Generic Environmental Impact 

Statement for License 

Renewal of Nuclear Plants

Supplement 49

Regarding

Limerick Generating Station,

Units 1 and 2

Draft Report for Comment

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 49
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Generic Environmental Impact 

Statement for License Renewal 

of Nuclear Plants

Supplement 49

Regarding 

Limerick Generating Station,

Units 1 and 2

Draft Report for Comment

Manuscript Completed: March 2013

Date Published: April 2013

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 49
1 COMMENTS ON DRAFT REPORT

2 Any interested party may submit comments on this report for consideration by the NRC staff. 

3 Comments may be accompanied by additional relevant information or supporting data. Please 

4 specify the report number NUREG-1437, Supplement 49, in your comments, and send them by 

5 the end of the comment period specified in the Federal Register notice announcing the 

6 availability of this report. 

7 Addresses: You may submit comments by any one of the following methods. Please include 

8 Docket ID NRC-2011-0166 in the subject line of your comments. Comments submitted in 

9 writing or in electronic form will be posted on the NRC website and on the Federal rulemaking 

10 website http://www.regulations.gov. 

11 Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents 

12 filed under Docket ID NRC-2011-0166. Address questions about NRC dockets to Carol 

13 Gallagher at 301-492-3668 or by e-mail at Carol.Gallagher@nrc.gov. 

14 Mail comments to: Cindy Bladey, Chief, Rules, Announcements, and Directives Branch

15 (RADB), Division of Administrative Services, Office of Administration, Mail Stop: 

16 TWB-05-B01M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Faxes 

17 may be sent to RADB at 301-492-3446.

18 For any questions about the material in this report, please contact Leslie Perkins, NRC 

19 Environmental Project Manager, at 1-800-368-5642, extension 2375, or by e-mail at 

leslie.perkins@nrc.gov

21 Please be aware that any comments that you submit to the NRC will be considered a public 

22 record and entered into the Agencywide Documents Access and Management System 

23 (ADAMS). Do not provide information you would not want to be publicly available.

NUREG-1437, Supplement 49, has been reproduced from the best available copy.
iii

1 ABSTRACT

2 This draft supplemental environmental impact statement has been prepared in response to an

3 application submitted by Exelon Generation Company, LLC (Exelon) to renew the operating 

4 license for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20 years.

5 This draft supplemental environmental impact statement includes the preliminary analysis that 

6 evaluates the environmental impacts of the proposed action and alternatives to the proposed 

7 action. Alternatives considered include natural gas combined-cycle (NGCC); supercritical

8 pulverized coal; new nuclear; wind power; purchased power; and not renewing the license (the 

9 no action alternative).

10 The U.S. Nuclear Regulatory Commission’s preliminary recommendation is that the adverse 

11 environmental impacts of license renewal for LGS are not great enough to deny the option of 

12 license renewal for energy planning decisionmakers. This recommendation is based on the 

13 following:

14  the analysis and findings in NUREG-1437, Volumes 1 and 2, Generic 

15 Environmental Impact Statement for License Renewal of Nuclear Plants; 

16  the environmental report submitted by Exelon;

17  consultation with Federal, state, and local agencies;

18  the NRC’s environmental review; and

19  consideration of public comments received during the scoping process.

v 

1 TABLE OF CONTENTS

2 ABSTRACT.............................................................................................................................. iii

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

4 FIGURES.................................................................................................................................. xi

5 TABLES ................................................................................................................................. xiii

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

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

8 1.0 PURPOSE AND NEED FOR ACTION.............................................................................. 1-1

9 1.1. Proposed Federal Action............................................................................................... 1-1

10 1.2. Purpose and Need for the Proposed Federal Action ..................................................... 1-1

11 1.3. Major Environmental Review Milestones....................................................................... 1-2

12 1.4. Generic Environmental Impact Statement..................................................................... 1-3

13 1.5. Supplemental Environmental Impact Statement............................................................ 1-6

14 1.6. Cooperating Agencies................................................................................................... 1-6

15 1.7. Consultations................................................................................................................ 1-6

16 1.8. Correspondence ........................................................................................................... 1-7

17 1.9. Status of Compliance.................................................................................................... 1-7

18 1.10. References.................................................................................................................. 1-7

19 2.0 AFFECTED ENVIRONMENT............................................................................................ 2-1

20 2.1. Facility Description........................................................................................................ 2-1

21 2.1.1. Reactor and Containment Systems.................................................................. 2-1

22 2.1.2. Radioactive Waste Management ..................................................................... 2-1

23 2.1.3. Nonradiological Waste Management................................................................ 2-7

24 2.1.4. Plant Operation and Maintenance.................................................................... 2-9

25 2.1.5. Power Transmission System............................................................................ 2-9

26 2.1.6. Cooling and Auxiliary Water Systems ............................................................ 2-16

27 2.1.7. Facility Water Use and Quality....................................................................... 2-21

28 2.2. Surrounding Environment ........................................................................................... 2-23

29 2.2.1. Land Use ....................................................................................................... 2-24

30 2.2.2. Air Quality and Meteorology........................................................................... 2-25

31 2.2.3. Geologic Environment.................................................................................... 2-27

32 2.2.4. Surface Water Resources .............................................................................. 2-30

33 2.2.5. Groundwater Resources ................................................................................ 2-34

34 2.2.6. Aquatic Resources......................................................................................... 2-37

35 2.2.7. Terrestrial Resources..................................................................................... 2-47

36 2.2.8. Protected Species and Habitats..................................................................... 2-50

37 2.2.9. Socioeconomics............................................................................................. 2-65

38 2.2.10. Historic and Archaeological Resources.......................................................... 2-80
Table of Contents

vi

1 2.3. Related Federal and State Activities ........................................................................... 2-84

2 2.4. References ................................................................................................................. 2-84

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

4 3.1. References ................................................................................................................... 3-3

5 4.0 ENVIRONMENTAL IMPACTS OF OPERATION .............................................................. 4-1

6 4.1. Land Use ...................................................................................................................... 4-1

7 4.2. Air Quality ..................................................................................................................... 4-2

8 4.3. Geologic Environment................................................................................................... 4-2

9 4.3.1. Geology and Soils............................................................................................ 4-2

10 4.4. Surface Water Resources............................................................................................. 4-3

11 4.4.1. Generic Surface Water Issues ......................................................................... 4-3

12 4.4.2. Surface Water Use Conflicts ............................................................................ 4-3

13 4.5. Groundwater Resources ............................................................................................... 4-4

14 4.5.1. Generic Groundwater Issues ........................................................................... 4-5

15 4.5.2. Groundwater Use and Quality Conflicts ........................................................... 4-5

16 4.6. Aquatic Resources........................................................................................................ 4-7

17 4.6.1. Exposure of Aquatic Organisms to Radionuclides............................................ 4-8

18 4.7. Terrestrial Resources.................................................................................................... 4-8

19 4.7.1. Generic Terrestrial Resources Issues .............................................................. 4-9

20 4.7.2. Effects on Terrestrial Resources (Non-Cooling System Impacts)..................... 4-9

21 4.8. Protected Species and Habitats.................................................................................. 4-10

22 4.8.1. Correspondence with Federal and State Agencies......................................... 4-10

23 4.8.2. Aquatic Species and Habitats ........................................................................ 4-11

24 4.8.3. Terrestrial Species and Habitats .................................................................... 4-16

25 4.9. Human Health............................................................................................................. 4-21

26 4.9.1. Generic Human Health Issues ....................................................................... 4-21

27 4.9.2. Radiological Impacts of Normal Operations ................................................... 4-22

28 4.9.3. Microbiological Organisms ............................................................................. 4-25

29 4.9.4. Electromagnetic Fields—Acute Effects .......................................................... 4-26

30 4.9.5. Electromagnetic Fields—Chronic Effects ....................................................... 4-27

31 4.10. Socioeconomics ........................................................................................................ 4-28

32 4.10.1. Generic Socioeconomic Issues...................................................................... 4-28

33 4.10.2. Housing ......................................................................................................... 4-29

34 4.10.3. Public Services—Public Utilities..................................................................... 4-29

35 4.10.4. Offsite Land Use ............................................................................................ 4-30

36 4.10.5. Public Services—Transportation.................................................................... 4-31

37 4.10.6. Historic and Archaeological Resources.......................................................... 4-31

38 4.10.7. Environmental Justice.................................................................................... 4-32

39 4.10.8. Conclusion..................................................................................................... 4-39

40 4.11. Evaluation of New and Potentially Significant Information ......................................... 4-39
Table of Contents

vii

1 4.12. Cumulative Impacts................................................................................................... 4-41

2 4.12.1. Air Quality ...................................................................................................... 4-42

3 4.12.2. Water Resources ........................................................................................... 4-43

4 4.12.3. Aquatic Resources......................................................................................... 4-46

5 4.12.4. Terrestrial Resources..................................................................................... 4-48

6 4.12.5. Human Health................................................................................................ 4-50

7 4.12.6. Socioeconomics............................................................................................. 4-51

8 4.12.7. Cultural Resources ........................................................................................ 4-52

9 4.12.8. Summary of Cumulative Impacts ................................................................... 4-52

10 4.13. References................................................................................................................ 4-54

11 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS...................................... 5-1

12 5.1. Design-Basis Accidents ................................................................................................ 5-1

13 5.2. Severe Accidents.......................................................................................................... 5-2

14 5.3. Severe Accident Mitigation Alternatives ........................................................................ 5-3

15 5.4. References ................................................................................................................. 5-14

16 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

17 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS...................... 6-1

18 6.1. The Uranium Fuel Cycle ............................................................................................... 6-1

19 6.2. Greenhouse Gas Emissions ......................................................................................... 6-3

20 6.2.1. Existing Studies ............................................................................................... 6-3

21 6.2.2. Conclusions: Relative Greenhouse Gas Emissions......................................... 6-9

22 6.3. References ................................................................................................................. 6-10

23 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING................................................. 7-1

24 7.1. Decommissioning.......................................................................................................... 7-1

25 7.2. References ................................................................................................................... 7-2

26 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES ........................................................ 8-1

27 8.1 Natural Gas Combined-Cycle Alternative ...................................................................... 8-5

28 8.1.1. Air Quality ........................................................................................................ 8-7

29 8.1.2. Groundwater Resources .................................................................................. 8-8

30 8.1.3. Surface Water Resources ................................................................................ 8-9

31 8.1.4. Aquatic Resources......................................................................................... 8-10

32 8.1.5. Terrestrial Resources..................................................................................... 8-11

33 8.1.6. Human Health................................................................................................ 8-12

34 8.1.7. Land Use ....................................................................................................... 8-12

35 8.1.8. Socioeconomics............................................................................................. 8-13

36 8.1.9. Transportation................................................................................................ 8-14

37 8.1.10. Aesthetics ...................................................................................................... 8-14

38 8.1.11. Historic and Archaeological Resources.......................................................... 8-15

39 8.1.12. Environmental Justice.................................................................................... 8-15

40 8.1.13. Waste Management....................................................................................... 8-16
Table of Contents

viii

1 8.2. Supercritical Pulverized Coal-Fired Alternative ........................................................... 8-17

2 8.2.1. Air Quality ...................................................................................................... 8-18

3 8.2.2. Groundwater Resources ................................................................................ 8-20

4 8.2.3. Surface Water Resources .............................................................................. 8-21

5 8.2.4. Aquatic Resources......................................................................................... 8-22

6 8.2.5. Terrestrial Resources..................................................................................... 8-22

7 8.2.6. Human Health................................................................................................ 8-23

8 8.2.7. Land Use ....................................................................................................... 8-24

9 8.2.8. Socioeconomics............................................................................................. 8-24

10 8.2.9. Transportation................................................................................................ 8-25

11 8.2.10. Aesthetics ...................................................................................................... 8-26

12 8.2.11. Historic and Archaeological Resources.......................................................... 8-26

13 8.2.12. Environmental Justice.................................................................................... 8-26

14 8.2.13. Waste Management....................................................................................... 8-27

15 8.3. New Nuclear ............................................................................................................... 8-28

16 8.3.1. Air Quality ...................................................................................................... 8-29

17 8.3.2. Groundwater Resources ................................................................................ 8-30

18 8.3.3. Surface Water Resources .............................................................................. 8-31

19 8.3.4. Aquatic Resources......................................................................................... 8-31

20 8.3.5. Terrestrial Resources..................................................................................... 8-32

21 8.3.6. Human Health................................................................................................ 8-32

22 8.3.7. Land Use ....................................................................................................... 8-33

23 8.3.8. Socioeconomics............................................................................................. 8-33

24 8.3.9. Transportation................................................................................................ 8-34

25 8.3.10. Aesthetics ...................................................................................................... 8-34

26 8.3.11. Historic and Archaeological Resources .......................................................... 8-35

27 8.3.12. Environmental Justice.................................................................................... 8-35

28 8.3.13. Waste Management....................................................................................... 8-36

29 8.4. Wind Alternative.......................................................................................................... 8-37

30 8.4.1. Air Quality ...................................................................................................... 8-39

31 8.4.2. Groundwater Resources ................................................................................ 8-39

32 8.4.3. Surface Water Resources .............................................................................. 8-40

33 8.4.4. Aquatic Resources......................................................................................... 8-40

34 8.4.5. Terrestrial Resources..................................................................................... 8-41

35 8.4.6. Human Health................................................................................................ 8-41

36 8.4.7. Land Use ....................................................................................................... 8-42

37 8.4.8. Socioeconomics............................................................................................. 8-43

38 8.4.9. Transportation................................................................................................ 8-44

39 8.4.10. Aesthetics ...................................................................................................... 8-44

40 8.4.11. Historic and Archaeological Resources.......................................................... 8-44
Table of Contents

ix

1 8.4.12. Environmental Justice.................................................................................... 8-45

2 8.4.13. Waste Management....................................................................................... 8-45

3 8.5. Purchased Power ....................................................................................................... 8-46

4 8.6. Alternatives Considered But Dismissed ...................................................................... 8-49

5 8.6.1. Solar Power ................................................................................................... 8-49

6 8.6.2. Combination Alternative: Wind, Solar, and NGCC......................................... 8-57

7 8.6.3. Combination Alternative: Wind and Compressed Air Energy Storage............. 8-65

8 8.6.4. Wood Waste .................................................................................................. 8-74

9 8.6.5. Conventional Hydroelectric Power ................................................................. 8-75

10 8.6.6. Ocean Wave and Current Energy .................................................................. 8-75

11 8.6.7. Geothermal Power......................................................................................... 8-76

12 8.6.8. Municipal Solid Waste.................................................................................... 8-77

13 8.6.9. Biomass Fuels ............................................................................................... 8-78

14 8.6.10. Oil-Fired Power.............................................................................................. 8-78

15 8.6.11. Delayed Retirement ....................................................................................... 8-78

16 8.6.12. Fuel Cells....................................................................................................... 8-79

17 8.6.13. Coal-Fired Integrated Gasification Combined-Cycle....................................... 8-79

18 8.6.14. Demand-Side Management ........................................................................... 8-80

19 8.7. No-Action Alternative .................................................................................................. 8-81

20 8.7.1. Air Quality ...................................................................................................... 8-81

21 8.7.2. Groundwater Resources ................................................................................ 8-82

22 8.7.3. Surface Water Resources .............................................................................. 8-82

23 8.7.4. Aquatic and Terrestrial Resources ................................................................. 8-82

24 8.7.5. Human Health................................................................................................ 8-82

25 8.7.6. Land Use ....................................................................................................... 8-82

26 8.7.7. Socioeconomics............................................................................................. 8-82

27 8.7.8. Transportation................................................................................................ 8-83

28 8.7.9. Aesthetics ...................................................................................................... 8-83

29 8.7.10. Historic and Archaeological Resources.......................................................... 8-83

30 8.7.11. Environmental Justice.................................................................................... 8-83

31 8.7.12. Waste Management....................................................................................... 8-83

32 8.8. Alternatives Summary................................................................................................. 8-84

33 8.9. References ................................................................................................................. 8-86

34 9.0 CONCLUSION.................................................................................................................. 9-1

35 9.1. Environmental Impacts of License Renewal.................................................................. 9-1

36 9.2. Comparison of Alternatives ........................................................................................... 9-1

37 9.3. Resource Commitments................................................................................................ 9-2

38 9.3.1. Unavoidable Adverse Environmental Impacts .................................................. 9-2

39 9.3.2. Short-Term Versus Long-Term Productivity ..................................................... 9-2

40 9.3.3. Irreversible and Irretrievable Commitments of Resources................................ 9-3

41 9.4. Recommendations........................................................................................................ 9-4
Table of Contents

x 

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

2 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF 

3 THIS SEIS ARE SENT.................................................................................................. 11-1

4 12.0 INDEX........................................................................................................................... 12-1

5 APPENDIX A COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 

6 UNITS 1 AND 2, ENVIRONMENTAL REVIEW ................................................ A-1

7 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

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

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

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

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

12 APPENDIX F DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

13 IMPACT ANALYSIS......................................................................................... F-1
Table of Contents

xi

1 FIGURES

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

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

4 Figure 2–1. Location of LGS, 6-mile (10-km) vicinity ............................................................. 2-3

5 Figure 2–2. Location of LGS, 50-mile (80-km) region............................................................ 2-4

6 Figure 2–3. LGS site boundary and facility layout ................................................................. 2-5

7 Figure 2–4. Limerick to Cromby 230-kV Transmission Line Route ...................................... 2-11

8 Figure 2–5. Cromby to North Wales 230-kV Transmission Line Route................................ 2-12

9 Figure 2–6. Cromby to Plymouth Meeting 230-kV Transmission Line Route ....................... 2-13

10 Figure 2–7. Limerick to Whitpain 500-kV Transmission Line Route..................................... 2-14

11 Figure 2–8. Location of Schuylkill Pumphouse and LGS Discharge Structure..................... 2-17

12 Figure 2–9. LGS Makeup Water Supply System and Alternative Water Sources within 

13 the Delaware River Basin................................................................................. 2-19

14 Figure 4–1. 2010 Census Minority Block Groups within a 50-mi Radius of the LGS............ 4-35

15 Figure 4–2. 2010 Census Low-Income Block Groups within a 50-mi Radius of LGS........... 4-37

Table of Contents

xiii

1 TABLES

2 Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts of 

3 License Renewal.............................................................................................. xviii

4 Table 2–1. Annual Fuel Use and Estimated Air Emission Estimates for Significant 

5 Sources at LGS............................................................................................... 2-27

6 Table 2–2. NOAA Trust Resources Observed in LGS-related Aquatic Studies.................. 2-46

7 Table 2–3. Federally and Pennsylvania-Listed Aquatic Species........................................ 2-52

8 Table 2–4. Federally and Pennsylvania-listed Terrestrial Species..................................... 2-58

9 Table 2–5. Pennsylvania-listed Bird Species in the Action Area........................................ 2-63

10 Table 2–6. Limerick Generating Station, Employee Residence by County ........................ 2-66

11 Table 2–7. Housing in Berks, Chester, and Montgomery Counties in 2010....................... 2-66

12 Table 2–8. Public Water Supply Systems in Berks, Chester, and Montgomery 

13 Counties (in million gallons per day [mgd]) ...................................................... 2-68

14 Table 2–9. Major Commuting Routes in the Vicinity of LGS, 2010 Average Annual 

15 Daily Traffic Count........................................................................................... 2-69

16 Table 2–10. Population and Percent Growth in Berks, Chester, and Montgomery 

17 Counties from 1970 to 2000 and Projected for 2010-2050............................... 2-71

18 Table 2–11. Demographic Profile of the Population in the Limerick Generating Station 

19 Socioeconomic Region of Influence in 2010.................................................... 2-72

20 Table 2–12. Seasonal Housing in Counties Located within 50 Miles (80 Km) of the 

Limerick Generating Station(a) 21 .......................................................................... 2-73

22 Table 2–13. Migrant Farm Workers and Temporary Farm Labor in Counties Located 

23 within 50 Miles (80 Km) of Limerick Generating Station................................... 2-75

24 Table 2–14. Major Employers by Industry in the LGS ROI in 2010...................................... 2-76

25 Table 2–15. Largest Private Sector Employers – Montgomery County – 2007.................... 2-77

26 Table 2–16. Estimated Income Information for the Limerick Generating Station Region 

27 of Influence in 2010......................................................................................... 2-77

28 Table 2–17. Limerick Generation Station Tax Distribution, 2006–2010 ............................... 2-79

29 Table 2–18. Payment as a Percentage of Taxing Authority 2010 Adopted Budget.............. 2-80

30 Table 3–1. Category 1 Issues Related to Refurbishment .................................................... 3-1

31 Table 3–2. Category 2 Issues Related to Refurbishment .................................................... 3-2

32 Table 4–1. Land Use Issues................................................................................................ 4-1

33 Table 4–2. Air Quality Issues .............................................................................................. 4-2

34 Table 4–3. Surface Water Resources Issues ...................................................................... 4-3

35 Table 4–4. Groundwater Resources Issues ........................................................................ 4-5

36 Table 4–5. Aquatic Resources Issues ................................................................................. 4-7
Table of Contents

xiv

1 Table 4–6. Terrestrial Resources Issues............................................................................. 4-8

2 Table 4–7. Protected Species and Habitats Issues ........................................................... 4-10

3 Table 4–8. Human Health Issues ...................................................................................... 4-21

4 Table 4–9. Socioeconomics Issues................................................................................... 4-28

5 Table 4–10. Summary of Cumulative Impacts on Resource Areas..................................... 4-53

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

7 Table 6–1. Issues Related to the Uranium Fuel Cycle and Waste Management ................. 6-1

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

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

10 Table 6–4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

11 Sources............................................................................................................. 6-8

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

13 Table 8–1. Summary of Alternatives Considered In Depth .................................................. 8-5

14 Table 8–2. Summary of Environmental Impacts of the NGCC Alternative Compared to 

15 Continued Operation of the Existing LGS........................................................ 8-16

16 Table 8–3. Summary of Environmental Impacts of the Supercritical Coal-Fired 

17 Alternative Compared to Continued Operation of LGS .................................... 8-28

18 Table 8–4. Summary of Environmental Impacts of the New Nuclear Alternative 

19 Compared to Continued Operation of the Existing LGS................................... 8-37

20 Table 8–5. Summary of Environmental Impacts of the Wind Alternative Compared to 

21 Continued Operation of the Existing LGS........................................................ 8-46

22 Table 8–6. Summary of Environmental Impacts of Purchased Power Compared to 

23 Continued Operation of the Existing LGS........................................................ 8-49

24 Table 8–7. Summary of Environmental Impacts of the Solar PV Alternative Compared 

25 to Continued Operation of the Existing LGS .................................................... 8-56

26 Table 8–8. Summary of Environmental Impacts of the Combination Alternative 

27 Compared to Continued Operation of the Existing LGS................................... 8-65

28 Table 8–9. Summary of Environmental Impacts of the Wind and CAES Alternative 

29 Compared to Continued Operation of the Existing LGS................................... 8-74

30 Table 8–10. Environmental Impacts of No-Action Alternative.............................................. 8-84

31 Table 8–11. Summary of Environmental Impacts of Proposed Action and Alternatives....... 8-85

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

33 Table 11–1. List of Agencies, Organizations, and Persons to Whom Copies of this 

34 SEIS Are Sent ................................................................................................. 11-1
xv 

1 EXECUTIVE SUMMARY

2 BACKGROUND

3 By letter dated June 22, 2011, Exelon Generation Company, LLC (Exelon) submitted an 

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

5 licenses for Limerick Generating Station, Units 1 and 2 (LGS) for an additional 20-year period.

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

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

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

9 that the NRC shall prepare an EIS, which is a supplement to the Commission’s NUREG-1437, 

10 Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants. 

11 Upon acceptance of Exelon’s application, the NRC staff began the environmental review 

12 process described in 10 CFR Part 51 by publishing a Notice of Intent to prepare a supplemental 

13 EIS (SEIS) and conduct scoping. In preparation of this SEIS for LGS, the NRC staff performed 

14 the following:

15 • conducted public scoping meetings on September 22, 2011, in Pottstown, 

16 Pennsylvania, 

17 • conducted a site audit at the plant on November 7–10, 2011,

18 • reviewed Exelon’s environmental report (ER) and compared it to the GEIS,

19 • consulted with other agencies,

20 • conducted a review of the issues following the guidance set forth in 

21 NUREG-1555, Standard Review Plans for Environmental Reviews for 

22 Nuclear Power Plants, Supplement 1: Operating License Renewal, and

23 • considered public comments received during the scoping process.

24 PROPOSED ACTION

25 Exelon initiated the proposed Federal action—issuing renewed power reactor operating 

26 licenses—by submitting an application for license renewal of LGS, for which the existing 

27 licenses (NPF-39 and NPF-85) will expire on October 26, 2024, and June 22, 2029, 

28 respectively. The NRC’s Federal action is the decision whether or not to renew the license for 

29 an additional 20 years.

30 PURPOSE AND NEED FOR ACTION

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

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

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

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

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

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

37 Act or findings in the National Environmental Policy Act (NEPA) environmental analysis that 

38 would lead the NRC to reject a license renewal application, the NRC does not have a role in the 
Executive Summary

xvi

1 energy planning decisions of whether a particular nuclear power plant should continue to 

2 operate.

3 If the renewed licenses are issued, the appropriate energy-planning decisionmakers, along with 

4 Exelon, will ultimately decide if the plant will continue to operate based on factors such as the 

5 need for power. If the operating licenses are not renewed, then the facility must be shut down 

6 on or before the expiration dates of the current operating licenses, October 26, 2024, and 

7 June 22, 2029.

8 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

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

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

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

12 criteria:

13 • The environmental impacts associated with the 

14 issue is determined to apply either to all plants or, 

15 for some issues, to plants having a specific type 

16 of cooling system or other specified plant or site 

17 characteristics. 

18 • A single significance level (i.e., SMALL, 

19 MODERATE, or LARGE) has been assigned to 

20 the impacts, except for collective offsite 

21 radiological impacts from the fuel cycle and from 

22 high-level waste and spent fuel disposal.

23 • Mitigation of adverse impacts associated with the 

24 issue is considered in the analysis, and it has 

25 been determined that additional plant-specific 

26 mitigation measures are likely not to be 

27 sufficiently beneficial to warrant implementation.

28 For Category 1 issues, no additional site-specific analysis is 

29 required in this draft SEIS unless new and significant information 

30 is identified. Chapter 4 of this report presents the process for 

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

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

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

34 Recently, the NRC approved a revision to its environmental protection regulation, 

35 10 CFR Part 51, which governs environmental impact reviews of nuclear power plant operating 

36 license renewals. The NRC, through its rulemaking process, has completed an update and 

37 re-evaluation of the potential environmental impacts associated with the renewal of an operating 

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

39 the 1996 GEIS, provides the technical basis for the revised rule. The revised GEIS specifically 

40 supports the revised list of NEPA issues and associated environmental impact findings for 

41 license renewal contained in Table B–1 in Appendix B to Subpart A of the revised 

42 10 CFR Part 51. The revised rule consolidates similar Category 1 and 2 issues, changes some 

43 Category 2 issues into Category 1 issues, and consolidates some of those issues with existing 

44 Category 1 issues. The revised rule also adds new Category 1 and 2 issues. 

SMALL: Environmental 

effects are not detectable or 

are so minor that they will 

neither destabilize nor 

noticeably alter any 

important attribute of the 

resource.

MODERATE: 

Environmental effects are

sufficient to alter noticeably, 

but not to destabilize, 

important attributes of the 

resource.

LARGE: Environmental 

effects are clearly noticeable 

and are sufficient to 

destabilize important 

attributes of the resource.
Executive Summary

xvii

1 The revised rule is expected to be published in 2013; it will become effective 30 days after 

2 publication in the Federal Register. Compliance by license renewal applicants will not be 

3 required until 1 year from the date of publication (i.e., license renewal environmental reports 

4 submitted later than 1 year after publication must be compliant with the new rule). 

5 Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal 

6 SEISs, the potential significant impacts described by the revised rule’s new Category 2 issues, 

7 and to the extent there is any new and significant information, the potential significant impacts 

8 described by the revised rule’s new Category 1 issues. 

9 The NRC staff has reviewed Exelon’s established process for identifying and evaluating the 

10 significance of any new and significant information on the environmental impacts of license 

11 renewal of LGS. Neither Exelon nor the NRC identified information that is both new and 

12 significant related to Category 1 issues that would call into question the conclusions in the 

13 GEIS. This conclusion is supported by NRC’s review of the applicant’s ER, other 

14 documentation relevant to the applicant’s activities, the public scoping process and substantive 

15 comments raised, and the findings from the environmental site audit that the NRC staff 

16 conducted. Further, the NRC staff did not identify any new issues applicable to LGS that have a 

17 significant environmental impact. The NRC staff, therefore, relies upon the conclusions of the 

18 GEIS for all Category 1 issues applicable to LGS.

19 Table ES-1 summarizes the Category 2 issues applicable to LGS, if any, as well as the NRC 

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

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

22 documented in Appendix B to Subpart A of 10 CFR Part 51, stand.
Executive Summary

xviii

1 Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts of 

2 License Renewal

Resource Area Relevant Category 2 Issues Impacts

Land Use Not applicable SMALL

Air Quality Not applicable SMALL

Surface Water Resources Water use conflicts SMALL

Groundwater Resources Groundwater use conflicts

Radionuclides released to groundwater

SMALL

SMALL

Aquatic Resources Not applicable SMALL

Terrestrial Resources Not applicable SMALL

Protected Species Threatened or endangered species SMALL

Human Health 

Electromagnetic fields—acute effects 

(electric shock)

Microbiological organisms (public health)

SMALL

Socioeconomics

Housing impacts

Public services (public utilities)

Offsite land use

Public services (public transportation)

Historic and archaeological resources

SMALL

Cummulative Impacts

Aquatic resources

Terrestrial resources

All other resource areas

SMALL to MODERATE

MODERATE

SMALL

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

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

5 of Exelon during the license renewal period. Additionally, the NRC staff has determined that no 

6 disproportionately high and adverse human health impacts would be expected in special 

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

8 local food, fish, and wildlife.

9 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

10 The NRC staff previously considered Severe Accident Mitigation Alternatives (SAMAs) for the 

11 applicant’s plant in the Final Environmental Statement Related to Operation of Limerick 

12 Generating Station, Units 1 and 2, in NUREG-0974, Supplement 1. The analysis was based on 

13 the licensee’s analysis in the updated probabilistic risk assessment. Because the NRC staff 

14 previously considered SAMAs for LGS, NRC regulations do not require the NRC staff to 

15 reconsider SAMAs for this license renewal proceeding. Nonetheless, the NRC must consider 

16 whether new and significant information impacts this determination in the NRC regulations, as it 

17 must for all environmental issues the NRC addresses through a generic determination in its 

18 regulations. The NRC staff has not identified any new and significant information regarding the 

19 determination in the regulations to not reconsider SAMAs for facilities that have already 

20 considered them once.
Executive Summary

xix

1 ALTERNATIVES

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

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

4 LGS operating license (the no action alternative). Replacement power options considered were 

5 as follows:

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

7 • supercritical pulverized coal (SCPC),

8 • new nuclear, 

9 • wind power, and

10 • purchased power. 

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

12 to license renewal of LGS; these were later dismissed because of technical, resource 

13 availability, or commercial limitations that currently exist and that the NRC staff believes are 

14 likely to continue to exist when the existing LGS license expires. The no action alternative by 

15 the NRC staff, and the effects it would have, were also considered.

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

17 located both at the LGS site and at some other unspecified alternate location. Alternatives 

18 considered, but dismissed were as follows:

19 • solar power, 

20 • combination alternative of wind, solar, and NGCC,

21 • combination alternative of wind and compressed-air energy storage (CAES),

22 • wood waste, 

23 • conventional hydroelectric power, 

24 • ocean wave and current energy, 

25 • geothermal power, 

26 • municipal solid waste (MSW),

27 • biofuels, 

28 • oiled-fired power,

29 • delayed retirement, 

30 • fuel cells, 

31 • coal-fired integrated gasification combined-cycle (IGCC), and

32 • demand-side management (DSM).

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

34 evaluating impacts from license renewal.
Executive Summary

xx 

1 RECOMMENDATION

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

3 renewal for LGS are not great enough to deny the option of license renewal for energy-planning 

4 decisionmakers. This recommendation is based on the following:

5 • analysis and findings in the GEIS,

6 • ER submitted by Exelon,

7 • consultation with Federal, state, and local agencies,

8 • NRC staff’s own independent review, and

9 • consideration of public comments received during the scoping process.
xxi

1 ABBREVIATIONS AND ACRONYMS

2 °C degree(s) Celsius

3 °F degree(s) Fahrenheit

4 AADT average annual daily traffic 

5 ac acre(s)

6 AC alternating current

7 ACHP Advisory Council on Historic Preservation

8 ADAMS Agencywide Documents Access and Management System

9 AEA Atomic Energy Act of 1954 [Also: UK Atomic Energy Authority]

10 AEC U.S. Atomic Energy Commission

11 AEPS alternative energy portfolio standard

12 ALARA as low as is reasonably achievable

13 ANSI American National Standards Institute

14 APE area of potential effect

15 AQCR air quality control region 

16 ATWS anticipated transient without scram 

17 BHP Bureau of Historic Preservation

18 BMP best management practice

19 BOL Bureau of Laboratories

20 BTU British thermal unit(s)

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

22 BTU/lb British thermal unit(s) per pound

23 BWR boiling water reactor

24 CAA Clean Air Act, as amended through 1990

25 CAES compressed air energy storage

26 CCS carbon capture and storage

27 CDF core damage frequency

28 Ceq/kWh carbon equivalent per kilowatt-hour 

29 CEQ Council on Environmental Quality

30 CFR Code of Federal Regulations

31 cfs cubic feet per second

32 cm centimeter(s)

33 cm/s centimeter(s) per second

34 CO carbon monoxide 
Abbreviations and Acronyms

xxii

1 CO2 carbon dioxide

2 CPI Containment Performance Improvement

3 CRGIS Cultural Resources Geographic Information System

4 CS candidate species

5 CSAPR Cross-State Air Pollution Rule

6 CSP concentrated solar power

7 CT combustion turbine

8 CWA Clean Water Act of 1972

9 dB decibels

10 dBA decibels adjusted

11 DBA design basis accident

12 DC direct current

13 DMR Discharge Monitoring Report

14 DOE U.S. Department of Energy

15 DRBC Delaware River Basin Commission

16 DSEIS draft supplemental environmental impact statement

17 DSM demand-side management 

18 DVRPC Delaware Valley Regional Planning Commission

19 DWS drinking water standard

20 EO Executive Order

21 EFH Essential Fish Habitat

22 EIA Energy Information Administration (of DOE) 

23 EIS environmental impact statement

24 ELF EMF extremely low-frequency electromagnetic field

25 EMS environmental management system

26 EPA U.S. Environmental Protection Agency 

27 EPCRA Emergency Planning and Community Right-to-Know Act of 1986

28 EPRI Electric Power Research Institute

29 EPT Ephemeroptera, Plecoptera, and Trichoptera

30 ER Environmental Report 

31 ESA Endangered Species Act of 1973, as amended 

32 Exelon Exelon Generation Company, LLC

33 FE Federally endangered

34 FENOC First Energy Nuclear Operating Company

35 FES final environmental statement
Abbreviations and Acronyms

xxiii

1 fps feet per second

2 FR Federal Register

3 FSAR final safety analysis report

4 FT threatened

5 ft foot (feet)

ft3 6 cubic foot (feet)

7 FW feedwater

8 FWCA Fish and Wildlife Coordination Act

9 FWS U.S. Fish and Wildlife Service

10 g gram(s)

11 gal gallon(s)

12 GE General Electric 

13 GEIS Generic Environmental Impact Statement for License Renewal of 

14 Nuclear Plants, NUREG–1437

15 GHG greenhouse gas 

16 GIC Green-is-Clean

17 gpd gallons per day 

18 gpm gallons per minute 

19 GW groundwater

20 ha hectare(s)

21 Hg mercury

22 HLSA high-level storage area

23 Hz hertz

24 IAEA International Atomic Energy Agency

25 IEEE Institute of Electrical and Electronics Engineers, Inc.

26 IGCC integrated gasification combined-cycle 

27 in. inch(es)

28 IPE Individual Plant Examination

29 IPEEE Individual Plant Examination of External Events

30 ISFSI Independent Spent Fuel Storage Installation

31 ISO International Organization for Standardization

32 kg kilogram(s)

33 km kilometer(s)

km2 34 square kilometer(s)

35 kV kilovolt(s)
Abbreviations and Acronyms

xxiv

1 kW kilowatt(s)

2 kWh kilowatt-hour(s)

3 L/min liter(s) per minute

4 lb pound(s)

5 LEFM Leading Edge Flow Meter

6 LGS Limerick Generating Station, Units 1 and 2

7 LLMW low-level mixed waste

8 LLRW low-level radioactive waste

9 m meter(s)

10 m/s meter(s) per second

m2 11 square meter(s)

m3 12 cubic meter(s)

m3 13 /s cubic meters per second 

14 mA milliampere(s)

15 MACCS2 MELCOR Accident Consequence Code System 2 

16 MAIS macroinvertebrate aggregated index for streams 

17 MassDEP Massachusetts Department of Environmental Protection

18 MATS Mercury and Air Toxics Standards 

19 MBTA Migratory Bird Treaty Act of 1918

20 MCPC Montgomery County Planning Commission 

21 MDPH Massachusetts Department of Public Health

22 MF migratory fishes

23 mg/L milligrams per liter

24 mgd million gallons per day 

25 mGy million gallons per year

26 mi mile(s)

mi2 27 square mile(s)

28 min minute(s)

29 mm millimeter(s)

30 MMI Modified Mercalli Intensity

31 MMPA Marine Mammal Protection Act of 1972

32 mph mile(s) per hour

33 mrad milliradiation absorbed dose

34 mrem milliroentgen equivalent man
Abbreviations and Acronyms

xxv 

1 MSA Magnuson–Stevens Fishery Conservation and Management Act, 

2 as amended through 2006

3 MSL mean sea level

4 mSv millisievert

5 MSW municipal solid waste

6 MUR measurement uncertainty recapture

7 MT metric ton(s)

8 MW megawatt(s)

9 MWd megawatt-day(s) 

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

11 MWe megawatt(s) electrical 

12 MWt megawatt(s) thermal

13 NA not applicable 

14 NAAQS National Ambient Air Quality Standards

15 NASS National Agricultural Statistics Service

16 NAS National Academy of Sciences

17 NEPA National Environmental Policy Act of 1969

18 NERC North American Electric Reliability Corporation

19 NESC National Electrical Safety Code

20 NETL National Energy Technology Laboratory

21 NGCC natural-gas-fired combined-cycle 

22 NHPA National Historic Preservation Act of 1966, as amended

23 NIEHS National Institute of Environmental Health Sciences

24 NMFS National Marine Fisheries Service (of NOAA)

25 NOAA National Oceanic and Atmospheric Administration 

26 NOx nitrogen oxide(s)

27 NPDES National Pollutant Discharge Elimination System 

28 NPS National Park Service

29 NRC U.S. Nuclear Regulatory Commission 

30 NRCS National Resources Conservation Service

31 NRHP National Register of Historic Places

32 NRR Office of Nuclear Reactor Regulation

33 NUREG NRC technical report designation (Nuclear Regulatory 

34 Commission)

35 NWS National Weather Service
Abbreviations and Acronyms

xxvi 

1 O3 ozone

2 OCA Owner-Controlled Area

3 ODCM Offsite Dose Calculation Manual

4 PADEP Pennsylvania Department of Environmental Protection

5 PAH polycyclic aromatic hydrocarbon

6 Pb lead

7 PBAPS Peach Bottom Atomic Power Station

8 PCBs polychlorinated biphenyl 

9 pCi/L picocuries per liter

10 PDCNR Pennsylvania Department of Conservation and Natural Resources

11 PE Pennsylvania endangered

12 PECO PECO Energy Company, the energy delivery subsidiary of Exelon

13 Corporation serving retail customers in southeastern Pennsylvania 

14 (also used in this report as an acronym for Philadelphia Electric 

15 Company or PECO Energy Company, predecessors of Exelon 

16 Generation)

17 PFBC Pennsylvania Fish and Boating Commission

18 PGA peak ground acceleration

19 PGC Pennsylvania Game Commission

20 PJM PJM Interconnection, LLC

21 PM particulate matter

22 PM10 particulate matter >2.5 microns and ≤10 microns in diameter

23 PM2.5 particulate matter ≤2.5 microns in diameter

24 PNDI Pennsylvania Natural Diversity Inventory

25 PNHP Pennsylvania Natural Heritage Program

26 PNNL Pacific Northwest National Laboratory

27 POST Parliamentary Office of Science and Technology

28 PPC Preparedness, Prevention, and Contingency

29 PR rare

30 PSD Prevention of Significant Deterioration

31 psia pounds per square inch absolute

32 PV photovoltaic

33 PWR pressurized water reactor

34 RCA radiological control area

35 RCRA Resource Conservation and Recovery Act of 1976, as amended

36 REMP radiological environmental monitoring program
Abbreviations and Acronyms

xxvii 

1 REOP Radiological Environmental Operation

2 RERS reactor enclosure recirculation system

3 RGPP Radiological Groundwater Protection Program

4 RKm river kilometer

5 RM river mile

6 RMC RMC-Environmental Services

7 ROI region of influence

8 ROW(s) right(s)-of-way

9 RPS renewable portfolio standard

10 RSP radwaste storage pad

11 RWCU reactor water cleanup

12 SAMA Severe Accident Mitigation Alternative

13 SAMDA Severe Accident Mitigation Design Alternative

14 SAMGs Severe Accident Mitigation Guidelines

15 SAR safety analysis report

16 SCR selective catalytic reduction 

17 SCPC supercritical pulverized coal

18 SE state endangered

19 SEIS supplemental environmental impact statement 

20 SER safety evaluation report

21 SGTS standby gas treatment system

22 SHPO State Historic Preservation Officer

23 SIP State Implementation Plan

24 SO2 sulfur dioxide

25 SOx sulfur oxide(s)

26 SPCC Spill Prevention Control and Countermeasure

27 SR State rare

28 SSCs structures, systems, and components

29 SSC species of special concern

30 SSE safe-shutdown earthquake

31 ST state threatened

32 STG steam turbine generator

33 State Commonwealth of Pennsylvania (or other state if specified)

34 Stroud Stroud Water Research Center

35 Sv sievert
Abbreviations and Acronyms

xxviii 

1 SW surface water

2 SWPPP Stormwater Pollution Prevention Plan

3 TLD thermoluminescent dosimeters

4 TMDL total maximum daily upload

5 TMI Three Mile Island

6 tpy ton(s) per year

7 TSF stocked trout 

8 TSP total suspended particles

9 TWh terawatt-hour(s)

10 U uranium

11 U.S. United States

12 U.S.C. United States Code

13 UFSAR updated final safety analysis report

14 USACE U.S. Army Corps of Engineers 

15 USCB U.S. Census Bureau

16 USDA U.S. Department of Agriculture

17 USGCRP United States Global Change Research Program [or GCRP]

18 USGS U.S. Geological Survey

19 VOC volatile organic compound

20 WEC wave energy conversion

21 WHC Wildlife Habitat Council

22 WWF warm water fishes
1-1 

1 1.0 PURPOSE AND NEED FOR ACTION

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

3 in Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51)—which carry out the 

4 National Environmental Policy Act (NEPA)—renewal of a new nuclear power plant operating 

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

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

7 reactors be granted for up to 40 years. The 40-year licensing period was based on economic 

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

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

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

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

12 deny license renewal based on whether the applicant has demonstrated that the environmental 

13 and safety requirements in the agency’s regulations can be met during the period of extended 

14 operation.

15 1.1. Proposed Federal Action

16 Exelon Generation Company, LLC (Exelon) initialized the proposed Federal action by submitting 

17 an application for license renewal of Limerick Generating Station, Units 1 and 2 (LGS), for which 

18 the existing licenses (NPF-39 and NPF-85) expire on October 26, 2024, and June 22, 2029. 

19 The NRC’s Federal action is to decide whether to renew the license for an additional 20 years.

20 1.2. Purpose and Need for the Proposed Federal Action

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

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

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

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

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

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

27 lead the NRC to reject a license renewal application, the NRC does not have a role in the 

28 energy-planning decisions of state regulators and utility officials as to whether a particular 

29 nuclear power plant should continue to operate.

30 If the renewed license is issued, state regulatory agencies and Exelon will ultimately decide 

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

32 matters within the state’s jurisdiction or the purview of the owners. If the operating license is not 

33 renewed, then the facility must be shut down on or before the expiration date of the current 

34 operating licenses—October 26, 2024, and June 22, 2029.
Purpose and Need for Action

1-2 

1 Figure 1–1. Environmental Review Process

2 1.3. Major Environmental Review Milestones

3 Exelon submitted an Environmental Report (ER) (Exelon 2011b) as part of its license renewal 

4 application (Exelon 2011a) on June 22, 2011. After reviewing the application and ER for 

5 sufficiency, the staff published a Federal Register Notice of Acceptability and Opportunity for 

6 Hearing (76 FR 52992) on August 24, 2011. Then, on August 26, 2011, the NRC published 

7 another notice in the Federal Register (76 FR 53498) on the intent to conduct scoping, thereby 

8 beginning the 60-day scoping period.

NRC staff 

reviews 

application

Staff conducts

environmental 

site audit

The NRC 

issues draft 

SEIS

Company submits

an application

to the NRC

*Scoping 

Process

*Draft 

SEIS 

Process

The NRC 

issues final 

SEIS

NRC decision

on whether to 

renew license

* Opportunity

for Public

Involvement
Purpose and Need for Action

1-3 

1 Two public scoping meetings were held on September 22, 2011, in Pottstown, Pennsylvania 

2 (NRC 2011). The comments received during the scoping process are presented in 

3 “Environmental Impact Statement, Scoping Process, Summary Report,” published in February 

4 2013 (NRC 2013). The scoping process summary report presents NRC responses to 

5 comments that the NRC staff considered to be out-of-scope of the environmental license 

6 renewal review. The comments considered to be within the scope of the environmental license 

7 renewal review and the NRC responses are presented in Appendix A of this supplemental 

8 environmental impact statement (SEIS).

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

10 in November 2011. During the site audit, NRC staff met with plant personnel, reviewed specific 

11 documentation, toured the facility, and met with interested Federal, state, and local agencies. A 

12 summary of that site audit and the attendees is contained in “Summary of Site Audit in Support 

13 to the Environmental Review of the License Renewal Application for Limerick Generating 

14 Station, Units 1 and 2,” published May 21, 2012 (NRC 2012a).

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

16 SEIS (Figure 1–1). This document is made available for public comment for 75 days. During 

17 this time, NRC staff will host public meetings and collect public comments. Based on the 

18 information gathered, the NRC staff will amend the draft SEIS findings, as necessary, and 

19 publish the final SEIS.

20 The NRC has established a license renewal process that can be completed in a reasonable 

21 period of time with clear requirements to ensure safe plant operation for up to an additional 

22 20 years of plant life. The safety review, which documents its finding in a safety evaluation 

23 report, is conducted simultaneously with the environmental review. The findings in both the 

24 SEIS and the safety evaluation report are factors in the Commission’s decision to either grant or 

25 deny the issuance of a renewed license.

26 1.4. Generic Environmental Impact Statement

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

28 license renewal to improve the efficiency of the license renewal process. The Generic 

29 Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437 

30 (GEIS) documented the results of the NRC staff’s systematic approach to evaluate the 

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

32 operating them for an additional 20 years. NRC staff analyzed in detail and resolved those 

33 environmental issues that could be resolved generically in the GEIS.

34 The GEIS establishes 92 separate issues for NRC staff to independently verify. Of these 

35 issues, NRC staff determined that 69 are generic to all plants (Category 1) while 21 issues do 

36 not lend themselves to generic consideration (Category 2). Two other issues remained 

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

38 evaluated on a site-specific basis. A list of all 92 issues can be found in Appendix B.

39 For each potential environmental issue, the GEIS: 

40 (1) describes the activity that affects the environment,

41 (2) identifies the population or resource that is affected,

42 (3) assesses the nature and magnitude of the impact on the affected population 

43 or resource,
Purpose and Need for Action

1-4 

1 (4) characterizes the significance of the effect for both beneficial and adverse 

2 effects,

3 (5) determines if the results of the analysis apply to all plants, and

4 (6) considers whether additional mitigation measures would be warranted for 

5 impacts that would have the same significance level for all plants.

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

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

8 significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below.

9 SMALL: Environmental effects are not detectable 

10 or are so minor that they will neither destabilize nor 

11 noticeably alter any important attribute of the 

12 resource.

13 MODERATE: Environmental effects are sufficient 

14 to alter noticeably, but not to destabilize, important 

15 attributes of the resource.

16 LARGE: Environmental effects are clearly 

17 noticeable and are sufficient to destabilize important 

18 attributes of the resource.

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

20 applied to all plants and whether additional mitigation measures would be warranted (Figure 1–

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

22 Category 1 issues are those that meet the following criteria:

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

24 to apply either to all plants or, for some issues, to plants having a specific 

25 type of cooling system or other specified plant or site characteristics.

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

27 assigned to the impacts (except for collective off-site radiological impacts 

28 from the fuel cycle and from high-level waste and spent fuel disposal).

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

30 in the analysis, and it has been determined that additional plant-specific 

31 mitigation measures are likely not to be sufficiently beneficial to warrant 

32 implementation.

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

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

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

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

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

38 documented in the SEIS.

Significance indicates the importance of 

likely environmental impacts and is 

determined by considering two variables: 

context and intensity. 

Context is the geographic, biophysical, 

and social context in which the effects will 

occur. 

Intensity refers to the severity of the 

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

1-5 

1 Figure 1–2. Environmental Issues Evaluated during License Renewal

2 The NRC staff initially evaluated 92 issues in the GEIS. Based on the findings of the GEIS, a 

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

4 On December 6, 2012, the Commission affirmed a decision to publish in the Federal Register

5 an amendment that would revise its environmental protection regulation, 10 CFR Part 51, which 

6 governs environmental impact reviews of nuclear power plant operating license renewals 

7 (NRC 2012b). Specifically, the revised rule will update and reevaluate the potential 

8 environmental impacts associated with the renewal of an operating license for a nuclear power 

9 reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS, provides the 

10 technical basis for the revised rule. The revised GEIS specifically supports the revised list of 

11 NEPA issues and associated environmental impact findings for license renewal contained in 

12 Table B–1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and 

13 rule reflect lessons learned and knowledge gained during previous license renewal 

14 environmental reviews. In addition, public comments received on the draft revised GEIS and 

15 rule and during previous license renewal environmental reviews were reexamined to validate 

16 existing environmental issues and identify new ones. 

17 The revised rule identifies 78 environmental impact issues, of which, 17 will require

18 plant-specific analysis. The revised rule consolidates similar Category 1 and 2 issues, changes 

19 some Category 2 issues into Category 1 issues, and consolidates some of those issues with 

20 existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. The new 
Purpose and Need for Action

1-6 

New and significant information either:

(1) identifies a significant environmental 

issue not covered in the GEIS, or

(2) was not considered in the analysis in the 

GEIS and leads to an impact finding that 

is different from the finding presented in 

the GEIS.

1 Category 1 issues include geology and soils, exposure of terrestrial organisms to radionuclides,

2 exposure of aquatic organisms to radionuclides, human health impact from chemicals, and 

3 physical occupational hazards. Radionuclides released to groundwater, effects on terrestrial 

4 resources (non-cooling system impacts), minority and low-income populations 

5 (i.e., environmental justice), and cumulative impacts were added as new Category 2 issues. 

6 The revised rule is expected to be published in 2013, and it will become effective 30 days after 

7 publication in the Federal Register. Compliance by license renewal applicants will not be 

8 required until 1 year from the date of publication (i.e., license renewal environmental reports 

9 submitted later than 1 year after publication must be compliant with the new rule). 

10 Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal 

11 SEISs, the potential significant impacts described by the revised rule’s new Category 2 issues 

12 and, to the extent there is any new and significant information, the potential significant impacts 

13 described by the revised rule’s new Category 1 issues. 

14 1.5. Supplemental Environmental Impact Statement

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

16 operation of LGS, alternatives to license renewal, and mitigation measures for minimizing 

17 adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential 

18 environmental impacts from alternatives while Chapter 9 presents the staff’s preliminary

19 recommendation to the Commission on whether or not the environmental impacts of license 

20 renewal are so great that preserving the option of license renewal would be unreasonable. The 

21 recommendation includes consideration of comments received during the public scoping period. 

22 In the preparation of this SEIS for LGS, the staff:

23  reviewed the information provided in Exelon’s ER, 

24  consulted with other Federal, state, and local agencies, 

25  conducted an independent review of the issues during a site audit, and

26  considered the public comments received during the scoping process.

27 New information can be identified from a 

28 number of sources, including the applicant, the 

29 NRC, other agencies, or public comments. If a 

30 new issue is revealed, then it is first analyzed to 

31 determine if it is within the scope of the license 

32 renewal evaluation. If it is not addressed in the 

33 GEIS, then the NRC determines its significance 

34 and documents its analysis in the SEIS.

35 1.6. Cooperating Agencies

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

37 agencies in the preparation of this SEIS.

38 1.7. Consultations

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

40 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966

41 require that Federal agencies consult with applicable state and Federal agencies and groups 

42 prior to taking action that may affect endangered species, fisheries, or historic and 
Purpose and Need for Action

1-7 

1 archaeological resources, respectively. Below are the agencies and groups with whom the 

2 NRC consulted; Appendix D to this report includes copies of consultation documents.

3  Advisory Council on Historic Preservation

4  National Marine Fisheries Service

5  U.S. Environmental Protection Agency, Region 3

6  U.S. Fish and Wildlife Service, State College, Pennsylvania

7  Absentee-Shawnee Tribe of Oklahoma

8  Cayuga Nation

9  Delaware Nation

10  Delaware Tribe

11  Eastern Shawnee Tribe of Oklahoma

12  Oneida Indian Nation

13  Oneida Nation of Wisconsin

14  Onondaga Nation

15  Seneca Nation of Indians

16  Seneca-Cayuga Tribe of Oklahoma

17  St. Regis Mohawk Tribe

18  Shawnee Tribe

19  Stockbridge-Munsee Band of the Mohican Nation of Wisconsin

20  Tonawanda Seneca Nation

21  Tuscarora Nation

22 1.8. Correspondence

23 During the course of the environmental review, the NRC staff contacted the Federal, state, 

24 regional, local, and tribal agencies listed in Section 1.7, as well as the following:

25  Pennsylvania Fish & Boat Commission

26  Pennsylvania Game Commission

27  Pennsylvania Historical and Museum Commission

28  Pennsylvania Department of Conservation and Natural Resources

29 Appendix E contains a chronological list of all the documents sent and received during the 

30 environmental review. 

31 A list of persons who received a copy of this SEIS is provided in Chapter 11.

32 1.9. Status of Compliance

33 Exelon is responsible for complying with all NRC regulations and other applicable Federal, 

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

35 in Appendix H of the GEIS. Appendix C to this SEIS includes a list of the permits and licenses 

36 issued by Federal, state, and local authorities for activities at LGS.

37 1.10. References

38 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

39 Protection Regulations for Domestic Licensing and Related Regulator Activities.”

40 76 FR 52992. U.S. Nuclear Regulatory Commission, Washington, DC, “Notice of Acceptance for 

41 Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of 

42 Facility Operating License Nos. NPF-39 and NPF-85 for an Additional 20-Year Period, Exelon 
Purpose and Need for Action

1-8 

1 Generation Company, LLC, Limerick Generating Station.” Federal Register

2 76(164):52992-52994, August 24, 2011. 

3 76 FR 53498. U.S. Nuclear Regulatory Commission, Washington, DC, “Exelon Generation 

4 Company, LLC; Notice of Intent To Prepare an Environmental Impact Statement and Conduct 

5 Scoping Process for Limerick Generating Station, Units 1 and 2.” Federal Register

6 76(166):53498–53500, August 26, 2011.

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

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

9 [Exelon] Exelon Generation Company, LLC, 2011a. Limerick Generating Station, Units 1 and 

10 2—License Renewal Application. June 2011. Agencywide Documents Access and Management 

11 System (ADAMS) Accession No. ML11179A101.

12 [Exelon] Exelon Generation Company, LLC, 2011b. License Renewal Application, Limerick 

13 Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

14 License Renewal Stage. ADAMS Accession No. ML11179A104. 

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

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

17 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321, et seq.

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

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

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

21 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 

22 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 

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

24 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

25 Report, NUREG-1437, Volume 1, Addendum 1. Washington DC. August 1999. ADAMS 

26 Accession No. ML04069720.

27 [NRC] U.S. Nuclear Regulatory Commission. 2011. “Summary of Public Scoping Meetings 

28 Conducted on September 22, 2011, Related to the Review of the Limerick Generating Station, 

29 Units 1 and 2, License Renewal Application.” September 2011. ADAMS Accession 

30 No. ML04069720.

31 [NRC] U.S. Nuclear Regulatory Commission. 2012a. “Summary of Site Audit Related to the 

32 Environmental Review of the License Renewal Application for Limerick Generating Station, 

33 Units 1 and 2.” May 21, 2012. ADAMS Accession No. ML12124A127.

34 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Staff Requirements, SECY-12-0063 – 

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

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

37 No. ML12341A134. 

38 [NRC] U.S. Nuclear Regulatory Commission. 2013. “Environmental Impact Statement, Scoping 

39 Process, Summary Report,” March 2013. ADAMS Accession No. ML12131A499.
2-1 

1 2.0 AFFECTED ENVIRONMENT

2 Limerick Generating Station, Units 1 and 2 (LGS) is located in Limerick Township of 

3 Montgomery County, Pennsylvania, 1.7 miles (2.7 kilometers [km]) southeast of the Borough of 

4 Pottstown. The City of Reading is about 19 miles (30.6 km) northwest of the site and the 

5 Borough of Phoenixville is about 9.3 miles (15 km) southeast of the site. Other nearby 

6 population centers are the Municipality of Norristown, about 11 miles (17.7 km) southeast of the 

7 site, and the City of Philadelphia, the city limits of which are about 21 miles (33.8 km) southeast 

8 from the site. Figure 2–1 and Figure 2–2 present the 6-mile (10-km) and 50-mile (80-km) 

9 vicinity maps, respectively. 

10 For the purposes of the evaluation in this supplemental environmental impact statement (SEIS), 

11 the “affected environment” is the environment that currently exists at and around LGS. Because 

12 existing conditions are at least partially the result of past construction and operation at the plant, 

13 the impacts of these past and ongoing actions and how they have shaped the environment are 

14 presented here. Section 2.1 of this SEIS describes the facility and its operation, and Section 2.2 

15 discusses the surrounding environment.

16 2.1. Facility Description

17 LGS is a two-unit nuclear-powered steam electric generating facility that began commercial 

18 operation in February 1986 (Unit 1) and January 1990 (Unit 2). The nuclear reactor for each 

19 unit is a General Electric Mark II boiling water reactor (BWR) producing a reactor core rated 

20 thermal power of 3,515 megawatts (MWt). The nominal net electrical capacity is 

21 1,170 megawatts electric (MWe). Figure 2–3 provides a general site layout of LGS.

22 2.1.1. Reactor and Containment Systems

23 The nuclear reactor system for each Limerick unit includes a single-cycle, forced circulation, 

24 General Electric Mark II BWR. The reactor core heats water that is dried by steam separators 

25 and dryers located in the upper portion of the reactor vessel. The steam is then directed 

26 through four main steam lines to the main turbine where it turns the turbine generator to 

27 produce electricity. 

28 Fuel enrichment and average peak rod burnup conditions are no more than 5 percent 

29 uranium-235 and 62,000 megawatt-days per metric ton of uranium (MWd/MTU), respectively. 

30 LGS operates on a 24-month refueling cycle. 

31 The reactor and related systems are enclosed in primary and secondary containments. The 

32 primary containment surrounds the reactor vessel and also houses the reactor coolant 

33 recirculation pumps and piping loops. The secondary containment is the structure that encloses 

34 the reactor’s primary containment and spent fuel storage pool areas. The primary containment 

35 is a steel-lined reinforced concrete pressure-suppression system of the over-and-under 

36 configuration. The secondary containment system is a reinforced concrete building and is 

37 designed to minimize the release of airborne radioactive materials under accident conditions.

38 2.1.2. Radioactive Waste Management

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

40 radioactive wastes that are byproducts of LGS operations. The byproducts are activation 

41 products associated with nuclear fission, reactor coolant activation, and noncoolant material 

42 activation. Release of liquid and gaseous effluents are controlled to meet the limits specified in 
Purpose and Need for Action

2-2 

1 Title 10, Code of Federal Regulations (CFR) Part 20 and 10 CFR Part 50, Appendix I, through 

2 the Radioactive Effluent Controls Program defined in the LGS technical specifications 

3 (Exelon 2011a). Operation procedures for the radioactive waste system ensure that radioactive 

4 wastes are safely processed and discharged from the LGS. The systems are designed and 

5 operated to ensure that the quantities of radioactive materials released from LGS are as low as 

6 is reasonably achievable (ALARA) and within the dose standards set forth in 10 CFR Part 20, 

7 “Standards for protection against radiation,” and Appendix I to 10 CFR Part 50, “Domestic 

8 licensing of production and utilization facilities.” The LGS Offsite Dose Calculation Manual 

9 (ODCM) contains the methods and parameters used to calculate offsite doses resulting from 

10 radioactive effluents. These methods are used to ensure that radioactive material discharges 

11 from the LGS meet regulatory dose standards.

12 Radioactive wastes resulting from LGS operations are classified as liquid, gaseous, and solid. 

13 The design and operation objectives of the radioactive waste management systems are to limit 

14 the release of radioactive effluents from LGS during normal operation and anticipated operation. 

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

16 as spent fuel. Spent fuel assemblies that are removed from the reactor core are replaced with 

17 fresh fuel assemblies during routine refueling outages. Spent nuclear fuel from the reactor is 

18 stored on site in a spent fuel pool and an independent spent fuel storage installation (ISFSI) 

19 located west of the Turbine Buildings. Under 10 CFR Part 50, LGS has a general license to 

20 store spent fuel from both units in pre-approved dry storage casks in accordance with the 

21 requirements in 10 CFR Part 72, Subpart K (Exelon 2011b).

22 2.1.2.1. Radioactive Liquid Waste

23 The liquid waste-management system collects, segregates, stores, and disposes of radioactive 

24 liquid waste. The system is designed to reduce radioactive materials in liquid effluents to levels 

25 that are ALARA and reduce the volume of waste through recycling. Liquid wastes that 

26 accumulate in radwaste drain tanks or in sumps at locations throughout each LGS unit are 

27 transferred to collection tanks in the common radwaste enclosure based on the classification of 

28 waste: equipment drain, floor drain, chemical drain, or laundry drain waste. The liquid wastes 

29 are processed for packaging and offsite shipment, returned to the condensate system, or mixed 

30 with cooling-tower blowdown and released from the plant.

31 Wastes from the equipment drains and floor drains are processed through separate precoat 

32 filters and mixed resin bed demineralizers. The processed waste is collected in one of two 

33 sample tanks. Usually, the water from these tanks is sent to the condensate tank for reuse, but 

34 if necessary, it will be treated or discharged into the Schuylkill River with radionuclide 

35 concentrations below 10 CFR Part 20 limits.

36 Laboratory wastes, decontamination solutions, and other wastes that may be corrosive are 

37 collected and chemically neutralized before being sent to the floor drain system for processing.

38 Waste from decontamination laundry facilities is processed through the laundry filter and then 

39 collected in a sample tank.

40 The contamination in the liquid wastes is concentrated in filters and ion exchange resins and 

41 then sent to solid waste management for processing. The waste is stored and eventually 

42 shipped to a licensed waste disposal facility. The processed liquids are either recycled or 

43 discharged from the plant in the cooling-tower blowdown into the Schuylkill River with 

44 radionuclide concentrations below 10 CFR Part 20 limits. 
Purpose and Need for Action

2-3 

1 Figure 2–1. Location of LGS, 6-mile (10-km) vicinity

Pennsylvania 

* Limerick Generating Station 

~ Exelon Property Boundary 

[ ___ }~ County Boundary 

Major Roads 0 

-- Minor Roads 

--+--+ Railroad 

CJ Waterbody 

Agricultural Land 

.. Pasture Land 

.. Forest Land 

Developed Land 
Purpose and Need for Action

2-4 

1 Figure 2–2. Location of LGS, 50-mile (80-km) region

Pennsylvania 

* = Limited Access - Na1ional Park Service limerick Generating Station - .. -- Highway Mih1ary Reserve 

c:J State Boundary Conservation Area 

County Boundary 

Urban Area 

C) waterbody 

State Park 

0 5 10 20 

Miles 
Purpose and Need for Action

2-5 

1 Figure 2–3. LGS site boundary and facility layout

/ .·'-. . . --, . . '· / ·, ./ ·,.. ·.,_ , /' Exclusion Area Boundary (2,500 fe t ra~:Uus) 

. '· 

, 

, , , 

, 

,' ~ .; , "><:;<:; 

, 

~ 

, ' I . 

(: 

./ 

./ 

./ 

·,_ -~ 

! 

·,_ 

·, ·. ,_. / 

500 kV Transmission Line 

230 kV Transmission Line 

c=J Exclusion Area Boundary (EAB) 

0 550 1.100 2,200 

Feet 

-..... __ / 

.· 

, . 

I 

/ 

I 

: 

..... __ 

'; 

./ 

./ 

LGS Security Barrier i.:::-_-_-.J Exelon Property Boundary 

[~~=] Security Fence D Limerick Nuclear Plant 

Plant Roads D Waterbody 

-+--+ Railroad 0 220 440 

Meters 

880 

,-
Purpose and Need for Action

2-6 

1 2.1.2.2. Radioactive Gaseous Waste

2 Gaseous waste management systems process and control the release of gaseous radioactive 

3 effluents to the atmosphere. Sources of radioactive gases from LGS include condenser 

4 offgases, sources from the reactor enclosure, containment systems, and the “hot” maintenance 

5 shop. 

6 The condenser offgases are the largest source of radioactive gaseous waste. The offgas 

7 system collects the noncondensable radioactive gases that are removed by the air ejectors from 

8 the main condensers. The release of the offgas is delayed to allow for radioactive decay. The 

9 stream is released to the turbine enclosure vent stack and diluted with air and monitored upon 

10 release through the north stack.

11 Other sources of radioactive gases are from the reactor enclosures, the turbine enclosures, and 

12 radwaste buildings. Discharge of these gases are planned, monitored, controlled, and 

13 discharged through the south stack.

14 The standby gas treatment system (SGTS) and the reactor enclosure recirculation system 

15 (RERS) are used to reduce radioactive levels before being discharged into the environment. 

16 2.1.2.3. Radioactive Solid Waste

17 The solid waste management system collects, processes, and packages solid radioactive 

18 wastes for storage and offsite shipment and permanent disposal. To ensure compliance with 

19 applicable regulations in 10 CFR Parts 20, 61, and 71, characterization, classification, 

20 processing, waste storage, handling, and transportation are controlled by the LGS Process 

21 Control Program.

22 Dry wastes (mostly Class A low-level radioactive wastes [LLRWs]) are collected throughout the 

23 plant. Compressible and noncompressible wastes are packaged and temporarily stored until 

24 they are sent to Duratech in Tennessee for processing or final disposal.

25 Wet wastes, generally Class A LLRWs, are collected, dewatered, packaged, and stored prior to 

26 offsite shipment. Wastes from the reactor water cleanup (RWCU) system floor drains, 

27 equipment drains, and fuel pool system usually exceed the criteria for LLRW or low specific 

28 activity material and are packaged in containers and stored in the high level storage area 

29 (HLSA), which is located in the Radwaste Enclosure. Exelon Generation Company, LLC 

30 (Exelon) transports Class A LLRWs to EnergySolutions, LLC, in Clive, Utah, for disposal. 

31 LGS has a “Green-is-Clean” (GIC) waste program that collects noncontaminated waste from the 

32 radiological control area (RCA) from the different controls streams. This waste is packaged 

33 separately and shipped to Duratech in Tennessee for processing and disposal. Any waste sent 

34 to Duratech that is found to be contaminated is repackaged and sent to the offsite LLRW facility 

35 in Clive, Utah. Exelon’s corporate policy is to minimize the generation of radioactive wastes by 

36 following corporate waste minimization procedures.

37 There is an onsite radwaste storage pad (RSP) for temporary storage of radioactive waste 

38 containers. The RSP is located west of the spray pond and has a fenced-in holding area and 

39 another area surrounded by a concrete shell. Contaminated reusable equipment is stored here 

40 as well as Class A wastes. Higher activity Class B/C wastes are not stored in this area.

41 Since closure of the Barnwell Facility to LGS in 2008, there has been no licensed facility that 

42 accepts Class B/C LLRW shipments. Exelon has been temporarily storing the Class B/C 

43 wastes in the HLSA. In May 2011, the NRC approved transport and temporary storage of LGS 

44 Class B/C wastes at Exelon’s Peach Bottom Atomic Power Station (PBAPS). Class B/C LLRW 

45 stored at LGS or packaged in the future will be sent to PBAPS to be stored at the LLRW storage 
Purpose and Need for Action

2-7 

1 facility at that site. The storage capacity for LGS Class B/C wastes at PBAPS is expected to be 

2 sufficient through the extended operating license for both LGS units. 

3 2.1.2.4. Low-Level Mixed Wastes

4 Low-level mixed wastes (LLMW) are wastes that contain both low-level radioactive waste and 

5 RCRA hazardous waste (40 CFR 266.210). LLMW is handled in accordance with Exelon

6 guidance and procedures. There is currently no LLMW stored at LGS. It is rare that LGS 

7 generates LLMW; however, if it were necessary to treat and dispose of LLMW during the license 

8 renewal period, Exelon would store it on site, in compliance with the 1976 Resource 

9 Conservation and Recovery Act (RCRA) storage and treatment conditional exemption. RCRA 

10 regulations are administered in the State by the Pennsylvania Department of Environmental 

11 Protection (PADEP) (25 Pa. Code 260a). Transportation and disposal of LLMW would also 

12 follow RCRA requirements. 

13 When necessary, LLMW is shipped off site to Perma-Fix of Florida, which is licensed and 

14 permitted to treat a variety of mixed waste, solids, liquids, sludges, and debris. Treated wastes 

15 are then sent to EnergySolutions, LLC, disposal facility located near Clive, Utah. LLMW are 

16 generated at LGS on occasion. LLMW are wastes that contain both low-level radioactive waste 

17 and RCRA hazardous waste (40 CFR 266.210). 

18 2.1.3. Nonradiological Waste Management

19 The LGS site generates nonradioactive wastes as part of routine plant maintenance, cleaning 

20 activities, and plant operations. RCRA governs the disposal of solid and hazardous waste. 

21 RCRA waste regulations are contained in 40 CFR Parts 239–299. In addition, 

22 40 CFR Parts 239–259 contain regulations for solid (nonhazardous) waste, and 

23 40 CFR Parts 260–279 contain regulations for hazardous waste. RCRA Subtitle C establishes 

24 a system for controlling hazardous waste from “cradle to grave,” and RCRA Subtitle D 

25 encourages States to develop comprehensive plans to manage nonhazardous solid waste and 

26 mandates minimum technological standards for municipal solid waste landfills. RCRA 

27 regulations are administered in the State by the Pennsylvania Department of Environmental 

28 Protection (PADEP) (25 Pa. Code 260a). PADEP further classifies solid waste as either 

29 municipal waste (25 Pa. Code 271) or residual waste (25 Pa. Code 287).

30 2.1.3.1. Nonradioactive Waste Streams

31 LGS generates solid nonradioactive waste, defined by RCRA, as part of routine plant 

32 maintenance, cleaning activities, and plant operations. Exelon manages these wastes, 

33 including waste minimization, using corporate procedures that meet applicable regulations 

34 (Exelon 2011b). RCRA regulations are administered in the state by the PADEP

35 (25 Pa. Code Article 260a).

36 EPA classifies certain nonradioactive wastes as hazardous based on characteristics including 

37 ignitability, corrosivity, reactivity, or toxicity (hazardous wastes are listed in 40 CFR Part 261). 

38 State-level regulators may add wastes to the EPA’s list of hazardous wastes. RCRA supplies 

39 standards for the treatment, storage, and disposal of hazardous waste for hazardous waste 

40 generators (regulations are available in 40 CFR 262).

41 EPA recognizes the following main types of hazardous waste generators based on the quantity 

42 of the hazardous waste produced (EPA 2012d): 

43  large quantity generators that generate 2,200 pounds (lb) (1,000 kg) per 

44 month or more of hazardous waste, more than 2.2 lb (1 kg) per month of 
Purpose and Need for Action

2-8 

1 acutely hazardous waste, or more than 220 lb (100 kg) per month of acute 

2 spill residue or soil, 

3  small quantity generators that generate more than 220 lb (100 kg) but less 

4 than 2,200 lb (1,000 kg) of hazardous waste per month, and

5  conditionally exempt small quantity generators that generate 220 lb (100 kg) 

6 or less per month of hazardous waste, 2.2 lb (1 kg) or less per month of 

7 acutely hazardous waste, or less than 220 lb (100 kg) per month of acute spill 

8 residue or soil. 

9 LGS, based on past and current generation of hazardous waste is classified as a small quantity 

10 generator of hazardous waste, according to 40 CFR 262 and given in Pa. Code 264a, with 

11 hazardous wastes between 220 lb (100 kg) and 2,200 lb (1,000 kg) per month. The quantities 

12 of hazardous waste and nonhazardous wastes are annually reported to PADEP (Exelon 2011b).

13 The EPA classifies several hazardous wastes as universal wastes; these include batteries, 

14 pesticides, mercury-containing items, and fluorescent lamps (25 Pa. Code 266b). Exelon has 

15 and expects to continue to generate universal waste such as discarded batteries, pesticides, 

16 thermostats, and mercury-containing devices. Other wastes that are not classified as 

17 hazardous waste but require regulation in Pennsylvania are (1) residual wastes such as 

18 discarded solid, liquid, semi-solids from industrial operations, waste treatment system sludges, 

19 and laboratory chemicals; (2) infectious waste; (3) regulated asbestos-containing material; and 

20 (4) municipal waste. LGS is considered a Large Quantity Generator of universal wastes 

21 (greater than 2,200 lb [1,000 kg] per month) (Exelon 2011b). 

22 National Pollutant Discharge Elimination System (NPDES) permits that provide limits and 

23 conditions for wastewater discharge are held by Exelon for industrial wastewater discharges 

24 and storm water discharges from the LGS site into the Schuylkill River (No. PA0051926) and 

25 discharges to the Bradshaw Reservoir to the East Branch Perkiomen Creek (No. PA0052221) 

26 (Exelon 2011b). Radioactive liquid waste is addressed in Section 2.1.2.1 of this SEIS. 

27 Section 2.2.4.2 gives more information about the LGS NPDES permit and permitted discharges.

28 The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable

29 facilities to supply information about hazardous and toxic chemicals to local emergency planning

30 authorities and the EPA (42 USC 11001). On October 17, 2008, the EPA finalized several

31 changes to the Emergency Planning (Section 302), Emergency Release Notification

32 (Section 304), and Hazardous Chemical Reporting (Sections 311 and 312) regulations that were

33 proposed on June 8, 1998 (63 FR 31268).

34 Exelon does not expect its generation rates of nonradiological waste to increase significantly 

35 during the extended period of operation (Exelon 2011b). 

36 2.1.3.2. Pollution Prevention and Waste Minimization

37 In compliance with PADEP requirements, Exelon has implemented a Preparedness, Prevention 

38 and Contingency (PPC) Plan as well as a Spill Prevention Control and Countermeasure (SPCC) 

39 Plan compliant with 40 CFR 112, “Oil Pollution Prevention.” 

40 In support of nonradiological waste-minimization efforts, EPA’s Office of Prevention and Toxics 

41 has established a clearinghouse that supplies information about waste management and

42 technical and operational approaches to pollution prevention (EPA 2012a). The EPA

43 clearinghouse can be used as a source for additional opportunities for waste minimization and

44 pollution prevention at LGS, as appropriate. EPA also encourages the use of environmental 

45 management systems (EMSs) for organizations to assess and manage the environmental 

46 impacts associated with their activities, products, and services in an efficient and cost-effective 
Purpose and Need for Action

2-9 

1 manner. EPA defines an EMS as “a set of processes and practices that enable an organization 

2 to reduce its environmental impacts and increase its operating efficiency.” EMSs help 

3 organizations fully integrate a wide range of environmental initiatives, establish environmental 

4 goals, and create a continuous monitoring process to help meet those goals. The EPA Office of 

5 Solid Waste especially advocates the use of EMSs at RCRA-regulated facilities to improve 

6 environmental performance, compliance, and pollution prevention (EPA 2012b). Exelon has 

7 implemented an EMS.

8 2.1.4. Plant Operation and Maintenance

9 Various types of maintenance activities are conducted at LGS, including inspection, testing, and 

10 surveillance to maintain current licensing basis of the facility and to ensure compliance with 

11 environmental and safety requirements. Various programs currently exist at LGS to maintain, 

12 inspect, test, and monitor performance of facility equipment. These maintenance activities 

13 include inspection requirements for reactor vessel materials, boiler and pressure vessel 

14 inservice inspection and testing, a maintenance structures monitoring program, and 

15 maintenance of water chemistry.

16 Additional programs include those carried out to meet technical specification surveillance 

17 requirements, those implemented in response to NRC generic communications, and various 

18 periodic maintenance, testing, and inspection procedures. Certain program activities are 

19 performed during operation of the plant, while others are carried out during scheduled refueling 

20 outages. Nuclear power plants must periodically discontinue production of electricity for 

21 refueling, periodic inservice inspection, and scheduled maintenance. LGS refuels on a 

22 24-month interval.

23 2.1.5. Power Transmission System

24 Four 230-kilovolt (kV) lines were constructed specifically to connect LGS Unit 1 to the regional 

25 power grid, and one 500-kV line was constructed to connect LGS Unit 2 to the regional electric 

26 grid. Philadelphia Energy Company (PECO), an energy delivery subsidiary of Exelon 

27 Corporation, owns and operates these lines. The LGS site also includes two switchyards—one 

28 for each reactor unit. The Unit 1 switchyard is a 230-kV substation, and the Unit 2 switchyard is 

29 a 500-kV substation. Unless otherwise noted, the discussion of the power transmission system 

30 is adapted from the Environmental Report (ER) (Exelon 2011b) or information gathered at 

31 NRC’s November 2011 environmental site audit (NRC 2012a). 

32 2.1.5.1. Description of the Lines

33 220-60 and 220-61 Lines

34 These lines extend southeast from the plant to the Cromby Substation in East Pikeland 

35 Township, Chester County (see Figure 2–4). The two lines run parallel to the Schuylkill River 

36 within two separate pre-existing railroad corridors on opposite sides of the river for about 

37 12.9 km (8 miles). The 220-60 line traverses the Montgomery County side of the river, and the 

38 220-61 line traverses the Chester County side of the river. The 220-60 line crosses the river 

39 into Chester County before terminating at the Cromby Substation in East Pikeland Township, 

40 Chester County. The 220-60 corridor is 18.3 m (60 ft) wide for the first 10.1 km (6.3 miles), at 

41 which point the line leaves the railroad corridor and joins with an existing 76.2-m (250-ft)-wide 

42 PECO corridor for 1.8 km (1.1 miles). The 220-60 line travels through the 220-61 corridor once 

43 it crosses the river. The 220-61 corridor is 18.3 m (60 ft) wide for the entire length of the 

44 corridor. The 220-61 line is within the Schuylkill River National and State Heritage Area and 

45 parallels a planned portion of the Schuylkill River Trail.
Purpose and Need for Action

2-10

1 220-62 Line

2 This line spans a total of 25.7 km (16 miles) from the Cromby Substation (the termination point 

3 of the 220-60 and 220-61 lines) to north and then east to the North Wales Substation in Upper 

4 Gwynedd Township, Montgomery County (see Figure 2–5). When constructed, the line was 

5 routed through an existing PECO transmission line corridor. The corridor varies from 45.7 m 

6 (150 ft) to 137.2 m (450 ft) wide and traverses the Evansburg State Park in Skippack Township.

7 220-63 and 220-64 Lines

8 The 220-63 and 220-64 lines span a total of 16.1 km (10 miles) and 5.6 km (3.5 miles), 

9 respectively, from the Cromby Substation southeast and then south to their respective 

10 termination points at Barbadoes Substation in West Norristown Township and Plymouth 

11 Meeting Substation in Plymouth Township, Montgomery County (see Figure 2–6). The lines 

12 cross the Schuylkill River in five locations and parallel an open portion of the Schuylkill River 

13 Trail between Phoenixville Borough and Philadelphia. The lines also traverse the Valley Forge 

14 National Park. When constructed, the lines were routed through a combination of existing 

15 PECO transmission line corridors and railroad corridors. The corridor width varies from 45.7 m 

16 (150 ft) to 137.2 m (450 ft).

17 5031 Line

18 This line spans a total of 27.4 km (17 miles) from the Limerick 500-kV substation east to the 

19 Whitpain Substation in Whitpain Township, Montgomery County (see Figure 2–7). The line 

20 crosses the Schuylkill River in Limerick Township and Evansburg State Park in Skippack 

21 Township. When constructed, the line was routed along an existing transmission line corridor 

22 associated with a 500-kV line originating from Peach Bottom Atomic Power Station in Delta, 

23 Pennsylvania. The line also merges with the 220-62 line corridor for about 4.8 km (3 miles). 

24 The corridor width varies from 91.4 m (300 ft) to 137.2 m (450 ft).
Purpose and Need for Action

2-11

1 Figure 2–4. Limerick to Cromby 230-kV Transmission Line Route

Source: Exelon 2011b

EAST COVENTRY 

Limerick 230 kV 

(Exelon Generation) 

EAST VINCENT 

':;..

0 

!!!!!!!!!!!!!!!!!0iii '

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1 in = 1 miles 

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230 kV Voltage (;li Municipal Boundary 

,..., Umerick-Cromby 220-00 Line • Interstate Highway 

~ Umerick-Cromby 220~1 Une 0 u.s. Highway 

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Purpose and Need for Action

2-12

1 Figure 2–5. Cromby to North Wales 230-kV Transmission Line Route

Source: Exelon 2011b

N 

UMERICK 

0 2 4 

'!!!!!!!!!!liiiiiiii!!!!!!!!5iiiiiiiiiiiiiiiiiiiiiiiiMiles 

1 in = 2 miles 

Legend 

230 kV Voltage (;! Municipal Boundary 

~ Cromby-N Wales 220-62 Line • Interstate Highway 

• Subslalion (POWERmap 2009) 0 U.S. Highway 

• State Pal1<s (OCNR 2009) Q State Road 

LOWER PROVIDENCE 

Exelon. NAO 1983 State Pbne Pennsy~ll\11 SQAh 

Ptojectioo; Lambert Conformal Conic 

Unear Unit Foot US 
Purpose and Need for Action

2-13

1 Figure 2–6. Cromby to Plymouth Meeting 230-kV Transmission Line Route

Source: Exelon 2011b

LC .. kf< POTTSGROVE 

A 

EAST GOSHEN 

J 

I 

0 2 4 

'!!!!!!!!iiiiii.i!!!!!!!!!!!5iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiil Miles 

1 inch • 2 miles 

Legend 

230 kV Voltage • State Parks (OCNR 2009) 

/'V Cromby-PiymMeeting 220-63 • Interstate Highway 

N Cromby-PiymMeeting 220-64 0 u.s. Highway 

• Substation (POWERmap 2009) 0 State Road 

Exelon. 

/'. UPPER GwYNEOO ;' ") 

Reference 

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Purpose and Need for Action

2-14

1 Figure 2–7. Limerick to Whitpain 500-kV Transmission Line Route

Source: Exelon 2011b

0 2 4 !!!!!5iiiiii!!!!5iiiiii!!!!!!!!!!!!!!!!!!!!!!!!Miles 

1 in= 2 miles 

Legend 

500 kV Voltage (;/j Municipal Boundary 

/'V Llmerick-IMlltpain 5031 Line • Interstate Highway 

• Substation (POWERmap 2009) 0 U.S. Highway 

• Slate Parks (DCNR 2009) 0 State Road 

Exelon. NAO 1983 State ~ne PenMy~anla ~ 

Protection: lambert Confocmal Conic Unear Unit Foot US 
Purpose and Need for Action

2-15

1 2.1.5.2. Transmission Line Corridor Vegetation Maintenance

2 The majority of the transmission line 

3 corridors associated with LGS lines 

4 traverse suburban areas and agricultural 

5 lands. PECO follows an integrated 

6 vegetation management program that 

7 combines manual, mechanical, biological, 

8 and chemical control techniques to 

9 maintain proper clearance from 

10 transmission lines and structures. PECO 

11 maintains vegetation on a 5-year cycle, 

12 and the degree and type of clearance varies by line voltage and the type, growth rate, and 

13 branching characteristics of trees and vegetation. PECO contracts with Asplundh Tree Expert 

14 Company to perform the majority of maintenance work, and the Davey Resources Group, part 

15 of the Davey Tree Expert Company, oversees quality assurance.

16 Workers follow the current American National Standards Institute (ANSI) guideline document, 

17 A300 Standards for Tree Care Operations, which contains requirements and recommendations 

18 for tree care practices, including pruning, lightning protection, and integrated vegetation 

19 management. These standards describe a wire-border zone management approach in which 

20 the wire zone (the section of the corridor directly under the wires and extending outward about 

21 10 ft [3 m]) is managed to promote low-growing plant communities dominated by grasses, 

22 herbs, and small shrubs (Miller 2007). The border zone (the remainder of the corridor on either 

23 side of the lines) is managed to promote small shrubs and lower growing trees (Miller 2007).

24 PECO has also followed the North American Electric Reliability (NERC) FAC-003, Vegetation 

25 Management, since 2003. This guidance document recommends that all transmission line 

26 owners have a specific vegetation maintenance plan that addresses vegetation inspections, 

27 clearances, qualifications of workers, and environmental impact mitigation.

28 2.1.5.3. PECO’s Environmental Stewardship and Partnerships with State and Local Agencies

29 As part of its environmental stewardship effort, PECO maintains a program to protect birds and 

30 comply with applicable Federal and state bird regulations, and that promotes native vegetation, 

31 maintains an environmental management certification, and partners with Federal and state 

32 agencies for specific mitigation or restoration projects.

33 PECO’s avian management program provides guidance to workers on how to deal with bird 

34 nests or dead birds when encountered during field operations and how it complies with 

35 applicable Federal and state bird regulations, including the Migratory Bird Treaty Act, the 

36 Endangered Species Act, and the Bald and Golden Eagle Protection Act.

37 As part of its maintenance procedures, PECO favors native warm season grass mixtures and 

38 native flower mixtures that include species such as little blue stem (Schizachyrium scoparium), 

39 big blue stem (Andropogon gerardi), Indian grass (Sorghastrum nutans), goldenrod 

40 (Solidago spp.), milkweed (Asclepias spp.), and aster (Aster spp.).

41 PECO maintains an International Organization for Standardization (ISO) 14001 certification, 

42 which provides a framework for environmental management systems to help companies 

43 manage the environmental impact of their activities and demonstrate sound environmental 

44 management (ISO 2009).

45 When the National Park Service (NPS) acquired an additional 65 acres (ac) (26 hectares[ha]) 

46 parcel of land for the Valley Forge National Park that coincided with the 220-63 and 220-64 

Transmission line corridors (or right-of-ways) are 

strips of land used to construct, operate, maintain, 

and repair transmission line facilities. The 

transmission line is usually centered in the corridor. 

The width of a corridor depends on the voltage of the 

line and the height of the structures. Transmission 

line corridors typically must be clear of tall-growing 

trees and structures that could interfere with a power 

line.
Purpose and Need for Action

2-16

1 corridor, PECO partnered with NPS to restore the acquired land to a native warm season grass 

2 community. PECO provided both contractors and equipment for this effort (Exelon 2011b). 

3 2.1.6. Cooling and Auxiliary Water Systems

4 LGS uses a cooling tower-based heat dissipation system that normally withdraws from and 

5 discharges cooling water to the Schuylkill River. In summary, the majority of the makeup water 

6 withdrawn is to provide cooling water for the LGS steam turbine condensers. As water 

7 evaporates in the cooling towers to dissipate heat to the atmosphere, cooling water is lost and 

8 must be replaced. Additionally, to control the chemistry of the circulating water in the cooling 

9 system, a portion of the cooling water is continuously discharged (i.e., blowdown). A much 

10 smaller portion of the makeup water is used to remove heat from auxiliary equipment during 

11 normal operation. A clay-lined spray pond located north of the cooling towers provides 

12 emergency cooling but has an insignificant interface with the environment. Four groundwater 

13 wells are also located on the LGS site to support LGS operations. Unless otherwise cited for 

14 clarity, the NRC drew information about LGS’s cooling and auxiliary water systems from 

15 Exelon’s ER (Exelon 2011b) and responses to NRC’s request for additional information 

16 (Exelon 2012b). NRC staff also toured these systems and facilities during the environmental 

17 site audit (NRC 2012). 

18 Individual LGS systems that interact with the environment are summarized below and focus on 

19 facilities owned and operated by Exelon. 

20 Makeup Water Supply System. The LGS makeup water supply system is comprised of the 

21 individual water sources, facilities, systems, and components used for supplying makeup water 

22 to LGS plant systems. These include the cooling water system, including the circulating water 

23 systems for each LGS unit, and other plant systems. In total, LGS operates its makeup water 

24 supply system and uses its makeup sources in accordance with Delaware River Basin 

25 Commission (DRBC) approvals (Docket No. D-69-210, as revised) (DRBC 2004). A discussion 

26 of these makeup sources and associated facilities and their attributes follows.

27 2.1.6.1. Schuylkill River Source

28 The Schuylkill River is the primary source of makeup water for LGS (see Figure 2–8). Water is 

29 withdrawn from the river via the Schuylkill Pumphouse located on the eastern bank of the river 

30 on the LGS site. River water enters the pumphouse through eight trash rack (bar screen) 

31 panels with sufficient bar spacing to allow aquatic life to pass. A floating trash dock with skirt 

32 located in front of the trash rack functions to divert river debris and some aquatic life before 

33 reaching the trash racks. Intake water then passes through four travelling screens prior to the 

34 intake bays. The screens have 0.25-in. (0.64-cm) mesh openings designed to limit water 

35 approaching the screens to a velocity of 0.75 fps (0.23 m/s). A backwash system operates 

36 automatically to clean the traveling screens of debris to maintain adequate pump wet-well 

37 levels. Screen backwash water is returned to the river via a Pennsylvania NPDES permitted 

38 outfall (no. 011). Leaves and debris removed from the traveling screens are collected in a 

39 dumpster and transported off site for disposal (Exelon 2012b). The facility has three pumps for 

40 cooling water makeup and two pumps for blowdown (nonconsumptive) water makeup use. The 

three cooling water pumps each have a rated capacity of 11,300 gpm (25.2 cfs or 0.71 m3 41 /s), 

and the two blowdown makeup pumps are each rated at 4,000 gpm (8.9 cfs or 0.25 m3 42 /s). 

43 These pumps are usable in any combination to meet the total plant makeup demand (for 

consumptive and nonconsumptive use) of up to 56.2 million gallons per day (mgd) (212,700 m3 44 ). 

45 From the pumphouse, a 36-in. (91-cm) pipeline conveys water to the cooling tower basins. Two 

46 smaller lines supply water to (1) a raw water clarifier in the process water treatment system and 

47 (2) the spray pond. 
Purpose and Need for Action

2-17

1 Figure 2–8. Location of Schuylkill Pumphouse and LGS Discharge Structure

Source: Exelon 2011a

0 75 150 300 

i!!!!!!!!!l;;;i;;iiiiiii!!!!!!!!!!Siiiiiiiiiiiiiiiiiiiiiiiiiiiiiiii~ Fee1 

1 inch; 150 feel 

Exelon. NAO 1983 :Stole Plano PenMY~Onia SOoAh ~n. Lambert ConfamaJ ConiC 

Linear Unit: Foot US 
Purpose and Need for Action

2-18

1 Seasonal low flows in the Schuylkill River and specific conditions and limitations imposed by the 

2 DRBC require that alternative makeup water sources be used by LGS either directly or to 

3 augment flow in the Schuylkill River. In point, source augmentation averaging 35 mgd

(132,500 m3

) or 24,300 gpm (54.1 cfs or 1.5 m3 4 /s) is required about 6 months per year 

5 (Exelon 2012d). Pursuant to DRBC rules and regulations, dockets are used to place limits and 

6 conditions on individual projects, such as LGS, that use water within the Delaware River Basin. 

7 DRBC Docket No. D-69-210 CP, as revised, prescribes the low-flow conditions that trigger the 

8 requirement for LGS to use alternative water sources for consumptive use. Depending on 

9 conditions, a combination of the DRBC-approved alternative water sources (as depicted in 

10 Figure 2–9) are used to supply consumptive use makeup water to LGS, although LGS may 

11 withdraw water from the Schuylkill River for nonconsumptive use without restriction. Perkiomen 

12 Creek is the first supplemental water source to be considered when withdrawals from the 

13 Schuylkill River are restricted because of low flow. 

14 2.1.6.2. Perkiomen Creek Source 

15 LGS must also withdraw water from Perkiomen Creek when the flow in the Schuylkill begins to 

drop below 560 cfs (15.9 m3 16 /s) for two-unit operation (as measured at the U.S. Geological 

17 Survey [USGS] maintained Pottstown, Pennsylvania, gage station), if instream flow conditions in 

18 Perkiomen Creek allow. Water is withdrawn via Exelon’s Perkiomen Pumphouse (auxiliary 

19 intake pumphouse), which is located just inland from the west bank of Perkiomen Creek. Water 

20 is withdrawn from the creek through a set of 15 submerged, stationary “wedge-wire” screen 

21 intakes on the middle of the streambed. Each screen is sized at 24-in. (61-cm) by 72-in. 

22 (183-cm), with a slot size of 0.08 in. (0.2 cm). The screens provide an average through-slot 

23 velocity of 0.4 fps (0.12 m/s). An air burst backwash system automatically functions to remove 

24 accumulated debris (Exelon 2012b). Three intake pumps, including a spare, rated at 

14,600 gpm (33 cfs pr 0.92 m3 25 /s) are sized to supply the consumptive cooling demands for both 

26 LGS units. A small auxiliary pump operates as needed to maintain the facility’s water storage 

27 tank when the intake system is not active. Water is conveyed by an underground pipeline 

28 approximately 8 miles (13 km) to a storage tank located at the LGS site. 

29 2.1.6.3. Delaware River Augmentation Source

30 The natural flow in Perkiomen Creek is not always adequate for LGS’s consumptive makeup 

31 water needs. This situation arises when the natural flow of Perkiomen Creek falls below 210 cfs 

(5.9 m3 32 /s) for two-unit operation, as measured at the USGS-maintained Graterford, 

33 Pennsylvania, gage station. Therefore, Exelon has established a system to transfer water for 

34 flow augmentation purposes from the Delaware River to East Branch Perkiomen Creek and, 

35 ultimately, Perkiomen Creek. This diversion of water originates at the Point Pleasant Pumping 

36 Station on the Delaware River, located about 30 miles (48 km) northeast of the LGS 

37 (see Figure 2–9). The pumping station is owned by a municipal water purveyor and not Exelon. 

38 The Point Pleasant Pumping Station withdraws from a deep water, mid-channel intake in the 

39 Delaware River. The intake structure consists of two rows of fixed cylindrical wedge-wire 

40 screens, with each row comprised of 12 screens. Each screen measures 40-in. (102-cm) in 

41 diameter and 80-in. (203-cm) of total screened length. Screens have a slot size of 0.08 in. 

(0.2 cm). At the maximum pumping rate of 95 mgd (360,000 m3 42 ), the average intake velocity is 

43 0.35 fps (0.11 m/s). Maintenance of the intake screens includes high-pressure spray washing 

44 and scrubbing by divers four times a year, with return of organic debris to the Delaware River 

45 (Exelon 2012b). 
Purpose and Need for Action

2-19

1 Figure 2–9. LGS Makeup Water Supply System and Alternative Water Sources within the 

2 Delaware River Basin

Source: Modified from Exelon 2011a

3 Once withdrawn at Point Pleasant, water is conveyed through a series of pumping stations, to 

4 the Bradshaw Reservoir, and then via transmission mains to East Branch Perkiomen Creek. At 

5 the outset, water is transferred as necessary to the Bradshaw Reservoir to maintain adequate 

6 reservoir operational volume and reserve storage. Located on a 43-ac (17-ha) site and 

7 approximately 27 miles (44 km) northwest of LGS, both the reservoir and associated Bradshaw 

8 Pumphouse are owned and operated by Exelon. According to Exelon personnel, the reservoir 

9 is maintained at an operating level of 17 to 21 ft (5.2 to 6.4 m), and the reservoir can be pumped 
Purpose and Need for Action

2-20

1 down as far as 8 ft (2.4 m) before suction is lost. From the Bradshaw Reservoir, water is 

2 pumped about 6 miles (10 km) by pipeline routed along a natural gas pipeline right-of-way to 

3 East Branch Perkiomen Creek. Located about midway along the pipeline routing, Exelon also 

4 owns and operates the Bedminster Water Processing (Treatment) Facility that is used to 

5 seasonally disinfect the water before it is discharged into the East Branch Perkiomen Creek in 

6 accordance with NPDES Permit PA0052221. 

7 In the event drought conditions on the Delaware River threaten the ability to transfer water to 

8 East Branch Perkiomen Creek, Exelon also has an agreement in place as one of the seven 

9 utility owners of the Merrill Creek Reservoir in northwestern New Jersey to release water to the 

10 Delaware for flow augmentation purposes. This could be exercised in the event of a 

11 DRBC-declared drought emergency. A separate DRBC docket governs operation of the 

12 reservoir. 

13 2.1.6.4. Wadesville Mine Pool and Still Creek Reservoir Augmentation Sources

14 LGS also uses two additional upstream water sources, the Wadesville Mine Pool and Merrill 

15 Creek Reservoir, to directly augment Schuylkill River flow (see Figure 2–9). As a demonstration 

16 project, DRBC approved the use of these sources in 2002 to compensate for the withdrawal of 

17 cooling water from the Schuylkill River and to evaluate the feasibility of continuing withdrawals 

18 from the river even under low flow conditions. Flow augmentation with these sources began in 

19 2003 and has included DRBC oversight. The Wadesville Mine Pool is located approximately 

20 70 miles (112 km) northwest of LGS in Pennsylvania’s anthracite coal region. The mine pool is 

21 comprised of an extensive complex of flooded underground mine workings some 700 ft (210 m) 

deep, storing an estimated 3.6 billion gal (13.6 billion m3 22 ) of water. The mine pool is unique, as 

23 compared to other coal workings that contribute to acid mine drainage, in that the water 

24 percolating through the workings has a neutral pH (NAI and URS 2011). Additionally, releases 

25 from the Still Creek Reservoir, located northeast of the Wadesville Mine Pool, are included in 

26 the demonstration project. DRBC previously approved this reservoir for emergency releases 

27 under a contract between Exelon and its owner and operator to augment low flows in the 

28 Schuylkill River when the Delaware River diversion system is unavailable (see Section 2.1.7.1). 

29 Circulating Water System. The LGS circulating water system is a closed-cycle cooling system 

30 that removes heat from the condenser and transfers it to the atmosphere through evaporation 

31 using hyperbolic natural-draft cooling towers. The plant’s twin cooling towers rise more than 

32 500 ft (152 m) above the ground. The circulating water system uses water from the LGS 

33 makeup water system to replenish the water lost from evaporation, drift, and blowdown. For 

34 each LGS unit, the circulating water system consists of one cooling tower, three main 

35 condensers, four 25-percent-capacity circulating water pumps, and associated piping, valves, 

36 controls, and instrumentation.

37 Blowdown Discharge System. Operation of LGS’s closed-cycle cooling system results in 

38 evaporative water losses of approximately 75 percent from the plant’s twin cooling towers. To 

39 control the chemistry of the water in the cooling system due to the buildup of total dissolved 

40 solids, a portion of the water must be continuously discharged. Each cooling tower basin has a 

41 blowdown line that combines into a single, 36-in. (32-cm) line that discharges through a 

42 submerged, multi-port diffuser pipe into the Schuylkill River at a point about 700 ft (210 m) 

43 downstream from the Schuylkill Pumphouse (see Figure 2–8). The diffuser is encased in a 

44 concrete channel stabilization structure on the east side of the river. The discharge structure 

45 consists of a 28-in. (71-cm) pipe with a total of 283 nozzles installed on 6-in. (15-cm) centers; 

46 nozzles have a 1.25-in. (3.2-cm) diameter opening. As shown in Figure 2–8, the diffuser does 

47 not use the entire channel width. 
Purpose and Need for Action

2-21

1 Plant Service Water System. The plant service water system functions continuously to supply 

2 water for service-water cooling (e.g., removal of heat rejected from auxiliary equipment), 

3 emergency service water, residual heat removal service water, and the clarified water system. 

4 Generally, these are small and normally nonconsumptive uses of water.

5 Each LGS unit has a nonsafety-related single-loop cooling system for normal operations that 

6 uses three 50-percent capacity pumps operating, with one pump on standby status. These 

7 loops take water from each unit’s cooling tower basin. These pumps circulate cooling water 

8 from the cooling tower basins through various heat exchangers and then back to the cooling 

9 towers. This service water system may at times also support decay heat removal during a 

10 refueling outage. 

11 An emergency service water system exists to supply cooling water to emergency equipment in 

12 the event of the loss of normal cooling. The system consists of two independent cooling loops 

13 and associated pumps. The pumps circulate water through the LGS spray pond located north 

14 of the LGS cooling powers for cooling through spray nozzles or winter bypass lines. Another 

15 safety-related system, the residual heat removal system, is also routed through the spray pond. 

16 The two loops of this system supply cooling water to each of the two heat exchangers that serve 

17 each LGS unit. 

18 Clarified river water for component lubrication and as makeup to the demineralized water 

19 system is supplied by the clarified water system. This system uses water from the cooling water 

20 intake system. 

21 Groundwater Supply System. Potable water and fire emergency water for LGS are provided by 

22 two separate wells. Two additional wells supply nonpotable water intermittently to the Limerick 

23 Training Center and the Limerick Energy Information Center, respectively. 

24 2.1.7. Facility Water Use and Quality

25 As discussed above, LGS Units 1 and 2 use a closed-cycle cooling system that primarily relies 

26 upon the Schuylkill River for its makeup water supply and, secondarily, Perkiomen Creek (see 

27 Section 2.1.6). Water losses from the plant’s cooling towers because of evaporation and drift 

28 average about 75 percent. As this water must be continually replaced, such a high consumptive 

29 use can conflict with the needs of other downstream users and with aquatic life, especially on 

30 smaller rivers (Exelon 2011b). 

31 However, Exelon has developed an extensive surface water diversion system to supplement 

32 LGS’s consumptive cooling water needs and to manage (augment) low river flows, as also 

33 described in Section 2.1.6. The Schuylkill River is also the makeup water source for replacing 

34 water discharged as blowdown from the cooling towers, which is necessary to control the quality 

35 of the recirculating cooling water. This use is considered to be nonconsumptive in nature. 

36 Nevertheless, all surface water withdrawals by LGS are regulated by the DRBC. Cooling tower 

37 blowdown, in addition to other plant wastewaters, is ultimately discharged back to the Schuylkill 

38 River via a submerged discharge structure. This is LGS’s main outfall (no. 001), which is 

39 regulated under its Pennsylvania NPDES permit (No. PA0051926), in addition to DRBC docket 

40 provisions (Exelon 2011b). 

41 Exelon also operates two primary groundwater supply wells in the main plant area to meet the 

42 potable needs of plant personnel and to supply fire emergency water, respectively. Two 

43 additional wells, one at the Limerick Training Center and another at Limerick Energy Information 

44 Center, supply water for sanitary needs in restrooms (Exelon 2011b). 

45 Exelon is annually required to report water use data for LGS to the PADEP in accordance with 

46 the Pennsylvania Water Resources Planning Act pursuant to 25 Pa. Code 110 (Exelon 2011b). 
Purpose and Need for Action

2-22

1 NRC staff reviewed the last 5 years of Exelon’s Act 220 Water Withdrawal and Use Reports 

2 submitted to the PADEP. 

3 A description of surface water resources at LGS and vicinity is provided in Section 2.2.4, and a 

4 description of the groundwater resources is presented in Section 2.2.5. The following sections 

5 further describe the water use from these resources.

6 2.1.7.1. Surface Water Use 

7 Makeup water demands for LGS Units 1 and 2 nominally total 56.2 mgd or 39,000 gpm (87 cfs 

or 2.5 m3

/s). For full operations, this includes 42 MGD or 29,200 gpm (65 cfs or 1.8 m3 8 /s) for 

consumptive cooling water use and 14.2 mgd or 9,860 gpm (22 cfs or 0.6 m3 9 /s) for 

10 nonconsumptive use (Exelon 2011b). As previously discussed, LGS water usage is governed 

11 by the DRBC docket approval and demonstration project that restricts surface water withdrawals 

12 from the Schuylkill River for consumptive use to protect water quality and quantity. These 

13 restrictions are triggered, requiring Exelon to switch to alternative water sources, when either 

the flow of the river falls below 560 cfs (15.9 m3

/s) for two-unit operation, or 530 cfs (15 m3 14 /s) for 

15 one-unit operation. This is adjusted based on upstream releases from DRBC-approved projects 

16 (DRBC 2004, Exelon 2011a). 

17 In addition, PADEP requires that water users submit water use information annually, in support

18 of its State Water Plan. Accordingly, Exelon reports LGS water usage to PADEP. The State 

19 Water Plan serves as a functional planning tool to establish vision, goals, and recommendations 

20 for meeting the challenges of sustainable water use over a 15-year planning horizon.

21 Since initiating the water supply diversion project in 2003, Exelon has sought to demonstrate 

22 that makeup water demands could be obtained from the Schuylkill River over a much wider 

23 range of conditions without deleterious effects. This included a major modification to the 

24 demonstration project that was approved in 2005 which, for the first time, allowed for 

25 withdrawals from the Schuylkill River for consumptive use when ambient water temperature was 

26 at or above 59 oF (15 oC). Previously, DRBC prohibited withdrawals for consumptive use 

27 makeup at or above that temperate and required LGS to rely upon the Perkiomen Pumphouse 

28 (Exelon 2011b). In summary, the objectives of the demonstration project include: (1) gaining 

29 an understanding of increased reliance on the Schuylkill River, (2) evaluating the effects of 

30 permanently lifting the 59 oF (15 oC) temperature restriction, (3) evaluating the effects of using 

31 the Wadesville Mine Pool and Still Creek Reservoir as low flow augmentation sources, 

32 (4) evaluating the effects of reducing water diversions from the Delaware River, and 

33 (5) evaluating the effects on public water supplies (Exelon 2012d). Based on the results of the 

34 demonstration project, Exelon submitted an application to the DRBC in September 2007 to 

35 make the provisions of the demonstration project permanent to support LGS operations and to 

36 consolidate all of DRBC’s docket approvals for surface water withdrawal, discharge, and 

37 groundwater usage into a single comprehensive docket (Exelon 2011a, DRBC 2011a). 

38 In May 2011, the DRBC passed a resolution approving Exelon’s request to increase LGS’s peak 

daily surface water withdrawals from 56.2 mgd or 39,000 gpm (87 cfs or 2.5 m3 39 /s) to 58.2 mgd

or 40,420 gpm (90 cfs or 2.6 m3 40 /s). This request was made to increase consumptive use 

withdrawals by 2 mgd or 1,390 gpm (3.1 cfs or 0.09 m3 41 /s) to provide operational flexibility to 

42 counter conditions of high air temperature combined with low relative humidity that had caused 

43 LGS to approach its maximum daily withdrawal limit in 2010 (DRBC 2011b). In 

44 December 2011, the DRBC extended the terms of docket Revision 12 for LGS, including the 

45 demonstration project for another year to enable it to complete work on Exelon’s docket revision 

46 and to hold a public hearing. As such, the terms of the current DRBC docket approval 

47 (DRBC 2004), as amended, and demonstration project remain in effect through 

48 December 31, 2012 or until the DRBC approves a revised docket (DRBC 2011a). 
Purpose and Need for Action

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1 Exelon officials met with DRBC officials on the status of the consolidated docket in 

2 February 2012 (Exelon 2012a). In June 2012, DRBC issued a draft consolidated docket for 

3 review and comment and held a hearing on August 28, 2012.

4 2.1.7.2. Groundwater Use 

5 Groundwater is withdrawn at LGS through two onsite wells to support LGS operations, with two 

6 additional wells supporting secondary uses (see Section 2.1.7). 

7 Well 1 (the “Alley” Well) supplies potable water to LGS personnel. Well 3 (the “Batch Plant”

8 Well) provides backup water supply to a fire water storage tank. Both wells were constructed as 

9 open boreholes in the Brunswick Formation with completion depths of 310 ft (94 m) and 585 ft 

10 (178 m) and pump capacities of 50 gpm (189 L/min) and 65 gpm (246 L/min), respectively. 

11 Both wells had their pumps replaced in 2004. Well 1 is located just east of the Unit 2 buildings 

12 and southeast of the Unit 2 cooling tower, while well 3 is located about 500 ft (150 m) east of the 

13 Unit 2 cooling tower (CRA 2006, Exelon 2011a). As a potable supply well for the plant, Well 1 is 

14 operated by Exelon under a public water supply permit from the PADEP. Before distribution, 

15 the water is treated by disinfection, for corrosion control for lead and copper, and by filtration to 

16 reduce arsenic levels (Exelon 2011b). 

17 Two additional active groundwater wells (i.e., the Training Center and Energy Information 

18 Center wells) are located on the LGS plant site but outside the main plant complex. These wells 

19 are seldom operated and only to provide sanitary water for restrooms at the referenced facilities 

20 (Exelon 2011b). The Training Center well is 560 ft (170 m) in depth and the Information Center 

21 well is 123 ft (37.5 m) in depth, based on Pennsylvania well records (Exelon 2011a, 

22 PADCNR 2012). 

23 LGS’s wells are located in the Southeastern Pennsylvania Ground Water Protected Area 

24 designated by the DRBC. Specifically, LGS is located in the Schuylkill-Sprogels Run Subbasin 

25 designated by the DRBC and for which basin-wide groundwater withdrawal limits have been set 

26 due to stress on the bedrock aquifer system (DRBC 1999, Exelon 2011a). Groundwater users 

27 in subbasins designated by the DRBC as stressed and withdrawing 10,000 gallons per day 

28 (gpd) (38,000 L/day) or more during any 30-day period are required to obtain a protected area 

29 permit from the DRBC or have docket approval for such withdrawals (DRBC 1999, 

30 18 CFR 430). The draft docket issued by the DRBC (see Section 2.1.7.1) proposes

31 groundwater production limits for LGS. 

32 Based on data from 2001 through 2010, LGS’s total groundwater production from its primary 

33 production wells has ranged from 14.3 to 21.1 gpm (54.1 to 79.9 L/min) or 20,600 to 

34 30,300 gpd, and averaged 17.9 gpm (67.8 L/min) or 25,800 gpd (Exelon 2011a, 2012b). While 

35 not subject to reporting under PADEP regulations, the two LGS secondary wells produce less 

36 than 4 gpm (13.9 L/min) combined (Exelon 2011b). 

37 2.2. Surrounding Environment

38 The LGS plant site comprises a total of 645 ac (261.0 ha), including 491 ac (198.7 ha) in 

39 Montgomery County and 154 ac (62.3 ha) in Chester County. The LGS site is located along the 

40 Schuylkill River, which flows in a southeasterly direction to its confluence with the Delaware 

41 River. The Schuylkill River passes through the LGS plant site and separates its western 

42 portion, which is located in Chester County, from its eastern portion, which is located in 

43 Montgomery County. 

44 The LGS is located about 1.7 miles (2.7 km) southeast of the Borough of Pottstown, the nearest 

45 population center. Other nearby population centers are the City of Reading located 19 miles 
Purpose and Need for Action

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1 (30.6 km) northwest of the site, the Borough of Phoenixville located about 9.3 mi(15 km) 

2 southeast of the site, the Municipality of Norristown about 11 miles (17.7 km) southeast of the 

3 site, and the city limits of Philadelphia, which are about 21 miles (33.8 km) southeast of the site.

4 2.2.1. Land Use

5 The site is surrounded by gently rolling countryside and farmland, with several valleys 

6 containing tributary drainages of the Schuylkill River. The vicinity of the site has experienced 

7 suburban growth as local farmland has been converted to several new residential subdivisions 

8 since the LGS units came online in 1986 and 1990. Figure 2–1 illustrates the principal land 

9 uses in the vicinity of the LGS, out to 6 miles (10 km).

10 Exelon owns both the primary LGS site and several offsite support facilities, including the 

11 Perkiomen Pumphouse, the Perkiomen Pumphouse-to-LGS pipeline, Bradshaw Reservoir and 

12 Pumphouse, and the Bedminster Water Processing (Treatment) Facility. Additional offsite 

13 facilities and components of the LGS makeup water system having contractual agreements with 

14 Exelon, but which are neither owned nor controlled by Exelon, including the following:

15  Wadesville Mine Pool, Pumphouse, and discharge channel,

16  Still Creek Reservoir,

17  Point Pleasant Pumping Station and combined water transmission main to 

18 the Bradshaw Reservoir, and 

19  Pottstown Gage Station, the Graterford Gage Station, and the Bucks Road 

20 Gage Station. 

21 Exelon jointly owns and operates the Merrill Creek Reservoir near Phillisburg, New Jersey, with 

22 six other utilities. The reservoir stores water for release when required to mitigate consumptive 

23 use at designated electric generating facilities, including LGS, in the event of low-flow conditions 

24 in the Delaware River. 

25 The major transportation routes located within 6 miles (10 km) of the site include 

26 U.S. Highway 422 (US-422), an east-west highway passing about 1.5 miles (2.4 km) north of 

27 the site; Pennsylvania Route 100 (PA-100), a north-south highway passing about 4 miles 

28 (6.4 km) west of the site in Chester County; and PA-724, a southeast-northwest highway 

29 passing about 1 mile (1.6 km) southwest of the site. The single plant entrance/exit can only be 

30 accessed by Evergreen Road, either directly from the Sanatoga exit of US-422 or indirectly from 

31 the Limerick Linfield exit of US-422 by several local roads. Figure 2–2 illustrates prominent 

32 features of the LGS region, out to 50 miles (80 km).

33 All activities on the LGS site are under the control of Exelon. The immediate area surrounding 

34 LGS is enclosed by a security barrier shown in Figure 2–3. Access to LGS is through a security 

35 gate by a three-lane road, Evergreen Road, north of the plant. A Conrail rail line (formerly 

36 Reading Company) traverses the LGS site along the eastern side of the Schuylkill River. The 

37 rail line includes two tracks and a rail spur serving LGS. Another Conrail rail line (formerly Penn 

38 Central Railroad) runs along the western side of the Schuylkill River, traversing the Chester 

39 County portion of the LGS site.

40 Notable manmade features within a 6-mile (10-km) radius of LGS (see Figure 2–1) include the 

41 Pottstown-Limerick regional airport roughly 1.5 miles (2.5 km) northeast, the Philadelphia 

42 Premium Outlets shopping mall roughly 1 mile (1.6 km) northeast, and the Occidental Chemical 

43 Corporation/Firestone Tire EPA superfund site roughly 1.5 miles (2.4 km) west of the LGS site.
Purpose and Need for Action

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1 Nearby communities include Pottstown, approximately 1.7 miles (2.7 km) northwest; 

2 Royersford, 3.8 miles (6.1 km) southeast; Phoenixville, 7.6 miles (12.2 km) southeast; and 

3 Philadelphia, 29 miles (46 km) southeast of the LGS site.

4 2.2.2. Air Quality and Meteorology

5 The LGS site is located within the Schuylkill River valley of the Piedmont Plateau in 

6 southeastern Pennsylvania. LGS maintains two meteorological towers that are in close 

7 proximity to the site. The primary tower (Tower 1) is located approximately at site grade and is 

8 76.2 m (250 ft) above mean sea level (MSL) (Exelon 2011b). The secondary tower (Tower 2) is 

9 located closer to the Schuylkill River and is at an elevation of 36.9 m (121 ft) above mean sea 

10 level. The meteorological towers are instrumented at three levels and take measurements of 

11 wind direction, wind speed, and temperature. Additional measurements, including wind 

12 direction fluctuations, relative humidity, pressure, and precipitation, are made at Tower 1.

13 The region surrounding the LGS site is characterized by a humid, continental climate that is 

14 moderated by the presence of the Appalachian Mountains to the west and the Atlantic Ocean to 

15 the east (NCDC 2012a). Periods of extreme heat or cold are generally short-lived. The 

16 summer months of June through September are warm and humid, and at times the area is 

17 engulfed in maritime air from the western Atlantic (NCDC 2012b). The winter months of 

18 December through February are characterized by frequent periods of warming and cooling from 

19 mid-latitude, low-pressure systems and associated fronts passing through the area; minimum 

20 temperatures during this time are usually below freezing, but temperatures below zero are rarely 

21 observed (NCDC 2012c).

22 The staff obtained climatological information with 30-year averages (1981−2010) for the 

23 Allentown and Philadelphia, Pennsylvania, first-order National Weather Service (NWS) stations. 

24 Both stations are approximately 30 miles from the LGS site and can be used to characterize the 

25 region’s climate because of their nearby location, comparable elevation, and long period of 

26 record. Regionally, the prevailing wind direction is from the southwest during most of the year, 

27 except during the winter months, when it is generally from the west-northwest 

28 (NCDC 2012b, 2012c). During stable atmospheric conditions, low-level winds at the LGS site

29 may be channeled in the same general direction as the Schuylkill River Valley, which is oriented 

30 in the north-northwest to south-southeast direction (Exelon 2012c). Mean annual wind speeds 

31 average around 8 to 9 mph (3.5 to 4.0 m/s); winds are faster than average in the spring and 

32 slower than average in late summer (NCDC 2012b, 2012c). Peak wind gusts were 69 mph

33 (30.8 m/s) in Allentown (NCDC 2012c) and 75 mph (33.5 m/s) in Philadelphia (NCDC 2012b).

34 In Allentown, monthly mean temperatures range from a low of 27.9 °F (-2.3 °C) in January to a 

35 high of 74.1 °F (23.4 °C) in July (NCDC 2012b). In Philadelphia, monthly mean temperatures 

36 are slightly warmer and range from 32.3 °F (0.2 °C) in January to 77.6 °F (25.3 °C) in July 

37 (NCDC 2012b). Recent monthly mean temperature observations taken at the LGS site are 

38 consistent with these ranges (Exelon 2012b). 

39 Normal annual liquid precipitation is 42.05 in. (1,068 mm) in Philadelphia (NCDC 2012b) and 

40 45.17 in. (1,147 mm) in Allentown (NCDC 2012c). The precipitation during the wettest year 

41 from the most recent 30-year period of record was 71.72 in. (1,822 mm) in 2011 (NCDC 2012c); 

42 during the driest year from the same period it was 30.41 in. (772 mm) in 1992 (NCDC 2012b). 

43 The summer months of June, July, and August are the wettest, averaging 4.0 in. (102 mm) of 

44 precipitation each month at both locations (NCDC 2012b, 2012c). February is the driest month, 

45 averaging 2.75 in. (70 mm) of precipitation (NCDC 2012b, 2012c). Precipitation trends 

46 measured at LGS (Exelon 2012c) are consistent with trends observed at Allentown and 

47 Philadelphia. Average annual snowfall for the area is 19.3 in. (49.0 cm) in Philadelphia 
Purpose and Need for Action

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1 (NCDC 2012b) and 32.3 in. (80.0 cm) in Allentown (NCDC 2012c). The higher snowfall 

2 amounts at Allentown are likely to be more representative of the LGS site because the 

3 Philadelphia NWS station is warmer because of its more southeastern location as well as 

4 additional heating from the urban environment. 

5 Thunderstorms are normally observed on 27 days throughout the year (NCDC 2012b, 2012c). 

6 Severe weather in the form of hail, tornadoes, or hurricanes is not commonly observed in the 

7 region. In the past 5 years, there have been 29 large hail (more than 0.75 in. [1.9 cm] in 

8 diameter) events reported in both Montgomery and Chester Counties, but many of the hail 

9 reports are associated with the same storm (NCDC 2012d). Tornadoes do not occur frequently 

10 in the region. In the past 5 years, no tornadoes were reported in Montgomery County and one 

11 tornado (classified on the Enhanced Fujita scale as an EF0, with a 65–85 mph (29.1–38.0 m/s) 

12 3-second wind gust) occurred in Chester County (NCDC 2012d). Using tornado data for the 

13 period from January 1, 1950, through August 31, 2003, the annual best-estimate tornado strike 

probability for a 1-degree box that includes the LGS site is 1.59x10-4 14 (Ramsdell and 

15 Rishel 2007). Tropical cyclones are rarely of hurricane strength by the time they are in the 

16 vicinity of the LGS site. The National Oceanic and Atmospheric Administration (NOAA) 

17 maintains a database of tropical cyclone tracks and intensities that covers the period from 

18 1842 through 2010. During this time, only two Category 1 hurricanes, with maximum sustained 

19 winds of 74−95 mph (33.0–42.5 m/s), have passed within 80 km (50 miles) of the LGS site 

20 (NOAA 2012). 

21 2.2.2.1. Air Quality

22 Under the Clean Air Act (CAA) of 1963, EPA has set primary and secondary National Ambient 

23 Air Quality Standards (NAAQSs, 40 CFR 50) for six common criteria pollutants to public health 

24 and the environment. The NAAQS criteria pollutants include carbon monoxide, lead, nitrogen 

25 dioxide, ozone, sulfur dioxide, and particulate matter (PM). PM is further categorized by 

26 size—PM10 (diameter of 10 micrometers or less) and PM2.5 (diameter of 2.5 micrometers or 

27 less). 

28 EPA designates areas of “attainment” and “nonattainment” with respect to the NAAQSs. Areas 

29 for which insufficient data are available to determine designation status are denoted as 

30 “unclassifiable.” Areas that were once in nonattainment, but are now in attainment, are called 

31 “maintenance” areas; these areas are under a 10-year monitoring plan to maintain the 

32 attainment designation status.

33 Air quality designations are generally made at the county level. For the purpose of planning and 

34 maintaining ambient air quality with respect to the NAAQSs, EPA has developed Air Quality 

35 Control Regions (AQCRs). AQCRs are intrastate or interstate areas that share a common 

36 airshed (40 CFR 81). The LGS site is located in Montgomery and Chester Counties, 

37 Pennsylvania; these counties are part of the Metropolitan Philadelphia Interstate AQCR 

38 (40 CFR 81.15). Additional counties in this AQCR include Bucks, Delaware, and Philadelphia 

39 Counties. With regard to the NAAQSs, Montgomery and Chester Counties are designated as 

40 unclassified or in attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10

41 and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339).

42 States have primary responsibility for ensuring attainment and maintenance of the NAAQSs. 

43 Under Section 110 of the CAA (42 USC 7410) and related provisions, states are to submit, for 

44 EPA approval, State Implementation Plans (SIPs) that provide for the timely attainment and 

45 maintenance of the NAAQSs. On March 26, 2012, EPA approved and promulgated the 

46 PADEP’s SIP for ozone in the Philadelphia area, including Montgomery and Chester Counties 

47 (77 FR 17341). Similarly, on March 29, 2012, EPA approved and promulgated PADEP’s 

48 revisions to the SIP for PM2.5 (77 FR 18987).
Purpose and Need for Action

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1 As required under 25 Pa. Code Chapter 127, Exelon maintains a Title V operating permit 

2 (TVOP-46-00038) for sources of air pollution at the LGS site (Exelon 2011b). Permitted sources 

3 include two cooling towers, a spray pond, several standby diesel generators and boilers, a 

4 solvent-based degreasing unit, and air emissions from various sources of waste oil 

5 (Exelon 2011b). As a condition of the Title V operating permit, Exelon is required to submit an 

6 annual compliance certification to the PADEP, which includes fuel usage and estimated air 

7 pollutant emissions (Exelon 2012b). Table 2–1 lists the total diesel fuel usage and associated 

8 air emissions for the most recent 5 years (Exelon 2012b). There are no plans for refurbishment 

9 of structures or components at LGS for license renewal. Therefore, there are no expected new 

10 air emissions associated with license renewal (Exelon 2011b). 

11 Table 2–1. Annual Fuel Use and Estimated Air Emission Estimates for Significant 

12 Sources at LGS

Year Fuel Usage 

(gal)(a) NOx (T)(b) CO (T)(b) SOx (T)(b) PM2.5 (T)(b) PM10 (T)(b) VOC (T)(b) Pb (T)(b)

2007 1,128,502 29.3 22.7 6.1 0.44 42.3 0.80 0.0000

2008 927,297 31.2 19.8 4.8 0.47 42.2 0.90 0.0010

2009 858,760 28.4 18.5 3.8 0.41 42.7 1.97 0.0005

2010 1,003,210 35.3 21.8 4.0 0.72 161.1c 2.13 0.0006

2011 1,145,960 32.8 24.2 7.8 0.80 166.3c 2.10 0.0010

(a) To convert gallons to liters, multiply by 3.8. (b) To convert T to MT, multiply by 0.91. (c) Beginning in 2010, the emission calculation for PM10 was changed for reporting purposes; no actual change in 

operations occurred and therefore no change in actual PM10 emissions (LGS RAI Reply E1-1). 

NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulphur oxides; PM2.5 = particulate matter with a diameter of 

2.5 micrometers or less; PM10 = particulate matter with an aerodynamic diameter between 2.5 and 10 micrometers; 

VOC = volatile organic compounds; Pb = lead.

Source: Exelon 2012b

13 40 CFR 81 Subpart D lists mandatory Class I Federal Areas where visibility is an important 

14 value. There are no mandatory Class I Federal areas within 50 miles (80 km) of the LGS site. 

15 The closest mandatory Class I Federal area is the Brigantine Wilderness in New Jersey, which 

16 is approximately 78 miles (127 km) southeast of the LGS site (40 CFR 81.420). Because of the 

17 significant distance from the site and prevailing wind direction, no adverse impacts on Class I 

18 areas are anticipated from LGS operation. 

19 2.2.3. Geologic Environment

20 This section describes the current geologic environment of the LGS site and vicinity including 

21 landforms, geology, soils, and seismic setting.

22 Physiography. LGS is located within the Gettysburg-Newark Lowland Section of the Piedmont 

23 physiographic province. This region is generally comprised of rolling lowlands, shallow valleys, 

24 and isolated hills and mainly underlain by red shale, siltstone, and sandstone, with some 

25 conglomerate and diabase (DCNR 2000). 

26 The main plant complex, including the LGS nuclear island, is situated on a broad, semi-circular 

27 ridge on the eastern bank of the Schuylkill River. Site topography slopes steeply to the west 

28 and south toward the Schuylkill River and Possum Hollow Creek, respectively. Elevations 

29 range from less than 110 ft (34 m) above MSL at the Schuylkill River to approximately 280 ft 
Purpose and Need for Action

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1 (85 m) MSL at the highest elevation near the cooling towers. Blasting and other construction 

2 activities have modified the natural land surface across the plant site (Exelon 2011b). 

3 Geology. Thick bedrock consisting of reddish-brown siltstone and interbedded sandstone and 

4 shale of the Brunswick Formation underlies the majority of the LGS site and vicinity. Rocks of 

5 the Sanatoga Member of the Lockatong Formation interfinger with the Brunswick in the northern 

6 part of the LGS site area and occur in the area of the spray pond, but do not occur beneath the 

7 cooling towers or the main plant structures. The Sanatoga is a bluish-gray, calcareous argillite 

8 with beds of black shale. This rock is relatively harder than the siltstone and other rocks of the 

9 Brunswick. In total, the uppermost bedrock sequence beneath the site is more than 5,000 ft 

10 (1,520 m) thick (Exelon 2008b).

11 The sediments that now comprise the Brunswick and other formations making up the near 

12 surface bedrock were deposited by streams feeding into one of a series of down-warped or 

13 down-faulted basins that formed during the late Triassic (i.e., between about 200 and 

14 228 million years ago). LGS overlies the northern (Newark) portion of one such basin, the 

15 Newark-Gettysburg Basin. The sediments that now constitute the rocks of the Brunswick 

16 Formation originally were deposited by an ancient river system in the form of a large alluvial fan 

17 while the Lockatong was deposited in a shallow lake environment (Exelon 2008b).

18 Subsequent to the deposition and consolidation of the basin sediments, the region was uplifted, 

19 tilted, and deformed. In addition, the sedimentary materials have been broken by numerous 

20 small faults and fractures and locally include interbeds of and intrusions by volcanic rocks. 

21 Numerous intrusions of the basin’s sedimentary rocks by volcanic diabase have been mapped 

22 throughout southeast Pennsylvania. One such prominent feature is a diabase dike (named the 

23 Downingtown Dike) that extends from about 11 miles (18 km) southwest of Downingtown, 

24 Pennsylvania, through Sanatoga Station, just north of the site, and continues about 3 miles 

25 (5 km) to the northeast. The sedimentary rock immediately bordering this feature has been 

26 thermally altered to a tough gray hornfels. Age dating of the numerous dikes in the region 

27 indicates that they were emplaced between about 140 and 198 million years ago 

28 Exelon 2008b). 

29 Across the LGS site and region, bedrock is overlain by up to 40 ft (12 m) of residual soil, 

30 developed in place by the weathering and decomposition of the bedrock. This material 

31 (regolith) grades into weathered rock (saprolite), then into fresh, unweathered rock; no clearly 

32 defined boundary exists between soil and rock. Holocene (recent) alluvium consisting of silt, 

33 sand, and gravel occurs along the Schuylkill River and tributaries such as Possum Hollow Run

34 (Exelon 2008b). 

35 Numerous small faults and fractures occur in the Triassic strata underlying LGS. These 

36 features formed as a result of regional uplift that occurred following the consolidation of 

37 sediments in the Newark basin (Exelon 2008b). Most notable on a regional basis, the northwest 

38 border of the Newark basin in northern New Jersey and southeastern New York State is marked 

39 by a system of normal faults known as the Ramapo fault system. This fault system has been 

40 extensively studied by various investigators, including the USGS, in part because historical 

41 epicenters of small earthquakes have been loosely associated with this fault system (Crone and 

42 Wheeler 2000). Information compiled by Exelon (2008b) indicated that there is no clear 

43 association between the Ramapo fault and earthquake epicenters in the region, and no 

44 evidence for fault reactivation or fault offset at the surface. USGS’s review of data for evidence 

45 of Quaternary fault activity (i.e., within the last 1.6 million years) encompassing the Eastern 

46 United States supports these conclusions, finding that geologic evidence is insufficient to 

47 demonstrate either the existence of a tectonic fault or Quaternary slip or deformation associated 
Purpose and Need for Action

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1 with the feature (Crone and Wheeler 2000, Wheeler 2006). Further, the Ramapo is not included 

2 in the USGS’s latest Quaternary Fault and Fold Database (USGS 2012a). 

3 Three small faults, the Sanatoga, the Brooke Evans, and the Linfield, occur within 2 miles 

4 (3.2 km) of the LGS site. The nearest approach of any fault, the Sanatoga fault, to the reactor 

5 area is 1,300 ft (400 m) to the west. The fault plane is intruded by Triassic diabase, which is 

6 part of the Downingtown Dike. The Brooke Evans fault passes within 2,800 ft (850 m) to the 

7 south of the plant area, and the trace of the Linfield fault lies about 2 miles (3.2 km) southeast of 

8 the LGS site. All three of these faults are associated with the Jurassic-Triassic events that 

9 occurred some 140 to 200 million years ago. Field studies of diabase intrusions of these faults 

10 indicate that they have been inactive for at least 140 million years (Exelon 2008b). Thus, none 

11 of these faults are active or considered “capable” of producing earthquakes per 10 CFR 100, 

12 Appendix A. 

13 During foundation excavation for the plant, several features, including shear-fractures with some 

14 small offsets (displacement), were encountered. While not unusual for the region and not 

15 posing a hazard to plant structures, these areas were treated as necessary to ensure 

16 subsurface stability. Treatment included excavating any soft or otherwise weathered material 

17 down to competent bedrock and/or by replacing excavated material with concrete, as further 

18 described in the updated final safety analysis report (UFSAR) (Exelon 2008b). 

19 There are no outstanding mineral rights within the LGS exclusion area (Exelon 2008b). There is 

20 one quarry (Pottstown Trap Rock Sanatoga Quarry) located about 0.8 miles (1.2 km) from the 

21 center of the main plant complex and adjacent to LGS’s northern property boundary. 

22 Operations at the quarry consist of blasting, crushing, grading, and stockpiling rock 

23 (Exelon 2008b). The Sanatoga Quarry produces red aggregate stone for use in construction 

24 and landscaping applications. The site also has an asphalt production operation (H&K 

25 Group 2012). 

26 Soils. Soils at the site, where present, consist predominantly of residual clayey silts 

27 (Exelon 2008b). Soil unit mapping by the Natural Resources Conservation Service (NRCS) 

28 identifies the majority of the LGS site complex as Urban land-Udorthents, shale and sandstone 

29 complex, 8 to 25 percent slopes. Consistent with the developed nature of the LGS site, this soil 

30 mapping unit is used to identify buildings and other impervious surfaces on hills and other 

31 uplands on graded land surfaces underlain by shale and sandstone. Natural soils bordering the 

32 main plant complex to the north and northeast include Penn silt loam, Readington silt loam, and 

33 Reaville silt loam, 0 to 8 percent slopes. These are generally moderately to well-drained soils 

34 on hills and hillslopes that developed from residuum weathered from sandstone and shale 

35 parent material. Depth to bedrock ranges from 20 to 40 in. (50 to 100 cm), which imparts a 

36 slight limitation for building site development. These soils are all prime farmland soils or 

37 farmland of statewide importance, where otherwise not committed to developed uses 

38 (7 CFR 657.5). This includes a continuous area totaling about 25 ac (10 ha) of Penn silt loam, 

39 3 to 8 percent slopes just to the northeast of the spray pond. To the south and southeast along 

40 the north side of Possum Hollow Run, the soils are mapped as Klinesville channery silt loam, 

41 35 to 60 percent slopes. These soils are relatively shallow and somewhat excessive drained. 

42 Soils along both banks of the Schuylkill River in the vicinity of LGS are mapped as Gibraltar silt 

43 loam. These soils are relatively deep, well-drained soils occupying valley flats, hills, and levees. 

44 Their parent material is coal overwash (i.e., materials derived from upstream coal mining) over 

45 alluvium derived from shale and siltstone. These soils are very limited for building site 

46 development because of the threat of ponding and flooding (NRCS 2012). 

47 Foundations for all seismic Category I (safety-related) structures at LGS are founded on hard, 

48 competent bedrock or were excavated to unweathered bedrock. In addition, no other localized 
Purpose and Need for Action

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1 geologic hazards, old landslides, rock slips, or landslide scars have been identified near plant 

2 structures (Exelon 2008b). 

3 Seismic Setting. Eastern Pennsylvania lies within a region that has experienced a moderate 

4 level of earthquake activity. However, zones of major earthquakes are located more than 

5 200 miles (340 km) from the site and have not had an appreciable effect at LGS 

6 (Exelon 2008b). Probabilistic analysis that considers both the occurrence and intensity of 

7 earthquakes within and outside Pennsylvania indicate a relatively low seismic risk overall 

8 (DCNR 2003). 

9 Pennsylvania is affected by small earthquakes that occur on local faults (DCNR 2003). Within a 

10 radius of 62 miles (100 km) of LGS, a total of 56 earthquakes have been recorded since 1973. 

11 The largest was a magnitude 4.6 event in January 1994, centered 24 miles (39 km) west of the 

12 site near Reading, Pennsylvania. The closest event was a magnitude 2.7 event in 

13 November 2003 with an epicenter 15 miles (24 km) west-northwest of LGS (USGS 2012b). 

14 These earthquakes are generally in association with the Lancaster Seismic Zone, an area of 

15 increased seismic activity, which encompasses recorded seismic events in Lancaster, York, 

16 Lebanon, and Berks Counties. This is the most active seismic zone in Pennsylvania. 

17 Southeastern Pennsylvania is not known to have experienced an earthquake with a magnitude 

18 greater than 4.7 (DCNR 2003). 

19 The largest earthquake recorded to date within the Commonwealth’s borders was a magnitude 

20 5.2 event on September 25, 1998, in northwestern Pennsylvania, some 280 miles (450 km) 

21 northwest of LGS. It caused only minor structural damage near the epicenter (e.g., bricks 

22 shaken from chimneys) and was classified by the USGS as producing Modified Mercalli 

23 Intensity (MMI) VI shaking. It was felt throughout northern Ohio and most of Pennsylvania and 

24 into bordering states (Dewey and Hopper 2009; USGS 2012c, 2012d). By comparison, a 

25 magnitude 6 earthquake occurring in southeastern New York or northern New Jersey could 

26 affect the easternmost counties of Pennsylvania. Historically, such events (i.e., in 1737 and 

27 1884) have produced MMI IV shaking in eastern Pennsylvania (DCNR 2003). Such a level of 

28 shaking would likely result in little to no damage to structures. 

29 As documented in the LGS UFSAR, evaluation of tectonic structures and the historical seismic 

30 record for the region indicated that a plant design for MMI VII shaking was adequately 

31 conservative for the site. MMI VII shaking was determined to correspond with a peak ground 

32 acceleration (PGA) of 0.13 g (i.e., force of acceleration relative to that of Earth’s gravity, “g”). 

33 For additional conservatism, 0.15 g was adopted for the LGS safe-shutdown earthquake (SSE) 

34 (Exelon 2008b).

35 For the purposes of comparing the plant SSE with a more contemporary measure of predicted 

36 earthquake ground motion for the site, the NRC staff also reviewed current PGA data from the 

37 USGS National Seismic Hazard Mapping Project. The PGA value cited is based on a 2 percent 

38 probability of exceedance in 50 years. This corresponds to an annual frequency (chance) of 

occurrence of about 1 in 2,500 or 4x10-4 39 per year. For LGS, the calculated PGA is 

40 approximately 0.11 g (USGS 2008). 

41 2.2.4. Surface Water Resources

42 2.2.4.1. Site Description and Surface Water Hydrology

43 The LGS main plant site is situated on a terraced hill that adjoins and overlooks the eastern 

44 bank of the Schuylkill River, and is located approximately 4 river miles (6.6 km) downriver from 

45 Pottstown, Pennsylvania. The plant site also lies 49 miles (79 km) upstream from the 
Purpose and Need for Action

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1 Schuylkill’s confluence with the Delaware River (Exelon 2011b). The Schuylkill River is within 

2 the boundaries of the Delaware River Basin. 

3 In addition to being bordered by the Schuylkill River, the LGS property is also cut by two 

4 northeast to southwest trending tributaries to the Schuylkill River, Possum Hollow Run, and 

5 Brooke Evans Creek. Possum Hollow Run runs along the southeastern boundary of the main 

6 plant complex and receives stormwater runoff from plant facilities (see Section 2.2.4.2). The 

7 only other notable surface water features on the LGS site are the spray pond and a small 

8 holding pond. Part of the emergency cooling system (see Section 2.1.6), the spray pond is a 

9 clay-lined, man-made impoundment covering 9.9 ac (4 ha). The holding pond is a 

10 concrete-lined structure located south of the power block and beyond the main plant protected 

11 area. It covers less than 0.5 ac (0.2 ha) and receives industrial wastewater from various plant 

12 systems; it is an internal NPDES monitoring point (outfall 201) to the plant’s main outfall 001 

13 (Exelon 2010d, 2011a). These features are not further assessed from the perspective of 

14 surface water hydrology. 

15 As described in Sections 2.1.6 and 2.1.7, all the water needs for the plant are provided by a 

16 combination of multiple subbasins’ flows in addition to flow from the mainstem Delaware River. 

17 While the Schuylkill River is the primary source of water for the plant, makeup water for 

18 consumptive (evaporative cooling) use must be supplemented with water taken from Perkiomen 

19 Creek during low flow periods on the Schuylkill River. Perkiomen Creek and its tributary (East 

20 Branch Perkiomen Creek) provide a channel to convey water pumped from the Delaware River 

21 to LGS. The nonconsumptive water withdrawals and other plant effluents are discharged to the 

22 Schuylkill River downstream of the LGS Schuylkill River intakes. 

23 Schuylkill River. The Schuylkill River flows for approximately 130 miles (209 km) to its 

24 confluence with the Delaware River at Delaware River Mile (RM) 92.5. Its watershed 

encompasses approximately 1,916 m2 (4,962 km2 25 ) and is one of the two largest tributaries to 

26 the Delaware River. Exelon’s Schuylkill Pumphouse is located at Schuylkill RM 48 

27 (Exelon 2011b). The mean annual discharge measured at the USGS gage at Pottstown, 

Pennsylvania, for water years 1928 through 2010 is 1,935 cfs (54.8 m3 28 /s). The 90 percent

exceedance flow is 482 cfs (13.6 m3 29 /s) (USGS 2010a, 2012e). For water year 2011, the mean 

discharge was 3,145 cfs (89.1 m3 30 /s). The 90 percent exceedance flow is an indicator value that 

31 a drought warning is appropriate. It signifies that the current 30-day average flow has been 

32 exceeded 90 percent of the time, as compared to the average flow for the period of record 

33 (DEP 2012). For the Schuylkill River, August is the low-flow month and March is the high-flow 

34 month over the period of record.

35 East Branch Perkiomen Creek. The East Branch Perkiomen Creek flows for a distance of 

36 24 miles (39 km) and enters Perkiomen Creek at a point about 11 stream miles (18 km) from the 

37 confluence of Perkiomen Creek with the Schuylkill River. Its flow is highly variable and, before

38 the establishment of the diversion of water from Exelon’s Bradshaw Reservoir, the creek was 

39 reportedly intermittent in nature during the summer and fall (Exelon 2011b). Based on water 

40 year data from 1990 through 2011, the mean annual discharge and 90 percent exceedance flow 

measured at the USGS gage at Dublin, Pennsylvania, are 35.8 cfs (1.0 m3 41 /s) and 13 cfs 

(0.37 m3 42 /s), respectively (USGS 2011a).

Perkiomen Creek. Perkiomen Creek drains an area of some 363 m2 (940 km2 43 ) and joins with 

44 the Schuylkill River at a point approximately 16 stream miles (26 km) downstream from LGS. 

45 For the period of 1915 through 1956 and prior to flow regulation due to Green Lane Reservoir 

46 beginning in late 1956, the reported mean annual discharge and 90 percent exceedance flow at 

the USGS gage at Graterford, Pennsylvania, are 389 cfs (11 m3

/s) and 42 cfs (1.2 m3 47 /s), 

48 respectively. As previously described (see Section 2.1.6), water has been diverted to the creek 
Purpose and Need for Action

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1 since August 1989 from the Delaware River at Point Pleasant to Bradshaw Reservoir and then 

2 pumped from the reservoir to East Branch Perkiomen Creek. For the period 1957 through

3 2011, the measured mean annual discharge and 90 percent exceedance flow values are 

435 cfs (12.3 m3

/s) and 65 cfs (1.8 m3 4 /s), respectively (USGS 2011b). 

5 Delaware River. The Delaware River flows 330 miles (531 km) from its origin in southern New 

6 York to the Delaware Bay, and it is the longest un-dammed river in the United States east of the 

7 Mississippi (DRBC 2012). The tidal portion of the Delaware River extends upriver from the 

8 estuary at Delaware Bay to Trenton, New Jersey. Upriver salinity intrusion varies according to 

9 increases or decreases in upriver inflows. The boundary of salinity intrusion, also known as the 

10 salt line, fluctuates with flow changes. The salt line is the point where the average sodium 

11 chloride concentration in the river exceeds 250 mg/L. The Point Pleasant Pumping Station used 

12 to transfer Delaware River water is located at Delaware RM 157, which is above the salt line 

13 (Exelon 2011b). Based on data for 1913 through 2010, the mean annual discharge and 

14 90 percent exceedance flow measured at the USGS gage at Trenton, New Jersey, are 

11,900 cfs (337 m3

/s) and 3,080 cfs (87.2 m3 15 /s), respectively. This gage site is at Delaware 

16 RM 134.5, about 20 river miles (32.2 km) downstream from the Point Pleasant Pumping Station 

17 (USGS 2010b).

18 2.2.4.2. Surface Water Quality and Effluents 

19 Among the powers and duties assigned to the DRBC are classifying all waters in the basin as to

20 use, setting basin-wide water quality standards, establishing pollutant treatment and control 

21 regulations, and reviewing projects or other undertakings with the potential to affect basin water 

22 resources for conformance with the DRBC Comprehensive Plan (DRBC 2001). DRBC has also 

23 promulgated water quality standards for the basin under 18 CFR 410. The DRBC acts in 

24 cooperation with the States and other parties that are signatories to the DRBC Compact 

25 (DRBC 1961) and who retain their authority to set more stringent standards necessary to protect 

26 the water resources of the basin. Article 3.8 of the DRBC Compact (DRBC 1961) requires that 

27 the DRBC approve a project whenever it finds and determines that the project would not 

28 substantially impair or conflict with the Comprehensive Plan. DRBC’s Comprehensive Plan 

29 already accounts for existing LGS operations (DRBC 2001). 

30 The Commonwealth of Pennsylvania has established surface water quality standards for 

31 individual rivers, streams, and unnamed tributaries, including wetlands, along with associated 

32 numeric water quality criteria to protect the desired and designated uses of the water bodies. 

33 Relative to the LGS site, PADEP has specifically designated the main stem of the Schuylkill 

34 River traversing Montgomery County to its mouth with the Delaware River for use in the 

35 maintenance and propagation of warm water fishes (WWF) and the passage, maintenance, and 

36 propagation of migratory fishes (MF). The main stem of Perkiomen Creek is also designated as 

37 WWF and MF. East Branch Perkiomen Creek is designed for use in the maintenance of 

38 stocked trout from February 15 to July 31 of each year, in addition to WWF and MF during the 

39 rest of the year. It should be noted that all surface waters in Pennsylvania are protected for 

40 water supply (public, industrial, and wildlife use) and for recreational uses (25 Pa. Code 93). 

41 Ambient water quality data Exelon compiled (Exelon 2011b) to support its 2010 NPDES permit 

42 renewal application and as part of the DRBC monitored demonstration study (Exelon 2012d) 

43 were reviewed by NRC staff during the course of the LGS license renewal environmental 

44 review. Comparison of the available data with the water quality criteria established by the DEP 

45 under 25 Pa. Code 93.7 and 93.9 for the designated uses of the Schuylkill River and tributaries 

46 indicate that existing water quality is supportive of designated uses. Section 2.2.6 discusses 

47 key trends in ambient water quality and its influence on aquatic biota. 
Purpose and Need for Action

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1 Section 303(d) of the Federal Clean Water Act (CWA) requires the Commonwealth of 

2 Pennsylvania and other states to identify all waters for which effluent limitations and pollution 

3 control activities are not sufficient to attain water quality standards in such waters. The 303(d) 

4 list includes those water quality limited segments that require the development of total maximum 

5 daily loads (TMDLs) to assure future compliance with water quality standards. While the 

6 Schuylkill River is listed as supporting its designated aquatic life uses, Pennsylvania’s draft 

7 2012 Clean Water Act Section 303(d) list of impaired waters continues to list the main stem of 

8 the Schuylkill River in the plant vicinity as impaired because of polychlorinated biphenyl (PCB) 

9 contamination from unidentified upstream sources (DEP 2011, Exelon 2011b). 

10 Industrial wastewater, cooling water, and stormwater discharges from LGS are governed by a 

11 Pennsylvania DEP-issued NPDES permit (No. PA0051926) and regulated under PADEP’s 

12 regulations at 25 Pa. Code 92a. Exelon’s current permit sets effluent quality limits and 

13 monitoring requirements for the plant’s discharges covering some 24 outfall locations. These 

14 include 17 outfalls discharging stormwater either to the Schuylkill River or Possum Hollow Run, 

15 with one outfall discharging stormwater runoff north to the headwaters of Sanatoga Creek. 

16 Six outfalls discharge industrial wastewater (mainly noncontact cooling water) or comingled 

17 noncontact cooling water with stormwater. Most notably, cooling tower blowdown, closed-cycle 

18 cooling water, spray pond water, stormwater via the plant’s holding pond, and other plant 

19 wastewaters (e.g., liquid radwaste treatment system and laundry drain wastes) are discharged 

20 through the plant’s primary outfall (no. 001) to the Schuylkill River (Exelon 2010d, 2011b). In 

21 particular, the treated liquid radwaste is batch discharged to the cooling tower blowdown line 

22 where it is diluted by the normal blowdown flow. This ensures that radionuclides discharged 

23 through outfall 001 comply with 10 CFR 20 limits (Exelon 2011b). 

24 The cooling tower blowdown line is also equipped with an overflow vent, which is monitored as 

25 a separate NPDES outfall (no. 023) (Exelon 2010d, 2011b). The vent, which NRC staff 

26 observed during the November 2011 environmental site audit (NRC 2012), is located south of 

27 the power block and just downslope from the plant’s holding pond. 

28 LGS’s current NPDES permit for plant operations was issued by PADEP with an effective date 

29 of April 1, 2006; the permit expired on March 31, 2011 (Exelon 2011b, 2012b). However, 

30 Exelon submitted a permit renewal application to PADEP on September 28, 2010, which the 

31 PADEP accepted as administratively complete on December 15, 2010 (PADEP 2010; 

32 Exelon 2010d, 2012a). As a result, LGS’s NPDES permit for LGS operations remains in effect 

33 (i.e., administratively continued) because Exelon submitted an application for renewal at least 

34 180 days before the expiration of the current permit in accordance with 25 Pa. Code 92a.7. 

35 Exelon has a separate PADEP-issued NPDES permit (No. PA0052221) for the discharge of 

36 diversion water from the Bradshaw Reservoir to East Branch Perkiomen Creek. The permit was 

37 issued with an effective date of July 1, 2009, and expires June 30, 2014. 

38 Continued NPDES permit coverage is an indication that Exelon’s discharges from LGS and 

39 other facilities meet applicable water quality standards, while satisfying state Water Quality 

40 Certification requirements under Section 401 of the Federal Clean Water Act. This is because, 

41 in Pennsylvania, the 401 Water Quality Certification process is integrated with other 

42 PADEP-issued permits and approvals, including those under the NPDES permit program. 

43 The NRC staff’s review of the last 3 years of NPDES Discharge Monitoring Reports (DMRs) 

44 submitted by Exelon to the PADEP revealed no unusual conditions or exceedances of effluent 

45 limitations. Further, the staff determined that Exelon has not received any Notices of Violation, 

46 nonconformance notifications, or related infractions associated with the site’s NPDES permits or 

47 related to other water quality matters within the past 5 years (Exelon 2012a). 
Purpose and Need for Action

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1 2.2.5. Groundwater Resources

2 2.2.5.1. Site Description and Hydrogeology

3 Groundwater beneath LGS and vicinity occurs in the thick bedrock of the Brunswick and 

4 Lockatong Formations, as described in Section 2.2.3. 

5 The USGS has grouped the water-bearing portions (i.e., aquifers) of these formations into the 

6 Aquifers in the Early Mesozoic Basins system (Trapp and Horn 1997). The Brunswick bedrock 

7 aquifer is the most widespread source of groundwater in the plant region and across the 

8 Triassic lowlands of the Newark Basin (Exelon 2008a). In general, aquifer zones occur in 

9 association with secondary fractures, joints, and bedding planes in the rock where groundwater 

10 is stored and may move along (Exelon 2008a, 2011b; Trapp and Horn 1997). In strata where 

11 approximately vertical sets of joints are tightly spaced and have some degree of 

12 interconnection, aquifer permeability is increased and groundwater flow and yield to wells are 

13 greatly enhanced. However, these localized zones of enhanced aquifer permeability vary 

14 vertically and laterally through the rock, especially as the basin strata dips to the north and 

15 northwest at 10 to 20 degrees on a regional basis and strikes approximately east to west 

16 (Exelon 2008a). Consequently, individual bedrock aquifer zones also dip downward and may 

17 run in the downdip direction for only a few hundred feet but can be continuous in extent for 

18 thousands of feet along (parallel to) the bedrock strike (Trapp and Horn 1997). As such, 

19 groundwater yield to individual wells can vary greatly over relatively short distances 

20 (Exelon 2008a, Trapp and Horn 1997). Because of decreasing fracture density with depth, 

21 groundwater movement primarily occurs in the upper 600 ft (180 m) of the Brunswick system 

22 (Exelon 2008b). In fact, within the Newark Basin in Pennsylvania, yields are highest from wells 

23 with completion depths ranging from 200 to 500 ft (60 to 150 m). Groundwater yields from 

24 large-diameter wells within the basin typically range from about 12 gpm (45 L/min) in shale and 

25 argillite up to 80 gpm (300 L/min) in massive sandstones (Trapp and Horn 1997). 

26 Recharge to the bedrock aquifer occurs from precipitation that falls over the higher elevations of 

27 the region’s groundwater basins, and which is able to infiltrate through the overlying soils and 

28 regolith (Exelon 2008a, 2011b). While overlying surficial materials (i.e., soils, regolith, and 

29 stream alluvium), where present in the region, are not typically thick enough to be a sustained 

30 source of groundwater to wells by themselves, thick deposits do help to increase the availability 

31 of water to wells withdrawing from the underlying bedrock (Trapp and Horn 1997). 

32 Nevertheless, the majority of the precipitation and runoff occurring in recharge areas moves 

33 laterally downgradient through the regolith and discharges to streams or low-lying areas rather 

34 than recharging groundwater (Trapp and Horn 1997). The regolith across the LGS site is 

35 relatively thin at no more than 12 ft (3.7 m) in thickness, and well measurements indicate that 

36 the materials are not water-bearing (Exelon 2011b). 

37 Beneath LGS, groundwater occurs under water table (unconfined) conditions but can occur 

38 under confined (artesian) conditions at depth. From static water levels recorded in the plant’s 

39 primary production wells, the depth to the water table surface beneath the plant ranges from 

40 20 to 30 ft (6 to 9 m) below ground surface. The water table approximates the surface 

41 topography, with groundwater generally flowing to the south and southwest beneath the site and 

42 discharging to Possum Hollow Run and the Schuylkill River. The groundwater flow rate through 

43 the Brunswick bedrock is estimated to be on the order of 0.07 ft (0.02 m) per day or about 26 ft 

44 (7.9 m) per year, based on the results of the site’s 2006 hydrogeologic investigation, as further 

45 described in Section 2.2.5.2. Locally on the plant site, a groundwater high point and 

46 groundwater flow divide (striking northeast to southwest) is evident just northeast of the cooling 

47 towers adjacent to the spray pond (Exelon 2008a, 2011a). Water table mapping does not 
Purpose and Need for Action

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1 indicate any groundwater mounding beneath the spray pond, an observation that would be 

2 expected if significant seepage were occurring from the pond. 

3 LGS’s four groundwater production wells are completed in the Brunswick aquifer system. 

4 These wells range in depth from 198 ft (60 m) to 585 ft (178 m), as further described in 

5 Section 2.1.7. They are located within a groundwater protected area (Schuylkill-Sprogels Run 

6 Subbasin) designated by the DRBC, and site groundwater withdrawals are otherwise subject to 

7 Pennsylvania reporting requirements as also described in Section 2.1.7. As for other 

8 groundwater users in the vicinity of LGS, a search of Pennsylvania water well records revealed 

9 54 wells within a 1-mile (1.6-km) radius from the center of the LGS site. This number includes 

10 eight wells attributed to the LGS property, although only four remain in service. Other than the 

11 LGS wells, only 3 of the 54 wells reportedly are used for other than domestic (i.e., residential) 

12 purposes. Most of the recorded residential wells range in depth from 120 to 200 ft (37 to 61 m). 

13 For the other nondomestic wells, they include one public water supply well at a mobile home 

14 park located northeast of the plant; the well depth is not recorded. One other nondomestic 

15 (commercial/industrial) supply well is located at the Pottstown Trap Rock-Sanatoga Quarry 

16 located just to the north of the LGS property boundary. This well is recorded as 100 ft (30 m) 

17 deep. The remaining well supplies a local bed and breakfast business located southeast of 

18 LGS; the well is recorded as 96 ft (29 m) in depth (Exelon 2011b, DCNR 2012). 

19 2.2.5.2. Groundwater Quality 

20 Regional groundwater is characteristically of the calcium bicarbonate type and is generally 

21 suitable for a wide range of purposes (Exelon 2008a, Trapp and Horn 1997). However, the 

22 natural quality of groundwater from the region’s bedrock aquifers is typically hard with TDS 

23 concentrations averaging 230 mg/L and hardness (measured as calcium carbonate) of 

24 160 mg/L (Trapp and Horn 1997). Groundwater from the Brunswick aquifer system can 

25 naturally have a TDS in excess of 500 mg/L, which exceeds the EPA secondary drinking water 

26 standard (DWS) primarily established for aesthetic (taste) purposes (40 CFR 143). Data 

27 collected from the plant’s production wells to establish background water quality indicated 

28 moderately hard water ranging from 134 to 618 mg/L with TDS concentrations from 199 to 

29 1,052 mg/L (Exelon 2008a). As noted in Section 2.1.7, groundwater used at LGS is treated, as 

30 necessary, including that withdrawn to meet the potable needs of LGS site personnel.

31 Exelon initiated a program at LGS in 2006 to characterize the hydrogeologic environment of the 

32 plant site and to specifically assess the potential impacts on groundwater quality of any 

33 inadvertent releases of tritium or other LGS-related radionuclides. The assessment conducted 

34 at LGS was part of a fleet-wide effort by Exelon to assess conditions at all of its nuclear plants 

35 and which was undertaken consistent with its participation in the Nuclear Energy Institute’s 

36 Groundwater Protection Initiative (NEI 2007). These efforts provided the framework for the 

37 plant’s ongoing Radiological Groundwater Protection Program (RGPP) (CRA 2006, 

38 Exelon 2011a). The RGPP incorporates knowledge gained from the LGS pre-operational 

39 Radiological Environmental Monitoring Program (REMP) assessment conducted between 1982 

40 and 1984 (CRA 2006). 

41 The 2006 hydrogeologic investigation and its associated report (CRA 2006) considered 

42 historical releases from LGS facilities to include the structures, systems, and components 

43 (SSCs) and areas that may have the potential to contribute to releases. Consequently, a 

44 groundwater monitoring well network was designed, sited, and installed as part of the study to 

45 include wells located at appropriate upgradient and downgradient locations (i.e., relative to 

46 groundwater flow) so as to assess the potential for radionuclides to migrate off site. The 

47 monitoring network established as part of the investigation initially included use of seven 

48 (i.e., nos. P3, P11, P12, P14, P16, P17, and SP22) of the 22 wells that were installed on site 
Purpose and Need for Action

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1 before and during LGS construction plus eight new wells (wells MW-LR-1 through MW-LR-8). 

2 The wells have total depths in the Brunswick Formation ranging from 34 to 115 ft (10 to 35 m) 

3 below ground surface. Aside from groundwater, surface water samples also were collected and 

4 analyzed for tritium and other radionuclides (CRA 2006, Exelon 2011b). 

5 From the initial 2006 sampling, no strontium-90 or gamma-emitting radionuclides were detected 

6 in groundwater or surface water above analytical detection limits. Tritium was detected in 5 of 

7 16 wells sampled (i.e., in well nos. MW-LR-4, MW-LR-5, MW-LR-8, MW-LR-9, and P12). 

8 Observed tritium concentrations ranged from 222±118 pCi/L to 4,360±494 pCi/L, all below the 

9 EPA primary DWS of 20,000 pCi/L (40 CFR 141). From three of the five wells with detectable 

10 tritium (MW-LR-4, MW-LR-5, MW-LR-8), levels ranged from 222±121 pCi/L to 305±121 pCi/L, 

11 which are within the range of background levels (established as 200 pCi/L) documented for the 

12 site and vicinity. The highest tritium level measured, at 4,360±494 pCi/L, was from monitoring 

13 well P12 located almost immediately south and within 100 ft (30.5 m) of the LGS power block 

14 perimeter. A subsequent sample yielded a comparable result. At the same time, a sample from 

15 the power block foundation sump had tritium at 2,020±154 pCi/L. Nevertheless, it was affirmed 

16 during the site investigation that well P12 was completed in a discrete zone normally located 

17 above the water table and thus not representative of overall site groundwater flow conditions 

18 (CRA 2006). This also had been noted before the start of plant operations, as documented in 

19 the UFSAR (Exelon 2008a). As a result, well MW-LR-9 was installed nearby to a depth of 100 ft 

20 (30.5 m) below ground surface to take the place of well P12. The new well was sampled in 

21 August 2006 and yielded a tritium concentration of 1,500±210 pCi/L (CRA 2006). 

22 Tritium was also detected in one surface water sample collected from the plant’s holding pond. 

23 The holding pond is located approximately 500 ft (152 m) due south and downgradient from 

24 wells P12 and MW-LR-9. Tritium was measured at 523±137 pCi/L. This concrete-lined 

25 structure receives nonradioactive wastewater, roof, and plant yard runoff from power block 

26 buildings, and collected drainage from the power block sump (CRA 2006). It is also an internal 

27 monitoring point (outfall 201) under the site’s NPDES permit, as discussed in Section 2.2.4.1 

28 (Exelon 2010d, 2011b).

29 The 2006 hydrogeologic investigation identified two possible sources of tritium to account for the 

30 levels in the referenced monitoring wells: (1) releases that occurred in December 2004 and

31 February 2005 from the Unit 1 Condensate Storage Tank dike because of heating steam valves 

32 leaking condensation and (2) the release of tritiated steam condensation to the ground from an 

33 auxiliary heating steam pipe in October 2002. The releases could have migrated directly 

34 downgradient and through bedrock fractures toward the wells or were collected by the power 

35 block drain system and into the sump, which then migrated through the bedrock fractures to 

36 groundwater. From observations the staff made during the November 2011 environmental site 

37 audit (NRC 2012) and the data reviewed, the conclusions presented in the 2006 hydrogeologic 

38 report are reasonable. 

39 Under the ongoing RGPP at LGS, groundwater and surface water samples are collected and 

40 analyzed for tritium and other radionuclides at least semi-annually. The results are reported as 

41 a component of the annual Radiological Environmental Operation (REOP) reports 

42 (Exelon 2008a, 2009, 2010c, 2011b, 2012c) submitted to the NRC. Exelon continues to adhere 

43 to a detection limit of 200 pCi/L for tritium, which is lower than the detection threshold 

44 (2,000 pCi/L) recommended by industry guidance (NEI 2007) and the site ODCM. This enables 

45 early detection and response to any releases (Exelon 2011b). As documented in the annual 

46 REOPs referenced above, a number of releases of tritiated water from plant SSCs have been 

47 documented and for which investigative and corrective action was taken, as necessary. 

48 Between 2007 and 2011, the highest tritium level observed was 1,750 pCi/L in well MW-LR-9 in 

49 2009 and was attributed to a release of condensate from the outside of the Unit 1 and 2 
Purpose and Need for Action

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1 condenser bays in February 2009. Tritium in MW-LR-9 had decreased to a maximum of 

2 1,154 pCi/L by April 2011 (Exelon 2012c). Overall, the RGPP results reveal that there is no 

3 migration of tritium in groundwater at LGS at concentrations exceeding 2,000 pCi/L, and 

4 observed tritium levels have been well within the EPA primary DWS at all onsite monitoring 

5 wells. 

6 2.2.6. Aquatic Resources

7 Potentially affected waterbodies primarily occur within the Piedmont physiographic province 

8 portion of the Delaware River Basin, including the Schuylkill River, Perkiomen Creek, East 

9 Branch Perkiomen Creek, and the Delaware River near the Point Pleasant Pump Station 

10 (Figure 2–9). LGS relies on consumptive and nonconsumptive water primarily from the 

11 Schuylkill River, as described in Section 2.1.6. When temperature and flow conditions in the 

12 Schuylkill River do not meet DRBC criteria for water use, LGS secondarily relies on water from 

13 Perkiomen Creek. Withdrawing water from Perkiomen Creek often requires augmentation of 

14 flow by transferring water from the Delaware River. A series of pumping stations delivers 

15 Delaware River water from the Point Pleasant Pump Station by pipeline to the Bradshaw 

16 Reservoir, which is then delivered by pipeline to the East Branch Perkiomen Creek. Water 

17 ultimately flows from the East Branch Perkiomen Creek to the Perkiomen Creek. The rate of 

18 flow into the East Branch Perkiomen Creek equals the LGS consumptive water demand plus an 

19 additional 3 percent to account for evaporative losses (Exelon 2011b). Because of the complex 

20 water diversion system, descriptions of the biological communities for each water body appear 

21 as separate resources.

22 2.2.6.1. Description of the Aquatic Resources Associated With Limerick Generating Station 

23 Schuylkill River

24 The Schuylkill River flows 209.2 km (130 miles) from headwaters at Tuscarora Springs, 

25 Pennsylvania, to the confluence of the Delaware River in Philadelphia, Pennsylvania. LGS is 

26 located on the Schuylkill River, 6.4 river km (4 river miles) downriver of Pottstown, 

27 Pennsylvania, and 56.3 river km (35 river miles) upriver of Philadelphia, Pennsylvania. 

28 The Schuylkill River historically contained abundant aquatic resources, including large 

29 populations of mussels and anadromous fish. Around the turn of the 18th century, coal mining 

30 became a predominant industry near the headwaters of the Schuylkill River. Mining waste 

31 effluents degraded downstream water quality and reduced optimal habitat for aquatic life 

32 (Rhoads and Block 2008). For example, the flow of acidic waters from mines, known as acid 

33 mine drainage, lowered pH values and increased dissolution of heavy metals in the river. 

34 Aquatic biota often cannot survive in waters with low pH values and increased concentrations of 

35 heavy metals (Sadak 2008). Water quality throughout the Schuylkill River basin continues to be 

36 influenced by mining activities from the last several decades (Interlandi and Crockett 2003). 

37 The Schuylkill River once supported large numbers of anadromous fishes such as the American 

38 shad (Alosa sapidissima), alewife (A. pseudoharengus), and river herring (or blueback herring, 

39 A. aestivalis), which spawn in freshwater and inhabit marine waters as adults. Anadromous fish 

40 would migrate from the Atlantic Ocean to the Delaware and Schuylkill Rivers to spawn. 

41 However, construction of the Fairmont Dam, built in 1820, and eight subsequent dams built in 

42 the 1800s, cut off access to upriver spawning locations for anadromous fish. Starting in the 

43 1970s, fish passage systems, such as vertical fish slots and the removal of dams along the 

44 Schuylkill River, have helped to reestablish migration upriver. For example, Pennsylvania Fish 

45 and Boating Commission (PFBC) conducted fish ladder passage counts in 2004 and 2005 and 

46 observed a total of 91 and 41 American shad migrating upriver, respectively (PFBC 2012b). In 

47 addition, the PFBC has been stocking American shad fry in the Schuylkill River for the past 
Purpose and Need for Action

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1 13 years in an effort to restore the legacy fishery (PFBC 2012a, NMFS 2012c). PFBC collected 

2 migrating shad between 2003 and 2007 in the Schuylkill River and observed that 95 percent 

3 were of hatchery origin. PFBC plans to continue to stock American shad fry annually until 

4 monitoring results indicate a self-sustaining fishery with spring runs averaging 300,000 to 

5 850,000 returning adults (PFBC 2012b). 

