the scientific 

name is Lutra canadensis. 

The text has 

been changed 

to address this 

comment. 

2-34 Table 2-4 The scientific name for squawfoot is Strophitus 

undulatus.

The text has 

been changed 

to address this 

comment. 

2-38 Table 2-5 The scientific name for prince's pine is Chimaphila 

umbellata

The text has 

been changed 

to address this 

comment. 

2-41 3 Duane Arnold schedules refueling outages at 18 to 24 

month intervals. 

The text has 

been changed 

to address this 

comment. 

2-42 15 “...(gallons per day)...” should be “...(million gallons per 

day)...” 

The text has 

been changed 

to address this 

comment. 

2-50 15 This line indicates there are 74 properties in Linn 

County that are listed on the National Register of 

Historic Places. The ER indicates that there are 75 

properties. (ER page 2.11-3 second ¶). 

The text has 

been changed 

to address this 

comment. 

4-6 Table 4-5 “Stimulation of nuisance organisms” should be included 

in this table (GEIS reference 4.2.2.1.11, Category 1) 

The text has 

been changed 

to address this 

comment. 

4-6 12 “...impact on groundwater...” should be “...impact on 

surface water...” 

The text has 

been changed 

to address this 

comment. 
Appendix A 

NUREG-1437, Supplement 42 A-62 October 2010 

Page Line Comment 

NRC 

Response 

4-10 28 & 36 Rem and rad are no longer considered to be acronyms. 

They are just special units of dose equivalent and 

absorbed dose, respectively. 

The text has 

been changed 

to address this 

comment. 

4-13 40 Biannually can mean either once every two years or 

twice a year. To avoid confusion the term biennially 

should be used. 

The text has 

been changed 

to address this 

comment. 

4-14 13 EMF is defined as electromagnetic force on line 13, but 

used as electromagnetic field on line 29. 

The text has 

been changed 

to address this 

comment. 

4-21 29-36 This is a repeat of lines 5-12 on the same page. The text has 

been changed 

to address this 

comment. 

4-22 1-14 This is a repeat of lines 17-28 on page 4-21. The text has 

been changed 

to address this 

comment. 

4-29 16 Change “...or lower levels...” to “...or lower...” The text has 

been changed 

to address this 

comment. 

4-36 32 Nebraska should be Iowa. The text has 

been changed 

to address this 

comment. 

4-37 15 Lynn should be Linn. The text has 

been changed 

to address this 

comment. 

5-1ff. There are multiple references to Appendix G, which 

should be Appendix F. 

The text has 

been changed 

to address this 

comment. 

5-5 6 For consistency, we suggest providing the dose 

calculations in rem first, followed by sieverts. 

The text has 

been changed 

to address this 

comment. 

6-1 2 Solid waste management is only mentioned in the title 

of the section. Should there be more information in the 

section? 

The text has 

been changed 

to address this 

comment. 

8-2 41 Biological is referred to as Terrestrial and Aquatic 

Resources in subsequent sections. This could cause 

some confusion. 

The text has 

been changed 

to address this 

comment. 
Appendix A 

October 2010 A-63 NUREG-1437, Supplement 42 

Page Line Comment 

NRC 

Response 

8-5 

8-17 

8-26 

Tables 8-

1 & 8-2 

For Continued DAEC Operation, Groundwater is 

categorized as SMALL to MODERATE. The text in 

Section 4.3 concludes that the impact is SMALL. 

The text has 

been changed 

to address this 

comment. 

8-5 

8-17 

8-26 

Tables 8-

1 & 8-2 

For Continued DAEC Operation, Surface Water is 

categorized as SMALL. The text in Section 4.4 

conclude that the impact is SMALL to MODERATE. 

The text has 

been changed 

to address this 

comment. 

8-23 38 “...coal-fired alternative ...” should be “... gas-fired 

alternative...” 

The text has 

been changed 

to address this 

comment. 

8-46 9 Should this be referencing an Iowa site rather than a 

Nebraska site? 

The text has 

been changed 

to address this 

comment. 

8-36 3-11 This paragraph indicates that “...FPL-DA indicated that it 

is unlikely that a nuclear alternative could be sited, 

constructed and operational by the time DAEC 

operating license expires in February of 2014.” 

Although FPL-DA did not make the statement, and 

analyzed the potential impacts of constructing a new 

nuclear facility at the DAEC site, we do agree that it 

would be unlikely that a new reactor could be on line 

before the expiration of the current operating license. 

The text has 

been changed 

to address this 

comment. 

Chapter 

8 

 NRC did not use the analysis prepared by FPL-DA for 

input to the alternatives analysis in the DEIS. 

Consequently, the various numbers cited for coal- and 

gas-fired emissions, land use, waste, etc. differ from 

those presented in the ER. In general, the numerical 

values cited by NRC are larger than those presented in 

the ER and NRC conclusions based on those values 

indicate impacts from the various alternatives would be 

larger than those estimated by FPL-DA. The less 

conservative assumptions and conclusions in the DEIS 

support the case for license renewal. 

The Staff's 

assessment of 

the 

alternatives, 

used 

information 

from the ER as 

well as various 

other sources. 

F-4 15 Most tables in this section are given a G- designation 

rather than an F- designation. 

The text has 

been changed 

to address this 

comment. 

F-34 

4 

line 7 

Change “...loss of offsite peer risk...” to “...loss of 

offsite power risk...” 

The text has 

been changed 

to address this 

comment. 
Appendix A 

NUREG-1437, Supplement 42 A-64 October 2010 

DAEC-6: Comments Received from Mr. J. Doershuk, Iowa State Archaeologist on the 

Draft Supplemental Environmental Impact Statement 

DAEC-6-1: Response to Comments Received from Mr. J. Doershuk 

NRC Response: Section 4.9.6 of the SEIS addresses these comments. 
APPENDIX B. 

NEPA ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER 

PLANTS 

October 2010 B-1 NUREG-1437, Supplement 42 

B. NEPA ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER 

PLANTS 

Table B-1. Summary of Issues and Findings. This table is taken from Table B-1 in Appendix 

B, Subpart A, to 10 CFR Part 51. Data supporting this table are contained in NUREG-1437, 

Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Throughout 

this report, “Generic” issues are also referred to as Category 1 issues, and “Site-specific” issues 

are also referred to as Category 2 issues.

Issue Type of Issue Finding 

Surface Water Quality, Hydrology, and Use 

Impacts of 

refurbishment on 

surface water quality 

Generic SMALL. Impacts are expected to be negligible during refurbishment 

because best management practices are expected to be employed 

to control soil erosion and spills. 

Impacts of 

refurbishment on 

surface water use 

Generic SMALL. Water use during refurbishment will not increase 

appreciably or will be reduced during plant outage. 

Altered current 

patterns at intake and 

discharge structures 

Generic SMALL. Altered current patterns have not been found to be a 

problem at operating nuclear power plants and are not expected to 

be a problem during the license renewal term. 

Altered salinity 

gradients 

Generic SMALL. Salinity gradients have not been found to be a problem at 

operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Altered thermal 

stratification of lakes 

Generic SMALL. Generally, lake stratification has not been found to be a 

problem at operating nuclear power plants and is not expected to be 

a problem during the license renewal term. 

Temperature effects 

on sediment transport 

capacity 

Generic SMALL. These effects have not been found to be a problem at 

operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Scouring caused by 

discharged cooling 

water 

Generic SMALL. Scouring has not been found to be a problem at most 

operating nuclear power plants and has caused only localized 

effects at a few plants. It is not expected to be a problem during the 

license renewal term. 

Eutrophication Generic SMALL. Eutrophication has not been found to be a problem at 

operating nuclear power plants and is not expected to be a problem 

during the license renewal term. 

Discharge of chlorine 

or other biocides 

Generic SMALL. Effects are not a concern among regulatory and resource 

agencies, and are not expected to be a problem during the license 

renewal term. 

Discharge of sanitary 

wastes and minor 

chemical spills 

Generic SMALL. Effects are readily controlled through NPDES permit and 

periodic modifications, if needed, and are not expected to be a 

problem during the license renewal term. 

Discharge of other 

metals in wastewater 

Generic SMALL. These discharges have not been found to be a problem at 

operating nuclear power plants with cooling-tower-based heat 

dissipation systems and have been satisfactorily mitigated at other 

plants. They are not expected to be a problem during the license 

renewal term. 

Water use conflicts 

(plants with 

once-through cooling 

systems) 

Generic SMALL. These conflicts have not been found to be a problem at 

operating nuclear power plants with once-through heat dissipation 

systems. 
Appendix B 

NUREG-1437, Supplement 42 B-2 October 2010 

Issue Type of Issue Finding 

Water use conflicts 

(plants with cooling 

ponds or cooling 

towers using make-up 

water from a small 

river with low flow) 

Site-specific SMALL OR MODERATE. The issue has been a concern at nuclear 

power plants with cooling ponds and at plants with cooling towers. 

Impacts on instream and riparian communities near these plants 

could be of moderate significance in some situations. See 

§ 51.53(c)(3)(ii)(A). 

Aquatic Ecology 

Refurbishment Generic SMALL. During plant shutdown and refurbishment there will be 

negligible effects on aquatic biota because of a reduction of 

entrainment and impingement of organisms or a reduced release of 

chemicals. 

Accumulation of 

contaminants in 

sediments or biota 

Generic SMALL. Accumulation of contaminants has been a concern at a 

few nuclear power plants but has been satisfactorily mitigated by 

replacing copper alloy condenser tubes with those of another metal. 

It is not expected to be a problem during the license renewal term. 

Entrainment of 

phytoplankton and 

zooplankton 

Generic SMALL. Entrainment of phytoplankton and zooplankton has not 

been found to be a problem at operating nuclear power plants and 

is not expected to be a problem during the license renewal term. 

Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at operating 

nuclear plants with once-through cooling systems, has not 

endangered fish populations or been found to be a problem at 

operating nuclear power plants with cooling towers or cooling 

ponds, and is not expected to be a problem during the license 

renewal term. 

Thermal plume barrier 

to migrating fish 

Generic SMALL. Thermal plumes have not been found to be a problem at 

operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Distribution of aquatic 

organisms 

Generic SMALL. Thermal discharge may have localized effects but is not 

expected to affect the larger geographical distribution of aquatic 

organisms. 

Premature emergence 

of aquatic insects 

Generic SMALL. Premature emergence has been found to be a localized 

effect at some operating nuclear power plants but has not been a 

problem and is not expected to be a problem during the license 

renewal term. 

Gas supersaturation 

(gas bubble disease) 

Generic SMALL. Gas supersaturation was a concern at a small number of 

operating nuclear power plants with once-through cooling systems 

but has been satisfactorily mitigated. It has not been found to be a 

problem at operating nuclear power plants with cooling towers or 

cooling ponds and is not expected to be a problem during the 

license renewal term. 

Low dissolved oxygen 

in the discharge 

Generic SMALL. Low dissolved oxygen has been a concern at one nuclear 

power plant with a once-through cooling system but has been 

effectively mitigated. It has not been found to be a problem at 

operating nuclear power plants with cooling towers or cooling ponds 

and is not expected to be a problem during the license renewal 

term. 

Losses from 

predation, parasitism, 

and disease among 

organisms exposed to 

sublethal stresses 

Generic SMALL. These types of losses have not been found to be a 

problem at operating nuclear power plants and are not expected to 

be a problem during the license renewal term. 

Stimulation of Generic SMALL. Stimulation of nuisance organisms has been satisfactorily 
Appendix B 

October 2010 B-3 NUREG-1437, Supplement 42 

Issue Type of Issue Finding 

nuisance organisms 

(e.g., shipworms) 

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. 

Aquatic Ecology (for plants with once-through and cooling pond heat dissipation systems) 

Entrainment of fish 

and shellfish in early 

life stages 

Site-specific SMALL, MODERATE, OR LARGE. The impacts of entrainment are 

small at many plants but may be moderate or even large at a few 

plants with once-through and cooling-pond cooling systems. 

Further, ongoing efforts in the vicinity of these plants to restore fish 

populations may increase the numbers of fish susceptible to intake 

effects during the license renewal period, such that entrainment 

studies conducted in support of the original license may no longer 

be valid. See § 51.53(c)(3)(ii)(B). 

Impingement of fish 

and shellfish 

Site-specific SMALL, MODERATE, OR LARGE. The impacts of impingement 

are small at many plants but may be moderate or even large at a 

few plants with once-through and cooling-pond cooling systems. 

See § 51.53(c)(3)(ii)(B). 

Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of continuing 

concerns about heat shock and the possible need to modify thermal 

discharges in response to changing environmental conditions, the 

impacts may be of moderate or large significance at some plants. 

See § 51.53(c)(3)(ii)(B). 

Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems) 

Entrainment of fish 

and shellfish in early 

life stages 

Generic SMALL. Entrainment of fish has not been found to be a problem at 

operating nuclear power plants with this type of cooling system and 

is not expected to be a problem during the license renewal term. 

Impingement of fish 

and shellfish 

Generic SMALL. The impingement has not been found to be a problem at 

operating nuclear power plants with this type of cooling system and 

is not expected to be a problem during the license renewal term. 

Heat shock Generic SMALL. Heat shock has not been found to be a problem at 

operating nuclear power plants with this type of cooling system and 

is not expected to be a problem during the license renewal term. 

Ground Water Use and Quality 

Impacts of 

refurbishment on 

ground water use and 

quality 

Generic SMALL. Extensive dewatering during the original construction on 

some sites will not be repeated during refurbishment on any sites. 

Any plant wastes produced during refurbishment will be handled in 

the same manner as in current operating practices and are not 

expected to be a problem during the license renewal term. 

Ground water use 

conflicts (potable 

and service water; 

plants that use 

<100 gpm) 

Generic SMALL. Plants using less than 100 gpm are not expected to 

cause any ground water use conflicts. 

Ground water use 

conflicts (potable and 

service water, and 

dewatering plants that 

use >100 gpm) 

Site-specific SMALL, MODERATE, OR LARGE. Plants that use more than 100 

gpm may cause ground water use conflicts with nearby ground 

water users. See § 51.53(c)(3)(ii)(C). 

Ground water use 

conflicts (plants using 

cooling towers 

Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts may result 

from surface water withdrawals from small water bodies during low 

flow conditions which may affect aquifer recharge, especially if other 
Appendix B 

NUREG-1437, Supplement 42 B-4 October 2010 

Issue Type of Issue Finding 

withdrawing make-up 

water from a small 

river) 

ground water or upstream surface water users come on line before 

the time of license renewal. See § 51.53(c)(3)(ii)(A). 

Ground water use 

conflicts (Ranney 

wells) 

Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can result in 

potential ground water depression beyond the site boundary. 

Impacts of large ground water withdrawal for cooling tower makeup 

at nuclear power plants using Ranney wells must be evaluated at 

the time of application for license renewal. See § 51.53(c)(3)(ii)(C). 

Ground water quality 

degradation (Ranney 

wells) 

Generic SMALL. Ground water quality at river sites may be degraded by 

induced infiltration of poor-quality river water into an aquifer that 

supplies large quantities of reactor cooling water. However, the 

lower quality infiltrating water would not preclude the current uses of 

ground water and is not expected to be a problem during the license 

renewal term. 

Ground water quality 

degradation (saltwater 

intrusion) 

Generic SMALL. Nuclear power plants do not contribute significantly to 

saltwater intrusion. 

Ground water quality 

degradation (cooling 

ponds in salt 

marshes) 

Generic SMALL. Sites with closed-cycle cooling ponds may degrade ground 

water quality. Because water in salt marshes is brackish, this is not 

a concern for plants located in salt marshes. 

Ground water quality 

degradation (cooling 

ponds at inland sites) 

Site-specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling 

ponds may degrade ground water quality. For plants located inland, 

the quality of the ground water in the vicinity of the ponds must be 

shown to be adequate to allow continuation of current uses. See 

§ 51.53(c)(3)(ii)(D). 

Terrestrial Ecology 

Refurbishment 

impacts 

Site-specific SMALL, MODERATE, OR LARGE. Refurbishment impacts are 

insignificant if no loss of important plant and animal habitat occurs. 

However, it cannot be known whether important plant and animal 

communities may be affected until the specific proposal is 

presented with the license renewal application. See 

§ 51.53(c)(3)(ii)(E). 

Cooling tower impacts 

on crops and 

ornamental vegetation 

Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity 

associated with cooling tower operation have not been found to be a 

problem at operating nuclear power plants and are not expected to 

be a problem during the license renewal term. 

Cooling tower impacts 

on native plants 

Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity 

associated with cooling tower operation have not been found to be a 

problem at operating nuclear power plants and are not expected to 

be a problem during the license renewal term. 

Bird collisions with 

cooling towers 

Generic SMALL. These collisions have not been found to be a problem at 

operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Cooling pond impacts 

on terrestrial 

resources 

Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all sites. 

Power line right of 

way management 

(cutting and herbicide 

application) 

Generic SMALL. The impacts of right-of-way maintenance on wildlife are 

expected to be of small significance at all sites. 

Bird collisions with Generic SMALL. Impacts are expected to be of small significance at all 
Appendix B 

October 2010 B-5 NUREG-1437, Supplement 42 

Issue Type of Issue Finding 

power lines sites. 

Impacts of 

electromagnetic fields 

on flora and fauna 

Generic SMALL. No significant impacts of electromagnetic fields on 

terrestrial flora and fauna have been identified. Such effects are not 

expected to be a problem during the license renewal term. 

Floodplains and 

wetland on power line 

right of way 

Generic SMALL. Periodic vegetation control is necessary in forested 

wetlands underneath power lines and can be achieved with minimal 

damage to the wetland. No significant impact is expected at any 

nuclear power plant during the license renewal term. 

Threatened and Endangered Species 

Threatened or 

endangered species 

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment 

and continued operation are not expected to adversely affect 

threatened or endangered species. However, consultation with 

appropriate agencies would be needed at the time of license 

renewal to determine whether threatened or endangered species 

are present and whether they would be adversely affected. See 

§ 51.53(c)(3)(ii)(E). 

Air Quality 

Air quality during 

refurbishment 

(non-attainment and 

maintenance areas) 

Site-specific SMALL, MODERATE, OR LARGE. Air quality impacts from plant 

refurbishment associated with license renewal are expected to be 

small. However, vehicle exhaust emissions could be cause for 

concern at locations in or near nonattainment or maintenance 

areas. The significance of the potential impact cannot be 

determined without considering the compliance status of each site 

and the numbers of workers expected to be employed during the 

outage. See § 51.53(c)(3)(ii)(F). 

Air quality effects of 

transmission lines 

Generic SMALL. Production of ozone and oxides of nitrogen is insignificant 

and does not contribute measurably to ambient levels of these 

gases. 

Land Use 

Onsite land use Generic SMALL. Projected onsite land use changes required during 

refurbishment and the renewal period would be a small fraction of 

any nuclear power plant site and would involve land that is 

controlled by the applicant. 

Power line right of 

way 

Generic SMALL. Ongoing use of power line right of ways would continue 

with no change in restrictions. The effects of these restrictions are 

of small significance. 

Human Health 

Radiation exposures 

to the public during 

refurbishment 

Generic SMALL. During refurbishment, the gaseous effluents would result 

in doses that are similar to those from current operation. 

