(a) An “environm entally preferred” alternative site is one for which the environm ental impacts are

sufficiently less than for the proposed site so that environmental preference for the alternative site can

be established (NRC 2000).

April 2006 9-1 NUREG-1817

9.0 Comparison of the Impacts of the Proposed and

Alternative Sites

The need to compare the proposed Grand Gulf early site permit (ESP) site with alternative sites

arises from the requirement in Section 102(2)(C)(iii) of the National Environmental Policy Act of

1969 (NEPA) (42 USC 4332(2)(C)(iii)) that environmental impact statements include an analysis |

of alternatives to the proposed action. The U.S. Nuclear Regulatory Commission (NRC) criteria |

to be employed in assessing whether a proposed ESP site is to be rejected in favor of an |

alternative site is based on whether the alternative site is “obviously superior” to the site

proposed by the applicant (Public Service Co. of New Hampshire 1977). An alternative site is |

“obviously superior” to the proposed site if it is “clearly and substantially” superior to the

proposed site (Rochester Gas & Electric Corp. 1978).

The standard of “obviously superior” “...is designed to guarantee that a proposed site will not be |

rejected in favor of an alternate unless, on the basis of appropriate study, the Commission can

be confident that such action is called for” (New England Coalition on Nuclear Pollution 1978). 

The “obviously superior” test is appropriate for two reasons. First, the analysis performed by |

NRC in evaluating alternative ESP sites is necessarily imprecise. Key factors considered in the

alternative site analysis, such as population distribution and density, hydrology, air quality,

aquatic and terrestrial ecological resources, aesthetics, land use, and socioeconomics are

difficult to quantify in common metrics. Given this difficulty, any evaluation of a particular site

must necessarily have a wide range of uncertainty. Second, the applicant’s proposed ESP site

has been analyzed in detail, with the expectation that most adverse environmental impacts

associated with the site have been identified. By design, the alternative sites have not |

undergone a comparable level of detailed study. For these reasons, a proposed ESP site may

not be rejected in favor of an alternative site when the alternative is “marginally better” than the |

proposed site, but only when it is “obviously superior” (Rochester Gas & Electric Corp. 1978).

NEPA does not require that a nuclear plant be constructed on the single best site for

environmental purposes. Rather, “...all that NEPA requires is that alternative sites be |

considered and that the effects on the environment of building the plant at the alternative sites

be carefully studied and factored into the ultimate decision” (New England Coalition on Nuclear

Pollution 1978).

The NRC staff’s review of alternative sites consists of a two-part sequential test for whether a |

site is “obviously superior” to the proposed site (NRC 2000). The first part of the test |

determines whether there are “environmentally preferred”(a) sites among the candidate ESP
Comparison of Impacts

NUREG-1817 9-2 April 2006

| sites. The staff considers whether the ESP applicant has (1) reasonably identified alternative

sites, (2) evaluated the likely environmental impacts of construction and operation at these

sites, and (3) used a logical means of comparing sites that led to the applicant’s selection of the

| proposed site. Based on the NRC staff’s independent review, the staff then determines

whether any of the alternative sites are environmentally preferable to the applicant’s proposed

ESP site.

If the staff determines that one or more alternative ESP sites are environmentally preferable,

| then it would compare the estimated costs (environmental, economic, and time) of constructing

the proposed nuclear power plant at the proposed site and at the environmentally preferable

site or sites (NRC 2000). To find an obviously superior alternative site, the staff must determine

that (1) one or more important aspects, either singly or in combination, of a reasonably

available alternative site are obviously superior to the corresponding aspects of the applicant’s

| proposed site, and (2) the alternative site does not have offsetting deficiencies in other

important areas.

9.1 Comparison of the Proposed Site with the Alternatives

The staff reviewed the environmental report submitted by System Energy Resources, Inc.

| (SERI) (SERI 2005) and supporting documentation and conducted site visits at the proposed

Grand Gulf ESP site and the three alternative sites. The staff found that SERI had reasonably

identified alternative sites, evaluated the environmental impacts of construction and operation,

and used a logical means of comparing sites. The following section summarizes the staff's

independent assessment of the proposed and alternative sites.

The staff’s characterization of the expected environmental impacts of constructing and

operating one or more new nuclear unit(s) at the Grand Gulf ESP site and alternative sites

within the bounds of SERI’s plant parameter envelope are summarized in Tables 9-1 and 9-2. 

Explanations for the particular characterizations are in Chapters 4 and 5 for the Grand Gulf

| ESP site, Section 8.5.1 for the River Bend site, Section 8.5.2 for the Pilgrim site, and

| Section 8.4.3 for the James A. FitzPatrick site. For those impacts to environmental resources

| for which the staff was unable to reach a single significance level in Chapters 4 and 5 for the

| Grand Gulf ESP site due to insufficient information, it is necessary to identify the most likely

| level of impact for the purposes of comparison to alternative sites. In the following analysis, the

| staff indicated a likely impact level for these unresolved issues based on professional

| judgement, experience, and consideration of controls likely to be imposed under required

| Federal, State, or local permits that would not be acquired until an application for a construction

| permit or combined license is underway. These considerations and assumptions were similarly

| applied at each of the alternative sites to provide a common basis for comparison. These

| impact levels are, therefore, best estimates of impacts that the staff used for its "obviously

| superior" determination. No new data were collected.
Comparison of Impacts

April 2006 9-3 NUREG-1817

Table 9-1. Comparison of the Construction Impacts at the Proposed and Alternative Early Site