6 Biological Communities in the Schuylkill River

7 The aquatic ecology of eastern U.S. streams and rivers is made up of producers and consumers 

8 that transfer energy through food web interactions. The base of the food web is primary 

9 producers, which convert light energy into organic matter. Common primary producers in the 

10 Schuylkill River include diatoms (a common phytoplankton), filamentous green alga such as 

11 Cladophora, and Myriophyllum, a fresh water flowering plant (NRC 1984). Detritus, nonliving 

12 organic matter such as leaves, is also an important base of the foodweb. Primary producers are 

13 consumed by zooplankton (small animals that float, drift, or weakly swim in the water column of 

14 any body of water), icthyoplankton (fish eggs and larvae), and herbivorous fish and 

15 invertebrates (e.g., aquatic insects, worms, and snails). Predatory invertebrates and fish, such 

16 as sunfish (Lepomis spp.) and brown bullhead (Ictalurus nebulosus), in turn consume 

17 zooplankton (including ichthyoplankton) and herbivorous fish and invertebrates.

18 Prior to LGS operations, LGS-related aquatic surveys conducted in the Schuylkill River near the 

19 LGS site provided baseline information for aquatic plant, benthic invertebrate, and fish 

20 assemblages. Surveys included sampling for phytoplankton (microscopic floating 

21 photosynthetic organisms), macrophytes (aquatic plants), macroinvertebrates, ichthyoplankton 

22 (fish eggs and larvae), and fish, from 1970 through 1984 (PECO 1984; RMC 1984, 1985, 1989). 

23 Subsequent sampling after LGS began operations included sampling for macroinvertebrates, 

24 ichthyoplankton, and fish from 1985 through 2009 (RMC 1986, 1987, 1988, 1989; Exelon 2001, 

25 2002, 2003, 2004, 2005; NAI 2010a). 

26 Periphyton, Phytoplankton, and Macrophytes. To support the operating license for LGS, 

27 PECO (1984) surveyed the seasonal abundances of periphyton (sessile algae and crustaceans 

28 that grow attached to hard surfaces) and phytoplankton (microscopic plants) from 1973 through 

29 1974 and macrophytes (plants that can be observed with the naked eye) from 1974 through 

30 1977. PECO (1984) observed peak productivity during summer and fall when light and 

31 temperature requirements are optimal for plant growth in shallow, lotic systems. Commonly 

32 collected periphyton and phytoplankton included diatoms (Navicula, Diatoma, and 

33 Gomphonema) and blue green algae. PECO (1984) observed 10 species of macrophytes. No 

34 additional LGS-related studies were conducted to examine plankton and periphyton 

35 communities since 1977. 

36 Macroinvertebrates. For macroinvertebrate surveys, RMC-Environmental Services (RMC) 

37 placed buried cylinder samplers in sediments upstream and downstream of LGS and collected 

38 the colonized samplers after several months of deployment (RMC 1984, 1985, 1986). 

39 Oligochaetes, true flies (Diptera) and the snail, Goniobasis viginica dominated downriver 

40 macroinvertebrate communities. In 1984, RMC characterized the macroinvertebrate community 

41 as typical of other U.S. temperate rivers (RMC 1984). 

42 From 1985 through 1988, RMC surveyed macroinvertebrates using the same sampling methods 

43 as described above for pre-operational surveys. Oligochaetes, snails, beetles (Coleoptera) and 

44 flies (Dipteria and Trichoptera) dominated the macroinvertebrate surveys both upstream and 

45 downstream of the Schuylkill River intake and discharge structures. RMC (1988) did not 

46 observe a substantial variation in the macroinvertebrate community when comparing 

47 pre-operational samples to post-operational samples at the same sampling sites (RMC 1988). 

48 Similarly, RMC (1988) did not observe a significant change in the benthic macroinvertebrates 
Purpose and Need for Action

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1 community when comparing the 3 years of data after LGS operations began. During this time 

2 period, LGS solely relied upon the Schuylkill River water for makeup water and did not use 

3 Perkiomen Creek (RMC 1988). 

4 In 2009, NAI (2010a) surveyed the macroinvertebrate community in the Schuylkill River using 

5 kicknets. Although NAI used different sampling methods than RMC in the 1980s, approximately 

6 95 percent of the taxa collected in the 1980s were also collected in 2009. Both studies found 

7 midges (Diptera and Trichoptera) and snails to be among most the abundant taxa. 

8 Fish. RMC (1984) used drift and push nets to survey fish eggs and larvae; seines to survey fish 

9 fry, juveniles, and small fish; and electrofishing to survey larger fish in the Schuylkill River. 

10 Sunfish, goldfish (Carassius auratus), and unidentified minnows dominated egg and larval fish 

11 samples, which were highest in May, June, and July (PECO 1984). Spot-fin shiner (Notropis 

12 spilopterus), swallowtail shiner (Notropis procne), and redbreast sunfish (Lepomis auritus) 

13 dominated seine samples. During electrofishing surveys, RMC (1984) captured redbreast 

14 sunfish, white sucker (Catastomus commersonii), goldfish, brown bullhead, and pumpkinseed 

15 (Lepomis gibbosus) most often. 

16 RMC (1987) conducted the most recent surveys of icthyoplankton, in the Schuylkill River near 

17 LGS in 1986. The species composition and relative abundances of the most common species 

18 were similar to that found in pre-operational surveys. The most common taxa included minnows 

19 and sunfish (RMC 1987). 

20 Several juvenile and adult fish studies have occurred since LGS began operations. From 1985 

21 through 1988, RMC surveyed juvenile and adult fish using the same sampling methods as 

22 described above for pre-operational surveys (RMC 1986, 1987, 1989). RMC collected shiner 

23 species, redbreast sunfish, and goldfish most often during seining and electrofishing surveys 

24 from 1985 through 1988 (RMC 1986, 1987, 1988, 1989). RMC (1988) noted no obvious shifts 

25 in fish population abundances or species diversity in the area of the LGS discharge. 

26 NAI (2010a) compared the fish community from 1987 to 2009. However, the timing and 

27 frequency of sampling efforts varied slightly among studies: NAI (2010a) conducted 

28 electrofishing and seining surveys in September and October whereas RMC sampled monthly 

29 from spring through fall. The most commonly collected species in 2009 were spotfin shiner 

30 (73.8 percent of the total catch), swallowtail shiner (8.1 percent), banded killifish (Fundulus 

31 heteroclitus) (3.7 percent), and tessellated darter (Etheostoma olmstedi) (3.4 percent) 

32 (NAI 2010a). In 1987, spotfin shiner was also the most abundant species, although the relative 

33 abundance (53.9 percent of the total catch) was lower compared to 2009 surveys. NAI 

34 collected all age groups of fish (fry, juveniles, and adults) for most fish families observed, with 

35 the exception of sunfishes, which were primarily fry and juveniles. NAI electroshocking surveys 

36 collected primarily adult and juvenile redbreast sunfish (27.7 percent of the total catch). Other 

37 commonly collected species included white sucker (17.4 percent), rock bass (Ambloplites 

38 rupestris) (17.2 percent), common carp (Cyprinus carpio) (16.9 percent), and smallmouth bass

39 (Micropterus dolomieu) (8.3 percent). In 1987 the most abundant species was rock bass 

40 (19.0 percent), followed by goldfish (17.6 percent), redbreast sunfish (15.7 percent), yellow 

41 bullhead (Ameiurus natalis) (8.8 percent), and pumpkinseed (8.6 percent). Despite the 

42 increased sampling frequency during earlier fish surveys, NAI (2010a) concluded that the 

43 overall species diversity was similar to the earlier fish surveys by RMC in 1987. However, the 

44 relative abundance of certain species changed between 1987 and 2009. For example, common 

45 carp replaced goldfish as one of the more abundant species in 2009 (NAI 2010a). In addition, 

46 goldfish (an introduced species) was not collected in 2009 and a single brown bullhead was 

47 collected in 2009. Both of these species were one of the five most commonly collected species 

48 during 1987 surveys. 
Purpose and Need for Action

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1 The Schuylkill River supports recreational fishing, although there is little public access to the 

2 river near the LGS site. Creel surveys indicate that the most common recreational species 

3 include sunfishes and smallmouth bass (NRC 1984; RMC 1984; 1985; 1986). 

4 Schuylkill River Flow Augmentation

5 In 2003, Exelon started a flow augmentation demonstration project, which pumped water from 

6 the Wadesville mine pool into the Schuylkill River. NAI and URS (2004 and 2011) conducted 

7 monitoring studies to determine the potential effects of the flow augmentation demonstration 

8 project on aquatic biota. Monitoring studies during the first year of the project indicated that the 

9 flow augmentation had no effect on water quality parameters such as total dissolved solids and 

10 pH (NAI and URS 2004). Aquatic biota monitoring included an assessment of 

11 macroinvertebrate and fish community composition and abundances before and after initiation 

12 of the demonstration project at upstream and downstream locations of the Norwegian Creek 

13 confluence with the Schuylkill River (NAI and URS 2004). NAI and URS sampled 

14 macroinvertebrates using kick nets and fish using electroshocking. Prior to the initiation of the 

15 demonstration project, predominant fish species included blacknose dace (Rhinichthys 

16 atratulus), creek chub (Semotilus atromaculatus), white sucker and green sunfish (Lepomis 

17 cyanellus), while macroinvertebrate sampling revealed limited species diversity with decapods, 

18 oligochaetes, and Trichoptera comprising the majority of samples. Fish abundances and 

19 community composition remained similar following commencement of the demonstration 

20 project. However, macroinvertebrate diversity and abundance increased below the confluence 

21 of Norwegian Creek and the Schuylkill River (NAI and URS 2004). Exelon and the DRBC have 

22 extended the initial demonstration project on a year-to-year basis. The most recent assessment 

23 compared water quality and aquatic biotic from 2003 to 2011. NAI and URS (2011) reported no 

24 significant changes to water quality or aquatic biota species diversity or abundances within the 

25 Schuylkill River due to use of the Wadesville Mine Pool water using sampling methods 

26 described for the initial study conducted in 2003. As described in Section 2.1.6, Exelon plans to 

27 continue to rely more on use of Schuylkill River water for consumptive water use rather than 

28 Perkiomen Creek in the future (Exelon 2012b).

29 Perkiomen Creek

30 As described in Section 2.1.6, LGS withdraws water from Perkiomen Creek, rather than the 

31 Schuylkill River, if the flow and temperature conditions in the Schuylkill River do not meet DRBC 

32 criteria for water use. Maintenance of minimal flow in Perkiomen Creek to meet the DRBC 

33 criteria often requires diversion of Delaware River water via East Branch Perkiomen Creek as 

34 discussed in Section 2.1.6.

35 The Perkiomen Creek enters the middle reach of the Schuylkill River at RM 32.3 which is 

36 25.7 stream km (16 stream miles) downstream of LGS (Exelon 2011b). Perkiomen Creek 

37 supports a warm water fishery with migratory fishes (Rhoads and Block 2008). The watershed 

38 includes predominantly agricultural and increasingly more residential land uses. Few large 

39 industrial facilities operate within the watershed, although some municipal wastewater treatment 

40 plants discharge to Perkiomen Creek (PECO 1984, PADEP 2003). The Perkiomen Railroad 

41 historically ran along a portion of Perkiomen Creek. The rail bed today is now part of the 

42 Perkiomen Trail used for recreation (Rhoads and Block 2007). The PFBC, in partnership with 

43 American Rivers, is currently proposing to restore habitat in the creek for diadromous fish, 

44 including American eels, alewife, and blueback herring (NMFS 2012c). 

45 Biological Communities in Perkiomen Creek

46 Pre-operational biotic sampling of Perkiomen Creek began in 1970 and included surveys of 

47 macroinvertebrates and fish in the 1970s and early 1980s, ichthyoplankton from 1973 through 
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1 1975, and phytoplankton in 1974 (PECO 1984; RMC 1984, 1985, 1989). Post-operational biotic 

2 sampling included surveys of macroinvertebrates from 1996 through 2007 (Stroud 2011) and 

3 fish from 1985 to 1987 (RMC 1986, 1987, 1988).

4 Periphyton and Phytoplankton. Surveys from 1973 through 1974 indicated that diatoms 

5 dominated periphyton and phytoplankton communities (PECO 1984). The most common 

6 diatom was Navicula, which is a benthic diatom that occurs throughout the year in Perkiomen 

7 Creek. No additional LGS-related studies were conducted to examine plankton and periphyton 

8 communities since 1974. 

9 Macroinvertebrates. Pre-operational benthic macroinvertebrate surveys indicated that a 

10 diverse and productive macrobenthos occurs within Perkiomen Creek (NRC 1984). Caddisflies, 

11 black flies, and Chironomidae (midges) dominated the collected species. PECO (1984) 

12 collected the greatest overall biomass during the fall. 

13 Stroud Water Research Center (Stroud) conducted a diversity assessment of 

14 macroinvertebrates between 1996 and 2007 using hand-picked collection off rocks and Hess 

15 samplers (Stroud 2011). The goal of the study was to use macroinvertebrate diversity as an 

16 indicator of water and habitat quality. Stroud evaluated the diversity at different areas of 

17 Perkiomen Creek by calculating the macroinvertebrate aggregated index for streams (MAIS)

18 score. The MAIS score incorporates 10 indices, such as the number of sensitive taxa and 

19 diversity of certain taxa, to come up with a score of 0 through 20. Sites with an MAIS score of 

20 0 to 6 are considered “Poor,” 6.1 to 13 “Fair,” and 13.1 to 20 “Good.” Stroud (2011) ranked the 

21 lower Perkiomen Creek as fair and assigned the site an MAIS value of 9.5 (Stroud 2011). The 

22 most abundant taxa included Chironomidae (midges), Elmidae (riffle beetles), and Oligochaetes 

23 (aquatic earthworms; Stroud 2011). Midges also dominated samples collected during 

24 pre-operational studies (PECO 1984). 

25 Fish. Pre-operational studies employed seines and electrofishing to survey juvenile and adult 

26 fish (PECO 1984). In addition, drift and shoreline traps were used to survey fish larvae 

27 (PECO 1984). Fish sampling efforts between 1970 and 1987 indicated that Perkiomen Creek 

28 supports fish assemblages typical of same-sized southeastern Pennsylvania lotic systems 

29 (PECO 1984; RMC 1984, 1985, 1986, 1987, 1988). Carp and minnows dominated larval fish 

30 collections, while dominant adult and juvenile species included minnows and sunfishes 

31 (PECO 1984). 

32 After operations began at LGS, RMC sampled Perkiomen Creek as part of the annual 

33 nonradiological monitoring program for LGS from 1985 through 1986. Species diversity for 

34 adult fish remained similar to pre-operational studies with redbreast sunfish being the 

35 predominant species (RMC 1986, 1987, and 1988). 

36 LGS-related studies did not include icthyoplankton surveys after operations began or juvenile or 

37 adult surveys following initiation of the Point Pleasant Water Diversion Project in 1988. 

38 However, the current fish community in Perkiomen Creek is likely similar to the current fish 

39 community in the East Branch Perkiomen Creek, which NAI (2010b, 2010c) sampled for fish 

40 from 2001 through 2009, as described below. The two creeks likely have similar fish 

41 communities because the creeks are in the same watershed, the East Branch Perkiomen 

42 Creeks flows into Perkiomen Creek, similar land uses (and related anthropogenic stresses) 

43 surround both creeks, and because both creeks provide similar habitats for fish. Furthermore, 

44 LGS-related studies collected a total of 54 fish species in East Branch Perkiomen Creek and 

45 Perkiomen Creek between 1970 and 2009 (Exelon 2011b). Of the 54 fish species collected, 

46 47 species (87 percent) were collected in both waterbodies (Exelon 2011b). Based on the 

47 historical similarities in fish communities, the hydraulic connection of the two creeks, and similar 
Purpose and Need for Action

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1 habitats, NRC staff expects that the current fish communities would be similar in Perkiomen 

2 Creek and East Branch Perkiomen Creek.

3 Recreational fishing in Perkiomen Creek existed historically for sunfishes, pike fishes, and carp 

4 (NRC 1984). Currently, the PFBC stocks Perkiomen Creek with brown trout (Salmo trutta) and 

5 rainbow trout (Onchorhynchus mykiss) in Montgomery County (PFBC 2011a).

6 East Branch Perkiomen Creek

7 As part of the transfer of water from the Delaware River to the Perkiomen Creek, a series of 

8 pumping stations delivers Delaware River water from the Point Pleasant Pump Station to the 

9 Bradshaw Reservoir by pipeline and then to East Branch Perkiomen Creek by pipeline (see 

10 Section 2.1.6). The water then flows from the East Branch of the Perkiomen Creek to 

11 Perkiomen Creek.

12 The East Branch Perkiomen Creek joins the Perkiomen Creek approximately 18 stream km 

13 (11.2 stream miles) upstream of the Perkiomen Creek and Schuylkill River confluence. The 

14 East Branch Perkiomen Creek is a warm water stream with riffles, runs, and shallow pools 

15 (Exelon 2011b). 

16 Biological Communities in East Branch Perkiomen Creek

17 Aquatic sampling in the East Branch Perkiomen Creek before LGS operations included surveys 

18 of phytoplankton from 1973 through 1974, macroinvertebrates and fish in the 1970s through 

19 1984, and ichthyoplankton from 1973 through 1975 (PECO 1984; RMC 1984, 1985, 1989). 

20 Aquatic sampling after LGS operations began includes surveys of macroinvertebrates and fish 

21 from 1985 through 1986 and 2001 through 2009 (RMC 1986, 1987; Exelon 2011b; NAI 2010b, 

22 2010c).

23 Periphyton and Phytoplankton. Surveys from 1973 through 1974 indicated that diatoms 

24 dominated periphyton and phytoplankton communities (PECO 1984). The most common 

25 diatoms were Navicula, Melosira, Synedra, Nitzschia, and Cocconeis. No additional 

26 LGS-related studies were conducted to examine plankton and periphyton communities 

27 since 1974. 

28 Macroinvertebrates. Aquatic sampling for macroinvertebrates occurred from 1970 through 

29 1987, 1979 through 1986, and 2001 through 2009 (PECO 1984, RMC 1986, 1987; 

30 Exelon 2011b; NAI 2010b, 2010c). Sampling methods followed those previously described 

31 under the studies described for Perkiomen Creek. Pre-operational sampling indicated that a 

32 diverse macroinvertebrate community made up of a variety of aquatic insects, annelids, and 

33 mollusks occurred within the East Branch of Perkiomen Creek (PECO 1984). Subsequent 

34 sampling between 1983 and 1986 showed similar diversity with the earlier studies. In addition, 

35 the biotic communities in the East Branch Perkiomen Creek resembled those found in the 

36 Perkiomen Creek with regard to macroinvertebrates assemblages (Exelon 2011b). After LGS 

37 operations began, RMC (1986 and 1987) reported the most abundant taxa as oligochaetes, 

38 stoneflies, caddisflies, snails, and clams from 1985 through 1986. 

39 After the initiation of the Point Pleasant water diversion project, which transported water from 

40 the Delaware River to East Branch Perkiomen Creek, NAI (2010b, 2010c) sampled 

41 macroinvertebrates between 2001 and 2009 using methods similar to those reported by RMC. 

42 This study was part of an analysis to examine post-operational effects of the Point Pleasant 

43 water diversion effort (Exelon 2011b). NAI (2010b, 2010c) observed similar levels of 

44 macroinvertebrate species diversity as compared to pre-diversion sampling. Midges and 

45 oligochaetes dominated samples both before and after the diversion project. However, after the 
Purpose and Need for Action

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1 diversion project, less variability existed along the stream gradient and pollution-sensitive 

2 species increased in abundance over time (NAI 2010b, 2010c). 

3 Fish. Fish studies from 1970 through 1976 examined fish larvae using drift nets and juvenile 

4 and adult fish using seines and electroshocking (PECO 1984). White sucker, yellow bullhead, 

5 sunfish, and minnows dominated larval fish samples (PECO 1984). Common species collected 

6 in juvenile and adult fish surveys included minnows, sunfish, shiners, banded killifish, suckers, 

7 catfish, and pike (PECO 1984). Species abundances varied by sampling site, suggesting 

8 possible species zonation along the regions sampled. 

9 From 1985 through 1987, dominant species in the seining and electrofishing studies included 

10 shiners, minnows, suckers, and sunfish (RMC 1986, 1987, 1988). NAI (2010b, 2010c) sampled 

11 for fish in East Branch of Perkiomen Creek from 2001 through 2009. Dominant species 

12 included sunfishes and minnows, which is similar to the dominant species captured in previous 

13 studies (NAI 2010b, 2010c). NAI (2010b, 2010c) did not observe approximately one quarter of 

14 the species identified in the 1970s and 1980s surveys. NAI (2010b, 2010c) may not have 

15 observed these species because they are no longer present or because the aquatic biota was 

16 sampled more frequently in the 1970s and 1980s, which would make it more likely that the 

17 surveys captured more species (Exelon 2011b). As with the macroinvertebrate sampling, 

18 NAI (2010b, 2010c) noted that pollution-sensitive fish species increased in abundance and that 

19 less variability existed between sampling locations. 

20 Recreational fishing in East Branch Perkiomen Creek existed historically for catfish, sunfishes, 

21 and pike fishes (NRC 1984). Currently, the PFBC stocks East Branch Perkiomen Creek with 

22 brown trout and rainbow trout in Montgomery County (PFBC 2011a).

23 Delaware River

24 The Delaware River flows 531 km (330 miles) from its origin in southern New York to the 

25 Delaware Bay. Historically, degradation of the Delaware River began as early as the late 1700s 

26 and by 1940, the Delaware River was considered one of the most polluted rivers in the United 

27 States. The Delaware River has high vessel traffic ports along with a large concentration of 

28 industry and oil-refinery plants (Albert 1988). The toxicity and low dissolved oxygen levels of 

29 the estuarine and tidal portions of the Delaware River presented a chemical barrier for fish to 

30 complete migration from the tidal to freshwater portions of the Delaware River. Restoration 

31 efforts started in the 1960s and continue to this day. The DRBC manages water resources and 

32 contaminant levels in the Delaware River (Albert 1988).

33 The Point Pleasant Pump Station, which withdraws water that is transferred to the East Branch 

34 Perkiomen Creek, occurs at RM 157. The Point Pleasant Pump Station is above the salt line, or 

35 the boundary where salt intrudes the river from tidal flows (Exelon 2011b). Riffle, run, and pool 

36 habitat characterize the Delaware River within 2.5 km (1.5 miles) upstream and downstream of 

37 the Point Pleasant Pump Station. 

38 Biological Communities in the Delaware River

39 Aquatic sampling in the Delaware River before LGS operations included surveys for 

40 macrophytes, macroinvertebrates, and fish from 1972 through 1973 and ichthyoplankton from 

41 1979 through 1984 (NRC 1984; PECO 1984; RMC 1984, 1985). Once operations began, RMC 

42 (1986) sampled ichthyoplankton in 1985. 

43 Periphyton and Macrophytes. Similar to the other waterbodies discussed above, diatoms 

44 dominated periphyton samples collected in the early 1970s (Exelon 2011b). Pre-operational 

45 monitoring for macrophytes indicated that water milfoils (Myriophyllum sp.) were common in 

46 back eddies near the Point Pleasant Pump Station (Exelon 2011b). No additional LGS-related 
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1 studies have been conducted near the Point Pleasant Pump Station to examine periphyton and 

2 macrophyte communities since 1973. 

3 Macroinvertebrates. Aquatic sampling for macroinvertebrates occurred from 1972 through 

4 1973 using dip nets, hand removal, and stationary fine mesh nets. Sampling areas included 

5 approximately 2 km (1.2 miles) upstream to 2.4 km (1.5 miles) downstream of Point Pleasant 

6 Pump Station. Samples included aquatic insects, snails, clams, mollusks, and worms 

7 (Exelon 2011b). Dominant taxa within dip net samples included chironomid midges and 

8 amphipods (Exelon 2011b). No additional LGS-related macroinvertebrate studies have been 

9 conducted near the Point Pleasant Pump Station since 1973.

10 DRBC conducted a diversity assessment of macroinvertebrates between 2001 and 2008 

11 throughout the non-tidal portion of the Delaware River (DRBC 2009). DRBC collected 

12 invertebrates annually using kick nets at 25 sites along the river, including two sites within 3 RM 

13 of the Point Pleasant Pump Station. DRBC calculated a multi-metric Index of Biotic Integrity 

14 (IBI) score, which was composed of 6 ecological metrics, including species richness (total 

15 number of species), EPT Richness (total number of species within three insect orders: 

16 Ephemeroptera, Plecoptera, Trichoptera), Shannon-Wiener Diversity (an index of species 

17 diversity based on the relative abundance and total number of species), the Biotic Index (an 

18 index based on the relative abundance species sensitive to environmental stress), Intolerant 

19 Percent Richness (the percent of species intolerant to environmental stress relative to the 

20 overall number of species), and Scraper Richness (degree of overlap and number of select 

21 invertebrate species). The IBI score for the two sites near the Point Pleasant Pump Station was 

22 generally similar to or slightly less than the IBI score of upriver sites within the Delaware 

23 Watergap National Recreation Area and the Upper Delaware Scenic & Recreational River 

24 (DRBC 2009). These results suggest that the area surrounding the Point Pleasant Pump 

25 Station is similar to, or slightly more disturbed, than upriver sites within Federally-designated 

26 areas.

27 Fish. RMC and PECO surveyed ichthyoplankton in the Delaware River from 1972 through 

28 1973 and 1979 through 1985 using drift and push nets (PECO 1984; RMC 1984, 1985, 1986). 

29 RMC sampled ichthyoplankton near the Point Pleasant Pump Station and downriver to RM 138 

30 near Yardley, Pennsylvania (RMC 1984, 1985, 1986). Dominant species within ichthyoplankton 

31 samples included herring (Clupeidae), sunfish, American shad, and common carp eggs and 

32 larvae. 

33 Adult fish studies were conducted from 1972 through 1973 and 1979 through 1980 in the vicinity 

34 of the Point Pleasant Pump Station using seines, fyke nets, and trap nets (Exelon 2011b). The 

35 most common taxa included sunfishes, shiners, and catfishes (Exelon 2011b). The adult fish 

36 studies also observed anadromous species such as the alewife, American shad, and blueback 

37 herring (Exelon 2011b). These species used this region of the Delaware River as a nursery 

38 area (Exelon 2011b). No additional LGS-related studies have been conducted near the Point 

39 Pleasant Pump Station to examine adult fish communities since 1980. 

40 PFBC sampled American shad in the non-tidal portion of the Delaware River at RM 178.9, 

41 which is approximately 20 RM upstream of the Point Pleasant Pump Station (PFBC 2011c). 

42 RFBC conducted the electrofishing surveys during the spring from 1997 through 2001 and 2010 

43 through 2011. The average annual catch per unit effort (CPUE) ranged from approximately 11 

44 to 50 shad per hour (PFBC 2011c). All females collected in 2011 were gravid, indicating that 

45 the females had produced eggs but had not yet spawned or released the eggs into the river. 

46 Recreational and commercial fishing occur in the Delaware River (NYSDEC 2009). Common 

47 recreational species caught in the non-tidal portion of the Delaware River include American 

48 shad, American eel, channel catfish, rainbow trout, smallmouth bass, striped bass (Morone 
Purpose and Need for Action

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1 saxatilis), and walleye (Versar 2003, PFBC 2012d). In 2003, river herring and hickory shad 

2 comprised a small portion of the catches (Versar, 2003). As of October 2012, river herring and 

3 hickory shad fisheries are closed in the Delaware River (PFBC 2012d). 

4 Onsite Water Bodies

5 Two streams, Possum Hollow Run and Brooke Evans Creek, run parallel to each other and flow 

6 through the LGS site. LGS discharges industrial wastewater and stormwater to Possum Hollow 

7 Run under NPDES compliance (Exelon 2012b). Brooke Evans Creek is a freestone stream and 

8 a tributary to the Schuylkill River (PADEP 2006a). The State of Pennsylvania designates both 

9 streams with water use protection for maintenance and propagation of flora and fauna 

10 indigenous to warm water habitat (Pa. Code 93.3).

11 Exelon has not conducted any sampling or monitoring of aquatic biota in Possum Hollow Run 

12 (Exelon 2012b). PADEP (2006a) conducted an evaluation of indigenous aquatic biota as an 

13 indicator of long-term water quality conditions in Brook Evans Creek. PADEP staff collected 

14 benthic macroinvertebrate data and assessed habitat using a modified index of biotic integrity 

15 protocols under PADEP’s antidegradation implementation guidance (PADEP 2006a). PADEP 

16 observed relatively high abundances of macroinvertebrates tolerant of water quality 

17 degradation, indicating that human activity in the basin has influenced the habitat quality and 

18 composition of aquatic biota within Brooke Evans Creek.

19 2.2.6.2. NOAA Trust Resources

20 NOAA trust resources include, but are not limited to, commercial and recreational fishery 

21 resources, anadromous species (fish that spawn in fresh water and then migrate to salt water), 

22 catadromous species (species that spawn in salt water and then migrate to fresh water), and 

23 threatened and endangered species. NOAA trust resources in the Schuylkill River and 

24 Perkiomen Creek include alewife, blueback herring, American shad, striped bass, hickory shad, 

25 bluefish, yellow perch, white perch, bay anchovy, and American eel and their habitat 

26 (NMFS 2012a). Alewife, blueback herring, American shad, striped bass, hickory shad, and 

27 white perch are anadromous species that spawn in fresh water, such as the Delaware River and 

28 its estuary, and then return to the Atlantic Ocean after spawning (PFBC 2012c). American eel is 

29 a catadromous species that spawns in the Atlantic Ocean and returns to the Delaware River 

30 after spawning (PFBC 2012c). Table 2–2 describes the NOAA trust species that have been 

31 observed in LGS-related surveys of the Delaware River, Perkiomen Creek, East Branch of the

32 Perkiomen Creek, and the Schuylkill River. As noted above, dams throughout the Schuylkill 

33 River historically have limited the movement of migrating fish. More recent efforts to remove 

34 dams, the addition of fish ladders, and stocking rivers with fry have helped to increase the 

35 population of anadromous fish (NMFS 2012a). 
Purpose and Need for Action

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1 Table 2–2. NOAA Trust Resources Observed in LGS-related Aquatic Studies

Schuylkill Rivera East Branch 

Perkiomen Creekb Perkiomen Creekc Delaware Riverd

Alewife X X

American eel X X X X

American shad X X

Bay anchovy

Blueback herring

Bluefish

Hickory shad

Striped bass

White perch X X

Yellow perch X X X X

(a) LGS-related surveys occurred from 1970–1976, 1979–2004, and 2009. 

(b) LGS-related surveys occurred from 1970–1976, 1979–1987, and 2001–2009.

(c) LGS-related surveys occurred from 1970–1977 and 1979–1987.

(d) LGS-related surveys occurred from 1972–1973 and 1982–1985 near the Point Pleasant Pumping Station on the 

Delaware River. 

Note: A blank cell indicates that the species was not observed during LGS-related surveys.

Source: Exelon 2011

2 2.2.6.3. Invasive or Introduced Aquatic Species

3 Hydrilla (Hydrilla verticillata) forms dense mats at the surface of waterbodies and reduces light 

4 to aquatic plants residing below. Hydrilla can also impair commercial water use by clogging 

5 pipes and reducing flow rates (Sea Grant Pennsylvania 2012). Hydrilla grows in freshwater 

6 habitats and tolerates a wide range of environmental conditions. Hydrilla occurs in the 

7 Schuylkill River near Philadelphia, Pennsylvania (Exelon 2011b). 

8 The Asiatic clam (Corbicula fluminea) can be problematic for nuclear facilities in terms of 

9 biofouling in the intake and circulating water systems (NRC 1996). NAI indicated that this 

10 invasive organism is present in the Schuylkill River upstream and downstream of LGS 

11 (NAI 2010a, 2010d), in Perkiomen Creek near the Perkiomen Pumphouse (NAI 2010d), East 

12 Branch Perkiomen Creek (NAI 2010b, 2010c), and the Delaware River near the Point Pleasant 

13 Pump Station (RMC 1989). 

14 Zebra mussels (Dreissena polymorpha) actively filter feed large amounts of freshwater and 

15 remove available plankton food sources making less food available for other aquatic organisms 

16 (Sea Grant Pennsylvania 2007). Exelon conducted surveys to determine if any zebra mussels 

17 were present near the LGS intakes in the Schuylkill River and in Perkiomen Creek 

18 (Exelon 2011b). Exelon did not find evidence of zebra mussels in the Schuylkill River or 

19 Perkiomen Creek (NAI 2010d, Exelon 2011b). 
Purpose and Need for Action

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1 2.2.7. Terrestrial Resources

2 LGS Ecoregion

3 The LGS site lies in the Triassic Lowlands portion of the Northern Piedmont ecoregion 

4 (EPA 2010). The Triassic Lowlands contain wide undulating ridges and broad nearly level 

5 valleys with limited local relief. Appalachian oak forest dominated by white oak (Quercus alba) 

6 and red oak (Q. rubra) is the most prevalent forest community. Hickory (Carya spp.) is more 

7 abundant in this region of the Piedmont because of the less acidic soils, while red maple (Acer 

8 rubrum) and black tupelo (Nyssa sylvatica) are present but less abundant than in other portions 

9 of the Northern Piedmont ecoregion (EPA 2010). Streams, wetlands, and a few ponds occur in 

10 the Triassic lowlands. Farms and houses have replaced much of the native vegetation, and 

11 suburban development intensifies nearer to Philadelphia (EPA 2010), which lies about 21 miles 

12 (34 km) southeast of the LGS site. In the immediate vicinity of the LGS site, land uses include 

13 light residential development, agriculture, old fields, and woodlands.

14 The LGS site is included in the Upper Schuylkill Conservation Landscape. The Montgomery 

15 County Planning Commission designated this as one of 13 conservation landscapes in the 

16 county that have high natural biodiversity. The Upper Schuylkill Conservation Landscape totals 

17 2,392 ac (968 ha) and extends from just above Royersford Borough to the Berks County line. 

18 The conservation landscape includes 1,064 ac (431 ha) of forest, about 275 ac (111 ha) of 

19 which qualify as interior forest. Although this area, especially along the Schuylkill River, has 

20 been the site of intensive industrial development, riparian habitat remains along the Schuylkill 

21 River and some of its tributaries, such as Possum Hollow Run and Brook Evans Run, which 

22 enter the Schuylkill River from the LGS site (Rhoads and Block 2008). 

23 The riparian area of the Schuylkill River is included in the river’s designation as a Pennsylvania 

24 Scenic River (PDCNR 2010). The Pennsylvania Department of Conservation and Natural 

25 Resources (PDCNR) manages designated scenic rivers that are free-flowing and capable of 

26 supporting water-based recreation and aquatic life.

27 Pennsylvania State Game Land #234 lies about 2 miles (3.2 km) southeast of the LGS site on 

28 the east side of the Schuylkill River in close proximity to the Limerick to Cromby 230-kV 

29 transmission line corridor (22-60 line) (PGC 2011). Pennsylvania State Game Lands are 

30 managed by the Pennsylvania Game Commission for hunting, trapping, and fishing. 

31 LGS Site

32 Before construction of the LGS plant, the LGS site consisted primarily of immature, nearly 

33 climax oak-hickory forest, and some fruit orchards (AEC 1973). LGS construction disturbed 

34 about 270 ac (110 ha; 42 percent of the current LGS site) (AEC 1973). PECO (which 

35 constructed and first operated LGS) seeded temporarily disturbed areas with perennial grasses 

36 after construction (AEC 1973, NRC 1984). When LGS first began operating in 1984, mixed 

37 deciduous forest occurred along the Schuylkill River, Possum Hollow Run, and in an area 

38 approximately 50 m (164 ft) west of the LGS Unit 1 cooling tower (NRC 1984). Today, riparian 

39 and upland forest, small forested and emergent wetlands, pioneer herbaceous, old fields, 

40 agricultural fields, and developed areas occupy the site (Exelon 2011a, WHC 2006). A 

41 description of each of these habitats appears below. Several linear corridors run through the 

42 LGS site, including utility distribution rights-of-way that are maintained as grass or scrub-shrub 

43 habitat (WHC 2006).

44 Forest habitat on the LGS site includes both lowland riparian and upland communities. Riparian 

45 forest occurs along the banks of the Schuylkill River and smaller tributaries such as Brooke 

46 Evans Creek and Possum Hollow Run. Tree species in these areas include silver maple (Acer 

47 saccharinum), American sycamore (Plantanus occidentalis), American elm (Ulmus americana), 
Purpose and Need for Action

2-48

1 and slippery elm (U. rubra). Riparian forest provides food, cover, and reproductive habitat to 

2 wildlife. For example, during spring, forest depressions may collect water and form ephemeral 

3 pools that amphibians use for breeding and waterfowl and neotropical migrant birds use as 

4 stopover habitat. Riparian forest provides dispersal and seasonal migration corridors. Upland 

5 forest supports common tree species, such as white ash (Fraxinus Americana), tulip poplar 

6 (Liriodendron tulipifera), red maple, chestnut oak (Quercus prinus), American elm, black walnut 

7 (Juglans nigra), slippery elm (Ulmus rubra), flowering dogwood (Cornus florida), bitternut 

8 hickory (Carya cordiformis), American beech (Fagus grandifolia), and red oak. Upland forest 

9 also provides food, cover, and reproductive habitat for wildlife (Exelon 2010a). 

10 Small palustrine forested and emergent wetlands on the LGS site are important habitat for 

11 wildlife, especially amphibians. Red maple and silver maple typically dominate the palustrine 

12 forested wetlands on the LGS site. Common vegetation in palustrine emergent wetlands

13 includes sedges (Carex spp.), microstegium (Eulalia viminea), bedstraws (Galium spp.), 

14 arrow-leaf tearthumb (Polygonum sagittatum), halberd-leaf tearthumb (Polygonum arifolium), 

15 flatsedges (Cyperus spp.), hollow joe-pye-weed (Eupatoriadelphus fistulosus), and swamp 

16 milkweed (Ascelpias incarnata) (Exelon 2010a).

17 Pioneer herbaceous habitat on the LGS site consists of plant communities that colonize areas 

18 following disturbances such as construction, grading, and periodic mowing. This plant 

19 community typically consists of wineberry (Rubus phoenicolasius), mugwort (Artemisia vulgaris), 

20 multiflora rose (Rosa multiflora), lesser celandine (Ranunculus ficaria), orchardgrass (Dactylis 

21 glomerata), foxtails (Alopecurus spp.), white goosefoot (Chenopodium album), spotted lady’s 

22 thumb (Polygonum persicaria), Pennsylvania smartweed (Polygonum pensylvanicum), 

23 cespitose knotweed (Polygonum cespitosum), curly dock (Rumex crispus), wild carrot (Daucus 

24 carota), white amaranth (Amaranthus albus), butter-and-eggs (Linaria vulgaris), red clover

25 (Trifolium pretense), yellow sweetclover (Melilotus officinalis), white sweetclover (Melilotus 

26 alba), and Deptford pink (Dianthus armeria). This habitat is of low value to native wildlife, but it 

27 is beneficial to some species such as white-tailed deer, eastern cottontail (Sylvilagus 

28 floridanus), and meadow vole (Microtus pennsylvanicus) (Exelon 2010a). 

29 Old field habitat on the LGS site consists of abandoned agricultural areas that are either in the 

30 meadow (grasses and forbs) or scrub/shrub state of succession. Old field meadow habitat 

31 supports grasses such as fescue (Festuca spp.), Kentucky bluegrass (Poa pratensis), timothy 

32 (Phleum pretense), and orchardgrass, and forbs such as Canada goldenrod (Solidago 

33 canadensis), daisy fleabane (Erigeron strigosus), evening primrose (Oenothera biennis), dwarf 

34 cinquefoil (Potentilla candensis), wild carrot, teasel (Dipsacus fullonum), red clover, smartweeds 

35 (Polygonum spp.), and shrubs such as brambles (Rubus spp.). Common wildlife species 

36 include white-tailed deer, red fox (Vulpes vulpes), eastern cottontail, raccoon (Procyon lotor), 

37 and Virginia opossum (Didelphis virginiana) (Exelon 2010a). 

38 Agricultural fields on the LGS site contain crops such as corn, wheat, barley, soybeans, and 

39 hay. Agricultural areas also support hedgerows of upland tree species such as black cherry 

40 (Prunus serotina), black walnut (Juglans nigra), Osage orange (Maclura pomifera), white ash 

41 (Fraxinus americana), red cedar (Juniperus virginiana), tulip poplar (Liriodendron tulipfera), 

42 sassafras (Sassafras albidum), and common hackberry (Celtis occidentalis). These areas 

43 provide cover and food for wildlife species such as white-tailed deer that are adapted to edge 

44 habitats (Exelon 2010a). 

45 Buildings, asphalted parking lots, roads, landscaping, and mowed lawns occupy the developed 

46 portions of the LGS site. Mowed lawns consist largely of non-native cool season grasses that 

47 are of minimal value to native wildlife species. Landscaped areas contain mostly non-native 
Purpose and Need for Action

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1 ornamental species, some of which may serve as nesting habitat, cover, and food sources for 

2 some native bird species (Exelon 2010a). 

3 Common mammal species on the LGS site include the white-tailed deer, raccoon, striped skunk 

4 (Mephitis mephitis), red fox, Virginia opossum, eastern cottontail, gray squirrel (Sciurus 

5 carolinensis), groundhog (Marmota monax), and white-footed mouse (Peromyscus leucopus) 

6 (Exelon 2010a, NRC 1984, Kriner and MacDonald 2009).

7 Common bird species on the LGS site include game birds such as Canada goose (Branta 

8 canadensis) and mourning dove (Zenaida macroura); raptors such as red-tailed hawk (Buteo 

9 jamaicensis) and turkey vulture (Cathartes aura); resident songbird species such as northern 

10 cardinal (Cardinalis cardinalis); and neotropical migrant songbirds such as Baltimore oriole 

11 (Icterus galbula), indigo bunting (Passerina cyanea), and red-eyed vireo (Vireo olivaceous). 

12 Other avian species include eastern bluebird (Sialia sialis), American robin (Turdus migratorius), 

13 eastern towhee (Pipilo erythrophthalmus), tufted titmouse (Baeolophus bicolor), downy 

14 woodpecker (Picoides pubescens), blue jay (Cyanocitta cristata), American crow (Corvus 

15 brachyrhynchus), killdeer (Charadrius vociferous), barn swallow (Hirundo rustica), tree swallow 

16 (Tachycineta bicolor), purple martin (Progne subis), and the introduced European starling 

17 (Sturnus vulgaris) (Blye 1973, Exelon 2010a, Kriner and MacDonald 2009). The 

18 U.S. Geological Survey has also regularly recorded all of these species during its annual 

19 Breeding Bird Survey along the Schwensksvill route (Sauer et al. 2011). This route, which runs 

20 near Pottstown (USGS 2001), lies about 3 miles to the northwest of the LGS site.

21 Reptiles that inhabit the riparian habitat bordering the Schuylkill River and its tributaries on the 

22 LGS site include the northern black racer (Coluber constricter), northern ring-necked snake 

23 (Diadophis punctatus punctatus), eastern garter snake (Thamnophis sirtalis), water snake

24 (Nerodia sipedon), spotted turtle (Clemmys guttata), mud turtle (Trachemys scripta), eastern 

25 box turtle (Terrapene carolina carolina), and eastern painted turtle (Chrysemys picta picta). 

26 Amphibians that inhabit the LGS site include the red-backed salamander (Plethodon cinereus), 

27 long-tailed salamander (Eurycea longicauda), northern two-lined salamander (Eurycea 

28 bislineata bislineata), American toad (Bufo americanus), spring peeper (Pseudacris crucifer), 

29 bullfrog (Rana catesbeiana), leopard frog (Rana pipiens), and green frog (Rana clamitans) 

30 (Exelon 2010a, Kriner and MacDonald 2009). The amphibians range from fully aquatic 

31 (e.g., bullfrog) to semi-aquatic (e.g., toad species) and are closely tied to water habitats, 

32 including streams, wetlands, and temporary pools where they reproduce. The frog and toad 

33 species, except the bullfrog, also make extensive use of adjacent terrestrial habitats, such as 

34 forest, grassland, and cropland as juveniles and adults. The turtle species leave the water to 

35 nest (egg deposition) in nearby soft substrates.

36 Exelon joined the Wildlife Habitat Council in 2005, and since that time has formed an 

37 Environmental Stewardship Committee that has developed a Wildlife Management Plan 

38 (Exelon 2010b). The Wildlife Management Plan is a comprehensive strategy that outlines the 

39 goals of the wildlife habitat program for the LGS site and describes projects and milestones to 

40 achieve these goals. As part of the program, Exelon places and monitors artificial avian nesting 

41 structures and bat roost boxes (WHC 2006). In 2007, Exelon installed structures around the 

42 perimeter of the LGS site for eastern blue birds, purple martins, owls, raptors, other perching 

43 birds, and bats. In addition, in 2010, Exelon installed a 300-ft-(90-m)-long barrier between 

44 Possum Hollow Run and an adjacent road and parking area on the east side of the LGS site to 

45 decrease the mortality of amphibians during post-natal dispersal (Exelon 2010b). Exelon staff 

46 continues to develop the wildlife habitat enhancement program and evaluate future projects that 

47 would enhance the quality of the natural environment on the site. In 2010, Exelon received 

48 WHC’s Corporate Wildlife Habitat Certification in recognition of its implementation of the wildlife 

49 habitat enhancement program (Exelon 2011b). 
Purpose and Need for Action

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1 Transmission Line Corridors

2 Section 2.1.5 describes the transmission lines that were built to connect the LGS to the regional 

3 electricity grid and that are within the scope of this SEIS. Section 2.1.5 also describes 

4 vegetation maintenance along the transmission line corridors. The NRC is not aware of any 

5 biological field surveys or studies of these transmission line corridors. Habitat within the 

6 corridors is highly variable and includes suburban, residential, agricultural, forested, 

7 wetland/floodplain, and open water. The lines also traverse several parks and natural heritage 

8 areas, including the Evansburg State Park and Schuylkill River National and State Heritage 

9 Area (Exelon 2011b).

10 The NRC staff did not identify any ecological surveys or studies that provide information on 

11 habitats and species along the transmission line corridors. However, some studies on the 

12 transmission lines in southeastern Pennsylvania provide information on common vegetation and 

13 species along the LGS transmission line corridors. Common tree species in transmission line 

14 corridors in the northern Piedmont ecoregion of Pennsylvania include white ash, red maple, and 

15 sassafras (Bramble et al. 1992, Yahner et al. 2001, Yahner and Yahner 2007). Common shrub 

16 species include multiflora rose, Japanese honeysuckle (Lonicera japonica), blackberry (Rubus 

17 allegheniensis), dewberry (R. hispidus), gray dogwood (Cornus paniculata), black haw 

18 (Viburnum prunifolium), and poison ivy (Toxicodendron radicans) (Bramble et al. 1992, 1997; 

19 Yahner and Yahner 2007). Common forb species include goldenrod (Solidago spp.), strawberry 

20 (Fragaria virginiana), common cinquefoil (Potentilla simplex), goosegrass (Galium aparine), 

21 sow-thistle (Sonchus oleraceus), and mile-a-minute (Polygonum perfoliatum) (Bramble et al. 

22 1992, 1997; Yahner and Yahner 2007). Common grass species include fall panic grass 

23 (Panicum spp.), deertongue grass (Panicum clandestinum), foxtail grass (Setaria glauca), and 

24 broomsedge (Andropogon virginicus) (Bramble et al. 1992, 1997; Yahner and Yahner 2007).

25 Common breeding bird species in transmission line corridors in the northern Piedmont 

26 ecoregion of Pennsylvania include the field sparrow (Spizella pusilla), black-throated blue 

27 warbler (Dendroica caerulescens), gray catbird (Dumetella carolinensis), rufous-sided towhee 

28 (Pipilo erythrophthalmus), common yellowthroat (Geothlypis trichas), American goldfinch 

29 (Carduelis tristis), and indigo bunting (Bramble et al. 1992). Amphibian species include the 

30 Jefferson salamander (Ambystoma jeffersonianum), redbacked salamander (Plethodon 

31 cinereus), spotted salamander (Ambystoma maculatum), and the American toad (Yahner et 

32 al. 2001). Reptile species include the eastern garter snake, northern ringneck snake (Diadophis 

33 punctatus edwards), black rat snake (Pantherophis obsoletus), and eastern box turtle (Yahner 

34 et al. 2001). Small mammals include the white-footed mouse, northern short-tailed shrew 

35 (Blarina brevicauda), and meadow vole (Yahner and Yahner 2007). Common butterfly species 

36 include the cabbage white (Pieris rapae), little wood-satyr (Megisto cymela), and great spangled 

37 fritillary (Speyaria cybele) (Bramble et al. 1997). 

38 2.2.8. Protected Species and Habitats

39 The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) 

40 jointly administer the Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.). The FWS 

41 manages the protection of and recovery effort for listed terrestrial and freshwater species, while 

42 the NMFS manages the protection of and recovery effort for listed marine and anadromous 

43 species.

44 Within Pennsylvania, the PGC, the PFBC, and the PDCNR oversee the protection of 

45 Commonwealth-listed species under the Pennsylvania Endangered Species Program. The 

46 PGC, PFBC, and PDCNR manage the recovery efforts for wild birds and mammals 
Purpose and Need for Action

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1 (34 Pa. Code 133); fish, amphibians, reptiles, and aquatic organisms (30 Pa. Code 75); and 

2 native plants (17 Pa. Code 45), respectively.

3 The Magnuson–Stevens Fishery Conservation and Management Act (MSA), as amended, is 

4 administered by the NMFS. The MSA requires Federal agencies to consider the impact of 

5 Federal actions on essential fish habitat (EFH) and to consult with the NMFS if any activities 

6 may adversely affect EFH. The NMFS has not designated any EFH under the MSA within the 

7 affected waterbodies. However, in a letter dated June 27, 2012, NMFS stated that the Schuylkill 

8 River and Perkiomen Creek provide habitat for a variety of prey species consumed by Federally 

9 managed species whose EFH has been designated in the mixing zone of the Delaware River 

10 (NMFS 2012c). The NRC staff’s EFH assessment will be issued separately as part of the staff’s 

11 consultation with NMFS under the MSA. 

12 The FWS and NMFS have not designated any critical habitat under the ESA within the action 

13 area, nor has either agency proposed the listing or designation of any new species or critical 

14 habitat within the action area (Exelon 2011b; FWS 2011, 2012d; NMFS 2012a, 2012c).

15 2.2.8.1. Action Area

16 For the purposes of its protected species and habitat discussion and analysis, the NRC 

17 considers the action area, as defined by the ESA regulations at 50 CFR 402.02, to include the 

18 lands and waterbodies described below. The following sections only consider terrestrial and 

19 aquatic species that occur or have the potential to occur within this action area.

20 LGS site and surrounding area within a 6-mile (10-km) radius. The majority of the LGS site 

21 lies in Limerick Township, Montgomery County, although a portion of the property extends into 

22 the adjacent Lower Pottsgrove Township in Montgomery County, and East Coventry Township 

23 in Chester County, directly across the Schuylkill River.

24 Transmission line corridors and 1-mile (1.6-km) buffer on either side of the lines. Of the 

25 five in-scope transmission lines (described in Section 2.1.5), three of the lines terminate within 

26 Montgomery County. One of lines—the 220-61 line—runs parallel to the Schuylkill River on the 

27 Chester County side for about 8 miles (12.9 km). Another line—the 220-60 line—crosses the 

28 Schuylkill River into East Pikeland Township, Chester County, just before terminating.

29 Waterbodies and facilities associated with the LGS makeup water supply system. The 

30 makeup water supply system includes a number of waterbodies and facilities off site of the LGS 

31 site. These include the Perkiomen Pumphouse (Montgomery County); the Bradshaw Reservoir 

32 and Bradshaw Pumphouse (Bucks County), which are located on 42 ac (17 ha) of 

33 Exelon-owned property; and the Bedminster Water Processing Facility (Bucks County), which is 

34 located on a 3 ac (1.2 ha) Exelon-owned property. Section 2.1.6 describes the LGS makeup 

35 water supply system in detail.

36 2.2.8.2. Aquatic Species and Habitats

37 The aquatic species described in this section and summarized in Table 2–3 are Federally listed 

38 or Pennsylvania-listed threatened, endangered, or species of special concern that may occur in 

39 the action area, as defined above. The three Federally listed species appear in bold.

40 FWS, NMFS, and/or PFBC list the species in Table 2–3 as occurring within Montgomery, 

41 Chester, or Bucks Counties, Pennsylvania, which are the three counties associated with LGS. 

42 LGS infrastructure and associated waters bodies within Montgomery County include the main 

43 plant site (e.g., power block), the Schuylkill River, Perkiomen Creek and Pumphouse, and the 

44 East Branch Perkiomen Creek. LGS infrastructure and associated waterbodies in Chester 

45 County include portions of the main plant site on the other side of the Schuylkill River and 

46 transmission lines. LGS infrastructure and associated waterbodies in Bucks County include the 
Purpose and Need for Action

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1 Delaware River and Point Pleasant Pumping Station, the Bradshaw Reservoir and Bradshaw 

2 Pumphouse, and the Bedminster Water Processing (Treatment) Facility. 

3 Table 2–3. Federally and Pennsylvania-Listed Aquatic Species

Scientific Name Common Name

Federal 

Status(a)

State 

Status(b)

County(ies) of 

Occurrence(c)

Fish

Acipenser brevirostrum shortnose sturgeon FE PE B 

Acipenser oxyrinchus oxyrinchus Atlantic sturgeon FE PE B

Alosa aestivalis blueback herring CS — B, C, M

Alosa pseudoharengus Alewife CS — B, C, M

Enneacanthus obesus banded sunfish — PE B 

Lepomis megalotis longear sunfish — PE B 

Notropis chalybaeus ironcolor shiner — PE B, M

Invertebrates

Alasmidonta heterodon dwarf wedgemussel FE PE B, C, M (d)

Stygobromus pizzinii Pizzini’s cave amphipod — SSC C, M

Aquatic Plants

Myriophyllum farwellii Farwell’s water-milfoil — PE B 

Myriophyllum heterophyllum broad-leaved water milfoil — PE B

Nymphoides cordata floating-heart — PT B 

Potamogeton pulcher spotted pondweed — PE B

(a) Federal status determined by the FWS and NMFS under the authority of the Endangered Species Act; CS = candidate 

species (NMFS 2012c, 2012a; FWS 2012d); FE = endangered, FT = threatened, — = not listed.

(b) Commonwealth of Pennsylvania status determined by the PFBC under the Pennsylvania Endangered Species Program; 

PE = endangered, PT = threatened, SSC = species of special concern; — = not listed (PNHP 2012a). (c) The LGS site lies in Montgomery County; the in-scope transmission lines traverse Montgomery and Chester Counties; 

and the offsite facilities associated with the LGS makeup water system lie in Montgomery and Bucks Counties. 

B = Bucks County, C = Chester County, M = Montgomery County. (d) FWS (2012d) lists the dwarf wedgemussel as known to or believed to occur in Monroe, Pike, and Wayne Counties, 

Pennsylvania, which do not contain LGS-related infrastructure or waterbodies. PNHP (2012a) lists the dwarf 

wedgemussel as potentially occurring in Bucks, Chester, and Montgomery Counties. PECO (1984) observed rare,

unidentified species of the genus Alasmidonta in the Schuylkill River in the 1970s and it is unknown whether the 

specimen was the dwarf wedgemussel (Exelon 2011b). 

4 In addition to the species listed in the above table, LGS collected bridle shiner (Notropis 

5 bifrenatus), a Pennsylvania-listed endangered species, through 1977. LGS did not observe 

6 bridle shiner since 1977 (Exelon 2011b). Furthermore, PNHP (2012a) does not list this species 

7 as occurring within Bucks, Chester, or Montgomery Counties and PBFC (2011b) did not identify 

8 the species as a concern regarding the proposed license renewal. Therefore, this species is not 

9 considered further within this SEIS.
Purpose and Need for Action

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1 Fish

2 Shortnose Sturgeon (Acipenser brevirostrum)

3 The shortnose sturgeon was initially listed as a Federally endangered species in 1967 and is 

4 designated as a Pennsylvania endangered species (NMFS 2012b, PNHP 2012a). Adult 

5 shortnose sturgeon use freshwater for spawning and estuarine and marine habitats for feeding. 

6 Juveniles migrate downriver to estuarine waters and may go back and forth between freshwater 

7 and estuarine habitats for several years before maturing to adults. Adults sometimes migrate to 

8 marine habitats for feeding, but primarily inhabit estuarine habitats (Rohde et al. 1994, 

9 NMFS 2012b). Spawning occurs in freshwaters characterized by low-to-moderate velocities 

10 and over substrates that include clay, sand, gravel, and woody debris. Eggs are adhesive and 

11 survival depends on water having little turbidity (Rohde et al. 1994). Sturgeon feed on benthic 

12 invertebrates such as snails, insect larvae, crustaceans, and worms (Gilbert 1989).

13 In Pennsylvania, populations of shortnose sturgeon inhabit the Delaware River 

14 (Hastings et al. 1987, O’Herron et al. 1993). Hastings et al. (1987) surveyed shortnose 

15 sturgeon movement in the Delaware River and estimated an overwintering population of about 

16 6,000 to 14,000 fish in the upper tidal portion of the Delaware River near Trenton, NJ at river 

17 kilometer (RKm) 211.8 (river mile [RM] 131.6) (Hastings et al. 1987). Sturgeon moved 

18 upstream into the non-tidal reach of the river in late March presumably to spawn before traveling 

19 downstream to lower tidal waters near Philadelphia (O’Herron et al. 1993). Hastings et al. 

20 (1987) observed upstream movement to non-tidal water as far as Lambertville, NJ at RKm 238 

21 (RM 147.9). This location is approximately 15 river km (9.1 river miles) from the Point Pleasant 

22 Pumping Station, which is located at RM 157 (RKm 253).

23 Shortnose sturgeon occur in Bucks County (PNHP 2012a, NMFS 2012a). On the Delaware 

24 River, LGS-related studies from 1979 to 1985 did not capture shortnose sturgeon eggs or larvae 

25 near the Point Pleasant Pumping Station and downriver to RM 138 (RKm 222.1) (Exelon 2011a; 

26 RMC 1984, 1985, 1986). NMFS (2012a) concluded that no species listed under the ESA occur 

27 within the action area.

28 Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus)

29 The Atlantic sturgeon is currently listed as a Federally endangered species for the New York 

30 Bight distinct population segment, which includes the Delaware River (77 FR 5880). The 

31 Atlantic Sturgeon is also designated as a Pennsylvania State endangered species 

32 (PNHP 2012a). Atlantic sturgeon share many life-history characteristics with the shortnose 

33 sturgeon in that adults migrate to freshwater to spawn and feed on benthic invertebrates such 

34 as worms, crustaceans, and aquatic insects (Gilbert 1989). Unlike shortnose sturgeon, adult 

35 Atlantic sturgeon prefer more marine habitats and make extensive migrations away from natal 

36 estuaries beginning as subadults (Gilbert 1989). 

37 Atlantic sturgeon occur in Bucks County (PNHP 2012a, NMFS 2012a). Historically, the 

38 Delaware River supported the largest population of Atlantic sturgeon along the Atlantic coast 

39 (Secor and Waldman 1999). Tagging studies in 2005 and 2006 indicated that Atlantic sturgeon 

40 followed similar migration patterns as shortnose sturgeon with spawning potentially occurring 

41 between mid to late June in the upper tidal Delaware reaches between Philadelphia, 

42 Pennsylvania, and Trenton, New Jersey (Simpson and Fox undated).

43 LGS-related studies from 1979 to 1985 did not observe Atlantic sturgeon eggs or larvae near 

44 the Point Pleasant Pumping Station and downriver to RM 138 (RKm 222.1) (Exelon 2011b; 

45 RMC 1984, 1985, 1986). NMFS concluded that no species listed under the ESA occur within 

46 the action area (NMFS 2012c). 
Purpose and Need for Action

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1 Alewife and Blueback Herring (Alosa pseudoharengus and A. aestivalis)

2 Blueback herring and alewife are candidate species that occur in the project area (NMFS 2012, 

3 76 FR 67652). As candidate species, blueback herring and alewife are not afforded any 

4 procedural or substantive protections under ESA. NFMS currently is considering whether to list 

5 blueback herring and alewife under ESA (69 FR19976). Blueback herring and alewife also are 

6 NMFS species of concern. A species is designated as a species of concern if NMFS has some 

7 concerns about the species’ status and threats, but there is insufficient information to indicate a 

8 need to list the species under the ESA (NMFS 2012). This status level does not carry any 

9 procedural or substantive protections under the ESA (NMFS 2012b).

10 Alewife and blueback herring are both part of the herring family, Clupeidae (PFBC 2012). The 

11 two species look similar to one another. However, blueback herring generally are more slender 

12 and darker in color than alewife (PFBC 2012c). Blueback herring grow to a maximum of 15 in. 

13 (38 cm) and 1 lb (0.45 kg). Herring are an important component of freshwater, estuarine, and 

14 marine food webs because they are prey for many predatory fish and help transport nutrients to 

15 freshwater systems. Alewife and blueback herring prey include zooplankton, shrimp, small fish, 

16 and fish eggs (PFBC 2012c). 

17 Blueback herring and alewife spawn in freshwater during the spring and migrate to estuaries or 

18 marine waters during the summer and cooler months. Alewife begin their spring migration to 

19 freshwater earlier than blueback herring and alewife spawn earlier (Collette and 

20 Klein-MacPhee 2002). In Pennsylvania, blueback herring spawn in the lower Delaware River 

21 and the Delaware estuary (PFBC 2012c). Alewife spawn in similar areas, but they also may 

22 inhabit and spawn in freshwater lakes and impoundments. In streams and rivers, spawning 

23 habitat includes fresh water several miles upstream of the tidal line in the Delaware River and in 

24 areas with a rocky, firm bottom (PFBC 2012c). Eggs are demersal and adhesive (PFBC 2012). 

25 Adults return to salt water after spawning, although adult alewife also can inhabit freshwater. 

26 Historically, dams have severely limited movement of blueback herring and alewife to and from 

27 spawning grounds (NMFS 2012c). 

28 In Pennsylvania, blueback herring only occur in the lower Delaware River and the Delaware 

29 estuary (PFBC 2012). LGS-related surveys did not observe blueback herring in the Schuylkill 

30 River, East Branch of the Perkiomen Creek, Perkiomen Creek, or the Delaware River near the 

31 Point Pleasant Pump Station (Table 2–2; Exelon 2011b). LGS-related studies captured alewife 

32 in the Schuylkill and Delaware Rivers, but did not observe this species in the East Branch of the 

33 Perkiomen Creek or the Perkiomen Creek (Table 2–2; Exelon 2011b). Studies from 1979–80 

34 indicated that American shad, alewife, and blueback herring used the Delaware River in the 

35 vicinity of Point Pleasant as a nursery area. 

36 Banded Sunfish (Enneacanthus obesus)

37 The Commonwealth of Pennsylvania lists the banded sunfish as endangered (PNHP 2012a). 

38 Banded sunfish prefer a restricted home range in coastal habitats such as small ponds, 

39 backwaters of creeks and rivers, and slow-moving waters that have high acidity and abundant 

40 vegetation. Banded sunfish prey on insects and microcrustaceans (PNHP 2012b). Spawning 

41 over gravel or sand nests occurs in April through July, and the buoyant eggs drift with the slow 

42 current (Rohde et al. 1994). 

43 Banded sunfish occur in Bucks County (PNHP 2012a). Waters in Bucks County associated with 

44 the LGS cooling system include the Delaware River at the Point Pleasant Pumping Station. 

45 However, this area is not a preferred habitat for the banded sunfish as it is far upriver from the 

46 coast and banded sunfish occur in the lower Delaware River (PNHP 2012b). LGS-related 

47 studies from 1979 to 1985 did not observe banded sunfish eggs or larvae in surveys in the 
Purpose and Need for Action

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1 Delaware River at the Point Pleasant Pumping Station and downriver to RM 138 (RKm 222.1) 

2 (Exelon 2011b; RMC 1984, 1985, 1986).

3 Longear Sunfish (Lepomis megalotis)

4 The Commonwealth of Pennsylvania lists the longear sunfish as endangered (PNHP 2012a). 

5 Longear sunfish prefer slow-moving, shallow, headwater streams where they prey on 

6 invertebrates, fish eggs, and smaller fish. Spawning occurs in spring and summer. Males 

7 defend eggs and fry (PNHP 2012c). 

8 Before 1980, the longear sunfish occurred in Bucks County (PNHP 2012a). However, 

9 Pennsylvania records since 1980 do not list longear sunfish as occurring in Bucks County 

10 (PNHP 2012c). LGS-related studies from 1979 to 1985 did not observe longear sunfish eggs or 

11 larvae during surveys in the Delaware River at the Point Pleasant Pumping Station and 

12 downriver to RM 138 (RKm 222.1) (Exelon 2011b; RMC 1984, 1985, 1986).

13 Ironcolor Shiner (Notropis chalybaeus)

14 The Commonwealth of Pennsylvania lists the ironcolor shiner as endangered (PNHP 2012a). 

15 Little is known about the habitat preference and life cycle of ironcolor shiner in Pennsylvania. 

16 Rohde et al. (1994) assumes that ironcolor shiner prefer habitats of headwaters in creeks or 

17 small rivers with sandy or rocky bottoms. They likely spawn during spring months and prey on 

18 insect larvae and algae, as is common among many shiner species along the eastern 

19 U.S. coast. 

20 PNHP (2012a) lists ironcolor shiners as possibly extirpated in both Bucks and Montgomery 

21 Counties. LGS-related studies from 1979 to 1985 did not observe ironcolor shiner eggs or 

22 larvae during surveys on the Delaware River at the Point Pleasant Pumping Station and 

23 downriver to RM 138 (RKm 222.1) (Exelon 2011b; RMC 1984, 1985, 1986). In the East Branch 

24 Perkiomen Creek, Perkiomen Creek, and the Schuylkill River, LGS-related studies did not 

25 observe ironcolor shiner eggs, larvae, juveniles, or adults during fish surveys between 1970 and 

26 2009 (Exelon 2001, 2002, 2003, 2004, 2005, 2011; NAI 2010a, 2010b, 2010c; PECO 1984; 

27 RMC 1984, 1985, 1986, 1987, 1988, 1989). 

28 Invertebrates

29 Dwarf Wedgemussel (Alasmidonta heterodon)

30 The dwarf wedgemussel is currently listed as a Federally endangered species wherever it 

31 occurs, and is designated as a Pennsylvania-endangered species (FWS 2012a, PNHP 2012a). 

32 The dwarf wedgemussel prefers habitat characterized by mud, sand, or gravel bottom in 

33 slow-to-moderate, clear flowing streams and rivers (FWS 1992). Reproduction requires mussel 

34 larvae (glochidia) to attach to host fish gills before completion of metamorphosis into juveniles. 

35 The dwarf wedgemussel uses a number of different fish host species for glochidial reproduction, 

36 including darter and sculpin fish species (FWS 2007b). 

37 FWS lists the dwarf wedgemussel as known to or believed to occur in Monroe, Pike, and Wayne 

38 Counties, Pennsylvania, which do not contain any LGS-associated infrastructure or waterbodies

39 (FWS 2012c). PNHP lists the dwarf wedgemussel as potentially occurring in Bucks, Chester, 

40 and Montgomery Counties (PNHP 2012a). PECO observed rare, unidentified species of the 

41 genus Alasmidonta in the Schuylkill River in the 1970s and it is unknown whether the 

42 specimens were the dwarf wedgemussel (PECO 1984, Exelon 2011b). Other than the rare 

43 Alasmidonta specimens observed in the 1970s in the Schuylkill River, LGS-related studies did 

44 not observe dwarf wedgemussels during benthic surveys in East Branch Perkiomen Creek, 

45 Perkiomen Creek, and the Schuylkill River between 1970 and 2009 (Exelon 2011b; NAI 2010c; 

46 PECO 1984; RMC 1984, 1985, 1986, 1987, 1989). 
Purpose and Need for Action

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1 Pizzini’s Cave Amphipod (Stygobromus pizzinii)

2 The Commonwealth of Pennsylvania lists the Pizzini’s cave amphipod, previously named 

3 Stygonectes pizzinii, as a Pennsylvania species of concern. The Pizzini’s cave amphipod is an 

4 invertebrate that occurs within a variety of groundwater habitats, such as seeps, small springs, 

5 small spring and seep-fed streams, mines, wells, and caves (Holsinger 1978). As of 1978, the 

6 Schuylkill River was the northern most portion of the known geographic range for this species 

7 (Holsinger 1978). Although the Pizzini’s cave amphipod is not listed as a candidate, threatened, 

8 or endangered species, PFBC (2011b) noted that the species may be listed “in the not so 

9 distant future.” This species is threatened by habitat destruction and poor water quality 

10 (PFBC 2011b).

11 Pizzini’s cave amphipod is possibly extirpated in Montgomery and Chester Counties 

12 (PNHP 2012a). PECO (1984) observed Stygonectes pizzinii and Stygonectes sp. during 

13 surveys of the Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek conducted 

14 between 1970 and 1976. RMC reported Stygobromus sp. (not specifically identified as 

15 Stygobromus pizzinii) during a survey in the East Branch Perkiomen Creek in 1983 (RMC 1984) 

16 and during surveys in the Schuylkill River in 1985 and 1986 (RMC 1986, 1987). However, from 

17 1986 until 1988, LGS-related studies did not observe Stygobromus species in the East Branch 

18 Perkiomen Creek nor the Schuylkill River (Exelon 2011a; RMC 1987, 1988, 1989). Based the 

19 Pennsylvania Natural Diversity Inventory (PNDI) database and PFBC files, PFBC (2011b) 

20 stated in its letter to the NRC that globally rare amphipod and/or isopod species are known to 

21 occur within the vicinity of the LGS site. 

22 Aquatic Plants

23 Farwell’s Water-Milfoil (Myriophyllum farwellii)

24 The Commonwealth of Pennsylvania lists the Farwell’s water-milfoil as an endangered aquatic 

25 plant (PNHP 2012a). Farwell’s water-milfoil is a submerged plant that will grow up to 1 ft 

26 (0.3 m) in length. This species of milfoil grows in lakes and ponds (PNHP 2012d). Farwell’s 

27 water-milfoil is often confused with other invasive milfoil species (PNHP 2012d).

28 PNHP reports no current observations of Farwell’s water-milfoil in the three counties associated 

29 with LGS. However, this plant was present in the coastal region of Bucks County before 1980 

30 (PNHP 2012d). PECO (1984) did not observe Farwell’s water-milfoil during aquatic surveys in 

31 the Delaware River near the Point Pleasant Pumping Station, East Branch Perkiomen Creek, 

32 Perkiomen Creek, or the Schuylkill River between 1970 and 1976.

33 Broad-Leaved Water-Milfoil (Myriophyllum heterophyllum)

34 The Commonwealth of Pennsylvania lists the broad-leaved water-milfoil as an endangered 

35 aquatic plant (PNHP 2012a). Broad-leaved water-milfoil colonizes slow-moving freshwater 

36 habitats and has both submerged and emergent foliage. Reproduction occurs when part of the 

37 plant breaks off, grows roots, and settles in a new location (NHDES 2010).

38 The broad-leaved water-milfoil is possibly extirpated in Bucks County (PNHP 2012a). PECO 

39 (1984) did not observe broad-leaved water-milfoil during aquatic surveys in the Delaware River 

40 at Point Pleasant Pumping Station, East Branch Perkiomen Creek, Perkiomen Creek, or the 

41 Schuylkill River between 1970 and 1976.

42 Floating-Heart (Nymphoides cordata)

43 The Commonwealth of Pennsylvania lists the floating-heart as a threatened aquatic plant 

44 (PNHP 2012a). Floating-heart grows in lakes and ponds and resembles a small water-lily 

45 (PNHP 2012e). In the spring, floating-heart propagates, or creates new plants, as rhizomes, 

46 tubers, or seeds sprout new growth. 
Purpose and Need for Action

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1 Floating-heart is listed as possibly extirpated in Bucks County (PNHP 2012e). PECO (1984) did 

2 not observe floating-heart during aquatic surveys in the Delaware River at Point Pleasant 

3 Pumping Station, East Branch Perkiomen Creek, Perkiomen Creek, or the Schuylkill River 

4 between 1970 and 1976.

5 Spotted Pondweed (Potamogeton pulcher)

6 The Commonwealth of Pennsylvania lists the spotted pondweed as an endangered aquatic 

7 plant (PNHP 2012a). Leaves are floating or submerged and flowering occurs between June 

8 and September. Spotted pondweed grows in wetlands characterized by acidic, standing water 

9 (PNHP 2012f). 

10 Spotted pondweed occurs within coastal regions of Bucks County (PNHP 2012f). PECO (1984) 

11 did not observe spotted pondweed during aquatic surveys in the Delaware River at Point 

12 Pleasant Pumping Station, or in East Branch Perkiomen Creek, Perkiomen Creek, or the 

13 Schuylkill River between 1970 and 1976.

14 2.2.8.3. Terrestrial Species and Habitats

15 Before LGS construction, PECO compiled lists of plants and animals likely to occur on the site 

16 and along the transmission line corridors based on species’ ranges and habitat requirements. 

17 In the late 1970s, PECO conducted surveys to confirm the presence of these species on the 

18 site. The final environmental statement (FES) for construction of LGS (AEC 1973) includes 

19 tables of those species PECO observed on the site as well as those species not specifically 

20 observed during surveys but that are likely to occur on the site or along the transmission line 

21 corridors. The NRC published an FES for operation of LGS in 1984 (NRC 1984), although this 

22 FES did not document any new surveys or studies not already mentioned in the previous FES. 

23 Exelon staff and Normandeau Associates, Inc. (Normandeau) performed reconnaissance 

24 surveys to confirm the accuracy of the pre-construction site surveys in 2009 and 2010, and 

25 Exelon’s ER (Exelon 2011b) and the LGS Wildlife Management Plan (Exelon 2010b) include 

26 information on the results of these reconnaissance surveys. The WHC’s “Site Assessment and 

27 Wildlife Management Opportunities for Exelon Corporation’s Limerick Generating Station” 

28 (WHC 2006) also provides information on LGS site habitats and species. The NRC staff did not 

29 identify any ecological surveys or studies that include the transmission line corridors or the 

30 offsite facilities within the action area or that might provide additional information about the 

31 occurrence of protected species and habitats.

32 Neither the pre-construction surveys nor the recent reconnaissance surveys identified any 

33 Federally listed species on the LGS site. However, several Federally listed species (see 

34 Table 2–4) have the potential to occur in the action area. In pre-operational surveys and 

35 ongoing informal surveys, Normandeau has identified 10 Pennsylvania-listed bird species on 

36 the LGS site. The PDCNR (2011) identified eight Pennsylvania-listed plants that occur along or 

37 near the transmission line corridors. Exelon’s LGS Wildlife Management Plan (Exelon 2010a) 

38 identifies two additional Pennsylvania-listed plants that occur on the LGS site. The 

39 PFBC (2011b) identified one reptile—the eastern redbelly turtle (Pseudemys rubriventris)—as 

40 occurring in the vicinity of the LGS site. Federally and Pennsylvania-listed species are 

41 discussed in more detail below.

42 Table 2–4 identifies the Federally and Pennsylvania-listed species that occur or have the 

43 potential to occur in the action area. The three Federally listed species appear in bold. The 

44 staff compiled this table from the FWS’s online species search by county (FWS 2012a); the 

45 Pennsylvania Natural Heritage Program (PNHP)’s online species database (PNHP 2012a); and 

46 correspondence with the FWS (2011), the PGC (2011), the PFBC (2011b), and the 

47 PDCNR (2011). The NRC staff did not identify any proposed species, proposed critical habitat, 
Purpose and Need for Action

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1 or designated critical habitat in the action area. In its correspondence with the NRC, the 

2 FWS (2011) also did not identify these categories of species or habitats. The Pennsylvania 

3 Endangered Species Program does not designate insects or spiders as Pennsylvania 

4 endangered or threatened; therefore, no insects or spiders appear in Table 2–4. 

5 Table 2–4. Federally and Pennsylvania-listed Terrestrial Species

Scientific Name Common Name Federal 

Status(a)

State 

Status(b)

County(ies) of 

Occurrence(c)

Amphibians

Acris crepitans northern cricket frog — PE B, C, M

Lithobates sphenocephalus utricularius southern leopard frog — PE B, C

Pseudacris kalmi New Jersey chorus frog — PE B, M

Scaphiopus holbrookii eastern spadefoot — PE B

Birds

Ardea alba great egret — PE M(e)

Asio flammeus short-eared owl — PE B

Asio otus long-eared owl — PT C

Bartramia longicauda upland sandpiper — PT B, C, M

Botaurus lentiginosus American bittern — PE C

Cistothorus platensis sedge wren — PE B, C

Dendroica striata blackpoll warbler — PE M(e)

Empidonax flaviventris yellow-bellied flycatcher — PE M(e)

Falco peregrinus peregrine falcon — PE B

Haliaeetus leucocephalus bald eagle — PT B, C, M

Ixobrychus exilis least bittern — PE C

Nyctanassa violacea yellow-crowned night-heron — PE M

Nycticorax nycticorax black-crowned night-heron — PE C

Pandion haliaetus osprey — PT B, C

Rallus elegans king rail — PE C

Spiza Americana dickcissel — PE C

Mammals

Cryptotis parva least shrew — PE C

Myotis leibii eastern small-footed myotis — PT B

Myotis sodalist Indiana bat FE PE B, C, M(d)

Plants

Andropogon gyrans Elliott's beardgrass — PR B, C, M

Arabis missouriensis Missouri rock-cress — PE M

Arabis patens spreading rock-cress — PT B, C, M
Purpose and Need for Action

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Scientific Name Common Name Federal 

Status(a)

State 

Status(b)

County(ies) of 

Occurrence(c)

Cuscuta campestris dodder — PT B, C, M

Cyperus schweinitzii Schweinitz’s flatsedge — PR C, M

Ilex opaca American holly — PT B, C

Iris prismatica slender blue Iris — PE B, C, M

Isotria medeoloides small-whorled pogonia FT PE C

Ranunculus fascicularis tufted buttercup — PE C, M

Rotala ramosior tooth-cup — PR B, C, M

Viburnum nudum wild raisin — PE B, C, M

Reptiles

Glyptemys muhlenbergii bog turtle FT PE B, C, M

Opheodrys aestivus rough green snake — PE C

Plestiodon laticeps broadhead skink — PC C

Pseudemys rubriventris eastern redbelly turtle — PT B, C, M

(a)Federal status determined by the FWS under the authority of the Endangered Species Act; FE = endangered, 

FT = threatened, — = not listed.

(b)Commonwealth of Pennsylvania status determined by the PDCNR, PGC, and PFBC under the Pennsylvania 

Endangered Species Program; PE = endangered, PT = threatened, PR = rare (plants), PC = candidate (amphibians 

and reptiles). (c)The LGS site lies in Montgomery County; the in-scope transmission lines traverse Montgomery and Chester 

Counties; and the offsite facilities associated with the LGS makeup water system lie in Montgomery and Bucks 

Counties. B = Bucks County, C = Chester County, M = Montgomery County. (d)The FWS (2012a) identifies the species as occurring in Montgomery, Chester, or Bucks Counties; however the 

PNHP (2012a) does not identify the Indiana bat as occurring in any of these three counties. (e)The PNHP (2012a) does not identify the great egret, blackpoll warbler, or yellow-bellied flycatcher as occurring in 

Montgomery County. However, according to Exelon’s Wildlife Management Plan (Exelon 2010a), Normandeau 

staff has observed these species on the LGS site.

Sources: FWS 2011, 2012a; PDCNR 2011; PGC 2011; PFBC 2011b; PNHP 2012a

1 In addition to the species listed in the Table 2–4, the NRC identified an additional 

2 14 Pennsylvania-listed amphibians, birds, and reptile species and about 100 additional plant 

3 species that occur within Montgomery, Chester, or Bucks Counties (PNHP 2012a). The table 

4 does not include these species, and this section does not consider these species further 

5 because the PGC, PFBC, and PDCNR, which oversee the recovery efforts of 

6 Pennsylvania-listed species, did not identify these species as occurring in the action area in 

7 correspondence with Exelon or the NRC (PDCNR 2011, PFBC 2011b, PGC 2011).

8 Species and Habitats Protected under the Endangered Species Act

9 Bog Turtle (Glyptemys muhlenbergii)

10 The FWS listed the northern population of the bog turtle, which occurs from New York and 

11 Massachusetts south to Maryland, as threatened under the ESA in 1997 (62 FR 59605). The 

12 FWS has not designated critical habitat for this species (FWS 2012a). This species is also 

13 listed as endangered by the PFBC.

14 The bog turtle is one of the smallest turtles in North America. Its upper shell is 3 to 4 in.

15 (8 to 10 cm) long and light brown to black in color. Each side of its black head has a distinctive 
Purpose and Need for Action

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1 patch of color that is bright orange to yellow. The bog turtle is diurnal and semiaquatic; it 

2 forages on land and in water for its varied diet of insects and other invertebrates, frogs, plants, 

3 and carrion. In Pennsylvania, the bog turtle usually is active from late March through late 

4 September and hibernates the remainder of the year under water in soft mud and crevices. Bog 

5 turtles construct nests in sphagnum moss or on tussock sedges, which allows them to deposit 

6 eggs above the wetland inundation level. Females lay one to six eggs in June and July. Eggs 

7 incubate unattended for 6 to 8 weeks, which often leaves them vulnerable to mice, raccoons, 

8 skunks, foxes, birds, and other predators. Young hatch during late August through early 

9 September (FWS 2001, 2010). 

10 Northern bog turtles primarily inhabit early to mid-successional wetlands fed by groundwater or 

11 associated with the headwaters of streams and dominated by emergent vegetation (spring

12 seeps and open marshy meadows) (FWS 2001). These habitats typically have shallow, cool, 

13 slow-flowing water, early to mid-successional vegetation, open canopies, and wet meadows of 

14 sedges (Carex spp.) (FWS 2001, PADEP 2006b). The species is also associated with spike 

15 rushes (Eleocharis spp.) and bulrushes (Juncus spp. and Scirpus spp.) (FWS 2001, 

16 PADEP 2006b). The species’ continued existence is threatened by loss and fragmentation of 

17 wetlands; hydrologic alterations that affect groundwater and surface water quantity and quality; 

18 livestock grazing and associated nutrient loading; habitat alterations associated with invasive 

19 plant species; and illegal collection and trade (FWS 2010).

20 In Pennsylvania, the bog turtle occurs in the southeastern part of the state. As of 2000, the 

21 FWS (2001) identified 14 Pennsylvania counties (including Montgomery, Chester, and Bucks 

22 Counties) with extant populations on bog turtles (FWS 2001). Two additional counties 

23 historically contained bog turtles, and the FWS (2001) considers a third county’s population 

24 extirpated. In total, the FWS (2001) identified 75 extant populations, many of which occur within 

25 the Delaware River and Susquehanna River watersheds. 

26 None of the available surveys or reports of the LGS site (described in the first paragraph of this 

27 section; AEC 1973; Exelon 2010a, 2011a; NRC 1984; WHC 2006) identified the bog turtle as 

28 occurring on the LGS site. However, no bog turtle habitat (Phase 1) surveys have been 

29 completed in the action area. Small sections of the LGS site along the Schuylkill River contain 

30 palustrine emergent and forested wetlands. Wetlands also occur along each of the 

31 transmission line corridors. Thus, the species may occur within suitable wetland habitat in these 

32 areas.

33 Indiana Bat (Myotis sodalis)

34 The FWS listed the Indiana bat as endangered wherever found in 1967 under the Endangered 

35 Species Preservation Act of 1966, the predecessor regulation to the ESA (32 FR 4001). The 

36 FWS has not designated critical habitat for the species in Pennsylvania (41 FR 41914). This 

37 species is also listed as endangered by the PGC.

38 The Indiana bat is an insectivorous, migratory bat that occurs within the central portion of the 

39 eastern United States and hibernates colonially in caves and mines. Menzel et al. (2005) 

40 concluded that habitat use is highly correlated with insect abundance, which means that Indiana 

41 bats often forage in riparian areas where insect densities are highest. Menzel et al. (2005) also 

42 found that Indiana bats were more closely associated with linear landscape features (forest 

43 corridors and roads) than open areas (agricultural land, grasslands, or meadows). 

44 Reproductive females migrate and form maternity colonies in wooded riparian areas, 

45 bottomlands, floodplains, wetlands, and upland areas. Males and nonreproductive females may 

46 stay close to their hibernation site or migrate to summer habitat, but they do not roost in 

47 colonies. Indiana bats create roosts in the exfoliating bark of large (often dead) trees. Both 

48 males and females return to hibernation sites in late summer or early fall to mate and enter 
Purpose and Need for Action

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1 hibernation. Destruction and degradation of caves from mining, tourism, and physical barriers 

2 (such as construction of doors or gates) threaten hibernation habitat (FWS 2007a). Loss and 

3 degradation of forest habitat, which affects migration pathways, maternity roosts, and breeding 

4 areas, also has contributed to the decline of the species (FWS 2007a).

5 The PGC (2010) reports that about 1,000 Indiana bats hibernate in 18 sites within 

6 11 Pennsylvania counties. The PGC (2010) also has identified nine summer maternity sites in 

7 seven counties. According to the draft Indiana bat draft recovery plan (FWS 2007a), no 

8 hibernation or maternity sites occur in Montgomery, Chester, or Bucks Counties. The closest 

9 hibernation site is north of the LGS site in Luzerne County, and the closest maternity colony to 

10 the LGS site is in Berks County, which borders the northwest edges of Montgomery and 

11 Chester Counties (FWS 2007a, PGC 2010). 

12 None of the available surveys or reports of the LGS site (described in the first paragraph of this 

13 section; AEC 1973; Exelon 2010a, 2011a; NRC 1984; WHC 2006) identified the Indiana bat as 

14 occurring on the LGS site. No FWS-qualified Indiana bat surveyor has conducted formal 

15 surveys on the site, and the NRC staff did not identify any other ecological studies that would 

16 provide information on the Indiana bat in the action area. Based on the species’ historic 

17 distribution (FWS 2007a) and the lack of records for the action area, the NRC staff cannot 

18 preclude the potential presence of the Indiana bat in the action area. Therefore, the NRC staff 

19 assumes that the species may occur in areas of suitable habitat within the action area. 

20 Small-Whorled Pogonia (Isotria medeoloides)

21 The FWS listed the small-whorled pogonia as threatened wherever found in 1982 

22 (47 FR 39827). The FWS has not designated critical habitat for this species (FWS 2012b). This 

23 species is also listed as endangered by the PDCNR.

24 The small-whorled pogonia is a small, herbaceous, perennial orchid. Its primary range extends 

25 through the Atlantic seaboard states, but it also occurs in adjacent states, including 

26 Pennsylvania. The species generally grows in young and maturing stands of mixed-deciduous 

27 or mixed-deciduous/coniferous forests that are in second- or third-growth stages of succession. 

28 The species inhabits areas with sparse to moderate ground cover, a relatively open understory, 

29 or areas in proximity to logging roads, streams, or other features that create long-persisting 

30 breaks in the forest canopy. In the northern part of its range, it has been associated with the 

31 following canopy species that are also prevalent in the action area: red maple (Acer rubrum), 

32 northern red oak (Quercus rubra), and American beech (Fagus grandifolia) (see Section 2.2.7). 

33 Throughout its range, the small-whorled pogonia is associated with understories containing red 

34 maple and oak species (Quercus spp.) (FWS 1992). Habitat destruction, disease, and 

35 predation by deer and rabbits threaten the species’ continued existence (FWS 1992, 2008).

36 None of the available surveys or reports of the LGS site (described in the first paragraph of this 

37 section; AEC 1973; Exelon 2010a, 2011a; NRC 1984; WHC 2006) identified the small-whorled 

38 pogonia as occurring on the LGS site. However, PECO conducted the last botanical surveys of 

39 the site before construction of LGS, and the FES for operation of LGS (NRC 1984) indicates 

40 that PECO did not complete any surveys along the transmission line corridors before its

41 construction. During its license renewal application review, the staff did not identify any 

42 ecological surveys or studies of the transmission line corridors or the offsite facilities within the 

43 action area since LGS began operating that might provide additional information about the 

44 occurrence of the small-whorled pogonia within the action area.

45 As of 2007, FWS (2008) reported three extant populations in Pennsylvania and an additional six 

46 populations that were historic, extirpated, or of unknown status. Historic population occurred in 

47 both Montgomery and Berks Counties (FWS-PA 2012). Both the PNHP online species 
Purpose and Need for Action

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1 database (PNHP 2012a) and the FWS Pennsylvania Field Office Web site (FWS-PA 2012) 

2 indicate that the species occurs in Chester County. The NRC did not identify any more specific 

3 information on the location of the three extant populations; therefore, the NRC assumes that the 

4 species has the potential to occur in the action area in areas of suitable habitat along or near 

5 the transmission line corridor that runs through Chester County. 

6 Species Protected under the Bald and Golden Eagle Protection Act

7 The Bald and Golden Eagle Protection Act of 1940, as amended, prohibits anyone from taking 

8 bald eagles (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos), including their 

9 nests or eggs without an FWS-issued permit. The term “take” in the Act is defined as, among 

10 other things, to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, destroy, 

11 molest, or disturb (50 CFR 22.3). “Disturb” means, among other things, to take action that 

12 (1) causes injury to an eagle; (2) decreases its productivity or nest abandonment, by 

13 substantially interfering with breeding, feeding, or sheltering behavior (50 CFR 22.3).

14 Pennsylvania maintains a Bald Eagle Management Plan (Gross and Brauning 2010), which lays 

15 out management goals and objectives to increase the number of successful nesting pairs and to 

16 delist the bald eagle from Pennsylvania-threatened to a secure, protected status. As of 2009, 

17 the PGC identified 174 active nests that produced 244 young in 48 Pennsylvania counties. In 

18 the same year, the PGC recorded three active nests in Bucks County, three in Chester County, 

19 and one in Montgomery County. Data from the 2008 FWS midwinter bald eagle survey indicate 

20 that the bald eagle is also present in Bucks and Chester Counties in the winter months (Gross 

21 and Brauning 2010).

22 Species Protected under the Migratory Bird Treaty Act

23 The FWS administers the Migratory Bird Treaty Act of 1918, as amended (MBTA), which 

24 prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA 

25 definition of a “take” differs from that of the ESA. Under the MBTA, take means to pursue, hunt, 

26 shoot, wound, kill, trap, capture, or collect, or any attempt to carry out these activities 

27 (50 CFR 10.12). Unlike a take under the ESA, a take under the MBTA does not include habitat 

28 alteration or destruction. The MBTA protects a total of 1,007 migratory bird species 

29 (75 FR 9282). Of these 1,007, the FWS allows for the legal hunting of 58 species as game 

30 birds (FWS undated). Within Pennsylvania, the PGC manages migratory bird hunting seasons 

31 and associated licenses for woodcock, pheasant, ruffed grouse, and a number of waterfowl 

32 species. All Federally and Pennsylvania-listed bird species that appear in Tables 2–4 and 2–5 

33 are protected under the MBTA. Additionally, the MBTA protects all U.S.-native bird species that 

34 belong to the families, groups, or species listed at 50 CFR 10.13.

35 Species Protected by the Commonwealth of Pennsylvania

36 This section only discusses those Pennsylvania-listed species from Table 2–4 for which the 

37 NRC has specific occurrence information within the action area. The remaining species in the 

38 table have the potential to occur in the action area, but were not identified during early surveys 

39 of the site (AEC 1973, NRC 1984), or in subsequent reports (Exelon 2010a, 2011a), or were not 

40 identified as species of specific concern in correspondence with the PDCNR (2011), 

41 PGC (2011), or PFBC (2011b) regarding the proposed LGS license renewal.

42 Birds

43 Normandeau conducted bird surveys on the LGS site from 1972 to 1985. Since 1985, 

44 Normandeau has maintained a running checklist of bird species on the site (Exelon 2010a). 

45 Normandeau has identified 10 state-listed bird species. These species and their habitat 

46 requirements appear in Table 2–5. Because more recent occurrence information is based on 
Purpose and Need for Action

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1 Normandeau’s running checklist, the year in which each bird species was last observed is not 

2 available (Exelon 2010a).

3 Table 2–5. Pennsylvania-listed Bird Species in the Action Area

Species Habitat

American bittern

(Botaurus lentiginosus) dense freshwater marshes; wet meadows

bald eagle

(Haliaeetus leucocephalus) riparian areas near rivers or open water bodies

black-crowned night heron

(Nycticorax nycticorax)

coastlines; swamps; river and stream riparian areas; canals; wet 

agricultural fields

blackpoll warbler

(Dendroica striata) second-growth scrub; woodlands; dense conifer forests

great egret

(Ardea alba) marshes; river margins; lakeshores; coastal swamps; lagoons

least bittern

(Ixobrychus exilis) dense marshland containing cattails and reeds

osprey

(Pandion haliaetus) lakes, ponds, rivers, and other open water bordered by trees

peregrine falcon

(Falco peregrines) cliffs, buildings, and other high structures overlooking rivers

yellow-bellied flycatcher

(Empidonax flaviventris)

shady coniferous forests and forested wetlands at higher 

elevations; mossy, poorly drained swamps and bogs

yellow-crowned night heron

(Nyctanassa violacea) small, shallow streams often associated with sycamores

4 Plants

5 The PDCNR (2011) identified eight Pennsylvania-listed plants that occur along or near the 

6 transmission line corridors. None of the available surveys or reports (AEC 1973; Exelon 2010a, 

7 2011a; NRC 1984; WHC 2006) indicate that these species occur on the LGS site; however, two 

8 additional Pennsylvania-listed plants occur on the LGS site. Exelon’s Wildlife Management Plan 

9 (Exelon 2010a) identifies American holly (Ilex opaca) and wild raisin (Viburnum nudum var. 

10 cassinoides), which are Pennsylvania-listed as threatened and endangered, respectively, as 

11 having been identified on the site in 1978 during surveys associated with the construction of 

12 LGS. The continued occurrence of these species on the site today cannot be confirmed 

13 because no vegetation surveys have been completed on the site since the 1970s.

14 American Holly (Ilex opaca). American holly is an evergreen shrub or small tree that grows to 

15 15 m (50 ft) in height. The species grows on wooded slopes and streambanks from coastal 

16 New England south and west into Florida and Texas (PNHP 2007a). Exelon’s ER 

17 (Exelon 2011b) and the LGS Wildlife Management Plan (Exelon 2010a) identify American holly 

18 as having occurred on the LGS site in 1978 during surveys associated with the construction of 

19 the LGS. The continued occurrence of this species on the site today cannot be confirmed 

20 because no vegetation surveys have been completed on the site since the 1970s. A 2007 

21 PNHP Pennsylvania distribution map does not indicate that the species occurs within 

22 Montgomery, Chester, or Bucks Counties (PNHP 2007a).
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1 Dodder (Cuscuta campestris). Dodder is an annual stem parasitic plant that lacks normal roots 

2 and leaves, but bears flowers and fruits that inhabit thickets and waste ground. In its 

3 correspondence with Exelon, the PDCNR (2011) indicated that this species occurs in an old 

4 impounding basin near the Schuylkill River along the 220-63 and 220-64 transmission line 

5 corridors.

6 Elliott’s Beardgrass (Andropogon gyrans). Elliott’s beardgrass is an erect, bunched, perennial 

7 grass that may grow to 3 ft (1 m) in height. It grows in dry to damp grasslands, clearings, open 

8 slopes, and successional old fields from New Jersey to Illinois and south into Florida and Texas 

9 (PNHP 2011a). Though it has not been identified on the LGS site, a 2011 PNHP Pennsylvania 

10 distribution map indicates that the species occurs in southwestern Montgomery County and 

11 throughout Chester County (PNHP 2011a). Additionally, in its correspondence with Exelon, the 

12 PDCNR (2011) indicated that the species occurs in an old field near the 220-63 and 220-64 

13 transmission line corridor.

14 Missouri Rock-Cress (Arabis missouriensis). Missouri rock-cress is an herbaceous biennial 

15 from a taproot, with stems 2 to 5 cm (0.8 to 2 in.) high. The species occurs on dry slopes 

16 across the central and eastern United States (NatureServe 2010a, PDCNR 2011). In its 

17 correspondence with Exelon, the PDCNR (2011) indicated that Missouri rock-cress occurs on a 

18 dry forested slope with scattered outcrops of Brunswick red shale located just east of the 220-60 

19 and 220-61 transmission line corridors.

20 Schweinitz’s Flatsedge (Cyperus schweinitzii). Schweinitz’s flatsedge is a grass-like perennial 

21 with stems 10- to 40-cm (4- to 16-in.) high. The species occurs on dry or moist sand flats and 

22 dunes across much of the continental United States (NatureServe 2010b, PDCNR 2011). In its 

23 correspondence with Exelon, the PDCNR (2011) indicated that Schweinitz’s flatsedge occurs in 

24 association with tooth-cup (described below) in a wet wooded area along the west side of the 

25 Schuylkill River near the 220-60 and 220-61 transmission line corridors.

26 Slender Blue Iris (Iris prismatica). Slender blue iris is a tall perennial forb with grass-like leaves 

27 and dark purple flowers. The species occurs in moist meadows and sandy or gravelly shores 

28 throughout the eastern seaboard of the United States from Maine to Georgia 

29 (NatureServe 2010c, PDCNR 2011). In its correspondence with Exelon, the PDCNR (2011) 

30 indicated that the species occurs on gently sloping land, open with scattered red maples in a 

31 mossy floodplain of Perkiomen Creek near the 220-62 and 5031 transmission line corridors.

32 Spreading Rock-Cress (Arabis patens). Spreading rock-cress is a slender, perennial herb. It 

33 occurs in moist, rocky woods over much of the central and southeastern portions of the eastern 

34 United States (NatureServe 2010d, PDCNR 2011). In its correspondence with Exelon, the 

35 PDCNR (2011) indicated that spreading rock-cress occurs in moist, shaded northwest-facing 

36 rock faces near the 220-60, 220-61, 220-62, 220-63, and 220-64 transmission line corridors.

37 Tooth-Cup (Rotala ramosior). Tooth-cup is a small annual herb that has smooth stems that may 

38 grow up to 12 in. (30 cm) in height. It grows on exposed shorelines, stream margins, streambed 

39 outcrops, and other damp, open places across much of the continental United States 

40 (PNHP 2011b). A 2011 PNHP Pennsylvania distribution map indicates that the species occurs 

41 in the Schuylkill River watershed between Montgomery and Chester Counties (PNHP 2011b). 

42 In its correspondence with Exelon, the PDCNR (2011) indicated that the species occurs in a wet 

43 wooded stretch along the west side of the Schuylkill River near the 220-60 and 220-61 

44 transmission line corridors and on an exposed mud flat and sandy-cobbly shores of seasonally 

45 flooded shallow basins near the 220-63 and 220-64 transmission line corridors.

46 Tufted Buttercup (Ranunculus fascicularis). Tufted buttercup is a small perennial forb with 

47 five-petal yellow flowers. It inhabits dry, thick woods and exposed calcareous slopes and edges 
Purpose and Need for Action

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1 across the central and eastern United States (NatureServe 2010e). In its correspondence with 

2 Exelon, the PDCNR (2011) indicated that the species occurs in a ridgetop glade in a state park 

3 near the 220-62 and 5031 transmission line corridors.

4 Wild Raisin (Viburnum nudum var. cassinoides). Wild raisin (also called possum-haw) is a 

5 deciduous shrub or small tree that grows up to about 12 ft (4 m) in height. The species inhabits 

6 swamps, wet thickets, and pond margins from New York west and south into Texas and Florida 

7 (PNHP 2007b). The LGS Wildlife Management Plan (Exelon 2010a) identifies wild raisin as 

8 having occurred on the LGS site in 1978 during surveys associated with construction of LGS. 

9 The continued occurrence of this species on the site today cannot be confirmed because no 

10 vegetation surveys have been completed on the site since the 1970s. A 2007 PNHP 

11 Pennsylvania distribution map indicates that the species occurs in southwestern Montgomery 

12 County, northern Chester County, and central Bucks County (PHNP 2007b).

13 Reptiles

14 Eastern Redbelly Turtle (Pseudemys rubriventris). The eastern redbelly turtle is one of 

15 Pennsylvania’s largest turtles. It occurs in large water bodies including lakes, ponds, marshes, 

16 slow-moving rivers, and creeks from New York to North Carolina (PNHP 2007c). Redbelly 

17 turtles prefer areas with deeper water with sandy or muddy substrate and aquatic vegetation in 

18 proximity to basking sites. Females nest in upland habitat within 100 m (330 ft) of water. A 

19 2007 PNHP Pennsylvania distribution map indicates that the species occurs throughout 

20 Montgomery, Bucks, and Chester Counties. In its correspondence with the NRC, the PFBC 

21 (2011b) noted that the eastern redbelly turtle occurs in the vicinity of the LGS site.

22 2.2.9. Socioeconomics

23 This section describes current socioeconomic factors that have the potential to be directly or 

24 indirectly affected by changes in operations at LGS. LGS and the communities that support it 

25 can be described as a dynamic socioeconomic system. The communities provide the people, 

26 goods, and services required to operate the nuclear power plant. Power plant operations, in 

27 turn, provide wages and benefits for people and dollar expenditures for goods and services. 

28 The measure of a communities’ ability to support LGS operations depends on the ability of the 

29 community to respond to changing environmental, social, economic, and demographic 

30 conditions.

31 The socioeconomic region of influence (ROI) is defined by the area where LGS employees and 

32 their families reside, spend their income, and use their benefits, thereby affecting the economic 

33 conditions of the region. The ROI consists of a three-county area (Montgomery, Chester, and 

34 Berks Counties), where approximately 84 percent of LGS employees reside.

35 Exelon employs a permanent workforce of 821 full time workers at LGS (Exelon 2011b). As 

36 previously discussed, approximately 84 percent live in Montgomery, Berks, and Chester 

37 Counties (see Table 2–6). Most of the remaining 16 percent of the workforce are divided 

38 among 12 counties across Pennsylvania and other states, with numbers ranging from 1 to 

39 35 employees per county. Given the residential locations of LGS employees, the most 

40 significant impacts of plant operations are likely to occur in Montgomery, Berks, and Chester 

41 Counties. The focus of the socioeconomic impact analysis in this SEIS is therefore on the 

42 impacts of continued LGS operations on these three counties.
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1 Table 2–6. Limerick Generating Station, Employee Residence by County

County Number of Employees Percentage of Total

Pennsylvania

Montgomery 339 41

Berks 249 30

Chester 105 13

Delaware 35 4

Bucks 18 2

Lancaster 18 2

Lehigh 13 2

Other 31 4

Other States 13 2

Total 821 100

Source: Exelon 2011a

2 Refueling outages at LGS normally occur at 24-month intervals. During refueling outages, site 

3 employment increases by as many as 1,400 temporary workers for approximately 20 to 30 days 

4 (Exelon 2011b). Most of these workers are assumed to be located in the same geographic 

5 areas as LGS employees. The following sections describe the housing, public services, offsite 

6 land use, visual aesthetics and noise, population demography, and the economy in the 

7 socioeconomic ROI surrounding LGS.

8 2.2.9.1. Housing

9 Table 2–7 lists the total number of occupied and vacant housing units, vacancy rates, and 

10 median value in the two-county ROI. According to American Community Survey estimates, 

11 there were approximately 683,000 housing units in the socioeconomic region, of which 

12 approximately 648,000 were occupied. The median value of owner-occupied housing units in 

13 the socioeconomic region was: Berks County, $175,700; Chester County, $350,500; and 

14 Montgomery County, $295,300. All three counties had a homeowner vacancy rate of less than 

15 2 percent (USCB 2011).

16 Table 2–7. Housing in Berks, Chester, and Montgomery Counties in 2010

Berks Chester Montgomery ROI

Total 164,861 192,614 325,733 683,208

Occupied housing units 155,329 184,160 308,233 647,722

Vacant units 9,532 8,454 17,540 35,526

Vacancy rate (percent) 1.2 1.2 1.6 1.3

Median value (dollars) * 175,700 350,500 295,300 273,833

Key: *estimated.

Source: USCB, 2011; 2010 American Community Survey 1-Year Estimates
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1 2.2.9.2. Public Services

2 This section presents information regarding public services including water supply, education, 

3 and transportation.

4 Water Supply 

5 The discussion of public water supply systems is limited to major municipal water systems in 

6 Berks, Chester, and Montgomery Counties. Information about municipal water suppliers in 

7 these counties, their average daily production, system capacity, and population served are 

8 presented in Table 2–8. 

9 Berks County is served by 75 water systems, with the Reading Area Water Authority serving the 

10 largest population at 87,000 (EPA 2012a). Water for this surface water system is primarily 

11 drawn from Lake Ontelaunee, a reservoir built and owned by the city of Reading. The system

12 storage capacity is approximately 76 million gallons (Exelon 2011b). 

13 Chester County is served by 83 water systems, with the Pennsylvania American Water 

14 Company serving the largest population at 44,000 (EPA 2012a). Montgomery County is served 

15 by 39 water systems, with Aqua Pennsylvania, Inc., serving the largest population at 785,000 

16 (EPA 2011). 

17 LGS withdraws water primarily from the Schuylkill River; however, the specific water source(s) 

18 from which LGS makeup water may be withdrawn at any particular time is subject to conditions 

19 and limitations established by the DRBC. The DRBC has jurisdiction over withdrawals and uses 

20 of water in the Delaware River Basin, which includes the Schuylkill Valley Subbasin where LGS 

21 is located (Exelon 2011b). 
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1 Table 2–8. Public Water Supply Systems in Berks, Chester, and Montgomery Counties 

2 (in million gallons per day [mgd])

Water Supplier

Primary 

Water 

Source

Average Daily 

Production 

(mgd)

System 

Capacity 

(mgd)

Population 

Served

Berks County

Reading Area Water Authority SW 14.0 40.0 87,000

Paw Penn District GW 2.5 3.7 29,552

Western Berks Water Authority SW 3.5 8.0 25,000

Paw Glen Alsace Division SW 1.4 28.1 23,251

Muhlenberg Township Municipal Authority GW 4.1 8.5 21,000

Chester County

PA American Water Company Main System SW 2.5 5.8 44,000

PA American Coatesville SW 3.8 8.0 35,600

Aqua PA West Chester SW 5.0 8.0 35,000

Aqua PA Uwchlan SW 2.0 3.2 22,000

Phoenixville Water Department SW 2.5 10.3 16,438

Montgomery County

Aqua Pennsylvania Main System SW 87.6 125.0 784,939

North Penn Water Authority SW 10.0 24.0 82,822

Pennsylvania American Water-Norristown SW 9.6 16.9 91,000

North Wales Water Authority SW 7.4 13.3 68,656

Pottstown Borough water Department SW 6.0 12.0 36,000

Key: Surface Water = SW, Groundwater = GW

Sources: EPA 2012; Exelon 2011a

3 Montgomery County has 22 school districts with 155 schools. LGS is located in the Spring-Ford 

4 Area School District in Montgomery County, Pennsylvania. The Spring-Ford Area School 

5 District has 12 public schools and had a total enrollment of approximately 7,700 students in 

6 2010–2011 (PDE 2011). Berks County has 18 school districts with 108 schools, and Chester 

7 County has 12 school districts with 92 schools (NCES 2011). During the 2010–2011 school 

8 year, public school enrollment in Montgomery County was 108,768 students, with 70,517 and 

9 83,589 students in Berks and Chester Counties, respectively (PDE 2011).

10 Transportation

11 There is a high concentration of Interstates and major roadways in the vicinity of LGS. 

12 Highways and other major roadways within a 50-mile (80-km) radius of LGS include 

13 U.S. Interstates I-78, I-176, I-178, I-276, and I-476, as well as US-30, US-1, and US-422 (known 

14 as “the Pottstown Expressway”). US-422 provides a direct link to Philadelphia, to the east. To 

15 the west, US-422 connects Reading to Lebanon, Harrisburg, and the Capitol region.

16 Montgomery County is traversed by Interstate Highways I-76 (known as the “Schuylkill 

17 Expressway”), I-276 (the East-West Pennsylvania Turnpike), and I-476 (known as the 
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1 “Northeast Extension of the Pennsylvania Turnpike” north of I-276 and as the “Blue Route” or 

2 “Mid-County Expressway” south of I-276). The Northeast Extension can be accessed 

3 approximately 15 miles (24.1 km) east of the LGS plant site. I-76, I-276, and I-476 are about 

4 15 miles (24.1 km) south of LGS and can be accessed by US-422.

5 The LGS plant site can only be accessed by Evergreen Road, either directly from the Sanatoga 

6 exit of US-422 or indirectly from the Limerick Linfield exit of US-422 by several local roads. 

7 US-422 runs northwest from the Sanatoga exit through Pottstown Borough and the City of 

8 Reading, and then continues west through Berks County.

9 Table 2–9 lists common commuting routes to LGS and average annual daily traffic (AADT) 

10 volume values. The AADT values represent traffic volumes for a 24-hour period factored by 

11 both day of week and month of year.

12 Table 2–9. Major Commuting Routes in the Vicinity of LGS, 2010 Average Annual Daily 

13 Traffic Count

Roadway and Location Annual Average Daily 

Traffic (AADT)

Montgomery County

US-422 east of Sanatoga Interchange 49,000

South Pleasantview/Linfield Road, between Evergreen Road and Ridge Pike 1,300–2,500

Linfield Road between Linfield and US-422 6,600

Sanatoga/Limerick Center Road between Evergreen Road and Limerick Road 1,600–1,900

North and South Lewis Road and Main Street from Royersford to US-422 

Limerick-Linfield Interchange 14,000

Main Street Royersford from Linfield Road (bridge) 7,000

Evergreen Road 3,000

Berks County

PA-82/PA-345 from PA-724 Birdsboro to US-422 8,400

PA 662 North of US-422 from Douglassville 8,900

PA-724 from Birdsboro 5,800–7,000

US-422 East of Douglassville/US-422 West of Douglassville 28,000–36,000

Chester County

US-422 West of Armand Hammer Interchange 53,000

PA-100 from PA-23 North to PA-724 17,000–20,000

PA-724 West of PA-100 5,800–7,000

PA-724 East of PA-100 8,900–14,000

Linfield Road (bridge) to Main Street Royersford 5,700

PA-100 South of US-422 25,000

(a) All AADTs represent traffic volume during the average 24-hour day during 2009.

Source: PennDOT 2012

14 2.2.9.3. Offsite Land Use

15 Offsite land use conditions in Berks, Chester, and Montgomery Counties are described in this 

16 section. More than 84 percent of the LGS permanent workforce lives in these three counties. 
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1 Within the region of the LGS, approximately 44 percent of the land is developed urban or rural 

2 land, 32 percent agricultural land, 23 percent woodlands, and 1 percent fresh water bodies 

3 (Exelon 2011b). 

4 Montgomery County occupies approximately 483 square miles (1,251 square km) (USCB 2011). 

5 Agricultural land is used principally as cropland (68.2 percent) and pasture (20.0 percent). Crop 

6 sales (mostly nursery and floriculture products) comprise 63 percent of the total market value of 

7 products sold in the county while livestock products (mostly milk, hogs, and cattle) comprise the 

8 remaining 37 percent. The number of farms in Montgomery County decreased just over 

9 1 percent from 2002 to 2007. Farmland acreage in the county decreased over 13 percent 

10 during the same period, and the average size of a farm decreased 12 percent to 58 ac (23 ha) 

11 (USDA 2009).

12 Chester County occupies approximately 751 square miles (1,945 square km) (USCB 2011). 

13 Agricultural land is used principally as cropland (70.2 percent) and pasture (18.6 percent). Crop 

14 sales (mostly nursery, greenhouse, floriculture, and sod) comprise 73 percent of the market 

15 value of agricultural products sold from the county while livestock sales (mostly milk and poultry 

16 products) comprise the remaining 27 percent. The number of farms in Chester County 

17 decreased from 2002 to 2007 by 9.6 percent. In the same period, the number of farmland acres 

18 decreased by less than 1 percent, however, the average size of farms increased by over 

19 9 percent to 96 ac (39 ha) (NASS 2009).

20 Berks County occupies approximately 857 square miles (2,220 square km) (USCB 2011). 

21 Agricultural land is used principally as cropland (76.9 percent) and pasture (10.7 percent). 

22 Livestock sales (mostly milk and poultry products) comprise 55 percent of the market value of 

23 agricultural products sold from the county while crop sales (mostly nursery, greenhouse, 

24 floriculture, and sod) comprise the remaining 45 percent. The number of farms in Berks County 

25 increased from 2002 to 2007 by 10.2 percent. The number of farmland acres increased nearly 

26 3 percent, however, the average size of farms decreased by over 6 percent to 112 ac (45 ha) 

27 (NASS 2009).

28 Even though population growth is projected to continue, there is ample urban and rural land to 

29 accommodate the anticipated growth over the next 20 years. Agriculture will continue to be the 

30 major land use outside urban areas. 

31 2.2.9.4. Visual Aesthetics and Noise

32 LGS is situated in gently rolling countryside, traversed by numerous valleys containing small 

33 creeks or streams that empty into the Schuylkill River. LGS is surrounded by urbanized areas, 

34 the Borough of Pottstown being the closest at 1.7 miles. Predominate features of the site 

35 include the reactor enclosures, turbine enclosures, two cooling towers (154.2 m high), electrical 

36 substations, independent spent fuel storage installation, Schuylkill River Pumphouse, cooling 

37 tower blowdown discharge line and associated structures, spray pond (17.2 ac), administrative 

38 buildings, and miscellaneous supporting buildings (Exelon 2011b). 

39 Noise from nuclear plant operations can be detected off site. Sources of noise at LGS include 

40 the turbines and large pump motors. Given the industrial nature of the station, noise emissions 

41 from the station are generally nothing more than an intermittent minor nuisance. However, 

42 noise levels may sometimes exceed the 55 dBA level that EPA uses as a threshold level to 

43 protect against excess noise during outdoor activities (EPA 1974). However, according to EPA 

44 this threshold does “not constitute a standard, specification, or regulation,” but was intended to 

45 provide a basis for State and local governments establishing noise standards (EPA 1974). 
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1 2.2.9.5. Demography

2 According to the 2010 Census, an estimated 1,365,850 people live within 32.2 km (20 miles) of 

3 the LGS plant site, producing a population density of 420 persons per square km 

4 (1,087 persons per square mile) (Exelon 2011b). This translates to a Category 4, “least sparse” 

5 population density using the GEIS measure of sparseness (greater than or equal to 120 persons 

6 per square mile within 20 miles). Approximately 8,311,616 people live within 80.4 km (50 miles) 

7 of LGS, which equates to a population density of 409 persons per square km (1,058 persons 

8 per square mile) (Exelon 2011b). As the ROI has a population greater than or equal to 

9 190 persons per square mile within 80.4 km (50 miles), this translates to a Category 4 (greater 

10 than or equal to 190 persons per square mile within 50 miles). Therefore, LGS is classified as 

11 being located in a high population area based on the GEIS sparseness and proximity matrix. 

12 Table 2–10 shows population projections and growth rates from 1970 to 2050 in Berks, Chester, 

13 and Montgomery Counties in Pennsylvania. All counties experienced an increased growth rate 

14 during the 2000 to 2010 time period. Montgomery County showed the smallest population 

15 increase between 2000 and 2010 (6.6 percent). All three county populations are expected to 

16 continue to increase at lower rates in the next decades through 2050.

17 Table 2–10. Population and Percent Growth in Berks, Chester, and Montgomery Counties 

18 from 1970 to 2000 and Projected for 2010-2050

Berks Chester Montgomery

Year Population

Percent 

Change(a) Population

Percent 

Change(a) Population

Percent 

Change(a)

1970 296,382 – 278,311 – 623,799 –

1980 312,497 5.4 316,660 13.8 643,621 3.2

1990 336,523 7.7 376,396 18.9 678,111 5.4

2000 373,638 11.0 433,501 15.2 750,097 10.6

2010 411,442 10.1 498,886 15.1 799,874 6.6

2020 450,718 9.5 604,385 21.1 854,994 6.9

2030 491,914 9.1 692,054 14.5 888,265 3.9

2040 531,830 8.1 791,610 14.4 936,102 5.4

2050 572,066 7.6 888,194 12.2 980,298 4.7

(a) Percent growth rate is calculated over the previous decade.

Sources: Population data for 1970 through estimated population data for 2009 (USCB 2011); population projections 

for 2012 to 2030 by Pennsylvania State Data Center, October 2010 (PASDC, 2010); 2040 to 2050 calculated.

19 Demographic Profile

20 The 2010 (estimate) demographic profiles of the three-county ROI population are presented in 

21 Table 2–11. In 2010, minorities (race and ethnicity combined) comprised 20.6 percent of the 

22 total three-county population. The largest minority populations in the three county area are 

23 Hispanic or Latino (7.8 percent) and Black or African American (6.6 percent).
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1 Table 2–11. Demographic Profile of the Population in the Limerick Generating Station 

2 Socioeconomic Region of Influence in 2010

Berks Chester Montgomery

Region of 

Influence

Population 411,142 498,886 799,874 1,710,202

Race (Not Hispanic or Latino) - percent of total population

White 76.9 82.1 79.0 79.4

Black or African American 4.0 5.9 8.4 6.6

American Indian and Alaska Native 0.1 0.1 0.1 0.1

Asian 1.3 3.9 6.4 4.4

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 0.0

Some other race 0.1 0.1 0.2 0.1

Two or more races 1.2 1.4 1.6 1.4

Ethnicity

Hispanic or Latino 67,355 32,503 34,233 134,091

Percent of total population 16.4 6.5 4.3 7.8

Total minority 95,036 89,325 168,090 352,451

Percent minority 23.1 17.9 21.0 20.6

Source: USCB 2011

3 Transient Population

4 Within 50 miles (80 km) of LGS, colleges and recreational opportunities attract daily and 

5 seasonal visitors who create demand for temporary housing and services. In 2010, there were 

6 approximately 354,728 students attending colleges and universities within 50 miles (80 km) of 

7 LGS (NCES 2011).

8 In 2010, all three counties in the direct ROI had a similar percentage of temporary housing for 

9 seasonal, recreational, or occasional use; Berks at 0.4 percent, Chester at 0.6 percent and 

10 Montgomery at 0.5 percent (USCB 2011). In comparison, the highest percent of temporary 

11 housing for seasonal, recreational, or occasional use in the counties located within 50 miles 

12 (80 km) of LGS is Monroe County, Pennsylvania, at 16.9 percent (UCSB 2010). Table 2–12 

13 provides information on seasonal housing for the 26 counties located all or partly within 50 miles

14 (80 km) of LGS.
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1 Table 2–12. Seasonal Housing in Counties Located within 50 Miles (80 Km) of the 

Limerick Generating Station(a) 2 

County

Housing Units: 

Total

Vacant Housing Units: For Seasonal; 

Recreational; or Occasional Use Percent

Pennsylvania

Berks 164,827 724 0.4

Bucks 245,956 1,536 0.6

Carbon 34,299 5,033 14.7

Chester 192,462 1,064 0.6

Delaware 222,902 621 0.3

Lancaster 202,952 930 0.5

Lebanon 55,592 506 0.9

Lehigh 142,613 663 0.5

Monroe 80,359 13,590 16.9

Montgomery 325,735 1,498 0.5

Northampton 120,363 755 0.6

Philadelphia 670,171 2,228 0.3

Schuylkill 69,323 1,360 2.0

York 9,870 1,117 11.3

County Subtotal 2,537,424 31,625 1.2

Maryland

Cecil 41,103 1,912 4.7

Harford 95,554 451 0.5

County Subtotal 136,657 2,363 1.7

New Jersey

Burlington 175,615 696 0.4

Camden 204,943 551 0.3

Cumberland 55,834 627 1.1

Gloucester 109,796 316 0.3

Hunterdon 49,487 512 1.0

Mercer 143,169 558 0.4

Salem 27,417 150 0.5

Somerset 123,127 173 0.1

Warren 44,925 457 1.0

County Subtotal 934,313 4,040 0.4

Delaware

New Castle 217,511 712 0.3

Total 3,825,905 38,740 1.0

(a) Counties within 50 miles (80 km) of LGS with at least one block group located within the 50-mile (80-km) radius

Source: USCB 2011
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1 Migrant Farm Workers

2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

3 crops. These workers may or may not have a permanent residence. Some migrant workers 

4 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 

5 Others may be permanent residents near LGS who travel from farm to farm harvesting crops.

6 Migrant workers may be members of minority or low-income populations. Because they travel 

7 and can spend a significant amount of time in an area without being actual residents, migrant 

8 workers may be unavailable for counting by census takers. If uncounted, these workers would 

9 be “underrepresented” in USCB minority and low-income population counts.

10 Information on migrant farm and temporary labor was collected in the 2007 Census of 

11 Agriculture. Table 2–13 provides information on migrant farm workers and temporary farm labor

12 (less than 150 days) within 50 miles (80 km) of the LGS. According to the 2007 Census of 

13 Agriculture, approximately 6,205 farm workers were hired to work for less than 150 days and 

14 were employed on 6,324 farms within 50 miles (80 km) of LGS. Pennsylvania had the largest 

15 number of farms hiring workers for less than 150 days (1,212), with Chester County containing 

16 the largest number of farms hiring workers for less than 150 days at 580.

17 In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 

18 any hired migrant workers, defined as a farm worker whose employment required travel that 

19 prevented the migrant worker from returning to their permanent place of residence the same 

20 day. A total of 528 farms in the 50-mile (80-km) radius of LGS reported hiring migrant workers 

21 in the 2007 Census of Agriculture. Chester County, Pennsylvania, hired the largest number of 

22 migrant workers at 101, followed by Cumberland County, New Jersey (65) (USDA 2011).

23 In the direct ROI, 591 temporary farm workers (those working fewer than 150 days per year) 

24 were employed on 458 farms in Berks County; 652 temporary farm workers (those working 

25 fewer than 150 days per year) were employed on 580 farms in Chester County; 208 temporary 

26 farm workers (those working fewer than 150 days per year) were employed on 105 farms in 

27 Montgomery County (USDA 2011).
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1 Table 2–13. Migrant Farm Workers and Temporary Farm Labor in Counties Located 

2 within 50 Miles (80 Km) of Limerick Generating Station

County(a)

Number of 

Farms with Hired 

Farm Labor(b)

Number of Farms 

Hiring Workers for 

Less Than 

150 days(b)

Number of Farm 

Workers Working 

for Less Than 

150 days(b)

Number of Farms 

Reporting Migrant 

Farm Labor(b)

Pennsylvania

Berks 458 180 591 32

Bucks 265 100 375 23

Carbon 27 12 59 6

Chester 580 233 653 101

Delaware 25 8 15 2

Lancaster 1,716 60 138 7

Lebanon 324 137 317 6

Lehigh 118 44 161 5

Monroe 155 23 66 0

Montgomery 155 71 208 14

Northampton 97 24 89 2

Philadelphia 5 2 (D) 0

Schuylkill 165 100 323 12

York 404 218 657 22

County Subtotal 4,494 1,212 3,652 232

Maryland

Cecil 128 52 213 5

Harford 155 62 154 12

County Subtotal 283 114 367 17

New Jersey

Burlington 217 93 326 39

Camden 52 25 85 17

Cumberland 192 60 230 65

Gloucester 163 57 216 56

Hunterdon 283 144 353 18

Mercer 86 39 102 8

Salem 172 71 248 33

Somerset 132 52 147 6

Warren 169 94 321 27

County Subtotal 1,466 635 2,028 269

Delaware

New Castle 81 34 158 10

Total 6,324 1,995 6,205 528

(a) Counties within 50 miles (80 km) of LGS with at least one block group located within the 50-mile (80-km) radius. (b) Table 7. Hired farm Labor – Workers and Payroll: 2007.

(D) – Withheld to avoid disclosing data for individual farms.

Source: 2007 Census of Agriculture – County Data (USDA 2009)
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1 2.2.9.6. Economy

2 This section contains a discussion of the economy, including employment and income, 

3 unemployment, and taxes.

4 Employment and Income

5 Between 2000 and 2010, the civilian labor force in Berks, Chester, and Montgomery Counties 

6 increased slightly. Chester County experienced the highest percentage of growth with 

7 10.2 percent (229,469 civilian worker to 252,993), while Berks and Montgomery experienced a 

8 similar growth of civilian labor force by 1.4 percent (190,552 civilian workers to 193,364) and 

9 2.2 percent (402,653 civilian workers to 411,517),respectively (USCB 2000, 2010).

10 In 2010, educational, health, and social services represented the largest sector of employment 

11 (24.4 percent) in the ROI followed by manufacturing and (13.2 percent) and professional,

12 scientific, management, administration, and waste management (13 percent). A list of some of 

13 the major employers by industry in each county and the ROI area is provided in Table 2–14. 

14 Table 2–14. Major Employers by Industry in the LGS ROI in 2010

Industry Berks Chester Montgomery Total Percent

Total employed civilian workers 193,364 252,993 411,517 857,874

Construction 10,555 12,814 23,472 46,841 5.5

Manufacturing 32,843 33,512 47,202 113,557 13.2

Wholesale Trade 6,246 7,384 12,669 26,299 3.1

Retail Trade 21,699 28,157 43,224 93,080 10.9

Transportation, warehousing, and utilities 9,077 8,482 14,631 32,190 3.8

Information 3,462 4,615 9,183 17,260 2.0

Finance, insurance, 

real estate, rental, and leasing 10,613 24,447 41,825 76,885 9.0

Professional, scientific, management, 

administrative, and waste management 

services

 16,398 36,113 58,720 111,231 13.0

Educational, health, and social services 49,407 57,072 102,572 209,051 24.4

Arts, entertainment, recreation, 

accommodation, and food services 14,904 17,876 26,997 59,777 7.0

Other services (except public

administration) 10,856 10,254 17,919 39,029 4.5

Public administration 4,021 5,522 11,353 20,896 13.2

Source: UCSB 2011

15 The top eight employers in Montgomery County are listed in Table 2–15. King of Prussia 

16 currently houses the largest number of private sector employers (SGP 2007).
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1 Table 2–15. Largest Private Sector Employers – Montgomery County – 2007

Company Industry

Number of 

Employees

Merck & Company Pharmaceutical and Vaccines: Global R&D HQ 12,000 

Abington Memorial Hospital Hospitals, General Market and Surgical 5,896 

Allied Barton Security Services Security, Integrated Asset Protection 5,160 

Northwestern Human Services Outpatient Mental Health and Substance Abuse 

Centers 4,000 

Lockheed Martin Systems Integrations, Systems Engineering, Software 

Development, and Program Management 3,700 

Aetna Managed Care, Health Insurance 3,000 

Unisys Information and Technology Solutions and Services 3,400 

Citizens Bank Commercial Banking 3,000 

Source: SGP 2007

2 Estimated income information for the socioeconomic ROI and Pennsylvania is presented in 

3 Table 2–16. According to the U.S. Census Bureau’s 2010 American Community Survey 1-Year 

4 Estimates, people living in the ROI had median household and per capita incomes above the 

5 state average. Chester County had the highest median household and per capita income 

6 among the three counties. Berks County has the highest percentages of persons (14.1 percent) 

7 living below the official poverty level when compared to the other two counties and the 

8 Commonwealth as a whole. Chester and Montgomery Counties had 6.2 and 5.5 percent, 

9 respectively, and the Commonwealth of Pennsylvania as a whole had 13.4 percent. The 

10 percentage of families living below the poverty level in Chester and Montgomery Counties 

11 (3.6 percent) was lower than the percentage of families in Berks County and the Commonwealth 

12 of Pennsylvania as a whole (9.3 percent and 10.9 percent, respectively) (USCB 2011).

13 Table 2–16. Estimated Income Information for the Limerick Generating Station Region of 

14 Influence in 2010

Berks Chester Montgomery Pennsylvania

Median household income (dollars)a 51,719 84,284 75,448 49,288

Per capita income (dollars)a 25,384 40,138 38,792 26,374

Individuals living below the poverty level (percent) 14.1 6.2 5.5 13.4

Families living below the poverty level (percent) 10.9 3.6 3.6 9.3

(a) In 2010 inflation-adjusted dollars.

Source: USCB 2011

15 Unemployment

16 According to the U.S. Census Bureau’s 2010 American Community Survey 1-Year Estimates, 

17 the unemployment rates in 2010 were: Berks County, 10.2 percent; Chester County, 

18 6.2 percent; and Montgomery County, 7.3 percent. Comparatively, the Commonwealth of 

19 Pennsylvania’s unemployment rate during the same time period was 9.6 percent (USCB 2011). 
Purpose and Need for Action

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1 Taxes

2 Exelon pays real estate taxes directly to local taxing authorities for the parcels of company3 owned property located within its tax jurisdiction. The taxing authorities include the counties, 

4 municipalities, and school districts in which these properties are located. LGS parcels are 

5 located only in Montgomery, Chester, and Bucks Counties. There are no LGS parcels located 

6 in Berks County.

7 Exelon is the sole owner of the LGS plant site along with the following components of the LGS 

8 makeup water supply system, which include the Perkiomen Pumphouse, the Bradshaw 

9 Reservoir; the Bradshaw Pumphouse; and the Bedminster Water Processing Facility. PECO, 

10 rather than Exelon, owns or has rights to the LGS transmission system beyond the two onsite 

11 substations (Exelon 2011b). 

12 The discussion of taxes in this section is limited to the taxes paid by Exelon, because taxes paid 

13 by PECO for the LGS transmission system would continue, whether or not the LGS operating 

14 licenses are renewed.

15 Table 2–17 shows the tax payments made by Exelon for LGS from years 2006–2010. 

16 Table 2–18 lists the 2010 budgets for each of the LGS taxing authorities and the percentages of 

17 the 2010 budget represented by LGS tax payments. The budgets are funded through payments 

18 made to the local government jurisdictions either directly (e.g., property tax payments) or 

19 indirectly (e.g., state tax and revenue-sharing programs). In all cases, the LGS property tax 

20 payments represent a small percentage (generally 3.1 percent or less) of the budget for each of 

21 the taxing authorities (Exelon 2011b). 

22 Currently, Exelon pays the majority of its annual real estate taxes to Limerick 

23 Township/Montgomery County and the Spring-Ford Area School District because most of the 

24 taxable Exelon-owned LGS assets are located in Limerick Township. Limerick Township 

25 provides a portion of these taxes to Montgomery County to fund county services such as county 

26 operations, the judicial system, public safety, public works, cultural and recreational programs, 

27 human services, and conservation and development programs. Limerick Township property tax 

28 revenues fund various operations, including libraries, hospitals, roads, school districts, and fire 

29 departments. The Exelon payments to Limerick Township and the Spring-Ford Area School 

30 District represent approximately 3.1 percent of the Township’s budget and 2.2 percent of the 

31 School District’s budget, respectively (Exelon 2011b). 

32 Real estate taxes paid by Exelon to the following taxing authorities represent less than 

33 1 percent of each of their respective budgets:

34  Lower Pottsgrove Township/Montgomery County and the Pottsgrove School 

35 District,

36  East Coventry Township/Chester County and the Owen J. Roberts School 

37 District,

38  Plumstead Township/Bucks County and the Central Bucks School District, 

39 and

40  Bedminster Township/Bucks County and the Pennridge School District.
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1 Table 2–17. Limerick Generation Station Tax Distribution, 2006–2010

Calendar Year

2006 2007 2008 2009 2010

Montgomery County

Limerick Township 368,376 402,404 479,143 495,044 466,315

Spring-Ford Area School District 2,340,454 2,184,627 2,193,537 2,429,533 2,271,282

Lower Pottsgrove Township 1,802 1,849 1,797 1,817 1,804

Pottsgrove School District 10,482 10,943 11,479 11,988 12,271

Total 2,721,114 2,599,823 2,685,956 2,938,382 2,751,672

Chester County

Chester County 6,207 6,383 6,383 6,654 6,654

East Coventry Township 2,517 2,517 5,319 5,034 5,035

Owen J. Roberts School District 39,052 40,210 41,770 42,794 43,919

Total 47,776 49,110 53,472 54,482 55,608

Bucks County

Plumstead Township 6,481 6,481 6,481 6,481 7,372

Central Bucks School District 21,373 22,178 23,148 24,048 24,971

Bedminster Township 5,097 4,920 4,920 4,920 4,920

Pennridge School District 17,461 18,664 19,484 19,977 20,557

Total 50,412 52,243 54,033 55,426 57,820

Total Taxes 2,819,302 2,701,176 2,793,461 3,048,290 2,865,100

Source: Exelon 2011
Purpose and Need for Action

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1 Table 2–18. Payment as a Percentage of Taxing Authority 2010 Adopted Budget

Taxing Authority

2010 Adopted Budget 

($ millions)a

LGS Property Tax Payment as 

Percentage of Budgetb

Montgomery County

Montgomery County – Through Limerick 

Township 407.7 Less than 0.1%

Limerick Township 14.5 3.1%

Spring-Ford Area School District 125.5 2.2%

Montgomery County – Through Lower 

Pottsgrove Township 403.9 Less than 0.1%

Lower Pottsgrove Township 5.4 Less than 0.1%

Pottsgrove School District 56.8 Less than 0.1%

Chester County

Chester County 420.7 Less than 0.1%

East Coventry Township 3.2 Less than 0.1%

Owen J. Roberts School District 103.0 Less than 0.1%

Bucks County

Bucks County – Through Plumstead 

Township 460.1 Less than 0.1%

Plumstead Township 4.3 0.17%

Central Bucks School District 283.2 Less than 0.1%

Bucks County – Through Bedminster 

Township 460.1 Less than 0.1%

Bedminster Township 2.0 0.2%

Pennridge School District 111.4 Less than 0.1%

(a) Municipal budget is for calendar year; school district budget is for school year 2010–2011.

(b) Percentages are based on 2010 LGS property tax payments shown in Table 2–17.

Source: Exelon 2011a

2 2.2.10. Historic and Archaeological Resources

3 In accordance with 36 CFR 800.8(c), the NRC has elected to coordinate compliance with 

4 Section 106 of the National Historic Preservation Act (NHPA) with steps it has taken to meet its 

5 requirements under NEPA. In addition, NUREG–1555 (NRC 2000) provides guidance to staff 

6 on how to conduct historic and cultural resource analysis in its environmental reviews.

7 In the context of NHPA, the NRC has determined that the area of potential effect (APE) for a 

8 license renewal action is the area at the power plant site and its immediate environment that 

9 may be affected by post-license renewal and land-disturbing activities associated with the 

10 proposed action (NRC 2011a) The APE may extend beyond the immediate environs in 

11 instances where post-license renewal and land-disturbing activities or refurbishment activities 
Purpose and Need for Action

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1 specifically related to license renewal may potentially have an effect on historic properties 

2 (NRC 2011a). Figure 2–3 shows the area under review. 

3 2.2.10.1. Cultural Background

4 This section discusses the cultural background and the known historic and archaeological 

5 resources at the LSG site and in the surrounding area. The cultural background for the State of 

6 Pennsylvania has been characterized by the staff in the following license renewal environmental 

7 impact statements and therefore, will be briefly described in this section:

8  Generic Environmental Impact Statement for License Renewal of Nuclear 

9 Plants, Supplement 10, Regarding Peach Bottom Nuclear Reactor, Units 2 

10 and 3, January 2003 (NRC 2003)

11  Generic Environmental Impact Statement for License Renewal of Nuclear 

12 Plants, Supplement 35, Regarding Susquehanna Steam Electric Station, 

13 Units 1 and 2, March 2009 (NRC 2009a)

14  Generic Environmental Impact Statement for License Renewal of Nuclear 

15 Plants, Supplement 36, Regarding Beaver Valley Power Station, Units 1 and 

16 2, May 2009 (NRC 2009b)

17  Generic Environmental Impact Statement for License Renewal of Nuclear 

18 Plants, Supplement 37, Regarding Three Mile Island Nuclear Station, Unit 1, 

19 June 2009 (NRC 2009c)

20 The Paleo-Indian Period occurred approximately 10,000 to 15,000 years ago. The 

21 Paleo-Indians were hunters and gathers and this period is largely characterized by the Clovis 

22 point (NRC 2009a).

23 The Early Archaic Period occurred approximately 3,000 to 10,000 years ago. As the glaciers 

24 retreated northward, larger fauna became extinct and people adapted to the resources in the 

25 surrounding environment. As the resources improved, the population of the Archaic people 

26 increased. Recent archaeological evidence suggests larger populations by the end of the 

27 Archaic era (NRC 2009a). 

28 The Woodland Period occurred approximately 3,000 years ago until the point of European 

29 contact. The Woodland Period is characterized by being dependent on maize agriculture, 

30 people living in villages, and the introduction of the bow and arrow for hunting (NRC 2009a).

31 The Late Woodland peoples were known as the Delaware, Nanticoke, Shawnee, Iroquois, and 

32 Susquehannock (NRC 2009a). Early Native American contact with European colonists and 

33 events associated with that contact make it difficult to associate present-day tribal groups with 

34 the territory in the vicinity of the LGS site. The contacts led to tribal movements, alliances with 

35 either the French or English, armed conflicts, epidemics, shifting inter-tribal confederacies, and 

36 eventual removal, or extinction in some cases, as the European expansion took place 

37 (NRC 2003).

38 The historic period can be traced to 1681 when King Charles II granted William Penn a charter 

39 for a tract of land running from the Delaware River toward Maryland. William Penn founded the 

40 City of Philadelphia, which contained 600 houses by 1685. William Penn also established 

41 Chester, Bucks, and Philadelphia Counties in 1682. The earliest colonists were farmers. 

42 Milling, distilling, and other processing industries were established along streams. A dramatic 

43 increase in the development of political organization and infrastructure can be seen through the 

44 period of 1784 to 1870. Because efficient means of transportation were needed to support the 

45 movement of settlers westward, turnpikes, canals, and railways were built. 
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1 The Schuylkill Navigation Company constructed a canal system between Philadelphia and the 

2 coal fields of Schuylkill County. The canal opened in 1824 and ran from south of Reading to 

3 Parker Ford, following the west bank of the Schuylkill River through land that is currently LGS 

4 property. The canal development spurred the farming industry in the area and, from 1857 to 

5 1937, a farming and commercial center arose around the locks. Locks 54, 55, and a two-story 

6 stone lockkeeper’s house (now part of Fricks Lock Historic District) were built by the canal 

7 company on property owned by John Frick (Exelon 2011b). 

8 The Philadelphia and Reading Railroad, which also passed through land that is now on LGS 

9 property, ran along the east bank of the Schuylkill River. It was one of the first railroads built in 

10 the Unites States and was completed in 1843. The Reading Company, an owner of the railroad, 

11 operated successfully until 1971 when it declared bankruptcy. Another railroad line, the 

12 Schuylkill Branch of the Pennsylvania Railroad, was built along the western bank of the river in 

13 1884. It served primarily as a commuter line, but was abandoned by the 1950s (Exelon 2011b). 

14 2.2.10.2. Historic and Cultural Resources at the Limerick Generating Station Site

15 The following information was used to identify the historic and cultural resources at the LGS 

16 site:

17  original construction FES (NRC 1973), 

18  original operating FES (NRC 1984), 

19  Exelon, Applicant’s Environmental Report, Operating License Renewal State, 

20 LGS Units 1 & 2 (Exelon 2011b),

21  site audit (NRC 2012a), 

22  LGS, request for additional information (Exelon 2012b), 

23  consultation with Pennsylvania BHP, and

24  consultation with tribes. 

25 Exelon’s ER describes the cultural resources investigations that occurred on the LGS site for 

26 the initial construction and operation of LGS Units 1 and 2 (Exelon 2011b). An archaeological 

27 survey of the LGS plant site was conducted to identify prehistoric archaeological resources and, 

28 as a result, four areas of occupation were identified. Three were located on the western shores 

29 of the Schuylkill River, in the vicinity of Fricks Locks, and are identified as 36CH38, 36CH103, 

30 and 36CH364. The other site was recorded on the eastern side of the Schuylkill and is 

31 recorded as site 36MG37. The artifacts associated with these sites were those associated with 

32 the Archaic, Early Woodland, and Middle Woodland cultural periods (Exelon 2011b)

33 On October 5, 1983, the BHP stated that the operations of “LGS would have no effect on 

34 significant historic or archaeological resources provided that archaeological surveys/mitigation 

35 were undertaken for the proposed transmission lines and provided that measures were taken to 

36 mitigate visual impacts to historic sites” (Exelon 2011b). The mitigation measures were 

37 reviewed and approved by the BHP. Archaeological surveys were conducted for the five

38 transmission system lines: Lines 220-60, 220-61, 220-62, 220-63/64, and 5031, and the results 

39 of these surveys are summarized in Exelon’s ER (Exelon 2011b). 

40 In 2011 the NRC performed a query of the Pennsylvania Cultural Resources Geographic 

41 Information System, a database maintained by the State of Pennsylvania through its BHP office, 

42 to identify historic and archaeological resources and their NRHP determinations within the APE 

43 and surrounding area. A total of 164 aboveground historic resources and 3 archeological sites 

44 are listed on the NRHP in Montgomery County, and 380 aboveground historic resources and 

45 6 archeological sites are listed in Chester County. Directly within the APE, the query noted two 
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1 aboveground historic resources and six archeological sites. All eight sites are located within the 

2 LGS owner-controlled area. The six archaeological resource sites are recorded as 36MG37, 

3 36CH37, 36CH38, 36CH103, 36CH364, and 36CH382, and date to the prehistoric time period. 

4 The aboveground historic resources are recorded as the Fricks Locks Historic District and the 

5 Schuylkill Navigation Company Canal, and both could contain associated archaeological 

6 material (Exelon 2011a, 2012b).

7 Site 36MG37 (Underpass Site), a multi-component 44-acre site, extends along the eastern 

8 terrace of the Schuylkill River. The site reflects evidence from the Middle Archaic through 

9 Transitional Archaic periods, along with Late Woodland. Because of insufficient data, no 

10 determination has been made for eligibility for inclusion in the National Register of Historic 

11 Places (NRHP) (Exelon 2012b).

12 Site 36CH37 (Warehouse Field) is located upland to the west of the Schuylkill River. Evidence 

13 suggests the site is from the Late and Transitional Archaic period. NRHP eligibility has not been 

14 determined (Exelon 2012b).

15 Site 36CH38 (Turkey Point House), an 8-acre prehistoric site, is located on the west side of the 

16 Schuylkill River and is commonly referred to as the Turkey Point House site. NRHP eligibility 

17 has not been determined (Exelon 2012b)

18 Site 36CH103 (Fricks Lock Site), a 22-acre site, is located on the west terrace of the Schuylkill 

19 River, directly east of the Fricks Lock Historic District. It is commonly referred to as the Fricks 

20 Lock site. Evidence collected from the site suggests Archaic and Early Woodland occupations. 

21 Data recovery was performed at the site; however, the NRHP status is listed as undetermined 

22 (Exelon 2012b). 

23 Site 36CH364 (Payne #1) is located south of site 36CH103 and is approximately 2 acres. No 

24 specific components were noted, other than the site was prehistoric and the NRHP eligibility 

25 was undetermined (Exelon 2012b). 

26 Site 36CH382 (Locus 25) was recorded through an archaeological survey for transmission 

27 line 220-61 and the site is listed as Late Archaic. “Subsurface testing was conducted, but did 

28 not provide sufficient data for NRHP eligibility determination” (Exelon 2012b). 

29 The Fricks Locks Historic District is 18 acres. Its buildings were built between 1757 and 1937 

30 as part of a farming hamlet. The site was listed on the NRHP in 2003 under Criteria A (local 

31 historical significance) and C (engineering significance) and the eligibility under Criterion D 

32 (information potential) has not been determined (Exelon 2012b). The district contains historic 

33 buildings, the Schuylkill Navigation Company’s Girard Canal, the filled-in remains of Locks 54 

34 and 55, and the Lock Keeper’s House (Exelon 2012b). Currently, Exelon is working with East 

35 Coventry Township and Chester County to rehab and mothball the site. The rehabilitation and 

36 mothballing activities are specified to meet the Secretary of Interior’s Standards for 

37 Rehabilitation and construction activity is expected to begin in 2012 (Exelon 2012b). In addition 

38 to historic archaeological deposits, prehistoric artifacts have been produced within the 

39 boundaries of the Fricks Locks Historic District (Exelon 2012b). 

40 The Schuylkill Navigation Company Canal was determined eligible for listing in the NRHP in 

41 2003 under Criteria A (local historical significance) and C (engineering significance) 

42 (Exelon 2012b). The 5-mile section of the canal, Locks 52-53 and Locks 54-55, originally was 

43 part of the 17-mile-long Girard Lock. “There are several intact remnants of the canal in this 

44 NRHP-eligible linear resource. However, the canal prism (channel) and Fricks Locks Historic 

45 District are the only canal-related resources recorded within the LGS property” (Exelon 2012b).
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1 2.2.10.3. Consultation 

2 In September 2011, the NRC initiated consultation on the proposed action with the Advisory 

3 Council on Historic Preservation, Pennsylvania’s Bureau of Historic Preservation, and 

4 15 Federally recognized tribes. An overview of consultation activities that occurred during the 

5 preparation of the SEIS is given in Section 4.9.6. 

6 2.3. Related Federal and State Activities

7 The staff reviewed the possibility that activities of other Federal agencies might affect the 

8 renewal of the operating license for LGS. Any such activity could result in cumulative 

9 environmental impacts and the possible need for a Federal agency to become a cooperating 

10 agency in the preparation of NRC’s SEIS for LGS. 

11 There are no Federal projects that would make it necessary for another Federal agency to 

12 become a cooperating agency in the preparation of this SEIS. There are no known American 

13 Indian lands within 50 miles (80 km) of LGS. The only Federally owned facility within 50 miles 

14 (80 km) of LGS is Valley Forge National Park. 

15 The NRC is required, under Section 102(2)(c) of NEPA, to consult with and obtain the 

16 comments of any Federal agency that has jurisdiction by law or special expertise with respect to 

17 any environmental impact involved. The NRC has consulted with the FWS, the NMFS, and the 

18 State of Pennsylvania SHPO. Federal agency consultation correspondence is listed in 

19 Appendix D.

20 2.4. References

21 7 CFR Part 657. Code of Federal Regulations, Title 7, Agriculture, Part 657, “Prime and unique 

22 farmlands.”

23 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

24 protection against radiation.”

25 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

26 production and utilization facilities.”

27 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

29 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

30 requirements for land disposal of radioactive waste.”

31 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

32 transportation of radioactive material.”

33 10 CFR Part 72. Code of Federal Regulations, Title 51, Energy, Part 72, “Licensing 

34 requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, 

35 and reactor-related greater than Class C waste.” 

36 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor site 

37 criteria.”

38 18 CFR Part 410. Code of Federal Regulations, Title 18, Conservation of Power and Water 

39 Sources, Part 410, “Basin regulations; water code and administrative manual part III water 

40 quality regulations.” 
Purpose and Need for Action

2-85

1 18 CFR Part 430. Code of Federal Regulations, Title 18, Conservation of Power and Water 

2 Sources, Part 430, “Ground water protected area: Pennsylvania.”

3 36 CFR Part 800. Code of Federal Regulations. Title 36, Parks, Forests, and Public Property, 

4 Part 800, “Protection of historic properties.” 

5 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of the Environment, Part 50, 

6 “National primary and secondary ambient air quality standards.”

7 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

8 “Designation of areas for air quality planning purposes.”

9 40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112, 

10 “Oil pollution prevention.”

11 40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, 

12 “National primary drinking water regulations.”

13 40 CFR Part 143. Code of Federal Regulations, Title 40, Protection of Environment, Part 143, 

14 “National secondary drinking water regulations.”

15 40 CFR Parts 239–259. Code of Federal Regulations, Title 40, Protection of Environment, 

16 Parts 239–259, “Solid (nonhazardous) waste.”

17 40 CFR Parts 239–299. Code of Federal Regulations, Title 40, Protection of Environment, 

18 Parts 239–299, “Solid wastes” and “Resource Conservation Recovery Act (RCRA).”

19 40 CFR Part 260. Code of Federal Regulations, Title 40, Protection of Environment, Part 260, 

20 “Hazardous waste management system: general.”

21 40 CFR Parts 260–279. Code of Federal Regulations, Title 40, Protection of Environment, 

22 Parts 260–279, “Hazardous waste.”

23 40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of Environment, Part 261, 

24 “Identification and listing of hazardous waste.”

25 40 CFR Part 262. Code of Federal Regulations, Title 40, Protection of Environment, Part 262, 

26 “Standards applicable to generators of hazardous waste.”

27 40 CFR Part 266. Code of Federal Regulations, Title 40, Protection of Environment, Part 266, 

28 “Standards for the management of specific hazardous wastes and specific types of hazardous 

29 waste management facilities.”

30 50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, “General 

31 provisions.”

32 50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, “Eagle 

33 permits.”

34 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

35 “Interagency cooperation—Endangered Species Act of 1973, as amended.”

36 32 FR 4001. U.S. Fish and Wildlife Service. Native fish and wildlife; endangered species. 

37 Federal Register 32(48):4001. March 11, 1967. Available at 

38 <http://ecos.fws.gov/docs/federal_register/fr18.pdf> (accessed 10 May 2012).

39 41 FR 41914. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, 

40 determination of critical habitat for American crocodile, California condor, Indiana bat, and 

41 Florida manatee. Federal Register 41(187):41914–41916. September 24, 1976. Available at 

42 <http://ecos.fws.gov/docs/federal_register/fr115.pdf> (accessed 8 May 2012).
Purpose and Need for Action

2-86

1 47 FR 39827. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants, 

2 determination of Isotria medeoloides (small-whorled pogonia) to be an endangered species. 

3 Federal Register 47(178):39827–39831. September 9, 1982. Available at 

4 <http://ecos.fws.gov/docs/federal_register/fr621.pdf> (accessed 10 May 2012).

5 62 FR 59605. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 

6 final rule to list the northern population of the bog turtle as threatened and the southern 

7 population as threatened due to similarity of appearance. Federal Register 62(213): 

8 59605–59623. November 4, 1997. Available at 

9 <http://ecos.fws.gov/docs/federal_register/fr3175.pdf> (accessed 10 May 2012).

10 63 FR 31268. U.S. Environmental Protection Agency. Emergency planning and community 

11 right-to-know programs; amendments to hazardous chemical reporting thresholds, streamlining 

12 requirements; proposed rule. Federal Register 63(109):31268–31317. June 8, 1998. Available 

13 at <http://www.gpo.gov/fdsys/pkg/FR-1998-06-08/pdf/98-14490.pdf> (accessed April 2012).

14 75 FR 9282. U.S. Fish and Wildlife Service. General provisions; revised list of migratory birds. 

15 Federal Register 75(39):9282–9314. March 1, 2010.

16 77 FR 5880. National Oceanic and Atmospheric Administration. Endangered and threatened 

17 wildlife and plants; threatened and endangered status for distinct population segments of 

18 Atlantic Sturgeon in the Northeast region.” Federal Register 77(24):5880-5912. 

19 February 6, 2012. 

20 77 FR 17341. U.S. Environmental Protection Agency. Approval and promulgation of air quality 

21 implementation plans; Delaware, Maryland, New Jersey, and Pennsylvania; determinations of 

22 attainment of the 1997 8-hour ozone standard for the Philadelphia-Wilmington-Atlantic City

23 moderate nonattainment area. Federal Register 77(58):17341–17344. March 26, 2012.

24 77 FR 18987. U.S. Environmental Protection Agency. Approval and promulgation of air quality 

25 implementation plans; Pennsylvania; nonattainment new source review; fine particulate matter 

26 (PM2.5). Federal Register 77(61):18987–18990. March 29, 2012.

27 17 Pa. Code 45. Pennsylvania Code, Title 17, Conservation and Natural Resources, 

28 Chapter 45, “Conservation of Native Wild Plants.” January 1, 1988. Pennsylvania Department of 

29 Conservation and Natural Resources.

30 25 Pa. Code 92a. Pennsylvania Administrative Code, Part 1, Department of Environmental 

31 Protection, Title 25, Environmental Protection, Chapter 92a, “National Pollutant Discharge 

32 Elimination System Permitting, Monitoring and Compliance.” Available at 

33 <http://www.pacode.com/secure/data/025/025toc.html> (accessed 16 May 2012).

34 25 Pa. Code 93. Pennsylvania Administrative Code, Part 1, Department of Environmental 

35 Protection, Title 25, Environmental Protection, Chapter 93, “Water Quality Standards.” Available 

36 at <http://www.pacode.com/secure/data/025/025toc.html> (accessed 16 May 2012).

37 25 Pa. Code 110. Pennsylvania Administrative Code, Part 1, Department of Environmental 

38 Protection, Title 25, Environmental Protection, Chapter 110, “Water Resources Planning.” 

39 Available at <http://www.pacode.com/secure/data/025/025toc.html> (accessed 16 May 2012).

40 25 Pa. Code 127. Pennsylvania Administrative Code, Part 1, Department of Environmental 

41 Protection, Title 25, Environmental Protection Chapter 127, “Construction, Modification, 

42 Reactivation, and Operations of Sources.” Available at 

43 <http://www.pacode.com/secure/data/025/chapter127/chap127toc.html> (accessed May 2012).
Purpose and Need for Action

2-87

1 25 Pa. Code 260a. Pennsylvania Administrative Code, Part 1, Department of Environmental 

2 Protection, Title 25, Environmental Protection, Chapter 260a, “Hazardous Waste Management 

3 System.” Available at 

4 <http://www.pacode.com/secure/data/025/chapter260a/chap260atoc.html> (accessed 

5 April 2012).

6 25 Pa. Code 266b. Pennsylvania Administrative Code, Part 1, Department of Environmental 

7 Protection, Title 25, Environmental Protection, Chapter 266b, “Universal Waste Management.” 

8 Available at <http://www.pacode.com/secure/data/025/chapter266b/chap266btoc.html>

9 (accessed April 2012).

10 25 Pa. Code 271. Pennsylvania Administrative Code, Part 1, Department of Environmental 

11 Protection, Title 25, Environmental Protection, Chapter 271, “Municipal Waste Management.” 

12 Available at <http://www.pacode.com/secure/data/025/chapter271/chap271toc.html> (accessed 

13 April 2012).

14 25 Pa. Code 287. Pennsylvania Administrative Code, Part 1, Department of Environmental 

15 Protection, Title 25, Environmental Protection, Chapter 287, “Residual Waste Management.” 

16 Available at <http://www.pacode.com/secure/data/025/chapter287/chap287toc.html> (accessed 

17 April 2012). 

18 30 Pa. Code 75. Pennsylvania Code, Title 30, Fish and Boat Code, Chapter 75, “Endangered 

19 Species.” Revised February 9, 1991. Pennsylvania Fish and Boat Commission.

20 34 Pa. Code 133. Pennsylvania Code, Title 34, Game and Wildlife Code, Chapter 133, “Wildlife 

21 Classification.” Revised December 1, 1990. Pennsylvania Game Commission.

22 42 USC 11001. United States Code, Title 42, The Public Health and Welfare, Chapter 116, 

23 Emergency Planning and Community Right-To-Know, Subchapter I, Emergency Planning and 

24 Notification, Section 11001, “Establishment of State commissions, planning districts, and local 

25 communities.” Available at <http://uscode.house.gov/download/pls/42C116.txt> (accessed 

26 April 2012). 

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28 Proposed Limerick Generating Station Units 1 and 2. Washington, DC: AEC. June 1973. 700 p. 

29 ADAMS Accession No. ML11313A215.

30 Albert RC. 1988. The historical context of water quality management for the Delaware Estuary. 

31 Estuaries 11(2):99–107.

32 [BHP] Bureau of Historic Preservation. 2011. Letter from D.C. McLearen, Pennsylvania 

33 Historical and Museum Commission Bureau for Historic Preservation, to D.H. Frens, Frens and 

34 Frens. Subject: NRC: Limerick Generating Station Relicensing Project, Fricks Lock Village 

35 Rehabilitation and Mothballing, E. Coventry Twp., Chester Co. October 19, 2011. Agencywide 

36 Documents Access and Management System (ADAMS) Accession No. ML11318A295.

37 Blye RW. 1973. Relative abundance of bird species during migration. Limerick Generating 

38 Station 16 p. ADAMS Accession No. ML12110A231.

39 Bramble WC, Yahner RH, Byrnes WR. 1992. Breeding bird population changes following 

40 right-of-way maintenance treatments. Journal of Arboriculture 18(1):23-32. Available at 

41 <http://joa.isa-arbor.com/request.asp?JournalID=1&ArticleID=2476&Type=2> (accessed 

42 8 May 2012).
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2 electric transmission right-of-way. Journal of Arboriculture 23(5):196-206. Available at 

3 <http://joa.isa-arbor.com/request.asp?JournalID=1&ArticleID=2775&Type=2>. Accessed 22 

4 August 2012)

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8 Maine. 3rd ed. Washington, DC: Smithsonian Institution Press. 748 p.

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10 Assessment Limerick Generating Stations, Pottstown, Pennsylvania. September 2006. ADAMS 

11 Accession No. ML12110A228.

12 Crone AJ, Wheeler RL. 2000. Data for Quaternary faults, liquefaction features, and possible 

13 tectonic features in the Central and Eastern United States, east of the Rocky Mountain front. 

14 Reston, VA: U.S. Geological Survey. Open-File Report 00-260. 2000. 332 p. Available at 

15 <http://pubs.usgs.gov/of/2000/ofr-00-0260> (accessed 13 June 2012).

16 Dewey JW, Hopper MG. 2009. “Intensity Distribution and Isoseismal Maps for the Pymatuning 

17 (Northwestern Pennsylvania) Earthquake of 25 September, 1998.” January 29, 2009. 

18 U.S. Geological Survey, Earthquake Hazards Program. Available at 

19 <http://earthquake.usgs.gov/research/groundmotion/field/pymatuning/intensity.php> (accessed 

20 6 April 2012).

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22 <http://www.state.nj.us/drbc/about/regulations/> (accessed 11 May 2012). 

23 [DRBC] Delaware River Basin Commission. 1999. Ground Water Protected Area Regulations 

24 Southeastern Pennsylvania. June 23, 1999. Available at 

25 <http://www.state.nj.us/drbc/about/regulations/> (accessed 16 May 2012). 

26 [DRBC] Delaware River Basin Commission. 2001. Comprehensive Plan. July. Available at 

27 <http://www.state.nj.us/drbc/about/regulations> (accessed 11 May 2012). 

28 [DRBC] Delaware River Basin Commission. 2004. Docket No. D-69-210 CP 

29 (Final)(Revision 12), Exelon Generation Company, LLC Limerick Generating Station Water 

30 Supply Modification Demonstration Project and Wadesville Mine Pool Withdrawal and 

31 Streamflow Augmentation Demonstration Project, Montgomery, Bucks, Schuylkill, Berks and 

32 Chester Counties, Pennsylvania. October 27, 2004. Available at 

33 <http://www.nj.gov/drbc/library/documents/D1969-210CPfinalRev12-102704.pdf> (accessed 

34 11 May 2012).

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36 the Delaware River for the DRBC 2010 Integrated Assessment. July 24, 2009. Available at 

37 <http://www.nj.gov/drbc/library/documents/10IntegratedList/Bioassessment-draft38 July2009rev.pdf> (accessed 22 October 2012). 

39 [DRBC] Delaware River Basin Commission. 2011a. Resolution NO. 20011–12. 

40 December 8, 2011. Available at <http://www.state.nj.us/drbc/library/documents/Res2011-

41 12Exelon.pdf> (accessed 11 May 2012). 

42 [DRBC] Delaware River Basin Commission. 2011b. Delaware River Basin Commission Meeting 

43 of May 11, 2011. Series 11, Number 2. May 11, 2011. Available at 

44 <http://www.state.nj.us/drbc/library/documents/5-11-11_minutes.pdf> (accessed 11 May 2012).
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2 at <http://www.state.nj.us/drbc/basin/> (accessed 16 May 2012).

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

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5 Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety.” 

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9 Maryland, Pennsylvania, Virginia, and West Virginia.” Available at 

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12 <http://www.epa.gov/osw/> (accessed April 2012).

13 [EPA] U.S. Environmental Protection Agency. 2012b. “Waste Environmental Management 

14 Systems.” Available at <http://www.epa.gov/osw/inforesources/ems/index.htm> (accessed 

15 April 2012).

16 [EPA] U.S. Environmental Protection Agency . 2012c. “Safe Drinking Water Information System 

17 (SDWIS),” County Search. Berks, Chester, Montgomery County, Pennsylvania. Last updated 

18 February 7, 2012. Available at 

19 <http://oaspub.epa.gov/enviro/sdw_form_v2.create_page?state_abbr=PA> (accessed 

20 April 2012).

21 [Exelon] Exelon Generation Company, LLC. 2001. Letter from J. Doering, Vice President, to 

22 U.S. Nuclear Regulatory Commission. 2000 Annual Environmental Operating Report 

23 (Non-Radiological). April 16, 2001.

24 [Exelon] Exelon Generation Company, LCC. 2002. Letter from R. Braun, Plant Manager, to 

25 U.S. Nuclear Regulatory Commission. 2001 Annual Environmental Operating Report 

26 (Non-Radiological). April 9, 2002.

27 [Exelon] Exelon Generation Company, LLC. 2003. Letter from R. Braun, Vice President, to 

28 U.S. Nuclear Regulatory Commission. 2002 Annual Environmental Operating Report 

29 (Non-Radiological). April 30, 2003.

30 [Exelon] Exelon Generation Company, LLC. 2004. Letter from R. DeGregorio, Vice President, to 

31 U.S. Nuclear Regulatory Commission. 2003 Annual Environmental Operating Report 

32 (Non-Radiological). April 26, 2004.

33 [Exelon] Exelon Generation Company, LLC. 2005. Letter from R. Degregorio, Vice President, to 

34 U.S. Nuclear Regulatory Commission. 2004 Annual Environmental Operating Report 

35 (Non-Radiological). April 25, 2005

36 [Exelon] Exelon Generation Company, LLC. 2006. Letter to U.S. Nuclear Regulatory 

37 Commission. 2005 Annual Environmental Operating Report (Non-Radiological). April 6, 2006.

38 [Exelon] Exelon Generation Company, LLC. 2007. “Wildlife at Work: Bird and Bat Project 

39 Summary Sheet.” 9 p. ADAMS Accession No. ML12110A289.

40 [Exelon] Exelon Generation Company, LLC. 2008a. Limerick Generating Station, Units 1 and 2. 

41 Annual Radiological Environmental Operating Report, Report No. 23, 1 January through 

42 31 December 2007. Sanatoga, PA. April 2008. ADAMS Accession No. ML081260681.

43 [Exelon] Exelon Generation Company, LLC. 2008b. Updated Final Safety Analysis Report, 

44 Limerick Generating Station Units 1 and 2. Revision 13. Kennett Square, PA. September 2008. 
Purpose and Need for Action

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1 [Exelon] Exelon Generation Company, LLC. 2009. Limerick Generating Station, Units 1 and 2, 

2 Annual Radiological Environmental Operating Report, Report No. 24, 1 January through 

3 31 December 2008. Sanatoga, PA. April 2009. ADAMS Accession No. ML091280061.

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6 [Exelon] Exelon Generation Company, LLC. 2010b. Exelon Corporation Limerick Generating 

7 Station Wildlife Management Plan. 66 p. ADAMS Accession No. ML12110A289.

8 [Exelon] Exelon Generation Company, LLC. 2010c. Limerick Generating Station, Units 1 and 2, 

9 Annual Radiological Environmental Operating Report, Report No. 25, 1 January through 

10 31 December 2009. Sanatoga, PA. April 2010. ADAMS Accession No. ML101250333.

11 [Exelon] Exelon Generation Company, LLC. 2010d. Limerick Generating Station, Units 1 and 2, 

12 Limerick Township, Montgomery County, Pennsylvania, NPDES Permit No. PA0051926 

13 Renewal Application. Submitted to Pennsylvania Department of Environmental Protection, 

14 Southeast Regional Office, Norristown, PA. September 2010. ADAMS Accession 

15 No. ML12110A229.

16 [Exelon] Exelon Generation Company, LLC. 2011a. Limerick Generating Station, Units 1 and 2, 

17 Annual Radiological Environmental Operating Report, 1 January through 31 December 2010. 

18 Sanatoga, PA: Exelon Generation Company. April 2011. ADAMS Accession No. ML11126A169.

19 [Exelon] Exelon Generation Company, LLC. 2011b. Applicant’s Environmental Report –

20 Operating License Renewal Stage, Limerick Generating Station, Units 1 and 2, Docket Numbers 

21 50-352 and 50-353, License Numbers NPF-39 and NPF-85. Exelon Generation Company, LLC. 

22 ADAMS Accession No. ML11179A104.

23 [Exelon] Exelon Generation Company, LLC. 2012a. “Corporate Policy, Environment.” EN-AC-1 

24 Revision 3, Effective Date: March 16, 2012. Available at

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26 3 May 2012).

27 [Exelon] Exelon Generation Company, LLC. 2012b. Letter from M.P. Gallagher, Vice President, 

28 License Renewal Projects, to NRC Document Desk. Subject: Response to NRC request for 

29 additional information, dated February 28th, 2012, related to the Limerick Generating Station 

30 license renewal application. March 27, 2012. ADAMS Accession No. ML12088A366, 

31 ML12110A227. 

32 [Exelon] Exelon Generation Company, LLC. 2012c. Limerick Generating Station, Units 1 and 2, 

33 Annual Radiological Environmental Operating Report, 1 January through 31 December 2011. 

34 Sanatoga, PA: Exelon Generation Company. April 2012. ADAMS Accession No. ML12121A620.

35 [Exelon] Exelon Generation Company, LLC. 2012d. The Limerick Generating Station Water 

36 Supply Modification Demonstration Project and Wadesville Mine Pool Withdrawal and Stream 

37 Flow Augmentation Demonstration Project Annual Update. Kennett Square, PA: Exelon. 

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44 Population Recovery Plan. Hadley, MA: FWS. 109 p. Available at 

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2 First Revision. Fort Snelling, MN: FWS Region 3. 258 p. Available at 

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15 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC. Subject: Reply to request for 

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24 Publication to the ANSI A300 Part 7: Tree, Shrub, and Other Woody Plant Maintenance—

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27 composition in the Schuylkill River in the vicinity of Limerick Generating Station during 2009. 

28 February 2010.

29 [NAI] Normandeau Associates, Inc. 2010b. East Branch Perkiomen Creek aquatic biology 

30 assessment XIII, 2008 monitoring period. May 2010.

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32 assessment XIV, 2009 monitoring period. July 2010.

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36 interim report for the Wadesville mine water demonstration project. Available at 

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38 9 April 2012).

39 [NAI and URS] Normandeau Associates, Inc. and URS Corporation. 2011. 2011 Interim report 

40 for the Limerick Generating Station water supply modification demonstration project and 

41 Wadesville Mine Pool withdrawal and streamflow augmentation demonstration project. Available 

42 at <http://www.nj.gov/drbc/library/documents/wadesville/2011_interim-report.pdf> (accessed 

43 9 April 2012).

44 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq.
Purpose and Need for Action

2-93

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

2 [NatureServe] NatureServe Explorer. 2010a. NatureServe Explorer: An online encyclopedia of 

3 life. Version 7.1. “Missouri rock-cress (Arabis missourienis).” Available at 

4 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Arabis+missouriensis>

5 (accessed 10 May 2012).