Applicable regulatory dose limits to the public are not expected to 

be exceeded. 

Occupational 

radiation exposures 

during refurbishment 

Generic SMALL. Occupational doses from refurbishment are expected to 

be within the range of annual average collective doses experienced 

for pressurized-water reactors and boiling-water reactors. 

Occupational mortality risk from all causes including radiation is in 

the mid-range for industrial settings. 

Microbiological 

organisms 

(occupational health) 

Generic SMALL. Occupational health impacts are expected to be controlled 

by continued application of accepted industrial hygiene practices to 

minimize worker exposures. 

Microbiological 

organisms (public 

Site-specific SMALL, MODERATE, OR LARGE. These organisms are not 

expected to be a problem at most operating plants except possibly 
Appendix B 

NUREG-1437, Supplement 42 B-6 October 2010 

Issue Type of Issue Finding 

health)(plants using 

lakes or canals, or 

cooling towers or 

cooling ponds that 

discharge to a small 

river) 

at plants using cooling ponds, lakes, or canals that discharge to 

small rivers. Without site-specific data, it is not possible to predict 

the effects generically. See § 51.53(c)(3)(ii)(G). 

Noise Generic SMALL. Noise has not been found to be a problem at operating 

plants and is not expected to be a problem at any plant during the 

license renewal term. 

Electromagnetic 

fields – acute effects 

(electric shock) 

Site-specific SMALL, MODERATE, OR LARGE. Electrical shock resulting from 

direct access to energized conductors or from induced charges in 

metallic structures have not been found to be a problem at most 

operating plants and generally are not expected to be a problem 

during the license renewal term. However, site-specific review is 

required to determine the significance of the electric shock potential 

at the site. See § 51.53(c)(3)(ii)(H). 

Electromagnetic 

fields – chronic 

effects 

Uncategorized UNCERTAIN. Biological and physical studies of 60-Hz 

electromagnetic fields have not found consistent evidence linking 

harmful effects with field exposures. However, research is 

continuing in this area and a consensus scientific view has not 

been reached. 

Radiation exposures 

to public (license 

renewal term) 

Generic SMALL. Radiation doses to the public will continue at current 

levels associated with normal operations. 

Occupational 

radiation exposures 

(license renewal 

term) 

Generic SMALL. Projected maximum occupational doses during the license 

renewal term are within the range of doses experienced during 

normal operations and normal maintenance outages, and would be 

well below regulatory limits. 

Socioeconomic Impacts 

Housing impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are expected 

to be of small significance at plants located in a medium or high 

population area and not in an area where growth control measures 

that limit housing development are in effect. Moderate or large 

housing impacts of the workforce associated with refurbishment 

may be associated with plants located in sparsely populated areas 

or in areas with growth control measures that limit housing 

development. See § 51.53(c)(3)(ii)(I). 

Public services: 

public safety, social 

services, and 

tourism, and 

recreation 

Generic SMALL. Impacts to public safety, social services, and tourism and 

recreation are expected to be of small significance at all sites. 

Public services: 

public utilities 

Site-specific SMALL OR MODERATE. An increased problem with water 

shortages at some sites may lead to impacts of moderate 

significance on public water supply availability. See 

§ 51.53(c)(3)(ii)(I). 

Public services: 

education 

(refurbishment) 

Site-specific SMALL, MODERATE, OR LARGE. Most sites would experience 

impacts of small significance but larger impacts are possible 

depending on site- and project-specific factors. See 

§ 51.53(c)(3)(ii)(I). 

Public services: 

education (license 

renewal term) 

Generic SMALL. Only impacts of small significance are expected 
Appendix B 

October 2010 B-7 NUREG-1437, Supplement 42 

Issue Type of Issue Finding 

Offsite land use 

(refurbishment) 

Site-specific SMALL OR MODERATE. Impacts may be of moderate 

significance at plants in low population areas. See 

§ 51.53(c)(3)(ii)(I). 

Offsite land use 

(license renewal 

term) 

Site-specific SMALL, MODERATE, OR LARGE. Significant changes in land use 

may be associated with population and tax revenue changes 

resulting from license renewal. See § 51.53(c)(3)(ii)(I). 

Public services: 

transportation 

Site-specific SMALL, MODERATE, OR LARGE. Transportation impacts (level 

of service) of highway traffic generated during plant refurbishment 

and during the term of the renewed license are generally expected 

to be of small significance. However, the increase in traffic 

associated with the additional workers and the local road and traffic 

control conditions may lead to impacts of moderate or large 

significance at some sites. See § 51.53(c)(3)(ii)(J). 

Historic and 

archaeological 

resources 

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment 

and continued operation are expected to have no more than small 

adverse impacts on historic and archaeological resources. 

However, the National Historic Preservation Act requires the 

Federal agency to consult with the State Historic Preservation 

Officer to determine whether there are properties present that 

require protection. See § 51.53(c)(3)(ii)(K). 

Aesthetic impacts 

(refurbishment) 

Generic SMALL. No significant impacts are expected during refurbishment. 

Aesthetic impacts 

(license renewal 

term) 

Generic SMALL. No significant impacts are expected during the license 

renewal term. 

Aesthetic impacts of 

transmission lines 

(license renewal 

term) 

Generic SMALL. No significant impacts are expected during the license 

renewal term. 

Postulated Accidents 

Design basis 

accidents 

Generic SMALL. The NRC staff has concluded that the environmental 

impacts of design basis accidents are of small significance for all 

plants. 

Severe accidents Site-specific SMALL. The probability weighted consequences of atmospheric 

releases, fallout onto open bodies of water, releases to ground 

water, and societal and economic impacts from severe accidents 

are small for all plants. However, alternatives to mitigate severe 

accidents must be considered for all plants that have not 

considered such alternatives. See § 51.53(c)(3)(ii)(L). 

Uranium Fuel Cycle and Waste Management 

Offsite radiological 

impacts (individual 

effects from other 

than the disposal of 

spent fuel and high 

level waste) 

Generic SMALL. Off-site impacts of the uranium fuel cycle have been 

considered by the Commission in Table S-3 of this part. Based on 

information in the GEIS, impacts on individuals from radioactive 

gaseous and liquid releases including radon-222 and 

technetium-99 are small. 

Offsite radiological 

impacts (collective 

effects) 

Generic The 100 year environmental dose commitment to the U.S. 

population from the fuel cycle, high level waste and spent fuel 

disposal excepted, is calculated to be about 14,800 person rem, or 

12 cancer fatalities, for each additional 20-year power reactor 

operating term. Much of this, especially the contribution of radon 

releases from mines and tailing piles, consists of tiny doses 
Appendix B 

NUREG-1437, Supplement 42 B-8 October 2010 

Issue Type of Issue Finding 

summed over large populations. This same dose calculation can 

theoretically be extended to include many tiny doses over 

additional thousands of years as well as doses outside the U.S. 

The result of such a calculation would be thousands of cancer 

fatalities from the fuel cycle, but this result assumes that even tiny 

doses have some statistical adverse health effect which will not 

ever be mitigated (for example no cancer cure in the next thousand 

years), and that these doses projected over thousands of years are 

meaningful. However, these assumptions are questionable. In 

particular, science cannot rule out the possibility that there will be 

no cancer fatalities from these tiny doses. For perspective, the 

doses are very small fractions of regulatory limits, and even smaller 

fractions of natural background exposure to the same populations. 

Nevertheless, despite all the uncertainty, some judgment as to the 

regulatory NEPA implications of these matters should be made and 

it makes no sense to repeat the same judgment in every case. 

Even taking the uncertainties into account, the Commission 

concludes that these impacts are acceptable in that these impacts 

would not be sufficiently large to require the NEPA conclusion, for 

any plant, that the option of extended operation under 10 CFR Part 

54 should be eliminated. Accordingly, while the Commission has 

not assigned a single level of significance for the collective effects 

of the fuel cycle, this issue is considered Category 1 [Generic]. 

Offsite radiological 

impacts (spent fuel 

and high level waste 

disposal) 

Generic For the high level waste and spent fuel disposal component of the 

fuel cycle, there are no current regulatory limits for offsite releases 

of radionuclides for the current candidate repository site. However, 

if we assume that limits are developed along the lines of the 1995 

National Academy of Sciences (NAS) report, “Technical Bases for 

Yucca Mountain Standards,” and that in accordance with the 

Commission's Waste Confidence Decision, 10 CFR 51.23, a 

repository can and likely will be developed at some site which will 

comply with such limits, peak doses to virtually all individuals will be 

100 millirem per year or less. However, while the Commission has 

reasonable confidence that these assumptions will prove correct, 

there is considerable uncertainty since the limits are yet to be 

developed, no repository application has been completed or 

reviewed, and uncertainty is inherent in the models used to 

evaluate possible pathways to the human environment. The NAS 

report indicated that 100 millirem per year should be considered as 

a starting point for limits for individual doses, but notes that some 

measure of consensus exists among national and international 

bodies that the limits should be a fraction of the 100 millirem per 

year. The lifetime individual risk from 100 millirem annual dose limit 

is about 3 x 10-3. 

Estimating cumulative doses to populations over thousands of 

years is more problematic. The likelihood and consequences of 

events that could seriously compromise the integrity of a deep 

geologic repository were evaluated by the Department of Energy in 

the "Final Environmental Impact Statement: Management of 

Commercially Generated Radioactive Waste," October 1980. The 

evaluation estimated the 70-year whole-body dose commitment to 

the maximum individual and to the regional population resulting 

from several modes of breaching a reference repository in the year 

of closure, after 1,000 years, after 100,000 years and after 

100,000,000 years. Subsequently, the NRC and other federal 

agencies have expended considerable effort to develop models for 

the design and for the licensing of a high level waste repository, 

especially for the candidate repository at Yucca Mountain. More 

meaningful estimates of doses to population may be possible in the 
Appendix B 

October 2010 B-9 NUREG-1437, Supplement 42 

Issue Type of Issue Finding 

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 

amount of radioactive material released over 10,000 years. The 

cumulative release limits are based on EPA's population impact 

goal of 1,000 premature cancer deaths worldwide for a 100,000 

metric ton (MTHM) repository. 

Nevertheless, despite all the uncertainty, some judgment as to the 

regulatory NEPA implications of these matters should be made and 

it makes no sense to repeat the same judgment in every case. 

Even taking the uncertainties into account, the Commission 

concludes that these impacts are acceptable in that these impacts 

would not be sufficiently large to require the NEPA conclusion, for 

any plant, that the option of extended operation under 10 CFR Part 

54 should be eliminated. Accordingly, while the Commission has 

not assigned a single level of significance for the impacts of spent 

fuel and high level waste disposal, this issue is considered in 

Category 1 [Generic]. 

Nonradiological 

impacts of the 

uranium fuel cycle 

Generic SMALL. The nonradiological impacts of the uranium fuel cycle 

resulting from the renewal of an operating license for any plant are 

found to be small. 

Low-level waste 

storage and disposal 

Generic SMALL. The comprehensive regulatory controls that are in place 

and the low public doses being achieved at reactors ensure that the 

radiological impacts to the environment will remain small during the 

term of a renewed license. The maximum additional 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 low-level waste disposal 

capacity will be made available when needed for facilities to be 

decommissioned consistent with NRC decommissioning 

requirements. 

Mixed waste storage 

and disposal 

Generic SMALL. The comprehensive regulatory controls and the facilities 

and procedures that are in place ensure proper handling and 

storage, as well as negligible doses and exposure to toxic materials 

for the public and the environment at all plants. License renewal 

will not increase the small, continuing risk to human health and the 

environment posed by mixed waste at all plants. The radiological 

and nonradiological environmental impacts of long-term disposal of 

mixed waste from any individual plant at licensed sites are small. 

In addition, the Commission concludes that there is reasonable 

assurance that sufficient mixed waste disposal capacity will be 
Appendix B 

NUREG-1437, Supplement 42 B-10 October 2010 

Issue Type of Issue Finding 

made available when needed for facilities to be decommissioned 

consistent with NRC decommissioning requirements. 

On-site spent fuel Generic SMALL. The expected increase in the volume of spent fuel from an 

additional 20 years of operation can be safely accommodated on 

site with small environmental effects through dry or pool storage at 

all plants if a permanent repository or monitored retrievable storage 

is not available. 

Nonradiological 

waste 

Generic SMALL. No changes to generating systems are anticipated for 

license renewal. Facilities and procedures are in place to ensure 

continued proper handling and disposal at all plants. 

Transportation Generic SMALL. The impacts of transporting spent fuel enriched up to 5 

percent uranium-235 with average burnup for the peak rod to 

current levels approved by NRC up to 62,000 MWd/MTU and the 

cumulative impacts of transporting high-level waste to a single 

repository, such as Yucca Mountain, Nevada are found to be 

consistent with the impact values contained in 10 CFR 51.52(c), 

Summary Table S–4 – Environmental Impact of Transportation of 

Fuel and Waste to and from One Light-Water-Cooled Nuclear 

Power Reactor. If fuel enrichment or burnup conditions are not 

met, the applicant must submit an assessment of the implications 

for the environmental impact values reported in § 51.52. 

Decommissioning 

Radiation doses Generic SMALL. Doses to the public will be well below applicable 

regulatory standards regardless of which decommissioning method 

is used. Occupational doses would increase no more than 1 

man-rem caused by buildup of long-lived radionuclides during the 

license renewal term. 

Waste management Generic SMALL. Decommissioning at the end of a 20-year license renewal 

period would generate no more solid wastes than at the end of the 

current license term. No increase in the quantities of Class C or 

greater than Class C wastes would be expected. 

Air quality Generic SMALL. Air quality impacts of decommissioning are expected to be 

negligible either at the end of the current operating term or at the 

end of the license renewal term. 

Water quality Generic SMALL. The potential for significant water quality impacts from 

erosion or spills is no greater whether decommissioning occurs 

after a 20-year license renewal period or after the original 40-year 

operation period, and measures are readily available to avoid such 

impacts. 

Ecological resources Generic SMALL. Decommissioning after either the initial operating period 

or after a 20-year license renewal period is not expected to have 

any direct ecological impacts. 

Socioeconomic 

impacts 

Generic SMALL. Decommissioning would have some short-term 

socioeconomic impacts. The impacts would not be increased by 

delaying decommissioning until the end of a 20-year relicense 

period, but they might be decreased by population and economic 

growth. 

Environmental Justice 

Environmental 

Justice 

Uncategorized NONE. The need for and the content of an analysis of 

environmental justice will be addressed in plant-specific reviews. 
APPENDIX C. 

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 

October 2010 C-1 NUREG-1437, Supplement 42 

C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 

Table C-1 lists environmental authorizations for current Duane Arnold Energy Center (DAEC) 

operations. In this context “authorizations” includes any permits, licenses, approvals, or other 

entitlements. FPL Energy Duane Arnold, LLC (FPL-DA) expects to continue renewing these 

authorizations during the current license period and through the U.S. Nuclear Regulatory 

Commission (NRC) license renewal period. 

Table C-2 lists additional environmental authorizations and consultations related to FPL-DA 

renewal of the DAEC license to operate. As indicated, FPL-DA anticipates needing relatively 

few such authorizations and consultations. Sections C.1 through C.5 discuss some of these 

items in more detail. 

C.1. HISTORIC PRESERVATION 

Under Section 106 of the National Historic Preservation Act (16 USC 470 et seq.), federal 

agencies having the authority to license any undertaking, prior to issuing the license, shall take 

into account the effect of the undertaking on historic properties and shall afford the Advisory 

Committee on Historic Preservation an opportunity to comment on the undertaking. Committee 

regulations provide for establishing an agreement with any State Historic Preservation Officer 

(SHPO) to substitute state review for Committee review (35 CFR 800.7). The results of this 

review are presented in Chapter 4. 

C.2. THREATENED OR ENDANGERED SPECIES 

Pursuant to Section 7 of the Endangered Species Act (16 USC 1531 et seq.), federal agencies 

are required to ensure that agency action is not likely to jeopardize any species that is listed or 

proposed for listing as endangered or threatened. Depending on the action involved, the Act 

requires consultation with the U.S. Fish and Wildlife Service (FWS) regarding effects on nonmarine species, the National Marine Fisheries Service (NMFS) for marine species, or both. 

FWS and NMFS have issued joint procedural regulations at 50 CFR 402, Subpart B, that 

address consultation, and FWS maintains the joint list of threatened and endangered species at 

50 CFR 17. An assessment of the effects on threatened or endangered species is presented in 

Chapter 4. 

C.3. WATER QUALITY (401) CERTIFICATION 

Under the Federal Clean Water Act, Section 401, applicants for a federal license to conduct an 

activity that might result in a discharge into navigable waters are required to provide the 

licensing agency a certification from the state that the discharge will comply with applicable 

Clean Water Act requirements (33 USC 1341). NRC has indicated in its Generic Environmental 

Impact Statement for License Renewal of Nuclear Power Plants (GEIS) that issuance of a 

National Pollutant Discharge Elimination System (NPDES) permit implies certification by the 

state (NRC 1996e). The U.S. Environmental Protection Agency granted the State of Iowa 

authority to issue NPDES permits. FPL-DA is applying to NRC for license renewal to continue 

DAEC operations. Hydrological Impacts are presented in Chapter 4. 
Appendix C 

NUREG-1437, Supplement 42 C-2 October 2010 

C.4. COASTAL ZONE MANAGEMENT PROGRAM COMPLIANCE 

The Federal Coastal Zone Management Act (16 USC 1451 et seq.) imposes requirements on 

applicants for a federal license to conduct an activity that could affect a state’s coastal zone. 