Permit Sites

Impact Area Category Grand Gulf River Bend Pilgrim FitzPatrick |

Land use – – – –

Site and vicinity *Unresolved,

likely to be

SMALL

SMALL SMALL SMALL |

|

Power transmission line rightsof-way and offsite areas |*Unresolved,

likely to be

SMALL

SMALL SMALL to

MODERATE

SMALL to |

MODERATE |

Air quality SMALL SMALL SMALL SMALL

Water-related – – – –

Water use *Unresolved,

likely to be

SMALL

SMALL SMALL SMALL |

|

Water quality *Unresolved,

likely to be

SMALL

SMALL SMALL SMALL |

|

Ecological – – – –

Terrestrial ecosystems *Unresolved,

likely to be

MODERATE

MODERATE SMALL MODERATE to |

LARGE |

Aquatic ecosystems SMALL SMALL SMALL SMALL

Threatened and endangered

 species

SMALL SMALL to

MODERATE

MODERATE to

LARGE

SMALL

Socioeconomic – – – –

Physical impacts SMALL SMALL SMALL SMALL

Demography LARGE SMALL SMALL SMALL |

Social and economic LARGE

Beneficial

LARGE

Beneficial to

SMALL

Beneficial

MODERATE

Beneficial to

MODERATE

Adverse

MODERATE |

Beneficial to |

SMALL |

Beneficial |

Infrastructure and

 community services

MODERATE SMALL to

MODERATE(a)

MODERATE(b) SMALL to |

MODERATE(c) |

Historic and cultural resources SMALL SMALL SMALL SMALL

Environmental justice LARGE

Beneficial

SMALL SMALL SMALL

|

Nonradiological health SMALL SMALL SMALL SMALL

Radiological health SMALL SMALL SMALL SMALL

(a) Most of the adverse impact would be related to effects on transportation. |

(b) Most of the adverse impact would be related to effects on transportation and housing. |

(c) Most of the adverse impact would be related to effects on transportation near the facility. |

 * Impact level estimated for the purposes of comparison |
Comparison of Impacts

NUREG-1817 9-4 April 2006

Table 9-2. Comparison of the Operational Impacts at the Proposed and Alternative Early Site

Permit Sites

| Impact Area Category Grand Gulf River Bend Pilgrim FitzPatrick

Land use – – – –

Site and vicinity SMALL SMALL SMALL SMALL

| Power transmission line rights-

| of-way and offsite areas

SMALL SMALL SMALL SMALL

Air quality SMALL SMALL SMALL SMALL

Water-related – – – –

| Water use 

|

*Unresolved,

likely to be

SMALL

| SMALL SMALL SMALL

| Water quality

|

*Unresolved,

likely to be

SMALL

SMALL SMALL SMALL

Ecological – – – –

Terrestrial ecosystems(a) | SMALL SMALL SMALL to

MODERATE

SMALL

Aquatic ecosystems SMALL SMALL SMALL to

MODERATE

SMALL

Threatened and endangered

 species

SMALL SMALL SMALL to

MODERATE

SMALL

Socioeconomic – – – –

| Physical impacts SMALL SMALL SMALL to

MODERATE

SMALL

| Demography LARGE SMALL SMALL SMALL

| Social and economic

|

|

LARGE

Beneficial

LARGE

Beneficial to

SMALL

Beneficial

MODERATE

Beneficial to

MODERATE

Adverse

MODERATE

Beneficial to

| SMALL

| Beneficial

| Infrastructure and

 community services

MODERATE SMALL to

MODERATE

MODERATE(b) SMALL

Historic and cultural resources SMALL SMALL SMALL SMALL

Environmental justice LARGE

Beneficial

SMALL SMALL SMALL

Nonradiological health(a) | SMALL SMALL SMALL SMALL

Radiological health SMALL SMALL SMALL SMALL

| Impact of postulated accidents

|

|

|

|

SMALL for LWR

designs;

unresolved for

gas-cooled

reactors

SMALL SMALL SMALL

| (a) Electromagnetic field health effects are indeterminate.

(b) Most of the adverse impact would be related to effects on transportation and housing. 

| * Impact level estimated for the purposes of comparison
Comparison of Impacts

April 2006 9-5 NUREG-1817

Some environmental impacts considered for the Grand Gulf ESP site and for the alternative

sites are generic for all sites and, therefore, do not influence the comparison of impacts

between the Grand Gulf ESP site and the alternative sites. The generic environmental impacts

common to all sites are air quality, nonradiological and radiological health impacts, and

environmental impacts from postulated accidents and hydrologic alterations. Generic impacts

are discussed in Section 8.5.4. |

The environmental impact areas shown in Tables 9-1 and 9-2 have been evaluated using the

NRC’s three-level standard of significance – SMALL, MODERATE, or LARGE – based on the

Council on Environmental Quality guidelines and set forth in the footnotes to Table B-1 of

Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B:

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

destabilize nor noticeably alter any important attribute of the resource.