6 [NatureServe] NatureServe Explorer. 2010b. NatureServe Explorer: An online encyclopedia of 

7 life. Version 7.1. “Schweinitz’s flatsedge (Cyperus schweinitzii).” Available at 

8 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Cyperus+schweinitzii>

9 (accessed 10 May 2012). 

10 [NatureServe] NatureServe Explorer. 2010c. NatureServe Explorer: An online encyclopedia of 

11 life. Version 7.1. “Slender blue iris (Iris prismatica).” Available at 

12 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Iris+prismatica>

13 (accessed 10 May 2012). 

14 [NatureServe] NatureServe Explorer. 2010d. NatureServe Explorer: An online encyclopedia of 

15 life. Version 7.1. “Spreading rock-cress (Arabis patens).” Available at 

16 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Arabis+patens>

17 (accessed 10 May 2012). 

18 [NatureServe] NatureServe Explorer. 2010e. NatureServe Explorer: An online encyclopedia of 

19 life. Version 7.1. “Tufted buttercup (Ranunculus fascicularis).” Available at 

20 <http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Ranunculus+fascicular

21 is> (accessed 10 May 2012). 

22 [NCDC] National Climatological Data Center. 2012a. Climate of Pennsylvania. Asheville, North 

23 Carolina. Available at <http://climate.met.psu.edu/data/ncdc_pa.pdf> (accessed 6 April 2012).

24 NCDC] National Climatological Data Center. 2012b. 2011 Local Climatological Data Annual 

25 Summary with Comparative Data—Philadelphia, Pennsylvania. Asheville, North Carolina. 

26 Available at <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html> (accessed 6 April 2012).

27 [NCDC] National Climatological Data Center. 2012c. 2011 Local Climatological Data Annual 

28 Summary with Comparative Data—Allentown, Pennsylvania. Asheville, North Carolina. 

29 Available at <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html> (accessed 6 April 2012)

30 [NCDC] National Climatological Data Center. 2012d. Storm Events Database. Asheville, North 

31 Carolina. Available at <http://www.ncdc.noaa.gov/stormevents/> (accessed 6 April 2012).

32 [NCES] National Center for Education Statistics. 2011. Institute of Educational Science (IES). 

33 U.S. Department of Education. “College Opportunities Online Locator.” Zip Code 19464 Data 

34 release date August 16, 2011. Available at <http://nces.ed.gov/ipeds/cool/RefineSearch.aspx>. 

35 Search for Public School Districts. Available at <http://www.nces.ed.gov/ccd/districtsearch/> 

36 (accessed January 2011).

37 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative – Final 

38 Guidance Document. Washington, DC: Nuclear Energy Institute. NEI 07-07 [Final]. 

39 August 2007. ADAMS Accession No. ML091170588. 

40 [NHDES] New Hampshire Department of Environmental Services. 2010. Environmental Fact 

41 Sheet, Variable milfoil (Myriophyllum heterophyllum). Available at: 

42 <http://www.tuftonboro.org/Pages/TuftonboroNH_boards/facts> (accessed 10 April 2012).

43 [NMFS] National Marine Fisheries Service. 2012a. “Marine/Anadromous Fish Species Under the 

44 Endangered Species Act (ESA).” March 9, 2012. Available at 

45 <http://www.nmfs.noaa.gov/pr/species/esa/fish.htm> (accessed 9 April 2012).
Purpose and Need for Action

2-94

1 [NMFS] National Marine Fisheries Service. 2012b. “Shortnose Sturgeon (Acipenser 

2 brevirostrum).” March 14, 2012. Available at 

3 <http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm> (accessed 9 April 2012).

4 [NMFS] National Marine Fisheries Service. 2012c. Letter from M.A. Colligan, Assistant Regional 

5 Administrator for Protected Resources, NMFS, to J. Susco, Acting Branch Chief, NRC. June 2, 

6 2012. ADAMS Accession No. ML12226A163.

7 [NOAA] National Oceanic and Atmospheric Administration. 2012. Historical Hurricane Tracks. 

8 Available at <http://www.csc.noaa.gov/hurricanes/#> (accessed 6 April 2012).

9 [NRC] U.S. Nuclear Regulatory Commission. 1973. Final Environmental Statement Related to 

10 the Proposed Limerick Generating Stations Units 1 and 2. Washington, DC: NRC. ADAMS 

11 Accession No ML11313A215.

12 [NRC] U.S. Nuclear Regulatory Commission. 1984. Final Environmental Statement Related to 

13 Operation of Limerick Generating Station, Units 1 and 2. Washington, DC: NRC. NUREG-0974. 

14 April 1984. ADAMS Accession No. ML11221A204.

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

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

17 ADAMS Accession Nos. ML040690705 and ML040690738.

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

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

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

21 NRC. NUREG–1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 

22 No. ML04069720.

23 [NRC] U.S. Nuclear Regulatory Commission. 2000. Environmental Standard Review Plan: 

24 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. Washington, DC: 

25 NRC. NUREG–1555.

26 [NRC] U.S. Nuclear Regulatory Commission. 2003. Generic Environmental Impact Statement 

27 for License Renewal of Nuclear Plants, Supplement 10, regarding Peach Bottom Atomic Power 

28 Plant, Units 2 and 3. Washington, DC: NRC. NUREG–1437, Supplement 10. ADAMS Accession 

29 No. ML030270059. 

30 [NRC] U.S. Nuclear Regulatory Commission. 2009a. Generic Environmental Impact Statement 

31 for License Renewal of Nuclear Plants, Supplement 35, regarding Susquehanna Steam Electric 

32 Station, Units 1 and 2. Washington, DC: NRC. NUREG–1437, Supplement 35. ADAMS 

33 Accession No. ML090700454. 

34 [NRC] U.S. Nuclear Regulatory Commission. 2009b. Generic Environmental Impact Statement 

35 for License Renewal of Nuclear Plants, Supplement 36, regarding Beaver Valley Power Station, 

36 Units 1 and 2. Washington, DC: NRC. NUREG–1437, Supplement 36. 

37 [NRC] U.S. Nuclear Regulatory Commission. 2009c. Generic Environmental Impact Statement 

38 for License Renewal of Nuclear Plants, Supplement 37, regarding Three Mile Island Nuclear 

39 Station, Unit 1. Washington, DC: NRC. NUREG–1437, Supplement 37. 

40 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from D. Wrona, Branch Chief, to 

41 J. Cutler, Bureau of Historic Preservation. Limerick Generating Station license renewal 

42 environmental review (SHPO File No. ER 2004-2024-091-B). September 15, 2011. ADAMS 

43 Accession No. ML11221A265.
Purpose and Need for Action

2-95

1 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from D. Wrona, Branch Chief, to 

2 T. McCulloch, Advisory Council on Historic Preservation. Subject: Limerick Generating Station 

3 license renewal environmental review (SHPO File No. ER 2004-2024-091-B). 

4 September 16, 2011. ADMAS Accession No. ML11245A083.

5 [NRC] U.S. Nuclear Regulatory Commission. 2011c. E-mail from Ann, BHP, to T.K. O’Neil, 

6 PNNL. LGS license renewal—SHPO meeting. November 1, 2011. ADAMS Accession 

7 No. ML12255A291

8 [NRC] U.S. Nuclear Regulatory Commission. 2011d. “Official Transcript of Proceedings— 

9 Limerick Generating Station License Renewal: Evening Session.” October 26, 2011. ADAMS 

10 Accession No ML11287A211.

11 [NRC] U.S. Nuclear Regulatory Commission. 2011e. Memo from L. Regner to D. Wrona, Branch 

12 Chief. Subject: Summary of public scoping meetings conducted on September 22, 2011, related 

13 to the review of the Limerick Generating Stations, Units 1 and 2, license renewal application. 

14 October 26, 2011.

15 [NRC] U.S. Nuclear Regulatory Commission. 2011f. Letter from D. Wrona, Branch Chief, to 

16 Olivia Braun, Environmental Planner, Pennsylvania Game Commission. Subject: Request for list 

17 of protected species within the area under evaluation for the Limerick Generating Stations, 

18 Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession 

19 No. ML11234A065. 

20 [NRC] U.S. Nuclear Regulatory Commission. 2012a. “Summary of Site Audit in Support to the 

21 Environmental Review of the License Renewal Application for Limerick Generating Station, 

22 Units 1 and 2.” May 2012. ADAMS Accession No. ML12124A127.

23 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Letter from J. Susco, RERB Acting Branch 

24 Chief, NRC, to D. Morris, Acting Regional Administrator National Marine Fisheries Service. 

25 Subject: Request for list of Federal protected species within the area under evaluation for the 

26 Limerick Generating Station, Units 1 and 2, license renewal application review. May 30, 2012. 

27 ADAMS Accession No. ML12138A347.

28 [NRCS] Natural Resources Conservation Service. 2012. “Web Soil Survey, Soil Map – Chester 

29 County, Pennsylvania, and Montgomery County, Pennsylvania.” (Search parameters: soil map; 

30 soil data explorer-suitabilities and limitations for use, building site development, farmland 

31 classification; soil reports). February 17, 2012. U.S. Department of Agriculture, National 

32 Cooperative Soil Survey. Available at <http://websoilsurvey.nrcs.usda.gov/app> (accessed 

33 6 April 2012).

34 [NYSDEC] New York State Department of Environmental Conservation. 2009. “Delaware River 

35 American Shad Stock Status, Status of American Shad in the Delaware River.” Albany, NY: 

36 NYSDEC. August 2009. Available at <http://www.dec.ny.gov/animals/57679.html> (accessed 

37 9 April 2012).

38 O’Herron JC, Able KW, Hastings RW. 1993. Movements of shortnose sturgeon (Acipenser 

39 brevirostrum) in the Delaware River. Estuaries 16(2):235-240.

40 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2000. 

41 Physiographic Provinces of Pennsylvania. Harrisburg, PA: Commonwealth of Pennsylvania, 

42 Bureau of Topographic and Geological Survey. Map 13. Available at 

43 <http://www.dcnr.state.pa.us/ucmprd1/groups/public/documents/multimedia/dcnr_008642.pdf>

44 (accessed 6 April 2012).
Purpose and Need for Action

2-96

1 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2003. 

2 Earthquake Hazard in Pennsylvania. Harrisburg, PA: Commonwealth of Pennsylvania. Bureau 

3 of Topographic and Geological Survey. Educational Series 10. May 2003. Available at 

4 <http://www.dcnr.state.pa.us/ucmprd2/groups/public/documents/document/dcnr_006704.pdf>

5 (accessed 6 April 2012).

6 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2010. “Scenic 

7 Rivers.” Available at 

8 <http://www.dcnr.state.pa.us/brc/conservation/rivers/scenicrivers/index.htm> (accessed 

9 8 May 2012).

10 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2011. Letter from 

11 R. Bowen, Environmental Review Manager, for C. Firestone, Wild Plant Program Manager, 

12 Bureau of Forestry, PDCNR, to M. Gallagher, Exelon Nuclear. Subject: Pennsylvania Natural 

13 Diversity Inventory review for renewal of operating licenses for Limerick Generating Station, 

14 Units I and 2, Chester, Montgomery & Bucks Counties. March 9, 2011.

15 [PADCNR] Pennsylvania Department of Conservation and Natural Resources. 2012. PaGWIS 

16 Records. (Well radial search parameters: Latitude 40.22483 N, Longitude -75.5874 W, Radius 

17 1 mi). Harrisburg, PA: Commonwealth of Pennsylvania. Bureau of Topographic and Geological 

18 Survey, Pennsylvania Ground Water Information System. Available at 

19 <http://www.dcnr.state.pa.us/topogeo/groundwater/pagwis/records/index.htm> (accessed 

20 30 May 2012).

21 [PADE] Pennsylvania Department of Education – Division of Data Quality. 2011. “Enrollment 

22 Data and Statistics.” “Public School Enrollment Reports,” 4/20/2011. Available at 

23 <http://www.portal.state.pa.us/portal/server.pt/community/enrollment/7407/public_school_enroll

24 ment_reports/620541> (accessed April 2012).

25 [PADEP] Pennsylvania Department of Environmental Protection. 2003. Watershed restoration 

26 action strategy (WRAS) state water plan subbasin 03E, Perkiomen Creek Watershed, 

27 Montgomery, Bucks, Berks, and Lehigh counties. Bureau of Watershed Management.

28 [PADEP] Pennsylvania Department of Environmental Protection. 2006a. Water Quality 

29 Standards Review Stream Redesignation Evaluation Report. October 2006. Available at 

30 <http://files.dep.state.pa.us/water/Drinking%20Water%20and%20Facility%20Regulation/Water

31 QualityPortalFiles/Stream_Packages/Big%20Brook/Brooke_Evans.pdf> (accessed 

32 8 August 2012).

33 [PADEP] Pennsylvania Department of Environmental Protection. 2006b. “General Permit 

34 BWM-GP-11: Maintenance, Testing, Repair, Rehabilitation, or Replacement of Water 

35 Obstructions or Encroachments.” December 2006 Revision. 30 p. Available at 

36 <http://www.elibrary.dep.state.pa.us/dsweb/Get/Document-85002/3930-PM-WM0511-

37 Entire%20Package.pdf> (accessed 18 April 2012).

38 [PADEP] Pennsylvania Department of Environmental Protection. 2010. Letter from P. Patel, 

39 Permits Section, Water Management Program, to E.W. Callan, Plant Manager, Exelon 

40 Generation Co. LLC, Pottstown, PA. Subject: Limerick Generating Station Application 

41 No. PA0051926. December 15, 2010. ADAMS Accession No. ML12110A229.
Purpose and Need for Action

2-97

1 [PADEP] Pennsylvania Department of Environmental Protection. 2011. Draft 2012 Pennsylvania 

2 Integrated Water Quality Monitoring and Assessment Report, Clean Water Act Section 305(b) 

3 and 303(d) List. Harrisburg, PA: Bureau of Point and Non-Point Source Management. Available 

4 at 

5 <http://www.portal.state.pa.us/portal/server.pt/community/water_quality_standards/10556/integr

6 ated_water_quality_report_-_2012/1127203> (accessed 25 May 2012).

7 [PADEP] Pennsylvania Department of Environmental Protection. 2012. Drought Management in 

8 Pennsylvania. 3940-BK-DEP2742. Bureau of Safe Drinking Water, Planning and Conservation 

9 Division. March 2012. Available at 

10 <http://www.portal.state.pa.us/portal/server.pt/community/fact_sheets___guidelines/10609>

11 (accessed 16 May 2012).

12 [PASDC] Pennsylvania State Data Center. 2010. “Pennsylvania Population Projections: 

13 2000-2030.” Published 10/21/2010. Middletown, PA. Available at 

14 <http://pasdc.hbg.psu.edu/Data/Projections/tabid/1013/Default.aspx> (accessed May 2012).

15 [PECO] Philadelphia Electric Company. 1984. Environmental Report Operating License Stage 

16 Limerick Generating Station Units 1 & 2, Vol. 1. 

17 [PennDOT] Pennsylvania Department of Transportation. 2012. “2010 Traffic Volume Map” 

18 Available at 

19 <http://www.dot.state.pa.us/Internet/Bureaus/pdPlanRes.nsf/infoBPRTrafficInfoTrafficVolumeMa

20 p?openform> (accessed April 2012).

21 [PFBC] Pennsylvania Fish and Boat Commission. 2011a. “Adult Trout Stocking by County.” 

22 Available at <http://pfbc.state.pa.us/pfbc_webgis/TroutStockingDetails.aspx> (accessed 

23 9 April 2012).

24 [PFBC] Pennsylvania Fish and Boat Commission. 2011b. Letter from C.A. Urban, Natural 

25 Diversity Section Chief, Division of Environmental Service, PFBC, to D. Wrona, RPB2 Chief, 

26 NRC. Subject: Species Impact Review (SIR)—rare, candidate, threatened and endangered 

27 species, renewal of operating licenses for Limerick Generating Station, Units 1 and 2, 

28 Montgomery and Chester County, Pennsylvania. October 5, 2011. ADAMS Accession 

29 No. ML11291A077.

30 [PFBC] Pennsylvania Fish and Boat Commission. 2011c. “American shad spring spawning 

31 monitoring, Biologist Report, Delaware River, Monroe and Northampton Counties.” Available at 

32 <http://fishandboat.com/images/reports/2011bio/del2011shad.pdf> (accessed 

33 16 October 2012). 

34 [PFBC] Pennsylvania Fish and Boat Commission. 2012a. “Schuylkill River American Shad.” 

35 Available at <http://fishandboat.com/shad_schu.htm> (accessed 5 April 2012).

36 [PFBC] Pennsylvania Fish and Boat Commission. 2012b. “2004 and 2005 Fairmont Fish Ladder 

37 Passage Data Compared to Historical Counts.” Available at 

38 <http://fishandboat.com/pafish/shad/schuylkill/fairmount2005.htm> (accessed April 26, 2012).

39 [PFBC] Pennsylvania Fish and Boating Commission. 2012c. “Gallery of Pennsylvania Fishes.” 

40 Available at <http://fishandboat.com/pafish/fishhtms/chapindx.htm> (accessed 8 August 2012)

41 [PFBC] Pennsylvania Fish and Boating Commission. 2012d. “Summary Book, 2012 

42 Pennsylvania Fishing Laws and Regulations, Regulations by Location, Delaware River.” 

43 Available at <http://fishandboat.com/fishpub/summary/delaware.html> (accessed 

44 16 October 2012). 
Purpose and Need for Action

2-98

1 [PGC] Pennsylvania Game Commission. 2010. “Indiana Bat.” Available at 

2 <http://www.portal.state.pa.us/portal/server.pt/document/775661/indiana_bat_pdf> (accessed 

3 9 May 2012).

4 [PGC] Pennsylvania Game Commission. 2011. Letter from O.A. Mowery, Environmental 

5 Planner, Division of Environmental Planning and Habitat Protection, to D. Wrona, Chief, Division 

6 of License Renewal, NRC. Subject: Re: Limerick Generating Station and transmission lines—

7 license renewal, Montgomery and Chester Counties, Pennsylvania. November 17, 2011. 

8 ADAMS Accession No. ML11329A060. 

9 [PNHP] Pennsylvania Natural Heritage Program. 2007a. “American Holly, Ilex opaca.” Available 

10 at <http://www.naturalheritage.state.pa.us/factsheets/12926.pdf> (accessed 10 May 2012).

11 [PNHP] Pennsylvania Natural Heritage Program. 2007b. “Possum-haw, Viburnum nudum.” 

12 Available at <http://www.naturalheritage.state.pa.us/factsheets/13672.pdf> (accessed 

13 10 May 2012).

14 [PNHP] Pennsylvania Natural Heritage Program. 2007c. “Redbelly Turtle (Pseudemys 

15 rubriventris).” Available at <http://www.naturalheritage.state.pa.us/factsheets/11525.pdf>

16 (accessed 24 July 2012).

17 [PNHP] Pennsylvania Natural Heritage Program. 2011a. “Elliott's beardgrass (Andropogon 

18 gyrans).” Available at <http://www.naturalheritage.state.pa.us/factsheets/15497.pdf> (accessed 

19 10 May 2012).

20 [PNHP] Pennsylvania Natural Heritage Program. 2011b. “Toothcup (Rotala romosior).” 

21 Available at <http://www.naturalheritage.state.pa.us/factsheets/14149.pdf> (accessed 

22 10 May 2012).

23 [PNHP] Pennsylvania Natural Heritage Program. 2012a. “Species of Special Concern Lists.” 

24 Search by County for Bucks, Chester, and Montgomery Counties. Available at 

25 <http://www.naturalheritage.state.pa.us/Species.aspx> (accessed 10 May 2012).

26 [PNHP] Pennsylvania Natural Heritage Program. 2012b. “Species Fact Sheet, Banded sunfish 

27 (Enneacanthus obesus).” Available at 

28 <http://www.naturalheritage.state.pa.us/factsheets/11395.pdf> (accessed 10 April 2012).

29 [PNHP] Pennsylvania Natural Heritage Program. 2012c. “Species Fact Sheet, Longear sunfish 

30 (Lepomis megalotis).” Available at 

31 <http://www.naturalheritage.state.pa.us/factsheets/11401.pdf> (accessed 10 April 2012).

32 [PNHP] Pennsylvania Natural Heritage Program. 2012d. “Species Fact Sheet, Farwell’s 

33 Water-milfoil (Myriophyllum farwellii).” Available at 

34 <http://www.naturalheritage.state.pa.us/factsheets/13979.pdf> (accessed 10 April 2012).

35 [PNHP] Pennsylvania Natural Heritage Program. 2012e. “Species Fact Sheet, Floating-heart 

36 (Nymphoides cordata).” Available at 

37 <http://www.naturalheritage.state.pa.us/factsheets/14174.pdf> (accessed 10 April 2012).

38 [PNHP] Pennsylvania Natural Heritage Program. 2012f. “Species Fact Sheet, Spotted 

39 Pondweed (Potamogeton pulcher).” Available at 

40 <http://www.naturalheritage.state.pa.us/factsheets/15786.pdf> (accessed 10 April 2012).

41 Ramsdell JV, Rishel JP. 2007. Tornado Climatology of the Contiguous United States. 

42 Washington, DC: U.S. Nuclear Regulatory Commission. NUREG/CR–4461, Rev. 2. 

43 Resource Conservation and Recovery Act of 1976, as amended. 42 U.S.C. §6901 et seq.
Purpose and Need for Action

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1 Rhoads AF, Block TA. 2008. Montgomery County, Pennsylvania: Natural Areas Inventory 

2 Update. Philadelphia, PA: Morris Arboretum of the University of Pennsylvania. Submitted to the 

3 Montgomery County Planning Commission. June 30, 2007. 401 p. Available at 

4 <http://planning.montcopa.org/planning/cwp/view,a,3,q,66753.asp> (accessed 8 May 2012).

5 [RMC] RMC Environmental Services. 1984. Progress Report, Non-radiological environmental 

6 monitoring for Limerick Generating Station 1979–1983. October 1984.

7 [RMC] RMC Environmental Services. 1985. Progress Report, Non-radiological environmental 

8 monitoring for Limerick Generating Station 1984. December 1985.

9 [RMC] RMC Environmental Services. 1986. Progress Report, Non-radiological environmental 

10 monitoring for Limerick Generating Station 1985. September 1986.

11 [RMC] RMC Environmental Services. 1987. Progress Report, Non-radiological environmental 

12 monitoring for Limerick Generating Station 1986. November 1987.

13 [RMC] RMC Environmental Services. 1988. Progress Report, Non-radiological environmental 

14 monitoring for Limerick Generating Station 1987. September 1988.

15 [RMC] RMC Environmental Services. 1989. Progress Report, Non-radiological environmental 

16 monitoring for Limerick Generating Station 1988. December 1989.

17 Rohde FC, Arndt RG, Lindquist DG, Parnell JF. 1994. Freshwater Fishes of the Carolinas, 

18 Virginia, Maryland, and Delaware. University of North Carolina Press, Chapel Hill, North 

19 Carolina.

20 Rothbart P, Capel S. 2006. Chapter 3: “Maintaining and Restoring Grasslands.” In: Oehler JD, 

21 Covell DF, Capel S, Long B, editors. Managing Grasslands, Shrublands, and Young Forest 

22 Habitats for Wildlife: a Guide for the Northeast. Westborough, MA: Massachusetts Division of 

23 Fisheries & Wildlife, Northeast Upland Habitat Technical Committee. Available at 

24 <http://www.wildlife.state.nh.us/Wildlife/Northeast_Mgt_Guide/Ch03_Maintaining_Grasslands.

25 pdf> (accessed 8 May 2012).

26 Sadak T. 2008. Acid mine drainage pollution in the West Branch Schuylkill and Upper Schuylkill 

27 River, Schuylkill County, Pennsylvania: a case study and recommendations for the future. 

28 Presented to the faculties of the University of Pennsylvania in partial fulfillment of the 

29 requirements for the degree of Master of environmental studies 2008. Available at 

30 <http://repository.upenn.edu/mes_capstones/34> (accessed 23 August 2012).

31 Sauer JR, Hines JE, Fallon JE, Pardieck KL, Ziolkowski Jr. DJ, Link WA. 2011. The North 

32 American Breeding Bird Survey, Results and Analysis 1966–2006. Version 12.07.2011. Species 

33 List for Schwenksville, Pennsylvania. Laurel, MD: U.S. Geological Survey Patuxent Wildlife 

34 Research Center. Available at <http://www.mbr-pwrc.usgs.gov/cgi-bin/rtena210.pl?72182> 

35 (accessed 8 May 2012).

36 Sea Grant Pennsylvania. 2007. Zebra Mussel and Quagga Mussel, Dreissena polymorpha and 

37 Dreissena rostriformis bugensis. Available at 

38 <http://seagrant.psu.edu/publications/fs/zebraquagga2007.pdf> (accessed 29 April 2012).

39 Sea Grant Pennsylvania. 2012. Hydrilla, Hydrilla verticillata. Available at 

40 <http://seagrant.psu.edu/publications/fs/Hydrilla.pdf> (accessed 29 April 2012).

41 Secor DH, Waldman, JR. 1999. Historical Abundance of Delaware Bay Atlantic Surgeon and 

42 Potential Rate of Recovery. American Fisheries Society Symposium 23:203-216.
Purpose and Need for Action

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1 Select Greater Philadelphia (SGP). 2007. Montgomery County Data Economic Profile. Largest 

2 Private Sector Employers. Available at 

3 <http://www.selectgreaterphiladelphia.com/data/counties/montgomery.cfm> (accessed 

4 January 2011).

5 Simpson PC, Fox DA. undated. Atlantic sturgeon in the Delaware River: contemporary 

6 population status and identification of spawning areas. Dover, DE: Delaware State University. 

7 Available at 

8 <http://www.nero.noaa.gov/StateFedOff/grantfactsheets/DE/FINAL%20REPORTS/FINAL%20N

9 A05NMF4051093.pdf> (accessed 27 August 2012).

10 [Stroud] Stroud Water Research Center. 2011. Schuylkill River Project. Available at 

11 <http://www.stroudcenter.org/research/projects/schuylkill/index.shtm> (accessed 

12 25 October 2011).

13 Trapp H, Horn, MA.1997. Ground Water Atlas of the United States, Delaware, Maryland, New 

14 Jersey, North Carolina, Pennsylvania, Virginia, West Virginia. Washington, DC: U.S. Geological 

15 Survey. HA-730-L. Available at <http://pubs.usgs.gov/ha/ha730/ch_l/L-text4.html> (accessed 

16 30 May 2012). 

17 [USCB] U.S. Census Bureau. 2011. American FactFinder, Census 2010, 3-Year Estimate, 

18 American Community Survey, State and County QuickFacts on Berks, Chester, and 

19 Montgomery Counties. Land Area in Square Miles, 2010; Housing Characteristics, 2010; Major 

20 Employers, 2010; Available at <http://factfinder.census.gov> and <http://quickfacts.census.gov>

21 (accessed January 2011 and April 2012).

22 [USDA] U.S. Department of Agriculture. National Agricultural Statistics Service (NASS). 2009. 

23 2007 Census of Agriculture. Volume 1 Chapter 2: County Level Data for Pennsylvania. Table 1. 

24 County Summary Highlights: 2007 and Table 7. Hired Farm Labor—Workers and Payroll: 2007. 

25 Released February 4, 2009 and updated in December 2009. Available at 

26 <http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_

27 Level/Pennsylvania/st42_2_001_001.pdf> and 

28 <http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_

29 Level/Pennsylvania/st42_2_007_007.pdf> (accessed April 2012).

30 [USGS] U.S. Geological Survey. 2001. “North American Breeding Bird Survey: Route Location 

31 and Availability.” Available at <http://www.pwrc.usgs.gov/bbs/results/routemaps/index.html>

32 (accessed 8 May 2012).

33 [USGS] U.S. Geological Survey. 2008. “Geologic Hazards Team Interactive Map Server, 

34 National Seismic Hazard Maps—2008.” April 23, 2008. Available at <http://gldims.cr.usgs.gov>

35 (accessed 6 April 2012). 

36 [USGS] U.S. Geological Survey. 2010a. Water-Data Report 2010, 01472000 Schuylkill River at 

37 Pottstown, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 

38 <http://wdr.water.usgs.gov/wy2010/pdfs/01472000.2010.pdf> (accessed 16 May 2011).

39 [USGS] U.S. Geological Survey. 2010b. Water-Data Report 2010, 01463500 Delaware River at 

40 Trenton, NJ, Delaware River Basin. Available at 

41 <http://wdr.water.usgs.gov/wy2010/pdfs/01463500.2010.pdf> (accessed 16 May 2011).

42 [USGS] U.S. Geological Survey. 2011a. Water-Data Report 2011a, 01472620 East Branch 

43 Perkiomen Creek near Dublin, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 

44 <http://wdr.water.usgs.gov/wy2011/pdfs/01472620.2011.pdf> (accessed 16 May 2011).
Purpose and Need for Action

2-101

1 [USGS] U.S. Geological Survey. 2011b. Water-Data Report 2011, 01473000 Perkiomen Creek 

2 at Graterford, PA, Lower Delaware Basin Schuylkill Subbasin. Available at 

3 <http://wdr.water.usgs.gov/wy2011/pdfs/01473000.2011.pdf> (accessed 16 May 2011).

4 [USGS] U.S. Geological Survey. 2012a. “Quaternary Fault and Fold Database of the United 

5 States.” February 25, 2011. Earthquake Hazards Program. Available at 

6 <http://earthquake.usgs.gov/hazards/qfaults> (accessed 6 April 2012).

7 [USGS] U.S. Geological Survey. 2012b. “Circular Area Earthquake Search, NEIC: Earthquake 

8 Search Results, U.S. Geological Survey Earthquake Data Base.” (Search parameters: 

9 USGS/NEIC (PDE) 1973 database, latitude 40.225 N, longitude -75.5873 W, radius 100 km). 

10 March 2, 2012. Earthquake Hazards Program, National Earthquake Information. Available at 

11 <http://earthquake.usgs.gov/earthquakes/eqarchives/epic/epic_circ.php> (accessed 

12 6 April 2012).

13 [USGS] U.S. Geological Survey. 2012c. “Historic United States Earthquakes, Pennsylvania.” 

14 November 23, 2009. Earthquake Hazards Program. Available at 

15 <http://earthquake.usgs.gov/earthquakes/states/historical_state.php> (accessed 6 April 2012).

16 [USGS] U.S. Geological Survey. 2012d. “Magnitude/Intensity Comparison.” February 22, 2010. 

17 Earthquake Hazards Program. Available at 

18 <http://earthquake.usgs.gov/learn/topics/mag_vs_int.php> (accessed 6 April 2012).

19 Versar, Inc. 2003. The Delaware River Creel Survey 2002. Prepared for Pennsylvania Fish & 

20 Boat Commission. May 2003.

21 [WHC] Wildlife Habitat Council. 2006. Site Assessment and Wildlife Management Opportunities 

22 for Exelon Corporation’s Limerick Generating Station. Report submitted to Limerick Generating 

23 Station, Exelon Corporation. Silver Spring, MD: WHC. August 2006. 119 p. ADAMS Accession 

24 No. ML12110A289.

25 Wheeler RL. 2006. Quaternary tectonic faulting in the Eastern United States. Engineering 

26 Geology 82:165–186.

27 Yahner RH, Bramble WC, Byrnes WR. 2001. Response of amphibian and reptile populations to 

28 vegetation maintenance of an electric transmission line right-of-way. Journal of Arboriculture 

29 27(4):215-221. Available at <http://joa.isa-arbor.com/request.asp? JournalID=1&ArticleID=2933 

30 &Type=2> (accessed 8 May 2012).

31 Yahner RH, Yahner RT. 2007. Populations of small mammals on an electric transmission line 

32 area in southeastern Pennsylvania. U.S. Arboriculture and Urban Forestry 33(6):433-434. 

33 Available at <http://joa.isa-arbor.com/request.asp?JournalID=1&ArticleID=3022&Type=2>

34 (accessed 8 May 2012).

3-1 

1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

2 Facility owners or operators may need to undertake or, for economic or safety reasons, may 

3 choose to perform refurbishment activities in anticipation of license renewal or during the license 

4 renewal term. The major refurbishment class of activities characterized in the Generic 

5 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996) is 

6 intended to encompass actions which typically take place only once in the life of a nuclear plant, 

7 if at all. Examples of these activities include, but are not limited to, replacement of boiling water 

8 reactor recirculation piping and pressurized water reactor steam generators. These actions may 

9 have an impact on the environment beyond those that occur during normal operations and may 

10 require evaluation, depending on the type of action and the plant-specific design. Table 3-1 lists 

11 the environmental issues associated with refurbishment that the U.S. Nuclear Regulatory 

12 Commission (NRC) staff (the staff) determined to be Category 1 issues in the GEIS.

13 Table 3–1. Category 1 Issues Related to Refurbishment

Issue GEIS 

Section(s)

Surface water quality, hydrology, and use (for all plants)

Impacts of refurbishment on surface water quality 3.4.1

Impacts of refurbishment on surface water use 3.4.1

Aquatic ecology (for all plants)

Refurbishment 3.5

Groundwater use and quality

Impacts of refurbishment on groundwater use and quality 3.4.2

Land use

Onsite land use 3.2

Human health

Radiation exposures to the public during refurbishment 3.8.1

Occupational radiation exposures during refurbishment 3.8.2

Socioeconomics

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 

3.7.4.4; 3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

14 Table 3-2 lists environmental issues related to refurbishment that the staff determined to be 

15 plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The definitions 

16 of Category 1 and 2 issues can be found in Section 1.4.
Environmental Impacts of Refurbishment

3-2 

1 Table 3–2. Category 2 Issues Related to Refurbishment

Issue GEIS Section(s)

10 CFR 51.53 

(c)(3)(ii) 

Subparagraph

Terrestrial resources

Refurbishment impacts 3.6 E

Threatened or endangered species (for all plants)

Threatened or endangered species 3.9 E

Air quality

Air quality during refurbishment

(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(a) Not addressed Not addressed

(a) Guidance related to environmental justice was not in place at the time the U.S. Nuclear Regulatory Commission 

(NRC) prepared the GEIS and the associated revision to 10 CFR Part 51. If an applicant plans to undertake 

refurbishment activities for license renewal, the applicant’s environmental report (ER) and the staff’s environmental 

impact statement must address environmental justice.

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

2 Table B–2 of the GEIS identifies systems, structures, and components (SSCs) that are subject 

3 to aging and might require refurbishment to support continued operation during the license 

4 renewal period of a nuclear facility. In preparation for its license renewal application, Exelon 

5 Generation Company, LLC (Exelon) performed an evaluation of these SSCs pursuant to Title 10 

6 of the Code of Federal Regulation (10 CFR 54.21), in order to identify the need to undertake 

7 any major refurbishment activities that would be necessary to support the continued operation of 

8 Limerick Generating Station Units 1 and 2 (LGS) during the proposed 20-year period of 

9 extended operation.

10 In its SSC evaluation, Exelon did not identify the need to undertake any major refurbishment or 

11 replacement actions associated with license renewal to support the continued operation of LGS 

12 beyond the end of the existing operating license (Exelon 2011). Therefore, the staff will not 

13 assess refurbishment activities in this SEIS.
Environmental Impacts of Refurbishment

3-3 

1 3.1. References

2 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

3 Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

4 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

5 Renewal of Operating Licenses for Nuclear Power Plants.”

6 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

7 Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

8 License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 

9 Accession No. ML11179A104. 

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

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

12 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738.

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

14 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants. In: 

15 Generic Environmental Impact Statement for License Renewal of Nuclear Plants.

16 Washington, DC: NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS 

17 Accession No. ML04069720.

4-1 

1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION

2 This chapter addresses potential environmental impacts related to the period of extended 

3 operation of Limerick Generating Station, Units 1 and 2 (LGS). These impacts are grouped and 

4 presented according to resource. Generic issues (Category 1) rely on the analysis presented in 

5 the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants

6 (NRC 1996), unless otherwise noted. Site-specific issues (Category 2) have been analyzed for 

7 LGS and assigned a significance level of SMALL, MODERATE, or LARGE, accordingly. Some 

8 issues are not applicable to LGS because of site characteristics or plant features. For an 

9 explanation of the criteria for Category 1 and Category 2 issues, as well as the definitions of 

10 SMALL, MODERATE, and LARGE, refer to Section 1.4. 

11 4.1. Land Use

12 Section 2.2.1 of this supplemental environmental impact statement (SEIS) describes the land 

13 use around LGS. 

14 Land use in the vicinity of nuclear power plants could be affected by the license renewal 

15 decision. However, as discussed in the GEIS, onsite land use and power line right of way

16 (ROW) conditions are expected to remain unchanged during the license renewal term at all 

17 nuclear plants and any impacts would therefore be SMALL. These issues were classified as 

18 Category 1 issues in the GEIS and are listed in Table 4–1. 

19 Exelon Generation Company, LLC’s (Exelon) Environmental Report (ER) (Exelon 2011a), 

20 scoping comments, and other available information about land use in the vicinity of LGS, 

21 Units 1 and 2 were reviewed and evaluated for new and significant information. The review 

22 included a data gathering site visit to LGS. No new and significant information was identified 

23 during this review that would change the conclusions in the GEIS. Therefore, for these 

24 Category 1 issues, impacts during the renewal term are not expected to exceed those 

25 discussed in the GEIS.

26 Montgomery County has been working to develop an interconnected system of open space and 

27 trails along the Schuylkill River and within other natural resource areas of the county. The LGS 

28 site contains land along the Schuylkill River that has been identified as part of the Schuylkill 

29 River Greenway in the county plan. Onsite land use conditions at LGS are expected to remain 

30 unchanged during the license renewal term. Therefore, activities associated with continued 

31 reactor operations during the license renewal term are not expected to affect the use and 

32 management of LGS lands identified as part of the Schuylkill River Greenway. 

33 Table 4–1. Land Use Issues

Issue GEIS Section Category

Onsite land use 4.5.3 1

Power line ROW 4.5.3 1

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51
Environmental Impacts of Operation

4-2 

1 4.2. Air Quality

2 Section 2.2.2 of this report describes the meteorology and air quality in the vicinity of the LGS 

3 site. One Category 1 air quality issue is applicable to LGS—air quality effects of transmission 

4 lines. No Category 2 issues apply for air quality, as there is no planned refurbishment 

5 associated with license renewal. The U.S. Nuclear Regulatory Commission (NRC) staff did not 

6 identify any new and significant information related to the Category 1 air quality issue during the 

7 review of Exelon’s ER, the site audit, or during the scoping process. Therefore, there are no 

8 impacts related to this issue beyond those discussed in the GEIS. For this issue, the GEIS 

9 concluded that the impacts are SMALL. 

10 Table 4–2. Air Quality Issues

Issue GEIS Section Category

Air quality effects of transmission lines 4.5.2 1

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

11 4.3. Geologic Environment

12 4.3.1. Geology and Soils

13 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

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

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

16 With respect to the geologic environment of a plant site, the revised rule amends Table B–1 in 

17 Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 issue, “Geology and 

18 soils.” This new issue has an impact level of SMALL. This new Category 1 issue considers 

19 geology and soils from the perspective of those resource conditions or attributes that can be 

20 affected by continued operations during the renewal term. An understanding of geologic and 

21 soil conditions has been well established at all nuclear power plants and associated 

22 transmission lines during the current licensing term, and these conditions are expected to 

23 remain unchanged during the 20-year license renewal term for each plant. The impact of these 

24 conditions on plant operations and the impact of continued power plant operations and 

25 refurbishment activities on geology and soils are SMALL for all nuclear power plants and not 

26 expected to change appreciably during the license renewal term. Operating experience shows 

27 that any impacts to geologic and soil strata would be limited to soil disturbance from 

28 construction activities associated with routine infrastructure renovation and maintenance 

29 projects during continued plant operations. Implementing best management practices would 

30 reduce soil erosion and subsequent impacts on surface water quality. Information in 

31 plant-specific SEISs prepared to date and reference documents has not identified these impacts 

32 as being significant.

33 Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to 

34 LGS. The NRC staff did not identify any new and significant information with regard to this

35 Category 1 (generic) issue based on review of the ER (Exelon 2011a), the public scoping 

36 process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS 

37 and as identified in the ER (Exelon 2011a), Exelon has no plans to conduct refurbishment or 

38 replacement actions associated with license renewal to support the continued operation of LGS. 

39 Further, Exelon anticipates no new construction or other ground disturbing-activities or changes 

40 in operations and that operation and maintenance activities would be confined to previously 
Environmental Impacts of Operation

4-3 

1 disturbed areas or existing ROWs. Based on this information, it is expected that any 

2 incremental impacts on geology and soils during the license renewal term would be SMALL. 

3 4.4. Surface Water Resources 

4 The Category 1 (generic) and Category 2 surface water use and quality issues applicable to 

5 LGS, Units 1 and 2 are discussed in the following sections and listed in Table 4–3. Surface 

6 water resources-related aspects and conditions relevant to the LGS site are described in 

7 Sections 2.1.7.1 and 2.2.4. 

8 Table 4–3. Surface Water Resources Issues

Issues GEIS Section Category

Altered current patterns at intake and discharge structures 4.2.1.2.1 1

Altered salinity gradients 4.2.1.2.2 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 river with low flow) 4.3.2.1 2 

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

9 4.4.1. Generic Surface Water Issues 

10 The NRC staff did not identify any new and significant information with regard to the Category 1 

11 (generic) surface water issues based on review of the ER (Exelon 2011a), the public scoping 

12 process, or as a result of the environmental site audit. As a result, no information or impacts 

13 related to these issues were identified that would change the conclusions presented in the 

14 GEIS. Therefore, it is expected that there would be no incremental impacts related to these 

15 Category 1 issues during the renewal term beyond those discussed in the GEIS. For these 

16 surface water issues, the GEIS concludes that the impacts are SMALL. 

17 4.4.2. Surface Water Use Conflicts 

18 This section presents the NRC staff’s review of plant-specific (Category 2) surface water use 

19 conflict issues as listed in Table 4–3. 

20 4.4.2.1. Plants Using Makeup Water from a Small River with Low Flow

21 For nuclear power plants utilizing cooling towers or cooling ponds supplied with makeup water 

22 from a small river, the potential impact on the flow of the river and related impacts on instream 

23 and riparian ecological communities is considered a Category 2 issue, thus, requiring a 

24 plant-specific assessment. A small river is defined in 10 CFR 51.53(c)(3)(ii)(A) as one whose 

annual flow rate is less than 3.15x1012 ft3

/yr (9x1010 m3/yr) or 100,000 cfs (2,820 m3 25 /s). LGS has 

26 a closed-cycle, heat-dissipation system that uses natural draft cooling towers with makeup 
Environmental Impacts of Operation

4-4 

1 water pumped from the Schuylkill River (see Section 2.1.7). As noted in Section 2.2.4.1, the 

2 Schuylkill River near the LGS site has a mean annual flow rate of less than 

6.3 x 1010 ft3 3 /yr (2,000 cfs). Therefore, an assessment of the impact of the proposed action on 

4 the flow of the river is required. 

5 Flow conditions in the Schuylkill River have required Exelon to supplement LGS’s water 

6 sources. As discussed in Section 2.2.4.1, the mean annual flow and 90 percent exceedance 

7 flow for the Schuylkill River, as measured at the U.S. Geological Survey (USGS) Pottstown, 

Pennsylvania, gage station, total 1,935 cfs (54.8 m3

/s) and 482 cfs (13.6 m3 8 /s), respectively. 

9 Against these measures of flow, the withdrawal of water at the maximum consumptive use 

permitted by the Delaware River Basin Commission (DRBC) (65 cfs (1.84 m3 10 /s)) represents a 

11 3.4 percent and a 13 percent reduction, respectively, in the flow of the Schuylkill River 

12 downstream of LGS. In order to limit downstream, including aquatic and riparian, impacts in the 

13 Schuylkill River during low flow, the DRBC requires LGS to augment its consumptive use of 

water when the river flow falls to 560 cfs (15.9 m3 14 /s), based on two-unit operation. This is 

15 accomplished either through withdrawing makeup water directly from other DRBC-approved 

16 water sources or through augmentation of the flow in the Schuylkill River through surface water 

17 diversion, as described in Sections 2.1.6 and 2.1.7.1 of this SEIS. 

18 In 2003, as part of a demonstration project approved by the DRBC, Exelon included water from 

19 Wadesville Mine Pool and the Still Creek Reservoir in its portfolio of water sources for flow 

20 augmentation. Since their use presently remains a demonstration project and has not received 

21 final docket approval from the DRBC (Docket No. D-69-210, as revised), the NRC staff did not 

22 consider these alternative water sources in its impact level determination. Before 2003, the 

23 frequency of water withdrawals by LGS for consumptive use was approximately 50 percent from 

24 the Schuylkill River, 4 percent from Perkiomen Creek natural flow, and 46 percent from

25 Perkiomen Creek supplemented by water diverted from the Delaware River. Under the 

26 demonstration project with releases from the Wadesville Mine Pool to the Schuylkill River, the 

27 frequency of withdrawals from the Schuylkill River to support LGS consumptive uses has 

28 increased (Exelon 2012a). This trend toward an increasing reliance on augmented flows in the 

29 Schuylkill River would be expected to increase during the license renewal term should the 

30 demonstration project continue or be made permanent by DRBC, as requested by Exelon. 

31 Regardless of the above considerations, the DBRC Comprehensive Plan (DRBC 2001) includes 

32 consideration of LGS operations. The DBRC’s mission includes water conservation, control, 

33 use, and management, which is to be accomplished through the adoption and promotion of 

34 uniform and coordinated policies basin-wide (DRBC 1961). The DBRC requirement that LGS 

shift to alternative water sources when the flow of the Schuylkill River falls to 560 cfs (15.9 m3 35 /s) 

36 ensures that LGS cooling water withdrawals and associated consumptive use will not reduce 

37 river flow by more than 12 percent during low-flow periods. During average flows, LGS 

38 operations will reduce the flow by about 3 percent. Therefore, because DRBC imposes 

39 requirements to ensure that LGS’s consumptive water use from the Schuylkill River remains 

40 within acceptable limits, the NRC staff concludes that the impact on surface water resources 

41 and downstream water availability from consumptive water use by LGS, Units 1 and 2 during 

42 the license renewal term would be SMALL. 

43 4.5. Groundwater Resources 

44 The Category 1 (generic) and Category 2 groundwater use and quality issues applicable to LGS 

45 are discussed in the following sections and listed in Table 4–4. Groundwater resources related 

46 aspects and conditions relevant to the LGS site are described in Sections 2.1.7.2 and 2.2.5. 
Environmental Impacts of Operation

4-5 

1 Table 4–4. Groundwater Resources Issues

Issues GEIS Section Category

Groundwater use conflicts (potable and service water; plants that use 

less than 100 gpm) 4.8.1.1 1 

Groundwater use conflicts (plants using cooling towers withdrawing 

makeup water from a small river) 4.8.1.3 2 

Radionuclides released to groundwater To be determined(a) 2

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b

2 4.5.1. Generic Groundwater Issues 

3 Section 2.2.5 of this SEIS discusses groundwater use and quality at LGS. The NRC staff did 

4 not identify any new and significant information with regard to Category 1 (generic) groundwater 

5 issues based on the review of the ER (Exelon 2011a), the public scoping process, or as a result 

6 of the environmental site audit. NRC staff also reviewed other sources of information, such as 

7 various permits and data reports. As a result, no information or impacts related to these issues 

8 were identified that would change the conclusions presented in the GEIS. Therefore, for the 

9 single issue found to be directly applicable to LGS, it is expected that there would be no 

10 incremental impacts related to this Category 1 issue during the renewal term beyond those 

11 discussed in the GEIS. For this groundwater issue, the GEIS concludes that the impacts are 

12 SMALL. 

13 4.5.2. Groundwater Use and Quality Conflicts 

14 This section presents the NRC staff’s review of plant-specific (Category 2) groundwater 

15 resources issues as listed in Table 4–4. 

16 4.5.2.1. Plants Using Cooling Towers Withdrawing Makeup Water from a Small River, Alluvial 

17 Aquifers 

18 For nuclear power plants utilizing cooling towers supplied with makeup water from a small river 

19 (as defined in Section 4.3.2.1), the potential impact on alluvial aquifers is also considered a 

20 Category 2 issue, thus, requiring a plant-specific assessment. This groundwater aspect was 

21 classified as a Category 2 issue in the GEIS because consumptive use of water withdrawn from 

22 a small river could adversely affect groundwater aquifer recharge. Low river flow conditions are 

23 of particular interest. 

24 Based on the topography of the plant site and review of local groundwater elevations, NRC staff 

25 determined that groundwater flow across and in the vicinity of the plant site predominately 

26 discharges to the Schuylkill River and Possum Hollow Run. Groundwater provides baseflow to 

27 these surface waters. For groundwater use conflicts to occur due to reduced streamflow, the 

28 affected stream segments must also be a principal source of recharge to an affected aquifer, 

29 which is not the case. Recharge to the bedrock aquifer (Brunswick) in the region predominantly 

30 occurs in upgradient areas from precipitation and runoff, as described in Section 2.2.5.1 of the 

31 SEIS. In addition, the alluvial sediments and regolith overlying the area’s bedrock are relatively 

32 thin and not used as a source of groundwater. A review of Pennsylvania water well records 

33 within a 1-mi (1.6-km) radius of the LGS site revealed that all recorded wells are in the 

34 Brunswick Formation rather than in surficial materials. Therefore, the NRC staff concludes that 
Environmental Impacts of Operation

4-6 

1 continued withdrawals of surface water for the operation of LGS, Units 1 and 2 during low-flow 

2 periods would have a SMALL impact on groundwater recharge during the license renewal term. 

3 4.5.2.2. Radionuclides Released to Groundwater

4 In its ER (Exelon 2011a), Exelon identified the presence of tritium in groundwater as new, but 

5 not significant, information based on site groundwater monitoring. In response, the NRC staff

6 specifically reviewed information relating to the current state of knowledge on groundwater 

7 quality beneath and downgradient of LGS, as detailed in Section 2.2.5.2 and summarized 

8 below. 

9 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

10 protection regulation, 10 CFR Part 51. With respect to groundwater quality, the revised rule 

11 amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

12 Category 2 issue, “Radionuclides released to groundwater,” with an impact level range of 

13 SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from

14 plant systems into groundwater. This new Category 2 issue has been added to evaluate the 

15 potential impact to groundwater quality from the discharge of radionuclides from plant systems, 

16 piping, and tanks. This issue was added because, within the past several years, there have 

17 been events at nuclear power reactor sites that involved unknown, uncontrolled, and 

18 unmonitored releases of radioactive liquids into the groundwater. 

19 Exelon commissioned a hydrogeologic investigation in 2006 (CRA 2006), in part, to evaluate the 

20 potential impacts on groundwater quality of any inadvertent releases of tritium or other 

21 LGS-related radionuclides and to identify and eliminate contributing sources of radionuclides to 

22 groundwater. The investigation provided the basis for the site’s current Radiological 

23 Groundwater Protection Program (RGPP). 

24 As part of the 2006 investigation, a network of 15 onsite groundwater monitoring wells was 

25 installed in the Brunswick Formation (bedrock aquifer) at LGS. From the initial 2006 sampling, 

26 no strontium-90 or gamma-emitting radionuclides were detected in groundwater or surface 

27 water above analytical detection limits. Tritium was detected in five of the monitoring wells at 

28 relatively low wells, but one well (P12), located immediately south and downgradient of the 

29 power block, had a concentration of 4,360 ± 494 pCi/L. At the same time, a sample from the 

30 power block foundation sump had tritium at 2,020 ± 154 pCi/L. As noted in Section 2.2.5.2, 

31 well P12 was replaced with well no. MW-LR-9 in August 2006, to be more representative of 

32 water table conditions beneath the site. Sampling of this new well yielded tritium at 

33 1,500 ± 210 pCi/L. 

34 Under the ongoing RGPP at LGS, groundwater and surface water samples are collected and 

35 analyzed for tritium and other radionuclides at least semi-annually. The results are reported in 

36 annual radiological environmental operating (REOP) reports (Exelon 2008a, 2009a, 2010a, 

37 2011b, 2012b) that are submitted to the NRC. Since 2006, there have been no detections in 

38 groundwater of gamma-emitting radionuclides or strontium-90 associated with LGS operations. 

39 The peak tritium level observed in groundwater was 1,750 pCi/L in well MW-LR-9 in 2009. 

40 Exelon traced this to a condensate release in February 2009, which was corrected (see 

41 Section 2.2.5.2). Tritium in MW-LR-9 had decreased to a maximum of 1,154 pCi/L by 

42 April 2011. It is noted that tritium concentrations have exceeded 2,000 pCi/L in samples from 

43 the power block foundation sump since 2006 (Exelon 2011a). Regardless, monitoring data 

44 indicates that there is no migration of tritium in groundwater at LGS at concentrations exceeding 

45 2,000 pCi/L, and observed tritium levels have been well within the U.S. Environmental 

46 Protection Agency (EPA) primary drinking water standard (i.e., 20,000 pCi/L) at all onsite 

47 monitoring wells. In addition, there are no potable water wells downgradient of the LGS power 

48 block and no drinking water pathway. The plant’s potable water supply well (well 1) is located 
Environmental Impacts of Operation

4-7 

1 about 1,000 ft (300 m) upgradient and slightly cross-gradient (northeast) of MW-LR-9 and the 

2 power block sump pit. Based on the information presented and the NRC staff’s review, NRC 

3 staff concludes that inadvertent releases of tritium have not substantially impaired site 

4 groundwater quality or affected groundwater use downgradient of the LGS site. The NRC staff 

5 further concludes that groundwater quality impacts would remain SMALL during the license 

6 renewal term. 

7 4.6. Aquatic Resources

8 Section 2.1.6 of this SEIS describes the LGS cooling-water system; Section 2.2.5 describes the 

9 aquatic resources. Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B–1, 

10 which are applicable to the operation of the LGS cooling-water systems during the renewed 

11 license term, are listed in Table 4–5. There are no Category 2 issues that apply to aquatic 

12 resources at LGS. The NRC staff did not find any new and significant information during the 

13 review of the applicant’s ER (Exelon 2011a), the site audit, the scoping process, or the 

14 evaluation of other available information; therefore, the NRC staff concludes that there are no 

15 impacts related to aquatic resource issues beyond those discussed in the GEIS (NRC 1996) 

16 and the revised rule (NRC 2012b). Consistent with the GEIS, the NRC staff concludes that the 

17 impacts are SMALL, and additional site-specific mitigation measures are unlikely to be 

18 sufficiently beneficial to warrant implementation. 

19 Table 4–5. Aquatic Resources Issues

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 4.2.2.1.10 1

Stimulation of nuisance organisms 4.2.2.1.11 1

Exposure of aquatic organisms to radionuclides To be 

determined(a) 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

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b
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1 4.6.1. Exposure of Aquatic Organisms to Radionuclides

2 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

3 protection regulation, 10 CFR Part 51. With respect to the aquatic organisms, the revised rule 

4 amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

5 Category 1 issue, “Exposure of aquatic organisms to radionuclides,” among other changes. 

6 This new Category 1 issue considers the impacts to aquatic organisms from exposure to 

7 radioactive effluents discharged from a nuclear power plant during the license renewal term. An 

8 understanding of the radiological conditions in the aquatic environment from the discharge of 

9 radioactive effluents within NRC regulations has been well established at nuclear power plants 

10 during their current licensing term. Based on this information, the NRC concluded that the 

11 doses to aquatic organisms are expected to be well below exposure guidelines developed to 

12 protect these organisms and assigned an impact level of SMALL.

13 The NRC staff has not identified any new and significant information related to the exposure of 

14 aquatic organisms to radionuclides during its independent review of LGS’s ER, the site audit, 

15 and the scoping process. Section 2.1.2 of this SEIS describes the applicant’s radioactive waste 

16 management program to control radioactive effluent discharges to ensure that they comply with 

17 NRC regulations in 10 CFR Part 20, “Standards for protection against radiation.” Section 4.9.3 

18 of this SEIS contains the NRC staff’s evaluation of the LGS’s radioactive effluent and 

19 radiological environmental monitoring programs. LGS’s radioactive effluent and radiological 

20 environmental monitoring programs provide further support for the conclusion that the impacts 

21 of aquatic organisms from radionuclices are SMALL. The NRC staff concludes that there would 

22 be no impacts to aquatic organisms from radionuclides beyond those impacts contained in 

23 Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and, therefore, the 

24 impacts to aquatic organisms from radionuclides are SMALL.

25 4.7. Terrestrial Resources

26 The Category 1 (generic) and Category 2 (site-specific) terrestrial resources issues applicable to 

27 LGS are discussed in the following sections and listed in Table 4–6. Terrestrial resources 

28 issues that apply to LGS are described in Sections 2.2.7 and 2.2.8. 

29 Table 4–6. Terrestrial Resources Issues

Issue GEIS Section Category

Cooling tower impacts on crops and ornamental vegetation 4.3.4 1

Cooling tower impacts on native plants 4.3.5.1 1

Bird collisions with cooling towers 4.3.5.2 1

Power line right-of-way management (cutting herbicide application) 4.5.6.1 1

Bird collisions with power lines 4.5.6.2 1

Impacts of electromagnetic fields on flora and fauna (plants, 

agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1

Floodplains and wetland on power line right-of-way 4.5.7 1

Exposure of terrestrial organisms to radionuclides

To be 

determined(a) 1

Effects on terrestrial resources (non-cooling system impacts) To be 

determined(a) 2 

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b
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1 4.7.1. Generic Terrestrial Resources Issues

2 For the Category 1 terrestrial resources issues listed in Table 4–6, the NRC staff did not identify 

3 any new and significant information during the review of the ER (Exelon 2011a), the NRC staff’s 

4 site audit, the scoping process, or the evaluation of other available information. Therefore, there 

5 are no impacts related to these issues beyond those discussed in the GEIS and the revised rule 

6 (NRC 2012b). For these issues, the GEIS and the revised rule concluded that the impacts are 

7 SMALL, and additional site-specific mitigation measures are not likely to be sufficiently 

8 beneficial to warrant implementation.

9 4.7.1.1. Exposure of Terrestrial Organisms to Radionuclides

10 As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its 

11 environmental protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, 

12 the revised rule amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a 

13 new Category 1 issue, “Exposure of terrestrial organisms to radionuclides,” among other 

14 changes. This new issue has an impact level of SMALL. This new Category 1 issue considers 

15 the impacts to terrestrial organisms from exposure to radioactive effluents discharged from a 

16 nuclear power plant during the license renewal term. An understanding of the radiological 

17 conditions in the terrestrial environment from the discharge of radioactive effluents within NRC 

18 regulations has been well established at nuclear power plants during their current licensing 

19 term. Based on this information, the NRC concluded that the doses to terrestrial organisms are 

20 expected to be well below exposure guidelines developed to protect these organisms and 

21 assigned an impact level of SMALL.

22 The NRC staff has not identified any new and significant information related to the exposure of 

23 terrestrial organisms to radionuclides during its independent review of LGS’s ER, the site audit, 

24 and the scoping process. Section 2.1.2 of this SEIS describes the applicant’s radioactive waste 

25 management program to control radioactive effluent discharges to ensure that they comply with 

26 NRC regulations in 10 CFR Part 20. Section 4.9.3 of this SEIS contains the NRC staff’s 

27 evaluation of LGS’s radioactive effluent and radiological environmental monitoring programs, 

28 which provide further support for the conclusion that the impacts from radioactive effluents are 

29 SMALL.

30 Therefore, the NRC staff concludes that there would be no impact to terrestrial organisms from

31 radionuclides beyond those impacts contained in Table B–1 in Appendix B, Subpart A, to 

32 10 CFR Part 51of the revised rule and, therefore, the impacts to terrestrial organisms from 

33 radionuclides are SMALL. 

34 4.7.2. Effects on Terrestrial Resources (Non-Cooling System Impacts)

35 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

36 protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revised rule 

37 amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the 

38 Category 2 issue, “Refurbishment impacts,” among others, to include normal operations, 

39 refurbishment, and other supporting activities during the license renewal term. This issue 

40 remains a Category2 issue with an impact level range of SMALL to LARGE; however, the 

41 revised rule renames this issue “Effects on terrestrial resources (non-cooling system impacts).”

42 Section 2.2.7 describes the terrestrial resources on and in the vicinity of the LGS site and 

43 vicinity, and Section 2.2.8 describes protected species and habitats. During construction of 

44 LGS, approximately 42 percent of the plant site (270 ac (110 ha)) was cleared for buildings, 

45 parking lots, roads, and other infrastructure. The remaining terrestrial habitats have not 

46 changed significantly since construction. As discussed in Chapter 3 of this SEIS and according 
Environmental Impacts of Operation

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1 to the applicant’s ER (Exelon 2011a), Exelon has no plans to conduct refurbishment or 

2 replacement actions associated with license renewal to support the continued operation of LGS. 

3 Further, Exelon (2011a) anticipates no new construction or other ground-disturbing activities, 

4 changes in operations, or changes in existing land use conditions because of license renewal. 

5 Exelon (2011a) reports that operation and maintenance activities would be confined to 

6 previously disturbed areas or existing ROWs. As a result, Entergy (2011a) anticipates no new 

7 impacts on the terrestrial environment on the LGS site or along the in-scope transmission line 

8 corridors during the license renewal term. Based on the staff’s independent review, the staff 

9 concurs that operation and maintenance activities that Exelon might undertake during the 

10 renewal term, such as maintenance and repair of plant infrastructure (e.g., roadways, piping 

11 installations, onsite transmission lines, fencing, and other security infrastructure), likely would be 

12 confined to previously disturbed areas of the LGS site. Therefore, the staff expects non-cooling 

13 system impacts on terrestrial resources during the license renewal term to be SMALL.

14 4.8. Protected Species and Habitats

15 Section 2.2.7 of this SEIS describes the action area, as defined by the ESA regulations at 

16 50 CFR 402.02, and describes the protected species and habitats within the action area 

17 associated with the LGS license renewal. Table 4–7 lists the one Category 2 issue related to 

18 protected species and habitats that is applicable to LGS. 

19 Table 4–7. Protected Species and Habitats Issues

Issue GEIS Section Category

Threatened or endangered species 4.1 2

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

20 4.8.1. Correspondence with Federal and State Agencies

21 In accordance with Section 7 of the Endangered Species Act (ESA), in a letter to the U.S. Fish 

22 and Wildlife Service (FWS), dated September 8, 2011, the NRC staff requested information 

23 regarding Federally listed species in the action area (NRC 2011d). Also in accordance with 

24 Section 7 of the ESA, the NRC staff sent a similar request regarding Federally listed species to

25 the National Marine Fisheries Service (NMFS) (NRC 2012a). The NRC staff sent further 

26 requests to the Pennsylvania Fish and Boat Commission (PFBC) (NRC 2011e), Pennsylvania 

27 Game Commission (PGC) (NRC 2011g), and Pennsylvania Department of Conservation and 

28 Natural Resources (PDCNR) (NRC 2011f) regarding the presence of Pennsylvania-listed

29 species in the action area. The PFBC, PGC, FWS, and NMFS responded to the NRC staff in 

30 letters dated October 5, 2011 (PFBC 2011b); November 17, 2011 (PGC 2011); 

31 November 22, 2011 (FWS 2011b); and June 2, 2012 (NMFS 2012c), respectively. The PFBC 

32 noted that the eastern redbelly turtle (Pseudemys rubriventris) and globally rare amphipods 

33 and/or isopods may be in the project area (PFBC 2011b); Section 4.7.3 considers the potential 

34 effects to this species. The PGC determined that no impacts to Pennsylvania-listed threatened 

35 or endangered birds or mammals under PGC responsibility would be likely from the proposed 

36 license renewal (PGC 2011). The FWS indicated that the proposed project is within the known 

37 range of the bog turtle (Clemmys muhlenbergii) (FWS 2011b); Section 4.7.3 considers the 

38 potential effects to this species. However, because FWS concluded that the proposed action is 

39 not likely to have an adverse effect on the bog turtle, no further consultation with FWS under 

40 Section 7 of the ESA is required. NMFS stated that no species listed under the ESA occur 
Environmental Impacts of Operation

4-11

1 within the action area (NMFS 2012c). NMFS also stated that two candidate species—alewife 

2 (Alosa pseudoharengus) and blueback herring (Alosa aestivalis)—occur in the project area. 

3 However, as candidate species, NMFS is still considering whether the species should be listed 

4 and protected under ESA. Therefore, no further consultation with NMFS under Section 7 of the 

5 ESA is required. The NRC staff has not received a response from the PDCNR to date. 

6 However, in a March 9, 2011, letter to Exelon, the PDCNR identified several plant species that 

7 occur within the action area near LGS transmission line corridors (PDCNR 2011). The PDCNR 

8 indicated that because the proposed license renewal does not involve new construction, 

9 refurbishment, ground disturbance, or changes to operations or existing land-use conditions, no 

10 impact is likely to occur to species under the PDCNR’s jurisdiction (PDCNR 2011). 

11 4.8.2. Aquatic Species and Habitats

12 For purposes of its protected species and habitat discussion and analysis, the NRC staff 

13 considers the action area, as defined by 50 CFR 402.02, to include the lands and waterbodies 

14 associated with LGS, as defined in Section 2.2.7. Two fish species and one aquatic 

15 invertebrate protected under the ESA may occur in the Delaware River or in small waterbodies 

16 throughout Pennsylvania (FWS 2012, NMFS 2012a). Two fish within the action area are 

17 considered candidate species and species of concern by NMFS (NMFS 2012c). Three 

18 additional fish species, one additional aquatic invertebrate, and four aquatic plant species listed 

19 as a species of special concern, endangered, or threatened by the Commonwealth of 

20 Pennsylvania may occur in waterbodies in Bucks, Chester, or Montgomery Counties 

21 (PNHP 2012a). 

22 4.8.2.1. Federally Protected Species

23 Shortnose Sturgeon (Acipenser brevirostrum)

24 The endangered shortnose sturgeon uses the tidal, estuarine, and lower portion of the Delaware 

25 River in Bucks County, Pennsylvania (NMFS 2012b). LGS-related studies from 1979-1985 did 

26 not observe shortnose sturgeon eggs or larvae at the Point Pleasant Pumping Station and 

27 downriver to river mi (RM) 138 (river km (RKm) 222.1) (Exelon 2011a; RMC 1984, 1985, 1986). 

28 The most recent population studies observed the farthest upriver migration up to 9 RM 

29 (15 RKm) below the Point Pleasant Pumping Station, which is located at RM 157 (RKm 253) 

30 (Hastings et al. 1987, O’Herron et al. 1993). NMFS stated that no species listed under the ESA 

31 occur within the action area (NMFS 2012c). 

32 The NRC staff concludes that the proposed LGS license renewal would have no effect on the 

33 shortnose sturgeon because: 

34 • NMFS (2012c) stated that no species listed under the ESA occur within the 

35 action area, 

36 • the LGS intake at the Point Pleasant Pumping Station is approximately 9 RM

37 (15 RKm) upriver of the farthest known upriver occurrence of this species,

38 • LGS-related studies from 1979–1985 did not observe Atlantic sturgeon eggs 

39 or larvae near the Point Pleasant Pumping Station, and

40 • no new construction, refurbishment, ground-disturbing activities, or changes 

41 to existing land use conditions at the Point Pleasant Pumping Station would 

42 occur. 
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1 Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus)

2 The endangered Atlantic sturgeon uses the tidal, estuarine, and lower portion of the Delaware 

3 River in Bucks County, Pennsylvania (NMFS 2012b). LGS-related studies from 1979 to 1985 

4 did not observe Atlantic sturgeon eggs or larvae at the Point Pleasant Pumping Station and 

5 downriver to 138 RM (222.1 RKm) (Exelon 2011a; RMC 1984, 1985, 1986). Tagging studies 

6 in 2005 and 2006 indicated that Atlantic sturgeon followed similar migration patterns as 

7 shortnose sturgeon with spawning potentially occurring in the upper tidal Delaware reaches 

8 between Philadelphia, Pennsylvania, and Trenton, New Jersey (Simpson and Fox undated). 

9 NMFS (2012c) stated that no species listed under the ESA occur within the action area. 

10 The NRC staff concludes that the proposed LGS license renewal would have no effect on 

11 Atlantic sturgeon because: 

12 • NMFS (2012) stated that no species listed under the ESA occur within the 

13 action area, 

14 • LGS-related studies from 1979 to1985 did not observe Atlantic sturgeon eggs 

15 or larvae near the Point Pleasant Pumping Station, and

16 • no new construction, refurbishment, ground-disturbing activities, or changes 

17 to existing land use conditions at the Point Pleasant Pumping Station would 

18 occur. 

19 Dwarf Wedgemussel (Alasmidonta heterodon) 

20 FWS (2012b) lists the endangered dwarf wedgemussel as known to or believed to occur in 

21 Monroe, Pike, and Wayne Counties, Pennsylvania, which is not part of the action area. PNHP 

22 (2012a) lists the dwarf wedgemussel as potentially occurring in Bucks, Chester, and 

23 Montgomery Counties. The Philadelphia Electric Company (PECO 1984) observed rare,

24 unidentified species of the genus Alasmidonta in the Schuylkill River in the 1970s and it is 

25 unknown whether the specimens were the dwarf wedgemussel (Exelon 2011a). Other than the 

26 rare Alasmidonta specimens observed in the 1970s in the Schuylkill River, LGS-related studies

27 did not observe dwarf wedgemussels during benthic surveys in East Branch Perkiomen Creek, 

28 Perkiomen Creek, and the Schuylkill River between 1970 and 2009 (Exelon 2011a; NAI 2010c; 

29 PECO 1984; RMC 1984, 1985, 1986, 1987, 1989). 

30 Both Exelon and the NRC staff contacted FWS to request information on potential impacts to 

31 Federally protected species. In a March 22, 2011, letter to Exelon, FWS (2011a) did not identify 

32 the dwarf wedgemussel as a concern in regard to LGS’s proposed license renewal. In a 

33 November 22, 2011, letter to the NRC, the FWS (2011b) confirmed that the conclusions in their 

34 previous letter to Exelon were still appropriate. 

35 Therefore, the NRC staff concludes that the proposed LGS license renewal would have no

36 effect, on dwarf wedgemussel because effects to the species would be insignificant, 

37 discountable, or beneficial. 

38 4.8.2.2. Pennsylvania-Protected Species, Candidate Species, and Species of Concern

39 Fish 

40 The Commonwealth of Pennsylvania lists the banded sunfish (Enneacanthus obesus) and the 

41 longear sunfish (Lepomis megalotis) as endangered in Bucks County (PNHP 2012a). The 

42 Pennsylvania endangered ironcolor shiner (Notropis chalybaeus) occurs in Bucks and 

43 Montgomery Counties (PNHP 2012a). Blueback herring and alewife are considered candidate 

44 species and NMFS species of concern (NMFS 2012). 
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1 LGS-related activity in Bucks County that could affect the blueback herring, alewife, banded 

2 sunfish, longear sunfish, or ironcolor shiner and their habitat is the intermittent withdrawal of 

3 Delaware River water for the LGS cooling system. Direct impacts could include impingement or 

4 entrainment and indirect impacts could include impingement or entrainment of prey. Blueback 

5 herring and alewife eggs are demersal and adhesive, which make them less likely to be 

6 entrained. Eggs and larvae entrained in the Point Pleasant Pumping Station would be 

7 transported from the Delaware River to the East Branch Perkiomen Creek. Eggs and larvae 

8 would experience sudden pressure fluctuations, velocity shear forces, and physical abrasion in 

9 the pumps at Point Pleasant and Bradshaw Reservoir and throughout the pipeline. If any eggs 

10 or larvae survive the transport, successful development would depend on organisms finding

11 suitable habitat. Prey species that survive the transport would no longer be available as prey for 

12 fish in the Delaware River. 

13 LGS license renewal would include continued operation at the Point Pleasant Pumping Station. 

14 However, as described in Section 2.1.6, Exelon’s withdrawal of water from the Delaware River

15 is secondary to its withdrawal of water from the Schuylkill River, and Exelon plans to continue to 

16 rely less on the Delaware River and more on the Schuylkill River in the future (Exelon 2012a). 

17 LGS license renewal would not involve new construction, refurbishment, ground-disturbing 

18 activities, or changes to existing land use conditions at the Point Pleasant Pumping Station. 

19 Transmission lines associated with LGS do not cross any portion of the Delaware River 

20 (Exelon 2011a). 

21 In addition to Bucks County, blueback herring, alewife, and the ironcolor shiner may occur in 

22 Montgomery County. Waters in Montgomery County associated with LGS include East Branch 

23 Perkiomen Creek, Perkiomen Creek, and the Schuylkill River.LGS license renewal would 

24 include continued operation at the Perkiomen Pumphouse, the Schuylkill Pumphouse, and the 

25 Schuylkill River discharge structure. Direct effects could include mortality if fish are impinged or 

26 entrained. Blueback herring and alewife eggs are demersal and adhesive, which make them 

27 less likely to be entrained. Indirect effects could include a decrease in habitat quality from 

28 thermal discharge in the Schuylkill River. However, the flow, temperature, and other conditions 

29 of the discharge are regulated by LGS’s NPDES permit, which would limit changes in water 

30 quality. Indirect effects could also occur from the Delaware River intrabasin transfer of water, 

31 which involves diversion of Delaware River water to the East Branch Perkiomen Creek that 

32 discharges by gravity flow to Perkiomen Creek in order to augment the flow in Perkiomen 

33 Creek. As described in Section 2.2.6, NAI (2010a) sampled aquatic biota between 2001 

34 and 2009 as part of an analysis to examine post-operational effects of the water diversion effort 

35 (Exelon 2011a). Species diversity remained relatively consistent and samples continued to be 

36 dominated by midges and oligochaetes. In addition, less variability existed along the stream 

37 gradient and over time; NAI noted that pollution-sensitive species increased in abundance 

38 (NAI 2010a, 2010c). 

39 The LGS license renewal would include continued operation and maintenance of four 

40 transmission lines that extend from the Limerick site and travel and cross portions of the 

41 Schuylkill River and Perkiomen Creek (Section 2.1.5 describes the in-scope transmission lines 

42 in more detail). The transmission lines associated with LGS cross rivers and streams that have 

43 the potential to be blueback herring, alewife, or ironcolor shiner habitat. PECO must maintain 

44 the transmission lines and associated structures and manage vegetation along the transmission 

45 line corridors to prevent interference with the lines. Line and vegetation maintenance may result 

46 in a temporary decline in habitat quality from increased sedimentation and turbidity during 

47 maintenance activities. 

48 If PECO needs to perform maintenance in or near waterbodies, it takes a number of precautions 

49 to avoid impacts to blueback herring, alewife, and ironcolor shiners or their habitat. First, PECO 
Environmental Impacts of Operation

4-14

1 typically performs mechanical vegetation maintenance activities on foot and does not operate 

2 heavy machinery near wetlands and water bodies. This type of maintenance avoids the 

3 potential for heavy machinery to affect fish habitat by reducing the amount of sedimentation and 

4 turbidity in the stream. Foot traffic could result in some minimal disturbance of fish habitat. 

5 However, foot traffic would create impacts that are insignificant (i.e., those impacts that would 

6 never reach the scale where fish mortality would occur) or discountable (i.e., those impacts that 

7 cannot be meaningfully measured, detected, or evaluated). In addition, PECO must obtain 

8 several permits and certifications for maintenance activities in wetlands or near waterbodies, 

9 which for a given work area may include: (1) a General Permit or Water Obstruction and 

10 Encroachment General Permit issued jointly by the USACE and PADEP, (2) a CWA 404 permit 

11 issued by the USACE, or (3) an erosion and sedimentation control plan from the appropriate 

12 county conservation district. 

13 LGS license renewal would not involve new construction, refurbishment, ground-disturbing 

14 activities, or changes to existing land use conditions at LGS-associated facilities or transmission 

15 lines. 

16 The NRC staff contacted PFBC to request information on potential impacts to 

17 Pennsylvania-protected species. In an October 5, 2011, letter to the NRC, PFBC (PFBC 2011b) 

18 did not identify the banded sunfish, longear sunfish, or the ironcolor shiner as a concern in 

19 regard to LGS’s proposed license renewal. 

20 Pizzini’s Amphipod 

21 The Pizzini’s cave amphipod (Stygobromus pizzinii), previously named Stygonectes pizzinii, is a 

22 Pennsylvania species of concern and is possibly extirpated in Montgomery and Chester

23 Counties (PNHP 2012a). Based on the Pennsylvania Natural Diversity Inventory (PNDI) 

24 database and PFBC files, PFBC (2011) stated in its letter to the NRC that globally rare 

25 amphipod and/or isopod species are known to occur within the vicinity of the LGS site. 

26 LGS license renewal would include continued operation at the Perkiomen Pumphouse, the 

27 Schuylkill Pumphouse, and the Schuylkill River discharge structure. Direct effects could include 

28 mortality if amphipods are entrained. Indirect effects could include a decrease in habitat quality 

29 from thermal discharge in the Schuylkill River. However, the flow, temperature, and other 

30 conditions of the discharge are regulated by LGS’s NPDES permit, which would limit changes in 

31 water quality. Indirect effects could also occur from the Delaware River intrabasin transfer of

32 water, which involves diversion of Delaware River water to the East Branch Perkiomen Creek 

33 that discharges by gravity flow to Perkiomen Creek in order to augment the flow in Perkiomen 

34 Creek. As described in Section 2.2.6, NAI (2010a) sampled aquatic biota between 2001 

35 and 2009 as part of an analysis to examine post-operational effects of the water diversion effort 

36 (Exelon 2011a). Species diversity remained relatively consistent and samples continued to be 

37 dominated by midges and oligochaetes. In addition, less variability existed along the stream 

38 gradient and over time; NAI noted that pollution-sensitive species increased in abundance 

39 (NAI 2010a, 2010c). 

40 The LGS license renewal would include continued operation and maintenance of four 

41 transmission lines that extend from the Limerick site and travel and cross portions of the 

42 Schuylkill River and Perkiomen Creek (Section 2.1.5 describes the in-scope transmission lines 

43 in more detail). The transmission lines associated with LGS cross rivers and streams that have 

44 the potential to be Pizzini’s cave amphipod habitat. PECO must maintain the transmission lines 

45 and associated structures and manage vegetation along the transmission line corridors to 

46 prevent interference with the lines. Line and vegetation maintenance may result in direct 

47 impacts to Pizzini’s cave amphipod if instream work is required that could crush the amphipods. 

48 Potential indirect effects could include a temporary decline in habitat quality from increased 
Environmental Impacts of Operation

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1 sedimentation and turbidity during maintenance activities. In PFBC’s (2011) letter to the NRC, 

2 PFBC noted that the Pizzini’s cave amphipod is threatened by habitat destruction and poor 

3 water quality. If PECO needs to perform maintenance in or near waterbodies, it takes a number 

4 of precautions to reduce the likelihood of crushing amphipods and to reduce sedimentation and 

5 water quality impacts. These actions, such as performing mechanical vegetation maintenance 

6 activities on foot and obtaining necessary permits, are described in more detail earlier in this 

7 section. 

8 LGS license renewal would not involve new construction, refurbishment, ground-disturbing 

9 activities, or changes to existing land use conditions at LGS-associated facilities or transmission

10 lines. 

11 The NRC staff contacted PFBC to request information on potential impacts to 

12 Pennsylvania-protected species. In an October 5, 2011, letter to the NRC, PFBC (2011) 

13 identified Pizzini’s cave amphipod as potentially occurring in the vicinity of the LGS site. 

14 However, given that license renewal would not involve new construction, earth disturbances, or 

15 changes to existing land uses, PFBC did not anticipate any significant adverse impacts to this 

16 species (PFBC 2011b). 

17 Aquatic Plants 

18 Pennsylvania lists Farwell’s water-milfoil (Myriophyllum farwellii), broad-leaved water-milfoil 

19 (Myriophyllum heterophyllum), floating-heart (Nymbphoides cordata), and spotted pondweed 

20 (Potamogeton pulcher) as either threatened or endangered as described in Section 2.2.7. All 

21 four plants have historic or current records of occurrence in coastal portions of Bucks County 

22 (PNHP 2012a). 

23 LGS-related activity that could affect the Farwell’s water-milfoil, broad-leaved water-milfoil, 

24 floating-heart, and spotted pondweed and their habitat is the intermittent withdrawal of Delaware 

25 River water for the LGS cooling system. Direct impacts could include mortality if the plants were 

26 sucked into the intake at the Point Pleasant Pumping Station. As described above, preferred 

27 habitat does not occur near the Point Pleasant Pumping Station. LGS license renewal would 

28 include continued operation at the Point Pleasant Pumping Station. However, as described in 

29 Section 2.1.6, Exelon’s withdrawal of water from the Delaware River is secondary to its 

30 withdrawal of water from the Schuylkill River, and Exelon plans to continue to rely less on the 

31 Delaware River and more on the Schuylkill River in the future (Exelon 2012a). LGS license 

32 renewal would not involve new construction, refurbishment, ground-disturbing activities, or 

33 changes to existing land use conditions at the Point Pleasant Pumping Station. Transmission 

34 lines associated with LGS do not cross any portion of the Delaware River (Exelon 2011a). 

35 The NRC staff contacted PFBC to request information on potential impacts to 

36 Pennsylvania-protected species. In an October 5, 2011, letter to the NRC, PFBC (2011b) did 

37 not identify the Farwell’s water-milfoil, broad-leaved water-milfoil, floating-heart, and spotted 

38 pondweed aquatic plants as a concern in regard to LGS’s proposed license renewal. 

39 4.8.2.3. Conclusion for Aquatic Species

40 The NRC staff evaluated the three ESA-listed species, two candidate species, and eight 

41 additional Pennsylvania-protected species and species of special concern that could be present 

42 in the action area defined in Section 2.2.8. In its evaluation, NRC staff examined the known 

43 distributions and habitat ranges of those species, the ecological impacts of the operation of LGS

44 on the species, and the LGS-related occurrence and monitoring studies described above. In 

45 addition, no critical habitat occurs within the action area. Given that LGS license renewal would 

46 not involve new construction, refurbishment, ground-disturbing activities, or changes to existing 

47 land use conditions at LGS-associated facilities or transmission lines, the continued operation of 
Environmental Impacts of Operation

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1 LGS is not likely to noticeably affect these species. Thus, the NRC staff concludes that the 

2 impact on protected aquatic species from the proposed license renewal would be SMALL. 

3 4.8.3. Terrestrial Species and Habitats

4 Species and Habitats Protected Under the Endangered Species Act

5 Bog Turtle (Clemmys muhlenbergii)

6 The following analysis of the impacts of LGS license renewal on the bog turtle constitutes the 

7 biological assessment for that species required by the ESA. Under the ESA, an agency’s 

8 requirement to prepare a biological assessment is independent of consultation and can be 

9 completed through the NEPA process. 

10 Section 2.2.8 concludes that the bog turtle could occur in suitable wetland habitat on the LGS 

11 site, within palustrine emergent and forested wetlands along the Schuylkill River, or within 

12 wetland habitat along the transmission line corridors. 

13 Small sections of the LGS site contain suitable habitat for bog turtles. According to Figure 10, 

14 “Habitat Map of Limerick Generating Station,” in Exelon’s Wildlife Management Plan 

15 (Exelon 2012a), palustrine emergent and forested wetlands lie along the Schuylkill River 

16 adjacent to riparian forest, old field, and agricultural land. Within the LGS site, the LGS license 

17 renewal would include maintenance and operation activities within developed or previously 

18 disturbed areas and would not involve new construction, refurbishment, ground-disturbing 

19 activities, changes to conduct of operations, or changes to existing land use conditions in either 

20 natural or developed areas. The proposed license renewal would have no direct or indirect 

21 adverse impacts to LGS site wetlands; therefore, it would have no direct or indirect adverse 

22 effects on the bog turtle. As noted in Section 2.2.7, poaching and loss of habitat are two of the 

23 primary threats to the species. Continued operation of LGS during the license renewal term 

24 would preserve the existing wetlands on the LGS site. Site security would prevent public 

25 access to the site, and thus, prevent poaching. Therefore, continued operation of the LGS 

26 could result in beneficial effects to the species. 

27 The LGS license renewal would include Exelon’s continued operation and maintenance of the 

28 Perkiomen Pumphouse, Bradshaw Reservoir and Pumphouse, and the Bedminster Water 

29 Processing Facility. Exelon would only perform maintenance and operation activities within 

30 developed or previously disturbed areas during the license renewal period. Thus, the proposed 

31 license renewal would have no direct or indirect adverse impacts to habitat at these offsite 

32 facilities and no direct or indirect adverse effects on the bog turtle. 

33 The LGS license renewal also would include continued operation and maintenance of four 

34 transmission line corridors that extend from the Limerick site and travel through Montgomery 

35 and Chester Counties (Section 2.1.5 describes the in-scope transmission lines in more detail). 

36 Although the NRC does not license or regulate PECO, which owns and operates the 

37 transmission lines, the NRC considers all transmission lines that were constructed specifically to 

38 connect the facility to the transmission system in its NEPA analysis. The transmission lines 

39 associated with LGS cross rivers, streams, and wetlands that have the potential to be bog turtle 

40 habitat. PECO must maintain the transmission lines and associated structures and manage 

41 vegetation along the transmission line corridors to prevent interference with the lines. Line and 

42 vegetation maintenance may result in direct impacts to bog turtles, including takes of bog turtles 

43 or their eggs and disturbance or destruction of bog turtle habitat. Potential indirect effects could 

44 include prevention of natural successional changes in transmission line plant communities over 

45 time. This indirect effect could positively affect bog turtles because they prefer early 

46 successional wetlands. 
Environmental Impacts of Operation

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1 Generally, PECO maintains transmission line corridors to promote the growth of shrubs, 

2 grasses, and other low-growing vegetation. Because bog turtles prefer shallow, open-canopy 

3 wetlands, the need for maintenance in these areas is much lower. If PECO needs to perform 

4 maintenance in wetland areas, it takes a number of precautions to avoid impacts to the bog 

5 turtle or its habitat. 

6 First, PECO trains all of its contractors to be knowledgeable about Federally protected species 

7 they may encounter while working and that they are able to identify potential wetlands and 

8 obtain the necessary permits before proceeding with work. 

9 Second, PECO typically performs mechanical vegetation maintenance activities on foot and 

10 does not operate heavy machinery near wetlands and water bodies. This type of maintenance 

11 avoids the potential for heavy machinery to crush turtles or nests or to create ruts, crush 

12 wetland vegetation, or otherwise alter bog turtle habitat. PECO also makes an effort to perform 

13 work in wetland areas during the winter months when the ground is hard or frozen. Foot traffic 

14 could result in some minimal disturbance of wetland habitat. However, foot traffic would create 

15 insignificant impacts (i.e., those impacts that would never reach the scale where a take might 

16 occur) or discountable impacts (i.e., those impacts that cannot be meaningfully measured, 

17 detected, or evaluated). 

18 Finally, PECO must obtain several permits and certifications for maintenance activities in 

19 wetlands or near waterbodies, which for a given work area may include: (1) a General Permit or 

20 Water Obstruction and Encroachment General Permit issued jointly by the USACE and PADEP, 

21 (2) a CWA 404 permit issued by the USACE, or (3) an erosion and sedimentation control plan 

22 from the appropriate county conservation district. Within Montgomery and Chester Counties 

23 (through the in-scope transmission lines traverse), PADEP requires applicants for a General 

24 Permit or Water Obstruction and Encroachment General Permit to comply with bog turtle 

25 screening requirements, which includes a site assessment by qualified PADEP personnel 

26 (PADEP 2006c). In cases in which a site assessment identifies potential bog turtle habitat, the 

27 USACE and PADEP will not issue a permit until the FWS determines that the project will not 

28 have an impact on the species (PADEP 2006c). In cases in which PECO must obtain a 

29 CWA 404 permit, this permitting process triggers a PECO company process during which 

30 PECO personnel must review the proposed maintenance activities for potential impacts to bog 

31 turtles and coordinate with FWS to avoid such impacts. 

32 PECO’s maintenance of transmission line corridors to promote low-growing vegetation may 

33 benefit the species by preventing or stalling natural plant succession. Successional changes 

34 within wetland communities often gradually eliminate some wetland vegetation and reduce open 

35 areas that bog turtles use for nesting and basking (Morrow et al. 2001). In a study of bog turtles 

36 at two sites in Maryland, Morrow et al. (2001) found that bog turtles avoided dense and 

37 higher-growing vegetation and sought areas with low-lying cover. 

38 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts 

39 to Federally protected species. In a March 22, 2011, letter to Exelon, FWS (2011a) indicated 

40 that the bog turtle occurs or may occur in or near the project area, but that the proposed action 

41 is not likely to have an adverse effect on the bog turtle based on the FWS’s review of the project 

42 description and location. In a November 22, 2011, letter to the NRC, the FWS (2011b) 

43 confirmed that the conclusion in its previous letter to Exelon was still appropriate. 

44 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely 

45 to adversely affect the bog turtle because effects to the species would be insignificant, 

46 discountable, or beneficial. 
Environmental Impacts of Operation

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1 Indiana Bat (Myotis sodalis)

2 Section 2.2.8 concludes that the Indiana bat could occur in suitable forest habitat within the 

3 action area. Potential types of Indiana bat habitat that occur in the action area include summer 

4 roosting habitat, foraging habitat, and commuting habitat. Summer roosting habitat includes 

5 trees with exfoliating bark, cracks, or crevices in trees or snags (dead trees) that are greater 

6 than 3-in. (8-cm) diameter-at-breast height (FWS 2012a). Foraging habitat includes forest 

7 patches, wooded riparian corridors, and natural vegetation adjacent to such habitats 

8 (FWS 2012a). Commuting habitat includes wooded tracts, tree lines, wooded hedgerows, 

9 streams, or other linear pathways within or connected to roosting or foraging habitat 

10 (FWS 2012a). 

11 The LGS license renewal would not disturb or alter any natural habitats within the LGS site or 

12 offsite facilities associated with the LGS makeup water system. Thus, no direct or indirect 

13 adverse effects would result from continued operation and maintenance of these facilities. If the 

14 Indiana bat occurs on the LGS site, continued operation of LGS would be beneficial to the 

15 species because it would preserve forest habitat that might otherwise be developed or 

16 converted to some other land use. 

17 Because the majority of LGS transmission line corridors contain low-growing plant communities 

18 dominated by grasses, herbs, and small shrubs, PECO’s continued maintenance of the lines 

19 generally would not alter the existing habitat. Occasionally, PECO may need to remove trees 

20 that either grow tall enough to interfere with the lines or trees that die and could fall on the lines. 

21 In such cases, PECO could have to remove trees that provide summer roosting habitat for 

22 Indiana bats. However, PECO trains all of its contractors to be knowledgeable about Federally 

23 protected species they may encounter while working. If a tree that provided potential Indiana 

24 bat habitat required removal, PECO would typically coordinate with FWS and the appropriate 

25 state agencies. PECO could also perform such maintenance in the fall or winter months when 

26 the Indiana bat has migrated to hibernation sites. Thus, this potentially adverse impact would 

27 be insignificant because it is unlikely to result in a take. 

28 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts 

29 to Federally protected species. The FWS did not mention that the Indiana bat was of particular 

30 concern in either its March 22, 2011, letter to Exelon (FWS 2011a) or its November 22, 2011, 

31 letter to the NRC (FWS 2011b). 

32 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely 

33 to adversely affect the Indiana bat because effects to the species would be insignificant. 

34 Small-Whorled Pogonia (Isotria medeoloides)

35 Section 2.2.8 indicates that three extant populations of the small-whorled pogonia occur in 

36 Pennsylvania, and at least one of these populations occurs in Chester County. Thus, 

37 Section 2.2.8 conservatively concludes that the small-whorled pogonia could occur in areas of 

38 suitable habitat along or near the transmission line corridor that runs through Chester County. 

39 Because the small-whorled pogonia does not occur in Montgomery or Bucks Counties, 

40 continued operation and maintenance of the LGS site and offsite facilities associated with the 

41 LGS makeup water system would have no direct or indirect effects on the small-whorled 

42 pogonia. LGS license renewal would include continued operation and maintenance of four 

43 transmission line corridors that extend from the Limerick site and travel through Montgomery 

44 and Chester Counties. The corridor within Chester County is about 13 mi (21 km) long 

45 (Section 2.1.5 describes the in-scope transmission lines in more detail). The small-whorled 

46 pogonia generally grows in young and maturing stands of mixed-deciduous or 

47 mixed-deciduous/coniferous forests in areas close to logging roads, streams, or other features 
Environmental Impacts of Operation

4-19

1 that create long-persisting breaks in the forest canopy. Therefore, the species could occur near 

2 the transmission line corridor, but it is unlikely to occur in the corridor itself. Because the 

3 species is unlikely to occur within the corridor, it would not experience any direct adverse effects 

4 such as trampling caused by worker foot traffic, crushing caused by vehicles and equipment, or 

5 herbicide application when workers spray adjacent vegetation. Depending on the proximity of 

6 the small-whorled pogonia to the transmission line corridor, the species could experience 

7 indirect adverse effects such as taking up water containing chemicals from herbicide runoff. 

8 However, PECO maintains vegetation on a 5-year cycle and selectively sprays herbicides by 

9 hand, so the indirect effects from herbicide application would be so small as to not be able to be 

10 meaningfully measured or detected and would not reach the scale where a take would occur. 

11 Thus, such effects would be discountable and insignificant. 

12 Both Exelon and the NRC staff have contacted FWS to request information on potential impacts 

13 to Federally protected species. The FWS did not mention the small-whorled pogonia was of 

14 particular concern in either its March 22, 2011, letter to Exelon (FWS 2011a) or its 

15 November 22, 2011, letter to the NRC (FWS 2011b). 

16 The NRC staff concludes that the proposed LGS license renewal may affect, but is not likely 

17 to adversely affect the small-whorled pogonia because effects to the species would be 

18 insignificant or discountable. 

19 Designated Critical Habitat

20 The NRC staff did not identify any Federally designated critical habitat within the action area 

21 during its review (see Section 2.2.7). Additionally, in its correspondence with Exelon and the 

22 NRC, the FWS (2011a, 2011b) did not identify any designated critical habitat. Thus, the NRC 

23 staff concludes that the proposed license renewal would have no effect on designated critical 

24 habitat. 

25 Proposed Species and Proposed Critical Habitat

26 The NRC staff did not identify any Federally proposed species or proposed critical habitat within 

27 the action area during its review (see Section 2.2.7). Additionally, in its correspondence with 

28 Exelon and the NRC, the FWS (2011a, 2011b) did not identify any proposed species or 

29 proposed critical habitat. Thus, the NRC staff concludes that the proposed license renewal 

30 would have no effect on Federally proposed species or proposed critical habitat. 

31 Species Protected Under the Bald and Golden Eagle Protection Act

32 Though bald eagles occur throughout the action area, no known nests are in close proximity to 

33 any of the LGS site buildings, parking lots, or other structures; the LGS makeup water system 

34 offsite facilities; or along the transmission line corridors that could be disturbed by operations or 

35 maintenance activities associated with the proposed license renewal. Because the proposed 

36 license renewal does not involve construction or land disturbances, the proposed license 

37 renewal would not affect any bald eagle habitat. The NRC staff concludes that the impacts of 

38 the proposed LGS license renewal on the bald eagle would be SMALL. 

39 Species Protected Under the Migratory Bird Treaty Act

40 As discussed in Section 2.2.7, a variety of migratory birds inhabit the LGS site and surrounding 

41 region. Because the proposed license renewal does not involve construction or land 

42 disturbances, the NRC staff concludes that the impacts of the proposed LGS license renewal on 

43 migratory birds would be SMALL. 
Environmental Impacts of Operation

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1 Species Protected by the Commonwealth of Pennsylvania

2 Section 2.2.8.3 discusses species protected under the Pennsylvania Endangered Species 

3 Program. Ten Pennsylvania-listed birds and two Pennsylvania-listed plants occur or have 

4 occurred on the LGS site since the plant began operating. An additional eight plant species 

5 occur near the transmission line corridors. One Pennsylvania-listed reptile, the eastern redbelly 

6 turtle (Pseudemys rubriventris), occurs in the vicinity of the LGS site. Because the proposed 

7 license renewal does not involve construction or land disturbances, the NRC staff concludes 

8 that the impacts of the proposed LGS license renewal on Pennsylvania-protected species on 

9 the LGS site or at offsite facilities associated with the LGS makeup water system would be 

10 SMALL. 

11 Continued transmission line maintenance would not adversely affect any of the 

12 Pennsylvania-listed birds or the eastern redbelly turtle. As discussed in Section 2.1.5, PECO 

13 has implemented an avian management program to ensure that it does not unnecessarily 

14 disturb or harm birds or nests and to ensure compliance with applicable Federal and state bird 

15 regulations. The mitigative measures described above for the bog turtle would also be 

16 protective of the eastern redbelly turtle. Because the eastern redbelly turtle inhabits aquatic and 

17 wetland habitats, the likelihood of habitat disturbance or direct effects to this species is lower 

18 because PECO follows more stringent procedures when performing work in these areas. 

19 Additionally, in its February 11, 2011, letter to Exelon, the PFBC (2011a) noted that it does not 

20 anticipate the proposed license renewal will have any significant adverse impacts on 

21 Pennsylvania-listed species of concern under the PFBC’s jurisdiction. 

22 Some of the Pennsylvania-listed plants discussed in Section 2.2.8.3 occur in woodlands or other 

23 habitats near, but not directly within, the transmission line corridors. Continued transmission 

24 line maintenance would not affect these plant species because PECO only manages vegetation 

25 within the corridor. The other plant species occur in habitats compatible with transmission lines, 

26 such as old fields or other early successional communities, and PECO likely would not perform 

27 intensive maintenance or use herbicides in these areas because these habitats already contain 

28 low-growing vegetation. The NRC staff concludes that the impacts of the proposed license 

29 renewal on Pennsylvania-listed plants along the transmission line corridors would be SMALL. 

30 Conclusion

31 The NRC staff concludes that the impacts of the proposed LGS license renewal on protected 

32 terrestrial species and habitats would be SMALL as defined by the NRC for the purposes of 

33 NEPA. 
Environmental Impacts of Operation

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1 4.9. Human Health

2 Table 4–8 lists the Category 1 and 2 issues related to human health that are applicable to LGS. 

3 Table 4–8. Human Health Issues

Issue GEIS Section Category

Radiation exposure to the public during refurbishment 3.8.1a 1

Occupational radiation exposures during refurbishment 3.8.2a 1

Microbiological organisms (occupational health) 4.3.6 1

Microbiological organisms (public health) 4.3.6(b) 2

Noise 4.3.7 1

Radiation exposures to public (license renewal term) 4.6.2 1

Occupational 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

Human health impact from chemicals To be 

determined(c) 1 

Physical occupational hazards To be 

determined(c) 1 

(a) Issues apply to refurbishment, an activity that LGS does not plan to undertake

(b) Issue applies to plants with features such as cooling lakes or cooling towers that discharge to a small river. 

The issue applies to LGS.

(c) NRC 2012b

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

4 4.9.1. Generic Human Health Issues

5 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B–1, applicable to LGS in 

6 regard to human health impacts are listed in Table 4–9. Exelon stated in its ER (Exelon 2011a) 

7 that it was aware of one new radiological issue associated with the renewal of the LGS 

8 operating license, tritium in groundwater. Exelon’s groundwater monitoring program for 

9 radioactive material is discussed in Sections 2.2.5, 4.5.2, and 4.11 of this document. Based on 

10 its review of LGS’s groundwater monitoring data, the NRC staff concluded that the issue, while 

11 new, is not significant. The NRC staff has not identified any new and significant information

12 during its independent review of Exelon’s ER, the site visit, the scoping process, or its 

13 evaluation of other available information.

14 4.9.1.1. New Category 1 Human Health issues

15 As described in Section 1.4 of this draft SEIS, the NRC has approved a revision to its 

16 environmental protection regulation, 10 CFR Part 51. With respect to the human health, the 

17 revised rule amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new 

18 Category 1 issues, “Human health impact from chemicals” and “Physical occupational hazards.” 

19 The first issue considers the impacts from chemicals to plant workers and members of the 

20 public. The second issue only considers the nonradiological occupational hazards of working at 
Environmental Impacts of Operation

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1 a nuclear power plant. An understanding of these non-radiological hazards to nuclear power 

2 plant workers and members of the public have been well established at nuclear power plants 

3 during those plants’ current licensing terms. The impacts from chemical hazards are expected 

4 to be minimized through the licensee’s use of good industrial hygiene practices as required by 

5 permits and Federal and state regulations. Also, the impacts from physical hazards to plant 

6 workers will be of small significance if workers adhere to safety standards and use protective 

7 equipment as required by Federal and state regulations. The impacts to human health for each 

8 of these new issues from continued plant operations are SMALL.

9 The NRC staff has not identified any new and significant information related to these non10 radiological issues during its independent review of LGS’s ER, the site audit, and the scoping 

11 process. Therefore, the NRC staff concludes that there would be no impact to human health 

12 from chemicals or physical hazards beyond those impacts described in Table B–1 in 

13 Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and, therefore, the impacts are 

14 SMALL. 

15 4.9.2. Radiological Impacts of Normal Operations

16 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B–1, applicable to LGS in 

17 regard to radiological impacts to human health are listed in Table 4–8. The NRC staff has not 

18 identified any new and significant information related to radiological issues during its 

19 independent review of Exelon’s ER, the site audit, the scoping process, or its evaluation of other 

20 available information. Therefore, the NRC staff concludes that there would be no impact from

21 radiation exposures to the public or to workers during the license renewal term beyond those 

22 discussed in the GEIS. 

23 The findings in the GEIS are as follows:

24 • Radiation exposures to the public (license renewal term). Based on 

25 information in the GEIS, the Commission found the following: 

26 • Radiation doses to the public will continue at current levels associated with 

27 normal operations. 

28 • Occupational exposures (license renewal term). Based on information in the 

29 GEIS, the Commission found the following: 

30 • Projected maximum occupational doses during the license renewal term are 

31 within the range of doses experienced during normal operations and normal 

32 maintenance outages, and would be well below regulatory limits. 

33 According to the GEIS, the impacts to human health are SMALL, and additional plant-specific 

34 mitigation measures are not likely to be sufficiently beneficial to be warranted. 

35 There are no Category 2 issues related to radiological impacts of routine operations. 

36 The information presented below is a discussion of selected radiological programs conducted at

37 LGS. 

38 Limerick Generating Station Radiological Environmental Monitoring Program

39 LGS conducts a Radiological Environmental Monitoring Program (REMP) to assess the 

40 radiological impact, if any, to its employees, the public, and the environment from the operations 

41 at LGS, Units 1 and 2. The REMP measures the aquatic, terrestrial, and atmospheric 

42 environment for radioactivity, as well as the ambient radiation. In addition, the REMP measures 

43 background radiation (i.e., cosmic sources, global fallout, and naturally occurring radioactive 

44 material, including radon). The REMP supplements the radioactive effluent monitoring program 
Environmental Impacts of Operation

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1 by verifying that any measurable concentrations of radioactive materials and levels of radiation 

2 in the environment are not higher than those calculated using the radioactive effluent release 

3 measurements and transport models. 

4 An annual radiological environmental operating report (REOP) is issued, which contains a 

5 discussion of the results of the monitoring program. The report contains data on the monitoring 

6 performed for the previous year. The REMP collects samples of environmental media in order 

7 to measure the radioactivity levels that may be present. The media samples are representative 

8 of the radiation exposure pathways that may affect the public. 

9 The LGS REMP is made up of three categories based on the exposure pathways to the public. 

10 They are as follows: atmospheric, aquatic, and ambient gamma radiation. The atmospheric 

11 samples taken around LGS are airborne particulate, airborne iodine, milk, and broad leaf 

12 vegetation. Airborne iodine and particulate samples are taken using vacuum pumps and glass 

13 fiber filters. The aquatic pathway samples are taken from surface water and drinking water 

14 sources. Also included in this pathway are sediment samples and fish samples. The ambient 

15 gamma radiation pathway measures direct exposure from environmental radiation doses using 

16 thermoluminescent dosimeters. 

17 In addition to the REMP, LGS has a groundwater protection program designed to monitor the 

18 onsite plant environment for the detection of leaks from plant systems and pipes containing 

19 radioactive liquid (see Sections 2.2.5.2 and 4.5.2). 

20 The NRC staff reviewed the LGS annual REOPs for 2007 through 2011 to look for any 

21 significant impacts to the environment or any unusual trends in the data (Exelon 2008a, 2009a, 

22 2010a, 2011b, 2012b). A 5-year period provides a data set that covers a broad range of 

23 activities that occur at a nuclear power plant, such as refueling outages, routine operation, and 

24 years in which there may be significant maintenance activities. Based on the NRC staff’s 

25 review, no adverse trends (i.e., steadily increasing buildup of radioactivity levels) were observed 

26 and the data showed that there was no measurable impact to the environment from LGS 

27 operations. 

28 Groundwater Protection Program

29 A radioactive groundwater protection program was established at LGS in 2006 to assess 

30 potential impacts to groundwater from plant’s operation. 

31 In 2007, the Nuclear Energy Institute (NEI) established a standard for monitoring and reporting 

32 radioactive isotopes in groundwater: NEI 07-07, “Industry Ground Water Protection Initiative–

33 Final Guidance Document” (NEI 2007). LGS implemented the recommendations of this industry 

34 standard. Data from the groundwater monitoring program are contained in the annual 

35 radiological environmental operating report submitted to the NRC in May of each year. These 

36 reports are available for review by the public through the Agencywide Documents Access and 

37 Management System (ADAMS) electronic reading room available through the NRC website.

38 Additional information on the groundwater protection program is discussed in Sections 2.2.5 and 

39 4.5.2 of this SEIS. 

40 Pennsylvania Department of Environmental Protection Bureau of Radiation Detection 

41 Environmental Monitoring Program 

42 The Bureau of Radiation Protection (BRP) performs its own independent environmental 

43 monitoring around the LGS site and other nuclear facilities located in Pennsylvania. All 

44 analyses of environmental media (i.e., soil, air, water, and vegetation) are performed by its 

45 Bureau of Laboratories (BOL). The state’s BRP performs the monitoring of direct radiation from 

46 a facility using thermoluminescent dosimeters (TLDs). 
Environmental Impacts of Operation

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1 The NRC staff reviewed the state’s environmental summary reports for 2003 through 2004 (the 

2 most recent reports available at the time of the NRC’s review) (PADEP undated). In each of the 

3 reports, the state concluded that the sample data indicated no release of radioactive material to 

4 the environment that exceeded the regulatory or license limits of the PADEP or the NRC. 

5 Limerick Generating Station Radioactive Effluent Release Program

6 All nuclear plants were licensed with the expectation that they would release radioactive 

7 material to both the air and water during normal operation. However, NRC regulations require 

8 that radioactive gaseous and liquid releases from nuclear power plants must meet radiation 

9 dose-based limits specified in 10 CFR Part 20, and the as low as is reasonably achievable 

10 (ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation 

11 dose that members of the public can receive from radioactive effluents released by a nuclear 

12 power plant. In addition, nuclear power plants are required by 10 CFR 50.36(a) to submit an 

13 annual report to the NRC that lists the types and quantities of radioactive effluents released into 

14 the environment. The radioactive effluent release reports are available for review by the public 

15 through the ADAMS electronic reading room available through the NRC website. 

16 The NRC staff reviewed the annual radioactive effluent release reports for 2007 through 2011

17 (Exelon 2008b, 2009b, 2010b, 2011c, 2012c). The review focused on the calculated doses to a 

18 member of the public from radioactive effluents released from LGS. The doses were compared 

19 to the radiation protection standards in 10 CFR 20.1301 and the ALARA dose design objectives 

20 in Appendix I to 10 CFR Part 50. 

21 Dose estimates for members of the public are calculated based on radioactive gaseous and 

22 liquid effluent release data and atmospheric and aquatic transport models. The 2011 annual 

23 radioactive effluent release report (Exelon 2012d) contains a detailed presentation of the 

24 radioactive discharges and the resultant calculated doses. The following summarizes the 

25 calculated dose to a member of the public located outside the LGS site boundary from 

26 radioactive gaseous and liquid effluents released during 2011: 

27 • The combined total-body dose to an offsite member of the public from LGS, 

Units 1 and 2 radioactive liquid effluents was 8.38x10-2 mrem (8.38x10-4 28

29 mSv), which is well below the combined 6 mrem (0.06 mSv) dose criterion for 

30 two reactor units in Appendix I to 10 CFR Part 50.

31 • The organ (liver) dose to an offsite member of the public from LGS, Units 1 

and 2 radioactive liquid effluents was 8.38x10-2 mrem (8.38x10-4 32 mSv), which 

33 is well below the combined 20 mrem (0.20 mSv) dose criterion for two reactor 

34 units in Appendix I to 10 CFR Part 50.

35 • The air dose at the site boundary from gamma radiation in gaseous effluents 

from LGS, Units 1 and 2 was 1.46x10-2 mrad (1.46x10-4 36 mGy), which is well 

37 below the combined 20 mrad (0.2 mGy) dose criterion for two reactor units in 

38 Appendix I to 10 CFR Part 50.

39 • The air dose at the site boundary from beta radiation in gaseous effluents 

from LGS, Units 1 and 2 was 8.73x10-3 mrad (8.73x10-5 40 mGy), which is well 

41 below the combined 40 mrad (0.4 mGy) dose criterion for two reactor units in 

42 Appendix I to 10 CFR Part 50.

43 • The dose to an organ (bone) from radioactive iodine, radioactive particulates, 

and carbon-14 from LGS, Units 1 and 2 was 4.13x10-1 44 mrem 

(4.13x10-3 45 mSv), which is well below the combined 30 mrem (0.3 mSv) dose 

46 criterion for two reactor units in Appendix I to 10 CFR Part 50.
Environmental Impacts of Operation

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1 • No radiation above background was detected at the site boundary from direct 

2 radiation, as measured by TLDs. There is no dose criterion for direct 

3 radiation in Appendix I to 10 CFR Part 50. The data is included in the 

4 summation of doses from all radioactive effluent release pathways to 

5 determine compliance with EPA’s 40 CFR Part 190 dose standard of 

6 25 mrem (0.25 mSv) for the total dose to members of the public from the 

7 reactor units at the LGS site.

8 • The NRC staff summed the applicant’s data on the individual total body 

9 doses from radioactive gaseous and liquid effluents from both units and 

10 added it to the dose from direct radiation to obtain the maximum all pathways 

11 dose to an offsite member of the public from the operation of LGS, Units 1 

12 and 2. The dose to a member of the public from all radioactive releases in 

2011 was 1.30x10-1 mrem (1.30x10-3 13 mSv), which is well below the 25 mrem 

14 (0.25 mSv) dose standard in EPA’s 40 CFR Part 190. 

15 The NRC staff’s review of the LGS radioactive effluent control program showed that radiation 

16 doses to members of the public were controlled within Federal radiation protection standards 

17 contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 40 CFR Part 190. 

18  The applicant has no plans to conduct refurbishment activities during the 

19 license renewal term; however, routine plant refueling and maintenance 

20 activities currently performed will continue during the license renewal term. 

21 Based on the past performance of the radioactive waste system to maintain 

22 the dose from radioactive effluents to be ALARA, similar performance is 

23 expected during the license renewal term. Continued compliance with 

24 regulatory requirements is expected during the license renewal term; 

25 therefore, the impacts from radioactive effluents to the public would be 

26 SMALL. 

27 4.9.3. Microbiological Organisms

28 The effects of thermophilic microbiological organisms on human health (see Table 4–8), are

29 categorized as a Category 2 issue and require a plant-specific evaluation during the license 

30 renewal process for plants using closed-cycle cooling, located on a small river. The Schuylkill 

31 River is considered a small river because its average annual flow is approximately 

6.3 x 1010 cubic feet per year (ft3

/yr) (1.7 x 108 cubic meters per year (m3 32 /yr)), which is less than 

the threshold value of 3.15 x 1012 ft3

/yr (9 x 1010 m3 33 /yr) in 10 CFR 51.53(c)(3)(ii)(G) 

34 (Exelon 2011a). Therefore, the effects of the LGS cooling water discharge on microbiological 

35 organisms must be addressed for LGS license renewal. 

36 The Category 2 designation is based on the magnitude of the potential public health impacts 

37 associated with thermal enhancement of enteric pathogens such as Salmonella spp. and 

38 Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living 

39 amoebae Naegleria spp., and Legionella spp. bacteria (NRC 1996). Thermophilic 

40 microorganisms generally occur at temperatures of 77 °F to 176 °F (25 °C to 80 °C) with an 

41 optimal growth temperature range of 122 °F to 150 °F (50 °C to 66 °C), and minimum and 

42 maximum temperature tolerances of 68 °F (20 °C) and 158 °F (70 °C), respectively. However, 

43 thermal preferences and tolerances vary across bacterial groups. Pathogenic thermophilic 

44 microbiological organisms of concern during nuclear reactor operation typically have optimal 

45 growing temperatures of approximately 99 °F (37 °C) (Joklik and Smith 1972). 

46 Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal 

47 infections in immunocompromised individuals. The organism produces toxins harmful to 
Environmental Impacts of Operation

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1 humans and animals. It has an optimal growth temperature of 99 °F (37 °C) (Todar 2012). 

2 Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for 

3 Legionnaires’ disease, with the onset of pneumonia in the first 2 weeks of exposure. Risk 

4 groups for Legionella spp. include elderly, cigarette smokers, persons with chronic lung or 

5 immunocompromising disease, and persons receiving immunosuppressive drugs. 

6 The LGS NPDES permit (No. PA0051926) requires the temperature in the thermal discharge to 

7 be monitored at least once weekly for compliance with an instantaneous maximum limit of 

8 110 °F (43.3 °C) for the protection of human health. Although thermophilic microbiological 

9 organisms of concern during nuclear reactor operation could grow at that stated instantaneous 

10 maximum temperature limit, there are several years of Discharge Monitoring Report (DMR) data 

11 showing that maximum summer discharge temperatures range from 90 °F to 95 °F (32.2 °C to 

12 35.0 °C) (Exelon 2011a). These temperatures are below the stated optimal growing 

13 temperature of approximately 99°F (37°C); therefore, ambient river conditions are not likely to 

14 support the proliferation of the pathogenic organisms of concern.

15 Exelon requested PADEP to provide comments or concerns about LGS’s contribution to 

16 potential health effects resulting from thermophilic organisms. Exelon requested PADEP to 

17 alternatively confirm Exelon’s conclusion that operation of LGS during the period of extended 

18 operation would not enhance growth of thermophilic pathogens. In response, PADEP identified 

19 that it does not have any data associated with thermophilic organisms in the Schuylkill River nor 

20 has it conducted any investigations on the impact or potential impact of the LGS discharge on 

21 thermophilic organisms in the river. As a result, PADEP is unable to make any conclusions 

22 regarding the effect on public health from thermophilic organisms in the Schuylkill River 

23 (Exelon 2011a). 

24 DRBC designated that uses to be maintained in the Schuylkill River in the vicinity of LGS 

25 include secondary contact recreation, in which body contact is either incidental or accidental,

26 and in which the probability of ingesting appreciable quantities of water, particularly through 

27 nasal passages, is minimal. 

28 LGS currently discharges sanitary sewage to the local publicly owned treatment works for 

29 treatment, which further reduces the potential for the facility’s discharge to introduce pathogenic 

30 microorganisms that could present a threat to recreational users of the Schuylkill River. 

31 The NRC staff reviewed all documents applicable to this Category 2 issue, including Exelon’s 

32 ER and the LGS NPDES permit. The NRC staff concludes that for the reasons above, 

33 thermophilic microbiological organisms are unlikely to present a public health hazard as a result 

34 of LGS discharges to the Schuylkill River. The NRC staff concludes that impacts on public 

35 health from thermophilic microbiological organisms from continued operation of LGS in the 

36 license renewal period would be SMALL. 

37 4.9.4. Electromagnetic Fields—Acute Effects

38 Based on the GEIS, the Commission found that electric shock resulting from direct access to 

39 energized conductors or from induced charges in metallic structures has not been found to be a 

40 problem at most operating plants and generally is not expected to be a problem during the 

41 license renewal term. However, site-specific review is required to determine the significance of 

42 the electric shock potential along the portions of the transmission lines that are within the scope 

43 of this SEIS. 

44 In the GEIS (NRC 1996), the Commission found that without a review of the conformance of 

45 each nuclear plant transmission line with National Electrical Safety Code (NESC) criteria, it was 

46 not possible to determine the significance of the electric shock potential (IEEE 2002). 
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1 Additionally, the Commission found that evaluation of individual plant transmission lines is 

2 necessary because the issue of electric shock safety was not addressed in the licensing 

3 process for some plants. For other plants, land use in the vicinity of transmission lines may 

4 have changed, or power distribution companies may have chosen to upgrade line voltage. To 

5 comply with 10 CFR 51.53(c)(3)(ii)(H), Exelon must provide an assessment of the impact of the 

6 proposed action on the potential shock hazard from the transmission lines if the transmission 

7 lines that were constructed for the specific purpose of connecting the plant to the transmission 

8 system do not meet the recommendations of the NESC for preventing electric shock from 

9 induced currents. 

10 Limerick Units 1 and 2 electrical outputs are delivered to the PJM Interconnection by the LGS 

11 transmission system. Each Limerick unit is provided with an independent substation, which are 

12 230 kilovolts (kV) for Unit 1 and 500 kV for Unit 2. Four 230-kV transmission lines, the 

13 Limerick-Cromby 220-60 line, the Limerick-Cromby 220-61 line, the Cromby-North Wales 

14 220-62 line, and the Cromby-Plymouth Meeting 220-63/64 line, were constructed to connect the 

15 Limerick Unit 1 substation to the electric grid. One 500-kV transmission line, the 

16 Limerick-Whitpain 5031 line, was constructed to connect the Limerick Unit 2 substation to the 

17 electric grid. These are the lines that are within scope of license renewal. Exelon developed an 

18 electric field strength policy for the design and operation of its transmission system. The policy 

19 is intended to minimize shock hazards consistent with the NESC criteria. Exelon used the 

20 Electric Power Research Institute (EPRI) HERB 2.0 software to determine NESC compliance. 

21 Their analysis determined that there are no locations within the right-of-way under these 

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

23 parked beneath the lines. Therefore, the lines meet the NESC 5 mA criterion. The maximum 

24 induced current calculated for the power lines was 4.6 mA on the Cromby-Plymouth Meeting 

25 220-63/64 line (Exelon 2011a). 

26 The LGS transmission line corridor crosses over highways, streets, other public places, or 

27 property owned by others for which PECO, a subsidiary of Exelon Corporation, has permits, 

28 grants, easements, or licenses. PECO, and owners and operators of the transmission lines, 

29 conduct surveillance and maintenance activities to verify that design ground clearances will not 

30 change. These procedures include routine inspection for clearance problems by aircraft 

31 periodically. Ground inspections are conducted yearly for clearance problems, which are 

32 brought to the attention of the appropriate organizations for maintenance. Exelon expects that 

33 it, as well as PECO, will continue to use these or similar processes during the period of 

34 extended operation. No land use changes are anticipated in the vicinity of the corridor. 

35 Exelon’s and PECO’s periodic surveillance of the transmission system assures that ground 

36 clearances would remain in compliance with NESC criteria (Exelon 2011a). 

37 The NRC staff reviewed the available information, including Exelon’s evaluation and results. 

38 Based on this information, the NRC staff concludes that the potential impacts from electric 

39 shock during the renewal period would be SMALL. 

40 4.9.5. Electromagnetic Fields—Chronic Effects

41 In the GEIS, the effects of chronic exposure to 60 Hertz electromagnetic fields from power lines 

42 were not designated as Category 1 or 2 and will not be until a scientific consensus is reached 

43 on the health implications of these fields. 

44 The potential effects of chronic exposure from these fields continue to be studied and are not 

45 known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs 

46 related research through the U.S. Department of Energy (DOE). 
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1 The report by NIEHS (NIEHS 1999) contains the following conclusion:

2 The NIEHS concludes that ELF EMF (extremely low frequency electromagnetic 

3 field) exposure cannot be recognized as entirely safe because of weak scientific 

4 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 

5 is insufficient to warrant aggressive regulatory concern. However, because 

6 virtually everyone in the United States uses electricity and therefore is routinely 

7 exposed to ELF EMF, passive regulatory action is warranted such as continued 

8 emphasis on educating both the public and the regulated community on means 

9 aimed at reducing exposures. The NIEHS does not believe that other cancers or 

10 non cancer health outcomes provide sufficient evidence of a risk to currently 

11 warrant concern. 

12 This statement is not sufficient to cause the NRC staff to change its position with respect to the 

13 chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of 

14 “UNCERTAIN” still appropriate and will continue to follow developments on this issue. 

15 4.10. Socioeconomics

16 Section 2.2.9 of this SEIS describes socioeconomics in the vicinity of the LGS site. Table 4–9 

17 lists the Category 1 and Category 2 issues related to socioeconomics. 

18 Table 4–9. Socioeconomics Issues

Issues GEIS Section Category

Housing impacts 4.7.1 2

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 1

Public services: public utilities 4.7.3.5 2

Public services: education (license renewal) 4.7.3.1 1

Offsite land use (license renewal term) 4.7.4 2

Public services: transportation 4.7.3.2 2

Historic and archaeological resources 4.7.7 2

Aesthetic impacts (license renewal term) 4.7.6 1

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1

Environmental justice minority and low-income populations To be 

determined(a) 2 

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 2012b

19 4.10.1. Generic Socioeconomic Issues

20 The NRC staff did not identify any new and significant information during the review of the 

21 applicant’s ER (Exelon 2011a), the NRC staff’s site audit, the scoping process, or the evaluation 

22 of other available information. Therefore, there are no impacts related to Category 1 

23 socioeconomic issues beyond those discussed in the GEIS. For these issues, the GEIS 

24 concluded that the impacts are SMALL, and additional site-specific mitigation measures are not 

25 likely to be sufficiently beneficial to warrant implementation. 
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1 4.10.2. Housing

2 Appendix C of the GEIS presents a population characterization method based on two factors, 

3 sparseness and proximity (GEIS Section C.1.4). Sparseness measures population density 

4 within 20 mi (32 km) of the site, and proximity measures population density and city size within 

5 50 mi (80 km). Each factor has categories of density and size (GEIS Table C.1). A matrix is 

6 used to rank the population category as low, medium, or high (GEIS Figure C.1). 

7 According to the 2010 Census, an estimated 1,365,850 people live within 32.2 km (20 mi) of the 

8 LGS plant site, producing a population density of 420 persons per square kilometer 

9 (1,087 persons per square mile) (Exelon 2011a). This translates to a Category 4, “least sparse” 

10 population density using the GEIS measure of sparseness (greater than or equal to 120 persons 

11 per square mile within 20 miles). Approximately 8,311,616 people live within 80.4 kilometers 

12 (50 miles) of LGS, which equates to a population density of 409 persons per square kilometer 

13 (1,058 persons per square mile) (Exelon 2011a). As the region of influence (ROI) has a 

14 population greater than or equal to 190 persons per square mile within 80.4 kilometers 

15 (50 miles), this translates to a Category 4 (greater than or equal to 190 persons per square mile 

16 within 50 miles). Therefore, LGS is classified as being located in a high population area based 

17 on the GEIS sparseness and proximity matrix. 

18 Table B–1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 

19 are expected to be of small significance in a medium or high density population area where 

20 growth-control measures are not in effect. Since LGS is located in a high population area and

21 Montgomery, Berks, and Chester Counties are not subject to growth-control measures that 

22 would limit housing development; any changes in employment at LGS, Units 1 and 2 would 

23 have little noticeable effect on housing availability in these counties. Since Exelon has no plans 

24 to add non-outage employees during the license renewal period, employment levels at LGS, 

25 Units 1 and 2 would remain relatively constant with no new demand for permanent housing 

26 during the license renewal term. Based on this information, there would be no additional impact 

27 on housing during the license renewal term beyond what has already been experienced. 

28 4.10.3. Public Services—Public Utilities

29 Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility 

30 has the ability to respond to changes in demand and would have no need to add or modify 

31 facilities. Impacts are considered MODERATE if service capabilities are overtaxed during 

32 periods of peak demand. Impacts are considered LARGE if additional system capacity is 

33 needed to meet ongoing demand. 

34 Analysis of impacts on the public water systems considered both plant demand and 

35 plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and 

36 actual use of water for reactor cooling at LGS, Units 1 and 2. 

37 Since Exelon has no plans to add non-outage employees during the license renewal period, 

38 employment levels at LGS, Units 1 and 2 would remain relatively unchanged with no additional 

39 demand for public water services. Public water systems in the region are adequate to meet the 

40 demands of residential and industrial customers in the area. Therefore, there would be no 

41 impact to public water services during the license renewal term beyond what is currently being 

42 experienced. 
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1 4.10.4. Offsite Land Use

2 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, 

3 Subpart A, Appendix B, Table B–1). Table B–1 notes that “significant changes in land use may 

4 be associated with population and tax revenue changes resulting from license renewal.” 

5 Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 

6 operation during the license renewal term as SMALL when there will be little new development 

7 and minimal changes to an area’s land-use pattern, as MODERATE when there will be 

8 considerable new development and some changes to the land-use pattern, and LARGE when 

9 there will be large-scale new development and major changes in the land-use pattern. 

10 Tax revenue can affect land use because it enables local jurisdictions to provide the public 

11 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 

12 the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 

13 term should consider: (1) the size of the plant’s tax payments relative to the community’s total 

14 revenues, (2) the nature of the community’s existing land-use pattern, and (3) the extent to 

15 which the community already has public services in place to support and guide development. If 

16 the plant’s tax payments are projected to be small relative to the community’s total revenue, 

17 tax-driven land-use changes during the plant’s license renewal term would be SMALL, 

18 especially where the community has pre-established patterns of development and has provided 

19 public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax 

20 payments by the plant owner are less than 10 percent of the taxing jurisdiction’s revenue, the 

21 significance level would be SMALL. If tax payments are 10 to 20 percent of the community’s 

22 total revenue, new tax-driven land-use changes would be MODERATE. If tax payments are 

23 greater than 20 percent of the community’s total revenue, new tax-driven land-use changes 

24 would be LARGE. This would be especially true where the community has no pre-established 

25 pattern of development or has not provided adequate public services to support and guide 

26 development. 

27 4.10.4.1. Population-Related Impacts

28 Since Exelon has no plans to add non-outage employees during the license renewal period, 

29 there would be no plant operations-driven population increase in the vicinity of LGS, Units 1 

30 and 2. Therefore, there would be no population-related offsite land use impacts during the 

31 license renewal term beyond those already being experienced. 

32 4.10.4.2. Tax Revenue-Related Impacts

33 As discussed in Chapter 2, Exelon pays property taxes for LGS to the following entities in 

34 Montgomery and Chester Counties: Limerick Township, Spring-Ford Area School District, 

35 Lower Pottsgrove Township, Pottsgrove School District, Chester County, East Coventry 

36 Township, and Owen J. Roberts School District. Exelon also makes tax payments to taxing 

37 authorities in Bucks County, but the amounts are relatively minor. Since Exelon started making 

38 property tax payments to local jurisdictions, population has increased steadily and land has 

39 continued to be converted to residential and commercial uses in the affected counties—adding 

40 to the tax base of affected jurisdictions. Therefore, tax revenue from LGS as a proportion of 

41 total tax revenue has had little or no effect on land use conditions within these counties. 

42 Since employment levels would remain relatively unchanged with no increase in the assessed 

43 value of LGS, annual property tax payments also would be expected to remain relatively 

44 unchanged throughout the license renewal period. Based on this information, there would be no 

45 tax-revenue-related offsite land use impacts during the license renewal term beyond those 

46 already being experienced. 
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1 4.10.5. Public Services—Transportation

2 Table B–1 of Appendix B to Subpart A of 10 CFR Part 51 states the following: 

3 Transportation impacts (level of service) of highway traffic generated during the term of the 

4 renewed license are generally expected to be of SMALL significance. However, the increase in 

5 traffic associated with additional workers and the local road and traffic control conditions may 

6 lead to impacts of MODERATE or LARGE significance at some sites. 

7 The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of 

8 highway traffic generated by the proposed project on the level of service of local highways 

9 during the term of the renewed license. Since Exelon has no plans to add non-outage 

10 employees during the license renewal period; traffic volume and levels of service on roadways 

11 in the vicinity of LGS, Units 1 and 2 would not change. Therefore, there would be no 

12 transportation impacts during the license renewal term beyond those already being 

13 experienced. 

14 4.10.6. Historic and Archaeological Resources

15 This section provides the NRC staff’s assessment of the effects on historic and archaeological 

16 resources from the proposed license renewal action for LGS, Units 1 and 2. The National 

17 Historic Preservation Act (NHPA) requires Federal agencies to consider the effects of their 

18 undertakings on historic properties. Historic properties are defined as resources that are eligible 

19 for listing on the National Register of Historic Places (NRHP). The criteria for NRHP eligibility 

20 are listed in 36 CFR 60.4 and include, among other things, (1) association with significant 

21 events that have made a significant contribution to the broad patterns of history, (2) association 

22 with the lives of persons significant in the past, (3) embodiment of distinctive characteristics of 

23 type, period, or method of construction, and (4) sites or places that have yielded or may be likely 

24 to yield important information in history or prehistory. The historic preservation review process 

25 (Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA)) is outlined 

26 in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 

27 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the NRC has elected to use the 

28 National Environmental Policy Act of 1969, as amended (NEPA), process to comply with its 

29 obligations under Section 106 of the NHPA. 

30 In accordance with 36 CFR 800.8(c), on September 16, 2011, and September 15, 2011, 

31 respectively, the NRC staff initiated consultations on the proposed action by writing to the 

32 Advisory Council on Historic Preservation and the Pennsylvania Bureau of Historic Preservation 

33 (BHP), which houses the Pennsylvania State Historic Preservation Office (NRC 2011a, 2011b). 

34 Previously, Exelon, outside of the NHPA process, consulted with the BHP on January 19, 2011, 

35 regarding the renewal of operating licenses for LGS, Units 1 and 2. Exelon stated in its letter to 

36 the BHP that there would be no effect on historic properties from license renewal and 

37 associated operation and maintenance activities (Exelon 2011a). The BHP responded to LGS 

38 on February 16, 2011, concluding that “due to the nature of the activity, it is our opinion that 

39 there will be no effect on these properties” (Exelon 2011a). 

40 On September 13, 2011, the NRC staff initiated consultation with 15 Federally recognized 

41 tribes: the Absentee-Shawnee Tribe of Oklahoma, the Heron Clan, the Delaware Nation 

42 (located in Anadarko, Oklahoma), the Delaware Tribe (located in Emporia, Kansas), the Eastern 

43 Shawnee Tribe of Oklahoma, the Oneida Indian Nation, the Oneida Nation of Wisconsin, the 

44 Onondaga Nation, the Seneca Nations of Indians, the Seneca-Cayuga Tribe of Oklahoma, the 

45 St. Regis Mohawk Tribe, the Shawnee Tribe, the Stockbridge-Munsee Band of the Mohican 

46 Tribe, the Tonawanda Seneca Nation, and the Tuscarora Nation (see Appendix D for a list of 
Environmental Impacts of Operation

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1 these letters). In its letters, the NRC staff provided information about the proposed action, the 

2 definition of APE, and indicated that the NHPA review would be integrated with the NEPA 

3 process, according to 36 CFR 800.8(c). The NRC staff invited participation in the identification 

4 and possible decisions concerning historic properties and also invited participation in the 

5 scoping process. 

6 Before the site audit in May 2011, the NRC staff contacted the BHP concerning license renewal 

7 for LGS and concluded there was no need to meet during the environmental audit to discuss 

8 cultural resources (NRC 2011c). 

9 The NRC staff received scoping comments from two tribes, the Delaware Tribe and the 

10 Stockbridge Munsee Tribe, in September 2011, and one comment from the Onondaga Nation in 

11 October 2011. The tribes did not raise any concerns in their scoping comments and indicated 

12 there are no religious or culturally significant sites in the project area (see Appendix D). The

13 NRC responded to the tribes concerning their scoping comments. 

14 Section 2.2.10 describes the historic and cultural resources at the LGS site. Exelon currently 

15 has no planned changes or ground-disturbing activities associated with license renewal at LGS 

16 site (Exelon 2011a). Exelon is presently working with East Coventry Township and Chester 

17 County to rehabilitate and mothball the Fricks Lock Historic District located on its property. 

18 The rehabilitation and mothballing activities are specified to meet the Secretary of Interior’s 

19 Standards for Rehabilitation and have been approved by the Pennsylvania Historical and 

20 Museum Commission Bureau for Historic Preservation (BHP 2011). Construction activity is 

21 expected to begin in 2012 (Exelon 2011a). Exelon has also developed a cultural resources 

22 management plan to manage known and potentially existing, or discovered archaeologically or 

23 historically significant cultural resources within the Owner-Controlled Area (OCA) of the LGS. 

24 The Plan addresses possible impacts from land-disturbing activities or other actions within the 

25 OCA that could introduce new noise, air, or visual element impacts to known cultural resources 

26 outside the OCA. The plan describes the process for initiating informal consultation with BHP 

27 and provides guidance on how to manage an unexpected discovery (Exelon 2012a). 

28 For the purposes of NHPA Section 106 consultation, based on the (1) historic and cultural 

29 resources located within the APE, (2) tribal input, (3) Exelon’s Cultural Resources Management 

30 Plan and the status of the Fricks Lock rehabilitation and mothball project, (4) the fact that there 

31 will be no changes or ground-disturbing activities that will occur as part of the relicensing of 

32 LGS, Units 1 and 2, (5) BHP finding of “no effect,” and (6) the NRC staff’s cultural resource 

33 analysis and consultation, the NRC staff concludes that license renewal will have no effect on 

34 historic properties (36 CFR 800.4(d)(1)). 

35 For the purposes of the NRC staff’s NEPA analysis, based on the items that lead to the above 

36 finding of no effect, the NRC staff concludes that potential impacts on historic and cultural 

37 resources related to operating LGS, Units 1 and 2 during the renewal term would be SMALL. 

38 4.10.7. Environmental Justice

39 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

40 protection regulation, 10 CFR Part 51. With respect to environmental justice concerns, the 

41 revised rule amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

42 Category 2 issue, “Minority and low-income populations,” to evaluate the impacts of continued 

43 operations and any refurbishment activities during the license renewal term on minority

44 populations and low-income populations living in the vicinity of the plant. Environmental justice 

45 was listed in Table B–1 as a concern before this revised rule, but it was not evaluated in the 

46 1996 GEIS and, therefore, is addressed in each SEIS. 
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1 Under Executive Order (EO) 12898 (59 FR 7629, February 16, 1994), Federal agencies are 

2 responsible for identifying and addressing, as appropriate, potential disproportionately high and 

3 adverse human health and environmental impacts on minority and low-income populations. 

4 In 2004, the NRC issued a Policy Statement on the Treatment of Environmental Justice Matters 

5 in NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004), which states that 

6 “[t]he Commission is committed to the general goals set forth in EO 12898, and strives to meet 

7 those goals as part of its NEPA review process.” 

8 The Council of Environmental Quality (CEQ) provides the following information in Environmental 

9 Justice: Guidance under the National Environmental Policy Act (CEQ 1997): 

10 Disproportionately High and Adverse Human Health Effects. Adverse health 

11 effects are measured in risks and rates that could result in latent cancer fatalities, 

12 as well as other fatal or nonfatal adverse impacts on human health. Adverse 

13 health effects may include bodily impairment, infirmity, illness, or death. 

14 Disproportionately high and adverse human health effects occur when the risk or 

15 rate of exposure to an environmental hazard for a minority or low-income 

16 population is significant (as employed by NEPA) and appreciably exceeds the 

17 risk or exposure rate for the general population or for another appropriate 

18 comparison group. 

19 Disproportionately High and Adverse Environmental Effects. A 

20 disproportionately high environmental impact that is significant (as defined by 

21 NEPA) refers to an impact or risk of an impact on the natural or physical 

22 environment in a low-income or minority community that appreciably exceeds the 

23 environmental impact on the larger community. Such effects may include 

24 ecological, cultural, human health, economic, or social impacts. An adverse 

25 environmental impact is an impact that is determined to be both harmful and 

26 significant (as employed by NEPA). In assessing cultural and aesthetic 

27 environmental impacts, impacts that uniquely affect geographically dislocated or 

28 dispersed minority or low-income populations or American Indian tribes are 

29 considered. 

30 The environmental justice analysis assesses the potential for disproportionately high and 

31 adverse human health or environmental effects on minority populations and low-income 

32 populations that could result from the operation of LGS during the renewal term. In assessing 

33 the impacts, the following definitions of minority individuals and populations and low-income 

34 population were used (CEQ 1997): 

35  Minority individuals. Individuals who identify themselves as members of 

36 the following population groups: Hispanic or Latino, American Indian or 

37 Alaska Native, Asian, Black or African American, Native Hawaiian or Other 

38 Pacific Islander, or two or more races—meaning individuals who identified 

39 themselves on a Census form as being a member of two or more races 

40 (e.g., Hispanic and Asian). 

41  Minority populations. Minority populations are identified when the minority 

42 population of an affected area exceeds 50 percent or the minority population 

43 percentage of the affected area is meaningfully greater than the minority 

44 population percentage in the general population or other appropriate unit of 

45 geographic analysis. 

46  Low-income population. Low-income populations in an affected area are 

47 identified with the annual statistical poverty thresholds from the Census 

48 Bureau’s Current Population Reports, Series P60, on Income and Poverty. 
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1 4.10.7.1. Minority Population

2 According to 2010 Census data, 34.5 percent of the population residing within a 50-mi (80-km) 

3 radius of LGS identified themselves as minority individuals. The largest minority group was 

4 Black or African American (17 percent), followed by Hispanic or Latino (of any race) 

5 (9.1 percent) (CAPS 2012). 

6 According to 2010 Census data, minority populations in the socioeconomic ROI (Berks, 

7 Chester, and Montgomery Counties) comprised 20.6 percent of the total three-county population 

8 (see Table 2–9) (USCB 2011). Figure 4–1 shows minority population block groups, using 

9 2010 Census data for race and ethnicity, within a 50-mile (80-kilometer) radius of LGS. 

10 Census block groups were considered minority population block groups if the percentage of the 

11 minority population within any block group exceeded 34.5 percent (the percent of the minority 

12 population within the 50-mi radius of LGS). A minority population block group exists if the 

13 percentage of the minority population within the block group is meaningfully greater than the 

14 minority population percentage in the 50-mi (80-km) radius. Approximately 2,030 of the 

15 5,800 census block groups located within the 50-mi (80-km) radius of LGS were determined to 

16 have meaningfully greater minority populations. 

17 Minority population block groups are concentrated in the Philadelphia Metropolitan Area, with 

18 smaller concentrations in Reading and Allentown, Pennsylvania. The minority population block 

19 group nearest to LGS is located in Sanatoga, Limerick Township, Pennsylvania. According to 

20 the 2010 Census, approximately 20.7 percent of the total Sanatoga population (which includes 

21 more than one census block group) identified themselves as minority. 
Environmental Impacts of Operation

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1 Figure 4–1. 2010 Census Minority Block Groups within a 50-mi Radius of the LGS

Source: USCB 2011

Cities .. Aggregate Minority plus Hispanic * Limerick Generating Station D County Boundaries 

D 50 mile Boundary 

0 3 6 12 18 24 ll•ci•-=i--iC==:::.i--Miles 
Environmental Impacts of Operation

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1 4.10.7.2. Low-Income Population

2 According to 2010 American Community Survey Census data, an average of 7.7 percent of 

3 families and 10.4 percent of individuals residing in counties within a 50-mile radius of LGS

4 (Burlington, Camden, Gloucester, Hunterdon, Mercer, Salem, Somerset, and Warren, New 

5 Jersey; Berks, Bucks, Carbon, Chester, Delaware, Lancaster, Lebanon, Lehigh, Monroe, 

6 Montgomery, Northampton, Philadelphia, and Schuylkill, Pennsylvania; Cecil, Maryland; and 

7 New Castle, Delaware) were identified as living below the Federal poverty threshold in 2010. 

8 The 2010 Federal poverty threshold was $22,314 for a family of four (USCB 2011). 

9 According to the 2010 Census, 9.3 percent of families and 13.4 percent of individuals in 

10 Pennsylvania were living below the Federal poverty threshold in 2010, and the median 

11 household income for Pennsylvania was $49,288 (USCB 2011). All three counties in the 

12 immediate ROI of LGS had higher median household incomes and Montgomery and Chester 

13 Counties had lower percentages of families and individuals living below the poverty level when 

14 compared to the state average. Berks County had a median household income average 

15 of $51,719 and 14.1 percent of individuals and 10.9 percent of families living below the poverty 

16 level. Chester County had a median household income average of $82,284 and 6.2 percent of 

17 individuals and 3.6 percent of families living below the poverty level. Montgomery County had a 

18 median household income of $75,448 and 5.5 percent of individuals and 3.6 percent of families 

19 living below the poverty level (USCB 2011). 

20 Figure 4–2 shows low-income census block groups within a 50-mile (80-kilometer) radius of 

21 LGS. Census block groups were considered low-income population block groups if the 

22 percentage of individuals living below the Federal poverty threshold within any block group 

23 exceeded the percent of the individuals living below the Federal poverty threshold within the 

24 50-mile radius of LGS. Approximately 2,070 of the 5,800 census block groups located within 

25 the 50-mile (80-kilometer) radius of LGS were determined to have meaningfully greater 

26 low-income populations. 

27 Similar to the locations of minority population block groups, the majority of low-income 

28 population block groups are located in the Philadelphia metropolitan area, with smaller 

29 concentrations in Reading and Allentown, Pennsylvania. The nearest low-income population to 

30 LGS is located in Sanatoga, Limerick Township, Pennsylvania. 
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1 Figure 4–2. 2010 Census Low-Income Block Groups within a 50-mi Radius of LGS

Source: UCSB 2011

Cities .. Low Income Population * Limerick Generating Station D County Boundaries 

D 50 mile Boundary _ _i State Boundaries 

0 3 6 12 18 24 

J.::i.::::i.-..:::::==•-•Miles 
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1 4.10.7.3. Analysis of Impacts

2 The NRC addresses environmental justice matters for license renewal through (1) identifying 

3 the location of minority and low-income populations that may be affected by the continued 

4 operation of the nuclear power plant during the license renewal term, and (2) determining 

5 whether there would be any potential human health or environmental effects to these 

6 populations and special pathway receptors, and (3) determining if any of the effects may be 

7 disproportionately high and adverse. 

8 Figures 4–1 and 4–2 identify the location of minority and low-income block group populations 

9 residing within a 50-mi (80-km) radius of LGS. This area of impact is consistent with the impact 

10 analysis for public and occupational health and safety, which also focuses on populations within 

11 a 50-mi (80-km) radius of the plant. Chapter 4 presents the assessment of environmental and 

12 human health impacts for each resource area. The analyses of impacts for all environmental 

13 resource areas indicated that the impact from license renewal would be SMALL. 

14 Potential impacts to minority and low-income populations (including migrant workers or Native 

15 Americans) would mostly consist of socioeconomic and radiological effects; however, radiation 

16 doses from continued operations during the license renewal term are expected to continue at 

17 current levels and would remain within regulatory limits. Socioeconomic effects were likewise 

18 found to be SMALL. Chapter 5 of this SEIS discusses the environmental impacts from 

19 postulated accidents that might occur during the license renewal term, which include both 

20 design-basis and severe accidents. The Commission has generically determined that impacts 

21 associated with design-basis accidents are small because nuclear plants are designed and 

22 operated to successfully withstand such accidents, and the probability weighted impact risks 

23 associated with severe accidents are also small. 

24 Therefore, based on this information and the analysis of human health and environmental 

25 impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high

26 and adverse impacts to minority and low-income populations from the continued operation of 

27 LGS during the license renewal term. 

28 As part of addressing environmental justice concerns associated with license renewal, the NRC 

29 also assessed the potential radiological risk to special population groups (such as migrant 

30 workers or Native Americans) from exposure to radioactive material received through their 

31 unique consumption and interaction with the environment patterns, including subsistence 

32 consumption of fish, native vegetation, surface waters, sediments, and local produce; 

33 absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive 

34 material released from the plant during routine operation. This analysis is presented below. 

35 4.10.7.4. Subsistence Consumption of Fish and Wildlife

36 The special pathway receptors analysis is an important part of the environmental justice 

37 analysis because consumption patterns may reflect the traditional or cultural practices of 

38 minority and low-income populations in the area, such as migrant workers or Native Americans. 

39 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 

40 appropriate, to collect, maintain, and analyze information on the consumption patterns of 

41 populations that rely principally on fish and/or wildlife for subsistence and to communicate the 

42 risks of these consumption patterns to the public. In this SEIS, the NRC staff considered 

43 whether there were any means for minority or low-income populations to be disproportionately 

44 affected, and it considered this by examining impacts to American Indians, Hispanics, migrant 

45 workers, and other traditional lifestyle special pathway receptors. Special pathways took into 

46 account the levels of radiological and nonradiological contaminants in native vegetation, crops, 
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1 soils and sediments, groundwater, surface water, fish, and game animals on or near LGS were 

2 considered. 

3 The following is a summary discussion of the NRC staff’s evaluation from Section 4.9.2 of the 

4 radiological environmental monitoring programs (REMPs) that assess the potential impacts for 

5 subsistence consumption of fish and wildlife near the LGS site. 

6 Exelon has an ongoing comprehensive REMP to assess the impact of LGS operations on the 

7 environment. To assess the impact of nuclear power plant operations, samples are collected 

8 annually from the environment and analyzed for radioactivity. A plant effect would be indicated 

9 if the radioactive material detected in a sample was significantly larger than background levels. 

10 Two types of samples are collected. The first type, control samples, are collected from areas 

11 that are beyond the measurable influence of the nuclear power plant or any other nuclear 

12 facility. These samples are used as reference data to determine normal background levels of 

13 radiation in the environment. These samples are then compared with the second type of 

14 samples, indicator samples, collected near the nuclear power plant. Indicator samples are 

15 collected from areas where any contribution from the nuclear power plant will be at its highest 

16 concentration. These samples are then used to evaluate the contribution of nuclear power plant 

17 operations to radiation or radioactivity levels in the environment. An effect would be indicated if 

18 the radioactivity levels detected in an indicator sample was significantly larger than the control 

19 sample or background levels. 

20 Samples of environmental media are collected from the aquatic and terrestrial pathways in the 

21 vicinity of LGS. Nine hundred and twenty-six radiological environmental samples were collected 

22 and analyzed in 2010. The aquatic pathways include groundwater, surface water, drinking 

23 water, fish, and shoreline sediment. The terrestrial pathways include airborne particulates, milk, 

24 food products (i.e., leafy vegetables, such as cabbage, collards, Swiss Chard, collected from 

25 gardens in the vicinity of LGS), and wild animal feed (i.e., broad leaf vegetation). During 2010, 

26 analyses performed on samples of environmental media at LGS showed no significant or 

27 measurable radiological impact above background levels from site operations (Exelon 2011b). 

28 4.10.8. Conclusion

29 Based on the radiological environmental monitoring data from LGS, the NRC staff finds that no 

30 disproportionately high and adverse human health impacts would be expected in special 

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

32 local food, fish, and wildlife. 

33 4.11. Evaluation of New and Potentially Significant Information

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

35 issue not covered in the GEIS and codified in Table B–1 of 10 CFR Part 51, Subpart A, 

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

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

38 GEIS and codified in 10 CFR Part 51. 

39 The new and significant assessment that Exelon conducted during the preparation of the license

40 renewal application included: (1) interviews with Exelon subject-matter experts on the validity of 

41 the conclusions in the GEIS as they relate to LGS, (2) review of the results of LGS 

42 environmental monitoring and reporting, as required by regulations and oversight of plant 

43 facilities and operations by state and Federal regulatory agencies, (3) a review of 

44 correspondence with state and Federal agencies to determine if agencies had concerns 

45 relevant to their resource areas that had not been addressed in the GEIS, (4) a review for 
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1 issues relevant to the LGS application of certain license renewal applications that operators of 

2 other nuclear plants have previously submitted to the NRC, (5) an extensive review of 

3 documents related to environmental issues at LGS, and (6) a review of information related to 

4 severe accident mitigation. 

5 The NRC also has a process for identifying new and significant information, which is described 

6 in NUREG–1555, Supplement 1, “Standard Review Plans for Environmental Reviews for 

7 Nuclear Power Plants, Supplement 1; Operating License Renewal” (NRC 1999b). The search 

8 for new information includes: (1) review of an applicant’s ER and the process for discovering 

9 and evaluating the significance for new information, (2) review of records for public comments, 

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

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

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

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

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

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

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

17 Exelon reported in its ER (Exelon 2011a) that it was aware of one new radiological issue 

18 associated with the renewal of the LGS operating license—tritium in groundwater. In 2006, 

19 Exelon implemented a fleet-wide program to proactively review the environmental status of its 

20 nuclear power generating stations, specifically to identify the potential for releases of 

21 radionuclides. The program is consistent with the guidance provided in NEI 07-07, “Industry 

22 Ground Water Protection Initiative–Final Guidance Document.” As part of this program, Exelon

23 commissioned a hydrogeologic investigation of LGS to evaluate any groundwater impact from 

24 radionuclides that may have been released from the plant. Exelon also developed its RGPP 

25 during this time. 

26 A groundwater monitoring well network for LGS’s groundwater protection program was 

27 designed and installed to gather any radionuclide release data. Monitoring was initiated in 2006 

28 and performed at least semi-annually on each monitoring well. The results of the program, 

29 including trending data, program modifications, reporting protocols, and other information are 

30 included in the annual LGS radiological environmental operating reports. Neither Sr-90 nor any 

31 LGS-related gamma-emitting radionuclides have been identified in any groundwater sample. 

32 The reporting level for tritium in groundwater specified in the Exelon Offsite Dose Calculation 

33 Manual (ODCM) is equal to the EPA drinking water standard of 20,000 picocuries per liter 

34 (pCi/L). The ODCM specifies a detection capability of 200 pCi/L for analyzing tritium 

35 concentrations in groundwater samples. 

36 The groundwater monitoring data are reported in the annual LGS REMP reports. Sampling of 

37 the monitoring well network at LGS has not identified any tritium concentration greater than 

38 20,000 pCi/L. Tritium was detected during a 2006 site investigation at a concentration of 2,020 

39 ± 154 pCi/L in a sample collected from the power block foundation sump, which accumulates 

40 water from the drain system around the power block. This water is not in direct contact with 

41 groundwater and, therefore, also is not reflective of groundwater quality beneath LGS. Tritium 

42 concentrations greater than 2,000 pCi/L, but below the reporting level of 20,000 pCi/L, have 

43 been detected in power block foundation sump samples on other occasions since 2006. 

44 Exelon’s evaluation of the groundwater monitoring data concluded that there are no significant 

45 impacts associated with tritium in groundwater down gradient of LGS. This conclusion is based 

46 on the following information. Sampling of the monitoring well network at LGS has not identified 

47 tritium concentrations greater than the reporting level of 20,000 pCi/L. There is no groundwater 

48 connectivity with the monitoring points that have shown tritium concentrations greater than 
Environmental Impacts of Operation

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1 2,000 pCi/L. None of the wells that have detectable tritium are used by workers or members of 

2 the public for drinking water. The applicant’s groundwater protection monitoring program and 

3 REMP will continue to monitor the groundwater and report the results in the annual radioactive 

4 effluent operating reports. Also, NRC inspectors will periodically review the REMP data for 

5 compliance with NRC radiation protection standards. Based on the above, the NRC staff 

6 concludes that the issue of tritium contamination of the groundwater on the LGS site is not 

7 significant.

8 4.12. Cumulative Impacts 

9 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 

10 protection regulation, 10 CFR Part 51. With respect to cumulative impacts, the revised rule

11 amends Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 

12 Category 2 issue, “Cumulative impacts,” to evaluate the potential cumulative impacts of license 

13 renewal. 

14 The NRC staff considered potential cumulative impacts in the environmental analysis of 

15 continued operation of the LGS nuclear plant during the 20-year license renewal period. 

16 Cumulative impacts may result when the environmental effects associated with the proposed 

17 action are overlaid or added to temporary or permanent effects associated with other past, 

18 present, and reasonably foreseeable actions. Cumulative impacts can result from individually 

19 minor, but collectively significant, actions taking place over a period of time. It is possible that 

20 an impact that may be SMALL by itself could result in a MODERATE or LARGE cumulative 

21 impact when considered in combination with the impacts of other actions on the affected 

22 resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL individual 

23 impact could be important if it contributes to or accelerates the overall resource decline. 

24 For the purposes of this cumulative analysis, past actions are those before the receipt of the 

25 license renewal application. Present actions are those related to the resources at the time of 

26 current operation of the power plant, and future actions are those that are reasonably 

27 foreseeable through the end of plant operation, including the period of extended operation. 

28 Therefore, the analysis considers potential impacts through the end of the current license terms 

29 as well as the 20-year renewal license term. The geographic area over which past, present, 

30 and reasonably foreseeable actions would occur depends on the type of action considered and 

31 is described below for each resource area. 

32 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

33 in Sections 4.1 to 4.10, are combined with other past, present, and reasonably foreseeable 

34 future actions regardless of what agency (Federal or non-Federal) or person undertakes such 

35 actions. The NRC staff used the information provided in the ER; responses to requests for 

36 additional information; information from other Federal, state, and local agencies; scoping 

37 comments; and information gathered during the visits to the LGS site to identify other past, 

38 present, and reasonably foreseeable actions. To be considered in the cumulative analysis, the 

39 NRC staff determined if the project would occur within the noted geographic areas of interest 

40 and within the period of extended operation, was reasonably foreseeable, and if there would be 

41 potential overlapping effect with the proposed project. For past actions, consideration within the 

42 cumulative impacts assessment is resource and project-specific. In general, the effects of past 

43 actions are included in the description of the affected environment in Chapter 2, which serves as 

44 the baseline for the cumulative impacts analysis. However, past actions that continue to have 

45 an overlapping effect on a resource potentially affected by the proposed action are considered 

46 in the cumulative analysis. 
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1 Other actions and projects identified during this review and considered in the NRC staff’s 

2 independent analysis of the potential cumulative effects are described in Appendix F. Examples 

3 of other actions that were considered in this analysis include the following: 

4 • Cromby Generating Station,

5 • Titus coal plant,

6 • independent spent fuel storage installation, 

7 • transmission lines

8 • future urbanization, and

9 • Schuylkill River greenway. 

10 4.12.1. Air Quality

11 This section addresses the direct and indirect effects of license renewal on air quality resources 

12 when added to the aggregate effects of other past, present, and reasonably foreseeable future 

13 actions. As described in Section 4.2, the incremental impacts on air quality from the proposed 

14 license renewal would be SMALL, as there is no planned refurbishment associated with the 

15 LGS license renewal. The geographic area considered in the cumulative air quality analysis is 

16 the county of the proposed action because air quality designations for criteria air pollutants are 

17 generally made at the county level. Counties are further grouped together based on a common 

18 air shed—known as an air quality control region (AQCR)—to provide for the attainment and 

19 maintenance of the National Ambient Air Quality Standards (NAAQS). The LGS site is located 

20 in Montgomery and Chester Counties, Pennsylvania, and is part of the Metropolitan 

21 Philadelphia Intrastate AQCR (40 CFR 81.15). Additional counties in this AQCR include Bucks, 

22 Delaware, and Philadelphia Counties. 

23 Section 2.2.2 presents a summary of the air quality designation status for Montgomery and 

24 Chester Counties. As noted in Section 2.2.2, EPA regulates six criteria pollutants under the 

25 NAAQS, including carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, and 

26 particulate matter. Montgomery and Chester Counties are designated unclassified or in 

27 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment 

28 with respect to ozone and PM2.5 (40 CFR 81.339). All other counties in this AQCR are similarly 

29 designated with respect to the NAAQS criteria pollutants. 

30 Criteria pollutant air emissions from the LGS site are presented in Section 2.2.2.1; these 

31 emissions are principally from standby diesel generators, boilers, two cooling towers, and a 

32 spray pond. Air pollutants from these sources are permitted under a Title V operating permit 

33 (TVOP-46-00038) (Exelon 2011a). In Section 4.2, it was noted that there would be no new air 

34 emissions associated with the LGS license renewal because there is no planned site 

35 refurbishment. Therefore, cumulative changes to air quality in Montgomery and Chester 

36 Counties would be the result of changes to present-day emissions from other existing facilities 

37 as well as future projects and actions within the county. 

38 Appendix F provides a list of present and reasonably foreseeable projects that could contribute 

39 to cumulative impacts to air quality. Continued air emissions from existing projects and actions 

40 listed in Appendix F as well as proposed new source activities would contribute to air emissions 

41 in Montgomery and Chester Counties and will affect air quality within the region. Development 

42 and construction activities associated with regional growth of housing, business, and industry, 

43 as well as associated vehicular traffic, also will result in additional air emissions. Project timings 

44 and locations, which are difficult to predict, affect cumulative impacts to air quality. However, 

45 permitting and licensing requirements, efficiencies in equipment, cleaner fuels, and various 

46 mitigation measures can be used to minimize cumulative air quality impacts. 
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1 The effects of global climate change are already being felt in the northeastern United States, 

2 including an increase in annual average temperatures since 1970. This warming has resulted in 

3 many other climate-related changes, such as more frequent days over 90 °F (32 °C), increased 

4 heavy precipitation, less snow and more rain in winter, reduced snowpack, earlier spring 

5 snowmelt, and rising sea temperatures and sea level. The Northeast is projected to face 

6 continued warming and more extensive climate-related changes. Extreme heat and declining 

7 air quality (notably ozone) could affect human health. States, however, must continue to comply 

8 with the Clean Air Act, so it is likely that additional limitations on ozone precursors could help

9 counteract this effect. 

10 The overall warming trend also affects patterns of agricultural production and fisheries in the 

11 region, and the projected reduction in snow cover would adversely affect winter recreation and 

12 its related industries. Above all, more frequent flooding due to the sea-level rise and heavy 

13 downpours would have severe impacts on densely populated coastal areas, resulting in storm 

14 surges, coastal flooding, erosion, losses of life, property damage, and loss of wetlands 

15 (Karl et al. 2009). While these impacts are the result of changing atmospheric conditions, most 

16 of them are not, in and of themselves, air quality impacts. 

17 Given that there is no planned plant refurbishment associated with the LGS license renewal, 

18 and therefore no expected changes in air emissions, cumulative air quality impacts in 

19 Montgomery and Chester Counties would be the result of changes to present-day emissions 

20 and emissions from reasonably foreseeable projects and actions. As NRC staff noted above, 

21 project timings and locations, which are difficult to predict, affect cumulative impacts to air 

22 quality. However, various strategies and techniques are available to limit air quality impacts. 

23 Therefore, the NRC staff concludes that the cumulative air quality impacts from the proposed 

24 license renewal and other past, present, and reasonably foreseeable projects would be SMALL. 

25 4.12.2. Water Resources 

26 This section addresses the direct and indirect effects of license renewal on water resources 

27 when added to the aggregate effects of other past, present, and reasonably foreseeable future 

28 actions. As described in Sections 4.4 and 4.5, the incremental impacts on water resources from 

29 continued operations of LGS, Units 1 and 2 during the license renewal term would be SMALL. 

30 NRC staff also conducted an assessment of other projects and actions for consideration in 

31 determining their cumulative impacts on water resources (see Appendix F). The geographic 

32 area considered for the surface water resources component of the cumulative impacts analysis 

33 spans the Delaware River Basin. For groundwater, the area considered encompasses the local 

34 groundwater basin relative to LGS in which groundwater is recharged and flows to discharge 

35 points, or is withdrawn through wells. As such, this review focused on those projects and 

36 activities that would (1) withdraw water from or discharge wastewater to the Delaware River or 

37 its tributaries (i.e., the Schuylkill River) and/or (2) would use groundwater or could otherwise

38 affect the bedrock aquifer beneath the LGS site. 

39 4.12.2.1. Cumulative Impacts on Surface Water Resources

40 Water resource managers must balance multiple conflicting water management objectives. 

41 Within the Delaware River Basin, this includes demands for power generation, municipal water, 

42 industrial water, agricultural water, mining, recreation, flood protection, and instream flow 

43 requirements to sustain aquatic life (see Section 4.12.2). The Delaware River Basin 

44 Commission (DBRC) was formed to balance these objectives. These tradeoff decisions reflect 

45 an understanding of the inevitable uncertainty in regulated flows that result from inter-annual 

46 and intra-annual variability. Based on the USGS gage on the Schuylkill River at Pottstown, 

47 Pennsylvania, for water years 1928 to 2010, the highest annual mean flow and lowest annual 
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mean flow recorded are 3,211cfs (90.7 m3

/s) and 843 cfs (23.8 m3 1 /s), respectively. The highest 

daily mean flow and the lowest daily mean flow recorded are 71,200 cfs (2,011 m3 2 /s) and 

175 cfs (4.9 m3 3 /s), respectively (USGS 2010). This magnitude of variability reflects climate 

4 variability and no other projects within the basin. 

5 To support full operations of LGS, Units 1 and 2, Exelon must withdraw up to 42 mgd or 

29,200 gpm (65 cfs or 1.8 m3 6 /s) of water from either the Schuylkill River or other sources for

7 consumptive cooling water use, as further described in Section 2.1.7.1 of this SEIS. Surface 

8 water withdrawals by LGS, like other similar surface water users in the basin, are subject to 

9 limits and conditions imposed by DRBC dockets. Relative to the cited magnitude of variability of 

10 flows in the Schuylkill River, the hydrologic impacts of surface water withdrawals associated 

11 with LGS operations are very small. 

12 In general, water quality across the Delaware River Basin has dramatically improved over the 

13 past several decades. The water quality of the Delaware River and its main tributaries, such as 

14 the Schuylkill River, was profoundly impaired by municipal and industrial waste discharges and 

15 mining activities. Regulatory changes, including implementation of the Clean Water Act, have 

16 eliminated many of the largest point and nonpoint sources of water quality degradation. Still, 

17 within this context, the trend in urban and suburban development in the immediate LGS region 

18 (see Sections 4.12.3 and 4.12.4) and associated corridor-type development (e.g., roads) to 

19 keep pace with overall population growth in the Delaware River Basin has introduced a different 

20 impact dynamic. From the perspective of water quality, these types of development generally 

21 substitute more diffuse sources of pollution (i.e., nonpoint) and their impacts for point sources 

22 traditionally associated with industry. 

23 Nevertheless, the segment of the Schuylkill River near LGS meets all established water quality 

24 standards at present, as further described in Section 2.2.4.1. The DRBC is responsible for 

25 classifying all waters in the basin as to use, setting basin-wide water quality standards, 

26 establishing pollutant treatment and control regulations, and reviewing projects or other 

27 undertakings with the potential to affect basin water resources for conformance with the DRBC 

28 Comprehensive Plan (DRBC 2001). DRBC acts in coordination with the states and other 

29 parties that are signatories to the DRBC Compact (DRBC 1961) to include the imposition of 

30 necessary effluent limitations on industrial wastewater discharges to surface water. 

31 In addition, the NRC staff considered the U.S. Global Change Research Program’s (USGCRP’s) 

32 most recent compilation of the state of knowledge relative to global climate change effects 

33 (Karl 2009). Temperatures in the Northeastern United States are projected to rise an additional 

34 2.5 to 4 °F (1.4 to 2.2 °C) in winter and 1.5 to 3.5 °F (0.8 to 1.9 °C) in the summer by about 

35 2050. This would be in addition to the 2 °F (1.1 °C) increase in annual average temperature 

36 that has occurred since 1970. Sea level is expected to continue to rise. While there is great 

37 uncertainty, sea levels are expected to rise between 3 and 4 ft (0.9 to 1.2 m) by the end of this

38 century. Meanwhile, precipitation and runoff are projected to increase in the winter and spring 

39 across the Northeast. Increased runoff generally equates to increased streamflow

40 (Karl et al. 2009). 

41 Without an offsetting increase in discharge in the Delaware River, any sea level rise associated 

42 with climate change will cause increased upstream saltwater migration and potentially affect 

43 fresh water withdrawals upstream of the salt line (see Section 2.2.4.1). This could lead to fresh 

44 water availability and water use conflicts. Moreover, permitting agencies, principally the PADEP 

45 and the DRBC, could have to consider imposing more stringent effluent limits on power plant 

46 discharges, should water temperatures rise. These predictions, if borne out, have important 

47 implications for the Delaware River Basin as a whole, but the overall interaction of predicted 
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1 hydrologic changes and their effect on water users in the Delaware River Basin is highly 

2 speculative at the present time. 

3 Surface water withdrawals for LGS operations are a small fraction of the mean annual flow of 

4 the Schuylkill River, and the discharge of cooling tower blowdown has not significantly affected 

5 ambient surface water quality. The NRC staff did not identify any exceptional limitations to 

6 water resources. The NRC staff concludes that the cumulative impacts from past, present, and 

7 reasonably foreseeable future actions on surface water resources during the license renewal 

8 term would be SMALL. This conclusion is based on the regulatory framework established by 

9 the DBRC and PADEP in managing surface water use and quality and the generally improving 

10 trend in conditions in the Schuylkill River and within the Delaware River Basin. 

11 4.12.2.2. Cumulative Impacts on Groundwater Resources 

12 The Brunswick bedrock aquifer is the most widespread source of groundwater in the plant 

13 region and across the Triassic lowlands of the Newark Basin. LGS’s four groundwater 

14 production wells are completed in the Brunswick aquifer system along with over 50 domestic 

15 and several other commercial/industrial supply wells within a 1-mi (1.6-km) radius of LGS (see 

16 Section 2.2.5.1). 

17 The DRBC promulgated its Ground Water Protected Area Regulations (DRBC 1999; 

18 18 CFR 430) to manage groundwater resources in the Triassic lowland and adjacent areas in 

19 southeastern Pennsylvania. LGS and its regulated production wells are located in the 

20 Schuylkill-Sprogels Run Subbasin, as delineated by the DRBC (DRBC 1999; Exelon 2011a). 

21 The DRBC has established a total maximum withdrawal limit of 1,455 million gal/yr (mgy) 

(5.49 million m3 22 /yr) for the subbasin. It has also set a withdrawal level of 1,091 mgy 

(4.12 million m3 23 /yr) as that level where groundwater resources of the subbasin would be 

24 “potentially stressed” (DRBC 1999; 18 CFR 430). Nonetheless, total net annual groundwater 

25 withdrawals in the subbasin are currently well below the DRBC limits at 174.89 mgy 

(0.66 million m3 26 /yr) (DRBC 2011). As described in Section 2.1.7.2, total LGS site groundwater 

withdrawals have averaged about 31,500 gpd or 11.5 mgy (0.04 million m3 27 /yr). This withdrawal 

28 is about 0.8 and 1.1 percent, respectively, of the DRBC established thresholds for groundwater 

29 withdrawals in the Schuylkill-Sprogels Run Subbasin. 

30 LGS operations have resulted in inadvertent releases of liquids containing tritium to the bedrock 

31 aquifer, as described in Sections 4.5.2 and 2.2.5.2 of this SEIS. However, there has been no 

32 migration of tritium in groundwater exceeding 2,000 pCi/L, and tritium levels have been well 

33 below the EPA primary drinking water standard (i.e., 20,000 pCi/L) at all onsite monitoring wells. 

34 In addition, there are no potable water users downgradient of the LGS power block that have 

35 been affected by the inadvertent releases. As site groundwater locally discharges to the 

36 Schuylkill River and Possum Hollow Run where rapid mixing and dilution occurs, there is no 

37 drinking water pathway to other groundwater users. Meanwhile, Exelon maintains an ongoing 

38 RGPP at LGS to detect and correct the source of inadvertent releases of 

39 radionuclide-containing liquids. 