The Act requires an applicant to certify to the licensing agency that the proposed activity would 

be consistent with the state’s federally approved coastal zone management program [16 USC 

1456(c)(3)(A)]. The National Oceanic and Atmospheric Administration has promulgated 

implementing regulations indicating that the requirement is applicable to renewal of federal 

licenses for activities not previously reviewed by the state [15 CFR 930.51(b)(1)]. The 

regulation requires that the license applicant provide its certification to the federal licensing 

agency and a copy to the applicable state agency [15 CFR 930.57(a)]. Iowa is not included in 

the coastal zone management program and therefore this requirement is not applicable to 

DAEC. 
Appendix C 

October 2010 C-3 NUREG-1437, Supplement 42 

Table C-1. Environmental Authorizations for Current DAEC Operations 

Agency Authority Requirement Issuance or 

Expiration Date 

Federal and State Requirements

U.S. Nuclear Regulatory 

Commission

Atomic Energy Act 

(42 USC 2011, et 

seq.), 10 CFR 50.10

License to operate Issued: 02/21/1974 

Expires: 02/21/2014

U.S. Department of 

Transportation

49 USC 5108 Registration Issued: 07/09/2008 

Expires: 06/30/2011

U.S. Environmental 

Protection Agency

Federal Resource 

Conservation and 

Recovery Act 

(42 USC 6912)

Notification of 

Regulated Waste 

Activity

N/A 

Iowa Department of 

Natural Resources

Code of Iowa 455B 

and IAC 567:71

Permit for water 

intake and discharge 

structures and low 

head dam on Cedar 

River

Issued: 08/06/1971 

No expiration date

Iowa Department of 

Natural Resources 

Code of Iowa 455B 

and IAC 567:50-51 

Permit to store water 

in Pleasant Creek 

Reservoir and 

withdraw water from 

Cedar River

Issued: 03/14/2004 

Expires:03/13/2014

Iowa Department of 

Natural Resources 

Clean Water Act 

Section 401 

(33 U.S.C. 1341)

Water Quality 

Certification

Issued: 08/26/2005 

No expiration date

U.S. Army Corps of 

Engineers

Rivers and Harbors 

Act of 1899 Section 

10 (33 U.S.C. 403) 

Clean Water Act 

Section 404 (33 

U.S.C. 1344) 

Marine Protection, 

Research and 

Sanctuaries Act of 

1972 Section 103 

(33 U.S.C. 1413)

Dredging Permit Issued: 09/20/2005 

Expires: 12/31/2010 

Linn County Linn County Flood 

Plain Management 

Regulations 

Flood Plain 

Development Permit 

Issued: 12/04/2007 

One time event, not 

renewed 

Iowa Department of 

Natural Resources 

Code of Iowa Chapter 

461A

Sovereign Lands 

Construction Permit 

Issued: 10/10/2006 

One time event, not 

renewed 

Iowa Department of 

Natural Resources 

Code of Iowa Chapter 

461A

Sovereign Lands 

Construction Permit 

Issued: 11/07/2007 

One time event, not 

renewed
Appendix C 

NUREG-1437, Supplement 42 C-4 October 2010 

Agency Authority Requirement Issuance or 

Expiration Date 

Iowa Department of 

Natural Resources 

Code of Iowa 455B 

and IAC 567:50-51 

Operator certification Issued: 08/29/2007 

Expires: 06/30/2011

Iowa Department of 

Natural Resources 

Clean Water Act (33 

USC Section 1251 et 

seq.), Iowa Code 

455B.174, IAC 

567-64.3

NPDES Permit Issued: 07/06/2007 

Application is under 

review for renewal. 

Linn County Federal Clean Air Act 

(42 USC 7661-7671), 

Iowa Code 455B:567, 

IAC 20-31, LCCO 

10.5 

Air Operation Permit Expires 10/1/2010 

Renewal in progress

Iowa Department of 

Public Health

Iowa Homeland 

Security Emergency 

Management 

Transportation 

Service License 

Issued: 06/9/2009 

Expires: 06/30/2011

Iowa Department of 

Natural Resources 

Code of Iowa Chapter 

455B and part 567 

Permit to operate 

public water system 

Issued: 9/16/2009 

Expires: 12/31/2012

Iowa Department of 

Natural Resources 

Code of Iowa 455B 

and IAC 567:50-51 

Permit to operate 

4-well system for 

potable water 

Issued: 07/01/2002 

Expires: 06/30/2012

Tennessee Department 

of Environment and 

Conservation

Tennessee Code 

Annotated 68-202-206 

License to ship 

Radioactive material 

Expires: 12/31/2010

Utah Department of 

Environmental Quality 

Utah Rule 313-26 License to ship 

Radioactive material 

Expires: 11/24/2010

NA- Not Applicable NRC – Nuclear Regulatory Commission US- United States Code IAC – Iowa Administrative Code LCCO 

– Linn County Code of Ordinances NPDES – National Pollutant Discharge Elimination System UST – Underground Storage 

Tank
Appendix C 

October 2010 C-5 NUREG-1437, Supplement 42 

Table C-2. Environmental Authorizations for DAEC License Renewal 

Agency Authority Requirement Remarks

U.S. Nuclear Regulatory 

Commission 

Atomic Energy Act 

(42 USC 2011 et seq.) 

License renewal Environmental Report 

submitted in support 

of license renewal 

Application

U.S. Fish and Wildlife 

Service

Endangered Species 

Act Section 7 

(16 USC 1536)

Consultation Requires federal 

agency issuing a 

license to consult with 

the FWS (Appendix 

C) 

Iowa Department of 

Natural Resources

Endangered and 

Threatened Species 

Laws (State Statute 

29.604 & 

Administrative Rule 

NR 27)

Endangered 

Resources Review

Review explains what 

rare species, natural 

communities, or 

natural features 

tracked in the Natural 

Heritage Inventory 

database are found in 

or near the proposed 

project area. And any 

additional steps to 

assure compliance 

with the Iowa 

endangered species 

protection laws and 

regulations. 

(Attachment C) 

Iowa Department of 

Natural Resources

Clean Water Act 

Section 401 

(33 USC 1341)

Certification Requires State 

certification that 

proposed action 

would comply with 

Clean Water Act 

standards

Iowa Historic 

Preservation Office

National Historic 

Preservation Act 

Section 106 

(16 USC 470f)

Consultation Requires federal 

agency issuing a 

license to consider 

cultural impacts and 

consult with State 

Historic Preservation 

Officer (Attachment D) 

APPENDIX D. 

CONSULTATION CORRESPONDENCE

October 2010 D-1 NUREG-1437, Supplement 42 

D. CONSULTATION CORRESPONDENCES 

The Endangered Species Act of 1973, as amended, the Magnuson-Stevens Fisheries 

Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 

require that Federal agencies consult with applicable State and Federal agencies and groups 

prior to taking action that may affect threatened and endangered species, essential fish habitat, 

or historic and archaeological resources, respectively. This appendix contains consultation 

documentation. 

Table D-1 provides a list of the consultation documents sent between the U.S. Nuclear 

Regulatory Commission (NRC) and applicable agencies. 

Table D-1. Consultation Correspondences. This is a list of the consultation documents sent 

between the NRC and other agencies we are required to consult with based on NEPA 

requirements.(a) 

Author Recipient Date of Letter 

U.S. Nuclear Regulatory Commission Iowa Department of Natural Resources (W. 

Gieselman) 

May 6, 2009 

(ML091200651) 

U.S. Nuclear Regulatory Commission National Oceanographic and Atmospheric 

Administration, National Marine Fisheries 

Service (R. Crabtree) 

May 6, 2009 

(ML091210025) 

U.S. Nuclear Regulatory Commission U.S. Fish and Wildlife Service, Region 3 

(T. Melius) 

May 6, 2009 

(ML091210033) 

U.S. Nuclear Regulatory Commission Iowa Office of the State Archaeologist, 

State Archaeologist (J. Doershuck) 

May 7, 2009 

(ML091210024) 

U.S. Nuclear Regulatory Commission Advisory Council on Historic Preservation 

(C. D. Vaughn) 

May 7, 2009 

(ML091210066) 

U.S. Nuclear Regulatory Commission Historic Preservation Officer State 

Historical Society of Iowa (J. Thompson) 

May 7, 2009 

(ML091210015) 

Iowa Department of Natural Resources U.S. Nuclear Regulatory Commission May 18, 2009 

(ML092020069) 

U.S. Fish and Wildlife Service U.S. Nuclear Regulatory Commission May 29, 2009 

(ML092020070) 

U.S. Nuclear Regulatory Commission ITC Midwest, LLC 

(M. McNulty) 

September 28, 2009 

(ML092470449) 

Iowa State Archaeologist U.S. Nuclear Regulatory Commission February 15, 2010 

(ML102560486) 

U.S. Nuclear Regulatory Commission Historic Preservation Officer State 

Historical Society of Iowa (J. Thompson) 

February 3, 2010 

(ML093430184) 

U.S. Nuclear Regulatory Commission US Environmental Protection Agency February 3, 2010 

(ML093430204) 

US Environmental Protection Agency U.S. Nuclear Regulatory Commission April 16, 2010 

(ML101120600) 
Appendix D 

NUREG-1437, Supplement 42 D-2 October 2010 

Author Recipient Date of Letter 

Iowa State Historic Preservation Office U.S. Nuclear Regulatory Commission May 27, 2010 

(ML102570737 

Iowa State Historic Preservation Office U.S. Nuclear Regulatory Commission June 3, 2010 

(ML102560510) 

Iowa State Historic Preservation Office U.S. Nuclear Regulatory Commission June 14, 2010 

ML102560518) 

(a) Correspondence was also sent to nineteen Native American Tribes listed in Section 1.8. 
Appendix D 

October 2010 D-3 NUREG-1437, Supplement 42 

D.1. Consultation Correspondence 

The following pages contain copies of the letters listed in Table D-1. 
Appendix D 

NUREG-1437, Supplement 42 D-4 October 2010 
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October 2010 D-5 NUREG-1437, Supplement 42 
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October 2010 D-63 NUREG-1437, Supplement 42 

Note: This letter was forwarded to the NRC from Iowa State Historic Preservation Office 
Appendix D 

NUREG-1437, Supplement 42 D-64 October 2010 
APPENDIX E. 

CHRONOLOGY OF ENVIRONMENTAL REVIEW 

October 2010 E-1 NUREG-1437, Supplement 42 

E. CHRONOLOGY OF ENVIRONMENTAL REVIEW 

CORRESPONDENCE 

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and external parties as part of its environmental review for 

license renewal of the Duane Arnold Energy Center. All documents, with the exception of those 

containing proprietary information are available electronically from the NRC’s Public Electronic 

Reading Room found on the Internet at the following Web address: http://www.nrc.gov/readingrm.html. From this site, the public can gain access to the NRC’s Agencywide Document Access 

and Management System (ADAMS), which provides text and image files of NRC’s public 

documents in ADAMS. The ADAMS accession number for each document is included below. 

E.1. Environmental Review Correspondence 

September 30, 2008 Application submitted by FPL Energy Duane Arnold, LLC (FPL-DA) 

for renewal of Facility Operating License No. DPR-49 for an 

additional 20 years of operation at Duane Arnold Energy Center 

(DAEC). (Accession No. ML082980481) 

February 10, 2009 United States Nuclear Regulatory Commission (NRC) issued 

“United states nuclear regulatory commission Notice of acceptance 

for docketing of the application and notice of opportunity for hearing 

regarding renewal of facility operating license no. DPR-49 for an 

additional 20-year period, Duane arnold energy center docket no. 

50-331.” (Accession No. ML090140399) 

March 24, 2009 NRC issued Notice of Intent to prepare an environmental Impact 

statement and conduct scoping process, Docket no. 50-331. 

(Accession No. ML090140399) 

May 6, 2009 Consultation letter to Robyn Thorson, Regional Director Region 3, 

U.S. Fish and Wildlife Service “Request For List Of Protected 

Species within the Area Under Evaluation For The Duane Arnold 

Energy Center License Renewal Application Review.” (Accession 

No. ML091200651) 

May 6, 2009 Consultation letter to Wayne Gieselman, Administrator Iowa 

Department of Natural Resources “Request For List Of Protected 

Species And Water Usage Impacts Within The Area Under 

Evaluation For The Duane Arnold Energy Center License Renewal 

Application Review.” (Accession No. ML091200651) 

May 6, 2009 Dr. Roy Crabtree, NOAA National Marine Fisheries Service 

“Request for List of Protected Species and Essential Fish Habitat 

Within the Area Under Evaluation for the Duane Arnold Energy 

Center License Renewal Application Review. (ML0912100252) 
Appendix E 

NUREG-1437, Supplement 42 E-2 October 2010 

May 6, 2009 Mr. Tom Melius, Regional Director, Region 3, U.S. Fish and Wildlife 

Service “Request for List of Protected Species Within the Area 

Under Evaluation tor the Duane Arnold Energy Center License 

Renewal Application Review” (Accession No. ML0912100331) 

May 6, 2009 Letter to Christie Modlin, Chairperson Iowa Tribe of Oklahoma 

inviting them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 

May 7, 2009 Consultation letter to Charlene Dwin Vaughn, Assistant Director 

Federal Permitting, Licensing, and Assistance Section Advisory 

Council on Historic Preservation. (Accession No. ML091210066) 

May 7, 2009 Consultation letter to John Doershuck State Archaeologist Office of 

the State Archaeologist. (Accession No. ML0912100240) 

May 7, 2009 Consultation letter to Mr. Jerome Thompson, Interim-SHPO, State 

Historical Society of Iowa. (Accession No. ML 0912100150) 

May 14, 2009 George Thurman, Principal Chief Sac and Fox Nation of Oklahoma 

inviting them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to Fredia Perkins, Chairperson Sac and Fox Nation of 

Missouri inviting them to participate in the scoping process related 

to NRC’s environmental review of the license application for the 

Duane Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to Steve Ortiz, Chairman Prairie Band of Potawatomi Indians 

inviting them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to Joshua Weston, President Flandreau Santee Sioux Tribe 

inviting them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to Mr. Roger Trudell, Chairman Santee Sioux Nation inviting 

them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to John Blackhawk, Chairman Winnebago Tribe of Nebraska 

inviting them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 
Appendix E 

October 2010 E-3 NUREG-1437, Supplement 42 

May 14, 2009 Letter to Ronald Johnson, President Prairie Island Indian 

Community inviting them to participate in the scoping process 

related to NRC’s environmental review of the license application for 

the Duane Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to Stanley R. Crooks, Chairman Shakopee Mdewakanton 

Sioux Community of Minnesota inviting them to participate in the 

scoping process related to NRC’s environmental review of the 

license application for the Duane Arnold Energy Center.” 

(Accession No. ML0913400566) 

May 14, 2009 Letter to Kevin Jensvold, Chairman Upper Sioux Community of 

Minnesota inviting them to participate in the scoping process 

related to NRC’s environmental review of the license application for 

the Duane Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to Wilfred Cleveland, President Ho-Chunk Nation inviting 

them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0913400566) 

May 14, 2009 Letter to The Sac and Fox Tribe of the Mississippi: Adrian 

Pushetonequa, Chairman inviting them to participate in the scoping 

process related to NRC’s environmental review of the license 

application for the Duane Arnold Energy Center. (Accession No. 

ML0913400566) 

May 26, 2009 Mr. Richard L. Anderson, Vice President Duane Arnold Energy 

Center, FPL Energy Duane Arnold, LLC, “Request for Additional 

Information Regarding Severe Accident Mitigation Alternatives for 

Duane Arnold Energy Center (TAC NO. MD9770).” (Accession No. 

ML0913803131) 

May 26, 2009 Letter to Lori Nelson, Acting Lower Sioux Indian Community of 

Minnesota inviting them to participate in the scoping process 

related to NRC’s environmental review of the license application for 

the Duane Arnold Energy Center. (Accession No. ML0914001451) 

May 26, 2009 Letter to Amen Sheriden, Chairman Omaha Tribal Council inviting 

them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0914001451) 

May 26, 2009 Letter to Marlon E. Frye, Chairman Kickapoo Tribe of Oklahoma 

inviting them to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0914001451) 
Appendix E 

NUREG-1437, Supplement 42 E-4 October 2010 

May 26, 2009 Letter to John Shotton Otoe-Missouria Tribe of Indians inviting them 

to participate in the scoping process related to NRC’s 

environmental review of the license application for the Duane 

Arnold Energy Center. (Accession No. ML0914001451) 

May 26, 2009 Letter to Leon Campbell, Chairman Iowa Tribe of Kansas and 

Nebraska inviting them to participate in the scoping process related 

to NRC’s environmental review of the license application for the 

Duane Arnold Energy Center. (Accession No. ML0914001451) 

July 17, 2009 Summary of public license renewal overview and environmental 

scoping meetings related to the review of the Duane Arnold Energy 

Center license renewal application (TAC No. MD 9770). 

(Accession No. ML0919100122) 

April 17, 2010 

July 21, 2009 

Letter from W. L. Taylor and P.M Taylor of the Sierra Club Iowa 

Chapter, providing NRC with comments on the draft supplemental 

environmental impact statement (SEIS) for license renewal of 

Duane Arnold Energy Center. 

Letter from Richard C. Nelson, U.S. Fish and Wildlife Service, 

providing a list of threatened and endangered species that may, 

occur on or near the site of the Duane Arnold Energy Center 

(Accession No. ML092020070). 

July 21, 2009 Letter from Inga Foster, Iowa State Department of Natural 

Resources indicating it had completed its review of the proposed 

license renewal of the Duane Arnold Energy Center. The letter 

indicated that the department had no concerns with respect to 

water usage for the proposed license renewal application. 

(Accession No. ML092020069) 

August 7, 2009 Issuance of environmental scoping summary report associated with 

the staff’s review of the application for renewal of the operating 

license. (Accession No. ML0920301850) 

September 28, 2009 Letter from NRC to Mr. Michael McNulty, ITC Midwest, LLC. The 

letter notified ITC that the NRC has indentified 12 historic and 

archaeological sites within the transmission corridor for the 

proposed license renewal project so that ITC can take the 

appropriate measures to consider these sites. (Accession No. 

ML092470449) 

February 3, 2010 Letter from NRC to Mr. Costanzo, Vice President of Florida Power 

& Light, notifying him of the availability of the draft supplemental 

environmental impact Statement for license renewal of the Duane 

Arnold Energy Center. (Accession No. ML093430112) 

February 3, 2010 Public notice of availability of the draft supplemental environmental 

impact statement for license renewal of Duane Arnold Energy 

Center. (Accession No. ML093430112) 
Appendix E 

October 2010 E-5 NUREG-1437, Supplement 42 

February 3, 2010 Letter from NRC to Mr. Jerome Thompson, State Historic 

Preservation Officer, requesting comments on the draft 

supplemental environmental impact statement for license renewal 

of Duane Arnold Energy Center. (Accession No. ML093430184) 

February 3, 2010 

February 15, 2010 

Letter from NRC to the U.S. Environmental Protection Agency 

requesting comments on the draft supplemental environmental 

impact statement for license renewal of Duane Arnold Energy 

Center. (Accession No. ML093430204) 

Email from J. Doershuk, State Archaeologist for Iowa to C. 

Eccleston, providing cultural resource comments on the review of 

the draft SEIS. (Accession No. ML102560486) 

April 16, 2010 

May 27, 2010 

June 3, 2010 

June 14, 2010 

Letter from Ronald F. Hammerschmidt, Environmental Protection 

Agency, providing NRC with comments on the draft supplemental 

environmental impact statement for license renewal of Duane 

Arnold Energy Center. (Accession No. ML101120600) 

Email from D. Jones, Iowa State Historic Preservation Officer, to C. 

Eccleston, providing additional comments and clarification 

regarding cultural resource section of the draft SEIS. (Accession 

No. ML102570737) 

Email from D. Jones (State Historic Preservation Officer) to Herb 

Giorgio (DAEC), dated 12/17/2009. Correspondence was 

forwarded to the NRC on June 3, 2010. The letter states that no 

historic properties would be affected for a proposed project in the 

SE corner of the DAEC property. (Accession No. ML102560510) 

Email from D. Jones, Iowa State Historic Preservation Officer, to C. 

Eccleston, providing final clarification regarding cultural resources 

issues described in the draft SEIS. (Accession No. ML102560518) 

APPENDIX F. 

U.S. NUCLEAR REGULATORY COMMISSION STAFF 

EVALUATION OF SEVERE ACCIDENT MITIGATION 

ALTERNATIVES FOR DUANE ARNOLD ENERGY CENTER IN 

SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW 

October 2010 F-1 NUREG-1437, Supplement 42 

F. U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 

OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR DUANE 

ARNOLD ENERGY CENTER IN SUPPORT OF LICENSE RENEWAL 

APPLICATION REVIEW 

F.1. Introduction 

FPL Energy Duane Arnold, (FPL-DA) submitted an assessment of severe accident mitigation 

alternatives (SAMAs) for the Duane Arnold Energy Center (DAEC) as part of the environmental 

report (ER) (FPL-DA, 2008). Supplemental information on the SAMA assessment was provided 

in response to a U.S. Nuclear Regulatory Commission (NRC) staff request (FPL-DA, 2009). 