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

destabilize important attributes of the resource.

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

important attributes of the resource.

The staff determined the impact level from construction for most of the environmental issues at

the sites would be SMALL (see Table 9-1). Construction of transmission corridors for a new |

ESP facility at the Pilgrim and FitzPatrick sites would have SMALL to MODERATE impacts. For |

terrestrial ecology and threatened and endangered species, there are factors related to a site

that could cause the impact level to increase from SMALL to MODERATE and, in the case of

FitzPatrick, to LARGE because of probable impacts to forests and wetlands and associated

protected species at that site. In addition, socioeconomic and environmental justice impacts

range from SMALL to MODERATE adverse impacts in some aspects, and up to LARGE

beneficial impacts in other aspects, such as social and economic benefits because of tax |

revenue. These are explained more fully in Chapter 4 for the Grand Gulf ESP site and in

Chapter 8 for the alternative sites.

Similarly, the staff determined that the impact level from operations for most of the

environmental issues at most of the sites would be SMALL (see Table 9-2). Exceptions are |

aquatic and terrestrial ecosystems and threatened and endangered species at the Pilgrim site,

arising from potential impacts on the redbelly turtle. Additionally, social and economic impacts |

in socioeconomics at the alternative sites include LARGE to SMALL beneficial impacts |

principally due to added tax revenue and beneficial impacts on the local economy. Impacts at |

the Grand Gulf ESP site would be LARGE and beneficial. Impacts on infrastructure and |

community services would be MODERATE adverse at the Grand Gulf ESP site and SMALL to |

MODERATE adverse at the alternative sites. Environmental justice impacts wold be SMALL at |
Comparison of Impacts

NUREG-1817 9-6 April 2006

| the alternative sites, but up to LARGE and beneficial at the Grand Gulf ESP site. These are

explained more fully in Chapter 5 for the Grand Gulf ESP site and in Chapter 8 for the

alternative sites.

9.2 Environmentally Preferable Sites

This section discusses whether any of the three alternative sites are environmentally preferable

to the Grand Gulf ESP site. As noted in the introduction to this chapter, an “environmentally

preferred” alternative site is a site for which the environmental impacts are sufficiently less than

for the proposed site such that environmental preference for the alternative site can be

established. The issue of environmental preferability is discussed in Section 9.2.1 for

construction-related impacts and in Section 9.2.2 for operation-related impacts.

9.2.1 Construction

As shown in Table 9-1, the environmental impacts of construction at the Grand Gulf ESP site

are characterized by the staff as SMALL for most impact categories. The exceptions include:

| demographic impacts, which could be LARGE; the impacts on terrestrial ecosystems and

| infrastructure and community services, which may involve moderate impacts; and social and

| economic impacts, which would have LARGE beneficial impacts, largely due to the impact of

tax revenue.

At the three alternative ESP sites, the construction-related impacts are also predominately

characterized as SMALL. The exceptions are that (1) impacts on terrestrial ecosystems are

characterized as MODERATE at the River Bend site, SMALL to MODERATE at the Pilgrim site,

and as MODERATE to LARGE at the FitzPatrick site, (2) impacts on threatened and

endangered species are characterized as SMALL to MODERATE at the River Bend site,

SMALL at the FitzPatrick site, and MODERATE to LARGE at the Pilgrim site, and (3) impacts

| on infrastructure and community services are characterized as SMALL to MODERATE or

| MODERATE at the three alternative sites. The economy in the vicinity of the Pilgrim site could

also be negatively affected. The Grand Gulf ESP site and three alternative sites would also

have various beneficial impacts for the social and economic subcategories of economy

and taxes.

While there are some differences in the environmental impacts of construction at the proposed

and alternative ESP sites, the staff concludes that none of these differences is sufficient to

determine that any of the alternative sites is environmentally preferable to the Grand Gulf

ESP site.
Comparison of Impacts

April 2006 9-7 NUREG-1817

9.2.2 Operations

As shown in Table 9-2, the environmental impacts of operations at the Grand Gulf ESP site are 

characterized by the staff as SMALL for most impact categories. Demographic impacts at the

Grand Gulf ESP site could be LARGE. Potential impacts on infrastructure and community |

services could be MODERATE. Potential social and economic impacts and environmental |

justice impacts could be LARGE and beneficial, depending in large part on local capture of tax |

revenues. |

At the three alternative ESP sites, the operations-related impacts are also predominately

characterized as SMALL. The primary exception is the Pilgrim site, where ecological impacts

are characterized as SMALL to MODERATE, and the possibility of a MODERATE adverse

impact on local infrastructure and community services and on social and economic components

exists. Effects on social and economic components at the River Bend and FitzPatrick sites |

range from LARGE to SMALL beneficial, based on tax capture. |

While there are some differences in the environmental impacts of operation at the proposed

and alternative ESP sites, the staff concludes that none of these differences is sufficient to

determine that any of the alternative sites is environmentally preferable to the Grand Gulf

ESP site.

9.3 Obviously Superior Sites

None of the alternative sites was determined to be environmentally preferable to the Grand Gulf

ESP site. Therefore, none of the alternative sites is obviously superior to the Grand Gulf

ESP site.