40 In summary, the DRBC has established limits on total groundwater withdrawals in the local 

41 groundwater subbasin, and current total withdrawals for all projects identified in this review are a 

42 small percentage of the established thresholds for the subbasin. LGS groundwater withdrawals 

43 are not expected to increase during the license renewal term. Further, inadvertent releases of 

44 liquids containing tritium have not impacted groundwater quality beyond the site boundary, and 

45 there is no pathway to other drinking water users. Tritium levels as measured in groundwater 

46 on site are well below the EPA drinking water standard and a program is in place to safeguard 

47 groundwater quality. Based on the above considerations, the NRC staff concludes that the 
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1 cumulative impacts from past, present, and reasonably foreseeable future actions on 

2 groundwater use and quality during the license renewal term would be SMALL. 

3 4.12.3. Aquatic Resources

4 This section addresses the direct and indirect effects of license renewal on aquatic resources 

5 when added to the aggregate effects of other past, present, and reasonably foreseeable future 

6 actions. As described in Section 4.6, the incremental impacts on aquatic biota from the

7 proposed license renewal would be SMALL. The geographic area considered in the cumulative 

8 aquatic resources analysis includes the LGS cooling water sources in the vicinity of intake and 

9 discharge structures on the Schuylkill River, the Perkiomen Creek, the Delaware River, and 

10 along the East Branch Perkiomen Creek and Perkiomen Creek where water from the Delaware 

11 River is discharged to augment flows to the Perkiomen Creek. 

12 The benchmark for assessing cumulative impacts on aquatic resources takes into account the 

13 preoperational environment as recommended by the EPA (1999), for its review of NEPA 

14 documents, as follows: 

15 Designating existing environmental conditions as a benchmark may focus the 

16 environmental impact assessment too narrowly, overlooking cumulative impacts 

17 of past and present actions or limiting assessment to the proposed action and 

18 future actions. For example, if the current environmental condition were to serve 

19 as the condition for assessing the impacts of relicensing a dam, the analysis 

20 would only identify the marginal environmental changes between the continued 

21 operation of the dam and the existing degraded state of the environment. In this 

22 hypothetical case, the affected environment has been seriously degraded for 

23 more than 50 years with accompanying declines in flows, reductions in fish 

24 stocks, habitat loss, and disruption of hydrologic functions. If the assessment 

25 took into account the full extent of continued impacts, the significance of the 

26 continued operation would more accurately express the state of the environment 

27 and thereby better predict the consequences of relicensing the dam. 

28 Sections 2.2.4 and 2.2.6 present an overview of the condition of the Schuylkill River, Perkiomen 

29 Creek, East Branch Perkiomen Creek, and the Delaware River at the Point Pleasant Pumping 

30 Station, and the history and factors that led to current conditions. The direct and indirect 

31 impacts from water use and industrial discharge, such as mining waste water, are some of the 

32 most influential human activities on the Delaware River Basin (DRBC 2010a). Within the 

33 Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek, increased urbanization 

34 over the past 100 years has also led to increased runoff and elevated levels of pollutants within 

35 (Rhoads and Block 2008). On the Schuylkill River, the construction of dams beginning in the 

36 early 1800s blocked anadromous fish migrations and resulted in the decline of American shad, 

37 river herring, and blueback herring, which require movement between freshwater and marine 

38 waters to complete their life cycles (Perillo and Butler 2009). 

39 Many natural and anthropogenic activities can influence the current and future aquatic biota in

40 the area surrounding the LGS site and the Delaware River Basin. Potential biological stressors 

41 include operational impacts from LGS (as described in Section 4.6), increasing urbanization, 

42 energy development, and climate change. 

43 4.12.3.1. Urbanization and Water Quality

44 Interlandi and Crockett (2003) reported an increase in residential and commercial development 

45 for the area surrounding LGS along the Schuylkill River, Perkiomen Creek, and East Branch 

46 Perkiomen Creek, and a decrease in population near Philadelphia. Increased urbanization has 

47 led to increases in dissolved nitrate and chloride levels in the Schuylkill River. Urbanization will 
Environmental Impacts of Operation

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1 likely continue to contribute significant organic and metal pollutants to the river through runoff 

2 (Interlandi and Crockett 2003). The DRBC and EPA manage and set total maximum daily load 

3 (TMDL) limits for contaminants, such as polychlorinated biphenyl (PCBs), to help control future 

4 pollution of waters within the Delaware River Basin (DRBC 2008, EPA 2007). 

5 Several other facilities within 10 miles (16 km) of LGS have NPDES permits to discharge into 

6 the Schuylkill River, which contributes to the cumulative impacts to aquatic habitats 

7 (EPA 2012a). For example, six municipal wastewater treatment facilities discharge treated 

8 wastewater to the Schuylkill River for a total discharge of less than 9 mgd (Appendix F). In 

9 addition, at least seven major industrial facilities, such as industrial laundry facilities, chemical 

10 production facilities, and aluminum die casting facilities, discharge into the Schuylkill River. Two 

11 municipal and one industrial treatment facilities discharge to Perkiomen Creek with a maximum 

12 total discharge of 2.0 mgd (Appendix F). Three major industrial facility NPDES permits for water 

13 discharge to Perkiomen Creek exist within a 10-mi (16-km) radius of LGS. Little effect to 

14 aquatic habitats from industrial and wastewater discharges is expected assuming that facilities 

15 comply with NPDES permit limitations. 

16 4.12.3.2. Energy Development 

17 A number of energy plants withdraw water from the Schuylkill and Delaware Rivers. Within 

18 30 miles (48 km) of LGS, one oil plant and one natural-gas plant also withdraw and discharge to 

19 the Schuylkill River. In 2011, Exelon decommissioned two coal-fired units on the Schuylkill 

20 River at Cromby Generating Station (Appendix F). Two coal and two natural-gas plants operate 

21 near the confluence of the Delaware and Schuylkill Rivers, and use tidal Delaware River water 

22 as the main water source. In 2005, DRBC annual consumptive surface water use records show 

Eddystone Generating Station Coal Plant at 897 million gallons per year (MGY) (3.4 million m3 23 ), 

Florida Power & Light Energy Marcus Hook gas plant at 1,018 MGY (3.85 million m3 24 ), and 

Fairless Energy at 495 MGY (1.87 million m3 25 ) (DRBC 2012a). These energy plants use water 

26 resources shared by LGS, but do not affect habitats or aquatic biota directly associated with the 

27 LGS cooling system. 

28 Marcellus shale formation underlies approximately 36 percent of the Delaware River Basin and 

29 energy companies are actively seeking to mine the natural gas deposits within the Marcellus 

30 Shale (DRBC 2012b). Several impacts to aquatic habitat could occur during the mining 

31 process, including physical habitat disturbance at the drill site; the potential to add, discharge, or 

32 cause the release of pollutants into waterbodies near the drill site; reduced water flow where 

33 water is withdrawn to support mining operations; and degradation of aquatic habitat if recovered 

34 “frac water” is not properly treated before discharge into waterbodies (DRBC 2012b). Direct 

35 impacts to aquatic biota could occur if aquatic organisms are immobile or unable to avoid the 

36 drill site. On May 5, 2010, DRBC voted to postpone its consideration of well pad dockets 

37 until DRBC has developed and implemented regulations for natural gas development within 

38 Marcellus Shale. As of May 2012, DRBC was in the process of developing these regulations, 

39 which would likely provide protection of aquatic resources during drilling activities 

40 (DRBC 2012b). 

41 4.12.3.3. Climate Change 

42 Within the northeast region, climate models predict increasing average annual temperatures 

43 that foster rising sea surface temperatures and sea levels, increased heavy precipitation, 

44 reduced snowpack, and earlier spring peak river flows (Karl et al. 2009). The impacts of climate 

45 change on aquatic communities within the Delaware River Basin may be substantial and 

46 subsequently affect aquatic resources in the region. For example, seasonal spawning may shift 

47 earlier to coincide with earlier spring flows from higher temperatures melting snowpack earlier in 

48 the season. Increased water temperatures and higher sea levels may result in anadromous fish 
Environmental Impacts of Operation

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1 migrations further up the Delaware or Schuylkill Rivers. Further degradation of water quality 

2 from increased runoff following heavy precipitation events may compromise sensitive life stages 

3 of aquatic species in associated watersheds and have noticeable effects on aquatic populations. 

4 Interlandi and Crockett (2003) examined the relative influences of climate change and 

5 stormwater discharge on the Schuylkill River Basin from 1895 to 1999 using temperature, 

6 precipitation, and river discharge data. While seasonal variations exist, the overall influence of 

7 long-term climate change showed marginal influence as increasing urbanization and increased 

8 stormwater discharge had a larger direct effect on water quality (Interlandi and Crockett 2003). 

9 Therefore, stormwater discharges may play a larger role than climate change in cumulative 

10 changes to aquatic biota in the future. 

11 4.12.3.4. Conclusion 

12 The stresses from past river flow alterations, increasing urbanization, and demand for water 

13 resources across the geographic area of interest depend on many factors that the NRC staff 

14 cannot quantify, but they are likely to noticeably alter aquatic resources when all stresses on the 

15 aquatic communities are assessed cumulatively. Therefore, the NRC staff concludes that the 

16 cumulative impacts from the proposed license renewal and other past, present, and reasonably 

17 foreseeable projects would be SMALL to MODERATE. 

18 4.12.4. Terrestrial Resources

19 This section addresses past, present, and future actions that could result in cumulative impacts 

20 on the terrestrial species and habitats described in Section 2.2.7. For purposes of this analysis, 

21 the geographic area considered in the evaluation includes the LGS site, the in-scope 

22 transmission line corridors, and the offsite facilities associated with the LGS makeup water 

23 system. See Section 2.2.8.1 for a description of these areas. 

24 Historic Conditions

25 Section 2.2.7 discusses the ecoregion in which the LGS site is located—the Triassic Lowlands 

26 portion of the Northern Piedmont ecoregion—which is dominated by Appalachian oak forest. In 

27 the region surrounding the LGS site, much of what would be forest has been cleared and 

28 cultivated for crops, hayfields, and pastureland. Forest remains on marginal land, such as steep 

29 slopes and land with poorer quality soils. From 1973 to 2000, about 6.2 percent of land in the 

30 Northern Piedmont ecoregion changed in land use type. New development surrounding urban 

31 areas accounted for about 70 percent of this change. This rate of land development is one of 

32 the highest in the Eastern ecoregions over the time period (Auch 2003). 

33 On the immediate site, PECO cleared about 270 ac (110 ha; 42 percent of the current LGS site)

34 for construction of the facility’s buildings, parking lots, roads, and other infrastructure

35 (AEC 1973). The terrestrial habitats on the undeveloped portions of the site have not changed

36 significantly since LGS’s construction (Exelon 2011a). 

37 Energy-Producing Facilities

38 A number of operating energy-producing facilities within the vicinity of the LGS site could affect 

39 the terrestrial environment now and in the future. 

40 Two bituminous coal plants operate near LGS: the Cromby Generating Station (6 mi [10 km] 

41 southeast) and the Titus Coal Plant (18 mi [29 km] northwest). Coal-fired plants are a major 

42 source of air pollution in the United States because they release sulfur dioxide, nitrogen oxides, 

43 mercury, carbon dioxide, and particulates. Nitrous oxides and sulfur dioxides combine with 

44 water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury 
Environmental Impacts of Operation

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1 deposits onto soil and surface water, which may then be taken up by terrestrial and aquatic 

2 plant or animal species and poses the risk of bioaccumulation. 

3 Several natural gas plants operate in the region as well, including Linfield Energy Center, which 

4 lies 3 mi (5 km) northwest of LGS. Natural gas plants emit nitrous oxides and sulfur dioxides, 

5 though at much lower levels than coal plants. Methane, a primary component of natural gas 

6 and also a greenhouse gas, can be released when natural gas is not burned completely or as a 

7 result of leaks or losses during transportation. The release of methane contributes to climate 

8 change, the terrestrial resource impacts of which are discussed below. 

9 Additionally, a number of distillate oil facilities in the area contribute to air emissions, which can 

10 result in bioaccumulation of chemicals and contribute to climate change, as discussed above. 

11 Urbanization and Habitat Fragmentation

12 As the region surrounding the LGS site becomes more developed, habitat fragmentation will 

13 increase. Species that require larger ranges, especially predators, will likely suffer reductions in 

14 their populations. In contrast, herbivores will experience less predation pressure and their 

15 populations are likely to increase. Edge species will benefit from the fragmentation, while 

16 species that require interior forest or swamp habitat will likely suffer. The transmission line 

17 corridors established for LGS’s transmission lines represent habitat fragmentation, though all of 

18 the LGS transmission lines were constructed along existing utility or railroad corridors; therefore, 

19 these lines likely did not contribute measurable cumulative impacts. 

20 Agricultural Runoff

21 As of 2000, agriculture accounted for about 20 percent of Montgomery County’s land acreage 

22 (MCPCB 2005). As development continues, the county’s agricultural lands are being converted 

23 to residential and commercial uses; however, a significant portion of the county continues to be 

24 used for agriculture. The 2000 National Water Quality Inventory reported that agricultural 

25 nonpoint source pollution accounted for the second largest source of impairments to wetlands 

26 (EPA 2012b). Fertilizers and pesticides can affect wetlands in a variety of ways. Because 

27 wetlands are often at lower elevation than surrounding land, they receive much of the runoff 

28 first, and that runoff persists because it is unable to drain to lower ground. This can result in 

29 pollutant loadings and bioaccumulation and changes to species composition and abundance 

30 and increases. Species that rely on wetlands, such as birds and amphibians, are more 

31 sensitive to environmental stressors, which exacerbate these effects. 

32 Parks and Conservation Areas

33 Eleven National and state parks occur within 30 mi (50 km) of the LGS site (see Appendix F). 

34 These areas will continue to provide valuable habitat to native wildlife and migratory birds. As 

35 habitat fragmentation resulting from various types of development occurs, these areas will 

36 become ecologically more important because they will provide large areas of natural habitat. 

37 The Montgomery County Planning Commission (MCPC) has designated about 24 percent of the 

38 county as conservation landscapes. Conservation landscapes provide a focus for the county’s 

39 restoration and native habitat management efforts. The MCPC has designated 13 of these 

40 landscapes, which total about 75,000 ac (30,000 ha). These conservation landscapes include 

41 relatively large forested tracts, stream corridors, wetlands, known sites of rare plant and animal 

42 species, and areas of high natural biodiversity. The large tracts of forest support native bird and 

43 wildlife diversity throughout the county, and the wetland habitats are critical to maintaining 

44 native amphibian and reptile populations (Rhoads and Block 2008). In addition, terrestrial 

45 habitats within the Schuylkill River corridor are protected by the Schuylkill River National and 

46 State Heritage Area. 
Environmental Impacts of Operation

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1 Climate Change

2 Over the next several decades, the U.S. Global Change Research Program (Karl et al. 2009) 

3 estimates that summer temperatures within the Northeast will rise 1.5 to 3.5 °F (0.8 to 1.9 °C) 

4 and winter temperatures will rise 2.5 to 4 °F (1.4 to 2.2 °C). By late this century, the Northeast 

5 is likely to experience shorter winters with more precipitation; short-term droughts in the summer 

6 months; longer, hotter summers; and sea-level rise, among other effects. Changes in the 

7 climate will shift many wildlife population ranges and alter migratory patterns. Such changes 

8 could favor non-native invasive species and promote the population increases of insect pests 

9 and plant pathogens. Climate change will likely alter disturbance regimes as the severity or

10 frequency of precipitation, flooding, and fire change. Climate change may also exacerbate the 

11 effects of existing stresses in the natural environment, such as those caused by habitat 

12 fragmentation, invasive species, nitrogen deposition and runoff from agriculture, and air 

13 emissions. 

14 Conclusion

15 The NRC staff examined the cumulative effects of the construction of LGS, neighboring 

16 energy-producing facilities, continued urbanization and habitat fragmentation, agricultural runoff, 

17 nearby parks and conservation areas, and climate change. The NRC staff concludes that the 

18 minimal terrestrial impacts from the continued LGS operations would not contribute to the 

19 overall decline in the condition of terrestrial resources. The NRC staff believes that the 

20 cumulative impacts of other and future actions during the term of license renewal on terrestrial 

21 habitat and associated species, when added to past, present, and reasonably foreseeable 

22 future actions, would be MODERATE. 

23 4.12.5. Human Health

24 The radiological dose limits for protection of the public and workers have been developed by the 

25 NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation 

26 and radioactive material. These dose limits are codified in 10 CFR Part 20 and

27 40 CFR Part 190. For the purpose of this analysis, the area within a 50-mi (80-km) radius of

28 LGS was included. The REMP conducted by Exelon in the vicinity of the LGS site measures 

29 radiation and radioactive materials from all sources (i.e., hospitals and other licensed users of 

30 radioactive material); therefore, the monitoring program measures cumulative radiological 

31 impacts. Within the 50-mi (80-km) radius of the LGS site there are currently no other nuclear 

32 power reactors or uranium fuel cycle facilities. 

33 Radioactive effluent and environmental monitoring data for the 5-year period from 2006 to 2010 

34 were reviewed as part of the cumulative impacts assessment. In Section 4.9.2 of this SEIS, the 

35 NRC staff concluded that impacts of radiation exposure to the public and workers (occupational) 

36 from operation of LGS during the renewal term are SMALL. The NRC and the State of 

37 Pennsylvania would regulate any future actions in the vicinity of the LGS site that could 

38 contribute to cumulative radiological impacts. 

39 Exelon constructed an Independent Spent Fuel Storage Installation (ISFSI) on the LGS site 

40 in 2008 for the storage of its spent fuel. The installation and monitoring of this facility is 

41 governed by NRC requirements in 10 CFR Part 72, “Licensing Requirements for the 

42 Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and 

43 Reactor-Related Greater Than Class C Waste.” Radiation from this facility, as well as from the 

44 operation of LGS, is required to be within the radiation dose limits in 10 CFR Part 20, 

45 40 CFR Part 190, and 10 CFR Part 72. The NRC carries out periodic inspections of the ISFSI 

46 to verify its compliance with its licensing and regulatory requirements. 
Environmental Impacts of Operation

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1 The cumulative radiological impacts from LGS, Units 1 and 2 and the ISFSI are required to meet 

2 the radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. Therefore, the NRC staff 

3 concludes that cumulative radiological impacts would be SMALL. 

4 4.12.6. Socioeconomics

5 Socioeconomics

6 This section addresses socioeconomic factors that have the potential to be directly or indirectly 

7 affected by changes in operations at LGS, Units 1 and 2 in addition to the aggregate effects of 

8 other past, present, and reasonably foreseeable future actions. The primary geographic areas 

9 of interest considered in this cumulative analysis include Montgomery, Berks, and Chester 

10 Counties where approximately 84 percent of LGS, Units 1 and 2 employees reside (see 

11 Section 2.2.9). This is where the economy, tax base, and infrastructure would most likely be 

12 affected since LGS workers and their families reside, spend their income, and use their benefits 

13 within these counties. As previously discussed in Section 4.1, onsite land use conditions at 

14 LGS are expected to remain unchanged during the license renewal term. Therefore, activities 

15 associated with continued reactor operations during the license renewal term are not expected 

16 to affect the use and management of LGS lands identified as part of the Schuylkill River 

17 Greenway. 

18 As discussed in Section 4.10 of this SEIS, continued operation of LGS would have no impact on 

19 socioeconomic conditions in the region during the license renewal term beyond what is already 

20 being experienced. Since Exelon has no plans to hire additional workers during the license 

21 renewal term, overall expenditures and employment levels at LGS, Units 1 and 2 would remain 

22 relatively unchanged with no new, additional, or increased demand for permanent housing and 

23 public services. In addition, since employment levels and tax payments would not change, 

24 there would be no population or tax revenue-related land use impacts. Based on this and other 

25 information presented in Chapter 4 of this SEIS, there would be no contributory effect from 

26 continued operations of LGS, Units 1 and 2 on socioeconomic conditions in the region beyond 

27 what is currently being experienced. Therefore, the only cumulative contributory effects would 

28 come from the other planned activities in the region independent of LGS, Units 1 and 2 

29 operations.

30 Environmental Justice

31 The environmental justice cumulative impact analysis assesses the potential for 

32 disproportionately high and adverse human health and environmental effects on minority and 

33 low-income populations that could result from past, present, and reasonably foreseeable future 

34 actions including LGS, Units 1 and 2 operations during the renewal term. Adverse health 

35 effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human 

36 health. Disproportionately high and adverse human health effects occur when the risk or rate of 

37 exposure to an environmental hazard for a minority or low-income population is significant and 

38 exceeds the risk or exposure rate for the general population or for another appropriate 

39 comparison group. Disproportionately high environmental effects refer to impacts or risk of 

40 impact on the natural or physical environment in a minority or low-income community that are 

41 significant and appreciably exceeds the environmental impact on the larger community. Such 

42 effects may include biological, cultural, economic, or social impacts. Some of these potential 

43 effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and 

44 low-income populations are subsets of the general public residing in the area and all would be 

45 exposed to the same hazards generated from LGS operations. As previously discussed in this 

46 chapter, the impact from license renewal for all resource areas (e.g., land, air, water, ecology, 

47 and human health) would be SMALL. 
Environmental Impacts of Operation

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1 As discussed in Section 4.10.7 of this SEIS, there would be no disproportionately high and 

2 adverse impacts to minority and low-income populations from the continued operation of LGS, 

3 Units 1 and 2 during the license renewal term. Since Exelon has no plans to hire additional 

4 workers during the license renewal term, employment levels at LGS, Units 1 and 2 would 

5 remain relatively constant with no new, additional, or increased demand for housing or 

6 increased traffic. Based on this information and the analysis of human health and 

7 environmental impacts presented in Chapters 4 and 5, it is not likely there would be any 

8 disproportionately high and adverse contributory effect on minority and low-income populations 

9 from the continued operation of LGS during the license renewal term. 

10 4.12.7. Cultural Resources

11 This section addresses the direct and indirect effects of license renewal on historic and cultural 

12 resources when added to the aggregate effects of other past, present, and reasonably 

13 foreseeable future actions. The geographic area considered in this analysis is the Area of 

14 Potential Effect (APE) associated with the proposed undertaking, as described in 

15 Section 2.2.10. 

16 Substantial archeological records indicate that there was historic occupation of the LGS area. 

17 Surveys were performed in the 1970s and 1980s. Section 2.2.10 presents an overview of the 

18 existing historic and archaeological resources located on the LGS site. Past land development 

19 has resulted in impacts on and the loss of cultural resources near and at the LGS site. As 

20 described in Section 4.10.6, no cultural resources would be affected by relicensing activities 

21 associated with the LGS site because there will be no changes or ground-disturbing activities 

22 that will occur as part of the relicensing of LGS, Units 1 and 2 (Exelon 2011a). Cultural 

23 resources are being managed through Exelon’s Cultural Resources Management Plan and the 

24 Fricks Lock rehabilitation and mothball project (Exelon 2012a). 

25 The present and reasonably foreseeable projects reviewed in conjunction with license renewal 

26 are noted in Appendix F of this document. Direct impacts would occur if archaeological sites in 

27 the APE are physically removed or disturbed. The following projects are located within the 

28 geographic area considered for cumulative impacts: 

29 • decommissioning of LGS Units 1 and 2,

30 • transmission lines, and

31 • future urbanization. 

32 Decommissioning of LGS Units 1 and 2, transmission lines, and future urbanization have the 

33 potential to result in impacts on cultural resources through inadvertent discovery during 

34 ground-disturbing activities. However, as discussed above in Section 4.10.6, the contribution 

35 from the proposed license renewal action would not incrementally affect historic or cultural 

36 resources. Therefore, the NRC staff concludes that the cumulative impacts of the proposed 

37 license renewal plus other past, present, and reasonable foreseeable future activities on historic 

38 and cultural resources would be SMALL. 

39 4.12.8. Summary of Cumulative Impacts

40 The NRC staff considered the potential impacts resulting from the operation of LGS during the 

41 period of extended operation and other past, present, and reasonably foreseeable future actions 

42 near LGS. The preliminary determination is that the potential cumulative impacts would range 

43 from SMALL to MODERATE, depending on the resource. Table 4–10 summarizes the 

44 cumulative impacts on resources areas. 
Environmental Impacts of Operation

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1 Table 4–10. Summary of Cumulative Impacts on Resource Areas

Resource Area Cumulative Impact

Air Quality

Because there are no planned site refurbishments with the LGS license renewal, and 

no expected changes in air emissions, cumulative impacts in Montgomery and Chester 

Counties would be the result of changes to present-day emissions and emissions from 

reasonably foreseeable projects and actions. Various strategies and techniques are 

available to limit air quality impacts. Therefore, the cumulative impacts from the 

continued operation of LGS would be SMALL. 

Water Resources

Surface water withdrawals by LGS and other surface water users in the basin are 

subject to limits and conditions imposed by DRBC. The DRBC and PADEP 

established a regulatory framework to manage surface water use and quality. The 

water quality of Delaware River and its main tributaries, such as the Schuylkill, has 

improved over the past several decades. The annual net groundwater withdrawals in 

the Schuylkill-Sprogels Run Subbasin are currently below the DRBC limits. Therefore, 

the cumulative impacts from the continued operations of LGS would be SMALL. 

Aquatic Ecology

The stresses from past river flow, alterations, increasing urbanization, and demand of 

water resources across the geographic area of interest are likely to alter aquatic 

resources when stresses on the aquatic communities are assessed cumulatively. 

Therefore, the cumulative impacts from the continued operation of LGS would be 

SMALL to MODERATE. 

Terrestrial 

Ecology

A number of operating energy-producing facilities within the vicinity of LGS have the 

potential to affect terrestrial resources. Habitat fragmentation will increase as the 

region surrounding the LGS site becomes more developed. Therefore, the cumulative 

impacts from the continued operation of LGS would be MODERATE. 

Human Health

The NRC staff reviewed the radioactive effluent and environmental monitoring data 

from 2006 to 2010, and concluded the impacts of radiation exposure to the public from 

operation of LGS during the renewal term are SMALL. The cumulative radiological 

impacts from LGS and the Independent Spent Fuel Storage Installation would be 

required to meet radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. 

Therefore, the cumulative impacts from the continued operation of LGS would be 

SMALL. 

Socioeconomics

As discussed in Section 4.9, continued operation of LGS during the license renewal 

term would have no impact on socioeconomic conditions in the region beyond those 

already experienced. Exelon has no plans to hire additional workers during the license 

renewal term; employment levels at LGS would remain relatively constant with no new 

demands for housing or increased traffic. Combined with other past, present, and 

reasonably foreseeable future activities, there will be no additional contributory effect 

on socioeconomic conditions from the continued operation of LGS during the license 

renewal period beyond what is currently being experienced. 

Cultural 

Resources 

Transmission lines, future urbanization, and decommissioning of LGS have the 

potential to affect cultural resources through inadvertent discovery during 

ground-disturbing activities. However, no cultural resources would be affected by 

relicensing activities associated with the LGS site because there will be no changes or 

ground-disturbing activities that will occur as part of the relicensing of LGS, Units 1 and 

2. Therefore, combined with other past, present, and reasonable foreseeable future 

activities, the potential cumulative impacts on historic and cultural resources would be 

SMALL. 
Environmental Impacts of Operation

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1 4.13. References

2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

3 protection against radiation.”

4 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

5 production and utilization facilities.”

6 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

8 10 CFR Part 72. Code of Federal Regulations. Title 10, Energy, Part 72, “Licensing 

9 requirements for the independent storage of spent nuclear fuel, high-level radioactive waste, 

10 and reactor-related greater than Class C waste.” 

11 18 CFR Part 430, Code of Federal Regulations, Title 18, Conservation of Power and Water 

12 Sources, Part 430, “Ground water protected area: Pennsylvania.” 

13 36 CFR Part 60. Code of Federal Regulations, Title 36, “Parks, Forests, and Public Property,” 

14 Part 60, “National Register of Historic Places.”

15 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

16 Part 800, “Protection of historic properties.”

17 40 CFR Part 81. Code of Federal Regulations. Title 40, Protection of Environment, Part 81, 

18 “Designation of areas for air quality planning purposes.”

19 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

20 “Environmental radiation protection standards for nuclear power operations.”

21 50 CFR Part 402. Code of Federal Regulations. Title 50, Wildlife and Fisheries, Part 402, 

22 “Interagency cooperation—Endangered Species Act of 1973, as amended.

23 59 FR 7629. Executive Order 12898. Federal actions to address environmental justice in 

24 minority populations and low-income populations. Federal Register 59(32):7629–7634, 

25 February 16, 1994.

26 69 FR 41576. Environmental Protection Agency. “National Pollutant Discharge Elimination 

27 System-Final Regulations to Establish Requirements for Cooling Water Intake Structures at 

28 Phase II Existing Facilities.” Federal Register 69(131):41576-41593. July 9, 2004.

29 69 FR 52040. U.S. Nuclear Regulatory Commission. Policy statement on the treatment of 

30 environmental justice matters in NRC regulatory and licensing actions. Federal 

31 Register 69(163):52040–52048. August 24, 2004.

32 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the 

33 Proposed Limerick Generating Station Units 1 and 2. Washington, DC: AEC. June 1973. 700 p. 

34 Agencywide Documents Access and Management System (ADAMS) Accession 

35 No. ML11313A215.

36 Auch RF. 2003. “Northern Piedmont.” Available at 

37 <http://landcovertrends.usgs.gov/east/eco64Report.html> (accessed 12 May 2012).

38 [BHP] Bureau of Historic Preservation. 2011. Letter from D.C. McLearen, Pennsylvania 

39 Historical and Museum Commission Bureau for Historic Preservation, to D.H. Frens, Frens and 

40 Frens. Subject: NRC: Limerick Generating Station Relicensing Project, Fricks Lock Village 

41 Rehabilitation and Mothballing, E. Coventry Twp., Chester Co. October 19, 2011. ADAMS 

42 Accession No. ML11318A295.
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1 [CAPS] Missouri Census Data Center Circular Area Profiling System. Version 10C. Using Data 

2 from Summary File 1, 2010 Census Summary of Census Tracts in a 50-mile radius around the 

3 South Texas Project (40.22 Lat., -75.58 Long.). March 2012.

4 [CEQ] Council on Environmental Quality. 1997. Environmental Justice: Guidance Under the 

5 National Environmental Policy Act. Available at <http://www.epa.gov/compliance/ej/

6 resources/policy/ej_guidance_nepa_ceq1297.pdf> (accessed 22 May 2012). ADAMS Accession 

7 No. ML082520150.

8 [CRA] Conestoga-Rovers & Associates. 2006. Hydrogeologic Investigation Report, Fleetwide 

9 Assessment Limerick Generating Stations, Pottstown, Pennsylvania. September 2006. ADAMS 

10 No. ML12110A228.

11 [DRBC] Delaware River Basin Commission. 1961. Delaware River Basin Compact. Available at 

12 <http://www.state.nj.us/drbc/about/regulations/> (accessed 11 May 2012). 

13 [DRBC] Delaware River Basin Commission. 1999. Ground Water Protected Area Regulations, 

14 Southeastern Pennsylvania. June 23, 1999. Available at 

15 <http://www.state.nj.us/drbc/about/regulations/> (accessed 11 May 2012). 

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11 Annual Radioactive Effluent Release Report No 33. Sanatoga, PA. ADAMS No. 

12 ML0812606830.

13 [Exelon] Exelon Generation Company, LLC. 2009a. Limerick Generating Station, Units 1 and 2. 

14 2008 Annual Radiological Environmental Operating Report. Sanatoga, PA. ADAMS No. 

15 ML0912800600.

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17 Annual Radioactive Effluent Release Report No 34. Sanatoga, PA. ADAMS No. 

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20 Annual Radiological Environmental Operating Report, Report No. 25, 1 January through 31 

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40 Annual Radiological Environmental Operating Report, 1 January Through 31 December 2011. 

41 Sanatoga, PA: Exelon Nuclear. April 2012. ADAMS No. ML12121A620. 

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43 Annual Radioactive Effluent Release Report No 37. Sanatoga, PA. ADAMS No. ML12129A391
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14 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 

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

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

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24 Accession No. ML1121A265.

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26 McCulloch, Advisory Council on Historic Preservation, dated September 16, 2011, “Limerick 

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30 PNNL, dated November 1, 2012. “LGS License Renewal–SHPO Meeting.” ADAMS Accession 

31 No. ML12255A291. 

32 [NRC] U.S. Nuclear Regulatory Commission. 2011d. Letter from D. Wrona, RPB2 Branch Chief, 

33 NRC, to M. Roberts, Pennsylvania Field Office, U.S. Fish and Wildlife Service. Subject: Request 

34 for list of protected species within the area under evaluation for the Limerick Generating Station, 

35 Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession No. 

36 ML11258A248.

37 [NRC] U.S. Nuclear Regulatory Commission. 2011e. Letter from D. Wrona, RPB2 Branch Chief, 

38 NRC, to C. Urban, Division of Environmental Services, Pennsylvania Fish and Boat 

39 Commission. Subject: Request for list of protected species within the area under evaluation for 

40 the Limerick Generating Station, Units 1 and 2, license renewal application review. 

41 September 8, 2011. ADAMS Accession No. ML11234A024.

42 [NRC] U.S. Nuclear Regulatory Commission. 2011f. Letter from D. Wrona, RPB2 Branch Chief, 

43 NRC, to C. Firestone, Bureau of Forestry Plant Program, Pennsylvania Department of 

44 Conservation and Natural Resources. Subject: Request for list of protected species within the 

45 area under evaluation for the Limerick Generating Station, Units 1 and 2, license renewal 

46 application review. September 16, 2011. ADAMS Accession No. ML11230B346.
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2 NRC, to O. Braun, Environmental Planner, Pennsylvania Game Commission. Subject: Request 

3 for list of protected species within the area under evaluation for the Limerick Generating Station, 

4 Units 1 and 2, license renewal application review. September 8, 2011. ADAMS Accession 

5 No. ML11234A065.

6 [NRC] U.S. Nuclear Regulatory Commission. 2012a. Letter from J. Susco, RERB Acting Branch 

7 Chief, NRC, to D. Morris, Acting Regional Administrator, National Marine Fisheries Service. 

8 Subject: Request for list of Federal protected species within the area under evaluation for the 

9 Limerick Generating Station, Units 1 and 2, license renewal application review. May 30, 2012. 

10 ADAMS Accession No. ML12138A347.

11 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Staff Requirements, SECY-12-0063, “Final 

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

13 Licenses (10 CFR Part 51; RIN 3150–AI42).” December 6, 2012. ADAMS No. ML12341A134. 

14 O’Herron, JC, Able, KW, Hastings, RW. 1993. Movements of shortnose sturgeon (Acipenser 

15 brevirostrum) in the Delaware River. Estuaries 16(2):235-240.

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17 (BRP). Environmental Radiation in Pennsylvania 2003 and 2004 Annual Reports. Available at 

18 <http://www.elibrary.dep.state.pa.us/dsweb/Get/Document-66310/2900-BK-DEP4006%

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24 20Package.pdf> (accessed 18 April 2012). 

25 [PDCNR] Pennsylvania Department of Conservation and Natural Resources. 2011. Letter from 

26 R. Bowen, Environmental Review Manager, for C. Firestone, Wild Plant Program Manager, 

27 Bureau of Forestry, PDCNR, to M. Gallagher, Exelon Nuclear. Subject: Pennsylvania Natural 

28 Diversity Inventory review for renewal of operating licenses for Limerick Generating Station, 

29 Units 1 and 2, Chester, Montgomery & Bucks Counties. March 9, 2011. In Appendix C to 

30 Applicant’s Environmental Report—Operating License Renewal Stage, Limerick Generating 

31 Station, Units 1 and 2. ADAMS Accession No. ML11179A104. 

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33 Limerick Generating Station Units 1 & 2, Vol. 1. Philadelphia, PA: PECO. September 30, 1984. 

34 ADAMS Accession No. ML11299A113.

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36 with application to anadromous fish restoration in the Schuylkill River, Pennsylvania.” Journal of 

37 the Pennsylvania Academy of Science 83(1):24–33.

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39 Diversity Section Chief, PFBC, to N. Ranek, Exelon Nuclear. Subject: Species impact review for 

40 renewal of operating licenses for Limerick Generating Station, Units 1 and 2, Montgomery and 

41 Chester County, Pennsylvania. February 11, 2011. In Appendix C of “Exelon 2011a.” ADAMS 

42 Accession No. ML11179A104.
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4 Montgomery and Chester County, Pennsylvania. October 5, 2011. ADAMS Accession 

5 No. ML11291A077.

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7 Planner, Division of Environmental Planning and Habitat Protection, PGC, to D. Wrona, RPB2 

8 Chief, NRC. Subject: Re: Limerick Generating Station and transmission lines—license renewal, 

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10 ML11329A060.

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12 Chester, and Montgomery Counties.” Available at <http://www.naturalheritage.state.pa.us/>

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16 <http://www.naturalheritage.state.pa.us/factsheets/13979.pdf> (accessed 10 April 2012).

17 [PNHP] Pennsylvania Natural Heritage Program. 2012c. “Species Fact Sheet, Floating-heart 

18 (Nymphoides cordata).” Available at 

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23 Rhoads AF, Block TA. 2008. Montgomery County, Pennsylvania: Natural Areas Inventory 

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5-1 

1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

2 This chapter describes the environmental impacts from postulated accidents that Limerick 

3 Generating Station, Units 1 and 2 (LGS) might experience during the period of extended 

4 operation. The term “accident” refers to any unintentional event outside the normal plant 

5 operational envelope that results in a release or the potential for release of radioactive materials 

6 into the environment. The two classes of postulated accidents listed in Table 5–1 are evaluated 

7 in detail in the generic environmental impact statement (GEIS). These two classes of accidents 

are: 8 

9  design-basis accidents (DBAs), and

10  severe accidents.

11 Table 5–1. Issues Related to Postulated Accidents

Issues GEIS Section Category

DBAs 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

12 5.1. Design-Basis Accidents

13 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 

14 power plant, an applicant for an initial operating license must submit a safety analysis report 

15 (SAR) as part of its application. The SAR presents the design criteria and design information for 

16 the proposed reactor and comprehensive data on the proposed site. The SAR also discusses 

17 various hypothetical accident situations and the safety features that prevent and mitigate 

18 accidents. The NRC staff (the staff) reviews the application to determine if the plant design 

19 meets the NRC’s regulations and requirements and includes, in part, the nuclear plant design 

20 and its anticipated response to an accident.

21 DBAs are those accidents that both the licensee and the staff evaluate to ensure that the plant 

22 can withstand normal and abnormal transients and a broad spectrum of postulated accidents, 

23 without undue hazard to the health and safety of the public. Many of these postulated accidents 

24 are not expected to occur during the life of the plant but are evaluated to establish the design 

25 basis for the preventive and mitigative safety systems of the nuclear power plant. Title 10 of the 

26 Code of Federal Regulations (10 CFR) Part 50 and 10 CFR Part 100 describe the acceptance 

27 criteria for DBAs.

28 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 

29 ability of the nuclear power plant to withstand these accidents is demonstrated to be acceptable 

30 before issuance of the operating license. The results of these evaluations are found in license 

31 documentation such as the applicant’s final safety analysis report (FSAR), the staff's safety 

32 evaluation report (SER), the final environmental statement (FES), and Section 5.1 of this 

33 supplemental environmental impact statement (SEIS). A licensee is required to maintain the 

34 acceptable design and performance criteria throughout the life of the nuclear power plant, 

35 including any period of extended operation. The consequences for these events are evaluated 

36 for the hypothetical maximum exposed individual. Because of the requirements that continuous 

37 acceptability of the consequences and aging management programs be in effect for license 

38 renewal, the environmental impacts, as calculated for DBAs, should not differ significantly from 

39 initial licensing assessments over the life of the nuclear power plant, including the license 
Environmental Impacts of Postulated Accidents

5-2 

1 renewal period. Accordingly, the design of the nuclear power plant, relative to DBAs during the 

2 extended period, is considered to remain acceptable; therefore, the environmental impacts of 

3 those accidents were not examined further in the GEIS.

4 The NRC has determined in the GEIS that the environmental impacts of DBAs are of SMALL 

5 significance for all nuclear power plants because the plants were designed to successfully 

6 withstand these accidents. Therefore, for the purposes of license renewal, DBAs are 

7 designated as a Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The 

8 early resolution of the DBAs makes them a part of the current licensing basis (CLB) of the plant; 

9 the CLB of the plant is to be maintained by the licensee under its current license and, therefore, 

10 under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This 

11 issue is applicable to LGS.

12 Exelon Generation Company, LLC (Exelon) stated in its environmental report (ER) 

13 (Exelon 2011c) that it is not aware of any new and significant information related to DBAs 

14 associated with the renewal of the LGS. The staff has not noted any new and significant 

15 information during its independent review of Exelon’s ER, the scoping process, or its evaluation 

16 of other available information. Therefore, the staff concludes that there are no impacts related 

17 to DBAs beyond those discussed in the GEIS (NRC 1996). 

18 5.2. Severe Accidents

19 Severe nuclear accidents are those that are more severe than DBAs because they could result 

20 in substantial damage to the reactor core, whether or not there are serious offsite 

21 consequences. In the GEIS, the staff assessed the effects of severe accidents during the 

22 period of extended operation, using the results of existing analyses and site-specific information 

23 to conservatively predict the environmental impacts of severe accidents for each plant during 

24 the period of extended operation.

25 The impacts from severe accidents initiated by external phenomena such as tornadoes, floods, 

26 earthquakes, fires, and sabotage were specifically considered in the GEIS. The GEIS evaluated 

27 existing impact assessments—performed by the staff and by the industry at 44 nuclear power 

28 plants (including LGS) in the United States—and concluded that the risk from beyond 

29 design-basis earthquakes at existing nuclear power plants is SMALL. The GEIS also performed 

30 a discretionary analysis of sabotage, in connection with license renewal, and concluded that the 

31 core damage and radiological release from such acts would be no worse than the damage and 

32 release expected from internally initiated events. In the GEIS, the NRC concludes that the risk 

33 from sabotage at existing nuclear power plants is SMALL and, additionally, that the risks from 

34 other external events are adequately addressed by a generic consideration of internally initiated 

35 severe accidents (NRC 1996). 

36 Based on information in the GEIS, the NRC determined in its regulations that: 

37 The probability weighted consequences of atmospheric releases, fallout onto open bodies of 

38 water, releases to ground water, and societal and economic impacts from severe accidents are 

39 small for all plants. However, alternatives to mitigate severe accidents must be considered for 

40 all plants that have not considered such alternatives.

41 The staff found no new and significant information related to postulated accidents during the 

42 review of Exelon’s ER (Exelon 2011c), the scoping process, or evaluation of other available 

43 information. Therefore, there are no impacts related to these issues, beyond those already 

44 discussed in the GEIS. 
Environmental Impacts of Postulated Accidents

5-3 

1 5.3. Severe Accident Mitigation Alternatives

2 The purpose of the evaluation of severe accident mitigation alternatives (SAMAs) is to identify 

3 design alternatives, procedural modifications, or training activities that are cost-beneficial and 

4 further reduce the risks of severe accidents (NRC 1999a). The analysis of SAMAs includes the 

5 identification and evaluation of alternatives that reduce the radiological risk from a severe 

6 accident by preventing substantial core damage (i.e., preventing a severe accident) or by 

7 limiting releases from containment in the event that substantial core damage occurs (i.e., 

8 mitigating the impacts of a severe accident) (NRC 1999b). In accordance with 10 CFR 

9 51.53(c)(3)(ii)(L) and Table B-1 of Part 51, license renewal ERs must provide a consideration of

10 alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the 

11 applicant’s plant in an environmental impact statement (EIS) or related supplement or in an 

12 environmental assessment. 

13 The staff has previously performed a site-specific analysis of severe accident mitigation in a 

14 NEPA document for LGS in the Final Environmental Statement Related to Operation of LGS, 

15 Units 1 and 2 in NUREG-0974, Supplement 1 (NRC 1989) (“1989 SAMDA Analysis”). 

16 Therefore, no analysis of SAMAs for LGS is required in Exelon’s ER or the staff’s SEIS. The 

17 NRC Staff uses the term SAMA to refer to severe accident mitigation alternatives at the license 

18 renewal phase. In contrast, the term severe accident mitigation design alternatives (SAMDA) 

19 refers to severe accident mitigation alternatives at the initial licensing phase. The site-specific 

20 SAMDAs reviewed for applicability to LGS were evaluated in the 1989 SAMDA Analysis and 

21 also documented in GEIS Table 5.35. The staff examined each SAMDA (individually and, in 

22 some cases, in combination) to determine the potential SAMDA individual risk reduction 

23 potential. This risk reduction was then compared with the cost of implementing the SAMDA to 

24 provide cost-benefit evidence of its value. The staff concluded that: 

25 The risks of early fatality from potential accidents at the site are small in 

26 comparison with risks of early fatality from other human activities in a comparably 

27 sized population, and the accident risk will not add significantly to population 

28 exposure and cancer risks. Accident risks from Limerick are expected to be a 

29 small fraction of the risks the general public incurs from other sources. Further, 

30 the best estimates show that the risks of potential reactor accidents at Limerick 

31 are within the range of such risks from other nuclear power plants. 

32 However, in the LGS specific 1989 SAMDA Analysis, the staff acknowledged: 

33 In the longer term, these same severe accident issues are currently being 

34 pursued by the NRC in a systematic way for all utilities through the Severe 

35 Accident Program described in SECY-88-147, “Integration Plan for Closure of 

36 Severe Accident Issues” (NRC 1988c). The plan includes provisions for an 

37 Individual Plant Examination (IPE) for each operating reactor, a Containment 

38 Performance Improvement (CPI) program, and an Accident Management (AM) 

39 program. These programs will produce a more complete picture of the risks of 

40 operating plants and the benefits of potential design improvements, including 

41 SAMDAs. The staff believes that the severe accident program is the proper 

42 vehicle for further review of severe accidents at nuclear power plants, including 

43 Limerick. 

44 Therefore, the Commission considers ways to mitigate severe accidents at a given site more 

45 than once. The Commission has considered alternatives for mitigating severe accidents at 

46 many sites, including LGS, multiple times through a variety of NRC programs. When it 

47 promulgated Table B-1 of 10 CFR Part 51, the Commission explained,

48 The Commission has considered containment improvements for all plants 

49 pursuant to its Containment Performance Improvement (CPI) program...and the 
Environmental Impacts of Postulated Accidents

5-4 

1 Commission has additional ongoing regulatory programs whereby licensees 

2 search for individual plant vulnerabilities to severe accidents and consider cost3 beneficial improvements [(the individual plant examination “IPE” and individual 

4 plant examination of external events “IPEEE” programs)] (61 Fed. Reg. 28,467).

5 In light of these studies, the Commission believed it was “unlikely that any site-specific 

6 consideration of SAMAs for license renewal will identify major plant design changes or 

7 modifications that will prove to be cost-beneficial for reducing severe accident frequency or 

8 consequences” (61 FR 28467). Given the significant costs of a major plant design change, 

9 such an improvement must result in a substantial reduction in risk to be cost-beneficial. As 

10 discussed below, these studies already thoroughly considered severe accidents and ways to 

11 mitigate their impacts and did not identify cost-beneficial major plant design changes or 

12 modifications for mitigating the impacts of severe accidents. Regulations in 10 CFR 

13 51.53(c)(3)(ii)(L) and Table B-1 reflect the Commission’s judgment that in light of these ongoing 

14 studies, reconsideration of SAMAs at license renewal would be unlikely to uncover major cost15 beneficial plant modifications and is unnecessary.

16 Containment Performance Improvement Program

17 One of the programs the Commission relied on in determining that SAMAs need not be 

18 performed at license renewal if the staff had already performed a SAMA review in an earlier 

19 NEPA document is the CPI program. With this program, the NRC examined each of five U.S. 

20 reactor containment types (BWR Mark I, II, and III; PWR Ice Condenser; and PWR Dry) with the 

21 purpose of examining the potential failure modes, potential fixes, and the cost benefit of such 

22 fixes. Tables 5.32 through 5.34 in the GEIS summarize the results of this program. As can be 

23 seen from these tables, many potential changes were evaluated but only a few containment 

24 improvements were identified for site-specific review. The items evaluated in the CPI program 

25 were also included in the list of plant-specific SAMDAs examined in the LGS FES supplement

26 (NRC 1996). 

27 Individual Plant Examination

28 Another program the Commission relied on in determining that SAMAs need not be performed 

29 at license renewal if the staff had already performed a SAMA review in an earlier NEPA 

30 document is the Individual Plant Examination (IPE). The IPE’s specific objective was to develop 

31 an appreciation of severe accident behavior, and to identify ways in which the overall 

32 probabilities of core damage and fission product releases could be reduced if deemed 

33 necessary. In general, the IPEs have resulted in plant procedural and programmatic 

34 improvements (i.e., accident management) and, in only a few cases, minor plant modifications, 

35 to further reduce the risk and consequences of severe accidents (NRC 1996). 

36 In accordance with NRC’s policy statement on severe accidents, the licensee performed an IPE 

37 to look for vulnerabilities to both internal and external initiating events (NRC 1988a). This 

38 examination considered potential improvements on a plant-specific basis. The CDF was found 

to be considerably less in the LGS IPE (4.3x10-6 39 ) than in the original CDF value provided in 

NUREG-1068 (1.0x10-5) for LGS and the 1989 PRA Update (1.0x10-5 40 ) used in the 1989 SAMDA 

Analysis review. The staff further notes that the 2009 PRA Update (3.2x10-6 41 ) is approximately

42 an order of magnitude less than the 1989 PRA Update (Exelon ER). Plant improvements 

43 identified and implemented for LGS as a result of the IPE included: (1) relaxing restrictions on 

44 the drywell spray initiation curve in the Emergency Operating Procedures; (2) creating a 

45 procedure to cross-tie the 4 kV safeguards electrical buses; (3) creating a procedure to power 

46 Unit 2 emergency service water pumps from Unit 1; and (4) creating a cross-connection 

47 between the fire water and residual heat removal systems (PECO 1992).
Environmental Impacts of Postulated Accidents

5-5 

1 Individual Plant Examination of External Events

2 Another program the Commission relied on in determining that SAMAs need not be performed 

3 at license renewal if the staff had already performed a SAMA review in an earlier NEPA 

4 document is the Individual Plant Examination of External Events (IPEEE) program. The IPEEE 

5 program was initiated in the early 1990s. All operating plants in the United States (including 

6 LGS) performed an assessment to identify vulnerabilities to severe accidents initiated by 

7 external events and reported the results to the NRC, along with any identified improvements 

8 and/or corrective actions. Perspectives Gained from the Individual Plant Examination of 

9 External Events (IPEEE) Program, NUREG–1742 documents the perspectives derived from the 

10 technical reviews of the IPEEE results (NRC 2002). As a result of conducting the LGS IPEEE, 

11 PECO Energy identified seismic event and fire event findings. Actions were taken to address 

12 minor housekeeping and maintenance issues related to the seismic analysis such as 

13 unrestrained tools, lockers, hoist controllers and lifting devices for low voltage switchgear. In 

14 addition, Fire brigade drill activities and fire brigade awareness were increased for 3 areas in the 

15 common control structure. Furthermore, actions credited in the fire analysis such as improved 

16 transient combustible controls, creation of transient combustible free zones and formal 

17 designation of certain fire rated doors as "fire" doors were implemented at LGS (PECO 1995).

18 Accident Management Program

19 The staff specifically relied on the Accident Management Program as the proper avenue for 

20 addressing the improvements considered in the 1989 SAMDA Analysis. Accident management 

21 involves the development of procedures that promote the most effective use of available plant 

22 equipment and staff in the event of an accident. The staff indicated its intent (NRC 1988a) that 

23 licensees develop an accident management framework that will include implementation of 

24 accident management procedures, training, and technical guidance. Insights gained as a result 

25 of the IPE were factored into the accident management program at LGS. As discussed earlier, 

26 the majority of improvements identified from the completed IPEs to date have been in the area 

27 of accident management or other procedural and programmatic improvements (NRC 1996 and 

28 NRC 1997). 

29 NRC Efforts to Address Severe Accident-Related Issues since the Publication of the 1996 GEIS

30 The NRC has continued to address accident-related issues since the GEIS was published and 

31 10 CFR Part 51 changes related to license renewal were promulgated. The NRC’s efforts have 

32 reduced risks from accidents beyond that considered in the 1996 GEIS. As discussed below, in 

33 some cases, such as the agency response to Fukushima, these activities are ongoing. Each of 

34 the activities applied or continues to apply to all reactors, including LGS. The specific 

35 requirement for any given reactor was based either on a site-specific evaluation or a 

36 design-specific requirement. 

37 10 CFR 50.54(hh) Conditions of License Regarding Loss of Large Areas of the Plant Due to Fire 

38 or Explosions 

39 Following September 11, 2001, the Commission issued Order EA-02-026 and ultimately a new 

40 regulation (10 CFR 50.54(hh)), which required commercial power reactor licensees to, among 

41 other things, adopt mitigation strategies using readily available resources to maintain or restore 

42 core cooling, containment, and spent fuel pool cooling capabilities to cope with the loss of large 

43 areas of the facility due to large fires and explosions from any cause, including 

44 beyond-design-basis aircraft impacts (See 74 FR 13926). The final rule also added several new 

45 requirements developed as a result of insights gained from implementation of the security 

46 orders, reviews of site security plans, and implementation of the enhanced baseline inspection 

47 program, and updated the NRC’s security regulatory framework for the licensing of new nuclear 
Environmental Impacts of Postulated Accidents

5-6 

1 power plants. Compliance with the final rule was required by March 31, 2010, for licensees, 

2 including Exelon, currently licensed to operate under 10 CFR Part 50. Exelon has updated its 

3 plant and procedures accordingly, and the NRC has inspected the guidelines and strategies that 

4 Exelon has implemented to meet the requirements of 10 CFR 50.54(hh)(2). The specifics of the 

5 enhancements are security related and not publicly available but in general include: 

6 (1) significant reinforcement of the defense capabilities for nuclear facilities, (2) better control of 

7 sensitive information, (3) enhancements in emergency preparedness to further strengthen the 

8 NRC’s nuclear facility security program, and (4) implementation of mitigating strategies to deal 

9 with postulated events potentially causing loss of large areas of the plant due to explosions or 

10 fires, including those that an aircraft impact might create. These measures are outlined in 

11 greater detail in NUREG/BR-0314 (NRC 2004), NUREG-1850 (NRC 2006a), and Sandia 

12 National Laboratory’s “Mitigation of Spent Fuel Loss-of-Coolant Inventory Accidents and 

13 Extension of Reference Plant Analyses to Other Spent Fuel Pools” (NRC 2006b).

14 Severe Accident Mitigation Guidelines

15 Exelon has also developed and implemented severe accident mitigation guidelines (SAMGs) at 

16 LGS, which further reduce risk at the facility. SAMGs were developed by the industry during the 

17 1980s and 1990s in response to the Three Mile Island (TMI) Nuclear Station accident and 

18 follow-up activities. SAMGs are meant to “enhance the ability of the operators to manage 

19 accident sequences that progress beyond the point where emergency operating procedures 

20 (EOPs) and other plant procedures are applicable and useful” (NRC 2011a).

21 Fukushima-Related Activities

22 The Commission also considered additional measures to enhance plant severe accident 

23 performance throughout the nuclear fleet, including LGS, following the March 11, 2011, 

24 Fukushima Dai-ichi accident. The Commission established a Task Force to “conduct a 

25 methodical and systematic review of the NRC’s process and regulations to determine whether 

26 the agency should make additional improvements to its regulatory system and to make 

27 recommendations to the Commission for its policy direction.” 

28 As a result of this review, the Task Force issued SECY-11-0093 (NRC 2011c), “Near-Term 

29 Report and Recommendations for Agency Actions Following the Events in Japan;” 

30 SECY-11-0124 (NRC 2011d), “Recommended Actions to be Taken Without Delay from the 

31 Near-Term Task Force Report;” and SECY-11-0137 (NRC 2011f), “Prioritization of 

32 Recommended Actions to be Taken in Response to Fukushima Lessons Learned,” to establish 

33 the staff's prioritization of the recommendations. The Commission’s direction is provided in 

34 SRM-SECY-11-0124 (NRC 2011e) and SRM-SECY-11-0137 (NRC 2011g). In March 2012, 

35 three Orders were issued to U.S. nuclear power plants. The first Order requires all U.S. plants 

36 to better protect portable safety equipment put into place after the 9/11 terrorist attacks and to 

37 obtain sufficient equipment to support all reactors at a given site simultaneously (NRC 2012a). 

38 The second Order applies only to U.S. boiling water reactors that have “Mark I” or “Mark II” 

39 (such as LGS) containment structures. Mark I reactors must improve installed venting systems 

40 that help prevent or mitigate core damage in the event of a serious accident; Mark II reactors 

41 must install these venting systems (NRC 2012b). The third Order requires all plants to install 

42 enhanced equipment for monitoring water levels in each plant’s spent fuel pool (NRC 2012c). 

43 The NRC also issued an information request in March 2012, including earthquake and flooding 

44 hazard “walkdowns,” during which skilled engineers verify that the plants conform to their 

45 current license requirements (NRC 2012d). 

46 Under 10 CFR 51.53(c)(3)(ii)(L) and 10 CFR Part 51 Table B-1, the NRC does not need to 

47 reconsider SAMAs for LGS at the license renewal phase. As provided above, those regulations 

48 rely on more than just the prior 1989 SAMDA Analysis; they also rest on the IPE, IPEEE, and 
Environmental Impacts of Postulated Accidents

5-7 

1 CPI programs, to consider SAMAs in cases like LGS in which the NRC has already analyzed 

2 SAMAs. These studies did not identify major cost-beneficial mitigation measures that could 

3 substantially reduce offsite risk. Rather, they mostly uncovered minor improvements and 

4 programmatic fixes. The volume of studies cited by the Commission, and their ongoing nature, 

5 provide the type of “hard look” the Commission understood it must apply to the issue of severe 

6 accident mitigation alternatives in its NEPA review for every license renewal proceeding

7 (61 FR 28481). This approach is all the more reasonable in light of the Commission’s finding 

8 that the probability-weighted environmental impacts of severe accidents are small.

9 Evaluation of New Information 

10 Additionally, both the applicant and the NRC must consider whether new and significant 

11 information affects environmental determinations in the NRC’s regulations, including the 

12 determination in 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 that the agency need not reconsider 

13 SAMAs at license renewal if it has already done so in a NEPA document for the plant. New 

14 information is significant if it provides a seriously different picture of the impacts of the Federal 

15 action under consideration. Thus, for mitigation alternatives such as SAMAs, new information is 

16 significant if it indicates that a mitigation alternative would substantially reduce an impact of the 

17 Federal action on the environment. Consequently, with respect to SAMAs, new information may 

18 be significant if it indicated a given cost-beneficial SAMA would substantially reduce the impacts 

19 of a severe accident, the probability or consequences (risk) of a severe accident occurring. As 

20 discussed below, none of the information identified by the applicant or the staff indicates that 

21 any SAMAs would be cost beneficial and likely to result in such a reduction of risk. Rather, new 

22 information indicates that further SAMA analyses are unlikely to identify a SAMA that 

23 substantially reduces the risk of a severe accident, such as major, cost-beneficial plant 

24 improvements, and that the overall probability of a severe accident has decreased at LGS. The 

25 following evaluation for new and significant information is to determine whether any new and 

26 significant information exists that provides a “seriously different picture of the environmental 

27 impacts than what was previously envisioned” regarding the determination in 

28 10 CFR 51.53(c)(3)(ii)(L), Table B-1, and the clarifications in the statement of considerations. 

29 As explained above, the Commission determined that no new SAMA analysis is required for

30 plants such as LGS at the license renewal stage. 

31 The applicant relied on this and did not submit a SAMA analysis for license renewal. 

32 Specifically, the applicant cited 10 CFR 51.53(c)(3)(ii)(L) and stated that no SAMA was 

33 submitted as none was required as a matter of law (Entergy 2011c). Thus, the applicant’s 

34 treatment of SAMA in its ER is in accordance with the Commission’s regulations, and the 

35 applicant evaluated the new and significant information evaluation with respect to the 

36 Commission’s regulation (Exelon 2011c). The applicant analyzed whether potentially new and 

37 significant information would change the results of its 1989 SAMDA Analysis review. The 

38 Commission had indicated that if the Staff identifies information that could invalidate the 1989 

39 SAMDS Analysis, it should determine if that information is significant. The staff reviewed the 

40 applicant’s submitted information and also assessed if any new and significant information has 

41 been found that would change the generic conclusion codified by the NRC that Exelon need not 

42 reassess SAMAs at LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)) and the staff need not 

43 reconsider SAMAS at this stage (10 CFR 51, Table B-1). The following summarizes Exelon’s 

44 evaluation and the staff’s review of this information. In addition, the staff’s independent 

45 assessment did not identify any other new and significant information with respect to those 

46 regulations. Hence, no new and significant information has been found with respect to the 

47 generic conclusion codified by the NRC that LGS need not reassess SAMAs for license renewal 

48 (10 CFR 51.53(c)(3)(ii)(L)) because neither the Staff nor applicant uncovered any new and 
Environmental Impacts of Postulated Accidents

5-8 

1 significant information that suggested another cost beneficial SAMA that could substantially 

2 reduce the risk of a severe accident at Limerick. 

3 The Applicant’s Evaluation of New and Significant Information

4 The applicant explained the process it used to identify any potentially new and significant 

5 information related to its existing 1989 SAMA review in Section 5.3.1 of the ER (Exelon 2011c). 

6 As provided in Section 5.1 of Appendix E of the ER (Exelon 2011c), the new and significant 

7 assessment that Exelon conducted during preparation of this license renewal application 

8 included: (1) interviews with Exelon Generation subject-matter experts on the validity of the 

9 conclusions in the GEIS as they relate to LGS, (2) an extensive review of documents related to 

10 environmental issues at LGS, (3) a review of correspondence with State and Federal agencies 

11 to determine if the agencies had concerns relevant to their resource areas that had not been 

12 addressed in the GEIS, (4) a review of the results of LGS environmental monitoring and 

13 reporting, as required by regulations and oversight of plant facilities and operations by State and 

14 Federal regulatory agencies (i.e., the results of ongoing routine activities that could bring 

15 significant issues to Exelon Generation’s attention), (5) a review for issues relevant to the LGS 

16 application of certain license renewal applications that have previously been submitted to the 

17 NRC by the operators of other nuclear plants, and (6) a review of information related to severe 

18 accident mitigation. The significance and materiality of the new information identified through 

19 this process was discussed further in ER Section 5.3.2, “Significance of New Information.” 

20 Exelon used a methodical approach to identify new and significant information and the staff 

21 finds Exelon’s process adequate to ensure a reasonable likelihood that the applicant would be 

22 aware of any new and significant information.

23 The following four items of new information were identified and evaluated by the applicant by 

24 comparing assumptions for the 1989 SAMDA Analysis with assumptions used for current-day 

25 assessments of SAMAs: 

26 (1) population increase

27 (2) consideration of offsite economic cost risk

28 (3) changed criteria for assigning cost per person-rem averted

29 (4) changed seismic hazard proposed by GI-199

30 Each item of new information was evaluated by the applicant and reviewed by the staff to 

31 determine whether it would materially alter the NRC’s conclusions, as documented in the 

32 1989 SAMDA Analysis, which is one of the documents that supports the determination in 

33 10 CFR 51.53(c)(3)(ii)(L). None of the items of new information led to the identification of a 

34 SAMA that was cost-beneficial. Consequently, the applicant’s and staff’s review of new and 

35 significant information with respect to the 1989 SAMA review did not uncover any cost beneficial 

36 plant improvements or SAMAs that would substantially decrease the risk of a severe accident. 

37 Instead, it confirmed that no plant improvements that led to a substantial reduction in risk would 

38 be cost-beneficial. Therefore, the staff finds that none of the new information identified by the 

39 applicant significantly affects the generic conclusion codified by the NRC that applicants need 

40 not reassess SAMAs for license renewal at facilities like LGS (10 CFR 51.53(c)(3)(ii)(L)). 

41 Risk

42 As provided in the discussion earlier regarding LGS’s IPE, the CDF in the 2009 PRA Update 

(3.2x10-6 43 ) is more than an order of magnitude less than the 1989 PRA Update (Exelon ER). 

44 Any change in the likelihood of accidents that release substantial amounts of radioactive 

45 material to the environment not only affects the human impact but also any environmental 

46 impact. For LGS, this decrease in CDF would demonstrate less impact to dose, economic, and 

47 environmental impact. The overall reduction in risk indicates that further SAMA analyses for 
Environmental Impacts of Postulated Accidents

5-9 

1 LGS would be unlikely to uncover cost-beneficial major plant improvements or plant 

2 improvements that could substantially reduce risk. In light of the significant reduction in CDF, 

3 no new information is likely to significantly affect the Commission’s generic determination that 

4 the NRC need not reanalyze SAMAs at LGS for license renewal.

5 Population Increase

6 A summary of Exelon’s evaluation of population increase provided in the ER is as follows. 

7 Exelon provided population values within 50 miles growing from 6,819,505 in 1980 to 9,499,925 

8 in 2030. They further assumed that this 39 percent increase in population would yield an 

9 approximate 39 percent increase in dose values. Hence, even assuming 2030 population 

10 numbers, the highest benefit/cost ratio SAMDA (ATWS Vent) based on cost per person-rem 

11 averted would still not be cost beneficial in the 1989 SAMDA Analysis.

12 The staff reviewed the calculation provided by the applicant and agrees that the population 

13 increase would not make any of the 1989 SAMDA’s cost effective. The staff acknowledges that 

14 a more precise estimate of this relationship could be obtained by using the MACCS2 code, 

15 performing a level III PRA, and completing a SAMA analysis. However, NEPA does not require 

16 the NRC to completely reanalyze issues it has resolved generically, only look for information 

17 that provides a “seriously different picture” of those considered generically. Notably, additional 

18 conservatisms not mentioned by the applicant include that converting the $3,000,000 cost of the

19 anticipated transient without scram (ATWS) Vent SAMDA to 2012 dollars would increase the 

20 cost of the SAMDA to over $5,000,000(assuming similar construction and engineering 

21 practices) and the current CDF for LGS is nearly an order of magnitude smaller than the one 

22 used in the 1989 SAMDA Analysis. Considering the large conservatisms in the analysis with 

23 respect to CDF, the applicant’s analysis is reasonable. Moreover, even if population increase 

24 led to another SAMA becoming cost beneficial, that SAMA would still not likely result in a 

25 substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick since the 

26 1989 SAMDA analysis. Consequently, the population increase within 50 miles of LGS does not 

27 suggest that additional cost beneficial SAMAs could substantially reduce the risk of severe 

28 accidents and therefore does not constitute new and significant information with respect to the 

29 generic conclusion codified by the NRC that SAMAs need not be reassessed at facilities like 

30 LGS for license renewal (10 CFR 51.53(c)(3)(ii)(L)). 

31 Consideration of Offsite Economic Cost Risk

32 The applicant indicated that the 1989 SAMDA Analysis did not consider offsite economic cost 

33 risk. To account for the offsite economic cost risk, the applicant estimated these impacts by 

34 using data from the Three Mile Island (TMI) license renewal application (Amergen 2008). Using 

35 TMI data, the offsite economic cost risk was approximately 70 percent larger than the offsite 

36 exposure cost risk at TMI. In order to apply the TMI data to LGS, the applicant applied a factor 

37 of 3 (300 percent) to analyze the impact on the 1989 SAMDA Analysis for LGS. Applying a 

38 factor of 3 reduction to the closest potential cost beneficial SAMDA (ATWS Vent) would not 

39 result in a cost beneficial SAMDA (Exelon 2011c).

40 The staff assessed the calculation provided by the applicant. The staff also used similar ratios 

41 to evaluate the cost impact of onsite exposure and economic costs for LGS ($2,000 and 

42 $400,000, respectively) to obtain the total offsite and onsite economic and exposure cost. The 

43 net value was -$284,000, indicating the ATWS Vent SAMDA was still not cost effective. Since 

44 this was applied to the SAMDA (ATWS Vent) that was closest to being cost effective, none of 

45 the SAMDAs identified in the 1989 SAMDA Analysis would be cost effective. Additional 

46 conservatisms not mentioned by the applicant include converting the $3,000,000 cost of the 

47 ATWS Vent SAMA to 2012 dollars that would increase the cost of the SAMDA to over 

48 $5,000,000 (assuming similar engineering and construction practices). Considering the large 
Environmental Impacts of Postulated Accidents

5-10

1 conservatisms in the Exelon analysis, it is reasonable. Moreover, even if consideration of offsite 

2 economic risk increase led to another SAMA becoming cost beneficial, that SAMA would still not 

3 likely result in a substantial reduction in offsite risk, given the substantial reduction in CDF at 

4 Limerick since the 1989 SAMDA analysis. Therefore, consideration of offsite costs would not

5 likely lead to discovery of a cost beneficial SAMA that would substantially reduce risk of severe 

6 accidents and, therefore, does not constitute new and significant information with respect to the 

7 generic conclusion codified by the NRC that applicants need not reassess SAMAs for facilities 

8 such as LGS for license renewal.

9 Changed Criterion for Assigning Cost per Person-Rem Averted

10 The 1989 SAMDA Analysis calculated the benefit of each proposed SAMDA based on a 

11 criterion of $1,000 per person-rem averted. Using a value of $2,000 per person-rem averted 

12 would increase the threshold and potentially result in new cost beneficial SAMDAs. As 

13 described in 1989 SAMDA Analysis, changing the cost/benefit threshold using the $2,000 per 

14 person-rem averted conversion would still not result in this or any other of the SAMDAs 

15 becoming cost beneficial. Therefore, Exelon concludes that changing the criterion for assigning 

16 benefit (i.e., cost per person-rem averted) from $1,000 per person-rem averted to $2,000 per 

17 person-rem averted would not change the conclusions in the 1989 SAMDA Analysis. Hence, 

18 the new information represented by the changed criterion for assigning cost per person-rem 

19 averted was judged not to be significant by Exelon. 

20 The staff reviewed the LGS analysis provided in the License Renewal ER and agrees that 

21 changing the criterion for assigning cost per person-rem averted would not result in a cost 

22 beneficial SAMA. As provided above, the ATWS Vent has the lowest cost/benefit ratio for the 

23 set, and it represents the SAMDA with the largest benefit potential. Even for this limiting 

24 SAMDA, changing the cost/benefit threshold to $2,000 per person-rem averted would still not 

25 result in this or any other of the SAMDAs becoming cost beneficial. Since this was applied to 

26 the SAMDA (ATWS Vent) closest to being cost effective, none of the SAMDAs are cost 

27 effective. Additional conservatisms not mentioned by the applicant include that converting the 

28 $3,000,000 cost of the ATWS Vent SAMA to 2012 dollars would increase the cost of the 

29 SAMDA to over $5,000,000 (assuming similar engineering and construction practices). 

30 Considering all of the large conservatisms in the analysis, the applicant’s analysis is reasonable. 

31 Moreover, even if the increase in cost per person-rem averted led to another SAMA becoming 

32 cost beneficial, that SAMA would still not likely result in a substantial reduction in offsite risk, 

33 given the substantial reduction in CDF at Limerick since the 1989 SAMDA analysis. Therefore, 

34 consideration of offsite costs would not likely lead to discovery of a cost-beneficial SAMA, let 

35 alone one that would substantially reduce offsite risk and therefore does not constitute new and 

36 significant information with respect to the generic conclusion codified by the NRC that Exelon

37 need not reassess LGS SAMAs for license renewal.

38 Changed Seismic Hazard Proposed in GI-199

39 The staff is investigating the implication of Updated Probabilistic Seismic Hazard Estimates in 

40 Central and Eastern United States in GI-199.

41 The applicant indicated that GI-199 issues related to the seismic hazard will not result in 

42 postulated accident scenarios not already considered for LGS. Seismologists are frequently 

43 refining seismic methodologies and results, which may increase the estimated frequency of 

44 seismic events with very low probability. Results from the LGS June 1989 PRA Update indicate 

45 that the contribution from seismic risk to the total CDF is approximately 25 percent, with fire risk 

46 contributing 31 percent to the total risk (Exelon 2011c). Therefore, based on the June 1989 

47 Update, the major risk contributors for external hazards are approximately equal to the CDF 

48 computed for internal events only. Based on the ER, total CDF for internal and external events 
Environmental Impacts of Postulated Accidents

5-11

1 can generally be approximated by multiplying the CDF for internal events by a factor of 2. With 

2 a multiplication factor of 2 applied to the CDF estimated by the current model of record 

(CDF=3.2 x10-6 3 ), the revised CDF that accounts for both internal and external hazards 

(CDF=6.4 x10-6 4 ) would still be a factor of 6.5 below the value used in the 1989 SAMDA Analysis 

(CDF=4.2 x10-5 5 ). This demonstrates the excess margin in the 1989 SAMDA Analysis. A 

6 possible increase in risk beyond this assumption due to an even larger seismic CDF would be 

7 more than offset by the factor of 6.5 reduction in the current CDF. Therefore, Exelon concludes 

8 that the new information represented by the changed seismic hazard proposed in GI-199 is not 

9 significant because it would not materially alter the SAMDA conclusions in the 1989 SAMDA 

10 (Exelon 2011c).

11 The staff reviewed the method the applicant used in determining the external events multiplier 

12 and its use and determined that it was consistent with the guidance provided in NEI 05-01. The 

13 staff also confirmed that the risk has decreased since the 1989 SAMDA and agrees with 

14 Exelon’s analysis that the new information represented by the changed seismic hazard 

15 proposed in GI-199 is not significant because it would not materially alter the SAMDA 

16 conclusions in the 1989 SAMDA Analysis. Considering the large conservatism in the 

17 1989 SAMDA Analysis, the applicant’s approach is reasonable. Moreover, even if the change in 

18 seismic hazard led to another SAMA becoming cost beneficial, that SAMA would still not likely 

19 result in a substantial reduction in offsite risk, given the substantial reduction in CDF at Limerick 

20 since the 1989 SAMDA analysis. Therefore, consideration of GI-199 is not likely to lead to the 

21 discovery of a cost-beneficial SAMA that would substantially reduce offsite risk and, therefore, 

22 does not constitute new and significant information with respect to the generic conclusion 

23 codified by the NRC that SAMAs need not be reassessed at LGS for license renewal.

24 Additional staff evaluation for new and significant information

25 The staff reviewed records of public meetings and correspondence related to the application 

26 and compared information presented by the public with information considered in NUREG-1437 

27 to determine if there was any new and significant information with respect to the generic 

28 conclusion codified by the NRC, which indicates that SAMAs need not be reassessed at LGS 

29 for license renewal (10 CFR 51.53(c)(3)(ii)(L)). 

30 Cost-effective SAMAs Identified at Other Plants

31 From the scoping comments (NRDC 2011), there was a recommendation that potential 

32 cost-effective SAMAs identified at other similar plants be addressed at LGS. Many of the SAMA 

33 recommendations identified from other plants are compiled in an NRC published paper 

34 (NRC 2009). The paper concludes that, “SAMAs that are found to be potentially cost-beneficial 

35 tend to be low-cost improvements such as modifications to plant procedures or training, minimal 

36 hardware changes, and use of portable equipment.” These potential cost-beneficial SAMAs are 

37 further evaluated and many times not found cost beneficial because sufficient risk is not 

38 eliminated by the modification (which was assumed) or other factors. Furthermore, the staff 

39 found that SAMA analyses that have been performed to date have found SAMAs that were 

40 cost-beneficial, or at least possibly cost-beneficial subject to further analysis, in approximately 

41 half of the plants. In general, the cost-beneficial SAMAs were identified and considered by the 

42 licensee under the current operating license. In several cases, SAMA-related modifications 

43 were implemented at LGS, further reducing that probability of an additional SAMA substantially 

44 reducing severe accident risk. (PECO 1992)(Exelon 2011c)

45 As provided in the statement of considerations for 10 CFR 51.53(c)(3)(ii)(L), in forming its basis 

46 for determining which plants needed to submit a SAMA, the Commission noted that all licensees 

47 had undergone, or were in the process of undergoing, more detailed site-specific severe 

48 accident mitigation analyses through processes separate from license renewal, specifically the
Environmental Impacts of Postulated Accidents

5-12

1 CPI, IPE, and IPEEE programs (61 FR 28467). These programs for LGS were discussed 

2 earlier. In light of these studies, the Commission stated that it did not expect future SAMA 

3 analyses in the license renewal stage to uncover “major plant design changes or modifications 

4 that will prove to be cost-beneficial” (61 FR 28467). As discussed above, the NRC’s experience 

5 in completed license renewal proceedings has confirmed this assumption (NRC 2009). As a 

6 result, potentially cost-beneficial SAMAs at other facilities do not constitute new and significant 

7 information with respect to the NRC’s determination not to perform a second SAMA analysis at 

8 license renewal in the event the agency has previously considered the issue because even if 

9 cost beneficial the NRC staff’s experience show that they will not likely yield a major reduction of 

10 risk, particularly in light of the many improvements already implemented at Limerick. 

11 Current State of the Art Knowledge for Performing SAMA Analysis

12 A current detailed SAMA analysis has the ability to analyze numerous plant-specific variables 

13 and the sensitivity of a SAMA analysis to these variables. In the scoping comments, numerous 

14 variables were identified that might cast doubt on the results of the initial 1989 SAMDA Analysis. 

15 To thoroughly evaluate all of these variables would require a de novo SAMA analysis, which is 

16 not required by 51.53(c)(3)(ii)(L) and Table B-1. However, the applicant evaluated some of the 

17 changes at LGS that could have a significant impact on the SAMA evaluation such as 

18 population increase, consideration of offsite economic cost risk, changed criteria for assigning 

19 cost per person-rem averted, and changed seismic hazard proposed by GI-199 and concluded 

20 that the changes or new information did not have a significant effect on the analysis. As 

21 provided earlier, the staff independently confirmed this information to be reasonable and 

22 moreover determine that they would not lead to identification of a SAMA that would substantially 

23 reduce offsite risks but acknowledges that a more precise answer could be found with a detailed 

24 SAMA analysis. However, the staff believes that this more precise answer would still not 

25 identify significant cost beneficial SAMAs. As explained above, new and significant information 

26 must provide a seriously different picture of the consequences of the Federal action under 

27 consideration. With respect to SAMAs, new information may be significant if it indicated a given 

28 SAMA would substantially reduce the probability or consequences of a severe accident. None 

29 of the information identified by the applicant or the staff indicates that any SAMAs would be 

30 likely to result in such a reduction of risk. Instead, as discussed above, new information 

31 indicates that further SAMA analyses are unlikely to identify such major, cost-beneficial plant 

32 improvements particularly in light of the substantial reduction in the CDF for Limerick since the 

33 1989 SAMDA analysis. Nonetheless, the staff discusses another significant variable in 

34 contemporary SAMA analyses, fuel enrichment, further below. 

35 Enrichment of Fuel (Power Uprates)

36 Another potentially new and significant item that could impact the 1989 SAMA analysis is 

37 increases in the enrichment of the fuel in the core. The following is the staff’s review for any 

38 significant changes to the fuel enrichment design basis at LGS by reviewing LGS docketed 

39 information regarding power uprates. Extended power uprates require using fuel with a higher 

40 percentage of uranium-235 or additional fresh fuel to derive more energy from the operation of 

41 the reactor. This results in a larger radionuclide inventory (particularly short-lived isotopes, 

42 assuming no change in burnup limits) in the core, than the same core at a lower power level. 

43 The larger radionuclide inventory represents a larger source term for accidents and can result in 

44 higher doses to offsite populations in the event of a severe accident. Typically, short-lived 

45 isotopes are the main contributor to early fatalities. As stated in NUREG-1449 (NRC 1993), 

46 short-lived isotopes make up 80 percent of the dose following early release. The staff found 

47 that LGS had received two power uprate approvals since 1989. One uprate occurred in 1995. 

48 In 1993, an amendment request was submitted to the NRC that would increase the licensed 

49 thermal power level of the reactor from 3,293 megawatts thermal (MWt) to 3,458 MWt, primarily 
Environmental Impacts of Postulated Accidents

5-13

1 by increasing the licensed core flow. In the staff’s Environmental Assessment and Finding of 

2 No Significant Impact related to the LGS application for the amendment, the staff found, “the 

3 radiological and nonradiological environmental impacts associated with the proposed small 

4 increase in power are very small and do not change the conclusion in the FES that the 

5 operation of LGS, Units 1 and 2, would cause no significant adverse impact upon the quality of 

6 the human environment.” Furthermore, in the January 23, 1995 submittal relating to increasing 

7 core flow, the licensee indicated that while fuel burnup and enrichment levels may increase as a 

8 result of operation at uprated power, the burnup and enrichment will remain within the 5 percent 

9 enrichment and 60,000 MWd/MT value previously evaluated by the staff. Thus, the fuel 

10 enrichment did not exceed the previously licensed value (NRC 1995). 

11 By application dated March 25, 2010 (Exelon 2010), Exelon submitted a license amendment 

12 request for the LGS Units 1 and 2 Facility Operating Licenses and Technical Specifications. 

13 The proposed amendment consisted of a 1.65 percent measurement uncertainty recapture 

14 (MUR) power uprate that will increase each unit’s rated thermal power from 3,458 megawatts 

15 (MWt) to 3,515 MWt. The proposed amendment was characterized as a MUR power uprate, 

which uses a Cameron International (formerly Caldon) CheckPlusTM 16 Leading Edge Flow Meter

17 (LEFM) system to improve plant calorimetric heat balance measurement accuracy. This 

18 flowmeter provides a more accurate measurement of feedwater (FW) flow and thus reduces the 

19 uncertainty in the FW flow measurement. This submittal did not change the fuel enrichment 

20 design basis.

21 Neither of these power uprates increased the fuel enrichment any higher than was previously 

22 evaluated by the staff before the 1989 SAMDA Analysis was completed. Since the fuel 

23 enrichment was not increased, further SAMA analyses for LGS would be unlikely to uncover 

24 cost-beneficial major plant improvements or plant improvements that could substantially result in 

25 lower doses to offsite populations in the event of a severe accident. Also, it reinforces the 

26 Commission’s generic determination that the NRC need not reanalyze SAMAs at LGS for 

27 license renewal.

28 Conclusion

29 In conclusion, 10 CFR 51.53(c)(3)(ii)(L) states that, “[i]f the staff has not previously considered 

30 SAMAs for the applicant’s plant, in an environmental impact statement or related supplement or 

31 in an environmental assessment, a consideration of alternatives to mitigate severe accidents 

32 must be provided.” Table B-1 in 10 CFR Part 51, which governs the scope of the staff’s 

33 environmental review for license renewal, echoes this regulation. Applicants for plants that 

34 have already had a SAMA analysis considered by the NRC as part of an EIS, supplement to an 

35 EIS, or EA, do not need to have a SAMA analysis reconsidered for license renewal. In forming 

36 its basis for determining which plants needed to submit a SAMA at license renewal, the 

37 Commission noted that all licensees had undergone, or were in the process of undergoing, 

38 more detailed site-specific severe accident mitigation analyses through processes separate 

39 from license renewal, specifically the CPI, IPE, and IPEEE programs (61 FR 28467). In light of 

40 these studies, the Commission stated that it did not expect future SAMA analyses to uncover 

41 “major plant design changes or modifications that will prove to be cost-beneficial” 

42 (61 FR 28467). The NRC’s experience in completed license renewal proceedings has 

43 confirmed this assumption. 

44 LGS is a plant that had a previous SAMA documented in a NEPA document. Therefore, Exelon 

45 was not required to, and did not, submit a SAMA in its license renewal ER. Exelon did evaluate 

46 whether there was new and significant information with respect to the Commission’s prior 

47 determination not to require a SAMA analysis at license renewal for those plants that were 

48 already the subject of a SAMA analysis by the staff.
Environmental Impacts of Postulated Accidents

5-14

1 The staff analyzed information in the applicant’s ER with respect to the 1989 SAMDA Analysis 

2 for LGS, public comments, and its own review of information relevant to LGS to search for new 

3 and significant information with respect to the NRC’s determination not to conduct a second 

4 SAMA analysis at LGS for license renewal and the studies and assumptions underlying that 

5 determination. In conducting that search, the staff considered whether new information 

6 provided a seriously different view of the consequences of renewing the LGS operating license 

7 than previously contemplated. For a mitigation analysis, such as a SAMA analysis, such 

8 information would need to demonstrate a substantial change in the environmental impact sought 

9 to be mitigated, in this case severe accidents. Given the discussion above, it is unlikely that 

10 further SAMA analyses for LGS could uncover cost beneficial SAMAs that would substantially 

11 reduce the risk of severe accidents because the reduction in severe accident risk at Limerick

12 from the use of new information outweighs any increases resulting from new considerations. 

13 The staff also did not identify any new and significant information that rises to a level that 

14 requires staff to seek Commission approval to conduct a new SAMA analysis (similar to the 

15 waiver requirement that applies for Category 1 issues when staff identifies new and significant 

16 information). The impacts of all other new information do not contribute sufficiently to the 

17 environmental impacts to warrant their inclusion in a SAMA analysis, since the likelihood of 

18 finding cost-effective plant improvements that substantially reduce risk is small. Additionally, the 

19 staff did not identify a significant environmental issue not covered in the GEIS, or that was not 

20 considered in the analysis in the GEIS and leads to an impact finding that is different from the 

21 finding presented in the GEIS.

22 The staff identified no new and significant information related to postulated accidents during the 

23 review of LGS’s ER (Exelon 2011c) or evaluation of other available information. Therefore, 

24 there are no impacts related to these issues beyond those discussed in the GEIS. In

25 accordance with 10 CFR 51.53(c)(3)(ii)(L), the staff did not repeat the review of SAMAs for LGS. 

26 While another SAMA is not required, the applicant provided and the staff reviewed 

27 considerations of new and significant information.

28 5.4. References

29 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

30 production and utilization facilities.”

31 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

33 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

34 renewal of operating licenses for nuclear power plants.”

35 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor site 

36 criteria.”

37 61 FR 28467. U.S. Nuclear Regulatory Commission. Environmental review for renewal of 

38 nuclear power plant operating licenses. Federal Register 61(109):28467-28481. June 5, 1996.

39 74 FR 13926. U.S. Nuclear Regulatory Commission. Power reactor security requirements.

40 Federal Register 74(58): 13926-13993. March 27, 2009.

41 [Amergen] Amergen Energy Company, LLC. 2008. “Three Mile Island Nuclear Station, 

42 Applicant’s Environmental Report, License Renewal Operating Stage.” Kennett Square, PA: 

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

44 ML080220255, ML080220257, ML080220261, and ML080220282.
Environmental Impacts of Postulated Accidents

5-15

1 Energy Northwest. 2011. Letter from A. Javorik, Vice President, to NRC Document Control 

2 Desk. Subject: Columbia Generating Station, Docket No. 50-397, Response to request for 

3 additional information, license renewal application. November 17, 2011. ADAMS Accession 

4 No. ML11325A067.

5 [Exelon] Exelon Generation Company, LLC. 2010. Letter from M. Jesse, Manager, 

6 Licensing-Power Uprate, to NRC Document Control Desk. Limerick Generating Station, Units 1 

7 and 2: Request for license amendment regarding measurement uncertainty recapture power 

8 uprate. March 25, 2010. ADAMS Accession No. ML100850380. 

9 [Exelon] Exelon Generation Company, LLC. 2011a. Letter from M.P. Gallagher, Vice President, 

10 License Renewal Projects, to NRC Document Control Desk. Limerick Generating Station, Units 

11 1 and 2: Application for renewed operating licenses. June 22, 2011. ADAMS Accession No. 

12 ML11179A096. 

13 [Exelon] Exelon Generation Company, LLC. 2011b. License Renewal Application [LRA], 

14 Limerick Generating Station, Units 1 and 2. June 22, 2011. ADAMS Accession 

15 No. ML11179A101.

16 [Exelon] Exelon Generation Company, LLC. 2011c. Environmental Report–Operating License 

17 Renewal Stage, Limerick Generating Station, Units 1 and 2. June 22, 2011. ADAMS Accession 

18 No. ML11179A104.

19 Ghosh T, Palla R, Helton D. 2009. Perspectives on Severe Accident Mitigation Alternatives for 

20 U.S. Plant License Renewal. U.S. Nuclear Regulatory Commission. September 2009. ADAMS 

21 Accession No. ML092750488.

22 [NRC] U.S. Nuclear Regulatory Commission. 1988a. Generic Letter No. 88-20, “Individual Plant 

23 Examination for Severe Accident Vulnerabilities.” November 23, 1988. ADAMS Accession 

24 No. ML031150465.

25 [NRC] U.S. Nuclear Regulatory Commission. 1988b. Generic Letter No. 88-20, Supplement 

26 No. 4, “Individual Plant Examination of External Events (IPEEE) for Severe Accident 

27 Vulnerabilities –10 CFR 50.54(f).” June 28, 1991. ADAMS Accession No. ML031150485.

28 [NRC] U.S. Nuclear Regulatory Commission. 1988c. SECY-88-147, “Integration Plan for 

29 Closure of Severe Accident Issue.” May 25, 1988.

30 [NRC] U.S. Nuclear Regulatory Commission. 1989. Final Environmental Statement Related to 

31 Operation of LGS, Units 1 and 2. Washington, DC: NRC. NUREG-0974, Supplement 1. 

32 August 1989. ADAMS Accession No. ML112221A204.

33 [NRC] U.S. Nuclear Regulatory Commission. 1991. Procedural and Submittal Guidance for the 

34 Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities.

35 Washington, DC: NRC. NUREG-1407. June, 1991. ADAMS Accession No. ML063550238.

36 [NRC] U.S. Nuclear Regulatory Commission. 1993. Shutdown and Low-Power Operation at 

37 Commercial Nuclear Power Plants in the United States. Washington, DC: NRC. NUREG-1449. 

38 September 1993. ADAMS Accession No. ML063470582.

39 [NRC] U.S. Nuclear Regulatory Commission. 1995. Letter from F. Rinaldi, Project Director, 

40 Division of Reactor Projects, to G. Hunger, Director–Licensing, PECO Energy Company. 

41 Environmental assessment and finding of no significant impact, power uprate with increased 

42 core flow, Limerick Generating Station, Unit Nos. 1 and 2 (TAC Nos. M88392 and M88393). 

43 February 7, 1995. ADAMS Accession No. ML011560483.
Environmental Impacts of Postulated Accidents

5-16

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

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

3 ADAMS Accession Nos. ML040690705 and ML040690738.

4 [NRC] U.S. Nuclear Regulatory Commission. 1997. Status of the Integration Plan for Closure of 

5 Severe Accident Issues and the Status of Severe Accident Research. Washington, DC: NRC. 

6 SECY 97-132. June 1997. ADAMS Accession No. ML992930144

7 [NRC] U.S. Nuclear Regulatory Commission. 1999a. Standard Review Plans For Environmental 

8 Reviews for Nuclear Power Plants, Supplement 1. Washington, DC: NRC. NUREG-1555. 

9 October 1999. ADAMS Accession No. ML003702019.

10 [NRC] U.S. Nuclear Regulatory Commission. 1999b. Section 6.3 – Transportation, Table 9.1, 

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

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

13 NRC. NUREG–1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 

14 No. ML04069720.

15 [NRC] U.S. Nuclear Regulatory Commission. 2002. Perspectives Gained from the Individual 

16 Plant Examination of External Events (IPEEE) Program. Washington, DC: NRC. NUREG-1742. 

17 April 2002. ADAMS Accession No. ML021270070. 

18 [NRC] U.S. Nuclear Regulatory Commission. 2004. Protecting Our Nation–Since 9-11-01. 

19 Washington, DC: NRC. NUREG/BR-0314. September 2004.

20 [NRC] U.S. Nuclear Regulatory Commission. 2006a. Frequently Asked Questions on License 

21 Renewal of Nuclear Power Reactors. Washington, DC: NRC. NUREG-1850. March 2006. 

22 [NRC] U.S. Nuclear Regulatory Commission. 2006b. Mitigation of Spent Fuel Loss-of-Coolant 

23 Inventory Accidents and Extension of Reference Plant Analyses to Other Spent Fuel Pools.

24 Sandia Letter Report, Revision. November 2, 2006.

25 [NRC] U.S. Nuclear Regulatory Commission. 2011a. “Recommendations for Enhancing Reactor 

26 Safety in the 21st Century: The Near-Term Task Force Review of Insights from the Fukushima 

27 Dai-ichi Accident.” July 12, 2011. ADAMS Accession No. ML111861807 

28 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from P. Bamford, Project Manager, 

29 Division of Operating Reactor Licensing, to MJ Pacilio, President and Chief Nuclear Officer, 

30 Exelon Nuclear. Limerick Generating Station, Units 1 and 2 – Issuance of amendments re: 

31 measurement uncertainty recapture power uprate and standby liquid control system changes 

32 (Tac Nos. ME3589, ME3590, ME3591, and ME3592). April 8, 2011. ADAMS Accession No. 

33 ML110691095.

34 [NRC] U.S. Nuclear Regulatory Commission. 2011c. SECY-11-0093, “Near-Term Report and 

35 Recommendations for Agency Actions Following the Events in Japan.” ADAMS Accession 

36 No. ML 11186A950.

37 [NRC] U.S. Nuclear Regulatory Commission. 2011d. SECY-11-0124, “Recommended Actions to 

38 be taken Without Delay from the Near-Term Task Force Report.” ADAMS Accession 

39 No. ML112911571.[NRC] U.S. Nuclear Regulatory Commission. 2011e. SRM-SECY-11-0124, 

40 “Staff Requirements-SECY-11-0124: Recommended Actions to Be Taken Without Delay from 

41 the Near-Term Task Force Report.” October 18, 2011.

42 [NRC] U.S. Nuclear Regulatory Commission. 2011f. SECY-11-0137, “Prioritization of 

43 Recommended Actions to be Taken in Response to Fukushima Lessons Learned.” 

44 October 3, 2011. ADAMS Accession No. ML11272A111. 
Environmental Impacts of Postulated Accidents

5-17

1 [NRC] U.S. Nuclear Regulatory Commission. 2011g. Staff Requirements– Secy-11-0137 – 

2 “Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons 

3 Learned.” December 15, 2011.

4 [NRC] U.S. Nuclear Regulatory Commission. 2012a. Order EA-12-049, Issuance of Order to 

5 Modify Licenses With Regard to Requirements for Mitigation Strategies for 

6 Beyond-Design-Basis External Events. March 12, 2012. ADAMS Accession No. ML012054A735

7 [NRC] U.S. Nuclear Regulatory Commission. 2012b. Order EA-12-050, “Issuance of Order to 

8 Modify Licenses with Regard to Reliable Hardened Containment Vents.” March 12, 2012. 

9 ADAMS Accession No. ML012054A694.

10 [NRC] U.S. Nuclear Regulatory Commission. 2012c. Order EA-12-051, “Subject: Issuance of 

11 Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.” 

12 March 12, 2012. ADAMS Accession No.ML012054A679.

13 [NRC] U.S. Nuclear Regulatory Commission. 2012d. “Request For Information Pursuant to 

14 Title 10 of The Code of Federal Regulations 50.54(F) Regarding Recommendations 2.1,2.3, and 

15 9.3, of The Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident.” 

16 March 12, 2012. ADAMS Accession No. ML012053A340.

17 [NRC] U.S. Nuclear Regulatory Commission. 2012e. Generic Environmental Impact Statement 

18 for License Renewal of Nuclear Plants Regarding Columbia Generating Station (NUREG-1437, 

19 Supplement 47) Final Report for Comment. Washington, DC: NRC. NUREG-1437. April 2012. 

20 ADAMS Accession No. ML11227A007. 

21 [NRDC] Natural Resources Defense Council. 2011. Letter from NRDC to C. Bladey. Natural 

22 Resources Defense Council comments on Limerick EIS scoping process.” October 28, 2011. 

23 ADAMS Accession No. ML11307A456

24 [PECO] Philadelphia Electric Company. 1992. Limerick Generating Station, Units 1 and 2: 

25 Individual plant examination volume 1. July 1992. ADAMS Accession No. ML080030106 and 

26 ML080030104. 

27 [PECO] Philadelphia Electric Company. 1995. Limerick Generating Station, Units 1 and 2 

28 response to NRC Generic Letter 88-20, supplement 4, “Individual Plant Examination of External 

29 Events (IPEEE) for Severe Accident Vulnerabilities.” June 1995. ADAMS Accession 

30 No. ML073610238.

31 [PECO] Philadelphia Electric Company. 1996. Letter from G.A. Hungar, Jr., Director–Licensing, 

32 to NRC Document Control Desk. Limerick Generating Station, Units 1 and 2: Response to 

33 request for additional information regarding review of individual plant examination of external 

34 events. June 28, 1996. ADAMS Accession No. ML073610237. 

6-1 

1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

2 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS

3 This chapter addresses issues related to the uranium fuel cycle, solid waste management, and 

4 greenhouse gas emissions during the proposed 20-year period of extended operation.

5 6.1. The Uranium Fuel Cycle

6 The uranium cycle includes uranium mining and milling, the production of uranium hexafluoride, 

7 isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation of radioactive 

8 materials, and management of low-level wastes and high-level wastes related to uranium fuel 

9 cycle activities. The generic potential impacts of the radiological and nonradiological 

10 environmental impacts of the uranium fuel cycle and transportation of nuclear fuel and wastes 

11 are described in detail in NUREG–1437, Generic Environmental Impact Statement (GEIS) for 

12 License Renewal of Nuclear Plants (NRC 1996, 1999) based, in part, on the generic impacts 

13 given in Table S–3, “Table of Uranium Fuel Cycle Environmental Data,” located in Title 10 of the 

14 Code of Federal Regulations 51.51 (10 CFR 51.51) and in 10 CFR 51.52(c), Table S-4, 

15 “Environmental Impact of Transportation of Fuel and Waste to and from One 

16 Light-Water-Cooled Nuclear Power Reactor.”

17 In the GEIS, the U.S. Nuclear Regulatory Commission staff (the staff) identified nine 

18 Category 1 issues related to the fuel cycle and waste management, which appear in Table 6–1. 

19 There are no Category 2 issues related to the fuel cycle and waste management.

20 Table 6–1. Issues Related to the Uranium Fuel Cycle and Waste Management

Issues GEIS Sections Category

Offsite radiological impacts (individual 

effects from other than the disposal of spent 

fuel and high-level waste) 

6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 1 

Offsite radiological impacts (collective 

effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 

Offsite radiological impacts (spent fuel 

and high-level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 

Nonradiological impacts of the uranium fuel 

cycle

6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 

6.2.4; 6.6 1 

Low-level waste storage and disposal

6.1; 6.2.2.2;6.4.2; 6.4.3; 6.4.3.1; 6.4.3.2; 

6.4.3.3; 6.4.4; 6.4.4.1; 6.4.4.2; 6.4.4.3; 

6.4.4.4; 6.4.4.5; 6.4.4.5.1; 6.4.4.5.2; 

6.4.4.5.3; 6.4.4.5.4; 6.4.4.6;6.6

1 

Mixed waste storage and disposal

6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 6.4.5.5; 

6.4.5.6; 6.4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 

6.4.5.6.4; 6.6

1 

Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; 

6.4.6.5; 6.4.6.6; 6.4.6.7; 6.6 1 

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, 

Addendum 1 1 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-2 

1 The NRC staff’s evaluation of the environmental impacts associated with spent nuclear fuel is 

2 addressed in two issues in Table 6-1, “Offsite radiological impacts (spent fuel and high-level 

3 waste disposal)” and “Onsite spent fuel.” However, as explained later in this section, the scope 

4 of the evaluation of these two issues in this SEIS has been revised. The issue, “Offsite 

5 radiological impacts (spent fuel and high-level waste disposal),” is not evaluated in this SEIS. In 

6 addition, the issue, “Onsite spent fuel” only evaluates the environmental impacts during the 

7 license renewal term.

8 For the term of license renewal, the staff did not find any new and significant information related 

9 to the remaining uranium fuel cycle and solid waste management issues listed in Table 6–1 

10 during its review of the Limerick Generating Station environmental report (ER) (Exelon 2011), 

11 the site visit, and the scoping process. Therefore, there are no impacts related to these issues 

12 beyond those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the 

13 impacts are SMALL, except for the issue, “Offsite radiological impacts (collective effects),” which 

14 the NRC concluded are acceptable.

15 However, the offsite radiological impacts resulting from spent fuel and high-level waste disposal 

16 and the onsite storage of spent fuel, which will occur after the reactors have been permanently 

17 shutdown, are addressed in the Commission’s Waste Confidence Decision Rule (WCD), 

18 10 CFR 51.23. In 2010, the Commission revised the WCD (i.e., WCD Update) to reflect 

19 information gained based on experience in the storage of spent nuclear fuel and the increased 

20 uncertainty in the siting and construction of a permanent geologic repository for the disposal of 

21 spent nuclear fuel.

22 On June 8, 2012, in response to a legal challenge to the WCD, the U.S. Court of Appeals for the 

23 District of Columbia Circuit (New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012)) vacated the 

24 NRC’s WCD Update (75 Federal Register (FR) 81032, 75 FR 81037). The court decision was 

25 based on grounds relating to aspects of the National Environmental Policy Act (NEPA). The 

26 court decision held that the WCD Update is a major Federal action necessitating either an 

27 environmental impact statement (EIS) or a finding of no significant environmental impact 

28 (FONSI), and the Commission’s evaluation of the risks associated with the storage of spent 

29 nuclear fuel for at least 60 years beyond the licensed life for reactor operation is deficient.

30 In response to the court’s ruling, the Commission, in CLI-12-16 (NRC 2012a), determined that it 

31 would not issue licenses dependent upon the WCD, until the issues identified in the court’s 

32 decision are appropriately addressed. In CLI-12-16, the Commission also noted that this 

33 determination extends only to final license issuance; all current licensing reviews and 

34 proceedings should continue to move forward. 

35 In addition, the Commission directed in SRM-COMSECY-12-0016 (NRC 2012b) that the NRC 

36 staff proceed with a rulemaking that includes the development of an EIS to support an updated 

37 WCD within 24 months (by September 2014). The Commission indicated that the EIS used to 

38 support the revised rule should build on the information already documented in various NRC 

39 studies and reports on the impacts associated with the storage of spent nuclear fuel that were 

40 developed as part of the 2010 WCD Update, and should primarily focus additional analyses on 

41 the deficiencies identified in the D.C. Circuit’s decision. The NRC considers the WCD to be a 

42 generic issue that is best addressed through rulemaking, and that the NRC rulemaking process 

43 provides an appropriate forum for public review and comment on both the draft EIS and the 

44 proposed WCD.

45 The updated rule and supporting EIS will provide the necessary NEPA analyses of waste 

46 confidence-related human health and environmental issues. As directed by the Commission, 

47 the NRC will not issue a renewed license before the resolution of waste confidence-related 

48 issues. This will ensure that there would be no irretrievable or irreversible resource 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-3 

1 commitments or potential harm to the environment before waste confidence impacts have been 

2 addressed. 

3 If the results of the WCD EIS identify information that requires a supplement to this EIS, the 

4 NRC staff will perform any appropriate additional NEPA review for those issues before the NRC 

5 makes a final licensing decision. 

6 6.2. Greenhouse Gas Emissions

7 This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the 

8 nuclear fuel cycle. The GEIS does not directly address these emissions, and its discussion is 

9 limited to an inference that substantial carbon dioxide (CO2) emissions may occur if coal- or 

10 oil-fired alternatives to license renewal are carried out.

11 6.2.1. Existing Studies

12 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 

13 electricity generating methods have been widely studied. However, estimates and projections 

14 of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done. 

15 Additionally, considerable debate also exists among researchers on the relative effects of 

16 nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG 

17 emissions from nuclear power plants generally take two different forms:

18 (1) qualitative discussions of the potential to use nuclear power to reduce GHG 

19 emissions and mitigate global warming, and

20 (2) technical analyses and quantitative estimates of the actual amount of GHGs 

21 generated by the nuclear fuel cycle or entire nuclear power plant life cycle 

22 and comparisons to the operational or life cycle emissions from other energy 

23 generation alternatives. 

24 6.2.1.1. Qualitative Studies

25 The qualitative studies consist primarily of broad, large-scale public policy, or investment 

26 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 

27 or politically workable means of achieving global GHG reductions. Studies the staff found 

28 during the subsequent literature search include the following:

29  Evaluations to determine if investments in nuclear power in developing 

30 countries should be accepted as a flexibility mechanism to assist 

31 industrialized nations in achieving their GHG reduction goals under the Kyoto 

32 Protocols (IAEA 2000, NEA 2002, Schneider 2000). Ultimately, the parties to 

33 the Kyoto Protocol did not approve nuclear power as a component under the 

34 clean development mechanism (CDM) because of safety and waste disposal 

35 concerns (NEA 2002).

36  Analyses developed to assist governments, including the United States, in 

37 making long-term investment and public policy decisions in nuclear power 

38 (Hagen et al. 2001, Keepin 1988, MIT 2003).

39 Although the qualitative studies sometimes reference and critique the existing quantitative 

40 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 

41 rely heavily on discussions of other aspects of nuclear policy decisions and investment, such as 

42 safety, cost, waste generation, and political acceptability. Therefore, these studies typically are 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-4 

1 not directly applicable to an evaluation of GHG emissions associated with the proposed license 

2 renewal for a given nuclear power plant.

3 6.2.1.2. Quantitative Studies

4 A large number of technical studies, including calculations and estimates of the amount of 

5 GHGs emitted by nuclear and other power generation options, are available in the literature and 

6 were useful in the staff’s efforts to address relative GHG emission levels. Examples of these 

7 studies include—but are not limited to—Mortimer (1990), Andseta et al. (1998), Spadaro (2000), 

8 Storm van Leeuwen and Smith (2008), Fritsche (2006), Parliamentary Office of Science and 

9 Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), Fthenakis 

10 and Kim (2007), and Dones (2007). In addition, Sovacool (2008) provides a review and 

11 synthesis of studies in existence through 2008; however, the Sovacool synthesis ultimately uses 

12 only 19 of the 103 studies initially considered (the remaining 84 were excluded because they 

13 were more than 10 years old, not publicly available, available only in a language other than 

14 English, or they presented methodological challenges by relying on inaccessible data, providing 

15 overall GHG estimates without allocating relative GHG impacts to different parts of the nuclear 

16 lifecycle, or they were otherwise not methodologically explicit).

17 Comparing these studies and others like them is difficult because the assumptions and 

18 components of the lifecycles that the authors evaluate vary widely. Examples of areas in which 

19 differing assumptions make comparing the studies difficult include the following:

20  energy sources that may be used to mine uranium deposits in the future,

21  reprocessing or disposal of spent nuclear fuel,

22  current and potential future processes to enrich uranium and the energy 

23 sources that will power them,

24  estimated grades and quantities of recoverable uranium resources,

25  estimated grades and quantities of recoverable fossil fuel resources,

26  estimated GHG emissions other than CO2, including the conversion to CO2

27 equivalents per unit of electric energy produced,

28  performance of future fossil fuel power systems,

29  projected capacity factors for alternatives means of generation, and

30  current and potential future reactor technologies.

31 In addition, studies may vary with respect to whether all or parts of a power plant’s lifecycle are 

32 analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, 

33 resource extraction—for fuel and construction materials, and decommissioning), whereas a 

34 partial lifecycle analysis primarily focuses on operational differences. In addition, as 

35 Sovacool (2008) noted, studies vary greatly in terms of age, data availability, and 

36 methodological transparency.

37 In the case of license renewal, a GHG analysis for the portion of the plant’s lifecycle attributable 

38 to license renewal (operation for an additional 20 years) would not involve GHG emissions 

39 associated with construction because construction activities already have been completed at the 

40 time of relicensing. In addition, the proposed action of license renewal also would not involve 

41 additional GHG emissions associated with facility decommissioning because that 

42 decommissioning must occur whether the facility is relicensed or not. However, in many 

43 studies, the specific contribution of GHG emissions from construction, decommissioning, or 

44 other portions of a plant’s lifecycle cannot be clearly separated from one another. In such 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-5 

1 cases, an analysis of GHG emissions would overestimate the GHG emissions attributed to a 

2 specific portion of a plant’s lifecycle. As Sovacool (2008) noted, many of the available analyses 

3 provide markedly lower GHG emissions per unit of plant output when one assumes that a power 

4 plant operates for a longer period of time. Nonetheless, available studies supply some 

5 meaningful information on the relative magnitude of the emissions among nuclear power plants 

6 and other forms of electric generation, as discussed in the following sections.

7 In Tables 6–2, 6–3, and 6–4, the staff presents the results of the above-mentioned quantitative 

8 studies to supply a weight-of-evidence evaluation of the relative GHG emissions that may result 

9 from the proposed license renewal compared to the potential alternative use of coal-fired, 

10 natural gas-fired, and renewable generation. Most studies from Mortimer (1990) onward 

11 (through Sovacool 2008) indicate that uranium ore grades and uranium enrichment processes 

12 are leading determinants in the ultimate GHG emissions attributable to nuclear power 

13 generation. These studies show that the relatively lower order of magnitude of GHG emissions 

14 from nuclear power, when compared to fossil-fueled alternatives (especially natural gas), could 

15 potentially disappear if available uranium ore grades drop sufficiently while enrichment 

16 processes continued to rely on the same technologies.

17 Sovacool’s synthesis of 19 existing studies found that nuclear power generation causes carbon 

18 emissions in a range of 1.4 grams of carbon equivalent per kilowatt-hour (g Ceq/kWh) to 

19 288 g Ceq/kWh, with a mean value of 66 g Ceq/kWh. The results of his synthesis and the results 

20 of others’ efforts are included in the tables in this section.

21 6.2.1.3. Summary of Nuclear Greenhouse Gas Emissions Compared to Coal

22 Considering that coal fuels the largest share of electricity generation in the United States and 

23 that its burning results in the largest emissions of GHGs for any of the likely alternatives to 

24 nuclear power generation, including CGS, many of the available quantitative studies focused on 

25 comparing the relative GHG emissions of nuclear to coal-fired generation. The quantitative 

26 estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the 

27 nuclear lifecycle), as compared to an equivalent coal-fired plant, are presented in Table 6–2. 

28 The following table does not include all existing studies, but it gives an illustrative range of 

29 estimates that various sources have developed.
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-6 

1 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% of the GHG emissions compared to coal.

Note: Future reprocessing and use of nuclear-generated electrical power 

in the mining and enrichment steps are likely to change the projections of 

earlier authors, such as Mortimer (1990).

Spadaro (2000) Nuclear—2.5–5.7 g Ceq/kWh

Coal—264–357 g Ceq/kWh

Storm van Leeuwen and Smith 

(2008) 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—>1,000 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% 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%.

Weisser (2006) (compilation of 

results from other studies)

Nuclear—2.8–24 g Ceq/kWh

Coal—950–1,250 g Ceq/kWh

Fthenakis and Kim (2007) Authors did not evaluate nuclear versus coal.

Dones (2007) Author did not evaluate nuclear versus coal.

Sovacool (2008)

Nuclear—66 g Ceq/kWh

Coal —960 to 1,050 g Ceq/kWh

(coal adopted from Gagnon et al. 2002)

2 6.2.1.4. Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas

3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 

4 some cases, the nuclear lifecycle), as compared to an equivalent natural gas-fired plant, are 

5 presented in Table 6–3. The following table does not include all existing studies, but it gives an 

6 illustrative range of estimates various sources have developed.
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-7 

1 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—2.5–5.7 g Ceq/kWh

Natural gas—120–188 g Ceq/kWh

Storm van Leeuwen and Smith 

(2008)

Nuclear fuel cycle produces 20–33% of the GHG emissions compared to 

natural gas (at high ore grades).

Note: Future nuclear GHG emissions will increase because of declining 

ore grade.

Fritsche (2006) (values 

estimated from graph in 

Figure 4)

Nuclear—33 g Ceq/kWh

Cogeneration combined cycle natural gas—150 g Ceq/kWh

POST (2006) (nuclear 

calculations from AEA, 2006)

Nuclear—5 g Ceq/kWh

Natural gas—500 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and 

storage could reduce natural gas GHG emissions by 90%.

Weisser (2006) (compilation of 

results from other studies)

Nuclear—2.8–24 g Ceq/kWh

Natural gas—440–780 g Ceq/kWh

Fthenakis 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 15-27% 

of the GHG emissions of natural gas.

Sovacool (2008)

Nuclear—66 g Ceq/kWh 

Natural gas—443 g Ceq/kWh 

(natural gas adopted from Gagnon et al. 2002)

2 6.2.1.5. Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

3 Sources

4 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 

5 some cases, the nuclear lifecycle), as compared to equivalent renewable energy sources, are 

6 presented in Table 6–4. Calculation of GHG emissions associated with these sources is more 

7 difficult than the calculations for nuclear energy and fossil fuels because of the large variation in 

8 efficiencies and capacity factors because of their different technologies, sources, and locations. 

9 For example, the efficiency of solar and wind energy is highly dependent on the wind or solar 

10 resource in a particular location. Similarly, the range of GHG emissions estimates for 

11 hydropower varies greatly depending on the type of dam or reservoir involved (if used at all). 

12 Therefore, the GHG emissions estimates for these energy sources have a greater range of 

13 variability than the estimates for nuclear and fossil fuel sources. As noted in Section 6.2.1.2, the 

14 following table does not include all existing studies, but it gives an illustrative range of estimates 

15 various sources have developed.
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-8 

1 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 are expected to increase 

because of declining ore grade.

Andseta et al. (1998) Author did not evaluate nuclear versus renewable energy sources.

Spadaro (2000)

Nuclear—2.5–5.7 g Ceq/kWh

Solar PV—27.3–76.4 g Ceq/kWh

Hydroelectric—1.1–64.6 g Ceq/kWh

Biomass—8.4–16.6 g Ceq/kWh

Wind—2.5–13.1 g Ceq/kWh

Storm van Leeuwen and Smith 

(2008) Author did not evaluate nuclear versus renewable energy sources.

Fritsche (2006) (values 

estimated from graph in 

Figure 4)

Nuclear—33 g Ceq/kWh

Solar PV—125 g Ceq/kWh

Hydroelectric—50 g Ceq/kWh

Wind—20 g Ceq/kWh

POST (2006) (nuclear 

calculations from AEA, 2006)

Nuclear—5 g Ceq/kWh

Biomass—25–93 g Ceq/kWh

Solar PV—35–58 g Ceq/kWh

Wave/Tidal—25–50 g Ceq/kWh

Hydroelectric—5–30 g Ceq/kWh

Wind—4.64–5.25 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 

6.8 g Ceq/kWh. 

Weisser (2006) (compilation of 

results from other studies)

Nuclear—2.8–24 g Ceq/kWh

Solar PV—43–73 g Ceq/kWh

Hydroelectric—1–34 g Ceq/kWh

Biomass—35–99 g Ceq/kWh

Wind—8–30 g Ceq/kWh

Fthenakis and Kim (2007) Nuclear—16–55 g Ceq/kWh

Solar PV—17–49 g Ceq/kWh

Dones (2007) Author did not evaluate nuclear versus renewable energy sources.

Sovacool (2008) (adopted from 

other studies)

Nuclear—66 g Ceq/kWh 

Wind—9–10 g Ceq/kWh 

Hydroelectric (small, distributed)—10–13 g Ceq/kWh

Biogas digester—11 g Ceq/kWh

Solar thermal—13 g Ceq/kWh

Biomass—14–35 g Ceq/kWh

Solar PV—32 g Ceq/kWh

Geothermal (hot, dry rock)—38 g Ceq/kWh

(solar PV value adopted from Fthenakis et al. 2008; all other 

renewable generation values adopted from Pehnt 2006)
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-9 

1 6.2.2. Conclusions: Relative Greenhouse Gas Emissions

2 The sampling of data presented in Tables 6–2, 6–3, and 6–4 demonstrates the challenges of 

3 any attempt to determine the specific amount of GHG emission attributable to nuclear energy 

4 production sources because different assumptions and calculation methods will yield differing 

5 results. The differences and complexities in these assumptions and analyses will further 

6 increase when they are used to project future GHG emissions. Nevertheless, several 

7 conclusions can be drawn from the information presented.

8 First, the various studies show a general consensus that nuclear power currently produces 

9 fewer GHG emissions than fossil-fuel-based electrical generation (e.g., GHG emissions from a 

10 complete nuclear fuel cycle currently range from 2.5–66 grams of carbon equivalent per kilowatt 

11 hour (g Ceq/kWh), as compared to the use of coal plants (264–1,250 g Ceq/kWh) and natural gas 

12 plants (120-780 g Ceq/kWh)). The studies also provide estimates of GHG emissions from five 

13 renewable energy sources based on current technology. These estimates included 

14 solar-photovoltaic (17–125 g Ceq/kWh), hydroelectric (1–64.6 g Ceq/kWh), biomass 

15 (8.4–99 g Ceq/kWh), wind (2.5–30 g Ceq/kWh), and tidal (25–50 g Ceq/kWh). The range of these 

16 estimates is wide, but the general conclusion is that current GHG emissions from nuclear power 

17 generation are of the same order of magnitude as from these renewable energy sources.

18 Second, the studies show no consensus on future relative GHG emissions from nuclear power 

19 and other sources of electricity. There is substantial disagreement among the various authors 

20 about the GHG emissions associated with declining uranium ore concentrations, future uranium 

21 enrichment methods, and other factors, including changes in technology. Similar disagreement 

22 exists about future GHG emissions associated with coal and natural gas for electricity 

23 generation. Even the most conservative studies conclude that the nuclear fuel cycle currently 

24 produces fewer GHG emissions than fossil-fuel-based sources and is expected to continue to 

25 do so in the near future. The primary difference between the authors is the projected cross-over 

26 date (the time at which GHG emissions from the nuclear fuel cycle exceed those of 

27 fossil-fuel-based sources) or whether cross-over will actually occur. 

28 Considering current estimates and future uncertainties, it appears that GHG emissions 

29 associated with the proposed LGS relicensing action are likely to be lower than those 

30 associated with fossil-fuel–based energy sources. The staff bases this conclusion on the 

31 following rationale:

32  As shown in Tables 6–2 and 6–3, current estimates of GHG emissions from 

33 the nuclear fuel cycle are far below those for fossil-fuel-based energy 

34 sources.

35  License renewal of a nuclear power plant such as LGS may involve continued 

36 GHG emissions caused by uranium mining, processing, and enrichment, but 

37 will not result in increased GHG emissions associated with plant construction 

38 or decommissioning (since the plant will have to be decommissioned at some 

39 point whether the license is renewed or not).

40  Few studies predict that nuclear fuel cycle emissions will exceed those of 

41 fossil fuels within a timeframe that includes the LGS periods of extended 

42 operation. Several studies suggest that future extraction and enrichment 

43 methods, the potential for higher-grade resource discovery, and technology 

44 improvements could extend this timeframe.
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6-10

1 With respect to the comparison of GHG emissions among the proposed LGS license renewal 

2 action and renewable energy sources: 

3  It appears likely that there will be future technology improvements and 

4 changes in the type of energy used for mining, processing, manufacturing, 

5 and constructing facilities of all types. 

6  Currently, the GHG emissions associated with the nuclear fuel cycle and 

7 renewable energy sources are within the same order of magnitude. 

8  Because nuclear fuel production is the most significant contributor to possible 

9 future increases in GHG emissions from nuclear power—and since most 

10 renewable energy sources lack a fuel component—it is likely that GHG 

11 emissions from renewable energy sources will be lower than those 

12 associated with LGS at some point during the period of extended operation.

13 The staff provides additional discussion on the contribution of GHG to cumulative air quality 

14 impacts in Section 4.11.2 of this supplemental EIS. 

15 6.3. References

16 75 FR 81032. U.S. Nuclear Regulatory Commission. Consideration of environmental impacts of 

17 temporary storage of spent fuel after cessation of reactor operation. Federal Register

18 75(246):81032-81037. December 23, 2010.

19 75 FR 81037. U.S. Nuclear Regulatory Commission. Waste confidence decision update. 

20 Federal Register 75(246):81037-81076. December 23, 2010.

21 [AEA] AEA Technology. 2006. “Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note.” East 

22 Kilbride. UK: British Energy Group. March 2006. Available at <http://www.british-energy.com/

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24 Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU Reactors and Greenhouse 

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27 20documents/Publications/Life%20Cycle.htm> (accessed 21 May 2012). 

28 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

29 Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

30 License Renewal Stage. ADAMS Accession No. ML11179A104.

31 Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the 

32 Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain. 

33 Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at 

34 <http://gabe.web.psi.ch/pdfs/Critical%20note%20GHG%20PSI.pdf> (accessed 21 May 2012).

35 Fritsche UR. 2006. Comparison of Greenhouse-Gas Emissions and Abatement Cost of Nuclear 

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39 Fthenakis VM, Kim HC. 2007. Greenhouse-gas emissions from solar-electric and nuclear 

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Solid Waste Management, and Greenhouse Gas Emissions

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36 Netherlands: Ceedata Consultancy. February 2008. Available at <http://www.stormsmith.nl/>

37 (accessed 22 May 2012).

38 Weisser D. 2006. A guide to life-cycle greenhouse gas (GHG) emissions from electric supply 

39 technologies. Energy 32(9): 1543–1559. Available at 

40 <http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre41 print_versionDanielWeisser.pdf> (accessed 22 May 2012).

7-1 

1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

2 Environmental impacts from the activities associated with the decommissioning of any reactor 

3 before or at the end of an initial or renewed license are evaluated in Supplement 1 of 

4 NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear 

5 Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The

6 U.S. Nuclear Regulatory Commission (NRC) staff’s evaluation of the environmental impacts of 

7 decommissioning—presented in NUREG–0586, Supplement 1—notes a range of impacts for 

8 each environmental issue.

9 Additionally, the incremental environmental impacts associated with decommissioning activities 

10 resulting from continued plant operation during the renewal term are discussed in 

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

12 Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the 

13 environmental issue could be applied to all plants and whether additional mitigation measures 

14 would be warranted. Issues were then assigned a Category 1 or a Category 2 designation. 

15 Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines 

16 the impact designations of SMALL, MODERATE, and LARGE. The NRC staff analyzed 

17 site-specific issues (Category 2) for Limerick Generating Station, Units 1 and 2 (LGS) and 

18 assigned them a significance level of SMALL, MODERATE, or LARGE, or not applicable to LGS

19 because of site characteristics or plant features. There are no Category 2 issues related to 

20 decommissioning.

21 7.1. Decommissioning

22 Table 7–1 lists the Category 1 issues in Table B–1 of Title 10, Part 51 of the Code of Federal 

23 Regulations (10 CFR Part 51), Subpart A, Appendix B that are applicable to LGS

24 decommissioning following the renewal term.

25 Table 7–1. Issues Related to Decommissioning

Issues GEIS section Category

Radiation doses 7.3.1; 7.4 1

Waste management 7.3.2; 7.4 1

Air quality 7.3.3; 7.4 1

Water quality 7.3.4; 7.4 1

Ecological resources 7.3.5; 7.4 1

Socioeconomic impacts 7.3.7; 7.4 1

26 Decommissioning would occur either if LGS were shut down at the end of its current operating 

27 license or at the end of the period of extended operation. There are no site-specific issues 

28 related to decommissioning.

29 A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1 

30 of 10 CFR Part 51, for each of the issues follows:

31 Radiation doses. Based on information in the GEIS, the NRC noted that “[d]oses to the public 

32 will be well below applicable regulatory standards regardless of which decommissioning method 
Environmental Impacts of Decommissioning

7-2 

1 is used. Occupational doses would increase no more than 1 person-rem (1 person-millisievert) 

2 caused by buildup of long-lived radionuclides during the license renewal term.”

3 Waste management. Based on information in the GEIS, the NRC noted that 

4 “[d]ecommissioning at the end of a 20-year license renewal period would generate no more 

5 solid wastes than at the end of the current license term. No increase in the quantities of 

6 Class C or greater than Class C wastes would be expected.”

7 Air quality. Based on information in the GEIS, the NRC noted that “[a]ir quality impacts of 

8 decommissioning are expected to be negligible either at the end of the current operating term or 

9 at the end of the license renewal term.”

10 Water quality. Based on information in the GEIS, the NRC noted that “[t]he potential for 

11 significant water quality impacts from erosion or spills is no greater whether decommissioning 

12 occurs after a 20-year license renewal period or after the original 40-year operation period, and 

13 measures are readily available to avoid such impacts.”

14 Ecological resources. Based on information in the GEIS, the NRC noted that 

15 “[d]ecommissioning after either the initial operating period or after a 20-year license renewal 

16 period is not expected to have any direct ecological impacts.”

17 Socioeconomic Impacts. Based on information in the GEIS, the NRC noted that 

18 “[d]ecommissioning would have some short-term socioeconomic impacts. The impacts would 

19 not be increased by delaying decommissioning until the end of a 20-year relicense period, but 

20 they might be decreased by population and economic growth.”

21 Exelon Generation Company, LLC (Exelon) stated in its environmental report (ER) 

22 (Exelon 2011) that it is not aware of any new and significant information on the environmental 

23 impacts of LGS license renewal. The NRC staff has not found any new and significant 

24 information during its independent review of Exelon’s ER, the site visit, the scoping process, or 

25 its evaluation of other available information. Therefore, the NRC staff concludes that there are 

26 no impacts related to these issues, beyond those discussed in the GEIS. For all of these 

27 issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and additional 

28 plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

29 7.2. References

30 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

31 Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

32 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

33 Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

34 License Renewal Stage. ADAMS Accession No. ML11179A104. 

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

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

37 Agencywide Documents Access and Management System (ADAMS) Accession 

38 Nos. ML040690705 and ML040690738.

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

40 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants. In: 

41 Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, 

42 DC: NRC. NUREG–1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 

43 No. ML04069720.
Environmental Impacts of Decommissioning

7-3 

1 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 

2 Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 

3 Nuclear Power Reactors. Washington, DC: NRC. NUREG–0586, Supplement 1. 

4 November 2002. ADAMS Accession Nos. ML023470304 and ML023500295.

8-1 

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 

2 The National Environmental Policy Act (NEPA) requires that Federal agencies consider 

3 reasonable alternatives to the proposed action in an environmental impact statement (EIS). 

4 In this case, the proposed action is the issuance of renewed licenses for the Limerick 

5 Generating Station (LGS), which will allow the plant to operate for 20 years beyond its current 

6 license expiration dates.

7 An operating license, however, is just one of a number of authorizations that an applicant must 

8 obtain to operate a nuclear plant. Energy-planning decisionmakers and owners of the nuclear 

9 power plant ultimately decide whether the plant will continue to operate, and economic and 

10 environmental considerations play important roles in this decision. In general, the U.S. Nuclear 

11 Regulatory Commission’s (NRC’s) responsibility is to ensure the safe operation of nuclear 

12 power facilities and not to formulate energy policy or encourage or discourage the development 

13 of alternative power generation.

14 The license renewal review process is designed to ensure safe operation of the nuclear power 

15 plant during the license renewal term. Under the NRC’s environmental protection regulations in 

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

17 Section 102(2) of NEPA, renewal of a nuclear power plant operating license also requires the 

18 preparation of an EIS.

19 To support the preparation of these EISs, the NRC prepared the Generic Environmental Impact 

20 Statement for License Renewal of Nuclear Plants (GEIS), NUREG–1437, in 1996. The license 

21 renewal GEIS was prepared to assess the environmental impacts of continued nuclear power 

22 plant operations during the license renewal term. The intent was to determine which 

23 environmental impacts would result in essentially the same impact at all nuclear power plants 

24 and which ones could result in different levels of impacts at different plants and would require a 

25 plant-specific analysis to determine the impacts. For those issues that could not be generically 

26 addressed, the NRC develops a plant-specific supplemental environmental impact statement 

27 (SEIS) to the GEIS.

28 NRC regulations in 10 CFR 51.71(d) implementing NEPA for license renewal require that a 

29 SEIS must do the following: 

30 ...include a preliminary analysis that considers and weighs the environmental 

31 effects of the proposed action [license renewal]; the environmental impacts of 

32 alternatives to the proposed action; and alternatives available for reducing or 

33 avoiding adverse environmental effects.

34 While the 1996 GEIS reached generic conclusions on many environmental issues associated 

35 with license renewal, it did not determine which alternatives are reasonable and did not reach 

36 conclusions about site-specific environmental impact levels. As such, the NRC must evaluate 

37 the environmental impacts of alternatives on a site-specific basis.
Environmental Impacts of Alternatives

8-2 

1 As stated in Chapter 1 of this document, alternatives to renewing the LGS operating licenses 

2 must meet the purpose and need for the proposed action; they must do the following:

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

4 current nuclear power plant operating license to meet other future system generating 

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

6 Federal (other than NRC) decision makers. (NRC 1996) 

7 The NRC ultimately makes no decision about which alternative (or the proposed action) to carry 

8 out because that decision falls to utility, state, or other Federal officials. Comparing the 

9 environmental effects of these alternatives, however, will help the NRC decide whether the 

10 adverse environmental impacts of license renewal are so great as to deny the option of license 

11 renewal for energy-planning decisionmakers 

12 (10 CFR 51.95(c)(4)). If the NRC acts to issue 

13 a renewed license, then all of the alternatives 

14 considered in this SEIS, including the 

15 proposed action, will be available to 

16 energy-planning decisionmakers. If the NRC 

17 decides not to renew the license (or takes no 

18 action at all), then energy-planning 

19 decisionmakers may no longer elect to 

20 continue operating LGS and will have to resort 

21 to another alternative (or combination of 

22 alternatives)—which may or may not be one of 

23 the alternatives considered in this section—to 

24 meet the energy needs that LGS now satisfies.

25 In evaluating alternatives to license renewal, 

26 the NRC considered energy technologies or 

27 options currently in commercial operation, as 

28 well as some technologies not currently in 

29 commercial operation but likely to be 

30 commercially available by the time the current 

31 LGS operating licenses expire. The current 

32 operating licenses for LGS reactors will expire 

33 on October 26, 2024, and June 22, 2029, and 

34 reasonable alternatives must be available 

35 (constructed, permitted, and connected to the 

36 grid) by the time the current LGS licenses 

37 expire to be considered likely to become 

38 available.

39 Alternatives that cannot meet future system needs by providing amounts of baseload power 

40 equivalent to LGS’s current generating capacity and, in some cases, those alternatives whose 

41 costs or benefits do not justify inclusion in the range of reasonable alternatives, were eliminated 

42 from detailed study. The staff evaluated the environmental impacts of the remaining 

43 alternatives and discusses them in depth in this chapter. Each alternative eliminated from 

44 detailed study is briefly discussed, and a basis for its removal is provided at the end of this 

45 section. In total, 18 alternatives to the proposed action were considered (see text box) and then 

46 narrowed to the 5 alternatives considered in 

47 Sections 8.1–8.5. 

48 The 1996 GEIS presents an overview of some energy technologies but does not reach any 

49 conclusions about which alternatives are most appropriate. Since 1996, many energy 

Alternatives Evaluated In-Depth:

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

• supercritical pulverized coal (SCPC)

• new nuclear

• wind power

• purchased power

Other Alternatives Considered:

• solar power,

• combination alternative of wind, solar, and 

NGCC, 

• combination alternative of wind and 

compressed-air energy storage (CAES),

• wood waste,

• conventional hydroelectric power,

• ocean wave and current energy,

• geothermal power,

• municipal solid waste (MSW),

• biofuels,

• oil-fired power,

• fuel cells,

• demand-side management (DSM), and

• delayed retirement.
Environmental Impacts of Alternatives

8-3 

1 technologies have evolved significantly in capability and cost while regulatory structures have 

2 changed to either promote or impede development of particular alternatives.

3 As a result, the analyses may include updated information from the following sources:

4 • Energy Information Administration (EIA),

5 • other offices within the U.S. Department of Energy (DOE),

6 • U.S. Environmental Protection Agency (EPA),

7 • industry sources and publications, and

8 • information submitted by Exelon Generation Company, LLC (Exelon) in its 

9 environmental report (ER).

10 The evaluation of each alternative considers the environmental impacts across several impact 

11 categories: air quality, groundwater use and quality, surface water use and quality, terrestrial 

12 ecology, aquatic ecology, human health, land use, socioeconomics, transportation, aesthetics, 

13 historic and archaeological resources, environmental justice, and waste management. 

14 A three-level standard of significance—SMALL, MODERATE, or LARGE—is used to indicate 

15 the intensity of environmental effects for each alternative undergoing in-depth evaluation. The 

16 order of presentation is not meant to imply increasing or decreasing level of impact. Nor does it 

17 imply that an energy-planning decisionmaker would be more likely to select any given 

18 alternative.

19 In some cases, the NRC considers the environmental effects of locating a replacement power 

20 alternative at the existing nuclear plant site. Selecting the existing plant site allows for the 

21 maximum use of existing transmission and cooling system infrastructures and minimizes the 

22 overall environmental impact. However, LGS does not have a sufficient amount of land 

23 available for all the replacement power alternatives because LGS would continue to operate 

24 while the replacement alternative is being built to prevent a gap in energy generation during the 

25 period of construction, which would take several years. As a result, the NRC evaluated the 

26 impacts of locating replacement power facilities at other existing power plant sites within the 

27 PJM Interconnection (PJM). Installing replacement power facilities at existing power plants and 

28 connecting to existing transmission and cooling system infrastructure would reduce the overall 

29 environmental impact.

30 To ensure that the alternatives analysis is consistent with state or regional energy policies, the 

31 NRC reviewed energy-related statutes, regulations, and policies within the Commonwealth of 

32 Pennsylvania and PJM, including, for example, state renewable portfolio standards (RPSs). As 

33 a result, the staff considers several alternatives that include wind power or solar photovoltaic 

34 power, as well as combinations that include them.

35 Exelon is wholly-owned by Exelon Corporation, which also owns companies that provide electric 

36 transmission, power marketing, and energy delivery. Exelon Generation does not directly serve 

37 any customers, but sells its output through existing markets, and in particular, through PJM. 

38 The NRC considered the current generation capacity and electricity production within the 

39 Commonwealth of Pennsylvania, as well as, where pertinent, the territory covered by PJM. 

40 Pennsylvania is similar to the U.S. average in reliance on coal, natural gas, and nuclear power 

41 as its primary electric generation fuels. Pennsylvania is slightly more reliant on coal, less reliant 

42 on natural gas, and more reliant on nuclear power than the U.S. average. Pennsylvania 

43 diverged most from national averages in renewable generation. Pennsylvania hydropower and 

44 other renewables provided 2.8 percent of electricity in the Commonwealth compared to 

45 10.4 percent nationwide (EIA 2012).
Environmental Impacts of Alternatives

8-4 

1 Pennsylvania is one of the nation’s top generators of electricity and a net exporter of power. 

2 While the staff generally considers alternatives located within Pennsylvania, it acknowledges 

3 that alternatives could also be located elsewhere in PJM.

4 The Commonwealth of Pennsylvania has established an alternative energy portfolio standard 

5 (AEPS, similar to a renewable portfolio standard) that requires electricity providers to obtain a 

6 minimum percentage of their power through renewable energy resources, energy efficiency 

7 measures, or one of several nonconventional coal-fired or natural-gas-fired alternatives, 

8 including waste coal, coal-mine methane, coal gasification, and combined-heat-and-power 

9 generation. The AEPS also includes a solar-power set-aside. Pennsylvania first adopted the 

10 AEPS requirement in 2004. It currently requires 18 percent of all electricity sold in the 

11 Commonwealth to come from qualifying sources by 2020–2021. The standard allows 

12 renewable energy credit trading within PJM (DSIRE 2011). Other states in PJM also have 

13 similar policies, which typically take the form of binding standards. Some, however, have 

14 implemented non-binding goals, as Virginia has done.

15 Sections 8.1–8.7 describe the environmental impacts of alternatives to license renewal. These 

16 include a natural gas combined-cycle (NGCC) in Section 8.1; a supercritical pulverized coal 

17 (SCPC) alternative in Section 8.2; a new nuclear alternative in Section 8.3; and a wind-power 

18 alternative in Section 8.4. A summary of these alternatives considered in depth is provided in 

19 Table 8-1. In Section 8.5, the staff discusses purchased power as an alternative, and in 

20 Section 8.6, the staff addresses alternatives considered but dismissed. Finally, the 

21 environmental effects that may occur if NRC takes no action and does not issue renewed 

22 licenses for LGS are described in Section 8.7. Section 8.8 summarizes the impacts of each of 

23 the alternatives considered.
Environmental Impacts of Alternatives

8-5 

1 Table 8–1. Summary of Alternatives Considered In Depth

Natural Gas (NGCC) 

Alternative

Supercritical 

Pulverized Coal 

(SCPC) Alternative

New Nuclear 

Alternative

Wind 

Alternative

Summary of 

Alternative

Four 530-MW units, 

for a total of 

2,120 MW

Two to four SCPC 

Units, for a total of 

2,120 MW

Two unit 

nuclear plant

2,250 to 9,000 

2-MW wind 

turbines, for a 

total of 4,500 to 

18,000 MW

Location An existing power 

plant site (other than 

LGS) in PJM. Some 

infrastructure 

upgrades may be 

required; would 

require construction of a 

new or upgraded 

pipeline.

An existing power 

plant site (other than 

LGS) in PJM. Some 

infrastructure 

upgrades may be 

required.

An existing nuclear 

plant site (other than 

LGS) in PJM. Some 

infrastructure 

upgrades may be 

required.

Spread across 

multiple sites 

throughout PJM. 

Cooling System Closed-cycle with 

mechanical-draft cooling 

towers. Consumptive 

water use would be 

approximately 

1/3 less than LGS.

Closed-cycle with 

natural-draft cooling 

towers. Consumptive 

water use would be 

slightly less than 

LGS.

Closed-cycle with 

natural-draft cooling 

towers. 

Consumptive water 

use would be similar 

to LGS.

N/A

Land 

Requirements

35 ac (14 ha) for the 

plant (Exelon 2011); 

7,630 ac (3,090 ha) 

for wells, collection site, 

pipeline (NRC 1996)

280 ac (113 ha) for 

the plant (Exelon 

2011); 49,600 ac 

(20,100 ha) for coal 

mining and waste 

disposal (NRC 1996); 

464 ac (188 ha) for 

ash and scrubber 

sludge (Exelon 2011)

630 ac to 1,260 ac 

(255 ha to 510 ha) 

(Exelon 2011); 

1,000 ac (400 ha) 

for uranium mining 

and processing 

(NRC 1996)

Wind farms 

would be spread 

across 130,000 

to 534,000 ac 

(53,000 to 

216,000 ha) of 

land, but only 

3,200 to 13,300 

ac (1,300 to 

5,400 ha), would 

be directly 

affected by the 

wind turbines 

(Exelon 2011, 

NREL 2009) 

Work Force 800 during construction; 

45 during operations 

(Exelon 2011)

2,500 during 

construction; 141 

during operations 

(Exelon 2011)

3,650 during 

construction; 

820 during 

operations (Exelon 

2011)

200 during 

construction; 

50 during 

operations 

(Exelon 2011)

2 8.1 Natural Gas Combined-Cycle Alternative

3 Natural gas combined-cycle (NGCC) systems represent the large majority of the total number of 

4 plants currently under construction or planned in the United States. Factors that contribute to 

5 the popularity of NGCC facilities include high capacity factors, low relative construction costs, 
Environmental Impacts of Alternatives

8-6 

1 low gas prices, and relatively low air emissions. Development of new NGCC plants may be 

2 affected by uncertainties about the continued availability and price of natural gas (though less 

3 so than in the recent past) and future regulations that may limit greenhouse gas (GHG) 

4 emissions. A gas-fired power plant, however, produces markedly fewer GHGs per unit of 

5 electrical output than a coal-fired plant of the same electrical output.

6 Combined-cycle power plants differ significantly from most coal fired and all existing nuclear 

7 power plants. Combined-cycle plants derive the majority of their electrical output from a gas 

8 turbine and then generate additional power—without burning any additional fuel—through a 

9 second, steam turbine cycle. The exhaust gas from the gas turbine is still hot enough to boil 

10 water to steam. Ducts carry the hot exhaust to a heat recovery steam generator, which 

11 produces steam to drive a steam turbine and produce additional electrical power. The 

12 combined-cycle approach is significantly more efficient than any one cycle on its own; thermal 

13 efficiency can exceed 60 percent versus 38 percent for conventional single-cycle facilities 

14 (NETL 2007, Siemens 2007). In addition, because the natural gas-fired alternative derives 

15 much of its power from a gas-turbine cycle, and because it wastes less heat than the existing 

16 LGS unit, it requires significantly less cooling water.

17 While nuclear reactors, on average, operate with capacity factors above 90 percent 

18 (LGS Units 1 and 2 operated at 97 percent and 96 percent capacity factors, respectively, 

19 from 2003 to 2010 [NRC 2011]), the staff expects that an NGCC alternative would operate with 

20 roughly an 85 percent capacity factor. Nonetheless, the staff assumes that a similar-sized 

21 NGCC facility would be capable of providing adequate replacement power for the purposes of 

22 this NEPA analysis. 

23 Typical power trains for large-scale NGCC power generation would involve one, two, or three 

24 combined-cycle units, available in a variety of standard sizes, mated to a heat-recovery steam 

25 generator. To complete the assessment of an NGCC alternative, the NRC presumes that 

26 appropriately sized units could be assembled to annually produce electrical power in amounts 

27 equivalent to LGS. For purposes of this review, the staff evaluated an alternative that consists 

28 of four General Electric (GE) Advanced F Class units, 530 MW(e) each, equipped with 

29 dry-low-nitrogen-oxide combustors to suppress nitrogen oxide formation and selective catalytic 

30 reduction (SCR) of the exhaust with ammonia for post-combustion control of nitrogen oxide 

31 emissions. This alternative provides 2,120 MW(e) of capacity, and thus slightly underestimates 

32 the potential environmental impacts of replacing the full 2,340 MW(e) produced by LGS.

33 While siting an alternative on the LGS site would allow for the fullest use of existing ancillary 

34 infrastructure, such as transmission and support buildings, and minimizes the use of 

35 undisturbed land, space constraints on the LGS site preclude that option. In its ER, Exelon 

36 proposed that the NGCC alternative could be constructed at another existing power plant site 

37 elsewhere in Pennsylvania or PJM, which would mitigate construction impacts in a similar way 

38 to building the alternative at the LGS site (Exelon 2011). The staff finds this to be a reasonable 

39 approach and adopts it for purposes of this analysis. It is possible that an NGCC alternative 

40 constructed at an existing power plant site would require some infrastructure upgrades, such as 

41 improved transmission lines or modifications to existing intake or cooling systems, but the staff 

42 expects that these impacts would be smaller than those necessary to support an NGCC 

43 alternative constructed on an undeveloped site. 

44 Wherever the NGCC alternative is constructed, it is likely to require a new or upgraded pipeline 

45 to supply natural gas to the facility. Some of the natural gas supplied to this alternative is likely 

46 to come from Pennsylvania or neighboring states, but the NGCC alternative is unlikely to 

47 directly trigger new natural gas development in Pennsylvania or the region.
Environmental Impacts of Alternatives

8-7 

1 NGCC power plants are feasible, commercially available options for providing electric 

2 generating capacity beyond the current LGS license expiration dates. Environmental impacts 

3 from the NGCC alternative are summarized in Table 8–2 and discussed in depth in 

4 Sections 8.1.1–8.1.9.

5 8.1.1. Air Quality

6 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

7 Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control 

8 Region (AQCR, 40 CFR 81.15). With regard to the National Ambient Air Quality Standards 

9 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 

10 attainment for carbon monoxide (CO), lead, sulfur dioxide (SO2), and PM10 (particulate matter 

11 10 microns or less in diameter) and nonattainment for ozone and PM2.5 (particulate 

12 matter 2.5 microns or less in diameter) (40 CFR 81.339).

13 A new NGCC generating plant would qualify as a new major-emitting industrial facility and 

14 would be subject to Prevention of Significant Deterioration (PSD) under requirements of the 

15 Clean Air Act (CAA) (EPA 2012a). The Pennsylvania Department of Environmental Protection 

16 (PADEP) has adopted 25 Pa. Code Chapter 127, which implements the EPA’s PSD review. 

17 The NGCC plant would need to comply with the standards of performance for stationary 

18 combustion turbines set forth in 40 CFR Part 60 Subpart KKKK. 

19 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 

20 including review of the new sources that may affect visibility in any Federal Class I area. If an 

21 NGCC alternative was located close to a mandatory Class I area, additional air pollution control 

22 requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I 

23 Federal areas within 50 miles (80 km) of the LGS site. However, there are a total of 

24 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: 

25 Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 

26 A new NGCC plant would have to comply with Title IV of the CAA (42 USC §7651) reduction 

27 requirements for sulfur dioxides (SO2) and nitrogen oxides (NOx), which are the main precursors 

28 of acid rain and the major causes of reduced visibility. Title IV establishes maximum SO2 and 

29 NOx emission rates from the existing plants and a system of SO2 emission allowances that can 

30 be used, sold, or saved for future use by the new plants. 

31 More recently, EPA has promulgated additional rules and requirements that apply to certain 

32 fossil-fuel-based power plants, such as NGCC generation. The Cross-State Air Pollution Rule 

33 (CSAPR) and the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) 

34 Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG 

35 emissions from fossil-fuel based power plants (EPA 2012c). A new NGCC plant would be 

36 subject to these additional rules and regulations. 

37 The EPA has developed standard emission factors that relate the quantity of released air 

38 pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the 

39 staff projects the following air emissions for the NGCC alternative: 

40 • sulfur oxides (SOx) – 167 tons (151 MT) per year, 

41 • nitrogen oxides (NOx) – 485 tons (440 MT) per year,

42 • carbon monoxide (CO) – 735 tons (667 MT) per year,

43 • PM10 and PM2.5– 323 tons (293 MT) per year, and

44 • carbon dioxide (CO2) – 5,390,097 tons (4,889,896 MT) per year
Environmental Impacts of Alternatives

8-8 

1 Activities associated with the construction of the new NGCC plant on or off the LGS site would 

2 cause some additional, temporary air effects as a result of equipment emissions and fugitive 

3 dust from operation of the earth-moving and material-handling equipment. Emissions from 

4 workers’ vehicles and motorized construction equipment exhaust would be temporary. The 

5 construction crews would use dust-control practices to control and reduce fugitive dust. The 

6 staff concludes that the impact of vehicle exhaust emissions and fugitive dust from operation of 

7 the earth-moving and material-handling equipment would be SMALL. 

8 Greenhouse Gas Emissions

9 Combustion of fossil fuels, including natural gas, is the greatest anthropogenic source of GHG 

10 emissions in the United States. Greenhouse gas emissions during construction of an NGCC 

11 alternative would result primarily from the consumption of fossil fuels in the engines of 

12 construction vehicles and equipment, workforce vehicles used in commuting to and from the 

13 work site, and delivery vehicles. Analogous impacts would occur in association with offsite 

14 pipeline construction. All such impacts, however, would be temporary. 

15 Although natural gas combustion in the combustion turbines (CTs) would be the primary source 

16 of GHGs during operations, other miscellaneous ancillary sources such as truck and rail 

17 deliveries of materials to the site and commuting of the workforce would make minor 

18 contributions.

19 The National Energy Technology Laboratory (NETL) estimates that carbon capture and storage 

20 (CCS) will capture and remove as much as 90 percent of the CO2 from the exhausts of CTs, but 

21 it will result in a power production capacity decrease of approximately 14 percent, a reduction in 

22 net overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a 

23 potential increase in the levelized cost of electricity produced in NGCC units so equipped by as 

24 much as 30 percent (NETL 2007). Further, permanent sequestering of the CO2 would involve 

25 removing impurities (including water) and pressurizing it to meet pipeline specifications and 

26 transferring the gas by pipeline to acceptable geologic formations. Even when opportunities 

27 exist to use the CO2 for enhanced oil recovery (rather than simply dispose of the CO2 in 

28 geologic formations), permanent disposal costs could be substantial, especially if the NGCC 

29 units are far removed from acceptable geologic formations. With CCS in place, the NGCC 

30 alternative would release 539,000 tons per year (489,000 MT) of CO2. Without CCS in place, 

31 the staff’s projected CO2 emissions for the NGCC alternative would be 5,390,097 tons 

32 (4,889,896 MT) per year. 

33 Given the expected relatively small workforce, relatively short construction period for both the 

34 NGCC facility and the pipeline, and CO2 emissions of operation for the NGCC alternative, the 

35 overall impact from the releases of GHGs of a natural gas-fired alternative would be SMALL to 

36 MODERATE.

37 Conclusion

38 Based on the above review, the overall air quality impacts of a new NGCC plant located at the 

39 LGS site are SMALL to MODERATE and based largely on operational impacts.

40 8.1.2. Groundwater Resources

41 Construction activities associated with the NGCC alternative could require groundwater 

42 dewatering of foundation excavations. This activity might require the use of cofferdams, sumps, 

43 wells, or other methods to address high water-table conditions. However, because of the 

44 relatively shallower depth of excavation for the NGCC plant as compared to other alternatives, 

45 any impacts would be expected to be minor at most sites; however, dewatering needs could be 

46 greater at some sites. Facility construction would increase the amount of impervious surface at 
Environmental Impacts of Alternatives

8-9 

1 the site location as well as alter the subsurface strata because of excavation work and the 

2 placement of backfill following facility completion. While an increase in impervious surface 

3 would reduce infiltration and reduce groundwater recharge, the effects on water-table elevations 

4 at most sites would likely be very small. Below-grade portions of the new NGCC plant could 

5 also alter the direction of groundwater flow beneath a site. Such effects would likely be very 

6 localized at most site locations and would not be expected to affect offsite wells. Application of 

7 best management practices (BMPs) in accordance with a state-issued NPDES general permit, 

8 including appropriate waste management, water discharge, and spill prevention practices, would 

9 prevent or minimize any groundwater quality impacts during construction. 

10 For the construction period, the NRC has conservatively assumed that groundwater would be 

11 used. However, it is more likely that water would be supplied via a temporary utility connection, 

12 if available, or trucked to the point of use from offsite sources. Regardless, groundwater use for 

13 construction of a new NGCC plant would be substantially less than the volume required for the 

14 coal-fired or nuclear alternatives because of the smaller footprint involved for excavation, 

15 earthwork, and structural work. This would encompass such uses as potable and sanitary uses, 

16 concrete production, dust suppression, and soil compaction. The workforce at the NGCC would 

17 be slightly smaller than the existing LGS workforce, which uses substantially less than 100 gpm 

18 (380 L/min) for both potable water supply and fire suppression uses. The GEIS has found that 

19 pumping rates of less than 100 gpm (380 L/min) have not been shown to adversely affect 

20 groundwater availability (NRC 1996). 

21 For NGCC plant operations, the NRC assumed that the NGCC alternative would entail the same 

22 relative ratio of groundwater use to surface water use as that used at LGS Units 1 and 2. This 

23 includes the use of groundwater for service water makeup and potable and sanitary uses. 

24 Consequently, the staff expects that total groundwater usage and associated aquifer effects 

25 would be much less under this alternative than those under current LGS operations because of 

26 the smaller number of auxiliary systems requiring groundwater and the much smaller 

27 operational workforce under the NGCC alternative. Based on this assessment, the impacts on 

28 groundwater use and quality under the NGCC alternative would be SMALL.

29 8.1.3. Surface Water Resources

30 Construction activities associated with the NGCC alternative would be similar to construction

31 activities for most large industrial facilities. A new NGCC plant would occupy a much smaller 

32 footprint (about 35 ac [14 ha]) than the current LGS or the proposed coal-fired or new nuclear 

33 alternatives. This would also result in less extensive excavation and earthwork than under 

34 either of the other conventional replacement power facility alternatives. The staff assumes that 

35 no surface water would be used during construction for the NGCC alternative because the staff 

36 assumed groundwater would be used or water would be supplied by a water utility or trucked in, 

37 as explained above in Section 8.1.2. 

38 Some temporary impacts to surface water quality may result from increased sediment loading 

39 and from any pollutants in stormwater runoff from disturbed areas and from dredging activities. 

40 During facility construction, runoff from disturbed areas in the plant footprint would be controlled 

41 under a state-issued NPDES general permit that would require implementation of a stormwater 

42 pollution prevention plan and associated BMPs to prevent or significantly mitigate soil erosion 

43 and contamination of stormwater runoff. Depending on the path of the gas pipeline to supply 

44 the NGCC plant, some creeks and streams would likely be crossed. However, because of the 

45 short-term nature of the dredging activities, the hydrologic alterations and sedimentation would 

46 be localized and temporary. In addition, modern pipeline construction techniques, such as 

47 horizontal directional drilling, would further minimize the potential for water quality impacts in the 
Environmental Impacts of Alternatives

8-10

1 affected streams. Dredging would be conducted under a permit from the U.S. Army Corps of 

2 Engineers (COE) requiring the implementation of BMPs to minimize impacts. 

3 For facility operations, the NGCC alternative would require much less cooling water than LGS 

4 Units 1 and 2, and consumptive water use would be much less. Assuming a typical ratio of 

5 2 to 1 for electrical generation from gas turbine (Brayton cycle) to electrical generation from 

6 steam turbine (Rankine cycle) for a combined-cycle plant, the staff estimated that the 

7 consumptive water loss for an equivalent-sized combined-cycle plant would be about one-third 

8 the LGS water use. For the purposes of comparison, and as described in Section 2.2.4.1, the 

9 mean annual flow and 90 percent exceedance flows of the Schuylkill River are 1,935 cfs 

(54.8 m3

/s) and 482 cfs (13.6 m3 10 /s), respectively. At the mean annual flow and the 90 percent 

11 exceedance flow, the projected rate of consumptive water use for the NGCC plant (i.e., 22 cfs 

[0.62 m3 12 /s]) represents a 1 percent and a 4 percent reduction in the streamflow in the Schuylkill 

13 River downstream of the NGCC alternative location, if sited at or near the LGS site. This 

14 reduced demand for water would substantially reduce the need for low-flow augmentation from 

15 either the Delaware River or the Wadesville Mine Pool. Effects may vary at other sites, but the 

16 net consumption of water would be less than that associated with existing LGS operations.

17 The NRC assumed that water treatment additives for the NGCC alternative would be essentially 

18 identical to LGS because similar additives are required for water conditioning to operate NGCC 

19 and nuclear plants. The NRC also assumed that the proposed site’s existing intake and 

20 discharge infrastructure would be used, as described above. While the quality would be 

21 chemically similar, the discharge volume would be about one-third less than current LGS 

22 operations. Surface water withdrawals would be subject to applicable water allocation 

23 requirements in Pennsylvania and other states, and effluent discharges and stormwater 

24 discharges associated with industrial activity would be subject to a state-issued NPDES permit 

25 under this alternative. The NRC also assumes that facility operations would be subject to and 

26 would be conducted in accordance with a spill prevention, control, and countermeasures 

27 (SPCC) plan, stormwater pollution prevention plan, or equivalent plans and associated BMPs 

28 and procedures to prevent and respond to accidental releases of non-nuclear fuels, chemicals, 

29 and other materials to soil, surface water, and groundwater.

30 Therefore, based on the above assessment, the impacts on surface water use and quality under 

31 the NGCC alternative would be SMALL.

32 8.1.4. Aquatic Resources

33 Construction activities for the NGCC alternative (such as construction of heavy-haul roads, a 

34 new pipeline, and the power block) could affect drainage areas or other onsite aquatic features. 

35 Minimal impacts on aquatic ecology resources are expected because the plant operator would 

36 likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, 

37 which would be required to comply with Pennsylvania NPDES permitting, would minimize the 

38 flow of disturbed soils into aquatic features. Depending on the available infrastructure at the 

39 selected site, the NGCC alternative may require modification or expansion of the existing intake 

40 or discharge structures. Because of the relatively low withdrawal rates compared to the SCPC 

41 or new nuclear alternatives, it is unlikely that the operators would need to construct new intake 

42 and discharge structures for the NGCC alternative at an existing power plant site. Dredging 

43 activities that result from infrastructure construction would require BMPs for in-water work to 

44 minimize sedimentation and erosion. Because of the short-term nature of the dredging 

45 activities, the hydrological alterations to aquatic habitats likely would be localized and 

46 temporary.
Environmental Impacts of Alternatives

8-11

1 During operations, the NGCC alternative would require approximately one-third less cooling 

2 water to be withdrawn from the Schuylkill River, or other similar water body, than required for 

3 LGS Units 1 and 2. Because of the lower withdrawal rates, the number of fish and other aquatic 

4 resources affected by cooling-water intake and discharge operations, such as entrainment, 

5 impingement, and thermal stress, would be less for an NGCC alternative than for those 

6 associated with license renewal. The cooling system for a new NGCC plant would have similar 

7 chemical discharges as LGS, but the air emissions from the NGCC plant would emit particulates 

8 that could settle onto the river surface and introduce a new source of pollutants as described in 

9 Section 8.1.1. However, the flow of the Schuylkill River (or other water source) would likely 

10 dissipate and dilute the concentration of pollutants, resulting in minimal exposure to aquatic 

11 biota. 

12 The impacts on aquatic ecology would be minor because construction activities would require 

13 BMPs and stormwater management permits, and because surface water withdrawal and 

14 discharge for this alternative would be less than for LGS Units 1 and 2. Deposition of pollutants 

15 into aquatic habitats from the plant’s air emissions would be minimal because the concentration 

16 of pollutants would be diluted with the river flow. Therefore, the staff concluded that impacts on 

17 aquatic ecology would be SMALL.

18 Consultation with National Marine Fisheries Service (NMFS), and the U.S. Fish and Wildlife 

19 Service (FWS) under the Endangered Species Act (ESA) would ensure that the construction 

20 and operation of an NGCC plant would not adversely affect any Federally listed species or 

21 adversely modify or destroy designated critical habitat. Consultation with NMFS under the 

22 Magnuson-Stevens Act would require the NRC to evaluate impacts to essential fish habitat 

23 (EFH). NMFS would provide conservation recommendations if there would be adverse impacts 

24 to EFH. Coordination with state natural resource agencies would further ensure that the plant 

25 operator would take appropriate steps to avoid or mitigate impacts to state-listed species, 

26 habitats of conservation concern, and other protected species and habitats. Consequently, the 

27 impacts of construction and operation of an NGCC plant on protected species and habitats 

28 would be SMALL. 

29 8.1.5. Terrestrial Resources

30 Construction of an NGCC plant would occur at the site of an existing power station other than 

31 LGS and would require about 35 ac (14 ha) of land for the plant itself and about 7,630 ac 

32 (3,090 ha) of additional land off site for wells, collection stations, and pipelines to bring the gas 

33 to the plant (see Section 8.1.7). Because the onsite land requirement is relatively small, Exelon 

34 would likely be able to site most of the construction footprint in previously disturbed, degraded 

35 habitat, which would minimize impacts to terrestrial habitats and species. Offsite construction 

36 would occur mostly on land where gas extraction is occurring already. To the extent 

37 practicable, Exelon would route gas pipelines along existing, previously disturbed utility 

38 corridors (Exelon 2011). Erosion and sedimentation, fugitive dust, and construction debris 

39 impacts would be minor with implementation of appropriate BMPs (Exelon 2011). Impacts to 

40 terrestrial habitats and species from transmission line operation and corridor vegetation 

41 maintenance, and operation of the mechanical draft cooling towers would be similar in 

42 magnitude and intensity as those resulting from operating nuclear reactors and would, therefore, 

43 be SMALL (NRC 1996). Overall, the impacts of construction and operation of an NGCC plant to 

44 terrestrial habitats and species would be SMALL.

45 Consultation with FWS under the ESA would ensure that the construction and operation of an 

46 NGCC plant would not adversely affect any Federally listed terrestrial species or adversely 

47 modify or destroy designated critical habitat. Coordination with state natural resource agencies 

48 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 
Environmental Impacts of Alternatives

8-12

1 state-listed species, habitats of conservation concern, and other protected species and habitats. 

2 Consequently, the impacts of construction and operation of an NGCC plant on protected 

3 species and habitats would be SMALL. 

4 8.1.6. Human Health

5 Impacts on human health from construction of the NGCC alternative would be similar to effects

6 associated with the construction of any major industrial facility. Compliance with worker 

7 protection rules would control those impacts on workers at acceptable levels. Impacts from 

8 construction on the general public would be minimal since crews would limit active construction 

9 area access to authorized individuals. Impacts on human health from the construction of the 

10 NGCC alternative would be SMALL.

11 Human health effects of gas-fired generation are generally low, although in Table 8–2 of the 

12 GEIS (NRC 1996), the staff identified cancer and emphysema as potential health risks from 

13 gas-fired plants. Nitrogen oxide emissions contribute to ozone formation, which in turn 

14 contributes to human health risks. Emission controls for the NGCC alternative can be expected 

15 to maintain NOx emissions well below air quality standards established for the purposes of 

16 protecting human health, and emissions trading or offset requirements mean that overall NOx

17 releases in the region will not increase. Health risks for workers may also result from handling 

18 spent catalysts used for NOx control that may contain heavy metals. Impacts on human health 

19 from the operation of the NGCC alternative would be SMALL.

20 8.1.7. Land Use

21 The GEIS generically evaluates the impacts of constructing and operating various replacement 

22 power plant alternatives on land use, both on and off each power plant site. The analysis of 

23 land use impacts focuses on the amount of land area that would be affected by the construction 

24 and operation of a four-unit NGCC plant at the LGS site. Locating the new NGCC power plant 

25 near an existing power plant site would maximize the availability of support infrastructure and 

26 reduce the need for additional land.

27 Exelon estimated 35 ac (14 ha) for new unit construction (Exelon 2011). Based on GEIS 

28 estimates, approximately 243 ac (98.3 ha) of land would be needed to support an NGCC 

29 alternative to replace the LGS (NRC 1996). This amount of land use would include other plant 

30 structures and associated infrastructure and is unlikely to exceed the 243 ac (98.3 ha) estimate, 

31 excluding land for natural-gas wells and collection stations. Exelon’s estimate appears 

32 reasonable and is a more site-specific estimate than the GEIS estimate. Depending on the site 

33 location and availability of existing natural gas pipelines, a 100-feet (ft)-wide (30.5-meter 

34 [m]-wide) right-of-way would be needed for a new pipeline. Land-use impacts from NGCC 

35 construction would be SMALL to MODERATE depending on location.

36 In addition to onsite land requirements, land would be required off site for natural-gas wells and 

37 collection stations. Scaling from GEIS (NRC 1996) estimates, approximately 7,630 ac 

38 (3,090 ha) would be required for wells, collection stations, and pipelines to bring the gas to the 

39 plant. Most of this land requirement would occur on land where gas extraction already occurs. 

40 Some natural gas could come from within Pennsylvania or nearby states. 

41 The elimination of uranium fuel for LGS could partially offset some, but not all, of the land 

42 requirements for the NGCC. Scaling from GEIS (NRC 1996) estimates, approximately 1,640 ac 

43 (664 ha) would no longer be needed for mining and processing uranium during the operating life 

44 of the plant. Operational land-use impacts from a NGCC power plant would be SMALL.
Environmental Impacts of Alternatives

8-13

1 8.1.8. Socioeconomics

2 Socioeconomic impacts are defined in terms of changes to the demographic and economic 

3 characteristics and social conditions of a region. For example, the number of jobs created by 

4 the construction and operation of a power plant could affect regional employment, income, and 

5 expenditures. Two types of jobs would be created by this alternative: (1) construction jobs, 

6 which are transient, short in duration, and less likely to have a long-term socioeconomic impact; 

7 and (2) power plant operations jobs, which have the greater potential for permanent, long-term 

8 socioeconomic impacts. Workforce requirements for the construction and operation of the 

9 NGCC alternative were evaluated to measure their possible effects on current socioeconomic 

10 conditions.

11 Scaling from GEIS estimates, the construction workforce would peak at 2,650 workers. Exelon 

12 estimated 800 workers at the peak of construction (Exelon 2011). Exelon’s estimate appears to 

13 be reasonable and is consistent with trends toward lowering labor costs by reducing the size of 

14 plant workforces. Therefore, Exelon’s estimate of 800 workers is used throughout this analysis. 

15 The relative economic impact of this many workers on the local economy and tax base would 

16 vary, with the greatest impacts occurring in the communities where the majority of construction 

17 workers would reside and spend their income. As a result, local communities could experience 

18 a short-term economic “boom” from increased tax revenue and income generated by 

19 construction expenditures and the increased demand for temporary (rental) housing and 

20 business services. Some construction workers could relocate in order to be closer to the 

21 construction work site. However, given the proximity of many existing power plants to 

22 metropolitan areas, workers could commute to the construction site, thereby reducing the need 

23 for rental housing.

24 After completing the installation of the four-unit NGCC plant, local communities could 

25 experience a return to pre-construction economic conditions. Based on this information and 

26 given the number of construction workers, socioeconomic impacts during construction in 

27 communities near the new NGCC site could range from SMALL to MODERATE.

28 Scaling from GEIS estimates, the plant operations workforce would be 331 workers. Exelon 

29 estimated a plant operations workforce of approximately 45 workers (Exelon 2011). Exelon’s

30 estimate appears to be reasonable and is consistent with trends toward lowering labor costs by 

31 reducing the size of plant operations workforces. Therefore, Exelon’s estimate of 45 workers is 

32 used throughout this analysis. The reduction in employment at LGS from operations to 

33 decommissioning and shut down could affect property tax revenue and income in local 

34 communities and businesses. In addition, the permanent housing market could also experience 

35 increased vacancies and decreased prices if operations workers and their families move out of 

36 the region. However, the amount of property taxes paid to local jurisdictions under the NGCC 

37 alternative may increase if additional land is required to support this alternative. Based on the 

38 above discussion, socioeconomic impacts during operations could range from SMALL to 

39 MODERATE.
Environmental Impacts of Alternatives

8-14

1 8.1.9. Transportation

2 Transportation impacts associated with construction and operation of a four-unit, NGCC power 

3 plant would consist of commuting workers and truck deliveries of construction materials to the 

4 power plant site. During periods of peak construction activity, up to 800 workers could be 

5 commuting daily to the site (Exelon 2011), as described in Section 8.1.8. Workers commuting 

6 to the construction site would arrive by site access roads, and the volume of traffic on nearby 

7 roads could increase substantially during shift changes. In addition to commuting workers, 

8 trucks would be transporting construction materials and equipment to the worksite, thus 

9 increasing the amount of traffic on local roads. The increase in vehicular traffic would peak 

10 during shift changes, resulting in temporary levels of service impacts and delays at 

11 intersections. Pipeline construction and modification to existing natural gas pipeline systems 

12 could also have a temporary impact. Some power plant components and materials could also 

13 be delivered by train or barge, depending on location. Train deliveries could cause additional 

14 traffic delays at railroad crossings. Based on this information, traffic-related transportation 

15 impacts during construction could range from SMALL to MODERATE.

16 Traffic-related transportation impacts would be greatly reduced after completing the installation 

17 of the new NGCC units. Transportation impacts would include daily commuting by the operating 

18 workforce, equipment and materials deliveries, and the removal of commercial waste material to 

19 offsite disposal or recycling facilities by truck. The NGCC alternative is estimated to require an

20 operational workforce of 45 (Exelon 2011), as described in Section 8.1.8. Since fuel is 

21 transported by pipeline, the transportation infrastructure would experience little to no increased 

22 traffic from plant operations. Overall, transportation impacts would be SMALL during power 

23 plant operations.