This assessment was based on the most recent DAEC probabilistic risk assessment (PRA) 

available at that time, a plant-specific offsite consequence analysis using the MELCOR Accident 

Consequence Code System 2 (MACCS2) computer code, and insights from the DAEC 

individual plant examination (IPE) (IELP, 1992) and individual plant examination of external 

events (IPEEE) (IES, 1995a). In identifying and evaluating potential SAMAs, FPL-DA 

considered SAMAs that addressed the major contributors to core damage frequency (CDF) as 

well as SAMA candidates for other operating plants that have submitted license renewal 

applications. FPL-DA initially identified 166 potential SAMAs. This list was reduced to 24 

unique SAMA candidates by eliminating SAMAs that: are not applicable to DAEC due to design 

differences, have already been implemented at DAEC, are similar in nature and could be 

combined with another SAMA candidate, or have excessive implementation cost. FPL-DA 

assessed the costs and benefits associated with each of the potential SAMAs and concluded in 

the ER that several of the candidate SAMAs evaluated are potentially cost-beneficial. 

Based on a review of the SAMA assessment, the NRC staff issued a request for additional 

information (RAI) to FPL-DA by letter dated June 25, 2009 (NRC, 2009a) and a request for RAI 

response clarification by letter dated August 24, 2009 (NRC, 2009b). Key questions concerned: 

the dominant contributors to CDF; clarification to the historical development of the Level 1 PRA; 

source term and release time category assignment assumptions used in the Level 2 and Level 3 

analyses; additional details on the seismic and fire risk assessment models and their results; 

further information on the selection and screening of SAMA candidates; and further information 

on the cost benefit analysis of several specific candidate SAMAs and low cost alternatives. 

FPL-DA (under the name of NextEra Energy Duane Arnold, LLC) submitted additional 

information by letters dated July 9, 2009 (NextEra, 2009a) and September 23, 2009 

(NextEra, 2009b). Corrections to the license renewal application were contained in an 

amendment to the application dated September 30, 2009 (NextEra, 2009c). In the responses, 

FPL-DA provided: a listing of the contribution to CDF by initiating an event and a tabulation of 

risk reduction worth (RRW) importance; clarification of PRA revision dates and CDF results; a 

discussion of the Level 2 analysis and the process for assigning severe accident source terms 

and binning release categories; further details on the external events PRA models, their results, 

and the potential for additional SAMAs based on these results; further support for the screening 

of certain SAMA candidates; and additional information regarding several specific SAMAs. The 

licensee’s responses addressed the NRC staff’s concerns and resulted in the identification of 

one. 
Appendix F 

NUREG-1437, Supplement 42 F-2 October 2010 

F.2. Estimate of Risk for Duane Arnold Energy Center 

FPL-DA’s estimates of offsite risk at DAEC are summarized in Section F.2.1. The summary is 

followed by the NRC staff’s review of FPL-DA’s risk estimates in Section F.2.2. 

F.2.1 FPL-DA’s Risk Estimates 

Two distinct analysis are combined to form the basis for the risk estimates used in the SAMA 

analysis: (1) the DAEC Level 1 and 2 PRA model, which is an updated version of the IPE 

(IELP, 1992), and (2) a supplemental analysis of offsite consequences and economic impacts 

(essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The SAMA 

analysis is based on the most recent DAEC Level 1 and Level 2 PRA models available at the 

time of the ER, referred to as the DAEC PRA (Revision 5C, July 2007 model). While FPL-DA 

states that the scope of the current DAEC Level 1 PRA includes external (fire and seismic) 

events, the SAMA analysis did not explicitly include the external events models for identifying 

SAMAs or evaluating the benefit of SAMAs. FPL-DA stated that fire and seismic models were 

not explicitly included in determining the benefit of a SAMA because Level 2 models were not 

available for external events; thus risk impacts could not be determined for these events 

(NextEra, 2009a). 

The baseline CDF for the purpose of the SAMA evaluation is approximately 1.08 × 10-5 per year. 

The CDF is based on the risk assessment for internally initiated events. FPL-DA did not 

explicitly include the contribution from external events within the DAEC risk estimates; however, 

it did account for the potential risk reduction benefits associated with external events by 

multiplying the estimated benefits for internal events by a factor of 1.57. This is discussed 

further in Sections F.2.2 and F.6.2. 

The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, 

events initiated by loss of offsite power and other transients (turbine trip, main steam isolation 

valve (MSIV) closure and inadvertent open relief valve) are the dominant contributors to the 

CDF. Although not reported separately, station blackout (SBO) sequences account for 34 

percent of the CDF, and anticipated transient without scram (ATWS) sequences account for 29 

percent of the CDF. Internal floods contribute less than 1 percent of the CDF (NextEra, 2009a). 
Appendix F 

October 2010 F-3 NUREG-1437, Supplement 42 

Table F-1. Duane Arnold Energy Center Core Damage Frequency for Internal Events 

Initiating Event CDF(a) 

(per year) 

Percent Contribution 

to CDF 

Loss of Offsite Power 4.0 × 10–6 37 

Turbine Trip with Bypass 1.6 × 10–6 15 

MSIV Closure 1.4 × 10–6 13 

Inadvertent Open Relief Valve 1.2 × 10–6 11 

Loss of Condenser Vacuum 5.9 × 10–7 6 

Div 2 125 Volt DC Bus Failure 3.2 × 10–7 3 

Manual shutdown 2.8 × 10–7 3 

Loss of River Water Supply 2.8 × 10–7 3 

Small loss of coolant accident (LOCA) 2.7 × 10–7 3 

Loss of Feedwater 2.5 × 10–7 2 

Medium LOCA 1.9 × 10–7 2 

Div 1 125 Volt DC Bus Failure 1.3 × 10–7 1 

Others (less than 1 percent each) 2.8 × 10–7 3 

Total CDF (internal events)(b) 1.08 × 10–5 100 

(a) Based on percent contribution from ER (NextEra, 2009a) and total CDF 

(b) Column totals may be different due to round off 

The Level 2 DAEC PRA model that forms the basis for the SAMA evaluation is essentially the 

original IPE Level 2 model applied to the revised Level 1 model. The Level 2 model utilizes 

three containment event trees (CETs) containing both phenomenological and systemic events. 

The Level 1 core damage sequences are binned into accident classes which provide the 

interface between the Level 1 and Level 2 CET analysis. The CETs are linked directly to the 

Level 1 event trees and CET nodes are evaluated using supporting fault trees. 

The result of the Level 2 PRA is a set of 12 release categories, also referred to as source term 

categories (STCs), with their respective frequency and release characteristics. The results of 

this analysis for DAEC are provided in Table 3.4.3-2 of Appendix F to the ER (FPL-DA, 2008). 

The frequency of each release category was obtained by summing the frequency of the 

individual accident progression CET endpoints binned into the release category. Source terms 

were developed for each of the 12 release categories using the results of Modular Accident 

Analysis Program (MAAP 3.0B) computer code calculations. 

The offsite consequences and economic impact analyses use the MACCS2 code to determine 

the offsite risk impacts on the surrounding environment and general public. Inputs for these 

analyses include plant-specific and site-specific input values for core radionuclide inventory, 

source term and release characteristics, site meteorological data, projected population 

distribution (within a 50-mile radius) for the year 2040, emergency response evacuation 

modeling, and economic data. The core radionuclide inventory corresponds to the end-of-cycle 

values for DAEC accounting for the 2007 plant power upgrade to 1,912 (megawatt-thermal 

(MWt) and reflects the expected fuel management and burnup during the license renewal period 

(NextEra, 2009a). The magnitude of the onsite impacts (in terms of clean-up and 

decontamination costs and occupational dose) is based on information provided in 

NUREG/BR-0184 (NRC, 1997a). 
Appendix F 

NUREG-1437, Supplement 42 F-4 October 2010 

In the ER, FPL-DA estimated the dose to the population within 50-miles (80-km) of the DAEC 

site to be approximately 19.8 person-roentgen equivalent man (rem) per year. The breakdown 

of the total population dose by containment release mode is summarized in Table F-2. 

Containment failures within the early time frame (0 to less than 6 hours following event initiation) 

dominate the population dose risk at DAEC. 

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

Containment Release Mode Population Dose 

(Person-Rem(a) Per Year) Percent Contribution 

Early Releases (< 6 hrs) 14.1 71 

Intermediate Releases (6 to <24 hrs) 4.2 21 

Late Releases (≥ 24 hrs) 1.5 8 

Total 19.8 100 

(a) One person-rem = 0.01 person-sievert (Sv)

F.2.2 Review of FPL Energy Duane Arnold, LLC’s Risk Estimates 

FPL-DA’s determination of offsite risk at DAEC is based on the following three major elements 

of analysis: 

● Level 1 and 2 risk models that form the bases for the 1992 IPE submittal 

(IELP,1992), and the external event analyses of the 1996 IPEEE submittal (IES, 

1995a) 

● Major modifications to the IPE model that have been incorporated in the DAEC 

PRA 

● MACCS2 analyses to translate fission product source terms and release 

frequencies from the Level 2 PRA model into offsite consequence measures 

Each of these analyses was reviewed to determine the acceptability of FPL-DA’s risk estimates 

for the SAMA analysis, as summarized below. 

The NRC staff's review of the DAEC IPE is described in an NRC report dated November 12, 

1996 (NRC, 1996). Based on a review of the original IPE submittal, responses to RAIs, and a 

revised IPE submittal, the NRC staff concluded that the IPE submittal met the intent of GL 88-20 

(NRC, 1988); that is, the licensee’s IPE process is capable of identifying the most likely severe 

accidents and severe accident vulnerabilities. 

No vulnerabilities or specific improvements to either hardware or procedures identified as a 

result of the original IPE submittal (IELP, 1992) or in the response to IPE RAIs (IES, 1995b) 

were deemed to be necessary. However, the licensee identified a number of potential 

improvements and evaluations in conjunction with the original IPE process. Specific 

improvements or evaluations identified were to: 

● Develop an Abnormal Operating Procedure or Emergency Operating Procedure 

(EOP) to address total loss of 125 VDC. 
Appendix F 

October 2010 F-5 NUREG-1437, Supplement 42 

● Evaluate the existing EOP guidance to terminate vessel injection from outside 

containment if drywell pressure exceeds 53 psia. 

● Maintain heightened awareness regarding timely use of standby liquid control 

for ATWS. 

● Test diesel fire pump capability for vessel injection and evaluate DC reserve 

needed to accomplish this. 

● Evaluate appropriateness of terminating water injection to containment under 

any circumstances for which core degradation may be aggravated. 

● Evaluate the use of drywell sprays as a means to control drywell temperature to 

avoid premature containment failure. 

● Provide guidance to operators related to protection of containment and cooling 

debris using methods that do not require venting. 

● Prioritize injection systems for use in degraded core conditions. 

● Evaluate the benefits of resetting the Automatic Depressurization System (ADS) 

timer instead of immediately locking out the automatic initiation of ADS. 

The first seven of these improvements were included in the list of Phase I SAMAs evaluated. In 

response to an RAI, FPL-DA discussed the resolution of the two remaining items. With regard 

to the prioritizing injection systems, FPL-DA indicates that it has implemented Severe Accident 

Guidelines based on the boiling water reactor owner’s group (BWROG) strategies for degraded 

core conditions that include prioritization of injection sources. With regard to the potential 

benefit of not locking out the ADS, FPL-DA indicates that this has been reviewed as part of the 

boiling water reactor (BWR) industry’s Emergency Operating Procedure and Severe Accident 

Guideline (EOP/SAG) activities and has been concluded that the undesirable impacts of 

automatic ADS initiation outweighs the benefit of not locking out the ADS (NextEra, 2009a). 

The original IPE took credit for a hardened containment vent to be installed shortly after IPE 

submittal. In addition, two improvements were identified during the revision of the original IPE 

that would significantly reduce the potential for flood-related accidents in the control building. 

These modifications to change the control building fire protection system from a “wet” pipe 

system to a “dry” pipe system were completed and credited in the revised IPE. 

The CDF value from the 1992 IPE (7.8 x 10-6 per year) is near the middle of the range of the 

CDF values reported in the IPEs for other BWR 3/4 plants while the value from the 1995 update 

(3.3 x 10-5 per year) is in the upper third of the values reported for other 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 x 10-8 per year to 8 x 10-5 per year, with an average CDF for the group of 

2 x 10-5 per year (NRC, 1997b). It is recognized that other plants have updated the values for 

CDF subsequent to the IPE submittals to reflect modeling and hardware changes. The current 

internal events CDF results for DAEC are comparable to that for other plants of similar vintage 

and characteristics. 
Appendix F 

NUREG-1437, Supplement 42 F-6 October 2010 

There have been seven revisions to the IPE model since the 1992 IPE submittal. A listing of the 

major changes made to the DAEC PRA since the original IPE submittal was provided in the ER 

(FPL-DA, 2008) and in response to an RAI (NextEra, 2009a) and is summarized in Table F-3. 

While a comparison of internal events CDF between the 1992 IPE and the current PRA model 

indicates an increase of about 40 percent in the total CDF (from 7.8 x 10-6 per year to 1.1 x 10-5

per year), the CDF from the current PRA is about 33 percent of that from the revised IPE (from 

3.3 x 10-5 per year to 1.1 x 10-5 per year). 
Appendix F 

October 2010 F-7 NUREG-1437, Supplement 42 

Table F-3. Duane Arnold Energy Center Probabilistic Risk Assessment Historical 

Summary 

Version Description/changes from previous model CDF (per year) 

IPE 

1992 

Original IPE 7.8 x 10-6 

3 (3A) 

3/1995 

Revised IPE 

- Revision of HPCI/RCIC battery life estimates 

- Re-evaluation of LOOP initiating event frequency 

- Addition of sole dependence of DC power on 125 VDC battery (chargers 

excluded) for LOOP and LOCA 

- Incorporation of revised control building HVAC assessment 

- Inclusion of control building flood 

3.3 x 10-5 

3B 

1/1996 

- Incorporation of design modification that eliminated control building flood 

scenario from ruptured fire water propagating to essential switchgear room 

 Model reviewed by BWROG 

1.5 x 10-5 

4 (4A) 

3/1998 

- Relaxation of essential switchgear room’s ventilation requirements 

- Addition of dependency of HPCI/RCIC on decay heat removal for small 

LOCAs 

- Addition of credit for river water supply recovery 

- LOOP sequences with SORV transferred to IORV event tree rather than to 

the MSIV closure event tree 

- Addition of credit for drywell venting 

- Revision of human error probability for containment heat removal models 

- Addition of credit for total loss of 125 VDC procedure 

- Updated initiating event frequencies for transients and manual shutdown 

- Inclusion of well water system design modification 

- Inclusion of common cause failure of SRVs 

- Incorporation of updated maintenance unavailabilities from maintenance rule 

database 

- Incorporation of explicit models for important transformers, breakers, and 

power source lines 

1.1 x 10-5 

4B 

12/2001 

- Conversion from REBECA to CAFTA 1.2 x 10-5 

5 (5A) - Incorporation of updated human error probabilities as result of power uprate 

- Incorporation of updated LOOP frequency based on operating experience 

- Incorporation of instrument air fault tree model as result of BWROG 

certification comment 

- Incorporation of plant-specific equipment performance data for major 

equipment 

1.0 x 10-5 

5B 

2/2005 

- Addition of energy service reactor/residual heat removal service water 

(ESW/RHRSW) pump house ventilation dependency 

- Addition of explicit model for recirculation pump trip failure 

- Incorporation of updated LOOP frequency based on SBO analysis 

1.1 x 10-5 

5C 

7/2007 

- Correction of quantification flag settings 1.1 x 10-5 
Appendix F 

NUREG-1437, Supplement 42 F-8 October 2010 

The NRC staff questioned the licensee regarding the reasons for the relatively large contribution 

to CDF from ATWS and SBO events. In responses to RAIs (NextEra 2009a, 2009b) the 

licensee attributed the ATWS frequency to a relatively high ratio of power to suppression pool 

volume that leads to a shorter time available to initiate boron injection, and attributed the SBO 

frequency to DAEC being a single unit site and thus not having the additional AC power 

resources that would be available if another unit were at the site. 

The NRC staff considered the peer reviews completed for the DAEC PRA, and the potential 

impact of the review findings on the SAMA evaluation. In the ER (FPL-DA, 2008) and in 

response to an NRC staff RAI (NextEra 2009a, 2009b), FPL-DA described the BWROG Peer 

Review of Revision 3B conducted in March 1997, as well as a PRA program self-assessment 

studied in 2004. 

The BWROG review concluded “the DAEC PRA certification resulted in a very consistent 

evaluation across all the elements. For each element, the certification team assigned a 

summary grade level of 3 which supports risk significance determinations supplemented by 

appropriate deterministic analyses.” FPL-DA identified all Level A and B (extremely important 

and important, respectively) facts and observations from the BWROG Peer Review and their 

disposition in the ER. All appear to have been satisfactorily resolved. 

The 2004 self-assessment of the PRA program was analyzed by a team that included 

individuals from one neighboring PWR and one neighboring BWR with a primary focus on 

ensuring that the DAEC PRA program complies with applicable standards and to identify 

potential program enhancement opportunities. The assessment team concluded that, in 

general, the DAEC had established, implanted, and maintained a PRA program consistent with 

applicable fleet (at that time Nuclear Management Company) standards. 

In response to an RAI, FPL-DA described the PRA update process in use at DAEC. 

Department instructions define the overall quality assurance control responsibilities, authorities, 

and requirements, as well as provide guidance on the maintenance, revision and configuration 

management of the model, and associated documentation and software. PRA model changes 

and associated documentation are reviewed by qualified individuals within FPL-DA’s corporate 

PRA department which includes DAEC PRA personnel. If appropriate, changes and associated 

documentation are also reviewed by site System Engineering, Training or Operations personnel. 

Completed documents are approved by either site or corporate supervisory personnel 

responsible for PRA activities. 

FPL-DA states that the Revision 5 PRA incorporates all plant modifications completed up to 

approximately 1999 and that a review of modification packages initiated since late 1997 was 

performed to assess their potential impact on the SAMA analysis. It was determined that no 

completed modifications would have a non-conservative impact on the SAMA results. 

Given that the DAEC internal events PRA model has been peer-reviewed and the peer review 

findings were all addressed, and that FPL-DA has satisfactorily addressed NRC staff questions 

regarding the PRA, the NRC staff concludes that the internal events Level 1 PRA model is of 

sufficient quality to support the SAMA evaluation. 

As indicated above, FPL-DA maintains a current DAEC external events PRA that explicitly 

models seismic and fire initiated core damage accidents. The models are stated to be based on 

the original DAEC IPEEE. Both the original IPEEE and current models are described in the ER. 
Appendix F 

October 2010 F-9 NUREG-1437, Supplement 42 

The DAEC IPEEE was submitted in November 1995 (IES, 1995a), in response to Supplement 4 

of Generic Letter 88-20 (NRC, 1991b). This analysis included a seismic margins analysis, a fire 

screening analysis, and a screening analysis for other external events. While no fundamental 

weaknesses or vulnerabilities to severe accident risk in regard to the external events were 

identified, a list of improvement opportunities was developed as discussed below. In a letter 

dated March 10, 2000, the NRC staff concluded that the submittal met the intent of Supplement 

4 to Generic Letter 88-20, and that the licensee’s IPEEE process is capable of identifying the 

most likely severe accidents and severe accident vulnerabilities (NRC, 2000). 