9.4 Comparison with the No-Action Alternative

The no-action alternative refers to a scenario in which NRC denies the ESP request. Denial of

the ESP application would prevent early resolution of safety and environmental issues for the

site. These issues would have to be addressed during a future licensing action (ESP,

construction permit, or combined license), should an applicant decide to pursue construction |

and operation activities for a nuclear facility at the site at a later time.

In the event that NRC denies the ESP application, SERI could follow any of several paths

to satisfy its electric power needs including (1) seeking an ESP construction permit or combined |

license for a different location, (2) seeking a construction permit or combined license at the |

same location if the basis for ESP denial was reconciled, (3) purchasing power from other |

electricity providers, (4) establishing conservation and demand-side management programs, |
Comparison of Impacts

NUREG-1817 9-8 April 2006

(5) constructing new generation facilities other than nuclear at the Grand Gulf ESP site,

| (6) constructing new generation facilities at other locations, (7) delaying retirement of existing

| Entergy generating facilities, or (8) reactivating previously retired Entergy generating facilities. 

The preceding paths could be pursued individually or in combination. Each of the paths would

have associated environmental impacts.

No significant environmental impacts would be avoided by the no-action alternative because no

such impacts are caused by a site-suitability determination.

9.5 References

| Public Service Company of New Hampshire. (Seabrook Station, Units 1 and 2) CLI-77-8, 5

| NRC 503, 516 (1977).

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

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

New England Coalition on Nuclear Pollution. 1978. New England Coalition on Nuclear

Pollution v. NRC, 582 F.2d 87 (1st Circuit 1978).

Rochester Gas & Electric Corp. 1978. (Sterling Power Project Nuclear Unit No. 1), ALAB-502,

8 NRC 383, 397 (1978), affirmed, CLI-80-23, 11 NRC 731 (1980).

System Energy Resources, Inc. (SERI). 2005. Grand Gulf Site Early Site Permit Application.

Revision 2, Jackson, Mississippi. Available at http://www.nrc.gov/reading-rm/adams.html,

| Accession No. ML052780449.

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

| Reviews for Nuclear Power Plants. NUREG-1555, Office of Nuclear Reactor Regulation, 

| Washington, D.C. Available at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1555/.
April 2006 10-1 NUREG-1817

10.0 Conclusions and Recommendations

By letter dated October 16, 2003, System Energy Resources, Inc. (SERI), submitted an

application to the U.S. Nuclear Regulatory Commission (NRC) for an early site permit (ESP) for

property co-located with the existing Grand Gulf Nuclear Station (GGNS) near Port Gibson, |

Mississippi (SERI 2005). The proposed Grand Gulf ESP site is located in Claiborne County, |

Mississippi, approximately 40 km (25 mi) south of Vicksburg, Mississippi, 10 km (6 mi)

northwest of Port Gibson, Mississippi, and 60 km (37 mi) north-northeast of Natchez,

Mississippi. The Grand Gulf ESP site will include one or more nuclear power facilities to be

sited adjacent to the existing GGNS Unit 1. |

An ESP is a Commission approval of a location for siting for one or more nuclear power

facilities, and is separate from the filing of an application for a construction permit (CP) or

combined license (COL) for such a facility. An ESP application may refer to a reactor or reactor |

characteristics or plant parameter envelope, which is a set of postulated design parameters that |

bound the characteristics of a reactor or reactors that might be built at a selected site. 

Alternatively, an ESP may refer to a detailed reactor design. The ESP is not a license to build a

nuclear power plant; rather, the application for an ESP initiates a process undertaken to assess

whether a proposed site is suitable should the applicant decide to pursue a CP or COL.

Section 102 of the National Environmental Policy Act of 1969 (NEPA) (42 USC 4321 et seq.) |

directs that an environmental impact statement (EIS) be prepared for major Federal actions that

significantly affect the quality of the human environment. Subpart A of Title 10 of the Code of

Federal Regulations (CFR) Part 52 contains the NRC regulations related to ESPs. The NRC

implemented Section 102 of NEPA in 10 CFR Part 51. As set forth in 10 CFR 52.18, the |

Commission determined that an EIS will be prepared during the review of an application for an |

ESP. The purpose of SERI’s requested action, issuance of the ESP, is for the NRC to

determine whether the Grand Gulf ESP site is suitable for one or more new nuclear units by

resolving certain safety and environmental issues before SERI incurs the substantial additional

time and expense of designing and seeking approval to construct such facilities at the site. 

Under the provisions of 10 CFR 52.21, an ESP is described as a “partial construction permit.” 

An applicant for a CP or COL for a nuclear power plant or plants to be located at the site for

which an ESP was issued can reference the ESP, thus reducing the need to review siting

issues at that stage of the licensing process. However, issuance of a CP or COL to construct

and operate a nuclear power plant is a major Federal action that requires its own environmental |

impact statement in accordance with 10 CFR 51.20(b). |

Three primary issues—site safety, environmental impacts, and emergency planning—must be |

addressed in an ESP application. Likewise, in its review of the application, the NRC assesses |

the applicant’s proposal in relation to these issues and determines if the application meets the |
Conclusions and Recommendations

NUREG-1817 10-2 April 2006

requirements of the Atomic Energy Act of 1954 and NRC regulations. This EIS addresses the

| potential environmental impacts resulting from construction and operation of one or more new

nuclear units at the proposed and alternative sites.