24 8.1.10. Aesthetics

25 The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC 

26 alternative and the surrounding landscape and the visibility of the new NGCC plant at an 

27 existing power plant site. During construction, all of the clearing and excavation would occur on 

28 the existing power plant site. These activities could be visible from offsite roads. Since the 

29 existing power plant site would already appear industrial, construction of the NGCC power plant 

30 would appear similar to other ongoing onsite activities. The power block of the NGCC 

31 alternative could look similar to the existing power plant.

32 The four NGCC units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to 

33 150 ft (46 m) tall with two cooling towers over 500 ft (152 m) high (Exelon 2011). The facility 

34 would be visible off site during daylight hours, and some structures may require aircraft warning 

35 lights. The addition of mechanical draft cooling towers and associated condensate plumes 

36 could add to the visual impact. Noise generated during NGCC power plant operations would be 

37 limited to routine industrial processes and communications. Pipelines delivering natural gas fuel 

38 could be audible offsite near gas compressor stations.

39 In general, given the industrial appearance of the existing power plant site, the new NGCC 

40 power plant would blend in with the surroundings and the NGCC power plant could be similar in 

41 appearance to the existing power plant. Aesthetic changes therefore would be limited to the 

42 immediate vicinity of the existing power plant site, and any impacts would be SMALL depending 

43 on its location and surroundings.
Environmental Impacts of Alternatives

8-15

1 8.1.11. Historic and Archaeological Resources

2 To consider effects on historic and archaeological resources, any areas potentially affected by 

3 the construction of the NGCC alternative would need to be surveyed to identify and record

4 historic and archaeological resources. An inventory of a previously disturbed former plant 

5 (brownfield) site may still be necessary if the site has not been previously surveyed or to verify 

6 the level of disturbance and evaluate the potential for intact subsurface resources. Plant 

7 operators would need to survey all areas associated with operation of the alternative 

8 (e.g., a new pipeline, roads, transmission corridors, other ROWs). Any resources found in these 

9 surveys would need to be evaluated for eligibility on the National Register of Historic Properties 

10 (NRHP), and mitigation of adverse effects would need to be addressed if eligible resources 

11 were encountered. Areas with the greatest sensitivity should be avoided. Visual impacts on 

12 significant cultural resources—such as the viewsheds of historic properties near the site—also 

13 should be assessed.

14 The potential for impacts on historic and archaeological resources from the NGCC alternative 

15 would vary greatly depending on the location of the proposed site. Given that the preference is 

16 to use a previously disturbed former plant site, avoidance of significant historic and 

17 archaeological resources should be possible and effectively managed under current laws and 

18 regulations. However, historic and archaeological resources could potentially be affected, 

19 depending on the resource richness of the land required for a new pipeline. Therefore, the 

20 impacts on historic and archaeological resources from the NGCC alternative would range from 

21 SMALL to MODERATE.

22 8.1.12. Environmental Justice

23 The environmental justice impact analysis evaluates the potential for disproportionately high and 

24 adverse human health, environmental, and socioeconomic effects on minority and low-income 

25 populations that could result from the construction and operation of a new power plant. Minority 

26 and low-income populations are subsets of the general public living near the proposed power 

27 plant site.

28 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 

29 impacts on human health. Disproportionately high and adverse human health effects occur 

30 when the risk or rate of exposure to an environmental hazard for a minority or low-income 

31 population is significant and exceeds the risk or exposure rate for the general population or for 

32 another appropriate comparison group. Disproportionately high environmental effects refer to 

33 impacts or risk of impact on the natural or physical environment in a minority or low-income 

34 community that are significant and appreciably exceed the environmental impact on the larger 

35 community. Such effects may include biological, cultural, economic, or social impacts. For 

36 example, increased demand for rental housing during replacement power plant construction 

37 could disproportionately affect low-income populations that rely on the previously inexpensive 

38 rental housing market. 

39 Potential impacts to minority and low-income populations would mostly consist of environmental 

40 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

41 housing impacts). Noise and dust impacts during construction would be short term and 

42 primarily limited to onsite activities. Minority and low-income populations residing along site 

43 access roads would be directly affected by increased commuter vehicle and truck traffic. 

44 However, because of the temporary nature of construction, these effects are not likely to be high 

45 and adverse and would be contained to a limited time period during certain hours of the day. 

46 Increased demand for rental housing during construction could cause rental costs to rise 

47 disproportionately affecting low-income populations living near the site who rely on inexpensive 
Environmental Impacts of Alternatives

8-16

1 housing. However, given the proximity of some existing power plant sites to metropolitan areas, 

2 workers could commute to the construction site, thereby reducing the need for rental housing. 

3 Emissions from the operation of a NGCC plant could affect minority and low-income populations 

4 as well as the general population living in the vicinity of the new power plant. However, all 

5 would be exposed to the same potential effects from NGCC power plant operations, and any 

6 impacts would depend on the magnitude of the change in ambient air quality conditions. 

7 Permitted air emissions are expected to remain within regulatory standards.

8 Based on this information and the analysis of human health and environmental impacts 

9 presented in this SEIS, the construction and operation of a new NGCC power plant would not 

10 have disproportionately high and adverse human health and environmental effects on minority 

11 and low-income populations.

12 8.1.13. Waste Management

13 During the construction stage of the NGCC generation alternative, land clearing and other 

14 construction activities would generate waste that could be recycled, disposed of on site, or 

15 shipped to an offsite waste disposal facility. Because the alternative would be constructed at 

16 power plant sites with existing infrastructure, the amount of wastes produced during land 

17 clearing would be reduced.

18 During the operational stage, spent selective catalytic reduction (SCR) catalysts, which are used 

19 to control NOx emissions from natural gas−fired plants, would make up most of the waste 

20 generated by this alternative (see Air Quality, Section 8.1.1)

21 According to the GEIS (NRC 1996), a natural gas-fired plant would generate minimal waste. 

22 Waste impacts therefore would be SMALL for an NGCC alternative.

23 Table 8–2. Summary of Environmental Impacts of the NGCC Alternative Compared to 

24 Continued Operation of the Existing LGS

New NGCC at an Existing 

Power Plant Site

Continued LGS 

Operation

Air Quality SMALL to MODERATE SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Aquatic Resources SMALL SMALL

Terrestrial Resources SMALL SMALL

Human Health SMALL SMALL

Land Use SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics SMALL SMALL

Historic and Archaeological SMALL to MODERATE SMALL

Waste Management SMALL SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS.
Environmental Impacts of Alternatives

8-17

1 8.2. Supercritical Pulverized Coal-Fired Alternative

2 In this section, the NRC evaluates the environmental impacts of a supercritical pulverized 

3 coal-fired alternative to the continued operation of LGS. In the Commonwealth of Pennsylvania, 

4 48 percent of electricity was generated using coal-fired power plants in 2010 (EIA 2012). 

5 Throughout PJM, coal-fired units provided 47 percent of electricity in 2011 (Monitoring Analytics 

6 2012). As noted by EIA in its Annual Energy Outlook (EIA 2011b), coal-fired generation 

7 historically has been the largest source of electricity in the United States and is expected to 

8 remain so through 2035. Baseload coal units have proven their reliability and can routinely 

9 sustain capacity factors of 85 percent or greater. Among the various boiler designs available, 

10 pulverized coal boilers producing supercritical steam (SCPC boilers) are the most likely variant 

11 for a coal-fired alternative given their generally high thermal efficiencies and overall reliability.

12 While nuclear reactors, on average, operate with capacity factors above 90 percent, the new 

13 SCPC coal-fired power plant would operate with roughly an 85 percent capacity factor. Despite 

14 the slightly lower capacity factor, a SCPC plant would be capable of providing adequate 

15 replacement power for a nuclear plant for the purposes of this NEPA analysis.

16 A myriad of sizes of pulverized coal boilers and steam turbine generators (STGs) are available; 

17 however, the staff presumes that four equal-sized boiler/STG powertrains, operating 

18 independently and simultaneously, would likely be used to match the power output of LGS. To 

19 complete this analysis, the staff presumes that all powertrains would have the same features, 

20 operate at generally the same conditions, have similar impacts on the environment, and be 

21 equipped with the same pollution-control devices such that once all parasitic loads are 

22 overcome, the net power available would be equal to 2,120 MWe. The staff assumes that 

23 6 percent of an SCPC boiler’s gross capacity is needed to supply typical parasitic loads (plant 

24 operation plus control devices for criteria pollutants to meet New Source Performance 

25 Standards). Introducing controls for GHG emissions (i.e., CCS) would cause the parasitic load 

26 to increase to 27 percent of the boiler’s gross rated capacity (NETL 2010). However, because 

27 of uncertainty regarding future GHG regulations and the limited real-world experience in CCS at 

28 utility-scale power plants, parasitic loads associated with CCS are not considered. Various 

29 bituminous coal sources are available to coal-fired power plants in Pennsylvania. EIA reports 

30 that, in 2008, Pennsylvania produced electricity from coal with heating values of 11,549 British 

31 thermal units per pound (Btu/lb), sulfur content of 2.07 percent, and ash of 16.29 percent 

32 (EIA 2010a). For the purpose of this evaluation, the NRC presumes that coal burned in 2008 

33 will be representative of coal that would be burned in a coal-fired alternative regardless of where 

34 it was located. Approximately 74 percent of the coal burned in Pennsylvania in 2008 came from 

35 mines in Pennsylvania. West Virginia, Wyoming, and Ohio supplied most of the remaining coal 

36 (EIA 2010a). Bituminous coals from Appalachian mines have CO2 emission factors ranging 

37 from 202.8 to 210.2 lb per million Btu of heat input (Hong and Slatick 1994). 
Environmental Impacts of Alternatives

8-18

1 Exelon determined that the current LGS site 

2 was not viable to accommodate a coal-fired 

3 alternative with net generating capacity 

4 sufficient to meet the power production of 

5 LGS because of limited space on the LGS 

6 site, as explained in Section 8.0

7 (Exelon 2011). The staff concurs with that 

8 assessment and the analysis of the impacts 

9 of the coal-fired alternative assumes that the 

10 SCPC coal-fired power plant would be sited 

11 at an existing power plant site to take 

12 advantage of existing infrastructure. The site 

13 could be located in Pennsylvania or 

14 elsewhere in PJM. 

15 It is reasonable to assume that a coal-fired 

16 alternative would use supercritical steam 

17 (see text box). Supercritical steam 

18 technologies are increasingly common in 

19 new coal-fired plants. They are 

20 commercially available and feasible. 

21 Supercritical plants operate at higher 

22 temperatures and pressures than older 

23 subcritical coal-fired plants and, therefore, 

24 can attain higher thermal efficiencies. While 

25 supercritical facilities are more expensive to 

26 construct than subcritical facilities, they consume less fuel for a given output, reducing 

27 environmental impacts throughout the fuel life cycle. The staff expects that a new, supercritical 

28 coal-fired plant would operate at a heat rate of 8,844 Btu/kWh (EIA 2010b), or approximately 38

29 to 39 percent thermal efficiency. However, heat inputs could be less, depending on the coal 

30 source and whether fuel blending is practiced in order to remain compliant with emission 

31 limitations.

32 SCPC coal-fired power plants are currently commercially available and currently are feasible 

33 alternatives to LGS license renewal. The overall environmental impacts of a coal-fired 

34 alternative, as well as the environmental impacts of proposed LGS license renewal, are shown 

35 in Table 8–3. Additional details of the impacts on individual resources of the coal-fired 

36 alternative are provided in subsequent sections.

37 8.2.1. Air Quality

38 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

39 Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control 

40 Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards 

41 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 

42 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment 

43 with respect to ozone and PM2.5 (40 CFR 81.339).

44 A new SCPC generating plant would qualify as a new major-emitting industrial facility and would 

45 be subject to PSD under requirements of the CAA (EPA 2012a). The PADEP has adopted 

46 25 Pa. Code Chapter 127, which implements the EPA’s PSD review. The SCPC plant would 

47 need to comply with the standards of performance for electric utility steam generating units set 

48 forth in 40 CFR Part 60 Subpart Da.

Supercritical Steam

“Supercritical” refers to the thermodynamic 

properties of the steam being produced. Steam 

whose temperature and pressure is below water’s 

“critical point” (3,200 pounds per square inch 

absolute [psia; 221 bar] and 705 °F [374 °C]) is 

subcritical. Subcritical steam forms as water boils 

and both liquid and gas phases are observable in 

the steam. The majority of coal boilers currently 

operating in the United States produce subcritical 

steam with pressures around 2,400 psia (165 bar) 

and temperatures as high as 1,050 °F (566 °C). 

Above the critical point pressure, water expands 

rather than boils, and the liquid and gaseous 

phases of water are indistinguishable in the 

supercritical steam that results. More than 

150 coal boilers currently operating in the United 

States produce supercritical steam with pressures 

between 3,300–3,500 psia (228 to 241 bar) and 

temperatures between 1,000–1,100 °F (538–

593 °C). Ultrasupercritical boilers produce steam 

at pressures above 3,600 psia (248 bar) and 

temperatures exceeding 1,100 °F (593 °C). There 

are only a few of these boilers in operation 

worldwide, and none in the United States.
Environmental Impacts of Alternatives

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1 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 

2 including the review of the new sources that may affect visibility in any Federal Class I area. 

3 If an SCPC alternative was located close to a mandatory Class I area, additional air pollution 

4 control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory 

5 Class I Federal areas within 50 miles (80 km) of the LGS site. There are a total of 

6 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: 

7 Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 

8 A new SCPC plant would have to comply with Title IV of the CAA (42 USC §7651) reduction 

9 requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause 

10 of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the 

11 existing plants and a system of SO2 emission allowances that can be used, sold, or saved for 

12 future use by the new plants.

13 More recently, the EPA has promulgated additional rules and requirements for certain fossil-fuel 

14 based power plants, such as coal. The Cross-State Air Pollution Rule (CSAPR), the Prevention 

15 of Significant Deterioration and Title V Greenhouse Gas (GHG) Tailoring Rule, and the Mercury 

16 and Air Toxics Standards (MATS) for Power Plants impose several additional standards to limit 

17 ozone, particulate, mercury, and GHG emissions from fossil-fuel based power plants 

18 (EPA 2012c). A new SCPC plant would be subject to these additional rules and regulations. 

19 The EPA has developed standard emission factors that relate the quantity of released air 

20 pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the 

21 staff projects the following air emissions for the SCPC alternative:

22 • sulfur oxides (SOx) – 14,876 tons (13,495 MT) per year,

23 • nitrogen oxides (NOx) – 1,891 tons (1,716 MT) per year,

24 • carbon monoxide (CO) – 1,891 tons (1,716 MT) per year,

25 • PM10 – 1,232 tons (1,118 MT) per year,

26 • PM2.5 – 616 tons (559 MT) per year 

27 • carbon dioxide (CO2) – up to 18,363,843 tons (16,659,678 MT) per year, and

28 • mercury (Hg) – 0.31 tons (0.28 MT) per year.

29 The above emission estimates assume that the SCPC plant implements certain pollution control 

30 devices, including wet calcium carbonate scrubbers for SO2 control (operating at 95 percent 

31 removal efficiency), low-NOx burners with overfire air and selective catalytic reduction for 

32 nitrogen oxide controls capable of attaining a NOx removal of 86 percent, and fabric particulate 

33 filters with 99.9 percent removal efficiency.

34 Activities associated with the construction of the new SCPC plant would cause some additional, 

35 temporary air effects as a result of equipment emissions and fugitive dust from operation of the 

36 earth-moving and material-handling equipment. Emissions from workers’ vehicles and 

37 motorized construction equipment exhaust would be temporary. The construction crews would 

38 use dust-control practices to control and reduce fugitive dust. The staff concludes that the 

39 impact of vehicle exhaust emissions and fugitive dust from operation of the earth-moving and 

40 material-handling equipment would be SMALL. 

41 Greenhouse Gas Emissions

42 The largest anthropogenic source of CO2 emissions is the combustion of fossil fuels, especially 

43 coal. After a thorough examination of the scientific evidence and careful consideration of public 

44 comments, the EPA announced on December 7, 2009, that GHGs threaten the public health 

45 and welfare of the American people and meet the CAA definition of air pollutants. The 

46 construction and operation of the coal-fired alternative would emit GHGs that likely contribute to 

47 climate change.
Environmental Impacts of Alternatives

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1 Greenhouse gas emissions from the construction of a coal-fired alternative would result 

2 primarily from the consumption of fossil fuels in the engines of construction vehicles and 

3 equipment, workforce vehicles used in commuting to and from the work site, and delivery 

4 vehicles. All such impacts would be temporary. 

5 The staff estimates that uncontrolled emissions of CO2-e (carbon dioxide equivalents) from 

6 operation of the coal-fired alternative would amount to 18.36 million tons per year (16.66 million 

7 metric tons per year). From a life-cycle perspective, Sovacool (2008) found that coal-burning 

8 plants can have GHG footprints as high as 1,050 grams of carbon dioxide equivalent per kWh. 

9 For comparison, nuclear facilities and NGCC facilities have life-cycle GHG footprints of 

10 66 grams of CO2-e/kWh and 443 grams of CO2-e/kWh, respectively. Although coal combustion

11 in the boilers would be the primary source, other miscellaneous ancillary sources, such as truck 

12 and rail deliveries of materials to the site, commuting of the workforce, and deliveries of wastes 

13 to offsite disposal or recycling facilities, would contribute to the CO2-e emissions from continued 

14 operations.

15 NETL estimates that further development could yield technologies that could capture and 

16 remove as much as 90 percent of the CO2 from the exhausts of SCPC boilers. However, NETL 

17 also estimates that such equipment imposes a significant parasitic load that would result in 

18 a power production capacity decrease of approximately 27 percent (NETL 2010). In addition, 

19 permanent sequestering of the CO2 would involve removing impurities (including water) and 

20 pressurizing it to meet pipeline specifications to transfer the gas, by pipeline, to acceptable 

21 geologic formations. Even when opportunities exist to use the CO2 for enhanced oil recovery 

22 (rather than simply disposing of the CO2 in geologic formations), permanent disposal costs 

23 could be substantial, especially if the SCPC units are far removed from acceptable geologic 

24 formations. With CCS in place, the coal-fired alternative would release 1.84 million tons of 

25 CO2 per year (1.67 million metric tons per year). Without CCS in place, the staff’s projected CO2 

26 emissions for the SCPC alternative would be 18,363,843 tons (16,659,678 MT) per year

27 The overall impact from the releases of GHGs of a coal-fired alternative would be MODERATE. 

28 Construction impacts would be temporary, but GHG emissions during operation would be 

29 noticeable.

30 Conclusion

31 Based on the above discussion, the overall air emissions and associated quality impacts from a 

32 new SCPC plant located at the LGS site would be MODERATE, primarily because of the 

33 noticeable impact during operations. 

34 8.2.2. Groundwater Resources

35 Construction activities associated with the SCPC alternative could require more extensive 

36 groundwater dewatering as compared to the NGCC alternative, depending on the hydrogeologic 

37 conditions of the selected site. This is because of the more extensive excavation that would be 

38 required for the SCPC power block and the onsite disposal facility. Nevertheless, engineering 

39 measures, as described in Section 8.1.2, can be used to minimize impacts to facilitate 

40 construction. Facility construction would increase the amount of impervious surface at the site 

41 location and alter the subsurface strata because of excavation work and the placement of 

42 backfill following facility completion. At some sites, this could cause a localized decline in 

43 water-table elevation in a surficial aquifer, if present. However, recharge basins incorporated 

44 into the stormwater management system design can make such alterations undetectable at the 

45 site boundary. Below-grade portions of a new SCPC plant also could alter the direction of 

46 groundwater flow beneath a site, although such effects would likely be very localized at most 

47 site locations. Finally, application of BMPs in accordance with a state-issued NPDES general 
Environmental Impacts of Alternatives

8-21

1 permit, including appropriate waste management, water discharge, and spill prevention 

2 practices, would prevent or minimize any groundwater quality impacts during construction. 

3 During the construction period, groundwater could be used to provide water for potable and 

4 sanitary uses, concrete production, dust suppression, and soil compaction. However, it is more 

5 likely that water would be supplied via a temporary utility connection, if available, or trucked to 

6 the point of use from offsite sources. The SPCP alternative would require a peak construction 

7 workforce of 2,500 (Exelon 2011), as described in Section 8.2.8. While the potential demands 

8 for groundwater based on this workforce combined with construction uses might result in water 

9 demands nearing 100 gpm (380 L/min) during the peak construction period, the staff determined 

10 that any impacts would be very temporary and localized.

11 For SCPC plant operations, the NRC assumed that the SCPC alternative would entail the same 

12 relative ratio of groundwater use to surface water use as that used at LGS Units 1 and 2. This 

13 includes the use of groundwater for service water makeup and potable and sanitary uses. 

14 Consequently, it is expected that total groundwater usage and potential aquifer effects would be 

15 much less under this alternative than those under current LGS operations. This is because of 

16 the smaller number of auxiliary systems requiring groundwater and the much smaller workforce 

17 under this alternative. The only mechanism identified that could adversely affect groundwater 

18 quality under normal operations would be operation of the disposal facility. However, the

19 leaching of contaminants from the fly ash and scrubber sludge and impacts to groundwater can 

20 be minimized in modern facilities with protective barriers, disposal cell liners, and leachate 

21 collection and treatment systems, along with groundwater monitoring systems. Therefore, 

22 based on the above assessment, the impacts on groundwater use and quality under this 

23 alternative would be SMALL. 

24 8.2.3. Surface Water Resources

25 Impacts from construction activities associated with the SCPC alternative on surface water 

26 resources would be expected to be similar to but somewhat greater than those under the NGCC 

27 alternative. This is attributable to the additional land required for construction of the power block 

28 and for excavation and construction of an onsite disposal facility for coal ash and scrubber 

29 sludge. However, additional offsite impacts, including hydrologic changes in affected streams 

30 and contaminant runoff, would occur from coal mining (see Section 8.2.7). At the SCPC site, 

31 some temporary impacts to surface water quality may result from increased sediment loading 

32 and from any pollutants in stormwater runoff from disturbed areas and from dredging activities. 

33 There also would be the potential for water quality effects to occur from the extension or 

34 refurbishment of a rail spur to transport coal to the site location. Nevertheless, as described in 

35 Section 8.1.3, water quality impacts would be minimized by the application of BMPs and 

36 compliance with state-issued NPDES permits. Any dredging would be conducted under 

37 a permit from the COE requiring the implementation of BMPs to minimize impacts. 

38 During operations, the SCPC alternative would use slightly less water than LGS because of the 

39 greater generation-efficiency of the SCPC technology. Therefore, the water resources impact 

40 assessment presented in Section 4.3.2 of this SEIS generally applies to the SCPC alternative. 

41 The NRC assumed that water treatment additives for the SCPC alternative would be essentially 

42 identical to LGS. Existing intake and discharge infrastructure would be used at the selected 

43 power plant site but it could require refurbishment or expansion. Similar to LGS, surface water 

44 withdrawals would be subject to applicable state water allocation requirements, and effluent 

45 discharges and stormwater discharges associated with industrial activity would be subject to 

46 a state-issued NPDES permit under this alternative. The NRC further assumes that the SCPC 

47 plant and waste disposal facility would be operated in accordance with appropriate management 

48 plans with adherence to appropriate BMPs and procedures to minimize the release of 
Environmental Impacts of Alternatives

8-22

1 non-nuclear fuels, chemicals, and other materials to soil, surface water, and groundwater (see 

2 Section 8.1.3). As a result, the overall impacts on surface water use and quality from 

3 construction and operations under the SCPC alternative would be SMALL. 

4 8.2.4. Aquatic Resources

5 Construction activities for the SCPC alternative (such as construction of heavy-haul roads and 

6 the power block) could affect drainage areas or other onsite aquatic features. Minimal impacts 

7 on aquatic ecology resources are expected because the plant operator would likely implement 

8 BMPs to minimize erosion and sedimentation. Stormwater control measures, which would be 

9 required to comply with Pennsylvania NPDES permitting, would minimize the flow of disturbed 

10 soils into aquatic features. Depending on the available infrastructure at the selected site, the 

11 SCPC alternative may require modification or expansion of the existing intake or discharge 

12 structures, or construction of new intake and discharge structures. Dredging activities that 

13 result from infrastructure construction would require BMPs for in-water work to minimize 

14 sedimentation and erosion. Because of the short-term nature of the dredging activities, the 

15 hydrological alterations to aquatic habitats likely would be localized and temporary.

16 During operations, the SCPC alternative would require slightly less cooling water to be 

17 withdrawn from the Schuylkill River or other similar water body than required for LGS Units 1 

18 and 2. The number of fish and other aquatic resources affected by cooling water intake and 

19 discharge operations, such as entrainment, impingement, and thermal stress, would be equal or 

20 less for an SCPC alternative compared to LGS. The cooling system for a new SCPC plant 

21 would have similar chemical discharges as LGS, but the SCPC plant would emit small amounts 

22 of ash and particulates that would settle onto the river surface and introduce a new source of 

23 pollutants as described in Section 8.2.1.

24 The impacts on aquatic ecology would be minor because construction activities would require 

25 BMPs and stormwater management permits, and because the surface water withdrawal and 

26 discharge for this alternative would be slightly less compared to LGS Units 1 and 2. Therefore, 

27 impacts on aquatic ecology would be SMALL.

28 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 

29 of an SCPC plant would not adversely affect any Federally listed species or adversely modify or 

30 destroy designated critical habitat. Consultation with NMFS under the Magnuson-Stevens Act 

31 would require the NRC to evaluate impacts to EFH. NMFS would provide conservation

32 recommendations if there would be adverse impacts to EFH. Coordination with state natural 

33 resource agencies would further ensure that the plant operator would take appropriate steps to 

34 avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other 

35 protected species and habitats. Consequently, the impacts of construction and operation on 

36 protected species and habitats would be SMALL. 

37 8.2.5. Terrestrial Resources

38 Construction of an SCPC plant would require approximately 280 ac (113 ha), as described in 

39 Section 8.2.7. The SCPC alternative may require up to 46,600 ac (18,860 ha) of additional land 

40 for coal mining and processing (NRC 1996). Approximately 464 ac (188 ha) of land also would 

41 be required for disposal of ash and scrubber sludge (Exelon 2011). However, land for disposal 

42 would likely be located on site (see Section 8.2.7). Because of the relatively large land 

43 requirement for the site, a portion of the site would likely be land that had not been previously 

44 disturbed, which would directly affect terrestrial habitat by removing existing vegetative

45 communities and displacing wildlife. The level of direct impacts would vary substantially based 

46 on site selection. Offsite construction would occur mostly on land where coal extraction is 
Environmental Impacts of Alternatives

8-23

1 ongoing. To the extent practicable, Exelon would route the railroad spur along an existing, 

2 previously disturbed railroad corridor. Erosion and sedimentation, fugitive dust, and 

3 construction debris impacts would be minor with implementation of appropriate BMPs

4 (Exelon 2011). Impacts to terrestrial habitats and species from transmission line operation and 

5 corridor vegetation maintenance, and operation of the cooling system would be similar in 

6 magnitude and intensity as those resulting from operating nuclear reactors and would, therefore, 

7 be SMALL (NRC 1996). Because of the potentially large area of undisturbed habitat that could 

8 be affected from construction of an SCPC plant, the impacts of construction on terrestrial 

9 habitats and species could range from SMALL to MODERATE depending on the specific site 

10 location. The impacts of operation would be SMALL.

11 As with the NGCC alternative, consultation with FWS under the ESA would avoid potential 

12 adverse impacts to Federally listed species or adverse modification or destruction of designated 

13 critical habitat. Coordination with state natural resource agencies would further ensure that 

14 Exelon would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats 

15 of conservation concern, and other protected species and habitats. Consequently, the impacts 

16 of construction and operation of an SCPC plant on protected species and habitats would be 

17 SMALL.

18 8.2.6. Human Health

19 Impacts on human health from construction of the SCPC alternative would be similar to impacts 

20 associated with the construction of any major industrial facility. Compliance with worker 

21 protection rules would control those impacts on workers at acceptable levels. Impacts from 

22 construction on the general public would be minimal since limiting active construction area 

23 access to authorized individuals is expected. Therefore, impacts on human health from the 

24 construction of the SCPC alternative would be SMALL.

25 Coal-fired power plants introduce worker risks from coal and limestone mining, coal and 

26 limestone transportation, and disposal of coal combustion residues and scrubber wastes. In 

27 addition, there are public risks from inhalation of stack emissions and the secondary effects of 

28 eating foods grown in areas subject to deposition from plant stacks.

29 Human health risks of coal-fired power plants are described, in general, in Table 8–2 of the 

30 GEIS (NRC 1996). Cancer and emphysema as a result of the inhalation of toxins and 

31 particulates are identified as potential health risks to occupational workers and members of the 

32 public (NRC 1996). The human health risks associated with coal-fired power plants, both for 

33 occupational workers and members of the public, are greater than those of the current LGS 

34 reactors because of exposures to chemicals such as mercury, SOx, NOx, radioactive elements 

35 such as uranium and thorium contained in coal and coal ash, and polycyclic aromatic 

36 hydrocarbon (PAH) compounds, including benzo(a)pyrene. 

37 Regulations restricting emissions enforced by either EPA or delegated state agencies have 

38 reduced potential health effects, but have not entirely eliminated them. These agencies also 

39 impose site-specific emission limits as needed to protect human health. Even if the coal-fired 

40 alternative were located in a nonattainment area, emission controls and trading or offset 

41 mechanisms could prevent further regional degradation; however, local effects could be visible. 

42 Many of the byproducts of coal combustion responsible for health effects are largely controlled, 

43 captured, or converted in modern power plants, although some level of health effects may 

44 remain.

45 Aside from emissions impacts, the coal-fired alternative introduces the risk of coal pile fires and 

46 for those plants that manage coal combustion residue liquids and sludge in waste 

47 impoundments, the release of the waste may result because of a failure of the impoundment. 
Environmental Impacts of Alternatives

8-24

1 Good housekeeping practices to control coal dust greatly reduce the potential for coal dust 

2 explosions or coal pile fires. Although there have been several instances in recent years, 

3 sludge impoundment failures are still rare. Free water also could be recovered from such waste 

4 streams and recycled and the solid or semi-solid portions removed to permitted offsite disposal 

5 facilities.

6 Overall, given extensive health-based regulation and controls likely to be imposed as permit 

7 conditions applicable to waste handling and disposal, the staff expects human health impacts 

8 from operation of the coal-fired alternative at an alternate site to be SMALL.

9 8.2.7. Land Use

10 The GEIS generically evaluates the impact of constructing and operating various replacement 

11 power plant alternatives on land use, both on and off each power plant site. The analysis of 

12 land-use impacts focuses on the amount of land area that would be affected by the construction 

13 and operation of an SCPC power plant at an existing power plant site.

14 Based on scaled GEIS estimates, more than 3,800 ac (1,540 ha) of land could be needed 

15 to support a coal-fired alternative to replace the LGS. This amount of land use would include 

16 other plant structures and associated infrastructure and is unlikely to exceed the 3,800 ac 

17 (1,540 ha) estimate, excluding land needed for coal mining and processing. Exelon estimated 

18 280 ac (113 ha) for new unit construction (Exelon 2011). The NRC determined that this 

19 estimate is reasonable because it is consistent with land requirements for modern coal-fired 

20 facilities. It is expected that the SCPC alternative would be located at an existing power plant 

21 site or otherwise disturbed industrial site, and thus the land-use impacts from construction would 

22 range from SMALL to MODERATE. Depending on existing power plant infrastructure, 

23 additional land may be needed for frequent coal and limestone deliveries by rail or barge.

24 Offsite land-use impacts would occur from coal mining, in addition to land-use impacts from the 

25 construction and operation of the new power plant. Using the GEIS figure, the SCPC alternative 

26 might require up to 49,600 ac (20,100 ha) of land for coal mining and waste disposal during 

27 power plant operations. However, much of the land in existing coal mining areas already has 

28 experienced some level of disturbance. An additional 464 ac (188 ha) of land would be required 

29 for disposal of ash and scrubber sludge (Exelon 2011). It is likely that most of the land needed 

30 for disposal would be found within the 22,000 ac (8,900 ha) requirement estimated in the GEIS.

31 The elimination of uranium fuel for the LGS could partially offset some, but not all, of the land 

32 requirements for the SCPC alternative. Scaling from GEIS estimates, approximately 1,640 ac 

33 (660 ha) no longer would be needed for mining and processing uranium during the operating life 

34 of the SCPC plant. Since a substantial amount of land could be converted for coal and 

35 limestone delivery and waste disposal, land-use impacts could range from SMALL to 

36 MODERATE.

37 8.2.8. Socioeconomics

38 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

39 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

40 socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for 

41 permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

42 operation of the SCPC alternative were evaluated to measure their possible effects on current 

43 socioeconomic conditions.

44 Scaling from GEIS estimates, the construction workforce would peak at 5,638 workers. Exelon

45 estimated 2,500 workers at the peak of construction (Exelon 2011). This estimate appears to 
Environmental Impacts of Alternatives

8-25

1 be reasonable and is consistent with trends toward lowering labor costs by reducing the size of 

2 plant workforces. Therefore, Exelon’s estimate of 2,500 workers is used throughout this 

3 analysis. The relative economic impact of this many workers on the local economy and tax 

4 base would vary, with the greatest impacts occurring in communities where the majority of 

5 construction workers reside and spend their income. As a result, local communities could 

6 experience a short-term “boom” from increased tax revenue and income generated by 

7 construction expenditures and the increased demand for temporary (rental) housing and 

8 business services. Some construction workers could relocate in order to be closer to the 

9 construction work site. However, given the proximity of many existing power plants to 

10 metropolitan areas, workers could commute to the construction site, thereby reducing the need 

11 for rental housing. After completing the installation of the subcritical coal-fired power plant, local

12 communities could experience a return to pre-construction economic conditions. Based on this 

13 information and given the number of construction workers, socioeconomic impacts during 

14 construction in local communities could range from SMALL to MODERATE.

15 Scaling from GEIS estimates, the plant operations workforce would be 564 workers. Exelon

16 estimated a plant operations workforce of approximately 141 workers (Exelon 2011). This 

17 estimate appears to be reasonable and is consistent with trends toward lowering labor costs by 

18 reducing the size of plant operations workforces. Therefore, Exelon’s estimate of 141 workers 

19 is used throughout this analysis. This alternative would result in a loss of approximately 

20 700 relatively high-paying jobs at LGS, with a corresponding reduction in purchasing activity and 

21 tax contributions to the regional economy. In addition, the permanent housing market also 

22 could experience increased vacancies and decreased prices if operations workers and their 

23 families move out of the region. However, a larger amount of property taxes may be paid to 

24 local jurisdictions under the SCPC alternative as more land may be required for coal-fired power 

25 plant operations than LGS. Therefore, socioeconomic impacts during operations could range 

26 from SMALL to MODERATE. 

27 8.2.9. Transportation

28 Transportation impacts associated with construction and operation of a four-unit, SCPC power 

29 plant would consist of commuting workers and truck deliveries of construction materials to the 

30 power plant site. During periods of peak construction activity, up to 2,500 workers could be 

31 commuting daily to the site (Exelon 2011), as described in Section 8.2.8. Workers commuting 

32 to the construction site would arrive by site access roads and the volume of traffic on nearby 

33 roads could increase substantially during shift changes. In addition to commuting workers, 

34 trucks would be transporting construction materials and equipment to the worksite, thus 

35 increasing the amount of traffic on local roads. The increase in vehicular traffic would peak 

36 during shift changes, resulting in temporary levels of service impacts and delays at 

37 intersections. Some power plant components and materials could also be delivered by train or 

38 barge, depending on location. Train deliveries could cause additional traffic delays at railroad 

39 crossings. Based on this information, traffic-related transportation impacts during construction 

40 could range from MODERATE to LARGE.

41 Traffic-related transportation impacts on local roads would be greatly reduced after the 

42 completion of the power plant. Transportation impacts would include daily commuting by the 

43 operating workforce, equipment and materials deliveries, and the removal of commercial waste 

44 material to offsite disposal or recycling facilities by truck. During operations, the estimated 

45 number of operations workers commuting to and from the power plant would be 141 workers 

46 (Exelon 2011), as described in Section 8.2.8. The increase in traffic on roadways would peak 

47 during shift changes, resulting in temporary levels of service impacts and delays at 

48 intersections. Frequent deliveries of coal and limestone by rail would add to the overall 
Environmental Impacts of Alternatives

8-26

1 transportation impact. Onsite coal storage would make it possible to receive several trains per 

2 day. Limestone delivered by rail could also add additional traffic (though considerably less 

3 traffic than that generated by coal deliveries). Coal and limestone delivery and ash removal by

4 rail would cause levels of service impacts on certain roads because of delays at railroad 

5 crossings. Overall, transportation impacts would be SMALL to MODERATE during power plant 

6 operations.

7 8.2.10. Aesthetics

8 The analysis of aesthetic impacts focuses on the degree of contrast between the SCPC 

9 alternative and the surrounding landscape and the visibility of the new SCPC plant at an existing 

10 power plant site. During construction, all of the clearing and excavation would occur on the 

11 existing power plant site. These activities could be visible from offsite roads. The coal-fired 

12 power plant could be approximately 100 ft (30 m) tall, with two to four exhaust stacks several 

13 hundred feet tall with natural-draft cooling towers approximately 400 to 500 ft (122 to 152 m) 

14 in height. The facility would be visible off site during daylight hours, and some structures may 

15 require aircraft warning lights. The condensate plumes from the cooling towers could add to the 

16 visual impact. Noise generated during power plant operations would be limited to routine 

17 industrial processes and communications. 

18 In general, given the industrial appearance of the existing power plant site on which it would be 

19 built, the new SCPC power plant would blend in with the surroundings. The power block of the 

20 SCPC alternative could look very similar to the existing power plant and construction would 

21 appear similar to other ongoing onsite activities. Aesthetic changes would therefore be limited 

22 to the immediate vicinity of the existing power plant site, and any impacts would be SMALL 

23 depending on its location and surroundings.

24 8.2.11. Historic and Archaeological Resources

25 The impacts of the construction of a new SCPC alternative on historic and archaeological 

26 resources are similar to those impacts associated with activities for constructing an NGCC 

27 facility. Any areas potentially affected by the construction of the SCPC alternative would need 

28 to be surveyed to identify and record historic and archaeological resources. An inventory of a 

29 previously disturbed former plant (brownfield) site may still be necessary if the site has not been 

30 previously surveyed or to verify the level of disturbance and evaluate the potential for intact 

31 subsurface resources. Plant operators would need to survey all areas associated with operation 

32 of the alternative (e.g., roads, transmission corridors, other ROWs). Any resources found in 

33 these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse 

34 effects would need to be addressed if eligible resources were encountered. Areas with the 

35 greatest sensitivity should be avoided. Visual impacts on significant cultural resources—such 

36 as the viewsheds of historic properties near the site—should also be assessed.

37 The potential for impacts on historic and archaeological resources from the SCPS alternative 

38 would vary greatly depending on the location of the proposed site. However, given that the 

39 preference is to use a previously disturbed former plant site, avoidance of significant historic 

40 and archaeological resources should be possible and effectively managed under current laws 

41 and regulations. Therefore, the impacts on historic and archaeological resources from the 

42 SCPC alternative would be SMALL.

43 8.2.12. Environmental Justice

44 The environmental justice impact analysis evaluates the potential for disproportionately high and 

45 adverse human health, environmental, and socioeconomic effects on minority and low-income 
Environmental Impacts of Alternatives

8-27

1 populations that could result from the construction and operation of a new power plant. As 

2 previously discussed in Section 8.1.12, such effects may include human health, biological, 

3 cultural, economic, or social impacts. 

4 Potential impacts to minority and low-income populations would mostly consist of environmental 

5 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

6 housing impacts). Noise and dust impacts during construction would be short term and 

7 primarily limited to onsite activities. Minority and low-income populations residing along site 

8 access roads would be directly affected by increased commuter vehicle and truck traffic. 

9 However, because of the temporary nature of construction, these effects are not likely to be high 

10 and adverse and would be contained to a limited time period during certain hours of the day. 

11 Increased demand for rental housing during construction could cause rental costs to rise 

12 disproportionately affecting low-income populations who rely on inexpensive housing. However, 

13 given the proximity of some existing power plant sites to metropolitan areas, workers could 

14 commute to the construction site, thereby reducing the need for rental housing. 

15 Emissions from the operation of a SCPC plant could affect minority and low-income populations 

16 as well as the general population living in the vicinity of the new power plant. However, all 

17 would be exposed to the same potential effects from SCPC power plant operations and any 

18 impacts would depend on the magnitude of the change in ambient air quality conditions. 

19 Permitted air emissions are expected to remain within regulatory standards. 

20 Based on this information and the analysis of human health and environmental impacts 

21 presented in this SEIS, the construction and operation of a new SCPC power plant would not 

22 have disproportionately high and adverse human health and environmental effects on minority 

23 and low-income populations.

24 8.2.13. Waste Management

25 Coal combustion generates several waste streams, including ash (a dry solid) and sludge 

26 (a semi-solid byproduct of emission control system operation). The staff estimates that a 

27 2,120-MW(e) power plant would use approximately 7,340,000 tons (6,659,000 MT) of coal 

28 annually with an ash content of 16.29 percent. This would generate approximately 

29 1,196,000 tons (1,085,000 MT) of ash and 559,000 tons (507,125 MT) of scrubber sludge each 

30 year. About 538,059 tons (488,119 MT) or 45 percent of the ash waste would be marketed for 

31 beneficial use (Exelon 2011). Therefore, approximately 559,000 tons (507,125 MT) of ash 

32 would be disposed of on site if space were available. According to Exelon (2011), disposal of 

33 the ash and sludge would require approximately 464 ac (187 ha) over 20 years. Disposal of the 

34 remaining waste could noticeably affect land use and ground water quality, but with proper siting 

35 and implementation of groundwater monitoring and management practices, in accordance with 

36 25 Pa. Code 290, it would not destabilize important resources. After closure of the waste site 

37 and revegetation, the land could be available for other uses. 

38 The impacts from waste generated during construction would be minor, although the waste 

39 generated during operation of this coal-fired alternative would be MODERATE; the impacts 

40 would be clearly visible, but would not destabilize any important resource. The amount of the 

41 construction waste would be small compared to the amount of waste generated during the 

42 operational stage and much of it could be recycled (i.e, marketed for beneficial use). Therefore, 

43 the staff concludes that the overall waste management impacts from construction and operation 

44 of this alternative would be MODERATE.
Environmental Impacts of Alternatives

8-28

1 Table 8–3. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative 

2 Compared to Continued Operation of LGS

Supercritical Coal-Fired 

Generation Continued LGS Operation

Air Quality MODERATE SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Aquatic Resources SMALL SMALL

Terrestrial Resources SMALL to MODERATE SMALL

Human Health SMALL SMALL

Land Use SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to LARGE SMALL

Aesthetics SMALL SMALL

Historic and Archaeological SMALL SMALL

Waste Management MODERATE SMALL(a)

(a)

As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not 

evaluated in this EIS.

3 8.3. New Nuclear 

4 In this section, the NRC evaluates the environmental impacts of a new nuclear alternative to 

5 LGS. In the Commonwealth of Pennsylvania, 34 percent of electricity was generated using 

6 nuclear power plants in 2010 (EIA 2012). Throughout PJM, nuclear units also provided 

7 34 percent of electricity in 2011 (Monitoring Analytics 2012). As noted by EIA in its Annual 

8 Energy Outlook (EIA 2011b), nuclear generation is expected to account for 3 percent of capacity 

9 additions through 2035. A new nuclear power plant is likely to be similar to LGS in terms of 

10 capacity factor.

11 Several designs are possible for a new nuclear facility. However, a two-unit nuclear power plant 

12 similar to the existing LGS in output is most likely. While two Westinghouse AP1000 reactors 

13 would provide an approximately equivalent output, it is possible that other designs also would 

14 be available. The new nuclear alternative would rely on a closed-cycle cooling system, similar 

15 to the cooling system currently in place at LGS. 

16 In its ER, Exelon determined that the current LGS site was not viable to accommodate a new 

17 nuclear alternative with net generating capacity sufficient to meet the power production of LGS

18 because of insufficient space at the LGS site (ER 2011). Exelon also indicated that a new 

19 nuclear alternative was most likely to be constructed on a site that already hosts a nuclear 

20 power plant. This placement would allow the new nuclear alternative to take advantage of 

21 existing site infrastructure, including transmission lines and some support facilities. The staff

22 concurs that a new nuclear facility is most likely to be sited at the location of an existing nuclear 

23 power plant. Utilities in PJM have expressed interest in either early site permits or combined 

24 licenses for new nuclear facilities at several sites, including Calvert Cliffs (in Maryland), Hope 
Environmental Impacts of Alternatives

8-29

1 Creek (New Jersey), North Anna (Virginia), and Bell Bend (adjacent to the Susquehanna site in 

2 Pennsylvania). 

3 New nuclear power plants are commercially available and feasible alternatives to LGS license 

4 renewal. The overall environmental impacts of a nuclear alternative, as well as the 

5 environmental impacts of proposed LGS license renewal, are shown in Table 8–4. Additional 

6 details of the impacts on individual resources of the new nuclear alternative are provided in 

7 subsequent section.

8 8.3.1. Air Quality

9 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

10 Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control 

11 Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards 

12 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 

13 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment 

14 with respect to ozone and PM2.5 (40 CFR 81.339).

15 A new nuclear generating plant would have similar air emissions to those of the existing LGS 

16 site; air emissions would be primarily from backup diesel generators and boilers as well as 

17 particulates from the cooling towers. As noted in Section 2.2.2.1, Exelon maintains a Title V 

18 operating permit (TVOP-46-00038) for sources of air pollution at the LGS site (Exelon 2011). 

19 Because air emissions would be similar for a new nuclear plant, the staff expects similar air 

20 permitting conditions and regulatory requirements. 

21 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 

22 including the review of the new sources that may affect visibility in any Federal Class I area. If a 

23 new nuclear plant were located close to a mandatory Class I area, additional air pollution control 

24 requirements may be required. As noted in Section 2.2.2.1, there are no Mandatory Class I 

25 Federal areas within 50 miles (80 km) of the LGS site. There are a total of 13 designated 

26 Class 1 Federal areas (40 CFR 81) located in the following PJM states: Kentucky, Michigan, 

27 New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. The following air 

28 emissions were reported by Exelon and are from the year 2011 for the existing LGS site (Exelon 

29 2012). 

30 • sulfur oxides (SOx) – 7.8 T (7.1 MT) per year, 

31 • nitrogen oxide (NOx) – 32.8 T (29.8 MT) per year, 

32 • carbon monoxide (CO) – 24.2 tons (21.9 MT) per year, and

33 • PM10 and PM2.5 – 166.3 T (150.9 MT) per year.

34 The staff expects similar air emissions from a new nuclear plant because these emissions are 

35 primarily from backup diesel generators that would also be used at a new nuclear plant. 

36 Activities associated with the construction of the new nuclear plant would cause some 

37 additional, temporary air effects as a result of equipment emissions and fugitive dust from 

38 operation of the earth-moving and material-handling equipment. Emissions from workers’ 

39 vehicles and motorized construction equipment exhaust would be temporary. The construction 

40 crews could use dust-control practices to control and reduce fugitive dust. The staff concludes 

41 that the impact of vehicle exhaust emissions and fugitive dust from operation of the 

42 earth-moving and material-handling equipment would be SMALL. 

43 Greenhouse Gas Emissions

44 In Chapter 6, the staff discussed the relative GHG emissions of nuclear power compared to 

45 other electric generation technologies. This discussion, where applicable, addressed the 
Environmental Impacts of Alternatives

8-30

1 nuclear lifecycle, including construction and operation. Impacts during construction of this 

2 alternative would result primarily from the consumption of fossil fuels in the engines of 

3 construction vehicles and equipment, workforce vehicles used in commuting to and from the 

4 work site, and delivery vehicles. However, all such impacts would be temporary. 

5 Greenhouse gas emissions from the new nuclear alternative during operation arise primarily 

6 from operation of onsite diesel generators and other auxiliary equipment. For additional 

7 discussion of GHG emissions from nuclear generation, see Chapter 6. 

8 Given the expected workforces, relatively short construction period , and minor GHG emissions 

9 during operation, the overall impact from the releases of GHGs of the new nuclear alternative 

10 would be SMALL.

11 Conclusion

12 The overall air quality impacts of a new nuclear plant located at the LGS site would be 

13 designated as SMALL.

14 8.3.2. Groundwater Resources

15 Under this alternative, deep excavation work on the order of 70 ft (21 m) below ground surface

16 for the nuclear island may require active dewatering during construction. Depending on the site 

17 and local hydrogeology, this dewatering could have localized drawdown effects on local wells 

18 and require the use of cofferdams, sumps, wells, or other methods to address high water-table 

19 conditions. However, grout injection and diaphragm walls can be installed to effectively 

20 eliminate offsite drawdown impacts and reduce the need for dewatering. Facility construction 

21 also would increase the amount of impervious surface at the site location and alter the 

22 subsurface strata because of excavation work and the placement of backfill following facility 

23 completion. This could cause a localized decline in water-table elevation in the surficial aquifer, 

24 but the incorporation of recharge basins into the stormwater management system design can 

25 make such alterations undetectable at the site boundary. Below-grade portions of a new 

26 nuclear power plant also could alter the direction of groundwater flow beneath a site. Such 

27 effects would likely be very localized at most site locations, encompassing the area around the 

28 nuclear island, and would not be expected to affect offsite wells at most sites. In addition, 

29 application of BMPs in accordance with a state-issued NPDES general permit, including 

30 appropriate waste management, water discharge, and spill prevention practices, would prevent 

31 or minimize any groundwater quality impacts during construction. 

32 During the construction period, groundwater could be used to provide potable water for potable 

33 and sanitary uses, concrete production, dust suppression, and soil compaction. However, it is 

34 more likely that water would be supplied via a temporary utility connection, if available, or 

35 trucked to the point of use from offsite sources. Exelon (2011) estimated a peak construction 

36 workforce of 3,650. While the potential demands for groundwater based on this workforce 

37 combined with construction uses might result in water demands nearing 100 gpm (380 L/min) 

38 during the peak construction period, the staff determined that any effects would be temporary 

39 and localized. To support operations of a new nuclear power plant, the NRC assumed that this 

40 alternative would entail the same relative ratio of groundwater use to surface water use as that 

41 at LGS Units 1 and 2, along with a similar-sized workforce and operational activities. This 

42 includes the use of groundwater for service water makeup and potable and sanitary uses. 

43 Therefore, the groundwater resources impact assessment presented in Section 4.4 of this SEIS 

44 generally applies to the new nuclear alternative. Based on this assessment, impacts on 

45 groundwater use and quality under this alternative would be SMALL.
Environmental Impacts of Alternatives

8-31

1 8.3.3. Surface Water Resources

2 Surface water resources impacts from construction activities associated with the new nuclear 

3 alternative at an alternative site would be similar to but somewhat greater in scale than those 

4 described for the SCPC alternative (see Section 8.2.3). While no ash and sludge disposal 

5 facility would be required as under the SCPC alternative, deep excavation work for the nuclear 

6 island and more extensive site clearing and larger laydown area for facility construction would 

7 have potentially greater impacts to water resources from water use and stormwater runoff. 

8 Thus, temporary impacts to surface water quality may result from increased sediment loading 

9 and from any pollutants in stormwater runoff from disturbed areas and from any required 

10 dredging activities. Nevertheless, as described in Section 8.1.3, water quality impacts would be 

11 minimized by the application of BMPs and compliance with state-issued NPDES permits. Any 

12 dredging would be conducted under a permit from the COE requiring the implementation of 

13 BMPs to minimize impacts. To support operations of a new nuclear power plant, the NRC has 

14 assumed that the new facility would consumptively use and discharge the same amount of 

15 water as LGS. Therefore, the water resources impact assessment presented in Section 4.3.2 of 

16 this SEIS applies to the new nuclear alternative. In Section 4.3.2, the NRC determined that the 

17 impacts of LGS operations on surface water resources are SMALL. The NRC assumed that 

18 water treatment additives for this alternative would be essentially identical to LGS. Existing 

19 intake and discharge infrastructure would be used at the selected power plant site, but it could 

20 require refurbishment or expansion. Similar to LGS, surface water withdrawals would be 

21 subject to applicable state water allocation requirements, and effluent discharges and 

22 stormwater discharges associated with industrial activity would be subject to a state-issued 

23 NPDES permit. The NRC further assumes that the new nuclear plant would be operated in 

24 accordance with appropriate management plans with adherence to appropriate BMPs and 

25 procedures to minimize the release of non-nuclear fuels, chemicals, and other materials to soil, 

26 surface water, and groundwater (see Section 8.1.3). Therefore, based on this assessment, the 

27 overall impacts on surface water use and quality from construction and operations under the 

28 new nuclear alternative would be SMALL.

29 8.3.4. Aquatic Resources

30 Construction activities for the new nuclear alternative (such as construction of heavy-haul roads 

31 and the power block) could affect drainage areas or other onsite aquatic features. Minimal 

32 impacts on aquatic ecology resources are expected because the plant operator would likely 

33 implement BMPs to minimize erosion and sedimentation. Stormwater control measures, which 

34 would be required to comply with state NPDES permitting, would minimize the flow of disturbed 

35 soils into aquatic features. Depending on the available infrastructure at the selected site, the 

36 new nuclear alternative may require modification or expansion of the existing intake or 

37 discharge structures, or construction of new intake and discharge structures. Dredging activities 

38 that result from infrastructure construction would require BMPs for in-water work to minimize 

39 sedimentation and erosion. Because of the short-term nature of the dredging activities, the 

40 hydrological alterations to aquatic habitats would likely be localized and temporary.

41 During operations, the new nuclear alternative would require a similar amount of water from the 

42 Schuylkill River, or other similar water body, as is required for LGS Units 1 and 2. The number 

43 of fish and other aquatic resources affected by cooling water intake and discharge operations, 

44 such as entrainment, impingement, and thermal stress, would be similar for a new nuclear 

45 alternative as for those associated with LGS Units 1 and 2, provided the cooling-water intake 

46 and blowdown operations involve a water body similar in species composition and populations 

47 to the Schuylkill River. 
Environmental Impacts of Alternatives

8-32

1 The impacts on aquatic ecology would be minor because construction activities would require 

2 BMPs and stormwater management permits, and because the surface water withdrawal and 

3 discharge for this alternative would be similar to LGS Units 1 and 2 (as discussed in 

4 Section 4.5). Therefore, the staff concluded that impacts on aquatic ecology would be SMALL.

5 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 

6 of a new nuclear plant would not adversely affect any Federally listed species or adversely 

7 modify or destroy designated critical habitat. Consultation with NMFS under the 

8 Magnuson-Stevens Act would require the NRC to evaluate impacts to EFH. NMFS would 

9 provide conservation recommendations if there would be adverse impacts to EFH. Coordination 

10 with state natural resource agencies would further ensure that the plant operator would take 

11 appropriate steps to avoid or mitigate impacts to state-listed species, habitats of conservation 

12 concern, and other protected species and habitats. Consequently, the impacts of construction 

13 and operation on protected species and habitats would be SMALL. 

14 8.3.5. Terrestrial Resources

15 The new nuclear alternative, including the new reactor units and auxiliary facilities, would affect 

16 630 ac to 1,260 ac (255 ha to 510 ha) of land at the site of an existing power station other than 

17 LGS (Exelon 2011), as described in Section 8.3.7. Because of the significant land requirement 

18 for the site, impacts to terrestrial species and habitats would vary depending on the amount of 

19 previously undisturbed land that would be cleared for the new nuclear alternative. By siting the 

20 new nuclear alternative at an existing nuclear site or adjacent to an existing site, the majority of 

21 land that would be affected by construction would be developed or previously disturbed. 

22 However, as with the SCPC alternative, the level of direct impacts would vary based on site 

23 selection. Erosion and sedimentation, fugitive dust, and construction debris impacts would be 

24 minor with implementation of appropriate BMPs (Exelon 2011). Impacts to terrestrial habitats 

25 and species from transmission line operation and corridor vegetation maintenance, and 

26 operation of the cooling system would be similar in magnitude and intensity to those resulting 

27 from operating nuclear reactors and would, therefore, be SMALL (NRC 1996). The offsite land 

28 requirement (1,000 ac (400 ha)) (NRC 1996) and impacts associated with uranium mining and 

29 fuel fabrication to support the new nuclear alternative would be no different from those occurring 

30 in support of LGS (see Section 8.3.7). Overall, the impacts of construction of a new nuclear 

31 facility on terrestrial species and habitats would be SMALL to MODERATE, and the impacts of 

32 operation would be SMALL.

33 As with the previously discussed alternatives, consultation with FWS under the ESA would 

34 avoid potential adverse impacts to Federally listed species or adverse modification or 

35 destruction of designated critical habitat. Coordination with state natural resource agencies 

36 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 

37 state-listed species, habitats of conservation concern, and other protected species and habitats. 

38 Consequently, the impacts of construction and operation of new nuclear generation on 

39 protected species and habitats would be SMALL.

40 8.3.6. Human Health

41 Impacts on human health from construction of two new nuclear units would be similar to impacts 

42 associated with the construction of any major industrial facility. Compliance with worker 

43 protection rules would control those impacts on workers at acceptable levels. Impacts from 

44 construction on the general public would be minimal since limiting active construction area 

45 access to authorized individuals is expected. Impacts on human health from the construction of 

46 two new nuclear units would be SMALL.
Environmental Impacts of Alternatives

8-33

1 The human health effects from the operation of two new nuclear power plants would be similar 

2 to those of the existing LGS Units 1 and 2. Most other noises during power plant operations 

3 would be limited to industrial processes and communications. Impacts on human health from 

4 the operation of two new nuclear units would be SMALL.

5 8.3.7. Land Use

6 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and 

7 operating various replacement power plant alternatives on land use, both on and off each plant 

8 site. The analysis of land-use impacts focuses on the amount of land area that would be 

9 affected by the construction and operation of a new two-unit nuclear power plant at or adjacent 

10 to an existing nuclear power plant site.

11 Based on GEIS estimates, approximately 1,000 ac (400 ha) of land would be needed for the 

12 new nuclear alternative. Exelon estimated 630 ac to 1,260 ac (255 ha to 510 ha) of land would 

13 be needed to construct and operate a new two-unit nuclear power plant (Exelon 2011). The 

14 NRC determined that Exelon’s estimate is reasonable because it is consistent with land 

15 requirements for proposed new nuclear plants. 

16 Locating the new units at or adjacent to an existing nuclear power plant would mean that the 

17 majority of the affected land area would already be zoned for industrial use. Making use of the 

18 existing infrastructure would reduce the amount of land needed to support the new units. Local 

19 residents are already accustomed to living near a nuclear power plant. Land-use impacts from 

20 constructing two new units at an existing nuclear power plant site would be SMALL.

21 The amount of land required to mine uranium and fabricate nuclear fuel during rector operations 

22 would be similar to the amount of land required to support LGS, although an additional amount 

23 of land would be required during the license renewal term. According to GEIS estimates, an 

24 additional 1,000 ac (400 ha) of land would be affected by uranium mining and processing during 

25 the life of the new nuclear power plant. Impacts associated with uranium mining and fuel 

26 fabrication to support the new nuclear alternative would generally be no different from those 

27 occurring in support of the existing LGS reactors. Overall land-use impacts from nuclear power 

28 plant operations would range from SMALL to MODERATE depending on whether the nuclear 

29 plant is sited entirely contained within an existing nuclear power plant site or if it located on open 

30 land. 

31 8.3.8. Socioeconomics

32 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

33 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

34 socioeconomic impact; and (2) power plant operations jobs, which have the greater potential for 

35 permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

36 operation of a new nuclear power plant were evaluated in order to measure their possible 

37 effects on current socioeconomic conditions.

38 Exelon estimated 3,650 workers at the peak of construction (Exelon 2011). The relative 

39 economic impact of this many workers on the local economy and tax base would vary, with the 

40 greatest impacts occurring in communities where the majority of construction workers reside

41 and spend their income. As a result, local communities could experience a short-term economic 

42 “boom” from increased tax revenue and income generated by construction expenditures and the 

43 increased demand for temporary (rental) housing and business services. Some construction 

44 workers could relocate in order to be closer to the construction work site. However, given the 
Environmental Impacts of Alternatives

8-34

1 proximity of many existing power plants to metropolitan areas, workers could commute to the 

2 construction site, thereby reducing the need for rental housing.

3 After completing the installation of the two new reactor units, local communities could 

4 experience a return to pre-construction economic conditions. Based on this information and 

5 given the number of construction workers, socioeconomic impacts during construction in local 

6 communities could range from SMALL to LARGE.

7 Exelon estimated that the number of operations workers at the new nuclear power plant would 

8 be similar to the number of operations workers at LGS (Exelon 2011). The amount of property 

9 taxes paid under the new nuclear alternative may increase if additional land is required to 

10 support this alternative. However, the reduction in employment at LGS from operations to 

11 decommissioning and shut down could affect property tax revenue and income in local 

12 communities and businesses. In addition, the permanent housing market could also experience 

13 increased vacancies and decreased prices if operations workers and their families move out of 

14 the region. Therefore, socioeconomic impacts during operations could range from SMALL to 

15 MODERATE. 

16 8.3.9. Transportation

17 Transportation impacts associated with construction and operation of a new nuclear power plant 

18 would consist of commuting workers and truck deliveries of construction materials to the power 

19 plant site. During periods of peak construction activity, up to 3,650 workers could be commuting 

20 daily to the site (Exelon 2011). Workers commuting to the construction site would arrive by site 

21 access roads and the volume of traffic on nearby roads could increase substantially during shift 

22 changes. In addition to commuting workers, trucks would be transporting construction materials 

23 and equipment to the worksite, thus increasing the amount of traffic on local roads. 

24 The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 

25 service impacts and delays at intersections. Some power plant components and materials 

26 could also be delivered by train or barge, depending on location. Train deliveries could cause 

27 additional traffic delays at railroad crossings. Based on this information, traffic-related 

28 transportation impacts during construction could range from MODERATE to LARGE.

29 Traffic-related transportation impacts on local roads would be greatly reduced after the 

30 completion of the power plant. Transportation impacts would include daily commuting by the 

31 operating workforce, equipment and materials deliveries, and the removal of commercial waste 

32 material to offsite disposal or recycling facilities by truck. During operations, the estimated 

33 number of operations workers commuting to and from the power plant would be 820 workers 

34 (Exelon 2011). Traffic-related transportation impacts would be similar to current operations at 

35 LGS, because the new units would employ the same number of workers as currently employed 

36 at LGS. Overall, transportation impacts would be SMALL to MODERATE during power 

37 operations.

38 8.3.10. Aesthetics

39 The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear 

40 power plant and the surrounding landscape and the visibility of the new units at an existing 

41 nuclear power plant site. The power block of the two new units would look very similar to the 

42 power block(s) at the existing nuclear power plant.

43 During construction, all of the clearing and excavation would occur on site. These activities may 

44 be visible from offsite roads. Since the existing power plant site already appears industrial, 
Environmental Impacts of Alternatives

8-35

1 construction of the new nuclear power plant would appear similar to other ongoing onsite 

2 activities. 

3 Located near an existing power plant, the tallest power plant structures, the natural draft cooling 

4 towers could be 400 to 500 ft (122 to 152 m) tall. Visible off site during daylight hours, they may 

5 require aircraft warning lights. Associated condensate plumes could add to the visual impact. 

6 Noise generated during power plant operations would mostly be limited to routine industrial 

7 processes and communications. Natural draft cooling towers would also generate noise.

8 In general, given the industrial appearance of an existing power plant site, the new nuclear 

9 power plant would blend in with the surroundings. Aesthetic changes would therefore be limited 

10 to the immediate vicinity of the existing power plant site, and any impacts would be SMALL to 

11 MODERATE, depending on its location and surroundings.

12 8.3.11. Historic and Archaeological Resources 

13 The impacts of constructing the new nuclear alternative on historic and archaeological 

14 resources are similar to those impacts associated with activities for constructing an NGCC 

15 facility. Any areas potentially affected by the construction of the SCPC alternative would need 

16 to be surveyed to identify and record historic and archaeological resources. An inventory of a 

17 previously disturbed former plant (brownfield) site may still be necessary if the site has not been 

18 previously surveyed or to verify the level of disturbance and evaluate the potential for intact 

19 subsurface resources. Plant operators would need to survey all areas associated with operation 

20 of the alternative (e.g., roads, transmission corridors, other ROWs). Any resources found in 

21 these surveys would need to be evaluated for eligibility on the NRHP, and mitigation of adverse 

22 effects would need to be addressed if eligible resources were encountered. Areas with the 

23 greatest sensitivity should be avoided. Visual impacts on significant cultural resources—such 

24 as the viewsheds of historic properties near the site—should also be assessed.

25 The potential for impacts on historic and archaeological resources from the new nuclear

26 alternative would vary greatly depending on the location of the proposed site. However, given 

27 that the preference is to use a previously disturbed former plant site, avoidance of significant 

28 historic and archaeological resources should be possible and effectively managed under current 

29 laws and regulations. Therefore, the impacts on historic and archaeological resources from the 

30 new nuclear alternative would be SMALL.

31 8.3.12. Environmental Justice

32 The environmental justice impact analysis evaluates the potential for disproportionately high and 

33 adverse human health, environmental, and socioeconomic effects on minority and low-income 

34 populations that could result from the construction and operation of a new power plant. As 

35 previously discussed in Section 8.1.12, such effects may include human health, biological, 

36 cultural, economic, or social impacts. 

37 Potential impacts to minority and low-income populations would mostly consist of environmental 

38 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

39 housing impacts). Noise and dust impacts during construction would be short term and 

40 primarily limited to onsite activities. Minority and low-income populations residing along site 

41 access roads would be directly affected by increased commuter vehicle and truck traffic. 

42 However, because of the temporary nature of construction, these effects are not likely to be high

43 and adverse and would be contained to a limited time period during certain hours of the day. 

44 During construction, increased demand for rental housing in the vicinity of the site could affect 

45 low-income populations living near the plant site. However, given the proximity of some existing 
Environmental Impacts of Alternatives

8-36

1 nuclear power plant sites to metropolitan areas, workers could commute to the construction site, 

2 thereby reducing the need for rental housing. 

3 Potential impacts to minority and low-income populations from new nuclear power plant 

4 operations would mostly consist of radiological effects; however, radiation doses are expected 

5 to be well below regulatory limits. All people living near the nuclear power plant would be 

6 exposed to the same potential effects from power plant operations, and any impacts would 

7 depend on the magnitude of the change in ambient air quality conditions. Permitted air 

8 emissions are expected to remain within regulatory standards. 

9 Based on this information and the analysis of human health and environmental impacts 

10 presented in this SEIS, the construction and operation of a new nuclear power plant would not 

11 have disproportionately high and adverse human health and environmental effects on minority 

12 and low-income populations.

13 8.3.13. Waste Management

14 During the construction stage of the new nuclear alternative, land clearing and other 

15 construction activities would generate waste that could be recycled, disposed of on site, or 

16 shipped to the offsite waste disposal facility. Because the new nuclear plants would be 

17 constructed at a location on and adjacent to an existing nuclear power plant (although not at 

18 LGS because of space limitations), the amount of wastes produced during land clearing would 

19 be reduced.

20 During the operational stage, normal plant operations, routine plant maintenance, and cleaning 

21 activities would generate nonradioactive waste as well as mixed waste, low-level waste, and 

22 high-level waste. Quantities of nonradioactive waste (discussed in Section 2.3.1 of this SEIS) 

23 and radioactive waste (discussed in Section 6.1 of this SEIS) generated by Units 1 and 2 would 

24 be comparable to that generated by the new nuclear plants.

25 According to the GEIS (NRC 1996), the generation and management of solid nonradioactive 

26 waste during the terms of an extended license are not expected to result in significant 

27 environmental impacts. Two new nuclear plants would generate waste streams similar to those 

28 at nuclear plants that have undergone license renewal. Based on this information, the waste 

29 impacts would be SMALL for the new nuclear alternative. 
Environmental Impacts of Alternatives

8-37

1 Table 8–4. Summary of Environmental Impacts of the New Nuclear Alternative Compared 

2 to Continued Operation of the Existing LGS

New Nuclear 

Alternative Continued LGS Operation

Air Quality SMALL SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Aquatic Resources SMALL SMALL

Terrestrial Resources SMALL to MODERATE SMALL

Human Health SMALL SMALL

Land Use SMALL to MODERATE SMALL

Socioeconomics SMALL to LARGE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics SMALL to MODERATE SMALL

Historic and Archaeological SMALL SMALL

Waste Management SMALL(a) SMALL(a)

(a)

As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS.

3 8.4. Wind Alternative

4 The feasibility of wind as a baseload power source depends on the availability, accessibility, and 

5 constancy of the wind resource within the region of interest. Wind power, in general, cannot be 

6 stored without first being converted to electrical energy. 

7 Wind power installations, which may consist of several hundred turbines, produce variable 

8 amounts of electricity. LGS, however, produces electricity almost constantly. Because wind 

9 power installations deliver variable output when wind conditions change, wind power cannot 

10 substitute for existing baseload generation on a one-to-one basis. In its ER, Exelon discusses 

11 the need for “firming capacity” to provide support to the variable wind resource and provide 

12 consistent baseload power. Firming capacity could come from other generators, from 

13 compressed air energy storage (CAES), from pumped hydroelectric storage, or from 

14 interconnected wind installations. Archer and Jacobsen (2007), indicates that an array of

15 interconnected wind sites (19 in their study), spread across significant distances (with 

16 approximately 850 km (530 mi) distance from north to south and east to west) could provide 

17 21 percent of installed capacity 79 percent of the time. While the sites in Archer and Jacobsen’s 

18 study, in most cases, accessed higher power-class wind resources than are readily available 

19 onshore in PJM, the approach suggests that approximately 20 percent of the installed capacity 

20 in a series of interconnected wind installations could provide baseload power. Therefore, this 

21 study indicates that interconnecting windfarms, as assumed in this alternative, may provide a 

22 source of consistent, baseload power. In this alternative, the staff considers a wind alternative 

23 that relies on numerous, interconnected wind installations scattered across PJM. This 

24 arrangement ensures that generators are sufficiently dispersed so that low-wind or no-wind 

25 conditions are unlikely to occur at all or most locations at any given time.
Environmental Impacts of Alternatives

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1 Wind farms currently operate at much lower capacity factors than nuclear power. For example, 

2 LGS Unit 1 has operated at a 97 percent capacity factor over the years 2003 to 2010, while LGS 

3 Unit 2 has operated at a 96 percent capacity factor over the same period (NRC 2011). 

4 Currently, Department of Energy (DOE) estimates that wind turbine installations operate at 

5 39 percent or lower capacity factors because of the variability of wind resources. As Exelon 

6 indicated in its ER, this capacity factor is likely to increase as wind turbine technology advances 

7 and as operators become more experienced in maximizing output. DOE indicates that, by 

8 2020, onshore wind turbines may reach a 52 percent capacity factor, while offshore units may 

9 reach a 55 percent capacity factor (DOE 2008). As described in more detail below, the staff 

10 finds it likely that all wind turbines in this alternative will be land-based and, therefore, used the 

11 52 percent capacity factor as an upper range of the capacity factor for this analysis. 

12 For a lower range of the capacity factor used in this analysis, the staff reviewed PJM’s

13 13 percent “capacity credit” to wind power. Capacity credit is the amount of a generator’s 

14 nameplate capacity that counts toward the total generating capacity of the PJM system for 

15 system planning purposes. Assuming a 13 percent “capacity credit” for wind power, 

16 18,000 MW(e) of wind power would be necessary to replace 2,340 MW(e) of LGS because of 

17 the intermittency of wind power. 

18 Wind power is a commercially available and feasible means of generating electricity. Assuming 

19 a range of 13 to 52 percent capacity factor, the staff, in this alternative, evaluates a 

20 wind-powered alternatives that contains between 4,500 MW(e) and 18,000 MW(e) of installed 

21 capacity. Relying on commonly available 2-MW(e) turbines, 2,250 to 9,000 turbines would be 

22 required to replace LGS. The NRC staff determined this was a reasonable alternative because 

23 wind power is currently a source of energy generation within PJM. As of October 2012, 

24 approximately 6,000 MW of installed wind capacity exists within PJM (PJM 2012a). The 

25 installed wind capacity within Pennsylvania, Delaware, Maryland, New Jersey, Ohio, and West 

26 Virginia has grown on average 50 percent per year from 2000 through 2011 (DOE 2012). 

27 Similar growth is likely within the next several years. For example, as of January 2012, a total 

28 of 37,792 MW of wind energy generation is proposed within PJM (PJM 2012b). Similarly, in a 

29 recent update of PJM’s renewable portfolio standards, PJM (2012a) estimated that 35,600 MW 

30 of wind energy would be installed by 2027. 

31 As described above, this alternative assumes all wind power would be generated onshore 

32 because it is currently commercially available and a feasible means of generating electricity. 

33 While some offshore wind development is possible by 2024, no commercial offshore wind 

34 installations currently operate in the United States, despite more than a decade of development 

35 efforts. In the Atlantic Ocean, several commercial wind-power projects have been proposed, 

36 but none have yet received final approvals or begun construction. The most prominent of these 

37 projects, Cape Wind would consist of 130 turbines with a maximum installed capacity of 

38 468 MW. The project was initially proposed in 2001; however, because of significant delays 

39 related to permitting and the NEPA process, the project is currently scheduled to begin 

40 construction in 2013. Cape Wind is the first and only U.S. offshore wind farm to have received 

41 all required Federal and State approvals, a commercial lease, and an approved construction 

42 and operations plan (BOEMRE, 2012b). Other projects offshore of Rhode Island and New 

43 Jersey are smaller than Cape Wind (Wald 2011), and another organization has proposed—

44 though not yet constructed—a high-voltage direct-current powerline on the seafloor to connect 

45 offshore projects (Atlantic Wind Connection undated, Wald 2011). Finally, a group working near 

46 Long Island proposed an installation of 700 MW(e) of wind capacity (Con Edison 2009). While 

47 wind data suggest there is potential for offshore wind farms along the coast of the mid-Atlantic 

48 and in the Great Lakes, project costs likely limit the future potential of large-scale projects 

49 (NREL 2010). NREL (2010) estimated that offshore project costs would run approximately 
Environmental Impacts of Alternatives

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1 200 to 300 percent higher than land-based systems. Also, based on current prices for wind 

2 turbines, the 20-year levelized cost of electricity produced from an offshore wind farm would be 

3 above the current production costs from existing power generation facilities. In addition to cost, 

4 other barriers include the immature status of the technology, limited resource area, and high 

5 risks and uncertainty (NREL 2010).

6 Environmental impacts from the wind alternative are summarized in Table 8–5.

7 8.4.1. Air Quality

8 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

9 Pennsylvania, which is part of the Metropolitan Philadelphia Interstate Air Quality Control 

10 Region AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards 

11 (NAAQS), EPA has designated Montgomery and Chester Counties as unclassified or in 

12 attainment with respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment 

13 with respect to ozone and PM2.5 (40 CFR 81.339).

14 Beyond maintenance of the wind turbines, there would be no routine air emissions associated 

15 with operations from wind generation. Activities associated with the construction and installation 

16 of the wind turbines would cause some temporary air pollutant emissions. However, emissions 

17 from workers’ vehicles and construction equipment exhaust would be temporary. The staff

18 concludes that the air quality impact from construction would be SMALL. 

19 Greenhouse Gas Emissions

20 Wind power releases no GHGs during operation, although some GHG emissions occur during

21 component manufacturing, transportation, and installation, as well as during site preparation. 

22 Impacts from the construction of components of this alternative would result primarily from the 

23 consumption of fossil fuels in the engines of construction vehicles and equipment, workforce 

24 vehicles used in commuting to and from the work site, and delivery vehicles. However, all such 

25 impacts would be temporary. 

26 In general, wind power is one of the least carbon-intensive electric generation options available. 

27 For a comparison to other means of electric generation, see the discussion in Chapter 6.

28 Given the expected relatively small workforces, short construction period, and GHG emissions 

29 resulting from site preparation and installation, ,the overall impact from the release of GHGs of 

30 the wind alternative would be SMALL. 

31 Conclusions

32 Based on the above discussion, the overall air emissions and air quality impacts from the wind 

33 alternative would be designated as SMALL.

34 8.4.2. Groundwater Resources

35 Groundwater dewatering, where required for installation of wind turbines on land, would be 

36 minimal because of the small footprint of foundation structures and piling emplacements. For all 

37 construction activities, appropriate BMPs, including spill prevention practices, would be used 

38 during wind turbine construction to prevent or minimize impacts on groundwater quality. 

39 Little or no groundwater use would be expected for operation of wind turbines, and no impacts 

40 on groundwater quality would be expected from routine operations. Consequently, the impacts 

41 on groundwater use and quality under this alternative would be SMALL.
Environmental Impacts of Alternatives

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1 8.4.3. Surface Water Resources

2 Small amounts of water would be required during the construction phase for each of the 

3 2,250 wind turbines, including for dust suppression and soil compaction during site clearing and 

4 for concrete production for pad and piling construction, as appropriate. Although surface water 

5 from nearby water bodies may be used for pad site construction at some locations, it is likely 

6 that water would be procured from offsite sources and trucked to the point of use on an as 

7 needed basis. Use of ready-mix concrete also would reduce the need for onsite use of nearby 

8 water sources.

9 Further, the installation of land-based wind turbines would require installation of access roads

10 and possibly transmission lines (especially for turbine sites not already proximal to transmission 

11 line corridors). Access road construction also would require some water for dust suppression 

12 and roadbed compaction and would have the potential to result in soil erosion and stormwater 

13 runoff from cleared areas. Water would likely be trucked to the point of use from offsite 

14 locations along with road construction materials. Construction activities would be conducted in 

15 accordance with state-issued NPDES or equivalent permits for stormwater discharges 

16 associated with construction activity, which would require the implementation of appropriate 

17 BMPs to prevent or mitigate water quality impacts. 

18 To support operations of individual wind turbine installations, only very small amounts of water 

19 would be needed to periodically clean turbine blades and motors as part of routine servicing. It 

20 would be expected that water would be trucked to the point of use and procured from nearby 

21 sources. Adherence to appropriate waste management and minimization plans, spill prevention 

22 practices, and pollution prevention plans during servicing would minimize the risks to soils and 

23 surface water resources from spills of petroleum, oil, and lubricant products and runoff 

24 associated with the turbine installations. Therefore, the impacts on surface water use and 

25 quality under the wind alternative would be SMALL.

26 8.4.4. Aquatic Resources

27 Construction activities for the land-based wind alternative (such as construction of heavy-haul 

28 roads and the wind turbines) could affect drainage areas and other onsite aquatic features. 

29 Minimal impacts on aquatic ecology resources are expected because the plant operator would 

30 likely implement BMPs to minimize erosion and sedimentation. Stormwater control measures, 

31 which would be required if an NPDES permit was necessary, would minimize the flow of 

32 disturbed soils into aquatic features. During operations, the land-based wind alternative would 

33 not require consumptive water use. 

34 The impacts on aquatic ecology would be minor because construction activities would likely 

35 require BMPs and stormwater management permits. During operations, the land-based wind 

36 alternative would not require consumptive water use. Therefore, impacts on aquatic ecology 

37 from the land-based wind alternative would be SMALL.

38 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 

39 of wind farms would not adversely affect any Federally listed species or adversely modify or 

40 destroy designated critical habitat. If wind farms were located near EFH, consultation with 

41 NMFS under the Magnuson-Stevens Act would require the NRC to evaluate impacts to EFH. 

42 NMFS would provide conservation recommendations if there would be adverse impacts to EFH. 

43 Coordination with state natural resource agencies would further ensure that the wind farm 

44 operators would take appropriate steps to avoid or mitigate impacts to state-listed species, 

45 habitats of conservation concern, and other protected species and habitats. Consequently, the 

46 impacts of construction and operation on protected species and habitats would be SMALL. 
Environmental Impacts of Alternatives

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1 8.4.5. Terrestrial Resources

2 The wind alternative would contain between 2,250 and 9,000 wind turbines requiring

3 approximately 3,200 to 13,300 ac (1,300 to 5,400 ha) of land. This land estimate includes only 

4 the area directly affected by placement of turbines, and about two-thirds of this land area would 

5 only experience temporary disturbance during construction. The logistics of delivering heavy or 

6 oversized components to ideal locations such as hilltops or ridgelines would be challenging and 

7 might require extensive modifications to existing road infrastructures and construction of access 

8 roads that take circuitous routes to their destination to avoid unacceptable grades. However, 

9 once construction was completed, many access roads could be reclaimed and replaced with 

10 more-direct access to the wind farm for maintenance purposes. Likewise, land used for 

11 equipment laydown and turbine component assembly and erection could be returned to its 

12 original state. BMPs following construction that include plans to restore disturbed land would 

13 also reduce the impact of construction on terrestrial habitats. Because wind turbines require 

14 ample spacing between one another to avoid inter-turbine air turbulence, the footprint of 

15 utility-scale wind farms could be quite large. The turbines would be spread across a total area 

of 200 to 830 mi2 (520 to 2,150 km2 16 ), and most of this area will remain in compatible land uses, 

17 such as agriculture and forests (Exelon, 2011). During operations, only 5 to 10 percent of the 

18 total acreage within the footprint of wind installations would actually be occupied by turbines, 

19 access roads, support buildings, and associated infrastructure while the remaining land areas 

20 could be put to other compatible uses, including agriculture. Habitat loss and some habitat 

21 fragmentation may occur as a result, especially for wind turbines installed in forested areas. 

22 Overall, construction impacts on terrestrial species and habitats could range from SMALL 

23 to MODERATE.

24 Operation of wind turbines could uniquely affect terrestrial species through noise, collision with 

25 turbines and meteorological towers, site maintenance activities, disturbance associated with 

26 activities of the project workforce, and interference with migratory behavior. Bat and bird 

27 mortality from turbine collisions is a concern for operating wind farms; however, recent 

28 developments in turbine design have reduced the potential for bird and bat strikes. Additionally, 

29 impacts to those bird and bat species protected by the ESA, the Migratory Bird Treaty Act, or 

30 the Bald and Golden Eagle Protection Act would be mitigated through consultation with the 

31 appropriate agencies as discussed below. Impacts to terrestrial habitats and species from 

32 transmission line operation and corridor vegetation maintenance would be similar in magnitude 

33 and intensity to those resulting from operating nuclear reactors and would, therefore, be SMALL 

34 (NRC 1996). Overall, operation impacts to terrestrial species and habitats could range from 

35 SMALL to MODERATE.

36 As with the previously discussed alternatives, consultation with FWS under the ESA would 

37 avoid potential adverse impacts to Federally listed species or adverse modification or 

38 destruction of designated critical habitat. Coordination with state natural resource agencies 

39 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 

40 state-listed species, habitats of conservation concern, and other protected species and habitats. 

41 Consequently, the impacts of construction and operation of a wind alternative on protected 

42 species and habitats would be SMALL.

43 8.4.6. Human Health

44 Impacts on human health from construction of the wind alternative would be similar to impacts 

45 associated with the construction of any major industrial facility. Compliance with worker 

46 protection rules would control those impacts on workers at acceptable levels. Impacts from 

47 construction on the general public would be minimal since limiting active construction area 
Environmental Impacts of Alternatives

8-42

1 access to authorized individuals is expected. Impacts on human health from the construction of 

2 the wind alternative would be SMALL.

3 The Massachusetts Department of Environmental Protection (MassDEP), in collaboration with 

4 the Massachusetts Department of Public Health (MDPH), convened a panel of independent 

5 experts to identify any documented or potential health impacts of risks that may be associated 

6 with exposure to wind turbines (MassDEP and MDPH 2012). The panel conducted an 

7 extensive literature review of scientific literature as well as other reports, popular media, and the 

8 public comments received by MassDEP to write its report. Based on its review, the panel 

9 presented findings relative to three factors associated with the operation of wind turbines: noise 

10 and vibration, shadow flicker, and ice throw.

11 Noise and Vibration

12 Noise produced by wind turbines during operation depends on the design of the wind turbine. 

13 Propagation of the sound is primarily a function of distance from the wind turbine, but can also 

14 be affected by placement of the wind turbine, surrounding terrain, and atmospheric conditions. 

15 Infrasound refers to vibrations with frequencies below 20 Hertz (Hz). Infrasound at amplitudes 

16 over 100-110 Decibels (dB) can be heard and felt. Research has shown that vibrations below 

17 these amplitudes are not felt. Through its research, the panel found that the highest infrasound 

18 levels measured near turbines are under 90 dB at 5 Hz and lower at higher frequencies for 

19 locations as close as 100 meters (m). The panel found that there was not sufficient evidence 

20 to conclude that noise and vibration from wind turbines cause negative impacts on human 

21 health (MassDEP and MDPH 2012).

22 Shadow Flicker

23 Shadow flicker results from the passage of the blades of a rotating wind turbine between the 

24 sun and the observer. The occurrence of shadow flicker depends on the location of the 

25 observer relative to the turbine and the time of day and year, and is found to only be present at 

26 distances of less than 1,400 m (4,600 ft) from the turbine. The panel found through its research 

27 that there was not sufficient evidence to conclude that shadow flicker causes negative impacts 

28 (such as seizures from photic stimulation) on human health (MassDEP and MDPH 2012).

29 Ice Throw

30 Ice can fall or be thrown from a wind turbine during or after an event when ice forms or 

31 accumulates on the blades. The distance that a piece of ice may travel from the turbine is a 

32 function of the wind speed, the operating conditions, and the shape of the ice. The panel found 

33 that in most documented cases of ice throw, the ice falls within a distance from the turbine equal 

34 to the tower height, and very seldom does the distance exceed twice the total height of the 

35 turbine (tower height plus blade length). The panel found that there is sufficient evidence that 

36 falling ice is a human health impact, and measures should be taken to ensure proper hazard 

37 minimization. Proper siting of the wind turbines, limitation of access by members of the public, 

38 and adequate training of persons in charge of maintenance of the facility will help to minimize 

39 the danger of ice throw (MassDEP and MDPH 2012).

40 Overall, given proper health-based regulation through procedures and access limitations, the 

41 staff expects human health impacts from operation of the wind alternative at an alternate site 

42 to be SMALL.

43 8.4.7. Land Use

44 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and 

45 operating various replacement power plant alternatives on land use, both on and off each power 
Environmental Impacts of Alternatives

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1 plant site. The analysis of land-use impacts focuses on the amount of land area that would be 

2 affected by the construction and operation of new land-based wind farms in the PJM territory. 

3 Most of the wind farms would likely be located on open agricultural cropland, which would 

4 remain largely unaffected by the wind turbines.

5 Since wind turbines require ample spacing between one another to avoid air turbulence, the 

6 footprint of a utility scale wind farm could be quite large. Under the wind alternative, land-based 

7 turbines would be located on multiple wind farms spread across approximately 130,000 to 

534,000 ac (53,000 to 216,000 ha or 200 to 830 mi2

 [520 to 2,150 km2 8 ]) of land. A small portion 

9 of this land, approximately 3,200 to 13,300 ac (1,300 to 5,400 ha), would be directly affected by 

10 the placement of the wind turbines (Exelon 2011). This land would be temporarily affected 

11 during the installation of the turbines and the construction of support facilities, and about 

12 one-third of the land across a very wide area would be permanently impacted during the 

13 operation. Land in between the turbines can be used for farming or grazing.

14 Delivering heavy and oversized wind turbine components would also require the construction of 

15 temporary site access roads, some of which may require a circuitous route to their destination. 

16 However, once construction is completed, many temporary access roads can be reclaimed and 

17 replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land 

18 used for equipment and material lay down areas, turbine assembly, and installation could be 

19 returned to its original state. During operations, however, only 5–10 percent of the total acreage 

20 within the wind farm is actually occupied by turbines, access roads, support buildings, and 

21 associated infrastructure while the remaining land area can be returned to its original condition 

22 or some other compatible use, such as farming or grazing.

23 The elimination of uranium fuel for LGS could partially offset some, but not all, of the land 

24 requirements for the wind farms. Scaling from GEIS estimates, approximately 1,640 ac 

25 (660 ha) would no longer be needed for mining and processing uranium during the operating life 

26 of the wind farms. 

27 The wind farms would require a substantial amount of open land, although only a small portion 

28 would be used for wind turbines, access roads, and infrastructure. Therefore, land use impacts 

29 from the wind alternative would range from MODERATE to LARGE. 

30 8.4.8. Socioeconomics

31 As previously explained in Section 8 1.8, two types of jobs would be created by this alternative: 

32 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

33 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 

34 long-term socioeconomic impacts. Workforce requirements for the construction and operation 

35 of the wind alternative were evaluated in order to measure their possible effects on current 

36 socioeconomic conditions.

37 Exelon estimated 200 construction and 50 operations workers would be required for this 

38 alternative (Exelon 2011). These numbers appear reasonable and in line with current 

39 construction and operational trends. Because of the relatively small number of construction 

workers and the large area covered by the wind farms (i.e., 200 to 830 mi2

 [520 to 2,160 km2 40 ]), 

41 the relative economic impact of this many workers on local communities and the tax base would 

42 be SMALL. Given the small number of operations workers, socioeconomic impacts associated 

43 with operation of the wind farms would also be SMALL.

44 The reduction in employment at LGS could affect property tax revenue and income in local 

45 communities and businesses. In addition, the permanent housing market could also experience 

46 increased vacancies and decreased prices if operations workers and their families move out of 
Environmental Impacts of Alternatives

8-44

1 the LGS region. However, the increased property taxes paid by wind farms may offset lost tax 

2 revenues in local jurisdictions. Based on this information, socioeconomic impacts during wind 

3 farm operations could range from SMALL to MODERATE. 

4 8.4.9. Transportation

5 Transportation impacts during the construction and operation of the wind alternative would be 

6 less than the impacts for the NGCC, SCPC, and new nuclear alternatives, discussed in the 

7 previous sections, because of a smaller construction workforce and smaller volume of materials 

8 and equipment needed to be transported to the construction site.

9 As described in 8.4.7, up to 200 workers could be commuting daily to the site during periods of 

10 peak construction activity (Exelon 2011). Workers commuting to the construction site would 

11 arrive by site access roads and the volume of traffic on nearby roads could increase during shift 

12 changes. In addition to commuting workers, trucks would be transporting construction materials 

13 and equipment to the worksite, thus increasing the amount of traffic on local roads. The 

14 increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 

15 service impacts and delays at intersections. Transporting heavy and oversized wind turbine 

16 components on local roads could have a noticeable impact over a large area. Some 

17 components and materials could also be delivered by train or barge, depending on location. 

18 Train deliveries could cause additional traffic delays at railroad crossings. Based on this 

19 information, traffic-related transportation impacts during construction could range from SMALL 

20 to MODERATE depending on the location of the wind farm site, road capacities, and traffic 

21 volumes.

22 During plant operations, transportation impacts would not be noticeable. Exelon estimated an 

23 operational workforce of 50 workers (Exelon 2011). Given the small number of operations 

24 workers, transportation impacts on local roads would be SMALL.

25 8.4.10. Aesthetics

26 The analysis of aesthetic impacts focuses on the degree of contrast between the wind farms 

27 and the surrounding landscape and the visibility of wind turbines. In general, aesthetic changes 

28 would be limited to the immediate vicinity of the wind farms. However, wind turbines would 

29 have the greatest visual impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple 

30 sites, wind turbines would dominate the view and would likely become the major focus of 

31 attention. Because wind farms are generally located in rural or remote areas, the introduction of 

32 wind turbines will be in sharp contrast to the visual appearance of the surrounding environment. 

33 Placing turbines along ridgelines would maximize their visibility. Wind turbines also generate 

34 noise. Most other noises would be limited to industrial processes and communications. Based 

35 on this information, aesthetic impacts from the construction and operation of a land-based wind 

36 alternative would range from MODERATE to LARGE depending on location and surroundings.

37 8.4.11. Historic and Archaeological Resources 

38 To consider effects on historic and archaeological resources, any areas potentially affected by 

39 the construction of a wind alternative would need to be surveyed to identify and record historic 

40 and archaeological resources. Any resources found in these surveys would need to be 

41 evaluated for eligibility on the NRHP, and mitigation of adverse effects would need to be 

42 addressed if eligible resources were encountered. The owner of the wind farms would need to 

43 survey all areas associated with operation of the alternative (e.g., roads, transmission corridors, 

44 other ROWs). Areas with the greatest sensitivity should be avoided. Visual impacts on 
Environmental Impacts of Alternatives

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1 significant cultural resources—such as the viewsheds of historic properties near the sites—also 

2 should be assessed.

3 The potential for impacts on historic and archaeological resources from the wind alternative 

4 would vary greatly, depending on the location of the proposed sites. Areas with the greatest 

5 sensitivity could be avoided or effectively managed under current laws and regulations. 

6 However, construction of wind farms and their support infrastructure have the potential to 

7 notably impact historic and archaeological resources because of earthmoving activities 

8 (e.g., grading and digging) and the aesthetic changes they may bring to the viewshed of historic 

9 properties located nearby. Therefore, depending on the resource richness of the site chosen for 

10 the wind farms and associated infrastructure, the impacts could range from SMALL to LARGE. 

11 8.4.12. Environmental Justice

12 The environmental justice impact analysis evaluates the potential for disproportionately high and 

13 adverse human health, environmental, and socioeconomic effects on minority and low-income 

14 populations that could result from the construction and operation of new wind farms. As 

15 previously discussed in Section 8.1.12, such effects may include human health, biological, 

16 cultural, economic, or social impacts. 

17 Potential impacts to minority and low-income populations would mostly consist of environmental 

18 and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise 

19 and dust impacts during construction would be short term and primarily limited to onsite 

20 activities. Minority and low-income populations residing along site access roads would be 

21 affected by increased commuter vehicle and truck traffic. However, because of the temporary 

22 nature of construction, these effects are not likely to be high and adverse and would be 

23 contained to a limited time period during certain hours of the day. Increased demand for rental 

24 housing during construction could affect low-income populations. However, given the small 

25 number of construction workers and the possibility that workers could commute to the 

26 construction site, the need for rental housing would not be significant. Minority and low-income 

27 populations living in close proximity to the wind farms could be disproportionately affected by 

28 wind farm operations. However, operational impacts would mostly be limited to noise and 

29 aesthetic effects. The general public living near the wind farms would also be exposed to the 

30 same effects.

31 Based on this information and the analysis of human health and environmental impacts 

32 presented in this SEIS, the construction and operation of new wind farms would not have 

33 disproportionately high and adverse human health and environmental effects on minority and 

34 low-income populations.

35 8.4.13. Waste Management

36 During the construction stage of the wind alternative facility, land clearing and other construction 

37 activities would produce minor quantities of waste. Only small quantities of waste, such as 

38 dielectric fluids used during maintenance activities, would be produced during operation 

39 (Exelon 2011). In addition, Table 8–2 of the GEIS (NRC 1996), the staff identified very minor 

40 amounts of waste from maintenance of equipment and potentially removing vegetation. Based 

41 on this information, waste impacts would be SMALL for a wind turbine site.
Environmental Impacts of Alternatives

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1 Table 8–5. Summary of Environmental Impacts of the Wind Alternative Compared to 

2 Continued Operation of the Existing LGS

Wind Power Continued LGS Operation

Air Quality SMALL SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Aquatic Resources SMALL SMALL

Terrestrial Resources SMALL to MODERATE SMALL

Human Health SMALL SMALL

Land Use MODERATE to LARGE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics MODERATE to LARGE SMALL

Historic and Archaeological SMALL to LARGE SMALL

Waste Management SMALL SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS.

3 8.5. Purchased Power

4 The impacts from purchased power would depend substantially on the generation technologies 

5 used to supply the purchased power. Given PJM’s market-based system operations, 

6 replacement power could come from different generators at different times of the year, so 

7 impacts are not necessarily predictable. Impacts from operation of other generators would likely 

8 occur in Pennsylvania or elsewhere in PJM. 

9 Exelon assumed that purchased power would be available as a reasonable alternative for 

10 meeting load obligations if the LGS licenses are not renewed (Exelon 2011). The NRC staff 

11 finds this assessment reasonable given the large size of PJM and wide range of existing and 

12 potential energy-producing facilities available to purchase power. Purchased power would likely 

13 come from one or more of the other types of alternatives considered in this chapter. As a result, 

14 operational impacts would be similar to the operational impacts of the alternatives considered in 

15 this chapter. Unlike the alternatives considered in this chapter, however, facilities from which 

16 power would be purchased would not likely be constructed solely to replace LGS. Purchased 

17 power may, however, require new transmission lines (which may require new construction), and 

18 may also rely on slightly older and less efficient power plants’ operating at higher capacities 

19 than they currently operate. Exelon, in the ER, states that impacts would be “incremental and 

20 reflective of the increased amount of power being produced,” and may vary based on fuels 

21 used, waste management practices, and facility locations (Exelon 2011). 

22 At some times, some portion of replacement power needs may be addressed by PJM’s 

23 demand-response program, which the staff discusses in Section 8.6.14. As noted in 

24 Section 8.6.14, impacts from DSM programs are generally small, although backup generators

25 could impact air quality. 
Environmental Impacts of Alternatives

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1 During operations, impacts from new nuclear, coal-fired, and natural gas-fired plants and wind 

2 energy projects would be similar to that described under the new nuclear, coal, natural gas, and 

3 wind alternatives described in the previous sections. Impacts from the operations of existing 

4 coal and natural gas-fired plants would likely be greater than the operations of new plants 

5 because older plants are more likely to be less efficient and without modern emissions controls. 

6 Air quality impacts from the combination of all sources would likely be greater than license 

7 renewal because a large portion of the purchased power would likely be from coal- and natural

8 gas-fired plants. 

9 While purchased power is a reasonable alternative, the potential impacts of constructing and 

10 operating new power generating facilities are addressed elsewhere in this chapter. In general, 

11 the impacts would likely be greater than license renewal because of potential new construction 

12 and because continued operation of older plants could result in higher emissions. A brief 

13 summary of the impacts for each resource area is provided below: 

14 Air Quality: SMALL to MODERATE

15 New and continued nuclear and wind energy generation would not have noticeable impacts on 

16 air quality. New and continued natural gas- and coal-fired plants would have noticeable impacts 

17 on air quality; both natural gas- and coal-fired plants emit higher amounts of NOx, SOx, PM, 

18 PAHs, CO, CO2, and mercury as compared to LGS Units 1 and 2, and would have noticeable 

19 impacts. 

20 Groundwater and Surface Water: SMALL

21 New and continued operation of nuclear, coal-fired, and natural gas-fired plants and wind 

22 energy projects would not have noticeable impacts on water resources assuming all energy 

23 generating facilities operate within their associated water quality and water use permits.

24 Terrestrial and Aquatic: SMALL to MODERATE

25 New and continued operation of existing natural gas-fired and nuclear plants would not have 

26 noticeable impacts on aquatic and terrestrial resources assuming plants are built in areas that 

27 avoid sensitive species and habitats. New land-based wind energy projects would not have 

28 noticeable impacts on aquatic resources assuming projects are built in areas that avoid 

29 sensitive species and habitats. New wind energy projects would have noticeable impacts on 

30 avian and bat communities. Any new transmission lines would likely be collocated with existing 

31 right-of-way, which would minimize impacts to ecological resources. New and continued 

32 operation of coal-fired plants would have noticeable impacts primarily because of the deposition 

33 of ash and other pollutants and because of the extent of terrestrial habitat disturbance 

34 associated with coal mining.

35 Human Health: SMALL

36 New and continued operation of existing nuclear, coal-fired, and natural gas-fired plants and 

37 wind energy projects would not have noticeable impacts on human health because of the extent 

38 of regulations to protect public health.

39 Land Use: SMALL to LARGE 

40 Purchased power from existing nuclear power plants would not cause any land use changes. 

41 New power plants would be constructed at existing power plant sites. Purchased power from 

42 coal- and natural gas-fired plants could have a noticeable impact on land use because of the 

43 amount of land required for coal mining and gas drilling. Wind energy projects would have a 

44 noticeable land-use impact because of the large amount of land required for wind farms. Any 

45 new transmission lines would likely be collocated with existing right-of-way, which would 

46 minimize any land use impacts. 
Environmental Impacts of Alternatives

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1 Socioeconomics, Transportation, and Aesthetics: SMALL to LARGE

2 Purchased power from existing power plants would not have any socioeconomic impact, 

3 because there would be no change in power plant operations or workforce. Construction of new 

4 electrical power generating facilities could cause noticeable short-term socioeconomic and 

5 transportation impacts because of the number of construction workers required to build the new 

6 power plant. Traffic volumes would increase on local roads during shift changes. Continued 

7 operations of existing power plants would not have noticeable increased socioeconomic impacts 

8 as there would be no change in the number of workers at existing power generation facilities.

9 Wind energy projects would have the greatest visual impact; wind turbines would dominate the 

10 view and would likely become the major focus of attention.

11 Archaeological and Historic Properties: SMALL to LARGE

12 No direct impacts on historic and archaeological resources are expected from purchased power. 

13 If new transmission lines were needed to convey power to the PJM area, surveys similar to 

14 those discussed in Section 8.1.11 would need to be performed. However, transmission lines 

15 would likely be collocated with existing right-of-ways minimizing any impacts to historic and 

16 archaeological resources. 

17 Indirectly, construction of new nuclear, coal-fired, and natural gas-fired plants, wind energy 

18 projects and any new transmission lines to support the purchased power alternative could affect 

19 archaeological and historic resources. Any areas potentially affected by the construction would 

20 need to be surveyed to identify and record historic and archaeological resources. Resources 

21 found in these surveys would need to be evaluated for eligibility on the NRHP and mitigation of 

22 adverse effects would need to be addressed if eligible resources were encountered. Plant 

23 operators would need to survey all areas associated with operation of the alternative 

24 (e.g., roads, transmission corridors, other ROWs). The potential for impacts on historic and 

25 archaeological resources would vary greatly depending on the location of the proposed sites; 

26 however, using previously disturbed sites could greatly minimize impacts to historic and 

27 archaeological resources. Areas with the greatest sensitivity could be avoided or effectively 

28 managed under current laws and regulations. Therefore, depending on the resource richness of 

29 the sites chosen, the impacts could range from SMALL to LARGE. 

30 Environmental Justice

31 Low-income populations could be disproportionately affected by increased utility bills because of

32 the cost of purchased power. However, programs, such as the low income home energy 

33 assistance program in Pennsylvania, are available to assist low-income families in paying for 

34 increased electrical costs.

35 Waste Management: SMALL to MODERATE

36 New and continued operations of existing nuclear and natural gas-fired plants and wind energy 

37 projects would not have noticeable impacts. However, new and continued generation of 

38 coal-fired plants would have noticeable impacts because of the accumulation of ash and 

39 scrubber sludge. 

40 The impacts presented in Table 8–6 represent the potential range of impacts from relying on 

41 purchased power to replace LGS. Impacts from operation of other generators would likely occur 

42 elsewhere in PJM. The overall impacts would range from SMALL to MODERATE.
Environmental Impacts of Alternatives

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1 Table 8–6. Summary of Environmental Impacts of Purchased Power Compared to 

2 Continued Operation of the Existing LGS

Purchased Power Alternative Continued Operation of LGS 

Air Quality SMALL to MODERATE SMALL

Groundwater Resources SMALL SMALL

Surface Water Resources SMALL SMALL

Aguatic & Terrestrial Resources SMALL to MODERATE SMALL

Human Health SMALL SMALL

Land Use SMALL to LARGE SMALL

Socioeconomics (including 

transportation and aesthetics) SMALL to LARGE SMALL

Historic and Archaeological SMALL to LARGE SMALL

Waste Management SMALL to MODERATE SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS.

3 8.6. Alternatives Considered but Dismissed

4 Alternatives to LGS license renewal that were considered and eliminated from detailed study

5 are presented in this section. These alternatives were eliminated because of technical, 

6 resource availability, or current commercial limitations. Many of these limitations would continue 

7 to exist when the current LGS licenses expire.

8 8.6.1. Solar Power

9 Solar technologies, including photovoltaic (PV) and solar thermal (also known as concentrated 

10 solar power (CSP)), use the sun’s energy to produce electricity at a utility scale. In PV systems, 

11 special PV materials convert the energy contained in photons of sunlight incident to direct 

12 current (DC) electricity that can be aggregated, converted to alternating current (AC), and 

13 connected to the high-voltage transmission grid. Some PV installations, especially those 

14 located on existing buildings, provide power directly to consumers without first going onto the 

15 grid. CSP technologies produce electricity by capturing the sun’s heat energy. CSP facilities 

16 are typically grid connected, and owing to their size and operational characteristics, are not 

17 located atop existing structures. Although some aspects of solar generation result in few 

18 environmental impacts, solar technology requires substantial land areas, and CSP technologies 

19 require roughly the same amount of water for cooling of the steam cycle as most other 

20 thermoelectric technologies.

21 The potential for solar technologies to serve as reliable baseload power alternative to LGS 

22 depends on the value, constancy, and accessibility of the solar resource. Both PV and CSP are 

23 enjoying explosive growth worldwide, especially for various off-grid applications or to augment 

24 grid-provided power at the point of consumption; however, discrete baseload applications still 

25 have technological limitations. As Exelon indicates in the ER, solar power generation typically 

26 requires backup generation or other means of balancing its variable output. Further, PV 

27 installations have no ability to provide power at night, and they provide reduced levels of power 

28 on overcast days, during fog events, and when snow accumulates. While their generation 
Environmental Impacts of Alternatives

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1 during summer months is high when electricity consumption is high, their capacity to generate 

2 electricity in winter declines before the evening electricity demand peaks.

3 EIA reports the total solar generating capacity (CSP and solar PV) in the United States in 2009 

4 was 619 MW, 0.005 percent of the total nationwide generating capacity. Solar power produced 

5 891,000 MWh of power in 2009, 0.02 percent of the nationwide production (EIA 2011a). The 

6 staff is not aware of any CSP facilities in the United States that are not located in the southwest, 

7 while many PV installations occur throughout the country. As a result, the staff determined that 

8 a solar-powered alternative in PJM would rely on solar PV technology rather than CSP 

9 technology. 

10 Because PV does not produce electricity at night and produces diminished amounts of power 

11 during particular weather conditions, the staff does not consider solar PV to provide a viable, 

12 standalone alternative to license renewal. The staff considers a standalone PV alternative here, 

13 however, because Exelon includes solar PV in its range of alternatives to LGS license renewal 

14 in the ER, and because solar PV comprises a portion of the combination alternative in 

15 Section 8.6.2. 

16 This section addresses only the solar PV impacts, and does not address impacts from load 

17 balancing or firming methods, which would be necessary for solar to serve as a standalone

18 alternative to LGS. Technology to achieve load balancing or firming methods is not yet feasible 

19 or commercially available, which is part of the reason why the staff’s determined that this 

20 alternative is not reasonable. As a result, this analysis likely understates potential impacts from 

21 a solar PV alternative because technology to achieve load balancing or firming methods would 

22 also result in environmental impacts. As discussed in the wind power section, pumped 

23 hydroelectric storage, compressed air energy storage, and backup generating capacity could all 

24 conceivably offset the variable power output of solar PV facilities. Unlike wind power, however, 

25 interconnected solar installations cannot span a sufficient area to provide consistent output at 

26 night. 

27 Within PJM, solar PV installations receive a 38 percent capacity credit (PJM 2010). On this 

28 basis, approximately 6,160 MW(e) of solar capacity would be necessary to replace LGS. 

29 Exelon indicates that a utility-scale solar PV facility located in PJM receives 2.8 to 3.9 kWh of 

30 solar radiation per square meter per day (2011). (These estimates take into account average 

31 weather conditions, and they also account for solar unavailability at night. The estimate thus 

32 also accounts for solar capacity factors.) As a result, Exelon estimated that a solar PV facility 

33 would require approximately 6.5 ha (16 ac) per MW(e) of capacity (Exelon 2011). The total area 

34 necessary for solar PV installations, then, is approximately 40,000 ha (98,900 ac). 

35 The staff notes that much of the solar capacity installed in PJM is likely to be in the form of 

36 rooftop installations. This type of installation minimizes land disturbance, can provide electricity 

37 directly to end-users, and minimizes the modifications necessary to the transmission system. 

38 Some land-based installations are also likely to occur. They are likely to be larger than rooftop 

39 installations, and they will require some degree of land disturbance for installation purposes.

40 Environmental impacts from the solar PV alternative are summarized in Table 8–7. 

41 8.6.1.1. Air Quality

42 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

43 Pennsylvania, and is part of the Metropolitan Philadelphia Interstate Air Quality Control Region 

44 AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), 

45 EPA has designated Montgomery and Chester Counties as unclassified or in attainment with 

46 respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect 

47 to ozone and PM2.5 (40 CFR 81.339).
Environmental Impacts of Alternatives

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1 Beyond maintenance activities (e.g. serving equipment or repairs), there would be no routine air 

2 emissions associated with operations from solar PV. Activities associated with the construction 

3 and installation would cause some temporary air pollutant emissions. However, emissions from 

4 workers’ vehicles and construction equipment exhaust would be temporary. The staff concludes 

5 that the air quality impact from construction would be SMALL.

6 Greenhouse Gas Emissions 

7 Solar PV installations release no GHGs during operation, although some GHG emissions occur 

8 during component manufacturing, transportation, and installation, as well as during site 

9 preparation. Greenhouse gas emissions during construction of this alternative would result 

10 primarily from the consumption of fossil fuels in the engines of construction vehicles and 

11 equipment, workforce vehicles used in commuting to and from the work site, and delivery 

12 vehicles. However, all such impacts would be temporary. In general, solar PV installations are 

13 among the least carbon-intensive electric generation options available. For a comparison to 

14 other means of electric generation, see the discussion in Chapter 6. 

15 Given the expected small workforces and GHGs emitted during construction, site preparation 

16 and installation, the overall impact from the release of GHGs of the solar PV alternative would 

17 be SMALL.

18 Conclusion

19 Based on the above analysis, the impact would be SMALL. 

20 8.6.1.2. Groundwater Resources

21 For construction of solar PV installations, the need for groundwater dewatering likely would be 

22 minimal because of the small footprint and shallow depth of excavation for PV installations. For 

23 all construction activities, appropriate BMPs, including spill prevention practices, would be used 

24 during construction to prevent or minimize impacts on groundwater quality. Operation of PV 

25 units would not be expected to have any appreciable effect on groundwater resources. Based 

26 on the foregoing, the impacts on groundwater use and quality associated with the solar PV 

27 alternative would be SMALL.

28 8.6.1.3. Surface Water Resources

29 Siting and construction of solar PV installations would require relatively small amounts of water 

30 for dust suppression and soil compaction during site clearing and for concrete production. The 

31 NRC assumes that required water would be procured from offsite sources and trucked to the 

32 point of use on an as needed basis. Use of ready-mix concrete also would reduce the need for 

33 onsite use of nearby water sources. To support operations, water additionally would be 

34 required to clean PV panels. The staff expects that water would be trucked to the point of use 

35 and procured from nearby sources or could be supplied from a municipal water source. 

36 Adherence to appropriate waste management and minimization plans, spill prevention practices, 

37 and pollution prevention plans during servicing of PV installations would minimize the risks to 

38 soils and surface water resources from spills of petroleum, oil, and lubricant products and runoff. 

39 As a result, the impacts on surface water use and quality under this alternative would be 

40 SMALL.

41 8.6.1.4. Aquatic Resources

42 Construction activities for the solar PV alternative (such as construction of heavy-haul roads and 

43 the solar panels) could affect drainage areas or other onsite aquatic features. Minimal impacts 

44 on aquatic ecology resources are expected because BMPs would likely be used to minimize 

45 erosion and sedimentation at large facilities. Stormwater control measures, which would be 

46 required if an NPDES permit was necessary, would minimize the flow of disturbed soils into 
Environmental Impacts of Alternatives

8-52

1 aquatic features. Many of the solar panels would be installed on rooftops. Because 

2 construction would occur within an existing structure, impacts to aquatic resources would be 

3 minimal. During operations, the solar PV alternative would not require consumptive water use.

4 For installations that do not occur on top of existing buildings, operators of the solar PV 

5 alternative would need to assess the occurrence and potential impacts to protected aquatic 

6 species within surface waters potentially affected during construction. In compliance with the 

7 ESA, FWCA, and the Magnuson-Stevens Act, the solar PV operators would need to consult with 

8 state officials, NMFS, and FWS to determine whether any avoidance or mitigation measures 

9 would be required and to ensure that construction and operation do not adversely affect any 

10 Federally listed species or adversely modify or destroy designated critical habitat.

11 The impacts on aquatic ecology would be minor because construction activities would likely 

12 require BMPs and stormwater management permits. During operations, the solar PV alternative 

13 would not require consumptive water use. Therefore, impacts on aquatic ecology from the solar 

14 PV alternative would be SMALL.

15 8.6.1.5. Terrestrial Resources

Up to 155 mi2 (420 km2 16 ) of land would be needed to support a solar PV alternative to replace 

17 LGS if all installations were located at standalone solar sites (see Section 8.6.1.7). Because the 

18 solar PV alternative would include many relatively small installations on building roofs or existing 

19 residential, commercial, or industrial sites, impacts to terrestrial species and habitats would be 

20 minimal. Some installations may be built on standalone solar sites, and impacts to terrestrial 

21 species and habitats on these sites would vary greatly depending on site selection and the 

22 allocation of installations on buildings versus standalone sites. Because many of the 

23 installations would likely be installed in developed areas that are already connected to the 

24 regional electric grid, construction of additional transmission lines or access roads to solar PV 

25 installation sites would likely be unnecessary. The impacts of construction to terrestrial habitats 

26 and species could range from SMALL to MODERATE, and the impacts of operation to terrestrial 

27 habitats and species would be SMALL. 

28 Impacts to protected species and habitats would only occur in locations where solar PV 

29 installations are constructed on standalone solar sites. However, as with the previously 

30 discussed alternatives, consultation with FWS under the ESA would avoid any potential adverse 

31 impacts to Federally listed species or adverse modification or destruction of designated critical 

32 habitat. Coordination with state natural resource agencies would further ensure that Exelon 

33 would take appropriate steps to avoid or mitigate impacts to state-listed species, habitats of 

34 conservation concern, and other protected species and habitats. Consequently, the impacts of 

35 construction and operation of the solar PV alternative on protected species and habitats would 

36 be SMALL.

37 8.6.1.6. Human Health

38 The manufacture of solar cells involves the use of many hazardous chemicals, including toxic 

39 gases (e.g., arsine, phosphine, silane, sulfur hexafluoride, molybdenum hexafluoride, tungsten 

40 hexafluoride, hydrogen selenide, hydrochloric, and hydrofluoric acids), toxic metals 

41 (e.g., arsenic, cadmium, selenium, and various other heavy metals), and numerous flammable, 

42 corrosive, or highly reactive chemicals. In addition, the photocells contain cadmium, selenium, 

43 and other heavy metals. However, worker exposure to these hazards often are minimized. For 

44 example, a 2003 study conducted jointly by the Electric Power Research Institute (EPRI) and 

45 the California Energy Commission (CEC) concluded that the manufacture and use of photocells 

46 presented no significant health or environmental risk (EPRI and CEC 2003). In the study, EPRI 

47 and CEC (2003) state that the greatest possibility of human health risks comes from the 
Environmental Impacts of Alternatives

8-53

1 manufacturing of the solar PV cells. The study states that, because of these health risks, 

2 extensive work has been done to reduce those hazards to plant workers. It also states that 

3 OSHA and similar state agencies set standards for allowable exposure limits to the various toxic 

4 chemicals used in the manufacturing process.

5 Impacts on human health from construction of the solar PV alternative would be similar to 

6 impacts associated with the construction of any major industrial facility. Compliance with worker 

7 protection rules would control those impacts on workers at acceptable levels. Impacts from 

8 construction on the general public would be minimal since limiting active construction area 

9 access to authorized individuals is expected. Impacts on human health from the construction of 

10 the solar PV alternative would be SMALL.

11 Solar PV panels are encased in heavy-duty glass or plastic. As a result, there is little risk that 

12 the small amounts of hazardous semiconductor material they contain will be released into the 

13 environment. 

14 In the event of a fire, hazardous particulate matter could be released to the atmosphere. Given 

15 the short duration of fires and the high melting points of the materials found in the solar 

16 photovoltaic panels, the impacts from inhalation are minimal. Also, the risk of fire at 

17 ground-mounted solar installations is minimal because of precautions taken during site 

18 preparation, such as the removal of fuels and the lack of burnable materials contained in the 

19 solar photovoltaic panels. Another potential risk associated with photovoltaic systems and fire is 

20 the potential for shock or electrocution if a person would come in contact with a high-voltage 

21 conductor. Proper procedures and clear marking of system components should be used to 

22 provide emergency responders with appropriate warnings to diminish risk of shock or 

23 electrocution (OIPP 2010).

24 Photovoltaic solar panels do not produce electromagnetic fields at levels considered harmful to 

25 human health established by the International Commission on Non-Ionizing Radiation 

26 Protection. These small electromagnetic fields diminish significantly with distance and are 

27 indistinguishable from normal background levels within several yards (OIPP 2010). 

28 Overall, given proper health-based regulation through procedures and access limitations, the 

29 staff expects human health impacts from operation of the Solar PV alternative at an alternate 

30 site to be SMALL.

31 8.6.1.7. Land Use

32 As discussed in Section 8.1.7, the GEIS generically evaluates the impact of constructing and 

33 operating various replacement power plant alternatives on land use, both on and off each power 

34 plant site. The analysis of land-use impacts focuses on the amount of land area that would be 

35 affected by the installation and operation of solar PV technologies. PV technologies would 

36 generally be installed on building roofs at existing residential, commercial, or industrial sites. 

37 Some solar installations may also be built at standalone solar sites. Land use impacts may vary 

38 depending on the amount of additional land required and the actual allocation of solar 

39 installations.

40 The footprint of a utility scale standalone PV solar installation would be quite large. Based on 

Exelon’s local PJM territory estimates, approximately 98,900 ac (40,000 ha or 155 mi2 41

[400 km2 42 ]) of land would be needed to support a solar PV alternative to replace the LGS 

43 (Exelon 2011). Land required for a standalone PV solar installation would alter the existing land 

44 to energy production, and would preclude most other land uses from coexisting. Land would 

45 also be needed for transmission lines to connect PV solar installations to the electrical power 

46 grid and site access roads for maintenance purposes. Installing PV solar technologies on 

47 building rooftops would reduce the amount of land required for standalone solar.
Environmental Impacts of Alternatives

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1 The elimination of uranium fuel for the LGS would partially offset some, but not all, of the land 

2 requirements for standalone PV solar sites. Scaling from GEIS estimates, approximately 

3 1,640 ac (660 ha) (NRC 1996) would no longer be needed for mining and processing uranium 

4 during the operating life of the plant. Based on this information, overall land-use impacts from 

5 the construction and operation of a PV solar alternative could range from SMALL to LARGE, 

6 depending in part on the extent to which PV installations occur on existing buildings rather than 

7 standalone sites.

8 8.6.1.8. Socioeconomics

9 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

10 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

11 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 

12 long-term socioeconomic impacts. Workforce requirements for the construction and operation 

13 of the PV alternative were evaluated in order to measure their possible effects on current 

14 socioeconomic conditions.

15 Exelon estimated 200 construction and 50 operations workers would be required for this 

16 alternative (Exelon 2011). These estimates appear reasonable and in line with current 

17 construction and operational trends. Because of the relatively small number of construction 

18 workers and the potentially large area covered by the PV solar installations at standalone sites 

19 and other locations, the relative economic impact of this many workers on local communities 

20 and the tax base would be SMALL. Given the small number of operations workers, 

21 socioeconomic impacts associated with operation of the PV solar installations would also be 

22 SMALL.

23 The reduction in employment at LGS could affect property tax revenue and income in local 

24 communities and businesses. In addition, the permanent housing market could also experience 

25 increased vacancies and decreased prices if operations workers and their families move out of 

26 the LGS region. However, the amount of property taxes paid for a utility-scale standalone PV 

27 solar installation may offset lost tax revenues in the socioeconomic region around local 

28 jurisdictions if more land is required for solar installations. Based on this information, 

29 socioeconomic impacts during PV solar power generating operations could range from SMALL 

30 to MODERATE.

31 8.6.1.9. Transportation

32 Transportation impacts during the construction and operation of the PV alternative would be 

33 similar to the wind alternative, discussed in Section 8.4.10, as a smaller construction workforce 

34 and smaller volume of materials and equipment would be needed to be transported to the 

35 construction site.

36 During periods of peak construction activity, up to 200 workers could be commuting daily to the 

37 sites (Exelon 2011). Workers commuting to the construction sites would arrive by site access 

38 roads and the volume of traffic on nearby roads could increase during shift changes. In addition 

39 to commuting workers, trucks would be transporting construction materials and equipment to the 

40 worksites, thus increasing the amount of traffic on local roads. The increase in vehicular traffic 

41 would peak during shift changes, resulting in temporary levels of service impacts and delays at 

42 intersections. Delays may not be noticeable because the solar alternative may be spread 

43 across multiple sites. Some components and materials could also be delivered by train or 

44 barge, depending on the locations. Train deliveries could cause additional traffic delays at 

45 railroad crossings. Based on this information, traffic related transportation impacts during 

46 construction could range from SMALL to MODERATE depending on the location of the 

47 standalone site, road capacities, and traffic volumes.
Environmental Impacts of Alternatives

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1 During plant operations transportation impacts would not be noticeable because of the small 

2 estimated operational workforce spread across multiple sites. Exelon estimated an operational 

3 workforce of 50 workers (Exelon 2011), which appears reasonable. Given the small numbers of 

4 operations workers, the traffic impacts on local roads from PV solar installation operations would 

5 be SMALL.

6 8.6.1.10. Aesthetics

7 The analysis of aesthetic impacts focuses on the degree of contrast between PV solar 

8 installations and the surrounding landscape and the visibility of PV installed technologies. In 

9 general, aesthetic changes would be limited to the immediate vicinity of PV solar installations.

10 As previously discussed, the footprint of a utility scale standalone PV solar installation would be 

11 quite large, and could create a noticeable visual impact. Spread across a large site, the utility 

12 scale standalone PV solar installation could dominate the view and would likely become the 

13 major focus of attention. The introduction of a utility scale standalone PV solar installation 

14 would be in sharp contrast to the visual appearance of the surrounding environment. Installing 

15 PV solar technologies on building rooftops, although noticeable to a lesser degree in urban 

16 settings, would reduce the amount of land required for standalone solar sites. Any noise at 

17 utility scale standalone PV solar installation would be limited to industrial processes and 

18 communications. Based on this information, aesthetic impacts from the construction and 

19 operation of a PV alternative could range from MODERATE to LARGE depending on the type of 

20 solar technology installed and its location and surroundings.

21 8.6.1.11. Historic and Archaeological Resources

22 Any areas potentially affected by the construction of the solar alternative would need to be 

23 surveyed to identify and record historic and archaeological resources. Resources found in 

24 these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse 

25 effects would need to be addressed if eligible resources were encountered. Plant operators 

26 would need to survey all areas associated with operation of the alternative (e.g., roads, 

27 transmission corridors, other ROWs). Visual impacts on significant cultural resources—such as 

28 the viewsheds of historic properties near the sites—should also be assessed.

29 The impacts of the construction of a new solar PV alternative on historic and archaeological 

30 resources will vary depending on the form of the solar capacity installed in PJM. Rooftop 

31 installations minimize land disturbance and the modifications necessary to the transmission 

32 system, thereby minimizing impacts to historic and archaeological resources. Land-based 

33 installations are larger than rooftop installations and will require some degree of land 

34 disturbance for installation purposes, potentially causing greater impacts to historic and 

35 archaeological resources. Aesthetic changes caused by the installation of both forms could 

36 have a noticeable effect on the viewshed of nearby historic properties. Using previously 

37 disturbed sites for land-based installations and collocating any new transmission lines with 

38 existing right-of-ways could minimize impacts to historic and archaeological resources. Areas 

39 with the greatest sensitivity could be avoided or effectively managed under current laws and 

40 regulations. Therefore, depending on the resource richness of the sites chosen and the type of 

41 solar technology installed, the impacts could range from SMALL to LARGE. 

42 8.6.1.13. Environmental Justice

43 The environmental justice impact analysis evaluates the potential for disproportionately high and 

44 adverse human health, environmental, and socioeconomic effects on minority and low-income 

45 populations that could result from the construction and operation of PV solar installations. As 

46 previously discussed in Section 8.1.12, such effects may include human health, biological, 

47 cultural, economic, or social impacts.
Environmental Impacts of Alternatives

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1 Potential impacts to minority and low-income populations would mostly consist of environmental 

2 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

3 housing impacts). Noise and dust impacts during construction would be short term and 

4 primarily limited to onsite activities. Minority and low-income populations residing along site 

5 access roads would be affected by increased commuter vehicle and truck traffic. However, 

6 because of the temporary nature of construction, these effects would only occur during certain 

7 hours of the day and not likely to be high and adverse and would be contained to a limited time 

8 period during certain hours of the day. Increased demand for rental housing during construction 

9 could affect low-income populations. However, given the small number of construction workers 

10 and the possibility that workers could commute to the construction site, the need for rental 

11 housing would not be significant. 

12 Minority and low-income populations living in close proximity to the PV solar installations could 

13 be disproportionately affected by operations. However, operational impacts would mostly be 

14 limited to aesthetic effects. The general public living near the PV solar installation would also be 

15 exposed to the same effects.

16 Based on this information and the analysis of human health and environmental impacts 

17 presented in this SEIS, the construction and operation of PV solar installations would not have 

18 disproportionately high and adverse human health and environmental effects on minority and 

19 low-income populations.

20 8.6.1.14. Waste Management

21 During the construction stage of a solar PV facility, land clearing and other construction 

22 activities would produce minor quantities of waste. During operation, very small quantities of 

23 waste might be produced when operators perform maintenance activities. Based on this 

24 information, waste impacts would be SMALL for the solar PV alternative.

25 Table 8–7. Summary of Environmental Impacts of the Solar PV Alternative Compared to 

26 Continued Operation of the Existing LGS

Solar PV Alternative Continued LGS Operation

Air Quality SMALL SMALL

Groundwater Resources SMALL SMALL

Surface Water Resources SMALL SMALL

Aquatic Ecology SMALL SMALL

Terrestrial Ecology SMALL to MODERATE SMALL

Human Health SMALL SMALL

Land Use SMALL to LARGE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics MODERATE to LARGE SMALL

Historic and Archaeological SMALL to LARGE SMALL

Waste Management SMALL SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS
Environmental Impacts of Alternatives

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1 8.6.2. Combination Alternative: Wind, Solar, and NGCC

2 The combination alternative consists of 2,300 MW(e) of installed wind capacity, 3,000 MW(e) of 

3 solar PV capacity, and 400 MW(e) of NGCC capacity to provide the balance needed to replace 

4 LGS. The impacts of this alternative are similar to the combined and scaled impacts of the 

5 NGCC, wind, and solar PV alternatives considered in Sections 8.1, 8.4, and 8.6.1, respectively. 

6 The staff assumes that sufficient rooftop space exists throughout PJM to support installation of 

7 the solar-PV portion of this alternative solely on existing structures, thus minimizing potential for 

8 land-use and terrestrial ecology impacts from solar PV installations. The staff applied a 

9 capacity-factor-based approach to determining the relative amount of wind power (much as it 

10 did in Section 8.4), and applied a capacity-credit approach to solar-PV capacity (using PJM’s 

11 38 percent capacity credit) in this alternative. The NGCC capacity considered here provides 

12 backup and firming capacity to the variable wind and solar PV resources, though it may not be 

13 adequate to provide full firming capacity at all times (e.g., on nights with little wind across PJM). 

14 At the same time, this alternative may produce markedly more power than LGS on days that are 

15 both sunny and windy.

16 Because this alternative many not be able to generate 2,340 MW(e) because of the variable 

17 wind and solar PV resources, the staff does not consider the wind, solar, and NGCC 

18 combination alternative to provide a viable, standalone alternative to license renewal. The staff 

19 considers a standalone alternative here, however, because Exelon includes a wind, solar, and 

20 NGCC combination alternative in its range of alternatives to LGS license renewal in the ER. 

21 Table 8–8 summarizes the environmental impacts of the combination alternative compared to 

22 the continued operation of LGS.

23 8.6.2.1. Air Quality

24 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

25 Pennsylvania, and is part of the Metropolitan Philadelphia Interstate Air Quality Control Region 

26 AQCR (40 CFR 81.15). With regard to the National Ambient Air Quality Standards (NAAQS), 

27 EPA has designated Montgomery and Chester Counties as unclassified or in attainment with 

28 respect to carbon monoxide, lead, sulfur dioxide, and PM10; and nonattainment with respect to 

29 ozone and PM2.5 (40 CFR 81.339).

30 This alternative includes a combination of generation from wind, solar, and NGCC capacity. 

31 Operational air emissions would only be associated with the NGCC portion (400 MW[e]) of this 

32 alternative. The NGCC component would qualify as a new major-emitting industrial facility and 

33 would be subject to PSD under CAA requirements (EPA 2012a). The Pennsylvania Department 

34 of Environmental Protection (PADEP) has adopted 25 Pa. Code Chapter 127, which implements 

35 the EPA’s PSD review. The NGCC plant would need to comply with the standards of 

36 performance for stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK.

37 Subpart P of 40 CFR Part 51.307 contains the visibility protection regulatory requirements, 

38 including the review of the new sources that may affect visibility in any Federal Class I area. If 

39 the NGCC component of this combination alternative were located close to a mandatory Class I 

40 area, additional air pollution control requirements would be required. As noted in 

41 Section 2.2.2.1, there are no Mandatory Class I Federal areas within 50 miles (80 km) of the 

42 LGS site. There are a total of 13 designated Class 1 Federal areas (40 CFR 81) located in the 

43 following PJM states: Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, 

44 and West Virginia. 

45 A new NGCC plant would have to comply with Title IV of the CAA (42 USC §7651) reduction 

46 requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause 

47 of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the 
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1 existing plants and a system of SO2 emission allowances that can be used, sold, or saved for 

2 future use by the new plants.

3 More recently, EPA has promulgated additional rules and requirements that apply to certain 

4 fossil-fueled power plants, such as NGCC generation. The Cross-State Air Pollution Rule 

5 (CSAPR) and the Prevention of Significant Deterioration and Title V Greenhouse Gas (GHG) 

6 Tailoring Rule impose several additional standards to limit ozone, particulate, and GHG 

7 emissions from fossil-fuel based power plants (EPA 2012c). A new NGCC plant would be 

8 subject to these additional rules and regulations. 

9 The EPA has developed standard emission factors that relate the quantity of released air 

10 pollutants to a variety of regulated activities (EPA 2012b). Using these emission factors, the 

11 staff projects the following air emissions for the NGCC portion of this alternative: 

12 • sulfur oxides (SOx) – 31.4 tons (28.5 MT) per year, 

13 • nitrogen oxides (NOx) – 91.5 tons (83.0 MT) per year, 

14 • carbon monoxide (CO) – 138.7 tons (125.8 MT) per year, 

15 • PM10 and PM2.5 – 61.0 tons (55.4 MT) per year, and

16 • carbon dioxide (CO2) – 1,016,100 tons (922,622 MT) per year.

17 Activities associated with the construction of the combination alternative, which includes wind, 

18 solar, and NGCC, would cause some additional, temporary air effects as a result of equipment 

19 emissions and fugitive dust from operation of the earth-moving and material-handling 

20 equipment. Emissions from workers’ vehicles and motorized construction equipment exhaust 

21 would be temporary. Construction crews would use dust-control practices to control and reduce 

22 fugitive dust. The staff concludes that the impact of vehicle exhaust emissions and fugitive dust 

23 from operation of the earth-moving and material-handling equipment would be SMALL. 

24 Greenhouse Gas Emissions

25 As discussed in Sections 8.1.1 and 8.2.1, combustion of fossil fuels, including natural gas, is the 

26 greatest anthropogenic source of GHG emissions in the United States. As noted in 

27 Sections 8.4.1 and 8.6.1.1—and discussed in Section 6.2—wind power and solar PV generation 

28 are among the least GHG-intensive generation options available. 

29 Greenhouse gas emissions during construction of this alternative would result primarily from the 

30 consumption of fossil fuels in the engines of construction vehicles and equipment, workforce 

31 vehicles used in commuting to and from the work site, and delivery vehicles. However, all such 

32 impacts would be temporary. 

33 Only the NGCC portion of this alternative would emit GHGs during operations, and it would emit 

34 approximately 25 percent of the emissions of the full NGCC alternative that the staff evaluated

35 in Section 8.1.1. As discussed in Section 8.1.1, NETL estimates that CCS will capture and 

36 remove as much as 90 percent of the CO2 from the exhausts of combustion turbines but will 

37 result in a power production capacity decrease of approximately 14 percent, a reduction in net 

38 overall thermal efficiency of the CTs studied from 50.8 percent to 43.7 percent, and a potential 

39 increase in the levelized cost of electricity produced in NGCC units so equipped by as much as 

40 30 percent (NETL 2007). Further, permanent sequestering of the CO2 would involve removing 

41 impurities (including water) and pressurizing it to meet pipeline specifications and transferring 

42 the gas by pipeline to acceptable geologic formations. Even when opportunities exist to utilize 

43 the CO2 for enhanced oil recovery (rather than simply dispose of the CO2 in geologic 

44 formations), permanent disposal costs could be substantial, especially if the NGCC unit is far 

45 removed from acceptable geologic formations. With CCS in place, the NGCC portion of this 

46 alternative would release 92,262 MT per year (0.102 million tons) of CO2. Without CCS in place, 
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1 the staff’s projected CO2 emissions for the NGCC portion would be 922,622 MT (1,016,100 

2 tons) per year. 

3 Given the expected relatively small workforces, relatively short construction period for 

4 constructing the alternatives’ components, and GHG emissions resulting from operations of the 

5 NGCC portion, the overall from the releases of GHGs of the combination alternative would be 

6 SMALL to MODERATE. 

7 Conclusion

8 There would be no routine air emissions associated with the wind and solar component of this 

9 alternative. However, the NGCC component of this alternative would result in routine air 

10 emissions. Therefore, the overall air-quality impact from this combination alternative would be 

11 SMALL to MODERATE.

12 8.6.2.2. Groundwater Resources

13 Impacts on groundwater resources from constructing and operating a new NGCC plant under 

14 this alternative would be a fraction of those described in Section 8.1.2. For construction of wind 

15 turbine and solar PV installations, the need for groundwater dewatering likely would be minimal. 

16 For all construction activities, appropriate BMPs, including spill prevention practices, would be 

17 used during wind turbine construction to prevent or minimize impacts on groundwater quality. 

18 Operation of the wind turbine and PV components of this alternative would not be expected to 

19 have any appreciable effect on groundwater resources. Based on the above, the impacts on 

20 groundwater use and quality under this alternative would be SMALL.

21 8.6.2.3. Surface Water Resources

22 Impacts on surface water resources from constructing and operating a new NGCC plant under 

23 this alternative would be a fraction of those described in Section 8.1.3 because the NGCC 

24 component has been scaled back to 400 MW(e). Construction of the wind turbine and solar PV 

25 installations would each require relatively small amounts of water for dust suppression and soil 

26 compaction during site clearing and for concrete production. The NRC assumes that required 

27 water would be procured from offsite sources and trucked to the point of use on an as needed 

28 basis. Use of ready-mix concrete would also reduce the need for onsite use of nearby water 

29 sources.

30 To support operation of individual wind turbine installations, only very small amounts of water 

31 would be needed to periodically clean turbine blades and motors as part of routine servicing. 

32 Water also would be required to clean PV panels. The staff expects that water would be 

33 trucked to the point of use and procured from nearby sources. Adherence to appropriate waste 

34 management and minimization plans, spill prevention practices, and pollution prevention plans 

35 during servicing of turbine and PV installations would minimize the risks to soils and surface 

36 water resources from spills of petroleum, oil, and lubricant products and runoff. As a result, the 

37 impacts on surface water use and quality under the combination alternative would be SMALL.

38 8.6.2.4. Aquatic Resources

39 Construction activities for the wind, solar, and NGCC combination alternative (such as 

40 construction of heavy-haul roads, the NGCC power block, wind turbines, and solar panels) 

41 could affect drainage areas or other onsite aquatic features. Minimal impacts on aquatic 

42 ecology resources are expected because BMPs would likely be used to minimize erosion and 

43 sedimentation. Stormwater control measures, which would be required to comply with 

44 Pennsylvania NPDES permitting, would minimize the flow of disturbed soils into aquatic 

45 features. Depending on the available infrastructure at the selected site, the NGCC plant may 

46 require modification or expansion of the existing intake or discharge structures. Because of the 
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1 relatively low withdrawal rates compared to the NGCC, SCPC, or new nuclear alternatives, it is 

2 unlikely that the operators would need to construct new intake and discharge structures for the 

3 combination alternative. Dredging activities that result from infrastructure construction would 

4 require BMPs for in-water work to minimize sedimentation and erosion. Because of the 

5 short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would 

6 likely be localized and temporary.

7 Similar to the NGCC alternative described in Section 8.1.4, during operations, the NGCC 

8 component of the combination alternative would require cooling water to be withdrawn from the 

9 Schuylkill River or other similar water body, would have chemical discharges, and would emit 

10 some pollutants that could settle onto the river surface. However, these impacts would be less 

11 than that described in Section 8.1.4 because NGCC would be a smaller portion of this 

12 alternative. During operations, the solar PV and wind components of the combination 

13 alternative would not require consumptive water use.

14 The impacts on aquatic ecology would be minor because construction activities would require 

15 BMPs and stormwater management permits, and because the surface water withdrawal and 

16 discharge for this alternative would be less than for LGS Units 1 and 2. Therefore, the staff 

17 concluded that impacts on aquatic ecology would be SMALL.

18 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 

19 of wind, solar, NGCC plants would not adversely affect any Federally listed species or adversely 

20 modify or destroy designated critical habitat. If new infrastructure were located near EFH, 

21 consultation with NMFS under the Magnuson-Stevens Act would require NRC to evaluate 

22 impacts to EFH and NMFS would provide conservation recommendations if there would be 

23 adverse impacts to EFH. Coordination with state natural resource agencies would further 

24 ensure that the plant and wind farm operators would take appropriate steps to avoid or mitigate 

25 impacts to state-listed species, habitats of conservation concern, and other protected species 

26 and habitats. Consequently, the impacts of construction and operation on protected species 

27 and habitats would be SMALL. 

28 8.6.2.5. Terrestrial Resources

29 Impacts to terrestrial species and habitats from construction and operation of this combined 

30 alternative would be similar to those described under each individual alternative in 

31 Sections 8.1.5, 8.4.5, and 8.6.1.5. The same is true of mitigation measures. The primary 

32 difference in this alternative is that each portion of this alternative is smaller than the 

33 full-replacement alternatives considered in Sections 8.1, 8.4, and 8.8.1. Also, solar PV capacity 

34 would be installed almost entirely at already-developed sites on building rooftops. The 

35 wind-power portion of this alternative would require approximately half of the area required for 

36 the standalone wind alternative in Section 8.4. The development of the solar component on 

37 land already in use for other purposes, combined with the reduced size of the wind-power 

38 component, would likely result in minimal additional impacts to terrestrial species and habitats 

39 during construction and operation. The NGCC component of this alternative would be smaller 

40 and require less land than the NGCC plant described in Section 8.1.5. This alternative still 

41 assumes that the NGCC plant would be sited on an already existing power station other than 

42 LGS, and predominantly previously developed or pre-disturbed land would be affected. The 

43 impacts of construction and operation of this alternative on terrestrial species and habitats 

44 would be SMALL because of this alternative’s extensive use of developed or previously 

45 disturbed land.

46 Because the solar PV installations would be sited on buildings and other already-developed 

47 sites, impacts to protected species and habitats would be most likely to occur as a result of the 

48 wind or NGCC component of this alternative. As with the previously discussed alternatives, 
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1 consultation with FWS under the ESA would avoid potential adverse impacts to Federally listed 

2 species or adverse modification or destruction of designated critical habitat. Coordination with 

3 state natural resource agencies would further ensure that Exelon would take appropriate steps 

4 to avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other 

5 protected species and habitats. Consequently, the impacts of construction and operation of this 

6 alternative on protected species and habitats would be SMALL.

7 8.6.2.6. Human Health

8 Impacts on human health from construction of the wind alternative, the NGCC alternative, and 

9 the solar PV portion of this alternative would be similar to impacts associated with the 

10 construction of any major industrial facility. Compliance with worker protection rules would 

11 control those impacts on workers at acceptable levels. Impacts from construction on the 

12 general public would be minimal since limiting active construction area access to authorized 

13 individuals is expected. Impacts on human health from the construction of the wind alternative 

14 would be SMALL.

15 Given proper health-based regulation through procedures and access limitations, the staff

16 expects human health impacts from operation of the solar PV and the wind portions of this 

17 alternative at an alternate site to be SMALL. 

18 The staff notes that human health effects of gas-fired generation are generally low, although in 

19 Table 8–2 of the GEIS (NRC 1996), the staff identified cancer and emphysema as potential 

20 health risks from gas-fired plants. NOx emissions contribute to ozone formation, which in turn 

21 contributes to human health risks. Emission controls on the NGCC alternative can be expected 

22 to maintain NOx emissions well below air quality standards established for the purposes of 

23 protecting human health, and emissions trading or offset requirements mean that overall NOx

24 releases in the region will not increase. Health risks for workers may also result from handling 

25 spent catalysts used for NOx control that may contain heavy metals. Impacts on human health 

26 from the operation of the NGCC alternative would be SMALL.

27 8.6.2.7. Land Use

28 As discussed in Section 8.1.7, the GEIS (NRC 1996) generically discusses the impact of 

29 constructing and operating various replacement power plant alternatives on land use, both on 

30 and off each power plant site. The analysis of land-use impacts here focuses on the amount of 

31 land area that would be affected by the construction and operation of a combination of wind 

32 turbines, PV solar installations, and a NGCC power plant in the PJM territory.

33 Land-use impacts from this alternative would be similar those described for each of the 

34 alternatives described in Sections 8.1.7, 8.4.7, and 8.6.1.7. Because each component of this 

35 alternative would individually be generating less electricity, the magnitude of the impacts from 

36 each individual component would be less than those previously described. For example, under 

37 this combination alternative, solar PV technology would be installed on existing building 

38 rooftops, and approximately half the number of wind turbines would be installed as would be 

39 installed in the standalone wind alternative (Section 8.4). In addition, the NGCC component 

40 would be constructed at an existing power plant site.

41 The elimination of uranium fuel for the LGS would partially offset some, but not all, new land 

42 requirements. Scaling from GEIS estimates, approximately 1,640 ac (660 ha) would no longer 

43 be needed for mining and processing uranium during the operating life of the plant. Based on 

44 this information, overall land-use impacts from the construction and operation of a combination 

45 of wind, solar, and NGCC alternatives would range from SMALL to MODERATE.
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1 8.6.2.8. Socioeconomics

2 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

3 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

4 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 

5 long-term socioeconomic impacts. Workforce requirements for the construction and operation 

6 of a combination of wind turbines, PV solar installations, and a NGCC power plant were 

7 evaluated in order to measure their possible effects on current socioeconomic conditions.

8 Approximately 200 construction and 50 operations workers would be required for the utility scale 

9 wind alternative and 200 construction and 50 operations workers would be required for the

10 solar alternative (see Sections 8.4.8, and 8.6.1.8) (Exelon 2011). These estimates appear 

11 reasonable and in line with current construction and operational trends. The construction and 

12 operation workforce requirements for these two components of this combination alternative 

13 would be much less. The NGCC component scaled down to 400 MW(e) would require 150 

14 (Exelon 2011) to 500 (NRC 1996) construction workers during peak construction and 8 to 

15 60 operations workers. Socioeconomic impacts would be similar to those described for NGCC, 

16 wind, and solar alternatives discussed in Sections 8.1.8, 8.4.8, and 8.6.1.8, but on a smaller 

17 scale than each of the full alternatives. Because of the relatively small number of construction 

18 workers scattered over a large area at various locations, the relative economic impact of this 

19 many workers on local communities and the tax base would be SMALL. Given the small 

20 number of operations workers, socioeconomic impacts associated with operation of the NGCC, 

21 wind, and solar components of this combination alternative would also be SMALL.

22 The net reduction in employment at LGS could affect property tax revenue and income in local 

23 communities and businesses. In addition, the permanent housing market could also experience 

24 increased vacancies and decreased prices if operations workers and their families move out of 

25 the region. Nevertheless, the amount of property taxes paid under the combination alternative 

26 may offset lost tax revenues in the socioeconomic region around LGS. Based on this 

27 information, socioeconomic impacts during operations could range from SMALL to MODERATE.

28 8.6.2.9. Transportation

29 Transportation impacts during the construction and operation of the NGCC, wind, and solar 

30 components of this combination alternative would be less than the impacts for the NGCC, wind, 

31 and PV solar alternatives, discussed in Sections 8.1.7, 8.4.7, and 8.6.1.7. This is because the

32 construction workforce for each component and the volume of materials and equipment needing 

33 to be transported to each respective construction site would be smaller than each of the 

34 individual alternatives. In other words, the transportation impacts would not be as concentrated 

35 as in the other alternatives, but spread out over a wider area.

36 As previously described for each alternative, workers commuting to the construction site would 

37 arrive by site access roads and the volume of traffic on nearby roads could increase during shift 

38 changes. In addition to commuting workers, trucks would be transporting construction materials 

39 and equipment to the worksite, thus increasing the amount of traffic on local roads. The 

40 increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 

41 service impacts and delays at intersections. Transporting heavy and oversized wind turbine 

42 components on local roads could have a noticeable impact over a large area. Some 

43 components and materials could also be delivered by train or barge, depending on location. 

44 Train deliveries could cause additional traffic delays at railroad crossings. Based on this 

45 information, traffic-related transportation impacts during construction could range from SMALL 

46 to MODERATE depending on the location of the NGCC power plant, wind farm, and PV solar 

47 installation; road capacities; and traffic volumes.
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1 During operations, transportation impacts would be less noticeable during shift changes and 

2 maintenance activities. Given the small number of operations workers, the levels of service 

3 traffic impacts on local roads from NGCC power plant, wind farm, and PV solar installation 

4 operations would be SMALL.

5 8.6.2.10. Aesthetics

6 The analysis of aesthetic impacts focuses on the degree of contrast between the wind, solar, 

7 and NGCC alternative and surrounding landscapes and the visibility of new wind turbines at 

8 existing wind farms, PV solar technologies on existing buildings, and the new NGCC plant at an 

9 existing power plant site. In general, aesthetic changes would be limited to the immediate 

10 vicinity of the wind farms, PV solar installations, and NGCC power plant.

11 Wind turbines would have the greatest potential visual impact. At 400 ft (122 m) tall 

12 (Exelon 2011) and spread across multiple sites, wind turbines often dominate the view and 

13 become the major focus of attention. However, adding additional wind turbines to existing wind 

14 farms at multiple sites is not likely to increase the visible impact of the wind farm unless it 

15 significantly increases the number of wind turbines at the wind farm. PV solar technologies 

16 located on building rooftops, depending on the angle of the roof, may or may not be seen offsite, 

17 and would be less noticeable in urban settings.

18 Located near an existing power plant site, the NGCC power plant could be approximately 100 ft 

19 (30 m) tall, with an exhaust stack up to 150 ft (46 m) tall and have two cooling towers over 500 ft 

20 (152 m) high (Exelon 2011). The facility would be visible off site during daylight hours, and 

21 some structures may require aircraft warning lights. The power block of the new NGCC power 

22 plant unit could look very similar to the existing power plant at the site where it would be 

23 constructed. The addition of mechanical draft cooling towers and associated condensate 

24 plumes could add to the NGCC power plant visual impact. Mechanical draft cooling towers also 

25 generate noise. Most other noises during power NGCC plant operations would be limited to 

26 industrial processes and communications. Pipelines delivering natural gas fuel could be audible 

27 off site near gas compressor stations.

28 Based on this information, aesthetic changes caused by this combination alternative would be 

29 limited to the immediate vicinity of the existing facilities and would therefore be SMALL to 

30 MODERATE depending on location and surroundings.

31 8.6.2.11. Historic and Archaeological Resources

32 Areas potentially affected by the construction of the NGCC, wind, and solar PV alternative 

33 would need to be surveyed to identify and record historic and archaeological resources. Any 

34 resources found in these surveys would need to be evaluated for eligibility on the NRHP and 

35 mitigation of adverse effects would need to be addressed if eligible resources were 

36 encountered. An inventory of a previously disturbed former plant (brownfield) site may still be 

37 necessary if the site has not been previously surveyed or to verify the level of disturbance and 

38 evaluate the potential for intact subsurface resources. Plant operators would need to survey all 

39 areas associated with operation of the alternative (e.g., roads, transmission corridors, other 

40 ROWs). Areas with the greatest sensitivity should be avoided. Visual impacts on significant 

41 cultural resources—such as the viewsheds of historic properties near the sites—should also be 

42 assessed.

43 The impacts of this alternative are similar to the combined and scaled impacts of the NGCC, 

44 wind, and solar PV alternatives considered in Sections 8.1, 8.4, and 8.6.1, respectively. The 

45 potential for impacts would vary greatly depending on the location of the proposed sites. Use of

46 a previously disturbed site for the NGCC alternative and rooftop PV technology could minimize 

47 affects to historic and archaeological resources. Wind turbines could be installed in 
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1 pre-established wind farms. Areas with the greatest sensitivity could be avoided or effectively 

2 managed under current laws and regulations. However, construction of wind farms sites and 

3 their support infrastructure on developed sites, agricultural areas, or previously undisturbed 

4 have the potential to notably impact historic and archaeological resources because of 

5 earthmoving activities (e.g., grading and digging). Aesthetic changes from wind farms and solar 

6 technology may also impact the viewshed of historic properties located nearby. Therefore, 

7 depending on the resource richness of the site chosen for the NGCC, wind, and solar PV 

8 alternative, the impacts could range from SMALL to MODERATE. 

9 8.6.2.12. Environmental Justice

10 The environmental justice impact analysis evaluates the potential for disproportionately high and 

11 adverse human health, environmental, and socioeconomic effects on minority and low-income 

12 populations that could result from the construction and operation of a combination of wind 

13 turbines, PV solar installations, and a NGCC power plant. As previously discussed in 

14 Section 8.1.12, such effects may include human health, biological, cultural, economic, or social 

15 impacts. 

16 Potential impacts to minority and low-income populations would mostly consist of environmental 

17 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

18 housing impacts). Noise and dust impacts during construction would be short term and 

19 primarily limited to onsite activities. Minority and low-income populations residing along site 

20 access roads would be affected by increased commuter vehicle and truck traffic. However, 

21 because of the temporary nature of construction, these effects are not likely to be high and 

22 adverse and would be contained to a limited time period during certain hours of the day. During 

23 construction, increased demand for rental housing in the vicinity of the site could affect 

24 low-income populations living near the plant site. However, given the small number of 

25 construction workers and the possibility that workers could commute to the construction site, the 

26 need for rental housing would not be significant. 

27 Minority and low-income populations living in close proximity to the power generating facilities 

28 could be disproportionately affected by wind farm, PV solar, and NGCC power plant operations. 

29 However, all would be exposed to the same potential effects from operations, and any effects 

30 would depend on the magnitude of the change in ambient conditions. Operational impacts from 

31 the wind turbines and PV solar installations would mostly be limited to noise and aesthetic 

32 effects. The general public living near the wind farms and PV solar installations would be 

33 exposed to the same effects.

34 Based on this information and the analysis of human health and environmental impacts 

35 presented in this SEIS, the construction and operation of new wind turbines, PV solar 

36 installations, and a NGCC power plant would not have disproportionately high and adverse 

37 human health and environmental effects on minority and low-income populations.

38 8.6.2.13. Waste Management

39 During the construction stage of this combination of alternatives (wind, solar, and NGCC), land 

40 clearing and other construction activities would generate wastes that could be recycled, 

41 disposed of on site, or shipped to the offsite waste disposal facility. During the operational 

42 stage, spent SCR catalysts, which control NOx emissions from the NGCC plant, would make up 

43 the majority of the waste generated by this alternative, along with some wastes generated 

44 during maintenance for the wind and solar operations.

45 The staff concludes that overall waste impacts from the combination of the NGCC unit 

46 constructed on an existing site, and renewable energy components such as wind and solar, 

47 would be SMALL.
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1 Table 8–8. Summary of Environmental Impacts of the Combination Alternative Compared 

2 to Continued Operation of the Existing LGS

Combination Alternative Continued Operation of 

LGS 

Air Quality SMALL to MODERATE SMALL

Groundwater Resources SMALL SMALL

Surface Water Resources SMALL SMALL

Aquatic Ecology SMALL SMALL

Terrestrial Ecology SMALL SMALL

Human Health SMALL SMALL

Land Use SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics SMALL to MODERATE SMALL

Historic and Archaeological SMALL to MODERATE SMALL

Waste Management SMALL SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS.

3 8.6.3. Combination Alternative: Wind and Compressed Air Energy Storage 

4 In compressed air energy storage (CAES), an electric motor uses electricity to pump air into an 

5 underground, pressurized cavity, and when electricity is needed, the operator releases the 

6 compressed air through a gas turbine generator. The compressed air provides some power to 

7 the generator (essentially, reducing the need for compression by the turbine), and burning 

8 natural gas provides heat to increase pressure and to power the turbine. Thus, CAES is not 

9 solely an energy storage technology, but also relies on additional fossil fuel (future, 

10 as-yet-undeveloped CAES technologies promise no reliance on natural gas).

11 CAES is a commercially viable technology for energy storage, though it is seldom-used on a 

12 utility scale. It is in use at one site in the United States and one site in Germany (with capacities 

13 of 110 MW[e] and 290 MW[e], respectively).

14 Currently, no state or utility in the United States is operating wind power in combination with 

15 compressed air energy storage, let alone doing so to offset baseload power supplies. A group 

16 of utilities had proposed a 270-MW(e) project of that type in Iowa but have since terminated the 

17 project because of geologic unsuitability of the proposed site (ISEPA 2011). The McIntosh 

18 facility in Alabama is the only existing U.S. compressed air energy storage installation; it 

19 provides peaking capacity to existing non-wind generation, and it is relatively small. It provides 

20 110 MW(e) of power for up to 26 hours. The McIntosh facility and Germany’s Huntorf facility are 

21 both based in salt domes. 

22 Currently, no compressed air energy storage facilities exist in PJM. In Ohio, First Energy has 

23 acquired the Norton Energy Storage project, a proposed CAES facility that could be constructed 

24 in a retired limestone mine. The First Energy Nuclear Operating Company (FENOC) indicates 

25 that the Norton Energy Storage facility could have a maximum of 536 MW(e) of capacity 
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1 available by 2017 (though it has not committed to install this capacity in that time period) and 

2 that it has an air permit for up to 804 MW(e) of capacity that the site (FENOC 2011). FENOC 

3 indicates that the maximum potential storage capacity at the Norton Energy Storage project is 

4 2,700 MW(e) (FENOC 2011). However, the NRC is not aware of a CAES project coupled with 

5 wind generation that is providing baseload power. Therefore, the NRC concludes that the use 

6 of CAES in combination with wind turbines to generate 2,340 MW(e) in PMJ is unlikely.

7 Because the use of CAES in combination with wind turbines to generate 2,340 MW(e) in PMJ is 

8 unlikely, the staff does not consider CAES in combination with wind to provide a viable, 

9 standalone alternative to license renewal. The staff considers a standalone alternative here, 

10 however, because Exelon includes a CAES and wind combination alternative in its range of 

11 alternatives to LGS license renewal in the ER. 

12 This section analyzes the potential impacts from a CAES and wind combination alternative. 

13 NREL (2006) suggests that 2,000 MW(e) of wind power together with 900 MW(e) of CAES can 

14 provide a near-constant 900 MW(e) of output. Using the high capacity factors the staff applied 

15 to the windpower alternative in Section 8.4 (which exceeds current wind capacity factors), this 

16 alternative relies on 2,000 MW(e) of CAES capacity from a facility similar in operation to the 

17 Norton project and 4,500 MW(e) of onshore wind capacity. While the approach in NREL (2006) 

18 suggests that 2,340 MW(e) of CAES may be necessary to provide firming capacity that would 

19 provide similar baseload potential as that provided by LGS, this alternative underestimates the 

20 amount of CAES capacity necessary to provide for technological advances and avoid 

21 overstating the potential impacts from relying on a combination of wind and CAES. In general, 

22 the staff relies on information from the Norton project to describe the potential impacts of a 

23 CAES project, though the staff notes that projects at different sites may incur varying levels of 

24 environmental impacts. Where appropriate, the staff scales impacts from the Norton project to 

25 account for the size of the CAES project considered here. 

26 Table 8–9 summarizes the environmental impacts of the wind and CAES alternative compared 

27 to the continued operation of LGS.

28 8.6.3.1. Air Quality

29 As discussed in Section 2.2.2.1, the LGS site is located in Montgomery and Chester Counties, 

30 Pennsylvania, and is part of the Metropolitan Philadelphia Interstate Air Quality Control Region 

31 AQCR (40 CFR 81.15). With regard to the NAAQS, EPA has designated Montgomery and 

32 Chester Counties as unclassified or in attainment with respect to carbon monoxide, lead, sulfur 

33 dioxide, and PM10; and nonattainment with respect to ozone and PM2.5 (40 CFR 81.339).

34 This alternative relies on CAES to store electricity produced by wind turbines, which is then 

35 released during periods of low wind production. CAES facilities burn natural gas to heat the 

36 compressed air; therefore, they produce air emissions. The CAES facility would qualify as a 

37 new major-emitting industrial facility and would be subject to PSD under CAA requirements 

38 (EPA 2012). The PADEP has adopted 25 Pa. Code Chapter 127, which implements the EPA’s 

39 PSD review. The CAES plant would need to comply with the standards of performance for 

40 stationary combustion turbines set forth in 40 CFR Part 60 Subpart KKKK.

41 Subpart P of 40 CFR Part 51.307 contains visibility protection regulatory requirements, including 

42 the review of the new sources that may affect visibility in any Federal Class I area. If the CAES 

43 component of this combination alternative were located close to a mandatory Class I area, 

44 additional air pollution control requirements would be required. As noted in Section 2.2.2.1, 

45 there are no Mandatory Class I Federal areas within 50 miles of the LGS site. There are a total 

46 of 13 designated Class 1 Federal areas (40 CFR 81) located in the following PJM states: 

47 Kentucky, Michigan, New Jersey, North Carolina, Tennessee, Virginia, and West Virginia. 
Environmental Impacts of Alternatives

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1 A new CAES facility would have to comply with Title IV of the CAA (42 USC §7651) reduction 

2 requirements for SO2 and NOx, which are the main precursors of acid rain and the major cause 

3 of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the 

4 existing plants and a system of SO2 emission allowances that can be used, sold, or saved for 

5 future use by the new plants.

6 More recently, the EPA has promulgated additional rules and requirements that apply to certain 

7 fossil-fuel based power plants, such as the CAES portion of this alternative. The CSAPR and 

8 the Prevention of Significant Deterioration and Title V GHG Tailoring Rule impose several 

9 additional standards to limit ozone, particulate, and GHG emissions from fossil-fuel based 

10 power plants (EPA 2012c). A new CAES plant would be subject to these additional rules and 

11 regulations. 

12 Air emission permits from the Norton CAES Project in Norton, Ohio, were used as a basis for 

13 estimating emissions for this alternative. The current Norton air emissions permit allows 

14 804 MW(e), so the staff scales the values from the Norton CAES project to 2,000 MW(e) to 

15 determine air quality impacts associated with this alternative. The staff projects the following air 

16 emissions for the CAES alternative:

17 • sulfur oxides (SOx) – 105.5 tons (96.2 MT) per year, 

18 • nitrogen oxides (NOx) – 233.0 tons (212.4 MT) per year, 

19 • carbon monoxide (CO) – 224.8 tons (204.9 MT) per year, 

20 • PM10 and PM2.5 – 116.0 tons (105.8 MT) per year, and

21 • carbon dioxide (CO2) – 1,694,279 tons (1,544,735 MT) per year.

22 Activities associated with the construction of the CAES alternative would cause some additional, 

23 temporary air effects as a result of equipment emissions and fugitive dust from operation of the 

24 earth-moving and material-handling equipment. Emissions from workers’ vehicles and 

25 motorized construction equipment exhaust would be temporary. Construction crews could use 

26 dust-control practices to control and reduce fugitive dust. The staff concludes that the impact of 

27 vehicle exhaust emissions and fugitive dust from operation of the earth-moving and 

28 material-handling equipment would be SMALL. 

29 Greenhouse Gas Emissions

30 Greenhouse gas emissions during construction of this alternative would result primarily from the 

31 consumption of fossil fuels in the engines of construction vehicles and equipment, workforce 

32 vehicles used in commuting to and from the work site, and delivery vehicles. However, all such 

33 impacts would be temporary. 

34 Greenhouse gas emissions during operation would primarily be from natural gas combustion in 

35 the combustion turbines (at both the NGCC facility and the CAES facility). However, other 

36 miscellaneous ancillary sources such as truck and rail deliveries of materials to the site and 

37 commuting of the workforce would make minor contributions.

38 NETL estimates that CCS will capture and remove as much as 90 percent of the CO2 from the 

39 exhausts of combustion turbines, but will result in a power production capacity decrease of 

40 approximately 14 percent, a reduction in net overall thermal efficiency of the CTs studied from 

41 50.8 percent to 43.7 percent, and a potential increase in the levelized cost of electricity 

42 produced in NGCC units so equipped by as much as 30 percent (NETL 2007). Further, 

43 permanent sequestering of the CO2 would involve removing impurities (including water) and 

44 pressurizing it to meet pipeline specifications and transferring the gas by pipeline to acceptable 

45 geologic formations. Even when opportunities exist to utilize the CO2 for enhanced oil recovery 

46 (rather than simply dispose of the CO2 in geologic formations), permanent disposal costs could 

47 be substantial, especially if the combustion turbines are far removed from acceptable geologic 
Environmental Impacts of Alternatives

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1 formations. With CCS in place, the CAES alternative would release 0.154 million MT per year 

2 (0.169 million tons) of CO2. Without CCS in place, the CAES alternative would release 1.54 

3 million MT (1.69 million tons) of CO2 per year

4 Given the temporary impacts during the construction period and GHG emissions resulting from 

5 operations, the overall from the releases of GHGs of the CAES alternative would be SMALL to 

6 MODERATE.

7 Conclusion

8 The overall air quality impacts from CAES alternative would be similar to those of an NGCC 

9 facility and would be designated as SMALL to MODERATE.

10 8.6.3.2. Groundwater Resources

11 Impacts on groundwater resources of constructing and operating wind turbine installations 

12 under this alternative would be similar to those described in Section 8.4.2. Similarly, for 

13 construction and operation of the CAES facility, it is expected that overall impacts would be 

14 similar to and would be bounded by those described for the NGCC alternative (see 

15 Section 8.1.2) because construction and operations of the two facilities would be relatively 

16 similar, although the NGCC plant would be larger than the CAES facility. As an additional 

17 impact, pressurization of an underground cavity associated with CAES operations could affect 

18 groundwater flow on a localized basis. However, overall impacts on groundwater use and 

19 quality under this alternative would be SMALL. 

20 8.6.3.3. Surface Water Resources

21 Impacts on surface water resources of constructing and operating wind turbine installations 

22 under this alternative would be similar to those described in Section 8.4.3. For construction and 

23 operation of the CAES facility, it is expected that overall impacts on surface water would be 

24 similar to and would be bounded by those described for the NGCC alternative (see 

25 Section 8.1.3). The nature of potential surface water impacts of CAES would depend on the 

26 type of CAES reservoir. For CAES using hard rock caverns, makeup water would be required 

27 because of evaporation from the surface reservoir and some potential for leakage. With these 

28 systems, as well as with porous rock reservoirs, there is generally a provision for pumping of 

29 water into the caprock or zones above the caprock to ensure hydraulic overpressure that would 

30 counter the potential for air leakage. In general, however, the potential for effects from caprock 

31 overpressure requirements would be smaller than the makeup water required for cooling. 

32 As a result, the projected cooling water demands would be smaller than the requirement 

33 presented in Section 8.1.3 for the NGCC alternative; the demands would relate primarily to 

34 removing waste heat from compression of the stored air. In conclusion, the overall impacts on

35 surface water use and quality under this alternative would be SMALL. 

36 8.6.3.4. Aquatic Resources

37 Construction activities for the wind and CAES alternative (such as construction of heavy-haul 

38 roads, the wind turbines, and CAES facility) could affect drainage areas and other onsite aquatic 

39 features. Minimal impacts on aquatic ecology resources are expected as the plant operator 

40 would likely implement BMPs to minimize erosion and sedimentation elsewhere on the site. 

41 Stormwater control measures, which would be required to comply with Pennsylvania NPDES 

42 permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the 

43 available infrastructure at the selected site, the CAES facility may require modification or 

44 expansion of the existing intake or discharge structures. Because of the relatively low 

45 withdrawal rates compared to the NGCC, SCPC, or new nuclear alternatives, it is unlikely that 

46 the operators would need to construct new intake and discharge structures. Dredging activities 
Environmental Impacts of Alternatives

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1 that result from infrastructure construction would require BMPs for in-water work to minimize 

2 sedimentation and erosion. Because of the short-term nature of the dredging activities, the 

3 hydrological alterations to aquatic habitats would likely be localized and temporary.

4 During operations, the CAES alternative would require less cooling water to be withdrawn from 

5 the Schuylkill River, or other similar water body, than required for LGS Units 1 and 2. In 

6 addition, the cooling system for a CAES plant would have similar chemical discharges as LGS. 

7 The flow of the Schuylkill River, or other similar waterbody, would likely dissipate and dilute the 

8 concentration of pollutants resulting in minimal exposure to aquatic biota. 

9 The impacts on aquatic ecology would be minor because construction activities would require 

10 BMPs and stormwater management permits, and because the surface water withdrawal and 

11 discharge for this alternative would be less than for LGS Units 1 and 2. Therefore, the staff 

12 concluded that impacts on aquatic ecology would be SMALL.

13 Consultation with NMFS and FWS under ESA would ensure that the construction and operation 

14 of wind farms and CAES facility would not adversely affect any Federally listed species or 

15 adversely modify or destroy designated critical habitat. If new infrastructure were located near 

16 EFH, consultation with NMFS under the Magnuson-Stevens Act would require NRC to evaluate 

17 impacts to EFH and NMFS would provide conservation recommendations if there would be 

18 adverse impacts to EFH. Coordination with state natural resource agencies would further 

19 ensure that the CAES and wind farm operators would take appropriate steps to avoid or mitigate 

20 impacts to state-listed species, habitats of conservation concern, and other protected species 

21 and habitats. Consequently, the impacts of construction and operation on protected species 

22 and habitats would be SMALL. 

23 8.6.3.5. Terrestrial Resources

24 Impacts to terrestrial species and habitats from construction and operation of this combined 

25 alternative would be similar in type, magnitude, and intensity as those described in Section 8.4.5 

26 for the wind alternative. The primary difference in impact would result from the additional 92 ac 

27 (37 ha) required for the CAES facility. Impacts resulting from the CAES facility would vary 

28 depending on the site of the facility, but would generally not contribute considerably more 

29 impacts than the wind component because of the wind component’s large land area 

30 requirements. Consequently, the impacts of construction and operation of this alternative to 

31 terrestrial habitats and species could range from SMALL to MODERATE.