The DAEC IPEEE seismic analysis utilized a seismic margin assessment (SMA) approach 

following NRC guidance (NRC, 1991a) and Electric Power Research Institute (EPRI) guidance 

(EPRI, 1991). This method is qualitative and does not provide numerical estimates of the CDF 

contributions from seismic initiators. The seismic analysis was completed in conjunction with 

the Seismic Qualification User Group (SQUG) program (SQUG, 1992). The review level 

earthquake (RLE) was taken to be the safe shutdown earthquake (SSE). 

Approximately 850 items identified for the safe shutdown equipment list (SSEL) were evaluated 

using the four screening considerations in the SQUG Generic Implementation Procedure, i.e., 

seismic capacity versus demand, equipment class caveats, equipment anchorage, and seismic 

interactions. Exceptions were shown to be acceptable by calculation or were resolved by 

modification or maintenance action (NRC, 2000). For structures, one masonry wall was 

identified as an outlier and was subsequently qualified for SSE loadings, and inspection of the 

control room ceiling indicated potential outliers that were resolved by selected modifications. 

Several seismic-induced fire and flood outliers were noted including unanchored gas storage 

bottles, air-handlers in the HPCI room and inadequate supports for the turbine lube oil storage 

tank. The first was resolved by providing restraints or removing the bottles, the second shown 

by analysis to have adequate clearance, while the latter was shown not to be risk significant 

(CDF less than 1 x 10-6 per year) (NRC 2000, 2002). The NRC review and closeout of USI A-46 

for DAEC is documented in a letter dated July 29, 1998 (NRC, 1998). 

While the DAEC IPEEE did not identify any vulnerabilities due to seismic events, potential 

improvements and strategies were discussed. These improvements involved the resolution of 

the outliers identified during the IPEEE process. While all were indicated to have been 

completed in the IPEEE submittal, they were incorporated in the Phase I SAMA list for 

completeness. This is discussed further in Section F.3. 

Subsequent to the IPEEE, the licensee created a seismic PRA. The DAEC seismic PRA utilizes 

the 1994 seismic hazard curves from Lawrence Livermore National Laboratory (NRC, 1994). 

The seismic CDF model credits only the equipment in the SSEL developed for the IPEEE. 

Fragilities of the equipment were obtained from high confidence low probability of failure 

(HCLPF) values from industry studies. The probability of failure due to earthquake motion was 

then combined with random failures in modified versions of system fault trees. The Revision 5C 

seismic CDF is 7.0 x 10-7 per year. In response to an RAI, FPL-DA provided additional 

information on the seismic PRA including the SSEL systems and equipment of interest, the 

issues included in the seismic event trees, the treatment of fragility dependencies, human errors 

employed, and the treatment of the turbine lube oil tank issue. FPL-DA also identified 

conservatisms and non-conservatisms in the analysis (NextEra, 2009a). Based on the 

information provided, the staff concludes that while the above seismic CDF value may be 

appropriate for DAEC, the best estimate seismic CDF value might also be higher than that given 

above due to the lack of DAEC-specific fragilities, the treatment of fragility dependencies, and 

the lack of consideration of increases in human error rates for seismic-initiated events. 
Appendix F 

NUREG-1437, Supplement 42 F-10 October 2010 

To provide additional insight as to the appropriate seismic CDF to use for the SAMA evaluation, 

the NRC staff developed an independent estimate of seismic CDF for DAEC using the simplified 

hybrid method described in a paper by Robert P. Kennedy, entitled “Overview of Methods for 

Seismic PRA and Margin Analysis Including Recent Innovations” (Kennedy, 1999) and using the 

1994 LLNL hazard curve from NUREG-1488. This approach uses a median capacity (C50) of 

0.30g (based on the DAEC IPEEE of high confidence low probability of failure screening value 

for critical equipment) to represent the overall plant fragility. The NRC staff’s independent 

calculation conservatively estimates the seismic CDF for DAEC to be approximately 1 x 10-5 per 

year. This value is an order of magnitude greater than that given by FPL-DA in the ER. 

Based on the above, the NRC staff requested the licensee to assess the impact that a higher 

seismic CDF would have on the results of the SAMA analysis. This is discussed further in 

Section F.6.2. 

The NRC staff inquired about the important contributors to seismic risk. In response to an RAI, 

FPL-DA provided a listing and description of the seismic core damage sequences with a CDF of 

1 x 10-8 per year or more (NextEra 2009a, 2009b). The dominant seismic core damage 

sequences are listed in Table F-4. 

Table F-4. Dominant Contributors to Seismic Core Damage Frequency 

Seismic Sequence Description CDF per year 

A seismic event with a magnitude of 1.0 g or more causes wide-spread failure of 

safe-shutdown equipment. Core damage occurs due to loss of injection in a potentially 

damaged containment. 

1.5 × 10–7 

A seismic event with a magnitude between 0.7 and 0.9 g results in loss of offsite power 

and failure to scram. HPCI and RCIC are conservatively not credited leading to core 

damage at high RPV pressure. 

5.0 × 10–8 

A seismic event with a magnitude between 0.7 and 0.9 g results in loss of offsite power 

with a successful scram. HPCI and RCIC are conservatively not credited leading to the 

requirement for depressurization. This fails resulting in core damage at high RPV 

pressure. 

4.6 × 10–8 

A seismic event with a magnitude between 0.7 and 0.9 g causes wide-spread failure of 

safe-shutdown equipment. Core damage occurs due to loss of injection in a potentially 

damaged containment. 

4.1 × 10–8 

A seismic event with a magnitude between 0.9 and 1.0 g causes wide-spread failure of 

safe-shutdown equipment. Core damage occurs due to loss of injection in a potentially 

damaged containment 

3.8 × 10–8 

A seismic event with a magnitude between 0.7 and 0.9 g results in loss of offsite power 

with a successful scram. HPCI and RCIC are conservatively not credited leading to the 

requirement for depressurization. Depressurization and low pressure injection is 

successful but long term containment heat removal fails resulting in core damage at high 

containment pressure. 

3.3 × 10–8 

A seismic event with a magnitude between 0.7 and 0.9 g results in loss of offsite power 

with a successful scram. HPCI and RCIC are conservatively not credited leading to the 

requirement for depressurization. Depressurization is successful but low pressure 

injection fails leading to core damage. 

3.2 × 10–8 

Others 3.1 × 10–7 

Total (all seismic sequences) 7.0 × 10–7 
Appendix F 

October 2010 F-11 NUREG-1437, Supplement 42 

The DAEC IPEEE fire analysis employed EPRI’s fire-induced vulnerability evaluation (FIVE) 

method to analyze a qualitative screening and then a progressive probabilistic evaluation that 

considers the sequence of events that must occur to prevent safe shutdown. This evaluation 

considered fire propagation, damage, and suppression effectiveness if required. An area was 

screened out from further analysis once the fire induced core damage frequency dropped below 

1 x 10-6 per year. A walkdown and verification process was employed to determine weather or 

not the assumptions and calculations were supported by the physical condition of the plant. 

Two fire compartments remained unscreened at the end of the quantification process, Divisions 

I and II 4kV essential switchgear rooms. The fire induced CDF for these two rooms was 

5.6 x 10-6 and 4.9 x 10-6 per year, respectively, for a total fire CDF of approximately 1 x 10-5 per 

year. FPL-DA stated that these values are conservative since fire brigade and offsite fire 

fighting are not credited. 

While no vulnerabilities were identified in the DAEC IPEEE due to fire events, potential 

improvements and strategies were identified and discussed in the IPEEE. These improvements 

were: prohibiting work in the switchgear room supporting the operating river water train during 

river water system maintenance, posting a fire watch in the switchgear room supporting the 

operating river water train during river water system maintenance, and converting the two fire 

protection pipes in the heating, ventilation, air conditioning (HVAC) control building from a “wet” 

pipe system to a “dry pipe” system. In addition, the NRC staff SER for the DAEC IPEEE 

indicates that cables for Division II equipment required for the remote shutdown of the plant 

were being rerouted so that they do not pass through the cable spreading room and that 

implementation of this modification was nearing completion at the time of the IPEEE submittal. 

In response to an RAI FPL-DA confirmed that this rerouting had been completed. These 

improvements, except for the cable rerouting, were incorporated in the Phase I SAMA list for 

completeness. This is discussed further in Section F.3. 

Subsequent to the IPEEE, the licensee created a fire PRA. The Revision 5C fire CDF is 

3.0 x 10-6 per year. In response to an RAI, FPL-DA provided further information on the fire 

PRA. The modeling in the fire PRA consists of three main steps: (1) determining the fire 

frequency for each compartment, (2) analyzing fire growth, and (3) suppression analysis and 

determining the fire induced CDF. The DAEC fire PRA utilizes the compartment fire ignition 

frequencies from the DAEC IPEEE. Fire growth and suppression event trees were developed 

based on the FIVE method as implemented in the IPEEE. The end points of the fire growth and 

suppression event trees are four fire damage states. Core damage frequency was then 

determined using a fire induced core damage event tree for each fire damaged state in each 

compartment. Fire compartments that had core damage frequencies of 2.5 x 10-8 per year or 

more in the IPEEE analyses were analyzed further in the fire PRA. 

In response to an RAI, FPL-DA provided a listing of the fire initiator contribution to the total fire 

CDF as indicated by the fire PRA. The dominant contributors are listed in Table F-5. 
Appendix F 

NUREG-1437, Supplement 42 F-12 October 2010 

Table F-5. Important Fire Areas and Their Contributions to Fire Core Damage Frequency 

Fire Area Description CDF (per year) 

Essential Switchgear Room Division I 8.5 × 10-7 

Lower Non-essential Switchgear Room 7.8 × 10-7 

Essential Switchgear Room Division II 3.4 × 10-7 

Control Room Complex 2.0 × 10-7 

Reactor Building, Third Floor 1.2 × 10-7 

Battery Room, Division II 1.2 × 10-7 

Reactor Building, Second Floor 1.2 × 10-7 

Other 4.7 x 10-7 

Total (all fire areas) 3.0 x 10-6 

The licensee also identified a number of conservatisms and non-conservatisms in the fire PRA 

model (FPL-DA 2008; NextEra 2009a, 2009b). The conservatisms identified are: 

● The assumption that a reactor trip (either automatic or manual) will be 

generated for all fires inside the security fence 

● The susceptibility to failure of unprotected cables entering and exiting the 

metal-enclosed components even for low-intensity fires 

● The assumption that internal cabinet fires disable the entire MCC or cabinet 

● Fire suppression or the fire brigade is not credited (See clarification below) 

● ATWS mitigation features (SLC, manual rod insertion, level/power control, etc.) 

are not credited 

● Neither Thermo-Lag nor other fire wraps are credited 

● The assumption that systems for which cabling has not been tracked and 

located are disabled for all fires 
Appendix F 

October 2010 F-13 NUREG-1437, Supplement 42 

Potential non-conservatisms identified are: 

● MCC and other metal-enclosed components are not considered susceptible to 

failure by exposure to low-intensity external fires 

● Primary containment is not analyzed due to the inert atmosphere 

● The assumption that the electrical portions of the reactor scram function fails 

safe 

● Fire barriers will contain fires up to their listed ratings 

In response to an RAI, FPL-DA clarified that while neither fire suppression nor the fire brigade is 

credited if the core damage frequency for the compartment under consideration is 1 x 10-7 per 

year or less, they are credited if the initial value exceeds this criteria. The improved realism 

provided by the fire growth and suppression event trees resulted in a reduction in CDF for the 

Divisions I and II 4KV essential switchgear rooms from the relatively high IPEEE values. 

It is noted that the IPEEE and the current PRA screened out the cable spreading room on the 

basis of the absence of no fixed fire sources in the room. A screening value for the cable 

spreading room of 2.3 x 10-7 per year was provided in the IPEEE and no CDF for the cable 

spreading room was evaluated in the current fire PRA. The lack of a quantified CDF for the 

cable spreading room at DAEC is in contrast with the results of a number of similar BWR 3/4 

plants. While the lack of a cable spreading room is of concern, the value is not expected to 

significantly change the fire CDF. 

Considering the above discussion, the conservatisms and non-conservatisms and the response 

to the staff RAIs, the staff concludes that the fire CDF of 3.0 x 10-6 per year is reasonable for the 

SAMA analysis. 

The IPEEE analysis of high winds and tornadoes estimated there contribution to CDF to be 

1.4 x 10-7 per year. The NRC staff review of the analysis noted some weaknesses in the 

analysis; nevertheless, the staff concluded that nevertheless the CDF from high winds at DAEC 

is on the order of 1 x 10-6 per year and would not constitute a vulnerability (NRC, 2000). For 

external floods, the IPEEE concluded that DAEC meets the 1975 Standard Review Plan and 

therefore no further analysis was needed. For transportation and nearby facility hazards, the 

IPEEE concluded that no floods posed a threat to the plant. 

While no vulnerabilities to high winds, floods, and other external events were identified in the 

DAEC IPEEE, potential improvements and strategies were identified and discussed in the 

IPEEE. These improvements were: increasing the distance between a new on-site hydrogen 

storage tank and safety-related structures, and constructing barriers around the auxiliary boiler 

propane storage tank. These improvements were incorporated in the Phase I SAMA list and all 

have been implemented. This is discussed further in Section F.3. 

As indicated in Supplement 1 to the License Renewal application (FPL-DA, 2009), a multiplier of 

1.57 was used to adjust the internal event risk benefit associated with a SAMA to account for 

external events. In response to an RAI, FPL-DA indicated that this multiplier was based on a 

total external event CDF of 6.2 x 10-6 per year. This CDF is the sum of the total fire and seismic 

CDF from the DAEC external events PRA (3.74 x 10-6 per year rounded up to 4 x 10-6 per year) 
Appendix F 

NUREG-1437, Supplement 42 F-14 October 2010 

plus the high wind and tornado CDF from the IPEEE (1.4 x 10-7 per year rounded up to 2 x 10-7

per year) plus the screening values for external flooding and transportation events (1 x 10-6 per 

year for each). The external event CDF is thus 56.4 percent of the internal events CDF 

(1.08 x 10-6 per year rounded up to 1.1 x 10-6 per year). Thus, the total CDF is 1.564 times the 

internal events CDF and this was rounded up to 1.57 (NextEra, 2009a). 

As indicated above, the NRC staff estimates that the seismic CDF might be as high as 

approximately 1 x 10-5 per year. If this is combined with a fire CDF of 3 x 10-6 per year, and if 

the other contributions to external events CDF are negligible by comparison, the total multiplier 

to account for external events might be as high as 2.3. In response to an RAI, FPL-DA 

addressed the impact of using this higher multiplier on the results of the SAMA assessment. 

This is discussed further in Section F.6.2. 

The NRC staff reviewed the general process used by FPL-DA to translate the results of the 

Level 1 PRA into containment releases, as well as the results of the Level 2 analysis, as 

described in the ER and in response to NRC staff requests for additional information (FPL-DA 

2008; NextEra 2009a, 2009b). The current Level 2 model utilizes a set of CETs containing both 

phenomenological and systemic events. The Level 1 core damage sequences are grouped into 

core damage accident classes with similar characteristics. All of the sequences in an accident 

class are then input to a CET by linking the level 1 event tree sequences with the level 2 CET. 

The CETs are analyzed by the linking of fault trees that represent each CET node. Whenever 

possible the fault trees utilized in the Level 1 analysis are utilized in the CETs to propagate 

dependencies. 

Each CET end state represents a radionuclide release to the environment. Each is assigned to 

an STC based on magnitude and timing of release. Twelve release categories, as defined in 

the IPE, are utilized. Magnitude is given by CsI release fraction: High (H) greater than 

10 percent, Moderate (M) 1 to 10 percent, Low (L) 0.1 to 1 percent and Low-Low (LL) less 

than 0.1 percent. Timing is based on the time of initial release relative to the time of accident 

initiation (scram): Early (E) less than 6 hours, Intermediate (I), 6 to 24 hours and Late (L) greater 

than 24 hours. The assignment to release magnitude bins was done by consideration of three 

fundamental variables, initial containment failure mode, water availability and reactor building 

effectiveness (NextEra 2009a, 2009b). 

The frequency of each STC was obtained by adding the frequencies of the contributing CET 

end states. The release characteristics for each STC were developed by using the results of 

MAAP 3.0B computer code calculations. The MAAP cases which represented the largest 

release fractions of those in an STC were used to characterize the entire STC. The STCs, their 

frequencies, and release characteristics are presented in Tables 3.4.3-2 and 3.4.4-1 of 

Appendix F to the ER (FPL-DA, 2008). 

The NRC staff review of this information noted a number of apparent discrepancies in the STC 

assignments with respect to timing and release magnitude and requested the licensee to clarify 

the reasons for these discrepancies (NRC 2009a, 2009b). As indicated above, the timing of 

release was measured relative to the time of accident initiation rather than the time of 

declaration of general emergency. This results in assigning sequences to a “Late” bin when 

they would be “early,” considering the time of emergency declaration given in the ER. However, 

the Level 3 consequence analysis correctly used the period between the time of emergency 

declaration and the time of release in evaluating the effectiveness of the evacuation, and a 

sensitivity study showed that the population dose and the off-site economic cost results are not 
Appendix F 

October 2010 F-15 NUREG-1437, Supplement 42 

sensitive to the time used. Thus, this inconsistency in treating release timing would not 

significantly impact the SAMA analysis. 

With regard to release magnitude, the staff noted that the release fractions for a number of 

STCs did not agree with the above definitions. In most cases the release fractions utilized were 

greater than that prescribed by the STC definition. This apparently was the result of the process 

for assigning sequences to the STCs, and selecting the highest release fraction of the assigned 

sequences to represent the STC. In one case, STC M/I (moderate release magnitude and 

intermediate release timing), the release fraction utilized did not include the scrubbing from the 

suppression pool. This was due to the fact that pool scrubbing was not included in the Level 2 

MAAP analysis but was added manually. The release fraction used in the Level 3 analysis also 

excluded this correction. In response to an RAI, the licensee indicated that use of the correct 

release fraction (a factor of 10 lower) would reduce the total population dose by about 8 percent. 

The DAEC Level 2 PRA model is essentially that used in the IPE. As indicated in the ER, no 

changes to major modeling assumptions, containment event trees structure, accident 

progression/source term calculations, or binning of end states in the Level 2 PRA model have 

been made since the IPE submittal. The NRC staff’s review of the IPE Level 2 model concluded 

that it appeared to have addressed the severe accident phenomena normally associated with 

the Mark I containment type, that it met the IPE requirements, and that there were no 

weaknesses. It was noted, however, that DAEC appears not to have analyzed a thorough 

internal peer review of the back-end (i.e., Level 2) portion of the IPE. The BWROG review did 

not have any important (i.e., Level A or B) facts and observations from its review of the Level 2 

model. 