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

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

an EIS and conduct scoping (68 FR 75656). The staff visited the Grand Gulf ESP site on

July 29, 2003, January 21, 2004, and April 12 and 13, 2004 to gather information and become

familiar with the site and its environs. The staff held a public scoping meeting on January 21,

2004, in Port Gibson, Mississippi to obtain public input on the scope of the environmental

review. Subsequent to the site visit and the scoping meeting and in accordance with NEPA and

| 10 CFR Part 51, the staff evaluated the potential environmental impacts of constructing and

| operating one or more new nuclear units at the Grand Gulf ESP site.

Included in this EIS are (1) the results of the NRC staff’s analyses, which consider and weigh

the environmental effects of the proposed action (issuance of the ESP) and of constructing and

operating one or more new nuclear units at the ESP site; (2) mitigation measures for reducing

or avoiding adverse effects; (3) the environmental impacts of the alternatives; and (4) the staff’s

| recommendation regarding the proposed action based on its environmental review.

During the preparation of this EIS, the staff reviewed the SERI environmental report; consulted

with Federal, State, Tribal, and local agencies; and conducted an independent review of the

issues following the guidance set forth in NRC’s review standard RS-002, Processing

Applications for Early Site Permits (NRC 2004). The review standard draws from the previously

published NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for

| Nuclear Power Plants (NRC 1987), and NUREG-1555, Standard Review Plans for

| Environmental Reviews for Nuclear Power Plants, Environmental Standard Review Plan

| (NRC 2000). In addition, the NRC considered public comments received during the scoping

| process and on the draft EIS. These comments and the staff’s responses are provided in

| Appendix D and E of this EIS.

| A 75-day comment period began on April 29, 2005 when the U.S. Environmental Protection

| Agency issued a Notice of Availability (70 FR 22308) of the draft EIS to allow members of the

| public to comment on the results of the NRC staff’s review. During this comment period, a

| public meeting was held in Port Gibson, Mississippi on June 28, 2005. At the meeting, the staff

| described the results of the NRC environmental review, answered questions related to the

review, and provided members of the public with information to assist them in formulating

their comments.
Conclusions and Recommendations

April 2006 10-3 NUREG-1817

Following the practice the staff used in the Generic Environmental Impact Statement for |

License Renewal of Nuclear Plants (NUREG-1437) (NRC 1996) and supplemental license

renewal EISs, environmental issues are evaluated using the three-level standard of significance

– SMALL, MODERATE, or LARGE – developed by NRC using guidelines from the Council on

Environmental Quality (40 CFR 1508.27). The footnote to Table B-1 of 10 CFR Part 51, |

Subpart A, Appendix B, provides the following definitions of the three significance levels:

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.

Mitigation measures were considered for each environmental issue and are discussed in the

appropriate sections. During its environmental review, the staff considered planned activities

and actions that SERI indicates it would take should it decide to apply for a CP or COL. Key |

activities and actions considered by the staff in determining the level of impacts to a resource

are discussed throughout the EIS and are listed in Appendix J. |

NEPA requires that an EIS include information on:

 C Any adverse environmental effects that cannot be avoided should the proposal be

implemented

 C Any irreversible and irretrievable commitments of resources that would be involved if the

proposed action is implemented

 C The relationship between local short-term uses of the environment and the maintenance

and enhancement of long-term productivity.

The NEPA information is provided in Sections 10.1 through 10.3. |

10.1 Unavoidable Adverse Environmental Impacts

Section 102(2)(C)(ii) of NEPA (42 USC 4321 et seq.) requires that an EIS include information |

on any adverse environmental effects that cannot be avoided should the proposed action be

implemented. Unavoidable adverse environmental impacts are those potential impacts of
Conclusions and Recommendations

NUREG-1817 10-4 April 2006

construction and operation of the proposed new unit(s) that cannot be avoided and for which no

practical means of mitigation are available.

If granted, the ESP will not authorize any activities by SERI that would have an environmental

impact. This is because SERI did not include a site redress plan in its application as provided

| by 10 CFR 52.17(c) and 10 CFR 52.25 and thus would not be authorized to perform any of the

activities provided by 10 CFR 50.10(e)(1). Consequently, there are no unavoidable adverse

environmental impacts associated with implementing the proposed action: granting an ESP to

| SERI for the Grand Gulf ESP site. However, issuance of an ESP may lead to construction and

operation of a new nuclear facility under a CP or COL, either of which would require their own

environmental review in accordance with 10 CFR Part 51. Although definitive assessment of

adverse environmental impacts from construction and operation of one or more new nuclear

| units at the Grand Gulf ESP site would be performed at the CP or COL stage for issues that

| were not resolved, a summary of the impacts based on the analyses presented in this EIS is

given below.

10.1.1 Unavoidable Adverse Impacts During Construction

Chapter 4 discusses the impacts from construction in detail. The unavoidable adverse impacts

related to construction are listed in Table 10-1 and summarized below. The primary

unavoidable adverse environmental impacts during construction would be related to land use. 