32 As with the previously discussed alternatives, consultation with FWS under the ESA would 

33 avoid potential adverse impacts to Federally listed species or adverse modification or 

34 destruction of designated critical habitat. Coordination with state natural resource agencies 

35 would further ensure that Exelon would take appropriate steps to avoid or mitigate impacts to 

36 state-listed species, habitats of conservation concern, and other protected species and habitats. 

37 Consequently, the impacts of construction and operation of a wind and CAES alternative on 

38 protected species and habitats would be SMALL.

39 8.6.3.6. Human Health

40 CAES is a process by which air is compressed and forced into a holding area (like a large 

41 underground cavern) for later use in powering a gas turbine. Construction impacts of a CAES 

42 facility would be similar to impacts associated with the construction of any major industrial 

43 facility. Although constructing an energy facility with and near a suitable holding area (like a 

44 large underground cavern) would pose some unique challenges, proper regulation through state 

45 and Federal agencies would ensure that human health impacts are minimized. 
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1 Impacts on human health from construction of the wind alternative would be similar to impacts 

2 associated with the construction of any major industrial facility. Compliance with worker 

3 protection rules would control those impacts on workers at acceptable levels. Impacts from 

4 construction on the general public would be minimal since limiting active construction area 

5 access to authorized individuals is expected. Impacts on human health from the construction of 

6 the wind alternative would be SMALL.

7 Given proper health-based regulation through procedures and access limitations, the staff 

8 expects human health impacts from operation of the CAES and the wind alternative at an 

9 alternate site to be SMALL. 

10 8.6.3.7. Land Use

11 As discussed in Section 8.1.7, the GEIS generically discusses the impact of constructing and 

12 operating various replacement power plant alternatives on land use, both on and off each power 

13 plant site. The analysis of land-use impacts focuses on the amount of land area that would be 

14 affected by the construction and operation of new wind turbines and CAES.

15 Land-use impacts from the wind turbines would be similar to the impacts described for the wind 

16 alternative (see Section 8.4.7). Most of the wind farms would be located on open agricultural 

17 cropland, which would remain largely unaffected by the presence of the wind turbines. Since 

18 wind turbines require ample spacing between one another to avoid air turbulence, the footprint 

19 of a utility scale wind farm could be quite large. Exelon estimates 3,200 ac (1,300 ha) of land 

20 would be directly affected by the placement of the wind turbines (Exelon 2011). These 

21 estimates appear reasonable based upon the size of current and proposed wind farms. 

22 Nevertheless, wind turbines would be located on multiple wind farms spread across 

approximately 130,000 ac (53,000 ha or 200 mi2

 [520 km2 23 ]) of land. Most of this land would be 

24 temporarily affected during the installation of the turbines and the construction of support 

25 facilities, and about one-third of the land would be permanently impacted. Based on Exelon’s 

26 estimates, approximately 3,200 ac (1,300 ha) of land would be needed to support the wind 

27 portion of the alternative to replace the LGS. This amount of land use would include the area 

directly affected by the placement of turbines. Turbines would be spread across about 200 mi2 28

(520 km2 29 ). Additional land would be needed for any new transmission lines to connect wind 

30 farms to the grid and for any needed access roads. 

31 Delivering heavy and oversized wind turbine components would also require the construction of 

32 temporary site access roads, some of which may require a circuitous route to their destination. 

33 However, once construction is completed, many temporary access roads can be reclaimed and 

34 replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land 

35 used for equipment and material lay down areas, turbine assembly, and installation could be 

36 returned to its original state. During operations, only 5–10 percent of the total acreage within 

37 the wind farm is actually occupied by turbines, access roads, support buildings, and associated 

38 infrastructure while the remaining land area can be returned to its original condition or some 

39 other compatible use, such as farming or grazing.

40 Land-use impacts from the gas-fired portion of the energy recovery process associated with the 

41 CAES portion of this alternative would be similar to the impacts described for a NGCC power 

42 plant (see Section 8.1.7). Only a minor amount of land would be needed above the geologic 

43 storage formation. As a whole, construction and operation of a wind generation facility 

44 combined with the construction and operation of a CAES facility would have relatively greater 

45 impacts than the wind generation facilities alone.

46 The elimination of uranium fuel for LGS would partially offset some, but not all, of the land 

47 requirements for the wind farms. Scaling from GEIS estimates, approximately 1,640 ac 
Environmental Impacts of Alternatives

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1 (660 ha) would no longer be needed during the operating life of the wind farms and the CAES 

2 facility. Overall land-use impacts from the construction and operation of new wind farms and a 

3 CAES facility would range from MODERATE to LARGE.

4 8.6.3.8. Socioeconomics

5 As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

6 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 

7 socioeconomic impact; and (2) operations jobs, which have the greater potential for permanent, 

8 long-term socioeconomic impacts. Workforce requirements for the construction and operation 

9 of a combination of wind turbines and a CAES facility were evaluated in order to measure their 

10 possible effects on current socioeconomic conditions.

11 Socioeconomic impacts from the wind turbine component would be similar to the impacts 

12 described for the wind alternative (see Section 8.4.8). Exelon estimated the wind alternative 

13 would require 200 construction and 50 operations workers (Exelon 2011). These estimates 

14 appear reasonable and in line with current construction and operational trends. Impacts from 

15 the construction and operation of the gas-fired portion of the energy recovery process 

16 associated with the CAES component would be similar to the impacts described for a NGCC 

17 power plant (see Section 8.1.8). Because of the relatively small number of construction workers 

18 at wind farms scattered over a large area at various locations, the relative economic impact of 

19 this many workers on local communities and the tax base would be SMALL. Given the small 

20 number of operations workers, socioeconomic impacts associated with operation of the wind 

21 and CAES components of this combination alternative would also be SMALL.

22 The reduction in employment at LGS could affect property tax revenue and income in local 

23 communities and businesses. In addition, the permanent housing market could also experience 

24 increased vacancies and decreased prices if operations workers and their families move out of 

25 the LGS region. However, the amount of property taxes paid by wind farms and CAES may 

26 offset lost tax revenues in the socioeconomic region around local jurisdictions if additional land 

27 is required to support this alternative. Based on this information, socioeconomic impacts during 

28 wind farm operations and CAES could range from SMALL to MODERATE. 

29 8.6.3.9. Transportation

30 Transportation impacts during the construction and operation of the wind and CAES 

31 components of this combination alternative would be similar to the impacts for the NGCC and 

32 wind alternatives, discussed in Sections 8.1.7 and 8.4.7. This is because the construction 

33 workforce for each component and the volume of materials and equipment needing to be 

34 transported to each respective construction site would be the same.

35 As previously described for the NGCC and wind alternatives, workers commuting to the 

36 construction site would arrive by site access roads and the volume of traffic on nearby roads 

37 could increase during shift changes. In addition to commuting workers, trucks would be 

38 transporting construction materials and equipment to the worksite, thus increasing the amount 

39 of traffic on local roads. The increase in vehicular traffic would peak during shift changes, 

40 resulting in temporary traffic volume impacts and delays at intersections. Transporting heavy 

41 and oversized wind turbine components on local roads could have a noticeable impact over a 

42 large area. Some components and materials could also be delivered by train or barge, 

43 depending on location. Train deliveries could cause additional traffic delays at railroad 

44 crossings. Based on this information, traffic-related transportation impacts during construction 

45 could range from SMALL to MODERATE depending on the location of the wind farm and CAES 

46 facility; road capacities; and traffic volumes.
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1 During operations, transportation impacts would be less noticeable during shift changes and 

2 maintenance activities. Given the small numbers of operations workers, traffic impacts on local 

3 roads from wind turbine and CAES facility operations would be SMALL.

4 8.6.3.10. Aesthetics

5 The analysis of aesthetic impacts focuses on the degree of contrast between the wind and 

6 CAES alternative and surrounding landscapes and the visibility of new wind turbines at existing 

7 wind farms and the new CAES facility. In general, aesthetic changes would be limited to the 

8 immediate vicinity of the wind farms and CAES facility.

9 Aesthetic impacts during the construction and operation of the wind and CAES components of 

10 this combination alternative would be similar to the impacts for the NGCC and wind alternatives, 

11 discussed in Sections 8.1.10 and 8.4.10. Wind turbines would have the greatest potential visual 

12 impact. At 400 ft (122 m) tall (Exelon 2011) and spread across multiple sites, wind turbines 

13 often dominate the view and become the major focus of attention. Because wind farms are 

14 generally located in rural or remote areas, the introduction of wind turbines will be in sharp 

15 contrast to the visual appearance of the surrounding environment. Placing turbines along 

16 ridgelines would maximize their visibility. Wind turbines also generate noise.

17 The new CAES facility could be sited at a previously undisturbed location. The mechanical draft 

18 cooling towers and associated condensate plumes along with the CAES facility surface 

19 structures would be the only significant visual for this part of the alternative. Mechanical draft 

20 cooling towers also generate noise. Most other noises during facility operations would be 

21 limited to industrial processes and communications. Based on this information, aesthetic 

22 impacts from the construction and operation of new wind farms and CAES facility would range 

23 from MODERATE to LARGE depending on location and surroundings. 

24 8.6.3.11. Historic and Archaeological Resources

25 Any areas potentially affected by the construction of a wind and CAES alternative should be

26 surveyed to identify and record historic and archaeological resources. Resources found in 

27 these surveys would need to be evaluated for eligibility on the NRHP and mitigation of adverse 

28 effects would need to be addressed if eligible resources were encountered. Plant operators 

29 would need to survey all areas associated with operation of the alternative (e.g., roads, 

30 transmission corridors, other ROWs). Visual impacts on significant cultural resources—such as 

31 the viewsheds of historic properties near the sites—should also be assessed.

32 The potential for impacts on historic and archaeological resources from the wind and CAES 

33 alternative would vary greatly depending on the location of the proposed sites. Areas with the 

34 greatest sensitivity could be avoided or effectively managed under current laws and regulations. 

35 However, construction of wind farms and CAES could have the potential to notably impact 

36 historic and archaeological resources because of ground disturbing activities (e.g., grading, 

37 digging an underground geologic repository). Aesthetic changes caused by the installation of 

38 wind turbines could also have a noticeable effect on the viewshed of nearby historic properties. 

39 Therefore, depending on the resource richness of the site chosen for the wind farm and CAES 

40 alternative, the impacts could range from SMALL to LARGE. 

41 8.6.3.12. Environmental Justice

42 The environmental justice impact analysis evaluates the potential for disproportionately high and 

43 adverse human health, environmental, and socioeconomic effects on minority and low-income 

44 populations that could result from the installation and operation of wind turbines and a CAES 

45 facility. As previously discussed in Section 8.1.12, such effects may include human health, 
Environmental Impacts of Alternatives

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1 biological, cultural, economic, or social impacts. Some of these potential effects have been 

2 identified in resource areas discussed in this SEIS. 

3 Potential impacts to minority and low-income populations would mostly consist of environmental 

4 and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

5 housing impacts). Noise and dust impacts during construction would be short term and 

6 primarily limited to onsite activities. Minority and low-income populations residing along site 

7 access roads would be affected by increased commuter vehicle and truck traffic. However, 

8 because of the temporary nature of construction, these effects would only occur during certain 

9 hours of the day and are not likely to be high and adverse and would be contained to a limited 

10 time period during certain hours of the day. During construction, increased demand for rental 

11 housing in the vicinity of the site could affect low-income populations living near the alternatives. 

12 However, given the small number of construction workers and the possibility that workers could 

13 commute to the construction site, the need for rental housing would not be significant. 

14 Minority and low-income populations living in close proximity to the wind farms and CAES 

15 facility could be disproportionately affected by operations. However, operational impacts would 

16 mostly be limited to noise and aesthetic effects. The general public living near the wind farms 

17 and CAES facility would also be exposed to the same effects.

18 Based on this information and the analysis of human health and environmental impacts 

19 presented in this SEIS, the construction and operation of new wind turbines and a CAES facility 

20 would not have disproportionately high and adverse human health and environmental effects on 

21 minority and low-income populations.

22 8.6.3.13. Waste Management

23 During the construction stage of the combination of wind and CAES alternative, land clearing 

24 and excavation, and other construction activities would generate wastes that could be recycled, 

25 disposed of on site, or shipped to the offsite waste disposal facility. During the operational 

26 stage, the wind and CAES alternative might generate minor amounts of waste.

27 The staff concludes that overall waste impacts from the combination of the wind and CAES 

28 alternative would be SMALL.
Environmental Impacts of Alternatives

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1 Table 8–9. Summary of Environmental Impacts of the Wind and CAES Alternative 

2 Compared to Continued Operation of the Existing LGS

Wind and CAES Alternative Continued Operation of LGS 

Air Quality SMALL to MODERATE SMALL

Groundwater Resources SMALL SMALL

Surface Water Resources SMALL SMALL

Aquatic Ecology SMALL SMALL

Terrestrial Ecology SMALL to MODERATE SMALL

Human Health SMALL SMALL

Land Use MODERATE to LARGE SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL to MODERATE SMALL

Aesthetics MODERATE to LARGE SMALL

Historic and Archaeological SMALL TO LARGE SMALL

Waste Management SMALL SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS.

3 8.6.4. Wood Waste

4 As noted in the GEIS (NRC 1996), the use of wood waste to generate utility-scale baseload 

5 power is limited to those locations where wood waste is plentiful. Wastes from pulp, paper, and 

6 paperboard industries and from forest management activities can be expected to provide 

7 sufficient, reliable supplies of wood waste as feedstocks to external combustion sources for 

8 energy generation. Beside the fuel source, the technological aspects of a wood-fired generation 

9 facility are virtually identical to those of a coal-fired alternative—combustion in an external 

10 combustion unit such as a boiler to produce steam to drive a conventional STG. Given 

11 constancy of the fuel source, wood waste facilities can be expected to operate at equivalent 

12 efficiencies and reliabilities. Costs of operation would depend significantly on processing and 

13 delivery costs. Wood waste combustors would be sources of criteria pollutants and GHGs, and 

14 pollution control requirements would be similar to those for coal plants. Unlike coal plants, there 

15 is no potential for the release of HAPs such as mercury. Co-firing of wood waste with coal is 

16 also technically feasible. Processing the wood waste into pellets can improve the overall 

17 efficiency of such co-fired units. 

18 Although co-fired units can have capacity factors similar to baseload coal-fired units, such levels 

19 of performance are dependent on the continuous availability of the wood fuel. In the 

20 Commonwealth of Pennsylvania, 2010 electricity generating capacity from wood waste was 

21 108 MW(e) and produced 675,000 MWh (EIA 2011c). Given the limited capacity and modest 

22 actual electricity production, the staff has determined that production of electricity from wood 

23 waste at levels equivalent to LGS would not be a feasible alternative to LGS license renewal.
Environmental Impacts of Alternatives

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1 8.6.5. Conventional Hydroelectric Power

2 Three technology variants of hydroelectric power exist—dam and release (also known as 

3 impoundment), run-of-the-river (also known as diversion), and pumped storage. In each variant, 

4 flowing water spins turbines of different designs to drive a generator to produce electricity. Dam 

5 and release facilities affect large amounts of land behind the dam to create reservoirs but can 

6 provide substantial amounts of power at capacity factors greater than 90 percent. Power 

7 generating capacities of run-of-the-river dams fluctuate with the flow of water in the river, and 

8 the operation of such dams is typically constrained (and stopped entirely during certain periods) 

9 so as not to create undue stress on the aquatic ecosystems present. Pumped storage facilities 

10 use electricity from other power sources to pump water from lower impoundments or flowing 

11 watercourses to higher elevations during off-peak load periods. Water is then released during 

12 peak load periods through turbines to generate electricity. Capacities of pumped storage 

13 facilities are dependent on the configuration and capacity of the elevated storage facility.

14 A comprehensive survey of hydropower resources in Pennsylvania was completed in 1997 by 

15 DOE’s Idaho National Environmental Engineering Laboratory (now known as the Idaho National 

16 Laboratory). In the study, generating potential was defined by a model that considered the 

17 existing hydroelectric technology at developed sites or applied the most appropriate technology 

18 to undeveloped sites and introduced site-specific environmental considerations and limitations. 

19 Pennsylvania had modest hydroelectric potential, with a total generating potential of 703 MW(e) 

20 (INEEL 1997). This potential was spread across 104 sites, only one of which had the potential 

21 for more than 100 MW(e) of generation. Most other states in PJM have very limited potential 

22 (INEEL 1998b), with the exception of West Virginia, which has 1,149 MW(e) spread across 

23 37 sites (INEEL 1998a)

24 More recently, EIA reported that, in 2010, conventional hydroelectric power (excluding pumped 

25 storage) was the principal electricity generation source among renewable sources in 

26 Pennsylvania (EIA 2011c). Nevertheless, only 747 MW(e) of hydroelectric capacity was 

27 installed in the Commonwealth. Those installations provided 2,332 gigawatt-hours of electricity 

28 (EIA 2011a). Although hydroelectric facilities can demonstrate relatively high capacity factors, 

29 the small potential capacities and actual recent power generation of hydroelectric facilities in 

30 Pennsylvania, combined with the diminishing public support for large hydroelectric facilities 

31 because of their potential for adverse environmental impacts, supports the staff’s conclusion 

32 that hydroelectric is not a feasible alternative to LGS.

33 8.6.6. Ocean Wave and Current Energy

34 Ocean waves, currents, and tides represent kinetic and potential energies. The total annual 

35 average wave energy off the U.S. coastlines at a water depth of 60 m (197 ft) is estimated at 

36 2,100 terawatt-hours (TWh) (MMS 2006). Waves, currents, and tides are often predictable and 

37 reliable; ocean currents flow consistently, while tides can be predicted months and years in 

38 advance with well-known behavior in most coastal areas. Four principal wave energy 

39 conversion (WEC) technologies have been developed to date to capture the potential or kinetic 

40 energy of waves—point absorbers, attenuators, overtopping devices, and terminators. All have 

41 similar approaches to electricity generation but differ in size, anchoring method, spacing, 

42 interconnection, array patterns, and water depth limitations. Point absorbers and attenuators 

43 both allow waves to interact with a floating buoy, subsequently converting its motion into 

44 mechanical energy to drive a generator. Overtopping devices and terminators are also similar 

45 in their function. Overtopping devices trap some portion of the incident wave at a higher 

46 elevation than the average height of the surrounding sea surface, thus giving it higher potential 
Environmental Impacts of Alternatives

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1 energy, which is then transferred to power generators. Terminators allow waves to enter a tube, 

2 compressing air trapped at the top of the tube, which is then used to drive a generator.

3 Capacities of point absorbers range from 80–250 kW, with capacity factors as high as 

4 40 percent; attenuator facilities have capacities of as high as 750 kW. Overtopping devices 

5 have design capacities as high as 4 MW, while terminators have design capacities ranging from 

6 500 kW–2 MW and capacity factors as high as 50 percent (MMS 2007).

7 The most advanced technology for capturing tidal and ocean current energy is the submerged 

8 turbine. Underwater turbines share many design features and functions with wind turbines, but 

9 because of the greater density of water compared to air, they have substantially greater 

10 power-generating potential than wind turbines with comparably sized blades. Only a small

11 number of prototypes and demonstration units have been deployed to date, however. 

12 Underwater turbine “farms” are projected to have capacities of 2–3 MW, with capacity factors 

13 directly related to the constancy of the current with which they interact.

14 The staff is not currently aware of any plans to develop or deploy ocean wave and ocean 

15 current generation technologies on a scale similar to that of LGS. Consequently, the relatively 

16 modest power capacities, relatively high costs, and limited planned implementation support the 

17 staff’s conclusion that water energy current technologies are not feasible substitutes for LGS.

18 8.6.7. Geothermal Power

19 Geothermal technologies extract the heat contained in geologic formations to produce steam to 

20 drive a conventional steam-turbine generator. The following variants of the heat exchanging 

21 mechanism have been developed: 

22 • Hot geothermal fluids contained under pressure in a geological formation are 

23 brought to the surface where the release of pressure allows them to flash into 

24 steam (the most common of geothermal technologies applied to electricity 

25 production).

26 • Hot geothermal fluids are brought to the surface in a closed loop system and 

27 directed to a heat exchanger where they convert water in a secondary loop 

28 into steam.

29 • Hot dry rock technologies involve fracturing a rock formation and extracting 

30 heat through injection of a heat transfer fluid.

31 Facilities producing electricity from geothermal energy can routinely demonstrate capacity 

32 factors of 95 percent or greater, making geothermal energy clearly eligible as a source of 

33 baseload electric power. However, as with other renewable energy technologies, the ultimate 

34 feasibility of geothermal energy serving as a baseload power replacement for LGS depends on 

35 the quality and accessibility of geothermal resources within or proximate to the region of 

36 interest—in this case, Pennsylvania or PJM. As of April 2010, the United States had a total 

37 installed geothermal electricity production capacity of 3,087 MW(e) originating from geothermal 

38 facilities in nine states—Alaska, California, Hawaii, Idaho, Nevada, New Mexico, Oregon, Utah, 

39 and Wyoming. Additional geothermal facilities are being considered for Colorado, Florida, 

40 Louisiana, Mississippi, and Oregon. Neither Pennsylvania nor PJM has adequate geothermal 

41 resources to support utility-scale electricity production (GEA 2010). NRC concludes, therefore, 

42 that geothermal energy does not represent a feasible alternative to LGS.
Environmental Impacts of Alternatives

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1 8.6.8. Municipal Solid Waste

2 Municipal solid waste (MSW) combustors use three types of technologies—mass burn, modular, 

3 and refuse-derived fuel. Mass burning is currently the method used most frequently in the 

4 United States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or 

5 hazardous components present in the waste stream are combusted, and toxic constituents are 

6 exhausted to the air or become part of the resulting solid wastes. Currently, approximately 

7 86 waste-to-energy plants operate in 24 states, processing 97,000 tons (88,000 MT) of 

8 municipal solid waste per day. Approximately 26 million tons (24 million MT) of trash were 

9 processed in 2008 by waste-to-energy facilities. With a reliable supply of waste fuel, 

10 waste-to-energy plants have a nationwide aggregate capacity of 2,572 MW(e) (compared to 

11 2,340 MW[e] capacity at LGS) and can operate at capacity factors greater than 90 percent 

12 (ERC 2010). The EPA estimates that, on average, air impacts from MSW-to-energy plants are 

13 as follows: 

14 • carbon dioxide (CO2) –3,685 lb (1,672 kg)/MWh,

15 • sulfur dioxide (SOX) –1.2 lb (0.54 kg)/MWh, and 

16 • nitrogen oxide (NOx) – 6.7 lb (3.0 kg)/MWh. 

17 Depending on the composition of the municipal waste stream, air emissions can vary greatly, 

18 and the ash produced may exhibit hazardous characteristics that require special treatment and 

19 handling (EPA 2010).

20 Estimates in the GEIS suggest that the overall level of construction impact from a waste-fired 

21 plant would be approximately the same as that for a coal-fired power plant. Additionally, 

22 waste-fired plants have the same or greater operational impacts as coal-fired technologies 

23 (including impacts on the aquatic environment, air, and waste disposal). The initial capital costs 

24 for municipal solid-waste plants are greater than those for comparable steam-turbine technology 

25 at coal-fired facilities or at wood-waste facilities because of the need for specialized waste 

26 separation and handling equipment (NRC 1996).

27 The decision to burn municipal waste to generate energy is usually driven by the need for an 

28 alternative to landfills, rather than energy considerations. The use of landfills as a waste 

29 disposal option is likely to increase in the near term as energy prices increase (and especially 

30 since such landfills, of sufficient size and maturity, can be sources of easily recoverable 

31 methane fuel); however, it is possible that municipal waste combustion facilities may become 

32 attractive again.

33 Regulatory structures that once supported municipal solid waste incineration no longer exist. 

34 For example, the Tax Reform Act of 1986 made capital-intensive projects, such as municipal 

35 waste combustion facilities, more expensive relative to less capital-intensive waste disposal 

36 alternatives such as landfills. Additionally, the 1994 Supreme Court decision C&A 

37 Carbone, Inc. v. Town of Clarkstown, New York, struck down local flow control ordinances that 

38 required waste to be delivered to specific municipal waste combustion facilities rather than 

39 landfills that may have had lower fees. In addition, environmental regulations have increased 

40 the capital cost necessary to construct and maintain municipal waste combustion facilities.

41 Given the limited nationwide implementation of MSW-based generation to date (only 10 percent 

42 greater than the capacity of LGS), small average installed size of municipal solid waste plants, 

43 the likelihood that additional stable streams of MSW are not likely to be available to support 

44 numerous new facilities, and the increasingly unfavorable regulatory environment, the staff does 

45 not consider municipal solid waste combustion to be a reasonable alternative to LGS license 

46 renewal.
Environmental Impacts of Alternatives

8-78

1 8.6.9. Biomass Fuels

2 When used here, “biomass fuels” include crop residues, switchgrass grown specifically for 

3 electricity production, forest residues, methane from landfills, methane from animal manure 

4 management, primary wood mill residues, secondary wood mill residues, urban wood wastes, 

5 and methane from domestic wastewater treatment. The feasibility of using biomass fuels for 

6 baseload power depends on its geographic distribution, available quantities, constancy of 

7 supply, and energy content. A variety of technical approaches has been developed for 

8 biomass-fired electric generators, including direct burning, conversion to liquid biofuels, and 

9 biomass gasification. In a study completed in December 2005, Milbrandt of NREL documented 

10 the geographic distribution of biomass fuels within the United States, reporting the results in 

11 metric tons available (dry basis) per year (NREL 2005). Most counties in Pennsylvania have 

12 limited potential biomass fuels, with the exception of Philadelphia and Bucks County. Use of 

13 biomass fuels in Pennsylvania is also limited. Beyond the wood and wood waste considered in 

14 Section 8.6.4, generators in the Commonwealth used biomass fuels to produce merely 

15 3,000 MWh of electricity in 2010 (EIA 2011c).

16 In the GEIS, the NRC indicated that technologies relying on a variety of biomass fuels had not 

17 progressed to the point of being competitive on a large scale or of being reliable enough to 

18 replace a baseload plant such as LGS. After reevaluating current technologies, and after 

19 reviewing existing statewide capacities and the extent to which biomass is currently being used 

20 to produce electricity, the staff finds biomass-fueled alternatives are still unable to replace the 

21 LGS capacity and are not considered feasible alternatives to LGS license renewal.

22 8.6.10. Oil-Fired Power

23 Although oil has historically been used extensively in the Northeast for comfort heating, EIA 

24 projects that oil-fired plants will account for very little of the new generation capacity constructed 

25 in the United States during the 2008 to 2030 time period. In 2010, Pennsylvania generated 

26 0.2 percent of its total electricity from oil (EIA 2012). Further, EIA does not project that oil-fired 

27 power will account for any significant additions to capacity (EIA 2011b).

28 The variable costs of oil-fired generation tend to be greater than those of nuclear or coal-fired 

29 operations, and oil-fired generation tends to have greater environmental impacts than natural 

30 gas-fired generation. In addition, future increases in oil prices are expected to make oil-fired 

31 generation increasingly expensive (EIA 2011b). The high cost of oil has prompted a steady 

32 decline in its use for electricity generation. Thus, the staff does not consider oil-fired generation 

33 as a reasonable alternative to LGS license renewal.

34 8.6.11. Delayed Retirement

35 Exelon currently plans to retire three coal-fired units and one oil-fired unit (Exelon 2011). These 

36 units total 946 MW(e) of capacity, far less than the 2,340 MW(e) LGS currently provides. In 

37 PJM, however, Exelon indicates that generators have retired 5,945 MW(e) from 2003 to 2009 

38 (Exelon 2011). 

39 Most retired units are dirtier and less efficient than new units. Often, units are retired because 

40 operation is no longer economical. In some cases, the cost of environmental compliance or 

41 necessary repairs and upgrades are too high to justify continued operation. As a result, the staff 

42 does not consider delayed retirement a reasonable alternative to license renewal. It is possible, 

43 however, that a site where a unit has been retired could play host to a new generation facility, 

44 like the NGCC and SCPC alternatives considered in Sections 8.1 and 8.2, and the NGCC 

45 portion of the combination alternative considered in Section 8.6.2. 
Environmental Impacts of Alternatives

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1 8.6.12. Fuel Cells

2 Fuel cells oxidize fuels without combustion and its environmental side effects. Power is 

3 produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 

4 over a cathode and separating the two by an electrolyte. The only byproducts (depending on 

5 fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a variety of 

6 hydrocarbon resources by subjecting them to steam reforming under pressure. Natural gas is 

7 typically used as the source of hydrogen.

8 Currently, fuel cells are not economically or technologically competitive with other alternatives 

9 for electricity generation. EIA projects that fuel cells may cost $5,478 per installed kW (total 

10 overnight costs, 2008 dollars) (EIA 2010c). This amount is substantially greater than coal 

11 ($2,223), advanced (natural gas) combustion turbines ($648), onshore wind ($1,966), or 

12 offshore wind ($3,937), but it is cost-competitive with solar PV ($6,171) or CSP solar ($5,132). 

13 Installed costs provided for PV and CSP solar are before application of Investment Tax Credits 

14 provided in Federal statutes. More importantly, fuel cell units are likely to be small in size (the 

15 EIA reference plant is 10 MWe). While it may be possible to use a distributed array of fuel cells 

16 to provide an alternative to LGS, it would be extremely costly to do so and would require many 

17 units and wholesale modifications to the existing transmission system. Accordingly, the staff 

18 does not consider fuel cell technology to be a reasonable alternative to LGS license renewal.

19 8.6.13. Coal-Fired Integrated Gasification Combined-Cycle

20 Integrated gasification combined-cycle (IGCC) is an emerging technology for generating 

21 electricity with coal that combines modern coal gasification technology with both gas turbine and 

22 steam turbine power generation. Gasifiers, similar to those used in oil refineries, use heat 

23 pressure and steam to pyrolyze (thermally reform complex organic molecules without oxidation) 

24 coal to produce synthesis gases (generically referred to as syngas) typically composed of 

25 carbon monoxide, hydrogen, and other flammable constituents. After processing to remove 

26 contaminants and produce various liquid chemicals, the syngas is combusted in a combustion 

27 turbine to produce electric power. Separating the CO2 from the syngas before combustion is 

28 also possible. Latent heat is recovered both from the syngas as it exits the gasifier and from the 

29 combustion gases exiting the combustion turbine and directed to a heat recovery steam 

30 generator feeding a conventional Rankine cycle STG to produce additional amounts of 

31 electricity. Emissions of criteria pollutants would likely be slightly higher than those from an 

32 NGCC alternative but significantly lower than those from the supercritical coal-fired alternative. 

33 Depending on the gasification technology employed, IGCC would use less water than SCPC 

34 units but slightly more than NGCC (NETL 2007). Long-term maintenance costs of this relatively 

35 complex technology would likely be greater than those for a similarly sized SCPC or NGCC

36 plant.

37 Only a few IGCC plants are operating at utility scale. Operating at higher thermal efficiencies 

38 than supercritical coal-fired boilers, IGCC plants can produce electrical power with fewer air 

39 pollutants and solid wastes than coal-fired boilers. To date, however, IGCC technologies have 

40 had limited application and have been plagued with operational problems such that its effective, 

41 long-term capacity factors are often not high enough for them to reliably serve as baseload 

42 units. Although IGCC technology may become more commonplace in the future, current 

43 operational problems that compromise reliability result in the dismissal of this technology as a 

44 viable alternative to LGS.
Environmental Impacts of Alternatives

8-80

1 8.6.14. Demand-Side Management

2 In its ER, Exelon indicates that DSM does not fulfill the stated purpose of license renewal 

3 because it does not provide power generation capacity (Exelon 2011). Exelon also notes that 

4 the purpose of LGS license renewal is to “allow Exelon to sell wholesale power generated by 

5 LGS to meet future demand.” The ER continues to note that, because “Exelon engages solely 

6 in the sale of wholesale electric power, the Company has no business connection to end-users 

7 of its electricity and, therefore, no ability to implement DSM.” While the staff finds this position 

8 reasonable for purposes of this analysis, it notes that DSM is an option for energy planners and 

9 decisionmakers—and it may be a potential consequence of no action—and so will discuss it in 

10 brief in this section. 

11 DSM measures—unlike the energy supply alternatives discussed in previous sections—address 

12 energy end uses. DSM can include measures that do the following:

13 • reduce energy consumption;

14 • shift energy consumption to different times of the day to reduce peak loads;

15 • interrupt certain large customers during periods of high demand;

16 • interrupt certain appliances during high demand periods; and

17 • encourage customers to switch from gas to electricity for water heating and 

18 other similar measures that utilities use to boost sales.

19 In terms of overall ability to offset or replace an existing baseload power plant, DSM measures 

20 that reduce energy consumption, typically referred to as energy conservation and energy 

21 efficiency, are the most useful. Though often used interchangeably, energy conservation and 

22 energy efficiency are different concepts. Energy efficiency typically means deriving a similar 

23 level of service by using less energy, while energy conservation simply indicates a reduction in 

24 energy consumption. The GEIS directly addressed energy conservation, and noted that it is not 

25 a discrete power-generating source; it represents an option that states and utilities may use to 

26 reduce their need for power generation capability (NRC 1996). Conservation measures may 

27 include incentives to reduce overall energy consumption, while efficiency measures may include 

28 incentives to replace older, less efficient appliances, lighting, or heating and cooling systems. 

29 A variety of conservation or energy efficiency measures would likely be necessary to replace the 

30 capacity currently provided by LGS. 

31 Another DMS approach is called demand-response. PJM currently has a robust 

32 demand-response program, which, unlike energy efficiency and energy conservation measures, 

33 generally aims to reduce consumption during times of high demand. This program also reduces 

34 stresses on the PJM transmission system. 

35 PJM’s demand-response program provides payments to participants who reduce demand 

36 (PJM 2012c, PJM undated). The payments increase as the price of electricity increases, so that 

37 participants are most likely to reduce consumption when electricity is most expensive, which 

38 usually (though not always) occurs during times of high demand (this may also occur during 

39 certain emergencies). This type of approach usually offsets intermediate and peaking 

40 generation rather than baseload generation. Exelon notes, in the ER, that it is unlikely that 

41 demand reductions in PJM could be sufficiently increased to replace the LGS baseload capacity 

42 (Exelon 2011). The NRC staff determined that this conclusion is reasonable because a 

43 considerable amount of demand reduction efforts are currently in place and it is unlikely that 

44 additional programs could reduce use by another 2,340 MW(e). 
Environmental Impacts of Alternatives

8-81

1 As Exelon noted in its ER, the impacts of DSM at most sites are generally SMALL. The staff 

2 has considered energy efficiency or energy conservation in several SEISs 

3 (see, e.g., NUREG-1437, Supplements 33, 37, and 38) and in each case has found the impacts 

4 to be SMALL, except when conservation or efficiency measures are unlikely to offset 

5 socioeconomic impacts of plant shutdown. For LGS, the conservation or efficiency measures 

6 may not offset the socioeconomic plant shutdown because the measures could occur across the 

7 entire PJM territory, which includes several states. The GEIS also indicates that impacts from 

8 energy conservation are likely to be SMALL. The staff notes, however, that some generation 

9 owners recently expressed concern that in cases where demand-response programs trigger 

10 increased reliance on backup diesel generators, air-quality impacts may occur, particularly in 

11 PJM (see, e.g., Beattie 2012). The EPA has provided clean-air waivers for the use of these 

12 generators for a limited number of hours throughout the year. Emergency use of these 

13 generators is likely to occur during the hottest days of the summer, when impaired air quality 

14 often also occurs (Beattie 2012). Some air quality effects from some DSM measures are 

15 possible, but they would depend on the specific DSM measures employed. Because it is 

16 unlikely that demand reductions in PJM could be sufficiently increased to replace the LGS 

17 baseload capacity, the NRC did not consider DSM to be a reasonable alternative. 

18 8.7. No-Action Alternative

19 This section examines the environmental effects that occur if NRC takes no action. No action, 

20 in this case, means that NRC denies the renewed operating licenses for LGS and the licenses 

21 expire at the end of the current license terms, in 2024 and 2029. If the NRC denies the 

22 renewed operating licenses, the plant will shut down at or before the end of the current licenses. 

23 After shutdown, plant operators will initiate decommissioning in accordance with 10 CFR 50.82.

24 No action does not satisfy the purpose and need for this SEIS, as it neither provides 

25 power-generation capacity nor meets the needs currently met by LGS or that the alternatives 

26 evaluated in Sections 8.1–8.5 would satisfy. Assuming that a need currently exists for the

27 power generated by LGS, the no-action alternative would require the appropriate energy 

28 planning decision-makers (not NRC) to rely on an alternative to replace the capacity of LGS, 

29 rely on energy conservation or power purchases to offset parts of the LGS capacity, or rely on 

30 some combination of measures to offset and replace the generation provided by the facility. 

31 This section addresses only those impacts that arise directly as a result of plant shutdown. The 

32 environmental impacts from decommissioning and related activities have already been 

33 addressed in several other documents, including the “Final Generic Environmental Impact 

34 Statement on Decommissioning of Nuclear Facilities,” NUREG-0586, Supplement 1 

35 (NRC 2002); the license renewal GEIS, Chapter 7 (NRC 1996); and Chapter 7 of this SEIS. 

36 These analyses either directly address or bound the environmental impacts of decommissioning 

37 whenever Exelon ceases to operate LGS.

38 Even with a renewed operating license, LGS will eventually shut down, and the environmental 

39 effects we address in this section will occur at that time. Because these effects have not 

40 otherwise been addressed in this SEIS, the impacts are addressed in this section. As with 

41 decommissioning effects, shutdown effects are expected to be similar whether they occur at the 

42 end of the current license or at the end of a renewed license. Table 8–10 provides a summary 

43 of the environmental impacts of the no-action alternative.

44 8.7.1. Air Quality

45 When the plant stops operating, there will be a reduction in emissions from activities related to 

46 plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the staff 
Environmental Impacts of Alternatives

8-82

1 determined that these emissions would have a SMALL impact on air quality during the renewal 

2 term; therefore, if emissions decrease, the impact on air quality would also decrease and would 

3 be SMALL.

4 8.7.2. Groundwater Resources

5 Impacts to groundwater resources would decrease, as the plant would withdraw less water than 

6 it does during operations. Therefore, shutdown would reduce the impacts to groundwater 

7 resources, which would remain SMALL. 

8 8.7.3. Surface Water Resources

9 Impacts to surface water resources would decrease, as the plant would withdraw and discharge 

10 less water than it does during operations. Therefore, shutdown would reduce the impacts to 

11 surface water resources, which would remain SMALL. 

12 8.7.4. Aquatic and Terrestrial Resources

13 Impacts to aquatic ecology would decrease, as the plant would withdraw and discharge less 

14 water than it does during operations. Therefore, fewer organisms would be subject to 

15 impingement, entrainment, and heat shock. Shutdown would reduce the impacts to aquatic 

16 ecology, which would remain SMALL.

17 Terrestrial ecology impacts would remain SMALL. No additional land disturbances on or offsite 

18 would occur.

19 8.7.5. Human Health

20 In Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on 

21 human health would be SMALL. After cessation of plant operations, the amounts of radioactive 

22 material released to the environment in gaseous and liquid forms, all of which are currently 

23 within respective regulatory limits, would be reduced or eliminated. Therefore, the staff 

24 concludes that the impact of plant shutdown on human health would also be SMALL. In 

25 addition, the potential for a variety of accidents would also be reduced to only those associated 

26 specifically with shutdown activities and fuel handling. In Chapter 5 of this SEIS, the staff

27 concluded that impacts of accidents during operation would be SMALL. It follows, therefore, 

28 that impacts on human health from a reduced suite of potential accidents after reactor operation 

29 ceases would also be SMALL. Therefore, the staff concludes that impacts on human health 

30 from the no-action alternative would be SMALL.

31 8.7.6. Land Use

32 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 

33 remain in place until decommissioning. Most transmission lines connected to the LGS would 

34 remain in service after the plant stops operating. Maintenance of most existing transmission 

35 lines would continue as before. Impacts on land use from plant shutdown would be SMALL.

36 8.7.7. Socioeconomics

37 Plant shutdown would have a noticeable impact on socioeconomic conditions in the 

38 communities located in the immediate vicinity of LGS. Should LGS shut down, there would be 

39 immediate socioeconomic impact from the loss of jobs (some, though not all, of the 

40 820 employees would begin to leave), and tax payments may be reduced. As the majority of 
Environmental Impacts of Alternatives

8-83

1 LGS employees reside in Montgomery, Berks, and Chester Counties, socioeconomic impacts 

2 from plant shutdown would be concentrated in these counties, with a corresponding reduction in

3 purchasing activity and tax contributions to the regional economy. Revenue losses from LGS 

4 operations would directly affect Montgomery County and other local taxing districts and 

5 communities closest to, and most reliant on, the nuclear plant’s tax revenue. The impact of the 

6 job loss, however, may not be as noticeable given the amount of time required to decontaminate 

7 and decommission existing facilities and the proximity of LGS to the Philadelphia metropolitan 

8 area. The socioeconomic impacts of plant shutdown (which may not entirely cease until after 

9 decommissioning) could, depending on the jurisdiction, range from SMALL to MODERATE.

10 8.7.8. Transportation

11 Traffic volumes on the roads in the vicinity of LGS would be reduced after plant shutdown. Most 

12 of the reduction in traffic volume would be associated with the loss of jobs at the nuclear power 

13 plant. The number of deliveries to the power plant would be reduced until decommissioning. 

14 Transportation impacts would be SMALL as a result of plant shutdown.

15 8.7.9. Aesthetics

16 Plant structures and other facilities would remain in place until decommissioning. Most sources 

17 of operational noise would cease. Therefore, aesthetic impacts of plant closure would be 

18 SMALL.

19 8.7.10. Historic and Archaeological Resources 

20 Impacts from the no-action alternative on historic and archaeological resources would be 

21 SMALL. A separate environmental review addressing the protection of historic and 

22 archaeological resources would be conducted for decommissioning. 

23 8.7.11. Environmental Justice

24 Impacts to minority and low-income populations would depend on the number of jobs and the 

25 amount of tax revenues lost by communities in the immediate vicinity of the power plant after 

26 LGS ceases operations. Closure of LGS would reduce the overall number of jobs (there are 

27 currently 820 employed at the facility) and tax revenue for social services attributed to nuclear 

28 plant operations. Minority and low-income populations in the vicinity of LGS could experience 

29 some socioeconomic effects from plant shutdown, but these effects would not likely be high and 

30 adverse. 

31 8.7.12. Waste Management

32 If the no-action alternative were implemented, the generation of high-level waste would stop, 

33 and generation of low-level and mixed waste would decrease. Impacts from implementation of 

34 the no-action alternative are expected to be SMALL.
Environmental Impacts of Alternatives

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1 Table 8–10. Environmental Impacts of No-Action Alternative

No-Action Alternative Continued Operation of LGS

Air Quality SMALL SMALL

Groundwater Resources SMALL SMALL

Surface Water Resources SMALL SMALL

Aquatic Ecology SMALL SMALL

Terrestrial Ecology SMALL SMALL

Human Health SMALL SMALL

Land Use SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL

Transportation SMALL SMALL

Aesthetics SMALL SMALL

Historic and Archaeological SMALL SMALL

Waste Management SMALL(a) SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not 

evaluated in this EIS

2 8.8. Alternatives Summary

3 In this SEIS, the staff has considered alternative actions to license renewal of LGS, including 

4 in-depth evaluations of new generation alternatives (Sections 8.1–8.4), a purchased power 

5 alternative (Section 8.5), alternatives that the staff dismissed from detailed evaluation as 

6 infeasible or inappropriate (Section 8.6; including in-depth consideration of solar PV generation

7 and two combination alternatives), and the no-action alternative in which the operating license is 

8 not renewed (Section 8.7). Impacts of all alternatives considered in detail are summarized in 

9 Table 8-11.

10 Based on the above evaluations, the staff concludes that the environmental impacts of renewal 

11 of the operating license for LGS would be smaller than those of feasible and commercially 

12 viable alternatives studied in this SEIS that satisfy the purpose and need of license renewal 

13 (providing 2,340 MWe of baseload power to the grid). Impacts on air quality are less from 

14 continued operation of LGS than from any of the alternatives involving fossil fuels, though they 

15 are likely to be greater than wind and solar PV alone. Finally, the staff concluded that under the 

16 no-action alternative, the act of shutting down LGS on or before its license expiration would 

17 have mostly SMALL impacts, although socioeconomic impacts would be SMALL to 

18 MODERATE. Depending on how the power lost to the region from reactor shutdown was 

19 replaced (decisions outside of the NRC’s authority and made instead by Exelon, other power 

20 producers, PJM operators, and state or non-NRC Federal authorities), the net environmental 

21 impact of the no-action alternative could be greater than continued reactor operation, especially 

22 when fossil energy power plants provide replacement generation capacity. 
8BEnvironmental Impacts of Alternatives

1 Table 8–11. Summary of Environmental Impacts of Proposed Action and Alternatives

Alternative

Impact Area

Air QualityGroundwater and Surface Water ResourcesAquatic and Terrestrial ResourcesHuman HealthLand UseSocioeconomics (including Transportation and Aesthetics)Historic and Archaeological ResourcesWaste Management

License Renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL(a)

NGCC at an Alternate 

Site

SMALL to 

MODERATE SMALL SMALL SMALL SMALL to MODERATE

SMALL to 

MODERATE

SMALL to 

MODERATE SMALL

SCPC at an Alternate 

Site MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE

SMALL to 

LARGE SMALL MODERATE

New Nuclear at an 

Alternate Site SMALL SMALL SMALL to MODERATE SMALL SMALL to MODERATE

SMALL to 

LARGE SMALL SMALL(a)

Wind Power SMALL SMALL SMALL to 

MODERATE SMALL MODERATE to LARGE

SMALL to 

LARGE

SMALL to 

LARGE SMALL

Purchased Power SMALL to 

MODERATE SMALL SMALL to MODERATE SMALL SMALL to LARGE

SMALL to 

LARGE

SMALL to 

LARGE

SMALL to 

MODERATE

Solar PV (dismissed in 

Section 8.6.1) SMALL SMALL SMALL to MODERATE SMALL SMALL to LARGE

SMALL to 

LARGE

SMALL to

LARGE SMALL

Wind, Solar, and NGCC 

(dismissed in Section 

8.6.2)

SMALL to 

MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE

SMALL to 

MODERATE

SMALL to 

MODERATE SMALL

Wind and CAES

(dismissed in Section 

8.6.3)

SMALL to 

MODERATE SMALL SMALL to MODERATE SMALL MODERATE to LARGE

SMALL to 

LARGE

SMALL to 

LARGE SMALL

No-Action Alternative SMALL SMALL SMALL SMALL SMALL SMALL to 

MODERATE SMALL SMALL(a)

(a) As described in Chapter 6, the issue, “offsite radiological impacts (spent fuel and high level waste disposal),” is not evaluated in this EIS.

8-85
8BEnvironmental Impacts of Alternatives

8-86

1 8.9. References 

2 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

3 production and utilization facilities.” 

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

6 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 

7 “Standards of performance for new stationary sources.” 

8 40 CFR Part 75. Code of Federal Regulations, Title 40, Protection of Environment, Part 75, 

9 “Continuous emission monitoring.” 

10 40 CFR Part 80. Code of Federal Regulations, Title 40, Protection of Environment, Part 80, 

11 “Designation of areas for air quality planning purposes.” 

12 65 FR 79825. U.S. Environmental Protection Agency. 2000b. Regulatory finding on the 

13 emissions of hazardous air pollutants from electric utility steam generating units. Federal 

14 Register 65(245):79825-79831. December 20, 2000.

15 65 FR 33214. U.S. Environmental Protection Agency. 2000c. Notice of regulatory determination 

16 on wastes from the combustion of fossil fuels.” Federal Register 65(99): 32214-32237. 

17 May 22, 2000.

18 76 FR 24976. U.S. Environmental Protection Agency. 2011c. National emission standards for 

19 hazardous air pollutants from coal and oil-fired electric utility steam generating units and 

20 standards of performance for fossil-fuel-fired electric utility, industrial-commercial-institutional, 

21 and small industrial-commercial-institutional steam generating units.” Federal Register

22 76(85):24976-24147. May 3, 2011. Available at 

23 <http://www.epa.gov/ttn/atw/utility/fr03my11.pdf> (accessed 9 May 2011).

24 25 Pa. Code 290. Pennsylvania Administrative Code, Part 1, Department of Environmental 

25 Protection, Title 25, Environmental Protection, Chapter 290, “Beneficial Use of Coal Ash.” 

26 Available at <http://www.pacode.com/secure/data/025/chapter290/chap290toc.html> (accessed 

27 November 2012).

28 [ACAA] American Coal Ash Association. 2010. 2009 Coal Combustion Product (CCP) 

29 Production and Use Survey Report. Aurora, CO: ACAA. November 3. Available at 

30 <http://www.acaa-usa.org/displaycommon.cfm?an=1&subarticlenbr=3> (accessed 

31 29 November 2010).

32 Archer CL, Jacobson MZ. 2007. Supplying baseload power and reducing transmission 

33 requirements by interconnecting wind farms. Journal of Applied Meteorology and Climatology

34 46(11)1701-1717.

35 Atlantic Wind Connection. Undated. “Right of Way Application—FAQs.” Available at 

36 <http://atlanticwindconnection.com/ferc/BOEM/ROW%20application%20FAQs.pdf> (accessed 

37 3 November 2011).

38 Beattie J. EPA easing emissions rules for demand response—generators. The Energy Daily. 

39 Vol. 40, No. 30 (February 13, 2012). 

40 [BLM] Department of the Interior, Bureau of Land Management. 2005. Final Programmatic 

41 Environmental Impact Statement on Wind Energy Development on BLM-Administered Lands in 

42 the Western United States. Washington, DC: BLM. June. Available at 

43 <http://windeis.anl.gov/documents/fpeis/index.cfm\> (accessed 17 May 2011).
8BEnvironmental Impacts of Alternatives

8-87

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21 (accessed 3 November 2011).

9-1 

1 9.0 CONCLUSION

2 This draft supplemental environmental impact statement (SEIS) contains the environmental 

3 review of Exelon’s application for renewed operating licenses for Limerick Generating Station, 

4 Units 1 and 2 (LGS), as required by the Code of Federal Regulations (CFR), Part 51 of 

5 Title 10 (10 CFR Part 51), the U.S. Nuclear Regulatory Commission’s (NRC’s) regulations that 

6 implement the National Environmental Policy Act (NEPA). This chapter presents conclusions 

7 and recommendations from the site-specific environmental review of LGS and summarizes 

8 site-specific environmental issues of license renewal that the NRC staff (staff) noted during the 

9 review. Section 9.1 summarizes the environmental impacts of license renewal; Section 9.2 

10 presents a comparison of the environmental impacts of license renewal and energy alternatives; 

11 Section 9.3 discusses unavoidable impacts of license renewal, energy alternatives, and 

12 resource commitments; and Section 9.4 presents conclusions and staff recommendations.

13 9.1. Environmental Impacts of License Renewal

14 The staff’s review of site-specific environmental issues in this SEIS leads to the conclusion that 

15 issuing renewed licenses at LGS would have SMALL impacts for the Category 2 issues 

16 applicable to license renewal at LGS, as well as environmental justice and chronic effects for 

17 electromagnetic fields. 

18 The staff considered mitigation measures for each Category 2 issue, as applicable. For surface 

19 water use, current measures to mitigate the environmental impacts of plant operations were 

20 found to be adequate. The Delaware River Basin Commission (DRBC) requires LGS to shift to 

an alternative water source when the flow of the Schuylkill River falls to 560 (15.9 m3 21 /s) to 

22 ensure that LGS cooling water withdrawals and associated consumptive use will not reduce flow 

23 by more than 12 percent during low-flow periods.

24 The staff also considered cumulative impacts of past, present, and reasonably foreseeable 

25 future actions, regardless of what agency (Federal or non-Federal) or person undertakes them. 

26 The staff concluded in Section 4.11 that cumulative impacts of LGS’s license renewal would be 

27 SMALL for all areas except aquatic ecology and terrestrial ecology. For aquatic ecology, the 

28 staff concluded that the cumulative impact would be SMALL to MODERATE. For terrestrial 

29 ecology, the cumulative impacts would be MODERATE. 

30 9.2. Comparison of Alternatives

31 In the conclusion to Chapter 8, the staff considered the following alternatives to LGS license 

32 renewal:

33  natural-gas-fired combined-cycle (NGCC),

34  supercritical pulverized coal,

35  new nuclear,

36  wind power,

37  purchased power, and

38  no-action.

39 The staff concluded that the environmental impacts of renewal of the operating license for LGS 

40 would be smaller than those of feasible and commercially viable alternatives. The no-action 

41 alternative, the act of shutting down LGS on or before its license expires, would have SMALL 

42 environmental impacts in most areas with the exception of socioeconomic impacts which would 

43 have SMALL to MODERATE environmental impact. Continued operations would have SMALL 
Conclusion

9-2 

1 environmental impacts in all areas. The staff concluded that continued operation of the existing 

2 LGS is the environmentally preferred alternative.

3 9.3. Resource Commitments

4 9.3.1. Unavoidable Adverse Environmental Impacts

5 Unavoidable adverse environmental impacts are impacts that would occur after implementation 

6 of all workable mitigation measures. Carrying out any of the energy alternatives considered in

7 this SEIS, including the proposed action, would result in some unavoidable adverse 

8 environmental impacts.

9 Minor unavoidable adverse impacts on air quality would occur due to emission and release of 

10 various chemical and radiological constituents from power plant operations. Nonradiological 

11 emissions resulting from power plant operations are expected to comply with 

12 U.S. Environmental Protection Agency (EPA) emissions standards, although the alternative of 

13 operating a fossil-fueled power plant in some areas may worsen existing attainment issues. 

14 Chemical and radiological emissions would not exceed the National Emission Standards for 

15 hazardous air pollutants.

16 During nuclear power plant operations, workers and members of the public would face 

17 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 

18 exposed to radiation and chemicals associated with routine plant operations and the handling of 

19 nuclear fuel and waste material. Workers would have higher levels of exposure than members 

20 of the public, but doses would be administratively controlled and would not exceed standards or 

21 administrative control limits. In comparison, the alternatives involving the construction and 

22 operation of a non-nuclear power generating facility would also result in unavoidable exposure 

23 to hazardous and toxic chemicals to workers and the public.

24 The generation of spent nuclear fuel and waste material, including low-level radioactive waste, 

25 hazardous waste, and nonhazardous waste would also be unavoidable. In comparison, 

26 hazardous and nonhazardous wastes would also be generated at non-nuclear power generating 

27 facilities. Wastes generated during plant operations would be collected, stored, and shipped for 

28 suitable treatment, recycling, or disposal in accordance with applicable Federal and State 

29 regulations. Due to the costs of handling these materials, power plant operators would be 

30 expected to carry out all activities and optimize all operations in a way that generates the 

31 smallest amount of waste possible.

32 9.3.2. Short-Term Versus Long-Term Productivity

33 The operation of power generating facilities would result in short-term uses of the environment, 

34 as described in Chapters 4, 5, 6, 7, and 8. “Short-term” is the period of time that continued 

35 power generating activities take place.

36 Power plant operations require short-term use of the environment and commitment of resources 

37 and commit certain resources (e.g., land and energy), indefinitely or permanently. Certain 

38 short-term resource commitments are substantially greater under most energy alternatives, 

39 including license renewal, than under the no-action alternative because of the continued 

40 generation of electrical power and the continued use of generating sites and associated 

41 infrastructure. During operations, all energy alternatives require similar relationships between 

42 local short-term uses of the environment and the maintenance and enhancement of long-term 

43 productivity.
Conclusion

9-3 

1 Air emissions from power plant operations introduce small amounts of radiological and 

2 nonradiological constituents to the region around the plant site. Over time, these emissions 

3 would result in increased concentrations and exposure, but they are not expected to impact air 

4 quality or radiation exposure to the extent that public health and long-term productivity of the 

5 environment would be impaired.

6 Continued employment, expenditures, and tax revenues generated during power plant 

7 operations directly benefit local, regional, and State economies over the short term. Local 

8 governments investing project-generated tax revenues into infrastructure and other required 

9 services could enhance economic productivity over the long term.

10 The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous 

11 waste, and nonhazardous waste requires an increase in energy and consumes space at 

12 treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 

13 waste disposal needs would reduce the long-term productivity of the land.

14 Power plant facilities are committed to electricity production over the short term. After 

15 decommissioning these facilities and restoring the area, the land could be available for other 

16 future productive uses.

17 9.3.3. Irreversible and Irretrievable Commitments of Resources

18 This section describes the irreversible and irretrievable commitment of resources that have 

19 been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit 

20 the future options for a resource. An irretrievable commitment refers to the use or consumption 

21 of resources that are neither renewable nor recoverable for future use. Irreversible and 

22 irretrievable commitment of resources for electrical power generation include the commitment of 

23 land, water, energy, raw materials, and other natural and man-made resources required for 

24 power plant operations. In general, the commitment of capital, energy, labor, and material 

25 resources are also irreversible.

26 The implementation of any of the energy alternatives considered in this SEIS would entail the 

27 irreversible and irretrievable commitment of energy, water, chemicals, and in some cases, fossil 

28 fuels. These resources would be committed during the license renewal term and over the entire 

29 life cycle of the power plant, and they would be unrecoverable.

30 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 

31 operations and electricity for equipment and facility operations. Electricity and fuel would be 

32 purchased from offsite commercial sources. Water would be obtained from existing water 

33 supply systems. These resources are readily available, and the amounts required are not 

34 expected to deplete available supplies or exceed available system capacities.
Conclusion

9-4 

1 9.4. Recommendations

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

3 renewal for LGS are not great enough to deny the option of license renewal for energy-planning 

4 decisionmakers. This recommendation is based on the following:

5  the analysis and findings in NUREG-1437, Volumes 1 and 2, Generic 

6 Environmental Impact Statement for License Renewal of Nuclear Plants, 

7  the environmental report submitted by Exelon,

8  consultation with Federal, state, and local agencies,

9  the NRC’s environmental review, and

10  consideration of public comments received during the scoping process. 
10-1 

1 10.0 LIST OF PREPARERS

2 Members of the U.S. Nuclear Regulatory Commission’s (NRC’s) Office of Nuclear Reactor 

3 Regulation (NRR) prepared this SEIS with assistance from other NRC organizations and 

4 contract support from Pacific Northwest National Laboratory (PNNL). Table 10–1 lists each 

5 contributor’s name, affiliation, and function or expertise.

6 Table 10–1. List of Preparers

Name Affiliation Function or Expertise

NRC

David Wrona NRR Branch Chief

Jeremy Susco NRR Branch Chief

Leslie Perkins NRR Project Manager

Michelle Moser NRR Aquatic Ecology

Briana Balsam NRR Terrestrial Ecology

William Rautzen NRR Radiation Protection; Human 

Health

Kevin Folk NRR Hydrology

Andrew Stuyvenberg NRR Air Quality & Meteorology; 

Alternatives

Jeffrey Rikhoff NRR Socioeconomics; Environmental 

Justice; Land Use

Emily Larson NRR Historic & Archaeological 

Resources; Socioeconomic

Allison Travers NRR Historic & Archaeological 

Resources

Jerry Dozier NRR Severe Accident Mitigation 

Alternatives

Contractor(a)

Eva Hickey PNNL Radiation Protection

Ann Miracle PNNL Aquatic Ecology

Lance Vail PNNL Hydrology

Jim Becker PNNL Terrestrial Ecology

Jeremy Rishel PNNL Air Quality & Meteorology

Tara O’Neil PNNL Historic & Archaeological 

Resources

David Anderson PNNL Land Use

(a)PNNL is operated by Battelle for the U.S. Department of Energy

11-1 

1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS

2 TO WHOM COPIES OF THIS SEIS ARE SENT

3 Table 11–1. List of Agencies, Organizations, and Persons to Whom Copies of this SEIS 

4 Are Sent

Name and Title Company and Address

EIS Filing Section U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20004

Tom McColloch

Office of Federal Programs

Advisory Council on Historic Preservation

Old Post Office Building, Suite 803

1100 Pennsylvania Avenue, NW 

Washington, DC 20004

Douglas C. McLearen

Chief, Division of Archaeology and Protection

Pennsylvania Historical and Museum Commission

Bureau for Historic Preservation

Commonwealth Keystone Building, 2nd Floor

400 North Street

Harrisburg, PA 17120

Jean Cutler

Deputy, State Historic Preservation Officer

Pennsylvania Historical and Museum Commission

Bureau for Historic Preservation

Commonwealth Keystone Building, 2nd Floor

400 North Street

Harrisburg, PA 17120

Chris Urban

Chief, Natural Diversity Section

Pennsylvania Fish and Boat Commission

Division of Environmental Services

Natural Diversity Section

450 Robinson Lane

Bellefonte, PA 16823-9620

Olivia Mowery

Environmental Planner

Division of Environmental Planning and Habitat 

Protection

Bureau of Wildlife Habitat Management

Pennsylvania Game Commission

2001 Elmerton Avenue

Harrisburg, PA 17110-97-97

Clinton Riley

Field Office Supervisor

U.S. Fish and Wildlife Service

Pennsylvania Field Office

315 South Allen Street, Suite 322

State College, PA 16801

Mark Roberts U.S. Fish and Wildlife Service

Pennsylvania Field Office

315 South Allen Street, Suite 322

State College, PA 16801
List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent

11-2 

Name and Title Company and Address

Chris Firestone Pennsylvania Department of Conservation and 

Natural Resources

Bureau of Forestry–Plant Program

Forest Advisory Services

P.O. Box 8552

Harrisburg, PA 17105-1673

Daniel Morris

Acting Regional Administrator

National Marine Fisheries Service

Northeast Regional Office

55 Great Republic Drive

Gloucester, MA 01930-2276

Brice Obermeyer Delaware Tribe Historic Preservation Office

1420 C of E Drive, Suite 190

Emporia, KS 66801

Anthony Gonyea

Faithkeeper

Onondaga Nation

Hemlock Road, 11a Box 319-B 

Via Nedrow, NY 13120

Sherry White

Cultural Preservation Officer

Stockbridge-Munsee Band of the Mohican

Stockbridge-Munsee Tribal Preservation Office

W13447 Camp 14 Road

P.O. Box 70

Bowler, WI 54416

Henryetta Ellis Absentee-Shawnee Tribe of Oklahoma

2025 South Gordon Cooper Drive

Shawnee, OK 74801

Robin Dushane

Cultural Preservation Officer

Eastern Shawnee Tribe of Oklahoma

P.O. Box 350

Seneca, MO 64865

Tamara Francis

Tribal Historic Preservation Officer

Tribal Historic Preservation Office

Delaware Nation

P.O. Box 825

Anadarko, OK 73005

Clint Halftown

Heron Clan Representative

Cayuga Nation

P.O. Box 11

Versailles, NY 14168

Chief Roger Hill Tonawanda Seneca Nation

7027 Meadville Road

Basom, NY 14013

Neil Patterson, Jr. 

Director, Tuscarora Environmental Program

Tuscarora Nation

2045 Upper Mountain Road

Sanborn, NY 14132

Kim Jumper

Tribal Historic Preservation Officer

Shawnee Tribe

29 South 69a Highway

Miami, OK 74354
List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent

11-3 

Name and Title Company and Address

Arnold Printup

Historic Preservation Officer

St. Regis Mohawk Tribe

412 State Route 37

Akwesasne, NY 13655

Paul Barton

Historic Preservation Officer

Seneca–Cayuga Tribe of Oklahoma

23701 South 655 Road

Grove, OK 74344

Lana Watt

Tribal Historic Preservation Officer

Seneca Nation of Indians

90 Ohiyoh Way

Salamanca, NY 14779

Corina Burke Tribal Historic Preservation Office

Oneida Nation of Wisconsin

P.O. Box 365

Oneida, WI 54155-0365

Jesse Bergevin

Historian

Oneida Indian Nation

1256 Union Street

P.O. Box 662

Oneida, NY 13421-0662

Michael P. Gallagher

Vice President, License Renewal Projects

Exelon Generation Company, LLC

200 Exelon Way

Kennett Square, PA 19348

Nancy L. Ranek

Environmental Lead

Exelon Generation Company, LLC

200 Exelon Way, KSA-2-E 

Kennett Square, PA 19348

Chris Wilson

Licensing Lead

Exelon Generation Company, LLC

200 Exelon Way, KSA-2-E 

Kennett Square, PA 19348

Environmental Review Section U.S. Environmental Protection Agency

Region 3

1650 Arch Street

Philadelphia, PA 19103-2029

William Muszynski

Branch Manager, Water Resources Management

Delaware River Basin Commission

P.O. Box 7360

25 State Police Drive

West Trenton, NJ 08628-0360

Ken Stoller

Project Review Section Chief

Delaware River Basin Commission

P.O. Box 7360

25 State Police Drive

West Trenton, NJ 08628-0360

Steve Walsh Delaware River Basin Commission

P.O. Box 7360

25 State Police Drive

West Trenton, NJ 08628-0360

Regional Administrator U.S. Nuclear Regulatory Commission

Region 1

2100 Renaissance Boulevard

Renaissance Park

King of Prussia, PA 19406
List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent

11-4 

Name and Title Company and Address

Professor Paul Friesseman Northwestern University

304 Scott Hall

Evanston, IL 60208

Michael Stokes Montgomery County Planning Commission

P.O. Box 311

Norristown, PA 19404

Thomas Sullivan Montgomery County Department of Public Safety

Operation Center

50 Eagleville Road

Eagleville, PA 19403

Natural Resources Defense Counsel Natural Resource Defense Counsel

1152 15th Street NW, Suite 300

Washington, DC 20005

Representative Tom Quigley Pennsylvania State Representative

Lorraine Ruppe Resident

Dr. Fred Winter Resident

Dr. Anita Baly Resident

Camilla Lange Resident

Eric Hamell Resident

Steven Furber Resident

Charlene Padworny Resident

Sylvia Polluck Resident

Joe Roberto Resident

Richard Kolsch Resident

Charles Shank Resident

Elizabeth Shank Resident

Nancy Leaming Resident

Cynthia Gale Resident

Jude Shwegel Resident

Michael Gale Resident

Melissa Atrium Resident

Michael Atrium Resident

Joan McGone Resident

Mary Lou Smith Resident

Harold Smith Resident

Lisa Moyer Resident

Ken Sekellick Resident

Debby Penrod Resident

Charlie Koeing Resident
List of Agencies, Organizations, and Persons to Whom Copies of This SEIS Are Sent

11-5 

Name and Title Company and Address

Joyce Webber Resident

Charlotte Derr Resident

Dr. Lewis Cuthbert Alliance for Clean Environment

Sharon Yohn Resident

Michael Smokowicz Resident

Barbara Miller Resident

Bill Maguire Exelon Generation Company, LLC

12-1 

1 12.0 INDEX

2 3 A 

4 accidents, xviii, 4-38, 5-1, 5-2, 5-3, 5-4, 

5 5-5, 5-7, 5-8, 5-9, 5-10, 5-12, 5-13, 5-14, 

6 8-82,A-12, A-27, A-29, A-31, A-32, A-33, 

B-9 7 

8 Advisory Council on Hispanic 

9 Preservation (HCHP), 1-7, 2-83, 2-94, 

10 4-31, 4-59, 11-1 

11 alternatives, iii, xviii, xix, 1-6, 5-2, 5-3, 

12 5-3, 5-7, 5-13, 6-3, 6-4, 6-5, 8-1, 8-2, 8-3, 

13 8-4, 8-5, 8-8, 8-9, 8-10, 8-12, 8-18, 8-24, 

14 8-28, 8-32, 8-33, 8-37, 8-41, 8-42, 8-43, 

15 8-46, 8-48, 8-49, 8-51, 8-53, 8-56, 8-58, 

16 8-59, 8-60, 8-61, 8-62, 8-63, 8-64, 8-66, 

17 8-68, 8-69, 8-70, 8-71, 8-72, 8-73, 8-77, 

18 8-78, 8-79, 8-81, 8-84, 9-1, 9-2, 9-3, 10-1, 

19 A-1, A-7, A-8, A-9, A-22, A-29, A-30, 

20 A-31, A-32, A-33, A-42, B-9 

21 archaeological resources, xviii, 1-7, 

22 2-80, 2-82, 3-2, 4-28, 4-31, 4-52, 8-3, 

23 8-15, 8-26, 8-35, 8-44, 8-47, 8-54, 8-55, 

24 8-63, 8-72, 8-83, 8-85, 10-1, B-9, D-1 

25 B 

26 biota, 2-32, 2-37, 2-40, 2-43, 2-45, 4-7, 

27 4-13, 4-14, 4-46, 4-47, 4-48,8-11, 8-69, 

28 B-2 

29 boiling water reactor, 2-1, 3-1, 5-6, A-30, 

30 B-7 

31 burnup, 2-1, 5-12, 5-13, B-13

32 C 

33 chronic effects, 1-3, 4-21, 4-28, 9-1, B-7 

34 Clean Air Act (CAA), 2-26, 2-87, 4-43, 

35 8-7, 8-18, 8-19, 8-57, 8-66, 8-86, A-10, 

36 C-2 

37 closed-cycle cooling, xvi, 1-4, 1-6, 2-16, 

38 2-20, 2-21, 2-31, 2-54, 4-8, 4-9, 4-10, 

39 4-13, 4-15, 4-47, 8-3, 8-5, 8-6, 8-11, 8-22, 

40 8-23, 8-28, 8-32, 8-69, 8-80, B-2, B-3, B-4 

41 core damage frequency (CDF), A-30

42 Council on Environmental Quality 

43 (CEQ), 1-4, 4-55

44 critical habitat, 2-52, 2-57, 2-59, 2-60, 

45 2-61, 2-85, 4-15, 4-19, 8-11, 8-12, 8-22, 

46 8-23, 8-32, 8-40, 8-41, 8-51, 8-59, 8-60, 

47 8-69, C-4 

48 D 

49 design-basis accident, 4-38, 5-1, B-9 

50 dischargers, 2-2, 2-8, 2-16, 2-20, 2-33, 

51 2-34, 2-45, 4-5, 4-6, 4-8, 4-9, 4-13, 4-14, 

52 4-24, 4-44, 4-45, 4-47, 4-48, 8-10, 8-11, 

53 8-21, 8-22, 8-31, 8-39, 8-59, 8-69, A-33, 

54 A-41, A-41, B-1, B-2, B-7, C-3, F-2, F-3, 

55 F-4 

56 dose, 2-2, 4-8, 4-22, 4-23, 4-24, 4-25, 

57 4-38, 4-40, 4-50, 4-51, 4-53, 5-8, 5-9, 

58 5-12, 5-13, 7-1, 8-35, 9-2, A-18, A-19, 

59 A-20, B-7, B-9, B-10, B-11, B-12, B-13

60 E 

61 education, 2-67, 2-76, 2-93, 2-95, 2-96, 

62 3-2, 4-28, A-23, B-8 

63 electromagnetic fields, xviii, 1-3, 4-8, 

64 4-21, 4-27, 4-28, 8-52, 9-1, B-6, B-7 

65 endangered and threatened species, 

66 1-7, 1-8, 2-15, 2-50, 2-52, 2-59, 2-85, 

67 2-88. 2-93. 4-10. 4-16. 4-54. 4-58, 8-11, 

68 C-4, D-1 
Index

12-2 

1 Endangered Species Act (ESA), 1-7, 

2 1-8, 2-15, 2-50, 2-52, 2-59, 2-85, 2-88, 

3 2-93, 4-10, 4-16, 4-54, 4-58, 8-11, C-4, 

D-1 4 

5 entrainment, 4-7, 4-13, 8-11, 8-22, 8-31, 

6 8-82, B-2, B-3, B-4 

7 environmental justice (EJ), xviii, 1-3, 

8 1-6, 3-2, 4-28, 4-32, 4-33, 4-38, 4-51, 

9 4-54, 4-55, 8-3, 8-15, 8-26, 8-35, 8-44, 

10 8-48, 8-55, 8-63, 8-72, 8-83, 9-1, 10-1, 

11 B-13

12 essential fish habitat (EFH), C-4, D-1 

13 F 

14 Fish and Wildlife Coordination Act 

15 (FWCA), C-4 

16 G 

17 Generic Environmental Impact 

18 Statement (GEIS), xv, xvi, xvii, xx, 1-3, 

19 1-4, 1-5, 1-6, 1-8,.2-70, 2-71, 3-1, 3-2, 

20 4-1, 4-2, 4-27, 4-28, 4-29, 4-30, 4-33, 

21 4-39, 4-40, 5-1, 5-2, 5-3, 5-4, 5-5, 5-8, 

22 5-14, 6-1, 6-2, 6-3, 7-1, 7-2, 8-1, 8-2, 8-9, 

23 8-12, 8-13, 8-16, 8-23, 8-24, 8-25, 8-33, 

24 8-36, 8-42, 8-45, 8-53, 8-61, 8-70, 8-74, 

25 8-77, 8-78, 8-80, 8-81, A-1, A-5, B-1, B-9 

26 greenhouse gases, 6-3, A-34, A-35, 

27 A-38, A-39

28 groundwater, xviii, 1-6, 2-16, 2-21, 2-22, 

29 2-23, 2-35, 2-26, 2-3, 7, 2-55, 2-56, 2-68, 

30 3-1, 4-4, 4-5, 4-6, 4-7, 4-21, 4-23, 4-24, 

31 4-39, 4-40, 4-41, 4-43, 4-45, 4-46, 4-53, 

32 4-55, 8-3, 8-8, 8-9, 8-10, 8-16, 8-20, 8-21, 

33 8-22, 8-27, 8-28, 8-30, 8-31, 8-36, 8-39, 

34 8-45, 8-46, 8-48, 8-50, 8-56, 8-58, 8-65, 

35 8-68, 8-74, 8-81, 8-84, 8-85, A-7, A-12, 

36 A-13, A-41, B-4, B-5, B-9, C-1 

37 H 

38 hazardous waste, 2-7, 2-8, 2-85, 2-86, 

39 9-2, 9-3, C-4, C-6 

40 heat shock, 4-7, 8-82, B-4 

41 high-level waste, xvi, 1-4, 6-1, 6-2, 8-36, 

42 8-83, B-9, B-10, B-11, B-12, B-13

43 I 

44 Impingement, 4-7, 4-18, 8-11, 8-22, 8-31, 

45 8-82, B-2, B-4, 4-7, 4-13

46 Independent spent fuel storage 

47 installation, 2-2, 2-70, 4-42, 4-50, 4-53, 

48 A-12, F-5 

49 L 

50 low-level waste, 6-1, 8-36, B-12

51 M 

52 Magnuson-Stevenson Fishery 

53 Conservation and Management Act 

54 (MSA), 1-7, 2-50, C-4 

55 Marine Mammal Protectino Act 

56 (MMPA), C-4, 

57 maximum occupational dose, 4-22, B-7 

58 mitigation, xvi, xvii, 1-4, 1-6, 2-15, 2-82, 

59 4-7, 4-9, 4-22, 4-29, 4-40, 4-42, 5-3, 5-5, 

60 5-6, 5-7, 5-9, 5-11, 5-13, 5-13, 5-14, 5-15, 

61 5-16, 5-17, 6-10, 7-1, 7-2, 8-15, 8-26, 

62 8-35, 8-44, 8-47, 8-51, 8-54, 8-60, 8-68, 

63 8-72, 9-1, 9-2, 10-1, A-6, A-12, A-24, 

64 A-29, A-30, A-31, A-33

65 mixed waste, 2-7, 6-1, 8-36, 8-83, B-12

66 N 

67 National Environmental Policy Act 

68 (NEPA), xii, 1-1, 1-8, 2-92, 4-31, 4-33, 

69 4-55, 4-58, 6=-2, 8-1, 9-1, 8-13, A-43, B-1, 

70 B-10, B-11
Index

12-3 

1 National Marine Fisheries Service 

2 (NMFS), 1-7, 2-38, 2-40, 2-45, 2-50, 2-51. 

3 2=-52. 2-53. 2-54. 2-84. 2-93. 4=-10. 4-11. 

4 4-12, 4-58, 4-59, 8-11, 8-22, 8-32, 8-40, 

5 8-51, 8-59, 8-60, 8-69, C-4 

6 National Pollutant Discharge 

7 Elimination System (NPDES), 2-8, 2-16, 

8 2-20, 2-21, 2-31, 2-32, 2-33, 2-36, 2-45, 

9 2-90, 4-13, 4-14, 4-26, 4-47, 8-9, 8-10, 

10 8-20, 8-21, 8-22, 8-30, 8-31, 8-39, 8-40, 

11 8-51, 8-59, 8-68, A-41, A-42, B-2, C-1, 

12 C-3, C-5 

13 nonattainment, 2-26, 2-86, 3-2, 4-42, 

14 8-7, 8-18, 8-23, 8-29, 8-38, 8-50, 8-57,

15 8-66, B-6 

16 O 

17 once-through cooling, B-2, B-3, B-4 

18 P 

19 peak dose, B-10

20 pressurized water reactor, 3-1 

21 R 

22 radon, 4-23, A-19, B-9 

23 Ranny wells, B-5 

24 reactor, xv, xvi, 1-1, 1-5, 2-1, 2-2, 2-6, 

25 2-9, 2-29, 2-70, 2-84, 3-1, 4-1, 4-6, 4-24, 

26 4-25, 4-26, 4-29, 4-50, 4-51, 4-54, 5-1, 

27 5-2, 5-3, 5-4, 5-5, 5-6, 5-12, 5-14, 6-2, 

28 6-4, 6-10, 7-1, 8-2, 8-6, 8-11, 8-17, 8-23, 

29 8-28, 8-32, 8-41, 8-82, 8-84, A-11, A-12, 

30 A-18, A-21, A-23, A-24, A-25, A-26, A-30, 

31 A-31, A-42, B-5, B-7, B-9, B-12

32 refurbishment, 2-27, 2-80, 3-1, 3-2, 4-2, 

33 4-9, 4-10, 4-11, 4-12, 4-13, 4-15, 4-16, 

34 4-21, 4-25, 4-33, 4-42, 4-43, 4-53, 8-21, 

35 8-31, A-11, B-1, B-2, B-4, B-6, B-7, B-8, 

36 B-9 

37 S 

38 salinity gradients, 4-3, B-1 

39 scoping, iii, xv, xvii, xx, 1-2, 1-3, 1-6, 

40 2.95, 4-1, 4-2, 4-3, 4-5, 4-7, 4-8, 4-9, 4-21, 

41 4-22, 4-29, 4-32, 4-41, 5-2, 5-11, 5-12, 

42 5-17, 6-2, 7-2, 9-4, A-1, A-2, A-3, A-6, 

43 A-18, A-44, E-2, F-1 

44 severe accident mitigation alternative 

45 (SAMA), 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 

46 5-10, 5-11, 5-12, 5-13, 5-14, A-6, A-7, 

47 A-22, A-27, A-29, A-30, A-31, A-32, A-33

48 severe accidents, 4-38, 5-1, 5-2, 5-3, 

49 5-4, 5-5, 5-7, 5-9, 5-10, 5-13, 5-14, A-12, 

50 A-29, A-31, A-32, A-33, B-9 

51 solid waste, xix, 2-2, 2-6, 2-7, 6-1, 6-2, 

52 7-2, 8-2, 8-76, 8-77, 8-79, A-10, B-13, 

53 C-1, C-4 

54 spent fuel, xvi, 1-4, 2-1, 2-2, 2-70, 4-50, 

55 5-5, 5-6, 6-1, 6-2, 6-10, 8-16, 8-28, 8-36, 

56 8-45, 8-48, 8-56, 8-65, 8-74, 8-84, 8-85, 

57 A-12, A-24, A-28, A-29, A-33, A-34, B-9, 

58 B-10, B-11, B-12, B-13, F-5 

59 State Historic Preservation Office 

60 (SHPO), 2-84, 2-94, 4-59, B-9 

61 surface water, 2-21, 2-22, 2-31, 2-32, 

62 2-36, 2-60, 2-67, 3-1, 4-2, 4-3, 4-4, 4-5, 

63 4-6, 4-23, 4-38, 4-39, 4-43, 4-44, 4-45, 

64 4-47, 4-48, 4-53, 8-3, 8-9, 8-10, 8-11, 

65 8-21, 8-22, 8-30, 8-31, 8-39, 8-51, 8-59, 

66 8-68, 8-69, 8-81, 9-1, A-10, A-13, A-41, 

67 A-42, B-1, B-4, C-1, C-3 

68 T 

69 Transmission lines, 2-15, 2-49, 2-50, 

70 2-51, 2-52, 2-59, 2-82, 2-97, 4-2, 4-10, 

71 4-13, 4-14, 4-15, 4-16, 4-17, 4-18, 4-20, 

72 4-27, 4-28, 4-42, 4-49, 4-52, 4-61, 8-6, 

73 8-28, 8-39, 8-46, 8-47, 8-51, 8-53, 8-55, 

74 8-70, 8-82, B-6, B-9 
Index

12-4 

1 U 

2 U.S. Department of Energy (DOE), 4-28, 

3 8-3, 8-37, 8-38, 8-75, 8-87, 8-89, 8-90, 

B-11 4 

5 U.S. Environmental Protection Agency 

6 (EPA), 1-1, 1-7, 2-7, 2-8, 2-9, 2-24, 2-26, 

7 2-35, 2-36, 2-37, 2-69, 2-70, 2-89, 4-6, 

8 4-25, 4-40, 4-42, 4-45, 4-46, 4-47, 4-50, 

9 4-55, 8-3, 8-7, 8-18, 8-19, 8-23, 8-29, 

10 8-38, 8-50, 8-57, 8-66, 8-67, 8-77, 8-80, 

11 8-86, 8-87, 8-88, 9-2, 11-1, A-13, A-14, 

12 B-1, B-11, C-1, C-2, C-3, C-4, C-6, F-5 

13 U.S. Fish and Wildlife Service (FWS), 

14 2-50, 2-51, 2-52, 2-55, 2-57, 2-59, 2-60, 

15 2-61, 2-62, 2-84, 2-90, 2-91, 4-10, 4-11, 

16 4-12, 4-17, 4-18, 4-19, 4-57, 8-11, 8-12, 

17 8-22, 8-23, 8-32, 8-40, 8-41, 8-51, 8-59, 

18 8-60, 8-69, D-1, D-2 

19 uranium, 2-1, 2-2, 4-50, 5-12, 6-1, 6-2, 

20 6-4, 6-5, 6-6, 6-7, 6-8, 6-9, 8-5, 8-13, 

21 8-23, 8-24, 8-32, 8-33, 8-42,8-53, 8-61, 

22 8-70, A-34, B-9, B-12, B-13

23 W 

24 wastewater, 2-8, 2-21, 2-31, 2-33, 2-36, 

25 2-40, 2-45, 4-3, 4-43, 4-44, 4-47, 8-77, 

26 A-40, B-2, F-2, F-3 

27 Y 

28 Yucca Mountain, B-10, B-11, B-13
1 APPENDIX A

2 COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 

3 UNITS 1 AND 2, ENVIRONMENTAL REVIEW

A-1 

1 COMMENTS RECEIVED ON THE LIMERICK GENERATING STATION, 

2 UNITS 1 AND 2, ENVIRONMENTAL REVIEW

3 A.1. Comments Received during Scoping

4 The scoping process began on August 26, 2011, with the publication of the U.S. Nuclear 

5 Regulatory Commission's (NRC’s) notice of intent to conduct scoping in the Federal Register

6 (FR) (75 FR 53498). As part of the scoping process, the NRC held two public meetings at the 

7 Sunnybrook Ballroom in Pottstown, PA, September 22, 2011. Approximately 100 members of 

8 the public attended the meetings. After the NRC staff presented prepared statements pertaining 

9 to the license renewal and the scoping processes, the meetings were opened to members of the 

10 public for their comments. Attendees provided oral statements that were recorded and 

11 transcribed by a certified court reporter. Transcripts of the entire meeting are available using 

12 the NRC’s Agencywide Documents Access and Management System (ADAMS). ADAMS 

13 Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. 

14 Transcripts for the afternoon and evening meetings are available in ADAMS under Accession 

15 Nos. ML11287A207 and ML11287A211, respectively (NRC 2011a, NRC 2011b). In addition to 

16 the comments received during the public meetings, comments were received through the mail 

17 and e-mail. 

18 Each commenter was given a unique identifier so that every comment could be traced back to 

19 its author. Table A-1 identifies the individuals who provided comments applicable to the 

20 environmental review and the commenter ID associated with each person’s set of comments. 

21 The individuals are listed in the order in which they spoke at the public meeting and in random 

22 order for the comments received by letter or e--mail. To maintain consistency with the scoping 

23 summary report, the unique identifier used in that report for each set of comments is retained in 

24 this appendix.

25 Specific comments were categorized and consolidated by topic. Comments with similar specific 

26 objectives were combined to capture the common essential issues raised by participants. 

27 Comments fall into one of the following general groups: 

28 • Specific comments that address environmental issues within the purview of 

29 the NRC environmental regulations related to license renewal. These 

30 comments address the Category 1 (generic) or Category 2 (site-specific) 

31 issues identified in NUREG-1437, “Generic Environmental Impact Statement 

32 for License Renewal of Nuclear Plants” (GEIS), or issues not addressed in 

33 the GEIS. The comments also address alternatives to license renewal and 

34 related Federal actions. There are also comments that do not identify new 

35 information for the NRC to analyze as part of its environmental review.

36 • There are comments that address issues that do not to fall within or are 

37 specifically excluded from the purview of NRC environmental regulations 

38 related to license renewal. These comments typically address issues such as 

39 the need for power, emergency preparedness, security, current operational 

40 safety issues, and safety issues related to operation during the renewal 

41 period.

42
Appendix A

A-2 

1 Table A–1. Individuals Providing Comments during the Scoping Comment Period 

2 Commenters are identified below, along with their affiliations 

3 and how their comments were submitted.

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Dr. Lewis Cuthbert Alliance for a Clean 

Environment 1 

Afternoon scoping 

meeting ML11287A207

Evening scoping 

meeting ML11287A211

Letters

ML11354A392

ML11036A244

ML11036A245

Bill Maguire Limerick Site Vice 

President, Exelon 2 

Afternoon scoping 

meeting Ml11287A207

Evening scoping 

meeting ML11287A211

Representative 

Tom Quigley State Representative 3 Afternoon scoping 

meeting ML11287A207

Lorraine Ruppe Resident 4 

Afternoon scoping 

meeting ML11287A207

Evening scoping 

meeting ML11287A211

Letter ML11308B354

Mike Gallagher Vice President for License 

Renewal, Exelon 5 

Afternoon scoping 

meeting ML11287A207

Evening scoping 

meeting ML11287A211

Dr. Fred Winter Resident 6 

Afternoon scoping 

meeting ML11287A207

Evening scoping 

meeting ML11287A211

Letter ML11305A016

Thomas Neafcy Resident 7 Afternoon scoping 

meeting ML11287A207

Dr. Anita Baly Resident 8 

Afternoon scoping 

meeting ML11287A207

Letter ML11035A010

Tim Fenchel Schuylkill River Heritage 

Area 9 Afternoon scoping meeting ML11287A207

Bill Vogel Resident 10 Afternoon scoping 

meeting ML11287A207
Appendix A

A-3 

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Eileen Dautrich Tri-County Area Chamber of 

Commerce 11 Afternoon scoping meeting ML11287A207

Billy Albany Resident 12 Afternoon scoping 

meeting ML11287A207

John McGowen Jaeco/Gas Breaker/UMAC, 

Inc. 13 Afternoon scoping meeting ML11287A207

Ted Del Gaizo Resident 14 Afternoon scoping 

meeting ML11287A207

Tim Phelps Resident 15 Afternoon scoping 

meeting ML11287A207

Thomas Saporito Saporito-Associates 16 Evening scoping 

meeting ML11287A207

Jeff Chomnuk Resident 17 Evening scoping 

meeting ML11287A207

Daniel Ludwig Resident 18 Evening scoping 

meeting ML11287A207

Catherine Allison 19 Evening scoping 

meeting ML11287A207

Jeffrey Norton Pennsylvania Energy 

Alliance 20 Evening scoping meeting ML11287A207

Dan Ely Resident 21 Evening scoping 

meeting ML11287A207

Jay Beckermen Resident 22 Evening scoping 

meeting ML11287A207

Jim Der Pottstown Energy Advisory 

Committee 23 Evening scoping meeting ML11287A207

Traci Confer Energy Justice Network 24 Evening scoping 

meeting ML11287A207

Camilla Lange 25 E-mail ML11279A107

Eric Hamell 26 E-mail ML11279A108

Steven Furber 27 E-mail ML11279A109

Charlene Padworny 28 Letter ML11279A110

Sylvia Polluck 29 Letter ML11279A111

Joe Roberto 30

E-mail ML11290A106

E-mail ML11279A112

Brice Obermeyer Delaware Tribe Historic 

Preservation Office 31 Letter ML11279A113

Sherry White Stockbridge-Munsee Tribal 

Historic Preservation Office 32 Letter ML11279A114
Appendix A

A-4 

Commenter Affiliation (if stated) ID Comment source

ADAMS 

Accession 

Number

Unknown 33 Letter ML11286A298

Richard Kolsch Resident 34 E-mail ML11286A299

Charles and 

Elizabeth Shank Resident 35 Letter ML11286A300

Nancy Leaming Resident 36 E-mail ML11290A102

Cynthia Gale Resident 37 E-mail ML11290A103

Jude Schwegel 38 E-mail ML11290A104

Michael Gale Resident 39 E-mail ML11290A105

Melissa Antrim Resident 40 E-mail ML11291A155

Michael Antrim Resident 41 E-mail ML11291A156

Joan McGone 42 E-mail ML11292A011

Mary Lou and 

Harold Smith Resident 43 Letter ML11294A208

Lisa Smoyer 44 E-mail ML11300A011

Unknown 45 Letter ML11300A012

Lori Molinari Resident 46 Letter ML11305A072

Doris Meyers Resident 47 E-mail ML11305A014

Ken Sekellick Resident 48 E-mail ML11305A015

Anthony Gonyea Onondaga Nation 49 Letter ML11305A006

Debby Penrod Resident 50 E-mail ML11305A007

Charlie Koeing Resident 51 E-mail ML11305A008

Joyce Webber Resident 52 E-mail ML11305A009

Charlotte Derr Resident 53 Letter ML11307A388

Michael Stokes Montgomery County 

Planning Commission 54 Letter ML11307A387

Thomas Sullivan Montgomery County 

Department of Public Safety 55 Letter ML11307A386

Natural Resources 

Defense Council 56 Letter ML11307A456

Sharon Yohn 57 E-mail ML11307A455

Michael Smokowicz 58 E-mail ML11307A454

Barbara Miller Resident 59 Letter ML11311A063

Debra Schneider Resident 60 Letter ML11313A013
Appendix A

A-5 

1 To evaluate the comments, the NRC staff gave each comment a unique identification code that 

2 categorizes the comment by technical issue and allows each comment or set of comments to be 

3 traced back to the commenter and original source (transcript, letter, or e-mail) from which the 

4 comments were submitted.

5 Comments were placed into one of the technical issue categories, which are based on the 

6 topics that will be contained within the staff’s supplemental environmental impact statement 

7 (SEIS) for Limerick Generating Station (LGS), as outlined by the GEIS. These technical issue 

8 categories and their abbreviation codes are presented in Table A-2.

9 Table A–2. Technical Issue Categories

10 Comments were divided into 1 of the 16 categories below, each of which has a unique 

11 abbreviation code.

Code Technical issue

AL Alternatives Energy Sources

AM Air & Meteorology

DC Decommissioning

GE Geology

GW Ground water

HA Historical and Archeological 

HH Human Health 

LU Land Use

LR License Renewal and its Process

OL Opposition to License Renewal

OS Outside of Scope(a)

PA Postulated Accidents and Severe Accident Mitigation Analyses (SAMA)

RW Radioactive & Non-Radioactive Waste

SE Socioeconomics

SR Support of License Renewal

SW Surface Water

(a) Outside of scope are those comments that pertain to issues that are not evaluated during the environmental 

review of license renewal and include, but are not limited to, issues such as need for power, emergency 

preparedness, safety, security, terrorism, and spent nuclear fuel storage and disposal.

12 Comments received during scoping applicable to this environmental review are presented in this 

13 section, along with the NRC response. They are presented in the order shown in Table A-3. 

14 The comments that are outside the scope of the environmental review for LGS are not included 

15 here but can be found in the scoping summary report, which can be accessed through ADAMS, 

16 Accession No. ML12131A499.
Appendix A

A-6 

1 Table A–3. Comment Response Location in Order of Resource Area

Comment category Page

Alternative Energy Sources (AL) A-7

Air & Meteorology (AM) A-10

Decommissioning (DC) A-10

Geology (GE) A-11

Groundwater (GW) A-12

Historical and Archeological (HA) A-13

Human Health (HH) A-14

Land Use (LU) A-20

License Renewal and its Process (LR) A-20

Opposition to License Renewal (OR) A-24

Postulated Accidents and SAMA (PA) A-27

Radioactive & Non-Radioactive Waste (RW) A-33

Socioeconomics (SE) A-34

Support of License Renewal (SR) A-35

Surface Water (SW) A-39

2 A.1.1. Alternative Energy Sources (AL)

3 Comment: 1-44-AL; We have had 26 years of insults to our environment, and I choose that 

4 word purposely, insults to our environment and costly nuclear power. We can replace it with 

5 safe, clean, renewable energy before 2029. That is a matter of scientific fact.

6 Comment: 4-8-AL; Solar wind, geothermal, ocean thermal, energy conservation and efficiency 

7 are now cheaper than nuclear power, along with being truly clean and safe. The Department of 

8 Energy 2006 report stated solar alone could provide 55 times our entire nation's energy needs 

9 which leads me to a point, there have been numerous studies proving the many dangerous and 

10 deadly consequences of nuclear power.

11 Comment: 5-3-AL; We also reviewed the alternatives if Limerick would not have its license 

12 renewed and another source of electric generation would need to be installed either here on site 

13 or someplace else to generate the replacement electricity. We concluded that any other means 

14 of generating the replacement electricity would have more of an impact on the environment than 

15 continued operation of Limerick. For instance, if Limerick could be replaced by a wind 

16 generation facility, the wind from [it] would have to occupy between 10 and 40 percent of all the 

17 land in the state of Delaware and that would have a huge impact on the land. If a solar facility 

18 could replace Limerick, it would need to cover 32 to 50 percent the entire land area of 

19 Montgomery County.

20 Comment: 6-10-AL; Please listen to this advice after years of doing my best for America. Rely 

21 on more and truly safe and renewable sources like solar, wind, and geothermal power. 

22 A patriotic duty to protect our kids.
Appendix A

A-7 

1 Comment: 16-7-AL; The NRC is required under the law in this review, the environmental 

2 review to consider renewable energy sources, alternatives. And that means need. Is there 

3 really a need for these two nuclear plants to operate and the answer is no. Simply stated if all 

4 the customers who receive power from these nuclear plants were to simply remove their hot 

5 water heaters and replace them with on-demand electric water heaters you would reduce the 

6 electric base load demand by 50 to 70 percent. You wouldn't need either one of those nuclear 

7 power plants to operate. If you take that further and introduce other energy conservation you 

8 would actually have the licensee shut down more of their other power plants because of you 

9 would need a demand. If you take wind energy which is plentiful up there in Pennsylvania and 

10 even the new solar panel which can operate when the sun isn’t shining on a cloudy day you 

11 could replace even more operating power plants. So these renewable energy sources even 

12 with respect to wind energy since you have a common grid throughout the United States you 

13 can have wind farms generate power to a common grid point and supplying the power that 

14 these nuclear plants are now providing. The NRC’s required under the law to consider these 

15 alternatives to extending this license. And I would hope that the NRC’s final evaluation and 

16 review shows a complete and thorough analysis of all these renewable energy sources 

17 including installing on demand hot water electric heater and doing an analysis of how many 

18 megawatts you're going to take off the grid and based on those evaluations make a licensing 

19 determination whether or not this license should be extended. Because 20 years from now all 

20 these renewable resources are going to be all that much more advanced and capable of 

21 supplying all that much more power than they’re currently supplying. 

22 Comment: 25-5-AL; Other forms of energy can and must be utilized to meet consumption 

23 demands. 

24 Comment: 27-1-AL; I am under the belief that the natural disaster in Japan is enough for 

25 Pennsylvania to make a move toward clean energy. 

26 Comment: 28-2-AL; I support more healthy and efficient sources of energy such as Solar and 

27 Wind Power. Please stop ignoring the detrimental effects that this power plant is having on our 

28 environment, health, and children’s health...it’s time to move on to betters things for all involved. 

29 Comment: 29-1-AL; I hope Exelon Energy does not get Renewed. I am sure we could find 

30 alternative energy that would not be contaminating the whole area. 

31 Comment: 35-6-AL; The nuclear process is not an enlightened way to generate electrical 

32 energy. This plant needs to transition itself into a more intelligent way of generating energy by 

33 actually phasing out and safely shutting down the nuclear plant. By retraining its workers and 

34 adopting the safer green technologies, it could truly partner with the local community without 

35 putting its workers out of jobs.

36 Comment: 37-15-A, 39-16-AL; Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not 

37 Needed. It Can And Should Be Replaced With Safe, Clean, Renewable Energy 

38 Comment: 44-5-AL; We as a society need to wake up and start paying attention to the 

39 massive harm power plants can cause to the people, animals, water, air, etc. Why does 

40 everyone want to pay attention when it is way too late?? There are safer alternative forms of 

41 energy available to our country/communities. We should be working on them and training 

42 employees, who currently work for the nuclear power plants, how to work with safer forms of 

43 energy to help our country move forward in today’s society.

44 Comment: 44-10-AL; We deserve to live in a community where our air and water isn’t being 

45 contaminated constantly with hazardous chemicals, radiation, etc., when there are other energy 

46 alternatives out there that are being used that are safer for the community.
Appendix A

A-8 

1 Comment: 44-12-AL; Do your job knowing that you are doing what is morally right and safe for 

2 humanity and for my children and for the future of generations to come. Please help women 

3 have a chance to carry a baby full term without complications due to any possible air and water 

4 pollution that may have been caused by allowing more radiation into the environment when 

5 there are safer alternatives for energy.

6 Comment: 53-2-AL; We need cleaner air and water. We need to decrease radiation. We 

7 need clean, safe, renewable energy. 

8 Comment: 60-3-AL; Do not extend—Plenty of safe alternatives—water—solar—wind—

9 geothermal.

10 Comment: 60-19-AL; Can replace with clean renewable energy before current license expires. 

11 Response: In evaluating alternatives to license renewal, the NRC staff first selects energy 

12 technologies or options currently in commercial operation, as well as some technologies not 

13 currently in commercial operation but likely to be commercially available by the time the current 

14 LGS’s operating licenses expire, in 2024 and 2029. 

15 Second, the NRC staff screens the alternatives to remove those that cannot meet future system 

16 needs. Then, the remaining options are screened to remove those whose costs or benefits 

17 don’t justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, 

18 constitute alternatives to the proposed action that the NRC staff evaluates in depth throughout

19 Chapter 8. 

20 The staff will evaluate all reasonable alternatives in Chapter 8 of the SEIS. In this chapter, the 

21 NRC staff examines the potential environmental impacts of alternatives to license renewal for 

22 LGS, as well as alternatives that may reduce or avoid adverse environmental impacts from 

23 license renewal, when and where these alternatives are applicable. 

24 In addition to evaluating alternatives to the proposed action, the NRC staff also—when 

25 appropriate—examines alternatives that may reduce or avoid environmental impacts of the 

26 proposed action; the NRC staff does so to illustrate how such alternatives may mitigate potential 

27 impacts of license renewal. 

28 The NRC staff considered 18 alternatives to the proposed action and then narrowed to the five 

29 alternatives considered. In addition to the five alternative, the staff considered the no-action 

30 alternative (not renewing the operating license). 

31 The alternatives evaluated in depth included the following;

32 • natural-gas-fired combined-cycle (NGCC)

33 • supercritical pulverized coal 

34 • new nuclear

35 • wind power

36 • purchased power

37 • no action

38 Other alternatives considered, but dismissed, are listed below:

39 • solar power

40 • combination alternative of wind, solar, and NGCC

41 • combination alternative of wind and compressed-air energy storage

42 • wood waste

43 • conventional hydroelectric power

44 • ocean wave and current energy
Appendix A

A-9 

1 • municipal solid waste

2 • biofuels

3 • oiled-fired power

4 • delayed retirement

5 • coal-fired integrated gasification combined-cycle 

6 • demand-side management

7 A.1.2. Air & Meteorology (AM)

8 Comment: 1 -16-AM; Major air pollution issues under health-based standards of the Clean Air 

9 Act, 32 individual sources listed. Drastic, harmful increases permitted in particulate matter 

10 known also as PM-10 from the cooling towers, other air pollution increases also permitted.

11 Comment: 1-22-AM; They are a major air polluter under the Clean Air Act and to say they're 

12 not doing it anymore, they just asked for the conditions that would allow an eightfold increase in 

13 dangerous air pollution that actually is claimed to kill people, thousands of deaths per year. And 

14 they asked for an eightfold increase. As a matter of fact, these are all the air pollution sources 

15 and the pollutants they list in their own permit. If you add that to all the radiation emissions 

16 there’s a broad range of radionuclides. 

17 Comment: 1-32-AM; [M]ajor air pollution under health-based standards of the Clean Air Act. 

18 A Title 5 permit being issued to this facility means by definition that they are a major air polluter 

19 under the federal Clean Air Act.

20 Comment: 37-2-AM, 39-3-AM; Major Air Pollution Under Health Based Standards of the Clean 

21 Air Act

22 Comment: 60-8-AM; They want increase emissions—Pollutants

23 Response: Air pollutant emissions associated with LGS operations are presented in 

24 Sections 2.2.2.1 of the SEIS. The NRC’s evaluation of LGS’s air emissions is presented in 

25 Section 4.2 of this SEIS. 

26 Comment: 35-3-AM; Limerick Nuclear’s request for re-licensing is ludicrous, considering its 

27 aging and inadequate equipment, its increased air pollution by particulate matter, its horrific 

28 destruction of Schuylkill river

29 Response: Aging management of plant systems is evaluated as part of the LRA safety review. 

30 The results of the staff’s safety review of the LRA for LGS will be documented in the staff’s 

31 safety evaluation report (SER).

32 Air pollutant emissions associated with LGS operations are presented in Sections 2.2.2.1 of the 

33 SEIS. The NRC’s evaluation of LGS’s air emissions is presented in Section 4.2 of this SEIS. 

34 Surface water resources at LGS, including the Schuylkill River, and the effects of plant 

35 operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of 

36 the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied upon 

37 by LGS and including the sources of water used to augment low flows in the Schuylkill River.

38 A.1.3. Decommissioning (DC)

39 Comment: 34-2-DC; A firm closure plan should be approved before license renewal is 

40 accepted. This must include what is to be done with the site, where the nuclear waste will be 

41 disposed of etc. 
Appendix A

A-10

1 Response: Decommissioning would occur whether LGS were shut down at the end of its 

2 current operating license or at the end of the period of extended operation. Environmental 

3 impacts from the activities associated with the decommissioning of any reactor before or at the 

4 end of an initial or renewed license are evaluated in the GElS (NUREG-1437) and in 

5 NUREG-0586 Generic Environmental Impact Statement for Decommissioning Nuclear Facilities, 

6 Supplement 1, “Regarding the Decommissioning of Nuclear Power Reactors,” published 

7 in 2002. The findings from these two documents are used to support the findings in the SEIS by 

8 the use of tiering. Tiering is a process by which agencies eliminate repetitive discussions. The 

9 effects of license renewal on the impacts of decommissioning are stated in Chapter 7 of this 

10 SEIS. 

11 A.1.4. Geology (GE) 

12 Comment: 1-12- GE; Limerick, in addition, is now third on the earthquake risk list for nuclear 

13 plants in the United States.

14 Comment: 4-2-GE; [F]our months have passed since the NRC failed to get back to me when I 

15 asked how close the Remapo fault line is to the Limerick nuclear reactors?

16 Comment: 4-14-GE; It took five months for the Nuclear Regulatory Commission to answer my 

17 question concerning how close the nearest fault line is to Limerick Nuclear Plant. No wonder! 

18 Two faults are dangerously close. Chalfont Fault is only 9 miles East. Ramapo Fault is 17 

19 miles Northwest. This is alarming!

20 Comment: 30-2-GE; Limerick should NOT be approved for an extension with their permit for 

21 the following reasons:

22 • Limerick is designated as one of the TOP THREE nuclear plants in the 

23 country based on it's construction (which is similar to the ones in Japan—and 

24 we see how they failed) and the fact that it sits on an earthquake fault line.

25 • The NRC JUST a few weeks ago stated that “more information needs to be 

26 done and studied” regarding further fortifying nuclear plants regarding 

27 earthquakes. Thus, until you folks know exactly what needs to be done, 

28 etc.THERE IS NOTHING TO APPROVE as long as Limerick sits in it's 

29 current position.

30 • Do NOT think that earthquakes only happen on the West Coast—as we 

31 JUST had a 6+ earthquake less than a month ago. BY ONLY luck was there 

32 no damage to the plant, environment or community.

33 Comment: 51-4-GE; Limerick is built on a fault

34 Comment: 52-5-GE; It is one of the six most dangerous plants in the country because [of] its 

35 proximity to an earthquake fault. 

36 Comment: 60-2-GE; Earthquake Fault

37 Response: Geologic and seismic conditions were considered in the original design of nuclear 

38 power plants and are part of the license bases for operating plants. Seismic conditions are 

39 attributes of the geologic environment that are not affected by continued plant operations and 

40 refurbishment and are not expected to change appreciably during the license renewal term for 

41 all nuclear power plants. Nevertheless, as part of characterizing the environmental baseline 

42 (affected environment) and associated resource conditions of LGS and the vicinity, 

43 Section 2.2.3 of the SEIS includes a discussion of the current geologic environment, including 

44 its seismic setting. Specifically, the section includes a discussion of the Ramapo fault system. 
Appendix A

A-11

1 This fault system encompasses the Chalfont fault and other named geologic faults. In addition, 

2 the NRC and Exelon considered in Chapter 5 of this SEIS whether increased seismic risk could 

3 provide a seriously different picture of severe accidents mitigation at Limerick. 

4 As noted in the section, the nearest mapped faults to LGS have not been geologically active for 

5 more than 140 million years.

6 To the extent that the comments express concern for the seismic design of LGS, the seismic 

7 design of structures are beyond the scope of the environmental review. NRC’s assessment of 

8 seismic hazards for existing nuclear power plants is a separate and distinct process from 

9 license renewal reviews. Seismic hazard issues are being addressed by the NRC on an 

10 ongoing basis at all licensed nuclear facilities. The NRC requires all licensees to take seismic 

11 activity into account to maintain safe operating conditions at all nuclear power plants. When 

12 new seismic hazard information becomes available, the NRC evaluates the new data and 

13 models to determine if any changes are needed at existing plants, regardless of whether or not 

14 a plant has renewed its license or is applying for license renewal. This reactor oversight 

15 process, which includes seismic safety, remains separate from license renewal.

16 Unrelated to license renewal, the NRC completed the Generic Issues Program Safety/Risk 

17 Assessment Stage for Generic Issue (GI) 199 in August 2010, “Implications of Updated 

18 Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing 

19 Plants,” which evaluated recent updates to estimates of the seismic hazard in the central and 

20 eastern United States. The results of the GI-199 Safety/Risk Assessment indicated that the 

21 currently operating nuclear power plants have adequate safety margin for seismic issues. The 

22 NRC’s assessment indicated that overall seismic risk estimates remain SMALL, and adequate 

23 protection is maintained. NRC Information Notice 2010–18 (ADAMS Accession 

24 No. ML101970221) was then issued to nuclear power plants and independent spent fuel 

25 storage installations (ISFSI). It provided notice of the NRC’s intent to follow the appropriate 

26 regulatory process to request that operating plants and ISFSIs provide specific information 

27 relating to their facilities to enable the NRC staff to complete the Regulatory Assessment, in 

28 which candidate backfits would be identified and evaluated. The NRC then developed a draft 

29 Generic Letter to request needed data from power reactor licensees. 

30 However, following the accident at the Fukushima Dai-ichi nuclear power plant resulting from 

31 the March 11, 2011, Great Tohoku Earthquake and subsequent tsunami, the NRC established 

32 the Near-Term Task Force, as directed by the Commission. The Japan Near-Term Task Force 

33 assessment resulted in the issuance of letters requesting information per Title 10 of the Code of 

34 Federal Regulations (10 CFR) 50.54(f) letter on March 12, 2012. These letters were issued to 

35 all power reactor licensees and holders of construction permits and address GI-199 in its 

36 entirety in recommendation 2.1 regarding seismic reevaluations, (ADAMS Accession 

37 No ML12056A046). The NRC staff will use this information, as well as information requested in 

38 the 10 CFR 50.54(f) letter, to determine if further regulatory action is needed, including issuing 

39 orders to modify, suspend, or revoke a license. 

40 A.1.5. Groundwater (GW)

41 Comment: 1-34-GW, 37-5-GW, 39-6-GW; Radioactive Groundwater Contamination. 

42 Comment: 37-4-GW, 39-5-GW; Schuylkill River Depletion and Major Drink Water 

43 Contamination

44 Comment: 45-10-GW; Limerick contaminated groundwater. Radioactive leaks and spills over 

45 the years were never cleaned up. More radioactive leaks can be expected in the future through 

46 earthquakes, deterioration, and corrosion. Many residential well are very close to Limerick. 
Appendix A

A-12

1 Response: This comment deals with groundwater quality issues related to the operation of 

2 LGS. Groundwater resources at LGS, and the effects of plant operations on groundwater 

3 hydrology and quality, are presented in Sections 2.2.5 and 4.4 of the SEIS. Specifically, 

4 Section 2.2.5.1 discusses groundwater users at and in the vicinity of the plant, and 

5 Section 2.2.5.2 summarizes the results of the NRC’s review of Exelon’s Radiological 

6 Groundwater Protection Program for LGS, including the placement of site groundwater 

7 monitoring wells. As part of this evaluation, the NRC staff specifically reviewed the 

8 hydrogeologic investigation prepared for LGS in 2006 and the results of ongoing groundwater 

9 quality monitoring. Chapter 2 of this SEIS cites all studies reviewed by the NRC staff. 

10 Based on the staff’s review, and as presented in Section 4.4.3 of this SEIS, no strontium-90 or 

11 gamma-emitting radionuclides have been detected in groundwater or surface water associated 

12 with LGS operations or at levels above natural background. While inadvertent releases of 

13 liquids containing tritium (a radioactive isotope of hydrogen) have occurred to the ground and 

14 subsurface at LGS, levels in groundwater have been less than one-tenth of the EPA established 

15 drinking water standard of 20,000 picoCuries per liter. No upward trend in tritium levels has 

16 been observed, and Exelon’s ongoing Radiological Groundwater Protection Program functions 

17 to detect and address potential new sources of groundwater contamination. Further, there are 

18 no offsite drinking water wells downgradient of LGS that could be affected by inadvertent 

19 releases of radionuclides to groundwater. 

20 A.1.6. Historical and Archaeological (HA) 

21 Comment: 31-1-HA; Thank you for informing the Delaware Tribe on the proposed construction 

22 associated with the above referenced project. Our review indicates that there are no religious or 

23 culturally significant sites in the project area. As such, we defer comment to your office as well 

24 as to the State Historic Preservation Office and/or the State Archaeologist. 

25 We wish to continue as a consulting party on this project and look forward to receiving a copy of 

26 the cultural resources survey report if one is performed. We also ask that if any human remains 

27 are accidentally unearthed during the course of the survey and/or the construction project that 

28 you cease development immediately and inform the Delaware Tribe of Indians of the inadvertent 

29 discovery.

30 Comment: 49-1-HA; Thank you for providing the Onondaga Nation with information about this 

31 project. If any changes are made, I would like to be consulted. I realize that Unit 1 and Unit 2 

32 have licenses that may be renewed in 2024 and 2029 respectively, therefore you may send 

33 updates and information until then.

34 In the event that during project construction, any archeological resources or remains, including, 

35 without limitation, human remains, funerary objects, sacred objects, or objects of cultural 

36 patrimony are uncovered, please immediately stop construction and contact me at 

37 (315) 952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at

38 (315) 475-2559.

39 Response: In accordance with 36 CFR 800.8(c), the NRC has elected to coordinate 

40 compliance with section 106 of the National Historical Preservation Act with steps it has taken to 

41 meet its requirements under the National Environmental Policy Act (NEPA). An overview of 

42 consultation activities that occurred during the preparation of this SEIS is given in 

43 Section 4.10.6. All consultation parties will receive a copy of the draft SEIS to review and 

44 provide comments to the NRC. 
Appendix A

A-13

1 A.1.7. Human Health (HH)

2 Comment: 1-15-HH; Research has confirmed radiation in our children's baby teeth in this 

3 community. 

4 Comment: 1-18-HH; Alarming cancer increases that have been well documented in this 

5 community repeatedly far higher than national and state averages after Limerick started 

6 operating until the late 1990s. 

7 Comment: 1-25-HH; The sooner this place closes the better off we'll all be. Even if you look at 

8 infant mortality rates we have higher infant mortality rates and neonatal mortality rates far above 

9 state averages and even above Philadelphia and Reading, and we've had these for quite 

10 awhile. The fact is when babies are the most vulnerable in the womb what else would we 

11 expect? And by the way, for those of you who have been saying that ACE data is anecdotal 

12 today I have news for you. This infant mortality report for example is state data reported by 

13 EPA in 2003. Every cancer statistic that you see back there is based on Pennsylvania Cancer 

14 Registry statistics or CDC statistics. So it is not anecdotal, those are the cancer increases, 

15 those are the cancer above the national average that have happened here since Limerick 

16 started operating.

17 Comment: 1-26-HH; We have so many cancers above the national average. Childhood 

18 cancer, 92.5 percent higher than the national average. Think about that. We track the cost of 

19 one child with cancer diagnosed at six months to two years and up until that time it was 

20 $2.2 million. How many more kids have that above the national average? Cost that out and 

21 how many other cancers are above the national average?

22 Comment: 1-36-H; [D]ocumented alarming cancer increases especially in our children since 

23 Limerick started operating

24 Comment: 4-6-HH; There has been increased particulate matter in the air and other toxics 

25 from Limerick causing increased asthma, heart attacks, and strokes. And to add insult to injury, 

26 Limerick was granted a permit to allow an eight-fold increase in air pollution since 2009. Cancer 

27 rates in our area have skyrocketed since Limerick has been up and running in the '80s and 

28 rates have steadily increased.

29 Comment: 4-7-HH; The Toothfairy Project showed high levels of strontium 90, a radionuclide 

30 in baby teeth of children nearest to nuke plants. Baby teeth near Limerick plant had the highest 

31 levels in the whole United States. This stuff and God knows what else is in our bodies now 

32 thanks to a Nuclear Regulatory Commission that to put it nicely is less than enthusiastic about 

33 protecting us.

34 Comment: 6-1-HH; As a physician practicing radiology for over 50 years, I still have strong 

35 concern about cancer sensitivities from harmful radiation exposures, naturally. My medical 

36 colleagues share the same concerns because we have seen our cancer rates increase since 

37 the Limerick power plant started, especially thyroid cancer. It jumped to 78 percent higher here 

38 than the national average. And some of the people I talked to, this is because people are aging 

39 more now, getting older, so there are more cancers. But that's not true because in other areas 

40 similar to our area in Pottstown, they're not nearly getting the thyroid cancers that we are. This 

41 has been well established by the state.

42 Comment: 6-2-HH; Having attended a Hiroshima, Japan atom bomb clinic right after World 

43 War II, naturally I had a chance to see the worst results of harmful radiation. All those little kids 

44 I saw who only lived for a few days, it left me with a very sad memory. Of course, what is 

45 happening here will be taking much longer, but it sure is not good. I don't know whether you've 

46 heard that some scientists are already predicting that -- I'm sorry to tell you this, but nuclear 
Appendix A

A-14

1 energy has the capacity of destroying mankind. It may take about 100 years, but our whole 

2 world is exposed to the harmful effects, maybe not so much here in the United States, but the 

3 whole world can be affected.

4 Comment: 6-6-HH; According to the National Center of Disease Control, Pennsylvania ranks 

5 No. 1 for the highest incidence of Thyroid cancer. This occurred after installation of nuclear 

6 power plants in our area as well as in the rest of the State. Medical journals are reporting high 

7 rates of cancer near nuclear plants. 

8 Comment: 6-8-HH; Incidentally, baby teeth studies have revealed Strontium 90 radioactive 

9 particles which can affect the child’s immune system for more illness. 

10 Comment: 19-6-HH; but I hate to tell you I have so many friends and coworkers and people 

11 that are only 35, 40, 50 years old, cancer. And why? We have to stop and think. Go home, 

12 don't just always, you know, just go watch TV and get on your computer. Stop and think what 

13 we're doing to ourselves, our bodies, our children, our grandchildren.

14 This is again, this licensing renewal is coming down to human lives, the quality of our lives. 

15 Again, why all this cancer? Microwaves and electricity. So I won't go on and on, but I just think 

16 us as a group can't just all be just complaining about the power companies, we are the ones 

17 using the electricity. That's all I'm saying. Maybe we should cut back and we won't need power 

18 plants.

19 Comment: 21-2-HH; Some people don't understand about radiation and I read when the 

20 Japanese thing occurred and I heard on the news a radiologist talking about oh, the radiation is 

21 such a low amount. It really isn't the low amount of radiation exposure that we get incidentally 

22 in standing next to a nuclear power plant. It's three ten-thousandths of a gram of plutonium that 

23 is death for you if you breathe that dust particle. It's almost certain death. And the problem 

24 becomes you can't have -- and it's not going to be a nuclear bomb. It's going to catch on fire if 

25 the fuel pool girders were to fail and you'll have a cloud of a material that in and of itself you 

26 might not have radiation exposure to it but that particle when it deposits itself can be an issue 

27 much the same as fluoride is what causes thyroid cancer when it's a radioactive fluoride. That's 

28 why we're very careful in building a plant with no Teflon and no fluoride components

29 Comment: 36-1-HH; I am concerned about the effects of our surrounding air and water supply 

30 of my children and grandchildren, some of whom are already inflicted with cancer and other 

31 diseases. 

32 Comment: 37-1-HH, 39-2-HH; Radiation into Air and Water From Routine and Accidental 

33 Emissions

34 Comment: 37-7-HH, 39-8-HH; Alarming cancer increases, especially in children, since 

35 Limerick started operating

36 Comment: 37-14-HH, 39-15-HH; Increased Costs to the Public—More cancers and other 

37 costly illnesses, more emergency room visits and hospitalization from massive increases in 

38 PM-10 and TDS, treatment of public drinking water, environmental clean-up

39 Comment: 25-2-HH; The scientific statistics citing dramatic increase in cancer rates, infant 

40 mortality, and Schuylkill River water pollution is disturbing. 

41 Comment: 36-3-HH; I am more concerned about the effects of surrounding air and water 

42 supply and the future of my children and grandchildren, some of whom are already inflicted with 

43 cancer and other diseases.

44 Comment: 40-4-HH; it doesn’t take an accident or disaster for Limerick to poison the region’s 

45 residents with radiation. Radiation from Limerick’s routine and accidental emissions alone for
Appendix A

A-15

1 the past 26 years is reason enough to deny Exelon’s request. It’s not credible for NRC to claim 

2 continuous radiation levels are safe for me and my family when there is no safe level of 

3 exposure according to the National Academy of Sciences and Physicians for Social 

4 Responsibility. 

5 NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by 

6 Exelon and DEP cannot be trusted. Exposure to radiation [is] known to cause cancer. It should 

7 be obvious to NRC that Limerick played a major role in our tragic, well documented cancer crisis 

8 after Limerick started operating in the mid 1980s to late 1990s. Four cancer studies based on 

9 PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far higher 

10 than national and state averages, especially in children. Our children had the highest levels of 

11 Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick 

12 Nuclear Plant released SR-90 into our air and water that got into the milk, vegetation, and food 

13 since Limerick started operating. 

14 Comment: 40-5-HH; Thyroid cancer increased by 128% from 1985 to 1997—was as side note, 

15 with no family history or other obvious risk factors in my life, I was recently treated for thyroid 

16 cancer. Since my diagnosis, I have learned of many other locals like me. It’s scary to think the 

17 choice of where we lived could kill us. 

18 Comment: 41-3-HH; Exposure to radiation is known to cause cancer. NRC has not done any 

19 radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP 

20 cannot be trusted—it’s ridiculous to think they could monitor themselves. It should be obvious 

21 to NRC that Limerick played a major role in our cancer crisis after Limerick started operating 

22 mid 1980s to 2000. Four cancer studies based on Pennsylvania Cancer Registry and the CDC 

23 showed skyrocketing rates for several cancers much higher than national and state averages, 

24 especially children—innocent children. Thyroid cancer increased 128% from 1985 to 1997. I 

25 have local friends and family with thyroid cancer and brain cancer—not one, but several. Sadly 

26 it is uncommon in other areas of the country. It used to be uncommon here too—prior to 

27 Limerick. Would you want to live here? Would you approve a license renewal so close to 

28 home? Your job is to safely review the facts. 

29 Comment: 42-2-HH; The increased risk of cancer is well founded in the literature also. 

30 Comment: 44-8-HH; The most alarming and compelling thing to me as a taxpayer, 

31 homeowner, and mother is the overwhelming and alarming cancer increases to the public after 

32 Limerick had started operating. The CDC website showed 92.5% higher than the national 

33 average for childhood cancer in six communities close to the Limerick Nuclear Plant which 

34 included, Pottstown, West Pottsgrove, Lower Pottsgrove, North Conventry, and Douglas Berks 

35 Township from cancers diagnosed from 1995-1999. The Pennsylvannia State Cancer Registry 

36 For Montgomery County from 1985-86 to 1996-97 also shows cancer rates skyrocketed in 

37 Montgomery County where the Limerick Nuclear Plant is located during the Mid 80’s and 90’s 

38 after they opened. Prostate Cancer increased 132%, Thyroid Cancer increased 128%, Kidney 

39 cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin’s Disease increase 67%, 

40 Non-Hogdin’s Lymphoma increased 61%, Breast cancer increased 61%, Pancreas cancer 

41 increased 54%, and Leukemia increased 48%.

42 Radiation exposure can cause cancer and other serious disease and disability, at any level of 

43 exposure according the National Academy of Sciences and Physicians Responsibility. 

44 Permissible radiation levels does not mean that they are safe levels for everyone in the 

45 community. Most permissible levels based on the average healthy adult. They are not levels 

46 that were based or researched for fetuses, infants, toddlers, and children or pets. Fetuses, 

47 infants, children, pets, and the elderly and immuned compromised individuals are at most risk of 

48 health problems. There is a broad range of dangerous randionulcides routinely released into air 
Appendix A

A-16

1 and water from the Limerick Nuclear Plant as well as any accidental releases. Permissible 

2 radiation levels does not mean that they are safe radiation levels, it only means that they are 

3 allowed. 

4 Comment: 44-9-HH; I have children as well as other loved ones that have or have had 

5 allergies, asthma, learning disabilities, speech disabilities, behavioral disabilities, thyroid 

6 conditions, cancers, skin disorders and irritation, etc. I know neighbors and other community 

7 members that have suffered from the same and more. 

8 Comment: 45-6-HH; But, it doesn’t take an accident or disaster for Limerick to poison the 

9 region’s residents with radiation. Radiation from Limerick routine and accidental emissions 

10 alone for the past 26 years is reason enough to deny Exelon’s request. It’s not credible for NRC 

11 to claim continuous radiation levels are safe for me and my family when there is no safe level of 

12 exposure according to the National Academy of Sciences and Physicians for Social 

13 Responsibility. 

14 Comment: 45-7-HH; NRC is failing to acknowledge obvious health harms from Limerick’s 

15 continuous additive, cumulative, and synergistic radiation releases which get into water, food, 

16 soil, vegetation, milk, and our bodies. NRC has no idea what health harms some of the region’s 

17 residents experienced from Limerick Nuclear Plant. NRC never did any radiation monitoring or 

18 testing at Limerick. Evidence shows testing done by Exelon and DEP cannot by trusted. 

19 Comment: 45-8-HH; Exposure to radiation is known to cause cancer. It should be obvious to 

20 the NRC that Limerick played a major role in our tragic, well documented cancer crisis after 

21 Limerick started operating in the mid 1980s to the late 1990s. Four cancer studies based on 

22 PA Cancer Registry and CDC data showed skyrocketing rate for several cancers for higher than 

23 the national and state averages, especially children. Our children had the highest levels of 

24 Strontium-90 radiation in their baby teeth of any group near any nuclear plant studied. Limerick 

25 Nuclear Plant release SR-90 into our air and water that got into the milk, vegetation, and food 

26 since Limerick started operating. Thyroid cancer increased by 128% from 1985 to 1997. Other 

27 cancers rose dramatically as well.

28 Comment: 46-6-HH; Finally, my concerns regarding the impact of this nuclear power plant on 

29 my community are not limited to catastrophic scenarios that might potentially occur. There have 

30 been studies published in health journals that show a higher incidence of certain illness—

31 particular among children—in communities surrounding nuclear plants. While these studies 

32 were conducted in a variety of locations, they seem to be consistent with some of the data that 

33 Pottstown’s local Alliance for a Clean Environment presents on its website regarding increased 

34 cancer and leukemia rates–also especially among children–in the greater Pottstown area. 

35 Comment: 47-2-HH; I am fully aware of the amount of cancer that is prevalent in this area.

36 Comment: 48-2-HH; I moved to Pottstown, Pa., some time ago in perfect health. In 2006, 

37 I was diagnosed with prostate cancer. Although, I cannot prove it was a direct cause of the 

38 nuclear power plant, I feel that much further, unbiased studies and tests need to be done prior 

39 to the relicensing of the Limerick plant by reputable sources not by corporate interests groups 

40 that can manipulate the statistics in Exelon’s favor.

41 Wouldn’t it be in the best interest of our community and surrounding communities if the higher 

42 cancer rate was due the Limerick power plant? This question is a “no brainer.” There is plenty 

43 of time for testing to be done prior to relicensing. 

44 Comment: 51-3-HH; Cancer rates are higher than the national average and NRC is going with 

45 the status quo. 
Appendix A

A-17

1 Comment: 52-6-HH; The surrounding area has abnormally high cancer rates among adults 

2 and children. 

3 Comment: 57-3-HH; I also feel its presence has led to [an] increase of cancer in our area.

4 Comment: 58-1-HH; I feel that there is a lot of people that had not known to report anything 

5 because of not knowing who to go to. I don't understand why the hospitals don't give statistical 

6 information based on areas? 

7 Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's 

8 Hospital until she was 5. With several years of chemotherapy she is now 18 and in remission. 

9 We had lived on Limerick Center Road for most of our young lives and now with our kids. I don't 

10 know what other information you would need but I would be happy to get you whatever you 

11 might need.

12 Comment: 60-10-HH; High infant mortality rates and neo natal, cancer increase, thyroid 

13 cancer rates 70% higher 

14 Comment: 60-14-HH; cancer increases, especially children 

15 Response: The NRC’s mission is to protect the public health and safety and the environment 

16 from the effects of radiation from nuclear reactors, materials, and waste facilities. The NRC’s 

17 regulatory limits for radiological protection are set to protect workers and the public from the 

18 harmful health effects (i.e., cancer and other biological impacts) of radiation on humans. 

19 Radiation standards reflect extensive scientific study by national and international organizations. 

20 The NRC actively participates and monitors the work of these organizations to keep current on 

21 the latest trends in radiation protection.

22 Recently, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art 

23 study on cancer risk for populations surrounding nuclear power facilities. The NAS study will 

24 update the 1990 U.S. National Institutes of Health—NCI report, “Cancer in Populations Living 

25 near Nuclear Facilities.” 

26 The study will be carried out in two consecutive phases. A Phase 1 scoping study will identify 

27 scientifically sound approaches for carrying out an epidemiological study of cancer risks. This 

28 scoping study began on September 1, 2010, and will last for 15 months. The result of this 

29 Phase 1 study will be used to inform the design of the cancer risk assessment, which will be 

30 carried out in a future Phase 2 study.

31 Although radiation can cause cancers at high doses, currently there are no data to

32 unequivocally establish the occurrence of cancer following exposures to low doses, below about 

33 10 rem (0.1 Sv). Radiation protection experts conservatively assume that any amount of 

34 radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is 

35 higher for larger radiation exposures. Therefore, a linear, no-threshold dose response 

36 relationship is used to describe the relationship between radiation dose and detriments such as 

37 cancer induction. Simply stated, any increase in dose, no matter how small, is assumed to 

38 result in an incremental increase in health risk. This theory is accepted by the NRC as a 

39 conservative model for estimating health risks from radiation exposure, recognizing that the 

40 model probably over-estimates those risks. Based on this theory, the NRC conservatively 

41 establishes limits for radioactive effluents and radiation exposures for workers and members of 

42 the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC 

43 (10 CFR Part 20, “Standards for Protection Against Radiation”), the NRC has imposed 

44 additional constraints on nuclear power reactors. Each nuclear power reactor, including LGS, 

45 has license conditions that limit the total annual whole body dose to a member of the public 

46 outside the facility to 25 mrem (0.25 mSv). In addition, there are license conditions to limit the 
Appendix A

A-18

1 dose to a member of the public from radioactive material in gaseous effluents to an annual dose 

2 of 15 mrem (0.15 mSv) to any organ; for radioactive liquid effluents, a dose limit of 3 mrem 

3 (0.03 mSv) to the whole body, and 10 mrem (0.1 mSv) to any organ.

4 Chapter 4 of this SEIS discusses the Radiological Environmental Monitoring Program (REMP) 

5 that LGS uses for environmental monitoring. The purpose of the LGS Radiological REMP is to 

6 evaluate the radiological impact that operation may have on the environment. The program is 

7 designed to highlight and look at specific consumption pathways for local inhabitants and 

8 special interest groups. The LGS radiological environmental monitoring program is made up of 

9 three categories based on the exposure pathways to the public. They are as follows: 

10 atmospheric, aquatic, and ambient gamma radiation. The atmospheric samples taken around 

11 LGS are airborne particulate, airborne iodine, milk, and broad leaf vegetation. Sampling for the 

12 LGS REMP program is performed as specified in Appendix I to 10 CFR Part 50, “Domestic 

13 licensing of production and utilization facilities,” as well as agreements made with the State of 

14 Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection. 

15 The amount of radioactive material released from nuclear power facilities is well measured, well 

16 monitored, and known to be very small. The doses of radiation that are received by members of 

17 the public as a result of exposure to nuclear power facilities are so low (i.e., less than a few 

18 millirem) that resulting cancers attributed to the radiation have not been observed and would not 

19 be expected. To put this in perspective, each person in this country receives a total annual 

20 dose of about 300 mrems (3 mSv) from natural sources of radiation (i.e., radon, 200 mrem; 

21 cosmic rays, 2 mrem; terrestrial (soil and rocks), 28 mrem; and radiation within our body, 

22 39 mrem) and about 63 mrem (0.63 mSv) from man-made sources (i.e., medical x-rays, 

23 39 mrem; nuclear medicine, 14 mrem; consumer products, 10 mrem; occupational, 0.9 mrem; 

24 nuclear fuel cycle, <1 mrem; and fallout, <1 mrem).

25 A number of studies have been performed to examine the health effects around nuclear power 

26 facilities. The following is a list of some of the studies that have been conducted:

27 • In 1990, at the request of Congress, the National Cancer Institute (NCI) 

28 conducted a study of cancer mortality rates around 52 nuclear power plants 

29 and 10 other nuclear facilities. The study covered the period from 1950–1984 

30 and evaluated the change in mortality rates before and during facility 

31 operations. The study concluded there was no evidence that nuclear facilities 

32 may be casually linked to excess deaths from leukemia or from other cancers 

33 in populations living nearby.

34 • Investigators from the University of Pittsburgh found no link between radiation 

35 released during the 1979 accident at the Three Mile Island Nuclear Station 

36 and cancer deaths among nearby residents. This study followed more than 

37 32,000 people who lived within 5 miles (mi) (8 kilometers (km)) of the facility 

38 at the time of the accident.

39 • In January 2001, the Connecticut Academy of Sciences and Engineering 

40 issued a report on a study around the Haddam Neck Nuclear Power Plant, in 

41 Connecticut, and concluded that exposures to radionuclides were so low as 

42 to be negligible and found no meaningful associations to the cancers studied.

43 • In 2001, the American Cancer Society concluded that, although reports about 

44 cancer clusters in some communities have raised public concern, studies 

45 show that clusters do not occur more often near nuclear plants than they do 

46 by chance elsewhere in the population. Likewise, there is no evidence linking 
Appendix A

A-19

1 the isotope strontium-90 with increases in breast cancer, prostate cancer, or 

2 childhood cancer rates.

3 • In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims 

4 that there are striking increases in cancer rates in southeastern Florida 

5 counties caused by increased radiation exposures from nuclear power plants. 

6 However, using the same data to reconstruct the calculations on which the 

7 claims were based, Florida officials did not identify unusually high rates of 

8 cancers in these counties compared with the rest of the state of Florida and 

9 the nation.

10 • In 2000, the Illinois Public Health Department compared childhood cancer 

11 statistics for counties with nuclear power plants to similar counties without 

12 nuclear plants and found no statistically significant difference.

13 In summary, there are no studies to date that are accepted by the nation’s leading scientific 

14 authorities that indicate a causative relationship between radiation dose from nuclear power 

15 facilities and cancer in the general public. The amount of radioactive material released from 

16 nuclear power facilities is well measured, well monitored, and known to be very small.

17 The staff addresses human health impacts of renewing the LGS operating licenses in 

18 Chapters 2 and 4 of the draft SEIS.

19 A.1.8. Land Use (LU)

20 Comment: 54-5-LU; The county has been working hard to develop an interconnected system 

21 of open space and trails along the Schuylkill River and within other natural resource areas of the 

22 county. In doing this, the county has provided funding to local municipalities and nonprofit 

23 conservation organizations to purchase open space and park land; acquired county land and 

24 agriculture easements; and developed trails. The Limerick Generating Station site contains 

25 significant land along the Schuylkill River that has been identified as part of the Schuylkill River 

26 Greenway in the county plan. The use and management of these lands relative to the county 

27 open space and natural areas inventory plans should be evaluated in the relicensing process.

28 Response: Current onsite and offsite land use conditions in the vicinity of LGS are described in 

29 Sections 2.2.1 and 2.2.9.3 of this SEIS. The NRC’s evaluation of LGS’s impacts on onsite and 

30 offsite land use during the license renewal term is presented Section 4.1 of this SEIS. While 

31 license renewal is not expected to affect the use and management of LGS lands identified as 

32 part of the Schuylkill River Greenway, this information will be evaluated with other potential 

33 cumulative effects in Section 4.12.6.

34 A.1.9. License Renewal and its Process (LR)

35 Comment: 1-4-LR; Current 40-year operating licenses expire in 2024 and 2029. Why the rush 

36 to renew these licenses now?

37 Comment: 1-19-LR; While NRC is required to prepare a supplement to the Limerick 

38 Environmental Impact Statement for license renewal, we have little confidence in the process 

39 based on NRC's regulatory history. It would be difficult to enumerate a short list, so I'm going to 

40 rely on written documents.

41 Comment: 4-9-LR; But my big question of the day is why is Exelon applying for an extension 

42 18 years ahead of time?
Appendix A

A-20

1 Comment: 4-13-LR; Exelon is rushing the timeline to reissue a license (18 years ahead of 

2 time) to run Limerick Nuclear Plant into the unknown, yet it took more than 5 months for the 

3 NRC to get back me concerning an already known survey of fault lines. 

4 Comment: 8-1-LR; I'm a retired Lutheran pastor and my concern today is with the speed at 

5 which this application process is going. I mean it seems to me that to predict what 

6 environmental factors will be in place 13 years hence and 18 years hence, posits a kind of 

7 omniscience and prescience that we should attribute to Almighty God, but certainly not to any of 

8 us human beings. I would favor a slower process.

9 Comment: 8-5-LR; As I stated then, I continue to be concerned and puzzled about the very 

10 early and pre-mature application of Exelon to extend the licenses of the towers. One [of] those 

11 does not come up for renewal until 2024 and the other 2029. I ask the NRC not work on the 

12 relicensing for this facility for at least ten years. The wait could only ensure better information. 

13 The public can not possibly benefit from a decision to renew the licenses at this time. The best 

14 decision will be made based on the best possible information. The NRC does not have the best 

15 information this early. Much will happen in the next ten years. I urge NRC to wait and see how 

16 any of it affects the prospect of continuing these plants at that later date. 

17 What can happen in the next ten years that we can all learn from the relevantly could be 

18 anything. It may be better information about how natural disasters are affecting nuclear 

19 facilities; we may know more about weather patterns that could cause damage. We will 

20 certainly know more about the world situation in terms of advances in terrorist technological 

21 capabilities and goals. We will know more about how well nuclear plants in general and the 

22 Limerick facility are faring as they continue age. If someone steps forward to fund studies, we 

23 will know yet more about cancer rates in the nuclear zones

24 Comment: 16-4-LR; This particular nuclear plant, these plants, you know, their license is 

25 already good till 2024. Why are we here now 12 years ahead of time trying to extend this 

26 license? And the only reason is because it's a foot race the NRC's in with Congress and 

27 nothing more. This has nothing to do with protecting public health and safety, it's the NRC's 

28 zeal to continue to rubber-stamp these license extensions without allowing citizens due process 

29 like I already talked about and without doing a cost intense and thorough review.

30 Comment: 19-4-LR; He was stating the fact why are we re-licensing them, what, 12 years 

31 ahead of time. To me that is absurd. Like maybe a year before or they have to do some 

32 studies, two years before. Why do they want us, and I love Thomas's words, rubber-stamp 

33 something? Twelve years beforehand to go into what, 2024 for Unit 1 was it and 2029 for 

34 Unit 2? Why do they need to push this licensing renewal? You've got to stop and think.

35 Comment: 25-1-LR; First of all, considering the impact of the outcome to many area residents, 

36 this forum was not widely publicized for local citizens to be aware of this important matter and 

37 offer feedback. Secondly, it does not make sense that Exelon is pursuing renewal for a license 

38 that does not expire until 2024. 

39 Comment: 30-1-LR; It is NOT due to expire until 2024—thus, Exelon has nothing to [lose] but 

40 getting an extension sooner than later so they can sit back and relax operating for the next 

41 20+ years. 

42 Comment: 30-13-LR; Since the reactor has until 2024—why the rush, and only one public 

43 meeting. I if you have not heard it, you will. There is a major public outrage over this one 

44 meeting and not know about it until too late. People want public meetings so that people hear 

45 that many are against this plant rather than just submitting comments to the NRC which appears 

46 to be rubber stamping license requests—which is not comforting to me and many.
Appendix A

A-21

1 Comment: 3-1-LR; Why is the request so early—The NRC should get a request closer to [the] 

2 expiration date. Also, the inspection should [be] done closer to the expiration date. In 2023, 

3 not 2013. 

4 Comment: 34-1-LR; Why is there rush to renew the license? It is not due until 2024, approval 

5 at the earliest should be 2019. This would allow 5 years for the business plan of PECO to either 

6 continue or close the plant and make arrangements for additional power to replace the closed 

7 plant. 

8 Comment: 41-1-OR; The possible renewal of Limerick Nuclear Plant’s license for 20 years 

9 past its current 2024 and 2029 expiration dates more than 12 years ahead of time, worries me a 

10 great deal. It’s hard to understand why something this major would be done so far in advance. 

11 It’s IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth 

12 would this be renewed early? It’s lengthy process that could begin earlier, but in no way should 

13 something this important be rushed through now. Why not wait until closer to the expiration 

14 dates, and then seek approval? I understand this how the original guidelines were set up—but 

15 those are long outdated. Approving Limerick Nuclear Plant to be relicensed until 2049 would be 

16 jeopardizing the health of millions. Renewing this license could be catastrophic to millions. 

17 Comment: 48-3-LR; Also, why the hurry? Common sense would indicate that Exelon knows 

18 something which we are not aware. Why must the license be renewed at this time when they 

19 are licensed through 2024 and 2029?

20 Again, Why The Hurry? To relicense now is not the best interest of everyone in our area. 

21 Comment: 56-2-LR; Finally, we have grave misgivings regarding the future time-dependence, 

22 accuracy, and relevance of the licensee’s current ER, as presumptively incorporated in the 

23 NRC’s planned SEIS for LGS license extension, given that such license extension will not 

24 become effective until the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for 

25 Unit 2. We submit that any decision to relicense these units must be supported by the most 

26 timely NEPA and SAMA analysis obtainable within a reasonable interval (e.g. five years) prior to 

27 actual expiration of the existing licenses. 

28 Intervals of 12 and 17 years are not required for corporate planning purposes and are far too 

29 long to credibly sustain the accuracy and relevance of NEPA analyses, or for the NRC to 

30 accurately project both the future condition of the plant, the future state of nuclear safety 

31 knowledge, trends in local resource use, population, and the affected environment, and the 

32 future range of reasonable electricity supply alternatives to LGS license extension. By 

33 comparison, major government owned nuclear installations, such as nuclear laboratories and 

34 weapon production sites, are required to conduct site-wide NEPA reviews of their operations 

35 and facility plans every\five years. Using this federal standard for timeliness, the NRC’s NEPA 

36 analysis for LGS relicensing should not commence before 2019, for Unit 1, and before 2024 for 

37 Unit 2, or should be subjected to mandatory reassessment and supplementation after those 

38 dates.

39 Comment: 60-5-LR; 12 years ahead of time—no way to guarantee safety

40 Comment 60-13-LR; NRC should not be considering this so far in advance—no way to assure 

41 safety—shut it down

42 Response: According to NRC regulations, 10 CFR Part 54, “Requirements for renewal of 

43 operating licenses for nuclear power plants,” a nuclear power plant licensee may apply to the 

44 NRC to renew a license as early as 20 years before expiration of the current license. The NRC 

45 determined that 20 years of operating experience is sufficient to assess aging and 

46 environmental issues at the site. Additionally, 20 years is a reasonable lead period because if 
Appendix A

A-22

1 the NRC denies the license renewal application, it takes about 10 years to design and construct 

2 major new generating facilities, and long lead time times are required by energy-planning 

3 decisionmakers. 

4 Comment: 54-7-LR; As part of the environmental assessment process and the evaluation of 

5 the plant safety and long term operational capacity, we think that it is important for the NRC to 

6 maintain close communication with the community surrounding the plant. Overall education 

7 about the plant and the associated risks presented by its operation should be provided in a 

8 variety of ways so that the public is better informed about the plant and the overall evaluation 

9 taking place as part of the relicensing.

10 Response: The NRC’s Office of Public Affairs (OPA) is available to address the public 

11 concerns and questions regarding nuclear safety and information regarding about LGS. The 

12 office follows news coverage of the agency and responds to media and public inquiries. If 

13 members of the public have questions or comments about the NRC, nuclear safety, or related 

14 topics, they can contact OPA at OPA.Resource@nrc.gov. For specific questions and concerns 

15 regarding Limerick, the public can contact the Region I OPA at OPA1.Resource.@nrc.gov. 

16 Additional contact information for OPA can be accessed at http://www.nrc.gov/

17 about-nrc/organization/opafuncdesc.html

18 Comment: 1-6-LR; The public was led to believe that Limerick's generators, fuel pools, and 

19 miles of underground pipes and cables could operate safely for 40 years and then the facility 

20 would close. Is Exelon fearful that the longer they wait the more serious problems may arise?

21 Response: The original licenses for commercial nuclear power plants were granted for 40 year 

22 period, which was set by the Atomic Energy Act 1954 and the NRC’s regulations. It was 

23 imposed for economic and antitrust reasons rather than technical limitations of the plant. 

24 According NRC regulations, 10 CFR Part 54, a nuclear power plant licensee may apply to the 

25 NRC to renew a license as early as 20 years before expiration of the current license. Part 54 

26 requires the applicant to demonstrate that it can successfully manage aging at the facility during 

27 the period of extended operation. 

28 Comment: 22-1-LR; I'm a resident of Phoenixville. I found out about this meeting because I 

29 scan a lot of newspaper websites. I found the notice of the meeting on the West Chester Daily 

30 Local website. Didn't find it in the Phoenixville paper, didn't see it in the Philadelphia 

31 newspaper, didn't hear about it on any of the local radio stations, didn't hear about it on cable, 

32 didn't hear about it on any of the television.

33 Comment: 60-20-LR; Should have been more public notice for hearing—Mail notices so 

34 people have an opportunity to attend.

35 Response: The NRC provides notice of the environmental public meetings through the Federal 

36 Register, press releases, and local advertisements. The public also can get information about 

37 all NRC public meetings at the NRC public Web site, http://www.nrc.gov/public-involve/

38 public-meetings/index.cfm. The public also can receive public meeting notices and press 

39 releases by subscribing to e-mail notices for reactor correspondence for Limerick at 

40 http://www.nrc.gov/public-involve/listserver/plants-by-region.html. 

41 Comment: 22-3-LR: The slide behind me documents exactly two libraries that the documents 

42 are going to go in. Why not in my library in Phoenixville? Why not in Montgomery County and 

43 Norristown and all of the other public libraries that are in areas that can be affected by the 

44 plume should something happen here? Why are the documents in such a restricted area?

45 Response: The NRC contacts the local libraries in the communities surrounding the plant to 

46 ask if the agency could send them copies of license renewal applications and other documents 
Appendix A

A-23

1 related to the license renewal review so that they could be accessed by members of the public. 

2 However, some libraries have limited shelf space and may not be able to accommodate the 

3 NRC. Members of the public also can access the license renewal application and SEIS on the 

4 Limerick license renewal Web page on the NRC public Web site. The public can access the site 

5 at http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html.

6 Additionally, the NRC will have hard copies and CDs of the draft SEIS available for the public 

7 during the public meeting on the draft SEIS. Members of the public also can contact the NRC to 

8 request a hard copy or CD of the SEIS. 

9 Comment: 16-2-LR; And I'd like to correct that statement. He stated that the NRC is extending 

10 the original operating license which was granted by the NRC for a 40-year period of time that 

11 that initial 40- year license was not based on safety considerations or technical considerations. 

12 But that's absolutely not true and there was recently a year-long investigative report done by the 

13 Associated Press who interviewed expert nuclear personnel, engineers, safety engineers in the 

14 nuclear industry who told them that the 40-year licenses issued by the NRC for 104 nuclear 

15 plants in the United States was based on safety and technical—safety technical analysis. So 

16 these proceedings, these license extension proceedings like the one we're currently at are a 

17 rubber-stamping of these 20-year license extensions.

18 Comment: 16-3-LR; This is in fact a foot race between the Nuclear Regulatory Commission 

19 and the United States Congress where Congress wants to stop this process, put a moratorium 

20 on the re-licensing until the Fukushima disasters can be fully understood and the enhancement 

21 enacted in August for our power plants here.

22 Reponses: As a result of Fukushima, the NRC issued three orders requiring safety 

23 enhancements of operating reactors, construction permit holders, and combined license 

24 holders. These orders require nuclear power plants to implement safety enhancements related 

25 to (1) mitigation strategies to respond to extreme natural events resulting in the loss of power at 

26 plants, (2) ways to ensure reliable hardened containment vents, and (3) ways to enhance spent 

27 fuel pool instrumentation. The plants are required to promptly begin implementation of the 

28 safety enhancements and complete implementation within two refueling outages or by 

29 December 31, 2016, whichever comes first. In addition, the NRC issued a request for 

30 information asking each licensee to reevaluate the seismic and flooding hazards at the site 

31 using present-day methods and information, conduct walkdowns of its facilities to ensure 

32 protection against the hazards in its current design basis, and reevaluate emergency 

33 communications systems and staffing levels. LGS is required to comply with the NRC orders or 

34 revised regulations whether or not the operating licenses are renewed. 

35 A.1.10. Opposition to License Renewal (OR)

36 Comment: 1-5-OR; We urge the NRC to say no to Exelon's requested license renewals.

37 Comment: 1-20-LR; It’s long past time for the NRC to summon the courage to do the right 

38 thing in our judgment and actually protect the environment and the public, rather than the 

39 industry.

40 Comment: 1-21-OR; Based on the compelling body of evidence of environmental harms to 

41 date and the enormous increased population in proximity to this facility, Limerick Nuclear Plant 

42 must be closed by 2029. There is no amount of energy production that is worth risking the lives 

43 of so many people.

44 Comment: 1-29-OR; Nuclear Regulatory Commission today and that is very simply that 

45 Limerick nuclear power plant must be closed by the NRC, not re-licensed until 2049.
Appendix A

A-24

1 Comment: 6-5-OR; So please, ask your politicians, reliable politicians to close the Limerick 

2 power plant. Let's save America for our kids and descendants

3 Comment: 6-9-OR; We can’t control the use of nuclear in the rest of the world, but we can 

4 keep the U.S. safer by eliminating nuclear energies. Fortunately, many European allies 

5 including Australia have decided to phase out reactors. We should join them [to] reduce human 

6 suffering. Also this can reduce our increasing costs of health care.

7 Comment: 6-11-OR; Limerick Power Plant is ranked in the top 3 riskiest nuclear power plants 

8 in the U.S.A. Limerick Power Plant must be closed not relicensed. 

9 Comment: 10-1-OR; If Limerick Unit 1 or 2 fails, all hell breaks loose, no disrespect. That's 

10 what a nuclear failure is, hell. It affects everybody in this room, everybody in the community, 

11 everybody in the tri-state area, not for a week, but for decades. It's very, very last thing we want 

12 to happen. 

13 And I think we're putting ourselves in harm's way by taking something that had a lifespan of 

14 40 years and adding another 20 to it. It doesn't make sense. The only way to rationalize it is 

15 through our personal fear of being inconvenienced because we lose a very, very good source of 

16 power. It's done a great job for us. But like me, you get to a point where your ability to provide 

17 a great job is at an end and things start deteriorating. Let’s not put ourselves in that position. 

18 Let’s make an intelligent decision now and allow these two units to expire at their nameplate 

19 time.

20 Comment: 19-3-OR; So from day one I think power plants never should have been built but 

21 now that they are here why would we ever want to re-license.

22 Comment: 25-4-OR; I attend to agree with the fourteen reasons provided by the Alliance For A 

23 Clean Environment why Exelon should be denied the renewal license. In my opinion, the 

24 long-term negative consequences caused by the Limerick Generating Station far outweigh any 

25 possible benefits it may contribute. 

26 Comment: 26-1-OR; Please do NOT extend the Limerick licenses!

27 Comment: 27-2-OR; Renewing Limerick’s license just as controversies are arising with pushes 

28 to move from dependence on Nuclear energy is a bold business strategy by them. I don’t think 

29 this the right move to make. A long term contract will limit any sort of wiggle room to address 

30 future issues that may arise.

31 I ask that you please consider the future of our great state. I don’t think oil or nuclear energy is 

32 the way. I truly believe in heart, that in order to protect the health of our population for the 

33 future, we must change our ways today. 

34 Comment: 28-1-OR; I object being continuously poisoned by the Limerick Nuclear Plant’s 

35 radiation and other dangerous toxins. Please do not allow for an extension of the Limerick 

36 Nuclear Power Plant’s operation license. 

37 Comment: 29-2-OR; The Reactor time has served its years and should not be renewed. 

38 Comment: 30-10-OR; I feel firmly and many in the community feel the exact same way, that 

39 there is no reason to approve NOW (especially so far in advance, with no answer on usage on 

40 rods nor what needs to be done to prevent a meltdown due to an earthquake, etc.) or Ever since 

41 the population will only increase and the facility age further. It is the wrong timing, wrong plant, 

42 wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and “energy” to develop 

43 solar fields, etc... They would rather beat the hell out of a high efficiency plan at any and all cost 

44 to the environment and community. This where the NRC does the right thing and says NO until 

45 a year before it expires. 
Appendix A

A-25

1 Comment: 35-1-OR; Limerick Nuclear’s influence is vast and horrific. This industry is a 

2 behemoth that has not been honest with the public about its true impact, forming its own 

3 "environmental" partnerships that are pure pronuclear propaganda tools. It's economic 

4 contributions are miniscule when compared to its enormous profits, while destroying our quality 

5 of life. The nuclear process’s devastating environmental effect on our community cannot be 

6 understated.

7 Comment: 35-7-OR; Ordinary daily nuclear generation has had devastating community-wide 

8 consequences that need to be addressed. Re-licensing should not even be a consideration! 

9 The NRC must fully investigate the environmental concerns presented Dr. Lewis and Donna 

10 Cuthbert (ACE), Dr. Winter, and each resident who so civilly represented this community's 

11 concerns at the September 22, 2011 hearings. The Limerick Nuclear Power Plant should NOT 

12 be re-licensed and should, instead, begin to address the pollution issues it has already created 

13 as it seriously and carefully shuts down its reactors.

14 Comment: 38-1-OR; I’m writing to you to state my opposition to the relicensing of Limerick 

15 Generating Station in Limerick Township, Pennsylvania.

16 Comment: 40-1-OR; I attended the recent meeting on the possible renewal of Limerick 

17 Nuclear Plant’s license for 20 years past its current 2024 and 2029 expiration dates. I strongly 

18 believe, as do many of my local friends and family that the Limerick Nuclear Plant must be 

19 closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be 

20 jeopardizing the health of thousands and thousands of people in neighboring communities. 

21 There is substantial evidence readily available which justifies closing Limerick. Renewing this 

22 license could lead to a catastrophic meltdown. 

23 Comment: 40-6-OR; It would be careless, unethical and immoral for NRC to approve Exelon’s 

24 requested license extensions Limerick Nuclear Power Plant. Limerick Nuclear Power Plant must 

25 be closed by 2029.

26 Comment: 41-4-OR; Just remember, it would be careless, unethical and immoral for NRC to 

27 approve Exelon’s requested license extensions for Limerick Nuclear Power Plant. Limerick 

28 Nuclear Plant must be closed by 2029.

29 Comment: 42-3-OR; Why does the NRC think they can play God with people lives? It is no 

30 longer debatable, shut it down before our very lives are jeopardized.

31 So-called quality life issues addressed as part of public debate, e.g. “the power is always on” 

32 seems irrelevant to us when our families are required to evacuate during disaster. Limerick 

33 must be closed and NOT relicensed at any cost, specifically the cost of life itself!

34 Comment: 43-1-OR; Do NOT renew Limerick licenses. It’s too dangerous and too old. Please 

35 listen to their neighbors like us. 

36 Comment: 44-1-OR; There are so many reasons why you as a group should already know that 

37 it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, 

38 wildlife in general and the environment for you to refuse/oppose Limerick Power Plant from 

39 re-licensing. The problem that always seems to come up at some of the public hearings and 

40 sessions where businesses/corporations want to expand and become bigger and run their 

41 businesses long past the time that they should truly be allowed in order keep safe, always 

42 comes back to the issue of money, offerings, bribes, donations, etc. in the end. When these 

43 things occur, people and businesses turn a “blind eye” so to speak to the dangers of allowing a 

44 business like the Limerick Power Plant to renew its license again. That is unacceptable. I 

45 expect and demand better service from you to help protect myself and my family from harm!
Appendix A

A-26

1 Comment: 44-4-OR; It is disgusting and heart wrenching to know that officials and 

2 organizations are not paying attention to what can happen to the public if Limerick Power Plant 

3 continues to operate longer than expected. Ignoring the obvious problems our community is 

4 facing and hoping that after they serve their term, it will be someone else problem to deal with is 

5 unacceptable. Now is the time. Step up and [do] what is morally right for humanity

6 Comment: 44-11-OR; I expect you to what is morally right now for me, my family, my 

7 neighbors, my community, and the pets, wildlife, air, water, and environmental in whole by 

8 rejecting, refusing, and opposing Limerick Power Plant from relicensing to run their business 

9 longer than originally planned for 2029. 

10 Comment: 45-1-OR; I urge NRC to deny Exelon’s request to renew Limerick Nuclear Plant’s 

11 license for 20 years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant 

12 must be closed, not relicensed, for many valid reasons. Approval of Limerick Nuclear Plant to 

13 be relicensed until 2049 would be reckless and would show blatant disregard for the health and 

14 safety of the public. There is more than sufficient evidence of harms and threats to justify 

15 closing Limerick. There are too many things beyond NRC’s control that could lead to a 

16 catastrophic meltdown. 

17 Comment: 45-11-OR; It would be both unethical and immoral for NRC to approve Exelon’s 

18 requested license extensions for Limerick Nuclear Power Plant. All of the unprecedented 

19 harms, threats, risks from Limerick Nuclear Plant will increase if NRC approves and additional 

20 20 year Limerick license extension, until 2049. Limerick Nuclear Plant must be closed by 2029.

21 Comment: 46-1-OR; I am writing to express my opposition to the re-licensing of Limerick 

22 nuclear power generating station, which is located about 20 miles from my home. There are 

23 several reasons why this relicensing in not in the best interests of people living in the 

24 surrounding community

25 Comment: 48-1-OR; Just a quick note requesting the NRC to NOT allow the relicensing of the 

26 Limerick, PA, nuclear plant at this time.

27 Comment: 51-1-OR; Please protect our citizens from possible disaster and do not relicense 

28 Limerick

29 Comment: 52-1-OR; As a resident of New Hanover Twp., Montgomery County, PA (less than 

30 5 miles from Exelon’s Limerick Nuclear Power Plant), I urge you to vote AGAINST the 

31 premature relicensing of that facility. 

32 Comment: 53-1-OR; I implore you to not relicense the Nuclear Power Plant of Limerick when 

33 its licenses expires in 2029. If I had my wish, the power plant would be closed years before 

34 2029. 

35 Comment: 57-1-OR; Just wanted to voice my opinion for a no vote to renew the license for the 

36 Limerick power plant. 

37 Response: These comments are general in nature and express opposition to Exelon, nuclear 

38 power, and license renewal of LGS. Portions of these comments that express general 

39 opposition to renewing the licenses for LGS provide no new and significant information and 

40 have not resulted in any changes to this SEIS. Portions of these comments that address 

41 particular technical issues are addressed in the respective technical sections of this appendix.
Appendix A

A-27

1 A.1.11. Postulated Accidents & SAMA (PA)

2 Comment: 1-1-PA; Whether a natural disaster or terrorist attack occurs, by relicensing 

3 Limerick, NRC would in effect be playing Russian roulette with the lives of more than eight 

4 million people. NRC must close Limerick Nuclear Plant by 2029.

5 Comment: 1-13-PA; With loss of cooling water, Limerick's fuel rods could heat up, self ignite, 

6 and burn in an unstoppable fire with catastrophic results. Exelon has not been required to 

7 spend the money to guard limerick against terrorists, missiles, or air strike despite repeated 

8 requests to do so.

9 Comment: 1-24-PA; It’s not safe, it’s a ticking time bomb. And nuclear power, they say it’s 

10 always on. That’s not true either as evidence by shutdowns, some for long periods caused by 

11 earthquakes, tornadoes, hurricanes, fires, heat, and drought and more. 

12 Comment: 4-1-PA; Increasing floods, droughts, earthquakes, tornados have made us all feel 

13 insecure, making nuclear power increasingly risky, especially with the Limerick plant basically in 

14 our backyards. Any earthquake that comes through this area could be a possible Fukushima, 

15 Chernobyl or Three Mile Island...

16 Comment: 4-15-PA; The 9-21-11 Mercury article said “whether or not earthquake risk is a 

17 factor in the current relicensing request for Limerick remains to be seen”. It would be grossly 

18 unacceptable for the NRC to ignore Limerick's extreme vulnerability to earthquake damage.

19 Earthquake risk should be on the top of NRC's relicensing concerns for Limerick. Earthquake 

20 risks are far greater for Limerick than previously realized—increased by 141%. We now know 

21 Limerick is 3rd on nation's earthquake risk list Plus evidence shows earthquakes in the East can 

22 be far stronger than Limerick's “design basis” can withstand.

23 There's a good chance that an earthquake can exceed Limerick's design basis, causing a 

24 severe nuclear accident, jeopardizing the health, safety and financial well being of our entire 

25 region.

26 The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant. Since 

27 January there have been 2 small earthquakes in Philadelphia, only 21 miles from Limerick.

28 Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to 

29 nuclear disaster. It's disquieting that NRC uses a “visual inspection” to determine damage on 

30 buried pipes. Problems may not be identified until it's too late.

31 For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on 

32 fires and earthquakes. To save money, Exelon typically concludes Limerick is “safe enough”. 

33 This is unacceptable!

34 10-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear 

35 plant. The warning was tied to renewed focus on earthquake risk. It's difficult to see how 

36 Limerick's design flaws can be fixed, even if Exelon WOULD spend the money.

37 There is no proof whatsoever Limerick's design can withstand other threats ranging from 

38 hurricanes, tornadoes, floods, or terrorist attacks to an impact from a jet airliner.

39 We need precaution before there is a catastrophe. NRC should close Limerick as soon as 

40 possible.

41 Comment: 6-3-PA; Of course, what is happening here will be taking much longer, but it is sure 

42 not good news. Besides harmful power plant exposures, we have environmental disasters and 

43 a concern about our nearby earthquake fault and others in the eastern U.S., especially one near 
Appendix A

A-28

1 New York City. And then there are the radioactive spent fuel deadly waste material sitting 

2 around, supposedly protected.

3 Comment: 6-7-A; An earthquake in our area is not too far fetched. And of course, threat of 

4 terrorism with vulnerable spent fuel are always a concern. 

5 Comment: 8-6-PA; One big concern—because of Japan’s recent experience and the fact that 

6 we had an earthquake in the Limerick plant’s territory—is refurbishing the plants so they can 

7 withstand earthquakes. It has been widely reported by MSNBC and the AP, using NRC data—

8 that the Limerick plant has the nation’s third highest risk of being damage by an earthquake. 

9 When the plant was built, no one thought this area would get earthquakes. Now we do. I 

10 understand Congress is now or soon will be considering increasing earthquake preparedness 

11 capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would 

12 encourage them to do less than they should to make the plant safer. 

13 Comment: 19-1-A; Now lately with the -- unfortunately it's a reality now that we have 

14 hurricanes, more tornadoes, tsunamis throughout the world. And I hate to say it but it is a reality 

15 now that we have terrorist attacks and Limerick is definitely one. I don't want to be blowing this 

16 out of proportion but it's just something that I know that we've all been concerned about, not 

17 wanting to say yes, Limerick, and all the people that built the power plant and the company say 

18 oh, there's no impact to the air and the water pollution and so forth. So we've kind of just 

19 blinded our, you know, selves to that and let's believe then, okay, let's take a minute. Let's 

20 really believe that there is no impact in our clean air, clean water and those type of things and 

21 cancer, et cetera. Let's just go into the new reality which is terrorist attacks which would 

22 happen. Let's just say for example there was human error there with the spent fuel rods and 

23 something happened, or a radiation leak.

24 Comment: 30-10-PA; Let’s also mention a fact that Category I Hurricane Irene, which could 

25 have been Category 3, just zipped less than 100 miles away from the site a few weeks ago and 

26 then Hurricane Lee which decided to travel further east case close to also causing chaos. 

27 Limerick is still TOO close to the disaster of Hurricanes as well. 

28 Comment: 37-11-PA, 39-12-PA; Increased Risked of Meltdown From More Frequent and 

29 Stronger Earthquakes and Other Natural Disasters

Comment: 45-2-PA; Limerick is 3rd 30 on the earthquake risk list. It is too dangerous to keep 

31 Limerick operating. Earthquakes and other natural disasters are more frequent and stronger. 

32 Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling 

33 water, and meltdown. Limerick’s substandard containment flaw means more radiation would be 

34 released.

35 Comment: 47-1-PA; Limerick Generating Station is old and I don’t think it is strong enough to 

36 with stand plane impacts, earthquakes, or tornadoes that occur here. 

37 Response: The comments express concern for the potential adverse environmental impacts 

38 associated with postulated accidents. The impacts of design basis accidents were evaluated in 

39 the GElS and determined to be small for all plants; therefore, it is a Category 1 issue. The GElS 

40 evaluated severe accidents for all plants including LGS, and it concluded that the impact was 

41 small under Part 51, “Environmental protection regulations for domestic licensing and related 

42 regulatory functions.” In accordance with 10 CFR 51.53(c)(3)(ii)(L), the license renewal 

43 Environmental Reports must provide consideration of alternatives to mitigate severe accidents if 

44 the staff has not previous evaluated SAMAs for the applicant’s plants in an environmental 

45 impact statement or related supplement or in an environmental assessment. The staff has 

46 previously performed a site-specific analysis of severe accidents mitigation in the NEPA 
Appendix A

A-29

1 document for LGS. For the license renewal review, the staff must consider whether new and 

2 significant information affects the environmental determination in the NRC regulations. 

3 A detailed discussion of postulated accidents, and the staff’s considerations of new and 

4 significant information related to SAMA, including seismic risk, can be found in Chapter 5 of this 

5 SEIS.

6 Comment: 56-1-PA; The original SAMA analysis for the Limerick Generating Station (LGS) is 

7 a 1989 report that was issued as the result of a ruling by the U.S. Court of Appeals for the Third 

8 Circuit, which concluded that the NRC had failed to consider a “reasonable set” of Severe 

9 Accident Mitigation Design Alternatives (“SAMDAs”). In 1989, the NRC subsequently adopted 

10 this SAMDA analysis and agency staff concluded they had “discovered no substantial changes 

11 in the proposed action as previously evaluated in the FES [Final Environmental Statement] that 

12 are relevant to environmental concerns nor significant new circumstances or information 

13 relevant to environmental concerns and bearing on the licensing of [LGS]”. 

14 As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, the 

15 notion that an updated SAMA analysis need not be completed at the license renewal stage (for 

16 the exact reactor site that gave birth to the regulatory requirement) we find highly objectionable, 

17 particularly in light of the catastrophic nuclear accident that befell similar Boiling Water Reactor 

18 (BWR) units in Japan in March, 2011. It has become clear in the 770 years of combined 

19 U.S. BWR operational experience since 1989 that domestic and international events provide 

20 numerous examples of “new information” and make a strong case for the need to reconsider all 

21 that has been learned about newly discovered risks and vulnerabilities of nuclear power plants. 

22 It has been noted that global core damage events happen at a rate that exceeds NRC’s 

23 presumptions of what should be considered safe at plants within the U.S., which implies that 

24 either the NRC estimates for domestic plants are wrong or that international nuclear plants have 

25 a core damage frequency much higher than what the NRC deems safe. Either scenario is 

26 troubling and deserves the industry’s full attention and effort. Exelon’s 1989 effort in response 

27 to the Court was, respectfully, less than one would have hoped for in light of the seriousness of 

28 the issue. The LGS 1989 SAMDA can in no way claim necessary conservatism with regard to 

29 public safety over the total timeframe of a possible sixty year reactor lifetime.

30 In contrast to the 1989 SAMDA, relatively recent SAMA analyses conducted in other license 

31 renewal applications, such as those for sites at Nine Mile Point, Three Mile Island, and the 

32 Joseph M. Farley Nuclear Plant, to name a few, were considerably more thorough and 

33 addressed a range of detailed alternatives. Pursuant to regulatory analysis techniques supplied 

34 by NRC and aided by an industry-supplied guidance document most modern-day SAMA 

35 analyses are designed using a fairly prescriptive set of initial assumptions, baseline calculations, 

36 and cost benefit arithmetic recipes that employ the use of sophisticated codes in their evaluation 

37 of potential risk and the benefit of removing this risk.