Since there have been no major changes in the Level 2 PRA since the IPE and the IPE Level 2 

model was based on the state of knowledge in the 1991–1992 time frame, the staff asked 

FPL-DA to discuss the impact of the current state of knowledge on key BWR accident and 

containment failure phenomenology on the Level 2 assumptions and results used for the SAMA 

analysis. FPL-DA responded that while the Level 2 analysis was updated to reflect the current 

Level 1 model, there have been no major changes in the state of knowledge regarding accident 

progression and containment failure mechanisms that would require a change in the Level 2 

model. FPL-DA indicated that a peer assessment analyzed in 2007, subsequent to the 

preparation of the ER, concluded that the DAEC Level 2 analysis is comprehensive and 

acceptable for risk-informed applications such as SAMA, that the model can still be considered 

state of the art, and that the sequence binning and release characterization met the American 

Society of Mechanical Engineers (ASME) Code Standard. The reviewers suggested that 

FPL-DA upgrade from MAAP 3.0B to MAAP 4. FPL-DA has not yet implemented this change. 

The staff concludes that, given the conservative release fractions used for the important STCs, 

upgrading the MAAP analysis will not adversely impact the SAMA evaluation. 

Based on the NRC staff’s review of the Level 2 method, the licensee’s responses to RAIs and 

the fact that the Level 2 model was reviewed in more detail as part of the BWROG peer review’ 

plus a more recent review for conformance to the ASME Code PRA standard was found 

acceptable, the NRC staff concludes that the Level 2 PRA provides an acceptable basis for 

evaluating the benefits associated with various SAMAs. 

FPL-DA used the MACCS2 code and a core inventory from a plant specific ORIGEN2 

calculation to determine the offsite consequences of activity release (NextEra, 2009b). FPL-DA 

confirmed that the inventory used reflects the expected fuel management/burnup during the 

license renewal period (NextEra, 2009a). 
Appendix F 

NUREG-1437, Supplement 42 F-16 October 2010 

The NRC staff reviewed the process used by FPL-DA to extend the containment analysis 

(Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3 

PRA). This included consideration of the source terms used to characterize fission product 

releases for the applicable containment release categories and the major input assumptions 

used in the offsite consequence analyses. The MACCS2 code was used to estimate offsite 

consequences. Plant-specific input to the code includes the source terms for each source term 

category and the reactor core radionuclide inventory (both discussed above), site-specific 

meteorological data, projected population distribution within a 50-mile (80-km) radius for the 

year 2040, emergency evacuation modeling, and economic data. This information is provided in 

Section 3.4 of Appendix F to the ER (FPL-DA, 2008). 

All releases were modeled as being from the off-gas stack or the top of the reactor building 

depending on the accident sequence release location. In response to an RAI, FPL-DA indicated 

the type of sequence released from each location. The results of sensitivity studies on release 

height or location provided in the original submittal and in response to an RAI indicated a 

negligible impact (less than plus or minus 3 percent) on both population dose and offsite 

economic cost. The thermal content of each of the releases was assumed to be the same as 

ambient (that is a non-buoyant plume). Wake affects for the 140-foot high and 140-foot wide 

reactor building were included in the model. Sensitivity studies were analyzed on these 

assumptions and indicated little (approximately 1 percent increase or decrease) or no change in 

population dose or offsite economic cost. Another sensitivity study showed that removing the 

base case assumption of perpetual rainfall in the 40–50 mile segment surrounding the site 

would result in a 9 percent reduction in population dose and a 15 percent reduction in offsite 

costs. Based on the information provided, the staff concludes that the release parameters used 

are acceptable for the purposes of the SAMA evaluation. 

FPL-DA used site-specific meteorological data for the 2005 calendar year as input to the 

MACCS2 code. The development of the meteorological data is discussed in Section 3.4.5 of 

Appendix F to the ER and in response to an RAI (NextEra, 2009a). The data were collected 

from the onsite meteorological monitoring system. Sensitivity analyses using MACCS2 and the 

meteorological data for the years 2002 through 2006 show that use of data for the year 2005 

results in the largest dose and economic cost risk. Missing meteorological data was filled using 

data: from another level on the met tower (accounting for the relationship between the levels as 

determined from the preceding hours); by interpolation if the gap were less than 4 hours; or from 

the hour and a nearby day of a previous year. Missing precipitation data was obtained from a 

nearby airport. The NRC 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 

2005 meteorological data in the SAMA analysis is reasonable. 

The population distribution that the licensee used as input to the MACCS2 analysis was 

estimated for the year 2040 using year 2000 census data as accessed by SECPOP 2000 

(NRC, 2003) as a starting point. The 2000 population was adjusted to account for transient 

population obtained from the evacuation time estimate study (TOMCOD, 2003). County growth 

rates based on projections from State Data Center of Iowa (State Library, 2006) were applied to 

obtain the distribution in 2040. These data were used to project county-level resident and 

transient populations to the year 2040 using an exponential fit and applied to each zone based 

on the fraction of each county within the zone. The NRC staff considers the methods and 

assumptions for estimating population reasonable and acceptable for purposes of the SAMA 

evaluation. 
Appendix F 

October 2010 F-17 NUREG-1437, Supplement 42 

The emergency evacuation model was modeled as a single evacuation zone extending out 

10 miles (16 km) from the plant (the emergency planning zone (EPZ). FPL-DA assumed that 

95 percent of the population would evacuate. This assumption is conservative relative to the 

NUREG-1150 study (NRC, 1990), which assumed evacuation of 99.5 percent of the population 

within the emergency planning zone. The evacuated population was assumed to move at an 

average radial speed of approximately 4.4 miles per hour (2.0 meters per second) with a 

delayed start time of 17 minutes after declaration of a general emergency. A general 

emergency declaration was assumed to occur at the onset of core damage. The evacuation 

speed (0.314 meters per second) was derived from the projected time to evacuate the entire 

EPZ under winter, weekday, mid-day, adverse weather conditions during the year 2000 

(TOMCOD, 2003) and then adjusted by the ratio of the year 2000 EPZ population to the 

projected year 2040 EPZ population. Sensitivity studies on these assumptions indicate that 

there is little or no change to the population dose or offsite economic cost by the assumed 

variations. The sensitivity studies included setting the general emergency declaration time to 

zero (the earliest possible declaration time). This change resulted in a 2 percent reduction in 

population dose and no change in offsite economic cost. The NRC staff concludes that the 

evacuation assumptions and analysis are reasonable and acceptable for the purposes of the 

SAMA evaluation. 

Site-specific agriculture and economic data was provided from SECPOP 2000 (NRC, 2003) by 

specifying the data for each of the counties surrounding the plant to a distance of 50 miles 

(80 km). This included the fraction of land devoted to farming, annual farm sales, the fraction of 

farm sales resulting from dairy production, and the value of non-farm land. SECPOP2000 

utilizes economic data from the 1997 National Census of Agriculture (USDA, 1998). In 

response to an RAI, FPL-DA analyzed a sensitivity study which indicated that replacing the data 

from the 1997 National Census of Agriculture with data from the 2002 National Census of 

Agriculture (USDA, 2002) has a negligible (less than 1 percent) impact on results (NextEra, 

2009a). 

Area wide farm wealth was determined from 2002 National Census of Agriculture (USDA, 2002) 

county statistics for farmland, buildings and machinery, with only the fraction of each county 

within 50 miles of DAEC considered. Non-farm wealth was taken as the population-weighted 

average of the SECPOP2000 non-farm property value. In addition, generic economic data that 

applied to the region as a whole were revised from the MACCS2 sample problem input in order 

to account for cost escalation since 1986 (the year the input was first specified). This included 

parameters describing cost of evacuating and relocating people, land decontamination and 

property condemnation. An escalation factor of 1.90 was applied to these parameters to 

account for cost escalation from 1986 (the year the input was first specified) to July 2007. 

FPL-DA confirmed that the three recently discovered problems in SECPOP2000 have all been 

accounted for in preparing the input for DAEC (NextEra, 2009a). These problems involved: (1) 

an inconsistency in the format in which several economic parameters were output from the 

SECPOP2000 code and input to the MACCS2 code, (2) an error that resulted in use of 

agricultural/economic data for the wrong counties in the SECPOP2000 calculations, and (3) an 

error that resulted in the economic data for some counties being handled incorrectly. 

The NRC staff concludes that the methods used by FPL-DA to estimate the offsite 

consequences for DAEC provides an acceptable basis from which to proceed with an 

assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based 

its assessment of offsite risk on the CDF and offsite doses reported by FPL-DA. 
Appendix F 

NUREG-1437, Supplement 42 F-18 October 2010 

F.3. Potential Plant Improvements 

This section discusses the process for identifying potential plant improvements, an evaluation of 

that process, and the improvements evaluated in detail by FPL-DA. 

F.3.1 Process for Identifying Potential Plant Improvements 

FPL-DA’s process for identifying potential plant improvements (SAMAs) consisted of the 

following elements: 

● Review of the most significant basic events from the current, plant-specific Level 

1 PRA, 

● Review of potential plant improvements identified in the DAEC IPE and IPEEE, 

● Review of generic SAMA candidates from Table 13 of NEI 05-01 (NEI 2005), 

and 

● Review of the above generic and site-specific SAMAs by an expert panel to 

identify any additional candidates. 

The expert panel consisted of 16 individuals with a wide range of plant, design, and analysis 

experience. The panel identified one additional SAMA, SAMA 156 – Provide an alternate 

source of water for the Residual Heat Removal/Emergency Service Water (RHR/ESW) pit. 

Based on this process, an initial set of 166 candidate SAMAs, referred to as Phase I SAMAs, 

was identified. These are identified in Table 5.5-1 of Appendix F to the ER (FPL-DA, 2008). In 

response to an NRC staff RAI, FPL-DA provided further information on the potential for a 

modification to the lube oil storage tank support structure found in the IPEEE to fail at the DAEC 

safe shutdown earthquake. This modification was designated as SAMA 167 and was added to 

the Phase I list of SAMA candidates in an update to the ER (NextEra, 2009c). 

In Phase I of the evaluation, FPL-DA analyzed 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 DAEC due to design differences (23 screened 

out). 

● The SAMA has already been implemented at DAEC (104 screened out initially; 

103 screened out in updated ER after correcting miss-categorization of SAMA 

118). 

● The SAMA is similar in nature and could be combined with another SAMA 

candidate (2 screened out). 

● The SAMA requires excessive changes that will obviously exceed the maximum 

benefit (13 screened out initially; 15 screened out in updated ER after correcting 

miss-categorization of SAMA 118 and adding SAMA 167). 
Appendix F 

October 2010 F-19 NUREG-1437, Supplement 42 

● The SAMA is related to a non-risk significant system for which changes in 

reliability are known to have negligible impact on risk (none screened out). 

Based on this screening, a total of 143 SAMAs were eliminated leaving 24 for further evaluation. 

The results of the Phase I screening analysis are given in Table 6-1 of Appendix F to the ER. 

The remaining SAMAs, referred to as Phase II SAMAs, are listed in Table 7.1.3-1 of Appendix F 

to the ER. In Phase II, a detailed evaluation was analyzed for each of the 24 remaining SAMA 

candidates, as discussed in forthcoming Sections F.4 and F.6 below. To account for the 

potential impact of external events, the estimated benefits based on internal events were 

multiplied by a factor of 1.57, as previously discussed. 

F.3.2 Review of FPL Energy Duane Arnold, LLC’s Process 

FPL-DA’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

initiating events. In response to NRC staff RAIs, explicit consideration was also given to 

potential SAMAs for fire and seismic events. The initial list of SAMAs generally addressed the 

hardware failures and human actions considered to be important to CDF from risk reduction 

worth (RRW) perspectives at DAEC, and included selected SAMAs from prior SAMA analyses 

for other plants. 

FPL-DA provided a tabular listing of the dominant human action contributors (Table 5.1-1 of 

Appendix F to the ER) and dominant hardware contributors (Table 5.1-2 of Appendix F to the 

ER) to CDF sorted according to their RRW (FPL-DA, 2008). SAMAs impacting these basic 

events would have the greatest potential for reducing risk. FPL-DA used a RRW cutoff of 1.005, 

which corresponds to about a one-half percent change in CDF given 100-percent reliability of 

the SAMA. This equates to a benefit of approximately $11,000 (after the benefits have been 

multiplied to account for external events). 

Initially, no Phase I SAMAs were identified for the human actions on the basis that DAEC 

procedures and training meet current industry standards. The NRC staff noted that the CDF 

contribution from failure of important operator actions could possibly be reduced by provision of 

additional alarms or automating the action. In response to an RAI, FPL-DA indicated that risk 

significant operator actions have been prioritized in operator training and scrutinized for 

improvement opportunities. Several improvements implemented were described. FPL-DA 

stated that appropriate indications and alarms are already in place and any hardware 

modifications to automate operator actions would typically cost substantially more than any 

benefit and may create the potential for adverse impacts or consequences. In conclusion, no 

SAMAs in this area were identified for further consideration. 

The FPL-DA review of the important hardware contributors identified four new plant specific 

SAMAs. 15 generic SAMAs were stated to address the remaining important contributors. The 

NRC staff noted that the most important hardware contributor in the RRW table (event PDI1947, 

failure of the RHRSW Loop “B” heat exchanger differential pressure indicator, with a RRW of 

1.053) is addressed by SAMA 165, to improve the differential pressure indicators. However, 

this SAMA was subsequently screened out on the basis that it was not applicable since the PRA 

did not reflect a plant modification that had been implemented at DAEC. In an RAI, the NRC 

staff noted that event PDI2046, involving failure of the corresponding pressure indicator in Loop 

“A,” has a RRW of only 1.005. In response, FPL-DA indicated that the RRW value for event 

PDI1947 reported in the ER was in error and that the correct value should be 1.005 

(NextEra, 2009a). Since this value is at the low RRW cutoff, no SAMA is appropriate for these 

pressure indicators. This error was corrected in the ER update (NextEra, 2009c). 
Appendix F 

NUREG-1437, Supplement 42 F-20 October 2010 

A total of 17 DAEC specific SAMAs based on improvements identified in the IPE and IPEEE 

were included in the Phase I list. All were screened out on the basis that they have been 

implemented. 

Table 6-1 of the ER provides the results of Phase I screening of the initial list of SAMA 

candidates. The NRC staff questioned the screening out of a number of SAMAs on the basis 

that they were not applicable to DAEC or were already implemented at DAEC. In response to 

an RAI and subsequent request for clarification, FPL-DA provided additional information to 

support the screening of the questioned items. The additional information included: (1) results 

of fire studies that did not find fire barrier or spurious actuation vulnerabilities or weaknesses, (2) 

the identification of equipment, procedures and programs in place at DAEC that effectively 

implement the intent of the SAMA and/or result in most of the risk reduction that could be 

achieved by the SAMA, and (3) for one SAMA (SAMA 118 – add an independent boron injection 

system) a correction to the reported basis for screening. For SAMA 159, which originated from 

the IPEEE and involves either posting a fire watch in the switchgear room supporting the 

operating river water train, or staging temporary hoses for implementation of abnormal operation 

procedure (AOP)-410, Total Loss of River Water, FPL-DA concluded that the need for such a 

requirement has been eliminated since the emergency switchgear rooms fire risk has been 

reduced by a factor of ten from that in the IPEEE. The NRC staff agrees with this conclusion. 

The NRC staff also questioned FPL-DA about lower cost alternatives to some of the SAMAs 

evaluated, including: 

● Using a portable diesel driven pump for low pressure injection through existing 

systems, 

● Using a portable diesel driven pump to provide makeup to the RHRSW/ESW pit, 

● Using a portable DC power supply to maintain DC power availability for SBO 

sequences, 

● Improving the reliability of cross-ties between the RHR system and (1) the RHR 

service water, (2) the fire system or (3) other systems that could be used for 

alternate low pressure injection, and 

● Creating a procedure to maximize CRD flow to provide early and/or late 

injection. 

In response to the RAIs, FPL-DA addressed the suggested lower cost alternatives, and 

indicated that all of these alternatives are effectively covered by existing procedures 

(NextEra, 2009a). This is discussed further in Section F.6.2. 

Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER 

addresses the major contributors to internal event CDF. 

Although the Phase I list of potential SAMAs did include candidate SAMAs for external events 

based on generic insights and the IPEEE results, FPL-DA did not report that the DAEC seismic 

and fire PRA models were systematically reviewed for the purpose of identifying potential 

external event SAMAs. In response to an RAI, FPL-DA provided a listing of important 

component and human error events for the seismic and fire initiated events sorted by risk 
Appendix F 

October 2010 F-21 NUREG-1437, Supplement 42 

reduction worth. FPL-DA noted that almost all of the important seismic and fire contributors 

were the same as those identified for internal events and reviewed for potential SAMAs. 

FPL-DA reviewed those events that are not on the internal events list and determined that they 

were either covered by existing SAMAs or, for human errors, are unlikely to be reduced by 

improved procedures. 

The NRC staff noted that all of the important seismic and fire basic events discussed above are 

random failures and none are due to the effects of the seismic or fire initiating event. In 

response to a NRC staff RAI, FPL-DA attributed this to the manner in which seismic and fire 

failures are incorporated in the external events models. 

In a further effort to identify external event SAMAs, the NRC staff requested FPL-DA to list the 

important seismic and fire initiated core damage sequences and to review them for potential 

SAMAs. FPL-DA provided the requested information and stated that a review of the dominant 

fire and seismic sequences did not identify any potential SAMAs. The major sequences are 

extreme magnitude earthquakes that cause widespread damage and significant fires in the 

essential and non-essential switchgear rooms. 

The staff notes that the largest contributor to fire risk is a sequence involving a severe fire in the 

lower (non-essential) switchgear room that disables multiple equipment in the room and has a 

CDF contribution of 7.4 x 10-7 per year (NextEra, 2009a) while the largest contributor to seismic 

risk is a sequence involving a severe earthquake that causes widespread damage and has a 

CDF contribution of 1.5 x 10-7 per year (NextEra, 2009a). These sequences correspond to 

7.4 percent and 1.5 percent of the internal events CDF, respectively. Eliminating them entirely 

would have a benefit of $110,000 and $22,000, respectively. Considering that the minimum 

cost of a hardware modification would likely exceed $100,000, the NRC staff concludes that it is 

unlikely that any SAMAs to address these fire or seismic sequences would be cost beneficial. 

Failure of the turbine lube oil tank support structure leading to a fire and core damage was 

identified in the DAEC IPEEE (IES, 1995a) and discussed extensively in the IPEEE SER 

(NRC, 2000). In response to NRC staff RAIs, FPL-DA provided additional information on this 

failure, its modeling in the seismic PRA, and the potential for a cost beneficial SAMA to address 

the failure. The failure is described as a buckling of the 5-foot tall support structure leading to 

the tank tipping over, breaching the surrounding wall, and spilling oil into the turbine building 

causing a major fire. This is assessed to have a CDF contribution of 1 x 10-7 per year. This 

corresponds to approximately 1 percent of the internal events CDF. Eliminating or reducing this 

risk would involve adding stiffeners to the support structure. The benefit associated with 

eliminating this risk is given by FPL-DA as 1 percent of the maximum attainable benefit (MAB) 

of $2.3 million or $23,000. FPL-DA points out that since this is less than the minimum cost for a 

hardware fix of $100,000, strengthening the lube oil tank support structure would not be cost 

effective. 