All construction activities for a new nuclear facility, including ground-disturbing activities, would

occur within the existing Grand Gulf site boundary. According to SERI, the area that would be

| affected as a result of permanent facilities is approximately 51 ha (125 ac). Much of this area

| was previously disturbed during construction of GGNS Unit 1. An additional 111 ha (275 ac)

would be disturbed on a short-term basis as a result of temporary activities and facilities and

| laydown areas (SERI 2005). Additional land may be needed for transmission lines.

Impacts of construction on the terrestrial ecology of the site would be both short-term and longterm. Construction of a new nuclear facility would result in the removal of approximately 59 ha

(145 ac) of upland hardwood forest and 43 ha (105 ac) of upland fields, with approximately

17 ha (43 ac) of forested habitat permanently lost. The Grand Gulf ESP site does not contain

any old-growth timber, nor any unique or sensitive plants or communities. Therefore,

construction activities would not noticeably reduce the local or regional diversity of plants or

| plant communities. Impacts associated with transmission line upgrades, including right-of-way

| expansion, are not known at this stage and would have to be evaluated at the CP/COL stage. 

There are no important animal species or habitats known on the Grand Gulf ESP site. No

areas designated by the U.S. Fish and Wildlife Service as critical habitat for threatened or

endangered species exist at or near the site; however, a number of terrestrial and aquatic

threatened or endangered plants or animals are known to exist in the vicinity of the site, and

preconstruction surveys would be required to ensure these species are protected. Loss of

upland and lowland forest would be noticeable. Construction would not permanently affect any 
Conclusions and Recommendations

April 2006 10-5 NUREG-1817

Table 10-1. Unavoidable Adverse Environmental Impacts from Construction

Impact Category

Adverse Impacts Based

on SERI’s Proposal

Actions to Mitigate

Impacts(a)

Unavoidable Adverse

Impacts

Land use Yes Comply with requirements

of applicable Federal,

State, and local permits

51 ha (125 ac) disturbed |

on a long-term basis;

111 ha (275 ac) additional |

land disturbed on a |

temporary basis

Hydrological and water

 use

Yes Obtain a Clean Water Act

401 certification prior to

site preparation activities;

construction would use

best management

practices

Dewatering systems

would depress the water

table in the general |

vicinity, but the impacts |

would be localized and

temporary. Some

dredging and shoreline

alterations

Ecological

Terrestrial

Aquatic

Yes

Yes

Conduct survey for

protected species prior to

construction

Stabilize embankments;

install silt fences

Loss of wildlife habitat, |

wetland, and hardwood |

forest |

Lowered water quality

onsite

Socioeconomic Yes Implement flexible

construction shifts

Potential impacts on

housing and educational

institutions in Claiborne

County

Radiological Yes Use as low as reasonably

achievable (ALARA)

principles

Dose to site preparation |

and construction workers |

Atmospheric and

 meteorological

Yes Implement actions to

reduce fugitive dust

Equipment emissions and

fugitive dust from

operation of earth-moving

equipment

Environmental justice Yes Not applicable -

dependent on actions of

the State

Dependent upon State tax

allocations, adverse

socioeconomic impacts

could be disproportionate

on local minority/lowincome community

(a) Additional mitigation measures are presented in Section 4.10. SERI’s commitments and the staff’s

assumptions regarding sources and levels of impact and mitigation are included in Appendix J. |
Conclusions and Recommendations

NUREG-1817 10-6 April 2006

| aquatic species, and the possibility of disturbance to the Federally threatened Louisiana black

bear is considered to be negligible. Socioeconomic impacts of construction include an increase

in traffic and potential strain on housing and educational institutions in Claiborne County. 

Atmospheric and meteorological impacts include fugitive dust from construction activities that

would be mitigated by dust control plans. Radiological doses to construction workers from

| GGNS Unit 1 are expected to be well below regulatory limits. Regarding environmental justice,

the impacts are dependent on the allocation of tax revenues between the State and

Claiborne County.

10.1.2 Unavoidable Adverse Impacts During Operation

Chapter 5 provides a detailed discussion of the impacts from operation. The unavoidable

adverse impacts related to operation are listed in Table 10-2 and summarized below. The

unavoidable adverse impacts from operation for land use are small. Hydrological, water use,

| and water-quality impacts during operation are likely to be small resulting from very limited use

of Mississippi River flow. Ecological impacts are also small for both ecosystems and

threatened and endangered species because of the lack of key habitat at the site. 

Socioeconomic impacts are primarily increased demand for services in Claiborne County and

| Port Gibson, along with impacts on infrastructure and community services in this area. 

| Meteorological and radiological impacts are expected to be negligible. Pollutants emitted

during operations are considered insignificant.

10.2 Irreversible and Irretrievable Commitments of

Resources

| Section 102(2)(C)(v) of NEPA (42 USC 4321 et seq.) requires that an EIS include information

on any irreversible and irretrievable commitments of resources that would occur should the

proposed action be implemented. There will be no irreversible and irretrievable commitments of

resources should the proposed action be implemented. If granted, the ESP will not authorize

any activities by SERI that would have an environmental impact. SERI did not include a site

| redress plan in its application as provided by 10 CFR 52.17(c) and 10 CFR 52.25 and thus

| would not be authorized to perform any of the activities as provided by 10 CFR 50.10(e)(1). 