38 The most common code used is the MELCOR accident consequence code system (MACCS2), 

39 which provides a modeling framework for calculating the off-site consequences of a severe 

40 accident. This code accepts an advanced set of input parameters, including population density 

41 distributions within 50 miles, detailed regional economic data obtained from multiple sources, 

42 nuclide release scenarios accounting for reactor core inventory, emergency response and 

43 exposure variables, and meteorological data for plume migration pathways. The current state of 

44 knowledge regarding the assumptions and understanding of severe accident events has 

45 expanded and improved in the intervening twenty-two years since the initial SAMDA analysis 

46 for LGS. 
Appendix A

A-30

1 While we acknowledge that this analysis was limited by the knowledge available at the time, the 

2 limitations and shortcomings of a previous era in no way disqualify the claim that, in light of 

3 numerous advances in modeling capabilities, a library of discovered cost-beneficial SAMAs, and 

4 the saliency of severe accident risks following the disaster at Fukushima Daiichi, not only is 

5 there new and significant information, there are significant volumes of this information acquired 

6 since 1989.

7 In the licensee’s current environmental report, the identification and treatment of new and 

8 significant information (four items in total) were developed only in the narrow context of how 

9 they may affect the dated SAMDA analysis. It should go without saying that this approach does 

10 not comprise all of the applicable new and noteworthy severe accident mitigation strategies 

11 bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA 

12 analysis.

13 The entire set of first-stage envisioned alternatives in the initial SAMDA analysis was no more 

14 than fifteen options. The “analysis” in the current environmental report consists of perfunctory, 

15 “back-of-the-envelope” calculations in lieu of a proper SAMA analysis. The current operator 

16 Exelon referred to these considerations as representing an “abundance of caution.” We 

17 disagree.

18 One of the largest problems with the calculations offered, aside from only focusing on an 

19 arbitrarily limited number of alternatives, is that licensee evaluated each item of new information 

20 in isolation of the other factors that would also change the cost-benefit conclusion for a 

21 particular alternative. The effects of each changed parameter (e.g., population, offsite economic 

22 risk, cost per person-rem averted, and seismic hazards) should be evaluated in a 

23 comprehensive model that shows the aggregate benefit, as performed in all current day SAMA 

24 analyses. Unfortunately, their analysis barely scraped the surface of how this new information 

25 should actually be considered in the context of environmental impacts.

26 In comparison, a “reasonable set” of alternatives for another recently relicensed plant included 

27 an initial consideration of 128 SAMA candidates developed from previous lists at other plants, 

28 NRC documents, and documents related to advanced power reactor designs. After screening 

29 this initial set for non-applicable or previously implemented designs as well as 

30 combining/dropping common-benefit options, the applicant was still left with a set of forty unique 

31 SAMA candidates, for which it was required to enter preliminary cost estimates in a so-called 

32 “Phase I Analysis.” A total of fifteen SAMA candidates survived this screening to enter more 

33 detailed cost consideration in the Phase II analysis, of which none were deemed cost-beneficial. 

34 However, in another renewal application, the SAMA analysis found eleven potentially 

35 cost-beneficial options from an initial set of thirty-three.

36 In an NRC report discussing insights on SAMAs in connection with plant license renewals, the 

37 agency authors list numerous potentially cost-beneficial SAMAs relating to station blackouts, 

38 protection and support systems, procedures and training, and external events such as flood, 

39 fire, and seismic hazards. The authors note that “averted onsite costs (AOSC) is a critical factor 

40 in cost-benefit analyses and tends to make preventative SAMAs more attractive than mitigative 

41 SAMAs.” This AOSC factor was not considered in either the original SAMDA or the recently 

42 submitted environmental report.

43 Finally, NRDC believes that in addition to a comprehensively updated SAMA analysis, the 

44 licensee or agency must conduct a study that, as part of the supplemental environmental impact 

45 statement, presents postulated accident scenarios showing the full range and weight of 

46 environmental, economic, and health risks posed by these accidents. This type of study should 

47 model site-specific severe accidents and illustrate the full consequences of a range of severe 

48 accident scenarios so that the public and their policy makers can make informed decisions 
Appendix A

A-31

1 whether to continue plant operations after the existing licenses expire, thereby continuing to run 

2 the risk of a severe nuclear accident, invest in additional accident mitigation capabilities, or 

3 alternatively, avoid these risks altogether by relying on a portfolio of low carbon electricity 

4 generation alternatives that could meet future electricity service needs over the license 

5 extension period.

6 The SAMA analyses are inadequate in this regard because they only address isolated issues in 

7 a cost-benefit analysis that discounts the cumulative impacts on displaced populations, regional 

8 economic losses, and environmental cleanup. These types of calculations do not present a 

9 clear picture of the potential hazards or costs experienced in the event of a severe accident. 

10 Instead they tend to mask the full range of accident consequences that policy makers may wish 

11 to avoid. Recently, NRDC produced an analysis, of the type we believe should be included in 

12 the Limerick NEPA analysis, to inform ongoing relicensing efforts at the Indian Point nuclear 

13 plant site.

14 In order to illustrate the full extent of a major accident, the NRDC study used the 

15 U.S. Department of Defense computer model HPAC (Hazard Prediction and Assessment 

16 Capability) to calculate site-specific release radiological source-terms, resulting fallout plumes, 

17 and data on the effects on nearby populations. The results were compared to similar modeling 

18 of the Fukushima disaster to provide a sense of scale, and to estimate the rough magnitude of 

19 financial and economic damages that would be incurred if a severe accident were to occur at 

20 Indian Point. This is not a hypothetical issue. Policy makers in several countries, including 

21 Germany and Switzerland, have made decisions not to grant nuclear plant license extensions to 

22 avoid having to endure the continuing risk of severe nuclear plant accidents.

23 Regardless of Exelon’s own corporate understanding of its legal obligations, NEPA is clear in its 

24 well-established mandates and what it requires of the NRC. NEPA requires that federal 

25 agencies characterize environmental impacts broadly to include not only ecological effects, such 

26 as physical, chemical, radiological and biological effects, but also aesthetic, historic, cultural, 

27 economic, and social effects. NEPA requires an agency to consider both the direct effects 

28 caused by an action and any indirect effects that are reasonably foreseeable. Effects include 

29 direct effects caused by the action and occurring at the same time and place and indirect effects 

30 caused by the action, but later in time or farther removed in distance, but still reasonably 

31 foreseeable.

32 Most specifically, NEPA directs that NRC take a “hard look” at the environmental impacts of its 

33 proposed action, in this instance the relicensing of two BWR Mark 2 units for an additional 

34 20 years, and compare them to a full range of reasonable alternatives. “What constitutes a 

35 ‘hard look’ cannot be outlined with rule-like precision, but it at least encompasses a thorough 

36 investigation into the environmental impacts of an agency’s action and a candid 

37 acknowledgement of the risks that those impacts entail.” Nat’l Audubon Soc. v. Dept of the 

38 Navy, 422 F.3d 174, 185 (4th Cir. 2005) (emphasis added). As a stalking horse for the NRC’s 

39 draft EIS, the applicant’s ER does not meet this standard. In taking the “hard look” required by 

40 law, the NRC must therefore address the potential environmental impacts of a range of severe 

41 accidents—and accident mitigation strategies—especially in light of the new information 

42 provided by the Fukushima nuclear disaster on the performance of BWR radiological 

43 containment in a prolonged loss-of-coolant, core-damage scenario.

44 For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA 

45 analysis be conducted as part of (or supplement to) the required supplemental environmental 

46 impact statement, the draft of which is currently scheduled for August 2012 and the final SEIS 

47 currently scheduled for February 2013. Additionally, the full cumulative effect of severe 

48 accidents must be studied and presented as part of these documents. These analyses must 
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1 make every effort to meet the current expectations of what these studies should encompass and 

2 use the necessary guidance and tools commonly utilized by the industry and NRC. The NRC’s 

3 legal obligation to consider new information and determine its nuclear safety significance exists 

4 independently of whether a SAMA has or has not been prepared previously: in the event a 

5 SAMA has not been prepared, then new and potentially significant nuclear safety information 

6 must be included in the initial SAMA; if a previous SAMA exists, then it must be updated to 

7 reflect this new information, and the resulting costs and benefits of the full spectrum of 

8 reasonable accident mitigation alternatives must be considered as part of the Draft 

9 Supplemental Environmental Impact Statement, and issued for public comment.

10 Response: For license renewal, the NRC discharges its NEPA obligation to consider severe 

11 accidents mitigation through 10 CFR 51.539(c)(3)(ii)(L) and Table B–1. In accordance with 

12 10 CFR 51.53(c)(3)(ii)(L), the license renewal ERs must provide consideration of alternatives to 

13 mitigate severe accidents if the staff has not previous evaluated SAMAs for the applicants 

14 plants in an environmental impact statement or related supplement or in an environmental 

15 assessment. LGS is a plant that had a previous SAMA documented in a NEPA document. 

16 Under NEPA, the NRC must consider whether new and significant information affects 

17 environmental determination in the NRC’s regulations, including the determination in 10 CFR 

18 51353(c)(3)(ii)(L) and Table B–1, that the agency need not reconsider SAMAs at license 

19 renewal if it has already done so in a NEPA document for the plant. New information is 

20 significant if it provides a seriously different picture of the impacts of the Federal action under 

21 consideration. For SAMAs, new information may be significant if it indicated a given 

22 cost-beneficial SAMA would substantially reduce the risk of a severe accident, by reducing the 

23 probability, or the consequences of a severe accident. 

24 The staff’s evaluation of new and significant information for SAMAs is addressed in Section 5.3 

25 of this SEIS.

26 A.1.12. Radioactive & Non-Radioactive Waste (RW)

27 Comment: 1-10-RW; This aging plant is an accident waiting to happen. Large volumes, more 

28 than 6,000 assemblies weighing more than a thousand tons of highly radioactive waste in the 

29 form of spent fuel rods are stored in densely-packed pools, elevated five stories above and 

30 outside the reinforced containment structure.

31 Comment: 1-11-RW; This plant will produce about two more tons of dangerous spent fuel rods 

32 every year that it operates.

33 Comment: 1-14-RW; Dry cask storage and transport are also very dangerous alternatives. 

34 It's time to close Limerick and stop producing such deadly waste for which there is no safe 

35 solution. As long as Limerick operates harms to us and our environment will increase.

36 Comment: 1-30-RW; [R]adiation into air and water from routine and accidental emissions

37 Comment 1-36-RW; [D]eadly high-level radioactive wastes that are packed in vulnerable fuel 

38 pools on this site and they are in fact unprotected. They are above ground and unprotected

39 Comment: 6-4-RW; [T]he radioactive spent fuel deadly waste material sitting around, 

40 supposedly protected 

41 Comment: 18-1-RW; One would be what are we going to do with the 20 years of spent rods 

42 and how are you going to take care of those.
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1 Comment: 23-3-RW; And then to—I'm sure that the generic plan includes a pretty good 

2 discussion of fuel storage long-term and short-term onsite but certainly the site-specific fuel 

3 storage considerations.

4 Comment: 30-7-RW; The NRC and USA Government still have not decided where to store 

5 spent nuclear rods and as we speak each spent rod is sitting in baths on the Limerick site, 

6 stacking up—expanding even a greater hazard to the community, environment, etc. So put 

7 simply, there absolutely no reason to approve this request for years until the US Government 

8 decides how they will handle such rod and such rods and properly stored. 

9 Comment: 34-3-RW; The disposal area must be in operation not some theoretical site like the 

10 now defunct Yucca site. The public and our future generation deserves to know what is 

11 expected to be done at the site. Radioactive material must not be allowed to remain on the site. 

12 Comment: 35-5-RW; Limerick Nuclear’s request for re-licensing is ludicrous, considering its 

13 aging and inadequate equipment, its increased air pollution by particular matter, its horrific 

14 destruction of the Schuylkill River and dangerous above-ground spent fuel rod storage.

15 Comment: 37-8-RW, 39-9-RW; Deadly high level radioactive wastes packed in vulnerable fuel 

16 pools on site

17 Comment: 52-5-RW; The plant can no longer store its used fuel rods and has asked 

18 permission to begin transporting them to another facility.

19 Comment: 60-4-RW; Spent fuel—Storage—Uranium mining—Dirty

20 Comment: 60-11-RW; Nuclear waste—nothing clean

21 Comment: 60-14-RW; Radiation in air and water—Radioactive ground water

22 Response: Radioactive and non-radioactive waste management is discussed in Section 2.1.2

23 in this SEIS. The NRC’s evaluation of impacts of the uranium fuel cycle and waste 

24 management are addressed in Chapter 6 of this SEIS. 

25 A.1.13. Socioeconomics (SE)

26 Comment: 1-28-SE; Then you take the property taxes. They tried to get zero for their property 

27 taxed by the end of the 90s and didn’t pay any property taxes until the early 2000s at which time 

28 they paid $3 million instead of $17 million they were suppose to pay. So when you think about 

29 that no wonder Exelon’s willing throw around a couple million in the community. They owe this 

30 community a lot more than what they’re giving.

31 Comment: 52-3-SE; The area around the facility has exploded with homes and businesses

32 Response: The property taxes paid by Exelon are presented Section 2.2.9.2 in this SEIS. 

33 Section 2.2.9.1 discusses the total number of vacant and occupied housing units in Berks,

34 Chester, and Montgomery counties. Section 2.2.9.6 presents information on the number of 

35 businesses in the area. Section 4.9 presents the NRC’s evaluation of socioeconomic impacts of 

36 continued operation of LGS. In addition, the socioeconomic impacts of not renewing the 

37 operating license are discussed in Chapter 8.

38 A.1.14. Support of License Renewal (SR)

39 Comment: 2-1-SR; Operating Limerick Generating Station safely and reliably is a responsibility 

40 that everyone at the power station takes very seriously. We understand our obligation to the 

41 community, to the environment, and to each other to operate the plant safely. 
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A-34

1 A key component of a thriving community like ours is the availability of safe, clean, and reliable 

2 electricity. And as we look into the future for the power needs of Pennsylvania and the United 

3 States as a whole, we can see the increasing demand for this very important resource.

4 At the same time, there's a growing concern about greenhouse gases and climate change that 

5 is a result of burning fossil fuels. To help meet that growing power demand and to help keep 

6 our environment clean, Exelon has applied to the U.S. Nuclear Regulatory Commission for a 

7 20-year extension to the plant's operating license. Limerick's current license for Unit 1 will 

8 expire in 2024 and Unit 2 in 2029. With license renewal, Limerick can provide our region with 

9 clean power through 2049.

10 We understand our special obligation to operate the plant safely and reliably and to maintain a 

11 close relationship with our neighbors. We pledge to continue that special trust as we operate 

12 the plant well into the future.

13 Comment: 3-1-SR; I’m here today to voice my strong support for the relicensing of the 

14 Limerick Generating Station. I wanted to touch on a couple points of why I feel it is important for 

15 this facility to be relicensed. 

16 First is the amount of electricity that is produced by this facility. One of the things that myself 

17 and my colleagues in Harrisburg hear consistently from businesses and the Commonwealth and 

18 our citizens is the demand for energy and electricity now and more importantly what that 

19 demand is going to be in the future. 

20 Right now this facility generates enough electricity for two millions homes and without producing 

21 some of the greenhouse gases that we hear so much about that could be produced by coal, 

22 natural gas, or oil. And I'm going to put a caveat in there for my good friends out in the western 

23 part of the state where coal is a big part of the Pennsylvania economy and I’m suggesting that 

24 this be done to the exclusion of coal and nevertheless, some of the technologies that they're 

25 developing out there are also important for that industry and important for the Commonwealth of 

26 Pennsylvania.

27 Again, one of the concerns we hear consistently from businesses is how can we come here into 

28 Pennsylvania with the infrastructure being what it is which needs to be improved for the 

29 transmission of the electricity, but more importantly the generation of that electricity? 

30 Number two, I think is important is the jobs and overall economy. Again, in these tough 

31 economic times that we're facing here in the Commonwealth of Pennsylvania and also in this 

32 nation, one of the top issues that we hear consistently about is jobs.

33 And as was mentioned by the site vice president, over 860 people are employed here with an 

34 annual payroll of $75 million. The direct impact that is to the Commonwealth of Pennsylvania, 

35 of course, is realized through the state income tax and also all of these local municipalities most 

36 of them enact an earned income tax which again sustains their townships as well as their 

37 respective school districts. To have that taken away I think would have an even more dramatic 

38 impact on our local economy.

39 As was mentioned the impact for the local area here, the temporary workers who show up here 

40 during the outages and the refueling, there's already been two hotels that have sprung up along 

41 the 422 corridor with another one planned right up here at the Sanatoga area. Again, more jobs 

42 and more economic growth here for our communities.

43 Thirdly, I want to talk about the communication that I’ve experienced in the seven years that I've 

44 been in office with Exelon and with their Government Affairs people as well as with their site

45 people. I've been on the site three times, twice for a tour and one to make a presentation during 

46 an anniversary of the facility. And I have to say that it is a very secure area. I know a lot of 
Appendix A

A-35

1 people are concerned about terrorism attacks or people being on the property. But unless 

2 you've actually gone over there and gone through a tour, seeing how things are set up, seeing 

3 the armed guards there, seeing the security measures that are in place, I think you come away 

4 much more relieved with that. And I’m able to speak to my constituents more affirmatively about 

5 the safety and security of the facility.

6 Any time that there's been the slightest occurrence there, whether it will be a couple times a 

7 hunter has wandered onto the property where the authorities were called, the Government 

8 Affairs people at Exelon are on the phone to me or with an email right away to let me know 

9 what's happening before the word gets out to the media or to the press. So they're always very 

10 well prepared in their explanations, not only of things that happen at the plant itself, but also 

11 incidents and issues that occur around the country and around the world.

12 Obviously, what took place in Japan with the incident over there, they were on the phone with 

13 me and met with me a few times to explain what took place over there and how the safeguards 

14 are being put in place here so that doesn’t happen at this facility.

15 Comment: 5-1-SR; Because the license Generating Station can be operated safely and 

16 reliably, Exelon decided to pursue license renewal for Limerick. Limerick is a very clean energy 

17 source which produces no greenhouse gas emissions. Limerick is also good for the economy in 

18 that it lowers market prices on electricity for the citizens of Pennsylvania to the tune of 

19 $880 million per year.

20 Comment: 5-4-SR; [W]e operate Limerick safely and we can continue to operate it safely for 

21 an additional 20 years. Limerick will provide approximately 2340 megawatts of base-load 

22 generation that's not only safe, but it's clean, reliable and economical.

23 Continued operation of Limerick will benefit this community, the Commonwealth of Pennsylvania 

24 and our nation. 

25 Comment: 7-1-SR; As the largest private employer in the region, the Board is thankful for the 

26 860 jobs that Exelon provides, the positive impact of their operation, the vitality of our local 

27 community. The community and local economy are enhanced by the needed services provided 

28 by the township, which includes the roadway network maintained by our Limerick Township 

29 Public Works, public safety provided by the Limerick and Linfield Fire Companies, and our local 

30 emergency medical response, our public parks, our recreation facilities and also the police 

31 protection that's provided by Limerick’s 21 sworn officers.

32 Because of Limerick Generating Station's location within our borders, the Limerick Township 

33 Police Department is the only municipal police department in Pennsylvania with the primary 

34 jurisdiction over Tier 1 critical infrastructure. This Board prides itself on the services provided 

35 directly both to the residents and the businesses of this community and the township's ability to 

36 maintain those current levels of service during these difficult economic downturns. We are 

37 thankful for the generosity of the Limerick generating plant and Exelon for being good corporate 

38 neighbors and the assistance they provide to the community. Without their financial assistance 

39 that impact to provide those services to the community would fall squarely on the backs of the 

40 taxpayers. They assist in our fire companies. They have been corporate sponsors of our 

41 Limerick Community Days. And we are confident that Limerick generating facility and Exelon 

42 will continue that support in the future and be our good corporate neighbor. We also are in 

43 support of the relicensing of the Limerick nuclear plant.

44 Comment: 11-1-SR; I’m president of the Tri-County Area Chamber of Commerce. I'm happy 

45 to be here today to provide examples of how Limerick Generating Station is a valued community 

46 and business partner and echo the statements already shared by several others. They’re one 

47 of the tri-county area’s largest employer, providing professional employment opportunities for 
Appendix A

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1 local residents. Those local residents employed by Limerick Generating Station are supporting 

2 the entire tri-county business community. They’re purchasing personal goods and services from 

3 local small businesses. The annual outage is a tremendous benefit to the local economy and 

4 our local businesses. Limerick encourages their outage employees to visit and purchase from 

5 tri-county area, local businesses, and small businesses. 

6 In addition to the jobs they provide local residents, they’re making a significant investment in our 

7 local communities. Municipalities and residents benefit from assistance received from Limerick 

8 to start, maintain, expand parks, recreation, and quality of life opportunities.

9 Their corporate culture of giving back to the community is practiced by their hundreds of 

10 employees. Nonprofit organizations are supported by Limerick Generating Station and the 

11 efforts of their employees. Financial donations, as well as volunteer hours and time are 

12 donated, enabling our local nonprofits to provide the much needed services that impact those 

13 in need throughout the tri-county area. 

14 The Limerick Generating Station is confident in the clean and safe environment they maintain in 

15 our community. The community has been invited to experience the generating station firsthand. 

16 The chamber hosted a membership breakfast and the site vice president, Bill Maguire provided 

17 the keynote presentation. He summarized safety measures and advancements at Limerick and 

18 answered questions pertaining to the Limerick plant and its safety in the wake of the tsunami in 

19 Japan. 

20 Comment: 12-1-SR; I don’t believe that continued operations of the power plant would have 

21 any detrimental effect on public safety in the southeast region.

22 Comment: 13-1-SR; Today, I would like to say that in all of the years that I’ve lived in this area, 

23 I’ve never worried at all about the safety of the nuclear power plant. I see it every day. And it 

24 bothers me not in the least. I have never seen any credible evidence to suggest that there are 

25 safety problems with this plant. In terms of reliability, it is the same. It is running 24/7, 365 days 

26 a year and it has been doing so for a quarter of a century and I hope it continues to do so for 

27 many more years to come. 

28 As far as its environmental impact, I think it’s pretty widely known that nuclear power is one of 

29 the cleanest environmental energies that we possess today throughout the world and to dismiss 

30 it is I think a foolish notion. 

31 The impact of the Limerick plant in our region has been extraordinarily positive. It provides, as 

32 we all know and have heard today, lots of jobs, lots of good jobs, tax revenues for schools, local 

33 governments and for those who live in the area to enjoy the fruits of public services and it also 

34 provides a lot of charitable donations to the community which is very important.

35 I think that to not keep this plant running and not consider a renewal of its license for an 

36 extended period would be a tragic mistake for all of us and I would like to end this by saying that 

37 the only meltdown that would concern me is the economic one that certainly would happen to 

38 this area should this plant not continue to operate.

39 Comment: 14-1-SR; But I'm here today as a private citizen, as a resident of the area and as a 

40 member of the Pennsylvania Energy Alliance to go on record and say I strongly favor license 

41 renewal for the Limerick Generating Station. I say that because in my personal experience I 

42 know in spite of some of the things you’ve probably heard here today, nuclear power is safe, 

43 reliable, secure and clean. But in addition to that, I would like to go on record, I would like my 

44 neighbors to know we are lucky to have the Limerick Generating Station in this area. In the 

45 industry, it has a top reputation. It is one of the finest nuclear power plants in America. And 

46 Exelon, if not the best, is certainly one of the finest nuclear operators in the world. 
Appendix A

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1 I have nothing but confidence that Exelon will work together with the NRC, will run through the 

2 process and we will come up with the right conclusion here which is license renewal should be 

3 granted to the Limerick Generating Station. I think we need to keep Limerick operating as long 

4 as we can. 

5 Comment: 14-2-SR; And so from my perspective as a citizen, as a business person who 

6 worked in this community, I understand the value this is to the region. And for me, I applaud the 

7 NRC for what they’re doing here. I applaud Exelon for the great work that they’re doing there 

8 and I encourage the renewal process to take place. 

9 Comment: 17-1-SR; And my comments tonight are more I guess from my perspective as a 

10 newly elected official with the generating station. About a year ago I had the opportunity to go 

11 down to the generating station and meet with Joe Saffron and the first part of my meeting had to 

12 do with looking for some support for the Pottstown Soapbox Derby. Through some 

13 conversation while we were standing outside you know Joe [told] me a little bit on what Exelon 

14 and the generating station do for the surrounding communities, whether it’s supporting our 

15 firefighters, police departments and other civic organizations. You know, from a Pottstown 

16 perspective they help us with our yearly borough cleanup, our Salvation Army and now the 

17 Soapbox Derby. Thank you.

18 And we were standing outside that day, it was pretty nice out, and our conversation led to the 

19 power plant itself. We were standing there looking around it’s a pretty impressive sight. So I 

20 asked him about, you know, possibly having a tour for municipal officials. He said he would look 

21 into it and see what he could do. A couple of months later he got a group of about 20 of us and 

22 gave us a tour of the plant one evening. And I have to say that from the time we walked through 

23 the front gates and past the security as our tour progressed, you know, throughout the plant 

24 safety was paramount. Whether you were having explained what the different colors are on the 

25 different panels and what they mean to different fail safes, why you walk certain areas certain 

26 ways and what lines you had to stand behind, you know, safety was paramount with them. You 

27 know, from the environment, I'm looking around and this place is spotless. And I asked why 

28 and it's because they can’t afford to have dirt or lint or fuzz balls around because of static 

29 electricity because it could create issues. So from that aspect I thought it was a good tour and it 

30 made me feel good about the safety aspects there.

31 To finish our tour we ended up in the control room upstairs. And I’d say maybe a dozen or so 

32 individuals up there monitoring you know everything going on within the plant and around the 

33 plant. And again, explaining the failsafes and why they're double-, triple-checked to eliminate 

34 human error. It was just very impressive and as an elected official to go down and take a tour of 

35 the plant and understand how it operates. I know when I left I personally know how to issue a 

36 concern with the generating station. I know I felt a lot better and a lot safer going home that 

37 night. And it was also good to realize, you know, as one of our region’s largest employers now 

38 that they are willing to give back to the community and keep safety first. So thank you, I just 

39 wanted to make those comments.

40 Comment: 20-1-SR; I’m going to be making essentially five points in support of license 

41 renewal for Limerick Generating Stations and they are that, number one, nuclear energy lowers 

42 electricity prices, it protects our environment against greenhouse gases, it strengthens our local 

43 economies and it is safe.

44 With regard to my first point in lowering electricity prices the Limerick Generating Station has 

45 reduced wholesale energy costs in Pennsylvania by $880 million in 2010 thus lowering 

46 electricity prices for all consumers. It operates around the clock thereby stabilizing the nation's 

47 electricity distribution system and the electricity marketplace. The average electricity production 

48 costs at nuclear plants have actually declined more than 30 percent in the past 10 years due to 
Appendix A

A-38

1 various efficiencies. Nuclear power is cheaper to produce than other forms of electricity 

2 generation such as coal and natural gas, and helps moderate the price of electricity for 

3 consumers. 

4 My next point is that Limerick Generating Station and nuclear plants strengthen our local 

5 economies and it is a valuable economic driver for the Commonwealth of Pennsylvania. 

6 Limerick Generating Station contributes $113 million annually in direct economic contributions to 

7 the Pennsylvania economy through various employee wages and salaries, purchase of goods 

8 and services from other Pennsylvania businesses and in property tax payments to the local 

9 governments. Limerick Generating Station also contributes generously as we've also heard and 

10 in fact in 2010 contributed $600,000 to various community organizations. Limerick has over 

11 800 full-time employees and employs more than 1,000 skilled temporary contract employees 

12 during annual refueling outages. A significant percentage of the current nuclear plant workforce 

13 will reach retirement age in the next 10 years creating a demand for high-paying jobs in the 

14 nuclear industry. Yes, Limerick Generating Station is one of Pennsylvania's most valuable 

15 economic and energy assets and the commonwealth should embrace it. 

16 My third point is that nuclear energy protects our environment from greenhouse gases and 

17 reduces the need to generate electricity from fossil fuels. If Limerick Generating Station were 

18 retired from service replacing the electricity would require increased natural gas-fired or 

19 coal-fired generation. Nuclear energy is the nation’s largest source of carbon-free electricity 

20 and is critical to our nation's environmental, security and energy goals. 

21 My next point is that nuclear energy is safe. It's always on, it’s stable, it’s a reliable source of 

22 electricity and the station here at Limerick has been built with multiple redundant safety layers.

23 And the workforce is committed to best practices and continuous improvement. It is also 

24 important for our nation's quest to be energy-independent. According to the Bureau of Labor 

25 Statistics it’s safer to work at a nuclear plant than in industries such as manufacturing, real 

26 estate and finance. And according to the Department of Energy a person receives more 

27 radiation exposure flying from Baltimore to Los Angeles than by standing near a nuclear plant 

28 24 hours for a year.

29 On a personal note I've been inside Limerick Generating Station several times. I’ve also lived 

30 within 30 miles with my four boys and wife next to the Limerick Generating Station and also 

31 Three Mile Island. I feel safe, secure and comfortable. That is why I'm in support of the 

32 re-licensing of the Limerick Generating Station.

33 Comment: 50-1-SR; I wanted to let you know that I am complete and full supporter of the 

34 Limerick Nuclear plant. I am also supportive of the scientific [judgment] and expertise of those 

35 such as yourself who have the job of making the decisions. 

36 Response: These comments express support for nuclear power or the license renewal of LGS 

37 or both. The comments provide no new and significant information and will not be evaluated 

38 further. 

39 A.1.15. Surface Water (SW)

40 Comment: 1-17-SW; Dangerous depletion of the Schuylkill River, in and by itself, a singular 

41 reason to deny this permit. The Schuylkill is a vital drinking water source for nearly two million 

42 people from Pottstown to Philadelphia. It is being depleted and contaminated every day that this 

43 plant operates.

44 Comment: 1-23-SW; They are destroying the Schuylkill River. There was enough water in the 

45 Schuylkill River to sustain this nuclear plant from the very beginning and now we’re seeing the 
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A-39

1 consequences of that and they more and more pollution in it. They want to pump mine water in 

2 to supplement the flow for Limerick. It’s contaminated and they don’t filter it. And they’re 

3 actually asking for huge, four times Safe Drinking Water standard increase in total dissolved 

4 solids which carry a lot of toxic pollutants. So they put radiation into the river 24 hours a day, 

5 365 days a year, and now they’re asking for these huge increases and people have the nerve to 

6 get up here and say that they have no environmental impacts. 

7 Comment: 1-32 SW; Schuylkill River depletion and major drinking water contamination. Keep 

8 in this is vital drinking water source for nearly 2 million people from here to Philadelphia.

9 Comment: 4-5-SW; Our drinking and bathing water here is being continuously polluted by 

10 Limerick every day, 24/7 for years with radiation and unfiltered toxic contaminated mine water, 

11 thanks to the NRC and Exelon. This is disgusting. Most of us have to depend on the water,

12 especially for bathing. Some of us pay extra for water filtration or drink bottled water because 

13 we are afraid to drink from the Schuylkill and because it tastes really bad now. Imagine how 

14 toxic it would be 18 plus years from now if there was even any wate left.

15 Comment: 4-10-SW; So then there’s the cost for the pollution they’re putting in the river. 

16 They're asking for increases in pollution. They want to put more mine water in. They want to 

17 increase the total dissolved salts. That's going to cost water treatment systems a lot of money 

18 to try to—for extra treatment for that. It can even break down their equipment, some of the stuff 

19 that’s coming out of the mines. And when you think about it who actually ultimately pays that 

20 cost? We do. We pay for increased costs for our water because they're having to do that at the 

21 water treatment systems. And it seems to me that if you really take a good look at things 

22 Limerick has got to be the major cause for the radiation in Philadelphia's water.

23 Comment: 23-1-SW; Mine water issue, better defining that quality and flow particularly in light 

24 of the likely pending changes in stormwater concerns and regulations in the area. Adding that 

25 flow to the Schuylkill is going to affect all the municipalities around here who have to deal with 

26 stormwater.

27 Comment: 44-3-SW; There is concern that should be faced regarding the Schuylkill River and 

28 the affects it is going to have on the public if it becomes depleted, and/or toxic due to the 

29 contaminates going in it. 

30 Comment: 36-2-SW; I am more concerned about the effects of surrounding air and water 

31 supply and the future of my children and grandchildren, some of whom are already inflicted with 

32 cancer and other diseases. 

33 Comment: 45-9-SW; Limerick Nuclear Plant is slowly destroying the vital public drinking water 

34 source for almost two million people from Pottstown to Philadelphia. Radioactive and heated 

35 wastewater is discharged by Limerick Nuclear Plant into the Schuylkill River 24/7. Limerick’s 

36 cooling towers are causing significant depletion. To supplement the flow to operate Limerick, 

37 Exelon wants to pump more contaminated mine water into the river. No one can credibly 

38 assure if drinking water will remain safe even until 2029 when Limerick’s original license 

39 expires. 

40 Comment: 54-4-SW; Since the last impact statement was prepared in 1973, the Schuylkill 

41 River has been designated as a state scenic river and as a heritage area for both the state and 

42 federal government. Due to these designations and the efforts of non-profit organizations and 

43 local government, access to the river has been expanded so that the river has become a 

44 recreation and heritage tourism destination. Use of the river in the vicinity of the plant will 

45 continue to grow. With the return of American Shad made possible through down stream fish 

46 ladders, interest in the river could even grow further in the future.
Appendix A

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1 The Limerick Plant withdraws sizeable portions of river water. During low flow periods, 

2 additional quantities of water are released into the river from the Wadesville Mine, and Still 

3 Creek Reservoir in Schuylkill County to compensate for the water withdrawn at the plant. This 

4 process was initially approved by the Delaware River Basin Commission (DRBC), in 2003 and 

5 kept active through a series of docket amendments. Future river water use is, dependent upon 

6 the ability of this water make up system to operate within various water quality and flow 

7 parameters set by DRBC. It is important to evaluate the viability of the use of the river water 

8 and water make up system to provide needed water through the expanded plant lifetime. 

9 Analysis of this aspect of plant operation needs to account for the water quality impact from the 

10 total dissolved solids in the Wadesville water among other parameters. If resumed use of the 

11 Delaware water diversion is anticipated, an evaluation of that system is required to ensure that 

12 the capacity is available in the conveyance system and that water quality objectives can be met 

13 for discharge into the East Branch of the Perkiomen Creek.

14 Comment: 60-9-SW; Dirty polluted mine water

15 Response: These comments express concern in part over the health of the Schuylkill River, 

16 including river flow and water quality. Surface water resources at LGS, including the Schuylkill 

17 River, and the effects of plant operations on surface water hydrology and quality are presented 

18 in Sections 2.2.4 and 4.3 of the SEIS. In addition, Section 2.1.6 of the SEIS details the surface 

19 water sources relied upon by LGS and include the sources of water used to augment low flows 

20 in the Schuylkill River. Section 2.1.7 further describes the surface water and groundwater 

21 sources used to support plant operations, the volumes of water used, and the regulatory 

22 conditions and associated regulatory agencies that govern the plant’s water uses. With respect 

23 to the comments regarding depletion of the Schuylkill River, the NRC’s evaluation of LGS’s 

24 consumptive use of surface water is presented in Section 4.3.2.1 of the SEIS. As described in 

25 Section 2.1.7.1 and 4.3.2.1, the Delaware River Basin Commission (DRBC) has imposed 

26 consumptive use limits on LGS’s surface water withdrawals. During low river flows, the DRBC 

27 limits the plant’s consumptive withdrawals to no more than 12 percent of river flow to be 

28 protective of aquatic life and downstream water users. Under average flow conditions, 

29 consumptive water use by LGS amounts to about 3 percent of river flow. 

30 With respect to concerns about pollution attributable to operation of LGS, effluent discharges to 

31 the Schuylkill River through its discharge structure are regulated by, and subject to, water 

32 quality standards set by, the Pennsylvania Department of Environmental Protection (DEP), in 

33 conjunction with the DRBC docket issued to Exelon. More precisely, these discharges are 

34 regulated through the National Pollutant Discharge Elimination System (NPDES) permitting 

35 process as discussed in Section 2.2.4.1. Although the Schuylkill River has historically been 

36 affected by a range of activities as described in Section 2.2.4.1 and further in Section 4.11.3 

37 (Cumulative Impacts), the main stem of the Schuylkill River in the vicinity of the LGS currently 

38 meets designated water quality standards and uses, including use as a source for public water 

39 supply. 

40 As required by its operating license, Exelon Generation conducts a Radiological Environmental 

41 Monitoring Program (REMP) at LGS to assess the radiological impact, if any, to its employees, 

42 the public, and the environment around the plant site. The REMP measures the aquatic, 

43 terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. The 

44 NRC’s staff’s evaluation of the radiological impacts of LGS operation and its REMP are 

45 discussed in Section 4.8 of this SEIS. As part of its evaluation, the NRC staff reviewed Exelon’s 

46 annual radiological environmental operating reports for 2006–2010 to look for any significant 

47 impacts to the environment or any unusual trends in the data. A 5-year period provides a 

48 representative data set that covers a broad range of activities that occur at a nuclear power 

49 plant. Based on the review of the radiological environmental monitoring data, the staff found 
Appendix A

A-41

1 that there were no unusual and adverse trends, and there was no measurable impact to the 

2 offsite environment from LGS operations. Further, the NRC’s ongoing Inspection Program 

3 periodically inspects Exelon’s Radioactive Effluent Monitoring and REMP programs for 

4 compliance with the NRC’s radiation protection standards in 10 CFR. The NRC’s Inspection 

5 Program evaluates the data for compliance with radiation protection standards. If the data were 

6 to show a noncompliance with requirements, the NRC would take appropriate enforcement 

7 action. Additional information for LGS can be found at http://www.nrc.gov/reactors/operating/

8 ops-experience/tritium/plant-specific-reports/lim1-2.html. 

9 Comments 1-23-SW, 4-5-SW, 4-10-SW, 45-9-SW, 54-4-SW, and 60-9-SW specifically raise the 

10 issue of the diversion of water from the Wadesville Mine Pool to augment the flow of the 

11 Schuylkill River. The use of mine pool water and other diversion sources to augment surface 

12 water flows to support LGS operations are described in Sections 2.1.6 and 2.1.7 of the SEIS. 

13 These sections also summarize the background and current status surrounding the ongoing 

14 water diversion demonstration project that is regulated by the DRBC. The NRC staff’s 

15 evaluation of the projected impacts on surface water resources of the continued operations of 

16 LGS during the license renewal term are presented in Section 4.3 of this SEIS. Regarding use 

17 of the Wadesville Mine Pool and other low flow augmentation sources, the DRBC, and not the 

18 NRC, is responsible for regulating such activities. Likewise, and as mentioned above, the 

19 Pennsylvania DEP through the NPDES permitting process, along with DRBC’s docket approval 

20 process, are responsible for regulating effluent discharges from LGS and will ultimately decide if 

21 revised effluent limits on chemical and thermal discharges are appropriate.

22 Comment: 55-6-SW; A note should be added regarding the diversion of Delaware River water 

23 to the East Bank of the Perkiomen. Due to the residential build-up along the Perkiomen Creek 

24 area, additional consideration should be presented and discussed with the Army Corps of 

25 Engineers and the National Weather Service regarding potential flooding impact this may have 

26 on the area. 

27 Comment: 35-4-SW; Limerick Nuclear’s request for re-licensing is ludicrous, considering its 

28 aging and inadequate equipment, its increased air pollution by particular matter, its horrific 

29 destruction of the Schuylkill River and dangerous above-ground spent fuel rod storage.

30 Response: Aging management of plant systems is evaluated as part of the LRA safety review. 

31 The results of the staff’s safety review of the LRA for LGS will be documented in the staff’s SER.

32 Air pollutant emissions associated with LGS operations are presented in Section 2.2.2.1 of the 

33 SEIS. The NRC’s evaluation of LGS’s air emissions is presented in Section 4.2 of this SEIS. 

34 Surface water resources at LGS, including the Schuylkill River, and the effects of plant 

35 operations on surface water hydrology and quality are presented in Sections 2.2.4 and 4.3 of 

36 the SEIS. In addition, Section 2.1.6 of the SEIS details the surface water sources relied on by 

37 LGS and include the sources of water used to augment low flows in the Schuylkill River. 

38 Comment: 24-1-SW; ...I want to add that I want the NRC to look into potential water depletion 

39 issues from shale gas fracking upriver in both rivers.

40 Comment: 60-21-SW; Depleted water due to fracking up river

41 Response: The contributions of past, present, and reasonably foreseeable future actions or 

42 activities in the Delaware River Basin, including hydraulic fracturing (fracking), have been 

43 considered in the cumulative impacts analyses of this SEIS as presented in Section 4.11 of the 

44 SEIS. With respect to surface water, these impacts are presented in Section 4.11.3. In 

45 addition, the environmental impacts of alternatives to the proposed action (i.e., whether to grant 

46 a renewed operating license to LGS) are evaluated in depth in Chapter 8 of the SEIS. This 
Appendix A

A-42

1 includes comparative analysis of a natural gas-fired combined-cycle facility as a replacement 

2 power source for LGS and considers related effects of hydraulic fracturing to supply natural gas. 

3 A.2. References

4 10 CFR 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Rules of practice for 

5 domestic licensing proceedings and issuance of orders.”

6 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

7 production and utilization facilities.”

8 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental protection 

9 regulations for domestic licensing and related regulatory functions.”

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

11 of operating licenses for nuclear power plants.”

12 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

13 Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

14 License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 

15 Accession No. ML11179A104. 

16 National Environmental Policy Act of 1969. 42 U.S.C. 4321, et seq.

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

18 for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, DC, 

19 ADAMS Accession Nos. ML040690705 and ML040690738.

20 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 

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

22 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

23 Report,” NUREG-1437, Volume 1, Addendum 1, Washington, DC, ADAMS Accession 

24 No. ML040690720.

25 [NRC] U.S. Nuclear Regulatory Commission. 2011a. Official Transcript of Proceeding, “Limerick 

26 Generating Station License Renewal Public Meeting: Afternoon Session.” Adams Accession No

27 ML11287A207

28 [NRC] U.S. Nuclear Regulatory Commission. 2011b. Official Transcript of Proceeding, 

29 “Limerick Generating Station License Renewal Public Meeting: Afternoon Session.” Adams 

30 Accession No ML11287A211
A-43

1 Comment Letters and Meeting Transcripts

2 The following pages contain the comments, identified by commenter designation and comment 

3 number, from letters and public scoping meeting transcripts.
Appendix A

A-44

31 

1 unthinkable proportions . Whether a natural disaster 

2 p r terrorist a ttack occurs, by relicensing Limerick, 1-1-PA I 

3 NRc would in effect be placing Russian roulette with 

4 the lives of more than eight million people . NRC must 

5 close Limerick Nuclear Plant by 2029 0 

6 There is no way for either NRC or Exelon 

1-2-0S I 

7 t o ensure t he s afety o f the environment or the 

8 r esi dent s impacted b y thi s plant . It cannot be made 

9 fn i l snfe No o t.her fncc i l i t v hns t he notent i nl t o 

1 0 render t he ent ire region uninhabi table , p o ssibly for 

1-3-0S I 

11 cent uri es as the result of an a c cident or t errorist 

1 2 att ack . Thi s i s t he highest- risk f acility that could 

13 exi st i n any commu n ity i n t h i s country. 

1 4 Current 40- year operating licenses expire 

15 n 202 4 and 2029 0 Why the rush t o renew these 1-4-LR I 

1 6 i censes now? 

1 7 we urge the NKC to say no to t;xe l on s 

1 8 requested license renewals . The public was led t l 1-5-0R I 

19 li eve t hat Limerick ' s generators, fuel pools, and 

20 f'niles of underground pipes and cabl es could 

11-6-LR 

operate 

I 

21 safely for 40 years and then the f acility woul d close . 

22 Is Exelon fearful that the longer they wait the more 

23 serious problems may arise ? 

24 After only 26 of 4 0 years, numerous signs 1-7-0S I 

25 of aging and risk have b een iden tified . Corrosion, 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., NW. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-45

32 

1 !deterioration, tatigue , cracKing , thinning wi tn loss 

2 o f materia l , loss of fracture toughness are all 1-7-0S I 

Cont'd 

3 documented i n Exelon ' s own ren ewal application in the 

4 agi ng management section . I nst a nces of equipment 

5 fatigue and cracking o f vital equipment include the 

6 reactor vessel and coolant system. 

7 Aging equipment , aft er only 26 years 

8 suggest s that NRC should no t just close the plant by 1-8-0S I 

9 2029 , but also ramp up their oversight vigilance 

1 0 duri ng the rema i n i ng 1 8 y ears o f the current l i cense . 

11 In the past few years, Li merick has h ad numerous 

1 2 nplanned shutdowns suggesti ng t here are already 

13 ignifi cant probl ems . Th ree occurred i n one week i n 

1 4 u ne 2011. Loss o f coolant leaks and acci dents a t 

1-9-0S I 

15 imerick have already been documented . Serious 

1 6 adi oactive contaminati on cou l d go u ndetected and 

1 7 nreported for years from the corroding 

1 8 nfrastru ctu re, mu ch of it underground . 

19 There have already been two n ear misses at 

20 Limerick from 1996 to 2001 . 

21 This aging p l ant is an acci dent waiti ng to 

2 2 happen . Large v o lumes , more than 6 , 000 assemblies rL-..1....::--:=-:-:-:, 

1-10-RW I 

23 weighing more than a thousand tons of highly 

2 4 radioactive waste in the form of spent fue l rods are 

25 stored in d e nsel y - packed pools, elevated five stories 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-46

33 1 

1 above a nd out side the reinforced cont a i nment 1-10-RW I 

Cont'd 

2 

3 

tructure . This p lant 

ons o f dangerous spent 

wi ll produce about two more I 

,...,.......,....,-::::;-:.,..., 

fuel r ods every year tha t it 1-11 -RWI 

4 perat es . LlmerlcK, ln addltlon , lS now thlrd on the 1 I 

5 earthquake r isk list f o r nuclear p lants in the 

6 Stat es . 

7 Wi t h loss o f cooling wa t er, Limeri ck ' s 

8 fuel rods could heat up , sel f ignit e , and burn in an 

9 unstoppable fire with cata strophic r esults. Exelon 

1 0 has not been requ i red to spend t he money t o g uard 1-1 3-PA I 

11 Limerick a g ainst terrorists, missiles, or air strikes 

1 2 despite repeat ed requests t o d o so . 

13 Dry cask storage a nd transpor t are als'f:-J'-:-!-=:-:-:-:o o

p - 14-RW I 

1 4 e ry d angerous a lternat ives. It ' s time to close 

1 5 imerick and stop produci ng s uch deadly wa ste for 

16 hi ch there is no safe s o l u t i on . As long as Lime r i ck 

1 7 perates har ms to us and our environme nt will 

1 8 nc rease . 

19 Their harmf ul e nvi ronmental impacts are 

20 unprecedented . At the conc lusion o f our 11- year 

21 investi ga tion of rou t i ne radiation releases and review 

22 o f permits for ma j or air pollut i o n and a va riety of 

23 dangerous water contamination issu es, it ' s clear t hat 

24 thi s ene rgy is not j ust dirty, it is i n fact filthy. 

25 Evidence that we ' ve c o mp iled has address e d a wide 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-47

34 

1 r ange o f topics : r outine radiati o n r e l eases into the 

2 a i r , radioa c t ive wastewater discharges into t he 

3 Schuylki ll Rive r , radioactive groundwater 

4 c ontaminatio n , radioact i v e n uclides associat ed with 

5 the plant detect ed in our soil, o ur sediment , our 

6 v egetation , our f ish , our wat er, and milk . 

7 Res e arch has c o nfirmed radiation i n our 1-15-HH 

8 

9 

1 0 lean Air Act , 32 i ndividual s our ces listed . Drastic, 

11 armful i ncreases p ermitted i n par t i culate matter 

1 2 nown a l so as PM- 1 0 from t h e cooli ng t owers , ot h er air 

13 o lluti on i ncreases a l s o pe rmitted . 

14 Dangero us depletio n of t h e Schuylkill 

15 singular rea s on to deny/+--:-::!-:::~--, 

p -17-SW I 

Rive r , i n a nd by i tself, a 

16 this permit . The Schuyl kill is a v i tal drinking wat er 

1 7 s ource for nearly two mi l lio n people from Pottstown t o 

1 8 Philadelphia . I t is be ing depleted a nd contami nated 

19 eve ry day t hat this p lant operates. 

20 Alarmi ng can cer increases that h ave been 

21 wel l d ocume nted in this community r epeatedl y far j1 -18-HH I 

22 h i gher than na t ional and state a v e rages a fter Lime r ick 

23 started o p e r a t i ng until the l ate 1990s . The 

24 f i ndings of o u r inv estigati o n l ead us to conclude that 

25 this p lant is i n common lang uage a r ecipe for 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

I 
Appendix A

A-48

35 

1 disaster. 

2 While NRC is required t o prepare a 

3 supplement to t he Limerick Environment al I mpact 

1-1 9-LR I 

4 Statement f or lice ns e ren ewal , we have lit tle 

5 confidence in the process b ased o n NRC ' s regulatory 

6 h i s t ory. It would b e d ifficult t o enumerat e a s hort 

7 list, s o I ' m goi ng t o r e l y o n writt e n docume nts . 

8 There are crit ics o f t he NRC out t here who h ave d o n e a 

9 much better job t han we have of g e n e r ating such a 

1 0 l i st, mo st notabl y a s cathing i ndi c tment by t he 

11 Associat ed Press. I ' m n o t going to re- enumerate that 

1 2 info r matio n . 

1 3 It ' s long past t ime for the NRC to summon r.-7:::-::::::-=, 

1-20-0R I 

1 4 t he courage t o d o the right t h i ng in o u r judgment and 

1 5 actually prot ect the environment and the publi c , 

16 rat h er t han t he i ndus try . 

1 7 Today, I am going to be submitting on the 

1 8 record summary packets of ou r research on Limerick ' s 

19 maj or air poll ution , harms to the Schuylkill River, 

20 radioacti ve grou ndwater contamination , links between 

21 Limeri c k ' s r ad iation and o ur e l evated cancers i n thi s 

22 community and how Limerick ' s nuclear p ower can , in 

23 fact , b e replaced with safer sources tod ay . 

24 

25 

Based on the compelling body o f evidence 

o f environment al h a rms t o date and 

(202) 234-4433 

N~LK.uKU~~ 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

t he enormous 

WW'W.nealrgross.com 

1-21-0R I 
Appendix A

A-49

1 i ncreased p opulat ion i n proximity to this facility, 

2 Limerick Nuclear Plant must be closed by 2029 . 

3 There is no amount of energy production that is 

4 worth risking the l ives of so many people . Thank you 

5 very much . 

6 (Applause . ) 

7 FACILITATOR BARKLEY : Thank you , sir. 

8 MR . MAGUIRE : Good afternoon . My name is 

9 Bil l Magui re and I am the site vice president a t 

1 0 Limerick Generati ng St ation . And I h ave overal l 

11 responsibility for the safe and r e l iable operation of 

1 2 t he facil i ty. 

13 I have been worki ng i n t he nuc l ear power 

1 4 industry f o r 25 years and my career began at t he 

15 Limerick Generating Stati on as an engineer . I 

16 continued with a l icense to be a licensed senior 

1 7 reactor operator supervisor in the operations 

1 8 o rganizati o n and was the on- shift senior manager of 

19 tha t facility f or many years . 

20 I have also worked at a few other nuclear 

21 stations across the cou ntry and before rejoining 

22 Limerick as t h e site vice president in May of 2010 , I 

23 was t h e site vice president at the Peach Bottom Atomic 

24 Power Station i n southeastern Pennsylva nia in York 

25 County . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

I 

1-21-0R I 

Cont'd 
Appendix A

A-50

37 

1 Operat ing Limerick Generating Stati on 

2 safely and r e l iably is a respon sibility t hat everyone 

3 at t he power station t akes very seriously. We 

4 u nderst a nd o u r obligation to the communi ty, to t he 

5 e nvironment , and to each oth er to operate t h e plant 

6 safely. 

7 A key component o f a thriving communi ty 

8 l ike o urs is the ava ila b i l ity o f s afe , clean , and 

9 reliab l e electricity. And a s we l ook i nt o t he f uture 

1 0 for the powe r needs o f Pennsylvania a nd t he United 

11 States as a whol e , we can see the increasi ng demand 

1 2 for this v ery important resour ce . 

1 3 At t he same t i me , t here ' s a growi ng 

1 4 concern about greenhouse gases and climate change that 

1 5 i s a resul t o f burn ing fossil f ue ls. To help meet 

1 6 t hat growi ng p ower demand a nd to he l p keep our 

1 7 env i ronment c l ean , Exelon has applied to the U. S . 

1 8 Nuc lear Regu latory Commission for a 20- year extension 

19 t o the p l ant ' s op erating l icense . Limerick ' s cur rent 

20 l i cense fo r Unit 1 will expire in 202 4 and Uni t 2 in 

21 2029 0 Wi th l icens e renewal , Li me r ick can provide our 

22 region wi th clean power through 20 49 . 

23 We understand our special obligation to 

24 operate the plant safel y and reliably and to ma i ntain 

25 a c l ose relationship with o ur neighbors . We p ledge t o 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

12-1-SR I 
Appendix A

A-51

38 

1 ontinue that special trust as we operate the plant 

2 ell into the future . 

3 The 104 nuclear reactors in the United 

4 States provide roughly 20 percent o f our nation ' s 

5 electricity . More than 7 0 react ors nationwide have 

6 already received approva l from t he Nuclear Regulatory 

7 Commission for a 20 - year license extension including 

8 the Peach Bottom Atomic Power St ation in York Count y . 

9 Limerick Generating St ation ope r ates in a 

1 0 manner t hat preserves the environment . The plan t 

11 produces almost no g r eenhouse gases . The plant 

1 2 conduct s approximately 1 700 t ests annually on air, 

13 wa t er, fish , soil , cow ' s mi lk, and other food products 

14 t o measure for environmental impact . We also ma i ntai n 

15 a chai n of radiation monitors surrounding the plant . 

16 In 2005 , t h e environmental management 

1 7 systems at Limerick Generating Station achieved 

1 8 certification under the strict criterion of the 

19 International Organization for Standardization, ISO . 

20 This certification is known as ISO 14001 , a common 

21 industry r eference f o r the envi ronmental 

2 2 certification. The ISO 1 4001 certification requires a 

23 commitmen t t o excellence to prevent pollution and to 

24 ensure continuous improvement in environmental areas . 

25 

(202) 234-4433 

In 2010, the Wildlif e Habitat Council 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

I 

2-1-sRI 

Cont'd 
Appendix A

A-52

39 

1 recogni zed Limeric k Generating Station ' s commitment t o 

2 e nvironmental stewardshi p by awarding us the Wildlife 

3 at Work Certifi cation . This distinction was awarded 

4 t o Limerick Generating St ati o n for our commitment 

5 t owards establishing long- term wildlife habit a t 

6 e n hancement s that provided undist urbed habita t s wit h 

7 food , water , cov er, and space f or anima l speci es 

8 l i v i ng on the p l ant station ' s l a ndscape . 

9 To ensure Lime r i ck c onti nues t o ope r ate 

1 0 safely f o r years t o come , Exelon is invest ing i n 

11 upgrades t o p lant equipment . Since 201 0 , Exelon has 

1 2 invest ed more t han $200 million i nto t he plan t 

1 3 incl udi ng instal lati on o f new sa f ety equipment, new 

1 4 electri ca l cabl es, new va l ves, and re furbishing t he 

1 5 cool ing towers . In additi o n , Limerick has made more 

1 6 t han $40 million i n physical security upgrades since 

1 7 2001. 

1 8 Our investment i n the fut ure does not stop 

19 with equipment . We hav e hired and t rai ned over 100 

20 new employees over the last three years, mostly coming 

21 f r om ou r native regi on here . We maintai n a steady 

22 workforce of appr oximately 850 peopl e and during our 

23 annual maintenance and refueling outages, we bring in 

24 b etween 1500 and 2000 temporary workers that provide a 

25 b oost to our local economy. Hiring 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

and 

WW'W.nealrgross.com 
Appendix A

A-53

40 

1 retaini ng top talent is a key priority for Limeri ck 

2 Generat i ng St ation . 

3 Over t he past 25 years, Limerick has been 

4 o ne o f the best performing a nd most r e liable 

5 generat i ng stations in the nuclear power industry. 

6 Du r i ng tha t t ime , t he p lant has set several records 

7 for con t inuous days o f operation and has been 

8 r ecogni zed b y the i ndustry for our reliable operation . 

9 In March 2010 , Lime r i ck completed a successful r un of 

1 0 727 co nt i n uou s days f or o ur Unit 1 plant . This 

11 r epresented the s econd l o ngest conti nuo u s run fo r a 

1 2 boi ling wate r reactor i n the Uni t e d States . 

13 Whi l e we do not set out t o break re cords, 

1 4 continuous operations are o n indicator of t he 

1 5 excellent human performa nce and equipmen t reliability 

16 t hat Limeri ck strikes f o r every day . 

1 7 We also take pride in our investments i n 

1 8 the community. In 201 0 , Limerick donated more than 

19 $600 , 000 to the community in contrib u tions to t he 

20 United Way , fire and ambulance compani es, educational 

21 health and youth organi zations. And many o f our 

22 employees serve as vol un teers in the loca l c ommunities 

23 around t h e plant . 

24 In conclusion, Limerick Generating Station 

25 looks forward to working with the Nuclear Regul atory 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-54

41 

1 Commission as you r evi ew our license r e n ewa l . I 

2 appreciate the opportunit y t o speak with you this 

3 a ft ernoon . Tha nk you . 

4 FACILITATOR BARKLEY : Thanks, Bill . 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Represent ative 

7 Qui gley. 

8 RE P . QUIGLEY : Good afternoon , my name is 

9 State Rep resentative Tom Quigley. I represent t he 

1 0 146t h Dist rict here o f wh ich lower Pot tsville is a 

11 part y of t ha t district , s o I want t o we l come t he NRC 

1 2 here t oday t o t h e b eaut iful Sunnybroo k Ba l l room f or 

13 t hi s meeting and t h ank t h em for comi ng o ut to lis t en 

1 4 t o the p u blic and take c omme nta r y . 

15 I 'm h ere today t o voice my stro ng support 

1 6 for the re l i censing o f the Limeri ck Generati ng 

1 7 Station . I want ed t o touch o n a coupl e p o i n ts o f why 

1 8 I feel it is i mportant for this f acility to be 

19 r e licensed . 

20 First is the amount of electricity that is 

21 produced b y thi s faci lity. One o f the thi ngs that 

2 2 myself and my colleagu es in Harrisburg hear 

23 consisten tly from businesses a nd the Commonwealth and 

24 o u r cit i z e ns is the d e mand for ener g y a nd e l ectricity 

25 now and more impo rtan t l y wh a t that dema nd i s going t o 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

3-1-SR I 
Appendix A

A-55

42 

1 b e in the future . 

2 Right now this facil ity generates e nough 

3 electricity for two millions homes a nd without 

4 producing some o f the greenhouse gases t hat we hear so 3-1-SR 

5 much a b o ut t hat coul d be produced by coal , n a tural 

6 gas, o r o il. And I ' m goi ng t o put a caveat in there 

7 for my good f riends out in t he west ern part o f the 

8 s tat e where coa l i s a b ig part o f t h e Pennsylvania 

9 economy a nd I ' m suggesti ng t h at t his be d one t o t h e 

1 0 exclusion o f coal a nd n evertheless, s ome of t he 

11 t echnol ogies t hat t hey ' r e developing o ut t here are 

1 2 also i mp o rtant f or that industry and important for t he 

13 Commonwealth o f Pennsylv a n i a . 

1 4 Aga in, o ne o f the c o ncern s we hear 

1 5 c onsistently f rom business e s is how can we come here 

16 into Pennsylva n i a wi t h t h e infrastructure being wh at 

1 7 it is whi ch needs to be improved for the tran s mi ssi on 

1 8 o f the e l ectricity, but more impo r t antly the 

19 generation o f t h at e lectricity? 

20 Number two , I think is important i s the 

21 j ob s and overall economy . Again , in t h e se tough 

22 economic t ime s t hat we ' re f a c i ng here i n t he 

23 Commonwealth of Pe nns y lvania and a l so i n t his n ati on, 

24 one of the top issues that we hear c o n sistently about 

25 i s jobs. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

Cont'd 
Appendix A

A-56

43 

1 And as was me ntioned by the site v i ce 

2 resident , ove r 8 60 p eople are e mployed h ere with an 

3 n nual p ayroll o f $7 5 million. The direct impact that 

4 s t o the Commonwealth o f Pennsylvania , of cou r se , i s 

5 ea l ized through the state i ncome t ax and als o all of 

6 h ese l ocal municipalit ies most o f them e nact an 

7 

8 

arned i n come t ax which aga i n sustains t he i r own shi ps r.3~- 1-S~R~-.~ 

Cont'd 

swell as t h eir respect ive school distri cts. To ave ~~----~ 

9 hat taken away I think woul d ha ve an e v en more 

1 0 ramat i c i mpact on our l o c al e c onomy . 

11 As was mentio ned t h e i mpa ct f o r t h e l oca l 

1 2 rea here , t he tempora r y worke rs who s how up h ere 

1 3 u r i ng t he o u t ages a nd t h e r efueli ng , there ' s a lready 

1 4 ee n t wo h o tels t hat have sprung up a l ong t he 422 

1 5 orr idor with ano t h e r one planned right up here a t t h e 

16 ana toga area . Aga i n , more j obs a nd more economi c 

1 7 rowth here for o u r communities . 

1 8 Thirdly, I want to talk a b o ut the 

19 ommuni ca tion tha t I ' v e exp erienced in the seven years 

20 h at I ' v e b een in office with Exelon and with their 

2 1 ove r nment Af f a i r s peopl e as we l l as with their s ite 

22 

23 

24 

25 

eople . I ' ve b een on the site three times, twice for 

tou r a nd one to make a p resentation during an 

nniversary o f the faci l ity. And I have to say that 

t is a very secur e area . I know a l ot of p eople are 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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44 

1 concerned about terrorism attacks or peopl e b e i ng on 

2 the property. But u nl ess y o u ' ve actua lly gone over 

3 the r e a nd gone through a t o ur, seeing how things are 

4 set up , seeing t he a rme d guards there , seeing t he 

5 securit y meas u res tha t are i n place , I think you come 

6 away much more relieved with t ha t . And I ' m abl e t o 

7 speak t o my co nstituents more affirmati vely about the 

8 

9 

safety and s ecurity o f t he fac i l ity. 13-1-SR I 

ICont'd 

Any t i me that t h e r e ' s been t he s l ightest 

1 0 occurrence t he re , whet h e r it wi l l be a c o upl e times a 

11 h u n ter has wandered o nto t he pro perty where t h e 

1 2 authori t ies were called , t h e Gove rnment Affa i rs people 

13 at Ex e lon are o n t h e pho ne t o me or wit h an ema i l 

1 4 r i ght away t o let me know what ' s happening be f o re t he 

1 5 word gets out t o the media o r t o the press. So 

16 they ' re always very well prepared in the i r 

1 7 explanations , not only of t hings tha t happen a t t h e 

1 8 plant itse l f , but also i ncidents and issues that occur 

19 a r ound t h e country and around the world . 

20 Obviously, what took p l ace in Japan with 

21 the i nci dent over there, they we r e on t h e p hone with 

22 me and met with me a few times to explain what took 

23 place over there and how t he safeguards are being put 

24 in place he r e so t h at d oesn ' t happen a t this faci lity. 

25 

(202) 234-4433 

I t was ment i oned earl ier t he dry cask 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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45 

1 storage wh ere t he s p ent fuel r ods are now stored 

2 o utsi de in a d r y cask storage faci lity . When that was 

3 proposed back i n 2005 - 2006 , the Generating Station 

4 h e ld t wo open houses that were very well a tte nded . I 

5 went to b o t h of them where t hey h ad peopl e on there t o 

6 expl a i n to t he peopl e wha t exa ctly was taking place 

7 wit h thi s d r y cask storage , why it was neces sary. A 

8 lot o f questio ns a nd a nswers ba c k and f ort h and I 

9 t hi nk a lot of the p e opl e came away better inf ormed 

1 0 about t ha t process . 

11 Just recently at a n open house, t he sit e 

1 2 VP who just spoke , Bi ll Maguire , came o ut t o give some 

13 ini tial comment s and wound up spendin g t he full ho ur 

1 4 in an impromptu qu estion and answer sessio n and not 

1 5 again j u s t planted q u estions , a l ot o f tough 

1 6 q uestions . And I t h ink aga in the people came away 

1 7 fee l ing confident in t he openness and the transparency 

1 8 that was displ ayed in that question and answer 

19 session . 

20 Another point of that is for relicensing 

21 for t he overa ll envi ronment here i s the good corpo rate 

22 c i tizenship that the Ge n erating Station has exhibited. 

23 As was mentioned by Bill, some o f t he charitable 

24 contrib uti ons that have gone on , not only for the host 

25 community of Limerick , b ut also f or t he surrounding 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-59

46 

1 areas. I attended a f ew dedication services wh ere 

2 t hey p rovided mo n e y t o the Upper Pr ovidence El eme ntary 

3 School a nd t h e Li merick El ement a ry School for a n 

4 o utside environmental c l assroo m. 

5 One o f t h e t h i ngs we tal k about as 

6 p o litical l eaders, and I ' m on the House Educati o n 

7 Committ ee , is the need f o r our children to be educat e d 

8 part icularl y in the s c i ences and g i ven t hese b udget 

9 c onstrai nts t hat we ' r e o p erati ng unde r , bot h t he 

1 0 schoo l d i stri c t s and the Commonwe a l t h , it ' s good t o 

11 see a corpo ra t e c itizen steppi ng up t o the plate and 

1 2 providi ng t hat f i na nci a l s upport, pa r t i c u l arl y i n t he 

13 area of s c ience . They ' ve a l so partnere d wit h t he 

1 4 Montgomery Co u nty Commu nity Co l lege t o prov i de 

1 5 assistance in s u pport for an assoc i ate degree i n 

1 6 n u c lear engineeri ng technol ogy . 

1 7 Again, we hear s o mu c h a bout our students 

1 8 here not b e i ng well versed i n technology and 

19 e ngi neeri ng a nd things of that n a t u re . So again, 

20 s tepping u p t o the plate to provid e that assi stance 

2 1 when , i n f act, per h a ps i n these t ough budget t i mes 

2 2 wh ere the governmen t might not be able to do that . 

23 Last, I want to talk abou t overall public 

24 opi nion and sa f ety issues. One o f the thi ngs t h a t I 

25 looked a t when I tal k about saf e t y and the f eeling of 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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47 

1 comfort that p eople have here is how many of the 

2 people who work at that plant live within the t en- mile 

3 radius of the f acility? And I asked that question 

4 when I first was elected in 2004 and I just asked it 

5 again in preparation f or this hearing and 563 

6 empl oyees l ive wi t hin the t en- mi le r adius. 

7 The population g r owth in my District in 

8 t he past ten yea rs, we ' re getti ng ready to r edraw our 

9 lines based on the 201 0 Census, s o I broke i t d own by 

1 0 t ownship as to how much the population has i ncreased 

11 in t hos e areas: Limeri ck Township, i ncreasing by 33 . 5 

1 2 percent; Upper Pottsgrove b y 29 . 5 ; Royersford Borough, 

13 whe re I liv e , 11 . 9; Lower Pottsgrove , 7 ; Pottstown , 2 ; 

1 4 now this is a l ittle bit skewed, but I have a small 

1 5 piece of New Hanover Townshi p which actua l ly i ncreased 

16 by 54 percent . 

1 7 When you l ook at t he p u b l ic opini on, and 

1 8 again , we get calls on a lot of d ifferent i ssues and 

19 as I mentioned t hat dry cask sto rage issue . Back 

20 then , at the same t ime that that issue was being 

21 r o l l ed out to the publi c , Boyd Gaming had purchased a 

22 proper ty next to our plant was getting ready to apply 

23 -- had applied for a lice nse , casino license . At that 

24 t i me , my office had received 2 calls in regard to the 

25 dry cask storage project , over 200 calls regarding the 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 casino applicatio n . So at the time , i t appeared 

2 p eople were more concerned a b out the p r osp ect o f a 

3 casino b eing i n the ir ne ighborhood t han t h ey were a 

4 dry cask s t orage fa cility. 

5 And lastly, as some o f you h ea rd , there is 

6 a propo sal right now t o put a hold on Rout e 422 . And 

7 again , i n t he past six months wi t h t h e incidents in 

8 Japan , with the c urrent earthquak e we had here , with 

9 t he AP s t o ry t ell ing you how these plan t s are all 

1 0 fa l ling apart, I recei ved t wo calls regarding t hat one 

1 1 where they could get t he KI pill s , o ne where they 

1 2 c oul d -- what wa s the evacua t ion plan for t hat , and 

13 more calls and e mail s regarding the proposed 422 . So 

1 4 aga i n , i t appears t hat t he c onst ituents and t he 1 46t h , 

15 they ' re more conce rned about the prospect o f paying a 

1 6 t o l l t o ride of 422 t han t hey are about the nuclear 

1 7 p ower p lant i ssu es . 

1 8 So again , I strongly support the 

19 r e l icensi ng of thi s f o r the reasons I mentioned . 

20 Thank you . 

21 (App l ause . ) 

22 FACILITATOR BARKLEY : Thank you, 

23 Representative Quigl e y . 

24 The ne x t t hree people I ' d like to call, 

25 first is Lorraine Ruppe , private citizen; and t he 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 next , Michael Gallagher of Exelon; and finally, I ' d 

2 l ike to call Dr . Fr ed Wi nter after that . 

3 MS . RU E'E'E : Hi , my n ame is Lorraine Ruppe . 

4 I a m speaki ng h ere t oday t o represent t h e children 

5 a nd fut ure generations, especially in our communit y . 

6 Resi dent s are f earfu l a b out t he p ossibil ity o f 

7 disast ers here i n light o f Fukushima in March 201 1 and 

8 s i nce the ea r thquake and Hurri cane Irene in August 

9 2011 affecting our a rea . Climate changes, e t c etera , 

1 0 are causing disasters everywhere and continuing t o get 

11 wors e . 

1 2 Increasing f l oods, d r ought s , e art hqua kes, 

13 t ornado s h a ve made us a l l f eel i n secure , maki ng 4-1 -PA I 

1 4 n u c lear power i ncreas i ngly risky, especi all y with t he 

1 5 Lime rick p lant basi cally in our b ackyards . Any 

1 6 earthquake tha t comes through t h is area cou ld be a 

1 7 p ossibl e Fukushima , Chernobyl o r Three Mil e I s land 

1 8 whi ch remi nds me , four months h ave p assed since the r.--=--=-:~ 

4-2-GE I 

19 NRC f ailed t o get back to me when I asked how c l ose 

20 the Remapo f ault l ine i s to the Li me ric k nucl ear 

21 reactors ? Maybe I can get an answer today . 

22 Ind ian E'oint nuke plant was sketched as a 

23 p ossibl e terrorist target in reference to 9/11 

24 attacks . A s uspected t errorist worked at Limeri ck for 

25 y ea r s without t h e i nd ust r y knowing it. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

How s c ary is 

WW'W.nealrgross.com 

4-3-os 1 
Appendix A

A-63

50 

1 that? 

2 The Pacific Ocean is now severely 4-4-0S I 

3 i rradiated by Fukushima . Ra d iation i mpacts of 

4 Fukushima equa lled over 20 Hiroshima b ombs whe n I last 

5 esearched . Our drinking and b a t hing water here is 

6 e i ng continuously pollut ed by Lime ri c k every day, 

7 4/7 f o r years with radiation and unfilt ered t oxic 

8 ontamina t ed mine water, thanks to the NRC and Exelon . 4-5-SW 1 

9 This is disgusting . 

1 0 Most of u s have to depend on t he wa ter, 

11 special ly for bathi ng . Some o f u s pay ext ra f o r 

1 2 ater filtrati on o r drink b o ttled water because we are 

13 f r aid to drink f r om the Schuylk ill a nd because it 

14 astes r eal ly bad now . Imagi n e how toxic it would be 

15 8 plus years f r om n ow if there was even any water 

16 eft . 

1 7 There has bee n increased particulate 

1 8 matter i n the air a nd other t oxics from Lime ic ...,_~.,...,..,......., 

4-6-HH I 

19 causing increased ast hma , heart a ttacks, and stro kes . 

20 And to add i nsult to i njury , Lime rick was granted a 

21 p ermit to allow an e i ght - fo l d increase in air 

2 2 p o llution since 2009 . Cancer rates i n our area have 

23 skyrocketed s ince Limerick has b een up and running in 

24 t h e ' 80s and rates have s t eadily increased . 

25 I 

(202) 234-4433 

The Tooth fa i ry Pro ject showe d hig h l evels 114-7-HH I 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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51 

1 o r strontium :!U , a radionuclide in baby teetn or 

2 children nearest to nuke plants. Baby teet h n ear 

3 Limerick p lant had the highest levels i n the whole 

4 United States. This stuff and God knows what else is 

5 i n our bodies now t hanks t o a Nuclear Regulatory 

6 Commission t hat t o put it nicely is less than 

7 e nthusi astic about p r otecting us. 

8 Solar wi nd , geothermal , ocea n t hermal , 

9 nergy conservati o n and efficien cy are now cheaper 

1 0 ha n nuclear power, a lon g with being trul y clean and 

11 afe . The Department of Energy 2006 report stated 

1 2 o l ar a lone c ould provide 55 t i mes o ur entire na tion ' s 

13 nergy needs which leads me to a point, there have 

1 4 ee n numero us studies proving the many da ngero us and 

15 eadly consequences of n u c lear power . There ' s n o 

16 denying the mass i ve devastation it has already cau sed 

1 7 and wi l l conti nue t o cau se i ndefinitely, but the 

1 8 i ndustry still goes on in their trance- like, 

19 indifferent f ashion as if everything is safe and 

20 wonderful and wi l l continue to b e 18 plus years from 

21 now o r u ntil 2049 for o u r communi ty. Th is i s what 

22 really scares us t h e most . 

23 The NRC has turned into a culture of 

24 secrecy, h iding the dangers a nd sweeping the p robl ems 

25 under the rug . 

(202) 234-4433 

The i ndustry ' s addiction to mo ney and 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

4-7-HH I 

Cont'd 

~-:--~:,.......,....,...., 

4-8-AL I 
Appendix A

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52 

1 p ower has blinded them to moral life and death issues 

2 a nd facts set right in front of t heir faces . Bu t my.-1:--='-::-=---, 

14-9-LR I 

3 ig question of t he day is why is Exelon applyi ng for 

4 a n extensi o n 18 years ahead o f t ime? Thank you . 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Thank you , Lorraine . 

7 Mi ke ? 

8 MR . GALLAGHER: Good a f ternoon . My name 

9 is Mike Gallagher a nd I ' m t he Vice President of 

1 0 License Renewal for Exelon . I have ove ral l 

11 responsibility for t he Limeri ck Generat i ng Stat i on 

1 2 l i cense renewal a pplicati on . 

13 Ex e lon has a great dea l o f experience wi t h 

1 4 l i c e ns e renewa l , as we have a l read y obtained t he 

1 5 renewed licenses for our Peach Bottom and our TMI 

1 6 plants in Pennsyl vania , o u r Oyster Cree k plant i n New 

1 7 J ersey, and o ur Dresden and Quad Cities p l ants i n 

1 8 Illinois. 

19 Just briefly a bo ut mysel f . I ' ve been 

20 working in the nu c l ear power industry for 30 years . I 

21 was a licensed senior operator and p l a n t manager a t 

22 Li merick and I worked a t two other nuclear plants and 

23 o ur corporate offices . 

24 Mr . Maguire , the site vice president for 

25 Limerick spoke about reasons for renewi ng the license 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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53 

1 for Limerick . I ' d like to speak briefly about the 

2 process f or preparing this l icens e renewal application 

3 a nd t he amoun t of work and engineeri ng a n alysis that 

4 was put i nto preparing the applica t ion . 

5 Because the license Generat i ng Station can 

6 pe operat ed sa f ely a nd reliably, Exelon decid ed t o 

7 purs ue license renewal fo r Limerick . Lime rick is a 

8 very c l ean e nergy source which produces no greenhouse 

9 pas emissio ns . Limer i ck is a lso good f o r the eco nomy 

1 0 n t hat i t l owers market pri ces on elect r icity for t he 

11 pi ti zens of Pe nnsylvania to t he tune o f $880 mill i on 

1 2 per year. 

13 So i n 2009 , we annou nced o ur i nte nti on t o 

1 4 seek l icense renewal for Limerick . Later t ha t year, 

1 5 we star t e d t h e work necessary to p repa re t he 

1 6 application . Af ter over two years of work, we 

1 7 submitted the appl ication to the Nuclear Regul atory 

1 8 Commission o n June 22 , 2011 . The a ppli cation, as Lisa 

19 had ment ioned , when you print it o u t i t ' s about 2100 

20 p ages. And when you p u t it in the binders it ' s three 

21 large binders . I t ' s a huge amount o f info r ma t ion . 

22 But t hat only represents a small part o f t h e work that 

23 was done for the engineering analysis to p repare this 

24 appl ication . 

25 The total amount of engineering ana lysis, 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

1~"--::=---, 5-1-SR I 
Appendix A

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54 

1 i f we printed it a ll out would be about 290 binders of 

2 i nfo rmation . We invested over 60, 000 manhours of 

3 e ngineering work . Once we comp l eted our engineering 

4 work to prepare the application, we brought in expert s 

5 from outside Exelon to review t he application t o 

6 e ns ure that it was complete , thorough a nd accurat e . 

7 Our total cost t o prepare the applicatio n and get t his 

8 applicat ion revi ewed by t he NRC wi ll be about $30 

9 mi l lion . 

1 0 There are t wo different pa rts o f our 

11 f:l ppl icat ion , t he safet y review and the environmental 

1 2 eview. For t he safety revi ew, we t ook an in- dept h 

13 ook at t h e histo ry and t he c o nditi o n of t h e safety 

1 4 quipment i n the plant . We did that to determi n e 

15 hether the necessary maintenance was being performed 

16 pn t hat equipment and to make sure t hat the equi pment 

1 7 ll be able to operate when it' s n eed ed , not onl y for 

1 8 oday, but also for an additional 20 years of 

19 pperation . 

20 When you look b ack at Limeri c k , when it 

21 as b ui l t , a l l t he equipment was new. I t was 

22 horoughly tested to make sure it would perform 

23 properly, but like anything e l se equipmen t does a g e . 

24 hat doesn ' t mean it won ' t work, but it does age and 

25 ertain acti v i ties ne ed t o be do ne to the equipment . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

5-2-0S I 
Appendix A

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55 

1 So we perform preventive maint e nance . Sometimes we 

2 refurbish the equipment . Some equipment is replaced. 

3 There may be modifications done t o upgrade the 

4 equipment in the plant and i n f act, as Bill Magui re 

5 has stated, Limerick had spent over $2 00 million in 

6 the last couple years a lone t o i mprove a nd modernize 

7 the equipment and enhance pl ant operations and safety. 

8 

9 were 

We a l so t hen 

performed as par t of 

revi ewed calculat ions that 5-2-0S I 

Cont'd 

the o rigina l design o f t he 

1 0 plant t hat were d one t o e nsure t hat the plant coul d 

11 operat e safely for 40 years . We a na lyzed tho se 

1 2 calculatio ns and were able t o confirm t hat the plant 

13 would be able t o o perat e safely fo r 60 years. 

1 4 Overall , our conc lusion from ou r e ng i neeri ng review 

15 was that Lime rick could operate safely for up to 60 

1 6 years. 

1 7 We also took a l ook at the environmental 

1 8 impacts of continuing t o operate Limerick . We l ooked 

19 at all t he impacts of c o nti nued impact o f the p l a nt on 

20 the environment . Our concl u sion is tha t impacts on 

21 the envi ronment are sma ll and I use the term s mall i n 

22 the sense tha t is i n the regul a t ion . The regulat ion 

23 defines small as environmental effects are not 

24 detectabl e or are mino r . 

25 

(202) 234-4433 

We a l so revlewed t h e a l ternatlves l f 115-3-AL I 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 Limerick wo uld not have its license r e newed a nd 

2 a nother source o f electric generation would n eed to be 

3 i n s t alled eit her here o n sit e or someplace else t o 

4 gene r a t e the repl acemen t electricity. We concluded 

5 tha t any o the r means o f generating t he replacement 

6 electricity would have more of a n impact o n t he 

7 e nvironment than continue d operation o f Limerick . Fo r 115-3-AL I 

IICont'd 

8 inst ance , i f Limerick could b e repl ace d by a wi nd 

9 g enerat ion faci l ity , t he wi nd f o rm wou ld have t o 

1 0 occup y bet ween 1 0 a nd 4 0 percent of all t he land i n 

11 t he s t ate o f Delaware a nd that would h ave a huge 

1 2 impact o n t h e l and . If a s ola r fac ility could replace 

13 Limerick , it woul d n eed t o cover 32 t o 50 percent of 

1 4 t he ent ire land area o f Mont gome ry Co u nty . 

1 5 In conclusion, we ope r ate Li me rick safel y 

1 6 and we can conti n u e to operate it saf e ly for an 

1 7 addi t i ona l 20 y ea r s . Limer ick will provi d e 

1 8 approximately 2340 megawatts of base- l oad gene ration 

19 tha t ' s not o nl y safe, but it ' s clean, reliable and 

20 economica l . 

2 1 Conti n u ed operation o f Lime rick will 

22 b enefit this community, the Commonwealth of 

23 Pennsylvania and our nation . Thanks for giving me the 

24 t i me for this. Thank you . 

25 

(202) 234-4433 

(Applau se . ) 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

5-4-SR I 
Appendix A

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57 

1 FACILITATOR BARKLEY : Tha nk you , Mike . 

2 Dr . Winter? 

3 DR . WINTER: Good a f ternoon . Thanks for 

4 letting me speak . We h av e h ea rd a lot of pros and 

5 c o ns, haven ' t we? And it' s hard t o make a decisio n 

6 tha t ' s f or sure . But let me ge t going here . 

7 As a pnyslclan praCLlClng r aalo.Logy r o r 

8 over 50 years, I s t i ll have s t r ong c o ncern about 

9 cancer sensitiviti es from h armfu l radiati o n exposures, 

1 0 nat ural ly. My medical col l eagues share the same 

11 concern s because we have seen o ur cancer rat es 

1 2 increase since t he Limerick power plant started, 

13 especi a l ly thyro id cancer . I t j umped to 78 p ercent 

14 h i g h er here t han the natio nal average . And some of 

15 the people I tal ked to , this is because people are 

16 agi ng more now, getting older, s o there a re more 

1 7 cancers. But that ' s not true because in other areas 

1 8 simil a r t o our area i n Pottstown , they ' re not nearly 

19 getting the t hyroid cancers t hat we are . This has 

20 b een we l l established by the state . 

21 You wond e r why some o f our medical and 

2 2 cancer fundrais ers h aven ' t reacted with mo re 

23 r es po nsibility in order to stop this. The y ' re making 

24 a l ot o f money , but not taking much effort to prevent 

25 e nvironmental d amage . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

6-1 -HH I 
Appendix A

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5 8 

1 Yes, we are creat ing our own form of 

2 t errorism. Now tha t sounds kind of funn y , doesn ' t it? 

3 But a l lowing any harmful environmenta l event s t o 

4 occur , we a r e a l lowing o ur own form of t err orism, j ust 

5 like forei g n people would come in here . 

6 Havi ng att end ed a Hi roshima , Japan a t om 

7 omb c linic right a fter Wo rld War II, naturally I had 

8 chanc e t o s ee t he worst results o f harmf ul 

9 adiation . All those little kids I saw who only lived 

1 0 or a f ew days, it left me with a ve ry s ad memory. Ofii6-2-HH I 

11 ourse , what i s ha ppeni ng he r e will b e taking much 

1 2 onger, but it s u re is no t good . 

13 I don ' t know whe ther you ' ve heard tha t 

1 4 orne s c ientists are already predict ing that I ' m 

1 5 orry to tel l yo u t his , but nuclear energy has t h e 

16 apacity of destroyi ng man k ind . I t may t a ke about 1 00 

1 7 ears, but our whole wo r l d i s exposed to t he ha r mfu l 

1 8 f fects, maybe not so much here i n t he United States , 

19 ut the whole world can be a f f ected . 

20 Of course , what is happening here will b e 

2 1 taking much l o nger, but it is s ure not good news . 

22 Besides harmful power plant exposures, we have 

23 environmental disasters and a concern about our nearby 

24 earthq uake fault a nd others in the eastern U. S ., 

25 e special ly o ne near New York City . And the n there are 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

6-3-PA I 
Appendix A

A-72

.------------------, 59 I 

1-::1-:--::::--::::-o 1 he radioactive spent f uel deadly waste materi al 6-4-os 1 

2 itting around , supposedly protect ed . We can ' t 

3 control the use of n uclear power in the rest o f the 

4 world , but can k eep America sa f er and cleaner here . 

5 So please , ask your politicians, reliable 6-5-0R I 

6 p o liticians t o c l o se t he Limerick power p l ant . Let ' s 

7 save America f o r our kids a nd des cendants . I h ope you 

8 will take my con cerns seri ousl y . And t hank you f o r 

9 listening . 

1 0 (Applause . ) 

11 FACILITATOR BARKLEY : Okay, thank you , Dr. 

1 2 Wi nt er. The next three people I ' d l i k e t o call i s Tom 

13 Neaf cy o f Limerick Township, f ollowed by Dr . Ani t a 

1 4 Baly, a nd then Tim Fen c he l o f t he Schuylki l l Ri ver 

1 5 Heritage Fo undati o n . 

1 6 MR . NEAFCY : Good a f ternoon, t hank you . 

1 7 My name i s Tom Neafcy. I ' m t he Chairman of Limerick 

1 8 Township Board of Supervi sors and I want to thank you 

19 for this opportunity to speak at t his forum t od ay. 

20 As the largest priv ate empl oyer i n the 

2 1 region , the Board is thankfu l f o r the 8 60 jobs that 

22 Exelon provides, the positive impact of the i r-'r=-L-1=, F-1 -SR I 

23 operation , the vitality of our local community. The 

24 community and local economy are enhanced by the needed 

25 services provided by t h e township , which includes the 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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60 

1 roadway ne twork maintained by our Limerick Township 

2 Public Works, public sa f e ty provided by the Limerick 

3 a nd Linfield Fire Compan ies, a nd our l ocal e mergency 

4 medica l response , o ur public parks, our recreati o n 

5 facilit ies and als o t he police protecti on tha t ' s 

6 p r ovided by Limerick ' s 2 1 sworn o ffi cers. 

7 Because o f Limeri c k Generating Station ' s 

8 location withi n our b orders, t h e Limeri ck Township 

9 Pol ice Department 

1 0 depart ment in 

11 jurisd i cti o n over 

is t he only municipal poli ce 

Pennsyl vania wi t h 

Tier 1 criti ca l 

t he pri mary 

lr=7._-1,.....-s=-R=-___,I 

i nfrast ructure · iCont'sd 

1 2 Thi s Board prides itself on t he servi ces provi ded 

1 3 directly bo t h t o the resi dents and t he b usinesses of 

1 4 t hi s c ommunity and t he t ownship ' s ability to ma i ntai n 

1 5 thos e cur rent l evels of service dur ing t hese dif ficult 

1 6 economi c d ownturns . We are thankf u l f or t he 

1 7 generosity of the Limerick generating p lant a nd Exe l on 

1 8 for be i ng good corpora te neighbors and the assistance 

19 they provide t o t he commu nity . Wi thout their 

20 f i nancial assi stance that i mpact to provide those 

21 services to the c ommuni ty would f a l l squa r ely on the 

22 b acks of the taxpayers . They assist in o u r fire 

23 companies . They have b een corporate sponsors of our 

24 Li merick Community Days . And we are confident that 

25 Limerick generating facility and Exelon will continue 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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61 

1 that support in the f uture and be our good corporate 

2 neighbor. 

3 We a lso are i n support of t h e relicensin g 

4 o f the Lime rick nuclear plant . Th a nk you . 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Dr . Baly? 

7 DR. BALY : Good a f ternoon . I ' m Anita 

8 Bal y . I ' m a reti red Lutheran pastor and my concern 

9 t oda y i s wit h the speed at which this appl i cati on 

1 0 p rocess is g o i ng . I mean it seems to me t hat t o 

11 p redict what environmental fact ors wi ll be i n p lace 1 3 

1 2 years h enc e a nd 1 8 years hence , posits a k i nd o f 

1 3 p mnisci ence a nd prescience t ha t we should attribute t o 

1 4 f\l mi ght y God , b ut certai n l y not t o any of us human 

1 5 ng . 

16 I would favor a s l ower process . As we 

1 7 look around, we see t h at the population i n thi s area 

1 8 i s getting d e nser all the time . The roads are not 

19 b e i ng improved . And t hat l eaves me wi th conce rns 

20 a b out how we would eff ect an e v acuation were one 

21 needed . I suspect strongl y t hat we couldn ' t p erfor m a 

22 good evacuation tod ay . And I a l so suspect that t he 

23 p opulation will be increasing and the roads 

24 deteriorating . In fact , just this morning i n the 

25 Po ttstown Mercury , t h ey were r eport ing on the hearing 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

7-1-SR I 

Cont'd 

8-1-LR I 

8-2-os 1 
Appendix A

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62 

1 hat was held o n Route 422 which i s ou r ma i n r o ad 

2 around here . And Barry Seymour is quot ed , he ' s the 

3 xecutive Director o f the Del aware River Valley 

4 Regi onal Planning Commission , and he t old last wee k ' s 

5 orum audience that population projections anticipate 

6 a 50 percent increase in the region a nd if we don ' t 

7 n crease capacit y o n 422 , we will have v irtual 

8 ~r dlock a l l the way to t he Berks Count y l ine . 

9 Maybe we ' ll improve t h at situation, but 

1 0 it ' s way too early t o k now i f that wi l l happen . And 

11 s o my plea a nd my c oncern is can we s low thi s down s o 

1 2 t hat we k now, i n fact , what t he environmen t a l i mpacts 

13 are going t o be c l oser to a time that the decision i s 

1 4 made . Tha n k you. 

15 (Ap p l ause . ) 

16 FACILI TATOR BARKLEY: Thank you . Ti m? 

1 7 MR . FENCHEL : Good afternoon . My name i s 

1 8 Tim Fenchel and I ' m o n the staff of the Schuylkill 

19 River National a nd State Heri t age Area . We are one of 

20 4 9 congressi on a l ly- designated Heritage Areas in the 

21 country and our mi ssion i s t o use r ecr ea t i on, 

22 conservation , education , c u ltural and historic 

23 preservation a nd touri sm as tools for community 

24 r evi tal ization and economic development with the 

25 Schuyl ki ll River Valley. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

118-2-081 

IICont'd I 
Appendix A

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63 

1 The Herit age Area has had t he opportuni ty 

2 for almost sev en years now to par t ne r wit h Exelon 

3 Nuclear a nd t h e Limerick Generating Station on several 

4 local and regiona l proj ect s a nd programs . These 

5 programs have p r oven t o have a positive impact on our 

6 local commun i ties, residents, a nd natural resources. 

7 And I woul d lik e t o take a few moments t o hig hlight 

8 t hose now . 

9 In 2 005 , Exelon Nuclear appro ach ed us 

1 0 about the possibi lity of partnering t o gethe r on a 

11 g rant program t h a t would work t o resto re our area ' s 

1 2 cri tical natural reso urce , t h e Schuylki l l Ri ver. Th e 

13 river has b een d et rime ntall y i mpacted by hundreds of 

1 4 years o f abu se and n eglect , prima rily as a resul t of 

1 5 o u r nation ' s h i story related to the I ndustr ial 

1 6 Revolution . But even more recently, d u e t o 

1 7 deforestati on , f a rmi ng p r a c tices , and c ontinued open 

1 8 space developme nt . 

19 Beginning in 2006 , a ft er the creati on of 

20 grant p r o gram g uide l ines, an advisory committ ee and a 

21 necessary accounti ng a nd r eporti ng s t ructu r es, Exe l on 

2 2 b egan ma king ann ual contributions to the Schuylkill 

23 River Restorat ion Fund . The Sch uyl kill River Heritag e 

24 Area acts as the administrator a nd t h e manager of this 

25 grant program, redistri buti ng Exelon ' s co ntributions 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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64 

1 t o local and regional waters hed groups, conservati on 

2 organi z a t i o ns , and local g overnment agenci es f or 

3 project s addressing t he q uality a nd q u antity of 

4 Schuylkill River water . Projects f ocus ing o n 

5 agricu ltural remediation , a bandoned mi n e drainage , a nd 

6 stormwat er runo ff are supported t hrough this program. 

7 To d a t e , Exelon ha s cont r ibuted over $1 . 2 

8 million to t he restora t i on fund f or watershed- wi de 

9 project s . Twent y-two g rants have been awarded a nd 1 1 

1 0 project s have been c ompl e t ed . These project s have 

11 made a n i mpact on the water quality and qu antity of 

1 2 t he Schuyl kill Ri v er whi c h i s a sou r c e o f dri n ki ng 

13 wa t er f o r over 1 . 7 5 mi llion people i n s ou t heastern 

1 4 Penn sylvani a . 

1 5 Ex e lon ' s establ i shment and c ontributio n t o 

1 6 t he restoration f u nd has been a model p rogr a m and is 

1 7 now a uni qu ely val ued public/priva te p artnership as 

1 8 several new pa r tne rs have j oined e fforts and made 

19 the i r own contributions to t h e fund . Bot h t he 

20 Phil ad elphia Water Dep artme nt and the Partn ership for 

21 the Del aware Estua r y h ave brought f u nding t o the 

22 program and s u pport ed regi o na l waters hed project s . 

23 The con tributions made by Exe l on have b een the 

24 catalyst to l everage additional funds we ll over 

25 $600 , 000 f o r area restoration . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 The goal o f the Restoration Fu nd Advisory 

2 Commi ttee is to be abl e t o support a sustainable level 

3 o f half a mi l lion d o llars a nnually for the fund a nd in 

4 turn , conservation projects t ha t will continue t o 

5 e ns ure the futu re hea lth o f the Schuyl ki l l River. 

6 I n addi tio n t o o ur wo rk o n the rest oration 

7 f u nd , we have a ssisted Exelon Nucl ear, East Coventry 

8 Townshi p , and Che ster Count y in a p l a nning eff ort t o 

9 begi n the process o f rest oratio n a nd preservati on of 

1 0 t he h ist o r i c Fricks Locks Vi l lage . Earl i er t his year, 

11 Exe l on Nuclear, t he current owne r s o f t he v illage , 

1 2 s i gned an agreement with East Coven try Townshi p t o 

13 stabili ze , reh abi litate , a nd p r otect several of 

1 4 Chest er Cou nty ' s oldest b u ildings . Exelon ha s agreed 

1 5 t o spend $2 . 5 mill ion to resto re t he exterior of 

1 6 several buildings as stabi l i z ed ruins . A fen ce will 

1 7 be built around the grou nds and t he corporati o n is 

1 8 donating four ho uses t o t he township worth an 

19 estimated $1 mil l ion. 

20 In additio n , the corp oration has agreed to 

21 c ontinue t o do routine ma i ntenance on the vil lage and 

22 work with the l o c a l h ist ori ca l soci ety to host g uid e d , 

23 historic and edu cation a l tours for t h e p ublic . 

24 From ou r perspective , mu ch of the success 

25 o f t h i s pa rtnership can be assi g ned t o the h ard work, 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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66 

1 dedicat ion and p ersonal commi tment of Exelon staff a nd 

2 management . Bas e d on t he v ery positive c ommunity 

3 prog rams and i nvolvement we h ave experienced a nd 

9-1-SR I 

4 witnessed firs t hand as a regiona l organization, we 

5 would l i ke to communicat e our support for t he 

6 r e licensi ng a nd c o ntinued o p eration o f Lime r i ck 

7 Gene rati ng Stat i o n . Thank you . 

8 (Ap plause . ) 

9 FACILITATOR BARKLEY : Oka y , t ha n k you . 

1 0 The next t hree people I would like t o call , Bill 

11 Vogel , fo llowed by Eileen Dautrich, is t h at how you 

1 2 s ay that ? 

13 MS . DAUTRICH : Dautrich . 

1 4 FACILITATOR BARKLEY: Dautrich . Okay. 

15 And then Bi l l Albany. 

1 6 MR . VOGEL : Hi , my na me i s Bill Vo gel . I 

1 7 l ive i n Phoe nixville . Units 1 and 2 had an i n i t ial 

1 8 l i fe e x pectancy o f 40 years . They a re now asking t o 

19 increase that 20 yea rs, a f ull one third increase . 

20 Everything has a life expectancy , machin ery , as well 

21 as people . Demographi call y , my l i fe e x pectancy i s 74 . 10-1-LR 1 

2 2 If I was to get a one third extensi on, like t he 

23 Limerick plant wants , t h at woul d take me to 111 . What 

24 do you think is going to happen to me between age 74 , 

25 my l i f e span, my na meplate capacity, and the year when 

(202) 234-4433 

.. ~ ... ""· '"'""'"'"" COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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67 

1 I reach 111? I t ' s going to go down hil l . That ' s 

2 l ifecycle . Machinery has them. You don ' t n eed an 

3 e ngineer t o t e ll you that . Just l ike human b e ings 

4 have t hem . We b ecome less e ff ect ive , less effi cient , 

5 less compe t e nt . 

6 The signi f i cant d i fferen ce is my f a ilure 

7 wil l be containabl e . Limeri c k ' s mo st likely wi ll n o t . 

8 If I drive over you wi t h my car because I no l onge r 

9 see as well or h ave t h e re fl exes I o nce had, that ' s a 

1 0 t ragedy for you , you r f ami l y , f or me and my famil y . 

11 The s phere o f t he tragedy is containable . If Lime r i ck 

1 2 Uni t 1 or 2 fails, a l l h e l l breaks loo se , no 

13 disrespect . That ' s what a n u c lear f ailur e is, hell. 

1 4 It affects everybody in t his r oom, everybody in t h e 

1 5 community , everybody i n the t r i - s t ate a rea , not for a 

1 6 week , but for decades . I t ' s very, very last thing we 

1 7 want to h a ppen . 

1 8 And I think we ' re putting ourselves in 

19 harm ' s way by taking somethi ng that had a lif espan of 

20 40 years and adding another 20 to it. It doesn ' t make 

21 sense . The o n l y way t o rati ona l i ze i t i s through our 

22 p ersonal fear o f b eing inconvenienced b eca use we l ose 

23 a very, very good sou rce of power . It ' s done a great 

24 job for u s . But l i ke me , you get to a point where 

25 your abi l ity to provide a great job is at an end and 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

10-1-LR I 

Cont'd 

10-2-

0R I 
Appendix A

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6 8 

1 thi ngs start d eteri o r a ting . Let ' s not put ourselves 

2 i n that position . Let ' s make an intellige n t decision 

3 now and a l low these two u nits t o expire at the ir 

4 n a me pl a t e t ime . Tha nk you . 

5 (Applause . ) 

6 FACILITATOR BARKLEY : Thank you , Bill. 

7 Eil een . 

8 MS . DAUTRICH : Good afternoo n . My name is 

9 Eil een Dautrich . I ' m president o f the Tri - County Area 

110-2-0RI 

ICont'd I 

1 0 

11 

I ' m happy to be here t o day t o I 

,..,u......,....=-=-..., 

p rovide examples of how Limerick Ge nerati ng St a tio n is 111-1-SR I 

f=hamber of Commerce . 

1 2 a valued c ommu nity a nd b usiness part ner and echo t he 

13 statements already s hared by seve ral others . 

1 4 They ' re one o f t he tri-county area ' s 

15 l arg est empl o ye r , provi ding pro fession al emplo yment 

16 p pportuniti es for l ocal residents . Thos e l oca l 

1 7 resi dents emplo yed by Limeri ck Generating Stat i on are 

1 8 s upporting the e n tire tri - county business community. 

19 rrhey ' re purchasing personal goods and services from 

20 local s ma ll businesses. The annual outage i s a 

21 t r e mendou s benefi t t o the local e conomy and o u r local 

22 nesses . Limerick encourages t heir outage 

23 employees to v isi t and purchase f rom tri- county area , 

24 local b usi nesses, and s mall businesses . 

25 In addition to t he jobs t hey provide local 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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69 

1 r eside nts, t h e y ' re making a sig nifi c a nt i nvestment in 

2 o u r loc al commu ni tie s . Muni cipa l ities a nd r esidents 

3 b e n e fit f rom a s s istance r eceiv e d from Limerick t o 

4 s tar t , ma i n tain, e xpa nd p a rks, r ecr eat ion , a nd q ua lity 

5 o f l i f e o pportunities . 

6 The ir c orp o r a te culture o f givi ng back t o 

7 the commun i ty is p racti ced by their hundreds o f 

8 emplo yees . Nonprofit o rganizatio ns are suppo r t ed by 

9 Limerick Generati ng Station a nd t he effo r ts o f their 

1 0 emplo yees . Fi nancial donati ons, as well as v o l unteer 

11 h ours and time are donated , e nabling o ur l o cal 

1 2 nonprofits t o provid e t h e much n eeded servi c es t h a t 

13 impact t hose i n n eed through out the tri- c o unt y area . 

1 4 The Limerick Generating Stat ion is 

15 c onfident i n t h e c l e an and sa f e e nvironment t h ey 

1 6 ma i ntain i n our c ommuni ty. The commun ity has b e e n 

1 7 invit e d t o exp erien ce t he generating stat i o n 

1 8 f i r s t hand . The chambe r hosted a membership breakfast 

19 a nd the site vice president, Bill Maguire p r ovided t he 

2 0 key note p resenta tio n . He s umma ri zed s afety measu res 

2 1 and adv ancements at Limeri ck and a n s we red q u est ions 

2 2 p e rtaining t o the Limerick p lan t and i t s s afet y in t h e 

2 3 wak e o f the tsuna mi i n J a p an . 

24 In a ddition, after our breakfa s t , Chamb e r 

25 memb ers wer e e n c our a ged t o a tte nd t h e infor ma tional 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

111-1-SR I 

ICont'd 
Appendix A

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71 

1 see p o licies and procedures that people t al k about a n d 

2 t hey ' re put up on a shel f and t hey ' r e followed at best 

3 haphazardly with a wink and a nod and deviation from 

4 the policy is n ot addressed . 

5 One of t he things tha t I ' m c o n t inuously 

6 impressed a t LGS when I v i s i t is t heir sound adherence 

7 t o pol icy and p r oc edure . They don ' t deviat e from i t . 

8 I ' ve been t o numerous d r i lls a t t h e plant, numerous 

9 exer c ises a t the p l a nt , some of wh ich were run by t he 

1 0 NRC and I ' v e neve r seen t hem fail . The y a l ways come 

11 o u t o n t op . In f act , i n 2009 , Limerick was selec t ed 

1 2 as a s i te f or t he f i rst comprehen s i v e pilot exerci se 

13 involvi ng fede ral , s t ate, and local law enfo rce ment 

1 4 SWAT teams t o act ua lly g o into the power b l o ck and 

1 5 c onduct tacti cal oper ati o ns i n there , and that drill 

1 6 was u sed as a boil er p l ate to develop pol i cies and 

1 7 pro cedures f o r implementation in power plants 

1 8 throughou t the cou ntry. 

19 One o f the I ' m s o rry, I don ' t beli eve 

20 that continued operations o f the power p l ant would 112-1-SRI 

2 1 have any detr i mental e f fect on pub l i c safety in the 

2 2 southeast regio n . Th a nk you . 

23 (Applause . ) 

24 FACILITATOR BARKLEY : Okay, thank you . 

25 I ' d li k e to call t h e final three speakers wh o h ave 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
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72 

1 signed up , Jo hn McGowan , Ted Del Ga izo , and Timothy 

2 Phillips. John? 

3 MR . McGOWAN : Thank you very much . My 

4 n ame i s John McGowan and I am a l i f e - long r esident of 

5 the Delaware Valley. I have l ived h a lf o f my -- or I 

6 should say the Limerick Nuc l ear Power St a t ion has been 

7 operat i ng for ha lf o f my l ife . I own three 

8 manu fact uri ng companies i n the Ma l vern area and emp l oy 

9 a number o f peop l e in t hose faci l iti es who r ely 

1 0 t remendously on the Limerick Power Ge ne r ating St ation 

11 t o supply safe , rel iable e l ect rical power t o keep us 

1 2 operating . 

13 Today, I would like to say t ha t in all of 

1 4 t he years t hat I ' ve l ived i n this area , I ' ve never 

15 worr ied a t a ll about the safety of t h e nu c lear power 

16 plant . I see i t every day. And it bothers me not i n 

1 7 the least . I have n ever seen any credi b le evidence t o lr:-13=---1-=--::s::-::::-'1 R

1 8 s uggest t hat there are s afety p roblems with this 

19 plant . I n t e rms o f relia bility, i t is the same . It 

20 is running 24 /7 , 365 days a year and it has been doing 

21 so for a quarter o f a centu ry and I hop e it con tinues 

22 to do so f or ma ny more years to come . 

23 As far as its environmental impact , I 

24 thi nk it ' s pretty widely known that nuclear power is 

25 o ne of the c leanest environmental energ ies tha t we 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
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1 p ossess t od a y throughout the world and t o d ismiss it 

2 is I t hink a foolish notion . 

3 The impact o f the Limerick p lant i n our 

4 r egi o n has b een extraordinaril y p ositive . It 

5 provid es, as we a ll know and have heard t od ay, lots o f 

6 j obs, l ots o f good jobs, tax r evenues for schools, 

7 local governmen ts and for t hose who live i n the area 

8 t o e nj oy t he fruits o f public services and it also 

9 provides a lot o f chari tabl e d o natio ns t o t h e 

1 0 c ommunit y which is ver y importa nt . 

11 I think t h a t t o no t keep this plant 

1 2 runn ing a nd not consid er a renewal of its license f o r 

13 an extended period would be a tragic mistake fo r all 

1 4 o f us and I would l i ke t o end t hi s by saying t hat t he 

15 o nly meltdown that wo uld c o ncern me i s the economic 

1 6 o ne that certainly would happen to this area s hould 

1 7 this p lant not con t i n u e to operat e . 

1 8 (Applause . ) 

19 FACILITATOR BARKLEY : Ted , go ahead . 

20 MR . DEL GAIZO: Hi , my name i s Te d Del 

21 Gai zo . I' m a r egi stered p r o fess i o nal engi nee r i n the 

22 Commonwea lth o f Pennsylvania . I ' m also president and 

23 CEO of a small business engineering firm in nearby 

24 Exton , Pennsylvania . 

25 

(202) 234-4433 

My experi ence in nuclear p ower goes b a c k 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

13-1-SE 

Cont'd 
Appendix A

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74 

1 t o the 1960s where I spent 1 4 years i n Navy submarines 

2 a nd I personally operated, maintained , a nd refueled 

3 nuc l ear power plants during tha t period . 

4 But I ' m he r e t od ay as a priv ate c itizen, 

5 as a resident o f the area and as a member o f the 

6 Pennsylvani a En ergy Alliance t o go o n r ecord and say I 

7 s trongl y favor l icense r e newal f o r the Limeri ck 

8 Gene rati ng Stat ion . I say that because i n my personal 

9 experience I know in spite o f s ome of the t hings 

1 0 you ' ve probably heard here t oday , nuclear power is 

11 safe , reliable , secure and c lean. But i n additio n t o 

1 2 t hat , I would l ike t o go o n record , I would l ike my 

13 n e i ghbors t o know we are lucky t o have t he Lime r i c k 

1 4 Generat i ng Station in t h is area . In the i ndustry, it 

15 has a top reputati o n . It i s one of the fi nest nuclear 

16 p ower plan ts i n America . And Exel o n , if not the best, 

1 7 is ce r t a i nly one o f t h e f i nest nucl ear operato rs i n 

1 8 the world . 

19 I have no thing but confidence t hat Exel on 

20 will work together with the NRC , wi ll run through the 

21 process and we wi l l c ome up wi th the r i ght concl usion 

22 here which i s license renewal s hould b e granted to t he 

23 Limerick Generating Station. I think we need to keep 

24 Limerick operating as long as we can . 

25 In addition, in spite of some other things 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
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76 

1 openness in the t h inking process t hat goes into place 

2 for renewa l of any nuclea r power plant . 

3 And so f rom my p erspective as a citize n , 

4 as a bus iness person who h as worked in this community, 114-2-SR I 

5 I understand the value t his is to t he r egion . And f o r 

6 , I applaud the NRC f or what they ' re doi ng here . I 

7 applaud Exelon fo r the g reat work that t hey ' re d o ing 

8 there and I encourage the renewa l process t o take 

9 p lace . Thank you . 

1 0 (Applause . ) 

11 FACILITATOR BARKLEY : Thank you . With 

1 2 t hat , I have a l l 15 people who had signed up f o r this 

13 meeting , have been call ed . Is there anyone else who 

1 4 would l i ke to make a short f o l low- up remark or would 

15 like to stil l speak at this po i nt ? 

16 Okay, if not, I ' d like to make two points 

1 7 befo re we wrap up . One , the NRC does have publi c 

1 8 meeting feedba ck fo r ms whi ch give us feedback on how 

19 you think thi s meeting was cond ucted , s o I would 

20 greatly appreciate yo u filling out one o f those forms 

21 for us so that we c a n l earn how to improve . The re is 

22 another session o f this meeting at 7 o ' clock tonight . 

23 You ' re welcome to speak again tonight . 

24 And secondly, wh at I ' d l i ke to say is I 

25 facilitate a l ot o f mee tings t h roughout t he Northeast 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
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27 

1 meeting via c o nference bridge . And due to the 

arrangements of the audio in this room it wasn ' t 

p ossible t o do it any other way than a cell pho ne . So 

we ' re goi ng to go to him a nd ask him to make a 

statement f or the period and move from there . So our 

first speaker will be Mr. Thomas Saporito who is a 

senior consulting associate and he actua l l y l ives in 

Florida . So as soo n as we can work having him on t he 

microphone we will have him make his statement . Are 

1 we free to give i t a try? 

MS . REGNER : Go ahead . Yes . Go ahead, 

1 Mr . Sapori to . 

1 MR . SAPORITO : Is it my turn t o speak? 

MS . REGNER : Yes . 

1 MR . SAPORI TO : Oka y . Can you hear me 

1 oka y? 

FACILITATOR BARKLEY : As best we can , yes. 

1 MS . REGNER : Yes , go ahead . 

1 MR . SAPORITO : All right . My name is 

2 Thomas Saporito . I ' m the senior consultant with 

Sapr odani Associ ates and I ' m l ocated in Jupiter, 

2 Florida . I would like to comment on the NRC ' s 

2 environmental review but before I d o that I want to 

state that, you know, I ' m very upset at the NRC ' s 

2 refusal to honor my enforcement p e tition filed under 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

16-1-0S I 
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28 

1 10 CFR 2 . 206 wit h respect to the Limerick nucl ear 

plant . The NRC denied tha t petiti o n on the basis that 

I would have an opportunity t o int erven e o n this 

proceedin g through the NRC ' s judi cial process. 

However, that ' s not available to me . I made that 

q uit e c l ear in t he 2 2 06 petit ion . Now, I don ' t have 

standing a s a Un i t e d Stat es cit izen because of my 

physical location i n Jupiter to intervene in a 

proceeding in Pennsylvania where this plant is 

1 located . The NRC staff is incorrect i n their opinion 

and t hey have a leg a l oblig a tio n t o honor that 

1 enforcemen t pet i tio n and t o provide a n opport unity f or 

1 me t o address t he Petiti on Review Bo ard . So I want t o 

put t hat on the record and I'm asking t he NRC to l ook 

1 into that issue . 

1 Wi th respect to this environmental 

petit i on the fel low who spoke earlier from t he NRC , I 

1 don ' t recal l his name . It was very ha r d f or me to 

1 hear t hro ugh this communication his name . But anyway , 

2 o ne of his comments was exceptional l y incorrect and he 

mis i n formed the p ublic . And I ' d l ike to correct that 

16-1-0SI 

Cont'd I 

2 statement . 16-2-LR I He stated that the NRC is e x tendi ng the 1--r-----' 

2 o riginal operating license which was granted by the 

NRC for a 40 - year period o f time that that initial 4 0-

2 yea r license was no t based on safety consi derations or 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 echnical consid e rations . But that ' s absol u t ely not 

rue and there was recently a year- long investigative 

4 

eport done by the Associated Press who int erviewed 

t-:-::! 2:--:-:L R::::-ol 

2xpert nuclear personnel , engineers, safety engineers Cont'd 

~ n the nucl ear industry who told t hem that the 40 - year 

E i censes issued by the NRC f or 104 n uclear plants in 

7 h e United States was based on safety and t echni cal 

afety techni cal analysis. So these proceedings, 

c hese l icense extension proceedings l ike the one we ' re 

1C :::urrent ly a t are a rubber- stamping of these 20- year 

11 icense extensions. This i s i n fact a foot race 

1 L bet ween the Nuclear Regu latory Commission a nd t he 

L ' Uni ted St ates Congress where Congress wants t o s t op 

1 4 t h i s process, put a moratorium on the re- lic e nsing 

16-3-LR I 

1 " until the Fukushima disasters can be ful l y understood 

1E and the enhancement enacted i n August for o u r power 

1 7 ::>lants here . This particul ar nuclear p lant, these 

1 c ::>lants , you know, their license is a lready good till 

024 . Why are we here now 1 2 years ahead of time 

2C ryi ng to extend this license? And the only reason is 

2 1 ::>ecause i t ' s a foot race the NRC ' s in with Congress 16-4-LRI 

2.c nd nothing more . This has nothing to do with 

2 ::>rotecting public health and safety, it ' s the NRC ' s 

2 4 ea l to continue to rubber- stamp these license 

2 ." 2xtensio n s without allowing c i tizens due p rocess like 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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30 

I already talked a b out a nd without doing a cost 

i nt e nse and t horough e nvironmental r e v iew. 

And with r esp ect t o t he NRC ' s 

environmental review the NRC i n my v iew fail ed t o 

pro p erly consider t he embri t t lemen t o f this n uclear 

eactor vessel . When these nuclear reactors are 

:>perat i ng the neutrons c ause the me tal i n the reacto r 

vessel to become bri ttl e over t ime . And a fter 

numerous years o f ope r a t ion these reactor vessels 

coul d crack because t hey ' r e so brittl e . But t he NRC 

j oesn ' t properly evaluat e that a nd the NRC doesn 't 

equire the l i censee t o d o dest ruc tive testing a nd 

analysi s o f t he reactor ' s metal vessel pri or t o 

ubber - s t amping a 20- year extensi on t o t h ese l icenses. 

Twenty years f r om now, o h actually 20 years f rom 2024 

whi ch wi l l b e 204 4 this reactor is goi ng to be even 

more c r itically brittle and the NRC ' s not going t o 

understand the dynamics of t ha t and t he reactor could 

c r ack and i t ' s g oing t o melt down because you can ' t 

ecover f rom a l oss o f cool ant acciden t of that 

magn itude . So tha t ' s one p oint . 

The other p oint is the NRC ' s Commissi on 

I 

16-4-LR I 

Cont'd 

16-5-0S I 

:>ver there i n Rockville , in the Whit e Flint Building, 16-6-0SI 

hey recently a d o p ted a new p olicy with respect t o 

ev a cua t ions. 

(202) 234-4433 

They want these licensees t o update 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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32 

1 would actually have the licensee shut down more of 

their other power p lants because o f you would need a 

demand . I f you t a k e wind energy which is plentiful up 

there in Pennsylvania and even the n ew solar panel 

which can operat e when t he sun isn ' t s hining on a 

cloudy day you could replace even more operating power 

plants. So these renewable e nergy sources even with 

respec t to wind energy s i nce you have a common grid 

t hroughout t he United St ates you can have wind farms 

1 g enerat e power t o a common gri d point and supplyi ng 

t he power t hat t hese nucl ear p lants are now provi ding . 

1 The NRC ' s required under the law t o consider these 

1 alt e rnatives to extending t his l icens e . And I woul d 

hope that the NRC ' s f i nal eval u ation and revi ew shows 

1 a complete and thorou gh ana l ysis of a ll these 

1 renewable energy sources including installing ondemand hot water electric heater and doing an analysis 

1 of how many megawatts you ' re going to take off the 

1 grid and based on those evaluations make a licensing 

2 determination whether or not this l icense should be 

extended . Because 2 0 years from now a l l these 

2 renewable r esources are going to be all that much more 

2 advanced a nd capable of supplying all that much more 

power than they ' re c u rrently s upplyi ng . So those are 

2 my comments and I would hope that the NRC takes them 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

16-7-AL I 

Cont'd 
Appendix A

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33 

1 seriously and applies them to this license renewal . 

And I hope e verybo dy h eard me . 

(Applause) 

MS . REGNER : Can you hear that? They ' re 

clapping . 

FACILITATOR BARKLEY : Okay, a t this point 

I '11 ca l l b ack Mr . Saporito later and t hank him f o r 

h is remarks and fo r being succinct i n his remarks. 

It ' s awfully awkward t o provide comments v ia this 

avenue . 

The first t h ree people I would like t o 

call a re actually i ndiv i d u a ls who did n o t speak this 

aft ernoon s o I' d like to start with them. Firstly, 

Jeff Chumnuk , then Daniel Ludewi g , and t h en f i nally 

Cat h e r i ne Allison . So Je ff, i f you could lead off. 

MR . CHUMNUK : Hi , my name is Jeff Chumnuk 

and I ' m a member of Borough Counc il with Pottstown 

Borough . And my comments t oni ght are more I g uess 

from my perspect ive as a newly elec t e d o f ficial with 

the generating station . Ab out a y ear ago I had the 

oppo r tunity to go d own to the generating station and 

1.-:-:::'--:--=:-=-. 17-1-SR I meet with Joe Saffro n and the first part of my meeting 

h ad to do with looking for some supp ort for the 

Pottstown Soapb ox Derb y . Th rou gh some conversation 

whil e we 

(202) 234-4433 

were s t a ndin g outsid e 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 

you know Joe 

WW'W.nealrgross.com 
Appendix A

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34 

1 e nlight ened me a l ittle b it on what Exelon and the 

generat i ng stat ion do for t he surrounding communities, 

whether it' s supporting our f i refighters, po lice 

departments and other civi c o rganizatio ns . Yo u know, 

from a Pottstown p erspective they help us with our 

yearly b o r ough cleanup, o ur Salvatio n Ar my and now t he 

Soapbox Derby . Thank you . 

And we we re standi ng outside that day, i t 

was pret ty nice out, and o u r c o nve rsation l ed to t he 

1 power p lant i tsel f. We were s t anding t here loo king 

around , it's a pretty impressive sight . So I asked 

1 h i m about , you know, possibl y havi ng a tour f or 

1 municipal offi c i a l s . He sai d he wou l d look i n t o it 

and see what he could d o . A cou ple of months later he 

1 got a group o f about 20 o f us and gave us a t o u r of 

1 the plant one even ing . And I have t o say t hat from 

the time we wal ked thr o ugh the fro nt ga tes and p ast 

1 the security as our tou r p rog r essed, you know, 

1 throughout t h e plant safety was paramount . Whether 

2 you were having explained what the different colors 

a r e on the d i fferent panels and what t hey mean to 

2 d i fferent f a ilsafes , why you walk cer tain areas 

2 certain ways a nd what lines you had to stand behind, 

you know, safety was paramount with them . You know, 

2 from t he e nvironment, I ' m looking around and t his 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

17-1-SR I 

Cont'd 
Appendix A

A-96

1 

35 

place is spotless . And I asked wh y and it ' s because 

t hey can ' t afford to have dirt or lint or fuzz ba lls 

around b e cause o f static e lectricit y becau s e i t could 

create issues. So f rom that aspect I thought i t wa s a 

good t o ur and i t made me feel good abo ut the safety 

aspect s there . 

To fini sh o ur tour we ended up i n t he 

c ont rol r oom upsta i rs. And I ' d say maybe a dozen o r 

s o i nd i vid ua l s up there moni t o ring you know everything 

goi ng o n within t he p l a n t and around t he p l ant. And 

aga i n , expl a i ning t h e f a ils a f e s and wh y t he y ' re 1 

,...1-,J?'-- 1--s=-=R=--""1 

It Cont'd doub l e -, tripl e - check ed t o e limi nate h uman err o r . 

was j ust v e ry i mpre ssi v e a nd as an electe d offici a l t o 

go down and t ake a t our of the p l ant and u nderstand 

how it operat es . I know whe n I left I personally know 

how to issue a c onc e rn with the generating stati on . I 

know I fe lt a l ot better and a l ot safer goi ng home 

that night . And i t was a l so good to rea l ize , you 

know, as one o f our region ' s largest empl o yers now 

that they are will ing to give b ac k to the community 

and keep s a fety first. So t hank you, I just wanted to 

make those comments . 

Daniel? 

(202) 234-4433 

(Applause) 

FACILITATOR BARKLEY : Thank you , J e ff. 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 

36 

MR . LUDEWIG : I ' m Da n Lud ewig . Jus t two 

q uest ions . One wo uld be what ar e we goi ng t o d o wit h lr.:':-:--::::-:-:-:"1, 18-1-RW1 

1 

the 20 y e a r s o f spent r o ds a nd how a r e you g o i ng t o 

t a k: e car e o t those . And s e c o ndl y , l t we d o n t get the 

licens e which I d oub t but wha t would -- how would we 

get ele ctric i f t he l icens e we r e c ance l ed ? I d o n ' t 

know who a nswe rs t his . 

FACILITATOR BARKLEY : I ' l l a s k Li sa t o 

s p ea k . 

MS . REGNER: Yes, the spent fuel r ods. 

Limerick is l icens ed f o r a n ind ivi d u al s pen t f u e l pool 

fac i lit y . They o ffl oad t he spe n t f ue l . Once t he y ' ve 

c ooled t o a c ert a i n l eve l the y will p ut t hose int o dry 

cas k storage and s tore t ho se o ns i t e . I n t h e 

env i r onmen tal review t h a t ' s l o o ked at g ene ri cally . 

Lime rick d o es h a v e storage f or the spent f u e l r ods. 

Tha t ' s a n o ngoing , i t ' s o nsite and p art of thei r 

r eactor o ve r s i g ht process a s we l l . So t he res i d e n ts 

tha t work at t he p lant monitor the s a f e ope r a t ion of 

those fac iliti es . 

The second q uesti o n , whe r e wou ld the power 

come f rom i f Lime rick we r e s hut d own ? There a r e 

a l ternate p ower faciliti es i n the a r ea . Da v e , you 

want t o g i ve that a t ry? 

MR . WRONA: I ' m David Wro na , a bra nch 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

18-2-0S I 
Appendix A

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3 8 

1 Can everyone hear me i n the back r ow? I am Catherine 

Allison and I was born and raised in this area so as 

far as t he NRC want i ng to know how this impacts t he 

area I know it very well . I ' v e also trave l ed t he 

worl d so , Europe , et ce t era . So did a n yone not be 

abl e to hear me , just r a i se your ha nd . You ' re good? 

Okay . 

One thing I wanted t o say is the NRC 

t oni ght is d o ing a scoping basically fo r e nvironment a l 

1 p u rposes f o r t he r e - licensing . What I wanted t o say 

i s for years eve ryone , I ' m being general here , but 

1 most pe ople have been tal king abo ut t he effects of 

1 like , you know, c ancer, you know, t h e i mpact on t h e 

clean air, c lean water which things we are all 

1 c oncerned abo ut a nd a lot of us just didn ' t d o 

1 anythi ng about i t even though we were ve r y concerned . 

Now l ately wi th the -- u nfo rtunately it' s 

1 a reality now t h at we have h urrica n es, mor e tor nadoes, 

1 tsunamis throughout the worl d . And I hate to say it 

2 but it i s a reality now that we have terrorist att acks 

and Li meri ck is d efini t e ly one . I don ' t want to b e 

2 blowing t his out of proportio n but it ' s just something 

2 that I know t hat we ' ve all been c oncerned about , not 

wanting to say yes, Limerick, and all the people that 

2 built the power p lant and the company say o h , there ' s 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

lr-=1..,.-=-:--. 

19-1-PA I 
Appendix A

A-99

39 

1 no impact to the air and the water pollution and so 

f orth . So we ' v e kind o f j ust b linded our, you know, 

selves to tha t a nd let ' s b e l iev e t hen , o kay, l e t ' s 19-1-PA 

Cont'd 

a ke a mi n ut e . Let ' s r eal l y b e lieve tha t t here i s no 

mpact i n our clean a i r , c lean wa t er a nd those type o f 

hi ngs and cance r , e t cet era . Let ' s j ust go into t he 

new rea l ity which is terrorist attacks which would 

happen . Let ' s j u st say f or examp le ther e was human 

e rror t here with the s p e nt fue l r ods a nd s omething 

happened, o r a radiation l ea k . I j ust d r ove toni ght 

r o m King of Prussi a . Talk abo ut evacuation when 

hese natural disast ers and realitie s hit us . One 

a cci den t, t wo hou r backu p , a lmost no exaggerat i on, one 

housand cars. The re will be no evacuatio n . I don 't 

want t o be l ike scare tactics here but like I s aid, 

he weathe r and s o f ort h , na tur al d i sasters h as r eally 

bee n hitti ng the whole Un i t ed States and the wo r l d 

ately so i t ' s a reality . 

There was flood ing after the hurricane 

hat we just had . Five d ays later there was roads 

l ased in Pottstown, i n No rth Coventr y , East Coventry. 

There were , when I t ried to get home f rom work r ight 

Jn Route 7 2 4 , no e x aggeration again from a l l t he back 

oads ab o u t 500 cars. Th ere wi ll be no evacuation and 

certain l v hope t hat p eople understand I ' m not trvinq 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

19-2-0S I 

I 
Appendix A

A-100

1 

40 

t o b e scare tactics. I see t his . I ' m sure a l ot of 

you have seen this and been in these situations. All 

with a l ittle bit of flooding . What t his do es to 

~-:-1 ~2--="""s,....,l 

the Cont'd 

r oads. Aoain there will be no evacu ation . 

So from day one I t hi nk power plants never 

s ho uld have b een built but now tha t they are 19-3-0R I 

here why i-"T"--...1 

would we ever want t o re- license . And a s o ur 

gent leman caller just said, I believe his name was 

Thomas , he was very eloquent . He was stating the fact 

why are we re- li c ensing t hem, what, 1 2 years ahead of 

t ime . To me that is absurd . Like maybe a year befo re 

o r they have t o do s ome studies, t wo years before . 

Why do they and l ove Thoma s ' s words , r'-:-:,..._:-:--=-• 

19-4-LR I 

want us, I 

rubber- stamp something? Twe l ve years beforehand to go 

into what , 202 4 f o r Unit 1 was it and 2029 for Unit 2? 

Wh y do they need to push t his licensi ng re newal? 

You ' ve got t o stop and t hink . Peop l e , go home , think 

about that. I ' m not an expert l ike evidently our 

cal ler Thomas was b ut again , I ' m concerned about human 

l ife . This is what I have at the top here . We are 

a l k ing about human life . Wha t ' s mo r e i mportant, not 

all this e lectricity that we need for all ou r cell 

phones a nd everything . I n a way we are responsible 19-5-0SI 

-For the fact that PECO and all these other Exelon 

ompanies are buil d ing power plants. 

(202) 234-4433 

1\I~L "· U"U;;);;) 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 

I myse lf you 

WW'W.nealrgross.com 
Appendix A

A-101

4 1 

1 Know am gu11ty ot a lot ot tn1s but let s JUSt maybe 

for a solution besides the wind and solar power and 

everythin g s t op using all t his new technology . Yes, 

4 you need it for some jobs and businesses, it ' s good 

~ for c ertain thin gs, but let ' s not overindulge where we 

E need s o much electricity that we are willin g t o risk 

7 o u r lives . Cancer, pollu ted water. There ' s n o 

dri nki ng wate r anymore . Peopl e have t o pay to buy 

c wa te r t hat c omes from natural s prings. But yo u ' re 

1C usi ng p l astic bot tles, you c an 't even trust t hat. 

11 But this whole world h as kind of just 

1;; cha nged f rom you know nature . Let ' s get back t o 

L ' nat ure , let t h e -- i nstead o f having all the young 

1 4 t ee n agers on their cell phones t exti ng , usi ng more 

1 " electri c ity , t hat again it ' s going to cause cancer for 

lE them . Everybody has to stop and think why do we need 

1 7 the powe r p l ants ? We really don ' t and again , Thomas, 

1c o u r wonderfu l call er mentio ned some a l ternatives like 

1 S the solar power, wind, but I ' m jus t saying we are 

2C usi ng so mu ch electricity and stupid little video 

21 games on the computers. People get on the computers 

2.c for hours at a time doing nonsense . That ' s taking up 

2 electricity where again why do yo u need a ll this 

119-5-0SI 

ICont'd I 

2 4 cancer in your I not that young -6~- ~H~1 

electricity? It coul d be causing 

2 :' c hildren . 

(202) 234-4433 

I am not t h a t old but I ' m 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-102

1 

1 

1 

1 

1 

1 

1 

2 

2 

2 

42 

1 but I hate to tell you I have so many friends a nd 

c oworkers and people that are o n l y 35 , 40 , 50 years 

old, cancer . And why? We have to stop and think . Go 

home , don ' t j ust always , you know, just go watch TV 

and get on your computer. 

doi ng to ourselves, o ur 

grandchil dren . 

Stop and think what we ' re .- 'f-_-:::-_:-H:-:-H-:-~I 

Cont'd bodies, our children, our r-----~ 

Thi s is agai n , t his l i censing renewal is 

comi ng down t o human lives, the qualit y o f our lives. 

Again , why all t his cancer? Mi crowaves and 

electri cit y . So I won 't go on and on, but I just 

t hi nk us a s a group can ' t just all be just compla i ning 

about the power companies, we are the o nes using t he 

electrici ty. That ' s all I ' m saying . Maybe we should 

cut back and we won ' t need powe r p lants. Thank you . 

(Appl a use) 

FACILITATOR BARKLEY : Thank you, 

Cat h erine . The next three people I ' d l ike to call 

would be Jeffrey Nort o n of the P. Energy Alliance , 

the n Bi ll Ma g uire and then fi na lly Lorra ine Ruppe . 

Mr. Norton? 

MR . NORTON : Good evening . My name is 

J effrey Nort o n and I ' m here to represen t the 

Pennsylvania Energy Al liance which is an i ndependent 

2 grassroots diverse organization made up of community 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-103

43 

1 leaders a nd org a ni zati o n s who promote nuclear power as 

a c l ean, safe , reliable and aff ord a b le source of 

p owe r . I ' m goi ng t o be ma king essential l y five po ints 

i n s u ppo rt o f l icens e renewal for Limerick Generating 

Stat ions and they are that, number o ne , n uclear e nergy 

lowers e l ect ricity p r i ces, i t pro t ects our env ironment 

against greenhouse gas e s , it strength ens our l ocal 

economi es and it is safe . 

Wi t h regard t o my firs t po i nt in lowe r ing 

elec tri c i t y prices the Limerick Ge ne r ating St atio n has 

r ed u ced wholesale energy co sts i n Penn s y l vania by $880 

mi llion i n 2 010 thus l owering elec tri c ity pri c es f o r 

all c onsume rs. I t operates aro u nd t he c l o ck t he reby 

stabili zi ng t h e n ati o n ' s e l e c tricity dis t ributi on 

system a nd t he electricity ma rketp l a ce . The ave r age 

electricity prod ucti on costs at nuc lear p l ants have 

actually decl i ned more than 30 percent i n the past 1 0 

years due to various effi ciencies . Nuc l ear p owe r is 

c heaper t o produce than other f orms of e l ectricity 

generation such as coal and natura l gas, and helps 

mode r ate t he pri ce of e l ectri c i t y for consume r s . 

My next poi nt is that Limeri ck Generat ing 

Station and nucl ear plants strength en our local 

economies and it is a valu a b le economic driver f or the 

Commonwea lth o f Penn syl vani a . Limerick Generating 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

20-1-SR I 
Appendix A

A-104

44 

1 Station contributes $113 mi l l ion a nnua l ly in direct 

economic contributions to the Penn sylv ania economy 

through v arious e mployee wages and salaries, purchase 

o f goods and services from other Pennsylvania 

businesses and i n property tax payments to the l ocal 

governments. Limeri ck Generating Station also 

contributes generously as we ' v e also heard and i n fa c t 

1 

t emporary contract employees during a nnual refueli ng 

1 o utages . A s i gnificant percent age of the cur rent 

1 n uclear plant workforce wi ll reach retirement age i n 

t he next 10 years crea ting a demand for high- paying 

1 jobs in the nuc lear industry. Yes , Lime r ick 

1 Generating Stati on is one of Pennsyl vania ' s most 

valuable e conomic and energy assets and the 

1 commonwea lth should embrace i t . 

1 My third point is that nuclear energy 

2 protects our environment from greenhouse gases and 

r educes the need to generate e l ectri c i ty from fossi l 

2 fuels . If Limerick Generating Station were reti red 

2 from service replacing the electricity wo uld require 

increased natural gas- fired or coal- fired generation. 

2 Nuclear energy is the nation ' s largest source of 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-105

1 

45 

carbon- free electricity a nd i s critical to our 

nation ' s e nvironmental , security and energy goals. 

My next poi nt is that n uclear energy is 

safe . It ' s a lwa ys on , it ' s stable, it ' s a r e liable 

source o f electricity and t he s t a tio n here a t Limerick 

h as been b uilt with multiple redundant sa f e ty l ayers. 

And t he workforce is committed t o b est practice s and 

c ontinuous i mprovement . I t is a lso i mp o rtant f or our 

nation ' s qu est t o be e n ergy- independent . According t o 

t he Bureau o f Labo r St atist ics it ' s safer t o work a t a 

n uc lear p l a n t than in industries such as 

manu fact u r i ng , rea l estate and fi n ance . And acc ording 

t o the Department o f Energy a p erson r e c e i v es more 

radiation expo sure flyi ng f r om Bal t imore t o Los 

Angeles t ha n by standi ng near a nucl ear p lant 24 hours 

for a year . 

On a pe rsonal no te I ' ve bee n i nside 

Limerick Generating Sta tio n s evera l times . I ' ve also 

lived within 3 0 mi les with my f our boys and wife next 

to the Limerick Generating Station a nd a l so Three Mile 

Isl and . I fee l s a fe , secu re and comfort able . Tha t is 

why I ' m in suppo rt o f the re - licensing o f the Limerick 

Generatin g Station . Thank you very much . 

(App l a us e ) 

FACILITATOR BARKLEY: Tha nk you . Mr . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

20-1-SR I 

Cont;'d 
Appendix A

A-106

5 4 

1 three people I ' ll call are Donna Cuthb ert, fo l lowed by 

Mike Gallag her and then f ollowed by Dr . Fred Winter. 

Okay, Don na . 

MS . CUTHBERT : You k now, after heari ng 

some of these gentleme n speak t o night I f eel like I ' m 

l i v i ng i n f antasy land . For some b ody t o get up here 

a nd actually say t hat there ' s no a dverse i mpacts f rom 

Li meri ck n uclear power p l ant i s insani t y . I t is 

u nbe lie v a b l e . I have s pent t he last 1 1 year s 

1 r evi ewi ng per mit s from Li meri c k nuclea r powe r plan t. 

They are a ma jor a i r po l l ut e r under the Clean Air Act 

1 a nd t o s ay t hey ' r e not doi ng it anymor e , the y jus t 

1 a sked fo r t he cond i t i ons t h at wou l d allow an eig h t fo l d 

increase i n dange rous air pollut i o n that act ua lly i s 

1 claimed t o ki l l people , thou s a nds of deaths pe r yea r . 

1 And t hey asked f or a n e i ght fo ld i ncrease . 

As a matter of f act , the se are a ll the a i r 

1 p o l luti on sources and the pollutants they list in 

1 the i r own permit . I f yo u add that t o all t he 

2 radi ation emissi ons there ' s a b road range of 

r adi o nuclides . For some bod y t o just c l aim that i t ' s 

2 onl y tri tium going into t he water is insanity . It ' s 

2 unbelievable what they exp ect people to b elieve . I 

encourage everybody to go back to the table we have 

2 a nd take a good look at that Schu ylkill Ri ver board . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

1-22-AM I 
Appendix A

A-107

1 

55 

Th e y are d estroy i ng t h e Schuyl kill Ri ver. Ther e was 

never enou gh water in the Schuylkill River to sustain 

this n uclear p lant fro m the very beginni ng a nd now 

we ' re seeing the consequences of that a nd t h e y put 

more and more p oll uti on in it. They want to pump mine 

water in t o suppl e ment t he flow f or Limeri ck . I t's 

c o ntami nated and they d on ' t f ilter it . And t hey ' re 

act u ally asking f o r a huge , f ou r t i mes Safe Dri nki ng 

Wa t er standa rd i n c rease i n t o tal dissolved s o lids 

wh i ch carry a l ot o f t o x i c p o llut a nts . So t hey put 

radi a tio n int o the r i ver 24 hou r s a day, 365 day s a 

year, and now t h ey ' re aski ng f o r these h uge i ncreases 

and people h a v e t h e nerve t o get up he r e and say that 

t hey h ave no e nv iro nme ntal i mpact s . Frankly I ' ve had 

enough o f t his deception a t the expense of publ ic 

.l T 

The facts s h ow, when we looked at Ex elon ' s 

thi ng f o r envi ronmen t al h a rms they say t h ey wer e clean 

ene r gy . Th e facts s how Limerick isn ' t c lean, it i s 

ilthy . It ' s not s afe , it ' s a ticking time bomb . And 

nucl ear power, they say i t ' s a l ways o n . Th at ' s not 

rue either as evid enced by shutdowns , some fo r long 

p eriod s caused by earth quakes , t ornadoes , h urricanes, 

-Fi res, h ea t and dro ught and mo r e . It clearly isn ' t 

always o n i n Japa n . So when you t ake a l l o f this 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

1-23-SW I 

1-c--:!-:--:~ 1-24-PA I 
Appendix A

A-108

56 

1 toge ther and you look at all the ways that they 

p o llute o ur environment with radiation and all the 

other toxics, every day Limerick operates o ur children 

face more risk. And that ' s what i t ' s all about . It ' s 

about the health of o ur region . 

The sooner t h is place closes the bett er 

o ff we ' ll all be . Even if you l oo k at i nfant 

mort ality rates we have higher inf ant mortali ty rat es 

and neonata l mo r t a l i t y rates far above s t ate averages 

and even above Phi ladelphi a and Reading , and we ' ve had 

t hese for qu i te awhile . The fact is when babies are r-:1--'-2':c5::-_-:-H:-:-H.,-,I 

t he most vulnerable i n t he womb what e l se would we 

expe ct ? And by t he way, fo r those of you who have 

bee n sayi ng t hat ACE data is anecdotal t oday I have 

news for you . This infant mortal i ty report for 

example is state data reported by EPA in 2003 . Every 

cancer stati s t ic that you see back there is based on 

Pennsylva nia Cancer Registry s tatistics or CDC 

statistics. So it is not anecdotal , those are the 

cancer increases, those are the cancer above the 

nati onal average that have h a ppened here s i nce 

Limerick started operating . That is a fact . 

So it ' s not anecdotal and t he fact of the 

matter is I thought this was about the environment but 

apparently it ' s about money . So I decided that 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-109

57 

1 b etween the sessio ns I was go i ng to cha nge t hings 

around a l itt le bit . I coul d talk abo ut t he 

e nv i ronment a l impacts o f this place f or a whole week 

it ' s so b a d . And I ' ve got all t h e d ocument s i n our 

o ffice to prov e i t . Let ' s t a lk a bo ut , l et ' s t ake a 

mi nute now t hough a nd we ' re goi ng to talk a bout t he 

cost . What i s thi s p lace act ua lly costing us? Let ' s 

just t hi n k about c ancer f or exa mp le . We h ave s o many 

c a ncer s above t he n ational av e r a g e . Childhood c a ncer , 

92 . 5 perc ent h i g he r than t he nat i o na l a v e r a g e . Think 

about tha t . We tra c k t h e cost o f one child with 

1-26-HH I 

c ancer diag no sed a t s ix mo nths t o t wo years a nd up 

unt i l t hat time i t was $ 2 . 2 mi llion . How many more 

k i ds hav e tha t a bove the nat iona l ave r a ge? Co s t that 

o ut and how ma n y o t h er c a nc ers a r e a bove the na tiona l 

average ? Yo u d o t he ma t h . Figure t h a t ou t . 

How abo u t the custome rs t h a t paid I 

hea r them t al k a bo ut how g reat the costs are for 

Limerick . We pa id f or Limeri c k from 1 98 5 t o 2 010 i n 1-.L......--::-~ 

1-21-os 1 

o u r electri c b i lls. And i n f act the e l ectric that was 

s uppos ed to b e too cheap t o me t e r t u r n e d o ut t o be 55 

p ercent above the nation a l average by 1 997 . So that ' s 

how c heap Limerick electric is . 

Then you ta ke the property t axes . They 

t r i e d to get zero f or their p roperty t a x es by t he e nd 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 

1-28-SE I 
Appendix A

A-110

5 8 

1 o f the ' 90s a nd d i dn ' t pa y any p r operty taxes until 

the ea rly 2000s at which time they paid $3 million 1-:-'=~':="1 

1-28-SE I 

i n s t ead of the $17 million they were supposed to pay. Con'W 

So when you think about that no wonder Exelon ' s 

willing to throw a r o und a coupl e mi l lion i n t he 

communit y . They owe this community a l ot more than 

what t hev ' re aivina o u t . 

(Applause) 

MS . RUPPE : So t hen t here ' s t he cost f o r 

t he pollution t hey ' re put t i ng i n t h e river . Th e y ' re 

aski ng f o r i ncreases i n p o llutio n . They want t o put 

more mi n e water i n . They want t o i ncrease the t o t a l 

dissolved sal ts. Tha t's goi ng t o c o st wa ter t reatment 

a l o t o f mo ney to try t o f or extra .....,_......,,.......,,..,...,..,., 

4-10-SW I systems 

treatment f or t h a t . I t can even break down their 

e qui pment , some o f the stuff that ' s comi ng o ut o f t he 

mi n es. And whe n you thi n k abo ut it who a c tually 

ultimately pays that cost? We d o . We pay for 

increased costs f or our wa t er because t he y ' re having 

to do that at the water treatment s ystems . And it 

see ms to me that if you rea lly take a good l ook a t 

thi ngs Limerick has got to be the ma j or cause for t he 

radiation i n Philad elphi a ' s water . 

So a l l i n all taken as a whole t his place 

h as u np recede nted e nvironme ntal h arms . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 

The re is n o 

WW'W.nealrgross.com 
Appendix A

A-111

59 

1 question a bout that . Anybody t hat doesn ' t believe it 

c ome look at the permits with me and I ' l l show you 

exactly what ' s going on . I i nvi te a nyb od y to d o that. 

And t he one t h i ng t hat ' s really impo r tant 

is that NRC a nd the nuclear i ndustry are claiming that 4-11-08 1 

age is no i ssue whi le at t he same t ime t hey admit that 

s ome parts are t oo b ig and too expensive t o replace . 

I f rankly am really conce rned about NRC accommodati ng 

the nuclear i ndustry wi t h weakened regulatio ns, lax 

1 e nfo rceme n t, n e g l ige nce a nd unsubsta ntiated d e nials . 4-12-081 

I t ' s h a p pened right h ere e v en wi th t heir fire sa fet y 

1 r egulat ions t hat are -- we ' re o n wea kened fire safet y 

1 regulat ions eve n though we know t hat t ha t can 

eventually lead to a meltdown . I know my time ' s up . 

1 Thank you. 

1 (Ap p l a use) 

FACILITATOR BARKLEY : Thank you, Do nna . 

1 Mike? 

1 MR . GALLAGHER: Okay, good evening . My 

2 name ' s Mike Gallagher and I ' m vice presid ent of 

license r enewal f or Exe lon . I have the overal l 

2 r esponsibili ty f or t he Lime rick l i cense renewal 

2 application . Exelon has a great d ea l of experience in 

l i cense r enewa l . We ' ve obtained renewed lice nses for 

2 the Peach Bottom and TMI p l ants i n Pennsylvania , a l so 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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68 

1 FACILITATOR BARKLEY : We have an 

i nspect ion ongoing at t h a t point right now regarding 

the North Anna facil ity . So yes, i t d id experience an 

earthq uake b eyond its ori g i nal desi gn . So f a r t he 

i nspect ions have revea l ed no -- mi ni mal damage . I ' v e 

o nl y heard of one p i ece o f equipme nt that experi e nced 

even v i s i b l e signs o f problems . But t h e overa ll 

a na l ysis, this is continui ng a nd t he l i cen see has t o 

have p e rmissi o n from us t o r est a rt a f ter a n e x t e nsive 

1 i nspec t ion . 

MR . ELY: My conce rn i s t hat t his ha stened 

1 l i cens e r e newa l process is inapprop r iate f o r 

1 eng i neeri ng reasons. I worked i n a v a r iety of 

d i f f e r e nt a r eas in the construc t ion of t hat power 

1 plant and t here we re conti n ual devi ati ons tha t were 

1 pro v i d ed, whether i t was in- storage mai nt ena nce 

moni torin g of t he condi t i on o f t he compone nts that 

1 were used to the actual constru cti on of tha t p lant . I 

1 coul d cite you several examples . 

2 What I would l ike to as k of the pub lic is 

tha t the people that had worked a t t hat nuclea r power 

2 p lant take a look at this l icensing renewal and 

2 understand t hat they need to review those fail u res and 

those devi ations that were provided to go a head wit h 

2 the constructi on of t hat p l a nt with non- con forma nces 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

21-1-0S I 
Appendix A

A-113

69 

1 that were reviewed , b u t not reviewed in ligh t of what 

we understand and know today about earthquakes or 

other anomalies. We need to have enough time to make 

the evaluation on those deviations . The cooling 

pools. The fue l pool girders t h at are placed there . 

There a r e rebar concrete reinforced supports where a 

q uality engineer, he was supposed to be accepting t he 

very highest grad e o f concr e t e t o be placed i n a 36-

hour pour there and he didn ' t pay attention . And t he 

1 cofferdam wa s being bui lt down i n t he river and up 

come s this sand mi x wit h a very low strengt h and get s 

1 p umped up i n t o those fuel pool g i rders in a l ayer a nd 

1 t he e ngi nee r sai d well, boy, t hat was a t erri ble 

mi stake , but it ' 11 be okay . We need to go back and 

1 t ake a look at all of tho se mist akes and make sure 

1 t hat they ' re not writt en off because a layer i n a 

structure under load cau sed by an earthquake , that ' s 

1 an issue . It might not be a n issue for the strength 

1 o f the fue l pool girders t o support those f ue l pools 

2 that when we see them i n Japan and they catch fire 

b ecause t hey ' r e ex tremely hot and you need to address 

2 that . I was o n that po ur b u t I wasn ' t the engineer 

2 that made t h at error, but t here ' s a number of e rrors 

that we r e made . And I don ' t see or und erstand that 

2 the NRC or the review or the licensing application is 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

21 -1-0S I 

Cont'd 
Appendix A

A-114

70 

1 t aking a look a t those failures and those errors a nd 

21-1-0S I addressing them in light o f the knowledge that we have Cont'd 

t oday. 

Some people don ' t understand about 

radiation and I read when t he Japanese thing occurred 

and I heard on the news a radiologist t alking about 

o h , the radiation is s uch a low amount . It really 

isn ' t the l ow amount o f radi ation exposure that we get 

i nc i dentally i n standing next to a nuclear power 

plant. It ' s three t en-thousandt hs o f a gram of 

plutoni um that is death f or you if you breathe that 

dust p article . It ' s almost certain death . And t he 

problem becomes you can ' t have -- and it' s not go i ng 

t o be a nuclear bomb. It's goi ng to cat ch on fire if 

the f uel pool girders were to fa i l and you ' ll have a 

cloud of a material that in and of itself you might 

not have radiation exposure to it but that particle 

when it deposits i tself can be an issue much the same 

as f l uoride i s what causes thyroid cancer when it ' s a 

radioactive fluoride . That ' s why we ' re very careful 

in b uildi ng a pl ant wi th no Tefl o n and no f l uoride 

components . 

So we need to pay attention to some of 

that engineering and I ' m not certain that that ' s being 

done . 

(202) 234-4433 

I ' d like t o see an agency or for somebody t o 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

21 -2-HH I 
Appendix A

A-115

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1 

1 

1 

1 

1 

1 

2 

2 

2 

71 

1 contact me if they know ab o ut a variety o f different 

flaws that they saw during the construction . And my 

email a ddress is asqchair@yahoo . com. Yes , I will be 

the chair o f t h e Philadelphia section of the Ame rican 

Society f or Quality comi ng up and I ' ve been past chair 

i n t he past s o yes , I ' m very quality- orient ed a nd I ' d 

appreci ate any f eedback f rom people that have issues 

with t hat constr ucti o n . Thank you . 

(Ap p lause) 

FACILITATOR BARKLEY: Okay . Th ank you, 

Da n . Jim Beckerman? 

MR . BECKERMAN : Good eveni ng . My name is 

Jay Beckerman . I ' m a resident of Pho enixvil l e . I 

found out a bo ut this meeting because I s can a l ot of 

newspaper websites. I fou nd t he noti ce of the meeting 

on t he West Chester Daily Local website . Di d n ' t nd ~~ 

22-1-LR I 

it in the Phoenixvill e paper , d i dn ' t see it i n the 

Philadelphi a newspaper, didn ' t hear about it on any of 

the local radio stat i ons, didn ' t hear a bout it on 

cabl e , didn ' t hear about i t o n any of t he television. 

Once a month , what i s i t the f irst Tuesday 

about 2 : 00 I hear the siren that we all hear. What 

should happen in terms of people getting notice is 

everybody who ' s within t h e plume a rea should something 

2 happen at Limer i ck should fi nd out about this meeting 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-116

72 

1 and I seriously doubt that that actually h appened . I 

thi nk it was pure accident t ha t I f o und it. Some thing 

as serious as license renewa l s hould get the same kind 

o f o utreach that occurs when Limerick does what it 

s hould whi c h is to mail out every year o r t wo t o all 

o f t he possibly affected homes t he maps and t he 

no tificati o ns of how do you eva cuate . I f you ' re go ing 

t o renew a plant which happens once every 20 years I 

don ' t u nderstand why t he NRC d o esn 't requi re the same 

1 k i nd of o ut rea c h p ub l ic notifi cation so peopl e get a 

chance t o come to one - time meet ings like t his. I 

1 t hi nk that i s a basi c f l aw i n t he NRC ' s l i censing a nd 

1 re- licensi ng procedure and I thi n k i t should address 

t hat . 

1 The slide behind me documents exactly t wo 

1 l i braries that the docume nts are goi ng to go i n . Why 

not in my l i brary i n Pho e nixville? Why not in 

1 Montgomery County and No rrist own and a ll of the other 

1 public libraries that are in a reas that c a n be 

2 affected by the plume should something happen here? 

Why are the doc umen ts i n s uc h a r estri cted a r ea? 

2 I ' d like to switch a l ittle bit. I ' ve 

2 b een researching , I didn ' t e ven know about t h is ACE 

o rgani zati o n . Glad t o find it. I ' ve b een researching 

2 o n my own information about nuclear power plants and 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

22-2-LR I 

22-3-LR I 
Appendix A

A-117

1 

73 

their risks f o r quite awhile . An organization I ran 

across publi s hed this book t itled Ins u r mount able 

Risks . The organization is c a lled t he I nstit ute for 

Energy and Environment a l Research . I t ' s a n a maz ingly 

well- resea rched book . I d o ubt very many peop le have 

r ead it but you should . This organization is a t l east 

as int erested i n a l ternat ive e nergy s ources as it is 

in h avi ng put the e f fort in to d ocument what are t he 

problems with nuclea r power engineeri ng- wise . The man 

who ' s head of this o rganizat i o n i s a n uclear 

sci entist, a guy named Arj u n Makhij ani . He ' s a PhD 

n uc lear s c ient ist . These are f irst-class researchers, 

t hi s i s PhD- l evel stuff wri t ten for popular 

c onsump tio n . So I ' 11 be glad t o make mo re detail 

about t he book avail able to anybody who wants to know. 

A few q uestions I have , o ne t hat I' ve been 

thi nki ng abou t for a l ong t ime . I wonder how many 

people here are awa r e of something cal l ed t he Price 

Anderson Nuclear Industries Indemn ity Ac t . Who knows 

a bout that? The title alone should give you some 

p ause . Why do we need a n ucl ear i ndustr ies i ndemni ty 

act? Wha t d oes i t do ? What it does i s it puts a 

ceil i ng of a few h undred mill i o n dollars on the 

l i a b ility that nuclear power plant owners have f or the 

d amage t hei r p lants wo uld cause . I t ' s basically a 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

22-4-0S I 
Appendix A

A-118

1 

74 

s cneme , u1ey pay ln LO a poo.L . Tile prou.Lem lS LilaL 

c e ili ng was set a v ery long time ago . It ' s tota lly 

unrealistic in terms o f the risk in just the value of 22-4-0S I 

Cont'd 

h ouses i n a r eas that are covered by a p lant like this. 

When this plant was plann ed t h e populatio n in the 

area that its plume woul d cover probably wasn ' t 20 

percent of what the p opulatio n i s now . Th at i s I 

t h i nk a va l id environment al concern . The environment 

in which t h i s pl a nt operat es h as chan ged bec ause of 

in- migrati o n , populat ion i ncrease for a l l s o r t s of 

reasons . Part of that ' s been discussed toni ght in 22-5-0S I 

t erms o f evacuatio n rout es, would you be able t o get 

people out were there an accident . The roads haven 't 

changed very mu ch, the p o pulati on h as. That I think 

i s a va l i d e nvironmental c o ncern t hat surely o ug h t t o 

be addressed . 

The q u estion I ask about the money 

l i a bility is let ' s just go back to the Price 

Anderson Act . Th e fact is t hat the n uclear indus try 

d oes not pay market rates for insurance to cover it 

for the l iabi l i t i es . This congressi ona l a ct f r om way 22-6-0S I 

b ack in the 1960s eli min ates t h at need . Back then t he 

insurance i ndu stry did n ' t have the research to put a 

pri ce on what should the Limericks of the world have 

t o pay for a liability p o licy. I t hink there ' s plenty 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-119

1 

~--------------------5 I 

o f insurance industry experience now . So my questi on 

2~2--=.....,=-"'=""q 

would b e if n uclear plants are so safe why do we need 

the Price Anderson Act ? 

(Applause) 

MR . BECKERMAN : I l ist e n ed , I ' m going t o 

switch subjects aga in . I l ist ened to Mr . Gallagher 

and I h eard s omething I really didn ' t expect t o hear. 

He said t hat their studi es said t hat t his plant is 

now safe to run for 60 years . That s ounds t o me like 

advanced not ice t o the publi c t hat t his isn ' t t he 

first renewal t h e y ' re goi ng t o ask for on t h i s plant. 

Mr . Ga l l agher , are you goi ng to ask f or another one 

20 years from now? 

FACILITATOR BARKLEY : We have n ' t had a n y 

lice nsee at this point in t ime as k f or s omething 

beyond that . 

MR . BECKERMAN: Yo u did n ' t make t h e 

statement . Mr . Ga l lagher did . 

FACILITATOR BARKLEY : I know and I ' m not 

going to have him add r ess t h is from the audi e nce . 

Thi s i s a meeting wi th us . 

MR . BECKERMAN: And I would l ike t o 

finally address an issue t h at the speake r o n t he cell 

phone b rought up . He tal ked a bo u t embr i ttlemen t of 

concrete o v er t he lifet ime so f ar o f the nuclear 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

Cont'd I 

22-7-0SI 
Appendix A

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1 

1 

1 

1 

1 

1 

1 

2 

2 

2 

7 6 

r eactor c ontainment vessel . That ' s a n int ern al 

e nv ironmental matt er. I d on ' t know i f it' s q uite i n 

t he scop e o f what the NRC plans t o tal k a bo ut or pl a n s 

t o l ook a t , b ut some thing t ha t I have not r ead about 

at a l l is an NRC requiremen t f or d estructive t esting . 

For i n s t ance , i f you wa n t t o know what a tree l ooks 

like on the i n s ide you p ut a borehol e i n it and you 

p ul l a core sample o u t a nd you f i nd out wha t t h a t tree 

looks like on the insi d e. I f a n eng i neer wa n ts t o 

know wha t i s t he q ua lit y of t he c oncret e t h a t was 

poured for a r o ad -- I used to wor k f o r Flo r i da 

Department o f Transpo r t ati o n t h e y bo re o u t a sample 

nd t h en you t ake a look a t it . Wha t I haven 't heard 

n yt hi ng a bou t exc ep t gen e ralizations is has anybody 

on e a n y destructi ve eve n boreho l e t esti ng of these 

ontainment v ess e ls a nd t heir s u pport pourings t o f i nd 

22-7-0S I 

Con'td 

put ha s there b e e n i n fact a ny det e rior ati on of t h e 22-8-0S I 

onc r e t e , t he r e ba r and anything e l se t hat went in 

he r e . The stu f f that ' s b u r i ed i n the concret e , t he 

lvi re , all of t hose things that are buried i n the 

onc r e t e . I f y o u ha v e n ' t bothe r ed t o ope n t hat stu ff 

p s i nce the plant was b ui lt how o n earth do yo u know 

lvhat condi tion i t ' s in? Shoul dn ' t that be a 

equirement to d o some d estructi ve , open t h e bottom 

2 est i ng , go all the way t h rough and make s u r e wha t you 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 

1 

1 

1 

1 

1 

2 

2 

2 

77 

1 thi nk is there is what ' s t he re and i n the conditi on 

that it 

years? 

should be i n to l ast f or another 20 or 40 22-a-osl 

Cont'd 

So t hese are q u est ions that I ' d like t he NRC 

t o go into . I thank y ou very much f or lis t ening . 

Overall it ' s been a very i n formative presentat i o n by 

b o t h t he proponents and people who have questions and 

I thank you f o r the opport u nity. I would l i ke to s ee 

a mee ting like thi s occur at a bigger venue wi t h more 

notice . An example woul d be, as I ' ve dis cussed with 

Ms . Regner is it? 

FACILITATOR BARKLEY: Regner, y es . 

MR . BECKERMAN : I didn 't have h er name 

c orrect. Th e Phil ade l phia Expo Cent er would be mo re 

central t o where the p lume area for this p lant is. 

It 1 s right off 422 . Th is i s not h ard t o get t o , 

t hat ' s not hard t o get to . It' s much mo re i n t he 

cent e r o f the popu lation . Thank you v ery muc h . 

(Appla us e) 

FACILITATOR BARKLEY : Okay, thank you . 

Mr . Cu thb ert? Aga i n , fol l owing Mr . Cuthbert ' s remarks 

i t ' l l b e J i m De rr t o wrap up the eveni ng . 

DR . CUTHBERT : Good eveni ng . My name is 

Dr . Lewis Cuthbert . I ' m the president of ACE , the 

Alliance for a Clean Environment . And my comment s 

2 this e v ening are going to di f f er from this afternoon 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

A-122

78 

1 b ecause t he y ' re go ing t o be focusing o n as a g eneral 

t opic documen ted evidence . We ' ve heard a lot of 

assertions , assumptions and c l aims throughout the day 

many of which would be v ery d i fficult t o s ubs t antia t e 

i n o ur exp eri ence . Based o n a n 1 1- y ear investigati o n 

conduct ed by t he All iance f or a Clean Environment we 

have f o rmed a conclusi on that we are pre senting t o the 

Nuclear Reg ul a t ory Commi ssion today and t hat is very 

simply that Limerick nuclear power plant must be 

1 closed by t he NRC, no t re- l i censed until 20 4 9 . And 

t hat ' s based o n a s ubstantial b o dy o f evidence i n 

1 t erms of d o cument ed e nvironmental harms, threats and 

1 ris k s that have i n fact g o t t en into ou r air , o ur 

water, our s o il, our f ood, o ur mi l k and o ur children . 

1 The evi de nce is no t refu table . 

1 So I ' ll be presenting as par t of my 

remarks t o night what I ' m calling a sho r t list o f 1 4 

1 r easons why the NRC may feel free t o wit h more than 

1 a d equate j ustifi cation d eny this permit . And I ' m 

2 g o i ng to categori ze each of them v e ry briefly without 

any furt he r d escri p tio n or ana l ysi s . The evi d ence 

2 comes f rom a variety of permits, o f ficial records and 

2 r e po r ts, and Exelon ' s own renewal application whic h is 

s i zabl e by the ir own admission and i n o ur experience 

2 i n taking a look at it . 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

j-,-J~=-=,., 

1-29-0R I 
Appendix A

A-123

79 

1 The 14 i tems any o f which i n our j udgment 

should be adequate a nd sufficient t o d eny this permit 

enewa l i nc lude , n umber 1 , radi ation into air a nd 1-30-RW I 

"ater from rou t ine and accid ental e missions. Number 

2 , major a i r pollution und er healt h - based stand ard s of 

the Cl ean Air Act . A Title 5 permit b e i ng issued t o 

1-31-AM I 

thi s fa c i l i t y means b y d e f initio n that they a r e a 

maj or air po l lut er under the federa l Clean Air Act . 

Number 3 , Schuyl kill Ri v e r dep l e t ion a nd ma jor 

1-32-SW I 

d r i nki ng water c o nt a mination . Ke ep i n mind this is a 

vit a l drinki ng wa ter s o u rce f o r nearly 2 mill i on 

people from here t o Phil adelphia . Number 4 

radio acti v e gro u ndwat er c o nt ami n ation . Number s , 1-33-GW I 

radlatlon reportlng level s lncreased a ramatlCallY 

after t he Fukushima Japan disast e r . Number 6 , 

1-34-RW I 

documen t ed a larmi ng cancer increases e s pecially i n our 

1-35-HH I 

children since Limerick started operating . Number 7 , 

deadly h i g h - level radioactive wastes t hat are packed 

1-36-RW I 

in v u l nerabl e fuel pools on t his sit e a nd t hey are in 

fact unprotected . The y are a bove ground and 

unprotected . Numbe r 8 , l a x fire saf e t y r egul a tions 1-37-0S I 

and multipl e violat ions. Numbe r 9 , accidents and 

leaks from corroding , d eteriorating equipme n t p lus 

1-38-0S I 

mil es o f b uried pipes and cab les. Many probl ems and 

shu tdowns have already occurred a t t his fac i l ity in 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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1 

80 1 

r':-1-:-3:-::--:-0::-::8~1 

Cont'd 

its first 26 years of operation . They are a matter of 

record . Number 10, increased risk of meltdowns from 

more frequent and stronger earthquakes and other 1-39-o8 1 

nat u ral disasters such as tornadoes and floods, not t o 

mention mechanical failures . Number 11 , threats from 

unguarded terrorist attacks with p lanes and missiles 

and a new threat, cyber attacks. Fuel pool are 1-40-081 

vul nerable to att ack . 

Number 1 2 , one that I think probably 

should jump to the head of t he list for t he NRC based 

o n a lot of comments from a l o t o f o t her ana l y s ts and 

elected official s , the need f or an updated evacuation 

plan and i ncreased EPZ , a 10- mile radius . This p lan 

is serio usly o utdated . It is by many expert ' s 1-41-08 1 

observations fatally f lawed . There wi ll be no 

evacuation i n the eve n t of a worst case scenari o . 

Several people spoke t o that t his evening . The 

popul ation in this area has increased more than 180 

percent since 1980 to 2010 , U. S . Census data . Updates 

are obviously needed and the y should be reasonable , 

comprehensi ve , detailed and accommodate a l l of the 

demographics fr om 1 985 to today and from today until 

as far o u t as the NRC is willing to license this 

facility. 

I Number 13 , i ncreased cost to t he public. 1-42-08 1 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON , D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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81 

1 We ' v e heard a little bit a b out this t h i s e v e ning , more 

cancers , mo r e i l l n esses, mo r e eme rge n c y r oom v isits, 

mo r e h o spitaliza t ion fr om i n c r eas e d PM- 1 0 . Ma ssive 

111-42-0S I r esea r ch on wha t pa r t iculat e ma t t e r i n t e rms o f PM- 10 IICont'd 

does t o human b eings . And t here a re a f ew oth e r 

thi ngs that c o ntribute t o tho s e visi t s . The c o sts a re 

astro nomi c a l . One case that Donn a ment i one d , $2 . 2 

million f o r a c h ildhood c a n cer case . You d o t he math . 

And nu mbe r 14 , the last i tem o n my list. 

1 We h ave had 2 6 years o f i nsults to o ur environme n t, 

and I choose t h at wo rd p urpo sel y , insul ts to 1-43-AL I o u r 'r-""T""----' 

1 enviro nmen t a nd c o s t l y n uclear power . We can replace 

1 it with sa f e , c l ea n , re n ewable e n ergy b e f ore 2 029 . 

That is a matter o f s c i e n tif i c fact . 

1 It is a sci e n tific certain ty that h a rms , 

1 thr eats and ris ks t o o ur e nvironment and t o o ur 

communi ty wi l l increase conti nuo usly d a ily until 

1 Limerick ' s c u r r e nt operating lic enses exp ire in 2 029 . 

1 It would be both u n e t h i c a l and i r re spon sibl e fo r t he 

2 NRC to cavali e r l y a pprov e a l i c e n se ren ewa l without 

the most r i go rous r evi ew and j ustifi cation i n the 

2 his t ory of this ag ency . NRC, you ha v e a r a r e 

2 opp o r tuni t y b efore y o u t h a t most peopl e and a g enci e s 

n e v e r are affo rded . I t ' s cal led a d o - over , a chan ce 

2 t o c orrect a l itany of mi stakes and errors associa ted 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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8 2 

1 with t his f acility and with your agenc y s i n ce 1985 . 

Twentieth cent ury techno l ogy a nd infrastructure are no 

longer sufficient ly reliable for a n y o f you t o assure 

us t h at t here is nothing t o fear a nd no thi ng about 

which t o b e con cerned . De n ial of d ocument e d evidence 

i s no longer an option . We ' ll b e sub mitting 

addit i onal packet s of research d o cumentation and 

evi dence tonight a l ong with my comments whi c h will 

comp l iment what I did earli er t oday . The ma jor 

1 categories t h at you ' ll be getting f or additiona l 

r eading and review, me ltdown thr eats, evacuation 

1 plans , Ex elon ' s inaccu rat e a nd un substan tiated c laims 

1 and a cri t i cism o f the NRC ' s oversi g ht t rac k record i n 

t hi s c ommu n i ty. Th ank yo u very much and please accept 

1 this for review. 

1 (Appla us e) 

FACILITATOR BARKLEY: Okay, t ha nk yo u , I 

1 will . Th ank you . Mr . De r r ? 

1 MR . DERR : Good evening . I t ho ught I 

2 would add some comments just t o make s ure my 

unde rstanding i s t hat t h is is e ssentially the NRC ' s 

2 opportuni ty of listeni ng f or things specifically to be 

2 i nclud ed in the environme n tal site review of the rel i censing . And j ust a few things whi c h are question 

2 marks that l ots o f f ol ks in t he community I think will 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 
Appendix A

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83 

1 b e interested in . Most o f these have b een touched on . 

Mine wat er issue , b etter d efining that 

q uality and fl ow particularly i n light o f t he likely 

pending c hanges in stormwater concerns and regulations 23-1-8VV I 

i n t he area . Ad ding that f low t o t he Schuylkill is 

goi ng t o a f fect a ll t he mun i c ipalities around h ere who 

have t o d eal with sto r mwa t er. 