The NRC staff notes that since the MAB used above includes a multiplier of 1.57 to account for 

both internal external events, the benefit of eliminating this failure would be only $8,000 (when 

the benefit in internal events is not included). The staff further notes that while there is the 

possibility that the CDF contribution from the lube oil tank support structure is greater than the 

value cited above, even if the seismic contribution were increased by a decade, the modification 

would have to cost less than $80,000 to be cost beneficial. This is considered unlikely given the 

nature of the required fix and the associated analysis required. Based on the above, the NRC 

staff concludes that a SAMA to address the lube oil tank support structure failure need not be 

evaluated further. 
Appendix F 

NUREG-1437, Supplement 42 F-22 October 2010 

Based on the licensee’s IPEEE, the A-46 efforts to identify and address seismic outliers, the 

modifications that have already been implemented, the review of the results of the DAEC 

seismic and fire PRAs, and the expected cost associated with further risk analysis and potential 

plant modifications, the NRC staff concludes that the opportunity for seismic and fire-related 

SAMAs has been adequately explored and that it is unlikely that there are any cost-beneficial, 

seismic- or fire-related SAMA candidates. 

As stated earlier, other external hazards (i.e., high winds, external floods, and transportation 

and nearby facility accidents) are below the IPEEE threshold screening frequency and are not 

expected to impact the conclusions of the SAMA analysis. Two improvements were, however 

noted in the IPEEE and were implemented. The NRC staff concludes that the licensee’s 

rationale for eliminating other external hazard enhancements from further consideration is 

reasonable. 

The NRC staff notes that the set of SAMAs submitted is not all-inclusive, since additional, 

possibly even less expensive, design alternatives can always be postulated. However, the NRC 

staff concludes that the benefits of any additional modifications are unlikely to exceed the 

benefits of the modifications evaluated and that the alternative improvements would not likely 

cost less than the least expensive alternatives evaluated when the subsidiary costs associated 

with maintenance, procedures, and training are considered. 

The NRC staff concludes that FPL-DA used a systematic and comprehensive process for 

identifying potential plant improvements for DAEC, and that the set of potential plant 

improvements identified by FPL-DA is reasonably comprehensive and, therefore, acceptable. 

This search included reviewing insights from the plant-specific risk studies and reviewing plant 

improvements considered in previous SAMA analyses. While explicit treatment of external 

events in the SAMA identification process was limited, it is recognized that the prior 

implementation of plant modifications for fire and seismic risks and the absence of external 

event vulnerabilities reasonably justifies primarily examining the internal events risk results for 

this purpose. 

F.4. Risk Reduction Potential of Plant Improvements 

FPL-DA evaluated the risk-reduction potential of the 24 remaining SAMAs that were applicable 

to DAEC. The majority of the SAMA evaluations were analyzed in a bounding fashion in that 

the SAMA was assumed to completely eliminate the risk associated with the proposed 

enhancement. On balance such calculations overestimate the benefit and are conservative. 

FPL-DA used model re-quantification to determine the potential benefits. The CDF, population 

dose reductions, and offsite economic cost reductions were estimated using the DAEC PRA 

model. The changes made to the model to quantify the impact of SAMAs are described in 

Table 7.1.3-1 of Appendix F to the ER (FPL-DA, 2008). Table F-6 lists the assumptions 

considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk 

reduction in terms of percent reduction in CDF and population dose, and the estimated total 

benefit (present value) of the averted risk. The estimated benefits reported in Table F-6 reflect 

the combined benefit in both internal and external events. The determination of the benefits for 

the various SAMAs is further discussed in Section F.6. 
Appendix F 

October 2010 F-23 NUREG-1437, Supplement 42 

The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction 

estimates of certain SAMAs provided in the ER, as summarized below (NRC, 2009a; 

NRC, 2009b). 

● SAMA 41, provide capability for alternate injection via the reactor water cleanup 

(RWCU), was initially evaluated as being beneficial only for events involving 

steamline breaks or stuck open safety relief valves. In response to an RAI, 

FPL-DA indicated that this treatment was based on interpreting the generic 

SAMA as providing a means of heat removal and not a source of injection, and 

that the RWCU system is not capable of being used for injection (NextEra, 

2009a). However, in another response, the cost estimate was stated to include 

some of the modifications necessary to use it for injection (NextEra, 2009a). 

Although the benefit associated with a SAMA based on use of the RWCU for 

injection was not provided by FPL-DA (NextEra, 2009b), this benefit can be 

estimated from the assessed benefits of other SAMAs. This is discussed in 

Section F.6.2. 

● SAMA 117, increase boron concentration or enrichment, was initially evaluated 

by eliminating mechanical failures of the standby liquid control (SLC) system 

rather than reducing the human error probability associated with initiating SLC 

(NextEra, 2009a). FPL-DA revised this evaluation in response to an RAI which 

pointed out that increasing boron concentration or enrichment would provide 

more time for the operator to act but would not prevent mechanical failures. The 

reevaluation, based on the RRW of the operator’s failure to inject SLC early, 

indicated a 9.9 percent reduction in CDF and a benefit of approximately 

$200,000 (NextEra, 2009b). This is discussed in Section F.6.2. 

● SAMA 164, improve the reliability of the river water system (RWS) control 

system, was evaluated by revising the base case PRA to more accurately reflect 

the current primary and backup RWS control system, and further modifying this 

model to account for SAMA implementation. The original base case PRA model 

included the primary automatic control system, whose failure had a RRW that 

led to the identification of the SAMA. FPL-DA added an independent backup 

control system to the base case model with an assumed reliability equal to that 

of the primary system. This reduced the importance of the primary control 

system and thus the benefit that could result from further improvements 

(NextEra 2009a, 2009b). The NRC staff concludes that this approach to 

evaluating the risk reduction of this SAMA was acceptable. 

The NRC staff has reviewed FPL-DA’s bases for calculating the risk reduction for the various 

plant improvements and concludes, with the above clarifications, that the rationale and 

assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the 

estimated risk reduction is higher than what would actually be realized). Accordingly, the NRC 

staff based its estimates of averted risk for the various SAMAs on FPL-DA’s risk reduction 

estimates. 
Appendix F 

NUREG-1437, Supplement 42 F-24 October 2010 

F.5. Cost Impacts of Candidate Plant Improvements 

FPL-DA estimated the minimum implementation costs for a procedure change, including training 

on the procedure, to be $30,000 and for an integrated hardware modification, including 

associated training, to be $100,000. If the calculated benefit exceeded these minimum 

implementation costs then an expert panel further assessed the SAMA. 

The expert panel consisted of plant staff familiar with design, construction, operation, training 

and maintenance. The expert panel in their assessment discussed a conceptual design and 

degree of complexity to implement the SAMA under consideration. The panel then chose a 

similarly complex design modification that had been completed at DAEC and used the actual 

cost for this modification as the cost of implementing the SAMA. 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 account 

for inflation (NextEra, 2009b). For some SAMAs, particularly when evaluating the cost benefit 

associated with sensitivity studies, other licensees’ estimates for similar improvements were 

cited to indicate that the DAEC cost estimates were too low. A member of the Design 

Engineering department reviewed the cost estimates for four SAMAs (SAMAs 12, 78, 156 and 

168) to provide further assurance that the estimates were sufficiently accurate for cost benefit 

decision making purposes. 

The NRC staff reviewed the bases for the licensee’s cost estimates (presented in Table 7.1.3-1 

of Appendix F to the original ER) and requested more information concerning the design and 

associated cost for a number of the SAMAs. Also, for a number of SAMAs where the cost was 

given only as greater than the MAB, the NRC staff requested specific dollar cost estimates 

(NRC, 2009a). In response, FPL-DA described in general terms the nature of the modification 

required to implement the SAMA to support the expert panel’s judgment on the cost, and in 

some cases cited DAEC experience with similar modifications and/or cost estimates given in 

other SAMA evaluations (NextEra, 2009a). For certain improvements, the NRC staff also 

compared the cost estimates to estimates developed elsewhere for similar improvements, 

including estimates developed as part of other licensee’s analyses of SAMAs for operating 

reactors and advanced light-water reactors. The staff reviewed the costs and found them to be 

reasonable, and generally consistent with estimates provided in support of other plants’ 

analyses. Updated cost estimates provided in support of the NRC staff review were 

incorporated in the first annual update of the License Renewal Application (NextEra, 2009c) and 

are reflected in Table F-6. 

The NRC staff concludes that the cost estimates provided by FPL-DA are sufficient and 

appropriate for use in the SAMA evaluation. 
Appendix F 

Table F-6. Severe Accident Mitigation Alternative Cost/Benefit Screening Analysis for Duane Arnold Energy CenterOctober 2010 F-25 NUREG-1437, Supplement 42 

(a)

DAEC SAMA Number 

Potential Improvement Modeling Assumptions 

% Risk Reduction Total Benefit ($) 

Minimum 

Cost(b) ($) CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty 

10 - Provide an additional diesel generator 

Standby diesel generators do not fail 38 41 950K 2.4M 10M 

12 - Improve 4.16-kV bus cross-tie Division 1 diesel generator does not fail 12 18 400K 1.0M 1.6M 15 - Install a gas turbine generator Standby diesel generators do not fail 38 41 950K 2.4M 5M 17 - Install a steam-driven turbine generator that uses reactor steam and exhausts to suppression pool 

Standby diesel generators do not fail 38 41 950K 2.4M 20M 

27 - Install an independent active or passive high pressure injection system 

Small, medium and large LOCAs, breaks outside containment, IORV and SORV sequences eliminated 

26 26 570K 1.4M 20M 

28 - Provide an additional high pressure injection pump with independent diesel 

HPCI does not fail 37 36 810K 2.0M 10M 

35 - Add signals to open relief valves automatically in an MSIV closure transient 

Safety/relief valves do not fail 15 7.6 190K 460K 1M 

39 - Increase flow rate of suppression pool cooling 

Torus cooling always successful 8.1 8.4 170K 420K 2.3M 

41(c) - Provide capability for alternate 

injection via reactor cleanup (RWCU)

Steam line breaks and SORV sequences eliminated 

16 16 350K 860K 1.3M 

HPCI does not fail 37 36 810K 2.0M 4.0M 

49 - Replace two of the four electric safety injection pumps with diesel-powered pumps 

Small, medium and large LOCAs, breaks outside containment, IORV and SORV sequences eliminated 

26 26 570K 1.4M 20M 
Appendix F 

NUREG-1437, Supplement 42 F-26 October 2010 

DAEC SAMA Number 

Potential Improvement Modeling Assumptions 

% Risk Reduction Total Benefit ($) 

Minimum 

Cost(b) ($) CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty 

52 - Replace ECCS pump motors with air-cooled motors 

Small, medium and large LOCAs, breaks outside containment, IORV and SORV sequences eliminated 

26 26 570K 1.4M 1.5M 

55 - Implement modifications to allow manual alignment of the fire water system to RHR heat exchangers 

RHR Service Water System does not fail 

4.7 8.7 160K 390K 500K 

56 - Add a service water pump RHR Service Water System does not 

fail 

4.7 8.7 160K 390K 1M 

75 - Install an independent method of suppression pool cooling 

Torus cooling always successful 8.1 8.4 170K 420K 1M 

78 - Enable flooding of the drywell head seal 

Failures of the drywell head flange seal eliminated 

0.0 1.8 25K 65K 100K 

107 - Increase leak testing of valves in interfacing system loss of coolant accident (ISLOCA) paths 

Interfacing System LOCA initiated sequences eliminated 

0.6 0.5 11K 26K 2.3M 

117 - Increase boron concentration or enrichment in the SLC system 

Human error failure to inject stand-by liquid control early eliminated(d)

9.9 (e) 200K 500K 400K 

120 - Add a system of relief valves to prevent equipment damage from pressure spikes during ATWS 

ATWS events do not occur 30 26 590K 1.5M 5M 

123 - Install an ATWS sized filtered containment vent to remove decay heat 

ATWS events do not occur 30 26 590K 1.5M 3M 

139 - Install digital large break LOCA protection system 

Small, medium and large LOCAs, breaks outside containment, IORV and SORV sequences eliminated 

26 26 570K 1.4M 13M 

156 - Provide an alternate source of water for the RHRSW/ESW pit (Add T-connection and valve to pipe connecting the RHRSW/ESW pit to the Circ Water pit to allow backflow from the Circ Water pit to the RHRSW/ESW pit) 

All failures of RWS system eliminated 13 15 320K 800K 250K 
Appendix F 

October 2010 F-27 NUREG-1437, Supplement 42 

DAEC SAMA Number 

Potential Improvement Modeling Assumptions 

% Risk Reduction Total Benefit ($) 

Minimum 

Cost(b) ($) CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty 

163 - Improve the reliability of the RWS system control valves CV4914 and CV4915 

All failures of RWS system eliminated 13 15 320K 800K 1M 

164 - Improve the reliability of the RWS control system 

Failure of hand switches for both RWS supply valves to stilling basin eliminated from revised SAMA baseline model modified to include backup redundant controls not included in original baseline model 

0.4 0.5 10K 25K 100K 

166 - Increase the reliability of the low pressure ECCS RPV low pressure permissive circuitry. Install manual bypass of the low pressure permissive 

All failures of the low pressure ECCS low reactor pressure permissive switches eliminated 

6.4 13 280K 690K 250K 

 (a) SAMAs in bold are potentially cost-beneficial  (b) Minimum cost values are based on information provided in response to RAIs and incorporated in updated ER (NextEra 2009a, 2009c)  (c) For SAMA 41 the benefit reported in the ER is based on mitigating only steam break. An RAI response provided an estimated cost for an enhanced 

modification but no associated benefit information (NextEra, 2009b). The benefit for this enhanced modification was estimated by NRC staff. See Section F.6.2. 

 (d) Analysis revised in response to an RAI (NextEra, 2009b) 

 (e) Not provided. See Section F.6.2 
Appendix F 

NUREG-1437, Supplement 42 F-28 October 2010 

F.6. Cost-Benefit Comparison 

FPL-DA’s cost-benefit analysis and the NRC staff’s review are described in the following 

sections. 

F.6.1 FPL Energy Duane Arnold, LLC’s Evaluation 

The method used by FPL-DA was based primarily on NRC’s guidance for analyzing cost-benefit 

analysis, (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook) 

(NRC, 1997a). The guidance involves determining the net value for each SAMA according to 

the following formula: 

Net Value = (APE + AOC + AOE + AOSC) – COE, where, 

APE = present value of averted public exposure ($) 

AOC = present value of averted offsite property damage costs ($) 

AOE = present value of averted occupational exposure costs ($) 

AOSC = present value of averted onsite costs ($) 

COE = cost of enhancement ($) 

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 

benefit associated with the SAMA and it is not considered cost-beneficial. FPL-DA’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). FPL-DA analyzed the SAMA using 7 percent and 

provided a sensitivity analysis using the 3 percent discount rate in order to capture SAMAs that 

may be cost-effective using the lower discount rate, as well as the higher, baseline rate. In 

addition, FPL-DA provided the results of a sensitivity study using an 8.5 percent discount rate 

which was being used by FPL-DA for project cost estimating purposes at the time of the 

submittal (FPL-DA, 2008). This analysis is sufficient to satisfy NRC policy in Revision 4 of 

NUREG/BR-0058. 

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula: 

APE = Annual reduction in public exposure (Δperson-rem/year) 

x monetary equivalent of unit dose ($2,000 per person-rem) 

x present value conversion factor (10.76 based on a 20-year period with a 

7-percent discount rate) 
Appendix F 

October 2010 F-29 NUREG-1437, Supplement 42 

As stated in NUREG/BR-0184 (NRC, 1997a), it is important to note that the monetary value of 

the public health risk after discounting does not represent the expected reduction in public 

health risk due to a single accident. Rather, it is the present value of a stream of potential 

losses extending over the remaining lifetime (in this case, the renewal period) of the facility. 

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an 

accident could occur at any time over the renewal period, and the effect of discounting these 

potential future losses to present value. For the purposes of initial screening, which assumes 

elimination of all severe accidents, FPL-DA calculated an APE of approximately $666,000 for 

the 20-year license renewal period (including the 1.57 factor to account for external events). 

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 

This term represents the sum of the frequency-weighted offsite economic costs for each release 

category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which 

assumes all severe accidents are eliminated, FPL-DA calculated an annual offsite economic risk 

of about $76,700 based on the internal events Level 3 risk analysis. This results in a discounted 

value of approximately $1,290,000 for the 20-year license renewal period (including the 1.57 

factor to account for external events). 

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 

FPL-DA derived the values for AOE from information provided in Section 5.7.3 of the regulatory 

analysis handbook (NRC 1997a). Best estimate values provided for immediate occupational 

dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem over a 10-year 

cleanup period) were used. The present value of these doses was calculated using the 

equations provided in the handbook in conjunction with a monetary equivalent of unit dose of 

$2,000 per person-rem, a real discount rate of 7 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, FPL-DA calculated an AOE of approximately $6,500 for the 

20-year license renewal period (including the 1.57 factor to account for external events). 

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 
Appendix F 

NUREG-1437, Supplement 42 F-30 October 2010 

accidents only, not for severe accidents. FPL-DA derived the values for AOSC based on 

information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook 

(NRC 1997a). 

FPL-DA divided this cost element into two parts – the onsite cleanup and decontamination cost, 

also commonly referred to as averted cleanup and decontamination costs (ACC), and the 

replacement power cost (RPC). 

ACCs were calculated using the following formula: 

ACC= Annual CDF reduction 

x present value of cleanup costs per core damage event 

x present value conversion factor 

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 

NUREG/BR-0184 to be $1.5 x 109

 (undiscounted). This value was converted to present costs 

over a 10-year cleanup period and integrated over the term of the proposed license extension. 

Long-term RPCs 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 

FPL-DA based its calculations on a DAEC net output of 610 megawatt-electric (MWe) and 

scaled down from the 910 MWe reference plant in NUREG/BR-0184 (NRC, 1997a). Therefore 

FPL-DA applied a power scaling factor of 610/910 to determine the replacement power costs. 

The DAEC net output is stated to include a planned power uprate. 

For the purposes of initial screening, which assumes all severe accidents are eliminated, 

FPL-DA calculated AOSC of approximately $296,000 for the 20-year license renewal period 

(including the 1.57 factor to account for external events). 

Using the above equations, FPL-DA estimated the total present dollar-value equivalent 

associated with completely eliminating severe accidents from both internal and external events 

at DAEC to be about $2.26M, also referred to as the Maximum Attainable Benefit (MAB). 
Appendix F 

October 2010 F-31 NUREG-1437, Supplement 42 

FPL-DA’s Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a 

7 percent discount rate, and considering the impact of external events), FPL-DA identified two 

potentially cost-beneficial SAMAs. The potentially cost-beneficial SAMAs are: 

● SAMA 156 – Provide an alternate source of water for the RHRSW/ESW pit 

● SAMA 166 – Increase the reliability of the low pressure ECCS RPV low 

pressure permissive circuitry. Install manual bypass of low pressure permissive. 