Because the proposed action therefore does not involve commitment of resources, a complete

assessment of irreversible and irretrievable commitments of resources would be performed at

| the CP or COL stage if SERI is granted an ESP and later applies for a CP or COL. This issue

is, therefore, not resolved.

| Irretrievable commitments of resources during construction of the proposed new unit(s)

generally would be similar to that of any major construction project. The actual commitment of

construction resources (concrete, steel, and other building materials) would depend on the
Conclusions and Recommendations

April 2006 10-7 NUREG-1817

reactor design selected at the CP or COL stage. Hazardous materials such as asbestos would

not be used, if possible. If materials such as asbestos were used, it would be in accordance

with safety regulations and practices. The actual estimate of construction materials would be

performed at the CP or COL stage when the reactor design is selected. 

Table 10-2. Unavoidable Adverse Environmental Impacts from Operation

Impact Category

Adverse Impacts Based

on SERI’s Proposal

Actions to Mitigate

Impacts(a)

Unavoidable Adverse

Impacts

Land use Yes Follow local land

management plans

Upgrade/modification of

existing transmission corridors

probably needed

Hydrological and

 water use |

Yes Comply with State

discharge permit limits

Use of Mississippi River water |

Ecological

Terrestrial

|

Aquatic

Yes

Yes

Use best management

practices

Use impingement/

entrainment screens for

intake; diffuser for thermal

discharge

Wildlife collisions with

structures

Losses of species in larval

state

Socioeconomic Yes Implement flexible work

hours and road

improvements

Potential impacts on housing

and educational institutions in

Claiborne County; increased

traffic

Radiological Yes Use as low as is

reasonably achievable

(ALARA) principles

Dose to workers, the public,

and biota

Atmospheric and

 meteorological

Yes Comply with State permit |

limits

Equipment emissions, cooling |

tower drift and electromagnetic

field exposure

Environmental

 justice

Yes Not applicable - dependant

on actions of the State

Dependent upon State tax

allocations, adverse

socioeconomic impacts could

be disproportionate on local

minority/low-income community

(a) Additional mitigation measures are presented in Section 5.11. SERI’s commitments and the staff’s

assumptions regarding sources and levels of impact and mitigation are included in Appendix J. |
Conclusions and Recommendations

NUREG-1817 10-8 April 2006

The staff expects that the use of construction materials in the quantities associated with those

expected for the new ESP unit or units, while irretrievable, would be of small consequence, with

respect to the availability of such resources.

The main resource that would be irretrievably committed during operation of a new nuclear unit

or units would be uranium. The availability of uranium ore and existing stockpiles of highly

enriched uranium in the United States and Russia that could be processed into fuel is sufficient,

so that the irreversible and irretrievable commitment would be of small consequence.

10.3 Relationship Between Short-Term Uses and Long-Term

Productivity of the Human Environment

| Section 102(2)(C)(iv) of NEPA (42 USC 4321 et seq.) requires that an EIS include information

on the relationship between local short-term uses of the environment and the maintenance and

enhancement of long-term productivity. There will be no short-term use of the environment

should the proposed action be implemented because SERI is not authorized to perform any site

preparation activities. The evaluation of the relationship between local short-term uses of the

environment and the maintenance and enhancement of long-term productivity for the

construction and operation of the ESP unit or units can only be performed by discussing the

benefits of operating the unit. The benefit is the production of electricity. In accordance with

10 CFR 52.18, an EIS for an ESP does not need to include an assessment of the benefits of

| the proposed action. However, an assessment of the relationship between local short-term

uses of the environment and the maintenance and enhancement of long-term productivity for

| the construction and operation of one or more new nuclear unit or units would be performed at

| the CP or COL stage should SERI be granted an ESP and later seek a CP or COL. This issue

is, therefore, not resolved. 

10.4 Cumulative Impacts

The staff considered the potential cumulative impacts resulting from construction and operation

of the proposed unit(s) in the context of past, present, and future actions at the Grand Gulf ESP

| site in Chapter 7 of this EIS. For each impact area, the staff determined that the potential

cumulative impact resulting from construction and operation would be generally SMALL, and

further mitigation would not be warranted. The geographical area over which past, present, and

future actions could contribute to cumulative impacts is dependent on the type of action

| considered. Several impact issues were not resolved due to lack of necessary information. 

| These issues have the potential for MODERATE or LARGE adverse impacts and,

consequently, cumulative are not resolved and would have to be addressed in a future

| environmental impact statement, should an applicant for a CP or COL reference an ESP for the

| Grand Gulf ESP site. 
Conclusions and Recommendations

April 2006 10-9 NUREG-1817

10.5 Staff Conclusions and Recommendations

The staff’s recommendation to the Commission related to the environmental impacts of the

proposed action is that the ESP should be issued. The staff’s evaluation of the safety and

emergency preparedness aspects of the proposed action are documented in a separate safety |

evaluation report prepared in accordance with 10 CFR Part 52 (NRC 2005). This |

recommendation is based on (1) the environmental report submitted by SERI (2005); |

(2) consultation with Federal, State, Tribal, and local agencies; (3) the staff’s independent

review; (4) the staff’s consideration of comments received from the public; (5) the assessments |

summarized in this EIS, including the potential mitigation measures identified in the

environmental report and in this EIS; and (6) the staff’s conclusion there are no environmentally

preferable or obviously superior alternative sites.