The emergency p l a nning i s an area which 

needs t o b e seri o usly l ooked a t. Hard and soft 

123-2-08 I 

i nfrast ruc ture on t hat . Hopefully t ha t's s ome t hing 

whi c h is part of t he o ngoing operat ional requiremen t s 

for pe riodic revi ew and update since obvi o usly t his is 

not a stati c environment we l i ve i n . Th at has t o be 

changed on a n o ngoing basi s . And then t o -- I ' m sur e 

hat the generi c plan i ncl ude s a pretty good 

::l i scussion o f f u e l sto rage l ong- term a nd short - term 

::msi t e but c e rtai nly the site- speci fic f u el storage 

onsiderati ons . And I want t o seco nd the comments by 

Mr . Ely o f review o f record s of non- conf ormances and 

anything that was done is part of the i n i tial 

construction record . And basicall y that ' s those 

are the things t hat we ' re going to be looking f or a 

b etter understanding o f . Thank you . 

(Applause) 

FACILITATOR BARKLEY : I did h ave o ne l ast 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRA NSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

23-3-o8 1 

23-4-08 1 
Appendix A

A-128

84 

1 request f o r a n indi vidual to s p eak . She p romis es 

she ' l l o nly b e two minutes so we ' ll have her u p and 

then we ' ll wrap up the meeti ng . Thank you . 

MS . CONFER: Hi , my n a me is Traci Con f er. 

I ' m with Energy Justice Netwo rk . We s upport clean 

e nergy whi c h we do no t believe nu c l ear is . I would 

like t o put our name behind a l l o f Buzz Cu thbe r t ' s 

omments and I want to add t hat I want t h e NRC t o look 

nto potentia l water depletion issues from s hale gas 

1 rac ki ng upriver i n both r i vers . I also thin k t hat it 

would be very prudent t o put a lot of att ention on 

1 t errori st attacks o n t he f u e l poo ls. And those are my 

1 pri ma ry c omments . Th ank you f o r your time . 

(Ap p lause) 

1 FACILI TATOR BARKLEY : Okay, t hank you . 

1 With t hat I'd like t o have Lisa Regner come up f o r a 

mi nute and give clos ing remarks . 

1 MS . REGNER : I j ust wanted t o real quickly 

1 thank our senior reside n t i nspector who came out 

2 t oni ght out of the good ness of her heart . She does 

not g e t pa id for this . Jo, would you mi nd standing 

2 up? 

2 (Applause ) 

MS . REGNER : Thank you . This is one of 

2 the NRC inspectors who works at the plant d a y in and 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com 

24-1-SW I 

24-2-0S I 
Appendix A

A-129

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Dear Ms. Regner: 

Camilla Lange [camillange@verizon.net] 

Monday, September 26, 2011 2:20 AM 

Regner, Lisa 

NRC Public Meeting Feedback 

. g)/le /cfbJ// 

%rJ<_J3f-1 g--

(j) 

I attended the NRC Limerick Generating Station License Renewal public meeting at Sunnybrook Ballroom on 

9/22/11 . I listened attentively to comments from all 15 speakers at the evening session and took into account 

all the pro and con arguments presented. Despite all the reassurances from Exelon representatives about the 

safety and efficacy of the generating station's nuclear power, I have serious reservations and concerns about 

these issues. 

First of all, considering the impact of the outcome to the many area residents, this forum was not widely 

publicized for local citizens to be aware of this important matter and offer feedback. Secondly, it does not 

make sense that Exelon is pursuing renewal for a license that does not expire until 2024. This action seem 

ve remature. 

I will briefly summarize my chief concerns. 

consum 1on eman s. 25_

5_ 

Thank you for arranging the public meetings to discuss this serious matter. I trust you will take my AI ts 

into consideration and urge Exelon to provide other such forums with widespread notification beforehand so 

that more interested citizens can participate. 

Sincerely, 

Camilla Lange 

616 W. Schuylkill Road Apt. 164 

Pottstown, PA 19465 

camilla nge@verizon. net 

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Appendix A

A-130

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Follow Up Flag: 

Flag Status: 

Eric Hamell [stripey7@yahoo.com] 

Wednesday, September 21 , 2011 7:38AM 

Regner, Lisa 

Limerick 

Follow up 

Flagged 

Please do NOT extend the Limerick licenses! 126-1-0R I 

Eric Hamel! 

Philadelphia, PA <6'jd&/~/f 

/ZF/f. 6-9¥-J f" 

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Appendix A

A-131

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Follow Up Flag: 

Flag Status: 

steve furber [ctevewrx@yahoo.com] 

Tuesday, September 20, 2011 4:17 PM 

Regner, Lisa 

Limerack Renewal 

Follow up 

Flagged 

ij&~ ;~ /,/ 

')t?£.5:3~ yr/ 

@ 

Kenewmg Ltmencl<'s license JUSt as controversies are ansmg w1th pushes to move trom dependence on Nuclear ~7_::2 1 

energy is a bold business strategy by them. I don't think this is the right move to make. A long term contract ~ 

will limit any sort of wiggle room to address future issues that may arise. · 

I ask that you please consider the future of our great state. I don't think oil or nuclear energy is the way. I truly 

believe in heart, that in order to protect the health of our population for the future, we must change our ways 

today. 

Sincerely, 

Steven Furber 

J J :_1:1 

c: 

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Appendix A

A-132

RULES . :.J ;/ iECTIVES ~~·-; :..-..~C:H 

PUBLIC SUBMISSION: ~- :~ 71 c; a= ll7 

~;-·.~.---1\ ' i 

Page I of I 

As of: September 27, 2011 

Received: September 22, 2011 

Status: Pending_Post 

Tracking No. 80f27eee 

Comments Due: October 28, 2011 

Submission Type: Web 

Docket: NRC-2011-0166 ,-,, - , · · I .. ,!- 0 

Notice of Receipt and Availability of Application for Renewal of Limerick Generating Station, Units I and 2 

Facility Operating License 

Comment On: NRC-2011-0166-0003 

Exelon Generation Company, LLC; Notice of Intent to Prepare an Environmental Impact Statement and 

Conduct the Scoping Process for Limerick Generating Station, Units 1 and 2 

Document: NRC-2011-0166-DRAFT-0002 

Comment on FR Doc # 2011-21921 

Submitter Information 

,2)::u, J:V /f 

7C.r/L6-5 7-:JF:' 

Name: Charlene Padwomy 

Address: 

Ill 7 Oakdale Dr 0 

Pottstown, pennsyvania, 19464-2782 

General Comment 

Thanks so much, 

Charlene Padworny 

_£-;/{'_.;::: _})5 =- ,& .!::>~ --1 -c:? 3 

~;;//)~f-At.r2.:z.) 

https :1/fdms.erulemaking.net/fdms-web-agency I component/contentstrearner?objectld=0900006480f27 ee... 09/27/20 II 
Appendix A

A-133

-·, 

~U.S.NRC Unired Scares Nucle<lr Rcguhuory <:nmmi.uinn 

Proterting People and the Environment 

LIMERICK GENERATING STATION 

Environmental Scoping Comments 

Division of License Renewal 

NRC-2011-0166 

Written Comment Form 

Must be received on or before October 28, 2011. Please print clearly. 

Name: SW / U /A Po //, C k_ 

Title: JPs t d f IJ t J ~ L.~ <; 1 (b I) .P tJ t rr.. (' 

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City: -~ !7-;--;--/ (:) LV b J State: --LB..L%-'----- Zip Code: Jt/tif 5 .--

Use other side if more space is needed. 

Comment Forms may be mailed to: 

Chief, Rules, Announcements, and Directives Branch 

Mail Stop: lWB-05-801 M 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 ~ 

5 u .U5J..- /Je- v't 'eur~etk 

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Appendix A

A-134

Gallagher, Carol :.; 

From: Joe Roberto Uoe@robertoandassociates.com] 

Wednesday, September 21, 2011 7:20 PM 

·-r,J 

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c:.~ 

.· --: ::- : 

Sent: 

To: 

Cc: 

Regner, Lisa ,... ; ~ } , 1 

Subject: 

Joe Roberto . ~jcil-IL;~ 1/ 

LIMERICK 

4-rX5~1(v Dear NRC: 

First of all, let me ask why the lack of public notice regarding the public hearing to be held for Limerick Licensing 

Extension when in fact the current permit is through 2024 and Exelon is asking for another 20 year extension? Your first 

priority is NOT for the publically traded, for profit company to rush to get this public notice "done" as a requirement to 

extend the permit another 20 years out which is not due to expire for another 10+ years but to rather really solicit input 

from the community and folks impacted. The NRC did not do so. There was one article in the local newspapers stating 

that there would a public session and only saw the actual notice, by virtue of an article in the North Penn Reporter 

yesterday. This is not proper notice in general and not sure NRC did what is required. What is required and what have 

you done? And if proper notice was not done, I want another one(s) scheduled please. I, respectfully, am very 

interested in this answer. 

FEEL FREE TO READ THE FOLLOWING AT THE PUBLIC HEARING: 

Now, let's get to the big issue at hand. Limerick should NOT be approved for an extension with their permit for the 

following reasons: 

• Limerick is designated as one of the TOP THREE nuclear plants in the country based on it's construction (which is 

similar to the ones in Japan - and we see how they failed) and the fact that it sits on an earthquake fault line. 

• The NRC JUST a few weeks ago stated that "more information needs to be done and studied" regarding further 

fortifying nuclear plants regarding earthquakes. Thus, until you folks know exactly what needs to be done, etc. 

THERE IS NOTHING TO APPROVE as long as Limerick sits in it's current position. 

• Do NOT think that earthquakes only happen on the West Coast- as we JUST had a 6+ earthquake less than a 

month a o. BY ONLY luck was there no dam a e to the I ant, environment or communit . 

When Limerick was built, there was no idea that the area would grow in population like it has. For safety 

reasons, just look on any given day the traffic on Route 422 - stacked and stuck for miles on end. Route 422 is 

the #1 route for evacuations and does not handle re ular commuter traffic let alone entire communities. 

• The NRC and USA Government STILL have not decided on where to store spent nuclear rods and as we spea ~t-;;:-::-::::o 

each spent rod is sitting in baths on the Limerick sit, stacking up-expanding even a greater hazard t o the 

community, environment, etc. SO put simply, there is ABOSLUTELY NO REASON to approve this request for 

YEARS until the US Government decides how the will handle such rods and such rods and ro erl stored. 

• There are many other environmental friendly sources of energy and Limerick as anything but that. As a matter 30-6 

fact, Limerick is a TIME BOMB, placed at the wrong location, on the wrong land, too close to major populations, -OS 

run by a for profit company who can not even handle the basic maintenance issues of power lines, in an aged 

buil · h n re I 

6 o v s .!-- 13 e.- J/; ur 

t!T &!Zi:::: /hH - 013 
Appendix A

A-135

• 

• 

Let' s also mention a fact that Category I Hurricane Irene, which could have been a Category 3, just zipped less 30-8-

than 100 miles away from the site a few weeks ago and then Hurricane Lee which decided to travel further Eas AM 

came close to also causing chaos. Limerick is still TOO close to t he disaster of Hurricanes as well. 

Lastly, some who have a vested interest in working at the plant, etc. are quick to state that it is safe, etc. -no~ 130-9-~ 

now, nor has it ever been fool proof against disasters, technical glitches, etc. I OS 

us, ee 1rm y an many m t e commun1 y ee t e exact same way, a ere IS o approve 

(especially so far in advance, with no answer on usage rods nor what needs to be done to prevent a meltdown due to a 

earthquake, etc.) or EVER since the population will only increase and the facility age further. It is the wrong timing, 

wrong plant, wrong place, etc. for Limerick. Maybe Exelon can put in as much effort and "energy" to develop solar 

fields, wind, etc ... They would rather beat the hell out of a high efficiency plant at any and all cost to the environment 

and community. This is where the NRC does the right thing and says NO until a year before it expires. NRC needs to 

take a stand as you have the data and know what I have stated above is more than fair and true. 

Thank you for your time and attention. 

Regards, 

J«R~ 
Appendix A

A-136

!-C? /d& /?:o /) 

/"C..r.£ .5:3//'7~ 

Delaware Tribe Historic Preservation Office 

1420 C of E Drive, Suite 190 

Emporia, KS 6680 I 

(620) 340-0111 

bobermeyer@delawaretribe.org 

September 23, 20 II 

Chief, Rules, Announcements, and Directives Branch 

Division of Administration Services 

Office of Administration 

Mailstop TWB-05-BOJM 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555 

Re: Request for scoping comments concerning the Limerick Generating Station, Units 1 

and 2, License Renewal Application Review 

Dear Lisa Regner: 

Thank you for informing the Delaware Tribe on the proposed construction associated 

with the above referenced project. Our review indicates that there are no religious or .-----

culturally significant sites in the project area. As such, we defer comment to your office 131-1-HAI 

as well as to the State Historic Preservation Office and/or the State Archaeologist. 

We wish to continue as a consulting party on this project and look forward to receiving a 

copy of the cultural resources survey report if one is performed. We also ask that if any 

human remains are accidentally unearthed during the course of the survey and/or the 

construction project that you cease development immediately and inform the Delaware 

Tribe of Indians of the inadvertent discovery. 

If you have any questions, please feel free to contact this office by phone at (62) 340-

0111 or by e-mail at bobermeyer@delawaretribe.org 

Sincerely, 

Brice 

~~ Obermeyer 

Delaware Tribe Historic Preservation Office 

1420 C ofE Drive, Suite 190 

Emporia, KS 66801 

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Appendix A

A-137

StocRfiritfge-Munsee fJ'riba{ :Jlistoric Preservation Office . Slimy ~te - 'Tri6a{ :Historic Preserrlation Offiar 

'W13447 camp 14 ~all g_/c?&/zt91 / 

P.O. ~.t70 

'&wfo; 'WI 54416 ~?/(.d'"3./-'J '?' 0 

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TCNS 

Project 

Number 

Number ~:_p:;u;_je; J ufi;} ~ " tb./YI ~ ~ t /J 0' ba ?i 'f'1 ~ 

Company Name { () [l( 4 f !{ 1

. We have received you letter for the ab~ve listel:l project. Before we can process the 

request we need more information. The additions~ items needed are checked below. 

Additional Information Required: 

·~·,-

__ Site visit b~'.TtlbaJ Historic P,Fese~ation. Offic~ . ·-,_ .. ~<; .~ · .... ·= Archeolpgical sllrv.ey Ehi!Se 1. · -· ., · · -~ -- ·• .,./>..... -

Literaturefte(:9p.d sear6h. wcf~9in&col0red 'maPli. , ' ' .,. · ;;" • · ., ·' · } ; -• 

Pictures ofthe!$'iie . · · . · · · · ·•·· · · .·. · . ···, <">Jj' . Any rep,ort~ fh~ tate . Htstoric PreseFVation .Office m~y haVe~:: . . ...... 

__ Has the,site;been prev~{)usJy disturbed · . . . . · · 

Review fee !I!:USt-be·included with letter ·, \ 

If site has beeirpreviously disturbed please explain what the us.e ~~s :ari~C~hen it was . .. , .. . ,.: . . ··- . . .., dtsturbed. :. · ,, . · . _ , '· ,.. :· 

Other colll11fel)ts..or information needed - ------~-~--~~~---

: . ·1 .. 

After reviewi!lg .. your·ietter we fmd that: ~ . ).~. 

~- ~~;::~~ 

"t.,. il 

. : . . : :~~ 

_y "No P..f.Gp~ies ' -meTribe concurs with a Federal agen<;Y'S ~di~ ~t there are 132-1-HA I no National R~&ist~r cli~~ble or listed properties within the f,ederidi:¥m~~rtlfking's area of 

potential effe~t or APE.3q.CFR ,800.4 (d) (1) '· · • .. . · ... , 

1.: :.:;i 

· "No Ef.l~ct" his~oric or prehistoric properties arc::_pj-esentbut th.e,$.e4eral 

underta~ing ~~l:f,!t~~~ ~o effect on the Natio11al Rc::gi~ter ~1igi,91:C or\i$te pr~~erties as 

defined ll:l-,$~ 800, 1·6(t.) · .. · · .·.: . · -. . ,r·•- . i' . '. "' '.'· 

___ ''Nd Adverse Effect" ref~ . written opinioris pp:>~ded to a Federai''agency as to 

whether or notlthe Tribe agrees with (or believes-that-there should be) a Federal agency 

finding that its: Federal undertaking would have 'No Adverse Effect" 36 CFR 800.5(b) 

6ovs.z: IJe f;~ ~~ 

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Appendix A

A-138

U.S. NUCLEAR REGULA TORY COMMISSION 

,- ~~;~~~~ .. ]. 

I '··· NRC p~~uc MEETING FEEDBACK L--- ·- ·- .. -- 1· 

Meeting 

Date: 

.. - - M~eiing - Li~eric~ ~~~rating Station License Renewal Overview and Environmental 

09/22/2011 Title: Scoping Comments Public Meeting . _....!,._.:,_ ,_ ....... ... - . .....:-- - . -·- ·-··· --. .... . _ __________________ ·-- ...... _ _______ _ _ 

In order to better serve tile public, we need to hear from the meeting participants. Please take a few minutes to fill out 

this feedback form and return it to NRC. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

How did you hear about this ~eetinq? 

[ l NRC Web Page 

[] RadiofTY 

LJ NRC Mailing List 

D Other 

Were you able to find supporting information prior to 

the meeting? 

Did the meeting achieve its stated purpose? -

Has ttiis meeting helped you wiih your understanding 

of the to_pic? · 

Were the meeting starting time, duration, and location 

reasonably_G()nvenient? --.k, _,_,-_,- _ 

. · .. ; ·-t.: ... ~ .- : .. 

Were you given sufficient opportunity to ask questions 

or express your views? 

Are you satisfied O>Jerall with the N_Ry staff who 

participated inthe meeting? - '.. - -~ ~ ' ·,_- -

No Somewhat 

X!§_ r'Piease explain below) 

I i 

~ 

.,,··" 

[i6 

1.1 

[J 0 

[] [J 

[] [_] 

[J i -] '--

.; •· 

Continue Comments on the reverse. r.:> 

OPTIONAL 

Name Organization Q <'-~~ ~-{--

Telephone No. E-Mail 

- ~c,:> ______ _ ------ -

C -~ Check here if you would like s 

-- - - --- -.------------ ---- ------ .... --- ... --... memberofNRCstafftocontactyou 

OMS NO. 3150-0197 Expires: 0813112012 

Public Prote:tion Notification: If a means used to impose an information collection does not display e curr$nlly v&lid OMS control number. the NRC rNlY not conduct 0t sPQr,sor. and a person i!. 

nol required to tespond 10. the information colledion. 

Please fold on the dotted lines with Business Reply side out, tape the bottom, and mail back to the NRC. 
Appendix A

A-139

tr . . .. 

Mendiola, Doris 

Subject: FW: Response from "Comment on NRC Documents" 

y-pc., )4!J1/ 

-----Original Message----- /'/ 

From: Richard Kolsch !mailto:Rklsch@aol.coml 7'~ /.,!( ~3~ /'0 

Sent: Thursday, September 22, 2011 5:44PM @ 

To: INFOCOLLECTS Resource 

Subject: Response from "Comment on NRC Documents" / (} 

Below is the result of your feedback form. It was submitted by 

=o ·' :_ -, :r.J 

c: il ·:-, ,--

;-n l -, (.'..: '") - ·1 

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Richard Kelsch (Rklsch@aol.com) on Thursday, September 22, 2011 at 17:44:25 -- 2;~ :......_ ' ~~ :.::, 

.--n '9 L:-~ -I 

CJ < ..r::: rn 

N (/) 

Document_ Title: License Renewal Limerick PA 

Comments: Comments on Limerick Power Plant License Renewal Limerick, PA September 22, 2011 

1. Why is there a rush to renew the license? It is not due 34-1 

until 2024, approval at the earliest should be 2019. This would allow 5 years for the business plan of PECO to -LR 

either continue or close the plant and make arrangements for additional power to replace the closed plant. 

2. A firm closure plan should be approved before license renewa 134-2-DCI 

is accepted. This plan must include what is to be done with the 

site, where the nuclear waste will be disposed of etc. The 

site like the 

<UvQ 

now 

OOU"' 

defunct 

Uv <'0 

Yucca 

""" U 

site. 

V.1-'v0 <'UVO 

The public 

OVO "VO 

and 

OOv U 

our 

OvVOvUvU

future 

> ~ 

RW 

generation deserves to know what is expected to be done at the site. Radioactive material must not be 

allowed to remain on the site. 

3. The government should conduct a survey of various illness in the vicinity of the nuclear plant prior to an 

renewal of a 34-4-HH 

license. If this would indicate a danger living near the plant 

then the license should not be renewed. 

4. Developers are required to fund traffic improvements to an area to allow an area to be developed, this 1 

should apply to Limerick. The evacuation plan now will not work. When the plant 

was started there was no traffic out here, now it is grid lock. 134-5-0S 

Limerick should fund new roads and bridge to alleviate traffic I ·ams in order to have an orderly evacuation. 

5. The plant is vulnerable to terrorist attacks. An airport is located next to the facility. A plane could be flown ;J into the reactor building or the emergency power supply for the water circulation system at the same time 

terrorist could cut all outside power to the plant this would cause a meltdown and render the entire area around A 

and downwind of the area uninhabitable for hundreds ofyears. 

organization: None 

address1 : 1694 Kepler Rd. 

address2: · ,()~ 

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,£-Q"2J5 .:=- ,!&ZJ.)..t-.?! 3 

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Appendix A

A-140

.. ~ .. 

·<(. 

f/c9~ I 6UJ I I 

September 24, 20 I I 

7'~ r-,.e .. :5-a¥ ~7 2461 E. High St.,tJnit F-lB 

Pottstown PA 19464 

US NRC 

Mailstop: TWB-05-BOI M 

Washington DC 20555 

USNRC Lisa Regner: 

0) 

We wish to add our comments to the NRC record. 

We attended one of the NRC hearings concerning Limerick's Environmental Impact (9/22/ 11 at 

2:00 p.m.) and were appalled that local business and community leaders avoided voicing concerns about 

Limerick's environmental impact, mentioning its economic influence, instead. That doesn't mean that those 

speakers had no concerns. The NRC would be remiss to consider a "thank you for money and jobs" as part 

of its evaluation of community-wide nuclear safety issues connected with Limerick's re-licensing request. . . . . . 

be addressed. Re-licensing should not even be a consideration! The NRC must fully investigate the r::-::-:::-:::c=-, 

environmental concerns presented Dr. Lewis and Donna Cuthbert (ACE), Dr. Winter, and each resident 135-7 -OR 

who so civilly represented this community's concerns at the September 22, 20 II hearings. The Limerick 

Nuclear Power Plant should NOT be re-licensed and should, instead, begin to address the pollution issues i 

has already created as it seriously and carefully shuts down its reactors. 

= .. ..; : 

Sin~erely, 

~ll'rd~tfl~ 

Charles and Elizabeth Shank 

(610-323-6715) .. 

. • ,~ • 1 ·: •. : •: - • : :r • :•. • ·.:n 

"···· · · ·.PtfV.---:JJs-·/JJJH-0 3 

·• ·: ,'X:/5~ (!-u~_z) 
Appendix A

A-141

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

naturalcat@comcast. net 

Wednesday, October 12, 2011 5:26 PM 

Regner, Lisa 

NRC 10 DOCKET 2011-0166 

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Appendix A

A-142

-• ... 

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Dear Ms. Regner, 

~~~~// 

7't rJ<:. sa.t/-7' r? 

Cynthia Gale [cgale@barbergale.com] 

Wednesday, October 12, 2011 4:31 PM 

Regner, Lisa 

Michael Gale 

TJ 

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DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERJOD .. ::::::-1 . I 

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On behalf of my family, friends, and neighbors, please do not relicense the Limerick Nuclear Power 

Plant. We work in Pottstown, live in Elverson, and our young daughter goes to school in Kimberton. All 

these locations are in harm's way of Limerick. Every day when I drop our child off at school I have a 

view of the Limerick towers when I travel on Route 724. I pray everyday that nothing happens when our 

daughter is at school. We no longer feel safe or even drink our tap water, do you? 

Limerick Nuclear Plant's License Expires In 2029 - Exelon Wants To Run It Until 2049 

Threats and Harms, Already Unacceptable After 26 Years, Are Increasing! 

Since 1985. Unprecedented Environmental Harms. Threats. and Risks From Limerick Include: 

1. Radiation Into Air and Water From Routine and Accidental Emissions 137 -1-RW I 

2. Major Air Pollution Under Health Based Standards of the Clean Air Act 137 -2-AM 

3. Schuylkill River Depletion and Major Drinking Water Contamination 37 -3-SW; 

37-4-GW 

4. 

5. 

6. 

7. 

8. 

9. 

Radioactive Groundwater Contaminationl37 -5-GWI 

Radiation Reporting Levels Increased Dramatically After Japan Disasteri37-6-0S I 

Alarming Cancer Increases, Especially In Children, Since Limerick Started Operatinq37-7-HHI 

Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Site 137-8-RW 1 

Lax Fire Safety Regulations i37-9-0S I 

Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cable 

10. Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaste 37-11 

11 . Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacksl37 -12-0S I 

-PA 

12. Need for an Updated Evacuation Plan and Increased EP 37 13 0S I 

13. Increased Costs to the Public- More Cancers and Other Costly Illnesses, More Emergency Room Visits 

and Hospitalizations from Massive Increases in PM-10 and TDS, Treatment of Public Drinking Water, 137-14-HH I 

Environmental Clean-Up 

14. Dangerous, Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replar:;c::;e;.;;; d::-::--:-:--, 

With Safe, Clean, Renewable Energy. 137-15-AL I 

List Compiled By The Alliance For A Clean Environment- September 2011 

5v..vs-'- If-e-n~~~ ~-XJ:;-?Js = /7-Z>N- .?3 

17~= IT:vH-t::?/3 ~==-x .!f~0~R...z) 
Appendix A

A-143

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Hello Ms. Regner, 

8jc7(p /?» 1/ 

%r;e~3~<Jf' 

Schweg [schweg@gmail.com] 

Thursday, October 13, 201110:21 AM 

Regner, Lisa 

Limerick License Renewal- NRC J.D. Docket 2011-0166 

:n 

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Ill ·-

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w 

I'm writing to you to state my opposition to the relicensing of the Limerick Generating Station in Limerick 38-1-0R . . 

Respectfully, 

Jude Schwegel 

79 South White Horse Road 

Phoenixville, Pa 19460 

If you want to be important-wonderful. If you want to be recognized-wonderful. If you want to be greatwonderful. But recognize that he who is greatest among you shall be your servant. That's a new definition of 

greatness. 

Everybody can be great, because everybody can serve. You don't have to have a college degree to serve. You 

don't have to make your subject and your verb agree to serve. You don't have to know about Plato and Aristotle 

to serve. You don't have to know Einstein's theory of relativity to serve. You don't have to know the second 

theory of thermodynamics in physics to serve. You only need a heart full of grace, a soul generated by love. 

And you can be that servant. 

Excerpted from The Drum Major Instinct sermon of the Rev. Dr. Martin Luther King, Jr. 

Delivered at Ebenezer Baptist Church, Atlanta, Georgia, on 4 February 1968 
Appendix A

A-144

( .. ' 

Mendiola, Doris 

~~/~// 7~~/(53-l--.7'7 

From: 

Sent: 

To: 

Subject: 

Michael Gale [mgale@barbergale.com] 

Thursday, October 13, 2011 9:26AM 

Regner, Lisa 

DO NOT RELICENSE LIMERICK NUCLEAR PLANT. PERIOD. 

II . -~ 

And. gel the US manufacturing again making wind turbines, solar panels, =.] · .~ retrofitting older buildings to be energy efficient, not funding this an other budget-busting toxic time bombs. ·-; 

Limerick Nuclear Plant's License Expires In 2029 - Exelon Wants To Run It Until 2049 

Threats and Harms, Already Unacceptable After 26 Years, Are Increasing! 

_ ) 139-1-ALt 

,-j 

--- ........ Since 1985 Unprecedented Environmental Harms Threats and Risks From Limerick Include: ;TJ 

1. Radiation Into Air and Water From Routine and Accidental Emissionsi39-2-RWI 0 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

Major Air Pollution Under Health Based Standards of the Clean Air Acti39-3-AMI 

r=?::::;::::::;::::;=:=~-:--::::-:-:-:----, Schuylkill River Depletion and Major Drinking Water Contamination 139-4-SW; 39-5-GW 

Radioactive Groundwater Contamination 139-6-GWI 

Radiation Reporting Levels Increased Dramatically After Japan Disaster 139-7 -OS 

~~:-:::--=-:"-:-:-:-! Alarming Cancer Increases, Especially In Children, Since Limerick Started Operating 139-8-HHI 

Deadly High Level Radioactive Wastes Packed In Vulnerable Fuel Pools On Sitei39-9-RW I 

Lax Fire Safety Regulations 139-1 0-0S I 

L·J 

:!? 

-F.= 

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9. Accidents and Leaks From Corroding, Deteriorating Equipment Plus Miles of Buried Pipes and Cables 139- 11 -0S 

10. Increased Risk of Meltdown From More Frequent and Stronger Earthquakes and Other Natural Disaster9 39- 12-PA 

11. Threats From Unguarded Terrorist Attacks With Planes and Missiles, Cyber Attacks 139-13-0S 

12. Need for an Updated Evacuation Plan and Increased EPZI39- 14 -0S I 

::TJ c r ·-- r.-·; 

(.J; 

14. Dangerous. Dirty, Harmful, and Costly Nuclear Power Is Not Needed. It Can And Should Be Replaced With Safe. Clean, 139-1 6-AL I 

Renewable Energy. · · 

List Compiled By The Alliance For A Clean Environment - September 2011 

We sincerely hope you will act with your fellow citizens' health, and indeed longevity in mind. 

Sincerely, 

Michael Gale 

172 north hanover street 

pottstown. pa 19464 

610-705<'.606 p 

mgale@barbergale.com 

http://www.barbergale.com 

dcsif}Tlill!J su.-ttairUJ blc brands 

_.,c--/(...:z~Z6.::::-/301'7'-.v 3 

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Appendix A

A-145

Mendiola, Doris 

Subject: FW: LIMERICK 

~~// 

7'~r£03-'/-9~ 

From: Joe Roberto fmailto:joe@robertoandassociates.coml 

Sent: Monday, September 26, 2011 2:46PM 

To: Regner, Lisa 

Subject: RE: UMERICK 

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.1 nanKs ana again, Since tnJS reactor nas until LUL4 wny tne rusn, ana an1y one public meet1ng. IT you nave not neara n, 

ou w ill. There is a major public outrage over this one meeting and not knowing about until too late. People want 

ublic meetings so that people hear that many are against this plant rather than just submitting comments to the NRC 

Nhich appears to just rubber stamp license requests - which is not comforting to me and many. But I do thank you very 

tnuch for the courtesy, response and review of points. 130-13-LR ~ 

I

There is also something that I did not comment on before- why was Limerick taken "offline" three times in as many l months? Is NRC checking? 130-14-0S 

Thanks, 
Appendix A

A-146

.... . . ~ 

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Melissa Antrim [mantrim@boscovs.comj 

Friday, October 14, 2011 2:18 PM 

Regner, Lisa 

Antrim, Melissa home) 

Docket 2011-0166 - Limerick License Renewal 

Via email: Lisa.Regner@NRC.gov 

U.S. NRC 

ejd-4 jcn;/l 

/'&r/(_JUfi 

Ms. Lisa Regner 

Mailstop TWB-05-801 M 

Washington, D.C. 20555 0 

Reference: Request for Denial of Limerick License Renewal - NRC I. D. Docket 2011-Q166 

Dear Ms. Regner: 

. _, 

~2 

... -.:> , .. ..., 

-1 

attended the recent meeting on the possible renewal of LimencK Nuclear Plant's license for 20 years past 1ts currerif 

024 and 2029 expiration dates. I strongly believe, as do many of my local friends and family, that the Limerick Nuclear 

Plant must be closed, not relicensed. Approving Limerick Nuclear Plant to be relicensed until 2049 would be jeopardizing 

~ r n 

(.' · 

he health of thousands and thousands of people in neighboring communities. There is substantial evidence readilv 

vail able which justifies closing Limerick. Renewing this license could lead to a catastrophic meltdown. 140-1-0R I 

Limerick was built to last 40 years. The older any facility gets, the more liKely breakdowns and equipment failure will 

occur. When it's a nuclear power plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and 

equipment - honestly, a number of things. Miles of deteriorating underground buried pipes and cables are a major 

concern - how and how often are these inspected? Signs of mechanical damage and breakdown already exist -

three unplanned shutdowns June 2011 , preceded by many others since 2007, one with loss of cooling water. While 

some parts can be replaced, by the nuclear industry's own admission, some equipment is too big and expensive to 

replace. Limerick is showing signs of stress and no one knows just how bad this will be by the time the current license is 

up. To add 20 more years to that, without having a clue as to what the condition will be, would be beyond careless. 140_

2_

08 I 

Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not possible, even within the 

seriously flawed and inadequate current 10-mile evacuation plan. Until Limerick closes, NRC should expand the 

evacuation plan (to 50 miles) and be sure there are enough shelters and supplies available to accommodate the ov,.,_ 7-~:--o 

million people within that radius. Exelon should pay for the supplies. 40-3-0S 

It doesn't take an accident or disaster for Limerick to poison the region's residents w1th ra 1alion. a 1a 1on rom 

Limerick's routine and accidental emissions alone for the past 26 years is reason enough to deny Exelon's request. It's 

not credible for NRC to claim continuous radiation levels are safe for me and my family when there is no safe 

level of exposure according to the National Academy of Sciences and Physicians for Social Responsibility. 

NRC never did any radiation monitoring or testing at Limerick. Evidence shows testing done by Exelon and DEP cannot 

be trusted. Exposure to radiation is known to cause cancer. It should be obvious to NRC that Limerick played a 

major role in our tragic, well documented cancer crisis after LimericK started operating in the mid 198.0s to the late 1990s. 

Four cancer studies based on PA Cancer Registry and CDC data showed skyrocketing rates for several cancers far 

higher than national and state averages, especially in children. Our children had the highest levels of Strontium-90 

radiation in their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released SR-90 into our 

air and water that got into the milk, vegetation, and food since Limerick started operating. '"'4:-:0:-_-:-4-:-H-:+-.H,.., ' ~ -dJ.3 
Appendix A

A-147

-. 

hyroid cancer increased by 128% from 1985 to 1997 - was a side note, with no family history or other obvious risk 

actors in my life, I was recently treated for thyroid cancer. Since my diagnosis, I have learned of many other locals like 

e. It's sea to think the choice of where we live could kill us. 40-5-HH 

It would be careless, unethical · and immoral for NRC to approve Exelon's requested 

Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 

Sincerely, 

Melissa Antrim 

1008 Reading Ave 

Boyertown, PA 19512 

The information transmitted is intended only for the person or entity to which it is addressed and may contain 

confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of 

any action in reliance upon, this information by persons or entities other than the intended recipient is 

prohibited. If you received this in error, please contact the sender and delete the material from any computer. 
Appendix A

A-148

' ...... g).u)~l/ 

"' ' Mendiola, Doris J:J 9 e!. 

----------~-------------------------------------------------~. ~~------~~,------- f~ 

. /t r .;t c; -:3-"'-'7 f' 

From: Michael Antrim [antrim89@gmail.com] (ii) ~) -1 

T

S

0

en.· t: Friday, October 14,2011 2:35PM J(j ·~~-l~· ~~~ D ~ 

Subject: Limerick- NRC I. D. Docket 2011-0166 -::::::: ::;?. 

Reference: Request for Denial of Limerick License Renewal -

Dear Ms. Regner: 

iTi 

NRC I.D. Docket 2011-01-66 ~ 

he possible renewal of Limerick Nuclear Plant's license for 20 years past its current 2024 and 2029 expiration dates 

more than 12 years ahead of time, worries me a great deal. It's hard to understand why something this major would be 

one so far in advance. It's IMPOSSIBLE to know the condition of Limerick 12-19 years ahead of time. Why on earth 

ould this be renewed so early? It's a lengthy process that could begin earlier, but in no way should something this 

mportant be rushed through now. Why not wait until closer to the expiration dates, and then seek approval? I 

nderstand this is how the original guidelines were set up - but those are long outdated. Approving Limerick Nuclear 

Plant to be relicensed until 2049 would be jeopardizing the health of millions. Renewing this license could be catastroohic 

o millions. Someone has to speak up; someone has to step up. 141-1-LR I 

Earthquakes and other natural disasters are more frequent and stronger than ever before. Limerick is 

3rd on the earthquake risk list. Underground pipes and cables can shake and break, which 

would lead to loss of power, loss of cooling water, and meltdown. Limerick's substandard 

containment flaw means more radiation would be released. It is simply too dangerous to keep 

limerick operating. Would you want to live within miles of this potential catastrophic disaster? Add 

the enormous population growth that this area has seen over the past 10 years - with little to no road 

improvements - and attempting to evacuate the area during a disaster would be futile. It would be 

virtually impossible to get out of harms way. 141-2-0S I 

The older any facility gets, the more likely breakdowns and equipment failure will occur. Limerick was built to last 

40 years. Limerick is showing signs of stress and no one knows just how bad this will be by the time 

the current license is up. To add 20 more years to that, without possibly knowing what the condition 

will be, would be careless. No one can predict what the condition of Limerick will be in 2024 or 2029. 

Over eight million people live within 50 miles of Limerick Nuclear Plant. Safe evacuation is not an 

ootion. Plain and simole. That's a scarv thouaht for those of us who live here!! 

hey could monitor themselves. It should be obvious to NRC that Limerick played a major role in our 

cancer crisis after Limerick started operating in the mid 1980s to 2000. Four cancer studies based on 

Pennsylvania Cancer Registry and the CDC showed skyrocketing rates for several cancers much 

higher than national and state averages, especially in children - innocent children. Thyroid cancer 

increased by 128% from 1985 to 1997. I have local friends and family with thyroid cancer and brain 

ancer- not one, but several. Sadly, it's no longer uncommon in this area to have a personal link to 

ancer. However, it IS uncommon in other areas of the country. It used to be uncommon here too -

prior to Limerick. Would YOU want to live here? Would YOU approve a license renewal so close to 

home? Your job is to safely review the facts. Don't like the money of these corporations ~~~-!----. 

acts. 

Thank you for your time today. Just remember, it would be careless, unethical and immoral for NRC to approve ' 

requested license extensions for Limerick Nuclear Power Plant. Limerick Nuclear Plant must be closed by 2029. 41-4-0R 

. Sincerely, • · /'--

SUVSI lfe-//~~&..4::. 

A~-P./3 

~*:J)S-= 8D/-/-c 3 

~-=~ 4~ c~~;;j 
Appendix A

A-149

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Dear Ms. Regner: 

joanmcglone@comcast.net 

Sunday,October16, 201110:11 PM 

Regner, Lisa 

Limerick License Renewal 

re: Limerick License Renewal- NRC I.D. Docket 2011-0166 

I am opposed to the license renewal of the Limerick nuclear plant which was designed to safely . 1(2-1-

operate for 30 yrs. and should now be safely ,1> hut down. Statistics regarding nuclear accidents at OS I 

similar aging structures are well documented. Those two towers are ticking timebombs and the NK~ 

knows this and needs to shut them down. Following the Japanese nuclear disaster our Limerick 

literature 

nuclear plant 

also. 

hit 

Why 

the 

does 

statistical 

the NRC 

at risk 

think 

list 

they 

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can 

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play 

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people's 

of cancer 

lives? 

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It is no longer 

in the 

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debatable, shut it down before our very lives are jeopardized!!! 

So-called quality of life issues addressed as part of public debate, e.g. "the power is always on"I42-3-0R I 

seems irrelevant to us when our families are required to evacuate during a disaster. Limerick must 

be closed and NOT relicensed at any cost, specifically the cost of life itself! 

Sincerely, 

Joan McGlone 

Resident of Royersford borough 

JJ --n 

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Appendix A

A-150

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43-1-0R 
Appendix A

A-151

Mendiola, Doris 

Subject: 

Attachments: 

-----Original Message-----

FW: *Limerick License Renewal-NRC I. D. Docket 2011-0166 

Limerick.odt 

From: Angelbosley <anqelbosley@aol.com> 

To: Lisa.Regner <Lisa.Regner@NRC.gov> 

Cc: AngeiBosley <AnqeiBosley@aol.com> 

Sent: Sun, Oct 23, 2011 12:48 pm 

Subject: *Limerick License Renewal-NRC I. D. Docket 2011-0166 

Lisa Regner: 

Hello, I am attaching a letter to you regarding Limerick Power Plant trying to Re-license until 2049. Please read it. Thank 

you for your time and attention. 

Sincerely, 

Lisa Smoyer 

1027 Farmington Ave. 

Pottstown PA 19464 

484-945-0246 

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Appendix A

A-152

Sunday, October 23, 2011 

Lisa Regner, License Renewal 

Mail stop TWB-05-BO I M 

Washington DC 20555 

Lisa.Regner@NRC.gov 

*Limerick License Renewal-NRC l.D. Docket 2011-0166 

Dear NRC/Lisa Regner: 

I was unable to attend the public hearing at the time that is occurred. I would like to voice my concern 

to all of you through this letter. There are so many reasons why you as a group should already know 

that it would be in the best interest of the men, women, children, babies, fetuses, animals, fish, wildlife 

in general and the environment for you to refuse/oppose Limerick Power Plant from re-licensing. The 

problem that always seems to come up at some of these public hearings and sessions where 

businesses/corporations want to expand and become bigger and run their businesses long past the time 

that they should truly be allowed in order to keep people safe, always comes back to the issue of 

money, offerings, bribes, donations, etc. in the end. When these things occur, people and businesses 

tum a "blind eye" so to speak to the dangers of allowing a business like the Limerick Power Plant to 

renew its license again. That is unacceptable! I expect and demand better service from you tn h Pln 

protect myself and my family from harm! 144-1-0R I 

There is no "independent" testing being done at Limerick. The results of testmg are provtded by thetr 

own company, who has a vested interest in the outcome of those results, so how could you ever believe 

that they would be honest about the results? Seriously?? 144-2-0S I 

There is concern that should be faced regarding the Schuylkill Rtver and the atlects it ts gomg to have 44-3- I on the public if it becomes depleted and/or toxic due to the contaminates going in it. It is disgusting sw 

and heart wrenchmg to know that ofilctals and orgamzatwns are not paymg attentwn to what can 

happen to the public if Limerick Power Plant continues to operate longer then expected. Ignoring the 

obvious problems our community is facing and hoping that after they serve their term, it will be 

someone else s problem to deal with is unacceptable. Now is the time. Step up and do what is morally 

right for humanity. 144-4-0RI 

We as a society need to wake up and start paying attention to the massive harm power plants can cause 

to the people, animals, water, air, etc. Why does everyone want to pay attention when it is way too 

late?? There are safer alternative forms of energy available to our country/communities. We should be 

working on them and training employees, who currently work for the nuclear power plants how to 

work with safer forms of energy to help our country move forward in today's society. 144-5-AL I 

Haven't we already seen some of the damage that a terrorist attack can cause for our country and for ~ 

others? Do you really need to risk more possible attacks on a power plant that is not fully equipped for 44-

6 

hat kind of attack or for some other natural disasters that can occur. This plant is not prepared for -PA 

!tacks with planes missiles and other threats such as a cyber attack. There should also be a concern .---

or accidents and leaks from corroding and deteriorating equipment at the site from over the years 144-7-0 S 
Appendix A

A-153

(Page 2 of3) 

which could cause parts of it to be shut down for periods of time, as well as the miles of buried pipes 

and cables. There are many concerns that should be fully looked at and considered, and just with 

minimal thought to them, it shouldn't take a "rocket scientists" so to speak to figure out that it is not in 

the best interest of the public or environment to allow them tore-license. 

he most alarming and compelling thing to me as a taxpayer, homeowner, and mother is the 

verwhelming and alarming cancer increases to the public after Limerick had started operating. The 

DC website showed a 92.5% higher than the national average for childhood cancer in six 

ommunities close to the Limerick Nuclear Plant which included, Pottstown, West Pottsgrove, Lower 

ottsgrove, Upper Pottsgrove, North Coventry, and Douglass Berks Township from cancers diagnosed 

om 1995-1999. The Pennsylvania State Cancer Registry For Montgomery County- from 1985-86 to 

996-97 also shows cancer rates skyrocketed in Montgomery County where the Limerick Nuclear Plant 

s located during the Mid 80's to 90's after they opened. Prostate Cancer increased 132%, Thyroid 

ancer increased 128%, Kidney cancer increased 96%, Multiple Myeloma increased 91%, Hodgkin's 

isease increased 67%, Non-Hodgkin's Lymphoma increased 61 %,Breast cancer increased 61%, 

ancreas cancer increased 54%, and Leukemia increased 48%. 

adiation exposure can cause cancer and other serious disease and disability, at any level of exposure 

ccording to the National Academy of Sciences and Physicians for Social Responsibility. Permissible 

adiation levels does not mean that they are safe levels for everyone in the community. Most 

ermissible levels are based on the average healthy adult. They are not levels that were based or 

esearched for fetuses, infants, toddlers and children or pets. Fetuses, infants, children, pets and the 

lderly and immuned compromised individuals are at most risk of health problems. There is a broad 

ange of dangerous radionuclides routinely released into our air and water from the Limerick Nuclear 

lant as well as any accidental releases. Permissible radiation levels does not mean that they are safe 

adiation levels it onl means that the are allowed. 

44-7-

OS 

Cont'd 

I have children as well as other loved ones that have or have had allergies, asthma, learning disabilitie:i,-H_H__,_..J 

speech disabilities, behavioral disabilities, thyroid conditions, cancers, skin disorders and irritation, etc. 

I expect you to do what is morally right now for me, my family, my neighbors, my community, and the 44-11- 1 

pets, wildlife, air, water, and environment in whole by rejecting, refusing and opposing Limerick Power OR 

Plant from re-licensing to· run their business longer then originally planned for 2029. Don't tum a 

"blind eve" now. Do vour iob knowin!l: that vou are doing what is morallv ri!l:ht and safe for humanitv 

and for my children and for the future of generations to come. Please help women have a chance to 

carry a baby full term without complications due to any possible air and water pollution that may have 

been caused by allowing more radiation into the environment when there are safer alternatives for 

energy. 144-12-AL I 
Appendix A

A-154

(Page 3 of 3) 

One person/individual can make a huge difference in the life of others whether or not you realize it. It 

can have a domino effect on others. Please step up and be that one person that we truly need right now 

to do what is right. Why does it have to take someone to be personally affected by a situation or to 

have a loved one suffer or die to step forward and do something? Please don't wait. Now is the time. 

Please be courageous enough to stand up and fight for what is right for this community and for 

humanity in a whole, no matter how hard or long the task may seem, it will be worth it in the end!!! 

I appreciate your time and attention in this matter. Thank you. 

Sincerely, 

Lisa Smoyer- Upper Pottsgrove Resident 

1027 Farmington Ave. 

Pottstown P A 19464 

CC: Friends, Family and some community members 
Appendix A

A-155

October 8, 2011 

U.S. NRC 

Ms. Lisa Regner 

Mailstop TWB-05-801 M 

Washington, D.C. 20555 

Lisa.Regner@NRC.gov 

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Subject: Deny Limerick License Renewal - NRC I.D. Docket 2011-G166 

Dear Ms. Regner: 

I urge NRC to deny Exelon's request to renew Limerick Nuclear Planfs license for 20 

years past its current 2024 and 2029 expiration dates. Limerick Nuclear Plant must be closed, 

not relicensed, for many valid reasons. Approval for Limerick Nuclear Plant to be relicensed 

until 2049 would be reckless and would show blatant disregard for the health and safety of the 

public. There is more than sufficient evidence of harms and threats to justify closing Limerick. 

There are too many things beyond NRC's control that could lead to a catastrophic meltdown. 

Limerick is 3rd on the earthquake risk list. It is too dangerous to keep Limerick 

operating. Earthquakes and other natural disasters are more frequent and stronger. 

Underground pipes and cables can shake and break, then lead to loss of power, loss of cooling 

water, and meltdown. Limerick's substandard containment flaw means more radiation would bA 

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released. ]45-2-PA 

Everything has a hfe expectancy. Umenck's was 40 years. The older any facility gets, 

the more likely mechanical breakdowns and equipment failure will occur. When it's a nuclear 

l 

plant, meltdown could result from corroding, deteriorating, and aging pipes, cables, and 1-:4-=5,....-3=--=o:-:S~I 

equipment. Miles of difficult to inspect corroding, deteriorating underground buried pipes and 

cables are a major concern. Signs of mechanical damage and breakdown already exist - three 

unplanned shutdowns June 2011 , preceded by many others since 2007. one with loss of cooling 

water. While some parts can be replaced, by the nuclear industry's own admission, some 

eauioment is too bia and exoensive to reolace. 

errons s ave ma e ' c ear ey 1n en o a ac nuc ear p an s. xe on as re us o 

pay to guard Limerick against a 9/11 type terrorist attack with a plane or missile, even though 

the most deadly targets (Limerick's fuel pools) are vulnerable to such attacks. Limerick is a 

similar design to nuclear plants in Japan that are melting down and exploding. NRC's own 

report from 2000 shows people 500 miles away could be impacted by an accident or attack on .-:'::,.......,.--=:::-• 

such fuel pools. Deadly radioactive spent fuel rods are jam packed into Limerick's vulnerable 45-4-0S 

fuel pools five stories high. Cyber attacks, now declared an act of war, could wipe out systems 

that could lead to meltdown. Hackers have penetrated the Pentagon and other well guarded 

s stems. Exelon's new lan for c ber attacks ives us little comfort. 

No NRC policy, review, or report can make Limerick failsafe from a catastrophic 

meltdown. Over ei ht million eo le live within 50 miles of Limerick Nuclear Plant. Safe 

~-/0-:l>S-= /9-L>JY-0.3 

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Appendix A

A-156

.... ·., !" .,. 

evacuation is merely an illusion, even within the seriously flawed and fundamentally inadequate 

current 1 0-mile evacuation plan. Until Limerick closes, NRC should expand the evacuation 

plan (minimally to 50 miles) and be sure there are enough shelters and supplies available to 

accommodate the over 8 million people within the 50 miles. Exelon should pay for the supplies. 

Unless this is done, Limerick should be closed as soon as possible. 

But, it doesn't take an accident or disaster for Limerick to poison the region's residents 

with radiation. Radiation from Limerick's routine and accidental emissions alone for the past 26 

years is reason enough to deny Exelon's request. It's not credible for NRC to claim continuous 145-6-HH 

radiation levels are safe for me and my family when there is no safe level of exposure according 

to the National Academy of Sciences and Physicians for Social Responsibility. 

NKv 1s ramng 10 acKnow•eage oov1ous neann narms rrom umencK·s commuous aaamve, 

cumulative, and synergistic radiation releases which get into our water, food, soil, vegetation, 

milk, and our bodies. NRC has no idea what health harms some of the region's residents 

experienced from Limerick Nuclear Plant. NRC never did any radiation monitoring or testing at 45-7-HHI Limerick. Evidence shows testing done by Exelon and DEP cannot be trusted. 

Exposure to radiation is known to cause cancer. It should be obvious to NRC that 

Limerick played a major role in our tragic, well documented cancer crisis after Limerick started 

operating in the mid 1980s to the late 1990s. Four cancer studies based on PA Cancer Registry 

and CDC data showed skyrocketing rates for several cancers far higher than national and state 

averages, especially in children. Our children had the highest levels of Strontium-90 radiation in 45-8-HH I 

their baby teeth of any group near any nuclear plant studied. Limerick Nuclear Plant released 

SR-90 into our air and water that got into the milk, vegetation, and food since Limerick started 

operating. Thyroid cancer increased by 128% from 1985 to 1997. Other cancers rose 

dramatically as well. 

Limerick Nuclear Plant is slowly destroying the vital public drinking water source for 

almost two million people from Pottstown to Philadelphia. Radioactive and heated wastewater 

is discharged by Limerick Nuclear Plant into the Schuylkill River 24n. Limerick's cooling towers 

are causing significant depletion. To supplement the flow to operate Limerick, Exelon wants to 

pump more contaminated mine water into the river. No one can credibly assure us if drinking 45-9-SW I water will remain safe even until 2029 when Limerick's original license expires. 

Limerick contaminated groundwater. Radioactive leaks and spills over the years were 

never cleaned up. More radioactive leaks can be expected in the Mure through earthquakes, 45-10-GWI deterioration, and corrosion. Many residential wells are very close to Limerick. 

145-11-0R I 

Sincerely, 

e~JJ~ 
Appendix A

A-157

1618 Benjamin Dr. 

Ambler, PA 19002 

Oct. 21 , 2011 

Ms. Lisa Regner 

Project Manager 

NRC Environmental Review Project 

Dear Ms. Regner: 

am writing to express my opposition to the re-licensure of Limerick nuclear power generating station, 

hich is located about 20 miles from my home. There are several reasons why this re-licensure is not in 

he best interests of people living in the surrounding community. 

liT tnls ncense renewal IS gramea, tms p1ant wn1 contmue operatmg untu ~U'+!f, at wmcn ttme 1t Will oe 

over sixty years old. Cracks in concrete and corrosion in piping will inevitably develop as this facility 

ages. While some of this "wear and tear" may be evident to visual inspection, some of it will also occur 

in less accessible places, such as in underground piping systems. The Associated Press has shown that 

tritium leaks in underground piping systems frequently go undetected-sometimes for years-in aging 

nuclear power plants.' While no leaks of this kind have so far been documented at Limerick, the odds of 

these sorts of problems developing will only increase with every successive decade of the plant's working 

life. 

While the problems associated with age will develop in any nuclear power plant over time, there are 

additional problems with the reactors at Limerick. Limerick's reactors are boiling water reactors similar 

to those that catastrophically melted down last spring in Japan. Although these reactors have a later 

containment design, .they have the same fundamentally flawed reactor pressure vessel design as those that 

failed at Fukushima." In the BWR design, the control rods come up through the bottom of the pressure 

vessel, instead of dropping down from above as in other reactor designs. While the reactor pressure 

vessel itself is made of very thick steel, the bottom of the BWR pressure vessel contains 60 holes through 

which the rods enter the vessel.'" In the event of a meltdown, however, these same holes can provide a 

"path of least resistance" through which the hot molten fuel can escape with relative ease; it then only has 

to melt through connecting pipes that are much thinner and weaker than the metal of the pressure vessel 

itself.'v This apparently occurred at Fukushima, where authorities now admit that reactor fuel underwent 

not merely a "melt-down," but a "melt-through," breaching the inner pressure vessel and in the process 

releasing considerable amounts of radioactive material into the environment.v 

146-1-0R I 

146-2-0S I 

146-3-0SI 

vne m1gm oe remprea to a1sm1ss tne companson wnn uKu n1ma on me grouna s umencK tn 

Pennsylvania is unlikely to experience a similar combination tsunami and earthquake. While the tsunami 

is not an issue, however, recent analysis by the Nuclear Regulatory Commission suggests that 

earthquakes pose a more significant threat to the Limerick reactors than was recognized at the time of 

their construction and initial licensure. (incidentally, it now appears that at least one of Fukushima's 

reactors was significantly damaged by the earthquake even before the tsunami struck.)vi According to the 

NRC's own data, Limerick's two reactors are the third and fourth most likely in the country to sustain core 

damage in the event of an earthquake. vii There is a fault line called the Ramapo fault line that runs 146-4-PA I 

slightly north of Limerick, and two small earthquakes associated with this fault line occurred as recently 

as February 2009.viii The unexpected quake that shook Virginia's North Anna nuclear plant with over two 

times the amount of force that it was designed to withstand should make us take very seriously the NRC' s 

data regarding Limerick's greater than previously recognized vulnerability to earthquake damage.;' 

These concerns are compounded by the fact that the manufacturer of Limerick's control rods, GE Hitachi, 
Appendix A

A-158

Questions about the Limerick reactors' ability to withstand accidents and natural disasters are all the more 

pressing because so many people could potentially be affected if something catastrophic were to occur. 

Since 1990, the population within a ten-mile radius of the plant has increased by 45%, from 178,047 to 

257,625." In addition, Philadelphia, with a population of 1,526,006, is only about 28 miles away. How 

much more might these populations increase by 2049? Bearing in mind that the NRC advised Americans 

within a 50 mile radius of Fukushima to evacuate last spring, one can only imagine how difficult it would 

be to carry out such evacuations if the unthinkable were ever to occur at Limerick. 

Finally, my concerns regarding the impact of this nuclear power plant on my community are not limited 

to catastrophic scenarios that might potentially occur. There have been some recent studies published in 

health journals that show a higher incidence of c~rtain illness-particularly among children-in 

communities surrounding nuclear power plants."' While these studies were conducted in a variety of 

locations, they seem to be consistent with some of the data that Pottstown's local Alliance for a Clean 

Environment presents on its website regarding in,creased cancer and leukemia rates-also especially 

among children-in the greater Pottstown area."" 

For all of these reasons, I am asking the Nuclear Regulatory Association to deny Exelon's request to 

extend Limerick's operating license for an extra twenty years. 

Thank you for your time. 

Sincerely, 

Lori Molinari 

46-5-0SI 

46-6-HH I 
Appendix A

A-159

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: 

Subject: 

Regner, Lisa 

Thursday, October 27, 2011 10:17 AM 

Gallagher, Carol 

Mendiola, Doris 

Limerick Comment dictated to PM (docket NRC-2011-0166) 

Environmental Scoping comment dictated to PM (L. Regner) on October 27, 2011: 

I'm against it for two reasons: 

I' am fully aware of the amount of cancer that 1s prevalent 1n th1s area. 1 147-2-HH I 

Doris Meyers 

Read back to Ms. Meyers twice by PM to ensure accuracy of dictated statement. 

Lisa M Regner, Senior Project Manager 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

lisa.Regner@NRC.Gov 

Office: 0 11 H-23 

Mail Stop: 0 11 F-1 

(301) 415-1906 --.-o 

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Appendix A

A-160

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Hello Ms. Re ner: 

quteasz@comcast. net 

Thursday, October 27, 2011 3:03 PM 

Regner, Lisa 

Limerick Nuclear Plant Relicensing 

Just a quick note requesting the NRC to NOT allow the relicensing of the Limerick, Par.-:-.-':- ~,---, 

nuclear plant at this time. 48-1-0R 

move o o sown, a., some 1me ago 1n pe ec ea . , w w1 

prostate cancer. Although, I cannot prove it was a direct cause of the nuclear power plant, 

I feel that much further, unbiased studies and tests need to be done prior to the 

relicensing of the Limerick plant by reputable sources not by corporate interests groups 

that can manipulate the statistics in Exelon's favor. 

Wouldn't it be in the best interest of our community and surrounding communities if the 

higher cancer rate was due to the Limerick power plant???? This question is a "no ..-:::--:::--:-:-:'-:--, 

brainer". 

There is plenty of time for testing to be done prior to the relicensing. 

so, w y e urry ... 

hich we are not aware. 

hy must the license be renewed at this time when they are licensed through 2024 and 

029???? 

gain, WHY THE HURRY??? 48-

3-LR 

o relicense now is not in the best interest of everyone in our area. 

Prior to the construction of the Limerick power plant, everyone in our surrounding area 

was told that our electricity would be one of the lowest in the U.S. 

THIS WAS A BOLD FACE LIE!!!! IT IS ONE OF THE HIGHEST IN THE U.S.!!! r:-:::-~~ 

Excelon lied to us then and the will distort the facts now. 48-

4-0S 

PLEASE DO NOT BE IN A HURRY TO RELICENSE LIMERICK WITHOUT COMPLETE 

AND HONEST TESTING BY AN IMPARTIAL COMPANY. There is plenty of time after the 

test results. 

Thank you for reading my e-mail. I hope God guides your agency into making the correct 

decision. 

Ken Sekellick 

661 N. Price St. 

Pottstown, PA. 19464 

guteasz@comcast.net 
Appendix A

A-161

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936 Shenkel Road 

Pottstown, P A 19465 

October 25, 2011 

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U. S. NRC 

C/0 Lisa Regner, License Renewal 

Mailstop TWB-0505-BOl M 

Washington, D. C. 20555 

Dear Lisa, NRC: 

Re: Limerick License 

Renewal 

NRC I.D. Docket 2011-0166 

As a physician, I am writing to help you understand that nuclear reactors are not safe. 

I attended the medical clinic in Hiroshima right after the bombing and saw the radiation 

horrors caused by nuclear bombing. I have kept a close watch on similar problems by 

nuclear energy in the medical field since then, not only worldwide, but because of our 

nearby nuclear power plant. Here are some concerns. 

Incidentally, baby teeth studies have revealed Strontium 90 radioactive particles which ~::-:-:-:-:-1 

can affect the child's immune system for more illness. · 6-8-HH 

We can't control the use of nuclear in the rest of the world, but we can keep the U. S. 

safer by eliminating nuclear energies. Fortunately, many of our European allies including 6-9-0R I 

Australia have decided to phase out reactors. We should join them to reduce human 

suffering. Also this can reduce our increasing costs of health care! 

lease listen to this advice after years of doing my best for America. Rely on more and 

ruly safe and renewable sources like solar, wind and geothermal power. A patriotic dut)'-,----' 

imerick Power Plant is ranked in the top 3 riskiest nuclear power plants in the U.S.A. I6_11 _

0 R 

imerick Power Plant must be closed not relicensed. . 

Sincerely yours, 

Is! Fred S, Winter 

Fred S. _Winter, M.D. ~ 

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Appendix A

A-162

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Anthony Gonyea 

Onondaga Nation 

Hemlock Rd. Box 3198 

via Nedrow, NY 13120 

Oct. 15, 2011 JJ 

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David J Wrona ~~ - US Nuclear Regulatory Commission 

Washington, DC 20555-0001 

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RE: Project ID: Limerick Generating Station 

Limerick Township of Montgomery County, PA 

Dear Mr. Wrona, 

Thank you for providing the Onondaga Nation with information about this project. If 

anything changes are made, I would like to be consulted. I realize that Unit 1 and Unit 

2 have licenses that may be renewed in 2024 and 2029 respectively, therefore you may 

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send updates and information until then. [49-1-HA I 

In the event that during project construction, any archeological resources or remains, 

including, without limitation, human remains, funerary objects, sacred objects, or objects 

of cultural patrimony are uncovered, please Immediately stop construction and contact 

me at (315)952-3109, or the Onondaga Nation's General Counsel Mr. Joseph Heath at 

(315)475-2559. 

If you have any comments or questions about this matter, please do not hesitate to let 

me know. Thank you for your help. 

Sl~~ 

Anthony Gonyea 

A Faithkeeper for the Onondaga Nation 

Onondaga Nation Historic Preservation Office 

Section 106 Representative 

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Appendix A

A-163

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

Hi, 

q/c?-&/~/1 

%!7i S3-f-/~ 

Deb Penrod (deb24532@comcast.net] 

Thursday, October 27, 2011 8:06 PM 

Regner, Lisa 

greetings from a SUPPORTER of Limerick nuclear plant 

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wanted to let you know that I am a complete and full supporter of the Limerick Nuclear plant I am 

lso supportive of the scientific judgement and expertise of those such as yourself who have the ·ob 

f making the decisions. f-=5,-;:-0--:::1~-:-S~R;:::-, 

(I saw your name in an article in the Mercury where the writer was requesting that objections be sent 

to you. I thought I would take advantage of the contact information to state a contrary position.) 

I grew up in coal-mining country, and never saw a stream or a creek with clear water uncontaminated 

by acid mine runoff until I was in my late teens. Opponents to nuclear power have usually never lived 

near coal truck entrances to mines and coal plants, and have probably never lost family members to 

mine cave-ins or black lung. Risks should be minimized as much as possible, but the world will 

always have something that someone objects to. Unscientific or fear-based objections to nuclear 

power are unproductive and do not advance safe or reasonably priced power. 

I work in the pharmaceutical industry (I was first educated as a pharmacist, and then as an attorney; I 

now help to get new vaccines approved, and to help increase vaccination rates). The parallel I see is 

with the group of people who see disaster in every prescription drug product, and complain about 

everything the FDA approves or does. Nothing is ever 'safe' enough for them. 

Please renew Limerick, using the best scientific information and risklbenfit analysis available to ou. 

Thank you. 

Debby Penrod 

215 Amanda Smith Drive 

PO Box 516 

Pottstown, PA 19464 

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Appendix A

A-164

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

DocKoenig@aol.com 

Thursday, October 27, 2011 8:49 PM 

Regner, Lisa 

Fwd: Nuclear Limerick 

From: DocKoenig@aol.com 

To: LisaRegner@nrc.gov 

Sent: 10/27/2011 7:36:13 P.M. Eastern Daylight Time 

Subj: Nuclear Limerick 

g;/c?c:, ;~ ~ 

:/&r/G03~:1~ 

Hello Lisa Limerick should not .be licensed. or relicensed at this t ime. 

doing it because the plant has issues that they are trying to hide. The evacuation pia 

is a joke because we would not get out of our driveways. It would not have worked 10 1'-5-::-1--::-1-::-0::-::S:-11 

years ago and certainly with the population growth it would be much 

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Appendix A

A-165

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

· John & Joyce Webber [jbwebberpc@comcast.net) 

Friday, October 28, 2011 2:41 PM 

Regner, Lisa 

Exlon Limerick Relicensing 

As a resident of New Hanover Twp., Montgomery County, PA (less than 5 miles from Exelon's Limerick Nuclear 

Power Plant), I urge you to vote AGAINST the premature relicensing of that facility. 52-1-0R 

5/C?~J~// 

2) It has now gone far beyond its limitations. ;;2. r _,tC S.3 -1- / ([" 

p1 Tfie ,.., "o""d tfie foo,hty fi., e>ploded wrtfi fiom" '"d "''"•~" 52-3-SE I 0 

(4) The roads to any safe place are overwhelmed with congestion with normal traffic. (5)The plant can n 

longer store its used fuel rods and has asked permission to begin transporting them to another facility. r:5!-:::2,--4-:---::0~S~ 

(5) It is one of the six most dangerous plants in the country because of its proximity to an earthquake fault. 

j6) The surrounding area has abnormally high cancer rates among adults and chrldren. 1152-6-HHI 

For all these reasons and many others too numerous to mention, it would be a truly disastrous mistake to 

extend Exelon's Limerick license for 20 years beyond the current licenses that do no expire until 2024 & 2029! 

Please consider the thousands and thousands of people who would be lost to an accident that could be 

prevented. 

Sincerely, 

Joyce B. Webber 

2338 Holly Drive 

Gilbertsville, PA 19525 

610-326-2584 

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Appendix A

A-166

Mendiola, Doris 

G'/J4-/~// 

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c: 

or·-

From: Anita Baly [ajbaly@yahoo.com] 

Friday, October 28, 2011 3:06 PM 

Regner, Lisa 

--: -·· \~ ,:,..·. 

Sent: 

To: 

Dear Lisa, 

Subject: Limeriok Pl•m Reli"'"""' AG"" 

It was good to meet you at the September 22, 20 II hearing the NRC held at Sunny brook. 

,-..) 

V1 

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As I stated then, I continue to be concerned and puzzled about the very early and pre-mature application of 

Exelon to extend the licenses of the towers. One of those towers does not come up for renewal until 2024 and 

the other 2029. I ask the NRC not to work on the relicensing question for this facility for at least ten years. Th~ 

wait could only ensure better information. The public cannot possibly benefit from a decision to renew the 

licenses at this time. The best decision will be made based on the best possible information. The NRC does no 

have that best information this early. Much will happen in the next ten years. I urge the NRC to wait and see 

r::-:::-:L=--> how any of it affects the prospect of continuing these plants at that later date. 18-5-LR 1 

What can happen in the next ten years that we can all learn from relevantly could be anything. It may be better 

information about how natural disasters are affecting nuclear facilities; we may know more about weather 

patterns that could cause damage. We will certainly know more about the world situation in terms of advances 

in terrorist technological capabilities and goals. We will know more about how well nuclear plants in general 

and the Limerick facility are faring as they continue to age. If someone steps forward to fund studies, we will 

know yet more about cancer rates in the nuclear zone. (We do know something about that now: Joseph 

Mangano and others have done studies already that I assume he has provided to you, and I urge you to consider 

carefully.) · 

One big concern--because of Japan's recent experience and the fact that we had an earthquake here in the 

Limerick plant's territory--is refurbishing the plants so they can withstand earthquakes. It has been widely 

reported--by MSNBC and the AP, using NRC data--that the Limerick plant has the nation's third highest risk of 

being damaged by an earthquake. When the plant was built, no one thought this area would get earthquakes. 

Now we do. I understand that Congress is now or soon will be considering increasing earthquake preparedness 

capabilities at the plants. I fear that if you grant Exelon carte blanche now, the NRC would encourage them to 

do less than thev should to make the nlants safer. 18-6-PA 1 

There can be no good reasons for relicensing now. Please wait as long as possible to do that. Better 

information helps everyone who wants an outcome that is right and socially beneficial--not just profitable for 

Exelon. 

Thank you for your consideration. 

Anita Baly 

,E~_2).5 = /32).~7 23 

~'iA~(?~e~) 
Appendix A

A-167

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_ ~~:? ¢:£aa(J:Y.t.S _ace. __ a -c ---::r.c-4. -~ --- ------ __ ··---- ________________ . _ . ·- , ft-/G72x5 = /3-Y--t-- ~ /-:5 . - - -- - - -- - · . ------ --· -· ·-

j;;~~!?:;f=~-~--~--=~ =---:t:;;;:;p;;;;d2~~e;_) 
Appendix A

A-168

MONTGOMERY COUNTY PLANNING COMMISSION 

box 311 • norristown • pennsylvania • 19404-0311 • 610-278-3722 

office location: suite 201 • one montgomery plaza • swede & airy streets • norristown pa 

FAX 610-278-3941 • Website www.planning.montcopa.org 

JJ :- ~ 

-Tl ~ il 

) 

: 1 ' ; ... 

October 25, 2011 -:; 

:::!1 ~~ 

Chief, Rules Announcements, and Directives Branch 

Mail Stop: TWB-05-B01M 

US Nuclear Regulatory Commission 

Washington, DC 205550001 

RE: Environmental Scoping Comments 

Limerick Nuclear Generating Station 

Division of License Renewal 

NRC-2011-0166 

Dear NRC Staff: 

......_ __ , 

:-ll 1>? 

:-::J V1 

V1 

We have examined thep~Qposed reli~ensing review information presented by NRC staff 

at the Public Hearing held in _Pottstown on September 22 and the information posted 

on th~ web .site. operated ·by the NRC. We feel that. it is vital that any decision 

regarding the relicensirig of the Limerick Nuclear Power Station reflect careful 

consideration of all relevant public health and safety, security, and environmental 

issues that pertain to nuclear power generation in general and the unique conditions 

at the nuclear power generating station situated in Limerick Township. It is our 

understanding that an Environmental Impact Statement will be developed which 

addresses relevant environmental impacts pertaining to socioeconomics, 

environmental justice, and noise; cultural resources, archeology, and geological 

science; atmospheric science, .air-quality; hydrological sciences; transportation and 

land use; radiation protection; nuclear safety, fuel cycle, waste, and accident analysis; 

construction, operation, refurbishment,, and decommissioning; regulatory compliance; 

aquatic ecology; and water quality. Further it is our understanding that a detailed 

safety review will be conducted to review design assumptions; assess aging 

management of safety systems; and determine if new monitoring and inspections are 

needed during the expanded licensing period. 

While we implo~e the NRC to do a full review of both environmental and public safety 

issues pei:'tainin'g to the plant- particularly addressing radioactivity exposures during 

normat operation of the power station and_ during various types of unusual events and 

disasters- we additionally feel that the impact review preceding any relicensing 

decision should also address specific issues .pertaining to the plant based upon it's 

conformity to the Montgomery Co~nty Comprehensive Plan ·and overall county 

development poli~ies. Below we have itemizeci is,sues with respect to land use change 

and growth around the 'power plan,t, 'transportation and evacuation capacity, 

Schuylkill River; and county trruls that we feel warrant consideration in the 

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environmental impact study. 

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~~~ /J?)H-?J13 

£--/(J2)S 7 /9-:~H-?J 3 

~ ::=. /! 11~ (2/-//(..1L) 
Appendix A

A-169

NRC Staff -2- October 25, 2011 

Land Use Change and Growth around the Power Plant: 

Since the original plant was constructed,, the population in. the surrounding 

communities has grown dramatically. LimeriCk Township and nearby Upper · · 

Providence Township have been two of the most rapidly growing communities in the·· 

county. This gro~ largely fueled by access to US Route· 422 Expressway and ' 

available land with suitable infrastructure, has dramatically chan'ged the character of 

the area surrounding the Limerick Power Sta:ticin. In the ·past few years, the ·" · 

Philadelphia Premium Outlet Mall, a 600,000 square foot retail facility, and the 

adjoining Costco shoppi,ng center opened along US Route 422 about one mile north of 

the .. Limerick Power ~h.tti:<,>rJ. proper.cy.: ·The. land adjoining those facilities is being· · 

consideredfor various types of retail and residential. uses. · At' one time,· a large 

gamblirig casino had been pr6posed m this location as well. Other lands in Lower 

Pottsgrove Township near the Liinerick Power Station have also been proposed for 

similar types of uses. · .. · 

While the county planniri:g commission has tried to promote lowerdensities of growth 

in proximity to the Limerick Plant, the local communities and the marketplace favor 

this location for significant development due to its proximity to the US Route 422 

interchange at Township Line/ Evergreen Road. The growth that has taken place in 

the area around the power plant, and in particular the growth taking place·in the area 

immediately adjoining the. plant and the primary access to it; as well as th:e projected 

growth in the future, could complieate e~adJ.ation plans and-the movement of · 

appropriate emergenc)irespi:irtse personnel-to the·plantin the event ofa disaster. 

Certainly this access could be even more critical in the event cif-a natural disaster 

when other roads to the plant niay be·iinpassable. The environmental assessment 

review needs to analyze this 'groWth in the vicinity of the powe·r plant to evaluate what 

impact it would have on plant operations and whether or not safe evacuation can take 

place from the newly developed areas. · · · · ·· 

ransoortation and Evacuation Caoacitv: · · ' · 

ifhe growth in the whole US Route 422 Corridor has raised numerous proposals for 

xpanding the vehicle capacity of the 422 expressway. Current peak commuting 

raffic tie ups on portions of the expressway serve as evidence that it may have 

· nadequate capacity to continue to serve as a safe evacuation corridor for the region. 

lfhe county transportation plan recognizes the need for various road improvements 

fuong the US 422 ,Corridor 1;o address current and future traffic demands. The first 

!Priority projects in the plan include ·interchange improvements· at the Township Line 

!Road/ Evergreen Road intersection which is also the primary access route to the 

!Plant; needed widening and reconstruction of the highway east of the power station 

!between Route 29 and US Route 202 in King of Prussia, reconstruction· of US Route 

22 in the vicinity of Pottstown, and the reconstruction and widening of the Route 422 

!Bridge across the Schuylkill River at Betzwood. A passenger train line is also 

!Proposed as a first priority in the transportation' plan to provide service through the 

jwestem portion of the county into Norristown. The proposed route for this train line is 

he existing Norfolk Southern raillirie that goes through the Limerick Power Station 

!Property. O,ther improvements including the wi&ning and expansion of US Route422 

rom Pottsto&n tO Route 29 and additionhl interchange improvements at Township 

!Line/ Evergreen' Road 'are' proposed as seccindaiy priorities iri 'tlie CO'\lnty plan. In . 

!addition ·to these itn.pr9veinents', several othei-·localired improvements mat may impact 

!evacuation feasibility a:te'prbposed irt'the' county plan . • : ' . ' . ' ' ' . . 

-- .J 

54-2-0S I 

154-3-osl 
Appendix A

A-170

.. ... ,.. _, 

NRC Staff -3- October 25, 2011 

Due to tundmg limitatiOns m Pennsylvania, these proJects are not likely to move 

forward at this time .. The envir.onmental impact review should consider the capacity of 

the roadway facilities to service the Limerick }'lant as well as provide sufficient 

evacuation .·of the area in the eVent of a disaster·. Possible mitigation strategies 'to be 

considen!d in the environmental assessment review cotlld include the role of Exelon in 

funding .tp.~ imp~~t~t road imj)r~vements needed in t~is area to ensure safe 

evacuation and access to the, planf ln any type of disaster. . . ; . 

SchuylklllRlver;, ... , . . ,,,_,. :: •:c-,: '· ' .... . , ... ·· .• ; . ' ·· , . . . .. . 

Since the last i_mpacistaternenJ ,was prep.~~d ~J.i:l 973, the S~hl.!ylkill'Ri\ler hiu=i been · 

designated as a state scenic river anci'as a ,hefitiige,aiea 'for. b()th the state and federi:U 

government. D:ue to these. designations. and the efforts. of non-· profit organizations 

and local govert:lment, acce~s tc) the river has been expanded so that the river has 

become a recreation and heritage tourism destination. Use of the river in the vicinity 

of the plant will continue to grow. With the return of American Shad made possible 

54-3-0S I 

Cont'd 

~~:~~e~h down stream fis~ ladders, in teres~ iJ1 th~ rive,~: ~_quld e':'en grow further in the 1

54_4_8 W 1 

The .Limerick P.lant withdraws sizeable portions of river water. During low flow 

periods, additional.quantities of water are released into the river from the Wadesville 

Mine. and Still Creek Reservoir in Schuylkill County to compensate for the water · 

withdrai.vn at the plant . . Thi~ process was. initially approved .by the. Delawar~ River 

. Basin .Commission (DRBG)jn ~003 and kept ~yi:ive . th,rough, ·;;;_series o·f docket 

amendments. Future river -water use is dependent upon the .ability of this water make 

up system to op~rcate~thi~~ario~~ wat~]; qualitY. and flow,parameters set by DRBC.· 

It is important.to evaluate. th~ bility ofth.e tlSe of the river water and water make up 

system to provide needed water through the expanded plant lifetime . Analysis of this 

aspect of plant operation needs to account for the water quality impact from the total 

dissolved solids in the Wadesville water among other pai-'ameters. If resumed use of 

the Delaware water diversion is anticipated, an evaluation of that system is required tc 

ensure that the capacity is available in the conveyance system and that water qucility 

objectives can be met for discharge .into the East Branch of the Perkiomen Creek. . 

Countv Trails and Open Space: 

The county has been working hard to develop an interconnected system of open space 

and trails along the;! .Schuylkill. River and within other natural re.source areas of the 

county. In doing this, the county has provided funding to local muniCipalities and · 

non-profit conservation organizations to purchase open space and park land; acquirec 

county land and agriculture easements; and developed trails. The Limerick 

Generating Station site contains significant land along the Schuylkill River that has 

been identified as part of the Schuylkill River Greenway in the county plan. The use 154-5-LU I 

and management of these lands relative to the county open spac:e and natural areas 

inventory plans should be evaluated in the relicensing process. . . · 

The Mo~tgo~ery County Op~ri Space Pia~ ~poses a tra,il along the iver thrm,;,gh the 

power plant property .. ,This trail.isprqposed as the Schuylkill East Trail, which would 

be developed as \.Inpave,dtrail. be~ee~ Mo.ti~ Clare and Pottstown. Essentially the 

proposed route,w:ould .foJlow.an old road,.WayJ:>etween t}1e 'river and Norfolk Southern 

rail line, through 'the. ~i~eri~~ P9 ~r St{ltiqn .. si~e .... J'hgugh ~:ucha trail route. wi:iuld · 

appear to raise significant safetY coQ ~m~·.ctu~ · ii:s prop ~~C;l :p~ ximity to th~ j:>ower ~ 
Appendix A

A-171

NRC Staff -4- October 25, 2011 

station, appropriate elements could be de~igned into any trail system to limit its threat 

to plant's security. We have found that trails can enhance the overall security of an 

area since they concentrate users along a defined corridor. Furthermore, trails can 

provide emergency access routes that could be used during different disaster events to 

evacuate people and provide access for emergency response. This trail and the 

m:amigemen~ ~(undeveloped portions of the Limerick Power Station site should be 

considered iri 'the environmental assessment. ,- . 

Community Outreach and Education: 

As part of the environmental assessment process and the evaluation of the plant 

safety and long term operational capacity, we think that it is important for the NRC to 

ma1ntaill.close communication with the community surrounding the plant. Overall 

education about the plant and the associated risks presented by its operation should 

be provided in a variety of ways so that the public is better informed about the plant 

and the overall evaluation taking place as part of the relicensing. 

If you have any questions, please contact me. Also, we offer our assistance in 

providing local information that may be helpful to your review. 

Sincerely,· ·' . . . ! . . 

Michael M. Stokes 

Assistant Director 

mstokes.@montcopa.org 

(610) 278-3729 

~I • • • 

: . ; . • ~l· '· .. ~ . 

c. Thomas Sullivan, Public Safety DepaJ1:!nent 

~ ; . ' .. . ; '·· ' 

_i. -, :· · · · "'!· 

... . . 

., 

. ' 

. •' . 

54-6-0S 

Cont'd I 

54-7-LR I 
Appendix A

A-172

COUNTY OF MONTGOMERY Commissioners 

JAMES R. MATTHEWS 

CHAIRMAN 

JOSEPH M. HOEFFEL BRUCE L. CASTOR, Jr 

THOMAS M. SULLIVAN 

DEPARTMENT DIRECTOR 

October 25, 2011 

Olief, Rules Announcements, and Directives Branch 

Mail Stop: 1WB-05-B01M 

US Nuclear Regulatory O>lnmission 

Washington, DC 205550001 

Re: Environmental Scoping Comments 

Limerick Nuclear Generating Station 

Division of License Renewal 

NRG2011-0166 

Dear NRC Staff: 

Montgomery County 

Department of Public Safety 

Operations Center 

50 Eagleville Road 

Eagleville, PA 19403 

(610)631-6500 FAX (610)631-6536 

www.dps.montcopaorg 

o/c7~/2VI/ 

~?)(..69-¥7~ 

) 

.. ·! 

® 

The Montgomery County Department of Public Safety would like to offer the following comments regarding 

the NRC relicensing review information presented at the Public Hearing held in Pottstown on September 22, 

2011. 

• [The NRC should provide a full review of environmental and public safety issues pertaining to the plant . 

t is understood that emergency responders providing services to the power plant understand the 

. .. y~ · 

--j-!j 

c; 

azards associated with daily operations of the plant. However, in light of events in Japan and recent 

eismic activity in this area, the NRC should clarify the risks associated with plant operations in times of 155-1-0S I usual activity, outage operations, and during times of natural I man-made events that may pose a risk 

o the plant in terms that the public will understand in an attempt to quell public concern. 

• rwe concur that the NRC require Exelon to conform to the Montgomery County Comprehensive Plan 

o not only ensure cooperation in the community, but also in the region. Additionally, it is also 155-2-0SI uggested that Exelon be included in pending roadway infrastructure improvements projects as both a 

take holder and possible source of funding. 

• It is important to note that the 10 - mile Emergency Planning Zone (EPZ) is the second largest in 

population in the nation. As a result of recent development and type of development in the area of 

LGS, it is important to review the Evacuation Tlllle Estimate Study (ETE) on a more timely basis and 

account 155-3-osl for the transient population present in the hotels that have accompanied this development. 

Additionally, funding should be supplied for either Exelon staff or County staff to act as a transient 

planning and outreach specialist to assist these transient population locations with emergency planning. 

• It should be noted that the Evacuation Time Estimate is currently being updated. Required highway 

and roadway infrastructure upgrades should be included as a part of and also as a result of any changes r=:~~~ 

noted in the updated ETE. Special attention for improvement should be given to the local, county and 155-4-0S I 

state roads used for evacuation that feed the larger highways, as many of these roadways are no longer .._ __ __, 

suitable for the amount of traffic that an EPZ evacuation could produce. 

-;1{.2.- JJs -:::: J9 !Y-7-2J .3 

X ;f~ 0-H;:<;z.j 
Appendix A

A-173

• 

-2- October 25, 2011 

• The NRC should consider requiring Exelon to enhance planning for day to day emergency situations 

that require a response from local emergency services. Often times, Fire and EMS access is delayed due 155-5-0S I 

to screening of vehicles and personnel This can cause delay in patient care to potentially life 

• 

• 

threatening illnesses . 

While recreation utilization is of importance and a major mission within this county, homeland security 

must be of a concern with any open access within the vicinity of LGS. However, we concur that with 1-:5::-:5=---=7:-_-,1 

support of local law enforcement and a commitment from LGS to control and monitor access, trail OS 

~ugh put may be accomplished. 

• In an attempt to promote and increase community outreach, the NRC should consider requiring Exelon 

to reopen the LGS Information Visitor Center. As a result of the incident in Fukushima, Japan, the 

Montgomery County Department of Public Safety has a received a higher than normal volume of '==--=--=-=-> 

inquiries concerning nuclear power generation from the public. The LGS Information Center, although 55-8-0S I 

dated, could be upgraded to provide this service to the community to raise awareness and promote 

education of the nuclear power industry. This center could also be incotporated as an educational stop 

on the County Trail system. 

If you have any questions please feel free to contact me. 

Vuy<ruly)O~ 

~'!:,~ Director of Public Safety 

CX:::: R. Graf, CO.O. 

M Stokes, Assistant Director of Planning 

S. Mickalonis, Deputy Director for Emergency Mgt. 

J. Wilson, Radiological Planning Specialist 
Appendix A

A-174

THE 

~·~c EARTH'S BEST DEFENSE 

October 28, 20 II 

Via Electronic Mail 

Ms. Cindy Bladey 

Chief, Rules, Announcements, and Directives Branch 

Office of Administration 

U.S. Nuclear Regulatory Commission 

Washington, D.C.20555-000 I 

Electronic Mail: cindy.bladey@nrc.gov 

RE: Natural Resources Defense Council Comments on Limerick EIS Scoping Process 

NRC Docket ID NRC-2011 -0166 

Dear Ms. Bladey: 

The Natural Resources Defense Council (NRDC) comments today on the Nuclear Regulatory 

Commission's (NRC) Notice of Intent To Prepare an Environmental impact Statement and 

Conduct the Scoping Process for Limerick Generating Station, Units I and 2, (hereinafter 

"Limerick EIS Scoping Process"). 76 Fed. Reg. 53498 (August 26, 20 II ). 

Summary of Comments 

Our comments specifically address the NRC's National Environmental Policy Act ((NEPA) 42 

U.S. C. § 432 1, et seq,) obligations and the need for any environmental analysis the agency 

conducts to include an up-to-date "Severe Accident Mitigation Alternatives" (SAMA) analysis 

that fully incorporates current insights into severe nuclear accident causation and mitigation. 

While we recognize that, as a private entity, the relicensing applicant, Exelon Generation 

Company, is not directly bound by NEPA, the same is not true for the NRC. Given that the 

applicant's ER generally serves as the basis for the Commission's eventual Draft Environmental 

Impact Statement (Draft EIS), and Exelon suggests it need not revise and update its SAMA 

analysis, we are raising this NEPA concern at this early stage in hopes that this matter may be 

addressed before the agency moves to relicense a facility based on a legally insufficient NEPA 

review. 
Appendix A

A-175

C'ommPnf<: 

The original SAMA analysis for the Limerick Generating Station (LGS) is a 1989 report that wa 

issued as the result of a ruling by the U.S. Court of Appeals for the Third Circuit/ which 

concluded that the NRC had failed to consider a "reasonable set" of Severe Accident Mitigation 

Design Alternatives ("SAMDAs"). In 1989, the NRC subsequently adopted this SAMDA 

analysis and agency staff concluded they had "discovered no substantial changes in the proposed 

action as previously evaluated in the FES [Final Environmental Statement] that are relevant to 

environmental concerns nor significant new circumstances or infom1ation relevant to 

environmental concerns and bearing on the licensing of [LGS]". 

As the original LGS SAMDA effort in 1989 was the first mandated effort to focus on SAMAs, 2 

the notion that an updated SAMA analysis need not be completed at the license renewal stage 

(for the exact reactor site that gave birth to the regulatory requirement) we find highly 

objectionable, particularly in light of the catastrophic nuclear accident that befell similar Boiling 

Water Reactor (BWR) units in Japan in March, 2011. It has become clear in the 770 years of 

combined U.S. BWR operational experience since 1989 that domestic and international events 

provide numerous examples of "new information" and make a strong case for the need to 

reconsider all that has been learned about newly discovered risks and vulnerabilities of nuclear 

power plants. 

It has been noted3 that global core damage events happen at a rate that exceeds NRC's 

presumptions of what should be considered safe at plants within the U.S., which implies that 

either the NRC estimates for domestic plants are wrong or that international nuclear plants have 

a core damage frequency much higher than what the NRC deems safe. Either scenario is 

troubling and deserves the industry's full attention and effort. Exelon's 1989 effot1 in response 

to the Court was, respectfully, less than one would have hoped for in light of the seriousness of 

the issue. The LGS 1989 SAMDA can in no way claim necessary conservatism with regard to 

public safety over the total timeframe of a possible sixty year reactor lifetime. 

In contrast to the 1989 SAMDA, relatively recent SAMA analyses conducted in other license 

renewal applications, such as those for sites at Nine Mile Point, Three Mile Island, and the 

Joseph M. Farley Nuclear Plant, to name a few, were considerably more thorough and addressed 

a range of detailed alternatives. Pursuant to regulatory analysis techniques supplied by NRC4 

and aided by an industry-supplied guidance document5

, most modem-day SAMA analyses are 

designed using a fairly prescriptive set of initial assumptions, baseline calculations, and costbenefit arithmetic recipes that employ the use of sophisticated codes in their evaluation of 

potential risk and the benefit of removing this risk. 

1 Limerick Ecology Action v. NRC, 869 F.2d 719 (3'd Cir. 1989) 2 Or SAMDAs in this case, and we use the tenns interchangeably for the purposes of these comments. 3 Global Implications of the Fukushima Disaster for Nuclear Power, T. Cochran, M. McKinzie (NRDC). World 

Federation of Scientists' International Seminars on Planetary Emergencies. Erice, Sicily. Aug 2011. 4 NUREGIBR-0184 Regulatory Analysis Technical Evaluation Handbook, Jan 1997 

'NEI 05-01 [Rev A] Severe Accident Mitigation Alternatives (SAMA) Analysis- Guidance Document, Nov 2005 

156-1-PA I 
Appendix A

A-176

The most common code used is the MELCOR accident consequence code system (MACCS2)6

, 

which provides a modeling framework for calculating the off-site consequences of a severe 

accident. This code accepts an advanced set of input parameters, including population density 

distributions within 50 miles, detailed regional economic data obtained from multiple sources, 

nuclide release scenarios accounting for reactor core inventory, emergency response and 

exposure variables, and meteorological data for plume migration pathways. The current state of 

knowledge regarding the assumptions and understanding of severe accident events has expanded 

and improved in the intervening twenty-two years since the initial SAMDA analysis for LGS. 

While we acknowledge that this analysis was limited by the knowledge available at the time, the 

limitations and shortcomings of a previous era in no way disqualify the claim that, in light of 

numerous advances in modeling capabilities, a library of discovered cost-beneficial SAM As, and 

the saliency of severe accident risks following the disaster at Fukushima Daiichi, not only is 

there new and significant information, there are significant volumes of this information acquired 

since 1989. 

In the licensee's current environmental report, the identification and treatment of new and 

significant information (four items in total) were developed only in the narrow context of how 

they may affect the dated SAMDA analysis. It should go without saying that this approach does 

not comprise all of the applicable new and notewmthy severe accident mitigation strategies 

bearing on the site in question, or serve to remedy gaps and omissions in the original SAMDA 

analysis. 

The entire set of first-stage envisioned alternatives in the initial SAMDA analysis was no more 

than fifteen options. The "analysis" in the current environmental report consists of perfunctory, 

"back-of-the-envelope" calculations in lieu of a proper SAMA analysis. The current operator 

Exelon referred to these considerations as representing an "abundance of caution." We disagree. 

One of the largest problems with the calculations offered, aside from only focusing on an 

arbitrarily limited number of alternatives, is that licensee evaluated each item of new information 

in isolation of the other factors that would also change the cost-benefit conclusion for a particular 

alternative. The effects of each changed parameter (e.g., population, offsite economic risk, cost 

per person-rem averted, and seismic hazards) should be evaluated in a comprehensive model that 

shows the aggregate benefit, as performed in all current day SAMA analyses. Unfortunately, 

their analysis barely scraped the surface of how this new information should actually be 

considered in the context of environmental impacts. 

In comparison, a "reasonable set" of alternatives for another recently relicensed plant included an 

initial consideration of 128 SAMA candidates developed from previous lists at other plants, NRC 

documents, and documents related to advanced power reactor designs. 7 After screening this 

initial set for non-applicable or previously implemented designs as well as combining/dropping 

common-benefit options, the applicant was still left with a set of forty unique SAMA candidates, 

for which it was required to enter preliminary cost estimates in a so-called "Phase I Analysis." A 

6 NUREG/CR-6613, Vol. 1, CodeManualforMACCS2, User'sGuide, D. Chanin & M.L. Young, May 1998 7 Joseph M . Farley Nuclear Plant -Application for License Renewal, Appendix D. EnvironmentalReporl, 

Attachment F. Severe AccidentMitigationAltematives, Sept 2003 

56-1 -PAI 

Cont'd I 
Appendix A

A-177

total of fifteen SAMA candidates survived this screening to enter more detailed cost 

consideration in the Phase II analysis, of which none were deemed cost-beneficial. However, in 

another renewal application, 8 the SAMA analysis found eleven potentially cost-beneficial 

options from an initial set of thirty-three. 56-1-PA I 

In an NRC report discussing insights on SAMAs in connection with plant license renewals,9 th<I'-C_o_n_t_'d _ _. 

agency authors list numerous potentially cost-beneficial SAMAs relating to station blackouts, 

protection and support systems, procedures and training, and external events such as flood, fire 

and seismic hazards. The authors note that "averted onsite costs (AOSC) is a critical factor in 

cost-benefit analyses and tends to make preventative SAMAs more attractive than mitigative 

SAMAs." This AOSC factor was not considered in either the original SAMDA or the recently 

submitted environmental report. 

Finally, NRDC believes that in addition to a comprehensively updated SAMA analysis, the 

licensee or agency must conduct a study that, as part ofthe supplemental environmental impact 

statement, presents postulated accident scenarios showing the full range and weight of 

environmental, economic, and health risks posed by these accidents. This type of study should 

model site-specific severe accidents and illustrate the full consequences of a range of severe 

accident scenarios so that the public and their policy makers can make informed decisions 

whether to continue plant operations after the existing licenses expire, thereby continuing to rur 

the risk of a severe nuclear accident, invest in additional accident mitigation capabilities, or 

alternatively, avoid these risks altogether by relying on a portfolio of low carbon electricity 

generation alternatives that could meet future electricity service needs over the license extensio 

period. 

The SAMA analyses are inadequate in this regard because they only address isolated issues in< 

cost-benefit analysis that discounts the cumulative impacts on displaced populations, regional 

economic losses, and environmental cleanup. These types of calculations do not present a clear 

picture of the potential hazards or costs experienced in the event of a severe accident. Instead 

they tend to mask the full range of accident consequences that policy makers may wish to avoic. 

Recently, NRDC produced an analysis, of the type we believe should be included in the 

Limerick NEPA analysis, to inform ongoing relicensing efforts at the Indian Point nuclear plan 

site10 

In order to illustrate the full extent of a major accident, the NRDC study used the U.S. 

Department of Defense computer model HP AC (Hazard Prediction and Assessment Capability 

to calculate site-specific release radiological source-terms, resulting fallout plumes, and data on 

the effects on nearby populations. The results were compared to similar modeling of the 

Fukushima disaster to provide a sense of scale, and to estimate the rough magnitude of financia 

8 Three Mile Island Nuclear Station Unit l -License Renewal Application, Environmental Repor~ Appendix E. 

SAM4 ANALYSIS 9 Perspectives on Severe AccidentMitigationAltemativesfor U.S. Plant License Renewal, I. Gosh, R. Palla, D. 

Helton, U.S NRC, Sept 2009 (Accession No.: ML092750488) 10 Nuclear Accident at Indian Point: Consequences and Costs, M. McKinzie, Oct 2011 

(http :1 /www. nrdc. org/nuclear/ind.ianpoint/files/NRDC-1336 _Indian _Point_ FSr8mediwn. pdf) 11 Hazard Prediction and Assessment Capability (HPAC), version 4.0.4. Washington, D.C.: Defense Threat 

Reduction Agency, Apr 2004 
Appendix A

A-178

and economic damages that would be incurred if a severe accident were to occur at Indian Point. 

This is not a hypothetical issue. Policy makers in several countries, including Germany and 

Switzerland, have made decisions not to grant nuclear plant license extensions to avoid having t 

endure the continuing risk of severe nuclear plant accidents. 

Regardless of Exelon's own corporate understanding of its legal obligations, NEP A is clear in it 

well-established mandates and what it requires of the NRC. NEPA requires that federal agencies 

characterize environmental impacts broadly to include not only ecological effects, such as 

physical, chemical, radiological and biological effects, but also aesthetic, historic, cultural, 

economic, and social effects.12 NEP A requires an agency to consider both the direct effects 

caused by an action and any indirect effects that are reasonably foreseeable. Effects include 

direct effects caused by the action and occurring at the same time and place and indirect effects 

caused by the action, but later in time or farther removed in distance, but still reasonably 

foreseeable. 

Most specifically, NEP A directs that NRC take a "hard look" at the environmental impacts of its 

proposed action, in this instance the relicensing of two BWR Mark 2 units for an additional20 

years, and compare them to a full range of reasonable alternatives. "What constitutes a 'hard 

look' cannot be outlined with rule-like precision, but it at least encompasses a thorough 

investigation into the environmental impacts of an agency's action and a candid 

acknowledgement of the risks that those impacts entail." Nat 'l Audubon Soc. v. Dept of the Navy 

422 F.3d 174, 185 (4th Cir. 2005) (emphasis added). As a stalking horse for the NRC's draft EIS 

the applicant's ER does not meet this standard. In taking the "hard look" required by law, the 

NRC must therefore address the potential environmental impacts of a range of severe 

accidents-and accident mitigation strategies-especially in light of the new information 

provided by the Fukushima nuclear disaster on the performance of BWR radiological 

containment in a prolonged loss-of-coolant, core-damage scenario. 

For the reasons stated above, NRDC urges that NRC direct that a thorough and lawful SAMA 

analysis be conducted as part of (or supplement to) the required supplemental environmental 

impact statement, the draft of which is currently scheduled for August 2012 and the final SEIS 

currently scheduled for February 2013. Additionally, the full cumulative effect of severe 

accidents must be studied and presented as pali of these documents. These analyses must make 

every effort to meet the current expectations of what these studies should encompass and use the 

necessary guidance and tools commonly utilized by the industry and NRC. The NRC's legal 

obligation to consider new information and determine its nuclear safety significance exists 

independently of whether a SAMA has or has not been prepared previously: in the event a 

SAMA has not been prepared, then new and potentially significant nuclear safety information 

must be included in the initial SAMA; if a previous SAMA exists, then it must be updated to 

reflect this new information, and the resulting costs and benefits ofthe full spectrum of 

reasonable accident mitigation alternatives must be considered as part of the Draft Supplemental 

Environmental Impact Statement, and issued for public comment. 

56-1 -PA I 

Finally, we have grave misgivings regarding the future time-dependence, accuracy, and ~ 1 :--::--:-::::-o 

relevance of the licensee' s current ER, as presumptively incorporated in the NRC's planned i56-2-LR I 

12 40C.F.R § 1508.8 
Appendix A

A-179

SEIS for LGS license extension, given that such license extension will not become effective unti 

the current unit operating licenses expire in 2024 (for Unit 1) and 2029 for Unit 2. We submit 

that any decision to relicense these units must be supported by the most timely NEPA and 

SAMA analysis obtainable within a reasonable interval (e.g. five years) prior to actual expiration 

of the existing licenses. 

56-2-LR I 

Intervals of 12 and 17 years are not required for corporate planning purposes and are far too lomJCont'd 

to credibly sustain the accuracy and relevance of NEP A analyses, or for the NRC to accurately 

project both the future condition ofthe plant, the future state of nuclear safety knowledge, trends 

in local resource use, population, and the affected environment, and the future range of 

reasonable electricity supply alternatives to LGS license extension. By comparison, major 

government owned nuclear installations, such as nuclear laboratories and weapon production 

sites, are required to conduct site-wide NEP A reviews of their operations and facility plans ever 

five years. Using this federal standard for timeliness, the NRC's NEP A analysis for LGS 

relicensing should not commence before 2019, for Unit 1, and before 2024 for Unit 2, or should 

be subjected to mandatory reassessment and supplementation after those dates. 

We further note, given the ex-tended timeframes for expiration of the existing LGS operating 

icenses, that they easily encompass the five year timeframe that the Commission has set out for 

ormulation and implementation of NRC staff safety recommendations to be undertaken 

'without unnecessary delay" in the wake of the Fukushima accident. In light of these important 156-3-0S I 

nuclear safety developments, we seek no reason why this proposed NEPA analysis, and hence 

he entire licensing proceeding that it is required to support, could not be deferred for at least five 

years, until the Commission has completed its decision-making and schedule for implementation 

of post-Fukushima safety upgrades. As noted above, to ensure the timeliness and accuracy of the 

NEP A analysis, the deferral could be even longer (on the order of 7 years for Unit 1 ), to allow 

or the inclusion of the results of the extended mlemakings contemplated under the 

Commission's regulatory response to the Fukushima accident. 

Preparation of the applicant's ER, and the NRC's subsequent SEIS, could then take account of 

these required safety modifications and enhanced severe accident coping strategies, and these 

would be reflected in a significantly revised SAMA analysis. In these comments, we are not 

formally advocating such a deferred pathway for the LGS relicensing proceeding, but merely 

note its plausibility and inherent advantages for all parties to the proceeding. Without such a 

deferral, the only sensible alternative course is to ensure the incorporation of the most up-to-date 

nuclear safety knowledge - "new and significant information" - regarding BWR Mark 2 reactors 

and severe accident mitigation into the current licensing proceeding. 
Appendix A

A-180

Thank you for your consideration of these comments. Please do not hesitate to contact us at 

(202) 289-6868 if you have any questions. 

Sincerely, 

G-z/l !fF&, Geoffrey H. ettus 

C. Jordan Weaver, Ph.D. 

Program Scientist 

..... 

Christopher E. Paine 

Director, Nuclear Program 
Appendix A

A-181

Mendiola, Doris 

From: lorraineruppe@aol.com 

Sent: 

To: 

Subject: 

Friday, October 28, 2011 6:33 PM 

Regner, Lisa 

Fwd:Faultlines close to Limerick Nuclear Plant JJ 

l :n - c 

Ms. Regner, 

Please include this for the record concerning rel icensing of Limerick Power Plant. 

----Original Message-----

From: lorraineruppe <lorraineruppe@aol.com> 

To: letters <letters@pottsmerc.com> 

Sent: Mon, Oct 24, 2011 9:09 pm 

Letter to Editor 

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Exelon is rushing the timeline to reissue a license(18 years ahead of time) to run Limerick Nuclear Plant into the unknown, I 

yet it took more than 5 months for the NRC to get back to me concerning an already known survey of fault lines. 14-13-LR 1 

It took five months for the Nuclear Regulatory Commission to answer my question concerning how close the nearest fault I 

line is to Limerick Nuclear Plant. No wonder! Two faults are dangerously close. Chalfont Fault is only 9 miles East. 14_

14_GE I 

Ramapo Fault is 17 miles Northwest. This is alarming! 1 

The 9-21-11 Mercurv article said" whether or not earthauake risk is a factor in the current relicensina reauest for Limerick 

remains to be seen". It would be grossly unacceptable tor the NRC to ignore Limerick's extreme vulnerability to 

earthquake damage .. 

Earthquake risk should be on the top of of NRC's relicensing concerns for Limerick. Earthquake risks are far greater for 

Limerick than previously realized-increased by 141%. We now know Limerick is 3rd on nation's earthquake risk lis,_t ~-=-:-:,.----, 

.Plus, evidence shows earthquakes in the East can be far stronger than Limerick's " design basis" can withstand. 14-15-P A 1 

There's a good chance that an earthquake can exceed Limerick's design basis, causing a severe nuclear accident, 

jeopardizing the health, safety and financial well being of our entire region. 

The Virginia 8-24-11 earthquake caused shaking in PA at Limerick Nuclear Plant .Since January there have been 2 small 

earthquakes in Philadelphia, only 21 miles from Limerick. 

Shaking and breaking in miles of Limerick's buried underground pipes and cables can lead to nuclear disaster. It's 

disquieting that NRC uses a "visual inspection" to determine damage on buried pipes. Problems may not be identified unt 

it's too late. 

For years the NRC allowed Exelon to do its own studies, to stall and avoid responsible action on fires and earthquakes. 

To save money, Exelon typically concludes Limerick is "safe enough". This is unacceptable! 

10-5-11, the Mercury reported a flaw was found in the mechanism to shut down the nuclear plant. The warning was tied t 

renewed focus on earthquake risk. It's difficult to see how Limerick's design flaws can be fixed, even if Exelon WOULD 

spend the money. 

There is no proof whatsoever Limerick's design can withstand other threats ranging from hurricanes, tornadoes, floods, o 

terrorist attacks to an impact from a jet airliner. 

We need precaution before there is a catastrophe. NRC should close Limerick as soon as possible . 

.£R --:?;;6 =- 13 'JJH- o 3 

c;2LL ~ ~(/_H/f-2-) 
Appendix A

A-182

Mendiola, Doris 

From: 

Sent: 

To: 

Subject: 

sunbeamsky [sunbeamsky@aol.com) 

Monday, October 31, 2011 2:28 PM 

Regner, Lisa 

power plant renewal 

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Appendix A

A-183

Mendiola, Doris 

From: 

Sent: 

To: 

Cc: Subject: 

Good Morning 

Smokowicz, April (Aprii.Smokowicz@graphicpkg.com) 

Wednesday, November 02, 2011 8:49AM 

Regner, Lisa 

msworkdog@verizon. net 

Pottstown Mercury article 10/27/11 

I know this is late according to your article, but I wanted to still send you some information. 

I feel that there is a lot of people that had not known to report anything because of not knowing who to go to. 

I don't understand why the hospitals don' t give statistical information based on areas? 158-1-HH I 

Anyway my daughter Tracey had Leukemia at the age of 2 1/2. Was a patient at Children's Hospital until she 

was 5. With several years of chemotherapy she is now 18 and in remission. We had lived on Limerick Center 

Road for most of our young lives and now with our kids. I don' t know w hat other information you would need 

but I would be happy to get you whatever you might need. 

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Appendix A

A-184

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Appendix A

A-185

.,. ..... ~ . 

~U.S.NRC United Stares Nuc:lc;n ReguLuor.y Commh;siol'l 

Proucting People and the Environment 

LIMERICK GENERATING STATION 

Environmental Scoping Comments 

Division of License Renewal 

N RC-2011-0166 

Written Comment Form 

Must be received on or before October 28, 2011. · Please print clearly. 

Name "\ie \rcr;_ SfJwi' c\?( 

Title: · C \JC 1 z.e f\ 

Organization: (f.l'\.1 t-rcL-· L7t~+e s of H- Mer; cO...... 

Address: 2 <{(' c;-IJ'] /J-otifl-tJ 1/ Y 5 -h 

City:fJv Tkio [# /"1 State: I It r Zip Code: . /'1 I# 0--

Comment Forms may be maileq to: 

Chief, Rules, Announcements, an9 Directiv·94. ~:aAEiR-:- ~.....l:~::..,.....,.....:.___:L....=._:__:.....!::===LJ 

Mail Stop: TWB-05-B01M 

U.S. Nuclear Regulatory Commissio 

Washington, DC 20555-0001 
Appendix A

A-186

7 

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1 APPENDIX B

2 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

3 RENEWAL OF NUCLEAR POWER PLANTS

B-1 

1 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

2 RENEWAL OF NUCLEAR POWER PLANTS

3 The table in this appendix summarizes the National Environmental Policy Act (NEPA) issues for 

4 license renewal of nuclear power plants identified in Table B–1 in Appendix B, Subpart A, to 

5 10 CFR Part 51. Data supporting this table are contained in NUREG–1437, Generic 

6 Environmental Impact Statement for License Renewal of Nuclear Plants. Throughout this 

7 supplemental environmental impact statement (SEIS), “generic” issues are also referred to as 

8 Category 1 issues, and “site-specific” issues are also referred to as Category 2 issues. 

9 Table B–1. Summary of Issues and Findings

Issue Type of Issue Findings

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.
Appendix B

B-2 

Issue Type of Issue Findings

Discharge of chlorine or 

other biocides

Generic SMALL. Effects are not a concern among regulatory and 

resource agencies, and are not expected to be a problem 

during the license renewal term.

Discharge of sanitary 

wastes and minor 

chemical spills

Generic SMALL. Effects are readily controlled through National 

Pollutant Discharge Elimination System (NPDES) permit and 

periodic modifications, if needed, and are not expected to be 

a problem during the license renewal term.

Discharge of other 

metals in wastewater

Generic SMALL. These discharges have not been found to be a 

problem at operating nuclear power plants with 

cooling-tower-based heat dissipation systems and have 

been satisfactorily mitigated at other plants. They are not 

expected to be a problem during the license renewal term.

Water use conflicts 

(plants with oncethrough cooling systems) 

Generic SMALL. These conflicts have not been found to be a 

problem at operating nuclear power plants with 

once-through heat dissipation systems.

Water use conflicts 

(plants with cooling 

ponds or cooling towers 

using makeup water 

from a small river with 

low flow)

Site-specific SMALL OR MODERATE. The issue has been a concern at 

nuclear power plants with cooling ponds and at plants with 

cooling towers. Impacts on in-stream and riparian 

communities near these plants could be of moderate 

significance in some situations. See § 51.53(c)(3)(ii)(A).

Aquatic Ecology (all plants)

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.
Appendix B

B-3 

Issue Type of Issue Findings

Thermal plume barrier to 

migrating fish

Generic SMALL. Thermal plumes have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Distribution of aquatic 

organisms

Generic SMALL. Thermal discharge may have localized effects but 

is not expected to affect the larger geographical distribution 

of aquatic organisms.

Premature emergence of 

aquatic insects

Generic SMALL. Premature emergence has been found to be a 

localized effect at some operating nuclear power plants but 

has not been a problem and is not expected to be a problem 

during the license renewal term.

Gas supersaturation 

(gas bubble disease)

Generic SMALL. Gas supersaturation was a concern at a small 

number of operating nuclear power plants with once-through

cooling systems but has been satisfactorily mitigated. It has 

not been found to be a problem at operating nuclear power 

plants with cooling towers or cooling ponds and is not 

expected to be a problem during the license renewal term.

Low dissolved oxygen in 

the discharge

Generic SMALL. Low dissolved oxygen has been a concern at one 

nuclear power plant with a once-through cooling system but 

has been effectively mitigated. It has not been found to be a 

problem at operating nuclear power plants with cooling 

towers or cooling ponds and is not expected to be a problem 

during the license renewal term.

Losses from predation, 

parasitism, and disease 

among organisms 

exposed to sublethal 

stresses

Generic SMALL. These types of losses have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Stimulation of nuisance 

organisms 

(e.g., shipworms)

Generic SMALL. Stimulation of nuisance organisms has been 

satisfactorily mitigated at the single nuclear power plant with 

a once-through cooling system where previously it was a 

problem. It has not been found to be a problem at operating 

nuclear power plants with cooling towers or cooling ponds 

and is not expected to be a problem during the license 

renewal term.

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).
Appendix B

B-4 

Issue Type of Issue Findings

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 impacts of impingement have not been found 

to be a problem at operating nuclear power plants with this 

type of cooling system and are 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.

Impacts of refurbishment

on groundwater use and 

quality

Generic SMALL. Extensive dewatering during the original 

construction on some sites will not be repeated during 

refurbishment on any sites. Any plant wastes produced 

during refurbishment will be handled in the same manner as 

in current operating practices and are not expected to be a 

problem during the license renewal term.

Groundwater use 

conflicts (potable and 

service water; plants that 

use <100 gallons per 

minute [gpm])

Generic SMALL. Plants using less than 100 gpm are not expected to 

cause any groundwater use conflicts.

Groundwater use 

conflicts (potable and 

service water, and 

dewatering plants that 

use >100 gpm)

Site-specific SMALL, MODERATE, OR LARGE. Plants that use more 

than 100 gpm may cause groundwater use conflicts with 

nearby groundwater users. See § 51.53(c)(3)(ii)(C).

Groundwater use 

conflicts (plants using 

cooling towers 

withdrawing makeup 

water from a small river)

Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts may 

result from surface water withdrawals from small water 

bodies during low flow conditions which may affect aquifer 

recharge, especially if other groundwater or upstream 

surface water users come on line before the time of license 

renewal. See § 51.53(c)(3)(ii)(A).

Groundwater use 

conflicts (Ranney wells) 

Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can result 

in potential groundwater depression beyond the site 

boundary. Impacts of large groundwater withdrawal for 

cooling tower makeup at nuclear power plants using Ranney 

wells must be evaluated at the time of application for license 

renewal. See § 51.53(c)(3)(ii)(C).
Appendix B

B-5 

Issue Type of Issue Findings

Groundwater quality 

degradation (Ranney 

wells) 

Generic SMALL. Groundwater quality at river sites may be degraded 

by induced infiltration of poor-quality river water into an 

aquifer that supplies large quantities of reactor cooling 

water. However, the lower quality infiltrating water would not 

preclude the current uses of groundwater and is not 

expected to be a problem during the license renewal term.

Groundwater quality 

degradation (saltwater 

intrusion)

Generic SMALL. Nuclear power plants do not contribute significantly 

to saltwater intrusion.

Groundwater quality 

degradation (cooling 

ponds in salt marshes)

Generic SMALL. Sites with closed-cycle cooling ponds may degrade 

groundwater quality. Because water in salt marshes is 

brackish, this is not a concern for plants located in salt 

marshes.

Groundwater quality 

degradation (cooling 

ponds at inland sites)

Site-specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle

cooling ponds may degrade groundwater quality. For plants 

located inland, the quality of the groundwater in the vicinity 

of the ponds must be shown to be adequate to allow 

continuation of current uses. See § 51.53(c)(3)(ii)(D).

Terrestrial Ecology

Refurbishment impacts Site-specific SMALL, MODERATE, OR LARGE. Refurbishment impacts 

are insignificant if no loss of important plant and animal 

habitat occurs. However, it cannot be known whether 

important plant and animal communities may be affected 

until the specific proposal is presented with the license 

renewal application. See § 51.53(c)(3)(ii)(E).

Cooling tower impacts 

on crops and ornamental 

vegetation

Generic SMALL. Impacts from salt drift, icing, fogging, or increased 

humidity associated with cooling tower operation have not 

been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the 

license renewal term.

Cooling tower impacts 

on native plants

Generic SMALL. Impacts from salt drift, icing, fogging, or increased 

humidity associated with cooling tower operation have not 

been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the 

license renewal term.

Bird collisions with 

cooling towers

Generic SMALL. These collisions have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Cooling pond impacts on

terrestrial resources

Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all 

sites.

Power line right-of-way

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 

power lines

Generic SMALL. Impacts are expected to be of small significance at 

all sites.
Appendix B

B-6 

Issue Type of Issue Findings

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-ofway

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 or 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

(nonattainment 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 rights-of-way 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.
Appendix B

B-7 

Issue Type of Issue Findings

Microbiological 

organisms (occupational 

health)

Generic SMALL. Occupational health impacts are expected to be 

controlled by the continued application of accepted industrial 

hygiene practices to minimize worker exposures.

Microbiological 

organisms (public 

health)(plants using 

lakes or canals, or 

cooling towers or cooling 

ponds that discharge to 

a small river)

Site-specific SMALL, MODERATE, OR LARGE. These organisms are 

not expected to be a problem at most operating plants, 

except possibly at plants using cooling ponds, lakes, or 

canals that discharge to small rivers. Without site-specific 

data, it is not possible to predict the effects generically. 

See § 51.53(c)(3)(ii)(G).

Noise Generic SMALL. Noise has not been found to be a problem at 

operating plants and is not expected to be a problem at any 

plant during the license renewal term.

Electromagnetic fields – 

acute effects (electric 

shock)

Site-specific SMALL, MODERATE, OR LARGE. Electric shock resulting 

from direct access to energized conductors or from induced 

charges in metallic structures has not been found to be a 

problem at most operating plants and generally is not 

expected to be a problem during the license renewal term. 

However, site-specific review is required to determine the 

significance of the electric shock potential 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.
Appendix B

B-8 

Issue Type of Issue Findings

Public services: public 

utilities

Site-specific SMALL OR MODERATE. An increased problem with water 

shortages at some sites may lead to impacts of moderate 

significance on public water supply availability. See 

§ 51.53(c)(3)(ii)(I).

Public services: 

education

(refurbishment)

Site-specific SMALL, MODERATE, OR LARGE. Most sites would 

experience impacts of small significance but larger impacts 

are possible depending on site- and project-specific factors. 

See § 51.53(c)(3)(ii)(I).

Public services: 

education (license 

renewal term)

Generic SMALL. Only impacts of small significance are expected

Offsite land use 

(refurbishment)

Site-specific SMALL OR MODERATE. Impacts may be of moderate 

significance at plants in low population areas. See 

§ 51.53(c)(3)(ii)(I).

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).

Issue Type of Issue Findings

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.
Appendix B

B-9 

Issue Type of Issue Findings

Severe accidents Site-specific SMALL. The probability weighted consequences of 

atmospheric releases, fallout onto open bodies of water, 

releases to groundwater, and societal and economic impacts 

from severe accidents are small for all plants. However, 

alternatives to mitigate severe accidents must be considered 

for all plants that have not considered such alternatives. 

See § 51.53(c)(3)(ii)(L).

Uranium Fuel Cycle and Waste Management

Offsite radiological 

impacts (individual 

effects from other than 

the disposal of spent fuel

and high-level waste)

Generic SMALL. Offsite impacts of the uranium fuel cycle have been 

considered by the Commission in Table S-3 of this part. 

Based on information in the GEIS, impacts on individuals 

from radioactive gaseous and liquid releases, including 

radon-222 and technetium-99, are small.

Offsite radiological 

impacts (collective 

effects)

Generic The 100-year environmental dose commitment to the U.S. 

population from the fuel cycle, high-level waste, and spent 

fuel disposal is calculated to be about 14,800 person rem, or 

12 cancer fatalities, for each additional 20-year power 

reactor operating term. Much of this, especially the 

contribution of radon releases from mines and tailing piles, 

consists of tiny doses summed over large populations. 

This same dose calculation can theoretically be extended to 

include many tiny doses over additional thousands of years, 

as well as doses outside the United States. The result of 

such a calculation would be thousands of cancer fatalities 

from the fuel cycle, but this result assumes that even tiny 

doses have some statistical adverse health effects 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 

Issue Type of Issue Findings

Offsite radiological 

impacts (collective 

effects)

[continued from previous 

page] 

Generic 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).
Appendix B

B-10

Issue Type of Issue Findings

Offsite radiological

impacts (spent fuel and 

high-level waste

disposal)

Generic For the high-level waste and spent fuel disposal component 

of the fuel cycle, there are no current regulatory limits for 

offsite releases of radionuclides for the current candidate 

repository site. However, if it is assumed that limits are 

developed along the lines of the 1995 National Academy of 

Sciences (NAS) report, “Technical Bases for Yucca 

Mountain Standards,” and that in accordance with the 

Commission’s Waste Confidence Decision, 10 CFR 51.23, a 

repository can and likely will be developed at some site 

which will comply with such limits, peak doses to virtually all 

individuals will be 100 milliroentgen equivalent man 

(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 3x10-3. 

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, 
Appendix B

B-11

Issue Type of Issue Findings

Offsite radiological 

impacts (spent fuel and 

high-level waste

disposal) 

[continued from the 

previous page] 

Generic especially for the candidate repository at Yucca Mountain. 

More meaningful estimates of doses to the population may 

be possible in the future as more is understood about the 

performance of the proposed Yucca Mountain repository. 

Such estimates would involve great uncertainty, especially 

with respect to cumulative population doses over thousands 

of years. The standard proposed by the NAS is a limit on 

maximum individual dose. The relationship of potential new 

regulatory requirements, based on the NAS report, and 

cumulative population impacts has not been determined, 

although the report articulates the view that protection of 

individuals will adequately protect the population for a 

repository at Yucca Mountain. However, the Environmental 

Protection Agency’s (EPA) generic repository standards in 

40 CFR Part 191 generally provide an indication of the order 

of magnitude of cumulative risk to the population that could 

result from the licensing of a Yucca Mountain repository, 

assuming the ultimate standards will be within the range of 

standards now under consideration. The standards in 

40 CFR Part 191 protect the population by imposing the 

amount of radioactive material released over 10,000 years. 

The cumulative release limits are based on the EPA’s 

population impact goal of 1,000 premature 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.
Appendix B

B-12

Issue Type of Issue Findings

Low-level waste storage 

and disposal

Generic SMALL. The comprehensive regulatory controls that are in 

place and the low public doses being achieved at reactors 

ensure that the radiological impacts to the environment will 

remain small during the term of a renewed license. The 

maximum additional onsite land that may be required for 

low-level waste storage during the term of a renewed license 

and associated impacts will be small.

Nonradiological impacts on air and water will be negligible. 

The radiological and nonradiological environmental impacts 

of long-term disposal of low-level waste from any individual 

plant at licensed sites are small. In addition, the 

Commission concludes that there is reasonable assurance 

that sufficient low-level waste disposal capacity will be made 

available when needed for facilities to be decommissioned 

consistent with NRC decommissioning requirements.

Mixed waste storage and 

disposal

Generic SMALL. The comprehensive regulatory controls and the 

facilities and procedures that are in place ensure proper 

handling and storage, as well as negligible doses and 

exposure to toxic materials for the public and the 

environment at all plants. License renewal will not increase 

the small, continuing risk to human health and the 

environment posed by mixed waste at all plants. The 

radiological and nonradiological environmental impacts of 

long-term disposal of mixed waste from any individual plant 

at licensed sites are small. In addition, the Commission 

concludes that there is reasonable assurance that sufficient 

mixed waste disposal capacity will be made available when 

needed for facilities to be decommissioned consistent with 

NRC decommissioning requirements.

Onsite spent fuel Generic SMALL. The expected increase in the volume of spent fuel

from an additional 20 years of operation can be safely 

accommodated on site with small environmental effects 

through dry or pool storage at all plants if a permanent 

repository or monitored retrievable storage is not available.

Nonradiological waste Generic SMALL. No changes to generating systems are anticipated 

for license renewal. Facilities and procedures are in place to 

ensure continued proper handling and disposal at all plants.

Transportation Generic SMALL. The impacts of transporting spent fuel enriched up 

to 5 percent uranium-235 with average burnup for the peak 

rod to current levels approved by the NRC up to 

62,000 megawatt days per metric ton uranium (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.
Appendix B

B-13

Issue Type of Issue Findings

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 the 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 license renewal 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.

Table source: Table B–1 in Appendix B, Subpart A, to 10 CFR Part 51

1 APPENDIX C

2 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

C-1 

1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

2 The Atomic Energy Act of 1954, as amended (42 USC § 2011 et seq.), authorizes the 

3 U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any state to assume 

4 regulatory authority for certain activities (see 42 USC § 2012 et seq.). For example, through the 

5 Agreement State Program, Pennsylvania assumed regulatory responsibility over certain 

6 byproduct, source, and quantities of special nuclear materials not sufficient to form a critical 

7 mass. The Bureau of Radiation Protection, Pennsylvania Department of Environmental 

8 Protection, administers the Pennsylvania State Agreement Program. 

9 In addition to carrying out some Federal programs, state legislatures develop their own laws. 

10 State statutes supplement, as well as implement, Federal laws for protection of air, water 

11 quality, and groundwater. State legislation may address solid waste management programs, 

12 locally rare and endangered species, and historic and cultural resources.

13 The Clean Water Act (33 USC § 1251 et seq., herein referred to as CWA) allows for primary 

14 enforcement and administration through state agencies, given that the state program is at least 

15 as stringent as the Federal program. The state program must conform to the CWA and to the 

16 delegation of authority for the Federal National Pollutant Discharge Elimination System 

17 (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the state. The 

18 primary mechanism to control water pollution is the requirement for direct dischargers to obtain 

19 an NPDES permit, or in the case of states where the authority has been delegated from the 

20 EPA, a State Pollutant Discharge Elimination System permit, under the CWA. In Pennsylvania, 

21 the Pennsylvania Department of Environmental Protection issues and enforces NPDES permits.

22 One important difference between Federal regulations and certain state regulations is the 

23 definition of waters that the state regulates. Certain state regulations may include underground 

24 waters, whereas the CWA only regulates surface waters. The Delaware River Basin 

25 Commission regulates the Groundwater Protection Area in Southeastern Pennsylvania. 

26 C.1. Federal and State Environmental Requirements

27 Limerick Generating Station, Units 1 and 2 (LGS) is subject to Federal and state requirements 

28 for its environmental program. 

29 Table C–1 lists the principle Federal and state environmental regulations and laws applicable to 

30 the review of the environmental resources that could be affected by this project that may affect 

31 license renewal applications for nuclear power plants. See Table C–2 of this supplemental 

32 environmental impact statement for LGS’s compliance status with these requirements. 
Appendix C

C-2 

1 Table C–1. Federal and State Environmental Requirements

Law/regulation Requirements

Current operating license and license renewal

Atomic Energy Act (42 

U.S.C. § 2011 et seq.)

This Act is the fundamental U.S. law on both the civilian and the military 

uses of nuclear materials. On the civilian side, it provides for both the 

development and the regulation of the uses of nuclear materials and 

facilities in the United States. The Act requires that civilian uses of nuclear 

materials and facilities be licensed, and it empowers the NRC to establish 

by rule or order, and to enforce, such standards to govern these uses as 

“the Commission may deem necessary or desirable in order to protect 

health and safety and minimize danger to life or property.”

10 CFR Part 51. Title 10 

Code of Federal 

Regulations (10 CFR) Part 

51, Energy

“Environmental Protection Regulations for Domestic Licensing and 

Related Regulatory Functions.” This part contains environmental 

protection regulations applicable to the NRC’s domestic licensing and 

related regulatory functions.

10 CFR Part 54 “Requirements for Renewal of Operating Licenses for Nuclear Power 

Plants.” This part focuses on managing adverse effects of aging rather 

than noting all aging mechanisms. The rule is intended to ensure that 

important systems, structures, and components will maintain their 

intended function during the period of extended operation.

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

that the NRC issues under the Atomic Energy Act of 1954, as amended 

(68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 

(88 Stat. 1242), provide for the licensing of production and utilization 

facilities. This part also gives notice to all persons who knowingly 

supply—to any licensee, applicant, contractor, or subcontractor—

components, equipment, materials, or other goods or services that relate 

to a licensee’s or applicant’s activities subject to this part, that they may be 

individually subject to NRC enforcement action for violation of § 50.5.

Air quality protection

Clean Air Act (CAA) 

(42 USC § 7401 et seq.)

The Clean Air Act (CAA) is a comprehensive Federal law that regulates air 

emissions. Among other things, this law authorizes EPA to establish 

National Ambient Air Quality Standards (NAAQS) to protect public health 

and public welfare and to regulate emissions of hazardous air pollutants. 

EPA has promulgated NAAQS for six criteria pollutants: sulfur dioxide, 

nitrogen dioxide, carbon monoxide (CO), ozone, lead, and particulate 

matter. All areas of the United States must maintain ambient levels of 

these pollutants below the ceilings established by the NAAQS.

Pennsylvania Air Pollution 

Control Act (P.L. 2119)

The Pennsylvania Air Pollution Control Act establishes procedures for the 

protection of health and public safety during emergency conditions, 

creating a stationary air contamination source permit system and providing 

additional remedies for abating air pollution.

Land use resources protection

Coastal Zone Management 

Act (16 USC § 1451 et seq.)

The Coastal Zone Management Act (CZMA) was established to preserve, 

protect, develop and where possible, restore or enhance, the resources of 

the Nation’s coastal zone. 

Water resources protection

Clean Water Act (CWA) 

(33 USC § 1251 et seq.) 

and the NPDES

(40 CFR 122)

The Clean Water Act (CWA) establishes the basic structure for regulating 

discharges of pollutants into the waters of the United States and regulating 

quality standards for surface waters. 
Appendix C

C-3 

Law/regulation Requirements

Wild and Scenic River Act 

(16 USC § 1271 et seq.)

The Wild and Scenic River Act created the National Wild and Scenic 

Rivers System, which was established to protect the environmental values 

of free flowing streams from degradation by affecting activities, including 

water resources projects.

Safe Drinking Water Act

(42 USC § 300f et seq.)

The Safe Drinking Water Act (SDWA) is the principal Federal law that 

ensures safe drinking water for the public. Under the SDWA, EPA is 

required to set standards for drinking water quality and oversees all states, 

localities, and water suppliers that implement these standards.

Pennsylvania Code, Title 

25, Environmental 

Protection, Part I, 

Department of 

Environmental Protection, 

Chapter 92a, National 

Pollutant Discharge 

Elimination System 

Permitting, Monitoring, and 

Compliance (25 Pa Code 

92a). 

The regulatory provisions contained in this Pennsylvania code implement 

the NPDES Program by the Pennsylvania Department of Environmental 

Protection under the Federal Act. 

Pennsylvania Code, Title 

25, Environmental 

Protection, Part 1, 

Department of 

Environmental Protection 

Chapter 93, Water Quality 

Standards (25 Pa Code 93)

This code sets forth water quality standards for surface waters in the State 

of Pennsylvania, including wetlands. These standards are based upon 

water uses that are to be protected and will be considered by the 

Pennsylvania Department of Environmental Protection in implementing its 

authority under the Clean Streams Law and other statutes that authorize 

protection of surface water quality.

Pennsylvania Code, Title 

25, Environmental 

Protection, Part V, Delaware 

River Basin Commission, 

Chapter 901, General 

Provisions (20 Pa Code 

901)

This code incorporates by reference among other things Parts 401, “Rules 

of Practice and Procedures,” “Basin Regulations; Water Code and 

Administrative Manual Part III Water Quality Regulations,” and 430, 

“Ground Water Protection Area: Pennsylvania,” of 18 CFR containing 

regulations on conservation of power and water resources. 

Pennsylvania’s Clean 

Streams Law 

(35 P.S. Section 691.1 et 

seq.)

The Clean Streams Law provides additional remedies for abating pollution 

of waters; regulates discharges of sewage and industrial wastes; regulates 

the operation of mines; and regulates the impact of mining upon water 

quality, supply, and quantity. The law places responsibilities on 

landowners and land occupiers, and maintains primary jurisdiction over 

surface coal mining in Pennsylvania.

Pennsylvania Safe Drinking 

Water Act (P.L. 206, No. 43 

and 25 PA Code 109)

The Pennsylvania Safe Drinking Water Act protects the public health and 

safety by assuring that public water systems provide a safe and adequate 

supply of water for human consumption by establishing drinking water 

quality standards, permit requirements, and design and construction 

standards.

Waste management and pollution prevention

Resource Conservation and 

Recovery Act (RCRA) 

(42 USC § 6901 et seq.)

RCRA gives EPA authority to control hazardous waste. Before a material 

can be classified as a hazardous waste, it first must be a solid waste as 

defined under the Resource Conservation and Recovery Act (RCRA). 

Hazardous waste is classified under Subtitle C of the RCRA. Parts 261, 

“Identification and Listing of Hazardous Waste,” and 262, “Standards 

Applicable to Generators of Hazardous Waste,” of 40 CFR contain all 

applicable generators of hazardous waste regulations. 
Appendix C

C-4 

Law/regulation Requirements

Pollution Prevention Act 

(42 USC § 13101 et seq.)

The Pollution Prevention Act formally established a national policy to 

prevent or reduce pollution at its source whenever feasible. The Act 

supplies funds for state and local pollution prevention programs through a 

grant program to promote the use of pollution prevention techniques by 

business.

Protected species

Endangered Species Act

(ESA) (16 USC § 1531 et 

seq.)

The Endangered Species Act (ESA) forbids any government agency, 

corporation, or citizen from taking (e.g., harming or killing) endangered 

animals without an Endangered Species Permit. The ESA also requires 

Federal agencies to consult with the U.S. Fish and Wildlife Service or 

National Marine Fisheries Service if any Federal action may adversely 

affect any listed species or designated critical habitat.

Magnuson–Stevens Fishery 

Conservation and 

Management Act (MSA) 

(P.L. 94-265), as amended 

through January 12, 2007

The Magnuson–Stevens Fishery Conservation and Management Act 

(MSA) includes requirements for Federal agencies to consider the impact 

of Federal actions on essential fish habitat and to consult with the National 

Marine Fisheries Service if any activities may adversely affect essential 

fish habitat.

Marine Mammal Protection 

Act (MMPA)

(16 USC § 1361 et seq.)

The Marine Mammal Protection Act (MMPA) prohibits the take of marine 

mammals in U.S. waters or by U.S. citizens on the high seas without an 

MMPA Take Permit issued by the National Marine Fisheries Service. 

MMPA also prohibits importation of marine mammals and marine mammal 

products into the United States.

Fish and Wildlife 

Coordination Act

(16 USC § 661 et seq.)

To minimize adverse impacts of proposed actions on fish and wildlife 

resources and habitat, the Fish and Wildlife Coordination Act requires that 

Federal agencies consult Government agencies regarding activities that 

affect, control, or modify waters of any stream or bodies of water. It also 

requires that justifiable means and measures be used in modifying plans 

to protect fish and wildlife in these waters.

Pennsylvania Code, Title 

58, Recreation, Part II, Fish 

and Boat Commission, 

Chapter 75, Endangered 

Species (58 PA Code 75)

This code provides a lists of endangered, threatened, and candidate 

species in the State of Pennsylvania. The code prohibits the catching, 

taking, killing, possessing, importing or exporting from the 

State of Pennsylvania, selling, or offering to sale or purchase of any 

species listed without a special permit from Executive Director of the 

Pennsylvania Fish and Boat Commission.

Historic preservation

National Historic 

Preservation Act (NHPA) 

(16 USC § 470 et seq.)

The National Historic Preservation Act (NHPA) directs Federal agencies to 

consider the impact of their actions on historic properties. To comply with 

NHPA, Federal agencies must consult with State Historic Preservation 

Officers and, when applicable, tribal historic preservations officers. NHPA 

also encourages state and local preservation societies.

1 C.2. Operating Permits and Other Requirements

2 Table C–2 lists the permits and licenses issued by Federal, state, and local authorities 

3 for activities at LGS.
Appendix C

C-5 

1 Table C–2. Licenses and Permits

Permit Number Dates Responsible Agency

Operating license NPF-39 Issued: 08/8/1985

Expires: 10/26/2024

NRC

Operating license NPF-85 Issued: 08/25/1989

Expires: 06/22/2029

NRC

NPDES Permit PA0051926 Issued: 03/31/2006

Expires: 03/31/2011

(administratively 

continued)

Pennsylvania 

Department of 

Environmental Protection 

(PADEP)

NPDES Permit PA0052221 Issued: 07/1/2009

Expires: 06/30/2014

PADEP

Submission of project for 

Delaware River Basin 

Commission (DRBC) 

approval and determination 

as to whether project impairs 

or conflicts with the DRBC 

comprehensive plan

D-69-210 CP Issued: 11/7/1975

(Rev. 12–

11/02/2004)

Expires: No 

expiration date 

indicated

DRBC

Submission of project for 

DRBC approval and 

determination as to whether 

project impairs or conflicts 

with the DRBC 

comprehensive plan

D-69-52 CP Issued: 02/18/1981

Expires: No 

expiration date 

indicated

DRBC

Submission of project for 

DRBC approval and 

determination as to whether 

project impairs or conflicts 

with the DRBC 

comprehensive plan

D-77-110 CP Issued: 10/24/1984

Expires: No 

expiration date 

indicated

DRBC

Submission of project for 

DRBC approval and 

determination as to whether 

project impairs or conflicts 

with the DRBC 

comprehensive plan

D-65-76 CP Issued: 12/18/1981

Expires: No 

expiration date 

indicated

DRBC

Title V Operating Permit TVOP-46-00038 Issued: 12/07/2009

Expires: 12/07/2014

PADEP

Approval of design 

modifications, operation, and 

maintenance of Bradshaw 

Reservoir Dam

D09-181A Issued: 12/30/1986

Expires: 12/30/2036

PADEP
Appendix C

C-6 

Permit Number Dates Responsible Agency

Maintenance Dredging 

Permit

19616 Issued: 07/16/1976

Expires: No date 

listed on permit

PADEP

Maintenance Dredging 

Permit

19615 Issued: 07/16/1976

Expires: No date 

listed on permit

PADEP

General Permit No. 11 for 

Maintenance Dredging

044610317 Issued: 12/07/2010

Expires: No 

expiration date 

indicated

PADEP

Permit to operate a public 

water system or a 

substantially modified facility

4696508 Issued: 03/25/1997

Expires: No date 

listed on permit

PADEP

Permit to operate a public 

water system or a 

substantially modified facility

4606501 Issued: 06/30/2006

Expires: No date 

listed on permit

PADEP

Permit to operate a public 

water system or a 

substantially modified facility

4609503 Issued: 11/20/2009

Expires: No date 

listed on permit

PADEP

Notification of regulated 

waste activity to obtain an 

EPA identification number for 

hazardous waste

PAD000797951 Issued: 01/01/2001

Expires: N/A

EPA

Certificate of 

registration/permit to operate 

storage tanks

None Issued: 02/04/2011

Expires: Renewed 

Annually

PADEP

Hazardous Materials 

Certificate of Registration

070810 750 001SU Issued: 06/09/2010

Expires: 06/30/2013

U.S. Department of 

Transportation

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

172,943 Issued: 02/25/1972

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

186,609 Issued: 08/15/1977

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

186,610 Issued: 08/15/1977

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section
Appendix C

C-7 

Permit Number Dates Responsible Agency

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

187,162 Issued: 11/17/1977

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

Environmental laboratory 

certificate of accreditation 

under PA Code 252

PA Lab ID No. 46-

0128, Cert. 003

Issued: 08/31/2010

Expires: Renewed 

Annually

PADEP

Permit to operate 

encroachment

E 09-77A Issued: 02/12/1988

Expires: 02/11/2038

PADEP

Approval for disposal of 

licensed material generated 

by licensee’s activities

N/A Issued: 07/10/1996 

(NRC)

Issued: 03/23/1998 

(PADEP)

Expires: No date 

listed on approvals

NRC and PADEP

Source: Exelon 2011

1 C.3. Reference

2 [Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

3 Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

4 License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 

5 Accession No. ML11179A104. 

1 APPENDIX D

2 CONSULTATION CORRESPONDENCE

D-1 

1 CONSULTATION CORRESPONDENCE

2 D.1. Background

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

4 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 

5 (NHPA) require that Federal agencies consult with applicable State and Federal agencies and 

6 groups before taking action that may affect threatened or endangered species, essential fish 

7 habitat, or historic and archaeological resources, respectively. This appendix contains 

8 consultation documentation.

9 Table D–1 lists the consultation documents sent between the U.S. Nuclear Regulatory 

10 Commission (NRC) and other agencies. The NRC staff is required to consult with these 

11 agencies based on the requirements of the statutes listed above.

12 Table D–1. Consultation Correspondence

Author Recipient Date of Letter/email

Wrona, D., NRC M. Roberts, U.S. Fish and Wildlife 

Service (USFWS)

September 8, 2011

ML11258A248

Wrona, D., NRC O. Braun, Pennsylvania Game 

Commission

September 8, 2011

ML11234A065

Wrona, D., NRC C. Urbarn, Pennsylvania Fish &

Boat Commission

September 8, 2011

ML11234A024

Wrona, D., NRC H. Ellis, Absentee-Shawnee Tribe of 

Oklahoma

September 13, 2011

ML112340045

Wrona, D., NRC B. Obermeyer, Delaware Tribe September 13, 2011

ML112340045

Wrona, D., NRC R. Dushane, Cultural Resource Officer, 

Eastern Shawnee Tribe of Oklahoma

September 13, 2011

ML112340045

Wrona, D., NRC C. Halftown, Heron Clan Representative, 

Cayuga Nation

September 13, 2011

ML112340045

Wrona, D., NRC T. Francis, Tribal Historic Preservation 

Office, Delaware Nation

September 13, 2011

ML112340045

Wrona, D., NRC R. Hill, Tonawanda Seneca Nation September 13, 2011

ML112340045

Wrona, D., NRC N. Patterson, Tuscarora Nation September 13, 2011

ML112340045

Wrona, D., NRC J. Bergevin, Oneida Indian Nation September 13, 2011

ML112340045

Wrona, D., NRC C. Burke, Oneida Nation of Wisconsin September 13, 2011

ML112340045

Wrona, D., NRC T. Gonyea, Onondaga Nation September 13, 2011

ML112340045

Wrona, D., NRC L. Watt, Seneca Nation of Indians September 13, 2011

ML112340045
Appendix D

D-2 

Author Recipient Date of Letter/email

Wrona, D., NRC P. Barton, Seneca-Cayuga Tribe

of Oklahoma

September 13, 2011

ML112340045

Wrona, D., NRC S. White, Stockbridge-Munsee Band 

of the Mohican Nation of Wisconsin

September 13, 2011

ML112340045

Wrona, D., NRC A. Printup, St. Regis Mohawk Tribe September 13, 2011

ML112340045

Wrona, D., NRC K. Jumper, Shawnee Tribe September 13, 2011

ML112340045

Wrona, D., NRC J. Cutler, Pennsylvania Historic and 

Museum Commission

September 15, 2011

ML11221A265

Wrona, D., NRC C. Firestone, Pennsylvania Department 

of Conservation & Natural Resources

September 16, 2011

ML11230B346

Wrona, D., NRC T. McCulloch, Advisory Council on 

Historical Preservation

September 16, 2011

ML11245A083

Obermeyer, B., Delaware Tribe

Historic Preservation Office

D. Wrona, NRC September 23, 2011

ML11279A113

White, S., Stockbridge-Munsee 

Tribal Historic Preservation Office D. Wrona, NRC September 28, 2011ML11279A114

Urban, C., Pennsylvania Fish & 

Boat Commission D. Wrona, NRC October 5, 2011ML11291A077

Gonyea, A., Onondaga Nation D. Wrona, NRC October 15, 2011

ML11305A006

McLearn, D., Pennsylvania 

Historical & Museum Commission, 

Bureau for Historic Preservation

D. Wrona, NRC October 26, 2011

ML11307A383

Mowery, O., Pennsylvania Game

Commission D. Wrona, NRC November 17, 2011ML11339A042

Riley, C., USFWS D. Wrona, NRC November 22, 2011

ML11339A043

Susco, J., NRC D. Morris, National Marine Fisheries 

Service

May 30, 2012

ML12138A347

Colligan, M., National Marine 

Fisheries Service J. Susco, NRC June 27, 2012ML12226A163
1 APPENDIX E

2 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

E-1 

1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

2 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

3 Regulatory Commission (NRC) and external parties as part of its environmental review for 

4 Limerick Generating Station, Units 1 and 2 (LGS). All documents, with the exception of those 

5 containing proprietary information, are available electronically from the NRC’s Public Electronic 

6 Reading Room found on the Internet at the following Web address: http://www.nrc.gov/reading7 rm.html. From this site, the public can gain access to the NRC’s Agencywide Documents 

8 Access and Management System (ADAMS), which provides text and image files of NRC’s 

9 public documents in ADAMS. The ADAMS accession number for each document is included in 

10 the following list. To locate a reference in ADAMS, click on the “Simple Search” tab at the top of 

11 the web page, and enter the ADAMS accession number in the search box.

12 E.1. Environmental Review Correspondence

13 Table E–1 lists the environmental review correspondence in date order beginning with the 

14 request by Exelon to renew the operating license for LGS.

15 Table E–1. Environmental Review Correspondence

Date Correspondence Description ADAMS No.

June 22, 2011 Letter from Exelon forwarding the LGS license renewal 

application and request to renew operating licenses for 

additional 20 years

ML11179A096

June 30, 2011 NRC press release announcing the availability of license 

renewal application for LGS

ML11181A084

July 13, 2011 Letter to Exelon, “Receipt and Availability of the License 

Renewal Application for the Limerick Generating Station, 

Units 1 and 2” 

ML11180A040

July 26, 2011 Federal Register Notice of Receipt and Availability of 

Application for Renewal of Limerick Generating Station, 

Units 1 and 2 Facility Operating License Nos. NPF-39 and 

NPF-85 for an Additional 20-Year Period (76 FR 44624)

ML11180A178

August 12, 2011 Letter to Exelon, “Determination of Acceptability and Sufficiency 

for Docketing, Proposed Review Schedule, and Opportunity for 

a Hearing Regarding the Application from Exelon Generating 

Station Company, LLC for Renewal of the Operating Licenses 

for Limerick Generating Station, Units 1 and 2”

ML11206A206

August 17, 2011 Letter to Exelon, “Notice of Intent to Prepare an Environmental 

Impact Statement and Conduct Scoping Process for License 

Renewal for the Limerick Generating Station, Units 1 and 2”

ML111213A206

August 24, 2011 Federal Register Notice of Acceptance for Docketing of the 

Application and Notice for Opportunity for Hearing Regarding the 

Renewal of Facility Operating License Nos. NPF-39 and NPF-85 

for an Additional 20 Years Period, Exelon Generation Company , 

LLC, Limerick Generating Station (76 FR 52992)

ML11206A206

August 26, 2011 Federal Register Notice of Intent To Prepare an Environmental 

Impact Statement and Conduct Scoping Process for Limerick 

Generating Station, Units 1 and 2 (76 FR 53498)

ML11214A048
E-2 

Date Correspondence Description ADAMS No.

September 7, 2011 NRC press release announcing the LGS license renewal 

environmental scoping meeting 

ML11250A162

September 8, 2011 Letter to Mr. Mark Roberts, U.S. Fish and Wildlife Service ML11258A248

September 8, 2011 Letter to Ms. Olivia Braun, Environmental Planner, Pennsylvania 

Game Commission

ML11234A650

September 8, 2011 Letter to Mr. Chris Urban, Pennsylvania Fish and Boat 

Commission

ML11234A024

September 13, 2011 Letter to Henryetta Ellis, Absentee-Shawnee Tribe of Oklahoma ML112340045

September 13, 2011 Letter to Clint Halftown, Heron Clan Representative, Cayuga 

Nation

ML112340045

September 13, 2011 Letter to Ms. Tamara Francis, Tribal Historic Preservation Office, 

Delaware Nation

ML112340045

September 13, 2011 Letter to Dr. Brice Obermeyer, Delaware Tribe ML112340045

September 13, 2011 Letter to Ms. Robin Dushane, Cultural Resource Officer, 

Eastern Shawnee Tribe of Oklahoma

ML112340045

September 13, 2011 Letter to Chief Rogers Hill, Tonawanda Seneca Nation ML112340045

September 13, 2011 Letter to Mr. Neil Patterson, Director, Tuscarora Nation ML112340045

September 13, 2011 Letter to Ms. Kim Jumper, Tribal Historic Officer, Shawnee

Tribe

ML112340045

September 13, 2011 Letter to Mr. Arnold Printup, Historic Preservation Officer, 

St. Regis Mohawk Tribe

ML112340045

September 13, 2011 Letter to Ms. Sherry White, Cultural Preservation Officer,

Stockbridge-Munsee Band of the Mohican Nation of Wisconsin

ML112340045

September 13, 2011 Letter to Mr. Paul Barton, Historic Preservation Officer

Seneca-Cayuga Tribe of Oklahoma

ML112340045

September 13, 2011 Letter to Ms. Lane Watt, Tribal Historic Preservation Office

Seneca Nation of Indians

ML112340045

September 13, 2011 Letter to Mr. Tony Gonyea, Faithkeeper, Onondaga Nation ML112340045

September 13, 2011 Letter to Ms. Corina Burke, Tribal Historic Preservation Office

Oneida Nation of Wisconsin

ML112340045

September 13, 2011 Letter to Mr. Jesse Bergevin, Historian, Oneida Indian Nation ML112340045

September 15, 2011 Letter to Ms. Jean Cutler, Deputy State Historic Preservation 

Officer, Pennsylvania Historical and Museum Commission

ML11221A265

September 16, 2011 Letter to Mr. Chris Firestone, Pennsylvania Department of 

Conservation & Natural Resources

ML11230B346

September 16, 2011 Letter to Mr. Tom McCulloch, Advisory Council on Historic 

Preservation

ML11245A083

September 23, 2011 Letter from Dr. Brice Obermeyer, Delaware Tribe Historic 

Preservation Office

ML11279A113

September 28, 2011 Letter from Ms. Sherry White, Tribal Historic Preservation 

Officer, Stockbridge-Munsee Tribal Historic Preservation Office

ML11279A114
Appendix E

E-3 

Date Correspondence Description ADAMS No.

October 5, 2011 Letter from Mr. Chris Urban, Pennsylvania Fish and Boat 

Commission

ML11291A077

October 15, 2011 Letter from Mr. Anthony Gonyea, Onondaga Nation ML11305A006

October 26, 2011 Letter from Mr. Douglas McLearen, Pennsylvania Historical and 

Museum Commission

ML11307A383

November 17, 2011 Letter from Ms. Olivia Mowery, Pennsylvania Game Commission ML11339A042

November 22, 2011 Letter from Mr. Clinton Riley, U.S. Fish and Wildlife Service ML11339A043

February 24, 2012 Letter to Exelon, “Request for Additional Information for the 

Review of the Limerick Generating Station, Units 1 and 2, 

License Renewal Application Environmental Review”

ML12041A443

March 27, 2012 Letter from Exelon, “Limerick Generating Station, Units 1 and 

2–Response to NRC Request for Additional Information, Dated 

February 28, 2012, Related to the License Renewal Application”

ML12088A366

April 11, 2012 Memorandum, “Summary of Telephone Conference Call on 

February 23, 2012, Between the U.S. Nuclear Regulatory 

Commission and Exelon Generation Company, LLC, 

Concerning Request for Additional Information Pertaining to the 

Limerick Generating Station License Renewal Application”

ML12083A211

May 21, 2012 Summary of Site Audit Related to the Environmental Review of 

the License Renewal Application for Limerick Generating 

Station, Units 1 and 2

ML12124A127

May 30, 2012 Letter to Mr. Daniel Morris, National Marine Fisheries Service ML12138A347

June 27, 2012 Letter from Ms. Mary Colligan, National Marine Fisheries Service ML12226A163

1 APPENDIX F

2 DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

3 IMPACT ANALYSIS 

F-1 

1 DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

2 IMPACTS ANALYSIS

3 F.1. Description of Projects Considered

4 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

5 in Sections 4.1–4.9, are combined with other past, present, and reasonably foreseeable future 

6 actions regardless of what agency (Federal or non-Federal) or person undertakes such other 

7 actions. The U.S. Nuclear Regulatory Commission (NRC) staff (staff) used the information in 

8 the environmental report (ER); responses to requests for additional information (RAIs); 

9 information from other Federal, State, and local agencies; scoping comments; and information 

10 gathered during the visits to the Limerick Generating Station, Units 1 and 2 (LGS) site to identify 

11 other past, present, and reasonably foreseeable actions. Other actions and projects that were 

12 identified during this review, and considered in the staff’s independent analysis of the potential 

13 cumulative effects, are described in Table F–1. 

14 Table F–1. Projects and Actions Considered in the Cumulative Impacts Analysis

Project Name Summary of Project Location Status

Moser Generating 

Station Oil Plant

60 MW, 3 unit oil-fired peaking plant Lower 

Pottstown 

Township, 

approximately 

2 miles (mi) 

west (W) of 

LGs

Operational (Exelon 

Corp. 2012); (Exelon 

2011)

Linfield Energy 

Center 

616 MW, 3 unit natural gas plant 3 mi northwest 

(NW) of LGS

Air-quality permitted 

in 2002, but project 

“withdrawn” and not 

constructed (EJN); 

(Enviro 2002)

Schuylkill 

Generating 

Station 

196 MW, 3 unit oil power plant 29 mi NW of 

LGS

Operational (Exelon 

Corp. 2012)

Cromby 

Generation 

Station

2 unit fossil fuel power plant located 

on the Schuylkill River

8 mi south (S) 

of LGS

Both units were 

retired from service in 

2011 (Exelon Corp. 

2012)

Titus Coal Plant 261 MW, 5 unit coal power plant 18 mi NW of 

LGS

Operational (GEO 

2012a)

Ontelaunee 

Energy Center 

Gas Plant

728 MW, 3 unit gas power plant 23 mi northeast 

(NE) of LGS

Operational (GEO 

2012b)

Montenay 

Montgomery LP

Waste Plant

32 MW, 1 unit waste power plant 17 mi southeast 

(SE) of LGS

Operational (GEO 

2012c)

Grays Ferry 

Cogeneration Gas 

Plant

193 MW, 2 unit gas power plant 29 mi SE of 

LGS

Operational (GEO 

2012d)
Appendix F

F-2 

Project Name Summary of Project Location Status

Chester 

Generating 

Station Oil Plant

56 MW, 3 unit oil power plant 20 mi 

southwest (SW) 

of LGS

Operational (GEO 

2012e)

Philadelphia 

Refinery Waste 

Plant

30 MW, 3 unit waste power plant 30 mi SE of 

LGS

Operational (GEO 

2012f)

Delaware 

Generating 

Station Oil Plant

392 MW, 4 unit oil power plant 30 mi SE of

LGS

Operational (GEO 

2012g)

Eddystone 

Generation 

Station Coal Plant

1,589 MW, 8 unit coal power plant 20 mi SE of 

LGS

Operational (GEO 

2012h)

Florida Power & 

Light Energy 

Marcus Hook Gas 

Plant

836 MW, 4 unit gas power plant 30 mi SE of 

LGS

Operational (GEO 

2012i)

Chester 

Operational Coal 

Plant

67 MW, 1 unit coal power plant 29 mi SE of 

LGS

Operational (GEO 

2012j)

Royersford 

Borough

Sewage/wastewater treatment plant that 

discharges 54 millions of gallons per day 

(mgd) to the Schuylkill River

4 mi SE of LGS Operational (EPA 

2012a)

Spring City 

Borough

Sewage/wastewater treatment plant that 

discharges .345 mgd to the Schuylkill 

River

7 mi SE of LGS Operational (EPA 

2012a)

Limerick 

Township 

Municipal 

Authority

Sewage/wastewater treatment plant that 

discharges 1.7 mgd to the Schuylkill River

3 mi SE of LGS Operational (EPA 

2012a)

East Vincent 

Municipal 

Authority

Sewage/wastewater treatment plant that 

discharges .5 mgd to the Schuylkill River

4 mi S of LGS Operational (EPA 

2012a)

North Coventry 

Municipal 

Authority

Sewage/wastewater treatment plant that 

discharges 1.5 mgd to the Schuylkill River

2 mi W of LGS Operational (EPA 

2012a)

Phoenixville 

Borough Sewage 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges 4 mgd to the Schuylkill River

9 mi SE of LGS Operational (EPA 

2012a)

Lower Frederick 

Township Sewage 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges .2 mgd to the Perkiomen 

Creek

7 mi NE of LGS Operational (EPA 

2012a)
Appendix F

F-3 

Project Name Summary of Project Location Status

Schwenksville 

Borough Authority 

Sewage 

Treatment Plant 

Sewage/wastewater treatment plant that 

discharges .3 mgd to the Perkiomen 

Creek

7 mi NE of LGS Operational (EPA 

2012a)

Pottstown Water 

Treatment Plant

Sewage/wastewater treatment plant 

withdraws up to 5 mgd from the Schuylkill 

River

2 mi W of LGS Operational (EPA 

2012b) 

Pennsylvania 

American Water 

Company, Shady 

Lane Water 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges .111 mgd to the Schuylkill 

River

2 mi S of LGS Operational (EPA 

2012a)

JBS Souderton 

Inc., Industrial 

Waste Water 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges .832 mgd to the Skippack 

Creek at River Mile 92.47 – 32.3 – 3.0 – 

12.8 (Delaware River – Schuylkill River – 

Perkiomen Creek – Skippack Creek)

15 mi NE of 

LGS

Operational (DRBC 

2011)

Warwick Drainage 

Company

Public wastewater collection, treatment, 

and disposal that discharges .0135 mgd to 

the French Creek (Schuylkill River 

Tributary)

8 mi NW of 

LGS

Operational (EPA 

2012a)

Doehler-Jarvis 

Limited 

Partnership

Aluminum die casting 5 mi W of LGS Operational (EPA 

2012a)

Sun Co., Inc. Major gas service station 3 mi NE of LGS Operational (EPA 

2012a)

Pottstown Trap 

Sanatoga Quarry

Quarry 3,650 feet NW, 

directly 

adjacent to 

Schuylkill River 

and contiguous 

with the LGS 

plant site 

property

Operational (Exelon 

2011)

Uniform Tubes, 

Inc.

Steel parts manufacturing 6 mi SE of LGS Operational (EPA 

2012a)

Plotts Oil Co. Heating oil distribution 4 mi SE of LGS Operational (EPA 

2012a)

Specialty 

Chemical 

Systems

Inorganic chemical production 4 mi SE of LGS Operational (EPA 

2012a)

Spring City 

Electric 

Manufacturing 

Company

Iron foundry discharges 4 mi SE of LGS Operational (EPA 

2012a)

Unitech Services 

Group, Inc.

Industrial launderer 3 mi SE of LGS Operational (EPA 

2012a)
Appendix F

F-4 

Project Name Summary of Project Location Status

Smurfit-Stone 

Container

Paper packaging 9 mi SE of LGS Operational (EPA 

2012a)

Wyeth 

Pharmaceuticals

Biotechnology research and development 8 mi SE of LGS Operational (EPA 

2012a)

GlaxoSmithKline Pharmaceutical manufacturing 7 mi SE of LGS Operational (EPA 

2012a)

Evansburg State 

Park

3,349 acre state park in south-central 

Montgomery County between Norristown 

and Collegeville

10 mi east of 

LGS

Operational (DCNR 

2012a)

Fort Washington 

State Park

493 acre state park in Springfield and 

Whitemarsh Townships, Montgomery 

County

20 mi SE of 

LGS

Operational (DCNR 

2012b)

Norristown Farm 

Park

690 acre park in East Norriton and West 

Norriton Townships and the Borough of 

Norristown

14 mi SE of 

LGS

Operational (DCNR 

2012c)

Marsh Creek 

State Park

1,727 acre state park in Chester County 11 mi SW of 

LGS

Operational (DCNR 

2012d)

Pickering Creek 

Preserve

25 acre park in Schuylkill Township 13 mi SE of 

LGS

Operational

Valley Forge 

National Park

3,500 acre national historic park 11 mi SE of 

LGS

Operational

French Creek 

State Park

7,730 acre state park in North Coventry 

and Warwick Townships in Chester 

County and Robeson and Union 

Townships in Berks County

10 mi W of LGS Operational (DCNR 

2012e)

Ridley Creek 

State Park

2,606 acres of Delaware County 

woodlands and meadows

25 mi SE of 

LGS

Operational (DCNR 

2012f)

Independent 

Spent Fuel 

Storage 

Installation (ISFSI)

The ISFSI provides dry storage for spent 

fuel at the LGS site

At LGS Operational (Exelon 

2011)

Recticon/Allied 

Steel Corp.

Comprehensive Environmental Response, 

Compensation, and Liability Act 

(CERCLA) site 

1 mi S of LGS CERCLA site (EPA) 

Occidental 

Chemical 

Corporation 

Remediation Site 

(Formerly 

Firestone Tire and 

Rubber 

Manufacturing 

Facility)

Occidental Chemical Corporation is 

remediating under the oversight of EPA

2.5 mi W of 

LGS 

Superfund site 

(Exelon 2011)
Appendix F

F-5 

1 F.2. References

2 [DRBC] Delaware River Basin Commission. 2012. DOCKET NO. D-1996-021-4, JBS 

3 Souderton, Inc., Industrial Wastewater Treatment Plant, Franconia Township, Montgomery 

4 County, Pennsylvania. Available at 

5 <http://www.state.nj.us/drbc/library/documents/dockets/1996-021-4.pdf> (accessed 

6 7 July 2012).

7 [EJN] Energy Justice Network. Linfield Energy Center. Available at 

8 <http://www.energyjustice.net/map/displayfacility-68986.htm> (accessed 11 July 2012).

9 [Enviro] Enviro.blr.com. 2002. Environmental Compliance News. “DEP Issues Air Plan Approval 

10 to Florida Power and Light for Its Linfield Energy Center Project.” April 10, 2002. Available at

11 <http://enviro.blr.com/environmental-news/air/air-permitting/DEP-Issues-Air-Plan-Approval-to12 Florida-Power-and-/> (accessed 11 July 2012). 

13 [EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts. Air Facility System (AFS). 

14 Available at 

15 <http://ofmpub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=420

16 2900003> (accessed 11 July 2012).

17 [EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts, Permit Compliance System 

18 (PCS) and Integrated Compliance Information System (ICIS) databases. Available at 

19 <http://www.epa.gov/enviro/facts/pcs-icis/index.html> (accessed 11 July 2012).

20 [EPA] U.S. Environmental Protection Agency. 2012b. Envirofacts. Comprehensive 

21 Environmental Response, Compensation, and Liability Information System (CERCLIS). 

22 Available at 

23 <http://ofmpub.epa.gov/enviro/cerclisquery.get_report?pgm_sys_id=PAD002353969>

24 (accessed 11 July 2012)

25 [Exelon Corp] Exelon Corporation. 2012. Energy Diversity for Pennsylvania. Available at 

26 <http://www.exeloncorp.com/community/locations/pennsylvania.aspx> (accessed 11 July 2012).

27 [Exelon] Exelon Generation Company, LLC. 2011. Applicant’s Environmental Report –Operating 

28 License Renewal Stage, Limerick Generating Station, Units 1 and 2, Docket Numbers 50-352 

29 and 50-353, License Numbers NPF-39 and NPF-85. Exelon Generation Company, LLC. 

30 Agencywide Documents Access and Management Systems Accession No. ML11179A104. 

31 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012a. Available at 

32 <http://www.dcnr.state.pa.us/stateparks/findapark/evansburg/index.htm> (accessed 

33 8 August 2012).

34 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012b. Available at 

35 <http://www.dcnr.state.pa.us/stateparks/findapark/fortwashington/index.htm> (accessed 

36 8 August 2012).

37 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012c. Available at 

38 <http://www.dcnr.state.pa.us/stateparks/findapark/norristown/index.htm> (accessed 

39 8 August 2012).

40 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012d. Available at 

41 <http://www.dcnr.state.pa.us/stateparks/findapark/marshcreek/index.htm> (accessed 

42 8 August 2012).
Appendix F

F-6 

1 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012e. Available at 

2 <http://www.dcnr.state.pa.us/stateparks/findapark/frenchcreek/index.htm> (accessed 

3 8 August 2012).

4 [DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012f. Available at 

5 <http://www.dcnr.state.pa.us/stateparks/findapark/ridleycreek/index.htm> (accessed 

6 8 August 2012).

7 [GEO] Global Energy Observatory. 2012a. Available at 

8 <http://globalenergyobservatory.org/geoid/1737> (accessed 11 July 2012).

9 [GEO] Global Energy Observatory. 2012b. Available at 

10 <http://globalenergyobservatory.org/geoid/4624> (accessed 11 July 2012).

11 [GEO] Global Energy Observatory. 2012c. Available at 

12 <http://globalenergyobservatory.org/geoid/4351> (accessed 11 July 2012).

13 [GEO] Global Energy Observatory. 2012d. Available at 

14 <http://globalenergyobservatory.org/geoid/3386> (accessed 11 July 2012).

15 [GEO] Global Energy Observatory. 2012e. Available at 

16 <http://globalenergyobservatory.org/geoid/2651> (accessed 11 July 2012).

17 [GEO] Global Energy Observatory. 2012f. Available at 

18 <http://globalenergyobservatory.org/geoid/4778> (accessed 11 July 2012).

19 [GEO] Global Energy Observatory. 2012g. Available at 

20 <http://globalenergyobservatory.org/geoid/5080> (accessed 11 July 2012).

21 [GEO] Global Energy Observatory. 2012h. Available at 

22 <http://globalenergyobservatory.org/geoid/530> (accessed 11 July 2012).

23 [GEO] Global Energy Observatory. 2012i. Available at 

24 <http://globalenergyobservatory.org/geoid/3221> (accessed 11 July 2012).

25 [GEO] Global Energy Observatory. 2012j. Available at 

26 <http://globalenergyobservatory.org/geoid/320> (accessed 11 July 2012).
NRC FORM 335 

(12-2010) 

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER 

NRCMD 3.7 

BIBLIOGRAPHIC DATA SHEET 

(See instructions on the reverse) 

2. TITLE AND SUBTITLE 

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Supplement 49 Regarding Limerick Generating Station, Units 1 and 2 

Draft Report 

5. AUTHOR(S) 

See Chapter 10 

(Assigned by NRC, Add Vol., Supp., Rev., 

and Addendum Numbers, if any.) 

NUREG-1437, Supplement 49 

3. DATE REPORT PUBLISHED 

r- ::~; I ;~~----

4. FIN OR GRANT NUMBER 

6. TYPE OF REPORT 

Technical 

7. PERIOD COVERED (Inclusive Dates) 

8. PERFORMING ORGANIZATION ·NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if 

contractor, provide name and mailing address.) 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-001 

9. SPONSORING ORGANIZATION- NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory 

Commission, and mailing address.) 

Same os above 

10. SUPPLEMENTARY NOTES 

Docket Nos. 50-352, 50-353 

11. ABSTRACT (200 words or less) 

This draft supplemental environmental impact statement has been prepared in response to an application submitted by Exelon 

Generation Company, LLC (Exelon) to renew the operating license for Limerick Generating Station, Units 1 and 2 (LGS) for an 

additional 20 years. 

This draft supplemental environmental impact statement includes the preliminary analysis that evaluates the environmental impacts 

of the proposed action and alternatives to the proposed action. Alternatives considered include natural gas combined-cycle (NGCC); 

supercritical pulverized coal; new nuclear; wind power; purchased power; and not renewing the license (the no action alternative). 

The U.S. Nuclear Regulatory Commission's preliminary recommendation is that the adverse environmental impacts oflicense 

renewal for LGS are not great enough to deny the option of license renewal for energy planning decisionmakers. This 

recommendation is based on the following: 

• the analysis and findings in NUREG 1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants; 

• the environmental report submitted by Exelon; 

• consultation with Federal, state, and local agencies; 

• the NRC's environmental review; and 

• consideration of public comments received during the scoping process 

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 

Limerick Generating Station, Units 1 and 2 

Limerick 

Exelon Generation Company, LLC 

Exelon 

Supplemental to the Generic Environmental Impact Statement, SEIS 

Generic Environmental Impact Statement, GElS 

National Environmental Policy Act, NEP A 

License Renewal 

NUREG-1437, Supplement 49 

NRC FORM 335 (12-201 0) 

13. AVAILABILITY STATEMENT 

unlimited 

14. SECURITY CLASSIFICATION 

(This Page) 

unclassified 

(This Report) 

unclassified 

15. NUMBER OF PAGES 

16. PRICE 


UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
NUREG-1437

Draft

Supplement 49

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Limerick Generating Station, Units 1 and 2