FPL-DA analyzed additional analyses to evaluate the impact of parameter choices (alternative 

discount rates and remaining plant life) and uncertainties on the results of the SAMA 

assessment. For the Phase I screening, FPL-DA assumed that there was sufficient margin in 

the maximum benefit estimation that this screening would not be impacted by the sensitivity and 

uncertainty analyses. For the Phase II cost benefit analyses, a quantitative assessment 

indicated that, except for SAMA 117, even with the sensitivity and uncertainty impacts 

considered, the costs of the originally non-cost beneficial SAMAs exceed the benefits and no 

additional SAMA candidates were determined to be potentially cost-beneficial (FPL-DA, 2008). 

As discussed above, the benefit of SAMA 117, increase boron concentration or enrichment, was 

originally underestimated in the ER. FPL-DA provided a revised benefit estimate in response to 

an NRC staff RAI and concluded that this SAMA would also be potentially cost-beneficial when 

considering the impact of uncertainties (NextEra, 2009b). 

FPL-DA indicated that they plan to further evaluate these SAMAs for possible implementation, 

and have included these items in FPL-DA’s corrective action program (FPL-DA, 2008; 

NextEra, 2009b). 

The potentially cost-beneficial SAMAs and FPL-DA’s plans for further evaluation of these 

SAMAs are discussed in detail in Section F.6.2. 

F.6.2 Review of FPL Energy Duane Arnold, LLC’s Cost-Benefit Evaluation 

The cost-benefit analysis analyzed by FPL-DA was based primarily on NUREG/BR-0184 

(NRC, 1997a) and the NRC staff review stated the analysis was conducted consistent with this 

guidance. 

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). FPL-DA provided a base set of results using the 

7 percent discount rate and a sensitivity study using the 3 percent discount rate (FPL-DA, 

2008). 

SAMAs identified primarily on the basis of the internal events analysis could provide benefits in 

certain external events, in addition to internal events. To account for the additional benefits in 

external events, FPL-DA multiplied the internal event benefits for each internal event SAMA by 

a factor of 1.57, which is the ratio of the total CDF from internal and external events to the 

internal event CDF. This factor was based on a combined fire and seismic CDF from the DAEC 

external events PRA (3.74 x 10-6 per year rounded up to 4 x 10-6 per year) plus the high wind 

and tornado CDF from the IPEEE (1.4 x 10-7 per year rounded up to 2 x 10-7 per year) plus the 
Appendix F 

NUREG-1437, Supplement 42 F-32 October 2010 

screening values for external flooding and transportation events (1 x 10-6 per year for each). 

The external event CDF is thus 56.4 percent of the internal events CDF (1.08 x 10-5 per year 

rounded up to 1.1 x 10-5 per year). The total CDF is thus 1.564 times the internal events CDF 

and this was rounded up to 1.57 (NextEra, 2009a). 

Potential benefits in external events were estimated in this manner, since the external-event 

models are generally less detailed than the internal-event models, do not lend themselves to 

quantifying the benefits of the specific plant changes associated with internal-event SAMAs and 

for DAEC, the external events models were not extended to incorporate the assessment of 

releases to the environment. For example, the benefits of a procedural change associated with 

an important internal event sequence cannot be readily assessed using the seismic-risk model if 

that operator action or system is not represented in the seismic-risk model. The use of a 

multiplier on the benefits obtained from the internal events PRA to incorporate the impact of 

external events implicitly assumes that each SAMA would offer the same percentage reduction 

in external-event CDF and population dose as it offers in internal events. While this provides 

only a rough approximation of the potential benefits, such an adjustment was considered 

appropriate given the lack of information on which to base a more precise risk reduction 

estimate for external events. In view of the licensee’s further evaluation of the impacts of the 

use of a multiplier on the SAMA screening (as part of the uncertainty assessment discussed 

below), the NRC staff agrees that the use of such a multiplier for external events is reasonable. 

FPL-DA analyzed additional SAMA sensitivity issues, including use of a 3 percent discount rate, 

use of a longer plant life, and use of different evacuation assumptions. It also considered the 

impact of unresolved peer review findings and recent plant modifications on the results of the 

SAMA analysis. These analyses did not identify additional potentially cost-beneficial SAMAs 

beyond those already identified. 

FPL-DA considered the impact that possible increases in benefits from analysis uncertainties 

would have on the results of the SAMA assessment. In the ER, FPL-DA states that upper 

bound benefits were estimated by multiplying the results using the mean risk values by an 

uncertainty factor of 2.5. This factor was stated to be based on a review of similar PRAs. While 

the factor does not represent an upper bound, it does represent the ratio of the 95th percentile 

CDF to the mean CDF and is considered by the NRC staff to be appropriate for use in the 

SAMA sensitivity analyses. 

FPL-DA’s conclusion that there was sufficient margin in the maximum benefit estimation that the 

Phase I screening would not be impacted by the sensitivity and uncertainty analyses was 

reviewed by the NRC staff and further information was requested in an RAI (NRC, 2009a). 

FPL-DA indicated that the MAB was predicated on the basis of elimination of all the risk, that 

none of the Phase I SAMAs screened out (based on exceeding the MAB) would be expected to 

achieve more than about a 37 percent reduction in risk (equal to elimination of all loss of offsite 

power risk), and that all of the screened SAMAs involve complex design changes with a 

correspondingly high cost (NextEra, 2009a). Based on the additional information provided, the 

NRC staff agrees with the conclusion that the sensitivity and uncertainty analyses will not result 

in any additional Phase I SAMAs being retained for further evaluation in the Phase II 

cost-benefit analyses. 

As indicated in Section F.2.2, the NRC staff developed an independent conservative 

assessment of the seismic CDF that is approximately an order of magnitude greater than that 

indicated by the DAEC seismic PRA. If this higher value is used, the external events multiplier 

would be increased to 2.3 (from the value of 1.57 used in the ER analysis). The NRC staff 
Appendix F 

October 2010 F-33 NUREG-1437, Supplement 42 

requested that FPL-DA assess the impact on SAMA analysis results if this higher multiplier were 

used in the cost-benefit analysis. In response, FPL-DA indicated that only three SAMAs would 

become potentially cost-beneficial using the higher external events multiplier combined with the 

CDF uncertainty factor described above, (i.e., SAMAs 52, 53, and 163). For SAMA 52, replace 

ECCS pump motors with air-cooled motors, and for SAMA 55, implement modifications to allow 

manual alignment of the fire water system to RHR heat exchangers, FPL-DA provided updated 

cost estimates from other SAMA evaluations for similar modifications that were considerably 

higher than those originally estimated for DAEC. Based on the updated cost estimates, these 

SAMAs would not be cost-beneficial even for the higher external events multiplier combined 

with the CDF uncertainty factor. For SAMA 163, improve the reliability of the RWS system 

control valves; the benefit was originally assessed assuming that the modification would 

eliminate all risk associated with the RWS system. FPL-DA argued that based on a more 

realistic estimate of the risk reduction, this SAMA would also not be cost beneficial even for the 

higher external events multiplier combined with CDF uncertainty (NextEra, 2009a). The NRC 

staff agrees with these conclusions. 

As indicated in Section F.4, the NRC staff questioned FPL-DA on the risk reduction potential for 

certain SAMAs, as summarized below. 

● For SAMA 41, provide capability for alternate injection via the RWCU, the ER 

reported a benefit of $345 thousand and an implementation cost of $1.3 million 

assuming the SAMA is only beneficial in events involving steamline breaks or 

stuck open safety relief valves. In response to an NRC staff RAI, FPL-DA 

indicated that the cost associated with modifying the RWCU to allow injection at 

higher pressures would increase to $4 million (NextEra 2009b). While FPL-DA 

did not provide a revised assessment of the benefit associated with the more 

capable RWCU modification, the NRC estimates that the benefit for the more 

extensive RWCU modification would be between that determined for SAMA 27 

for an independent active or passive high pressure injection system 

($570 thousand) and that for SAMA 28 for an additional high pressure injection 

pump with independent diesel ($814 thousand). The NRC staff concludes that 

the more extensive modification for SAMA 41 would not be cost beneficial for 

the base evaluation or for any of the sensitivity study or uncertainty cases. 

● For SAMA 117, increase boron concentration or enrichment. The evaluation 

reported in the ER assumed that this SAMA eliminated mechanical failures of 

the standby liquid control (SLC) system rather than reduce human errors 

associated with initiating SLC. When reevaluated based on the RRW of the 

operator’s failure to inject SLC early, FPL-DA indicated that this SAMA would 

provide a 9.9 percent reduction in CDF and a benefit of approximately $200 

thousand (NextEra, 2009b). Considering uncertainty, this benefit could increase 

to $500 thousand. Since the cost for implementing this SAMA is $400 

thousand, FPL-DA concluded that this SAMA would be potentially 

cost-beneficial. FPL-DA has indicated that this SAMA has been included in the 

site corrective action program for further evaluation (NextEra, 2009b). 

The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 

that could achieve much of the risk reduction at a lower cost. The NRC staff asked the licensee 

to evaluate several lower cost alternatives to the SAMAs considered in the ER, including 

SAMAs that had been found to be potentially cost-beneficial at other BWR plants. These 
Appendix F 

NUREG-1437, Supplement 42 F-34 October 2010 

alternatives included: (1) the use of a portable diesel driven pump for low pressure injection 

through existing systems, (2) use of a portable diesel driven pump to provide makeup to the 

RHRSW/ESW pit, (3) use of a portable DC power supply to maintain DC power availability for 

SBO sequences, (4) improve the reliability of cross-ties between the RHR system and the RHR 

service water, the fire system or other systems that could be used for alternate low pressure 

injection, and (5) create a procedure to maximize CRD flow to provide early and/or late injection. 

FPL-DA addressed each of these alternatives and stated that each has been implemented by 

DAEC procedures. For item 4, FPL-DA described the steps already in place to ensure the 

reliability of the RHR cross-ties. No additional reliability improvements were identified. The 

NRC staff concludes that these alternative SAMAs have been satisfactorily addressed. 

FPL-DA indicated that the three potentially cost-beneficial SAMAs (i.e., SAMAs 117, 156 and 

166) have been entered in DAEC’s site corrective action program for further consideration 

(FPL-DA, 2008; NextEra, 2009b). 

The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs 

discussed above, the costs of the other SAMAs evaluated would be higher than the associated 

benefits. 

F.7. Conclusions 

FPL-DA compiled a list of 167 SAMAs based on a review of: (1) the most significant basic 

events from the plant-specific PRA, (2) insights from the plant-specific IPE and IPEEE, (3) the 

generic SAMA candidates from NEI 05-01, and (4) a review of the generic and site-specific 

SAMAs by an expert panel to identify any additional candidates. A qualitative screening 

removed SAMA candidates that: (1) are not applicable to DAEC due to design differences, (2) 

have already been implemented at DAEC, (3) are similar and could be combined with another 

SAMA, and (4) have excessive implementation costs that will obviously exceed the maximum 

benefit. Based on this screening, 143 SAMAs were eliminated leaving 24 candidate SAMAs for 

evaluation. 

For the remaining SAMA candidates, a more detailed design and cost estimate were developed 

as shown in Table F-6. The cost-benefit analyses in the ER showed that two of the SAMA 

candidates were potentially cost-beneficial in the baseline analysis (i.e., Phase II SAMAs 156 

and 166). FPL-DA analyzed additional analyses to evaluate the impact of parameter choices 

and uncertainties on the results of the SAMA assessment. One additional SAMA 

(i.e., SAMA 117) was identified as potentially cost-beneficial in the ER. FPL-DA has indicated 

that these potentially cost-beneficial SAMAs have been entered into the DAEC site corrective 

action program for further consideration. 

The NRC staff reviewed the FPL-DA 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 analyzed by FPL-DA are reasonable 

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 

events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 

area was minimized by improvements that have been realized as a result of the IPEEE process, 

and inclusion of a multiplier to account for external events. 

The NRC staff concurs with FPL-DA’s identification of areas in which risk can be further reduced 

in a cost-beneficial manner through the implementation of the identified, potentially 
Appendix F 

October 2010 F-35 NUREG-1437, Supplement 42 

cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff 

agrees that further evaluation of these SAMAs by FPL-DA is warranted. However, these 

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

operation. Therefore, they need not be implemented as part of license renewal pursuant to Title 

10 of the Code of Federal Regulations (CFR), Part 54. 

F.8. References 

Electric Power Research Institute (EPRI). 1991. “A Methodology for Assessment of Nuclear 

Power Plant Seismic Margin,” Implementation Guide NP-6041, Revision 1, Palo Alto, CA, 

August 1991. 

FPL Energy Duane Arnold, LLC, (FPL-DA). 2008. Duane Arnold Energy Center – License 

Renewal Application, Applicant’s Environmental Report, Operating License Renewal Stage, 

September 2008, Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML082980480. 

FPL Energy Duane Arnold, LLC, (FPL-DA). 2009. Letter from Richard L. Anderson, FPL 

Energy Duane Arnold, LLC, to NRC Document Control Desk, Subject: License Renewal 

Application, Supplement: Changes Resulting from Issues Raised in the Review Status of the 

License Renewal Application for the Duane Arnold Energy Center, January 23, 2009, ADAMS 

Accession No. ML090280418. 

IES Utilities, Inc. (IES). 1995a. “Duane Arnold Energy Center Individual Plant Examination for 

External Events,” November 1995. 

IES Utilities, Inc. (IES). 1995b. Letter from John F. Franz, IES Utilities, Inc., to William T. 

Russell, USNRC, Subject: Duane Arnold Energy Center Docket No: 50-331 Op. License No: 

DPR-49 Response to Request for Additional Information on Individual Plant Examination (IPE) 

dated January 6, 1995, June 26, 1995. 

Iowa Electric Light and Power Co. (IELP). 1992. “Duane Arnold Energy Center Individual Plant 

Examination,” November 1992. 

Kennedy, R.P. 1999. “Overview of Methods for Seismic PRA and Margin Analysis Including 

Recent Innovations,” Proceedings of the OECD-NEA Workshop of Seismic Risk, Tokyo, Japan, 

10–12 August 1999 

NextEra Energy Duane Arnold, LLC (NextEra). 2009a. Letter from Richard L. Anderson, 

NextEra Energy Duane Arnold, LLC Energy, to NRC Document Control Desk, Subject: 

Response to Request for Additional Information Regarding Severe Accident Mitigation 

Alternatives for Duane Arnold Energy Center, July 9, 2009. 

NextEra Energy Duane Arnold, LLC (NextEra). 2009b. Letter from Christopher R. Costanzo, 

NextEra Energy Duane Arnold, LLC Energy, to NRC Document Control Desk, Subject: 

Clarification of Response to Request for Additional Information Regarding Severe Accident 

Mitigation Alternatives for Duane Arnold Energy Center, September 23, 2009. 

NextEra Energy Duane Arnold, LLC (NextEra). 2009c. Letter from Christopher R. Costanzo, 

NextEra Energy Duane Arnold, LLC Energy, to NRC Document Control Desk, Subject: First 

Annual Amendment to the Duane Arnold Energy Center License Renewal Application, 

September 30, 2009. 

Nuclear Energy Institute (NEI). 2005. “Severe Accident Mitigation Alternative (SAMA) Analysis 

Guidance Document,” NEI 05-01, Rev. A, November 2005. 
Appendix F 

NUREG-1437, Supplement 42 F-36 October 2010 

Seismic Qualification Users Group (SQUG). 1992. “Generic Implementation Procedure” 

Rev. 2, February 1992. 

State Library. 2006. “Projections of Total Population of the U.S., Iowa, and its Counties: 

2000-2003,” adapted from Woods & Poole Economics, Inc. Washington D.C., June 2006. 

TOM COD Data Systems (TOMCOD). 2003. “Evacuation Time Estimate Study for the Duane 

Arnold Emergency Center Emergency Planning Zone,” Decorah, Iowa, June 19, 2003. 

U.S. Department of Agriculture (USDA). 1998. “1997 Census of Agriculture,” National 

Agriculture Statistics Service. Available URL: 

http://www.nass.usda.gov/census/census97/volume1/vol1pubs.htm 

U.S. Department of Agriculture (USDA). 2002. “2002 Census of Agriculture, Volume 1 

Geographic Area Census, State County Data.” Available URL: 

http://www.nass.usda.gov/Census/Create_Census_US_CNTY.jsp 

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, “Individual Plant 

Examination for Severe Accident Vulnerabilities,” November 23, 1988. 

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). 1994. Revised Livermore Seismic Hazard 

Estimates for Sixty-Nine Nuclear Plant Sites East of the Rocky Mountains, NUREG-1488, 

Washington, D.C., April 1994. 

U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from Glenn B. Kelly, U.S. NRC, to 

Lee Liu, Subject: Duane Arnold energy Center - Individual Plant Examination (IPE) Submittal - 

Internal Events (TAC No. M74407), November 12, 1996. 

U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 

Handbook, NUREG/BR-0184, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program: 

Perspectives on Reactor Safety and Plant Performance, NUREG-1560, Washington, D.C. 

U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from Richard J. Laufer, U.S. NRC, 

to Lee Liu, IES Utilities Inc., Subject: Safety Evaluation Report for Unresolved Safety Issue A-46 

at the Duane Arnold Energy Center (TAC No. M69444), July 29, 1998. 

U.S. Nuclear Regulatory Commission (NRC). 2000. Letter from Brenda L. Mozafari, U.S. NRC, 

to Eliot Protsch, IES Utilities, Subject: Review of Individual Plant Examination of External Events 

(IPEEE) Submittal, Duane Arnold Energy Center (TAC No. M83618), March 10, 2000. 

U. S. Nuclear Regulatory Commission (NRC). 2002. Perspectives Gained From the Individual 

Plant Examination of External Events (IPEEE) Program, Volumes 1 and 2, Final Report, 

NUREG-1742, Washington, D.C., April 2002. 

U.S. Nuclear Regulatory Commission (NRC). 2003. SECPOP2000: Sector Population, Land 

Fraction, and Economic Estimation Program, NUREG/CR-6525, Rev. 1, Sandia National 

Laboratories, August 2003. 

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. 

U.S. Nuclear Regulatory Commission (NRC). 1991a. Procedural and Submittal Guidance for 

the Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, 

NUREG-1407, Washington, D.C., June 1991. 
Appendix F 

October 2010 F-37 NUREG-1437, Supplement 42 

U.S. Nuclear Regulatory Commission (NRC). 1991b. Generic Letter No. 88-20, Supplement 4, 

“Individual Plant Examination of External Events for Severe Accident Vulnerabilities, 

NUREG-1407, Washington, D.C., June 28, 1991. 

U.S. Nuclear Regulatory Commission (NRC). 2009a. Letter from Charles Eccleston, U.S. NRC, 

to Richard L. Anderson, FPL-DA, Subject: Request for Additional Information, Including a 

Revision to RAI 3.H, Regarding Severe Accident Mitigation Alternatives for the Duane Arnold 

Energy Center (TAC No. MD9770), June 25, 2009. 

U.S. Nuclear Regulatory Commission (NRC). 2009b. Letter from Charles Eccleston, U.S. NRC, 

to Richard L. Anderson, FPL-DA, Subject: Clarification of Responses to the Request for 

Additional Information Regarding Severe Accident Mitigation Alternatives for the License 

Renewal of the Duane Arnold Energy Center (TAC No. MD9770), August 24, 2009.