A comparative summary showing the staff’s estimate of the environmental significance of

locating one or more new nuclear units at the Grand Gulf ESP site and at any of the alternative |

sites is shown in Table 10-3. The estimated environmental significance of the no-action

alternative, or denial of the ESP application, is also shown. Table 10-3 shows that the

significance of the environmental impacts of the construction and operation of one or more new |

nuclear units is generally SMALL for all impact categories at all sites, with the exception of |

certain ecological, socioeconomic, and environmental justice categories. The alternative sites

may have environmental effects in at least some categories that reach MODERATE or LARGE

significance. The staff concludes that none of the alternative sites assessed are obviously

superior to the Grand Gulf ESP site.

The range of impacts estimated by the NRC staff for resolved issues is predicated on certain |

assumptions; these are identified in each section and in Appendix J. Should the Commission |

issue an ESP for the Grand Gulf ESP site, the staff will verify that the assumptions identified in |

Appendix I and Appendix J remain applicable. In addition, certain issues are not considered to |

be resolved because of a lack of information. A CP or COL applicant referencing an ESP for |

the Grand Gulf ESP site would need to provide the necessary information for these issues, if |

the proposed action ultimately would affect the resources associated with these issues. |
Conclusions and Recommendations

NUREG-1817 10-10 April 2006

Table 10-3. Summary of Environmental Significance of Nuclear Power Plant Construction

and Operation at the Grand Gulf Early Site Permit Site, at Alternative Sites, and

for the No-Action Alternative

Proposed

Action

No-Action

Alternative Alternative Site Options

Impact Category

ESP at

Grand Gulf Denial of ESP River Bend Pilgrim FitzPatrick

| Land use

|

|

|

|

|

Unresolved,

likely to be

SMALL for

construction

and SMALL

for operation

SMALL SMALL SMALL to

MODERATE

| SMALL to

| MODERATE

| Ecology

|

|

|

|

|

|

SMALL for

operation and

Unresolved,

likely to be

MODERATE

for

construction

SMALL SMALL to

MODERATE

SMALL to

LARGE

SMALL to

LARGE

| Water use and quality 

|

|

Unresolved,

likely to be

SMALL

SMALL SMALL SMALL SMALL

Air quality SMALL SMALL SMALL SMALL SMALL

Radiological and

 nonradiological health

SMALL SMALL SMALL SMALL SMALL

| Socioeconomic

|

|

|

LARGE

Beneficial

SMALL LARGE

Beneficial to

MODERATE

Adverse

MODERATE

Beneficial to

MODERATE

Adverse

MODERATE

Beneficial to

MODERATE

Adverse

Historic and cultural

 resources

SMALL SMALL SMALL SMALL SMALL

| Environmental justice

|

LARGE

Beneficial

SMALL SMALL SMALL SMALL

10.6 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing

of Production and Utilization Facilities.” 
Conclusions and Recommendations

April 2006 10-11 NUREG-1817

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Early Site Permits,

Standard Design Certifications, and Combined Licenses for Nuclear Power Plants.” 

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

Part 1508, “Terminology and Index.”

68 FR 75656. December 31, 2003. “System Energy Resources, Inc., Grand Gulf Site; Notice

of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process.” 

Federal Register, U.S. Nuclear Regulatory Commission.

70 FR 22308. April 29, 2005. “Environmental Impact Statements; Notice of Availability.” |

Federal Register, U.S. Environmental Protection Agency. |

Atomic Energy Act of 1954. 42 USC 2011, et seq. |

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

System Energy Resources, Inc. (SERI). 2005. Grand Gulf Site Early Site Permit Application.

Revision 2, Jackson, Mississippi. Available at http://www.nrc.gov/reading-rm/adams.html,

Accession No. ML052780449. |

U.S. Nuclear Regulatory Commission (NRC). 1987. Standard Review Plan for the Review of

Safety Analysis Reports for Nuclear Power Plants. NUREG-0800, Washington, D.C. Available

at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0800/.

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

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

Available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/. |

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

Reviews for Nuclear Power Plants. NUREG-1555, Office of Nuclear Reactor Regulation, |

Washington, D.C. Available at http://www.nrc.gov/reading-rm/doc- |

collections/nuregs/staff/sr1555/. |

U.S. Nuclear Regulatory Commission (NRC). 2004. Processing Applications for Early Site

Permits. RS-002, Washington, D.C. Available at

http://www.nrc.gov/reactors/new-licensing/esp/esp-public-comments-rs-002.html, Accession |

No. ML040700236. |

U.S. Nuclear Regulatory Commission (NRC). 2005. Safety Evaluation Report of Early Site |

Permit Application in the matter of System Energy Resources, Inc., a subsidiary of Entergy |
Conclusions and Recommendations

NUREG-1817 10-12 April 2006

| Corporation, for the Grand Gulf Early Site Permit Site. Available at

| http://www.nrc.gov/reactors/new-licensing/esp/grand-gulf.html. Accession No. ML052860041.